STATEMENT OF WORK
Design and Removal Actions at the Winston-Thomas Wastewater
Treatment Plant in Bloomington, Indiana
I. PURPOSE
The purpose of this Statement of Work ("SOW") is to set forth
requirements for implementation of certain removal actions for the Winston-Thomas
Wastewater Treatment Facility (hereinafter "Winston Thomas" or
"the Site") as part of the stipulation to the Consent Decree entered
in U.S. v. Westinghouse Electric Corporation, Docket Nos. IP-83-9-C
and 81-448-C, consolidated (the "Stipulation"). The Westinghouse
Electric Corporation ("Westinghouse"), now known as CBS Corporation
("CBS"), and its successors and assigns, shall follow this SOW,
the Stipulation, and the Removal Action Work Plan(s) ("RA Work Plan(s)")
approved by the United States Environmental Protection Agency ("U.S.
EPA"), the Indiana Department of Environmental Management ("IDEM"),
and the City of Bloomington (the "City")(collectively the "governmental
parties") for submitting deliverables required by this SOW and for
designing and implementing the Removal actions at Winston Thomas.
II. DESCRIPTION OF THE REMOVAL ACTIONS/PERFORMANCE STANDARDS
CBS shall plan, design, implement, operate, maintain, and monitor the
Removal actions to meet the performance standards and specifications set
forth herein and Stipulation. Performance standards shall include cleanup
standards, standards of control, quality criteria and other substantive
requirements, criteria or limitations including all Applicable or Relevant
and Appropriate Requirements (ARARs) set forth in the Action Memorandum,
this SOW, and the Stipulation. To the extent that the Action Memorandum
is incorporated into this SOW, CBS agrees to perform the work and meet the
performance standards set forth in the Action Memorandum, but does not concur
with the factual findings made by U.S. EPA in the Action Memorandum.
1. Site Security
CBS shall maintain fencing at the Site to prevent access and vandalism
to the Site. Fencing at the Site consists of a combination of woven wire
and chain link fences that encloses property containing the existing units
to be addressed in this SOW. The existing fencing is at least four-feet
high with
two-strand barbed wire above the fence. The existing fence location is
shown in Figure 1. In addition, warning signs shall be posted at the entrances
to the site. The warnings signs shall advise that the area is hazardous
due to the existence of hazardous chemicals at the site. The signs shall
also provide a telephone number to call for further information.
2. Restrictive Covenants/Deed Restrictions
Within 90 days after the entry of the Stipulation, the City of Bloomington
shall execute and record with the Monroe County recorder the restrictive
covenants identified in Appendix B of this SOW. The restrictive covenants
shall limit future site uses to uses that are not inconsistent with the
removal actions and shall prevent uses that damage, or could damage, any
of the components of the removal actions that remain on-site and serve to
contain contamination. The restrictive covenant shall prohibit the use of
the site for residential purposes and shall prohibit the human consumption
of the groundwater at the site.
3. Submittal of a Removal Action Work Plan for each of the facilities
at the Site.
CBS shall submit the RA Work Plan to the governmental parties for their
approval. Where appropriate, separate Work Plans may be submitted to address
discrete units or facilities at the Winston Thomas site. The RA Work Plan(s)
shall address each of the facilities described in this paragraph (subparagraphs
A through C below). The RA Work Plan(s) shall describe in detail how the
activities, criteria, and limitations identified in the this SOW and the
Stipulation related to each of the units or facilities at Winston Thomas
will be accomplished. The RA Work Plan(s) shall include a schedule of the
major activities identified within the RA Work Plan(s). The schedule(s)
shall contain, at a minimum, the anticipated start date, completion date,
and the expected duration for each major activity identified in such RA
Work Plan(s), as well as a schedule for the submission of all required progress
reports and work completion reports.
The RA Work Plan shall identify the location and availability for inspection
or copying of site records including, but not limited to, manifests, sampling
records, on-site meteorological data, and chain-of-custody documentation.
The facilities at Winston Thomas to be addressed by the RA Work Plan(s)
are listed (Sections A through C) as follows:
A. Tertiary Lagoon
The activities, requirements, criteria, and limitations, related to the
tertiary lagoon and to be addressed by the RA Work Plan(s) for the tertiary
lagoon are as follows:
1) CBS shall remove all of the sewage sludge in the tertiary lagoon.
The Parties estimate the volume of sewage sludge to be removed to be approximately
50,000 cubic yards of wet sludge;
2) CBS shall dewater and treat the removed sewage sludge material, as
necessary, to render the removed material suitable for acceptance by a
Toxic Substances Control Act ("TSCA") licensed and compliant,
or TSCA/Resource Conservation and Recovery Act ("RCRA") licensed
and compliant, landfill selected by CBS, and as approved by the governmental
parties, for proper disposal of the removed material;
3) CBS shall remove, treat, and properly dispose of, as necessary, the
surface water contained in the tertiary lagoon. CBS may discharge the surface
water contained in the tertiary lagoon at the City of Bloomington's Dillman
Road Waste Water Treatment Facility ("Dillman Road Facility"),
provided that the contaminant concentrations in water discharged to the
Dillman Road Facility are not greater than concentrations allowed by federal
law, including TSCA and the Clean Water Act, as well as state and local
laws and requirements. Any water discharged to the Dillman Road Waste Water
Treatment Facility will be treated and discharged in accordance with the
City of Bloomington Utilities requirements;
4) CBS shall remove the sludge material residual in the tertiary lagoon
after sludge removal and surface water removal activities have been completed;
5) In the RA Work Plan, CBS shall propose the specific techniques to
be used in finding and evaluating anomalies (irregularities in the surface
features of the clay, such as, borehole penetrations, tree roots, slumps,
animal burrows, etc,) in the clay material underlying the lagoon sludge
and shall implement such techniques upon approval of the RA Work Plan(s).
The borehole 14 area, as identified in the Consent Decree, is an anomaly;
6) In the RA Work Plan, CBS shall establish a thirty-five foot by thirty-five
foot grid system extending across the entire bottom of the clay liner in
the tertiary lagoon and also extending up the interior berm walls of the
tertiary lagoon to an elevation six inches above the top of the chlorination
chamber (located in the northwest corner of the tertiary lagoon);
7) CBS shall establish a subgrid system within each thirty-five foot
by thirty-five foot grid (described above in item #6) that provides for
the collection of four samples, each sample representing equal areas within
each thirty-five by thirtyfive foot grid. CBS shall take one sample from
within the area of each subgrid unit;
8) In the RA Work Plan, CBS shall propose the manner of collecting,
compositing, analyzing, and storing samples, necessary to ensure the following:
a) that six inch deep samples will be obtained from the center of each
subgrid area;
b) that sufficient samples are obtained to demonstrate that for each
thirty-five by thirty-five foot grid, a concentration of not greater than
25 parts per million exists within each grid as determined by the analysis
of a single sample composed of equal aliquots from each of the four subgrid
samples representing each individual grid;
c) that the arithmetic average of the PCB concentration of all of the
composited samples is less than 15 parts per million; and
d) that for any individual composite sample, the PCB concentration of
which is equal to or greater than 15 parts per million, a portion of each
subgrid sample representing that grid must be analyzed by an immuno assay
test.
e) Regarding paragraph 8(d), above, the parties agree that as work proceeds
in the field, the fifteen part per million trigger specified above may
be revised upwards by mutual agreement of the parties, provided, however,
that any revision of the trigger shall not exceed 25 ppm and that site
work will not be affected in any way, pending the approval of revision
of a trigger value.
9) CBS shall excavate the berm or clay bottom material where the following
conditions exist:
a) any subgrid area with a PCB concentration exceeding 25 ppm as demonstrated
by immuno assay test;
b) any grid with a PCB concentration exceeding 25 ppm as demonstrated
by the composite sampling described in #8(b) above; or
c) if the arithmetic average of the PCB concentration of all of the
individual composite samples taken together exceeds 15 parts per million
PCBs.
10) In the RA Work Plan, CBS shall provide the methodology for determining
that a portion of any subgrid or grid can be excavated such that the arithmetic
average of 15 parts per million and the not-to-exceed value of 25 parts
per million can be accomplished without excavating the entire area of any
subgrid or grid. If CBS cannot demonstrate, to the satisfaction of the
governmental parties, that it has adequately determined that only a portion
or portions of any subgrid or grid needs to be excavated, then CBS shall
excavate a minimum of three inches in depth across the entire grid or subgrid
with PCB concentrations exceeding the criteria identified above in item
#9.
In the RA Work Plan CBS shall also include a plan for confirmation sampling
that will demonstrate whether the cleanup criteria have been achieved in
the excavated areas.
11) In the RA Work Plan CBS shall describe the activities related to
the investigation and, if necessary, the containment or excavation of any
PCB contaminated fill materials existing in or adjacent to the original
creek channel (as existed prior to 1965), currently underlying the southern
and western portion of the tertiary lagoon. The specific requirements for
containment or disposal of the fill materials described above, shall be
established and set forth in the RA Work Plan(s) after sufficient sampling
of the fill material has been performed and after the governmental parties
have evaluated the results of testing.
12) In the RA Work Plan, CBS shall describe the activities related to
handling, loading, and transporting PCB containing material for disposal
to either a TSCA landfill, a TSCA/RCRA landfill (if appropriate), or a
Subtitle D landfill (special waste) landfill.
13) In the RA Work Plan, CBS shall provide for the preparation by CBS
of a contingency plan for the handling and treatment, if necessary, of
all subsurface water that must be removed during excavation activities
in the tertiary lagoon area and for rain water collected during excavation.
The contingency plan shall address the manner of sampling and disposing
of water collected and/or treated. CBS may discharge the surface water
contained in the tertiary lagoon at the City of Bloomington's Dillman Road
Waste Water Treatment Facility ("Dillman Road Facility"), provided
that the contaminant concentrations in water discharged to the Dillman
Road Facility are not greater than concentrations allowed by federal law,
including TSCA and the Clean Water Act, as well as state and local laws
and requirements. Any water discharged to the Dillman Road Waste Water
Treatment Facility will be sampled, treated, and/or discharged in accordance
with the City of Bloomington Utilities requirements.
14) In the RA Work Plan, CBS shall provide for and describe the activities
related to closure of the Tertiary Lagoon area after completion of the
removal actions, including, but not limited to grading and contouring the
bottom clay to provide for adequate drainage of rain water and to avoid
ponding of rain water within the lagoon after excavation activities have
been completed; use of a soil cover of clean fill material to back-fill
excavated areas; planting of suitable vegetation for erosion prevention,
etc. The closure plan shall also include provisions to assure that all
surface water that drains to Clear Creek meets federal, state, and local
water quality laws and standards.
15) In the RA Work Plan CBS shall provide for six inches of soil cover
initially in the tertiary lagoon. The requirement for the initial six inches
of soil cover may be modified for any portion or portions of the tertiary
lagoon after excavation (a) if CBS demonstrates to the parties that PCB
contamination levels are below 1 ppm, in which no soil cover shall be required
for applicable portion or portions, or (b) to account for grading as described
below. if modifications to the initial six inch requirement are made, some
soil cover may be necessary for purposes of erosion control and support
for a vegetative cover which may be reflected in the approved Plan discussed
below. within thirty days after excavation and sampling are completed,
CBS shall provide the parties with its "Soil Cover Plan" for
their review and approval, which may include a request for variances. The
On-Scene Coordinator may grant CBS additional minor variances to the soil
cover approved under the Plan.
An additional six inches of soil cover must be applied by CBS within
two years after completion of the excavation in the tertiary lagoon unless
(a) the City of Bloomington has started construction on a future use for
the tertiary lagoon which would make additional cover unnecessary, or (b)
CBS has presented data and information clearly demonstrating that leaving
the existing soil cover over the tertiary lagoon will not result in a threat
to human health or the environment.
Prior to installing any additional soil cover, CBS will submit a "Supplemental
Soil Cover Plan" for the parties' review and approval, which may include
a request for variances. if appropriate, and if there is a demonstration
by CBS of a lack of threats posed by any PCBs remaining in the tertiary
lagoon, then the additional six inches of soil cover may no longer be required,
and U.S. EPA may amend the response action required by the Action Memorandum.
Such a demonstration by CBS may include the City's plans for future use
of the tertiary lagoon. U.S. EPA may also modify the requirement for an
additional six inches of soil cover for any portion or portions of the
tertiary lagoon to account for grading. The On-Scene Coordinator may grant
CBS additional minor variances to the soil cover approved under the Supplemental
Plan.
With respect to the initial and additional soil cover requirements described
above, one-half of the requisite soil necessary for each phase shall be
provided by the City and the remaining one-half by CBS. CBS will be responsible
for applying the soil at the site.
If a dispute arises among or between the parties with regard to initial
or additional soil cover requirements, such disputes shall be resolved
in accordance with the provisions of Section 113 of the Consent Decree
which shall be available and applicable to CBS as well as the governmental
parties.
16) CBS shall have the obligation to maintain the fence at the site,
control erosion and drainage at excavated areas, and maintain vegetative
covers until such time as a final cover is placed over the tertiary lagoon
and the site is turned over to the City of Bloomington. Until such time,
CBS shall submit annual post closure reports.
B. Abandoned Lagoon Area
CBS shall perform removal actions at the abandoned lagoon area. The activities,
requirements, criteria, and limitations, related to the abandoned lagoon
area and to be addressed by the RA Work
Plan(s) to be prepared by CBS for the abandoned lagoon area are as follows:
1) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to the initial excavation as describe
in II.B. of soils containing PCB concentrations of 25 ppm or greater in
the area described in Attachment "A" to this SOW;
a) The RA Work Plan(s) shall provide for the establishment of a twenty-five
foot by twenty-five foot grid system extending across the entire area shown
in Attachment "All to this SOW.
b) CBS shall describe in the RA Work Plan(s) the activities related
to the establishment of a subgrid system within each twenty-five by twentyfive
foot grid (described above in item #1-a) that provides for the collection
of four samples, each sample representing equal areas within each twenty-five
by twenty-five foot grid.
c) In the RA Work Plan(s), CBS shall propose the activities, protocols,
and procedures related to collecting, compositing, analyzing, and storing
samples, necessary to ensure the following:
i) twelve inch deep samples will be obtained from the center of each
subgrid area;
ii) that sufficient samples are obtained to demonstrate that for each
twenty-five by twenty-five foot grid, a concentration of not greater that
25 parts per million exists within each grid as determined by the analysis
of a single sample composed of equal aliquots from each of the four subgrid
samples representing each individual grid; and
iii) that the arithmetic average of the PCB concentration of all of
the composited samples is less than or equal to 15 parts per million;
2) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to the treatment of the excavated material,
as necessary, to render the material suitable for acceptance by the TSCA
or TSCA/RCRA landfill selected by CBS, and as approved by the governmental
parties, for proper disposal of the excavated material;
a) In the RA Work Plan(s), CBS shall describe the activities related
to the excavation of PCB containing material, remaining after the initial
excavation described in II.B.1, where the following conditions exist:
i) any grid with a PCB concentration exceeding 25 ppm as demonstrated
by the composite sampling described in #1-b above, or
ii) if the arithmetic average of the PCB concentration of all individual
composite samples together exceeds 15 parts per million PCBs.
b)The RA Work Plan(s) for the abandoned lagoon area must contain a description
of additional confirmation sampling in the areas (and to the elevations)
specified in Attachment "A-1" to this SOW to confirm that PCB
concentrations consistent with this paragraph have been achieved through
the abandoned lagoon area.
3) As part of the RA Work Plan(s) CBS shall prepare a contingency plan
for the handling and treatment, if necessary, of any subsurface water that
must be removed during excavation activities in the abandoned lagoon area
and rain water collected during excavation. The contingency plan shall
address the manner of sampling and disposing of water collected and/or
treated. CBS may discharge the water at the City of Bloomington's Dillman
Road Waste Water Treatment Facility ("Dillman Road Facility"),
provided that the contaminant concentrations in water discharged to the
Dillman Road Facility are not greater than concentrations allowed by federal
law, including TSCA and the Clean Water Act, as well as state and local
laws and requirements. Any water discharged to the Dillman Road Waste Water
Treatment Facility will be treated and/or discharged in accordance with
the City of Bloomington Utilities requirements;
4) CBS shall describe in the RA Work Plan(s) any proposed methodology
for determining that a portion of any grid or subgrid can be excavated
such that the arithmetic average of 15 parts per million and the not-to-exceed
value of 25 parts per million can be accomplished without excavating the
entire area of any subgrid or grid. The RA Work Plan(s) shall provide that
if CBS cannot demonstrate, to the satisfaction of the governmental parties,
that it has adequately determined that only a portion or portions of any
grid need be excavated, then CBS shall excavate a minimum of twelve inches
in depth across the entire twenty-five by twentyfive foot grid containing
PCB concentrations exceeding the criteria identified above in item #2.
Confirmation sampling shall be required in areas where additional excavation
occurs.
5) CBS shall describe the activities related to handling, loading, and
transporting PCB containing material for disposal to either a TSCA landfill,
a TSCA/RCRA landfill (if appropriate), or a RCRA Subtitle D landfill (special
waste) landfill;
6) CBS shall describe the activities related to grading and contouring
the abandoned lagoon area identified in Attachment "A-1" to provide
for adequate drainage of rain water and to avoid ponding of rain water
within the area after excavation activities have been completed;
7) In the RA Work Plan(s), CBS shall describe the activities related
to isolating the spring water that resurges within the &rea identified
in Attachment "All to this SOW from PCB containing soils or materials
on the Site; and
8) CBS shall describe all of the activities related to the placement
of a twelve inch thick soil cover, capable of supporting vegetation, over
the area described in Attachment "A". The RA work Plan(s) for
the abandoned lagoon area shall include a description of the grading to
be performed to provide adequate drainage and to avoid ponding of rain
in the abandoned lagoon area. The RA Work Plan(s) shall also describe the
type of vegetation to be placed over the area and the manner of placement
of the seeding.
C.Trickling Filter
The activities, requirements, criteria, and limitations, related to the
trickling filter to be performed by CBS and to be addressed by CBS in the
RA Work Plan(s) for the tricking filter are as follows:
1) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to the removal and washing of the rock
filter media contained in the trickling filter. The rock filter media shall
be washed and decontaminated to the specifications required by 40 C.F.R.
Section 761,125 depending upon future use of the rock filter media.
2) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to the removal and sampling of sediment,
rock fragments, and other waste material, and drainage blocks for disposal
to either a TSCA landfill, a TSCA/RCRA landfill (if appropriate), or a
RCRA Subtitle D landfill (special waste) landfill. The RA Work Plan(s)
for the trickling filter shall describe whether the drainage blocks will
either be appropriately landfilled or decontaminated by washing in a manner
similar to that previously described in C(1) of this SOW;
3) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to highpressure spray washing of the
walls and floor of the trickling filter. At its option, CBS may first sample
these areas, and if the sampling demonstrates that the areas already meet
the criteria of 10 ug/100cm2, then no washing will be required.
4) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to the sampling, decontamination, or
disposal of all piping in the trickling filter;
5) The RA Work Plan(s) shall describe the activities, requirements,
criteria, and limitations related to the collection, treatment and disposal
of all wash fluids and rain water collected in the trickling filter before
removal actions are completed. Wash water or rain water, collected in the
trickling filter prior to the completion of removal actions associated
with the trickling filter, may be discharged to the Dillman Road Facility
provided that the contaminant concentrations in water discharged to the
Dillman Road Facility are not greater than concentrations allowed by federal
law, including TSCA and the Clean Water Act, as well as state and local
laws and requirements. Any water discharged to the Dillman Road Waste Water
Treatment Facility will be sampled, treated, and/or discharged in accordance
with the City of Bloomington Utilities requirements;
4. Installation and Operation of Monitoring Programs for Removal Action
CBS shall implement monitoring program(s) to evaluate and ensure that
the construction and implementation of the Removal actions comply with approved
plans and design documents and performance standards. CBS shall submit monitoring
programs as part of the RA Work Plan(s). The monitoring program(s) shall
address the specific components of the Removal actions listed below. Each
sample shall be analyzed for a list of parameters approved by the governmental
parties and consistent with the Support Sampling Plans identified in the
Action Memorandum, this SOW, or the Stipulation for this Site.
A. Groundwater Monitoring
CBS shall implement a groundwater monitoring program for the Winston
Thomas Site. The groundwater monitoring program for the Site will be addressed
in a separate RA Work Plan. The groundwater monitoring RA Work Plan shall
be submitted by CBS, to the Governmental Parties for their approval, within
60 days after submittal of the Completion of Work Report required by this
SOW. The groundwater monitoring program will address the number and placement
of monitoring wells, the chemical and physical parameters to be sampled,
and the frequency and duration of sampling to be conducted, as well as the
period of time that the sampling will continue. The purpose of the groundwater
monitoring program is to determine whether groundwater contamination has
occurred, and to ensure that no off-site migration of contaminated groundwater
is occurring. In the event that at any time in the future it is determined
that groundwater contamination related to this site may occur or is occurring
and/or migrating off-site, U.S. EPA and/or the other Governmental Parties
may require that CBS undertake additional removal activities to address
such contamination and/or migration, provided that if a dispute arises among
or between the parties with regard to whether such contamination or migration
is related to this site and whether any additional removal activities, or
any specific removal activities, are necessary to protect human health or
the environment, then such disputes shall be resolved in accordance with
the provisions of Section 113 of the Consent Decree which shall be available
and applicable to CBS as well as the governmental parties.
B. Air
The RA Work Plan(s) submitted by CBS shall provide for the submission
of an air monitoring plan, which shall describe the activities, requirements,
criteria, and limitations related to air monitoring. The air monitoring
plan submitted pursuant to the RA Work Plan(s) shall provide, at a minimum,
that during days when excavation, handling, or loading of PCB containing
material associated with the tertiary lagoon, the abandoned lagoon, and
the trickling filters occurs, ambient air monitoring for PCBs shall be performed.
Ambient air sampling shall be conducted through the use of high-volume air
sampling devices fitted with polyurethane foam plugs. CBS shall conduct
a sufficient duration of sample collection to achieve a detection limit
of approximately one nanogram per cubic meter of air sampled.
The air monitoring program described in the air monitoring plan submitted
pursuant to the RA Work Plan(s) shall identify specific actions to be taken
at the site to minimize air borne PCBs.
Specific actions to minimize air borne PCBs shall include, but are not
limited to, misting of PCB containing materials during excavation, loading,
or handling operations, reduction of work activities causing the generation
of PCB containing dust, covering of PCB containing materials with plastic
or tarps, and cessation of work activities causing the PCBs to become airborne.
The initiation of the specific actions identified in the air monitoring
plan shall begin when measured PCB air concentrations exceed the action
limit of 1 microgram of PCBs per cubic meter of air sampled. The air monitoring
plan shall describe the escalation of specific actions to be taken, commensurate
with measured PCB concentrations, to avoid an exceedance of the 1 microgram
of PCBs per cubic meter of air action level. Air samples must be analyzed
and the results available to field personnel within three days of collecting
the air sample.
The air monitoring plan shall also provide for the collection of on-site
meteorological data to assist with the evaluation of sampling and analysis
of air samples. Such meteorological data shall include wind direction and
speed, the frequency of changes in wind direction, and air temperature.
The meteorological data shall be recorded and interpreted on-site and made
available for inspection, upon request of an authorized representative of
any of the governmental parties.
The air monitoring plan shall include a provision for controlling dust
emissions, including dust from drying agents used to treat moist soil or
material. The air monitoring plan shall include a novisible emission limit
(except if one of the conditions of IAC 6-46 - Fugitive Dust Emissions exceptions
are met), as determined at the Site boundary, for dust, including lime kiln
dust (Calcium Oxide). The air monitoring plan shall identify specific precautions
to be followed in order to avoid releases of visible emissions of lime kiln
dust when it is handled, loaded, unloaded, or mixed with other materials
on-site.
III. SCOPE OF REMOVAL DESIGN AND REMOVAL ACTION
The removal actions shall consist of three tasks. All plans and reports
are subject to the approval of the governmental parties.
Task 1: Removal Action Work Plan
Task 2: Removal Action/Construction
Task 3: Reports
1. Monthly Progress Status Reports
2. Completion of Removal Action Report
3. Completion of Work Report
Task 1: Draft Removal Action Work Plan
CBS shall submit a set of work plans which shall document the overall
management strategy for performing the design, construction, operation,
maintenance and monitoring of Removal actions for review and approval of
the governmental parties. The plans shall document the responsibility and
authority of all organizations and key personnel involved with the implementation
and shall include a description of qualifications of key personnel directing
the Removal Design, including contractor personnel. The Work Plans shall
also contain a project schedule for each major activity and submission of
deliverables generated during the Removal actions.
This RA Work Plan(s) shall include, at a minimum, any necessary amendments
to the QAPP for the Consent Decree sites, a Health and Safety Plan, and
a Field Sampling Plan and schedule to further delineate the extent of contamination
in soil and sludge material in the abandoned lagoon area.
Task 2: Removal Action/Construction
CBS shall implement the removal actions as detailed in the approved Removal
Action Work Plan(s).
For the removal actions, CBS shall submit a Completion of Work Report
by the date identified in Section V. In the Completion of Work Report, CBS's
Project Coordinator shall certify that the removal actions have been completed
in full satisfaction of the requirements of the Action Memorandum, this
SOW, the Stipulation, and the approved RA Work Plan(s). The report shall
contain the following statement, signed by a responsible corporate official
of CBS or CBS's Project Coordinator that "To the best of my knowledge,
after thorough investigation, I certify that the information contained in
or accompanying this submission is true, accurate and complete. I am aware
there are significant penalties for submitting false information, including
the possibility of fine and imprisonment for knowing violations."
IV. CONTENT OF SUPPORTING PLANS
The documents listed in this section -- amendments to the existing Quality
Assurance Project Plan (QAPP), Field Sampling Plans, the Health and Safety
Plan -- are documents that shall be prepared and submitted, for approval,
as outlined in Section III of this SOW. The required contents of each of
these supporting plans are listed below.
A. Amendments to the Quality Assurance Program Plan
Not later than forty-five days prior to starting on-site activities at
Winston-Thomas, CBS shall develop any necessary amendments to the existing
QAPP, to address sample analysis and data handling for samples collected
in all phases of future Site work for each relevant facility or unit, based
upon the requirements provided in the Action Memorandum, this SOW, and consistent
with the approved RA Work Plan(s) to be submitted for this project.
B. Health and Safety Plan
Not later than forty-five days prior to starting on-site activities at
Winston-Thomas, CBS shall develop and submit to the governmental parties
for approval a health and safety plan designed to protect on-site personnel
and area residents from physical, chemical, and all other hazards posed
by the removal actions. The safety plan shall develop the performance levels
and criteria necessary to address the following areas:
Facility Description
Personnel
Levels of protection
Safe work practices and safe guards
Medical surveillance
Personal and environmental air monitoring
Personal protective equipment
Personal hygiene
Decontamination - personal and equipment
Site work zones
Contaminant control
Contingency and emergency planning
Logs, reports and record keeping
The safety plan shall follow U.S. EPA guidance and all OSHA requirements
as outlined in 29 CFR 1910 and 1926.
The plan shall also describe procedures to be used in the event of an
accident or emergency at the site, and the manner in which previously unknown
or undiscovered hazardous wastes or substances that are discovered during
the course of the removal actions will be addressed. The following shall
be included:
1. Name of the person or entity responsible for responding in the event
of an emergency incident.
2. Plan and date(s) for meeting(s) with the local community, including
local, State and Federal agencies involved in the cleanup, as well as local
emergency squads and hospitals.
3. First aid medical information.
4. Air Monitoring Plan.
5. Plan(s) for treatment or disposal of contaminated materials in the
event of discovery of areas of contamination not previously known or disclosed
through prior sampling.
C. Field Sampling Plan
CBS shall develop field sampling plans and shall supplement the QAPP
and address all sample collection activities. Additional sample collection
is necessary for the tertiary lagoon, abandoned lagoon area, and the trickling
filter as described above in Section II.
V. SUMMARY OF MAJOR DELIVERABLES/SCHEDULE
A summary of the project schedule and reporting requirements contained
in this SOW is presented below:
|
Submission |
Due Date |
1. |
Completion of Removal Action One report due for each of the three
Report units. Each report due within 45 days following the completion of
all removal actions taken in the respective unit, as specified in the RA
Work Plan for each of the units. |
|
| A) The tertiary lagoon |
|
| B) the abandoned lagoon area |
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| C) the trickling filter |
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2. |
Completion of Work Report |
Due 60 days after the completion of all site work specified in the
RA Work Plan for the unit actually completed last |
The following maps and legal documents were scanned into Adobe pdf format.
Some resolution was lost. The originals are in the public repositories in
Bloomington, Indiana.
Figure 1: Fences at Winston Thomas Wastewater
Treatment Facility.
Attachment A: Sampling Locations and Results
for PCB Field Screening and Offsite Laboratory Analysis in the Abandoned
Lagoon Area.
Attachment A-1: Approximate Altitudes of Bottoms
of Abandoned Lagoons at Winston Thomas WTP.
Attachment B: There are three legal documents in draft form transferring
title of the land associated with the Winston Thomas Waste Water Treatment
Plant from the City of Bloomington, Indiana and Utilities Services Board
of the City of Bloomington Indiana to the Utilities Service Board of the
City of Bloomington, Indiana with deed restrictions.
1. Draft Warranty Deed
2. Draft notarized statement that President
of Utilites Service Board executed above deed.
3. Draft notarized statement that President
and Secretary signed the above deed and are aware of restrictions in new
deed.
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