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1 Engineering Management Support, Inc. Memorandum To: Jesse Aviles, EPA RPM, VB/I70 Superfund Site From: Timothy C. Shangraw Date: December 20, 2017 Re: POLREP #29 - Vasquez Boulevard/Interstate 70 (VB/I70) Superfund Site, Operable Unit 2, Removal Action ======================================================================= On behalf of the City and County of Denver (Respondent), Engineering Management Support, Inc. (EMSI) is submitting this Pollution Report (POLREP #29) in accordance with Section 4.c of Appendix C to the Administrative Settlement Agreement and Order on Consent for Removal Action, for the subject Superfund Site (the Site). This report follows the outline detailed in Section 4.c of Appendix C, and contains pertinent new information specified in the Superfund Removal Procedures, Removal Response Reporting: POLREP and On-Scene Coordinator (OSC) Reports (EPA, 1994). Section I Heading The date, site name, report author, report recipient, and report number are presented above. Section II Response Information This reporting period extended from November 1 through 30, 2017 during which time, the following activities occurred: Excavation of Regulated Asbestos-Contaminated Soils (RACS) and hauling to and disposing at the Denver Arapahoe Disposal Site (DADS); Excavation of non-racs and hauling to and disposing at DADS; Construction of the concrete box conduit, outlet wing walls, and open channel sidewall footings through the Coliseum Parking Lot (CPL); Pumping and treatment of groundwater from dewatering zones 1, 2, 3a, and 3b; Construction of the drop inlet structure and reinforced box conduits (RBCs) in dewatering zone 2 (beneath Delgany sanitary sewers); Construction of lateral drain boxes in dewatering zone 3a; On-site and off-site monitoring for air quality, dust, and odors; and Updated the groundwater flow model to reflect new hydrogeologic conditions observed during construction. The volumes of RACS and non-racs excavated and managed, and the volumes of water pumped, treated, and returned to the South Platte River, are summarized in Table 1. On-site monitoring for volatile organic compounds (including methane), odor, and visible dust
2 Memorandum POLREP #29 VB/I70, OU2 removal Action December 20, 2017 Page 2 emissions occurred continuously during excavation activities. In addition, monitoring for airborne asbestos fibers proceeded in accordance with Section 5.5 of the Colorado Department of Public Health and Environment (CDPHE) Solid Waste Regulations. Due to their overall size, daily monitoring reports for volatile organic compounds, odor, dust, and asbestos are being submitted under separate cover. Off-Site monitoring by Denver for PM 10, airborne lead and arsenic at four locations within the monitoring boundary continued throughout the reporting period. Sampling from these stations occurred every sixth day throughout the month. Results were all below Occupational Safety and Health Administration 8-hour limits and National Ambient Air Quality Standards. Monthly monitoring report are posted on the Globeville Landing Outfall (GLO) project web site at: As part of the GLO project s Community Outreach program, a community hotline was operated. No complaints were received during the reporting period. The Community Advisory Group (CAG) held its ninth and tenth meetings on November 14 th and December 12 th, respectively. Meeting minutes are posted on the VB/I-70 Superfund Community Advisory Group web site. The next CAG meeting is scheduled for January 9, The following project meetings were held in November: Weekly GLO Project Status Meetings (November 2, 9, and 30, 2017); EPA monthly progress meeting (November 15, 2017); and Technical meetings with EPA to discuss leaving sheet along southern in place (November 14 and 29, 2017). Lastly, a 3-week look-ahead Construction Schedule is attached to this POLREP. Section III Issues, Resolutions, and Planned Activities A Quality Assurance Audit was performed on Asbestos-Containing Soils Daily Reports (ACSRs) prepared by Kleinfelder during the month of October for consistency with Section 5.5 of Colorado s Solid Waste Regulations (CSWRs) and the Final Materials Management Plan (MMP) (EMSI, 2016). No deficiencies were noted. A copy of the Audit Report is attached to this POLREP. Monitoring of treated effluent from the GLO project continued during the reporting period in accordance with Discharge Permit Number CO All monitored parameters met discharge limits during the month. The exceedance of potentially dissolved selenium in treatment plant effluent during October was researched and confirmed to exceed the permit limit. As stated in last month s POLREP, plant operating parameters prior to and during the sampling event were found to be within normal operating ranges and sampling procedures, preservation, chain of custody, and delivery procedures were followed exactly as in the past. As shown in the
3 Memorandum POLREP #29 VB/I70, OU2 removal Action December 20, 2017 Page 3 summary table attached to this POLREP, historical plant influent concentrations, including those from October and November, were less than the effluent permit limit. Consequently, the October exceedance was determined to be an anomaly. Beginning in November, the plant operator initiated collection of weekly effluent samples for metals analyses and simply holding them until the end of the month for analyses should a first-of-the-month sample result exceed a permit limit. Planned activities for the next reporting period consist of: Continue construction of wing walls, open channel sidewall footings, and open channel sidewalls through the CPL and GLP; Continued construction of lateral drain boxes in the GLP; Continued construction of outlet structures and riprap downstream of the RBCs in the GLP; Continued final grading of the drainage channel in preparation for placement of the strengthening layer; Continued dewatering in zones 1, 2, 3a and 3b; and Continued on-site and off-site monitoring of air quality. To maintain effective and transparent communication during GLO implementation, EPA and CDPHE personnel are invited to participate in weekly coordination meetings at Kiewit s RiNo office. The next two EPA Monthly Status meetings will be held on December 20 th and January 17 th at 9:00 in the Webb building. Please call Jennifer Luthi ( ) or me ( ) if you have any questions. Attachments: November 2017 Summary of GLO Construction Activities 3-Week Look-Ahead Schedule QA Audit Report #6 Summary of Effluent and Influent Analytical Results
4 Table 1 - November 2017 Construction Summary Current Month QTY QTY to date Comments EXCAVATION/HAULING # of days Excavation occurred Globeville park 9 97 # of days Excavation occurred Municipal Landfill 4 35 Volume of Racs Excavated (CY) 5,908 89,163 From Globeville Park and Coliseum Parking lot Volume of Racs hauled to DADS (CY) 5,908 89,163 From Globeville Park and Coliseum Parking lot Volume of Non-Racs Excavated (CY) ,969 Volume of Non-Racs stockpiled onsite (CY) 12,606 Volume of Non-Racs hauled to DADS (CY) ,363 Material was Non-RACS from Over-Exc area (unsuitable) Volume Hauled to Clean Harbors (CY) 0 GROUT AND STONE COLUMNS number of grout columns installed this month 0 1,091 All Stone and Grout columns are complete Grout column SPT testing results 0 0 All Stone and Grout columns are complete number of stone columns installed per month All Stone and Grout columns are complete stone column test results 0 0 All Stone and Grout columns are complete REMEDIATION DEWATERING AND TREATMENT LF of underdrain/wick wells installed 650 Volume of water transported and treated at MFEI 1,687,496 23,569,371 Volume of treated water, including dilution, discharged to S. Platte 1,721,857 24,035,657 Analytical results 0 Oct DMR submitted CONSTRUCITION DEWATERING status of permit compliance LINER INSTALLATION % complete during the month N/A QC/QA testing results N/A Issues and Resolutions N/A MODCP RESULTS Daily Methane, Odor, and Dust monitoring reports Issues and Resolutions COMMUNITY OUTREACH Summary of Calls to hotline Issues and Resolutions
5 Globeville Phase 1A Schedule Title Current Week Phase 1A 3 week schedule Monday, December 04, 2017 Item Activity Description Work performed by Start Finish Shift Current Forecast Forecast Forecast Comments 12/04 12/04 12/05 12/05 12/06 12/06 12/07 12/07 12/08 12/08 12/09 12/09 12/10 12/10 12/11 12/11 12/12 12/12 12/13 12/13 12/14 12/14 12/15 12/15 12/16 12/16 12/17 12/17 12/18 12/18 12/19 12/19 12/20 12/20 12/21 12/21 12/22 12/22 12/23 12/23 12/24 12/24 12/25 12/25 12/26 12/26 12/27 12/27 12/28 12/28 12/29 12/29 12/30 12/30 12/31 12/31 M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su 1 2 EARTHWORK (Park Channel) 3 Excavate Tie in between Park Walls and Arkins Ames 12/13/17 12/20/17 day 4 5 OUTFALL CHANNEL 6 Excavate for 42" type M Soil Rip Rap Ames 11/28/17 12/05/17 day 7 Place 42" Type M Soil Rip Rap Ames 11/30/17 12/05/17 day 8 Install Soil Wraps Ames 12/06/17 12/12/17 day 9 Install type 2 bedding above soil wraps Ames 12/06/17 12/18/17 day 10 Install Rip Rap above bedding Ames 12/18/17 12/22/ DROP OUTLET 15 F/R/P Wing wall Walls (A1) Ames 12/11/17 12/15/17 day 16 F/R/PCIP box Deck Ames 12/04/17 12/11/17 day 17 F/R/P headwall Ames 12/18/17 12/22/17 day S. LATERAL DRAIN BOX 22 Form Deck sections 1-6 Ames 12/11/17 12/29/17 day N. LATERAL DRAIN BOX 26 F/R/P N. Lateral Footings 1-4 Ames 11/30/17 12/17/17 day 27 F/R/P N. Lateral Walls sections 1-4 Ames 12/18/17 01/10/18 day EAST PARK WALL 33 F/R/P East Park wall section 2 Footing Ames 11/27/17 12/06/17 day WEST PARK WALL 38 F/R/P West Park wall section 1 Footing Ames 11/27/17 12/06/17 day COLISEUM CONDUIT 41 Seal joints Ames 11/27/17 12/08/17 day 42
6 Globeville Phase 1A Schedule Title Current Week Phase 1A 3 week schedule Monday, December 04, 2017 Item Activity Description Work performed by Start Finish Shift Current Forecast Forecast Forecast Comments 12/04 12/04 12/05 12/05 12/06 12/06 12/07 12/07 12/08 12/08 12/09 12/09 12/10 12/10 12/11 12/11 12/12 12/12 12/13 12/13 12/14 12/14 12/15 12/15 12/16 12/16 12/17 12/17 12/18 12/18 12/19 12/19 12/20 12/20 12/21 12/21 12/22 12/22 12/23 12/23 12/24 12/24 12/25 12/25 12/26 12/26 12/27 12/27 12/28 12/28 12/29 12/29 12/30 12/30 12/31 12/31 M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su 43 COLISEUM CONDUIT OUTLET 44 Excavate/Finegrade Outlet Apron Ames 12/06/17 12/08/17 day 45 F/R/P Apron Ames 12/08/17 12/18/17 day N. Coliseum Wall 48 F/R/P N. Colisuem Walls Ames 12/18/17 01/15/18 day S. Coliseum Wall 51 F/R/P S. Colisuem Walls Ames 12/05/17 01/15/18 day S. Bridge Abutment 55 Finegrade Abutment Footings Ames 12/05/17 12/07/17 day 56 F/R/P Abutment/WW footings Ames 12/07/17 12/15/17 day Arkins outlet 59 F/R/P S. A1, J1, K1 Wing wall footings Ames 11/30/17 12/20/17 day
7 Engineering Management Support, Inc. QA Audit Report #7 To: From: cc: Matt Ceresa, Kiewit, Tim Shangraw, EMSI Jennifer Luthi, DEH; Steve Gonzales, DEH; Bret Banwart (DPW); Brian McLaren (DPW); and Patrick Riley (DPW) Date: December 6, 2017 Re: Audit of Kleinfelder CABI Notes, October 2017, Globeville Landing Outfall Project Representatives from Engineering Management Support, Inc. (EMSI) reviewed Asbestos- Containing Soils Daily Reports (ACSRs) prepared by Kleinfelder during the month of October 2017 for consistency with Section 5.5 of Colorado s Solid Waste Regulations (CSWRs) and the Final Materials Management Plan (MMP) (EMSI, 2016). Specifically, the audit involved an independent evaluation of CABI notes consisting of checking for: i. Site description including location; ii. Descriptions of site activities; iii. Descriptions of equipment in use; iv. Descriptions of hand removals (including locations); v. Descriptions of types of debris identified; vi. Descriptions of suspect material identified; vii. Friability of ACM identified (as determined by a CABI); viii. Sampling, if conducted (all sampling shall be conducted by a CABI); ix. Decontamination visual inspection and clearances; x. Excavation visual inspection and clearances; xi. Spill response activities; xii. Observations of visible emissions and responses; xiii. Observations of non-earthen material or the appearance of fill; and xiv. Observations of other indicators of impact to soils. Page 1
8 QA Audit Report #7, GLO Project December 6, 2017 Our process for reviewing Kleinfelder s CABI daily logs consisted of examining daily logs for the items noted above, using the attached spreadsheet as a guide for identification and documentation purposes. The review entailed reading/reviewing descriptions and notes for anything that stood out and/or that was not documented properly. If an issue was identified, it was marked on the spreadsheet with a note below it. When review of a group of logs was complete, we forwarded our spreadsheet with notes to a Kleinfelder representative. That person then corrected a noted issue and/or responded with a verbal clarification. Corrected/revised CABI logs were then uploaded to Teambinder and in turn, EMSI representatives downloaded and reviewed the corrected/revised log. When EMSI representatives approved the correction/revision, the spreadsheet was updated. All change communication was documented in s. AUDIT FINDINGS As shown in the attached table, all final audited parameters complied with Section 5.5 of the CSWRs and the MMP during the month of October. ACTION REQUIRED No corrective action is required. Denver and EMSI will continue to monitor Ames/Kleinfelder s implementation of agreed-to reporting procedures and identify any area(s) in need of improvement during monthly progress meetings and if necessary, in subsequent QA Audit Reports. Page 2
9 Oct 4-Oct 31 QA of CABI daily logs per Colorado Regulation L (Documentation) and Final Materials Management Plan Page 1 1C 1A 1B 1D Personnel Date Grid Grid Site Description Description Description of Description Description Friability per CABI diagram description of site of equipment hand removals of types of suspect of ACMs Notes agree w including activities use including of debris materials discussed CABI location locations Lanaia Carveth 10/4/17 yes yes yes yes yes yes yes yes yes Billie Godby 10/4/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/5/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/5/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/6/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/6/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/7/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/10/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/11/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/11/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/12/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/12/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/13/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/14/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/16/17 yes yes yes yes yes yes yes yes yes Tim Ponder 10/16/17 yes yes yes yes yes yes yes yes yes Tim Ponder 10/17/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/18/17 yes yes yes yes yes yes yes yes yes Tim Ponder 10/18/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/19/17 yes yes yes yes yes yes yes yes yes Mitchell Reese 10/19/17 yes yes yes yes yes yes yes yes yes Tim Ponder 10/19/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/20/17 yes yes yes yes yes yes yes yes yes Tim Ponder 10/20/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/21/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/23/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/23/17 yes yes yes yes yes yes yes yes yes Tim Ponder 10/24/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/24/17 yes yes yes yes yes yes yes yes yes
10 Tyler Godby 10/25/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/25/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/26/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/26/17 yes yes yes yes yes yes yes yes yes Mitchell Reese 10/27/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/28/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/30/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/30/17 yes yes yes yes yes yes yes yes yes Tyler Godby 10/31/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 10/31/17 yes yes yes yes yes yes yes yes yes Notes: 1) NVE = no visible emissions observed 2) in the table "yes" designates that documentation was completed
11 Oct 4-Oct 31 QA of CABI daily logs per Colorado Regulation L (Documentation) and Final Materials Management Plan Page 2 2A and 2B 4 5B 1E 1F Personnel Date Bulk sampling Decontamination Spill Observations Observations Observations Photo-log / documentation visual inspection response of visible of non-earthen of other description and clearance activities emissions / material / indicators of Reponses commented soil impact Lanaia Carveth 10/4/17 Not conducted yes No spills NVE yes yes yes Billie Godby 10/4/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/5/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/5/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/6/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/6/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/7/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/10/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/11/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/11/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/12/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/12/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/13/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/14/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/16/17 Not conducted yes No spills NVE yes yes yes Tim Ponder 10/16/17 Not conducted yes No spills NVE yes yes yes Tim Ponder 10/17/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/18/17 Not conducted yes No spills NVE yes yes yes Tim Ponder 10/18/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/19/17 Not conducted yes No spills NVE yes yes yes Mitchell Reese 10/19/17 Not conducted yes No spills NVE yes yes yes Tim Ponder 10/19/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/20/17 Not conducted yes No spills NVE yes yes yes Tim Ponder 10/20/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/21/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/23/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/23/17 Not conducted yes No spills NVE yes yes yes Tim Ponder 10/24/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/24/17 Not conducted yes No spills NVE yes yes yes
12 Tyler Godby 10/25/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/25/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/26/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/26/17 Not conducted yes No spills NVE yes yes yes Mitchell Reese 10/27/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/28/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/30/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/30/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 10/31/17 Not conducted yes No spills NVE yes yes yes Lanaia Carveth 10/31/17 Not conducted yes No spills NVE yes yes yes
13 Historical Influent and Effluent Water Quality, GLO Water Treatment Plant Parameter Unit Sample Frequency Effluent Permit Limit May-17 Jun-17 Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Flow Rate (monthly ave) gpm Continuous 100 N/R 95.5 N/R 96.8 N/R 91.2 N/R 84.5 N/R 54.6 N/R 38.5 N/R 32.9 ph standard units 3 days/wk N/R N/R N/R N/R N/R N/R N/R Total Residual Chlorine mg/l 3 days/wk 0.5 N/R N/R N/R N/R N/R N/R N/R Oil and Grease (visual) visual presence 3 days/wk Report N/R None N/R None N/R None N/R None N/R None N/R None N/R None Oil and Grease (lab) mg/l Contingent upon visual presence 10 N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R Total Suspended Solids mg/l Weekly N/R <5-21 N/R 1.4J N/R <5-2.5J N/R < N/R N/R N/R < E. Coli #/100 ml Weekly N/R 0-2 N/R 0 N/R 0 N/R N/R 0-54 N/R 0-1 N/R 0-1 BOD 5 mg/l Monthly N/R <2 N/R <1 N/R <1 N/R 1.1 N/R 2.6 N/R <1.0 N/R 11.4 Total Inorganic Nitrogen mg/l Monthly 10 N/R 8.4 N/R 8.7 N/R 8.7 N/R 8.3 N/R 5.9 N/R 6.8 N/R 5.9 Ammonia mg/l Monthly Report N/R 0.48 N/R 0.3 N/R 0.26 N/R 0.38 N/R 0.38 N/R 0.04 N/R 0.38 Arsenic, total recoverable ug/l Monthly < < Cadmium, potentially dissolved ug/l Monthly < < < < < < <0.2 Copper, potentially dissolved ug/l Monthly 5,656-6, < Iron, total recoverable ug/l Monthly 253, < < Lead, total recoverable ug/l Monthly 13, < <1.0 <1.0 < < <1.0 Lead, potentially dissolved ug/l Monthly 2, < <1.0 < < <1.0 Mercury, total ug/l Monthly 3.5 N/R <0.2 N/R <0.2 N/R <0.1 N/R <0.1 N/R <0.1 N/R 2.0 N/R 0.6 Selenium, potentially dissolved ug/l Monthly < WET Testing LC 50 Quarterly 100 N/R N/R N/R Failed, then passed N/R N/R N/R N/R N/R N/R N/R Passsed N/R N/R shaded cell indicates compliance with permit limit shaded cell indicates influent exceeds discharge limit; treatment required shaded cell indicates effluent exceeds permit limit * Metals Screen required per Section 1.A.3 of GLO Discharge Permit. VOC and SVOC screens confirmed only trace detections. ** Monitored parameters required per Section 1.A.2 of GLO Discharge Permit N/R Not Required Jul-17 Aug-17 Sep-17 Oct-17 Nov-17
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