NC0002374445_20230127_Hemphill Road TCE_Final Technical Management Plan

Technical Management Plan
Hemphill Road TCE Superfund Site Remedial Action
Gastonia, North Carolina
Prepared for:

United States Environmental Protection Agency – Region 4
Prepared by:

EQ & CH Remediation 1800 Carrillon Blvd. Cincinnati, OH 45240
Remedial Engineering Services (RES) Contract Line Item Number (CLIN) 2
Contract 68HERH19D0009
Task Order Number 68HE0422F0081 DCN: RES-R5-22F0081-02000
January 27, 2023
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Contents
Acronyms and Abbreviations ..................................................................................................................................... ii
1. Introduction ................................................................................................................................................... 1
2. Task Descriptions .......................................................................................................................................... 1
2.1 Task 1 General Requirements ........................................................................................................... 1
2.1.1 Task 1.1 Site-specific Plan Development ........................................................................... 1
2.1.2 Task 1.2 Project Management, Monitoring and Reporting ................................................. 3
2.1.3 Task 1.3 Permitting and/or Notifications ............................................................................ 4
2.1.4 Task 1.4 Clean Diesel Requirements .................................................................................. 5
2.1.5 Task 1.5 Task Order Closeout ............................................................................................ 5
2.2 Task 2 Fieldwork and Analytical Support ......................................................................................... 5
2.2.1 Task 2.1 Field Investigation ................................................................................................ 5
2.2.2 Task 2.2 Analytical Support and Data Validation .............................................................. 5
2.2.3 Task 2.3 Data Management and Evaluation ....................................................................... 6
2.3 Task 3 Remedial Action Implementation .......................................................................................... 7
2.3.1 Task 3.1 Mobilization and Site Preparation ........................................................................ 8
2.3.2 Task 3.2 Remedy Implementation ...................................................................................... 8
2.3.3 Task 3.3 Site Restoration .................................................................................................. 12
2.3.4 Task 3.4 Demobilization ................................................................................................... 12
2.3.5 Task 3.5 Photography/Video (Optional) ........................................................................... 12
2.3.6 Task 3.6 As-Built Drawings (Optional) ............................................................................ 12
2.4 Task 4 Engineering Support (Optional) .......................................................................................... 12
3. Project Organization ................................................................................................................................... 13
4. Communication and Reporting .................................................................................................................. 14
5. Schedule ....................................................................................................................................................... 15
6. Subcontractor Management ....................................................................................................................... 15
7. Public Involvement ...................................................................................................................................... 15
Appendices
A RD Diagrams B Project Schedule

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Acronyms and Abbreviations
Acronym Definition
ASB Analytical Services Branch
CFR Code of Federal Regulations
CLP Contract Laboratory Program
CQCP construction quality control plan
DMP data management plan
EPA U.S. Environmental Protection Agency
EQ CH JV EQ & CH Remediation joint venture
FASTAC Field and Analytical Services Teaming and Advising Committee
HASP health and safety plan
IDW investigation-derived waste
ISCO in situ chemical oxidation
MPR monthly progress report
PM project manager
PWS performance work statement
QA quality assurance
QC quality control
RA remedial action
RD remedial design
SMP site management plan
SMWMP site management and waste management plan
TCE trichloroethylene
TMP technical management plan
TO task order
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Acronym Definition
TOCO task order contracting officer
TOCOR task order contracting officer representative
UFP-QAPP Unified Federal Policy Quality Assurance Project Plan
VOC volatile organic compound
WMP waste management plan
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1. Introduction
This technical management plan (TMP) defines the scope for completing the remedial action (RA)
activities for the Hemphill Road TCE Superfund Site in Gastonia, North Carolina, as defined in the U.S. Environmental Protection Agency’s (EPA’s) performance work statement (PWS) dated July 2022; the Final (100%) Remedial Design (RD) dated July 2020; the request for offers dated July 20, 2022 with
associated attachments as well as questions and answers; and the kickoff meeting conducted November 4, 2022. The scope of this project is focused on in situ chemical oxidation (ISCO) treatment of contaminated subsurface soil, ISCO treatment of groundwater source areas (concurrent with subsurface soil treatment),
and groundwater monitoring at the site. The site consists of two contiguous land parcels, a 5.89-acre partially developed northwestern parcel and a 9.98-acre undeveloped wooded southeastern parcel. The period of performance for the base period is October 24, 2022, through October 23, 2025. The contract also includes option year 1 (October 24, 2025, through October 23, 2026) for which funding has not been obligated.
2. Task Descriptions
The work breakdown structure for project execution in the following subsections matches the structure defined in the PWS.
2.1 Task 1 General Requirements
2.1.1 Task 1.1 Site-specific Plan Development
The EQ & CH Remediation joint venture (EQ CH JV) will develop the following plans to support field
investigation/data acquisition activities. EQ CH JV will provide draft and final versions of each document incorporating one round of EPA comments. All submittals are electronic only.
2.1.1.1 Technical Management Plan
This TMP outlines the technical approach, project organization (including personnel), communication and reporting, schedule, subcontractor management, and public involvement. The draft TMP will be submitted 30 days after receipt of the notice to proceed, which is November 23, 2022.
2.1.1.2 Site Management and Waste Management Plan
Due to significant overlap, the site management plan (SMP) and waste management plan (WMP) will be presented in a combined site management and waste management plan (SMWMP).
The SMP outlines the processes, procedures, monitoring, and safeguards that will be used so that contaminants or pollutants are not released offsite during the implementation of the task order (TO) and how wastes that are encountered during TO activities will be managed and disposed, as appropriate. The SMP will also describe how EQ CH JV will conduct field sampling and data acquisition activities, communications, and investigation-derived waste (IDW) management.
The WMP outlines the safe handling of contaminated material, drummed material, and contaminated liquids in addition to procedures for offsite transportation and disposal of materials.
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Manifesting, Department of Transportation shipping papers, and chain-of-custody procedures will be described. The draft SMWMP will be submitted 30 days after EPA approval of the TMP.
2.1.1.3 Health and Safety Plan
A site-specific health and safety plan (HASP) will specify employee training, personal protective equipment, medical surveillance requirements, standard operating procedures, and a contingency plan in accordance with 40 Code of Federal Regulations (CFR) 300.150 of the National Contingency Plan and 29 CFR 1910.120(b)(1)(i) and (1)(ii). The HASP will address task-specific health and safety requirements. The draft will be submitted 30 days after EPA approval of the TMP and prior to any site work being performed. The HASP will be updated annually.
2.1.1.4 Uniform Federal Policy Quality Assurance Project Plan
The Uniform Federal Policy (UFP)-Quality Assurance Project Plan (QAPP) will describe the necessary quality assurance (QA), quality control (QC), and other technical activities that must be implemented so that the results of the work performed satisfy the stated performance criteria. A UFP-QAPP integrates technical and QC aspects of a project throughout its life cycle, including planning, implementation,
assessment, and corrective actions. The UFP-QAPP will provide:
 Data quality objectives that specify the data needed to support decisions regarding remedial response activities.
 Field sampling plan that describes the number, type, and locations of samples and types of analyses.
 Data management plan (DMP) in accordance with EPA national and region-specific data management plans or guidance. The TO DMP will detail the standard processes, procedures, and tools that the
contractor will use to support response activities and include requirements for EPA deliverable.
The UFP-QAPP will be submitted 30 days after EPA approval of the TMP. The UFP-QAPP will be updated once in base year 3.
2.1.1.5 Construction Quality Control Plan
The Construction Quality Control Plan (CQCP) will outline the necessary steps to inspect and sample construction materials in support of the overall quality of the constructed project. The CQCP will include
the following elements:
 Quality Management Organization (Independent chain of command)
 Quality Management Responsibilities
 Procedures for Submittals
 Surveillance and inspection of Subcontractor’s Operations
 Material Testing
 Tracking Procedures
 Control Phases (Preparatory, Initial, follow-up)
 Tracking Deficiencies and Corrective Actions
 Project Documentation Control System
 Notification of Changes to Procedures in CQCP
The draft will be submitted 45 days after EPA approval of the TMP.
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2.1.2 Task 1.2 Project Management, Monitoring and Reporting
Activities performed under this subtask include general management, coordinating staffing, and other support activities to perform project tasks in accordance with the PWS. This includes coordinating with
team subcontractors and other subcontractors; establishing and maintaining necessary project files; performing contract administration functions; and managing and tracking costs, monitoring progress of the project against the task schedules, and due dates for deliverables and submitting monthly progress
reports (MPR) and invoices.
EQ CH JV will review the project schedule monthly and when there are changes, EQ CH JV will update the schedule. A copy will be provided to the task order contracting officer representative (TOCOR) and
the task order contracting officer (TOCO).
This task involves preparation for, participation in, and follow-up by the project manager (PM) and QA officer in audits with the TOCOR and other EPA staff to review compliance of the delivered work to the requirements of the planning documents. Additionally, EQ CH JV will perform a health and safety and quality audits during fieldwork under Task 3.0.
The base period of performance for the project is October 24, 2022, to October 23, 2025, for 36 months. Option Year 1 is from October 24, 2025, to October 23, 2026, for 12 months. The total period of performance for base and option periods is 48 months.
Task 1.2 also includes the activities listed in the following subsections.
2.1.2.1 Task 1.2.1 Kickoff Meeting
The kickoff meeting was held on November 4, 2022, to discuss the PWS, site visit plans, and document
review needs. The TOCOR and EPA hydrogeologist were in attendance with the EQ CH JV PM, assistant project manager, engineer of record, senior remediation engineer, and designated project executive. EQ CH JV prepared and submitted meeting minutes to EPA within 2 business days. The meeting
deliverable will be the TMP.
2.1.2.2 Task 1.2.2 Systematic Project Planning Meetings
Throughout the project, the EQ CH JV will schedule virtual/teleconference systematic planning meetings to revisit project-specific requirements and discuss any changes or modifications needed in project scope, schedule, and/or budget.
Two-hour meetings will occur monthly starting after the UFP-QAPP is approved (assumed February 6, 2023) until the initial full round of ISCO injections (July 2023) are performed, which is assumed to be a duration of 6 months. A total of six meetings are estimated.
After that, meetings will be scheduled after each of two complete rounds performance monitoring and after each of four semiannual sampling durations. Six meetings are estimated and assumed to be 2 hours in duration. The meetings will be used to discuss data on the system performance monitoring data.
Meeting minutes will be prepared and submitted to EPA within 3 business days of a meeting. The PM and one additional staff member will attend the meetings.
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2.1.2.3 Task 1.2.3 Preconstruction Conference
After award and prior to field mobilization, a preconstruction conference call will be held with EPA. EQ CH JV proposes that our hydrogeologist, engineer, PM, ISCO subject matter expert, QC personnel,
safety personnel, and representative from FRx (the ISCO subcontractor) will attend this meeting. This meeting is expected to last 2 hours. Submittals, safety, environmental protection, project schedule, and procurement materials will be discussed in this meeting. EQ CH JV will record meeting minutes and submit them to the TOCOR within 3 business days of the meeting. After approval by EPA, EQ CH JV will distribute the meeting minutes.
2.1.2.4 Task 1.2.4 Site Visit
On a date approved by the EPA TOCOR, EPA personnel and up to three EQ CH JV personnel will meet for 1 day onsite in Gastonia, North Carolina, to view the existing conditions at the site. EQ CH JV will prepare a site visit report to include meeting minutes and key observations within 5 business days after
the visit. The site visit is scheduled for December 15, 2022.
2.1.3 Task 1.3 Permitting and/or Notifications
Under Task 1.1, EQ CH JV will prepare several plans that will support environmental compliance of onsite activities (WMP and SMP). EQ CH JV will also prepare a list of compliance requirements for chemical storage and will prepare a spill control plan and stormwater pollution prevention plan (including
soil erosion and sediment control) the field operations to follow. Draft and final versions of these plans will be submitted electronically similarly to Task 1.1.
EQ CH JV assumes that there are no wetlands present, and the site is not in a floodplain. EQ CH JV also
assumes roads will not need to be constructed to provide access to construction activities. As noted by EPA in responses to questions, an environmental protection plan is not required to be submitted to EPA.
EQ CH JV expects that approximately 1.1 acres of low brush vegetation will need to be cut to gain access to areas where work will be performed. Some trees may also require cutting. No grubbing is planned, and low-cut tree stumps will be left in place. To comply with the Migratory Bird Treaty Act timeframes and field inspection requirements, EQ CH JV will identify the species and their nesting timeframes and consult with the U.S. Fish and Wildlife Service as appropriate immediately prior to tree removal. EQ CH JV assumes that threatened and endangered species have been evaluated as part of previous work at the site and are not present.
In accordance with North Carolina Administrative Code 15A 02C.0225, EQ CH JV will prepare the necessary documentation on the planned injections. If required by EPA, EQ CH JV will submit to the
State of North Carolina prior to beginning injections. EQ CH JV assumes that all the required documentation is available and that there will be one submission of documentation on injections after completion of the work.
A list of compliance records that EQ CH JV will maintain for compliance with substantive requirements will be prepared.
Based on the RD, EQ CH JV assumes that EPA still retains access agreements for all applicable properties
and has included in this proposal the effort only to coordinate fieldwork timing with landowners.
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2.1.4 Task 1.4 Clean Diesel Requirements
EQ CH JV will use diesel non-road-construction equipment and generators that meet EPA’s Tier 2 clean diesel standards as appropriate to this project.
2.1.5 Task 1.5 Task Order Closeout
EQ CH JV will perform the work necessary to close out the TO in accordance with the contract requirements. Project closeout will consist of the following activities:
 Complete all deliverables as outlined in the PWS.
 Consolidate, package, inventory, and return documents via compact disc to EPA.
 Duplicate/distribute/store files according to EPA instructions.
 Submit the final invoice.
2.2 Task 2 Fieldwork and Analytical Support
Per Attachment 3, Instructions to Offerors, Task 2 Fieldwork and Analytical Support activities (i.e., Analytical Support and Data Validation, Data Management and Evaluation) are included with the remedy implementation activities in Task 3. This section only describes the activities that will be performed in Task 3.
2.2.1 Task 2.1 Field Investigation
EQ CH JV will perform the following field activities:
 Mobilization and demobilization
 Site Reconnaissance
 Environmental Investigations
 Contaminant Characterization
 IDW Disposal
The following sections reflect EPA’s PWS for Task 2.
2.2.2 Task 2.2 Analytical Support and Data Validation
EQ CH JV will coordinate with the regional sample control coordinator, regional laboratories and/or the Laboratory Services and Applied Science Division, and the EPA sample management office, or
equivalent, regarding any analytical support, data validation, and QA issues. The scope of analytical support and data validation activities will generally be outlined in the TO document and more specifically in the UFP-QAPP.
EPA Region 4 will perform completeness checks on laboratory data generated by Field and Analytical Services Teaming and Advising Committee (FASTAC) Tier Laboratories 1-3 (EPA Regional Laboratory and Environmental Services Assistance Team Contract, Contract Laboratory Program (CLP), or Region
Specific Analytical Services Contract). Upon review of analytical completeness check, EPA Region 4 will perform Step I through Step IIa validation. Resulting data will be provided to EQ CH JV and will be evaluated to determine if further qualification of the data is required (Step IIb-III) by EPA Region 4. EQ
CH JV will not conduct validation on its own generated data unless otherwise directed by the TOCOR.
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Analytical support and data validation activities including environmental sample collection, analytical services and support, data review and validation (if applicable). Throughout the analytical support and data validation process,
Data Review Elements:
• Step I: Verification
• Step IIa: Validation – compliance with methods, procedures and contracts
• Step IIb: Validation – comparison with measurement performance criteria in project-specific
QAPP
• Step III: Usability Assessment – comparison with project quality objectives in project-specific
QAPP
2.2.2.1 Task 2.2.1 Environmental Sample Collection
This activity includes the collection of soil, groundwater, and IDW characterization samples in
accordance with the UFP-QAPP. EQ CH JV will use EPA’s Scribe software to generate sample and tag labels and chain-of-custody forms for samples collected in the field. The Scribe sample manager will set up the Scribe database, prepare sample labels, and coordinate with the field team prior to sample collection. EQ CH JV assumes that all analytical sample analyses will be completed by EPA’s Analytical Services Branch (ASB) laboratory. If ASB is unable to analyze samples, an EPA CLP-assigned laboratory will be used; EQ CH JV did not include procurement and coordination efforts with a non-CLP laboratory within the proposal. Sample containers per sample method and matrix, as outlined in the UFP-QAPP and appropriate analytical equipment will be obtained by EQ CH JV.
2.2.2.2 Task 2.2.2 Analytical Services and Support
Sample counts are assumed to include QA/QC samples. Sample data management will include sample tracking, data entry of field sample information, tracking receipt of laboratory reports and electronic data
deliverables, and performing a 10% check of electronic data against hard-copy reports.
2.2.2.3 Task 2.2.3 Data Validation
It is assumed that 100% validation on field data will be performed by EPA Region 4 validators. It is
assumed that EPA Region 4 validators will perform 100% Step I-IIa validation of laboratory data, excluding IDW characterization data. The validators will review the validated analytical results against the analytical method and UFP-QAPP requirements and reconcile the analytical results with the data
quality objectives to assess whether the data are acceptable for use on the project. It is assumed that the EQ CH JV project chemist will perform an evaluation on 100% of the validated analytical data to determine if additional validation (Step IIb-III) is needed by EPA Region 4 validators. EQ CH JV will not
conduct validation on its own generated data unless otherwise directed by the TOCOR.
2.2.3 Task 2.3 Data Management and Evaluation
EQ CH JV will provide data management support services that address the collection, processing, management, distribution, analysis, and archiving of data and information consistent with the EPA-approved site-specific DMP. EQ CH JV will not use proprietary software that must be abandoned or paid for by the EPA at the end of the contract. EQ CH JV will deploy data management support services in close coordination with EPA, manage and archive data consistent with the EPA-approved DMP, and
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conduct data evaluation as discussed in each respective activity in Task 3. The information will be submitted in a technical memorandum with supporting data as discussed in Task 3.
Data management and evaluation include database administration, including database setup, uploading field
and laboratory data, and performing database completeness checks. Data submittals include generating data tables for reporting and preparing and submitting the electronic data deliverable. It is assumed that the laboratory will provide valid values compatible with the EPA database. Preliminary data (if applicable) and final data will be submitted electronically by the laboratory, and the data will be compared to project screening levels and sent to the project team for evaluation to support decision making. Given the analytical methods specified in the Statement of Work and EPA’s FASTAC-tiered hierarchy to prioritize the use of
ASB and CLP, EQ CH JV assumes that two different laboratories will be used.
2.2.3.1 Task 2.3.1 Data Submittals
Sampling, monitoring, and environmental data will be submitted in accordance with EPA Region 4 Superfund Environmental Data Submission Procedure, January 2020. The standard Region 4 electronic data deliverable format is available at: https://www.epa.gov/superfund/region-4-superfund-electronic-
data-submission. Other delivery methods may be allowed if electronic direct submission technology changes.
Spatial data, including spatially referenced data and geospatial data, will be submitted in accordance with
EPA Region 4 Superfund Environmental Data Submission Procedure, January 2020. The standard Region 4 spatial format is available at: https://www.epa.gov/superfund/region-4-superfund-electronic-data-submission.
2.3 Task 3 Remedial Action Implementation
EQ CH JV will complete the field activities in the following sequence. First, a migratory bird survey will be completed in the area where brush clearing and drilling will occur. If nests or migratory bird habitats are discovered, EPA will be contacted and fieldwork postponed until the issue is resolved. The awarded contract does not include any costs for resolving issues. One survey is included in this proposal.
Vegetation clearance from the source area depicted in RD Figure 4-2 presented in Appendix A will be
completed prior to the first drilling event. Grass and undergrowth will be mowed, and small trees up to 10 inches in diameter (at breast height) will be removed only if needed. All material will be shredded/chipped in place or trees removed from the site. Any shredded or chipped material will be
spread onsite to a thickness of less than 4 inches. Vegetation clearance will be conducted one time.
Utility clearance will be conducted by a third-party locator (in addition to call North Carolina One-Call). Utility clearance will be conducted three times: prior to drilling the 5 permanent monitoring wells, prior
to drilling the 35 temporary monitoring wells, and prior to drilling the ISCO boreholes. Utility clearance will also be conducted prior to Optional Task 1, installation of 4 additional monitoring wells, and Optional Task 2, drilling boreholes for additional ISCO, if completed. Funding for Optional Tasks 1 and 2
has not been obligated.
Surveying will be completed for the five permanent monitoring wells and for the additional four monitoring wells if Optional Task 1 is completed. This work will be completed by a North Carolina-licensed contractor after each of the two events. The 35 temporary monitoring wells will be documented using submeter global positioning system equipment only.
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The first permanent monitoring wells will be installed, followed by a separate mobilization to install the 35 temporary monitoring wells. The baseline groundwater investigation will be completed concurrently with the temporary well installation, though staggered to begin a week or so later. EQ CH JV will request
from ASB/CLP 2- or 3-day turnaround times for preliminary results to streamline the remaining delineation effort.
ISCO injection work will begin once the baseline investigation results are assessed. EQ CH JV assumes for scheduling purposes that after three performance sampling events (1, 3, and 6 months), an additional injection will take place. The second injection would therefore take place approximately 12 months after the first injection.
Quarterly groundwater monitoring will then be conducted for eight events.
2.3.1 Task 3.1 Mobilization and Site Preparation
After EPA has approved all site-specific plans and provided a full notice to proceed for the project, EQ CH JV will convene a project team kickoff call to provide the mission, objectives, keys to success, routes of communication, areas of responsibilities, and schedule for the overall project. Five subcontractors will
also be procured for the field effort: a driller, FRx, a surveyor, a utility locator, and an IDW transporter.
Once subcontractors have been procured and field activities scheduled, mobilization and site preparation activities will include the following:
 Prior to drilling activities, EQ CH JV will coordinate and provide both North Carolina One-Call and independent third-party utility locates to locate and mark subsurface utilities within each of the areas where drilling will occur.
 EQ CH JV will identify and order field supplies, sample bottles, and equipment; prepare field instructions and documentation; coordinate with subcontractors and suppliers; and review subcontractor health and safety plans.
Preparation work will include preparing internal project field readiness reviews, field team charter teleconferences, and subcontractor charter teleconferences. The field staff charter teleconferences involve reviewing task roles/responsibilities/task instructions with team members and each subcontractor, including review of the scope of work, health and safety plans, schedule, equipment mobilization, and EQ CH JV points of contact. These internal project meetings will be completed prior to each of the two drilling events, the baseline investigation, injection work, performance monitoring, and quarterly
monitoring.
2.3.2 Task 3.2 Remedy Implementation
EQ CH JV will implement the remedy in accordance with the applicable parts of the RD and the PWS.
2.3.2.1 Task 3.2.1 Well Installation
Five performance monitoring wells will be installed within the source area as shown on RD Figure 4-3
presented in Appendix A, expected to be no more than 60 feet below ground surface (bgs) with an average of 50 feet bgs (see Appendix A). The borings will be advanced to the top of bedrock (bottom of the Piedmont Transition Zone).
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Lithology and discontinuity characteristics will be recorded by the EQ CH JV field geologist. The licensed well driller onsite will be requested to provide input on drilling data during drilling activities. Following placement of the well screen and casing, the sand pack will be placed in the borehole
annulus adjacent to the screen. The screen will be factory slotted to 0.020-inch, 10-foot screens, 2-inch threaded polyvinyl chloride. Blank casing will be 2-inch, factory threaded as a stickup well. Following placement of the well screen, 8-16 grade sand pack will be placed in the borehole annulus. The sand pack will extend a minimum of 2 feet above the top of the screen. This will be followed by a minimum 2-foot-thick bentonite seal and cement/bentonite grout from the seal to approximately 3 feet bgs.
Surface completion will include a 4-foot x 4-foot x 4-inch-deep concrete well pads with a protective steel cover and four protective bollards placed around each well pad to protect the well stickup. Construction completion logs will be prepared for each monitoring well.
The monitoring wells will be developed following installation to remove as much fine-grained material as possible from the well casing, sand pack, and borehole wall and to stabilization parameters according to standard operating procedures included in the UFP-QAPP.
All soil cuttings generated during drilling and fluids generated by well development and equipment decontamination will be contained in 55-gallon steel drums. The drums will be staged onsite for transportation and disposal offsite. EQ CH JV assumes 50% of the waste containers from this project will
be classified as hazardous.
2.3.2.2 Task 3.2.2 Baseline Investigation
A baseline investigation will be completed to establish current conditions and refine the treatment area as
needed. The baseline investigation will include the activities in the following subsections.
Groundwater Sampling (Baseline Groundwater Assessment)
Groundwater sampling will be conducted at a total of 34 permanent monitoring wells (including the five installed under Task 3.2.1). Collected groundwater will be analyzed for volatile organic compound (VOC) parameters.
Temporary Monitoring Wells (Delineation Refinement)
Thirty-five temporary monitoring wells will be installed to the top of bedrock to refine the ISCO target treatment zone. Lithology and discontinuity characteristics will be recorded by the EQ CH JV field geologist. Groundwater grab samples will be collected from each well location for VOC analysis. The temporary wells will be abandoned following grab sample collection per North Carolina regulations following sampling by EQ CH JV.
Baseline Investigation Report
A report summarizing the baseline investigation will document the work performed, detections of
constituents of concern and remedial goal exceedances, and provide recommendations to confirm and refine the trichloroethylene (TCE) treatment area. The report will include the following:
 Up to 10 pages of text
 Tabulated groundwater sampling results
 Field photographs
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 Boring logs from permanent and temporary monitoring wells
 Well completion logs for permanent monitoring wells
 Up to five figures presenting the well locations, sampling results, and groundwater flow maps
A draft report will be submitted. EQ CH JV assumes a 30-day review period by EPA and stakeholders. One set of review comments will be delivered to EQ CH JV and a final report submitted that incorporates review comments.
2.3.2.3 Task 3.2.3 ISCO Injections
EQ CH JV will perform ISCO injections of the remedial substrate into the residuum layer in the TCE source area as described on RD Figure 4-2, or as refined per the results of the baseline investigation.
A drilling subcontractor will drill 26 borings within the saprolite, Piedmont Transition Zone, and bedrock assuming an average maximum depth of 57 feet bgs (7 feet into the bedrock). The drilling subcontractor will use sonic drilling methods to advance an 8-inch borehole to a depth of 7 feet below the treatment interval. The subcontractor will then install a 4-inch diameter polyvinyl chloride blank casing with end cap from 60 feet bgs to the surface. Centralizers will be employed above and below the treatment zone
and every 20 feet above to the surface (assumes three centralizers per well).
Team subcontractor, FRx, whose technology is specified in the RD, will perform the ISCO injections using a permanganate slurry. A design radium of 15 feet was selected for each injection point per RD
Figure 4-2. Unless physical obstructions are present, injection points will be located 30 feet from the next closest injection point in a grid layout. Injections will begin just above the partially weathered rock, fractured bedrock interface, and then progress upwards at 5-foot intervals to the water table. FRx will
complete all reagent procurement, management, and usage.
Following injections, the drilling subcontractor will abandon the wells per North Carolina regulations.
2.3.2.4 Task 3.2.4 Performance Monitoring
Performance monitoring will be completed to evaluate the effectiveness of the injections in distributing ISCO amendments into the subsurface. Groundwater will be collected from 14 permanent monitoring wells in the TCE source area and submitted for VOC analysis.
Performance monitoring will occur 1 month, 3 months, and 6 months following completion of ISCO injections for a total of 3 events. The results of the performance monitoring will be presented to EPA in Task 3.2.8.
2.3.2.5 Task 3.2.5 Groundwater Monitoring
Groundwater monitoring will be completed from site monitoring wells to evaluate the progress of the
ISCO injections. Groundwater monitoring will occur quarterly and begin 9 months following the injections and proceed for 8 quarters. The monitoring network will include site monitoring and residential wells for a total of 40 monitoring wells. Groundwater samples will be collected for laboratory VOC
analysis and natural attenuation field parameters to evaluate the progress of the remedy.
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Following the completion of each quarterly sampling event, a groundwater monitoring report will be completed that summarizes all detections of constituents of concern, all remedial goal exceedances, and provides basic trend analysis. Each report will include:
 Up to 5 pages of text
 Tabulated groundwater sampling field parameters and analytical results
 Up to 5 figures with data results and trends
2.3.2.6 Task 3.2.6 Well Installation (Optional Task 1)
If performance or quarterly monitoring indicates that one or more additional monitoring well locations are needed in the shallow/saprolite portion of the aquifer, EQ CH JV and the drilling subcontractor will install four additional monitoring wells. These wells are assumed to be installed in a single mobilization, following utility clearance of the planned locations.
Monitoring wells will be installed per Task 3.2.1.
For sampling purposes, it is assumed these additional wells will be included in four of the eight quarterly sampling events. The inclusion of four additional wells in the quarterly sampling network is expected to
add one additional field day for each sampling event.
Funding for this task has not been obligated.
2.3.2.7 Task 3.2.7 ISCO Injections with Performance Sampling (Optional Task 2)
If performance monitoring indicates an additional round of ISCO injections in the source area residuum would be favorable to the progress of the remedy, EQ CH JV will prepare a plan to conduct additional ISCO injections in the designated area and repeat performance monitoring. A drilling subcontractor will
drill eight additional borings within the source area using the same procedures and assumptions as described under Task 3.2.3. These are assumed to be installed in a single mobilization, following utility clearance of the planned locations.
The additional ISCO injection is assumed to occur following the initial 6-month performance monitoring event, with three additional subsequent performance monitoring events before the full 8 quarters of groundwater sampling.
For sampling purposes, it is assumed this optional task will include three additional performance monitoring events at 14 monitoring wells in the TCE source area and submitted for VOC analysis as detailed in Task 3.2.4.
Funding for this task has not been obligated.
2.3.2.8 Task 3.2.8 Remedial Action Report
Following the ISCO injection event, EQ CH JV will prepare a draft RA report that will include the following:
 Documentation of the work performed
 Results of tests and measurements
 Engineering drawings, maps, and figures
 Waste manifests
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 Deviations in the field
 Costs incurred
A draft report will be prepared and submitted to EPA within 14 days of completion of the injections.
Comments on the draft report will be incorporated into a final report.
Upon completion of the performance monitoring, a final report will be prepared and submitted to EPA within 14 days of receipt of monitoring data. The final report will include the following:
 Tabulated groundwater sampling field parameters and analytical results
 Up to five figures with data results and trends
 Evaluation of the RA based on performance monitoring
2.3.2.9 Task 3.2.9 ISCO Injections with Performance Sampling – For Informational Purposes Only
Per the EPA PWS, if performance monitoring and quarterly groundwater monitoring indicate an additional round of ISCO injections beyond the original source area or in the partially weathered bedrock would be favorable to the progress of the remedy, at EPA request, EQ CH JV will prepare a plan for ISCO injections and performance monitoring, conduct additional injections in the designated area, and
perform the performance monitoring at 1, 3, and 6 months following the ISCO injections.
2.3.3 Task 3.3 Site Restoration
EQ CH JV assumes that site restoration activities will be limited to restoring only those disturbances
caused by drilling and injection rig activity. No site restoration to other areas is assumed.
2.3.4 Task 3.4 Demobilization
Demobilization includes removal of personnel and support facilities from the site upon TO completion.
EQ CH JV will not have any permanent or temporary facilities at the site.
2.3.5 Task 3.5 Photography/Video (Optional)
EQ CH JV will use electronic photography during each field event and those efforts are included in each
respective field task.
2.3.6 Task 3.6 As-Built Drawings (Optional)
EQ CH JV assumes the only drawings required for this project include well completion diagrams, boring logs, and site maps updated with surveyed locations of monitoring and injection wells. This information will be provided to EPA in each respective deliverable discussed in Task 3.
2.4 Task 4 Engineering Support (Optional)
EQ CH JV will provide a variety of engineering services to support RA or removal action activities for the site. These activities may include structural, mechanical, electrical, architectural, geotechnical, geological, civil, chemical, environmental, cost engineering, constructability reviews, and other
engineering support. This support may also include data evaluation (Task 2) and /or services to support engineering activities including development and updates to the existing conceptual site model. The extent of the engineering services is described in this TO document.
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Engineering support may include:
 Project systematic planning and associated project objectives documentation
 Design analysis reports including the criteria, design assumptions calculations and other pertinent data
 Performance specifications or completely edited Government furnished guide specifications
 Computer-Aided Design generated drawings
 Contractor schedules compatible with Microsoft Project
 Cost estimating software utilizing an industry approved software package capable of providing sufficient information to adequately and accurately capture the projected project costs
 Record drawings, modifications or as-built drawings
 Constructability reviews
EQ CH JV will work with EPA to define the required elements of this optional task within EPA’s scope assumptions.
3. Project Organization
Figure 3-1 presented the organization chart for this project. The project will be supported by local field staff
from the Charlotte, North Carolina, office as well as other nearby regional offices and nationwide as needed.
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Figure 3-1. Project Organization

4. Communication and Reporting
The following lines of communication will be established between EQ CH JV and EPA and other project stakeholders, as well as internal communication with the EQ CH JV team.
The PM will report directly to the TOCOR and will be the main point of contact for all matters associated
with the TO. Potential changes in scope, budget, and schedule will be immediately brought to EPA’s attention.
If directed by EPA, the PM or other delegated EQ CH JV staff will communicate with other project
stakeholders.
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The PM and field staff are responsible for ensuring conformance with the site plans and field operating procedures. When additional technical support and guidance are needed, the field staff will communicate directly with the PM or other technical staff to receive clarification before proceeding with the work task.
EQ CH JV will report project progress to the TOCOR by preparing MPRs and invoices. Minutes will be prepared for formal meetings such as the kickoff meeting, preconstruction conference, site visit, and systematic project planning meetings to document decisions and discussion points.
5. Schedule
Activities performed under this subtask include general management, coordinating staffing, and other
support activities to perform project tasks in accordance with the PWS. This includes coordinating with team subcontractors and other subcontractors; establishing and maintaining necessary project files; performing contract administration functions; and managing and tracking costs, monitoring progress of
the project against the task schedules, and due dates for deliverables and submitting MPR and invoices.
EQ CH JV will review the project schedule monthly and when there are changes, EQ CH JV will update the schedule. A copy will be provided to the TOCO.
The current project schedule is provided in Appendix B.
6. Subcontractor Management
EQ CH JV will use subcontractors to support implementation of the project. Each subcontractor will work to complete thoroughly defined scopes of work and schedules, and invoice against its compensation schedule. EQ CH JV field staff will monitor subcontractor performance and usage of materials for quality
control and for invoice review.
7. Public Involvement
Attendance of public meetings to support the TOCOR and EPA Community Involvement Coordinator were not scoped in the PWS or included in the proposal. However, if requested (and current funding allows), EQ CH JV will attend meetings. If more funding is required, it will be discussed with EPA before the meetings.
EQ CH JV staff and subcontractors will treat the site property owners, Mr. and Mrs. Trantham, professionally in person and via phone. Trash and debris will be removed before demobilizing each event.

Appendix A
RD Diagrams

Appendix B
Project Schedule
ID Task Name Duration Start Finish
1 Site Plans / Planning 123 days Mon 10/24/22Wed 4/12/23
2 Receipt of Notice to Proceed 1 day Mon 10/24/22 Mon 10/24/22
3 Kickoff meeting 1 day Fri 11/4/22 Fri 11/4/22
4 Technical Management Plan (TMP)22 days Tue 10/25/22 Wed 11/23/22
5 Site Visit 1 day Thu 12/15/22 Thu 12/15/22
6 Approval of the TMP 33 days Thu 12/15/22 Mon 1/30/23
7 Site Management and Waste Management Plan (SMWMP)21 days Tue 1/31/23 Tue 2/28/23
8 Health and Safety Plan (HASP)21 days Tue 1/31/23 Tue 2/28/23
9 Unified Federal Policy Quality Assurance Project Plan (UFP-QAPP)21 days Tue 1/31/23 Tue 2/28/23
10 Construction Quality Control Plan (CQCP)36 days Tue 1/31/23 Tue 3/21/23
11 Approval of SWMWP, HASP, and UFP-QAPP 1 day Wed 3/22/23 Wed 3/22/23
12 Construction Planning Meeting 1 day Fri 3/31/23 Fri 3/31/23
13 Approval of CQCP 1 day Wed 4/12/23 Wed 4/12/23
14 Field Investigations 815 days Mon 4/24/23 Fri 6/5/26
15 Mobilization 1 - Drilling 5 Performance Wells 12 days Mon 4/24/23 Tue 5/9/23
16 Mobilization 2 - Baseline Investigation 5 days Mon 5/1/23 Fri 5/5/23
17 Mobilzation 3 - Drilling/Grab Sampling Temp Wells 45 days Mon 5/22/23 Fri 7/21/23
18 Receive data / evaluate results 10 days Mon 7/31/23 Fri 8/11/23
19 Finalize injection locations 10 days Mon 8/14/23 Fri 8/25/23
20 Mobilization 4 - ISCO Injections 77 days Mon 8/28/23 Tue 12/12/23
21 Mobilization 5 - Performance Monitoring - 1 month 4 days Wed 1/10/24 Mon 1/15/24
22 Mobilization 6 - Performance Monitoring - 3 month 4 days Wed 3/6/24 Mon 3/11/24
23 Mobilization 7 - Performance Monitoring - 6 month 4 days Wed 5/29/24 Mon 6/3/24
24 Performance GW Monitoring 468 days Wed 8/21/24 Fri 6/5/26
25 GW Monitoring #1 6 days Wed 8/21/24 Wed 8/28/24
26 GW Monitoring #2 6 days Thu 11/21/24 Thu 11/28/24
27 GW Monitoring #3 6 days Fri 2/21/25 Fri 2/28/25
28 GW Monitoring #4 6 days Mon 5/26/25 Mon 6/2/25
29 GW Monitoring #5 6 days Tue 8/26/25 Tue 9/2/25
30 GW Monitoring #6 6 days Wed 11/26/25 Wed 12/3/25
31 GW Monitoring #7 6 days Thu 2/26/26 Thu 3/5/26
32 GW Monitoring #8 6 days Fri 5/29/26 Fri 6/5/26
33 Reporting 840 days Mon 5/8/23 Fri 7/24/26
34 Baseline Investigation Report 30 days Mon 5/8/23 Fri 6/16/23
35 Remedial Action Report - Draft 10 days Wed 12/13/23 Tue 12/26/23
36 Remedial Action Report - Final 10 days Tue 6/4/24 Mon 6/17/24
37 Quarterly Groundwater Monitoring Report #1 35 days Thu 8/29/24 Wed 10/16/24
38 Quarterly Groundwater Monitoring Report #2 35 days Fri 11/29/24 Thu 1/16/25
Qtr 3
2022
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ID Task Name Duration Start Finish
39 Quarterly Groundwater Monitoring Report #3 35 days Mon 3/3/25 Fri 4/18/25
40 Quarterly Groundwater Monitoring Report #4 35 days Tue 6/3/25 Mon 7/21/25
41 Quarterly Groundwater Monitoring Report #5 35 days Wed 9/3/25 Tue 10/21/25
42 Quarterly Groundwater Monitoring Report #6 35 days Thu 12/4/25 Wed 1/21/26
43 Quarterly Groundwater Monitoring Report #7 35 days Fri 3/6/26 Thu 4/23/26
44 Quarterly Groundwater Monitoring Report #8 35 days Mon 6/8/26 Fri 7/24/26
Qtr 3
2022
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