united states environmental protection agency · 2019-11-24 · 0 3301 : dear mr. ro y: epa and...

11
l UNITED STATES ENVIRONMENTAL PROTECTION AGENCY IIIIOION I H . ltiNNI D'f' flDIIIAL IUILDINQ, I OITON, MAISACHUilnS 02203·2211 January 25, Mr. Thomas Roy I I Ar ies Engineering, Inc. 46 South Ma i n Street Concord, NH 0 3301 Dear Mr. Ro y: EPA and NHDES have compl eted the review of t.he 100\" Remedial Design submitted by Golder Ass oci a tes for the Coa kl ey Landfill Group in accordance with Section F. 3 of the Consent Dec ree Scope o f W ork. There are three eignificar.t po ints which need to be emphasized: 1) t he design is approved , 2 ) how ever, I expect the gas collection and treatment system to be rede•igned to reflec t the request by the Coakley Landfill Group to change to a passi ve gas collection and venting system, and 3l the groundwater monitoring plan needs further modification/ clarification prior to· approva l a nd implementation. Each point is d i scussed below. Dedgn Approval As with the: 95\ design approval there are i ss ues that you w ould be p rud ent to explore in or der to improve the biddability of the design package. These issues are provided as comments in an enclosure to this letter. Of part icular concern is the: de:sign schedule, made more problemati c by the intended redesign of the gas coll ection system. Firm dates need t o be established quickly a nd preferabl y without missing any construction aaa Collec tion Syat- I t is my understanding tha t NHOES has approved , in concept, the use of a passive gas collection system at the Coakley Landfill. Since the potential f or o ff-site migration of landfill gases wa: the impe:us f o r requir ing an extraction and treatment system in the Record of Decision , I cannot approve a redesi gn u nt il you c assure EPA (through documl!!:ntary ev idence ) that the pas s ive co llec tion system c an preve:nt unacceptable off - s itl!!: migration c landfill gases . Furt hermorl!!: , mo ni toring of the vents must be abll!!: to ensurl!!: compl iance with pl!!:rtinent ARARs and the c hanges re:flect ed in a revised segment off the Environment al M onitori ng Plan. As indi c ated above , a rev ised schedule ref lec ting thi s de:sign c hange, al so, needs t o be developed . n Q > = = en

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Page 1: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

l

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

IIIIOION I

H ltiNNI Df flDIIIAL IUILDINQ I OITON MAISACHUilnS 02203middot221 1

January 25 19bull9~

Mr Thomas Roy I I

Aries Engineering Inc 46 South Ma i n Street Concord NH 0 3301

Dear Mr Ro y

EPA and NHDES have completed the review of the 100 Remedial Design submitted by Golder Associa tes for the Coa kley Landfill Group in accordance with Section F 3 of the Consent De c ree Scope o f Work There are three eignificart po ints which need to be emphasized 1) t he design is approved 2 ) however I expect the gas collection and treatment system to be redebulligned to reflec t the request by the Coakley Landfill Group to change to a passive gas collection and venting system and 3 l the groundwater monitoring plan needs further modification clarification prior tomiddot approva l a nd implementation Each point is d i scussed below

Dedgn Approval

As with the 95 design a pproval there are i ssues that yo u would be p rudent to explore in o r der to improve the biddability of the design package These issues are provided as comments in an enclosure to this letter Of part icular concern is the design schedule made more problematic by the intended redesign of the gas collection system Firm dates need t o be established quickly a nd preferabl y without missing any construction

aaa Collec tion Syat-

I t is my understanding that NHOES has approved in concept the use of a passive gas collection system at the Coakley Landfill Since the potential f or off-site migratio n of landfill gases wa the impeus f o r requiring an extraction and treatment system in the Record of Decision I cannot approve a redesig n unt il you c assure EPA (through documlntary evidenc e ) that the pass ive collec tion system c an prevent unacceptable off - s itl migration c landfill gases Furt hermorl mo ni toring o f the vents must be abll to ensurl compl iance with plrtinent ARARs and the c hanges reflected in a revised segment off the Environmental Monitoring Plan As indicated above a rev ised schedule ref l e c ting thi s design c hange also needs t o be developed

n Q gt = = en

shy

Groundwater Moni taring Plan

Based upon our telephone conversat i o n middotJ f January 9 1996 the groundwater moilitpring segment of the Environmental Monito ring Plan does lOt seem t o reflect your understanding of well abandonment and sampling no r does it appear to have responded to my comments of Oct o ber 17 1995 with the exception of t he water level monitoring Specific comments are enclosed I would like a revised plan which ~ responds to these and the previous comments To reiterate what I had expected to be reflected in thi s version of the EMP as stated in the October 17 letter

As always if you have any questions regarding a ny of these comments please contact me a t (617) 573-9628

Sincenly

4vl)~ Roger F Ouwart Remedi a l Project Ma nager NHRI Superfund Section Office of Site Re mediat ion a nd Restoration

enclosures

Talcott Hubbard NHDES James Philcox Weston Dave Allen City of Po rtsmouth Al Macdonald Golder

~

bull ~ ~

bull~

0 ii m

s ~

~ij n ~~~ ~~~ ~ ~ ~~~ GPipzmr 8~ sect~ m

n Q gt = = m

r

100 DESIGN COMMENTS

COULEY LANDFILL SUPERFUND SITE

GENERAL COMMEtJi

The Final Design Re port FOR) does not in itself prov i de a comprehensive desig n package which furn i shes the information ne c essary to support the anal ysis o f compliance with Performance Standards identified in the Pre-Design Report a s r equned by the Consent Order Scope of Work tSOW) [Section F 3 a (2 ) t d l l Comple t e d a t a a nd engineeri ng c a lcu lations prepa red t o suppo rt comp l iance wit h the Perfo rmanc e St a ndards are not part of the 100 de s i g n p a c kage as def i ned by Artic le 2 o f t he Envnonmenta l Remed iation Contractor Agreement Inste ad t he r e ader is frequently c r oss- referenced t o one o f the draf t des ign reports All of these draft submittals have re c eived s i gn i f ican t comme nts from the US Environmental Pro tectio n Agency (EPA ) and Ne w Ha mpshire Department of Environmental Services (NHDES ) Whi l e they hav e been accepted by EPA these acceptances have been ma de in the context that the drafts have met the intent of t he SOW milestones not that they are technically complete or meet the fu ll requirements of the Record of Decision (ROD )

Due to these cross-references in the final design submittal all three draft documents would have to be made available to create a final comprehensive design package Thi s is not cons idered idea l due to redu ndancy and t he potential for conf usion which ma y result from the incons i stenci e s between the documents It is recommended that cross-references to informa tion in other design reports be replaced by the inclusion of specific info rma t i o n as appendices to the FOR prior t o going out to b i d

SECTION 4 CONSOLIDATION OP SEDIMENTS WETLANDS RESTORATION

27 Based on the dimensions provided (Drawi ng 5- 24 ) appears as though insuffic i ent s t r uctu ra l f ill m exis t o ver the pro po sed c ulverts (6 N of No 57 s t one and a s bull o f Type C grading f ill) cons i de ri ng t he numle r of fu lly loaded truc ks a n ticipa ted to construct that cap This along with a ny poor subgra de materials remaining in tl area may lead to increased ma intena nce requ ire ments which could further impact the adj a ce nt wetl a nds subsequent to initial construction

n Q = = en

28

l

To help provide a more complete final design package all r equi r ed permit f o rms should be ~ttached t o the FDR

SPECIFICATIONS

02936 l0 4A Will this paragraph of the specification affect any i~terpretation of adequate percent cover for the Wetland Mi tigation requirements or requireme~ts of specificat i on 02936-4

paragraph 3 08

02937 2 06E The FOR text indicates that transplants may come f rom o ff -site wetlands ye t the text o f this specific a tion appears to contradict this It is recommended that words only and small amourt s i n the specification be clarified

APPENDIX 1 ENVIRONMENTAL MONITORING PLAN

Consider including estimated cover monitoring for a subset of individual shrubs and trees by measuring width and extent of canopy There will likely be differences among planted species which will be useful in replanting (if necessary) and determining which planted species are most s uccessful at both survival and growth

For clarity Figures 2-1 through 2-3 should be referenced in the order that they appear in the text

10 Will the photographic stations be established at each plo t being used f o r p l ant coverage evaluations

10 There is a discrepancy regarding the frequency monitoring being i mp lemented according to t he F a nd t hat needed to lnsure performance standards are met This paragraph indicates that moniton efforts will be the most intense during the firs t wo ylars yet the rest of the text does not support this statement requirement Consistenc~

n Q

= en=

amo ng sect i ons a nd a table with thO p r op o s e d mon itoring time l i ne f o r each pa r a meter

veget at 1on aquat ic macro invertebra tes middot wildli fe wate r table ma i n te nance activitie5

etc ) would be ve ry us eful

12 In the e ven t that the g r oundwate r pump-and-treat system is not constructed a djacen t wetland monitoring would still be required to evaluate the impact that other remedial actions may have on ad j acent wetlands

14 The wetland mo nitoring prog ram i s to be initlated once r estora tion of t he we tl ands ha s been complet ed In i t i a tion o f the moni to r i ng p rog r am sho u l d not be s che duled in rel a tio nsh i p t o t he imp leme ntat ion o f t he groundwater co l l e c tio n a d r echarge s ystem

SECTI ON 5 CAPPING OP THE LANDFILL

SPICIPICATI ONS

02215middot3 No requirement s for covering the re located was te are presented i n t he specif i cat ions other than those related t o odo r contro l (01563-2 ) In add i tion to od o rs exposed waste will i nc rease health c oncerns associated wi th vec t ors t he inc reased emi s s ion of VOCs etc Ti me f r ames f o r the placement o f da il y or inte r mediate cover ove r relocated waste must be d eveloped in acco rdanc e wit h New Hampshi re regulations Leav i ng relocat e waste exposed f o r exte nded periods un t il fina l cover system placemen t would no t be a cce pta ble Pl ease note that i n a ccordanc e with the SOW (F 2 a (3) (b ) (ii)) continuous ambien t a ir bull mon ito r ing is to be conducted througho ut s oi l waste excavatio n

02215 -3 A The off - s i te d i s posa l o f a ny ha za rdou s waste shall be i n a ccordance wi th a ll st a te a nd fede r co requirements On-site disposa l of any haz a rdou wa ste will require prior EPA approval

B In addition to addressing any haza rdous wast t encountered the Contingency Plan must also

i bull z ~0

middot= middot ~m

n = gt = = en

address issues suc h a s odors v ectors fl ooding o f t he ope n exc avation areas e tc Provide o ne copy

to NHDES Ple ase note that in acco r dance with the sow (i 2 a (3) (cl (ii ] monito ring of surface dr~inage is to be conducted throughout soi l waste excava tion a nd cap canst r uction

02215- 4 The use of a modified excavation specification for waste relocation is confusing Numerous references are made to suitability o f subgrade materials distances to f o rmwork and f ootings damage t o existing structures etc which are not considered part of thi s task Consider modifying this specification to address o nly the actua l work requirements associated with waste excavation r elocat i on pla cement and covering

02223 NHDES recommends testing be increa sed to one in 5000 cubic y a rds for g r ad a tion At t e rbur g l i mits modif ied proctor pe r me abili t y interna l f r i ct i o n and cohes ion a nd d irec t s hear

022 33 NHDES r e commends that a f requecy of t e s t i ng section be added f o r in- place mat erial

0 2590-202 D The tens i l e strength at break requ i red may eliminate blown film textured HOPE from use on this Project

02590 - 2 03 The d isc ussio n on materia l ha nd ling a nd t ransport is very limited compared to 0259 1-104 Thes e requirement s should be verified

02591-24 Allowable g r ound pressures for const ructio n equipment placing materials over geos ynt he t ics i n other parts o f the spec if ica tions a r e not c onsisten t wi t h the t abl e on this page Other refe rences indicate a 12- i nc h thick laye r o f s o i middot i s appa r ent ly r equi red f or equipment hav ing grou pressures les s than 5 psi a nd a 36- inch l ayer f c equipment having ground pressures in excess o f 5 psi This information should be cla rif ied and made c onsistent throughout the text

Table 02591 - 1 The peel adhes ion requirement of 133 ppi differ from 10 ppi in the t ext Make consistent

~~ - = ~~ ~

~i ~0

Z a~a middot=bull~m~ [~

~

Q n

= = =

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 2: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

shy

Groundwater Moni taring Plan

Based upon our telephone conversat i o n middotJ f January 9 1996 the groundwater moilitpring segment of the Environmental Monito ring Plan does lOt seem t o reflect your understanding of well abandonment and sampling no r does it appear to have responded to my comments of Oct o ber 17 1995 with the exception of t he water level monitoring Specific comments are enclosed I would like a revised plan which ~ responds to these and the previous comments To reiterate what I had expected to be reflected in thi s version of the EMP as stated in the October 17 letter

As always if you have any questions regarding a ny of these comments please contact me a t (617) 573-9628

Sincenly

4vl)~ Roger F Ouwart Remedi a l Project Ma nager NHRI Superfund Section Office of Site Re mediat ion a nd Restoration

enclosures

Talcott Hubbard NHDES James Philcox Weston Dave Allen City of Po rtsmouth Al Macdonald Golder

~

bull ~ ~

bull~

0 ii m

s ~

~ij n ~~~ ~~~ ~ ~ ~~~ GPipzmr 8~ sect~ m

n Q gt = = m

r

100 DESIGN COMMENTS

COULEY LANDFILL SUPERFUND SITE

GENERAL COMMEtJi

The Final Design Re port FOR) does not in itself prov i de a comprehensive desig n package which furn i shes the information ne c essary to support the anal ysis o f compliance with Performance Standards identified in the Pre-Design Report a s r equned by the Consent Order Scope of Work tSOW) [Section F 3 a (2 ) t d l l Comple t e d a t a a nd engineeri ng c a lcu lations prepa red t o suppo rt comp l iance wit h the Perfo rmanc e St a ndards are not part of the 100 de s i g n p a c kage as def i ned by Artic le 2 o f t he Envnonmenta l Remed iation Contractor Agreement Inste ad t he r e ader is frequently c r oss- referenced t o one o f the draf t des ign reports All of these draft submittals have re c eived s i gn i f ican t comme nts from the US Environmental Pro tectio n Agency (EPA ) and Ne w Ha mpshire Department of Environmental Services (NHDES ) Whi l e they hav e been accepted by EPA these acceptances have been ma de in the context that the drafts have met the intent of t he SOW milestones not that they are technically complete or meet the fu ll requirements of the Record of Decision (ROD )

Due to these cross-references in the final design submittal all three draft documents would have to be made available to create a final comprehensive design package Thi s is not cons idered idea l due to redu ndancy and t he potential for conf usion which ma y result from the incons i stenci e s between the documents It is recommended that cross-references to informa tion in other design reports be replaced by the inclusion of specific info rma t i o n as appendices to the FOR prior t o going out to b i d

SECTION 4 CONSOLIDATION OP SEDIMENTS WETLANDS RESTORATION

27 Based on the dimensions provided (Drawi ng 5- 24 ) appears as though insuffic i ent s t r uctu ra l f ill m exis t o ver the pro po sed c ulverts (6 N of No 57 s t one and a s bull o f Type C grading f ill) cons i de ri ng t he numle r of fu lly loaded truc ks a n ticipa ted to construct that cap This along with a ny poor subgra de materials remaining in tl area may lead to increased ma intena nce requ ire ments which could further impact the adj a ce nt wetl a nds subsequent to initial construction

n Q = = en

28

l

To help provide a more complete final design package all r equi r ed permit f o rms should be ~ttached t o the FDR

SPECIFICATIONS

02936 l0 4A Will this paragraph of the specification affect any i~terpretation of adequate percent cover for the Wetland Mi tigation requirements or requireme~ts of specificat i on 02936-4

paragraph 3 08

02937 2 06E The FOR text indicates that transplants may come f rom o ff -site wetlands ye t the text o f this specific a tion appears to contradict this It is recommended that words only and small amourt s i n the specification be clarified

APPENDIX 1 ENVIRONMENTAL MONITORING PLAN

Consider including estimated cover monitoring for a subset of individual shrubs and trees by measuring width and extent of canopy There will likely be differences among planted species which will be useful in replanting (if necessary) and determining which planted species are most s uccessful at both survival and growth

For clarity Figures 2-1 through 2-3 should be referenced in the order that they appear in the text

10 Will the photographic stations be established at each plo t being used f o r p l ant coverage evaluations

10 There is a discrepancy regarding the frequency monitoring being i mp lemented according to t he F a nd t hat needed to lnsure performance standards are met This paragraph indicates that moniton efforts will be the most intense during the firs t wo ylars yet the rest of the text does not support this statement requirement Consistenc~

n Q

= en=

amo ng sect i ons a nd a table with thO p r op o s e d mon itoring time l i ne f o r each pa r a meter

veget at 1on aquat ic macro invertebra tes middot wildli fe wate r table ma i n te nance activitie5

etc ) would be ve ry us eful

12 In the e ven t that the g r oundwate r pump-and-treat system is not constructed a djacen t wetland monitoring would still be required to evaluate the impact that other remedial actions may have on ad j acent wetlands

14 The wetland mo nitoring prog ram i s to be initlated once r estora tion of t he we tl ands ha s been complet ed In i t i a tion o f the moni to r i ng p rog r am sho u l d not be s che duled in rel a tio nsh i p t o t he imp leme ntat ion o f t he groundwater co l l e c tio n a d r echarge s ystem

SECTI ON 5 CAPPING OP THE LANDFILL

SPICIPICATI ONS

02215middot3 No requirement s for covering the re located was te are presented i n t he specif i cat ions other than those related t o odo r contro l (01563-2 ) In add i tion to od o rs exposed waste will i nc rease health c oncerns associated wi th vec t ors t he inc reased emi s s ion of VOCs etc Ti me f r ames f o r the placement o f da il y or inte r mediate cover ove r relocated waste must be d eveloped in acco rdanc e wit h New Hampshi re regulations Leav i ng relocat e waste exposed f o r exte nded periods un t il fina l cover system placemen t would no t be a cce pta ble Pl ease note that i n a ccordanc e with the SOW (F 2 a (3) (b ) (ii)) continuous ambien t a ir bull mon ito r ing is to be conducted througho ut s oi l waste excavatio n

02215 -3 A The off - s i te d i s posa l o f a ny ha za rdou s waste shall be i n a ccordance wi th a ll st a te a nd fede r co requirements On-site disposa l of any haz a rdou wa ste will require prior EPA approval

B In addition to addressing any haza rdous wast t encountered the Contingency Plan must also

i bull z ~0

middot= middot ~m

n = gt = = en

address issues suc h a s odors v ectors fl ooding o f t he ope n exc avation areas e tc Provide o ne copy

to NHDES Ple ase note that in acco r dance with the sow (i 2 a (3) (cl (ii ] monito ring of surface dr~inage is to be conducted throughout soi l waste excava tion a nd cap canst r uction

02215- 4 The use of a modified excavation specification for waste relocation is confusing Numerous references are made to suitability o f subgrade materials distances to f o rmwork and f ootings damage t o existing structures etc which are not considered part of thi s task Consider modifying this specification to address o nly the actua l work requirements associated with waste excavation r elocat i on pla cement and covering

02223 NHDES recommends testing be increa sed to one in 5000 cubic y a rds for g r ad a tion At t e rbur g l i mits modif ied proctor pe r me abili t y interna l f r i ct i o n and cohes ion a nd d irec t s hear

022 33 NHDES r e commends that a f requecy of t e s t i ng section be added f o r in- place mat erial

0 2590-202 D The tens i l e strength at break requ i red may eliminate blown film textured HOPE from use on this Project

02590 - 2 03 The d isc ussio n on materia l ha nd ling a nd t ransport is very limited compared to 0259 1-104 Thes e requirement s should be verified

02591-24 Allowable g r ound pressures for const ructio n equipment placing materials over geos ynt he t ics i n other parts o f the spec if ica tions a r e not c onsisten t wi t h the t abl e on this page Other refe rences indicate a 12- i nc h thick laye r o f s o i middot i s appa r ent ly r equi red f or equipment hav ing grou pressures les s than 5 psi a nd a 36- inch l ayer f c equipment having ground pressures in excess o f 5 psi This information should be cla rif ied and made c onsistent throughout the text

Table 02591 - 1 The peel adhes ion requirement of 133 ppi differ from 10 ppi in the t ext Make consistent

~~ - = ~~ ~

~i ~0

Z a~a middot=bull~m~ [~

~

Q n

= = =

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 3: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

r

100 DESIGN COMMENTS

COULEY LANDFILL SUPERFUND SITE

GENERAL COMMEtJi

The Final Design Re port FOR) does not in itself prov i de a comprehensive desig n package which furn i shes the information ne c essary to support the anal ysis o f compliance with Performance Standards identified in the Pre-Design Report a s r equned by the Consent Order Scope of Work tSOW) [Section F 3 a (2 ) t d l l Comple t e d a t a a nd engineeri ng c a lcu lations prepa red t o suppo rt comp l iance wit h the Perfo rmanc e St a ndards are not part of the 100 de s i g n p a c kage as def i ned by Artic le 2 o f t he Envnonmenta l Remed iation Contractor Agreement Inste ad t he r e ader is frequently c r oss- referenced t o one o f the draf t des ign reports All of these draft submittals have re c eived s i gn i f ican t comme nts from the US Environmental Pro tectio n Agency (EPA ) and Ne w Ha mpshire Department of Environmental Services (NHDES ) Whi l e they hav e been accepted by EPA these acceptances have been ma de in the context that the drafts have met the intent of t he SOW milestones not that they are technically complete or meet the fu ll requirements of the Record of Decision (ROD )

Due to these cross-references in the final design submittal all three draft documents would have to be made available to create a final comprehensive design package Thi s is not cons idered idea l due to redu ndancy and t he potential for conf usion which ma y result from the incons i stenci e s between the documents It is recommended that cross-references to informa tion in other design reports be replaced by the inclusion of specific info rma t i o n as appendices to the FOR prior t o going out to b i d

SECTION 4 CONSOLIDATION OP SEDIMENTS WETLANDS RESTORATION

27 Based on the dimensions provided (Drawi ng 5- 24 ) appears as though insuffic i ent s t r uctu ra l f ill m exis t o ver the pro po sed c ulverts (6 N of No 57 s t one and a s bull o f Type C grading f ill) cons i de ri ng t he numle r of fu lly loaded truc ks a n ticipa ted to construct that cap This along with a ny poor subgra de materials remaining in tl area may lead to increased ma intena nce requ ire ments which could further impact the adj a ce nt wetl a nds subsequent to initial construction

n Q = = en

28

l

To help provide a more complete final design package all r equi r ed permit f o rms should be ~ttached t o the FDR

SPECIFICATIONS

02936 l0 4A Will this paragraph of the specification affect any i~terpretation of adequate percent cover for the Wetland Mi tigation requirements or requireme~ts of specificat i on 02936-4

paragraph 3 08

02937 2 06E The FOR text indicates that transplants may come f rom o ff -site wetlands ye t the text o f this specific a tion appears to contradict this It is recommended that words only and small amourt s i n the specification be clarified

APPENDIX 1 ENVIRONMENTAL MONITORING PLAN

Consider including estimated cover monitoring for a subset of individual shrubs and trees by measuring width and extent of canopy There will likely be differences among planted species which will be useful in replanting (if necessary) and determining which planted species are most s uccessful at both survival and growth

For clarity Figures 2-1 through 2-3 should be referenced in the order that they appear in the text

10 Will the photographic stations be established at each plo t being used f o r p l ant coverage evaluations

10 There is a discrepancy regarding the frequency monitoring being i mp lemented according to t he F a nd t hat needed to lnsure performance standards are met This paragraph indicates that moniton efforts will be the most intense during the firs t wo ylars yet the rest of the text does not support this statement requirement Consistenc~

n Q

= en=

amo ng sect i ons a nd a table with thO p r op o s e d mon itoring time l i ne f o r each pa r a meter

veget at 1on aquat ic macro invertebra tes middot wildli fe wate r table ma i n te nance activitie5

etc ) would be ve ry us eful

12 In the e ven t that the g r oundwate r pump-and-treat system is not constructed a djacen t wetland monitoring would still be required to evaluate the impact that other remedial actions may have on ad j acent wetlands

14 The wetland mo nitoring prog ram i s to be initlated once r estora tion of t he we tl ands ha s been complet ed In i t i a tion o f the moni to r i ng p rog r am sho u l d not be s che duled in rel a tio nsh i p t o t he imp leme ntat ion o f t he groundwater co l l e c tio n a d r echarge s ystem

SECTI ON 5 CAPPING OP THE LANDFILL

SPICIPICATI ONS

02215middot3 No requirement s for covering the re located was te are presented i n t he specif i cat ions other than those related t o odo r contro l (01563-2 ) In add i tion to od o rs exposed waste will i nc rease health c oncerns associated wi th vec t ors t he inc reased emi s s ion of VOCs etc Ti me f r ames f o r the placement o f da il y or inte r mediate cover ove r relocated waste must be d eveloped in acco rdanc e wit h New Hampshi re regulations Leav i ng relocat e waste exposed f o r exte nded periods un t il fina l cover system placemen t would no t be a cce pta ble Pl ease note that i n a ccordanc e with the SOW (F 2 a (3) (b ) (ii)) continuous ambien t a ir bull mon ito r ing is to be conducted througho ut s oi l waste excavatio n

02215 -3 A The off - s i te d i s posa l o f a ny ha za rdou s waste shall be i n a ccordance wi th a ll st a te a nd fede r co requirements On-site disposa l of any haz a rdou wa ste will require prior EPA approval

B In addition to addressing any haza rdous wast t encountered the Contingency Plan must also

i bull z ~0

middot= middot ~m

n = gt = = en

address issues suc h a s odors v ectors fl ooding o f t he ope n exc avation areas e tc Provide o ne copy

to NHDES Ple ase note that in acco r dance with the sow (i 2 a (3) (cl (ii ] monito ring of surface dr~inage is to be conducted throughout soi l waste excava tion a nd cap canst r uction

02215- 4 The use of a modified excavation specification for waste relocation is confusing Numerous references are made to suitability o f subgrade materials distances to f o rmwork and f ootings damage t o existing structures etc which are not considered part of thi s task Consider modifying this specification to address o nly the actua l work requirements associated with waste excavation r elocat i on pla cement and covering

02223 NHDES recommends testing be increa sed to one in 5000 cubic y a rds for g r ad a tion At t e rbur g l i mits modif ied proctor pe r me abili t y interna l f r i ct i o n and cohes ion a nd d irec t s hear

022 33 NHDES r e commends that a f requecy of t e s t i ng section be added f o r in- place mat erial

0 2590-202 D The tens i l e strength at break requ i red may eliminate blown film textured HOPE from use on this Project

02590 - 2 03 The d isc ussio n on materia l ha nd ling a nd t ransport is very limited compared to 0259 1-104 Thes e requirement s should be verified

02591-24 Allowable g r ound pressures for const ructio n equipment placing materials over geos ynt he t ics i n other parts o f the spec if ica tions a r e not c onsisten t wi t h the t abl e on this page Other refe rences indicate a 12- i nc h thick laye r o f s o i middot i s appa r ent ly r equi red f or equipment hav ing grou pressures les s than 5 psi a nd a 36- inch l ayer f c equipment having ground pressures in excess o f 5 psi This information should be cla rif ied and made c onsistent throughout the text

Table 02591 - 1 The peel adhes ion requirement of 133 ppi differ from 10 ppi in the t ext Make consistent

~~ - = ~~ ~

~i ~0

Z a~a middot=bull~m~ [~

~

Q n

= = =

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 4: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

28

l

To help provide a more complete final design package all r equi r ed permit f o rms should be ~ttached t o the FDR

SPECIFICATIONS

02936 l0 4A Will this paragraph of the specification affect any i~terpretation of adequate percent cover for the Wetland Mi tigation requirements or requireme~ts of specificat i on 02936-4

paragraph 3 08

02937 2 06E The FOR text indicates that transplants may come f rom o ff -site wetlands ye t the text o f this specific a tion appears to contradict this It is recommended that words only and small amourt s i n the specification be clarified

APPENDIX 1 ENVIRONMENTAL MONITORING PLAN

Consider including estimated cover monitoring for a subset of individual shrubs and trees by measuring width and extent of canopy There will likely be differences among planted species which will be useful in replanting (if necessary) and determining which planted species are most s uccessful at both survival and growth

For clarity Figures 2-1 through 2-3 should be referenced in the order that they appear in the text

10 Will the photographic stations be established at each plo t being used f o r p l ant coverage evaluations

10 There is a discrepancy regarding the frequency monitoring being i mp lemented according to t he F a nd t hat needed to lnsure performance standards are met This paragraph indicates that moniton efforts will be the most intense during the firs t wo ylars yet the rest of the text does not support this statement requirement Consistenc~

n Q

= en=

amo ng sect i ons a nd a table with thO p r op o s e d mon itoring time l i ne f o r each pa r a meter

veget at 1on aquat ic macro invertebra tes middot wildli fe wate r table ma i n te nance activitie5

etc ) would be ve ry us eful

12 In the e ven t that the g r oundwate r pump-and-treat system is not constructed a djacen t wetland monitoring would still be required to evaluate the impact that other remedial actions may have on ad j acent wetlands

14 The wetland mo nitoring prog ram i s to be initlated once r estora tion of t he we tl ands ha s been complet ed In i t i a tion o f the moni to r i ng p rog r am sho u l d not be s che duled in rel a tio nsh i p t o t he imp leme ntat ion o f t he groundwater co l l e c tio n a d r echarge s ystem

SECTI ON 5 CAPPING OP THE LANDFILL

SPICIPICATI ONS

02215middot3 No requirement s for covering the re located was te are presented i n t he specif i cat ions other than those related t o odo r contro l (01563-2 ) In add i tion to od o rs exposed waste will i nc rease health c oncerns associated wi th vec t ors t he inc reased emi s s ion of VOCs etc Ti me f r ames f o r the placement o f da il y or inte r mediate cover ove r relocated waste must be d eveloped in acco rdanc e wit h New Hampshi re regulations Leav i ng relocat e waste exposed f o r exte nded periods un t il fina l cover system placemen t would no t be a cce pta ble Pl ease note that i n a ccordanc e with the SOW (F 2 a (3) (b ) (ii)) continuous ambien t a ir bull mon ito r ing is to be conducted througho ut s oi l waste excavatio n

02215 -3 A The off - s i te d i s posa l o f a ny ha za rdou s waste shall be i n a ccordance wi th a ll st a te a nd fede r co requirements On-site disposa l of any haz a rdou wa ste will require prior EPA approval

B In addition to addressing any haza rdous wast t encountered the Contingency Plan must also

i bull z ~0

middot= middot ~m

n = gt = = en

address issues suc h a s odors v ectors fl ooding o f t he ope n exc avation areas e tc Provide o ne copy

to NHDES Ple ase note that in acco r dance with the sow (i 2 a (3) (cl (ii ] monito ring of surface dr~inage is to be conducted throughout soi l waste excava tion a nd cap canst r uction

02215- 4 The use of a modified excavation specification for waste relocation is confusing Numerous references are made to suitability o f subgrade materials distances to f o rmwork and f ootings damage t o existing structures etc which are not considered part of thi s task Consider modifying this specification to address o nly the actua l work requirements associated with waste excavation r elocat i on pla cement and covering

02223 NHDES recommends testing be increa sed to one in 5000 cubic y a rds for g r ad a tion At t e rbur g l i mits modif ied proctor pe r me abili t y interna l f r i ct i o n and cohes ion a nd d irec t s hear

022 33 NHDES r e commends that a f requecy of t e s t i ng section be added f o r in- place mat erial

0 2590-202 D The tens i l e strength at break requ i red may eliminate blown film textured HOPE from use on this Project

02590 - 2 03 The d isc ussio n on materia l ha nd ling a nd t ransport is very limited compared to 0259 1-104 Thes e requirement s should be verified

02591-24 Allowable g r ound pressures for const ructio n equipment placing materials over geos ynt he t ics i n other parts o f the spec if ica tions a r e not c onsisten t wi t h the t abl e on this page Other refe rences indicate a 12- i nc h thick laye r o f s o i middot i s appa r ent ly r equi red f or equipment hav ing grou pressures les s than 5 psi a nd a 36- inch l ayer f c equipment having ground pressures in excess o f 5 psi This information should be cla rif ied and made c onsistent throughout the text

Table 02591 - 1 The peel adhes ion requirement of 133 ppi differ from 10 ppi in the t ext Make consistent

~~ - = ~~ ~

~i ~0

Z a~a middot=bull~m~ [~

~

Q n

= = =

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 5: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

amo ng sect i ons a nd a table with thO p r op o s e d mon itoring time l i ne f o r each pa r a meter

veget at 1on aquat ic macro invertebra tes middot wildli fe wate r table ma i n te nance activitie5

etc ) would be ve ry us eful

12 In the e ven t that the g r oundwate r pump-and-treat system is not constructed a djacen t wetland monitoring would still be required to evaluate the impact that other remedial actions may have on ad j acent wetlands

14 The wetland mo nitoring prog ram i s to be initlated once r estora tion of t he we tl ands ha s been complet ed In i t i a tion o f the moni to r i ng p rog r am sho u l d not be s che duled in rel a tio nsh i p t o t he imp leme ntat ion o f t he groundwater co l l e c tio n a d r echarge s ystem

SECTI ON 5 CAPPING OP THE LANDFILL

SPICIPICATI ONS

02215middot3 No requirement s for covering the re located was te are presented i n t he specif i cat ions other than those related t o odo r contro l (01563-2 ) In add i tion to od o rs exposed waste will i nc rease health c oncerns associated wi th vec t ors t he inc reased emi s s ion of VOCs etc Ti me f r ames f o r the placement o f da il y or inte r mediate cover ove r relocated waste must be d eveloped in acco rdanc e wit h New Hampshi re regulations Leav i ng relocat e waste exposed f o r exte nded periods un t il fina l cover system placemen t would no t be a cce pta ble Pl ease note that i n a ccordanc e with the SOW (F 2 a (3) (b ) (ii)) continuous ambien t a ir bull mon ito r ing is to be conducted througho ut s oi l waste excavatio n

02215 -3 A The off - s i te d i s posa l o f a ny ha za rdou s waste shall be i n a ccordance wi th a ll st a te a nd fede r co requirements On-site disposa l of any haz a rdou wa ste will require prior EPA approval

B In addition to addressing any haza rdous wast t encountered the Contingency Plan must also

i bull z ~0

middot= middot ~m

n = gt = = en

address issues suc h a s odors v ectors fl ooding o f t he ope n exc avation areas e tc Provide o ne copy

to NHDES Ple ase note that in acco r dance with the sow (i 2 a (3) (cl (ii ] monito ring of surface dr~inage is to be conducted throughout soi l waste excava tion a nd cap canst r uction

02215- 4 The use of a modified excavation specification for waste relocation is confusing Numerous references are made to suitability o f subgrade materials distances to f o rmwork and f ootings damage t o existing structures etc which are not considered part of thi s task Consider modifying this specification to address o nly the actua l work requirements associated with waste excavation r elocat i on pla cement and covering

02223 NHDES recommends testing be increa sed to one in 5000 cubic y a rds for g r ad a tion At t e rbur g l i mits modif ied proctor pe r me abili t y interna l f r i ct i o n and cohes ion a nd d irec t s hear

022 33 NHDES r e commends that a f requecy of t e s t i ng section be added f o r in- place mat erial

0 2590-202 D The tens i l e strength at break requ i red may eliminate blown film textured HOPE from use on this Project

02590 - 2 03 The d isc ussio n on materia l ha nd ling a nd t ransport is very limited compared to 0259 1-104 Thes e requirement s should be verified

02591-24 Allowable g r ound pressures for const ructio n equipment placing materials over geos ynt he t ics i n other parts o f the spec if ica tions a r e not c onsisten t wi t h the t abl e on this page Other refe rences indicate a 12- i nc h thick laye r o f s o i middot i s appa r ent ly r equi red f or equipment hav ing grou pressures les s than 5 psi a nd a 36- inch l ayer f c equipment having ground pressures in excess o f 5 psi This information should be cla rif ied and made c onsistent throughout the text

Table 02591 - 1 The peel adhes ion requirement of 133 ppi differ from 10 ppi in the t ext Make consistent

~~ - = ~~ ~

~i ~0

Z a~a middot=bull~m~ [~

~

Q n

= = =

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 6: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

address issues suc h a s odors v ectors fl ooding o f t he ope n exc avation areas e tc Provide o ne copy

to NHDES Ple ase note that in acco r dance with the sow (i 2 a (3) (cl (ii ] monito ring of surface dr~inage is to be conducted throughout soi l waste excava tion a nd cap canst r uction

02215- 4 The use of a modified excavation specification for waste relocation is confusing Numerous references are made to suitability o f subgrade materials distances to f o rmwork and f ootings damage t o existing structures etc which are not considered part of thi s task Consider modifying this specification to address o nly the actua l work requirements associated with waste excavation r elocat i on pla cement and covering

02223 NHDES recommends testing be increa sed to one in 5000 cubic y a rds for g r ad a tion At t e rbur g l i mits modif ied proctor pe r me abili t y interna l f r i ct i o n and cohes ion a nd d irec t s hear

022 33 NHDES r e commends that a f requecy of t e s t i ng section be added f o r in- place mat erial

0 2590-202 D The tens i l e strength at break requ i red may eliminate blown film textured HOPE from use on this Project

02590 - 2 03 The d isc ussio n on materia l ha nd ling a nd t ransport is very limited compared to 0259 1-104 Thes e requirement s should be verified

02591-24 Allowable g r ound pressures for const ructio n equipment placing materials over geos ynt he t ics i n other parts o f the spec if ica tions a r e not c onsisten t wi t h the t abl e on this page Other refe rences indicate a 12- i nc h thick laye r o f s o i middot i s appa r ent ly r equi red f or equipment hav ing grou pressures les s than 5 psi a nd a 36- inch l ayer f c equipment having ground pressures in excess o f 5 psi This information should be cla rif ied and made c onsistent throughout the text

Table 02591 - 1 The peel adhes ion requirement of 133 ppi differ from 10 ppi in the t ext Make consistent

~~ - = ~~ ~

~i ~0

Z a~a middot=bull~m~ [~

~

Q n

= = =

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 7: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

0 02592-202C The tensile strength at break required may

middot eliminate blown film smooth LLDPE geomembranes ~rom use on this Pro ject Please verify

02595-201A If the geotextile is to be used in filtration Apparent Opening Size (AOSl and permitt ivity va lues should be included as part o f the spec

02596-2018 Requiring GCLs t o have widths exceeding 15 feet may eliminate at least one maj o r manufacturer

02596-2 01C A There is a typographical error in the GCL testing property 3b and its associated ASTM reference

B Is the GCL permeability required to be 10 x 10 or 1 0 x 10middot em sec Specify the confining pressures to be used in the permeability tests

02831-1 Security fencing will be required at the site to prevent potential exposure to exposed wa ste leachate and other site hazards This requirement is not a contractor option Methods to isola te hazards must be addressed in the Site Security Plan

SECTION 6 GAS COLLECTION GAS ABATIMENT SYSTEM

Al l comme nt s are reserved pending submission of revised design

SICTION 7 GROUNDWATER XTRACTION RCHARGB SYSTEM

65 A Reference to Figures 7-5 7-6 and 7-8 is not correct it should read Figures 7-6 7-7 and 7-8

B No figure is presented whi ch illustrates the effects of using the auxiliary recharge trench or the capture zone in the bedrock as pred icted by the 2 - D model

65 This paragraph states that the pumps f or the bedrock extraction well s will be ~ ho rsepower (hp ) Specifi catio n 02621 (Sections A1H a nd A2H states tha t 1 4 hp pumps will be used in the bedrock extraction wel ls While this is

~ ~ z 0

= lt ~

~

~

~~8 ~z~

~~~ 0~ ~~i ~ill~ ~~~ ~om

n Q 111

= = m

0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

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0

associated with Phase I I Construction this inconsistency needs to be resolved Furthermore 14 hp may not be appropriate conside ring the

amiddotm9uno of li f t required

FrGURES AND DRAWINGS

Figure 7-8 The title block indicates this figure illustrates the effect of using the auxiliary recharge trench o n water levels in the overburden as predicted by the 2middot0 model However the Notes section lists the bedrock extraction wells and their respective pumping rates Because the flow lines on this figure appear to represent overburden fl ow (based on a comparison wi th figures 7 - 6 and 7-7) the Notes section should be modi fied to list the extraction rates of the overburden wells and trenches

APPENDIX E ENVIRONMENIAL MONITORING PLAN

Comments are pro v ided e l sewhere

SECTION 8 GROUNDWATER TREATMENT SYSTEM

701 As indicated continue d asse s sment of the groundwater quality will be made during the initial s tages o f the remedial act i on In the event t hat EPA does not consider the additional groundwater data supportive of meeting groundwater cleanup goals via the proposed Phase I remedi a l actions final b i d documents and a n engineering report for t he treatment plant are t o be submitte to EPA fo r review and appr oval The final desigr package for the groundwater treatment plant if required is to be s ubmitted to EPA within 60 c a lendar days from the date that EPA issues its decision on the need f or an active groundwater pump and treat system

z ~

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 9: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

SECTION 10 CONSTRUCTION SCHEDULE

81 While previous design package submit t als hamiddote

included a construction schedule the FOR and the

bid documents do not establish a t i me frame for

completion of the contract work Instead the bid

documents request that the bidders prepare their

own time frame f or construction through several

c r oss-references Article 73 o f the Co1tractor

Agreement indicates that time is of the

essence and chat the b idder shall adhere

to the progress schedul e established in accordance

with Article 3 Article 3 i ndicates tha t a

schedule is to be submit ted b y the bidder which

complies with the s c heduli ng r e s traints

identified in Section 010 10 of the

Spec ifications Section 01010 of the nSpecifications indicates that the contractor is tomiddot

prepare a schedule which meets the requirements of =gtth FOR Yet as discussd above t he FOR does not

speci fy any time frame requirements =Th PFOR assumed an April 1996 contractor =mobilization and completion o f the remedial action en component (with the exception of the g r oundwater

treatment plant) by mid to late August 1 997 In

the event t hat contractor mo bilization s lips three

months to July 1996 (as indicated in t he FOR) it

would be reasonable to expect that construction

(other than the groundwater treatment plant) caulmiddot

be c ompleted by November 1997 To he l p minimize

future impacts to the environment by completing

the fi na l cover as early as practica l and to a vo middot

construction compliclt t ions a ssoci a ted with leavi

a partially complted cover system exposed to po

we a thr conditions it is recommnded that an

appropriat e date be set for comple ting the

contract wo rk

APPENDIX 8 SPECIFICATIONS AND BID DOCUMENTS

c-2 e I expect that the actual project sign will more

accurately depict EPA and NHDES involvment tha r

the sample project sign does

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 10: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

00600-1 1 Exhibit A which defines the persons representing the Coakley Landfill Group and Exhibit B copy of the Consent Decree need to be added to the bid

-documents

00600-5 4 The contract documents indicate that conflict between the EPA approved FOR and the contract specifications wi ll be resolved by the Project Coordinator a r epresenta tive of the Group) in accordance with Article 9 3 of the Agreement Ar ticle 9 3 of the Agreement needs to clarify EPAs role in the process of resolving potential conflicts between t he FOR and the specifications t o ensure t hat Consent Orde r requ irements are being met This clarification should also address requirements f o r EPA approvals as discussed in Arti cles 74 and 75 (p 00600-11)

In addition to the items listed the contractor needs to submit a Construction Quality Control n Plan This plan should provide at a minimum a Qdescription of 111 - responsibilities and authorities of the quality control manager and personnel = - methods of performing qual ity control = inspect ions - testing procedures = - procedures f or scheduling and managing submittals of subcontractor off-site fabricators and suppliers and - reporting procedures including frequency and formats of reports

APPENDIX D CONSTRUCTION QUALITY ASSt11tANC PROJECT PLAN

21 Will the contractor be required to retain only a 100 sf sample of geocomposite materials and no o ther geosynthetic s If so why

Table 4 middot1 A A It is not clear why tens il e properties and dimensional st ab ility testing a re required in ea direction for PVC geomembraneamp and not f or polyethylene geomembra nes Similarly there are soil burial tests required for PVC geomembranes bu t not f or polyethylene geomembranes

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556
Page 11: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2019-11-24 · 0 3301 : Dear Mr. Ro y: EPA and NHDE S have compl eted the review of t.he 100\" Remedial Design submitted by Golder

B Peel strength testing is indicated for geocomposites but are not specified in Section 02598

c Tbere is a typographical error in the f ourth testing method for GCL and its assoc iated ASTM r eference

n C) 111

= = eft

  1. barcode 558556
  2. barcodetext SDMS Doc ID 558556