·• I STATEMENT OF WORK TECHNICAL AND ENFORCEMENT OVERSIGHT SALEM ACRES RI/FS Salem, Massachusetts Introduction The purpose of this work assignment is to conduct a Technical and Enforcement OVersight for the Salem Acres \'laste Site located in Salem, Massachusetts. The Remedial Investigation/ Feasibility Study (Rl/FS) to be conducted will be performed by PRP Contractor, The Maguire Group, Inc. The work plan for Salem Acres was prepared for EPA by GCA Corporation of Bedford, MA. This work plan is divided into four phases, Phases 1 through 3 describe the work to be completed under the RI, and Phase 4 describes the work to be completed under the FS. The Remedial Investigation and Feasibility Study is being conducted under an EPA Administrative Order by Consent with the South Essex Sewerage District (SESD). On April 10, 1987, EPA initiated an Emergency Removal Action to stabilize the two sludge pit areas which are leaching out into the Strongwater and Swampscott Road Brook Wetlands. Damage to wetlands is apparent. · Task 1 - Technical Review of the RI/FS Work Plan The purpose of this task is to perform a review of the PRP's RI/FS work plan (GCA/EPA approved work plan). The work plan shall be approved and modified to reflect the SARA/CERCLA Amendments and any changes to the NCP. Subtask 1.1 - Review existing documents pertinent to RI/FS l-lork Plan The objective of this task is to become familiar with material pertinent to the RI/FS work plan. Site Inspection Reports conducted by State, County, or Federal Government should be reviewed. NUS FIT Report, Hazardous Ranking System Report, Disposal History at Site and any other reports deemed essential. Subtask 1.2 - Review Phase I: Project Operations Plan (POP) Before any onsite Remedial Investigation work begins at Salem Acres, a variety of RI support activities must be addressed. The Salem Acres Project Operations Plan (POP) will be written to identify site-specific policy and procedural guidelines that will be implemented throughout the RI/FS. The POP will be written a series of specific plans that will incorporate individual remedial activities proposed to take place onsite or in the surrounding areas. Specifically, the Salem Acres POP will include plans for: 0 and Analysis
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·• I
STATEMENT OF WORK TECHNICAL AND ENFORCEMENT OVERSIGHT
SALEM ACRES RI/FS Salem, Massachusetts
Introduction
The purpose of this work assignment is to conduct a Technical and Enforcement OVersight for the Salem Acres \'laste Site located in Salem, Massachusetts. The Remedial Investigation/ Feasibility Study (Rl/FS) to be conducted will be performed by PRP Contractor, The Maguire Group, Inc. The work plan for Salem Acres was prepared for EPA by GCA Corporation of Bedford, MA. This work plan is divided into four phases, Phases 1 through 3 describe the work to be completed under the RI, and Phase 4 describes the work to be completed under the FS. The Remedial Investigation and Feasibility Study is being conducted under an EPA Administrative Order by Consent with the South Essex Sewerage District (SESD). On April 10, 1987, EPA initiated an Emergency Removal Action to stabilize the two sludge pit areas which are leaching out into the Strongwater and Swampscott Road Brook Wetlands. Damage to wetlands is apparent. ·
Task 1 - Technical Review of the RI/FS Work Plan
The purpose of this task is to perform a review of the PRP's RI/FS work plan (GCA/EPA approved work plan). The work plan shall be approved and modified to reflect the SARA/CERCLA Amendments and any changes to the NCP.
Subtask 1.1 - Review existing documents pertinent to RI/FS l-lork Plan
The objective of this task is to become familiar with material pertinent to the RI/FS work plan. Site Inspection Reports conducted by State, County, or Federal Government should be reviewed. NUS FIT Report, Hazardous Ranking System Report, Disposal History at Site and any other reports deemed essential.
Subtask 1.2 - Review Phase I: Project Operations Plan (POP)
Before any onsite Remedial Investigation work begins at Salem Acres, a variety of RI support activities must be addressed. The Salem Acres Project Operations Plan (POP) will be written to identify site-specific policy and procedural guidelines that will be implemented throughout the RI/FS. The POP will be written ~s a series of specific plans that will incorporate individual remedial activities proposed to take place onsite or in the surrounding areas. Specifically, the Salem Acres POP will include plans for:
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• Quality Assurance/Quality Control
• Site Health, and Safety
• Topographic Mapping
• Data Management
Subtask 1.3 - Review groundwater aspect of the RI/FS
The groundwater section is a very important aspect of the POP and is identified as a separate subtask. The purpose of this task is to provide a review of the PRP's Remedial Investigation/Feasibilty Study (RI/FS)· activities with respect to groundwater at the site. The review activities will include the review of the PRP's draft and final WOrk Plan, Full Field OVersight of RI activities, and review of the RI report. Comments on the work plan and the RI report will be summarized in letter reports and discussed at technical review meetings with EPA staff as designated by Remedial Project Manager.
Subtask 1.3.1 - Review existing geological/hydrogeological information of the Salem Acres Site
An attempt must be made to identify and review any existing information pertaining to geology or hydrogeology of the Salem Acres Site. Reports by NUS/FIT could supply pertinent information.
Subtask 1.3.Z - Review of PRP's RI Work Plan with emphasis on well design
The RI work plan will be reviewed with special emphasis on the well placement and design. Attendance at informational meetings to clarify the work plan elements is anticipated. Work plan comments will be summarized in a letter report and additional meetings to discuss the RI work plan comments are anticipated.
Subtask 1.4 - Review Phase II: Wetlands Assessment Plan
This task will deal with determining harm to the surrounding wetland areas. Since it is believed that the wetlands are receptors of groundwater and surface water contamination, an in depth study to assess this damage will be made. An assessment of the wetland ecosystem is anticipated; this will include a determination of stress to the benthos macroinvertebrate community. A review of the wetlands plan will be summarized in a written report and discussed at technical review meetings as scheduled by RPM.
Subtask 1.5 - Review Phase III: Data Summary and Analysis
The data summary and analysis phase is composed of 1) siteconceptualization 2) the endangerment assessment and 3) the Remedial Investigation Report. A review of each reportwill be summarized in a written report and discussed attechnical review meetings as scheduled by RPM.
Subtask 1.5 - Review Endangerment Assessment (EA)
The endangerment Assessment is a very important aspect of the Data Summary and Analysis phase and is describedseparately. The endangerment assessment will consider and focus on those compounds found on-site that pose the greatestthreat to human health, welfare or the environment due to their toxicological properties, and concentrations of onsite compounds the E-A will also consider the fate of the compounds. A review of the endangerment assessment will beoutlined in a written report and discussed at technicalreview meetings.
The overall purpose of the report is to present a compreThe report'J hensive site characterization of Salem Acres.
will review and analyze in detail the data for each specificmedium investigated. It will include all figures, maps, data tables etc. as outlined in the individual tasks. The RI report will identify and discuss the concentrations ofcontaminants in specific ~edia, migration pathways, and sensitive environmental and/or human receptors. The specific format to be used in the development of the RI reportwill be based on the RI report format found in •Guidance on Remedial Investigations Under CERCLA• and subject to u.s.EPA Region I modifications. The data collected during the RI will be summarized in a report incorporating the results of the tasks specified in the Work Plan. The OversightContractor will conduct an in depth review of RI Report and identify any data gaps or inconsistencies and provide a written report for discussion with EPA technical review tea~. · The Contractor and RPM will meet with PRP Contractor to correct any deficiencies.
Subtask 1.6 - Review Phase IV Feasibility Study
The underlying purpose for the development of a Feasibility Study for Salem Acres is tofulfill the requirements stipulated in the National Oil and Hazardous Substance ContingencyPlan (NCP; 50 FR 47912, 20 November 1985: 40 CFR 300) as may be further amended. More specifically, the FS willutilize the site characterization data obtained during the remedial investigation and the risk characterization obtainert
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in the EA to develop and evaluate alternative •remedial actions• appropriate for the Salem Acres site as required by CERCLA Section 121. This alternative evaluation process will result in the identification of the most cost-effective alternative that is technologically feasible and reliable and which effectively mitigates or minimized the release of hazardous substances . to, and provides adequate protectionof, present and future public health, welfare or the environment and meets the requirements of CERCLA Section 121. Several subtasks and analyses comprise the Feasibility Study.
• Refinement of Site - Specific Remedial Response Objectives
• Refinement of Remedial Technologies
• Treatability studies (Remedial Investigation)
• Development of Remedial alternatives (Remedial Investigation)
• Initial Screening of Remedial Alternatives (Remedial - Investigation)
• Detailed Analysis of Limited Number of Remedial Alternatives
• Conceptual Design
Draft and Final Report .
The PRP's feasability study report, based on the remedial investigations, will be reviewed and comments will be summarired in a written report. Attendance and formal presentations at technical and legal review meetings will be provided as required by RPM.
Task 2 - Oversight Activities
2.1 Review existing documents pertinent to RI/RS Work Plan
Technical OVersight is required for this task to assure identification of all Federal and State ARAR's and compliance with EPA Policy Guidance. Treatability Studies must consider all available technologies.
Subtask 2.2 - Technical Oversight for Review of Project Operations Plan
Technical Oversight is required under this task. The contractor will be responsible for overseeing all aspects of media sampling. This includes QA/OC protocol, and chai~of-custody. The contractor will also be responsible for
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reviewing environmental sampling collected by the TAT team during Removal Action in Spring, 1987. This data will be reviewed for data validation, and OA/OC. This data will assist the PRP's contractor to develop sampling and analysis plan for the RI in order to complete the soil/sludge investigation for the DA-1 and DA-2. Modification to existing work plan will be neccessary to account for fieldwork completed in conjunction with EPA Removal Action.
A workplan for field oversight of the responsible party including split sampling and health and safety plan will be prepared. Emergency response activities occurred at Salem Acres in Spring 1987 and are continuing. Therefore, it will be required that the contractor participate during any oversight removal of soil, sludges, and contaminated surface water that may be removed or stabilized during RI activities. The Removal Action must be integrated with the Remedial Investigation and Feasibility Study.
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Subtask 2.3 - Technical OVersight of the Groundwater RI/FS ':o:
Full time field monitoring of the RI activities, including well construction, equipment installation, and data collection phases, will be performed. Pertinent field observations, will •Je documented in a letter report to RPM. Surface and sub-surface water, soil and sediment sampling will be collected and split with the PRP and sent to the CLP for analysis. Pertinent field observations will be documented in brief status letters and provided in a timely manner to the RPM and discussed as appropriate. oversight contractor will maintain detailed logs of all field activities and assure proper air monitoring is being conducted by PRP Contractor. Wind direction and odor releases must be strictly monitored.
Subtask 2.4 - Technical OVersight of Wetlands Assessment .fl!!l Technical oversight will be required, the Contractor will oversee the mapping of the wetlands area.
Subtask 2.5 - Technical oversight for Data Summary and Analysis Quality Objectives
No field oversight is required under this task. The Contactor will be responsible for reviewing any conceptualized model. Strict observance of EPA Data Oualit~ Objectives Guidance (10-86) must be adhered to and is the responsibility of the Oversight Contractor.
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Task 3 - General Management
The Contractor will be responsible for reviewing monthly
progress and preparing financial reports for oversight.
costs, attending technical and legal review meetings, and
review and provide written analysis of all PRP technical
reports.
The Contractor will be responsible for assembling and
preparin~ draft ROD package including Public Review and
Comment. EPA will establish a Record of Decision (ROD)
Team early within the RI process and will review all sub
missions (reports/deliverables) of the PRP Contractor
(The Maguire Group, Inc.). The Contractor will attend all
such technical review meetings and be responsible for
filling any data gaps on EPA technical or legal review
concerns in close coordination with Site RPM and provide
enforcement support of EPA PRP Consent Order.
Modifications to the EPA approved RI/FS workplan may become
necessary due to admendments or modifications to the NCP or
Federal and State ARARS. The Contractor and RPM will
closely coordinate and implement any necessary changes or
modifications of the RI/FS workplan and requirements of the~
PRP (SESD) under the terms of the EPA Administrative Order
of Consent with the PRP South Essex Sewerage District
(SESD). Contractor will provide any additional technical
support or oversight on any EPA enforcement action underIt will be
the EPA Administrative Order of Consent.neccessary for Oversight Coordinator to identify any
modifications or clarifications on initial review of the RI tasks which are presently
current RI/FS wo~k plan.bein; conducted as part of the EPA removal action must be
modified and incorporated into the the RI and FS (Sludge/
The Oversight Contractor must be guided by EPA Directive
9355,0-19 Interim Guidance on Superfund Selection of Remedy
(Dec.24, 1986) and SARA/CERCLA Section 121 - Cleanup
Standards.
If negotiations with PRP are neccessary, oversight Contractor
may be required to participate. All disputes arising under
terms of PRP Consent Order will require contractor
participation.
The Oversight Contractor will design, develop, establish
and keep current the Site Administrative Record. It will
be neccessary for the Contractor and the RPM to identify
all previous documents for this site.-whic.h should be
contained in the Administrative Record.
The Contractor will review the PRP Contractor's •project'~
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Schedule• and develop a tracking system to identify current
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status and projected completion of all RI/FS Tasks, SubTasks, reports due/received, comment returned, complied with, and compliance with Schedule of Deliverable• and any other events neccessary for tracking.
Community Relations Plan
Oversight Contractor will review, update and appropriately modify Community Relations Plan developed for the site by NUS - December, 1985. OVersight Contractor will be responsible for the conduct of the Community Relations Plan in close coordination with the RPM and EPA Community Relations staff.
