Foster Wheeler Environmental Corporation - Us Epa

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SDMS Document 117858 FOSTER WHEELER E N V I R O N M E N T A L CORPORATION June 17,1999 RAC n-99-178 Mr. John J. Bachmann, Jr. Contracting Officer U.S. Environmental Protection Agency - Region n 290 Broadway, 27th Floor New York, NY 10007-1866 Mr. Keith Moncino Project Officer U.S. Environmental Protection Agency - Region 11 290 Broadway, 18th Floor New York, NY 10007-1866 Re: RAC H PROGRAM - CONTRACT NO. 68-W-98-214 WORK ASSIGNMENT NO. 027-RICO-026J WHITE CHEMICAL RI/FS LETTER WORK PLAN Dear Mr. Bachmann and Mr. Moncino: In response to EPA's Work Assignment Form (WAF) dated May 8, 1999 and the May 20, 1999 Work Assignment (WA) Scoping Meeting (conference telephone call), this Letter Work Plan summarizes the RI/FS WA tasks/subtasks which were completed by Malcolm Pimie, Inc., (MPI) undei the ARCS II Program (WA No. 052-26JC) and presents the remaining tasks/subtasks that will be performed under the RAC D Program (WA No. 027-RICO-026J). 1.0 INTRODUCTION The White Chemical Corporation (WCC) site is an inactive 4.4 acre site located at 660 Frelinghuysen Avenue, Newark, Essex County, New Jersey. Frelinghuysen Avenue is a major thoroughfare with significant residential and commercial populations, as well as major industry. Newark International Airport, Conrail and Amtrak lines, and U.S. Highway Routes 1 and 9 are located within 0.5 mile of the site. 8 PEACH TREE HILL ROAD, LIVINGSTON, TEL: 973-597-7000 NJ 07039 FAX:973-597-7025 300001

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 2 Five major buildings (Building Numbers 33,34, 34A, 35 and 36) and three smaller facility support buildings (Boiler Room, Pump House and Maintenance Shop) are located on the site. In September 1970, Central Services Corporation (CSC) purchased the site from Union Carbide Corporation. It is believed that much of the present site infrastructure, including sewer and utility conduits and buildings may date from Union Carbide's ownership. In August 1975, CSC sold the property to the Lancaster Chemical Compaiiy, a division of AZS Corporation. Very little information is presentiy known of Union Carbide's, CSC's or Lancaster's operations at the site. In 1983, WCC leased the site from AZS Corporation and moved its operations from Bayonne, New Jersey to Newark, New Jersey. WCC continued operations in Newark until 1990. WCC produced three primary groups of chemical products: acid chlorides, brominated organics (both aliphatic and aromatic) and mineral acids, most notably hydriodic acid. A brief sununary of their products and processes is presented below. Acid chlorides are functional derivatives of carboxylic acids and were produced by the simple reaction of phosphorous trichloride with a carboxylic acid. Although acid chlorides are not a conmion or generally useful end product, they are essential intermediates for the production of other organic compounds. Esters, amides, phenyl ketones, aldehydes, anhydrides, neo-alcohols and acid cyanide are produced with acid chloride precursor compounds. These end products have a multitude of commercial and domestic applications ranging from pharmaceuticals to cosmetics. Aliphatic and aromatic brominated materials were produced by substitution reactions with alcohols, carboxylic acids and diphenyloxide. Brominated organics have a wide variety of potential uses. One major category of brominated organics, namely alkyl bromides, was as an extremely useful intermediate and was used most frequently as an alkylating agent. End products that resulted from the use of alkyl bromides included perfume oils, pharmaceuticals, dyestuffs and agricultural chemicals. Of the aromatic brominated compounds, WCC produced decabromodiphenyloxide, which is a flame retardant. Precursor chemicals in the manufacture of decabromodiphenyloxide have been known to contain polybrominated biphenyls (PBBs). No information is currently available on the production of hydriodic acid. Five SARA Title III extremely hazardous substances (EHS) were reported by the Technical Assistance Team (TAT) to be located on the site in 1990. The five EHSs, which were contained in drums and tanks, included allyl alcohol, bromine, chlorine, red phosphorous and phosphorous trichloride. No NJPDES or TSD permits could be found for the Newark facility although the Bayonne facility had an NJPDES and air permits. It is not known if the Newark facility had a Significant Industrial Usage (SIU) permit. Tech\rac\while\leiierwp.wpd 300002

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17,1999 Page 3 A removal action was initiated by the New Jersey Department of Environmental Protection (NJDEP) on May 15,1990. In August 1990, after removing approximately 1,000 drums, NJDEP reached their project cost ceiling of 825,000 and they were forced to suspend operations. Subsequently, NJDEP requested that EPA undertake a removal action at the site. On September 7,1990, the EPA performed a preUminary assessment (PA) of the WCC facility and found numerous air and water-reactive substances in 55-gallon dmms (NUS, 1990). Numerous other RCRA violations were discovered. Approximately 10,900 55-gallon dmms of hazardous substances were precariously stacked or improperly stored throughout the site. Drums and other containers were found in various stages of deterioration, fuming, and leaking their contents onto the soil. Numerous stains were observed on the soil. Other containers that were found on the site included: approximately 150 gas cylinders; 126 storage tanks, vats, and process reactors; hundreds of fiberpack drums; glass and plastic bottles; carboys; boxes; and approximately 18,000 laboratory-type containers. The on-site laboratory contained thousands of unsegregated laboratory chemicals in deteriorating containers. These containers were haphazardly stored on stmcturally unsound shelving, or stacked in piles on the floor. The EPA overpacked 11filmingdrums and secured them for future handling. A total of 4,200 empty dmms were shipped off-site for disposal and approximately 6,700 dmms were staged on-site for later characterization and disposal. The contents of most dmms could not be identified because of poor, improper or multiple labeling. In 1992, the EPA issued a UAO to a group of PRPs to remove 7,900 drums, the contents of more than 100 tanks, approximately 12,500 laboratory chemical containers, approximately 50,000 gallons of liquid contained in process tanks, 14 gas cylinders, and to empty and clean process tank piping. The PRP group completed their action on March 3, 1993. Field activities in support of the RI/FS began in October 1998 and continued until March 1999. Surface soil, subsurface soil and sediment samples were collected and analyzed for TAL/TCL compounds, additional selected chemical parameters and physical properties. Building material samples were collected and analyzed for either TCLP Parameters, asbestos or lead. In addition, a subcontractor performed a lead paint survey of interior building surfaces utilizing an x-ray fluorescence (XRF) unit. Eleven on-site monitoring wells were installed and one round of groundwater samples were collected and analyzed for chemical parameters. With the exception of the XRF building survey, all sample collection activities were conducted by MPI personnel. TechNracWhiicMenerwp.wpd . ' 300003

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17,1999 Page 4 2.0 ARCS II WORK ASSIGNMENT The tasks and subtasks completed by MPI prior to May 25, 1999 under the ARCS n Program are presented below. 2.1 TASK 1 - PROJECT PLANNING This task was completed. MPI prepared and submitted a Draft and Draft Final Work Plan and Quality Assurance Project Plan (QAPjP), a Draft Field SampUng Plan (FSP) and a Health and Safety Plan (HASP). In response to EPA review comments, variances to the Draft Final Work Plan and Draft FSP were also prepared and submitted. All planning documents were prepared in accordance with EPA's Work Assignment Statement of Work. MPI also attended a site visit with the WAM and participated in a Scoping Meeting. 2.2 TASK 2 - COMMUNITY RELATIONS This task was never initiated. No conununity relations support was provided by MPI to the EPA. 2.3 TASK 3 . FIELD INVESTIGATION This task was not completed. Field activities in support of the RI/FS were initiated in November 1998 and continued until March 1999. These activities included the collection of soil, sediment, building material and groundwater samples. Six test pits, 30 on-site and four off-site soil borings were completed and subsurface soil samples were collected. Seventy-seven surface soil samples and two sump sediment samples were also collected. All of the soil/sediment samples were analyzed for TAL/TCL parameters, additional selected chemical parameters and physical properties. Samples collected from the on-site buildings included building material samples, asbestos samples, lead paint chip samples and wipe samples. The building material samples were analyzed for TCLP Parameters while the wipe samples were analyzed for TAL/TCL parameters and PBBs. An XRF survey (for lead-based paint) was also performed inside the buildings. Eleven on-site monitoring wells were installed, and one round of groundwater samples were collected using the low-flow sampling technique. With the exception of the XRF survey, MPI performed all sample collection activities. A subcontractor was procured for the XRF survey. An ecological survey and wetiands delineation were performed. Stage la and lb Archaeological Investigations were performed and the respective draft reports were submitted to the EPA. Subcontractor procurement and administration were completed for drilling, surveying, non-RAS laboratory analyses (three separate laboratories), debris removal, an XRF building survey and 24hour security services. Tech\rac\while\lelierwp.wpd 300004

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17,1999 Page 5 The work under Task 3 that was not completed under MPFs ARCS II contract is presented in Section 3.2 of this document. 2.4 TASK 4 - SAMPLE ANALYSIS/DATA VALIDATION This task was not completed. Routine Analytical Services (RAS) and non-RAS laboratory analytical data were collected during the field investigation. The majority (estimated at 70%) of non-RAS data (soil, sediment and building material samples) were validated under the ARCS WA . Validation of the first round of non-RAS groundwater data was never initiated under the ARCS WA. Under the ARCS WA, validation of all RAS data was being performed by EPA Region n ESAT/RSCC, however, it was not completed. The work under Task 4 that was not completed under MPI's ARCS n contract is presented in Section 3.3 of this document. 2.5 TASK 5 - DATA EVALUATION This task was not completed. Partial summaries of the soil, sediment and building material analytical data have been generated. A summary of the first round of groundwater data were never initiated under the ARCS WA because the data were not validated. Preparation of the required NJDEP electronic deliverables (EDDs) have also been partially completed. The non-RAS data EDDs are approximately 70% complete; preparation of the RAS data EDDs were never started. The work under Task 5 that was not completed under MPI's ARCS n contract is presented in Section 3.4 of this document. 2.6 TASK 6 - RISK ASSESSMENT This task was never initiated. The work under Task 6 that was not completed under MPI's ARCS n contract is presented in Section 3.5 of this document. 2.7 TASK 7 - TREATABILITY STUDIES/PILOT TESTING This task was never initiated. The work under Task 7 that was not completed under MPI's ARCS n contract is presented in Section 3.6 of this document. 2.8 TASK 8 - REMEDIAL INVESTIGATION (RI) REPORT This task was never initiated. The work under Task 8 that was not completed under MPI's ARCS n contract is presented in Section 3.7 of this document. Tech\rac\white\Jetlerwp.wpd 300005

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 6 2.9 T A S K 9 - D E V E L O P M E N T A N D SCREENING O F ALTERNATIVES This task was never initiated. The work under Task 9 that was not completed under MPI's ARCS n contract is presented in Section 3.8 of this document. 2.10 TASK 10 - DETAILED ANALYSIS OF REMEDL4L ALTERNATIVES This task was never initiated. The work under Task 10 that was not completed under MPI's ARCS n contract is presented in Section 3.9 of this document. 2.11 TASK 11 - FEASIBILITY STUDY (FS) REPORT This task was never initiated. The work under Task 11 that was not completed under MPI's ARCS n contract is presented in Section 3.10 of this document. 2.12 TASK 12 - DISPOSAL OF RI/FS GENERATED WASTE This task was never initiated. The work under Task 12 that was not completed under MPI's ARCS H contract is presented in Section 3.2 of this document. 2.13 TASK 13 - POST RI/FS SUPPORT This task was never initiated. The work under Task 13 that was not completed under MPI's ARCS n contract is presented in Section 3.11 of this document. 2.14 TASK 14 - PROJECT C L O S E O U T This task was completed under the ARCS n contract. 3.0 RAC II WORK ASSIGNMENT The following tasks will be performed under the RAC 11 Program (WA No. 027-RICO-026J). The work will be performed in accordance with the approved ARCS D Draft Final Work Plan and QAPjP, Draft Field Sampling Plan, related variances and the Health and Safety Plan, as modified below: Tcch\rac\whiie\]eilerwp.wpd 300006

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 7 3.1 TASK 1 - PROJECT PLANNING AND SUPPORT The following activities will be performed under this task: Letter Work Plan - This Letter Work Plan describes the tasks that have been completed under the ARCS n Program WA and the tasks that will be performed under the RAC n Program WA. This Letter Work Plan also presents a revised project schedule (Figure 1) and project organization chart (Figure 2). The RAC n project budget, which provides an estimate of the LOE hours and dollars needed to complete this WA, has been submitted to the EPA under separate cover. Revise Letter Work Plan - The Letter Work Plan and project budget estimate will be revised following negotiations with the EPA. Procure Non-RAS Laboratories - It will be necessary to procure two non-RAS laboratory subcontracts: one laboratory will perform PBB analysis and the other laboratory will perform the various water quality analyses. Task activities include modification of the previous statements of work, preparation of sole-source justification for the PBB laboratory subcontract, preparation of one laboratory bid package, review of laboratory qualifications and award of a new laboratory subcontract. Procure Security Subcontractor - This task includes modification of the previous statement of work and preparation of a sole-source justification to continue 24-hour security at the site. Procure IDW Disposal Subcontractor - This task includes development of a statement of work, attendance at a pre-bid site visit, responding to bidder questions, evaluation of bids and selection of the selected subcontractor. Manage, Track and Report Status of Site Specific Equipment - This task includes the activities necessary to manage and track the equipment necessary for the second round of a groundwater sampling event. Prepare an analysis of equipment purchase vs lease for non-expendable equipment. 3.2 TASK 3 - FIELD INVESTIGATION The field investigation subtasks that were not completed under the ARCS WA included a second round of groundwater elevation measurements and a second round of groundwater sampling. Lowflow sampling of the 11 on-site monitoring wells will be conducted under the RAC WA. Equipment and supplies will be mobilized to the site to conduct the groundwater sampling. Once the water level measurement/groundwater sampling activities are completed, all equipment will be demobilized. Tech\rac\whiie\Ieiierwp.wp(i 300007

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 8 Another authorized task that was not completed under the ARCS WA (Task 12) included the characterization and disposal of investigation-derived wastes (IDW). Under the RAC WA, this activity has been included under Task 3. The IDW includes drill cuttings, monitoring well development/purge water, waste methanol vials and discarded personal protective equipment. Coordination and field oversight of the selected subcontractor will be provided. 3.3 TASK 5 - ANALYTICAL SUPPORT AND DATA VALIDATION This task includes the activities necessary for validating the remaining non-RAS soil, sediment, building material (approximately 30 samples). Validation of the first round of non-RAS groundwater data was never initiated under the ARCS WA and must be validated under the RAC WA. Validation of the second round of groundwater data must also be completed under the RAC WA. As part of the validation process, a data useability report will also be prepared as required by the new risk assessment guidance. This task also includes the sample management needed to complete the second round of groundwater sampling. Sample management activities include coordinating with the EPA Sample Management Office (SMO) and Regional Sample Control Coordinator (RSCC) to obtain Contract Laboratory Program (CLP) analytical services, as well as providing all required sample management activities (e.g., chain-of-custody procedures, sample labels, tags, etc.). 3.4 TASK 6 - DATA EVALUATION This task includes the activities necessary to tabulate the analytical data. Partial summaries of the soil, sediment and building material analytical data have already been generated under the ARCS WA. These summaries will be completed under the RAC WA. Summaries of the groundwater analytical data will also be generated. As part of the data tabulation, NJDEP EDDs will be completed. The non-RAS data EDDs are approximately 70% complete; the RAS data EDDs have not been started. This task also includes the activities necessary to assess the large volume of chemical data as well as the hydrogeology of the site. Information pertaining to the geology and hydrogeology of the site will be assembled and reviewed. Mapping of all relevant information will be performed for the execution of RAC H Tasks 7 and 9. Tech\rac\whiteyelterwp.wpd 300008

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 9 3.5 TASK 7 - ASSESSMENT OF RISK Basehne human health and ecological risk assessments will be conducted in accordance with EPA guidance including the latest EPA Risk Assessment Guidance for Superfund (RAGS), Part D (January 1998). The human health risk assessment will include the following components; hazard identification, dose-response assessment, exposure assessment, risk characterization, and limitations/uncertainties. A conceptual site model will also be developed. The ecological risk assessment will evaluate potential impacts of site-generated contaminants to organisms and their respective habitats. 3.6 TASK 8 - TREATABILITY STUDY A treatability study is not currently envisioned; however, an evaluation will be conducted during the feasibility study to determine if one may be necessary during remedial design. 3.7 TASK 9 - REMEDIAL INVESTIGATION REPORT A Draft Remedial Investigation (RI) Report will be prepared in accordance with EPA guidance documents. The RI Report will include a discussion of site background, a summary of the field investigation, site characteristics, nature and extent of contamination, fate and transport, human health and environmental risk assessments, and a summary and conclusions. Following the receipt of EPA comments, the RI Report will be revised and resubmitted as Draft Final. 3.8 TASK 10 - REMEDIAL ALTERNATFV E SCREENING Remedial technologies and options will be screened initially to develop a list of potential alternatives. The remedial alternatives will then be screened to develop and select an appropriate range of remedial alternatives to be analyzed more fully in Task 11. 3.9 TASK 11 - REMEDIAL ALTERNATIVE ANALYSIS Remedial alternatives that remain after the screening phase will then be analyzed in detail. Nine evaluation criteria will be used in this analysis including: overall protection of human health and the environment, compliance with ARARs, long-term effectiveness and permanence, reduction in toxicity, mobility, and/or volume through treatment, short-term effectiveness, implementability, cost, state acceptance, and community acceptance. Tech\rac\white\lenerwp.wpd 300009

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 10 3.10 TASK 12 - FS REPORT AND RI/FS REPORT A Draft Feasibility Study (FS) report will be prepared which details the findings of the remedial alternatives screening and evaluation. The FS report will include a discussion of the following: FS objectives, remedial objectives, general response actions, identification and screening of remedial technologies, description of remedial alternatives, detailed analysis of remedial alternatives, comparison of all remedial alternatives evaluated in detail, and a summary and conclusions. Following the receipt of any EPA comments, the FS report will be revised, resubmitted, and finalized. 3.11 TASK 13 - POST RI/FS SUPPORT This task includes the activities necessary to support the Record of Decision (ROD). Typically, activities included in this task include providing support to the EPA during the preparation of the Proposed Plan, preparation for and attendance at one public meeting, hiring of a stenographer for the public meeting and support during preparation of both the Responsiveness Summary and the ROD. 3.12 TASK 16 - WORK ASSIGNMENT CLOSEOUT At the completion of all activities under the RAC WA, work assignment closeout activities will be performed. This will include file duplication, file archiving, transferring all applicable files into an approved data storage format, return of all documents to the EPA, and the preparation of a Work Assignment Closeout Report (WACR). 4.0 PROJECT SCHEDULE AND RAC II WORK ASSIGNMENT The project schedule is presented in Figure 1. 5.0 PROJECT ORGANIZATION The organizational chart for the project is presented in Figure 2. Tech\rac\while\leticrwp.wpd 300010

Mr. John J. Bachmann, Jr. Mr. Keith Moncino June 17, 1999 Page 11 6.0 PROJECT BUDGET ESTIMATE (Optional Form 60) FOR RAC II WORK ASSIGNMENT The project Budget Estimate (Optional Form 60) has been submitted to EPA under separate cover. If you have any questions regarding this Letter Work Plan, please do not hesitate to contact me at (973) 597-7034. Very truly yours, Dev Sachdev, PhD, PE RAC n Program Manager Attachments c: S. Alvi (EPA) M. Donovan (EPA) D. McGrath (MPI) L. Greco (MPI) R. Hill M. Kuo TechVacWhileMetterwp.wpd 300011

FIGURE 2 W h i t e C h e m i c a l C o r p o r a t i o n Site Remedial Investigation/Feasibility Study Organization Contracting Officer J. Bachmann, Jr. EPA Project Officer Program Manager K. Moncino D. Sachdev, PhD, PE EPA WAM Point of Contact M. Donovan D. Sachdev, PhD, PE 1 " Project Manager D. McGrath Technical Support Environmental Chemist Hydrogeologist Environmental Engineer Tech\rac\while\orgchart.wpd 300012

AMtl.l*» Activity Description ID i Work Earty Earty Days Start Finish TASK 01 PRpJECt PLANNING AND SUPPORT T0270100 T0270102 T0270103 T0270105 T0270107 T0270113 T0270115 Work Assignment Authorization Attend Scoping Meeting Develop Work Plan Letter and Cost Estimate EPA Review & Approve Work Plan and Cost Estima Negotiate Work Plan and Make Revisions Project Administration and Support Project Manager's Activities i T0270301 1 Field Investigation ' ' 06MAY99 20MAY99 21MAY99 18JUN99 03AUG99 06MAY99 06MAY99 1 Analytical Support and Data Validation AIIH SFtJ OCit ' 1 1 1 1 1 1 11 1 1 I I 1 Data Evaluation «; ;&.!;:. -;' { 90 28JUN99 290CT99 1 122 06MAY99 220019 135 01JUN99 1 06DEC99 88 01SEP99 1 31DEC99 : (Risk Assessment I i . TASK OB TREATABILITY STUDY/PILOT TESTING i' T0270801 i 1 Treatability Study Prepare Draft RI Report OC Review of Draft RI Report EPA Review of Draft RI Report Finalize RI Report Submit to EPA Final RI Report 5 iRemedial Alternative Screening : h 1 Remedial Alternative Analysis 3 130 5 20 20 0 02AUG99 31JAN00 07FEB00 06MAR00 28JAN00 04FEB00 03MAR00 31MAR00 31MAR00 i Prepare Draft FS Report 0 0 Review of Draft FS Report EPA Review of Draft FS Report Finalize Feasibility Study Report Submit to EPA Final FS Report 1 Post RI/FS Support 38 J 110CT99 1 01DEC99 1 22 02DEC99 1 31DEC99 1 66 5 20 10 0 02DEC99 O3MAR0O 10MAR00 07APR00 ImDM. IWork Assignment Close-out irjUNM u o o o U) Tech\rac\while\rig I. wpd ,. ;: / m mmmumm i 62 07MAR00 1 31MAY00 62 07MAR00 1 31MAY00 ; i ' m T ' ' kmi : ' : ; 1 \ - Y 1 hmmtJ - - . . . , il Bl TASK 16 WORK ASSIGNMENT CLOSE OUT ; T0271601 i : 02MAR00 09MAR00 06APR00 20APR00 20APR00 ""Tr i T 1; TASK 13 POST RI/FS SUPPORT :!lT0271300 MA 1 . 1 iI m m g u i [ I TASK 12 FS REPORT AND RI/FS REPORT T0271200 T0271203 T0271205 T0271207 T0271209 Apd i . . TASK 11 REMEDIAL ALTERNATIVES EVALUATION !,iT0271101 MAli 1 1 1 1 1 1 1 i 11 11 i 1 1 04OCT99* 1 08OCT99 j If TASK 10 REMEDIAL ALTERNATIVES SCREENING E1T0271001 FFri wsmmmmmm i TASK 09 REMEDIAL INVESTIGATION REPORT T0270901 T0270903 T0270905 T0270907 T0270909 .lAlJ } . ; . TASK 07 ASSESSMENT OF RISK i T0270700 npf 11 1 11 11 : 1; TASK 06 DATA EVALUATION i T0270601 NO\l V 20MAY99 17JUN99 02AUG99 j 16AUG99 30MAY00 I H l i l i B 30MAY00 immmmm TASK 05 ANALYTICAL SUPPORT AND DATA VALIDATION : T0270501 .IlliJ : J l l l l j 0 1 20 32 10 279 279 ; TASK 03 FIELD INVESTIGATION 1 .„i i a a k A --: . :V:.-.- MA4 1 RAC 11 PROGRAM WHITE Ch1EMICAL - WA 027-RICO-026J PROJECT SCHEDULE w ; \k M 1 ' T FIGURE 1 f

ARCS II LOE HOURS ESTIMATED TO REMAIN IN WA BUDGET FOR RAC II CONTRACT WHITE CHEMICAL CORPORATION SITE REMEDIAL INVESTIGATION/FEASIBILITY STUDY TASK 1 2 3 -4 5 6 7 8 9 10 11 12 13 15 ARCS II TASK NAME Project Planning and Support' Community Relations Field Investigations Sample Analysis/Data Validation Data Evaluation Risk Assessment Treatability Study/Pilot Testing RI Report Develop/Screen Alternatives Analysis of Alternatives FS Report Disposal of RI/FS Generated Wastes Post RI/FS Support Project Closeout TOTAL APPROVED LOE WP BUDGET LOE EXPENDED AS OF 5/25/99 1,260 378 4,740 2,771 956 862 40 944 367 408 455 95 167 60 1,499 0 4,437 606 32 0 0 0 0 0 0 0 0 38 13,503 6,612 Y\ NOTES: ' Expenditure Limit increased by 353 hours (WAF Revision No. 4), but not Work Plan Budget. Expenditure Limit increased by 233 hours (WAF Revision No. 4); 120 hours (WAF Revision No.8), but not Work Plan Budget. o o o TECH\RAC\WHITE\ARCSLOE.WPD LOE BALANCE AT END OF ARCS \ 7 ? 5 - . . \ % --- .' -:::-. , 378 -303 J ( o —-" 2,165 924 862 40 944 367 408 455 95 167 22 7,130

# ESTIMATED LOE HOURS NEEDED TO COMPLETE WHITE CHEMICAL CORPORATION SITE UNDER RAC H TASK 1 3 5 7 8 9 10 11 12 13 16 RAC II TASK NAME LOE REQUIRED FOR RAC II Project Planning and Support Field Investigations Analytical Support and Data Validation Data Evaluation Risk Assessment Treatability Study RI Report Remedial Alternative Screening Remedial Alternative Analysis FS Report and RI/FS Report Post RI/FS Support Work Assignment Closeout 478 358 1,069 1,013 1,082 40 944 367 408 455 167 60 TOTAL 6,441 Malcolm Pimie Foster Wheeler TOTAL o o o 01 TECH\RAC\WHITE\RACLOE.WPD 6,441

FOSTER WHEELER ENVIRONMENTAL CORPORATION June 17,1999 RAC n-99-178 Mr. John J. Bachmann, Jr. Contracting Officer U.S. Environmental Protection Agency - Region n 290 Broadway, 27th Floor New York, NY 10007-1866 Mr. Keith Moncino Project Officer U.S. Environmental Protection Agency - Region 11 290 Broadway, 18th Floor New York, NY 10007-1866

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