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SDMS Document m MALCOLM PIRNIE K; AINBEp«;NpeNT-;ENV|RONMENTAL ,*•»:';' •ENGINEERS, SCIENTISTS 104362 rAND CONSULTANTS Januarv j 2007 Ms. Farnaz Saghafi United Slates Environmental Protection Agency (USEPA), Region 11 290 Broadway New York. NY 10007-1 866 Ke: CLTL OU-2 Bridgepon, N.i - Work Plan for Supplemental Remedial Investigation Related .Activities for OU-2 Areas 6, 7 and 8 Chemical Leaman Tank Lines, Inc. Bridgeport, New jersey Dear N4s. Saghafi: .As discussed during our project scoping meeting on November 7, 2006, N4alcolm Pirnie, Inc. (N4alcolm Pirnie) proposes the following activities to support completion of the Remedial Investigation (Rf) for CLTL OU-2. These activities are intended to fully characterize and delineate soil related impacts ai Areas 6. 7 and 8 (Figure 1). Data from these sampling activities will be used to complete the OU-2 Rl, identify and evaluate potentially applicable remedial technologies, and support the OU-2 Risk .Assessment and Feasibility Study (FS). For .Area 6, we ie\'iewed the historical sampling data provided by Environ to determine if the area had been adequately characterized, and identity the data gaps that needed to be filled though additional sampling. For Area 7, we essentially expanded upon the PRP's previously-approved work plan for characterization of this area, which will be completed once the PRP's pipe removal activities had occurred. And for Area 8, we developed a delineation approach based on the observations made during OU-1 construction oversight activities and the results of the waste characterization sample analysis provided by the PRP. Hie following paragraphs provide the specific activities to be performed in each of the areas of concern. 300237

Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

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Page 1: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

SDMS Document

m MALCOLM

PIRNIE K; AINBEp«;NpeNT-;ENV|RONMENTAL

,*•»:'; ' •ENGINEERS, SCIENTISTS

104362

rAND CONSULTANTS

Januarv j 2007

Ms. Farnaz Saghafi United Slates Environmental Protection Agency (USEPA), Region 11 290 Broadway New York. NY 10007-1 866

Ke: CLTL OU-2 Bridgepon, N.i - Work Plan for Supplemental Remedial Investigation Related .Activities for OU-2 Areas 6, 7 and 8 Chemical Leaman Tank Lines, Inc. Bridgeport, New jersey

Dear N4s. Saghafi:

.As discussed during our project scoping meeting on November 7, 2006, N4alcolm Pirnie, Inc. (N4alcolm Pirnie) proposes the following activities to support completion of the Remedial Investigation (Rf) for CLTL OU-2. These activities are intended to fully characterize and delineate soil related impacts ai Areas 6. 7 and 8 (Figure 1). Data from these sampling activities will be used to complete the OU-2 Rl, identify and evaluate potentially applicable remedial technologies, and support the OU-2 Risk .Assessment and Feasibility Study (FS).

For .Area 6, we ie\'iewed the historical sampling data provided by Environ to determine if the area had been adequately characterized, and identity the data gaps that needed to be filled though additional sampling. For Area 7, we essentially expanded upon the PRP's previously-approved work plan for characterization of this area, which will be completed once the PRP's pipe removal activities had occurred. And for Area 8, we developed a delineation approach based on the observations made during OU-1 construction oversight activities and the results of the waste characterization sample analysis provided by the PRP.

Hie following paragraphs provide the specific activities to be performed in each of the areas of concern.

300237

Page 2: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

Ms. Farnaz Saghatl USEPA, Region II

INDEPENDENT ENVIRONMENTAL | . , , „ , - , „ , ^ ^ n A - ^

ENGINEERS, SCIENTISTS

AND CONSULTANTS

'ane .

Area 6

Suininary of Exislins Soil Data N4alcolm Pirnie has reviewed soil boring logs and soil analytical data from the Area 6 sampling events conducted on behalf of QDl by Environ International Cori^oration (Environ) in October 2005 and iVlay 2006. Environ's soil quality data suggests that the areal extent of Area 6 soil impacts has been defined, except in the vicinity of boring W9-4A , Analytical data from boring W9-4A samples SBOl (depth 2.5 to 3 feet below ground surface (bgs)), and SB02 (depth 8 to 8.5 feet bgs), revealed TCE concentrations ol"470 mg/kg and 560 mg/kg. respectively. .As such, the extent of soil impacts north of this boring, and possibly beneath the adjacent loading pad. have noi been defined. .Also, the les'els of TCE and related constituents in soil boring \V-9 (e.y.. 990 mg/kg TCE at 3 to 3.5 i'eet bgs, 590 mg/kg TCE at 5.5 to 6 feet bgs, and 950 mg.'kg ai 10-10.5 J'eel bgs), as well as surrounding Area 6 soil constituent levels, indications of a smear zone, and other aspects of .Area 6 geology suggest that a temporary monitoring well is necessary to evaluate the possible presence of LNAPL and/or DNAPL in the vicinity of boring W-9. Furthermore, based on the discovery of high levels of TCE (e.g., 6,200 mg/kg) in shallow (i.e., 1 10 3 feet bgs) vadose zone soils in borings W8-8B, -8C, -8D, -9B, -9C and -90, as well as the presence of a localized and discontinuous clay bed found in all but W8-9D, a second temporary monitoring well is reconmiended for the area of boring W8-9A to investigate potential groundwater impacts in this portion of Area 6 The proposed locations of the soil boring and monitoring wells described above are shown on Figure 2.

Proposed A (Id it ion a IA ctivities Based on these identified data gaps, we recommend the installation of at least one soil boring, and the installation and sampling of two shallow groundwater moniioritig wells in Area 6. 'fhese activities will complete the delineation of .Area 6 soil impacts, provide data on the extent of .Area 6 groundwater impacts (e.g., dissolved phase and possible ENAPL./DNAPL impacts), and uhimately support the evaluafion of Area 6 remedial technologies. Details are provided below:

• Soil Boring - To complete the delineation of soil impact in Area 6, one boring will be installed by Geoprobe between W9-4A and the adjacent loading pad. The boring will terminate at the top of a taiv'white clay layer (i.e., depth approximately 13 feet bgs near \A''9-4.A) which ajipears lo underlie most of .Area 6, In the event the proposed boring reveals additional impacts, provisions will be made to install up to two more borings, possibly angle-drilled at the northern and eastern sides of the loading pad (to limit the need for subsequent Area 6 delineation efforts).

Soil samples will be collected ibr laboratory analysis for volatile organic compounds (VOCs) via EP.A K4ethod 8260B. Selection of depth intervals for analysis will be collected based on field screening results and photoionization detector (PID) readings.

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Page 3: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

MAicoyvi PIRNIE

INDEPENDENT ENVIRONMENTAL'

ENGINEERS, SCIENTISTS

AND CONSULTANTS ,

Ms. Farnaz Sayliat'i USEPA, Region II January 3, 2007 Paie 3

Quality assurance/quality control (( ,).A/QC) samples will be collected in accordance with the Quality .Assurance Project Plan (QAPP). Like the previous borings installed by Environ, it is anticipated that a maximum of three samples will be collected from each boring. Saturated soil samples will not be collected for laboratory analysis, unless field screening results suggest a need to ex'aluate smear zone impacts below the water table

• Monitoring Wells - To investigate the potential presence of LN.APL and.for DN.APL and assess current groundwater conditions in Area 6, we propose the installafion and sampling of one monitoring well in the vicinity of boring W-9, and a second monitoring well near the location of boring W8-9A (see Figure 1). Both wells should be installed to the top of the tan/white clay layer described above (i.e., approximately 13 feet bgs near boring W-9 and 15 feel bgs near boring W8-9A), and include well screens Hi leet in length. .As such, the wells will be designed to detect residual and/or mobile DN.APL (if present) and/or fioaiing LNAPL. To streamline installation, the temporary \vells will be installed using a hollow stem augur (l-lSA)-capable Geoprobe rig. Since the wells will be used only lo assess groundwater quality and the presence of LNAPL and DN.API.., we are proposing the installation of fiush-mounied two-inch schedule 40 PVC wells. 'Fhese wells are intended to serve only as temporary monitoring points to support lo Rl/FS process. These temporary wells will be abandoned prior to implementation of any remedial activities in Area 6, unless otherwise determined to be beneficial for remedial aciivities.

• Field Screening/Logging - All soil borings and monitoring well borings will be logged according to standard logging procedures and will include the collection of photoionization detector (PID) readings at six-inch intervals. Collection of soil samples at 2-foot intervals for headspace analysis will also be conducted. Depth intervals displaying the highesl PID readings will be subjected to DNAPL screening using USEP.A-approved dye and ultraviolet light DN.APL field screening procedures previously employed by Environ.

• Disposal ol' investigation dcriAcd waste (IDW) - Soil cuttings, development water and subsequent monitoring well sampling purge water will be drummed and stored on-Site in accordance with existing USEPA-approved IDW procedures. I'or subsequent waste characterization and disposal by the PRP.

Note that the Geoprobe-based procedures described above will also be used to delineate soil impacts in and around OU-2 .Areas 7 and 8. Jn the event soil impacts that extend to shallow groundwater are encountered in either oi'these areas, we propose the installation of additional ilush-mounied two-inch PVC monitoring wells by Geoprobe as needed lo complete the assessment of OU-2 impacts wiih one Geoprobe mobilization.

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Page 4: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

MALCXXJS4 PIRNIE

INDEPENDENT ENVIRONMENTAL

ENGINEERS, SCIENTISTS

AND CONSULTANTS

Ms. j-arnaz Saghafi USEPA, Region II .Ianuar-y3,2b07 Paee 4

Area 7

Backsround The Area 7 investigation activifies are focused along the two abandoned wash lines (PVC and steel) adjacent to monitoring wells EW-8S and EW-81. The w-'ash lines were discovered by Shaw-Environmental (Shaw) during remedial construction activities; these incidents are summarized below:

• On .lanuary 9. 2006 Shaw uncovered an abandoned PVC pipe. Based on visual observations (stained soils) and PID readings (maximum of 175 ppm near the wash line), visibly stained soils were removed and staged for off-site disposal.

• On jVlarch 1, 2006, Shaw uncovered a sieel pipe and screenedjidjacent soils using a PID. .According to Shaw, the pipe location was consistent with a pipe encountered during building subgrade preparation. The soils were screened for evidence of impacts and no soil staining or PID detections were reported.

• On N4arch 8, 2006, Shaw discovered a PVC pipe in the same vicinity as the steel pipe and noted that it was similar to the pipe discovered on .lanuary 9. No soil staining was reported and a maximum PID detection of 2 ppm was reported from the trench sidewalks.

Based on a review of the former building layoui and site observations, the two former wash lines are assumed to run parallel to each other between the waste drum storage building and the groundwater treatment building.

Proposed A dditional A ctivities Based on the approved Technical .Approach Addressing Underline Pipeline at EW-8S and EW-81 prepared by Shaw Environmental and dated April 7, 2006, soil sampling will be completed on twenty (20) foot spacing along each of the abandoned wash lines (see Figure 3). A total of approximately thirty-two (32) post-excavation soil samples will be collected at, or just below, the pipe inverts at a depth of approximately four feet below ground surface. The sampling will be coordinated with the QDI pipe removal contractor. The sampling will progress as the QDl contractor trenches and removes the steel and PVC pipes, Soil samples will be screened using a PID and submitted for laboratory analysis for VOCs via EPA N4ethod 8260B, semi volatile organic compounds (SVOCs) via EPA Method 8270C, and 'FAL metals via EPA Method 6010; requisite Q.A.'QC samples will be collected in accordance with the QAPP. Depth intervals displaying the highest PID readings will be subjected to DNAPL screening using USEPA-approved dye and ultraviolet light DN.APL field screening procedures employed previously by Environ. We have assumed that the water table will not be encountered at the shallow depths anticipated for the trench, and that the portion of the lines beneath the groundwater treatment building will be properly abandoned in-place by the QDl pipe removal contractor. Therefore, no samples will be collected from beneath the groundwater treatment building. In the event the QD! contractor's irenchmg activities reveal additional .soil impacis. provisions will be made to collect

300240

Page 5: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

IVWiCOUS4 PIRNIE

jJi'lNDERENOENT ENVIRONMENTAL

!• ^ V iENG!NEERS.:SC|ENTISTS • ' •

P;' '• '.;':'h ANDXOHSULTANTi " ' . - ' r

Ms. Farnaz Saghafi USEPA, Region II January 3, 2007 Pasie 5

additional post-excavanon and/or soil delineation soil samples to complete the delineation. Borings will be extended outward (-10 ft. intervals) from the observed soil impact area until a "clean zone'"' is found, as indicated by visual observations and field screening. Samples will be collected fi'om the borings as needed to horizontally and vertically delineate the soil impact.

Area 8

Backt^roniid On N4arch 16, 2006 odorous soils were discovered near the Shaw office trailer during the trenching for the East-West trending pipeline trench, Shaw reported a small impacted area consisting of steel shavings and discolored soils in die trench sidewalk this was the only area identified along the trench alignment,. .Approximately five cubic yards of visibly stained soils were removed and staged for off-site disposal. .According to Shaw, additional material could not be removed from the side of the trench on CONRAlL''s property due to the potential for destabilizing the soil under Shaw's office trailer.

Proposed A dditional Activities In an initial attempt to delineate .Area 8, four soil borings will initially be installed in the area of the former excavation and one from liie soils below the former excavation. If initial results from the soil borings necessitate additional sampling, impacts will be evaluated and soils will be horizontally delineated at a minimum of ten feet between soil borings. Details are provided below:

• Geophysical Survey - Prior to initialing the boring activities in .Area 8, the area will be surveyed using electromagnetic (e.g., E.M-61) and ground peneiraling radar (GPR) geophysical methods to identify potential buried pipes or other obstructions.

• Soil Borings - To complete the delineation of soil impacts, five borings will be installed by Geoprobe in Area 8 at the locations shown in Figure 4. One boring will be installed in the center of the odorous soil area and four borings will be placed at the perimeter. The center boring will be used to vertically delineate impacts below the excavated area. 'Fhe four perimeter borings will be used for horizontal and vertical delineation of soil impacts outside the excavated area. At a minimum, one sample ^vill be collected from the 0-2 foot depth interval (with the exception of the center boring), and two samples will be collected from the deeper interval in each boring. For the subsutface samples (below 2 feet below ground surface), one will be collected just above (he zone of saturation, and the other sample will be collected based on field screening results and photoionization detector (PID) readings. If additional soil impacts are encountered, provisions will be made to collect additional post-excavation and/or soil delineation soil samples to

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Page 6: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

MALDOyVI PIRNIE

INDEPENDENT ENVIRONMENTAL

ENGINEERS, SCIENTISTS

AND CONSULTANTS

Ms. Farnaz Saghafi USEPA. Region II January 3, 2007 Paae 6

complete the delineation in the same manner as that provided for .Area 7 (i.e. additional borings installed outward at -10 ft. intervals and samples collected to establish a "'clean zone" outside the area of impact). Soil samples will be collected for laboratory analysis for VOCs via EPA Method 8260B, SVOCs via EPA Method 8270C, and TAL metals via EPA Method 6010. Q.A,/QC samples will be collected in accordance with the QAPP.

• Field Screening/Logging - All soil borings will be logged according to standard logging procedures and will include the collection of PID readings at six-inch intervals. Collection of soil samples at 2-foot inten'als for headspace analysis will also be conducted. Depth intervals displaying the highest PID readings will be subjected lo DN.APL screening using USEP.A-approved dye and ultraviolet light DNAPL field screening procedures employed previously by Environ.

• Disposal of investigation derived waste (IDW) - Soil cuttings will be drummed and stored on-Site in accordance with existing LiSEP.A-approved IDW procedures, for subsequent waste characterization and disposal by the PRP.

.Schedule

In order to meet the Rl/FS project schedule, we will attempt to complete the delineation activities described below- in one event; how-ever, potential delays to the startup and 'or completion of this work may be incurred due to uncertainties in the exact timing of CL'FL's pipe removal activities (.Area 7) and working around the existing site trailer (.Area 8). In addition, it is possible that a second sampling event may be required to complete the delineation of diese areas, if analytical data obtained in the first event fails to define the limits of .soil impact.

Reporting

Progress reports will be submitted to document the performance of the Work according to the following schedule:

• Weekly Progress Reports will be prepared while the field aciivities are being performed; • Biweekly Progress Reports will be prepared during periods wiien no field work is being

performed. .A copy of the proposed Progress Report format is jDrovided in .Attachment A.

300242

Page 7: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

MAUJOLM PIRNIE

INDEPENDENT ENVIRONMENTAL

.ENGINEERS, SCIENTISTS

AND CONSULTANTS

Ms. Farnaz Saghafi USEPA, Region II Januarv 3, 2007 Paue 7

If you have any questions or require additional information, please call me at (302) 884-6919.

Very truly yours.

MALCOLM PIRNIE, INC.

Daniel P. Sheehan, P.E. Senior .Associate

300243

Page 8: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

FIGURES

300244

Page 9: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

AREAS: Odorous Trench .Soii

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3,0^0 S^J>!

AREA 7: EXTnAcriorj W E U . PIPING AREA-I Ci. IHW-8S, EWPI, 195? SPI1..L AREA

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Da!r>d,l/I7'0r). FNVIRON lnlHrn,11ior>.1l Cotpornlioi

MALCOyVI PIRNIE

Areas Identified for OU-2 Remedial Investigation Chemical Leaman Tank Line Superfund Site

Bridgeport, New Jersey

Figure 1

300245

Page 10: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

* * » % # • * * , ^

V \ \ . \ \ \ \

\ \ \ \ \ \

\

. /

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• •'* A 'J I . Adasjiefi from II I 7951B75C06A

i> • J 1 l/ib/OS

r ' i yll 'ON Iniernaiionai

A ! • Soil Boring

A Monitoring Wei!

MALCOLM PIRNIE

Proposed OU-2 Area 6 Soil Boring and Monitoring Well Locations Figure 2

300246

Page 11: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

Dt ' iS t ; ••^ZGirAlK

^ Post Excavation Soil Boi tng

0;i!':!U O'l/0?/0fi, Slifiw Wash iJitG Work Plein

MALCOLM PIRNIE

Proposed OU-2 Area 7 Soil Boring Locations Figure 3

300247

Page 12: Letter Report to Ms. Farnaz Saghafi, U.S. Environmental

TRAtFlRS a;.>r\;5s

\ - '^ ^..^'vi^''

O"

a-rtt XT'

^ x - ^

, f l ? « - * ^ '

Initial Delineation Soil Boring

M0Tt2' ftdaiif^o from X-\<MX^ l D;il'?n 04'07/06, Sli-nwyjnsrii.iri" Work Plnn

MALCOL/VI PIRNIE

Proposed OU-2 Area 8 Soil Boring Locations

Figure 4

300248