2017 GW RA RAWP.pdf

N62661.PF.003776

NS NEWPORT

5090.3b

FINAL GROUNDWATER REMEDIAL ACTION WORK PLAN OPERABLE UNIT 7 (OU 7) SITE 8

NS NEWPORT RI

10/6/2017

TETRA TECH

4659‐WE15‐17‐0336

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING COMMAND, ATLANTIC

REMEDIAL ACTION CONTRACT (RAC)

CONTRACT NO. N62470-13-D-8007

CONTRACT TASK ORDER NO. WE15

FINAL

GROUNDWATER REMEDIAL ACTION WORK PLAN

OPERABLE UNIT 7 (SITE 8)

NAVAL STATION NEWPORT

MIDDLETOWN, RHODE ISLAND

October 2017

Prepared for

Department of the Navy

Naval Facilities Engineering Command, Mid-Atlantic 9742 Maryland Avenue

Norfolk, VA 23511-3095

Prepared by

Tetra Tech EC, Inc.

5250 Challedon Drive

Virginia Beach, Virginia 23462

Revision Date Prepared by Approved by Pages Affected 0 10/6/17 K. Sellers D. Pinkham All

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Work Plan Final Contract No. N6270-13-D-8007 October 2017 Contract Task Order No.WE15 – NAVSTA Newport, RI i

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 WORK PLAN OBJECTIVE AND ORGANIZATION

3.0 SITE DESCRIPTION AND BACKGROUND

3.1 Site Location and Description

3.2 Site Background

4.0 REGULATORY FRAMEWORK

4.1 Remedial Action Objectives

5.0 PRE-CONSTRUCTION ACTIVITIES

5.1 Work Plan Documents

5.2 Permitting Considerations

5.2.1 Underground Injection

5.2.2 Effluent Discharge

5.2.3 Navy Facility Engineering and Acquisition Division Approvals

5.3 Procurement

5.4 Pre-Construction and Mutual Understanding Meeting

5.5 Subsurface Utility Location

6.0 SITE WORK

6.1 Mobilization and Site Preparation

6.1.1 Coordination with NUWC Operations

6.1.2 Base Access

6.1.3 Work Hours

6.1.4 Material Storage and Equipment Laydown Areas

6.1.5 Erosion and Sediment Control

6.2 Additional Refinement Activities

6.2.1 Surface Geophysical Surveys

6.2.2 Well Installation and Testing

6.2.2.1 Well Installation and Pump Testing for North Meadow

(Treatment Area A)

6.2.2.2 Well Installation and Recovery Testing for Building 179 Area (Treatment Area C)

6.2.2.3 Well Installation and Pump Testing for South Meadow

(Treatment Area B)

6.2.3 Site Surveying

6.3 In-Situ Enhanced Bioremediation of Groundwater Overview

6.3.1 Microbial Population Monitoring

6.3.2 Electron Donor Substrate (Sodium Lactate)

6.4 Remedy Implementation - North Meadow (Treatment Area A)

6.4.1 Remedial Design Parameters for North Meadow (Treatment Area A)

6.5 Remedy Implementation – Building 179 Area (Treatment Area C) ii

6.5.1 Remedial Design Parameters

6.5.2 RIDEM Discharge Criteria

6.6 Remedy Implementation - South Meadow (Treatment Area B)

6.6.1 Hydraulic Evaluation

6.7 Decontamination and Demobilization

7.0 GROUNDWATER SAMPLING AND ANALYSIS REQUIREMENTS

7.1 Analytical Parameters

7.1.1 Baseline and Post-Bioremediation Monitoring

7.1.2 Performance Monitoring During Bioremediation Injection:

7.1.3 Discharge Monitoring to Deerfield Creek:

7.2 Remedy Performance Evaluation

8.0 ACCIDENT PREVENTION PLAN

9.0 ENVIRONMENTAL PROTECTION PLAN

9.1 Designation of Environmental Manager

9.2 Required Environmental Training

9.3 Applicable or Relevant and Appropriate Requirements

9.4 Chemical Inventory and Control

9.5 Spill Prevention and Control

9.5.1 Rhode Island Spill Reporting

9.5.2 National Response Center Reporting

9.5.3 Spill Prevention

9.5.4 Spill Containment and Control

10.0 SPILL CLEANUP AND REMOVAL

10.1 Protection of Existing Resources

10.1.1 Protection of Air Quality

10.1.2 Protection of Water Quality

10.1.3 Protection of Land Resources

10.1.4 Protection of Fish and Wildlife

10.1.5 Protection of Historical and Archaeological Resources

10.1.6 Noise

10.2 Environmental Conditions Report

11.0 WASTE MANAGEMENT PLAN

11.1 Objective

11.2 Navy Assistance

11.3 Waste Streams

11.4 Sample Shipment

11.5 On-Site Waste Management

11.5.1 Containerization

11.5.2 Container Marking and Labeling

11.5.3 Accumulation/Storage

11.5.4 Container Inspections

11.5.5 Waste Container Inventory Log

iii

11.6 Transportation and Disposal Plan

11.6.1 Treatment, Storage, and Disposal Facility Selection

11.6.2 Waste Transporter Selection

11.6.3 Land Disposal Restrictions

11.6.4 USDOT Requirements

11.6.5 Complete Manifest Packages

11.6.6 Manifest Package Submittal

11.6.7 Recordkeeping Requirements

11.6.8 Discrepancy Reports

11.6.9 Exceptions Reports

11.7 Spill Prevention

12.0 CONTRACTOR QUALITY CONTROL PLAN

12.1 Introduction

12.2 Scope of Work

12.3 Definable Features of Work

12.4 Inspection Process

12.4.1 Preparatory Phase Inspection

12.4.2 Initial Phase Inspection

12.4.3 Follow-up Phase Inspection

12.5 Deficiency Management

12.6 Quality Control Meetings

12.6.1 Project Kickoff and Mutual Understanding Meetings

12.6.2 On-Site Quality Control Meetings

12.7 Submittals

12.7.1 Contractor Production Report

12.7.2 Contractor Quality Control Report

12.7.3 QC Certifications

12.7.4 Submittal Register

12.8 Field QC Logbook

12.9 Project Files

13.0 CONSTRUCTION COMPLETION REPORT

14.0 REFERENCES

iv

LIST OF FIGURES

Figure 1 Location and Vicinity Map Figure 2 Site Detail Map Figure 3 Limits of Groundwater Contamination above RGs Figure 4 Geophysical Survey Areas Figure 5 Proposed North Meadow (Treatment Area A) Remediation Well Locations Figure 6 North Meadow (Treatment Area A) Remediation Wells Design Figure 7 Proposed Treatment Area B Remediation Well Locations Figure 8 Building 179 Area (Treatment Areas B and C) Remediation Wells Design Figure 9 Proposed Treatment Area B Remediation Well Locations Figure 10 North Meadow (Treatment Area A) Groundwater Remedy Layout Figure 11 South Meadow Area (Treatment Area B) Groundwater Remedy Layout

LIST OF TABLES

Table 1 Remediation Goals (RGs) for Site 8 Groundwater Table 2 RIPDES Discharge Requirements Table 3 Bioremediation System Monitoring Locations during the Injection Period Table 4 Performance Monitoring Frequency and Parameters for Post Injection

Sampling Table 5 Additional Sampling of Multiple Depth Intervals Table 6 Emergency Contact Information for Spills

LIST OF APPENDICES

Appendix A Sampling and Analysis Plan Appendix B Accident Prevention Plan Appendix C Contractor Quality Control Plan Documents v

ABBREVIATIONS AND ACRONYMS

AHA Activity Hazard Analyses APP Accident Prevention Plan ARARs Applicable or Relevant and Appropriate Requirements Bgs Below ground surface CCR Construction Completion Report CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CIH Certified Industrial Hygienist COC Contaminants of Concern COR Contracting Officer’s Representative CQCP Contractor Quality Control Plan CTO Contract Task Order CVOCs Chlorinated volatile organic compounds DCA Dichloroethane DCE Dichloroethene DFOW Definable Features of Work DHC Dehalococcoides DN Deficiency Notice DO Dissolved Oxygen DoD Department of Defense ECATTS Environmental Compliance Assessment Training and Tracking System EPP Environmental Protection Plan ERP Environmental Remediation Program ESD Explanation of Significant Differences FCR Field Change Request FEAD Facility Engineering and Acquisition Division FFA Facility Agreement GAC granular activated carbon GPM Gallons per Minute GPS global positioning system GSR Green and Sustainable Remediation HERO Hazards of Electromagnetic Radiation to Ordnance IATA International Air Transportation Association ID Inner diameter LDR Land Disposal Restriction LUC Land Use Control mg/L milligrams per liter MNA Monitored Natural Attenuation MSDS Material Safety Data Sheets NAVFAC Naval Facilities Engineering Command NAVSTA Naval Station NCP National Oil and Hazardous Substances Pollution Contingency Plan vi

NCR Nonconformance Report NETC Naval Education and Training Center NFPA National Fire Protection Association NOI Notice of Intent NRC National Response Center NTR Navy Technical Representative NUSC Naval Underwater Systems Center NUWC Naval Undersea Warfare Center ORP Oxidation Reduction Potential OSR Off-Site Rule PCBs Polychlorinated Biphenyls PDI Pre-Design Investigation PCE tetrachloroethene PLS Professional Land Surveyor PM Project Manager PPE personal protective equipment PQCM Project Quality Control Manager PSA Paved Storage Area PSIG pounds per square inch gauge PSN Proper Shipping Name QC Quality Control RA Remedial Action RAC Remedial Action Contract RAO Remedial Action Objective RAWP Remedial Action Work Plan RCRA Resource Conservation and Recovery Act RD Remedial Design RGs Remediation Goals RI Remedial Investigation RIDEM Rhode Island Department of Environmental Management RIPDES Rhode Island Pollutant Discharge Elimination System ROD Record of Decision RPM Remedial Project Manager RQ Reportable Quantity SAP Sampling and Analysis Plan SARA Superfund Amendments and Reauthorization Act SDS Safety Data Sheets SHM Safety and Health Manager SPCC Spill Prevention Control and Countermeasure SRI Supplemental Remedial Investigation SRT Seismic Refraction Tomography SS Site Superintendent SSHO Site Safety and Health Officer TAL Target Analyte List TBD To Be Determined vii

TCA Trichloroethane TCE Trichloroethene TOC Total Organic Carbon TSCA Toxic Substances Control Act TSDF Treatment, Storage, and Disposal Facility TtEC Tetra Tech EC, Inc.

TtNUS Tetra Tech NUS, Inc.

UL Underwriters Laboratories USDOT United States Department of Transportation USEPA U.S. Environmental Protection Agency UST Underground Storage Tank VC Vinyl chloride VOCs Volatile Organic Compounds WMP Waste Management Plan viii

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1.0 INTRODUCTION

Tetra Tech EC, Inc. (TtEC) has prepared this Remedial Action Work Plan (RAWP) for contaminated groundwater at Site 8, Naval Station (NAVSTA) Newport, Middletown, Rhode Island under the Naval Facilities Engineering Command (NAVFAC) Mid-Atlantic Remedial Action Contract (RAC) N62470-13-D-8007, Contract Task Order (CTO) WE15. Site 8 is located within the Naval Undersea Warfare Center (NUWC) portion of the NAVSTA Newport facility, which lies within Middletown, Rhode Island. Site 8 occupies approximately 12.4 acres along the northern boundary of the NUWC grounds and includes the Building 179 Area (research facilities), the Building 185 Complex (paved storage area [PSA]), as well as undeveloped open fields and wooded areas, two shallow streams bounded by steep slopes, wetlands, and Deerfield Pond, also known as NUWC Pond. A Site Location and Vicinity Map has been provided as Figure 1.

NAVSTA Newport was formerly called the Naval Education and Training Center (NETC) and has been assigned U.S. Environmental Protection Agency (USEPA) ID Number RI6170085470.

This action will be performed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Executive Order 12580; and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The work scope addresses the groundwater remediation portion of the remedy as described and detailed in the Record of Decision (ROD), Operable Unit 7 (Site 8, Naval Undersea Systems Center Disposal Area) of the Former Naval Education and Training Center (NAVFAC, 2012), and the Remedial Design (RD) (Tetra Tech NUS, Inc. [TtNUS], 2016). All work will be performed following applicable and appropriate Department of Defense (DoD) guidance and policy for the Navy Environmental Remediation Program (ERP).

In accordance with the ROD, selected areas of Site 8 with elevated concentrations of chlorinated solvents such as trichloroethene (TCE) and 1,1,1-trichloroethane (TCA) in bedrock groundwater compounds will undergo in-situ, enhanced bioremediation. This RAWP addresses three locations at Site 8, identified on Figure 2, where groundwater will be treated: the North Meadow (Treatment Area A) adjacent to the NUWC Pond, Building 179 Area (Treatment Area C) in the southern portion of the site, and South Meadow (Treatment Area B) in the central area of the site.

2.0 WORK PLAN OBJECTIVE AND ORGANIZATION

The objective of this RAWP is to describe the proposed remedial action (RA) for the remediation of groundwater at Site 8. The remainder of this RAWP is organized in the following order.

• Section 3.0: Includes the site description and background

• Section 4.0: Describes the regulatory framework for this RA to meet the project objectives

• Section 5.0: Describes the pre-construction activities

• Section 6.0: Describes the implementation plan for site work

• Section 7.0: Presents the field sampling and laboratory analytical requirements

• Section 8.0: Presents the Accident Prevention Plan (APP)

• Section 9.0: Contains Environmental Protection Plan (EPP)

• Section 10.0: Describes the procedures for spill management and response

• Section 11.0: Contains Waste Management Plan (WMP)

• Section 12.0: Contains Contractor Quality Control Plan (CQCP)

• Section 13.0: Discusses the Construction Completion Report

• Section 14.0: Presents the references for documents used in preparing this RAWP

• Appendix A: Contains the Sampling and Analysis Plan (SAP)

• Appendix B: Contains the APP

• Appendix C: Contains the CQCP Documents

3.0 SITE DESCRIPTION AND BACKGROUND

NAVSTA Newport is located approximately 25 miles south of Providence, Rhode Island, on Aquidneck Island. The facility occupies approximately 1,000 acres, with portions of the facility located in the City of Newport and the Towns of Middletown, Portsmouth, and Jamestown, Rhode Island. The western boundary of NAVSTA Newport follows the western shoreline of Aquidneck Island for nearly 6 miles, facing the eastern passage of Narragansett Bay. A Site Location and Vicinity Map has been provided as Figure 1.

The NAVSTA Newport area has been used by the U.S. Navy since the Civil War era. Activities have increased during war times and later decreased as naval forces were reorganized. From 1900 to the mid-1970s, the facility was also used as a refueling depot. The Shore Establishment Realignment Program reorganization in April 1973 resulted in reductions in personnel, and the Navy excessed a large portion of the original facility acreage. NETC was subsequently established.

In the mid-1990s several new laboratories were constructed at the NUWC to provide research, development, testing, evaluation, engineering, and fleet support for submarines and underwater systems. In October 1998, NAVSTA Newport was established as the primary host command, taking over base operating support responsibilities from NETC.

NAVSTA Newport is an active military training facility and is expected to remain active for the foreseeable future. Forty-two Naval and defense commands currently operate at NAVSTA Newport, which is used for conducting advanced undersea warfare and development systems activities and is also one of the Navy's primary sites for training and education. The major commands currently located at NAVSTA Newport include the NETC, the Surface Warfare Officers School Command, the NUWC, and the Naval War College. Research, development, and training are the primary activities at the facility. Tenant commands include the NUWC, Naval Warfare College, Surface Warfare Officers School, Navy Warfare Development Command, Officer Training Command, Center for Service Support, Naval Academy Preparatory School, and Senior Enlisted Academy.

3.1 Site Location and Description

Site 8 is located within the NUWC portion of the NAVSTA Newport facility, which lies within Middletown, Rhode Island. Site 8 occupies approximately 12.4 acres along the northern boundary of the NUWC grounds and includes the Building 179 Area (research facilities), the Building 185

Complex (PSA), as well as undeveloped open fields and wooded areas, two shallow streams bounded by steep slopes, wetlands, and Deerfield Pond, also known as NUWC Pond. A low, concrete dam is present at the northern end of the 2-acre pond. A chain-link fence separates Site 8 from the Wanumetonomy Golf and Country Club to the northeast. A one-lane crushed gravel roadway runs along the Navy side of the fence and is used as a security patrol road as well as a walking/jogging path used by Naval Underwater Systems Center (NUSC) employees. A Site Detail Map has been provided as Figure 2.

3.2 Site Background

Site 8 was reportedly used for disposal of rubble and inert materials, including scrap lumber, tires, wire, cable, and empty paint cans. The NUSC disposal area consists of approximately 12.4 acres of land adjacent to two streams, associated wetlands, and a small (2-acre) pond. The upland portions have been used as fill and storage areas since the Navy developed the site in the early 1950s. Currently, there is a paved secured storage area and paved open storage area (approximately

2.3 acres), a research facility (Building 179 Area), as well as open fields (1.6 acres) and brush covered areas (4.2 acres). The current site use is industrial and will remain as such for the foreseeable future.

Contaminants in soil, groundwater, and sediment have been identified during past environmental assessments at Site 8. Specific records of materials spilled or disposed of since site operations began in the early 1950s are not available. However, it is known that the central, upland portion of Site 8 in the Building 185 area was used for equipment storage, temporary hazardous waste storage, and the disposal of miscellaneous materials including scrap lumber, tires, wire, cable, empty paint canisters, and drums containing a tar-like substance. Removal actions have been conducted for the paint canisters and buried drums.

The cause of the groundwater contamination present in the North Meadow is unknown, but likely is associated with the disposal of spent liquid solvents from past facility operations.

Several former NUSC operations also had the potential to generate hazardous materials (e.g., industrial plating, anodizing, and chemical cleaning in a former nearby building, as well as storage of polychlorinated biphenyls [PCBs] at an unknown location). The Building 185 Complex was also used to store torpedo fuels and, in 2004, a release of Otto Fuel, a monopropellant used to drive torpedoes and other weapon systems, was discovered and the impacted soil was removed.

Building 179 is a research and development facility that formerly housed a 2,000-gallon concrete underground storage tank (UST) used to collect byproducts generated from the torpedo propulsion system tests. This UST likely received wastewater mixed with engine oil, solvent-based cleaners, Otto Fuel, and combustion byproducts. In 1995, it was discovered that the UST had leaked, contaminating soil and groundwater in this area. A removal action was completed under the state’s environmental program and residual contaminants are being addressed under the CERCLA program.

Contaminants from these areas entered Deerfield Creek through overland stormwater runoff/soil erosion and groundwater transport, impacting sediment in the creek and in NUWC Pond.

Groundwater underlying NAVSTA Newport is not used for drinking water. Drinking water for NAVSTA Newport and most of the residents of Newport and Middletown is supplied and managed by the Newport Water Department. Groundwater flows to Site 8 from the undeveloped wetland to the south and from the golf course area to the east.

4.0 REGULATORY FRAMEWORK

NAVSTA Newport is an active facility, with environmental investigations and remedial efforts funded under the Navy’s Environmental Restoration program. The Navy is conducting its ERP at NAVSTA Newport in accordance with a Federal Facility Agreement (FFA) between the Navy, USEPA, and the Rhode Island Department of Environmental Management (RIDEM). The FFA established the Navy as the lead agency for the investigation and specified cleanup of designated sites within the NAVSTA Newport property, with USEPA and RIDEM providing oversight.

The ROD (NAVFAC, 2012) presents the Selected Remedy for Site 8. The Selected Remedy for Site 8 is a combination of soil Alternative S03 (soil cover, selective excavation and removal of anomalies, offsite disposal, land use controls [LUCs], and monitoring), groundwater Alternatives GW3/GW4 (in-situ enhanced bioremediation, LUCs/in-situ chemical oxidation, monitored natural attenuation [MNA], and LUCs), and sediment Alternative SD4 (sediment removal and offsite disposal).

The remedy was chosen by the Navy and USEPA in accordance with CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA), and, to the extent practicable, the NCP. The decision is based on information contained in the Administrative Record for the site.

RIDEM and USEPA concur with the Selected Remedy.

An Explanation of Significant Differences (ESD) has been prepared for Site 8 to modify the existing ROD, by adding asbestos as a contaminant of concern (COC) for soil only. This modification, signed on 9 February 2015, is significant as it adds a COC to be addressed; however, it does not alter the remedy selected in the ROD.

As presented in the ROD, the Selected Remedy incorporates the following elements of Alternative GW3, In-Situ Enhanced Bioremediation, MNA, and LUCs that will be implemented in accordance with this RAWP:

• Surface geophysical investigation of subsurface fractures that effect groundwater movement,

• Installation of an in-situ enhanced bioremediation system, and

• Operation and performance monitoring of the bioremediation system.

Other elements of the overall RA for Site 8 (including long term monitoring, LUCs, soil and sediment excavation and removal) are being addressed under separate cover. Other supporting elements of this RAWP include: the October 2016 Remedial Design for Groundwater and Sediment at Site 8 and the October 2013 Land Use Control Remedial Design prepared by TtNUS established to address LUC implementation actions, in accordance with the ROD.

4.1 Remedial Action Objectives

NAVSTA Newport remedial action objectives (RAOs) are media-specific goals that define the objective of conducting remedial actions to protect human health and the environment. RAOs specify the COCs, potential exposure routes and receptors, and acceptable concentrations by media (i.e., cleanup levels) for a site and provide a general description of what the cleanup will accomplish.

The RAOs are based on current and reasonably anticipated future site use, which is industrial/commercial. Although the site is not currently used for residential or recreational purposes and there are no plans for residential/recreational use of the property in the foreseeable future, Remediation Goals (RGs) for residential exposures were calculated in order to evaluate cleanup options that provide for unrestricted use and unlimited exposure of the property and to determine whether institutional controls are needed to control hypothetical future site uses.

The following RAOs for Site 8 groundwater serve as the design basis for the groundwater remedial alternatives evaluated for this Site:

• Prevent the use of site groundwater for human consumption until groundwater RGs have been achieved.

• Restore groundwater quality to its beneficial use.

These RAOs are based on current and reasonably anticipated future site use, which is industrial/commercial.

The groundwater RAOs will be achieved through a combination of treatment, MNA, long-term monitoring, and LUCs. LUCs have been implemented (Navy, 2013) to prevent the use of site groundwater until RGs are achieved inside of the compliance boundary established for the Waste Management Area (i.e., the PSA). The RGs for groundwater at Site 8 are provided in Table 1.

The limits of groundwater contamination above RGs are shown on Figure 3.

5.0 PRE-CONSTRUCTION ACTIVITIES

Pre-construction activities consist of developing required plans, initiating procurements, and conducting a pre-construction meeting.

5.1 Work Plan Documents

All plans will be submitted for approval prior to commencing field work, including the RAWP, CQCP, APP, and EPP. Regulatory and NAVSTA Newport-specific environmental requirements have been incorporated into to this RAWP.

5.2 Permitting Considerations

5.2.1 Underground Injection

Substantive requirements for injection of chemicals into the subsurface must be met (Registration of Discharges to Class V Injection Wells). The injection of chemicals into the subsurface is regulated under the Underground Injection Control Program (RIGL Ch. 46-12, 46-13.1). To ensure that the substrate injection complies with the substantive requirements of these regulations, the anticipated quantities to be injected have been included in the design and submitted to USEPA and RIDEM for comment and concurrence. The performance monitoring program will assess the impact of the injected substrate.

5.2.2 Effluent Discharge

As described in Sections 6.5 and 6.6, a portion of the treated groundwater from Building 179 Area and possibly the South Meadow Area, will be discharged to surface water to achieve hydraulic control of the in-situ bioremediation system. Section 6.5.2 discusses the substantive requirements of the Rhode Island Pollutant Discharge Elimination System (RIPDES) Remediation General Permit, which includes and Notice of Intent (NOI), water quality requirements, effluent monitoring and reporting requirements, and system operation requirements. Coordination with the RIDEM Office of Water Resources is required to ensure that the Navy complies with the substantive requirements of the permit at least 90 days prior to effluent discharge.

5.2.3 Navy Facility Engineering and Acquisition Division Approvals

The following permits for on-site activities will be submitted to NAVSTA Facility Engineering and Acquisition Division (FEAD) for approval, if required:

Dig Permit Outage Permit Photography Permit Computer Permit

Additional permits may be required and will be applied for once identified.

5.3 Procurement

Upon approval of the RAWP, procurement for all necessary equipment, materials, and subcontractors required to implement the RAWP will be initiated. It is anticipated that subcontractors will provide services for geophysical surveys, land survey, well installation, well pump tests, waste disposal, utility location, remediation supplies, and equipment rental.

5.4 Pre-Construction and Mutual Understanding Meeting

A pre-construction meeting will be conducted at NAVSTA Newport prior to starting work. The following items will be discussed with Remedial Project Manager (RPM), Navy Technical Reviewer (NTR), and other stakeholders at the pre-construction meeting:

• Overall approach to site work

• Access/security requirements

• Schedule and specific tasks included

• Review of RAWP and associated documents

5.5 Subsurface Utility Location

Underground utilities (storm drains and buried fiber-optic cable) and overhead utilities (electric and fiber-optic cable) are present within the Site limits. Prior to well installation, Dig Safe (811) will be contacted for utility clearance and mark out. A private, professional utility locating service will also be contracted to provide a subsurface utility survey.

6.0 SITE WORK

This RAWP includes tasks related to the selected remedy for groundwater at Site 8, in-situ, enhanced bioremediation. With the exceptions of activities stated in this RAWP, work will be completed in accordance with the RD (TtNUS, 2016). Definable features of work (DFOWs) incorporate both health and safety requirements and quality control (QC) inspections.

This RAWP includes the following DFOWs.

Mobilization and Site Preparation Geophysical Surveys and Well Installation Baseline Groundwater Sampling Installation and Operation of In-Situ Enhanced Bioremediation System for Groundwater Remedy Performance Monitoring Decontamination and Demobilization

6.1 Mobilization and Site Preparation

Mobilization and site preparation activities include transportation of personnel, as well as equipment, materials, instruments, and supplies to the site; and other services required to implement the RA. Mobilization will commence following receipt of a Notice to Proceed from the Navy.

6.1.1 Coordination with NUWC Operations

Site 8 includes portions of NUWC that are active operational areas (i.e., the Building 179 Area, the Building 185 Complex, and the PSA). Onsite personnel will coordinate with the NUWC

Operations Manager to minimize disruption to Navy activities. Site access will be coordinated with the NUWC Security Office. It is anticipated that there may be some restricted work periods (e.g., during designated Hazards of Electromagnetic Radiation to Ordnance [HERO] conditions in the vicinity of the Building 179 Area).

TtEC will coordinate with the NUWC Operations Manager and meet all requirements for the following:

Personnel access and badges.

NUWC security requirements, including prohibition of the use of photographic equipment, cellular phones containing photographic capabilities, and use of certain electronic equipment (including certain computers).

Work hours (must be approved prior to commencing any activities).

Work area locations, including laydown areas, stockpile areas, and truck routes.

Any activities in the PSA, including movement of NUWC equipment.

As a result of security requirements, NUWC mission activities, and restricted work periods, work stoppages may occur during remedial activities.

6.1.2 Base Access

In order to access the base, workers must be United States citizens, and provide a date of birth, place of birth, social security number, full name, and company name to our Base sponsor. The Base currently operates on a J-Pass system. Passes are obtained at Building 500. Personnel in Building 500 can be reached by phone at 860-964-4030 to obtain additional information regarding a pass for Base access. No drugs, alcohol or firearms are allowed on Base. All vehicles are subject to search.

6.1.3 Work Hours

Work hours for remediation activities are between 0700 and 1700 hours, Monday through Friday, unless otherwise directed by the Navy. Equipment, supplies, and materials will be received during the defined work hours.

6.1.4 Material Storage and Equipment Laydown Areas

TtEC will use a Navy-approved staging area for the duration of the construction activities. The staging area is assumed to be in the PSA in the southern portion of the site. A site trailer has been positioned in the PSA; temporary electric service will be provided. Portable sanitary facilities will also be mobilized to the site for use by field personnel. Field personnel will use cell phones as a means of communication. The PSA is gated and fenced; however, security of equipment and supplies will be maintained by locking the field trailer and securing equipment and supplies in one place each day. All equipment will arrive at the site pre-cleaned and ready for use.

6.1.5 Erosion and Sediment Control

Erosion and sediment control measures are not required for the groundwater remediation activities.

6.2 Additional Refinement Activities

Additional refinement activities, designed to provide a better understanding of the subsurface groundwater flow, include surface geophysical surveys of subsurface fractures and well installation and pump testing. Based on the results of the geophysical surveys and pump testing the groundwater treatment configurations for the North Meadow (Treatment Area A), South Meadow (Treatment Area B), and Building 179 Area (Treatment Area C) may be modified.

6.2.1 Surface Geophysical Surveys

Surface geophysical surveys will be used to investigate possible bedrock fractures at Treatment Areas A, B and C. Based on the results of the surveys, remediation system wells and monitoring wells may be placed for more effective plume treatment and monitoring.

Surface geophysical surveys will be conducted to investigate depth to bedrock and possible bedrock fractures along ten profile lines, ranging from 115-300 feet in length. Seismic refraction tomography (SRT) has been selected as the most appropriate method for the site, based on the desired depth of penetration and numerous site constraints, including infrastructure, deep well casings, and surface modifications (parking lots, roads, riprap, and vegetated areas), especially those in areas of particular interest. The seismic data provide good definition of depth to bedrock and can identify zones with lower seismic velocities that can be indicative of fracture zones.

SRT data acquisition requires placement of equally spaced geophones in the ground and measuring their response to sledge hammer blows with data acquired on an engineering seismograph. The sledge hammer blows, to a steel plate approximately 1-foot square, are repeated at incremental positions along the line of geophones. The travel times from hammer to each geophone are measured and analyzed using the Rayfract commercial software package from Intelligent Resources Inc.

The seismic method presents no hazard or damage to the terrain, and leaves no permanent effect on the surface along the profile lines. Where lines cross pavement or asphalt, geophones will be mounted on small steel plates resting on the surface. Line and sensor locations will be determined with a post-processed differential global positioning system (GPS) to provide a nominal positioning accuracy of 2 m. Survey flags and markers will be removed upon completion and verification of positioning measurements. Locations on concrete or asphalt will be marked with marker paint.

Products of the project will include all processed profile lines for both systems with geopositioning data and a final report which will include description of procedures, field parameters, acquisition or processing issues, interpretation and recommendations. If the results of the geophysical survey indicate the potential for bedrock fractures, then the remediation wells will be placed in those areas. If the survey does not indicate the presence of fracture areas, then the wells will be placed as indicated in the RD.

6.2.2 Well Installation and Testing

Based on the results of the surface geophysical survey and consultation with the Navy, EPA and RIDEM, final well locations for new injection wells will be determined. A professional driller will be subcontracted by TtEC to install the wells. Preliminary well locations, installation characteristics, and pump tests to be performed at Treatment Areas A, B, and C are provided in the subsections below.

Pump tests will be performed at each treatment area on the planned extraction wells to confirm hydraulic connections. Pressure transducers will be utilized during the performance of the pump test to continuously monitor the groundwater levels in each well. Extracted groundwater will be treated with granular activated carbon (GAC) prior to discharge. For each pump test, the GAC unit influent, mid-point, and effluent will be sampled in accordance with the substantive requirements of the RIPDES Remediation General Permit and discharge limits listed in Table 2.

TtEC assumes that analyzing for the compounds listed in Table 2, and not the entire list presented in the RIDEM Remediation General Permit, will be sufficient to meet these requirements.

Sampling and analytical testing requirements are provided in Section 7.0 and detailed in the SAP (Appendix A).

6.2.2.1 Well Installation and Pump Testing for North Meadow (Treatment Area A)

The locations of six (6) additional injection wells (NIW-1 through NIW-6 are shown on Figure 5.

Four additional injection wells are located north of well NRW and two wells are located south of well NRW. The wells will be constructed as 2-inch-inside diameter (ID) open boreholes with the upper steel casing cemented into the formation. Total depth of the new injection wells will be approximately 45 feet, which is the expected maximum depth before intercepting the high yield fracture zone identified during the Remedial Investigation (RI) and Supplemental Remedial Investigation (SRI) (TtNUS, 2010 and 2011). The wells will have 1-foot high steel casing stick-ups above grade and 2 inch male pipe threaded connections to attach the temporary injection piping. The construction details for the new 2-inch ID injection wells are shown on Figure 6. The driller will develop the wells following installation.

A brief, no more than 5-hour pump test will be conducted between extraction well NRW and the six new injections wells to confirm a hydraulic connection between new injection wells and the pumping well NRW. If required, the pump test will extract up to 40 gallons per minute (gpm) of groundwater from well NRW; the water will then be treated with GAC and discharged to the NUWC (Deerfield) Pond. This pump test may not be needed if a hydraulic connection between new injection wells and the pumping well NRW is confirmed during the injection wells development.

6.2.2.2 Well Installation and Recovery Testing for Building 179 Area (Treatment Area C)

The locations of existing wells and wells to be installed in the Building 179 Area (Area C) are shown on Figure 7. The new remediation wells listed below will be constructed as open boreholes with the upper steel casing cemented into the formation. The new remediation wells will have approximately 1-foot high steel casing stick-up above grade and male pipe threaded connections to attach the injection piping shown on Figure 8. The wellheads of the existing monitoring wells MW-124B and MW-101B will be modified to allow for the reinjection of extracted groundwater.

The following will be performed:

The existing 4-inch monitoring well MW-129B will be converted into a 6-inch diameter pumping well by over-drilling the existing well borehole, as shown on Figure 8.

The existing 4 inch monitoring well MW-7B will be converted into a 6-inch diameter injection well by over-drilling the existing well borehole as shown on Figure 8.

Two (2) additional locations, IEW-1 and IEW-2, will be installed between MW-129B and MW-7B (Figure 7) for potential use as injection wells. IEW-1 and IEW-2 will first be installed to depth of 40 feet as 2-inch ID open boreholes. Then the yield of these two wells will be immediately assessed. If the recovery well test shows a sustained yield of at least

0.75 gpm, then the borehole diameter will be enlarged to 6 inches to a depth of 50 feet below ground surface (bgs); the final construction will be similar to that shown for MW- 7B (Figure 8, with the exception of total depth). If the test well shows lower yield, then it will be assumed to be insufficient for substrate injection and will be properly abandoned (grouted). Any well testing water generated will be treated with GAC, sampled as required, and discharged to Deerfield Creek.

6.2.2.3 Well Installation and Pump Testing for South Meadow (Treatment Area B)

The hydrogeological conditions in the South Meadow (Treatment Area B) were only partially evaluated during the Pre-Design Investigation (PDI) performed in March 2015.

Install two (2) additional remediation wells IEW-3 and IEW-4 (Figure 9). The wells IEW- 3 and IEW-4 will first be installed to depth of 40 feet as 2-inch ID open boreholes. The groundwater yield of these two wells will be immediately assessed. If the well shows a sustained yield of at least 0.75 gpm, then the borehole diameter would be enlarged to 6 inches and a depth of up to 50 feet bgs, and finished with an approximately 1-foot high steel case stick-up above grade and male pipe threaded connections to attach the injection piping as done for injection wells in Area 179 (Figure 8, with the exception of the total depth).

Perform a recovery test by evacuating the well volume and measuring the rate of groundwater recharge for the following wells: IEW-3, IEW-4, MW-102B, MW-103B, MW-103S, MW 104B, and MW 105B.

If the recovery test on any well demonstrates a potential yield of greater than 0.75 gpm, then an extended (72 hour) pump test will be performed using the highest yielding well as a pumping location and the remaining observation wells as monitoring locations. Water discharged from the pump test will be treated with two 250-pound GAC vessels connected in sequence. There will be a mobile generator as a source of electrical power (capable of running 72 hours uninterrupted). Treated groundwater will be discharged into the Deerfield Creek via a temporary aboveground line (with influent/effluent sampling for COCs in accordance with RIDEM regulations). Submersible pressure transducers placed in the monitoring wells will measure hydraulic response continuously throughout the test.

These results will be evaluated to determine if an RD similar to Treatment Area A (higher hydraulic conductivity, e.g. greater than 15 gpm with a rapid response between wells) or Treatment Area C (low hydraulic conductivity) can be implemented.

6.2.3 Site Surveying

TtEC will subcontract a professional land surveyor (PLS) to survey the horizontal and vertical locations of newly installed wells and any newly installed long-term site features. These will locations will be included on figures in the Construction Completion Report (CCR).

6.3 In-Situ Enhanced Bioremediation of Groundwater Overview

At Site 8, anaerobic reductive dechlorination of chlorinated COCs in the groundwater will be enhanced with the addition of an electron donor substrate. The intent is to accelerate the naturally occurring reductive dechlorination of TCE in groundwater in the North Meadow to dichloroethene (DCE), followed by vinyl chloride (VC) to ethene and, to reductively dechlorinate chlorinated alkanes, such as TCA found primarily at Building 179 and in the South Meadow, to dichloroethane (DCA), followed by ethyl chloride and eventually to ethane.

The implementation of in-situ enhanced bioremediation at three groundwater treatment areas in Site 8 (North Meadow (Treatment Area A), Building 179 Area (Treatment Area C), and South Meadow (Treatment Area B)) will include:

Installation of injection wells and extraction pumping wells to create a confined distribution of injected substrate

GAC carbon treatment of groundwater extracted and either re-injected or discharged Installation of temporary aboveground lines between GAC treatment system to injection and extraction wells Distribution of an electron donor substrate (sodium lactate) in to the groundwater via re-circulation Operational and performance monitoring of the substrate, COCs, electron acceptors and their by-products, and microbial populations.

Depending upon the results of substrate circulation in the subsurface and the performance monitoring results, additional rounds of substrate and/or microbial bioaugmentation injections, modified for the resultant groundwater conditions may be proposed to the Navy at each Treatment Area. If there is no reduction of COCs in the groundwater following bioremediation, chemical oxidation may be proposed as a remedial alternative and the injection/pumping configuration revised as appropriate for the new substrate.

6.3.1 Microbial Population Monitoring

As part of the monitoring process, the presence of a dechlorinating bacterial population will be analyzed to determine if bioaugmentation, by injection of additional dechlorinating bacterial cultures, such as Dehalococcoides species (DHC) into the subsurface is needed to boost the level of microbial activity. Microbial population monitoring requirements are further discussed in Section 7.0 and the SAP (Appendix A). If, after the final post injection monitoring event, groundwater in monitoring wells that has received sodium lactate has the DHC functional gene concentrations that are less than 104 DHC/liter, then bioaugmentation will be considered. This concentration of DHC should be sufficient to provide adequate degradation rates.

6.3.2 Electron Donor Substrate (Sodium Lactate)

In the presence of a suitable electron donor (e.g., hydrogen from an organic substrate), the appropriate microbial consortia, and favorable geochemical conditions, a hydrogen atom can replace a chlorine atom on a chlorinated ethene molecule in the TCE reductive dechlorination series. Hydrogen is typically generated when an organic carbon electron donor substrate is fermented and the fermentation process will be enhanced with the addition of the substrate. Per the RD recommendation to prevent clogging of bedrock fracture by initially avoiding a vegetable oil substrate, sodium lactate will be used for the proposed injection events at Treatment Areas A, C, and B. Sodium lactate (Appendix F of the RD a description of and material data safety sheet [MSDS]) for WILCLEAR®, a sodium lactate product manufactured by JRW Bioremediation LLC) is a completely soluble substrate that will not clog bedrock fractures, will not cause a sheen, and will be quickly consumed if released to surface water. Based on the results of the first injection event, the need for subsequent substrate injection events will be evaluated, as well as, whether changing the lactate substrate to a slow-release substrate or a combination slow-release and fast-release substrate is warranted. A possible alternate combination substrate is LactOilTM, which is a combination of a slow-release soy vegetable oil (45 percent) and a fast-release soluble ethyl lactate (35 percent).

The quantity of the electron donor substrate, sodium lactate, to be injected at each Treatment Area, is based on the electron donor demand. The sum of electron acceptors including contaminant mass demand plus the demand of other geochemical species such as ferric iron (Fe+3), nitrates (NO3-), and sulfate (SO4-2), was estimated in the RD. Sulfate concentrations in the Site 8 groundwater are much higher than the concentrations of other electron acceptor such as chlorinated volatile organic compounds (CVOCs), ferric iron, and nitrate. Thus, sulfate concentrations were used to calculate total electron donor demand as sodium lactate. The total sulfate mass in each Treatment Area was estimated using the average sulfate concentrations in groundwater and estimated pore volumes.

6.4 Remedy Implementation - North Meadow (Treatment Area A)

Remedial activities required to implement the in-situ enhanced anaerobic biodegradation of COCs in North Meadow, Treatment Area A, are as follows:

Make adjustments to RD operating parameters based on pump test results, if needed. Any changes will be reviewed and approved by the Navy.

Construct a groundwater recirculation system that includes aboveground piping, GAC units connected to equipment, extraction well NRW and seven (7) injection wells NIW, and NIW-1 through NIW-6 as shown in Figure 10 and detailed in the RD. If TtEC’s subcontractor proposes modifications to the system in the RD, those modifications will be submitted to TtEC for approval by the Navy.

Conduct initial baseline groundwater sampling for locations listed in Table 4 prior to injection of substrate to establish baseline concentrations of substrate as Total Organic Carbon (TOC), Volatile Organic Compounds (VOCs), 1,4-dioxane, metals, microbial populations, dissolved gases, and general chemistry parameters per the requirements listed in Section 7.0 and the SAP (Appendix A).

Preliminary testing of the pumping and recirculation set-up to ensure it functions properly prior to adding the substrate. Procedures include: activating well pump WP-1, and adjusting the pumping rate to approximately 25 gpm using valve V-1 and flowmeter FM-

1. Based on the PDI pump test results, the expected, sustained pumping rate from NWR should be 20 to 30 gpm.

Collect a baseline TOC sample from the well pump discharge. Reagent sets (e.g., Hach® or similar) and a colorimeter will be used to test for real time TOC concentrations. Both low range and high range reagent kits will be used, as needed.

Implement the injection of substrate, sodium lactate, following remedial design parameters listed in Section 6.4.1 that may be modified by the pump test (Section 6.2.2.1) results.

Collect TOC samples from the well pump discharge and from the first GAC vessel outlet (sampling port SP-2) twice a day as recirculation continues. The concentration of TOC will be used to evaluate the presence of sodium lactate substrate. Reagent sets (e.g., Hach® or similar) and a colorimeter will be used to provide real time analyses of TOCs. Both low range and high range reagent kits will be used, as needed.

Table 3 presents additional sampling that will be performed during the injection, including sampling for the Site COCs.

In order to evaluate whether substrate injections are impacting the pond, collect TOC samples from three piezometers (PZ-1, PZ-2, and PZ-3) installed at the edge of the NUWC Pond prior to substrate injection and daily during re-injection of groundwater for real time analyses as recirculation continues as detailed in Table 3.

Re-inject 100% of the treated groundwater with sodium lactate into the injection wells (NIW-1 through NIW6).

Recirculate groundwater between the recovery well, NRW, and the injection wells, NIW- 1 through NIW-6, in a closed-loop configuration until a uniform substrate distribution has been achieved.

As the distribution of substrate, sodium lactate, in the subsurface formation becomes more uniform, the TOC results from groundwater collected from the well pump discharge port, are expected to stabilize. At this point recirculation can be stopped. Alternatively, recirculation will be stopped when TOC concentrations at the first GAC vessel effluent (sampling port SP-2) exceeds 10 milligrams per liter (mg/L) (sodium lactate breakthrough).

The expected groundwater recirculation duration is 3 - 4 days, based on continuous operation (24 hours/day). The injection equipment is designed for an automatic, unmanned operation.

Review the results of the first injection phase with sodium lactate and make adjustments as needed. Adjustments could include, but are not limited to: changing the substrate, bioaugmentation of microbial population, and changing extraction flow rate.

After the injection and recirculation system has been shut off, the performance monitoring schedule at 1, 3 and 6 month intervals will be followed, as detailed in Section 7.0 and the SAP (Appendix A).

After completion of the first round of bioremediation, review results with the Navy and determine if an additional round of substrate injection is warranted.

6.4.1 Remedial Design Parameters for North Meadow (Treatment Area A)

Based on the RD, 125 gallons of sodium lactate, as a 60% solution, will be added to the injection wells over an estimated 3.3 days of recirculation time.