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r^i Bechtel Oak Ridge Corporate Center 151 Lafayette Drive P.O. Box 350 Oak Ridge, Tennessee 37831-0350 Telephone: (423) 220-2000 January 24, 1996 Mr. Edward J. Hanlon, Remedial Project Manager U.S. Environmental Protection Agency Region V (HSRM-6J) 77 West Jackson Chicago, IL 60604-3590 SUBJECT: FIELDS BROOK SEDIMENT OPERABLE UNIT SUPERFUND SITE REMEDIAL DESIGN. Bechtel Job No. 22257-010 Comment Response Report for the Intermediate (60%) Design Report References: 1. Letter from B. C. McConnel to E. Hanlon, dated August 28, 1995, Subject: Final Design (60-, 90-, and 100-Percent) Work Plan. 2. Letter from B. C. McConnel to E. Hanlon, dated October 20, 1995, Subject: Intermediate (60-Percent) Design Report. 3. Letter from B. C. McConnel to E. Hanlon, dated February 16, 1995, Subject: Preliminary (30%) Design Report. 4. Letter from E. Hanlon to J. Heimbuch, dated December 13, 1995, Subject: Comments to October 20, 1995, Draft Sediment Operable Unit Intermediate (60%) Design Report. 5. Letter from E. Hanlon to J. Heimbuch, dated December 27, 1995, Subject: Additional Comments to 10/20/95 Draft Sediment Operable Unit Intermediate (60%) Design Report Fields Brook Superfund Site. Dear Mr. Hanlon: Enclosed for your review and comment are the responses to EPA comments (References 4 and 5) on the Intermediate (60%) Design Report. FBAG will be prepared to discuss these responses at the February 8, 1996, meeting in Chicago. If you have any questions, please call me at (423) 220-2570. B. CMcConnel Project Manager Enclosure: as stated BCM/mas A0231 1/24/96 2:30pro Bechtel Environmental, Inc.

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Page 1: BECHTEL INC LETTER RE: COMMENTS/COMMENT …

r^i

BechtelOak Ridge Corporate Center151 Lafayette DriveP.O. Box 350Oak Ridge, Tennessee 37831-0350

Telephone: (423) 220-2000

January 24, 1996

Mr. Edward J. Hanlon, Remedial Project ManagerU.S. Environmental Protection AgencyRegion V (HSRM-6J)77 West JacksonChicago, IL 60604-3590

SUBJECT: FIELDS BROOK SEDIMENT OPERABLE UNIT SUPERFUND SITEREMEDIAL DESIGN. Bechtel Job No. 22257-010Comment Response Report for the Intermediate (60%) Design Report

References: 1. Letter from B. C. McConnel to E. Hanlon, dated August 28, 1995, Subject:Final Design (60-, 90-, and 100-Percent) Work Plan.

2. Letter from B. C. McConnel to E. Hanlon, dated October 20, 1995, Subject:Intermediate (60-Percent) Design Report.

3. Letter from B. C. McConnel to E. Hanlon, dated February 16, 1995, Subject:Preliminary (30%) Design Report.

4. Letter from E. Hanlon to J. Heimbuch, dated December 13, 1995, Subject:Comments to October 20, 1995, Draft Sediment Operable Unit Intermediate(60%) Design Report.

5. Letter from E. Hanlon to J. Heimbuch, dated December 27, 1995, Subject:Additional Comments to 10/20/95 Draft Sediment Operable Unit Intermediate(60%) Design Report Fields Brook Superfund Site.

Dear Mr. Hanlon:

Enclosed for your review and comment are the responses to EPA comments (References 4 and 5) on theIntermediate (60%) Design Report. FBAG will be prepared to discuss these responses at theFebruary 8, 1996, meeting in Chicago.

If you have any questions, please call me at (423) 220-2570.

B. CMcConnelProject Manager

Enclosure: as stated

BCM/mas

A02311/24/96 2:30pro

Bechtel Environmental, Inc.

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cc: NOAA, Ron Gouget (1 copy)USACE-Buffalo, Steve Golyski (3 copies)USEPA, David Charters (1 copy)USDOI, Don Henne (1 copy)USEPA Mark Meckes (1 copy)USFWS, Bill Kurey (1 copy)OEPA, Regan Williams (3 copies)CH2M Hill-Milwaukee, Laura Weyer (1 copy)CH2M Hill, Kevin Klink (1 copy)CH2M Hill, Ohio, Jack Dingledine (1 copy)USACE-Omaha, Rober J. Curnyn (1 copy)USACE-WES, Ron Heath (1 copy)

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COMMENTS ON THE 10/20/95 DRAFT SEDIMENT OPERABLE UNITINTERMEDIATE (60%) DESIGN REPORT AND THE DESIGN INVESTIGATION

REPORTS, FIELDS BROOK SUPERFUND SITE

A) General Comments on the Design

Comment 1: As noted in previous meetings and comment letters, EPA remains concerned thatthe project will be significantly delayed at the 90% RD stage because key designconcepts will first be submitted for review at that time. These concepts includeqffsite thermal specifications, offsite landfill specifications, offsite solidificationrequirements (and whether in-situ solidification and associated specificationsremain Bechtel's concept), materials handling specifications, specificationrequirements as to how the contractor is expected to meet cutlines as drawn,specific access needs and efforts to procure access from property owners,specifications for how existing facilities (structures, utilities, roads) will be assuredof being protected from destruction and/or contamination, particularly since off-site transportation is being considered (for example, requirements for videotaping,pictures, etc. such as was required for the Bayou Bonfouca site), requirements fora preconstruction property condition survey to help ensure that the constructionfirm does not damage property, requirements for construction impact assessmentinformation and whether and how the project will meet Clean Water Act (CWA)Sections 401 and 404 requirements, ARARs issue resolution and how specificationswill be written to meet ARARs, work sequencing specifications to ensure that theconstruction occurs property, and various other items discussed below. EPArequests to discuss concepts and schedule for resolution of these issues withFBPRPO on a conference call to occur within two weeks of receipt of thesecomments. Further, because a number of specification sections will not beprovided until the 90% RD submittal, EPA reserves the right to comment again onthe sections affected by the sections not yet submitted.

Also, EPA reiterates its concern that a number of major issues have been left to beprovided by the remedial action contractor, such as the design/determination ofrequirements for wastewater treatment systems, O&M, haul road specific locationsto and from the Brook, Sections 401 and 404 of the Clean Water Actrequirements, substantive requirements of other ARARs, and borrow source areas,and EPA requests to discuss with FBPRPO why FBPRPO pursues this strategy,including whether delaying the submittal of details to the construction phase wouldbe expected to pose significant problems during the execution of the remedialaction. While EPA recognizes that may be more practical for portions of thedesign to develop performance-type specifications which leave the means andmethods of construction to the remedial action contractor, the bidding documentsmust provide minimum criteria to be met, or describe in greater detail theinformation to be provided to demonstrate that the means and methods will work.Without this information, the applicability and appropriateness of the designcannot be adequately evaluated. A clear understanding regarding: a) howdeliverables will be handled and approved during construction, b) what portionswill be performance vs. design specification, and c) schedule implications for theconstruction, must be provided, so that EPA can review and potentially agree toFBPRPO's procurement strategy. Also, regarding procurement in general, anoverall project Acquisition Strategy was previously requested (e.g., EPA's 1/8/93letter), which describes in part requirements for, and how FBPRPO plans toassure, contractor responsibility and responsiveness during the bidding process.

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FBAG Response:

General: The Fields Brook remedial design includes several performance-based specifications forwhich a detailed design will not be completed. EPA has approved the use of performance-basedspecifications for portions of the Fields Brook SOU remedial design and, therefore, mustunderstand that these details will be provided by the remedial action contractor.Contractor-specific submittals detailing the contractor's approach in meeting dieperformance-based design specifications can be met only after the contractor is selected. FBAGbelieves that all critical elements of the remedial design have been submitted for EPA review.Submittal of the remaining details with the prefmal (90%) design or during the preconstruction oreven construction phase will not affect successful execution of the remedial action.

Specific. The following responses address the items identified in the first paragraph ofComment 1:

Material sent for offsite treatment and disposal will be sent to a treatment/disposal facilitypermitted to accept RCRA and TSCA wastes. Specifications for offsite treatment and disposalwill be developed as part of the subcontracting package(s) to be developed for treatment anddisposal services.

Material handling specifications were included in the Intermediate (60%) Design Report; theywere Section 02130, Material Handling, and Section 02145, Screening of Sediments.Section 02135, Offsite Transportation, was not a key specification and will be provided in the90% design.

Excavation is addressed under Section 02110, Earthwork. Excavation of contaminated sedimentwill be in accordance with the performance-based technical requirements described inSection 02110.

The strategy for obtaining access agreements was detailed in the Final Design Work Plan(FDWP). EPA has been provided with maps showing property lines and construction limits.Individual property maps will be developed with individual access agreements. These materialswill be developed once the full impact of FWA remedial activities have been determined (i.e.,during the FWA remedial design).

Protection of property is addressed under Division 00800 - Special Conditions, Section SC-3,Protection of Property. This section states that the remedial action contractor shall conduct itsoperations in a manner that does not damage, close, or obstruct any utility installation, highway,road, or other property until permits have been obtained.

A survey of existing conditions will be completed using preconstruction photographs. Thesephotographs will be compared with post-construction photographs to identify any impacts fromthe remedial construction activities.

A Construction Impact Assessment Report was submitted to EPA as an appendix to the DraftFWA Feasibility Study on December 15, 1995.

ARARs issue resolution will be addressed in the ARARs compliance document to be submitted toEPA by the Fields Brook legal committee in early 1996. Specifications for the Fields BrookSOU were developed based on an analysis of ARARs and have been written to meet theserequirements.

A construction schedule will be submitted with the 90% design.

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Design requirements for the wastewater treatment plant are defined in Section 13200,Wastewater Treatment. The specification describes the minimum system requirements for awastewater treatment system. Data sheets that identify site-specific performance requirements fortreating water were inadvertently left out of the 60% design; these data sheets are Appendix A tothis comment/response package.

O&M requirements will be submitted with the 90% design.

Specific locations for haul roads between the brook and access roads will be selected in the fieldbased on field conditions and construction requirements.

FBAG will coordinate with USAGE and OEPA to determine specific requirements related tosatisfying requirements under Clean Water Act (CWA) Sections 401 and 404.

No borrow materials are to be used in remediation of the SOU.

The specification for stream diversion is a performance-based specification that establishes thetechnical requirements for construction. The remedial action contractor will determine thespecific technical details required to attain the performance criteria for stream diversions.

Excavation areas are as shown on the excavation plan and profile sheets (Drawings C-01 throughC-ll).

See the responses to General Comment 8 regarding VOC releases.

FWA issues will be addressed in the FWA design.

Diversion and trenching stability requirements will be determined in the field.

Specifications for haul roads will be provided in the Section 02001, Site Preparation. Haul roaddetails are shown on Detail Sheet No. 1, Drawing No. C-16. The width, depth, and disturbancerequirements are indicated on Detail Sheet No. 1 and the excavation plan and profile sheets(Drawings C-01 through C-ll); haul road routes are also shown on Drawing C-12.

Construction impacts associated with the haul roads were assessed in the Construction ImpactAssessment Report submitted with the FWA Feasibility Study.

Requirements for protection of excavation areas are described in Part 3.8, Channel Protection inSection 01000, Summary of Work. Additional protective measures, including the use of siltfences, will be used as described in Section 02271, Erosion Control, to be submitted with the90% design.

Design calculations regarding surface water control options will be submitted with the 90%design.

Sections 01300, Submittal Descriptions, and 01305, Submittal Procedures, define how thedeliverables will be handled and reviewed. The list attached to the specification will becompleted for the 90% design. The list of submittals could not be completed until allspecifications are completed.

The procurement strategy is described in the Preliminary (30%) Design Report, Section 11.FBAG intends to procure the remedial action contractor without EPA involved in the selectionprocess.

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Comment 2: FBPRPO was requested in EPA 's 9/29/95 letter to provide plans, procedures andspecifications which will provide details of the excavation and constructionactivities planned for the FWA and Brook areas, requirements to prevent releasesfrom the excavation pit areas and Retention Basins within stream diversion areasif storms more severe than a 2-year 24 hour event occur, submission of astormwater pollution plan to specifically identify requirements to prevent point-source releases during construction in a manner which would meet all water-quality ARARs, and provide details of how requirements of Sections 401 and 404of the Clean Water Act would be met. The Stream Diversion (section 02120) andSpill Prevention and Control specifications (section 01495) do not provide anyspecifications regarding retention basins, excavation pit requirements, maximumallowable pit sizes due to the potential for unacceptable VOC releases, specificarea(s) within the FWA where diversion and construction activities are to beavoided, diversion and trenching stability requirements including under whatconditions sheet piles vs dikes vs sandbags will be used, haul road specificationsincluding specific locations (and whether there is flexibility for the locations) andmaximum width, depth, and disturbance requirements, and other relatedconstruction-impact considerations. Also, as noted in EPA's 1/8/93 letter,requirements for the protection of stream diversion and excavation pit areasagainst off-hour rainstorms are expected, including consideration of the use ofprotective canvas covers over excavation pit areas and downstream siltfences/screens (of approximately 70-100 mesh (US standard sieve)), to preventreleases; design calculations regarding surface water control options are alsoexpected.Construction work in the FWA area raises particular concerns regardingprotectiveness since there is greater potential for releases of contamination duringconstruction (particularly during storm events) than for other upland Superfundprojects. Also, there is a particular need in this project to carefully avoiddisturbances in specific FWA areas due to considerations regarding value ofhabitat and FWA remedy requirements. FBPRPO is requested to consider anddiscuss in a comment response report whether delaying the submittal of details tothe construction phase would be expected to pose significant problems during theexecution of the remedial action, and also whether the more efficient and cost-effective approach is to conduct a detailed design presently for all work to beconducted within the Brook/FWA area. FBPRPO should be aware that OEPA andUSACE will be conducting reviews of this design to help ensure that thesubstantive requirements ofCWA Sections 401 and 404 are met; to help facilitateFBPRPO's development of this design, FBPRPO may contact Linda Merchant ofOEPA, at 614-644-2135 to discuss substantive requirements of CWA Section 401,and Steve Gofyski of USACE at 716-879-4228 to discuss substantive requirementsof CWA Section 404.

FBAG Response:Design and construction details related to the FWA will be submitted in a separate design reportfor the FWA. The 60% design for the SOU contains plans, procedures, and specifications forexcavation and construction work in the brook.The stream diversion system (as detailed in Section 02120, Stream Diversion, and relateddrawings) was designed to divert stream flow during normal flow conditions. The diversionsystem is not designed to handle storm flows. There are no retention basins within the streamdiversion areas, but rather check dams and sumps designed to temporarily divert water into thediversion pipelines to facilitate excavation. The retention basins in the pretreatment area are

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designed to handle runoff related to a 2-year, 24-hour storm event. Any releases that occurbecause of storms larger than the design storm would be mitigated as described in Section 01495,Spill Prevention and Control.

Sediment excavation work will cease during precipitation events. A geotextile filter fabric will beplaced over any exposed excavation areas at the end of each day or if rain begins to fall duringworking hours to prevent scour and release of contaminated sediment. All excavated areas willbe covered with riprap no later than 3 working days after excavation is completed to furtherminimize the potential for erosion. Section 02271, Erosion Control, to be submitted with the90% design, will provide additional information concerning the engineering controls to be used tominimize releases from the construction areas within the brook.

Stormwater pollution plan requirements are effectively addressed in the earthwork and erosioncontrol specifications (Sections 02110 and 02271, respectively).

Issues regarding compliance with the CWA 401/404 requirements with regard to potentialreleases caused by storm events will be identified and resolved in coordination with USAGE andOEPA, as discussed in the response to General Comment 1.

Issues related to construction impacts in the FWA were evaluated in the Construction ImpactAssessment Report submitted with the FWA Feasibility Study Report.

See the response to General Comment 1 regarding the submittal of details during thepreconstruction phase.

Comment 3: As discussed in EPA's 3/17/94, 4/14/95, 6/14/95 and 9/29/95 letters, allsediments to be excavated that do not require thermal treatment are to besolidified prior to disposal in a facility permitted by RCRA and TSCA.Specifications and drawings for solidification were to be provided within the 60%RD, but were not, and must be submitted within the 90% RD consistent with theabove-noted EPA letter requirements. A solidification design requires a minimumamount of testing to assure that the remedy will be protective, including testing forfreeze/thaw, flash point, organics, and reactivity during construction to provideassurance that the materials will be landfilled in a protective manner. FBPRPO isrequested to propose specific testing methods and frequency in the 90% RDforthese criteria, including specifics on how many samples must be taken, QA/QCsamples will be collected, and what type of analysis and methodology will thesamples be subjected to.The 60% RD's dewatering specifications and drawings are not clear regardingspecific requirements and restrictions to the contractor. As discussed withinEPA's 6/14/95 comments, EPA would not accept the original dewatering proposalfor bankside drainage without collection of the drainage water and withoutcontrols to ensure that spills and releases to the environment from these areas didnot occur during such materials handling. Since this approach does not appear tobe currently planned, and since approach was considered unacceptable, thespecifications must make clear this restriction. Also, since FBPRPO's in-situstabilization also appears to now not be currently pursued, the specifications mustalso make clear this restriction.

If FBPRPO pursue the proposal to design and conduct in-situ solidification of thesediments, information is required to be provided before it can be accepted (andmust be submitted within, including: proposed concepts for the solidificationprocess, whether there will be any residual construction impact effects to the

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Brook and floodplain/wetland area (FWA), assurances that the wet-cemented masswill be excavated prior to curing, calculation of how much residual material isexpected to be left in the brook, what QC will be conducted on stabilizationmaterials to ensure they are not contaminated, details of the methods andmaterials to be used, whether use of kiln dust and fly ash would be acceptablegiven the potential for presence of contaminants, and other related informationwhich would ensure that the process is conducted safely. Also, since there may bereleases of VOCs during this process, consideration of air impacts to nearbyresidences and people should be provided in the concept plan. Lastly, if the RAcontractor is to use "customized methods" for adsorbents, the performance specshould indicate that he needs to submit specific info such as TCLP data on theproposed absorbent. Since this information has not been submitted by FBPRPO,EPA assumes that all solidification to be conducted will be conducted ex-situ.

FBAG Response:

All sediments that do not require thermal treatment will be solidified prior to disposal. FBAGwill prepare a specification for offsite treatment and disposal with the contracting package fortreatment and disposal services.

Sections 01000, Statement of Work; 02110, Earthwork; and 02130, Material Handling, clearlystate that the contaminated material requiring incineration will be directly loaded into watertightcontainers and trucked to the pretreatment area. The contaminated material not requiringincineration will be loaded onto dump trucks and transported to the disposal facility.

The remedial design is to remove and transport the contaminated material to an offsitetreatment/disposal facility. No in situ solidification is specified and, therefore, there will be noresidual impact from in situ solidification.

Admixtures may be added by the contractor to adjust the moisture content of the excavatedmaterials; however, all solidification/stabilization will be conducted at the offsitetreatment/disposal facility.

Comment 4: As previously requested and as noted in EPA's 6/14/95 and 9/29/95 letters, noinformation has been submitted to date by FBPRPO regarding the feasibility ofoffsite landfilling vs. onsite landfilling which might provide a basis forconsideration of offsite landfilling. EPA is willing to consider offsite disposaloption far the Brook sediment remedy if FBPRPO submits a proposal/analysiswhich evaluates the offsite disposal option with consideration of all nine criteria,and compares it to the on-site option. This analysis must also consider thepotential for schedule impacts due to the potential change in design strategy. EPAwill respond to FBPRPO as soon as possible once this analysis is providedregarding whether the offsite disposal option will be acceptable. In this analysis,FBPRPO should discuss the CERCLA Section 121 bias against off-site landdisposal of untreated waste, and NCP section 300.430(f)(l)(ii)(E) discussion thatan alternative that relies on the off-site transport and land disposal of untreatedhazardous substances will be the least favored alternative. FBPRPO should alsodiscuss and compare total off-site disposal costs including those of solidifiedmaterials, the potentially large volume of 'construction related' soils and debris,the potential for significant additional volumes which might need to be removedfrom and related to the FWA remediation.

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FBAG Response:

The Analysis of Offsite Treatment and Disposal Option was transmitted to EPA onJanuary 10, 1996.

Comment 5: Specifications for off-site RCRA- and TSCA-compliant landfill and thermaltreatment facilities, were to be provided within the 60% RD, but were not, andmust be submitted within the 90% RD.

FBAG Response:

See the response to General Comment 1.

Comment 6: As required previously, access requirements for construction were required to bedetailed within the 60% RD; however, no procedure describing FBPRPO'sstrategy for access was provided, nor any specific areas and access needsidentified. FBPRPO's 9/95 "Real Estate Access Information" document also doesnot provide these specific needs and procedures to be followed; EPA will beproviding FBPRPO with specific comments to that report by 22/30/95. EPArequested FBPRPO to submit information sufficient to receive access for review byand/or within the 60% RD, in part to help ensure that this issue is resolved. Asdiscussed, this issue may cause significant schedule delays if put off any further.While specific comments will be sent to the 9/95 document by 12/30/95, FBPRPOis requested to submit a plan which indicates FBPRPO's plan to receive all accessrequired for the project to be constructed. This plan should include descriptionsof procedure/requirements to be followed and locations needed for temporary andpermanent access, real estate acquisition, temporary or permanent easements, andother forms of access if necessary. This information would likely includedescriptions of specific properties requiring access agreements, descriptions ofaccess needs per property, figures outlining access needs per property, and otherinformation required to attain access.Figures indicating location of haul roads (including details regarding roads goingfrom the Brook area up to the existing roadways such as those provided by WCCin their pre-30% RD deliverables), temporary storage areas, and other locationalspecifics for construction down to, along and within the Brook should also bedeveloped by 1/96; these figures should also identify any specificconstruction/roads and/or access required on/to individual properties.

FBAG Response:

The access strategy is presented in the Preliminary (30%) Design Report, Section 13. Theconstruction limits (clearing) are shown on design Drawings C-01 through C-ll, and theconstruction limits are also shown on the property tax maps. Individual packages will beprepared for property owners showing their properties and the areas to be affected by theremedial action. Property lines will not be shown on the remedial design drawings.

Comment 7: Safety to the residents will likely be a key issue at a site where PCBs, HCB, vinylchloride, mercury and cyanide are present. The design does not address safetypoints and considerations to residents in detail The 90% RD must describe howHASP requirements will be carried out (including noise limits, limits onconstruction hours, monitoring assurances, and related concerns).

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FBAG Response:

The contractor's safety and health plan will provide the details requested, and a limit onconstruction hours in the residential areas (Reaches 1-3) will be worked out with the residentsand local officials. No limitation on working hours will be required in the industrial park areas.

Comment S: As discussed within EPA 's 6/14/95 comments, when this project goes toconstruction it will emit contaminants to the air from various area sources(sediment handling operations) and point sources (e.g., vents from treatmentprocesses). The acceptability of and limits for emissions to the air from thesesources is not addressed in the design investigation reports nor within thespecifications, and it is requested that they do so. Such efforts will help addresspublic concerns, may result in specific and appropriate engineering controls to bespecified, and would assist in the specification for a reasonable air monitoringsystem design. Air emissions expected from such activities and areas must beassessed and referenced in the various sections to which this comment applies(e.g., excavation, solidification, facility siting, wastewater treatment), and an airpathway analysis presented per section. Presentation of expected emission rates(estimates) should be included from area sources for each process or activity.Also, specific design criteria and draft specifications for air monitoring andcontaminant release control measures to be conducted should be provided andsubmitted within the 90% ftp. For example, as noted within EPA's 4/28/93 letter,the use of protective remedial measures to prevent VOC releases duringconstruction, such as foams and the use of negative pressure ''elephant hoses"near excavation areas, should be considered in the specifications for contingentuse.

FBAG Response:

Section 01200, Part 3.6.1 provides stop work trigger limits for airborne emissions offsite. Thesetrigger levels are 0.02 of the occupational exposure limits for the contaminants of concern andare the industry-wide standard for emission limits where no EPA or local standard exists.

Projecting air emission rates and performing air pathway analyses would be superfluous becauseair monitoring will be performed at all potential sources during the work, and stop work triggerlevels have been specified and are fully protective for the general public. In addition,contaminant levels onsite are not anticipated to create offsite releases in excess of the stop worktrigger levels. EPA has agreed that the requirement to perform calculations of expected emissionrates and air path analyses would not be necessary provided that Part 3.6 of the safety and healthspecification be revised to:

• Provide a discussion of which site activities would have the greatest potential to createoffsite emissions

• Provide specific guidelines for the locations and frequency of perimeter air monitoringduring various site activities

Comment 9; EPA requested that a construction 'schedule optimization' analysis be providedwithin the 60% RD, and also requested that a construction schedule itself besubmitted; this should be provided and submitted within the 90% RD.

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FBAG Response:

A construction schedule will be included with the 90% design,

Comment 10: As discussed previously and noted within EPA 's 4/4/95, 4/14/95, and 6/29/95letters, FBPRPO must provide drawings and specifications for the specificrequirements/measures to be implemented to prevent the short- and long-termerosion, exposure; and/or migration of any cutline or erodible areas within theBrook after remediation; these specifics include riprap size, depth and installationprocedures, materials handling requirements, and stream diversion considerations.

EPA through USACE-Buffalo conducted a comparison of the excavation plans andprofiles with areas identified within the SQDI Phase 1 and Phase 2 reports, andgenerated approximate mean channel velocities for erosion of cohesive materials.Specific comments to this issue are included as an attachment to these comments;in summary, the specific comments describe the various significant areas of theBrook in non-excavation areas which would have greater than 4.5 fi/sec flowduring 100-year storms, and at such velocities, significant erosion would beexpected. As discussed previously in meetings and the above-noted letters, erosionof these areas would likely result in releases of contamination which may result ina non-protective remedy. Drawings and specifications to prevent erosion inexcavation and non-excavation areas of the Brook are required (including thoseunprotected bank areas indicated in the enclosed comparative analyses), and arerequested to be provided and submitted within the 90% RD, to ensure long-termprotectiveness of the remedy.

FBAG Response:

The specific details for controlling erosion of the excavated area are specified in Sections 01000,Statement of Work; 02110, Earthwork; 02120, Stream Diversion; and 02130, Material Handling,and are shown on the design drawings. The specifications require the contractor to install thegeotextile at the end of each day to prevent erosion of the excavated streambed. Thespecifications also require the contractor to backfill the excavations with riprap within 3 workingdays after the excavation has been completed.

The velocity criterion of 4.5 ft/s is probably adequate for the areas associated with theconstruction and expansion of the flow upstream and downstream from bridges, and these areaswill be excavated and backfilled with riprap as shown on Drawings C-l through C-ll. The 4.5ft/s velocity criterion in Reaches 1 and 2 is not appropriate because these reaches are generallyon bedrock and the velocities can be higher without causing erosion.

The velocity in Reach 8 is not in an area to be excavated, and FBAG does not plan to placeriprap in areas that do not require excavation.

EPA's May 18, 1994, letter on "Preliminary Draft Comments to 4/26/94 Draft RecontaminationAssessment SCRI Report; Source Control OU; Fields Brook Site" contained a comment by EPAthat "areas cleaned within the Brook to non-detect might be contaminated with inflowingcontamination to concentrations below CRG's, but above CUGs..." and "...even if incomingconcentrations were limited to CUGs, the statistics in the Brook after remediation might still beadversely affected..." FBAG responded to these concerns in Attachment 1 to the "AnnotatedAgenda for Scheduled June 16, 1994 Teleconference, Response to USEPA Preliminary DraftComments to 4/26/94 Draft Recontamination Assessment, Section 6.0 SCRI Report." A copy ofthis attachment is provided as Appendix B to these responses.

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EPA's new concern as expressed in the "Comments to 10/20/95 Draft Sediment Operable UnitIntermediate (60%) Design Report Fields Brook Superfund Site" appears very similar. EPA isconcerned with releases of contaminated material in nonexcavated areas that occur duringerosion, "which may result in a non-protective remedy." However, by definition, any area wedo not excavate is below the CRG, and if it is moved from one place to another, the averagewould not change.

EPA is reraising a predesign issue discussed in the past, notably in the 5/18/94 comments formEPA to the PRPs and in the 6/16/94 response by the PRPs to EPA. The CRG approach, whichhas been previously agreed upon, ensures that average concentrations are met post-remediation,and the effects of erosion, transport, and dilution will not affect this average concentration.Therefore, FBAG does not intend to place riprap in areas that do not require excavation.

Comment 11: Specifications regarding excavation to the depths indicated on the drawings, andto a two foot depth of sediments/soils on the channel sideslopes, are required.For example, specs which note that if bedrock is encountered during construction,no further excavation is required should be provided. Also, as required in theROD, specs which require that erosion protective and resistant materials will bebackfilled in all excavated areas as well as to areas which are not excavated butare expected to be prone to erosion are needed, as well as specs which provide forremoval of any areas of "highly contaminated material" uncovered duringremediation at depths deeper than sediment ("highly contaminated material" wouldbe defined qualitatively: e. g., drums; pure product oozes, etc.).

FBAG Response:

The excavation of contaminated sediments is addressed in Section 02110, Earthwork, whichclearly defines the excavation procedure, including what to do if highly contaminated material isencountered (e.g., drums, free waste material). Design Drawings C-02, 03, and 04 clearly statethat excavation will stop at the depth designated on the drawing or at bedrock if encounteredbefore that depth is reached.

Comment 12: EPA will review the 30% RD cost analysis, construction impact assessment,ARARs response, and any other documents FBPRPO noted it will submit withinthe next few weeks upon submittal,

FBAG Response:

FBAG acknowledges the comment.

Comment 13: The 60% RD Report does not provide the following information expected for anintermediate design, and are required to be submitted within the P0% RD):a. Design criteria specific enough to identify conceptual design requirements,

equipment sizes or materials requirements. Some design criteria wereprovided, but only for some equipment.

b. The ARARs discussion is minimal, and the specific manner in which the designis affected by each ARAR is not designed or presented.

Specific information which was requested within the 60% RD but was notprovided, includes various items noted below.

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d. Contingency Plan conceptual requirements, including (as discussed in EPA 's4/28/93 letter) supplies, training, and equipment availabilities at the locallevel, equipment and personnel to perform emergency measures required tocontain any spillage and to remove and property dispose of any media thatbecome contaminated due to spillage, and equipment and personnel to performdecontamination measures that may be required to remove spillage frompreviously uncontaminated structures, equipment, or material.

e. Run-on and Runoff Control Plan, including specifications for final grading,drainage, hydraulic analysis and details of hydraulic structures, rip-raperosion control, and flood and sedimentation control structures. Calculationsshould be provided in an appendix.

f. Description of systems, eg, wheel washes, to prevent contamination of accessroutes.

g. Detailed description of liner system and leachate collection, detection, andremoval systems for the decon and dewatering bed. Liner information shouldaddress materials of construction, geotechnical issues such as ability of linersto withstand stress and loads imposed by waste, bearing capacity of theunderlying foundation, sideslope stability. Calculations should be provided inan appendix.

h. Specifications for materials to be used in leachate collection systems.i. Specifications for stability of drainage layers, pipe strength calculations.

Calculations should be provided in an appendix.j. Provide design basis for ditches, sediment basins, etc

k. Specifications for haul routes and mitigation/contingency plans in the event ofa spill.

1. Specifications for how water will get Jrorn working area to the treatment area.It would seem appropriate that any water pumped from the working area tohelp facilitate excavation or dewatering either be treated at the CRF or betested prior to discharge if untreated.

m. Specifications for requirements to address a diversion dike overflow andprevent redistribution of sediment within the excavation area or inflow ofsediment from the upstream waters flowing into the excavation.

FBAG Response:

a. Bechtel agrees that some of the design criteria were not included in the Intermediate (60%)Design Report and will be provided in the 90% design.

b. The legal committee is preparing a document on ARARs that will be submitted underseparate cover.

c. A draft post-closure plan (operation and maintenance plan) will be included with the 90%design as stated in the FDWP. The post-closure plan will be for a 1-year period after theremedial action is complete and will cover site inspection and repair of the streambed andvegetative cover.

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d. The contingency requirements for cleaning up spills will be provided in Section 01495, SpillPrevention and Control, as stated in Section 8.2.17 of the FDWP.

e. The runon and runoff controls are presented throughout the design. The final grading willrestore the areas to their previous grades. The only backfill will be riprap, and the size ofthe riprap is shown on Drawing C-17. The temporary pretreatment area will be graded asshown on Drawing C-14; the details are presented in Drawing C-16. No calculations wereprovided to the agency for review with the Intermediate (60%) Design Report, butcalculations will be included with the 90% design.

f. The contractor's site-specific safety and health plan is required by Section 01200, Safety andHealth Plan, to contain a section describing decontamination of personnel and equipment toprevent the spread of contamination. Drawing C-14 shows the layout of thedecontamination pad, and a detail of the pad is shown on Drawing C-16. Wheel washes arerequired at each ingress to a public road, as defined in Section 01000, Summary of Work,Part 3.10, Decontamination Facilities.

g. This comment is confusing; the only liner to be used will be beneath the pretreatment areaand under the decontamination facilities to prevent the spread of contamination. The bearingcapacity of the natural existing soil will be able to support the temporary constructiontraffic. There is no landfill, so no calculations were prepared for side slope stability orbearing capacity. The leachate collection system is for dewatering the sediments that requirethermal treatment, and drainage pipes are shown in Drawings C-14, C-15, and C-16. Thedewatering bed is specified in Section 02140, Dewatering Bed.

h. The leachate collection materials are noted on Drawings C-14 through C-16; Section 02140,Dewatering Bed; and Section 02110, Earthwork.

i. FBAG did not prepare calculations for the stability of the drainage layer or for pipestrength. Section 02140, Dewatering Bed, specifies that the drainage layer be made of high-strength polyurethane and able to withstand a loading of 3,500 Ib, per panel and that thePVC pipe conforms to ASTM 1784, Class 1245 D. These specifications are more thanenough to ensure that the dewatering system will not fail under operating conditions.

j. In accordance with the FDWP, the design basis for the stormwater controls is based on a2-year, 24-hour storm.

k. The haul road details are shown on Drawing C-16, and the crushed stone is defined inSection 02110, Earthwork. The contractor is required to develop a section in the safety andhealth plan that addresses the cleanup of accidental spills. Section 01495, Spill Preventionand Control, specifies the technical requirements for the contractor.

1. Only the water from the wheel washes, decontamination pad, and the pretreatment area willbe collected and treated to meet the discharge criteria. Water within the brook will bediverted around the excavations.

m. See the response to General Comment 10.

Comment 14: Regarding O&Mt FBPRPO must provide a draft O&M plan which provides in partfor sediment sampling to assure that the remedy remains protective afterremediation. As discussed in EPA's 6/14/95 30% RD comments, the conceptualrequirements for an "O&M* plan was required to be discussed conceptually withinthe 60% RDfor each aspect of the design. Further, as previously discussed, it isexpected that an O&M plan will be prepared by the design contractor for all

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aspects of this project, and that the contractor will finalize and submit it uponcompletion of construction.

FBAG Response:

See the response to General Comment 13 c.

Comment 15: As noted in EPA's 12/7/93 letter, FBPRPO did not present confirmation samplingprocedures or frequency to be followed after remediation in the 9/93 DQO/FSPdraff documents. In response to EPA 's 12/7/93 letter, FBPRPO presented arevised approach at the 12/17/93 meeting: to conduct no post-remediationconfirmation sampling, but rather conduct 'confirmation sampling' at the outeredge of the cutlines immediately before setting up final cutlines, to ensure thatthese outer areas mil be below the CRG; FBPFiPO also agreed to provide a planto test all bacilli material, and conduct surveying. EPA accepted this approach,but has not yet received the 'cleanup confirmation' plan and/orspecifications/drawings to resolve this issue as requested in EPA's 9/29/95 letter.EPA requests that FBPRPO respond to this issue within the comment responsereport to these comments, and that the 'outer edge' sampling move forwardwithout delay.

FBAG Response:

WCC will perform confirmation sampling just before remedial action begins.

The only backfill to be used for the sediment operable unit is riprap, which does not requiretesting for contaminants of concern. Section 01050, Layout of Work Zones and Surveys, will beprovided in detail in the 90% design, as stated in the FDWP.

Comment 16: The report generally lacks actual design computations, including those requiredfor the riprap design, slope stability, geotextile fabrics, and other areas. Thesecalculations must be provided as backup to the 90% ED for review.

FBAG Response:

See the response to General Comment 13 e.

Comment 17: As noted within EPA's 4/14/95 comments, requirements for the contingency plandocument are required. Included within this plan should be a discussion of whowill decide to start and stop work when problems arise, with clear delineation ofresponsibilities/chain-of-command. For example, when the Brook stage is rising,the plan should discuss at what point will workers be informed to stop workingand then start again.

FBAG Response:

The contractor will be responsible for developing a contractor quality control plan, as defined inSection 01440, Contractor Quality Control. The contractor will be responsible for performingthe work in accordance with the contract documents. FBAG's onsite representative will be ableto issue stop work orders if the contractor is not performing in accordance with the contract.

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B) General Comments Retarding Drawings

Comment 1: The drawings do provide much of the requested information, such as cutlines.However, many drawings appear to be lacking the detail needed tofulfyunderstand what is to be constructed. For example, for the excavation plans, theproper width of cut has not been defined. There is no coordinate system and noturning points identified for the centerlines. Design details such as slopeinformation, typical cross section details, pipe diameters, and constructionmaterial references are needed. Some call-outs are absent and make it difficult tounderstand what is to be built (e.g., see C-14). Further discussion is requestedwith FBPRPO regarding why these details should not be incorporated into thefinal design.

FBAG Response:

Drawings C-l through C-ll provide the layout of the haul roads, limits of construction activity,and limits of excavation. The excavation is tied to the center line stationing, which is shown oneach drawing, and WCC has already laid out this centerline stationing in the field. Thecontractor will be provided a beginning and ending station for each reach to be excavated.FBAG will add a typical excavation cross section Drawing C-16 to clarify the excavation at theembankment.

Comment 2: More label detail (i.e. street names, prominent features, etc.) is needed for theREFERENCE and PLAN sheets. The drawings lack a legend to explain thedifferent line designations (ie. haul road, construction easement, etc.).

FBAG Response:

Drawing C-12 will be modified to include more street names. A legend is not necessary becausethe lines are labeled on the drawings.

Comment 3: Although it is implied to be the depth of cut, the solid line beneath the "ExistingChannel Bottom" in the profile must be called out.

FBAG Response:

Bechtel will label the depth of cut line on Drawings C-01 through C-ll.

Comment 4: The drawings suggest that the contractor is being directed to make cuts to aspecific depth from the top of sediment. Discuss and provide specifications forhow will it be verified, and whether surveys before and after excavation will berequired.

FBAG Response:

The contractor will be required to perform surveys before and after the excavation to verify thatthe requirements of excavation were met. Section 01000, Statement of Work, Part 3.14,Excavation, will modified to include this statement, "Perform a preexcavation elevation survey ofthe required excavation areas and a post-survey excavation survey to verify that the excavationmeets the lines and grades shown on the design drawings by a licensed surveyor in the state ofOhio."

Comment 5: Drawings do not show property limits, and should do so to facilitate the accessrequirements issue.

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FBAG Response:

Showing property lines on these drawings would add no value to this design package. The taxmaps show the property lines and the limits of construction. Bechtel will prepare individualproperty owner maps to show the limits of construction activity at a later date, as explained in theletter from Heimbuch to Hanlon dated December 26, 1995. WCC will prepare figures for EPAto use when talking with the property owners and the public.

C) Specific Comments - Specifications

Comment 1: Executive Summary: This section lacks mention of areas to be stabilized (i.e.,riprap, stabilization of excavated streambanks subject to erosion) and streamdiversion.

FBAG Response:

The Executive Summary is a summary of the remedial design and does not describe all activities.The Executive Summary will not be a part of the final remedial design. Section 01000,Summary of Work, defines the activities for the remedial action.

Comment 2: Section SC-1, PART 1

A) Page SC-1-1, Par 1: The nature of contamination in the sediments should bementioned.

FBAG Response:

Section 01000, Summary of Work, Part 1.1 (Introduction) provides a general description of thenature of contaminants in the sediments. The material in SC-1 is contractual language that isassociated with procurement and does not need to contain the nature of the contaminants, whichis addressed in Section 01000.

B) Regarding access which is discussed in this section, the first sentence impliesthat the contractor is responsible for securing access agreements from affectedproperties. However, the Final Design Workplan stated that FBPRPO woulduse best efforts to obtain and provide the required access agreements, and ifthese efforts do not succeed. EPA may then assist in that effort. Also,regarding the "Real Estate Access Information report"provided by Bechtel inits 9/95 report, the following general comments are made; additionalcomments will be sent in the next three weeks:

The report should provide a list of the PRPs implementing the remedial actionsand the innocent residential property owners affected by the project. Thelisting of residential property owners should delineate those listed as PRPs (ifany are categorized as such).

The real estate information report should address the impact of the project onthe affected areas and the length of the impact. This can be accomplished byproviding a summary of or by referencing the construction impact assessment.

The report does not indicate if it was prepared by a title company, an attorneyor other source/manner.

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The following are observations of the access agreement:

It purports to bind successors in interests, i. e. , future owners, but is not arecordable format. Recording of a real estate document is the basic means ofproviding fitture owners of encumbrances affecting real estate.

The access agreement is drafted as a license which is generally terminable atwill. The validity of the clause requiring mutual agreement to terminate isquestionable, especially against future owners.

FBAG Response:

Section 01000, Summary of Work, Part 1.5 (Site Access) specifies that FBAG, with assistancefrom USEPA, will provide access to the site. The material in SC-1 is contractual language thatis associated with procurement and merely specifies that the contractor shall understand thenature of the work and existing site conditions before initiation.

Comment 3: SC-3: Regarding protection of property, it may be useful to also require thecontractor to locate, verify location of and prevent damages to all active existing'facilities ' and on property requiring access within the site (particularly within theBrook, floodplain and ACME facility areas), including electrical, water, sewer,and other utilities, and any structures including fencing, roadways, curbing,culverts, stream crossing areas, and other such items. To help facilitateresolution of any issues which might arise if such damages occur, FBPRPOshould consider whether to require a preconstruction property condition surveysimilar to that required for the Bayou Bonfouca site.

FBAG Response:

The contractor will be required to take preconstruction photos of all roadways, sidewalks, etc. todocument the existing conditions before beginning construction activities.

Section 01310, Photographs, will specify that photographs be taken before construction of thepublic roads. These photographs will serve the function of a preconstruction property survey.

Comment 4: Section SC-4, PART 1, Page SC-4-1, Par 2: This section requires writtenpermission from the CA prior to removing construction plant, equipment, or toolsfrom the site. The criteria for approval is not given here. Also, thedecontamination area/pad requirement should be mentioned. Also, detailedspecifications were expected for the decon operation. FBPRPO was expected toinclude specifications such as those for a high pressure washer (with pressurerequirements), steam cleaning system requirements to remove mud and other suchmaterials/debris from trucks leaving the FWA/stream area and from ACME, andother such requirements.

FBAG Response:

Section SC-4, Decontamination, Part 1 (General) provides standard contract language for alldecontamination activities. Additional information regarding decontamination facilities isaddressed in Section 01000, Summary of Work, Part 3.10 (Decontamination Facilities). Thedecontamination pad is shown on Drawings C-14 and C-16. The contractor is required to supplyequipment for decontamination of equipment and tools, including a high-pressure washer.Detailed information such as pressure requirements for the pressure washer is more detail than isnecessary to ensure appropriate release control.

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Comment S: 01000, General Requirements page: This page outlines the various Division 1sections included within the design. EPA expected drawings and minimumspecifications for offsite thermal treatment, post closure requirements, andoperation and maintenance requirements; these requirements must be submittedwithin the 90% RD.

FBAG Response:

Refer to the response to General Comment 1 regarding thermal treatment. The draft post-closureoperation and maintenance specification will be part of the 90% design.

Comment 6: Section 01000, page 01000-1, paragraph L5: First paragraph, last line shouldmention decontamination areas.

FBAG Response:

Decontamination areas are a part of the temporary appurtenant remedial facilities mentioned inthe first line of this paragraph.

Comment 7: Section 01000, page 01000-2, Part 3: When encountering boulders, FBPRPOmust develop a specification requirement to perform wipe tests for the larger sizesin order to determine degree of contamination remaining after remediationprocedures are implemented.

FBAG Response:

Wipe test results are not quantitative and would not provide reliable results as to whetherremaining boulders were contaminated. After some discussion, EPA agreed that wipe testswould not be necessary provided that the specifications provided greater detail regarding requireddecontamination procedures for rocks.

Comment 8: Section 01000, page 01000-3, paragraph 3.3: As noted within EPA's previouscomments, ifonsite vegetation is collected from areas to be incinerated orsolidified, vegetation should be considered hazardous and either Subtitle-Clandfilled or thermal treated unless it can be proven otherwise. Also, as notedwithin EPA's 8/3/93 letter, EPA approved a decision matrix for addressing rootsand stumps within contaminated sediment areas; this matrix should beincorporated into the design. Further, as noted within EPA's 4/28/93 letter, EPAnoted that roots, stumps, etc. below the surface in contaminated areas must beincinerated. Also, EPA's 1/8/93 comment regarding this issue noted that alldowned vegetation in highly contaminated areas will be managed as contaminated,all roots in contaminated areas must be incinerated, live surface vegetation notcontaminated with sediments, and/or which can be adequately spray washed, maybe considered not contaminated, and generally may be mulched, and used for siterestoration. Larger rocks which can be spray cleaned and deconned do notrequire incineration. As noted within FWA operable unit discussions, trees suchas willows, cononwoods and poplars should not be considered free ofcontamination and should not be mulched since research indicates these speciespick up metals.

FBAG Response:

FBAG has reviewed the contaminant concentration data in the "Integrated Human and EcologicalBaseline Risk Assessment for the Fields Brook Floodplains/Wetlands Area" (October 1995 draft,

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Table 3-6) and can make the following statements. The data indicate that in all cases thevegetation contaminant concentrations are less than the corresponding elevated soilconcentrations. Also, the vegetation contaminant concentrations are constant and are not afunction of soil contaminant concentrations. The data, therefore, support FBAG's vegetationdisposition selection for having the better cost to benefit ratio.

Comment 9: Section 1000, P3, Par 4: Please interpret the term "provide ".

FBAG Response:

Section 01000, Summary of Work, provides a summary overview of the work required and theresponsibilities of the contractor. Part 3.1 (Mobilization) states that it is the contractor'sresponsibility to provide the necessary equipment, including fuel, etc., as part of its initialactivities. The sense of the word 'provide' is to supply what is needed for beginning andmaintaining operations.

Comment 20: Section 1000, P5, Par 5: The phrase "clean up spills" should reference Section2130.

FBAG Response:

Section 01000, Part 5, Par 5 will be revised to reference Section 02130 regarding spills.

Comment 11: Section 01000, page 01000-5, paragraph 3.10: Should have wheel andundercarriage washed.

FBAG Response:

Section 02130, Material Handling, Part 3.5 (Onsite Transportation) specifies that an inspectionand removal be done for mud and soil on the exterior, underbody, and between tires of vehiclesbefore they leave an excavation area. Possible accumulation on surfaces other than the tires isexpected only during onsite transport. Therefore, only a wheel wash is needed before trucksenter public roads from constructed haul roads.

Comment 12: Section 1000, 3.12.1: This article should reference Section 02271 regardingsediment and erosion control

FBAG Response:

This section will be revised to reference Section 02271 regarding sediment and erosion control.

Comment 13: Section 1000, 3.17.1: This section should reference specific comments to section02130-3; section 3.1, noted below, regarding separation of materials.

FBAG Response:

Section 01000, Part 3.17 will be revised to reference Section 02130 regarding material handlingafter pretreatment.

Comment 14: 01060, Section 1.3: Regarding ARARs, as noted above within the generalcomments, EPA will review FBPRPO's ARARs compliance document as soon as itis received. Also, the list of Federal ARARs on page 01060-1 to be met is notcomplete when compared to the Workplan list as amended, and should include:40 CFR 260, 262, 263, and the transportation of hazardous waste regulations;

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regulations associated with disposal at a TSCA/RCRA landfill facility; the CleanWater Act's Section 401 and 404 requirements; 33 CFR 320-330 requirements forstream diversion; and the Clean Air Act's requirements noted in 40 CFR 1-99.The list of State ARARs to be met is not complete, and should include: 3734-01through 99, hazardous waste requirements; 3745-3 pretreatment requirements;3745-21-09 control of VOC issues; 3745-35 requirements for meeting airregulations'; 3745-27,07,08,09,11 landfill requirements; 3745-52,53transportation requirements; 3745-33 Ohio NPDES requirements; and local(including building permits, electrical, plumbing, HVAC.fire code).

FBAG Response:

Refer to the response to General Comment 13 regarding ARARs. After concurrence of EPAregarding which regulations are ARARs, Section 01060 will be revised to reflect the agreement.

Comment 15: 01200: Regarding use of ACME as the pretreatment/materials handling facilitylocation, current data indicate that PCB surface soil concentrations are up to 10PPM in the work area. FBPRPO must describe how these contaminated surfacesoils will affect the siting design and contractor health and safety, andspecifications for site preparation regarding how these contaminated soils wouldbe addressed if graded.

FBAG Response:

Bechtel intentionally located the pretreatment area in an uncontaminated area of the Acme site.Sampling results from the source control remedial investigation performed by WCC indicated thatthis area of the Acme site is not contaminated with PCBs. FBAG is considering moving thepretreatment and transfer station to another site to take advantage of the fully operational railroadsiding and a water treatment plant.

Comment 16: 01200, Paragraph 1.3, Codes and Standards; Include the USEPA guidelines-AirSuperfund National Guidance Series as part of this list. Also, under the OSHAlist, include 29 CFR 1910.1030, "occupational exposure to blood-bornepathogens".

FBAG Response:

This section addresses codes and standards. Although the USEPA guidelines, Air SuperfundNational Guidance Series, provide guidance, they are neither a code nor a standard and,therefore, are inappropriate for incorporation. The list of OSHA regulations are those that areapplicable to the removal of organic and metal contaminants at the site. The 29 CFR 1910.1030regulation addresses employers having employees working in conditions where it is reasonablyanticipated that contact will be made with blood or other infectious materials. These conditionsare not expected to exist at the Fields Brook site, and, therefore, this regulation is not appropriatefor incorporation into this technical specification. Also, this regulation does not apply to theconstruction industry, as clarified in a letter from H. Berrien Zettler, Deputy Director,Directorate of Compliance Programs, U.S. Department of Labor, Occupational Safety and HealthAdministration, to Jeffrey D. Meddin, CSP, CHCM, Corporate Director of Safety, ZurnIndustries, Inc. on May 13, 1994.

Comment 17: 01200, Paragraph 3.1, Section 01200-5: under the second to last bullet of thispage, specifications for hearing conservation requirements should be provided.

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FBAG Response:

This paragraph will be revised to reference 29 CFR 1910.95(c).

Comment 18: 01200, Paragraph 3.2, Section 01200-6: Safety and Health Plan Specifications:A spill control program needs to be developed for any staged hazardous materials.These materials include soil stabilization additives and any proprietary chemicals.The appropriate Material Safety Data Sheets must be located on site also. Allstaged areas must be lined and diked. Absorbent materials must be available forthe treatment of spills.

FBAG Response:

As specified in the noted paragraph of the technical specification, the contractor is to develop aspill control program in accordance with 29 CFR 1910.120(j)(l)(viii). However, because theexcavated soil is a solid, soil stabilization additives and absorbent materials are not needed. Inaddition, the relatively low concentration of the contaminant precludes the need for materialsafety data sheets. The safety and health plan (Section 01200) is not intended to includeinformation on the design of staging areas such as lining and diking.

Comment 19: Section 01200, pages 01200-7/8, paragraphs 3.2.2/3: Provide local contacts foremergency response situations indicated on the list of personnel that the CIH andSSHO should know about.

FBAG Response:

The CIH and SSHO will be provided a list of contacts for emergency situations. However,because these contacts may change over time, they are not included in the technical specification.

Comment 20: Section 01200, page 01200-8, paragraph 3.2.3: The minimum requirement of oneyear of experience for the SSHO appears low considering the extent/degree ofremedial work scoped for the area; it is recommended that a minimum of 3 yearsexperience be required, with a similar level of experience required for the CIH.

FBAG Response:

The SSHO requirement is for at least 1 year of experience performing full-time safety and healthfunctions equivalent to those required at the Fields Brook site. The individual is likely to havemore experience than that specified; however, 1-year, full-time experience equivalent to work atFields Brook is considered appropriate. For the CIH, 3 years of experience in HAZWOPERactivities is already specified.

Comment 21: 01200, Paragraph 3.3.1, Section 01200-9: under the last bullet, the wordingshould be modified as follows: "...submission to the CA and employee of aphysician's...".

FBAG Response:

The noted paragraph will be revised to include a copy of the physician's statement to theemployee.

Comment 22: 01200, Paragraph 3.6, Section 01200-13: Specifications for Air Monitoring: It isrecommended that the air monitoring program not be conducted by the sitecontractor, and that an independent air monitoring contractor be utilized, to avoid

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a conflict of interest. Additionally, the air monitoring program must address thesampling of effluents from thermal desorbtion if it is to be performed on site. Airmonitoring needs to be in conformance with the VSEPA Air Superfund NationalTechnical Guidance Series.

FBAG Response:

Air monitoring is typically done by the contractor during remediation of similar sites. Therefore,air monitoring by the contractor is also considered appropriate in this situation. Note that thecontractor is required to develop an air monitoring plan that is to contain qualityassurance/quality control requirements. Therefore, adequate assurance of the accuracy of the airmonitoring is provided. Thermal treatment is not presently planned to be performed onsite.Refer to the response to General Comment 3, which addresses this topic.

Refer to the response to Specific Comment 16 regarding the EPA Air Superfund NationalTechnical Guidance Series.

Comment 23: 01200, Paragraph 3.8.1, Section 01200-17: under the first bullet, change thewording in the first sentence as follows: "...to contamination or hazardousoperations at or above... *.

FBAG Response:

The first bulletized item in Section 01200, Part 3.8.1 requires establishing exclusion zones forcontrolling exposure to chemical contamination levels that may exceed applicable action limits.Inclusion of the wording "hazardous conditions at or above applicable action limits does not"would not enhance the scope of this requirement.

Comment 24: 01200, Paragraph 3.9.3, Section 01200-22: under these noise specifications andperhaps elsewhere within these specifications, specifications must be includedwhich also restrict working hours and the maximum decibel levels (e.g., no noiseslouder than 85 Db allowed at any time), since there is a need to provide forprotection of residents who will be in certain areas within 150' of the Brook andcloser when considering haul roads. Also, limits regarding allowable work hoursfor any construction work within residential areas are required (i. e., no workoutside of such hours would be allowed to limit disturbances to residents), and aresuggested to be between 8am-5pm.

FBAG Response:

Comment incorporated. Section 01200, Part 3.9.3 will be rewritten to include bulletized itemsrequiring use of engineering and administrative controls, where feasible, to maintain noise levelsto below 85 dB(A)-TWA and to establish with local communities the hours during which workwill be performed.

Comment 25: Section 01305, Attachment A. This is a very important part of the document andshould be as complete as possible when final. At this time, there appears to be alarge number of submittals that are not referenced here, including but not limitedto weekly and monthly reports, dewatering (2140), earth materials (2110),contractor and sub-contractor qualifications submittals, surveying requirements,pre-and post-cutline surveying/drawings, as-built drawings, calibrationcertificates, preconstruction conference submittals requirements, daily safety logs,sign design, P.E. certifications of closure, security plan, O&M plan, initialconditions report, approvals/permits from applicable state and local agencies,

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plan for clearing and grubbing, soil/clay/hydric soil borrow source plan with QCresults, revegetation plan, flood protection details, stormwater management plan,and revegetation plan.

FBAG Response:

FBAG agrees that Section 01305, Attachment A (Contractor Submittal Summary Requirements) isa very important document, and it will be completed for the prefmal (90%) design package.Because only the key specifications were completed for the Intermediate (60%) Design Report,we were not able to complete Attachment A.

Comment 26: Section 01305, Attachment A: The Contract Submittal Requirements summary hasno listing for earthwork, riprap, backfill, aggregate, or grout.

FBAG Response:

FBAG agrees that these submittals were not listed in Attachment A; they will be incorporated inthe prefmal (90%) design package. The backfill required is riprap, so a borrow area will not berequired to be identified, nor testing of the soil for the sediment operable unit.

Comment 27: Sections 01440 and 01450: Additional comments will be sent to these sectionswithin two weeks.

FBAG Response:

FBAG acknowledges the comment.

Comment 28: Section 01440, Article 3.5, Page 01440-8, Par. 3.5.1: Discuss what are therequired tests and where are they listed. Provide a table of recommended orrequired testing frequencies for the individual tests.

FBAG Response:

The required tests are identified in each specification, and the submittals are listed in Section01305, Submittal Procedures, Attachment A.

Comment 29: Section 01440, Par. 3.5.1, 5th Bullet, 4th sentence: Discuss what is an offsetlaboratory.

FBAG Response:

"Offset" is a typographical error and will be changed to "offsite."

Comment 30: Section 01450, general: Please include specifications for additional purchasedmaterials (e.g. stabilization agents) and treatment performance constraints(thermal desorption, stabilization) in these specifications. It is suggested thatthese specifications be included even if this work is done by subcontractors andwill be covered in their submissions.

FBAG Response:

See the response to General Comment 1.

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Comment 31: Sections 01450 and 01460, Par. 1.6.1 and 1.6.2: Sampling locations, numbers,and procedures must also be developed for delineation samples within the Brooksediments, soil sampling generally, borrow sources for clay and soil, watersamples from onsite treatment systems, air samples, and-water samples from stormevent occurrences and control systems. Further, as noted within EPA 's 8/3/93letter, QA/QC requirements for chemical and analytical testing and samplingprocedures are recommended to follow the approved QA/QC procedures approvedfor the sediment and source control operable units; this requirement willencourage consistency with the QA/QC of the sampling data generated during theRI/FS and RD which is relied upon to ensure that cleanup action levels are metduring the RA.

FBAG Response:

WCC will develop a sampling and analysis plan for the delineation of the sediments. FBAG willmodify the specification to be in accordance with QA/QC for the RI/FS.

Comment 32: Section 01450, Article 1.6 Page 01450-5, Par. 1.6.2: Discuss whether the deconprocedure is consistent with the decon procedures previously approved for designsampling within the FWA. Isopropanol (pesticide grade) is typically not used inthe decon process because in the presence of sunlight it can degrade to acetone.

FBAG Response:

The decontamination procedure will be modified to be consistent with the decontaminationprocedures previously approved for design sampling within the FWA.

Comment 33: Section 01450, Article 1.6 Page 01450-5, Par. 1.6.1: Other potentially applicablesampling points and frequency expected should be provided/identified and/orreferenced as specifications within this section of the document, including soil andclay borrow source sampling to assure no COCs are present, sampling locations

for the onsite wastewater treatment system, air sampling requirements, andtemporary pre-treatment/materials handling area sampling locations.Specifications regarding sampling points, frequency of sampling and analysis,should be included and/or discussed.

FBAG Response:

Air sampling points and frequency will be provided by the contractor in the safety and healthplan, as specified in Section 012(X), Part 3.6. There is no borrow for the sediment operable unit.

Comment 34: Section 01450, Article 1.7, Page 01450-6, Par. 1.7.1: Chain-of-Custody formshould also include time and date samples were taken and the particular media ofthe sample (i.e. soil, water, or composite).

FBAG Response:

FBAG agrees that the chain of custody should include the time and date the samples were takenand the media. These items will added as bullets in Section 01450, Part 1.7.

Comment 35: Section 01460:

-Regarding disposal offsite of construction materials, EPA's review of this projectindicates that the more cost-effective approach for the construction may occur if

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FBPRPO identifies within this design the specific locations, depths and volumeswhere the 'construction materials' soils and debris will be excavated and movedfrom the Brook and FWA area, and discuss how these materials must be removed.

-Provide specifications for any site preparation work required to occur prior tosuch excavation and removal necessary to help ensure that no releases ofcontamination will occur, including minimum requirements for dust control,excavation limits, erosion and sedimentation controls during the excavations, andregrading and revegetation requirements.

-Provide specifications to ensure that any temporary storage soils, whether locatedon ACME or within the FWA area, will: 1) be tarped/receive an 'erosion blanketso that rain/windstorms will not allow the contamination to be released; 2)receive/have a vegetative cover within three months of the movement; and 3)provide for O&M;

-Provide specifications describing requirements to ensure that dusts will beprevented, and for periodic monitoring of the excavation and disposal areas toensure releases do not occur.

FBAG Response:

This comment is confusing; it is not clear what EPA is trying state. It is very clear that the 60%design contains the specifications (e.g., dust control, erosion control, materials handling, etc.) tocontrol the remedial activities to prevent spread of contamination. The disposal of constructionmaterials (gravel and liners from haul roads) offsite appears to be the only option other thanleaving the haul roads in place. If EPA is stating that the haul roads can be left in the residentialarea, the FBAG will add that option to the design. This design covers only the sedimentoperable unit and not the FWA operable unit.

Comment 36: 01460, 3.1.2, page 01460-3: FBPRPO's plan to take a total of only twelve haulroad samples for the purposes of determining whether or not the roadbedmaterials are free of contamination is not acceptable. Since it is envisioned thatthere will be haul roads installed along the entire Brook length from AshtabulaRiver to areas east ofSCM, EPA expects that at least four samples of each haulroad materials be taken per each exposure unit's haul road, which would averageapproximately one sample per every 500' of haul road. EPA also expects that atleast one sample of the roadways going from the Brook areas to the industrial andresidential roadways will also be sampled, at the midpoint between the Brook andthe roadways. The specifications should refer to a figure generally indicatingsample locations, indicate that specific locations will be identified by the oversightofficial and that each sample to be taken must be aliquoted/composited. Thespecifications must also indicate expectations for the conceptual sequence andtiming of the sampling to be conducted for this purpose, including discussion thatthe roadways would not be used during the period of testing to ensure cross-contamination does not occur, and/or discussion that ensures that the discretesections of the road per sample area if excavated soon after sampling areseparately stored in a manner preventing cross-contamination while awaitinganalytical results. Lastly, the above requirements for aliquoted/compositedsamples, concepts for preventing cross-contamination during the testing period,and off-site disposal requirements if contaminated soils are indicated, also applyto the ACME facility temporary facility samples which are required to be taken.

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FBAG Response:

FBAG does not agree to biased sampling of the haul roads. We agree to take four randomsamples from each exposure unit, and these sampling locations will be evenly spaced and will beshown on the drawings.

FBAG does not agree to sample the public (asphalt) roads. A simple inspection each day forspilled material should be sufficient.

Comment 37: 02000, General Requirements page: This page outlines the various Division 2sections included within the design. As noted within the Bayou Bonfoucaspecifications, FBPRPO is requested to review the Bayou Bonfouca specificationsand justify why the following various specification sections which appear to beessential to that project are not included within this design: demolition; interimstorage of contaminated material; solidification; permanent access roads; designspecifications for channel relocation; bank stabilization; channel fill; water qualitycontrol systems; dredging; flood protection; stormwater management; seeding andlandscaping; observation; coordination and site conditions; surveying;environmental data management and reporting; mobilization and demobilization.

FBAG Response:

See the response to General Comment 1 concerning specification for thermal treatment andsolidification. Specifications are not required if this type of work (demolition, permanent accessroads, channel relocation, dredging, etc.) is not planned in the Fields Brook remedial design. Aspreviously stated, the other specifications are included in the design.

Comment 38: Section 02110, page 02110-1, paragraph 1.2: To prevent confusion, it isrecommended that earthwork materials not include riprap or grout, and separatesections be provided for riprap and grout.

Adding a

FBAG Response:

It is not clear why the agency wants a separate specification for riprap and grout,specific specification for riprap and grout would not add any value to this design.

Comment 39: Section 02110, pages 02110-1 through 5: FBPRPO is expected to discuss andprovide specifications and backup calculations for any specific site preparationwork required to occur prior to installation of haul roads and stream diversionsystems, including any structural stability testing/requirements necessary to ensurethe roads and streambank areas will maintain integrity, options to ensure that theroadways Junction properly within the FWA area due to the unstable and softnature of the base soils (including use of geomembrane, geofabrics, larger stone,quick-cementing options, and other such requirements. Also, to help ensure thatno releases of contamination will occur, minimum specific requirements for haulroad and stream diversion boundaries and limits are required, as well as specifictemporary erosion and sedimentation controls to be installed immediately uponinstallation of the roadways and stream diversions, and temporary revegetationrequirements.

FBAG Response:

See the response to General Comment 16.

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Comment 40: FBPRPO is requested to consider and discuss in a comment response reportwhether delaying the submittal of details to the construction phase would beexpected to pose significant problems during the execution of the remedial action,and also whether the more efficient and cost-effective approach is to conduct adetailed design presently for all work to be conducted within the Brook/FWA area.

FBAG Response:

The FDWP clearly defines which specifications would be detailed and which specifications wouldbe performance-based. This will not affect the schedule because the schedule is based on theFDWP.

Comment 41: Section 02110, page 02110-2, paragraph 1.3: DOA EM should be numbered1110-2-1906.

FBAG Response:

DOA EM 110-2-1906 will be corrected to DOA EM 1110-2-1906.

Comment 42: Section 02110, paragraph 2.1, page 02110-3: Specifications for riprap arerequired for all excavation and non-excavation areas which may be prone toerosion, as discussed above in General Comment #10.

FBAG Response:

See the response to General Comment 10.

Comment 43: Section 02110, page 02110-8, paragraph 3.11: Section 02010 is referenced butnot provided for review.

FBAG Response:

Section 02010, Clearing and Grubbing, is not a key specification and was provided in outlineformat in accordance with the FDWP.

Comment 44: Section 2110, p9: Discuss whether in-situ testing will be performed for QApurposes.

FBAG Response:

As previously stated, no backfill will be used, and no testing has been planned for this work. Ifbackfill is required, then testing will be performed in accordance Section 02110, Earthwork,Part 3.13, Fill and Backfill Placement, and the frequency of testing will be added as follows:

In-Place Density

• One test per 30,000 ft2 or a minimum of one test every other lift for fill or backfill areascompacted by other than hand or hand-operated machines.

• One test per area less than 2,500 ft2, or one test per 250 linear feet in length for trenches,pits, building perimeters, or other structures or areas less than 10 feet in width.

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Moisture Content

A minimum of two tests per day per type of material being placed during stable weatherconditions.

Comment 45: 02110: This section mentions numerous activities including bank stabilization withassociated riprap and haul road stone sizing; however, backup calculations for thesizing of stone and other portions of this design are required.

FBAG Response:

No calculations were provided with the 60% design; calculations will be provided with the 90%design.

Comment 46: 02120: Refer to General Comment #2 above.

FBAG Response:

See the response to General Comment 2.

Comment 47: Section 02120, page 02120-2, paragraph 2.3: Stone gradation should beprovided.

FBAG Response:

The stone gradation is shown on Drawing C-17.

Comment 48: Section 02120, page 02120-3, paragraphs 3.1 through 3.4: The sizing of allsumps, dike areas, pumps, diversion widths and depths, and pipes arerecommended to be detail designed vs. left to the construction phase, as indicatedin General Comment #2 above.

FBAG Response:

See the response to General Comment 2. The flow rates and pipe sizes are shown onDrawing C-17.

Comment 49: 02130: Provided specifications to ensure that the construction firm will beprevented from storing the different materials near each other so that the potentialfor cross-contamination is reduced. Specifications for segregated storage areasfor sediments to receive thermal treatment, sediments to receive solidification,construction materials, decon wastes, and sanitary/rubbish must be provided.

FBAG Response:

The 60% design clearly states that the sediments that require thermal treatment will be removedand taken to the pretreatment area for dewatering and then transported to the offsite thermaltreatment facility. Sediments that do not require thermal treatment will be taken directly to theoffsite RCRA/TSCA facility for disposal. When the excavation has been completed within anexposure unit, then the gravel from the haul road will be tested and a determination will be madeas to where this material can be taken (Class C or D landfill). Then the contractor can removethe haul road from this exposure unit. This sequence of work activities will ensure that thecontaminated materials are not mixed together.

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Comment SO: 02130-3; section 3.1: Due to the expected difficulty in assuring that properdeconning occurs to any oversized (> 2-inch) solids which are collected fromBrook areas expected to receive thermal treatment, as discussed previously inprior meetings, onsite materials separation is expected to occur to separateorganic from inorganic oversized material. Any organic material (roots, stumps)which might be >2" and collected from such areas must still receive thermaltreatment, and specifications and plans must be developed for either reducing thesize onsite to a diameter which would be acceptable to the offsite thermaltreatment facility (e.g., a crushing specification may be developed), or plans andspecs developed for such handling offsite. Any inorganic material (large rocks,other debris) which might be >2" and collected from such areas must be sent to aRCRA subtitle C facility for disposal. Boulders may be wipe sampled and sent toan offsite subtitle D facility if suitable specifications are submitted within the 90%RD and approved by EPA.

FBAG Response:

FBAG agreed with EPA to look into this issue and discuss it with EPA in the February meeting.

Comment 51: Section 02135:-Develop specifications which require the following details:a) identify volumes of soils/sediments/debris to be shipped and discuss how such

materials will be removed;b) the specific facility (s) to be used and volumes to be disposed at each;c) sampling/analysis procedures to meet offsite disposal acceptance;d) QA/QC and Sampling requirements;e) manifesting procedures and assurances these procedures meet all applicable

transport regulations;f) the name, location, and ID number of each facility planned to receive the soils;g) assurances from each of the landfill facilities that they are in compliance with

applicable regulations, are able under the regulations to accept such soils fordisposal (e.g., assurance that the facility (s) is currently in compliance withState of Ohio landfill regulations, and are willing to accept these soils; and

h) submittal of copies of any and all data either provided to orcollected/generated by the construction firm or the disposal facilities for thepurposes of determining facility acceptance of the soils.

FBAG Response:

The name of facilities and all the pertinent information will be provided to EPA after FBAG hasentered into an agreement with the firm.

Comment 52: 02145: Regarding screening of sediments, refer to specific comments to Section02130 noted above.

FBAG Response:

See the response to comments on Section 02130.

Comment 53: Section 02500: This section should have been considered a key section and textprovided for review/comment; EPA will consider the 'construction impactassessment' this specification section and will review it accordingly. Regardingcomplying with CWA Sections 401 and 404, Site Restoration requirements must bedetailed to allow USAGE and OEPA to ensure this design will meet the

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requirements of these ARARs. For example, on page 01060-3, title 3.1.1 Federal,possible 404 activities 02001, Site Preparation; 02110, Earthwork; 02120, StreamDiversion; 02145, Dewatering Bed; page 02271-1, Erosion Control; and page02500-1 - page 02500-3, Site Restoration are all mentioned, but do not have anydetails provided on their types of impacts as well as their amounts. Details suchas how much stream is going to be disturbed, how many acres of wetland impactswill occur, and where specifically are these impacts taking place are required inorder tojulfy assess the impacts on the environment for the proposed project. Asnoted within EPA 's 4/14/95 comments, FBPRPO is also expected to evaluatehabitat loss from construction cleanup, define rehabilitation and mitigationobjectives and actions, evaluate costs and benefits of mitigation and rehabilitationactions, develop an implementation plan meeting these objectives, delineate thewetlands to be affected, and describe a mitigation plan to restore the wetlands.Until this information and these plans are provided, USACE and OEPA cannotprovide an acceptable review for Section 401 and 404 Compliance. One copy ofseveral documents including ER 1105-2-100 (28 Dec 90), recommended outline forSection 404(b)(l) Evaluation; Interim Section 404(b)(l) Guidance (Revision); andReauthorization of the Clean Water Act (12 Oct 1994) are provided to FBPRPO'sBechtel and WCC contractors with these comments, and will be useful in helpingprepare detailed plans which satisfy Section 404(b)(l) requirements.

FBAG Response:

All of this information is provided in the design investigation reports and the construction impactreport and will not be repeated in the remedial design. FBAG has agreed to develop a mitigationplan for the FWA to satisfy 404/401 issues. Section 02500, Site Restoration, will establishtechnical requirements (seed mixture, seeding rates, species of plants, etc.) for restoring thedisturbed construction areas.

Comment 54: Section 13200: This Section does not specifically comply with the following itemsidentified on page 41 of the 60/90/100% Work Plan by not including the following(these specifications must be submitted within the 90% RD): a) The establishmentof the technical and performance (operation and maintenance) requirements forwater treatment; b) Retention basin size; c) Treatment rate; and d) Treatmentstandards for treatment of water resulting from decontamination and dewateringoperations from stormwater collection. No data is presented in this attachment; asdiscussed with FBPRPO, these specifications and the actual discharge numbersmust be submitted as soon as possible and prior to the 100% RD to not impedesite progress. This section should provide sufficient information so that acontractor could design and construct a wastewater treatment system capable ofremoving pofychlorinated biphenyls, pesticides, volatile and semivolatile organicchemicals, and suspended solids from contaminated site waters. This documentfails to provide the level of detail necessary to design and construct such a system.EPA's 4/14/95 letter requirements regarding water treatment are expected to beaddressed in this design, and details should be included within the 90% RDconsistent with those comments.

FBAG Response:

The attached data sheet was mistakenly not included with the specification. The actual dischargecriteria will be provided by OEPA and the local POTW.

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Comment 55: Additional specific deficiencies include:

a. No conceptual design is provided. Such a conceptual design was included aspan of the "Preliminary (30%) Design, °. Inclusion of the conceptual designin subsequent design documents, ensures that such information will betransferred. At the least, the earlier conceptual design should be referencedhere.

b. Section 2.2.2 Feed Conditions. This section specifies hydraulic feedcharacteristics, feed rates, and water quality parameters, which are includedon "the data sheets; * no data sheets were provided.

c. Attachment A. Wastewater Treatment Discharge Limits. This attachmentstates that discussions to establish discharge limits are ongoing; EPA expectsthat these discussions will be completed by, and the actual discharge numbersincluded within, the 100% RD.

d. Controls and instrumentation should be addressed.

The above- and below-noted deficiencies are expected to be resolved in the 90%RD document.

FBAG Response:

a. A reference will be made in Section 01000, Statement of Work, Part 3.11 to the SedimentDewatering and Wastewater Treatment Design Investigation (WCC, February 1995). FBAGwill also include a conceptual P&ID with the 90% design.

b. See the attached data sheet.

c. FBAG agrees that the discharge limits have to be in the 100% design.

d. As previously stated, FBAG will include a conceptual P&ID with the 90% design. FBAGdid not intend to specify all the instrumentation and controls but allow the contractor to usean off-the-shelf unit. The specification will be modified to require a wastewater treatmentunit that is simple to operate, has low maintenance requirements, is compact in size, allowsintermittent operation, is automatic except for setting chemical feed rates, and can treat thewastewater to meet the discharge criteria.

Comment 56: Page 13200-1, Pan 1, Section L2-SCOPEAND APPLICATION

a. The unit specified does not include the retention basin identified on page 41 ofthe 60/90/100% Work Plan.

b. Based on a preliminary review of the SDWTDI report, the feed systems for Phadjustments and flocculating agents were assumed to be for solids and metalsremoval Since there is no clarifier to "drop out" the solids or precipitatedmetals, discuss whether the multimedia filter is planned to be used for thisremoval process. Since it is standard practice to include process flowdiagrams which indicate the conceptual design, such diagrams are requestedin the 90% RD.

c. The SDWTD1 report indicates that among the constituents of concern aremetals. However, these are not identified in last sentence of Section 1.2. A

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comparison of Table 6-2B ofSDWTDI versus Table 6-1 of the SDWTDIsuggests that metals removal may be necessary.

FBAG Response:

a. Section 01000, Summary of Work, will be modified to include the retention basin. Theoperating contractor has the option to use alternative procedures or equipment to meet theperformance requirements of this specification.

b. The use of a multimedia filter for the low quantities of solids and soluble metals isappropriate. The operating contractor is responsible for meeting the performance criteria ofthis specification.

The inclusion of a process flow diagram might be construed as an invariant requirement toprovide certain pieces of equipment. The design document is provided as guidance thatallows an operating contractor to consider many equipment configurations mat result in alow-cost solution to the project while also meeting the performance criteria. While FBAGcan offer a process flow diagram that meets the performance criteria, the operatingcontractor has the option to implement other configurations that result in a higher valueadded to the project. A process flow diagram will be included in a revised water treatmentspecification.

c. The term "total suspended solids" implicitly includes insoluble metals. The wastewatertreatment treatability study contained in the SDWTDI makes the statement: "The dissolvedconcentrations for all metals are generally lower than the total concentrations." Thisstatement is not supported with quantification data that would indicate whether "metalsremoval" using solids removal equipment is adequate to meet the discharge requirements orif precipitation with solids removal is required for acceptable performance. In any case, theoperating contractor is responsible for system performance.

Comment 57; Page 13200-2, Pan 1, Section 1.3-CODES AND STANDARDS: The second tolast sentence reads. Identify any additional codes and standards that apply to thiswork. " Discuss who will be responsible for identifying these additional codes andstandards, and whether it is recommended that the contractor would beresponsible for only the non-environmental code/standards/permits.

FBAG Response:

The responsibility for identifying applicable codes and standards is jointly held by FBAG (asdelegated to its agents) and the affected regulatory agencies. Through a review and commentprocess, the codes and standards sections will become complete.

Comment 58: Page 13200-4. Pan 1, Section 1.5-SYSTEM REQUIREMENTS

a. The second sentence reads, "Design a system such that the redundancy indesign of components is minimal but is operable at least 90 percent of thetime. " Clarify whether this sentence means that the redundancy should beoperable at least 90 percent of the time or that the system should be operableat least 90 percent of the time, and what amount is associated with 'minimal'.Redundancy in the system design required to ensure that the systemsoperations will remain on line 90% of the time may not be required for such asystem. This is because (according to the conceptual design) a reservoir willbe used to hold water prior to treatment. Appropriate sizing of the reservoir

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could reduce the need for a 90% on line requirement for the wastewatertreatment system.

b. The fourth sentence reads, "Design controls and alarms to shut down thesystem and to provide a remote signal in the event of system failure." Discusswhat is meant by system failure and what types of failures should shut downthe system.

FBAG Response:

a. The wastewater treatment system will be available to perform as specified for 90 percent ofthe time (7,884 hours/year).

b. Failure includes environmental damage from spills and releases of hazardous constituentsand failure to perform within the performance specifications. The operating contractor shallset specific control and alarm criteria.

Comment 59: Page 13200-4, Part 1, Section 1.6-DELWERY AND STORAGE: The sentencereads in part, "in accordance with the schedule". However, there is no scheduleincluded in this section. If this is referring to the schedule identified in Section01320, then this should be cross-referenced here.

FBAG Response:

FBAG will provide a reference to Section 01320.

Comment 60: Page 13200-4, Part 1, Section 1.7-PERMIT REQUIREMENTS: The requirementfor the contractor to submit applications for all permits within 30 days of contractaward may be unreasonable without providing the list of permits in the contractdocuments. Discuss whether the discharge requirements will already be specified,since due to the ongoing negotiations the permit requirements would likefy havebeen worked out prior to award with OEPA.

FBAG Response:

FBAG will obtain from OEPA the required criteria for wastewater discharge to Fields Brook.The contractor has the option of sending the water to the POTW or treating and discharging it tothe brook.

Comment 61: Page 13200-4, Pan 2, Section 2.1, Subsection 2.1.1-General: The fourthsentence refers to "data sheets ", but these are not attached and should beprovided.

FBAG Response:

See the response to Comment 54.

Comment 62: Page 13200-5, Part 2, Section 2.1, Subsection 2.1.3-Materials and Equipment:The second sentence reads in part, "for the specified service ". However, thespecified service is not identified and should be.

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FBAG Response:

The contractor will be responsible for specifying the service requirements and material limitationsof the equipment chosen to meet the performance requirements.

Comment 63: Page 13200-6, Part 2, Section 2.2, Subsection 2.2.2-Feed Conditions: The datasheets referred to should be attached.

FBAG Response:

The data sheets will be included.

Comment 64: Page 13200-6, Part 2, Section 2.2, Subsection 2.2.3-Performance: The firstsentence reads, "Ensure that effluent discharge is in accordance with allregulatory requirements. " However, the regulatory requirements are not definedand must be,a. The second sentence reads in pan, "take samples.....at periodic intervals".

Discuss what is meant by "periodic" and how many intervals does thisconstitute.

b. The data sheets referred to should be attached.

FBAG Response:

The effluent discharge limitations have not been set and are currently under discussion betweenthe FBAG and OEPA. When these quantities are established, the numerical values will appear insubsequent revisions to the affected specification documents and data sheets.

a. Sample periods are subject to the same discussions as the above comment. Whenestablished, sampling periods will also appear in the data sheets.

b. The data sheets will be included.

Comment 65: Page 13200-6, Pan 2, Section 2.6-INSTRUMENTATION AND CONTROLS: Thesecond sentence reads in pan, "Provide a computer-based system.....capableof.....trending, reponing, networking, and data logging". Discuss whatparameters specifically should be trended. The seventh paragraph containswording specifying, "state of the an"; this is too qualitative for a specification andshould be detailed to particular requirements.

FBAG Response:

Regulatory reporting requirements are also under discussion, as discussed above. Whenestablished, reporting requirements will also appear in the data sheets. In addition, the operatingcontractor may choose other monitoring that is useful and of value to the performance of theequipment. Tlie specific monitoring will be required to be disclosed during the procurementprocess. "State of the art" is used to suggest that computer-based systems are preferred overanalog devices.

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D) Specific Comments - Drawings

Comment 1: Regarding Drawings C-01 through C-ll (containing the excavation Plan andProfile of Exposure Units 1-8), and drawings C-12 through C-17 (containingactivities including haul roads, site layout/paving plan, site grading and drainageplan, and dewatering bed), to help conduct the CWA section 401 and 404 reviewsfor compliance with these ARARs, actual "numbers'1 for the various constructionactivities were not included. For example, amount of wetland disturbance (duringexcavation and construction activities), length of stream to be impacted,dimensions and volume of rip rap to be placed, amounts of fill to be placed(cover-capping), amount of fill to be placed for site restoration (hydric soils), mustbe indicated on the drawings or within the specifications.

FBAG Response:

See the response to Specific Comment C-53.

Comment 2: DRAWING NO. C-01: Drawings show 2 feet of cut at the steel bridge. Discusswhat precautions will be undertaken to insure no detrimental effects to the bridge.

FBAG Response:

The 2-ft excavation beneath the bridge in Reach 1 should not cause a structural problem for thefooter. FBAG will send a copy of the drawings to Conrail for review and comment.

Comment 3: DRAWING NO. C-02: Discuss to what extent will excavation take place at andaround the box culverts.

FBAG Response:

As shown on the drawings, the excavation will be to the concrete apron of the culverts.

Comment 4: DRAWING NO. C-05: Discuss how the 12ft x 12ft CMP will be protected againstscour during excavation.

FBAG Response:

The 1-ft excavation will be up to the concrete apron and as specified in Section 01000. Thecontractor is required to place the geotextile in the excavation at the end of each excavation andbackfill with riprap within 3 working days. FBAG feels this procedure will provide the requiredprotection from erosion and that a 1-ft excavation will not cause any structural damage. FBAGwill send a copy of the excavation plans and drawings to the appropriate agencies (ODOT, city orcounty engineer) for review and comment.

Comment 5: DRAWING NO. C-ll: No cut is shown in this Profile section and must be, sincediscussions for this EU indicated that there would be sediment removal plannedfor this exposure unit.

FBAG Response:

Drawing C-ll does show the excavation from station 49+86 to 54+61.

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Comment 6: DRAWING NO. C-12: How much truck traffic is projected to go throughresidential areas? Will Section 02135 address requirements for travel throughpublic roads?

FBAG Response:

The total volume of sediments to be removed is 5,368 yd3 and approximately 2,000 tons ofgravel for the haul roads. Approximately 250 to 400 yd3 per day or 25 to 40 truck loads per dayof contaminated sediments are expected to be removed. Section 02135, Offsite Transportation,will cover transportation of sediments from the Fields Brook site to the permitted facility. Thespecification will cover the transportation of hazardous material. Section 02130, MaterialHandling, covers onsite transportation.

Comment 7: DRAWING NO. C-13: Provide design details/cross sections and calculations forthe detention basin and the 100,000 gal retention facility.

There should be a note referencing the perimeter berm Detail on DRAWINGNO. C-16.

Provide additional information/detail, specifications and designconcepts/calculations for the Temporary Enclosure Detail.

Note 1 states that the location is preliminary and the final site has not beendetermined; however, it was EPA 's understanding that the Acme site beenidentified for materials handling prior to offsite shipment. Discuss why this issuehas not yet been finalized, what additional facility siting locations are now beingconsidered, whether facility siting and access will not be finalized by the 90% RDand whether the overall schedule will be impacted due to delays associated withthis issue's resolution.

FBAG Response:

Design calculations will be provided with the 90% design. FBAG will add a cross section of theretention basin. The retention basin is a modular tank lined with polypropylene. FBAG will adda note to Drawing C-13 to identify the tank as a EconoTank with a polypropylene linermanufactured by ModuTank, Inc.

A note will be added to Drawing C-13 that the detail of the berm is presented inDrawing C-16.

Additional information on the building will be provided in the 90% design. The plan is to use aSprung building if control of VOC releases is required.

See the response to Specific Comment 15 concerning the location of the pretreatment facility. Noschedule impact is anticipated.

Comment 8: DRAWING NO. C-14: The granular/crushed rock material shown under the slabsshould be labeled.

FBAG Response:

A label will be added to identify the gravel beneath the concrete slab.

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Comment 9: DRAWING NO. C-16: There are two types of geotextiles shown in the DetailSections. However, information is only given for the woven geotextile. Pleaseprovide a note indicating what type ofnonwoyen geotextiles are acceptable. Also,indicate what type of geotextile is being specified in Detail 1 and in the TypicalGravel Pad Detail, Type A. There should be a note referencing the perimeterberm Detail on this drawing.

FBAG Response:

A note will be added to Drawing C-16 to specify the geotextile filter fabric as Type B, as definedby State of Ohio Department of Transportation's Construction and Material Specifications,Section 712.09.

Comment 10: DRAWING NO. C-17: The Temporary Diversion Pipe diameter is not given in theTypical Stream Diversion Detail, and should be.State Department of Transportation (DOT) Standard Specifications criteria andterminology is typically used to specify riprap. Discuss whether Dso Riprap is astandard Ohio DOT material. Provide the design backup for the choice of riprapsizes and slope value used. The FBPRPRAG should consider consolidating stonesizes, since purchasing a single size may be more cost effective versus purchasingseveral different sizes.

FBAG Response:

The temporary diversion pipe is sized in a table on Drawing C-17, Detail A, with the normalflow rate.

The riprap size was based on the velocity of the stream in each reach. The size is not a standardfrom the ODOT specifications, except that the D50 - 0.5 foot is the same as ODOT, Type D. Itwould have been easier to specify one size of riprap, but based on the velocity and the depth ofthe excavation, the sizes of riprap are different, and we cannot use stone larger than 1 ft tobackfill a 1 ft excavation.

E) Comments • Design Investigation Report Response

Comment 1: SDWIDI Report: EPA could not locate certain items that were to be provided,such as information on effect of carbon specifications on removal efficiency (pg.55), or questions related to dewaterability of sediment (pg. 56). In addition, someinsert pages were different than the comment response e.g., channel bottoms andsideslopes information in Table 3-8 was different from page 56.

FBAG Response:

WCC will provide the response to this comment.

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Responses to Supplemental Comments from USEPA Region Von the 10/25/95 Draft Sediment Operable Unit

Intermediate (60%) Design Report, Fields Brook Superfund Site

/. Section 1450, Technical Specification for Contractor Chemical Data Quality:

Comment a. Representativeness should be defined as the degree to which data accurately andprecisely represents a characteristic of a population, parameter variations at asampling point, a process condition or an environmental condition.Representativeness is a qualitative parameter which is dependent upon the properdesign of the sampling program and proper laboratory protocol.

FBAG Response

The definition of representativeness will be amended to state: Representativeness is the degree towhich the data accurately and precisely represent the conditions at the site. This is a qualitativeparameter dependent on the proper design of a sampling plan and appropriate laboratoryprotocols.

Comment b. Completeness should be defined as the amount of valid data obtained from ameasurement system compared to the amount that was expected to be obtained.

FBAG Response

The definition of completeness will be amended to state: Analytical completeness is the amountof valid data obtained from a measurement system compared with the amount expected to beobtained from a stated number of analyses.

Comment c. Comparability should be expressed as the confidence with which one data set canbe compared with another. The extent to which existing and planned analyticaldata can be compared depends on the similarity of sampling and analyticalmethods. Requiring the use ofEPA -approved methods will not assurecomparability with existing site data unless the methods are similar.

FBAG Response

In this instance, the data generated will be from the analysis of construction materials and holdingtank water, to determine disposal requirements; therefore, there is no existing historical databasethat would require a consistent choice of methods to ensure comparability. The definition ofcomparability given in Section 01450 is adequate in this instance to ensure that the data producedwill be comparable to other waste characterization activities.

Comment d. Precision is measured by relative percent difference (RPD) or relative standard orrelative standard deviation.

FBAG Response

The text will be revised to state: Precision is defined in terms of relative percent difference.

Comment e. Corrective actions should specify what effect the exceedance of the acceptabilitylimits has upon the associated data, and under what circumstances the data can beused.

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FBAG Response

The paragraph was expanded, as follows: When limits of acceptability are exceeded, documentthe poor recovery or precision, including a description of how the exceedance will affect theassociated data and their useability. See Part 1.8.3 for a further description.

Comment/. The matrix spike section should specify that for each organic analysis, a matrixspike/matrix spike duplicate should be analyzed for every 20 samples.

FBAG Response

The text was revised as follows: Analyze one matrix spike and matrix spike duplicate for every20 samples for organics analyses.

Comment g. The Standard Reference Material Section should specify that the reference standardsare used to validate a particular analytical procedure by comparing the responsegenerated by the laboratory's analytical standards to the response produced by thereference standards.

FBAG Response

The text was revised as follows: These standards are used to validate a particular analyticalprocedure by comparing the response generated by the laboratory's analytical standards with theresponse produced by the reference standards. The standards usually originate from EPA, theNational Institute of Occupational Safety and Health, or the National Institute of Standards andTechnology.

Comment h. All laboratory SOPs should be reviewed and approved before samples are submittedto the laboratory. Specifying the use of EPA approved methods is not enough toensure useable data. A review needs to be performed to ensure that the methodbeing proposed is appropriate for the sample matrix and expected level ofcontamination.

FBAG Response

It is standard practice to require the laboratory to submit a complete set of its SOPs, which arereviewed and approved before the contract is awarded. The contract gives precedence to theEPA method rather than the laboratory SOP. Therefore, the comment was not incorporated.

Comment i. The data validation process must include a review of the raw data, so thatlaboratory transcription errors and the proper operation of analytical instrumentscan be checked.

FBAG Response

The paragraph was amended as follows to include reference to the EPA protocols for datavalidation, which direct the validator to check transcription, instrument operation, and calculationof results: The validation shall be carried out in accordance with the USEPA ContractLaboratory Program National Functional Guidelines for Organic Data Review(EPA-540/R-94/012) and the USEPA Contract Laboratory Program National FunctionalGuidelines for Inorganic Data Review (EPA-540/R-94/013), as appropriate to the type ofanalysis.

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//. Section 1460, Disposal of Construction Materials

Comment a. Sampling the Haul roads must also occur where there is visual evidence ofcontamination (for example, if staining of the haul road or a visual difference inareas of the haul road material occurs in addition to the locations within EPA 's12/13/95 comments).

FBAG Response

The additional locations indicated in EPA's 12/13/95 comments will be sampled, but no biasedsampling strategy will be adopted unless the analysis of any of the haul road samples showscontamination. If there is visual evidence of a spill, the gravel from this area will be consideredcontaminated, removed, and taken to the permitted landfill as contaminated material. Spills onpublic roads will be cleaned up immediately and taken to the permitted landfill for disposal.Stains on public roads will not be sampled because any stains are probably from motor oildripping from vehicles, etc. and not from the spill of contaminated material.

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APPENDIX A

A02311/24/96 2:13pn

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Job No. 22257-001Section No. 13200

Revision 0

SERVICE: Weiteweter Treetment Syettm

Oet* Sheet: Influent end Effluent Che re cteriitic*

brfh_ «» Mrir•ilNMiil GneiBriennre

VOLATTLES

1 ,2*Dfchloroethene

1 , 1 ,2,2-Tetnchloroethene

T etrec M o roet he ne

1 , 1 , 2-Trf chloroethene

Trlchlo roe then*

Vinyl Chloride

SEMIVOLAT1LES

He xaehlorobenz ene

He xac hlo rbut adle ne

PESTICIDES

Dleldrin

pca«Aroclor-1248

Efflucm CtiMCUrieHc* IHPDES olMhefg* Smlta to neidebtnoh)

Antimony

Art.nlc

Cedmium

Chromium, totel

Chromium, hex*velent

Copper

Cyanide, tree

Lead

Mercury

Nickel

Selenium

Silver

Thallium

Zinc

Polychlorineted Blphenyle

j Cjjl Performance Specification for FieldsbrookCWjjy Wastewater Treatment

3,200 ftgH.

22.000 py/l

45,000 ^g/L

230>/g/L

18,000 j/g/L

150/fg/L

380 M/L

1 1 0O pg/L

213.7 j/g/L

eeo pg/LDely Meidmum bvoA)

To be provided by OEPA

30-Day Awvnga (f /L)

To be provided by OEPA

Job No,22257

Specification 13200 REV

Appendix A A

ShP*t 7 of 7

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Job No. 22257-001Section No. 13200

Revision 0

SERVICE: Waetewater Treatment System

Data Sheet: Wastewater Characteristic

|nf1uem characteristics

T*mp*F*tur» *C

pH

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Job No.22257

« .-, FUM.hrMk Specification 1 3200 REV

eetment Appendix A A

Sheet 1 of 2

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APPENDIX B

A02311/24/96 l:33un

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Wttrfwai-d-Clyde f c o o 0 o 8 7 8«vm • oa «nwonm«m

ATTACHMENT 1

Source Averaging Issue

USEPA expresses concern that "if the average concentration of all exposure routes wereconsidered per EU, areas cleaned within the Brook to non-detect might be contaminatedwith inflowing contamination to concentrations below CRGs but above CUGs, due tothe averaging method." USEPA further states that even if input concentrations arelimited to CUG levels, they may "adversely artect..brook statistics". USEPA implies withthese statements that they believe that source inputs at any concentrations level (abovenon-detect but particularly above CXJG levels) would raise the average Fields Brooksediment concentrations above the CUG, This is not true. This misunderstanding seemsto have arising out of losing sight of the concept of averaging as previously discussed inthe CRG approach. Risk is related to average concentrations on an Exposure Unit(EU) basis, and it does not matter if portions of an EU (surface layer versus depth,inputs from one sub-basin versus another) contain COCs with concentrations greaterthan the CUG as long as the EU meets the CUG on average.

It is important to note in the context of USEPA's statements that sediment input toFields Brook from the source areas via the sub-basins are additions to the EUs, notreplacements of sediment in the EU. These two concepts appear to have been confusedThe addition of sediment with an average concentration at the CUG to sediment alreadyhaving an average concentration at the CUG will result in no change in concentration(i,e, the average concentration will remain at the CUG). While it is true that thereplacement of Fields Brook sediment at non-detect concentrations with incomingsediment at any concentration above detection levels would increase the average COCconcentration in the sediment, this is not how new sediment inputs occur. Thus thereis no concern for this process to "adversely affecUbrook statistics" as long as the averageof new sediment inputs that are added to the EU are at or below the CUG.

USEPA is apparently concerned that incoming sediment with concentrations at or abovethe CUG wfll cover a clean surface layer of sediments (although clean at the surface, theaverage concentration equals the CUG over depth) in Fields Brook. But the EU is notdefined as only the surface layer ot the sediment. Rather, the EU has a depth

WMdiwrd-Olyd* ConMiltttRta * A subaWlwy o( Woodward-Clyde Group. Inc.-Al-

14

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7 Woodward-Cfyde

component The distribution of COCs at the surface of the EU may change, but theaverage concentration over the volume of sediment remains constant Stated anotherway, a $™?\\ volume of sediment from source areas with average COO concentrationsat CUG values is added to a large volume of sediment already in Fields Brook also withan average COC concentration at the CUG. The total volume of sediment in FieldsBrook has now increased slightly and remains with an average COC concentration equalto the CUG.

The concepts described above can be illustrated with a simplified example. Figure 1 Ais a schematic representing the length and depth of a hypothetical EU. The numericalvalues represent multiples of the CUG value. Tne eight values shown average to onevahie, meaning that the average concentration of the COC in this BU is equal to theCUG. Figure 1.B shows the EU after input of source area sediments from two sub-basins* The average COC concentration of the sub-basin inputs also is equal to theCUG, although the concentration from sub-basin Y is greater than the CUG, while theconcentration from sub-basin Z is less than the CUG. (Note that the boxes representingthe surface layer from source area inputs are represented as the same size as the othersediment boxes, while in actuality this surface layer is very thin compared to the depthof the sediment in the EU.) The average concentration of the ten boxes shown in Figure13 also is equal to the CUG (average = 1), demonstrating that the addition of sedimentwith an average concentration of the CUG (top two boxes) to existing sediments withan average concentration of the CUG flower eight boxes) results in an average equal tothe CUG overall. Note that the surface layer shown by the shaded boxes in Figure 13does not have an average concentration equal to the CUG, but this is irrelevant becausethe total volume of sediment in the EU maintain its average concentration at the CUG.

USEPA also has rejected the averaging of multiple sub-basin inputs to the same EU.This rejection appears to be predicated on the misunderstanding described above as tohow the sub-basin sediment additions to Fields Brook affect the average concentrationof COCs in Fields Brook sediment If FBPRPO is required to limit COC concentrationsin each of multiple sub-basins to CUG values, then it is clew that some sub-basins wouldcontribute COGs at the CUG, while some have already been determined to contributeCOCs below the CUG. If such multiple sub-basins contribute to the same EU, then theaverage sub-basin input to that EU would be less than the CUG. Such a requirement

' ,/•; D995/nU/AOUIhVAOB>niA.001 -A2- 00-WMM

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/'i-li£-l99t 14:03 GPHbitni

Woodward-ClydehO 0 n 0 8 7 8

ROD In contrast, the ROD requiems *a be met by bnutmfl<>** average 01KOU. in CQniR»i. u»* -x values. This approach is

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Wood ward-Clyde

fcO 0 8 7 8

0,1

0.1

0.1

1.9

1

U

18

.8

Post-remediation, before input from source areas. Average concentration overthe volume of sediment in the EU * 1.

From Sab-basin Y

0.1

0.1

From Sub-basin Z

0.1

1.9 12

guaffiiiffuEiSto ": "iiTfcte

as

B. Post-remediation, post sediment addition from source areas: Averageconcentration of source inputs * 1, average concentration over the volume ofsediment in the EU * 1. Note that the average concentration of the surfacelayer (shaded boxes) exceeds 1, but this does not violate any requirement for theEU

-A4- W-W-H

TOTHL