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STATEMENT OF WORK SITE INVESTIGATION ON THE BURLINGTON DEPARTMENT OF PUBLIC WORKS

PROPERTY FOR CONTRACT 6 - CHAMPLAIN PARKWAY FROM LAKESIDE AVENUE TO PINE STREET TO BATTERY STREET - PINE STREET BARGE CANAL SITE

SECTION 1 OBJECTIVES REPORTING REQUIREMENTS SCHEDULE AND DELIVERABLES

I OBJECTIVES

The objectives of the site investigation on the Champlain Parkway C-6 Alignment along Lakeside Ave and Pine Street and the feASMO_proper_ty_(-collectively referred to as the C-6 Alignment) are to clarify the nature extent and source of the contamiriatiori and to develop remedial alternative(s) if required Some soil boring and sampling contaminant information is available from the Supplemental Remedial Investigation (SRI) conducted by an Environmental Protection Agency (EPA) Contractor in 1990 on the io^ Street Barge CanalSite other information from studies in 1988 by Aquatee in 1989 by PEER Consultants and most recently by The Johnson Co is also available for the C-6 Alignment This soil pound 5deg ^ deg ^ limited in areal extent and depth on parts of tne C-6 Alignment No groundwater monitoring wells were installed Lf ^ f ^^^ ^^ Alignment so groundwater quality is unknown Additionally a Feasibility Study (FS) was completed by an EPA contractor in 1992 This document can be used to identify remedial alternatives r

The site invesstigation is being conducted by the City of Burlington to document an coart^fmt anyy coal t^^related or other environmental contamination on the C-6 Alignment If contamination Is found it must be cleaned-up prior to the city constructing the part of the

^ Champlain Parkway known as the c-6 Alignment This construction would create a connection between Lakeside Avenue along Pine Street and then to Battery Street

bull The^Scope of Work (SOW) will require the City to (1) focus V ^ studies to clarify the nature extent and source of coa-lmdashtar lt^^^ related contamination on the C-6 Alignment (2) investigate thed^ nature extent and source of any other contamination on the properties not related to the former coal^ gasification plant ea leaking petroleum product^^-^nampegtri^aTetanksdeg^ remedial alternatives if needed and (4) consider the effects of highway construction not only pn the part of the properties where road construction will take place but on the Barge Canal Site and entire C-6 Alignment Any area outside of these properties and part of the Pine Street Barge Canal Site that is used for or directly gt affected by road construction activities must be Identified by the City for-inclusion in this SOW

II REPORTING REQUIREMENTS bull

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p-All data methods and interpretations must be

1 scientifically and technically sound with all assumptions biases potential deficiencies safety factors and design criteria explicitly stated in writing

2 discussed with observations and interpretation clearly identifiable and distinguishable

3 discussed with all supporting reference material clearly identified and included

4 concisely illustrated and presented in separate graphs charts maps plans andor cross-sections where possible sp that the text provides a clear discussion ofsuch illustrations

5 linked to each and every objective for which they were completed and to which they are applicable and

6 sufficient to satisfy the objectives of the site investigation listed above

III SCHEDULE AND DELIVERABLES

A Schedule

The schedule of work to be performed by the City in conducting this site investigation is outlined in Table 1 below

Table 1 Schedule of Work

ITEMS DELIVERABLE DUE DATE

1 Work Plan Site Investigatipn Thirty days following Preparation on C-6 Alignment effective date of AOC

Workplan

2 Commence Field Notification Letter Ten days after Work from Respondents Approval of Work

Plan

3 Field Work Notif icat ion Let ter 180 days a f te r Completed from Respondents a p p r o v a l o f

Work Plan

Report Investigation 210 days after

^ y ^ Delivered Report approval of ^ ^ Work Plan

I c

B Deliverables

The major deliverables fPr each step of the Site Investigation are shown on Table 1 The actual number of deliverables may vary depending on

1 revisionsbased on State iand EPA review

2 requests for additional field studies analyses and documentation by the State and EPA and

J3 the quality and completeness of the Respondents work

C Schedule bull bull3

The schedule for the Respondents to Pommence work under gt this SOW and to deliver the Work Plan for the Site j Investigation shall be triggered by the effective date of Si the Administrative Order by Consent (AOC) Initiation of the other components of work shall be triggered by notice from the State and EPA as outlined in Table 1 A component of the investigation will not be started ahead of another component unless prior approval by the State and EPA

SECTION 2 WORK PLAN

OBJECTIVES

The Work Plan shall include

A site background and features including location map(s)

B project history of the Champlain Parkway

C clearly defined purpose and objectives of the S i ^ xLac^ A Investigation on the C-6 Alignment nciltJ^^^ t r ^ ^ r - u

D overview ot all procedures for all work required to meet the interit purposes and objectives consistent with the November22 1993 letter from Merrill S Hohman EPA Waste Management Director to Susan Compton Esqgt attorney for the City

E discussion of how the City will evaluate and report the data

F a detailed schedule (based on the schedule contained in Table 1) which shows when various components of the site investigation will take place arid when deliverables will be submitted

G sampling and analysis plans that will provide a process for obtaining data of sufficient quality and quantity to satisfy data needs (this includes a field sampling plan and a laboratory quality assurance project plan)

H site-specific health arid safety plans that shall specify at a minimum employee training and protective equipment medical surveillance requirements standard operation procedures and a contingency plan that conforms with 29 CFR 1910120 (l)(l) and (1) (2) and

I discussiPn of community relations support

II DELIVERABLES J ^

A Overview rf bull r 6^

The City shall design an investigationthat is sufficient to fully address the objectives listed above The Work Plan shall provide a comprehensive overview of all work required in this SOW^ Additional details of the various compPnents of the investigation shall be presented in the Field Sampling Plan (FSP) The FSP shall fully describe the locations methods field forms procedures and types of analyses to be used in performing the investigation including surface subsurface hydrogeological and surface water investigations This description shall include all methods and protocols to be used The Work Plan shall clearly show bull the relationship between the objectives and the studies to be performed The Work Plan shall provide a mechanism for the State and EPA to review and approve of deviations from the approved Work Plan The Work Plan shall allow for the potential for additional work contingent on the results of the studies described in the site investigation Work Plan

B Work Plan

Prior to the commencement of field activities the City shall prepare the following site-specific plans to establish procedures to be followed by the City in performing field and laboratory work and community and State and EPA liaison activities The City shall deliver to the State aind EPA a Site Investigation Work Plan in writing The Work Plan shall consist of the following elements

1) Site Management Plan (SMP) 2) Sampling and Analysis Plan (SAP) which includes the

Field SampLing Plan (FSP) and the Quality Assurance Project Plan (QAPP)

3) Health arid Safety Plan (HSP)

4) Community Relatioris Plan and 5) Expanded Project Schedule

Collectively these documents are referred to as the G-6 Alignment Site Investigation Work Plan in Table 1 and elsewhere in bullthis document The Work Plan or elements of the work plan shall be revised as necessary and revisions as appropriate submitted prior to each subsequent phase of work as described in Table 1 or additional phases of work determined to be necessary

The Work Plan is subject to State and EPA review The Work Plan must be rewritten in response to a request by the State or EPA for revision before any field work commences The City shall modify the format and scope of each plan as needed to describe the sampling analyses and other activities that are clarified as the investigation progresses Before field work commences the Work Plan must be approved by the State The elements of the Work Plan are discussed in the following subshysections ^

1 Site Management Plan (SMP)

The overall objective of the Site Management Plan is to provide the State and EPA with a written understanding and commitment of how various project aspects such as access security contingency procedures managiement responsibilities investigation-derived waste disposal budgeting and data handling are being managed by the City As part of the SMP the City shall include

a a map of the property which will be investigated O bull bullbull bull bull bull bull bull

b a clear indication of the exclusion zone contamination reduction zone and clean area for on-site and off-site (if necessary) activities

c measures to prevent uriauthorized entry to the site if bull necessary to prevent exposure of persons to potentially hazardous conditions

d the location of a field office if necessary for on-site activities bull

e contingency and notification plans for (for state federal and local~authorities) potentially dangerous activities associated with the investigation

f provision for the monitoring of airborne contaminants released by site activities which may affect the local populations

g procedures for communication to theState EPA and the

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public about the organization and management of the investigation including key personnel and their roles and responsibilities

h a list of-potential contractors and subcontractors of the City in the investigation and a description of their activities and roles

i provision for the proper disposal and out of state notification of material used and wastes derived during the investigation (eg drill cuttings extracted groundwater protective clothing disposable equipment) These provisions shall be consistent with the off-site disposal aspects of SARA RCRA and applicable State laws The City

shall be identified as the generator of wastes for the purpose of regulatory of policy compliance

j plans and procedures for organizing analyzing and presenting the data generated during all phases of the investigation and for verifying its quality before and during the investigation These plans shall include the description of the proposed computer data base management system

2 Sampling and Analysis Plan (SAP)

The purpose of the Sampling and Analysis Plan is to ensure that sampling data collection activities will be comparable to and compatible with previous data collection activities performed at thesite while providing a mechanism for planning and approving field activities

- The overall objectives of the Sampling and Analysis Plan are as follows

a to document specific data iguality objectives procedures and rationales for field work and sample analytical work

b to provide a mechanism for planning and approving site and laboratory activities

c to ensure that sampling and analysis activities are necessary and sufficient and

d to provide a common point of reference for all parties to ensure the comparability and compatability of all objectives and of sampling and analysis activities

The SAP shall be the framework for all anticipated field activities (eg sampling objectives evaluation of existing data standard operating procedures) and contain specific information on the field work (eg sampling location and rationale sample numbers

and rationale ananyses of samples) During the investigation the SAP shall be revised as necessary to cover each round of field or laboratory activities Revisions or a statement regarding the need for revisions shall be included in jeacli deliverable describing new field work

The SAP consists of two parts (1) the Field Sampling Plan (FSP)and (2) a Quality Assurance Project Plan (QAPP) Components of these two individual plans are described in the following sections In addition the FSP and QAPP should be submitted as a single document

The SAP shall specify in the FSP provisions for notifying the State and EPA four (4) weeks before initiation of each field sampling or monitoring activity The plan shall also allow split replicate or duplicate samples to be requested or to be taken by the State or EPA and by other parties approved by the State and EPA

Guidance on the topics covered in the FSP and the QAPP and their integration into each of these plans and the integration of the QAPP aind the FSP into the SAP can be found in the following several references which shall be used to develop the SAP

Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (OSWER Directive 9355-3-01 EPA540G-89004 bull October 1988) bull

Data Quality Objectives for Remedial Response Activities Development Process (OSWER Directive 93550-7 EPA540G-87003 March 1987)

Draft Data Quality Objectives for Remedial Response Activities Example Scenario RIFS Activities at a Site with Contaminated Soil and Grotind Water (OSWER Directive 93550-7B EPA540G-87002 March 1987)

Test Methods for Evaluating Solid Waste PhysicalChemical Methods (EPA Pub SW-amp46 Third Edition)

Guidance for Data Useability in Risk Assessment Part A (EPA Pub 92857-09AFS May 1992)

Ecological Assessment of Hazardous Waste Sites A Field and Laboratory Reference Document (EPA 6003-89013) March 1989

Framework for Ecological Risk Assessment (EPA630R-92001 February 1992)

Ground Water Technical Enforcement Guidance Document (OSWER Directive 9950 Sept 1986) and

Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites (OSWER Dir 92831-2 Final Review Draft EPA August 1988)

2A Field Sampling Plan (FSP)

The objective of the Field Sampling Plan is to provide the State and EPA and other parties involved with the collection and use of field data with a common written understanding of all fieldwork The FSP shall address the site investigation objectives and conform to the procedures in Section 2 of this document and the National Contingency Plan (NCP)

The FSP shall define in detail the sampling and data gathering methods used on a project The FSP shouldbe written so that a field sampling team unfamiliar with the site would have sufficient information and knowledge about the sites- history earlier investigations to be able to gather the samples and field information required to fulfill thecurrent data objective needs Guidance for the selection of field methods sampling prpcedures and custody can be acquired from the Compendium of Superfund Field Operations Methods (OSWER Directive 93550-12 EPA540P-87001) which is a compilation of demonstrated field techniques that have been used during remedial response activities at hazardous waste sites ~

The FSP shall be site-specific and shall include the following information

C-6 Alignment Background - The analysis of the existing property details must be included in the FSP In order to avoid duplication of effort reference to earlier studies on the properties conducted during the Remedial InvestigationFeasibility Study (RIFS) process may be made However the property background should include a conceptual property model A conceptual model includes a description of the properties and surrounding areas and a discussion of known and suspected contaminant sources probable transport pathways and other informationabout the properties that the field samplingteam will need to know in order to successfully collect the data in manners which meet the data quality objectives The FSP shall alsoinclude descriptions of specific data gaps and ways in which sampling is designed to fill those gaps

Sampling Objectives - Specific objectives of a sampling effort that describe the intended uses of data must be clearly and succinctly stated

Sample Location Analytes and Frequency - This section of the sampling plan identifies each sample matrix to be collected and the constituents to be analyzed Tables shall be used to

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clearly identify the number of samples to be collected along with the appropriate number of replicaties and blanks Figures shall be included to show the locations of existing or proposed sample points

Sample Designation - A sample numbering system shall be established The sample designation should include the sample or well number the sample round the sample matrix (eg surface soil groundwater soil boring) and the name of the properties

Sampling Equipment and Procedures - Sampling procedures must be clearly written Step-by-step instructions for each type of sampling are necessary to enable the field team to gather data that shall meet the Data Quality Objectives (DQOs) A list should include the equipment to be used and the material composition (eg teflon stainless steel) of equipmerit along with decontamination procedures

Sampling Handling and Analysis - A table shall be included that identifies sample preservation methods types of sampling jars shipping requirements and holding times Examples of paperwork such as traffic reports chain of custody forms packing slips and sample tags filled out for each sample as well as instructions fpr filling out the paperwork must be included Field documentation methods including field notebooks and photographs shall be described

Each Field Sampling Plan submitted as a part of the Work Plan for the C-6 Alignment shall be sufficiently detailed to carry out the study and shall provide data needed to fully address the objective of the study and to complete the study Each study shall be designed to achieve a high performance on the first attempt Each work plan shall be related (by cross-references) to the other requirements in the site investigation work plan

2B Quality Assurance Project Plan (QAPP)

TheQuality Assurance Project Plan (QAPP) shall document in writing site-specific objectives policies organizations functional activities and specific quality assurancequality control activities designed to achieve the data quality objectives (DQOs) of the site investigation The QAPP shall cover all environmeritally related measurements The QAPP develpped for this project shall document quality control and quality assurance policies procedures routines and specifications

All project activities throughout the site investigation shall comply with the QAPP All QAPP sampling - and analysis objectives and procedures shall be consistent with Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans (EPA 1983 - EPAQAMS 00580) and appropriate EPA handbooks manuals and guidelines including Test Methods for

Evaluating Solid Waste PhysicalChemical Methods (EPA Pub SWshy846 Third Edition as amended by update 1) (Routine Analytical

Services RAS should be used in lieu of Special Analytical Services when possible) and Guidelines Establishing Test Procedures for the Analysis of Pollutants (40 CFR Part 136)

The 16 basic elements ojf the QAPP are

a) title page with provision for approval signaturesof principal investigators -

b) table of corttents

c) project description

d) project organization and responsibility

e) quality assurance objectives for measurement data in terms of precision accuracy completeness representativeness and comparability

f) sampling procedures

g) bull sample custody

h) calibration procedures and frequency

i) analytical procedures which must be EPA approved or equivalent methods or-methods which have been expressly incorporated into this SOW

j) data reduction validation and reporting

k) internal quality control checks and frequency

1) performance and systemaudits and frequency

m) preventive maintenance procedures and schedules

n) specific routine procedures to be used to assess the precision accuracy and completeness of data and to assess specific measurement parameters involved

o) corrective action and

p) quality assurance reports to management

As indicated -in EPAQAMS-00580 the above list of essential elements must be considered in the QAPP for the site investigation If a particular element is not relevant to a project and therefore excluded from the QAPP specific and detailed reasons for exclusion must still be provided

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Information in a plan other than the QAPP may be cross-referenced clearly in the QAPP provided that all objectives procedures and rationales in the documents are consistent and the reference material fulfills the requirements of EPAQAMS-00580 Examples of how this cross reference might be accomplished can be found in the Data Quality Objectives for Remedial Response Activities (OSWER Directive 93550-7B) and the Data Quality Objectives for Remedial Response Activities Examjple Scenario (OSWER Directive 93550-7B) EPA-approved references or equivalent or alternative methods approved by the State and EPA shall be used and their corresponding EPA-approved guidelines shall be applied when they are available and applicable

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Laboratory QAQC Procedures

The QAQC procedures for any laboratory (both fixed and mobile) used during the site investigation shall be included in the Citys QAPP When this work is performed by a contractor to a private party each laboratory performing chemicalanalyses shall meet the following requirements

a) be approved by the State LaboratoryEvaluation Program if available

b) have successful performance in one of EPAs National Proficiency Sample Programs (ie Water Supply or Water Pollution Studies -or the States Proficiency Sampling Program)

c) be familiar with the requirements of 48 CFR Part 1546 contract requirements fpr quality assurance and

d) have a QAPP for the laboratory including all relevant bullanalysis This plan shaill be referenced as part of the contractors QAPP

Data Validation Procedures

The City is required to certify that all data has been validated by an independent person according to the Region I Laboratory Data Validation Functional Guidelines for Evaluating Organic Analyses and the Region I Laboratory Data Validation Functional Guidelines for Evaluating Inorganic Analyses (amended as necessary to account for the differences between the approved analytical methods for the project and the Contract Labpratory Procedures (CLP) procedures) or as indicated in this SOW Approved validation methods shall be contained in the QAPP

The independent person shall not be the -laboratory conducting the analyses arid should be a person with a working knowledge of or prior experience with EPA data validation procedures The independent persori shall certify that the data has

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been validated discrepancies have been resolved if possible and the appropriate qualifiers have been provided

The respondents must keep the complete data package and make it available to the State and EPA oh request in order for the State arid EPA to conduct an independent validation of the data The complete data package shall consist of all results the raw data and all relevant QAQC information An example set ofdata package deliverables is listed below

a) a summary of positive results and detection limits of nori-detects with all raw data

b) tabulated surrogate recoveries and QC limits from methods 3500 and 8000 in SW-846 and all validation and sample raw data

c) tabulated matrix spikematrix spike duplicated recoveries relative percent differences spike concentrations and QC limits from methods 3500 and 8000 in SW-84 6 and all validation and sample raw data

d) associated blanks (trip equipment and method) with accompanying raw data for tests shy

e) tabulated initial and continuing calibration results bull (concentrations calibration factors or relative response

factors and mean relative response factors difference and relative standard deviations) with accompanying raw data

f) tabulated retention time windows for jeach column ^

g) a record of the daily analytical scheme (run logbook instrument logbook) which includes samples and standards order of analysis

h) the chain of custody fpr the sample shipment grpups SAS packingslip SAS request forms

i) a narrative summary of method and any problems encountered during extraction or analysis

j) tabulated sample weights volumes and solids used in each sample calculation

k) example calculations for positive values and detection limits and

1 ) SW-846 method 3500 and 8000 validation data for all bull - tests

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The forms contained in Chapter 1 of SW-846 (Second Edition 1982 as amended by Update I April 1984 and Update II April 1985) must be utilized to report the data when applicable Raw data includes the associated chromatograms and the instrument printouts with area and height peak results The peaks in all standards and samples must be labelled The concentration of all standards analyzed with the amount injected must be included

3 Health and Safety Plan

The objective of the site-specific Health and Safety Plan (HSP) is to establish the procedures personnel resppnsibilities and training necessary to protect the health and safety of all on-site personnel during the site investigation The plan shall provide for routine but hazardpus field activities and for unexpected site emergencies The current site-specific HSP may be used for subsequent field activities with little or ^no modifications provided that the site conditions have not changed or that the activities to be performed are similar to previous activities for which the HSP was developed Substantial modifications may be required for changes in site conditions or types of field activities

The site-specific health or safety requirements and procedures in the HSP shall be based oh an ongoing assessment of site conditions including the most current information on each medium For each field task during the site investigation the HSP shall identify

a) possible problems and hazards and their solutions

b) environmental surveillance measures

c) specifications for protective clothing

d) the appropriate level of respiratory protection

e) the rationale for selecting that level

f) criteria procedures and mechanisms for upgrading the level of protectionnecessary and

and for suspending activity if shy

g) clean contaminantexclusion zones

reductiondecontamination and

The HSP shall also include the delineation of exclusion -areas on a map and describe provisions for this delineation in the field and procedures for proper decontamination and disposal of decontamination fluids The HSP shall indicate the on-site person responsible for inplementing the HSP as a representative of the city protective equipment personriel decontamination procedures

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and medical surveillance The following documents shall be consulted

Interim Standard Operations Safety Guides (Hazardous Response Support Division Office of Emergency and Remedial Response EPA Wash DC 1982)

Hazardous Waste Operations and Emergency Response (Department of Labor Occupational Safety and Health Administration (OSHA) 29 CFR Part 1910) and

Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities Appendix B

- (NIOSHOSHAUSCGEPA 1985)

OSHA regulations at 29 CFR 1910 and Chapter 9 of the Interim Standard Operating Safety Guide which describes the routine emergency provisions of a site-specific health and safety plan shall be the primary reference used by the City in developing and implementing the Health and Safety Plan

The measures in the HSP shall be developed and implemented to ensure compliance with all applicable state and federal occupational health and safety regulations The HSP shall be consistent with the objectives and contents of all other plans submitted by the City The HSP shall be updated at the request of the State and EPA during the course of the site investigation and as necessary to support the different work or phases of work of the site investigation

4 Community Relations

The City shall develop a Community Relations Plan (CRP) or use the Community Relations Plan developed by the Pine Street Potentially Responsible Parties (PRPs) for the Additional Remedial Investigation (ARI) which is in progress on the Pine Street Site The CRP describes the public relations activities anticipated during the site investigation at the BDPW property The CRP shall include at a minimum

a participation inmeetings includiequipment

publicng the provision

informational of vis

orual technical aids and

b publicationand

and copying of fact sheets or updates bull

c assistance in preparing a responsiveness summary after public comment period(s) as requested by the State or EPA

5 Schedule for the Site Investigation

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3

The- deliverables for the site investigation are identified in Table 1 The schedule for all tasks shall be included asa component of the Work Plan prepared by the City for the site investigation Any modifications to the schedule must be approved by the State and EPA prior to their implementation

The schedule shall be presented as a chart which shall include target dates and time periods for each deliverable to the extent possible The chart shall be updated when arid if the schedule changes by showing the original (planned) due date and revisions of the due date

SECTION 3 FIELD INVESTIGATIONS

bull^11 OBJECTIVES

The goal of the C-6 Alignment site investigation shall be to collect field data which is necessary to characterize the nature extent and source of contamination on the property Thisdata collection will allow the City to develop remedial alternative(s) if required for the property so that a part of the Champlain Parkway can be constructed

The City shall perform all the components of the site investigation as outlined in this section (Sectiori 3) of this SOW in accordance with the schedule provided in Table I

II WORK PLAN REQUIREMENTS

The site investigation shall consist of the activities and deliverables described in this section (Section 3) of this SOW The City shall prepare a written Site Investigation Work Plan in accordance with Section 2 of this SOW which shall be reviewed by EPA and reviewed and approved by the State before startirig the site investigation

III SCHEDULEDELIVERABLES shy

The City shallbegin the site investigation within the time period provided in Table 1 of this SOW During the implementatiori of the work forthe site investigation the City shall provide for the States and EPAs review and approval all proposed deviations from the procedures in the Work Plan before making such changes in the field

IV COMPONENTS OF THEC-S ALIGNMENT SITE INVESTIGATION

A Additional Site Characterization

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Objective To develop a detailed large scale topographic map of the C-6 Alignment

The City shall perform the following activity

Site Survey

The City shall construct or update (if a map already exists) a topographic suryey map of the C-6 Alignment and any adjoining property that will be affected or used for the Champlain Parkway Connector This may include properties that are not part of the Pine Street Barge Canal Site ie property immediately north of the C-6 Alignment or property immediately to the south of the C-6 Alignment

The topographic survey map shall have one (1) foot contour elevations and display all survey data collected at the property The map shall contain all standard topographic physiographic cultural and facility features the surveyed locations of all wells and underground storage tanks (if applicable) and soil sampling locations The City shall include offsite features such as sampling locations on the topographic survey map if appropriate

The City shall prepare a topographic survey map to encompass an area larige enough to show all pathways of surface water runoff onto and off of the C-6 Alignment The survey map shall beof sufficient detail to delineate areas onthe site where contaminants may migrate to or from - ~ ^

B Soil Profiling Screening and Sampling ^ (

Objective To conduct soil borings for screening profiling and sampling to determine the approximate areal nature and extent of coal taarcont ami nation Soil profiling will help deterifiine the distribution of substrate type Soil sampling will assist in pinpointing the distribution of polycyclic aromatic hydrocarbons (PAHs) in the subsurface

The City shall perform the following activities

1 Soil Boring Profiling - additional soil borings shall be conducted on the C-6 Alignment^^feo^ a depth adequate to characterize any coal Jsrx or other contamination These borings shall be located in the areas where the Champlain Parkway will cross any C-6 Alignment properties Soil borings shall be advanced with a drill rig using hollow stem augers A

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split spoon sampler will be used for continuous soil profiling A geologic and visual description will be provided of the resultant soil core All important information observed during the drilling operatipn will be carefully noted in the field

The following information is important to note for the geologic log

-Drilling methpd and type of drilling rig

- Depth to which split spoon is driven and amount of soil recovery

- Number of blow counts required to drive the split spoon sampler the required distance

- Stratigraphic descriptions lithology and estimates of particle size and

- Other soil characteristics (odprs discolorization e c t ) bull - bull

All investigation derived wastes shall be handled according to State and EPA prptocols

2 SPil Boring Screening and Sampling - all continuous split spoon samples will be screened for volatile organic compounds (VOCs) with a photoionization detector (PID) device and levels of all VOCs detected recorded PID screening along with visually determined physical characteristics(color or presence of coal tar) will be used to idehtify samples to be collected for laboratory analysis A split spoon soil sample shall be collected where screening or visual observations indicate potential contamination If screeriing andor direct observation do not indicate potential contamination two soil samples will be collected per soil boring for analysis One sample will be a composite of soil from the 0 to 10 foot depth The second sample will be collected frpm the greater than 10 foot to 20 foot level (if this depth interval is indicated) Soil sample analyses include VOCs and total individual and carcinogenic PAHs

The following soil sampling procedures shallbe followed

Immediately after the split spoon sampler is removed frpm the borehole and opened screen the length of the

bull soil core with the PID Carefully record the instrument reading If screening and visual observation indicates potential contamination a sample will be collected from the split spoon If no

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potential contamination is evident place an amount in a sealed container for compositing with soil from other spoons

Samples for VOC analysis should be collected first to minimize volatile loss bull

- Place an amount of the soil sample in a plastic bag and seal After a short period of time open a cprner of the bag and screen with the PID Carefully record the instrument reading

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- The remaining samples should riow be collected by mixing and compositing arid

- Label and tag all samples and log in the field logbook and complete the chain of custody form

Sample analysis validation arid sample parameter detection quantitation limits must be addressed in the Workplan

C Groundwater Mpnitoring bull

Objective To determine groundwater flow direction and the quality of groundwater on the C-6 Alignment where no groundwater monitoring wells have been installed This work element will document the extent and degree of contamination (if present) on the C-6 Alignment


1 Installation of Monitoring Wells - Wells shall be placed on the C-6 Alignment in locations which will best characterize the quality of groundwater A minimum auger diameter of 4-58 inches ID will be used to permitthe installation of the monitoring well casing and allow room for the sand pack in the annular space Each well will be sealed from surface runoff by placing a seal above the sand pack

Some procedures and protocols for the installation of monitoring wells follows

- Monitoring well casing shall consist of Schedule 40 polyvinyl chloride (PVC) or the equivalent The casing will be flush-threaded riser pipe screen and end cap Screen lengths will not exceed 10 feet and slots will be sized appropriately for the sand pack

T The screened interval in each well will be 2 feet above and 5 feet below the water table

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- A locking watertight cap and a steel protective casing to prevent tampering by unauthorized personnel will be installed over the well immediately after well installation and

- A well construction log will be completed for each monitoring well installed and each well will be surveyed to determine its elevation relative to existing wells on the Pine Street Barge Canal Site

2 Groundwater Monitoring Well Sampling - Groundwater wells will be sampled to collect data which indicates whether migration of site contaminants into groundwater has taken place on the property The analysis of groundwater samples will include VOCs total individual and carcinogenic PAHs (filtered and unfiltered) bull

Some procedures and protocols for the sampling of monitoring wells follows

- Screen the air iri the well head for VOCs using- a PID or other instrument and record measurements

- If a floating layer of petroleum product is encountered carefully measure its thickness before purging the well and

- Immediately label and tag all samples fill out the chain of custody form and refrigerate or ice as necessary

All investigation derived water waste shall be handled according to State and EPA protocols

D Other

Objective To determine if any other items need to be addressed in the Work Plan to adequately characterize contamination or potential contamination on the property This may include

1 The removalrelocation of underground storage tanks

2 The removal of building structures or other man made features

3 Direct impacts on the Pine Street Barge Canal Site Direct impacts include encroachment on the site along Pine Street from excavation during construction activities or from soil loading during these activities

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y 4 Indirect impacts on thesite These may be from

surface water drainage onto the site or from soil loading due to highway construction activities in close proximity to the site

Potential impacts from the above sourcesactivities must be anticipated and minimized In the event other items as listed above require investigation or action the City shall address the details of such investigation or action in the Work Plan

SECTION 4 REPORTING REQUIREMENTS y i2l^

The City shall prepare and deliver the Investigation Report according to the schedule in Table 1 Monthly progress reports shall be required during the field data collection phase of the investigatiori These reports shall be submitted by the 15th of each month following the month in which the field data collection activities took place These reports shall be sent to the State arid the EPA

SECTION 5 CLEAN-UP LEVELS

If remediation is required for all or any part of the C-6 Alignment clean-up levels will be based on the results Pf a risk assessment conducted by the City This assessment will deal with the risk to human health arid environmental media (recptors)

SECTION 6 FEASIBILITY -STUDY FOR DEVELOPING REMEDIAL ALTERNATIVES

SUBSECTION 1 Overview

1 Objectives

The objectives of the Feasibility Study (FS) for the C-6 Alignment shall be to

[ bull bull bull bull bull ^

A evaluate the feasibility and applicability of various remedial technologies (including those not previously evaluated in the November 1992 Feasibility Study Final Report prepared by Metcalf amp Eddy) includingbutnot limited to removal containment institutional controls as well as innovative treatment technologies used at existing Manufacturing Gas Plant (MGP) sites and recyclereuse optioris

B determine if new remedial alternatives can be developed for the C-6 Alignment by combining these additional remedial technologies alone or in cPmbination with those

2 0

previously evaluated in the FS

C evaluate these new remedial alternatives against the short and long-term aspects of the following three broad criteria

1 effectiveness 2 implementability and 3 cost

D evaluate each new remedial alternative or combination of alternatives and appropriate remedial alternatives or combinations thereof from the November 1992 FS Final Repprtgt prepared by Metcalf amp Eddy if new data objectives or other-information indicate significantly different conditions than

those assumed by them through a detailed and comparative analysis based upon the nine (9) criteria listed in the Guidance for Conducting Remedial Investigations arid Feasibility Studies Under CERCLA (EPA 540G-89004 OSWER Dir 93553-01 October 1988) and in the most recent NCP (40 CFR Part 3 00) or CERCLA as amended bull

The FS includes but is not limited to conceptualizations engineering analyses cost analyses and an analysis of time frames for the achievement of clean-up goals The guidance document listed in 1 D above shall be used as the basis for the development of the FS for the C-6 Alignment In addition the document entitled Presumptive Remedies Site Characterization and Remedy Selection fPr Contaminated Soil At Manufactured Gas Plant Sites may also be used in developing and completing the FS for the C-6 Alignment

II Overview of FS Work

The City shall perform all tasks necessary to complete the FS necessary fpr selection of a remedy in accordance with CERCLA and the NCP- In performing the FS the City should use to the extent feasible the FS completed by Metcalf amp Eddy dated November 1992 Where technologies and or alternatives are retained by the City from the previous FS the detailed analysis of alterriatives must be conducted in such a manner that the detailed evaluation involves an appropriate comparison of alternatives consistent with the NCP and EPA guidance

III Deliverables and Reporting Requirements

A Deliverables

The City shall gather all necessary field data during the investigation on the C-6 Alignment to fulfill the requirements of the Feasibility Study

21

B Reporting Requirements

All data methods and interpretations must be

1 scientifically and technically sound with all assumptions biases potential deficiencies safety factors and design criteria explicitly stated



4 concisely illustrated and presented in separate graphs charts maps plans andor cross-sections where possible so that the text provides a clear discussion of such illustrations


6 sufficient to satisfy the objectives of the FS listed previously

C Data Requiremerits for Potential Remedial Alternatives and Technologies

Potential Remedial Action objectives shall be identified for each contaminated medium and a preliminary range of remedial action alternatives and associated technologies shall be identified The City shall identify consistent with the NCP arid applicable guidance all potential remedies that may be useful in remediating affected media In discussing potential remedies EPA describes an alternative as a group of technologies including innovative ones that will achieve certain remedial action goals As part of the FS the City shall identify the various technologies showing the critical data needed tp evaluate such technologies and the performance Pf technologies grouped into an alternative As part of the FS the City shall identify all data requirements necessary- to eliminate or to further evaluate retained technologies This identification of technologies and evaluation of data needs shall be presented as an appendix in the FS report

The identification of potential technologies shall help ensure that data needed to evaluate the technologies are collected durinig the property investigation Certain parameters may be common to several possible technologies arid alternatives As an example the following parameters for soils are common chemical comppunds soil density soil moisture soil types soil gradation BTU values total halogens and total organic carbon shy

22

In addition to the common data requirements any other data necessary to evaluate a particular technology or alternative leading to remedy selection shall be noted and integrated Into the property investigation The EPA Guidance on Conducting Remedial Investigations and Feasibility Studies Urider CERCLA (EPA540Gshy89004 OSWER Directive 93553-01 EPA October 1988) and the Technology Screening Guide for Treatment of CERCLA Soils and Sludges (EPA5402-88004 September 1988) shall be sources of additional information ori identifying alternative remedies and potential innovative technologies

A preliminary list of broadly defined alternatives shall be developed by the City Consistent with the NCP this list shall include a range of alternatives in which treatment that significantly reduces the toxicity mobility or volume of waste is a principal element one or more alternatives that involve removal or treatment and a no-action alternative The City shall present a chart showing the data requirements and technologies to be considered for remedial alternatives

SUBSECTION 2 Development and Initial Screeriing of Alternatives

I Objectives - ~ i

The City shall _ develPp an appropriate range of remedial alternatives for the C-6 Alignment in a manner consistent with the National Contingency Plan (NCP) (40 CFR Part 300) the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (OWSER Directive 93553 - 01) and any format or guidance provided by the State or EPA Alternatives for remediation shall be developed by assembling combinations of technologies and the media to which they would be applied intp alternatives that address contamination at the C-6 Alignment

Alternatives shall be developed that

A protect human health and the environment by recycling waste or by eliminating reducing aridor controlling risks to human health and the environment posed through each pathway at the C-6 Alignment ^

B corisider the long-term uncertainties associated with land disposal

C comply with the Applicable or Relevant and Appropriate Requirements (ARARs) of both state and federal laws

D consider the persistence toxicity mobility and propensity to bioaccumulate hazardous substances and their constituents

23

E consider the short- and long-term potential for human exposure

F consider the potential threat to human health and the environment if the remedial alternative was to fail

G corisider the threat to human health and the environment associated with the excavation transportation and redisposal or containment of contaminated substances andor media

II Development of New Remedial Alternatives shy

In developing the remedial alternatives the City shall perform at-a minimum the following activities

A Analysis

1 identification of data needs for all technologies identified

2 development of remedial action objectives specifying the contaminants and media of concern potential exposure pathways and preliminary remedialgoals that are based on chemical specific ARARs risk assessment data and property characterization data

3 development of general response actions for each media of concern defining engineering controls

treatment excavationdredging pumping or other response actions separately andor in combinations

4 evaluation of potential impacts to ambient air and human health as a result of excavation and dredging including an evaluation of engineering controls to

1 mitigate potential impacts

5 identification of volumes or areas of media to which the general response actions shall apply

6 identification and screening pf additional remedial technologies including at a minimum thpse previously identified in the Feasibility Study prepared by Metcalf and Eddy that would be applicable to each response action This task includes a comprehensive research of other Manufactured Gas Plantremediations

7 identification and evaluation of technology process options -

24

8 assembly of the selected technologies into new remedial alternatives representing a range of removal treatment recyclereuse andor containment options I

9 identification and evaluation of appropriate handling treatment and final disposal of all

treatment residuals and

10 an assessment of the need for early action(s)

B Range of Alternatives ^ The City shall develop a range of new remedial alternatives beyond those already developed and evaluated for the Pine Street Site in the Feasibility Study prepared by Metcalf and Eddy including but not limited to the following

The City shall give special consideration to inriovative technologies If any innovative technologies pertinent to the properties can be identified then one or more such technologies shall be evaluated beyond the initial screening

A no-action alternative that involves no long-term maintenance shall be carried through the development arid screening process bdquo

1 For source control actions as apropriate

a A range of remedial alternatives in which treatment that reduces the toxicity mobility or volume of hazardous substances pollutants or contaminants is a principal element As appropriate this range shall include an

alternative that removes or destroys hazardous substances pollutants or contaminants to the maximum extent feasible eliminating or minimizing to the degree possible the need for long-term management The City shall also develop as appropriate other alternatives which at aminimum treat the principal threats posed by the properties but vary in the degree of treatment employed and the quantities and characteristics of the treatment residuals and untreated waste that must be managed In-situ treatmerit options may include but are not limited to soil venting soil sparging soil washing biPfliters and intrinsic or enhanced bioremediation Ex-situ treatment options may include but are not limited to soil venting

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7 bioremediation soil scouring soil n e u t r a l i z a t i o n s o i l w a s h i n g solidificationstabilization recyclereuse via asphalt batching pr co-firing at utility boilers for energy recovery and low temperature thermal desorption should be evaluated

b limited action alternatives that deal with discrete areas of the properties (e^g hot spots) and an evaluation of early actions(s)

c one or more alternatives that involve little pr no treatment but provide protection of human health and the erivironment primarily by preventing pr controlling exposure to hazardous substances pollutants Pr contaminants through engineering controls for example containment source area groundwater control soil vapor cpllectiori and treatment and as necessary institutional controls to prPtect human health and the environment and to assure continued effectiveness of the response action

2 If groundwater response actions are determined to be appropriate by the state and EPA the City shall develop a limited number of new remedial alternatives that attain site-specific remediation levels within different restoration time periods utilizing-one or more different technologies if they offer the potential for comparable or superior performance or implementability fewer or lesser adverse impacts than other available approaches or lower costs for similar levels of performance than

- demonstrated treatment technologies Groundwater treatment technologies may include but are not limited to granular activated carbon adsorption air stripping electrokinetic technologiesneutralizationprecipitation UVchemicaloxidation and iori exchange

III Initial Screening of Alternatives

A Criteria

In the initial screening of alternatives the City shall consider but not be limited to the short- and long-term aspectsof the following three broad criteria

1 Effectiveness

This criterion focuses on the degree to which an alternative reduces toxicity mobility or volume through treatment minimizes residual risks and affords long-term

26 bull shy

protection after the alternative is completed complies with ARARs and minimizes short-term impacts during the construction and implementation period of the alternative It also focuses on how quickly the alternative achieves protection with a minimum of short term impact in comparison to how quickly the protection shall be achieved

2 Implementability

This criterion focuses on the technical feasibility and availability of the technologies that each alternative would employ and the admimistrative feasibility of implementing the alternative

3 Cost

The costs of construction and any long-term costs to operate and maintain the alternatives shall be considered

IV Deliverables

All new remedial alternatives- shall be presented in the Feasibility Study Report If an alternative is to be eliminated it must be screened out for clearly stated reasPns contained in the NCP (40 CFR Part 300) and other EPA guidance

If the City determines that an early action is warranted to address risks posed by the C-6 Alignment the City shall submit a proposal for early action conisitent with the NCP The state and EPA will review and approve such proposal consistent with the terms of the Abe bull - I shy

SUBSECTION 3 Analysis of Alternatives ~

I Objectives

The purpose and objective of this phase is to prepare the Feasibility Study Report for the public record as follows

II Analysis

The detailed analysis of alternatives consists of an assessment of individual alternatives against each of the nine (9) evaluation criteria and a comparative analysis that focuses upon the relative performance of each alternative against those criteria The analysis shall be consistent with the National ContingencyPlan (NCP) (40 CFR Part 300) and shall consider the Guidance for Conducting Remedial Investigations arid Feasibility

27 bull bull

studies under CERCLA (OSWER Directive 93553-01)

The nine criteria are as follows

1 Overall protection of human health and the environment

2 Compliance with ARARs 3 Long term effectiveness and permarience 4 Reduction of toxicity mobility or volume

through treatment 5 Shprt term effectiveness 6 Implementability 7 Cost - 8 State Acceptance 9 Community Acceptance

Criteria one (1) and two (2) from the above list are considered threshold criteria This means that an alternative must meet these two (2) criteria or must contain a statutory basis for waiving compliance with specific ARARs in order for it to be eligible for selection Criteria three (3) through seven (7) on the above list are considered primary balancing criteria These (5)- criteria are used to further evaluate alternatives that satisfy the threshold criteria The final two (2) criteria state acceptance and community acceptance are modifying criteria that shall be considered by EPA in remedy selection

28

p-All data methods and interpretations must be

1 scientifically and technically sound with all assumptions biases potential deficiencies safety factors and design criteria explicitly stated in writing



4 concisely illustrated and presented in separate graphs charts maps plans andor cross-sections where possible sp that the text provides a clear discussion ofsuch illustrations


6 sufficient to satisfy the objectives of the site investigation listed above

III SCHEDULE AND DELIVERABLES

A Schedule

The schedule of work to be performed by the City in conducting this site investigation is outlined in Table 1 below

Table 1 Schedule of Work

ITEMS DELIVERABLE DUE DATE

1 Work Plan Site Investigatipn Thirty days following Preparation on C-6 Alignment effective date of AOC

Workplan

2 Commence Field Notification Letter Ten days after Work from Respondents Approval of Work

Plan

3 Field Work Notif icat ion Let ter 180 days a f te r Completed from Respondents a p p r o v a l o f

Work Plan

Report Investigation 210 days after

^ y ^ Delivered Report approval of ^ ^ Work Plan

I c

B Deliverables







SECTION 2 WORK PLAN

OBJECTIVES











II DELIVERABLES J ^



B Work Plan

















bull


































bull 8





























bull 10




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




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18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28

I c

B Deliverables







SECTION 2 WORK PLAN

OBJECTIVES











II DELIVERABLES J ^



B Work Plan

















bull


































bull 8





























bull 10




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







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II DELIVERABLES J ^



B Work Plan

















bull


































bull 8





























bull 10




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28













bull


































bull 8





























bull 10




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28


































bull 8





























bull 10




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28





























bull 10




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28




























12















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28















13














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28














b publicationand





3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28

3




bull^11 OBJECTIVES









15



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28



Site Survey








bull ^ bull ~ 1 6













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28













17




bull shy











18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28




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18









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28









D Other





1 9 bull ^ bull










1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







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1 Objectives





2 0










A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







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A Deliverables


21












22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







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22




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28




I Objectives - ~ i







23






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28






A Analysis










24


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







28


















A Criteria


1 Effectiveness


26 bull shy


2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







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2 Implementability


3 Cost


IV Deliverables




I Objectives


II Analysis


27 bull bull







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28

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