The remediation of Bennett's Quarry is being performed under the Consent Decree entered on August 27, 1985, in Civil Action No. IF 83-9-C and IF 81-448-C. The Federal District Court of Southern Indiana is overseeing the implementation of the Consent Decree.

This Work Plan has been prepared by CBS based on the Statement of Work (SOW) for the Remedial Action at Bennett's Quarry as prepared by the USEPA and dated June 25, 1999. It will be revised as necessary to satisfy the final SOW and the final applicable or relevant and appropriate requirements (ARARs), when agreed upon.

This Work Plan is being sent to the Indiana Department of Environmental Management (IDEM), the United States Environmental Protection Agency (USEPA) and Monroe County and the City of Bloomington (collectively, "the Consent Decree [CD] Parties").

Bennett's Quarry is a former limestone quarry that was operated as an industrial dump during the 1960's. During that time waste materials from the Westinghouse Bloomington plant were disposed of at Bennett's Quarry by waste haulers. The waste materials included whole capacitors (some drained and some ndrained), capacitor parts, filter aids and sawdust.

The scope of remedial activities includes site preparation; equipment and site layout; excavation and removal of waste materials; verification sampling; material handling and segregation; stormwater control and water treatment; waste loading, transportation and disposal; backfill and site restoration.

CBS started site preparation activities including clearing and access road building in mid July 1999. The remediation contractor is scheduled to mobilize on site in mid-August 1999.Excavation activities are anticipated to begin in late August or early September. The remediation work, including excavation and backfilling are scheduled to be completed by the end of 1999. Some final restoration work and re-vegetation may not be completed until the spring of 2000 due to the seasonal limitations. Specific project milestones are outlined in Section 5.

Bennett's Quarry is located in a rural setting in the central portion of Monroe County, Indiana, approximately 2.5 miles northwest of the City of Bloomington. The site consists of two areas. The main area is 3.5 acres in size and is located adjacent to Stout's Creek. Another area, referred to as the satellite area, is comprised of approximately 0.5-acre and is located approximately one hundred feet to the east of the main area. The main area is bounded by Stout's Creek to the west, and quarry access roads to the south and east. Figure 2 provides a Site Plan of Bennett's Quarry.

A third small area (approximately 30 by 60 feet) 750 feet north of the main area was to be remediated under the original Consent Decree. Based on a 1992 EPA sampling effort of this area that produced all non-detectable analytical results for PCBs, the CD parties all agreed that no further action was necessary there.

Historically, land in the vicinity of Bennett's Quarry has been used for quarrying operations. The quarries produce a finished building stone from the Salem Limestone, crushed stone for road construction, low-magnesium limestone for cement, and high-magnesium limestone for steel production and agricultural application. There is an inactive stone mill within 50 feet of the south west corner of the main fill. The Vernia Quarry, east of Bennett's Quarry, is currently active. The adjacent land to the west of the site, across from Stout's Creek is agricultural.

Bennett's Quarry is characterized by relatively flat topography with moderate slopes. The topography near the site is characterized by numerous rectangular water-filled pits (quarries) remaining from the quarry operations. The main fill area is on a gently westward sloping hillside east of Stout's Creek. Elevations at the site range between 710 and 750 feet above mean sea level. Stout's Creek flows north past Bennett's Quarry and is joined from the southwest by an intermittent stream near the western margin of the site.

The geology of Bennett's Quarry is characterized by a relatively thin layer of unconsolidated material overlying bedrock. The unconsolidated material at the site consists of fill material and indigenous soil. Fill materials range in depth to 13 feet and generally consist of black to brown clay, sand, and gravel with rubble, brick, glass, and porcelain. Material consisting of a very compact gravel was encountered in the upper three feet of unconsolidated material in the western portion of the site along the old railroad bed. This gravel fill ranged in thickness from 1.4 to 3 feet. Other fill materials consisting of a mixture of clay, limestone, and coal were encountered to the southern boundary of the main fill area. The predominant soil encountered at the site is a yellow/red/brown, stiff silty clay that ranges in thickness from approximately 2.5 to 5.5 feet. This silty clay grades with a red/gray, stiff clayey silt that ranges in thickness from 1.6 to 4 feet. The site contains large surface and subsurface limestone quarry blocks, which were abandoned during quarry operations.

Recharge to the groundwater flow system occurs in the topographically higher areas east of the site. The groundwater flow in the bedrock is believed to occur in fractures, and to a lesser degree joints and solution enlarged features, in bedding planes. Groundwater flow is interpreted to be to the west-northwest towards Stout's Creek. In the southern portion of the site, the Groundwater flow direction trends more directly west towards Stout's Creek, while in the central and northern areas of the site the groundwater flow direction trends west-northwest. Groundwater is believed to primarily discharge to the creek.

The site is located within a former limestone quarrying area previously known as Bennett's Quarry. The quarry produced a finished building stone whose source was the Salem Limestone. The quarry was privately owned and operated by Mr. Edward Bennett until it was sold to the Star Stone Company in 1987. In the 1960s (exact dates unknown), a portion of the quarry was used as a landfill for industrial wastes. These wastes included Westinghouse electrical capacitors, some of which contained PCBs.

The initial condition of this site indicated that it was an uncontrolled dumping and salvaging ground for electrical parts. Most of the electrical parts visible at the site had been crushed, burned or otherwise torn open, with insulator wrapping paper, ceramic bushings, and other electrical parts scattered about the surface. The existence of stained soil was also evident on the landfill surface.

Interim remedial measures were completed at Bennett's Quarry in two phases. The first phase, completed by USEPA in June 1983, consisted of securing the site, and isolating and containing the waste material. A locked, 8-foot high, chain-link barbed wire security fence was installed around the perimeter of the three areas. A total of 252 visible capacitors were removed as well as 20 cubic yards of stained soils. A 16 to 22 inch clay cap and 6 inches of topsoil cover were installed over the main site.

Westinghouse removed two additional surface capacitors in December 1983 and one surface capacitor in 1987.

The second phase began in late 1987 and was completed by Westinghouse in early 1988. The second phase included installing additional cap area at the edge of the main site, posting warning signs and removing sediment along 1600 feet of Stout's Creek. The sediments were transported to the Interim Storage Facility for storage. They were subsequently shipped by CBS in early 1998 to a TSCA permitted landfill in Belleville, Michigan for final disposal.

All remedial measures implemented to remove any identifiable hot spots and immediate threats to public health and the environment were designed and conducted with oversight and approval from the Consent Decree Parties - USEPA, State of Indiana (IDEM), City of Bloomington (Utilities Service Board), and Monroe County (County Health Board). Maintenance of the site by Westinghouse began in 1985. CBS personnel regularly inspect the site to assure there has been no disturbance of the site and to verify that the security fences and cap remain intact.

The following is a summary of the post-Interim Remedial Measures (IRM) analytical results of numerous sampling activities characterizing PCB concentrations in environmental media at Bennett's Quarry.

Soil samples were collected from Bennett's Quarry in 1983, 1984, and 1992 and analyzed for total PCBs.

In June 1983, soil samples were collected from 63 borings in the site boundaries (U.S. EPA, 1983).A grid pattern with a 50-foot interval was used to locate the borings. Soil samples collected from the0.0-0.5, 2.0-2.5, and 5.0-5.5 foot depth were analyzed. Over the 0-0.5 foot interval, PCBs were reported for 59 of the 62 samples analyzed with a range of ND (less than 0.1 ppm) to 24,648 ppm,in boring E2. For the 2.0-2.5 foot depth, PCBs were reported in 46 of the 50 samples analyzed with a range of ND to 52,332 ppm in boring E2. For the 5.0-5.5 foot depth, PCBs were reported for 44of 46 samples analyzed with a range of ND to 15,047 ppm in boring F2. Figure 1 of Appendix A shows these sample results

In May 1984, four surficial soil samples and three subsurface soil samples were collected from within the site boundaries. PCBs were reported (above the detection limit of 1 mg/kg) in two of the seven samples, with total PCB concentrations (identified as Aroclor 1248) of 2 and 3 mg/kg dry weight.

In the November 1984, two surficial soil samples and one subsurface soil sample were collected north of the site boundary. PCDD isomers; HpCDD and/or OCDD were reported in all three samples. The maximum total PCDD concentration detected was 3.3 ug/kg in a subsurface soil sample (E-25) collected approximately 1,200 feet northwest of Bennett's Quarry. PCDFs were not detected in any of the soil samples. All results detected were within acceptable levels.

In May 1992, twelve additional soil samples were collected from the smallest satellite fill area north of the fill area and analyzed for PCBs. The May 1992 sampling results all showed nondetectable levels of PCBs. Based on these sample results the third satellite area was delisted by the EPA.

Groundwater samples were collected and analyzed for total PCBs quarterly in 1988 from a series of seven wells located adjacent to the Bennett's Quarry areas, as shown on Figure 3, Monitoring Well Locations. Well MOO-5 was only analyzed in March 1988 when subsequent

monitoring was discontinued due to the observation of a PCB oil sheen floating at the water surface within the well. The well use was discontinued because the presence of free product precludes its unbiased use as a proper monitoring well. PCBs were detected during each of the four sampling events in wells MW-6I and MW-6D located in the southwest corner of the fill area, and once in wellMOO-3. The maximum total PCB concentration detected in groundwater was 21.0 ug/L and 27.3ug/L in the duplicate sample for MW-6I collected during December 1988.

Indiana University collected water samples from 66 residential wells located in the vicinity (5000-footradius) of Bennett's Quarry between September and November 1986. PCBs were not detected in any of the wells at concentrations greater than the drinking water standard (MCL) of 0.5 ug/L. Only seven of the residential well samples contained detectable levels of PCBs (above the detection limit of 0.001ug/L). Observed PCB concentrations ranged from 0.002 to 0.402 ug/L. The highest concentration was observed at a residence at 4005 Woodyard Road. Westinghouse had also sampled this well in October 1986 and detected PCBs at a level of 0.187 ug/L. This residence has municipal water as its primary source of drinking water, and the well is at most a secondary source since it is attached to an outside faucet. Available information indicates that this well is not located in an area influenced by Groundwater flow from Bennett's Quarry. Because of its relative proximity to Bennett's Quarry, the Indiana University survey included this well in the Bennett's Quarry survey area.

In July 1993, two surface water samples were collected from Stout's Creek, one upstream and one downstream of Bennett's Quarry. PCBs were not detected (at a detection limit of 0.1 ug/L) in the upstream sample. However, PCBs were observed at a concentration of 0.65 ug/L downstream of Bennett's Quarry.

In 1998 water in Stout's Creek was sampled. Water samples were taken at both low and high flow conditions. Under low flow conditions, seven grab water samples were taken in April and May 1998 and analyzed for PCBs

Three samples were taken immediately adjacent to the site, one just upstream, one at the site midpoint and one just downstream. The upstream sample measured less than 0.1 ppb. The other two samples were 0.24 ppb (near MOO-5) and 0.3 ppb (near MW-3)

One sample was taken in the west branch of Stout's Creek just before the confluence with the east branch. This sample measured less than 0.1 ppb.

Under high flow, samples were taken at three locations in Stout's Creek. Auto-samplers took grab samples at one to four hour intervals across a storm event on April 15, 1998. The

Following completion of the site preparation activities as described above, execution of the remedial approach will commence as described in this subsection.

The lateral limits of excavation are shown on Figure 4. These limits have been established based on the recent geophysical studies and subsequent boring sampling program as described in Appendix A and in Section 2.4. The geophysical studies identified areas that contained buried metallic material. This buried metallic material may include capacitors and/or other non-PCB debris. Boring sampling of these areas and areas around the 1983 EPA "hot" borings were performed. This sampling defined the limits of excavation shown in Figure 4 by identifying soils that meet the clean criteria of "not greater than 50 ppm." The vertical limits of the excavation will advance downward across a grid to the depth determined by the boring samples to meet the clean criteria. Verification sampling will then be performed to confirm that the cleanup levels are achieved per Appendix B.

Figure 4 shows that in several places a "hot" EPA boring exists on the perimeter between a hot grid and a clean subgrid. In these areas a couple of feet of the clean subgrid, containing the EPA boring, will be excavated along with the hot grid. The subgrid material will be excavated to the depth of the hot EPA boring or the hot grid, whichever is contaminated deeper, per Appendix A.

The EPA boring at GO of Figure 1 in Appendix A had a PCB content of 1488 ppm at 0 to 6 inches and 0.3 ppm at 2 to 2.5 feet. All four subgrid borings around this hot EPA boring were analyzed at less than 50 ppm to below the EPA contaminated depth. To ensure that the material represented by the EPA boring GO is removed, a 25 by 25-foot grid will be centered around the EPA boring, excavated to one foot and sampled for verification.

Nine main grid borings with deep contamination that are adjacent to borings with shallow contamination or no contamination were delineated further as indicated in Appendix A. A 25-foot by 25-foot subgrid was placed for removal around the deep contaminated boring within the center of the 50-foot by 50-foot main grid. Additional borings were drilled at each corner of this subgrid. A 25 foot by 25 foot subgrid centered around this additional boring (separating the main grid into four quadrants) will be excavated based on the depth of contamination shown by this additional boring. Figure 4 shows the four quadrant subgrids as L-shaped since the center subgrid overlies them. The overlap between the center subgrid and the corner quadrant subgrid will be excavated as TSCA to the depth of whichever subgrid shows deeper contamination.

Approximately 11,500 cubic yards of material have been delineated for removal as TSCA in the main area. An additional 200 cubic yards were delineated in the satellite area.

Grids delineated for excavation on the east, west and south perimeter of the site extend outside of the fenceline. The fence will be moved to enclose these areas or temporary fencing will be placed around these areas while the excavation takes place. On the south side of the site, one subgrid and one main grid extends out into the roadway, as shown in Figure 4. These grids will be excavated, backfilled and the road restored, if it is still required.

The final report presenting all the delineation data supporting these limits of excavation is included as Appendix A. The sample results from all the 1999 sampling is included in the final report.

It is anticipated that some amount of excavation below the potential groundwater surface may be required. This will require some amount of groundwater removal in order to access and remove soil and other debris that may exist at and below these depths. Groundwater was encountered in the boring samples performed in May 1999 at four foot below the surface in row C of Figure 4. Excavation depths in row C extend down to as deep as 13 feet. As the excavation is advanced, groundwater may accumulate in the bottom of the excavation. A pump will be used to remove this water and it will be transferred to the temporary water treatment system.

In addition, other sources of potentially impacted water will be collected and transferred into the temporary water treatment system including decontamination water, water collected in the material handling areas, etc.

The temporary water treatment system will consist of a temporary water storage tank or pool that will be used for flow equalization and settling. Water collected in this tank will then be pumped through a sand and/or bag filter system followed by carbon treatment, and transferred into a temporary holding tank where the treated water will be sampled. The 100gpm water treatment system equipment and arrangement designed by the remedial contractor is shown in Figure 7.

Although the EPA discharge limit is 3 ppb, CBS, in this instance, will treat all water to a limit of 0.3 ppb. Following receipt of acceptable analytical results, treated effluent will be batch discharged into Stout's Creek in accordance with IDEM and USEPA approval. Discharge flow rates will be regulated to avoid streambed erosion.

If the analytical results indicate that the discharge limitations have not been met, the water will be re-treated and re-sampled, as necessary. The treated water effluent may also be used for dust control, as necessary, after batch sampling results show the water satisfies the clean up level of 0.3 ppb.

The extent of contamination within the excavation area has been delineated during the boring sampling program described in Appendix A. Figure 4 shows the results of the sampling programs.

One foot layers of all the grids have been segregated between TSCA eS0 ppm) and clean material (<50ppm). Some grid layers between 0 to 50 ppm may be sent off as special waste to achieve an overall average <25 ppm clean up level per the SOW.

The clay cap installed over the contaminated areas by the EPA in 1983 was delineated during the recent boring sampling program as shown on Figure 4. The topsoil, clay cap and clean overburden will be stripped and stockpiled for use as backfill, below 12 inches from the final grade established during restoration. A few inches of clean overburden will be left in place on top of the TSCA material to insure no contaminated material is removed with the overburden. The remaining clean overburden will also reduce PCB air emissions and prevent storm water runoff from being impacted with PCB. This residual clean overburden will be excavated and shipped with the underlying TSCA material.

During the course of the excavation, the different types of waste material will be segregated and removed. This will include TSCA and non-TSCA soil and other debris as well as capacitors. Also, it is anticipated that large debris materials may be encountered including quarry stones, metal scrap and other similar materials.

Soil and debris impacted by contaminants other than PCBs (including RCRA contaminants) may also be encountered. The June 1999 sampling indicated the presence of VOCs in the TSCA material is within regulatory limits for TSCA disposal.

In general, the approach will include use of conventional excavation equipment to carefully access and remove waste materials. As the excavation proceeds, waste materials will be physically segregated, sampled if required and placed in the appropriate staging location to await loading and off-site transportation for disposal.

The removal and segregation of the specific waste streams are described below.

TSCA materials will include soil and other debris removed from the grids in the excavation area, which were determined to have a PCB concentration greater than or equal to 50 ppm. Tree stumps within the TSCA grids will be excavated, sized and shipped to the TSCA landfill with the PCB soils.

The volumes delineated as TSCA may contain whole capacitors, capacitor parts and oil stained or soaked materials. The whole capacitors and capacitors containing PCB liquids may be intermixed and will require segregation from the soil and debris prior to disposal at the incinerator.

As the TSCA materials are excavated, the whole capacitors will be mechanically and/or manually separated. This activity will likely be performed in the immediate area of the excavation. As the capacitors are removed, they will be directly transferred into secure containers that are staged within the excavation area. As the capacitor containers are filled, they will be removed from the excavation and transferred to the waste processing area to be prepared for off-site transport to a TSCA incinerator. Whole capacitors will ultimately be placed in rolloffs for shipment to the incinerator. The rolloffs will have six inches of an absorbent material (wood chips) placed on the bottom to absorb any oil that may leak from the capacitors.

In addition, contingency measures will be in place to provide containment and collection of PCB oils, which may be encountered during removal of leaking capacitors. The oil will be sent to a TSCA incinerator for disposal. The TSCA soil and other debris, once segregated, will either be directly loaded into trucks or temporarily staged in a separate pile in or near the excavation area and loaded when trucks are available. All soil and debris that contains whole capacitors or contain capacitor parts will be transported to the TSCA landfill. Capacitor parts that are free of PCB oil will be loaded out with soil and debris being shipped to the TSCA landfill.

During the course of the excavation, it is anticipated that large debris may be encountered within contaminated grids, including buried quarry stone, rail road rails and ties, discarded appliances, scrap metal and other inorganic debris. As the excavation proceeds these materials will be separated and handled as described below.

Large buried quarry stones discovered within a contaminated grid layer will be cleaned within the excavation. The excavator will scrap the soil off of all surfaces of the stone by scraping and moving it around in the excavation. All TSCA soil and debris surrounding the stone will be removed. If no visible signs of PCB oil staining are on the stone it will be left in the bottom of the excavation and buried with backfill.

If the stone shows visible signs of PCB oil staining on the surface, it will be spray washed to remove the oil. The stone will either be washed in the excavation or removed from the excavation for washing. After the excavation bottom is verified clean, the stone will be placed back into the excavation as backfill.

Rail road rails and ties within TSCA grid layers will be loaded out with the TSCA soils. Alternately, the rails and ties in the TSCA layers may be lifted and cleaned of dirt. After removing the dirt the rails and ties would be placed back into the excavations to be reburied under the backfill after the excavation is confirmed clean.

Most of the surface rails and ties are contained in clean grids or lie on the clean overburden with TSCA material starting a few feet below. The rails and ties on clean grids will be left in place. The rails and ties lying on clean overburden will either be scrapped or reburied in the excavations. .

Large materials (washers, dryers, etc.) within TSCA layers will generally be disposed of with the TSCA soils to the landfill. However, they may be processed by scraping or washing off any residual soil. The materials will then be placed back in the excavation during the backfill phase.

Several empty, crushed drums exist in the wooded area at the eastern edge of the main site. These will be inspected for residual chemical waste and checked using the PID. If no contaminants other than PCB are found, they will be disposed of with the excavated soil as TSCA.

One drum at this location contained some liquid. All the liquid was removed to obtain enough material for analysis for VOCs. No contaminants were found in the liquid above acceptable levels, as indicated in Appendix A. This drum will be crushed and disposed of with the TSCA soils.

Two large metallic objects are contained within or near hot grids inside of the satellite area. These two objects will be left in place. Excavation will occur around these objects.

The June 1999 sampling for other contaminates showed VOCs to be within acceptable levels within the TSCA excavation area. The EPA plans to perform additional sampling for VOCs in non-TSCA areas of the site.

As indicated in section 3.2.5, a separate material handling area will be established for buried drums and other chemical wastes and contaminates including RCRA wastes. These materials will be characterized and held in this area for proper disposal by either CBS or EPA. Soils impacted by these other contaminants will also be segregated and stored within this area (if only a small quantity) for proper disposal.

The EQ landfill can accept TSCA materials, which contain up to 10 times the LDR levels of other hazardous contaminates. If the hazardous contaminant level is higher than 10 times the LDR level and the PCB concentration is below (50 ppm, EQ can treat the materials to stabilize the hazardous contaminates and then landfill them. Other landfills may be able to treat TSCA material up to 100 ppm PCB to stabilize hazardous contaminants. If the PCB content is higher than 100 ppm and the other hazardous contaminant levels exceed 10 times the LDR level, the material would require incineration. Table 1 lists the LDR levels (Regulatory Level) of some hazardous contaminants, which were detected on site.

Verification sampling will be conducted within completed portions of the excavation to determine whether the cleanup level of "not greater than " 50 ppm has been achieved. This will consist of a composite soil sample collected in four subgrids within a 50-foot by 50-foot grid. CBS reserves the right to perform verification sampling in grids smaller than 50 by 50 foot, at CBS's discretion. The sample will be analyzed for PCBs.

If a grid is excavated to bedrock, the remediation contractor will scrape as much soil as possible from the bedrock with the excavator bucket. Residual PCB oil, stained soils or capacitor parts will be removed manually, if necessary. If no obvious contamination remains on the bedrock, such as oil stains, residual oil stained soils or capacitor parts, the grid will be considered confirmed clean with no verification sampling or further "rock" excavation required. Residual soil, which cannot be removed with the excavator bucket but that is not obviously contaminated, may be left in place.

The decision if bedrock is clean enough or requires additional removal will be made in the field by CBS and the CD parties oversight people.

Sidewalls of excavations will also be inspected during the excavation of the grids. If contamination is obvious, including PCB oil stained soils and/or capacitors or capacitor parts in the sidewall, contaminated items will be removed for shipment with the TSCA material.

The details associated with the verification sampling are described in the Sampling and Analysis Plan - Appendix B.

Verification sampling for other contaminates (VOCs) will be performed by CBS if in a TSCA area or by EPA if in a non-TSCA area.

Once the waste materials have been excavated, segregated and processed, those materials designated for off-site disposal will be loaded, transported and disposed of as described below. A designated transportation and disposal coordinator will be on site during transportation and disposal activities. This individual will be responsible for coordinating and overseeing these activities.

A Transportation Plan, which describes specific aspects of the transportation activities, is included as Appendix E.

The waste materials will be loaded into appropriate transport vehicles/containers for off-site transportation to the designated disposal facility. Loading will be conducted in the designated loading area, and will be carefully controlled to minimize spillage and/or fugitive dust. The plastic liner of the truck bed will be draped over the side to prevent spillage onto the side of the truck. Plastic will be laid on the ground on the loading side of the truck to catch any spillage. As loading is completed, the loaded truck will be brushed off to remove loose materials, tarped, and will pass through the wheel wash area.

After loading, each truck will be weighed to assure it is within the legal weight of 80,000 pounds. Prior to leaving the site, each truck will be inspected to ensure that it is secure and that the truck has been properly cleaned/decontaminated, as required. Appropriate documentation (including hazardous waste manifests) will be completed and checked. In addition, a site log will be maintained of loading and transportation.

Once loaded and inspected, the loaded truck will exit the site and proceed to the designated disposal facility in accordance with local, state and federal transportation requirements. TSCA soils and other debris will be transported to the Environmental Quality (EQ) TSCA landfill facility in Belleville, Michigan. Capacitors will be transported to an approved incinerator facility operated by Waste Management in Port Arthur, Texas. Non-TSCA soils and other debris will be transported to Southside Landfill in Indianapolis, Indiana.

TSCA soils and other debris will be disposed of in EQ's TSCA landfill. Also, site remediation related material (e.g., PPE, liners, spent water treatment carbon, etc.) will be disposed of in EQ's TSCA landfill. Non-TSCA material that includes landfill debris and less than 50 ppm will be sent to Southside Landfill in Indianapolis, Indiana.

Potential RCRA or TSCA/RCRA material, if discovered, will be disposed of in a TSCA/RCRA landfill. The requirements for stabilization will be determined before disposal. The preferred disposal facility is the EQ TSCA/RCRA landfill in Belleville, Michigan.

Capacitors will be incinerated at Waste Management facility in Port Arthur, Texas.

Upon completion of the remediation activities, site restoration will commence, including backfilling and grading of the excavation and re-establishment of vegetation.

It should be noted that the remediation work may be completed in the early winter months and it may be necessary to complete some of the final restoration (i.e., landscaping, seeding) in the spring. Erosion controls will be established and maintained during this time until the area is revegetated.

The completed excavation will be backfilled using the stockpiled clean cap and other general fill obtained from an off-site borrow source. Prior to this activity, a representative sample of the backfill material obtained from off-site will be obtained and analyzed for PCBs, to insure that the material is less than 1 ppm. In addition, clean, site-related material may be included as backfill material including wood chips and cleaned scrap metal, cleaned quarry stones, railroad ties and rails.

As the material is placed in the excavation it will be compacted by running the heavy equipment over the backfill. The top 6 inches of the completed backfill will be clean (<lppm) topsoil from offsite. The excavation area will be backfilled to "protect the slopes from erosion and shall fit the approximate original contour of the natural surrounding grade" per the SOW. The contouring will provide adequate drainage to prevent pending. At least twelve inches of clean cover will be placed over all excavated grids with a residual surface PCB content of>1 ppm.

Once the backfill is in place and the topsoil has been prepared, the area will be hydroseeded to promote new vegetation in the area. The seed mixture will include a combination of annual and perennial grasses. Erosion controls will be installed and maintained to prevent washout of the newly planted grass.

Following completion of the activities described above, CBS will provide continued site maintenance which will include periodic inspection and maintenance of the grass cover, erosion controls until a vegetative cover is established, ground water monitoring wells and other site features. Also, a post-remediation ground water monitoring plan will be developed and implemented by CBS as per the SOW.

4.1 Verification Sampling and Analysis

Verification sampling and analysis will be conducted to determine whether the cleanup standards have been achieved. A Post-Excavation Verification Sampling and Analysis Plan (SAP) which describes the verification sampling and analysis is included as Appendix B.

Health and safety will be conducted in accordance with the Health and Safety Plan (HASP) included in Appendix C. This HASP has been prepared in accordance with 29 CFR 1910.120 - Hazardous Waste Operations and Emergency Response.

Air monitoring will include perimeter air sampling as well as personal air monitoring as part of the health and safety program. Personal air monitoring will be performed for PCB, lead and asbestos, as well as any other contaminates discovered during subsequent excavation work in areas where odors are noticed. These monitoring procedures are described in the Air Monitoring Plan (AMP) included as Appendix D.

	No Later Than
Submit Work Plan to CD Parties for review and approval	June 16, 1999
Inititate Site Preparation	mid-July 1999
Final Work Plan Approval	August 11, 1999
Remedial Contractor Mobilizes	August 16, 1999
Initiate Excavation Activities	September 1, 1999
Complete Remedial Activities	December 31, 1999
Spring 2000
Complete Site Restoration Activities

Home