SOW_CronwpointSchool_Remediation.pdf

Scope of Work Expanded Site Characterization with Remedial Alternatives of Oil Contamination Plume(s) at former UST sites and removal of construction stockpile debris at the Former Crownpoint Community School Bureau of Indian Affairs, Eastern Navajo Agency

Crownpoint, New Mexico

PURPOSE

The Bureau of Indian Affairs (BIA), Navajo Region Branch of Environmental Management (BEM) requires the professional services from a qualified Contractor to remove two (2) solid waste (concrete material) stockpiles and restore surface for future use. Additionally, the Contractor is expected to determine the extent of soil and groundwater contamination at the former School property. Through this work, the best remediation alternatives to address the contamination is to be provided. The contractor will identify five (5) remedial action alternatives which includes a No Action Alternative with associated itemized cost estimates for each alternative for mitigation. The BIA will use the findings and results of this work to consult with the Navajo Nation Environmental Protection Agency (NNEPA) on the next course of action to address the contamination.

GENERAL

This project involves three (3) phases of required work where Phase I requires removal of two

(2) stockpiles of construction debris left behind from previous project site activities (Figure 1), Phase II is the Planning Phase where the Contractor will review existing data and records to develop a plan to determine precise locations for sampling (boring). Phase III requires an extensive subsurface investigation of soils and groundwater to complete delineation of contamination horizontally, vertically, and laterally at locations where Underground Storage Tanks (USTs) have been removed. The area of UST removal was also was once excavated of contaminated soils and clean backfill was recontoured. Closure and removal of the former USTs revealed heating oil was released into the soils and groundwater. Although previous investigation has been completed, the extent of contamination is still unknown. This work will require determining the location, extent, and mapping of subsurface oil contaminant plumes within the project area. Work requires review of reports from past investigation studies, field sampling practices, and analytical results as determined from laboratory analysis. This work will require developing remediation alternatives with a cost estimate breakdown. All findings in this investigation will be summarized in a final report with complete results and analytical laboratory results. The report shall contain the site assessment, delineation of contamination, and a minimum of five (5) remedial alternatives along with a no action alternative with estimated costs associated with each alternative.

BACKGROUND

The Bureau of Indian Affairs (BIA) owned and operated the former Crownpoint Community School on a BIA withdrawn Administrative property within the Navajo Nation (Figure 2). The school was in operation since the 1950’s which was at the time operated by the BIA in Eastern Navajo Agency. At the time the School consisted of thirteen buildings where nine (9) buildings had USTs and Building 3001 had two (2) USTs. In 2004, all ten (10) USTs were removed which lead to detection of leaking heating oil throughout the site and thus, the Navajo Nation Environmental Protection Agency (NNEPA) was notified of a release from USTs via correspondence dated March 31, 2004.

Previous work was completed by a Contractor ASTS and documented in their report Closure Report of Underground Storage Tanks, Volume I: Report, Crownpoint (T’iists’oozi’) Community School (August 9, 2004). The School property had not been investigated prior to the UST closure activities. In summary, due to residual contamination remaining in place, ASTS recommended further investigation based on results at former buildings 3001, 3002, 3004, 3005, 3006, 3009 and three (3) remote fill locations associated within the area of former tanks.

In 2008, the BIA retained the RMC Consultants to perform a follow up site investigation, to determine an exposure assessment, and an engineering evaluation cost analysis for remediation.

Based on the results of investigation, RMC Consultants concluded and recommended the following in their final report dated July 2009: (1) No further action was recommended for release that occurred at Buildings 3001, 3002, 3004, and 3008. (2) An engineering evaluation cost analysis to determine the best alternative remedial action was performed to address releases documented at Buildings 3009, and 3010, and recommended remedial action alternative selected was excavation and off-site disposal.

In a letter dated January 7, 2011, the NNEPA provided the following recommendations: (1) Further investigation is required at former UST locations at Building numbers 3001, 3004, 3008, and 3009. (2) Further investigation is required of remote fill and former UST locations at Building 3004 and 3010. (3) No further excavation is required at Building 3001.

In 2011, the BIA retained Terranext who performed further field investigation activities in August 2011. Terranext was contracted to further evaluate the extent of soil contamination within the project area. A final report dated September 2012 was prepared by Terranext where the report details the evaluation of the nature and extent of soil contamination at each UST oil leak and release locations. The release was also quantified by volume of contaminated soils at each release location with an estimated cost for removal/remediation.

In summary, Terranext’s report based on field samples and analytical results describes concentrations of Total Petroleum Hydrocarbons (TPH) in exceedance of 500 mg/kg at the following Buildings 3001, 3004, 3008, 3009, and 3010. Concentrations of benzene, toluene, ethylbenzene, and xylenes (BTEX) were also present Buildings 3004 and 3009. The presence of shallow TPH contaminated groundwater was documented for Building 3010 and thus, the extent of groundwater contamination is still unknown.

In 2012, the BIA Office of Facilities Management and Construction (OFMC) Southwest Region contracted EW Wells Group, LLC (Wells) to conduct a Limited Phase II Environmental Site Assessment (ESA) of all buildings located on the School property which included thirteen (13).

A final report dated July 26, 2012 disclosed the details of the Phase II results. It is notable that although Wells conducted soil samples for lead which was below recommended risk-based screening levels, Wells did not collect soil samples for oil to be analyzed for petroleum products.

At the time of Well’s Phase II ESA, all USTs were removed and were replaced with ASTs.

Wells conducted follow up research with staff from the BIA Navajo Region Branch of Environmental Management (BEM) and BEM’s Project Manager informed Wells that the impacts are being addressed separately by BEM with remediation efforts. Wells did not review any further reports or obtain any information about former USTs on the project site.

After completion of abatement activities, all buildings and structures associated with the former School were demolished prior to 2017. Thus, construction debris in the form of crushed rock and concrete was stockpiled for later use. Included in the stockpile is various solid waste such as metal debris from the prior demolition project. To date, the stockpiles remain on site which will have to be removed as part of this project.

SCOPE

The Contractor shall furnish the necessary personnel, material, equipment, services and facilities to perform the following: test and remove two (2) concrete remnant stockpiles left in place from a former demolition project (Figure 1), develop a project Sampling and Analysis Plan, and delineate soil and groundwater contamination with identifying remedial action alternatives at the former Crownpoint Community School property. The Contractor will fully characterize the vertical and horizontal extent of petroleum contamination in soils and groundwater within the areas of former USTs. This project has three (3) phases. Phase I is testing and removal of two (2) stockpiles of construction debris, Phase II is the Planning Phase where the Contractor will review existing data and records to develop a Sampling and Analysis Plan to determine precise locations for sampling (boring). Phase III will include the Site Assessment, Risk Assessment, and the identification of a minimum of five (5) remedial action alternatives with associated cost estimate breakdown. A No Action Alternative shall so be included. The Contractor shall make a final recommendation of the five (5) alternatives. Comparisons should include cost effectiveness, time period, and site conditions. Work from Phase I, II, and III shall be detailed in a final report.

PHASE I – Stockpile Removal (Figure 1)

Test, excavate, and removal of approximately 5,000 Cubic Yards (CY) of construction debris. Recontour surface and replace with clean soils as needed.

Dispose of construction debris at an approved/permitted landfill.

PHASE II – Planning

Contractor will review existing data and records to develop a sampling plan with QA/QC plan to determine precise locations for sampling.

Review historical data to identify potential data gaps and incorporate a sampling grid to clearly reflect sampling plan with locations.

Sampling plan and QA/QC plan will to be approved by the BIA.

Test for TPH, BTEX, VOC’s, SVOC’s with soils and groundwater Coordinate with BIA Facility Management and Navajo Tribal Utility Authority (NTUA) to locate any subsurface utilities to avoid disturbance and or damage(s).

PHASE III – Site Assessment (Figure 2)

Determine the lateral extent of soil and groundwater contamination by establishing soil boring using an approved boring method. Borings will be placed from points of known contamination extending outward until the lateral extent of contamination is defined. The placement of the borings shall be positioned to provide new and usable data to define the plume and to prevent duplication.

Field screen samples for volatile hydrocarbon contamination following an approved method of ASTM Standards, State of New Mexico or other approved methodology.

Collect a minimum of two soil samples from each boring to be transported to a certified laboratory for analysis of TPH per approved EPA Method, and BTEX per approved method with other approved parameters in accordance with approved sampling plan and QA/QC plan.

For each boring location, an estimated six samples will be field screened using either a photo ionization detector (PID) or flame ionization detector (FID) at depth intervals of three feet. Total depths of borings and the total number of field screening measurements for each boring location are to be based on PID and FID readings. The Contractor will cease boring and field screening activities at non-contaminated depth or when contact with groundwater is reached. Samples are to be submitted following proper chain of custody protocol to an EPA accredited laboratory.

Develop drawings to document the placement of boring and associated data. A table shall eb included using GPS coordinates to locate the borings on the drawings and for future reference.

The drawing shall include BTEX contamination with concentrations in soils and groundwater The drawing shall include TPH concentrations in soils at each borehole The drawing shall include DO concentrations in soils at each borehole The drawing shall include DRO, BTEX, and TPH plumes to scale on a summary drawing A drawing shall depict each individual plume identified.

All drawings shall be the same scale.

A soil contamination concentration map shall be included Geologic cross section with lithologic units, field screening data, laboratory results relative to depth shall be included Sample logs and subsurface soil cross-sections for an explanation of findings shall be presented

RISK ASSESSMENT

Using data gathered in the site assessment, the contractor shall identify the potential threat and evaluate the risk to human health, to soil, to groundwater and environment from the contamination. The Contractor shall further evaluate potential receptors or flow paths for contaminate migration and exposure pathways and prepare a discussion of the investigation in a Tier II format.

REPORT

The contractor will develop a draft and final Report containing (1) a description of the field work performed (2) a description of the subsurface lithology (3) the nature and extent of contamination in subsurface soils (4) cross sections for each contaminate by building (5) quantification of the volume of contaminated soils and engineering evaluation and cost estimate for removal of contaminated soils. Maps and drawings as described previously with surveyed improvement and sampling locations shall be included. Sample logs and subsurface soil cross-sections for suitable for an explanation of findings will be presented in the report.

Any reports generated by the contractor shall be initially submitted as a draft for approval/concurrence by the COR. Contractor shall submit a bi-weekly report of progress and expenditures to the COR. Final reports will be due within two weeks of the return of a draft. All final reports shall be signed by a Professional Engineer or certified environmental professional.

All correspondence shall be confidential until BIA’s discretion to make available to the public.

Delivery Requirement and Period of Performance. The period of performance will be 120 days from the notice to proceed date.

The COR in consultation with the BEM and potentially the NNEPA and United States Environmental Protection Agency (USEPA) will determine the acceptability of work performed and completed by the Contractor. If the Contractor communicates with NNEPA or USEPA, the BIA BEM shall be immediately informed.

Full documentation shall be maintained for all field testing, results, and project completions.

During field situations, the Contractor shall maintain a daily log and record all events relevant to a task order. Any additional sub-contractors shall do likewise. The logs will be signed and closed daily. The logs shall become the property of the BIA. A copy of all bills, and receipts shall be maintained, in case there is a potential claim for cost recovery.

ROLES & RESPONSIBILITY

Contractor shall be responsible for verifying subsurface utilities with the project area prior to re-disturbance of the former project construction site.

Figure

Building 3012

Building 3000

Building 3002

Building 3001Building 3003

Building 3004

Building 3008

Building 3009

Building 3010

Campus Layout Map Crownpoint Community School Figure 2

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