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I Central Maine Power . .. (2:'?) 52:-:::2;

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Mr. Steven Serian. Waste Manaaeaent Division Enforceaent ' Coat Recovery Section u.s. lnvironaental Protection Aaency J.F. lennedy Buildina Boston, Maaaachuaetta 02203

Subject: O'Connor Monthly Report

Dear Site Manaaer:

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CERTIFIED MAIL

October 10, 1988

Ma. Cynthia Kuhns Bureau of Oil ' Hazardous Material Control Depart•ent of Environmental Protection State House Station 17 Auausta, Maine 04333

In co•pliance with itea 53 of the O'Connor Site Consent aareement for the perfo~nce of the RI/FS, Docket Ko. summary report for September 1988.

Enclosure AKT/hj

1-86-1031, I .. enclosina the activity

Slncerely yours, I

_... .,jI· -...-·.

, ...-. · \ ..,·

Andrew K. Towt Bnvironaental Services Department

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F. O'CONNOR SITE MONTHLY STATUS REPORT

SEPTEMBER 1988

TASK 1 - DATA COLLECTION/EVALUATION

This task was completed with the collection of all available site characterization data prior to the initiation of field studies. This data was incorporated with data collected from other tasks and used in the evaluation process to formulate the Remedial Investiaation Report and Feasibility Study .

TASK 2 - PROJECT MANAGEMENT

The PRPs project manaaement structure is illustrated in the Project Operation Plan.

ROUTE 17 - SOIL REMOVAL:

An EPA letter dated September 8, 1988 retracted the statements in MDEP's letter of Auaust 22, 1988 which required the PRPs to remove the subject soils and auaranteed release from further remediation effort upon completion of this action. This EPA letter stated that release from CIRCLA liablity would not be aiven by EPA and that no work could co ..ence unless specified in a for.al order.

A MDZP letter dated September 13, 1988 stated that the MDEP letter of Auaust 22, 1988 was no lonaer valid in the effect that the PRPa would have

~ to take post-removal a..plea, a new schedule would be imposed, and the PRPs would not aet a release from further remediation in the affected area.

On September 23, 1988, the PRPa received a proposed amendment to Appendix I of the Consent Order froa EPA and MDIP. The purpose of this uendment is to address the removal of soils alona Route 17. The PRPs responded in a letter dated September 29, 1988, auaaeattna the addition of a clause relevant to the use of cleanup levels.

Followtna receipt of EPA's and MDEP's instruction not to commence soil removal, the PRPa cancelled contracts with vendors who were to take part in this effort. Rew work aareements will have to be developed prior to co..encement of any future soil removal activity .

DRAFT F .S.:

In a letter dated September 21, 1988, the EPA sent comments to the draft FS report and to the PRPa Auaust 5th response to EPA's letter of June 27, 1988.

The PRPa are worktna on responses to all the comments exclusive of the requirement in Item 3 that the PRPs provide in the FS a chemical analysis demonstratin& the separation of PCBs from soils taken from the O'Connor Site .

The chemical analysts required is beina challenaed because of lack of clarity in the request . Future action on this matter will depend upon determination of the scope of the request .

9/88

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O'Connor Site Status Report

Pendin& the outcome of this matter, the PRPs, in a letter dated September 30, 1988, invoked paraaraph 69 of the Amended Consent Order in order to insure that the time frame in which to file this claim was not exceeded. In doin& this, the PRPs held open the ri&ht to ao to dispute resolution if the type of work requested for this chemical analysis is viewed as not bein& necessary, relevant or appropriate in performin& the RI/FS for the O'Connor Site.

SCHEDULE:

In a letter dated September 15, 1988, the PRPs responded to EPA's proposed schedule chanae dated Auaust 1, 1988. The only exception noted waa the description to Item 1 under the task column in which the PRPs wanted it noted that the deliverable due on Auaust 5, 1988 was responses to aaency comments and not the delivery of a draft FS Report.

In a letter dated September 30, 1988, the PRPs requested a time waiver under paraaraph 66 of the Amended Consent Order. This request was for, (1) the existina four week time period in which to submit the revised draft rs Report be calculated from the date the PIPs receive comments from the KDIP; (2) the PIPs be aranted an additional four weeks to submit a revised draft FS report and this is exclusive of the time needed to do the chemical analysis requested in paraaraph 3 of EPA's letter of September 21, 1988; (3) Additional time as may be requested be aranted to the PIPs to perfora the subject chemical analyses; (4) Additional time as needed be aranted to the PIPs in order to respond to comments by the MDEP.

TASK 3 - OBJECTIVES/ALTIUATIVIS DIVBLOPMBIT

The final development of objectives and alternatives was presented in the Draft FS report. A report entitled, "Preliminary Indication of ARARa," was presented to IPA and MDIP in June 1986. On Auaust 13, 1987, a revised report which incorporates chanaes required by the Superfund Amendment and Reauthorization Act was submitted.

tASK 4 - COMMUIITY RELATIONS PLAI

There was no community relations activity for September. There is no community relations activity scheduled for October.

tASK 5 - SUBCOITRACTOR PROCUREMEIT

No subcontractor procurement activity took place in September even thouah arranaements were made to excavate soils between the fence and Route 17. No subcontractor activity will take place until the aaenciea can resolve reaulatory issues affectina this matter.

TASK 6 - PERMITS/AUTHORIZATIONS

No permit/authorization activity occurred in September and none is anticipated for October.

9/88

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O'Connor Site Status Report

TASK 7 - SITE RECOKRAISSARCE

Site Reconnaissance activities have been completed. Data aathered from this effort was used in the Tour I and Tour II data presentation. This data was also used in the development of the Draft Feasibility Study.

TASK 8 - TOPOGRAPHIC MAPPING

The one inch - 40 foot and one inch - 100 foot scale Base Map of the site has been submitted to EPA and MDEP. This Task is now complete. These mapa were referenced in the Tour I and Tour II data packaae, the Remedial Investiaation Report, and they were used in the Draft Feasibility Study.

TASK 9 - PROJECT OPERATION PLAK

The Project Operation Plan has been approved by both the EPA and the MDEP. On April 22, 1987, 1. C. Jordan submitted an addendum to the POP which covered the teat pittina procedure ..ployed in Tour II subsurface soil analysis. No additional chanaea to the POP are anticipated.

TASK 10 - FIELD MOBILIZATION

Ro field equi~ent .obilization occurred in Sept..ber. Dependina on resolution of the soil excavation issue, (refer to Task 2 and 5), there may be excavation equi~ent in use in October.

TASK 11 - DOMESTIC WILL SURVEY

This task has been co.pleted. Results from this survey have been incorporated with the results presented in the Tour I data packaae. These results were incorporated into the RI Report.

TASK 12 - IRVIiOIIIUTAL ASSESSNIII'l'

This task has been completed with the submission of the environmental section of the RI Report.

TASK 13 - REMOTE SIRSIRG IRVISTIGATIOK

The PIP's have responded to two independent seta of photoarammetric comments. Pursuant to the aare..ent between the aaenciea and the PRPa, third round comments were addressed in the discussion of this task in the RI report.

TASK 14 - MORITOIIRG WILLS

With the analysis of aonitorina well samples taken in July 1987, a complete aroundwater hydroloaic cycle was •onitored . This data was reported with the results fro• Tour II and was incorporated in th II report . No further groundwater samplin& is required for the RI / FS process .

9/88

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~ I O'Connor Site Status Report

TASK 15 - HYDROLOGIC STUDIES

Hydrologic studies were concluded with the reportina of site hydrologic characteristics in the RI report.

TASK 16 - ENVIRONMENTAL SAMPLING & ANALYSIS

This task has been completed.

TASK 17 - SITE SURVEY

This task has been completed.

TASK 18 - DATA REDUCTION

This task was completed with the submission of data in the RI report.

TASK 19 - RI REPORT

The RI report was submitted on December 18th.

A partial packaae of EPA co..ents to the draft RI Report was received on March 16th. A final packaae of EPA coaDents was received on March 31st. The MDIP submitted co.-ents on July 29th. The PRPs are reviewina com.ents and will respond to th.. as appropriate.

TASK 20 - ACTIOI LIMITS/RESPOISB OBJECTIVES

An Action Limit Response Objectives Report was submitted on March lat.

Reaulatory comments to this report were presented on March 16th. PRP response to these comments was submitted on March 30th.

TASK 21 - REMEDIAL ALTERNATIVES OVERVIEW

An overview of potential remedial alternatives was submitted on March 30th. EPA comments to this submission were received in late April. The PRPs responded to these comments in the draft FS Report submitted June 1, 1988. The MDEP has not submitted comments.

TASK 22 - DETAILED BVALUAIIOI OF REMEDIAL ALTERNATIVES

On May 11, a report which lists details of r..edial alternatives and evaluates them was submitted to EPA and MDEP . On June 28th the PRPa received coaaenta from the EPA concernina this docu.ent . The PRPs have not received co.aents from MDEP .

9/88

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I O'Connor Site Status Report

TASK 23 - DRAFT FS REPORT

The Draft FS Report is a compendium of Task 20, 21, and 22 activities and findinaa. The Draft FS report waa submitted on June lat. EPA comments to this aubmiaaion were received on September 22, 1988. The PRPa are reviewin& these comments and will respond to them. MDEP haa not submitted co..enta.

TASK 24 - FIKAL RI/FS REPORT

Work haa not commenced on thia task.

Arr 10/11

AJCI- 9366L