NCD980729602_19910226_Jadco-Hughes_FRBCERCLA RD_Scope of Work - Remedial Design Remedial Action-OCR

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SCOPE OF WORK
REMEDIAL DESIGN/REMEDIAL ACTION
Jadco-Hughes Site
Gaston County, North Carolina
FEBRUARY 1991
REF. NO. 3669 (2) CONESTOGA-ROVERS & ASSOCIATES
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CRA CONESTOGA-ROVERS & ASSOCIATES LIMITED
651 Colby Drive,
Consulting Engineers Watertoo, Ontario, Canada N2V 1C2
[phone]
February 26, 1991
Ms. Barbara H. Benoy
Superfund Project Office
United States Environmental Protection Agency
Region IV
Air and Waste Management Division
345 Courtland Street
Atlanta, Georgia 30365
Dear Ms. Benoy:
Re: Preliminary Draft -Scope of Work (SOW)
Tadeo-Hughes Site (Site), Gaston County, NC
Reference No. 3669
Please find enclosed three (3) copies of the preliminary draft SOW for the Site. This
draft is submitted on behalf of the Jadco-Hughes steering committee to assist in
negotiations related to the Consent Decree for the Remedial Design/Remedial
Action at the Site.
The draft has been prepared based on the USEPA's SOW which was transmitted to
Potentially Responsible Parties attached to the December 21, 1990 Special Notice
letters. Proposed additions to the SOW are underlined and proposed deletions are
crossed out.
In the interest of accelerating the negotiation process, we have submitted this
preliminary draft before all Figures have been completed. We will complete the
Figures this week and forward them to you under separate cover.
We look forward to discussing the preliminary draft SOW with you at your offices
on March 8, 1991. In the interim, if you have any questions, please call our office.
Yours truly,
OVERS & ASSOCIATES
~e~~en~M7(. ~~s;~-=--
SMQ/cz
Encl.
c.c. Reuben Bussey, USEPA Region IV
Rick Leahy, USEP A Region IV
Jill Hickey, NC Dept. of Justice (3 copies)
Jadco-Hughes steering committee
Jimmy Kirkland, King & Spalding
Richard Shepherd, CRA
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION ...................................................................................................... 1
1.1 PURPOSE ......................................................................................................... 1
1.2 SCOPE ............................................................................................................... 3
2.0 DESCRIPTION OF THE REMEDIAL ACTION TO BE CONDUCTED
BY THE STEERING COMMITTEE ........................................................................ .4
2.1 SUMMARY OF REMEDIAL ACTION WORK TASKS ......................... 4
2.2 ACCESS AND DEED RESTRICTIONS ...................................................... 12
3.0 PILOT STUDY -SOIL REMEDIATION OBJECTIVES ......................................... 13
4.0 SOIL TREATMENT ................................................................................................... 14
5.0 GROUNDWATER EXTRACTION, PRETREATMENT
AND DISCHARGE .................................................................................................... 16
5.1 GENERAL. ....................................................................................................... 16
5.2 EXTRACTION, PRETREATMENT AND DISCHARGE
SYSTEM COMPONENTS ............................................................................. 16
5.2.1 Extraction Wells ............................................................................................. 16
5.2.2 Pump Chamber and Discharge Piping ...................................................... 17
5.2.3 Discharge to POTW ....................................................................................... 17
5.3 GROUNDWATER TREATMENT OBJECTIVES .................................... 17
6.0 GROUNDWATER PRETREATMENT SYSTEM ................................................ 19
7.0 REPAIR AND SLIP-LINING OF CULVERT ........................................................ 20
8.0 SPRING DISCHARGE LINE .................................................................................... 21
9.0 SITE SPILLWAY ......................................................................................................... 22
I 10.0 OPERATION AND MAINTENANCE .................................................................. 23
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11.0 PERFORMANCE MONITORING PROGRAM ................................................... 24
11.1 GENERAL ........................................................................................................ 24
11.2 GROUNDWATER MONITORING PROGRAM .................................... 25
11.2.1 Hydraulic Monitoring ................................................................................... 25
11.2.2 Chemical Monitoring ................................................................................... 26
11.2.3 Data Evaluation and Reporting .................................................................. 29
11.3 SOIL VAPOR EXTRACTION/FLUSHING MONITORING ................. 30
11.3.1 Vacuum Monitoring ..................................................................................... 30
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TABLE OF CONTENTS
11.3.2 Hydraulic Monitoring ................................................................................... 31
11.3.3 Chemical Monitoring ................................................................................... 31
11.3.4 Data Evaluation .............................................................................................. 32
11.4 DATA REPORTING ...................................................................................... 32
12.0 REMEDIAL CONTINGENCY PLAN ..................................................................... 34
13.0 REMEDIAL DESIGN ................................................................................................. 36
13.1 GENERAL. ....................................................................................................... 36
-h13.2 RD WORK PLAN .......................................................................................... 37
~ 13.3 HEAL TH AND SAFETY PLAN ................................................................. .40
~13.4 SAMPLING AND ANALYSIS PLAN ...................................................... .40
4.13.5 TREATABILITY STUDY WORK PLAN ................................................... 42
B,13.6 PRELIMINARY DESIGN REPORTING ................................................ .43
13.6.1 Fifty Percent Design Stage ............................................................................ 44
9'13.6.2 Prefinal/Final Design .............................................................................. 49
14.0 REMEDIAL ACTION ................................................................................................ 51
14.1 GENERAL. ....................................................................................................... 51
-hl4.2 RA WORK PLAN .......................................................................................... 52
~14.3 CONSTRUCTION MANAGEMENT PLAN ............................................ 54
~14.4 CONSTRUCTION QUALITY ASSURANCE PLAN .............................. 54
4.14.5 CONSTRUCTION HEALTH AND SAFETY
PLAN/CONTINGENCY PLAN .................................................................. 56
B,14.6 PRECONSTRUCTION CONFERENCE .................................................. 60
G.14.7 PREFINAL INSPECTION .......................................................................... 61
9'14.8 FINAL INSPECTION ................................................................................. 62
E,14.9 REMEDIAL ACTION REPORT ................................................................... 63
15.0 TASK IV -OPERATION AND MAINTENANCE .............................................. 65
15.1 GENERAL. ....................................................................................................... 65
A.15.2 OPERATION AND MAINTENANCE PLAN ...................................... 65
B,16.0 FIVE YEAR REVIEW .................................................................................... 70
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I FIGURE 4.1
FIGURE 5.1
I FIGURE 5.2
I FIGURE 5.3
FIGURE 5.4
I FIGURE 6.1
I FIGURE 7.1
FIGURE 7.2
I FIGURE 11.1
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LIST OF FIGURES
EXCAVATION AND INCINERATION LAYOUT
GROUNDWATER EXTRACTION SYSTEM
SITE GEOLOGY
TYPICAL EXTRACTION WELL INSTALLATION
TYPICAL mE TRENCH
AERATION PRETREATMENT SYSTEM
CUL VERT PLAN AND SECTION
SLIP LINING OF CUL VERT
MONITORING LOCATIONS
Following
Page
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TABLE 3.1
TABLE 5.1
TABLE 11.1
LIST OF TABLES
SOIL CLEANUP REMEDIATION GOALS
GROUNDWATER REMEDIATION GOALS
MONITORING PROGRAM
Following
Page
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1.0 INTRODUCTION
1.1 PURPOSE
The purpose of this Remedial Design/Remedial Action
(RD/RA) at the Tadeo-Hughes Site (Site) is to design, construct, operate and
maintain, monitor and complete the selected remedy to ensure protection of
human health and the environment. Remedial Design (RD) is generally
defined as those activities to be uRdertakeR by the SettliRg DefeRdaRts to
develop the final plans and specifications, general provisions and special
requirements necessary to translate the Record of Decision (ROD) into the
remedy to be constructed under the Remedial Action (RA) phase. RA is
generally the implementation phase of site remediation or actual
construction of the remedy, including necessary operation and maintenance,
and performance monitoring. The RA is based on the RD to achieve the
remediation goals specified in the ROD. A group of Potentially Responsible
Parties (hereinafter referred to as the steering committee) have expressed a
desire to conduct the RD/RA program. This Scope of Work (SOW) is
designed to provide a framework for conducting the RD/RA activities at this
Site and is the "technical" portion of this Consent Decree. This SOW
provides for a number of detailed documents which shall be used to guide
each component of the RD/RA process at this Site.
The SettliRg DefeRdaRts shall eoRduet aR RD/RA The
steering committee shall implement an RD/RA that is in accordance with
this SOW and consistent with the Reeord of DeeisioR (ROD} issued on
September 27, 1990, the Consent Decree, the approved RD/RA Work Plan and
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the Superfund Remedial Design and Remedial Action Guidance (EPA Office
of Solid Waste and Emergency Response Directive 9355.0-4A, June 1986) (the
"RD/RA Guidance"), and other guidanee used by EPA in eondueting an
RD/RA (a list of the primary guidanees is attaehed), as well as any additional
requirements in this Consent Deeree. The Settling Defendants steering
committee shall furnish all necessary personnel, materials, and services
needed, or incidental to, performing and completing the RD/RA, including
necessary operation and maintenance, and performance monitoring.
The SOW includes a summary and description of the
remedial work tasks to be completed by the steering committee as part of the
description of the tasks for the RD and RA. a summary of all deliverables is
presented.
EPA shall provide oversight of the Settling Defendants'
steering committee's activities throughout the RD/RA. The Settling
Defendants steering committee shall support EPA's initiation and conduct of
activities related to the implementation of oversight activities. However, the
responsibility for conducting an adequate RD/RA to satisfactorily implement
the selected remedy shall lie with the Settling Defendants steering committee.
EPA review and approval of deliverances is a tool to assist this process and to
satisfy, in part, EPA's responsibility to provide effective protection of public
health, welfare, and the environment. EPA approyal of a task or deliverable
shall not be eonstrued as a guarantee as to the ultimate adequaey of sueh task
or deliverable. A summary of the major deliverances that Settling
Defendants shall submit for the RD/RA is attaehed.
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1.2 SCOPE
The preferred remedial action identified by the EPA in the
ROD and remedial actions described herein by the steering committee satisfy
the following statutory requirements:
i)
ii)
iii)
iv)
protection of human health and the environment:
meet applicable or relevant and appropriate requirements:
cost effectiveness: and
utilization of permanent solutions for hazardous substances to the
maximum extent possible.
The final remedial action, with proper operation and
maintenance, should permanently reduce the mobility of Site contamination,
through a combination of treatment, engineering and institutional controls.
Any existing or potential risks associated with direct contact with
contaminated subsurface soil or migration of contaminants through the
shallow groundwater will be mitigated. The technologies to be implemented
as part of the RA are proven and the necessary construction labor, equipment
and materials are readily available in the Belmont, North Carolina area.
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2.0 DESCRIPTION OF THE REMEDIAL ACTION TO BE CONDUCTED
BY THE STEERING COMMITTEE
The steering committee shall implement and operate the
remedy described in the ROD. The steering committee shall design.
implement and maintain the remedial action so as to achieve the standards
and specifications of the major components set forth in Sections 3.0 through
12.0.
2.1 SUMMARY OF REMEDIAL ACTION WORK TASKS
The work tasks listed below have been developed based
on the EPA approved Feasibility Study (FS) and the ROD and are based on
current conditions at the Site. These work tasks will be included as part of the
final RA at the Site.
The work tasks to be completed by the steering committee
under the RA include:
i)
ii)
Provision of deed and access restrictions.
Completion of a pilot study to demonstrate the effectiveness of soil
vapor extraction and soil flushing technologies for treating the
contaminated soils in the landfill. The final soil action levels for
volatile organic compounds (VOCs) and base. neutral and acid
extractable compounds (BNAs) will be established based on treatability
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limitations demonstrated by this pilot study and supported by
Site-specific data.
iii) Based on the results of the pilot study completed in (ii}, treatment of
soils in the landfill and approximately 500 cubic yards of soil from the
Former Operations Area which are to be consolidated into the landfill.
The soils shall be treated by a combination of soil vapor extraction and
soil flushing.
iv) Construction of a groundwater extraction system including extraction
wells, tile collection trench, pumps, pipelines and electrical controls to
hydraulically contain the groundwater contaminant plume.
v) Construction of a groundwater pretreatment plant, to pretreat the
extracted groundwater prior to being discharged to the Belmont
publicly owned treatment works (POTW).
vi) Excavation and repair of the damaged sections of the Site culvert
followed by slip-lining of the culvert with polyethylene.
vii) Construction of a gravity drainage line to carry uncontaminated
groundwater from the spring discharge to the Tributary B north of the
Former Operations Area.
viii) Construction of a Site spillway to protect the soils and the treatment
system in the landfill from 100 year flooding.
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ix)
x)
xi)
Provision of long-term operation and maintenance for the constructed
remedial components.
Implementation of a long-term groundwater monitoring program to
allow confirmation of the effectiveness of the constructed remedial
components and to allow determination of the need for additional
measures or corrective actions. if any.
Development of criteria for implementing contingency actions.
Removal and off-Site disposal of polychlorinated biphenyl
(PCB) contaminated surface soils in the southeast corner of the Site and the
construction of an eight-foot high chain link fence with three strands of
barbed wire around the perimeter of the Site were completed by the steering
committee in 1990 under an Administrative Order on Consent with the EPA
dated August 16, 1990.
Each of the above components are described in
Sections 3.0 through 12.0 of this SOW. Work tasks and schedules specific to
the RD/RA are described in Sections 14.0 and 15.0, respectively.
TASK 1 SCOPING
Scoping is the initial planning process of the RD/R,<\ and
has been initiated by EPA through this document to determine how the
site specific remediation goals as specified in the ROD will be met. The
specific project scope shall be planned by the Settling Defendants and EPA.
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pe in an RD . f' c project seo . ent the speeH
a fl ts shall aoeum ... flature of the h Settling Defen a • of the unlmo,. n
T < I B,ra_ 'R"
R • 'Nork p an. hout the RDr". "'ork Plan anti an '". . . ee iaentifiea throug
N .,;,efflffi~ -ffl6<ffl·-S. te aaaitional aata req II emit a technical me .
' ' I •Mt.,l,a ~ • Oat, s The Settling De en I g with the propose
pre~, . • "' ,..;...., """ • -. "'""""'· IR ••Y • aflY nee . ts are 1 aoeumenting. ueh reqmremen
. (DQOs) whenever s , 11 · aaaitional aata Quality Objeeti¥es nsiele for fulfi mg
event, t .e EP • consistent wi f dants are respo I ope anti h Settling De~n. . ····th the genera se
. els iaentifiea ey H lA7 anti analysis nee . luaing this SO, •.
oejeetives of the Consent Decree, me
s·t ha"e eeen h s 1 e • • . for the Jaaeo Hug e The Site Oejeetives f n to ee the
•• . laele informa io ' . ·1 • easea on as, a1 . a prelimman y, aetermme
following:
1.
ReYiew of emstmg . . 'Feasieility Stuliyr ' a. I Investigation, h ROD the Reme ia . t e , .
latea information. other reports or re
. . to the Site. This ineluaes tion pertammg a . informa (RI , FS) an
2. unaerstana hea references) to . (eeattae . l1 I ·ant gmaanees a . performing t.e R ··ie.,.,. of re e\ . h II ee use in
e" This information s .a
h RD 'R ". process. a r this SOW. t e rs.. . es un e . all aeliYerane RD/RA anti prepanng
This ineluaes aaaitional . . I aata, as required. Further Collection of aaa1t1ona . rveys, moaelling, etc.
I · stigatlons, su · e . eoteehniea mve ary to aetermm sampling, g t plume will ee neeess
f the grounawa er . for fue delineation ° !Is Soil sampling ·
tt .,. -~ .. 0 •
eer anti locations for eictrae ~·-efficients ·.viii ee eonauete num . . .1 partition eo f site spee1fle s01 development
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4.
5.
6.
7.
8.
9.
ta geReFate a eemp · ants ···eFe
f ail eeRtamm. " . f eleaRup geals ~f s ThiFteeR ta -speeHe
hensi··e list ef sail eleaRup geals. lete aRd eempFe, •
ideRtified ifl the ROD.
FeFfeFmaRee ef beRe . aR , d • ta e·•aluate aRd h d 'eF pilet TFeatability Stu ies~
d . the seleeted remedy. prnpeFly es1gR.
eeifieatieRs Reeessary ta d ·1 d desigR plaRs aRd sp J2Feparatl:efl ef eta1 e
enstFuet the seleeted remedy. e,
. iReludiRg e0Rstrueti0R . f the seleeted remedy' " etual implemeRtaheR e d .
" . !em eRt the seleeted reme Y. ef faeilities Reeessary ta imp,
· plemeRt the . f the faeilities Reeessary ta lffl Operatiefl aRd mamteF1aF1ce e
selected remedy, as required.
d . ta eRsuFe all . . ef the selected Feme }
FerformaRce memtenRg . . I as specified iR the
These remediatiefl gea s, FemediatieR geals are met
ROD, aFe as follews:
ERsurmg a t These ARARs, as
( ii R ii Rs) are me • apprnpriate requiFemeRts, '" '
lieable er relevaRt aRd . th t all Federal aRd State app
. . • 11 ROD are as follews: spec1fwd m he '
• · \., ater A.et JA' ter ii ct 'Safe DrmkmgY • Cleafl na ,, ,
. S bsta11 ces CeRtrnl Act
TmE1eu ' . . · "et
. d Health Admm1strati0R '. Federal OecupatieRal Safety aR
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Resource CoRseryatioR aRd Reco•1ery Act
EffiueRt GuideliRes aRd StaRdards, 40 CPR 400 Subchapter N
NatioRal PollutioR Discharge ElimiRatioR System
~forth CaroliRa SuperfuRd Act
~forth CaroliRa GrouRdwater RegulatioRs/North CaroliRa Water
Quality StaRdard
DuriRg aRd upoR developmeRt of the Remedial DesigR,
further review of aRy ARARs applicable iR the maRagemeRt of residual
wastes will be ideRtified and complied with, i.e. sludge, carbon filters, etc.
WheR scopiRg the specific aspects of the project, the
1 • !SEUSS a proiect planmng SettliRg DefeRdaRts must meet with the EPA to d' 11 · ·
decisioRs aRd special coRcerRs associated 'Nith the Site. The followiRg
activities shall be performed by the SettliRg DefoRdaRts as a fuRction of the
project scopiRg process.
A :t ,. SITE I!ACI<;GROUND
The SettliRg DefeRdaRts shall gather aRd aRalyze the eJcistiRg
iRformatioR regardiRg the Site aRd shall coRduct a 'lisit to the Site to
assist iR plaRRiRg the scope of the RD/RA as follows:
Collect aRd ARalyze EJcistiRg Data and DocumeRt the Ne d f " . " dd · · 1 e -0r 1 ,Hr 1 , ltiORa Data
I!efore plaRRiRg RD/RA acti•1ities, all eJdstiRg Site data shall be
thoroughly compiled aRd reviewed by the SettliRg DefendaRts.
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B.
2.
, r , and other Speeifically, this shall include the ROD RI 'FS
· is m ormat10n shall be available data related to the Site Th. . f .
a a 1s needed for utilized in determining if any additional d t .
RD/R.<\ implementation. Deeisions on the necessary data and
Data Quality Objectives (DQOs) shall be made by EPA.
Conduct Site Visit
The Settling Defe d n ants shall conduct a ··isit to th 5· ' e 1te ···1th th
EPA R . " e ' ,emed1al Project Manager (RPM) d . h . . · urmg t e project
scopmg phase to assist in de··eloping a c I • onceptua
' , " ' requirements for the Site. understanding of the RD iR" .
Information gathered during this visit shall be ti!. d u 1ze to better
scope the project and to determine the extent of additional data
necessary to implement the RD/AA.
PROJECT PL<\."iNING
The Settling Defe d Ii n ants s ,all meet the EP " d. . . . ' ' regar mg the following
act1 .. 1ties d b f r ane ore proceeding ···ith T I II .v as, .
Refine the Site Objectives
"'ll n,enever necessary th 5 r ,eett mg Defendants shall r f h . . e~nete
Site Objectines A • , • d . • . ',ny re ,1se Site Objecti··es shall b d . ~ e ocumented
m a technical mem d ran um to be preparea by Settling
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2.
3.
Defenelants anel are subject te EPA appreyal prier te preceeeling
'Nith Task II.
Document the Neeel fer Treataeility Stuelies
Treatability Stuelies shall be cenelucteel by the Settling Defenelants
te insure that the selecteel remeely will attain all applicable er
relevant anel appropriate requirements (ARARs) as well as any
ether treatment requirements eutlineel in the ROD. Treatability
Stuelies shall be requireel ei1cept where the Settling Defenelants
can elemenstrate te EPA's satisfaction that they are net neeeleel.
The stuely results anel operating cenelitiens shall be useel in the
eletaileel elesign ef the selecteel remeely. 'A'here Treatability
Stuelies are neeeleel, Treatability Stuely acti¥ities shall be planneel
te eccur concurrently with aelelitienal elata cellectien acti¥ities
(see Task II).
Evaluate Treatability Stuelies
'A'here Treatability Stuelies are requireel, the Respenelents shall
prepese aF.el EPA shall appre¥e the type ef Treatability Stuelies te
be useel (e.g. bench yersus.pilet yersus bench anel pilet). The
elecisien te perform pilet testing shall be maele as early in the
precess as possible te minimize potential elelays.
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2.2 ACCESS AND DEED RESTRICTIONS
Access restrictions include regulation of the Site land use
by zoning, by restrictive covenants in the deed, and by fencing the Site.
Future land use at the Site will be restricted to prevent
on-Site development or other activities that might compromise protective
measures or interfere with long-term Site monitoring.
The purpose of deed notifications is to record a note on a
deed or some other instrument examined during a title search that would
notify any potential purchaser that the land had been used for waste disposal
and that land use is restricted. Deed restrictions will prevent disturbance of
the landfill cover and control future property use.
An eight-foot high chain link fence, with three strands of
barbed wire along the top of its entire length was installed along the entire
perimeter of the Site by the steering committee in 1990.
Off-Site groundwater withdrawal restrictions will be
implemented as appropriate to prevent any adverse impact to the proposed
extraction well system. Adjacent property owners immediately north of the
Site would be required to utilize existing connections to municipal water
supply and discontinue use of private groundwater wells for any purpose.
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3.0 PILOT STUDY -SOIL REMEDIATION OBJECTIVES
The soil remediation objectives for VOCs and BNAs will
be established based on a best available technology demonstration. The best
available technology demonstration will demonstrate treatment limitations
for the soil vapor extraction and soil flushing technologies through a pilot
study. This demonstration will include evaluating specific performance
records from other sites. The pilot study shall be completed through the
installation of one soil vapor extraction/soil flushing well in the landfill,
operation of the well over an approximate 60-day period with periodic
sampling and analysis of soils in the immediate area of the well. The scope of
the treatability study will be submitted to the EPA in a Treatability Study
Work Plan.
Thirteen specific remediation goals for soil contaminants
were identified in the ROD. These remediation goals are presented in
Table 3.1.
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Chemical
arsenic a
barium
cadmium
carbon tetrachloride
chloroform
chromium a
TABLE3.1
SOIL CLE." .. ~UP REMEDIATION GOALS
JADCO-HUGHES SUPERFUND SITE
Cleanup Remediation Goal
48.0
360.0
6.0
3.689
15.865
140.0
1,2-dichlorobenzene a 1.5
lead a +:-3--3.2
mercury a 0.15
PCBs -l{W-25.0
selenium 4.6
silver a 0.6
vinyl chloride 0.014
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
The above identified soil cleanup goals are developed for the protection of the
groundwater and are designed to ultimately eliminate any leachability from soil
contamination that would exceed the established groundwater cleanup goals.
a -based on the established background soil concentration as established by the
RI.
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4.0 SOIL TREATMENT
Approximately 500 cubic yards of soils from the Former
Operations Area will be consolidated with the soils in the landfill and treated
for voe and BNA contamination by soil vapor extraction and soil flushing.
The location of the soils from the Former Operations Area and the landfill
are shown on Figure 4.1.
The number of soil vapor extraction wells to be placed in
the consolidated soils and the technology utilized for treatment of the
extracted vapors will be based on the results of the Soil Vapor Extraction Pilot
Study (Section 3.0).
The soil vapor extraction system will be constructed and
operated by the steering committee until data from the operation of the
system indicate that no further voes can practicably be collected, whereupon
the steering committee shall install six soil borings at locations in the landfill
mutually agreeable between the steering committee and the EPA and collect
soil samples at two-foot intervals to the surface of the water table for voe
analyses. The soil vapor extraction system will be considered completed if the
laboratory composite of the collected samples exhibits VOC concentrations at
or below the remediation criteria established through the Pilot Study
(Section 3.0)
Following completion of soil vapor extraction, soil
flushing will commence, if required. and proceed until data from the analyses
of water collected from the slushing system demonstrate that no further
14
-- --
366~-26/02/91-2-0
-·--
-----PROPERTY LINE
SfDIMEN T SAMPl£
-
---uo GROUND CONTOUR (FT. AMSl)
SURfACE WATER OR.4.INAGE
--
-------~-.otr -----..... _.., _____ ~•
,.---
' ' ' ' :=
--·-- - - ---
a 50 100ft
"" Ill
figure 4.1
EXCAVATION AND INCINERATION LAYOUT
JADCO-HUGHES SITE
Gaston County. NC
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organic species can practicably be collected, whereupon the steering
committee shall install six soil borings at locations in the landfill mutally
agreeable between the steering committee and EPA and collect soil samples at
two-foot intervals to the surface of the water table for BNA analyses. The soil
flushing system will be considered completed if the laboratory composite of
the collected samples exhibits BNA concentrations at or below the
remediation criteria established through the Pilot Study (Section 3.0).
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5.0 GROUNDWATER EXTRACTION. PRETREATMENT
AND DISCHARGE
5.1 GENERAL
A tile collection trench and extraction well system will be
constructed to achieve hydraulic containment within the shallow aquifer to
prevent further off-Site migration of contaminated groundwater. The
locations of the extraction system components have been established in the
FS and will be confirmed during RD using piezometric data and known
aquifer characteristics.
5.2 EXTRACTION. PRETREATMENT AND DISCHARGE
SYSTEM COMPONENTS
Based on the design development in the FS for the
extraction, pretreatment and discharge of groundwater, 800 feet of tile
collection trench, four deep extraction wells and an aeration system are
required. Figure 5.1 presents the location of the extraction and pretreatment
system. Figure 5.2 presents a hydrogeologic cross-section in the vicinity of the
proposed extraction system.
5.2.1 Extraction Wells
The extraction wells will be installed to typical depths of
25 and 65 feet within the upper aquifer and screened over the interval 20 feet
16
---
,,. ___ , .,, __ _
,,.
CHA
36e9-26 02/91-2-0
l!!!l!!9
WiElll1
------PROPERTY UNE
GROUHO cantJUR en. AMSL)
---PERF. COLLECTION SYSTEM
FOACEMAIN
a""c MANHCl.£ CUL ~T
iiiiii ----
0
""
----
50 100ft
-
... ... .. ,
""
... .., .., ...
.t
figure 5. 1
GROUNDWATER EXTRACTION SYSTEM
JADCO-HUGHES SITE
Gaston County, NC
-- - - ---
680.0
670.0
660.0 ----·--------
i fil 650.0
ii ~ 84'>0
630.0
620.0
!!11!!!1 iliil --
l'M,.m.T (W,)aT
CONCRETE CUL VERT/
SAPROLITE UNIT
- -
.... ,
-
..._,
-.w,tsr.r
A'
610.0_L~--------~--------~-------~r-------------,---------.---------,
0
CRA
3&a9-21J/02/91-2-0
JOO
.JJ;lillill.
=r-
GROUND SURFACE
~ STRATIGRAPHIC DESCRIPTION
na.4 STATIC WATER Ln£l. (11/18/89)
MONITORING WB..l. SCREEN LOCA 110N
900 1200
HORIZONTAL DISTANCE (FEEl)
1500
1800
figure 5.2
Sil£ GEOLOGY
JADCO-HUGHES Sil£
Goston County. NC
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to 30 feet and 60 feet to 70 feet respectively. below ground surface. Figure 5.3
presents a typical extraction well installation.
5.2.2 Pump Chamber and Discharge Piping
A pump chamber will be installed at each extraction well
to house the mechanical and electrical components (i.e. flow meter. flow
control valves. telemetry and electrical power connections).
Extracted groundwater from each well will be directed to a
gravity collection header and will be delivered to the pretreatment system
(Section 6.0).
5.2.3 Discharge to POTW
The steering committee shall construct a discharge
pipeline to the City of Belmont pumping station shown on Figure 5.4. The
design of the pipeline shall be completed in a manner acceptable to the City of
Belmont and the EPA.
5.3 GROUNDWATER TREATMENT OBJECTIVES
The steering committee shall operate the extraction and
pretreatment system until the concentrations of contaminants in the
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c;:::=::;J------CAP
~--CONCRETE SURFACE SEAL
GROUND SURFACE
_____________ I:::=:!!---~-STAN_D_ING_W_AlER_LEVEL_ ---------------
CRA
3689-26 02 91-'-2-0
' ' ' '-
y> --~;ING WAlER LEVEL
/
1=3-------6"11 STAINLESS S1EEL
SLOTTED WEU. SCREEN
-+------TAIL PIECE
lO HOUSE PUMP
figure 5.3
TYPICAL EXTRACTION
WELL INSTALLATION
JADCO -HUGHES SITE
Gaston County, NC
GROUND ELEV~.~------r---------7
-------
CRA
3669-26 02 91-2-0
COMPACTED
NATIVE
BACKFILL
--------
. sz..:..------
' \
GRAVEL
' I PERFORA lED 6" •
CORRUGATED H.O.P.E. \
WITH SOCK · . I ~------
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GEO-TEXTILE
FILTER ...
figure 5.4 ' .
TYPICAL TILE TRENCH
JADCO -HUGHES SllE
Gaston Coun fy. NC
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combined influent from the tile collection trench at the downgradient
property limit are below the remediation objectives listed in Table 5.1 for four
consecutive monitoring events.
If the level of any contaminant exceeds the level set forth
in Table 5.1 (based on a statistical evaluation to determine if there is a
statistically significant exceedance) during any subsequent monitoring event,
then the extraction and pretreatment system shall be operated until the
remediation objectives listed in Table 5.1 are met for four consecutive
monitoring events.
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Page 1 of 2
TABLE 5.1
GROUNDWATER REMEDIATION GOALS FOR THE
JADCO-HUGHES SITE
Chemical
Organics
acetone
benzene
2-butanone
carbon tetrachloride
chlorobenzene
chloroethane
chloroform
1, 1-dichloroethane
1,2-dichloroethane
1, 1-dichloroethylene
1,2-dichloroethylene (Total)
1,2-dichloropropane
eth y 1 benzene
2-hexanone
methylene chloride
4-methyl-2-pentanone
tetrachloroeth ylene
toluene
1, 1, 1-trichloroethane
1, 1,2-trichloroethane
trichloroeth ylene
vinyl chloride
xylene
benzoic acid
bis(2-chloroethyl)ether
bis(2-ethylhexyl)phthalate
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
di-n-butyl phthalate
phenol
1,2,4-trichlorobenzene
CleaHup Remediation Goal
(µg!L)
7Gfl
-12
m
°'32
300100
-HJ
0,-1-9100 (a)
0,3
°'32
7
70
!h§62
29700
-HJ
5
3S(J
°'72
-l;-0002,000
200
32
2'82
Ml-§£
40010,000
28,000
0,-03
4
620600
620
-b-875
7Gfl
~
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Page 2 of 2
TABLE 5.1
GROUNDWATER REMEDIATION GOALS FOR THE
JADCO-HUGHES SITE
Chemical
Organics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Iron
Lead
Manganese
Nickel
Vanadium
Zinc
Notes:
Cleanup Remediation Goal
(µg!L)
§0
3JQ
50
1,000
1
§10
50
300
-l--§50
-l-§0
-l-§0100
~
5,000
(a) Total Trihalomethane (the sum of bromodichloromethane,
dibromochloromethane, bromoform and chloroform).
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6.0 GROUNDWATER PRETREATMENT SYSTEM
The extracted groundwater shall be pretreated prior to
discharge to the Belmont POTW by aeration of the groundwater in a 10-foot
diameter by 15-foot high aeration tank. The exhaust air from the aeration
tank shall be passed through a granular activated carbon (GAC) column to
remove organic contaminants. The steering committee shall use a method
acceptable to the EPA for the disposal of.any spent GAC so as to minimize the
release of contaminants to the air. Figure 6.1 presents a schematic
cross-section of the treatment system.
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- - - - ---!!I!! == == =a liiiiil -liiii iili - ---
--
Aeration Tank
1 O' Diameter
15' Height
E xtracted . .
G roundwater I I I I I I I.
CRA
3669-26 /02/91::... 2.:.o
/ ......,
'-~
Blower
Treated Air
•
Tr eated
. ------
Activated Gro undwater
. Carbon
Adsorption
Unit
figure 6.1
AERATION PRETREATMENT SYSTEM
JADCO-HUGHES SITE
Gaston County, NC
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7.0 REPAIR AND SLIP-LINING OF CULVERT
The existing damaged Site culvert shall be excavated at the
approximate location shown on Figure 7.1 to expose the damaged section for
repair. The repaired culvert shall be backfilled and slip-lined with 30-inch
inside diameter butt-welded polyethylene pipe, as shown on Figure 7.2. The
annulus between the concrete culvert arid the polyethylene pipe at the
culvert inlet and outlet shall be plugged to prevent the discharge of
groundwater to surface water.
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36 .. EXISTING
CONCRETE CUL VERT
MANHOLE
CROSS SECTION
DETAIL
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MH SUMP
Jo"· HOPE PIPE
35•· EXISTING
CONCRETE CULVERT
JO .. HOPE PIPE
PLUG
. . ·. : .... ' .... , ...... · .
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35•· EXISTING
CONCRETE CULVERT
30"" HDPE PIPE
CRA
36611-26 D2 91-2-0
fig1Jre 7.2
SUP LINING OF CUL VERT
JADCO-HUGES SITE
Gaston County, NC
- ---
TRIBUTARY 'B'
~·
66' 666 __ _
666
CRA
3669-26 02/91-2-0
-
67
66
J <n " < 66
>-w r 65
z 0
0
5
0
5
i= 650 L.....'.>,_ NVERT EL[VATION ~ w J w
1----653.07
6'5
6<o 0 50
!II! i::= iiii1 liiil - -
~
Y BANIS_ __ -, .;
·fh L
-7 0 20 50ft
~
6"111 CONCRETE CULVER-T ------------------~ ~· ~-+t,t;:· r---
ANK
- ---
·-
co 1 APcc-n 1"'111
200 250 300 350
DISTANCE (FEET)
1
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400
-----PROPERTY UN[
--
INVER
EL£VA
T
TION
0 649.6
450
---~ GROUND COtHOUR (FT. AMSl.)
SPLL•H i;t'UWAl -·-J\~---="-" ___ r\_
cu.,u,10
TYPICAL SPILLWAY
CROSS-SECTION
N. T.S.
figure 7.1
CULVERT PLAN AND SECTION
JADCO-HUGHES SITE
Gaston County. N.C.
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8.0 SPRING DISCHARGE LINE
A gravity discharge pipe shall be constructed from the
outlet of the spring adjacent to the Site to Tributary B north of the Former
Operations Area. The approximate routing of the pipe is shown on
Figure 5.1.
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9.0 SITE SPILLWAY
A Site spillway will be constructed in the locations shown
on Figure 7.1 to prevent 100 year floods from inundating the landfill area. A
plan/profile of the spillway is presented on Figure 7.2.
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10.0 OPERATION AND MAINTENANCE
Long-term operatio~ and maintenance of the
implemented remedial components will consist of the following:
i)
ii)
iii)
operation and maintenance of pumping equipment to ensure
continued effectiveness of the proposed groundwater extraction system
in containing, collecting and extracting contaminated groundwater
from the Site to prevent off-Site migration of contaminated
groundwater;
operation and maintenance of aeration equipment to ensure continued
effectiveness of the aeration system in removing volatile contaminants
from groundwater to meet the Belmont POTW discharge criteria; and
maintenance of the Site security fence and maintenance of the Site
vegetative cover by fertilizing. grass cutting and erosion control.
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11.0 PERFORMANCE MONITORING PROGRAM
11.1 GENERAL
A performance monitoring program will be established
and maintained during operation of and for 15 years after the termination of
groundwater extraction at the Site. The objective of this monitoring program
shall be to provide data for:
i)
ii)
iii)
iv)
v)
vil
the demonstration of hydraulic containment and collection of
Site-related contaminated groundwater within the surface aquifer;
the demonstration that pretreatment standards for extracted
groundwater are met prior to discharge to the POTW;
the demonstration of the reduction of the concentrations of Site-related
contaminants in groundwater on Site within the surface aquifer to
concentrations specified by the associated cleanup standards;
the demonstration of treatment of collected soil vapor prior to
atmospheric discharge:
the demonstration of the reduction of the concentrations of
contaminants in soil at the Site: and
monitoring for evidence of releases to the environment of hazardous
substances or contaminants from the Site.
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The evaluation of data collected will determine whether
the remedial system is performing to its design criteria. The data will be used
to determine if the contingency measures (Section 12.0) require
implementation.
The data also shall be used to determine when the
operation of the soil vapor extraction/soil flushing and the groundwater
extraction system may cease.
11.2 GROUNDWATER MONITORING PROGRAM
Groundwater monitoring has the following components:
• hydraulic monitoring;
• sample collection and analyses; and
• data evaluation.
11.2.1 Hydraulic Monitoring
Initially, water level measurements will be made on a
quarterly basis from existing and proposed monitoring wells and piezometers
as shown in Table 11. 1. A total of five (5) new monitoring wells and six (6)
piezometers are proposed to augment the existing well network as shown on
Figure 11.1. These data will be used to define the potentiometric surface of
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I TABLE 11.1
MONITORING PROGRAM
I JADCO-HUGHES RI/FS
Parameters/Frequency
I voes BNAs Metals
A Plume Monitoring Wells
I MW2S Q2/A A A
MW2D Q2/A A A
I MW3S Q2/A A A
MWSS QS/A A A
MWSD QS/A A A
MW6S Q2/A A A
m MW7S Q2/A A A
MW8S Q2/A A A
0 B Sentry Monitoring System
MW3D Q2/A • •
MWSDD (Proposed) QS/A • •
D MW6D QS/A • •
MW9S QS/A • •
MW10D Q2/A • •
D MW12S QS/A • •
MW12D QS/A • •
MW145 (Proposed) QS/A • •
MW14D (Proposed) QS/A • •
I MW15S (Proposed) QS/A • •
MW15D (Proposed) QS/A • •
S59 Q2/A • •
D 5S14 Q2/A • •
5515 Q2/A • •
C Extraction System
I PWl Q2/A A A
PW2 (Proposed) Q2/A A A
I PW3 (Proposed) Q2/A A A
PW4 (Proposed) Q2/A A A
Treatment Plant Influent Q2/A A A
I
Notes:
E Q2(.A sam12le guarterly for two years, annually thereafter.
QS(.A sam12le guarterly for five years, annually thereafter.
• sample 7 of 14 stations each year I voes volatile organic compounds
BNAs base/neutral and acid extractable compounds
Metals lead, cadmium, chromium, nickel and arsenic
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------~
------
CRA
... .,.
... ...
3869-26 02 91-2-0
--- - -
~
------PROPERTY UNE
GROUND CQfTOUR (Fl". AMS..) ----PERF. COLLECTION SYSTEM
FORCEMAIN
■ MW3S PLUME M0NJ!~R1HG WELLS
.6. ss 9 SENTRY MONITORING SYSTEM
@PW2 EXTRACTION SYSTEM e PZ PROPOSED ~EZOMETER
OMHC MANHOt.E CUL'v£RT
---liliil .. liiili
~
0 50 100•
iiiil
... ... -...
•• ••
""
S514.,,_ 125• 1206 ~.~ ~
figure 11.1
MONITORING LOCATIONS
JAOCO-HUGHES SITE
Gaston County. NC
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the surface aquifer and hence plot groundwater contours in response to
pumping.
After the first five years of hydraulic monitoring, water
level measurements will be reduced to semi-annually if it can be
demonstrated that the system has been effectively containing the
contaminated groundwater plume.
Constructed potentiometric contours plans will be
prepared for each monitoring event and submitted to EPA in an annual
report.
11.2.2 Chemical Monitoring
Groundwater samples will be collected from the plume
monitoring system, the sentry system and the extraction and pretreatment
system (Table 11.1).
Plume monitoring involves the determination of
groundwater quality within areas of known groundwater contamination.
These data are used to monitor the progress of remediation and the
redistribution of contamination within the aquifer in response to pumping.
Sentry monitoring involves the determination of
groundwater quality downgradient and below the contaminant plume.
Should groundwater contamination migrate vertically downward or
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northward against the influence of the groundwater extraction system,
contamination would be detected in the sentry well system.
Extraction and pretreatment monitoring involves the
determination of groundwater quality from the collection drain, extraction
wells, combined influent to the pretreatment system and effluent from the
pretreatment system. These data are used to monitor the progress of
remediation and pretreatment operations.
Sampling frequency by location is provided in Table 11. 1.
The monitoring program involves more frequent sampling in the first
two years to assist in optimizing the operation of groundwater extraction and
pretreatment. The frequency of monitoring is annual for long-term
monitoring given the slow rate of groundwater movement of 8 to
14 feet/year.
Parameter groups for analysis are as follows:
• VOCs, as listed in the Target Compound List (TCL),
• BNAs listed on the TCL, and
• selected metals (nickel, lead, chromium, cadmium and arsenic).
The groundwater extraction system will be operated to
reduce groundwater contaminant concentrations at the downgradient
property limit to the groundwater remediation objectives as presented in
Table 5.1.
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If the appropriate remediation objectives standards are
met at any individual well for three consecutive sampling events, and if
attainment is expected to continue, then sampling frequency for the particular
extraction well will be increased to quarterly for one year. If cleanup
standards are confirmed to be met by these data. operation of the extraction
well will be terminated.
After groundwater extraction is terminated pursuant to
the provisions of Section 5.3, groundwater monitoring will be conducted for
the plume and sentry monitoring wells identified in Table 11.1. The
frequency of sampling will be semi-annually for the first two years following
system shutdown and annually for years three to five following shutdown.
Samples will be analyzed for the TCL. If compliance with cleanup standards
is confirmed through the five-year post-termination groundwater
monitoring. the monitoring frequency will be decreased to every fifth year up
to 15 years, with analyses for the TCL.
If at any point in the five-year post-termination
groundwater monitoring program data indicate noncompliance with the
appropriate cleanup standards, an additional sampling event will be
conducted. If analytical data indicate that cleanup standards have been
exceeded in one or more wells. all or a portion of the groundwater extraction
system will be reactivated and operated until the cleanup standards are
obtained. Monitoring events then will be conducted in the sequence
described above. beginning with the quarterly sampling events, for the
appropriate monitoring wells.
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11.2.3 Data Evaluation and Reporting
The hydraulic data collected as part of the hydraulic
monitoring program will be reduced to elevations and entered into a
computer database. Groundwater elevations will be contoured for the surface
aquifer on Site plans; and the capture zones will be delineated. The capture
zones will demonstrate the hydraulic performance of the groundwater
extraction system.
Upon receipt of analytical results, data validation will be
undertaken to determine if the data are acceptable for use in the groundwater
quality monitoring program. If the data are deemed to be acceptable, all data,
including Quality Assurance/Quality Control (QA/QC) data, will be entered
into a computer database. The computer database will provide the required
listing and summary tables of analyses. including a separate listing of selected
QA/QC data. The summarized data will be used to determine the
groundwater quality in the extraction wells, and any reduction in
contaminant concentrations.
All monitoring data will be reported to the EPA in an
annual report.
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11.3 SOIL VAPOR EXTRACTION/FLUSHING MONITORING
Soil vapor extraction/flushing monitoring has the
following components:
• vacuum monitoring;
• hydraulic monitoring;
• chemical monitoring; and
• data evaluation.
11.3.1 Vacuum Monitoring
Initially, pressure measurements will be taken on a
monthly basis at each vapor extraction wellhead and accompanying
piezometers. These data will be used to confirm conditions of vacuum over
the surface of the landfill.
After one (1) year of operation, measurements may be
reduced to quarterly if conditions are steady-state and if agreed to by the EPA .
Pressure contours will be prepared for each monitoring
event and submitted to EPA in an annual report.
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11.3.2 Hydraulic Monitoring
If the soil flushing system is constructed, flow rate and
water level measurements will be made on a monthly basis at each recharge
wellhead. In addition, monthly water level measurements will be made at all
accompanying piezometers. These data will be used to confirm conditions of
recharge over the surface area of the landfill.
After one (1) year of operation, measurements may be
reduced to quarterly if conditions are relatively steady-state and if agreed to by
EPA.
Constructed water level contour plans will be prepared for
each sampling event and submitted to EPA in an annual report.
11.3.3 Chemical Monitoring
Initially during soil vapor extraction system operations,
total organic vapor measurements will be made monthly at each extraction
wellhead. the combined inlet to the vapor phase treatment unit and the
outlet from the vapor phase treatment unit. These data will be used to
confirm the effectiveness of the vapor extraction and the vapor phase
treatment and to provide an indication of the requirement to replace
/regenerate the treatment equipment.
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After one (1) year of operation, measurements may be
reduced to quarterly if conditions are relatively steady-state and if agreed to by
EPA.
11.3.4 Data Evaluation
The vacuum pressure measurements and hydraulic data
collected as part of the program will be entered into a computer database.
Pressure contour maps and groundwater contours will be prepared with
appropriate area of influence zones delineated. These maps will demonstrate
the extraction and flushing performance of the system.
Analytical data will be entered into a computer database.
The computer database will provide required listings and summary tables.
These data will be used to determine the progress of soil vapor extraction and
soil flushing.
11.4 DATA REPORTING
An evaluation report on the effectiveness of the
monitoring program will be submitted annually to the EPA. This evaluation
report will include:
i) analytical results and appropriate OA/OC data;
ii) hydraulic monitoring data;
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iii)
iv)
v)
a description of the Site system maintenance activities and
encountered problems that required corrective action;
an evaluation of the effectiveness of the groundwater extraction
system, including Tables and Figures generated; and
recommendations for program revisions, if appropriate.
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12.0 REMEDIAL CONTINGENCY PLAN
Performance monitoring will provide an indication of the
effectiveness of the soil vapor extraction and treatment/flushing system as
well as the groundwater extraction system. with respect to cleanup standards
and requirements. If the system(s) is not performing as designed or required.
considering the time required to substantially attain steady-state conditions.
contingency actions shall be required.
The criteria for implementation of contingency action(s)
with respect to the hydraulic containment system shall be as follows:
i)
ii)
if hydraulic containment. collection and extraction of groundwater in
the shallow aquifer is not achieved for the Site-related groundwater
contamination; and/or
if contaminated groundwater in the shallow aquifer increase with time
and such increase is attributable to the Site.
The criteria for implementation of contingency action(s)
with respect to the soil vapor extraction/flushing system shall be as follows:
i)
ii)
if vapor extraction (influence) cannot be demonstrated to be occurring
over the majority of the landfill;
if it is determined that VOC removal is impeded during vapor
extraction by air entry through the surface of the landfill; and
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iii) if soil flushing cannot be demonstrated to be occurring over the
majority of the landfill.
The contingency actions that shall be undertaken if any or
all of the above criteria are met shall include one or more of the following:
i)
ii)
iii)
an increase or decrease of pumping rates, if possible, in the extraction
wells: and/or
the installation of additional groundwater extraction or soil vapor
extraction/soil flushing wells; and/or
the regrading of the soil colver over the landfill.
Contingency plans will be developed for other appropriate
components of the remedial action.
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13.0 REMEDIAL DESIGN
TASK H RE:MEDIAL DESIGN
13.1 GENERAL
Remedial Design (RD) shall be performed to support the
response actions selected in the ROD. The RD shall provide the technical
details for implementation of the Remedial Actiefl RA in accordance with
standard professional engineering and construction practices. The design
shall iRclude clear af\d cempreheRsive desigR plaRs af\d specificatiefls.
A l 1. REMEDIAL DESIGN PLA ... "'tNJJltG
At the ceRclusien ef the project plaRRiRg phase, the
SettliRg DefeRdaRts As part of the RD, and within 90 calendar days of the
effective date of the Consent Decree, the steering committee shall submit the
following to the EPA:
-RD Work Plan;
-Sampling and Analysis Plan;
-Health and Safety Plan; and
-Treatability Study Work Plan.
The RD Work Plan, Sampling and Analysis Plan, and
Treatability Study Work Plan -must will be reviewed and approved and the
Health and Safety Plan reviewed by EPA prior to the initiation of field
activities.
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Upen appreval ef the RD 1Nerk Plan, the Settling
Defenaants shall implement the RD J;l/erk Plan in aeeeraanee with the
BPA apprevea aesign management seheaule eentaiRea therein. Su.eh
implementation shall ineluae EPA review anti/or appro,,al ef plans,
speeifieatiens, submittals anti ether aeli,.,erables. The purpese ef these aesign
reviews is fer BPA te assess the feasibility of the aesigR to aehieve the Site
Objeetives in aeeoraanee with the ROD anti Censent Deeree, induaing this
SQJN. Review anti/er appro,,al ef aesign submittals enly allews the Settling
Defenaants te proeeea te the ReiEt step ef the aesigR preeess. It aees Rot imply
aeeeptaRee ef later aesigR submittals that have Rat been re,,iewea, ner that
the remeay, when eenstruetea, will meet performaRee stanaaras anti be
aeeeptea.
-1-,13.2 RD WORK PLAN
A 'Nark Plan aeeumeRting the aeeisioRs anti evaluatieRs
eempletea au.ring the seeping preeess shall be submittea te EPA fer reviev,
anti appreYal. The Work Plan shall include a comprehensive description of
the additional data collection and evaluation activities to be performed, if
any, and the plans and specifications to be prepared. A comprehensive design
management schedule for completion of each major activity and submission
of each deliverable shall also be included. The Work Plan shall be developed
in conjunction with the Health and Safety Plan, the Sampling and Analysis
Plan, and the Treatability Study Work Plan, although each plan may be
delivered under separate cover.
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Specifically, the Work Plan shall present the following:
a. A statement of the problem(s) and potential problem(s) posed by the
Site and how the objectives of the RD/RA will address the problem(s).
b. A background summary setting forth the following:
1) A brief description of the Site including the geographic location,
and a description of the physiographic, hydrologic, geologic,
demographic, ecological, cultural and natural resource features
of the Site;
2) A brief synopsis of the history of the Site including a summary
of past disposal practices and a description of previous responses
that have been conducted by local, State, Federal or private
parties at the Site;
3) A summary of the existing data in terms of physical and
chemical characteristics of the contaminants identified and their
distribution among the environmental media at the Site.
c. A brief list and detailed description of the tasks to be performed,
information needed for each task, information to be produced during
and at the conclusion of each task, and a description of the work
products that shall be submitted to EPA. This includes the deliverances
set forth in the remainder of Task II and Task IIIA Sections 13.0 and
14.0.
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d.
e.
f.
A schedule with specific dates for completion of each required activity
and submission of each deliverable required by this Consent Decree,
including those in this SOW. This schedule shall also include
information regarding timing, initiation and completion of all critical
path milestones for each activity and/or deliverable.
A project management plan, including a data management plan,
monthly reports to EPA, and meetings and presentations to EPA at the
conclusion of each major phase of the RD/RA. The data management
plan shall address the requirements for project management systems,
including tracking, storing, and retrieving the data along with
identifying software to be used, minimum data requirements, data
format and backup data management. The plan shall address both data
management and document control for all activities conducted during
the RD/RA.
A description of the community relations support activities to be
conducted during the RD. At EPA's request, it is expected that the
Settling Defendants steering committee will assist EPA in preparing
and disseminating information to the public regarding the RD work to
be performed.
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~13.3 HEALTH AND SAFETY PLAN
A Health and Safety Plan shall be prepared in
conformance with the SeHliRg DefeRdaRts steering committee's health and
safety program, and in compliance with OSHA regulations and protocols.
The Health and Safety Plan shall include a health aRd safety risk aRalysis, a
description of monitoring and personal protective equipment, medical
monitoring, and site control for future construction and testing work. -Nete
fftilt The EPA does not "approve" the SettliRg DefeRdaRts' steering
committee's Health and Safety Plan, but rather the EPA reviews it to ensure
that all necessary elements are included, and that the plan provides for the
protection of human health and the environment.
J,13.4 SAMPLING AND ANALYSIS PLAN
The SettliRg DefeRdaRts steering committee shall prepare
a Sampling and Analysis Plan (SAP) to ensure that sample collection and
analytical activities are conducted in accordance with technically acceptable
protocols and that the data generated will meet the DQOs established. The
SAP shall consist of a Field Sampling and Analysis Plan (FSAP) and a Quality
Assurance Project Plan (QAPP).
The FSAP shall define in detail the sampling and
data-gathering methods that shall be used on the project. It shall include
sampling objectives, sample location (horizontal and vertical) and frequency,
sampling equipment and procedures, and sample handling and analysis. The
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Field Sampling and Analysis Plan shall be written so that a field sampling
team unfamiliar with the site would be able to gather the samples and field
information required. The QAPP shall describe the project objectives and
organization, functional activities, and quality assurance and quality control
(QA/Q!:.) protocols that shall be used to achieve the desired DQOs. The DQOs
shall, at a minimum, reflect use of analytical methods for identifying
contamination and addressing contamination consistent with the levels for
remedial action objectives identified in the National Contingency Plan. In
addition, the QAPP shall address personnel qualifications, sampling
procedures, sample custody, analytical procedures, and data reduction,
validation, and reporting. These procedures must be consistent with the
Region IV Engineering Support Branch Standard Operating Procedures and
Quality Assurance Manual.
The SettliRg DefeI1daI1ts steering committee shall
demonstrate, in advance and to EPA's satisfaction, that each laboratory it may
use is qualified to conduct the proposed work. This includes use of methods
and analytical protocols for the chemicals of concern in the media of interest
within detection and quantification limits consistent with both QA/QC
procedures and DQOs approved by EPA in the QAPP for the Site. The
laboratory must have and follow an approved QA program. The SettliRg
DefoI1daI1ts steering committee shall provide assurances that EPA has access
to laboratory personnel, equipment and records for sample collection,
transportation, and analysis. The Settliilg DefoI1daI1ts steering committee
shall submit detailed information to demonstrate that the laboratory is
qualified to conduct the work, including information on personnel
qualifications, equipment and material specifications. In addition, EPA may
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require submittal of data paelEages equi¥alent to those generated in the EPA
Contraet Laboratory Program (CLP) and may require laboratory aI1alysis of
performanee samples (blank and/or spilEe samples) in suffieient number of
determine the eapabilities of the laboratory upon reasonable request by EPA,
such laboratories shall perform analyses of samples provided by EPA to
demonstrate the quality of each laboratory's analytical data. If a laboratory not
in the CLP is selected, methods consistent with CLP methods that would be
used at this Site for the purposes proposed and QA/QC procedures approved
by EPA shall be used. In addition, if the laboratory is not in the CLP program,
a laboratory QA program must be submitted for EPA re¥iev1 and appro¥al.
4'13.5 TREATABILITY STUDY WORK PLAN
The Settling Defendants ~teering committee shall prepare
a Treatability Study Work Plan for EPA review and approval. This Plan shall
describe the remedial teehnology to be tested, test objectives, experimental
procedures, treatability conditions to be tested, measurements of performance,
analytical methods, data management and analysis, health and safety, and
residual waste management for the soil vapor extraction/soil flushing
technologies. The DQOs for the Treatability Study shall be documented as
well. If a pilot seale Treatability Study is to be performed, The Treatability
Study Work Plan shall also describe pilot plant installation and start-up, pilot
plant operation and maintenance procedures, and operating conditions to be
tested. If testing is to be performed off site, permitting requirements must be
addressed. A schedule for performing the Treatability Studies shall be
included with specific dates for·the tasks, including, but not limited to, the
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procurement of contractors and the completion of sample collection,
performance sample analysis, and report preparation.
6.
Treatability Srudy Sampling and Analysis Plan
If tile SAP is not adettaate for defining the activities to be
performed dliring the Treatability Stlidy, a separate Treatability
Stlidy SAP shall be prepared by the Settling Defendants fer EPA
reYiew and appro•;al. It shall be designed to monitor pilot plant
performance.
Treatability Srudy Health and Safety Plan
If tile Health and Safety Plan is not adeqliate for defining the
actiYities to be performed dliring the Treatability Stlidy, a
separate Treatability Srudy Health and Safety Plan shall be
developed by the Settling Defendants. Note that EPA does not
"approve" the Settling Defendants' Treatability Stlidy Health
and Safety Plan, biit rather BPA reYiews it to enslire that all
necessary elements are incllided, and that the plan pro•,ides fer
the protection of h!iman health and the enyironment.
PRELIMINARY DESIGN REPORTING
The RD will be performed in two stages. The Stage I
design will include the design of remedial components for which existing
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data and preliminary additional data in support of the remedial design are
available. The Stage II design will include the design of remedial components
for which additional data in support of the RD are required.
13.6.1 Fifty Percent Design Stage
Prelimi11.ary Fifty percent design begins with initial design
and ends with the completion of approximately 3G SO percent of the design
effort. At this stage. the Settli11.g Defo11.da11.ts steering committee shall have
field verified, as necessary, the existing conditions of the Site. The
Prelimi11.ary SO percent design shall reflect a level of effort such that the
technical requirements of the project have been addressed and outlined so
that they may be reviewed to determine if the final design will provide an
operable and usable remedial project. Supporting data and documentation
shall be provided with the design documents defining the functional aspects
of the project to prove that the completed project will be effective in meeting
the remediation goals and ARARs. EPA approval of the Prelimi11.ary
SO percent design is required before proceeding with further design work,
unless specifically authorized by EPA. The Prelimi11.ary SO percent design
shall include -the preliminary results of additional data acquisition activities,
if required, a Treatability Study Evaluation Report, a Design Criteria Report,
preliminary plans and specifications, a Project Delivery Strategy, and a Plan
for Satisfying Permitting Requirements. In accordance with the design
management schedule established in the approved Remedial Design Work
Plan, the Settli11.g Defe11.da11.ts Gteering committee shall submit to EPA the
Prelimi11.ary SO percent design submittal which shall consist of the following:
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1.
2.
Results of Data Acquisition Activities
Data gathered during the projeet planning phase shall be eompiled,
summarized, and submitted along with an analysis of the impaet of the
results on design aetivities. In addition, _2urveys conducted to establish
topography, rights-of-way, easements, and utility lines shall be
documented. Utility requirements and acquisition of access, through
purchases or easements, that are necessary to implement the RA shall
also be discussed.
Design Criteria Report
The concepts supporting the technical aspects of the design shall be
defined in detail and presented in this report. Specifically, the Design
Criteria Report shall include the preliminary design assumptions and
parameters, including:
a. Waste characterization;
b. Pretreatment requirements;
c. Volume of each media requiring treatment;
d. Treatment schemes (including all media and by-products);
e. Input/ output rates;
f. Influent and effluent qualities;
g. Materials and equipment;
h. Performance standards; and
i. Long-term performance monitoring requirements,
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3.
4.
Preliminai:y Plans and Specifications
The Settling Defonaanls steering committee shall submit an outline of
the required drawings, including preliminary sketches and layouts,
describing conceptual aspects of the design, unit processes, etc. In
addition, an outline of the required specifications, including
performance standards, ARARs, etc., shall be submitted. The initiation
of the construction drawings shall reflect organization and clarify. The
scope of the technical specifications shall be outlined in a manner
reflecting the final specifications.
Plan for Satisfying Permitting Requirements
The final design plans and specifications must be consistent with the
technical requirements of all applicable or relevant and appropriate
requirements unless a waiver has been issued. Any off-site disposal
shall be in compliance with the policies stated in the Procedure for
Planning and Implementing Off-Site Response Actions (Federal
Register, Volume 50, Number 215, November, 1985, pages 45933-45937)
and other applicable guidances. The plan shall identify the off-site
disposal/discharge permits that are required, the time required to
process the permit applications, and a schedule for submittal of the
permit applications.
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5.
C.
Treatability Study Evaluation Report
Following completion of the Treatability Studxies, the Settling
Defendants steering committee shall analyze and interpret the testing
results in a technical report to EPA. Depending on the sequence of
activities, Ihis report may will be submitted with the Pfeliminafy
50 percent design Of as a separnte delivernble, as appm';ed in the RD
\I\Jofk Plan. The report shall evaluate the treatment technology's
effectiveness, implementability, cost, and actual results as compared
with predicted results. The report shall also evaluate full-scale
application of the technology, including a sensitivity analysis
identifying the key parameters affecting full-scale operation.
ll'lTI:ID.4EDIATI: DESIGN
The Intefmediate Design ends 'Nith the completion of appmximately
6Q pefcent of the design effort. The Settling Defendants shall submit to
EPA the Intefmediate Design submittal 'Nhich shall consist of a
continuation and expansion of the Preliminary Design submittal as
may be modified by any value engineefing fecommendations adopted
by Settling Defendants. Any ,,alue engineefing fecommendations
adopted by Settling Defendants shall be summafized in a feport
submitted with the Intermediate Design. EPA revie'.v comments on
the Intefmediate Design shall be reflected in the Prefinal / Pinal Design.
The Intefmediate Design submittal shall be submitted in accordance
'Nith the appFoved design management schedule and shall consist of
the following:
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1.
2:.
Draft Design Analysis
The e¥aluation conducted to select the design approach shall be
desCFibed. Design calculations shall be included.
Draft Plans and Specifications
Draft construction drawings and specifications for all
components of the Remedial Action shall be prepared and
presented. Plans and specifications shall conform to acceptable
standards of good practice and shall be formatted in accordance
with the requirements of the Construction Specification
Institute.
Draft Construction Schedule
The Settling Defendants shall de¥elop a Draft Construction
Schedule for construction and implementation of the remedial
action which identifies timing for initiation and completion of
all critical path tasks. The Settling Defendants shall specifically
identify dates for completion of the project and major
milestones.
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t),13.6.2 Prefinal/Final Design
The Settling Defondants steering committee shall submit
the Prefinal Design when the work is approximately 9() 95 percent complete -iR
accordance with the appro¥ed design management schedule within 90 days of
receipt of the EP A's coments on the 50 percent design. The Prefinal Design
shall have addressed comments generated from the IHtermediate 50 percent
Ddesign -R[eview and clearly show any modification of the design as a result
of incorporation of the comments. The Prefinal Design shall function as the
draft version of the Final Design. After EPA revievi' and comment on the
Prefinal Design, the Final Design shall be submitted. The EPA shall provide
comments within 30 days of their receipt of the Prefinal Design. Within
60 days of receiving the EP A's comments on the Prefinal Design submission,
the revisions will be incorporated into the design and the final documents
will be submitted 100 percent complete with reproducible drawings and
specifications ready for bid advertisement. All Final Design documents shall
be certified by a Professional Engineer~ registered in the State of North
CaroliHa. EPA approval of the Final Design is required before initiating the
RA, unless specifically authorized by EP,",. The following items shall be
submitted as part of the Prefinal/Final Design:
1. Complete Design Analyses
The selected design shall be presented along with an analysis
supporting the design approach. Design calculations shall be included.
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2 .
3.
4.
Complete Plans and Specifications
A complete set of construction drawings and specifications shall be
submitted at the Prefinal stage which describe the selected design. The
final submittal shall include a complete set of construction drawings
and specifications as well as a set of one-half size reductions of the
drawings.
Final Construction Schedule
Construction Cost Estimate
A construction cost estimate accurate to within +15 percent to
-10 percent shall be submitted.
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14.0 REMEDIAL ACTION
TASK III REMEDIAL ACTION
14.1 GENERAL
Remedial Action shall be performed to implement the
response actions selected in the ROD. The Remedial Action shall consist of
all activities necessary to implement the response actions selected in the ROD
prior to operation and maintenance and long-term performance monitoring
activities.
A 1 J., REMEDIAL ACTION PLJ' .... "rNING
Concurrent with the submittal of the Intermediate Design,
The Settling Defendants steering committee shall prepare and submit the
following submittals concurrently with the 50 percent Design:
-RA Work Plan;
-Construction Management Plan;
-Construction Quality Assurance Plan; and
-Construction Health and Safety Plan/Contingency Plan .
The RA Work Plan, Construction Management Plan, and
Construction Quality Assurance Plan must be reviewed and approved and
the Construction Health and Safety Plan/Contingency Plan reviewed by EPA
prior to the initiation of the Remedial Action.
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Upon approYal of the RA ¥/erk Plan and the Final
Design, the Settling Defendants shall implement the RA 'A'orlE Plan in
accordance with the construction managemeHt schedule. SignificaHt "field"
changes to the R,\ as set forth in the R,\ ¥/erk PlaH and Final DesigH shall
not ee undertaken ·Nithout the appro.,•al of EPA. The RA shall ee
documented in enough detail to produce "as euilt" construction drawings
certified ey a Professional Engineer or Geologist registered in the State of
North CaroliHa. Implementation of the RA shall include EPA reyiew and/or
approyal of required deliveraeles. The purpose of these reyie·Ns is for EPA to
assess the feasieility of the project to achie\'e the Site Oejectives in accordance
with the ROD and Consent Decree, including this SOW. Review and/or
appro•ral of suemittals does not imply acceptance of later suemittals that have
not eeen reviewed, nor that the remedy, when constructed, will meet
performance standards and ee accepted.
-h14.2 RA WORK PLAN
A Work Plan which provides a detailed plan of action for
completing the RA activities shall be submitted to EPA for review and
approval. The objective of this work plan is to provide for the safe and
efficient completion of the RA. The Work Plan shall include a
comprehensive description of the work to be performed and a construction
management schedule for completion of each major activity and submission
of each deliverable. The Work Plan shall be developed in conjunction with
the Construction Management .Plan, the Construction Quality Assurance
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Plan, and the Construction Health and Safety Plan/Contingency Plan,
although each plan may be delivered under separate cover.
Specifically, the Work Plan shall present the following:
a. A detailed description of the tasks to be performed and a description of
the work products to be submitted to EPA. This includes the
deliverances set forth in the remainder of Task III.
b. A schedule for completion of each required activity and submission of
each deliverable required by this Consent Decree, including those in
this SOW.
c. A project management plan, including monthly reports to EPA and
meetings and presentations to EPA at the conclusion of each major
phase of the RA.
d. A description of the community relations support activities to be
conducted during the RA. At EPA's request, it is expected that the
Settling Defendants steering committee will assist EPA in preparing
and disseminating information to the public regarding the RA work to
be performed.
e. A description of Settling Defendants' steering committee's strategy for
delivering the project. This description shall focus on the
management approach to carry out the design and implement the
Remedial Action. Items to be addressed include procurement method
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and contracting strategy, phasing alternatives, and contractor and
equipment availability concerns. If the construction of the selected
remedy is to be accomplished by Settling Defendants' steering
committee's "in-house" resources, these resources shall be identified.
2.14.3 CONSTRUCTION MANAGEMENT PLAN
A Construction Management Plan shall be developed to
indicate how the construction activities are to be implemented and
coordinated with the EPA during the RA. The Settling Defendants steering
committee shall designate a person to be a Remedial Action Coordinator and
their representative on-site during the Remedial Action. This plan shall
identify this representative along with other key project management
personnel and lines of authority as well as provide descriptions of the duties
of the key personnel along with an organizational chart. In addition, a plan
for the administration of construction changes and EPA review and approval
of those changes shall be included.
3-:14.4 CONSTRUCTION QUALITY ASSURANCE PLAN
Settling Defendants The steering committee shall develop
and implement a Construction Quality Assurance Program to ensure, with a
reasonable degree of certainty, that the completed remedial action meetings or
exceeds all design criteria, plans and specifications, and Site Objectives . .:i:he
Construction Quality Assurance Plan shall incorporate relevant areas of the
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Remeeiiaaen Gaal VeFiiieatien Plan (see Task V). At a minimum, the
Construction QA plan shall include the following elements:
a. A description of the quality control organization, including a chart
showing lines of authority, identification of the members of the
Independent Quality Assurance Team (IQAT), and acknowledgement
that the IQAT will implement the control system for all aspects of the
work specified and shall report to the project coordinator and EPA.
The IQAT members shall be representatives from testing and
inspection organizations and/or the Supervising Contractor and shall
be responsible for the QA/QC of the RA. The members of the IQAT
shall have a good professional and ethical reputation, previous
experience in the type of QA/QC activities to be implemented, and
demonstrated capability to perform the required activities. They shall
also be independent of the construction contractor.
b. The name, qualifications, duties, authorities, and responsibilities of
each person assigned a QC function.
c. Documentation of the observations and control testing that will be
used to monitor the construction and/or installation of the
components of the remedial action. This includes information which
certifies that personnel and laboratories performing the tests are
qualified and the equipment and procedures to be used complies with
applicable standards. Any laboratories to be used shall be specified.
Acceptance/Rejection criteria and plans for implementing corrective
measures shall be addressed.
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d.
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f.
A schedule for managing submittals, testing, inspections, and any other
QA function (including those of contractors, subcontractors, fabricators,
suppliers, purchasing agents, etc.) that involves assuring quality
workmanship, verifying compliance with the plans and specifications,
or any other QC objectives. Inspections shall also verify compliance
with all environmental requirements and include but not be limited
to, air quality and emissions monitoring records and waste disposal
records, etc.
Reporting procedures and reporting format for QA/QC activities
including such items as daily summary reports, schedule of data
submissions, inspection data sheets, problem identification and
corrective measures reports, evaluation reports, acceptance reports, and
final documentation.
A list of definable features of the work to be performed. A definable
feature of work is a task which is separate and distinct from other tasks
and has separate control requirements.
4.14.5 CONSTRUCTION HEALTH AND SAFETY
PLA .. "l/CONTINGENCY PLAN
A Construction Health and Safety Plan/Contingency Plan
shall ee prepared in conformance with the Settling Defendants' health and
safety program, and in compliance with OSHA regulations and protocols.
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The Construetion Health and Safety Plan shall inelude a health and safety risk
analysis, a deseription of monitoring and personal proteetive equipment,
medieal monitoring, and site eontrol. Note that EPA does not "appro¥e" the
Settling Defendants' Construetion Health and Safety Plan/Contingeney Plan,
but rather EPA revie·Ns it to ensure that all neeessary elements are ineluded,
and that the plan provides for the proteetion of human health and the
environment. Thgi.5 Construction Contingency Plan plan shall inelude a
Contingency Plan and incorporate Air Monitoring and Spill Control and
Countermeasures Plans, if applieable for the site. Air monitoring will be
neeessary at any site v1hen the site speeifie risk assessment speeifies a risk Yia
the inhalation/air transport pathway. The Contingency Plan is to be written
for the on-site construction workers and the local affected population. It shall
include the following items:
a. Name of Person who will be responsible in the event of an emergency
incident.
b. Plan for initial safety indoctrination and training for all employees,
name of the person who will give the training and the topics to be
covered.
c. Plan and date for meeting with the local community, including Local,
State and Federal agencies, involved in the remediation, as well as the
local emergency squads and the local hospitals.
d. A list of the first aid and medical facilities, including: location of first
aid kits, names of personnel trained in first aid, a clearly marked map
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with the route to the nearest medical facility, all necessary emergency
phone numbers conspicuously posted at the job site (i.e. fire, rescue,
local hazardous material, teams, National Emergency Response Team,
etc).
Plans for protection of public and visitors to the job site.
Air Monitoring Plan which addresses the following factors:
1) Air t.4oRitoriRg shall be coRducted both OR site aRd at the
perimeter of the site. The chemical coRstitueRts that were
ideRtified at the site as part of the Risk AssessmeRt shall service
as a basis of the sampliRg fer aRd measuremeRt of pollutaRts in
the atmosphere.
~11 Air monitoring shall include personnel monitoring, on-site area
monitoring, and perimeter monitoring
a) Personnel Monitoring shall be conducted according to
OSHA and NIOSH regulations and guidance.
b) On-Site Area Monitoring shall consist of continuous
real-time monitoring performed immediately adjacent to
any waste excavation areas, treatment areas, and any other
applicable areas when work is occurring. Measurements
shall be taken in the breathing zones of personnel and
immediately upwind and downwind to the work areas.
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Equipment shall include the following, at a minimum:
Organic Vapor Meter, Explosion Meter, Particulate
Monitoring Equipment, and On-site Windsock.
c) Perimeter Monitoring shall consist of monitoring
airborne contaminants at the perimeter of the Site to
determine whether harmful concentrations of toxic
constituents are migrating off-Site. EPA methods T0-1
and T0-2 shall be used to sample and analyze ambient air
at the Site perimeter. Such sampling will occur on a daily
basis during the active excavation of Site materials from a
downwind maximum of two perimeter stations. EPA
appro¥ed methods shall be used for sampling and analysis
of air at the site perimeter. Perimeter samples shall be
sampled and analyzed for the constituents of concern
identified in the risk assessment. The results of the
perimeter air monitoring and the on-Site meteorological
station shall be used to assess the potential for off-site
population exposure to toxic materials. The air
monitoring program shall include provisions for
notifying nearby residents, Local, State and Federal
agencies in the event that an emission of detectable
concentrations of airborne toxic constituents are migrating
off-Site.
A Spill Control and Countermeasures Plan which shall include the
following:
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-S,14.6
1) Contingency measures for potential spills and discharges from
materials handling and/ or transportation.
2) A description of the methods, means, and facilities required to
prevent contamination of soil, water, atmosphere,
uncontaminated structures, equipment, or material by the
discharge of wastes from spills due to operations.
3) A description of the equipment and personnel necessary to
perform emergency measures required to contain any spillage
and to remove spilled materials and soil or liquids that become
contaminated due to spillage. This collected spill material must
be properly disposed of.
4) A description of the equipment and personnel to perform
decontamination measures that may be required to remove
spillage from previously uncontaminated structures, equipment,
or material.
PRECONSTRUCTION CONFERENCE
A Preconstruction Conference shall be held after selection
of the construction contractor but before initiation of construction. This
conference shall include the SettliRg DefeRdaRts steering committee, the
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construction contractor and Federal, State and Local government agencies and
shall:
1. Define the roles, relationships, and responsibilities, of all parties;
2. Review methods for documenting and reporting inspection data;
3. Review methods for distributing and storing documents and reports;
4. Review work area security and safety protocols;
5. Review the Construction Schedule; and
6. Conduct a Site reconnaissance to verify that the design criteria and the
plans and specifications are understood and to review material and
equipment storage locations.
The Preconstruction Conference must be documented,
including names of people in attendance, issues discussed, clarifications
made, special instructions issued, etc.
G14.7 PREFINAL INSPECTION
Upon preliminary project completion the Settling
Defendants steering committee shall notify the EPA for the purpose of
conducting a Prefinal Inspection. Participants shall include the Project
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Coordinators, Supervising Contractor, Construction Contractor, and other
Federal, State, and local agencies with a jurisdictional interest. The Prefinal
Inspection shall consist of a walk through inspection of the entire project Site.
The objective of the inspection is to determine whether the project is
complete and consistent with the Consent Decree. Any outstanding
construction items discovered during the inspection shall be identified and
noted on a punch list. Additionally, treatment equipment shall be
operationally tested by the Settlil\g DefeHdaHts steering committee. The
SettliHg DefeHdaHts steering committee shall certify that the equipment has
performed to effectively meet the purpose and intent of the specifications.
Retesting shall be completed where deficiencies are revealed. A Prefinal
Inspection Report shall be submitted which outlines the outstanding
construction items, actions required to resolve the items, completion date for
the items, and an anticipated date for the Final Inspection.
FINAL INSPECTION
Upon completion of all outstanding construction items,
the SettliHg DefeHdaHts steering committee shall notify EPA for the purposes
of conducting a Final Inspection. The Final Inspection shall consist of a
walk-through inspection of the entire project Site. The Prefinal Inspection
Report shall be used as a check list with the Final Inspection focusing on the
outstanding construction items identified in the Prefinal Inspection. All tests
that were originally unsatisfactory shall be conducted again. Confirmation
shall be made during the Final Inspection that all outstanding items have
been resolved. Any outstanding construction items discovered during the
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inspection still requiring correction shall be identified and noted on a punch
list. If any items are still unresolved, the inspection shall be considered to be
a Prefinal Inspection requiring another Prefinal Inspection Report and
subsequent Final Inspection.
J;.14.9 REMEDIAL ACTION REPORT
Within thlfty ninety (90) days after the Final Inspection at
the Site, the Settling Defendants steering committee shall prepare and submit
a Remedial Action Report to the EPA which certifies that all items contained
in the Consent Decree, including the ROD and this SOW and all incorporated
documents (i.e., work plans, reports, plans and specifications, etc.) have been
completed and that the remedy is functional and operating and has met the
specifications. Such report shall be certified by a Professional Engineer-el'
Geologist registered in the State of North Carolina. The RA Report shall
include the following items:
1. Brief description of how outstanding items noted in the Prefinal
Inspection were resolved;
2. Synopsis of the work defined in the SOW and certification that this
work was performed;
3. Explanation of modifications made during the RA to the original RD
and RA Work Plans and why these changes were made;
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4. As built aRd Record Drawings, and;
5. Documentation of how the Respondents are implementing the
EPA-approved Operation and Maintenance Plan and Remediation
Goal Verification Plan.
The EPA will review the Remedial Action Report and
provide comments to the steering committee within 30 days of receipt of the
report. After EPA review, Settling Defendants the steering committee shall
address any comments and submit a revised report 30 days after receipt of
EPA's comments. The Remedial Action shall not be considered complete
until EPA approves the RA Report.
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15.0 TASK IV OPERATION AND MAINTENANCE
15.1 GENERAL
Operation and Maintenance (O&M) shall be performed for
projects that produce facilities requiring operation and maintenance to
support the response actions selected in the ROD. OpeFatioR aRd
MaiRteRaRce shall be coRsideFeEi to begiR OR the Elate of the RA Fepmt and
shall be coREiucteel uRtil the Site ObjectiYes aFe achieves iR accoFEiaRce with
the ROD aREi CoRseRt Decwe. An O&M Plan will be developed to provide a
scope of work for the long-term operation and maintenance of the RA
components at the Site.
15.2 OPERATION AND MAINTENANCE PLAN
Concurrent with the submittal of the Prefinal (9tl
95 percent) Design, the SettliRg DefeREiants steering committee shall submit
an Operation and Maintenance Plan to the EPA for review. The Operation
and Maintenance Plan shall be revised during the Remedial Action after
identification of the specific equipment to be installed by the construction
contractor and submitted for review by the EPA prior to 50 percent
completion of the Remedial Action and initiation of Operation and
Maintenance activities.
Upon approval of the Operation and Maintenance Plan,
the SettliRg DefeREiaRts steering committee shall implement the Operation
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and Maintenance Plan in accordance with the schedule contained therein.
This plan shall describe startup procedures, operation, troubleshooting,
training, and evaluation activities that shall be carried out by the Settling
Oerenaants steering committee. This plan shall also include all necessary
O&M information for the operating personnel for the anticipated life of the
project. The plan shall address the following elements:
1. Equipment startup and operator training;
a. Technical specifications governing treatment systems;
b. Requirements for providing appropriate service visits by
experienced personnel to supervise the installation, adjustment,
startup and operation of the systems; and
c. Schedule for training personnel on appropriate operational
procedures once startup has been successfully completed.
2. Description of normal operation and maintenance;
a. Description of tasks required for system operation;
b. Description of tasks required for system maintenance;
c. Description of prescribed treatment or operating conditions; and
d. Schedule showing the required frequency for each O&M task.
3. Description of potential operating problems;
a. Description and analysis of potential operating problems;
b. Sources of information regarding problems; and
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4.
5 .
6.
7.
c. Common remedies of anticipated corrective actions.
Description of routine monitoring and laboratory testing;
a. Description of monitoring tasks;
b. Description of required laboratory tests and their interpretation;
c. Required QA/($:.; and
d. Schedule of monitoring frequency and date, if appropriate, when
monitoring may cease.
Description of alternative O&M;
a. Should systems fail, alternate procedures to prevent undue
hazard; and
b. Analysis of vulnerability and additional resource requirements
should a failure occur.
Safety Plan;
a. Description of precautions to be taken and required health and
safety equipment, etc., for Site personnel protection; and
b. Safety tasks required in the event of systems failure.
Description of equipment;
a. Equipment identification;
b. Installation of monitoring components;
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c. Maintenance of Site equipment; and
d. Replacement schedule for equipment and installation
components.
8. Records and reporting mechanisms required;
a. Daily operating logs;
b. Laboratory records;
c. Records of operating cost;
d. Mechanism for reporting emergencies;
e. Personnel and Maintenance Records; and
f. Monthly reports to State/Federal Agencies.
TASK V PERFORMANCE MONITORING
Performanee monitoring shall be eondueted to ensure that the Site objeetives
for the remedy are met.
A 1 ,. Remediation Goal Verifieation Plan
The purpose of the Remediation Goal Verifieation Plan is to provide a
mechanism to ensure that both short term and long term performance
standards for the Remedial Action are being met. Guidances used in
developing the Sampling and Analysis Plan during the Remedial
Design phase shall be used. The Remediation Goal Verification Plan
shall be submitted with the RA 'Nork Plan. Onee approved, the
Remediation Goal Verifieation Plan shall be implemented on the
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appfe•rea scheaule. +h R eemeaiatien Goal Vefificaf Pl . an CORSIStS
of two pafts:
1. The Remeaiatien Goal Vefificatien Piela Sam I" a Pl th . P mg an Analysis
an at prnv1aes guiaance fef all fiela···eflc by El.cf . . .v ~mng m
El.etail the sampli 8 8 . . ng anata gathefing metheas to be a . use en a
PfOJCCt. The Vefificatien Piela Sampr a A • . mg an • ,nalys1s Plan shall
be wntten so that a fiela sam lin .. p g team unfam1haf •Nith th s·t
moula b bl e I e ..ea eteg th 11 a Cf he samples ana fiela . f . .· 1n~rmahen
reqmrea.
2. The Remeaiatien Goal Verification Quality A ssuf 'Q ' ' ance r uahty
Ce~t~~l plan that aesCfibes the policy, ergani:2:atien, functional
actw1hes aF1a q rt . ,ua I Y assurance ana quality centr 1 e protocols
necessary to achieve the f per~rmance stanaaras set forth i th R " n e
ecera of Decision ana the Remeaial D . . es1gn plans ana
specifications.
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&IM FIVE YEAR REVIEW
Because the selected remedy will leave residual levels of
hazardous eonstituents chemicals on Site, EPA shall conduct a Five Year
Review to ensure that the remedy has reached the goal of being protective of
human health and the environment. The time period for the five year
review shall start on the day of the Preconstruction Meeting.
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