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RI01635DF
Superfund Rtcordipoundenier DRAFT FINAL BREAK WORK PLAN OTHER
ENGINEERING EVALUATIONCOST ANALYSES
MOHAWK TANNERY SITE NASHUA NEW HAMPSHIRE
RESPONSE ACTION CONTRACT (RAC) REGION I
For US Environmental Protection Agency
By Tetra Tech NUS Inc
EPA Contract No 68-W6-0045 EPA Work Assignment No 055-NSEE-01C7
TtNUS Project No N4024
May 2001
TETRA TECH NUS INC
RI01635DF
DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSES
MOHAWK TANNERY SITE NASHUA NEW HAMPSHIRE
RESPONSE ACTION CONTRACT (RAC) REGION
For US Environmental Protection Agency
By Tetra Tech NUS Inc
EPA Contract No 68-W6-0045 EPA Work Assignment No 055-NSEE-01C7
TtNUS Project No N4024
May 2001
Diane M Baxter George DjuGardner PE Project Manager Program Manager
DRAFT FINAL
TABLE OF CONTENTS DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
SECTION PAGE
10 INTRODUCTION 1-1 11 Work Assignment Objectives 1-1 12 Work Plan Organization 1-1
20 SITE BACKGROUND 2-1
30 SCOPE OF WORK 3-1
40 TASK PLAN DESCRIPTION 4-1 41 Task 0100 - Project Planning and Support 4-1
411 Subtask0110-Project Planning 4-2 412 Subtask 0120-Prepare Site-Specific Plans 4-4 413 Subtask 0130-Project Management 4-6 414 Subtask 0140 - Subcontractor Procurement and Support
Activities 4-7 42 Task 0300 - Data Acquisition 4-8
421 Subtask 0310 - MobilizationDemobilization 4-9 422 Subtask 0321 -Site Surveys 4-10 423 Subtask 0322 - Geological Investigations 4-10 424 Subtask 0323 - IDW Disposal 4-16
50 PROJECT MANAGEMENT 5-1 51 Project Organization 5-1 52 Project Schedule 5-1 53 Quality Assurance and Data Management 5-2 54 Project Costs 5-2
60 EQUIPMENT AND SUPPLIES 6-1
Proposed Sample Summary
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4-14
DRAFT FINAL
TABLE OF CONTENTS (continued) DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
FIGURES
NUMBER PAGE
2-1 Site Location 2-2 2-2 Site Sketch 2-4 5-1 Project Organization 5-3
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DRAFT FINAL
10 INTRODUCTION
This Draft Final Work Plan - Base Period was prepared by Tetra Tech NUS (TtNUS) at the
request of the US Environmental Protection Agency (EPA) under Contract No 68-W6-0045
Work Assignment No 055-NSEE-01C7 This document describes the technical scope of work
and proposed schedule for conducting tasks to support an Engineering EvaluationCost
Analysis and associated field investigations at the Mohawk Tannery Site in Nashua New
Hampshire This work plan describes the tasks to be completed during the base period of
Contract No 68-W6-0045 which ends August 28 2001 A separate work plan (Draft Work
Plan - Option Period) describes the tasks to be performed during the contract option period
(August 29 2001 through the projected period of performance for this work assignment -June
2002)
This Work Plan was developed based on an EPA Statement of Work (SOW) dated January
26 2001 discussions with EPA at the kickoff meeting held at TtNUS Wilmington office on
February 12 2001 EPAs comments on the Draft Work Plan discussed during a fact-finding
teleconference on April 27 2000 and subsequent discussions with the EPA Work Assignment
ManagerRemedial Project Manager (RPM)
11 Work Assignment Objectives
The work assignment objectives are (1) to conduct an Engineering Evaluation and Cost
Analysis (EECA) to select a remedy to eliminate reduce or control risks to human health and
the environment posed by contaminated wastessludge contained in the lagoons and disposal
areas at the Mohawk Tannery Site and (2) to plan and perform a field investigation to collect
necessary data to support the EECA The overall goal of the work assignment is to develop
an EECA that will result in a well supported Action Memorandum for the site
12 Work Plan Organization
This Work Plan contains six sections Section 10 provides an introduction Section 20
presents site background information Section 30 details the Scope of Work Section 40
describes the specific tasks to be undertaken Section 50 provides a proposed project
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DRAFT FINAL
management approach and Section 60 identifies the equipment and consumable supplies
that may be required to perform the specified activities
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20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
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DRAFT FINAL
1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
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FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
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30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
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DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
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411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
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4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
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DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
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DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
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42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
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DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
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DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
RI01635DF
DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSES
MOHAWK TANNERY SITE NASHUA NEW HAMPSHIRE
RESPONSE ACTION CONTRACT (RAC) REGION
For US Environmental Protection Agency
By Tetra Tech NUS Inc
EPA Contract No 68-W6-0045 EPA Work Assignment No 055-NSEE-01C7
TtNUS Project No N4024
May 2001
Diane M Baxter George DjuGardner PE Project Manager Program Manager
DRAFT FINAL
TABLE OF CONTENTS DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
SECTION PAGE
10 INTRODUCTION 1-1 11 Work Assignment Objectives 1-1 12 Work Plan Organization 1-1
20 SITE BACKGROUND 2-1
30 SCOPE OF WORK 3-1
40 TASK PLAN DESCRIPTION 4-1 41 Task 0100 - Project Planning and Support 4-1
411 Subtask0110-Project Planning 4-2 412 Subtask 0120-Prepare Site-Specific Plans 4-4 413 Subtask 0130-Project Management 4-6 414 Subtask 0140 - Subcontractor Procurement and Support
Activities 4-7 42 Task 0300 - Data Acquisition 4-8
421 Subtask 0310 - MobilizationDemobilization 4-9 422 Subtask 0321 -Site Surveys 4-10 423 Subtask 0322 - Geological Investigations 4-10 424 Subtask 0323 - IDW Disposal 4-16
50 PROJECT MANAGEMENT 5-1 51 Project Organization 5-1 52 Project Schedule 5-1 53 Quality Assurance and Data Management 5-2 54 Project Costs 5-2
60 EQUIPMENT AND SUPPLIES 6-1
Proposed Sample Summary
RI01635DF I Mohawk Tannery NH
4-14
DRAFT FINAL
TABLE OF CONTENTS (continued) DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
FIGURES
NUMBER PAGE
2-1 Site Location 2-2 2-2 Site Sketch 2-4 5-1 Project Organization 5-3
RI01635DF II Mohawk Tannery NH
DRAFT FINAL
10 INTRODUCTION
This Draft Final Work Plan - Base Period was prepared by Tetra Tech NUS (TtNUS) at the
request of the US Environmental Protection Agency (EPA) under Contract No 68-W6-0045
Work Assignment No 055-NSEE-01C7 This document describes the technical scope of work
and proposed schedule for conducting tasks to support an Engineering EvaluationCost
Analysis and associated field investigations at the Mohawk Tannery Site in Nashua New
Hampshire This work plan describes the tasks to be completed during the base period of
Contract No 68-W6-0045 which ends August 28 2001 A separate work plan (Draft Work
Plan - Option Period) describes the tasks to be performed during the contract option period
(August 29 2001 through the projected period of performance for this work assignment -June
2002)
This Work Plan was developed based on an EPA Statement of Work (SOW) dated January
26 2001 discussions with EPA at the kickoff meeting held at TtNUS Wilmington office on
February 12 2001 EPAs comments on the Draft Work Plan discussed during a fact-finding
teleconference on April 27 2000 and subsequent discussions with the EPA Work Assignment
ManagerRemedial Project Manager (RPM)
11 Work Assignment Objectives
The work assignment objectives are (1) to conduct an Engineering Evaluation and Cost
Analysis (EECA) to select a remedy to eliminate reduce or control risks to human health and
the environment posed by contaminated wastessludge contained in the lagoons and disposal
areas at the Mohawk Tannery Site and (2) to plan and perform a field investigation to collect
necessary data to support the EECA The overall goal of the work assignment is to develop
an EECA that will result in a well supported Action Memorandum for the site
12 Work Plan Organization
This Work Plan contains six sections Section 10 provides an introduction Section 20
presents site background information Section 30 details the Scope of Work Section 40
describes the specific tasks to be undertaken Section 50 provides a proposed project
RI01635DF 1-1 Mohawk Tannery NH
DRAFT FINAL
management approach and Section 60 identifies the equipment and consumable supplies
that may be required to perform the specified activities
RI01635DF 1-2 Mohawk Tannery NH
20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
RI01635DF 2-1 Mohawk Tannery NH
DRAFT FINAL
1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
RI01635DF 2-3 Mohawk Tannery NH
DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
RI01635DF 3-1 Mohawk Tannery NH
DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
RI01635DF 3-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
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DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
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ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
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DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
TABLE OF CONTENTS DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
SECTION PAGE
10 INTRODUCTION 1-1 11 Work Assignment Objectives 1-1 12 Work Plan Organization 1-1
20 SITE BACKGROUND 2-1
30 SCOPE OF WORK 3-1
40 TASK PLAN DESCRIPTION 4-1 41 Task 0100 - Project Planning and Support 4-1
411 Subtask0110-Project Planning 4-2 412 Subtask 0120-Prepare Site-Specific Plans 4-4 413 Subtask 0130-Project Management 4-6 414 Subtask 0140 - Subcontractor Procurement and Support
Activities 4-7 42 Task 0300 - Data Acquisition 4-8
421 Subtask 0310 - MobilizationDemobilization 4-9 422 Subtask 0321 -Site Surveys 4-10 423 Subtask 0322 - Geological Investigations 4-10 424 Subtask 0323 - IDW Disposal 4-16
50 PROJECT MANAGEMENT 5-1 51 Project Organization 5-1 52 Project Schedule 5-1 53 Quality Assurance and Data Management 5-2 54 Project Costs 5-2
60 EQUIPMENT AND SUPPLIES 6-1
Proposed Sample Summary
RI01635DF I Mohawk Tannery NH
4-14
DRAFT FINAL
TABLE OF CONTENTS (continued) DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
FIGURES
NUMBER PAGE
2-1 Site Location 2-2 2-2 Site Sketch 2-4 5-1 Project Organization 5-3
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DRAFT FINAL
10 INTRODUCTION
This Draft Final Work Plan - Base Period was prepared by Tetra Tech NUS (TtNUS) at the
request of the US Environmental Protection Agency (EPA) under Contract No 68-W6-0045
Work Assignment No 055-NSEE-01C7 This document describes the technical scope of work
and proposed schedule for conducting tasks to support an Engineering EvaluationCost
Analysis and associated field investigations at the Mohawk Tannery Site in Nashua New
Hampshire This work plan describes the tasks to be completed during the base period of
Contract No 68-W6-0045 which ends August 28 2001 A separate work plan (Draft Work
Plan - Option Period) describes the tasks to be performed during the contract option period
(August 29 2001 through the projected period of performance for this work assignment -June
2002)
This Work Plan was developed based on an EPA Statement of Work (SOW) dated January
26 2001 discussions with EPA at the kickoff meeting held at TtNUS Wilmington office on
February 12 2001 EPAs comments on the Draft Work Plan discussed during a fact-finding
teleconference on April 27 2000 and subsequent discussions with the EPA Work Assignment
ManagerRemedial Project Manager (RPM)
11 Work Assignment Objectives
The work assignment objectives are (1) to conduct an Engineering Evaluation and Cost
Analysis (EECA) to select a remedy to eliminate reduce or control risks to human health and
the environment posed by contaminated wastessludge contained in the lagoons and disposal
areas at the Mohawk Tannery Site and (2) to plan and perform a field investigation to collect
necessary data to support the EECA The overall goal of the work assignment is to develop
an EECA that will result in a well supported Action Memorandum for the site
12 Work Plan Organization
This Work Plan contains six sections Section 10 provides an introduction Section 20
presents site background information Section 30 details the Scope of Work Section 40
describes the specific tasks to be undertaken Section 50 provides a proposed project
RI01635DF 1-1 Mohawk Tannery NH
DRAFT FINAL
management approach and Section 60 identifies the equipment and consumable supplies
that may be required to perform the specified activities
RI01635DF 1-2 Mohawk Tannery NH
20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
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1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
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FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
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DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
TABLE OF CONTENTS (continued) DRAFT FINAL WORK PLAN
ENGINEERING EVALUATIONCOST ANALYSIS MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE
FIGURES
NUMBER PAGE
2-1 Site Location 2-2 2-2 Site Sketch 2-4 5-1 Project Organization 5-3
RI01635DF II Mohawk Tannery NH
DRAFT FINAL
10 INTRODUCTION
This Draft Final Work Plan - Base Period was prepared by Tetra Tech NUS (TtNUS) at the
request of the US Environmental Protection Agency (EPA) under Contract No 68-W6-0045
Work Assignment No 055-NSEE-01C7 This document describes the technical scope of work
and proposed schedule for conducting tasks to support an Engineering EvaluationCost
Analysis and associated field investigations at the Mohawk Tannery Site in Nashua New
Hampshire This work plan describes the tasks to be completed during the base period of
Contract No 68-W6-0045 which ends August 28 2001 A separate work plan (Draft Work
Plan - Option Period) describes the tasks to be performed during the contract option period
(August 29 2001 through the projected period of performance for this work assignment -June
2002)
This Work Plan was developed based on an EPA Statement of Work (SOW) dated January
26 2001 discussions with EPA at the kickoff meeting held at TtNUS Wilmington office on
February 12 2001 EPAs comments on the Draft Work Plan discussed during a fact-finding
teleconference on April 27 2000 and subsequent discussions with the EPA Work Assignment
ManagerRemedial Project Manager (RPM)
11 Work Assignment Objectives
The work assignment objectives are (1) to conduct an Engineering Evaluation and Cost
Analysis (EECA) to select a remedy to eliminate reduce or control risks to human health and
the environment posed by contaminated wastessludge contained in the lagoons and disposal
areas at the Mohawk Tannery Site and (2) to plan and perform a field investigation to collect
necessary data to support the EECA The overall goal of the work assignment is to develop
an EECA that will result in a well supported Action Memorandum for the site
12 Work Plan Organization
This Work Plan contains six sections Section 10 provides an introduction Section 20
presents site background information Section 30 details the Scope of Work Section 40
describes the specific tasks to be undertaken Section 50 provides a proposed project
RI01635DF 1-1 Mohawk Tannery NH
DRAFT FINAL
management approach and Section 60 identifies the equipment and consumable supplies
that may be required to perform the specified activities
RI01635DF 1-2 Mohawk Tannery NH
20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
RI01635DF 2-1 Mohawk Tannery NH
DRAFT FINAL
1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
RI01635DF 2-3 Mohawk Tannery NH
DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
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I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
RI01635DF 3-1 Mohawk Tannery NH
DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
RI01635DF 3-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
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424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
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50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
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ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
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DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
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DRAFT FINAL
10 INTRODUCTION
This Draft Final Work Plan - Base Period was prepared by Tetra Tech NUS (TtNUS) at the
request of the US Environmental Protection Agency (EPA) under Contract No 68-W6-0045
Work Assignment No 055-NSEE-01C7 This document describes the technical scope of work
and proposed schedule for conducting tasks to support an Engineering EvaluationCost
Analysis and associated field investigations at the Mohawk Tannery Site in Nashua New
Hampshire This work plan describes the tasks to be completed during the base period of
Contract No 68-W6-0045 which ends August 28 2001 A separate work plan (Draft Work
Plan - Option Period) describes the tasks to be performed during the contract option period
(August 29 2001 through the projected period of performance for this work assignment -June
2002)
This Work Plan was developed based on an EPA Statement of Work (SOW) dated January
26 2001 discussions with EPA at the kickoff meeting held at TtNUS Wilmington office on
February 12 2001 EPAs comments on the Draft Work Plan discussed during a fact-finding
teleconference on April 27 2000 and subsequent discussions with the EPA Work Assignment
ManagerRemedial Project Manager (RPM)
11 Work Assignment Objectives
The work assignment objectives are (1) to conduct an Engineering Evaluation and Cost
Analysis (EECA) to select a remedy to eliminate reduce or control risks to human health and
the environment posed by contaminated wastessludge contained in the lagoons and disposal
areas at the Mohawk Tannery Site and (2) to plan and perform a field investigation to collect
necessary data to support the EECA The overall goal of the work assignment is to develop
an EECA that will result in a well supported Action Memorandum for the site
12 Work Plan Organization
This Work Plan contains six sections Section 10 provides an introduction Section 20
presents site background information Section 30 details the Scope of Work Section 40
describes the specific tasks to be undertaken Section 50 provides a proposed project
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DRAFT FINAL
management approach and Section 60 identifies the equipment and consumable supplies
that may be required to perform the specified activities
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20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
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1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
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FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
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30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
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DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
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411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
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DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
management approach and Section 60 identifies the equipment and consumable supplies
that may be required to perform the specified activities
RI01635DF 1-2 Mohawk Tannery NH
20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
RI01635DF 2-1 Mohawk Tannery NH
DRAFT FINAL
1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
RI01635DF 2-3 Mohawk Tannery NH
DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
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Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
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411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
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4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
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DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
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DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
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42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
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DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
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DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
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DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
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DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
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DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
20
DRAFT FINAL
SITE BACKGROUND
This section provides a site description and a synopsis of the site history The information
presented in this section was obtained from the EPA Approval Memorandum for the site (EPA
July 12 2000) and the Phase I Hydrogeologic Study for the site (prepared by Goldberg Zoino
and Associates Inc April 1985 for Fairmount Height Associates Nashua New Hampshire)
Site Description
The Mohawk Tannery Site is located at the intersection of Fairmount Street and Warsaw
Avenue in the City of Nashua Hillsborough County New Hampshire (Figure 2-1) The site is
the former location of a leather tannery facility The site consists of two contiguous properties
an approximately 15 acre developed parcel to the north and an approximately 15 acre
undeveloped parcel to the south The site is bordered by the Nashua River on the west a
closed landfill to the north and residential areas to the south and east The site is bordered by
a chain link fence except along the Nashua River side
The inactive tannery facility is situated on the northern parcel Several structures used in
tannery operations as well as debris from several demolished structures remain on site
Remaining structures include the main facility building and a smaller control building and
portions of the former wastewater treatment system Also remaining on the west side of the
site alongside the Nashua River is an open lagoon that was part of the wastewater treatment
system
Site History
The Mohawk Tannery also known as Granite State Leathers operated at the site from 1924 to
1984 While in operation the facility used numerous hazardous substances in the preparation
and tanning of animal hides Substances used included volatile organic compounds (VOCs)
inorganic metals chlorinated phenols and alkaline and acidic solutions The facility produced
waste streams containing spent chromium as well as VOCs chlorinated phenols
proteinaceous solids (eg hair and hide scraps) alkaline and acid residuals mineral solids and
undissolved lime
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DRAFT FINAL
1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
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DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
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DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
1 MILE
E 1000 0 2000 4000 6000 8000 10000 FEET
QUADRANGLE LOCATION
NOTE Bose Map from U S G S Nashua North Quadrangle New Hampshire 75 Minute Series 1968 Photorevised 1985
SITE LOCATION FIGURE 2-1
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAW BY R G DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspm Road Wilmington MA 01887 (978)658-7899 SCALE AS SHOWN NAME DWG40240110snE_LOCDWG
Mohawk Tannery NH RI01635DF 2-2
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
RI01635DF 2-3 Mohawk Tannery NH
DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
RI01635DF 3-1 Mohawk Tannery NH
DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
RI01635DF 3-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
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DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
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DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
Little is known about the tannerys effluent treatment practices prior to the 1960s In general
industry practice prior to that time did not require treatment of wastes prior to discharge into
nearby waterways In the 1960s the facility began providing some treatment of waste prior to its
discharge into the Nashua River Two unlined lagoons were constructed along the western side
of the site approximately thirty feet from the Nashua River and within its 100-year floodplain
Treatment in the lagoons (which are identified as Areas I and II on Figure 2-2) consisted of
combining the acid and alkaline waste streams and allowing the solids to settle out before the
liquid fraction was discharged to the river
A separate treatment process for the alkaline and acid waste streams was put into use from
around 1971 to 1981 The alkaline effluent was pumped sequentially into the Area II and Area I
lagoons before being discharged to the river The acid waste stream passed through a series of
settling basins before being discharged to the river The sludge from the lagoons and settling
basins was periodically dredged and disposed of in four disposal areas at the site identified as
Areas III through VI on Figure 2-2 The sludge in these disposal areas is estimated to range in
thickness from approximately three to ten feet
Between 1971 and 1981 a new treatment facility was constructed consisting of a control
building screen house equalization tank sulfide oxidation tank primary clarifier Indronova
sludge dewatering unit with belt filter press aerated lagoon (Area I lagoon) and a secondary
clarifier During construction it was reported that sludge located in the general vicinity of the
new primary clarifier (Area VI on Figure 2-2) was transferred to Areas III - V
The use of the Area II lagoon was discontinued prior to completion of the new treatment system
and the lagoon was covered with a layer of 4 to 12 inch diameter logs and a layer of fill Area II
has since been allowed to naturally revegetate and is now covered with primarily aquatic
vegetation such as cattails
In approximately 1980 materials including hide scraps and other miscellaneous refuse were
excavated in preparation for constructing the control building for the new treatment facility The
excavated materials were moved approximately 30 to 125 feet southwest of the building to the
area identified as Area VII on Figure 2-2
RI01635DF 2-3 Mohawk Tannery NH
DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
I t1
z
RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
RI01635DF 3-1 Mohawk Tannery NH
DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
RI01635DF 3-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
FIMBEL DOOR COMPANY
FIMBEL LANDFILL
BOSTON amp MAINE RAILROAD
lv
o LJ
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RESIDENCES
RESIDENCES
I 0_ O cn o_ A MONITORING WELL
(SCREENED INTERVAL UNKNOWN)
FENCE INTERVALE
1 GRASS TREE STREET I SLUDGE CLARIFYING
UNIT SLUDGE DEWATERING
UNDEVELOPED LAND UNIT SCREEN HOUSE gtRIMARY CLARIFIER
SULFIOE OXIDATION TANK
SPRAGUE EQUILIZATION TANK 8 5 NOTE THE DESCRIPTIONS MAIN FACILITY 1) 2 PROPERTY BOILER HOUSE OF AREAS I-VIII ARE IN TABLE 1 CONTROL BUILDING
NOT TO SCALE ( REF GZA 1985a amp GZA 1985b) J - NASH STORAGE TANK
SITE SKETCH FIGURE 2-2
MOHAWK TANNERY SITE
NASHUA NEW HAMPSHIRE TETRA TECH NUS INC DRAWN BY RG DEWSNAP REV
CHECKED BY D BAXTER DATE MARCH 22 2001 55 Jonspin Rood Wilmington MA 01887 (978)658-7899 SCALE NONE NJamp- DWC40240110FIG_2-20WG
2-4 Mohawk Tannery NH RI01635DF
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
RI01635DF 3-1 Mohawk Tannery NH
DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
RI01635DF 3-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
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composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
From 1981 until the tannery closed in 1984 dried sludge from the facility was placed in a PVC
lined landfill on the adjacent Fimbel Door Company property (Fimbel Landfill Area VIII on
Figure 2-2) Since 1984 disposal Areas III through VII have been covered with up to a few feet
of sand and gravel and allowed to naturally revegetate In addition to granular fill Area V was
covered with a base layer of 6 to 12 inch diameter logs similar to the cover on Area II The
Fimbel Landfill has been capped and closed under New Hampshire State Regulations
RI01635DF 2-5 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
RI01635DF 3-1 Mohawk Tannery NH
DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
RI01635DF 3-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
30
DRAFT FINAL
SCOPE OF WORK
The overall scope of the work assignment is to develop an EECA to support EPAs selection of
a remedy to eliminate reduce or control risks to human health and the environment posed by
contaminated wastessludge contained in the lagoons and disposal areas at the Mohawk
Tannery Site and that results in a well supported Action Memorandum The EECA will be
developed using existing data and new data collected under this work assignment This section
presents a list of general activities to be performed under this work assignment The activities
are broken down by contract base period and option period The specific technical requirements
of the base period activities are detailed in Section 40 Details of the remaining activities are
presented in the option period work plan
Base Period Activities
Develop a Work Plan and Detailed Cost Estimate (draft and draft final versions)
Perform project management and monthly reporting activities
Review existing information
Develop project goals and objectives
Develop a Quality Assurance Project Plan (QAPP) to describe project objectives and
organization proposed data collection activitiesmethods and QAQC protocols that will
be used to achieve the desired data quality objectives
Develop a site-specific Health and Safety Plan (HASP)
Procure and manage subcontractors to perform drilling test pitting surveying and IDW
disposal
Plan and conduct field activities to acquire necessary data to support the EECA
Proposed field activities include wetland delineation endangered species survey
topographic survey collection of sludge and soil samples using direct-push technique
drilling and manual-driven coring techniques and identification of waste area boundaries
using by test-pitting methods
Ship sludge and soil samples to analytical laboratories for characterization
Dispose of Investigation-Derived Wastes (IDW)
Option Period Activities
Perform data validation on the new analytical data
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DRAFT FINAL
Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
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411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
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4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
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DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
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DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
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DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
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50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
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ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
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DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
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Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
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Compile existing and new data into a site database that will facilitate evaluation use
and presentation of site data
Provide support for community relations activities including preparing 2 fact sheets and
providing technical and logistical support for a public meeting and public hearing
Perform Streamlined Human Health and Ecological Risk Evaluations
Prepare an EECA Report (draft and final versions)
Provide technical support to EPA during their preparation of the Responsiveness
Summary and Action Memorandum
Close out work assignment at completion
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40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
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DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
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4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
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The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
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The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
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The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
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42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
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DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
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It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
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DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
40 TASK PLAN DESCRIPTION
This section provides detailed descriptions of the tasks to be performed by TtNUS during the
contract base period to meet the requirements of this work assignment The task numbering system
corresponds to the work breakdown structure (WBS) presented in the EPA SOW Tasks or
subtasks missing from the sequence were considered not applicable by EPA The tasks to be
performed in both the contract base and option periods are identified below Detailed descriptions
of the tasks to be performed during the base period are presented in Sections 41 and 42 tasks to
be performed during the option period are described in a separate option period work plan
Tasks to be performed during the contract base period (described in this work plan)
Task 0100 - Project Planning and Support
Task 0300 - Data Acquisition
Tasks to be performed during contract option period (described in option period work plan)
Task 0100 - Project Planning and Support
Task 0200 - Community Relations
Task 0400 - Sample Analysis
Task 0500 - Analytical Support and Data Validation
Task 0600 - Data Evaluation
Task 0700 - Streamlined Risk Evaluation
Task 0800 - Identification of Removal Alternatives
Task 0900 - Analysis of Removal Alternatives
Task 1000 - Engineering EvaluationCost Analysis Report
Task 1100 - Post EECA Support
Task 1300 - Work Assignment Closeout
41 Task 0100 - Project Planning and Support
This task encompasses all necessary activities to plan execute and manage the tasks specified in
the EPA SOW through the projected performance period of February 2001 through August 2001
RI01635DF 4-1 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
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composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
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DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
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DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
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DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
411
DRAFT FINAL
This work will span the contract base and option periods as described below for each subtask
SubtaskOHO-Project Planning
The five subtasks that comprise the project planning task are described below These tasks are all
expected to be completed during the contract base period
4111 Subtask 0111 - Attend Scoping Meeting
A scoping meeting was held on February 12 2001 at TtNUS Wilmington office between the
EPA Project Officer Remedial Project Manager (RPM) and Contracting Officer (via telephone)
and the TtNUS Deputy Program Manager and Work Assignment Project Manager Two
representatives of the State of New Hampshire Department of Environmental Services
(NHDES) also attended Additional information was provided by EPA during the meeting to
clarify the activities to be performed
4112 Subtask 0112 - Conduct Site Visit
The TtNUS project manager and two key project personnel conducted a site visit with the RPM on
April 30 2001 The purpose of the site visit was to familiarize key personnel with the layout and
physical conditions that exist at the site that could impact data collection or implementation of the
NTCRA The information obtained during the site visit will be used to identify additional data
requirements determine the approach to the field sampling program and better scope the EECA
4113 Subtask 0113 - Evaluate Existing Information
TtNUS will review and evaluate existing data and documents including previous site investigations
Preliminary Assessment Reports Site Inspection Reports Removal Reports and other pertinent
documents identified by EPA The information will be used to familiarize key project personnel
(project manager field operations leaderproject geologist human health and ecological risk
assessors) with site conditions and contamination determine the need for additional data plan the
field sampling program develop project goals and objectives and prepare the streamlined risk
evaluations and EECA report
RI01635DF 4-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
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DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
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composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
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DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
4114 Subtask 0114 - Develop Technical Project Goals and Objectives
TtNUS will identify data needs and develop data quality objectives (DQOs) for the sampling and
analysis to be performed in support of the EECA The DQOs will be used to define the appropriate
analytical methods and protocols decontamination procedures and EPA reporting levels for the
project
4115 Subtask 0115 - Work Plan Preparation
TtNUS will prepare and submit a Draft and a Draft Final Work Plan and Detailed Cost Estimate
This document is the Work Plan and it includes a description of project tasks the procedures to
accomplish them and a proposed project schedule Specifically the Work Plan includes the
following
bull A detailed identification of project elements and associated tasks and subtasks
TtNUS technical approach to each task to be performed including a description of each
task the assumptions used 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 information is presented in a sequence consistent with
the WBS provided in the SOW
A comprehensive description of the EECA scope including the identification of additional
data collection activities characterization of the nature and extent of contamination to be
addressed by the NTCRA and identification of potential alternatives that may be
considered in the EECA
A schedule that provides specific dates for completion of each required activity and
submission of each deliverable required by this SOW
RI01635DF 4-3 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
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composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
The Detailed Cost Estimate prepared as a separate document presents the estimated cost to
complete the work Costs are broken into Level of Effort (LOE) (by P levels) and dollar cost for each
task of the WBS
TtNUS will prepare a Draft Final Work Plan and Detailed Cost Estimate within 15 days after receipt
of EPA comments on the Draft version The draft final versions incorporate revisions discussed
during a conference call with EPA on April 27 2001 and documented in EPAs letter of May 18
2001 presenting EPAs comments to the Draft Work Plan and Detailed Cost Estimate The April 27
conference call was conducted under this task
412 Subtask 0120 - Prepare Site-Specific Plans
This task entails preparing site-specific plans needed to implement the work assignment Only a
Quality Assurance Project Plan (QAPP) and a Health and Safety Plan (HASP) will be generated
under this task The elements included in a Site Management Plan (identified in SOW
section 121) Sampling and Analysis Plan (identified in SOW section 1212) and Field
Sampling Plan (discussed in SOW section 1212b) will be addressed in the QAPP and HASP
as described below separate plans will not be developed to address these elements This task
is expected to be completed during the contract base period
4121 Subtask 0121 - Develop Quality Assurance Project Plan (QAPP)
The Quality Assurance Project Plan will be prepared in accordance with EPA QAR-5
(November 1997) and the Region I EPA-New England Compendium of Quality Assurance
Project Plan Requirements and Guidance October 1999 Final The QAPP discusses the
project objectives and organization functional activities and quality assurancequality control
(QAQC) protocols that will be used to achieve the desired data quality objectives (DQOs)
This subtask includes identifying data needs and developing DQOs for the environmental
sampling to be performed during the field investigation The DQOs are used to identify
sampling protocol and analytical methods that will be used to characterize the environmental
samples to the degree needed to adequately support performance of the EECA and NTCRA
RI01635DF 4-4 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
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composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
The goals and objectives of the field investigation will define the analytical methods and
protocols
In accordance with EPA QAR-5 there are four basic element groups that must be addressed in the
QAPP project management and objectives measurementdata acquisition assessmentoversight
and data validation and usability The QAPP will be developed to address each of these elements
Sections 30 to 70 of the QAPP address project management and objectives elements including
project organization personnel responsibilities project planning and project and data quality
objectives
Sections 80 to 150 of the QAPP include the measurement and data acquisition elements
(sampling and analysis) dealing with sampling design rationale sampling procedures and
requirements sample handling tracking and chain-of-custody requirements sample analysis
requirements field quality control samples and documentation and record management
Sections 9 10 and 11 of the QAPP present the sampling and analytical objectives traditionally
described in a Field Sampling Plan
Sections 160 and 170 of the QAPP address data assessment and quality assurance Sections
180 through 200 of the QAPP address data validation verification and usability
4122 Subtask 0122 - Develop Health and Safety Plan (HASP)
TtNUS will develop a site-specific Health and Safety Plan (HASP) to address the specific health
and safety requirements for implementation of the sampling required under this work assignment
The purpose of the HASP is to provide adequate health and safety protection for all TtNUS and
subcontractor personnel working on site
The HASP will specify employee training requirements protective equipment needs medical
surveillance requirements standard operating procedures and an emergency contingency plan
that applies to all field investigation activities The HASP will include task-specific health and safety
requirements for all planned field activities that will be carried out by TtNUS any subcontractors
working under the HASP and any visitors to the site
RI01635DF 4-5 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
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DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
The HASP will address several elements that are traditionally included in a Site Management Plan
These include site access and security delineation of work zones decontamination procedures
and emergency contingency procedures
The HASP will also include requirements for air monitoring and project action levels above which
workers would be required to upgrade respiratory protection during intrusive activities It is
anticipated that it may be necessary to upgrade to respiratory protection level B (supplied air) during
test pitting activities and it may be desirable to upgrade to Level C (purified air) during other
intrusive activities to control odors even when concentrations do not require respiratory protection
413 Subtask 0130 - Project Management
This task includes overall work assignment management cost and schedule tracking
preparing monthly progress reports and preparing semi-annual project self evaluation reports
(SERs) for the projected 17 month duration of the work assignment The first seven months of
this task (through August 2001) fall within the contract base period
The monthly progress reports will be prepared in accordance with contract requirements The
reports will document the technical progress and status of each task and report costs and level of
effort (by P-level) for the reporting period as well as cumulative amounts expended to date
Monthly invoices will be prepared and submitted in accordance with the level of detail specified in
the contract
This task also includes overall project management and ongoing routine communications with
the EPA RPM to report project status Communications are assumed to be weekly or as
appropriate during the active period of the work assignment Attendance at an estimated three
technical project meetings at EPA Boston and providing documentation of meeting results as
requested by EPA are also included in this task It is assumed that two technical staff from
TtNUS (Wilmington office) may be required to attend these meetings
RI01635DF 4-6 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
414 Subtask 0140 - Subcontractor Procurement and Support Activities
This task includes the work efforts to solicit award and manage the subcontracts required to
complete the activities identified in the SOW It is assumed that all subcontractor procurement
and support activities will be completed during the contract base period
It is anticipated that subcontracts will be awarded for drilling test pitting topographic
surveying and investigation-derived waste (IDW) characterization transport and disposal It is
assumed that drilling and test pitting will be included in the same subcontract and that site clearing
and management and disposal of cleared material will be performed under the drilling and test
pitting subcontract
Analytical services to be performed under this work assignment will be contracted under the
Delivery of Analytical Services (DAS) subcontract because the Contract Laboratory Program
(CLP) only includes routine soil and water analysis Technical specifications and subcontract
procurement for the DAS analyses will be performed under the DAS work assignment
Procurement of subcontractors under this contract must be conducted under the Federal
Acquisition Regulations (FAR) TtNUS has a government approved procurement and
acquisition system in compliance with the FAR The following bullets detail the work required
to solicit award and manage the necessary subcontracts for this work assignment
bull Prepare technical specifications and bid documents for each task to be subcontracted
Technical specifications will be developed based on EPA requirements and TtNUS
standard operating procedures Draft technical specifications will be provided to EPA
for comment Final specifications will be prepared to address any EPA comments
bull Prepare a list of bidders to receive the bid packages for each required subcontract
bull Prepare print and distribute contract documents It is assumed that up to 5 firms will be
solicited for each of the subcontracts and that only one solicitation will be required for
each subcontract
RI01635DF 4-7 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
42
DRAFT FINAL
bull Pre-bid meeting Pre-bid meetings will be held on site prior to bid submittal for the
drillingtest pitting and surveying subcontracts to ensure that the bids submitted
accurately reflect the scope and cost of the work to be conducted The purpose of the
pre-bid meeting is to provide clarification of the scope of work specifications and
contract documents and allow the bidders to observe the site conditions and areas
where the work will be conducted One pre-bid meeting is anticipated for each of these
subcontracts A pre-bid meeting is not expected to be needed for the IDW-disposal
subcontract because the work is not significantly affected by site conditions No other
site visits associated with subcontractor procurement are anticipated It is assumed
that two TtNUS personnel will attend each pre-bid meeting
bull Resolution of bidder inquiriesissuing addenda Bidders questions will be resolved and
if necessary contract amendments will be prepared and issued to all bidders
bull Review compile and evaluate all bids received for the other subcontracts The bid
evaluation will include an assessment of bid responsiveness reference checks
proposed schedule bid tabulation bid analysis and cost
bull Review permits requirements msurance(s) and bonds provided by subcontractors to
minimize site risks and potential financial liabilities
bull Award subcontracts
bull Review subcontractor invoices review and approve any appropriate subcontract
modifications track and monitor subcontract costs and schedule
Task 0300 - Data Acquisition
The objective of this task is to collect additional environmental data from the Site that is
needed to support preparation of the EECA Specifically additional data is required to better
quantify the volume and chemical characteristics of waste materials in seven disposal areas
and lagoons in order to identify appropriate remedial objectives for this material
RI01635DF 4-8 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
This task will consist of obtaining field data to assist in determining the lateral and vertical
extent of contamination in the seven disposal areas and lagoons Subtasks include
mobilization demobilization and field investigation activities including wetlands delineation
well inventory and water level measurements site topographic survey test pitting activities soil
borings (direct push technique [DPT] drilling) and associated sludgesoil sample collection and
analysis and characterization and disposal of investigation-derived wastes (IDW) The
detailed plan for sample collection procedures locations and the basis for the design of that
plan will be provided in the Quality Assurance Project Plan (QAPP described in
Section 4121 of this Work Plan) to be submitted under separate cover It is assumed that all
data acquisition activities will be completed during the contract base period
The sections that follow present a description of the data acquisition tasks and the proposed
numbers of samples and analyses
421 Subtask 0310 - MobilizationDemobilization
This subtask involves providing the necessary personnel equipment and materials for mobilization
and demobilization from the Site to conduct the field investigation Included in this subtask are
efforts to locate onsite and remove upon fieldwork completion a field trailer and trailer support
items (dumpster portable toilet temporary telephone and power connections etc) and identifying
and obtainingreturning field equipment supplies etc It is noted that construction of the
decontamination pad and any required clearing and grubbing of the Site is to be performed by a
subcontractor to TtNUS as part of Subtask 0322 (see below)
A field orientation meeting for all TtNUS field team members and the TtNUS project manager
health and safety officer and quality assurancequality control officer will be held in the TtNUS
office as part of the mobilization activities prior to initiation of fieldwork The purpose of the field
orientation meeting is to discuss the work plan quality assurance project plan and health and
safety protocols to ensure that field team members have a complete understanding of the project
objectives field activities and procedures This subtask also includes preparing field documentation
forms completing up-front field tracking systems and performing other similar field investigation
support tasks
RI01635DF 4-9 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
422 Subtask 0321 - Site Surveys
This task includes performing various site surveys to accomplish the following
bull Perform a wetlands delineation of the Site including TtNUS staff to identify and map
the wetlands boundaries in the field using rented GPS equipment
bull Identify rare and endangered species that may be present at the Site through
communications with federal and state agencies and through onsite observations
bull Conduct a well inventory of approximately 10 existing monitoring and observation wells
including evaluation of condition of each well and water level measurements
bull Perform a limited topographic survey of the Site using a subcontracted surveyor
licensed in the State of New Hampshire Features to be surveyed include the property
boundary sewer interceptorutility rights of way locations and elevations of
approximately 10 previously installed monitoring and observation wells spot elevations
to confirm the 100-year floodplain elevation location and miscellaneous site features
including fencing buildings and other structures One TtNUS representative will
accompany the surveyor at the site and will provide a health and safety briefing to the
onsite surveying personnel
423 Subtask 0322 - Geological Investigations
The advancement of test pits and direct-push technique (DPT) soil borings will be conducted
under this task by a subcontractor to TtNUS In Area I an open lagoon manually driven cores
will be collected by TtNUS staff The borings and test pits will be advanced to delineate the
horizontal and vertical extent of sludge in each of the seven onsite lagoons and disposal
areas and sludgesoil samples will be collected to characterize the sludge and associated
soils The TtNUS field team will pack and ship the soil and sludge samples for laboratory
analysis for required analytical parameters (described in Task 0400 of the option period work
plan) and prepare chain-of-custody forms and associated sample tracking documentation
RI01635DF 4-10 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
It is assumed that some clearing and grubbing of trees and brush will be required prior to
conducting intrusive activities in most areas particularly in disposal areas IV and V which contain
small trees The subcontractor will conduct any required land clearing activities It is assumed that
trees and brush to be removed will be chipped and disposed offsite by the subcontractor It is
currently estimated that approximately one acre may require clearing In addition the subcontractor
will be required to construct the decontamination pad at the Site prior to intrusive activities
Test Pits
An estimated 24 to 32 trenchestest pits will be excavated at the site in order to better define
the horizontal boundaries of the former tannery waste disposal areas and if possible to
determine the sludge thickness at the disposal area boundaries This information will be used
to assist in estimating the volume of waste materials in each of the disposal areas The
excavations will be conducted by a TtNUS subcontractor and directed by TtNUS personnel
The maximum depth of excavation is assumed to be 12 feet Based on previous site
information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the presence of sludge will be determined primarily
through visual observations of the test pits
An estimated 4 to 8 test pits or trenches will be excavated at Areas II through VII (Area I is an
open lagoon and it is assumed that test pits will not be required in this area) The test pits will
be advanced near the currently estimated edges of the disposal areas (depicted on an existing
site map Figure 2 - Exploration Location Plan from GZAs Hydrogeologic Study Phase II
October 1985) When the horizontal limit of the sludge is determined in a pit or trench the
excavation will be advanced deeper if possible to determine the thickness of sludge at that
location After excavation the test pit locations and the disposal area boundaries will be
marked and located by TtNUS using GPS equipment with sub-meter accuracy
Soil sampling will not be conducted as part of the test pit operation but ambient air screening for
VOCs and hydrogen sulfide will be performed during excavation activities Efforts will be made to
disturb as little of the tannery waste material as possible during this activity It is assumed that any
visually-contaminated soil or sludge removed during test pitting operations will be segregated from
any overlying dean soils and will be placed back into the test pits with the upper clean soils placed
RW1635DF 4-11 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
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rea
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udge
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eas
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ides
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ples
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posi
tes
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ings
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otal
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udge
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ples
are
a =
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es =
laquo +m TJ 5 poundc t
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il V
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jar)
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Een S re reT- CO pound mCO -2 = 8 0UJ CD TJ bull= o CD ltshy ishy CD O are CL CD CCO CO ce o pound O bullmdashbull5 ~ rvi
Q 1
RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
on top upon completion of each excavation After backfilling grass seed will be spread on the
scarred areas to revegetate the areas and minimize erosion
For cost estimating purposes it is assumed that because of potential hydrogen sulfide
emissions the excavation work will be conducted partially in Level B respiratorypersonal
protection and partially in Level C respiratory protection It is assumed that test pit activities
using a combination of Level B and Level C protection will require a total of 10-days
Soil Borings and Associated SludgeSoil Sampling
An estimated 28 soil borings will be advanced using a DPT drilling methodology and manually
driven coring techniques for the purpose of obtaining sludge and soil samples for chemical
analysis and determining the thickness of sludge and cover soils in each disposal area The
general sampling approach is to divide each of the seven onsite disposallagoon areas into
quadrants and advance one boring in the approximate center of each quadrant for a total of 4
borings per area (28 borings total) The borings to be located in Area I an open lagoon will be
advanced by TtNUS staff using manual coring techniques In the remaining areas borings will
be advanced by a TtNUS subcontractor using DPT drilling if possible In Areas II and V which
contain logs as part of the backfill materials placed over the sludge it is anticipated that the
test pit excavatorbackhoe may be required to collect the sludge samples if the DPT
methodology is unsuccessful in advancing to the required depth in these areas Each boring
will be located by TtNUS using GPS equipment with sub-meter accuracy The borings where
samples are to be collected for chemical analysis will be referred to in this work plan as
quadrant-borings
An estimated 18 additional DPT borings may be advanced in Areas II through VII to better
delineate the thickness of sludge and cover soil in each disposal area These borings will be
advanced if necessary to fill data gaps remaining following the test pit excavations Soil and
sludge samples from these borings would be collected for observation only not for chemical
analysis These borings will be referred to in this work plan as observation-borings
At each boring location continuous sludgesoil samples will be collected (using 2-foot or 4-foot
length samplers) beginning at the ground surface and continuing through the entire thickness
of the sludge and approximately two feet into the soils beneath the sludge Based on previous
RI01635DF 4-12 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
a-Sc g in o 0 0 0 O 0 0 0 0 O 0 0 0 0 O - ~
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m 5 ro ro CO CO O CO 0 0 0 0 0 0 0 0 0 O 0 0deg- E (A
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in lta
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estic
ides
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ctiv
ity-s
ulfid
amt
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r (F
ree
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OC
sd
orou
s S
ulfid
es
gt O
rea
sll
l-V
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udge
are
a Ig
nita
biht
y^ ||
(one
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ing)
x
5 ar
eas
= 2
0 C
orro
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tyR
eact
ivity
-cya
ni
AN
ALY
SIS
(
mdash t_ o SoO W - o 03 CO
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LP-S
VO
Cs
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TJ mfu ^mdash
estic
ides
PC
Bs
CO o laquo O
^^ 01 c TJ o o
loxi
nsfu
rans
co 5 CO CO ^il 1-2 C
re 0ol a poundOin o0 O
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leta
ls
oin O in re rv O O roSo 0 CL 0 gt c TJ
TJ
(0
re in a o CO c0
|
DE
SC
RIP
TIO
N
LO
CA
TIO
2+
s
oil
sam
ples
are
a ex
ce
are
com
posi
tes
of 4
bor
ings
reltI CO ro O ro i= O -^ bullJ 5 mUJ c CL UJ TJ
in jj bull CO TJ CL 0
TJ a CO CCD Cre cre rein in o
0
z 5 II Q
1
agt
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(hea
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udge
ir
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E
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cor
ing
sam
T
otal
s an
alys
es
41 s
ampl
es O)
TJ
4 sl
udge
sam
ples
are
a =
2 o TJ
II ||RC
RA
ana
lyse
s 2
2 sa
mpl
es =
laquo +m TJ 5 poundc t
60 m
l so
il V
OC
jar)
C pound g in C= laquo u ro TJ c o - sect 0) ro x TJ re 3 oCO in TJ ^ ro TO co ro -Q Ure xpound Cro UJ oin Q
1si 1
sulfl
de -CO
irman
ce
U)CO in CL CO CL E laquo- o CL Ero
Een S re reT- CO pound mCO -2 = 8 0UJ CD TJ bull= o CD ltshy ishy CD O are CL CD CCO CO ce o pound O bullmdashbull5 ~ rvi
Q 1
RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
EEC
AEN
GINE
ERS
PR
OJE
CT
E (T B
D)
(pound O 5= Q- X C -3 _ HI ^
HI
CO Q
O
^j HI HI p
mdash
b m ^J ^^
QL SHI IX O HI
01 fc O OO~lt UJ 0 a co 3 in
Qi S Q OL CD O lt h- laquo c mdash fy n lt rv ^3 O c - =
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S ccc
n ^3 Q^ III yj d 1tmdash CO fi ^ o a lt 0 t3 8a Q a HQ_ n
Z HI c
oHI O
SI TO Z HI lt mdash
a HI
50
HHI o O bullS 8
v_ OLL H a o O C 0)
iojui ^0CO 9 N tiid$lt U- D laquogt_ LL O
fc _i 08 -5 X
O
1
RIS
K A
S 3
ES
SM
EN
T
C W
Olt D
OS (H
H)
A
BE
RN
H A
RD
T (E
CO
)
Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
site information it is assumed that the tannery waste materials to be delineated are readily
identifiable by visual means Therefore the total depth of each boring and the limits of the
sludge will be determined through visual observations of the borings For cost estimating
purposes it is assumed that the quadrant-borings will be advanced to a depth of 10 to 12 feet
and the observation-borings will be advanced to 4 to 6 feet depth
For all borings soils and sludge recovered from each sampler will be described on boring logs
using the Unified Soil Classification System All pertinent observations (depths and descriptions of
visually contaminated materials grain size dry vs wet etc) will be recorded
Additionally at each quadrant boring sludge and soil samples will be collected for chemical
analysis Media to be sampled from the quadrant borings include tannery sludge and the bottom
soil beneath the sludge in all disposal areas and the cover soil above the sludge in disposal areas
II through VII Three types of samples will be collected boring-composites area-composites and
grab samples Boring-composites are composite samples of sludge cover soil or bottom soil from
the entire thickness (all depth intervals) of the subject media within the same boring (for example a
boring-composite sludge sample would contain sludge from all depth intervals within a boring that
are visually observed as tannery waste materials) Area-composites are composite samples of
sludge or soil from multiple borings within the same area (typically all the quadrant-borings in the
area) Grab samples are collected from only one depth interval within a boring
The following paragraphs describe the proposed sampling Table 4-1 presents a summary of the
proposed analyses Further discussion of sample analysis is presented under Task 0400 in the
option period work plan
In Area I the open lagoon four boring-composite sludge samples and one area-composite bottom
soil sample (soils beneath the sludge) will be collected and shipped for laboratory analyses for
VOCs SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium Additionally
one area composite sludge sample will be collected and shipped for laboratory analysis for RCRA
hazardous waste characteristics and a paint filter (free water) test
RI01635DF 4-13 Mohawk Tannery NH
DRAFT FINAL
a-Sc g in o 0 0 0 O 0 0 0 0 O 0 0 0 0 O - ~
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m 5 ro ro CO CO O CO 0 0 0 0 0 0 0 0 0 O 0 0deg- E (A
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in lta
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estic
ides
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ctiv
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ulfid
amt
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r (F
ree
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es
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rea
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udge
are
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ides
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N
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2+
s
oil
sam
ples
are
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ce
are
com
posi
tes
of 4
bor
ings
reltI CO ro O ro i= O -^ bullJ 5 mUJ c CL UJ TJ
in jj bull CO TJ CL 0
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z 5 II Q
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udge
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otal
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ples
are
a =
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RA
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lyse
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2 sa
mpl
es =
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il V
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jar)
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Een S re reT- CO pound mCO -2 = 8 0UJ CD TJ bull= o CD ltshy ishy CD O are CL CD CCO CO ce o pound O bullmdashbull5 ~ rvi
Q 1
RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
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AEN
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Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
a-Sc g in o 0 0 0 O 0 0 0 0 O 0 0 0 0 O - ~
~ ffl
vt 0)
m 5 ro ro CO CO O CO 0 0 0 0 0 0 0 0 0 O 0 0deg- E (A
S bull to E in in in in o in 0 0 0 0 0 0 0 0 0 O 0 0 C trade pound CD
S 0 T- Tshy^ in in in in in in in CO CO CO CO CO co ro CO O 5 3 O
in lta
ogt CD h- CD in in in in in in in CL m CD CO in m in in bullt m CM CM CM CN CM CN CM CM Eo re
in in O in O ^ gt n agt re P
bullmdashbull ka oco ro CO CO g-P m T in laquoo in ro co CO CO CO CO CO co o CN CN CM ro ~ ^~ 3 O E mdash TJ pn CO CD 0 o in CL HmdashCO
CM CL UJ pound 10
O E^
t T E S l_ 2bullo -2 re CO CL
CM CM CM CM CN CM CM CM T~ ^ 0CM CM CM CM CN CM CM CN _ in 8 TJ CO - i
x CO o CD
Ul CO 8 CO 0 sectin CL 2 re o E x
CO re re CO CD lt lt H- Ul tn W a in x
L_ T- to TJ
H Q E gt ltf- 5T 5 o CO CO CL 0
ltOTZ Z t
uj 5 25 lt H TJ
raquo~ r- lt 3 Ife CO in m CO o CL a E bulla co Si ro CM 1 inI X fc
exav
alen
t C
hrom
mi
gt CO CL 2 I Qi- ce CL
TC
LP-p
estic
ides
Rea
ctiv
ity-s
ulfid
amt
Filte
r (F
ree
Wa
OC
sd
orou
s S
ulfid
es
gt O
rea
sll
l-V
II
4 sl
udge
are
a Ig
nita
biht
y^ ||
(one
bor
ing)
x
5 ar
eas
= 2
0 C
orro
sivi
tyR
eact
ivity
-cya
ni
AN
ALY
SIS
(
mdash t_ o SoO W - o 03 CO
CL 0
TC
LP-S
VO
Cs
J2 mS
TJ mfu ^mdash
estic
ides
PC
Bs
CO o laquo O
^^ 01 c TJ o o
loxi
nsfu
rans
co 5 CO CO ^il 1-2 C
re 0ol a poundOin o0 O
- h- re re
leta
ls
oin O in re rv O O roSo 0 CL 0 gt c TJ
TJ
(0
re in a o CO c0
|
DE
SC
RIP
TIO
N
LO
CA
TIO
2+
s
oil
sam
ples
are
a ex
ce
are
com
posi
tes
of 4
bor
ings
reltI CO ro O ro i= O -^ bullJ 5 mUJ c CL UJ TJ
in jj bull CO TJ CL 0
TJ a CO CCD Cre cre rein in o
0
z 5 II Q
1
agt
| A
IR
(hea
dspa
ce o
f sl
udge
ir
inCO o mdash co G7 cCO M ro 2
[ SLU
DG
E
SO
IL -
cor
ing
sam
T
otal
s an
alys
es
41 s
ampl
es O)
TJ
4 sl
udge
sam
ples
are
a =
2 o TJ
II ||RC
RA
ana
lyse
s 2
2 sa
mpl
es =
laquo +m TJ 5 poundc t
60 m
l so
il V
OC
jar)
C pound g in C= laquo u ro TJ c o - sect 0) ro x TJ re 3 oCO in TJ ^ ro TO co ro -Q Ure xpound Cro UJ oin Q
1si 1
sulfl
de -CO
irman
ce
U)CO in CL CO CL E laquo- o CL Ero
Een S re reT- CO pound mCO -2 = 8 0UJ CD TJ bull= o CD ltshy ishy CD O are CL CD CCO CO ce o pound O bullmdashbull5 ~ rvi
Q 1
RI01635DF 4-14 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
EEC
AEN
GINE
ERS
PR
OJE
CT
E (T B
D)
(pound O 5= Q- X C -3 _ HI ^
HI
CO Q
O
^j HI HI p
mdash
b m ^J ^^
QL SHI IX O HI
01 fc O OO~lt UJ 0 a co 3 in
Qi S Q OL CD O lt h- laquo c mdash fy n lt rv ^3 O c - =
O ^j ^C fO t^
S ccc
n ^3 Q^ III yj d 1tmdash CO fi ^ o a lt 0 t3 8a Q a HQ_ n
Z HI c
oHI O
SI TO Z HI lt mdash
a HI
50
HHI o O bullS 8
v_ OLL H a o O C 0)
iojui ^0CO 9 N tiid$lt U- D laquogt_ LL O
fc _i 08 -5 X
O
1
RIS
K A
S 3
ES
SM
EN
T
C W
Olt D
OS (H
H)
A
BE
RN
H A
RD
T (E
CO
)
Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
In Area II the covered former lagoon in addition to the samples described for Area I an area-
composite cover soil sample will be collected and shipped for laboratory analyses for VOCs
SVOCs pesticidesPCBs metals dioxinsfurans and hexavalent chromium
At each of the remaining disposal areas four boring-composite sludge samples one area-
composite bottom soil sample and one area-composite cover soil sample will be collected and
shipped for laboratory analyses for VOCs SVOCs pesticidesPCBs metals dioxinsfurans and
hexavalent chromium Additionally four boring-composite sludge samples from each area will be
collected and shipped for RCRA hazardous waste characteristics analyses In one of the five
disposal areas (selected based on field observations) one area-composite sludge sample will also
be collected and shipped to the laboratory for a paint filter test
In addition four grab sludge samples (one each from Areas I II and two other locations to be
selected in the field) will be collected and shipped to a laboratory for headspace analysis for VOCs
and odorous sulfides The purpose of these samples is to characterize the air that would be
generated during intrusive activities in order to evaluate potential air emissions that may result
from excavation of the sludge during the NTCRA The air data will be used in the EECA to
identify and evaluate potential control technologies to address the emissions generated from
excavation and handling of sludge
The purpose of the sludge sample analyses is to characterize the soils to allow for evaluation of
treatment and disposal options and human health and ecological risks The purpose of the cover
soil and bottom soil sample analyses is to characterize the soils to determine whether they have
been impacted by site contaminants and whether they should be addressed under the NTCRA
It is understood that due to the nature of the composite sampling the resulting analytical data
will not provide detailed waste characterization information by depth however as stated
previously due to the nature of the contamination it will be possible to determine the extent of
the waste primarily through visual observations (visual evidence of tannery sludge materials)
RI01635DF 4-15 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
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RA
HA
N
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QL
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ERS
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RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
424 Subtask 0323 - IDW Disposal
As part of the field investigation TtNUS will also characterize and dispose of investigation-derived
waste (IDW) in accordance with local state and federal regulations The IDW may be generated
from drilling sludgesoil sampling test pitting and decontaminating equipment Anticipated IDW
may include residual contaminated soilssludge decontaminated sampling gear and
decontamination fluids For costing purposes it is assumed that
bull Decontamination fluids (primarily rinse water detergent soilssludge removed from
sampling equipment and minor amounts of isopropyl alcohol) will be collected and allowed
to evaporate then discharged to the onsite lagoon
bull Any visually-contaminated soil or sludge removed during test pitting operations will be
segregated from overlying clean soils and will be placed back into the test pits with the
upper clean soils placed on top and will not require containerization and disposal under this
investigation
bull Only minimal amounts of soilssludge that may require disposal will be generated from soil
borings based on the DPT technique to be used and the number of analyses to be
performed (and associated sample jars filled)
bull An estimated 2 drums of soilssludge generated from soil sampling may require disposal at
an off site facility
bull An estimated 1 drum of PPEsampling debris may require disposal at an off site facility
bull Materials to be disposed are assumed to contain dioxins
RI01635DF 4-16 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
EEC
AEN
GINE
ERS
PR
OJE
CT
E (T B
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(pound O 5= Q- X C -3 _ HI ^
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CO Q
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^j HI HI p
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01 fc O OO~lt UJ 0 a co 3 in
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S ccc
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A
BE
RN
H A
RD
T (E
CO
)
Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
50 PROJECT MANAGEMENT
The overall project management and control of the work to be conducted under this work
assignment are discussed below
51 Project Organization
Mr George D Gardner the Program Manager is responsible for the overall management and
implementation of the TtNUS RAC I contract performed in US EPA Region I Ms Diane M
Baxter will serve as the project manager for Work Assignment 055-NSEE-01C7 and has
overall primary responsibility for implementing and executing the Work Assignment including
ensuring technical quality providing oversightreview controlling costs and schedules and
implementing appropriate quality assurance procedures during all phases of the work
assignment Other staff assignments to support this work effort are identified in the project
organization chart (Figure 5-1)
52 Project Schedule
The proposed schedule for performing project activities is presented below The projected
completion date for project is June 30 2002
ActivityDeliverable Draft Work PlanCost Estimate EPA Review CommentNegotiations Draft Final Work PlanCost Estimate Draft QAPP EPA Review Comment Final QAPP Subcontractor ProcurementAward
Analytical Laboratories DPT DrillingTest Pitting Surveying IDW
Field Activities MobilizeDemobilize Site Surveys Clearing Test Pitting DPT DrillingManual CoringGPS
Start Date February 12 2001 March 26 2001 May 18 2001 March 26 2001 June 5 2001 June 20 2001
March 26 2001 March 26 2001 March 26 2001 August 1 2001
July 2 2001 July 9 2001 July 16 2001 July 30 2001
Completion Date March 23 2001 May 18 2001 May 25 2001 June 4 2001 June 19 2001 June 29 2001
June 29 2001 June 29 2001 June 29 2001 August 31 2001
August 17 2001 July 13 2001 July 27 2001 August 15 2001
RI01635DF 5-1 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
EEC
AEN
GINE
ERS
PR
OJE
CT
E (T B
D)
(pound O 5= Q- X C -3 _ HI ^
HI
CO Q
O
^j HI HI p
mdash
b m ^J ^^
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01 fc O OO~lt UJ 0 a co 3 in
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n ^3 Q^ III yj d 1tmdash CO fi ^ o a lt 0 t3 8a Q a HQ_ n
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50
HHI o O bullS 8
v_ OLL H a o O C 0)
iojui ^0CO 9 N tiid$lt U- D laquogt_ LL O
fc _i 08 -5 X
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1
RIS
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S 3
ES
SM
EN
T
C W
Olt D
OS (H
H)
A
BE
RN
H A
RD
T (E
CO
)
Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
ActivityDeliverable Start Date Completion Date Chemical Analysis July 31 2001 September 19 2001 Data Validation September 5 2001 October 10 2001 Data Reduction Tabulation Evaluation October 10 2001 October 24 2001 Draft Data Evaluation Report October 17 2001 November 1 2001 EPA Review Comment November 2 2001 November 23 2001 Draft Streamlined Risk Evaluation October 24 2001 December 19 2001 Draft EECA October 24 2001 February 6 2002 EPA Review Comment February 7 2002 February 28 2002 Final EECA March 1 2002 March 18 2002
53 Quality Assurance and Data Management
All work will be performed in accordance with the TtNUS RAC I Quality Assurance Project Plan
and Quality Management Plan which were attached to the contract
54 Project Costs
The overall cost for performing the activities included under this work assignment and as
described in this Work Plan is presented in a separate document the Detailed Cost Estimate shy
Base Period
RI01635DF 5-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
EEC
AEN
GINE
ERS
PR
OJE
CT
E (T B
D)
(pound O 5= Q- X C -3 _ HI ^
HI
CO Q
O
^j HI HI p
mdash
b m ^J ^^
QL SHI IX O HI
01 fc O OO~lt UJ 0 a co 3 in
Qi S Q OL CD O lt h- laquo c mdash fy n lt rv ^3 O c - =
O ^j ^C fO t^
S ccc
n ^3 Q^ III yj d 1tmdash CO fi ^ o a lt 0 t3 8a Q a HQ_ n
Z HI c
oHI O
SI TO Z HI lt mdash
a HI
50
HHI o O bullS 8
v_ OLL H a o O C 0)
iojui ^0CO 9 N tiid$lt U- D laquogt_ LL O
fc _i 08 -5 X
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1
RIS
K A
S 3
ES
SM
EN
T
C W
Olt D
OS (H
H)
A
BE
RN
H A
RD
T (E
CO
)
Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
3IO
NA
LO
FF
ICE
RA
HA
N
mdash
QL
ltf - 5Qgt Z
EEC
AEN
GINE
ERS
PR
OJE
CT
E (T B
D)
(pound O 5= Q- X C -3 _ HI ^
HI
CO Q
O
^j HI HI p
mdash
b m ^J ^^
QL SHI IX O HI
01 fc O OO~lt UJ 0 a co 3 in
Qi S Q OL CD O lt h- laquo c mdash fy n lt rv ^3 O c - =
O ^j ^C fO t^
S ccc
n ^3 Q^ III yj d 1tmdash CO fi ^ o a lt 0 t3 8a Q a HQ_ n
Z HI c
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SI TO Z HI lt mdash
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50
HHI o O bullS 8
v_ OLL H a o O C 0)
iojui ^0CO 9 N tiid$lt U- D laquogt_ LL O
fc _i 08 -5 X
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1
RIS
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S 3
ES
SM
EN
T
C W
Olt D
OS (H
H)
A
BE
RN
H A
RD
T (E
CO
)
Q) O
RI01635DF 5-3 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
60
DRAFT FINAL
EQUIPMENT AND SUPPLIES
The following equipment and supplies are expected to be needed during the performance of
the work assignment See the Draft Final Detailed Cost Estimate for additional details of
equipment and supply needs and costs
Non-consumable Equipment
bull Flame lonization Detector (FID)
bull Photo lonization Detector (PID)
bull Lower Explosive LimitOxygen (LELO2) meter
bull Hydrogen Sulfide meter
bull ORP Probe
bull Respiratory protection equipment (Levels B and C)
bull Global Positioning System (GPS) equipment
bull Electronic water level meter
bull Videodigital camera (to document test pitting and other field activities)
bull Utility workboat w motor (for collecting samples from open lagoon)
bull Work vehicles (box truck pickup truck cargo van)
bull Cellular phone
bull Computers and printers CAD plotter and copiers
Consumable Supplies
bull Health and Safety Supplies protective clothing gloves boots respirator cartridges
portable eye wash floatation vests ear plugs safety glasses first aid kit
bull Sampling supplies Shovels trowels PVC pipe scoopulas bowls stakes flagging
spray paint paint pens preservation chemicals calibration gas
bull Shipping supplies coolers packing tape vermiculite zip-lock bags
R101635DF 6-1 Mohawk Tannery N H
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH
DRAFT FINAL
Decontamination supplies brushes spray bottles detergent rinses buckets garbage
bags plastic sheets
Documentation supplies logbooks disposable cameras film batteries pens markers
RI01635DF 6-2 Mohawk Tannery NH