FINAL_SOW_Impacted_Soil_Remediation_20150612.pdf

STATEMENT OF WORK

FOR IMPACTED SOIL REMEDIATION

DEVIL’S POSTPILE NATIONAL MONUMENT

P15PS00694

1. INTRODUCTION. By executive order 12580, as amended by EO 13016, the President has delegated response authority under Section 104 of the Comprehensive Environmental Response Compensation, and Liability and Act (CERCLA) 42 U.S.C. § 9604 to the National Park Service (NPS). Pursuant to its delegated authority, NPS is the CERCLA “lead agency” as defined by the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) 40 C.F.R. Part 300 for response actions where the release or threatened release of hazardous substances is on any facility under the jurisdiction, custody, or control of the NPS. Based on this authority, the NPS has prepared this Statement of Work for a non-time-critical removal action for a Site located within Devil’s Postpile National Monument (DEPO). This document is part of Phase 3b of “Response Action Implementation” being conducted at the Site by NPS, and is in compliance with the requirements of CERCLA and the NCP. The NPS is exercising its authority as lead agency under CERCLA to undertake response activities as set forth herein at the lead-based paint impacted area (Site) within DEPO (a.k.a., the Park). The response activities are following the non-time-critical removal action process, which included the preparation of an Approval Memorandum, Engineering Evaluation/Cost Analysis (EE/CA), public participation component, and Action Memorandum.

2. BACKGROUND.

2.1. In 2005, lead-based paint chips were deposited in the immediate vicinity of a 100,000-gallon potable water storage tank (WST) during sandblasting maintenance activities, performed as part of a lead-based paint abatement project , which included repainting of the tank’s exterior. The Site addressed by this removal action encompasses the 15 feet radius around the exterior of the WST.

2.2. In 2008, Provost and Pritchard Consulting Group (P&P, 2008)1 conducted a preliminary assessment (PA) for potential lead impacts to surficial soil at the Site. NPS concluded that additional work was necessary to address lead contamination to surficial soil at the Site.

2.3 In 2013, Environmental Cost Management, Inc. (ECM) reviewed the data from the PA report and prepared a Work Plan for Soil Sampling2 to perform surficial soil sampling using incremental sampling methodology (ISM) to facilitate the preparation of an EE/CA for the Site.

ECM implemented the Work Plan activities in July 2013, and the results were presented in the Site EE/CA Report3. The report found that lead concentrations within 15 feet of the WST exceeded recommended standards for ecological effects.

1 Provost and Pritchard Engineering Group, Inc. Preliminary Assessment for the National Park Service, Devils Postpile National Monument, prepared for Sequoia and Kings Canyon National Park, Three Rivers, California. October 2008.

2 Environmental Cost Management, Inc., Work Plan for Soil Sampling Lead Impacted Soil near Potable Water Tank at Devils Postpile National Monument, Madera County, California. June 17, 2013.

3 Environmental Cost Management, Inc., Engineering Evaluation/Cost Analysis Report, Devils Postpile National Monument, Lead Impacted Soil at Potable Water Tank, Madera County, California. March 21, 2014.

3. Scope.

3.1.1 General. The objective of this Statement of Work (SOW) is to define the procedures and protocols required to proceed with a targeted soil removal action at the Site, and restoration of the Site to a natural condition. The Contractor shall submit a technical and cost proposal to perform all the requirements of this SOW to successfully complete the project with exception of those tasks specifically identified as the responsibility of the NPS or an NPS-designated representative.

3.1.2. Work shall be performed under project-specific plans, developed by the Contractor. The plans and work shall conform to U. S. EPA document “Guidance on Conducting Non-Time Critical Removal Actions Under CERCLA”. No on-site treatment of hazardous substances is allowed on park land.

3.1.3. The Contractor shall furnish all construction services, materials, supplies, labor, equipment, investigations, studies, superintendence, and travel, as required, for completing the tasks.

3.1.4. The Contractor shall, without additional expense to the government, obtain any necessary licenses, permits, and shall comply with all federal, state, and local laws, regulations, rules, and codes applicable to the performance of the tasks required for this SOW.

3.1.5. The Contractor shall provide a Project Manager (CPM) for the project. The CPM shall be responsible for technical oversight of the work, preparation of invoices, monitoring of budgets and schedules, and maintaining timely and appropriate communication with the NPS Project Manager. The CPM shall be supported by professional and skilled technicians with experience in performing tasks/activities for the project as specified in this SOW.

3.1.6. The NPS will administer the contract and project management, as needed. NPS will provide all available documents relating to the project, as needed, upon contract award. NPS is responsible for and has completed the NEPA (National Environmental Policy Act) compliance actions for the site.

3.1.7. All truck traffic and vehicle routes shall be coordinated with the NPS officials to establish safe and coordinated plans to minimize impact on park operations. Vehicles (or vehicle and trailer) larger than 37 feet in length are not allowed on the DEPO access road. Transport of the estimated 30 yards of contaminated soil shall use vehicles that conform to this size limit.

3.1.7.1. Access to the remediation Site is via approximately 500 feet of steep, rough, unimproved road leading from the staging area. Vehicle size and weight limits on this road shall be equivalent to a Bobcat 5600 AWD 4x 4 that the monument currently uses to access the site.

This can be minimally graded to improve access and any excess soils generated will be stored and used for backfill.

3.1.8. At the top of the access road, the Contractor shall protect the water line and valve box from damage. Trucks must not travel on or over the water line and valves. The road can be widened up to 5 feet in this area to facilitate better protection of the waterline.

3.1.8.1In the event of damage to the water line and/or associated water distribution and containment, the contractor is responsible for providing 500 gallons of bottled drinking water in 1 liter bottles for the public at the Ranger Station within 2 hours of the break, and ensure that 500 gallons of the above specifications are available until the water system is operation again. In addition, a water unit containing 1000 gallons must be available in 12 hours. The contractor shall provide portable toilets for the day use area (6), campground (6) and employee housing area (2) within 12 hours. Handwash stations shall also be available at all sites. The contractor is responsible for all flushing, decontamination, and restoration for water system operations in compliance with the CA Department of Water Resources (CADWR) requirements. Once the CADWR at monument water distribution system operator determines the water system is safe and functional, water operations may return to routine operations. The contractor will be responsible for the removal of the portable toilets and wash stations, and clean up associated with the emergency operations.

3.1.9. The contractor shall insure that haul truck covers and proper vehicle decontamination and tracking control is operational so that contamination is not spread outside of the work area during operations and transport. Appropriate stormwater pollution prevention measures need to be in place such as drainage swales and/or silt fencing to minimize erosion and movement of soil during storm events, excavation, and soil handling activities.

Fugitive dust emissions will be eliminated by laying down water spray during excavation and movement of soils, and will conform to the CCR and applicable EPA regulations on earth moving activities in non-containment areas.

Contractor is not permitted to travel beyond the construction site for any purpose

3.1.10. With consultation and approval with the NPS Project Manager the contractor may be able to move materials around on the staging area site to facilitate material storage, although the fire hydrant, pump station and recycling container must remain accessible. Use of the fire hydrant water may be allowed on a limited basis dependent of the needs of the monument. If there is any damage from use of the monument hydrant or water system the contractor is responsible for a timely repair.

3.1.11. Restoration to Natural Condition.

3.1.11.1. Finish grading and cleanup shall be limited to that necessary to return the area to its natural condition and will control surface erosion. Up to 30 yards of native pumice soils located at the staging area (1500 feet) will need to be transported to the Site to backfill the excavated area. The Park Representative will provide guidance as to the acceptable regarding and compaction to meet preexisting topographic conditions.

3.1.11.2. Disturbance of existing vegetation shall be minimized. The park will be responsible for final revegetation.

3.1.11.3. Per approval of the Park Representative, other excavated areas may be reconditioned using park soils.

4. Statement of Work. The procedures/activities associated with the soil removal and lead recovery would include the following tasks:

4.1. Task 1. Prepare Schedule and Conduct Conference Call. A schedule of activities shall be prepared and submitted to the NPS upon award of the contract.

4.2. Task 2. Prepare Project Plans/Action Plan, Site Specific Health and Safety Plan, and Sampling and Analysis Plan (for confirmation sampling). Provide activities and procedures/methodologies for all of the proposed field activities. The Health and Safety Plan shall include measures to protect personnel and the public from lead exposure such as PPE, air monitoring, hygiene, medical surveillance, etc. The contractor shall prepare and submit for review a sampling and analysis plan (SAP) (draft, draft final, and final) which follows the attached SAP Template for the field activities described below. The SAP must be approved by the NPS before the contractor undertakes any field work. The Plan will include sections specifying the objectives, schedule, administrative and logistical requirements, and will include a sampling plan specifying the locations, types, and number of samples and field and laboratory procedures. The plan will include sections describing measures that the Contractor will follow to manage investigation-derived wastes. Pre project planning shall also include a stormwater and hazardous material spill prevention plan and an emergency drinking water plan for monument visitors and staff that require an average of 1500 gallons of potable water per day.

The stormwater and hazardous material prevention plan must also provide for a plan of how to immediately respond to the campsites that are approximately 100 feet downslope of the Site.

4.3. Task 3. Excavation.

4.3.1. Excavation activities should be performed during the dry part of the year. Excavation of contaminated soils shall not be conducted during severe weather conditions (i.e. heavy rain and/or winds). Soils at the Site are comprised of pumice and the excavation site should be periodically moistened to decrease the potential for air dispersal of the contaminated soil. The contractor is responsible for providing an on site source of water for dust abatement. Use of the fire hydrant water or other water source may be allowed on a limited basis dependent of the needs of the monument.

4.3.2. Prior to excavation, the Contractor shall complete and perform all notifications, permits and compliance requirements to ensure a safe removal project. The excavation area shall be demarcated as a safe work zone, including delineation of wetlands and utility clearances and The Contractor is required to coordinate with NPS, local, and state officials on all necessary activities.

4.3.3. Prior to excavation, the Contractor shall evaluate the EE/CA report and, if necessary, perform additional soil sampling at the impacted area to determine the metal concentrations within the area for total lead via SW-846 Method 6010B.

4.3.4. The proposed soil remediation activities comprise removing shallow soils from the impacted area. The excavation of the soil from the impacted area shall be performed to a depth of 4- 6 inches below the surface, or as needed to remove contamination. The soil removal areas are shown on Figure 9 of the Environmental Evaluation and Cost Analysis (EE/CA) document.

Once removed, the removal of impacted soil shall be documented with confirmation samples collected from soil beneath and adjoining the excavated areas.

4.3.5. The impacted soil shall be transported to and placed in approved roll-off boxes or stockpiled on thick plastic sheeting on an impervious pad, and immediately covered to protect it from the elements (wind and/or rain) with similar plastic sheeting for temporary site storage prior to transport and disposal at a licensed facility. A licensed transport, storage, and disposal (TSD) company, in good standing with the State of California, shall be utilized. The prime contractor shall be responsible for verifying the TSD company’s credentials. The waste manifest/bill of lading shall be sent to the Park within two weeks of disposal.

4.3.6. The Contractor is responsible for cleaning the entire impacted area of debris. In order to control the area of contamination, the Contractor shall not, at any time, extend or stock-pile the contaminated soil outside of the safe work area zone.

4.3.7. Confirmation soil samples should be collected along the bottom of every 20 linear feet of excavation sidewall, or every 400 square feet of non-linear excavation. Side wall and end wall samples should be collected using the same parameters; a minimum of five (5) samples should be collected to document completion of cleanup.

4.3.8. The EE/CA established a Site removal action objective (RAO) for lead concentrations of 195 mg/Kg.

4.3.9. Soil samples for lead should be collected to document cleanup of soil to concentrations at or less than 195 mg/kg. Samples should be analyzed for total lead content using EPA Method 6010B. The analytical laboratory must be California certified to perform the analyses.

4.3.10. Pre-disposal characterization sampling of excavated soil can comprise one, four-point composite of stockpiled soil. It is estimated that approximately 30 cubic yards of soil will need to be excavated at the Site. Cleanup confirmation samples should be analyzed for total lead content using EPA Method 6010B. Disposal characterization samples should be analyzed for total lead using the Soluble Threshold Limit Concentration (STLC) and Toxicity Characteristic Leaching Procedure (TCLP) methods. The impacted soil should be protected from wind, rain or runoff until removed from the Site. Impacted soil will need to be disposed at a Resource Conservation and Recovery Act (RCRA) landfill licensed to accept lead-contaminated waste. Documentation of transport and disposal must be retained for the record of cleanup, and included in the report documenting cleanup.

4.3.11. The prospective analytical and sampling requirements for the constituents of concern are summarized in the attached table 1, Requirements for Containers, Preservation Techniques, Sample Volumes, and Holding Times.

4.3.12. Collection and analysis of confirmation samples following removal of lead-contaminated soil. A sufficient number of samples shall be collected to insure that clean soil conditions have been encountered. Samples shall be analyzed for total lead. Sampling software such as “Visual Sampling Plan” or other site sampling programs should be utilized as deemed appropriate.

4.3.13. Note: Field sampling technology per EPA approved methods (e.g., XRF) may be used during soil removal activities to provide real time analysis for lead to determine if clean conditions have been encountered to aid in directing field operations. Confirmation samples shall be submitted to a laboratory for lead analysis per the appropriate EPA method.

4.3.14. Upon completion of the excavation, the Contractor shall test, confirm, and document the successful contaminate removal. Use a 24-hour turn around so we may verify test results confirm that the results are at or below 195 mg/kg.

4.4. Task 4. Composite Sampling. Composite samples shall be collected and submitted to a contract laboratory for analysis of TCLP lead. These samples will characterize the soil for disposal as required by the disposal facility.

4.5. Task 5. Site Survey. Not used.

4.6. Task 6. Meetings/Conference Calls. The contractor shall attend a preconstruction meeting at the park prior to the commencement of field activities and a closeout meeting following completion of field activities. The contractor may be required to attend up to three or more conference calls to coordinate/facilitate the work of this project.

4.7. Task 7. Reports. Summary written reports (draft and final) shall be prepared detailing activities performed, figures showing site features and sampling locations, site photographs (Photographs. Photographs shall be taken of the Site and surrounding area prior to, during, and after the removal of soil from the range), results, conclusions, recommendations and “lessons learned”. The draft report shall be submitted within 30 days following the completion of field activities to the Contracting Officer. The final report shall be submitted within 10 days of receiving comments from the NPS. The final report shall be submitted to the Contracting Officer.

4.8. Task 8. Final Inspection & Closeout.

4.8.1. Prior to request for final inspection, the Contractor shall submit copies of sampling results from the testing laboratory, manifests and certificates of disposal for solid and hazardous waste and any other individual reports specified in individual sections for approval.

4.8.2. All plans and reports shall be submitted to the Contracting Officer’s Representative (COR) at the address listed below and the appropriate personnel for DEPO. A copy shall also be submitted to the Contracting Officer.

5. CONTRACTOR’S USE OF PREMISES.

5.1. Establishment of a camp within park will not be permitted.

5.2. Preservation of natural features: Confine operations to limits shown for project. Prevent damage to natural surroundings. Restore damaged areas, repairing or replacing damaged trees and plants impacted by the contractor, at no additional expense to government.

5.3. Provide temporary barriers to protect existing trees and plants and root zones. Rock structures not covered with soil may remain in place. If an outcrop of columnar basalt is found, immediately consult with Project Manager for direction. Do not remove, injure, or destroy trees or other plants without prior approval. Consult with Park Representative and remove agreed-on roots and branches that interfere with construction. Soil shall be removed with handtools around all other root structures. Do not fasten ropes, cables, or guys to existing trees. Carefully supervise excavating, grading, filling, and other construction operations near trees to prevent damage.

5.4. Comply with regulations of the National Park Service, the Fish and Wildlife Service, or other authority having jurisdiction, governing the protection of land that includes or is adjacent to the project.

5.5. Existing Utilities: Notify Park Representative and utility companies of proposed locations and times for excavation at least 2 weeks prior to onsite. Contractor shall be responsible for locating and preventing damage to known utilities. If damage occurs, repair of the utility will be done at no additional expense to the Government. If damage occurs to an unknown utility, repair the utility. Equitable adjustment will be made in accordance with Changes clause of the contract.

6. PARK SPECIFIC CONSTRUCTION REQUIREMENTS.

6.1. Work Day: Hours of construction are 7 a.m. to 6 p.m. Monday through Friday.

Weekend work and work on federal holidays will only be allowed when approved in advance by the Contracting Officer.

6.2. Construction equipment must have adequate mufflers and pollution emission controls.

6.3. The Contractor shall incorporate decontamination procedures for all vehicles, trucks, and equipment used at the site to control and prohibit the transfer of noxious weeds and plants into the park environment. Vehicles and equipment will be inspected by Park Representative prior to entry into the park for mud, weeds, and other unwanted substances. Steam clean earth-moving equipment (including haul vehicles) of mud and weed seed. Subsequent entries of hauling vehicles will not require cleaning unless requested. Notify Park Representative a minimum of 48 hours prior to entry of vehicles and equipment.

6.4. Constantly keep project sites clean of construction debris during duration of project.

Provide trash dumpsters with animal proof cover lids to contain construction debris. Collect and dispose waste material outside park boundaries. Provide enough containers for collecting construction debris. Keep project neat, orderly, and in a safe condition at all times. Keep volatile wastes in covered containers.

6.5. Take all necessary reasonable measures to reduce air and water pollution by any material or equipment used during site work. Do not dispose of volatile wastes or oils in storm or sanitary drains. Do not allow waste materials to be washed into streams or bodies of water.

6.6. Before scheduling the final inspection, remove all tools, equipment, surplus materials, and rubbish. Restore or refinish surfaces that are damaged due to work of this contract to original condition. Pick up all construction debris from the site. At time of final inspection, project shall be thoroughly clean.

6.7. Do not feed or disturb wildlife within park boundaries. Suspend construction activities when dangerous animals (mountain lions, etc.) come near an active construction area and create potential animal/human conflict. Park Representative or Park Ranger will be notified immediately for resolution of potential animal/human conflicts.

6.8. Do not operate or park equipment outside construction limits or on topsoil areas, except as approved by Park Representative. Do not operate or store vehicles and equipment leaking oil, gas, or antifreeze within park boundaries. Do not drain oil, hydraulic fluids, antifreeze, or other chemicals onto ground within park boundaries. Completely contain diesel fuel at work site.

Clean up any spill immediately and notify Park Representative.

6.9. Repair leaks on equipment immediately. Do not use equipment that is leaking. Keep supply of acceptable absorbent materials at job site in event of spills. Acceptable absorbent materials are those manufactured specifically for containment and cleanup of hazardous materials.

6.10. Separate work areas, including material sources, by the use of a dike or other suitable barrier so that sediment, petroleum products, chemicals, and other liquid or solid material do not enter waters of the U.S. Use care in constructing and removing barriers to avoid discharge of material into, or siltation of, water. Remove and properly dispose of sediment and other material collected by barrier.

6.11. Quality Assurance: In case of conflicts between Federal, state, and local safety and health requirements, the most stringent shall apply. Equipment or tools not meeting OSHA requirements will not be allowed on the project sites. Failure to comply with the requirements of this section and related sections may result in suspension of work.

6.12. Qualifications of Employees: Operators of vehicles, mobile equipment, hoisting equipment, and hazardous plant equipment shall be able to understand signs, signals, and operating instructions, and be capable of operating such equipment. Provide operating instructions for all equipment. All site employees shall be HAZWOPER certified per OSHA 29 CFR Part 1910.120(h) with current certification. Site sampling personnel shall be qualified and experienced in EPA methods and sampling protocols.

6.13. Temporary Services.

6.13.1. Electricity - There is no electrical service available at the project site. Contractor shall provide source for power and lighting. Temporary Electrical: Temporary electrical work shall meet requirements of NFPA 70-1996 (NEC), Article 305.

6.13.2. . Telephone - No telephone service is available on site for Contractor's use. There is unreliable cellular phone service. Nearest reception is 5 miles from project site. The Contractor shall provide VHF radios for onsite communications.

6.13.3. Water - No water is available on site for Contractor’s use. Contractor shall provide water for site use. Furnish cool, potable water for construction personnel in locations convenient to work stations.

6.14. Barriers.

6.14.1. Public Protection - Adequately barricade and post as required in public areas.

6.14.2. Barrier Tape - Install where directed by NPS Park staff. Keep a minimum of two rolls on site at all times. Contractor is responsible for removal of all barriers at conclusion of project.

Contractor may close access through the work site during the course of work. Access through the project site on the existing dirt road must be maintained at the end of each work day and when no work is performed. Emergency access through the project site during construction activities must be provided within 15 minutes of notification.

6.15. A capable and qualified person shall be placed in charge of fire protection. The responsibilities shall include locating and maintaining fire protective equipment and establishing and maintaining safe conditions.

6.16. Take all necessary precautions to prevent fire during construction. Provide adequate ventilation during use of volatile or noxious substances. Equip all gasoline or diesel powered equipment used in potential forest and grass fire locations with spark arresters approved by NPS.

Provide one extinguisher on each vehicle or piece of equipment.

6.17. Designate smoking areas. Designated area must be posted, will need to be cleared of vegetation and will require a 5 gallon bucket of sand.

6.18. Cutting by torch or welding shall be performed only when adequate fire protection is provided.

7. PERIOD OF PERFORMANCE AND SCHEDULE.

7.1. Project shall be fully completed within 365 calendar days.

7.2. The Contractor field work shall be conducted by an agreed upon date with DEPO and the NPS COR to provide the least interference to visitors and park activities.