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Remedial Action Completion Report June 2008 Remediation of Soils and Dry Sediments at RVAAP 08-11 (LLs 1-4) Page 3-22 discussed in the RAWP (Shaw 2007b). Shaw’s intrusive activities continued past the normal growing season for the required seed mixtures; however, Shaw applied the seed mixtures for the completed areas as best possible. Only native species as identified in the INRMP were applied. At a minimum, annual rye was placed to provide a quick temporary cover at the restored areas. The annual rye was mixed with other more permanent species to provide long-term cover once the annual rye died off. No non-natives species were introduced. Since most of the excavation areas have not yet re-established vegetation, Shaw has maintained E&S controls consisting of silt fence and diversion barriers for rainwater run-on. Areas where the seed was applied were covered with a minimum of three bales of straw per every 1,000 ft 2 of disturbed area. 3.8.2 Borrow Source Material Prior to bringing the material to the RVAAP, Shaw collected a borrow source sample at the exact location at the source where the soils were to be taken from. The sample was submitted to Kemron for the full suite of analytical parameters that included VOCs, SVOCs, herbicides/pesticides, PCBs, inorganics/mercury, and pH. Analytical results indicated all results were either non-detect or below the applicable background concentrations with the exception of arsenic at 17.8 mg/kg. This concentration was below the applicable cleanup goal of 31 mg/kg for arsenic and Ohio EPA concurred that the metal concentration was naturally occurring. Shaw collected an additional sample prior to the 5,000 cubic yard interval of material to be brought on-site from the Route 5 Sand & Gravel source. The sample was again submitted to Kemron for the full suite of analytical parameters as for the initial sample. All results for this second sample were either non-detect or below the applicable background concentrations, consistent with the initial sample from the backfill source. In all, a total of 9,772 tons (approximately 7,000 cubic yards) of borrow source material was brought on-site from Route 5 Sand & Gravel. Shaw regularly inspected the condition of the soils that were brought on-site to ensure the material was free of debris, large stones or leaching water. A summary of analytical results for the borrow source material are presented in the data tables (Table B-4) in Appendix B. The laboratory reports and associated data evaluation reports are presented in Appendix G included as an electronic attachment to this RACR. 3.9 COORDINATION WITH BRAC DEMOLITION CONTRACTOR Shaw’s work was performed concurrently with the demolition of the remaining buildings at LLs 2-4. Shaw coordinated its activities with PIKA, the BRAC demolition contractor, to minimize potential disturbance to the proposed remediation areas by the demolition activities prior to excavation. Minor schedule interruptions associated with the demolition activities were encountered by Shaw due to limited access to the various load lines during demolition and delays in debris removal, in particular LL 4. It is expected that proposed future BRAC demolition activities of the remaining building slabs and foundations will disturb the areas previously backfilled and seeded by Shaw, and restoration of these areas following the demolition activities will be addressed by the Army. *** FINAL***
Remedial Action Completion Report June 2008 Remediation of Soils and Dry Sediments at RVAAP 08-11 (LLs 1-4) Page 4-1 4.0 WASTE MANAGEMENT AND TRANSPORTATION Two waste streams were generated during the remediation of soils and dry sediments at LLs 1-4: solid and liquid wastes. Waste characterization determined whether a waste was hazardous or non-hazardous and dictated the disposal option and facility where the waste was disposed. All waste disposal and transport was performed in accordance with sampling requirements of the FSP (Shaw 2006b) and the handling and management requirements of the Waste Minimization and Management Plan (WMMP) (Shaw 2006g), respectively. 4.1 SOLID WASTES Solid wastes generated as part of this removal action consisted of contaminated soils and dry sediments and expendable wastes such as personal protective equipment (PPE) (i.e., sample gloves and tyvek) and sampling equipment. Contaminated materials removed from the excavations were stockpiled on-site. All handling of contaminated and solid waste materials was performed in accordance with the WMMP (Shaw 2006g). 4.1.1 Stockpiling at the Site Excavated soils were stored on-site temporarily prior to transporting to the approved disposal facilities. Excavated soils were stockpiled based on the anticipated COCs previously identified for each area of contamination as soils with different COCs had the potential to require alternate disposal facilities. Essentially, soils were segregated into two categories: PCB soils and non-hazardous soils. Soils with known PCB concentrations greater than 40 mg/kg were automatically placed into PCB soil stockpiles based on disposal facility requirements. Soil stockpiles were generated at maximum volumes of 1,000 cubic yards in order to ensure adequate waste characterization in accordance with the FSP (Shaw 2006b). When possible, stockpiles were staged on existing asphalt or concrete to minimize any potential impact to underlying natural materials. At a minimum, stockpiles were staged on two layers of 10-mil poly liner and covered with a minimum of one-layer of 10-mil poly. The covers were secured with sand bags to prevent wind damage to the cover and stockpile. Storm water controls for the protection of the stockpile areas were performed in accordance with the SWPPP (Shaw 2007c). Soil berms were placed around the perimeter of the stockpiles to prevent storm water runoff or run-on. Stockpiles were inspected daily to ensure they were properly secured and the covers were repaired or replaced in order to maintain integrity of the protection of the stockpiled soils in accordance with the WMMP (Shaw 2006g). Items found to be deficient were corrected immediately to prevent potential release of stockpiled soil or associated contaminants in the soils. 4.1.2 Stockpile Sampling The soil stockpiles were sampled and analyzed for waste disposal parameters in accordance with the requirements of the FSP (Shaw 2006b) and the WMMP (Shaw 2006g); however, disposal *** FINAL***
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