1. Response Action Work Plan-Draft

RESPONSE ACTION WORK PLAN

LIBBY ASBESTOS SITE

LIBBY, MONTANA

Prepared for:

U.S. Army Corps of Engineers Omaha District

Rapid Response Program Offutt AFB, NE 68113

USACE Contract Number W9128F-04-D-0029

Task Order 027

Prepared by:

3760 Convoy Street, Suite 230 San Diego, California 92111

May 2010

TABLE OF CONTENTS

1.0 Introduction 11

1.1 Background and History 11

1.1.1. Former LA Operations in Libby 12

1.1.2. EPA Activities 12

2.0 Property Selection and Coordination 16

2.1 GeoUnits 18

2.2 Geographic Removal Zones 18

2.3 Property Coordination Team 19

2.3.1. Roles and Responsibilities 19

2.3.2. Property Status Updates 20

2.3.3. Removal Contractor Database 20

2.3.4. Use of Appendix C Property Coordination SOPs 20

2.3.5. Record of Communication 20

2.3.6. Consent for Access 21

2.3.7. Initial Contact with Property Owners 21

2.3.7.1. Properties that Agree to a Removal 22

2.3.7.2. Deferring Properties 22

2.3.7.3. Refusal Properties 23

2.3.8. Property Coordination for Investigation 23

2.3.9. No Further Action Determination 24

2.3.10. Removal Action Required 24

2.4 Removal and Restoration Agreement 25

2.4.1. ERS Coordination 25

2.4.2. Removal General Policies 25

2.4.3. Interior Removal Policies 27

2.4.4. Tree Protection Policies 27

2.4.5. Marking the RRA Design 27

2.4.6. Filling out the Removal and Restoration Agreement 28

2.4.7. Property Owner Relocation 28

2.4.8. Business Closure 29

2.4.9. Coordinating Contact for Removal Questions 29

2.5 Pre-removal Property Coordination 29

2.5.1. Landscape Inventory 29

2.5.2. Generation of the Final Design Packet 29

2.5.3. Documentation Pre-removal 30

2.5.3.1. Documentation for ERS Quick Response 30

2.5.3.2. Documentation of Contaminated Interior Areas 30

2.5.4. Utility Locate Request 30

2.5.5. Scheduling the Removal Action 31

2.5.6. Coordinating Relocation 31

2.6 Property Coordination during Removal Actions 31

2.6.1. Pets and Plants 31

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2.6.2. Tracking Waste Shipment Records 31

2.6.3. Tracking Quality Assurance Reports 32

2.6.4. Tracking Change Orders 32

2.6.5. Daily Close-out Meeting 32

2.6.6. Security Schedule Updates 33

2.6.7. Notifying property owners of the progress of the removal 33

2.6.8. Retrieving Items for Property Owners 33

2.6.9. Anticipating Completion of a Removal Action 33

2.7 Property Coordination Post-removal 34

2.7.1. Collection of Photo and Video Documentation 34

2.7.2. Property Close-out Meeting 34

2.7.3. Property Owner Reimbursement 34

2.7.4. Landscaping 35

2.7.5. Vacuum 36

2.7.6. Close-out Documentation 37

2.8 Data Management for the Property Coordination Team 37

2.8.1. Property ID and GeoUnits 37

2.8.2. Removal Contractor Property Folders 37

2.8.3. Photos, video, CAD files 38

2.8.4. Information the goes to Scribe 38

2.9 Daily Reporting Requirements 38

3.0 ERS Quick Response, Investigation and Design 39

3.1 Roles and Purpose 39

3.1.1. ERS 39

3.2 ERS Protocols and Procedures 39

3.2.1. Exterior Time-critical ERS Procedures 40

3.2.1.1. Interior ERS Time-critical Removals 40

3.2.1.2. ERS Non-time-critical removals 41

3.2.2. ERS Restoration 42

3.2.3. Documentation of ERS Removals 42

3.2.4. OU4 Investigation 42

3.2.5. OU7 Investigation 43

3.3 Investigation Protocols and Procedures 43

3.3.1. Initial Contact 43

3.3.2. Exterior Inspections 44

3.3.3. Interior Inspections 44

3.3.4. No Further Action 45

3.3.5. Investigation Results Data Transfer 45

3.4 Design 46

3.4.1. Surveys 46

3.4.1.1. Preparation of the Survey for Investigation Activities 47

3.4.1.2. Comparing Surveys to the GeoUnit 47

3.4.2. Generation of the Initial Removal and Restoration Design 48

3.4.3. QC of the Initial Design by the Investigation Team 48

3.4.4. Foreman Property Removal Evaluation 49

3.4.5. RRA Removal and Restoration Design 49

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3.4.6. Final Design Preparation 49

3.4.7. Final Excavated Area Map 50

3.4.8. Interior Post-removal Sketch 50

3.4.9. Design Daily Reporting Requirements 51

4.0 Construction Quality Control and Quality Assurance 52

4.1 Roles and Purpose 52

4.2 Three-phase Inspections 52

4.2.1. Preparatory Inspection 52

4.2.2. Initial Inspection 53

4.2.3. Follow-on Inspection 53

4.2.4. Final Inspection 53

4.2.5. TQA QAR Quality Control 53

4.3 Inspection Schedule and Deliverable 54

4.3.1. Assignment of New Properties 54

4.3.2. Set-up and Preparatory Inspection 54

4.3.3. Initial Inspection during Removals 54

4.3.4. Final Inspection 54

4.3.5. Quality Assurance Report 55

4.3.6. Property Completion Checklist 55

4.3.7. Daily Close-out Meeting 55

4.3.8. Exterior Removal Quality Assurance Requirements 56

4.3.9. Exterior Removal Action Documentation 56

4.3.10. Demolitions 56

4.3.11. Interior Abatement Quality Control Requirements 57

4.3.12. Interior Documentation 57

4.4 Health and Safety Requirements 58

4.4.1. Deviations from the Health and Safety Plan 58

4.5 Air Monitoring and Confirmation Sampling 59

5.0 Interior Removal and Restoration 60

5.1 Roles and Purpose 60

5.2 Removal Contractor Quality Control Documentation 60

5.2.1. Health and Safety Requirements 61

5.2.2. Subcontractor Activities 61

5.3 Pre-Worksite Activities 61

5.4 Documentation 62

5.5 Site Preparation 62

5.5.1. Removal Contractor Site Preparation Requirements 63

5.5.2. Protection of Existing Features 65

5.5.3. Containment Setup 66

5.5.4. Personnel Decontamination 68

5.5.5. Equipment Decontamination 69

5.5.6. Moving/Cleaning of Household Items 69

5.6 Vermiculite Removal from Attics 69

5.6.1. Design-build Interior Removals 69

5.6.2. Interior Removal Guidelines 70

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5.6.3. Sealing of Penetrations 71

5.6.4. Bulk Removal 71

5.6.5. Detailed Cleaning 72

5.6.6. Blocking 72

5.6.7. Encapsulation 73

5.6.8. Ventilation and Pre-Existing Damage Inspection 74

5.6.9. Building Material Demolition 74

5.7 Vermiculite Removal from Areas Anticipating a Remodel 75

5.8 Vermiculite and LACS Removal from Crawlspaces 75

5.8.1. Soil Removal from Crawl Spaces 75

5.8.2. Application of Concrete or Shotcrete 76

5.8.3. Confirmation Soil Sampling 76

5.9 Personal Breathing Zone Air Sampling 76

5.10 Final Clearance Air Samples 77

5.11 Interior Restoration 78

5.11.1. Property Owner Repair of Pre-existing Conditions 78

5.11.2. Attic Accesses 78

5.11.3. Insulation 79

5.11.4. Interior Furnishing or Miscellaneous Items 79

5.11.5. Electrical Repairs and Pre-existing Conditions 80

5.12 Government Inspection 80

5.12.1. Post-Cleanup Inspection 80

5.12.2. Removal Final Inspection 81

5.13 Change Orders 81

5.13.1. Interior Change Orders during Removal 81

5.13.2. Interior Change Orders during Restoration 82

5.14 Property Security 82

5.15 Callbacks 82

6.0 Contaminated Soil Removal 83

6.1 Purpose and Roles 83

6.2 Removal Activity Quality Control Documentation 83

6.2.1. Health and Safety Requirements 83

6.3 Subcontractor Activities 84

6.4 Pre-Worksite Activities 84

6.5 Site Preparation 86

6.5.1. Containment Setup 89

6.5.2. Protection of Existing Features 91

6.5.3. Personnel Decontamination 91

6.5.4. Equipment Decontamination 92

6.5.5. Equipment Pathways 93

6.5.6. Equipment Transport 94

6.5.7. Trees, Shrubs, and Other Debris 94

6.5.8. Concrete, Decks, and Other Items 94

6.5.9. Cleaning of Yard Items 95

6.5.10. Stumps 95

6.6 Soil Excavation 96

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6.6.1. Tree Protection Policies 96

6.6.2. Procedure for Soil Removal around Trees 96

6.6.3. Vermiculite Quality Control Inspections 97

6.6.4. Contaminated Soil Removal 97

6.6.5. Excavation Floors Greater than One Percent LA 99

6.6.6. Stockpiling Contaminated Soils 99

6.6.7. Confirmation Soil Sampling 99

6.6.8. Change Orders 100

6.6.9. Transportation and Disposal 100

6.6.10. Control of Surface Water 102

6.6.11. Pollution Prevention 102

6.7 Structure Demolition 102

6.7.1. Documentation 102

6.7.2. Disposal of Demolition Debris 103

6.8 Air Sampling During Contaminated Soil Removal 103

6.8.1. ACS Stationary Air Sampling 103

6.8.2. Personal Breathing Zone Air Sampling 104

6.9 Property Security 104

7.0 Restoration Activities 105

7.1 Roles and Purpose 105

7.2 Restoration Preparation 105

7.3 Exterior Restoration 106

7.3.1. Fill Material Type and Specification 106

7.3.2. Common Fill Material Specifications 106

7.3.3. Topsoil Specifications 107

7.3.4. Other Fill Material 107

7.4 Placement, Grading, and Compaction 107

7.5 Sub-grade Fill Requirements 108

7.5.1. Topsoil Fill Requirements 108

7.5.2. Placement Grading 108

7.5.3. Compaction of Graded Materials 109

7.5.3.1. Common Fill Compaction and Placement 109

7.5.4. Topsoil Compaction and Placement 110

7.5.5. Fences, Decks, and Other Exterior Items 111

7.5.6. Pre-existing Damage to Propane Tanks 111

7.5.7. Landscaping 111

7.5.8. Vegetation Damage 112

7.5.9. Change Orders 112

7.6 Government Inspection 112

7.6.1. Post-removal Inspection 112

7.6.2. Removal Final Inspection 113

7.6.3. Call Backs 113

8.0 Mine Operations 115

8.1 Roles and Purpose 115

8.2 Final Soil Disposition 115

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8.3 Mine Personnel Training Requirements 115

8.4 Health and Safety Requirements 115

8.4.1. Mine Personnel Protection Requirements 116

8.4.2. Personal Air Monitoring Requirements 116

8.5 Mine Site Disposal Operations 117

8.5.1. Staging Soil at the Amphitheater 117

8.5.2. Transporting Soil to the Mine 117

8.5.3. Transportation Requirements 118

8.5.4. Equipment Decontamination 118

8.5.5. Personnel Decontamination 118

8.5.6. Water Use and Supply 119

8.5.7. Decontamination Derived Waste Water 120

8.5.8. Spill Prevention Measures 120

8.5.9. Dust Control Procedures 120

8.6 Mine Operations Documentation 120

8.6.1. Waste Shipment Records 121

8.7 Debris Removal 121

8.8 Site Security 121

9.0 Landfill Operations 123

9.1 Roles and Purpose 123

9.2 Landfill Personnel Training Requirements 123

9.3 Health and Safety Requirements 123

9.3.1. Landfill Personnel Protection Requirements 123

9.3.2. Personal Air Monitoring Requirements 124

9.4 Site Disposal Operations 124

9.4.1. Traffic Control Plan 125

9.4.2. Transportation Requirements 125

9.4.3. Equipment Decontamination 125

9.4.4. Personnel Decontamination 126

9.4.5. Decontamination Pad Maintenance and Inspection 126

9.4.6. Water Use and Supply 127

9.4.7. Decontamination Derived Waste Water 127

9.4.8. Spill Prevention Measures 127

9.4.9. Dust Control Procedures 128

9.5 Landfill Operations Requirements 128

9.6 Disposal Operations Documentation 128

9.6.1. Waste Shipment Records 129

9.7 Site Security 129

10.0 Construction Management 130

10.1 Daily Quality Control Report 130

10.2 Daily Work Order 131

10.3 Daily Cost Reports 131

10.4 Weekly Progress Report 131

10.5 Weekly Variance Report 131

10.6 Daily Close-out Meeting 132

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10.7 Scheduling 132

10.7.1. Notification of MDOT 132

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APPENDICES

Appendix A Forms

Appendix B Construction Specifications

Appendix C Property Coordination Standard Operating Procedures

Appendix D Response Action Work Plan Sampling and Analysis Plan

Appendix E Standard Operating Procedures for Sample Coordination Duties

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LIST OF ABBREVIATIONS

ACM Asbestos Containing Material ACS Asbestos Contaminated Soil ASTM Association Society of Testing Material ARM Administrative Rules of Montana AHA Activity Hazard Analysis BGS Below Ground Surface BNSF Burlington Northern Santa Fe BZ Breathing Zone CDM Camp, Dresser, and McKee CFR Code of Federal Regulations CQA Construction Quality Assurance CRZ Contamination Reduction Zone CSHASP Comprehensive Site Health and Safety Plan CSS Contaminant Screening Studies DI Detailed Investigation DOT Department of Transportation DCOM Daily Close-out Meeting DQCR Daily Quality Control Report DWO Daily Work Order EPA U. S. Environmental Protection Agency Region 8 ERS Environmental Resource Specialists FSDS Field Sample Data Sheet GPI General Property Investigation GRZ Geographic Removal Zones HAZWOPR Hazardous Waste Operations HEPA High Efficiency Particulate Air HOH Head of Household IAG Interagency Agreement LA Libby Amphibole LACS Libby Amphibole Contaminated Soil Landfill Lincoln County Landfill Asbestos Cell LO/TO Lock-out/Tag-out MCA Montana Code Annotated MDEQ Montana Department of Environmental Quality Mine Former W.R. Grace Rainy Creek Mine Site

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LIST OF ABBREVIATIONS (cont.)

NESHAP National Emissions Standard for Hazardous Air Pollutants NPE Negative Pressure Enclosure OSHA Occupational Safety and Health Administration OU Operable Unit PAPR Powered Air-purifying Respirator PCC Property Completion Checklist PCT Property Coordination Team PIC Property Information Coordinator PPE Personal Protective Equipment QAR Quality Assurance Report RAWP Response Action Work Plan Revision 3.0 RAWP SAP RAWP Sampling and Analysis Plan RC Removal Contractor ROW Right-of -Way RRA Removal and Restoration Agreement RCD Removal Contractor Database SHSO Site Health and Safety Officer SI Screening Investigation Site Libby Asbestos Superfund Site SOP Standard Operating Procedure STEL Short-term Exposure Limit TAPE Troy Asbestos Property Evaluations TEM Transmission Electron Microscopy TQA Third Party Quality Assurance TPIC Third Party Independent Contractor TWA Time Weight Average UA Use Areas (e.g. SUA, CUA, LUA, etc.)

USACE United States Army Corps of Engineers Rapid Response Program VOLPE US Department of Transportation John A. Volpe Center

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1.0 Introduction

The purpose of the Response Action Work Plan (RAWP) is to provide the step-by-step process for removing sources and possible sources of Libby Amphibole asbestos (LA) from residences and businesses within the boundaries of the Libby Asbestos Superfund Site (Site) once they are identified at levels exceeding current action levels. Other guidance documents exist on this site and will be utilized via reference in the RAWP and as stand alone standard operating procedures (SOPs) or criteria documents.

The Libby Asbestos Superfund Site is managed by the US Environmental Protection Agency (EPA) with field execution and site management conducted by the US Army Corps of Engineers (USACE) through an Interagency Agreement (IAG). Two principal contractors will be utilized for site work under the current removal action implementation process: the Removal Contractor (RC) and the Third-party Independent Contractor (TPIC). The Third Party Independent Contractor is responsible for independent Third Party Quality Assurance (TQA) inspection of removal and restoration performed by the RC. Other site tasks will be divided among the Property Coordination Team, the Design Team, the Sample Coordination Team, Investigation Team, Environmental Resource Specialist (ERS) Team, and the Construction Management Team, as outlined in this plan.

Members of those teams will be drawn from the RC and the TPIC as appropriate based on staffing levels and experience.

Additionally, EPA directly contracted Camp, Dresser, and McKee (CDM) to perform investigations and ERS work utilizing the USEPA Remedial Action Contract. Both of these tasks have a direct effect on the removal process and will be referenced in this plan.

OU7 is managed primarily by the Montana Department of Environmental Quality (MDEQ). All activities in OU7 will be coordinated with MDEQ.

1.1 Background and History

Vermiculite was discovered 7 miles northeast of Libby, Montana in 1881 by gold miners.

In the early 1920s, Mr. Edward Alley began initial mining operations on the vermiculite ore body located approximately 7 miles northeast of Libby. Full-scale operations began later that decade under the name of the Universal Zonolite Insulation Company. This ore body contains a solid solution series of amphibole asbestos fibers with compositions including tremolite, actinolite, richterite, and winchite (herein referred to as LA). Unlike chrysotile asbestos, LA was not used commercially on a wide scale. During the mine's operation, while vermiculite was used in a variety of products (including insulation and

HFS-PRI Rapid 11 construction materials, as a carrier for fertilizer and other agricultural chemicals, and as a soil conditioner), LA was considered a byproduct of little or no value.

The vermiculite ore was mined using standard strip mining techniques and conventional mining equipment. The ore was then processed in an onsite dry mill to remove waste rock and overburden material. Once processed, the ore was transported from the mine to the former screening plant, where the ore was sorted into five size ranges. After the sorting process, the material was shipped to various locations across the United States, for either direct inclusion in products or for "expansion" prior to use in products. Expansion (also known as "exfoliation" or "popping") was accomplished by heating the ore, usually in a dry kiln, to approximately 2,000 degrees Fahrenheit. This process explosively vaporizes the water contained within the phyllosilicate structure causing the vermiculite to expand by a factor of 10 to 15. This produces the vermiculite material most commonly sold as a soil amendment for gardens and greenhouses.

1.1.1. Former LA Operations in Libby

In Libby, operations handling this material occurred at four main locations: the mine and mill located on Rainy Creek Road on top of Zonolite Mountain; the former screening plant and railroad loading station located at the intersection of Highway 37 and Rainy Creek Road and directly across the Kootenai River, respectively; the former expansion/export plant (the former export plant) located immediately west of Highway 37 where it crosses the Kootenai River; and at the former expansion plant located at the end of Lincoln Road, near 5th Street. The Lincoln Road Expansion Plant went offline sometime in the early 1950s. In 1963, W.R. Grace purchased Zonolite and continued vermiculite mining operations in a similar fashion. In 1975, a wet milling process was added that operated in tandem with the dry mill until the dry mill was taken offline in 1985. The wet milling process was added to reduce dust generation of the milling process. Expansion operations at the former W. R. Grace export plant ceased in Libby sometime prior to 1981, although the area was still used to bag and export milled ore until mining operations were stopped in 1990. Before the mine closed in 1990, Libby produced about 80 percent of the world's supply of vermiculite.

1.1.2. EPA Activities

Since 1999, EPA has been conducting sampling and cleanup activities to address highly contaminated areas in the Libby Valley. The EPA inspection was initiated in response to media articles, which detailed extensive asbestos-related health problems in the Libby

HFS-PRI Rapid 12 population. While at first the situation was thought limited to those with direct or indirect occupational exposures, it soon became clear that there were multiple exposure pathways and many persons with no link to mining-related activities were affected.

Typically, the LA contamination found in the Libby Valley comes from one or some combination of "primary" sources: vermiculite mining wastes, vermiculite ores, vermiculite processing wastes, bulk residuals from vermiculite processing, "LA-containing rocks," or LA-containing vermiculite insulation. Asbestos from these primary sources has been found in interior building dust samples and local soils, which in turn act as secondary sources. To date, EPA’s goal has been to find and identify areas with elevated levels of LA (the primary sources) and to remove them. EPA has conducted removal of Asbestos Containing Soil (ACS) at the former export plant location, the former screening plant and adjacent properties, and residential properties with LA source materials present. Removal actions have also been performed at three schools in Libby.

Cleanup work in Libby is ongoing and includes the removal of LA-containing media that include: vermiculite-containing materials (including vermiculite insulation and building materials with vermiculite additives), soil, and dust from residential, commercial, and industrial properties.

The vermiculite encountered in structures is typically found in attics and exterior walls where it is used for insulation. In some cases, vermiculite insulation is found in interior and exterior walls due to sifting from the attic. In rare cases, vermiculite is found as an additive in building materials such as plaster, mortar, and concrete. The LA-contaminated soil encountered is generally due to vermiculite used as a soil amendment in flowerbeds and gardens, for leveling of low spots, and for backfilling of utility trenches.

The Site has been divided by the EPA into 8 Operable Units (OU) to facilitate clean-up activities as follows:

• OU1. The former Export Plant is situated on the south side of the Kootenai River, just north of the downtown area of the City of Libby, Montana. OU1 includes the embankments of Highway 37, the former Export Plant, and Riverside Park. The property is bounded by the Kootenai River on the north, Montana Highway 37 (forthwith referred to as Highway 37) on the east, the Burlington Northern Santa Fe (BNSF) railroad thoroughfare on the south, and State of Montana property on the west.

• OU2. OU2 includes areas impacted by contamination released from the former Screening Plant. These areas include the former Screening Plant (Subarea 1), the

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Flyway property (Subarea 2), a privately-owned property (Subarea 3), and the Rainy Creek Road Frontage and Highway 37 right-of-way (ROW) adjacent to Rainy Creek Road (Subarea 4).

• OU3. The mine OU includes the former vermiculite mine and the geographic area (including ponds) surrounding the former vermiculite mine that has been impacted by releases from the mine, including Rainy Creek and the Kootenai River. Rainy Creek Road is also included in OU3. The geographic area of OU3 is based primarily upon the extent of contamination associated with releases from the former vermiculite mine.

• OU4. OU4 is defined as residential, commercial, industrial (not associated with former W.R. Grace Company operations), and public properties, including schools and parks in and around the City of Libby, or those that have received material from the mine not associated with Grace operations. OU4 includes only those properties not included in other OUs. Removal activities conducted adjacent or within state and local ROWs as part of an OU4 removal are documented in accordance with subsection 3.4.7.

• OU5. OU5 includes all properties that were part of the former Stimson Lumber Mill and that are now owned and managed by the Kootenai Business Park Industrial Authority.

• OU6. The rail yard owned and operated by BNSF is defined geographically by the BNSF property boundaries and extent of contamination associated with BNSF rail operation. Railroad transportation corridors are also included in this OU and have not been geographically defined.

• OU7. The Troy OU includes all residential, commercial, and public properties in and around the Town of Troy, approximately 20 miles west of downtown Libby.

Non-ERS residential and commercial removal actions will commence in OU7 starting in 2010. MDEQ is the lead agency for all Site work in OU7. All removal action work in OU7 will be coordinated with MDEQ and its contractor, TetraTech.

• OU8. OU8 is comprised of the US and Montana State Highways and secondary highways that lie within the boundaries of OU4 and OU7.

Through an IAG, the US Department of Transportation John A. Volpe Center (VOLPE) assisted EPA with direction and execution of Site activities until the end of the 2009 season. The site was managed through a fixed-price “design-bid-build” mechanism. An A & E firm contracted by VOLPE designed removals based on data collected in the field.

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The design was submitted for bid to removal contractors, who performed the removals under the oversight of CDM personnel.

Beginning in August 2009, the US Army Corps of Engineers Rapid Response program (USACE) began execution of field operations at the request of EPA. USACE and its contractor instituted a cost reimbursable fixed fee “design-build” process to the removal activities, thereby removing the bid process and change orders that increase the time and cost of removal activities. The design-build process allows USACE contractors to respond instantly to changed field conditions which affect the removal design.

This RAWP outlines the current cost-reimbursable process for removals at the Site from first contact with the property owner to completion of post removal documentation.

Forms referenced in this process will be noted at the end of each section where they are applicable. A complete list of forms and how forms are processed is Appendix A.

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2.0 Property Selection and Coordination

Properties eligible for further investigation and possible removal action clean-ups will be added to the Eligible Property List. Properties that become eligible for a clean-up will be marked as such in the EPA’s Scribe database. Current eligible properties are generated from various sources, as outlined below:

• Past investigative work at the Libby site includes an initial round of Phase 1 investigations that were implemented from 1999 to 2002 at the outset of the project to determine the extent of the LA contamination. Contaminant Screening Studies (CSS) were conducted from 2002 and the majority of them were completed by 2003, however periodic CSS investigations have been conducted since 2003. During the Phase 1 and CSS investigations properties were either classified based on the former 2003 EPA action memorandum removal criteria as no remediation required, remediation required, or additional information needed.

Some properties that were previously investigated may have documented contamination above the current removal criteria, but have not had a removal action. These properties require further detailed investigation to determine specific areas requiring removal actions prior to completion of the removal design. If the CSS is of insufficient detail to qualify a property for a Detailed Investigation (DI), the property will be grouped with properties that have had no investigation work performed to date.

• There are properties that lay within OU4 boundaries that have had no previous investigation. Through a door knocking campaign operated by the Property Coordination Team (PCT) these properties will be prioritized for investigation and ultimate inclusion in the removal process. When the status of a property changes, the PCT will notify the Property Information Coordinator (PIC) to update the information fields within the EPA Scribe Database. The PIC will ensure that the new status is updated in the Scribe database. Through the use of the campaign, the following will be determined:

o The correct E911 address o Property Owner information o If children reside on the property or are frequent visitors to the property o If the property owner is aware of vermiculite present in the interior attic, crawlspaces or any accessible interior areas located in the home or on the property, i.e. well houses, barns, sheds, etc.

o If more than one property address is located within the GeoUnit (as determined with the LibbyGeo database and the Mobile Mapper application) o If more than one GeoUnit is located within one property address (as determined with the LibbyGeo database with the Mobile Mapper application)

HFS-PRI Rapid 16 o If the property owner is willing to have a clean-up performed if a removal trigger is discovered during the investigation process

Once the correct E911 address is determined, a Property ID number will be assigned to the address from a sequential list provided by EPA.

Once initial contact is made as part of the door-knocking campaign, the above information will be collected, but no removal will be promised. Consent for Access forms will be collected if appropriate. The gathered information will be submitted by the PCT to the PIC. The PIC will ensure that the property information is updated in the Scribe database.

In an effort to eliminate the remaining interior contamination in OU4, properties with possible interior contamination will be added to the Eligible Property List and completion of investigations will be a priority on these properties throughout the site.

Properties that have not had an investigation, do not have a suspected interior removal trigger or active children will begin to be investigated at the discretion of the EPA.

• Properties that were previously remediated under old criteria that did not require the removal of visual vermiculite, nor did the investigations require a protocol for the identification of visual vermiculite across an entire property in non-specific use areas. These properties may require further investigation and remediation to remove impacted soils that were not removed under the old removal criteria.

These properties may be added to the Eligible Property List at the discretion of the EPA.

• Many removal areas are adjacent to alley ways and right of ways (ROWs), where contamination is dispersed across the border between the two. When the removal area of a property is in contact with an alley way with visible contamination, the alley way or ROW will be removed after permission from the City of Libby or the City of Troy, or the Montana Department of Transportation is granted.

• If, while excavating a property or an alley, visible contamination is observed extending into other properties, the property owner will be approached and a request will be made to immediately pursue the visible vermiculite. A Screening or Detailed investigation (depending on the where the vermiculite was observed) will be pursued on these properties to mitigate the effect of cross-contamination.

• Properties where the property owner is planning renovations or remodels may activate the ERS system. Non-time critical ERS Quick Response action will be converted into a DI. A full removal will be planned that will address the planned improvements to the property and the normal removal guidelines.

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• The MDEQ performed investigations on properties in Troy using guidelines for characterization outlined in the Troy Asbestos Property Evaluations (TAPE). The investigations were mostly completed in 2009 with the resulting data having an informational content partway between a Screening and a Detailed Investigation.

Additional TAPE investigations will commence in 2010, along with a Detailed Investigations as outlined in the OU7 GPI SAP. The first round of removal actions are planned for the summer of 2010 on these properties.

Removal actions will be pursued on newly investigated properties only to the extent that the current removal criteria are met or with the direction of EPA.

2.1 GeoUnits

GeoUnits are geospatial polygons that are employed by the EPA to track investigation and removal activities at properties within the Site. Each E911 address is assigned a Property ID number (AD number) that corresponds to a GeoUnit. The TPIC and RC will attempt to perform complete removals by GeoUnit.

After a survey has determined the property boundary, those boundaries will be rectified with the GeoUnit polygons in LibbyGeo, as detailed in Section 3.4.2.

2.2 Geographic Removal Zones

Property selection will be primarily based on geographic grouping of properties within the OU4 and OU7 property boundaries. The exception is properties with interior removal triggers as noted in Section 2.0. Property selection will be managed on layer created in the LibbyGeo database that outlines the boundaries of Geographic Removal Zones (GRZs). The grouping of removal areas is to facilitate optimization of field crew and equipment utilization, especially trucking, so that transit time between properties, and its associated cost, can be reduced and so that oversight and management personnel can more effectively utilize their time. Implementation of this approach requires coordination with property characterization scheduling. Optimization of the process requires a buildup of a sufficient pool of available properties (estimated available backlog of 50 properties is seen as reasonable). Scheduling of removals within a geographic area will accommodate property owner needs to the extent possible. Properties on the Eligible Property List will be grouped into one of the following GRZs:

• Area 1-Downtown Libby

• Area 2- South of Libby

HFS-PRI Rapid 18

• Area 3- Golf Course Area Southeast of Libby

• Area 4- Highway 37

• Area 5- Kootenai River Road

• Area 6- Pipe Creek

• Area 7- Troy

EPA may also request the inclusion of larger commercial properties into the schedule that may be addressed independently of geographic grouping.

Some attempt will be made to vary the time of year for subsequent visits to each GRZ.

This will afford an opportunity for removal on those properties where the removal is dependent on season (gardens, et al.), though a specific time of year will not be specified to the property owner.

Property owners within OU4 and OU7 will be notified of the process of executing removals in Libby by geographic area and that the removal teams will cycle through those areas until removals are complete.

At the end of each removal season, sufficient investigations will be performed to have the capacity to begin the next season without delay when the weather permits. These carry-over properties will be the first removals executed in the spring.

If a property has gross exterior contamination and active children, property owners may petition EPA to be considered a priority for investigation and potential remediation regardless of the schedule status of their geographic zone.

2.3 Property Coordination Team

2.3.1. Roles and Responsibilities

The Property Coordination Team (PCT) works with property owners and tenants, (hereafter referred to collectively as “property owners”), residential and commercial, during the removal process. The PCT initializes and manages the interaction with property owners during the removal process. The PCT represents the property owner while coordinating the removal action with the Construction Management Team. From the initial contact to the delivery of property completion forms, the PCT serves as a property owner’s point-of-contact for questions, requests or concerns regarding the removal process.

HFS-PRI Rapid 19

The PCT is responsible for fulfilling the EPA data management requirements for the RC.

The PCT performs day-to-day tasks required to support, document, communicate and resolve removal issues. These tasks may include tending to plants and animals in a relocated resident’s home, tracking waste manifest to determine the quantities of contaminated materials removed from a property, processing Change Order forms, uploading property remediation photos, and coordinating the site security.

2.3.2. Property Status Updates

The Eligible Property List, Investigation Property List and the Property Refusal List will be maintained by the PCT. Property status information will be updated in the Removal Contractor Database (RCD). The PIC will ensure that the new status is updated in the Scribe database. Changes to property status will be communicated daily to the PIC using the Property Coordination DQCR. The PIC will ensure that the status is updated in the Scribe database.

2.3.3. Removal Contractor Database

The PCT utilizes the Removal Contractor Database (RCD), (currently a MS Access database) to facilitate tracking the data, changes in status, documentation and other activities that take place at a property during a remediation. This database contains queries that can be used to assess the status of the remediation at a property and to assign the “tasks” to personnel necessary to facilitate the removal process.

Data that must be reported to the PIC for updating the Scribe database will be submitted to the PIC the same day the RCD is updated.

2.3.4. Use of Appendix C Property Coordination SOPs

The process of coordinating with property owners and tracking the required documentation is outlined and Appendix C. The PCT will use this appendix to standardize interactions with property owners. The forms referenced in Appendix C are listed alphabetically in Appendix A Site Forms.

2.3.5. Record of Communication

All contact with the property owners will be documented in the Record of Communication in the specific property folder. The complete Record of Communication

HFS-PRI Rapid 20 will be delivered to the Records Center Manager as part of the property folder transfer that occurs after the removal action is complete at each property.

In OU7, the initial contact with property owners will be performed by the MDEQ contractor, and documented in the MDEQ property interaction tracking database. After the initial contact, the PCT will contact property owners for removal and relocation purposes.

2.3.6. Consent for Access

The RC’s Consent for Access form will be signed by the property owner prior to the initiation of any on-site property investigation. This form will be signed when the property owners are initially contacted by the PCT, or prior to investigation activities when the Investigation Team arrives on site. The PCT will be responsible for ensuring that the form is signed, or in rare instances, for informing the Investigation Team when the form has not been signed prior to the investigation. In the case where the Consent for Access has not been signed at the initial meeting, the PCT will coordinate with the property owner and the investigation team to ensure the homeowner is present when the team arrives at the site. It will be the responsibility of the Investigation Team to have the property owner sign the form prior to the investigation activities, and then to submit the form to the PCT by close of business that same day. The original Consent for Access form will be maintained in the RC property folder until the removal action at the property is complete. Upon completion it will be submitted to the Records Center Manager for archiving in the OU where the removal was performed.

2.3.7. Initial Contact with Property Owners

When initial contact is made by the PCT, property owners will be asked about their willingness to participate in the investigation/removal process for the current field season, or the spring of the following season if the investigation is intended to build up a property surplus for the initiation of the next year’s operation season. The PCT will explain the process of performing removals by GRZs, and that removals in their zone will only occur while removal crews are cycling through the zone. Deferring until a later date means waiting for the next time when removal crews cycle through their GRZ.

Property owners will be given the option of accepting possible removal in the current season and moving forward with the investigation process provided that they intend to see the process through to completion. This offer has three common outcomes: an owner

HFS-PRI Rapid 21 will want to proceed with the removal, the owner will want to defer the removal, or the owner will refuse the removal.

This event is recorded on the Property Coordination Daily Quality Control Report (DQCR). Changes to the property status may occur during this contact. The Property Coordination DQCR will record the changes. A copy of this DQCR will be submitted to the PIC, who will record the change in the Scribe database.

If the property owner or tenant was contacted as part of the door-knocking campaign, the data will be collected as required by Section 2.0. No removals will be offered as part of this campaign until after a screening or investigation has been performed by the property investigation team.

2.3.7.1.Properties that Agree to a Removal

If the property owner accepts the offer of inclusion into the removal process, the property moves to the Investigation Property List. The PIC is notified of the change in the property status. The removal process will be explained to the property owner. The PCT will start a RC Property Folder, unique to each Property ID, to collect data and correspondence associated with the property, and will begin inputting property data into the RCD.

The PCT will inform the property owner that supplemental visits to the property will be necessary as part of the pre-removal investigation process. The PCT will request from the property owner that supplemental visits to the property for exterior work be performed without the property owner having to be present so as to facilitate easier scheduling. If the property owner agrees, then courtesy calls will be required for supplemental visits, but an appointment will not be necessary. If the property owner refuses and insists on being present during surveying, investigation activities, or the preparatory removal evaluation, those instructions will be communicated by the PCT to the surveyor, the Investigation Team and the foremen. The PCT will document in the property folder and in the RCD whether or not the property owner is willing to allow the visits without an appointment.

2.3.7.2.Deferring Properties

Property owners that choose to wait until the next time removal activities are being conducted within their GRZ will remain on the Eligible Property List. The removal offer

HFS-PRI Rapid 22 will be extended to the property owner the next time removal activities are scheduled to occur in their GRZ.

2.3.7.3. Refusal Properties

Property owners refusing clean-up activities may be removed from the Eligible Property List. The PCT will make a note in the RC property folder that access for removal activities is currently not allowed. The PCT will inform the PIC to note in the Scribe database that the property owner currently refuses clean-up. The removal action will not be offered to the property owner again until the end of the project. As the project nears completion and if the property remains adamant about refusing the clean-up, a Property Refusal Form will be completed by PCT and placed in the property folder. Property owners may remove themselves from the Refusal Property List by contacting the PCT, the EPA hotline number, or the MDEQ hotline number to place them back in the Eligible Property list. It is not anticipated that the Property Refusal Form will be necessary in the 2010 season.

This event is documented on the Property Coordination DQCR and submitted to the appropriate PIC for updating property status in the Scribe database.

2.3.8. Property Coordination for Investigation

Surveys will be ordered as soon as the property owner accepts the removal. The PCT will coordinate ordering a survey for all properties where a GPI will be performed by informing the Design Team when a property becomes eligible for an investigation. The surveyors will be given the property address, property owner name, and a phone number.

If the property owner has requested to be contacted prior to any visits to their property, the survey team will be required to call to the property owner to set-up an appointment.

Investigations should be scheduled as soon as possible following acceptance of the removal and receipt of a survey. Once the survey has been delivered and prepared by the Design Team, the PCT will coordinate with the Investigation Team to make an appointment for investigation. The PCT will notify the property owner that the Investigation Team will need access to all structures on the property, including any residence or out-buildings, and would prefer to have the property owner on-site for the investigatory/site history questions. The property owner will also be notified that the interior investigation should be completed during the initial visit and structures will not

HFS-PRI Rapid 23 need to be accessed again until the Interior Property Removal Evaluation, with the exception of rare follow-up needs like data gaps or photographic documentation.

Subsequent access to the property by the Investigation Team may be necessary. The property owner will be notified that the Investigation Team may have to return to complete their sampling effort, and will attempt to contact the property owner if they need to return, but will access the property regardless of whether contact is made if that is agreeable to the homeowner.

Details of this conversation are recorded in the property’s Record of Communication.

2.3.9. No Further Action Determination

The Investigation Team in OU4 will issue a “Letter of No Further Action” if no removal action is required at the property under current EPA removal criteria. The PCT is notified when a letter of “Letter of No Further Action” is issued by the Investigation Team, and receives a copy of this letter for the RC property files. Upon receipt of this letter, the PCT will close out the file and submit the Record of Communication and any other documents gathered on the property to the OU4 Record Center Managers.

Properties lying within the OU7 boundaries are to comply with MDEQ removal and no further action criteria. MDEQ is responsible for issuing notice to property owners when no removal action is necessary without assistance from the PCT.

2.3.10. Removal Action Required

When contamination is identified at a property and a removal action is required, the PCT calls the property owner to inform them that a removal action is necessary on their property. The property owner is notified that that a preparatory removal evaluation will be necessary prior to the Removal and Restoration Agreement (RRA) meeting, and that the foreman will attempt to contact them prior to the property visit. If the property owner has requested to be present during all property visits, the foremen will be notified to coordinate with the property owner. On some properties, the request may be made to have the property owner present as a resource for this evaluation. The call is documented in the property’s Record of Communication.

The Design Team prepares the initial design as discussed in Section 3.2.4. This design is submitted to the Foremen. The Foremen will visit the property to compare the initial design with actual site conditions, identifying any issues that may affect the removal

HFS-PRI Rapid 24 action and to estimate the time and resources required to perform the removal as discussed in the Interior Removal and Restoration Section 5.0 and Contaminated Soil Removal Section 6.0 of this RAWP. The Design Team will incorporate the notes from the preparatory removal evaluation into the design, generating the RRA design. The completed RRA design will be submitted to the PCT. Upon receipt of the RRA design, the PCT calls the property owner to schedule a RRA meeting.

This call is documented in the property’s Record of Communication.

2.4 Removal and Restoration Agreement

The purpose of RRA meeting is to ensure that property owners fully understand and agree with the proposed removal action that is planned for their property. During the meeting, the PCT explains the results of the investigation, presents the RRA design to the property owner and answers any questions that they have. Some questions may be directed to the Construction Management Team for resolution. The RRA meeting should result with a RRA signed by the property owner and a representative of the RC. The RRA will document the terms of the removal action.

This meeting is recorded on the property’s ROC and the Property Coordination DQCR and submitted to the proper PIC for property status updates in the Scribe database.

2.4.1. ERS Coordination

For ERS Quick response work, a complete RRA will not be used. A Scope of Work will be generated by the ERS Team and submitted to the PCT. The PCT will coordinate with the property owner to have the Scope of Work signed prior to removal activities.

2.4.2. Removal General Policies

Removal and restoration activities will be conducted in accordance with the following General Policies:

• Only government-authorized personnel will be permitted to perform work on site or enter the work exclusion zone during the removal and restoration activities.

• Excavation boundaries are subject to change based on the presence of vermiculite.

No excavation will occur beneath sidewalls or concrete pads. An exception may be made, with approval of the government, in cases where contamination extends beneath a severely damaged or degraded sidewalk and where removal and

HFS-PRI Rapid 25 replacement of the sidewalk facilitates more efficient and cost effective removal activities.

• If interior restoration is performed, some doors and windows may be left open as part of the removal activities. Non-secured entrances will be sealed to the extent possible with poly to prevent rain penetration and entrance of animals into the work space.. Security will be provided whenever the RC is not working for all non-secured properties.

• The landscaping contractor will water restored plants and hydro seed at the time of planting and over the following two business days. It will then become the resident’s responsibility to maintain these areas.

• If relocation is required and the resident returns to their property without prior approval, their relocation agreement with the government will be nullified and per diem and hotel costs will not be paid. Nullification of the relocation agreement under these conditions does not allow for re-occupancy of the property if removal or restoration activities are still ongoing.

• Any cost incurred in addition to pre-approved lodging arrangements will be reimbursed directly to the hotel by the resident. Unpaid costs will be deducted from the per diem allowance. In the event the resident is asked to leave the accommodations for non-compliance with hotel rules, EPA will not provide alternate lodging. The resident will be responsible for procuring their own lodging for the duration of the removal and restoration activities.

• Construction and restoration is guaranteed for one year after the remediation is complete. Damage to the restoration caused by pre-existing site conditions not addressed by the remediation or by acts of nature not enhanced by the remediation (e.g. erosion damage caused by removal of vegetation layer and not mitigated by erosion control measures) will not be covered as a warranty item.

• Backfill material will be provided according with the specification for those materials with no allowance made for property owner dissatisfaction with the material. Restoration material specifications and material samples may be provided as part of the RRA signing process.