Environmental Protectioni^gency

Environmental _Protectioni gency

Revision No. 1Page: 1 of 1Date: 3/24/89

SALTVILLE RI/FS FINAL WORK PLANWORK ASSIGNMENT NO. 90-09-3L24CONTRACT NO. 68-W8-0090MARCH 1989

Prepared forU.S. Environmental Protection Agency

Region III841 Chestnut Street

Philadelphia, Pennsylvania 19107

Prepared byCH2M HILL

Reston, Virginia

RR300Q02WDR391/064

£rig/neersPlanners

KBMSUH Economists

March 27,1989

WDC63107.PP.WP

Ms. Lesley BrunkerU.S. Environmental Protection AgencySixth Floor841 Chestnut StreetPhiladelphia, PA 19107

Subject: CH2M HILL's Final RI/FS Oversight for Saltville

Dear Lesley:

Enclosed are copies of CH2M HILL's Final RI/FS Oversight Work Plan for Saltville. Twocopies are also enclosed for Stephanie Del Re and one for Jim Clark.

CH2M HILL's draft work plan was revised to incorporate information obtained during ourwork plan meeting on February 27,1989 and from the PRP's revised RI/FS work plan.

Based on the assumption that the environmental assessment will be conducted as a separateoperable unit, this work plan assumes that a feasibility study for the soils and groundwater canbe completed by May 1991. This work plan includes activities through June, 1991, includingthose related to the environmental assessment.

Should you have any questions with regards to the work plan, please call.

Sincerely,

SadiaKissoon

SK/kcEnclosures: a/scc: Stephanie Del Re/EPA

Jim Clark/EPABob Dagostaro/CH2M HELLSkip Ellis/CH2M HILL

AR30QOQ3CH2M HILL Mid-Atlantic Office P.O. Box 4400, Reston, Virginia 22090 703.471.1441


CONTENTS

Section

1 IntroductionBackgroundProject ObjectivesAssumptions

2 Scope of WorkTask 1: Project Planning (PP)

Subtask PP.WP: RI/FS Oversight WorkPlan 2-2

Subtask PP.QS: Sampling and AnalysisPlan 2-3

Subtask PP.PM: Project Management 2-5Subtask PP.QC: Quality Control 2-5Subtask PP.MG: Meeting Attendance 2-5

Task 2: Enforcement Support (ES) 2-6Subtask ES.WP: Review PRP's Draft and

Final Work Plan 2-6Subtask ES.QS: Review PRP's Draft SAP 2-7Subtask ES.PM: Project Management 2-9

Task 3: Field Investigation (FI) 2-9Subtask FI.FO: Prepare Analytical

Service Requests andand Procurement ofAnalytical Laboratory 2-11

Subtask FI.SM: Sample and DataManagement 2-11

Subtask FI.FB:" Field Oversight ofBioassessment Program 2-12

Subtask FI.FI: Field Oversight of WellInstallation 2-16

Subtask FI.FQ: Field Oversight ofGroundwater Sampling 2-16

Subtask FI.FS: Field Oversight of SoilSampling 2-17

Subtask FI.FW: Field Oversight ofSurface Water andSediment Sampling 2-17

Subtask FI.DE: Data Evaluation 2-18Subtask FI.QC: Quality Control 2-19

Task 4: Assessment of Risks (AR) 2-19Subtask AR.RO: Technical Support for

Risk Assessment Review 2-19Subtask AR.Bl: Review PRP's Draft

Biological ToxicityReport 2-19

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CONTENTS

Section

Subtask AR.B2: Review PRP's DraftBiological AssessmentReport 2-20

Subtask AR.QC: Quality Control 2-21Task 5: Remedial Investigation (RI) 2-21

Subtask RI.R2: Review PRP's FinalGroundwater SamplingReport 2-21

Subtask RI.R3: Review PRP's DraftRemedial InvestigationReport 2-21

Subtask RI.QC: Quality Control 2-24Task 6: Feasibility Study (FS) 2-24

Subtask FS.R6: Review PRP's DraftFeasibility Study Report 2-25

Subtask FS.QC: Quality Control 2-25Task 7: Project Closeout (PC) 2-25

Project Schedule 3-1

Project Costs 4-1

Project Management Plan 5-1Project Organization 5-1Schedule Control 5-4Cost Control 5-4Coordination with EPA and the PRP 5-5Quality Control 5-5

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WDR391/065/2


TABLES

Page

1-1 Schedule for CH2M HILL's RI/FS OversightWork Plan 1-2

2-1 Assumed Quantities of Samples to beCollected by the PRP and by CH2M HILL 2-13

3-1 Summary of CH2M HILL's Other Planningand Reporting Deliverables to EPA 3-5

3-2 Summary of PRP's and CH2M HILL's 'Review Deliverables to EPA 3-6

4-1 Budget Summary 4-2, 4-3

5-1 Project Meeting Summary 5-6

FIGURES

Page

1-1 Area Map—Saltville Waste Disposal Site 1-4

3-1 Saltville RI/FS Oversight Schedule 3-2

5-1 CH2M HILL Project Organization 5-2

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WDR391/065/3

I Revision No. 1Section: 1Page: 1 of 7Date: 3/24/89

Section 1INTRODUCTION

CH2M HILL has received Work Assignment (WA) No. 90-09-3L24to oversee the remedial investigation/feasibility study(RI/FS) conducted by the potentially responsible party (PRP)at the Saltville Superfund site in Saltville, Virginia.Olin Corporation is the PRP for this site. The tasksdescribed in this work plan will be completed underCH2M HILL's ARCS III contract. No. 68-W8-0090, with EPARegion III. The schedule for reviewing and revising thiswork plan is shown in Table 1-1.

Concurrent with this effort, CH2M HILL has also receivedWA No. 90-09-3N24 to oversee the PRP's remedial design (RD)and remedial action (RA) at Saltville. The RI/FS and RD/RAwork assignments are separate and distinct. However, coor-dinated management of these two work assignments will becritical to maintain technical continuity between the twoassignments. This coordination will be a primary consider-ation throughout both work assignments.

WA No. 90-09-3L24 requires CH2M HILL to oversee the PRP's RIactivities and to review the RI and FS reports. Therefore,CH2M HILL's schedule is dependent on the scope and scheduleproposed by the PRP.

The RI/FS will be conducted by the PRP, as specified in theConsent Decree signed on September 30, 1988. The ConsentDecree includes the following technical components of theRI/FS, as detailed in the Record of Decision (ROD) of June1987:

o Define the hydrogeology of the area

o Define the extent of the area acting as the sourceof contamination to quantify the amount of mercurythat can leach into the groundwater and hence intothe North Fork Holston River (NFHR)

o Sample potentially contaminated areas at the site

o Perform a bioassessment of the NFHR

o Perform a risk assessment using historic and newRI data

o Conduct an FS to determine remedial alternativesfor final cleanup

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Revision No. 1Section: 1Page: 2 of 1Date: 3/24/89

Table 1-1SCHEDULE FOR CH2M HILL'S RI/FS OVERSIGHT WORK PLAN

AnticipatedEvent______________________ ____Time

CH2M HILL receives the PRP's Work Plan November 21, 1988

CH2M HILL submits comments to EPA on the PRP's Work Plan December 9, 1988

EPA sends Letter of Deficiency for the Work Plan to the PRP January 17, 1989

CH2M HILL submits draft RI/FS Oversight Work Plan to EPA February 1, 1989

The PRP submits a revised Work Plan to EPA (Consent Decree allows February 10, 198924 days for this effort)

CH2M HILL receives the PRP's revised Work Plan February 27, 1989

EPA provides comments to CH2M HILL's draft Oversight Work Plan February 27, 1989

CH2M HILL submits comments to EPA on the PRP's revised Work Plan March 10, 1989

CH2M HILL submits final RI/FS Oversight Work Plan to EPA March 30, 1989

The PRP submits Sampling and Analysis Plan (SAP) to EPA March 30, 1989

CH2M HILL receives the PRP's SAP EPA approves April 5, 1989

CH2M HILL's Oversight Work Plan April 28, 1989

CH2M HILL submits comments to EPA on the PRP's SAP May 3, 1989

EPA sends Letter of Deficiency on the SAP to the PRP May 17, 1989

The PRP submits revised SAP May 26, 1989

CH2M HILL receives the PRP's revised SAP June 2, 1989

CH2M HILL submits comments on revised SAP June 23, 1989

CH2M HILL submits revised Work Plan after review of the PRP's SAP June 30, 1989

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The objectives of the RI/FS, as described in the ROD, are asfollows:

o Implement a groundwater studyo Implement a bioassessment of the NFHRo Conduct additional sampling along the NFHRo Conduct a risk assessment to evaluate potential

health hazards

Section 2 describes CH2M HILL's scope of work for performingthe RI/FS oversight. The project schedule is included inSection 3, and a detailed cost estimate is included in Sec-tion 4. Section 5 describes the project management plan.The schedule for this project has been defined in the PRP'sRI/FS work plan. Because CH2M HILL is not implementing theRI/FS, the actual schedule for the project will be a func-tion of the PRP's progress and will be beyond CH2M HILL'scontrol.

BACKGROUND

The Saltville Waste Disposal Site, shown in Figure 1-1, islocated along the NFHR; the former plant site is situatedbetween the town of Saltville and the community of AllisonGap in western Smyth County, Virginia; the waste ponds extendsouthwest of the plant site and into Washington County,Virginia.

From 1951 to 1972, the PRP operated an electrolyte chlorineand caustic soda plant at the Saltville site. One of theelectrodes used in the chlorine-caustic process containedmercury, which was released into the process wastes and ontothe plant grounds. Waste Pond No. 5 was used to dispose ofthe waste sludges from the chlor-alkali processes. In 1963,Waste Pond No. 6 was constructed to receive overflow fromWaste Pond No. 5. According to the PRP, no wastes containingmercury were dumped into Waste Pond No. 6, but structuralcomponents of the old chlor-alkali plant reportedly wereburied at the eastern edge of the pond.

The Superfund site includes the former chlor-alkali plantand the two waste ponds described above; contamination hasreportedly migrated into the NFHR, which flows adjacent tothe southern border of the site and southwest, intoTennessee.

A task force of representatives from EPA Region III, theVirginia State Water Control Board (VASWCB), the TennesseeValley Authority, and the Tennessee Department of Public

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Revision No. 1Section: 1 -Page: 5 of 7Date: 3/24/89

Health was organized in 1970 to study the mercury con-j tamination. The task force, also served as a board of

advisors to the VASWCB.

The site was proposed for the National Priorities List in1982. In September 1982, the PRP and the VASWCB signed aSpecial Order, wherein the PRP agreed to perform remedialactions to remove mercury from the river. The actions,which were completed by 1983, were to dredge 1,000 feet ofthe river, spread the dredged sediments onsite, and cap the

I area. The PRP also constructed a diversion ditch, surround-j ing the western portion of Waste Pond No. 5. The Special

Order also required monitoring of the outfall and fish andI sediments in the NFHR until 1988.

1 Region III completed a preliminary risk assessment in Sep-tember 1986 using the data collected under the VASWCB SpecialOrder. Additional remedial investigations were not per-

! formed. Based on the results of the preliminary risk assess-ment, an interim ROD was signed in June 1987.

i' PROJECT OBJECTIVES

The primary objectives of this work plan are to define activ-ities necessary to conduct an RI/FS oversight at Saltvilleand to obtain funding from EPA Region III to conduct those

I activities. Oversight objectives are to (1) review the PRP'sj deliverables during the course of the RI/FS; (2) provide

oversight of field activities; and (3) provide EPA Region IIIwith technical memorandums and evaluation reports detailing

! CH2M HILL's review comments.

REVIEW OF THE PRP'S DELIVERABLESi' The objectives of reviewing the PRP's deliverables are to

determine for EPA Region III if the PRP's deliverablesi achieve the following:ti

o Satisfy the intent of the ROD and the ConsentDecree

o Comply with the National Contingency Plan

, o Follow the Guidance for Conducting RemedialInvestigations and Feasibility Studies UnderCERCLA (October 1988)

} o Provide the RI activities required to identifypotential sources of contamination and provide


information to characterize the nature and extentof contamination

o Follow EPA's Superfund Exposure Assessment Manualto perform an environmental assessment of the NFHR

o Provide the FS activities needed to select andevaluate alternatives for the final remedialaction

o Follow EPA guidance on quality assurance, including,as appropriate, the Users Guide to the ContractLaboratory Program; Guidelines Establishing TestProcedures for the Analysis of Pollutants UnderCWA (49-FR-209) (October 26, 1984, SW-846); EPANEIC Policies and Procedures Manual (EPA DocumentNo. 330/9-78-001-R); and Interim Guidelines andSpecifications for Preparing Quality AssuranceProject Plans (OAMS-005-80)

OVERSIGHT OF FIELD ACTIVITIES

The objectives of monitoring the PRP's field activities areto:

o Determine if the work being performed is in accord-ance with the PRP's work plan and sampling andanalysis plan (SAP)

o Assess the quality of information being collectedby the PRP through the collection and analysis ofsplit samples

CH2M HILL DELIVERABLES

Deliverables to EPA Region III will consist of technicalmemorandums detailing CH2M HILL's review comments of thePRP's deliverables that are selected by EPA for review byCH2M HILL. Two independent technical memorandums will besubmitted for review of PRP deliverables when both the draftand final documents are reviewed.

ASSUMPTIONS

This work plan is based on many assumptions about the PRP'sperformance at Saltville. Assumptions include the numberand the type of samples collected by the PRP, the samplesplit frequency, and the duration and the number of samplingepisodes. The specific assumptions are listed under each

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subtask description in Section 2. These assumptions mayprove to be invalid as the PRP's activities progress. Hence,this work plan is intended to be a flexible document and mayrequire revision during the project. It is anticipated thata work plan revision will be necessary after the PRP's SAPis received. The budget for the revision is included in thecosts. Other potentially required revisions, such as revi-sions to facilitate oversight of the FS, are not budgeted.The anticipated schedule for CH2M HILL's work plan revisionis shown on Table 1-1, previously referenced.

The actual level of effort required for review of the PRP'sdeliverables will depend on the quality and length of eachdeliverable. It is assumed that there will be one review ofdeliverables (draft) except for the PRP's work plan whereboth the draft and final will be reviewed. Proposed CH2M HILLreview teams have been identified for each deliverable antic-ipated. The type of review required for each deliverablewas discussed with the remedial project manager (RPM) and isincorporated into this final work plan. This coordinationbetween EPA and CH2M HILL will provide the individual reviewteam's experience and expertise quality review necessary forthis project. Assumptions regarding review of specific PRPdeliverables are stated within each subtask description inSection 2.

WDR391/001

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Section 2SCOPE OF WORK

This section presents the technical support and field over-sight activities to be performed in support of EPA Region IIIduring the PRP's implementation of the RI/FS at the Saltvillesite in Saltville, Virginia.

The scope of work is divided into standard tasks and subtasks,as defined in CH2M HILL's Superfund Project Control System(SPCS). The tasks and subtasks for CH2M HILL's oversightactivities are listed below:

o Task 1: Project Planning (PP)Subtask PP.WP: RI/FS Oversight Work PlanSubtask PP.QS: Sampling and AnalysisPlanSubtask PP.PM: Project ManagementSubtask PP.QC: Quality Control

- Subtask PP.MG: Meeting Attendance

o Task 2: Enforcement Support (ES)Subtask ES.WP: Review PRP's Draft and FinalWork PlanSubtask ES.QS: Review PRP's Draft SAPSubtask ES.PM: Project Management

o Task 3: Field Investigation (FI)Subtask FI.FO: Prepare Analytical ServiceRequests and Procurement of AnalyticalLaboratory

- Subtask FI.SM: Sample and Data ManagementSubtask FI.FB: Field Oversight ofBioassessment ProgramSubtask FI.FI: Field Oversight of WellInstallationSubtask FI.FQ: Field Oversight ofGroundwater Sampling

- Subtask FI.FS: Field Oversight of SoilSamplingSubtask FI.FW: Field Oversight of SurfaceWater and Sediment SamplingSubtask FI.DE: Data EvaluationSubtask FI.QC: Quality Control

o Task 4: Assessment of Risks (AR)Subtask AR.RO: Technical Support for RiskAssessment Review

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Subtask AR.B1: Review PRP's Draft BiologicalToxicity ReportSubtask AR.B2: Review PRP's Draft BiologicalAssessment ReportSubtask AR.QC: Quality Control

o Task 5: Remedial Investigation (RI)Subtask RI.R2: Review PRP's FinalGroundwater Sampling ReportSubtask RI.R3: Review PRP's Draft RemedialInvestigation Report

- Subtask RI.QC: Quality Control

o Task 6: Feasibility Study (FS)Subtask FS.R6: Review PRP's DraftFeasibility Study ReportSubtask FS.QC: Quality Control

The expected level of effort for each task is discussed inthe remainder of this section. The meetings anticipated foreach task are summarized in Table 5-1, discussed underSection 5.

TASK 1; PROJECT PLANNING (PP)

This task includes planning activities required for implemen-tation of CH2M HILL's RI/FS oversight activities.

SUBTASK PP.WP; RI/FS OVERSIGHT WORK PLAN

This subtask is for the preparation and submittal of thiswork plan, which describes CH2M HILL's scope of work underthe current work assignment and includes a detailed descrip-tion of the objectives, tasks, and level of effort necessaryfor the technical support and field oversight activities.

As part of developing the work plan, a review of backgroundinformation—risk assessment, FS, ROD, Consent Decree, andother information obtained from EPA Region Ill's files—willbe conducted in order to obtain a basic understanding of thesite and to aid in the oversight work plan development. Aninitial site visit is also budgeted in this subtask. A tripreport documenting the site visit will be submitted to EPARegion III following the site visit.

Basis of Estimate

The budget for this subtask assumes submittal to EPA of onedraft and one final work plan and one future revision after

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receipt of the PRP's sampling and analysis plan (SAP). Thenumber of samples to be collected per media will be detailedin the PRP's SAP. CH2M HILL can then utilized this informa-tion to finalize the field oversight costs which, for thepurposes of budgeting, are based on assumptions reported inSection 2.

SUBTASK PP.QS; SAMPLING AND ANALYSIS PLAN

CH2M HILL will be collecting split samples for chemicalanalysis during field oversight activities. The purpose ofcollecting and analyzing split samples is to compare analyt-ical results. For the evaluation of the split results to bemeaningful, both CH2M HILL and the PRP will have to use simi-lar methods for sample collection and analysis. CH2M HILLwill be reviewing the PRP's SAP and will comment on the col-lection and analysis methods proposed by the PRP. For pur-poses of this work plan, it will be assumed that the PRP'sfinal SAP will reflect collection and analytical methodswhich CH2M HILL will also use for their split samples.Therefore, CH2M HILL's SAP will reference methodologiesalready existing in the PRP's SAP.

CH2M HILL's SAP will include the quality assurance projectplan (QAPjP), the field sampling plan (FSP), and the Healthand Safety Plan (HSP). The QAPjP will include the followinginformation:

o Objectives and goals of samp'le collection andanalysis

o Data quality objectives

o Quality control requirements

o Sample custody

Samples which can be analyzed by laboratories in theContract Laboratory Program (CLP) will be sent to thoselaboratories for analysis. To date, no known CLP labora-tories have experience in the analysis of methyl-mercury infish tissue. It is anticipated that an intergency agreementbetween EPA Region III and another government agency may berequired for the methyl-mercury analysis. This work plandoes not include costs for development of interagency agree-ment documents, audits of laboratories, or QC oversight oflaboratory performance.

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The following elements of the FSP which are presented in theGuidance for Conducting Remedial Investigations and Feasibil-ity Studies Under CERCLA (October 1988) will be included:

o Site backgroundo Sampling objectiveso Sample location and frequencyo Sample designationo Sampling equipment and procedureso Sample handling and analysis

The procedures outlined in the Compendium of Superfund FieldOperations Methods (1987) and the Users Guide to theContract Laboratory Program (July 1984) will be used todevelop the FSP. The FSP will reference the PRP's FSP forprocedures.

Sample custody procedures, including those related to chainof custody, will be delineated in the FSP and will conformwith the procedures detailed in the National EnforcementInvestigation Center's Policies and Procedures for SampleControl (1978) .

A site-specific HSP will be developed by CH2M HILL for useby CH2M HILL's employees during each field oversight andsample collection activity associated with the RI fieldwork.Each HSP will include health and safety assessments to iden-tify areas where exposure to hazardous substances in thewater, air, or soil may exist. The assessment will alsoaddress safe working procedures, restrictions that will applyto the site work, potential human exposure to hazardous sub-stances, and the toxicological effects of those substances.The HSPs will be updated, as needed, to reflect changes inthe hazards, changes in work activities, or changes in oper-ating conditions encountered at the site.

The PRP will prepare an HSP for field activities associatedwith its implementation of the RI/FS. EPA Region III willprovide CH2M HILL with a copy of the PRP's HSP. CH2M HILLwill review this plan for information purposes only so thatpotentially conflicting directions in the HSPs can be mini-mized. CH2M HILL will not be responsible for the health andsafety of the PRP's personnel or the personnel of entitiescontracted to the PRP.

Assumptions

The budget for this subtask assumes submittal to EPA of onedraft and one final SAP. It is also assumes that CH2M HILLwill be referencing the PRP's SAP for methodologies and

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procedures with regards to sample collection and analysisand that the PRP's SAP is sufficiently detailed to act as areference source.

It is assumed that there will be eight revisions to the HSPprepared for the well installation oversight based on theother eight field activities currently scheduled.

SUBTASK PP.PM; PROJECT MANAGEMENT

There are charges to date on this subtask. However, thesecharges will be transferred to Subtask ES.PM and this subtaskwill be eliminated.

SUBTASK PP.QC; QUALITY CONTROL

The QC aspects of the project will be managed according toprocedures defined in Section 8 of the ARCS Draft ManagementPlan (CH2M HILL, February 1989). Project activities anddeliverables will be independently reviewed by a QC reviewteam.

The review team leader (RTL) will review overall implementa-tion of the project, including planning, technical conceptmeetings, and selection of subcontractors, and will providegeneral guidance on project activities.

Assumptions

It is assumed that the RTL will have conferences, via tele-phone, with review team members during execution of the indi-vidual tasks, hence no travel costs are budgeted for theRTL.

SUBTASK PP.MG; MEETING ATTENDANCE

Throughout the course of the RI/FS, CH2M HILL project per-sonnel will hold periodic meetings with EPA Region III. Atcritical junctures of the project, it will also be necessaryto conduct meetings between EPA Region III, CH2M HILL, thePRP, and other parties, as appropriate, to discuss projectdeliverables and the schedule and to evaluate the need forand scope of additional studies.

Assumptions

In general, meetings will be charged to the appropriate sub-task based on the meeting agenda. This subtask includes oneproject kickoff meeting, five semi-annual progress meetingswith Region III, and one public meeting after the FS report

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is issued. The semi-annual progress meetings will be con-ducted jointly with planned technical meetings when possible.(See Table 5-1 in Section 5.)

TASK 2; ENFORCEMENT SUPPORT (ES)

This task includes a review of the PRP's work plan and SAP,and the submission of technical memorandums detailingCH2M HILL's review comments.

SUBTASK ES.WP; REVIEW PRP'S DRAFT AND FINAL WORK PLAN

CH2M HILL have completed reviews of the PRP's draft andfinal work plan to determine if it outlines the remedialinvestigation activities necessary to identify possiblesources of contamination and if it characterizes the natureand extent of contamination.

The PRP's draft work plan was reviewed to ascertain if thefollowing information was addressed:

o Planning—The PRP's draft work plan was reviewedto determine if the following general planningitems were addressed:

- Collection and evaluation of existing data

Development of a conceptual site model thatcan be used to assess the nature and extentof contamination and to identify potentialexposure pathways and receptors

Identification of data needs and data qualityobjectives

Preliminary identification of ARARs

- Quality control

o Remedial investigation—The PRP's draft work planwas reviewed to determine if the October 1988Guidance for Conducting Remedial Investigations

. and Feasibility Studies Under CERCLA is being usedfor the RI planning. RI activities generallyinclude:

Identification of general site features

- Geophysical testing to assist in hydrogeolog-ical characterization

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Collection of samples from the groundwater,soil (surface and subsurface) , and NFHR sedi-ment to aid in defining the amount and extentof contamination

o Risk assessment — The PRP's draft work plan wasreviewed to determine whether appropriate tech-niques are proposed for evaluating chemicals ofconcern, population at risk, exposure pathways,effects of exposure to contaminants, and potentialand human health risks .

o Environmental assessment — The PRP's draft workplan was reviewed to determine whether appropriatetechniques are proposed for quantifying the effectsof mercury discharges to the NFHR. It is expectedthat the PRP's work plan will include an experimen-tal design to separate the effects of the mercurydischarges from the effects of all other potentialperturbations of biological composition (climato-logical fluctuations, inter species competition,etc.) .

o Feasibility study — The PRP's draft work plan wasreviewed to determine if an FS will be conductedthat complies with the October 1988 Guidance forConducting Remedial Investigations and FeasibilityStudies Under CERCLA.

The PRP's final work plan was reviewed to determine if thecomments made in EPA's letter of deficiency were addressedand if they were, were the responses technically adequate.No risk assessment review was done on the PRP's final workplan. At the end of each review, a technical memorandumdetailing CH2M HILL's review comments was submitted to EPARegion III. The review comments on the PRP's draft workplan was discussed at a review meeting.

SUBTASK ES.QS: REVIEW PRP'S DRAFT SAP

Description of PRP Deliverable

The PRP will submit to EPA Region III an SAP addressing theRI activities. It is expected that the SAP will follow theoutline recommended in the October 1988 Guidance for Conduct-ing Remedial Investigations and Feasibility Studies underCERCLA as well as appropriate regional guidance and willinclude a QAPjP and an FSP. The following elements of theQAPjP are expected to be included:

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o Project descriptiono Project organization and responsibilitieso QA objectives for measuremento Sampling procedureso Sample custodyo Calibration procedureso Analytical procedureso Data reduction, validation, and reportingo Internal quality controlo Performance and systems auditso Preventive maintenanceo Data assessment procedureso Corrective actionso Quality assurance reports

It is expected that the PRP's QAPjP will specify the analyt-ical procedures and the choice of analytical methods, datareduction, validation, and reporting methods. It is alsoexpected that samples will be analyzed by laboratories fol-lowing general CLP requirements.

The elements of the FSP are expected to be as follows:

o Site backgroundo Sampling objectiveso Sample location and frequencyo Sample designationo Sampling equipment and procedures

Anticipated Technical Support

A CH2M HILL review team consisting of the SM, the RTL, asenior hydrogeologist, a bioassessment specialist, a chem-ist, and a senior environmental engineer experienced in SAPpreparation will review and comment on the PRP's draft SAP.CH2M HILL will review the document for technical content,general information, and general conformance with EPARegion Ill's QAPjP guidance; completeness, accuracy, andappropriateness of field operation procedures and the ana-lytical program; and a data validation scheme.

Assumptions

It is assumed that the PRP's draft SAP will not exceed200 pages.

CH2M HILL will provide one technical memorandum summarizingthe major review comments on the PRP's draft SAP. The PRP'sfinal SAP will not be reviewed.

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SUBTASK ES.PM: PROJECT MANAGEMENT

CH2M HILL project management activities will be necessarythroughout the project. These activities will include proj-ect planning, scheduling, and staffing coordination; guidingand monitoring technical activities and tracking the budget;preparing monthly financial, technical, and scheduling statusreports; and coordinating communications between EPARegion III and CH2M HILL.

Assumptions

The project began in October, 1988 and it is assumed thatthe project will end in June 1991, therefore project manage-ment will be needed for a total of 32 months.

TASK 3; FIELD INVESTIGATION (FI)

During the RI, CH2M HILL will provide oversight of the PRP'sfield activities. The following field oversight activitiesare addressed in this work plan:

o Field oversight of bioassessment field activities(fish, benthic, algae, insects, mussel, bioaccumu-lation, and water toxicity studies)

o Field oversight of well installation and geotech-nical sampling

o Field oversight of groundwater sampling

o Field oversight of soil sampling

o Field oversight of surface water and sedimentsampling

These activities are considered the most pertinent, requir-ing oversight and split sample collection. The oversightactivities will be reviewed again after the PRP ' s SAP isreceived.

CH2M HILL will mobilize to monitor these field activitiesfollowing notification from the RPM. CH2M HILL will requireat least 10 working days notice to mobilize before the startof a field activity.

CH2M HILL's responsibilities during field oversight involve:


o Review the degree of compliance of the PRP's fieldactivities to those stated in their SAP and workplan.

o Coordinating split sampling with EPA Region III sothat analytical services can be scheduled. Be-cause the work is under the control of the PRP, itwill be necessary for EPA Region III to notifyCH2M HILL at least 60 calendar days beforesampling begins so that scheduling of analyticalservices can be optimized.

To reduce the potential for misdirection of investigativeactivities, CH2M HILL will not advise or make recommenda-tions to the PRP or its representatives while performingfield oversight. If CH2M HILL encounters a situation inwhich the PRP's field activities do not comply with the workplan or the SAP, the RPM will be notified as soon as pos-sible and the RPM will determine the proper action to betaken. CH2M HILL will provide written documentation of theincident to the RPM within 10 working days, including anydirection that may have been given to CH2M HILL by the RPM.

Within 10 working days after each sampling event, CH2M HILLwill provide the RPM with a technical memorandum addressingthe quantity and quality of field activities performed, thePRP's conformance with the applicable planning documents,and the types and number of sample splits collected aftereach field oversight episode.

EPA Region III will determine whether the progress, quantity,and quality of the work is in accordance with the consentagreement between the PRP and EPA Region III. CH2M HILLwill document all oversight activities; documentation willinclude field notes and photographs of the field activities,as appropriate.

CH2M HILL's time in the field will be determined by the rateat which the PRP progresses. CH2M HILL will follow its ownHSP while in the field. CH2M HILL's budget is based on theepisodes and associated level of effort described in eachsubtask below. CH2M HILL's budget is also based on Level Dpersonnel protection during field activities. CH2M HILL'scurrent HSP requires an upgrade to Level B should mercurylevels be-detected in air above the action level (using0.01 mg/m as required for methyl mercury). Level Cprotection is not commercially available for methyl mercury.If Level B is required, revisions to this work plan would benecessary.

AR300023


CH2M HILL will collect splits of the PRP's field samples atthe frequency determined in CH2M HILL's SAP for each samplematrix. Splits of geotechnical samples will not be collectedby CH2M HILL because this activity will be conducted by thePRP prior to approval of CH2M HILL's SAP.

The following split frequency for the media to be sampledwas provided to CH2M HILL by the RPM:

o Ecological sampling—fish, 5 percent; benthic,5 percent; algae, none; insects, none; and mussels,10 samples

o Groundwater sampling—10 per episode (4 episodes)

o Stream sampling—water column and sediment sampl-ing, 3 each per episode (2 episodes)

o Soil and waste sampling—2 soil samples and3 waste samples

The total number of splits to be collected by CH2M HILL,based on information reported in the PRP's work plan, andthe split frequency discussed above is indicated byTable 2-1. CH2M HILL will finalize the number of splitsamples to be collected upon receipt of the PRP's SAP.

SUBTASK FI.FO; PREPARE ANALYTICAL SERVICE REQUESTS ANDPROCUREMENT OF ANALYTICAL LABORATORY

Based on the split frequency described above, CH2M HILL willprepare a description of the samples to be analyzed andrequest special analytical services (SAS) from CRL.

As sumpt ions

It is assumed that all sample analysis {total mercury andmethyl-mercury) will be performed by the CLP with SASrequests.

SUBTASK FI.SM; SAMPLE AND DATA MANAGEMENT

The RI/FS oversight work will require planning and manage-ment of the split samples collected as well as the subsequentanalytical results. Analytical data from the split samplescollected by CH2M HILL will be entered in a data base whichwill be used to verify chain-of-custody and to conduct com-parisons of results from the split samples.

AR3QOQ21*


Sample management planning will address the following issues:

o Compatibility with the EPA Region III systemo The volume of data to be analyzedo The types of chemical analyseso Data entry and verification requirements

Assumptions

It is assumed that CH2M HILL's split data will be enteredinto a DBase III data base. The number of sample results tobe entered is based on the number of splits to be collectedby CH2M HILL (see Table 2-1).

No costs for data entry of any of the PRP's analytical dataare included in this budget. It is assumed that the PRP'scorresponding split data will be delivered to CH2M HILL ondiskettes in a data base compatible with DBase III.

It is assumed that only mercury and/or methyl-mercury analyt-ical results will be input in the data base.

SUBTASK FI.FB; FIELD OVERSIGHT OF BIOASSESSMENT PROGRAM

Whenever there is collection of benthic and fish samples by'the PRP, CH2M HILL will have a bioassessment specialist on-site to determine if the work is being performed in accord-ance with the PRP's work plan and SAP and to collect splitsamples as designated in CH2M HILL's SAP.

Assumptions

Field activity reports will be prepared and submitted to EPAwithin 10 working days of the completion of each samplingepisode.

The following general assumptions apply to the field over-sight of the bioassessment program:

o One analytical laboratory will be used and allbiological split samples will be forwarded by thePRP to that laboratory after homogenization at thePRP's laboratory.

o Benthic and fish sampling will not occur simultane-ously. Travel costs assume one round trip foreach fish and benthic sampling episode.

Level D personnel protection will be used. AR300025

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o All split samples collected will be analyzed onlvfor mercury, with the exception of fish and musselsamples, which will be analyzed for methyl-mercuryalso. Methyl-mercury analysis may be done outsideof the CLP.

The following assumptions apply specifically to the fishsampling activities:

o Four sampling episodes of six 10-hour days will beconducted.

o CH2M HILL will be onsite for oversight activitiesfor two 10-hour days for each episode.

o The PRP is expected to collect 16 fish of each offour species at each of six stations during eachof four sampling episodes. Hence the total numberof samples to be collected by the PRP is 1,536.As directed by the RPM, 5 percent of the samplescollected by the PRP will be split with CH2M HILL.Therefore, the number of samples which CH2M HILLwill send for analysis is 77 (see Table 2-1).

o All bioassessment splits will be shipped by thePRP to one analytical laboratory. CH2M HILL willprovide the PRP with appropriate sample shippingpaperwork and the name and address of the labora-tory the samples are to be sent to.

The following assumptions apply to the benthic samplingactivities:

o Six benthic sampling episodes will be conducted.i1 o CH2M HILL will be onsite for oversight activities

for three 10-hour days for each episode.

o The PRP is expected to collect one sample of eachof six species at each of six stations during eachof 6 sampling episodes. Hence the total number ofsamples to be collected by the PRP is 216. Asdirected by the RPM, 5 percent of the samples col-lected by the PRP will be split with CH2M HILL.Therefore, the number of samples which CH2M HILLwill send for analysis is 10 (see Table 2-1).

o All bioassessment splits will be shipped by thePRP to one analytical laboratory. CH2M HILL willprovide the PRP with appropriate sample shipping

AR300027


paperwork and the name and address of the labora-tory the samples are to be sent to.

The following assumption applies to the insect and algaecollections:

o CH2M HILL will oversee the collection of insectand algae samples during the benthic sampling epi-sodes in this subtask. Therefore, travel costsfor this activity are not included in this subtask.As directed by the RPM, no split samples will becollected.

The following assumptions apply to the mussel survey:

o The PRP is expected to collect three samples ofthree species from five stations. Hence the totalnumber of samples to be collected by the PRPis 45. As directed by the RPM, 10 of the samplescollected by the PRP will be split with CH2M HILL.

o Oversight activity will coincide with the fish/benthic sampling activities, therefore travelcosts for this activity are not included in thissubtask.

o Splits will be shipped by the PRP, after homogeniza-tion at the PRP's laboratory, to one laboratory.CH2M HILL will provide the PRP with appropriatesample shipping paperwork and the name and addressof the laboratory the samples are to be sent to.

The following assumptions apply to the bioaccumulation study:

o A field observation of the bioaccumulation studywill occur during a fish sampling episode, there-fore, travel costs for this activity are notincluded in this subtask.

o No split samples will be collected.

The following assumptions apply to the biotoxicity study:

o Field oversight will be done for the collection ofwater for the toxicity study only.

No split samples will be collected.

Oversight activity will coincide with a benthicfield activity, therefore, travel costs farpt-hAactivity are not included in this subtaskH*"* o U


SUBTASK FI.FI; FIELD OVERSIGHT OF WELL INSTALLATION

During the well installation period, CH2M HILL's hydrogeolo-gist was onsite to observe and document how the work isbeing performed. At the time of the well installation, boththe PRP's work plan and SAP was under preparation. Therefore,CH2M HILL's oversight activities was limited to observingthe well installation activites and not compliance of thePRP with their work plan and SAP.

Assumptions

The budget for this subtask assumes no collection of splitsamples and that Level D protection will be used byCH2M HILL's personnel. Three drilling/well installationepisodes have been completed. One more oversight activityis expected to observe well development.

CH2M HILL has submitted to EPA three trip reports, one aftereach well installation episode and a fourth will be sub-mitted after the well development observation.

SUBTASK FI.FQ; FIELD OVERSIGHT OF GROUNDWATER SAMPLING

Whenever there is collection of groundwater samples by thePRP, CH2M HILL will have a hydrogeologist onsite to determineif the work is being performed in accordance with the PRP'swork plan and SAP and to collect split samples as designatedin CH2M HILL's SAP.

Assumptions

The following assumptions apply to the groundwater samplingactivities:

o Four 2-day sampling episodes at 10 hours each daywill be conducted.

o Ten samples collected by the PRP will be splitwith CH2M HILL during each sampling episode asdirected by the RPM.

o Splits will be shipped daily to one analyticallaboratory.

o All split samples collected will be analyzed formercury only.

AR300029


o Level D protection will be used by CH2M HILL'spersonnel.

o Four field activity reports will be submitted toEPA within 10 days after the sampling episodes arecompleted.

SUBTASK FI.FS; FIELD OVERSIGHT OF SOIL SAMPLING

Whenever there is collection of soil and waste samples,.CH2M HILL will have an environmental engineer onsite todetermine if the work is being performed in accordance withthe PRP's work plan and SAP and to collect split samples asdesignated by CH2M HILL's SAP.

Assumptions

o Three waste samples and two soil samples collectedby the PRP will be split with CH2M HILL

o Samples will be collected during two 10-hour days

o Samples will be held at the end of the second daywhen sampling is expected to be completed and willbe shipped in a single shipment

o Split samples collected will be analyzed for mer-cury and methyl-mercury

SUBTASK FI.FW; FIELD OVERSIGHT OF SURFACE WATER ANDSEDIMENT SAMPLING

During the collection of stream and sediment samples by thePRP, CH2M HILL will have a hydrologist onsite to determineif the work is being performed in accordance with the PRP'swork plan and SAP and to collect split samples as designatedin CH2M HILL's SAP.

Assumptions

The following assumptions apply to the surface water andsediment sampling activities:

o Two 2-day sampling episodes lasting 10 hours eachwill be conducted.

o Two samples collected by the PRP will be splitwith CH2M HILL during each sampling episode.

AR300030


o Splits will be shipped daily to one analyticallaboratory.

o All water column split samples collected will beanalyzed only for total and dissolved mercury.

o All sediment split samples collected will beanalyzed only for total and methy mercury.

o Level D protection is assumed.

o Two field activity reports will be submitted toEPA, each within 10 days of the completion of eachsampling episode.

SUBTASK FI.DE; DATA EVALUATION

A technical memorandum will be developed to detail the quan-titative and qualitative comparisons of the analytical resultsobtained by the CLP laboratory versus the analytical resultsobtained by the PRP's laboratory for the split samples. Thememorandum will include tabulated data and conclusions.

Assumptions

The following assumptions regarding data evaluation havebeen made:

o As requested by the RPM CH2M HILL's split datawill not be validated.

o Statistical comparisons will be made ofCH2M HILL's split data with PRP's correspondingdata only.

o PRP's data will be provided to CH2M HILL ondiskettes on an ongoing basis as the analyticaldata are received by the PRP from the laboratoryand entered into their data base.

o It is assumed a comprehensive review of thequality of PRP's data will be done by CRL.

Potential action required by split comparisons will bediscussed with EPA Region III and any further action wouldthen be scoped and budgeted.

AR300031


SUBTASK FI.QC; QUALITY CONTROL

It is assumed that the RTL, and the senior project staff—the hydrogeologist, the bioassessment specialist, the pro-cess engineer, and the chemist—will communicate viaconference calls before field oversight activities areinitiated to discuss and resolve problems should they occur.

TASK 4; ASSESSMENTS OF RISKS (AR)

This task includes a review of the biological toxicity andbiological assessment reports and to provide technical assist-ance to EPA for the risk assessment when needed.

SUBTASK AR.RO: TECHNICAL SUPPORT FOR RISK ASSESSMENT REVIEW

It is assumed that EPA Region III will be the PRP's primaryreviewer of the risk assessment report. CH2M HILL will haveavailable a senior toxicologist to provide EPA with technicalsupport if needed. Meeting attendance is not budgeted inthis subtask.

SUBTASK AR.B1: REVIEW PRP'S DRAFT BIOLOGICAL TOXICITY REPORT

Description Of PRP's Deliverables

A biological toxicity study will be conducted by the PRP tocharacterize the potential toxicity of discharges from WastePond No. 5 to aquatic life. According to the Compendium ofSuperfund Field Operations Methods (EPA, 1987) , toxicitytest methods for hazardous waste sites are under develop-ment, with no one set of protocol mandated for use. It istherefore expected that the toxicity study will be conductedin accordance with state and regional National PollutantDischarge Elimination System (NPDES) procedures. Accordingto the PRP's schedule, the biological toxicity report willbe a distinct document for the purposes of review, but it isanticipated that this document may be included as a chapterof the RI report.


Draft and final versions of the biological toxicity reportwill be submitted by the PRP to EPA Region III for reviewand comment. Only the draft will be reviewed by CH2M HILL'sSM and a senior bioassessment specialist. The review willfocus on accuracy, completeness, and conformance withcurrent NPDES toxicity test requirements. AR300032


Assumptions

It is assumed that the PRP's draft biological toxicity reportwill be 30 pages in length. It is also assumed thatCH2M HILL's review will be for reasonableness and not be anindepth review of procedures, data quality, and method ofdrawing conclusions. CH2M HILL will provide one technicalmemorandum summarizing major comments on the PRP's bio-logical toxicity report. CH2M HILL will not be.reviewingthe PRP's final biological toxicity report. Meetingattendance is not budgeted in this subtask.

SUBTASK AR.B2; REVIEW PRP'S DRAFT BIOLOGICAL ASSESSMENTREPORT

Description of PRP's Deliverable

An environmental assessment will be performed by the PRP toevaluate the impacts of mercury discharge from the site tothe aquatic communities of the NFHR. This will include fish,benthic, and mussel studies; ambient toxicity and bioaccumu-lation studies; and mercury fate and transport modeling.CH2M HILL expects that the bioassessment will be performedin accordance with guidelines established in Compendium ofSuperfund Field Operations Methods (EPA, 1987). Accordingto the PRP's schedule, the biological assessment report willbe a distinct document for the purposes of review, but it isanticipated that this document may be included as a chapterof the RI report.

The objective of the bioassessment is to determine theimpacts of mercury discharge from the site on the bioticintegrity of the NFHR's aquatic communities.


Draft and final versions of the biological assessment tox-icity report will be submitted by the PRP to EPA Region IIIfor review and comment. Only the draft will be reviewed byCH2M HILL's SM and a senior bioassessment specialist. Thereview will focus on accuracy, completeness, and conformancewith EPA Region Ill's current bioassessment guidance.

Assumptions

It is assumed that the PRP's draft biological assessmentreport will be 50 pages in length. It is assumed thatCH2M HILL's review will be for reasonableness and not be anindepth review of procedures, data quality, and method of nnoodrawing conclusions. CH2M HILL will provide one technicalAR 30 0 0 3 3memorandum summarizing major comments of the PRP's bioassess-- - - - - -ment. CH2M HILL will not be reviewing the PRP's final


biological assessment report. Meeting attendance is notbudgeted in this subtask.

SUBTASK AR.QC; QUALITY CONTROL

It is assumed that the RTL, and the senior project staff—the hydrogeologist, the toxicologist, and the bioassessmentspecialist—will communicate via conference calls uponreceipt and review of the PRP's deliverables to discuss andresolve issues that may arise.

TASK 5: REMEDIAL INVESTIGATION (RI)

This task includes a review of the PRP's deliverables forthe remedial investigation.

SUBTASK RI.R2; REVIEW PRP'S FINAL GROUNDWATER SAMPLINGREPORT


The PRP's work plan indicates the submittal to EPA Region IIIof a final groundwater sampling report prior to the submittalof the draft RI report.


This subtask includes review of the final groundwater sampl-ing report by a senior hydrogeologist/geochemist.

Assumptions

It is assumed that the final groundwater report will beapproximately 120 pages and will describe results of waterelevation monitoring, analytical results of groundwatersamples, water balance, groundwater modeling, and geochem-ical evaluation. It is also assumed that CH2M HILL's reviewwill be for reasonableness. An extensive review of thegroundwater model is not included.

One memorandum detailing CH2M HILL's review comments will besubmitted to EPA.

SUBTASK RI.R3: REVIEW PRP's DRAFT REMEDIAL INVESTIGATIONREPORT

Description of PRP's Deliverable _ «.

Following completion of RI activities, the PRP will preparea report presenting the information and findings of the RI


for EPA Region Ill's review and comment. The report willpresent all current information on the site, as well as con-clusions and interpretations. CH2M HILL expects the RIreport to follow the Guidance for Conducting Remedial Invest-igations and Feasibility Studies Under CERCLA (October 1988).

Elements expected to be included in the RI report are:

o A thorough documentation of field activities

o Documentation and discussion of previous site char-acterization activities

o A summary of regional hydrogeology and relevantreferences

o A narrative describing the drilling and samplingprocedures that were followed, including a descrip-tion of the equipment used

o Detailed boring logs using accepted geotechnicaldescriptions, including results of HNu/OVAmonitoring

o Detailed record drawings of monitoring well con-struction, including elevations and descriptionsof measuring point

o Documentation of well development activities

o Detailed geologic cross sections showing the loca-tion of the screened interval of monitoring wellsand the identification of hydrostratigraphic units

o Potentiometric surface maps of all hydrostratigra-phic units

o Available water level data

o Maps showing locations of soil borings and monitor-ing wells

o A discussion of the aquifer testing program and apresentation of results

o Sampling methodologies and protocols followed

o A table showing time, date of collection, date ofshipment, courier, laboratory destination, andanalyses requested for all samples

AR300035


o A table of field parameters collected

o Well-organized data tables containing laboratoryanalytical results for all groundwater samples

o The QA/QC report validating the laboratory data

o Maps and a narrative describing the spatial andtemporal distribution of contaminants and aninterpretation of source, fate, and transport.

The following geotechnical information is also anticipatedto be included in the RI report:

o A narrative describing drilling procedures, sampl-ing methodologies, and protocols observed

o Detailed boring logs using accepted geotechnicalterminology, noting zones of contaminationencountered

o Detailed geologic cross sections showing the strat-igraphy encountered

o Tables showing sample number, time and date ofcollection, data shipped, analytical laboratorycourier, etc.

o Well-organized data for each boring table showinglaboratory results

CH2M HILL recommends that, before writing the report, thePRP submit an RI report outline to EPA Region III for review.The draft RI report would then be submitted to EPA Region IIIfor review. After review and comment, a final report willbe prepared by the PRP and submitted to EPA Region III forapproval.


As stated above, CH2M HILL expects that a draft and a finalof the PRP's RI report will be submitted to EPA Region IIIfor review and comment. Only the draft of the report willbe reviewed. It will be reviewed by the CH2M HILL SM, theRTL, the senior hydrogeologist/geochemist, and a seniorproject quality control (QC) reviewer. The draft of the RIreport will be reviewed for overall completeness and accu-racy and to identify additional data or information needs.The draft will also be reviewed to determine if: (I) thelevel and extent of groundwater contamination attribu-fcahl/erj n q c


to site sources has been identified, (2) the rate of con-taminant migration has been calculated, and (3) pathways forcontaminant migration have been identified.

Assumptions

For budgeting purposes, it is assumed that the draft RIreport will be 200 pages in length. CH2M HILL will provideEPA Region III with one RI evaluation report which will sum-marize and provide supporting information, where necessary,for the major comments and additional data needs. The reviewwill be conducted within 20 working days of receipt of thePRP's draft. Relative to fate and transport modeling, thissubtask assumes a review of a summary of the fate and trans-port study only. An extensive review of the fate and trans-port model is not included. Likewise, a review of only thesummary of the groundwater study is included. An extensivereview of groundwater model is not included.

CH2M HILL has budgeted for one meeting with EPA Region IIIand the PRP to discuss the draft RI report. The meetingwould be attended by the CH2M HILL SM, the RTL, and thesenior hydrogeologist/geochemist.

SUBTASK RI.QC; QUALITY CONTROL

It is assumed that the RTL, and the senior project staff—the hydrogeologist, the process engineer, and the geotech-nical engineer—will communicate via conference calls uponreceipt and review of the PRP's deliverables to discuss andresolve issues that may arise.

TASK 6; FEASIBILITY STUDY (FS)

CH2M HILL recommends that the list of the remedial actionalternatives and the comparative ranking of the alternativesbe reviewed by EPA Region III prior to reviewing the PRP'sdraft FS report. This will provide for a more efficient FSprocess and potentially can save time by eliminating majorrevisions to the FS report.

The following sections describe the subtasks to be conductedby CH2M HILL under Task 6, Feasibility Study.

AR300037


SUBTASK FS.R6; REVIEW PRP'S DRAFT FEASIBILITY STUDY REPORT


Following completion of the alternatives evaluation, a draftFS report will be prepared that summarizes the advantagesand disadvantages of each alternative and the PRP's recommen-dation of the alternative(s) to be implemented. The recom-mended alternative(s) must be technically feasible andreliable and must adequately protect against or mitigatedamage to the public health and the environment.


CH2M HILL has budgeted for the review of one draft FS report.The draft will be reviewed by CH2M HILL's SM, a senior hydro-geologist, a senior geotechnical engineer, and a senior pro-cess engineer for completeness, technical content, andconformance with the National Contingency Plan and the Guid-ance for Conducting Remedial Investigations and Feasibility"Studies Under CERCLA, October, 1988. Review for compliancewith applicable federal, state, and local regulations willbe the responsibility of EPA Region III and state reviewers.

Assumptions

It is assumed that the PRP's draft FS report will be 80 pagesin length.

CH2M HILL will provide to EPA Region III a draft a FS evalua-tion report, summarizing the review comments for the draftand the final versions reviewed. Comments will be providedto EPA Region III within 20 working days of CH2M HILL'sreceipt of the draft report.

SUBTASK FS.QC; QUALITY CONTROL

It is assumed that the RTL, and the senior project staff—the hydrogeologist, the process engineer, and the geotechni-cal engineer—will communicate via conference calls uponreceipt and review of the PRP's deliverables to discuss andresolve issues that may arise.

TASK 7; PROJECT CLOSEOUT (PC)

In accordance with ARCS II requirements, project files willbe organized, labeled, and sent to CH2M HILL's Program^ .f| Q n o pagement Office for microfilming. * - UUJQ


Assumptions

This task includes an allowance of 8 hours for each keyproject staff member to assemble and label his or her files.Project management is allocated 2-1/2 weeks for reviewingand organizing files and 1 week for general management ofproject closeout activities, including issuing instructions,answering questions, and monitoring the progress of thestaff. One week is allocated solely for the closeout ofhardcopy data files and diskettes. Office support is alsoincluded with an allowance of 2 weeks.

WDR391/067

AR300039


Section 3PROJECT SCHEDULE

The project schedule for CH2M HILL's involvement in the RI/FS,shown in Figure 3-1, is dependent upon the schedule outlinedin PRP's work plan. The schedule for project planning deliv-erables, data reports, and field activity reports is pre-sented in Table 3-1. The schedule for providing reviewcomments on the PRP deliverables is shown in Table 3-2.Comments on the draft deliverables will be provided byCH2M HILL to EPA Region III within 20 working days; commentson the final deliverables will be provided within 15 workingdays. CH2M HILL can be responsible for only those aspectsof the project directly within its control. Close coordina-tion will be required by EPA, the PRP, and CH2M HILL to avoidany adverse impacts on the schedule.

The schedule will be updated monthly and revised as needed.An updated schedule will be provided to the RPM if changeshave occurred.

WDR391/069

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Table 3-1SUMMARY OF CH2M HILL'S OTHER PLAHNING AND REPORTING DELIVERABLES TO EPA

BudgetedUnder Information/Activity

Subtask No. Required Prior to Submittal CH2M HILL Deliverable Projected Date/Schedule

PP.WP Site visit Site Visit Report February 7, 1989Draft PRP RI/FS Work Plan Draft Oversight Work Plan February 7, 1989EPA Comments to CH2M HILL DraftOversight Work Plan Final RI/FS Work Plan March 30, 1989Revised PRP SAP Revised Final RI/FS Work Plan June 30, 1989

FI.FB Oversight of Biological Sampling Field Activity Reports 10 working days after corn-Episodes (Total of 6 reports) pletion of field sampling

episode.FI.FI Oversight of Well Installation Trip Reports (Total of 4 10 working days after comple-

reports) tion of each well installa-tion and/or geotechnicalsampling episode.

FI.FQ Oversight of Groundwater Sampling Field Activity Reports (Total 10 working days after com-of 4 reports) pletion of field sampling

episode.

FI.FW Oversight of Surface Water and Field Activity Reports (Total 10 working days after corn-Sediment Sampling of 2 reports) pletion of field sampling

episode.

FI.DE Analytical Results of Split Data Evaluation Report 50 working days after receiptSamples and Validated PRP of analytical results fromAnalytical Results final field sampling episode

WDR404/086

Revision No. 1Section: .3.Page: 6 of 6Date: 3/24/89

Table 3-2SUMMARY OF PRP'S AND CH2M HILL'S REVIEW DELIVERABLES TO EPA

AnticipatedCH2M HILL

Turnaround TimeBudgeted CH2M HILL's Technical Discussion/ Working Day AfterUnder Support Deliverables Conference Receipt of PRP's

Subtask No. _____PRP's Deliverables_____ Deliverable Meeting Call Deliverables

PP.QS HSP None

ES.WP Draft RI/FS Work Plan TM1 X 20Final RI/FS Work Plan TM2 15

ES.QS Draft SAP TM3 X 20

RI.R2 Final Groundwater Sampling Report TM4 X 20

RI.R3 Draft RI Report RI Evaluation Report X 20

AR.B1 Draft Biological Toxicity Report TM5 X 20

AR.B2 Draft Biological Assessment Report TM6 X 20

FS.R6 Draft FS Report FS Evaluation Report 20

Note: TM—Technical Memorandum.

WDR404/043


Section 4PROJECT COSTS

Table 4-1 presents the estimated costs for the seven tasksdescribed in this work plan. These costs have been preparedon the basis of the assumed level of effort described inSection 2. The level of effort of each subtask will be afunction of the quality of the PRP deliverables, the dura-tion of field activities,' and the location and duration ofexternal meetings. It is important to note that since thePRP is implementing the RI/FS, many of these factors arebeyond CH2M HILL's control.

WDR391/068


Section 5PROJECT MANAGEMENT PLAN

PROJECT ORGANIZATION

This work assignment will be managed out of CH2M HILL'sReston, Virginia, office with significant support from theOak Ridge, Tennessee, office. Qualified technical personnelfrom the Oak Ridge office are being used because of theirproximity to the Saltville site and the lower travel costsassociated with using this office. Technical personnel will,in general, come from the Reston office; however, specializedtechnical expertise will be brought in as needed. SadiaKissoon will serve as SM and will work directly with LesleyBrunker, the Region III RPM.

To provide the required technical oversight support for theSaltville RI/FS, CH2M HILL has assembled a multidisciplinaryproject team. The project team organization for the over-sight activities for the Saltville RI/FS is shown in Fig-ure 5-1. The responsibilities of key members of the projectteam are discussed below.

Site Manager

The SM will be responsible for managing the execution ofproject tasks and using the resources of the project team inthe most efficient manner. The SM will be responsible forall technical, financial, administrative, and Agency-relatedaspects of the project. The SM will act as the primary con-tact between CH2M HILL and the RPM.

Review Team

A QC review team has been organized to meet the specificneeds of the project. The ARCS program manager will provideoverall assurance that all work is performed in accordancewith the ARCS III Management Plan. The RTL will be respons-ible for coordinating the technical reviewers on the reviewteam.

Senior Hydrogeologist

The senior hydrogeologist will be responsible for reviewingthe hydrogeologic aspect of the PRP's work plan, the RIreport, and well installation; overseeing the groundwatersampling; collecting, analyzing, and interpreting splitsamples; preparing technical memorandums and the RIevaluation report detailing review comments; summarizi

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field oversight activities; and attending review meetingswith EPA Region III and the PRP, when necessary.

Risk Assessment Specialist

The risk assessment specialist will be responsible for review-ing the PRP's work plan and risk assessment report. Specific-ally, he or she will review methodologies used by the PRP toassess actual and potential health risks posed by the site.The risk assessment specialist will incorporate results ofthe environmental assessment. The risk assessment specialistwill also be responsible for preparing technical memorandumsthat detail review comments and will attend review meetingswith EPA Region III and the PRP, when necessary.

Bioassessment Specialist

The bioassessment specialist will be responsible for review-ing the PRP's work plan and environmental assessment reports.He or she will also be responsible for preparing technicalmemorandums that detail review comments, and will attendreview meetings with EPA Region III and the PRP whennecessary.

Senior Geotechnical Engineer

The senior geotechnical engineer will be responsible forreviewing the PRP's work plan and FS report; overseeing thecollection of geotechnical samples; collecting, analyzing,and interpreting split samples; preparing technical memo-randums detailing review comments; and attending reviewmeetings with EPA Region III and the PRP, when necessary.

Site Safety Officer

The site safety officer will be responsible for monitoringteam members' adherence to the site safety requirements, asdescribed in the site safety plan, modifying the levels ofprotection based on site conditions; determining and postinglocations and routes to medical facilities, including poisoncontrol centers; arranging for emergency transportation tomedical facilities; examining work party members for symptomsof exposure or stress; and providing emergency first aidonsite, as necessary.

Sample Management Specialist

Responsibilities of the sample management specialist willinclude scheduling the analytical laboratory for delivery ofsample containers and for sample analysis; coordinating


appropriate paperwork for sample collection, custody, andshipping; coordinating data validation; and organizingCH2M HILL's and the PRP's analytical results of splits intoa data base in parallel with validation. Data QA, QC, andvalidation will be important in selecting the required reme-dial alternative. Responsibilities of the sample managementspecialist will also include coordination of an analyticaldata base, data QC and validation for split samples, and aQC review of a subset of the PRP's analytical data base.

SCHEDULE CONTROL

The site manager will monitor the actual progress of theproject against the task schedules and due dates for deliv-erables. The SM will be responsible for maintaining and, ifnecessary, updating the project schedule.

The SM will keep the RPM informed of any known or antici-pated slippage or acceleration of project elements. It isanticipated that the schedule may differ from that presentedin this work plan because of its dependence on the PRP'sproject schedule. If slippage of tasks within the controlof CH2M HILL occurs or is anticipated, the site manager willdevelop and outline available methods to maintain the overallproject schedule. If slippage occurs as a result of thePRP's schedule, the SM will inform the RPM and will partici-pate in discussions regarding methods available to minimizeschedule slipping.

COST CONTROL

The work plan includes a detailed summary of projected laborand expense costs broken down by individual activities andtasks. The cost monitoring system for this project willprovide the SM with a monthly report of current and cumula-tive site costs, down to the subtask level. This monitoringsystem will be used to track budget versus actual expendi-tures on individual site activities and will give the SM aclear indication of any deviations from projected projectdelivery costs.

The SM will keep the RPM informed of the status of the budget.If the costs of tasks within the scope of work are antici-pated to exceed the established budget, the SM will alertthe RPM before an overrun occurs and will work with the RPMto manage available funding. Changes in the scope of workor in the assumptions made in this scope that will result ina change in costs will be identified early so that appropri-ate actions can be taken.

flR300050


The SM will monitor and approve expenditures, authorize tra-vel costs, and direct the site team to use government traveldiscounts. The SM will check all subcontractor invoices forreasonableness and for compliance with the terms of the con-tract. No subcontractor charges in excess of contractedbudgets will be authorized or paid prior to EPA approval;clear documentation must be provided before consideration isgiven of the validity of the charges.

COORDINATION WITH EPA AND THE PRP

CH2M HILL anticipates having interaction with EPA and thePRP. The RPM for EPA, Lesley Brunker, is the primary con-tact for CH2M HILL, unless otherwise notified. Throughoutthe course of the RI/FS, CH2M HILL project personnel willhold periodic meetings with EPA Region III. At criticaljunctures of the project, it will also be necessary to con-duct meetings between EPA Region III, CH2M HILL, the PRP,and other parties, as appropriate, to discuss projectdeliverables and the schedule and to evaluate the need forand scope of additional studies. Where possible, meetingswill be combined to reduce project costs. Table 5-1 is asummary of meetings anticipated for this project.

QUALITY CONTROL

The focal point of quality control in ARCS projects is theRTL. For the Saltville RI/FS oversight, the RTL is SkipEllis. The RTL leads and organizes the review team ofsenior discipline members and is responsible for monitoringoverall project quality in deliverables and project manage-ment activities.

WDR391/070

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