engineering and design quality control plan

Engineering and Design Quality Control Plan Data Review, Data Gap Analysis, Acquisition of Field Data, and Remedial Investigation for the Former Guterl Specialty Steel Corporation Lockport, New York

Prepared for

US Army Corps of Engineers Buffalo District Contract W912P4-05-D-0001 Delivery Order 0001

Prepared by

Earth Tech, Inc. 300 Broadacres Drive Bloomfield, NJ 07003 (973) 338-6680

July 2005

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Engineering and Design Quality Control Plan

Data Review, Data Gap Analysis, Acquisition of Field Data, and Remedial Investigation

for the Former Guterl Specialty Steel Corporation Lockport, New York

Prepared for

US Army Corps of Engineers Buffalo District

Contract W912P4-05-D-0001 Delivery Order 0001

Prepared by

Earth Tech, Inc. 300 Broadacres Drive Bloomfield, NJ 07003

(973) 338-6680

Approvers:

James Kaczor, P.G. Date Project Manager

Mike Thiagaram, P.E. Date Program Manager

July 6, 2005

July 6, 2005

Engineering and Design Quality Control Plan Data Review, Data Gap Analysis, Acquisition of Field Data, and Remedial Investigation for the Former Guterl Specialty Steel Corporation, Lockport, New York

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TABLE OF CONTENTS

Section No. Page No.

1. INTRODUCTION...........................................................................................................................1-1 1.1 Purpose and Scope ..................................................................................................... 1-1 1.2 Organization of the Report......................................................................................... 1-2

2. BACKGROUND..............................................................................................................................2-1 2.1 Location ..................................................................................................................... 2-1 2.2 Site Description and History...................................................................................... 2-1 2.3 Current Status/Potential Contaminant Sources.......................................................... 2-3

3. PURPOSE AND SCOPE ................................................................................................................3-1 4. MANAGEMENT PHILOSOPHY AND APPROACH................................................................4-1

4.1 Management Philosophy............................................................................................ 4-1 4.1.1 Total Quality Management System ..................................................................... 4-1 4.1.2 Internal Peer Reviews .......................................................................................... 4-1 4.2 Management Approach.............................................................................................. 4-1 4.2.1 Managerial Continuity ......................................................................................... 4-1 4.2.2 Design Coordination Procedures and Checking .................................................. 4-2 4.2.3 Flexibility............................................................................................................. 4-2 4.2.4 Document Management and Control ................................................................... 4-2 4.2.5 Communication.................................................................................................... 4-2

5. MANAGEMENT STRUCTURE AND PROJECT DELIVERY TEAM...................................5-1 5.1 Project Delivery Team ............................................................................................... 5-1 5.1.1 Management......................................................................................................... 5-1 5.1.2 Technical Staff ..................................................................................................... 5-2 5.1.3 Quality Control Staff............................................................................................ 5-2 5.2 Subcontractors............................................................................................................ 5-3 5.2.1 Severn Trent Laboratories, Inc. ........................................................................... 5-3 5.2.2 SJB Services, Inc. ................................................................................................ 5-3 5.2.3 Other Subcontractors ........................................................................................... 5-3

6. GENERAL QUALITY CONTROL IMPLEMENTATION .......................................................6-1 6.1 Quality Planning and Project Meetings ..................................................................... 6-1 6.2 Programmatic and In-House Project Review............................................................. 6-1 6.2.1 Senior Technical Review ..................................................................................... 6-1 6.2.2 Independent Technical Review (ITR).................................................................. 6-2

7. PROJECT SCHEDULE .................................................................................................................7-1 8. PROJECT RISKS ...........................................................................................................................8-1 9. DESIGN TOOLS.............................................................................................................................9-1 10. IDENTIFICATION OF QUALITY INDICATORS ..................................................................10-1 11. COST TRACKING AND CONTROL ........................................................................................11-1 12. DOCUMENTATION....................................................................................................................12-1

12.1 Types of Documentation.......................................................................................... 12-1 12.2 Maintenance of Project Documentation................................................................... 12-1

REFERENCES


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TABLE OF CONTENTS

Figure No.

Figure 1 Site Location Plan Figure 2 Guterl Steel Site Entities Figure 3 Organizational Chart Figure 4 Project Schedule Appendix

Appendix A Resumes Appendix B Scope of Work for the Data Review, Data Gap Analysis, Acquisition of Field Data, and

Remedial Investigation for the Former Guterl Specialty Steel Corporation Lockport, New York

Appendix C Budget and Summary of Project Costs Appendix D Example of Senior Technical and Independent Technical Review Certification Signature

Pages


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LIST OF ACRONYMS ABHP American Board of Health Physics ABIH American Board of Industrial Hygiene AEC Atomic Energy Commission AFCEE Air Force Center for Environmental Excellence ARAR Applicable or Relevant and Appropriate Requirements CADD Computer Aided Design and Drafting CERCLA Comprehensive Environmental Response, Compensation and Liability Act CEGS Corps of Engineer Guide Specifications CIH Certified Industrial Hygienist DOE Department of Energy DQO Data Quality Objectives DrChecks Design Review and Checking System E&D QCP Engineering and Design Quality Control Plan ER Engineering Regulation FUSRAP Formerly Utilized Sites Remedial Action Program HELP Hydrologic Evaluation of Landfill Performance HTRW Hazardous, Toxic, and Radioactive Waste IDM Investigation-Derived Materials ITR Independent Technical Review MINTEQA2 Metal Speciation Equilibrium Model for Surface and Groundwater NJDEP New Jersey Department of Environmental Protection NLO National Lead of Ohio NTP Notice to Proceed NYSDEC New York State Department of Environmental Conservation ORISE Oak Ridge Institute for Science and Education ORNL Oak Ridge National Laboratory PA/SI Preliminary Assessment/Site Inspection QC Quality Control RCRA Resource Conservation and Recovery Act RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study SESOIL Seasonal Soil Compartment Model SJB SJB Services, Inc. SOW Scope of Work STL Severn Trent Laboratories, Inc. STR Senior Technical Review TSCA Toxic Substances Control Act USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency


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1-1

1. INTRODUCTION

1.1 Purpose and Scope Earth Tech, Inc. (Earth Tech) is performing a data gap analysis for the Guterl Specialty Steel Corporation (Guterl Steel), Lockport, Niagara County, New York under contract to the United States Army Corps of Engineers (USACE), Buffalo District. Earth Tech is performing this work under USACE Contract Number W912P4-05-D-0001, delivery order number 0001. The work will be conducted under the ongoing authorized Formerly Utilized Sites Remedial Action Program (FUSRAP) and as outlined in the scope of work (SOW) from USACE Buffalo District (USACE, 2005), included as Appendix B to the Engineering and Design Quality Control Plan (E&D QCP).

This E&D QCP defines the Quality Control (QC) practices applicable to the work defined under the SOW. This E&D QCP includes QC organization, implementation, objectives and standards, and procedures that define the general policies for how work activities are conducted for the defined SOW.

The specific goals of the E&D QCP are to define control measures so that:

• Work activities meet or exceed the requirements of the SOW, as reflected in the site-specific project planning documents.

• Deliverables and services produced by Earth Tech or its subcontractors are consistent with acceptable standards of engineering and scientific practices.

• Planning processes are implemented for generation of environmental data collection of appropriate type and quality.

• Technical oversight is implemented to verify that data assessment and other work activities are conducted in a manner consistent with applicable state and federal regulations, and applicable USACE standards.

• Independent quality reviews and evaluations are conducted to document that work activities are conducted in accordance with this E&D QCP and related project-specific plans.

• QC procedures for identifying, correcting, and reporting potential technical deviations or deficiencies in the work are implemented in an expeditious manner.

This E&D QCP identifies specific procedures to control performance on the Guterl Steel site project, in accordance with Earth Tech and USACE quality standards. QC methodologies and procedures for project management activities such as budgets and schedules are included in this E&D QCP as necessary to address specific USACE requirements. The focus of the E&D QCP is the technical work activities and project deliverables.


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1.2 Organization of the Report In general, the E&D QCP includes the following:

• Site background (Chapter 2);

• Project description, objectives, and scope (Chapter 3);

• Earth Tech’s management philosophy and approach (Chapter 4);

• Project organization and responsibilities (Chapter 5);

• Procedures for technical reviews (Chapter 6);

• Project schedule (Chapter 7);

• Evaluation of risk inherent in each task under the SOW (Chapter 8);

• Design tools to be used to accomplish the tasks under the SOW (Chapter 9);

• Parameters to be used to measure the overall quality of the project (Chapter 10); and

• Project cost tracking and control (Chapter 11).


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2. BACKGROUND The Guterl Steel site, formerly known as the Simonds Saw and Steel Company, performed rolling mill operations on uranium metal, and to a much smaller extent, thorium, during the period 1948 to 1956. Uranium and thorium operations were performed under contracts with the New York Operations Office of the Atomic Energy Commission (AEC), predecessor to the U.S. Department of Energy (DOE) and National Lead of Ohio (NLO). A radiological survey of the Guterl Steel site was performed in 1999. The USACE Buffalo District completed a Preliminary Assessment/Site Inspection (PA/SI) report in May 2001 (USACE, 2001). Based on the USACE recommendation, the Guterl Steel site was included into the FUSRAP based on evidence of radiological contamination. This E&D QCP outlines the work to be performed to delineate the nature and extent of constituents of potential concern within and around the Guterl Steel site.

2.1 Location The Guterl Steel site is located in Lockport, Niagara County, New York, approximately 20 miles north of Buffalo, New York (Figure 1). The approximately 70-acre site is bordered by Ohio Street to the east and southeast, residential and commercial properties to the north, Route 93 to the west and southwest, and a parking area to the south (Figure 2). The property is grouped into three areas: the 52-acre Allegheny Ludlum Corporation property, which includes four buildings that were constructed after the termination of AEC activities; the 9-acre landfill area, located in the northwest corner of the site; and the 9-acre excised property, which includes nine buildings that existed during the AEC activities, located in the southeast corner of the site.

2.2 Site Description and History The history of the Guterl Steel site presented in this section is based on information provided in the SOW (USACE, 2005). Uranium and thorium operations at the Guterl Steel site were performed under two separate contracts. The first contract, AT-30-1-Gen-339, initiated in May of 1948 and in effect until 1952, was negotiated with the New York Operations Office of the AEC, predecessor to the DOE. The second contract, number S-4, was a subcontract between NLO, who was under contract with the AEC, and Simonds Saw and Steel, which continued the plant activities until 1956. In total, between 25 and 35 million pounds of uranium and approximately 30 to 40 thousand pounds of thorium were rolled from 1948 until operations discontinued in 1956. More than 99 percent of work done under these contracts involved uranium, which was rolled on the 16-inch rolling mill located in Building 8 (Figure 2). Several small lots of uranium bars were run through the 10-inch rolling mill, and approximately 15 to 20 ingots were processed in the hammer forge shop, which was located in Building 3 (Figure 2).

During operations from 1948 through 1956, the AEC was responsible for providing radiological monitoring and safety guidance and assistance. Residue from the operation was returned to the AEC or NLO. The DOE’s Niagara Falls Storage Site (a portion of the former Lake Ontario Ordnance Works) was used for interim storage of the materials between processing operations and use. Protective measures employed at the site included the use of hoods and dust collection equipment over the 16-inch rolling mill stands, and catch pans in the mill pits to collect material from each rolling operation. The mill area was vacuumed after every batch of 16 ingots, and the shipping area was vacuumed daily.


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A radiological survey by Nuclear Science and Engineering Corporation/Carborundum Metals was performed in 1958 that identified elevated radiation levels, and indicated that radiation levels were highest in the quench tank area located in Building 8. Area decontamination was performed, clean steel plates were placed over the area, and a second radiological survey was performed in December 1958 to verify decontamination was effective. In October 1976, at the request of DOE Headquarters, Oak Ridge National Laboratory (ORNL) performed another radiological survey to determine the status of the property relative to current (as of 1976) radiological release guidelines. The ORNL survey revealed that most of the residual contamination remaining from the uranium and thorium rolling operations was confined to the areas inside and immediately outside of Building 6 and 8.

On February 7, 1980, DOE determined that the site required consideration for remedial action. New York State was notified of these findings and took steps to adequately control the Site. In August of 1984, after reviewing historical and contractual information, DOE determined that it did not have the authority under the Atomic Energy Act of 1954 to conduct remedial action at the site. This was primarily due to a “hold harmless” provision in the subcontract between Simonds and NLO, which released the government from liability in regard to these operations. In accordance with DOE policy, the State of New York and the U.S. Environmental Protection Agency (USEPA) were notified of the results of the investigation in order that appropriate actions would take place. In August 1982 Guterl Steel filed for Chapter 11 (bankruptcy) protection and in March 1984 Allegheny International (now known as Allegheny Ludlum Corporation) bought the assets of Guterl Steel. The purchase by Allegheny Ludlum Corporation included the entire site with the exception of two areas, classified as the excised property and the landfill. The excised property is approximately 9-acres, consisting of a chain-link fenced area that surrounds all of the buildings that existed during the rolling operations from 1948 through 1956, and includes the adjacent exterior land area. The landfill region was originally owned and used by Simonds Saw and Steel Company from 1962 to 1978 and was subsequently owned and used by Guterl Steel from 1978 to 1980. The landfill area was used for the disposal of slag, baghouse flue dust, foundry sand, waste oils and greases, and miscellaneous plant rubbish. The landfill is not lined or covered and, although its surface has been regraded, ponding occurs and surface runoff is uncontrolled. The 8.6-acre landfill is listed as a Class 2 site (“significant threat to the public health or environmental-action required”) (Site ID # 9-32-032) in the 2003 Registry of Inactive Hazardous Waste Sites in New York (NYSDEC, 2003). NYSDEC notes that alpha radioactivity exceeds Class GA standards in groundwater, which flows towards the Frontier Stone Quarry (NYSDEC, 2003). The quarry discharges to the Erie Canal, immediately upstream of the intake for the Lockport’s emergency water supply intake.

The nine buildings located within the excised property include Buildings 1 and 2, the co-joined Buildings 3, 4, 5, 6, 8, 9, and Building 35 (Figure 2). Buildings 1 and 2, built in 1913 and 1914, were primarily used as manufacturing buildings, having total areas of approximately 815 m2 and 6,400 m2, respectively. Buildings 3 and 35, built in 1920 and 1950, were used for grinding and roll staging and have total areas of approximately 6,300 m2 and 410 m2, respectively. Buildings 4 and 9 were built in 1920 and 1918 and were both used as manufacturing buildings and have total areas of approximately 2,600 m2 and 1,800 m2, respectively. Building 5, built in 1918, contained a 25-cycle heat exchanger and has a total area of approximately 350 m2 and is located between Buildings 4 and 6. Buildings 6 and 8, both built in 1918, were used for uranium and thorium


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metal roll processing and contain the 16-inch and 10-inch rolling mills. The total area of these buildings is approximately 970 m2 and 2,300 m2, respectively. Attached to the west end of Buildings 6 and 8 is a railcar loading dock, which was used to transport residues from the rolling operations. Building 24 is located outside of the excised property boundary and contains approximately 6,900 m2 of floor space. Only the southwest area of the structure existed at the time of the AEC activities. The southeast and north areas were constructed at later periods. Currently the structure is used for general warehousing type operations. The majority of the buildings are approximately 10 meters high to the steel I-beam supports. The walls are constructed of brick and sheet metal paneling and the floors consist primarily of compacted dirt with some areas of concrete or bricks. Most horizontal surfaces contain an excessive amount of dust and debris. Buildings 6 and 8 have steel plates on the floor surface with dirt and cinders beneath and with the majority of the equipment used during the AEC activities still present. The buildings have been isolated since closing and have leaking roofs, broken windows, excessive debris on the floor, etc. Numerous other safety hazards and concerns currently exist in all the buildings.

The exterior grounds of the excised area include a crane yard to the east of Buildings 1 and 2, an alleyway between Building 2 and 3, an alleyway encircling Building 5, a courtyard area between Buildings 2 and 35, and the exterior loading dock area to the west of Building 6 and 8. The 9-acre landfill region, which is located in the northwest corner of the site, consists of roughly level grade compacted dirt and sparse vegetation.

The Allegheny Ludlum Corporation property, measuring approximately 52-acres, consists of open land covered with minimal vegetation and numerous piles of used firebrick, stockpiled equipment, and other miscellaneous material. Railroad spurs that presently exist appear to have been moved approximately 10 meters south upon the completion of Building 24 in 1966. The previous location of the rail spurs extended north from the excised property (from the west end of Building 8 and from Building 2), merged and led to the east side of the landfill region. In addition to the 70-acre Site, there are additional properties to the north of the Site that were formerly owned by Simonds Saw and Steel Company.

2.3 Current Status/Potential Contaminant Sources At the request of the United States Bankruptcy Court for the Western District of Pennsylvania and with the approval of DOE, the Environmental Survey and Site Assessment Program of the Oak Ridge Institute for Science and Education (ORISE) performed a radiological survey of the Guterl Steel site in 1999 (ORISE, 1999). The survey procedures included surface scans, surface activity measurements, exposure rate measurements, and soil and miscellaneous material sampling. The survey identified residual uranium and thorium contamination in numerous areas of the site. The surfaces and soils within Building 8 contain the most significant residual uranium surface activity and soil concentration levels. Less extensive areas of residual concentrations of uranium were identified on surfaces or in soils within Buildings 1, 2, 3, 4, 6, and 9, and 24. For the site exterior, residual uranium or thorium was detected at multiple surface and subsurface locations, both within the excised property and in the northern half of the Allegheny Ludlum Corporation property. A survey of the southwest portion of the Allegheny Ludlum Corporation


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property, did not identify any locations of residual uranium concentrations, other than those associated with firebrick.

The analysis of the samples of subfloor soils beneath the concrete in suspect areas of Buildings 2, 3, 4 and 9, and 24 indicated that varying degrees of contamination exist within the soils of Buildings 3 and 24. Thoriated slag was identified beneath the concrete of Building 2. According to the SOW, previous investigations in Building 8 have confirmed contamination throughout the cinder layer, which varies in depth, up to at least one meter. Numerous traps, sumps, and equipment trenches throughout Buildings 3, 6, and 8 contain residues or sediments beneath accumulated water, some of which are contaminated. Exterior areas exhibit pockets of contamination, some of which extend to the bedrock layer, scattered within the excised area and across the northern portion of the Allegheny Ludlum Corporation property. Numerous pieces of thoriated metal are present outside the northern fence of the Allegheny Ludlum Corporation property, due east of the landfill. Because of the high radiation levels from these pieces of metal and existing data collected by the State of New York (NYSDEC, 2000; NYSDEC, 1994; NYSDEC, 1991; NYSDEC, 1988), specific samples of this material were not collected. According to the SOW, the presence of this material has also been identified on other property located due north of the northeast boundary of the Allegheny Ludlum Corporation property.


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3. PURPOSE AND SCOPE Earth Tech has prepared this E&D QCP in accordance with applicable principles outlined in the USACE Engineering Regulation (ER) 1110-1-12 to address the quality control and quality assurance requirements for data review, data gap analysis, acquisition of field data, and remedial investigation for the Guterl Steel site. The executing and managing agency for the work described in this E&D QCP is the USACE, Buffalo District, under contract W912P4-05-D-0001, delivery order number 0001.

The work will be conducted under the ongoing authorized FUSRAP and as outlined in the SOW in Appendix B (USACE, 2005). The goal of this project is to generate data of known and sufficient quality and quantity, with quantitation levels low enough to meet pertinent standards, ARARs and remediation goals, with the long-term objective being the selection of a protective remedy that satisfies the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). To achieve this, it is necessary to obtain data that is sufficient to determine nature and extent, risk, and fate and transport of contaminants in a remedial investigation. A secondary objective of this data collection may be to produce data sufficient to develop an adequate volume estimate of contaminated media, to support the feasibility study.

However, the current work authorized is limited to performing Task 1 through Task 4 of the SOW. Task 5 through Task 12 are presented in this section for information purposes only. The objective under the current scope is to generate a data gap analysis report that will be incorporated into the remedial investigation report for the Guterl Steel site.

Specific work breakdown tasks developed to meet the overall project objectives include the following:

• Task 1 – Site inspection and data review. • Task 2 – Preparation of an E&D QCP and performance of independent technical review

(ITR). • Task 3 – Identification of potential Applicable or Relevant and Appropriate

Requirements (ARARs) and Data Quality Objectives (DQOs). • Task 4 – Attend technical project planning (TPP) meeting, prepare TPP notes, and

perform data gap analysis. Attend a two-day TPP meeting. Evaluate relevance and usefulness of the data that was collected during prior

investigations to determine if the available data is sufficient to prepare a RI report. Prepare a summary document.

• Task 5 – Prepare project work plans (i.e., Site Safety and Health Plan/Radiation Protection Plan, Field Sampling Plan, Quality Assurance Project Plan, and Gamma Walkover Survey Plan) for the proposed RI if data gaps are identified.

• Task 6 – Acquisition of field data. Conduct a gamma walkover survey. Conduct a RI consisting of sample collection and analysis.


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• Task 7 – Groundwater modeling. Develop geologic model for groundwater modeling. Develop Hydrologic Evaluation of Landfill Performance (HELP) modeling for

infiltration estimates. Develop SESOIL modeling for soil contamination leaching into groundwater. Develop MINTEQA2 modeling of hydrogeochemical conditions

• Task 8 – Prepare a preliminary fate, transport, and exposure analysis. • Task 9 – Perform screening level ecological and/or human health baseline risk

assessment. • Task 10 – Prepare of a Remedial Investigation (RI) report. • Task 11 – Provide community relations support. • Task 12 – Provide technical support services.

Note that the current delivery order SOW (Appendix B) includes Tasks 1 through 4.


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4. MANAGEMENT PHILOSOPHY AND APPROACH

4.1 Management Philosophy

4.1.1 Total Quality Management System

Earth Tech utilizes a total quality management (TQM) system to ensure project quality, including development of client deliverables. A continuous employee improvement cycle ensures that the organization learns from results and improves its operations and outputs from what it learns. Focus is on initial training (both internal and external training sessions) of members of the project delivery team followed by mentoring of employees by technical managers and quality control managers with greater than ten years experience. A “plan-do-check-response action” approach is used to perform each task of a project. The project delivery team members are involved in the “plan-do-response action” portions of a task while the quality control managers are involved in the “plan-check-response action” portion of the project task. All professional levels are responsible for client services and understanding client needs and priorities. This system is deeply embedded within the organization and involves a continuous assessment and prediction of customers needs and wants.

4.1.2 Internal Peer Reviews

Internal technical peer reviews will be made by staff with the same or greater expertise in the technical work being carried out, but who are independent of the project team. Internal technical peer reviews may be either informal or formal:

• In an informal oral peer review, the project team member presents his or her preliminary draft documentation to the reviewers and responds to questions at a meeting, thereby providing for immediate feedback. This is an active form of review, which takes place quickly and is well-suited for early project evaluation.

• In a formal written peer review, the project team member submits documentation (reports, computations, computer data, drawings, etc.) to the reviewers who in turn comment in writing. The project team member then responds by revising the documentation or providing additional information. This is a passive form of review, which is appropriate prior to submission to the client.

Internal technical peer reviews will be documented upon completion. A detailed discussion on the internal peer review process is provided in Section 6.

4.2 Management Approach

4.2.1 Managerial Continuity

Earth Tech will assign the same Project Manager for all work assignments, as a site progresses through the remedial process. The approach of using a single Project Manager, regardless of which project phase or task, will simplify communications between USACE and Earth Tech, and will eliminate the confusion inherent in multiple handoffs between managers as a project progresses from one phase to another.


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4.2.2 Design Coordination Procedures and Checking

The Project Manager will be responsible for implementing quality control (QC) at the delivery order level. As necessary, the Project Manager will meet on a one-on-one basis with team members responsible for producing deliverables, such as reports, drawings and designs, which serve as a valuable double-check on the thoroughness, accuracy and overall quality of services and work products. During these reviews, issues that may affect the outcome of the project will be identified and resolved early in the project. In addition, the senior technical reviewers (see Section 6) will review the progress of the project team in preparing deliverables. These continuous process improvement measures will assist in avoiding costly and time-consuming corrections at later stages of the project.

4.2.3 Flexibility

A multidisciplinary project team with varying levels of experience and involvement in the project will be maintained throughout the duration of the project. A certain amount of technical personnel redundancy will occur within the project team to provide continuity in the event of departure of a team member. Primary disciplines for the project shall include: health physics; radiology; environmental engineering; geophysics; chemistry; data management; geographical information systems; policy, code, and regulations; and project management. Secondary disciplines shall include: civil engineering; and industrial hygiene. Some team members will be utilized more or less frequently depending on the expertise needed for resolution of the SOW under this delivery order.

4.2.4 Document Management and Control

Deliverables for the project will be prepared in a consistent manner and reviewed as described in Section 6. Reports and documents, including associated figures, drawings, and tables, will be produced using standardized software packages discussed in Section 9. Earth Tech maintains project documentation for a minimum of seven years subsequent to the project being inactive. The project documentation files will be maintained at Earth Tech’s Bloomfield, NJ office. A detailed discussion on the document management is provided in Section 12.

4.2.5 Communication

As part of Earth Tech’s commitment to client services, the Earth Tech Project Manager (Mr. James Kaczor) will be available as a central point of contact to respond to communication from the Buffalo District. If the Project Manager is unavailable, the Earth Tech Technical Task Managers and/or the Senior Technical Reviewer (Mr. Allen Burton) will be available to address USACE concerns.


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5. MANAGEMENT STRUCTURE AND PROJECT DELIVERY TEAM This section defines the organizational structure and management methodology within which the project has been planned and will be implemented with a clear delineation of the responsibility and authority of the personnel involved. Figure 3 illustrates the project organization for implementing the current SOW.

Resumes of key project personnel are provided in Appendix A. Responsibility for implementing Earth Tech quality program as well as those procedures outlined in this plan is shared by all Earth Tech staff working on the project.

5.1 Project Delivery Team The organization chart (Figure 3) illustrates the primary personnel responsible for implementing the SOW. The Earth Tech project delivery team personnel and associated responsibilities are summarized below.

5.1.1 Management

Program Manager: Mr. Mike Thiagaram is responsible for overseeing the overall performance of the project and has ultimate responsibility for client satisfaction. Mr. Thiagaram is a senior program manager with 24 years diversified experience in civil, environmental and geotechnical engineering and program/project management. He has managed a wide range of USACE Hazardous, Toxic and Radioactive Waste (HTRW) projects including engineering analyses, investigation, design, construction, and remediation projects involving innovative treatment technologies. His project/program clients included USACE, USEPA, Air Force Center for Environmental Excellence (AFCEE), and NYSDEC.

Project Manager: Mr. James Kaczor is responsible for managing schedule changes and funding needs, providing appropriate resources for execution of the SOW, and managing the final senior technical review (STR) and ITR. In addition, Mr. Kaczor is responsible for ensuring that all the TPP perspectives are represented within the multi-disciplinary team of personnel and for ensuring that the technical processes produce the desired results. Mr. Kaczor has experience in supervising a multidisciplinary staff of chemical and environmental engineers, geologists and hydrogeologists, geophysicists, chemists, biologists, and toxicologists. Mr. Kaczor has 20 years of professional experience in managing projects under the federal and state contracts with the USACE, USEPA, AFCEE, and NYSDEC.

Technical Task Managers: Several Technical Task Managers have been identified for the project. The Technical Task Managers will be chosen based on the technical skills and experience required to achieve the task goals. The Technical Task Managers will be responsible for coordinating multidisciplinary technical staff on a day-to-day basis to promote efficient completion of tasks outlined in Section 3. The Technical Task Managers identified in Figure 3 have high levels of experience, advanced degrees or training, and specialized skills or extensive experience in specific areas anticipated to be required for each of the tasks to be performed.


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5.1.2 Technical Staff

A multidisciplinary team comprised of environmental engineers, civil engineers, environmental scientists, geologists, geophysicists, data coordinators, and geographical information systems specialists has been developed to implement the project detailed in the SOW. The Earth Tech technical support personnel and their technical roles are presented in Figure 3.

Health and Safety Professional: Mr. Bob Poll, CIH, CSP, will be responsible for directing, evaluating and measuring the implementation of Earth Tech's environmental health and safety programs. In addition, Mr. Poll will be responsible for preparing the Health, Safety and Radiation Protection Plan. Mr. Poll manages Earth Tech's environmental, health and safety support services for environmental operations in the northeast United States. Mr. Poll has 19 years experience in the management of corporate-level health and safety programs. Mr. Poll’s resume is included in Appendix A.

Health Physicist: Mr. Charles Flynn, will perform the role of a health physicist for the project. Mr. Flynn has served as a senior health physicist since 1974 in support of plant operations, maintenance outages, and decontamination and decommissioning projects at nuclear power plants, uranium mill sites, uranium enrichment sites, research and development laboratories, petrochemical facilities, military bases, test ranges, and radiologically contaminated environmental remediation sites. Mr. Flynn has also directed the development and implementation of specialized survey systems using ultrasonic and GPS positioning for expedited site characterizations of sites contaminated with radioactive materials, hazardous materials, and unexploded ordnance. Mr. Flynn has also served as the Chief of the Uranium and NORM (Naturally Occurring Radioactive Material) Licensing Program for the state of Texas.

5.1.3 Quality Control Staff

Although the Program Manager, Project Manager, and Technical Task Managers will each be responsible for ensuring quality of project deliverables, specific personnel have been designated to provide senior and independent review of deliverables. Additional details on the project review process are included in Section 6. Personnel providing the review are described below.

Project Principal for Quality Control: Mr. Maheyar Bilimoria, PhD will provide quality assurance review for this project. Dr. Bilimoria has 30 years of diversified experience in hazardous waste management, chemical processes, computer modeling, and process simulation. Dr. Bilimoria has had direct hands-on experience in almost every aspect of hazardous waste site operations under CERCLA, Resource Conservation and Recovery Act (RCRA), and Toxic Substances Control Act (TSCA) through his participation under contracts with USEPA, NJDEP, USACE, and NYSDEC.

Senior Technical Reviewer: Mr. Allen Burton will provide the overall senior technical review of project deliverables. Mr. Burton has more than 20 years of experience in various aspects of hazardous waste management including site assessments, remedial investigations, feasibility studies, human health risk assessment, field and laboratory quality assurance, data usability, and data interpretation. Mr. Burton has served as quality assurance officer for several USACE and NYSDEC projects.

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6-1

6. GENERAL QUALITY CONTROL IMPLEMENTATION QC implementation on the Guterl Steel site includes a number of activities, including quality planning and project meetings, technical reviews, quality assessment, corrective action, and QC reporting to management. The use of trained and qualified personnel (as described previously in Section 5) is an example of QC implementation.

6.1 Quality Planning and Project Meetings The Earth Tech Project Manager directs the planning activities throughout the project so that technical and quality objectives are met and routinely assessed. Quality planning includes:

• Providing project team members with the necessary planning documents, procedures, and specifications to perform the work correctly.

• Advising team members and providing direction for integration of project requirements in a manner consistent with accepted standards of engineering and scientific practice.

• Identification and continual consideration of project and data quality requirements and objectives.

• Utilization of personnel with appropriate task-specific qualifications and experience. • Kick-off, interim, and close-out project meetings with appropriate team members to

discuss work requirements, QC requirements and results, individual responsibilities, plans and schedules, work progress, and reporting requirements.

• Tracking and control of budgets and schedules. Regular project meetings will be held for the duration of the project. At a minimum, the project meetings will include the Project Manager, Technical Task Managers, and key technical support personnel. Meeting topics will include project progress, coordination among team members, status of critical project or design components, resolution of technical problems, and USACE requirements. A summary memorandum will be prepared for each meeting, as necessary, to document the resolution of technical problems or critical project components. The memorandum will be sent to key team members and copied to the Project Manager. The initial project review meeting for the project is scheduled for June 10, 2005.

6.2 Programmatic and In-House Project Review Technical review will be performed for project work including data assessments, cost estimates, and any project deliverable. The technical review process provides for an evaluation of the work by a STR and an ITR, if required, to verify that the work or product meets the criteria established for the item.

6.2.1 Senior Technical Review

The Project Manager will perform initial review of documents while the deliverable is still in the working stages. Each deliverable will be reviewed by the Project Manager to verify:

• Adherence to the SOW. • Appropriateness and practicability of design and implementation (with respect to

planning documents).


6-2

• That the deliverable or the activities proposed within the deliverable meet the overall project technical objectives, and budgetary constraints.

Formal STR of individual documents will be provided by Mr. Allen Burton, the senior technical reviewer.

For project deliverables such as planning documents and reports, technical and administrative staff will produce one copy of the deliverable in its entirety, i.e., “client ready formats” approximately five days prior to the client delivery date. STR will be performed on this completed document and comments will be noted in the margins of the hard copy report. These comments will be forwarded to and discussed with the Technical Task Manager who will implement or oversee the implementation of the changes. A revised version of the deliverable will be re-reviewed by the STR to confirm that the comments have been addressed. Following this final review, the document will be forwarded to the independent technical reviewer, if required.

6.2.2 Independent Technical Review (ITR)

Qualified persons, as discussed in Section 5, who have not been involved in the preparation and who are under a separate supervision from those involved in the preparation of the SOW submittals, will perform an ITR of the draft documents prior to final submittal to the USACE. As discussed in Section 5, Mr. Darrin Lawrence will provide overall ITR of draft project submittals. This will include, but is not necessarily limited to, the review of the following documents:

• Draft Data Gap Analysis Report • Draft Gamma Walkover Survey Work Plan • Draft Site Safety and Health Plan • Draft Radiation Protection Plan • Draft Field Sampling Plan • Draft Quality Assurance Project Plan • Draft Technical Memorandum on Fate and Transport Analysis • Draft Screening Level Ecological and/or Human Baseline Risk Assessment • Draft Remedial Investigation Report

For this SOW, an ITR will be performed only on the draft data gap analysis report.

Errors, omissions, and/or technical inaccuracies discovered during the ITR will be discussed with the Project Manager, Technical Task Managers, and applicable technical staff. The Task Managers and technical staff will revise and correct the deficiencies. Following this revision, the ITR will review the corrected document to confirm that the comments have been resolved. This process will continue until issues are resolved. Subsequently, the ITR reviewer will certify that the review has taken place by signing and dating a certification of completion form (see Appendix D). This certification will be submitted with the draft report for USACE review.


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7. PROJECT SCHEDULE Figure 4 illustrates only the tasks that have been authorized under the SOW, including duration of each task and submittal milestones. The delivery order was ratified on May 16, 2005, which is indicated as the notice to proceed (NTP).


7-2



8-1

8. PROJECT RISKS Risk is inherent in each task included in the SOW. Identification of project risks, listing and prioritization of risks, determination of risk mitigating actions, and assigning risk mitigation actions to specific personnel, helps to reduce risk and the possible affects on the project. The table below lists the tasks authorized in the SOW dated May 16, 2005 and their associated risk and affect, if risk is not effectively mitigated. The affects are categorized as minor, significant, and critical based on the possible impact to the project. Note that the table summarizes the major risks and is not intended to present a comprehensive list of all risks associated with implementing the SOW.

Task Major Associated Risks Type of Affect – Affect Effective Risk Management 1 – Data Review, Site Visit

Inability to gain access to previous reports, and addenda cited within the SOW.

Inability to gain access to properties during site visits.

Significant – Incomplete “picture” of the site due to missed information. Possibility of not meeting project objectives.

Coordinate with USACE for delivery of “base” planning documents requiring addenda as cited in SOW.

Have the technical personnel involved in review of the necessary documents.

Coordinate with USACE in scheduling site visits to allow time to acquire rights-of-entry for properties included in investigation.

2 – Preparation of E&D QCP & ITR

Incomplete ITR of project deliverables.

ITR by unqualified personnel.

Critical – Possibility of not meeting project objectives.

Delegate ITR to experienced personnel independent of the project.

3 – Identification of Potential ARARs and DQOs.

Incorrect and/or incomplete identification of potential ARARS.

Incorrect DQOs.

Significant – Possibility of not meeting project objectives. Additional effort may be required. May delay the project schedule. Data generated may not be adequate for the intended or necessary uses.

Delegate ITR to experienced personnel independent of the project.

Assign experienced personnel for the task.

4 – Perform Data Gap Analysis

Incorrect and/or incomplete identification of data gaps.

Inability to gain access to previous investigation reports.

Significant – Possibility of not meeting project objectives. Additional effort may be required. May delay the project schedule.

Coordinate with USACE for obtaining all the required documents.

Dedicate experienced personnel throughout various phases of the project.

Assign experienced personnel for the task.

Risk will also be managed by open and frequent communication between the Earth Tech Project Manager and Technical Task Manager and the USACE Project Manager and Design Team Leader. The USACE will be notified in the event of uncertain interpretation of the scope of the task, possible impacts to costs or schedules, or changes in key personnel.


8-2



9-1

9. DESIGN TOOLS The overall quality objective of reports and other deliverables, including electronic deliverables and other documents, is to produce documents and deliverables of professional quality that have been developed in accordance with accepted standards and project-specific criteria.

Reports and documents will be complete and technically correct and will present information in a concise and logical manner. Reports and documents, including associated figures, drawings, and tables, will be produced using standardized software packages including the following:

• Computer-Aided Design and Drafting (CADD) – for preparing figures and drawings. • Geographical Information Systems (GIS) – for preparing GIS maps and drawings. • Microsoft Office Suite –for native file format production of deliverables as well as

database development. Specific software to be used will include Microsoft Word, Excel, PowerPoint, and Access.

• Adobe Acrobat Reader and Writer 7.0 – to read and produce searchable documents. • Design Review Checking System (DrChecks) – for comment and response to

comments on deliverables associated with the SOW. • Corps of Engineers Guide Specifications (CEGS) – predetermined specifications

produced by the USACE to assure conformity in design elements between projects. • Oracle Accounting System – Earth Tech internal cost accounting system for tracking

labor, subcontractor, and other direct/indirect costs applied to the project. • Microsoft Project – for scheduling, task durations, developing critical paths, and

milestones.


9-2



10-1

10. IDENTIFICATION OF QUALITY INDICATORS The following parameters will be used to measure the overall quality of the project:

• Project Budget – Monthly status reports will summarize work performed to date and project funds expended expressed in terms of percent complete. Total project costs will not exceed the total fixed price unless the USACE approves the change in advance. Costs expended will be compared to tasks completed to assess whether the project is being performed within budget.

• Project Schedule – Work performed will be compared to the project schedule to assess whether the project is being completed in a timely manner.

• Technical Quality –The technical quality will also be assessed based upon the number and severity of review comments from the USACE for project planning documents and reports, as well as assessment of attainment of project objectives.


10-2



11-1

11. COST TRACKING AND CONTROL Costs were developed based upon the work breakdown tasks outlined in Section 3. A summary of the projected costs is included in Appendix C. The Oracle Accounting System (“Oracle”) will be used to monitor and control the work performed and to track project expenditures. Oracle, a multi-faceted accounting and data management software, is particularly useful to Project Managers in planning and executing projects. The Oracle system records and reports detailed costs at multiple layers per job through entry of timesheet data, accounts payable, and expenses. The entries are tied to project and task numbers that are assigned by the Project Manager at the beginning of a project. Additional tasks may be opened throughout the duration of the project, as required. Project managers can review the financial status of their projects using the Oracle system, which is located on the Earth Tech intranet and therefore is readily accessible and fully interfaced among offices. Through the Oracle connection, Project Managers can review cumulative charges (labor and direct expenses) that have been set against their project budgets on a task-by-task basis. As a result, Earth Tech’s Project Managers have continually updated cost information for each of their projects at their command. Financial information is also provided in written reports produced by accounting staff located in Bloomfield, New Jersey and Richmond, Virginia. These written reports include summary reports that compare total labor and direct expense charges with the approved budgets.

Project costs will be controlled by:

• Communicating with members of the project delivery team and subcontractors to express the technical and budgetary expectations as well as schedule for completion of each task and subtask.

• Weekly review of total budget, budget spent, and projected costs to complete. • Timely communication with the USACE technical and management team for resolution

of tasks or requests that appear to be out of the currently budgeted SOW. • Timely communication with the USACE management team of previously unforeseen

issues that may impact costs and/or schedule (e.g., restricted, or delays in obtaining, rights-of-entry, resulting in shorter work hours on some properties; etc.).

• Monitoring and controlling subcontractor costs through the use of purchase orders and standardized subcontractor agreements.


11-2



12-1

12. DOCUMENTATION

12.1 Types of Documentation Types of documentation anticipated for completion of the SOW are varied and will fall into the following main categories:

• Contract administration and invoicing; • Project deliverables as outlined in the SOW – for example, planning documents and

reports and associated formal comments and responses; • Required certifications and licenses; • Daily technical correspondence such as emails, memoranda, log books, etc; • Formal memoranda and meeting minutes; including TPP meeting notes; • Check off lists; • Field notes and logs; and, • Electronic files – for example, electronic drawings, digital photographic documentation,

etc.

Project documentation will be maintained as discussed in Section 12.2 below.

12.2 Maintenance of Project Documentation Earth Tech maintains project documentation for a minimum of seven years subsequent to the project being inactive. The project documentation files will be maintained at Earth Tech’s Bloomfield, NJ office. Documentation maintained in the project files will include:

• SOW and associated cost proposal and contract; • Monthly status reports, invoices, and payment documentation; • Final deliverables; • Meeting minutes; • Field notes; and • Laboratory data reports;

Draft files and documents, as well as informal daily correspondence, are not maintained in the final and official project files. Substantial correspondences with the USACE shall be documented in a project notebook for inclusion into the project file.


12-2



REFERENCES New York State Department of Environmental Conservation (NYSDEC), 2003. Registry of

Inactive Hazardous Waste Disposal Sites in New York, Volume 9. April.

NYSDEC, 2000. Immediate Investigative Work Assignment (IIWA) Report for the Unlisted Guterl Excised Area, Lockport, New York, October.

NYSDEC, 1994. Engineering Investigations at Inactive Hazardous Waste Sites, Preliminary Site Assessment, Evaluation Report of Initial Data, Volume I and II, Guterl Specialty Steel, Lockport, New York, April.

NYSDEC, 1991. Engineering Investigations at Inactive Hazardous Waste Sites, Preliminary Site Assessment, Guterl Special Steel Corporation, Lockport, New York, January.

NYSDEC, 1988. Engineering Investigations at Inactive Hazardous Waste Sites in the State of New York, Phase I Investigation, Guterl (Special) Steel Corporation, Lockport, January.

Oak Ridge Institute for Science and Education (ORISE), 1999. Radiological Survey of the Guterl Specialty Steel Corporation, Lockport, New York, December.

USACE, 2005. Scope of Work for the Data Review, Data Gap Analysis, Acquisition of Field Data, And Remedial Investigation for The Former Guterl Specialty Steel Corporation, Lockport, New York. March.

USACE, 2001. Preliminary Site Assessment/Site Inspection, Former Guterl Specialty Steel Corporation, Lockport, New York. April.

USACE, 1998. Technical Project Planning (TPP) Process, EM 200-1-2, U.S. Army Corps of Engineers, August.

USACE, 1993. Regulation No. 1110-1-12. Engineering and Design Quality Management. June.


Figures

Corp IS

(Feet)

US Army Corpsof Engineers

Prepared for:200 0 200 400 Feet

Ohio

Stre

etEr

ie Ba

rge Ca

nal

NYS Route 93

1

2

35

4748

37

14

38

5

24

3688

9 4

Route 31

LEGEND

Guterl Excised BoundaryGuterl Site Boundary

Guterl BuildingsGuterl Landfill Boundary

N

Figure 2. Guterl Steel Site Entities

Lockport, NYE

Figure 3Organization Chart

Risk Assessor Health Physicist Project Chemist Industrial Hygienist Project Engineer Real Estate Counsel Public Affairs Hydrogeologist

Karen Keil Thomas Papura Peter Lorey Anthony Cappella Thomas Kenna Jennifer Janik Michelle Barczak Joan Morrissey William Frederick

Contracting Officer RepresentativeRichard Reffner

Program ManagerMike Thiagaram, PE

Design Team LeaderUSACE BuffaloThomas Kenna

Project ManagerJames Kaczor, PG

Project ManagerRaymond Pilon

Project Principal Quality Control

Maheyar Bilimoria, PhD

Technical Task Managers

Amit Haryani, PEWahid Khan, PE

Mark Moese, PhDClaire Hunt

Jeffrey Hall, PE

Independent Technical ReviewDarrin Lawrence

Senior Technical ReviewAllen Burton

Industrial HygienistRobert Poll, CIH, CSP

Chemist/ScientistJuliana Atmadja, ScD

GIS/CADDRoman SenykJason Klein

Data ManagementCeleste Foster

Health & SafetyRobert Poll, CIH, CSP

Civil EngineerMambu Kawa

Environmental EngineerAmit Haryani, PEJeffrey Hall, PE

GeophysicistMuhammad Akbar, PGPaul Kareth, PG

Health PhysicistCharles Flynn

Regulatory SpecialistMaheyar Bilimoria, PhDAllen Burton

Risk AssessorMark Moese, PhD

Technical Support Subcontracted Services

Laboratory ServicesPersonnel TBDSevern Trent Laboratories, Inc.

DrillerPersonnel TBDSJB Drilling, Inc.

USACEProject Personnel & Contractors

Earth TechQuality Assurance/Management Personnel

Earth TechTechnical Support

Earth TechSubcontractors

Product Delivery Team

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Appendix B Scope of Work for the Data Review, Data Gap Analysis, Acquisition of Field Data,

and Remedial Investigation for the Former Guterl Specialty Steel Corporation Lockport, New York

US Army Corps of Engineers, Buffalo District

Scope of Work Data Review, Data Gap Analysis, Acquisition of Field Data, and Remedial Investigation for the Former Guterl Specialty Steel Corporation

Authorized under the Formerly Utilized Sites Remedial Action Program (FUSRAP) Guterl Specialty Steel Corporation Lockport, New York

Prepared by: U.S. Army Corps of Engineers Buffalo District 1776 Niagara Street Buffalo, New York 14207-3199 March 2005

i

ACRONYMS.............................................................................................................................................................II

1.0 PROJECT BACKGROUND..............................................................................................................................1 1.1 LOCATION .........................................................................................................................................................1 1.2 SITE DESCRIPTION AND HISTORY ......................................................................................................................1 1.3 CURRENT STATUS/POTENTIAL CONTAMINANT SOURCES ..................................................................................2

2.0 STRATEGY AND OBJECTIVES......................................................................................................................3 2.1 SITE STRATEGY ..................................................................................................................................................3 2.2 STUDY OBJECTIVES ............................................................................................................................................3

3.0 DESCRIPTION OF TASKS .........................................................................................................................3 3.1 TASK 1: SITE INSPECTION AND DATA REVIEW ...................................................................................................4 3.2 TASK 2: ENGINEERING & DESIGN QUALITY CONTROL PLAN AND INDEPENDENT TECHNICAL REVIEW..............4 3.3 TASK 3: IDENTIFICATION OF POTENTIAL ARARS AND DATA QUALITY OBJECTIVES..........................................5 3.4 TASK 4: ATTEND TECHNICAL PROJECT PLANNING (TPP) MEETING, PREPARE TPP NOTES, PERFORM DATA GAP ANALYSIS.................................................................................................................................................................6

3.4.1 Data Gap Analysis ......................................................................................................................................6 3.4.2 Summary Document....................................................................................................................................6

3.5 TASK 5 (OPTIONAL): PROJECT WORK PLANS..................................................................................................6 3.5.1 Task 5.1 (Optional) Site Safety and Health Plan and Radiation Protection Plan......................................7 3.5.2 Task 5.2 (Optional) Field Sampling Plan and Quality Assurance Project Plan ........................................7

3.6 TASK 6 (OPTIONAL): ACQUISITION OF FIELD DATA ........................................................................................8 3.6.1 Task 6.1(Optional) Soil ...............................................................................................................................9 3.6.2 Task 6.2 (Optional) Groundwater...............................................................................................................9 3.6.3 Task 6.3 (Optional) Surface Water and Sediments .....................................................................................9 3.6.4 Task 6.4 (Optional) Site Structures.............................................................................................................9

3.7 TASK 7 (OPTIONAL): GROUNDWATER MODEL ...............................................................................................9 3.8 TASK 8 (OPTIONAL): FATE, TRANSPORT, AND EXPOSURE ANALYSIS ..........................................................10 3.9 TASK 9 (OPTIONAL): BASELINE RISK ASSESSMENT .....................................................................................11 3.10 TASK 10 (OPTIONAL): PREPARATION OF THE REMEDIAL INVESTIGATION REPORT....................................11 3.11 TASK 11 (OPTIONAL): COMMUNITY RELATIONS SUPPORT..........................................................................11 3.12 TASK 12 (OPTIONAL): TECHNICAL SUPPORT SERVICES ..............................................................................12

4.0 SUBMITTALS AND PRESENTATIONS .......................................................................................................12 4.1 SUBMITTALS.....................................................................................................................................................12 4.2 CORRESPONDENCE ...........................................................................................................................................12 4.3 COMMUNICATION .............................................................................................................................................12 4.4 FIELD REPORTS ................................................................................................................................................12 4.5 PUBLIC AFFAIRS ...............................................................................................................................................13 4.6 PREPARATION OF PROPOSAL.............................................................................................................................13

5.0 SCHEDULING AND REPORTING................................................................................................................13

6.0 REFERENCES ..................................................................................................................................................13

APPENDIX A – GUTERL SPECIALTY STEEL CORPORATION FIGURES.................................................1

APPENDIX B – KEY COMPONENTS OF AN ENGINEERING & DESIGN QUALITY CONTROL PLAN AND INDEPENDENT TECHNICAL REVIEW ....................................................................................................1

APPENDIX C – RISK ASSESSMENT GUIDANCE .............................................................................................1

APPENDIX D - CONTRACTOR SUBMITTAL PROCEDURES........................................................................1

ii

ACRONYMS

ABHP American Board of Health Physics AEC Atomic Energy Commission ANSI American National Standard Institute ARAR Applicable or Relevant and Appropriate Requirement AWQC Ambient Water Quality Criteria BRA Baseline Human and Screening Level Ecological Risk Assessments CERCLA Comprehensive Environmental Response, Compensation and Liability Act CD-ROM Compact Disc Read-Only Memory CHP Certified Health Physicist COPCs Contaminants of Potential Concern COPECs Contaminants of Potential Ecological Concern CPM Critical Path Method CSM Conceptual Site Model CSRS Contractor Submittal Requirements Summary CSU Combined Standard Uncertainty CTE Central Tendency Exposure DOE Department of Energy DQO Data Quality Objective ECSM Ecological Conceptual Site Model E&D QCP Engineering & Design Quality Control Plan EM Engineer Manual EPA Environmental Protection Agency ERA Environmental Risk Assessment ERAGS Ecological Risk Assessment Guidance for Superfund FSP Field Sampling Plan FUSRAP Formerly Utilized Sites Remedial Action Program HEAST Health Effects Assessment Summary Tables HELP Hydrologic Evaluation of Landfill Performance HHRA Human Health Risk Assessment HQ Hazard Quotients IDW Investigative Derived Wastes IRIS Integrated Risk Information System ISO International Standards Organization ITR Independent Technical Review MARLAP Multi-Agency Radiological Laboratory Analytical Procedures Manual MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDA Minimal Detectable Activity MDC Minimal Detectable Concentration MINTEQA2 Metal Speciation Equilibrium Model for Surface and Ground Water MUCs Military Unique Compounds NCEA National Center for Exposure Assessment NCP National Oil and Hazardous Substances Pollution Contingency Plan NLO National Lead of Ohio NOAA National Oceanic and Atmospheric Administration NTP Notice to Proceed ORISE Oak Ridge Institute for Science and Education ORNL Oak Ridge National Laboratory PA/SI Preliminary Assessment/Site Inspection PDF Adobe Acrobat Portable Document Format QAPP Quality Assurance Project Plan QA/QC Quality Assurance/Quality Control

iii

QC Quality Control QCP Quality Control Plan RAGS Risk Assessment Guidance for Superfund RBCs Risk Based Concentrations RESRAD Residual Radioactivity RI Remedial Investigation ROE Right of Entry RME Reasonable Maximum Exposure RPP Radiation Protection Plan RTVs Reference Toxicity Values SAP Sampling and Analysis Plan Sc Critical Level SESOIL Seasonal Soil Compartment Model SMDP Scientific/Management Decision Point SOW Scope of Work SSHP Site Safety and Health Plan TBC To Be Considered TDS Total Dissolved Solids TPP Technical Project Planning USACE United States Army Corps of Engineers USACHPPM United States Army Center for Health Promotion and Prevention Medicine USEPA United States Environmental Protection Agency

USACE Guterl Specialty FUSRAP Steel Corporation

1

1.0 PROJECT BACKGROUND

The following information has been gathered from numerous sources. It is believed to be accurate but may not be complete. Any information contained herein intended to be relied upon to complete the stated scope of services should be verified and additional information should be gathered as necessary.

1.1 Location

The Guterl Specialty Steel Corporation (Guterl Steel) site is located in Lockport, New York, approximately 20 miles north of Buffalo, New York (Figure 1). The approximately 70 acre site is bordered by Ohio Street to the east, residential and commercial properties to the north, Route 93 to the west, and the New York State Barge Canal to the south (Figure 2). The property is grouped into three areas, the 52 acre Allegheny Ludlum Corporation property, which includes four buildings that were constructed after the termination of AEC activities; the 9 acre landfill area, located in the northwest corner of the site; and the 9 acre excised property, which includes nine buildings that existed during the AEC activities, located in the southeast corner of the site (Figure 2). 1.2 Site Description and History

The Guterl Specialty Steel Corporation site, formerly known as the Simonds Saw and Steel Company, performed rolling mill operations on uranium metal, and to a much smaller extent, thorium metal, during the period from 1948 to 1956. Uranium and thorium operations were performed under two separate contracts. The first contract, AT-30-1-Gen-339, initiated in May of 1948 and in effect until 1952, was negotiated with the New York Operations Office of the Atomic Energy Commission (AEC), predecessor to the U.S. Department of Energy (DOE). The second contract, number S-4, was a subcontract between National Lead of Ohio (NLO), who was under contract with the AEC, and Simonds Saw and Steel, which extended the plant activities until 1956. In total, between 25 and 35 million pounds of uranium and approximately 30 to 40 thousand pounds of thorium were rolled from 1948 until operations discontinued in 1956. More than 99 percent of work done under these contracts involved uranium, which was rolled on the 16-inch rolling mill located in Building 8 (Figure 2). Several small lots of uranium bars were run through the 10-inch rolling mill, and approximately 15 to 20 ingots were processed in the hammer forge shop, which was located in Building 3 (Figure 2). During all operations from 1948 through 1956, the AEC was responsible for providing radiological monitoring and safety guidance and assistance. Residue from the operation was returned to the AEC or NLO. The DOE’s Niagara Falls Storage Site (formerly Lake Ontario Ordnance Works) was used for interim storage of the materials between processing operations and use. Protective measures employed at the site included the use of hoods and dust collection equipment over the 16-inch rolling mill stands, and catch pans in the mill pits to collect material from each rolling operation. The mill area was vacuumed after every batch of 16 ingots, and the shipping area was vacuumed daily. A radiological survey by Nuclear Science and Engineering Corporation/Carborundum Metals was performed in 1958 that identified elevated radiation levels, and indicated that radiation levels were highest in the quench tank area located in Building 8. Area decontamination was performed, clean steel plates placed over the area, and a second radiological survey was performed in December 1958 to verify decontamination was effective. In October 1976, at the request of DOE Headquarters, Oak Ridge National Laboratory (ORNL) performed another radiological survey to determine the status of the property relative to current radiological release guidelines. The ORNL survey revealed that most of the residual contamination remaining from the uranium and thorium rolling operations was confined to the areas inside and immediately outside of Building 6 and 8. On February 7, 1980 DOE determined that the site required consideration for remedial action. New York State was notified of these findings and took steps to ensure that the site would be adequately controlled. In August of 1984, after reviewing historical and contractual information, DOE determined that they did not have the authority under the Atomic Energy Act of 1954 to conduct remedial action at the site. This was primarily due to a “hold harmless” provision in the subcontract between Simonds and NLO, which released the government from liability in regard to these operations. In accordance with DOE policy, the State of New York and the U.S. Environmental Protection Agency (EPA) were notified of the results of the investigation in order that appropriate actions would take place.


2

In August 1982 Guterl Steel filed for Chapter 11 (bankruptcy) protection and in March 1984 Allegheny International (now known as Allegheny Ludlum Corporation) bought the assets of Guterl Steel. The purchase by Allegheny Ludlum Corporation included the entire site with the exception of two areas, classified as the excised property and the landfill. The excised property is approximately 9 acres, consists of a chain-link fenced area that surrounds all of the buildings that existed during the rolling operations from 1948 through 1956, and includes the adjacent exterior land area. The landfill region was originally owned and used by Simonds Saw and Steel Company from 1962 to 1978 and was subsequently owned and used by Guterl Steel from 1978 to 1980. The landfill area was used for the disposal of slag, baghouse flue dust, foundry sand, waste oils and greases, and miscellaneous plant rubbish. The landfill is not lined or covered and, although its surface has been regraded, ponding occurs and surface runoff is uncontrolled. The landfill region is currently a New York State superfund site. The nine buildings located within the excised property include Buildings 1 and 2, the co-joined Buildings 3, 4, 5, 6, 8, 9, and Building 35 (Figure 2). Buildings 1 and 2, built in 1913 and 1914, were primarily used as manufacturing buildings, having total areas of approximately 815 m2 and 6,400 m2, respectively. Buildings 3 and 35, built in 1920 and 1950, were used for grinding and roll staging and have total areas of approximately 6,300 m2 and 410 m2, respectively. Buildings 4 and 9 were built in 1920 and 1918 and were both used as manufacturing buildings and have total areas of approximately 2,600 m2 and 1,800 m2, respectively. Building 5, built in 1918, contained a 25-cycle heat exchanger and has a total area of approximately 350 m2 and is located between Buildings 4 and 6. Buildings 6 and 8, both built in 1918, were used for uranium and thorium metal roll processing and contain the 16-inch and 10-inch rolling mills. The total area of these buildings is approximately 970 m2 and 2,300 m2, respectively. Attached to the west end of Buildings 6 and 8 is a railcar loading dock, which was used to transport residues from the rolling operations. Building 24 is located outside of the excised property boundary and contains approximately 6,900 m2 of floor space. Only the southwest area of the structure existed at the time of the AEC activities. The southeast and north areas were constructed at later periods. Currently the structure is used for general warehousing-type operations. The majority of the buildings are approximately 10 meters in height to the steel I-beam supports. The walls are constructed of brick and sheet metal paneling and the floors consist primarily of compacted dirt with some areas of concrete or bricks. Most horizontal surfaces contain an excessive amount of dust and debris. Buildings 6 and 8 have steel plates on the floor surface with dirt and cinders beneath and with the majority of all the equipment used during the AEC activities still present. The buildings have been isolated since closing and exhibit leaking roofs, broken windows, excessive debris on the floor, etc. Numerous other safety hazards and concerns currently exist within all the buildings. The exterior grounds of the excised area include a crane yard to the east of Buildings 1 and 2, an alleyway between Building 2 and 3, an alleyway encircling Building 5, a courtyard area between Buildings 2 and 35, and the exterior loading dock area to the west of Building 6 and 8. The 9 acre landfill region, which is located in the northwest corner of the site, consists of level grade compacted dirt. The Allegheny Ludlum Corporation property, measuring approximately 52 acres, consists of open land covered with minimal vegetation and numerous piles of used firebrick, stockpiled equipment, and other miscellaneous material. Railroad spurs that presently exist appear to have been moved approximately 10 meters south upon the completion of Building 24 in 1966. The previous location of the rail spurs extended north from the excised property (from the west end of Building 8 and from Building 2), merged and led to the east side of the landfill region. North of the landfill is a one-acre strip of land that leads to another one-third acre parcel that may also have belonged to Simonds Saw and Steel Company. 1.3 Current Status/Potential Contaminant Sources

At the request of the United States Bankruptcy Court for the Western District of Pennsylvania and with the approval of DOE, the Environmental Survey and Site Assessment Program of the Oak Ridge Institute for Science and Education (ORISE) performed a radiological survey of the Guterl Steel site in 1999 (ORISE 1999). The survey procedures included surface scans, surface activity measurements, exposure rate measurements, and soil and miscellaneous material sampling. The survey identified residual uranium and thorium contamination in numerous areas of the site. The surfaces and soils within Building 8 contain the most significant residual uranium surface activity and soil concentration levels. Less extensive areas of residual concentrations of uranium were identified on


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surfaces and/or in soils within Buildings 1, 2, 3, 6, 4 and 9, and 24. For the site exterior, residual uranium and/or thorium was detected at multiple surface and subsurface locations, both within the excised property and in the northern half of the Allegheny Ludlum Corporation property. The survey of the Class 3 area of the site, the southwest portion of the Allegheny Ludlum Corporation property, did not identify any locations of residual uranium concentrations, other than those associated with firebrick. The collection of subfloor soils beneath the concrete in suspect areas of Buildings 2, 3, 4 and 9, and 24 determined that varying degrees of contamination exists within the soils of Building 3 and 24. Thoriated slag was identified beneath the concrete of Building 2. Previous investigations in Building 8 have confirmed contamination throughout the cinder layer, which varies in depth, up to at least one meter. Numerous traps, sumps, and equipment trenches throughout Buildings 3, 6, and 8 contain residues or sediments beneath accumulated water, some of which are contaminated. Exterior areas exhibit pockets of contamination, some of which extend to the bedrock layer, scattered within the excised area and across the northern portion of the Allegheny Ludlum Corporation property. Numerous pieces of thoriated metal are present outside the northern fence of the Allegheny Ludlum Corporation property, due east of the landfill. Because of the high radiation levels from these pieces of metal and existing data collected by the State of New York (NYSDEC 2000, NYSDEC 1994, NYSDEC 1991, NYSDEC 1988), specific samples of this material were not collected. State of New York personnel identified the presence of this material on other property located due north of the northeast boundary of the Allegheny Ludlum Corporation property. The United States Army Corps of Engineers (USACE) Buffalo District completed a Preliminary Assessment/Site Inspection (PA/SI) report in May 2001 (USACE 2001a). In the PA/SI report USACE, Buffalo District recommended that the Guterl Steel site be included into the Formerly Utilized Sites Remedial Action Program (FUSRAP) based on evidence of residual contamination. 2.0 STRATEGY AND OBJECTIVES

2.1 Site Strategy

The strategy for the Guterl Specialty Steel Corporation site is to address all AEC related waste at the site (and adjacent properties, if necessary) as directed by Congress. The strategy will follow the process defined in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The criteria in CERCLA (USEPA 1988a) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (USEPA 1990) will be used for site evaluation and remedy. Project specific Data Quality Objectives (DQOs) will be developed. Based on these objectives the Contractor shall prepare a Sampling and Analysis Plan (SAP), a Site Safety and Health Plan (SSHP), and a Radiation Protection Plan (RPP) delineating the methodologies, staffing and reporting protocols to be used during the Remedial Investigation (RI). These work plans must be submitted to and accepted by the USACE before implementation of the plans commences. The goal during the execution of this SOW is to generate data of known quality for the intended usage on the first attempt. The data shall be of sufficient quality and quantity, with quantitation levels low enough to meet pertinent standards, applicable or relevant and appropriate requirements (ARARs), and remediation goals.

2.2 Study Objectives

The Data Gap Analysis Report, Task 4 in this Scope of Work (SOW), will be incorporated into the Remedial Investigation (RI) report for the site. The long-term objective of this project is the selection of a protective remedy that satisfies CERCLA.

3.0 DESCRIPTION OF TASKS

This Scope of Work (SOW) delineates requirements for project data review, data gap analysis, project work plans, acquisition of field data, preparation of a remedial investigation report, and technical and community relations


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support for the Guterl Specialty Steel Corporation FUSRAP site, including adjacent properties, if necessary. All work is to be performed in accordance with CERCLA. The USACE completed a PA/SI as the first step in the CERCLA process. The Contractor shall provide all labor, material, equipment, and laboratory facilities necessary to perform the services described below. The Contractor shall furnish the required personnel, equipment, instruments, and transportation necessary to accomplish the required work and furnish to the Government data, reports, and all other material developed. During the execution of the work, the Contractor shall provide adequate professional supervision and Quality Control (QC) to assure the accuracy, quality, completeness, and progress of the work. 3.1 Task 1: Site Inspection and Data Review

The Contractor shall perform a visual walkover of the former Guterl Specialty Steel Corporation site, take pertinent photographs and denote the locations of applicable features at the site. The Contractor shall obtain, review and be in accordance with a Site Safety Plan from Allegheny Ludlum Corporation. The contractor shall coordinate this site visit with the USACE Project Manager, Mr. Raymond L. Pilon. If necessary, USACE Engineer/Scientist(s) shall accompany the contractor on the site inspection. Documents and data pertaining to the former Guterl Specialty Steel Corporation shall be collected at the USACE Buffalo District Office following the site inspection. The Contractor shall review historical data applicable to the site. Data review should include, but not be limited to, pertinent documents listed in the References section of this SOW and any pertinent references of these documents, and data obtained during the execution of this SOW. A list of the information gathered from this trip shall be summarized and used for the preparation of the Engineering and Design Quality Control Plan (Task 2). 3.2 Task 2: Engineering & Design Quality Control Plan and Independent Technical Review

The Contractor shall prepare an Engineering & Design Quality Control Plan (E&D QCP) as defined in the base contract to cover development of all products described in this Delivery Order. An E&D QCP is the Contractor’s management plan for execution of all aspects of the contract. It describes the way the Contractor will produce the deliverables and the steps that will be taken to control product quality, i.e., the Design, Engineering Drawings, and the Independent Technical Review (ITR) required under the contract for this project. A list of items that would normally be in the E&D QCP is included in Appendix B. Please note that this plan applies to the overall project, and is not part of the document that will be prepared for quality control and quality assurance of sample acquisition and analysis. The E&D QCP shall specify and document the policies and procedures the Contractor will follow in performance of this SOW. It must include, at a minimum, the following:

- Personnel responsibilities and qualifications, - Communications and reporting arrangement, and - Project schedule

The Contractor is required to specifically identify the individuals responsible for producing the Health, Safety, and Radiation Protection Plan and provide a detailed description of their qualifications (resume). The Contractor’s goal shall be to submit a complete and technically sound, implementable document sufficient for approval upon initial review by the USACE. To accomplish this, the Contractor is encouraged to contact the USACE during development of the submittal, and to discuss issues such as methodology, regulation interpretation, etc with relevant technical staff. The Contractor shall perform an Independent Technical Review of all documents identified in Appendix B as requiring an ITR review and attach an ITR Certification to new transmittals of documents before they are submitted to the Corps for review. ITRs do not need to be performed for document resubmittals. The ITR will focus primarily


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on conformance to the approved design and appropriate technical criteria for function, reliability, and safety. Although the ITR is not for value assessment or value engineering, such comments may be a natural outcome of the review. These comments will be considered suggestions and will not require a formal response. Performance of the ITR should not be accomplished by the same personnel that produced the product and personnel performing the ITR must have different supervision than those individuals producing the product. This is to ensure that a truly independent technical review is accomplished. If the Contractor elects to have the review done by another agency or firm, it shall identify that agency in the E&D QCP. Upon completion of the ITR, the Contractor shall submit to USACE a Certificate of Completion signed by the reviewer(s) (see Appendix B), along with responses to comments received. Please note that the labor hours associated with the ITR of documents should be estimated within the task associated with the document, and not within this task. 3.3 Task 3: Identification of Potential ARARs and Data Quality Objectives

Identification of potential ARARs begins early in the RI process. It is an iterative process that is refined as the RI progresses toward the remedial alternative analysis phase. ARARs can be classified as chemical, location, or action specific. Since this SOW is developed with the intent of collection the data needed for developing and evaluating effective remedial alternatives (if necessary), it is appropriate to examine potential ARARs during this phase. The Contractor shall identify potential Federal and State ARARs for this project, and briefly discuss why they may be ARARs, in order to perform data evaluation during the RI. The Contractor shall use the ARAR selection process as presented in CERCLA Section 121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA defines applicable requirements as those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal and/or State environmental or facility citing laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstances found at a CERCLA site. Relevant and appropriate requirements are defined as those substantive environmental protection requirements, promulgated under Federal and/or State law, that, while not jurisdictionally applicable, address problems or situations similar to those encountered at the CERCLA site and that are well suited to the particular site. Determination of ARARs is site specific and depends on chemical and radiological constituents present, site/location characteristics, and remedial actions under consideration for remediation of the site. State environmental statutes may be applicable or relevant and appropriate if they are: more stringent than Federal requirements; promulgated, generally applicable, and legally enforceable; identified by the State in a timely matter; and consistently applied in similar circumstances at other sites. It should be noted that while some state laws/requirements are being identified and evaluated as potential ARARs in this report, USACE shall identify ARARs and request that the State of New York identify specific sections of regulations or guidance that the State believes should be an ARAR. The State shall identify what the cleanup standard is and their justification for providing that section as a proposed ARAR to USACE (as required under CERCLA 40 Code of Federal Regulations [CFR] 300.430[b][9]). In addition to ARARs, advisories, criteria, or guidance may be identified as to be considered (TBC) information for a particular scenario. As defined, the TBC category consists of advisories, criteria, or guidance developed by EPA, other Federal agencies, or states that may be useful in developing remedies. Potential TBC requirements are typically considered only if no promulgated requirements exist that are either applicable or relevant and appropriate. The Contractor shall prepare a document describing his ARAR selection process and identifying the potential ARARs selected for this project. The Contractor will be asked to participate in discussions with Federal and State regulatory agencies for final ARAR determination and cleanup criteria.


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In addition, the Contractor shall develop project-specific Data Quality Objectives (DQOs) in accordance with EM 200-1-2 (USACE 1998b) Technical Project Planning (TPP) Process, and include these objectives as a separate section in the document identifying the potential ARARs. DQOs are qualitative and quantitative statements that clarify study objectives, define the appropriateness of data, and specify the tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support decisions (USACE 1998b). After USACE review of the potential ARAR/DQO document, a meeting at the USACE Buffalo District office between the Contractor and USACE representatives will be held to discuss and finalize the ARARs and DQOs. Meeting minutes shall be taken by the Contractor, and a brief document summarizing the meeting participants, discussions and outcomes shall be prepared. 3.4 Task 4: Attend Technical Project Planning (TPP) Meeting, Prepare TPP Notes, Perform Data Gap Analysis

The Contractor shall attend a two-day Technical Project Planning meeting in the Buffalo area. Project-specific DQOs shall be further defined during the TPP meeting. The Contractor shall be responsible for maintaining detailed notes of the TPP meeting and providing the notes in electronic format to the USACE. The Contractor shall evaluate the quality of existing data based on the requirements set by CERCLA. The Contractor shall evaluate the relevance and usefulness of the data. EM 200-1-3 (USACE 2001b) and EM 200-1-6 (USACE 1997) provide guidance on data requirements. Based on existing data pertaining to the Guterl Specialty Steel Corporation site and the outcome of the TPP meeting, the Contractor shall summarize useful data and data deficiencies for each of the following categories:

1. Soil/Sediment 2. Groundwater 3. Surface Water 4. Building Surfaces

If the existing data is not sufficient to complete a RI report, the Contractor shall specify the nature and extent of the additional data needed, and make recommendations with respect to further data collection and analysis. This includes data that will be needed to conduct a Fate and Transport Analysis and a Baseline Human Risk Assessment and screening level Ecological Risk Assessment. 3.4.1 Data Gap Analysis

The Contractor shall identify gaps in existing data and demonstrate how the collection of additional data will enhance the understanding of the surficial and subsurface systems and the fate and transport of the suspected contaminants. In order for data to be used in the risk assessment (Task 9), the following information must be present with the data: results including units, method detection limit, laboratory analysis method, sampling coordinates including depth (soil and groundwater), sample matrix, data qualifiers, and a chain of custody. The Contractor shall document, and make recommendations pertaining to, the data needs and collection options necessary to complete a RI. The output of this analysis should be detailed enough to use in a RI sampling and analysis plan. 3.4.2 Summary Document

The Contractor shall prepare a document outlining the results of the Data Gap Analysis. The report shall contain one section for each pathway (soil, groundwater, surface water, and building structures). Each of these sections shall summarize the available data, contamination indicated by that data, and provide justification of any additional recommended data collection. Each section shall contain a list of reference(s) to the source of the data. 3.5 Task 5 (OPTIONAL): Project Work Plans

The project work plans shall be comprised of: a Site Safety and Health Plan/Radiation Protection Plan, a Field


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Sampling Plan and a Quality Assurance Project Plan. These plans shall include all proposed field activities except a gamma walkover survey, for which a separate set of plans shall be produced. The gamma walkover survey work plans shall contain all applicable sections of the project work plans related (only) to the execution of the survey. Detailed strategies shall be presented in the project work plans on how data will be collected to fill data gaps. Results of the Data Review and Data Gap Analysis, performed under this SOW, shall be incorporated and made an integral part of the Remedial Investigation (RI) Work Plans. Key elements of the RI requiring additional data may include, but are not limited to, nature and extent of contamination, conceptual model, and fate and transport of contamination. The project work plans must be accepted by the USACE prior to the commencement of any fieldwork. 3.5.1 Task 5.1 (Optional) Site Safety and Health Plan and Radiation Protection Plan

The Contractor shall have in place a safety and health program that meets 29 CFR 1910.120 (b) requirements. The Contractor shall also prepare and submit a Site Safety and Health Plan (SSHP) that follows the exact outline of all elements (including radiation protection requirements) in Appendix C of ER 385-1-92 (USACE 2000). The Contractor is to submit an original SSHP document that is site specific and written only for this site. No “off-the-shelf” SSHP documents are acceptable. These plans must be reviewed by USACE personnel prior to performance of field activities, including mobilization. These plans shall conform to all appropriate USACE guidance, including but not limited to ER 385-1-92 Appendix C, and Engineer Manual (EM) 385-1-1 (USACE 2003). USACE guidance for preparation of site-specific SSHPs will be provided to the Contractor upon request. The radiation protection elements shall be included as a separate document called the "Radiation Protection Plan" (RPP) and shall be included as an Appendix in the SSHP. The Contractor will design an Activity Hazard Analysis for all field activities in accordance with the USACE Safety and Health Requirements Manual, EM 385-1-1 (USACE 2003), Figure 1-1, page 4. This Activity Hazard Analysis shall be included in the SSHP. The Contractor shall comply with all other appropriate and applicable regulations, which include but are not necessarily limited to: 29 CFR 1910.120, Hazardous Waste and Emergency Response; 10 CFR 20, Standards for Protection Against Radiation; and 49 CFR 172, Hazardous Materials. The Contractor shall also comply with any facility-specific health and safety procedures mandated by the site owner. The Contractor shall utilize the services of a Health Physicist certified by the American Board of Health Physics (ABHP) with 2 years experience in radioactive waste handling and disposal operations. The Certified Health Physicist (CHP) shall be responsible for preparing a site radiation risk evaluation, and the development of a Radiation Protection Program for inclusion in the SSHP. The radiation protection program shall be developed, documented, and implemented in a manner that ensures the program is commensurate with the scope and extent of activities, and is sufficient to ensure compliance with the provisions of the applicable standards. The CHP is not required on site continuously during the project, but must be on site at least 25 percent of the total field operation time. The CHP must be available for consultation with site personnel and for emergencies. 3.5.2 Task 5.2 (Optional) Field Sampling Plan and Quality Assurance Project Plan

The Contractor shall prepare a Field Sampling Plan (FSP) that specifies, and provides for documentation of, the data collection program. The Contractor is required to provide justification of why each data set is necessary. The FSP shall also include plans for mobilizing to the site, as well as plans for disposal of investigative derived wastes (IDW). The FSP shall be reviewed and approved by the USACE before work commences. The Contractor shall use the USACE publication entitled “Requirements for the Preparation of Sampling and Analysis Plans, EM 200-1-3” (USACE 2001b) and Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) 2000 as guidance in preparing the FSP. The Contractor shall also use the guidance of Multi-Agency Radiological Laboratory Analytical Procedures Manual (MARLAP) for technical project planning of radiochemical analysis. Radiochemical laboratories should report: minimal detectable activity or minimal detectable concentration (MDA or MDC) and critical level (Sc) consistent with MARLAP Chapter 20; analysis results, including negative results and combined standard uncertainty (CSU) consistent with MARLAP Chapter 19; and quality control lab methods as outlined in


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Chapter 18. The Contractor shall also provide to their Buffalo District approved laboratory a copy of the Department of Defense Quality Systems Manual as listed in the references section of this SOW (DOD 2002). The Contractor shall also use the Department of Defense Quality Systems Manual in developing the FSP and Quality Assurance Project Plan (QAPP). The Contractor shall coordinate with the USACE and the site owner to address any potential site constraints or other factors that may impact site characterization activities. The Contractor shall also prepare a QAPP, which shall be reviewed by the USACE before work commences. Guidelines for QAPP preparation are also given in EM 200-1-3 (USACE 2001b). Together the FSP and the QAPP constitute the Sampling and Analysis Plan (SAP). Please note that the QAPP described herein applies only to data acquisition and analysis and is not part of the E&D QCP described in Task 2. The QAPP and the E&D QCP are two separate documents with different names and purposes. 3.6 Task 6 (OPTIONAL): Acquisition of Field Data

In an effort to ensure the production of high quality chemical and radiological data that satisfy the project-specific DQOs, ER 1110-1-263 (USACE 1998a), including references in Appendix A, MARSSIM 2000, and MARLAP will be utilized to complete this task. Once the project work plans are reviewed and approved by the USACE, the Contractor shall implement the data acquisition plan for all necessary activities. Any installation of soil borings or monitoring wells shall comply with EM 1110-1-4000, Monitoring Well Design, Installation, and Documentation at Hazardous, Toxic, and Radioactive Waste Sites (USACE 1998c). The Contractor shall be responsible for disposal of all IDW, which must be considered and included in the Contractor’s cost proposal. The Contractor shall be responsible for characterizing all IDW into waste streams, including identifying and executing any sampling and analysis that may be required. All waste containers shall be properly sealed and labeled. The Contractor shall identify and select an appropriate disposal facility(ies) and submit completed disposal application (s). The Contractor shall coordinate the IDW disposal with the disposal facility(ies) and the USACE. Concurrent with or after IDW disposal activities, the Contractor shall ensure that all equipment and supplies are scanned and decontaminated as necessary to meet release criteria (Army Regulation 11-9) prior to leaving the site. During demobilization activities, the Contractor shall appropriately dispose of any IDW (equipment/supplies) that does not meet release criteria (Army Regulation 11-9). The Contractor shall ensure that leased equipment is thoroughly decontaminated and returned to the supplier in good condition. Verification surveys on the decontaminated equipment and supplies shall be performed and provided to the USACE. The verification surveys will require USACE approval prior to Contractor release action. The USACE Buffalo District may perform confirmatory release surveys. Demobilization will be considered complete only after the USACE Buffalo District has verified that all activities authorized under this task have been completed by the Contractor to the satisfaction of the USACE and all required documentation is provided to the USACE. New data collected during the acquisition process shall be entered into electronic data base format. The project database shall be screened for completeness, including but not limited to ensuring that all fields required for completing the risk assessment are present and complete. This includes, but is not limited to, the following fields: the method detection limit, starting and ending depths, method of analysis, investigative area, location, collection date and analysis date, data validated column, and “ok to use” column which implies that the aforementioned information is available. The Contractor shall update the database as needed to ensure that the most up-to-date data has been included. The Contractor is required to comply with all provisions stated in the USACE Rights of Entry (ROE) while on the Guterl Specialty Steel Corporation property and the Allegheny Ludlum Corporation property. Further, the Contractor must be in accordance with all safety protocols, as directed by the Allegheny Ludlum Corporation’s site manager, and Allegheny Ludlum Corporation’s Health, Safety, and Radiation Protection Plans. The Contractor shall propose field activities for the Guterl Steel site (including adjacent properties, if necessary) for the following areas in the FSP for USACE acceptance.


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3.6.1 Task 6.1(Optional) Soil

The Contractor shall propose the number and placement of soil samples, and the analytes of concern. This shall include surface and subsurface soil sampling. The combination of existing data and the data collected for this task should be adequate to delineate the nature and extent of soil contamination at the site, define fate and transport of materials, perform risk/dose assessments, and meet other requirements as specified by the USACE. This work shall be performed in accordance with sections 3.3.4.7.8 Subsurface Soil and 3.3.4.7.9 Surface Soil and Sediment of EM-200-1-3 (USACE 2001b). Task 6.1.1 (Optional) Gamma Walkover Survey In order to aid the selection of soil sampling locations, a gamma walkover survey shall be performed at Guterl Specialty Steel Corporation prior to the commencement of other fieldwork and sampling. The contractor shall propose the amount of survey coverage, in the separate gamma walkover survey work plans, as described in Task 5. Where possible, gamma activity data will be collected concurrently with global positioning data. Daily gamma survey results and/or a daily map of the gamma survey progress shall be made available to the USACE by the close of business one working day following any gamma survey activity. 3.6.2 Task 6.2 (Optional) Groundwater

The Contractor shall propose the number and placement of groundwater monitoring wells and groundwater samples, and the analytes of concern for each proposed sample. The combination of existing data and the data collected for this task should be adequate to delineate the nature and extent of groundwater contamination at the site, define fate and transport of materials, perform risk/dose assessments, and meet other requirements as specified by the USACE . This work shall be performed in accordance with section 3.3.4.7.6 Groundwater of EM-200-1-3 (USACE 2001b). 3.6.3 Task 6.3 (Optional) Surface Water and Sediments

The Contractor shall propose the number and placement of samples and the analytes of concern. The combination of existing data and the data collected for this task should be adequate to delineate the nature and extent of surface water and sediment contamination at the site, define fate and transport of materials, perform risk/dose assessments, and meet other requirements as specified by the USACE. The task shall be performed in accordance with sections 3.3.4.7.10 Surface Water and 3.3.4.7.9 Surface Soil and Sediment of EM-200-1-3 (USACE 2001b). 3.6.4 Task 6.4 (Optional) Site Structures

The Contractor shall propose the type, number, and placement of samples and the analytes of concern. This shall include scan and swipe samples to determine the nature and extent of radiological contamination in and on building floors, walls, and ceilings/roofs. In addition, the Contractor shall propose the type, number, and placement of samples to determine the nature and extent of asbestos and chemical contamination in and on building floors, walls, and ceilings/roofs. The combination of existing data and data collected for this task shall be adequate to delineate the nature and extent of contamination in and on the buildings of the Guterl Specialty Steel Corporation site. The Contractor shall define the fate and transport of contaminants. This task shall be performed in accordance with EM-200-1-3 (USACE 2001b). 3.7 Task 7 (OPTIONAL): Groundwater Model

The groundwater model task has been broken down into subtasks. 3.7.1 Geologic Model The Contractor will incorporate geologic data that were obtained from existing sources and from the Guterl project field investigation into a project geologic model. The geologic boundaries will be exported from the modeling software as grid-based coordinate data, i.e. easting, northing, elevation, column, row, for USACE use. These data also will be used by the Contractor to develop hydrostratigraphy for a possible groundwater model.


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3.7.2 HELP Modeling for Infiltration Estimates The Contractor shall compile a Hydrologic Evaluation of Landfill Performance (HELP) model of the Guterl Specialty Steel Corporation site conditions in order to provide groundwater recharge estimates for the numerical model and SESOIL simulations. Site-specific or appropriate literature values shall be used as input to a simplified HELP model that will estimate groundwater recharge to any natural water bearing units underlying the site. The simulations will use average site-wide lithologic conditions as input. This will provide groundwater recharge estimates for the most common conditions currently occupying the Guterl Steel site. 3.7.3 SESOIL Modeling for Soil Contamination Leaching to Groundwater The Contractor shall compile a SESOIL model of the Guterl Steel site representative of surface and/or near-surface soil contamination. Infiltration results from the HELP simulations, site specific hydrogeologic data, contaminant distributions in the vadose zone, and appropriate literature values will be input to SESOIL, which will estimate contaminant leaching to the groundwater in the area where most site soil contamination exists. The contaminants will include, but may not be limited to site contaminants of potential concern (COPCs). The results will include representative leaching rates, leachate concentrations, and temporal groundwater loading for the COPCs. These results may be used as input to a potential contaminant transport model. 3.7.4 MINTEQA2 Modeling of Hydrogeochemical Conditions The Contractor shall assemble site specific and appropriate literature values of chemical solubility and Kd for Guterl Steel COPCs. Since radiochemical transport is subject to uncertainty and highly dependent upon the site-specific geochemical conditions, the Contractor shall also model hydrogeochemical conditions at the Guterl Steel site using the MINTEQA2 code. Key COPCs will be assessed for site-specific solubility values and/or a reduced range of uncertainty for geochemical conditions at the Guterl Steel site. The Contractor shall use groundwater monitoring data to assemble a representative and near-balanced anion and cation inventory to simulate the speciation of radionuclides (elemental) and other COPCs in the on-site water bearing zone. A simple uncertainty analysis of the anion/cation ratio shall be performed if unbalanced (not unity). The site-specific or referenced COPC solubility and Kd values generated by this task will be input to the SESOIL model. All literature references shall be submitted by the Contractor for review by the USACE. 3.8 Task 8 (OPTIONAL): Fate, Transport, and Exposure Analysis

The Contractor shall conduct a site-specific fate, transport, and exposure analysis for the Guterl Special Steel Corporation site. This task requires the analysis of the potential for the release and transport by all possible pathways, including air, soils, surface water, and groundwater. In addition to applicable transport mechanisms, transformation, and/or attenuation mechanisms are to be evaluated for the affected media. The analysis should include a site-specific conceptual model for the Guterl Steel site depicting sources, contaminant transport routes, and potential human and ecological receptors. The major contaminants identified at the Guterl Steel site to date are radionuclides, however, transport of metals and organic compounds must be considered if such contaminants are identified during field sampling and analysis and are determined to fall under the jurisdiction of the FUSRAP. The Contractor shall describe the methodology proposed for the fate, transport, and exposure analysis. Included shall be the model framework proposed and the rational for either an analytical or numerical model. It is essential that fate, transport, and exposure analysis and modeling be coordinated with the Contractor’s risk assessor such that the requirements for risk assessment are satisfied. The Contractor shall prepare a preliminary Fate and Transport Analysis prior to field sampling activities, using existing data. The results of this preliminary Fate and Transport Analysis shall be submitted to the USACE Buffalo District as a Technical Memorandum. The Contractor shall then incorporate all additional field data generated under this Scope of Work into the final Fate and Transport Analysis, which will be included as part of the Remedial Investigation portion of the RI Report. The Contractor shall employ the document entitled “Superfund Exposure Assessment Manual” (EPA/540/1-88/001


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April 1988b) in development and performance of this task. This manual provides guidance on contaminant release analysis, exposed population analysis, and uncertainty analysis. 3.9 Task 9 (OPTIONAL): Baseline Risk Assessment

As part of the remedial investigation, the Contractor shall perform a screening level ecological risk assessment, following the protocol outlined in Appendix C of this SOW. If it is deemed necessary after completing the screening level ecological risk assessment, the USACE Buffalo District shall direct the Contractor to perform a baseline ecological risk assessment following the protocol outlined in Appendix C. The Contractor shall prepare a human Baseline Risk Assessment (BRA) and the Ecological Risk Assessment (if directed) for the Guterl Specialty Steel Corporation site. While the BRA shall focus primarily on the risks from the radiological contamination at the Guterl Steel site, the Contractor shall also assess the risks from any chemical contamination that is determined to fall under the jurisdiction of FUSRAP. The intent of the Human Health Evaluation shall be to assess the current and reasonable future exposures with the associated risks from site contaminants in the event no action is taken to remove contaminants and/or prevent their migration. The purpose of the Ecological Risk Assessment shall be to determine whether actual or potential ecological risks are occurring, or may occur, at the site. The Contractor shall follow the USEPA’s “Risk Assessment Guidance for Superfund” (USEPA 1989, 1991a, 1991b, and 1998) in performing this task. Additional guidance is given in Appendix C of this SOW. All existing data and any new data and information gathered during the performance of this SOW shall be incorporated into the BRA as appropriate. The Contractor shall detail site-specific risk assessment methodology in the same submittal as Fate, Transport, and Exposure Analysis for the USACE approval. 3.10 Task 10 (OPTIONAL): Preparation of the Remedial Investigation Report

The Contractor shall prepare a Remedial Investigation (RI) report that shall include, but not be limited to, an outline, acronym list, executive summary, introduction, site history, data quality objectives, description of site activities, physical site description, data quality, nature and extent of contamination (such as impacted soil extent and groundwater plume maps), risk assessment, fate and transport of contaminants, conclusions and recommendations. Preparation of the RI report shall be consistent with the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988a), and other relevant guidance by the USEPA and the USACE. Appendices to the RI report shall include, but not be limited to, boring logs, well construction details, finalized response to comments package, quality control information, data summary tables, all laboratory analysis data, data validation results (to be prepared by USACE), and other relevant information to the development of the RI report. This task involves time to prepare the RI report and coordinate with the USACE project team, and stakeholders, to ensure incorporation of the Baseline Risk Assessment and Contaminant Fate and Transport Model. The Contractor will format the text, tables, and figures of the risk assessment chapters (Task 9) (chemical human health risk assessment, radiological human risk assessment, building risk assessment, and screening level ecological risk assessment) and modeling chapters (Task 8) for incorporation into the RI report. 3.11 Task 11 (OPTIONAL): Community Relations Support

Although the USACE has principal responsibility for community relations activities, the Contractor shall assist the USACE as requested by providing information regarding site history, participating in public meetings, preparing written materials and displays, and providing other support as requested. The Contractor shall also assist the USACE Buffalo District by interfacing with other agencies, Contractors, districts/divisions within the USACE, government officials, and organizations/individuals as requested. Assistance shall include but not be limited to providing information regarding site history, discussing data acquisition techniques and characterization results, attending meetings and forums, preparing written materials, presentations and displays, conducting interviews and providing other support as requested. For cost estimating purposes, the


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USACE assumes that a total of 200 labor hours are associated with this task. This includes management, professional, and non-professional labor categories. 3.12 Task 12 (OPTIONAL): Technical Support Services

The Contractor shall provide the necessary labor to provide technical support services throughout the performance of this work order. These services may include engineering support, health physicist support, and other technical support as required. For estimating purposes, the USACE assumes that a total of 400 labor hours are associated with this task. This includes management, professional, and non-professional labor categories. 4.0 SUBMITTALS AND PRESENTATIONS

4.1 Submittals

The Contractor shall furnish copies of all prepared reports and documents to the Project Manager as shown below. Following each submission, comments generated as a result of review by the USACE and applicable regulatory agencies shall be incorporated into the final draft. Electronic copies of major reports shall be provided in Microsoft Word/Excel format, as well as in Adobe Acrobat Portable Document Format (PDF). Also, reference Appendix D for additional guidance.

Addressee Memos and Status Reports

Draft Reports

Final Reports

U.S. Army Corps of Engineers Buffalo District Attn: Raymond L. Pilon, Project Engineer 1776 Niagara Street Buffalo, NY 14207-3199

3 copies 10 copies plus

electronic

10 copies plus

electronic

4.2 Correspondence

The Contractor shall make a record of each telephone conversation and written correspondence regarding information pertinent to the performance of this contract. A summary of the telephone conversations and correspondence shall be submitted to the USACE Project Manager (refer to address in Section 4.1) on a monthly basis. 4.3 Communication

Good communication between the Contractor and the USACE is essential to deliver quality products and keep the project on schedule. Accordingly, the Contractor is encouraged to contact USACE personnel with questions, and required to advise the USACE about problems and delays as soon as they arise. In addition, weekly conference calls with USACE project personnel will be held to discuss project progress. 4.4 Field Reports

Daily Quality Control Reports shall be prepared both in the field and in the laboratory (should laboratory work be required). These reports shall be compiled weekly by the Contractor and made available to the USACE as requested. The USACE project engineer shall be notified immediately of significant problems with sampling, well installation, instrument calibration and laboratory analysis. This notification is to be followed by a letter to the Contracting Officer within five working days of the discovery of the problem. Reports shall detail the solutions agreed upon with the project engineer and corrective actions taken. The Contractor shall also maintain a file of these reports, and submit them as an appendix to the final report.


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4.5 Public Affairs

The USACE will conduct community relations activities designed to inform the public of the nature of the environmental problem, the threat the problem could pose, responses under consideration, and the progress being made addressing the problem. The Contractor may be required to attend and participate in public meetings as specified in the task list. 4.6 Preparation of Proposal

The Contractor shall prepare a cost estimate for negotiation with the USACE Contracting Officer based on work tasks as presented in this scope of work. The Contractor shall list all assumptions on which the cost estimate was based. The cost estimate must include all tasks delineated in this scope of work, unless otherwise directed. 5.0 SCHEDULING AND REPORTING

The following schedule will be adhered to in performance of this SOW. This does not include interim deliverables (such as technical memorandums) regarding critical decision points, which will be conveyed by the USACE project team.

Deliverable/Action Due Date

Site Inspection (Task 1) 14 calendar days after Notice to Proceed (NTP)

Draft E&D QCP (Task 2) 21 calendar days after NTP

Final E&D QCP (Task 2) 10 calendar days following receipt of USACE Comments

Draft ARAR/DQO Document (Task 3) 42 calendar days after NTP

Final ARAR/DQO Document (Task 3) 14 calendar days following receipt of USACE Comments

Attend Technical Project Planning Meeting (Task 4) As scheduled by USACE, following completion of Tasks 1, 2, and 3

Prepare TPP Meeting Notes (Task 4) 7 calendar days after TPP Meeting

Draft Data Gap Analysis Document (Task 4) 28 calendar days after TPP Meeting

Final Data Gap Analysis Document (Task 4) 14 calendar days following receipt of USACE Comments

6.0 REFERENCES

The following documents are provided for reference. Additional documentation may be used as required. 1. 10CFR20. Code of Federal Regulations, Title 10, Part 20, January 1999. 2. 29CFR1910.120. Code of Federal Regulations, Title 29, Part 190, Section 120, July 1999. 3. 49CFR172. Code of Federal Regulations, Title 49, Part 172, October 1998. 4. DOA 1999. The Army Radiation Safety Program, Army Regulation 11-9, Department of the Army, May 1999. 5. DOD 2002. Department of Defense Quality Systems Manual for Environmental Laboratories, DoD

Environmental Data Quality Workgroup, Department of Navy, Lead Service, Version 2, June 2002. 6. NYSDEC 2000. Immediate Investigative Work Assignment (IIWA) Report for the Unlisted Guterl Excised

Area, Lockport, New York, New York State Department of Environmental Conservation, October, 2000. 7. NYSDEC 1994. Engineering Investigations at Inactive Hazardous Waste Sites, Preliminary Site


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Assessment, Evaluation Report of Initial Data, Volume I and II, Guterl Specialty Steel, Lockport, New York, New York State Department of Environmental Conservation, April 1994. 8. NYSDEC 1991. Engineering Investigations at Inactive Hazardous Waste Sites, Preliminary Site

Assessment, Guterl Special Steel Corporation, Lockport, New York, New York State Department of Environmental Conservation, January 1991.

9. NYSDEC 1988. Engineering Investigations at Inactive Hazardous Waste Sites in the State of New York, Phase I Investigation, Guterl (Special) Steel Corporation, Lockport, New York, New York State Department of Environmental Conservation, January 1988.

10. ORISE 1999. Radiological Survey of the Guterl Specialty Steel Corporation, Lockport, New York, Oak Ridge Institute for Science and Education, December 1999.

11. USACE 2003. Safety and Health Requirements Manual, EM 385-1-1, U.S. Army Corps of Engineers, November 2003.

12. USACE 2001a. Preliminary Assessment/Site Inspection, Former Guterl Specialty Steel Corporation, Lockport, New York, April 2001. 13. USACE 2001b. Requirements for the Preparation of Sampling and Analysis Plans, EM 200-1-3, U.S. Army Corps of Engineers, February 2001. 14. USACE 2000. Safety and Occupational Health Document Requirements for Hazardous, Toxic and Radioactive Waste (HTRW) and Ordnance and Explosive Waste (OEW) Activities, ER 385-1-92, U.S. Army Corps of Engineers, September 2000. 15. USACE 1999a. Corps of Engineers Guide Specifications for Construction, Section 01351, Safety, Health, and Emergency Response (HTRW/UST), U.S. Army Corps of Engineers, February 1999. 16. USACE 1999b. EM 200-1-4. Risk Assessment Handbook, Volume I: Human Health Evaluation. Final. 17. USACE 1998a. Chemical Data Quality Management for Hazardous, Toxic, Radioactive Waste Remedial Activities, ER 1110-1-263, U.S. Army Corps of Engineers, April 1998. 18. USACE 1998b. Technical Project Planning (TPP) Process, EM 200-1-2, U.S. Army Corps of Engineers, August 1998. 19. USACE 1998c. Monitoring Well Design, Installation, and Documentation at Hazardous, Toxic, and Radioactive Waste Sites, EM 1110-1-4000, U.S. Army Corps of Engineers, November 1998. 20. USACE 1997. Environmental Quality – Chemical Quality Assurance for HTRW Projects, EM- 200-1-6, U.S. Army Corps of Engineers, October 1997. 21. USACE 1996. Policies, Guidance, and Requirements for Geospatial Data and Systems, ER 1110- 1-8156, U.S. Army Corps of Engineers, August 1996. 22. MARSSIM 2000. Multi-Agency Radiation Survey and Site Investigation Manual, EPA 402-R-97- 016, U.S. Environmental Protection Agency, December 2000. 23. USEPA 2004. Multi-Agency Radiological Laboratory Analytical Protocols Manual, EPA 402-B-04-001C, U.S. Environmental Protection Agency, July 2004. 24. USEPA 1998. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part D), U.S. Environmental Protection Agency, 1998. 25. USEPA 1992a. OSWER Directive 9285.7-09A. Guidance for Data Usability in Risk Assessment (Part A). Final report. Office of Emergency and Remedial Response. 26. USEPA 1992b. Publication No. 9285.7-09B. PB92-963362. Guidance for Data Usability in Risk Assessment (Part B). 27. USEPA 1991a. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part B), U.S. Environmental Protection Agency, December 1991. 28. USEPA 1991b. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part C), U.S. Environmental Protection Agency, December 1991. 29. USEPA 1990. National Oil and Hazardous Substances Pollution Contingency Plan. Final Rule. Office of Solid Waste and Emergency Response. 55 FR 8660. 30. USEPA 1989. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part A), U.S. Environmental Protection Agency, December 1989. 31. USEPA 1988a. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, U.S. Environmental Protection Agency, October 1988. 32. USEPA 1988b. Superfund Exposure Assessment Manual, EPA/540/1-88/001, U.S.Environmental Protection


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Agency, Office of Remedial Response, April 1988.


A-1

APPENDIX A – GUTERL SPECIALTY STEEL CORPORATION FIGURES

NYS Route 93

Erie

Bar

ge C

anal

Oh

io S

tree

t

Guterl Landfill

2

314

37

24

4

8

9

81

47

5

35

38

6

48

Guterl Steel

Buffalo, NY

0 250 500 750 1,000125Feet NY State Index Map

Guterl Steel Site

PMP FigureWTF25-Feb-2005

Legend

Guterl Site Boundary

Guterl Excised Boundary

Guterl Landfill Boundary

Guterl Buildings

Figure 2. Guterl Steel Site Entities

Numbers Indicate SiteBuilding Designations


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APPENDIX B – KEY COMPONENTS OF AN ENGINEERING & DESIGN QUALITY CONTROL PLAN AND INDEPENDENT TECHNICAL REVIEW

The “design” quality control plan (QCP) is the A/E’s management plan for execution of the contract. The QCP describes the way in which the A/E will produce the deliverables and the steps that will be taken to control quality. The following items are key components of a design QCP, but should not be interpreted as excluding others. 1. Management Philosophy. Discuss the organization’s technical management philosophy relative to its commitment to quality. If the firm has undergone a peer review of its organization, practices and procedures, a statement should be made describing it. Give the date, the name of the person who conducted the peer review, and a brief description of resulting changes. 2. Management Approach. Define the specific management methodology to be followed during the performance of the work, including such aspects as: documentation management and control, communications, design coordination procedures, checking, and managerial continuity and flexibility. 3. Management Structure. Delineate the organizational composition of the A/E firm to clearly show the interrelationship of management and the design team components, including all consultants. Include an organization chart to identify by name the key design and review team members, and show their specific responsibilities related to the project. 4. Design Tools. Describe the design tools that will be used in execution of the contract, such as CADD, MCACES, computer application programs, etc. 5. Scheduling. Include a time-scale bar chart or Critical Path Method (CPM) design schedule showing the sequence of events involved in carrying out specific tasks within the specified period of service. Clearly show the design review and correction periods scheduled prior to submittals. 6. Cost Control. For cost reimbursement contracts, describe how project costs will be monitored and controlled. 7. Construction Cost Estimate Control. Discuss the organization’s internal controls to minimize construction cost limitation overruns, and ensure the accuracy and integrity of the construction cost estimate. Indicate how construction cost information will be handled and communicated to the Government. 8. Communications. Discuss the methods by which clear and accurate communications are to be achieved within the organization, and outside the organization. Indicate the names of all parties authorized to request modifications to the work, and specifically how these modifications will be coordinated and documented.


B-2

COMPLETION OF INDEPENDENT TECHNICAL REVIEW The Contractor has completed the (type of study, workplans, report or P&S) of (project name and location). Notice is hereby given that an independent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project, as defined in the Quality Control Plan. During the independent technical review, compliance with established policy principles and procedures, utilizing justified and valid assumptions, was verified. This included review of assumptions; methods, procedures, and material used in analyses; alternatives evaluated; the appropriateness of data used and level of data obtained; and reasonableness of the results, including whether the product meets the customer’s needs consistent with law and existing Corps policy. ___/Signature/___________ Date:_________

Design Team Leader ___/Signature/___________ Date:_________ Design Team Members

___/Signature/___________ Date:_________

Independent Technical Review Team Leader ___/Signature/___________ Date:_________ Independent Technical Review Team Members

CERTIFICATION OF INDEPENDENT TECHNICAL REVIEW Significant concerns and the explanation of the resolution are as follows: Item Technical Concerns Possible Impact Resolution

As noted above, all concerns resulting from independent technical review of the project have been considered.

(Signature) Date:________________ Principal w/ CONTRACTOR firm


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APPENDIX C – RISK ASSESSMENT GUIDANCE

C.1 Introduction A section of the Remedial Investigation report for the site shall be entitled "Risk Assessment". This section shall be further subdivided into "Baseline Human Health Evaluation" and "Environmental Risk Assessment" sections. The Contractor shall utilize all available site information in the preparation of the baseline risk assessment. The Technical Project Planning (TPP) Process (USACE 1998) shall be utilized for planning data collection required for preparation of the risk assessment. Use of the TPP process will insure that only necessary data is collected. The Contractor shall propose sample locations, depth, and number of samples required for preparation of the Human Health Risk Assessment (HHRA), and as noted below for the ERA. The sampling scheme shall be based on the conceptual site model (CSM) and the ecological conceptual site model (ECSM). Data Quality Objectives (DQOs) for all data collection activities shall be clearly documented in the work plan (WP)/Sampling and Analysis Plan (SAP), and contain the following information: sample location, sample depth (if appropriate), analytical method requirements, quantitation limit requirements, and identification of data use. The Contractor shall insure that quantitation limits for any dual-purpose samples (i.e., those required for both the HHRA and ERA) are low enough to evaluate site concentrations against levels protective of potentially exposed receptors. The intent of the Human Health Evaluation shall be to assess the current and reasonable future exposures with the associated risks from site contaminants in the event no action is taken to remove contaminants and/or prevent their migration. The purpose of the Environmental Risk Assessment shall be to determine whether actual or potential ecological risks are occurring or may occur at the site. All topics required by this section of the scope of services as described below shall be addressed in the risk assessment. Where the use of a specific topic is not applicable to this site, provide a negative declaration to establish that adequate consideration was given the topic, and give a brief justification for its omission. The Contractor shall consider inhalation, ingestion, and dermal contact exposure routes, as well as direct exposure to gamma emitting ionizing radiation, from the following potentially impacted environmental media at each site:

- Contaminated Soil - Contaminated Ground water - Contaminated Surface Water/Suspended Sediment - Sludge/Bottom Sediment - Existing Structures (for radiological constituents only) - Air

Any rationale for excluding an exposure route or media shall be included in the risk assessment. This rationale shall be detailed and thorough. C.2 Baseline Human Health Risk Assessment The intent of the Baseline HHRA shall be to assess the reasonable and foreseeable current and future exposures as well as associated risks from site contaminants in the event no action is taken to remove contaminants and/or prevent their migration. In the process of evaluating the specified exposure routes the Contractor shall consider all reasonable present and future use scenarios and evaluate risk for adults and children. The Human Health Evaluation shall follow the EPA's guidance, "Risk Assessment Guidance for Superfund (RAGS) Volume I ", (EPA 1989), and the USACE guidance, "EM 200-1-4: Risk Assessment Handbook Human Health Evaluation Vol 1: Human Health Evaluation. (USACE 1999)" Additionally, regulatory requirements for the risk assessment follow from the NCP, 300.430 which describes the role of risk assessment in site evaluation and remedy selection. This HHRA will have 2 separate components: a chemical risk assessment and a radionuclide risk assessment. Both of these risk assessments will follow the same basic steps, as outlined below for chemical risk assessment. Instructions specific to radiological risk assessment follow the section on chemical risk assessment. The Baseline Human Health Risk Assessment shall include the following components:


C-2

C.2.1 Human Health Chemical Risk Assessment C.2.1.1 Data Evaluation All data collected during the RI and evaluated under this section shall all have been reviewed / validated according to USACE protocol, and qualifiers applied as required. Data identified as required to support the risk assessment in the DQOs for the project, are evaluated in this section to determine if data collected is of sufficient quantity and quality. The contractor shall then present data for chemicals selected as the range of concentrations detected, frequency of detection, sample quantitation limits, and footnoted to identify applicable quality assurance/quality control (QA/QC) results and any limitations on data use. Consideration shall be given to USEPA Regional and State requirements for utilization of RAGS, Part D (USEPA 1998). The next part of data evaluation is determining the chemicals of concern to be evaluated in the risk assessment. All contaminants found significantly above background concentrations and positively identified in at least one sample shall be taken through the quantitative risk assessment process. Contaminants that are not statistically different than background shall not be considered chemicals of concern in the risk assessment. For the statistical evaluation of background data, please refer to appropriate environmental statistic textbooks and guidance, including but not limited to Procedural Guidance from the US Navy, 1998. In addition, because a screening level risk assessment has not been performed as part of a site inspection at the Guterl Specialty Steel Corporation site, a risk-based screening shall be performed. Constituents that pass this risk based screen shall not be evaluated further in the baseline risk assessment. In order to perform this screening level risk assessment, the conceptual site model (CSM) referred to in Section C.2.1.2. will be utilized. The Contractor will use the maximum detected sampling value for comparison to risk screening levels. Choice of health-based screening level (i.e., regional guidance from the USEPA) shall be justified. For those constituents found to be significantly above background and greater than the risk-based screening level, an EPC shall be calculated to use in the baseline risk assessment. As specified in EPA guidance, exposure point concentrations shall be expressed as the 95th percent upper confidence limit (UCL95) on the arithmetic mean. For simplification, the data shall be assumed to be lognormal, unless demonstrated to be normal, in calculating the UCL95. For COPCs that may become risk drivers, if deemed appropriate (i.e., simplified UCL95 is greater than the maximum detection), more realistic UCL95’s may be determined following the latest EPA guidance (USEPA 2002). Where actual exposure point concentrations cannot be determined, the Contractor shall utilize appropriate analytical models approved by EPA using site specific input whenever possible.

C.2.1.2 Exposure Assessment The exposure assessment is based on the conceptual site model that was developed during the technical project planning (TPP) process (USACE 1998). The conceptual site model shall be updated to reflect any changes that have been realized since the original model was developed. This shall be the basis for the exposure assessment. The source area, intermedia transport mechanisms, exposure routes, and receptor shall be evaluated in this section. Dermal contact, incidental ingestion, and inhalation exposure routes shall be evaluated for chemical constituents for each appropriate media. When determining the land use (i.e., receptors) to be evaluated, the contractor shall evaluate current and only reasonable future land uses for the site. EPA OSWER Directive # 9355.7-04 (USEPA 1995b) and DoD policy, "Responsibility for Additional Environmental Cleanup after Transfer of Real Property" may be used in justifying using reasonable instead of worst-case land uses. During the exposure assessment process, the Contractor shall utilize available monitoring data, detailed analysis of potential contaminant releases, modeled estimation of exposure point concentrations, quantitative evaluation of en-vironmental fate and transport of contaminants released (through the modeling effort), and identification of exposed populations.


C-3

The Contractor shall perform the exposure assessment according to protocol contained in RAGS, utilizing the algorithms provided, or justify changes deemed necessary. Exposure parameters shall be taken from the Exposure Factors Handbook (USEPA 1997a, b, c). All exposure parameters used shall be documented in the text, including justification for their use. At a minimum, the reasonable maximum exposure (RME) and central tendency exposure (CTE) will be calculated. One example of each calculation shall be provided, and the results of all calculations shall be presented in tabular form. The AE shall refer to the groundwater modeling requirements specified in this scope for estimation of these exposure point concentrations.

C.2.1.3 Toxicity Assessment The hierarchy for toxicity values in the risk assessment shall be as follows:

- Tier I: EPA Integrated Risk Information System (IRIS) - Tier II: Provisional Peer Reviewed Toxicity Values (PPRTVs) which are developed by the

Superfund Health Risk Technical Support Center - Tier III: Other sources, including - EPA Health Effects Assessment Summary Tables (HEAST) - USACHPPM for military specific chemicals - ATSDR Toxicological Profiles - EPA Water Quality Criteria Documents - EPA Health Advisories - National Center for Exposure Assessment (NCEA)

Subchronic toxicity values shall be used when appropriate. Preparation of toxicological profiles is required only for those constituents that are deemed constituents of concern. These toxicity profiles shall minimally include a summary of the study used to derive reference doses and slope factors, confidence, eight of evidence, and indicated effect. Otherwise, for all constituents of potential concern, a table shall be prepared, indicating the reference doses, reference concentrations, and slope factors, as well as source of the toxicity information.

C.2.1.4 Risk Characterization Risk characterization is required for the individual and composite carcinogenic risk and noncarcinogenic hazard of human exposure to site COPCs. Risk calculations shall be performed in accordance with RAGS protocol. The contractor shall clearly identify, in a tabular format, risks and hazard quotients (HQs) associated with each chemical for each route of exposure, and the summation of those risks and calculation of a hazard index (HI) for all pathways and all receptors. If an HI exceeds unity, the Contractor shall segregate the individual HQs and recalculate HIs by target organ, as specified in RAGS. The Contractor will be expected to discuss all results within the body of the text, including uncertainties and limiting factors associated with quantitation, and provide a summary of all results.

C.2.1.5 Uncertainty Analysis Various approaches can be applied to describe the uncertainties of the assessment, ranging from descriptive to quantitative. The method selected shall be consistent with the level of complexity of the assessment. The Contractor shall provide an evaluation of all uncertainties associated with sampling and analysis, fate and transport, exposure assessment, toxicity assessment, and risk characterization, indicating the strengths and limitations of the HHRA. The discussion shall indicate sources of uncertainties, an estimation of the degree of uncertainty associated with each source, and an estimate of the effect (over- or under-estimation of risk) of that uncertainty. The Contractor shall also provide a brief discussion of potential options that could be used to reduce the most significant uncertainties in the assessment. At a minimum, the following two points shall be addressed: whether or not the performance of a quantitative uncertainty analysis (e.g., probabilistic assessment) on one or more aspects of the


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study would improve the assessment; and the potential success and/or feasibility of investigating site-specific measures of bio-availability. C.2.2 Human Health Radiological Risk Assessment The following sections note the differences in performing a risk assessment for radionuclides, as compared with the human health chemical risk assessment requirements stated above. Otherwise, the risk assessments for chemical and radionuclides will be identical.

The HHRA for radiological contaminants will be conducted by utilizing the most recent release of the RESRAD computer code, currently Version 6.21 (ANL 2000). The risk assessment should include a discussion of the advantages of using RESRAD over standard RAGS methodology for evaluating risks due to exposure to radionuclides. C.2.2.1. Data evaluation. Radionuclide data should be evaluated and compared to background in the same manner as chemical data. In addition, an ARAR-based and/or risk based screening value to use in selecting radionuclide COPCs should be proposed by the contractor. C.2.2.2. Exposure assessment. The RESRAD codes also require inputs that describe the physical characteristics of the contaminated media. Certain site-specific data such as evapotranspiration coefficients and air exchange rates may be limited, although as many as possible site-specific parameter values should be used. The choice of parameters will be clearly tabulated in the risk assessment, and a reference shall be provided for each parameter. The risk assessment shall provide justification for excluding any exposure pathway(s) from evaluation in RESRAD. C.2.2.3. Radionuclide toxicity. The source and choice of slope factors used for radiological cancer potential should be indicated in the risk assessment with preference given to latest version of HEAST tables, available on the internet. The following differences in the determination of radiological cancer potential and chemical cancer potential should be noted: • Radionuclide cancer potency factors are based primarily on epidemiology and other studies of humans exposed

to radioactivity; chemical cancer potency factors are based mainly on studies of animals exposed to chemicals. • Radionuclide cancer slope factors reflect central tendency or mean probability of developing fatal cancer;

chemical cancer slope factors reflect upper 95% confidence level of developing cancer.

C.2.2.4. Characterization of radiological risk. The risk assessment shall express and quantify radiological risk in terms of dose, as well as in incremental lifetime carcinogenic risk. C.2.2.5. Uncertainty Analysis. As with chemical risk assessment, uncertainties are associated with each step of the radiological risk assessment process, and should be analyzed in the same manner. The risk assessment should also provide an explanation of how the sensitivity analysis and/or uncertainty analysis function(s) of the most recent version of the RESRAD computer code may be utilized in evaluating uncertainty for radiological risks. C.3 Screening Level Ecological Risk Assessment The purpose of the ecological risk assessment (ERA) shall be to conservatively evaluate the potential for adverse ecological effects due to site contamination. The screening-level ERA shall follow Steps 1 and 2 of the USEPA guidance, Ecological Risk Assessment Guidance for Superfund (ERAGS): Process for Designing and Conducting Ecological Risk Assessments, Interim Final (USEPA 1997d), including a refinement of these initial 2 steps as a final step. As sampling will be conducted in areas of known or suspected contamination, this evaluation will provide a conservative estimate of the potential for environmental risks. For this ERA, only substances designated as hazardous under CERCLA are to be considered stressors of concern.


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Since the information regarding effects of ionizing radiation on ecological receptors is not as well developed as for human receptors, risks due to exposures to chemical and radionuclide constituents will both be evaluated in the ecological risk assessment. C.3.1 Planning. Prior to initiating the screening-level problem formulation, the Contractor, customer, project manager, risk assessor, and other stakeholders, as directed by USACE, shall meet to establish clearly articulated management goals and to characterize the decisions to be made within the context of those management goals. The Contractor shall participate in a site visit to document habitat types, receptors, and general site characteristics. Site-visit findings shall be documented in the investigation report using the “Checklist for Ecological Assessment/Sampling” (USEPA 1997e). C.3.1.1. Screening-Level Problem Formulation. For the screening-level problem formulation, the Contractor shall develop a preliminary ecological conceptual site model (ECSM) for the site. Based on the site history and an initial site reconnaissance, the ESCM shall address the following five issues: • Characterization of the environmental setting and known or suspected contaminants. • Fate and transport mechanisms that might exist at the site. • The mechanisms of ecotoxicity associated with contaminants and likely categories of receptors that could be

affected. • Complete exposure pathways. • Selection of appropriate endpoints to screen for ecological risks.

C.3.2. Screening-Level Ecological Effects Evaluation. The next step in the ERA is the preliminary ecological effects evaluation and the establishment of contaminant exposure levels that represent conservative thresholds for adverse ecological effects. The conservative thresholds are called screening ecotoxicity values. The Contractor shall locate and utilize an adequate benchmark as the screening ecotoxicity value and submit for USACE approval. The Contractor shall evaluate the ECSM for appropriate exposure pathways, exposure factors, and the assessment endpoints, then select the benchmark values that most accurately reflect site conditions. The following is a partial list of sources for benchmark values: • State and Federal Ambient Water Quality Criteria (AWQC). • USEPA, National Oceanic and Atmospheric Administration (NOAA) and Ontario sediment criteria. • USEPA online databases (ECOTOX, AQUIRE, etc.). • Oak Ridge National Laboratory (ORNL) benchmarks. • U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM) (military unique compounds

(MUCs)). • USEPA Region or state benchmark/guidance values. C.3.4. Screening-Level Exposure Estimates. In this step, the Contractor shall estimate contaminant intake levels to calculate a dose in order to screen for potential ecological risks. For all complete exposure pathways, the Contractor shall use the maximum detected on-site concentration as the exposure point concentration. Exposure parameters utilized shall be the conservative assumptions listed below: • Area use factor of 100%; • 100% bioavailability; • Most sensitive life stage present; • Minimum body weight and maximum ingestion rate; • 100% of the diet consists of the most contaminated dietary component.

Additional exposure factors (i.e., fraction of time spent above/below ground) will need to be used for assessment of ecological receptor exposure to radionuclides. Choice of all intake and exposure factors for each receptor should be clearly documented and tabulated in the risk assessment, including a reference for source of exposure parameter.


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C.3.5. Screening-Level Risk Calculation. For the screening-level risk calculation, the HQ approach shall be used, comparing the dose (estimated contaminant intake) with the screening ecotoxicity value. The Contractor shall determine if the contaminants present in each area of concern have similar toxic mechanisms, requiring summing of the HQs to produce an HI. Justification for calculating an HI shall be clearly documented in the work plans. The result of completing this step will be development of an initial list of contaminants of potential ecological concern (COPECs). C.3.6. Uncertainty Analysis. Uncertainties are associated with each step of the ecological risk assessment process. The risk assessment will outline how uncertainties and assumptions will be documented, and their impact evaluated, on characterization of ecological risk. C.3.7. Refinement of the Screening-Level ERA. If potential ecological risks are indicated by the determination of COPECs, a refinement of the screening-level ERA will be accomplished. Since the screening-level ERA uses very conservative assumptions, the Contractor shall evaluate the initial, tentative list of COPECs and the corresponding HQs generated to determine if the use of a more reasonable EPC , as well as site-specific exposure parameters, would cause the HQs to drop to or near unity. C.3.7.1 Data evaluation The data will be evaluated and compared to background in a manner similar to what was done during the baseline human health risk assessment. Similarly, an appropriate EPC will be determined for each medium and area of concern. C.3.7.2 Estimate of ecological exposure to contaminant: For this evaluation, the Contractor shall reevaluate the following exposure parameters and recalculate HQs for those pathways indicating a risk: • Area use percentage (home range). • Bioavailability < 100% • Reasonable body weights and ingestion rates • Diet Composition < 100% from the most contaminated media • Food Concentration Refinement of all exposure parameters for each receptor shall be clearly tabulated in the risk assessment, and shall include a reference for source of exposure parameter. Based on this evaluation , the Contractor shall propose which COPECs identified in the initial screening evaluation are not expected to pose an unacceptable risk to ecological receptors. A final list of COPECs will be generated following this step. C.3.8. Scientific/Management Decision Point (SMDP). The Contractor shall write a summary of the screening-level ERA, including its refinement as outlined in Section C.3.7. This summary will include a tabulation of the range of chemical concentrations detected, the number of chemicals exceeding their benchmarks, the degree of the exceedance of the benchmark(s), and finally an evaluation of the appropriateness of the benchmarks themselves. A description of how the weight of evidence will also be evaluated to aid in the characterization and interpretation of risk, and selection of ecological COPECs, should be provided. The weight of evidence evaluation shall include consideration of FUSRAP-related non-chemical stressors that may be potentially impacting important ecological receptors, for example:

- Elevated total dissolved solids (TDS); - Elevated or decreased pH concentrations in soils/surface waters; - Low dissolved oxygen levels in surface waters; - Cementation of surface water sediments; - Physical habitat modification; and - Elevated temperatures in surface water


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The Contractor shall insure that the information provided assists the risk manager in making one of the following decisions: • There is adequate information to conclude that ecological risks are negligible and therefore no need for

remediation on the basis of ecological risk; • The information is not adequate to make a decision at this point, and the ecological risk assessment process will

continue in a baseline ERA; • The information indicates a potential for adverse ecological effects, and a more thorough assessment is

warranted. If the indication is that further assessment is warranted, the Contractor shall clearly identify those contaminants that need to be carried forward, those pathways found to be complete and significant, and the potentially affected receptors. This information will help focus the Problem Formulation for the baseline ERA. A baseline ecological risk assessment may be prepared, depending on the outcome of the screening level ecological risk assessment, as outlined in section C.3. If a baseline ecological risk assessment is warranted, then the Contractor will prepare work plans for the performance of a baseline ecological risk assessment, according to the guidance presented in section C.4. C.4. Baseline Ecological Risk Assessment.

The Contractor shall conduct a baseline ERA for the site. The purpose of the baseline ERA shall be to determine whether actual or potential ecological risks are occurring or may occur due to contamination at the site. The ERA shall be based on the management goals, ECSM, the list of contaminants of potential ecological concern (COPECs), and the scientific/management decision point (SMDP) established at the end of the screening level ERA, and shall be conducted in accordance with Steps 3 through 8 of Ecological Risk Assessment Guidance for Superfund (ERAGS): Process for Designing and Conducting Ecological Risk Assessments (USEPA 1997d). Additionally, the following guidance documents shall be utilized as appropriate: Guidelines for Ecological Risk Assessment (USEPA 1998a), Tri-Service Procedural Guidelines for Ecological Risk Assessments, (Wentsel, et al. 1996), and guidance from the applicable USEPA region and state. C.4.1. Step 3: Problem Formulation. Problem formulation is a process for generating and evaluating hypotheses about why ecological effects have occurred, or may occur, from human activities. It establishes the goals, breadth, and focus of the baseline ERA (USEPA 1997d). The Contractor shall utilize the TPP Process (USACE 1998) during the problem formulation phase to insure that data collected is of adequate quality and quantity for its intended purpose. Problem formulation for the baseline ERA includes the following activities:

• Refinement of preliminary COPECs; • Refinement of the ECSM. • Selection of assessment endpoints; • Risk Questions. C.4.1.1. Refinement of Preliminary COPECs. Note that this should have been completed as part of the screening level ecological risk assessment, per Section C.3.7. C.4.1.2. Refinement of the ECSM. The Contractor shall review and revise the preliminary ECSM developed during the screening level ERA to identify the source area(s), fate and transport mechanisms of the COPECs, receptors exposed to site contaminants, and exposure routes expected to be complete. The detail required for the ECSM will be determined by the COPECs present, an evaluation of site use (both current and reasonable future), and the quality and quantity of available habitat (both on-site and adjacent off-site). The Contractor shall insure that adequate information on the COPECs is available to determine potential risks. Mechanisms of ecotoxicity available from the screening level ERA shall be reevaluated to insure their relevance to the exposure pathways identified as complete. If necessary, a literature search shall be conducted to evaluate toxicity information on these chemicals relative to any potential receptors


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identified, and to guide the sampling, analysis, and quantitation limit requirements for the data collection effort. C.4.1.3. Selection of Assessment Endpoints. Guided by the management goals and the ECSM, the Contractor shall propose the assessment endpoints to be evaluated in the baseline ERA. By definition, assessment endpoints are explicit expressions of the actual environmental value to be protected. In selecting assessment endpoints, special consideration shall be given to ecological relevance, regulatory policy goals and societal values, and susceptibility to the COPECs. C.4.1.4. Risk Questions. Ecological risk questions for the baseline ERA are basically questions about the relationships among assessment endpoints and their predicted responses when exposed to contaminants (USEPA 1997d). The questions or testable hypotheses will provide the basis for developing the study design and for evaluating the results of the site investigation in the analysis phase. The most basic question to be answered by the ERA is whether COPECs are causing or have the potential to cause adverse effects on the assessment endpoint(s). Based on the ECSM, the Contractor shall propose the risk questions to be answered by the baseline ERA. C.4.1.5. Step 3 SMDP. At this SMDP, the Contractor shall present the proposal for the final list of COPECs, assessment endpoints, and the risk questions. In order to develop the site study and establish the level of effort necessary to evaluate potential site risks, agreement must be reached on the following four components of the ECSM: the list of COPECs, the assessment endpoints, exposure pathways assumed to be complete, and the risk questions (or testable hypotheses) that will be answered by the baseline ERA. This will facilitate identification of the measurement endpoints and current data gaps to be evaluated by the field effort. C.4.2. Step 4: Study Design and the DQO Process. This step in the ERA process will establish field and laboratory procedures for the investigation and will document DQOs for all data to be collected. C.4.2.1. Establishing Measurement Endpoints. The Contractor shall propose measurement endpoints, based on the assessment endpoints agreed to at the Step 3 SMDP. Measurement endpoints are, by definition, measurable responses to a stressor that are related to the valued characteristics chosen as the assessment endpoints. Measurement endpoints can be measures of exposure (i.e., media concentration of COPECs) or measures of effect. The relationship between the measurement endpoint and the assessment endpoint must be clearly described, must be based on scientific evidence, and should allow evaluation of potential harm at the population, community, or ecosystem level of organization. The measurement endpoints shall be selected to determine the answer(s) to the risk questions (testable hypotheses) agreed to at the SMDP. In general, there are four lines of evidence that can be used to answer these questions (USEPA 1997d): • Comparing estimated or measured exposure levels with reference toxicity values (RTVs) derived from the

literature (i.e., the HQ method); • Comparing site tissue bioassays with tissue bioassays from a reference area; • Comparing in situ toxicity test results with toxicity test results from a reference area; and • Comparing observed effects on site receptors with those observed in a reference area. The Contractor shall propose the lines of evidence necessary to evaluate all complete pathways from COPECs to receptors, to be presented at the Step 4 SMDP for agreement. Additionally, the Contractor shall propose how the data and the various lines of evidence will be interpreted, and how inferences will be drawn from the measurement to the assessment endpoints. Agreement prior to the field effort will insure that the baseline ERA will provide the information appropriate for making risk management decisions. C.4.2.2. Determination of Data Needs. Based on the information above, the Contractor shall propose the data required for evaluation of potential ecological threats. All data available from previous site investigations shall be evaluated to determine appropriate sampling locations in an attempt to establish gradients of contamination and corresponding ecological impacts wherever possible. Additionally, the Contractor shall evaluate the existing data for usability to determine what data gaps exist,


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and the sampling required to fill those data gaps. Finally, DQOs shall be assigned for all required samples, establishing how the lines of evidence will be evaluated, the sampling and analytical requirements, and the analytical quantitation limits required. C.4.2.3. Step 4 SMDP. The SMDP at the end of Step 4 will obtain agreement on the following three items: the measurement endpoints, site investigation methods for both field and laboratory, and data reduction/interpretation techniques. The Contractor shall document the above and the applicable DQOs in the work plan (including the DQOs for HHRA samples), insuring that all DQOs are complete and clearly defined, that sampling for the ERA and HHRA are coordinated (i.e., not duplicated), and that the analytical quantitation limits are adequate for their intended purpose. C.4.3. Step 5: Field Verification of Sampling Design. Before the work plan are finalized, verification that the proposed field effort is implementable and appropriate is required. If it has not already been done, the Contractor shall verify the sampling design, the risk questions/testable hypotheses, complete exposure pathways, and the measurement endpoints for appropriateness and field implementability. The Contractor shall document any aspect of the field effort that might be problematic, propose a solution, and obtain concurrence from the USACE. C.4.4. Step 6: Site Investigation and Analysis Phase. This step of the ERA implements the field effort(s) delineated in the work plan and analyzes the resultant data, characterizing actual exposures and ecological effects, leading to the risk characterization in Step 7. C.4.4.1. Site Investigation. The site investigation will implement the work plan developed in Step 4 and verified in Step 5 (if required). If the Contractor determines that deviations from the work plan are required due to changes in field conditions or concentrations/locations of COPECs, they shall be proposed to the USACE for consideration at an SMDP. Documentation shall include the reason for the change and how the change will effect the baseline ERA. C.4.4.2. Step 6 SMDP. This SMDP is required only if alterations to the work plan are necessary, as noted above. Agreement shall be reached on the appropriateness of the changes as well as how the information will be utilized in the baseline ERA. C.4.4.3. Analysis of Ecological Exposures and Effects. The analysis phase of the ERA consists of the technical evaluation of data on existing and potential exposures and ecological effects at the site (USEPA 1997d). The procedures for characterizing exposures and ecological effects were documented in the work plan (SMDP at the end of Step 4). C.4.4.3.1. Characterizing Exposures. The exposure analysis combines the spatial and temporal distributions of the selected endpoints with those of the COPECs to evaluate exposures. The result of the exposure analysis is an exposure profile that quantifies the magnitude and spatial and temporal patterns of exposure as they relate to the assessment endpoints and risk questions developed during problem formulation (USEPA 1997d). C.4.4.3.2. Characterizing Ecological Effects. The ecological effects characterization shall include a summary of the types of adverse effects on biota associated with exposure to COPECs and an evaluation of the relationship between magnitude of exposures and adverse effects. C.4.4.3.3. Exposure-Response Analysis. The Contractor shall describe the relationship between the magnitude, frequency, or duration of exposures to the COPECs and the magnitude of any responses. The relationship between exposure and response shall be described to the extent possible and the linkage between the measurement and assessment endpoints shall be clearly explained. The Contractor shall provide a discussion of the confidence in these relationships, either qualitatively or quantitatively, as allowed by the data. C.4.4.3.4. Evidence of Causality.


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It is very important to evaluate the strength of the causal association between COPECs and effects on the selected endpoints. Demonstrating a correlation between a contaminant gradient and ecological impacts is a key component of establishing causality, but is not required. The Contractor shall utilize the procedures/methods outlined in the Guidelines (USEPA 1998) to assist in describing the cause/effect relationships. C.4.5. Step 7: Risk Characterization. Per ERAGS, “unless the site investigation during Step 6 discovers unexpected information, the risk assessment should move smoothly through the risk characterization phase, because the data interpretation procedures were specified in the work plan.” The Risk Characterization includes two major steps: risk estimation and risk description. C.4.5.1. Risk Estimation. The risk estimation shall consist of integration of the exposure profiles and the exposure-effects information gathered during the field effort, and assessing the uncertainties associated with the process. All assumptions, defaults, uncertainties, use of professional judgement, and any other inputs to the risk estimate shall be clearly identified and easy to find. C.4.5.2. Risk Description. The risk description shall consist of a summary of the results of the risk estimation and an assessment of confidence in the risk estimates through a discussion of the weight of evidence. An analysis and discussion of all identifiable uncertainties shall also be included. C.4.6. Step 8: Risk Management. At the end of the baseline ERA, the Contractor shall provide information to the risk manager(s) to assist in decision-making. In addition to summarizing the baseline ERA, the Contractor shall adequately address the six principals and the four questions from USEPA 1998. C.5 Results.

The risk assessment shall evaluate and interpret the results and uncertainties of both the HHRA and the ERA to determine the severity of any risks and/or hazards to human health and the environment. Criteria for recommending no further action for an area of concern will be established. This final evaluation should also address the relationships between human health chemical and radiological risk assessments, as well as between the overall HHRA and the ERA.

C.6 Development of Preliminary Remediation Goals. The conclusion of the RA will be to present preliminary remediation goals, which will assist in addressing remedial action objectives for the Guterl Specialty Steel Corporation site. C.6.1 Risk Based Concentrations (RBCs). The risk assessment will modify the previously utilized preliminary remediation goals to generate risk-based concentrations that are consistent with the methodology used to perform the risk assessment. Risk based concentrations will be developed for both chemical and radionuclide COCs. C.6.2. Identification and evaluation of applicable, relevant and appropriate requirements (ARARs) The risk assessment shall identify potential ARARs for all COCs at the Guterl Specialty Steel Corporation site as per Task 3. For radionuclides, this presentation of ARARs will include a calculation of action levels for all relevant media for dose-based, as well as risk-based, and concentration-based endpoints. C.7 References The following documents are provided for reference. Additional documentation may be used as required. Argonne National Laboratory (ANL) 2000 (December). Probabilistic Modules for the RESRAD and RESRAD-


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BUILD Computer Codes NUREG/CR-6692, ANL/EAD/TM-91. http://web.ead.anl.gov/resrad/ National Oil and Hazardous Substance Pollution Contingency Plan; Final Rule, Federal Register, Vol. 55, No. 46, Thursday, Mar. 8, 1990. Public Law No. 99-499, Superfund Amendments and Reauthorization Act (SARA) 42 USC 9601 et seq., Enacted Oct. 17, 1986. USA 1997. Environmental Protection and Enhancement, AR 200-1, U.S. Army, February 1997. USACE 1998. Technical Project Planning (TPP) Process, EM 200-1-2, U.S. Army Corps of Engineers, August 1998. USACE 1999. Risk Assessment Handbook - Volume I: Human Health Evaluation, EM 200-1-4, U.S. Army Corps of Engineers, January 1999. USEPA 1986. Guidelines for Ground Water Classification under the EPA Ground-Water Protection Strategy, Final Draft, U.S. Environmental Protection Agency, Office of Ground-Water Protection, Office of Water,1986. USEPA 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, U.S. Environmental Protection Agency, October 1988. USEPA 1989. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part A), U.S. Environmental Protection Agency, December 1989. USEPA 1991a. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part B), U.S. Environmental Protection Agency, December 1991. USEPA 1991b. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part C), U.S. Environmental Protection Agency, December 1991. USEPA 1992. Guidance for Data Useability in Risk Assessment (Part A), Final, U.S. Environmental Protection Agency, April 1992. USEPA 1993a. Wildlife Exposure Factors Handbook, Volume I, EPA/600/R-93/187a, U.S. Environmental Protection Agency, December 1993. USEPA 1993b. Wildlife Exposure Factors Handbook, Volume II, EPA/600/R-93/187b, U.S. Environmental Protection Agency, December 1993. USEPA 1995b. Land Use in the CERCLA Remedy Selection Process, OSWER Directive No. 9355.7-04, U.S. Environmental Protection Agency, 1995. USEPA 1996. Proposed Guidelines for Carcinogen Risk Assessment, EPA/600/P-92/003C, U.S. Environmental Protection Agency, April 1996. USEPA 1997a. Exposure Factors Handbook Volume I: General Factors, U.S. Environmental Protection Agency, August 1997. USEPA 1997b. Exposure Factors Handbook Volume II: Food Ingestion Factors, U.S. Environmental Protection Agency, August 1997. USEPA 1997c. Exposure Factors Handbook Volume III: Activity Factors, U.S. Environmental Protection Agency, August 1997.


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USEPA 1997d. Ecological Risk Assessment Guidance for Superfund (ERAGS): Process for Designing and Conducting Ecological Risk Assessments. Interim Final. EPA/540/R-97/006. OSWER Directive # 9285.7-75. USEPA 1997e. “Checklist for Ecological Assessment/Sampling”. USEPA 1998. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part D), U.S. Environmental Protection Agency, 1998. USEPA 1998a. Guidelines for Ecological Risk Assessment, Final.EPA/630/R-95/002F. USEPA 2002. Calculating Upper Confidence Limits for Exposure Point Concentrations at Hazardous Waste Sites, OSWER 9285.6-10, December 2002. USEPA 2004. Risk Assessment Guidance for Superfund. Volume I: Human Health Evaluation Manual (Part E: Supplemental Guidance for Dermal Risk Assessment) Final, U.S. Environmental Protection Agency, 2004. US Navy 1998. Procedural Guidance for Statistically Analyzing Environmental Background Data. http://erb.nfesc.navy.mil/erb_a/restoration/analysis/procguid.pdf Wentsel, R.S., et al., 1996. ADA297968, Tri-Service Procedural Guidelines for Ecological Risk Assessments. U.S. Army ERDEC, Aberdeen Proving Ground, MD, May 1996.


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APPENDIX D - CONTRACTOR SUBMITTAL PROCEDURES

CLAUSE 1 - SUBMITTAL REQUIREMENTS Contractor shall furnish ten (10) copies of all work plan submittals and three (3) copies of all other submittals (such as drawings, data, catalog cuts, and samples) in accordance with the technical specifications and Contractor Submittal Requirements Summary (CSRS) and this clause. All submittals prepared for this Contract shall have a cover sheet indicating the following information in or near the title block:

• Project Name and Phase • USACE Contract Number • Date • Submittal Title and Number

With each separate submittal, a copy of the attached Contractor Submittal Requirements Summary (CSRS) form shall be included and “Submittal Title” of item(s) being submitted shall be circled or highlighted. Also, the Contractor shall include a letter of transmittal detailing the following:

• Contract number • A description of contents per the CSRS Form • Number and type of items (CD-ROMs, etc.) • Note if the submittal is a resubmittal

Whenever possible, related items shall be submitted together to permit simultaneous review. When such submittal is not possible, submittals shall be in an appropriate sequence to ensure that necessary information is available for reviewing such item as it is received. USACE reserves the right to request any submittal not included on the CSRS form or any new submittal requirement. All work plan submittals shall be submitted in both hardcopy and in electronic Adobe PDF format and Microsoft formats (i.e., Word, Excel, Access) as applicable, or as otherwise specified by USACE. CLAUSE 2 - SUBMITTAL RECIPIENTS Submittals of all documents as identified on the CSRS shall be made directly to the individuals noted below. U.S. Army Corps of Engineers, Buffalo District Attn: Raymond L. Pilon, Project Manager 1776 Niagara Street Buffalo, New York 14207-3199 CLAUSE 3 - TYPES OF SUBMITTALS Documents Each submittal shall be an unfolded, direct reading, first-generated copy the same size as the original. The minimum size of submittals shall be 8-1/4 inches by 11 inches. Each submittal shall be of a sufficient quality to produce clearly legible/readable third-generation copies using either diazo or electrostatic (Xerox-type) processes and clearly legible/readable microfilm and copies from the microfilm. Submittals 11 inches by 17 inches or smaller shall be black-on-white, or color copies; bond paper is acceptable.


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Submittals larger than 11 inches by 17 inches shall be dark line on translucent or transparent material suitable for diazo reproduction and shall be rolled and inserted into mailing tubes. Drawing Requirements All drawings and diagrams shall be prepared in accordance with the latest applicable American National Standard Institute Drafting Manual, ANSI-Y14. Each drawing submitted shall have a separate drawing number. When a drawing is revised, revision numbers must be clearly legible and easily distinguishable from the drawing number and should be as close as possible to the title block. A short description of the nature of the revision must be included, and revised areas on the drawing shall be circled and identified with the revision number. “Typical,” “standard,” or “off-the-shelf” drawings will be acceptable only if they have all non-applicable sections either removed or noted on each drawing. Magnetic Storage Media 1. Data submitted on magnetic storage media shall be accompanied by a hardcopy list of the media contents and a letter of transmittal.

2. Electronic Digital Media shall consist of the following:

• Compact disc read-only memory (CD-ROM) with International Standards Organization (ISO)-9660 format • CD-R and/or CD-RW

Samples Submittal of sample materials, such as bentonite, geomembrane, or geotextile swatches, etc., shall be of the size and type as noted in the technical specifications. CLAUSE 4 - SUBMITTAL STATUS AND RETURN BY USACE A copy of documents submitted requiring review will be returned by USACE with status (code) marked in accordance with ENG FORM 4025. Approval and/or acceptance of submittals shall not be construed as a complete check, but will indicate only that the general method of construction, materials, detailing and other information are satisfactory. Approval and/or acceptance will not relieve the Contractor of the responsibility for any error that may exist, as the Contractor under the CQC requirements of this contract is responsible for the satisfactory performance of all work. Permission to proceed does not constitute acceptance or approval of design details, calculations, analyses, test methods, or materials developed or selected by the Contractor/supplier, and does not relieve the Contractor/supplier from full compliance with contractual obligations or release any “holds” placed on the contract. Work shall not proceed until submittals requiring prior review (see CSRS) have been reviewed and approved and/or accepted by USACE. The Contractor shall provide a disposition of each comment and incorporate changes as required by comments on submittals and resubmit corrected submittals for review. Submittals that have been given a code notation by USACE shall not be changed without notification to USACE. If changes are required, affected submittals shall be resubmitted to USACE for review. A minimum of thirty (30) calendar days of review time shall be allocated for USACE review of all submittals. Extended review time may be needed for certain submittals depending upon the distribution and review requirements.


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CONTRACTOR SUBMITTAL REQUIREMENTS SUMMARY

SUBMITTAL SCHEDULE SUBMITTAL TYPE REQUIRED CLASSIFICATION s Prior to Shipment O Original FIO For Information Only B Prior to Balance of Payment P Print/Photocopy GA Government Approval A Per S/C Schedule T Transparency M Prior to Mobilization M Microfilm W Prior to Commencing Work PH Photograph Y Prior to Progress Payment E Electronic Format For Each Specific Task S Sample Z As Required

NOTICES 1. To each item submitted, attach a copy of this form and circle the title of the item being submitted. 2. Failure to submit required submittals as delineated on this form may result in withholding of payment in accordance with provisions of the contract. 3. The Contract Administrator is responsible for distributing submittals to the requesting Department (e.g., Construction). The Department is responsible for further distributions (e.g., Site Superintendent).

Item No./ Submittal Titles

Scope of Work (SOW) Paragraph Classification ITR Required Submittal Codes

(No.) and Type

1 Quality Control Plan 4.2 GA No E, O

2 DQO Meeting Minutes 4.2 GA No E, 0

3 Data Summary and Data Gap Analysis Report 4.3 GA Yes E, O

Clause 5 - Written Monthly Reports, Payment Requests and Accruals Written Monthly Reports The A-E shall submit, no later than the 5th of the following month, a monthly letter (progress report) on the status of the execution of the tasks under the Delivery Order Scope of Work. This report shall include information on tasks that have been completed since the last report, tasks in progress, and tasks still to be executed. Any safety infractions, accidents, violations of regulations, delays, problems, or expected cost overruns shall be identified including recommendations/solutions. Work which is outside of the SOW but which is critical to project completion shall be explained. The A-E shall include an updated schedule as described in the E&D QCP and records of correspondence/confirmation notices. The A-E shall make a record of each telephone conversation, written correspondence, and confirmation notice regarding information related to the performance of tasks under this SOW. A summary of these records shall be submitted monthly to the Buffalo District Project Manager with the monthly progress report, copy of the monthly payment request for services performed, and an accrual through the end of the month as described in paragraph 8.3.

Payment Requests

Payment requests or invoices shall contain the following information as a minimum: Project Title, Contract Number, Delivery Order Number, Invoice Number (or indicate FINAL PAYMENT), date of invoice, dates covered for each invoice, total contract amount with all modifications and amounts listed individually, amounts retained, amount remaining in the contract to be completed, certification of the invoice by a responsible individual of the firm (i.e., A-E principal, program/project manager), and any other pertinent


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information that will assist in review and processing. The invoice must be accompanied by supporting documentation for each task worked on during the billing period. The USACE Contracting Officer cannot sign off on any invoice for which supporting documentation is not provided. Mail payments requests promptly to:

U.S. Army Engineer District, Buffalo ATTN: CELRB-TD-DE (Mr. Stephen J. Golyski, P.E., A-E Program Manager) Contract No. DACW49-XX-X-XXXX, Delivery Order No. 00X 1776 Niagara Street Buffalo, NY 14207-3199

Accruals

Each month, accrual information shall be presented in the following sample format:

Current Earnings & Cost Projections Project Name

Project Phase (i.e., SI, RI, FS, PP/ROD, etc.) For Month Ending May 2000

Last Month’s Earnings & Cost Projections Project Name

Project Phase (i.e., SI, RI, FS, PP/ROD, etc.) For Month Ending April 2000

Month Actual Billings Projections

Cumulative = Actuals +

Projections Month Actual

Billings Projections Cumulative =

Actuals + Projections

Oct-99 $0 $0 Oct-99 $0 $0 Nov-99 $0 $0 Nov-99 $0 $0 Dec-99 $0 $0 Dec-99 $0 $0 Jan-00 $0 $0 Jan-00 $0 $0 Feb-00 $53,222 $53,222 Feb-00 $53,222 $53,222 Mar-00 $120,031 $173,253 Mar-00 $120,031 $173,253 Apr-00 $80,349 $253,602 Apr-00 $60,349 $20,000 $253,602 May-00 $95,000 $35,000 $383,602 May-00 $130,000 $383,602 Jun-00 $200,000 $583,602 Jun-00 $200,000 $583,602 Jul-00 $50,000 $633,602 Jul-00 $50,000 $633,602

Aug-00 $633,602 Aug-00 $633,602 Sep-00 $633,602 Sep-00 $633,602 Total: $348,602 $285,000 $633,602 Total: $233,602 $400,000 $633,602

The table shall include actual billings, accruals, and projections of costs for each month remaining in the fiscal year (i.e., 01 October 2004 - 30 September 2005). Updated earnings and cost projections for the current month shall be presented along side accrual information from the previous month.

Actual payments made may not include all of the earned value of work performed in a given month. Accruals are used to provide projections of the incremental costs not yet paid for, but earned. Consequently, there may be instances where both actual payments and an accrual must be entered for the current month. Accruals may also be entered for previous months where no billings/payments have been made but work has been accomplished.


Appendix C Budget and Summary of Project Costs

Labor Hours 1,018Labor Cost (includes OH) 93,611$

Reimburseables/ODCs 5,990$ Subtotal 99,601$

Profit @ 10.0% 9,960$ Total 109,561$

Task 1 Site Inspection and Data ReviewProfessional Labor $18,452Reimburseables $1,971

Subtotal $20,423Profit @ 10.0% $2,042

Total $22,465

Task 2Engineering & Design Quality Control Plan and Independent Technical ReviewProfessional Labor $13,758Reimburseables $136

Subtotal $13,894Profit @ 10.0% $1,389

Total $15,283

Task 3Identification of Potential ARARs and Data Quality ObjectivesProfessional Labor $27,175Reimburseables $782

Subtotal $27,957Profit @ 10.0% $2,796

Total $30,753

Task 4

Attend TPP Meeting, Prepare TPP Notes, Review Data Assessment Report, Prepare Data Gap Analysis and Summary ReportsProfessional Labor $34,226Reimburseables $3,101

Subtotal $37,327Profit @ 10.0% $3,733

Total $41,060

Basis of Estimate SummaryUS Army Corps of Engineers, Buffalo District

Guterl Specialty Steel Corporation Site RI/FS

Earth Tech, Inc.

ID/IQ Contract No. WP912P4-05-D-0001, Delivery Order No. 0001Negotiated Proposal

Page 1 of 17 29 April 2005

Earth Tech, Inc.Guterl Specialty Steel Corporation Site RI/FS

W912P4-05-D-0001, D.O. 0001Negotiated Cost Proposal - Labor Estimate

Item # Labor Disciplines Loaded Units number Cost number Cost number Cost number Cost Sum of tasks1 Principal / Program Manager $156.00 hour 2 $312.01 4 $624.01 4 $624.01 2 $312.01 $1,872.042 Senior Technical Reviewer $134.28 hour $0.00 2 $268.57 8 $1,074.28 24 $3,222.84 $4,565.683 Quality Assurance Officer $120.34 hour $0.00 4 $481.38 16 $1,925.50 16 $1,925.50 $4,332.384 Project Manager $108.03 hour 16 $1,728.43 16 $1,728.43 24 $2,592.65 24 $2,592.65 $8,642.165 Senior Engineer $116.82 hour $0.00 8 $934.59 $0.00 $0.00 $934.596 Mid-Level Engineer $84.20 hour 30 $2,526.01 48 $4,041.62 20 $1,684.01 $0.00 $8,251.647 Junior Engineer $60.24 hour $0.00 8 $481.94 $0.00 $0.00 $481.948 Technician $43.36 hour $0.00 $0.00 $0.00 $0.00 $0.009 Architect $96.22 hour $0.00 $0.00 $0.00 $0.00 $0.00

10 Specification Writer $45.32 hour $0.00 $0.00 $0.00 $0.00 $0.0011 Senior Scientist $116.82 hour 64 $7,476.69 12 $1,401.88 48 $5,607.52 60 $7,009.40 $21,495.4912 Mid-Level Scientist $84.20 hour $0.00 $0.00 40 $3,368.01 60 $5,052.02 $8,420.0413 Junior Scientist $60.24 hour 24 $1,445.82 $0.00 12 $722.91 34 $2,048.25 $4,216.9814 Chemist $60.24 hour $0.00 $0.00 $0.00 $0.00 $0.0015 Data Validator $60.24 hour $0.00 $0.00 $0.00 $0.00 $0.0016 Field Chemist $53.09 hour $0.00 $0.00 $0.00 $0.00 $0.0017 Senior Geologist $96.22 hour 24 $2,309.39 16 $1,539.59 20 $1,924.49 24 $2,309.39 $8,082.8718 Geologist $64.65 hour $0.00 $0.00 $0.00 $0.00 $0.0019 Certified Industrial Hygienist $123.92 hour $0.00 $0.00 $0.00 $0.00 $0.0020 Industrial Hygienist $96.22 hour $0.00 $0.00 $0.00 $0.00 $0.0021 Certified Health Physicist $83.95 hour 24 $2,014.76 8 $671.59 40 $3,357.93 40 $3,357.93 $9,402.2022 Health Physicist $72.08 hour $0.00 $0.00 $0.00 $0.00 $0.0023 Radiation Control Technician $59.95 hour $0.00 $0.00 $0.00 $0.00 $0.0024 Risk Assessor $96.46 hour $0.00 $0.00 $0.00 $0.00 $0.0025 Ecological Risk Specialist $96.22 hour $0.00 $0.00 24 $2,309.39 36 $3,464.09 $5,773.4826 Environmental Compliance Specialist $83.95 hour $0.00 $0.00 $0.00 $0.00 $0.0027 Community Relations Specialist $92.84 hour $0.00 $0.00 $0.00 $0.00 $0.0028 Publicist $59.95 hour $0.00 $0.00 $0.00 $0.00 $0.0029 Contract Administrator $91.21 hour 2 $182.42 4 $364.84 4 $364.84 4 $364.84 $1,276.9630 Project Controls Analyst $55.14 hour 2 $110.28 4 $220.55 4 $220.55 6 $330.83 $882.2131 Cost Estimator $65.11 hour $0.00 $0.00 $0.00 $0.00 $0.0032 CADD/ Graphics $59.87 hour $0.00 8 $478.95 6 $359.22 20 $1,197.39 $2,035.5633 GIS Technician $59.95 hour $0.00 $0.00 $0.00 $0.00 $0.0034 GIS Structure Developer $89.63 hour $0.00 $0.00 $0.00 $0.00 $0.0035 GIS Data Inputer $43.10 hour $0.00 $0.00 $0.00 $0.00 $0.0036 Technical Writer $84.02 hour $0.00 $0.00 $0.00 $0.00 $0.0037 Secretarial/Clerical $43.31 hour 8 $346.45 12 $519.67 24 $1,039.34 24 $1,039.34 $2,944.7838 Licensed Land Surveyor (1) $104.20 hour $0.00 $0.00 $0.00 $0.00 $0.0039 Survey Crew (3 people) $48.16 hour $0.00 $0.00 $0.00 $0.00 $0.0040 Drill Rig Equipment Operator (2) $96.22 hour $0.00 $0.00 $0.00 $0.00 $0.0041 Laborer (2) $48.16 hour $0.00 $0.00 $0.00 $0.00 $0.0042 Construction Inspector $59.85 hour $0.00 $0.00 $0.00 $0.00 $0.00

Sum of each task 196 $18,452 154 $13,758 294 $27,175 374 $34,226 $93,611Total Sum

Task 1 Task 2 Task 3 Task 4Inpection E & D QCP ARAR ID & DQO's Data Gap Analysis

Page 2 of 17 06 May 2005


W912P4-05-D-0001, D.O. 0001Negotiated Cost Proposal - ODC/Reimburseable Estimate

Base YearID Item Name Units number Cost number Cost number Cost number Cost Sum of tasks43 Blueline or blackline copies, sq ft sq ft $0.90 $0.00 $0.00 $0.00 $0.00 $0.0044 Architectural rendering per sq ft sq ft $1.00 $0.00 $0.00 $0.00 $0.00 $0.0045 Mylar plots, sq ft sq ft $1.50 $0.00 $0.00 $0.00 $0.00 $0.0046 1" Binder ea $3.00 24 $72.00 $0.00 48 $144.00 48 $144.00 $360.0047 Binder >1" ea $4.00 24 $96.00 24 $96.00 $0.00 $0.00 $192.0048 3-day delivery, 50-lb empty cooler (shipping) ea $40.00 $0.00 $0.00 $0.00 $0.00 $0.0049 Overnight delivery, 50-lb cooler (loaded) ea $68.00 $0.00 $0.00 $0.00 $0.00 $0.0050 3 GPS stations, 3rd Order day $100.00 $0.00 $0.00 $0.00 $0.00 $0.00

week $300.00 $0.00 $0.00 $0.00 $0.00 $0.00month $900.00 $0.00 $0.00 $0.00 $0.00 $0.00

$0.00 $0.00 $0.00 $0.00 $0.00

51Per diem (Cost of personal travel expenses per person per day) day $124.00 4 $496.00 $0.00 2 $248.00 9 $1,116.00 $1,860.00

52a Airfares (San Antonio, TX/Buffalo, NY) trip $800.00 1 $800.00 $0.00 $0.00 1 $800.00 $1,600.0052b Airfares (Bloomfield, NJ/Buffalo, NY) trip $350.00 1 $350.00 $0.00 1 $350.00 2 $700.00 $1,400.0053 Automobile mileage mi $0.405 200 $81.00 $0.00 $0.00 200 $81.00 $162.0054 Truck/van mileage mi $0.00 $0.00 $0.00 $0.00 $0.0055 4-wheel drive mileage mi $0.00 $0.00 $0.00 $0.00 $0.0056 18' boat, daily rental day $150.00 $0.00 $0.00 $0.00 $0.00 $0.0057 Color photo prints ea $0.36 100 $36.00 $0.00 $0.00 $0.00 $36.0058 35mm slides 24 exp $2.99 $0.00 $0.00 $0.00 $0.00 $0.0059 digital camera rental day $0.00 $0.00 $0.00 $0.00 $0.0060 Video or cd equipment day $0.00 $0.00 $0.00 $0.00 $0.0061 Video tape/ 3 cd ea $5.00 $0.00 $0.00 $0.00 $0.00 $0.0062 Color plots per sq ft sq ft $4.50 $0.00 $0.00 $0.00 $0.00 $0.0063 8.5x11 color prints ea $0.40 100 $40.00 100 $40.00 100 $40.00 400 $160.00 $280.0064 11x17 color prints ea $0.50 $0.00 $0.00 $0.00 200 $100.00 $100.0065 Hydro Track Data Logger day $54.38 $0.00 $0.00 $0.00 $0.00 $0.0066 week $144.38 $0.00 $0.00 $0.00 $0.00 $0.00

66 a mnth $300.00 $0.00 $0.00 $0.00 $0.00 $0.0067 Organic Vapor Analyzer (FID) day $73.92 $0.00 $0.00 $0.00 $0.00 $0.0068 week $209.17 $0.00 $0.00 $0.00 $0.00 $0.00

68 a mnth $375.00 $0.00 $0.00 $0.00 $0.00 $0.0069 HNu Photoionization Detector (PID) day $59.58 $0.00 $0.00 $0.00 $0.00 $0.0070 week $159.17 $0.00 $0.00 $0.00 $0.00 $0.00

70 a mnth $325.00 $0.00 $0.00 $0.00 $0.00 $0.0071 Total Vapor Analyzer (PID/FID) day $60.25 $0.00 $0.00 $0.00 $0.00 $0.0072 week $169.17 $0.00 $0.00 $0.00 $0.00 $0.00

72 a mnth $500.00 $0.00 $0.00 $0.00 $0.00 $0.00

Task 4E & D QCP ARAR ID & DQO's Data Gap AnalysisInpection/Data Revw

Task 1 Task 2 Task 3

Note: All rates exclude Earth Tech mark-up and fee. March 10, 2005. Page 3 of 17 06 May 2005



Base YearID Item Name Units number Cost number Cost number Cost number Cost Sum of tasks



73 Soil Vapor Analyzer (PID) day $59.58 $0.00 $0.00 $0.00 $0.00 $0.0074 week $159.17 $0.00 $0.00 $0.00 $0.00 $0.00

74 a mnth $325.00 $0.00 $0.00 $0.00 $0.00 $0.0075 Magnetometer rental (Mag) day $27.67 $0.00 $0.00 $0.00 $0.00 $0.0076 week $69.50 $0.00 $0.00 $0.00 $0.00 $0.00

76 a mnth $110.00 $0.00 $0.00 $0.00 $0.00 $0.0077 Ludlum Radiation Survey Meter day $42.08 $0.00 $0.00 $0.00 $0.00 $0.0078 week $97.92 $0.00 $0.00 $0.00 $0.00 $0.00

78 a mnth $188.00 $0.00 $0.00 $0.00 $0.00 $0.0079 Well Pump (Peristaltic or Bladder) day $20.42 $0.00 $0.00 $0.00 $0.00 $0.0080 week $57.92 $0.00 $0.00 $0.00 $0.00 $0.00

80 a mnth $110.00 $0.00 $0.00 $0.00 $0.00 $0.0081 Well Pump (Whale) ea $98.00 $0.00 $0.00 $0.00 $0.00 $0.0082 Disposable Groundwater Filter Cartridge ea $12.83 $0.00 $0.00 $0.00 $0.00 $0.0083 Disposable Gloves box $9.67 $0.00 $0.00 $0.00 $0.00 $0.0084 Disposable Bailer ea $5.08 $0.00 $0.00 $0.00 $0.00 $0.0085 Water Level Indicator day $19.58 $0.00 $0.00 $0.00 $0.00 $0.0086 week $42.50 $0.00 $0.00 $0.00 $0.00 $0.00

86 a mnth $90.00 $0.00 $0.00 $0.00 $0.00 $0.0087 Oil/Water Interface Probe day $38.58 $0.00 $0.00 $0.00 $0.00 $0.0088 week $105.00 $0.00 $0.00 $0.00 $0.00 $0.00

88 a mnth $225.00 $0.00 $0.00 $0.00 $0.00 $0.0089 Water Quality Meter day $69.97 $0.00 $0.00 $0.00 $0.00 $0.0090 week $197.00 $0.00 $0.00 $0.00 $0.00 $0.00

90 a mnth $225.00 $0.00 $0.00 $0.00 $0.00 $0.0091 Turbidity Meter day $24.25 $0.00 $0.00 $0.00 $0.00 $0.0092 week $61.33 $0.00 $0.00 $0.00 $0.00 $0.00

92 a mnth $110.00 $0.00 $0.00 $0.00 $0.00 $0.0093 Flow Through Cell day $36.00 $0.00 $0.00 $0.00 $0.00 $0.0094 week $87.00 $0.00 $0.00 $0.00 $0.00 $0.00

94 a mnth $150.00 $0.00 $0.00 $0.00 $0.00 $0.0095 Water Sampler day $57.83 $0.00 $0.00 $0.00 $0.00 $0.0096 week $132.50 $0.00 $0.00 $0.00 $0.00 $0.00

96 a mnth $130.00 $0.00 $0.00 $0.00 $0.00 $0.0097 Air Monitoring Pump & Calibrator day $44.58 $0.00 $0.00 $0.00 $0.00 $0.0098 week $106.25 $0.00 $0.00 $0.00 $0.00 $0.00

98 a mnth $110.00 $0.00 $0.00 $0.00 $0.00 $0.00




Base YearID Item Name Units number Cost number Cost number Cost number Cost Sum of tasks



99 Air Monitoring Charger day $0.00 $0.00 $0.00 $0.00 $0.00100 week $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

100 a mnth $0.00 $0.00 $0.00 $0.00 $0.00 $0.00101 High Volume Air Sampler day $39.17 $0.00 $0.00 $0.00 $0.00 $0.00102 week $100.00 $0.00 $0.00 $0.00 $0.00 $0.00

102 a mnth $110.00 $0.00 $0.00 $0.00 $0.00 $0.00103 Multi Gas Monitor day $39.50 $0.00 $0.00 $0.00 $0.00 $0.00104 week $111.83 $0.00 $0.00 $0.00 $0.00 $0.00

104 a mnth $225.00 $0.00 $0.00 $0.00 $0.00 $0.00105 Miran 1A IR Spectrophotometer day $185.17 $0.00 $0.00 $0.00 $0.00 $0.00106 week $714.17 $0.00 $0.00 $0.00 $0.00 $0.00

106 a mnth $1,875.00 $0.00 $0.00 $0.00 $0.00 $0.00107 Photovac 10 S Portable Field GC day $158.33 $0.00 $0.00 $0.00 $0.00 $0.00108 week $656.20 $0.00 $0.00 $0.00 $0.00 $0.00

108 a mnth $1,500.00 $0.00 $0.00 $0.00 $0.00 $0.00109 Portable Field GC Carrier Gas day $50.00 $0.00 $0.00 $0.00 $0.00 $0.00110 week $100.00 $0.00 $0.00 $0.00 $0.00 $0.00

110 a mnth $300.00 $0.00 $0.00 $0.00 $0.00 $0.00111 MIE MiniRAM - Dust Sampler day $66.42 $0.00 $0.00 $0.00 $0.00 $0.00112 week $152.50 $0.00 $0.00 $0.00 $0.00 $0.00

112 a mnth $250.00 $0.00 $0.00 $0.00 $0.00 $0.00113 MIE Minibuck Calibrator day $15.63 $0.00 $0.00 $0.00 $0.00 $0.00114 week $46.88 $0.00 $0.00 $0.00 $0.00 $0.00

114 a mnth $115.00 $0.00 $0.00 $0.00 $0.00 $0.00115 Vista Heat Stress Monitor day $53.08 $0.00 $0.00 $0.00 $0.00 $0.00116 week $163.58 $0.00 $0.00 $0.00 $0.00 $0.00

116 a mnth $900.00 $0.00 $0.00 $0.00 $0.00 $0.00117 CEL Noise SLM day $37.25 $0.00 $0.00 $0.00 $0.00 $0.00118 week $107.58 $0.00 $0.00 $0.00 $0.00 $0.00

118 a mnth $300.00 $0.00 $0.00 $0.00 $0.00 $0.00119 Larson & Davis Noise Dosimeter day $32.08 $0.00 $0.00 $0.00 $0.00 $0.00120 week $93.58 $0.00 $0.00 $0.00 $0.00 $0.00

120 a mnth $188.00 $0.00 $0.00 $0.00 $0.00 $0.00121 5-minute Escape Pack day $450.00 $0.00 $0.00 $0.00 $0.00 $0.00122 week $0.00 $0.00 $0.00 $0.00 $0.00

122 a mnth $0.00 $0.00 $0.00 $0.00 $0.00123 Body Harness and Safety Tripod day $450.00 $0.00 $0.00 $0.00 $0.00 $0.00124 week $0.00 $0.00 $0.00 $0.00 $0.00

124 a mnth $0.00 $0.00 $0.00 $0.00 $0.00Sum of each task $1,971.00 $136.00 $782.00 $3,101.00 $5,990.00

Total SumEquipment does not include delivery fees, as delivery locations are unknown


DRILLING RATESFOR OFFICIAL USE ONLY

WELL DRILLING AND INSTALLATION COSTS Units Base Year Rates number Cost125 Mobilization - Cost per mile MI $6.50 $0.00126 Auger Advance (Hollow stem 4-1/2") - Cost per foot FT $14.50 $0.00127 Auger Advance (Hollow stem 6-1/4") - Cost per foot FT $17.50 $0.00128 Auger Advance with Continuous sampling (Hollow stem 4-1/2") (Split Tube) - Cost per foot FT $21.25 $0.00129 Auger Advance with Continuous sampling (Hollow stem 6-1/4") (Split Tube) - Cost per foot FT $24.50 $0.00130 Vibra Core Sampling, Continuous (Does not include boat) State capability to provide/availability FT $0.00131 Well Installation, Labor - Cost per hour HR $156.25 $0.00

Well Installation, Materials $0.00

132 PVC Well Installation, 2", materials (includes casing, 10' screen riser, annular materials and other per specifications). Average depth 50 feet. Cost per foot. FT $17.25 $0.00

133 PVC Well Installation, 4", materials (includes casing, 10' screen riser, annular materials and other per specifications). Average depth 50 feet. Cost per foot. FT $22.75 $0.00

134 Stainless Steel (Schedule 304) Well Installation, 2", materials (includes casing, 10' screen riser, annular materials and other per specifications). Average depth 50 feet. Cost per foot. FT $37.25 $0.00

135 Stainless Steel (Schedule 304) Well Installation, 4", materials (includes casing, 10' screen riser, annular materials and other per specifications). Average depth 50 feet. Cost per foot. FT $51.50 $0.00Hydropunch Groundwater Sampling (Does not include drilling) $0.00

136 0 - 20' EA $191.25 $0.00137 20 - 40' EA $220.00 $0.00138 Well Development - Equipment Decontamination - Cost per hour (2 men) HR $163.75 $0.00139 Well Permeability - per well (Slug Test) TEST $180.00 $0.00140 Drum Containment of Cuttings (Materials and Labor) - Cost per 55-gallon drum DR $52.50 $0.00141 Drum Overpacking (Materials and Labor for one 55-gallon Overpack to 85-gallon Drum EA $145.00 $0.00

142Soil Testing: Grain Size (ASTM D421, D422, Includes both Sieve and Hydrometer) (cost per sample) EA $113.75 $0.00

143 Soil Testing: Atterberg Limits (ASTM D423, D424) (cost per sample) EA $86.25 $0.00144 Soil Testing: Moisture Content (cost per sample) EA $9.00 $0.00145 Soil Testing: Dry Specific Gravity (cost per sample) ASTM D854-92 EA $40.00 $0.00146 Soil Testing: Bulk Density, as received (cost per sample) - ASTM D2937 EA $76.25 $0.00147 Soil Sample Visual Classification (USCS) and Storage (cost per sample) EA $20.00 $0.00148 Geologist - Cost per hour (A-E Staff) HR $0.00149 Industrial Hygienist - Cost per hour (A-E Staff) HR $0.00150 Site Safety Engineer - Cost per hour (A-E Staff) (Rad Control Tech) HR $0.00151 Survey Crew (2 people) - Cost per hour (A-E Staff) HR $0.00

HTRW Incremental - Cost per each day per person. Includes equipment, clothing, but NOT labor $0.00152 Level D (when PPE required) DAY $15.00 $0.00

All rates exclude Earth Tech indirect markup and fee.March 10, 2005

DRILLING RATESFOR OFFICIAL USE ONLY

153 Level C DAY $33.00 $0.00154 Level B DAY $52.00 $0.00155 Level A DAY $74.00 $0.00156 Geoprobe - Mobilization and Demobilization MI $4.96 $0.00157 Geoprobe On-Site Drilling and Multi-Media Sampling (Soil, Soil Gas, Groundwater) FT $14.00 $0.00

X-Ray Fluorescence Analysis (XRF) - Rental by A-E day $600.00 $0.00week $3,000.00 $0.00month $8,000.00 $0.00

158 On-site XRF Analysis for one (1) metal (soil sample) Sample $17.50 $0.00159 Analysis for each additional metal Sample $0.00

Portable Field GC Analysis - Rental by A-E $0.00160 BTEX Sample $85.00 $0.00161 Each Additional Compound Sample $5.00 $0.00162 Backfill Material (Granular Bentonite) - Standard 50-pound bag, unless otherwise indicated BG $17.00 $0.00

163 10-ft x 40-ft two room mobile office with two air conditioners. Includes drop off and pick-up charge. State capability to provide/availability Month $2,052.00 $0.00

164 Portable toilet, to include weekly cleaning. Includes drop off and pick-up charge. State capability to provide/availability JOB $85.00 $0.00Disposal of liquid and solid waste, to include the cost of a 55-gallon drum, transportation and tipping fees; disposal; preparing manifests and/or other documentation and providing a certificate of disposal for each waste. $0.00

165 Disposal of non-hazardous liquid or solid waste. Cost per 55-gallon drum. DR $100.00 $0.00166 Disposal of RCRA or TSCA hazardous liquid or solid waste. Cost per 55-gallon drum. DR $300.00 $0.00

Sum of each task $0.00


LAB ANALYSISFOR OFFICIAL USE ONLY

LABORATORY ANALYTICAL RATESA. SOIL/WASTE ANALYSIS

167 Zn (ICP)168 Hg (C.V.) (7471A)169 As (ICP)170 As (GFAA)171 Se (ICP)172 Se (GFAA)173 Ag (ICP)174 Ba (ICP)175 Cd (ICP)176 Cr (ICP)177 Cr (Hexavalent) (7196/3060A)178 Pb (ICP)179 Pb (GFAA)180 Na (ICP)181 Fe (ICP)182 Mn (ICP)183 Sb (ICP)184 Be (ICP)185 Cu (ICP)186 Ni (ICP)187 TI (ICP)188 Th (GFAA)189 TAL Metals (23) (6010B/7471A)190 Total Petroleum Hydrocarbons (418.1)191 Total Petroleum Hydrocarbons - Gasoline (Mod. 8015)192 Total Petroleum Hydrocarbons - Diesel (Mod. 8015)193 Pesticides (8081A)/PCB (8082)194 PCB (8082)195 Explosives (EPA 8330)



LABORATORY ANALYTICAL RATES196 Ignitability (1010)197 Corrosivity (9045C)198 Reactivity (Sulfides & Cyanides) (7.3)199 EP Toxicity (TCLP) All TCLP parameters200 Volatile Organics + 10 (8260 + TICs)201 B/N/A Organics + 20 (8270 + TICs)202 Diesel Range Organics (DRO) (8015B)203 PAHs (EPA SW846-8310)204 Semi-Volatile Organics (8270C)205 Residue, Total (160.3)206 Residue, Volatile (160.4)207 Phosphorus, Total (365.2)208 Paint Filter Test (9095A)209 Asbestos Fiber, Solid (PLM)210 Asbestos Fiber, Air (PCM)211 Asbestos Fiber, Air (TEM)212 COD (410.4)213 TOX (Method 9020)214 TOC (9060)215 Total Coliform (9132)216 Fecal Coliform (9222D)217 Phthalate Esters (8270C)218 Chlorinated Hydrocarbons (8120)219 Chlorinated Herbicides (8151A)220 Organophosphorus Pesticides (8141A)

221Common Anions (EPA 300.0) - price for 5 common anions; additional anions at $10 ea.(base)

222EPA RAS Inorganic and Organic CLP Analyses (TCL/TAL by CLP for VOC/sVOC/Pest/PCB/Metals/Cyanide)

223 MTBE (8260B)



LABORATORY ANALYTICAL RATESImmunoassays - Materials only [specify type of test kit(s) with detection limits indicated

224 PCP Immunoassay (4010A) 225 PCB Immunoassay (4020) 226 TPH by Immunoassay (4030) 227 PAHs by Immunoassay (4035)228 TNT by Immunoassay (4050) 229 pH (9041A)

230 Cyanide, Total and Amenable to Chloride (9012A/9010B)231 Phenols (8270C)232 2, 3, 7, 8-TCDD (8290)233 Total Sulfate (9056)234 Total Sulfide (376.2)235 Nitrate-Nitrogen (300.0)236 Ammonia Nitrogen (350.1)237 Total Kjeldahl Nitrogen (351.X)238 Volatile Aromatic Organics (8021B) (BTEX)

B. LIQUID ANALYSIS239 Zn (ICP)240 Hg (C.V.) (7470A)241 As (ICP)242 As (GFAA)243 Se (ICP)244 Se (GFAA)245 Ag (ICP)246 Ba (ICP)247 Cd (ICP)248 Cr (ICP)249 Cr (Hexavalent) (7196A)250 Pb (ICP)251 Pb (GFAA)252 Na (ICP)



LABORATORY ANALYTICAL RATES253 Fe (ICP)254 Mn (ICP)255 Sb (ICP)256 Be (ICP)257 Cu (ICP)258 Ni (ICP)259 TI (ICP)260 Th (GFAA)261 TAL Metals (23) (6010B/7470A)262 Total Petroleum Hydrocarbons (9070A)263 Total Petroleum Hydrocarbons - Gasoline (Mod. 8015)264 Total Petroleum Hydrocarbons - Diesel (Mod. 8015)265 Pesticide (8081A)/PCB (8082)266 PCB (8082)267 Explosives (EPA 8330)268 Ignitability (1010)269 Corrosivity (9045C)270 Reactivity (Sulfides & Cyanides) (7.3)271 EP Toxicity (TCLP)272 Volatile Organics + 10 (8260B + TICs)273 B/N/A Organics + 20 (8270C + TICs)274 Diesel Range Organics (DRO) (8015B)275 PAHs (8310)276 Semi-Volatile Organics (8270C)277 Residue, Total (160.3)278 Residue, Volatile (160.4)279 Residue, Non-Filterable (TDS - 160.2)280 Residue, Filterable (TSS - 160.1)281 pH (150.1)



LABORATORY ANALYTICAL RATES282 Cyanide, Amenable to Chloride (9012A/9010B)283 Cyanide, Total (335.3)284 Phenols (8270C) 285 2, 3, 7, 8-TCDD (8290)286 Total Sulfate (300)287 Total Sulfide (376.2)288 Nitrate-Nitrogen (EPA 300)289 Ammonia Nitrogen (350.1)290 Total Kjeldahl Nitrogen (351.X)291 Acid Soluble/Insoluble Sulfides (9030B)292 Volatile Aromatic Organics (8021B) (BTEX)293 Phosphorus, Total (365.4)294 Chloride (300.0)295 Fluoride (300.0)296 TOX (ASTM D808-87) (Method 9020)297 Turbidity (NTU) (180.1)298 COD (410.4)299 BOD (405.1)300 TOC (415.1)301 Total Coliform (9132)302 Fecal Coliform (9222D)303 Phthalate Esters (8270C)304 Chlorinated Hydrocarbons (8260B)305 Chlorinated Herbicides (8151A)306 Organophosphorus Pesticides (8141A)307 Common Anions (EPA 300.0)

308EPA RAS Inorganic and Organic CLP Analyses (TCL/TAL by CLP for VOC/sVOC/Pest/PCB/Metals/Cyanide)

309 MTBE (8260B)



LABORATORY ANALYTICAL RATESImmunoassays - Materials only [specify type of test kit(s) with detection limits indicated

310 PCP Immunoassay (4010A)311 PCB Immunoassay (4020)312 TPH by Immunoassay (4030)313 PAHs by Immunoassay (4035)314 TNT by Immunoassay (4050)315 Asbestos Fiber (TEM)316 "EnCore" samplers (price per sampler)

NEW ITEMS REQUESTED Total Suspended Solids Total Dissolved Solids Sum of each task


RAD ANALYSISFOR OFFICIAL USE ONLY

BASE YEARRADIOLOGICAL SERVICES PRICE PER SAMPLE ($) Dosimetry

317 a. internal, bioassy (per nuclide) ea318 b. external (TLD monitoring program, per person) ea

Analytical Services

319 neutron detection, (realitivistic), moderated gas proportional, min of 10 samples/day ea

320 neutron detection, (thermo), gas proportional, min of 10 samples/day ea

321 neutron coincidence counting, (fissile) ea

322 radiochemistry by ICP-MS, appropriate nuclides and isotopes ea

323On-site radiological analysis, (per sample per nuclide per isotope), may consist of various analytical instrumentation ea

324 Radon Flux ea325 TETLD (tissue equivalent thermo luminesent detector) ea

Alpha Spectroscopy326 Americium-241 ea $105.00327 Americium-243 ea $105.00328 Curium-242, 243/244, 245/246 ea $105.00329 Neptunium-237 (isotopic) ea $105.00330 Plutonium-238, 239/240 (isotopic) ea $105.00331 Plutonium-242 ea $105.00332 Polonium-208, 210 (isotopic) ea $105.00333 Thorium-228, 230, 232 (isotopic) ea $105.00334 Thorium-229 ea $105.00335 Uranium-233/234, 235/236, 238 (isotopic) ea $105.00336 Uranium-232 ea $105.00337 Radium-223, 224, 226 ea $126.00338 Radon Isotopes ea

Gamma Spectroscopy339 Antimony-124 ea $110.00340 Antimony-125 ea341 Barium-140 ea342 Berylium-7 ea343 Bismuth-212 ea344 Bismuth 214 ea345 Cerium-141 ea346 Cerium 144 ea347 Cesium-134 ea348 Cesium-137 ea349 Chromium-51 ea350 Cobalt-57 ea351 Cobalt-58 ea

Alll rates exclude Earth Tech indirect markup and fee.March 10, 2005


BASE YEARRADIOLOGICAL SERVICES PRICE PER SAMPLE ($)

352 Cobalt-60 ea353 Europium-152 ea354 Europium-154 ea355 Europium-155 ea356 Iodine-131 ea357 Iridium-192 ea358 Iron-59 ea359 Lead-212 ea360 Lead-214 ea361 Manganese-54 ea362 Mercury-203 ea363 Neptunium-239 ea364 Niobium-94 ea365 Potassium-40 ea366 Promethium-144 ea367 Promethium-146 ea368 Ruthenium ea369 Silver-110 ea370 Sodium-22 ea371 Thallium 208 ea372 Thorium-234 ea373 Tin-113 ea374 Uranium-235 ea375 Yitrium-88 ea376 Zinc-65 ea377 Zirconium-95 ea378 Radium-223, 224, 226; Radium 226 by Bismuth ingrowth ea

Liquid Scintillation 379 Radon-222 ea $105.00380 Carbon-14 ea $78.75381 Nickel-63 ea $126.00382 Phosphorous-32 ea $126.00383 Plutonium-241 ea $157.50384 Promethium-147 ea $170.00385 Radium 226 (by Radon Emanation EPA 903.X) ea $110.00386 Selenium-79 ea $165.00387 Technetium-99 ea $78.75388 Tritium (H-3) ea $73.50

Gas Flow Proportional389 Gross Alpha ea $36.75390 Nonvolatile Beta ea $36.75391 Gross Alpha and Nonvolatile Beta ea $47.25392 Total Alpha Radium ea $78.75393 Iodine-131 ea $84.00394 Lead-210 ea $99.75395 Radium-228 ea $78.75396 Strontium-89, 90 ea $115.50



BASE YEARRADIOLOGICAL SERVICES PRICE PER SAMPLE ($)X-Ray Spectroscopy

397 Tellurium-125m ea $84.00398 Iodine-129 ea $84.00399 Iron-55 ea $126.00400 Nickel-59 ea $126.00

Kinetic Phosphorimetry (KPA)401 Total Uranium ea $47.25

ICP-MS402 Total Uranium ea $31.50

Radiological Method References:

Alpha, Gamma, Gas Proportional, Liquid Scintillation -DOE EML HASL 300 Series / EPA 900 SeriesTotal Uranium -Kinetic Phosphorimetry, EPA 908.0 -ICP-MSLiquid Scintillation -EPA EERFX-Ray Spectroscopy -DOE RESL

2. The above prices are based upon a Certificate of Analysis deliverable. Sum of each task

SPECIFIC LINE NOTES: multiplier3-day turnaround 2.007-day turnaround 1.7514-day turnaround 1.3021-day turnaround 1.1028-day tournaround 0.00

ANALYTICAL COSTS – Laboratory Analytical Rates

Notes: 1. The pricing for the above line items shall include bottles and coolers shipped to the site, unless otherwise indicated.


NATURAL ATTENUATIONFOR OFFICIAL USE ONLY

Natural Attenuation Parameters Base Year Price Task 1 Task 2

Unit InpectionSoil Natural Attenuation Parameters number Cost number Cost

403 Total Organic Carbon each $32.50 $0.00 $0.00404 Moisture Content each $7.50 $0.00 $0.00405 Dry Specific Gravity each $40.00 $0.00 $0.00406 Common Anions each $32.50 $0.00 $0.00407 2,3,7,8 -TCDD each $410.00 $0.00 $0.00408 CH4,C2H6,C2H4 each $70.00 $0.00 $0.00

Water Natural Attenuation Parameters $0.00 $0.00409 CH4,C2H6,C2H4 each $87.50 $0.00 $0.00410 Alkalinity each $5.00 $0.00 $0.00411 Alkalinity each $17.00 $0.00 $0.00412 Ox/Red. Pot. each $10.00 $0.00 $0.00413 pH & Temperature each $10.00 $0.00 $0.00414 Conductivity each $10.00 $0.00 $0.00415 Major Cations each $17.50 $0.00 $0.00416 Chloride each $13.50 $0.00 $0.00417 Hydrogen each $150.00 $0.00 $0.00

Sum of each task $0.00 $0.00

ANALYTICAL COSTS – Laboratory Analytical RatesSPECIFIC LINE NOTES:

Level III (CLP Like – Forms only); EDD formatLevel IV (CLP Like – Forms + Raw Data); EDD format

#2. Standard turnaround time is 21 calendar days. The following surcharges apply:

3-day turnaround 7-day turnaround 14-day turnaround21-day turnaround 28-day tournaround

GENERAL NOTES:

A. The pricing for the above line items shall include bottles and coolers shipped to the site, unless otherwise indicated. B. Provide CD-ROM deliverables for all applicable line items in lieu of paper reports

E & D QCP



Appendix D Example of Senior Technical and Independent Technical Review

Certification Signature Pages

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