ri01635df draft final work plan other › work › 01 › 33080.pdf · an approximatel 15 acrye...

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RI01635DF Superfund Rt'cordi£enier DRAFT FINAL BREAK: WORK PLAN OTHER: ENGINEERING EVALUATION/COST ANALYSES MOHAWK TANNERY SITE NASHUA, NEW HAMPSHIRE RESPONSE ACTION CONTRACT (RAC), REGION I For U.S. 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.

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Page 1: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

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

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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

Page 2: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

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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

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

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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

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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

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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

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

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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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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

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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

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

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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

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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

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

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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

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

Page 7: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

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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

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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

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

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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

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

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

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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

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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

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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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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

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

Page 10: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

DRAFT FINAL

FIMBEL DOOR COMPANY

FIMBEL LANDFILL

BOSTON amp MAINE RAILROAD

lv

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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

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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

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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

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

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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

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

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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

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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

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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

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

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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

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

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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

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

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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

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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

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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

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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

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

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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

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

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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

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

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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

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

Page 22: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

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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

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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

Page 25: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

Page 26: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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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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

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NA

LO

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ICE

RA

HA

N

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^j HI HI p

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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

Page 27: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

DRAFT FINAL

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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

Page 28: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

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RA

HA

N

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T (E

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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

Page 29: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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

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HHI o O bullS 8

v_ OLL H a o O C 0)

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T (E

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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

Page 30: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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 ^

HI

CO Q

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^j HI HI p

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b m ^J ^^

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SI TO Z HI lt mdash

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HHI o O bullS 8

v_ OLL H a o O C 0)

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T (E

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)

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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

Page 31: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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 ^

HI

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^j HI HI p

mdash

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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

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50

HHI o O bullS 8

v_ OLL H a o O C 0)

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fc _i 08 -5 X

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K A

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EN

T

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H)

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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

Page 32: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

DRAFT FINAL

3IO

NA

LO

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RA

HA

N

mdash

QL

ltf - 5Qgt Z

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AEN

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ERS

PR

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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

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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

Page 34: RI01635DF DRAFT FINAL WORK PLAN OTHER › work › 01 › 33080.pdf · an approximatel 15 acrye developed t parceo th northel an,d a approximateln 15 acr ye undeveloped parce tol

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