EPA Region 5 Records Ctr.

382170

Final Feasibility Study Work Plan - Soils

St. Regis Paper Company Site Cass Lake, Minnesota

Prepared for International Paper BNSF Railway Company

December 23, 2008

Final Feasibility Study Work Plan - Soils

St. Regis Paper Company Site Cass Lake, Minnesota

Prepared for International Paper BNSF Railway Company

December 23, 2008

4700 West 7?" Street Minneapolis. MN SS435-4S03 Phone: (952) H32-2600 Fax: (952) 832-2601

Final Feasibility Study Work Plan - Soils St. Regis Paper Company Site

Table of Contents

1.0 Introduction 1 1.1 Overview 1

1.2 Document Structure 1

2.0 Project and Task Organization 3

2 1 U.S. EPA Remedial Project Manager 3

2.2 International Paper Project Manager 3

2.3 Barr Engineering Company Project Manager 3

3 0 Scope of Work 5

3 1 Task 1: Prepare Feasibility Study Work Plan 5

3.2 Task 2: Prepare Alternatives Screening Technical Memorandum 5

3.2 1 Remedial Action Objectives 6

3.2.2 Identify Areas or Volumes of Media 6

3 2.3 Identify, Screen, and Document Remedial Technologies 6

3 2.4 Assemble and Document Alternatives 7

3 3 Task 3: Feasibility Study Report 8

3.3 1 Apply Nine Criteria and Document Analysis 8

3.3.2 Compare Alternatives Against Each Other and Document the Comparison of

Alternatives 9

3 3 3 Alternatives Analysis for Institutional Controls 9

3.4 Task 4 Progress Reports 10

3.4 1 Monthly Progress Reports ' 10

3.4.2 Semi-Annual Progress Reports 10 4 0 General Schedule 11

References 13

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List of Tables

Table 1 Project Contact Information

List of Figures

Figure 1 Site Location

Figure 2 Site Layout

Figure 3 Project Organization

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1.0 Introduction

1.1 Overview This Feasibility Study (FS) Work Plan describes the proposed scope of work, general schedule and

technical approach for the Feasibility Study to be performed for soils of concern at the St Regis

Paper Company Site (the Site), which includes the former Cass Lake City Dump in Cass Lake,

Minnesota (Figure 1) The FS for Fox Creek sediment will be completed at a later date and is not a

part of this Work Plan, although the schedule for the sediment FS is presented herein. This FS Work

Plan was developed in accordance with the requirements in the Administrative Settlement Agreement

and Order on Consent for Feasibility Study (FS-AOC) with an effective date of September 11, 2008

(U.S. EPA Docket No. V-W-'08-C-912).

The Site, except for the Cass Lake City Dump is located within the Cass Lake city limits. The City

Dump is located south of the Cass Lake city limits. The Site is located in Cass County, Minnesota

and is bordered by the Chippewa National Forest, administered by the United States Department of

Agriculture (USDA). The Site and the surrounding areas, including the City of Cass Lake, are

located within the exterior boundaries of the Leech Lake Band of Ojibwe (LLBO) Reservation. The

Reservation encompasses 668,000 acres, including both Indian-owned and non-Indian-owned fee

land within Beltrami, Cass, Hubbard and Itasca counties

The Site includes a closed wood-treating facility that is listed on the National Priorities List (NPL) of

the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which is

administered by the United States Environmental Protection Agency (U S EPA) The City Dump

area, in the southern portion of the Site, is located at a former city dump that is owned and was

operated by the City of Cass Lake. The Cass Lake City Dump is south of the former St. Regis Paper

Company wood treating property and adjacent to Fox Creek. The layout of the Site is shown in

Figure 2.

U S EPA Region 5 has required that various activities be undertaken at the Site under Remedial

Action and Removal Action authorities, as defined in CERCLA 121(c).

1.2 Document structure

This FS Work Plan consists of the following sections'

• Section 1 - Introduction

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• Section 2 - Scope of Work

• Section 3 - General Schedule

• References

The FS Work Plan describes the following two submittals that are specified in the FS-AOC' (1)

Alternatives Screening Technical Memorandum, and (2) Feasibility Study Report. The Feasibility

Study Report will consist of alternatives screening followed by a detailed analysis of alternatives.

Draft documents will be submitted to the U.S. EPA and support agency partners (i.e., LLBO and

Minnesota Pollution Control Agency (MPCA)).

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2.0 Project and Task Organization

This section describes the organizational structure for conducting activities associated with the FS,

including project management and oversight and technical work associated with the FS. The

organizational structure for this project is shown in Figure 3. Contact information is provided in

Table 1. Project responsibilities are described below

The U.S. EPA Remedial Project Manager (RPM), International Paper Project Manager, and Barr

Engineering Company Project Manager will be responsible for project management Their roles are

described below.

2.1 U.S. EPA Remedial Project Manager The U S. EPA Remedial Project Manager (RPM), Mr. Timothy Drexler, has overall responsibility for

the oversight of all phases of the FS. The RPM will direct other U S. EPA technical staff, as required,

to provide technical support for this project. The RPM will also coordinate input to the process and

comments on the deliverables for the U.S. EPA and support agency partners and will resolve any

inconsistencies in the input and comments

2.2 International Paper Project Manager The International Paper Project Manager, Tom Richardson, will provide final approval on behalf of

International Paper of the submittals required by the FS-AOC. He oversees remediation and

management activities at the Site and will ensure compliance with the FS-AOC, provide technical

oversight and consultation, and provide final approval on behalf of International Paper for activities

to accomplish project objectives. Mr Richardson will serve as the primary point of contact on behalf

of IP for the U.S EPA and support agency partners on all non-legal matters related to the

performance of the FS Communications from the U.S EPA and support agency partners on these

matters should be directed to Mr. Richardson

2.3 Barr Engineering Company Project Manager The Barr Engineering Co. (Barr) Project Manager for the FS, Tom Mattison, will be responsible for

the management and overall coordination of all project activities to be completed by Barr. The Barr

Project Manager's primary function is to ensure that technical and scheduling objectives are achieved

successfully. The Barr Project Manager reports directly to the International Paper Project Manager

and will provide the major point of contact and control for matters concerning the project. The Barr

Project Manager's duties and responsibilities are as follows:

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• Define project objectives and develop a detailed work plan and schedule,

• Establish project policies and procedures to address specific needs of the project as a whole

for each project task;

• Acquire and apply technical and corporate resources as needed to ensure that project

performance is achieved within budget and schedule constraints,

• Orient the technical staff to the project's special considerations;

• Monitor and direct the collection of any needed information;

• Develop and meet ongoing project or task staffing requirements, including mechanisms to

review and evaluate each project work product;

• Review the work performed under each task to ensure quality, responsiveness, and timeliness;

• Review and analyze overall task perfonnance with respect to planned requirements and

authorizations;

• Approve external reports (deliverables) before submittal to U.S. EPA Region 5; and,

• Represent the project team at meetings and public hearings.

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3.0 Scope of Work

The following tasks will be completed for the Feasibility Study.

3.1 Task 1: Prepare Feasibility Study Work Plan This document is the draft FS Work Plan and has been submitted to the U.S EPA with copies to the

LLBO and the MPCA for review and approval in accordance with Section X of the FS-AOC. Prior

to submittal of the document, IP has met or conferred with U.S. EPA, and support agency partners as

detennined appropriate by U S EPA. The FS Work Plan was prepared in a manner consistent with

applicable portions of the U.S. EPA RI/FS Guidance (U S EPA 1988) and other relevant guidance

documents, and sets forth general approaches and concepts with the intent of streamlining

preparation of the FS and minimizing review times for deliverables.

3.2 Task 2: Prepare Alternatives Screening Technical Memorandum

The Alternatives Screening Technical Memorandum will document the development and screening of

an appropriate range of remedial alternatives for detailed analysis in the Feasibility Study Report.

The Alternatives Screening Technical Memorandum will summarize the work performed and the

results of each of the subtasks, and will include an alternatives array summary. If required by U S

EPA, in consultation with the support agency partners, the alternatives array will be modified to

assure that the array identifies a complete and appropriate range of viable alternatives to be

considered in the detailed analysis. The alternatives array will build on the FS Work Plan, as

appropriate. The range of alternatives will include, as appropriate,

• Options in which treatment is used to reduce the toxicity, mobility, or volume of wastes, but

which vary in the types of treatment, the amount treated, and the manner in which long-term

residuals or untreated wastes are managed,

• Options involving removal;

• Options involving containment with little or no treatment,

• Options involving both treatment and containment, and,

• A no-action alternative.

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The Alternatives Screening Technical Memorandum will document the methods, rationale and results

of the alternatives screening process, and will include:

• Remedial Action Objectives

• Identification of Areas and Volumes of Media

• Identification, Screening, and Documentation of Remedial Technologies and Processes

• Assembly and Documentation of Remedial Action Alternatives

3.2.1 Remedial Action Objectives

Remedial Action Objectives (RAOs) will be developed through consultation with the U.S. EPA and

support agency partners. The baseline human health and ecological risk assessment (Integral, 2007

and 2008, U.S. EPA, 2008, Integral 2009) will serve as the basis for establishing site-specific RAOs

for the soil in the nearby residential area, the former operations area, and the southwest area. The FS

for Fox Creek sediment will be completed at a later date and is not a part of this Work Plan The

RAOs will specify the contaminants of concern (COCs) and media of concern (i.e., soil), potential

exposure pathways and receptors, and contaminant level or a range of levels at particular locations

for each exposure route (i.e , preliminary remediation goals) that are protective of human health and

the environment. RAOs will be developed by considering the factors set forth in 40 C.F.R. §

300.430(e)(2)(i).

3.2.2 Identify Areas or Volumes of Media

The Alternatives Screening Technical Memorandum will identify general areas or volumes of soil to

which response actions may apply, taking into account requirements for protectiveness as identified

in the RAOs and the chemical and physical characterization of each area.

3.2.3 Identify, Screen, and Document Remedial Technologies

The Alternatives Screening Technical Memorandum will.

• Identify and evaluate applicable technologies and/or process options, and,

• Eliminate those technologies that cannot be implemented in a specific area of the Site

Technologies and/or process options will be evaluated based on effectiveness, implementability, and

cost factors The goal will be to select one or more representative processes for each technology

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type. Whenever practicable, the technologies/process options will also consider the CERCLA

preference for treatment over conventional containment or land disposal approaches

3.2.4 Assemble and Document Alternatives

The Alternatives Screening Technical Memorandum will identify potential Applicable or Relevant

and Appropriate Federal, State and Tribal requirements (ARARs) and non-promulgated criteria,

advisories, guidance, and policies issued by federal, state, or tribal governments to be considered

requirements (TBCs) and how the technologies/process options meet those potential ARARs and

TBCs. As described in the FS-AOC, U.S. EPA considers the following as potential ARARs or TBCs:

•

•

Approach for Addressing Dioxin in Soil at CERCLA and RCRA Sites, U.S. EPA, OSWER

Directive 9200 4-26, April 13, 1998;

Risk-Based Guidance for the Soil-Human Health Pathway, MPCA, Site Remediation Section,

Working Draft, September 1998 (i e., MPCA Soil Reference Values);

• Guidance on Incorporation of Planned Property Use into Site Decisions, MPCA, Site

Remediation Section, Working Draft, September 1998;

• Leech Lake Hazardous Substances Control Act, LLBO, Resolution No. 01-29, August 25,

2000;

• Leech Lake Land Acquisition Ordinance, LLBO, Resolution No 09-34, Ordinance 2009-01

The screening of technologies and process options will be conducted to assure that only the

technologies and process options with the most favorable composite evaluation of all factors are

retained for further analysis As appropriate, the screening will preserve the range of treatment and

containment technologies that was initially developed. The reasons for eliminating technologies

during the preliminary screening process will be presented.

The selected representative technologies and process options will be assembled into remedial action

alternatives for soils at each location of concern. Together, the alternatives will represent a range of

treatment and containment combinations that addresses the soil and locations of concern at the Site.

The memorandum will summarize the assembled alternatives and their related potential ARARs and

TBCs.

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3.3 Task 3: Feasibility Study Report The draft FS Report will be prepared and submitted to U.S. EPA, with copies to MPCA, and LLBO,

for review and approval pursuant to Section X of the FS-AOC. The FS Report will summarize the

development and screening of the remedial technologies and process options, assembly of remedial

alternatives and present the detailed analysis of the selected remedial alternatives. In addition, the

FS Report will include the information U.S EPA, in consultation with its support agency partners,

will need to prepare relevant sections of the Record of Decision (ROD) for the Site [see Chapters 6

and 9 of U S. EPA's Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other

Remedy Selection Decision Documents (EPA/540/R-98/031, OSWER Publication 9200.1-23P, July

1999) for the information that is needed].

The FS Report will build on the Alternatives Screening Technical Memorandum and will present a

detailed analysis of the identified remedial alternatives to provide U.S. EPA, in consultation with its

support agency partners, with the information needed to select a remedy.

The FS Report will provide a detailed analysis of the remedial alternatives for each identified

location of concern at the Site. The detailed analysis will include an analysis of each remedial

alternative measured against evaluation criteria set forth in 40 C F.R. § 300.430(e)(9)(iii) and a

comparative analysis of alternatives using the same criteria as the basis for comparison.

3.3.1 Apply Nine Criteria and Document Analysis

The FS Report will apply the evaluation criteria to the assembled remedial alternatives to document

that the selected remedial alternative will protect human health and the environment and meet

remedial action objectives; will comply with or include a waiver of ARARs (will address compliance

with ARARs); will be cost-effective; will utilize permanent solutions and alternative treatment

technologies, or resource recovery technologies, to the maximum extent practicable, and will address

the statutory preference for treatment as a principal element. The U.S. EPA-established evaluation

criteria include: 1) overall protection of human health and the environment; 2) long-term

effectiveness and permanence; 3) short-term effectiveness; 4) compliance with ARARs, 5) reduction

of toxicity, mobility, or volume through treatment, 6) implementability, 7) cost, 8) state and tribal

acceptance; and 9) community acceptance. (Note- criteria 8 and 9 will be considered after the FS

Report has been released to the general public.)

For each alternative, the FS Report will contain' 1) a description of the alternative that outlines the

waste management strategy involved and identifies the key ARARs and TBCs associated with that

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alternative, and 2) a discussion of the individual criterion assessment. Since the Respondents do not

have direct input on criteria 8, state and tribal acceptance; and 9, community acceptance; the U.S.

EPA will address these criteria in consultation with its support agency partners after the FS Report is

released for public comment.

3.3.2 Compare Alternatives Against Each Other and Document the Comparison of Alternatives

The FS Report will provide a detailed comparative analysis among the remedial alternatives Each

alternative will be compared against the other alternatives using the evaluation criteria. The FS

Report will present a recommended alternative although it is recognized that U.S. EPA in

consultation with its support agency partners will ultimately identify and select the preferred

alternative.

3.3.3 Alternatives Analysis for Institutional Controls

Institutional controls are nonengineering measures designed to prevent or limit exposure to

hazardous substances left in place at a site, or assure effectiveness of the chosen remedy. Institutional

controls are usually, but not always, legal controls, such as easements, restrictive covenants, and

zoning ordinances (U.S. EPA, 2000)

For each alternative that relies on institutional controls, the FS Report will provide an evaluation of

the following: 1) overall protection of human health and the environment including what specific

institutional control components will ensure that the alternative will remain protective and how these

specific controls will meet the RAOs, 2) compliance with potential ARARs and TBCs, 3) long-term

effectiveness including the adequacy and reliability of institutional controls and how long the

institutional control must remain in place; 4) short-term effectiveness including the amount of time it

will take to impose the institutional control; 5) implementability including research and

documentation that the proper entities (e.g., potential responsible parties, state, and local government

entities, local landowners, conservation organizations) are willing to enter into any necessary

agreements or restrictive covenants with the proper entities and/or that laws governing the restriction

exist or allow implementation of the institutional control, and 6) cost, including the cost to

implement, maintain, monitor and enforce the institutional control. State, tribal and community

acceptance of the institutional control will be evaluated by U.S EPA after receiving public comments

on the FS Report.

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3.4 Task 4: Progress Reports International Paper and the BNSF Railway Company will provide U.S. EPA and support agency

partners with project progress reports as follows:

3.4.1 Monthly Progress Reports

International Paper and the BNSF Railway Company will submit written and electronic monthly

progress reports to U.S. EPA, LLBO and the MPCA concerning actions undertaken pursuant to the

FS-AOC in accordance with the schedule in Section 4.0 of this FS Work Plan, unless otherwise

directed in writing by the U.S. EPA RPM. These reports will include a description of significant

developments during the preceding period, including the specific work that was performed and any

problems that were encountered; a summary of any analytical data that was received during the

reporting period, and the developments anticipated during the next reporting period, including a

schedule of work to be performed, anticipated problems, and actual or planned resolutions of past or

anticipated problems. The monthly progress report will summarize any field activities conducted

during that month. In addition, International Paper and BNSF Railway Company will provide the

U.S. EPA RPM with any laboratory data with the monthly progress reports and in no event later than

ninety (90) days after samples are shipped for analysis. These monthly progress reports will continue

until the final FS Report is submitted or until other correspondence from U.S. EPA terminates this

obligation.

3.4.2 Semi-Annual Progress Reports

In accordance with the schedule in Section 4.0, International Paper and BNSF Railway Company will

submit Semi-Annual Progress Reports including underlying data, in hard copy and electronic

formats, to U.S. EPA, LLBO, and MPCA. These reports will address the areas of the Site where

International Paper and BNSF Railway Company perform FS activities and will summarize overall

progress in completing the work required by the FS-AOC. These reports will continue until

termination of the FS-AOC, unless otherwise directed in writing by U.S. EPA.

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4.0 General Schedule

The FS-AOC and related scope of work establish the general schedule for preparation of the

Alternatives Screening Technical Memorandum and the Feasibility Study Report. The project start

date as defined by the U.S. EPA is the effective date of the FS-AOC (September 11, 2008).

The following general schedule will apply to the FS activities. The general schedule may be modified

when- (1) a different schedule is approved by U S. EPA in a Work Plan or other U.S. EPA-approved

document; or (2) International Paper and BNSF Railway Company submit, in writing, a request for

an extension or schedule modification, and U.S EPA approves such request

DELIVERABLE DUE DATE

TASK 1 - Feasibility Study Work Plan - Soils

TASK 2 - Alternatives Screening Technical Memorandum - Soils

TASK 3 - Feasibility Study Report - Soils

Draft FS Work Plan is due 45 days after the effective date of the FS-AOC (i.e., October 27, 2008). Final FS Work Plan is due 30 days after U S. EPA direction to modify the draft FS Work Plan pursuant to Section X of the FS-AOC.

60 days after submittal of the Final FS Work Plan.

Draft FS Report due 90 days after receipt of U.S. EPA's comments on the Alternatives Screening Technical Memorandum Final FS Report is due 45 days after receipt of U.S. EPA's direction to modify the draft FS Report pursuant to Section X of the FS-AOC

Task 4 - Progress Reports

Monthly Progress Reports

Semi-Annual Progress Reports

Miscellaneous Documents

Due on the 15"" day of each month or the first business day after the 15"" of the month commencing 60 days after September 11, 2008 and continuing until the Final FS Report is submitted, covering the previous month (first report due November 15, 2008).

Due six months after the effective date of the FS-AOC (i.e , March 11, 2009), and every six months thereafter until the Final FS Report is submitted.

In accordance with the submittal date provided by the U S. EPA RPM.

For the Fox Creek Area of the Site, the following schedule will apply for the FS Work.

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DELIVERABLE DUE DATE

TASK 1 - Feasibility Study Work Plan - Fox Creek Area

TASK 2 - Alternatives Screening Technical Memorandum - Fox Creek Area

TASK 3 - Feasibility Study Report - Fox Creek Area

Miscellaneous Documents

Draft FS Work Plan - Fox Creek Area is due 20 days after the U.S. EPA approval of the 28-day amphipod study to be conducted by the PRP International Paper under the Unilateral Administrative Order issued by the U S. EPA on August 11, 2004. Final FS Work Plan - Fox Creek Area is due 10-days after U.S. EPA direction to modify pursuant to Section X of the FS-AOC

50 days after submittal of the Final FS Work Plan - Fox Creek Area.

Draft FS Report - Fox Creek Area is due 70 days after receipt of U.S. EPA's comments on the Alternatives Screening Technical Memorandum - Fox Creek Area. Final FS Report - Fox Creek Area is due 25 days after receipt of U.S EPA's direction to modify the draft FS Report - Fox Creek Area pursuant to Section X of the FS-AOC.

In accordance with the submittal date provided by the U.S EPA RPM

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References

Integral 2007. Human Health and Ecological Risk Assessment, St. Regis Paper Company Site, Cass

Lake, MN Prepared for International Paper pursuant to Unilateral Administrative Order

Docket No. V-W-04-C-796 Prepared by Integral Consulting Inc September 28, 2007.

Integral 2008. Addendum Human Health and Ecological Risk Assessment, St. Regis Paper Company

Site, Cass Lake, MN. Prepared for International Paper pursuant to Unilateral Administrative

Order Docket No. V-W-04-C-796. Prepared by Integral Consulting Inc. May 30, 2008.

Integral 2009. TO BE DEVELOPED. Revisions Based on the Results of the 28-day Amphipod Study.

Prepared for International Paper pursuant to Unilateral Administrative Order Docket No. V-W-

04-C-796 Prepared by Integral Consulting Inc. 2009.

U.S. EPA, 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies Under

CERCLA, Interim Final, Office of Emergency and Remedial Response U S. Environmental

Protection Agency Washington, D C. 20460. EPA/540/G-89/004. October 1988

U S EPA, 1999. Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other

Remedy Selection Decision Documents (EPA/540/R-98/03 1, OSWER Publication 9200.1-23P,

July 1999).

U.S. EPA, 2000. Institutional Controls and Transfer of Real Property under CERCLA Section

J20(h)(3)(A), (B) or(C). U.S. Environmental Protection Agency.

http //www epa.iiov/fedfac/pdf/fi-icops_106 pdf. February 2000.

U S EPA, 2008. Approval of the HHERA with Modifications Letter from Tim Drexler, U S. EPA

RPM to Tom Richardson, International Paper Dated August 15, 2008.

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Tables

Table 1

Project Contacts Feasibility Study Work Plan

St. Regis Paper Company Site

Tim Drexler Remedial Project Manager U S. EPA, Superfund Division 77 West Jackson Blvd SR-6J Chicago, IL 60604-3590

Phone: 312-353-4367 Email: drexler timothv(S)epa gov

John Persell St Regis Site Project Coordinator Leech Lake Band of Ojibwe 6530 U.S. 2 NW Cass Lake, MN 56633

Phone. 218-335-7412 Email. psersell(a)lldrm org

Susan Johnson Project Manager Minnesota Pollution Control Agency 525 S Lake Avenue Suite 400 Duluth, MN 55802

Phone 218-725-7762 Email- susan iohnson(a>pca state mn us

Tom Richardson Project Manager International Paper 6400 Poplar Avenue Memphis, TN 38197

Phone: 901-419-3878 Email tom richardson(S)ipaper com

Greg Jeffries Manager Environmental Remediation BNSF Railway Company General Office Building 80 44"" Avenue NE Minneapolis, MN 55421

Phone: 763-782-3490 Email. greqory geffnes(a)bnsf com

Tom Mattison Project Coordinator Barr Engineenng Company 4700 West 77th Street Minneapolis, MN 55437

Direct- 952-832-2876 General 952-832-2600 Email. tmattison(a)barr com

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Project Organization FS Work Plan - Soils

Leech Lake Band of Ojibwe St Regis Site Project Coordinator

John Persell

U.S. EPA Region 5 Remedial Project Manager

Tim Drexler

Minnesota Pollution Control Agency Project Manager

Susan Johnson

International Paper Company

Project Manager

Tom Richardson

Barr Engineering Company

Project Manager

Tom Mattison

BNSF Railway Company Manager Environmental Remediation

Greg Jeffnes