revised final remedial investigation/feasibility study ... · document dated july 26, 2005, upon...

21
SITL )Ai/)S liAh^/^ OTHER: \r Revised Final Remedial Investigation/Feasibility Study Work Plan Davis Timber Site Hattiesburg, Lamar County, Mississippi July 26, 2005 ^ ' "-- 10655911

Upload: others

Post on 12-Jul-2020

1 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

SITL )Ai/)S liAh^/^

OTHER:

\r

Revised Final Remedial Investigation/Feasibility Study

Work Plan

Davis Timber Site Hattiesburg,

Lamar County, Mississippi

July 26, 2005

^ ' "--

10655911

Page 2: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

Remedial Investigation/Feasibility Study Work Plan

Volume 1 - Technical Approach Davis Timber Superfund Site

Hattiesburg, Lamar County, Mississippi

U.S. EPA Work Assignment No. 348-RIRI-A4P6 Black i& Veatch Project No. 48348.101

Prepared under EPA Contract No. 68-W-99-043

July 26,2005

Prepared by

Black & Veatch Special Projects Corp. 1145 Sanctuary Parkway, Suite 475

Alpharetta, Georgia 30004

Except for data contained on all pages of Volume 2 ofthis dociunent, it is agreed that as a condition of award of this contract, and notwithstanding the conditions of any notice appearing hereon, the Govemment shall have unlimited rights (as defined in Contract No. 68-W-99-043) in and to the technical data contained in this document dated July 26, 2005, upon which this work assignment is based.

Page 3: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No. ;348-RIRI-A4P6 Volume 1 Black & Veatch ProjectNo. 48348.101 July 26,2005

Contents

Volume 1 - Technical Approach

1.0 Introduction 1 1.1 Site Location and Background 1 1.2 Purpose and Scope ofWork 2

2.0 Technical Approach 4 2.1 Overview 4 2.2 Task 1 - Project Planning and Support ; 5 2.3 Tasks - Data Acquisition 6 2.4 Task 6 - Data Evaluation 7

' 2.5 Task 7 - Risk Assessment 8 2.6 Task 9 - Remedial hivestigation Report (Update) 8 2.7 Task 10 - Remedial Altematives Screening 10 2.8 Task 11 - Remedial Altematives Evaluation 11 2.9 Task 12 - FS Report and RI/FS Report 11 2.10 Task 13 - Post RI/FS Support 12 2.11 Task 14 - Negotiation Support 13 2.12 Task 15 - Administrative Support 13 2.13 Task 16 - Work Assigrmient Closeout 13

3.0 Contingency Plan 14

4.0 Quality Control Meastires 15 4.1 Technical Goals and Objectives 16

5.0 Project Milestones 17 5.1 Project Schedule 17 5.2 Project Deliverables 17

6.0 Cost Estimate 19

7.0 Exceptions to Assigimient, Anticipated Problems, and Special Requirements 20

Page 4: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No.: 348-RIRI-A4P6 Volume 1 Black & Veatch ProjectNo. 48348.101 July 26, 2005

1.0 In t roduc t ion

The United States Enviroimiental Protection Agency (EPA), tmder the authority of the

Comprehensive Envirormiental Response, Compensation and Liability Act of 1980

(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986

(SARA), has initiated a Remedial Investigation (RI)/ Feasibility Study (FS) at the Davis

Timber site located in Hattiesburg, Lamar County, Mississippi.

Black &, Veatch v/as initially tasked with conducting the Human Health Risk Assessment

(HHRA), as part of the ongoing Remedial Investigation (RI). Since this initial work was

initiated, the need for additional Black & Veatch support has been identified. An Interim

Work Plan was submitted in order to begin work on some ofthe additional tasks that were

scoped in the September 2004 Statement of Work (SOW). This document, the Final RI/FS

Work Plan, is intended to present an approach and proposed budget to meet the project

objectives. Contents ofthis document include previously scoped elements ofthe RI/FS (Task

1 - Project Planning and Support and Task 7 - Assessment of Risks); Interim Work Plan

Tasks; and the additional tasks that were scoped in the September 2004 SOW. A copy ofthe

SOW including additional scoped tasks is included in Appendix A.

This work plan for the RI/FS at the David Timber Site has been prepared by Black & Veatch

Special Projects Corp. (Black & Veatch) under Contract Number 68-W-99-043 with EPA

Region 4 and imder specific authorization of EPA Region 4 through Work Assignment

Number 348-RIRI-A4P6.

\ A Site Locat ion and Background

The Davis Timber Superfund Site is a former timber processing and wood preserving facility

located in Hattiesburg, Mississippi. The facility was operated by the Davis Timber Company

from 1972 imtil the late 1980's. The site is approximately 30 acres and consists of a skag

mill, pole peeler and debarker, closed holding pond, an office, treating cylinder, closed

cooling pond, oil separator, two abovegrotmd oil storage tanks, two aboveground

pentachlorophenol solution storage tanks, and a storage yard.

Page 5: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.; 68-W-99-043 Work Assignment No.: 348-RIRI-A4P6 Black & Veatch ProjectNo. 48348.101

Final RI/FS Work Plan Volume 1

July 26,2005

< • Task 3 -• Task 9 -• Task 10 • Task 11 • Task 12 • Task 13 • Task 14 • Task 15 • Task 16

Data Acquisition Remedial Investigation Report. - Remedial Altematives Screening. - Remedial Altematives Evaluation. - FS Report - Post m/FS Support. - Negotiation Support. - Administrative Record - Work Assignment Closeout

During the work assigrmient scoping meeting conducted October 28,2004, it was agreed that

to expedite the process an interim work plan would be prepared. Upon evaluation ofthe site,

the SESD Draft RI, and the data that has been collected since the Draft RI, a full (non-

interim) RI/FS Work Plan will be submitted. After the scoping meeting, the RPM requested

that initiation ofthe FS begin where appropriate. Tasks included in the Interim Work Plan

include the following; however, no additional LOE or funds have been requested for Task 7.

Task 1 - Project Planning and Support

Task 3 - Data Acquisition Task 7 - Risk Assessment

Task 9 - Remedial Investigation Report. Task 10 - Remedial Altematives Screening.

Tasks included in this non-interim RI/FS Work Plan include the follovsdng; however, no

additional LOE or funds have been requested for Task 7.

Task 1 - Project Planning and Support

Task 3 - Data Acquisition Task 7 - Risk Assessment

Task 9 - Remedial Investigation Report. Task 10 - Remedial Altematives Screening. Task 11 - Remedial Altematives Evaluation. Task 12 - FS Report Task 13 - Post RI/FS Support. Task 14 - Negotiation Support. Task 15 - Administrative Record Task 16 - Work Assignment Closeout

Page 6: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Work Assignment No.: 348-RIRI-A4P6 Black & Veatch Project No. 48348.101

Final Rl/FS Work Plan Volume 1

July 26, 2005

2.0 Technical Approach

2.1 Overview

This section ofthe work plan describes the technical approach to tasks to be performed imder work

assignment in providing technical support to EPA. Work descriptions, where appropriate, indicate

the technical approach and assumptions that will impact the estimated level of effort (LOE) the most.

Tasks outlined in the EPA's September 21,2004, SOW have been incorporated into this work plan

under the appropriate tasks described below. The work to be performed under this Interim Work

Plan wall consist ofthe following tasks:

Project Planning and Support (Black & Veatch Task 48348.101) Data Acquisition (Black & Veatch Task 48348.103) - Data Evaluation (Black & Veatch Task 48348.0106) Risk Assessment (Black & Veatch Task 48348.107) Remedial hivestigation Report (Black & Veatch Task 48348.109) - Remedial Altematives Screening. (Black & Veatch Task 48348.110) - Remedial Altematives Evaluation. (Black & Veatch Task 48348.111) - FS Report (Black & Veatch Task 48348.112) - Post RI/FS Support. (Black & Veatch Task 48348.113) - Negotiation Support. (Black & Veatch Task 48348.114) - Administrative Record. (Black & Veatch Task 48348.115) - Work Assignment Closeout (Black & Veatch Task 48348.116)

These task numbers correspond to the EPA work breakdown stmcture (WBS) for the RAC program

for performing 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 RI/FS activities;

however, only work activities=a;^ociated with the 12 tasks listed above are scoped. These tasks, as

described within the EPA SOW, will be performed under Black & Veatch Project Number 48348 as

discussed below.

' J . .

{•

Task 1 -Task 3 -Task 6 -Task 7 -Task9-Task 10 Task 11 Task 12 Task 13 Task 14 Task 15 Task 16

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 v^th the interim work

plan activities are included in Volume 2 of this work plan.

Page 7: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No.: 348-RIRI-A4P6 Volume 1 Black & Veatch ProjectNo. 48348.101 July 26, 2005

Preparation and submittal ofthe conflict of interest (COI) disclosure. Evaluation of existing site information. Conducting a site visit! Development of technical project goals and objectives. Development of a draft and final interim work plan (including any negotiations). Development of a draft and final work plan (including any negotiations). 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. The Technical

Status reports will summarize the followdng:

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 followdng 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.

Schedule status reports will summarize the following information:

Project tasks with plaimed and actual start and completion dates. Planned and actual dates for milestones and submittals.

This Work Plan includes costs through June 16, 2006; as reflected on the Work Assignment Form.

This information is presented in Volume 2 with the projected costs.

2.3 Task 3 - Da ta Acquisition

This task includes conducting a well inventory and an evaluation of existing information regarding

hydrogeology in the area and making a determination ofthe potential threat to groundwater. One of

the most important aspects ofthis task is to determine if an additional subsurface investigation is

needed to verify that the groundwater supply is not being impacted by the site. This task includes

researching literature on the local hydrogeology (which was completed under the interim budget).

Some ofthis information was originally intended to be obtained from SESD; however, to date, that

Page 8: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No.: 348-RIRI-A4P6 Volume! Black & Veatch ProjectNo. 48348.101 July 26,2005

• Evaluate Hydrogeological Data (Groundwater and Surface Water). • Evaluate Waste Data*. • Evaluate Geophysical Data**. • Evaluate the Ecological Data.

* - It is assumed waste data pertains only to the nine soil samples collected by SESD from

the onsite impoundment.

** - Geophysical data described in the Draft RI Field Effort has not been available for

review. It is proposed that evaluation of geophysical data be removed from the scope of

this Work Plan.

The LOE projected for the data evaluation is presented in Volume 2 along with the

projected costs.

2.5 T a s k 7 - R i s k Assessment

This task is not included in the revised SOW; however, a Baseline Human Health Risk Assessment

was included as a task from the original SOW. The Draft Baseline HHRA was submitted to EPA for

review on April 14, 2005; and was prepared in accordance with criteria listed in the original EPA

SOW.

It should be noted that SESD is completing an Ecological Risk Assessment for this project. It is

assumed that the Ecological Risk Assessment will be supplied by SESD and incorporated into the RI

as an Appendix.

LOE for this task are included in the original Statement of Work and carryover budget from the previously approved budget are included in Volume 2.

2.6 Task 9 - Remedia l Investigation R e p o r t (Update)

Draft RI Report update preparation activities will commence as additional information becomes

available. As part ofthe Draft Interim Work Plan, updates ofthe geological and hydrogeological

portions ofthe RI were initiated under the interim budget. The objective of updating Draft RI report

is to address those items identified in the September 21,2004 SOW to accurately establish the site

characteristics such as the media contaminated, extent of contamination within the focused

investigation area, and the physical boundaries of contamination by obtaining only the minimal

8

Page 9: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contracf No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No.; 348-RIRI-A4P6 Volume 1 Black & Veatch Project No. 48348.101 July 26, 2005

It is anticipated that 5 copies ofthe draft (including appendices) and 10 copies ofthe final RI Report

(including only those changes to the appendices that resulted from the review ofthe draft issue) will

be fiimished to EPA.

The LOE projected for the interim portion of the task are presented in Volume 2 along with the

projected costs.

2.7 Task 10 - Remedia l Al ternat ive Screening This task will involve work efforts to develop and screen remedial altematives for the site. Remedial

altematives will be developed and screened in accordance with the National Contingency Plan (NCP)

and the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA

(OSWER Directive 9355.3-01, October 1988). Hazardous waste management altematives

investigated shall include only those altematives that will remediate or control contaminated media

remaining at the site as deemed necessary in the RI, to provide adequate protection of human health

and the environment. The altematives shall include a range of altematives to reduce the toxicity,

mobility, or volume of wastes but vary in the degree to which long-term management of residuals or

untreated waste is required, one or more altematives involving containment with little or no

treatment and a no-action altemative. Altematives that involve minimal efforts to reduce potential

exposures (e.g. fencing, deed restrictions) will be presented as "limited action" altematives. As part

ofthe non-interim work plan, the following items will be included in a draft Technical Memorandum

presenting the potential remedial altematives:

• Development of remedial action objectives (RAOs). RAOs will be developed to address the contaminated groundwater, soil, surface water, and sediment at the site. The RAOs will address the contaminants and media of concem, 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 sediment only.

• 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 altematives. Altematiyes for the sediment will be developed from the technologies and process options passing the screening in

10

Page 10: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No. :348-RIRI-A4P6 Volume 1 Black & Veatch Project No. 48348.101 July 26, 2005

Summary of remedial action objectives.

Presentation ofthe general response actions.

Identification and screening of remedial technologies and process options.

Detailed analysis of remedial altematives.

Detailed analysis of remedial altematives.

Summary and Conclusions

Upon receipt of EPA comments, a Final FS report will be prepared that addresses the EPA

comments and submitted to the agency.

2.10 Task 13 - Post RI /FS R e p o r t

This task includes work efforts in support ofthe EPA's preparation ofthe Record of Decision

(ROD) for the site. The activities included in this task are as follows:

• Attendance at technical meetings, briefings, and technical meetings. Assumes

meetings (2 persons) to be held in Hattiesburg, Mississippi (assumes 2 meetings).

• Prepare Presentation Materials.

Provide technical assistance - Responsiveness Summary.

• Provide technical assistance - Proposed Plan and ROD.

• Prepare Feasibility Study Addendum should one be necessary.

Only a limited number of hours have been included in the cost estimate for any technical

assistance or other assistance related to this task since the need is speculative. It is assumed that

an FS Addendum will not be necessary; however, should one be required a variance request will

be submitted.

The LOE projected for the post RI/FS support task is presented in Volume 2 along with the projected

costs.

12

Page 11: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Work Assignment No.: 348-RIRI-A4P6 Black & Veatch Project No. 48348.101

Final RI/FS Work Plan Volume 1

July 26, 2005

3.0 Contingency Plan

As with any investigative or remedial planning project, problems and issues do arise that must be resolved in order to complete the project in a timely manner. The following contingency plan has been developed to address such areas of concem. Several potential issues have been listed to demonsfrate 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 concem will be handled.

Contingency Plan

Potential Issue

Subtask elements ofthis work assignment that are not fiilly scoped at this time.

Changes in program fiinctions.

Previous RI work does not detect all "contaminated areas"

Data to be used to perform the risk assessment or to screen remedial alternatives are not suitable for intended use.

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 quickly scope a revised work effort to collect useable data.

14

Page 12: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No.: 348-RIRI-A4P6 Volume 1 Black & Veatch ProjectNo. 48348.101 July 26,2005

4.0 Qual i ty Cont ro l Measures

Work activities on this assignment will be conducted in accordance with the procedures

defined in the Black & Veatch Corporate Quality Assurance (Q A) Plan. Our Q A Plan defines

the authority, responsibilities, and procedures for quality control. All major deliverables will

be reviewed by the quality assurance review team assembled for each specific task of this

assignment. The comments ofthe review team 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 Black & Veatch RAC 4 program quality assurance/quality confrol (QA/QC) manager will

be responsible for the management and performance of our intemal 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 our RAC 4

program manager with copies provided to the EPA RPM. The audit report will contain a brief

description ofthe audit; identification of compliance status, problems, and non-conformance;

and analysis of corrective action status if appropriate.

The Black & Veatch PM is responsible for the quality confrol 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 quality confrol reports and

reviews. The PM, in conjunction with the program QA manager, will appoint a review team

leader (RTL) for the deliverables to be submitted as part ofthis work effort.

QC personnel, as necessary, will consist of an independent reviewer, project reviewer, and a

flexible, multi disciplinary 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 at meetings or telephone

conferences arranged to discuss review comments. Review of deliverables will ultimately be at

the discretion ofthe PM and always in response to specific requests by the EPA RPM. All

15

Page 13: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Work Assignment No.: 348-RIRI-A4P6 Black & Veatch ProjectNo. 48348.101

Final RI/FS Work Plan Volume 1

July 26,2005

5.0 Project Milestones

5.1 Pro jec t Schedule

The project schedule and deliverable dates for submittals will follow the schedule as agreed

upon between the EPA RPM and the Black & Veatch PM. Figure 5-1 illustrates the proposed

project schedule for diis work assignment.

5.2 Pro jec t Deliverables

Specific project deliverables as discussed with the EPA RPM in the October 28,2004 scoping

meeting along with the projected dates of submission and the number of copies to be submitted

are presented below.

Other project deliverables that require EPA input or approval but that are not specifically called

out in the SOW are as follows:

Monthly status reports including financial as well as performance information. Response to comments from EPA review of documents scheduled as deliverables. Management procedures necessary for evidentiary considerations.

Figure 5-1

Project Deliverable

Draft Interim RI Work Plan

Final Interim RI Work Plan

Meeting with SESD

Draft RI Work Plan

Projected Date of Submission

11/11/04

15 work days after receipt of EPA comments

Originally planned to be Arranged/Coordinated by the EPA RPM; however, the meeting did not occur.

Originally planned for 45 work days after meeting with SESD; however, the meeting did not take place.

Number of Copies

3

3

NA

3

17

Page 14: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

EPA Contract No.: 68-W-99-043 Final RI/FS Work Plan Work Assignment No.: 348-RIRI-A4P6 Volume 1 Black& Veatch Project No. 48348.101 July 26,2005

6.0 Cost Estimate

The estimated project interim 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, along with the assumptions used to compile these estimates.

19

Page 15: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

L

EPA Contract No.:68-W-99-043 Final RI/FS Work Plan Work Assignment No.: 348-RIRI-A4P6 Volume 1 Black & Veatch Project No. 48348.101 July 26, 2005

7.0 Exceptions to Assignment, Anticipated Problems, and Special

( Requirements !

, At this time, nothing is foreseen that allows a prediction of effects on projected LOE hours, I budget, or time frames described in this plan other than those items noted in Section 2.3 and

Section 2.5 of this document, and speculative need for subtasks in Task 13 and Task 14. Some components ofthe included tasks are dependent upon receipt of additional data and elecfronic copies of existing documents. If other unforeseen factors arise, or if the current scope of work is changed, adjustments will be made to accommodate those changes. It is understood that such changes require the approval of the EPA contacting officer.

20

Page 16: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

APPENDIX A

EPA STATEMENT OF WORK

Page 17: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

09/21/04

STATEMENT OF WORK FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY

DAVIS TIMBER SITE, LAMAR COUNTY, HATTIESBURG, MISSISSIPPI

1.0 Introduction

.0.1 Site Description

The Davis Timber site is a former timber processing and wood preserving operation faciiity in Hattiesburg, Mississippi, that was operated by the Davis Timber Company from 1972 until the late i980's. Wastewater, containing pentachlorophenol, dioxin and furan compounds, was discharged into an onsite storage pond, which was reportedly backfilled and capped in 1980.. Prior to closing this pond, pentachlorophenol (PCP) and dioxin contaminated wastewater was released into surface water drainage pathways. Between 1974 and 1987, several fish kills in Country Club Lake, one mile downgradient of the facility, were reported. Pentachlorophenol, dioxins and furans have been detected at elevated levels in onsite soils and also in sediments in Mineral Creek and Country Club Lake. The site was finalized bn the NPL in July 2000.

The state of Mississippi has collected fish from Country Club Lake seven times since 1987, and analyzed the fish tissue for dioxin compounds. Upon obtaining the first set of fish tissue data, MDEQ issued a notice to local residents (in 1989) recommending that fish firom Country Club Lake not be consumed . Dioxin levels in fish have decreased significantly over the last ten years. In June 2001, the state of Mississippi lifted its ban on the consumption of fish caught in waters near this site.

The Remedial Investigation, conducted by EPA, began in May 2000. Four field efforts took place between 2000 and 2002 to characterize on-site soils, creek and lake sediments, surface water, and groundwater. Analytical results from the RI sampling events indicate the presence of contamination (predominandy dioxins and semi-volatile compounds) in the on-site soils, at the former PCP impoundment, and in sediments. The sediment contamination is predominantly in East Mineral Creek.

In July 2002, EPA prepared a report compiling all data collected during the RI, which summarized findings and conclusions of the sampling investigation. Ecological.and human health risk assessments for the site are currently being conducted. EPA anticipated finalizing both assessments by December 20O4. The ecological risk assessment is being finalized by EPA, and the human health risk assessment is being conducted by Black & Veatch. The next step in the remedial process will be to finalize the feasibility study and propose a cleanup strategy for the site.

.0.2Purpose The purpose of this Statement ofWork (SOW) is to set forth the requirement for finalizing a Remedial Investigation (RI) and conducting a Feasibility Study (FS) to select a remedy to eliminate, reduce, or control risks to human health and the environment. This SOW is designed tb provide the framework for conducting the RI/FS activities at the Davis Timber Site. The goal is to develop the minimum amount of data necessary to support the selection of ari approach for site remediation, and then to use this data that results in a well-supported Record of Decision (ROD). The estimated completion date for this work assignment is September 30, 2004.

.0.3 General Requirements .0.3.1 The contractor shall conduct the RI/FS in accordance with this SOW and all other relevant

guidance used by EPA in conducting an RI/FS. The primary contact for this work assignment is Amy Williams, Tel. 404-562-8776.

.0.3.2 The contractor shall furnish all necessary and appropriate personnel, materials, and services needed for, or incidental to, performing and completing the RI/FS.

.0.3.3 The contractor shall communicate at least weekly with the Work Assignment Manager or Remedial Project Manager (WAM/RPM), either in face-to-face meetings or through conference calls.

.0.3.4 The contractor shall notify the WAM/RPM when 75 percent of the approved work assignment budget has been expended and when 95 percent has been expended.

.0.3.5 The contractor shall documerit all decisions that are made in meetings and conversations with EPA. The contractor shall forward this documentation to the WAM/RPM within two working days of the meeting or conversation.

.0.3.6 EPA will provide oversight of contractor activities throughout the RI/FS. EPA review and approval of deliverables is a tool to assist this process and to satisfy, in part, EPA's responsibility to provide effective protection of public health, welfare, and the environment.

Page 18: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

geologic, demographic, ecological, cultural, und natural resource features of the site; (2) a brief synopsis of the history of the site including a summary of past disposal practices and a description of previous responses that have been conducted by local. State, Federal, or private parties at the site; (3) a siunmary of the existing data including physical and chemical characteristics of the contaminants identified and their distribution among the environmentarmedia at the site. The contractor's technical and management approach to each task to be performed, including a detailed description of each task; the assumptions used; the identification of any technical uncertainties (with a proposal for the resolution of those uncertainties); the information needed for each task; any 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 it plans to use to accomplish all or part of a task's objectives. Tasks and subtasks shall be presented in the same WBS format as provided in this work assignment. A schedule for specific dates for the start and completion of each required activity ahd 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 shall be broken down into the Level of Effort (by P-level) and cost for each element of the Work Breakdown Structure and submitted to EPA on disk.

(c) Intemal QA and Submission of Draft Work Plan. (2) Prepare Final Work Plan

(a) Attend Negotiation Meeting. The contractor shall attend a Work Plan negotiation meeting at the Region 4 office.

(b) Modify Draft Work Plan and Cost Estimate. If the contractor finds that the planned RI/FS cannot meet any ARAR, the contractor shall describe the issue and recommend technical solutions in a memo to the WAM/RPM. The contractor shall make revisions to the Work Plan as a result of EPA's comments and/or negotiation agreements.

. 1.2 Site Management Plan (not needed).

. 1.3 Project Management .1.3.1 Prepare Periodic Status Reports. The contractor shall prepare Monthly Progress Reports.

(1) Document Cost and Performance Status. The contractor shall document the status of each task and report costs and level of effort (by P-level) expended to date.

(2) Prepare and Submit Invoices . 1.3.2 Meeting Participation and Routine Conununications. 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 status.

.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 conditions. The system shall have the capability to compare technical progress with expenditures and predict completion dates and cost tp 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 site-specific equipment.

. 1.3.7 Project Closeout. The contractor shall perform the necessary activities to closeout the work assignment in accordance with contract requirements.

.1.4 Subcontract Procurement and Support Activities (not needed).

2.2 Conununity Relations (not needed)

2.3Data Acquisition The contractor shall conduct a well inventory and an evaluation of existing information regarding hydrogeology in the area to make a determination of the potential threat to groundwater.

2.4 Sample Analysis (not needed)

2.5 Analytical Support and Data Validation (not needed)

Page 19: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

health and the environment. The objectives should specify the contaminant(s) and media of concem, the exposure route(s) and receptor(s), and an acceptable contaminant level or range of levels for each exposure route (i.e., preliminary remediation goals).

. 10.1.2 Establish General Response Actions. The contractor will develop general response actions for each medium of interest by defining contaminant, treatment, excavation, pumping, or other actions, singly or in combination to satisfy remedial action objectives. The response actions should take into account requirements for protectiveness as identified in the remedial action objectives and the chemical and physical characteristics of the site.

. 10.1.3 Identify & Screen Applicable Remedial Technologies. The contractor shall identify and screen technologies based on the developed general response actions. Hazardous waste treatment technologies should be 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 effectively address the contaminants at the site, but will also take into account a technology's implementability and cost. The contractor will select representative process options, as appropriate, to carry forward into altemative development. The contractor will identify the need for treatability testing for those technologies that are probable candidates for consideration during the detailed analysis.

. 10.1.4 Develop Remedial Alternatives in accordance with NCP.

. 10.1.5 Screen Remedial Altematives for Effectiveness, Implementability, and Cost. The contractor shall screen altematives to identify the potential technologies or process options that will be combined into media-specific or sitewide altematives. The developed altematives shall be defined with respect to size and configuration of the representative process options; time for remediation; rates of fiow or treatment; spatial requirements; distances for disposal; and required permits, imposed limitations, and other factors necessary to evaluate the altematives. If many distinct, viable options are available and developed, the Research Engineer will screen the altematives that undergo the detailed analysis to provide the most promising process options. The altematives should be screened on a general basis with respect to their effectiveness, implementability, and cost.

. 10.2 Prepare Final Technical Memorandum. After EPA review of the draft Technical Memorandum, the contractor will incorporate EPA comments and submit the final Technical Memorandum.

2.11 Remedial Alternatives Evaluation

The contractor will conduct a detailed evaluation of alternatives.

.11.1 Perform Remedial Altematives Evaluation. The evaluation shall include: (1) a technical description of each altemative that outiines the waste management strategy involved and identifies the key ARARs associated with each altemative; and (2) a discussion that profiles the performance of that altemative with respect to each ofthe evaluation criteria. The Research Engineer shall provide a table summarizing the results of this analysis. Once the individual analysis is complete, the altematives will be compared and contrasted to one another with respect to each of the evaluation criteria.

2.12 FS Report and RI/FS Report

The Contractor shall develop a Feasibility (FS) Report consisting of a detailed analysis of altematives and cost-effectiveness analysis in accordance with NCP 300.68(h)(3)(i)(2). The report shall contain a summary of altemative remedial actions in accordance with Chapter 3, NCP 3C)0.68(h)(3)(i)(2)(A); 2) Cost Analysis in accordance with Chapter 7, NCP 300.68(h)(3)(i)(2)(B); 3) Institutional analysis in accordance with Chapter 4, NCP 300.68(h)(3)(i)(2)(C); 4) Public-health analysis in accordance with Chapter 5, NCP 300.68(h)(3)(i)(2)(D); 5) Environmental analysis in accordance with Chapter 6, NCP 300.68(h)(3)(i)(2)(E).

. 12.1 Prepare Draft FS Report. The contractor shall prepare a draft FS and submit to EPA according to the schedule in the RI/FS work plan. The FS Report should contain the following: .12.1.1 Summarizes Feasibility Study Objectives .12.1.2 Summarizes Remedial Objective .12.1.3 Articulate General Response Action .12.1.4 Identification & Screening of Remedial Technologies .12.1.5 Remedial Altematives Description . 12.1.6 Detailed Analysis of Remedial Altematives. The contractor's technical feasibility

considerations shall include the careful study of any problems that may prevent a remedial alternative from mitigating site problems. Therefore, the site characteristics from the RI must be kept in mind as technical feasibility ofthe altemative is studied. Specific items to be

Page 20: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

Revised Final Remedial Investigation/Feasibility Study Work Plan

Volume 2 - Confidential Business Information Davis Timber Superfund Site

Hattiesburg, Lamar County, Mississippi

EPA Work Assignment No. 348-RIRI-A4P6 Black & Veatch Project No. 48348.101

July 26, 2005

Prepared By

Black & Veatch Special Projects Corp. 1145 Sanctuary Parkway, Suite 475

Alpharetta, Georgia 30004

Except for data contained on all pages of Volume 2 ofthis document, it is agreed that as a condition of award ofthis contract, and notwithstanding the conditions of any notice appearing hereon, the Government shaU have unlimited rights (as defined in Contract No. 68-W-99-043) in and to the technical data contained in this document dated July 26,2005, upon which this work assignment is based.

Page 21: REVISED FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY ... · document dated July 26, 2005, upon which this work assignment is based. ... Timber site located in Hattiesburg, Lamar

r Please note: Due to CONFIDENTIAL nature, "Revised Final Remedial Investigation/Feasibility Study Work Plan, Volume 2 - Confidential Business Information, Davis Timber Superfund Site, Hattiesburg, Lamar County, Mississippi," Black & Veatch Special Projects Corp. has been withheld. Withheld material is available for. Judicial review only, at EPA Region IV, Atlanta, Georgia.