EPA WORK ASSIGNMENT NUMBER 179-2L24 EPA CONTRACT NUMBER 68-01-7250 EBASCO SERVICES INCORPORATED I FINAL WORK PLAN REMEDIAL INVESTIGATION AND FEASIBILITY STUDY NIAGARA COUNTY REFUSE SITE WHEATFIELD, NEW YORK MARCH 1988 NOTICE The information in this document has been funded by the United States Environmental Protection Agency (USEPA) under REM III Contract NO. 68-01-7250 to Ebasco Services Inc. (Ebasco). This document has been formally released by Ebasco to the USEPA. However, this document does not represent the USEPA position or policy, and has not been formally released by USEPA.
Transcript
EPA WORK ASSIGNMENT NUMBER 179-2L24EPA CONTRACT NUMBER 68-01-7250EBASCO SERVICES INCORPORATED
I
FINAL WORK PLAN
REMEDIAL INVESTIGATIONAND
FEASIBILITY STUDYNIAGARA COUNTY REFUSE SITE
WHEATFIELD, NEW YORK
MARCH 1988
NOTICE
The information in this document has been funded by the UnitedStates Environmental Protection Agency (USEPA) under REM IIIContract NO. 68-01-7250 to Ebasco Services Inc. (Ebasco). Thisdocument has been formally released by Ebasco to the USEPA.However, this document does not represent the USEPA position orpolicy, and has not been formally released by USEPA.
Mr M Shaheer Alvi, PERegional Project OfficerUS Environmental Protection Agency26 Federal PlazaNew York, New York 10278
Mr Joel SchlagelRemedial Project ManagerUS Environmental Protection Agency26 Federal PlazaNew York, New York 10278
SUBJECT: FINAL WORK PLAN (RI/FS)NIAGARA COUNTY REFUSE SITENIAGARA COUNTY, NEW YORKWORK ASSIGNMENT NUMBER: 179-2L24EPA CONTRACT NUMBER: 68-01-7250
Gentlemen:
Ebasco Services Incorporated (Ebasco) is pleased to submit thesubject Work Plan. The draft Work Plan has been revised toincorporate all the comments raised in Mr Joel Schlagel's letterreceived by Ebasco on February 17, 1988. The Draft Work Planhas also been revised to include the final decisions mutuallyagreed to during the meeting held at your New York office onFebruary 23, 1988. The revisions are separately detailed in aletter to Mr Joel Schlagel answering each comment or questionraised during the EPA review process and the subsequent meetingheld on February 23, 1988. This letter also indicates thelocation of revision in the final Work Plan to facilitate yourreview process.
The Work Plan presents Ebasco's technical scope, estimated cost,and schedule for field activities and preparing a RemedialInvestigation/Feasibility Study (RI/FS) Report for the NiagaraCounty Refuse site. The Work Plan also presents Ebasco'sunderstanding of the problem at the site and the rationale forour technical approach. It has been determined that no conflictof interest exists for the Regional or Site Manager, nor isthere an organizational conflict of interest for Ebasco.
The Work Plan assumes that the Community Relations Plan will befinalized by Ebasco but further Community Relations will behandled directly by EPA on this project. This is in accordancewith the oral directive by EPA to Ebasco. We have provided,however, a nominal level of effort for any future contingencywork related to community relations. This budgeted amount willnot be spent without permission from EPA.
300R20
-2-
March 2, 1988RMOII-88-065
Mr M Shaheer Alvi, PEMr Joel Schlagel
SUBJECT: FINAL WORK PLAN (RI/FS)NIAGARA COUNTY REFUSE SITENIAGARA COUNTY, NEW YORKWORK ASSIGNMENT NUMBER: 179-2L24EPA CONTRACT NUMBER: 68-01-7250
The Optional Forms 60 for Ebasco and its subcontractors areenclosed under separate cover.
Please let us know if we can be of assistance during yourreview. If you have any questions or comments regarding theFinal Work Plan or this letter, please do not hesitate to callme at (201) 460-6434 or Kris Ramachandra at (212) 839-1471.
Very truly yours,CD-ev/ /I. S»dJ-e<j
Dev R Sachdev, PhD, PERegional Manager-Region II
cc: D Sarno EPAM K YatesM AmdurerK Ramachandra
EPA WORK ASSIGNMENT NUMBER 179-2L24EPA CONTRACT NUMBER 68-01-7250EBASCO SERVICES INCORPORATED
Ebasco Services Incorporated (Ebasco) is submitting this Work Planto the U.S. Environmental Protection Agency (EPA) in response toEPA Work Assignment Number 179-2L24 dated Sept. 13, 1987 underContract Number 68-01-7250. Preparation of this Work Plan wasaccomplished pursuant to Ebasco's Work Plan Memorandum datedOctober 14, 1987.
This Work Plan presents Ebasco's technical scope of work as well asan estimated level of effort and schedule for performing a RemedialInvestigation and Feasibility Study (RI/FS) for the Niagara CountyRefuse Site (NCR Site), located in the town of Wheatfield, NiagaraCounty, New York.
1.1 PROJECT APPROACH
The remedial investigation and feasibility study (RI/FS) projectapproach is presented in the following paragraphs. The remedialinvestigations will be performed in one phase (Phase I) with anoptional and out of scope second phase (Phase II) whereas thefeasibility study will be a continuously evolving process which canbe broken into three tasks. This approach is in conformance withthe June 1985, EPA guidance on remedial investigations underCERCLA.
The objectives of the Phase I RI are:
(a) to define the nature and extent of contamination by
- collection and study of the existing data base for the site
- field investigations to fill the data gaps in the existingdata base
- sampling and testing of the surface sediment and water, groundwater and leachate from the landfill
- analysis of the field and laboratory data to delineate thenature and extent of the contamination;
(b) to refine Data Quality Objectives (DQO's);
(c) to assess the need for groundwater treatability studies and toascertain its feasibility as a remedial action; and
(d) to assess need for groundwater modeling.
The existing data base for the Niagara County Refuse Site hassignificant data gaps, which are discussed in Paragraph 2.3 - PriorData. Additional data will be collected from the federal and stateagencies as it becomes available during the RI activities.
The field investigations at the NCR site will consist of:
- topographical surveys to allow determination of existingdrainage characteristics and to locate new and existingboreholes and monitoring wells;
- electromagnetic and resistivity surveys outside the landfillarea to define any contaminant plume;
- soil-gas surveys (requirement subjected to the results of theelectromagnetic surveys) to facilitate the planning ofboreholes and monitoring wells, and help in identification ofthe location of industrial wastes;
- installation of weirs or flumes to allow measurement ofsurface water flow from the drainage ditches which exist atthe site;
- completion of two test pits adjacent to the site to examinepotential pathways for contaminant migration;
- boreholes and monitoring wells to define the soil and bedrockstratigraphy, and suspected industrial cell characteristics;
- sampling and analysis of subsurface soils and groundwater, sothat the nature and extent of contamination can be accuratelyassessed;
- water level monitoring and permeability testing of new andexisting monitoring wells to allow the geohydrologic regime tobe more clearly defined;
- hand auger boreholes to collect near surface samples inanomalous areas identified during the geophysical and soil-gassurvey program;
- air sampling to allow risks associated with airbornecontaminants (if any) to be assessed;
- surface water and sediment sampling to determine the potentialfor contaminant migration through drainage ditches present atthe site; and
- a reconnaissance inventory of terrestrial biota to allow anenvironmental assessment to be completed.
Surface water, sediment, leachate, air, subsurface soil andgroundwater samples will be collected during the Phase I fieldinvestigations program. Samples will be screened on-site using afield gas chromatograph to select samples (through head-spaceanalysis) to be sent to the laboratory for detailed analysis andvalidation.
Concurrently with the laboratory testing, analysis of the fielddata will be initiated to determine the need for Phase II remedialinvestigations (additional on-site or off-site fieldinvestigations). Groundwater modeling and treatability studies willbe considered as optional items and part of the Phase I RIactivity.
Phase I RI activity will not emphasize source characterization ofthe wastes as the amount and type of wastes are large andheterogeneous. Available records will be examined in detail tocharacterize the source to the extent possible. Groundwatersamples from the existing wells which are still operable within thelandfill area will be collected, analyzed, and correlated to thedata from additional monitoring well(s).
The initial data quality objective based on available site-specificinformation has been determined to be level IV to ensure thatenvironmental, health effects and treatability data will be ofadequate quality and appropriate for their intended uses. DuringRI Phase I, further evaluation of the initial DQO will be performedto identify data use, type, quality and quantity. DQO's will berefined as necessary to ensure that foreseeable needs forenvironmental, health effects and treatability data will be met.
In Phase I of the RI, the groundwater flow direction andgeohydrological characteristics will be determined and theprincipal contaminants (TCL's) will be identified. A computerizedgroundwater simulation model will be used, if necessary, toestimate the potential movement of the groundwater contaminationplume. Groundwater modeling is an optional item whose need will bedetermined during the RI Phase I study. The modeling will aid inthe selection of monitoring well depths and locations in RI PhaseII. It is also the intent of the modeling effort to establish ifdowngradient contamination originated from the site. It isnecessary to identify indicator compounds and determine the localgroundwater flow patterns to differentiate the site's contaminantcontribution from other potential sources of contamination in thearea (see Section 2-4 for details of other hazardous waste disposalareas near the NCR site). Since the NCR site is a large landfill,it is quite probable that the focus for treatability studies willbe on groundwater rather than soil treatment.
An optional and out of scope Phase II RI effort may be required tocollect additional data to perform the site FS. These additionaldata include further field investigations (on-site and/or off-site)as necessary to refine the general site characterization.
The Work Plan (WP) presented has budget provisions for thegroundwater modeling activity and bench scale treatability studiesof water. Both these activities are considered optional itemswhose need will be determined as RI Phase I progresses. No budgetprovision has been made for treatability studies of soil in this
work plan as this study is not foreseen at this stage. No budgetprovision has been made for RI Phase II field investigations as thecost of this work cannot not be estimated at this time
The FS activity will consist of development of remedialalternatives and will begin concurrently with, or slightly behind,the RI Phase I. Initial screening of the alternatives will then beperformed as an input to the RI Phase II process. A detailedanalysis of the screened alternatives will be performed as a nexttask to include the assessment of short- and long-term effects(effectiveness, implementability, technical and administrativefeasibility, costs). The relative strengths and weaknesses ofremedial options will be compared during this stage and suitablerecommendations made.
1.2 PROJECT PLANNING
This RI/FS Work Plan was prepared based upon review andconsideration of the data, information, and documents obtainedthrough the following activities:
o A project kick-off meeting was held on September 28, 1987, atthe EPA Region II Office. Project background information,including the Remedial Action Master Plan, prepared by NUSCorporation (1983), the site operations plan prepared by theTown of Wheatfield, and a site investigation report preparedby a developer to the northwest of the landfill, were obtainedat this meeting.
o A site visit was conducted on October 1, 1987, to inspect andconfirm existing site conditions and the surroundingenvironment.
o On December 4, 1987, a scoping meeting was held with EPARegion II staff and staff of the New York State Department ofEnvironmental Conservation (DEC). In that meeting, the Ebascoproject team presented their concepts, approach and scope forthe RI/FS. Comments from the EPA and NYSDEC have beenincorporated in this Work Plan.
In addition to these activities, a site reconnaissance visit willbe made to identify potential locations for installation of streamflow gauges (weirs), measure water levels in existing wells anddetermine well depths, and to visit local county and state agencieswhich may have additional data pertinent to the site. The sitereconnaissance visit will be scheduled as the initial task of RIPhase I.
The Work Plan was prepared in accordance with the followingguidance documents:
o The June 1985 EPA Guidance on Remedial Investigation underCERCLA,
300*30
o The June 1985 EPA Guidance on Feasibility Studies underCERCLA,
o The "Superfund Amendments and Reauthorization Act" (SARA)requirements (particularly those related to remedialalternatives and ARAR's),
o J.W. Porter's December 1986 and July 1987 memoranda on"Interim Guidance on Superfund Selection of Remedy" and
o The March 1987 EPA Guidance on Data Quality Objectives for theRI/FS Process.
Ebasco's Work Plan contains six sections in addition to thisintroduction. Specifically, Section 2.0 summarizes the existingdata on the site; Section 3.0 describes Ebasco's scoping processfor the planned RI/FS; Section 4.0 presents details of Ebasco's RItasks for the on-site investigation; Section 5.0 presents Ebasco'sFS tasks for remediation of the site; Section 6.0 discusses thecommunity relations task plan for the site; and Section 7.0summarizes Ebasco's project management approach, including Level ofEffort (LOE) and Other Direct Cost (ODC) estimates and a projectschedule. The LOE and ODC estimates and target schedule have beenprovided for all activities up to the completion of the RI/FS forthe site. However, the LOE and ODC's for the groundwater modelingeffort and treatability studies are preliminary and will befinalized following availability of requisite information during RIPhase I study. The RI Phase II field investigations may or may notbe required and is dependent on the results of the RI Phase Istudy. As such no budget provisions for RI Phase II activity(other than a preliminary estimate of groundwater treatabilitystudies) are included in the work plan.
2.0 SUMMARY OF EXISTING DATA
This section summarizes published literature acquired by Ebasco andpertinent data from the project files of EPA, New York StateDepartment of Environmental Conservation (NYSDEC), and the UnitedStates Geological Survey (USGS). Additional data will be collectedduring the initiation of RI activities and are not expected to haveany significant impact on the RI/FS approach proposed in this WorkPlan.
2.1 SITE LOCATION, SITE HISTORY AND CURRENT CONDITIONS
2.1.1 Site Location
The Niagara County Refuse Disposal Site occupies approximately 50acres in the Town of Wheatfield, New York. The site is locatedabout 3 miles upstream of the drinking water intake on the NiagaraRiver for the City of Niagara Falls. Nearby hazardous wastes sitesare described in section 2.4. Figure 2-1 shows the location of theNCR site.
The site is bounded by residences approximately 500 feet to theeast along Witmer Road, wetlands to the north, agricultural area tothe west, and Conrail tracks and River Road (Route 265/384) to thesouth, as shown in Figure 2-2. The Niagara River flows generallyeast to west a short distance to the south of the site, and isconnected to the site by an underground culvert (30-inch diameter)which runs from the southern end of the site's main drainage ditchinto the river. Topographically, the area surrounding the landfillis flat, and access to all areas of the site is easy.
The site is drained by ditches which carry runoff south to theNiagara River or north to Black Creek. The ponded marshy wetlandswhich lie directly north of the site form the headwaters of BlackCreek, which flows just north of the Love Canal region andeventually into the Niagara River.
2.1.2 Site History
The site received industrial solid and chemical wastes, much oflargely unknown composition, from 1969 to 1976. The site was ownedand operated by Niagara County Refuse Disposal District untilOctober 1976, when it was officially closed, exposed refuse wascovered with about 20 inches of dirt and clay, and it was graded.The Town of Wheatfield then acquired it, and the site wasidentified as potentially hazardous in March 1979. Table 2-1presents a list of hazardous and potentially hazardous materialsreported to have been disposed of at the site and the partiesreported to have disposed of each. Table 2-1 is not exhaustive andmay not be fully representative of all the industrial wastes at theNCR site.
9) Others Residue from Niagara FallsIncinerator on west side.Miscellaneous trash fromRoblin Steel Co.
Source: "Remedial Action Master Plan" by Camp Dresser McKee Inc.and Others, January 5, 1983.
Notes:
a) The above table indicates the characterization of the suspectedwastes that have been disposed at the site from availablerecords and may not be fully exhaustive and representative ofthe conditions at the site.
b) Over 100 generators disposed their wastes at the site.c) Over 12,000 tons has been classified as hazardous (source:
"Community Right to Know" by NYDEC, April 1, 1985).d) Total estimated wastes in landfill - 0.75 to 1 million tons.e) Approximate waste composition by weight based on 1972
Source: "Operation Plan for Site" by Krehbiel-Guay-Rugg-Hall,October 5, 1973.
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2.1.3 Current Conditions
The site is not fenced and is easily accessible. There are nosigns posted indicating that the site is hazardous and to prohibitentry to the site. As a result, local residents use the site forrecreational purposes (e.g. dirt bikes, snow mobiles, targetshooting). The landfill cover is eroded in several places, causingwastes to be exposed in some northern areas. The potential existsfor the large scale release of hazardous substances as thedeterioration of the soil cap continues. Vegetative stress (e.g.dead trees) is visible in some areas north of the site, whichappear to be receiving runoff from the site.
Excavation activities are currently being conducted approximately2000 feet to the northwest of the site, where lakes are beingcreated as part of the planned Summit Park Development. No housinghas begun as of January, 1988. Figure 2-3 shows the location ofthe Summit Park Development area relative to the Niagara CountyRefuse site. The Summit Park Development is expected to haveimpact on the NCR site as the runoff from this development will bedischarged through the existing 30-inch diameter culvert on thewest side of the site, this impact will be assessed as part of theRI/FS proposed in this work plan.
2.2 SITE DESCRIPTION
2.2.1 Site Stratigraphy and Hydrogeology
Subsurface drilling and sampling programs have been conductedduring various investigative programs conducted at the site. Theseinclude borings completed by the USGS, NUS Corp., and EA Scienceand Technology (EAST) and are listed as follows:
April 1973
July & December 1979
September 1980
March 1981
June 1981
1982
Niagara County Health Department - samplingand testing of leachate and surface water.Samples were analyzed by NYS Department ofHealth in June 1973.
RECRA Reseach performed some sampling andanalyses for the City of North Tonawanda.
Leachate and sediment samples were taken andtested by the USEPA Region II SourceMonitoring program.
Surface water, sediment and soil samplestaken and tested by Fred C. Hart Associatesfor USEPA Region II.
Surface water and sediment samples weretaken and tested by NYDEC.
Ten boreholes were drilled, samples taken
11
and tested by USGS. Monitoring wells wereinstalled in two of the boreholes.
1980, 1981, 1983 : Sediment, surface and groundwater sampleswere collected and tested by NUS Corporationfor USEPA. In 1983 NUS intalled fivemonitoring wells.
November 1985, 1987 : EAST installed four monitoring wells withinthe landfill for NYDEC. Samples werecollected and tested.
Monitoring wells are reported to have been installed in eleven ofthe completed soil borings, however no comprehensive evaluation ofgroundwater flow in either the overburden or bedrock units has beencompleted, nor can it be completed solely through testing of theexisting wells, even if all reported wells are found to be in goodcondition. Permeability data for various stratigraphic unitspresent at the site are not available, and chemical analyses ofsubsurface soil samples have not been completed.
Figure 2-4 shows the approximate locations of all soil borings andmonitoring wells which were previously completed at the site.Table 2-2 presents a summary of the soil boring logs; logs are notavailable for all borings.
The site is underlain by a series of unconsol idated glacialdeposits which overlie Paleozoic sedimentary rock. A generalizedgeologic cross section is shown in Figure 2-5. Typically, a thinlayer (3 to 4 feet) of sandy loam lies at the top of the sequence.Within the uppermost foot, this layer contains abundant organicmatter. The sandy loam is underlain by lacustrine silts and clayswhich in places may overlie glacial till. The lateral continuityof individual units within the unconsol idated sequence is unknown.
In 1983, under the EPA FIT project, NUS Corporation installed fivebedrock monitoring wells around the perimeter of the site(locations shown in Figure 2-4) . The monitoring wells were drilled10 feet into bedrock. The depth to bedrock varied between 35 feetand 55 feet below the ground level. Bedrock was found to befractured in all five wells, and all were reported to have highrates of recharge.
In 1985, under a project for NYDEC, EAST installed four monitoringwells within the landfill area. Only one well was taken to the topof bedrock, which was encountered at a depth of 43.5 feet belowground level. The bedrock was identified as weathered shale. Thefill in the northern section of the landfill was identified as greyash, paper, oil, wire, plastic, grey solids, etc., resting directlyon bedrock. The other three boreholes indicated that the fillvaries in thickness from 15 to 39 feet, and rests on clay and till.The water levels in these wells varied between 7 feet and 23 feetbelow ground level and may indicate a perched or mounded water
12
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SUMMIT PARK DEVPROJECT AREA
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FIGURE 2-3
REM III PROGRAM
NIAGARA COUNTY REFUSE SITELAKES CURRENTLYUNDER EXCAVATION
Field activities will include a reconnaisance to identify previoussoil boring locations, and to document the condition of anymonitoring wells which may still be extant.
17
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table at different levels within the landfill.
Dips of individual rock units in the region are reported to be tothe south, at approximately 40 to 50 feet per mile. Bedrockbeneath the NCR site is suspected to be from the upper portion ofthe Lockport Formation, or lowermost Camillus Formation. Coredrilling at the Gratwick Riverside site, located a short distanceto the southeast (stratigraphically up-section), encountered theCamillus Formation. Core drilling at the Love Canal, 102nd St. and"S" Area sites to the west (approximately the same point in thestratigraphic section), encountered the Lockport Formation. Figure2-6 shows the location of these sites relative to the NCR site.
Regional hydrogeological investigations, and investigationsundertaken at nearby waste disposal sites indicate that groundwateris found in varying amounts in almost all formations underlying thearea. Groundwater flow in both the unconsolidated and bedrockunits is assumed to be to the south, toward the Niagara River.However, surface flow in the northern portion of the site isnorthward into the Black Creek drainage, and flow in any perchedzones in the shallow subsurface may also be toward the north inthis area. Bedding joints in the Lockport Formation, widened bysolution, may allow yields of 30 to 80 gpm. Well yield in theunconsolidated formations are reported to range from a few gpm inthe finer grained units to 100 gpm or more in coarser sandy zones.No site specific data on groundwater yields is available in theexisting data base.
2.2.2 Climate
Climatologic data for the Buffalo/Niagara Falls region was obtainedfrom the National Climatologic Center and published information onthe region. The reported mean annual precipitation in the regionis 37.52 inches. August is typically the wettest month (4.16inches) and February the driest (2.40 inches). The highestrecorded amount of precipitation for one month was 10.67 inches,and 4.94 inches was the greatest recorded for one day. On theaverage, the area will receive measurable precipitation (greaterthan 0.01 inches) on 169 days of the year. Snowfall averages 93.20inches annually with 68.40 inches being the maximum amount recordedin a single month. The mean annual evaporation in the area is 40inches (Class A pan). Therefore, on an average basis, the annualprecipitation is slightly lower than the annual evaporation. Thenormal annual temperature in the area is 47.6 degrees F. Thelowest and highest temperatures ever recorded are -20 and 99degrees F, respectively. Temperatures remain above freezing anaverage of 150 days per year. The predominant wind flow is fromthe west at 10 knots during the winter, and from the southwest at 9to 10 knots during the summer.
2.2.3 Population and Environmental Resources
Land surrounding the NCR site is generally low density housing
300*4620
NASH ROAD
GRATWICK - RIVERSIDE SITE
FIGURE 2-8
NIAGARA COUNTY REFUSE SITE
3000 8000=••
SCALE IN FEETOTHER HAZARDOUS
WASTE SITESIN THE VICINITY
fBASCO SERVICES INCORPORATED
300847
(east of the site, along Witmer Road, and in areas south of thesite), open fields (the majority of the western boundary of thesite), or wooded (the area north of the site and portions of thearea to the east).
The town of North Tonawanda is the closest population center to thesite, and lies approximately 1.5 miles east of the site. Totalpopulation of North Tonawanda, as reported by the town office, is36,000. The NCR site is located in the town of Wheatfield whichhas a population of 9,600.
Surface water from the Niagara River is the sole source of waterfor the entire population of the Town of Wheatfield. No private orpublic wells are known to be in use in the vicinity of the NCRsite.
2.3 PRIOR DATA
2.3.1 Groundwater
Five wells were installed on the perimeter of the landfill in 1983,and an additional four wells were installed within the landfill in1985. Two additional wells are reported to have been installed tothe east of the landfill in 1982. No water level data areavailable from any of the wells outside the landfill. The waterlevels of the four landfill wells are reported to vary between 7and 23 feet below the existing ground level (EAST, 1987). Three ofthese wells were identified during the site visit, however caps toeach of the wells were locked and measurements were not made.Permeability test data are not available from any of the wells.
2.3.2 Chemical Characterization of the Site
The Niagara County Refuse Site has been the focus of severalinvestigations by USEPA, NYSDEC and USGS since 1980. Theseinvestigations have centered on limited sampling of on-site soils,groundwater, drainage trench water and sediments, as well as someoff-site soil surface water and sediment sampling. Analyticalresults are conflicting, however, and quality control is lacking inseveral instances. Tables 2-3 and 2-4 present a summary of theexisting chemical data for the site and federal and state waterquality standards. A sampling history is as follows:
In 1973, the NYS Dept. of Health reported finding concentrations ofheavy metals in leachate discharging into the Niagara River and inthe river water 50 feet downstream of the discharge. A controlsample taken 50 feet upstream of the site contained significantconcentrations of inorganic contaminants.
In 1979 Recra Research completed seven monitoring wells in thevicinity of Gratwick Riverside Park, a short distance upstream ofthe discharge of the NCR site into the Niagara River. Data fromthis location are presently unavailable but are expected to become
22 300848
available during the Phase I RI activity, and will aid in thedefinition of potential pathways for groundwater migration near theNiagara River.
On September 9, 1980, USEPA Region II Source Monitoring Sectioncollected two water samples and five sediment samples from thedrainage ditches on the site and the discharge in to the NiagaraRiver. These analyses showed negligible surface watercontamination while the sediments showed high levels ofBis(2-ethylhexyl)phthalate (2.3 to 6.9 mg/kg) and polycyclicaromatic hydrocarbons (0.017 to 3.2 mg/kg) as well as low levels ofPCB's (0.08 to 0.32 mg/kg). Sediment samples were collected fromdrainage ditches at the site, the ponded marshy area along thenorthern edge of the fill, and from the end of the storm drain pipepassing under River Road and into the Niagara River. Samples aresaid to have been taken from areas with "good sediment deposition".
On March 18, 1981, Fred C. Hart Associates collected five surfacewater, three sediment samples and five soil samples in and aroundthe Niagara County Refuse site. These samples were analyzed forpriority pollutants. Surface water samples contained similarpollutants to samples taken in 1980 (phthalates, phenols, methylenechloride, and others). Soil samples contained phthalates, PAHs,PCBs, and other compounds. Also during 1981, Recra Researchcollected limited surface water samples at the site and found fewcontaminants except for high concentrations of phenol (34 mg/1).
In 1981, four sediment and four water samples taken from drainageditches by the NYSDEC were reported to contain copper, zinc,phenol, ethylbenzene, toluene, and heptachlor in the water samples.
In 1982, the USGS completed a series of ten boreholes and installedmonitoring wells in two of the boreholes. Most samples takenwithin the refuse area had elevated concentrations of organiccompounds, but most samples taken along the perimeter did not(USGS, 1982). Three priority pollutants were found in soil samplestaken along the southern drainage and in groundwater from a welllocated on the eastern margin.
In 1983, NUS Corporation evaluated data from five groundwater andnine soil and surface water samples collected from drainage ditchesat the NCR site and determined that no organic compounds werepresent in surface water samples with the exception of methylenechloride and no significantly elevated concentration of inorganicelements were detected. Methylene chloride was also found inseveral groundwater samples. However, this may have been anartifact due to field decontamination procedures. Bisphthalate wasdetected in one groundwater sample at 35 ug/1. NUS Corporationalso found endosulfan sulfate in one sediment sample at 268 ug/kg.No other organic compounds were detected. Inorganic elementconcentrations in sediment and groundwater were not significantlyabove the background.
23
Volatile Organics
BenzeneChlorobenzene1,2-Dichloroethane1,1,1-THchloroethaneChloroform1,2-Trans-DichloroethyleneEthyl benzeneMethyl ene ChlorideTri chlorof1oromethaneTetrachloroethyleneTolueneTri chl oroethyl eneVinyl ChloridePhenol
In 1985, EA Science and Technology sampled and tested liquids fromfour monitoring wells installed within the landfill area. Elevatedconcentrations of volatile organic compounds (toluene, benzene,4-methyl-2 pentanene, ethylbenzene, etc.) were detected. Elevatedconcentrations of semi-volatile organic compounds (phenols) werealso detected. Wells in the suspected industrial cell (northernportion of the landfill) exhibited higher organic concentrationlevels. Metal concentrations (arsenic, barium, chromium, iron,lead, manganese and zinc) above NYS quality standards for class GAgroundwater were also detected. Total cyanide was detected at lowlevels. Ignitable substances were found in some of the drumssampled by EAST. Three wells were resampled in 1987 and tested forPCB and pesticide analyses. Preliminary results indicated that nopesticides or PCBs were detected.
The existing data are sufficient to state that hazardous wastes areleaching from the site, however, they are insufficient (in terms ofthe number of tests performed and quality control) to: a) properlycharacterize the contaminants existing within the site; b) properlycharacterize the waste leaving the Niagara County Refuse site; c)characterize the quality of groundwater and surface water at thesite; and d) determine the need for remedial action.
2.4 OTHER HYDROGEOLOGICAL INVESTIGATIONS IN THEVICINITY OF THE SITE
The Niagara County Refuse Site lies in close proximity to severalother known hazardous waste disposal areas as shown in Figure 2-6.These include: Gratwick Riverside Park, located approximately 900feet southeast of the site; Love Canal and 102nd Street Landfill,both located approximately 2 miles west of the site; and the "S"Area Landfill, located approximately 3 miles west of the site.Available data regarding subsurface conditions and geohydrologicunits at these sites are summarized in the sections which follow.As additional data become available, they will be reviewed forrelevance to the NCR site, and, where appropriate, integrated intothe data base on site and regional conditions. None of these sitesexcept the Gratwick Riverside Park have any direct impact on theNCR site. The geologic and hydrologic conditions at some of theselocations may, however, be pertinent to the NCR site as theregional stratigraphy does not change significantly.
2.4.1 Gratwick Riverside Park
The Gratwick Riverside Park lies approximately 900 feet southeastof the NCR site, along the northern bank of the Niagara River. Aremedial investigation is currently underway at the site by theNYSDEC. Results of investigations will be reviewed as they becomeavailable. The data will be assessed to investigate whether thecontaminant plume (if any) from the NCR site is mixing with thecontaminants at the Gratwick Riverside Park before entering theNiagara River.
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2.4.2 102nd Street Landfill
The 102nd Street Landfill is located immediately southeast of theLove Canal site, along the northern edge of the Niagara River. Thesite is approximately 2 miles due west of the NCR site. The sitedrains to the Niagara River. The depth to bedrock near the site isapproximately 27 feet below the natural grade. Pertinent data willbe gathered and reviewed during the Phase I RI study to aid inunderstanding the geologic and hydrologic conditions at the NCRsite.
2.4.3 Love Canal
The Love Canal waste disposal site lies approximately two mileswest, or downstream of, the NCR site. Geologic units trendapproximately east-west in this area, thus geologic conditions atthe Love Canal site are likely to be similar to those at the NCRsite. Extensive geologic and hydrogeologic investigationsundertaken in the vicinity of Love Canal found 33 to 39 feet ofoverburden overlying dolomite of the Lockport Formation. Bedrockbeneath the site dips gently to the south, and lies at an elevationof 537 feet beneath the southern end of the site (GTC Consultants,1983).
Overburden consists of a series of silts, clays, and glacial till.Glacial till lies directly on bedrock at the base of theunconsolidated sequence. Five separate zones were identifiedwithin the Love Canal hydrogeologic regime. From uppermost tolowermost these are:
o Shallow System - fill, silty sand, and clayey silt;o Confining Layers - clay and till overlying the Lockport;o Upper Lockport - main aquifer located in the upper 10-15 feet
of the formation, principally horizontaljoints, also some vertical joints;
o Lower Lockport - lower part of formation (up to 165 ft thick)o Rochester Shale - underlies Lockport, largely unfractured
These units are the same as the identified or inferred geologicunits which underlie the NCR site. While hydraulic conductivitiesin all of the overburden units at Love Canal were found to berelatively low (GTC Consultants, 1983), higher than expectedrecharge rates in pumped wells located in fine grained units (claysand silty clays) suggest the presence of secondary permeability dueto fractures.
Groundwater flow directions in both the Lockport and the overburdenunits were found to be towards the south, with very gentlegradients. Piezometric levels in wells set in bedrock typicallywere observed to be slightly lower than those in overburden.
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2.4.4 "S" Area Landfill
The "S" Area landfill lies approximately one mile west of the LoveCanal site, adjacent to the Niagara River. Subsurface conditionsat the "S" area site are similar to those at Love Canal, and thosewhich are thought to exist at the NCR site. Bedrock beneath thesite is the Lockport Dolomite, which is overlain by a sequence oftill, clay, and man-made fill. Groundwater flow in theunconsolidated deposits is generally to the south, towards theNiagara River. Flow within bedrock was found to be to the north,away from the river. This reversal of flow direction is thought toresult from the proximity of the Niagara Gorge, which acts as agroundwater sink for the region.
2.5 DISCUSSION
Based on the existing data for the NCR site, the following geologicand hydrogeologic issues can be identified as critical toassessment of the risk and development of remedial alternatives forthe NCR site.
a) Surface Runoff
The NCR site generally drains toward the south (to Niagara River)and to some extent towards the north (to Black Creek) . Since thepresent cover of the landfill is inadequate and eroded in severalplaces, the surface runoff may be carrying some of the contaminantsfrom the landfill. It is therefore necessary to measure the volumeof surface runoff, so that remedial alternatives such as landfillcap requirement, optimum drainage and collection systems can beadequately evaluated.
b) Thickness and Permeability of the Unconsolidated Units
The previously completed subsurface investigations contain asignificant amount of pertinent data on conditions at the site.However, most of the previously completed borings were terminatedat depths of 15 feet or less below ground surface. Consequently,the composition and lateral continuity of soil materials at greaterdepths cannot be adequately evaluated from the existing data.There is also a lack of information regarding the permeability ofthe unconsolidated and bedrock units.
c) Direction and Rate of Groundwater Migration
No comprehensive evaluation of groundwater flow has been developedfor the NCR site. Assessment of the risks associated withcontaminant migration and evaluation of the effectiveness ofpotential remedial actions requires a thorough understanding ofgroundwater flow through both the unconsolidated and bedrock unitspresent beneath the site. Insufficient groundwater elevation dataare available for the unconsolidated units, and the interconnectionof flow paths through overburden and bedrock cannot presently beevaluated.
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d) Bedrock Geology
The depths to the bedrock appear to vary considerably within theNCR site. The top zone of the bedrock appears to be fractured.
Though some limited geologic information is available for NCR site,the available information is inadequate to characterize thedetailed geology and hydrogeology of the site. The proposed RIPhase I investigations will fill the gaps of information regardingthe critical issues identified above.
If the Phase I RI investigations indicate offsite migration of thecontaminant plume, a groundwater modeling analysis is proposed asan optional item during Phase I RI. If the analysis indicates theneed for additional field investigations on-site and/or off-site,these additional investigations will be performed in RI Phase IIafter securing the concurrence of EPA.
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3.0 SCOPING OF THE REMEDIAL INVESTIGATION/FEASIBILITY STUDYFOR THE NCR SITE
In keeping with recently developed EPA policy and guidance, Ebascowill follow a phased approach to perform the RemedialInvestigations (RI) and Feasibility study (FS). The phasedapproach allows focusing of the field investigation effort oncollection of the data needed to characterize the site sufficientlyto support the selection of a cost-effective remedy that adequatelyprotects health, welfare, and the environment. A phased approachalso allows analytical and evaluative activities to be conducted ina timely and cost-effective manner.
The scope of this RI/FS, developed during the preparation of thisWork Plan, and in meetings with the EPA, promotes a phased approachby accomplishing the following three critical objectives.
o Provide a comprehensive rationale for specific fieldinvestigation tasks based on a thorough review and evaluationof existing data available for the site.
o Define specific data requirements by conducting a preliminaryrisk assessment and scoping of potential remedialalternatives. Preliminary identification of these risks andalternatives is a necessary first step in defining Applicableor Relevant and Appropriate Requirements (ARAR's) andinvestigative Data Quality Objectives (DQO's) for the project.
o Incorporate the previous considerations into the developmentof Project Plans. For the NCR site, development of the WorkPlan and the FOP (i.e., the Health and Safety Plan, FieldSampling and Analysis Plan, and Site Management Plan) wasperformed concurrently, and was authorized by the Work PlanMemorandum.
The following subsections identify the RI/FS objectives for the NCRsite (subsection 3.1), provide a discussion of ARAR's and DQO's(subsection 3.2), and define the scope and phasing of the proposedRI (subsection 3.3). The details of the Task Plans for the RI andthe FS are presented in Sections 4 and 5 respectively.
3.1 RI/FS OBJECTIVES
The objectives of the Remedial Investigation are to provide thedata base and technical understanding needed to complete afeasibility study, and, ultimately to allow USEPA to select acost-effective remedy which adequately protects human health andthe environment. The Remedial Investigation will consist ofdetermining the levels of contamination in the followingenvironmental media: surface and subsurface soils, surface waterin drainage trenches, drainage trench sediments, groundwater andair.
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The specific objectives of the Niagara County Refuse RemedialInvestigation include:
o identification of potential receptors, including population,environmental, and welfare concerns;
o evaluation of routes of exposure;
o assessment of quantity, concentrations, properties, andtransport of contaminants at the site;
o assessment of hydrogeological factors including continuity ofgeologic deposits underlying the site and direction and rateof groundwater flow;
o evaluation of the extent to which natural or man made barrierscurrently contain the contaminants of concern and adequacy ofthe barriers (including an evaluation of the present cappingsystems);
o evaluation of the present and potential distribution andmigration of contaminants in surface and subsurface soil,sediments, groundwater, surface water run-off, and air at thesite and immediately adjacent to the site;
o assessment of the degree to which future migration ofcontaminants may pose a threat to public health, welfare andenvironmental concerns;
o study of federal and state environmental and public healthrequirements so that site-specific applicable, or relevant andappropriate standards, limitations, criteria, and requirements(ARAR's) can be compiled;
o assessment of the degree to which site contaminants exceedARAR's; and
o assessment of site conditions which must be characterized forevaluation of site remedies.
Based on the results obtained from meeting these objectives, anevaluation of the necessity for, and extent of, remedial actions atthe site will be conducted and include:
o determination of need for additional source control actions;
o determination of need for migration control actions;
o identification of source and migration control actionsappropriate to the site conditions, particularly those actionsthat would offer a permanent solution or reduction in wastemobility, toxicity or volume; and
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o development and evaluation of appropriate migration and sourcecontrol actions as well as the no action alternative.
3.1.1 Preliminary Risk Assessment
A preliminary risk assessment has been performed to determine thenature of the potential health concern posed by the NCR site. Thisassessment was based on available data provided by USEPA and NYSDECand on information gathered during the site reconnaissance.Included in these sources is information on previous fieldinvestigations and chemical analyses, site history, geology andhydrogeology and adjoining demography and land uses. The mostlikely potential exposure pathways for chemical contamination willbe investigated to document and address the public health riskassessment. These possible pathways include soil and sediment,groundwater, surface water and biota. A brief discussion of eachpathway follows.
Soils
Limited surface soil sampling has been done on-site and in areasadjoining the NCR site. The site itself has been inadequatelycovered. In the south-west corner of the site, a few embeddeddrums have been exposed on the surface. Also, on-site personnel ortrespassers could be exposed to soils contaminated by leachateseeps at the northeast corner of the landfill. Access to the siteis not restricted (by evidence of all terrain vehicle tire marks onthe landfill) as is required by RCRA closure requirements for wastedisposal sites.
Areas of leachate seeps have not been evaluated to determine theirorigin or degree of contamination. The locations of these seepswere noted during the site reconnaissance. A limited samplingprogram will be conducted along with the collection of sedimentsamples to evaluate contaminant levels and exposure potential inthese areas. At the present time, as noted during the sitereconnaissance, the cap material is eroding away. With time,contaminated material may be exposed, or, erosion may have alreadyexposed material which is presently contaminating surface soils.The potential for public exposure to contaminated soils andsediment is real and primarily exists through the direct contact,ingestion and inhalation pathways.
Groundwater
Groundwater monitoring to date has not fully described thedistribution of groundwater contamination caused by hazardouschemicals emanating from the landfill. No site specificgroundwater potentiometric surface maps or other data ongroundwater flow paths beneath the site are available. Previoussampling results have indicated the presence of hazardous chemicalsabove background levels. However, their analyses have not
34 30^*60
adequately described the potential groundwater contamination underthe NCR site. Although the aquifer under the NCR Site is not usedby area residents, this pathway will be assessed to determine thepotential for landfill leachate movement via groundwater flow pathsfrom the landfill to soils, biota (through modeling) and surfacewaters (including the Niagara River) adjacent to the site.
The potential for public exposure via groundwater depends oncontaminant levels, groundwater use and the hydrologic regime.Exposure could occur through ingestion or direct contact withgroundwater containing landfill leachate which has migrated offsitevia subsurface pathways.
Surface Water
The potential for public exposure via surface water is dependent onthe hydrogeologic regime and drainage flows from the landfillrunoff trenches.
Niagara River and Black Creek are the primary recipients ofexisting or potential contamination from the NCR site. The NiagaraRiver is used primarily for fishing, recreational purposes and as adrinking water supply. The intakes for the area drinking watersupply are approximately 3 miles downriver from the discharge pipethat carries runoff water from the Niagara County Refuse Landfillinto the Niagara River. Surface water runoff from the northernsections of the site flow into Black Creek which eventually flowsinto the Niagara River. Persons using these waters for recreation,as well as aquatic life, could be exposed to existing or potentialcontamination.
Because of the potential for contamination to these surface waters,public health and environmental assessment evaluations are requiredto evaluate the potential for public health effects or impact onthese aquatic systems. Surface water and sediment sampling will beconducted during the field investigation to investigate the directcontact and/or ingestion pathways.
Air
Organic vapors have been detected at seeps and cracks in thelandfill during several site reconnaissances. Readings beyond theexplosive limit have been recorded with a combustible gas indicatorduring drilling operations within the landfill performed by EAST inAugust 1985. Erosion of the inadequate soil cover has resulted inthe potential for public exposure via air. Air sampling will beperformed during site operations to further investigate thispotential. In addition, air quality will be monitored during fieldoperations using portable instrumentation to provide additionaldata on air quality.
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Biota
The transport of materials from the soil, sediment, and surfacewater to local biota via applicable food chains will be evaluatedby modeling during the Phase I RI. The transfer of NCR siterelated materials to the local food chains could result in theirbioaccumulation and/or biomagnification in higher trophic levelsleading to man.
3.1.2 REVIEW OF EXISTING DATA BASE
Based on the potential pathways at the Niagara County Refuse Sitedescribed above, and review of the existing data base, thefollowing data gaps for characterizing contamination in the studyarea can be identified.
Groundwater Pathway - The data indicate that groundwater may becontaminated by organic and inorganic compounds including prioritypollutants. This early data base was for priority pollutantanalysis as opposed to TCL analysis. Therefore, the data base isdeficient for 20 organic compounds and 11 metals. Directconfirmatory sampling of groundwater is necessary to determine thepresent levels of organic and inorganic constituents within thegroundwater beneath the facility. Subsurface soil samples are alsorequired to establish the degree of migration of the contaminationand its adsorption to soils, and to ascertain the potential forcontaminated saturated soils to act as a secondary source forfuture migration.
Surface Pathway - The results of past studies of the surface waterimmediately adjacent to the Niagara County Refuse Site indicateelevated levels of volatile organics, phenol and pH. However, dueto the limited sampling results, information regarding thistransport pathway needs to be updated and expanded during thisRI/FS.
Direct Ingestion Pathway - There are insufficient data specifyingthe concentrations of organic or inorganic hazardous substances insurface waters and soils or sediments of the study area. Thesedata are needed both to evaluate the direct ingestion pathway andto estimate the potential for air contamination via suspension ofcontaminated soils.
In summary, the existing data base is not sufficient to definequantitatively the hydrogeologic regime at the site, nor is itadequate to quantitatively define groundwater and surface waterquality. As such, the data base also is not adequate to complete arisk assessment which could comply with existing guidance.Moreover, the minimal existing surface water and sediment data arenot sufficient to complete an environmental assessment, nor do theymeet quality assurance standards. However, the data that have beenobtained are adequate to make a qualitative assessment of theenvironmental conditions at the NCR site, and to plan a
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cost-effective and time-efficient RI program.
3.1.3 SCOPING OF REMEDIAL ALTERNATIVES
Preliminary Remedial Response Objectives - Although the existingdata base for the Niagara County Refuse Site is inadequate todefine the threat to public health and the environment, severalpreliminary remedial response objectives may be formulated from thepreliminary risk assessment and previous site investigations.
After data are gathered and evaluated in Tasks 5 through 8, theseobjectives will be refined and developed or, as appropriate,eliminated. Attainment of the RI objectives will provide a basisfor evaluation of these preliminary remedial response objectives.For example, if the extent to which natural and manmade barrierscontain substances and the adequacy of the barriers (i.e., cap) areassessed, the potential for direct contact with wastes can also beassessed. Other RI objectives, including assessment of chemicaldistribution and migration, will also allow better definition ofthe risk associated with direct contact with wastes.
On the basis of the existing data, preliminary remedial responseobjectives were identified to mitigate risks associated with thesite. These objectives include:
o minimizing human and wildlife exposures to contaminants thatmay be present in soil or wastes;
o minimizing human and wildlife exposures to contaminants thatmay be present in groundwater;
o minimizing environmental impacts due to the off-site migrationof contaminants via volatalization, groundwater and surfacewater flow; and
o minimizing site conditions and remedies from violating ARAR's.
Preliminary Scoping of Remedial Technologies and Operable UnitsTo meet the preliminary remedial response objectives developed, aset of general response actions were identified. These generalresponse actions fall into the following categories:
o source control actions;
o migration control actions; and
o no action.
Remedial technologies that address these actions are discussed inthe following paragraphs and are summarized in Table 3-1. Thesetechnologies will be screened during the FS. In general,technologies will be screened by site-limiting characteristics,
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NIAGARA (X < REFUSE SITEARAR'S - USEPA
TABLE 3-1
PRELIMINARY SCOPING OF REMEDIALTECHNOLOGIES AND OPERABLE UNITS
NCR RI/FS WORK PLAN
PotentialRemedial Actions
Attainment of PreliminaryResponse Objectives Feasibility for NCR Site Comments
Source Control Actions
Capping
Pumping Wells (throughlandfill)
Removal (followed by adisposal or treatmenttechnology)
Hot Spot Excavatingand Treatment
Minimizes exposure to volatilizedcontaminants.Minimizes exposure to contaminantsin soils and wastes.Reduces leaching of contaminants fromsource to groundwater so that potentialfor exposure to groundwater is lessened.Reduces off-site migration of contaminantsvia surface water flow.
Reduces leaching of contaminants fromsource to groundwater.Reduces off-site migration of contaminantsvia groundwater.
Prevents exposure to volatilizedcontaminants.Prevents exposure to contaminantsin soils and wastes.Reduces exposure to contaminatedgroundwater.Minimizes the off-site migration ofcontaminants via groundwater and surfacewater flow.
A soil cover has already beenplaced over most of the hazardouswaste area.Since side slopes of the landfillare not steep, capping is alsofeasible in these areas.
- Possible difficulties in placementof wells through landfill.
- The low permeabilities of the clay/till material beneath the landfillwill reduce the effectiveness ofthe pump.
May be necessary in the suspectedindustrial cell area if current sourcecontrol measures are not sufficient.Further information concerningtypes and amounts of wastes to beremoved would be necessary.After removal, disposal and treat-ment technologies would need to beimplemented. These technologiescould be implemented either on-or off-site.
The present soil cover iseroded and inadequate.Off-site migration which hasoccurred already is not addressed.May not meet SARA 121(b)(l)long-term effectiveness.Grass can be established on thecover to decrease erosion bywind and water.Diversion of surface runoffhas also been implemented inan effort to prevent coversoil erosion.
The vertical migration of thecontaminants into the rock isbetter controlled. Removal ofmounded water in the landfillaccelerates the source controlactivity. Suitable cover overlandfill will minimize seepagein the future.Water treatment facilities ableto handle elevated levels ofcontami nants required.Does not address off-sitemigration which has alreadyoccurred.
If removal is considered as asource control action, furtherconsideration of treatment anddisposal options will berequired.Removal may requi re removal ofnonhazardous as well ashazardous wastes.
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NIAGARA Cv. < REFUSE SITEARAR'S - USEPA
TABLE 3-1 (Cont'd)
PRELIMINARY SCOPING OF REMEDIALTECHNOLOGIES AND OPERABLE UNITS
NCR RI/FS WORK PLAN
PotentialRemedial Actions
Attainment of PreliminaryResponse Objectives Feasibility for NCR Site Comments
A successful in-situ treatment actioncan degrade, remove or immobilizecontaminants.
Probably not feasible at NCR siteas the landfill is large andcontains complex heterogeneousmaterials.In-situ technologies for landfillprojects are not developed fully andmay not be feasible from theviewpoint of implementability andcosts.
Migration Control Actions
Containment Barriers Minimizes off-site migration of groundwatercontaminants to surface water or off-siteareas.Reduces exposure to contaminatedgroundwater.
- Feasibility dependent on thedepth and integrity of bedrockand on groundwater flow patterns.
Pilot testing would be necessaryto assess any in situ treatmenttechnology.In-situ ground-freezing is usedonly as a temporary treatmentbecause of the maintenance costs.In-situ thermal processes requirea large power source and costlyemission controls.Thermal processes are lessefficient for deep zones ofcontaminants (about 20 feet atNCR site).Bioreclamation can be much moreeconomical than the physical and .chemical treatment, but itssuccess depends on far too manyvariables and may not degrade allcontaminants present in thelandfill.Elevated concentration ofcontaminant could be toxic tomicroorganisms. Oxygen supplymay be requi red.Chemical treatments may involveaddition of certain chemicalswhich may interact in a complexway with heterogeneous chemicalswithin the landfill and createnew problems.
Information gathered during theremedial investigation on geologyand hydrogeology at the site willbe used to assess the feasibilityof a containment barrier.
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NIAGARA CU,..iY REFUSE SITEARAR'S - USEPA
TABLE 3-1 (Cont'd)
PRELIMINARY SCOPING OF REMEDIALTECHNOLOGIES AND OPERABLE UNITS
NCR RI/FS WORK PLAN
PotentialRemedial Actions
Attainment of PreliminaryResponse Objectives Feasibility for NCR Site Comments
Groundwater Extraction/Treatment/Di scharge
No Action
Reduces off-site migration of ground-water contaminants to surface water oroff-site areas.Reduces exposure to contaminatedgroundwater.
Because a soil cover and a clay barrier inthe sandy loam surrounding the landfillhave already been constructed, remedialobjectives may have already beenattained by these measures to some degree.No further attainment of response objec-tives would be gained with the "no action"alternatives.
Groundwater extraction requiresthe installation of withdrawalwells or subsurface permeabletrenches and a pumping system.These measures could be implementedat NCR, although success willdepend on site geohydrology.The low permeabilities of the clay/till material may render the pump/trench ineffective.Treatment techniques are dependenton contaminant types. For volatileand semi-volatile organics, airstripping or carbon absorptiontechnologies may be applicable.Treated groundwater could be dis-charged to surface water or rein-jected into the aquifer.
The effectiveness of the presentdegree of remedy is dependent onresults of field investigation,risk analysis and degree towhich ARAR's are met.Source control measures implementedas part of a Consent Agreement maybe continued or altered as part ofthe "no action" alternative.
Pilot testing of applicable treat-ment, technologies may be required.ARARs concerning discharge or re-injection of water will requireconsideration.If air stripping is considered,contaminant concentrations ineffluent air must be under setaction levels.The likely presence of largequantities of nonhazardousorganics in leachate may maketreatment to remove hazardouscontaminants difficult orimpossible.
Data collected and analyzedduring the remedial inves-tigation must show conclusiveevidence that responseobjectives will be attainedwithout further action.Otherwise, remedial actions orfurther investigation will benecessary.Even if the no action alternativeis chosen, continuous monitoringwill still be necessary.
-n
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waste-limiting characteristics, and inherent limitations of thetechnology. The technologies that remain after screening will bedeveloped into alternatives. A more detailed discussion oftechnology screening is presented in Section 5.1.
Source Control Actions - Source control remedies prevent orminimize migration of hazardous substances from the sourcematerial. Such measures may assist in the attainment ofpreliminary response objectives by minimizing the volatilization ofcontaminants, preventing direct contact with wastes andcontaminated soil, minimizing the amount of contaminants leachingto groundwater, and reducing contamination in surface runoff.
After sampling data are gathered and evaluated, the adequacy of theexisting landfill cover for preventing surface water entry will beevaluated and a risk assessment performed. The need for additionalsource control actions will then be assessed. Additional sourcecontrol remedies that may be applicable to the NCR site includeinstallation of another cap, improvement of the present cap,installation of well points through the landfill, source removal,and in situ treatment. The preliminary feasibility of theseactions is presented in Table 3-1.
Migration Control Actions - Remedial actions designed to managecontaminant migration are necessary when hazardous substances havemigrated from the original contaminant source. At the NCR site,off-site migration of contaminants could occur via surface water,groundwater, and air emissions. Exposure to the general publiccould then occur by ingestion of contaminated drinking water,direct contact with surface water contaminants, inhalation of aircontaminants, or consumption of fish.
Several technologies, used alone or in combination, may effectivelycontrol the migration of contaminants in groundwater. Initially,an impermeable containment barrier may be used to restrictgroundwater flow. Such a barrier would help to prevent migrationof contaminated groundwater to surface water and off-site areas,therefore reducing human exposure risks.
When used together, groundwater extraction and treatmenttechnologies can also slow the migration of contaminants.Extraction requires the installation of withdrawal wells orsubsurface permeable trenches. Depending on the types ofcontaminants present in groundwater, applicable treatmenttechnologies may include carbon absorption or air stripping. Pilottesting may be necessary to assess potentially applicable treatmenttechnologies. Slowing or preventing migration of contaminants ingroundwater can reduce the potential of exposure due to directcontact with surface water contaminants. In addition, control ofleachate migration by the use of subsurface drains or drainageditches can lessen surface water contamination. The preliminaryfeasibility of these alternatives is presented in Table 3-1.
No Action - The no-action alternative generally consists of sitefencing and groundwater monitoring. These actions are not beingimplemented by the current owner. The NCP requires that the noaction alternative be considered in the remedy selection process.During this selection process, an assessment of the degree to whichremedial response objectives are met will be made. If potentialpublic health or environmental impacts are indicated or if ARAR'swill not be met, the no-action alternative will not meet responseobjectives. If these objectives are not met, the no-actionalternative will not be applicable to the site. A preliminaryfeasibility evaluation of the no-action alternative is given inTable 3-1.
3.2 DETERMINATION OF APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARAR's)
3.2.1 Determination of ARAR's
The ARAR's preliminarily identified below have been categorized as"applicable or relevant and appropriate," and "to be considered".These listings are based upon EPA guidance published pursuant toSection 121 of CERCLA. Section 121 of CERCLA requires that,subject to specified exceptions, remedial actions be undertaken incompliance with applicable or relevant and appropriateenvironmental laws, both State and Federal. The most recent EPAinterim guidance was published on August 27, 1987 (52 FederalRegister 32496).
CERCLA defines ARAR's as:
o any standard, requirement, criterion, or limitation under anyfederal environmental law; and
o any promulgated standard, requirement, criterion, orlimitation under a state environmental or facility siting lawthat is more stringent than any federal standard, requirement,criterion, or limitation.
Within these jurisdictional boundaries EPA guidance segregatesARAR's in accordance with the activity they are expected to effect.ARAR's that relate to the level of substance, contaminant orpollutant allowed are called contaminant-specific; ARAR's thatrelate to the characteristics of the site are calledlocation-specific; and ARAR's that relate to a method of remedialresponse are called action-specific.
3.2.2 Consideration of ARAR's During the RI/FS
It may be noted that as the RI/FS process continues, more ARAR's,particularly as guidance is issued by the State of New York, willbe considered and developed. Specifically, ARAR's will beconsidered at six key intervals.
1) Task 1 - Scoping of the Field Investigation and Analyses (seeSection 4.1): Consider ARAR's when determining the data to becollected in the field investigation and required analyticallevels.
2) Task 6 - Public Health Evaluation (see Subsection 4.6.1):Consider ARAR's during the analysis of risk to public healthand the environment.
3) Task 9 - Development of Remedial Response Objectives (seeSubsection 5.1.1): Compare site data base to ARAR's.
4) Task 9 - Identification of Applicable Technologies andAssembly of Alternatives (see Subsection 5.1.2): UtilizeARAR's specific to site conditions for development of actionlevels, specific response objectives, and remedialalternatives relative to criteria defined in 40CFR300.68(f).Also, identify ARAR's that apply to the formulatedalternatives.
5) Task 9 - Screening of Remedial Technologies/Alternatives (seeSubsection 5.1.3): Consider ARAR's when assessing theeffectiveness of an alternative, as defined in40CFR300.68(g)(3).
6) Task 10 - Remedial Alternatives Evaluation (see Section 5.2):Evaluate each alternative to the extent it attains or exceedsARAR's, as defined in 40CFR300.68 (h)(2)(iv).
The conclusions on ARAR's reached at these intervals will be usedas a guide to evaluate the appropriate extent of site cleanup, toaid in scoping and formulating proposed treatment technologies, andto govern the implementation/operation of the selected action. Aswith the preliminary identification (Section 3.2.3), they aredeveloped by taking into account the following:
o contaminants suspected to be at the site;
o chemical analyses to be performed;
o types of media to be sampled;
o geology and other site characteristics;
o use of the resource/media;
o level of exposure and risk;
o potential transport mechanisms;
o purpose and application of the potential ARAR's; and
o remedial alternatives that will be considered for the site.
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3.2.3 Preliminary Identification of ARAR's for the NCR Site
3.2.3.1 Potential Applicable or Relevant and AppropriateRequ i rements
The NCP and the EPA Interim Guidance define applicable requirementsas the Federal requirements for hazardous substances that would belegally applicable at the site if this response were not undertakenunder CERCLA Section 104. Relevant and appropriate requirementsare defined as those Federal requirements that, while notapplicable, are designed to apply to similar problems to thoseencountered at this site. Requirements may be relevant andappropriate if they would be applicable but for jurisdictionalprerequisites associated with the requirement. With respect to theselection of remedial alternatives, relevant and appropriaterequirements are to be afforded the same weight and considerationas applicable requirements. The Federal and New York regulatoryrequirements that could be potentially applicable or relevant andappropriate to the Niagara County Refuse Site are listed in Table3-2.
3.2.3.2 Potential "To Be Considered" Requirements
When ARAR's do not exist for a particular chemical or when theexisting ARAR's are not protective of human health or theenvironment, other promulgated criteria advisories and guidance maybe useful in developing a remedial alternative. These criteria,advisories and guidance were developed by EPA, other Federalagencies and the State of New York. The concepts and dataunderlying these requirements may be used at the site in anappropriate way. The Federal and State of New York regulatoryrequirements that could be considered are listed in Table 3-3.
3.3 DATA QUALITY OBJECTIVES (DQO) DETERMINATION
DQO's are based on the concept that different data uses may requiredifferent data quality. Data quality is defined as the degree ofcertainty of a data set with respect to precision, accuracy,reproducibility, comparability, and completeness. DQO's arequalitative and quantitative statement specifying the requiredquality of data required to support RI/FS activities including sitescreening, characterization and risk assessment, and to supportengineering alternative evaluation and selection decisions. Thefour categories of data quality are as follows:
o Screening (DQO Level 1) provides the lowest data quality butthe most rapid results, and is used for purposes of sitehealth and safety monitoring, preliminary comparison toARAR's, and initial site characterization to define areas forfurther study. The data generated provides presence-absenceof certain constituents and is generally qualitative ratherthan quantitative.
300*7044
TABLE 3-2
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTSNIAGARA COUNTY REFUSE SITE
Requirement Rationale
Contaminant-Specific
Clean Water Act - NPDES Requirements Remedial action may involvefor Storm Sewers (40 CFR 122.26) water including discharge
Proposed Maximum Contaminant Levels(50 FR 46902-46933, Nov. 13, 1985)
Proposed Maximum Contaminant LevelGoals (50 FR 46936-47022,NOV. 13, 1985)
Rationale
SARA Section 121(d)(2)(A)(ii)
Considered in the publichealth evaluation
RI activities identifiedpresence of chemical for whichhealth advisories are listed
Considered in the publichealth evaluation
Remedial actions may providegroundwater remediation anddischarge to surface waters
Considered in the publichealth evaluation
Remedial actions may includeremoval and treatment ofwaste
Remedial actions may providecleanup to MCLs
SARA Section 121(d)(2)(A)(ii)
State of New York
New York Floodplain ManagementCriteria for State Projects(6 NYCRR 502)
Generic Hydrogeologic Study forProposed New Landfills andExpansions (DEC Solid WasteManagement Facility [6 NYCRR 360Guidelines])
Floodplain resources may beaffected by site remedialalternatives
A hydrogeologic study may berequired
300975
o Field Analysis (DQO Level 2), provides rapid results butbetter quality data. Analysis includes some mobile-labgenerated data and data generated by use of analyticalinstruments which are carried in the field. The data may bequalitative or quantitative.
o Engineering (DQO Level 3), provides an intermediate level ofdata quality and may be used for site characterization or riskassessment. Engineering analysis includes mobile labgenerated data and standard commercial laboratory analyseswithout full CLP documentation. These data are bothqualitative and quantitative. The analysis conducted insupport of treatability modes will be performed to Level 3.
o Confirmational (DQO Level 4), provides the highest level ofdata quality and is used for purposes of risk assessment,engineering design and cost recovery documentation.Confirmation analyses require full CLP analytical and datavalidation procedures.
o Non-standard (Level 5) - This refers to analysis byNon-Standard procedures, for example, when exacting detectionlimits, or analyses of an unusual chemical compound. Theseanalyses often require method development or adoption.
For the Niagara County Refuse Site, DQO's have been established tomeet investigative data needs. The review of site data has shownthat data deficiencies exist in the area of risk assessment as itrelates to the no action alternative, engineering design andprocess evaluation.
The presence of deficiencies in the available data indicates thatdata of Level 3 or above are appropriate. DQO Level 4 will begenerated for the chosen analytes of interest as potentiallyresponsible parties (PRP's) are involved in this project.
To meet the objectives of the RI/FS study, sample collection andanalysis will include surface water from drainage trenches,sediment from drainage trenches, soil, groundwater, and leachatesampling. Data quality objectives for laboratory chemical analysesin each of these media have been established as DQO Level 4, thatis, quantitative data requiring rigorous QA/QC for riskassessments, site characterization, and to provide a legallydefensible data base. The existing data base cannot be consideredconfirmation level or adequate to determine site characterizationor provide adequate data for the completeness of a risk assessment.Confirmational level analyses are required.
50
4.0 TASK PLAN FOR REMEDIAL INVESTIGATION
The tasks for the site RI/FS correspond to the 12 tasks describedin the EPA Guidance for RI/FS Tasks for REM Contractors (OSWERDirective 9242.3-7). Of these 12 tasks, eight are considered partof the RI, and four are included in the FS. The order in whichthese tasks are presented is the general order in which they willbe performed; however, since some tasks (e.g., Community Relations)occur throughout the duration of the RI/FS, the order ofpresentation gives only a general indication of the order the taskswill follow.
The following tasks are considered to be part of the RI:
The following four tasks are considered to be part of the FS:
o Task 9-Remedial Alternatives Screeningo Task 10-Remedial Alternatives Evaluationo Task 11-Feasibility Study Reporto Task 12-Post RI/FS Support
This section describes each of the eight tasks comprising the RI.Section 5.0 describes the four tasks comprising the FS.
4.1 TASK 1 - PROJECT PLANNING
This task involves several subtasks which must be performed inorder to produce the project planning documents and projectschedule necessary to execute the RI/FS. These subtasks include: akick off meeting; site visits; RI/FS brainstorming sessions; theevaluation of existing data; the preliminary identification ofremedial alternatives; the preparation of a preliminary riskassessment; data quality objective determinations; thedetermination of ARAR's; and scoping of the RI. All theseactivities are required for the preparation of the project plans.
The preparation of the project plans includes completion of draftand final versions of a Work Plan and a Field Operations Plan(FOP). The FOP is further broken down into three plans: the SiteManagement Plan (SMP); the Field Sampling and Analysis Plan (FSAP);and the Health and Safety Plan (HASP). The contents of these threeplans are described as follows:
51
o The SMP includes: a brief site description; an operations planoutlining the site team organization and responsibilities; andthe field operations schedule. This plan also addresses thesite security and control of access by unauthorized personnel tobe implemented at the site.
o The FSAP includes: sampling and analytical objectives; thenumber, type, and location of all samples to be collected duringthe field investigation; the site-specific quality assurancerequirements (which will be in accordance with the QualityAssurance Project Plan for the REM III Program and Region IIEnvironmental Services Division requirements) ; the detailedprocedures for field activities; and data management elements.
o The HASP includes: site-specific information; a hazardassessment; training requirements; monitoring procedures forsite operations; safety and disposal procedures; and otherrequirements in accordance with the HASP for the REM IIIProgram .
The FOP was prepared concurrently with this Work Plan; however, ithas been submitted as a separate volume.
4.2 TASK 2 - COMMUNITY RELATIONS
This task will be initiated to provide support to the EPA throughthe implementation of the Community Relations Plan which will beprepared for this Work Assignment. The REM III team is prepared toprovide support in the following ways:
o preparing fact sheetso providing support for public meetingso preparing public meeting summarieso preparing a responsiveness summary
The details of the Community Relations activities proposed for thesite are described in Section 6.0.
4.3 TASK 3 - FIELD INVESTIGATION
The Field Investigation completed during Phase I will consist ofthe following subtasks:
o Subcontracting/Initial Activitieso Topographic and Property Surveyo Mobilizationo Geophysical Investigationo Soil-Gas Survey (optional)o Weir/Flume Installationo Test Pitso Soil Borings and Soil Samplingo Hand Auger Samplingo Monitoring Wells
52
o Field Permeability Testing/Pump Testingo Groundwater Samplingo Surface Water and Sediment Samplingo Air Sampling and Analysiso Biota Inventory
The Field Investigation (Phase I) program will generate the dataneeded to define the extent of contamination, to conduct the PublicHealth Evaluation (Risk Assessment), to evaluate the need forgroundwater modeling, treatability studies and Phase II RI(additional on-site and/or off-site) investigations, and tocomplete the FS.
4.3.1 Subcontracting/Initial Activities
This subtask will include the procurement of the subcontracts toperform the Field Investigation. Three subcontracts will berequired:
o A site preparation subcontract, which will includemobilization of site trailers and equipment, utility hook-ups,security fencing, and construction of a decon pad.
o A well installation, soil boring, and test pittingsubcontract. This contract will include soil sampling andwell installation and development.
o A surveying subcontract for surveying the locations andelevations of the monitoring wells, and preparation of sitetopographic and property maps.
Initial activities will also include a site reconnaissance visitwhich will be conducted to locate all existing monitoring wells notpreviously identified, and assess their condition and potentialuse. In addition, property ownership maps will be obtained fromthe local town office, so that property owners in the vicinity ofthe site can be identified, and where needed, contacts initiated toobtain necessary permission to conduct field investigations. Thesite reconnaissance will also identify locations where a weir orflume can be installed, and allow a determination of which type ofinstallation is more appropriate for the local conditions, asdiscussed in Section 4.3.6.
4.3.2 Topographic Survey
A topographic map will be prepared which will encompass the area ofthe RI, estimated to be approximately 300 acres. The area includesall subsurface exploration and surface sampling locations at theNCR site and drainage paths in the vicinity of the site. Thoughthe landfill is approximately 50 acres in size, a larger area isrequired for catchment studies, and to allow the impact to theadjacent Witmer Road housings to be assessed. Figure 4-1 shows theapproximate boundaries of the area to be mapped.
300879
53
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REM III PROGRAM
300P80SCALE IN FEET
54
NIAGARA COUNTY REFUSE SITE
TOPOGRAPHICSURVEY AREA
EBASCO SERVICES INCORPORATED
The topographic survey will be prepared using aerial photographywith a ground control survey to locate new and existing monitoringwells. Surface sampling and geophysical investigation locationswhich cannot be located by taping from existing landmarks will alsobe surveyed. In addition, the topographic survey will includehorizontal and vertical location of roads, buildings, drainagefeatures and other points as needed. Vertical contours will beshown at 1-foot intervals on a final plan with a scale of 1 inch =100 feet. Vertical control will be mean sea level (MSL), andhorizontal control will be USGS datum.
Preparation of the topographic map will be completed during thePhase I investigations. Limited ground survey checks will also berequired during Phase II if additional monitoring wells or othersampling points are established during Phase II. The budget for aPhase II survey effort is not included in this Work Plan. Thetopographic survey will be conducted by a subcontractor to Ebasco.
4.3.3 Mobilization/Field Services
This subtask will consist of site preparation and services, fieldpersonnel orientation, and equipment mobilization. Sitepreparation work will include the procurement of field office andequipment storage trailers and portable toilet facilities, hook-upof electricity and telephone service, installation of a chain linksecurity fence around the site support zone and installation of achain link fence with gate across the entrance access road to thesite.
Signs will be posted around the perimeter at four strategiclocations to warn the intruders that the site is hazardous andentry is prohibited. In addition a security guard will be providedduring the site investigation period. The security guard will beon duty during the weekday nights and weekends when the fieldpersonnel are not present to safeguard the equipment on site andprevent illegal entry.
Each field team member will attend an on-site orientation meetingto become familiar with the history of the site, health and safetyrequirements, and field procedures. Equipment mobilization willentail the ordering, purchase, and if necessary, the fabrication ofall sampling equipment needed for the field investigation. Acomplete inventory of available REM III equipment will be conductedand any additional equipment required will be secured.
Equipment mobilization may include, but not be limited to, thefollowing equipment:
o field office trailer (command post);o field equipment/sampling trailer;o drilling subcontractor equipment;o sampling equipment;
300*8155
o health and safety/decon equipment; ando utility hook-ups.
Site services (rental of trailers, utility hook-ups, fieldsecurity, etc.) will be subcontracted by Ebasco. The location ofthe decon area and site facilities is shown on Figure 4.1.
4.3.4 Geophysical Investigation
A series of geophysical investigations will be conducted at the NCRsite to aid in the determination of the distribution of subsurfacecontaminants and to better define the boundaries of the landfillcells. The geophysical program will include electromagneticconductivity profiling and resistivity soundings. Plannedlocations of these activities are shown in Figure 4-2.
Each technique will be evaluated in the field during the first dayof survey utilizing that technique. Where field evaluation of thedata indicates that the acquired data is of limited value, furtherinvestigations using that technique will be discontinued.Geophysical investigations will be completed early in the fieldinvestigation, so that results of the geophysical investigationprogram can be utilized to refine the proposed locations ofsubsurface investigations.
Locations for the soil borings and groundwater monitoring wellswill be staked after evaluation of on-site geophysical and soil-gasdata. These locations will be measured from existing landmarks.
Electromagnetic Conductivity Profiling - Conductivity profilespreviously completed at the site show an increase in conductivityvalues in the areas west of the landfill disposal cells and suggestthat similar conditions may exist in the area east of the landfill.Profiles completed at the site were oriented generally west toeast, and included the area of the landfill itself.
The electromagnetic conductivity (EM) survey planned as part of thePhase I site investigation program will be restricted to theperimeter areas of the landfill, and not include traverses acrossknown disposal areas. Profiles will initially be conducted alongthe margins of the site to identify those areas of elevatedconductivity which may indicate contaminant migration. Figure 4-2shows the planned area of investigation of the initial EM survey.If profiles along the perimeter of the site show areas of anomalousconductivity to be present, additional EM profiles will becompleted in a grid pattern in the areas adjacent to the landfillcells, so that areas of potential plume migration can beidentified.
A traverse will also be completed in an off site, upgradient area toobtain background conductivity values. The EM survey will becompleted using a Geonics EM-34 terrain conductivity meter. TheEM-34 allows various depths of investigation, through modification
56
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REM III PROGRAM
NIAGARA COUNTY REFUSE SITE
GEOPHYSICALSURVEY LOCATIONS
EBASCO SERVICES iNCORPORATED
in the spacing and orientation of the transmitting and receivingcoils of the instrument. Initial investigations will utilize a 10meter coil spacing, with both horizontal and vertical dipoles.
A series of lines parallel to the landfill cells will be stakedout, and conductivity readings taken at 25 foot intervals alongeach line. One line will be completed around the perimeter of thelandfill before additional lines are begun. Ten to twenty percentof the first lines will then be repeated, utilizing a 20 meter coilspacing, with both horizontal and vertical dipoles. Results ofsurveys at both coil spacings will be evaluated by the ProjectGeophysicist, and the spacing which provides the best resolution ofanomalies utilized for additional survey work, as described below.At the discretion of the Project Geophysicist, supplementary linesutilizing the alternate coil spacing may also be completed.
In areas which exhibit anomalous conductivities a second, parallel,baseline will be established 100 feet further away from thelandfill, and conductivity readings taken along the line for adistance sufficient to identify the limits of the anomalous area.Readings will again be taken at 25 foot spacing along the EM surveyline. In the event that no anomaly is detected along the secondsurvey line, a third line will be completed between the first two.In the event that the anomalous area is still apparent at thesecond line location, a third line will be completed an additional100 feet from the landfill. Additional parallel EM survey lineswill be completed in this manner until the limits of the anomalousarea can be established, or the boundaries of the landfill propertyare reached.
An estimated total of 15-17,000 feet of electromagneticconductivity profiling will be completed as part of the Phase Iinvestigations. Areas where anomalously high conductivities arerecorded will be staked or otherwise marked (flagging or paint) sothat these areas can be accurately located during subsequent fieldinvestigations.
Resistivity Soundings - Resistivity soundings will be completed ina limited number of locations. Vertical profiles of subsurfaceresistivity will be developed from the soundings, which, togetherwith EM conductivity profiling will allow the subsurfacedistribution of contamination to be more accurately assessed. Sixto eight resistivity soundings are expected to be completed at thesite. Locations for resistivity soundings will be selected basedon results of EM profiling. One sounding also be completed in anoffsite, upgradient area to provide background values.
Geophysical data gathered during the site investigations will beplotted and presented as part of the report of fieldinvestigations. Computer generated contour and 3-D mesh maps willbe compiled from the conductivity data as appropriate. Datagathered during the geophysical program will be utilized tooptimize the planned locations for subsurface investigations
58
including soil borings, monitoring wells, and hand augers.
4.3.5 Soil-Gas Survey
The surface flux characterization of soil gas may be investigatedby a soil-gas survey. This is an optional investigation contingentupon the initial results of the electromagnetic conductivitysurvey. The decision to perform the soil gas survey will be madein conjunction with EPA personnel. The soil-gas survey would beconducted both along the perimeter of the landfill and across thelandfill. The purpose of the soil-gas survey on the landfill is toidentify locations of elevated concentrations of organic volatileswhich in turn may identify the location of industrial wastes andcontamination. The soil-gas survey will be conducted outside thelandfill to clarify anomalies in the geophysical survey and aid inthe location of boreholes and monitoring wells.
Soil-gas probes will be spaced along two lines on the perimeter ofthe landfill. The first line will be near the perimeter of thelandfill and the second will be located approximately 200 feet awayfrom the landfill. Probes will be spaced at 150-foot intervalsalong each line. Within the landfill itself, probes will becompleted along two north-south lines, again at 150-foot intervals.Figure 4-3 shows the planned location of the soil-gas survey lines.The soil-gas survey will closely follow the geophysical program sothat anomalies identified during the geophysical program can befurther investigated. The proposed grid pattern may be modified inthe field in preference to locations based on geophysics.
Soil gas analysis will be performed by field gas chromatographyinstrumentation which has been quantitatively calibrated for thefollowing compounds: TCE, PCE, methylene chloride, benzene, andtoluene. If compounds are detected which have not been included inthe list of calibrated compounds, they will be recorded as unknownpeaks for further investigation. Results of the soil-gas surveywill be used together with the geophysical survey results toevaluate the planned locations of soil borings and monitoringwells.
4.3.6 Weir/Flume Installation
A quantitative evaluation of the amount of surface water which isleaving the site is needed in order to adequately characterize thepotential for contaminant migration through this pathway, and tocomplete Task 6 risk assessments. This objective will be metthrough the installation of two weirs or flumes at the points atwhich surface runoff leaves the site. Final locations for theseinstallations will be determined during the site reconnaissanceinspection, however it is anticipated that a weir or flume will beinstalled immediately upstream of the entrance into the culvertwhich allows surface water runoff to enter the Niagara River to thesouth, and at the northern edge of the landfill, where surfacewater enters the Black Creek drainage. These locations are shown
59
INDUSTRIALDUMP CEL
SOILSURVEYLINES
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WILL BE TAKEN ATAPPROXIMATELY 150 - FOOTINTERVALS ALONG EACHSURVEY LINE
SOIL GASSURVEY LINES
UNDERGROUND WARNER AVE
ACCESS ROAD
FIGURE 4-3
REM III PROGRAM
NIAGARA NIAGARA COUNTY REFUSE SITE
SOIL-GASSURVEY LINES
SCALE IN FEET EBASCO SfnVICES INCORPORATED
on Figure 4-4.
Weirs or flumes will be utilized for these installations. Anautomatic guage will be installed to measure the depth of water.Selection of weir or flume type will be made based on inspection ofpotential measurement locations identified during the sitereconnaissance. Factors to be considered during reconnaissancewill include flow volume, ease of access for both installation andmonitoring, and long-term stability. Weir or flume installationwill be completed during the first stage of field work to allow themaximum amount of flow data to be acquired.
Following the completion of the subsurface soil investigation andmonitoring well installation program, water levels at theweir/flume will be monitored during trips made to the site forgroundwater sampling and monitoring well water level measurement.It is assumed that five trips will be made to the site for waterlevel monitoring. Additional site visits for this purpose wouldsubsequently be arranged by the EPA.
4.3.7 Test Pits
One test pit will be excavated by backhoe in a field west of thelandfill. The purpose of this investigation is to allow thepresence of dessication features similar to those reported in clayunits at other nearby waste disposal sites to be evaluated.Dessication features, if present at the NCR site, could causeeffective permeabilities considerably higher than would be expectedon the basis of grain sizes of the finer grained materials. Thistest pit will be excavated in a rectangular area of at least 5 feetby 5 feet and will be terminated at the minimum depth necessary toallow visual examination of the clay materials which are expectedto be present. An infiltration test will be run in this test pitto measure the infiltration rate of water.
An additional test pit will be completed by backhoe to investigatea municipal water supply line which is reported to run north-southalong the western margin of the site. The presence, and locationof this line will be evaluated using geophysical (EM) methods. Ifthe water line is found to traverse the site, its potential to actas a conduit for groundwater movement will be investigated, as thisexcavation may form a permeable zone which could act as a conduitfor contaminant migration. Planned test pit locations are shown inFigure 4-4. One soil sample from each test pit will be collectedfor field GC analysis. The sample showing the higher level ofvolatile contaminants will be submitted for full TCL analysis.
4.3.8 Soil Borings and Soil Sampling
Thirteen soil borings will be completed at the locations shown onFigure 4-5, numbered NCR88-1 to -13. After completion, each boringwill be converted to a monitoring well. Soil boring locations willbe reviewed following the geophysical and soil-gas investigations.
61
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NIAGARA COUNTY REFUSE SITE
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63
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NIAGARA COUNTY REFUSE SITE
SOIL BORING/MONITORINGWELL LOCATIONS
EBASCO SERVICES INCORPORATED
Planned locations may be modified, such that areas identified asanomalous by geophysical or soil-gas methods are furtherinvestigated during the soil boring program. Field GC analysiswill be used to screen samples from each of the soil borings, andto select samples for full TCL analysis by a CLP laboratory.
Continuous soil sampling will be conducted at each location. Table4-1 summarizes the planned soil boring and sampling program. Wheresubsurface conditions permit, borings will be advanced utilizing acontinuous tube sampler or split-spoon sampler advanced withaugers. The continuous tube sampler produces a 5-foot long, 4-inchdiameter core. Its use, however, is restricted to fine grainedsoils with little sand or gravel. Available information indicatesthat much of the overburden beneath the NCR site consists of clayor clayey material, so the continuous tube sampler is expected tobe effective. In the event that field conditions prohibit the useof the continuous tube system, soil borings will be advanced bycontinuous split spoon sampling.
Dioxin analyses will be performed on samples recovered from soilborings in and adjacent to the industrial waste cell (NCR88-3 and-12), thereby allowing the presence of, and potential hazard posedby, dioxin to be evaluated.
Samples collected from each five-foot interval will be evaluatedbased on: readings by field instrumentation (PID or equivalent)immediately following opening of the sampling tube; visibleevidence of contamination; and grain-size of the recoveredmaterials. Where instrumental readings are above background, orvisible contamination is indicated, that portion of the five-footsample interval will be placed in a sample jar for GC analysis. Inthe event that no contamination is indicated, but a more permeablezone is evident, soil materials from the more permeable zone willbe collected for GC analysis. In the event that all soil materialsare similar in grain size, and no contamination is indicated, ahomogenized sample of the materials from the five-foot intervalwill be collected for GC analysis. Sampling will continue in thismanner until bedrock is reached. An estimated six to eight sampleswill be collected from each soil boring, depending on the depth torock.
Soil samples will be screened by head-space analysis utilizing aportable gas chromatograph, and evaluated for elevatedconcentrations of volatile contaminants. Two samples showingelevated levels of volatiles will be selected from each boreholefor full TCL analysis. In addition, during the course of the fieldinvestigation, four "discretionary" samples will be collected priorto the completion of a borehole. This may occur when a borehole isnot completed before a weekend, and sample holding times requirethat samples be shipped. Selected soil samples will also beanalyzed for physical parameters, as described in section 4.4.1.
If insufficient soil sample is recovered from the first boring at a
Notes: 1) All borings not completed as bedrock monitoring wells will be terminatedat top of bedrock, assumed to be 45 feet.
2) Bedrock coreholes will be extended 15 feet below top of rock, or 10feet below bottom of casing, whichever is deeper.
3) Soil samples not selected for TCL analysis will be stored until theconclusion of the field program. Representative samples will then bechosen for geotechnical analyses.
COs>
3934M
location, additional sample may be collected from the same intervalof an adjacent boring. Six soil borings will be advanced into rockby NX or NQ coring methods. Prior to advancing the borehole intorock, casing will be placed through the overburden, as described inSection 4.3.10. Core recovered from each hole in bedrock will belogged and stored.
Borings in which no monitoring wells are installed will be groutedto the surface after the sampling is completed. Drill cuttingswill be containerized during the soil boring effort. All rinsewater will be collected and containerized in 55-gallon drums orother suitable container. All drums containing drill cuttings willbe collected and covered in a staging area at the site. Soilborings will be completed by a subcontractor to Ebasco.
4.3.9 Hand Auger Sampling
Hand auger samples will be collected from 15 locations around theperimeter of the site in order to provide data on potentialcontaminant migration away from the landfill in the shallowsubsurface. Planned sampling locations are shown in Figure 4-4.These locations may be modified following analysis of thegeophysical and soil-gas data, such that hand auger samples arecollected from areas indicated as anomalous by those surveys.
Each hand auger sample will be analyzed by a field GC, and fivesamples showing elevated levels of volatile organic constituentswill be sent to a CLP lab for full TCL analysis.
4.3.10 Monitoring Wells
A total of 18 to 22 monitoring wells will be installed at the NCRsite. The monitoring well program includes a minimum of two and amaximum of six wells drilled into bedrock, eleven wells completedin overburden at depths of 20 to 45 feet, and five additionaloverburden wells completed at depths of 5 to 15 feet. These 22wells will be completed at thirteen locations, as shown in Figure4-5. Table 4-2 summarizes the planned depth and the purpose ofeach of the monitoring wells.
Five monitoring wells installed by NUS Corporation and fourmonitoring wells within the landfill installed by EAST will be usedto collect groundwater samples if they are found in a good andoperable condition. For the two wells installed by USGS, onlygroundwater level measurements will be taken if found in anoperable condition. Riser pipes will be raised in all the existingwells as necessary.
The purpose of the monitoring well installation subtask is to allowcollection of groundwater samples to characterize the nature andextent of groundwater contamination at the site and to determinegroundwater flow paths. The horizontal and vertical extent ofcontamination at the site is not known. Therefore, borings and
66
monitoring wells will be installed at fairly evenly spacedintervals on and around the site. Planned locations of monitoringwells will be reviewed following receipt of information onmonitoring wells reported to have been installed at the site in1983, and following inspection during the initial site activities.If the five bedrock monitoring wells are found to be in usablecondition, and if well construction materials, methods anddocumentation meet QA requirements, the planned bedrock monitoringwell program will be revised. Existing wells which do not havelocking protective cover will not be considered acceptable.
In the event that the reported bedrock monitoring wells installedby NUS are still operational, groundwater samples will be takenfrom these wells and the following revisions will be made to theplanned program (NUS well locations shown on Figure 2-4):
o NCR88-11D will be deleted if NUS wells 1 & 2 are functional;
o NCR88-2D will be deleted if NUS well 4 is functional;
o NCR88-6D will be deleted if NUS well 5 is functional.
NCR88-5D & -12D will be installed even if all the NUS wells areoperable. NCR88-8D may be deleted from the program if water levelsmeasured in all bedrock monitoring wells indicate a consistentbedrock groundwater gradient.
Planned locations of monitoring wells will also be reviewedfollowing completion of site geophysical and soil-gasinvestigations. If the results of these investigations showanomalous subsurface conditions in areas where no monitoring wellsare planned, soil boring/monitoring well locations may be adjustedto investigate the anomalous areas. Ebasco will submit a letter tothe EPA outlining any proposed revisions in the subsurfaceexploration program, and the reasons for the proposed revisions.
Overburden wells will be installed by hollow stem augering (4 or 6"inside diameter) or other method if subsurface conditions preventthe use of hollow stem augers. Each overburden well will beconstructed of 2" stainless steel screen and riser. In the event aconfining layer is encountered, overburden drilling will betelescoped through the confining layer.
In each soil boring/monitoring well location, the deepest boringwill be completed first. This will allow well screen depths forthe subsequent wells of the cluster to be selected based on thestratigraphy identified in the first hole. Selection of screendepths will be based on: observed water level in each boring;visible or field instrumental evidence of contamination; or depthsof more permeable zones based on the grain size of subsurfacematerials.
At locations where more than one well is planned, the deepest well
67
TABLE 4-2
MONITORING WELL SUMMARY
NIAGARA COUNTY REFUSE SITE
Boring/Well No.
NCR88-1M
NCR88-2S
Est.Depth
45 ft
5 ft
SoilSamples
Yes
No
Over-burden
45 ft
5 ft
Core
0
0
ft
ft
Objective
Background well forgroundwater quality
Assess groundwater
-2M 45 ft
-2D a 60 ft
NCR88-3S 5 ft
-3M 45 ft
NCR88-4S 5 ft
-4M 45 ft
NCR88-5S 5 ft
-5M 45 ft
-5D 60 ft
NCR88-6M 45 ft
-6D b 60 ft
NCR88-7M 45 ft
NCR88-8M 45 ft
-8D c 60 ft
NO
Yes
No
Yes
No
Yes
No
No
Yes
No
Yes
45
45
5
45
5
45
5
45
45
45
45
ft
ft
ft
ft
ft
ft
ft
ft
ft
ft
ft
0
15
0
0
0
0
0
0
15
0
15
ft
ft
ft
ft
ft
ft
ft
ft
ft
ft
ft
Yes
No
Yes
45 ft
45 ft
45 ft
0 ft
0 ft
15 ft
elev. and quality onnorth side of BlackCreek drainage, depthto bedrock, potentialfor vertical migration
Obtain chemical data oncontaminant migrationnorth into Black Creekfrom suspected chemicalwaste cell
Monitor groundwaterlevel and contaminantmigration to northeastof site
Allow development ofwest to east subsurfaceprofile across site,assess vertical move-ment of contaminants
Complete west to eastgeologic profile,assess potentialcontaminant migrationto east
Evaluate groundwaterflow paths andpotential for migrationsouthwest towardsNiagara River
Evaluate groundwaterflow to southeast andstratigraphy insouthern portion ofsite
68 300^04
TABLE 4-2 (CONT.)
MONITORING WELL SUMMARY
NIAGARA COUNTY REFUSE SITE
Boring/ Est. Soil Over-Well No. Depth Samples burden Core Objective
Evaluate groundwatermovement in overburdenunits to southeast andtowards river
Allow groundwater flowpaths in overburden andbedrock to be evaluatedin area between siteand Niagara River
Sample Groundwaterimmediately south ofindustrial cell
Assess groundwaterelevation and potentialmigration south
800 ft 90 ft
Locations of wells shown in Figure 3-7.
Notes; Monitoring wells will be installed in all boreholes. Holescompleted into rock will be completed as open holes, with four-inchstainless steel riser set 2 to 3 feet into rock. Overburden wellswill be completed with two-inch stainless steel screen and riser.The monitoring wells will be screened near the water table toassess contamination. The estimated depths are maximum depths.Well screen depths will be selected based on the stratigraphy andgroundwater level determined from the initial borings.
a - will be deleted if NUS well 4 is operable,b - will be deleted if NUS well 5 is operable,c - will be deleted if water levels measured in all bedrock
monitoring wells indicate a consistent bedrock water gradient,d - will be deleted if NUS wells 1 & 2 are operable.
Existing wells are considered to be in operable condition providedsufficient documentation of well construction details is availableto satisfy QA requirements. In the event that these wells aredeleted from the program, soil samples will be collected from thedeepest soil boring planned from the location.
69
will be completed first. Soil samples will be collected from thatboring for analysis. No soil samples will be collected fromshallower borings at a cluster location unless insufficient samplewas retrieved from the first boring of the cluster.
At locations where no bedrock well is planned, soil boring will becontinued until refusal is reached. Overburden monitoring wellswill then be placed as described in the text.
Bedrock wells will be drilled as an open hole 15 feet into rock.Boreholes will be advanced to bedrock utilizing the same methods asemployed for the overburden wells, except that 6" ID hollow stemaugers shall be used. Prior to advancing the hole into rock,four-inch diameter stainless steel casing will be installed throughthe overburden, and grouted into place. Casing will be seated intorock a minimum of two to three feet. Rock coring will not proceeduntil the grout around the casing has been allowed to set. Coringwill be accomplished using NX or NQ size equipment, producing ahole slightly less than three inches in diameter. Monitoring wellinstallation will be performed by a subcontractor to Ebasco.
Each well will be developed by pumping and/or surging afterinstallation. Development of overburden wells will last for atleast one hour or until the water is clear, whichever occurs later,depending on site conditions. All cuttings will be containerizedin drums and stored in a central area on-site. Well developmentwater will be temporarily containerized and disposed of on theground surface within 20 feet of the well, if permitted by NYSDEC.Development water will not be allowed to flow directly into asurface drainage channel. Cost estimates for this work assumedthat water can be disposed on-site.
4.3.11 Field Permeability Testing
Falling head or slug tests will be performed in each monitoringwell installed in the overburden units. In addition, where waterlevels are sufficiently close to the surface, a centrifugal pumpwill be used to perform low yield pumping tests in monitoring wellsinstalled in the overburden. Packer tests will be performed inholes advanced into bedrock. A short duration (two to four hour),low yield pump test will be completed in each bedrock monitoringwell. Monitoring of any possible response in the overburden wellsof the cluster will allow the permeability of the overlying unitsto be more fully evaluated. Pump tests will also provide dataneeded to evaluate treatment alternatives which involve extractionwells. Water extracted during pump tests will be temporarilycontainerized.
Following the completion of the pump test, and after thegroundwater level in the well has returned to its static level, apacker test will be conducted in each bedrock well. An inflatablepacker will be set approximately five feet below the rock surface,and water injected into the hole to a pressure equal to
70
approximately 1 psi per foot of depth below the ground surface.The flow rate will be monitored for a period of ten to twentyminutes. Results of the packer test will be used to assess thefeasibility of grouting of fractures in the rock, and to provideadditional permeability data. Water used in the packer test willbe that which was pumped from the hole during the pump test. Waternot reinjected into the hole during the packer test will be storedat a central location onsite.
4.3.12 Groundwater Sampling
Two rounds of groundwater samples will be obtained from allmonitoring wells installed during the RI, and from all existing NUSand EAST wells that are still operable. The samples will beanalyzed for the parameters shown in Table 4-3. Monitoring wellsampling procedures are presented in the FOP. The first round ofgroundwater samples will be collected approximately two weeks afterthe last monitoring well is developed. The second round will becollected four weeks after the first round is completed. Thepurpose of the second round is to confirm the analytical results ofthe first sampling round.
Three to five well volumes will be purged by pumping or bailingprior to sampling. The pre-sample purge water will be temporarilycontainerized until disposed of in a manner similar to developmentwater. A stainless steel bailer will be used to obtain thegroundwater samples after purging is complete and the water levelhas stabilized.
A background water sample will be collected from borehole NCR88-1,located upgradient of the site, as shown in Figure 4-4.
4.3.13 Surface Water, Leachate, and Sediment Sampling
Surface water samples will be collected from the drainage ditchesaround the site at approximately the locations shown in Figure 4-6.In addition, one sample will be collected from the Niagara River atthe point at which the drain pipe discharging from the site emptiesinto the river. Sampling of surface waters, together withmeasurement of surface water discharge into the Niagara River andBlack Creek is required to allow remedial alternatives for surfacewater treatment to be evaluated. During the field investigationprogram, surface water sampling will be scheduled following aprecipitation event.
Sediment samples will be collected from the drainage ditches at thesite at the approximate locations shown in Figure 4-6. Sampleswill be collected using a scoop sampler, and will be analyzed forthe parameters shown in Table 4-3. Sediment sampling will becompleted to allow contaminant migration through the surficialpathway to be evaluated, and to evaluate potential remedialalternatives.
71
,/ -3SUMMARY OF FIELD SAMPU.-u AND CHEMICAL ANALYSIS
NIAGARA COUNTY REFUSE SITE
Type &Numbers
Son12
SourceLocation
Soil borings
Samples perLocation
Sampli ngDevice
Splitspoon/auger
Sample Volume
Three 1/2 filledcontainers
Sample Container Preservation
2 x 8 oz and 120 mlglass
Cool to 4«C
Holding Times
Volatile* 10 days. Ex-tract ables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Lab Analyses
Full TCL or-ganics andinorganics
Test pit nearwater main
Shovel/Scoop
IS Hand auger Hand augers
Replicateslocation to befielddetermined.
Soil Borings
As above
Split Spoon
Three 1/2 filledcontainers
2 x 8 oz and 120 mlglass
Cool to 4-C
Three 1/2 filledcontainers
2 x 8 oz and 120 mlglass
Cool to 4»C
Three 1/2 filledcontainers
2 x 8 oz and 120 mlglass
Cool to 4-C
One filledcontainer
8 oz glass Cool to 4"C
Volatiles 10 days. Ex-tractables: 10 days ex-tract: 40 days analyzeInorganics: Metals 6months; Mercury 28 days
Volatiles 10 days. Ex-tractables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Volatiles 10 days. Ex-tractables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
6 months
Full TCL or-ganics andinorganics
Full TCLorganics andinorganics
Full TCLorganicsandinorganics
PCDD's andPCDF's
•Screen samples from soil borings and hand augers to select those forfull lab analysis. For soil borings screen 5-8 samples per hole, select2 for analysis. For hand augers screen each sample, select 5 for TCL analysis.
3924M
300P98
TABLE >nt'd)SUMMARY OF FIELD V. ..ING AND ANALYSIS
NIAGARA COUNTY REFUSE SITE
Type & SourceNumbers Location
Sediment18 Drainage
ditches
Samples perLocation
1
SamplingDevice
Samplingscoop
Replicateslocations to befielddetermined
As above
Sample Volume Sample Container Preservation
Three 1/2 filled 2 x 8 and 120 mlcontainers glass
Cool to 4»C
Three 1/2 filledcontainers
2 x 8 and 120 mlglass
Cool to 4"C
Holding Times
Volatile* 10 days. Ex-tractables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Volatile* 10 days. Ex-tractables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Lab Analyses
Full TCLorganicsandinorganics
Full TCLorganicsandInorganics
Surface Water11 Drainage ditches Sample
containers6 liters
Replicatelocation tobe fielddetermined.
Samplecontainers
6 liters
1 liter polyethylene2 x 40 ml glass; 4 x 1liter amber glass
1 liter polyethylene2 x 40 ml glass;4 x 1 literamber glass
Cool to 4«CHN03 topH< 2 (In-organicsonly) HC1 topH<2 (VOA's)
Cool to 4»CHN03 topH< 2 (in-organicsonly) HC1 topH<2 (VOA's)
Volatiles 10 days. Ex- Full TCLtractables: 5 days ex- organicstract; 40 days analyze. andInorganics: Metals 6 inorganicsmonths; Mercury 28 days
Volatiles 10 days. Ex- Full TCLtractables: 5 days ex- organicstract; 40 days analyze. andInorganics: Metals 6 inorganicsmonths; Mercury 28 days
00CDCD
3924M
TABLE/ Cont'd)SUMMARY OF FIELD SAMft.. . AND CHEMICAL ANALYSIS
NIAGARA COUNTY REFUSE SITE
Type &Numbers
SourceLocation
Samples perLocation
Groundwater22 Monitoring
wells (new)
SamplingDevice
Bailer
Sample Volume
6 liters perwell
Monitoringwells (existing)
Bailer 6 liters perwell
Replicateslocations tobe fielddetermined.
Bailer 10 liters perwell
Sample Container Preservation
1 liter polyethylene2 x 40 ml glass; 4 x 1liter amber glass
1 liter polyethylene2 x 40 ml glass; 4 x 1liter amber glass
1 liter polyethylene2 x 40 ml glass; 8 x 1liter amber glass
Cool to 4°CHN03 topH< 2 (in-organicsonly) HC1 topH<2 (VOA's)
Cool to 4"CHN03 topH< 2 (in-organicsonly) HC1 toptK2 (VOA's)
Cool to 4-CHN03 topH < 2 (in-organicsonly) HC1 topH<2 (VOA's)
Holding Times
Volatiles 10 days. Ex-tractables: 5 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 daysBOD 48 hrs, TDS 7 days,TSS 48 hrs, Alkalinity14 days
Volatiles 10 days. Ex-tractables: 5 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 daysBOO 48 hrs, TOS 7 days,TSS 48 hrs, Alkalinity14 days
Volatiles 10 days. Ex-tractables: 5 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 daysBOD 48 hrs, TDS 7 days,TSS 48 hrs, Alkalinity14 days
Lab Analyses
Full TCLorganicsandinorganicsBOD, TSS,TDS, Alk.
Full TCLorganicsandInorganicsBOD, TSS,TDS, Alk.
Full TCLorganicsandinorganicsBOD, TSS,TDS, Alk.
CO
3924M
TABlY ICont'd)SUMMARY OF FIELD SAMK .„ AND CHEMICAL ANALYSIS
Type &Numbers
SourceLocation
Samples perLocation
Leachate8 Leachate seeps
Air6
Sampli ngDevice
Scoop
Sample Volume
Three oz glass,120 ml glass
Replicate Scoop Three oz glass,120 ml glass
2 Upwind,2 downwind,2 on-site
and
Soil-Gas140 Perforated
steel tube
Tenex oractivatedcharcoaltubes
N/A
Air
N/A
Sample Container Preservation
2 x 8 oz glass, 120 ml Cool to 4«Cglass
2 x 8 oz glass, 120 ml Cool to 4°Cglass
7 cm long, 6 mm OD,4 mm ID tubes
Cool to 4»C
N/A N/A
Holding Times
Volatiles 10 days. Ex-tractables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Volatiles 10 days. Ex-tract ables: 10 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
N/A.
N/A
Lab Analyses
Full TCLorganic*andinorganics
Full TCLorganic*andinorganics
VolatileorganlcsprioritypollutantsMethane,H2S
Field testedby GC
Notes: Water Samples receiving pH adjustment must be checked with pH paper to ensure the proper pH has been achieved.All soil/sediment samples except those collected for VOA analyses must be homogenized prior to being put in containers.
COz>CO
3924M
TABL(SUMMARY OF FIELD SAMK^G AND CHEMICAL ANALYSIS
NIAGARA COUNTY REFUSE SITE
Type ftNumbers
Water14
SourceLocation
Field rinseblanks
Samples perLocation
SamplingDevice
Split Spoon,Hand Auger,Bailers
Sample Volume
6 liters
35
5
Trip blanks
DI waterblank
80 ml
6 liters
Drilling waterblank
6 liters
Sample Container Preservation
1 liter polyethylene2 x 40 ml glass 4 x 1liter amber glass
2 x 40 ml glass
1 liter polyethylene2 x 40 ml glass 4 x 1liter amber glass
1 liter polyethylene2 x 40 ml glass 4 x 1liter amber glass
Cool to 4»CHN03 topH < 2 (in-organicsonly) HC1 topH<2 (VOA's)
Holding Times
Volatile* 10 days. Ex-tractables: 5 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Cool to 4*C Volatile* 10 days
Cool to 4«CHN03 topH<2 (in-organics only)HC1 to pH<2(VOA's)
Cool to 4°CHN03 topH<2 (in-organics only)HC1 to pH<2(VOA's)
Volatile* 10 days. Ex-tract ables: 5 days ex-tract; 40 days analyze.Inorganics: Metals 6months; Mercury 28 days
Volatile* 10 days. Ex-tractable*: 5 days ex-tract; 40 days analyze.Inorganic*: Metals 6months; Mercury 28 days
Lab Analyses
Full TCLorganic*andinorganics
TCL VOA's
Full TCLorganic*andinorganics
Full TCLorganic*andinorganics
3924M
\\
FIELD
INDUSTRIALDUMP CELL
STREAM SEDIMENTSAMPLING LOCATION
W STREAM SEDIMENT ANDSURFACE WATERSAMPLING LOCATION
O LEACHATE SAMPLINGLOCATION
LOCATIONS SHOWN AREAPPROXIMATE. FINALLOCATIONS WILL BE
SELECTED BASED ON
FIELD CONDITIONS.
UNDERGROUNDCULVERT
FIGURE 4-6
REM III PROGRAM
300903
SCALE IN FEcT
NIAGARA COUNTY REFUSE SITE
PROPOSED SURFACE WATER,STREAM SEDIMENT, AND
LEACHATE SAMPLINGLOCATIONS.
EBASCO SERVICES INCORPORATED
77
Eight leachate samples will be taken at the approximate locationsshown in Figure 4-6. Final sample locations will be determined inthe field based on evidence of surface seepage and leachatedeposition. Samples will consist of surface soils or sludges, andwill be collected with a stainless steel scoop sampler. Leachatesamples will be analyzed for TCL compounds, as specified in Table4-3. Similar to the surface water sampling, the leachate samplingwill also be scheduled following a precipitation event.
4.3.14 Air Sampling and Analysis
Field survey meters such as organic vapor analyser (OVA) and HNUbrand photoionization detector had been used in the previousinvestigations. It appears that air quality is not a major problemat the NCR site. As such the proposed investigations will be keptto a minimum at a screening level to determine whether there areany critical problems of air quality at the NCR site.
Initially a reconnaissance will be performed over the landfill toassess any visual emission points within the landfill cover such ascracks, fissures and leachate seeps. These areas will then begrossly assessed using field survey meters as below:
o A flame ionization detector (FID) such as organic vaporanalyzer (OVA) calibrated to methane will be used.
o The OVA will be supplemented, by a photoionization detector(PID) such as HNU meter. Since the PID is blind to methane,these data will be useful in assessing the methane contentof the FID readings.
o The potential existance of hydrogen sulfide (H2S) will beassessed using a combustible gas indicator (CGI).
Two worst areas on the landfill will then be chosen for furtherquantification. Upwind and downwind locations for sampling willthen be determined by using a portable meteorological stationlocated on top of the landfill. The portable station will serve todetermine the upwind and downwind status of the sampling locationsand determine the atmospheric stability that would dilute landfillemissions prior to reaching the downwind location. As a minimumthe station will determine:
o the wind speed to assess dilution;o the wind direction to assess the plume direction; ando sigma theta to assess the dispersion.
The sensors will be located on a tripod approximately six feetabove the grade level.
After determining the sampling locations (one upwind site, twolandfill sites and one downwind site), further investigations willbe performed in the following sequence:
78
o Assuming high emissions at the landfill, portable pumps willbe used to draw a sample into an evacuated 125 ml glass"bomb". The bomb will be analyzed on site with the field GC.
o If the bombs indicate concentrations less than detectionlimits, Tenax and charcoal sampling of 5 litres of air willbe performed with immediate analysis with field GC. If theresults of the 5-litre sample indicate levels belowdetections, sample volumes will be increased in 5-litreincrements until an optimum volume is found.
Tenax and charcoal will be used in parallel as the combined use ofthese media allows for the capture of a fuller range of volatilecompunds. Charcoal is preferred for lighter volatile compoundsassociated with high vapor pressures. Tenax is preferred forheavier compounds associated with lower vapor pressures. Thecompounds of interest are phenol, benzene, chlorobenze, methylenechloride and toluene based on previous investigations.
The upwind sampling will be performed to assess ambient conditionsupwind of the landfill. Tenax and charcoal primary and backuptraps will be used in parallel to collect assumed clean upwind air.
The downwind sampling will be performed to assess contaminantcontributions from the landfill into the ambient air using the samemethodology as upwind sampling.
The results of the field sampling will yield concentration datathat can be used in establishing CLP sampling protocol. Fieldsorbent traps will be prepared in house. The traps will bethermally desorbed using a programmable thermal desorber (PTD) forreuse.
The CLP sorbent traps will be prepared under the protocol of acontract laboratory (CLP) participant. The analytical techniqueswill depend on trap contaminant concentrations.
Upwind and downwind analysis will follow EPA method 601/602. Theconcentration levels are expected to be low because the upwindsamples are assumed to be uncontaminated whereas the downwindsamples are expected to be diluted. Trap samples considered highlycontaminated will utilized EPA method 624/625 with GC/MS for theTenax and EPA method 601/602 with a carbon disulfide extraction forthe charcoal traps.
A total of six air samples plus QA samples are expected to becollected for detailed analysis: 2 upwind, 2 at the landfill and 2downwind of the landfill. Each sample will be collected over a 24hour period. The testing will be performed by a CLP laboratory.
30090579
4.3.15 Biota Inventory
A qualitative inventory of biota present at the NCR site will beperformed during the field investigation program. This inventoryis needed to allow the environmental risk assessment to becompleted. No biota sampling will be conducted as part of theplanned program of field investigations.
4.4 TASK 4 - SAMPLE ANALYSES/VALIDATION
Analysis of samples collected during the site investigation will beperformed in accordance with the DQO's established in Section 3.2.4of this Work Plan. The analyses will be performed by laboratorieswhich participate in the EPA National Contract Laboratory Program(CLP) utilizing CLP analysis protocol. Table 4-3 presents asummary of the planned analytical program.
Sample management and data validation will be performed by Ebascoutilizing the procedures and specifications contained in"Laboratory Data Validation - Functional Guidelines for EvaluatingOrganic Analyses," Technical Directive Document NO. HQ-8410-01, and"Laboratory Data Validation - Functional Guidelines for EvaluatingInorganic Analyses," Draft Technical Document.
Quality control during sample analyses is described in the EPA'sCLP program. Quality control for all other aspects of the task areto be in accordance with the Rem III Quality Assurance ProgramPlan.
Validation of measurements is a systematic process of reviewing abody of data to provide assurance that the data are adequate fortheir intended use. The process includes the following activities:
o Auditing measurement system calibration, and calibrationverification;
o Auditing quality control activities;
o Screening data sets for outliers;
o Reviewing data for technical credibility with respectto the sample location;
o Chain-of-Custody review;
o Checking intermediate calculations; and
o Certifying the previous processes.
4.4.1 Sample Analyses
Sample analyses will be performed by laboratories which participatein the EPA CLP Program.
80
Soil samples will be collected for full Target Compound List (TCL),TCL Volatile Organics, or TCL Inorganic analyses (see Table 4-3).Selected soil samples will also be classified and analyzed forgrain size, organic content, moisture content, bulk density,porosity, and laboratory permeability. The planned analyses foreach of the soil samples collected during the soil boring and wellinstallation efforts are shown in Table 4-3. Sediment and surfacewater samples will also receive full TCL analyses, as shown inFigure 4-2. Additional laboratory analyses (pH, conductivity,alkalinity, etc.) will be performed on all groundwater samples.
4.4.2 Preliminary Data Validation Support
Data validation is performed by the EPA Environmental ServiceDivision (BSD), Edison, NJ office. However, Ebasco will providesupport to EPA-ESD for data validation up to the extent of 98% ofthe effort in this task.
4.4.3 Sample Tracking
Samples sent to the CLP will be tracked to ensure the continuityand consistency of data and analyses throughout the samplingprogram. Tracking will include tabulating sampling and shippingdates; analyses performed; holding times; dates of extraction;dates of analysis; and dates of validation. The site manager willbe notified if problems develop with the sample analyses.
4.5 TASK 5 - DATA EVALUATION
This task includes efforts related to the analysis of data once ithas been verified that the data are acceptable. This task includesEbasco's data review, data reduction, summary and evaluationeffort.
Analytical precision at Niagara County Refuse will be assessed bycomparing split samples as well as collocated sampling locations.Knowledge of analyte data accuracy and precision within materialover the entire site and between locations is extremely important.The ability to test differences statistically between locations iscritical to defining contaminant boundaries, estimating volumesrequiring remediation, and developing treatment design criteria(Cleanup Levels) and cost.
Quantitative analytical data will be evaluated statistically usinggeostatistical methods (Kriging), as well as classical methods forcalculating point and interval estimated, testing hypothesis andevaluating corrections among parameters.
Geostatistical Evaluation of on-site contamination will:
o Provide accurate unbiased estimate of soil contamination;
30090781
o Depict the level of uncertainty associated with samplingthereby establishing the boundaries of contamination; and
o Define the minimum volume of void soil area requiringremediation.
All data collected will be analyzed to support a detailedevaluation of remedial alternatives. Site specific characteristicswill be compiled, mapped and analyzed including:
o Comparison, concentration, and physical state of contamination;
o Area and volume of contaminated media;
o Soil Engineering properties based on Unified SoilClassification System;
o Nature and events of drainage ditch sediment contamination;
o Groundwater contour maps; and
o Geologic cross-sections.
4.5.1 Data Reduction and Analysis
This task includes the data reduction and evaluation effort.Ebasco will develop the best means to organize, analyze, interpret,and present the data to support the RI and FS including:
o preparation and interpretation of well logs anddefinition of stratigraphy;
o identification of groundwater flow paths;
o investigation of the correlation between soilcontamination at the site and groundwater contaminantconcentrations;
o preparation of data summaries; and
o presentation of the field data to develop a picture ofcontaminant distribution at the site.
These analyses will provide information which will be incorporatedin the screening of remedial alternatives and in the detailedevaluation of remedial alternatives.
82
4.5.2 Groundwater Modeling
If the Phase I RI results indicate that a site-related contaminantplume extends beyond the boundaries of the site, it is important toestimate the extent of the plume beyond the site as well as todetermine if the plume originated from the site. Phase II's siteinvestigation (optional), primarily off-site, will be undertakenfor this purpose. It is proposed to utilize computerizedgroundwater simulation models to plan RI Phase II investigations.
Based on the results of Phase I of the RI, Ebasco will initiallydetermine whether groundwater modeling is necessary to assist inplanning Phase II RI to define the location and extent of thecontaminant plume. One of the following three recommendations maybe made to EPA after evaluating results of Phase I RI:
o No groundwater modeling is necessary;
o Groundwater modeling with additional fieldinvestigations is necessary during Phase II of the RI; or
o Groundwater modeling is necessary but no additionalfield investigations during Phase II of the RI.
If groundwater modeling is ultimately recommended, the appropriatemodel (i.e., one-, two-, or three-dimensional) shall be specifiedat the conclusion of Phase I of the RI.
The selected model will be the one which has been published andgenerally accepted. It should have the capability to simulate thegeohydrological conditions, environmental conditions (e.g.,multiple pollution sources), and contaminant transport mechanismsin the area adjacent to the site.
If one of the latter two alternatives is recommended, a letterreport documenting the recommendation will be submitted to the EPAfor review and approval. In the report, the following items willbe addressed.
o Reasons for selecting the alternative,
o Reasons for selecting a certain groundwater model;
o Brief description of the selected model; and
o Scope of work, budget and schedule required for theproposed groundwater modeling effort and additionalfield investigation (if any).
Although the specific scope of work for the groundwater modelingeffort cannot be defined at present, a lump sum provision of$80,000 has been estimated and budgeted in the Optional Form 60 for
this effort for planning RI Phase II investigations in this WorkPlan.
If Phase II work would have to be conducted, a Technical DirectionMemorandum will be prepared and submitted to the EPA for review andapproval. The effect of this Phase II work on the scheduleproposed for the work specified in this Work Plan is discussed inSection 7.3.
4.6 TASK 6 - ASSESSMENT OF RISKS
4.6.1 Public Health Evaluation
After the site information has been evaluated and the data base hasbeen established a semi-quantitative Public Health Evaluation willbe performed for the Niagara County Refuse Site. The object ofthis assessment is to characterize the health risks that wouldprevail if no further remedial actions are taken.
The objectives of this risk assessment are to determine:
o The potential health impacts of exposure to contaminatedsoils, sediments, groundwater, surface water, air andleachate and
o Appropriate remediation for contaminated soils, sediments,leachate, groundwater, air and surface water.
The basic methodology to be employed is summarized in Figure 4-7.The first item in the analysis is the selection of indicatorchemicals for which quantitative risk analyses will be performed.If numerous chemical constituents are found to be present,indicator chemicals will be selected. This process will beconducted according to the procedures outlined in EPA's"Endangerment Assessment Handbook" (1985). If fewer than 15 ToxicCompound List (TCL) compounds are found at the site, a quantitativerisk analysis will be performed for all of the detected pollutantspassing risks to health and the environment. If a greater numberof compounds are detected during the investigation, 10-15 indicatorchemicals will be selected for the risk analyses. Theconcentration will then be compared to the potentially applicableor relevant and appropriate standards and criteria which arereviewed in Section 3.2.
The second step in the Public Health Evaluation is the exposureanalyses. A preliminary identification of the potentialpopulations at risk based upon most likely exposure routes andexisting data base was presented in Sections 3.1.1 and 3.1.2.These exposure pathways will be the principal initial areas offocus, however, subsequent data collected during the siteinvestigation may warrant the inclusion of additional exposurepathways.
Concentrations of the indicator chemicals in environmental media atthe exposure points will then be estimated from the monitoring datausing environmental site and transport models as appropriate and asnecessary. Environmental chemistry and fate data from theliterature and prior studies (Section 2.2.5) will be considered andincorporated, where applicable, into all chemical concentrationestimates. The estimated concentrations will then be compared toapplicable or relevant and appropriate standards and criteria,which are reviewed in Section 3.2.1.
If applicable or relevant and appropriate standards are availablefor all of the indicator chemicals, no further quantitativeanalysis of risk will be performed. Additional risk analyses forcertain contaminants and critical exposure pathways, whereconcentrations exceed or nearly exceed standards, will be performedto confirm that the pollutant transport models adequately reflectconditions at the site and adequately determine where additionaldata are needed to properly characterize risks. If standards andcriteria are not available for all of the indicator chemicals,quantitative analyses will be performed, following the generalprocedures outlined in EPA's Endangerment Assessment Handbook(1985) and Superfund Public Health Evaluation Manual (1986) .
For other contaminants for which no applicable or relevantstandards exist, acceptable concentrations in environmental mediawill be developed based on Acceptable Daily Intakes (fornon-carcinogens) and on target risk levels (for carcinogens) . Theprimary sources of toxicologic data used in this analysis will beAppendix C of the Superfund Public Health Evaluation Manual (1986) ,EPA's Health Effects Analyses (HEAs) and EPA's Water and AirQuality Criteria Documents. The methods used to characterize risksfor the site, along with the level of detail and documentationassociated with the risk analysis, will be consistent with EPA'sEndangerment Assessment Handbook (1985) .
A copy of the public health assessment will be submitted to EPA fortransmittal to ATSDR for its review and use.
4.6.2 Environmental Assessment
An environmental assessment will be performed for the NiagaraCounty Refuse Site with the objective to ascertain existing andpotential future environmental impact of the site if no remedialaction is taken. The result of this analysis will then be used inthe development and evaluation of remedial alternatives.
A primary methodology to be utilized in assessing aquaticenvironmental impacts is a comparison of site water concentrationlevels to water quality criteria for the protection of aquaticlife. These aquatic life criteria, based primarily on toxicity,are listed within US EPA Ambient Water Quality Criteria Documents(US EPA, 1980) . Interpretation of these data will be computed byqualitative and (if necessary) quantitative observation of the
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habitat and biota of the Niagara River and Black Creek,are listed within US EPA Ambient Water Quality Criteria Documents(US EPA, 1980). Interpretation of these data will be computed byqualitative and (if necessary) quantitative observation of thehabitat and biota of the Niagara River and Black Creek.
To evaluate terrestrial environmental impacts, published toxicityinformation concerning the various chemical constituents onterrestrial organisms will be considered in tandem withobservations and inventories of biota made by a terrestrialecologist. If warranted, concentrations of numerous on-sitecontaminated matrices will be extrapolated to probable contaminantconcentrations at or within the organism (i.e., extrapolationallowing for dilution, organism uptake, bioaccumulation, etc.).Whenever possible, the level of detail and documentation associatedwith the environmental evaluation will be consistent with EPA'sEndangerment Assessment Handbook (1985). It is not expected that aNatural Resources Damage Assessment will be required for theNiagara County Refuse Site.
The preliminary scoping of remedial alternatives (Section 3.1.3)considered certain developed and innovative technologies fortreatment of the contaminated soil and groundwater at the site.Assuming that some of these technologies meet remedial responseobjectives and that they pass the initial screening, treatabilitystudies (laboratory or field) would be needed to evaluate theirapplicability to the site and to develop cost information foreconomical comparison among the technologies.
However, in this Work Plan, no specific treatability studies areproposed because the extent of contamination at the site isunknown. In addition, the ambient groundwater quality at the siteis not known. Conducting treatability studies for certaintechnologies can be costly. Therefore, treatability studies shouldnot be conducted for those technologies which cannot pass theinitial screening.
It is proposed that Ebasco will meet with EPA to discuss the needand suggested scope of the treatability studies to be performedwhen the preliminary analytical results become available. Thesestudies will be performed in order to confirm the applicability ofsource control technologies discusssed in Section 3.1.3. WithEPA's concurrence, Ebasco will submit, in twenty working days, awritten proposal (including scope of work, budget and schedule) forthe treatability studies to EPA for approval. During that time,Ebasco will also commence preparing and issuing necessary bidpackages for selecting qualified testing facilities to perform thetreatability tests. The subcontracts will not be awarded until EPAhas approved Ebasco's proposal.
A budget provision has been made for groundwater laboratory
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treatability studies (air stripping and carbon absorptionsystems). Ebasco is of the opinion (based on available data) thatgroundwater treatment technology could become a potential remedialalternative. No provision in the budget for soil treatabilitystudies has been made as the NCR site is a complex landfill and thesoil treatment technology may not be feasible. The scope oftreatability studies will be further discussed with the EPA at theconclusion of RI Phase I activities.
4.8 TASK 8 - REMEDIAL INVESTIGATION REPORT
The RI report will summarize the data collected and the conclusionsdrawn from the investigative areas, and will include the followinginformation:
o an updated site description;o site maps;o field investigation results;o results of the geohydrological modeling effort;o chemical analyses results;o results of the risk assessment; ando treatability study/bench scale testing results (if any).
Project status meetings are scheduled as part of Task 8 followingEPA's review of the RI report.
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5.0 TASK PLAN FOR FEASIBILITY STUDY
Based on the results of the Remedial Investigation, a feasibilitystudy will be conducted for the NCR site. This study will consistof four tasks:
In addition to these tasks, Task 2 - Community Relations, will becontinued during the FS. Community relations activities will beextended through the public comment period and development of theRI/FS report and Record of Decision (ROD), and into the post RI/FSsupport task if required. Throughout the FS process, referencesincluding the following will be used: EPA Guidance on FeasibilityStudies Under CERCLA (1985),The National Oil and HazardousSubstance Pollution Contingency Plan: Final Rule, NCP (1985),Remedial Action Costing Procedure Manual (JRB Associates, 1983),Interim Guidance on Superfund Selection of Remedy (J.W. Porter,1985), and REM III Program Technical Support Guidelines (Ebasco,1986), as well as technology-specific guidance and evaluationdocuments as appropriate.
The overall objective of the NCR site FS is to develop and evaluateremedial alternatives that allow the EPA to select a remedialaction that is:
o protective of human health and the environment;o cost effective;o in accordance with SARA; ando in accordance, to the extent practicable, with the NCP.
5.1 TASK 9 - REMEDIAL ALTERNATIVE SCREENING
This step in the RI/FS process is conducted following the RiskAssessment (Task 6) and the Data Validation, Reduction, andEvaluation effort (Tasks 4 and 5). The objective of this task isto refine the range of response actions developed during thescoping process (Task 1). This task will employ the data collectedin Phases I and II of the Site Investigation (Task 3), and theresults of the Risk Assessment (Task 6). The subtasks comprisingTask 9 will accomplish the following objectives:
o development of remedial response objectives and generalresponse actions;
o identification of applicable technologies and assembly ofalternatives;
o screening of remedial technologies/alternatives; and
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o scoping of the Phase II field investigation, if required.
The screening of remedial alternatives will be partially completedprior to scoping the Phase II field investigation, if needed. Inthis way, data needed to complete the development of remedialalternatives can be collected during Phase II if gaps exist.
5.1.1 Development of Remedial Response Objectivesand Response Actions
Based on the data collected in the RI, the remedial responseobjectives will be developed more fully. Prior to the developmentof these objectives, significant site problems and contaminantpathways will be identified. Considering these problems andpathways, the remedial response objectives which should eliminateor minimize substantial risks to public health and the environmentwill be developed further, including a refinement of the ARAR'swith consideration given to site-specific conditions. Based on theresponse objectives, general response actions will be delineated toaddress each of the site problem areas. These response actionswill form the foundation for the technology screening.
5.1.2 Identification/Screening of Applicable Technologies
Based on the remedial response objectives and general responseactions, a list of applicable technologies will be identified andscreened. During the identification of these technologies, theneed for source control measures will be assessed. If needed,technologies which will achieve these source control measures willbe identified in addition to technologies necessary for themanagement of migration from the site.
The following elimination criteria will be considered for thetechnology screening process:
o difficulties in implementation;
o unproven technologies;
o cannot achieve remedial objectives within a desireable period;and
o severe limitations for a given set of waste- and site-specificconditions.
5.1.3 Development of Alternatives
After potential remedial technologies have been screened andchosen, operable units will be defined for each site conditionrequiring remediation. Each operable unit should meet at least oneresponse objective. After these operable units have been compiled,any appropriate phasing of them will be considered. Depending on
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site conditions and the adequacy of RI results, a phased approachmay be desirable.
After operable units have been defined, remedial alternatives willbe identified. Each remedial alternative will be an overall siteremedy. The no action alternative will be considered as a baselineagainst which the other alternatives can be evaluated.Alternatives which can be classified in each of the classes ofalternatives required by the NCP (see RI/FS Objectives, subsection3.1) will be identified to the extent possible.
SARA states that, to the maximum extent practicable, remedialactions that utilize permanent solutions and alternative treatmenttechnologies or resource recovery technologies must be selected.Therefore, remedial actions that use these technologies will beconsidered. In accordance with both SARA and the NCP, alternativedeveloped will include, but not be limited to, treatment,containment, and no-action technologies. To the extent possible,treatment options will range from alternatives that eliminate theneed for long term management at the site to alternatives involvingtreatment that would reduce toxicity, mobility, and volume as aprincipal goal.
5.1.4 Screening of Remedial Alternatives
The lists of and alternatives discussed previously will bescreened. The objective of this effort is to eliminate fromfurther consideration any alternatives that have undesirableresults regarding cost, unacceptable engineering practices, or lackeffectiveness as described in the NCP Section 300.68 (g). Theseelimination criteria are as follows:
o alternatives which have significant adverse impact duringimplementation;
o alternatives which do not adequately protect the environmentand public health according to the risk assessment and ARAR's;
o alternatives that are technically inapplicable; and
o alternatives which have costs an order of magnitude greaterthan other alternatives but do not provide greaterenvironmental or public health benefits, reliability, or amore permanent solution. Costs will not be used todiscriminate among treatment technologies and non-treatmenttechnologies.
Reasons for elimination of any alternatives at this stage will bedocumented in the FS report.
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5.1.5 Scoping of Remedial Investigation Phase II/Memorandumfor Technical Direction
This out of scope effort, if required, will be determined by theoutcome of Tasks 3 through 6 and the results of the screening ofalternatives. The anticipated scope of the Phase II siteinvestigation will be similar to but simpler than that presented insubsection 4.3 of this Work Plan. This phase, if necessary, willconsist of additional work to address data gaps identified in PhaseI. If it is determined that a Phase II site investigation orlaboratory/bench scale studies are required, a Memorandum forTechnical Direction (MTD) will be prepared. The MTD will be usedto document completion of the first phase of the RI and willprovide a mechanism for changing the authorized ceiling withrespect to the obligated funding level for the work assignment (ifnecessary). Accompanying the MTD will be a revision to the WorkPlan documenting the scoping, scheduling, and budgetingrequirements of the proposed subsequent phase.
5.2 TASK 10 - REMEDIAL ALTERNATIVES EVALUATION
Remedial alternatives that pass the initial screening process (seeTask 9) will be further evaluated and compared in accordance withthe NCP, as required by CERCLA. As part of the FS process, SARArequires that waste, site, and technical/operational limitations,as well as the ability of each alternative to meet federal andstate ARAR's, be considered. Factors that will receive specialconsideration during the detailed evaluation of remedialalternatives include:
o long-term uncertainties of land disposal;
o ability to achieve a permanent and significant reduction inthe toxicity, volume, or mobility of the waste;
o goals and requirements of the Solid Waste Disposal Act;
o persistence, toxicity, and mobility of contaminants at thesite;
o short- and long-term potential for adverse human healtheffects;
o costs;
o implementability;
o community acceptance;
o state acceptance;
o potential for future remedial action costs if the remedyfails; and
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o potential threat to human health and the environment from theexcavation, transportation, and redisposal or containment ofhazardous substances, pollutants, or contaminants.
Within this phase, each remedial alternative will be evaluatedbased on effectiveness, implementability, and cost. In the FSreport, each alternative will be summarized and compared;advantages and disadvantages will be clearly stated.
5.2.1 Effectiveness
The effectiveness of an alternative is determined by evaluating (1)public health impacts, (2) environmental impacts, and (3) theattainment of ARAR's.
Public Health Evaluation. In the PHE, Ebasco will compare thepotential public health risks of each alternative to the baselinepublic health risks predicted in the RI Risk Assessment.
Baseline site conditions represent the no-action alternative.Ebasco will evaluate each alternative to determine if it willminimize or prevent exposures and risks existent under no-actionconditions and reduce exposures below ARAR's. When appropriate,Ebasco will identify the potential human exposure pathwaysassociated with the alternative, as well as potential healtheffects that could result from failure of the alternative. Ebascowill discuss potential short-term and long-term health risks(including risks associated with excavation, transportation,disposal, or containment) associated with implementation of thealternative, and identify appropriate management practices toeliminate or reduce these risks.
Environmental Impacts Evaluation. Potential environmental impactsfrom each alternative will be compared with current (baseline)conditions described in the Risk Assessment. Beneficial effects ofeach alternative will be evaluated in terms of containment levelsexpected in environmental media during and after implementation ofthe remedial alternative; improvement in the biological environmentas a result of decreased contamination levels; and decrease inhuman exposure potential. Adverse effects associated withconstruction and operation of each alternative will also bedescribed in this discussion.
Attainment of ARAR/s. ARAR's will be considered during thedetailed evaluation of alternatives. In this task, action-specificARAR's will be outlined for each alternative. During the detailedanalysis step, each of the ARAR's in the three categories (i.e.,contaminant-specific, location-specific, and action-specific) willbe summarized. Bench-scale test results will provide specificinformation on an alternative's ability to meet dischargerequirement ARAR's.
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5.2.2 Implementation
Each alternative will be evaluated with regard to its potential forimplementation. The following factors will be considered duringthis evaluation:
o Technical Feasibility - Is the technology appropriate to site-and waste-specific characteristics?
o Demonstrated Performance - How effective was the alternativeat other sites or during bench-scale testing?
o Support Requirements - What other equipment/ resources/activities would be needed to make this alternativesuccessful?
o Availability - Is the equipment currently available?
o Installation Requirements - How long will it take to installthe necessary equipment; that is, what is the constructabilitywith respect to site conditions?
o Time - How long will it take to implement the technology, howlong will it take to realize beneficial effects from theremedial action, and how long must the system remain inoperation?
o Safety - What are the short- and long-term threats to on-siteworkers and nearby communities?
o Maintenance - What are the expected monitoring and maintenanceneeds?
o Monitoring, Permits, Legal Constraints - Do additionalmonitoring, permits, or other constraints apply to thisalternative?
The long-term uncertainties and administrative requirements of eachalternative will be highlighted.
5.2.3 Cost Evaluation
For each alternative the cost will be estimated within a range of-30 percent to +50 percent. The cost analysis will includeseparate evaluation of capital and operation and maintenance costs.Capital costs will consist of short-term installation costs such asengineering/design fees, materials and equipment, construction, andoff-site treatment or disposal. Operation and maintenance costswill consist of long-term costs associated with operating andmonitoring the remedial actions such as a groundwater extractionand treatment plant or groundwater monitoring programs. Costs willbe determined based on the anticipated time necessary for thealternative to achieve cleanup criteria.
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A discount rate of 10 percent will be assumed for all present worthcalculations. Cost estimates will be prepared using data fromEbasco's project files, the current EPA Remedial Action CostingProcedures Manual (JRB, 1984), USEPA technical reports, andquotations from equipment vendors. Equipment replacement costswill be included when the required performance period exceedsequipment design life.
5.3 TASK 11 - FEASIBILITY STUDY REPORT
Task 11 will consist of the following subtasks:
o summarize each alternative in terms of detailed technology,reliability, implementability, public health, environment,institutional requirements, and cost evaluation;
o compare the remedial alternatives; and
o prepare the FS report.
The FS report will include an executive summary, an introduction,and a description of the screening and evaluation process. The FSreport will be presented in the format shown in Table 5-1. TheRI/FS Report will include a summary of the detailed technical andcost evaluations and a comparative evaluation of the remedialalternatives. This summary will be presented as table matrices.Backup information and calculations will be included as appendices.
The FS report will be incorporated into an overall RI/FS report.This overall report will include the revised draft RI report, thePublic Health Evaluation, and the Environmental Assessmentincorporating EPA comments. This report will be produced in draftand final forms. If Task 12 is requested as a component of theRI/FS, the final FS will include a responsiveness summary and theselected remedy.
To inform the EPA of progress and results, Technical Memoranda willbe issued at the following points during the FS:
o completion of development of remedial response objectives;
o completion of development of alternatives; and
o completion of initial screening of alternatives.
5.4 TASK 12 - POST RI/FS SUPPORT
Ebasco will provide support to EPA for requested assistance inactivities which occur after the NCR RI/FS is completed. The scopeand budget estimated for this effort, if needed, will be determinedin meetings with EPA after the RI/FS report is approved andfollow-up actions are identified. Such support may include
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community relations, assistance in preparing the Record of Decisionor Responsiveness Summary, and assistance to the U.S. Army Corps ofEngineers or other parties involved in the remedial design/remedialaction.
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TABLE 5-1
FEASIBILITY STUDY REPORT OUTLINENCR RI/FS WORK PLAN
Development of Response Objectives
Site background informationNature and extent of problemObjectives of remedial action
Screening of Remedial Action Technologies
Technical criteriaRemedial action alternatives developedEnvironmental and public health criteriaOther screening criteriaCost criteria
Remedial Action Alternatives Description
Alternative 1 (No Action)Alternative 2Alternative N
Analysis of Remedial Action Alternatives
Effectiveness
. Protectiveness - Environmental Evaluation- Institutional Requirements/ ARAR 's- Public Health Evaluation
. Reduction of Toxicity, Mobility and Volume
Implementability
. Technical Feasibility
. Administrative Feasibility
. Availability
Cost
. Cost Analysis
Summary of Alternatives
Recommended Remedial Action
Responsiveness Summary (in final report only)
References
Appendices
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6.0 TASK PLAN FOR COMMUNITY RELATIONS (Continuation of Task 2)
It has been decided by EPA that the Community RelationsImplementation (CRI) will be handled directly by EPA. The proposedscope of work reflects this decision. Ebasco's involvement in theCommunity Relations Program is listed below:
o Ebasco will finalize the Community Relations Plan (CRP).
o Any additional future work after CRP is finalized will beperformed directly by EPA.
o As a contingency, Ebasco has provided for 50 Level Of Effort(LOE) hours plus 10 secretarial hours. This amount will notbe spent without specific permission by EPA.
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7.0 PROJECT MANAGEMENT APPROACH
7.1 ORGANIZATION AND APPROACH
The proposed project organization is shown on Figure 7-1. TheRegional Manager (RM), Dr. Dev R. Sachdev is responsible for thequality of all REM III work performed in Regional II. He monitorsthe progress of each work assignment to ensure adequate resourcesare available and that major problems are prevented or minimized.Dr. Sachdev implements the program standard of quality for work inthe region and makes sure that the Site Manager meets thatstandard. The RM's review concentrates on the technical quality,schedule, and cost for all work assignments.
The Site Manager (SM), Mr. Kris Ramachandra, has primaryresponsibility and authority for implementing and executing theRI/FS. Supporting the SM are the Field Operations Leader (FOL), RILeader, FS Leader, and other staff. The FOL is responsible foron-site management for the duration of all activities at the site.The RI Leader is responsible for the RI and for the preparation ofthe RI Report. The FS Leader is responsible for the FS and for thepreparation of the FS Report.
The task numbering system for the RI/FS effort is a continuation ofthe task numbering system used for the initial tasks and activitiesdescribed in the Work Plan. The Tasks are numbered as follows:
Task 1 Project PlanningTask 2 Community RelationsTask 3 Field InvestigationTask 4 Sample Analyses/ValidationTask 5 Data EvaluationTask 6 Risk AssessmentTask 7 Treatability Study/Pilot TestingTask 8 Preparation of Remedial Investigation ReportTask 9 Remedial Alternatives ScreeningTask 10 Detailed Evaluation of Remedial AlternativesTask 11 Preparation of Feasibility Study ReportTask 12 Post RI/FS Support
The task list, in addition to a project schedule and budget,comprises the baseline plans which form an integrated managementinformation system against which work assignment progress can bemeasured. The baseline plans are a precise description of how theWork Assignment will be executed in terms of work scope, schedule,staffing and cost. The project schedule and the detailed costestimate are presented in Sections 7.3 and 7.4, respectively.
7.2 QUALITY ASSURANCE AND DATA MANAGEMENT
The site-specific quality assurance requirements will be inaccordance with the Quality Assurance Project Plan for the REM III
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NIAGARA COUNTY REFUSE SITEPROJECT ORGANIZATION
REGIONAL MANAGER
D. SACHDEV ZPMO
SITE MANAGER
K. RAMACHANDRA
COMMUNITYRELATIONSLEADER
G. ZANZALARI
SUBCONTRACTORS
• WELL DRILINQ• SURVEYING
• TREATABILITYTESTING LAB
• SOIL TESTING
FIELDOPERATIONSLEADER/GEOLOGIST
G. ROGERS
• GEOLOGIST• CHEMIST
• HEALTH ftSAFETY
QA MANAGER
S. MISSAILtDIS
HEALTH &SAFETYOFFICER
L. BIRNBAUM
REMEDIALINVESTIGATIONLEADER
P. HANSEN
FEASIBILITYSTUDYLEADER
K.RAMACHANDRA/W.S. LEE
HYDROGEOLOGIST (G. MAURATH)RISK ASSES. SPECIALIST (M. MOESE)ENVIRONMENTAL / CHEMICAL ENGR.
• CHEMIST
• GEOLOGIST
• MODELER
I.I
GEOTECH. ENGR.
• ENVIRON. ENGR.II • REGULATORY
SPECIALIST
ANALYTICALCHEMISTRYCOORDINATOR
J. GABPY
100FIGURE 7-1
Program, as approved by EPA, and in accordance with the BrossmanGuidance.
Data Management aspects of the program pertain to controlling andfiling documents. Ebasco has developed a program filing system(Administrative Guideline Number PA-5) that conforms to therequirements of the Environmental Protection Agency and the REM IIIProgram to ensure that the documents are properly stored and filed.This guideline will be implemented to control and file alldocuments associated with the site's RI/FS. The system includesdocument receipt control procedures, a file review and inspectionsystem, and security measures.
7.3 PROJECT SCHEDULE
The project schedule and critical path are shown on Figure 7-2 (inpocket). This figure also shows the tasks and activities for theRI/FS. The critical path has been highlighted and key milestonedates have been identified.
The schedule assumes ready access to the site and that surroundingproperty owners (for the drilling of monitoring wells andboreholes, test pits, geophysical surveys and the collection ofsamples) will not delay access to the site. The schedule alsoassumes that the health and safety personnel protectiverequirements are Level D and C dependent on the type of fieldactivities. The HASP gives details of the requirements.
The schedule for the RI/FS is based on the conditions discussed inthe Work Plan. If off-site migration of the contaminants is foundduring Phase I investigations, the optional item of groundwatermodeling will be performed during Phase I. During Phase II (notcovered by this work plan) additional field investigations(off-site) based on groundwater modeling results, laboratoryananlysis, data evaluation, risk assessment and RI/FS reportspreparation will be performed. This work is expected to take about8 months and is out of scope of the present work plan. If Phase Istudy indicates need for ground water treatment, the optional itemof treatability studies will also be performed.
7.4 ESTIMATED PROJECT COSTS
The estimated cost for the site RI/FS is $1,135,085. These costsdo not include the cost for any Phase II work or for the CLPanalyses. These costs include all workhours, other direct costsand subcontract costs for the initial tasks and the tasks describedin this Work Plan. The estimated costs for the optional items areas follows:
The cost estimate is based on the assumption that health and safetypersonnel protective equipment requirements are Level D and C. Ifthe level of protection has to be upgraded, increased costs will beincurred. Costs associated with the implementation of theCommunity Relations Plan have been included in the amount of$16,791.
Tabulations of the estimated hours for the RI/FS by labor categoryapportioned by task are shown on Table 7-1. The estimated dollarcosts for the RI/FS broken down by task as well as by labor,travel, equipment, computers, reports, miscellaneous andsubcontractors are shown on Table 7-2. These tables are providedunder separate cover with the Optional Form 60.
3005^8102
NIAGARA COUNTY REFUSE SITE
LIST OF REFERENCES
LIST OF REFERENCES
Camp Dresser McKee Inc. and Others, January 1983, Remedial ActionMaster Plan for Niagara County Refuse Disposal Hazardous Waste Site- Niagara County, New York, United States Environmental ProtectionAgency.
DEC, 1985, Community Right to Know - Vol. Ill - Past HazardousWaste Disposal Practices, New York State Department ofEnvironmental Conservation.
EAST, 1987, Engineering Investigations at Inactive Hazardous WasteSites - Phase II Investigations, Niagara County Refuse Disposal,Middletown, New York.
Ebasco, 1986, Technical Support Guidelines, REM III Program.
EPA, October 24, 1980, Analytical Results - Niagara County Refuse,Wheatfield, NY, U.S. Environmental Protection Agency InternalMemorandum.
EPA, 1985, Guidance on Feasibility Studies under CERCLA, U.S.Environmental Protection Agency, Office of Emergency and RemedialResponse, Washington, D.C.
EPA, October 1985, Handbook - Remedial Action at Wastes DisposalSites (Revised), U.S. Environmental Protection Agency, Office ofSolid Waste and Emergency Remedial Response, Washington, D.C.
EPA, 1985, National Oil and Hazardous Substances PollutionContingency Plan; Final Rule, 40 Federal Register Part 300, U.S.Environmental Protection Agency, Office of Emergency RemedialResponse, Washington, D.C.
Geologic Testing Consultants Ltd., January 1983, Love CanalHydrogeologic Evaluation, Ontario Ministry of the Environment.
B.C. Jordan Co., Groundwater Flow and Geologic Profile of LoveCanal Area.
Krehbiel-Guay-Rugg-Hall Engineers - Surveyors, October 1973,Operating Plan for Wheatfield Refuse Disposal site, Niagara CountyRefuse Disposal District.
NUS Corp., December 1, 1983, Evaluation of Analytical Chemical Datafrom Niagara County Refuse, U.S. Environmental Protection Agency.
NUS Corp., July 1983, Community Relations Plan for Niagara CountyRefuse Site, U.S. Environmental Protection Agency.
RECRA Reseach, January 1983, Environmental Quality Assessment,Summit Park Development Corporation, New Yok State Department ofEnvironmental Conservation.
