[SITE MANAGEMENT PLAN - REMEDIAL …

Site Management Plan Remedial Investigation/Feasibility Study Reassessment

Marion Pressure Treating Company Superfund Site Union Parish, Louisiana

EPA Region 6 Remedial Action Contract 2 Contract: EP-W-06-004

Task Order: 0062-RICO-067Z

Prepared for

U.S. Environmental Protection Agency 1445 Ross Avenue

Dallas, TX 75202-2733

Prepared by

EA Engineering, Science, and Technology, Inc. 405 S. Highway 121 Building C, Suite 100 Lewisville, TX 75067

October 2010 Revision: 00

EA Project No. 14342.62

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RECEIVED ?n!§nCT 13 PH 3̂ 00

SUPERFUND DIV. REMhOiAL BRAHCH

? j j : Q 17 tl) -1

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EA Project No. 14342.62 Contents, Page 1 of 1

EA Engineering, Science, and Technology, Inc. October 2010

CONTENTS Page

1. INTRODUCTION 1 2. SITE SECURITY 2 3. SITE ACCESS 3 4. HEALTH AND SAFETY 3 5. CONTINGENCY PROCEDURES 4 6. WASTE DISPOSAL 4 7. GREEN REMEDIATION 4 8. MANAGEMENT RESPONSIBILITIES 5

8.1 U.S. ENVIRONMENTAL PROTECTION AGENCY 5 8.2 PROJECT MANAGER 5 8.3 FIELD MANAGER 5 8.4 SITE SAFETY AND HEALTH OFFICER 5 8.5 QUALITY ASSURANCE OFFICER 6

9. DOCUMENT MANAGEMENT ...6 9.1 DOCUMENT CONTROL 6 9.2 DOCUMENT DISTRIBUTION 6 9.3 DOCUMENT STATUS 6 9.4 DOCUMENT FILING AND MAINTENANCE PROCEDURES 7 9.5 DEVIATION PROCEDURES 7

10. PROJECT MEETINGS 9 10.1 INVESTIGATION/KICKOFF MEETING 9 10.2 PROGRESS MEETINGS 9

11. AUDIT PROCEDURES 10 11.1 SITE AUDITS 10 11.2 SITE AUDIT REPORTS 10 11.3 SAFETY AND HEALTH AUDITS 11

12. REFERENCES 11

FIGURES

APPENDIX A APPENDIX B APPENDIX C APPENDIX D

DAILY ROSTER GREEN REMEDIATION CHECKLIST POTENTIAL DEVIATION FORM CONTRACT FIELD CHANGE FORM

Marion Pressure Treating Company Superfund Site Site Management Plan Union Parish, Louisiana Revision 00

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EA Engineering, Science, and Technology, Inc.

EA Project No. 14342.62 Acronyms and Abbreviations, Page 1 of 1

October 2010

ACRONYMS AND ABBREVIATIONS

CFR Codeof Federal Regulations EA EA Engineering, Science, and Technology, Inc. EPA U.S. Environmental Protection Agency FM Field Manager HSP Health and Safety Plan LDEQ Louisiana Department of Environmental Quality PM Project Manager QAO Quality Assurance Officer RA Remedial Action RD Remedial Design RI/FSR Remedial Investigation/Feasibility Study Reassessment ROD Record of Decision SAP Sampling and Analysis Plan Site Marion Pressure Treating Company Superfund Site SMP Site Management Plan SSHO Site Safety and Health Officer

Marion Pressure Treating Company Superfund Site Union Parish, Louisiana

Site Management Plan Revision 00

002604

EA Project No. 14342.62 Page 1 of 11


1. INTRODUCTION

This Site Management Plan (SMP) will be used to conduct work associated with the Remedial Investigation/Feasibility Study Reassessment (RI/FSR) at the Marion Pressure Treating Company (MPTC) Superfiind Site (Site) in Marion, Union Parish, Louisiana. The purpose ofthe SMP is to present the RI/FSR approach for handling site security, site access, health and safety, contingency procedures, waste disposal, management responsibilities, document management, project meetings, and audits. These procedures may be modified during the RI/FSR in response to unanticipated or changing conditions.

The Site is located near the town of Marion in Union Parish, Louisiana (Figure 1); the site coordinates are 33°24'29" north latitude and 94°3' 12" west longitude. The Site is located in a rural area on the east side of State Highway (SH) 551, approximately Vi mile north of SH 33. The original Site spans approximately 10 acres; however, past operations and the spread of contamination have extended the area of interest to approximately 22 acres. Although the site is located within a rural area, residential properties are located west and south ofthe site on SH 551. The property is surrounded by forest to the north, west, and south. Wetlands are located to the east and southeast. Big Creek is located east ofthe property, and an unnamed tributary to Big Creek is west ofthe property. The Site drains (1) to the east towards Big Creek through drainage gullies collectively called the East Drainage Ditch, and (2) to the west towards the gullies collectively called the West Drainage Ditch. The current layout of the Site is presented on Figure 2.

MPTC began operations on 1 November 1964, and was owned and operated by Mr. Bobby L. Green. MPTC produced pressure-treated wood products, including poles, bridge pilings, fence posts, and other lumber, reportedly using only creosote during the wood-treating process.

An unlined surface impoundment of unknown depth was used to dispose of process wastewater. During the Resource Conservation and Recovery Act (RCRA) closure ofthe unit in 1985, (1) water in the impoundment was pumped to the onsite wastewater treatment system; (2) sediments were excavated and transported offsite for disposal; and (3) the impoundment was backfilled with approximately 1,450 cubic yards of loamy sand and graded to conform with the general topography of the area. Closure of the impoundment resulted in several unresolved Louisiana Department of Envirormientai Quality (LDEQ) enforcement actions against MPTC for lacking post-closure plans, ground water sampling plans, invalid certification of clean closure, and other violations.

Operations at the facility ceased in late 1989 when the company president, Mr. Green, filed for Chapter 7 bankruptcy.

In September 1990, the LDEQ conducted a RCRA compliance inspection at MPTC and found that the facility was abandoned with no sign of recent activity. In March 1991, the LDEQ's Ground Water Protection Division referred the site to the Inactive and Abandoned Sites Division (lASD).


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In October 1991, LDEQ's lASD notified the EPA Region 6 Hazardous Waste Management Division that MPTC warranted a Federal Assessment Investigation, and in April 1993, the LDEQ Remedial Section requested that the LDEQ Site Assessment Section perform a site assessment at MPTC. Based on the investigation results, in March 1996 the lASD requested a removal action by the EPA Response and Prevention Branch.

From September 1996 through March 1997, EPA Region 6 performed a removal action at MPTC that included (1) the offsite disposal of fluids and sludge stored in the tanks; (2) decontamination; (3) dismantling and offsite disposal ofthe tanks and retort vessels; (4) excavation of contaminated soil; and (5) placement ofthe contaminated soil in the capped Consolidation Area. Approximately 10,000 cubic yards of contaminated soil were excavated and placed into a consolidation area that measures about 280 feet by 210 feet and is surrounded by a fence. The contaminated soil was capped with a 2-foot-thick clay cover and an 18-inch-thick topsoil layer.

In April 1999, the LDEQ conducted an Expanded Site Investigation (ESI) to determine if future actions at the Site were necessary. They recommended that the Site be proposed to the National Priorities List (NPL) for fiirther investigations and potential remedial action (RA). The Site was proposed to the NPL on 22 October 1999, and added to the NPL on 4 February 2000.

The initial RI and Feasibility Study (FS) were completed in July 2001, the Record of Decision (ROD) was issued in June 2002, and the initial Remedial Design (RD) was completed in 2003. The Site is currently under consideration for flmding to implement the RA.

In December 2006, the EPA noted that implementation ofthe selected remedial technology had confronted some challenges during its implementation at other sites, and took the opportunity to conduct a reassessment ofthe proposed remedy. The findings ofthe reassessment were presented in the report titled "Independent Review Report for Marion Pressure Treating Company."

2. SITE SECURITY

The main portion ofthe Site (approximately 22 acres) is surrounded by a chain-link fence that is topped with barbed-wire and locking gates which controls access to the site. A security contractor may be provided at night during site activities associated with the RI/FSR. Storable tools, instruments, and equipment will be collected at the end ofthe shift or workday, and will be either taken offsite or stored within the secured portion ofthe site.

A sign will be posted near the gate directing all visitors to check in with the Field Manager (FM) or Site Safety and Health Officer (SSHO). A daily roster ofall visitors to the site-support area will be kept onsite during field activities. The daily roster will include: (1) date ofeach person's visit to the site; (2) person's name, organization, and signature; and (3) time of site entry and exit. A sample daily roster is included in Appendix A. Any visitors to the site must present proper identification and be authorized to be onsite. Visitors must comply with all provisions of the site specific Health and Safety Plan (HSP) (EA 2010a) for the Site. The SSHO will identify work areas that visitors or personnel are authorized to enter and will enforce site control


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measures.

The principal objectives of site security are summarized below:

• Deter, restrict, and control financial losses, as applicable, to the govemment and the contractor(s). This would include prevention or detection and reporting ofthe following:

— Theft — Vandalism — Sabotage — Arson.

• To the extent practicable, keep unauthorized people from entering the Site.

• Keep unauthorized people from entering the site-support area and removing mechanical or monitoring equipment, small tools, fuel, and stored site material.

• Keep unauthorized people from taking action(s) at the Site that might exacerbate the environmental problem or interfere with site remediation.

• Keep unauthorized people from removing file information located at the site-support area. Essential electronic data will be stored on laptop computers and will be removed from the Site every evening.

3. SITE ACCESS

The RI/FSR activities will be performed on private properties and in the Union Parish or State of Louisiana right-of-way areas. Access agreements have been obtained by the EPA with the appropriate property owners. The access agreements provide the mechanism for the contractor and its subcontractors to work in these areas on behalf of EPA. Additionally, the necessary permits and/or notifications will be obtained by the contractor from the Union Parish or State of Louisiana prior to the performance of work in these areas. The location ofthe intmsive activities shall be clearly marked, identified, and approved by the FM before the intmsive activities begin. Work areas on the Site will be restricted to EA, EPA, LDEQ personnel, subcontractors, and other appropriate personnel. No other persons will be granted access to the Site during the RI/FSR without the consent of EPA.

4. HEALTH AND SAFETY

All personnel performing excavation activities at the Site will be trained in appropriate safety procedures as set forth in the Titles 29 and 40 ofthe Code of Federal Regulations (CFR), specifically 40 CFR Part 265.16, 29 CFR Part 1910, and 29 CFR Part 1926. During non-intmsive activities, non-trained personnel (e.g., surveyors) will be allowed onsite. These personnel may be restricted to certain areas ofthe site. The regulations in 29 CFR have been enacted to ensure a safe working environment for the United States labor force. In addition, medical monitoring will be required for personnel who will come into close contact with contaminated soils.


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Work shall be performed during a period when adequate light levels are available to provide a safe working environment. Night work shall not be allowed for performance ofthe work without prior written approval from the EA project manager (PM).

All onsite personnel will be informed ofthe possible dangers and long-term hazards present at the Site in compliance with the "right-to-know" laws. The site-specific HSP will provide more specific health and safety infomiation.

5. CONTINGENCY PROCEDURES

The potential exists for natural emergencies including tomadoes, lightning, storm flooding, high winds, and extreme heat and humidity.

In the event of a fire, explosion, or accidental material release, the response action will be govemed by an evaluation ofthe severity ofthe event. The SSHO will evaluate the situation. An emergency response action will be taken if the SSHO or other representative determines that an emergency situation exists.

Flooding, fires, or other conditions may warrant evacuation of site personnel and equipment. Offsite evacuation may be necessary if fire or fiimes threaten to spread to offsite receptors.

6. WASTE DISPOSAL

Wastes generated during the RI/FSR are expected to be solid waste (soil cuttings, and personal protective equipment) and liquid waste (water generated during well development, personnel and equipment decontamination, and DNAPL). Waste disposal for each of these is described below:

• Personal protective equipment shall be removed from the Site and disposed of at a commercial disposal facility.

• Water from well development and personnel and equipment decontamination shall be collected, stored in 55-gallon dmms and removed by a contractor for disposal at a treatment plant.

• Soil cuttings generated during monitoring well installation will be secured and stored onsite and addressed during the RI field prgram.

7. GREEN REMEDIATION

Green remediation is a term characterizing cleanup programs that "use natural resources and energy efficiently, reduce negative impacts on the environment, minimize or eliminate pollution at its source, and reduce waste to the greatest extent possible" (EPA 2008). Opportunities to increase sustainability and practice green remediation will occur throughout the RI/FSR process. Appendix B provides a checklist of strategies to improve project sustainability, and it will be used by the PM to implement, suggest, and record green remediation efforts that occur during


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implementation ofthe RI/FSR. Green remediation activities observed during the RI/FSR will be included in the monthly reports.

8. MANAGEMENT RESPONSIBILITIES

Field activities associated with the RI/FSR at the Site will involve several groups and individuals. This section summarizes the roles and responsibilities ofthe groups and individuals involved.

8.1 U.S. ENVIRONMENTAL PROTECTION AGENCY

RI/FSR activities will be conducted in accordance with the Sampling and Analysis Plan (SAP) (EA 2010b). The EPA Task Order Monitor will communicate directly with the PM regarding any concems about the quality of work or scheduling.

8.2 PROJECT MANAGER

The PM will serve as the point-of-contact for EPA and will be responsible for managing the schedule, tracking project costs, and providing general project management.

8.3 FIELD MANAGER

The FM will be responsible for interfacing with the PM, the subcontractors, and site staff, documenting field activity progress, and providing quality assurance oversight of subcontractors. The FM will manage the daily activities at the Site and will coordinate communications between subcontractor, local emergency response, local govemment, EPA, and LDEQ personnel.

8.4 SITE SAFETY AND HEALTH OFFICER

The SSHO will be responsible for compliance with the site specific HSP. The FM may also serve as SSHO. The SSHO will also be responsible for providing technical coordination ofthe health and safety program, for site implementation and enforcement ofthe HSP, and for any contingency procedures. The SSHO will have advanced field work experience and will be familiar with health and safety requirements specific to the project. The SSHO will see that the safety meeting sign-off sheet is signed by all personnel who are to perform field work and who have attended the daily safety briefing. The SSHO also must have each field worker sign a daily site log before entering and leaving the site. The SSHO will designate areas requiring air monitoring. The SSHO will be the liaison with the officers and representatives of EPA on matters relating to health and safety. The SSHO will be responsible for accessing up-to-date records of HSP-related documentation and HSP participants, if needed. HSP-related documentation may include the following:

• Results ofa physician's examination ofeach project worker

• Training records for each worker relevant to his or her job


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• Results ofa fit test for workers required to wear respiratory protection equipment (meeting the requirements of 29 CFR 1910.134 and American National Standards Institute Z88.2-1980).

These records will be maintained and stored at EA offices.

Project employees who do not meet HSP requirements will not be allowed to conduct field work.

8.5 QUALITY ASSURANCE OFFICER

The EA QA Officer (QAO) will be responsible for conducting audits and reviews of all work performed. The QAO issues recommendations to the technical staff and management about quality performance. The QAO will also provide recommendations and orders, as required, for corrective action for all aspects of work that do not meet EA and EPA standards. The QAO will confirm compliance with corrective action orders and recommendations.

9. DOCUMENT MANAGEMENT

This section provides the project filing requirements.

9.1 DOCUMENT CONTROL

Control procedures will be implemented for project documents prepared by subcontractors and vendors, and by the clients for the project. Hard copies of project documents will be stored in dedicated project files and maintained in central, lockable filing cabinets in the office in which the project is managed, rather than project staff members' individual offices. This procedure will provide control and confidentiality of documents and reports. Quality records and related documents provided as hard copies will be stored in a dedicated section ofthe project file.

Each project file will contain a master list of documents, indexed to the appropriate file section. Each draft or obsolete document will be discarded or destroyed after the final or next revised draft version is completed.

Electronic versions ofall project documents will be stored on servers at the PM's home office.

9.2 DOCUMENT DISTRIBUTION

In general, documents will be distributed as needed to project personnel. For project-related documents, the PM will distribute technical procedures, drawings, and specifications. The PM will distribute this SMP and any revisions to this plan to project team members.

9.3 DOCUMENT STATUS

To prevent inadvertent use of obsolete or superseded project-related information, members of the FM's project team are responsible for reporting document changes to the PM. The PM will


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coordinate with other management team members by notifying project personnel of changes in project document status.

Outdated material will be purged to prevent fiirther use.

9.4 DOCUMENT FILING AND MAINTENANCE PROCEDURES

At a minimum, one copy ofthe following documentation will be maintained at the PM's home office or EA headquarters:

• Health and safety training and physical fitness records

• Quality assurance records

• Copies of coiTCspondence generated onsite.

In addition, relevant regulatory requirements and information such as the following will be maintained onsite at all times: (1) Material Safety Data Sheets, and (2) EPA-issued ROD.

The official EPA project file will be maintained at the PM's home office. At the completion of the project, field file information (i.e., hard copies) will be transferred to the PM's home office.

9.5 DEVIATION PROCEDURES

A continual, up-to-date change control system will be implemented for the RI/FSR. Changes from the original scopes of work and procedures are common during field activities. Change does not imply nonconformance, but instead means that original plans must be altered because of new information or events that occur during the work. Changes may have no effect on the final work product or may require redirection ofthe work so that a different result becomes necessary, as long as the end product is consistent with the ROD and the EPA-approved Work Plan.

Changes must be documented, evaluated, and reported to project management personnel. Change management ensures that the actual course ofthe project, not the original plan, can be demonstrated and justified. Project personnel will be responsible for recording changes and providing documentation to project management, quality assurance, or subcontractor management personnel. In addition, the PM will be notified of potential changes that could cause the FM to redirect the work effort.

Potential deviation and contract field change forms are the mechanisms by which changes to the project work are documented (Appendixes C and D). Deviations can result from scoping oversights, price fluctuations, or changes in productivity. Deviations do not significantly impact the project schedule or budget and do not require EPA approval; however, EPA should be notified of deviations and should participate in the corrective action, as appropriate. Significant deviations will result in the use of field change forms, which may be authorized by EPA.

Field changes result from a change in the project scope of services or facilities. Written EPA approval is required to process and proceed with the work. Field changes impact the project


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budget and indicated total cost. The PM will notify EPA of potential field changes as soon as the cause becomes known.

The following sections define and describe some conditions that require potential deviation and field change forms to be filled out.

9.5.1 Deviations

Each member ofthe project team is responsible for identifying and documenting any deviations from the current forecast or schedule; however, the PM, FM, and subcontractor supervisor are central to identifying and quantifying deviations because of their intimate knowledge ofthe project scope, estimates, budgets, and execution plan. When a condition that may result in variation from the current estimate or schedule occurs, the PM should be alerted to start the deviation process.

The initial alert that a deviation has been detected is called a "potential deviation." The key to controlling the impact ofa deviation is time; therefore, the potential deviation and a rough order-of-magnitude cost estimate ofthe impact must be provided to the PM as soon as possible (at least within 24 hours).

Completion of a potential deviation form (Appendix C) starts the deviation process. The deviation process is not complete until the deviation has been approved or corrective action has been taken and the cost arid schedule impacts are entered into the project cost system. After a potential deviation has been documented, the deviation is evaluated, which involves a more detailed analysis of impact.

The PM will maintain the potential deviation form throughout the life ofthe project. This form tracks potential rough order-of-magnitude cost impacts, approved control impacts, and schedule impacts by individual deviation and total project.

The PM and FM will be responsible for identifying and handling project deviations. Each individual should continually review the scope of work and execution plan against the design work to identify potential deviations.

9.5.2 Field Changes

If unexpected site conditions are encountered that result in the need to increase the level of effort, a field change form must be generated. Completing a contract field change form (Appendix D) starts the process. The field change form is not completed until the project budget has been adjusted and EPA has accepted or rejected the contract field change form. No work associated with the change will proceed without a properly executed and signed field change form.

Field change forms will be numbered with a three-digit sequential number and should indicate whether the change is to be processed by EPA or EA. The PM maintains a field change form log throughout the life ofthe project; the log tracks changes to the base project estimate and budgets.


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The log should identify changes to the project estimate, budget, and schedule and should include the field change form number and a brief description ofthe change.

The PM, FM, and EPA will discuss any potential changes to the scope of work. The Contracting Officer will be immediately informed ofany scope, schedule, or budget implications. Meetings will be held on a regular basis involving all key personnel to discuss changes to the scope and identify areas where field change forms may be appropriate. The PM must approve field change forms for changes that affect the basis ofthe RA with EPA concurrence.

10. PROJECT MEETINGS

The project may require up to three planned Public and/or Open House Meetings during implementation of RI/FSR activities. EA will provide support to the EPA in preparing and conducting these meetings, as appropriate. Additionally, EA will conduct an investigation/kickoff meeting and scheduled project meetings. This section discusses attendance requirements and topics for these meetings.

10.1 INVESTIGATION/KICKOFF MEETING

The PM will schedule and conduct a meeting during initial mobilization and performance of field activities. The PM, FM, SHSO and other appropriate personnel will attend the meeting. Minimum agenda items that attendees must be prepared to discuss include the following:

Introduction of representatives and their respective roles Overview of proposed field work, and methodologies/procedures for gathering data Tentative schedule Relation and coordination of subcontractors, as required Adequacy and distribution of contract documents Procedures for maintaining records Use of project premises Requirements for PPE and health and safety requirements.

10.2 PROGRESS MEETINGS

For the duration of site activities, the PM will schedule and conduct occasional progress meetings. The PM, who is responsible for maintaining accurate meeting minutes, will chair the meeting. The PM will be responsible for distributing the meeting minutes to attendees and program management personnel. The PM, FM, SHSO and other appropriate personnel will attend the meeting. Minimum agenda items that attendees must be prepared to discuss include the following:

• Review of work progress since the last meeting • Site observations, problems, and decisions • Problems that may impede planned progress


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• Safety-related observations, incidents, or potential safety problems and the corrective action(s) taken to mitigate the problem(s)

• Corrective measures and procedures to regain the planned schedule, if required • Work scheduled for the next work period.

11. AUDIT PROCEDURES

Audits ensure that the work is performed accurately, safely, and within contract and schedule constraints. This section discusses site audits, site audit reports, and health and safety audits.

11.1 SITE AUDITS

A site audit may be performed to observe general conformance with project requirements. The site audit will be performed by the quality assurance/quality control manager and the SSHO as necessary during the course ofthe project. The scope of site audit is summarized below:

• During the site audit, only general visual observations and file reviews will be performed.

• Not every element and component indicated in the SAP will be observed during the site audit.

11.2 SITE AUDIT REPORTS

A written report documenting each site audit will be prepared for the project file, and the PM, FM, and relevant subcontractor management persormel will receive copies. The report should include the following information:

• The reason for the audit, such as: (1) fiilfill contract requirements, (2) conduct a planned general observation visit, (3) resolve a constmction error or omission, (4) resolve an error or omission within constmction documents, or (5) resolve a problem.

Date and time of the audit

Weather conditions during the audit

Individuals present during the audit

Work processes observed, such as site or office work

Specific conditions observed

Specific conditions resolved or discussed during the audit

Site conditions that require fiiture investigation and resolution

Corrective action, if any, forwarded to the subcontractors through the PM and FM

Photographs taken, if any


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• Follow-up actions, if required, including identification of the party responsible for the action, and timeframe and schedule to complete the action.

11.3 SAFETY AND HEALTH AUDITS

A health and safety audit may be performed during RI/FSR activities. Additional health and safety audits will be arranged by the PM and/or FM under the following conditions:

• • Significant deficiencies are noted during the initial audit

• A lost-time accident occurs onsite

• Project management determines that an additional audit is necessary.

12. REFERENCES

EA Engineering, Science, and Technology, Inc. (EA). 2010a. "Health and Safety Plan, Remedial Investigation/Feasibility Study Reassessment, Marion Pressure Treating Company Superfund Site, Union Parish, Louisiana." Prepared for U.S. Environmental Protection Agency. October.

EA. 2010b. "Sampling and Analysis Plan, Remedial Investigation/Feasibility Study Reassessment, Marion Pressure Treating Company Superfund Site, Union Parish, Louisiana." Prepared for U.S. Environmental Protection Agency. October.

U.S. Environmental Protection Agency. 2008. "Green Remediation: Incorporating Sustainable Environmental Practices into Remediation of Contaminated Sites." April.


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Figures

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Pond, infermitfenf

' Consolidation Area

™ " Operational Boundary POTW Sump

10-acre Tract OE Overhead Electrical

a—o— Fence Exposed Water Line "—— Former Surface Impoundment ^

Dirt road ^ ^ = Culvert ——— Tanl<s

—»-»" Building Stream, intermittent Spoil Pile '.Jfi^'

?^'?*^' 1^. ,^ }.

^ ' ' * > ,

l l t f y

0 100 200 I 1 1

Feet

Image Source: U.S. Departinent of Agriculture, NAIP, Aerial Photography Field Office, 2010.

Figure 2 Site Layout Map

Remedial Investigation/ Feasibility Study Marion Pressure Treating Company

Union Parish, Louisiana

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Appendix A

Daily Roster

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DAILY ROSTER

DATE NAME ORGANIZATION SIGNATURE ARRIVAL

TIME DEPARTURE

TIME

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Appendix B

Green Remediation Checklist

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GREEN REMEDIATION CHECKLIST

1) Energy

D Use direct-push technology instead of rotary drilling rigs to reduce drilling duration avoid drilling fluids, and eliminate drill cuttings

D Purchase supplies locally

D Select suitably sized and typed equipment_

D Instmct workers to avoid engine idle and using machinery with automatic idle-shutdown

devices

D Employ auxiliary power units to power cab heating and air conditioning when a machine

is unengaged

D Perform routine, on-time maintenance such as oil changes to improve fuel efficiency

D Improve insulation properties to reduce HVAC (heating, ventilation and air conditioning)

power requirements

D Use high efficiency lighting and other high efficiency electrical equipment

2) Air Emissions

D Cover excavated areas with biodegradable fabric that can also control erosion and serve as a substrate for favorable ecosystems, or with synthetic material that can be reused for other onsite or offsite purposes

n Revegetate excavated areas as quickly as possible

D Limit onsite vehicle speeds to 10 miles per hour.

D Retrofit equipment to use low-maintenance multistage filters for cleaner engine exhaust (diesel multistage filters [DMFs] and diesel particulate filters [DPFs])

D Use cleaner fuel such as ultra-low sulfur diesel, wherever available (and as required by

engines with particulate matter [PM] traps)

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3) Impacts on Water D Use phosphate-free detergents instead of organic solvents or acids to decontaminate

sampling equipment, if not required for certain contaminants

4) Materials Consumption and Waste D Give preference to products:

i) with recycled and bio-based instead of petroleum-based contents ii) with reuse or recycling potential iii) involving nontoxic chemical altematives

D When clearing trees and undergrowth, chip and save mulch for use onsite or supply to local nurseries/gardens

D Reclaim and stockpile uncontaminated soil for use as fill or other purposes such as habitat creation

D Salvage uncontaminated objects with potential recycle, resale, donation, or onsite infrastmcture value such as steel, concrete, granite, and storage containers

D Reduce or eliminate plastic silt fencing and substitute with blankets, berms, and filterstocks made of compost for erosion control

D Retum wooden pallets and other shipping materials to the supplier whenever possible

• Take apart non-retumable wood pallets to reuse the wood or chip it for use on site for mulch

D Reuse bollards and/or protective casing from abandoned wells for new wells

D Place recycle bins near trash receptacles

D Tum off lights when not in use

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5) Impacts on Land and Ecosystems D Save seedlings during site clearing activities and replant during revegetation instead of

buying and shipping from nurseries

D Establish minimally intmsive and well designed traffic pattems for onsite activities and plans to reduce offsite traffic congestion

D Place metal grates over a thick mulch layer in onsite traffic corridors to avoid soil compaction and associated reduction in subsurface water infiltration

D Constmct long-term stmctural controls such as earth dikes and swales to prevent upgradient surface flow into excavated areas

D Install silt fences and basins to capture sediment mnoff along sloped areas.

• Use quick-growth seeding and geotextile placements to stabilize sod in staging areas

• Use organic, bio-based, or slow-release fertilizers

D Amend soils with high quality compost

Other

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Appendix C

Potential Deviation Form

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POTENTIAL DEVIATION FORM

TASK ORDER: DOCUMENT CONTROL NO.: ORIGINATOR: DATE: DESCRIPTION OF POTENTIAL DEVIATION:

CAUSE OF DEVIATION: (Client Action/Request, Internal Action/Request)

POTENTIAL IMPACTS:

APPROXIMATE ORDER-OF-MAGNITUDE COST IMPACT ESTIMATE: SCHEDULE IMPACT:

BUDGET IMPACT: DELIVERABLE(S) AFFECTED: OTHER IMPACTS:

CONTRACT FIELD CHANGE FORM REQUIRED (Check One): | YES | NO COMMENTS:

SIGNATURE:

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Appendix D

Contract Field Change Form

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CONTRACT FIELD CHANGE FORM

Project Name

Contract No.

Document Name Task Order No.

Date

Scope of Work for Field Change Form:

Reason for Action:

1 COST DATA Item Description (Attach Specifications if Necessary)

Estimated Quantity Unit

Unit Rate

Subtotal for this field change form Subtotal for all previously approved field change forms

Plus original task order budget New total (upon approval of field change form)

Line Item Total

Schedule Impact (Calendar Days): SIGNATURES

Resident Engineer Financial Manager Project Manager EPA Approval

Date Date Date Date

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