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0 0 0 0 1 8 R-31-7-4-7 SP- -F-l FINAL WORK PLAN REMEDIAL INVESTIGATION/ FEASIBILITY STUDY OF ALTERNATIVES SPIEGELBERG AND RASMUSSEN SITES GREEN OAK TOWNSHIP LIVINGSTON COUNTY, MICHIGAN STATE OF MICHIGAN CONTRACT NO. 1611 NUS PROJECT NO. 6050/6051 NUS JOB NO. US39/U538 DECEMBER 1984 NUS CORPORATiCDN A Halliburton Company

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Page 1: WORK PLAN REMEDIAL INVESTIGATION/ - … · WORK PLAN REMEDIAL INVESTIGATION/ ... INITIAL REMEDIAL MEASURE PLANNING 3-60 ... is an information gathering and evaluation phase

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R-31-7-4-7SP- -F-lFINAL

WORK PLAN

REMEDIAL INVESTIGATION/FEASIBILITY STUDY OF ALTERNATIVES

SPIEGELBERG AND RASMUSSEN SITESGREEN OAK TOWNSHIP

LIVINGSTON COUNTY, MICHIGAN

STATE OF MICHIGAN CONTRACT NO. 1611

NUS PROJECT NO. 6050/6051NUS JOB NO. US39/U538

DECEMBER 1984

NUSCORPORATiCDN

A Halliburton Company

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IMUSCORPORATION

Park West TwoCiifl Mine RoaoPrttsburgn. PA 15275'412-788-1080

R-31-7-4-7SP- -F-lFINAL

WORK PLAN

REMEDIAL INVESTIGATION/FEASIBILITY STUDY OF ALTERNATIVES

SPIEGELBERG AND RASMUSSEN SITESGREEN OAK TOWNSHIP

UVINGSTON COUNTY, MICHIGAN

STATE OF MICHIGAN CONTRACT NO. 1611

NUS PROJECT NO. 6050/6051NUS JOB NO. US39/U538

DECEMBER 1984

SUBMITTED FOR NUS BY:

:.i<x?.^

APPROVED:

GEORGE e. GARDNER, P.E.PROJECT MANAGER

vG.A SGROMANAGER,MICHIGAN REGIONAL OFFICE

Halliburton Company

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CONTENTS

SECTION PAGE

1.0 INTRODUCTION 1-11.1 SUPERFUND, THE NATIONAL CONTINGENCY PLAN AND THE 1-1

PROGRAM FOR SPIEGELBERG AND RASMUSSEN SITES1.2 hnooLCM ASSESSMENT 1-41.3 TECHNICAL Afrno>kcw }-&

2.0 PROBLEM ASSESSMENT 2-'\2.1 BACKGROUND INFORMATION 2-12.1.1 DESCRIPTION OF SITE 2-12.1.2 ADJACENT LAND USE 2-32.1.3 HISTORY OF THE SITES 2-42.2 ENVIRONMENTAL SETTING 2-72.2.1 PHYSIOGRAPHY 2-72.2.2 GEOLOGY 2-82.2.3 SURFACE WATER HYDROLOGY AND DRAINAGE 2-92.2.4 HYDROGEOLOGY 2-92.2.5 AIR QUALITY 2-112.2.6 ECOLOGY 2-112.2.7 SOCIOECONOMICS 2-112.3 SUMMARY OF DATA AVAILABLE 2-122.4 HEALTH, SAFETY, AND ENVIRONMENTAL ASSESSMENT 2-142.4.1 PUBLIC HEALTH AND SAFETY 2-142.4.2 ENVIRONMENT 2-152.5 DATA LIMITATIONS 2-15

3.0 TECHNICAL APPROACH 3-13.1 INTRODUCTION 3-13.2 PHASE I - REMEDIAL INVESTIGATION 3-3

• TASK 1.0 - INITIAL ACTIVITIES 3-3- SUBTASK 1.1 - WORK PLAN PREPARATION 3-3- SUBTASK 1.2 - DESCRIPTION OF THE 3-3

CURRENT SITUATION- SUBTASK 1.3 - PROJECT MANAGEMENT 3-4

• TASK 2.0 - PREHNVESTIGAT10N SUPPORT ACTIVITIES 3-4- SUBTASK 2.1 - TOPOGRAPHIC MAPPING. 3-4

GROUND SURVEYING, AND WARNING SIGNS- SUBTASK 2.2 - HEALTH, SAFETY, AND GENERAL 3-6

SITE RECONNAISSANCE- SUBTASK 2.3 - SITE HEALTH AND SAFETY PLAN 3-7- SUBTASK 2.4 - QUALITY ASSURANCE AND 3-8

QUALITY CONTROL PLAN- SUBTASK 2.5 - SITE OPERATIONS PLAN 3-10- SUBTASK 2.6 - MOBILIZATION OF FIELD EQUIPMENT 3-11- SUBTASK 2.7 - SUBCONTRACTOR MANAGEMENT 3-11

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CONTENTS (CONTINUED)

SECTION RAGfc

' - SUBTASK 2.8 - PRELIMINARY IDENTIFICATION OF 3-12REMEDIAL TECHNOLOGIES

• TASK 3.0 - SITE INVESTIGATION 3-13- SUBTASK 3.1 - AIR QUALITY ANALYSIS 3-13- SUBTASK 3.2 - GEOPHYSICAL INVESTIGATIONS 3-20- SUBTASK 3.3 - HYDROOEOLOGICAL INVESTIGATION 3-25- SUBTASK 3.4 - ENVIRONMENTAL 3AMPLING 3-37- SUBTASK 3.5 - FIELD MONITORING 3-46

• TASK 4.0 - SITE DATA EVALUATION 3-48- SUBTASK 4.1 - DATA VALIDATION, REDUCTION, 3-48

AND EVALUATION- SUBTASK 4.2 - PUBLIC HEALTH AND ENVIRONMENTAL 3-50

RISK ASSESSMENT• TASK 5.0 - REMEDIAL INVESTIGATION REPORT 3-52

3.3 PHASE II - FEASIBILITY STUDY 3-52• TASK 6.0 - DESCRIPTION OF CURRENT SITUATION AND 3-52

SCOPE REFINEMENT• TASK 7.0 - [DEVELOPMENT OF ALTERNATIVES 3-53• TASK 8.0 - INITIAL SCREENING OF ALTERNATIVES 3-55• TASK 9.0 - LABORATORY WORK PLAN PREPARATION 3-55• TASK 10.0 - REMEDIAL ALTERNATIVES EVALUATION AND 3-57

PRELIMINARY FEASIBILITY REPORT PREPARATION• TASK 11.0 - SELECTION OF COST-EFFECTIVE ALTERNATIVE 3-58• TASK 12.0 - CONCtPTUAL DESIGN DEVELOPMENT 3-59• TASK 13.0 - FINAL REPORT 3-60• TASK 14.0 - ADDITIONAL REQUIREMENTS 3-60• TASK 15.0 - COMMUNITY RELATIONS 3-60• TASK 16.0 - DEVELOPMENT OF PHASE II COOPERATIVE 3-GO

AGREEMENT APPLICATION3.4 PHASE III - INITIAL REMEDIAL MEASURE PLANNING 3-60

• TASK 17.0 - SITE INVESTIGATION 3-60- SUBTASK 17.1 - HEALTH AND SAFETY PLAN 3-62- SUBTASK 17.2 - WASTE/SITE CHARACTERIZATION 3-62- SUBTASK 17.3 - DATA VALIDATION AND EVALUATION 3-64- SUBTASK 17.4 - FINAL REPORT 3-64

• TASK 18.0 - FOCUSED FEASIBILITY STUDY FOR THE 3-64INITIAL REMEDIAL MEASURES DEVELOPMENT- SUBTASK 18.1 - IDENTIFICATION OF ALTERNATIVES 3-64- SUBTASK 18.2 - EVALUATION OF ALTERNATIVES 3-65- SUBTASK 18.3 - SELECTION OF COST-EFFECTIVE 3-66

ALTERNATIVE- SUBTASK 18.4 - REPORT OF FINDINGS 3-66

• TASK 19.0 - DESIGN AND SPECIFICATIONS 3-66

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CONTENTS (CONTINUED)

SECTION PAGE

• TASK' 20.0 - IMPLEMENTATION OF SELECTED 3-67REMEDIAL ALTERNATIVE

• TASK 21.0 - FINAL REPORT 3-68• TASK 22.0 - ADDITIONAL REQUIREMENTS 3-69• TASK 23.0 - COMMUNITY RELATIONS 3-69

4.0 PROJECT MANAGEMENT AND PERSONNEL 4-14.1 PROJECT ORGANIZATION AND PERSONNEL 4-14.1.1 INTERFACE REQUIREMENTS AND LINES OF COMMUNICATION 4-34.1.2 FIELD OPERATIONS 4-34.2 PROJECT MANAGEMENT REPORTS 4-34.3 CONTRACT LAB PROGRAM COORDINATION 4-44.4 DOCUMENT CONTROL AND MANAGEMENT 4-4

^ 5.0 MANPOWER REQUIREMENTS AND SCHEDULE 5-15.1 MANPOWER REQUIREMENTS 5-15.2 SCHEDULE 5-1

APPENDICES

A WEEKLY PROGRESS SUMMARY A-1B DOCUMENT CONTROL AND MANAGEMENT B-1

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TABLES

NUMBER PAGE

3-1 OUTLINE, INITIAL HEALTH AND SAFETY PLAN 3-93-2 AIR QUALITY EQUIPMENT 3-193-3 DRILLING AND MONITORING WELL INSTALLATION 3-26

PROGRAM3-4 ENVIRONMENTAL SAMPLING AND ANALYSIS 3-393-5 AIR SAMPLING ANALYSIS 3-453-6 OUTLINE, FEASIBILITY STUDY FINAL REPORT 3-615-1 PROJECT MANHOURS 5-2

FIGURES

NUMBER

2-1 LOCATION MAP2-2 SITE MAP3-1 PROPOSED DEEP MONITORING WELL LOCATIONS3-2 PHASE 1 MONITORING WELL AND SAMPLING LOCATIONS3-3 METHOD FOR LOCATING AREAS OF CONTAMINATION4-1 PROJECT ORGANIZATION AND PERSONNEL5-1 PROJECT SCHEDULE

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1.0 INTRODUCTION

This section introduces the Work Plan for the Remedial Investigation/FeasibilityStudy, and a site investigation for a potential Initial Remedial Measure (IRM) forthe Spiegelberg and Rasmussen Sites. The Work Plan is a planning document thatoutlines the scope of work required to determine the existence and nature andextent of the problem posed by the release of hazardous substances to thesurrounding environment from a site which may be affecting, or have the potentialto affect, the public health and environment tt is also designed to determine thebest method, or methods, to remediate the site. In addition, a brief description ofthe "Supei-fund" program is presented in Section 1.1 to provide the legislativebackground for the work to be performed.

This Work Plan has been prepared in response to a Request for Work Plan issued bythe Michigan Department of Natural Resources under State of Michigan ContractNo. 1611 and received by NUS Corporation on June 22, 1984.

1.1 Superrund. the National Contingency Planand the Program for the Soieoalbero and Rasmussen Sites

Recognition of the adverse environmental impact of common waste disposalpractices in the late 1960's and through the 1970's fostered concerted efforts in the1980's to identify and remediate sites where the public health and the environmentare threatened by uncontrolled hazardous wastes. Part of those efforts areembodied in the Federal Comprehensive Environmental Response Compensationand Liability Act of 1980 (CERCLA), which is commonly known as "Superfund".

CERCLA ordered the revision of Section 105 of the National Contingency Plan(NCP). which was first published as part of the Federal water pollution controlprogram. This revision was to provide new and expanded Federal authority torespond to the problems of uncontrolled hazardous waste sites. The final form ofthe plan, published as 40 CFR Part 300, on July 16, 1982, provided methods andguidelines for identifying, ranking, investigating, evaluating, and remediating sitesunder the Superfund program.

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Sections 300.24 and 300.61 of the NCR invite and encourage the individual Statesto participate in the Superfund program. Section 300.62 provides for the Statetaking the lead in any or all phases of the Superfund program, once a contract orcooperative agreement has been reached between the State and theU.S. Environmental Protection Agency (EPA). The State of Michigan has obtaineda cooperative agreement with the EPA for the Spiegelberg and Rasmussen Sites,and it will be the lead agency in conducting the "Superfund" work at these sites.This cooperative agreement is the binding document between the State and EPAwhich outlines technical, administrative, community involvement, and legal aspectsof the project.

As the lead agency in the hazardous waste cleanup program, the MichiganDepartment of Natural Resources (MONR) is responsible for remediating the threatto public health and the environment posed by the Spiegelberg and Rasmussen Sitesand for recommending to EPA the proper course of remedial action under theguidelines of 40 CFR, Part 300 of the NCP. EPA will then make the finaldetermination of remedial action to be funded by CERCLA. The process requiredto implement the NCP, for identifying, evaluating, and remediating hazardouswaste sites, is thorough and complete, but it is also complex and demanding intechnical, administrative, and legal areas. Michigan has obtained the services ofNUS Corporation to assist in performing the hazardous waste program at thesubject sites.

The main work elements of the NCP, pertinent to the present investigations of theSpiegelberg and Rasmussen Sites, are.the Remedial Investigation, the FeasibilityStudy, and investigation for potential Initial Remedial Measures. Each of these aredescribed as follows.

Remedial Investigation

The Remedial Investigation (Rl) is an information gathering and evaluation phasethat determines the threat to the public health and the environment caused by therelease of hazardous substances from the site. The information is gathered mainlythrough field work, such as air, soil, and sediment sampling and analysis, drilling

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and monitoring well construction, and groundwater sampling and analysis,ecological surveys and other site activities. The goal of the Rl is to determine thenature and extent of present and potential future impacts of the release ofcontamination, so that Remedial Action Alternatives can be identified andevaluated during the Feasibility Study.

The information obtained during the Rl must be of sufficient detail to assess theimpact of the no action alternative. In addition, the need for any initial RemedialMeasures (IRMs) often must be assessed early in an Rl, so that appropriate actionscan be implemented to eliminate immediate threats to public health and/or theenvironment.

Feasibility Study

The Feasibility Study (FS) identifies and evaluates the remedial alternatives,identifies and selects the most cost-effective remedial action alternative, andprepares a conceptual design for the selected alternative. In addition, the noaction alternative Is evaluated, and the impact of no remediation at the site isaddressed.

Initial Remedial Measures

Initial Remedial Measures (IRMs) are actions that are taken prior to completion oftho Remedial investigation and Feasibility Study to limit exposure, or threat ofexposure, to a significant health or environmental hazard posed by the sites.According to Section 300.68 of the NCP, the factors to be used in determining

whether an IRM may be appropriatt to the Spiegelberg and Rasmussen Sites couldinclude the following.

* Actual or potential diract contact with hazardous substances by nearbypopulation.

* Absence of an effective drainage control system.

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• Hazardous Substances in drums, barrels, or other containers, abovesurface, posing a serious threat to public health or the environment(applicable only to the Rasmussen Site).

• Highly contaminated soils, largely at or near surface, posing a seriousthreat to the public health or environment.

• Serious threat of fire or explosion or other serious threat to public healthor environment.

The Rl, FS. and IRMs must be conducted within the framework and guidelines ofthe NCP. Each of these work items must have a planning document that detailsthe plan for investigation and appropriate action. This document is called the WorkPlan. The Work Plan, presented In subsequent sections, constitutes the generalplanning document for the Rl, FS, and the investigation of potential IRMs.

1.2 Problem Assessment

Section 2.0 of this Work Plan describes the site characteristics and an assessmentof the hazardous waste problems at both sites, as presently understood. A briefsummary is presented in this subsection.

The Spiegelberg and Rasmussen Sites are located in a rural area of Green OakTownship in Livingston County, Michigan. The Spiegelberg Site is about 115 acresand borders the west and south boundaries of the Rasmussen Site. The Spiegelberg

Site contains an active sand and gravel operation. A portion of the excavated »rtawas used for the disposal of industrial and domestic wastes, including paint sludges.

The Rasmussen Site is about 33 acres, and contains a currently inactive .»and andgravel pit. Prior to sand and gravel quarrying, the area had been used as amunicipal landfill and a storage area for drums containing industrial wastes. Wastematerials were exposed, as a result of sand and gravel quarrying. Drums weremoved to other areas of the site so quarrying could proceed. The present drumdisposal area contains crushed and rusted drums and dried sludges that are either

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exposed at the surface or buried beneath a thin soil cover. Dart organic liquids

emanate from the drum area on warm days.

The first official contact recorded in MDNR files regarding dumping on theSpiegelberg Site was on August 5, 1966 by the Livingstart County HealthDepartment (LCHD), asking the owner to apply for a refuse dumping permit,pursuant to Mi**iaan Legislature Act 87 of the Public Acts of 1965. The MichiganDepartment of Natural Res^,rfls (MDNR) performed inspections of the sitetnrougn trie 1970's and cited violations of vanuu* waste disposal regulations. Thesite is currently used only for private waste disposal and th« sand and graveloperation.

The Rasmussen Site, which was called the Green Oak Township dump, wasestablished in June, 1960, and was first brought to the attention of MichiganDepartment of Public Health (MDPH) in 1966. The dump caught fire in April, 1967;both rubbish and drums burned. The Rasmussen Site was closed by the LCHD inDecember, 1972 for failure to properly maintain the landfill.

MDNR installed and sampled a series of monitoring wells at both sites in April andMay, 1981. The wells were sampled again in April-May. 1982 by MDNR and EPAcontractors. One monitoring well, located between the sites, detected 25 parts perbniion (ppt) 1.1 d;rhinrnath*no and several wells tentatively identified hydrocarboncompounds. However, no metals were detected in the oroundwater at levels ofconcern to MDNR and the Toxic Substances Control Commission (TSCC). MDNR

\— and TSCC again sampled drums, soils, the monitoring wells, and ponds on the sitesin July, 1983. 7,i dicnioroethane was detected in one wall at levels of 50 ppb.Organic solvents were identified in the drum samples (toluene, xylene, methyl ethylketone) and in the soil samples (PCBs) from the Rasmussen Site.

Both sites lie in formerly glaciated areas that contain sand and gravel, as the mammaterials. General groundwater flow beneath the sites is believed to be to thenorth. Groundwater from the glacial sand and gravel is used locally for residentialwater supply. The surface waters at the sites may eventually enter the Huron

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River via local drainage to Horseshoe Drain. Both the local drainage traversing thesite and Horseshoe Drain which it may connect to, are intermittent drainages. TheHuron River is the largest flowing body of water in close proximity to the site,located approximately 1 mile to the northwest of the site. Local drainage aroundthe Spiegelberg Site enters low lying, swampy areas south and east of the disposedareas.

The main public health threats posed by the sites, as currently known, areaccidental ingestion and dermal exposure (direct contact) to soils or watercontaminated with PCS's and other chemicals. There is also a potential threatfrom the migration of contaminated groundwater and from fire and explosion nearthe drum area of the landfill. However, the nature and extent of present orpotential health and environmental health hazards at the sites are unknown becauseof a lack of data. Data deficiencies have been identified as follows:

• The area! distribution and contaminant characteristics for surface soils isunknown. Data on surface soils are limited.

• Levels of contamination of subsurface soils that could contributecontaminants to the groundwater via leaching are unknown.

• Groundwater quality has not been fully defined. Existing groundwatermonitoring wells may be located too far from the main drum disposal

areas.

• Hydrogeologic conditions need to be further defined as to depth,thickness, and continuity of anuifers and confining layers. Groundwatergradients and flow path need to be confirmed.

• Surface water drainage at the site has not been fully defined.

• Data on the waste material buried in the fill are limited.

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• Topographic data are limited to USGS 10-foot contour intervals andelevations at well heads.

• A detailed air quality analysis on site and adjacent to the site has notbeen performed.

• Data on waste materials allegedly buried in pits on the Spiegelbergproperty is scarce.

The main objective of this remedial investigation/feasibility study is to undertakestudies which will determine the nature and extent of environmentalcontamination, if any, at the site, the public health and environmental hazardsposed by the site, and the most cost-effective, environmentally sound, and sociallyacceptable remedial alternative.

The site-specific objectives of the RI/FS are as follows:

• To identify the means to reduce the potential of possible direct contactwith contaminated soils and hazardous materials by the public.

• To plan for the removal of the fire and explosion threat and hazardsassociated with the drums on the Rasmussen's property.

• To determine what public health hazard or environmental problems thesite poses in addition to those previously identified.

• To determine the nature and extent of contamination on the project site.

• To define pathways of contaminant migration from the site as well as theimpact of contaminants on potential receptors.

• To determine onsite features which couid affect contaminant migration,containment or cleanup.

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• To identify viable remedial action measures to prevent reduce, oreliminate contamination by containing, treating, removing, or otherwiseaddressing hazardous materials on and/or off site.

• To provide for the evaluation and analysis of remedial action alternatives.

• To recommend the most cost-effective remedial action alternative.

• To prepre a conceptual design for the selected alternative.

• To assist the DNR in the community relations effort pertaining to thesites.

13 Technical Approach

The scope of work describes a process to obtain the data required to assess theimpacts of the sites on the public health and the environment during the RemedialInvestigation; to determine the need for the Initial Remedial Measures; and toconduct the Feasibility Study, tt is described in Section 3.0 of this Work Plan.

The RI/F5 for the sites will be conducted in three phases which are subdivided intotasks.

Phase I constitutes the Remedial Investigation (Rl). It is composed of the first fivetasks.

Phase II constitutes the Feasibility Study (FS) and is composed of Tasks 6 to 16.The FS will result in the selection and conceptual design of the optimal remedialalternative(s).

Phase III constitutes the site investigation, preparation of a Focused FeasibilityStudy to determine the need for Initial Remedial Measures (IRMs). Phase IIIconsists of Tasks 17 to 23, of which only tasks 17 and 18 (Site Investigation and

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Focused Feasibility Study) will be conducted as part of this Work Plan. Work onPhase III will be performed concurrent with Phase I.

The tasks for the Rt include the following.

Task 1 - Initial Activities

Initial Activities include preparation of this work plan and a detailed review of thecurrent situation at each site.

Task 2 - Pro-Investigation Support Activities

Pre-lnvestigation Support Activities are conducted prior to the actual detailedfield work. Activities conducted during this task include preparation oftopographic maps, a site health and safety plan, a site quality assurance plan, and apreliminary identification of remedial technologies that could be used to remediatethe site.

Task 3 - Site Investigation

The Site Investigation includes the field work to determine the actual or thepotential threats to health and the environment from the site. Such activities asan air quality analysis and a geophysical and hydrogeological investigation will beconducted as part of this task.

Task 4 - Site-Data Evaluation

Site-Data Evaluation involves tha validation of chemical data obtained from thesampling and analysis conducted in Task 3 and the evaluation of the data from theinvestigation. In addition, an assessment of the environmental impact of both siteswill be conducted as part of this task.

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Task 5 - Remedial Investigation Report

A report detailing the findings of the Remedial Investigation will be drafted duringthis task.

The FS consists of eight tasks that, when completed, lead to the selection and

conceptual design of the remedial action to be taken at the site. The tasks thatconstitute the FS include the following:

Task 6 - Description of Current Situation and Scoping Needs

Task 7 - Development of Alternatives

Task 8 - Initial Screening of Alternatives

(MDNR/EPA Screens; NUS Provides Support)

Task 9 - Laboratory Study and Groundwater Modeling Work Plan

Task 10 - .Detailed Evaluation of AlternativesTask 11 - Selection of Cost Effective AlternativesTask 12 - Conceptual Design

Task 13 - Feasibility Report

The potential IRMs for one or both sites will require a brief site investigation and

development of a focused feasibility study. A Focused Feasibility Study (FFS)concentrates on a specific problem at a site, rather than on the problems that may

occur throughout the site. The focused feasibility study will be used to select anIRM, or IRMs, appropriate to the site, or sites, if needed. After completion of theFFS, MDNR will make recommendations to EPA who will select an IRM ordisapprove it. The design specifications will then be drafted for procurement of an

IRM contractor, who will implement the IRM, or IRMs. Once the IRM, or IRMs,are completed, a report will be prepared. The tasks to be performed for the IRM;if one is needed, include the following:

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medial Investigation Report

stalling the findings of the Remedial investigation will be dratted during

nsists of eight tasks that, when completed, lead to the selection anddesign of the remedial action to be taken at the site. The tasks that

rior tothe FS include the following:

>escription of Current Situation and Scoping Needsnumty

Jevelopment of Alternativesitional

Initial Screening of Alternatives , .d site(? NR/EPA Screens; NUS Provides Support)*s^ ation.Laboratory Study and Groundwater Modeling Work PlanDetailed Evaluation of Alternatives mentSelection of Cost Effective Alternatives ativeConceptual Design

• Feasibility Report

sntial iRMs for one or both sites will require a brief site investigation andnent of a focused feasibility study. A Focused Feasibility Study (FFS)ates on a specific problem at a site, rather than on the problems that mayrouqhout the site. The focused feasibility study will be used to select anif*v_, appropriate to the site, or sites, if needed. After completion of the)NR will make recommendations to EPA who will select an IRM or>ve it. The design specifications will then be drafted for procurement of anntractor, who will implement the IRM, or IRMs. Once the IRM. or IRMs,npleted, a report will be prepared. The tasks to be performed for the IRM;s needed, include the following:

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2.0 PROBLEM ASSESSMENT

2.1 Background Information

2.1.1 Description of Site

The Spiegelberg and Rasmussen Sites have been included on the National PrioritiesList and are located in the northeast corner of Section 3 of Green Oak Township in

Livingston County, Michigan {Figure 2-1). These properties are located in a ruralarea of southeastern Michigan, about 40 miles west of Detroit 15 miles fromHowell, and 1.5 miles from Hamburg, the closest town. Access to the Spiegelbergand Rasmussen Properties is from U.S. Highway 23, along the U.S. 23 outer road toSpicer Road, then west on Spicer Road about 0.75 miles.

Each site is separate and has its own set of characteristics. However, the word"site," as further used in this Work Plan, will mean both the Spiegelberg andRasmussen Sites, unless otherwise specified. Both sites are bordered on the northby Spicer Road and by privately owned property on the other boundaries. North ofthe site is property and a building owned by the Veterans of Foreign Wars (VFW).

The Spiegelberg Site is approximately 115 acres and borders the west and southboundaries of the Rasmussen Site. The Spiegelberg Site contains an active sandand gravel operation. A portion of the excavated area was used for the disposal of

industrial and domestic wastes including paint sludges. Demolition materials havealso been disposed on the site. Domestic wastes have been disposed in severallocations on the site. Currently, the owners personally use the land for disposal of

their domestic waste.

Twr large, well-maintained metal buildings are present on the Spiegelberg Site. Tothe south and west of the buildings are a discarded school bus, piles of old tires, adiscarded van, discarded tractor trailers, and miscellaneous discarded equipment.

Domestic refuse is disposed of east of the buildings.

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BASE MAP IS A PORTION OF THE U.S.6.S. HAMBURG, Ml QUADRANGLE (7. S MINUTE SERIES, PHOTOREVISED 1975).CONTOUR INTERVAL 10'. - FIGURE 2-1

LOCATION MAPSPIEGELBERG 8 RASMUSSEN SITES

LIVINGSTON COUNTY. MlSCALE: l"»2000'

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NUSCaRPORATON

A Halliburton Company.

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A rental home and barn are located on the northwest corner of the property.Cattle are penned near the barn, and evidence of grazing was found throughout thesite. It appears that septic tank sludge was deposited north of the metal buildingsand east of the barn. The southern part of the site consists of gently rolling to flatwoodland and pasture land. A pond created by peat excavation is also located nearthe southern boundary, as well as an intermittent drain and a pond reportedlycreated by a demolition demonstration.

The Rasmussen Site consists of approximately 33 acres. The main disposal area isadjacent to a sand and gravel pit on the southern part of the site. The mainexcavation area lies in the center of the property. The area had previously beenused as a municipal landfill, and its contents were exposed as a result of sand andgravel quarrying operations into the landfill area. The ridge outlining the

excavated area is littered with crushed and rusted drums and dried sludges.Motorcycle and all-terrain vehicle tracks throughout this area suggest recreationaluse. Some mounds littered with dried sludges and rusted and crushed drums arealso found in both the excavated area and on top of the fill area. The Rasmussenresidence is located on the northeast corner of the site property. Evidence oflimited woodcutting is found in the area.

2.1.2 Adjacent Land Use

The site is surrounded by predominantly private property. Immediately south, andadjacent to the Spiegelberg property is the Maxey Boys Training School. This is aState of Michigan correctional facility_with several hundred employees and long-term residents. Directly north and across Spicer Road from the Rasmussenproperty is Hamburg VFW Post 1224. This facility hosts weekly bingo games, fish

frys, and other community activities, such as blood donation drives, weddings, andwell-attended dances. To the east are residences and a mixture of open fields andwooded land. Holy Spirit Catholic Church (located one-half mile north on MuschRoad) is a parish of 450 families that holds numerous functions throughout theyear.

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2.1.3 History of the Sites

Spiegelberg Site

The Spiegelberg Site has been a concern of the Livingston County HealthDepartment (LCHD), the Michigan Department of Public Health (MDPH), theMichigan Department of Natural Resources {MDNR}, and local residents for manyyears. In response to passage by the Michigan Legislature of Act 87 of the PublicActs of 1965, the LCHD contacted Mr James Spiegelberg on August 5, 1966 andasked him to apply for a refuse dumping permit. In February 1967, the LCHD againcontacted Mr. Spiegelberg to inform him that his dump had been classified as ahazard to public health and that action would be taken to close the dump.

V-v During a Spiegelberg Site inspection on September 7, 1973, the MDNR found thatthere was still open dumping and burning, that rubbish was not properly covered,and that groundwater was located at the face of the rubbish pile. On

September 19, 1973, the MDNR attempted to notify Mr. Spiegelberg by registeredletter, of violations of Act 87 observed during the site visit. The registered letterwas refused by Mr. Spiegelberg. Subsequent site visits noted similar conditions,and in October 1973, heavy rat infestations and a liquid disposal pit were noted. ByNovember of that year, the Livingston County Prosecuting Attorney's Office hadreceived complaints that liquids from Burton Chemical Company had been dumpedon the site and had seeped into the groundwater. On October 18, 1977, the MDNRreceived a complaint that paint sludge was being dumped illegally (no license) on

^ the Spiegelberg property. During a site visit on October 31, dry sludge andleachate samples were taken 'or organics, by gas chromatograph, and for heavymetal analyses. Mr. Al Pearson, the hauler who had dumped sludge at the site,indicated that the sludge had come from the Ford Motor Company, Wayne Truck

Plant. Samples from the Ford plant were taken for comparison with samples fromthe Spiegelberg Site. On November 4, Mr. Spiegelberg agreed to stop acceptingsludge, but did not agree to remove th* sludge already on the site. Mr. Pearsonagreed to stop hauling sludge to the site.

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In November of 1980, Mr. Spiegelberg was notified that he was in violation of theSolid Waste Management Act, Act 641, Public Acts of 1978, and Act 245, Section6A, Public Acts of 1929 dealing with the disposal of solid waste and with thedischarge into public waters of substances that may be injurious to public health,safety, or welfare. The violation of the latter act was in reference toMr. Spiegelberg's practice of disposing sludge material that may have contaminatedthe groundwater. Mr. Spiegelberg was requested to perform a hydrogeologic studyof the site in accordance with the rules of Act 245. Mr. Spiegelberg replied that hehad not dumped rubbish on his property since 1977, that the rubbish had beencovered several years ago with the required amount of topsoil, and that he had hiswater and that of his neighbors checked.

On July 26, 1983, a Technical Assistance Team member attempted to gain access'W to the site. However, Mr. Spiegelberg stated that access would not be permitted to

the area.

Rasmussen Site

The Rasmussen Site has been a concern of LCHD, MDPH, MONR, and local

residents for many years. An agreement was made between Green Oak Townshipand the Rasmussen s for operation of a portion of his property as the Green OakTownship dump in June, 1960. Past Green Oak Township meeting minutes indicatethe property use as a Township Dump began in mid-1960. The site was first

brought to the attention of MDPH in 1966 in response to Michigan Legislature Act- 87 of the Public Acts of 1965. --- -

On April 26-27, 1967, the Rasmussen Site, then known as the Green Oak Townshipdump, caught fire and burned out of control for the major portion of three days.The fire spread to an area where hundreds of 55-gallon drums were stored. The

drums, which were reported by th« owner to contain paint thinner, paint remover,oil sludge, and rubber by-products exploded, sending barrels onto Mr. Spiegelberg's

property. The Rasmussan Site was closed by the LCHD on December 25, 1972, forfailure to properly maintain the landfill.

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The northwest section of the Rasmussen property was used for a gravel miningoperation, conducted by the Ann Arbor Asphalt Company, which eventually

undermined a substantial portion of the dump area. MDNR EnvironmentalEnforcement Division inspected the Rasmussen property on December 11, 1979,and approximately 75 drums filled with solids and 300 crushed drums werediscovered. Drum sampling revealed the contents to include toluene, xylene, andmethyl ethyl ketone. Soil sampling by the MDNR, on October 20, 1981, revealedPCBs in a concentration of 640,000 ppb near the southeast corner of the east drumpile and lower concentrations of PCBs at other locations on the property.

Throughout the early 1980s, approximately 30,000 tons of sand and gravel wereexcavated from the Rasmussen Site and used by the Michigan Department ofTransportation (MDOT) and by road construction contractors throughout southernMichigan. In 1983, the Michigan House of Representatives urged the MDNR,MDPH, and MDOT to investigate the use of the material. In response to this

request, the MDOT reviewed their records and identified several locations wherethe gravel had been mixed into asphalt.

In July, 1983, discussions were hatd between Mr. Rasmussen and the MDNREnvironmental Enforcement Division concerning Mr. Rasmussen's voluntaryremoval and proper disposal of drums and contaminated soil on his property. Aconsent order was sent to Mr. Rasmussen by the MDNR EnvironmentalEnforcement Division to remove and properly dispose of the drums but, no responsewas given. MDNR also asked Mr. Rasmussen to cover the exposed refuse on site.

These actions were not implemented.

Sampling for Both Sites

On May 4 and 5, 1981, residential wells in the area, including those of the site

owners, were sampled by the LCHD and the MDPH. Analyses did not revealorganics or PCBs at detectable levels in the samples.

In April and May of 1981, the MDNR installed monitoring wells and drilled testborings on the Spiegeiberg and Rasmussen Sites. These wells were sampled by the

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MDNR at installation and again in 1982. The report of this investigation wascompleted by the MDNR in November of 1982.

Groundwater monitoring at the site by the Field Investigation Team (FIT), onMay 24 and 25, 1982, found PCBs and organics to be below detectable limits. Inaddition, no metals were detected in the groundwater at levels of concern to theMDNR.

On July 21 and 22, 1983, the MDNR and TSCC conducted additional sampling onboth sites. Locations sampled at the Rasmussen Site included the gravel pit area,six drums on site, and the topsoil near a second pile of drums. Locations sampledat the Spiegelberg Site included the processed gravel- as well as soils, sediments,surface water and monitoring wells. Samples were analyzed for priority pollutants;Inductively-Coupled, Argon Plasma/Emissions Spectoscopy (ICAP) metals; andPCBs. Organic solvents were identified in the drum and soil samples.

In January 1984, a site assessment for the Rasmussen Site was prepared for theU. S. Environmental Protection Agency (EPA). A Draft Community Relations Planfor this site was prepared and published on October 14, 1984. Remedial ActionMaster Plans (RAMPs) were completed for both sites on April 18. 1984. OnJune 18, 1984 the Michigan Department of Natural Resources requested that thisWork Plan be prepared.

A more detailed and complete history and chronology for both sites is to beprepared under Subtask 1.2, Description of Current Situations.

2.2 Environmental Setting

2.2.1 Physiography

The Rasmussen and Spiegelberg Sites are in the Great Lakes section of the CentralLowland physiographic province. This section was glaciated during the Wisconsinglaciation and is characterized by glacial landforms. The topography of the sectionis marked by thousands of lakes, poorly integrated drainage and glacial land forms

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{including prominent end moraines), outwasn plains, knobs and kettles, and a few

eskers and kames. Prior to glaciation, this portion of southeast Michigan was partof the Thumb Uplands physiographic region. This region was characterized by hillytopography cut into Mississippian and younger sedimentary rock formations.

The upland portions of the northern part of the site is an apparent glacial moraineand the lower portions of the southern part of the site is a till plain or outwashplain. The sand and gravel in the'moraine has been mined from the sites causingchanges in the natural topographic features. The elevation across the sites rangesfrom more than 970 feet above mean sea level (MSL) in the northwest to less than890 feet above MSL in the south.

2.2.2 Geology

Livingston County is characterized by outwash, moraine, or ground morainedeposits on the surface. The thickness of these deposits ranges from 11 feet atspots in western portions of the county to as much as 800 feet at the easternborder. In the vicinity of the Rasmussen Site, the deposits range between 100 and

200 feet in thickness. An esker extends about two-thirds of the way from the northborder to the south border of the county, to a point just east of Howelt. Severalshorter, north-south trending eskers are near the western county line.

Sedimentary formations, deposited during the Mississippian and Pennsylvanian Eras,underlie the glacial deposits in Livingston County. The'bedrock surface generallydips northeast at a rate of 1.5 feet per mile. In the vicinity of the Rasmussendump, the bedrock dips south at about 20 feet per mile from a burial bedrock ridge

to the northwest.

From oldest to youngest, the formations forming the bedrock surface underLivingston County are the Coldwater Shale, the Marshall Sandstone, the MichiganFormation, and the Saginaw Formation. The Coldwater is a gray, micaeous shalewith interspersed beds of sandstone. The Marshall Formation includes 160 to320 feet of sandstone, siltstone, and shale. The sandstone is commonly confusedwith sandstones in the upper portion of the Coldwater Formation. These

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sandstones are composed of well-sorted, fine- to medium-grained quartz sandstone.The Michigan Formation is a sequence of dark gray shale, limestone, dolomite,sandstone, gypsum, and anhydrite.

In April and May of 1981 the MDNR drilled 11 borings in the Spiegelberg andRasmussen properties. The borings indicate that this site is covered withdiscontinuous layers of clay, silt, sand, gravel, and a heterogeneous mixture of

these materials. These layers are typical of a glaciated area. The hill across thenorthern part of the site is probably a glacial moraine. The southern part of theSpiegelberg Site may be an outwash plain or a till plain.

2.2.3 Surface Water Hydrology and Drainage

Streams into Livingston County drain into one of three river basins: the Grand, inthe western part of the county; the Shiawassee, in the central and northeasternparts; and the Huron, in the southern and east-central areas.

Drainage on the Spiegelberg property is southward to a intermittent stream andlowland area. During wet seasons runoff may reach Horseshoe Drain which runs

through Hamburg and enters the Huron River. This stream empties into the HuronRiver about 2-1/2 miles northwest of the site. The Huron River goes intoStrawberry Lake, through several small lakes, and then southwestward through theadjoining township to Washtenaw County. In Washtenaw County, the Huron River

turns to the southeast and flows into Lake Erie.

Drainage routes on the Rasmussen property have not been determined, and nosurface water bodies were visible onsite as of the visit conducted on March 9, 1983,by Livtngston County Health Department, MDNR and EPA personnel.

2.2.4 Hydrogeology

The thick glacial drift covering much of the county contains interbedded aquifers,aquicludes, and aquitards. The underlying Coldwater Shale and the Michigan

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Formation are classified as aquicludes. The Saginaw and Marshall Formations areconsidered good aquifers.

Drift Aquifer

The nature of the glacial drift determines its properties as an aquifer, withoutwash deposits being the best aquifers and tilt plains the poorest. The variety ofglacial deposits in Livingston County is reflected in well capacities, which rangefrom 2 to 600 gallons per minute. Specific capacities range from 0.23 to

18.75 gallons per minute per foot of drawdown, and the transmissivities range from14,000 to 57,000 gallons per day per foot. It is difficult to project hydrauliccharacteristics for the drift aquifer over any distance because of the highvariability. The drift aquifer in Livingston County is considered unprotected. Thatis, there is no impermeable material protecting the aquifer from surface seepagecontamination.

Bedrock Aquifers

It appears that the Coldwater shale is the bedrock unit directly under the glacialdrift in the vicinity of the sites. The Coldwater shale is normally an excellentconfining layer; however, in this part of the state, there are sandstones typically

present in the formation. The sandstone is usually coarse-grained. To the west ofthe site, in Hamburg Township, groundwater is produced from the MarshallFormation. The Marshall sandstone generally has good intergranular porosity andmoderate permeability. Interbedded siltstone and shale -reduce the effectiveporosity of the formation. Th« other bedrock aquifer encountered in LivingstonCounty is the Pennsylvanian Saginaw Formation. The sandstones of this formation,

which form the bedrock surface in the western pan of the county, make goodaquifers, with transmissivities ranging from about C.OOO gallons per day per foot to

37,000 gallons per day per foot.

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2.2.5 Air Quality

Air quality in Livingston County is generally good. In 1981, the county wasClassified as attaining the National Ambient Air Quality Standards (NAAQS) forcriteria pollutants of total suspended particulates (TSP), sulfur dioxide (S02).carbon monoxide (C02), nitrogen dioxide (N02>, lead (Pb), and ozone (03).

The only known air quality measurements at the sites were recorded during theMarch 9, 1983 site visit by MDNR, ERA and an ERA contractor. Measurementswere made with an HNU photoionization detector. Measurements of organicvapors were at or below background levels, and no odors could be detected. Thereadings were taken on a cloudy day when air temperatures ranged from 30°F to35°F.

2.2.6 Ecology

A wide variety of fauna and flora may be found throughout the county. Dependingon the drainage and soil type, some combination of oak, hickory, cherry, elm,aspen, and sugar and red maple trees are present in wooded areas. The SpiegelbergSite is suited for wetland animals, such as ducks, muskrat. and killdeer, in thesouthern part of the site. Open land animals, such as quail, skunk, field mice, fox,

and cottontail rabbits, may be found over much of the site. Owl. squirrels,raccoons, and other woodland animals may be found in forested areas of the sites.

2.2.7 Socioeconomics

Between 1970 and 1980, the population of Livingston County increased 70.1 percent

to 100,000 people. Much of this increase was probably due to people moving out oflarge cities, such as Flint, Pontiac, an? Detroit. The location of recreation

facilities may also have contributed to the growth. Numerous resorts and twostate recreation areas are located near the site.

About 48 percent of the county's 365.440 acres is farmland. Most of the farmlandproduces corn, wheat, oats, alfalfa, clover, and timothy.

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Topographic maps in the vicinity of the site indicate numerous small gravel pits.Sand and gravel have been mined at both the Spiegetberg and Rasmussenproperties.

2.3 Summary of Data Available

Sampling and analytical data reviewed for this Work Plan consisted of results ofanalyses from groundwater samples taken on April 1981, November 1981, andMay 1982; and July, 1983, sediment samples taken on April 1 and October 26, 1981;and drum, soil, monitoring wells, . gravel, sediment, and surface water samplestaken on July 21 and 22. 1983. The data were reviewed from RAMPS, MDNRGroundwater Contamination Investigation, and the Site Assessment for theRasmussen Site.

A concentration of 50 ppb 1,1-dichloroethane and several possible hydrocarbonswere identified at monitoring wells 81-4 and 81-5, respectively. (See Figure 2-2).Lead was found in one well at levels about eight times the Primary Drinking Water

Standards. A different well showed a lead value four times the Primary DrinkingWater Standard in the 1983 sampling. High levels of PCS contamination

(640,000 ppb) were detected in soil samples collected by the MONR near the eastdrum piles at the site. The sample locations were marked with wooden stakes.Additional samples were taken at these locations on May 8, 1984 by EPA. PCBshave also been detected in lower concentrations at other sample stations. Drum

samples were collected from the east drum pile. Toluene, ethyl benzene, andheavy metals have been identified in the drum samples.

In general, the analytical information is sparse, and exact sample locations are notadequately defined. Additional analytical information is needed to identify theextent of contamination at the sites. A more detailed review of the existing datawill be performed in Task 1.2, Description of Current Situation. Personalinterviews with residents living near the site may be conducted to provideadditional information.

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APPROXIMATE LOCATION OF EXISTINGMONITORING WELLS

BASE MAP IS A PORTION OF THE U.S.G.S. HAMBURG, Ml QUAORANGLEC7.5 MINUTE SERIES, PMOTOREVISEO i97S).CONT. INT. 10'

SITE MAPSPIEGELBERG 8 RASMUSSEN SITES

LIVINGSTON COUNTY, MlSCALE l"s2000'

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FIGURE 2-2

NUSCORPORATOR

A Halllbunon Company

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2.4 Health. Safety, and Environmental Assessment

2.4.1 Public Health and Safety

The potential exposure by direct contact with PCS contaminated soils or water isthe most significant known threat to public health and safety posed by the sites.Accidental ingestion and dermal exposures to PCBs have been known to cause anumber of disorders in humans. Long-term effects of PCS exposure are unknown;

however, symptoms of exposure have been documented, in some cases, five yearsafter exposure.

No contamination of local residential wells has been detected to date. Thepotential contamination of residential wells by the migration of both organicchemicals and heavy metals from the site is a significant threat. The presence oflead was detected in two monitoring well samples at levels exceeding PrimaryDrinking Water Standards. Ingestion of lead is of particular concern, since veryhigh levels were detected in one sampling, subsequent samples have shown only oneelevated lead value in one monitoring well. Ingestion of lead is of particularconcern and is currently being monitored by MDPH in nearby residential wells.Organic compounds were detected in two monitoring wells, with one compound

being 1,1, dichloroethane which the EPA lists as a hazardous substance.

Though the presence of toxic substances in the air has not been documented, thereis a possibility of airblown transport of PCB or lead contaminated dust. In

V- addition, direct contact may occur with other hazardous substances, not, as yet.identified. Further, where there is a history of burning PCB contaminated wastes,

the possible formation of toxic by-products is also a consideration. Accidentalfires involving PCBs may have resulted in the formation of highly toxicpolychlonnated dibenzofurans, polychlorinated dibenzo-p-dioxins, and

polychiormated biphenylenes.

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2.4.2 Environment

Should PCB contamination migrate offsite, an indirect health hazard would exist inthe potential consumption of contaminated wildlife. In addition, consumption oflivestock grazing onsite could pose an additional possible risk. PCBs are known tobioaccumulate in the adipose tissues of animals and fish.

2.5 Data Limitations

The following limitations have been identified in the site data reviewed to date.

• The areal distribution and contaminant characteristics for surface soils isnot known at this time. Data on surface soils are limited, with most databeing for the Rasmussan Site. Soil analysis at boring and monitoring welllocations is limited to inorganic parameters.

• Data on waste material reportedly buried on the Spiegelberg property islimited.

• Groundwater quality is not sufficiently defined to determine potentialhealth risks and requirements for remedial action. Existing groundwatermonitoring wells may be located too far from the main drum disposal

areas.

• Hydrogeologic conditions need to be further defined as to depth,thickness, and continuity of aquifers and confining layers. Groundwatergradients and flow paths need to be confirmed.

• Surface water drainage at the site has not been fully defined.

• Data on the wast* material buried in the fill are limited.

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* Topographic data are limited to USGS 10-foot contour intervals andelevations at well heads.

• Air quality, onsite and in depressions adjacent to the site, under varyingmeterological conditions, has not been determined.

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3.0 TECHNICAL APPROACH

3.1 Introduction

This section outlines the Remedial Investigation, Feasibility Study (RI/FS), and siteinvestigation for an Initial Remedial Measure (IRM) scope of work and serves as a

basis for cost estimation and technical review. The scope of work was definedfollowing a preliminary site reconnaissance and review of available existing data.In addition, the scope of work was designed to be responsive to the June 18, 1984Request for Work Plan, and subsequent comments submitted in writing by MDNRon August 14 and August 24, 1984.

The RI/FS will be conducted in three phases. Phase I constitutes the Rl and iscomposed of five major tasks. Phase II includes the FS consisting of 11 majortasks. The FS results in the selection and conceptual design of the optimalremedial alternative(s). Phase III constitutes the site investigation for an IRM inthe drum disposal area. Phase III investigations will be conducted concurrently

with the Rl.

It should be emphasized that while the scope of work included in this Work Plan isbased upon a site reconnaissance and thorough review of existing available data, itis preliminary in nature. The scope of work will be revised, as necessary, as newdata is obtained or generated during the Rl and the IRM, in order to ensure that the

data requirements of the FS are adequately met.— _ t

The scope of work presented in this section includes both the Spiegeiberg Site andthe Rasmussen Site. However, as stated in Section 2.0, the word "site*, as used inthis Work Plan, is defined to mean both the Spiegeiberg and Rasmussen Sites,unless otherwise specified.

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The following overall assumptions have been made in preparation of this Work Plan:

• The State of Michigan will take the leading role in project managementaspects of the performance of the RI/FS and IRM.

• The majority of Rl work performed at the sites will be at a Health andSafety Level 0. The drum area and landfill area may require work to becompleted at Level C. If a significant amount of work at higher levels isrequired, adjustments to manpower requirements, schedules, and budgetswill be necessary.

• All surveying and related topographic mapping will be completed byMDNR and will be made available in a timely manner for project use.

• If contaminated sites, apart from those assumed within the Work Plan, arediscovered during the RI/FS, the scope, budget, and schedule will need tobe modified.

• Health & Safety monitoring and site access control/security will belimited to NUS, MDNR, ERA, agents of each, and NUS subcontractorpersonnel during periods when such personnel are physically on the site.

• The drilling program can be completed within a five month time frameunder favorable weather conditions.

• Project management meetings will be limited to one per month. Weeklyprogress report meetings will be completed via telephone followed by awritten summary.

• implementation of any IRM activities is not a part of the present WorkPlan. Potential project delays due to implementation of drum removalwill be a maximum of two months.

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• No costs for analytical analyses have been included as part of the presentWork Plan except for onsite field analysis and screening for selectedinorganic parameters.

• Review and comment of project developed documents will be made byMDNR and EPA within a two-week time frame.

• No schedule or standby delays will be experienced due to site accessrestrictions.

3.2 Phase I - Remedial Investigation

Task 1.0 - Initial Activities

Initial Activities consist of three subtasks: development of the Work Plan,preparation of a description of the current situation, and project management. TheWork Plan contains a description of current conditions at the site; however the

description is not complete and is provided only to serve as a background for thetechnical approach.

Subtask 1.1 - Work Plan Preparation

Preparation of this Work Plan is considered part of Task 1.0. This Work Planidentifies the tasks anticipated within the RI/FS. The Work Plan addresses projectorganization, task assignments, manpower and resource requirements, projectschedule, and budget requirements, as given in this document

Subtask 1.2 - Description of th« Currant Situation

A description of the currant sita situation will be prepared. The description willinclude an update from previous sita descriptions, as well as an inventory of wastematerials from file and documant information sources. The current situation willbe described in a report similar to Section 2.0 of this Work Plan, with the additionof a section summarizing the findings of the waste inventory.

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Subtask 1.3 - Project Management

Project management activities will continue through the duration of the RI/FS.Project management costs will be covered by this task. These charges includecosts related to project coordination, budget and schedule supervision, reporting onproject progress to the MDNR, and interface requirements with the MDNR andEPA.

Task 2.0 - Pre-lnvestigation Support Activities

This task includes initial site activities and a Site Visit to start the Rl.

Subtask 2.1 - Topographic Mapping. Ground Surveying, and Warning Signs

Three separate surveying events are planned for the RI/FS. These include an initialsurvey to establish topographic control, site access, and property line boundariesand two other surveys, one after Phase I and one after Phase II of thehydrogeological investigation, to locate wells and sampling points during the RI.All surveying wilt be provided by MDNR.

Mapping Control

Horizontal and vertical control for aerial photography will be performed by MDNR.

Although most of the survey will be conducted on site, peripheral control pointsoff site could be required. The site planimetric contour map will be prepared byMDNR at an early enough date to be used, along with the surveyed grid, forelevation and location positioning of geophysical survey points.

The survey will provide sufficient topographic control points on the ground, withlocations tied to a coordinate control system, to enable a topographic map to beprepared in sufficient detail, including a 2-foot contour interval.

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Property Boundary Surveys

The Rasmussen and Spiegeiberg property boundaries will be surveyed and staked byMDNR so that site activities will be properly located with respect to site accessclearances. A title record search was conducted by the U.S. EnvironmentalProtection Agency (EPA) and is assumed to be sufficient for use in this RI.

Warning Signs

MDNR will place stakes to indicate property boundaries at key locations onsite.Approximately 6 warning signs measuring 18 inches x 24 inches will be placed onstakes at locations shown on Figure 3-1 of Subtask 3.2 - Geophysical Investigation.The signs will be lettered to read "DANGER, UNAUTHORIZED PERSONNEL KEEPOUT" Boundary signs will consist of red letters on white background.

Reference Grid

A 200 foot grid will be staked, by MDNR, continuously across the two properties,where determined to be necessary by MDNR. The grid will consist of stakesmarked with coordinate position and flagged for visibility. The grid will be initiallyused for the surface geophysical surveys of the properties. Subsequent uses willinclude the coordinate location of new borings and wells. This will allow initial

data evaluation before the final survey.

Boring, WeH. and Sampling Locations

The survey for boring, well, and sampling locations will be made by MDNR on two

occasions. The first survey will occur after the Phase t borings and wells have beenplaced, prior to the removal of drums on the Rasmussen Site. This survey willobtain the elevations of the wells (top of casing) and the ground elevations of thewells. This survey will also confirm the elevations of existing wells.

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The second survey of well and ground elevations will be conducted after thePhase II drilling and well installations which will occur following the drum removal.

Sub-task 2.2 - Health, Safety, and General Site Reconnaissance

An initial site reconnaissance will be conducted in order to evaluate existing siteconditions.

Objectives for the task include the following:

• Perform general health and safety reconnaissance.

• identify physical hazards and features.

• Perform geologic and hydrologic field reconnaissance, including existingand proposed onsite monitoring well locations.

• Evaluate site conditions for location of surface water, sediment, and soilsampling locations.

• Conduct air quality characterization for volatile organics, total suspendedparticulates. paniculate organics, and metals.

During the initial visit health and safety monitoring will be conducted, using real*time organic vapor monitors. The results of the monitoring wilt be used toestablish "hot" zones and to determine the proper levels of personal protective

equipment to be used during the site investigation. Additionally, physical hazardswill be noted, such as surface drums, steep topography, potentially contaminatedsoils, surface water, and exposed fill. The information gained during "he task willbe used to update the site health and safety plan, if necessary.

The onsite monitoring wells will be visually inspected. The headspace of the wellswill be checked for organic vapors, and static water levels will be taken during thereconnaissance to provide information for the hydrogeologic study. Access to

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proposed monitoring well locations will also be addressed during thereconnaissance.

The site conditions will be evaluated to determine surface water, soil, andsediment sampling locations. These areas will be marked and located on a sitemap. The locations will eventually be located using the site grid established duringthe surveying task.

The major effort during the initial reconnaissance will be collecting air samples.

These samples will be used to characterize the ambient conditions surrounding thesite. The information obtained from the samples wilt be used to determine sitehealth and safety requirements and to determine contaminant migration pathwaysduring the FS. The method for collection and analysis, as well as a detailedsampling plan for this task, is described in the Air Quality Analysis Subtask(Subtask 3.1). Additionally, air sampling points will be located in these areas

during the reconnaissance.

Subtask 2.3 - Site Health and Safety Plan

Before onsite work begins, a site-specific health and safety plan will be developedfor the site. The following federal, state, and local requirements reference

materials will be consulted during development of the plan:

• Section 111(c}(6) of Comprehensive Environmental Response.Compensation, and Liability_Act_of 1980 (CERCLA).

• EPA Order 1440.3 - Respiratory Protection.

• EPA Order 1440.2 - Health and Safety Requirements for Employers

Engaged in Field Activities.

• EPA Occupational Health and Safety Manual.

• EPA Interim Standard Operating Safety Procedures.

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• Michigan Occupational Safety and Health Act.

• 29 CFR 1910 - OSHA Safety and Health Standards for General Industry.

• 29 CFR 1926/1910 - OSHA Safety and Health Standards for theConstruction Industry.

In addition to the above standards, literature from the National Institute ofOccupational Safety and Health (NIOSH), the American Conference ofGovernmental Industrial Hygienists, the National Safety Council, National FireProtection Association, American Red Cross, and the American Industrial HygieneAssociation will be utilized. This information pertaining to chemicals found on sitewilt be available on site and will be provided to appropriate emergency personnel(i.e., hospital, county emergency coordinator).

The initial health and safety plan (Table 3-1} will address general site conditions asthey relate to each task. As more information is gathered, it will be included intask-specific health and safety plans. These plans are designed to augment the

initial plan and identify specific hazards and possible changes based on informationgained during the site investigation.

The task-specific plans will detail the specific activities to be conducted, thepersonnel involved. Personal Protective Equipment (PPE) requirements, sitemonitoring procedures, accident reporting forms, and respiratory protection logsheets. These task-specific plans will be implemented for the Rl/FS and site

investigation for the IRM phases of the project.

Subtask 2.4 - Quality Assurance) and Quality Control Plan

A Quality Assurance Project Plan (QAPPJ will be developed for the Rl/FS based

upon the general NUS Quality Assurance Project Requirements, MDNRrequirements, and requirements of the EPA. These requirements will refer to orinclude site-specific details on sampling, field testing, chain-of-custody, samplehandling, packaging, preservation and shipping, and record keeping and

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TABLE 3-1

OUTLINEINITIAL HEALTH AND SAFETY PLAN

L Background Information

Provide site workers with a general overview of site conditions and specifichazards.

IL Hazard Evaluation

Workers are given a brief evaluation of the hazards, both chemical and physical,which are known to exist on the site.

Hl^ Personnel Health Examination

Medical monitoring requirements for all site workers are defined.

IVA Operating Procedures

General site operating procedures are given in this section.

V. Personal Protective Equipment fPPEi

The specific types of PPE required for site work are outlined, and a discussion ofthe rationale for selecting the appropriate PPE. if site conditions changed isprovided.

VK Field Operations Work Area

Decontamination facilities and procedures are discussed in this section. Also, sitesecurity and personnel supervision art discussed.

iVII. Training

Training requirements for all site personnel are discussed in this section.

VIII. Accident Procedures

All emergency telephone numbers, personnel, and facilities are detailed in thissection. Also included are procedures to be followed should a site emergencyoccur.

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documentation. Appropriate NUS Corporation Quality Assurance requirements will

be imposed on alt subcontractors. Analysis requirements will be given, along withany other procedures needed for the RI/FS on or related to the site. Key elements

of the QA Requirements will be included in the Site Operations Plan.

In accordance with MONR's request the QAPP plan is being developed under a

separate purchase order agreement from MDNR, and the level of effort and costsfor this task are not included in this Work Plan.

Subtask 2.5 - Site Operations Plan

A Site Operations Plan will be developed to outline and coordinate activities at thesite during the Rl. The Site Operations Plan will be a compendium of the

site-specific plans and documents required for the execution of the field work.

The Site Operations Plan will serve as a reference guide in the field and willcontain the following:

• Final Approved Work Plan

• Site-Specific Health and Safety Plan• Site-Specific Quality Assurance Plan• Site-Specific Sampling and Analysis Plan

• Standard Forms• Maps and Plans

• Miscellaneous References

Elements of the Site Operations Plan can be changed, since information obtainedduring the Rl or IRM investigation may alter the assumptions used to develop theWork Plan, Health and Safety Plan, *nd Sampling and Analysis Plan. Major changesto those elements of the Site Operations Plan must be approved, in writing, by theMONR Project Manager and Contracting Officer, and by the EPA. Approvedchanges will be incorporated into the Site Operations Plan, along with a descriptionof the rationale for the changes and the approval documents. At the conclusion of

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the site investigation, the Site Operations Plan will then serve as the document ofrecord for site activities.

Subtask 2.6 - Mobilization of Field Equipment

Mobilization of field equipment includes the necessary preparations and facilitiesto implement the Site Investigation. A field office, supplied by MDNR, andequipment storage trailer, supplied by NUS, will be placed at the northwest cornerof the Rasmussen Site. The field screening equipment, such as the field gaschromatograph (GC), will be set up in the trailer and will be calibrated and testedduring mobilization. Initially, an outside decontamination line withdecontamination pad will be placed by NUS. MONR is pursuing obtaining adecontamination trailer NUS will construct the access ramp onto the SpiegelbergSite. A fence, with gates, will be constructed around the control area, and aroundthe area designated for storage of drums containing drilling fluids.

The subcontractor will assume responsibility for all mobilization costs andmobilization of equipment required to complete any subcontracted tasks.

Mobilization of equipment specific to a particular task, such as health and safetyequipment and monitoring instrumentation, has been included in the appropriatetask.

Subtask 2.7 - Subcontractor Management

Coordination and management of subcontractors will be required to orientsubcontractors to the requirements for sit* activities. A drilling specification willbe developed to detail the methods and procedures the drilling contractor must useto obtain soil and water samples and to install monitoring wells. The drillingspecification is the document that describes the methods and requirements that thedrilling subcontractor must use to drill and sample the borings, and install themonitoring wells. These methods and procedures will be included in the QAPP.Subcontractor specifications to improve sit* access for the site activities may alsobe required and will be developed under this task. Subcontractors are required to

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meet health, safety, and QAPP requirements for all work activities. Manhours forthis task are included in the overall project management task.

Subtask 2.8 - Preliminary Identification of Remedial Technologies

The Rl will determine the extent of contamination, the risks to the public, and theenvironment associated with the site, so that appropriate remedial actions can beevaluated during the FS. The scope of the Rl should be guided, in part, by thetypes of remedial action alternatives that may be evaluated during the FS.Therefore, a preliminary identification of remedial technologies will be made forthe site to ensure the scope of the Rl is adequate to conduct a FS. Preliminaryidentification of remedial technologies requires clearly defining the goals andobjectives of site remediation. The goals and objectives of remediation will bedeveloped in conjunction with the MDNR and U. S. EPA and will be consistent withthe regulations set forth in the National Contingency Plan.

Criteria to be used in the evaluation of remedial action alternatives, such astechnical, environmental, and economic factors, must also be identified. Thecriteria for the evaluation of alternatives typicalty include

• Reliability• Implementability• Environmental Concerns• Safety Requirements• Cost-Effectiveness

Factors implicit in the evaluation of remedial measures include availability andcost of materials required for final construction, physical site limitations for

construction activities, applicability of treatment technologies to the wastematerials, long-term effectiveness of the remedial measure, long-term operationand maintenance requirements, transportation requirements, and additionalexposure hazards to the environment and public, created by implementing a givenremedial measure.

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Once the site-specific objectives and criteria are established, appropriate remedialtechnologies applicable to both source control and off site remedial actions will beidentified. These technologies will be evaluated to determine how well they meetthe established project objective. Appropriate remedial technologies may begrouped as required to constitute the remedial measure. In addition, the possibilitythat the drums will be removed from the Rasmussen Site will also be considered inthe evaluation. The identification of remedial technologies will consider the type

of media contamination, the site-specific conditions {soils, geology, etc.), publichealth and safety concerns, and existing federal, state, and related regulations.

A brief report summarizing the objectives, criteria, and preliminary identificationof remedial technologies will be prepared as a portion of this task.

Task 3.0 - Site Investigation

This task includes the main activities that will collect the data for the Rl. Theseactivities include assessments of the air quality on the site, the relativecontamination of local surface water, sediments, surface and subsurface soils.groundwater flow patterns, and groundwater contamination.

Subtask 3.1 - Air Quality Analysis

An air sampling program will be conducted to characterize potential airbornepollutants both on and around the site. This program will provide information forinput into the site Health and Safety Plan, as well as provide baseline informationfor the development of a more comprehensive program, if it becomes necessary.Additionally, the information gained during this program will be used to address thetendencies of pollutants to enter and disperse in the atmosphere.

in order to determine the tendencies described above, the following variables willbe considered:

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• Seasonal weather

• Local wind patterns

• Chemical and physical properties of those compounds identified

The air quality study will be general and is only intended to aid in the recognitionof potential migration pathways of critical contaminants during remedial action.This study is not intended to provide absolute quantitative data. However, theinformation gained during this study may identify the need for a more extensivesampling program.

The parameters of interest during this study will include the presence andconcentrations of the following pollutants:

• PCBs• Pesticides• Total Suspended Particulates {TSP)• Toxic Heavy Metals• Volatile and Paniculate Organics

Sample Methodology

Volatile Organic Compounds

Tenax will be utilized as the sorbent media to collect ambient air samples forvolatile organic analysis. The samples will be collected by using a two-tube systemwith the front tube containing 0.2 grams and the backup tuba containing 0.1 gramsof Tenax, respectively. The tubas thamsalvas will be constructed of 1/4 inchoutside diametar stainless steel. The front tube will be 3 inches in length and thebackup 1-1/2 inches long. The tubas will be connected by teflon compressionfittings and a double-faced ferula. The sorbent will be held in place by fined

plugs.

The QAPP will include the methods for the air sampling.

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Each sample will be collected by pulling a known volume of air through thesampling tube. Samples taken during this task will be collected by using a flow

rate and sample volume that is appropriate for the chemical compoundconcentrations expected at each sample location.

Samples will be collected at within a range of 4 to 7 feet above the ground surface.This will provide a good estimation of the air quality in the breathing zone. Actualsampling locations are described later in this section.

RGBs, Pesticides, and Particulate Organics

These parameters will be sampled by following a procedure published by Straiten,et al.. in "A Method for the Sampling of Polychlorinated Biphenyls (PCBs) inAmbient Air," EPA-600/4-78-048, August 1978. This procedure uses a high volumesampler, which complies with 40 CFR 50, Appendix B - Reference Method for theDetermination of Suspended Particulars in Ambient Atmosphere (High VolumeMethod) with the following modifications:

• Extension of the throat assembly at the fitter holder outlet with a pieceof cylindrical aluminum.

• Replacement of rubber gasket material with Tefion.

• Attachment of flexible duct work at the pump discharge to direct alreadysampled air downwind of the sampler inlet.

The volatilized PCBs and pesticides will be collected by using Soxhtet extractedpolyurethane foam (PUF) plugs. Two 4-inch diameter cylindrical foam plugs, cutfrom 3-inch stock, will be placed, undtr slight compression, in the hexant-rinsed,aluminum throat assemblies.

Polyurethane foam plugs are cleaned in the laboratory to remove potentialinterferences prior to their use in the field. The cleaning procedure includes thefollowing steps.

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• Soxhlet extract foam plugs for 24 hours in 5 percent diethyl ether inhexane.

• Remove excess solvent by pressing the extracted plugs against the insideof the extractor apparatus. Remove the remaining solvent by placing theplugs in a clear vacuum desiccator or oven, heating to 104°F and drawingclean air or other suitable gas through them.

• Plugs extracted and dried as a group are assigned the same lot number.One plug from each lot is subjected to a quality control check; i.e.,extracted and analyzed for the organics of interest. Rejection criteriamust be established individually based on the analytical sensitivityrequired. All plugs from a given tot must be re-cleaned if the qualitycontrol check sample is rejected. The solvents used in the cleaningprocess, quality control check, and field reagents must first be evaluatedusing similar rejection criteria.

• After cleanup, each ptug is wrapped in hexane-rinsed aluminum foil andstored in a cleaned glass jar with a Teflon-lined cap.

Particulates are collected by using glass fiber filters with a collection efficiency of99 percent for particles 0.3 urn diameter, as measured by the Di-octyl phthalatetest. The filters are subsequently Soxhlet extracted using methylene chloride for aperiod of 24 hours and analyzed by Gas Chromatography/Mass Spectophotometry(GC/MS) for priority pollutants and Hazardous Substance List (HSL) organics.

Detection limits will be in the low part per billion range. As with the volatile

organic samples, these samples raquire the collection and analysis of field blanks,duplicates, and matrix spikes.

Total Suspended Particulates (TSP) and Heavy Metals

TSP and heavy metals will be sampled by following the procedure outlined in40 CFR 50, Appendix B - Reference Method for the Determination of SuspendedParticulates in Ambient Atmosphere (High Volume Method).

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In order to collect the sample, glass fiber filters meeting the specifications of theabove method will be employed. The recovery filters will be returned to thelaboratory for TSP analysis. Once paniculate weights have been recorded, metalsanalysis of the paniculate matter collected on the filters will be conducted byInductively Coupled Argon Plasma Emission Spectroscopv (ICAP).

The separate procedure for the collection of TSP/metals and organics is necessarybecause of the difference in sample flow rates required for each parameter. Atthe higher flow rates, the organic compounds can be driven from their paniculatehosts and can be missed in the analysis. Conversely, if both samples were collectedat the lower flow rates, the TSP analysis may be biased.

Sampling Locations

In order to characterize the types of pollutants in the ambient air on and aroundthe site the following sampling locations have been selected.

Volatile Organic Compounds

• Four onsite locations will be based on real-time air monitoring results.The locations selected will be directly downwind of the points that showthe highest response on a photoionization meter.

• Three off site locations will be placed as close as possible to potentialreceptors in the downwind direction of. the site.

• One off site location will be placed in the upwind direction. This will

serve as a background sample.

• One location will be placed in the proposed site trailer area.

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TSP, PCBs and Pesticides, Paniculate Organics, and Heavy Metals

• Three downwind locations will be placed as close as possible to potentialreceptors (same as volatile organic locations).

• One location will be placed at the proposed site trailer area.

• One location will be placed upwind of the site.

The exact location of the air sampling points wilt be approved by the MDNR andEPA. The sampling location strategy outlined above will allow the investigationteam to:

• Characterize point source organic emissions at the four onsite locations.

• Characterize pollutants to which may be a hazard to downwind residents.

• Determine if there are any ambient air hazards associated with theplacement of the site trailer.

• Characterize background levels by analyzing the upwind samples.

Two sampling runs will be conducted. The first run will take place when there is noactive site disturbance. The second run will take place during active site work,such as gravel hauling or drum disturbance. This type of comparison sampling will

allow the investigation team to compare the results to environmental variables, aswell as site activity variables, and provide a better data base to help determine theeffects remedial measures may have on the air quality.

Sample Equipment

Each sample location may require monitoring/sampling for volatile organics, PCBs,pesticides, particulars organics, total suspended particulates, and heavy metals.To provide these analyses the equipment identified in Tabte 3-2 will be required.

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TABLE 3-2

AIR QUALITY EQUIPMENT

Volatile Organics

• Ten low flow air sampling pumps capable of sustaining flow rates of 50 to200 milliliters per minute (ml/min) for eight hours.

• Twenty-four Tenax sampling tubes that have been pre-cteaned andcertified by a laboratory or manufacturer.

PCBs, Pesticides, and Paniculate Organics

• Six high-volume air sampling pumps capable of sustaining flow ratesthrough the sample media of 20 to 30 cubic feet per minute (cfm).

• Thirty-two precteaned polyurethane foam plugs.

• Sixteen glass fiber filters.

• One portable power supply for supplying the necessary voltage to the highvolume air sampling pumps.

Total Suspended Particulates and Heavy Metals_ ^ _ _

• Six high-volume air sampling pumps capable of sustaining flow rates of39 to 60 cfm through the sampling media for 24 hours.

• Sixteen glass fiber filters capable of trapping 99 percent of panicles0.3 um size using OOP test.

• One ponable power supply for the high-volume air sampling pumps.

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Data Evaluation

In addition to comparing the results to accepted health and safety standards, thedata will be reviewed for comparison with

• Similar studies.

• Federal, state, and local regulations where applicable.

• Applicable toxicologicai data for compounds identified during thecharacterization.

The second phase of the program requires the investigation team to address thetendency for the pollutants to enter and disperse in the atmosphere. The team willstudy chemical and physical properties of the identified pollutants, as well aspollutants identified on site but not in the air sampling program.

These properties will then be compered with meteorological data from the NationalWeather Service to develop an estimate of the dispersion characteristics. The

study will address local wind patterns, seasonal changes, and potential remedialmeasures.

Subtasfc 3.2 - Geophysical Investigations

Both surface and borehole geophysical investigations will be conducted at the site*

to assist in evaluating the subsurface geologic and hydrogeologic conditions, and todetermine the presence and extent of buried containerized and bulk wastesbelieved to be present on the site.

Surface Geophysics

Surface geophysics will be used to aid in delineating areas where buried drums,disposal pits, and trenches mey occur, as welt as determining if contaminantplumes can be identified using surface geophysical methods. Surface geophysics

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will be conducted at two key points in the project schedule. An electricalresistivity survey and/or an electromagnetic conductivity (EM) survey, will beconducted prior to the Phase I hydrogeological investigation. A magneticgradiometer survey will be conducted prior to the Phase II hydrogeologicalinvestigation, and after drum removal. Both techniques are described below.

Electrical Resistivity and Electromagnetic Surveys

The first geophysical survey will be conducted prior to the Phase I drilling and willconsist of conducting electrical resistivity and/or EM surveys to aid in delineatingthe landfill on the Rasmussen Site and areas where trenches, disposal pits and otherburied objects may occur on both sites. A Bison 2350B resistivity meter will be

used for the resistivity surveys. Areas for electrical resistivity surveys will beselected after a more complete review of the historical photography, and the sitereconnaissance. Areas where the surveys will probably be conducted include thoseshown on Figure 3-1. The electrical resistivity surveys will consist of conductingvertical electrical soundings (VES) at about 10 to 15 representative locations in thetesting area. Representative areas include those near existing borings so data canbe compared to boring logs, and areas representing the various subsurfaceconditions that could be encountered using the resistivity and/or conductivityprofiling. VES will be made using the Schlumberger electrode array, at spacings of

2 to 300 feet, equi-spaced logarithmically, with six points per decade. The VESprovides a vertical profile of changes in the electrical properties of the subsurfacematerials to a depth of approximately 80 to 100 feet, depending on the subsurfaceconditions. Those changes are used to interpret subsurface conditions, and toprovide a basis for establishing the spacing for electrical profiling.

The VES data will be interpreted in the field to determine the spacings for theelectrical resistivity profiling that will be conducted to aid in delineating burieddisposal areas. Resistivity profiling is conducted by traversing the target area withthe electrodes set at one or two spacings. If the VES indicate that the resistivitydata may be detecting a contaminant plume, an electrode spacing for potential

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plume detection will be selected and a resistivity profile will be producedtraversing the potential plume area.

If surface conditions merit, an EM34-3 and/or an EM31 terrain conductivity meterwill be used to detect the boundaries of possible contaminant plumes. This type ofsurvey would provide more complete coverage of the site. The NUS and MDNRgeophysicists will conduct a brief site reconnaissance prior to initiation of thesurface geophysical work, and they will determine which method, or application ofmethods is applicable and will yield the most useful results.

Resistivity and EM data will be processed daily in the field, using a handcalculator. Once field work is completed, final data reduction will beaccomplished with a Xerox 820 microcomputer. Resistivity values will then beplotted in log format, and matched with Schlumberger master curves (Mooney,1966) for final interpretation. Conductivity data (if any) will be corrected toresistivity, and profiles will be generated for interpretation.

Proper interpretation of the surface geophysical data requires direct subsurfaceinformation such as drilling logs. Several drilling logs are available for the site and

will be used for correlation purposes. However, the existing logs will not besufficient for the entire test area. Since the VES and electrical resistivityprofiling wilt be conducted prior to the drilling and sampling program for thisinvestigation, accurate assessment of the data will be delayed until the Phase Idrilling is completed. However, the data generated from these surveys should besufficient to identify potentially disturbed soils in buried disposal areas, _andapproximately locate the groundwater table. This information will be used to aidin selecting the exact Phase I drilling locations for both soil sampling andmonitoring well installations.

Magnetic Gradiometer Survty

The second geophysical survey will be conducted after the removal of the drumsfrom the Rasmussen Site and will involve using a magnetic gradient (gradiometer)survey to locate buried ferromagnetic materials, such as drums. The gradiometer

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has been chosen because of its ability to resolve composite anomalies into their

individual components. The gradiometer also removes the effects of regionalgradients and diurnal variations. Use of the gradiometer must be delayed untilafter drum removal because the surface drums, and other metal objects, wouldinterfere with the instrument's ability to detect subsurface metal objects.

The approximate locations for the gradiometer survey are those shown onFigure 3-1, although final locations will be determined after a more thoroughreview of the historical aerial photographs and site reconnaissance. Thegradiometer survey will be conducted on a 20-foot grid, oriented toward magneticnorth and staked every 100 feet over the testing area.

Magnetic gradient data will be collected with an EDA Instruments PPM-500gradiometer, which is capable of measuring and recording total magnetic field andmagnetic gradient intensities at each grid location. Hard copies of field data willbe obtained by interfacing the PPM-500 with a thermal printer. These data will beinput to Control Data Corporation Cybernet Computer System for processing anddisplay preparation. This will be done using the CPS-1 program written by RadianCorporation, and consists of griddlng, smoothing, and plotting the data. The

resultant total magnetic field and magnetic gradient control maps will displayareas of anomalous magnetic intensity, which indicate buried ferromagnetic

materials.

Borehole Geophysical Survey

During the hydrogeniogical investigation, the type and thickness of geologicalstrata in the boreholes will be evaluated by means of borehole geophysical surveys.It is proposed that each of the 10 new "deep," rotary drilled wells and selectedexisting MDNR monitoring wells bt surveyed. Open boreholes will be surveyedwith gamma, single-point resistivity, and multiple-electrode resistivity methods.A Keck model SR-3000 logger will be used for this purpose. These logs have beenshown to be useful in defining lithology. Existing MDNR cased monitoring wells

(Figure 3-1} will be togged with natural gamma ray tools. Selected borings mayalso be logged, but the need for such logging is not apparent at this time.

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.A!*.. — .\\1, fELECTRICAL RESISTIVITYSURVEY AREASAPPROXIMATE PROPERTY LINE

DRUMSWARNING SIGNS

BASE MAP IS A PORTION OF TH£ u S.G S. HAMBURG, Ml QUADRANGLES MiNuf? SERIES, WMOTQREVISED 1975).CONT INT .0' WARNING SIGN LOCATION

PROPOSED ELECTRICAL R€SISTIVITY SURVEY AREAS FIGURE 3"'

NUSSPIEGELBERG S RASMUSSEN SITESLIVINGSTON COUNTY, Ml

SCALE l"*2000' CCRPORATiaN

3-24A Halliburton Company

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Subtask 3.3 - Hydrogeological Investigation

Surface geophysical survey results will be used, in part, to guide thehydrogeological investigation as described in that task. The plan described below isbased on the existing available information, but the plan may be modified if thegeophysical survey indicates modifications are required.

The goals of the hydrogeological survey are to

• Define the geologic framework which governs groundwater occurrenceand migration.

• Define the principal onsite aquifers and the general direction ofgroundwater migration both vertically and horizontally.

• Determine the approximate extent of soil contamination and probabilitythat contaminated soils will act as sources of groundwater contamination.

• Determine the general extent and pathways of migration of potentiallycontaminated groundwater.

A phased approach is proposed to accomplish these goals. The drilling and wellinstallation elements of the phases for the hydrogeological investigation aresummarized in Table 3-3, and discussed below. Details of the sampling and analysisare given in Subtask 3.4, Environmental Sampling.

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r

TABLE 3-3

DRJLUHG AND MONITORING WEU INSTALLATION PROGRAM FOR THE HISPKGEIWHG AND RASMUSSEN SITES

LIVINGSTON COUNTY. MICIIIGAN

Phasa olInvestigation Numbaf and Twa ol Bortnus/Walli

10 augar/cabla-lool borings andmonttof tag walls

30 hand-augarad borings

EsllmaladOaplhtfaat)

100 10 170

IMat 10 boNow-siam augar poring* 10

2 hoHow-siam augar borings andmonitoring waHs

Numbaf and Typa of Samplas

170 groundwafar samples forHeld screening 10 monllortng

00 ton tamplM and soHgas lasting of aach bof ahota

40 •ubsurtaca son samptoswtth 4 from aach boring; andsoM gat tailing of aachborahola

20 «ubsurfaca *oU samplas,wllh 10 from aach boring

2 gfoundwaiar tampiaa

Purposa

Tha data wW astabllsh tha gaologlc and hydrogaologlcframawork naadad to daiarmlna lha natura and dagraa ofgroundwalar conlamlnallon banaalh and around lha alia,and lo datarmbia lha dlracllon of polantlal conlarnlnanltransport In groundwatar.

Tha borings wW b« tocalad In araas sutpaclad ofdisposal, basad on lira ravww of lha aartal photographs.sMa racormalssanca. and raslsilvUy profiling. Thadata wfN *a usa4 to daHnaaia araas of conlamlnallonthai wM ba largatad for furihar Invasilgatlon by augarboringi.

Tha borings win ba locaiad Mi largai araas of suspaciadcontamination Idantlflad by lha data from tha hand-aogaiad borings. Tha data wHI ba usad lo aslsbllsh lhanatura and dagraa of soil contamination at tha targai•ras {disposal pll or dltposal araa), and lo datarmlnaIf potanilal groundwatar conlamlnallon occius banaaihthat location.

Tha borings will ba locaiad In targat araas whara lha»oH samplas or soil •imosphara tatls Irom lha 10-fooldaap borings IntUcaia groundwalar conlamlnallon occurs.Tha data will asiabMsh lha nalura and dagraa ofconlamlnallon In lha groundwaiar causad h laachlngthrough conlamlnatad soil ovarburdan.

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rTAME 3-3DHHUNO AND MONfTOfHNG WfU MSTAILATION PROGRAM FOR TIIE MSttCGUMRG AND RASMUSSEN SITESLMNOSTON COUNIY. MICHIGANPAGE IWO

h EstimatedPhase of O«p(h

Investigation Number and Tw»e ol Boflnns/Wells tfeeil

6 hoNow-ilwn bortn0»

2 hollaw-«l«m MIQW boring*•Ad

10

60

Numbr gnd Typ* of S«mpl«»

32 *ubiurl«c« u»Hwtlh 4 from «*ch bwlny; and•oH QH !••!• In Mcti boring

28 subsurface soN samples,with 14 from each boring

2 grotMdwalef samples

Pyrposi

Borlngi win b« localad In areas whara drums war*ramovad during Ina HIM or Emavgancy Action (EA|.Tha data wlH astabNth tha naiwa and dagraa of aoHconlamlnallon and 10 determine H potential groundwatarconlamlnailon occurs baneeth the drUUng location.

Tha borings wHI be located where the 10-fool deepborings Indicate soH conlamlnallon occurs. The datawM esiabHsh the nature and degree of groundwetercoMwnaMtloii cauied by leaching through the contam-inated soH overburden.

c*iI

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Phase 1 - Hvdrooeological Investigation

Phase 1 of the hydrogeological investigation will be conducted to achieve thefollowing goats:

• Define the geology and groundwater flow directions beneath and aroundthe sites.

• Locate areas of soil contamination and determine the nature anddistribution of contaminants in the soils.

• Determine if leaching through contaminated soils are contaminating thegroundwater beneath that area.

Borings and Monitoring Wells

The geology and groundwater flow directions beneath and around the sites will bedetermined by drilling and installing 10 wells, as shown on Figure 3-2. The 10 wells

will be drilled by a combination of hollow-stem augers and cable-tool methods, andlogged by borehole geophysics. The purpose of these 10 wells are to define thegeneral hydraulic gradients (flow directions) around the site and to determine ifgroundwater contamination occurs beneath the site, and if it is migrating off site.The well screens are currently designed to sample only the uppermost aquifer,above any confining layers. This design assumes that if groundwater contaminationexists, it will first appear in the upper aquifer, if the potential exists for deepercontamination, further drilling and well installation may be required. Six of thesewells will be located in close proximity to existing MDNR wells 81-1, 81-3, 81-4,81-6, 81-7, and 81-9. These six borings and wells will be used in conjunction withthe existing welts to better define the geology and the vertical and horizontalhydraulic gradients (flow directions) at these locations. The remaining four rotaryborings and wells will be placed at locations on, and offsite, as tentatively shownon Figure 3-2. The exact location of the remaining four borings will be determinedafter the VES and electrical profiling geophysical data is evaluated forgroundwater table conditions. One of the four borings is tentatively located closed

3-28

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w

^ PHASE I DRILLING (AUGER WELLS)

A PHASE I DRILLING (AUGER/CABLE-TOOL WELLS)

Ci SEDIMENT « SURFACE WATER SAMPLE POINT

S EXISTING MONR MONITORING WELL

BASE MAP IS A PORTION OF THE U.S.G.S. HAMBURG, Ml QUADRANGLE (7.3 MINUTE SERIES, PHOTOREVISEO 1975.)CONTOUR INTERVAL 10*.PHASE I MONITORING WELL 8 SAMPLING LOCATIONS

SPIEGELBERG 8 RASMUSSEN SITESLIVINGSTON COUNTY. Ml

SCALE l"s 1000'

3-29

IMUSCORPORATION

A Halliburton Company

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to the drum areas on the Rasmussen property to determine if groundwater beneaththe drum area is contaminated.

Auger Drilling and Monitoring Wells

There are several areas where contamination is suspected on both the Rasmussenand Spiegetberg properties. The location and testing of areas for contaminatedsoils and buried disposal areas will be conducted using the systematic approachshown on Figure 3-3.

The first step in the approach in Figure 3-3 is to identify "target areas" for furtherinvestigation. Two known target areas are the paint-sludge disposal area on theSpiegelberg property, and the former drum storage area on the Rasmussen

property. Other target areas will be identified. These targets will be identified bythe surface geophysical investigation, evaluation of historical aerial photographs,site reconnaissance, and discussions with residents.

The second step in Figure .3-3 is to determine if the target areas containcontaminated soils. The target areas will include the sand and gravel source beingmined on the Spiegetberg property. The second step will concentrate mainly on thesurface and shallow subsurface soils and is designed to determine if contaminatedsoils occur in areas that could be mined, or pose a direct contact hazard. This willbe accomplished using about 30 hand-augered borings to collect surface and shallowsoil samples at 0 and 2 feet for field screening analysis for volatile organics. PCB'sand laboratory screening for selected inorganic contaminants. Jnorganic screeningwill be conducted for Itad (Pb), chromium (Cr), and zinc (Zn). The screeninganalyses are described in more detail in Subtask 3.4, Environmental Sampling.

in addition, each hand-augered boring will be tested for volatile organic emanations(soil gas contamination) to assist identifying deeper contaminated soils and/orgroundwater. Soil gas testing will be conducted by driving a probe to a depth ofabout 3 feet and drawing air from that depth, into an air bag (or syringe) for field

3-30

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FIGURE 3-3

METHOD FOR lOCATING AREAS OF CONTAMINATIONSPKGE18ERO AND RASMUSSEN SITES

STEP I______ ______STEP 2______ ______STEP 3______ _______STEP 4_______

locale Target Areas Screen Target Areas Test Arees where Install Monitoring Wellsfor further to Local* Areas Screening Indicates In Araas where

__ ol Conjarnjiiatlon Contamination Contamination Is Confirmed

Resistivity Profiling Select 1_rgel • Hand-Auger Borings Select Test • HoNow-Slem Auger Select Monitoring • Hollow-Si am Augerlocation* Borings (10 feel deep) Well locations Monitoring Wells

• Aerial Photography - SoH analysis usingInterpretation field screening for - SoM analysis as In - SoH analysis as In

organlca/lab for Step 2<*i Step 2M)• Site Reconnaissance Inorganics!1)

- SoH gas testing - Groundwaler sampling• Interviews wMft - SoM gee testing ind anetysls. All

Residents • mtafl A*M_ . samples screened InK*W end sent to

*i* laboratory lor*•* . analysis

Samples Indicating organic contamination wW be spNl. and the spUl sampta sentlo a laboratory lor fuH analysis lor organic* and Inorganics.

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screening. The method has been used on other similar sites and has successfullyindicated areas of organic contamination in soil and groundwater. The method isdescribed further in Subtask 3.5, Environmental Sampling. Several of the hand-augered borings will be placed in nontarget areas to test background conditions.

The third step of the approach in Figure 3-2 is to select the locations for drillingabout 10 hollow-stem auger borings to a depth of 10 feet deep to obtain samples atintervals of 0, 2.5, 5, and 10 feet. Locations will be selected based on findings ofthe previous steps. Borings will be located in areas where the soil gas testing orscreening of shallow soils obtained in the second step indicate contamination, orgeophysics indicate buried trenches or pits. The samples from the auger boringswill be screened for volatile organics, PCB's, and selected inorganic metals. Asplit sample from approximately half of these samples will be sent to laboratoriesfor a full analysis of the EPA full priority pollutants, PCB's. and hazardoussubstance list compounds. All samples indicating contamination in the screeninganalysis will have a split sample sent to a laboratory for full analysis. In addition,soil gas testing for volatile organic compounds will be conducted, as described in

Subtask 3.4, Environmental Sampling.

The fourth, and last step, will be to drill and install a monitoring welt beneathselected target areas identified as being contaminated. These wells will determineif, and to what extent, contaminated soils are contaminating the groundwater. Aspreviously stated, one deep rotary boring and well is tentatively planned for thedrum area on the Rasmussen property. An additional two monitoring wells areassumed, for costing purposes, to b« drilled to a depth of 10 feet below the watertable at two possible target areas found to be contaminated. The two wells will bedrilled and sampled using hollow-stem augers. Possible locations for these wellsare shown on Figure 3-2. but the actual locations will be determined based on dataobtained from the 10-foot auger borings.

Phase 2 - HvdroqeoloQical Investigation

Phase 2 of the hydrogeological investigation will be conducted after completion ofthe drum removal, either as an Initial Remedial Measure (IRM), Emergency Action

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{EA) or immediate Removal (IR). Phase 2 will concentrate on the drum areas on

the Rasmussen property since it is obvious that this is an area having significantpotential for contamination of soils and groundwater. The Phase I investigationwill concentrate on the Spiegelberg property and will not be repeated in Phase 2.Approximately eight hollow-stem auger borings drilled to a depth of 10 feet; andtwo auger borings and weils that will extend 10 feet below the water table will beplaced on the Rasmussen property in the drum contaminated area, and the ravinewhere drums were located prior to the IRM or EA. Prior to drilling, thegeophysical gradiometer survey will be conducted to ensure that buried drums havebeen removed and will not be penetrated by the drilling. The gradiometer survey isdiscussed in Subtask 3.2, Geophysical Surveys.

As in Phase 1, these borings and wells will determine the nature and extent of soiland groundwater contamination in this area, and further refine the knowledge ofthe hydraulic gradient flow direction of the water table beneath this location. The

auger borings will be sampled using a split-barrel sampler at depths of 0, 2.5, 5.0,and 10 feet, and at 5-foot intervals below a depth of 10 feet, where applicable.Soil gas tests will be performed in the 10-foot deep auger borings.

Hollow-stem Auoer Monitoring Well Installation (Shallow Wells)

Shallow hollow-stem auger monitoring wells will be constructed using the followingtechniques.

• Prior to entering the drill site, the drilling rig, augers, sampling tools.casing, and screen will be steam-cleaned and casing ends will be capped.

• Augers will be advanced to pra-datermined depths where soil samples aredesired and the auger plug removed and cleaned. The depths will be basedon depths to the groundwatar table. Soil brought to the surface will beplaced, to the extent possible, in 55-gallon drums for temporary storage.

3-33

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• A standard split-barrel sampling device will be lowered through the auger

stem and a soil sample obtained using standard American Society ofTesting Materials (ASTM) procedures designated ASTM-D-1586. {If soilsflow into the augers before a sample can be obtained, the soils will bewashed out with clean water.) Samples will be obtained at 0, 2.5, 5, 10and at 5-foot intervals below 10 feet, where applicable.

• The split-barrel sample will be examined, described, and placed in a glassbottle for potential future use. A portion of the sample will be placed involatile organic testing vials for field screening. The coring device willbe washed with soapy water and then rinsed twice in clean water betweeneach sample. The sample classifications will be logged on the boring log.

• Auger borings that are to receive monitoring wells will be screened to adepth of about 10 feet below the top of the water table. This will providea groundwater sample at the top of the aquifer to determine ifcontamination has leached downward into the aquifer.

• The augers will be advanced to a point about 1 foot above the top of theplanned screened interval, and the casing and screen will be drivenin-place through the hollow augers*. Screens should not be driven if there

is a possibility that, in doing so, the screen would collapse. The casingwill consist of 2-inch diameter galvanized steel pipe with threaded andcoupled joints. Screens will be 2-inch diameter, V-sloued, stainless steel

^__. drive points approximately 3 feet long. A variety of screen slot sizes willbe available so the proper size can be utilized. No organic materials wiltbe used during well construction. Teflon tape will be used on all joints.

• A thick slurry of bentonite and cement will be pumped into the annularspace between the open hole and the casing as the augers are beingremoved. A cement pad will be poured around the top of the casing forprotection against surface runoff.

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• Well development will consist of rod-pumping the well until particles areno longer observed in the produced water. All water produced during

development will be captured in 55-galton drums and temporarily storeduntil a proper disposal method is determined.

• Each well will be capped with a standard vented pipe cap. A chain will bewelded to the casing with a steel loop welded to the cap and secured witha padlock. MDNR will install a concrete post next to wells to allow foreasy location in the field, where necessary.

Auger/Cable-tool Monitoring Well Installation (Deep Wells)

Wells and test holes designed to extend deeper than about 70 feet total, or greaterthan 50 feet below the water table normally experience great difficulty wheninstalled by hollow-stem augers. Therefore, a combination of hollow-stem augerand cable-tool drilling technique will be utilized in such cases. In addition samplesof the groundwater will be taken at 10-foot intervals as drilling advances in eachboring. The method to be used is as follows.

• Borings will initially be drilled using 10 1/2-inch outside diameter6 1/4-inch inside diameter hollow-stem augers to the limit of augerlng, orthe first significant ctay layer encountered. A significant clay layer isdefined as one greater than 5-feet thick.

• Split-barrel samples will be ^attempted every 5-feet and a sample offormation groundwater will be obtained every 10 feet. The groundwater

samples will be obtained from a well-point that will be driven below thebottom of the augers, several feet into the undisturbed formation. Afterthe sample is obtained, the well-point will be removed from the boreholeand drilling will proceed.

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• When the limits of augering have been reached, the augers will be

removed from the borehole and the auger drill-rig will be moved awayfrom the borehole, and a cable-tool rig will be moved onto the borehole toresume drilling.

• The borehole will be continued below the depth of augering, usingcable-tool drilling. A 4-inch diameter casing will be advanced throughthe augers in the borehole during the cable-tool portion of the drilling.Soring and casing will be advanced to the desired depth (150 to 170 feet)or the first significant clay layer.

• Samples of formation groundwater will be obtained at ten-foot intervalsas the boring is advanced by cable-tool, using the driven well-points asdescribed above.

• Once the boring reaches the desired depth, the boring will be logged usingthe natural-gamma geophysical logging tool. This will be used to assist inobtaining the geologic profile of the boring.

• The depth of the monitoring well screen will be selected based on thefield gas-chromatograph field-screening of the groundwater samples and

the geologic profile. Screens will be placed in the zone(s) of apparentcontamination.

• The monitoring well consist of 4-inch diameter galvanized casing withthreaded and coupled joints and 4-foot by 4-inch pipe size V-slot stainlesssteel screen. Teflon tape will be used on all joints. Four-inch diameterwells are the preferred size to allow effective well development and toprovide for pumping tests in the future.

• Wells wilt be developed with compressed air forced through a jetting tool.It may be necessary to add potable water to the well to facilitate welldevelopment. Compressed air will be used to pump water from the welland agitate the aquifer adjacent to the screen until water with no

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observable particles is produced. All development water will be capturedin 55-gallon drums for temporary storage until a proper disposal method isdetermined.

» The annular space outside the casing will be tremie-grouted withcement/bentonite grout

• A cement pad will be poured around the casing at the surface. A standardvented pipe cap will seal the casing top. The cap will be secured with achain and padlock welded in place.

Hvdroqeological Measurements

Water level measurements will be made using standard techniques at thecompletion of each of the three hydrogeological phases and at three timesfollowing the hydrogeotogical study.

In-situ hydraulic conductivity tests will be conducted on all monitoring wellssuitably constructed for such tests. This testing procedure will not require theremoval or addition of water to the well being tested. The procedure involvesraising the water level in the well by use of a vacuum at the well head, allowingthe raised level to stabilize, then conducting a falling-head test to determine thehydraulic conductivity. If a high permeability zone is encountered where thefailing-head test is inappropriate, then a constant head permeability test will beconducted. Constant head testings requires introducing water into the well. Thewater used for testing will be field screened for volatile organics and a sample will

be sent for full HSL analysis. Wells where constant head testing is required will besampled prior to conducting this test. Details of the procedure will be included inthe QAPP.

Subtask 3.4 - Environmental Sampling

The environmental sampling task includes the sampling of soils, sediments, surfacewater and groundwater for the Rt. Sampling for the IRM site investigation is not

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included in this subtask. All sampling and analysis will be conducted according to

the methods, procedures and validation requirements that will be described in moredetail in the Quality Assurance Project Plan for the RI/FS at the sites. Thesampling plan is described for each media to be sampled in the paragraphs below.In addition, a brief discussion of the field screening methods and the soil gastesting is provided.

A summary of the projected sampling plan is presented in Table 3-4. Table 3-4also presents the additional analysis required for quality assurance and qualitycontrol. Additional analyses and their definition are as follows:

• Splits - A split sample taken from the same source and at the same timeas the first.

• Field Blank - A sample of decontaminated water or soil that is prepared inthe laboratory and travels to the site without being exposed.

Soil samples will be obtained during the Hydrogeological Investigation. Soil

samples will be obtained and analyzed as follows: •

Hand-augered Sampling

The hand-augered borings will be used, in part, to assist in delineating areas of

contaminated soils. Two samples will be obtained from each of the thirty boringsfor a total of 60 samples. Portions of the soil samples obtained from the hand-augered borings will be placed in volatile organic testing vials and scanned with an

organic vapor analyzer. Other portions of the two samples taken from each boringwill be composited and will be screened for volatile organics and PCBs with thefield gas chromatograph (GC), for a total of 30 samples. If field screeningindicates a composite sample is contaminated, then the individual samples fromthat boring will be screened. A total of 16 individual samples were assumed for

field screening.

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rTABLE 3-4

ENVIRONMENTAL SAMPLING AND ANALYSISFOH Utt REMEDIAL MVESTIOATION

Sample Type

Soil*

ID

Soil Gas

Sample Phase and, Sarnale Source

Pliese 1 Hydrogeologlcel bmsllgallon

- HMH! augw borings |30 borings)

HoHow-stwn(10 boflno* 10 Mwl

HoHow-stwn Migors(2 monttoriiig wells)

Phase 2 Hydf ogaotoglcal

Hydrog«ologlc«l

- HMH! «ug«r borings (30 borings)

- HoNow-ai*m(10 borings 10 !••! d««p|

Plus* 2 Hy*og«ologkal Invasllgallon

•uo«rs(ft tomlngs 10 !«•! d»«p)

Subtotal SoN OM

104

100

444

86

12

10

67

Ho ol S»mpl«s Using No. of S«mpl«s UsingFl*ld Screening lor Lebofetoiy Screening No of Analysis No ol Analysis

Volatile Oraanlca IQCj* lor mornanks" (Tolal HSL Orpanlcsr golal HSt teorBanksi'

46-3-2

40-2-2

20-1-1

40-2-2

297

60-3-2

10-1-1

16-1-1

20-1-1

20-1-1

U

16-1-1

15-1-1

5-1-1

1S-I-1

73

IS-1-1

15-1-1

S-l-1

IS-1-1

»-|-1

72

•7

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r

TABU 3-4ENVIRONMENTAL SAMPtMO AND AHAIVSISFOH II* HlUtUAL MWSIIOAIIONPAOt TWO

Sample Type

Sediment

Samole PJI§,M Semnle Source

Phaie 1 Hydrogeologtcel Invesllgellon

- Grab temples from sMe

ToUl No. ol Simple* UsingNo of Field Screening for

Anrtvsts VoUlMe Oifltnks IQCf

No. of SvmpUs UsingLlbofeloty Screening

lor Inotaentcs*No. Of Analysis

(Toiil HSl Oroanlcsl*

4-1-1

No of Aneryils(Toiel HSi InoroentciV

4-1-1

Surlece WeiM 1 Hi

IJo Ofoundweter

ISItQMlON

Orab

SuMolel Stirtec*

Phese I Hydfogoologlcel hwetllaellon .

- Enisling MDNH- Augef/CeMe-Tool Borings- Itoleiv monitoring woHs (10 wows)

- Auger monMorlng woUs (2 w*M»)

Ptwse 2 Hyelrogooiogicef tnvestlg«ilon

- AN PtwM I w*Hs

- Augor monHorlng wells (2 wells) 14

23-2-1

4-4-?

273

4-1-1

30170-10-10

24

12

11-1-10

10-1-1

2-1-1

010-1-1

0

0

11-1-110-1-110- 1-1

2-1-1

11-1-1

10-1-1

2-1-1

23-2-1

2-1-0

70

*No Samples - No OupUcales - No. Field Blank*

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Samples indicating organic contamination will be sent to a laboratory for HSL

priority pollutant analysis for organic and inorganic compounds. Several samplesthat indicate no organic contamination will be sent to the laboratory to verify thenonexistence of contaminants in these samples. A total of 15 samples wereassumed for full laboratory analysis.

Laboratory screening for potential inorganic compound contamination will beconducted on samples from borings that encounter waste materials, such as sludge,or soils that appear disturbed or stained from disposal. A total of 15 samples wereassumed for inorganic screening analysis. The selected inorganic parameters forlaboratory screening are lead (Pb), chromium (Cr), and zinc (Zn). These wereselected as indicator parameters based on a review of existing data and reported

wastes disposed on the sites.

Hollow-stem Auger Sampling

The hollow-stem auger borings will be used to locate buried contaminated soils andwastes. Hollow-stem augering will be used for both Phase 1 and Phase 2 of theHydrogeological Investigation. A total of 60 soil samples are anticipated from thehollow-stem auger drilling. Portions of the soil samples obtained from the hollow-stem borings will be placed in volatile organic testing vials. All samples will bescanned with an organic vapor analyzer. Alt samples will also be screened forvolatile organic compounds and PCBs with the field GC. Samples indicatingorganic contamination will be sent to a laboratory for full HSL priority pollutantanalysis for organic and inorganic compounds. Several samples that indicate noorganic contamination will be sent to the laboratory to verify the nonexistence ofcontaminants in these samples. A total of 40 samples were estimated for fulllaboratory analysis, with 15 designated for the 10-foot deep drilling, and5 designated for the monitoring well drilling in both Phase 1 ar.d 2.

Screening for potential inorganic contamination will be conducted on samples fromborings that encounter waste materials, such as sludge, or soils that appeardisturbed or stained from disposal. A total of 40 samples were assumed forinorganic compound screening.

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Sediment Sampling

Four sediment samples will be obtained from the areas shown on Figure 3-2 todetermine if erosion on portions of the Rasmussen Site has transportedcontaminated soils into these areas. These samples will be analyzed for PCBs,which are known to contaminate soils on the Rasmussen Site. HSL Base Neutral,and Acid Extractable Organics, and HSL metals. The exact sediment samplinglocations will be selected as the most likely to have received contaminatedsediment from the drum areas.

Surface Water Sampling

Surface water samples will be collected at the same location and time as the foursediment samples, as shown on Figure 3-2. Surface water samples will be analyzedfor the HSL, priority pollutants for both organic and inorganic compounds.

Groundwater Sampling (Borings)

Groundwater samples will be obtained from the 10 rotary auger/cable-toot boringsat 10-foot intervals throughout the length of the boring. A total of about170 samples may be obtained. The samples will be placed in volatile organictesting vials and scanned with an organic vapor analyzer. Samples will also bescreened using the field GC for volatile organic compounds. Approximately190 samples have been assumed for field screening. The field GC screening isdiscussed further in subsequent sections of this subtask. This information will beused to aid in establishing depths of the well screens. Groundwater that exhibitcontamination by the field GC screen will be split and forwarded to a laboratoryfor EPA Hazardous Substance List (HSL) priority pollutant organic analysis. TheHSL analysis determines the presence of, andquantities of, organic compounds considered to be hazardous by theU.S. Environmental Protection Agency. A total of 10 samples were assumed forthe full laboratory analysis.

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Groundwater Sampling fWells)

Groundwater sampling will be conducted two weeks after each group of wells iscompleted in the hydrogeologic investigation. Thus, two weeks after thecompletion of wells scheduled in Phase 1, all nine existing MDNR wells and the10 new rotary drilled wells and the two hollow-stem drilled wells will be sampled.The same procedure will be used at the completion of the two Phase 2 wells. Twosamplings will be conducted for each well, for a total of 46 samples.

The groundwater sampling of Phase 1 and 2 monitoring wells will require ananalysis for HSL total organics and inorganics to establish the character ofcontamination. Duplicate samples will be taken and will be field screened with theGC to determine possible volatile organic contamination.

Sampling will be conducted using the sampling protocol approved in the QAPP.Well purging will be conducted with a standard submersible pump (wells with 4-inchcasing), a centrifugal pump (wells with 2-inch casing and shallow water levels), or abladder type submersible pump (shallow wells with deep water table). The amountof water purged will equal three to five times the volume of stagnant watercontained in the casing. Purge water will be stored in precleaned 55-gallon drums.

Pumps will be decontaminated before moving to the next well.

Samples for chemical analysis will be collected with a bladder type submersiblepump. Sampling will proceed from the least contaminated well to the mostcontaminated based on available information. Specific procedures for purging andsampling will be addressed in the Quality Assurance Project Plan.

Soil Gas Sampling

Soil gas sampling and testing has been used successfully to detect soil and

groundwater contamination on sites where volatile organic compounds occur ascontaminants. Soil gas testing has successfully detected groundwater and/or soil

contamination on sites where the groundwater table was as deep as 100 feet belowthe ground surface. The principle for using soil gas as an indicator of

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contamination is based upon the fact that certain organic compounds volatilize in

the soil and/or groundwater, thereby introducing gaseous organic contaminants tothe air located between the grains of soil {soil gas). The contaminated soil gasmigrates upward by diffusion and by fluctuations in atmospheric pressure and thegroundwater table elevation, so that shallow surface soil gas becomescontaminated, and is detectable using sensitive analytical testing devices.

The soil gas testing method is easier, quicker and much less expensive than drilling

and monitoring well installations normally required to determine the presence ofcontamination. However, the method only approximates the location and relative

concentrations of volatile organics present in the soil and/or groundwater and it

does not detect nonvolatile organics nor inorganic contaminants. Thus, the method

is suited for screening, but not for exact determinations of the type andconcentrations of contaminants at those locations. The method will be used forthis investigation to assist in locating contaminated soils and potentiallycontaminated groundwater so that drilling and monitoring well locations can be

optimized.

The soil gas testing will consist of driving a hollow steel tube to a depth of

approximately three feet, then drawing a sample of soil gas from that depth using avacuum pump. The vacuum pump will be attached to the tube with tygon tubing,

and the sample will be extracted by inserting a syringe into the tubing and drawing

the sample from the tygon tube. The sample will then be analyzed by screening

with field GC. After the three-foot deep sample is obtained, the tube will bedriven to about six-feet deep and the process will be repeated.

Air Sampling

Air sampling will be conducted to determine the health risks for onsite workers,and for of?site residents. Sampling will be conducted as described in Subtask 3.1 -Air Quality Analysis. Table 3-5 summarizes the proposed air sampling program.

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rTABLE 3-5

AIR SAMPLING ANALYSIS

i*»u*

Sample locations

4 onsite locations

2 offsile locations

1 trailer location

1 upwind location1 duplicate1 blank1 matrix spike

of Samplings

2

2

Type of Analysis

VGA

VGA, TSP. PCB and PEST.

Part. Org , Heavy Metals

Sampling Media

Tenax.

PDF (2) glass fiberfilter, glass fiberfilter

Total Sample Analysis - VGATSPPCB & PEST.Heavy MetalsPart. Org.

i(1) VGA - Volatile Organic Analysis

TSP - Total Suspended ParticularsPCB - Polychlorinated BlphenylPEST. - PesticidesPart. Org. - Paniculate OrganicsPUF - Polyurelhane Foam

24 Tenax at 2 sections per location16 glass fiber filter (same as that on heavy metals)16 PUF plugs (2 per sample location - 32 analysis)1616 glass fiber filter collected in series with PUF plugs

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Field Screening

Water, soils, and soil gas samples will be field screened for volatile organics usinggas chromatography. The procedures that will be followed will be modifiedversions of EPA methods 601, 602, and 610 for purgeable halocarbons, purgeablearomatics, and polynuclear aromatic hydrocarbons. These procedures are found inthe Federal Register Part III - Environmental Protection Agency's guidelinesestablishing test procedures for the analysis of pollutants. These methods willproduce quantitative results of the target contaminants which are not bounded byprecision and accuracy limits. This field screening will enable the field teams toeliminate excessive samples being sent to the laboratory and quickly identify areasof high contamination during drilling operations. To insure that field resultscomply with Quality Assurance/Quality Control protocol and produce the mostreliable results, field and reagent blanks, standards, and duplicates wilt be run.

In addition, existing data from previous sampling provided by MONR will beutilized in conjunction with field-screening for PCBs to generate a data base todetermine the extent of PCS contamination in the drum storage area and in gravel

areas suspected of PCS contamination.

Details regarding the soil gas testing will be further described in the Quality

Assurance Project Plan for the RI/FS.

Subtask 3.5 - Field Monitoring

Field monitoring will involve activities to ensure the safety of sit* workers andresidents around the site. Field monitoring will occur throughout the siteinvestigation. The equipment and techniques used will depend on the specific taskbeing completed. The following sections outline the equipment and proceduresestimated to be required for each task.

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Geophysical Investigations

A site survey for organic vapors wilt be performed prior to survey start-up todetermine if site conditions have changed since previous activities. Because theseactivities will not disturb site soils or refuse, it is believed that those areaspreviously found to be free of organic vapors would not change. However, anyactivity in areas where there is a possibility for contamination (i.e., drum piles,open refuse areas, stained soils, boreholes) will require monitoring during workactivities.

Drilling

Because of the possibility of groundwater contamination, all borings will requireconstant air monitoring. The instruments to be used will be a photoionizationmeter and LEL/02 meter. Using these two instruments in tandem will allow thedetection of organic vapors, including methane, and will measure the relativeftammability of any possible contaminant mixture in air.

In addition to the constant air monitoring performed during the drilling program,all samples taken from the borings will be screened with a photoionization meterfor organic vapors. This procedure will identify the possibility of personnelexposure to concentrated organic vapors that may be present in the sample.

Groundwater Sampling

"WPrior to the sampling of any monitoring well, an organic vapor screen, will be

performed. This will b« accomplished by screening the well prior to opening andagain after opening. The monitoring wells will also be screened during the

sampling procedure to determine if the disturbance created during sampling causesany organic compounds to volatilize. Any elevated readings found during thesampling will require that the qualitative aspects of the contaminants beidentified. This information may be gained by using a head space sampling at thewell head and screening for volatile organics using the Field GC. The data

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generated during the monitoring will be used to update the health and safetyrequirements as necessary.

Surface Water and Stream Sediment Sampling

Before any surface water or sediments are sampled, sampling areas will besurveyed with an OVA. Any readings above background levels found during thesurvey will require identification in order to prescribe the proper levels ofrespiratory protection. The identification may be performed using colorimetrictubes.

Task 4.0 - Site Data Evaluation

The site data evaluation includes two major subtasks, data validation, reduction,and evaluation, and a public health and risk assessment. Each of these subtasks aredescribed below.

Subtask 4.1 - Data Validation, Reduction, and Evaluation

Data obtained during the Rt will be evaluated as part of the ongoing siteassessment as the Rl proceeds. Both NUS and MDNR will collectively review thedata as it is obtained and both NUS and MDNR will determine subsequent coursesof action, where required. Once all the data from the various field tasks arecompiled, an evaluation report of the data will be prepared to ensure that theinvestigation data are sufficient in quality and quantity to define the nature and

extent of contamination well enough to support the FS. The following methods andtechniques will be included in the data evaluation.

• All chemical analytical data must be validated according to criteriaspecified in the quality assurance plan. No chemical data can be used fortechnical decisions until the validation of the data is completed.

* AH chemical data will be entered into an NUS data base system for easeof recall and comparisons.

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• The location, thickness, and character of areas containing waste will beoutlined on a topographic map.

• Contaminated surface soil and sediment areas will be characterized onthe topographic map, with respect to contaminant type, samplinglocations, and approximate concentration for one or more indicatorchemicals. Areas where contaminated soils or sediments extend into thesubsurface will also be depicted on the map.

• Site geology will be depicted on a series of geologic cross-sections thatwill transect the most pertinent waste and/or contaminated areas of thesite. The cross-sections will be referenced on a topographic base map.

• Groundwater flow gradients and directions will be depicted ongroundwater table (piezometric) contour maps superimposed on atopographic map. The monitoring well locations will be shown on thetopographic map. Flow nets will be constructed, using the water table

contour map and geologic cross-sections to estimate the rate and volumesof groundwater flowing beneath the site.

• Groundwater contamination wilt be depicted as isoconcentration contoursfor indicator chemicals superimposed on the water table contour maps.

This assumes the data base and hydrogeologic conditions permit accurateisocentration contours to be constructed.

• The quantity of groundwattr r«ch»rg« through the waste materials andcontaminated areas will be estimated using an analytical water balance

method. One method that may be used is an ERA technique described inERA publication 530/SW-168, "Use of the Water Balance Method forPredicting Leachate Generation from Solid Waste Sites, October, 1975."

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• Air quality data obtained for the site will be presented in tables. Airsampling locations will be depicted on a topographic base map.

• A series of maps will be prepared showing potential receptors ofcontaminants from the site in relation to the various contaminated media.Receptors will include water well users, local streams and ponds, and airreceptors, if appropriate.

The evaluation report will discuss the adequacy of the data base and identify anydata gaps that may require further investigation. The report will reassess thepreliminary remedial technologies identified in Subtask 2.8 and recommend anyfurther requirements for data collection, initial remedial measures, or otherpossible remedial action alternatives not previously identified.

Subtask 4.2 - Public Health and Environmental Risk Assessment

The public health and environmental risk assessment is the main instrument usedfor determining the scope of the remedial action to be taken at a site. The "no

action alternative," to be evaluated in compliance with the NCP regulations.requires an assessment of the impact of the site on the public health andenvironment assuming the site is not remediated. In addition, performance of therisk assessment will aid in identifying any gaps in the data that may occur.

A Risk Assessment is also an integral part of the FS and is executed after the.remedial alternatives to be studied have been identified. It assesses the healthrisks and environmental impacts associated with each of the remedial alternatives

studied to evaluate the reduction in risks and impacts. This occurs after all of theavailable and relevant technologies have been screened and is used to determinethe most effective action. A section of the FS Report will include the RiskAssessment as one of the evaluation elements for each remedial alternative.

The objective of the Risk Assessment is to define, in site-specific terms, both thehealth risks to the general population and the environmental impacts associatedwith the contaminants. The results of the Risk Assessment are used as input into

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the decision process to determine the scope of an FS and the risks and impactsassociated with a "no-action" alternative.

The Risk Assessment is divided into two basic sections, (1) health risks and(2) environmental impacts. Each of the sections, where applicable, will includesimilar components. Health risks will be evaluated on the basis of the lexicologicalnature of the contaminants and the probability of exposure. In the case ofenvironmental impacts, the migration potential will be considered.

In the characterization of the contaminants, a list of critical contaminants will beselected for extensive evaluation. For the population at risk, health impacts, basedon the lexicological nature of the individual pollutants, are the major criteria forinclusion on the selected list. Toxicology factors considered will include acute andchronic toxicity for short-term and long-term exposure, birth defects (ifappropriate), and carcinogenicity. If determinate, synergistic and antagonisticassociation will be added to the evaluation. Environmental impact analysis (whereappropriate) wilt include, but not be limited to aquatic toxicity, ecological impacts(terrestrial and aquatic) on flora and fauna, reduction in amenities associated withrecreational use of the land and waters, and aesthetic impacts.

Factors used for evaluating the probability of exposure and health risks will include

the migration potential and environmental fate of each contaminant in site-specific terms. Hydrogeologic factors, topographical features, and distributionpatterns of the contaminants are also included in evaluation of the transportdynamics. Biological and chemical processes will be factored into the process.Food chain entry will also be considered for bioaccumulative and biomagnifiedcontaminants. Plant and animal food sources will be included.

Probability of exposure will also consider the location and presence of humanreceptors in the paths of migration and the specific route (inhalation, ingestion, ordermal exposure by direct contact) into the target organism. If possible, anotherfactor to be analyzed is the mobility of the contaminant, once it passes the outerbarrier, toward target organs (i.e., liver, central nervous system) that areassociated with the health effect.

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The public health and environmental risk assessment will be included in theevaluation report.

Task 5.0 - Remedial Investigation Report

Numerous reports and technical memoranda will be completed for each task andsite investigation activity as described in Tasks 1 to 4. Rl Report preparationinvolves the compilation and editing of these documents into a comprehensive,coherent report. In addition, technical information provided by MDNR activitieswill be incorporated into the report. The overall format of the Rl Report will be asfollows.

Chanter ___________Title__________1 Introduction2 Site Environs

3 Climatology4 Soils

5 Surface Water Hydrology6 Geology and Hydrogeology7 Hazardous Substances8 Public Health and Environmental Concerns

A detailed report outline will be submitted to MDNR and EPA for review and

comment during the initial stages of this task. The final report will be submittedto MDNR and EPA for comment and approval.

3.3 Phase II - Feasibility Study

Task 6.0 - Description of Current Situation and Scope Refinement

The scope of work for the FS, as presented in this Work Plan, will be reviewed todetermine if modifications are required on the basis of findings from the Rl.Modification, if required, will be made by submitting a Work Plan Modification that

will include the following major sections:

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Chapter __________Title__________1.0 Description of Modification

2.0 Purpose of the Modification

3.0 Technical Approach - This section refers tothe Specific Tasks that will be Modified

4.0 Estimated Cost and Schedule Revisions

The Work Plan Modification will be submitted to MDNR and EPA for approval.Work will not proceed until the Work Plan Modification has been approved by the

Contracting Officer of MDNR and the EPA Project Officer.

Task 7.0 - Development of Alternatives

The alternatives for source control or off site removal actions will be developedfrom the alternatives identified in Subtask 2.8, Subtask 4.1. and Task 5.0, RlReport. The selection of objectives for evaluation of remedial measures must bebased on public health protection and site-specific conditions.

The remedial response objectives and site-specific objectives for the responsebased on public health and environmental concerns, the Remedial Action MasterPlan, information gathered during the remedial investigation. Section 300.68 of theNational Contingency Plan (NCP), EPA interim guidance, and the requirements ofany other applicable Federal or State statutes. Preliminary cleanup objectivesshall be developed in consultation with EPA, and the Spiegelberg/Rasmussen Task

Force.

Specific objectives of remedial measures will be determined after completion ofthe remedial investigation. However, based on available information, the followingpreliminary objectives have been established.

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• Public Health and Safety Assurance. This includes health and safety

protection of local residents, field crews, and future land users fromhazards associated with exposure to the types of chemical contaminationidentified in the Rl. Both short- and long-term hazards are considered.

• Mitigation of Surface Water Impacts. Migration of wastes due to riverflow, bank or dike erosion, and river flooding must be controlled.

• Protection of Groundwater and Drinking Water Supplies. The preventionof degradation of any potential groundwater or drinking water supplieswill be addressed.

• Soil Protection. Further contamination of soils and sediments by contactwith the wastes wilt be prevented.

• Air Quality Protection. The prevention of release of contaminants intothe air will be addressed.

Criteria for evaluation of remedial alternatives must provide a means for testing

the suitability of the candidate remedial measures. Standard criteria forevaluation will include the following.

• Technical Feasibility. The technical feasibility and implementabilitywithin the constraints of acceptable engineering practices will beconsidered. ... Implementation and maintenance of the remedial measure

will be considered. Past effectiveness of the remedial measures in similarsite circumstances will be investigated.

• Health and Environment Risk Assessment. The potential for environ-mental contamination will be considered, such as spills or air emissions, inthe implementation of the remedial measures, as well as risks to thesafety and health of the site investigation teams.

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• Effectiveness. The degree to which the remedial measure will reduce

long-term environmental impact will be considered, including air, surfacewater, groundwater and soil contamination; ecologic impacts; and impactsupon human health. The reliability of post-closure monitoring systemswill be included. The ranking of relative effectiveness witl depend largelyon past performance of similar remedial measures. Best engineeringjudgment based on thorough knowledge of site conditions will be usedwhere past experience is deficient.

• Costs. All capital expenditures and annual operating and maintenancecosts associated with the remedial measure will be considered. Annualcost comparisons for each of the methods will.be performed by amortizingcapital over a selected time period to determine equivalent annual costs.Present-worth costs will be used.

As with the selection of objectives, the Rl findings will be used in remedialalternative evaluation. Additional criteria are not anticipated; however, each of

the criteria can be weighted to reflect the requirements of site-specific conditions.For instance, effectiveness might be more important than cost, and this relativeweighting can be reflected in the evaluation process.

Review meetings with the MONR and EPA will serve to develop the finalobjectives and criteria. A report will be prepared addressing the remedial response

objectives and technologies applicable to the site.

Task 8.0 - initial Screening of Alternatives

The remedial alternatives identified in Task 7.0 will be screened with the MDNRand EPA to identify measures that are not appropriate fo: further detailedevaluation. Evaluation criteria for the initial screening may include, but not belimited to. the following:

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• The cost for implementation, operation and maintenance, and monitoring

• The public health, welfare, and environmental effects created byimplementation of the remedial measure

• The degree of environmental protection that the remedial measure canprovide

• The feasibility and reliability of implementing the remedial measure

In addition, alternatives will be presented and discussed with the community, andresulting comments will be part of the screening process.

Task 9.0 - Laboratory Work Plan Preparation

After the Rl has been completed and the remedial actions have been identified inTask 8.0, it may be necessary to conduct additional field testing or pilot or bench-scale treatability studies to evaluate some of these actions. This work wouldinclude any studies required to evaluate the effectiveness of remedial actions andto establish engineering criteria necessary for design and implementation. Thesetreatability studies will be used to evaluate remedial actions applicable to thepotentially contaminated media at the site. Potential remedial technologies, whichmay be investigated through pilot or bench-scale studies, may include differenttypes of groundwater treatment. Literature reviews of treatment technologies willbe used where possible. ~

Because these laboratory studies are linked directly to the prior performance ofother FS tasks, a separate Work Plan for any proposed laboratory studies will besubmitted to the MDNR and EPA for approval, if such ttudies are warranted. Thecosts presented here include only the preparation of the Work Plan.

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Task 10.0 - Remedial Alternatives Evaluation and Preliminary Feasibility ReportPreparation

Alternatives selected from Task 8.0 as potential remedial actions will be evaluatedto determine the most cost-effective actions. Sufficient data must be developedto evaluate and compare each of the prescreened alternatives. The detaileddevelopment of each alternative will include the following:

• Description of appropriate treatment and disposal technologies.

• Special engineering considerations required to implement the alternative,including any pilot treatment facilities, or additional studies needed toproceed with final remedial design.

• Environmental impacts and proposed methods, and costs, for mitigating anyadverse effects.

• Operation, maintenance, and monitoring requirements of the remedy.

• Off site disposal needs and transportation plans.

• Temporary storage requirements.

• Safety requirements for remedial implementation, .including both onsiteand offsite health and safety considerations.

• An analysis of how the alternative could be phased into individual operationand a discussion of how these operations could best be implemented,individually or in combination, to produce a significant improvement to theenvironment or savings in costs.

• A review of any proposed offsite treatment or disposal facilities to ensurecompliance with applicable current and proposed RCRA and Staterequirements (provided by the state).

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In addition, an Environmental Assessment will be performed for each alternativeincluding, at a minimum, an evaluation of each alternative's environmental effects,

an analysis of measures to mitigate adverse effects, physical or legal constraints,and compliance with Federal and State regulatory requirements.

An incremental-step approach can be used in presenting the evaluation results forselection of the remedial measures. This approach identifies the increased costsassociated with increased levels of remediation. The no-action alternative would

provide the basis of essentially a no-cost alternative. The feasibility of a no-actionalternative must be verified by a complete risk assessment of potential healththreats associated with wastes left at the site.

As a result of the evaluation process, the most cost-effective remedial alternativewill be identified, i.e., the lowest cost alternative that is technically feasible,reliable, implementable, and adequately protects the public health andenvironment. A preliminary report will be prepared for regulatory agency reviewand selection of the remedial alternative to -be implemented. The report will

summarize the results of the remedial alternative development and initialscreening (Tasks 7 and 8) and the evaluation process.

Task 11.0 - Selection of Cost-Effective Alternative

The State will make a final recommendation to ERA who will decide on theRemedial Action Alternative that will enter conceptual design after comments arereceived from local .officials and the community on the detailed evaluation ofalternatives. NUS will provide support of the selection, if requested.

The following considerations shall be used as the basis for selecting the effective

alternative:

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• Reliability. The alternatives that minimize or eliminate the potential for

release of wastes into the environment and that utilize proven technologieswill be considered more reliable than other alternatives.

• Imptementabilitv. The alternatives most easily implemented based ontechnological, political, legal and community acceptance considerationsshall be favored.

• Effects of the Alternatives. The alternatives posing the greatest

improvement to (and least negative impact on) public health, welfare, andthe environment will be favored.

• Safety Requirements. The alternatives with the lowest adverse safetyimpacts and associated costs will be favored.

• Cost. The alternative with the lowest total present worth cost will befavored. Total cost will include the cost of implementing the alternativeand the cost of operations and maintenance of the proposed alternative.

Task 12.0 - Conceptual Design Development

Following selection of the remedial actions to be implemented at the site, aconceptual design and budgetary cost estimate of the selected remedial action wiltbe prepared for use in subsequent development of the detailed construction plans.

A conceptual design plan will be prepared, which includes the following items:

• Remedial action design criteria• Preliminary site and facility layout drawings• Operation and maintenance requirements• Monitoring requirements• Site health and safety plan• Institutional requirements• Scheduling and implementation requirements

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• Budgetary capital and operation and maintenance cost estimates• Additional information needs for final design

Task 13.0 - Final Report

A final report (Table 3-6) that summarizes all activities conducted during theRI/FS will be prepared and submitted to the MDNR and ERA for review. Thisreport will summarize the site background, contain the findings of the Rl, includinganalytical results, summarize the remedial action evaluation process, present thejustification for selection of the chosen remedial action, and contain theconceptual design drawings and supporting information. The report will contain allappendices, results, etc., that facilitate further public review or aid in subsequentprocurement and contracting.

Task 14.0 - Additional RequirementsTask 15.0 - Community RelationsTask 16.0 - Development of Phase II Cooperative Agreement Application

As specified in the MDNR Request-for-Work Plan, Tasks 14.0. 15.0 and 16.0 will bethe responsibility of the state. NUS will be prepared to assist the MDNR in any of

these tasks.

3.4 Phase HI - Initial Remedial Measure Planning

Task 17.0 - Site Investigation _•

The purpose of the site investigation is to characterize the wastes in the drum pilesand surrounding soils in sufficient detail to support the focused Feasibility Study(FFS) for Initial Remedial Measures (IRMs). Design and implementation of any IRMwill be addressed upon review and approval of the FFS by the ERA.

The main elements of field work for the limited site investigation to be conductedin the drum area on the Ramussen Site is determining what is in the drums, and ifburied drums occur in locations immediately adjacent to the visible drum areas.

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TABLE 3-6

OUTUNEFEASIBILITY STUDY FINAL REPORT

EXECUTIVE SUMMARY

1.0 INTRODUCTION1.1 SITE BACKGROUND INFORMATION1.2 NATURE AND EXTENT OF PROBLEMS1.3 OBJECTIVES OF REMEDIAL ACTION

2.0 INITIAL SCREENING OF REMEDIAL ACTION TECHNOLOGIES2.1 TECHNICAL CRITERIA2.2 ENVIRONMENTAL/PUBLIC HEALTH CRITERIA2.3 INSTITUTIONAL CRITERIA2.4 OTHER SCREENING CRITERIA2.5 COST CRITERIA

3.0 REMEDIAL ACTION ALTERNATIVES3.1 ALTERNATIVE 1 (No Action)3.2 ALTERNATIVE 23.X ALTERNATIVE X

4.0 ANALYSIS OF REMEDIAL ACTION ALTERNATIVES4.1 ALTERNATIVE 2

- Non-Cost Analysis- Cost Analysis

4.2 ALTERNATIVE 3- Non-Cost Analysis- Cost Analysis

4.X ALTERNATIVE X- Non-Cost Analysis- Cost Analysis

4.4 NON-COST CRITERIA ANALYSIS4.4.1 Technical Feasibility4.4.2 Environmental Evaluation4.4.3 Institutional Requirements4.4.4 Public Health Evaluation

4.5 COST ANALYSIS

5.0 COST- EFFECTIVE ANALYSIS

6.0 RECOMMENDED REMEDIAL ACTION PRE-DESIGN REPORT

7.0 CONCEPTUAL DESIGN (optional)

REFERENCES

APPENDICES

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Certain subtasks of the Rl will provide some data regarding the hazard posed by

the drum area. These subtasks include the electrical resistivity profiling whichmay help delineate buried drum areas; the rotary boring and monitoring well to beplaced in this area during Phase I of the Hydrogeological Investigation; and theSediment and Surface Water Sampling. However, a backhoe will be required forthis limited site investigation to help move drums, and test locations for burieddrums.

Subtask 17.1 - Health and Safety Plan

A Health and Safety Plan to address the site-specific conditions encountered duringthe site investigation and IRM will be prepared upon acceptance of the NUS WorkPlan. The Health and Safety Plan will follow the overall proposed plan previouslyidentified in Subtasks 2.2 and 2.3. The plan will be consistent with the following.

• EPA Occupational Health and Safety Manual.

• EPA Interim Standard Operating Safety Procedures and other EPAguidance as developed by EPA.

• Michigan Occupational Safety and Health Act Site Conditions.

• Section lll(c)(6) of CERCLA.

• EPA Order 1440.1 -.Respiratory Protection.

• EPA Order 1440.3 - Health and Safety Requirements for employeesengaged in field activities.

Subtask 17.2 - Waste/Site Characterization

The waste/site characterization will consist of obtaining samples from the drumson the Rasmussen Site so that the hezards posed by the drums can be assessed. Thedrum sampling will involve sampling the contents of about 10 percent of the

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estimated 3000 buried drums on the Rasmussen Site. It is estimated that thecontent of the drums will be encountered in the following states: liquid, liquid andsolid, semi-solid, and solid.

Sampling of the drum contents- will be performed on the in-place drums be eithersampling the contents which may have seeped through the bungs punctures in thedrums or by removing the bungs from the drums. No drums will be moved wrthmachinery for this investigation. The project field representative will identitywhich drums will be sampled and will select the drums in a manner to present arepresentative mix of the existing drums.

This scope of work will involve the following tasks:

• Identify the drums to be sampled.

• Obtain samples from the drums.

• Prepare documentation identifying the following information:

- Date of sampling- Location of drum- Condition of drum- Method used to obtain sample- Name of sampler

• Prepare the sample for shipping to laboratory.

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• Perform the following tests on the samples:

- Compatibility tests- EP toxicity tests- PCB tests (soil)- Priority po.llutant tests

• Prepare a brief report to outline the drum disposal method based on theresults of the laboratory testing.

Subtask 17.3 - Data Validation and Evaluation

The laboratory results will be validated and the results of the tests performed onthe drum contents will be listed and presented in tabular form.

Subtask 17.4 - Final Report

The results of the sampling and testing conducted will be compiled into reportform, which will also include conclusions that may warrant the implementation ofremedial measures.

Task 18.0 - Focused Feasibility Study for the Initial Remedial Measures Development

The purpose of the focused Feasibility Study will be to delineate and evaluate themethods to remediate the existing conditions of the two drum disposal areas.contaminated soils, and any other areas requiring initial remedial measures.

The objectives of the IRM are to protect the public from risk to health, posed bythe site.

Subtask 18.1 - Identification of Alternatives

Various methods can be selected to meet the objectives of the IRM FocusedFeasibility Study. Technologies will be identified, than screened to select the

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technology or technologies most applicable to the site. Once the applicabletechnologies are selected, they can be used to describe the available initialremedial alternatives. A study of the costs for each alternative will disclose themost feasible and cost effective alternatives.

Subtask 18.2 - Evaluation of Alternatives

Alternatives that pass the screening process will be evaluated using the followingcriteria areas:

• Cost

• Effectiveness in meeting objectives

• Engineering feasibility

• Operation, maintenance, and monitoring requirements

• Oft site disposal needs and transportation plans

• Temporary storage requirements

• Safety requirements to protect onsite personnel and the surrounding

community

• Public concerns

• Environmental impact

• Regulatory compliance

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Subtask 18.3 - Selection of Cost-Effective Alternative

A cost effective alternative will be recommended based on the results of theevaluation.

Subtask 18.4 - Report of Findings

A report containing the analysis of data, identification of technologies, screeningof technologies, identification of alternatives, and the result of the evaluation ofalternatives will be presented in the form of a draft and final focused FeasibilityStudy Report. The final FFS report will be submitted to MDNR.

Task 19.0 - Design and Specifications

If an initial remedial measure has been selected, a construction plan will bedeveloped to describe the method, quantities, and procedures that will be requiredto obtain a contractor to perform the selected remedial measure. Design andspecifications are not part of this Work Plan and no manhours or costs are included.However, if a construction plan Is required, the plan will include

• Construction Drawings• Soil and Erosion Control Plan• Utility Drawings• Cross-Sections• Site Plan . . . . _ . .

• Quantity Sheets• Bid Documents• Specifications• Operation and Maintenance Procedures• Health and Safety Plans• Permit Requirements.

NUS will be prepared to assist the State of Michigan to identify, obtain, complete,and submit the applicable permits necessary to implement the IRM procedures.

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NUS will be prepared to assist the State of Michigan in the development of

applicable documents required to obtain bids and qualifications from contractorsincluding review of resulting bids.

Task 20.0 - Implementation of Selected Initial Remedial Alternative

If an IRM is required, NUS, or other MDNR contractor as directed by MDNR, willschedule a pre-construction meeting prior to initiating any IRM procedures, inorder to inform the IRM contractors of the specific nature of the work and of anyspecial requests from state and federal agencies. The meeting will address thepurpose of the project and outline the construction procedures to be followed.Special attention will be paid to the implementation of the Health and Safety plan.Any revisions or suggestions resulting from comments presented during thesediscussions will be incorporated into the construction plans and specifications priorto commencement of work.

The permits required to commence work will be listed along with requirements tobe fulfilled in order for the contractor to move his equipment to the site. Planswill be implemented as "Action Items" to assign the responsibility for obtaining therequired clearances in order to perform the task. If special equipment is required,plans will be developed to obtain it and to train personnel in its use. NUS, or otherMONR contractor, will supply the services of full-time personnel to act as onsiteinspectors if requested by MDNR. The primary duties of the inspectors will be asfollows.

• Document the work performed by the contractor.

• Review the work being performed, so that it is in accordance with theplans and specifications.

• Maintain daily field logs (Appendix A, Anachment No. 1).

• Review and monitor the progress of the IRM.

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• Assist the IRM contractor^) in understanding the plans and specifications.

• Act as liaison, if requested, between the State of Michigan and the IRMcontractor(s).

• Review, if requested, the contractor's invoices.

• Provide office support and technical assistance when necessary.

• Provide inputs to the weekly status report (Appendix A).

• Conduct a prefinat inspection in order to prepare a list of items remainingto be completed prior to the final inspection.

• Schedule and attend the final inspection in order to review the completion

of the project with state and federal personnel.

• Close out the inspection process by

- Complete as-built drawings- Document final quantities- Review final invoice and suggest any required adjustments- Finalize documentation

Task 21.0 - Final Report . . . . . . . .

NUS will be prepared to assist MONR in the preparation of covering all IRMactivities. The final rtport could contain the following information:

• Background and chronology of events

• As-built drawings to indicate the dimensions and configurations of the

construction process

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• Copies and documentation supporting the contractors invoices and anyrequest for extras

• Summary of the effectiveness of the remedial measures based onobservations obtained during the construction process

• Daily field logs in Appendix form

Task 22.0 - Additional Requirements

Project personnel will be prepared to assist the MDNR in preparation of thefollowing.

• Progress Reports - NUS normally prepares periodic progress reports as afunction of the inspection process.

• Budget Reports - Monthly budgets could be prepared in order to provide astatus on the rate of expenditures and the remaining amount of the IRMcontractors budget.

Task 23.0 - Community Relations

A Community Relations Plan will be developed prior to beginning any remedialactions at the site. The primary role of NUS in this program could be one ofsupport for the planned activities conducted by the State of Michigan. NUSpersonnel will not represent the State of Michigan or take the lead in CommunityRelations. However, NUS can provide logistical support for the planning andexecution of the activities and technical support.

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4.0 PROJECT MANAGEMENT AND PERSONNEL

The services defined in Section 3.0 will be performed through the NUS MichiganRegional Office located in Grand Rapids Michigan. This office, located in thesame facility as EDI Engineering and Science, NUS' Principal Subcontractor, willdirect all project management, technical, and administrative functions for theSpielgelberg and Rasmussen Sites RI/FS and IRM. Support personnel from NUS

Pittsburgh Office will be used to supplement the project team.

4.1 Project Organization and Personnel

Figure 4-1 depicts the overall project organization and personnel for this project.Technical areas where personnel are not listed will be staffed when the projectstarting date is established.

Mr. George 0. Gardner, will serve as Project Manager for the Spiegelberg andRasmussen Sites (Figure 4-1). Mr. Gardner will be assisted in day-to-day

management and coordination activities by an assistant project manager.Mr. E. Dennis Escher, Vice President and General Manager of the NUS PECDivision; Dr. Douglas A. Wallace, President of EDI Engineering and Science; andDr. Raul A. Deju, NUS PEC Division Director of Science and Engineering will serveas members of the Senior Technical Review Committee. Administrative supportwill be provided by Mr. Gerard A. Sgro, NUS' Michigan Regional Office Manager.Senior technical guidance in the areas of Health and Safety, Community Relationsand Quality Assurance will be provided by Messrs Gary F. Smith, Gilbert J. Meyer,

and Earl L Denner, respectively.

Reporting to Mr. Gardner will be Dr. Jeffrey C. Sutherland, Manager of RemedialInvestigation?; Mr. William D. Trimbath. Manager of Feasibility Studies and InitialRemedial Measure; Mr. Richard W. McCracken, Quality Control and Validation; and

Dr. Joseph Bern and R. R. Rediske, Public Health & Safety and EnvironmentalAssessments. NUS Analytical Laboratory and Computer Operations services will

be available, if required, to support assignment activities.

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FIGURE 4-1

PROJECT ORGANIZATION AND PERSONNELSPIEGELSERG AND RASMUSSEN SITES

ADMINISTRATIVE SUPPORTG. A. Sgro

HEALTH & SAFETYG. F. Smith

COMMUNITY RELATIONSG. J. Meyer

QUAUTY ASSURANCEE. Denner

PROJECT MANAGERG. 0. Gardner

ASSISTANTJ. D. Frost

REMEDIAL INVESTIGATIONSJ.C. Sutherland

SITE OPS. & HEALTH & SAFETYR.H.ConleyJ. W. Harris

M.ShahH. Roffman

SOILSS. J. Young

GEOPHYSICSM. LucasP. Jones

GEOLOGY & HYDROGEOLOGY0. E. Swan sonT. A. Uetzke

0. S. OoorenbosJ. RutherfordG. $ch o I tenR. Johnson

Sterns Drilling Co.C. S. RaymerCo.

MAPPING 8. SURVEYINGA. L M«y«r

A. D. CatlinAbrams Aerial Co.

CHEMISTRYA. j. Olutwski0. E KriscunaiS. J. Livihgston

AIR INVESTIGATIONSR.P. Andes

D.F. SandersP. Bird

NUS ANALYTICAL LABORATORYA. R. Kupiec

SENIOR TECHNICALREVIEW COMMITTEE

E. 0. EscherD. A. Wallace

FEASIBILITY STUDY ANDINTTT1AL REMEDIAL MEASURE

W. D. Trimbath

CONCEPTUAL ENGINEERINGR. 6. Tarbert

T. L O'KeefeSPECIFICATIONS

J. E. LawrenceT. J. Rilcy

COST ESTIMATINGA. M. Finke

DESIGN ENGINEERINGP. C Falvey

M. J. DowiakDRAFTINGK. P. Kibler

QUAUTY CONTROL & VALIDATIONR. W. McCraocen

PUBLIC HEALTH & SAFETY ANDENVIRONMENTAL ASSESSMENTS

J. BernR. R. Rediske

R.W. Phillips,D. Tuck

NUS COMPUTER OPERATIONSM. C. Runatz

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4.1.1 Interface Requirements and Lines of Communication

All lines of communication, management activities and technical direction withinthe NUS/EDI assignment team will follow the organization and arrangementidentified on Figure 4-1.

4.1.2 Field Operations

All field operation activities, including sampling coordination, subcontractorscheduling, site access, worker health and safety, equipment storage, samplechain-of-custody, and sample shipment will be coordinated through the NUSpersonnel onsite. Access to the site will require advance scheduling to assure

compatibility with other site activities. Daily Field Logs (Appendix A, AttachmentNo. 1} will be maintained by the Site Operations Manager. These logs wilt beincorporated by the Project Manager into the Weekly Report Summaries providedto the MDNR Project Administrator.

4.2 Project Management Reports

Weekly progress summary and monthly progress reports will be prepared by theProject manager for submittal to the MDNR Project Administrator. The weekly

progress summary will contain the following elements:

1. Work Accomplished

2. Problems Encountered and Resolution

3. Work Projected

4. Anticipated Problems and Solution Options

5. Significant Deviations from the Work Plan

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6. Manpower and Estimated Other Direct Costs, Reporting Period and ProjectedWork for the Following Week.

7. General Comments

8. Attachments:

• Daily Field Logs

• Explanation

• Weekly Time Logs

The progress summaries will be neatly handwritten on a standard form, a copy ofwhich is provided in Appendix A.

Monthly progress reports will include a compendium of the weekly summaries inregard to items 1, 2, 4, 5, and 7; a work projection based upon the entire followingmonth; and a detailed financial accounting of the report period and projection forthe following period. This accounting would be by major study plan task item andwill include a breakdown by labor and other direct cost item.

4.3 Contract Lab Program Coordination

Contract Lab Program (CLP) Coordination will be completed between the ProjectManager (MONR) and the Sample Management Office. The availability ofsufficient laboratory openings, compatible with the project schedule, is not knownat this time. In accordance with the requests of MONR, NUS is prepared tocomplete analytical analyses support services for this assignment in the event that

laboratory space is not availabit through CLP. Costs for these support services arenot included in this work plan.

4.4 Document Control and Management

All data, documents, and information concerning the Spiegelberg and RasmussenSites assignment will be considered confidential and will not be released to anyone

outside of the NUS/EDI or MDNR/U.S. EPA project teams without the written

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authorization of the MDNR Project and/or Contract Administrators. Alldocuments and data will be indexed and assigned a file category number. A recordof recipients will be maintained. A copy of a standard distribution form andpreliminary data management and document index for the assignment is provided inAppendix 8. The index will be updated on an as-needed-basis, with copies beingprovided to all users. Duplicate copies of the file will be maintained in both theNUS facilities and at MDNR.

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5.0 MANPOWER REQUIREMENTS AND SCHEDULE

5.1 Manpower Requirements

The estimated manpower requirements for completion of the Spiegelberg andRasmussen Sites assignment is provided in Table 5-1. The manpower requirementestimates are based upon the condition that both site assignments will be

completed simultaneously. Manpower requirements efficiencies have been includedaccordingly.

5.2 Schedule

The estimated schedule for the RI/FS and IRM is presented in Figure 5-1.Successful completion of the schedule will require expedient turnaround time forreviews and approvals of appropriate tests; and the approval using field screeningof samples with a gas chromatograph (GC), and other screening techniques to planthe field activities. The Quality Assurance Project Plan will contain the proposedscreening techniques required for this investigation.

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TABLE 5-1

PROJECT MANHOURS

TotalTask Description______________ Hours

REMEDIAL INVESTIGATION

1 INITIAL ACTIVITIES1.1 WORK PLAN PREPARATION 1 , 1561.2 DESCRIPTION OF CURRENT SITUATION 1461.3 PROJECT MANAGEMENT 1,3812 PRE-INVESTIGATION SUPPORT ACTIVITIES2.1 TOPOGRAPHIC MAPPING AND SURVEYING 4942.2 HEALTH AND SAFETY, GENERAL

SITE RECONNAISSANCE 1352.3 SITE HEALTH AND SAFETY PLAN 602.4 QUALITY ASSURANCE/QUALITY CONTROL PLANS 02.5 SITE OPERATIONS PLAN 842.6 MOBILIZATION OF FIELD EQUIPMENT 1362.7 SUBCONTRACTOR MANAGEMENT (Performed as part of 0

Project Management)2.8 PRELIMINARY IDENTIFICATION OF

REMEDIAL TECHNOLOGIES 883 SITE INVESTIGATION3.1 AIR QUALITY ANALYSIS 1843.2 GEOPHYSICAL INVESTIGATION 5303.3 HYDROGEOLOGICAL INVESTIGATION 9903.4 ENVIRONMENTAL SAMPLING AND ANALYSIS 5213.5 FIELD MONITORING 2,3044 SITE DATA EVALUATION4.1 DATA REDUCTION AND EVALUATION 8304.2 PUBLIC HEALTH AND ENVIRONMENTAL

RISK ASSESSMENT . . . . . . _ 5465 REMEDIAL INVESTIGATION REPORT 1,138

SUBTOTAL 10,723

FEASIBILITY STUDY

6 CURRENT SITUATION/SCOPE REFINEMENT 807 DEVELOPMENT OF ALTERNATIVES 1508 INITIAL SCREENING OF ALTERNATIVES 1709 LABORATORY STUDIES WORK PLAN 160

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TABLE 5-1PROJECT MANHOURSPAGE TWO

Total_____________Task Description_____________ Hours

FEASIBILITY STUDY (Continued)

10 DETAILED EVALUATION OF ALTERNATIVES 49011 SELECTION OF ALTERNATIVE 8012 CONCEPTUAL DESIGN 37013 FEASIBILITY STUDY REPORT 34014 ADDITIONAL REQUIREMENTS 015 COMMUNITY RELATIONS 24016 PHASE II COOPERATIVE AGREEMENT ____0

SUBTOTAL 2,080

GRAND TOTAL 12.898

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FIGURE 5-1 PROJECT SCHEDULEMum

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APPENDICES

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APPENDIX A

WEEKLY PROGRESS SUMMARY

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WEEKLY PROGRESS SUMMARYNUS CORPORATION

CONTRACT NUMBER 1611

(Project Name)_______ MDNR PO NO.

._________________ NUS PROJECT NO.

(Reporting Period)

1. Work Accomplished

Field (Attachment No. 1)

Lab

Office

2. Problems Encountered and Resolution

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3. Projected Work Next Week

Field

Lab

Office

4. Anticipated Problems & Resolution Potions

5. Significant Deviations from Work Plan (Attachment No. 2)

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6. Manpower and Estimated Other Direct Costs

ProfessionalLevel

• P 4P3P2PIT2Tl

Secretarial

Totals

Approximate HoursH)This Period

(Attachment No. 3)Projected Hourst1)

Next Week

Estimated Major Other Direct Costs:

• Travel and Living• Equipment• Lower Tier Subcontractors• Other

Total

Approx. CostThis Period

Approx. CostNext Week

7. General Comments

(Project Manager)

(Date)

FOOTNOTE:

1. Includes NUS and EDI labor hours. Also includes lower tier subcontractors ifwork is to be performed on other than a fixed price basis.

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ATTACHMENT NO. 1

DAILY FIELD LOGS

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DAILY FIELD LOGMICHIGAN STATE-WIDE RI/FS PROGRAM

CONTRACT NUMBER 1611

________(Project Name)________ MDNR PO NO.

NUS PROJECT NO.

(Date)

1. Personnel and Subcontractors On Site

2. Visitors {Name/Affiliation/Nature)

3. General Conditions (Wt«th«r, «tc.

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4. Work Accomplished

5. Samples Collected and Deposition

6. Problems Encountered and Resolution

7. Major Anticipated Problems Requiring Modification of Work Plan

8. Field Data Transmitted

Item(s)_____ _____Means____ ____To

(Signature)Site Manager

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ATTACHMENT NO. 2

SIGNIFICANT DEVIATIONS FROM WORK PLAN EXPLANATIONS

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ATTACHMENT NO. 3

WEEKLY TIME LOGS

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WEEKLY LOG SHEET

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APPENDIX B

DOCUMENT CONTROL AND MANAGEMENT

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MICHIGANSTATE-WIDE RI/FS CONTRACT

DISTRIBUTION FORM

FILE NO.:

DATE:

SUBJECT:

Location

NUS

EDI

MDNR

OTHER

DISTRIBUTION

Namefs) MeansO)

Sender:

1. Means: FE (Federal Express),X (In Person) andM (Postal Service Mail).

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INDEX

DATE:REVISION: 00

PURCHASE ORDER NO. 1 (SPIEGELBERG/RASMUSSEN'S RI/FS)

FILE INDEX

LOGS 2.0

CORRESPONDENCE

COMMUNICATIONS

STUDY PLAN

REQUEST

BACKGROUND INFORMATION

SITE RECONNAISANCE

STUDY PLAN

PURCHASE ORDER

BASE

MOD 01

(NUS ACCOUNT NO.

1.0

2.1

2.2

3.0

3.1

3.2

3.3

3.4

4.0

4.1

4.2

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DATE:REVISION: 00

PROJECT MANAGEMENT 5.0

PERSONNEL AND CONTACT DIRECTORY 5.1

EQUIPMENT AND FACILITIES 5.2

REPORTS 5.3

WEEKLY 5.3.1

MONTHLY . 5.3.2

MEETINGS 5.4

FINANCIAL 5.5

PROJECT AND TASK NO. AUTHORIZATION 5.5.1

BUDGETS 5.5.2

WEEKLY LOGS 5.5.3

PRINT OUTS 5.5.4

SCHEDULE AND LOGISTICS . 5.6

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DATE:REVISION: 00

TECHNICAL DATA 57

LOCATION/MAPS/REGIONAL SETTING 5.7.1

PUBLIC HEALTH AND SAFETY 5.7.2

COMMUNITY RELATIONS 5.7.3

IRM 5.7.4

REMEDIAL INVESTIGATIONS 5.7.5

GEOLOGY AND HYDROGEOLOGY 5.7.5.1

GEOPHYSICS 5.7.5.2

MAPPING AND SURVEYING 5.7.5.3

AERIAL 5.7.5.3.1

GROUND 5.7.5.3.2

CHEMISTRY 5.7.5.4

WATER 5.7.5.4.1

SOLIDS 5.7.5.4.2

AIR " 5.7.5.4.3

WASTES 5.7.5.4.4

ENVIRONMENTAL ASSESSMENT 5.7.5.5

FEASIBILITY STUDY 5.7.6

ALTERNATIVE REMEDIAL ACTIONS 5.7.6.1

FEASIBILITY EVALUATIONS 5.7.6.2

CONCEPTUAL DESIGN 5.7.6.3

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DATE:REVISION: 00

TECHNICAL REPORTS 5.77

Rl 5.7.7.1

FS 5.7.7.2

IRM 577.3

SPECIAL 577.3

SUPPORT PROGRAMS 5.8

QUALITY ASSURANCE/CONTROL 5.8.1

HEALTH AND SAFETY 5.8.2

COMMUNITY RELATIONS 5.8.3

INITIAL REMEDIAL MEASURES 5.9

SITE INVESTIGATION 5.9.1

FOCUSED FEASIBILITY STUDY 5.9.2

DESIGN AND SPECIFICATIONS 5.9.3

ADDITIONAL SUPPORT ACTIVITIES 5.9.4

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TABLE B-1

MANPOWER REQUIREMENTS - RASMUSSEN SITE

____________________________Project Month____________________________Task 1 2 3 4 Total

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Table 8-1

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,r

TABLE B-2

MANPOWER REQUIREMENTS - SPIEGELBERG SITE

____________________________Project Month_____________Task _J_ 2 3 4 Total:

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Table B-2

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TABLE B-3

MANPOWER REQUIREMENTS - SPEIGELBERG AND RASMUSSEN SITES

______t______________________Project Month____________________________Task 1 2 3 4 Totals

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Table B-3

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