2_-_ARS_Volume_2_Supplemental_RD.pdf

Solicitation Number – P16PS00832

VAFO Remediation

Remediation for the Asbestos Release Site Remedial Action at Valley Forge National Historical Park, Upper Merion Township, Montgomery County, PA

Attachment 2:

Valley Forge ARS Volume 2

Supplemental RD March 2016

SUPPLEMENTAL

REMEDIAL DESIGN REPORT

VOLUME 2

VALLEY FORGE NATIONAL HISTORICAL PARK

ASBESTOS RELEASE SITE

VALLEY FORGE, PENNSYLVANIA

March 2016

Prepared by:

Final Remedial Design Report Volume 2 i The Johnson Company, Inc.

Asbestos Release Site - Valley Forge National Historical Park February 2015

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 PROJECT ORGANIZATION

2.1 NPS PROJECT MANAGER

2.2 THE CONTRACTOR

2.2.1 Construction Manager

2.2.2 Contractor’s Health and Safety Officer

2.3 THE ENGINEER

2.3.1 Engineer’s Project Manager

2.3.2 Engineer’s Health and Safety Officer

2.3.3 Project QA/QC Officer

2.3.4 Field Engineers

3.0 SITE MANAGEMENT

3.1 PROPERTY OWNERSHIP

3.2 EXISTING SITE INFRASTRUCTURE

3.3 PROTECTION OF AREAS OF POTENTIAL ARCHAEOLOGICAL

SIGNIFICANCE

3.4 SITE SECURITY

3.4.1 Security for Health and Safety

3.4.2 Property Security

3.5 AIR MONITORING

3.5.1 Site Worker Air Monitoring

3.5.2 Ambient Air Monitoring

3.6 CONTINGENCY PROCEDURES

3.6.1 Potentially Hazardous Conditions

3.6.2 Contaminant Exposure

3.6.3 Accidents

3.6.4 Unexpected Encounters with Utilities

3.6.5 Weather-related Incidents

3.7 FIELD OPERATIONS

3.7.1 Field Offices

3.7.2 Construction Vehicle Traffic

3.7.3 Communications

3.8 RECORDS MANAGEMENT

4.0 PLANTING AND RESTORATION PLAN

4.1 EXISTING CONDITIONS

4.1.1 Forested Communities

4.1.2 Herbaceous Communities

4.2 RESTORATION

4.2.1 Wooded Uplands

4.2.2 Emergent Wetland

Final Remedial Design Report Volume 2 ii The Johnson Company, Inc.

4.2.3 Fields

4.3 NUISANCE SPECIES CONTROL

5.0 SAMPLING AND ANALYSIS PLAN

6.0 CONSTRUCTION QUALITY ASSURANCE PLAN

6.1 INTRODUCTION

6.2 CONTRACTOR SUBMITTALS

6.3 FIELD TESTING

6.4 PROJECT INSPECTIONS

6.5 REPORTING

6.6 FIELD DOCUMENTATION

6.7 PROJECT CLOSE-OUT DOCUMENTATION

6.8 RELATIONSHIP TO OTHER RD ELEMENTS

7.0 ESTIMATED MATERIAL QUANTITIES

8.0 OPERATION AND MAINTENANCE PLAN

8.1 OVERVIEW

8.2 POTENTIAL FUTURE EXPOSURE SCENARIOS AND MITIGATION

METHODS

8.3 INSPECTIONS

8.4 MAINTENANCE

8.5 NUISANCE SPECIES MANAGEMENT

9.0 REFERENCES

K:\3-0700-8\Remedial Design\RD Report 2015\Volume 2\RD Report Vol 2 Revision 1.docx

Final Remedial Design Report Volume 2 iii The Johnson Company, Inc.

LIST OF TABLES

Table 4-1 Restoration Quantities for Additional Remediation Areas Table 4-2 Plantings for Wooded Uplands Table 4-3 Invasive Species Table 4-4 Planting Guide for Areas to be Restored as Wooded Uplands Table 6-1 Submittal Requirements for Construction Material Table 6-2 Field Tests Included in the CQAP Table 7-1 Summary of Estimated Material Quantities for Additional Remediation Areas Table 8-1 Potential Future Exposure Scenarios and Mitigation Methods

LIST OF FIGURES

Figure 2-1 Organizational Chart

LIST OF APPENDICES

Appendix A Material Quantity Tables

Supplemental Remedial Design Report Volume 2 1 The Johnson Company, Inc.

Asbestos Release Site - Valley Forge National Historical Park March 2016

1.0 INTRODUCTION

This Volume 2 of the Valley Forge National Historical Park Asbestos Release Site (Site)

Remedial Design (RD) Report is a companion document to three other volumes, all of which make up the RD Report. A description of the topics covered by each of the RD Report volumes is provided below.

• Volume 1: provides background information for the Site; a description of the selected remedy; the basis of design; performance standards and verification methods for evaluating the success of the remedy; decontamination and waste characterization and disposal plans; a transportation plan; an institutional controls plan; a description of archeologically sensitive areas and associated protections during the RA; and a summary of ARAR compliance.

• Volume 2: describes the following implementation plans - the site management plan; planting and restoration plan; sampling and analysis plan (SAP);

construction quality assurance plan; and the operation and maintenance plan.

• Volume 3: presents the Design Drawings, which will be used during the RA to implement the selected remedy.

• Volume 4: includes the construction specifications, which will be used in conjunction with the design drawings and implementation plans for the implementation of the remedy.

Supplemental Remedial Design Report Volume 2 2 The Johnson Company, Inc.

2.0 PROJECT ORGANIZATION

A preliminary project organization chart (Figure 2-1) has been prepared that describes key roles, responsibilities, and chains of command related to the planning and implementation of the RA. These roles and responsibilities are discussed below.

2.1 NPS PROJECT MANAGER

The National Park Service (NPS) Project Manager will be responsible for overall project management, coordination, and administration. The NPS Project Manager will manage and interface with the Engineer and the Contractor on all project-related matters, including the project costs, schedule, RD interpretation, change orders, Site conditions, and planned activities.

The NPS Project Manager will be responsible for all communications with the Commonwealth of Pennsylvania, the general public, and the Park about the project. The NPS may delegate its responsibilities and obligations identified in this Volume to the Engineer, or other engineering or environmental consulting companies.

2.2 THE CONTRACTOR

The Contractor will be selected and contracted by the NPS to perform the RA at the Site.

The Contractor will be responsible for preparing the Remedial Action Work Plan (RAWP) and other submittals as required by the construction specifications (Volume 4), obtaining NPS approval for these submittals, and performing the RA in accordance with the remedial design and the approved submittals. The Contractor will schedule and coordinate all Site activities with the

NPS Project Manager, and will be responsible for health and safety of their workers as well as

Park staff and the general public. The Contractor’s responsibilities include providing the required ambient air monitoring.

2.2.1 Construction Manager

A Construction Manager will be designated by the Contractor and will be the main point of contact for the NPS. The Construction Manager will be responsible for coordinating and controlling the Contractor’s submittals, logistics, and Site activities. The Construction Manager

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will be responsible for Site workers, equipment, and any subcontractors retained by the

Contractor to perform the Work.

2.2.2 Contractor’s Health and Safety Officer

The Contractor’s Site Specific Health and Safety Officer will be on site during all

Contractor activities, and will be responsible for ensuring the Contractor’s employees and subcontractors comply with the requirements of the Contractor’s Site-specific Health and Safety

Plan (HASP), which will be included as part of the RAWP. Specific responsibilities and tasks for this position will be described in the Contractor’s HASP.

2.3 THE ENGINEER

The Engineer will be retained by the NPS to review the Contractor’s submittals, provide construction oversight, conduct Construction Quality Assurance (CQA) tests (see Section 6.0), ensure data quality meets the remedial design requirements (see Section 5.0), and ensure the health and safety of the Engineer’s personnel on the Site during the remedial activities. Key project personnel associated with the Engineer’s organization include the Engineer’s Project

Manager, the Project Quality Assurance/Quality Control Officer (QA/QC), the Health and Safety

Officer, and the Field Engineer.

2.3.1 Engineer’s Project Manager

The Engineer’s Project Manager will be the main point-of-contact for the NPS Project

Manager and the Contractor. The Engineer’s Project Manager will be responsible for scheduling, CQA tests, Contractor oversight, and Site surveying activities. The Engineer’s

Project Manager will also be responsible for reviewing the Contractor’s submittals and providing review comments and recommendations to NPS in a timely manner.

2.3.2 Engineer’s Health and Safety Officer

The Engineer’s Health and Safety Officer will be responsible for ensuring the Engineer’s employees and subcontractors comply with the requirements of the Engineer’s Site-specific

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HASP, which will be reviewed by NPS prior to any site activities. Specific responsibilities and tasks for this position will be described in the Engineer’s HASP.

2.3.3 Project QA/QC Officer

The Project QA/QC Officer will be responsible for ensuring the data obtained in the field meets the data quality objectives established in the Contractor’s Quality Assurance Project Plan

(QAPP, see Section 5.0). The Project QA/QC Officer will be responsible for data quality, storage and archiving of project data, and for ensuring field tests are performed in accordance with the requirements of the RD.

2.3.4 Field Engineers

Field Engineers will be designated by the Engineer to provide Contractor oversight during RA activities. Field engineers will be responsible for performing Contractor oversight to ensure the RA is conducted in accordance with all of the elements of this Supplemental RD

Report including the Drawings (Volume 3) and Specifications (Volume 4). The Field Engineer will provide daily reports for all field activities, and will coordinate CQA testing activities, where required.

Supplemental Remedial Design Report Volume 2 5 The Johnson Company, Inc.

3.0 SITE MANAGEMENT

The Contractor will prepare and submit a Site Management Plan (SMP) as part of their

RAWP, which will be reviewed and approved by NPS before the Contractor commences RA activities at the Site. This section describes the requirements for the Contractor’s SMP as well as

Site-specific features and considerations to be addressed in the SMP.

At a minimum, the Contractor’s SMP will describe how the Contractor plans to address the following topics:

• Property Ownership

• Existing Site Infrastructure

• Protection of Sensitive Areas

• Site Security

• Air Monitoring

• Contingency Procedures

• Field Operations

• Records Management

Relevant requirements and considerations for each of these topics are described in the following sections.

3.1 PROPERTY OWNERSHIP

The Site is located within the Park, which is owned by the U.S. Government and managed by the NPS. The Park is open to the public as a day-use facility and typically closes at dusk. The Site is accessible via public roads located within the Park. Access and property ownership is not a significant concern for areas of the Site located south of PA Route 23.

3.2 EXISTING SITE INFRASTRUCTURE

Existing infrastructure at the Site that may be impacted by the RA includes buried and overhead utilities several public roads (PA Route 23 and County Line Road), and active parking areas. Remedial excavations have been designed to limit impacts to the existing Site infrastructure to the extent possible. Excavations will not be performed underneath paved parking lots, roads, or existing buildings.

Several underground utilities are located at the Site, including a natural gas pipeline, Supplemental Remedial Design Report Volume 2 6 The Johnson Company, Inc.

electrical utilities, water pipelines, storm water culverts, inactive septic systems and retaining walls. The NPS provided approximate locations for some utilities at the Site, which are shown on the Design Drawings (Volume 3, Sheets 3 to 10). However, the utility locations shown on these Drawings are approximate, and may not be comprehensive. The Contractor will be required to contact a utility locating service (Pennsylvania 8-1-1) and obtain utility clearance prior to conducting any excavation activities. If underground utilities are known or suspected to exist within a design excavation boundary, exploratory excavations will be completed to locate the utilities before remedial excavations are performed. The Construction Specifications

(Volume 4, Section 01560 and Section 02200) describe requirements for avoiding existing utilities and for performing exploratory excavations.

Remedial excavations must be completed in such a way as to preserve existing storm water drains, culverts, and retaining walls. Hand excavation and special precautions by the

Contractor may be required when working near these Site features in order to preserve them.

The Contractor will be required to coordinate excavation activities with the appropriate utility to preserve the overhead utility line and temporarily stabilize the pole during excavation along County Line Road, if necessary.

3.3 PROTECTION OF AREAS OF POTENTIAL ARCHAEOLOGICAL

SIGNIFICANCE

Portions of the Site where additional excavation occur contain areas of potential archaeological significance. NPS is conducting Phase IB archaeological field testing for these areas which will be completed before remedial excavations are performed. The Phase IB

Archaeological Assessment Report will provide recommendations and guidelines for mitigation measures to be implemented during the RA to limit potential impact to encountered artifacts and provide procedures to follow in the event of discovered artifacts. NPS will provide an archaeologist to conduct oversight of excavations performed in areas that NPS determines may be historically significant.

Supplemental Remedial Design Report Volume 2 7 The Johnson Company, Inc.

3.4 SITE SECURITY

Security at the Site is designed to address two principal functions: 1) the health, safety, and well-being of the public and site workers; and 2) the protection of property. These functions will be fulfilled through the installation of appropriate access control features, warning signage, and sound management practices. Ambient and worker safety air monitoring required during the

RA is described in Section 3.5.

Complete physical exclusion of the public from the entire Site is not feasible given the size and location of the Site and its frequency of use by the public. However, controls will be implemented to prevent entry of unauthorized personnel to areas of the Site where active remediation activities are occurring while allowing Park operations in un-impacted portions of the Site to continue with minimal interferences. These controls include closure of portions of public roads, recreation paths, and parking lots; installation of temporary warning signs; and installation of temporary restricted access fencing. The Community Involvement Plan, a separate document prepared by NPS describes requirements for notifying the public about scheduled road and recreation path closures.

3.4.1 Security for Health and Safety

3.4.1.1 Control of Existing Public Access

The RA includes excavation, stockpiling, and loading of contaminated soils onto trucks for off-Site disposal and importation of clean fill onto the Site. If not controlled, these activities have the potential to present the following risks to the general public: 1) accidents associated with heavy construction equipment; 2) direct exposure to contaminated soil; and 3) inhalation risks associated with the inadvertent release of contaminated construction dust to the atmosphere.

Dust control measures will be required to limit the generation of dust during construction activities (Volume 4, Section 01700), therefore ambient air quality impacts resulting from the

RA, if any, will likely be limited to the immediate vicinity of active excavations and material handling operations. Ambient air monitoring will be performed around the periphery of areas

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where land-disturbing remedial activities are taking place to alert the project team of potential contaminant migration with dust so that additional preventative control measures can be taken

(see Section 3.5).

To protect the public from these potential health and safety risks, temporary restricted access zones will be established for each excavation area before clearing or other intrusive site activities commence. Each restricted access zone will include a decontamination area and an exclusion zone (which includes the excavation area). The restricted access zones will be described in detail in the Contractor’s HASP.

The restricted access zones will change as the work progresses. Personnel (other than the

NPS Project Manager, Contractor and Engineer) that need to enter these restricted access zones will be required to sign in and present evidence of current OSHA training as specified in 29 CFR

1910.120 to gain access to the areas of intrusive activities. In those instances, the individual will be asked to read and sign the HASP, will receive a health and safety briefing, and will be allowed to enter the restricted access zone as needed to complete their tasks.

The restricted access zones will be delineated by either portable snow fencing, warning tape, or barricades, and warnings posted on appropriate signage (see below). The Contractor’s

Site Manager or his/her designee will be responsible for restricting access to these zones until remediation is complete and will be present during all field operations to ensure that no persons enter without authorization. Access locations to active work zones will be secured by fencing and/or barricades, and posted with warning signs, whenever the Contractor’s personnel are not present.

The temporary fencing, barricades, or warning tape will be accompanied by printed durable warning signs that contain the following text:

WARNING

AREA CLOSED TO THE PUBLIC

ENVIRONMENTAL REMEDIATION IN PROGRESS

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ASBESTOS HAZARDS PRESENT

Questions: Contact Donna Davies, NPS Project Manager

These signs must be spaced no further than 50 feet apart along the fence or barricade line and be a size (sign and text) that is large enough to be readable from at least 15 feet. Acceptable fencing and barricade materials include snow fencing and jersey barricades; however other materials may be acceptable based on NPS’ judgment. The fencing and signage must be installed prior to any earth disturbance activities, including clearing, grubbing, excavation, and site preparation work.

Following are AOC-specific requirements for access control to protect public health and safety. Remediation at several of the AOCs will require temporary closure of public roads, parking or recreation paths. These closures will only be implemented after consultation with

NPS.

MAR: The MAR AOC is currently open to public access. The restricted access zones for the

MAR-A-NB-01 excavation will be field fit at locations just outside the nearby wooded areas.

The park maintenance facilities access road is posted as closed to unauthorized travel, however additional controls, such as barricades may be necessary.

FKP: An existing wooden post and flexible rail fence exists along the southern, eastern, and western portions of the FKP AOC perimeter. This fence could be used to demark the restricted access zone perimeter during the RA. Temporary warning signs along the fence will be required.

New temporary fencing and warning signs will need to be installed north of FKP-M prior to start of remediation in the FKP AOC.

HIB: The HIB AOC is located near an informal, unpaved trail which will be closed to the public during remediation activities. Warning signs will be installed along existing fence lines during remedial activities.

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SAQ: The SAQ AOC is adjacent to County Line Road which will be used for access. County

Line Road will be closed to the public with barricades and warning signs during remediation of this AOC.

WCRS: The WCRS AOC is a linear feature that parallels County Line Road near the lower visitor center parking lot. Remediation that will be expanded within WCRS include WCRS-B

North, WCRS – C1, WCRS-D and WCRS - G South. An unpaved, informal trail currently crosses through the WCRS-B and WCRS-C remediation areas. This trail will be closed to the public during remediation activities in these areas with barricades or fencing and warning signs.

County Line Road will be used for access to WCRS-B North and C and may therefore be closed to the public during remediation of those areas. The southwestern portion of the lower visitor center parking lot will be used for equipment staging and access to the WCRS-D (and part of the

HIB) excavations. Therefore, the western one-half of the parking lot (west of the access road from County Line Road) will be closed during remediation of those areas. The eastern half of the parking lot will be closed during remediation of WCRS-G South due to the close proximity of this portion of the parking lot to these excavation areas.

3.4.1.2 Contractor Access Points and Staging Area

Construction vehicle access routes to the remediation areas are shown on Volume 3, Sheets 3 to 8. These access routes use existing access roads to the extent practicable, and intersect County Line Road and the lower visitor center parking lot.

A common staging area and field office location has been identified for use by the

Contractor, NPS and Engineer during the Remedial Action (Volume 3, Sheet 4). This location is in the FKP AOC, south of FKP-A-NB-01. This location is fairly isolated from the rest of the

Park, and is surrounded by quarry walls and wooded areas which will provide a buffer and natural screen from the portions of the Park frequented by the public. An existing access road off of County Line Road leads to this staging/field office location. Only the access road that connects to County Line Road will be used to access the field offices and central staging area during the RA. This access route avoids the Park visitor center and associated driveways and

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parking lots and therefore will reduce the impact to the Park resulting from the increased traffic due to the remediation. All deliveries and visitors to the Site will be required to first report to this field office.

3.4.2 Property Security

Security for the Contractor, NPS and Engineer’s property during the RA will depend on the type and size of the property. Durable, weatherproof, heavy and large equipment such as construction equipment and field offices, will be stored outside without any special security.

Small equipment (e.g., instruments, detectors, and hand tools), supplies (e.g., chain-of-custody forms and tape, deionized water, and flagging), and field office equipment (e.g., refrigerator, desk, computer, and other office equipment) will be kept in the field office which will be locked when unattended. All construction equipment, field offices, vehicles, and storage areas left on the Site overnight will be locked and secured prior to personnel leaving the Site.

3.5 AIR MONITORING

Air monitoring will be performed during the RA for two purposes: 1) health and safety of the Site workers within remediation areas; and 2) health and safety of the public and Park staff outside of remediation areas. Air monitoring for health and safety of Site workers will be described in detail in the Contractor’s HASP. Air monitoring for health and safety of the public and Park staff (ambient air monitoring) will be described in detail in the Contractor’s RA Work

Plan. Details regarding the collection and analysis of samples for asbestos will also be provided in the Contractor’s RAWP, specifically in the Sampling and Analysis Plan which includes the

Field Sampling Plan and QAPP. The two air monitoring programs to be implemented during the

RA are described below.

3.5.1 Site Worker Air Monitoring

Personal air monitoring conducted for the Contractor’s site workers will be outlined in the Contractor’s Site-Specific Health and Safety Plan to be included in the RAWP. It is the

Contractors responsibility to conduct monitoring as required by OSHA to protect its workers, determine appropriate levels of PPE and provide rationale for PPE downgrade.

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3.5.2 Ambient Air Monitoring

Whenever land-disturbing remedial activities are occurring the Contractor will conduct perimeter air monitoring at several locations surrounding the active remediation area to evaluate the potential for community exposure to airborne hazards, verify the effectiveness of engineering controls, and trigger an applicable response action in the event of an identified dust migration risk. Perimeter air monitoring will be conducted during soil excavation, stockpiling and/or loading to verify that dust suppression procedures are adequately preventing possible airborne contaminant exposure to Park visitors and employees. Monitoring for particulates (dust) will be performed at all AOCs; monitoring for airborne asbestos will only be performed at the following

AOCs where asbestos-contaminated soil will be excavated:

• FKP-A-NB-01

• FKP-F/G/J-NB-01

• HIB-C3-NB-01

• HIB-C3-NB-02

• WCRS-C1

• WCRS-G-South

Perimeter air monitoring will consist of real-time respirable dust (PM 10) monitoring at all locations and air sampling for asbestos in the areas identified above. The Contractor shall designate a qualified individual/subcontractor for all aspects of the perimeter air monitoring.

Exposed soil in open excavations and stockpiles will be maintained in a moist condition or covered to prevent fugitive dust. If perimeter air monitoring indicates exceedances of screening thresholds, the remediation will stop and dust control procedures will be reviewed and amended until the monitoring indicates successful reductions in dust. Some common dust suppression techniques are described in Volume 4, Section 01700. The health thresholds are described in the following subsections.

3.5.2.1 Dust Monitoring

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EPA ambient air PM-10 concentration of 0.150 milligrams per cubic meter (mg/m3) will be the action level used to evaluate the perimeter monitoring data collected during the performance of remedial activities for respirable dust.

Perimeter air monitoring will be conducted continuously during soil excavation, stockpiling and /or loading to measure particulate (respirable) dust at the downwind perimeter, as specified below.

Dust monitors shall be placed within 100 feet of the soil disturbance activities, unless the potential for Park employee or visitor to be exposed exists closer than 100 feet, in which case the monitoring shall be conducted at an appropriate location (e.g., edge of public road or trail).

Airborne particulate monitoring will be performed at one upwind and two downwind locations (relative to the remediation activities) using a dataRAM 4 Dust Monitor (or equivalent). The particulate monitors will be equipped with automatic alarms and instrumentation to allow for integration over a period not to exceed 15 minutes. The particulate action level for this Site is 0.150 mg/m3 over the integrated period not to exceed 15 minutes. If particulate levels (PM-10) are detected above 0.150 mg/m3, the background (upwind) level will be measured immediately using the same monitor. If the downwind (working) particulate level is greater than 0.100 mg/m3 above the background level, then the activity will be stopped until additional dust suppression techniques are implemented and/or expanded and additional monitoring data demonstrate that action levels have been achieved. In addition to the particulate monitoring action levels, a visible dust action level will be used. If dust is observed leaving the

Site, additional dust suppression techniques will be implemented, regardless of whether a dust monitoring alarm is triggered.

Quality assurance/quality control (QA/QC) procedures (in the field and laboratory) will be detailed in the QAPP provided as part of the Contractor’s SAP. The QAPP will include, at a minimum, daily instrument calibration, operator training, and a record keeping/ calibration plan.

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All dust monitoring results will be recorded on a daily air monitoring log and/or downloaded from the dust monitor and provided to the NPS Project Manager at the end of each work day.

3.5.2.2 Asbestos Monitoring

In the areas listed in Section 3.5.2 asbestos has been identified in soil; therefore, perimeter asbestos air sampling will be required in addition to dust monitoring. Two directional asbestos air samplers will be employed at the same location as the two downwind dust monitor locations and a third located in the direction of potential receptors (to be field determined and approved by NPS). Daily samples will be collected and analyzed by an American Industrial

Hygiene Association (AIHA) accredited laboratory utilizing National Institute for Occupational

Safety and Health (NIOSH) methods.

The perimeter action level for airborne asbestos is 0.1 fibers per cubic centimeter (f/cc), consistent with the OSHA permissible exposure limit (PEL) for asbestos. Phase Contrast

Microscopy (PCM) in accordance with NIOSH Method 7400 will be employed for laboratory analysis. If the action level is exceeded following PCM analysis, the sample will be analyzed using Transmission Electron Microscopy (TEM) analysis in accordance with NIOSH Method

7402. A minimum of two daily samples over each 8-hour work period will be collected with a calibrated pump and cassette filter. The pump flow rates will be recorded prior to and after the collection of air samples. Initial, i.e., day 1, air samples will be analyzed within 24 hours.

Assuming no exceedance of the action level in the day 1 air samples, subsequent samples can be analyzed on a 3 to 5 day turn-around time as long as site conditions and the Contractor’s activities do not appreciably change. Whenever Site conditions or Contractor activities change, as determined by NPS, a one day turn-around time for sample analysis will be required. Should an exceedance of the action level be reported by the laboratory, work will be temporarily suspended until additional or enhanced dust control measures are implemented.

The Contractor’s specific sampling protocols, analytical methods and QA/QC procedures will be detailed in the Contractor’s SAP (to include the field sampling plan [FSP] and QAPP, Supplemental Remedial Design Report Volume 2 15 The Johnson Company, Inc.

detailed below in Section 5.0) and will include at a minimum daily calibration of the samplers;

proper chain-of-custody records, adherence to sample handling and field documentation protocols; proper operator training; and documented record keeping. All sampling parameters will be recorded on daily air monitoring logs. Copies of all laboratory reports, and the daily air monitoring logs, shall be provided to the NPS Project Manager within 24 hours of receipt/completion.

3.6 CONTINGENCY PROCEDURES

The purpose of this section is to provide a contingency and notification plan for potentially dangerous situations, should they occur, during implementation of the RA.

3.6.1 Potentially Hazardous Conditions

Potentially hazardous conditions could develop during RA activities, including exposure to contaminated material; injury resulting from mechanical devices and machinery; vehicle collisions; unexpected encounters with existing utilities; and extreme weather related incidents.

The Contractor’s HASP, prepared as part of the RAWP, will assess these situations and describe preventative measures to be taken to mitigate the risks. The Contractor’s Site Manager, or his or her designee, will be responsible for observing potentially hazardous activities and implementing required actions.

3.6.2 Contaminant Exposure

The Contractor’s HASP will describe in detail measures to be taken to protect the health and welfare of workers in the vicinity of hazardous contaminants. It is currently anticipated that

RA activities performed in areas where contaminants include asbestos will be initiated in Level

C personal protective equipment (PPE) (Tyvek coveralls, respirator, steel-toed boots, hard hat, and hearing protection if needed). Air monitoring for worker protection will be required in the immediate vicinity of remediation activities. If the initial air monitoring indicates that worker exposure health thresholds (established in the Contractor’s HASP) are not being exceeded, the

Worker’s PPE may be downgraded to Level D (steel-toed boots, long pants, hard hat and hearing

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protection if needed).

As described in Section 3.5, the Contractor will conduct perimeter ambient air monitoring at peripheral locations around active remediation areas. If this monitoring indicates contaminant concentrations exceed health thresholds (as described above and detailed in the Air Monitoring

Plan and SAP elements of the Contractor’s RAWP), the work will stop at that location until a review of the dust control procedures is completed and adjustments are made.

3.6.3 Accidents

As with any construction project, there is potential for accidents related to the operation of mechanical devices, large equipment, and vehicles. The Contractor’s HASP will include the requirement for adherence with OSHA safety regulations related to general construction (29 CFR

Section 1926), and will include emergency response and contact information (including NPS specific procedures, local police and fire department), identification and directions to the nearest hospital, and accident reporting procedures.

3.6.4 Unexpected Encounters with Utilities

There are utilities in the Park that could present safety risks if inadvertently encountered and damaged during excavation (e.g., buried gas pipeline, water lines, and electric lines). The

Contractor will be required to investigate the locations and depths of all such utilities prior to initiating any excavations (see Section 3.2). The Contractor’s HASP will include the names and contact information for the owners of all the utilities that may be encountered and emergency response procedures in the event that any of the utilities are inadvertently damaged during excavation.

3.6.5 Weather-related Incidents

It is possible that severe weather events could cause an emergency situation resulting in property damage, damage to previously completed remediation areas, and injury or death. Such events may include flooding, high winds and lightning resulting from hurricanes, tornados or thunderstorms. The Contractor will be required to stop work, secure equipment and remediated

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areas, and ensure that all personnel retreat to safe, indoor environments in the event of forecasted or impending severe weather situations. The Contractor’s HASP will include emergency response and contact information (including the Park’s emergency contacts [to be provided to

Contractor by NPS], local police and fire department) and identification and directions to the nearest hospital.

3.7 FIELD OPERATIONS

3.7.1 Field Offices

Field activities for the RA will be managed from the field offices which will be maintained in a Contractor-provided trailer located in the FKP AOC area. Separate work areas will be provided in the field office for the Contractor and NPS, including NPS contractor staff.

Cabinets and shelving will be installed and file cabinets provided and maintained for the orderly filing and convenient retrieval of working documents for the RA (e.g., the Supplemental RD

Report, the RAWP, reference materials, charts, maps, and field notes). Field offices will be properly illuminated, provide heating and air conditioning, and will have internet access and scanning capabilities. Adequate space will be available within the facilities to accommodate staff, field equipment, supplies, layout tables, etc.

3.7.2 Construction Vehicle Traffic

The Contractor will be responsible for coordinating and managing vehicle traffic associated with the excavations, and loading and transport of waste materials.

The field office area will include a parking area for visitors and delivery vehicles. Access to the AOCs and remedial excavations will be restricted to only vehicles and personnel necessary to perform the RA. Construction vehicle traffic within the Site will utilize existing roads;

therefore, the Contractor will be required to review expected construction traffic frequency and routing with NPS regularly and ahead of the start of each new excavation area. The Contractor will provide the means for immediate communication with all construction vehicles within the

Site and will direct and restrict vehicle traffic as necessary for safety or logistical reasons. The

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Contractor will also be responsible for coordinating deliveries to the Site and off-Site transportation of equipment and waste materials. Transportation requirements for this project are outlined in the Transportation Plan in Section 8.0 of Volume 1 and will be detailed in the

Contractor prepared Transportation Plan to be provided to NPS as part of the RAWP.

3.7.3 Communications

Communications during the RA will include Site meetings between the Contractor, NPS and/or the Engineer, and telephone and e-mail communications between Site personnel and office-based personnel (e.g., Engineer’s Project Manager, Contractor’s office personnel and NPS management). As described above, the field offices will be equipped with telephone and internet connections to facilitate communications. In addition, all field personnel will have access to instant communication devices such as “direct connect” (walkie-talkie enabled) phones, wireless radio, or cell phones to facilitate communications between the field personnel and the field office, truck drivers, material suppliers, etc.

Daily field reports will be prepared by the NPS Project Manager or the Field Engineer and e-mailed to all office-based project team members. All daily reports will be filed electronically as described below in Section 3.8.

Daily meetings will be held at the start of each day between the Contractor, NPS and/or the Field Engineer to discuss plans for the day, problems requiring resolution, health and safety concerns, traffic control, logistics, etc.

3.8 RECORDS MANAGEMENT

During the RA, a variety of field data will be collected that requires management, including field notes, field measurements, health and safety monitoring results, equipment calibration records, digital photographs, laboratory reports, bills of lading and hazardous waste manifests. These data will be stored and organized in the field office, and will be transmitted to the NPS Project Manager and the Engineer as soon as practical. Analytical laboratory data will

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be provided in electronic formats that are compatible with the existing electronic databases for the Site. As much as possible, data will be digitized and maintained as electronic files. Field notes, forms, calibration records, etc. will be compiled at the end of each day and scanned and stored on the field computer. Back-up files of all electronic records will be stored on an external hard drive periodically, and that hard drive kept in a secure location by the NPS Project Manager or Engineer.

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4.0 PLANTING AND RESTORATION PLAN

The RA activities will impact a total of approximately 13 acres of land including the areas of concern, construction of temporary access roads, decontamination pads, equipment staging areas, and material stockpiles. This Planting and Restoration Plan describes the methods for restoring the areas of the Site impacted by the RA to a natural condition similar to what existed before the RA. The areas that will be impacted include emergent wetlands, upland forested habitats, fields, a drainage channel, and non-vegetated areas resulting from anthropogenic activities (parking areas, roads, recreation paths, etc.).

This Planting and Restoration Plan describes the existing Site conditions (observed in

2010) in Section 4.1, followed by restoration plans for each area of land disturbance associated with the RA in Section 4.2. Requirements for nuisance species control are presented in Section

4.4.

4.1 EXISTING CONDITIONS

Table 4-1 summarizes the acreage of different community types that are expected to be disturbed during the RA. The design drawings (Volume 3, Sheets 3 to 8) show how the different vegetation areas are distributed throughout the Site. The boundaries of these community types do not coincide with the boundaries of the remediation areas, and several different community types may be located within a single excavation area, such as excavation

FKP-C2-NB-01. The Site has been historically disturbed by anthropogenic activities. These disturbances have affected the development of plant communities. The USGS-NPS Vegetation

Classification and Mapping Report places the wooded areas at these locations into a Park-specific category called Northeastern Modified Successional Forest, which applies to areas with a history of disturbance (which includes most of the Site) and which contain early successional species (USGS-NPS, 2005).

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4.1.1 Forested Communities

The wooded uplands at the Site that are not in the floodplain forest are broadleaved deciduous forest. The USGS-NPS Report (USGS-NPS, 2005) characterizes the forest type as a

Park-specific Northeastern Modified Successional Forest. The composition of this forest type reflects the history of the land use changes that have occurred at the Site. Native and introduced species are present; tree and herb species that are aggressive colonizers are dominant. Native tree species include boxelder (Acer negundo), sycamore, black walnut (Juglans nigra), silver maple (Acer saccharum), white ash (Fraxinus americana), black cherry (Prunus serotina), and

American elm. Introduced tree species include black locust (Robina pseudoacacia) and Norway maple (Acer platanoides). The shrub stratum is dominated by multiflora rose and Japanese honeysuckle. The herb layer is dominated by weeds, especially garlic mustard and stiltgrass.

4.1.2 Herbaceous Communities

4.1.2.1 Emergent Wetland

Two isolated palustrine emergent (PEM) (Cowardin et al., 1979) wetlands have been delineated in the FKP area of the Site (see Volume 1, Appendix D of the 2012 RD Report).

These wetlands are dominated by common reed (Phragmites australis).

4.1.2.2 Fields

Fields present at the Site are maintained by seasonal mowing although some maintained lawn is present around the lower visitor center parking lot. The upland area surrounding the two emergent wetlands is dominated by pasture grass species such as orchard grass (Dactylis glomerata), bentgrass (Agrostis spp.), panic grass (Panicum anceps) and foxtail (Setaria verticillata) (NPS, 2006; USGS-NPS, 2005).

4.2 RESTORATION

The additional areas of concern described in Volume 1 are discrete areas within larger plant communities that will not be disturbed during the RA. Therefore, the restoration philosophy utilizes plantings combined with natural succession to restore disturbed areas of the

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Site. Thus, the planting plan will rely on a variety of tree and shrub species and seed mixes with sufficient diversity to encourage development of a diverse forest community. The natural seed rain from the undisturbed communities surrounding the disturbed areas will provide additional diversity that is suited to the microenvironments within the restored areas. A nuisance species control plan (Section 4.4) has been developed as an integral part of this approach to restoration.

Table 4-1 summarizes how the areas disturbed during the RA will be restored. Plantings for wooded uplands are presented in Tables 4-2 and 4-4, and are described in detail below.

Generally, disturbed areas will be restored to the communities that existed prior to the RA, except for the Type 1 institutional Control areas identified in Section 9.2 of Volume 1 of this

Supplemental RD Report. These seven Type 1 institutional control areas (FKP-A-NB-01, FKP-

C2-NB-01, FKP-E-NB-01, FKP-F/G/J-NB-01, FKP-K/L-NB-02, FKP-BN-NB-01, and WCRS-

D-NB-02) are located in wooded uplands areas, and will be restored by seeding with a Park-specific meadow mix; shrubs and trees will not be planted in these areas (see Section 9.2 of

Volume 1).

4.2.1 Wooded Uplands

Wooded upland areas disturbed during the remedial action will be restored by planting a mixture of 60% tree and 40% shrub plantings, with a total (trees and shrubs) planting density of

375 stems per acre. 70% of the tree plantings will be containerized seedling plantings with a target height range of 12 to 18 inches (minimum height of 12 inches); 30% of the tree plantings will be bare-root trees with an average height of 6 to 8 feet. All of the shrub plantings will be containerized seedlings with a target height of 12 to 18 inches. Bare-root tree plantings will be fitted with plastic trunk protectors; tree shelters will be installed around all containerized seedling plantings. Wooded uplands areas planted with trees and shrubs will also be seeded with a seed mixture known as the Valley Forge National Historical Park (VFNHP) Meadow Mix (see

Table 4-2 for species list and percentages for VFNHP meadow mix).

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Tree species selected for wooded uplands are: red maple (Acer rubrum), black cherry

(Prunus serotina), pin cherry (Prunus pennsylvanica), shagbark hickory (Carya ovata), American basswood (Tilia americana), shingle oak (Quercus imbricaria), bur oak (Quercus macrocarpa), red oak (Quercus rubra), and white oak (Quercus alba). Boxelder and black walnut will likely be early colonizers. Boxelder is a dominant in the shrub layer of the existing forests as well as being present in the tree canopy. Black locust, which is not native to this area of Pennsylvania, will also aggressively colonize cleared areas. The shrub plantings will include spicebush (Lindera benzoin), shadbush (Amelancier canadensis), maple leaf viburnum

(Vibrunum acerifolium), and arrowood viburnum (Viburnum dentatum). Spicebush (Lindera benzoin) is reported as a dominant in the Modified Successional Forest type, and flowering dogwood is often associated with red maple forest communities. The plantings for wooded uplands are summarized in Table 4-4.

4.2.2 Emergent Wetland

One emergent wetland area, Wetland F (as defined in the 2012 RD Report, Volume 1, Appendix D) is located in the FKP AOC near excavation FKP-B3. This wetland will be impacted by additional excavation FKP-C2-NB-01. Wetland hydrology for Wetland F is provided by overland flow and possibly groundwater. Wetland F currently is dominated by

Phragmites. The wetland area impacted by the remediation will be restored with placed topsoil to match the pre-existing wetland elevation, and seeded with VFNHP meadow mix (see Table 4-

2 for species list and percentages for VFNHP meadow mix).

4.2.3 Fields

Excavations in fields will be filled and topsoil applied to achieve the original grade. The fields will be seeded with the VFNHP Meadow Mix (see Table 4-2 for species list and percentages). Remediation areas to be filled will also be treated with topsoil and seeded with

VFNHP Meadow Mix.

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4.3 NUISANCE SPECIES CONTROL

The remediation areas currently support many plant species on the Pennsylvania invasive plants list (DCNR, 2005). Table 4-3 lists invasive plants that have been identified by previous plant surveys (NPS, 2006; USGS-NPS, 2005) and also identifies species that are considered noxious weeds by the Pennsylvania Department of Agriculture.

None of the invasive species recorded at the Site will be included in the restoration plantings or seed mixes. The primary strategy to minimize re-establishment of these species will be to encourage early vegetative cover by native grasses and forbs on the disturbed areas so that these invasive species will have a difficult time re-establishing themselves. Excess fertilizer tends to encourage invasive species over native species; therefore, fertilizer rates will be limited to that recommended for the seed mixes so that over fertilization is avoided. Soil amendments will not be used in wetland areas. Special precautions, as described in the following paragraph will be implemented when excavating portions of the FKP AOC where common reed is currently present. These precautions will avoid spreading plant material to unaffected areas of the Site.

Wetland and upland floodplain areas and the WCRS AOC are particularly susceptible to the introduction of three invasive species: common reed, purple loosestrife (Lythrum salicaria), and Japanese knotweed (Polygonum cuspidatum). In order to prevent introduction of these species, all equipment will be thoroughly cleaned to remove any residual soil or vegetative material prior to entering work areas. This includes the equipment used for remediation excavation and backfill, set up of staging and access areas, and final grading and planting of the remediated areas. Fill and topsoil will be obtained from sources that can certify that the material came from areas free of these invasive species. Since common reed is present in the FKP area, it will be extremely important to thoroughly clean equipment used in those areas before it is used elsewhere.

Inspections will be conducted in the summer and fall during the five years following Site remediation to monitor Site restoration areas for invasion by nuisance species that are not

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currently present in the plant community surrounding the restored areas.