revised scope of work (sow) for remedial … · purpose this statement of work (sow) ... the...

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From: JOHNJ OGRADYTo: R5CHG. IN. "[email protected]"Date: 9/9/99 12:55pmSubject: REVISED FINAL SOW FOR WOODSTOCK

Steve,

1) Attached please find the final Scope of Work for the pending amended UnilateralAdministrative Order for the Woodstock Municipal Landfill.

2)1 have incorporated as many of your comments and concerns as expressed in your August1999 letter. The paragraphs that I could not revise were either due to the Wetlands mitigationrequirements or the paragraphs were carried over from the original SOW.

3) If you have any questions, please contact me at your earliest convenience.

JohnJ O'GradyRemedial Project ManagerSuperfund DivisionU.S. EPA Region 5

Telephone: (312) 886-1477Facsimile: (312) 886-4071E-Mail: "[email protected]"

CC: R5CHG.IN."[email protected]"

Attachment 2

STATEMENT OF WORKFOR

REMEDIAL ACTIONAT THE WOODSTOCK MUNICIPAL LANDFILL SITE

WOODSTOCK, MCHENRY COUNTY, ILLINOISCERCLIS ID# ILD 980 605 943; SITE/SPILL ID# 05DB

1. PURPOSE

This Statement of Work (SOW) sets forth requirements for implementing the Remedial Action(RA) set forth in the original Record of Decision (ROD) for the Woodstock Municipal Landfill(WML) Site, which the Regional Administrator of the United States Environmental ProtectionAgency (U.S'. EPA), Region 5, signed on June 30, 1993, and the Amended ROD, which theDirector of the Superfund Division, U.S. EPA, Region 5, signed on July 15, 1998. In submittingdeliverables for implementing the RD at the WML Site, the Respondents must follow theamended Unilateral Administrative Order (amended UAO), the ROD as amended, this SOW, theapproved Final (100%) Remedial Design (RD), the approved final Remedial Action (RA) WorkPlan, applicable U.S. EPA Superfund Remedial Design and Remedial Action Guidance, theapproved Operation and Maintenance (O&M) Plan, and any additional guidance the U.S. EPAprovides.

If U.S. EPA determines that the Respondents must implement the Groundwater Remediation andTreatment System (GWRTS) in accordance with Section 4.6 of this SOW, the Respondents mustfollow the Amended UAO, the ROD as amended, this SOW, the approved final RD, theapproved final RA Work Plan, applicable U.S. EPA Superfund Remedial Design and RemedialAction Guidance, the approved O&M Plan, and any additional guidance U.S. EPA provides, inthe submitting deliverables for designing and implementing the RA for the GWRTS at the WMLSite.

All documents or deliverables required as part of this SOW must be submitted to the U.S. EPA,with a copy to the State of Illinois Environmental Protection Agency (Illinois EPA), for U.S.EPA's review and approval, in consultation with the Illinois EPA, under the Amended UAO'sprovisions.

2. GENERAL PROVISIONS

All soils, clay, fill, and construction materials used for implementation of the remedy must besubject to the U.S. EPA's approval. Representative samples of soils, clay, fill, and constructionmaterials used for implementing the remedy must be tested before their use to verify that thestandards promulgated by the Illinois Administrative Code (IAC) Title 35 Part 740 TieredApproach to Corrective Action Objectives have not been exceeded, and that they are suitable for

Final Version; September 9,1999

WML SOW FOR RA (Continued)

the intended use and meet all applicable engineering, chemical, or general specifications. Allsoils, clay and fill materials must be sampled and analyzed for all compounds, contaminants, orparameters as specified in the Predesign Investigation (PDI) Work Plan, RD/RA Work Plan,Quality Assurance Project Plan (QAPP), the approved final RD, the approved final RA WorkPlan, and supporting documents that Respondents must complete for approval of the U.S. EPAunder this SOW.

3. DESCRIPTION OF THE REMEDIAL ACTION

The Respondents must design and implement the RA to meet the performance standards andspecifications set forth in the Amended UAO, the ROD as amended, the approved final RD, andthis SOW. Performance standards include cleanup standards, standards of control, qualitycriteria and other substantive requirements, criteria or limitations including all Applicable orRelevant and Appropriate Requirements (ARARs) set forth in the Amended UAO, the ROD asamended, the approved final RD, the approved final RA Work Plan, or this SOW. The workRespondents must implement includes, but is not limited to, the following components:

3.1 Fencing:3.2 Contaminated soil/sediment excavation and consolidation:3.3 Capping:3.4 Groundwater remediation and treatment system (GWRTS)':3.5 Landfill gas collection system;3.6 Well monitoring and remedy monitoring programs;3.7 Institutiuiia. controls:3.8 Correction of work deficiencies: and3.9 Wetland mitigation.

The remedial action will be constructed in two phases. The first phase of the remedial action(Phase I RA), which began August 16, 1999, and will be completed by October 31, 1999, willprepare the site for construction of a landfill cap in spring 2000. The Phase I RA work includes:(1) Clearing the site of trees and vegetation; (2) Excavating contaminated wetland sediments,which will then be placed in an on-site landfill; (3) Sifting on-site soils to eliminate stones, foreventual reuse as landfill cover; and (4) Closing on-site monitoring wells that are no longerneeded.

1 Design and construction of component 3.4, the GWRTS, was made a contingent part ofthe Remedial Action by the ROD Amendment signed on July 15, 1998. Section 4.6 of this SOWcontains requirements related to the design, construction, and O&M of the GWRTS.

Final Version; September 9,1999 1


The second phase of the remedial action (Phase II RA) will run through the calendar year 2000construction season and includes: (1) regrading and contouring the site; (2) constructing thelandfill's geomembrane, drainage, and topsoil layers, as well as installing a landfill gas ventingsystem; (3) installing a surface-water and sedimentation control system; and (4) comprehensivemonitoring and institutional controls on future uses of the site.

The Performance Standards and specifications of the major components of the work for the Sitewhich must be implemented by the Respondents are listed in the ROD as amended and herein.The work must be designed, constructed, operated and maintained by the Respondents inaccordance with the Amended UAO, the ROD as amended, this SOW, the approved Final RD,the approved final RA Work Plan, applicable U.S. EPA Superfund Remedial Design andRemedial Action Guidance, the approved O & M Plan, and any additional guidance the U.S.EPA provides.

The groundwater Performance Standards for the Site must be the most stringent of MaximumContaminant Levels (MCLs), Maximum Contaminant Level Goals (MCLGs), SecondaryMaximum Contaminant Levels (SMCLs), and the substantive provisions of the IllinoisGroundwater Quality Standards (for Class I water resources).2 The point-of-compliance forPerformance Standards for this Site is at the property lines. Performance Standards must be metat all times at all monitoring wells at and beyond the point-of-compliance.3 It is noted, however,that the interim remedy for the vinyl chloride plume is natural attenuation, which will be verifiedthrough the groundwater monitoring program. It is anticipated that natural attenuation of thevinyl chloride plume will take in excess of 20 years to remediate to below the MCL of 2 parts perbillion.4

After completion of the remedy components as required in the Amended UAO or this SO W, if anexceedance of Performance Standards at or beyond the point-of-compliance occurs, theRespondents must implement additional response actions in compliance with the Amended UAO

2 Please refer to the discussion in the July 15, 1998, ROD Amendment, Section XII,STATUTORY DETERMINATIONS. 2. Compliance with ARARs, A. Chemical-SpecificARARs, (2) Ground Water.

3 NCP, 40 CFR Part 300.430(f)(5)(iii)(A); Vol. 55, Federal Register, No. 46, Thursday,March 8, 1990, p. 8852 (see also pp. 8713, 8753-8754)

4 Establishment of a groundwater management zone consistent with Illinois regulations(35 IAC Section 620) and existing restrictions on issuance of a well construction permit underthe current Illinois Water Well Regulations (77 IAC Section 920) will effectively restrict the useof groundwater downgradient of the Site, thus, ensuring protection of human health while naturalattenuation is occurring.



and this SOW. In addition to compliance with the Performance Standards set forth in the RODas amended and herein, the Respondents must design, construct, operate and maintain the workto meet all applicable or relevant and appropriate federal, state and local laws, regulations andstandards regarding discharges of hazardous substances, pollutants or contaminants (ARARs)from the Site to the environment.

The U.S. EPA will approve or disapprove schedules for construction and operation of theremedial components, including, if the U.S. EPA determines it appropriate, schedules for phasedor delayed installation of remedial components, after considering available information,including, but not limited to, the PDI Report, the approved final RD, or any other additional orsupplemental investigations, studies, technical memoranda, or documents.

3.1 Fence Installation

The Respondents must maintain the existing fence around the Site during construction in order toprevent Site access and to prevent vandalism to the Site remedy components. Temporaryconstruction fencing shall be installed, as needed, along Davis Road during cap and drainageswale construction in this area. The Respondents must also install and maintain a permanentfence around those Site components requiring such security as the U.S. EPA specifies at thecompletion of the construction activities. The fence must consist of a minimum six-foot highgalvanized steel chain-link fence with a minimum three-strand barbed wire on top. Since the Siteis bounded on the west, south, and part of the east side with wetlands preventing general accessby unauthorized persons and vehicles, installation of barbed wire on top of the fencing alongthese portions will not be required. However, barb wire must be placed on the final fencingalong the northern edge and sufficient portions of the eastern and western edges to restrict access.The minimum six-foot high galvanized steel chain-link fence must be installed around the entireperimeter of the Site as part of the construction activities. Those Site components requiringpermanent fencing must be fully enclosed and must have a locking gate entry for access. TheRespondents must prepare and utilize a Surveying Report to correctly delineate the Siteconstruction boundaries and properly establish the fence lines if such information does notcurrently exist. The fence must be equipped with a locking swing gate at each access road.

Respondents must post reflective warning signs at 200-foot intervals along the fence and on thegate as part of the construction activities. Respondents must also post warning signs as the U.S.EPA specifies at each of the permanently secured Site component areas. The warning signs mustadvise passers by that the area contains hazardous chemicals in soils and groundwater. The signsmust also provide a local telephone number to call for further information. These signs mustbear the following legend:



WARNING!

Woodstock Landfill U.S. EPA Superfund Site

AUTHORIZED PERSONNEL ONLY

This area contains hazardous chemicals in soils and groundwater.Call (847) xxx-xxxx for further information.

The Respondents must inspect the entire fence (including warning signs) at a minimum of onceevery month for the first year, and quarterly (four times per year) afterwards, to assure the fenceis intact and unbreached. Respondents must record incidents of vandalism, trespassing andbreaches of the fence, and report and document them to local authorities and the U.S. EPA assoon as possible after Respondents discover or otherwise become aware of them. Any damage ordeterioration must be repaired, or other maintenance performed, within seven (7) days ofRespondents' becoming aware or receiving notice that repair or maintenance is necessary. TheFence O&M Plan must describe inspection and maintenance, vandalism, and other overallgeneral monitoring activities.

3.2 Consolidation of Contaminated Soil and Sediment

The Respondents must excavate and consolidate onto areas within the landfill, the Site soils,sediments, and any associated material (e.g., sludges or debris) from the affected areas aroundthe Site and those portions of the Site where sludges were deposited which contain hazardoussubstances, pollutants or contaminants, at concentrations that exceed background concentrations.Please see also Section 3.9, Wetland Mitigation.

3.3 Capping-Landfill Cover

The Respondents must design, construct, install, operate and maintain a landfill cover and gascollection system over the landfill. The landfill cover must be designed and installed to meet orexceed those requirements of Title 35 IAC, Subtitle G, Chapter 1, Subchapter I, Part 811.314 asspecified in the ROD as amended, and the approved final RD. Upon completion, theRespondents must install a surface water control system and vegetate the cover.

The landfill cap construction must be integrated and coordinated with the construction of thesurface water control system, landfill gas collection system, and all other remedial components inorder to assure cap integrity and minimal interference with other remedial components.



The Respondents must conduct routine monitoring, repair and maintenance of the cover systemas part of the long-term requirements to be established in the O&M Plan. For a minimum of 30years, the Respondents must conduct annual inspections of the cover system to identify areasrequiring repair. The Respondents must maintain and repair any deficiencies identified throughthese inspections within 30 days.

3.4 Groundwater Remediation and Treatment System

See Section 4.6 (below) of this SOW.

3.5 Passive Landfill Gas Venting System

The Respondents must design, construct, and operate a passive landfill gas collection system forthe Site.

3.5.1 Landfill Gas Collection System Performance Standards

The Respondents must design, construct, operate and maintain a passive landfill gas collectionsystem that will: (1) control gas pressure; (2) prevent vertical and lateral migration; (3) preventany adverse impacts to the integrity of the other work components; and (4) ensure that thelandfill gases generated do not present a risk to public health or the environment. If necessary,the Respondents shall treat landfill gases in order to eliminate atmospheric emissions, includingemissions exceeding those levels specified in the substantive portions of Title 35 of the IAC.Subtitle B and G, and the Clean Air Act Regulations, as well as operate in compliance with allother federal, state, and local regulations.

3.5.2 Air Emissions Monitoring

The Respondents must perform air emission monitoring under a U.S. EPA-approved monitoringplan, at a minimum frequency of once every month for the first year, and quarterly (four timesper year) afterwards, to ensure that all federal, state and local regulations are met, including thesubstantive provisions of Title 35 of the IAC, Subtitle B and G, and the Clean Air ActRegulations, as applicable. The Respondents must submit to the U.S. EPA, with a copy to theIllinois EPA, an annual summary report that must include, at a minimum, summary data tables,site maps, a discussion of the potential significance, source and impact of landfill gas detected, adelineation of impacts to the Site and its work components, a preliminary list of proposedmodifications and rationale for such modifications, and other information as the U.S. EPAconcludes is necessary. The U.S. EPA, in consultation with the Illinois EPA, will approve ordisapprove any of the Respondents' proposed changes.



3.5.3 Additional Air Emission Remediation

If air emission monitoring indicates that any hazardous substance, pollutant or contaminant'sconcentration has exceeded federal, state, and local regulations, lateral migration of landfill gasesis present, the integrity of the landfill cap is degrading, or the generated gases present a risk topublic health or the environment, the Respondents must immediately take contingent actions toremedy the problem. The Respondents must thereafter operate and maintain the contingentsystem until they can again demonstrate compliance with Performance Standards under therequirements above.

3.6 Remedial Action Monitoring Programs

The Respondents must implement monitoring programs the U.S. EPA approves, and submitmonitoring results to demonstrate compliance or noncompliance with the PerformanceStandards, the Amended UAO, the ROD as amended, this SOW, ARARs, and to demonstrateprotection of human health and the environment. Monitoring results must also be used to assistin the design, construction, implementation, O&M of the work, and to assess the need foradditional work at, adjacent to, or related to the Site.

As the U.S. EPA requires, the Respondents must implement a multi-media monitoring programdesigned to detect changes in water quality or concentrations of hazardous substances,contaminants, or pollutants in the leachate, groundwater, surface water, wetlands, sedimentationbasins, soil, and sediment on or in the landfill as well as at and beyond the point-of-complianceand must include upgradient, downgradient and transgradient monitoring. This program mustprovide comprehensive information by which to assess the Site's present and future impact on allenvironmental media on and around the Site.

Monitoring activities must include, but are not limited to, collection and field and laboratoryanalysis of samples from all monitoring points designated in the PDI and RD/RA Work Plans, aswell as monitoring the landfill cap itself. In-field analyses must include, at a minimum,dissolved oxygen, Eh, turbidity, groundwater elevation, pH, temperature, and specificconductance. Groundwater sampling shall be conducted using low flow sampling techniques asstipulated in the U.S. EPA guidance Ground Water Issue Paper, A Low-Flow (minimalDrawdown) Ground-Water Sampling Procedures, by Puls and Barcelona (EPA/540/S-95/504).Laboratory analyses must include the following parameters for monitored natural attenuation,including but not limited to, volatile, semivolatile, inorganic and other required parameters asdesignated by the U.S. EPA. Respondents must submit all monitoring data to the U.S. EPA andthe Illinois EPA in report form.

If, at any time, levels of contaminants exceeding ARARs are found at or beyond the point-of-compliance, or Performance Standards are not being achieved at or beyond the point-of-



compliance, the U.S. EPA may require additional work. The work must meet all ARARs andPerformance Standards before the Respondents may seek a certificate of completion of work.

3.6.1 Supplemental Sampling

In addition to the monitoring described above, Respondents must conduct supplemental randomsampling as the U.S. EPA directs, in consultation with the Illinois EPA. The purpose of thesupplemental sampling is to verify the satisfactory performance of the work. Situations thatcould trigger supplemental sampling include, but are not limited to, high precipitation events,flooding and equipment failure.

3.6.2 Integration of Monitoring Programs

To the extent practicable, the various independent monitoring programs this SOW requiresshould be integrated to avoid unnecessary duplication. The Respondents must consider factorssuch as well installation and construction, sampling and analysis procedures, and qualityassurance and quality control in designing the monitoring programs, to assure consistency andusability of wells, sample points, samples and data for more than one monitoring program.However, the Respondents remain obligated to execute each particular monitoring programindependently of any other monitoring program, even if this requires duplication of effort. Suchnecessity may arise as the various components of the work proceed toward completion at variousrates, thus requiring one monitoring program be implemented before a related program is readyto be implemented.

3.7 Institutional Controls

The Respondents must implement institutional controls, as set forth in the Amended UAO.

3.8 Correction of Remedial Action Deficiencies/Additional Response Actions

The Respondents must review data from the monitoring programs referred to herein for otherindications that may reflect: (1) non-compliance with Performance Standards; (2) deficiencies inthe work; or (3) possible amended UAO violations. The Respondents must consider potentialdeficiencies and must array various possible corrective actions to be taken to correct a particulardeficiency as part of the O & M Plan. Examples of possible deficiencies include but are notlimited to:

3.8.1 Insufficient groundwater collection rates - causing insufficient capture;

3.8.2 Failure to attain Performance Standards - at or beyond the point-of-compliance;



3.8.3 Adverse hvdrologic consequences - such as lowering the water table in the wetlands;

3.8.4 Insufficient venting of landfill gases - refer to Section 3.5:

3.8.5 Insufficient construction of landfill cap - which allows ponding or causes erosion oradverse wetland impacts due to runoff.

If a monitoring program, or any other information, indicates that: (1) Performance Standards arenot being met; (2) there are deficiencies in the work; or (3) there are possible amended UAOviolations, the Respondents must report such non-compliance or deficiency to the U.S. EPAwithin three (3) days. The Respondents must also immediately implement the appropriatecorrective action as delineated by the O&M Plan or as directed by the U.S. EPA. If the O & MPlan does not cover exceedance, non-compliance, deficiency or violation, the Respondents mustimmediately propose additional response actions to the U.S. EPA, in accordance with theamended UAO. The U.S. EPA, in consultation with the Illinois EPA, will determine whatadditional response actions must be performed by the Respondents.

In the case of residential drinking water wells, corrective action (such as, at a minimum,provision of bottled water) must occur immediately and no later than twenty-four (24) hours afterRespondents' confirmation of site-related contamination in excess of MCLs or the U.S. EPA-designated compounds.

3.9 Wetland Mitigation

The Respondents must mitigate wetlands loss due to implementing this SOW, includingmitigation necessary as a result of any environmental impacts at or beyond the point-of-compliance associated with the design, construction, implementation, or O&M of the work.Mitigation and/or activities that take place in the wetlands must be conducted in compliance withall ARARs, directives, or requirements, including those received from the U.S. Army Corps ofEngineers (USACE), Chicago District Office.

According to the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40CFR Part 300.5, Definitions: On-site means the area! extent of contamination and all suitableareas in very close proximity to the contamination necessary for implementation of the responseaction? Since the existing sediment contamination is a result of releases of contaminants fromthe Site, the contaminated sediments that must be cleaned up are part of the Site, and therefore,not subject to the permitting requirements. The authority for this is found at Section 121(e) of

For further information, please refer to Vol. 55, Federal Register, No. 46, Thursday, March 8, 1990, pp. 8688-8692, 8817-8818, 8830-8831, 8840, 8842-8844, 8850, 8860-8861 (NCP, 40 CFR Part 300).



CERCLA [42 U.S.C. Section 962 l(e)], which relieves the party conducting the response actionfrom the permit requirement.

The final RD approved by the U.S. EPA on February 23, 1999, indicated that the wetlandsediments would be over-excavated to a depth of approximately two feet below ground surface inselected areas where sediment samples indicated exceedences of the sediment quality guidelines.The areal extent of excavation was chosen at 100 feet from the buried waste limits inmostlocations, to minimize construction costs and shorten the project schedule. However, someminimal wetlands sediments excavation needs to be proposed to the U.S. EPA for review andapproval, in order to confirm for the record that the excavation is complete.

4. SCOPE OF REMEDIAL ACTION

The complete Remedial Action as required by the amended UAO, the ROD as amended, theapproved final RD, and this SOW will be conducted in two phases, and will consist of six tasks.All plans and documents, unless otherwise noted, are subject to U.S. EPA review and approval,in consultation with the Illinois EPA. Since Phase I of the RA began on August 16, 1999, andwill be completed by October 31, 1999, Task 1 below will be limited to phase II of the remedialaction.

Task 1: Phase II Remedial Action Work Plan

Task 2: Phase II Remedial Action1. Pre-construction Inspection and Meeting2. Periodic Progress Meetings3. Pre-Final Inspection for Entire Remedial Action4. Final Inspection for Entire Remedial Action5. Completion of Remedial Action Report6. Completion of Work Report

Task 3: Operation and Maintenance

Task 4: Performance Monitoring Program

Task 5: Reporting

Task 6: Groundwater Remediation and Treatment System (GWRTS)

4.1 Task 1: Phase II Remedial Action Work Plan



Within fifteen (15) days of the effective date of the amended UAO, the Respondents must awardthe contract to the Supervising Contractor, and must submit to the U.S. EPA, a Remedial ActionWork Plan. The RA Work Plan must include a:

4.1.1 Detailed Description of Remediation and Construction Activities:

4.1.2 Description of Tentative Formulation of RA Team - including the key personnel,description of duties, and lines of authority in the management of construction activities;

4.1.3 Description of Process for Selection of RA Constructor(s):

4.1.4 Project Schedule and Process to Periodically Update Project Schedule - for each majoractivity and submission of deliverables generated during the construction phase;

4.1.5 Construction Quality Control Plan (COCP1 - to implement the Construction QualityAssurance Plan and to document that the RA is constructed according to the approvedfinal RD;

4.1.6 Contingency Plan - to identify measures to be taken if containerized or exposed waste isencountered during excavation activities;

4.1.7 Review of Approved Site Safety Plan - to include monitoring procedures if exposed orcontainerized waste is encountered, to ensure that it is consistent with the contingencyplan; and

4.1.8 Project Schedule for Each Major Activity and Submission of Deliverables generatedduring the RA.

The Respondents must submit the Phase II RA Work Plan in accordance with the AmendedUAO, this SOW, the ROD as amended, the approved Final RD, applicable U.S. EPA SuperfundRemedial Design and Remedial Action Guidance, the approved O&M Plan, and any additionalguidance the U.S. EPA provides. The RA Work Plan must be consistent with the Guidance onEPA Oversight of Remedial Designs and Remedial Actions Performed by PotentiallyResponsible Parties. (OSWER Directive 9355-5.01, April 1990).

4.1.9 Site Security During RA

The Respondents must erect, repair, and maintain a fence at the WML Site, in accordance withthe approved final RD, to limit access and vandalism to the Site. Please see also Section 3.1,Fence Installation.



4.2 Task 2: Phase II Remedial Action

Within 7 Days after the Pre-Construction Inspection Meeting, and within 30 Days of the U.S.EPA approval of the RA Work Plan, the Respondents must begin and continue on-site activity asdetailed in the approved RA Work Plan, the approved final RD, the ROD as amended, this SOW,and the Amended UAO. The following ancillary activities must be completed over the course ofthe Remedial Action.

4.2.1 Phase II Pre -Construction Inspection and Meeting

This meeting must be convened by the Respondents, and must occur at or near the WML Site,within 15 Days of the U.S. EPA's approval of the RA Work Plan. At a minimum, key personnelin attendance at this meeting must include the Respondents' Project Coordinator and SupervisingContractor, the U.S. EPA's Remedial Project Manager (RPM), the U.S. EPA oversightcontractor, and the Illinois EPA. These key personnel must conduct a pre-constructioninspection and meeting in order to:

4.2.1.1. Review methods for documenting and reporting inspection data;

4.2.1.2. Review methods for distributing and storing documents and reports;

4.2.1.3. Review work area security and safety protocol;

4.2.1.4. Discuss any appropriate modifications of the construction quality assurance planto ensure that site-specific considerations are addressed; and,

4.2.1.5. Conduct a Site walk-around to verify that the design criteria, plans, andspecifications are understood and to review material and equipment storagelocations.

The Respondents must conduct an additional pre-construction inspection and meeting, if the U.S.EPA requests, to discuss quality assurance associated with placement of the geosyntheticcomponents of the landfill cover. In addition to the personnel identified above, a representativeof the Independent Quality Assurance Team (IQAT) must be present at this meeting. Adesignated person must document the pre-construction inspection and meeting(s), and minutesmust be transmitted to all parties.

4.2.2 Periodic Progress Meetings

The Respondents, the U.S. EPA, and the Illinois EPA must meet monthly during construction toreview progress on construction activities, discuss schedule adjustments, quality



assurance/quality control issues, compliance issues, and upcoming activities. To the extentpossible, the Parties will establish the dates for these meetings at the preconstruction inspectionand meeting. Telephone conference calls are acceptable as an alternative to face-to-facemeetings.

4.2.3 Pre-Final Inspection for Remedial Action

Within 15 Days after the Respondents make a preliminary determination that construction iscomplete, the Respondents must notify the U.S. EPA and the Illinois EPA for the purposes ofconducting a prefinal inspection. The prefmal inspection will consist of a walk-throughinspection of the entire Facility with the U.S. EPA and the Respondents. The inspection is todetermine whether the project is complete and consistent with all actions called for in the RODas amended, the approved final RD, the approved final RA Work Plan, the Amended UAO, andthis SOW. Any outstanding construction items discovered during the inspection must beidentified and noted. The prefinal inspection report must outline the outstanding constructionitems, actions required to resolve items, completion date for these items, and a proposed date forfinal inspection. Within 15 Days after the Pre-Final Inspection, the Respondents must submit tothe U.S. EPA, the Pre-Final Inspection Report. The Prefinal Inspection Report can be in theform of a punch list or a letter. At a minimum, the personnel noted in Section 4.2.1 of this SOWmust be present at this meeting.

4.2.4 Final Inspection for Remedial Action

Within 15 Days after completion of any work identified in the prefinal inspection report, theRespondents must notify the U.S. EPA and the Illinois EPA for the purposes of conducting afinal inspection. The final inspection must consist of a walk-through inspection of the Facilityby the U.S. EPA and the Respondents. The prefinal inspection report must be used as a checklistwith the final inspection focusing on the outstanding construction items identified in the prefinalinspection. Confirmation must be made that outstanding items have been resolved.

4.2.5 Completion of Remedial Action Report

Within 30 Days of a fully successful final inspection, the Respondents must submit a Completionof Remedial Action Report (CRAR) in accordance with the Amended UAO. In the report, aregistered professional engineer or the Respondents' Project Coordinator must state that theRemedial Action has been completed in full satisfaction of the requirements of the AmendedUAO, the ROD as amended, the approved final RD, and this SOW. The written report mustinclude documentation (e.g., test results, quality assurance reports, etc.) substantiating that theperformance standards have been met, as well as "as-built" drawings signed and stamped by aregistered professional engineer. Additionally, the CRAR must include, as an attachment, an



interim site-specific O&M Plan to supersede the generic O&M Plan contained in the approvedfinal RD. The report must contain the following statement, over a responsible corporate officialor the Respondents' Project Coordinator's signature:

"To the best of my knowledge, after thorough investigation, I certify that the informationcontained in or accompanying this submission is true, accurate, and complete. I amaware that there are significant penalties for submitting false information, including thepossibility of fine and imprisonment for knowing violations."

Upon the CRAR's completion, the U.S. EPA will issue a letter to the Respondents certifyingremedial action is complete.

4.2.6 Completion of Work Report

Within 30 Days after notification from the U.S. EPA that all work requirements under theAmended UAO, the ROD as amended, the approved final RD, and this SOW have been satisfied,including O&M requirements, the Respondents must submit a Completion of Work Report, inaccordance with the Amended UAO. In the report, a registered professional engineer or theRespondents' Project Coordinator must state that the remedial action has been completed in fullsatisfaction of the Amended UAO. The written report must include any as-built drawings thatwere not previously submitted, with a professional engineer's signature and stamp. The reportmust contain the following statement, over a responsible corporate official or the Respondents'Project Coordinator's signature:

"To the best of my knowledge, after thorough investigation, I certify that theinformation contained in or accompanying this submission is true, accurate, andcomplete. I am aware that there are significant penalties for submitting falseinformation, including the possibility of fine and imprisonment for knowingviolations."

4.3 Task 3: Operation and Maintenance

During the year following the RA Certification of Completion by the U.S. EPA, the Respondentsmust operate and maintain the remedy under the interim O&M Plan, submitted with the CRAR,and based upon the approved final RD, the approved final RA Work Plan, the ROD as amended,and this SOW. Within one year of Certification of Completion, the Respondents must eithersubmit a final O&M plan that incorporates any additional requirements for O&M, or theRespondents' Project Coordinator must certify that the interim O&M plan will be sufficient forthe remainder of the O&M period, and must continue all O&M activities in accordance with theinterim O&M Plan.



4.4 Task 4: Performance Monitoring Program

Upon receipt of approval by the U.S. EPA of the RA Work Plan, the Respondents must initiate aPerformance Monitoring Program for RA construction. The basis for the program must be theConstruction Quality Assurance Plan in the approved final RD, and the Construction QualityControl Plan to be submitted by the Respondents constructing contractor. The purpose of thePerformance Monitoring Program is to ensure that all performance standards and ARARs areattained during, and at the completion of RA construction. In addition to the quality assuranceand quality control plans, performance standards for the RA are contained in the approved finalRD, the Site Health and Safety Plan, and the Field Sampling Plan.

Upon receiving Certification of Completion from the U.S. EPA, the Respondents mustimplement the Performance Monitoring Program for groundwater and landfill gas described inthe approved final RD, and as detailed in the RA Monitoring Quality Assurance Project Plan.

4.4.1 Dust Control

The Respondents must, in accordance with the approved final RD, implement dust controlmeasures, as necessary, to control the generation of visible emissions at the WML Siteboundary/fence line during the construction phase of the RA and to ensure that air emissions areminimized.

4.5 Task 5: Reporting

In addition to the one-time reports detailed above, the Respondents must provide progress reportsto the U.S. EPA, with a copy to the Illinois EPA, at the following intervals:

No. Description of Report Due

4.5.1 RA Construction Progress Monthly during RA4.5.2 Cover and Landfill Gas O&M Quarterly4.5.3 Long-Term Groundwater Monitoring Semi-Annual

Respondents must submit periodic groundwater monitoring results semi-annually (i.e., two (2)times per year), within 30 days of receiving the final reports from the laboratory.

Annual groundwater monitoring reports must include cumulative sampling results for all wellsfor the contaminants quantified from the approved final RD. Each annual report must furtherinclude a summary table listing all wells in which contaminant concentrations exceed establishedperformance standards, showing the contaminant and its concentration. An updatedpotentiometric surface map with monitoring well locations for the shallow and deep ground



water units must accompany each annual report. Annual groundwater monitoring reports mustalso include trend analyses in the form of maps, charts, tables, etc., to assist the U.S. EPA and theIllinois EPA assess natural groundwater attenuation at the Site. In addition, the annualgroundwater monitoring reports must include maps or charts that illustrate the extent of thegroundwater contamination, and the analytical values for each sampling point.

The Respondents may propose modifications to the Performance Monitoring Program inconjunction with the annual reports. The proposed modifications may include changes to thenumber and location of sample points, sampling frequency, analytes, and reporting requirements.Any proposed modifications to the Performance Monitoring Program are subject to the U.S.EPA's review and approval, in consultation with the Illinois EPA.

4.6 Task 6: Groundwater Remediation and Treatment System

4.6.1 Criteria for Evaluation of Natural Attenuation

In general, the U.S. EPA will follow the April 21, 1999, Office of Solid Waste and EmergencyResponse (OSWER) Directive No. 9200-4-17P, C/se of Monitored Natural Attenuation atSuperfund, RCRA Corrective Action, and Underground Storage Tank Sites, as guidance inevaluating the effectiveness of natural attenuation of contaminated groundwater at the TCLFSite. This OSWER Directive was public noticed in the Federal Register (Volume 64, Number89) on May 10, 1999.

The Performance Monitoring Program will be conducted to monitor and ensure the remedy'seffectiveness. At each 5-year review or earlier, as necessary, the U.S. EPA, in consultation withthe Illinois EPA, will evaluate relevant criteria in order to determine the need for implementationof the GWRTS. The U.S. EPA anticipates that this decision will be part of the 5-year reviewprocess required for sites where wastes are left on site. However, the U.S. EPA is authorized toimplement the contingency at any time before or after a five-year interval, if conditions warrantit. If the data available at the first such review is insufficient to determine the need for GWRTSimplementation, evaluation of remedy performance will be completed in the subsequent reviewor at some earlier time to be established during the initial 5-year review.

4.6.2 Implementation of the GWRTS

Should the U.S. EPA determine, in consultation with the Illinois EPA, and in accordance withthe Amended UAO, Section 4.6.1 of this SOW, and the ROD as amended, that the Respondentsmust implement the GWRTS, the U.S. EPA will issue a Notice of Authorization to Proceed withthe GWRTS to the Respondents, to proceed with the design, construction and implementation ofthe GWRTS. Upon receipt from the U.S. EPA of such a determination in writing, theRespondents must, within 60 Days, submit a 30% complete conceptual design for the GWRTS,



including provision for disposal of treated water. The Respondents must submit a 95% completedesign to the U.S. EPA within ninety (90) Days of receiving the U.S. EPA comments on the 30%design. The Respondents must submit a 100% complete design to the U.S. EPA within thirty(30) Days of receipt of the U.S. EPA comments on the 95% design.

5. Summary of Major Deliverables/Project Schedule

No. Submission/Event Due Date

5.1 Award RA Contract to Within Fifteen (15) Days of Amended UAOEffective Date. Supervising Contractor

5.2 RA Work Plan - Phase II

5.3 Phase II Pre-ConstructionInspection Meeting

No. Submission/Event

5.4 Initiate Phase II Construction

5.5 Completion of Phase I andPhase II Construction

5.6 Pre-fmal Inspection

5.7 Pre-fmal Inspection Report

5.8 Final Inspection

5.9 Remedial ActionCompletion Report

Within Fifteen (15) Days of Amended UAOEffective Date.

Fifteen (15) Days After U.S. EPA's Approval ofRA Work Plan or As Approved by U.S. EPA in RAConstruction Schedule.

Within Seven (7) Days After the Pre-ConstructionInspection Meeting.

As Approved by U.S. EPA in RA ConstructionSchedule.

Notice to U.S. EPA No Later than Fifteen (15) DaysAfter Completion of Construction.

Within Fifteen (15) Days After Completion ofPrefinal Inspection.

Notice to U.S. EPA No Later than Fifteen (15) DaysAfter Completion of Work Identified in PrefinalInspection Report.

Thirty (30) Days After Fully Successful FinalInspection.



No. Submission/Event

5.9.1 Interim Site-Specific Operationand Maintenance (O&M) Plan

5.10 Final O&M Plan

5.11 30% Design, GWRTS

5.12 95% Complete Design, GWRTS

With the Remedial Action Completion Report.

Within Three Hundred Sixty-Five (365) Days ofCertification of Completion of RA (if necessary).

Sixty (60) Days After Receipt of Determination byU.S. EPA That GWRTS Must Be Implemented.

Ninety (90) Days After Receiving U.S. EPAComments on the 30% Design.

5.13 100% Complete Design, GWRTS Thirty (30) Days After Receiving U.S. EPAComments on the 95% Complete Design.

5.14 Implementation of RAfor the GWRTS

5.15 Construction of the GWRTS

5.16 Completion of Work Report

Must Follow the Time-Frames in 5.1 Through 5.4,and 5.6 Through 5.10 Above.

As U.S. EPA Approves in RA ConstructionSchedule.

Within Thirty (30) Days After SuccessfullyCompleting All Required Remedial ActivitiesIncluding O&M; in Accordance with the AmendedUAO, and Section 4.2.6 of this SOW.


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