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Memorandum To: Jesse Aviles, EPA RPM, VB/I70 Superfund Site
From: Timothy C. Shangraw
Date: March 29, 2018
Amended: April 20, 2018
Re: POLREP #32 - Vasquez Boulevard/Interstate 70 (VB/I70) Superfund Site, Operable
Unit 2, Removal Action
=======================================================================
On behalf of the City and County of Denver (Respondent), Engineering Management Support, Inc. (EMSI) is submitting this Pollution Report (POLREP #32) in accordance with Section 4.c of Appendix C to the Administrative Settlement Agreement and Order on Consent for Removal Action, for the subject Superfund Site (the Site). This report follows the outline detailed in Section 4.c of Appendix C, and contains pertinent new information specified in the Superfund Removal Procedures, Removal Response Reporting: POLREP and On-Scene Coordinator (OSC) Reports (EPA, 1994).
Section I – Heading
The date, site name, report author, report recipient, and report number are presented above.
Section II – Response Information
This reporting period extended from February 1 through 28, 2018 during which time the following activities occurred:
Excavation of non-Regulated Asbestos-Contaminated Soil (RACS), stockpiling some ofit onsite for future backfilling, and hauling the remainder to the Denver ArapahoeDisposal Site (DADS);
Construction of outlet wing walls and open channel sidewalls through the ColiseumParking Lot (CPL);
Construction of inlet and outlet wing walls, open channel sidewalls, lateral drain boxes,UV treatment box, Arkins Court transition structure, and outlet rip rap through theGlobeville Landing Park (GLP);
Pumping and treatment of groundwater from dewatering zones 1, 2, 3a, and 3b;
On-site and off-site monitoring for air quality, dust, and odors; and
Conducting Quality Assurance field audits.
The volumes of water pumped, treated, and returned to the South Platte River, and the volumes of non-RACS excavated and managed are summarized in Table 1. No RACS were excavated
Engineering Management
Support, Inc.
Memorandum
POLREP #32
VB/I70, OU2 Removal Action
March 29, 2018
Page 2
during the month.
On-site monitoring for volatile organic compounds (including methane), odor, and visible dust emissions occurred continuously during excavation activities. In addition, monitoring for airborne asbestos fibers proceeded in accordance with Section 5.5 of the Colorado’s Solid Waste Regulations (CSWRs). Due to their overall size, daily monitoring reports for volatile organic compounds, odor, dust, and asbestos are being submitted under separate cover.
Off-Site monitoring by Denver for PM10, airborne lead and arsenic at four locations within the monitoring boundary continued throughout the reporting period. Sampling from these stations occurred every sixth day throughout the month. All results were all below the Occupational Safety and Health Administration 8-hour limits and National Ambient Air Quality Standards. Monthly monitoring reports are posted on the Globeville Landing Outfall (GLO) project web site at: https://www.denvergov.org/content/denvergov/en/environmental-health/environmental-quality/land-use-and-planning.html.
As part of the GLO project’s Community Outreach program, a community hotline was operated. No complaints were received during the reporting period. The Community Advisory Group (CAG) held its thirteenth meeting on March 13
th. Meeting minutes are posted on the VB/I-70
Superfund Community Advisory Group web site. The next CAG meeting is scheduled for April 10, 2018.
The following project meetings were held in February and earlier this month:
Weekly GLO Project Status Meetings (February 1, 8, 15, and 22, 2018); and
EPA monthly progress meeting (March 21, 2018).
Lastly, a 3-week look-ahead Construction Schedule is attached to this POLREP.
Section III – Issues, Resolutions, and Planned Activities
Quality Assurance (QA) Audit Report #10 was prepared on March 7, 2018. It involved a site inspection on February 15
th by a representative from Engineering Management Support, Inc.
(EMSI) to assess consistency with Section 5.5 of Colorado’s Solid Waste Regulations (CSWRs), and consistency with environmental monitoring activities detailed in the Final Materials Management Plan (MMP) (EMSI, 2016). In addition, the EMSI representative reviewed Kleinfelder’s Certified Asbestos Building Inspector (CABI) reports dated February 1, 5, 10, and 15 for completeness and accuracy. The field inspection indicated asbestos management and environmental monitoring activities were being performed in partial compliance with Section 5.5 of the CSWRs. During excavation to expose some of the stone columns, Kleinfelder representatives appeared uncertain about their determinations of whether the material immediately overlying the columns was RACS, and if the excavated area should be determined an RWA. This appeared to be caused more by a change in Kleinfelder personnel recently assigned to the project than by a proper determination of RACS/RWA. Upon review of earlier
Memorandum
POLREP #32
VB/I70, OU2 Removal Action
March 29, 2018
Page 3
records, the material had been classified as non-RACS. It also appeared that Kleinfelder was not informed by Ames that when excavating to the top of stone columns, Ames would encounter soil other than Class 1 fill material. Required corrective actions consisted of 1) better informing new Kleinfelder personnel about historical Site knowledge and prior RACS determinations, 2) updating protocol for handling suspect ACM, and 3) improving communications among Kleinfelder and Ames personnel. Only one minor typographical error was noted on one of the CABI reports. All of the required corrective actions have been implemented and the typographical error has been corrected. Therefore, the audit was closed. A copy of the Audit Report is attached to this POLREP.
Monitoring of treated effluent from the GLO project continued during the reporting period in
accordance with Discharge Permit Number CO0049002. All monitored parameters met
discharge limits during the month, as shown in the attached summary table.
Planned activities for the next reporting period consist of:
Continue construction of wing walls and open channel sidewalls through the CPL andGLP;
Complete construction of lateral drain boxes in the GLP;
Complete construction of outlet structures, transition zones, and riprap in the GLP;
Complete final grading of the drainage channel and placement of the strengthening layer;
Begin placement of liner material over the strengthening layer;
Continued dewatering in zones 1, 2, 3a and 3b; and
Continued on-site and off-site monitoring of air quality.
To maintain effective and transparent communication during GLO implementation, EPA and CDPHE
personnel are invited to participate in weekly coordination meetings at Kiewit’s RiNo office. The
next EPA Monthly Status meeting will be held on April 18th at 9:00 am in the Webb building.
Please call Andrew Ross (720.865.5458) or me (303.619.5179) if you have any questions.
Attachments:
February 2018 Summary of GLO Construction Activities 3-Week Look-Ahead Schedule QA Audit Report # 10 Summary of Effluent and Influent Analytical Results
UPDATED 4/20/18 TABLE 1 - FEB 2018 Construction Summary
Current Month QTY QTY to date Comments
EXCAVATION/HAULING
# of days Excavation occurred Globeville park 5 103# of days Excavation occurred Municipal Landfill 0 35
Volume of Racs Excavated (CY) 0 89,527 From Globeville Park
Volume of Racs hauled to DADS (CY) 0 89,527 From Globeville Park
Volume of Non-Racs Excavated (CY) 1,518 60,487
Volume of Non-Racs stockpiled onsite (CY) 510 13,116
Volume of Non-Racs hauled to DADS (CY) 1,008 47,371
Volume Hauled to Clean Harbors (CY) 0
GROUT AND STONE COLUMNS
number of grout columns installed this month 0 1,091 All Stone and Grout columns are complete
Grout column SPT testing results 0 0 All Stone and Grout columns are complete
number of stone columns installed per month 0 575 All Stone and Grout columns are complete
stone column test results 0 0 All Stone and Grout columns are complete
REMEDIATION DEWATERING AND TREATMENT
LF of underdrain/wick wells installed 650
Volume of water transported and treated at MFEI 1,439,500 28,313,874
Volume of treated water, including dilution,
discharged to S. Platte1 1,356,933 28,499,623
Analytical results 0 Jan DMR submitted; no exceedences
CONSTRUCITION DEWATERING
status of permit compliance
LINER INSTALLATION
% complete during the month N/A
QC/QA testing results N/A
Issues and Resolutions N/A
MODCP RESULTS
Daily Methane, Odor, and Dust monitoring reports
Issues and Resolutions
COMMUNITY OUTREACH
Summary of Calls to hotline
Issues and Resolutions
1 The difference between volume of water treated and the volume of water discharged to the S. Platte can be explained by a combination of factors including tank storage, loss due to reverse osmosis brines, and loss due to moisture in the waste sludge.
Current Forecast Forecast Forecast Comments
Work
performed byShift
03/1
2
03/1
2
03/1
3
03/1
3
03/1
4
03/1
4
03/1
5
03/1
5
03/1
6
03/1
6
03/1
7
03/1
7
03/1
8
03/1
8
03/1
9
03/1
9
03/2
0
03/2
0
03/2
1
03/2
1
03/2
2
03/2
2
03/2
3
03/2
3
03/2
4
03/2
4
03/2
5
03/2
5
03/2
6
03/2
6
03/2
7
03/2
7
03/2
8
03/2
8
03/2
9
03/2
9
03/3
0
03/3
0
03/3
1
03/3
1
04/0
1
04/0
1
04/0
2
04/0
2
04/0
3
04/0
3
04/0
4
04/0
4
04/0
5
04/0
5
04/0
6
04/0
6
04/0
7
04/0
7
04/0
8
04/0
8
M T W T F Sa Su T W T F Sa Su T W T F Sa Su T W T F Sa Su
1
2 EARTHWORK (Park Channel)
3 Backfill S. Lateral Dran box Ames 03/08/18 03/16/18 day
4 Backfill N. Lateral Dran box Ames 03/26/18 03/30/18 day
5 Finish Geogrid and Rock in Channel Ames 03/19/18 03/23/18 day
6 Install Strenghtening Layer (LINER) ECA 03/26/18 04/07/18 day
7
8
9 OUTFALL CHANNEL
10 Upper Soil wrap Ames 03/15/18 03/30/18 day
11 Upper Soil wrap Ames 03/26/18 03/30/18 day
12 Seed / Blanket Lower outfall channel Western states 03/15/18 03/19/18 day
13 Topsoil in upper outfall channel Ames 03/12/18 03/16/18 day
14 Topsoil in upper outfall channel Ames 03/12/18 03/15/18 day
15 Remove sheets zones 1 & 2 Ames 03/12/18 04/14/18 day
16
17 N. LATERAL DRAIN BOX
18 Strip shoring Ames 03/14/18 03/20/18 day
19
20
21 EAST PARK WALL
22
23 UV Vault
24 Lower Excavation Ames 03/12/18 03/13/18 day
25 F/R/D UV vault footing Ames 03/14/18 03/23/18 day
26 F/R/D UV vault wall Ames 03/26/18 03/30/18 day
27 F/R/D UV vault deck Ames 04/02/18 04/15/18 day
28
29
30 N. Bridge Abutment
31 F/R/P N. Abutment wall Ames 03/26/18 04/06/18 day
32
33
34 S. Bridge Abutment
35 F/R/P Abutment wing walls Ames 03/12/18 03/26/18 day
36
37
38 Arkins outlet
39 F/R/P Apron section 1 Ames 03/09/18 03/13/18 day
40 F/R/P Apron section 2 Ames 03/14/18 03/15/18 day
41
42
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M
Phase 1A 3 week schedule
Monday, March 12, 2018
Item
Globeville Phase 1ASchedule Title
Current Week
Finish Start Activity Description
M M
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Current Forecast Forecast Forecast Comments
Work
performed byShift
03/1
2
03/1
2
03/1
3
03/1
3
03/1
4
03/1
4
03/1
5
03/1
5
03/1
6
03/1
6
03/1
7
03/1
7
03/1
8
03/1
8
03/1
9
03/1
9
03/2
0
03/2
0
03/2
1
03/2
1
03/2
2
03/2
2
03/2
3
03/2
3
03/2
4
03/2
4
03/2
5
03/2
5
03/2
6
03/2
6
03/2
7
03/2
7
03/2
8
03/2
8
03/2
9
03/2
9
03/3
0
03/3
0
03/3
1
03/3
1
04/0
1
04/0
1
04/0
2
04/0
2
04/0
3
04/0
3
04/0
4
04/0
4
04/0
5
04/0
5
04/0
6
04/0
6
04/0
7
04/0
7
04/0
8
04/0
8
M T W T F Sa Su T W T F Sa Su T W T F Sa Su T W T F Sa SuM
Phase 1A 3 week schedule
Monday, March 12, 2018
Item
Globeville Phase 1ASchedule Title
Current Week
Finish Start Activity Description
M M
43 N. Colisuem conduit wingwall
44 Finegrade Footings J1 - K1 Ames 03/12/18 03/13/18 day
45 F/R/P Footings J1-K1 Ames 03/14/18 03/23/18 day
46 F/R/P walls J1-K1 Ames 03/26/18 04/07/18 day
47
48
49 S. Colisuem conduit wingwall
50 Finegrade Footings L1 - K1 Ames 03/15/18 03/19/18 day
51 F/R/P Footings J1-K1 Ames 03/20/18 03/30/18 day
52 F/R/P walls J1-K1 Ames 04/02/18 04/16/18 day
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
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Page 1
Engineering Management
Support, Inc.
QA Audit Report #10
To: Marty Beck and Paul Jacobson, Kiewit
From: Tim Shangraw, EMSI
cc:
Andrew Ross, DEH; Steve Gonzales, DEH; Ryan Crum (DPW); Brian McLaren (DPW); and Patrick Riley (DPW)
Date: March 7, 2018
Re:
Audit of Asbestos Management and Environmental Monitoring Activities during February 2018 at Globeville Landing Outfall Project
On February 15, 2018, a representative from Engineering Management Support, Inc. (EMSI) conducted a Quality Assurance (QA) audit of asbestos management activities at the Globeville Landing Outfall (GLO) project for consistency with Section 5.5 of Colorado’s Solid Waste Regulations (CSWRs), and environmental monitoring activities for consistency with the Final Materials Management Plan (MMP) (EMSI, 2016). Mr. David Matteocci with Matteocci & Associates, LLC represented EMSI and Mr. Mitch Reese and Mr. David Buckley represented Kleinfelder.
With respect to Section 5.5 of the CSWRs, the field inspections involved an independent inspection of asbestos handling activities, documentation of findings, sampling, assessment of regulated work areas (RWAs) and how they were delineated, who entered the RWAs and the level of personnel protection equipment (PPE) worn, decontamination procedures, observations of possible visible emissions from RWAs, and other possible indicators of impacted soils. With respect to the MMP, the field inspection involved observations of environmental screening activities of excavated materials, and odor and dust control monitoring.
In addition, the EMSI representative reviewed Kleinfelder’s CABI reports dated February 1, 5, 10, and 15 for completeness and accuracy.
Following completion of the field inspections and CABI report reviews, the EMSI representative met with Ms. Lanaia Carveth to review his observations. Discrepancies or omissions were resolved and documented in both EMSI’s logs and Kleinfelder’s logs. Copies of EMSI’s logs are attached to this Audit Report. Due to their size, copies of Kleinfelder’s logs are submitted under separate cover.
AUDIT FINDINGS
The field inspections indicated asbestos management and environmental monitoring activities were being performed in partial compliance with Section 5.5 of the CSWRs and in full compliance the MMP. Specifically, during excavation to expose stone columns in Area J8,
QA Audit Report #10, GLO Project March 7, 2018
Page 2
Kleinfelder representatives appeared uncertain about their determinations of whether the material being excavated was RACS, and if the area should be determined an RWA. This appeared to be caused more by a change in Kleinfelder personnel recently assigned to the project than by a proper determination of RACS/RWA. It also appeared that Kleinfelder was not informed by Ames that materials being excavated would be below the Class 1 material that had been placed in the area.
Because of the uncertainty, the Kleinfelder CABI conservatively assumed that the soil below the Class 1 material was RACS. Level C PPE was worn by equipment operators when excavating the material, but PPE was not worn be Ames’s workers who shoveled the assumed RACS into a poly-wrapped front-end loader bucket. As well, the area being disturbed was not delineated as an RWA.
On balance, Kleinfelder’s CABI was observing the material being excavated and determined there was no suspect ACM present; only minimal amounts of crushed red brick and concrete were present. He also had the assumed RACS placed in a delineated RWA in Area I6.
Screening of CABI reports identified only one discrepancy:
CABI Report dated February 1, 2018 by David Buckley: Section 2B does not have a yes or no marked. It should be properly marked.
ACTION REQUIRED
With regards to the Site Inspection findings, the following corrective actions should be taken:
1. New Kleinfelder personnel assigned to the project need to be better informed about historical Site knowledge and prior RACS determinations.
2. Protocol for handling suspect ACM should be updated and clearly communicated among Kleinfelder and Ames personnel.
3. Ames needs to better communicate the scope of excavation (areal and vertical extent) in areas containing suspect ACM with Kleinfelder before excavation begins, so proper contingent measures can be planned proactively.
As documented in correspondence from Kleinfelder, these three corrective actions have been addressed to the satisfaction of EMSI. With regards to the single CABI report discrepancy, Section 2B has been properly marked in a revised report. Consequently, this audit report is closed.
Attachments
Historical Influent and Effluent Water Quality, GLO Water Treatment Plant
Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent**
Flow Rate (monthly ave) gpm Continuous 100 N/R 95.5 N/R 96.8 N/R 91.2 N/R 84.5 N/R 54.6 N/R 38.5 N/R 32.9 N/R 31.9 N/R 32.6 N/R 33.7
pH standard units 3 days/wk 6.5 - 9 N/R 7.05 - 7.98 N/R 7.53 - 8.11 N/R 6.83 - 8.13 N/R 7.37 - 8.21 N/R 6.8 - 8.4 N/R 7.1 - 8.4 N/R 7.1 - 8.0 N/R 7.2 - 8.1 N/R 7.31 - 7.96 N/R 7.02 - 7.88
Total Residual Chlorine mg/L 3 days/wk 0.5 N/R 0 - 0.35 N/R 0 - 0.29 N/R 0.01 - 0.29 N/R 0 - 0. 14 N/R 0 - 0.02 N/R 0 - 0.22 N/R 0 - 0.01 N/R 0 - 0.03 N/R 0 - 0.02 N/R 0 - 0.03
Oil and Grease (visual) visual presence 3 days/wk Report N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None
Oil and Grease (lab) mg/L
Contingent upon
visual presence 10 N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R
Total Suspended Solids mg/L Weekly 30 - 45 N/R <5 - 21 N/R 1.4J - 7.3 N/R <5 - 2.5J N/R <2.5 - 13.3 N/R 0.6 - 21.9 N/R 1.7 - 7.7 N/R <2.5 - 20.4 N/R <2.5 - 3.8 N/R 1.3 - 4.7 N/R 1.6 - 7.0
E. Coli #/100 ml Weekly 126 - 252 N/R 0 - 2 N/R 0 N/R 0 N/R 0 - 105 N/R 0 - 54 N/R 0 - 1 N/R 0 - 1 N/R 0 - 11 N/R 0 - 1 N/R 0
BOD5 mg/L Monthly 30 - 45 N/R <2 N/R <1 N/R <1 N/R 1.1 N/R 2.6 N/R <1.0 N/R 11.4 N/R 7.4 N/R 5.5 N/R <12
Total Inorganic Nitrogen mg/L Monthly 10 N/R 8.4 N/R 8.7 N/R 8.7 N/R 8.3 N/R 5.9 N/R 6.8 N/R 5.9 N/R 5.9 N/R 8.1 N/R 2.7
Ammonia mg/L Monthly Report N/R 0.48 N/R 0.3 N/R 0.26 N/R 0.38 N/R 0.38 N/R 0.04 N/R 0.38 N/R 1.2 N/R 2.1 N/R 0.52
Arsenic, total recoverable ug/L Monthly 3.0 7.4 <0.6 3.0 0.55 3.9 <0.4 3.6 0.76 4.1 0.93 3.5 0.61 3.8 0.73 4.5 0.65 7.6 0.72 3.4 <2.0
Cadmium, potentially dissolved ug/L Monthly 0.87 1.88 <0.1 0.9 <0.2 0.74 <0.2 1.2 <0.2 1.6 <0.2 1.7 <0.2 0.81 <0.2 1.1 <0.2 1.0 <0.2 0.8 <0.3
Copper, potentially dissolved ug/L Monthly 5,656 - 6,975 14.8 1.1 6.1 3.2 - 6.1 4.7 4.1 6 5.9 4.3 <4.0 7.1 6.8 4.5 4.8 6.4 10.9 8.9 12.7 4.3 15.9
Iron, total recoverable ug/L Monthly 253,000 8020 50 259 78.2 - 91 332 <500 115 43.4 106 <20 254 53.8 99 315 369 443 2640 169 214 96.7
Lead, total recoverable ug/L Monthly 13,005 47.2 0.6 1.8 0.8 - 1.0 1.4 <1.0 2.1 <1.0 <1.0 <1.0 1.4 <1.0 1.3 <1.0 1.3 <1.0 17.6 <1.0 4.9 <0.5
Lead, potentially dissolved ug/L Monthly 2,405 42.3 0.5 1.6 0.8 - 1.1 3.2 <1.0 1.1 1.9 <1.0 <1.0 1.4 <1.0 1.2 <1.0 <1.0 <1.0 4.9 <1.0 2.9 <0.5
Mercury, total ug/L Monthly 3.5 N/R <0.2 N/R <0.2 N/R <0.1 N/R <0.1 N/R <0.1 N/R 2.0 N/R 0.6 N/R <0.1 N/R <0.1 N/R <0.07
Selenium, potentially dissolved ug/L Monthly 4.6 3.0 - 3.1 3.3 3.2 2.4 - 3.8 4.5 2.2 3.3 1.9 2.5 <0.8 3.0 23.7 4.0 2.3 1.1 2.6 3.5 3.1 3.1 <2.0
WET Testing LC 50 Quarterly ≥ 100 N/R N/R N/R
Failed, then
passed N/R N/R N/R N/R N/R N/R N/R Passsed N/R N/R N/R N/R N/R N/R N/R Passed
shaded cell indicates compliance with permit limit
shaded cell indicates influent exceeds discharge limit; treatment required
shaded cell indicates effluent exceeds permit limit
* Metals Screen required per Section 1.A.3 of GLO Discharge Permit. VOC and SVOC screens confirmed only trace detections.
** Monitored parameters required per Section 1.A.2 of GLO Discharge Permit
Feb-18Jan-18Jul-17Jun-17Parameter Unit
Sample
Frequency
Effluent
Permit Limit
May-17 Dec-17Nov-17Sep-17 Oct-17Aug-17