REPORT Remedial Action Work Plan - Southern Area Operable Unit 3 (OU-3) 216 Paterson Plank Road Carlstadt, New Jersey
Submitted to: 216 Paterson Plan Road Cooperating PRP Group
Submitted by: Golder Associates Inc. 200 Century Parkway, Suite C, Mt. Laurel, New Jersey, USA 08054
+1 856 793-2005
20141009
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Distribution List US Environmental Protection Agency
New Jersey Dept. of Environmental Protection
216 Paterson Plank Road Cooperating PRP Group
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Table of Contents
1.0 INTRODUCTION...... 5
1.1 Background ...... 5
1.2 RAWP Organization ...... 6
2.0 REMEDIAL ACTION PROJECT TEAM ORGANIZATION ...... 7
2.1 USEPA Representative ...... 7
2.2 The Project Coordinator ...... 7
2.3 Remedial Designer/Supervising Contractor ...... 8
2.4 Contractors ...... 8
2.5 Site Health and Safety Coordinator ...... 9
2.6 Training Requirements ...... 9
3.0 IMPLEMENTATION OF THE REMEDIAL ACTION ...... 10
3.1 Implementation of the Final Design ...... 10
3.1.1 Construction Sequencing...... 10
3.1.2 Drilling...... 11
3.1.3 Groundwater Treatment/Monitoring ...... 12
3.2 Submittals ...... 13
3.3 Permit Equivalencies and Requirements ...... 13
3.4 Access Agreements ...... 14
3.5 Clean and Green ...... 14
3.6 Decontamination...... 15
4.0 HEALTH AND SAFETY PLAN ...... 15
5.0 OPERATIONS, MAINTENANCE AND MONITORING PLAN ...... 15
6.0 QUALITY ASSURANCE / QUALITY CONTROL ...... 15
6.1 Performance Standards ...... 15
6.2 Implementation of Construction Quality Assurance Plan ...... 16
6.3 Implementation of Construction Quality Control ...... 16
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6.4 Quality Assurance Project Plan...... 17
7.0 COMMUNICATION AND REPORTING ...... 17
7.1 Lines of Communication ...... 17
7.2 Meetings ...... 17
7.3 Daily Records ...... 18
7.4 Construction Issues and Corrective Measure Reports ...... 18
7.5 Photographic Records...... 18
7.6 Final Record Documentation Report ...... 19
7.7 Records Storage...... 19
8.0 SCHEDULE ...... 19
9.0 REFERENCES ...... 19
TABLES Table 1 Well Construction, Baseline and Performance Monitoring Program
FIGURES Figure 1 Site Location Map Figure 2 Project Organization Chart (in text) Figure 3 Well Installation Phases Figure 4 Schedule
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LIST OF ACRONYMS AST – Above Ground Storage Tank CD – Consent Decree CEA/WRA - Classification Exception Area/Well Restriction Area CQA – Construction Quality Assurance CQAP – Construction Quality Assurance Plan FRDR – Final Remedial Design Report Golder – Golder Associates Inc. Group – 216 Paterson Plank Road Cooperating PRP Group H&S – Health and Safety HASP – Health and Safety Plan IC – Institutional Control IDW – Investigative Derived Waste ISCO – In-Situ Chemical Oxidation MNA – Monitored Natural Attenuation N.J.A.C. – New Jersey Administrative Code NJDEP – New Jersey Department of Environmental Protection OM&M – Operations, Maintenance and Monitoring Plan OU-2 – Operable Unit 2 OU-3 – Operable Unit 3 PPE – Personal Protective Equipment PDI – Pre-Design Investigation QA – Quality Assurance QAPP – Quality Assurance Project Plan QC – Quality Control RA – Remedial Action RAPM – Remedial Action Progress Memorandum RAWP – Remedial Action Workplan RAR – Remedial Action Report ROD – Record of Decision RPM – Remedial Project Manager SHSC – Site Health and Safety Coordinator Site – 216 Paterson Plank Road Site TBD – to be determined USEPA – United States Environmental Protection Agency VOCs – Volatile Organic Compounds
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1.0 INTRODUCTION On behalf of the 216 Paterson Plank Road Cooperating PRP Group (Group), Golder Associates Inc. (Golder) has prepared this Revised Remedial Action Work Plan (RAWP) for the Southern Area of Operable Unit 3 (OU-3) at the 216 Paterson Plank Road Site (Site), Carlstadt, New Jersey. The USEPA issued a Record of Decision (ROD) on September 27, 2012 (USEPA, 2012) for OU-3 identifying the selected remedy to address Site related impacts to deep groundwater in the glacial deposits and bedrock. The selected remedy consists of treatment of impacted deep groundwater using in situ treatment technologies, Monitored Natural Attenuation (MNA) during and after active treatment, and implementation of Institutional Controls (IC). USEPA entered a Consent Decree (CD) for OU-3 with the Group that was lodged on November 6, 2013 and addressed the implementation of the OU-3 remedial design and remedial action (RA). OU-3 is the final operable unit for the Site.
This RAWP for the Southern Area remedy addresses the in-situ treatment, of deep groundwater by In-Situ Chemical Oxidation (ISCO) to address contamination primarily consisting of 1,4-dioxane, together with performance monitoring to achieve the Site-wide remedial action objectives. MNA sampling and analysis is currently being implemented in accordance with the Draft Operations, Maintenance and Monitoring Plan, included as Appendix D of the approved Southern Area Final Remedial Design Report (FRDR). An IC in the form of an easement is in place for the 216 Paterson Plank Road property that limits use of the property and provides for a deed notice restricting the use of the property consistent with the remedy. In addition to the deed notice, a classification exception area/well restriction area (CEA/WRA) will be established to prevent the installation of wells within the plume area until groundwater quality is restored. As described in the FRDR, the CEA/WRA will address site-wide groundwater including both the Northern and Southern Areas and will be established following implementation of this RAWP. This Revised RAWP incorporates responses, dated February 9, 2021, to USEPA comments received on January 11, 2021. 1.1 Background The Site is in a light industrial/commercial area of Carlstadt, New Jersey (Figure 1) and includes a 6-acre property that was used as a chemical recycling and waste processing facility until 1980. The property is bordered by Paterson Plank Road to the southwest, Gotham Parkway to the northwest, a trucking company to the southeast, and Peach Island Creek to the northeast.
The current property owner is the Borough of Carlstadt. There have been no activities on the property since operations ceased, other than those related to site remediation and the recent construction of a solar panel array.
OU-3 of the Site is divided into two distinct areas: a Northern Area and a Southern Area, Pre-Design Investigation (PDI) activities were initiated at the Site in April 2015. The PDI provided information to complete the remedial design for the Northern Area, and data to design a pilot test to remediate Southern Area contamination (primarily 1,4-dioxane) via ISCO. The PDI Report (Golder, 2016) was approved by USEPA on September 13, 2016 and the ISCO pilot test for the Southern Area was subsequently completed and the associated Report (Golder, 2018) was approved on October 26, 2018.
The Preliminary Remedial Design Report – Southern Area Groundwater (Golder, 2019) was submitted to USEPA on January 25, 2019 and addresses the groundwater impacts in the Southern Area by means of ISCO and MNA, using information collected during the ISCO Pilot Test. The report also included a recommendation to consider co- metabolic biodegradation as an alternative in situ technology to treat 1,4-dioxane in the Southern Area. A pilot test for this treatment alternative was conducted between September 2019 and February 2020 following a USEPA-
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approved work plan (Golder, 2019). Overall, this pilot study did not demonstrate robust biodegradation of 1,4- dioxane to support its use at full-scale on this Site (Golder, 2020).
The Final Remedial Design Report – Southern Area Groundwater, addressing USEPA comments on the draft report and including a Construction Quality Assurance Plan (CQAP), Technical Specifications; and a Draft Operations, Maintenance and Monitoring Plan (OM&M) was approved by the USEPA on September 18, 2020. 1.2 RAWP Organization Consistent with the Consent Decree requirements, the purpose of this RAWP is to provide methodologies, plans, and schedules for the Southern Area OU-3 RA construction. Construction will be implemented in multiple phases of treatment and performance monitoring. The RAWP is organized as follows: Project Team organization and responsibilities (Section 2) Implementation of RA (Section 3) Health and Safety Plan (Section 4) Draft Operations, Maintenance and Monitoring Plan (Section 5) Quality Assurance / Quality Control (Section 6) Communications and Reporting (Section 7) Schedule (Section 8)
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2.0 REMEDIAL ACTION PROJECT TEAM ORGANIZATION The project organization is summarized in the chart below follow by descriptions of the various key roles.
Figure 2 - Project Organization Chart
2.1 USEPA Representative In general, USEPA’s designated Remedial Project Manager (RPM) will communicate, as necessary, with the Project Coordinator regarding technical and administrative issues and will monitor the RA construction. The RPM will also coordinate with the New Jersey Department of Environmental Protection (NJDEP) and the public, as necessary.
The RPM will be invited to attend regular progress meetings. 2.2 The Project Coordinator The Project Coordinator will serve as the Group’s representative and will be responsible for communicating directly with the USEPA and Remedial Designer.
In general, the Project Coordinator’s responsibilities include: Coordinate and communicate directly with USEPA during all RA activities
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Approve/disapprove, with concurrence from USEPA, any substantive changes proposed by the Remedial Designer to the FRDR and Contract Documents (i.e., construction drawings and specifications) Negotiate any changes to Construction Contracts, based upon recommendations by the Remedial Designer Resolve any design clarifications or interpretations with the Remedial Designer and specialty Contractors Participate, directly or via a designee, in weekly progress meetings, Site inspections, and other meetings, as necessary. 2.3 Remedial Designer/Supervising Contractor The responsibilities of the Remedial Designer include the following: Prepare agenda for, preside at, and record project meeting minutes, including a pre-construction meeting, and other meetings, as necessary Monitor and coordinate specialty Contractors’ and Subcontractor’s work in conformance with the technical requirements specified within the Contract Documents Review all proposed design and specification changes Provide clarifications to Contractors on the Southern Area FRDR and Technical Specifications Monitor and document installation of injection and monitoring wells Document injection events Document groundwater sampling events Review submittals required by the Southern Area FRDR and Technical Specifications Prepare periodic construction progress and monitoring reports for distribution to the project team Maintain project record drawings and files for storing reports generated during RA construction Evaluate materials and construction changes proposed during construction for co mpliance with the intent of the Southern Area FRDR and Technical Specifications.
Additionally, the Remedial Designer will be responsible for overseeing and implementing the construction quality assurance plan (CQAP) (included as Appendix E to the Southern Area FRDR).
The Remedial Designer will document that the project construction has been completed in conformance with the Southern Area FRDR and Technical Specifications. The Remedial Designer will also be responsible for reviewing each stage of construction activities and will have authority to reject materials and workmanship that is not in compliance with the Southern Area FRDR and Technical Specifications. 2.4 Contractors Various specialty contractors and subcontractors will be engaged to implement the RA. Drilling and well installation activities will be performed by a NJ licensed Drilling Contractor. The ISCO injection activities, including the procuring of the injection amendment materials, will be conducted by qualified personnel. Additional contractors include a NJ licensed surveyor to survey the injection and monitoring wells and a certified analytical
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testing laboratory to analyze performance monitoring samples. The Drilling Contractor will engage a specialty subcontractor for geosynthetic liner/cap repairs, where necessary. Contractors that meet the qualifications identified in the FRDR will be selected by competitive bidding. USEPA will be notified of the selected Contractors prior to conducting RA activities.
Under the oversight of the Remedial Designer, the specialty contractors will be responsible for implementing the final design, as specified in the Southern Area FRDR and Technical Specifications.
The contractors will also be responsible for implementing specific field Quality Control (QC), as required by the Technical Specifications and the CQAP. Upon completion of the project, the Drilling , Injection, and Surveying Contractors will provide record drawings (i.e., well records) and permits to the Remedial Designer for review, and to the Project Coordinator for record keeping. 2.5 Site Health and Safety Coordinator The Remedial Designer will provide a designated Site Health and Safety Coordinator (SHSC) to perform health and safety duties during remedial action construction and ongoing monitoring activities, as specified by the technical specifications, CQAP, and project health and safety plan (HASP) (Golder 2020). The SHSC will be on site and will be supported by the Remedial Designer’s Health and Safety Officer as necessary.
In general, the SHSC’s responsibilities include: Review H&S qualifications of all personnel on Site Coordinate and manage compliance of Site personnel with the HASP Conduct and participate in daily safety briefings and other regular project meetings to address Health and Safety (H&S) issues Coordinate with Project Coordinator and Remedial Designer on a routine basis Maintain comprehensive updated personnel H&S training files for all workers at the Site. The SHSC and field staff will be empowered to stop or redirect any Site work as necessary to resolve H&S issues and/or concerns at the Site. Concerns may include, but not be limited to, non-compliance with the HASP, and if, in the opinion of the SHSC, work is being performed in an unsafe manner. 2.6 Training Requirements It is anticipated that the drilling and survey work will be completed in Level D personal protective equipment (PPE). The ISCO injections and associated activities are anticipated to require a minimum of Level D3 PPE, including (Tyvek® or polycoated Tyvek® coveralls with nitrile gloves (liner and outer, as needed), goggles and face shield (or full-face respirator) and chemical resistant safety boots). Any decision to upgrade to a higher level of protective equipment will be based on changed conditions consistent with air monitoring per HASP requirements. Field personnel will be required to have Occupational Health and Safety Administration 40 hour, 29 CFR 1910.120 H&S training and current annual refresher course documentation prior to starting construction.
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3.0 IMPLEMENTATION OF THE REMEDIAL ACTION This section describes the implementation of the Southern Area OU-3 RA construction in accordance with the Southern Area FRDR, Technical Specifications, and Consent Decree Statement of Work. 3.1 Implementation of the Final Design The layout of injection and monitoring wells specified in the FRDR is shown in Figure 3 and reflects access limitations associated with the OU-2 slurry wall and underground conveyance piping as well as overhead power lines.
The injection and monitoring wells will be installed in two (2) phases: Phase A: Installation of five (5) new monitoring wells and four (4) injection wells as shown on Figure 3. Baseline sampling, initial injections, and post injection monitoring through the first quarter will be conducted using this well network as described in Section 3.1.3. Baseline sampling of these monitoring and injection wells will provide an understanding of the current distribution of 1,4-dioxane. Injections and post injection monitoring will provide additional information on conditions north of the previous pilot test location (see Figure 3) so that design adjustments can be made, if warranted, during Phase B 1. Phase B: Installation, baseline sampling and injections using the remaining eight (8) injection wells and existing well MP19-12 will be conducted based on Phase A results and any adjustments as agreed to with USEPA. Performance monitoring will be conducted as described in Section 3.1.3. 3.1.1 Construction Sequencing Phase A In general, the Phase A construction activities will be sequenced as follows: Mobilization ▪ Obtain permits/permit equivalencies, as required
▪ Utility Clearance
▪ Mobilize labor, equipment, and materials Site Preparation ▪ Construct a decontamination pad within the Site fence, at a location convenient to the above ground storage tank (AST)
▪ Make necessary changes to the trees and fence adjacent Paterson Plank Road (cut or trim trees; temporarily dismantle fencing for drill rig access)
▪ Stage equipment, as appropriate, within or adjacent to the Site building
1 Factors that will be considered when confirming placement of Phase B wells include the current extent of 1,4-dioxane and observed radii of influence during Phase A injections. 2 Based on a USEPA comment on the Draft Final Remedial Design Report – Southern Area Groundwater existing well MP-19-1 is proposed for injection rather than MP16-2. This change was not consistently made throughout the FRDR.
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Installation of Phase A wells ▪ Installation of monitoring and injection wells
▪ Development of monitoring and injection wells
▪ Survey of monitoring and injection wells
▪ Repair of OU-2 cap and cover as necessary following installation of on-property injection and monitoring wells
▪ On Site management, characterization sampling, and off-Site Disposal of Investigation Derived Waste (IDW) Baseline sampling of new wells ISCO Injection Treatment ▪ First injection of ISCO amendment Monitoring, Testing, and Sampling ▪ PID measurements during drilling and sampling
▪ Performance monitoring groundwater sampling of the Southern Area Remedy
▪ Progress monitoring sampling for the Northern Area Remedy and MNA sampling will be ongoing as per the associated approved designs Additional ISCO injections will be performed as necessary in accordance with the FRDR Phase B Phase B construction activities will follow a similar construction sequence. 3.1.2 Drilling The selected drilling Contractor will mobilize crew, equipment, materials, and temporary facilities to the Site to conduct and support the work activities. Public and private utility locates will also be conducted as part of Site mobilization. Soft-Dig techniques will be used to clear at a minimum the top 5 feet of all drilling locations. It is anticipated that the wells will be installed using Hollow Stem Auger/Air-rotary and/or Sonic drilling methods (drilling method to be determined by the selected Driller) in accordance with the Technical Specifications.
For the well located within the slurry wall, preparation for cap penetrations will be conducted as follows: Removal of the topsoil, cover soil, and underlying geosynthetic cap layers, within a 2-foot diameter around the drilling location to expose the underlying material at approximately 2 feet depth. Topsoil and cover soil will be segregated and temporarily stockpiled at the property for potential later reuse. Removed geosynthetic materials will be stored in a weather protected location, as directed by the Remedial Designer. Once the cap materials are cleared from the area, drilling work will be conducted.
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For wells located within the stone aggregate cover, preparation for penetrations will be conducted as follows: Removal of the stone aggregate and underlying geotextile within a 3-foot diameter around the proposed location, using hand tools. The stone aggregate will be segregated and temporarily stockpiled for reuse following well construction. Geotextile will be cut and removed and stored for reuse. Once the materials are cleared from the area, work will be conducted.
Steel isolation casing will be installed through the shallow fill and into the confining clay unit before drilling is advanced through the isolation casing to the target depth. Wells will be drilled to the top of bedrock and screened using 0.01-inch slot size screens, across the entire soft till aquifer based on field observations which may range up to 20 feet in length. Monitoring wells that have screen lengths longer than 10 feet will be subject to discrete interval sampling when compliance with groundwater quality standards is to be demonstrated.
The Contractor will construct and develop wells in accordance with NJDEP technical requirements (i.e. , NJDEP N.J.A.C., 7:9D Well Construction and Maintenance Requirements). Well casings will consist of 2-inch diameter flush joint, threaded, schedule 40 PVC casing. Wells will be completed with a threaded top (national pipe thread, female) within a flush-mount vault (such as A0721-018 Monitor Well Manhole or approved equivalent), or approved stickup protective casing, to allow space for injection headers and provide sufficient support for vehicular traffic. At the end of each day the drilling area will be secured and cleared to the extent practicable.
After the Phase A wells are completed, the site cap will be restored to original condition as specified in the Technical Specifications. A specialist liner installer approved by the Remedial Designer will repair areas wit hin the cap impacted by drilling activities. A New Jersey licensed surveyor will survey the new injection and monitoring wells. 3.1.3 Groundwater Treatment/Monitoring Baseline samples will be collected from the new injection and monitoring wells at least two weeks following development to allow natural groundwater flow to be reestablished. Following receipt and evaluation of the baseline sampling results, amendment injections and post-injection sampling will be conducted in accordance with the FRDR. The baseline and performance monitoring sampling program is detailed in Table 1 and will include analysis of Volatile Organic Compounds (VOCs), 1,4-dioxane, dissolved metals (including hexavalent chromium)3, and select conventional parameters (Total Organic Carbon, total carbonate alkalinity reported as CaCO3, and sulfate).
The injection Contractor will mobilize crew, equipment, materials, and temporary facilities to the Site to conduct and support the injection activities. The injectate will use 25% by weight sodium hydroxide and a 20% by weight solution of solid sodium persulfate and potable water. Injections will be performed using a pressurized injection system within appropriate check valves and other safety features. Back-pressures are anticipated to be under 20 psi but will be limited to a maximum of approximately 30 psi (lithostatic pressure) to avoid opening existing fractures in the formation or creating new fractures. A flow rate of approximately 1 to 5 gallons per minute is anticipated. Subsequent injections will be conducted as necessary based on progress monitoring results and additional sodium hydroxide may be injected in a separate event to maintain appropriately alkaline conditions (a
3 To monitor for the potential of metals mobilization due to the higher solubilities of some metals under basic conditions.
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pH of 10.5 or higher is desired). Additional potable water will be injected to flush the system following injection of activated persulfate.
At the end of each day the injection area(s) will be secured and cleared to the extent practicable, and on the completion of injection activities, the property will be cleared of all injection and sampling materials.
Field screening measurements of pH, conductivity, oxidation-reduction potential and temperature will be collected from injection wells using a direct measurement probe prior to and following each injection event, along with field tests for persulfate starting a few hours after injections and at increasing time intervals to evaluate injection progress until the persulfate appears to be largely consumed.
Approximately one month following the initial injections, progress monitoring samples will be collected from injection wells and monitoring wells within the treatment area as detailed in (Table 1). Samples will be analyzed for the same parameters as in the baseline round 4. It is currently anticipated that progress monitoring of injection and monitoring wells will initially be conducted quarterly.
Additional injections will be conducted when either substantial rebound has occurred (on the order of 50% of baseline concentrations) or if rebound appears to have stabilized and the remaining 1,4-dioxane is sufficiently high to make a further treatment event efficient. Based on the pilot test, the limits of ISCO treatment in a given well are expected to be reached after one or two injections5. 3.2 Submittals Contractors will be required to prepare construction submittals in accordance with the Technical Specifications to demonstrate that its intended construction sequence and activities will be in accordance with the FRDR including the CQAP and Technical Specifications. All construction submittals will be issued to the Remedial Designer/Supervising Contractor for review and comment, prior to any associated construction activities.
Construction completion documents including well permits, well records, survey records, NJD EP Form As and Form Bs, and total quantities of supplies used for well construction will be required as submittals per the FRDR from Specialty Contractors and Subcontractors.
All submittals will be logged in at the time of their receipt, by the Remedial Designer. A record of the submittal and review form indicating favorable review or rejection of the submittal will be kept on file by the Remedial Designer/Supervising Contractor, and a copy of the status record will be provided to the Project Coordinator. 3.3 Permit Equivalencies and Requirements All CERCLA response actions conducted on-Site are exempted by law from the requirement to obtain Federal, State or local permits; however, such response actions are still required to meet the substantive provisions of Applicable or Relevant and Appropriate Requirements. The associated “permit equivalency” process is similar to the standard permitting process except that administrative requirements are waived, such as permit fees, public notice requirements, and landowner signatures.
4 VOCs will be analyzed in the first post-injection performance monitoring event and in subsequent events/wells as necessary. 5 This determination and rationale will be presented for USEPA concurrence.
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As detailed in the approved FRDR, the following permits/permit equivalences will be required for the remedial activities: Drilling and well construction Injection of amendments into the subsurface NJDEP well permits will be obtained for the new monitoring and injection wells by the Drilling Contractor. NJDEP Form As and Form Bs will be completed by Drilling Contractor and the surveyor, respectively.
A NJDEP discharge to groundwater permit by rule equivalency will be required for injection of amendments (alkaline activated persulfate). The permit equivalency request will be submitted to the NJDEP by the Remedial Designer following approval of this RAWP, prior to initiating injection activities. 3.4 Access Agreements Access to the following properties will be required to install injection and monitoring wells, conduct injections, and to collect monitoring samples. OU-3 Southern Area RA Phase A property access: Block 124 Lot 2 OU-3 Southern Area RA Phase B property access: Block 124 Lots 2, 5, and 6 Access agreements are already in place for most of these lots; however, Block 124 Lot 6 was sold on January 19, 2021 and so an access agreement will be required with the new owner. 3.5 Clean and Green In 2009 USEPA Region 2 issued its Green Remediation Policy. The goal of the policy is to promote technologies and sustainable practices that enhance the environmental benefits of federal cleanup programs by minimizing the environmental footprint associated with remedy implementation (USEPA, 2009). In accordance with this policy, this design includes the following measures: Optimization of the injection and monitoring well footprint to optimally target the treatment area without over- sizing the system and minimizing the use of excess materials and equipment. Optimization of successive ISCO injections. Care will be taken to optimize injectant volumes and masses to efficiently utilize injectate materials for treatment of 1,4-dioxane. Minimization of Disturbances to Vegetation: To the extent practical, implementation of the remedy will avoid disturbing vegetated areas. Flexible Design: The design accommodates changes based on performance monitoring by ensuring monitoring wells have the future capability to become injection wells thereby minimizing the need to drill additional wells.
During the construction and monitoring phases, additional measures will be taken to minimize the environmental footprint of the remedy such as: Use of Clean Diesel in equipment Implementation of an idling policy for drilling rigs and vehicles
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Reduction of material consumption to the extent practicable while meeting remedial goals. Reduction of monitoring when appropriate 3.6 Decontamination The Contractor will be responsible for decontamination of drilling equipment as described in the Technical Specifications 02402 and 02675 in the approved FRDR. The drilling contractor will collect all IDW including drill cuttings and water generated during RA construction. Solid materials will be staged on the former SCP property in DOT approved drums or a roll-off. IDW liquids (drilling fluids and development water) will be placed in DOT approved 55-gallon drums or 300-gallon plastic totes and then transferred into the on-Site AST for off-Site disposal with OU-2 groundwater. Solid materials will be characterized and disposed off-Site at appropriate permitted facilities.
4.0 HEALTH AND SAFETY PLAN Contractors will be responsible for their workers H&S and for complying with the minimum requirements established under the Site HASP provided in the FRDR (Appendix D). Each contractor/subcontractor will be required to prepare an activity-specific Health and Safety Plan consistent with the Technical Specifications and the Site HASP including appropriate COVID-19 precautions. Contractors will be required to submit a traffic plan for review by the Remedial Designer prior to mobilization for off-property work, and the local authorities will be notified of the work.
The SHSC will have responsibilities as generally outlined in Section 2.5 for compliance with the HASP, will coordinate a daily tail-gate safety meeting and document health and safety related issues. The SHSC will be empowered to stop or redirect any Site work necessary based on identified H&S issues.
5.0 OPERATIONS, MAINTENANCE AND MONITORING PLAN No changes are necessary to the Draft OM&M Plan included as Appendix D to the approved FRDR at the present time.
6.0 QUALITY ASSURANCE / QUALITY CONTROL 6.1 Performance Standards The OU-3 Southern Area RA includes treatment of impacted groundwater through ISCO, MNA, and implementation of institutional controls to achieve final remedy performance standards.
ISCO treatment is most effective for localized, high concentration areas of contamination (e.g., the area around MW-21D) but is not efficient in addressing disperse low concentration areas. The objective of the ISCO injections in the design is to address the high concentrations of 1,4-dioxane with an aggressive initial treatment. Treatment will be evaluated on an on-going basis and a determination will be made in consultation with USEPA when the site-specific practical limits of ISCO treatment have been achieved and MNA will address residual 1,4-dioxane and lower concentration areas peripheral to the treatment zone. Long-term groundwater monitoring within and proximal to the treatment area will be used to assess progress towards the ROD performance goals and will inform any necessary adaptation of the treatment regime.
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6.2 Implementation of Construction Quality Assurance Plan The Remedial Designer will be responsible for overseeing and implementing the CQAP included as Appendix E in the approved FRDR (Golder 2020).
As described in the CQAP, the Remedial Designer is responsible for the following: Review of submittals for conformance with the design requirements Review of any proposed changes to the design and Technical Specification Provide modifications and clarifications to the Remedial Design Review corrective measures to be implemented when deviations from the remedial design occur Participate in the pre-construction, substantial completion, and regular progress meetings as necessary to review construction activities and conformance with the intent of the remedial design Review project schedule Maintain monitoring/injection well construction permit equivalency documents Document monitoring/injection well construction quantities Set up procedures, protocols, and documentation for ISCO injections Review quality assurance data Prepare daily CQA reports during construction Maintain a project file for storing CQA data and reports generated during construction Preparation of the Remedial Action Report at the completion of the project. 6.3 Implementation of Construction Quality Control During the Southern Area RA construction, Quality Control (QC) measures will be implemented by the Contractors, specialty subcontractors, and suppliers in accordance with the Southern Area FRDR, and Technical Specifications. Specific QC measures that must be adhered to for individual remedial construction activities, include: Documenting that the Contractor’s personnel that will be performing the work are qualified Documenting that the equipment and materials to be used during construction comply with specifications and applicable standards Documenting that the Specialty subcontractor personnel performing the liner cap repairs are qualified Documenting that the equipment and materials to be used in cap repair comply with the specifications and applicable standards Documenting that the ISCO injection materials meet the applicable standards Implementing procedures for scheduling and managing submittals in accordance with the Technical Specifications, including those of subcontractors and vendors
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6.4 Quality Assurance Project Plan Sampling and analysis activities will be conducted in accordance with the project-specific Quality Assurance Project Plan (QAPP), included as Appendix D of the approved FRDR (Golder 2020). The QAPP documents the QA/QC testing procedures, including methods for groundwater sample collection and the analyses to be performed.
7.0 COMMUNICATION AND REPORTING 7.1 Lines of Communication The Project Organization Chart included in Section 2 presents the formal lines of communication that will be followed during implementation of the OU-3 Southern Area Remedy. 7.2 Meetings A pre-construction meeting will be held prior to the beginning of Remedial Action construction. The meeting will be attended by the Remedial Designer, Contractor, and Agency representatives, as appropriate and may be held virtually.
The Remedial Designer will hold scheduled progress meetings on-Site at the beginning of each phase of construction, and as required during construction6. The progress meetings will typically be attended by Remedial Designer, relevant contractors, and the regulatory Agencies, as desired. Representatives may participate in the progress meetings through telephone conference calls, when unable to be present in person. The agenda for the progress meetings will be as follows: Review health and safety procedures/monitoring Review progress of construction and compare to schedule Coordinate work for the upcoming progress period Review implementation of the CQAP and identify areas or conditions requiring reconsideration Identify problem areas such as work deficiencies, work conflicts, or situations / conditions materially affecting work Review potential modifications to either the design, CQAP or construction methods that would improve the final work product
A substantial completion meeting will be held at the Site once the Remedial Designer and Contractor have agreed that Phase A and B activities are substantially completed. The meeting will be attended by the Remedial Designer, Contractors, and Agency representatives, during which a punch list of all outstanding tasks will be generated and transmitted to the attendees.
6 It is anticipated that meetings will occur weekly during the initial stages of construction
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7.3 Daily Records The Remedial Designer will keep records of construction progress, injection and monitoring activities in Daily Summary Reports. The Daily Summary Reports will be numbered sequentially and will include the following: Date and project name Weather conditions, including daily high and low temperature, wind conditions, and precipitation General description of work activities at the Site List of personnel and equipment operating on Site, number of hours worked, number of hours on standby, and work activities completed Description of work completed for the day, referencing stationing and grid coordinates as appropriate Identification of areas worked Test equipment calibrations, unless recorded in other field notebooks Summary of QA procedures used for the day and list of CQA personnel on Site Problems encountered and resolutions reached Health and Safety issues. 7.4 Construction Issues and Corrective Measure Reports A Construction Issue is defined herein as material or workmanship that apparently does not meet the requirements of the Remedial Design. Construction Issue and Corrective Measures Reports shall be numbered sequentially and include the following information: Detailed description of the issue Location and probable cause of the issue How and when the situation was identified Suggested measures to correct or resolve the issue How the problem was corrected or resolved Measures taken to prevent similar issues in the future Construction Issue and Corrective Measures Reports will be included as an appendix to the Remedial Action Report for the Southern Area. 7.5 Photographic Records The Remedial Designer will take photographs of the work in accordance with Section 01380 of the Technical Specifications. Photographic records will include the following information: The date, time, and location where the photograph was taken and weather conditions The size, scale, and orientation of the subject matter photographed
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Location and description of the work The purpose of the photograph Relevant photos will be included in the final Remedial Action Report for the Southern Area. 7.6 Final Record Documentation Report Following completion of each phase, a Remedial Action Progress Memorandum (RAPM) will be submitted to USEPA documenting the work completed and proposing the detailed scope of the next phase. The first RAPM will be submitted within 90 days after receiving analytical results from the first two monitoring events. A final Southern Area Remedial Action Report (RAR) will be submitted following completion of the final construction phase. Electronic Data Deliverables will be included with these reports.
The RAR will include the following certification as required by the CD:
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, t o the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. 7.7 Records Storage Throughout the construction, all original documents and copies will be kept in an organized file. All records and documents relating to the Remedial Action will be preserved and retained for a minimum of 10 years following receipt from USEPA of a Certification of Completion of the Work. As per the Consent Decree, at the conclusion of this record retention period, the Settling Defendants shall notify the United States at least 60 days prior to the destruction of any such records, documents, or information, and, upon req uest by the United States, the Settling Defendants shall deliver any such records, documents, or information to the USEPA.
8.0 SCHEDULE The anticipated Baseline Construction Schedule for Phase A of the Southern Area RA is presented in Figure 4. This schedule will be updated, in the RAPM to include Phase B activities.
9.0 REFERENCES Golder Associates Inc., 2016. Operable Unit 3 Pre-Design Investigation Report, April 2016. Golder Associates Inc., 2018. In Situ Chemical Oxidation Pilot Test, November 2018
Golder Associates Inc., 2019. Preliminary Remedial Design Report – Southern Area Groundwater, January 2019.
Golder Associates Inc., 2020. Enhanced Co-Metabolic Pilot Test Report, May 2020. Golder Associates Inc., 2020. Final Remedial Design Report Southern Area Groundwater: Operable Unit 3 (OU- 3), September 2020. USEPA, 2012. Record of Decision, United States Environmental Protection Agency, USEPA ID #NJD070565403, September 2012.
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Table 1 Well Construction, Baseline and Performance Monitoring Program 216 Paterson Plank NPL Site Carlstadt, NJ
Performance Monitoring Plan GROUND ELEVATION TOP WELL SCREEN Phase A Phase B DATE OF SURFACE WELL DIAMETER & WELL ID OF INNER CASING DEPTH LENGTH COMPLETION ELEVATION MATERIAL(S) 1st Post- Subsequent 1st Post- Subsequent (FT-MSL) (FT BGS) (FT) Semi-Annual Semi-Annual (FT-MSL) Baseline Injection Quarterly Baseline Injection Quarterly Monitoring Monitoring Sampling monitoring Monitoring Sampling monitoring Monitoring Events Events Event Events Event Events MONITORING WELLS MW-21D 9/18/1998 5.80 5.56 4-INCH SS 28.2 7.2 - - - B (3) B B MW-21R 12/22/2009 5.70 5.47 2-INCH PVC 84.5 10 - - B (3) B MW-22D 9/3/2002 6.77 6.41 4-INCH SS 42 10 - - - B (3) B B MW-33D 5/7/2015 11.30 14.23 2-INCH PVC 56 10 A (3) A - -
new monitoring wells along To be installed in Phase A ( 2-inch PVC) AAA - - - Paterson Plank Road (proximal B11-1 and B11-5) To be installed in Phase A ( 2-inch PVC) AAA - - - new monitoring well along Paterson Plank Road proximal To be installed in Phase A ( 2-inch PVC) A- - -BB B09-3 new monitoring well proximal To be installed in Phase A ( 2-inch PVC) A- - -B B B11-02 new monitoring well proximal To be installed in Phase A ( 2-inch PVC) AAA - - - PD-1 ISCO PILOT TEST WELLS IP16-2 11/1/2016 5.50 5.03 2-INCH PVC 45.00 10.00 - - - B B B MP16-1 11/2/2018 5.50 5.08 2-INCH PVC 45.00 10.00 - - - B B B MP16-2 11/2/2016 5.60 5.08 2-INCH PVC 46.00 10.00 - - - B B B MP16-3 10/31/2016 5.60 5.12 2-INCH PVC 56.00 10.00 - - - B B B MP19-2 11/2/2016 5.50 5.00 2-INCH PVC 45.00 10.00 - - - B B B INJECTION WELLS Phase A To be installed in Phase A ( 2-inch PVC) AAA - - - Phase B To be installed in Phase B ( 2-inch PVC) --- BBB MP19-1 11/2/2016 5.60 5.08 2-INCH PVC 46.00 10.00 - - - B B B
NOTES: (1) SS and PVC refer to stainless steel and PVC well casings and screens respectively. Overburden is isolated with steel casing. (2) Sampling will include analysis of VOCs (baseline event, and subsequent events as needed), 1,4-dioxane, dissolved metals (including hexavalent chromium), and select conventional parameters (Total Organic Carbon (TOC), Alkalinity as CaCO3, and sulfate. (3) A indicates baseline and monitoring initiated in Phase A B indicates baseline and monitoring initiated in Phase B MW-21D, MW-21R, MW-22D and MW-33D are monitored annually for 1,4-dioxane Updated by: HAL (4) The Performance Monitoring Program will be reviewed and updated, if necessary, with USEPA concurrence following each monitoring event. Reviewed by: RJI
https://golderassociates.sharepoint.com/sites/124709/Project Files/6 Deliverables/SA RAWP/Draft/Table 1 Preliminary Monitoring Program 12/7/2020 Page 1 of 1
PROPERTY BOUNDARY 9436222ZZF01.dwg | File Name: 11:16:57 AM Time:
2020-12-14 LEGEND SUBJECT PROPERTY BOUNDARY (APPROXIMATE) Date:
GSantell REFERENCE(S) 1. BASE MAP TAKEN FROM 7.5 MINUTE U.S.G.S. QUADRANGLE OF WEEHAWKEN, NEW 0 1000 2000 JERSEY, DATED 2016.
| Printed By: FEET
CLIENT PROJECT 5:27:48 PM 216 PATERSON PLANK ROAD PRP GROUP SOUTHERN AREA REMEDIAL ACTION WORK PLAN IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET SIZE HAS BEEN MODIFIED FROM: ANSI A Time: 216 PATERSON PLANK ROAD NPL SITE 1 in CARLSTADT, NEW JERSEY
2020-11-18 CONSULTANT YYYY-MM-DD 2020-12-14 TITLE SITE LOCATION MAP Date: DESIGNED HAL
rgrams PREPARED RG
REVIEWED HAL PROJECT NO. CONTROL REV. FIGURE \\golder.gds\ComplexData\office\MtLaurel\Cadd\Projects\1994\943-6222 Carlstadt\ZZF - Southern Area Remedial Action Report\Active\
NJ Authorization #24GA28029100 APPROVED PSF 20141009 ZZF01 0 Last Edited By: Path: 1 0 B-15 LEGEND PROPERTY LINE BLOCK 124 LOT 1 APPROXIMATE SLURRY WALL ALIGNMENT TARGET TREATMENT AREA
B-10
MW-14D APPROXIMATE SOLAR PANEL ARRAY MW-14D BLOCK 124
CD-1 CD-1 MW-14R LOT 49 CARRIER PIPE EW-02 MW-14R EXTRACTION WELL EW-06
BLOCK 124 B-16 LOT 3 PROPOSED INJECTION WELL PHASE A PROPOSED INJECTION WELL PHASE B (SEE NOTE 2)
PROPOSED MONITORING WELL (TO BE INSTALLED DURING PHASE A)
MW-8D PATERSON PLANK ROAD PLANK PATERSON BLOCK 124 TILL MONITORING WELL LOT 2 BLOCK 124 MW-20R BEDROCK MONITORING WELL LOT 4 SLURRY WALL CONSTRUCTION INVESTIGATION BORING BLOCK 124 B-6 (INSTALLED DURING OU-1 REMEDIAL DESIGN, 1992)
PD-1 PD-1 LOT 48 B09-2 PROFILE BORING
B-17 ISCO PILOT TEST MONITORING WELL
BH-9 ISCO PILOT TEST INJECTION WELL
LOT AND BLOCK
B11-5 B11-5 PD-2 PD-2 11:15:00 AM EW-01 Time:
NOTE(S) EW-07 1. ALL LOCATIONS ARE APPROXIMATE. 2020-12-14 2. MONITORING WELL MP19-1, INSTALLED AS PART OF THE ECMB PILOT TEST, WILL BE USED BLOCK 124 AS AN INJECTION WELL. Date: LOT 5
B11-1 B11-1 GSantell
B-18 REFERENCE(S) B-8 B-8 CD-6/MW-33D 1. PROPERTY BOUNDARIES SHOWN TAKEN FROM DIGITAL FILE 3074-02-TOPO.DWG, | Printed By: CD-6 / MW-33D ENTITLED "BOROUGH OF CARLSTADT BLOCK 124 LOTS 1 THROUGH 5," DATED DECEMBER 8, 2005, PREPARED BY PROMAPS. 2. HORIZONTAL DATUM REFERENCES THE NEW JERSEY STATE PLANE COORDINATE SYSTEM, NORTH AMERICAN DATUM OF 1983 (NAD 83). VERTICAL DATUM REFERENCES 11:13:42 AM THE NORTH AMERICAN VERTICAL DATUM OF 1988 (NAVD 88). 3. FENCE AND MAINTENANCE BUILDING LOCATIONS/LIMITS TAKEN FROM DIGITAL CAD FILE Time: BLOCK 124 RBSU008761.DWG, FIGURE 7 OF 7, ENTITLED "AS-BUILT FINAL SITE CONDITION SURVEY," LOT 50 BLOCK 107.01 B09-3 B09-3 EW-10 PREPARED BY MASER CONSULTING P.A., DATED MARCH 17, 2009. 4. MONITORING WELLS SURVEYED BY: GEOD CORPORATION (1996, 1998), JAMES M.
2020-12-14 LOT 1 B-7 B-7 STEWART, INC. (2002), VARGO ASSOCIATES (2009-2010) AND MPF LAND SURVEYING, LLC EW-09 (2015, 2017, 2018, 2019). Date:
PD-3 PD-3 B-1 5. PROFILE BORINGS B09-1 THROUGH B09-5 AND MONITORING WELL MW-21R FROM DIGITAL EW-08 B-2 CAD FILE VARGO SURVEY OF 216 PATERSON PLANK ROAD.DWG, DATED JANUARY 25, rgrams 2010, PREPARED BY VARGO ASSOCIATES. SOIL BORINGS CD-1, PD-1, PD-2 AND PD-3 WERE
B-3 SURVEYED BY MPF LAND SURVEYING, LLC.
B11-2 B11-2 B-4 6. APPROXIMATE SOLAR PANEL ARRAY TAKEN FROM DIGITAL PDF FILE 2020-01-24 Electrical
B-6 Record Condition Drawings.pdf, PREPARED BY KDC SOLAR/KUPPER ENGINEERING, INC., B-6 B-5 PEACH ISLAND CREEK DATED JANUARY 24, 2020.
| Last Edited By: 7. EXTRACTION WELLS AND CARRIER PIPE LOCATIONS TAKEN FROM DIGITAL CAD FILE MW-28R RBSU007938.DWG, ENTITLED "AS-BUILT GROUNDWATER RECOVERY SYSTEM AND
MW-21R MW-28R PIEZOMETER SURVEY," PREPARED BY MASER CONSULTING P.A., DATED AUGUST 16, 2011.
B09-2 8. LOT AND BLOCK PARCEL BOUNDARIES SHAPEFILE FROM NEW JERSEY GEOGRAPHIC
MW-21D B09-2
RMW-8D
MW-8S MW-21D MW-21R RWM-8D INFORMATION NETWORK WEBSITE (HTTP://NJGIN.STATE.NJ.US.). MP16-3 MP16-3
IP-16-2
9436222ZZF02.dwg IP16-2
MP16-1 MP16-1
MP16-2
MW-9S MP16-2
B11-3
| File Name: MP19-1 B11-3 MW-22D MW-22D ISCO PILOT TEST AREA B09-1 MP19-2 B09-1 0 40 80
1'' = 40' FEET
CLIENT BLOCK 124 216 PATERSON PLANK ROAD PRP GROUP
B11-4 B11-4 LOT 6
PROJECT SOUTHERN AREA REMEDIAL ACTION WORK PLAN 216 PATERSON PLANK ROAD NPL SITE CARLSTADT, NEW JERSEY TITLE WELL INSTALLATION PHASES
CONSULTANT YYYY-MM-DD 2020-12-14
DESIGNED HAL
PREPARED RG IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET SIZE HAS BEEN MODIFIED FROM: ANSI D
MW-17D
MW-18D
MW-8R MW-17D MW-8R REVIEWED HAL 1 in MW-18D NJ Authorization #24GA28029100 APPROVED PSF PROJECT NO. CONTROL REV. FIGURE \\golder.gds\ComplexData\office\MtLaurel\Cadd\Projects\1994\943-6222 Carlstadt\ZZF - Southern Area Remedial Action Report\Active\ 20141009 ZZF02 0
Path: 3 0 Figure 4 Southern Area Remedial Schedule 216 Paterson Plank Road NPL Site Carlstadt, NJ ID Task Name Duration Start Finish Half 2, 2020 Half 1, 2021 Half 2, 2021 Half 1 S O N D J F M A M J J A S O N D J F M 1 Groundwater MNA Monitoring 1330 days Mon 11/14/16 Fri 12/17/21
85 SOUTHERN AREA FINAL RD 23 days Wed 8/19/20 Fri 9/18/20
87 Submit Southern Area FINAL RD 0 days Fri 9/11/20 Fri 9/11/20 9/11
88 USEPA Approval 4 days Tue 9/15/20 Fri 9/18/20
90 SOUTHERN AREA RAWP 135 days Mon 9/21/20 Fri 3/26/21
91 Prepare Southern Area RAWP 50 days Mon 9/21/20 Fri 11/27/20
92 Submit to USEPA 0 days Mon 12/14/20 Mon 12/14/20 12/14
93 USEPA Review 20 days Tue 12/15/20 Mon 1/11/21
94 Revise and Resubmit to USEPA 39 days Tue 1/12/21 Fri 3/5/21
95 USEPA Review and Approval 15 days Mon 3/8/21 Fri 3/26/21
96 Phase A Construction 250 days Mon 3/29/21 Fri 3/11/22
97 Contractor Selection and Permit Equivalency 15 days Mon 3/29/21 Fri 4/16/21
98 Phase A wells installed 32 days Mon 5/31/21 Tue 7/13/21
99 Baseline Sampling (Phase A) 3 days Wed 7/28/21 Fri 7/30/21
100 Injection #1 (4 Phase A injection wells) 7 days Mon 9/6/21 Tue 9/14/21
101 Post-Injection Monitoring 3 days Mon 10/11/21 Wed 10/13/21
102 2nd Post-Injection monitoring of Injection #1 (1Q 6 days Thu 12/16/21 Thu 12/23/21 following)
103 Prepare Southern Area Remedial Action Progress 40 days Fri 1/14/22 Thu 3/10/22 Memorandum (including schedule for Phase B)
104 Submit to USEPA 1 day Fri 3/11/22 Fri 3/11/22
Task Project Summary Inactive Milestone Manual Summary Rollup Progress Project:SCP Schedule Split External Tasks Inactive Summary Manual Summary Deadline Date: Fri 3/5/21 Milestone External Milestone Manual Task Start-only Summary Inactive Task Duration-only Finish-only
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