IJRSMinutes Of Phase H CONSULTANTSPre-Design PlansReview Conference

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Pre-Design InvestigationDelaware Sand and Gravetuperfund Site (Phase II)PNew Castle, Delaware

I Prepared for:

U.S. Army Corps of Engineers!, w Omaha District|yi Omaha, Nebraska

Contract No. DACW45-89-C-0518Acting for:

U.S. Environmental ProtectionI » -^~ «^ •

^Philadelphia, PennsylvaniaPrepared by:

URS Consultants, Inc.Buffalo, NY

URSUHS CONSULTANTS, INC. n v r[if'tnrj

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November 14f 1989

Mr. Steve Rowo \ 'Department of the ArrayCorps of Engineers, Omaha District1624 Douglas Street ; -Suite 608 .' .Omaha, Nebraska 68102 iDear Mr. Rowe_: _ .._._......_ _.._ _. __..... ,. _ _ _ _ _ : _ _ ...._ i__

Enclosed please find fourteen (14) copies of the Delaware Sand and GravelPhase II Pre-UBsign Plans Review Conference notes.

I contacted Mr. Robert Smart of your office on this date regarding whoshould receive a copy. Mr, Smart suggested I send you enough copies todistribute to each person who attended the conference. !

Should you have any questions regarding this matter, please do nothesitate to contact me.

Sincerely, '.

U R S CONSULTANTS, INC. . . . . . . . "

Thomas KnickerbockerQA/QC Officer

Enc . - . . -

TK/bc11-14-89L.SR35214

AR30002U

LEinnCONSULTANTS, INC.

TCL

570 DELAWARE AVENUEBUFFALO, NY 14202•=TEL (716) 883-5525FAX: (716) 883-0754

GENTLEMEN:

PLEASE REFER TO THIS TRANSMITTAL NUMBER ON

ALL FUTURE CORRESPONDENCE. ____________

WE ARE SENDING YOU Âttached D Under separate cover via __________;_____ the following items:

D Slop drawings D Prints D Plans D Samples O SpecificationsD Copy of letter D Change order D .———_______————————————————————————

DESCRIPTION

=•THESE ARE TRANSMITTED as checked below:

D For approval D No Exceptions Taken D Resubmit ___ copies for approval

D For your use D Revise as Noted D Submit ___ copies for distribution

Q As requested D Amend and Resubmit Q Return ——— corrected prints

D For review and comment D Rejected-See Remarks D ________ ; ___________ ̂_D FOR RIDS DUE _ _. __ _______ 19 ____ D PRINTS RETURNED AFTER LOAN TO US

REMARKS ____________________________________________________ --• _________

AR3000

COPY TO,________________________________— _SIGNED:

I I. !_-M,. ———*.!£.. .._

DELAWARE SAND AND GRAVEL SUPERFUND SITE (PHASE II)

COE CONTRACT NO. DACW-45-89-C-0518

MINUTES OF PHASE II PRE-DESIGN PLANS REVIEW CONFERENCE

Date: October 26, X989Location: COE Region VII Office

Omaha, Nebraska

Attendees;

Steve Rove COE - Omaha iEd Bave COE - OmahaJerry Trease . COE - Omaha iEd Mead COE - MRD

Glint Anyszewski CENAB-EN-GF ,Jim Moore CENAB-COF-HTS

Rob Alien Delaware - DNRECEric Newman EPA - Region IIISharon Lehn CEMRO-ED-GCPenny Brockman CEMRO-ED-GC ;James Chevey CEMRO-ED-GCRobert Craig CENAB-COF-BAY

Michael Borovicka CEMRO-ED-ENick Pangaro Alliance TechnologiesThomas Knickerbocker URS ConsultantsJerald Jacobi URS ConsultantsDuane Lenhardt URS ConsultantsVern Singh URS ConsultantsMiquel Cintron COE"- MRD !

flR300026

INTEODPCtlOH

The Phase II Pre-Design Plans Review Conference was held to discussthe COE, the EPA, and the DNREC review comments on the Phase II Pre-Design draft documents which included the Thermal Destruction TreatabilityTesting Study Plan, the Sampling Plan, the Safety, Health and EmergencyResponse Plan, the Draft Field Investigation Report Format, and theQuality Control Plan.

The conference on 10/26/89 started at 0900 hours and adjourned at1645 hours. At 1300 hours, the meeting was split up into three (3) groupsas follows: the geologists discussed the Sampling Plan, the engineers/chemists discussed the Treatability Testing procedures and the industrialhygienists discussed the Health and Safety Plan.

Review comments were discussed in accordance with the meeting agendaprepared by the COE. The written review comments by each reviewer werereviewed by topic but the responses are presented here for simplicity, inchronological order.

The agenda of the conference is presented as Attachment fl. Writtenreview comments by each reviewer are included as Attachment #2 through#11 to these meetings. Review comment response number (1, 2, 3, etc.)corresponds to the numbers used by the review as in his/her reviewedcomments.

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DISCUSSION AND RESPONSE; _ .

Review Comments bv Rob Alien (DNREC) October 26. 1989 (Ko writtencomments, will be presented at a later date) i

i • ,,! .

1. Treatability Testing P4, #4 Agreed to delete "to determine whetherthe ash from the incinerator process may be delisted, or must bei 'considered a toxic waste," because delisting is a lengthy process.

iDiscussion lead into EPA's Region II comments that the RI/FS was notas extensive as it should have been. The PRP's do hot feel the siteis defined properly, although the EPA feels that incineration is thebest choice and therefore the samples collected for the TreatabilityStudy are also a waste characterization study. DNREC would like to

see more samples collected to further define the site.

2. Sampling Plan p2-7 Question was brought up regarding the drillingoperations and when a drum is encountered, the plan states that thedrill rig will more over five (5) feet and start again* With 7-10thousand crushed drums buried there, what are the probabilities ofnot hitting another drum? URS's comment to that was that is whatwas required in the RFP. Safety concerns were also mentionedregarding drilling into the drum disposal area ie. drilling into anintact drum. Suggestions of using remote drilling operations werebrought up. The COE stated that the test pit program was designedto determine the conditions of the drums ie intact or crushed. In

rthe event of hitting an intact drum during drilling, there would besufficient cover over the drums and reduce safety concerns versustest pits where the drum would be exposed. Sample strategies werediscussed during drilling and if an intact drum was punctured, ie.

a bailer could be lowered through the auger flights to obtain ther

sample and then close the hole. [

3. Sampling Plan p2-7 what is the purpose of 22 additional boringsaround the perimeter? The purpose is to further flefif

of contamination at the drum disposal area. The resolution was toput a modification in place to further define the extent ofcontamination during field activities.

i4. Sampling Plan p2-37 section 2 10.4 - Why are we analyzing for

residual chlorine and obtaining analytical, results for the watersource? This was a requirement in the RFP although we are notinstalling any monitoring wells and water will not be used fordrilling, we would like to discuss it. The COE understood ourreasoning and it vill be deleted and replace with "a potable watersource will be used for the decon of equipment".

5. Correction in Table 4-1 p. 4-2 - TCL Total Metals should read TALTotal Metals,

6. General - Why is Test Pit Program starting off in Level A ppe? Itwas decided to start the Test Pit Program in Level B ppe withnecessary equipment on site to up garde to Level A ppe.

Review Comments by D. Kachek fCOE) October 20. 1989 (Attachment

1. Section 2.3 p 2-3 Well installation will be deleted

2. Section 2.5.2, p 2-6 Solution was to start trenching at the edgeof drum area and work towards the center

3. Section 2.5.2, p 2-7 See response |2 in Review Comments by RobAlien

4. Section 2.5.2, p 2-7 No solution as of yet, conference callscheduled for 11/6/89

5. Section 2.5.2, p 2-7 See response #3 in Review Com$î g gflKbtt QAlien

6. Section 2.5.3, p 2-7 Should set up program to go to confining layer

7. Section 2.5.4, p 2-9 No resolution as of yet, conference callscheduled for 11/6/89

8. Section 2.5.5, p 2-9 Program is set up for continuous sampling

9. Section 2.5.5, p 2-14 Incinerator requirements parameters

Review Comments by Ed Mead (COE) October 6. 1989 (Attachment #3}

1. Agree, run incinerator slag test (ASTM procedure for fusion test)to provide information_to the contractor. Run test on mufflefurnace samples at three (3) temperatures and time intervals. Wouldsupply information to contractor, to be used at own risk. Mr. Meadwould find out the ASTM procedures and inform URS*,

Review Comments by Jim Moore (COE) October" 24. 1989 (Attachment M)Sampling Plan ,

i •

1. Agree, mistakes/typos - will be corrected :-

2. General - Yes, will state in plan the levels of "clean" as statedin the ROD. We will set up program with laboratory for 24 hour turnaround time so drilling crew can move further out.

3. Section 1.3 - We do not intend to penetrate the confining layer

4. Section 2.0 - 2.1.2 - URS will not be performing this taski

5. Section 2.3 - In addition to the PID, an OVA will also be used. Asignificant reading is 2 to 4 times above background

6. Section 2.4 - There are other alternatives such as drilling at anangle

7. Section 2.5.2 - The test pit program will be performed first, thendrilling

8. Section 2.5.2 - Will attempt to collect a sample, then abandon hole

9. Figures 2.1 & 2.2 - Will clarify and correct figures

10. Section 2.5.4 - A reading of 2 to 4 times above background will beused. VOA samples will not be composited. Table 2-1 was explainedaccording to the text, ie some boring will have three (3) samplescollected, other boring will have one (1) sample collected based onvisual appearance and PID readings

11. Section 2.5.5 - A reading of 2 to 4 times above background will beused to determine contaminants

12. Section 2.5.5 - All drill cuttings etc. will be placed in drums thatare suitable for incineration

13. Section 2.5,5 - Yes

14. Section 2.6 - Provisions were made in the SHEEP

15. Section 2.6.3 - The split spoon will be cleaned after each use

16. Section 2,6.6 - Will be clarified

17. Section 2.7 - Will start test pit activities in Level B ppe

18. Section 2.7 - Will change text to passively ventilated AR30003 1

19. Section 2.7 - Will delete probing with steel bar and working in 6inch lifts i

20. Section 2.10.2 - See comment #12 above

21. Section 2.10.3 & 2.10.4 - No water will be used for drilling,therefore no need for testing

22. Section 5.2 - Radiation and explosimeter will be used during testpits and drilling operations. This section will be included in theSHERP ,

Review Comments by Jim Moore (COE) October 24. 1989 (AttachmentThermal Destruction Treatabilitv Testing Study Plan ;

1. Section 1.0, p-1 - Discussed in SP and QCP, plans were put togetherthis was so they would not be redundant

i2. Section 3.0, p-8, and Table 1, p-9 - The purpose of ' group 2 in Table

1 are for bidding information. TCLP metals before and after themuffle test would not be realistic. The muffle test does notadequately represent the true effects of an incinerator. This issuewill be addressed in the finalized work plans.

3. Table 1, p-9 - Agree, will provide a written explanation of Table1 plus make necessary corrections to figures so numbering/lettersystems match. ! ,

4. Appendix A, p-1 We need to know what "clean" is ie RCRA hazardousor non hazardous, will use TCLP as standard. >

5. Appendix A, Section 2.3 - Answered elsewhere in plans, will clarify

'̂sUffi

6. Appendix A, Section 2*3 - Refrigerated samples will not make adifference prior to incineration

7. Appendix A, Section 3.2.1 & 3.2.2 - The design of the incineratorwill have over design capabilities.

8. Appendix A, Section 3.4 - Would be impractical to test mufflefurnace gases

Review Consents by Jim Moore (COE1 October 24. 1989 (Attachment *6) SHERP

1. Section 1.1, pp's 1-3 - Agree the onsite safety designee will haveauthority to make necessary upgrade/downgrade of ppe

2. Section 3.2.2 - Agree, will add Em 385-1-1

3-18. All comments will be answered and review with the COE's IH

Eeview Comments by Jim Moore (COE) October 24. 1989 (Attachment J7) A/EQC Plan ':

a. Section 1.3 Will add this section to the SHERP ^

b. Table 4-1 Agree

c. Section 4.6 Will be clarified

d. Draft Field Investigations Report Format: Agree, discussed earlier,

however, this is not a part of this contract.

SR30003

MINI CONFERENCE •A/E SHERP '•

E. Save (COE) T. Knickerbocker (URS)

Review Comments by Ed Save fCOE) October 17. 1989 (Attachment.

1. Table 3-1, pp's 3-5 Agree '<2. Table 3-1, pp's 3-5 Will correct3. Table 3-1, pp's 3-7 Will correct . ; :4. Figure 4-1 Will clarify5. Figure 4-2 Will clarify and correct :6. Section 4.5 Will Clarify .7. Section 5.0 will add specifics to this section8. General - Will include appendix with manufacturers specifications9. Section 6.1 - Agree10. Section 8.2.2 We have SOF's for these problems11. Section 13.2 Agree, will be outlined in the plan12. Comments not on sheet; a. justify use of Level A ppe - will

commence work in Level B withequipment readily available for LevelA ppe ;

b. the section on perimeter air samplingrequires more detail ie - how will airsampling take place? Will add AirSampling Plan to this section.

•AR30003l»'

MINI CONFERENCE

DELAWARE SAND AND GRAVEL

MEETING NOTE

OCTOBER 26, 1989

Field Investigation Group Discussion _\ - •- -

Participants: Sharon Lehn (Geologist COE/Omaha) "'~

Duane Lenhardt (Geologist URS /Buffalo)Vern Singh (Project Manager URS/Buffalo)

o Reviewed with Sharon, Dave Kachek's review comments on SamplingPlan. Major areas of difference:

.i

(1) Test trenching around perimeter to define limits and observecondition of waste materials/types (URS approach) vs. directexcavation within drum disposal area (COE approach) .Emphasized unknown character of waste and potential forhazardous incident /emissions, if waste excavated and mixed.Suggested Dave contact Jim Moore (COE/Baltimore Const.)concerning need for perimeter trenching. Vern Singh indicatedURS would require indemnification from COE to cover liabilityif UR.S required to excavate directly into waste.

(2) Dave recommends sealing back to 20 feet depth from 30 feetproposed (originally proposed by COE - Supplement A) depth ofborings in areas 1A and IB. Suggested select borings beextended as required to identify deeper contamination.

URS has no problem with this, however, this approach couldrequire timely contract modification if widespreadcontamination beyond 20 feet. COE/Baltimore and EPA appearto prefer cut-off depth for borings to consider withunderlying clay layer ( 30 feet) . Sharon will recommend

AR300035

conservative boring depth (ie 30 feet) for borings in areas1A and Ib with understanding that footage/samples be adjustedas required during the drilling program to adequatelycharacterize contaminated hot spots (eg. Ridge Area 75 ft;more perimeter borings).

ii

(3) Dave disagrees that the recommended perimeter borings arerequired to confirm lateral spread of contamination. Davefeels area identified as 1A on URS figure 2-1 includes bothdrum disposal area proper and surrounding undisturbed soil;areas, in which case, 20 foot center plan would adequatelycharacterize contamination beyond disposal area.

What is included in Area 1A will be further examined. URSArea 1A is believed taken directly from RI and includes onlyarea of magnetic anomaly. ; ^

Sharon recommended several changes to draft plansriI . •

(1) Identify level of effort for various activities (ie testtrenching personnel/responsibilities; necessity to stabilizedrill over fill areas, etc.)

(2) Rectify inconsistency between plans (eg 4''vs 15' or testi ' ," -trench excavation, Sherp p 13-2 vs Sampling JPlan P 2-6).

URS' s approach (as summarized by Vern Sing) emphasizes phasedinvestigation of drum area to include: (1) perimeter trenches, (2)perimeter borings, followed by (3) interior borings. Suggestedinconsistencies in recommended approach as presented in COE commentsbe discussed internally as need for 20* vs 40' spacing of boringsand need for perimeter trenching.

Duane Lenhardt11/3/89

HINT CONFERENCE

THERMAL DESTRUCTION TREATABILITY TESTING STUDY PLAN

Attendees: J. Trease, N. Pangaro, J. Jacobi, V. SinghReview Comments by J. Trease, Attachment #9

Section 1.4Page 4 AgreeSection 1.4Page 5 Scope of services will be placed in the appendix and

appropriate references to the sampling and otherrequirements will be made there.

Section 2.0Page 6 AgreeSection 3.0Page 8 Agree, clarification will be madeSection 3.0

Page 10 Comments on incineration difficulty will be toned down,and the comment requesting changes or rationale formuffle furnace testing was withdrawn.

Section 2.3Pages 9, 10 AgreeSection 3.2.1Page 11 A general decrease in the overall number of samples, as

well as the substitution of additional sample types,such as slagging samples will be addressed in thefinalized work plan.

Section 3.2.2Page 12 Withdrawn

AR300037

CONFERENCE CALL MEETING NOTES

Attendees: URS - V. Singh, J. Jacobi, D. Lenhardt, R. Tramposch,T. KnickerbockerCOE - S. Rowe, J. Trease, D. Kachek

Date: November 6, 1989 ,

Introduction: A conference call meeting was planned in order toresolve the issues brought forth in the October 26f 1989meeting with the COE. The conference; call started at1400 hr EST and ended at 1600 hr EST. ;

Discussion and Response; ;

Written review comments were received from Rob Alien (DNREC) fromthe October 26, 1989 meeting at the COE in Omaha, Nebraska (Attachment#10).

Review p.nniments bv D. Kachek (COE) November 6. 1989 (Attachment #11)

Sampling Plan ; .

1. Section 2.5.3, p 2-7 Agree, however, we would like to keep thesampling approach the same except we would not use a grid pattern.A site walkover would be performed and field decisions would be madebased on a biased sampling approach.

2. Section 2.5.4 p 2-8 Agree, perhaps 1 sample per boring may be usedbased on decisions made in the field.

3. Section 2.5.2, p 2-6 The number of borings will be reduced to ten

in the magnetic anomalic area and the 15 borings outside this areto determine the lateral extent of contamination.

4. Section 2.5.4 p 2-7 Agreed to cut back the number of borings inarea Ib, however, field decisions will dictate the actual numberof borings.

5. Section 2.7, p 2-27 Not resolved yet, we will obtain-pricinginformation for the program.

6. General - Agree, the COE will supply us with a copy of the report.

7. Will obtain pricing information for on-site analysis.

8* See comment #5 above

•s

9. Agree

AR300039

ATTACHMENT 4 1

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AR30006

OCT 24 '39 17:07

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ATTACHMENT * 4COMMENTS BY COE

AR3000

'LtS

?-HTS (50-6c) 24 October 1989

THRa Harrisburg Area Office-- . - -- i- oR Cf Construction Civ

SJBJECT: Delaware Sand and Gravel Superfund Site (Phase II) - Comments onCraft Predesign. Documents • ,-•

t. The following are preview comments qn̂ subject documents, all datedSeptember 19, prepared by U RŜ Consul tanta, Inc. These comments are alsobeing telefaxed directly to the"G£fcSC Project Manager and to Mr. Craig(CENAB-NA) prior to the 26 October' "Cĵ iaoard Review Conference, Asrequested, I plan to attand^frfiat confereiiĉ . along with Messrs* Craig andAnussewski.

2. Ifr detailed comments follow. These are based in^fchefive pre-designdocuments, entitled: Sampling Plan; Thermal Destruction "Tra.atabilityTesting Study Plan; A-E H&S/Emergency Response Plan; A-E QC Pî a: and Report

Sampling Plan:

1. Flan references and sketches do not agree with the TreatabilityTesting Study Plan, in that both boring and test pits are mentioned here andthe Treatability Testing Study Plan addresses only borings* Furthermore,the figures and area/phase designation for the Drum Disposal and Ittdge Areasdo not agree*

2. General - If one of the purposes of these investigations is todefine the extent of contamination, the levels for "contaminated" soil/wasteand water should be stated in the plan.

3. Paragraph 1.3 * Sketches, both plan view and section, would behelpful in defining how ground water moves into the "aPHZff. Also, is the"zero area" (page 1-5) the same as the "window" (page 1-4)7 Will theproposed drilling and trenching create more, "windows"?

4. Paragraph 2 - Are the proposed horizontal and vertical datums thesame as those used for the site maps/plans shown in this report?

!5. Paragraph 2.3 - Why is PID the only air screening tool? Thisdevice is neither selective nor comprehensive enough to "determine airquality" by itself. Also, what are "significant readings"? What- is"background" and how is it determined?

flR300069

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-2-

6. Paragraph 2.4 - Does not indicate what happens if the iaitiai 5foot offset still fails to clear the metallic object. Will the hole bedrilled at the original location anyway? If so, what additional precautionswill be taken?

7. Paragraph 2.5.2 - Will test trenching precede drilling? Willproposed borehole grid then be adjusted based on perimeter findings?

8. Paragraph 2.5.2, page 2-7, 2nd subparagraph - What "is the purposeof moving a boring five feet from where a drum is perforated and sampling"immediately below where the drum was encountered"? Chances are that in a 5foot radius there will be more drums and/or that the contaminant from the .punctured drum has not yet migrated to the revised hole location. A betterapproach would be to directly sample (if safety can be ensured) from thepunctured drum prior to backfilling the original borehole.

0- V±&uur>+m 2-1 suad 2-2 - On l»ao*nl, identify if th«a* ai*a aaed. et 1 n£ nnproposed wells and borings* Also, highlight and/or number the testtrenches* Better labels and interval for contours are needed. What does"Area 3W on Figure 2-2 mean?

10. Paragraph 2.5.4 - What Level of PID or FID reading qualifies forsampling soil for 70A? Will these be composited? If so, how can they beconsidered to be representative of in- situ concentrations? According to thesecond paragraph on page 2-8, 10 boring samples and 5 test trench sampleswill be collected and analyzed for "TCL"; since there are 75 borings and 10trenches shown on Figure 2-1, can we then assume these are composites? Whatare "TCL" parameters; 7QA, metals, PCB/Pesticides, or all of these?

Furthermore, how does this jive with page 2-9, which indicates that 165samples will be "submitted" from the Drum Disposal Area?

11. Paragraph 2.5.5 (a) - Define "elevated" PID/FID readings.

12. Paragraph 2.5.5 (b), page 2-12 - Where will the remaining samplebe "discarded"?

13* Paragraph 2.5*5 (d) - Is your lab equipped to do geotechnicaltesting on potentially contaminated soil?

14, Paragraph 2.6 - Why isn't project H&S Officer mentioned here?

15. Paragraph 2.6.3 - Will split-spoon be steam cleaned/changedbetween drives to prevent cross-contamination of samples?

16. Paragraph 2.6.6 - Who is doing the "ongoing pumping"? Will thisaffect our sampling validity? Will it be ongoing during and after ourremedial action?

-3-

17. Paragraph 2.7, page 2-27 - Why use Level "A"? Personnel canbarely move around in Level A suits, much less probe for drums, takepictures, etc. It would be better to have all personnel in Level H and tokeep operators and spotters out of harm's way during actual excavation.Survey locations should be by coordinates and Novations, not landmarks.

18. Paragraph 2.7, page 2-28 - Why is backhoe cab "ventilated"? Doyou mean operator uses equipment-mounted air bottle? If cab air isconditioned, it should be positive pressure from supplied air bottle.

19. Paragraph 2.7i page 2-29 - Steel bars are not acceptable for drumpro Ding. Non-sparking materials for prubo (and for shovel a, picho,, *>to.)are r

ATTACHMENT # 5COMMENTS BY COE

flR300072

-3-

17. Paragraph 2,7, page 2-27 - Why use Level "A"? Personnel can^ move around in Level A suits, much leas probe for ̂ rurns, take

pictures, etc. It would be better to have all personnel'in Level B and tokeep operators and spotters out of harm's way durin§Xctual ekcavation.Survey locations should be by coordinates and elevations, not landmarks.

V'barely

18. Paragraph 2.7, page 2-28 - Why is backhoe cab "ventilated"? Doyou mean operator uses equipment-mounted aiî bottle? If cab air i»conditioned, it should be positive pressure from supplied air'bottle.

19. Paragraph 2.7,^page 2-29 XSteel bars are not acceptable for drumprooing. Non-sparking materialsxfar probe (and for ahovclo, pteker.«to.)are required. Also, describe'"ŵ iat to do with, the drum if you find one(overpack, etc.). Also, how/doesrqn© probe for drums and/or sample thetrench sides without entering the trench?

20. Paragraph 2yfO,2 - How can FID OaJLone) be used to determine clean/dirty drill cuttii

22* Paragraph 2.10.3 & 2.10.4 - What about potentially contaminateddrilling watjarr and mud? Are these treated as cuttingŝ

Paragraph 5.2 - Where and when are the radiation anŜ explosimeterdevicê used? :

b. Thermal Destruction Treatability Testing Study Plan:

1. Paragraph 1.0 - If there are dual objectives to this project:defining the extent of contamination and performing a thermal treatabilitystudy, why are the samples being composited prior to analysis? At the veryleast, portions of the individual samples should be separately analyzed forTCL Parameters to satisfy the first objective (site characterization);composited samples could then be made from the remainder of the individualsamples, and incineration-specific testing (TCLP, Heat and Moisture Content,etc.) could then be performed, as required, on the composites.

2. Paragraph 3-0 and Table 1 - Shouldn't the objectives for bench-scaletesting also 'be to determine all applicable parameters in Table 1 on boththe untreated substrate .ana the furnace residue? For example, by doing TCLPonly on the furnace residue, how do we know what effect the incineration hason the TCLP characteristics of the material; perhaps it makes the metalsmore readily leachable. Furthermore, there are certain physical parameters,such as particle size, moisture, and specific gravity, which are alsoimportant in the residue, if that residue is to be placed as backfill at thesite. Finally, if the purpose of incineration is to "drive organiccontamination from the site substrate" (page 2 of Appendix A), then whyaren't VOC's being analyzed in the furnace residue?

Wig

MR'300073

.10 'ay yys-si '.̂ E-nCeTHE'Ĥ TEr.M RESIDE! .T OFC. "" ' — • P.

3. Table 1 - What is the meaning of the group and phase numbers shownon this table? How, do these relate to the borings, zones, sectors,experiments, samples, and composite designations used in Appendix A and inthe other documents listed above? The only match I've found is a connectionto Phase/Group in Paragraph 3*4 of Appendix A. I cannot connect these tothe physical samples and composites,

4. Appendix A, Paragraph 1,0 - How can phrases/terms such as "thecharacter of contaminants in the soil", "non-hazardous", and "de-listable"be used without some benchmark data as to the type of contaminant, thematrix in which it exists, and the levels which are considered to be clean/dirty? (i.e. How do we define victory for the incineration process and howdo we determine what soil to put into the incinerator in the first place?}.

Furthermore, on page 2, are we just interested in reducing the organiccontent in the soil or should we also be interested in reducing the mobilityof metals and other compounds in the residue?

5. Appendix A, Paragraph 2*3 - The proposed compositing methods(mixing, splitting, quartering, etc.) will tend to promote volitilization;will this artificially reduce the levels of volatile and aemivolatilecompounds?

6. Appendix A, Paragraph 2.3 - Refrigerated composites should beallowed to warm to ambient temperature prior to incineration.

7. Appendix A, Paragraph 3.2.1 & 3-2.2 - If only Zone 'A materials(i.e. those with the highest levels of organic contamination) are testedfor optimum burn time and temperature, are the optimum results necessarilyapplicable to the iftftat contaminated soils? Furthermore, will variances insoil type and in- situ moisture affect these optimum values?

8. Appendix A, Paragraph 3.4 - Would the measurement of TCL parametersin the stack gasses during incineration be useful data when designingsecondary or afterburners?

H&S

A/E .Ŝ etty,-Hê tĥ n̂d'-5.merseji

ATTACHMENT # 6

COMMENTS BY COE

M300075

•XT £6 *8S 0~C.

-4-

3-' "Table 1 - What ia the moaning uf'l:he' group and phase Aumberaon this table? How do these relate to the borings, zones, sectors,experiments, samples, and composite designations used in Appendix A ja£& inthe other documents listed above? The only match I've found is .a/connectionto Phase/Group in Paragraph 3.4 of Appendix A. I cannot connec.tr these tothe physical 3amples\*nd composites.

4, Appendix A, Paragraph 1.0 - How can phrases/terms such as nthecharacter of contaminants^ln the. soil1*, Bnon-ha2ardo>u..j!t, and "de-listable*be used without some benchraat̂ c data as to the type/bf contaminant, thematrix in which it exists, and\the levels whicĵ /are considered to be clean/dirty? (i.e. How do we defineNfectorv for/tlie incineration process and howdo we determine what soil to put jî to the/incinerator in the first place?).\ j ^

Furthermore, on! page 2, are we jA&t interested in reducing the organiccontent in the soil or should we :aLao b&xinterested in reducing the mobilityof metals and other compounds in j£he residue?

• 5. Appendix A, Paragraph: 2.3 - The proposed compositing methods(miiing, splitting, quartering, etc.) will tendN̂ p promote volitilization;will this artificially reduce the llevela of volatile and aemivolaHilecompounds? . /

] 6. Appendix A/(Paragraph 2.31- Refrigerated! composites shoul^ beallowed to warm to- azfbient temperature prior to ipcineratibq. \

7. Appendix A, 'Paragraph 3.2J1 4 3-2.2 - If \only 2one'A materials(i.e. those with the! highest leveljs of organic cdpt ami nation) are tpstedfor optimum burn time! and temperature, are the optkaum results necessarilyapplicable to the JL̂ aki contaminated soils? Furthermore, will variaiî es insoil type and in-situlmoisture affetat these optimum values?

' 8. Appendix A, paragraph 3.4 -\ Would the measurement of TCL paramet^in the stack gassas during incineration be useful data when designingsecondary or afterburners? ____• ________——————'

c. Draft A/E Safety, Health, and Emergency Response Plan:

1. Paragraph 1.1, page 1-3 - In the event that an upgrade in level ofPPE or a cessation of activities/evacuation are required, the.on-site safetyrepresentative should not be required to first consult with-anyone. If theH&S -Officer must make these calls, then the H&S Officer should be on-site.

2. Paragraph 3.2.2 - Add Em 385-1-1 to the list of applicable safetystandards.

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3. Table 3-1 and Paragraph 3.1 - Explain what matrix the"Concentration Range" numbers are> taken from and make some reasonablecorrelation with expected exposure concentrations (i.e. air/derail). Alsocite PEL's in units which will be measured at the site (i.e. PPM, in air forbenzene, etc* ) .

i4 Paragraph 3.2*7 - How will fugitive vapors be controlled?

!>. Paragraph 3.2.9, Page 3-11 - Recheck guidance in aubparagraph 1(a)regarding eating salted foods, especially as it relates to persons withblood pressure problems.

6. Paragraph 3-3 - The listing of miscellaneous safety concerns is notcomplete, nor does it adequately reference, cite, or highlight therequirements of EM 385-1-1. Plan should be prepared IAW Appendix Y of thatdocument .

?'. Paragraph 4.1 - SHERP JBIIS£ address the possibility of unaiithorizedentry by unprotected personnel, at the least to the point of requiring thecessation of hazardous activities.

9. Figure 4-1 and Paragraph 4.3 - How v:ill you prevent the spread ofcontaminants while equipment is enroute from work site to "Permanent CRZff?Trail ering may be impractical per Paragraph 13.3.

10. Paragraph 4.3, page 4-3 - At what "condition" will you erectshowers and changing facilities? Absent these facilities, where will workersdon PPE? All at the hot line?

11. Figure 4.3 - Further describe "woven poly liner" (i.e. thickness,strength, etc. ) . .

12. Paragraph 4.4 and 5.0 - Level A PPE is impractical for actuallydoing any borings or test pit work. Further, what are proposed actionslevels for up/downgrades?

13. Paragraph 6.0, 9-9-2 & Table 5-3 - Recheck 5 ppm action levelgiver, the compounds listed in Table 3-1 ,

14. Paragraph 8.1 - Conflicts with Paragraph 4.3 regarding showers andchanging facilities.

15. Paragraph 13-1 i 13*2 - Procedures described do not agree withother pre-design documents regarding drum handling. Also, what is theultimate fate of an uncovered drum? Overpack?

16. Paragraph 13-3 - Is moving equipment on trailers feasible, giventhe site topography?

17. Appendix B - Will you really set up 17* discreet stations in thedecon rine~~f or "Level ~B7~~ ~~" . AR30Q077

OCT 35 *S9 09! £8 CCC-f .OPThEHSTERf I FESIE-EUT OFC". P.7

-6-

18. Appendix B - Accident Report Form(s) should include or referenceUSACOE format.

igraph 1-3 - Methane precaution should also be in SHERP.>^ ^b. Table 4̂ K- Matrix for physical tests (specific aravity, %

moisture, etc. 3 may 3̂b̂ o be soil; same for EP Tox, dioxins, etc.

\c. Paragraph 4,6 - DefilM̂ exactly which^steps in compatibility testdare dpne on/ojff site.

Draft Field Investigationsi-Heport^

One of trie documents produced Jhould b© a full̂ fcŝ le reproducibletopographic shset, showing project features, the .asreeofeoordi nate andelevation datums, and-all established baselinesj IBM's etc.̂ ^̂ is shouldform the basis'f or--al]._other drawings such as boring and _The locations of"physical baseline points and monuments (including..backsights, ties, etc.) must be accurately depictgd/deacrltSel, __3. Any^further comsgnts/d±Scussions generated as a result of the 26October.—Oa-MiSrd̂ eview meeting will also be forwarded for yourinforaation.

JAMES P. MOORE.Resident Engineer

ATTACHMENT # 7COMMENTS BY COE

AR.300079

OCT £b '89 Q3:£3 CCC-nORTHEHSTEPM RES ICO .T OFC. - -- - - =- - - p.'

. • ,18A Appendix B -/Accident Report Fo"pm(3) should ihclud~USACOE fdrmat. \

d. A/E QC Plan:

a. Paragraph 1-3 - Methane precaution should also be in SHERP.

b. Table 4-1 - Matrix for physical tests (specific gravity, %moisture, etc.) nay also be soil; same for EP Tox, dioxins, etc.

c. Paragraph 4.6 - Define exactly which steps in compatibility testingare done on/off site.

e. Draft Field Investigations Report Format:

One of the documents produced should b* a full-scale reproducibletopographic sheet, shewing project features, the agreed coordinate andelevation datums, and all established baselines, IBM's etc. This shouldform the basis for all other drawings such as boring and test pit locations.The locations of physical baseline points and monuments (includingbacksights, ties, etc.) must be accurately depicted/described.

3. Any further comments/discussions generated as a result of the 26October On-Board Review meeting will also be forwarded for yourinformation.

JAMES P. MOOREResident Engineer

AR300080

ATTACHMENT t 8

COMMENTS BY COE

AR3QQQ8J

TO:STEVE ROWE CEMRQ-ED-EA 1O/17/S9FROM:ED BAVE CEMRO-ED-EF :

SUBJECT:DELAWARE SAND AND GRAVEL PHASE II PRE-DESIGNSUBMITTALS

Health and Safety Plan. _"M ...

1. Table 3-1; pg 3-5: USAGE feels the Benzene Standard 29 CFR1910.1028 is applicable to hazardous waste work. The 8-hourTWA under this stahclard is i ppm. Suggest adding Benzene spe-cific colorometric tubes to Section 6 "Air Monitoring" proto-col

2u Table 3-1; pg 3-5: Typo; Acetone 2nd col. "Up go".

3. Table 3-1; pg 3-7: PCS's PEL should read 0.5 mg/cu m.

4. Figure 4-1; The arrow pointing to the cyclone fencingaround the Support Zone is misleading. Although the CRZ isshaded differently, it appears that both zones are defined bytha arrow as the Support Zone.

5. Figure 4-2; It appears that the lab trailer is intended toreside in the CRZ yet section 4.2 states (twice pg '4-1 and4-2) that the lab is to be in the support zone. Logistics mayallow for a corridor" from the Exclusion Zone to the lab trailto aid in sample transport. This needs to be clarified"in theplan.

6. Pg 4-5; section 4.5: This paragraph defines work occurringin the CRZ as off-site; this contradicts activities"^ coveredunder B.3 on pg 5-4, Table 5-2.

7. Pg 5-5; section 5.0 second para.:Discuss site .specifictechniques/procedures anticipated to eliminate concerns re-lated to air-line damage etc.

8. Pg 5-5:General; A much more detailed discussion related tothe air supply sysEem(s) and associated requirements needs tobe added to the plan. Include daily inspection of air-lines,logistic concerns of~ personnel on-line working with andaround heavy equipment, as well as communications of foot andoperator personnel. Identify the type of supplied air respi-rator(s) to be used and the associated hose length specs.Discuss movement of the cylinders from one boring/excavationlocation to the next. Discuss the location of the cylindersin terms of use during" drilling and excavation, storage, re-filling, compressor requirements, and air monitoring require-ments if the cylinders are to be refilled on-site 'and thelocation of this refilling operation etc. Discuss how persoĵ -f{ 3 Q Q Q 8nel are to get off line in the active work zone if the exca- yvation has not been" backfilled. . .'.'.'.. ''.." _ . _. ___

• .3 —29 CFR 1910.134 states breathing air shall _meet the frequirs-ment of the specification for Grade D breathing air ! as as-scribed in the Compressed Gas Association Specification G7.-1966, It should be stated in the SHERP that URS ,requiresa certificate of analysis, from vendors which supply triebreathing air, that states the air meets this standard beforeoperations start and any time their process changes. ._

9. Pg 6-1; section 6,1: Reiterate in the text the location ofthe real-time monitoring for volatiles (breathingzone/borehole) as stated in the footnote of Table 5-3 pg 5-8.

10. Pg 8-2; section 8.2.2: High, humidity generated byhigh-pressure water may fog the lamp and af f_ect the. integri tyof PID readings during this work effort. ' t

11. Pg 13-2; section 13.2: It is not clearly stated what isto be done with an intact drum once it has been inspected. .Itis assumed that all intact drums (containing or suspected ofcontaining material)." recovered are to be overpacked using theequipment outlined in section 13.1. Clarify that this; is. thecase. Also, discuss what is to be done with excavated scrapdrums (i.e. those which may have been crushed on-sita;) duringthe .time the dump was active.

Thermal Destruction Treatability Testing Study Plan.

1. Pg 6; section 2.2 last para~. : All zones in figures aredesignated with letters. Clarify Zone 1'. It is assumed thisi s t h e equivalent "of" Zone " A . _ . - . . . . . . -

5R300083

ATTACHMENT f__9COMMENTS BY COE

AR300081*,

D MRD -rVf &*YnA/\6 DU*—

CORPS OF ENGINEERS TO, jSY

D MRO CORPS OF ENGINEERSQ ___________ District ENGINEERING REVIEW COMMENTSPLANS & SPECIFICATIONS AND/OR DESIGN REPORTUJ PRELIM LJ FINAL LJ AS-ADV.

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