5_-_Performance_Work_Statement.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 5:

Performance Work Statement April 14, 2016

PERFORMANCE WORK STATEMENT

IMPLEMENTATION OF

SUPPLEMENTAL REMEDIAL DESIGN

for the

ASBESTOS RELEASE SITE REMEDIAL ACTION

P16PS00823

Valley Forge National Historical Park Upper Merion Township, Montgomery County, PA

April 14, 2016

1.0 INTRODUCTION

The National Park Service (NPS) is currently completing a long-term remedial action under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) to address contaminated soils within the area of Valley Forge National Historical Park (VFNHP) known as the Asbestos Release Site (ARS). The remediation involves excavation and removal of contaminated soils at depths between 1.0 and 2.5 feet below the existing ground surface and filling of excavated areas with clean fill to original grade; or, capping existing contaminated soils with the addition of 2 feet of clean fill. The following performance work statement provides a general overview of work to be completed; details of all activities to be implemented and the design drawings are provided in the Supplemental Remedial Design Report, Volumes 1 through 4 for the Asbestos Release Site, March 2016 (Revised) (JCO 2016).

2.0 BACKGROUND

Valley Forge was the site of the 1777-78 winter encampment of the Continental Army. VFNHP commemorates the sacrifices and perseverance of the Revolutionary War generation and honors the ability of citizens to pull together and overcome adversity during extraordinary times. Here the Continental Army under Washington's leadership emerged as a cohesive and disciplined fighting force.

In the early 1800s, portions of what is now VFNHP were quarried for limestone. From the early 1890s to 1970s, the Ehret Magnesia Company and its successor, the Keene Corporation, manufactured asbestos insulation products at a plant located on private land within what is now VFNHP. Products were manufactured by combining imported asbestos fibers with magnesium carbonate from dolostone present within local limestone deposits. The manufacturer disposed of asbestos slurry waste by pumping it through pipelines into former quarries or by directing it to a waste channel constructed in a natural drainage swale that runs to the Schuylkill River. Slurry waste placed in the limestone quarries was subsequently covered with soil and in some locations asphalt.

NPS discovered asbestos contamination in 1997 during excavation of a trench for a fiber optic cable. The U.S. Environmental Protection Agency (EPA) completed emergency response activities to stabilize soils and remove the threat of an airborne release of asbestos. After

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emergency response activities were completed, EPA transferred control of the CERCLA long-term response to NPS. NPS proposed a remedy to address the contamination which includes the shallow excavation and off-site disposal of contaminated soils. After the formal public comment period ended, NPS chose the selected remedy and presented this remedy in the Record of Decision (ROD) issued for the Site on January 18, 2007 (JCO 2007).

Tetra Tech Foster Wheeler (TtFW) completed a remedial investigation for the site in 2005 (TtFW 2005). Contaminants associated with the site include asbestos, semivolatile organic compounds (specifically polycyclic aromatic hydrocarbons [PAHs]), and three metals (lead, mercury, and arsenic) at levels that were determined to possibly cause unacceptable risks to humans and/or ecological receptors.

NPS completed a feasibility study in 2006 and identified a preferred alternative to remediate the site which was presented in the proposed plan for cleanup, issued by NPS for public comment on September 22, 2006 (NPS 2006). After the formal public comment period ended on November 6, 2006, NPS chose the preferred alternative as the selected remedy for the site. The selected remedy was presented in the Record of Decision (ROD) issued for the Site on January 18, 2007

(NPS 2007).

NPS contractor, The Johnson Company (JCO), prepared the Final Remedial Design Report, Volumes 1 through 4 for the Asbestos Release Site, June 2012 (JCO 2012). The design presented in this report included 65 excavations in 11 areas of concern (AOCs) identified at the Site. In 2013 and 2014, Frontier Services Inc. (FSI), under contract to NPS, excavated approximately 45,000 cubic yards of contaminated soil from the Site to implement the design provided in the 2012 remedial design (RD) report. All excavated soils were transported to either Waste Managements’ Tulleytown or GROWS East landfill facilities for disposal. In accordance with the RD Report, to verify contaminated soils were removed from the Site, FSI collected soil samples from the sidewalls and bottoms of excavations and submitted the samples to a laboratory for analysis. Some of these horizontal (sidewall) verification samples contained concentrations of contaminants of concern (COCs) that exceeded the remediation goals (RGs) established in the ROD. In response to the RG exceedances identified by these horizontal verification samples (HV samples), NPS collected samples of undisturbed soils in the vicinity of the completed excavations to delineate the boundary between clean and contaminated soil. Samples collected by NPS were identified as new boundary (NB) samples. Data obtained from these NB samples provided the basis for the design of the additional remediation areas described in JCO’s March 2016 revised Supplemental Remedial Design report.

Cleanup of six of the 11 AOCs identified within the ARS was completed during the 2013 – 2014 remedial action. These areas include the Amphitheater Quarry (AMQ), Silicate Bank (SIB), PADOT Quarry (PDQ), Cave Quarry (CVQ), Betzwood Bridge (BZB) and Waste Channel and Rail Bed North (WCRN) AOCs. Brief descriptions of the five AOCs requiring additional remediation are presented below and are shown in the supplemental remedial design report Volume 1, Figures 4-1 through 4-11 and in Volume 3, the design drawings.

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• Maintenance Area Ruins (MAR):

The MAR AOC is east of the Park maintenance area access road and north of County Line Road, southwest of the location of the former Keene plant. Investigations completed at this AOC characterized the area as containing metal debris, including an empty metal storage tank, and a metal pipe that was suspected to be a former waste slurry pipe (TtFW 2005). This area may have been used to dispose of unwanted equipment and materials while the former Keene plant was operational. The COCs identified for this area are lead, mercury, and benzo(a)pyrene.

• Former Keene Plant (FKP):

The FKP AOC includes the building footprint of the former Keene plant. This area is located north of County Line Road, in a landscape dominated by meadows with pockets of trees. The COCs identified for this area are asbestos, lead, mercury, benzo(a)anthracene, benzo(a)pyrene, and dibenzo(a,h)anthracene.

• Historic Bridge (HIB):

The HIB AOC is located south of County Line Road and north of the AMQ AOC, near a historic arched stone bridge. The COC identified for this AOC is asbestos.

• Small Additional Quarry (SAQ):

The SAQ AOC is just north of County Line Road, on the floor of an abandoned quarry.

The COCs identified for this AOC are arsenic and lead.

• Waste Channel and Rail Bed South (WCRS):

The WCRS AOC includes a waste channel used by the former Keene plant to transport waste slurry material to the Schuylkill River. This area also includes a former rail bed where a railroad siding was constructed to connect the quarries and the former Keene plant to the railroad line located in the northern portion of the Site. The discharge of slurry waste from the former Keene plant to the Schuylkill River resulted in deposits of waste slurry material throughout the waste channel area. The COCs identified for this AOC are asbestos, arsenic, lead, mercury, and benzo(a)pyrene.

3.0 SCOPE OF WORK

The selected Contractor will implement the supplemental remedial action which involves excavation and off-site disposal of contaminated soils at depths of 1.0 to 2.5 feet below the existing ground surface, placement of a geotextile fabric warning layer, and filling of excavated areas with clean fill (including topsoil) to original grade; or, placement of a geotextile fabric warning layer over the existing ground surface and capping existing contaminated soils with the addition of 2 feet clean fill (including topsoil) at the five AOCs identified above (MAR, FKP, HIB, SAQ, and WCRS). After placement of clean fill and topsoil the remediated areas will be revegetated to a natural condition.

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The design drawings, excavation locations, material quantities and all other details regarding the implementation of this work are provided in the Supplemental Remedial Design Report for the Asbestos Release Site, March 2016 Revision (JCO 2016). The supplemental remedial design report provides a more detailed description of the scope required to meet the remedial action objectives and RGs presented in the ROD, including how the public and the environment will be protected during implementation of the remedial action.

A description of topics covered by each of the supplemental remedial design report volumes is provided below.

• Volume 1provides background information for the Site; a description of the selected remedy; the basis and method of the design; performance verification methods for evaluating the success of the remedy; decontamination and waste characterization and disposal requirements; soil transportation requirements; institutional controls; description of archeologically sensitive areas; and a summary of ARAR compliance.

• Volume 2 describes the project organization and responsibilities; site management including existing site infrastructure, protection of sensitive areas, site security, air monitoring, contingency procedures, field operations, and records management; the planting and restoration plan; sampling and analysis plan; construction quality assurance plan; estimated material quantities; and the operations and maintenance plan.

• Volume 3 presents the design drawings.

• Volume 4 provides the construction specifications.

4.0 MATERIAL QUANTITIES

An estimate of material quantities that may be used for planning and preparing cost estimates for implementing the supplemental remedial action at the Site has been prepared. The quantities for each remediation area are presented in the supplemental remedial design report, Volume 2, Appendix A, Tables A-1 to A-5; Table 7-1 of Volume 2 summarizes major quantities included in the estimate for each AOC.

5.0 PROJECT DELIVERABLES

The Contractor shall submit to NPS during the completion of this supplemental remedial action the following deliverables:

Remedial Action Work Plan: The Contractor shall submit to NPS for review a draft remedial action work plan (RAWP) within 2 months of participation in the project kick-off meeting. This draft plan will be reviewed by NPS within two weeks of receipt. A final RAWP shall be developed within one week of receipt of NPS comments which incorporates revisions to address those comments. The RAWP shall provide all of the

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elements to be followed during implementation of the supplemental remedial action including the technical approach, project organization (including personnel), communication, reporting, remedial schedule, and subcontractor management. In addition the RAWP shall include the plans identified below. The section of the Supplemental Remedial Design Report that provides the requirements and considerations for each of the plans is identified after the plan name in parenthesis below.

Site Management Plan (see Volume 1, Sections 4.8, and 10; Volume 2, Section 3.0; Volume 4) – The Site Management Plan (SMP) shall include at a minimum the following:

• Property Ownership Information

• Description of Existing Site Infrastructure

• Storm water and erosion controls

• Dust Control

• Protection of Sensitive Areas

• Site Security

• Air Monitoring

• Contingency Procedures

• Field Operations

• Records Management

Contractor Health and Safety Plan (see Volume 2, Section 3.6, Volume 4 Section 01560) – This plan shall specify employee training, protective equipment, medical surveillance requirements, standard operating procedures, and air monitoring.

Quality Assurance Project Plan (QAPP) (see Volume 2, Section 3.5) - The Contractor shall prepare a QAPP including a Sampling and Analysis Plan (SAP) for the perimeter air monitoring activities and imported soils testing detailed in the SMP.

Construction Quality Assurance Plan (CQAP) (see Volume 2, Section 6.0;

Volume 4) – The CQAP shall identify Contractor submittals; field testing; project inspection and reporting requirements; records management, and field and project close-out documentation.

Contaminated Soil Excavation and Handling Plan (see Volume 4 Section 02221)

– The Contractor shall describe proposed procedures for excavating and handling contaminated soil.

Waste Characterization and Disposal Plan (see Volume 1, Section 7; Volume 4 Section 02223) - This plan shall describe wastes generated during the supplemental remedial action and the procedures which the Contractor will follow to ensure excavated soil and decontamination wastes are managed in compliance with applicable federal, state and local laws and regulations.

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Transportation and Disposal Plan (see Volume 1, Section 8; Volume 4 Section 02223) – The Contractor shall describe the following:

• proposed routes for transporting excavated soils to the Contractor’s proposed disposal facilities;

• proposed routes for transporting imported fill to the Site; and

• proposed local construction traffic routes to the different excavations located at the Site and emergency response procedures.

Decontamination Plan (see Volume 1, Section 6; Volume 4 Section 02995) – The decontamination plan shall describe the Contractor’s proposed plan to prevent the inadvertent transport of contaminated media outside the remediation areas.

Planting and Restoration Plan (see Volume 2, Section 4.0; Volume 4 Sections 02821 and 02832) – The Contractor shall prepare a Planting and Restoration Plan that describes the proposed methods for restoring the areas of the Site impacted by the RA.

• Contractor Submittals: The Contractor shall be responsible for providing submittals to

NPS for all construction materials used on the Site, including fill materials, topsoil, erosion control products, and vegetation. NPS will review the submittals and will provide written approval or rejection of the proposed materials or request additional information within 2 days of receipt. Volume 2, Table 6-1of the supplemental remedial design report summarizes the material submittals the Contractor must provide prior to bringing the materials onsite. Details for each submittal requirement are provided in the supplemental remedial design report, Volume 4, Construction Specifications.

• Daily Inspection Reports: Daily inspection reports shall be prepared by the Contractor and submitted to NPS in electronic files via electronic mail. The daily inspection report shall include an accounting of material quantities as documented by weight slips and transportation manifests for all contaminated soils and waste materials transported offsite.

Truck loading inspection log sheets and a Commonwealth of Pennsylvania Residual Waste Transporter Daily Operational Record form are also required to be submitted in the daily reports. The daily reports shall also document the quantity of fill added to each remediation area including the type of fill (common fill, topsoil, etc.), weight, and source and the quantity and type of seed and soil amendments applied and vegetation planted in each area during that day. Any air monitoring data collected on that day shall be attached to the daily report. Photographs documenting the work activities as well as final re-vegetated areas shall be included in the inspection reports submitted to NPS. A sample daily inspection report is provided in the supplemental remedial design report, Volume 2, at the end of Section 6.0.

• Close-out Report: The Contractor shall prepare a draft and final report of the remedial action that fully documents and substantiates the work performed; results of all air

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monitoring; clean fill documentation; waste manifests; record drawings (as-built drawings) and a certification by a licensed Professional Engineer of the completion of the work.

6.0 SCHEDULE

The duration of RAWP preparation and reviews has been estimated as approximately three months. Once the RAWP is finalized and approved by NPS, the selected Contractor shall mobilize to the Site and begin onsite activities. The duration of the remedial construction is estimated to be approximately eight months.

7.0 PROJECT CLOSE-OUT DOCUMENTATION

A final report of the remedial action, including deviations from the RAWP, record drawings (as-built drawings) and a certification by a licensed Professional Engineer of the completion of the work shall be provided by the Contractor.

As-built surveys will be conducted by the selected Contractor’s surveyor to provide the basis for the record drawings. All surveying will be performed by a Pennsylvania Licensed Surveyor using the Pennsylvania State Plane Coordinate System as the datum.

8.0 REFERENCES

JCO 2012. Revised Final Remedial Design Report, Asbestos Release Site, Valley Forge

National Historical Site. June.

JCO 2016. Revised Supplemental Remedial Design Report, Asbestos Release Site. Volumes 1 through 4. March.

NPS 2006. Valley Forge Asbestos Release Site (ARS) Feasibility Study Report, National Park Service, August.

NPS 2007. Record of Decision Valley Forge Asbestos Release Site. January.

TtFW 2005. Valley Forge Asbestos Release Site (ARS) Final Remedial Investigation Report

Volumes I, II, and III. February.

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5 Final PWS Valley Forge ARS Supplemental Remediation 4 14 2016