engineering management support, inc. memorandum · on february 15, 2018, a representative from...

Memorandum To: Jesse Aviles, EPA RPM, VB/I70 Superfund Site

From: Timothy C. Shangraw

Date: March 29, 2018

Amended: April 20, 2018

Re: POLREP #32 - Vasquez Boulevard/Interstate 70 (VB/I70) Superfund Site, Operable

Unit 2, Removal Action

=======================================================================

On behalf of the City and County of Denver (Respondent), Engineering Management Support, Inc. (EMSI) is submitting this Pollution Report (POLREP #32) in accordance with Section 4.c of Appendix C to the Administrative Settlement Agreement and Order on Consent for Removal Action, for the subject Superfund Site (the Site). This report follows the outline detailed in Section 4.c of Appendix C, and contains pertinent new information specified in the Superfund Removal Procedures, Removal Response Reporting: POLREP and On-Scene Coordinator (OSC) Reports (EPA, 1994).

Section I – Heading

The date, site name, report author, report recipient, and report number are presented above.

Section II – Response Information

This reporting period extended from February 1 through 28, 2018 during which time the following activities occurred:

Excavation of non-Regulated Asbestos-Contaminated Soil (RACS), stockpiling some ofit onsite for future backfilling, and hauling the remainder to the Denver ArapahoeDisposal Site (DADS);

Construction of outlet wing walls and open channel sidewalls through the ColiseumParking Lot (CPL);

Construction of inlet and outlet wing walls, open channel sidewalls, lateral drain boxes,UV treatment box, Arkins Court transition structure, and outlet rip rap through theGlobeville Landing Park (GLP);

Pumping and treatment of groundwater from dewatering zones 1, 2, 3a, and 3b;

On-site and off-site monitoring for air quality, dust, and odors; and

Conducting Quality Assurance field audits.

The volumes of water pumped, treated, and returned to the South Platte River, and the volumes of non-RACS excavated and managed are summarized in Table 1. No RACS were excavated

Engineering Management

Support, Inc.

Memorandum

POLREP #32

VB/I70, OU2 Removal Action

March 29, 2018

during the month.

On-site monitoring for volatile organic compounds (including methane), odor, and visible dust emissions occurred continuously during excavation activities. In addition, monitoring for airborne asbestos fibers proceeded in accordance with Section 5.5 of the Colorado’s Solid Waste Regulations (CSWRs). Due to their overall size, daily monitoring reports for volatile organic compounds, odor, dust, and asbestos are being submitted under separate cover.

Off-Site monitoring by Denver for PM10, airborne lead and arsenic at four locations within the monitoring boundary continued throughout the reporting period. Sampling from these stations occurred every sixth day throughout the month. All results were all below the Occupational Safety and Health Administration 8-hour limits and National Ambient Air Quality Standards. Monthly monitoring reports are posted on the Globeville Landing Outfall (GLO) project web site at: https://www.denvergov.org/content/denvergov/en/environmental-health/environmental-quality/land-use-and-planning.html.

As part of the GLO project’s Community Outreach program, a community hotline was operated. No complaints were received during the reporting period. The Community Advisory Group (CAG) held its thirteenth meeting on March 13

th. Meeting minutes are posted on the VB/I-70

Superfund Community Advisory Group web site. The next CAG meeting is scheduled for April 10, 2018.

The following project meetings were held in February and earlier this month:

Weekly GLO Project Status Meetings (February 1, 8, 15, and 22, 2018); and

EPA monthly progress meeting (March 21, 2018).

Lastly, a 3-week look-ahead Construction Schedule is attached to this POLREP.

Section III – Issues, Resolutions, and Planned Activities

Quality Assurance (QA) Audit Report #10 was prepared on March 7, 2018. It involved a site inspection on February 15

th by a representative from Engineering Management Support, Inc.

(EMSI) to assess consistency with Section 5.5 of Colorado’s Solid Waste Regulations (CSWRs), and consistency with environmental monitoring activities detailed in the Final Materials Management Plan (MMP) (EMSI, 2016). In addition, the EMSI representative reviewed Kleinfelder’s Certified Asbestos Building Inspector (CABI) reports dated February 1, 5, 10, and 15 for completeness and accuracy. The field inspection indicated asbestos management and environmental monitoring activities were being performed in partial compliance with Section 5.5 of the CSWRs. During excavation to expose some of the stone columns, Kleinfelder representatives appeared uncertain about their determinations of whether the material immediately overlying the columns was RACS, and if the excavated area should be determined an RWA. This appeared to be caused more by a change in Kleinfelder personnel recently assigned to the project than by a proper determination of RACS/RWA. Upon review of earlier

Memorandum

POLREP #32

VB/I70, OU2 Removal Action

March 29, 2018

records, the material had been classified as non-RACS. It also appeared that Kleinfelder was not informed by Ames that when excavating to the top of stone columns, Ames would encounter soil other than Class 1 fill material. Required corrective actions consisted of 1) better informing new Kleinfelder personnel about historical Site knowledge and prior RACS determinations, 2) updating protocol for handling suspect ACM, and 3) improving communications among Kleinfelder and Ames personnel. Only one minor typographical error was noted on one of the CABI reports. All of the required corrective actions have been implemented and the typographical error has been corrected. Therefore, the audit was closed. A copy of the Audit Report is attached to this POLREP.

Monitoring of treated effluent from the GLO project continued during the reporting period in

accordance with Discharge Permit Number CO0049002. All monitored parameters met

discharge limits during the month, as shown in the attached summary table.

Planned activities for the next reporting period consist of:

Continue construction of wing walls and open channel sidewalls through the CPL andGLP;

Complete construction of lateral drain boxes in the GLP;

Complete construction of outlet structures, transition zones, and riprap in the GLP;

Complete final grading of the drainage channel and placement of the strengthening layer;

Begin placement of liner material over the strengthening layer;

Continued dewatering in zones 1, 2, 3a and 3b; and

Continued on-site and off-site monitoring of air quality.

To maintain effective and transparent communication during GLO implementation, EPA and CDPHE

personnel are invited to participate in weekly coordination meetings at Kiewit’s RiNo office. The

next EPA Monthly Status meeting will be held on April 18th at 9:00 am in the Webb building.

Please call Andrew Ross (720.865.5458) or me (303.619.5179) if you have any questions.

Attachments:

February 2018 Summary of GLO Construction Activities 3-Week Look-Ahead Schedule QA Audit Report # 10 Summary of Effluent and Influent Analytical Results

UPDATED 4/20/18 TABLE 1 - FEB 2018 Construction Summary

Current Month QTY QTY to date Comments

EXCAVATION/HAULING

# of days Excavation occurred Globeville park 5 103# of days Excavation occurred Municipal Landfill 0 35

Volume of Racs Excavated (CY) 0 89,527 From Globeville Park

Volume of Racs hauled to DADS (CY) 0 89,527 From Globeville Park

Volume of Non-Racs Excavated (CY) 1,518 60,487

Volume of Non-Racs stockpiled onsite (CY) 510 13,116

Volume of Non-Racs hauled to DADS (CY) 1,008 47,371

Volume Hauled to Clean Harbors (CY) 0

GROUT AND STONE COLUMNS

number of grout columns installed this month 0 1,091 All Stone and Grout columns are complete

Grout column SPT testing results 0 0 All Stone and Grout columns are complete

number of stone columns installed per month 0 575 All Stone and Grout columns are complete

stone column test results 0 0 All Stone and Grout columns are complete

REMEDIATION DEWATERING AND TREATMENT

LF of underdrain/wick wells installed 650

Volume of water transported and treated at MFEI 1,439,500 28,313,874

Volume of treated water, including dilution,

discharged to S. Platte1 1,356,933 28,499,623

Analytical results 0 Jan DMR submitted; no exceedences

CONSTRUCITION DEWATERING

status of permit compliance

LINER INSTALLATION

% complete during the month N/A

QC/QA testing results N/A

Issues and Resolutions N/A

MODCP RESULTS

Daily Methane, Odor, and Dust monitoring reports

Issues and Resolutions

COMMUNITY OUTREACH

Summary of Calls to hotline

Issues and Resolutions

1 The difference between volume of water treated and the volume of water discharged to the S. Platte can be explained by a combination of factors including tank storage, loss due to reverse osmosis brines, and loss due to moisture in the waste sludge.

Current Forecast Forecast Forecast Comments

Work

performed byShift

03/1

2

03/1

2

03/1

3

03/1

3

03/1

4

03/1

4

03/1

5

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03/1

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03/1

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03/1

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8

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9

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0

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8

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9

03/2

9

03/3

0

03/3

0

03/3

1

03/3

1

04/0

1

04/0

1

04/0

2

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2

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3

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3

04/0

4

04/0

4

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8

M T W T F Sa Su T W T F Sa Su T W T F Sa Su T W T F Sa Su

1

2 EARTHWORK (Park Channel)

3 Backfill S. Lateral Dran box Ames 03/08/18 03/16/18 day

4 Backfill N. Lateral Dran box Ames 03/26/18 03/30/18 day

5 Finish Geogrid and Rock in Channel Ames 03/19/18 03/23/18 day

6 Install Strenghtening Layer (LINER) ECA 03/26/18 04/07/18 day

7

8

9 OUTFALL CHANNEL

10 Upper Soil wrap Ames 03/15/18 03/30/18 day

11 Upper Soil wrap Ames 03/26/18 03/30/18 day

12 Seed / Blanket Lower outfall channel Western states 03/15/18 03/19/18 day

13 Topsoil in upper outfall channel Ames 03/12/18 03/16/18 day

14 Topsoil in upper outfall channel Ames 03/12/18 03/15/18 day

15 Remove sheets zones 1 & 2 Ames 03/12/18 04/14/18 day

16

17 N. LATERAL DRAIN BOX

18 Strip shoring Ames 03/14/18 03/20/18 day

19

20

21 EAST PARK WALL

22

23 UV Vault

24 Lower Excavation Ames 03/12/18 03/13/18 day

25 F/R/D UV vault footing Ames 03/14/18 03/23/18 day

26 F/R/D UV vault wall Ames 03/26/18 03/30/18 day

27 F/R/D UV vault deck Ames 04/02/18 04/15/18 day

28

29

30 N. Bridge Abutment

31 F/R/P N. Abutment wall Ames 03/26/18 04/06/18 day

32

33

34 S. Bridge Abutment

35 F/R/P Abutment wing walls Ames 03/12/18 03/26/18 day

36

37

38 Arkins outlet

39 F/R/P Apron section 1 Ames 03/09/18 03/13/18 day

40 F/R/P Apron section 2 Ames 03/14/18 03/15/18 day

41

42

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Phase 1A 3 week schedule

Monday, March 12, 2018

Item

Globeville Phase 1ASchedule Title

Current Week

Finish Start Activity Description

M M

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Current Forecast Forecast Forecast Comments

Work

performed byShift

03/1

2

03/1

2

03/1

3

03/1

3

03/1

4

03/1

4

03/1

5

03/1

5

03/1

6

03/1

6

03/1

7

03/1

7

03/1

8

03/1

8

03/1

9

03/1

9

03/2

0

03/2

0

03/2

1

03/2

1

03/2

2

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2

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3

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03/2

7

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03/2

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03/2

9

03/3

0

03/3

0

03/3

1

03/3

1

04/0

1

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8

M T W T F Sa Su T W T F Sa Su T W T F Sa Su T W T F Sa SuM

Phase 1A 3 week schedule

Monday, March 12, 2018

Item

Globeville Phase 1ASchedule Title

Current Week

Finish Start Activity Description

M M

43 N. Colisuem conduit wingwall

44 Finegrade Footings J1 - K1 Ames 03/12/18 03/13/18 day

45 F/R/P Footings J1-K1 Ames 03/14/18 03/23/18 day

46 F/R/P walls J1-K1 Ames 03/26/18 04/07/18 day

47

48

49 S. Colisuem conduit wingwall

50 Finegrade Footings L1 - K1 Ames 03/15/18 03/19/18 day

51 F/R/P Footings J1-K1 Ames 03/20/18 03/30/18 day

52 F/R/P walls J1-K1 Ames 04/02/18 04/16/18 day

53

54

55

56

57

58

59

60

61

62

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Engineering Management

Support, Inc.

QA Audit Report #10

To: Marty Beck and Paul Jacobson, Kiewit

From: Tim Shangraw, EMSI

cc:

Andrew Ross, DEH; Steve Gonzales, DEH; Ryan Crum (DPW); Brian McLaren (DPW); and Patrick Riley (DPW)

Date: March 7, 2018

Re:

Audit of Asbestos Management and Environmental Monitoring Activities during February 2018 at Globeville Landing Outfall Project

On February 15, 2018, a representative from Engineering Management Support, Inc. (EMSI) conducted a Quality Assurance (QA) audit of asbestos management activities at the Globeville Landing Outfall (GLO) project for consistency with Section 5.5 of Colorado’s Solid Waste Regulations (CSWRs), and environmental monitoring activities for consistency with the Final Materials Management Plan (MMP) (EMSI, 2016). Mr. David Matteocci with Matteocci & Associates, LLC represented EMSI and Mr. Mitch Reese and Mr. David Buckley represented Kleinfelder.

With respect to Section 5.5 of the CSWRs, the field inspections involved an independent inspection of asbestos handling activities, documentation of findings, sampling, assessment of regulated work areas (RWAs) and how they were delineated, who entered the RWAs and the level of personnel protection equipment (PPE) worn, decontamination procedures, observations of possible visible emissions from RWAs, and other possible indicators of impacted soils. With respect to the MMP, the field inspection involved observations of environmental screening activities of excavated materials, and odor and dust control monitoring.

In addition, the EMSI representative reviewed Kleinfelder’s CABI reports dated February 1, 5, 10, and 15 for completeness and accuracy.

Following completion of the field inspections and CABI report reviews, the EMSI representative met with Ms. Lanaia Carveth to review his observations. Discrepancies or omissions were resolved and documented in both EMSI’s logs and Kleinfelder’s logs. Copies of EMSI’s logs are attached to this Audit Report. Due to their size, copies of Kleinfelder’s logs are submitted under separate cover.

AUDIT FINDINGS

The field inspections indicated asbestos management and environmental monitoring activities were being performed in partial compliance with Section 5.5 of the CSWRs and in full compliance the MMP. Specifically, during excavation to expose stone columns in Area J8,

QA Audit Report #10, GLO Project March 7, 2018

Page 2

Kleinfelder representatives appeared uncertain about their determinations of whether the material being excavated was RACS, and if the area should be determined an RWA. This appeared to be caused more by a change in Kleinfelder personnel recently assigned to the project than by a proper determination of RACS/RWA. It also appeared that Kleinfelder was not informed by Ames that materials being excavated would be below the Class 1 material that had been placed in the area.

Because of the uncertainty, the Kleinfelder CABI conservatively assumed that the soil below the Class 1 material was RACS. Level C PPE was worn by equipment operators when excavating the material, but PPE was not worn be Ames’s workers who shoveled the assumed RACS into a poly-wrapped front-end loader bucket. As well, the area being disturbed was not delineated as an RWA.

On balance, Kleinfelder’s CABI was observing the material being excavated and determined there was no suspect ACM present; only minimal amounts of crushed red brick and concrete were present. He also had the assumed RACS placed in a delineated RWA in Area I6.

Screening of CABI reports identified only one discrepancy:

CABI Report dated February 1, 2018 by David Buckley: Section 2B does not have a yes or no marked. It should be properly marked.

ACTION REQUIRED

With regards to the Site Inspection findings, the following corrective actions should be taken:

1. New Kleinfelder personnel assigned to the project need to be better informed about historical Site knowledge and prior RACS determinations.

2. Protocol for handling suspect ACM should be updated and clearly communicated among Kleinfelder and Ames personnel.

3. Ames needs to better communicate the scope of excavation (areal and vertical extent) in areas containing suspect ACM with Kleinfelder before excavation begins, so proper contingent measures can be planned proactively.

As documented in correspondence from Kleinfelder, these three corrective actions have been addressed to the satisfaction of EMSI. With regards to the single CABI report discrepancy, Section 2B has been properly marked in a revised report. Consequently, this audit report is closed.

Attachments

Historical Influent and Effluent Water Quality, GLO Water Treatment Plant

Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent**

Flow Rate (monthly ave) gpm Continuous 100 N/R 95.5 N/R 96.8 N/R 91.2 N/R 84.5 N/R 54.6 N/R 38.5 N/R 32.9 N/R 31.9 N/R 32.6 N/R 33.7

pH standard units 3 days/wk 6.5 - 9 N/R 7.05 - 7.98 N/R 7.53 - 8.11 N/R 6.83 - 8.13 N/R 7.37 - 8.21 N/R 6.8 - 8.4 N/R 7.1 - 8.4 N/R 7.1 - 8.0 N/R 7.2 - 8.1 N/R 7.31 - 7.96 N/R 7.02 - 7.88

Total Residual Chlorine mg/L 3 days/wk 0.5 N/R 0 - 0.35 N/R 0 - 0.29 N/R 0.01 - 0.29 N/R 0 - 0. 14 N/R 0 - 0.02 N/R 0 - 0.22 N/R 0 - 0.01 N/R 0 - 0.03 N/R 0 - 0.02 N/R 0 - 0.03

Oil and Grease (visual) visual presence 3 days/wk Report N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None

Oil and Grease (lab) mg/L

Contingent upon

visual presence 10 N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R

Total Suspended Solids mg/L Weekly 30 - 45 N/R <5 - 21 N/R 1.4J - 7.3 N/R <5 - 2.5J N/R <2.5 - 13.3 N/R 0.6 - 21.9 N/R 1.7 - 7.7 N/R <2.5 - 20.4 N/R <2.5 - 3.8 N/R 1.3 - 4.7 N/R 1.6 - 7.0

E. Coli #/100 ml Weekly 126 - 252 N/R 0 - 2 N/R 0 N/R 0 N/R 0 - 105 N/R 0 - 54 N/R 0 - 1 N/R 0 - 1 N/R 0 - 11 N/R 0 - 1 N/R 0

BOD5 mg/L Monthly 30 - 45 N/R <2 N/R <1 N/R <1 N/R 1.1 N/R 2.6 N/R <1.0 N/R 11.4 N/R 7.4 N/R 5.5 N/R <12

Total Inorganic Nitrogen mg/L Monthly 10 N/R 8.4 N/R 8.7 N/R 8.7 N/R 8.3 N/R 5.9 N/R 6.8 N/R 5.9 N/R 5.9 N/R 8.1 N/R 2.7

Ammonia mg/L Monthly Report N/R 0.48 N/R 0.3 N/R 0.26 N/R 0.38 N/R 0.38 N/R 0.04 N/R 0.38 N/R 1.2 N/R 2.1 N/R 0.52

Arsenic, total recoverable ug/L Monthly 3.0 7.4 <0.6 3.0 0.55 3.9 <0.4 3.6 0.76 4.1 0.93 3.5 0.61 3.8 0.73 4.5 0.65 7.6 0.72 3.4 <2.0

Cadmium, potentially dissolved ug/L Monthly 0.87 1.88 <0.1 0.9 <0.2 0.74 <0.2 1.2 <0.2 1.6 <0.2 1.7 <0.2 0.81 <0.2 1.1 <0.2 1.0 <0.2 0.8 <0.3

Copper, potentially dissolved ug/L Monthly 5,656 - 6,975 14.8 1.1 6.1 3.2 - 6.1 4.7 4.1 6 5.9 4.3 <4.0 7.1 6.8 4.5 4.8 6.4 10.9 8.9 12.7 4.3 15.9

Iron, total recoverable ug/L Monthly 253,000 8020 50 259 78.2 - 91 332 <500 115 43.4 106 <20 254 53.8 99 315 369 443 2640 169 214 96.7

Lead, total recoverable ug/L Monthly 13,005 47.2 0.6 1.8 0.8 - 1.0 1.4 <1.0 2.1 <1.0 <1.0 <1.0 1.4 <1.0 1.3 <1.0 1.3 <1.0 17.6 <1.0 4.9 <0.5

Lead, potentially dissolved ug/L Monthly 2,405 42.3 0.5 1.6 0.8 - 1.1 3.2 <1.0 1.1 1.9 <1.0 <1.0 1.4 <1.0 1.2 <1.0 <1.0 <1.0 4.9 <1.0 2.9 <0.5

Mercury, total ug/L Monthly 3.5 N/R <0.2 N/R <0.2 N/R <0.1 N/R <0.1 N/R <0.1 N/R 2.0 N/R 0.6 N/R <0.1 N/R <0.1 N/R <0.07

Selenium, potentially dissolved ug/L Monthly 4.6 3.0 - 3.1 3.3 3.2 2.4 - 3.8 4.5 2.2 3.3 1.9 2.5 <0.8 3.0 23.7 4.0 2.3 1.1 2.6 3.5 3.1 3.1 <2.0

WET Testing LC 50 Quarterly ≥ 100 N/R N/R N/R

Failed, then

passed N/R N/R N/R N/R N/R N/R N/R Passsed N/R N/R N/R N/R N/R N/R N/R Passed

shaded cell indicates compliance with permit limit

shaded cell indicates influent exceeds discharge limit; treatment required

shaded cell indicates effluent exceeds permit limit

* Metals Screen required per Section 1.A.3 of GLO Discharge Permit. VOC and SVOC screens confirmed only trace detections.

** Monitored parameters required per Section 1.A.2 of GLO Discharge Permit

Feb-18Jan-18Jul-17Jun-17Parameter Unit

Sample

Frequency

Effluent

Permit Limit

May-17 Dec-17Nov-17Sep-17 Oct-17Aug-17

engineering management support, inc. memorandum · on february 15, 2018, a representative from...

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