HomeMy WebLinkAbout12567-CI-CLNT-ENVT Rqmts for Superfund SITE-2003-05-05
INTEROFFICE COMMUNICATION
CAT. NO. 4487
CORPORATE ENVIRONMENTAL DEPARTMENT
May 5, 2003
To: D. D. Bennitt
Cc: R. E. Bangert II
V. L. ZumBrunnen
From: L. C. Robbins
Subject: Requirements related to the PDS Renton Superfund Site
Environmental requirements related to the PDS Renton Superfund site follow. Please note
however that this year, Ecology is due to review 5 years of groundwater monitoring data to
determine if the site clean-up is performing as planned. The environmental requirements for
redevelopment of the property may change as a result of this review. Costs for compliance with
these requirements must be charged to the redevelopment project budget.
1. Both soil and groundwater may be contaminated and thus grading, excavation or trenching
of soil below the minimum 12 " structural cap must be conducted by a contractor that is
trained and conducts the work in accordance with WAC 296-62-300, Hazardous Waste
Operations and Emergency Response. A Health and Safety Plan will be needed. See
attached Heath and Safety Requirements applicable to any work performed below the level
of the structural cap.
2. Soils greater than 12" in depth must be assumed to be contaminated. If the site soil is visibly
clean and can be re-used on-site it must be stockpiled in a manner that prevents dust and
stormwater contact including plastic sheeting underneath, and a cover each evening and
during weather conditions that may result in dust or stormwater impacts. Berms should be
used to avoid excessive stormwater contact with potentially contaminated soil. Erosion,
stormwater and dust control plans will be needed. If the potentially contaminated but visibly
clean soil is not re-used on-site, the soil stockpiles must be sampled with a 5-point
composite sample for each individual stockpile or for each 500 cubic yards within a single
stockpile, whichever is more, and tested for proper disposal. Soil stockpiles should be
segregated in a manner that prevents contamination of clean soil and minimizes disposal
costs. CED must pre-approve the disposal site(s). Copies of all test results, shipping papers
and the final disposal site must be provided to CED. Off-site disposal of more than 200 cubic
yards of potentially contaminated soil in any 3 month period must be pre-approved by CED
and Ecology.
3. If visibly contaminated soil, debris or groundwater is encountered, CED should be notified
immediately. With approval from CED, proceed with Hot Spot Removal Action (HSRA) for
visibly contaminated soil as detailed in Item 15. Removed groundwater should be stored in a
portable Baker tank. Visibly contaminated debris must be stockpiled on plastic and covered
each evening or if weather conditions are such that wind or stormwater could contact and
mobilize any contaminated soil that is adhering to the debris. Berms should be used to
prevent excessive contact of stormwater runoff with potentially contaminated debris.
May 5, 2003
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4. Backfilling is allowable with either clean imported fill or visibly clean site soils. However,
unless testing is performed to confirm that the visibly clean site soils meet MTCA clean-up
levels, the site soil backfill must be covered with a minimum 12 " of clean imported backfill
even under buildings or paved areas. Where the structural cap is disturbed it must be
repaired or replaced to a minimum depth of 12 ", even under buildings or paved areas.
5. Excavations and trenches that may require future access for maintenance or repairs such as
stormdrains or utility trenches must be lined with a geotextile as a marker and backfilled with
clean imported fill.
6. Avoid collecting excessive stormwater in trenches and excavations with berms and other
surface water diversions.
7. Contact CED if free-product or a sheen is visible in any encountered groundwater. With
verbal approval from CED, collect the free-product or sheen with absorbent materials and
properly dispose.
8. Potentially impacted soils and groundwater must not be stored south of the Aquifer
Protection Zone. See attached Figure 2.
9. The dust control plan must include dust control measures such as water spaying for all
operations that could generate dust. No visible dust is allowed.
10. A soil erosion plan is required to prevent erosion due to stormwater runoff or run-on from
excavations, stockpiles, graded areas or other exposed site soils. Measures such as berms,
straw bails, plastic covers and other means must be taken to control soil erosion.
11. Measures must be taken to protect site groundwater monitoring wells. CED must be notified
of any well damage. The contractor shall be required to properly abandon and replace to
meet or exceed original conditions, any damaged wells.
12. Site access shall be limited. No access will be allowed to the other parts of the PDS
Superfund site. Any damage to the structural cap will be the responsibility of the contractor.
If the existing access gate and road are damaged or removed the contractor will be asked to
replace to meet existing conditions or better.
13. Site equipment that contacts potentially contaminated soil must be washed prior to leaving
the site. Wash water must be collected for proper disposal.
14. Sales tax exemptions apply to remediation projects in Washington State under some
circumstances. The contractor should be asked to apply for any application sales tax
exemptions if remediation efforts such as disposal of contaminated soil or groundwater are
required. The contractor may need a copy of the Consent Decree in applying for sales tax
exemptions. PACCAR will make copies of the Consent Decree available upon request.
May 5, 2003
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15. Hot Spot Removal Action (HSRA): If visibly contaminated soil is encountered a
representative sample should be taken and analyzed for the Hot spot Action Levels (HSAL)
provided below in accordance with the EDR Vol C.:
Soil
Constituent
HSAL
(mg/kg)
Prep Method Analytical Method
TPH 2,500 SW 3550 EPA 8015 Modified
CPAH 100 SW 3550 EPA 8310
Lead 3,000 SW 3050 EPA 6010
Chromium 600 SW 3050 EPA 6010
Arsenic 100 SW 3050 EPA 6010
PCB 7 SW 3580 EPA 8080
If any of the HSAL are exceeded the soil must be excavated and properly disposed off-site.
Excavate until visible contamination has been removed and then confirm residual (not
excavated) soils are below the HSAL. Confirmational soil samples must be taken from the
bottom and sidewalls of the excavation as shown in Figure 1. Hot spots will be sampled on a 10
foot grid. One four point composite sample will be taken for each 800 square foot excavated
bottom. One four point composite sample will also be taken for each 40 linear feet of side wall
per layer of strata. Subsamples will be collected at midpoints of the strata. If the composite
samples exceed a HSAL then excavation will continue until confirmational samples are below
HSAL. However, excavations will not be continued vertically below an underlying protective silt
layer.
Pending disposal all soils exceeding HSAL must be stored in bermed, lined and covered
stockpiles such that wind or stormwater will not contact and mobilize the contaminated soil.
Berms should be used to prevent excessive contact of stormwater runoff with contaminated soil
stockpiles. Soil stockpiles should be segregated in a manner that prevents contamination of
clean soil and minimizes disposal costs. For disposal purposes, a 5 point composite sample will
be taken for every 500 cubic yards of stockpiled soil. CED must pre-approve disposal sites.
Copies of the shipping papers (manifests) test results, and disposal location must be provided to
CED. Pre-approval from CED and Ecology is required for off-site disposal of greater than 200
cubic yards in any three-month period. Proper storage on-site is required prior to disposal.
May 5, 2003
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