'FINAL WORK PLAN, REMEDIAL INVESTIGATION ...hexachlorocyclohexane (BHC), endrin, and/pr dieldrin, as...
Transcript of 'FINAL WORK PLAN, REMEDIAL INVESTIGATION ...hexachlorocyclohexane (BHC), endrin, and/pr dieldrin, as...
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Final Work Plan
Remedial Investigation/Feasibility Study Volume 1 - Technical Approach
Barber Orchard Site Haywood County, North Carolina
USEPA Work Assignment No. 034-RICO-A4T9 Black & Veatch Project No. 48134.0101
• Prepared under
EPA Contract No. 68-W-99-043
May 14, 2001
Prepared by Black & Veatch Special Projects Corporation
1145 Sanctuary Parkway, Suite 475 Alpharetta, Georgia 30004
Except for data contained on all pages of Volume 2 of this document, it is agreed that as a condition of award of this contract, and notwithstanding the conditions of any notice appearing hereon, the Government shall have unlimited rights (as defined in Contract No. 68-W-99-043) in and to the technical data contained in this document dated December 21, 2000, upon which this work assignment is based.
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TABLE OF CONTENTS
VOLUME 1 - TECHNICAL APPROACH
1.0 INTRODUCTION 1-1 1.1 Site Location and Background 1-1 1.2 Purpose and Scope of Work 1-4
2.0 TECHNICAL APPROACH 2-1 2.1 Overview 2-1 2.2 Task 1 - Project Planning and Support 2-2 2.3 Task 2 - Community Relations 2-5 2.4 Task 3 - Data Acquisition 2-5
2.4.1 Site Reconnaissance 2-7 2.4.2 Monitoring Well Installation/Well Sampling 2-7 2.4.3 Soil Sampling 2-11 2.4.4 Sediment/Surface Water Sampling 2-17 2.4.5 IDW Handling and Disposal 2-17
2.5 Task 4 - Sample Analysis 2-19 2.6 Task 5 - Analytical Support and Data Validation 2-20 2.7 Task 6 - Data Evaluation 2-21 2.8 Task 7 - Risk Assessment 2-21 2.9 Task 8 - Treatability Study and Pilot Testing 2-26 2.10 Task 9 - Remedial Investigation Report 2-26 2.11 Task 10 - Remedial Alternatives Screening 2-27 2.12 Task 11 - Remedial Alternatives Evaluation 2-29 2.13 Task 12 - FS Report 2-30 2.14 Task 13 - Post RI/FS Support 2-31 2.15 Task 15 - Administrative Record 2-31 2.16 Task 16 - Work Assignment Close Out 2-32
3.0 SAFETY AND CONTINGENCY PLAN 3-1
4.0 QUALITY CONTROL MEASURES 4-1 4.1 Quality Assurance Project Plan (QAPP) 4-2 4.2 Data Management Plan (DMP) 4-3
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5.0 PROJECT MILESTONES 5-1 5.1 Project Schedule 5-1 5.2 Project Deliverables 5-3
6.0 COST ESTIMATE 6-1
7.0 SUBCONTRACTORS/CONSULTANTS 7-1
8.0 EXCEPTIONS TO ASSIGNMENT, ANTICIPATED PROBLEMS, AND SPECIAL REQUIREMENTS 8-1
LIST OF FIGURES
Figure 1-1 Site Location Figure 2-1 Site Layout Map Showing Drainage Basin Figure 2-2 Proposed Monitoring Well Locations - Phase I Figure 2-3 Proposed Background Soil Locations - Phase I Figure 2-4 Proposed Surface and Subsurface Soil Locations - Phase I Figure 2-5 Proposed Grab and Composite Surface Soil Samples - Phase I Figure 2-6 Proposed Composite Surface Soil Locations - Phase II Figure 2-7 Proposed Surface Water and Sediment Locations - Phases I and II Figure 5-1 Project Schedule
LIST OF TABLES
Table 2-1 Summary of Phase I and Phase II Soil Sampling Locations
LIST OF APPENDICES
Appendix A - EPA Statement of Work
LIST OF ACRONYMS
ARAR applicable or relevant and appropriate requirement AT averaging time BERA baseline environmental risk assessment
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BHHRA Black & Veatch BRA CERCLA
CLP COPC EPA IT LOE LS mg/kg NCP OSWER PCB PM PRG QA QAPP QC RAO RGO RI/FS ROD RPM SARA SB/SDB/WOB SESD SLERA . SOW SVOC TAL TCL VOC WACR
baseline human health risk assessment Black & Veatch Special Projects Corporation Baseline Risk Assessment Comprehensive Environmental Response, Compensation, and Liability Act Contract Laboratory Program chemical of potential concern U.S. Environmental Protection Agency IT Corporation level of effort lump sum milligram(s) per kilogram National Contingency Plan Office of Solid Waste Emergency Response polychlorinated biphenyls project manager preliminary remediation goal quality assurance quality assurance program plan quality control remedial action objective remedial goal option remedial investigation/feasibility study remedial operations plan revolutions per minute Superfund Amendments and Reauthorization Act of 1986 small busines/small disadvantaged business/woman owned business Science and Ecosystem Support Division screening-level ecological risk assessment statement of work semivolatile organic compound target analyte list target compound list volatile organic compound work assignment completion report
VOLUME 2 - CONFIDENTIAL BUSINESS INFORMATION
Task Summary Information
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RJCO-A4T9 Rl/FS Barber Orchard Site
Task 1 - Project Planning and Support Task 2 - Community Relations Task 3 - Data Acquisition Task 4 - Sample Analysis Task 5 - Analytical Support and Data Validation Task 6 - Data Evaluation Task 7 - Risk Assessment Task 8 - Treatability Study and Pilot Testing Task 9 - Remedial Investigation Report Task 10 - Remedial Alternative Screening Task 11 - Remedial Alternative Evaluation Task 12 - FS Report Task 13 - Post RI/FS Support Task 15 - Administrative Record Task 16 - Work Assignment Close Out
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1.0 INTRODUCTION
The U.S. Environmental Protection Agency (EPA), under the authority, of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauth^riz^on Act pfji986 (SARA); has initiated procedures to conduct a remedial investigation*(RI) andjfeasibijity[study (FS) at the3aibCT: Orchard site located in Haywood County, North Carolina CFigufe: 1-1). The RI/FS h^tiatesiajnew assignment for investigation of a former apple orchard contaminated with pesticides and metals. This work plan for the RI/FS has been prepared by Black & Veatch Special Projects Corporation (Black & Veatch) under Contract No. 68-W-99-043 with U.S. Environmental Protection Agency (EPA) Region 4 and under specific authorization of EPA Region 4_thrpugh Work Assignment No. 034-RICO-A4T9 with assistance from their team subcontractor, IT Corppratipn.
This work plan describes the tasks tot the project team will perform in providing technical and administrative assistance to theE^Aiy This wprkpian also presents the prpjectschedule, along with the projected costs associated with each task.. This work plan presents the RI/FS efforts that will be performed in support of the EPA's actionsatthis site.
1.1 Site Location and Background The Barber Orchard site is located along U.S. Highway 74 in Waynesyille, Haywood County, North Carolina. The property is about 400 acres in size and was used as aj ommercial apple orchard by the Barber family. The apple orchard operated from about 1908 to 1988; a portion of the property is still used to grow apples. The remaining orchard has been developed into a residential community. Throughout its operational years, various pesticide mixtures containing DDT, hexachlorocyclohexane (BHC), endrin, and/pr dieldrin, as well as arsenic, leacL and other hazardous substances, were applied to the orchard to control insects and rodents. Pesticides and related metals from spills, leaks, and improper disposal of pesticide-contaminated containers, as well as from product application, have been detected in soils and ground water throughput the site. The site is being proposed to the NPL because pesticide-related contamination is present in residential soils and in private drinking water wells.
The mixing of pesticides reportedly occurred in one central rruxing area. .This area is located at the
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FIGURE 1-1 NORTH CAROLINA
BARBER ORCHARD
SITE LOCATION MAP
BARBER ORCHARD NORTH CAROLINA
NOT TO SCALE Q3 IT CORPORATION A Member of The IT Group
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intersection of three properties off Wmesap Lane. The mixing area consisted of two 500-gallon concrete tanks. Occasional spills of the pesticide mixture allegedly occurred in this area. Diluted pesticides were transported from the mjxing area to locations throughout the orchard via an underground pipeline system that wasburjed to.a depth of.about 1 foot below; land surface. The pipeline system was pressurized at: 800 pounds per siqiwe mch, and was about 2 to 2.5 inches in diameter. At various locations, the orchard employees woujidcormect a flexible hose and nozzle to the pipeline to apply pesticides to the apple trees. During the winter months, the pipes reportedly would freeze, causing them to rupture and leak. The pipes were routinely .flushed to prevent clogging, and any pesticide mixture present in the pipes was allowed to flow onto the ground. All pesticides were reportedly stored in a packing house. Pesticides were purchased from a supplier in South Carolina in 50-gallon drums and 50-pound bags. Once empty, the drums were reportedly returned to the supplier and the bags were burned.
Starting in about 1988, the property was,developed and a hqusuig s u ^ the homes were built from 1993 to _1994_, . The. site was. discovered; ajftej a'resjd requested sampling of a private drinking water weU in January 1999. Analytical results of the well water indicated the presence of alpha, delta, and gamma BHC. As a result, the North Carolina Department of Environment and Natural Resources, Division of Water Quality (DWQ) conducted more extensive ground water sampling. About 8 8 wells were sampled by the D WQ . Of the 88 wells, 3 4 contained total BHC above the DWQ ground water standard of 0.019 parts per bUtion (ppb); Also, the North Carolina Department of Agriculture collected soil samples from 16 properties in the former orchard, 10 of which contained levels of pesticides and lead above their.respective North Carolina Inactive Hazardous Sites program soil remediation goals.
In June 1999, the EPA Region 4 Science and Ecosystem Support Division (SESD) collected soil samples from 55 locations (53 of which were residential properties). Of the soil samples collected, 35 locations contained arsenic above 20 parts per million (ppm), and 25 of those were above 40 ppm. SESD also collected 55 ground water samples from private wells. Of the 55 wells sampled, 21 contained concentrations of pesticides including alpha-BHC, beta-BHC, and gamma-BHC above health-based benchmarks. Two wells contained lindane (gamma-BHC) at concentrations above the maximum contaminant level (MCL) of 0.2 ppb, one well contained lead above the MCL of 15 ppb, and bottled water was supplied to one residence with lindane above the MCL (0,2 ppb) and EPA
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-WCO-A4T9 RI/FS Barber Orchard Site
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Region 4 removal action limit (2 ppb). Twenty-two additional wells contained detectable levels of pesticides. As a result, EPA initiated a time-critical removal action at the Barber Orchard subdivision. Soil excavation was conducted at 28 residences. During the June 1999 sampling and subsequent sampling associated with the removal action, pipes from the underground pipeline system were observed on residential properties. In many areas, thepipes are protruding from the ground, and liquid was observed leaking from ojie pf the pipes. A sample coUected from sediment in one of the pipes contained arsenic (2,460,000 ppb) and lead (6,970,000 ppbX; Also during removal actions, pesticide residue in powder; form;was Mted in the former central mixing area, discarded bottles containing liquid pesticide mixtures were found and;disposed off site, and a second dump area containing discarded pesticide containers was discovered. The remqvaj_action was.completed in August 2000,
1.2 Purpose and Scope of Work The purpose of this work assignment is to perform RI/FS activities for the Barber Orchard site and to complete the associated baseline risk assessment activities in accordance with all applicable ^ B regulations and guidance including but not limited to Office of Solid Waste and Emergency Response (OSWER) Directive 9355.3-01, dated 10-88 (Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA). The objective of the RI/FS is to delineate the nature and extent of contamination, quantify potential risk to human health and the environment, and collect sufficient data to conduct an FS to evaluate potential remedial measures for the site. RI/FS activities associated with the Barber Orchard site investigation will consist of the tasks indicated in EPA SOW described in the following text.
The EPA SOW, dated September 1, 2000 (Appendix A), defined the tasks to be included in this work plan as follows:
Project Planning and Support Community Relations Data Acquisition Sample Analysis Analytical Support and Data Validation Data Evaluation
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Risk Assessment Treatability Study and Pilot Testing Remedial Investigation Report Remedial Alternatives Screening Remedial Alternatives Evaluation FS Report Post RI/FS Support Administrative Record Work Assignment Closeout.
The technical approach outlined herein discusses only those tasks previously listed and includes the issues discussed during the work assignment scoping meeting held on October 12,2000, and during the site vvalk on October 31 st.
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2.0 TECHNICAL APPROACH
2.1 Overview This section of the work plan describes the technical approach to the tasks to be performed under this
work assignment in providing technical support to the EPA. Work descriptions, where appropriate,
indicate the technical approach and assumptions that will impact the estimated level of effort (LOE)
the most. The tasks outlined in the September 1,2000 SOW have been incorporated into this work
plan under the appropriate tasks. The work to be performed will generally consist of the following
tasks:
• Task 1 - Project Planning and Support
• Task 2 - Community Relations
• Task 3 - Data Acquisition
• Task 4 - Sample Analysis
Task 5 - Analytical Support and Data Validation
Task 6 - Data Evaluation
• Task 7 - Risk Assessment
Task 8 - Treatability Study and Pilot Testing
Task 9 - RJ Report
• Task 10 - Remedial Alternatives Screening
• Task 11 - Remedial Alternative Evaluation
Task 12-FS Report
Task 13 - Post-RI/FS Support
• Task 15 - Administrative Record
• Task 16 - Work Assignment Close Out.
These task numbers correspond to the EPA work breakdown structure (WBS) for the RAC program
for performing Fund-Lead RI/FS activities and provide a manageable and efficient means of
budgeting and tracking project activities. There are 16 tasks associated with the complete WBS for
Fund-Lead RI/FS activities; however, only work activities for the 15 tasks previously listed are
discussed. The remaining 15 tasks, as described within the EPA SOW, will be performed by Black
& Veatch. A large portion of the technical effort associated with these tasks will be subcontracted
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Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RJCO-A4T9 Rl/FS Barber Orchard Site
to the IT Corporation.
Section: 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 2 of32
The task numbers will be used to account for both expended LOE hours and associated costs for
project activities. The cost and LOE hours estimate for the tasks associated with the RI/FS activities
are included in Volume 2 of this work plan.
2.2 Task 1 - Project Planning and Support Project management activities are those planning and support tasks that provide project control and
ensure that all project activities are performed according to scope, accurately, efficiently, and on
schedule. Black & Veatch commenced project management activities for the Barber Orchard site
on September 28, 2000 under this work assignment when it was first issued and will continue as
discussed in the following text.
Qualified personnel with appropriate professional backgrounds will be assigned to perform project
tasks. Although all reasonable efforts will be made to maintain continuity of personnel throughout
this work assignment, the assistance of some technical specialists (e.g., scientists and
hydrogeologists) as well as pool subcontractors for selected subtasks (e.g., monitoring well
installation and land surveying) is anticipated. The EPA remedial project manager (RPM) will be
advised as soon as possible when assistance from technical specialists and other changes to the
project team are necessary.
The Black & Veatch project manager (PM) will maintain project control and communication with
the EPA. The Black & Veatch PM will be responsible for keeping the EPA informed of the direction
of project work; compliance with schedules and budgets; performance of reviews, content, and
format of review comments; and day-to-day monitoring of project staff. The PM is also responsible
for providing EPA technical, financial, and schedule status reports on a monthly basis throughout
the life of the project. IT will provide Black & Veatch with all of the information required to
complete the reporting requirements with the EPA upon request. The Black & Veatch PM will
discuss individual subtasks with the RPM before and after each work event to facilitate consistent
and thorough cost control. Informal accounting of LOE and costs will be provided at the request of
the RPM for individual task events.
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Quality control (QC) will be carried out in accordance with the Black & Veatch Corporate Quality
Assurance Manual and the relevant EPA Region 4 requirements as outlined by the Region 4 Quality
Assurance Officer. Ultimate responsibility for QC rests with the Black & Veatch PM, although
various QC personnel from both Black & Veatch and the IT Corporation will assist the PM. Specific
information regarding QC procedures is contained in Section 4.0 of this work plan.
Subtasks representative of the efforts that will be completed under the project planning and support
task include the following:
Participation in the work assignment scoping meetings.
Conducting site visit.
Evaluation of existing site information.
Development of technical project goals and objectives.
Development of a draft and final work plan (including any negotiations).
Preparation and administration of any subcontracts required to properly execute the
various subtasks associated with the RI fieldwork efforts.
Development of a draft and final health and safety plan (HASP) to address the RI
field activities to be conducted in accordance with the SOW. Section 3.0, Safety and
Contingency Plan, addresses the preparation and implementation of the HASP.
Development of a sampling and analysis plan (chemical data acquisition plan)
consisting of the quality assurance project plan, the field sampling plan (FSP) and the
Data Management Plan.
Development of a draft and final quality assurance project plan (QAPP) to delineate
the quality assurance (QA) and quality control activities to be performed during the
investigation task. The QAPP will also address data quality objectives (DQO) for
addressing analytical methods for identifying contamination. Section 4.0 Quality
Control Measures, addresses the activities associated with QA/QC.
Development of a draft and final FSP to delineate the data collection activities to be
performed during the field investigation task. Section 2.3, Data Acquisition
addresses the activities associated with the FSP.
Development of a draft and final data management plan to identify data management
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systems and document control activities for the RI/FS task. Section 4.2, data
management plan addresses the activities associated with the data management plan.
• Development of a draft and final pollution control and mitigation plan to outline
procedures and safeguards and ensure proper handling of contaminants during RI/FS
implementation. Section 2.3 - Data Acquisition addresses the activities associated
with the Pollution Control and Mitigation Plan.
• Development of a draft and final risk assessment plan summarizing the methods and
assumptions necessary to perform a baseline risk assessment Section 2.7, Risk
Assessment, addresses the activities associated with risk assessment activities.
• Management of any equipment and subcontractors required to carry out the field
investigation activities.
Preparation of monthly progress and financial status reports.
Monthly progress reports will continue throughout the project and will summarize the following
information in the form of the technical, financial, and schedule status reports. ^ B
The technical status reports will summarize the following:
Activities during the reporting period
• Project schedule and progress, including percent LOE and costs expended through
the period
• Schedule variances and corrective actions
Activities planned for the next reporting period.
Financial status reports will summarize the following information:
Project professional hours and costs expended to date by task
Actual project professional hours and expenditures for the given reporting period
Estimated professional hours and costs to complete each task.
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Schedule status reports will summarize the following information:
• Project tasks with planned and actual start and completion dates • Planned and actual dates for milestones and submittals.
The project planning and support LOE and costs projected for this task are presented in Volume 2 with the projected costs.
2.3 Task 2 - Community Relations Community relations activities will include providing technical support for attending one community relations meeting at the Barber Orchard site.
2.4 Task 3 - Data Acquisition This task will include performing the RI/FS field investigation necessary to address the characterization of the nature and extent of contamination within all known and potentially impacted media at the Barber Orchard site. Complete details of the field investigation program will be presented in the HASP, sampling and analysis plan (QAPP, FSP, and data management plan), pollution control and mitigation plan, and the risk assessment plan, to be prepared and submitted as deliverables under Task 1, Project Planning and Support, in accordance with the SOW. All techniques, procedures, and materials used to install the monitoring wells and collect samples will be in accordance with the EPA, Region 4, Science and Ecosystem Support Division, Environmental Investigations Standard Operating Procedures and Quality Assurance Manual, May 1, 1996.
Acquisition of data will follow a phased approach. The existing data from the emergency response action focussed on collecting surface soil and potable water well data to address imminent threats to residents from potential exposure to developed and surrounding residential properties. Samples from soil, sediment, surface water, and groundwater will be collected from additional locations to fully delineate the nature and extent of contamination in all site media. The first phase of the RI field investigation will begin with a site reconnaissance to inventory potable water wells and springs, and collect information for obtaining site access for sampling. Once access is obtained, monitoring wells and soil borings will be installed. Investigative work conducted at this site to date has indicated that metals and organochlorine pesticides are the primary chemicals of concern (COPC) at this site. To
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Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RJCO-A4T9 Rl/FS Barber Orchard Site
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insure that all COPC have been identified, a limited number of samples will be
collected from all site media and analyzed for a full analytical suite to confirm the COPC and
establish background concentrations. The analytical results from these samples will be screened
against EPA Region 9 preliminary remediation goals (PRG) to determine if subsequent sampling
should be analyzed for any additional analyses, beyond target analyte list (TAL) metals and
organochlorine pesticides.
The lateral extent of surface soil contamination will be assessed throughout the site by collecting
composite surface soil samples (Q ? P^bejqw ground surface (bgs)) from 5-acre grids. To assess
the impact of sample compositing, sample to evaluate the affect of collecting composite samples.
The both grab and composite samples will be collected from three test tracks during the Phase I field
investigation. Each individual track will b^ quartCTe , and two grab samples collected from each
quarter. A portion of each of the eight individual grab samples will be combined to produce a single
composite sample. The individual grab samples and composite sample will be submitted for
laboratory analysis of metals and pesticides due to previous sampling investigations having identified ^ B
organochlorine pesticides and metals as chemicals of concern. The results from the individual grab
samples will be statistically compared to its associated composite three test tracks.will be selected
within areas of high, medium, and low arsenic oDncentrations. The resulting comparison, will be
used to justify the: collection of V^re^ainu^" 5-acre grid sam II
investigation, or make recommendations for an alternate sampling methodology.
The second phase of the RI field investigation will consist of collecting the remaining samples from
monitoring wells, potable water wells and springs, streams and surface ponds, and composite
surface soil samples in order to complete characterization; of the site and delineate the extent of
contamination. The majority of samples will be collected during the phase two investigation. This
approach will allow confirmation of the appropriate analytical program and the required time to
obtain property access for sampling.
For additional details regarding the collection of samples, including maps showing specific sampling
locations, the reader is referred to the RI/FS Sampling and Analysis Plan (Volume 1).
Specific activities to be performed in the field investigation include the following:
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2.4.1 Site Reconnaissance
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Potable Well/Surface Spring Survey: A field survey of all private potable water
wells within and just outside the drainage basin (Figure 2-1) of the Barber Orchard
site will be performed. Prior to mobilizing to the field, the State of North Carolina
Groundwater Office in Ashville will be contacted to obtain any data available on
private or public water wells in the vicinity of the site. Field personnel will visit
private residents and obtain information on the location and depth of potable water
wells, and any other pertinent information available regarding installation of the
wells. Similar information will be obtained for natural springs. A hand-held global
positioning system (GPS) device will be used to obtain approximate coordinates and
the elevations of the wells and springs. For sites where individuals cannot be
contacted in person, survey letters requesting well information will be prepared and
mailed to property owners.
Property Access Survey: While conducting the potable well survey, residents will
be given a form letter prepared by EPA requesting access to their property, as
appropriate, to install wells, soil borings, or collect surface soil samples. A listing
of properties requiring access where the owners could not be contacted during the
field survey will be prepared and submitted to EPA. The cost estimate assumes that
all access permissions or agreements required to collect samples will be obtained by
EPA before mobiliziling to the field.
2.4.2 Monitoring Well Installation/Well Sampling More than 90 potable water wells have been sampled at the Barber Orchard site. Existing data show
that a significant portion of these wells contain low levels of pesticides. Most of the wells are
completed within fractured bedrock at depths of up to 600 feet below the ground surface. Little data
is available on the construction of the wells, including the primary depth or zone(s) of water
production. The RI field investigation will include the installation of a limited number of deep
bedrock and overburden wells at key locations across the site. The locations of these wells are
shown on Figure 2-2. Detailed data, including subsurface geology, fracture zone delineation and
orientation, and vertical groundwater profiling will be collected from these wells to characterize the
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fCURE 2-2
PROPOSED MONITORING WELL
LOCATIONS - PHASE I
BARBCR ORCHARD NORTH CAROLINA
[0 II CORPORA IIOII
3 4 0051
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Section; 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 10 of 32
bedrock aquifer and determine the nature and extent of groundwater contamination. Once these
wells have been installed and sampled, existing residential potable water wells will be sampled and
results interpolated based on data obtained from the monitoring wells.
• Bedrock Wells: Five deep monitoring wells (Figure ^ will be installed to a
maximum depth of 600 feet using air rotary drilling techniques. One background and
two downgradient, and two sidegradient wells will be installed at key locations to
establish both downgradient and crossgradient transects across the site. Wells will
initially be drilled to the top of bedrock and surface casing set to prevent any cross
contamination from groundwater within overburden. Drilling will proceed into
bedrock until significant water-bearing zones are encountered. These zones will be
isolated with a down-hole packer and tested as drilling advances. Up to five
groundwater samples will be submitted from each boring for rapid turn analyses in
order to determine the most significantly impacted zones and the vertical extent of
contamination. In the event that rapid-turn analysis indicates the vertical extent of
contamination is at a depth of less than 600 feet, drilling will cease and the well will
be completed at that depth. After reaching the total depth of each boring, borehole
video and geophysical logging will be performed to identify subsurface lithology,
significant water-bearing fracture zones, and fracture orientation. Based on logging
and analytical data, two separate water-bearing zones will be completed within each
boring. Zones will be completed to monitor the most significant or contaminated
interval, and a deeper clean zone to establish the vertical extent of groundwater
contamination. After completion and development, each bedrock well zone will be
sampled again for laboratory analysis by regular laboratory turn around time.
Additional details regarding the drilling and completion of bedrock wells are
provided in the RI/FS Sampling and Analysis Plan (Volume I).
Overburden Wells: Ten overburden wells (Figure 2-2) will be drilled to a maximum
depth of 100 feet. The well borings will be drilled and completed to determine
subsurface geology and the nature and extent a groundwater contamination within
the overburden aquifer just above bedrock. Five of the wells will be paired with each
of the five deep bedrock wells. The remaining five wells will be installed within
Work Plan, Volume 1 -Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RICO-A4T9 RI/FS Barber Orchard Site
Section: 2.0 Revision No. 0
Revision Date: December 21. 2000 Page 11 of 32
areas of known or suspected contamination to profile subsurface soil contamination and characterize the underlying groundwater. To profile subsurface soil contamination, soil samples will be collected continuously from the ground surface to the top of the saturated zone. The borings for these wells will be installed using hollow-stem auger drilling techniques, and drilled to bedrock or auger refusal. In the event that borings encounter. bedrock or auger refusal before encountering groundwater, only soil samplesjwUlbe collected and the boring will be abandoned without cpmple^^ ^ fflpn^ring; WeUv, After completion and development, groundwater samples will be collected from the wells.
2.4.3 Soil Sampling Both surface (0 to 6 inches) and subsurface soil samples will be collected. A summary of Phase I and Phase II soil sampling locations is shown in Table 2rl. Composite surface soil samples will be collected to supplement the existing data collected during the emergency response action and determine the full nature and extent of contamination. Subsurface soil samples will be collected only at selected locations to characterize the vertical extent of contamination and evaluate the potential for leaching to groundwater. Proposed soil sample locations are shown in Figures 2-3 through 2-6. For additional details regarding the number and Ipcatipns of soil samples to be collected, the reader is referred to the RI/ES Sampling andAnalysisPlan(Vpjunie 1).
Surface Soil Samples: Approximately 140 soil samples will be collected within and around the perimeter of the site. Individual grab samples will be collected from each location where subsurface soil samples are collected, including borings for the installation of bedrock and overburden wells, as well as selected background locations. Composite samples will be collected over selected areas of the site based on 5-acre grids, with one composite sample collected for each grid. Each 5-acre grid selected will be quartered, with two samples collected from each quarter, yielding a total of eight locations for each grid sample. As discussed in Section 2.4 both grab and composite samples will be collected from three five-acre tracks during the Phase I investigation to evaluate the validity of collecting composite samples. In the event that the results from these test tracks do not support the proposed sampling scheme, an alternative, plan wUlb^ raprwsed.
•
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RICO-A4T9 RI/FS Barber Orchard Site
Revision No. 0 Revision Date: April 2001
Table 2-1
Summary of Phase I and II Soil Sampling Locations
Phase I
II
Description/Depth Hand Auger (0.0-0.5,1-3 ft bgs) Surface Soil (0.0-0.5 ft bgs) Surface Soil (0.0-0.5 ft bgs) Direct-Push (0.0-0.5, 1-3, 4-6, 8-10 ft bgs) Split-Spoon (0.0-0.5, 1-3, 4-6, 8-10 ft bgs)
Surface Soil (0.0-0.5 ft bgs)
Type Grab
Composite Grab Grab Grab
Composite
Number of
Locations 10 3
24 10 10
107
Total Samples
20 3
24 40 40
107
Purpose |
Background Determination
X
Evaluation of Composite Sampling
Methodology for Phase II
X X
Full Suite Data to Confirm
Analytical Suite for Phase II
X X
Providing Full-Suite Data for
Risk Assessment
Determination of
Contamination Nature and
Extent
X X X X
X
.
SOURCE" BASE MAPPING TROU HATWOOO COUNTY LAND RtCOTOSvCEOCflAPWC I W O B M A T I O N S SYSTEMS OTFrCC HAYWOOD COUNTY, NC (2000 )
LEGEND:
ffi
PROPERTY BOUNDARY
ROAD
STREAM
WATERSHED BOUNDARY
NOTES: 1 BACKGROUND 5 0 * SAUPLE DEPTHS;
0 .0 -0 .5 ANO 1 ' i TCET BELOW CROWC SURFACE.
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8: l i ra KEY PLAN
soo vwoitn
FIGURE 2-3 PROPOSED BACKGROUND SOIL LOCATIONS - PHASE I
BARBER ORCHARD NORTH CAROL IN*
[0 I I COHPONAllUll
SOURCE: BASE UAPPtNC TROW HATNOCO COUNTY LAND RECOROS/CEOCRAPMC ITORIMTIONS SYSTEMS OTFCE. HAYWOOO COUNTY. NC I2OO0)
LEGEND:
H
PROPERTY BOUNDARY
ROAD CENTERltNE
STREAM
0 W X 1 PUSH LOCAWNS
OVERBURDEN MON-TORNG »CLL LOCATCNS. (SOLS COLLECTED DURING DRLLNG)
PROPOSED COMPOSITE SOL LOCAIIONS OUISJOE AREA OF KNOWN SOL C0N1AMWA1ON AND OUTSOC WATERSHED
PROPOSED COMPOSITE SOL LOCATIONS OUTSUC AREA OF KNOWN SOL CONTAUHATKM AND HSIDE WATERSHED
• NOTES:
PROPOSED COMPOSITE SOL LOCATIONS WSCE AREA OF KNOWN SOL CONTAUMATION
D*ECT PUSH AHO OVERBUROEH MONTTORMC WELL SOL SAMPLE DEPTHS' 0 .0 -0 .3 . 1-3. 4 - 6 . AND B-tO FEET BELOW GROUND SURFACE.
SURFACE SOL CRAB AND COMPOSITE SOL SAMPLE DEPTH: 0 .0-0 .5 FEET BELOW CROUNO SURFACE.
«*!«•.
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KEY PLAN
FIGURE 2 -4 PROPOSED SURFACE AND SUBSURFACE SOIL LOCATIONS - PHASE I
O i
CD CD
BARBCR ORCHARD NORTH CARO.HA
QL? IT CORPORATION A i W r n V 0' Tt* IT GlHV
LEGENO:
! :
PROPER TY BOUNDARY
ROAD
STREAM
PROPOSED COMPOSHE SOL LOCATIONS OUTSIDE AREA OF KNOWN SOL CONTAHNATION AND OUISOE WATERSHED
r" PROPOSED COMPOSHE SOL LOCATIONS OUfSiOl AREA Of KNOWN SOL C0NTAMNA11ON AND NSC*. WATERSHED
PROPOSED COWOSTC SOL LOCATIONS HSOE AREA Of KNOWN SOL CONTAMINATION
SOURCE'BASE UAPPWC FROM HAYWOOD COUNlY LAND RF.COTDS/GfOGRAPWC HFORMAliONS SYSTEMS 0»FICf HAYWOOO COUNTY. NC (7000)
I COW'OHAIIOH
LEGEND:
PROPERTY BOUNDARY
ROAD
STREAM
• • • • a i B i i WATERSXO BOUNDARY
PROPOSED COMPOSITE SOL LOCATIONS OUTSOE AREA Of KNOWN SOL CONTAUtNATON AND OUTSOE W A T E R E D
D PROPOSED COMPOSITE S O I LOCATIONS OUTSOE AREA OF KNOWN SO*. CONTAUMATON AND MS DC WATERSKO
PROPOSED C0MPOSI1E S O I LOCATCNS N5CE ARCA Of" KNOWN SCC CONTAUNATQN
NOTES:
KEY PLAN
HO DOCHin
FIGURE 2 - 6 PROPOSED COMPOSITE SURFACE SOIL LOCATIONS - PHASE 0
BARBER ORCHARD NORTH CAROLNA
SOlflCC'BASE yAPPlNC TROM HA*WOOO COUNTY LAND RECORDS/CEOCRAPHC INFORMATIONS SYSTCM5 OrriCE. HAYWOOO COUNTY. NC (2000 ) S3 II COHI'OHAMON
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• Subsurface Soil Samples: Subsurface grab soil samples will be collected from
selected areas with emphasis on those areas with high levels of known or suspected
contamination, as well as selected background locations. At a minimum, subsurface
soil samples will be collected at depths of 1 to 3, 6 to 8 and 8 to 10 feet, or auger
refusal. Five of the ten hollow-stem auger borings will be continuously sampled
from the ground surface to the top of the saturated zone. The remaining five auger
borings will be sampled on 5-foot centers, or continuously sampled at the discretion
of the onsite geologist. Additional depths[.will be determined; in the field at the
discretion of the site geologist. Subsurface soil samples will also be collected from
ten locations using direct-push technology rig in hard-to-access areas. At these
locations, up to three samples will be collected to depths of 10 feet or auger refusal.
2.4.4 Sediment/Surface Water Sampling
Seven small on-site creeks flow down the mountain side across the former orchard to Richland Creek
at the base of the site. Sediment and surface water samples will be collected along each creek at
locations to determine the nature and extent of contamination resulting from surface water runoff.
Sampling locations will be selected to evaluate known or suspected release areas where pesticides
were stored, mixed, and distributed. In addition, upstream locations will be selected to determine
background and anthropogenic concentrations. Proposed sediment and surface water locations are
shown on Figure 2-7.
2.4.5 IDW Handling and Disposal Field investigation activities will result in the production of potentially contaminated waste materials
that must be properly managed. Potentially contaminated materials generated during the field
investigation will include surface and subsurface soils, decontamination solutions, disposable
equipment, drill cuttings, well-development fluids, and well-purge water. The disposable equipment
and cuttings will be placed in 55-gallon drums segregated by boring. Decontamination fluids will
be placed in 55-gallon drums and staged at an on-site accumulation area. The containers will be
labeled to indicate contents. The contents of the drums will be disposed of by the subcontractor as
part of the demobilization following Phase I and Phase II of the RI. Development and purge water
from wells will be treated at each individual well location using activated carbon and discharged to
the ground surface. All investigation-derived wastes (IDW) will be characterized and disposed of
LEGEND:
PROPERTY BOUNDARY
TOAD CrNTERLINE
• I B I B I B I WAlERSHfO BOUNDARY
_ PROPOSED SURF ACt WATER AND (fi SED.MEN1 LOCATIONS. TO BE
COLLECTED W PHASE (SAMPLING.
PROPOSED SURFACE WATER AND SEDIWENI LOCATIONS. PHASE I BACKGROUND SAUP\ tS
_ PROPOSED SUftfAC£ WATER AND ( ! ) SCDWENl LOCATIONS. P>IASC I
FULL-SUITE SAMPLES
X "
1COUHCJ'tAllON
3 4 00
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Section: 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 19 of32
in accordance with local, state, and federal regulations, and as specified in the Guide to Management
of Investigation-Derived Wastes, 9345.3-03FS, January 1992. More detailed information on IDW
disposal will be provided in the FSP and pollution control and mitigation plan.
The LOE projected for this task is presented in Volume 2 with the projected costs.
2.5 Task 4 - Sample Analysis The samples to be collected during the field investigation will consist of soil, sediment, surface
water, groundwater, and IDW samples (soil and liquid) that are to be analyzed by an EPA Region
4 designated Contract Laboratory Program (CLP) laboratory.
Based on the analytical data currently available for this site, the COPC appear to be organochlorine
pesticides and metals. Due to the extended period of operations at this site from 1903 to the late
1980s, other chemicals could potentially be present that have not been identified. To ensure that all
potential COPC have been identified, a limited number of samples from each media will be
submitted for analysis of the following compounds:
• EPA Method OLM04.2 - Target Compound List (TCL) volatile organic compounds
(VOC), TCL semivolatile organic compounds (SVOC), and TCL organochlorine
pesticides /polychlorinated biphenyl (PCB)
EPA Method OLM04.0 -TAL metals and cyanide
• SW-846 Method 8142A - Organophosphorous pesticides
• SW-846 Method 8151A - Chlorinated herbicides.
The samples selected for this full analysis will include samples from known or suspected areas of
high pesticide/metals contamination and representative background locations. These samples will
be collected early in the field program, concurrently with the installation of the monitoring wells,
and analytical results reviewed prior to initiating area-wide sampling. The scope of work and costs
presented in this work plan reflect that the majority of the samples collected will be submitted for
Work Plan, Volume 1 - Technical Approach Section: 2.0 EPA Contract No. 68-W-99-043 Revision No. 0 Work Assignments 034-RJCO-A4T9 Revision Date: December 21, 2000 RI/FS Barber Orchard Site Page 20 of 32
analysis of organochlorine pesticides and TAL metals. In the event that other significant chemicals
are identified, the analytical program will be amended to include additional analyses, as appropriate.
Additional analyses will include grain size, sieve analysis, and total organic carbon for selected soil
and sediment samples, and water quality parameters for selected surface water and groundwater
samples.
IDW analysis will also be required for characterization and disposal of solids and liquids generated
during the investigation.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
2.6 Task 5 - Analytical Support & Data Validation This task includes sample management of the analytical data produced. The efforts to collect,
prepare, and ship the environmental samples collected during the field activities are included in the
Task 3 Data Acquisition details, as is the effort associated with preparation and tracking of the
sample custody records. The efforts required for the compilation of the custody records along with
the bulk of the QC functions associated with these records management activities are also under
Task 3 Data Acquisition.
It is assumed that minimal data validation efforts will be expended on the analytical data packages
received from the CLP laboratories because EPA Region 4 Science and Ecosystem Support Division
(SESD) validates CLP analytical data packages prior to shipping them to the site contractor. It is
also assumed that the data will be available in an electronic format from SESD. The QA/QC data
validation methods and criteria used will be defined in the FSP. A minimal effort on the part of
Black & Veatch and IT personnel has been included in this task, primarily for communications with
EPA Region 4 SESD personnel who perform the majority of the data validation activities associated
with CLP laboratory data, documentation of activities, and reporting.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
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Section: 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 21 of32
2.7 Task 6 - Data Evaluation This task will involve work efforts associated with the compilation of RI/FS analytical and field data associated with the field effort. In addition data collected in conjunction with the emergency response action conducted at the site will be incorporated jnto.the data base, as appropriate, The data will be entered into a database compatible with the EPA Region 4 database and will be used to prepare the RI risk assessment reports, including tables, maps, and figures. It is assumed that the data will be entered into a Lotus Version 9 compatible or equivalent spreadsheet and formatted to comply with the EPA Region 4 requirements. The following specific activities will be performed under this task:
• Conduct field evaluation of monitoring well data, including borehole video data and geophysical logs.
• Evaluate the usability of the data generated in the previous tasks of the RI/FS. • Evaluate, interpret, and tabulate data in an appropriate presentation format for final
data tables. • Establish an appropriate database for pertinent information collected during the
previous tasks for use in the RI/FS.
• Perform data reduction, tabulation, and evaluation of field data such as groundwater elevations, groundwater flux, hydrogeological testing, geophysical testing, waste data, and other analytical results.
• Perform routine reporting and data management.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
2.8 Task 7 - Risk Assessment The SOW requires the preparation of a baseline risk assessment (BRA) evaluating potential risks to both human health and ecological receptors associated with exposure to contaminated media at the Barber Orchard site. The BRA will be incorporated into the RI. Specific tasks and details of the protocol for the BRA are identified in the baseline risk assessment work plan. General assumptions to be followed in the human health and ecological risk assessments are presented as follows.
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RICO-A4T9 Rl/FS Barber Orchard Site
Human Health Risk Assessment
Section: 2.0 [ Revision No. 0
Revision Date: December 21, 2000 Page 22 of 32
Receptors. Receptors proposed for the Barber Orchard site baseline human health risk assessment
(BHHRA) include the following:
• On-site resident
• On-site commercial worker
• On-site construction worker
• On-site adolescent visitor
• Off-site sportsman.
It is assumed that the primary site use will be for residential purposes. However, a few beef cattle
were observed in one area and another had several goats. Therefore, separate exposure calculations
will be made for residents who may ingest home-produced beef or milk. As mentioned, a few of t h e ^ B
lots have ponds on them. Therefore, it is assumed that residents may occasionally swim in these
ponds during the summer; separate exposure calculations will be made for risks associated with
contaminants in the pond water.
The commercial worker is included to evaluate a possible alternative productive land use to provide
information for site management decisions. Because the site is actively being developed
residentially, it is expected that this commercial worker receptor would not include heavy industrial
activities or large office complexes where a full-time groundskeeper/maintenance worker would be
needed.
The construction worker represents an individual who would be exposed over the short-term during
excavation and construction of houses and buildings for small commercial businesses. The
construction worker scenario will be used to evaluate risks associated with subsurface soil.
The on-site adolescent visitor is likely to be an older child (who may live on site or near site) who
more broadly traverses the site while playing, but at a lower frequency than the residential exposur^^fc
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Revision Date: December 21,2000 Page 23 of 32
The only off-site receptor evaluated for this site is the sportsman who fishes the Richland Creek at the base of the mountain. Potential exposure pathways and media for these receptors are presented in the risk assessment work plan.
General Human Exposure Assumptions. Exposure assumptions proposed for the Barber Orchard BHHRA are listed as follows:
• Exposure to current residents living on property where remediation has already been performed will not be specifically evaluated. However, sampling points from nonremediated areas of these residential plots will be considered in the BHHRA, as will any subsurface soil samples underlying the remediated areas. These residents will not be evaluated for potential future exposure to subsurface soil.
• Primarily, the extent of contamination in surface soil is being evaluated in this phase of sampling. Therefore, potential exposure to contaminants in subsurface soil cannot be adequately quantified from the analytical results of these samples. Instead, relative concentrations in surface and subsurface grab soil samples will be compared, and potential relative contributions of subsurface soil contamination to future site risks (based on excavation and redistribution of soil) will be qualitatively evaluated. Existing confirmation samples may likewise be used in this evaluation. Also, subsurface grab soil data will be screened to identify any potentially site-related chemical that is detected at concentrations greater than in surface soil.
• Although risks associated with contaminants in subsurface soil samples will not be quantified in the BHHRA for receptors other than the construction worker, remedial goal options (RGO) may be derived based on surface soil cleanup levels (i.e., for lead and arsenic) for the residential receptor.
Although cows and goats are currently on the site, small-scale beef and milk
production is included separately from residential exposure because it is doubtful that
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-R1CO-A4T9 RJ/FS Barber Orchard Site
Section: 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 24 of 32
such land uses will be common or continuous at the site. Overall risks may be added
together, if desired, once risk calculations are made; cleanup levels may even be
derived from these combined risk results if deemed appropriate.
Because organochlorine pesticides are persistent in the environment and may be
taken up into plant tissue, and because home gardening is plausible, exposure of the
resident to site contaminants in homegrown produce will be evaluated.
Specific current and future residential areas are not being evaluated for residential
risk. Therefore, the primary utility of the residential cancer and noncancer risk
results is to develop RGOs. It is also for this reason that the estimation of risks
associated with subsurface soil are not necessary. As previously mentioned, RGOs
for subsurface soil may be derived based on RGOs for surface soil.
The Haywood County Head Start day care facility is located just southwest of the
site. IT plans to sample fte groundwater well that services the facility and compare
detected whcentrations of any chernicalsji Safe Drinking Water Act Mspomum
Contaminant L^vel(MCL)and EPA Region 9 PRGs: If concentrations of site-related
contaminants exceed, MG^i North C^pUna groundwater standards or PRGs, and
Barber Orrchard/is shpw^tVbe the h^ely source of these contaminants, risk
calculations will be p^praied for a child drinking from this well.
Contaminant concentrations in surface water will be screened against ambient water
quality criteria for ingestion of water and aquatic organisms and North Carolina
surface water standards.
Ecological Risk Assessment
The potential for adverse ecological effects associated with the Barber Orchard Site will be evaluated
through the performance of a screening-level ecological risk assessment (SLERA). The SLERA w i l ^ t
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be conducted using the procedures described in the 1997 EPA document Ecological Risk Assessment
Guidance for Superfund Process for Designing and Conducting Ecological Risk Assessment, the
1995 EPA Region 4 document Supplemental Guidance to RAGS: Region 4 Bulletins (EPA, 1995),
and August 1999 revisions to the Region 4 RAGS guidance (EPA, 1999), as modified based on
discussions with EPA Region 4. The results of the SLERA are used to determine whether a full
baseline ecological risk assessment (BERA) or other additional site activities are necessary.
The SLERA includes an ecological site description, screening-level effects evaluation, and
screening-level problem formulation. Data sources for the SLERA will be the same as for the
BHHRA unless appropriate exceptions are identified; these would be clearly noted in the SLERA.
The screening-level effects evaluation corresponds to Steps 1 and 2 of the eight-step ecological risk
assessment process for the 1997 Superfund guidance document. This evaluation identifies the
ecological COPC. The screening-level effects evaluation is followed by the initial phases of the
problem formulation, corresponding to Step 3 of the eight-step process.
General Ecological Assessment Assumptions. General assumptions used to evaluate
ecological risks for the Barber Orchard Site SLERA are as follows:
• Media evaluated in the SLERA include surface soil, surface water, and sediment.
Surface water and sediment will be evaluated for both on-site (drainages and ponds)
and off-site locations.
• Groundwater will not be evaluated because pathways for impacts to ecological
receptors via this medium have not been identified near the site. If surface
expressions of groundwater are identified, groundwater may be evaluated for
ecological receptors.
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RJCO-A4T9 Rl/FS Barber Orchard Site
Section: 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 26 of 32
•
• Additional ecological risk assessment activities, if necessary, will be performed after the SLERA is submitted, its results discussed, and such activities agreed upon by stakeholders.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
2.9 Task 8 - Treatability Study and Pilot Testing Task 8 includes efforts to perform treatability studies to evaluate potential remedial measures for the Barber Orchard site. As previously noted, any proposed treatability studies or pilot testing will be contingent on the results of the RI.
Potential studies could include options to supply an alternate potable water source to residents, or measures to minimize exposure to contaminated soil. The need for additional studies, if appropriate,^^ will be identified and recommended in the RI report. Accordingly, this task may be scoped andflV funded at a later date.
No LOE was projected for this task in Volume 2.
2.10 Task 9 - Remedial Investigation Report The draft RI report will document the site characteristics including the media contaminated, the extent of contamination, and the physical boundaries of the contamination by obtaining the detailed data necessary to determine the key contaminants and contaminant movement. The key contaminants will be selected based on persistence and mobility in the environment and the degree of hazard. The key contaminants will be evaluated for receptor exposure and an estimate made of the key contaminant levels reaching human or environmental receptors. Existing standards and guidelines, including drinking water standards, water quality criteria, and other criteria accepted by EPA Region 4 as appropriate, will be used to evaluate effects on human receptors who may be exposed to the key contaminant(s) exceeding appropriate standards or guidelines.
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The RI report format will generally follow the format as presented in the SOW for Task 9, Remedial
Investigation Report. The report will consist of several voluminous appendices including, but not
limited to: field reports including boring logs; and well installation logs, field test data; analytical
data results; graphics used to perform the data analyses; human health risk assessment tables; toxicity
profiles for constituents of concern; and other information well suited for inclusion in an RI report
appendix.
It is anticipated that three copies of the draft RI report (including appendices) andseven copies of
the final RI report (including only those changes to the appendices that resulted from the review of
the draft report) will be furnished to EPA.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
2.11 Task 10 - Remedial Alternative Screening This task will involve work efforts to develop and screen remedial alternatives for the site. It is
anticipated that remedial alternatives will be developed and screened for both soil and groundwater
at the site in accordance with the National Contingency Plan (N.P.) and the Guidance for
Conducting Remedial Investigations and Feasibility Studies Under CERCLA (OWNER Directive
9355.3-01, October 1988). Other appropriate OWNER directives concerning remediation of
groundwater contamination at Superfund sites will be consulted during this task, including Guidance
on Remedial Actions for Contaminated Groundwater at Superfund Sites (OWNER 9283.1-02,
December 1988); Considerations in Ground Water Remediation at Superfund Sites (OWNER
9355.4-03, October 18, 1989; OWNER 9283.1-06, May 27,1992). Hazardous waste management
alternatives investigated shall include those alternatives that will remedied or control exposure to
contaminated media remaining at the site as deemed necessary in the RI, to provide adequate
protection of human health and the environment.
The potential alternatives will encompass, as appropriate, a range of alternatives in which treatment
is used to reduce the toxicity, mobility, or volume of waste, but will vary in the degree to which
long-term management of residuals or untreated waste is required. One ormore alternatives involve
containment with little or no treatment; and a no-action alternative. Alternatives that involve
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Section: 2 Revision No. 0
Revision Date: December 21, 2000 Page 28 of 32
•
minimal efforts to reduce potential exposure (e.g., site fencing, dead restrictions) will be presented as "limited action" alternatives. Screening alternatives will be presented in a separate technical memorandum to include the following items:
• Development of remedial action objectives (RAO). RAOS will be developed to address contaminated media at the site. The RAOS will address the contaminants and media of concern, exposure routes and receptors, and the preliminary remediation goals.
• Development of general response actions. General response actions will be developed to satisfy the RAOS for the groundwater.
• Identification and screening of remedial technologies and process options. Technologies and process options will be identified for each general response action. Technologies and process options will be evaluated based on effectiveness, implementability, and costs.
• Development of remedial alternatives. Alternatives for the addressing soil^ groundwater, or other affected site media will be developed from the technologies and process options passing the screening in accordance with Section 300.430(e) of the N.P..
• Screening of remedial alternatives. The developed alternatives will be screened against the short- and long-term aspects of effectiveness, implementability, and cost.
The results of the remedial alternatives screening effort will be presented to EPA Region 4 in the Remedial Alternatives Screening Technical Memorandum. EPA Region 4's comments on the technical memorandum are to be incorporated into the Remedial Alternatives Evaluation described under Task 11.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
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2.12 Task 11 - Remedial Alternative Evaluation
This task will include the efforts to perform an evaluation of the remedial alternatives passing the
screening performed in Task 10. Guidance to be used will include that provided in the Guidance for
Conducting Remedial Investigations and Feasibility Studies under CERCLA (OSWER Directive
9355.3-01, October 1988) and other pertinent OSWER guidance. The nine N.P. evaluation criteria
are:
• Overall protection of human health and the environment.
• Compliance with applicable or relevant and appropriate requirement (ARAR).
• Long-term effectiveness and permanence.
• Reduction in toxicity, mobility, and volume through treatment.
• Short-term effectiveness.
• Implementability-technical and administrative.
• Cost.
• State acceptance: will be addressed by EPA Region 9 in the proposed plan
and/record of decision (ROD).
• Community acceptance: will be addressed by EPA Region 9 in the ROD following
the public comment period.
A detailed description of the alternatives will be prepared. Each description will outline the waste
management strategy involved, identify the key ARARs associated with each alternative, and provide
a discussion that profiles the performance of that alternative with respect to each of the first seven
of the nine N.P. evaluation criteria (40 CFR Part 300, March 8, 1990). The last two criteria, state
acceptance and community acceptance will be addressed by EPA Region 4 in the proposed plan
and/or ROD. The results of the individual alternative evaluations will be summarized in a table.
After the individual assessment is completed, a comparative analysis of the alternatives will be
conducted. The analysis will be performed in accordance with the N.P. and EPA guidance for
conducting RI/FSs. The results of the remedial alternative evaluation will be incorporated into the
draft FS report.
Work' Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RJCO-A4T9 RI/FS Barber Orchard Site
The LOE projected for this task is presented in Volume 2, along with the projected costs.
2.13 Task 12 - Feasibility Study Report This task will include preparation of the draft and final FS report consisting of a detailed analysis
of alternatives and cost-effectiveness analysis in accordance with Guidance for Conducting Remedial
Investigations and Feasibility Studies under CERCLA (OWNER Directive 9355.3-01, October 1988)
and the N.P. (330.68(h)(3)(I)(2), March 8, 1990). The FS report will contain the following: a
summary of alternative remedial actions in accordance with Chapter 3, N.P. 300.68(h)(3)(I)(2)(A);
cost analysis in accordance with Chapter 7, N.P. 300.68(h)(3)(I)(2)(B); institutional analysis in
accordance with Chapter 4, N.P. 300.68(h)(3)(I)(2)(C); public health analysis in accordance with
Chapter 5, N.P. 300.68(h)(3)(I)(2)(D); and environmental analysis in accordance with Chapter 6,
N.P. 300.68(h)(3)(I)(2)(E). The final FS report will incorporate EPA Region 4 comments on the
draft report. The FS report will include the following information:
• Executive summary
• Summary of background information for the site
• FS objectives
RADS
• Presentation of the general response actions
• Identification and screening of remedial technologies and process options
• Development and descriptions of remedial alternatives, with specific attention given
to the study of any problems that may prevent a remedial alternative from mitigating
site problems
• Detailed analysis of remedial alternatives against the seven criteria
• Comparative analysis of remedial alternatives against the seven criteria
• Summary and conclusions.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
Section: 2 Revision No.
Revision Date: December 21. 2000 Page 30 of 32
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Section: 2.0 Revision No. 0
Revision Date: December 21, 2000 Page 31 of32
2.14 Task 13-Post RI/FS Support
This task includes work efforts in support of the EPA's preparation of the ROD for the site. The
activities included in this task are as follows:
• Attendance by the Black & Veatch PM at two to three technical meetings or briefings
to be held at the EPA Region 4 offices
• Providing technical assistance that may be necessary in the preparation of the
responsiveness summary
• Providing limited technical assistance in the preparation of the Proposed Plan and
ROD.
• Providing assistance in preparing the FS addendum, should one be necessary.
Only a limited number of hours have been included in the estimate for any technical assistance or
other assistance in which the need is still speculative.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
2.15 Task 15 - Administrative Record
This task includes work efforts in support of the EPA's Administrative Record Coordinator for the
site. Specifically the activities included in this task will include:
• Coordination with Administrative Record Coordinator.
• Provide assistance in document compilation of all final plans prepared for the site.
• Prepare Administrative Record Index to include all documents prepared by IT
Corporation for the site.
The LOE projected for this task in accordance with the SOW is presented in Volume 2, along with
the projected costs.
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2.16 Task 16 - Work Assignment Closeout Work assignment closeout functions will be performed under this task when directed by the EPA
Region 4 RPM. Closeout functions include consolidation of the project records, preparation of
project file for storage, and return of any borrowed files, as well as administrative, technical, and
financial closeout, including minimal photocopying and duplicating, file indexing, microfilming of
project files, etc. A work assignment completion report (WACR) will also be prepared.
The LOE projected for this task is presented in Volume 2, along with the projected costs.
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3.0 SAFETY AND CONTINGENCY PLAN
Section: 3.0 Revision No. 0
Revision Date: December 21, 2000 Page 1 of 2
A site-specific health and safety plan (HASP) will be prepared for the site investigation, along with
a Task-Specific HASP to address site health and safety requirements for site visits for this project.
The HASPs will be prepared and submitted as part of the Project Planning and Support task
deliverables. Health and safety issues will be addressed in these HASPs in compliance with 40 CFR
300.150 of the N.P. and 29 CFR 1910.120 1(1) and (1)(2). The report will reference site-specific
health and safety criteria to be implemented and procedures to be followed for the pertinent field
activities.
As with any investigative or remedial planning project, problems and issues do arise that must be
resolved to complete the project in a timely manner. The following contingency plan has been
developed to address such areas of concern. Several potential issues have been listed to demonstrate
how these issues will be addressed during the course of the work assignment. While this list is not
all-inclusive of the problems or issues that may arise, it offers guidance on how such areas of
concern will be handled.
Contingency Plan
Potential Issue
Subtask elements of this work assignment that are not fully scoped at this time.
Changes in program functions.
Scheduled RI work does not detect all "contaminated areas."
Access to areas proposed for field activities is not granted in a timely manner or refused.
Response
Commence work efforts and revise the work plan and cost estimates in a timely manner for negotiations with the EPA.
Consult with EPA RPM, and Black & Veatch program personnel, as appropriate, and incorporate new guidance into project deliverables.
Work with EPA RPM to scope additional efforts in a timely manner (which are likely to be conducted during remedial design efforts).
Work with EPA RPM to adjust the field data collection program in a timely manner so as to minimize the adverse impact to field activities.
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-R1CO-A4T9 RI/FS Barber Orchard Site
Section: 3.0 Revision No. 0
Revision Date: December 21, 2000 Page 2 of2
•
Potential Issue
Community objections to approach or to the proposed WP.
Data to be used to perform the risk assessments or to screen remedial alternatives are not suitable for intended use.
Response
Work with EPA RPM to prepare alternative recommendations or support efforts to justify actions to the community, or both.
Work with EPA RPM to quickly scope a revised work effort to collect useable data.
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4.0 QUALITY CONTROL MEASURES
Work activities on this assignment will be conducted in accordance with the procedures defined in
both the Black & Veatch QA plan and the IT Corporation QA plan. The Black & Veatch QA Plan
defines the authority, responsibilities, and procedures for QC. Following internal review by the IT
Corporation QA review team, all major deliverables will be reviewed by Black & Veatch. The
comments of the review teams will be incorporated into deliverables before submission to the EPA.
This procedure should expedite the EPA's review of submittals by ensuring technical quality of both
draft and final deliverables.
The IT program QA/QC manager will be responsible for the management and performance of their
internal review process. The QA/QC manager will also audit work performed in conjunction with
this work assignment. The results of any audits performed on this work assignment will be
submitted to the internal RAC 4 program manager, with copies provided to Black & Veatch and the
EPA RPM. The audit report will contain a brief description of the audit; identification of
compliance status, problems, and non-conformance; and analysis of corrective action status if
appropriate.
The Black & Veatch PM is ultimately responsible for the QC activities for this work assignment.
The PM is responsible for verifying that the work meets the QA requirements associated with the
assignment and will maintain the project QC reports and reviews.
IT QC personnel, as necessary, will consist of an independent reviewer, project reviewer, and a
flexible, multidisciplinary review team able to provide input in their areas of specialization. Unless
specified herein, independent review of deliverables will be conducted to ensure they are accurate,
easy to understand, and free of typographical and mathematical errors. As necessary, the project
reviewer will participate in both project planning and review of deliverables. The project reviewer
may also provide input during telephone conferences arranged to discuss review comments. All
records and reviews will be maintained in accordance with the QA plan by the PM. Following are
Section: 4.0 Revision No. 0
Revision Date: December 21, 2000 Page 1 of3
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Section: 4.01 Revision No. 0
Revision Date: December 21, 2000 Page 2 of3
the review requirements for the work assignment deliverables that will apply to both Black & Veatch
and IT.
Document/Deliverable
RI/ FS Work Plan
Health & Safety Plan(s): Site- and Task-Specific
Quality Assurance Project Plan
Field Sampling Plan
Data Management Plan
Pollution Control and Mitigation Plan
Risk Assessment Plan
Human Health Risk Assessment Report
Ecological Risk Assessment Report
Remedial Investigation Report
Remedial Alternatives Screening
Technical Memorandum
FS Report
Responsiveness Summary Assistance
Proposed Plan and ROD Assistance
FS Addendum Assistance
Administrative Record Index
Work Assignment Closeout Report fWACR)
NOTE: 0 = Optional Review
Discipline Review
0
0
0
0
0
0
0
R
R
R
0
R
0
0
R
0
R
R = Require
Project Review
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
d Review
Independent Review
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
4.1 Quality Assurance Project Plan (QAPP)
A QAPP will be prepared in accordance with EPA QA/R-5. The QAPP will summarize the QA and
QC objectives and protocol utilized to achieve the DQOs at the facility.
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4.2 Data Management Plan (DMP)
The elements of a data management plan will be prepared to define the procedures that will be used to track, store, and retrieve data and will also identify the software to be used, minimum data requirements, data format, and backup data management. The Draft data management plan will address both data management and document control for the RI/FS activities as described in the SOW for the investigation. The data management plan will be submitted as a separate section within the sampling and analysis plan.
3 4 00
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RJCO-A4T9 Rl/FS Barber Orchard Site
5.0 PROJECT MILESTONES
5.1 Project Schedule
The project schedule will follow the schedule outlined in the SOW for this work assignment.
Deliverable dates for document review comments and other support services will be based on
individual documents and agreed to by the EPA RPM, the Black & Veatch PM, and the IT PM.
Figure 5-1 illustrates the proposed project schedule for this work assignment.
Figure 5-1
Project Schedule
Barber Orchard RI/FS
Start
10/12/00
10/31/00
12/01/00
11/13/00
01/12/01
02/17/01
01/02/01
02/17/01
05/01/01
05/21/01
05/20/01
05/21/01
Finish
10/12/00
10/31/00
01/11/01
12/23/00
02/16/01
04/30/01
02/16/01
04/30/01
05/20/01
07/11/01
06/20/01
05/26/01
Duration
(days)
1
1
40
40
35
72
45
72
19
51
30
6
Description
Scoping meeting
Site walk
Draft RI/FS WP preparation/submittal
Draft site-specific WP preparation/submittal
EPA RI/FSWP review/comment
Final R1FSWP preparation/submittal
EPA site-specific WP review/comment
Final site-specific WP preparation/submittal
EPA WP approval/notice to proceed
Phase I Field Investigation
Procurement
Site reconnaissance/property access/well inventory |
Section: 5.0 Revision No. 0
Revision Date: December 21, 2000 Page 1 of 5
Work Plan, Volume 1 - Technical Approach EPA Contract No. 68-W-99-043 Work Assignments 034-RICO-A4T9 Rl/FS Barber Orchard Site
Start
05/28/01
06/04/01
07/09/01
06/18/01
07/24/01
08/13/01
08/13/01
08/18/01
09/05/01
09/06/01
10/18/01
10/29/01
01/03/02
01/25/02
01/02/02
03/03/02
03/14/02
02/09/02
04/10/02
04/26/02
05/17/02
06/26/02
Finish
06/01/01
07/07/01
07/11/01
07/23/01
08/12/01
09/05/01
08/21/01
09/05/01
09/08/01
10/18/01
10/28/01
01/02/02
01/24/02
02/08/02
03/02/02
03/13/02
03/24/02
04/09/02
04/25/02
05/16/02
07/17/02
07/09/02
Duration
(days)
5
34
3
36
19
22
9
19
4
43
10
64
21
15
60
10
10
60
15
21
60
14
Description
Mobilization/set up temporary facilities
Soil boring/monitoring well installation
Monitoring well survey
Laboratory analysis
Preliminary data evaluation
Phase II Field Investigation
Monitoring well/potable water well sampling
Soil, sediment, surface water sampling
Demobilization/remove temporary facilities
Laboratory analysis / data validation
Data evaluation Summary report
Draft RI report (including baseline risk assessment)
EPA draft RI report review/comment
Final RI report
Draft remedial alternatives technical memorandum
EPA technical memorandum review/comment
Final remedial alternatives technical memorandum
Draft FS report
EPA FS report review/comment
Final FS report
Post RI/FS support
Work assignment closeout
•
Section: 5.0 Revision No. 0
Revision Date: December 21, 2000 Page 2 of 5
•
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Start
10/12/00
Finish
08/09/02
Duration
(days)
667
Description
Project Management
5.2 Project Deliverables
Specific project deliverables as defined in the SOW, along with the projected dates of submission and the number of copies to be submitted, are as follows:
Project Deliverable
Draft RI/FS Work Plan - Volume I
Draft RI/FS Work Plan - Volume II
Final RI/FS Work Plan
Draft Health and Safety Plan
Final Health and Safety Plan
Draft Sampling and Analysis Plan
Final Sampling and Analysis Plan
Draft Quality Assurance Project Plan
Final Quality Assurance Project Plan
Draft Field Sampling Plan
Final Field Sampling Plan
Draft Data Management Plan
Final Data Management Plan
Draft Pollution Control and Mitigation Plan
Final Pollution Control and Mitigation Plan
Projected Date of Submission
12/22/00
01/12/01
2/08/01
12/22/00
02/15/01
12/22/00
2/15/01
12/22/00
2/15/01
12/22/00
2/15/01
12/22/00
2/15/01
12/22/00
2/15/01
Number of Copies
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
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Section: 5 Revision No. 0
Revision Date: December 21, 2000 Page 4 of 5
Project Deliverable
Draft Risk Assessment Plan
Final Risk Assessment Plan
Draft Baseline Risk Assessment Report
Final Baseline Risk Assessment Report
Draft Remedial Investigation Report
Final Remedial Investigation Report
Draft RA Screening Technical Memo
Final RA Screening Technical Memo
Draft Feasibility Study Report
Final Feasibility Study Report
Administrative Record Index
Work Assignment Closeout Report
Projected Date of Submission
12/22/00
2/15/01
12/22/01
1/30/02
12/22/01
1/30/02
2/20/02
3/15/02
4/02/02
5/08/02
6/08/023
7/08/02
Number of Copies
3
3
3
7
3
7
3
7
3
7
3
3
Submittal dates for all final documents are based on receiving EPA Region 4 comments within the time frames specified on the project schedule presented as Figure 5-1.
Other project deliverables that require EPA input or approval, but that are not specified in the SOW, are as follows:
Individual subcontracting documents for services to be performed by others as outlined in Section 7.0, Subcontractors/Consultants
Monthly status reports, including financial as well as performance information
Responsibility for the preparation and securing of access rights to properties that will be affected by the proposed field activities
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Communications with the Florida Department of Health and Department of Environmental Protection and the local health departments/commissions
Responses to comments from EPA review of documents scheduled as deliverables.
Management procedures necessary for evidentiary considerations.
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6.0 COST ESTIMATE
The estimated project budget is based on projected LOE hours and other cost considerations. Volume 2 of this work plan provides a detailed cost estimate by task and subtask for the activities anticipated for the RI/FS, along with the assumptions used to compile these estimates.
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7.0 SUBCONTRACTORS/CONSULTANTS
The services of several subcontractors are required based on the present scope of work.
Subcontractors that will be solicited by competitive bidding and used to perform various services
for this assignment under either lump sum (LS) contracts with unit price adjustments or unit price
(UP) contracts, are as follows:
Activity
Drilling/monitoring well installation
Field surveying activities
IDW disposal
Procurement
Competitive Bid
Competitive Bid
Competitive Bid
Contract Type
UP
LS
LS
Pool subcontracting performed by IT will be coordinated through the Black & Veatch PM, who will
communicate with the EPA RPM and the EPA contracting officer to ensure that all contract
requirements are satisfied. If qualified small business/small disadvantaged business/woman owned
business (SB/SDB/WOB) contractors or equipment suppliers are available in the vicinity of the site,
they will be afforded every opportunity to participate in the solicitation for the above services. The
intent of IT is to use qualified SB/SDB/WOB contractors for those services to be procured outside
of the team members' capability, providing they are cost-effective. IT will supervise and manage all
subcontracted services and monitor their performance for compliance with the SOW and the RAC
4 contract.
3 4 0074
APPENDIX A
EPA STATEMENT OF WORK
> .
3 4 0075
September 1,2000
• >
STATEMENT OF WORK FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY
B A R B E R ORCHARD SITE, H A Y W O O D COUNTY, N O R T H CAROLINA
ATTACHMENTS Attachment 1. Summary of Major Submittals far the Remedial Investigation and Feasibility Study 18 Attachment 2. Work Breakdown Structure .". 21 Attachment 3. Regulation and Guidance Documents 28 Attachment 4. Transmittal of Documents for Acceptance by EPA 30 Attachment 3. Transmittal Register 31 Attachment 6. Existing documents pertaining to the Site 32
1 0 Introduction
,0.1 Site Description The site, approximately 300 acres, is located off of US Hwy 74 approximately 3 miles west of WaynesviUe,
\ j k Haywood County, North Carolina. The site was historically used as agricultural land (i.e.. apple orchard) ^NT from the carry 1900«s until the late 1980**. Currently, parte of the site are a residential development. An
emcregency response was completed in August 2000. This emergency response remediated those 0^ V properties developed as residents that contained levels of arsenic in the surface soils grater than 40 mg/kg.
v j fl ID addition to arsenic, the following compunds are also potential chemicals of concern: lead, DDT, DDE, dieldrin, alpha-BHC, beta-BHC, endrin, and endrin ketone.
.0.2 Purpose The purpose of this Statement of Work (SOW) is to set forth the requirement for conducting a Remedial Investigation^easlbility Study (RI/FS) to select a remedy to eliminate, reduce, or control risks to human health and the environment. This SOW is designed to provide the framework fix conducting the RI/FS activities at the Barber Orchard Site (site). The goal i$ to develop the minimum amount of data necessary to support the selection of an approach for site remediation and then to use this data that results in a wett-supported Record of Decision (ROD) within twenty (20) months after approval of the Project Management and Work Plans. The estimated completion date for this work assignment is June 30,2002.
.0 J General Requirements .0.3.1 The contractor shall conduct the RI/FS in accordance with this SOW and all other relevant
guldanccTisedirCTA4a-conducting-an J U / F S ^ - ^ assignmentJa_ Jon Bornholm, Tel. 404.562-8820; the secondary contact is Phil Vorsatz, Tel. 404-562-8789.
.0.3.2 A summary of the major deliverables and a suggested schedule tor submittals are attached (Attachment 1). The contractor shall submit the major deliverable* using the form Transmittal of Documents for Acceptance by EPA. Attachment 4.
.0.3.3 Specifically, the RI/FS Involves the investigation and study properly that was contaminated with pesticides when it was used as an apple orchard from the early 1900*s through the late 1980*8. Part of the orchard has been developed into residential properties.
.0.3.4 The contractor shall furnish all necessary and appropriate personnel, materials, and cervices needed for, or incidental to, performing and completing the ROTS.
,0.3.5 A list of primary guidance and reference material is attached (Attachment 3). In all cases, the ' contractor shall use the most recently issued guidance. .0.3.6 The estimated cost of the RMFSTs"$800700ClL I .0.3.7 The contractor shall communicate at least weekly with the Work Assignment Manager or
Remedial Project Manager (WAM/RPMX either iu face-to-lace mettinp oi through conference calls.
1 RI/FS SOW (9/1/00)
3 4 0076 This information shall be used to determine if any additional data are needed for RI/FS implementation. The documents available for review are listed in Attachment 6.
.1.1.4 Develop Technical Project Goals and Objective*. The contractor shall prepare data needs and data quality objectives (DQOs) tor analytical sampling to be performed during RI/FS. the goals and objectives should be used to define the analytical methods and protocols, decontamination procedures, and EPA reporting ievds (e^., I, Jl, HI, IV) required, (1) Not used - Develop Conceptual Site Model (2) Identify Preliminary Project Requirements
(a) Data Needs and DQOs (b) Not used - Objectives A Potential Alternatives (c) Not used-PossibleTreatability Studies (d) Not used -ARAJti and/or Standards (e) Not used • NEP A Requirements <f) Not used- Other Regulatory RequirerMrus/Rertrictions (g) Not used - Prepare Conceptual Exposure Pathway Analysis
.1.1.5 Develop Work Plan. The contractor shall present the general approach that will be used for the RI/FS at a Work Plan scoping meeting witk the WAM/RFM. This meeting will be hetd at the Region 4 office, (1) Develop Draft Work Plan. The contractor shall prepare and submit a draft RI/FS Work Plan
within 30 calendar days after initiation of the Work Assignment (WA). Submit the original to the Contracting Officer (CO) and two copies to the Project Officer (POX The Work Plan shall include a comprehensive description of the additional data collection and evaluation of 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 submittal shall also be included. The Work Plan shall be developed in conjunction with the Sampling and Anar/su Plan (SAP) and Health and Safety Plan (HASP), although each plan shall be delivered under separate cover within 30 calendar days after Initiation of the WA. (a) Develop Narrative. Specifically, the Work Plan shall present the following:
- A statement of the probtetn(s) and potential problem(s) posed by the she and how the objectives of the RWS will address the problem^).
• A background summary setting forth: (1) a brief description of the site including the geographic location and a description of the physiographic, h^dmlogic, geelogk. demographic, ecological, cultural, and natural resource features of the site; (?) a brief synopsis of the history of the site including a summary of past disposal practices and a description of previous responses that nave been conducted by local. State, Federal, or private parties at the site; (3) a summary of the existing data Including physical and chemical characteristics of the contaminants identified and their distribution among the environmental media at the site.
- The contractor's technical and management approach Co each task to be performed, -indudlnra detafled-descriotion of each task; the assumptions used; thctdcngficatlon of any tre*"*^ uncertainties (with a proposal for the resolution of those uncertainties); the information needed for each task; arry information to be produced during and at the conclusion of each task; and a description of the work products that will be submitted to EPA, The contractor shall identify any subcontractors H plane to use to accomplish all or pan of a task's objectives. Tasks and subtasks shall be presented in the same WBS format as provided in this work assignment
- A schedule lor specific dales for the startand completion of each required activity and submission of each deliverable required by this SOW. This schedule shall also include information about timing, initiation, and completion of all critical path milestones for each activity and deliverable and the expected review time for EPA.
(b) Develop Cost Estimate, The contractor's estimated cost to complete the work assignment IhlljlebluleeiroSwJnr^^ Work Breakdown Structure (Attachment 2) and submitted to EPA on disk.
(c) Internal QA and Submission of Draft Work Plan. (2) Prepare Final Work Plan
3 RI/FS SOW (9/1/00)
•
3 4 0077 (2) Prepare and Submit Invoices
.1.3.2 Meeting Participation and Routine Communications. The contractor shall attend project meetings, provide documentation of meeting results, and shall contact the WAM by telephone on a weekly basis to report project statua. >
.1.3.3 Maintain Cost/Schedule Control System. The contractor shall develop and maintain a system to monitor and control the costs and schedule of the Work Assignment The contractor shall specify the process to continuously update the information in the system as "a result of engineering network analyses and changing field condition! The system shall have the capability to compare technical progress with expenditures and predict completion dates and cost to complete information.
.1.3.4 Perform Value Engineering
. 1,3,5 Perform Engineering Network Analysis
.1.3.6 Manage, Track, and Report Equipment Status. The contractor shall manage, track, and report the status of all rite>spedfic equipment
.1.3.7 Project Ooseout. The contractor shall perform the necessary activities to doseout the work assignment in accordance with contract requirements.
.1.4 Subcontract Procurement and Support Activities .1.4.1 Idendflcarion and Procurement of Subcontractors. Procure and administer the necessary
subcontract*, including, but not limited to me following: (1) Drilling Subcontractor (2) Surveying Subcontractor (3) Geophysical Subcontractor (4) Site Preparation Subcontractor (5) Analytical Services Subcomractord) (6) Wane Disposal Subcontractor (7) Treatability Subcontractor(i) <8)Othetti)
.1.4.2 Establish and Carry Out a QA Program for Subcontract!
.1.4 J Perform Subcontract Management
2,2 Community Relation*
The contractor shall provide community relations support to EPA throughout the RI>. The contractor shall provide community relations suppon In accordance wim Community Motions In SuptrflmiL- A Handbook, June 1988. Community relations shall include the following subuuks:
2.1 Develop Community Relations Plan (CRP) The contractor shall develop a CRP IO address community relations requirements during RI/FS. This CRP may be modified from an existing CRP to meet ske-cpedfk requirements. .2.1.1 Conduct Community Interviews. The contractor shall assist the WAM/RPM in conducting
ccnunitnit^tcrvlewito-identtfy-Doinmii^ The contractor shall assiat the WAM/RPM In identifying key community member*, establishing an interview schedule, conducting interviews, and summarizing results.
2.12 Prepare the CRP. Tto connector sTiaUprepmUw CRP to addxewcon^ requirements and community concern} doling the RI/F& (I) Draft CRP. The contractor shall submit a draft CRP within 14 days after completion of the
community interviewa. <2) Final CRP. Within 7 days of receipt of EPA comments, the contractor shall submit the final
CBF. 22 Prepare Fact Sheets. The contractor shall prepare a tact sheet that informs the public about activities
related to the final design, a schedule for the RA, activities to be expected during construction, provisions for responding to emergency releasee and spills, and any potential inconveniences such as excess traffic and noise that mayaflect toe community during tne KA.
23 Public Bearing, Meetings, and Availability Support The contractor shall support and assist in public bearings, meeting!, and open houses. The contractor shall prepare presentation materials and provide
5 RJ/PS SOW (9/1/00)
3 4 0078 % 5 1 Perform Site Reconnaissance. The contractor shall conduct site surveys including property
boundary, utility rigbtt-of-vrcy. and topographic information. These surveys are to ensure the accuracy o f existing inferroatioo for the RI/FS. (1) Ecological Resource! Reconnaissance
(a) Well Inventory y (b) Residential Well Sampling (c) Land Survey (d) Topographic Mapping (e) Field Screening
3.2.2 Conduct Geological Investigatioos (Soils and Sediments) (1) Collect Surface Soil Samples (2) Cc41ect Subsurface Soil Samples P ) Soil Boring and Permeability Sampling (4) Collect Sediments Samples (5) Survey Soil Oases (6) Test Pit
3J.3 Conduct Air Investigations (1) Sample ColleerioA (2) Air Monitoring Station
.3.2.4 Conduct Hydrogeoiogical Investigations; Ground Water (1) Install Well Systems
(a) Accomplish Mobllizatioii (b) Develop Wells (c) Conduct Dcwahofe Geophysics (d) Install Monitoring Weill (e) Install Test Wells (f) Install Gas Watts
(2) Collect Samples (3) Collect Samples During Drilling (e.g.. HydroPunch or EqulvalenO (4) Conduct TMal Influence Study (5) Perform Hydraulic Tests (Pump Tests) (6) Measure Ground-Water Elevation
j .2 .5 Conduct Hydrogeoiogical lirvestigationr Sur&ce Water (1) Collect Samples (2) Study Tidal Influeacsi (3) Measure Surfhce-Water Elevation
3.26 Omduct Waste Investigation (1) Collect Samples (Gas. Liquid. Solid) (2) Dispose of Derived Waste (Gas, liquid. Solid)
^^^-^iidoct^GcophyticmlJnvffflgMion (1) Surface Gcophysfc*1 ActMty lean Just list these] (2) Magnetometer (3) Electromagnetics (4) Ground-fenetraung Radar (3) Seismic Refraction (6) Resistivity (7) Site Meteorology (5) Cone Penetrometer Survey (9) Remote Sensor Survey (10) Radiological Investlgadon
3 3.t Conduct Ecological Investigation "LJ~ (lyWclland and Habltalttelinestfon
(2) Wildlife Observations (3) Community Characterization (4) Identification of Endangered Species
RI/PS SOW (9/1/00)
3 4 0079 (1) Organic (2) Inorganic (3) Radiochemiitty
.4.2.3 Analyze Surface-Water Samples (1) Organic (2) Inorganic (3) H»dk»Jwmiatiy
.4.2.4 Analyze Soil and Sediment Samples <1) Organic (2) tonrgairic (3) Radiochftiiuatiy
r**5—Aualjitt Waste (CM) Sainuka • (1) Organic
(2) Inoignnfe <3>Radbchrmljtsy
?fcW—Aiiajya Wane (Liquid) Samptot (l)Oigaillc (g)Iuoigaaic (3) Radnjcbcjnbtty
•**9—Aiialjm Waste (Oulld) DaiiyUj (1) Organic
• (2) Iwoiaaate (3) RadJechaBfatty
.4.2,8 AnaJyw Biota Samples (1) Crganfc (2) Inorganic
• (3) RadwUtcoriatry .4.2.9 Analyze Bioassay Samples .4.2.10 Perform BioaccumulHion Studiea
&S Analytical Support and Data Validation
The contractor shall arrange for the validation of environmental samples collected during the previous task. The sample validation task begins with reserving sample slots in the CLP and the completion of the field ssraptliif program. This task ends with the contractor validating the analytical data rcccrvod from the laboratory. The contractor will perform appropriate data validation to ensure that the data are accurate and defensible.
The contractor stun perform the following activities or combination of activities to validate test results: J . j Prepare and Ship Environmental Samples
^±i—Ground-Watorfiaippka .5.1.2 Surface and Subsurface SoD Samples ,5.1J Surface-Water and Sediment Sarnpkt J . 1.4 Air Samples .5.1.5 Biota Samples .5.1.6 Other Types of Media Sampling and Screening
.5.2 Coordinate with Appropriate Sample Management Personnel ,5J Implement EPA-Aporovcd Laboratory QA Program. J.4 Provide Sample Management (Chain of Custody. Sample Retention, and Data Storage)
Ensure the proper management of samples. Ensure accurate chaln-of-custody procedures for sample tracking, protective sample packing techniques, and proper sarople-prescrvatioo technique*.
.3 5 Validate Data .5.5.1 Review Analysis Results Against Validation Criteria .5.5.2 Provide Written Documentation of Validation Efforts
RI/FS SOW (9/1/00)
3 4 0030
develop reasonable maximum estimates of exposure for both current land use conditions and potential land use conditions at the site.
(6) Risk Characterization. During risk characterization, chemical-specific toxicity information, combined with quantitative and qualitative information tram the exposure assessment, shall be compared to measured levels of contaminant exposure levels and the levels predicted through environmental fate and transport modeling. These comparisons shall determine whether concentrations of contaminants at or near the site arc affecting or could potentially affect human health.
(7) Identification ofLimitatk>nsAJscertainties. The contractor shall identify critical assumptions (e.g., background concentrations and conditions) and uncertainties in the report
(8) Site Conceptual Model Based on contaminant identification, exposure assessment, toxicity assessment, and risk characteriiation, the contractor shall develop a cooaptuil model of the tile.
.7.1.2 Final Human Health Risk Assessment Report After the draft Human Hcahh Risk Assessment Report has been reviewed and commented on by EPA, rbe contractor will incorporate EPA comments and submit the dual Human Health Risk Assessment Report
.12 Ecological Risk Assessment The contractor shaU evaluate and assess the risk to feenvtroiunem posed by aiecontamkantt .7.1.I Draft. Ecological Risk Assessment Report Prepare a draft Ecological Risk Assessment Report that
addresses the following: (1) Hazard Identification (sources). The contractor shall review available information on the
hazardous substances present at tha site and identify the major contaminants of concern. (2) Dose-Response Assessment Contaminants of concern should be selected based on (heir
intrinsic tnxicologlcai properties. (3) Prepare Conceptual Exposure/Pathway Analysis. Critical exposure pathways (e.g.. surface
water) shall be identified and analyzed. The proximity of contaminants to exposure pathways and their potential to migrate Into critical exposure pathways shall be assessed.
(4)CluuacierizationofSiteandPottnualRecepten. The contractor shall identify and characterize environmental exposure pathways.
(5) Select Chtmicalt, indicator Spedet. and End Points. In preparing the assessment, the contractor will select representative chemicals, indicator species (specks that are especially sensitive to environmental contaminants), and end points on which to concentrate.
(6) Exposure Assessment The exposure assessment will identify the magnitude of actual or environmental exposures, the frequency and duration of these exposures, and the routes by which receptors are exposed. ThecxpoeureasscssroemBhaJluxiude an evaluation of the livelihood of such exposures occurring and shall provide the basis for the development of acceptable exposure levels. In developing the exposure assessment, the contractor shall develop reasonable maximum estimates of exposure for bolh current land use conditions and potential land use conditions at the site.
pyToxidf/ A»»cs*rocatrea3ogicat:EilitcttTto«essm^ Bepgmettf yfl| %Mrt?M the typea of adverse environmental effects assoriatnri with chemical exposures, the relationships between magnitude of exposures and adverse erTeota, and the related uncertainties for contaminant toxicity (e.g,, weight of evidence for • chemical's carclnogrnlrhy).
(8) Risk Characterization. During risk characterization, cruunicsJ-apcdflc toxJdr/ information, combined with quantitative and qualitative information from the exposure assessment, shall be compared to measured levels of contaminant exposuit levels and to levels p i o l s ^ u^roug* environmental fate and transport modeling. These ct>nu?s U¥ms shall delermbMvAether concentrations of contaminants at or near the site are aSecttag « c«dd {xxettlalfy sJtec* to environment
(9) MfnriftcarJon of LlFp'w'^^'^-^lBJnt'tl. T*« eo»mctor shall identify critical assumptions ( e j . , background concentrations and conditions) and uncertainties in the report
(10) Site Conceptual Model. Based on contaminant identification, exposure assessment, texteuy assessment, and risk characterization, the contractor shall develop a conceptual model of the tits.
11 RI/FS SOW (9/1/DO)
3 4 0081
.7.3.4 Retrieve Sample for Testing. The contractor shall obtain samples for testing as specified in the Treatability Work Plan.
.7.3.5 Perform Laboratory Analysis. The contractor shall establish a field laboratory to facilitate fast-turnaround analysis of test samples, or, if necessary, shall procure outside laboratory services to analyze the test samples and evaluate testresults.
.7.3.6 Characterize and Dispose of Residuals .7.4 Pilot-Scale Test
- .7.4.1 Procure Test Facility and Equipment. The contractor shall procure test facility and equipment, including the procurement procedures necessary to acquire the vendor, equipment, or utility to execute the tests.
.7.4 J Provide Vendor and Analytical Service
.7.4.3 Test and Operate Equipment The contractor shall test equipment to ensure operation, then start up and operate equipment
.7.4.4 Retrieve Sample for Testing. The contractor shall obtain sample* for testing as specified in the Treatability Work Plan.
.7.4.3 Perform Laboratory Analysis. The contractor shall establish a field laboratory to facilitate fast-turnaround analysis of test samples, or, if necessary, shall procure outside laboratory services to analyze the test samples and evaluate test results.
.7.4.6 Characterize and Dispose of Residuals .7.5 field Teat
.7.3.1 Procure Test Facility and Equipment The contractor shall procure test facility and equipment, including the procurement procedures necessary to acquire the vendor, equipment or facility to execute the teste.
.7 J 2 Provide Vendor and Analytical Service
.7.3.3 Test and Operate Equipment The contractor shall test equipment to ensure operation, then start up and operate equipment
.7.5.4 Retrieve Sample for Testing. The contractor shall obtain samples for testing as specified in the Treatability Work Plan.
.7.5.5 Perform Laboratory Analysis. The contractor snail establish a Add laboratory to facilitate mat-turnaround analysis of test samples, or. if necessary, shall procure outside laboratory services to analyze the test samples and evaluate lest results.
.7.5.6 Characterize and Dispose of Residuals .7.6 Develop Treatability Study Report
Thirty (30) days after completion of the Treatability Study, the contractor shall prepare and submit the Treatability Study Evaluation Report that describes the performance of the technology. The study results shall clearly indicate the performance of the technology or vendor compared with the perfomairastarKiards established for the site The report shall also evaluate the treatment technology's effectiveness, ImplementabUity. cost and final results compared with the predicted results. The report shall also evaluate full-scale application of the technology, including * serisitivity-anaJysis4deruiryiagsliea:eyi>arameten
•
2.9 Remedial InveitlgarJeo Report
The Contractor shall develop and deliver a Remedial Investigation (RQ report that accurately establishes the site characteristics such as media contaminated, extent of contamination. and the physical boundaries of the contamination. Pursuant to this objective, the contractor shall obtain only the minimally essential amount of detailed data necessary to determine the key(s) contaminants) movement and extent of contamination. The key contarninant(s) must be selected based on persistence and mobility in the environment and the degree of hazard. The key contaminanl(s) identified in the Rl shall be evaluated for receptor exposure and an estimate of the key contaminants) level reaching human or environmental receptors must be made. The contractor shall nse existing m„,fard> and guidelines such aa drinking-water standards, water-quality criteria, and other criteria accepted by the EPA as appropriate for the situation may be used to evaluate effects on human recepton who may be exposed to the key contaminants) above appropriate standards or guidelines.
13 RI/FS SOW (9/1/00)
3 4 0 0 8 2
should take into account requirements for proteclivcness as identified in the remedial action objectives and die chemical and physical characteristics of the site.
10 I 3 Identify & Screen Applicable Remedial Technologies. The contractor shall identic and screen technologies based on the developed general response action*. Hazaidous waste treatmeot technologies should he identified and screened to ensure that only those technologies applicable to the contaminants present, their physical matrix, and other site characteristics will be considered This screening will be based primarily on a technology's ability to etrectrvdy address the contaminants at the site, but will also take into account a technology's implementabilrty and cost. The contractor will select representative process options, as appropriate, to cany forward into alternative development The contractor will identify the need for treatability testing for thon technologies that are probable candidates for consideration during the detailed analysie.
10 14 Develop Rcniec!ial Altematrva la acoortat»ce with NCP. 10 U Screen Remedial Alternatives for Effectiveness, ImpleroeotabiUty, and Cost The contractor shall
screen alternatives to identify the potential technologies or process c*tk>t* t r ^ vdU be combined into media-specific ot sitewide alternatives. The developed alternatives shall be defined with respect to size and configuration of the representative process options; lime tot remediation; rates of flow or treatment; spatial requirements; distances for disposal: and required P«nnh*. imposed limitations, and other factors necessary to evaluate the alternatives. If many distinct, viable options are available and developed, the Research Engineer will screen the alternatr^ that undergo the detailed analysis to provide me most promising process options. The dteroauvea should be screened on a general basis with respect to their eflecUvwess, imptementabUlty, and
102 Prepare STechmcsJMenu.iandum.Afkr EPA ren^ contractorwill iricorporattEPAcorrurienttardsubri^^
1.1 i Remedial AltenutHe* Evaluafiea
The contractor will conduct a detailed evaluation of alternatives.
.11.1 PcxfonnRemedialAltenutrivesEvaluation. ^ ^ ^ " ^ S ^ ^ ^ ^ k ' e ^ f f i ^ each alternative that outlines the waste management strategy tnvolved andjdentifie. the key ***** MsocWod with each alternative; and (2) a discussion that profiles the performance of that alternative wMh ^ t 7 e « h of the evaluation[criteria. The Research Engineer shall p r o v i n g ! * ^ leSoofthisanalyria. One* the individual analysis Is complete, the alternatives wjl be oMnpared. a*i contrasted to one another with respect to each of the evaluation criteria.
2.12 IS Report and RI/FS Report
Th. Contractor shall develop a Feasibility (FS) Report consisting of a detaUedaJuaysistfaiie^ I ^ S S ^ ^ ^ n W d a n c c w i t h ^ W 6 8 ( h X 3 X 0 O ) J h e J g P ^ «*"!! contalnaiMminary of
i f o S ^ m ^ a ^ m l c c T r o W with Chapter 3. NCP 300.68<h)P)( l )PX^» Coat Ana**, to
' £ £ n C wSrTSa^ NCP 300.«(h)C3X0(2KB); 3) ^ ^ ^ J ^ ^ ^ S S S a m t 5) J S 300.«WhK3)f.X3XC): 4) ' ^ ^ l ^ ^ ' S ^ S ^ S f f i 5 , 300-6S(W(3><,X2>(P* * Environmental analysis in accordance with Chapter «, NCP 300.«(bX3XiX2XW. 12.1 Prepare Draft ra Report The conrmctor shall prepare a draft F S a n d l ^ t l o E P A ^ c o r d i n g l o t h a
Sedule in the RI/FS work plan. The FS Report should contain the following. .12.1.1 SiumnarizaFeasibUiryShidyCtiKctivcs .12.1.2 Siunraarbei Remedial Ob}ectrve 111 J Artindate(3eneralRespoase Action
'jjj.* Identification A Screening of Remedial TechnologteB
121 shall mclpEthe carefulrtudy of any P ^ ^ ^ ^ J ^ 1 * Z ^ ^ ^ ^ ^ L m mitigating site problems. Therefore, the site eharscteristocs from the RI must be kept In mind as
w RlfPS SOW (9/t/OQ)
Attachment 1 Summary of Rtajor Submittal* for the Remedial Investigation/Feasibility Stody at
Barber Orchard Site
DDE DATE (calendar dan)
10 daw after site vtet
30 daw after tattation of work anigmcntfWAl
30 daw after iaitiatkm of WA
13 daw after neat* of EPA ownncntt
21 day! after approval of RI/FS Woric Plan
_ 10 dayt after receipt of EPA ooronealf
30 daw after Lmnoioa of WA
13 daw after receipt of EPA oaraienti
30 daw after initiation of W A
13 daw after itcdm of EPA aanraearj
(43) dan after iottajMefWA
As needed
EPA REVIEW PERIOD
7 daw after receipt of report
21 dan after receipt of Work Flam
11 day aftei leuuut of HASP
NA
14 days after receipt of SAP
NA
21 days after receipt of QAPP
NA
21 daw after receipt of PSP
NA
10 diyi after receipt of feet HKCL
CD CD CO
TASK.
111.1
1 1 1 !
1112
Diaft Fi Mobility Study Report
FimlFiMibi&rStndr Report
Summary of M iji
DELIVERABLE RET
Attachment 1 (or Submittals for the Remedial Investigation/Feasibility Study at
Barber Orchard SHe (contlnned)
NO. OF corns
DUE DATE (ofaaartara)
(30) days after completion of Rcatedial AkeiMawtTechaicalMtawairtii
CM)daynftgcogplrtinnofRI
ClJdjwatorertpirfgA^oBmcgi^
EPA REVIEW TIRIOD
(15) days At icoeipt of evtinatkm
1 (13) d m retort
after receipt of
NA
CM
CD CD co
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21 Model RI/FS SOW (5/31/95)
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23 Modd RI/FS SOW (5/31/95)
3 4 0088
29. Quality in the Constructed Project; A Guideline foi Owners. Designers and Constructors, Volume 1. Preliminary Edition for Trial Use and Comment. American Society of Civil Engineers, May 1988.
30. Remedial Design and Remedial Action Handbook, U.S. EPA. Office of Emergency and Remedial Response. June 1993, OSWER Directive No. 9333.3-22.
31. Revision of Policy Regarding Superfund Project Assignments, OSWER Directive No. 9242 3-08, December 10,1991. [Guidance, p. 2-2]
32. Scoping the Remedial Design (Fact Sheet), February 1993, OSWER Publ. 9335-5-21FS. 33. Standard Operating Safety Guides, U.S. EPA. Office of Emergency- and Remedial Response, November 1984 34. Standards for the Construction Industry. Code of Federal Regulations, Title 29, Part 1926 Occupational
Health and Safety Administration. 33. Standards tor General Industry, Code of Federal Regulations. Title 29, Part 1910, Occupational Health and
Safety Administration. 36. Structure and Components of 3-Year Reviews, OSWER Directive No. 9353.742, May 23,1991. [Guidance.
p. 3-3J 37. Superftind Guidance on EPA Oversight of Remedial Designs and Remedial Actions Performed by Potentially
Responsible Parties, April 1990. EPA/34O/G-90/001. ^ 38. Superftind Remedial Design and Remedial Action Guidance. U.S. EPA, Office of Emergency and Remedial
Response, June 1986, OSWER Directive No. 9353.0-4A. 39. Superftind Response Action Contracts (Fact Sheet), Msy 1993, OSWER PubL 9242.2-08TS. 40. TLVs-Threshold Limit Values and Biological Exposure Indices for 1987-88, American Conference of
Governmental Industrial Hygienlsts, 41. Treatability Studies Under CERCLA, Final. U.S. EPA, Office of Solid Waste and Emergency Restxrase.
EPA/540VR-92A>71a, October 1992. / « - » « — , 42. USEPA Contract Laboratory Program Statement of Work for Inorganic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, July 1988. 43. USEPA Concract Laboratory Program Statement of Work for Organic Analysis, U.S. EPA, Office of
Emergency and Remedial Response, February 1988. 44. User's Guide to the EPA Contract Laboratory Program, U.S. EPA, Sample Management Office, August 1982. 45. Value Engineering (Fact Sheet), U.S. EPA, Office of Solid Waste and Emergency Response, Publication
9333 J.03FS, May 1990. * ^ ^ ^ "
28 Model M/FS SOW (3/31*3)
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Attachment 6
Index of Existing File* ftom Emergens Response
3 4 0090