peterson/puritan, inc. sit e

39
•'''' X /(*?? Peterson/Puritan, Inc. Site Cumberland and Lincoln, Rhode Island DRAFT Operable Unit 1 Feasibility Study Work Plan August 1992 Prepared/or: CPC International Inc. Englewood Cliffs, New Jersey Prepared by: ABB Environmental Services, Inc. Wakefield, Massachusetts

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PetersonPuritan Inc SiteCumberland and Lincoln Rhode Island

DRAFT

Operable Unit 1Feasibility Study Work Plan

August 1992

PreparedorCPC International IncEnglewood Cliffs New Jersey

Prepared byABB Environmental Services IncWakefield Massachusetts

PETERSONPURITAN INC SITE

FEASIBILITY STUDY (FS) FOR OU 1

DRAFT

FEASIBILITY STUDY WORK PLAN

Prepared for

CPC International Inc

Englewood Cliffs New Jersey

Prepared by

ABB Environmental Services Inc

Wakefield Massachusetts

Project No 0596024

AUGUST 1992

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

TABLE OF CONTENTS

Section Title Page No

10 INTRODUCTION 1-1

11 SITE DESCRIPTION 1-1 12 SITE HISTORY 1-2 13 SITE CONTAMINATION SUMMARY 1-4

20 FEASIBILITY STUDY PROCESS 2-1

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES 2-1 211 Data Review 2-2 212 Compilation of Applicable or Relevant and Appropriate

Requirements 2-2 213 Development of Remedial Action Objectives 2-3 214 Development of General Response Actions 2-4 215 Identification of Area or Volume of Media 2-4 216 Technology Identification and Screening 2-4 217 Assembly of Remedial Alternatives 2-5

22 SCREENING OF REMEDIAL ALTERNATIVES 2-6 23 POST-SCREENING DATA COLLECTION 2-7 24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 2-8 25 FEASIBILITY STUDY REPORT 2-9

30 PROJECT ORGANIZATION AND SCHEDULE 3-1

GLOSSARY OF ACRONYMS FIGURES REFERENCES

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

LIST OF FIGURES

Figure Title

1-1 Site Location

1-2 Primary Source Area OU 1

1-3 Conceptual Site Model for OU 1

2-1 Alternative Development Process

2-2 Identification of Potential Remedial Technologies

3-1 Project Organization

3-2 FS Schedule Primary Source Area OU 1

SECTION 1

10 INTRODUCTION

This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc

(ABB-ES formerly C-E Environmental) on behalf of CPC International Inc (CPC) The FS will

address Operable Unit (OU) No 1 of the PetersonPuritan Inc Site in Cumberland Rhode Island

(Figure 1-1)

The FS program will be conducted hi accordance with the US Environmental Protection Agency

(USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA

Interim Final (USEPA 1988) and the National Contingency Plan (NCP) (USEPA 1990)

The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1

The remainder of Section 10 presents a brief site description and history Section 20 of this Work

Plan describes the components of the FS process and Section 30 presents the project organization

and schedule

11 SITE DESCRIPTION

The following site description and environmental setting was derived from various primary

references and initially compiled for the Remedial Investigation Report for the PetersonPuritan

Inc Site prepared by ABB-ES in February 1990

The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located near the

village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The site study area

as defined in the Consent Order of 1987 includes the CCL plant and extends approximately two

miles down the Blackstone Valley and as much as one-half mile to the northeast and to the

southwest of the Blackstone River (Figure 1-1)

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1-1

SECTION 1

The field investigations associated with the Remedial Investigation (RI) have addressed the site study

area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This

FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area

on the eastern side of the Blackstone River extending down the valley from the Lonza Inc facility

now owned by Pacific Anchor Chemical (PAC) to a point approximately 2000 feet south of the CCL

plant

The Blackstone River meanders through the valley on a comparatively flat floodplain between

subdued river terraces The industrial park facilities are located on the northeastern (Cumberland)

side of the river The CCL plant is located at the boundary between the valley sediments and the

steeper bedrock upland The PAC facility is located at the base of the upland and most of the other

industrial facilities in the area are underlain by the valley sediments

A small stream referred to in this investigation as Brook A flows westward between the PAC and

CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted

along Martin Street westward to the Blackstone River This drainage feature carries primarily

industrial and some stormwater discharges to the river

The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers

headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-

Providence area The canal flows parallel to the river and was historically used to transport

materials by barge within the local river corridor

1J SITE HISTORY

The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites

of the Industrial Revolution in America The river provided power supplied water and served as a

conduit for material transportation and wastewater discharge Many of the industrial plants in the

valley discharged untreated wastewaters directly to the Blackstone River before regulations were

enacted Metcalf amp Eddy (September 1948 p 11) estimated that within the Blackstone Valley

Sewer District (BVSD) there were approximately 34 million gallons per day (mgd) of industrial

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1-2

SECTION 1

wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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1-3

SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

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2-1

SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

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3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

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SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

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Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

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INTERNATIONAL

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P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

PETERSONPURITAN INC SITE

FEASIBILITY STUDY (FS) FOR OU 1

DRAFT

FEASIBILITY STUDY WORK PLAN

Prepared for

CPC International Inc

Englewood Cliffs New Jersey

Prepared by

ABB Environmental Services Inc

Wakefield Massachusetts

Project No 0596024

AUGUST 1992

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

TABLE OF CONTENTS

Section Title Page No

10 INTRODUCTION 1-1

11 SITE DESCRIPTION 1-1 12 SITE HISTORY 1-2 13 SITE CONTAMINATION SUMMARY 1-4

20 FEASIBILITY STUDY PROCESS 2-1

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES 2-1 211 Data Review 2-2 212 Compilation of Applicable or Relevant and Appropriate

Requirements 2-2 213 Development of Remedial Action Objectives 2-3 214 Development of General Response Actions 2-4 215 Identification of Area or Volume of Media 2-4 216 Technology Identification and Screening 2-4 217 Assembly of Remedial Alternatives 2-5

22 SCREENING OF REMEDIAL ALTERNATIVES 2-6 23 POST-SCREENING DATA COLLECTION 2-7 24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 2-8 25 FEASIBILITY STUDY REPORT 2-9

30 PROJECT ORGANIZATION AND SCHEDULE 3-1

GLOSSARY OF ACRONYMS FIGURES REFERENCES

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

LIST OF FIGURES

Figure Title

1-1 Site Location

1-2 Primary Source Area OU 1

1-3 Conceptual Site Model for OU 1

2-1 Alternative Development Process

2-2 Identification of Potential Remedial Technologies

3-1 Project Organization

3-2 FS Schedule Primary Source Area OU 1

SECTION 1

10 INTRODUCTION

This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc

(ABB-ES formerly C-E Environmental) on behalf of CPC International Inc (CPC) The FS will

address Operable Unit (OU) No 1 of the PetersonPuritan Inc Site in Cumberland Rhode Island

(Figure 1-1)

The FS program will be conducted hi accordance with the US Environmental Protection Agency

(USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA

Interim Final (USEPA 1988) and the National Contingency Plan (NCP) (USEPA 1990)

The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1

The remainder of Section 10 presents a brief site description and history Section 20 of this Work

Plan describes the components of the FS process and Section 30 presents the project organization

and schedule

11 SITE DESCRIPTION

The following site description and environmental setting was derived from various primary

references and initially compiled for the Remedial Investigation Report for the PetersonPuritan

Inc Site prepared by ABB-ES in February 1990

The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located near the

village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The site study area

as defined in the Consent Order of 1987 includes the CCL plant and extends approximately two

miles down the Blackstone Valley and as much as one-half mile to the northeast and to the

southwest of the Blackstone River (Figure 1-1)

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The field investigations associated with the Remedial Investigation (RI) have addressed the site study

area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This

FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area

on the eastern side of the Blackstone River extending down the valley from the Lonza Inc facility

now owned by Pacific Anchor Chemical (PAC) to a point approximately 2000 feet south of the CCL

plant

The Blackstone River meanders through the valley on a comparatively flat floodplain between

subdued river terraces The industrial park facilities are located on the northeastern (Cumberland)

side of the river The CCL plant is located at the boundary between the valley sediments and the

steeper bedrock upland The PAC facility is located at the base of the upland and most of the other

industrial facilities in the area are underlain by the valley sediments

A small stream referred to in this investigation as Brook A flows westward between the PAC and

CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted

along Martin Street westward to the Blackstone River This drainage feature carries primarily

industrial and some stormwater discharges to the river

The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers

headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-

Providence area The canal flows parallel to the river and was historically used to transport

materials by barge within the local river corridor

1J SITE HISTORY

The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites

of the Industrial Revolution in America The river provided power supplied water and served as a

conduit for material transportation and wastewater discharge Many of the industrial plants in the

valley discharged untreated wastewaters directly to the Blackstone River before regulations were

enacted Metcalf amp Eddy (September 1948 p 11) estimated that within the Blackstone Valley

Sewer District (BVSD) there were approximately 34 million gallons per day (mgd) of industrial

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wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

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development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

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identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

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The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

TABLE OF CONTENTS

Section Title Page No

10 INTRODUCTION 1-1

11 SITE DESCRIPTION 1-1 12 SITE HISTORY 1-2 13 SITE CONTAMINATION SUMMARY 1-4

20 FEASIBILITY STUDY PROCESS 2-1

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES 2-1 211 Data Review 2-2 212 Compilation of Applicable or Relevant and Appropriate

Requirements 2-2 213 Development of Remedial Action Objectives 2-3 214 Development of General Response Actions 2-4 215 Identification of Area or Volume of Media 2-4 216 Technology Identification and Screening 2-4 217 Assembly of Remedial Alternatives 2-5

22 SCREENING OF REMEDIAL ALTERNATIVES 2-6 23 POST-SCREENING DATA COLLECTION 2-7 24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 2-8 25 FEASIBILITY STUDY REPORT 2-9

30 PROJECT ORGANIZATION AND SCHEDULE 3-1

GLOSSARY OF ACRONYMS FIGURES REFERENCES

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

LIST OF FIGURES

Figure Title

1-1 Site Location

1-2 Primary Source Area OU 1

1-3 Conceptual Site Model for OU 1

2-1 Alternative Development Process

2-2 Identification of Potential Remedial Technologies

3-1 Project Organization

3-2 FS Schedule Primary Source Area OU 1

SECTION 1

10 INTRODUCTION

This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc

(ABB-ES formerly C-E Environmental) on behalf of CPC International Inc (CPC) The FS will

address Operable Unit (OU) No 1 of the PetersonPuritan Inc Site in Cumberland Rhode Island

(Figure 1-1)

The FS program will be conducted hi accordance with the US Environmental Protection Agency

(USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA

Interim Final (USEPA 1988) and the National Contingency Plan (NCP) (USEPA 1990)

The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1

The remainder of Section 10 presents a brief site description and history Section 20 of this Work

Plan describes the components of the FS process and Section 30 presents the project organization

and schedule

11 SITE DESCRIPTION

The following site description and environmental setting was derived from various primary

references and initially compiled for the Remedial Investigation Report for the PetersonPuritan

Inc Site prepared by ABB-ES in February 1990

The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located near the

village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The site study area

as defined in the Consent Order of 1987 includes the CCL plant and extends approximately two

miles down the Blackstone Valley and as much as one-half mile to the northeast and to the

southwest of the Blackstone River (Figure 1-1)

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SECTION 1

The field investigations associated with the Remedial Investigation (RI) have addressed the site study

area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This

FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area

on the eastern side of the Blackstone River extending down the valley from the Lonza Inc facility

now owned by Pacific Anchor Chemical (PAC) to a point approximately 2000 feet south of the CCL

plant

The Blackstone River meanders through the valley on a comparatively flat floodplain between

subdued river terraces The industrial park facilities are located on the northeastern (Cumberland)

side of the river The CCL plant is located at the boundary between the valley sediments and the

steeper bedrock upland The PAC facility is located at the base of the upland and most of the other

industrial facilities in the area are underlain by the valley sediments

A small stream referred to in this investigation as Brook A flows westward between the PAC and

CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted

along Martin Street westward to the Blackstone River This drainage feature carries primarily

industrial and some stormwater discharges to the river

The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers

headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-

Providence area The canal flows parallel to the river and was historically used to transport

materials by barge within the local river corridor

1J SITE HISTORY

The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites

of the Industrial Revolution in America The river provided power supplied water and served as a

conduit for material transportation and wastewater discharge Many of the industrial plants in the

valley discharged untreated wastewaters directly to the Blackstone River before regulations were

enacted Metcalf amp Eddy (September 1948 p 11) estimated that within the Blackstone Valley

Sewer District (BVSD) there were approximately 34 million gallons per day (mgd) of industrial

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SECTION 1

wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

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SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

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SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

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The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

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FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

PETERSONPURITAN INC SITE DRAFT FEASIBILITY STUDY

WORK PLAN FOR OU 1

LIST OF FIGURES

Figure Title

1-1 Site Location

1-2 Primary Source Area OU 1

1-3 Conceptual Site Model for OU 1

2-1 Alternative Development Process

2-2 Identification of Potential Remedial Technologies

3-1 Project Organization

3-2 FS Schedule Primary Source Area OU 1

SECTION 1

10 INTRODUCTION

This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc

(ABB-ES formerly C-E Environmental) on behalf of CPC International Inc (CPC) The FS will

address Operable Unit (OU) No 1 of the PetersonPuritan Inc Site in Cumberland Rhode Island

(Figure 1-1)

The FS program will be conducted hi accordance with the US Environmental Protection Agency

(USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA

Interim Final (USEPA 1988) and the National Contingency Plan (NCP) (USEPA 1990)

The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1

The remainder of Section 10 presents a brief site description and history Section 20 of this Work

Plan describes the components of the FS process and Section 30 presents the project organization

and schedule

11 SITE DESCRIPTION

The following site description and environmental setting was derived from various primary

references and initially compiled for the Remedial Investigation Report for the PetersonPuritan

Inc Site prepared by ABB-ES in February 1990

The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located near the

village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The site study area

as defined in the Consent Order of 1987 includes the CCL plant and extends approximately two

miles down the Blackstone Valley and as much as one-half mile to the northeast and to the

southwest of the Blackstone River (Figure 1-1)

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SECTION 1

The field investigations associated with the Remedial Investigation (RI) have addressed the site study

area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This

FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area

on the eastern side of the Blackstone River extending down the valley from the Lonza Inc facility

now owned by Pacific Anchor Chemical (PAC) to a point approximately 2000 feet south of the CCL

plant

The Blackstone River meanders through the valley on a comparatively flat floodplain between

subdued river terraces The industrial park facilities are located on the northeastern (Cumberland)

side of the river The CCL plant is located at the boundary between the valley sediments and the

steeper bedrock upland The PAC facility is located at the base of the upland and most of the other

industrial facilities in the area are underlain by the valley sediments

A small stream referred to in this investigation as Brook A flows westward between the PAC and

CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted

along Martin Street westward to the Blackstone River This drainage feature carries primarily

industrial and some stormwater discharges to the river

The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers

headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-

Providence area The canal flows parallel to the river and was historically used to transport

materials by barge within the local river corridor

1J SITE HISTORY

The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites

of the Industrial Revolution in America The river provided power supplied water and served as a

conduit for material transportation and wastewater discharge Many of the industrial plants in the

valley discharged untreated wastewaters directly to the Blackstone River before regulations were

enacted Metcalf amp Eddy (September 1948 p 11) estimated that within the Blackstone Valley

Sewer District (BVSD) there were approximately 34 million gallons per day (mgd) of industrial

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SECTION 1

wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

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SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

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SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

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SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

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YES

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FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 1

10 INTRODUCTION

This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc

(ABB-ES formerly C-E Environmental) on behalf of CPC International Inc (CPC) The FS will

address Operable Unit (OU) No 1 of the PetersonPuritan Inc Site in Cumberland Rhode Island

(Figure 1-1)

The FS program will be conducted hi accordance with the US Environmental Protection Agency

(USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA

Interim Final (USEPA 1988) and the National Contingency Plan (NCP) (USEPA 1990)

The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1

The remainder of Section 10 presents a brief site description and history Section 20 of this Work

Plan describes the components of the FS process and Section 30 presents the project organization

and schedule

11 SITE DESCRIPTION

The following site description and environmental setting was derived from various primary

references and initially compiled for the Remedial Investigation Report for the PetersonPuritan

Inc Site prepared by ABB-ES in February 1990

The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located near the

village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The site study area

as defined in the Consent Order of 1987 includes the CCL plant and extends approximately two

miles down the Blackstone Valley and as much as one-half mile to the northeast and to the

southwest of the Blackstone River (Figure 1-1)

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SECTION 1

The field investigations associated with the Remedial Investigation (RI) have addressed the site study

area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This

FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area

on the eastern side of the Blackstone River extending down the valley from the Lonza Inc facility

now owned by Pacific Anchor Chemical (PAC) to a point approximately 2000 feet south of the CCL

plant

The Blackstone River meanders through the valley on a comparatively flat floodplain between

subdued river terraces The industrial park facilities are located on the northeastern (Cumberland)

side of the river The CCL plant is located at the boundary between the valley sediments and the

steeper bedrock upland The PAC facility is located at the base of the upland and most of the other

industrial facilities in the area are underlain by the valley sediments

A small stream referred to in this investigation as Brook A flows westward between the PAC and

CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted

along Martin Street westward to the Blackstone River This drainage feature carries primarily

industrial and some stormwater discharges to the river

The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers

headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-

Providence area The canal flows parallel to the river and was historically used to transport

materials by barge within the local river corridor

1J SITE HISTORY

The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites

of the Industrial Revolution in America The river provided power supplied water and served as a

conduit for material transportation and wastewater discharge Many of the industrial plants in the

valley discharged untreated wastewaters directly to the Blackstone River before regulations were

enacted Metcalf amp Eddy (September 1948 p 11) estimated that within the Blackstone Valley

Sewer District (BVSD) there were approximately 34 million gallons per day (mgd) of industrial

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SECTION 1

wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

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SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

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SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

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YES

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Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 1

The field investigations associated with the Remedial Investigation (RI) have addressed the site study

area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This

FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area

on the eastern side of the Blackstone River extending down the valley from the Lonza Inc facility

now owned by Pacific Anchor Chemical (PAC) to a point approximately 2000 feet south of the CCL

plant

The Blackstone River meanders through the valley on a comparatively flat floodplain between

subdued river terraces The industrial park facilities are located on the northeastern (Cumberland)

side of the river The CCL plant is located at the boundary between the valley sediments and the

steeper bedrock upland The PAC facility is located at the base of the upland and most of the other

industrial facilities in the area are underlain by the valley sediments

A small stream referred to in this investigation as Brook A flows westward between the PAC and

CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted

along Martin Street westward to the Blackstone River This drainage feature carries primarily

industrial and some stormwater discharges to the river

The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers

headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-

Providence area The canal flows parallel to the river and was historically used to transport

materials by barge within the local river corridor

1J SITE HISTORY

The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites

of the Industrial Revolution in America The river provided power supplied water and served as a

conduit for material transportation and wastewater discharge Many of the industrial plants in the

valley discharged untreated wastewaters directly to the Blackstone River before regulations were

enacted Metcalf amp Eddy (September 1948 p 11) estimated that within the Blackstone Valley

Sewer District (BVSD) there were approximately 34 million gallons per day (mgd) of industrial

ABB Environmental Services Inc cpcfswkp 05960

1-2

SECTION 1

wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

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SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

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SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

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YES

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Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 1

wastewater being discharged directly to streams and approximately 35 mgd discharged to sewers

The industrial wastewaters had high levels of dissolved organic matter

In a study by the US Geological Survey (USGS) Johnston and Dickerman (1974b) concluded that

waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal

sewage and textile mills By 1983 the Blackstone River in the area of the CCL plant was rated as

Class C under the Clean Water Act of 1972 Class C includes surface waters that are suitable for

fish and wildlife habitat recreational boating and industrial processes and cooling and that have

good aesthetic value Class C waters are not suitable for bathing other recreational uses

agricultural uses or public water supply (even after treatment)

Groundwater from the Blackstone Valley aquifer was first developed in the study area as a

municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street

well The Town of Lincoln installed three wells in the Quinnville wellfield area west of the

Blackstone River between 1957 and 1975 By 1979 the Martin Street well was closed due to

elevated concentrations of iron and manganese The Quinnville wellfield was also shut down in the

1970s due to iron and manganese concentrations exceeding federal drinking water standards and the

unsuccessful attempt to obtain federal grants to remove these inorganics

Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source

of water to the most heavily pumped wells in the Blackstone River area and that under conditions

of sustained pumping most wells close to streams derive virtually all of their water from streamflow

They concluded that infiltration of organically contaminated streamflow was a possible causative

factor of high manganese concentrations in water from heavily pumped wells

The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the

permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville

wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations ranging

from estimated values below the detection limit to 017 micrograms per liter (^g1) (Malcolm Pirnie

1983)

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SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

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SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

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2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

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2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

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25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

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Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 1

During a routine state-wide testing program for municipal wells in October 1979 by the Rhode

Island Department of Health volatile organic chemicals (VOCs) from a limited suite of analytes

were detected in the Quinnville wells Chemicals found to be present in these wells were 111shy

trichloroethane and tetrachloroethene Some of the concentrations exceeded USEPA guidance

concentrations for drinking water causing the Quinnville wellfield to be closed (GZA 1982) Several

attempts were made by the Town of Lincoln to flush the contaminants but no long term

improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department

periodically used one or more of the affected wells when contaminant concentrations declined below

the USEPA drinking water standards but with those exceptions the wells have remained closed

since October 1979

With the expansion of the municipal water supply systems residential wells in Cumberland and

Lincoln were abandoned There are no known residential wells currently operating in the

Blackstone Valley aquifer within OU 1 or the site study area Local industrial use of groundwater

began in the Nineteenth Century and peaked in the 1960s With the exception of Okonite the

industrial use of groundwater in the area was discontinued by the early 1970s The supply well at

Okonite was closed on February 21 1981 when VOCs were detected by GZA (GZA 1982 p 5)

13 SITE CONTAMINATION SUMMARY

The presence of contaminants (summarized below) forms the basis for conducting the FS further

site characterization will be provided in the RI report This discussion is based largely on the

investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April

1988)

Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary

constituents affecting groundwater quality were chlorinated solvents and ketones respectively The

distribution of VOCs in groundwater is consistent with identified source area and past (pumping)

and present (non-pumping) groundwater flow patterns

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

ABB Environmental Services Inc cpcfswkp 05960

2-1

SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

ABB Environmental Services Inc cpcfswkp 05960

2-2

SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

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SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

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2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

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Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

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E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 1

The VOC contaminant plume centered around the CCL property has the highest contaminant

concentrations in groundwater monitoring wells located just south and southwest of the CCL plant

In cross section the highest concentrations were detected near the shallow portion of the aquifer in

the recharge area of the Blackstone River Elevated concentrations of VOCs have also been

identified beneath the current chemical tank farm in subsurface soils on the CCL property

Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During

operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath

the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville

wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn

beneath the river previously will eventually be flushed via discharge to the river

The highest concentrations of the ketone plume were detected on the PAC property based on 1988

and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of

the PAC property Flowlines originating beneath PAC tend to follow a path westward to the

Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the

southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that

of CCL

Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1-3) identifying the

contaminant sources from the CCL and PAC properties migration pathways and potential receptors

The models will be refined as the RIFS process proceeds

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

ABB Environmental Services Inc cpcfswkp 05960

2-1

SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

ABB Environmental Services Inc cpcfswkp 05960

2-2

SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

ABB Environmental Services Inc cpcfswkp 05960

2-3

SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

ABB Environmental Services Inc cpcfswkp 05960

2-4

SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

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and Analytical Support to Acquire Additional Data

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- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

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Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

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INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

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A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

ABB Environmental Services Inc cpcfswkp 05960

2-1

SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

ABB Environmental Services Inc cpcfswkp 05960

2-2

SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

ABB Environmental Services Inc cpcfswkp 05960

2-3

SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

ABB Environmental Services Inc cpcfswkp 05960

2-4

SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

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Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

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J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

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A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

20 FEASIBILITY STUDY PROCESS

Based on the preliminary results of the RI a single FS will be conducted which addresses the

Primary Source Area (OU 1) The FS will consist of the following tasks

development of remedial alternatives

screening of remedial alternatives

post-screening data collection (optional)

detailed analysis of remedial alternatives

FS report

The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated

media in OU 1 The remedial alternatives must be (1) protective of the public health and

environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) as amended by the

Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and

local requirements as stipulated in the Consent Order of 1987 The selection of a remedial

alternative may need to 1) utilize permanent solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for

treatment that reduces toxicity mobility and volume as a principal element or provide an

explanation as to why it does not

21 DEVELOPMENT OF REMEDIAL ALTERNATIVES

The development of alternatives task consists of the following subtasks as shown in Figure 2-1

data review

compilation of Applicable or Relevant and Appropriate Requirements

development of remedial action objectives

ABB Environmental Services Inc cpcfswkp 05960

2-1

SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

ABB Environmental Services Inc cpcfswkp 05960

2-2

SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

ABB Environmental Services Inc cpcfswkp 05960

2-3

SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

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SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

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GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

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SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

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SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

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Identify Potential Treatment and

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Evaluate Process Options Based on Effectiveness Implementability

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Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

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J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

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FIGURE 3-1 PROJECT ORGANIZATION

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

development of general response actions

identification of area or volume of media

technology identification and screening

assembly of remedial alternatives

211 Data Review

The Development of Alternatives work element will begin with a thorough review of the RI data and

information (both Phase I and Phase II) human health risk assessment and ecological risk

assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater

if this approach is believed to simplify the remediation process A review of data from the planned

vapor extraction pilot study will also be made Additionally pumping test data from the recovery

well and municipal well fields will be renewed

212 Compilation of Applicable or Relevant and Appropriate Requirements

Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the

appropriate extent of site clean-up develop site-specific remedial response objectives develop

remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA

1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs

and State of Rhode Island requirements when applied legally and consistently statewide

Applicable requirements are federal and state requirements that specifically address substances or

contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and

state requirements that while not legally applicable can be applied if the site circumstances are

sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate

Applicable requirements and relevant and appropriate requirements are considered to have the same

weight with respect to requiring compliance at CERCLA site cleanups

ABB Environmental Services Inc cpcfswkp 05960

2-2

SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

ABB Environmental Services Inc cpcfswkp 05960

2-3

SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

ABB Environmental Services Inc cpcfswkp 05960

2-4

SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

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Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

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INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

SARA also identifies a To Be Considered (TBC) category which includes federal and state

nonregulatory requirements such as criteria advisories and guidance documents TBCs do not have

the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs

can be used to ensure that a remedy is protective

ARARs must be attained for hazardous substances remaining on-site at the completion of the

remedial action Remedial action implementation should also comply with ARARs (and TBCs as

appropriate) to protect public health and the environment Generally ARARs pertain to either

contaminant levels or to performance or design standards to ensure protection at all points of

potential exposure ARARs are divided into three general categories chemical- location- and

action-specific

ABB-ES will identify federal and state chemical- and action-specific ARARs and TBCs Chemical-

and location-specific ARARs will be identified using RI site characterization data Action-specific

ARARs with respect to each proposed alternative and compliance of each alternative with all

ARARs will be discussed in the detailed analysis of alternatives section

213 Development of Remedial Action Objectives

Remedial action objectives consist of medium-specific or operable unit-specific goals to protect

public health and the environment based on the ARARs the risk assessment goals (human health

and ecological) and technology based cleanup goals Remedial action objectives specify

contaminants of concern by medium exposure routes and receptors and target clean-up levels

(TCLs) for contaminants of concern For compounds or media of concern for which no ARARs

exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be

determined on the basis of risk assessments as well as the evaluation of expected exposures and

associated risks of each alternative Final TCLs will be used to delineate the limits of contamination

and to refine general response actions

ABB Environmental Services Inc cpcfswkp 05960

2-3

SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

ABB Environmental Services Inc cpcfswkp 05960

2-4

SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

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N

1

111

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(0

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8

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bull bullbull 2 fe a

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AC

E

|

cc

iLU

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AC

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laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

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amp u0

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3 5shyx

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8 A ^ v

PA

C

PR

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TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

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2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

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ID _^

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in z S shy

oc Ul OQ S

Io

Ugt C

jshy

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5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

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E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

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OW

N B

OV

EW

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IVE

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ME

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IVE

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ILE

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5 lt 5O ui amp oc o8 u joc

ocQ

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tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

214 Development of General Response Actions

General response actions are general purpose statements describing probable remediation activities

at a given site to meet remedial action objectives Preliminary general response actions will be

identified based upon understanding of the site and remedial action objectives based on readily

available criteria and standards (eg ARARs TCLs) These preliminary general response actions

will be refined throughout the FS as technologies and action-specific ARARs are identified and as a

more complete understanding of a site and acceptable exposure levels is reached Like remedial

action objectives general response actions may be medium- operable unit or site-specific For

example typical general response actions for groundwater contamination would be

No ActionInstitutional Actions

Containment Actions

CollectionTreatment Actions

215 Identification of Area or Volume of Media

Areas or volumes of media to which general response actions might be applied will be determined

based on acceptable exposure levels potential exposure routes site conditions and the nature and

extent of contamination The effectiveness of applying remedial alternatives to hot spots will be

considered The areas or volumes may be refined as alternatives are assembled and evaluated

216 Technology Identification and Screening

Documented information and data on technologies will be reviewed by ABB-ES to identify those

technologies which best satisfy general response actions This initial assessment will involve a

literature search of USEPA-published reports environmental journals and vendor information

Results of this search will be presented as an identification table including the general response

action category the specific technology and a brief technology description

ABB Environmental Services Inc cpcfswkp 05960

2-4

SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

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bull bullbull 2 fe a

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Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

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ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

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DC UJ ffl S

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CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

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jshy

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^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

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n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

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vice

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AS

EA

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i I i I i MI 2 it raquo5 V)11 = deg pound gt D

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5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

The screening process assesses each technology for its probable effectiveness and implementability

with regard to site-specific conditions known and suspected contaminants and affected

environmental media The effectiveness evaluation focuses on (1) whether the technology is

capable of handling the estimated areas or volumes of media and meeting the contaminant reduction

goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting

human health during the construction and implementation phase and (3) how proven and reliable

the technology is with respect to the contaminants and conditions at the site Implementability

encompasses both the technical and institutional feasibility of implementing a technology These

factors will be incorporated into two screening criteria waste- and site-limiting characteristics

Waste-limiting characteristics consider the effect exerted on a technology by contaminant types

individual compound properties (eg volatility solubility specific gravity adsorption potential and

biodegradability) and interactions that may occur between mixtures of compounds (eg reactions

and increased solubility) Site-limiting characteristics consider site-specific physical features

including topography buildings underground utilities available space and proximity to sensitive

operations Waste-limiting characteristics largely determine effectiveness and performance of a

technology site-limiting characteristics affect implementability of a technology Figure 2-2 identifies

potential remedial technologies for the different contaminated media in OU 1

217 Assembly of Remedial Alternatives

A range of remedial alternatives will be developed by combining technologies retained through

screening which as a group address all remedial response objectives established for a particular site

The range of alternatives will reflect (1) a no action alternative (2) various volumes of media

andor areas of the site (3) several degrees of long-term management and (4) differences in

reduction of mobility toxicity and volume

Development of a complete range of treatment alternatives may not be practical in some cases For

example it would not be reasonable to develop a treatment or disposal alternative to eliminate the

need for long-term management of the contaminated soils beneath the CCL plant because of the

ABB Environmental Services Inc cpcfswfcp 05960

2-5

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

VE

LOP

ME

NT

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

SC

RE

EN

ING

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

extreme costs that would be involved For each alternative developed a narrative description will be

provided including the logic used to develop the alternative and other information describing its

implementation

22 SCREENING OF REMEDIAL ALTERNATIVES

During screening alternatives are quantitatively defined to allow differentiation with respect to the

criteria of effectiveness implementability and cost This is achieved through refinement of estimates

of volume or areas of contaminated media the size and configuration of onsite extraction and

treatment systems as well as time frames to achieve remediation goals rates or flows of treatment

spacial requirements distances for disposal technologies and required permits for off-site actions

and imposed limitations Innovative technologies may be carried through the screening process if

there is reason to believe they offer significant advantages in the form of better treatment

performance implementability fewer adverse impacts or lower costs

The three screening criteria conform with remedy selection requirements of CERCLA and the NCP

The screening step eliminates impractical alternatives or higher cost alternatives (ie order of

magnitude) that provide little or no increase in effectiveness or implementability over their lower-

cost counterparts By eliminating these alternatives early more time and effort can be devoted to

detailed analysis of the more promising alternatives The no-action alternative will not be evaluated

according to screening criteria it will pass through screening to be evaluated during detailed analysis

as a baseline for the other retained alternatives (USEPA 1988)

The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health

and the environment and the degree to which treatment alternatives reduce the mobility toxicity or

volume of the waste material Both short- and long-term aspects will be evaluated Short-term

aspects refer to risks posed to the community and workers during the construction and

implementation period the alternatives compliance with chemical- and location-specific ARARs

and the time required to achieve remedial action objectives Long-term aspects which apply after

the remedial action has been completed consider the magnitude of the remaining risk due to

ABB Environmental Services Inc cpcfswkp 05960

2-6

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

VE

LOP

ME

NT

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

SC

RE

EN

ING

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 2

untreated wastes and waste residuals and the adequacy and reliability of specific technical

components and control measures

Implementability is a measure of technical and administrative feasibility In the assessment of short-

term technical feasibility ABB-ES will consider the availability of a technology for construction or

mobilization and operation as well as compliance with action-specific ARARs during the remedial

action After the remedial action is complete technical feasibility focuses on operation and

maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated

wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory

and other agencies and the availability of required services and trained specialists or operators

The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy

of cost estimates during screening is not critical the focus is to identify costs of primary technical

components to facilitate a consistent comparative analysis among the alternatives with relative

accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the

cost estimates improves beyond the screening process (USEPA 1988)

The information discussed in Subsections 21 and 22 Development and Screening of Remedial

Alternatives respectively will be compiled and presented as an Initial Screening of Alternatives

deliverable ABB-ES will prepare a Comment Response Package for comments received on this

deliverable and incorporate these comments into the context of the Draft FS Report

2J POST-SCREENING DATA COLLECTION

It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and

evaluate potential remedial technologies and develop remedial alternatives If future data gaps are

identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional

field investigations

ABB Environmental Services Inc cpcfswkp 05960

2-7

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

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LOP

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NT

OF

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ME

DIA

L A

LTE

RN

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IVE

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SC

RE

EN

ING

OF

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ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

24

SECTION 2

DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

The detailed analysis presents the relevant information that allows a site remedy selection The

detailed analysis of each remedial alternative includes the following

detailed descriptions of each remedial alternative with emphasis on application of

the various technologies as components in the alternative and

detailed analysis of each remedial alternative relative to the evaluation criteria

established to address CERCLA requirements

The detailed description of each remedial alternative will emphasize the technologies used and the

components of each alternative Where appropriate the description will present preliminary design

calculations process flow diagrams sizing of key components preliminary site layouts and a

discussion of limitations assumptions and uncertainties concerning each alternative

As part of the criteria analysis remedial alternatives will be examined with respect to requirements

stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation

of long-term effectiveness and related considerations for each remedial alternative ABB-ES will

address the CERCLA statutory requirements by evaluating each remedial alternative and presenting

individual analyses based on the following criteria

Threshold Criteria (must be met by each alternative)

overall protection of human health and the environment

compliance with ARARs

Primary Criteria (basis of alternative evaluation)

long-term effectiveness and permanence

reduction of toxicity mobility or volume through treatment

short-term effectiveness

ABB Environmental Services Inc cpcfswicp 05960

2-8

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

VE

LOP

ME

NT

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

SC

RE

EN

ING

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

25

SECTION 2

implementability

cost

These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting

Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) and

Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two

criteria and will be addressed after comments on the RIFS and Proposed Plan have been received

FEASIBILITY STUDY REPORT

The Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed

Analysis of Alternatives Additionally the Draft FS Report will include a comparative analysis of

alternatives The comparative analysis will identify the advantages and disadvantages of each

alternative relative to one another hi relation to the seven evaluation criteria

The FS Report will be issued as follows

Draft

Receipt of Regulator comments

Revised Draft

Public Comment

Final

ABB Environmental Services Inc cpcfswkp 05960

2-9

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

VE

LOP

ME

NT

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

SC

RE

EN

ING

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

THIS PAGE INTENTIONALLY LEFT BLANK

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

VE

LOP

ME

NT

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

SC

RE

EN

ING

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 3

30 PROJECT ORGANIZATION AND SCHEDULE

The project organization structure is illustrated in Figure 3-1 Details of the function and

responsibilities of key project personnel are described below

The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for

conducting the FS project including

ensuring the appropriateness and adequacy of the technical or engineering services

provided for a specific task

developing the technical approach and level of effort required to address each

element of a task

supervising day-to-day conduct of the work including integrating the efforts of all

supporting disciplines and subcontractors

overseeing the preparation of all reports and plans

providing for quality control and quality review during the performance of the work

ensuring technical integrity clarity and usefulness of task work products and

developing and monitoring task schedules

Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional

Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests

risk assessment and ARARs In this position Mr Heislein will be responsible for

ABB Environmental Services Inc cpcfswkp 05960

3-1

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

VE

LOP

ME

NT

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

SC

RE

EN

ING

OF

RE

ME

DIA

L A

LTE

RN

AT

IVE

S

DE

TA

ILE

D E

VA

LUA

TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 3

identification of ARARs

coordination with the RI and risk assessment teams to identify and correct any data

gaps that may occur

based on the RI Report identify and analyze feasible alternatives for remediation of

contaminated media

coordinate and conduct appropriate process identification and testing evaluations

and

coordinate and oversee the production of the FS Report in accordance with the

contract requirements that accurately reflect the data and project findings

The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray

PhD PE Mr Doug Pierce PO and Mr William Siok Mr Murray will serve as technical

director and will be responsible for the overall technical quality of the work performed he will also

serve as chairman of the review committee The function of this group of senior technical andor

management personnel is to provide guidance and oversight on the technical aspects of the project

This is accomplished through periodic reviews of the services provided to ensure they represent the

accumulated experience of the firm are being produced in accordance with corporate policy and

live up to the objectives of the program as established by ABB-ES and CPC

The FS schedule presented in Figure 3-2 assumes the following review elements for primary and

secondary documents

Regulatory review of Screening of Remedial Alternatives Deliverable 15 days

ABB-ES Preparation of Comment Response Package 15 days

Regulatory review of Comment Response Package 15 days

Regulatory review of Draft FS 15 days

ABB Environmental Services Inc cpcfswkp 05960

3-2

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

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ON

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INH

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N

1

111

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8

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bull bullbull 2 fe a

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]

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]t

LU

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lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

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bdquogt

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5

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AC

E

|

cc

iLU

Ul

SU

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AC

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laquo W + lt

111 LU (9rUJ 3g z

cc X

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HIS

TO

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1

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amp u0

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3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

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c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

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ltUJ poundii UJ oc

lti

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zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

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T T ^EoSgUJ U Q

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gt laquopound8 laquogt ffi O lt(0

lti

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gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

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2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

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in I

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^ Sjw|poundltltii ^^ - U

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Io

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jshy

i ugt

^ ^ sr f

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M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

EW

i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

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TIO

N O

F

1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SECTION 3

The reporting requirements for the Initial Screening of Alternatives deliverable specify the above

schedule only through Preparation of Comment Response Package Finalization of the interim

document will be in the context of the Draft FS Report

ABB Environmental Services Inc cpcfswkp 05960

3-3

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

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amp

^

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lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

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I

5

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AC

E

|

cc

iLU

Ul

SU

RF

AC

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laquo W + lt

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cc X

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HIS

TO

RIC

1

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PE

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amp u0

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C

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OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

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ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

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U-Q

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CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

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ID _^

^ Sjw|poundltltii ^^ - U

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oc Ul OQ S

Io

Ugt C

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^ ^ sr f

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M gUl

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B E

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1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

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vice

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EA

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L A

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5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

THIS PAGE INTENTIONALLY LEFT BLANK

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

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bdquogt

I

5

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SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

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laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

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I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

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T T ^EoSgUJ U Q

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lti

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gZreg i gtl pound B W o

TT TT

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s

U-Q

DC UJ ffl S

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^o^u

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CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

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jshy

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^ ^ sr f

s shyui 0

M gUl

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| Q5

AB

B E

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n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

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i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

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LOP

ME

NT

OF

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L A

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DE

TA

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1 ft gt 8 3 S i 1 b raquo 2

r I 5 i E sij

^ M 111 3 2 UL OJ

5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

GLOSSARY OF ACRONYMS

ABB-ES ARAR

BVSD

CERCLA CPC

FS

NCP

OampM OU

PAC

RI

SARA

TBC TCL

USEPA USGS

VOCs

ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement

Blackstone Valley Sewer District

Comprehensive Environmental Response Compensation and Liability Act CPC International Inc

Feasibility Study

National Contingency Plan

operation and maintenance Operable Unit

Pacific Anchor Chemical

Remedial Investigation

Superfund Amendments and Reauthorization Act of 1986

to be considered target clean-up level

microgram per liter US Environmental Protection Agency US Geological Survey

volatile organic chemicals

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

H|S xJ

UJ

bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

g

amp

^

cc111 pound

lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

E LU (ji a cc 2

HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

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sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

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CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

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vice

s Inc

AS

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OW

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DE

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ME

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ING

OF

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AT

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tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

THIS PAGE INTENTIONALLY LEFT BLANK

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

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bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

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T

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1

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8

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]

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lt0

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1

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TO

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TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

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INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

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ID _^

^ Sjw|poundltltii ^^ - U

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Io

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jshy

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E1 i 8 I 2

IM

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Ser

vice

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AS

EA

BR

OW

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ME

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5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

SOURCE USGS TOPOGRAPHIC 75 MWUTE SERIES PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975

2000 4000

IOCATION SCALE FEET

FIGURE 1-1 ABBEnvironmental SITE LOCATIONABBB Services Inc PETERSON PURITAN INC SITE

ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

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8

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J sect C

]

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]t

LU

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lt0

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OCCsectpoundS =

1

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AC

E

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cc

iLU

Ul

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laquo W + lt

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TO

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1

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C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

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o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

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lti

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gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

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i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

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n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

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i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

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LOP

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OF

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L A

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5 lt 5O ui amp oc o8 u joc

ocQ

Mbull1

tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

CM Ul

tc111ffi

o

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

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8

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bull bullbull 2 fe a

J sect C

]

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LU

g

amp

^

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lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

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SU

RF

AC

E

|

cc

iLU

Ul

SU

RF

AC

E

i -^|j bull ~K

laquo W + lt

111 LU (9rUJ 3g z

cc X

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HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

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sect

o

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lti

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gZreg i gtl pound B W o

TT TT

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s

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CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

jshy

i ugt

^ ^ sr f

s shyui 0

M gUl

5 3 Q B laquo 2poundi ~ W

| Q5

AB

B E

nviro

n

1 gt s sect Toin IM U UJ ^i H O O 5 8 +2 -J ui lt lt3 2lt c x S St

E1 i 8 I 2

IM

P

Ser

vice

s Inc

AS

EA

BR

OW

N B

OV

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i I i I i MI 2 it raquo5 V)11 = deg pound gt D

DE

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LOP

ME

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AT

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tc obull

C lti

lt

lt3 u lt^ bull bull ltJ | 1

ii

A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

THIS PAGE INTENTIONALLY LEFT BLANK

  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

bull uizo bull

bull shy^5

o laquoo 3 QCLU bull bull CD

a 1 iiii sect A

LA

CT

DE

RM

AL

C

ON

TAC

T

INH

ALA

TIO

N

1

111

LL CC

(0

_j

8

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bull bullbull 2 fe a

J sect C

]

C 4 bull

]t

LU

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amp

^

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lt0

2UJ Ushy

OCCsectpoundS =

1

J ^

J

i

bdquogt

I

5

i

SU

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AC

E

|

cc

iLU

Ul

SU

RF

AC

E

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laquo W + lt

111 LU (9rUJ 3g z

cc X

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HIS

TO

RIC

1

| P

RO

PE

RT

Y

FA

RM

SP

I

ISTO

RIC

SU

amp u0

i1ii li

a 5 c

pound L

3 5shyx

bdquo u

8 A ^ v

PA

C

PR

OP

ER

TY

s

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

PETERSON PURITAN INC SITE ABB Services Inc FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

CM ^

sect5g|

UJ

H2

o 1E sectgi I

E i

s pound H OC mdashIQC I ti E_jiuai -Jice o llttlaquoi

c QQQ-2 3 -I SQ

2 IIT 0= 2 a UJ CO

2oi

1 lt o

pound

N^

5s

i UJ ll

ltUJ poundii UJ oc

lti

x gtbulluia

zo sect-H-ishylaquoH N O 010 ecu 3O Oz CI

O c

M or o- -J og^u5a deggtz~secty|3 sect Pgt Edeg

ipillh-ccd

T T ^EoSgUJ U Q

UJ E

oc UJ DO

sect

o

s UJ

ampui

o =

gt laquopound8 laquogt ffi O lt(0

lti

Zv uj5o E a sect| u cOa I sect5g

gZreg i gtl pound B W o

TT TT

ii 5S3 2 IB I

s

U-Q

DC UJ ffl S

I O

J

^o^u

i

i 1 shyUJ O CD r

CD d)ltco

2 i

INTERNATIONAL

PROJECT MANAGER

P EXNER PE

FS LEADER

D HEISLEIN

ARABS

N ROUSE

ASSESSMENT

J SULLIVAN

ABB Environmental Services Inc

ASEA BROWN BOVERI

CORPORATE OFFICER

D ERTZ P E

OUAU1Y ASSURANCE

E COOL Ph D

REVIEW COMMITTEE

W MURRAY Ph D D PIERCE PG

W SIOK

ENVIRONMENTAL ENGINEERING

D BELCHER

FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24

fl ^ III ^F ^^ V1 UJ Z LJ

co^t ltZ 111 O rfi mdash1 lt

1 sectsecto^raquo Ugt

E Hi -0 S

s bullsect58^^ a ^_ ^ Q Hgt I- J S E Q O C I 3 Pz OQ-S31 W Z s O

in I

pof o-eo 5 zoc =i n

ID _^

^ Sjw|poundltltii ^^ - U

in z S shy

oc Ul OQ S

Io

Ugt C

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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  1. barcode 16778
  2. barcodetext SEMS Doc ID 16778

Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies

and Analytical Support to Acquire Additional Data

- Amend QAPPFSP HSP and Work Plan as Appropriate

- Repeat Steps in Rl Site Characterization

SOURCE USEPA 1Mraquo

Determine Remedial Action Objectives Based on Risk Assessment and ARARs

Identification

Develop General Response Actions Descnbing Areas or Volumes of Media to wnich

Containment Treatment or bull Removal Actions may be Applied

Identify Potential Treatment and

Disposal Technologies and Screen Based on

Technical Implementability

Evaluate Process Options Based on Effectiveness Implementability

and Relative Cost to Select a Representative Process for each

Technology Type

YES

Combine Media-Specific Technologies into

Alternatives

Screening of Alternatives

FIGURE 2-1 ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental

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A III

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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INTERNATIONAL

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FIGURE 3-1 PROJECT ORGANIZATION

PETERSON PURITAN INC SITE FEASIBILITY STUDY WORK PLAN

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

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REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

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  2. barcodetext SEMS Doc ID 16778

REFERENCES

US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Tide 40 Part 300 March 8 1990 Final Rule Federal Register VoL 55 No 46 pp 8666 et seq

ABB Environmental Services Inc cpcfswkp 05960

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