- - - - - 4 4April 12, 1990

SCOPE OF WORK FOR CONDUCTING AREMEDIAL INVESTIGATION AND FEASIBILITY STUDY

AT THE H.O.D. LANDFILL SITE,LAKE COUNTY, ILLINOIS

TABLE OF CONTENTS

Page

1.0 INTRODUCTION 1

2.0 TASK 1: WORK PLAN AND INVESTIGATION SUPPORT 4

2.1 Introduction 4

2.2 Preliminary Site Evaluation 5

2.2.1 Site History 8

2.2.2 Site Characteristics ' 8

2.2.3 Nature and Extent of the Problem 8

2.2.4 History of Response Actions 8

2.2.5 Definition of Boundary Conditions 8

2.2.6 Identification of Potential Receptors 9

2.2.7 Development of Site Conceptual Model 9

2.3 Technical Scope 9

2.3.1 Development of Site Management Strategy 10

2.3.2 Evaluation of Data Quality Objectives (DQOs) 10

2.3.3 Identification of RI/FS Tasks 10

2.3.4 Request for ARAR 11

2.3.5 Schedule 11

2.2.6 Project Management 11

2.4 Investigative Support Activities 11

2.4.1 Site Mapping 12

2.4.2 Metes and Bounds 12

2.4.3 Access Arrangements 12

2.4.4 Preparation of Support Facilities 13

TABLE OF CONTENTS (CONTD.)

Page

3.0 TASK 2: Rl/FS PROJECT PLANS 14

3.1 Sampling and Analysis Plan (SAP) 14

3.1.1 Field Sampling Plan (FSP) 14

3.1.2 Quality Assurance Project Plan (QAPP) 15

3.2 Health and Safety Plan 16

i 33 Risk/Endangerment Assessment Plan 17

3.4 Data Management Plan 17

3.5 ATSDR Health Assessment Needs 18

4.0 REMEDIAL INVESTIGATION (RI) 20

4.1 Overview 20

4.2 Task 3: Site Investigation 21

4.2.1 Physical Characterization 21

4.2.2 Source Characterization 23

^-^ 4.2.3 Contaminant Characterization 23

4.2.4 Migration Pathways 24

4.3 Task 4: Site Investigation Analysis 24

4.3.1 Quality Assurance and Data Sufficiency Evaluation 24

4.3.2 Additional Data Collection 25

4.4 Task 5: Baseline Risk Assessment 25

4.5 Task 6: Treatability Studies 26

n

TABLE OF CONTENTS (CONTD.)

Page

4.6 Task 7: Reports 27

4.6.1 Monthly Progress Reports 27

4.6.2 Technical Memoranda 28

4.6.3 Draft Remedial Investigation Report 28

4.7 Task 8: Community Relations Support 29

4.8 Task 9: Conduct Interim Actions 29

5.0 FEASIBILITY STUDY 31

5.1 Overview 31

5.2 Task 10: Development of Remedial Action Alternatives 31

5.2.1 Develop Remedial Action Objectives 32

5.2.2 Develop General Response Actions 32

5.2.3 Identify Volumes or Areas of Media 32

5.2.4 Identify and Screen Remedial Technologiesand Process Options 32

5.2.5 Evaluate Process Options 32

5.2.6 Assemble Alternatives 34

5.2.7 Alternatives Array Document 34

5.3 Task 11: Screening of Alternatives 35

5.3.1 Alternative Definition 35

5.3.2 Screening Evaluation 36

533 Alternative Screening 37

in

TABLE OF CONTENTS (CONTD.)

Page

5.4 Task 12: Treatability and Supplemental RemedialInvestigations 37

5.4.1 Determination of Data Requirements 37

5.4.2 Treatability Testing 38

5.5 Task 13: Remedial Alternatives Evaluation 38

5.5.1 Detailed Development of Alternatives 40

5.5.2 Detailed Analysis of Alternatives 40

5.5.3 Comparison of Alternatives 43

5.6 Task 14: Feasibility Study Report " 44

5.7 Task 15: Community Relations Program 44

w

TABLE OF CONTENTS (CONTD.)

Page

FIGURE

1. RI/FS

TABLES

1. Suggested Preliminary Site Evaluation Repon Format 6

2. Suggested SAP (QAPP and FSP) Format 19

1.0 INTRODUCTION

This document presents the Scope of Work (SOW) to conduct a Remedial Investigation(RI) and Feasibility Study (FS) at the H.O.D. Landfill site located in Amioch, Illinois.The purpose of this SOW document is to provide the direction and intent of the RI/FS.Within 45 days of the effective date of the Administrative Consent Order (AGO) aPSER/TS Work Plan (see Task 1) will be submitted that provides detailed guidance onthe execution of the RI/FS.

The purpose of the RI is to determine if .there has been a release, or there exists aviable threat of release and if so, the nature and extent of contamination at the H.O.D.Landfill site. The purpose of the FS is to determine if remediation of the site isnecessary and to develop and evaluate appropriate remedial action alternatives based onthe RI data and report. All personnel, materials, and services required to perform theRI/FS will be provided by the Respondents.

This SOW generally addresses items needed to fulfill the requirements for an RI/FS.The RI/FS Work Plan to be developed pursuant to this SOW will present a phasedapproach that recognizes the interdependency of the RI and FS. The organization andinteractive nature of this approach are illustrated on Figure 1. The data collected in theRI influences the development of remedial alternatives in the FS, which in turn affectsthe data needs and scope of treatability studies and additional field investigations. TheRI/FS component shall be conducted in a manner that will minimize the need for -datacollection or performance assessments in the RD phase and, if deemed appropriate, willfacilitate separation of the remedial action into operable units.

The major RA tasks encompass three major topical categories:

" Work Plan and Investigation Support,* Project Plans and Management,

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* Remedial Investigation (RI),

Each of these tasks are discussed in greater detail in the following sections. Please notethat the activity sequence presented in Figure 1 is not consistent with the topicalsequence of presentation in this SOW.

Use of the terms "contamination", "contaminants of concern", "exposure routes","migration pathways", "receptors", "health impacts", "hazards of concern" and "adversehealth and environmental effects", "remedial action", "threat to public health and theenvironment", "treatment", "containment" ,or "removal goals" or any synonym or anyderivative thereof, within the context of this document neither specify nor imply thatthere has been a release from the facility or that the investigation will produce evidenceof a viable threat of such a release.

2.0 TASK 1: WORK PLAN AND INVESTIGATION SUPPORT

2.1 Introduction

The initial task of the RI/FS will encompass an evaluation of the existing siteinformation and identification of the data needs and data quality to be addressed in thepreparation of project plans (Task 2) and remedial investigation (Task 3). The resultsof these efforts will be reported in a Preliminary Site Evaluation Report and TechnicalScope (PSER/TS) which will define the level of effort required in the RI/FS. TheRI/FS PSER/TS will be developed in conformance with all provisions of the ConsentOrder and this SOW, and the standar4s set forth in the following statutes, regulations,and guidance:

Section 121 of CERCLA;

* U.S. EPA "Guidance for Conducting Remedial Investigations andFeasibility Studies under CERCLA, Interim Final" dated October, 1988;

* National Contingency Plan, dated March 8, 1990, as amended; and

* All Additional Guidance documents identified by the U.S. EPAno later than the effective date of the AGO.

All available existing data for the site will be compiled to evaluate the additionalactivities which need to be included for the RI/FS, and avoid duplication of previousefforts. Existing data will be analyzed to gain a better understanding of the nature andextent of existing impacts, migration pathways, and receptors. The data compilation andreview within the PSER is intended to form the basis for preparing the project plans forimplementing the RI. The TS will detail the technical approach, personnelrequirements, and schedule for each task described in this SOW. The schedule willshow the implementation of tasks and proposed dates for submittal of draft and finalreports summarizing the findings of the tasks.

The Respondents will submit the PSER/TS within 45 days after execution of the

consent order. The USEPA will have 45 days to review and provide written comments

on this document. If a longer review period is required, the USEPA

Project Manager shall notify the Respondents of that fact within 30 days of receipt

of the PSHyiS. Within 30 days of receiving these written contents, the

Respondents will submit a final PSEZyTS. The USEPA, in consultation with the IEPA,

will review and approve the PSER/TS prior to the development and sutndttal of the

project plans (faak 2) . The activities comprising the development of the PSE3VTS

are discussed below. A suggested format for the PSEEVTC is provided on Table 1.

g.2 Preliminary Site Evaluation

The background information pertinent to the site and to the environmental concerns

will be described, and the purpose of the RI will be furthered detailed. The data

gathered during previous investigations will be reviewed and evaluated. Regional

information will be obtained front available USGS and Illinois Geologic Survey and

Illinois Water Survey reports. The existing site information that will be reviewed

may include but will not necessarily be limited to:

* U.S. EPA's Expanded Site Investigation Report,

* Illinois EPA and U.S. ERA files,

* County Soils Conservation Service reports,

* Aerial photographs,

* Historical water quality data,

* U.S, Illinois Geological Survey, Illinois Water Supply files,

* Disposal records (if available) , and

* Non-privileged technical information generated to date.

In addition to this literature search, on-site activities may be used to confirm

and/or update certain information. For example, existing monitoring wells will be

inspected to

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determine if they are functional. Also, the location and status of selected water supplywells will be field verified.Table 1. Suggested Preliminary Site Evaluation Report/Technical Scope Format

1.0 EXECUTIVE SUMMARY2.0 INTRODUCTION3.0 DESCRIPTION OF CURRENT SITUATION

3.1 Site History3.1.1 Ownership3.1.2 Waste Disposal Activities

\*^3.2 Previous Response Actions3.3 Site Characteristics

33.1 Previous Investigations3.3.2 Physiography3.3.3 Soils3.3.4 Geology33.5 Hydrogeology3.3.6 Hydrology

3.4 Problem Definition3.5 Definition of Boundary Conditions3.6 Potential Receptors

3.6.1 Human3.6.2 Environmental

4.0 SITE CONCEPTUAL MODEL4.1 Sources of Potential Impacts4.2 Migration Pathways43 Receptors

5.0 SITE MANAGEMENT STRATEGY5.1 Probable Remedial Action Objectives5.2 Probable Response Actions

5.2.1 Short-term5.2.2 Long-term

*53 Identification of Separate Operable Units

5.4 Probable Sequence of Response Actions

Table 1. Suggested Preliminary Site Evaluation Report/Technical Scope Format

5.5 Data Collection Needs5.5.1 Soil5.5.2 Ground Water5.5.3 Surface Water5.5.4 Air5.5.5 Risk Assessment

6.0 DATA QUALITY OBJECTIVES6.1 Data Types and Uses6.2 Data Quality Needs6.3 Data Quantity Needs6.4 Sampling and Analysis Options6.5 PARCC Parameters

7.0 RI/FS TASKS8.0 REQUEST FOR ARAR NOTIFICATION9.0 SCHEDULE10.0 PROJECT MANAGEMENT

10.1 Lead Contacts10.1.1 Waste Management of Illinois, Inc.10.1.2 USEPA10.1.3 Illinois EPA10.1.4 Consultant

10.2 Project Communications103 Progress10.4 Problem Identification/Resolution

11.0 REFERENCES

Information and data that are gathered during these initial steps will be used to preparea Preliminary Site Evaluation Report (PSER). The purpose of the PSER is tosummarize the existing site conditions and identify additional characterization datarequirements so that the appropriate RI activities can be defined. A key component ofthe PSER is the development of a site conceptual model which will assist in focusing theRI data gathering and risk assessment activities. The PSER will address the following:

2.2.1 Site History

A chronology of the site history as it pertains to waste disposal activities (e.g. types,volumes) and ownership transfer will be prepared.

2.2.2 Site Characteristics

A description of pertinent site features, physiography, hydrology, and geology will bedeveloped.

2.2.3 Nature and Extent of the Problem

A summary of known or potential on-site and off-site health and environmental effectswill be prepared based on existing information. Threats or potential threats to publichealth and the environment will be emphasized.

2.2.4 History of Response Actions

A history of response actions conducted by local, state, or private parties will beprepared.

2.2.5 Definition of Boundary Conditions

Site boundary conditions will be established to identify the areas of investigation. Theboundaries will be set so that the on-site activities will cover the contaminated media in

sufficient detail to support the FS. Boundaries for site access control and site boundarysecurity will also be identified. The boundaries of the study area may or may notcorrespond to the property boundaries.

2.2.6 Identification of Potential Receptors

Potential receptors, human and environmental, will be identified and used in thedevelopment of the site conceptual model, migration pathway assessment, and riskassessment. Included will be the identification of private and public water supply wellswithin a two-mile radius of the site. If possible, well construction details for these wells

-/and other private water supply wells, which may have been previously sampled, will beobtained.

2.2.7 Development of Site Conceptual Model

Information on the waste sources, pathways, and receptors at the site will be used todevelop a conceptual site model to evaluate potential risks to human health and theenvironment. The conceptual site model will include all known and suspected sources ofcontamination, types of contaminants and affected media, known and potential routes ofmigrations, and known or potential human and environmental receptors. If data areunavailable for components of the model, the likely variability in the component will beidentified so that the model identifies the possible range of contaminant migration andthe potential effects on receptors. The site conceptual model, in addition to assisting inidentifying where samples need to be taken, will also assist in identifying appropriateremedial technologies.

23 Technical Scope

The purpose, description and overall schedule of RI/FS activities will be provided in theTechnical Scope (TS). The TS will provide clear direction as to the goals and qualityobjectives of the data collection efforts to be conducted during the RI. The intent ofthe TS is to provide a framework for the subsequent development and review of the

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other RI/FS project plans (Task 2). The activities comprising the development of theTechnical Scope include the following:

23.1 Development of Site Management Strategy*

Based on the conceptual model of the site, preliminary identification of potentialremedial action objectives and appropriate response actions will be performed in orderto identify the specific data needed to evaluate alternatives and support the design ofprobable response actions at the site. This process will assist in streamlining the RI/FS

i so that data collection focuses on the data needs of specific alternative evaluations. Asappropriate, identification of remedial action objectives will address both short and long-term objectives for site management.

The development of the site management strategy will also address the potential forimplementing interim remedies as separate operable units and initiating TreatabilityStudies early in the overall RI/FS process. The optimal sequence of site actions andactivities will also be evaluated, including opportunities for combining the identificationand screening of remedial action alternatives where the range of alternatives appearslimited. The site management strategy will thus become the framework for data

v collection during the RI and intended uses of the data.

2.3.2 Evaluation of Data Quality Objectives (DOOs)

Once the site data needs are identified, the quality of the data needed to supportresponse decisions will be reviewed. The types of data needed, as well as the quantityand quality of data, will be reviewed for each major site activity. As appropriate,sampling and analysis options capable of providing the above will be identified. Dataprecision, accuracy, representativeness, completeness, and comparability (PARCC) goalswill also be established and reviewed to select a technical approach toward sampling andanalysis methods.

2.3.3 Identification of RI/FS Tasks

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Based on the evaluation of the project data needs and quality objectives, the work elementsof the RI/FS will be broken down into defined tasks and subtasks. The definition of workelements will serve as the basis for establishing methods and procedures which will needto be addressed in the Sampling and Analysis Plan (Task 2).

2.3.4 Request for ARAR Notification

Based on the site management strategy and the definition of work elements, respondentswill prepare, as part of the TS, a formal request to U.S. EPA and all regulatory entities forApplicable or Relevant and Appropriate (ARAR) and To Be Considered (TBC)requirements for the performance of the RI/FS. The ARARs and TBCs that would addressRI/FS activities may include regulations and policies regarding monitoring well construction,investigative waste management, laboratory studies, etc. Should it be determined, as panof the development of the site management strategy, that an operable unit is appropriateearly in the RI/FS process, a formal ARAR request will address such activities.

2.3.5 Schedule

An anticipated schedule will be formulated to implement the RI/FS tasks and subtasksidentified in Task 2.2.3, including the development and approval of the project plans.The

^•^ schedule will also show deliverable dates and anticipated project planning/coordinationmeetings with USEPA and IEPA. Upon approval of the final TS, the project schedulewill become enforceable under the terms of the Administrative Consent Order.

2.3.6 Project ManagementLead personnel for respondents and their consultant, USEPA, and IEPA will be establishedto facilitate project communications, progress reporting, quality assurance, and problemidentification/resolution. These management elements will be addressed in the TS toassure that the USEPA and IEPA are kept abreast of RI/FS activities and progress, as wellas assist in timely response to unanticipated site characterization findings potentiallydictating modification of the TS.

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2.4 Investigative Support Activities

During preparation of the PSER/TS, activities will be initiated to facilitateimplementation of the site characterization work. The activities include development ofsite base maps needed in preparing the SAP and initiating site access and procuringsupport facilities, as described below.

2.4.1 Site Mapping

An accurate topographic map of appropriate working scale and contour interval will beprepared. The base map of the site will be prepared from this topographic map and willhave a scale of one inch to 100 feet (1MOO') and two-foot contour intervals. The basemap will illustrate the locations of wetlands, floodplains, water features, drainagepatterns, tanks, buildings, utilities, property boundaries, paved areas, easements, rights-of-way, and other pertinent features. Larger scale maps will be produced from the basemapping, as necessary.

Surveying will be required to establish horizontal and vertical controls for the siterelative to the National Geodetic Vertical Datum of 1929. In addition to thetopographic map, a grid plan will be prepared using the base map and grid overlay at anominal scale of the map. This grid plan will show the location of existing monitoringwells, additional wells installed, all sampling locations, and water supply wells.

A legal description of the property will be reviewed and field checked. The intent is notto perform a boundary survey, but to locate the boundaries so that the future activitiesdo not carry over onto adjacent properties without proper permission.

2.4.2 Metes and Bounds

A legal description of the site will be assembled from existing county and townshiprecords and results of the site survey.

?.4.3 Access Arrangements

The necessary arrangements will be made to facilitate access to the site and surroundingparcels. These arrangements will include negotiating access agreements with theappropriate landowners, the demarcation of all buried utilities, and construction ofaccess roads.

2.4.4 Preparation of Support Facilities '

Arrangements will be made to construct the appropriate support facilities and/orprocure the equipment necessary to perform a site investigation. This includespreparation of decontamination facilities, utility hookups, and site access control stations.

3.0 TASK 2: RI/FS PROJECT PLANS

Upon receipt of the USEPA's approval, in consultation with the IEPA, of the PSER/TSand respondents, through its consultant, will initiate preparation of specific project plansfor implementing the site investigation. These plans include the following:

* Sampling and Analysis Plan,Field Sampling Plan,Quality Assurance Project Plan,

* Health and Safety Plan,* Risk/Endangerment Assessment Plan,* Data Management Plan, and

ATSDR Health Assessment.

The scope of each of these plans are addressed below.

3.1 Sampling and Analysis Plan (SAP')

^"^ The SAP consists of two pans which include the following:

* Field Sampling Plan which details the specific guidance for the fieldactivities and sampling locations/methods to be utilized.

* Quality Assurance Project Plan that describes the policy, organization,functional activities, and quality assurance/quality control protocolsnecessary to achieve the DQOs dictated by the intended use of the data, asdescribed in the WP.

Each of the elements of the SAP are summarized below.

3.1.1 Field 'Sampling Plan fFSPI

A FSP that addresses all data acquisition activities will be prepared. The plan willcontain a statement of sampling objectives, specification of equipment, required analyses,sample types, sample location, and frequency. The plan will address specific hydrologic,hydrogeologic, and air transport characterization methods including, but not limited to,geologic mapping, geophysics, field screening, drilling and well installation, ground waterflow determination, and sampling. The application of these methods will be describedfor each major subtask within the site investigation (e.g., waste characterization,migration pathway assessment, and contaminant characterization). The plan will also

i identify the data requirements of specific remedial technologies which may be necessaryto evaluate remedial alternatives in the FS. It will include an evaluation explaining whatadditional data are required to adequately characterize the site, evaluate the no-actionalternative, and support the feasibility study. It will provide a schedule stating whenevents will take place and when deliverables will be ready.

The Compendium of Superfund Field Operations Method (EPA/540/P-87/001a,OSWER Directive 9355.0-14, Sept. 1987) will be utilized in the selection and definitionof field methods, sampling procedures, and custody. These methods will be incorporatedin the SAP by reference.

O3.1.2 Quality Assurance Project Plan (OAPP^

A QAPP, prepared in accordance with current U.S. EPA Region V guidance (June1989), will be appended to the FSP. The purpose of the QAPP is to ensure that formalprocedures are employed for all activities affecting the quality of data collected.

The QAPP will be prepared according to the U.S. EPA guidance documents and willinclude the following elements:

1) Title page with provisions for approval signatures,2) Table of Contents,3) Project description,4) Proper organization and responsibility,

5) QA objectives for measurement data in terms of precision, accuracy,completeness, representativeness, and comparability (for each parameter),

6) Sampling procedures,7) Chain-of-custody procedures,8) Calibration procedures and frequency,9) Analytical procedures,

10) Data reduction, validation, and reporting,11) Internal quality control checks,12) Performance and system audits and frequency,13) Preventive maintenance procedures and schedules,14) Specific routine procedures to be used to assess data precision, accuracy,

and completeness of specific measurement parameters involved,15) Corrective action, and16) Quality assurance reports to management.

Table 2 shows the suggested formats for the FSP and QAPP.

3.2 Health and Safety Plan

A Health and Safety Plan (HSP) will be prepared to address hazards that investigationactivities may present to the investigation team and to the surrounding community. TheHSP will conform to applicable regulatory requirements and guidance, including:

20 CFR 19l0.120(i)(2) - Occupational Health and Safety Administration:Hazardous Waste Operations and Emergency Response, Interim Rule,December 19, 1986.

U.S. EPA Order 1440.2 - Health and Safety Requirements for EmployeesEngaged in Field Activities.

U.S. EPA Order 1440.3 - Respiratory Protection.

U.S. EPA Occupational Health and Safety Manual.

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U.S. EPA Interim Standard Operating Procedures (September, 1982).

The plan will identify personnel responsibilities, protective equipment, decontaminationmethods, medical surveillance and problems or hazards that may be encountered andtheir solutions. Procedures for protecting third parties will also be provided.

3.3 Endangerment Assessment Plan

An Endangerment Assessment Plan will be developed for quantifying the risks posed bythe H.O.D. landfill, for analyzing the public health impacts of the remedial alternativesand for identifying the baseline risks under the no action alternative. The methodologypresented in the plan will conform to the Interim Final Risk Assessment Guidance forSuperfund, Volume 1: Human Health Evaluation Manual (12/89),* and Vol. 2:Environmental Evaluation Manual (3/1989).

3.4 Data Management Plan

A Data Management Plan will be developed to document and track -the investigationdata and results. The plan will identify and establish laboratory and data documentation

materials and procedures, project file requirements, and project-related progressreporting procedures and documents.

"The complexity of the HOD Landfill will be defined initially in task 2.2.7-DeveIopmemof the Site Conceptual Model and may be subsequently modified as the RI activitiesprogress. The steps and procedures necessary to complete the Superfund Human HealthEvaluation process will be dependent on the site complexity.

3.5 ATSDR Health Assessment Needs

The project plans will provide for collection of adequate information to support anATSDR Health Assessment which is required by SARA. Since the health assessmentwill be prepared by ATSDR, the PSER/TS and supporting project plans will besubmitted to ATSDR for review and comment to ensure that their needs andrequirements are being met. In the event that the preliminary health assessment hasalready been completed by ATSDR, the- RI Report will address the findings of thatreport.

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Table 2. Suggested SAP (QAPP and FSP) Format

FSPTitle PageTable of Contents1. Site Background (if not included in QAPP)2. Sampling Objectives3. Sample Location and Frequency ,4. Sample Designation

\^ 5. Sampling Equipment and Procedures6. Sample Handling and Analysis

QAPPTitle PageTable of Contents1. Project Description2. Project Organization3. QA Objectives for Measurement4. Sampling Procedures5. Sample Custody

i 6. Calibration Procedures7. Analytical Procedures8. Data Reduction, Validation, and Reporting9. Internal Quality Control\10. Performance and Systems Audits11. Preventative Maintenance12. Data Assessment Procedures13. Corrective Actions14. Quality Assurance Reports

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4.0 REMEDIAL INVESTIGATION (Rl)

4.1 Overview

The objectives of the RI are to:

* Characterize the source(s) of potential contamination;

* Characterize the site hydrogeologic and physical setting, characterize, contaminant sources, their nature and extent, evaluate the most likely

contaminant migration pathways and physical features that could affectpotential remedial actions;

* Determine the migration rates, extent, and characteristics of anycontamination that may be present at the site;

" Gather data and information to the extent necessary and sufficient toquantify risk to public health and the environment; and

. * Support the development and evaluation of remedial alternatives in theFS.

The remedial investigation consists of six tasks as follows:

Task 3: Site Investigation,Task 4: Site Investigation Analysis,Task 5: Baseline Risk Assessment,Task 6: Treatability Studies,Task 7: Reports, andTask 8: Community Relations Support.

A description of each of these tasks is presented in the following sections.

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4.2 Task 3: Site Investigation

Investigations necessary to characterize the site and its actual or potential hazard to publichealth and the environment will be conducted. The investigations will result in data ofadequate technical content to support the development and evaluation of remedialalternatives during the FS. Investigation activities will focus on problem definition anddata collection to support the screening of remedial technologies, alternative developmentand screening, and detailed evaluation of alternatives. Conductance of the site investigationactivities will follow U.S. EPA approval, in consultation with the IEPA, of the PSER (Task1) and the Project Plans set forth in Task 2. A description of the types of investigationsthat are anticipated is presented in the following subsections.

4.2.1 Task 3.1 Physical Characterization

The H.O.D, Landfill site will be physically characterized through the following types ofinvestigations.

Hydrogeologic:

A hydrogeologic study will be performed to further evaluate the subsurface geology and^ characteristics of the water formations. This study will define the site hydrostratigraphy,

controlling geologic features, zones of preferential ground-water transmission, and thedistribution of hydraulic heads within the water bearing formations. These data will formthe rationale for locating and designing monitoring wells and the subsequent contaminantcharacterization. The wells shall be located to provide information on the direction ofground-water flow and extent of impacted ground-water.

Hydrologic:

Drainage patterns and runoff characteristics will be evaluated for the potential of erosionaltransport. Surface water features such as streams, ponds, and lakes will also be evaluated.Staff gauges may also be used to evaluate the potential for hydraulic

22

connection between surface water bodies and the groundwater flow system, and todetermine the potential for sediment transport.

Soil and Sediments:

The physical and chemical characteristics of the site soils and aquatic sediments will beevaluated. This evaluation will consider the containment and attenuation capabilities ofsubsoils, characteristics of the existing landfill cover, and chemical characteristics ofproximate surface water sediments. The types of physical tests that may be performed aspart of this characterization include grain-size analysis, permeability, Atterburg limits, cationexchange capacity, etc.

Air:

The potential for airborne particle and vapor transport will be evaluated to determine ifan atmospheric testing program (over and above that required for assuring the personalprotection of the site workers and surrounding community) should be initiated at laterproject stages. Meteorological data may be required to characterize the atmospherictransport. Methane and VOC emissions will be evaluated to determine if rates of emissiondictate higher levels of protection during the RI or warrant possible consideration in thedevelopment of site remedial response objectives.

Human Population:

Information will be collected to identify, enumerate, and characterize human populationswhich could be exposed if contaminants were released from the site. For a potentiallyexposed population, information will be collected on population size and location. Theidentification of these populations will be linked with the potential contaminants of concern(i.e., those that are mutagenic, teratogenic, etc.) to identify potential risk. Census and othersurvey data may be used to identify and describe the population exposed to variouscontaminated media. Information may also be available from USGS maps, land use plans,zoning maps, and regional planning authorities. Copies of the water supply well logs withina two-mile proximity to the site will be submitted if available.

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Ecological Investigations:

Biological and ecological information will be collected for use in the risk assessment.The information will include a general identification of flora and fauna in and aroundthe site (including endangered and threatened species and those consumed by humans orfound in human food chains) and identification of critical habitats. Bioassay informationmay be needed for species that are known to be consumed by humans. It is anticipatedthat this information will be derived from a combination of existing information anddata resulting from the field investigations.

4.2.2 Source Characterization

An investigation will be carried out to characterize the physical and chemical aspects ofthe waste material and the materials in which they are contained. The investigation ofthese source areas will involve obtaining data related to:

* Waste characteristics (type, quantity, chemical and physical properties, andconcentrations); and

* Facility characteristics (type and integrity of containment, leachatecollection systems, and drainage control).

It is anticipated that this information will be obtained from a combination of existingsite information, field inspections, and site sampling activities.

The source characterization will culminate in the preparation and submittal of aTechnical Memorandum (#1). This memorandum will summarize the findings of thephysical and source characterizations and will recommend monitoring/samplinglocations, parameters, or classes of parameters, which will be the focus of subsequentcontaminant and migration pathway characterization studies.

4.2.3 Contaminant Characterization

Data generated from the Physical and Source Characterizations will also be used todesign an environmental sampling and analysis program. The objective of this programis to evaluate the extent and magnitude of contamination, if any, along pathways ofconcern at the H.O.D. Landfill site. Additional monitoring points may be installed asappropriate in each media previously identified in the physical site characterization as amigration pathway. The characterization of extent and magnitude of contamination willextend outward from source areas until either background characteristics are observed,or until the risk to public welfare and the environment is within an acceptable level ofrisk. Characterization of the extent and magnitude of contamination may be affected byaccess to off-site properties. Should access be limited, respondents will utilizeacceptable extrapolation procedures, such as analytical or numerical models, to estimaterepresentative exposure concentrations.

The analytical parameters list used in this subtask will be based on the data collectedduring the source characterization and review of background information. The selectionof parameters or classes of parameters (i.e., volatile organics, metals, etc.) will be basedupon their source concentration and their persistence and mobility within the most likelyand reasonable pathway(s) of migration. All samples will be collected, handled andanalyzed in accordance with the protocols and procedures described in the site QAPP.

4.2.4 Migration Pathways

The above site characterization activities will be used to define contaminant migrationpathways in air, surface water, ground water, soil and sediment. Such potentialmigration pathways will be evaluated in sufficient detail to support the Baseline RiskAssessment with respect to exposure routes and likely exposure levels to the public andenvironment.

4.3 Task 4: Site Investigation Analysis

4.3.1 Quality Assurance and Data Sufficiency Evaluation

An analysis of all data collected during the site investigation will be reviewed to assurethat the quality (e.g., QA/QC procedures have been followed) and quantity of dataadequately support the Risk Assessment and FS.

4.3.2 Additional Data Collection

Should the results of the Phase H Site Investigation (Figure 1) indicate that additionaldata collection or performance assessments are required to screen remedial alternatives,a supplemental work plan will be prepared and submitted for USEPA and IEPA reviewand USEPA approval in consultation with IEPA. The project plans described in Task 2will also be modified to reflect the additional work requirements.

As shown in Figure 1, provisions will be made for conducting additional siteinvestigation activities after the completion of the Remedial Alternatives Screening(Task 7). These supplemental investigations are intended to further characterize thesources, pathways, and/or contaminants and to satisfy the specific data requirements ofthe applicable remedial actions which may be necessary. In addition to these specificjunctures of the RI/FS, additional data collection will be proposed at any point of theinvestigation where it is deemed necessary.

<^Technical memorandum #2 will be prepared following this task which will report on theresults of Tasks 4.2.3, 4.2.4 and 43. The format of this technical memorandum willreflect the draft RI Report format discussed later in this section.

4.4 Task 5: Baseline Risk Assessment

A Risk Assessment will be prepared describing the specific contaminants at the H.O.D.Landfill site and ambient levels at the site, the number and location and types of nearbypopulation activities and pathways that may result in an actual or potential threat topublic health, welfare, or the environment. A projection of concentrations at thedifferent points of exposure through each media pathway over the likely period ofexposure will "be made along with the toxicity of exposure levels. Based on the above,potential carcinogenic, noncarcinogenic, and environmental risks will be estimated. This

assessment will be conducted in accordance with the procedures described in theapproved Risk/Endangerment Assessment Plan. A general outline of work for theRisk/Endangerment Assessment follows:

Select target chemicals for evaluation based on the following criteria: thedegree each chemical contributes to site risks; the representativeness of thechemical across site media; or the representativeness of the chemical to asignificant source.

» Conduct exposure assessments that include the identification of acute andchronic hazards of concern and the population(s) at risk,

Evaluate existing toxicity information and determine the potential acuteand chronic effects of the site contaminants, as well as the specific effectssuch as carcinogenicity, reproductive dysfunction, teratogeny, neurotoxicity,and other metabolic alterations; and environmental effects of aquatic andterrestrial toxicities.

Assess impact by identifying acceptable exposure guidelines or standards,comparing estimated doses with these guidelines or standards. For targetchemicals at the site that are designated as carcinogens by EPA, use EPA'sevaluations to estimate the increased cancer risks.

Technical Memorandum #3 will be prepared and submitted documenting theRisk/Endangerment Assessment.

4.5 Task 6: Treatability Studies

If necessary, bench and piloting scale testing studies may be performed to determine theapplicability of selected remedial technologies to site specific conditions. These mayinclude treatability and cover studies, aquifer testing, and/or material compatibilitytesting. These studies may be conducted at any stage of the RI/FS. The factors whichdetermine the point at which these studies are initiated include length of time to

complete, requisite site-specific data requirements and logistical constraints. Thesefactors will be considered in Task 2.3.3 - Identification of RI/FS Tasks, and TreatabilityStudies will be proposed at the appropriate juncture. Detailed plans for these studieswill be incorporated in the initial sampling and analysis Plan (SAP) or supplements tothe SAP. If required, supplements to the appropriate plans (i.e., FSP, QAPP) will beprepared and submitted to the USEPA and IEPA for review and USEPA approval, inconsultation with IEPA, prior to initiation of this task. The results of the treatabilitystudies will be incorporated into the final RI Report.

4.6 Task 7: Reports

4.6.1 Monthly Progress Reports

Progress reports will be prepared and submitted to the USEPA and IEPA on a monthlybasis. These reports shall be submitted to the USEPA and IEPA by the 7th businessday of each month, subsequent to the effective date of the Consent Order. Each reportwill summarize the technical progress of the RI/FS. The progress reports shall includethe following information.

* All sampling and testing results and all other validated data producedduring the month, pursuant to the implementation of the ConsentAgreement;

* A description of activities completed during the past month, as well assuch actions and plans which are scheduled for the next month;

* Target and actual completion dates for each element of activity, includingthe project completion, and an explanation of any deviation from theschedules provided in the TS;

* Changes in key personnel;

* Problems encountered and how they were resolved; and

Anticipated problems and recommended solutions.

4.6.2 Technical Memoranda

The results of specific RI activities such as the Risk Assessment, and Site Characterizationwill be submitted to the USEPA and IEPA throughout the RI/FS process. Thesememoranda will be submitted in draft form. Respondents response to review commentsprovided by the USEPA, in consultation with the IEPA and other agencies, will be providedto USEPA and IEPA in letters submitted by the respondent's Project Coordinator. AnyUSEPA requested revisions to the technical memoranda will be provided in the draft orfinal RI reports as appropriate. The specific technical memoranda and their associatedschedule will be identified in the TS. Technical memoranda will include the following:

#1: Physical and Source Characterization Results,#2: Contaminant and Migration Pathway Characterization Results, and#3: Risk Assessment.

4.6.3 Draft Remedial Investigation Report

A draft report summarizing the remedial investigations will be prepared and submitted afterrespondent receives the USEPA's comments, in consultation with the IEPA, on respondent'sresponse summaries on the Technical Memoranda. Technical memoranda preparedpreviously will be prepared in a format such that they can be directly incorporated in theRI report. The format for the RI Report will generally follow the October, 1988 RI/FSguidance document. The report will characterize the site and

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summarize the data collected and conclusions drawn from the preceding tasks.

report will be submitted in draft form for review and comment. The RI report will

not be considered final until site characterization activities are complete for

supporting remedial alternatives screening activities and a letter of approval is

issued by the USEPA Remedial Project Manager. A meeting may be scheduled with USEPA

and IEPA to discuss comments on the draft RI report. USEPA will submit the draft RI

report to A3SER for a health assessment.

4.7 Task 8: Community Relations Support

A community relations program will be implemented jointly by the USEPA and the

IEPA. Die Respondent will cooperate with the USEPA in providing RI/FS information

to the public. The Respondent will, at the request of the USEPA, participate in the

preparation of information distributed to the public, such as fact sheets, and in

public meetings that may be held or sponsored by the USEPA to describe activities

at, or concerning, the site, including the findings of the RI/FS. In light of the

pending litigation involving this site, USEPA shall make reasonable efforts to

provide the Respondents an opportunity to review and comment on all public

information releases prior to dissemination to the public so long as such

commentary does not unreasonably delay such releases. Community relations support

will be consistent with Superfund community relations policy, as stated in the

"Guidance for Implementing the Superfund Program" and Ooronunity Relations in

Superfund - A Handbook.

4.8 Task 9: Conduct Interim Actions

The IS (Task 1) included the review of probable RD/RA activities in planning the

site characterization portion of the RI. In some cases, the RA alternatives may be

very limited and require minimal site characterization in order to select a remedy.

If appropriate, RA activities will be categorized as operable units to the extent

possible and these activities will be evaluated for possible streamlining of the FS

process, thereby accelerating remedial action.

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Where implementation of an interim RA is obvious and will result in more timely siteremediation, respondent will document the proposed interim RA as follows:

* Justification of Interim RA recommendation on the basis of technical,environmental and human health factors;

* Objectives of the interim measures: how the measure mitigates a potentialthreat to human health and the environment and/or is consistent with anintegrated into any long term solution at the facility;

* Design, construction, operation, and maintenance requirements;

* Schedules for design, construction and monitoring;

* Method(s) for monitoring the effectiveness of the interim measures;

* Schedule for progress reports.

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5.0 FEASIBILITY STUDY

5.1 Overview

The purpose of the FS for the H.O.D. landfill site is to develop and evaluate remedialalternatives, based on the results of the RI, that protect human health and theenvironment, and present the relevant information needed to allow for the selection of asite remedy, if required, which will be protective of human health and the environment.The FS will conform to Section 121 of CERCLA as amended by SARA; the NCP, asamended; and the FS Guidance, as amended. The FS encompasses Phase III of the

v^-*RI/FS process, and is comprised of the following tasks:

Task 10: Remedial Alternatives Screening

Task 11: Screening of Alternatives

Task 12: Treatability and Supplemental Remedial Investigations

Task 13: Detailed Analysis of Alternatives

Task 14: Feasibility Study Report

Task 15: Community Relations Support

The intent and purpose of each of these tasks is outlined in the following sections. Thetechnical approach and schedule for each of these tasks will be detailed in the RI/FSWork Plan.

5.2 Task 10: Development of Remedial Action Alternatives

•

This task may consist of steps that involve making successively more specific definitionsof potential remedial activities. These steps are described as follows:

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S.2.1 Develop Remedial Action Objectives

Site-specific objectives for remedial action established during the RI will be reviewed forthe H.O.D. Landfill site considering the description of the current situation, informationgathered during the RI, Section 300.68 of the NCP, (or as amended) U.S. EPA interimguidance, and the requirements of other applicable U.S. EPA, Federal, and Illinoisenvironmental standards, guidance, and advisories.

These objectives consist of media-specific or operable unit-specific goals for protectingy^ human health and environment. They will specify: the contaminant(s) of concern,

exposure route(s), and receptor(s), and an acceptable contaminant level or range oflevels for each exposure route.

Acceptable exposure levels for human health will be determined on the basis of riskfactors and chemical-specific ARARS. Contaminant levels in each media will becompared with these acceptable levels, which will be determined on the basis of anevaluation of the following factors:

* For carcinogens, whether the chemical-specific ARARS are within the riski range of 10 -4 to 10 -6 (with 10 -6 as the point of departure) and whether

achievement of each chemical-specific ARAR will sufficiently reduce thetotal risk from exposure to multiple chemicals;

* For noncarcinogen, whether the chemical-specific ARAR is sufficientlyprotective if multiple chemicals are present at the site;

* Whether environmental effects (in addition to human health effects) areadequately addressed by the ARARS;

* Whether the ARARS adequately address all significant pathways of humanexposure identified in the baseline risk assessment. For example, ifexposure from the ingestion of fish and drinking water are both significant

pathways of exposure, application of an ARAR that is based only ondrinking water ingestion (e.g., MCLs) may not be adequately protective.

If an ARAR is determined to be protective, it will be used to establish the acceptableexposure level. In the situation that the ARAR is not protective (i.e., an existingstandard presents a risk greater than 10-4), or an ARAR doesn't exist for the specificchemical or pathway of concern, or multiple contaminants may be posing cumulative orcompounding risk, acceptable exposure levels will be identified through the riskassessment process.

5.2.2 Develop Genera! Response Actions

General response actions describing those actions that will satisfy the remedial actionobjectives will be developed. These may include no action or treatment, excavation,containment, extraction, disposal, institutional actions, or a combination of these.

5.2.3 Identify Volumes or Areas of Media

In this subtask, an initial determination is made of areas or volumes of media to whichgeneral response actions might be applied. This will be done for each medium of

^ interest at the H.O.D. Landfill site.

5.2.4 Identify and Screen Remedial Technologies and Process Options

In this subtask, applicable technology types and process options are screened byevaluating the options with respect to technical implementability. Technology types"refer to general categories of technologies, such as chemical treatment, thermaldestruction, solidification, capping, or dewatering. Technology process options" refer tospecific processes within each technology type. Several technology process options mayexist in each technology type. This screening is accomplished by using readily availableinformation from the RI to screen out technologies and process options that cannot beeffectively implemented.

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5.2.5 Evaluate Process Options

In this subtask, the technology processes considered to be implementable are evaluatedin greater detail before selecting one or two processes to represent each technology type.One, or in some cases, two, representative processes are selected, if possible, for eachtechnology type to simplify the subsequent development and evaluation of alternativeswithout limiting flexibility during remedial design. Process options are evaluated usingeffectiveness, implementability, and cost criteria. These criteria are applied only totechnologies and the general response actions they are intended to satisfy - not to the

^. site as a whole. Also, the evaluation will-typically focus on the effectiveness factor.

5.2.6 Assemble Alternatives

Alternatives are assembled using a combination of general response actions and theprocess options chosen to represent the various technology types for each media oroperable unit, for the site as a whole. Alternatives to be developed will include at leastthe following:

a. Treatment alternatives for source control that eliminate or minimize thei need for long-term management (including monitoring);

b. Alternatives involving treatment as a principal element to reduce thetoxicity, mobility, or volume of waste;

c. An alternative that involves containment of waste with little or notreatment but provides! protection of human health and the environment,primarily by preventing exposure or reducing the mobility of the waste;

d. A no action alternative.

5.2.7 Alternatives Array Document

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To obtain ARARS and TBCs from the USEPA and the IEPA, a formal requestproviding a detailed description of alternatives (including the extent of remediation,contaminant levels to be addressed, and method of treatment) will be prepared. Thisdocument will also include a brief site history and background, a site characterizationthat indicates the contaminants of concern, migration pathways, receptors, and otherpertinent site information. A Technical Memorandum (#4) will be prepared andsubmitted to the USEPA and IEPA detailing evaluations conducted in Task 10 by eachsubtask, along with the request for a notification of the ARARs and TBCs.

^ 5.3 Task 11: Screening of Alternatives

This task will narrow the list of potential alternatives that will be evaluated in detail andis comprised of the following steps:

* The alternatives are further refined as appropriate;

* They are evaluated on a general basis to determine their effectiveness,implementability, and cost; and

L * A decision is made, based on this evaluation, as to which alternativesshould be retained for further analysis.

5.3.1 Alternative Definition

In this subtask, alternatives will be further defined to form a basis for evaluation andcomparing them prior to their screening. Sufficient quantitative information to allowdifferentiation among alternatives with respect to effectiveness, implementability, andcost is required. Parameters that require additional refinement include the extent orvolume of contaminated material and the size of major technology and process options.The following information should be developed, as appropriate, for the varioustechnology processes used in an alternative:

* Size and configuration of on-site extraction and treatment systems orcontainment structures;

* Time frame in which treatment, containment, or removal goals can beachieved;

* Rates or flows of treatment;

* Spatial requirements for constructing treatment or technologies for stagingconstruction materials or excavated soil or waste;

* Distances for disposal technologies;

* Required permits and imposed limitations.

5.3.2 Screening Evaluation

In this subtask, defined alternatives are evaluated against short- and long-term aspects ofthree broad criteria: effectiveness, implementability, and cost. These are described asfollows:

* Effectiveness: Alternatives will be evaluated to determine whether theyadequately protect human health and the environmental; attain Federaland Illinois ARARS or other applicable criteria, advisories, or guidance;significantly and permanently reduce the toxicity, mobility, or volume ofthe hazardous constituents are technically reliable; and are effective inother respects. The consideration of reliability will include the potentialfor failure and the need to replace the remedy.

* Implementability: Alternatives will be evaluated as to the technicalfeasibility and availability of the technologies that each alternative would

t employ; the technical and institutional ability to monitor, maintain, and

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replace technologies over time; and the administrative feasibility ofimplementing the alternative.

' Cost: The cost of construction and long-term costs to operate andmaintain the alternative will be evaluated. This evaluation will be basedon conceptual costing information and not a detailed cost analysis. At thisstage of the FS, cost will be used as a factor when comparing alternativesthat provide similar results, but will not be a consideration of the screening

, stage when comparing treatment and nontreatment alternatives.\w>

5.3.3 Alternative Screening

In this subtask, alternatives with the most favorable composite evaluation of all factorsare retained for further consideration during detailed analysis. Alternatives selected willpreserve the range of treatment and containment technologies initially developed plusthe no action alternative.

A Technical Memorandum (#5) will be prepared and submitted to the USEPA andIEPA detailing Task 11 by each subtask. A meeting will also be scheduled with theUSEPA to discuss (1) the set of alternatives selected for detailed analysis, and (2) theneed for treatability and supplemental remedial investigations and what form they wouldtake.

5.4 Task 12: Treatability and Supplemental Remedial Investigations

Data Requirements not already available through the Remedial Investigation that arespecific to the remedial alternatives identified for detailed analysis in Task 11 will beidentified. These additional data needs may involve the collection of sitecharacterization data, supplemental remedial investigations, or treatability studies tobetter evaluate technology performance.

5.4.1 Determination of Data Requirements

Additional data needs can be identified by conducting a more exhaustive literaturesurvey than was originally conducted when potential technologies were initially beingidentified. The objectives of a literature survey are as follows:

* Determine whether the performance of those technologies underconsideration have been sufficiently documented on similar wastesconsidering the scale and the number of times the technologies have beenused.

" Gather information on relative costs, applicability, removal efficiencies,O&M requirements, and implementability of the candidate technologies.

* Determine testing requirements for bench or pilot studies, if required.

5.4.2 Treatability Testing

Treatability testing performed during an RI/FS is used to adequately evaluate a specifictechnology, including evaluating performance, determining process sizing and estimatingcosts in sufficient detail to support the remedy selection process. It is not meant to beused solely to develop detailed design or operating parameters that are moreappropriately developed during the remedial design phase. Bench-scale or pilot-scaletechniques may be utilized but, in general, treatability studies will include the followingsteps:

* Preparing a work plan (or modifying the existing work plan) for the benchor pilot studies for USEPA approval in consultation with IEPA.

* Performing field sampling, and/or bench testing, and/or pilot testing;

* Evaluating data from field studies, and/or bench testing, and/or pilottesting; and

' Preparing a brief report documenting the results of the testing.

A Technical Memorandum (#6) will be prepared and submitted to the USEPA andIEPA detailing Task 12.

5.5 Task 13: Remedial Alternatives Evaluation

Section 121(bXl)(A-G) of CERCLA outlines general rules for cleanup actions andestablishes the SARA statutory preference for permanent remedies, and for treatment

. and/or resource recovery technologies that reduce toxicity, mobility or volume ofhazardous substances, pollutants, and contaminants. Further, it directs that the long-term effectiveness of alternatives be specifically address and that at a minimum thefollowing be considered in assessing alternatives:

* Long-term uncertainties associated with land disposal;

* Goals, objectives, and requirements of the Solid Waste Disposal Act;

* Persistence, toxicity, mobility, and propensity to bioaccumulate ofhazardous substances and their constituents;

* Short- and long-term potential for adverse health effects from humanexposure;

* Long-term maintenance costs;

* Potential for future remedial actions costs if the alternative were to fail;and

* Potential threat to human health and the environment associated withexcavation, transportation and redisposal, or containment.

The U.S. EPA has developed nine evaluation criteria. Consideration of the criteria isintended to satisfy the statutory requirements; i.e., points A through G above, and toenable the decision maker to compare alternatives and select a remedy which will:

1. Be protective of human health and the environment;

2. Attain applicable or relevant and appropriate requirements (ARARS), orprovide grounds for invoking a waiver;

^3. Be cost effective;

4. Use permanent solutions and alternative treatment technologies to themaximum extent practicable; and

5. Satisfy the preference for treatment that reduces toxicity, mobility, orvolume as a principal element (or provide an explanation for why it doesnot).

. The evaluation of Alternatives task is basically a three-stage process consisting of thefollowing:

* Detailed development of alternatives;* Detailed analysis of alternatives; and* Comparison of alternatives.

5.5.1 Detailed Development of Alternatives

Each alternative will be defined in sufficient detail to facilitate subsequent evaluationand comparison. Typically, this activity may involve modification of alternatives basedon ARARS, refinement of quantity estimates, technology changes, or site areas to beaddressed. Prior to detailed definition, the final conceptual alternatives will be agreedon by the Respondents and the USEPA, in consultation with the IEPA.

S.S.2 Detailed Analysis of Alternativesrespondent will conduct a detailed analysis of alternatives which will consist of anindividual analysis of each alternative against a set of evaluation criteria and acomparative analysis of all options to assess relative performance in terms of theevaluation criteria. The nine evaluation criteria and their hierarchial order are asfollows:

Threshold Factors

* Protective of Human Health and Environment

* Compliance with ARARs

Balancing Factors

' Long-Term Effectiveness and Permanence

* Reduction of Toxicity, Mobility or Volume (TMV) throughTreatment

* Short-Term Effectiveness

* Implementability

* Cost

Modifying Factors

* Support Agency Acceptance* Community Acceptance

In evaluating the alternatives, the threshold factors must be satisfied prior toconsideration of the balancing factors. The balancing factors are only applied to thosealternatives that meet the threshold factors criteria. The modifying factors are appliedto the alternatives subsequent to the balancing factor evaluations.

The evaluation criteria are as follows:

Overall Protection of Human Health and the Environment addresses whetheror not a remedy provides adequate protection and describes bow risks posedthrough each pathway are eliminated, reduced, or controlled through treatment,engineering controls, or institutional controls.

Compliance with ARARs addresses whether or not a remedy will meet all ofthe applicable or relevant and appropriate requirements of other Federal andState environmental statutes and/or provide grounds for invoking a waiver.

Long-Term Effectiveness and Permanence refers to the ability of a remedy tomaintain reliable protection of human health and the environment over timeonce cleanup goals have been met.

Reduction of Toa'city. Mobility, or Volume Through Treatment is theanticipated performance of the treatment technologies a remedy may employ.

Short-Term Effectiveness addresses the period of time needed to achieveprotection and any adverse impacts on human health and the environment thatmay be posed during the construction and implementation period until cleanupgoals are achieved.

Implementability is the technical and administrative feasibility of a remedy,including the availability of materials and services needed to implement aparticular option.

Cost includes estimated capital and operation and maintenance costs, and netpresent worth costs.

State Acceptance (Support Agency) addresses the technical or administrativeissues and concerns the support agency may have regarding each alternative.

Community Acceptance addresses the issues and concerns the public may haveto each of the alternatives.

, The individual analysis shall include: (1) a technical description of eachalternative that outlines the waste management strategy involved and identifiesthe key ARARs associated with each alternative; and (2) a discussion thatprofiles the performance of that alternative with respect to each of theevaluation criteria. A table summarizing the results of this analysis should beprepared. Once the individual analysis is complete, the alternatives will becompared and contrasted to one another with respect to each of the evaluationcriteria.

In selecting a preferred alternative, USEPA will only consider selecting analternative that does not meet the Federal or State public health or

L *

environmental ARARs when:

1. The alternative is an interim remedy and will become part of a morecomprehensive final remedy that will meet the Federal and State ARARS.

2. Compliance with the ARAR will result in a greater risk to human healthand the environment than the alternative options.

3. Compliance with the requirements is technically impractical.

4. The alternative will attain a standard of performance that is equivalent tothat required under the otherwise applicable standard, requirement, orlimitation through the use of another method or approach.

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5. The State has not consistently applied or demonstrated the intent toconsistently apply the requirement at other similar facilities across the state.

$£3 Comparison of Alternatives

After each alternative has been individually assessed against each of the nine criteria, acomparative analysis will be conducted. The purpose of this analysis is to compare therelative performance of each alternative with respect to each specific evaluation criterion.The narrative discussion will describe the strengths and weaknesses of the alternativesrelative to one another with respect to each criterion, and how reasonable variations of keyuncertainties could change the expectations of their relative performance. If innovativetechnologies are being considered, their potential advantages in cost or performance andthe degree of uncertainty in their expected performance (as compared with moredemonstrated technologies) will also be discussed. A summary table should be preparedhighlighting the assessment of each alternative with respect to each of the nine criteria.

A Technical Memorandum (#7) will be prepared and submitted to the USEPA and IEPAdetailing Task 13 and will include a table summarizing the alternative analysis.

5.6 Task 14: Feasibility Study Report

The results of specific feasibility sZtudy activities will be submitted to the USEPA andIEPA in the form of technical memoranda throughout the RI/FS process. Thesememoranda will be submitted in draft form only. Responses to review comments providedby the USEPA, in consultation with IEPA, will be provided in letters submitted by therespondent Project Coordinator. These revisions will be provided in the draft or finalRI/FS reports as appropriate. The specific technical memoranda and their associatedschedule will be identified in the Work Plan.

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t•f

I </

A Feasibility Study Report covering the activities perfonned and conclusions dxawn

from Tasks 6, 10, 11, 12, and 13 will be completed following the receipt of the

USEPA's Garments on the technical memoranda. A draft report will be submitted to

the USEPA and IEPA for review and cement. A meeting will be scheduled to

USEPA's comments, if any, prior to preparation of the final draft report. One FS

report will not be considered the Public Ocmnent FS until a letter of approval is

issued by the USEPA Remedial Project Manager. The approved Public Ocmnent FS

report will be placed by the USEPA in the public repositories for public review

and ocranent as per the Ocnnunity Relations Plan for this site. Ihe report will

completely document the FS effort. The format for the Feasibility Study Report

will generally follow the October, 1988 RI/FS guidance document.

5.7 Task 15: OcOTTiinitv Relations Program

A program for the community relations support will continue throughout the FS, to

selection of a site remedy. Such support will be consistent with that described in

Task 8.

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