Microsoft Word - Benning RI-FS Scope of Work, R4 _CIP Format

REMEDIAL INVESTIGATION AND

FEASIBILITY STUDY SCOPE OF WORK

(DRAFT)

BENNING ROAD FACILITY

3400 BENNING ROAD, N.E.

WASHINGTON, DC 20019

PREPARED FOR:

Pepco and Pepco Energy Services

701 9

Street, NW

Washington, DC 20068

PREPARED BY:

AECOM

8320 Guilford Road, Suite L

Columbia, MD 21046

December 2011

REMEDIAL INVESTIGATION AND FEASIBILITY

STUDY SCOPE OF WORK (DRAFT)

Benning Road Facility

3400 Benning Road, N.E.

Washington, DC 20019

________________________________

Prepared By:

Ravi Damera, P.E

Senior Project Manager, AECOM

_________________________________

Prepared By:

Kevin Yue, E.I.T.

Environmental Engineer, AECOM

_________________________________

Reviewed By:

Gary Grinstead, P.G.

Senior Technical Reviewer, AECOM

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RI/FS Scope of Work

Contents

Introduction ................................................................................................................................. 1

TASK 1: Community Relations ............................................................................................ 3

1.1 Development and Implementation of Community Involvement Plan .....................................3

1.2 Support the Administrative Record .........................................................................................3

TASK 2: Scoping and Preparation of Work Plans ............................................................. 4

2.1 Review of Existing Data and Development of Conceptual Site Model ..................................4

2.2 Planning Scope of Inves tigation ..............................................................................................4

2.3 Preparation of Work Plans ......................................................................................................5

2.3.1 RI/FS Work Plan .................................................................................................................5

2.3.2 Sampling and Analysis Plan ...............................................................................................6

2.3.3 Health and Safety Plan .......................................................................................................6

2.4 Regulatory Review and Public Comment ...............................................................................6

TASK 3: Remedial Investigation .......................................................................................... 7

3.1 Field Investigation ....................................................................................................................7

3.1.1 Landside Investigation ........................................................................................................7

3.1.2 Waterside Investigation ......................................................................................................7

3.2 Data Analysis and Management .............................................................................................8

3.3 Exposure Assessment and Risk Analysis ..............................................................................8

3.3.1 Human Health Risk Assessment ........................................................................................8

3.3.2 Ecological Risk Assessment ..............................................................................................9

3.4 Remedial Investigation Report ............................................................................................. 10

3.5 Regulatory Review and Public Comment ............................................................................ 11

TASK 4: Feasibility Study ................................................................................................... 12

4.1 Identification of Remediation Requirements and Establishment of Remedial Objectives . 12

4.2 Development and Screening of Remedial Alternatives ....................................................... 12

4.3 Treatability Studies ............................................................................................................... 13

4.4 Detailed Analysis of Alternatives .......................................................................................... 13

4.5 Feasibility Study Report ....................................................................................................... 13

4.6 Regulatory Review and Public Comment ............................................................................ 14

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List of Tables

Table 1: Sources of Available Information Regarding Site Conditions

List of Figures

Figure 1: Site Location Map

Figure 2: Site Plan and Investigation Locations

Appendices

Appendix A: Community Involvement Plan Outline

Appendix B: RI/FS Work Plan Outline

Appendix C: Sampling and Analysis Plan Outline

Appendix D: Health and Safety Plan Outline

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List of Acronyms

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CIP Community Involvement Plan

COPC Contaminants of Potential Concern

CSM Conceptual Site Model

DDOE District Department of the Environment

DQO Data Quality Objective

ERA Environmental Risk Assessment

FS Feasibility Study

FSP Field Sampling Plan

HASP Health and Safety Plan

HHRA Human Health Risk Assessment

NPS National Park Service

NRDA Natural Resource Damage Assessment

OSHA Occupational Safety and Health Administration

PAH Polycyclic Aromatic Hydrocarbon

PRG Preliminary Remedial Goal

PCB Polychlorinated Biphenyl

QAPP Quality Assurance Project Plan

RAO Remedial Action Objectives

RBSL Risk-Based Screening Level

RI/FS Remedial Investigation/Feasbility Study

SAP Sampling and Analysis Plan

SLHHRA Screening-Level Human Health Risk Assessment

SOW Scope of Work

SVOC Semi-Volatile Organic Compound

USCG United States Coast Guard

USEPA United States Environmental Protection Agency

UST Underground Storage Tank

VOC Volatile Organic Compound

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Introduction

AECOM has prepared this Scope of Work (SOW) on behalf of Potomac Electric Power Company (Pepco) and

Pepco Energy Services, Inc. (collectively “Pepco”) to describe the specific tasks to be undertaken in the

performance of a Remedial Investigation and Feasibility Study (RI/FS) at Pepco’s Benning Road facility (the Site),

located at 3400 Benning Road NE, Washington, D.C. Pepco has agreed to perform the RI/FS pursuant to a

consent decree that was entered by the U.S. District Court for the District of Columbia on December 1, 2011 (the

Consent Decree). The Consent Decree documents an agreement between Pepco and the District of Columbia

(District) which is part of the District’s larger effort to address contamination in and along the lower Anacostia

River.

The 77-acre Site is bordered by a DC Solid Waste Transfer Station to the north, Kenilworth Maintenance Yard

(owned by the National Park Service, NPS) to the northwest, the Anacostia River to the west, Benning Road to

the south and residential areas to the east and south (across Benning Rd.). The general Site location is shown in

Figure 1. A detailed Site map is provided as Figure 2. Most of the Site is comprised of the Benning Service

Center, which involves activities related to construction, operation and maintenance of Pepco’s electric power

transmission and distribution system serving the Washington, D.C., area. The Service Center accommodates

more than 400 Pepco employees responsible for maintenance and construction of Pepco’s electric transmission

and distribution system; system engineering; vehicle fleet maintenance and refueling; and central warehousing for

materials, supplies and equipment. The Site is also the location of the Benning Road Power Plant, which is

scheduled to be shut down in 2012.

The Site is one of several properties along the Anacostia River that are suspected sources of contamination.

There have been five instances since 1985 in which materials containing polychlorinated biphenyls (PCBs) were

released at the Site. In each case, Pepco promptly cleaned up the releases in accordance with applicable legal

requirements. Nonetheless, it is suspected that these releases, and possibly other historical operations or

activities at the Site, may have contributed to contamination in the river. In particular, a site inspection conducted

for the U.S. Environmental Protection Agency (USEPA) in 2008 linked polycyclic aromatic hydrocarbons (PAH),

PCBs, and inorganic constituents detected in Anacostia River sediments to potential historical discharges from

the Site. The site inspection contractor also stated that currently the Site is properly managed and that any spills

or leaks of hazardous substances are quickly addressed and, if necessary, properly remediated.

The purpose of the RI/FS described herein is to (a) characterize environmental conditions at the Site and the

adjacent segment of the Anacostia River, (b) investigate whether and to what extent past or current conditions at

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the Site have caused or contributed to contamination of the river, (c) assess current and potential risk to human

health and environment posed by conditions in the river, and (d) develop and evaluate potential remedial actions.

As described below, the RI/FS will have a “landside” component which will focus on the Site itself, and a

“waterside” component that will focus on the shoreline and sediments in the segment of the river adjacent to and

immediately downstream of the Site. The landside and waterside areas of investigation are depicted in Figure 2.

The areas of investigation may be adjusted or expanded during the course of the RI as warranted based on the

findings of the investigation.

The RI/FS will be overseen by the District of Columbia Department of the Environment (DDOE) and will be

performed in accordance with USEPA’s Guidance for Conducting Remedial Investigations and Feasibility Studies

Under CERCLA, OWSER Directive 9355.3-01, dated October 1988, and other applicable USEPA and DDOE

guidance documents. This Scope of Work describes the specific tasks to be performed as part of the RI/FS. As

provided in the Consent Decree, upon approval of the Scope of Work by DDOE (after consideration of public

comments), Pepco will prepare an RI/FS Work Plan that will describe the specific manner in which the various

RI/FS tasks will be performed, including the specific sampling methodology and the location of sampling points,

and the framework and criteria for analyzing sampling data and evaluating potential remedial options.

DDOE will use the results of the RI/FS to determine whether and to what extent remedial action is warranted and

to select appropriate remedial actions.

This RI/FS SOW consists of the following four specific tasks:

 Task 1 – Community Relations

 Task 2 – Scoping and Preparation of Work Plans

 Task 3 – Remedial Investigation

 Task 4 – Feasibility Study

Each of these tasks is described further in the following sections.

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TASK 1: Community Relations

1.1 Development and Implementation of Community Involvement Plan

Pepco will prepare a Community Involvement Plan (CIP) for review and approval by DDOE. The CIP will identify

issues of potential community concern regarding the ongoing environmental activities being performed in and

around the Site, and will outline community involvement activities to be undertaken. The plan will provide the

framework for communicating information to the public about the RI/FS, and shall incorporate procedures for

ensuring that members of the public are provided the opportunity to review and comment on the following

deliverables for at least 30 days prior to final approval by DDOE: (a) this Scope of Work ; (b) the Community

Involvement Plan; (c) the RI/FS Work Plan; (d) the Conceptual Site Model; (e) the Field Sampling Plan; (f) the

Quality Assurance Project Plan; (g) the Health and Safety Plan; (h) the Remedial Investigation Report, and (i) the

Feasibility Study Report. An outline of the CIP is provided in Appendix A.

1.2 Support the Administrative Record

Pepco will support DDOE’s efforts to compile and maintain the administrative record for the RI/FS work, and to

make the record available to the public. Pepco will provide deliverables required hereunder in the format and

number requested by DDOE for that purpose.

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TASK 2: Scoping and Preparation of Work Plans

Scoping is the initial planning process for the RI/FS and it is continued and refined throughout the RI/FS

project. The RI/FS planning process will include the following activities:

 Review of Existing Data and Development of Conceptual Site Model (CSM)

 Planning the Scope of Investigation

 Preparation of Work Plans

 Regulatory Review and Public Comment

These activities are further described in the following paragraphs.

2.1 Review of Existing Data and Development of Conceptual Site Model

Pepco will gather and analyze existing available data and information regarding past and present

environmental conditions at the Site and in the adjacent segment of the Anacostia River, including results

from previous investigations and sampling events and information regarding handling and disposal of

waste or hazardous substances at the Site. This information will be used to identify additional data needs

and to develop a preliminary range of potential remedial alternatives. A preliminary list of documents to

be analyzed is presented in Table 1. This list will be revised/updated as additional information becomes

available.

Upon completion of data reviews, information on contaminant sources, pathways, and receptors at the

Site will be used to develop a preliminary conceptual understanding of the Site to evaluate potential risks

to human health and the environment. The CSM will include sources of contamination, affected media,

routes of migration, human and environmental receptors and routes of exposure. The CSM is useful in

identifying further sampling needs and potential remedial technologies to mitigate any identified risks. A

preliminary CSM will be included in the RI/FS Work Plan. The CSM will be updated as more data

becomes available through the RI/FS activities.

2.2 Planning Scope of Investigation

The field investigation will be designed to characterize conditions in soil, groundwater, surface water and

sediment, further refine the CSM, and collect data to support risk assessment and Natural Resource

Damage Assessment (NRDA). Specific data gaps identified during the review of existing data will be

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used to guide the scope of the investigation. In general, the investigation will include the following

elements:

 A landside investigation of the Site and select adjacent properties to which access is provided

(e.g., the District Department of Public Works Solid Waste Transfer Station and National Park

Service Kenilworth Maintenance Yard) will address existing soil and groundwater conditions at

the Site, and their effects on the Anacostia River.

 A waterside Investigation will primarily address sediment conditions within approximately 10-15

acre portion of the Anacostia River along 2,500 linear feet of the river, approximately 1,500 linear

feet to the south and 1,000 linear feet to the north of the Site’s main storm water outfall, with the

Benning Road Bridge as the approximate southern boundary of the study area. The proposed

study area is based on its proximity to the Site and recent USEPA sampling results.

 Additional sampling outside of the initially defined study areas will be planned as may be

warranted by the results of initial investigation activties.

 The investigation will focus on PAHs, PCBs, and metals, with limited screening samples for

volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), pesticides, and

dioxins/furans based on knowledge of past operations.

2.3 Preparation of Work Plans

2.3.1 RI/FS Work Plan

Upon completion of the scoping process, Pepco will prepare an overall RI/FS Work Plan for submittal to

DDOE. The Work Plan will describe the overall technical approach for the RI/FS. It will include a

description and analysis of data from previous investigations and remedial actions at the Site and a

description of the preliminary CSM based on information on contaminant sources, pathways and

receptors at the Site. The Work Plan will describe the data gaps to be addressed by the RI and include a

comprehensive description of the work to be performed, the media to be investigated (e.g., air, surface

water, ground water, soil, sediments, etc.), and the methodology to be utilized, and shall describe the

project management approach, communication procedures (including progress reporting to DDOE), and

permit requirements. The Work Plan also will identify each major deliverable and will include a

comprehensive schedule for completion of each major activity. An outline of the Work Plan is included as

Appendix B.

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2.3.2 Sampling and Analysis Plan

A Sampling and Analysis Plan (SAP) will be prepared in conjunction with the RI/FS Work Plan. The SAP

consists of two parts: (a) a Field Sampling Plan (FSP) that provides detailed guidance for all field work by

defining in detail the sampling locations and the sampling and data gathering methods to be used; and (b)

a Quality Assurance Project Plan (QAPP) that describes quality assurance and quality control protocols

necessary to achieve Data Quality Objectives (DQOs) dictated by the intended use of the data. An

outline of the SAP document is provided in Appendix C.

2.3.3 Health and Safety Plan

A Site-specific Health and Safety Plan (HASP) will be prepared in conjunction with the RI/FS Work Plan to

ensure safety of Site workers during the investigation activities for both the landside and waterside

investigations. The HASP will be prepared in accordance with the Occupational Safety and Health

Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (29 CFR

1910.120) and the Construction Industry Standard (29 CFR 1926). The HASP will discuss task-specific

hazard analyses, air monitoring for personnel safety, personal protective equipment recommendations,

Site controls, equipment and personnel decontamination, medical monitoring and training requirements,

and emergency response procedures. With respect to the waterside investigation, the HASP will require

all personnel operating on work boats to be trained for the task at hand and familiar with the United States

Coast Guard (USCG) policies and procedures. All field activities will be conducted in accordance with the

approved HASP. A HASP outline is provided in Appendix D.

2.4 Regulatory Review and Public Comment

The RI/FS Work Plan, SAP and HASP are subject to review and approval by DDOE. DDOE also may

solicit comments from other regional and federal agencies. In addition, DDOE will solicit public comments

on the RI/FS Work Plan, SAP and HASP in accordance with the CIP described above. Pepco will revise

the RI/FS Work Plan, SAP, and HASP, as appropriate to address comments from DDOE, other regulatory

agencies, and the public.

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TASK 3: Remedial Investigation

Pepco will perform a Remedial Investigation (RI) by implementing the SAP and related work plans with

the overall objective characterizing conditions in soil, groundwater, surface water and sediment, and

collecting data to refine the CSM and support risk assessments and Natural Resources Damage

Assessment. Various steps involved in the RI process are described in the following paragraphs.

3.1 Field Investigation

A general description of the technical approach for the RI field investigation is provided below. Additional

technical details will be described in the Work Plan documents.

3.1.1 Landside Investigation

Based on the detailed review of Site history and prior environmental investigations pursuant to Task 2

(Scoping), the landside investigation will include collection and analysis of soil and groundwater samples

at the Site to identify areas that have potential to contribute to surface water or sediment contamination.

The areas to be sampled will include areas where historical PCB spills and cleanups occurred, areas

where petroleum underground storage tanks (USTs) were removed, and current and historical PCB

storage/handling buildings. The sampling effort will proceed in two phases to allow careful review and

consideration of the findings of the initial contaminant delineation phase of work, followed by additional

delineation and optimized risk evaluation. Phase 1 will involve soil borings and Geoprobe sampling to

screen the areas of potential concern and identify any continuing sources of contamination. Phase 2 will

be a detailed hydrogeologic investigation involving the installation and monitoring of groundwater wells

based on the Geoprobe and soil boring data collected in Phase 1. The sampling program will incorporate

a progressive elimination approach that allows the use of screening parameters to screen larger areas to

help focus resources on potential problem areas.

3.1.2 Waterside Investigation

The waterside investigation will be conducted in two primary phases of field work. Data collected during

the first phase of work will be used to refine the scope and nature of work for Phase 2. In general, Phase

1 of the waterside investigation will focus on defining the nature and extent of constituents of potential

concern in sediments adjacent to the Site and selected background locations. Following the evaluation of

Phase 1 findings, Phase 2 will be implemented to refine delineation of chemical data, and add

toxicological, benthic, and geotechnical information from selected portions of the study area. Pepco will

also incorporate a progressive elimination approach into the waterside sampling program. This approach

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allows the use of screening parameters to screen larger areas to help focus resources on potential

problem areas.

3.2 Data Analysis and Management

Pepco will analyze and evaluate data collected during the field investigations to describe (a) the physical

and biological characteristics of the Site that are relevant to contaminant migration and potential receptors,

(b) the contaminant source characteristics, (c) the nature and extent of contamination, and (d) contaminant

fate and transport. The evaluation will include information relevant to characteristics of the Site and the

adjacent segment of the river necessary to the identification and evaluation of potential remedial

alternatives. The information from the Phase 1 data evaluation will be used to identify areas of interest and

significant data gaps, if any. This information will then be used to optimize the selection of Phase 2

sampling locations.

Pepco will consistently document the quality and validity of field and laboratory data compiled during the RI

according to methods to be specified in the relevant work plans. Pepco will develop an analytical database

for laboratory data and field measurements. Appropriate quality control procedures will be developed to

ensure that the data collected during the investigation are of adequate quality and quantity to support the

intended data uses. A representative sample of the collected data (~10-20%) will be validated at the

appropriate field or laboratory quality control level. The data validation reports will be included into the RI

Report appendices.

Data evaluation will include analysis and presentation of all Site investigation data in an organized and

logical manner so that the investigation results for each medium are apparent. The investigation results will

be reduced, compiled, and presented in tabular and graphical forms.

3.3 Exposure Assessment and Risk Analysis

As part of the RI, Pepco will perform Human Health and Ecological Risk Assessments using validated data

obtained during the RI field investigation.

3.3.1 Human Health Risk Assessment

Pepco will conduct a Human Health Risk Assessment (HHRA) in accordance with appropriate USEPA risk

assessment guidance documents. The majority of the Site is covered by impervious paving and/or gravel

and there is no exposure to soils under normal conditions. In addition, the Site is an operating facility with

restricted public access and has health and safety procedures in place to prevent exposure of workers to

any impacted subsurface soils. Accordingly, the risk analysis for the landside will be limited to the

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evaluation of potential risks to the Anacostia River, and related receptors, as a result of contaminant

migration from landside media.

The HHRA will evaluate potential human health effects using the four step paradigm as identified by the

USEPA in the Risk Assessment Guidance for Superfund, Volume I – Human Health Evaluation Manual

(USEPA, 1989). The steps are:

 Data Evaluation and Hazard Identification

 Toxicity Assessment

 Exposure Assessment

 Risk Characterization

Initial data evaluation and hazard identification will be conducted in a screening-level human health risk

assessment (SLHHRA). Based on the results of the SLHHRA, Constituents of Potential Concern (COPC)

and environmental media that warrant further evaluation in the baseline HHRA will be identified. The

SLHHRA will include refinement of the preliminary CSM for human health to identify potential receptors and

potential exposure pathways to environmental media at the Site. Concentrations of chemicals in Site media

will be compared to conservative, risk-based screening levels (RBSLs) determined to be protective of

human health under all exposure scenarios. Based on the outcome of the screening evaluation, the media

and COPCs for evaluation in the baseline HHRA will be identified. The HHRA will be used to evaluate

potential human health risks associated with exposure to environmental media at the Site. The results of

the HHRA will be used to help inform the need for any additional evaluation and/or remedial action at the

Site.

3.3.2 Ecological Risk Assessment

Pepco will conduct an Ecological Risk Assessment (ERA) based on the findings of the waterside field

investigation to evaluate potential ecological risks associated with exposure to environmental media within

or along the Anacostia River adjacent to the Site. The ERA will include the following activities:

 Literature review of previous investigations and assessments of conditions in the Anacostia River

 Identification of potential exposure pathways

 Identification of potentially exposed populations



Screening relative to literature-based ecological risk screening values

 Screening level risk assessments and targeted risk calculations

 Recommendations regarding the need for additional/expanded risk assessment

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The ERA will be conducted according to the general tiered approach and methodology provided by the

USEPA Ecological Risk Assessment Guidance for Superfund (ERAGS): Process for Designing and

Conducting Ecological Risk Assessment, Interim Final (USEPA, 1997), Guidelines for Ecological Risk

Assessment (USEPA, 1998), and The Role of Screening-Level Risk Assessments and Refining

Contaminants of Concern in Baseline Ecological Risk Assessments (USEPA, 2001).

Each successive tier of the ERA process requires more detailed and quantitative data analysis and

interpretation. Conducting assessments in a tiered, step-wise manner maximizes the use of available

information and sampling data, while providing the opportunity to reduce the uncertainties inherent in the

ERA process through the use of focused supplemental data collection to fill key data gaps identified in the

previous tier of the assessment, as necessary.

The results of the ERA will be used to inform the need for any additional evaluation and/or remedial action

at the Site or in the Anacostia River.

3.4 Remedial Investigation Report

Upon completion of field activities and receipt of the analytical data, Pepco will prepare a draft RI Report for

submittal to DDOE. The report will include the following elements:

 Site description

 Site history and previous investigations/remedial actions

 Description of field activities

 Results of field activities to determine physical characteristics (e.g., surface water hydrology,

geology/hydrogeology, ecology, etc.)

 Nature and extent of contamination

 Contaminant fate and transport

 Results of the HHRA and ERA

 Findings and conclusions

 Recommendations

Geologic logs, laboratory data, validation reports, and pertinent field data logs will be included as

attachments.

Pepco will submit a final RI Report following regulatory review.

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3.5 Regulatory Review and Public Comment

The RI Report is subject to review and approval by DDOE. DDOE also may solicit comments from other

regional and federal agencies. In addition, DDOE will solicit public comments on the RI Report in

accordance with the CIP described above. Pepco will revise the RI Report as appropriate to address

comments from DDOE, other regulatory agencies, and the public.

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TASK 4: Feasibility Study

Pepco will conduct a Feasibility Study (FS) based on the results of the RI. The objectives of the FS are to

(a) identify remediation requirements and establish cleanup levels as necessary to eliminate or prevent

unacceptable risks to human health and the environment, and (b) identify, screen and evaluate potential

remedial alternatives. Various steps involved in the FS process are described in the following

paragraphs.

4.1 Identification of Remediation Requirements and Establishment of Remedial Objectives

Pepco will identify areas and volumes of media for which remediation is required either (a) to eliminate or

control conditions in the Anacostia River posing an unacceptable risk to human health and the

environment or (b) to prevent the migration of contaminant from the Site to the river that would cause or

contribute to an unacceptable risk to human health or the environment. All calculations related to area

and volume estimates will be documented in the FS Report. For the areas where a remediation

requirement is identified, Pepco will develop remedial action objectives (RAOs) and preliminary remedial

goals (PRGs) in consultation with DDOE. The PRGs will be developed based on Site-specific risk factors.

The FS Report will describe the rationale for any cleanup levels established.

4.2 Development and Screening of Remedial Alternatives

Remedial alternatives are developed concurrently with the RI phase, with the results of one influencing the

other in an iterative fashion. Pepco will identify and screen a focused set of technologies that have the

potential to achieve the RAOs. This step will follow USEPA presumptive remedy guidance and USEPA’s

Contaminated Sediment Remediation Guidance for Hazardous Waste Sites (2005). Pepco will develop

general response actions (such as containment, treatment, excavation, pumping, institutional controls (e.g.,

deed restrictions), engineering controls (e.g., encapsulation), or other actions, singly or in combination) for

each medium of interest (e.g., soil, sediment, surface water, ground water) to achieve RAOs, and will

identify and evaluate technologies applicable to each general response action to eliminate those that cannot

be implemented at the Site. Consistent with USEPA guidance, the range of remedial options to be

considered will include, at a minimum (a) alternatives in which treatment is used to reduce the toxicity,

mobility or volume of contaminants, (b) alternatives that involve containment with little or no treatment, and

relative cost. Technologies retained after the screening process will be assembled into alternatives for each

remediation area.

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4.3 Treatability Studies

Pepco will perform treatability studies as necessary to assist in the detailed analysis of alternatives.

Treatability studies are generally performed to determine the effectiveness of a technology in achieving

the targeted cleanup levels, to obtain design parameters for a full-scale process, or to screen multiple

process options of a particular technology. Treatability studies are important when technologies have not

been sufficiently demonstrated or characterization data alone is insufficient to predict treatment

performance or to estimate the size and cost of treatment units. Treatability studies can be conducted on

a bench-scale in the laboratory or on a pilot-scale at the Site depending on the study objectives. The

need for treatability studies will be determined once the initial screening of technologies is completed and

sufficient data from the RI are available.

4.4 Detailed Analysis of Alternatives

Pepco will conduct a detailed analysis of the alternatives that have been assembled and retained. This

analysis will consist of an individual evaluation of each alternative against the following evaluation criteria

and a comparative evaluation of all options against the evaluation criteria with respect to one another:

 Overall protection of human health and the environment

 Compliance with applicable regulations

 Long-term effectiveness

 Reduction of toxicity, mobility, or volume through treatment

 Short-term effectiveness

 Implementability

 Cost

 DDOE acceptance



Community acceptance

4.5 Feasibility Study Report

Upon completion of the detailed evaluation of alternatives, Pepco will prepare a draft FS Report for submittal

to DDOE. The report will (a) document the location and extent of media requiring remediation and describe

the associated cleanup levels and RAOs, (b) describe the results of the identification and screening of

alternatives, and the detailed evaluation of alternatives, and (c) identify a preferred alternative for remedial

action.

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Pepco will submit a final FS Report following regulatory review.

4.6 Regulatory Review and Public Comment

The FS Report is subject to review and approval by DDOE. DDOE also may solicit comments from other

regional and federal agencies. In addition, DDOE will solicit public comments on the FS Report in

accordance with the CIP described above. Pepco will revise the FS Report as appropriate to address

comments from DDOE, other regulatory agencies, and the public.

Table

Table 1

Pepco Benning Road Facility

3400 Benning Road, NE

Washington, DC

Sources of Available Information Regarding Site Conditions

Agency for Toxic Substances and Disease Registry (ATSDR). 1991. Health Consultation, Anacostia River Initiative,

Washington, District of Columbia. Accessed at: http://www.atsdr.cdc.gov/hac/pha/pha.asp?docid=1341&pg=0

Anacostia Restoration Potential Workgroup (ARPW). 2009. Annual Report Card.

Anacostia Watershed Toxics Alliance (AWTA). 2009. White Paper on PCB and PAH Contaminated Sediment in the

Anacostia River. DRAFT FINAL. Anacostia Watershed Toxics Alliance. February 23, 2009.

Anacostia Watershed Toxics Alliance (AWTA). Undated. Charting a Course Toward Restoration: A Toxic Chemical

Management Strategy for the Anacostia River.

Behm, P., Buckley, A., and Schultz, Cherie L. 2003. TAM/WASP Toxics Screening Level Model for the Tidal Portion of the

Anacostia River. Final Report. ICPRB. April 2003.

Buchanon, M. 2001. (Draft) Preliminary Contaminated Sediment Management Plan for the Anacostia River. National

Oceanic and Atmospheric Administration, Coastal Protection and Restoration Division, Seattle, WA.

Doelling-Brown, P. 2001. Trophic transfer of PCBs in the food web of the Anacostia River. PhD. Dissertation. George Mason

University.

Hill, S., and P. McLaren. 2000. A Sediment Trend Analysis (STA®) of the Anacostia River. GeoSea Consulting (Canada) Ltd.

Brentwood Bay, British Columbia, Canada, December 2000.

Horne, 2005. Revised Draft Cap Completion Report for Comparative Validation of Innovative “Active Capping” Technologies,

Anacostia River, Washington, DC.

Horne, 2007. Final 30 Month Monitoring Report, Comparative Validation of Innovative “Active Capping” Technologies,

Anacostia River, Washington, DC.

Interstate Comission on the Potomac River Basin (ICPRB). 2007. Total Maximum Daily Loads of Polychlorinated Biphenyls

(PCBs) for Tidal Portions of the Potomac and Anacostia Rivers in the District of Columbia, Maryland, and Virginia. September

28, 2007.

Metropolitan Washington Council of Governments (MWCG). 2007. Anacostia River Watershed: Environmental Condition and

Restoration Overview. DRAFT. March 2007.

National Oceanic and Atmospheric Administration (NOAA). 2000. Interpretive Summary of Existing Data Relevant to

Potential Contaminants of Concern within the Anacostia River Watershed. National Oceanic and Atmospheric Administration.

Coastal Protection and Restoration Division. June, 2000.

Pinkney, A.E., C.A. Dobony and P. Doelling Brown 2001a. Analysis of contaminant concentrations in fish tissue collected from

the waters of the District of Columbia. U.S. Fish and Wildlife Service, Chesapeake Bay Field Office, Annapolis, MD CBFO-

C01-01b

Scatena, F.N. 1987. Sediment Budgets and Delivery in a Suburban Watershed: Anacostia Watershed., Ph.D. Dissertation;

Johns Hopkins University, Baltimore, MD.

Sullivan, M.P. and W.E. Brown, 1988. The tidal Anacostia model-Documentation of the hydrodynamics and water quality

parameters. Prepared for the DC Dept. of Consumer and Reg. Affairs by the Metropolitan Washington Council of

Governments, Washington, DC.

USEPA. 2009. Final Site Inspection Report for the Pepco Benning Road Site, Washington, D.C.

Velinsky, D. and J. Ashley. 2001. Sediment Transport: Additional Chemical Analysis Study, Phase II. Final Report. Report No.

01-30. December 20, 2001.

Velinsky, D.J. and J. Cummins. 1996. Distribution of chemical contaminants in 1993-1995 wild fish species in the District of

Columbia. Interstate Commission on the Potomac River Basin, Rockville, MD.

Velinsky, D.J., G.H. Reidel and G.D. Foster. 1999. Effects of stormwater runoff on the water quality of the tidal Anacostia

River. Academy of Natural Sciences, Philadelphia, PA.

Page 1 of 1

Figures

SITE LOCATION MAP

Benning Road Facility

3400 Benning Road, NE

Washington, DC 20019

Job No. 60189104

Pepco Holdings, Inc.

Remedial

Investigation/Feasbility Study

FIGURE 1

Source: DeLorme 3-D

SCALE: 1:24,000

June 2011

Site

BENNING ROAD NE

FOOTE ST NE

ROOSEVELT PL NE

GRANT PL NE

HAYES ST NE

ANACOSTIA FREEWAY

KENILWORTH

TERRACE NE

BARNES ST NE

ANACOSTIA AVE NE

ANACOSTIA RIVER

BENNING ROAD

FACILITY (PEPCO)

ANACOSTIA RIVER

LANGSTON GOLF COURSE

KINGMAN LAKE

KENILWORTH MAINTENANCE

YARD (NATIONAL PARK SERVICE)

OUTFALL 013

KENILWORTH AQUATIC GARDENS

WASHINGTON, D.C.

MUNICIPAL INCINERATOR (DC)

36TH ST NE

EADS ST NE

34TH ST NE

ANACOSTIA AVE NE

BENNING ROAD

BRIDGE

COLUMBIA, MARYLAND 21046

www.aecom.com

PHONE: (410) 884-9280

FAX: (410) 884-9271

SCALE:

AUGUST 2011AS SHOWN

DATE:

60189104

PROJECT NUMBER:

SHEET NUMBER:

FIGURE NUMBER:

DRAWN BY:

APPROVED BY:

CHECKED BY:

REVISIONS

NO.: DATE: BY:

DESCRIPTION:

WASHINGTON, DC 20019

3400 BENNING ROAD, NE

PEPCO - BENNING FACILITY

8320 GUILFORD ROAD, SUITE L

SITE PLAN AND INVESTIGATION LOCATIONS

PROPOSED INVESTIGATION AREA

BENNING ROAD FACILITY

PROPERTY BOUNDARY

LEGEND:

Appendix A

Community Involvement Plan

Outline

RI/FS Scope of Work A-1



Pepco Benning Road Facility

1.0 Introduction

2.0 Site and Project Background

2.1 Site Description

2.2 Areas and Contaminants of Concern

2.3 Regulatory Status

3.0 Summary of RI/FS Project Activities

3.1 Objectives and Purpose of the RI/FS Project

3.2 Current/Planned Project Activities

4.0 Community Involvement Program

4.1 Community Profile

4.2 Community Organizations

4.3 History of Community Involvement

4.4 Community Concerns

4.5 Community Involvement Plan Action Elements

4.6 Time Frame Summary for Community Involvement Activities

Figures

Figure 1 – Site Location Map

Figure 2 – Site Plan with Study Areas

Figure 3 – Site Vicinity Map

Appendices

Appendix A – Consent Decree and December 1, 2011, Court Order

Appendix B – List of Contacts and Interested Parties

Appendix C – Fact Sheets



The CIP has been prepared following the U.S. Environmental Protection Agency’s Community Involvement Plans

guidance available at http://www.epa.gov/superfund/community/pdfs/7clplans.pdf

Appendix A.

Community Involvement Plan Outline

Appendix B

RI/FS Work Plan Outline

RI/FS Scope of Work

B-1

Pepco Benning Road Facility

1. Introduction

2. Site Background and Setting

2.1. Historical Removal Actions and Investigations

2.2. Geology

2.3. Hydrogeology

2.4. Site Description

2.5. Area Description

3. Conceptual Site Model

4. Work Plan Rationale

4.1. Data Quality Objectives (DQO)

4.2. Work Plan Approach

5. RI/FS Tasks

5.1. Project Planning

5.2. Field Investigation Activities

5.3. Data Validation and Evaluation

5.4. Risk Analysis

5.5. Remedial Investigation Report

5.6. Feasibility Study

6. Project Organization

7. Schedule

8. References

9. Appendices

This outline follows the EPA suggested RI/FS work plan format per Guidance for Conducting Remedial

Investigations and Feasibility Studies under CERCLA, Interim Final, EPA-540-G-89-004, October 1988.

Appendix B.

Remedial Investigation/Feasibility Study Work Plan Outline

Appendix C

Sampling and Analysis

Plan Outline

RI/FS Scope of Work

C-1

Pepco Benning Road Facility

1. Site Background

Field Sampling Plan (FSP)

2. Sampling Objectives

3. Sample Location and Frequency

4. Sample Designation

5. Sampling Equipment and Procedures

6. Sampling Handling and Analysis

7. Field Quality Control

1. Project Description

Quality Assurance Project Plan (QAPP)

2. Project Organization and Responsibilities

3. Quality Assurance Objectives for Measurement

4. Sampling Procedures

5. Sample Custody

6. Calibration Procedures

7. Analytical Procedures

8. Data Reduction, Validation, and Reporting

9. Laboratory Quality Control

This outline follows the EPA suggested RI/FS work plan format per Guidance for Conducting Remedial

Investigations and Feasibility Studies under CERCLA, Interim Final, EPA-540-G-89-004, October 1988.

Appendix C.

Sampling and Analysis Plan Outline

Appendix D

Health and Safety Plan

Outline

RI/FS Scope of Work

D-1

Pepco Benning Road Facility

1. Executive Summary

2. Introduction

3. Site Information and Scope of Work

4. Hazard Assessment

4.1. Physical Hazards

4.2. Biological Hazards

4.3. Ultraviolet Hazards

4.4. Chemical Hazards

4.5. Weather Hazards

4.6. Other Hazards

4.7. Task-Specific Safety, Health, and Environment Procedures

5. SH&E Requirements

5.1. HAZWOPER Qualifications

5.2. Site-Specific Safety Training

5.3. Tailgate Meetings

5.4. Hazard Communication

5.5. Hazardous, Solid, or Municipal Waste

5.6. General Safety Rules

5.7. Stop Work Authority

5.8. Client-Specific Safety Requirements

6. Exposure Monitoring Procedures

6.1. Containment Exposure Hazards

6.1.1. PCBs

6.1.2. Volatile and Semi-Volatile Organic Compounds

6.1.3. Metals

6.1.4. Real-Time Exposure Measurement

6.1.5. Heat and Cold Stress

7. Environmental Program

7.1. Environmental Compliance and Management

8. Personal Protective Equipment

8.1. PPE Doffing and Donning Information

8.2. Decontamination

9. Project Health and Safety Organization

10. Site Control

11. Emergency Response Planning

12. Personnel Acknowledgement

Attachments (Task Hazard Analyses, MSDSs, Spill Reporting Procedures, SOPs)

Figures

Tables

This outline follows the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and

Emergency Response Standard (29 CFR 1910.120) and the Construction Industry Standard (29 CFR 1926).

Appendix D.

Health and Safety Plan Table of Contents Outline