ER

RESTORATION

Site Work Plan – USS Lead Zone 2 Excavation

Emergency and Rapid Response Services
U.S. Smelter and Lead Residential Area Superfund Site- Zone 2,
East Chicago, Indiana

April 10, 2017

Prepared for
U.S. Environmental Protection Agency
Region 5
77 West Jackson Blvd.
Chicago, IL 60604

Under Contract No.: EP-S4-16-04

Task Order: 031
Project No: UE5-31
 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

1.0 INTRODUCTION

This Work Plan has been prepared by Environmental Restoration, LLC (ER) on behalf of U.S.
Environmental Protection Agency Region 5 (EPA) to support the activities authorized under Task Order
(TO) #0031 of Contract EP-S4-16-02. This plan describes the project management, logistical procedures
and operation approach that will be carried out by ER at the USS Lead Site (site) during the removal of lead
and arsenic contaminated soils from high priority residential properties in Zone 2 during the 2017
construction season.

In general, the practices, procedures and activities outlined in this Work Plan are intended to be consistent
with those employed during the ongoing remedial action in Zone 3 of the USS Lead Site. This Work Plan
includes the Site Security Plan. Additional project plans will be submitted separately. These include: A
Health & Safety Plan, Traffic Management Plan, and Storm Water Pollution Prevention Plan.

Revisions to this plan may be necessary as work commences and site conditions warrant it or if additional
properties are added to the scope of work. Revisions to the plan will be approved by EPA prior to
implementation. Approved revisions will be incorporated into the plan and the revised plan will be
distributed to the appropriate project participants.

1.1. SITE LOCATION

The portion of the USS Lead site relevant to this Work Plan at present consists of 72 parcels located in
Zone 2. Zone 2 is bordered on the west by McCook Ave and on the east by Kennedy Ave. It is bordered
on the south by 151st Street and on the north by East Chicago Ave. Also included in the site is the site
office area, laydown yard, backfill stockpile and waste soil intermediate stockpile which are all located on
open land at the Chemours Company property, 5135 Kennedy Avenue in East Chicago.

This Work Plan addresses removal activities associated with the 72 parcels that have been identified by
EPA as high priority Zone 2 properties. These properties are identified in Attachment A.

1.2 CONTRACT & TASK ORDER INFORMATION

The period of performance for TO #31 is 04/05/2017 to 01/31/2018 and the current obligated amount of
award is $3,700,000. The EPA On-Scene Coordinator (OSC) and Task Order Contracting Officer
Representative (TOCOR) for this project is Mr. Dan Haag.

Project activities, as currently contemplated, will be conducted under both the Davis Bacon Act (DBA) and
the Service Contract Act (SCA). This Work Plan assumes the following primary project tasks and
corresponding Wage Determination. Final assignment of Wage Determinations will be made by EPA’s
Contracting Officer.
• Travel………………….…………………..SCA
• Site Setup…………………………………SCA
• Excavation, direct loading & disposal…..SCA (no intermediate stockpile)
• Excavation and transfer to stockpile….…DBA
• Loadout from stockpile to landfill………...SCA
• Backfill………………………………………SCA/DBA (matches excavation WD)
• Final Grading & Site Restoration………...SCA/DBA (matches excavation WD)

The contract mobilization point for this site is Chicago, Illinois. The CONUS lodging rate for Lake County,
Indiana is $99.00/night. The CONUS M&IE rate for Lake County, Indiana is $59.00/night.

2.0 PROJECT OBJECTIVES AND SCOPE

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 1 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

The objective of the project is to conduct a removal action at the site to mitigate the threats to public health,
welfare and the environment posed by the presence of uncontrolled hazardous substances. The project
scope, as outlined by the Statement of Work (SOW) includes the following elements:

1. Development of site plans, including a Work Plan, Sampling Plan/QAPP, Traffic Management Plan,
Construction Storm Water Pollution Prevention Plan, site-specific HASP, Site Security Plan and
Emergency Contingency Plan;
2. Development of an air monitoring plan and implementation of dust control measures to ensure worker
and public health protection;
3. Provision for site security measures as necessary;
4. Excavation of soil at parcels where lead in the top six inches of soil is equal to or exceeds 1,200
mg/kg and/or arsenic is equal to or exceeds 68 mg/kg, as determined by EPA's RD sampling. Soil will
be excavated to a depth of approximately two feet bgs, to eliminate any direct contact and inhalation
threats. Excavated material that fails toxicity characteristic leaching procedure (TCLP) for lead may
be treated with a fixation agent prior to disposal. Excavation will cease if lead and/or arsenic
concentrations are less than 400 mg/kg for lead and 26 mg/kg for arsenic;
5. Excavation of soil at residential parcels where lead in the top six inches is equal to or exceeds 400
mg/kg, as determined by EPA's RD sampling, and where a member of a sensitive population resides
(children 6 years old and under or a pregnant woman). Soil will be excavated to a depth of
approximately two feet bgs, to eliminate any direct contact and inhalation threats. Excavated material
that fails toxicity characteristic leaching procedure (TCLP) for lead may be treated with a fixation
agent prior to disposal. Excavation will cease if lead and/or arsenic concentrations are less than 400
mg/kg for lead and 26 mg/kg for arsenic;
6. Excavation of soil at residential parcels where lead in the top twenty-four inches is equal to or
exceeds 400 mg/kg, as determined by EPA's RD sampling, and where a child with a blood lead level
of 10 ug/dL or greater resides. Soil will be excavated to a depth of approximately two feet bgs, to
eliminate any direct contact and inhalation threats. Excavated material that fails toxicity characteristic
leaching procedure (TCLP) for lead may be treated with a fixation agent prior to disposal. Excavation
will cease if lead and/or arsenic concentrations are less than 400 mg/kg for lead and 26 mg/kg for
arsenic;
7. If lead levels below 400 mg/kg or arsenic levels below 26 mg/kg cannot be achieved at an excavation
depth of approximately two feet bgs, the excavation may advance deeper as directed by the OSC or
the excavation will cease and a visible barrier will be placed at the bottom of the excavation to alert
the property owner of the existence of high levels of lead and/or arsenic. In such instances and
consistent with the Record of Decision, institutional controls (ICs) will be implemented as part of the
2017 removal action to ensure the users of the property are not exposed to the contaminants of
concern in soil;
8. Replacement of excavated soil with clean soil, including 6 inches of top soil to maintain the original
grade. Each yard will be restored as close as practicable to its pre-removal condition. Once the
parcels are sodded or seeded, removal site control of the sod or seed, including, watering, fertilizing,
and cutting, will be conducted for the period prescribed in the final remedial design. After the initial
maintenance period, property owners will be responsible for the maintenance of their own yards. Tree
and shrubs shall be warranted for a period of one year from the time of construction and defective
trees and shrubs shall be replaced, as necessary, if identified within the warranty period. The
aforementioned work shall be documented in a Work Plan;
9. Transportation and disposal off-site of any hazardous substances, pollutants and contaminants at a
CERCLA-approved disposal facility in accordance with EPA's Off-Site Rule (40 CFR § 300.440) as
directed by the OSC;
10. Support the EPA Superfund Job Training Initiative; and
11. Performance of any other response actions to address any release or threatened release of a
hazardous substance, pollutant or contaminant that the EPA On-Scene Coordinator (OSC)
determines may pose an imminent and substantial endangerment to the public health or the
environment.

3.0 PROJECT ORGANIZATION, STAFFING AND RESOURCES

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 2 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

ER may request, on a case by case basis, authorization from the EPA Contracting Officer to charge per
diem and lodging for key personnel. Staffing levels outlined below and in Attachment B reflect the crew at
standard staffing. Staffing would ramp up to this level over a period of 3 weeks. A third excavation team
may be added to complete the exaction and backfill at several large parcels located within Zone 2 (1011
148th St. E & W, and 4901-07 Kennedy Ave. W).

Rental equipment used at the site will be procured from local sources when feasible to minimize mobilization
costs. In general, equipment and materials will be brought in on an as needed basis. The initial ERRS
crew will consist of:

Qty Classification
1 Response Manager
1 Field Cost Accountant
1 Foreman / Lead Laborer
1 Site Documentation Coordinator (billed as FCA)
2 Documentation Technician (billed as laborer)
5 Equipment Operator
16 Laborers
9 Truck Drivers
1 H&S Officer (onsite as needed)

As the nature and intensity of site activities change, the crew size and makeup may change with the consent
of the EPA TOCOR.

Equipment List:

Qty Description
8 Pickup trucks
4 1-ton stake bed truck
1 40’ secure storage container for materials
3 Mini-excavator ( 2 x 11,000 lb.) & (8,000 lb.) rubber tracked
2 Track skid steer loader 9,000 to 10,000 lb
1 Skid steer forks attachment & easy grader attachment
1 2,000 to 3,000 gallon water truck
2 Vibratory plate compactor
8 5 yd3 single axle dump trucks
1 2 yd3 single axle dump truck
2 Office trailer (ERRS & EPA/START)
2 6-10 ton equipment tag trailers
1 3 yd3 wheel loader (staging area)

As the nature and intensity of site activities changes, additional equipment may be mobilized with the
consent of the EPA TOCOR.

The crew at typical staffing will be organized into seven teams: site management team, excavation
teams (2), backfill teams (2), restoration/punch list team, and property coordination team:

 The excavation teams will focus on the excavation of contaminated soil from each property.
The excavation teams include trucks used to haul contaminated soil to the Chemours facility.
These teams will also be responsible for dust suppression activities, fencing properties, and
potholing utilities.

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 3 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

 The backfill teams will follow the excavation crew and will be responsible for the hauling fill from
the laydown yard, placement and compaction of the fill, and placement of topsoil.

 The restoration team will be responsible for establishing final grade, revegetation of properties,
removal of temporary fencing when restoration is completed, sod watering, and punch list
items.

 The property coordination team will be responsible for scheduling and documenting utility
locates, site video and photo documentation, documentation management, and homeowner
completion agreements.

 These teams will be managed by the RM and lead foreman who will be supported by the FCA,
a runner (laborer) and Regional Health & Safety Manager.

A third excavation crew and associated equipment may be mobilized to complete the excavation and backfill
of several large parcels: 1011 148th St E & W, and 4901-07 Kennedy.

4.0 PROJECT DOCUMENTATION AND MEETINGS

A site orientation meeting will be held with all crew members on the day of mobilization. The primary focus
of the meeting will be a comprehensive review of site plans including the Site Health & Safety Plan (HASP).
All crew members will acknowledge the HASP by signature.

All crew members, subcontractors, and visitors will be required to sign in and out each day on the Site Log.
A daily safety/operations meeting will be held each morning with the crew to review the planned activities
for the day, relevant AHAs and solicit crew feedback. This meeting will be used to formally communicate
changes in the HASP and other site specific plans to the crew. The covered topics and attendees will be
documented on the Daily Tailgate Safety Form.

Daily Work Orders (DWO) will be utilized to document EPA authorized activities and resources. The DWO
will also track progress towards completing the authorized activities. A draft DWO will be generated daily
by the RM for the following days planned activities.

All forms, video and photographic documentation will be uploaded to a mass storage device onsite which
will be backed up daily to a cloud based storage system.

The forms in Attachment D and listed below will be used to document site work:

 Property assessment and inspection form

 Landscape documentation form
 ER consent for access to property
 Impacted soil haul sheet
 Clean backfill & topsoil haul sheet
 Sod watering log
 Property close out form
 EPA satisfaction survey

4.1. COST TRACKING

RCMS 1900-55’s will be generated daily to track project costs. The 1900 for the previous day’s activities
will presented to the EPA TOCOR for review by 12:00 p.m. Costs will be tracked using the following tasks:

 Level 1 – Administrative, Operations, Mobe/Demobe, Health & Safety

 Level 2 – Excavation, Backfill, Restoration, Property Coordination, Staging Area
 Level 3 – Property ID
 Level 4 – Construction Debris, >24” Excavation

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 4 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

5.0 SCHEDULE

The standard work week will be Monday through Friday with the crew working approximately 40 to 45 site
hours.

The period of performance for TO 0031 is 04/05/2017 to 01/31/2018. A schedule will be developed and
inserted in Attachment C and assumes site setup work will begin on April 12th.

6.0 PRE-MOBILIZATION ACTIVITIES

6.1. PRE-MOBILIZATION SITE VISIT

A site visit will be conducted at the Chemours’ property on March 24th to identify areas for office trailers,
equipment staging, and backfill stockpiles.

6.2 PLANS

A Site Specific Health and Safety Plan (HASP) will be developed jointly by ER and Tetra Tech (START)
and approved by USEPA. The plan will be approved prior to the commencement of site activities. A Work
Plan (contained herein), Security Plan (contained herein), Stormwater Pollution Prevention Plan, and Traffic
Management Plan noting general haul routes will be developed by ER and submitted to EPA for review and
approval. All plans developed for this project will be amended, as site conditions warrant, with the approval
of EPA.

6.3 FIELD SAMPLING & LABORATORY ANALYSIS

Backfill and topsoil sources will be sampled at a frequency of one sample per 1,000 cubic yards delivered
to the site, and from each new borrow source. Sampling and analysis will be conducted by the EPA START
contractor in accordance with the requirements of the approved site Sampling Plan/QAPP.

The EPA START contactor will sample and analyze backfill & topsoil sources and submit results of this
analysis to EPA for approval prior to importing this material. The backfill and topsoil will be analyzed for
those constituents listed in Table 2 of the Final Remedial Design for Zone 2 properties as updated on March
23, 2017 by the Remedial Design contractor which is included as Attachment E to this Work Plan.

6.4 SUBCONTRACTOR PROCUREMENT & MANAGEMENT

Pricing will be solicited from multiple subcontractors for major items, including: equipment rental; backfill
materials; sod; PPE; laboratory analysis and fuel. The vendor which provides the best value to EPA for
each item and who is able to meet the project schedule will be selected. In general, subcontracted services
and supplies will be procured from local sources to minimize transportation.

ER recognizes that residential excavation work will be conducted concurrently in Zone 3 under a separate
contract and the potential exists for a subcontractor to work in each zone. Additionally, the Chemours
property will be used to support activities in both Zone 2 & Zone 3. ER will identify subcontractors working
in each zone and institute controls to ensure that equipment, materials and supplies are properly delivered
and tracked.

Signs will be placed on the Chemours property to direct deliveries to the Zone 2 staging area. The staging
area crew will be notified of delivery schedules on a daily basis and will be instructed to verify any
unscheduled deliveries prior to acceptance. When equipment, supplies and materials are ordered, clear
delivery instructions will be given for delivery to the Zone 2 staging area. Delivery tickets and packing slips
will be required for each delivery.

7.0 MOBILIZATION AND SITE SETUP

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 5 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

7.1 FIELD OFFICE AND TEMPORARY UTILITIES

Site setup activities will be conducted in level “D” PPE unless otherwise specified in the HASP.

Field Office Facilities – ER will rent a portion of the old Carrie Gosch School for use by EPA/START, an
office trailer for use by ERRS and a trailer for use as a breakroom/lunch room. Signs will be put up to
identify the EPA and ERRS offices and direct visitors to sign-in at the office. These trailers will be setup at
the Chemours facility.

Laydown Yard – ER will utilize the same area at the Chemours property as was used during 2016 activities
to store equipment and materials during the project. This location will also be used as a stockpile location
for backfill and top soil.

Electrical – The field offices will be connected to municipal power but may be run on temporary power
supplied by a diesel generator until this connection can be completed.

Potable Water – Bottled water will be provided to the crew.

Sanitation – Two portable restroom and a hand wash station will be stationed at the field office for use by
EPA/Start and ER’s administrative staff. Two additional portable restrooms and a hand wash station will
be placed at the laydown area. The portable restroom will be serviced at a minimum weekly.

Phone/Internet – Internet service will be extended to the office trailer location on the Chemours property.

7.2 CONTAMINATE REDUCTION ZONE (CRZ)

The CRZ will be established in accordance with the requirements of the Site HASP. The CRZ will be setup
at each location during excavation activities.

7.3 EXCLUSION ZONE SETUP (EZ)

The EZ will be setup in accordance with the requirements of the Site HASP. The EZ will encompass the
portion of each yard to be excavated. The exclusion zone will be fenced with 4’ construction barricade
fence and will remain fenced until backfill and sod placement is completed. Signs will be placed on each
side of the perimeter fence to warn the public to keep out.

7.4 UTILITY LOCATE

Utilities at each residence will be located using Indiana 811. At least 3 business days prior to beginning
excavation activities, but not more than 10, ER will submit a locate request for each location. To assist with
the utility locate, white paint or flags will be used to identify each excavation area. In addition, the City of
East Chicago wastewater, water and street lighting divisions will be notified to provide additional marking
information for City of East Chicago utilities.

8.0 REMOVAL ACTIVITIES

8.1 SURVEY EVENTS

Three survey events will be completed by EPA at each location. These survey events will be conducted
pre-remediation, post excavation and post remediation. The surveys will be compared to ensure that the
proper excavation design depth has been met and that the preexisting grade is reestablished after
restoration is completed.

8.2 SITE PREPARATION & WALK THROUGH

An initial walk through, attended by ER’s property coordination team, will be completed at each location.
The property will be walked with the property owner to review and document site conditions and determine

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 6 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

what trees, bushes or other landscaping will be removed/pruned and replaced, or not replaced. The
SulTRAC Property Design Sheet will be reviewed. An Access Agreement and The Property Assessment
& Inspection Form will be completed and site conditions will be thoroughly video and photo documented.
This documentation will also include interior basement walls.

Access to, and routes in and out of, the excavation areas will be discussed and agreed upon. Site specific
hazards will be discussed such as overhead wires, young children (under 7 years old) and pregnant women,
tight excavation areas or restricted access to excavation areas. ER assumes that EPA will notify residents
of the excavation and restoration schedule. ER’s documentation team will look for signs of buried private
utilities such as electrical lines running from the house to the garage.

On the day excavation begins at a location, a second site walkthrough will be conducted. The walk through
will be attended by the excavation crew, the RM or foreman, and a member of the property coordination
team. The Remedial Design sheet and The Property Assessment & Inspection Form will be reviewed.
Information regarding unique conditions noted by the property coordination team during the initial site
walkthrough will be given to the excavation crew.

The excavation crew will fence the excavation area and access routes into and out of the excavation area
with 4’ plastic barricade fence and metal fence posts spaced no more than 10’ apart. Sidewalks that bisect
excavation areas will be fenced off and two points of access to the residence will be maintained. Signs will
be placed on perimeter fencing warning the public to keep out.

ER personnel will control access points during excavation. Whenever access points are not under ER
control, construction fence will be used to close access to excavation areas. Any trees or tree limbs that
need to be removed or pruned for access will be removed at this time. Damaged limbs will be painted with
tree wound paint after pruning. The excavation crew will also pothole marked utilities in a minimum of two
locations leading from the property boundary to the residence.

8.3 TRAFFIC & PEDESTRIAN CONTROL

Traffic control will be conducted using signs, barricades and a flagman where necessary. Cones,
barricades and “sidewalk closed” signs will be used to close off the sidewalk in the work area. The sidewalk
will be opened up during non-working hours. A spotter will be used when backing up the dump truck at
each location.

8.4 EXCAVATION

Public access to the excavation sites will be controlled during removal activities to prevent exposure or
residents and property owners to contaminated soil and open excavations. Access will be controlled by
installing orange construction fence and/or warning tapes around the work area. This is further discussed
in Section 11.0 Site Security (Site Security Plan).

The site CRZ will be setup. Dust suppression equipment will be setup and the yard will be wetted as needed.
ER assumes that wherever possible, water will be taken from a house spigot. Plywood will be placed down
over sidewalks and yards to provide dump trucks a clean path to the active portion of the excavation. If the
excavation is inaccessible to dump trucks, excavated soil will be shuttled to the dump trucks using a tracked
skid steer. If dump trucks are loaded outside of a planned excavation area, plastic sheeting or geo-fabric
will be placed down beneath the truck to catch any soil which spills during loading. Some properties have
limited access such that soil will need to be shuttled out to dump trucks. Other locations have multiple
unrestricted points of access. Contaminated soil will be transported by 5yd3 dump trucks for offload at the
DuPont (Chemours) facility located at 5175 Kennedy Avenue, East Chicago, Indiana.

Excavations will proceed to the prescribed depth identified on the SulTRAC property remedial design.
Orange plastic fence will be used as the visual barrier placed at the bottom of excavations where indicated

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 7 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

in the SulTRAC Property Design Sheets after consultation and review of excavation by U.S. EPA On-Scene
Coordinator.

Excavation adjacent to the foundation of structures or other permanent structures (e.g. sidewalks, patios,
driveways, or alleys) will begin at 0 inches from the structure and proceed at a 1:1 slope (45 degree angle).
If the structural integrity of the permanent structure is poor, the 1:1 slope may instead begin at a maximum
distance of 6 inches from the structure. Surficial soil shall be excavated at a minimum depth of 1-2”.
Excavation immediately adjacent to the foundations of structures will be conducted manually.

Excavation shall proceed up to the property line. Excavation adjacent to fence posts may proceed at a 1:1
slope.

Where trees or shrubs are present in the are to be remediated, and will remain in place in accordance with
the property assessment and inspection form, soils within the drip zone shall be excavated manually.
Beginning at the trunk of any tree that will remain present in the remediation area, soil beneath the drip line
of the tree shall be manually excavated until significant roots (1” diameter) are encountered or the design
depth is achieved, and at minimum 1-2 inches of surficial soil shall be removed. Once the roots fall below
the design depth, mechanical excavation can occur in the remaining area within the drip zone. Compost
may be used to cover root wads that may be exposed for an extended period of time. Effort will be made
to manually remove soils from between roots in order to remove as much contaminated soil as is practical,
including possible use of an air mover or guzzler unit). In drip zone areas where the full depth of excavation
was not achieved due to the presence of roots and a significant portion of the yard will remain in canopy,
and as approved by U.S. EPA, high visibility fencing shall be installed at the bottom of the excavation (at a
minimum depth of 6 inches) prior to backfill installation to indicate the at contaminated material may be
present below this depth.

Decks, non-permanent structures, and wheelchair ramps shall be moved prior to excavation to access the
underlying soil for remediation. Non-permanent structures include, but are not limited to, inflatable
swimming pools, playsets, trailers, and portable storage sheds. Decks and wheelchair ramps will be
considered non-permanent unless EPA determines otherwise on a case-by-case basis.

Excavation will be conducted with an appropriately sized mini-excavator fitted with a smooth ditching
bucket. For larger unrestricted excavations a 10,000 to 11,000 lb. machine may be used. For smaller more
restricted areas, an 8,000 to 9,000-pound machine will be used. For the most restricted areas, and within
2’ of utilities, excavation will be done manually. Efforts will be made to minimize vibration of the ground near
and above LSLs.

As an excavation progresses, the crew will use a laser level or string line to verify that the design depth is
met. The final excavation depth will be determined by the post excavation survey conducted by the EPA
START contractor.

8.5 DUST & CONTAMINATED SOIL CONTROL

Water may be sprayed onto the excavation area to control dust. Water will be delivered either directly from
a homeowner water source or from a water truck. Water will be sprayed using a 3/4-1 ½”” hose outfitted
with a nozzle capable of delivering a fine spray. A hydrant meter/ backflow preventer will be rented from
the City of East Chicago. Streets in the neighborhood and on the Chemours property will be washed with
a spray bar outfitted on the water truck as needed

At the end of each day, sidewalks, driveways and curb lanes will be swept as needed. Plywood sheeting
will be used to provide a clean path for trucks to reach the active portion of the excavation. This plywood
will be swept throughout the day. Trucks will be inspected and brushed clean after loading and unloading
to ensure that no soil is present outside of the bed of the truck.

Excavation equipment (mini-excavator, skid-steer, shovels) will be removed from each property at the end
of each day and returned to the laydown yard for secure overnight storage. Each piece of equipment will

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 8 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

be brushed and scraped visibly clean prior to loading onto a truck or trailer. In the event excavation has
not been completed, heavy equipment may be secured and left on site until completion of the excavation.

Trucks hauling excavated soil and backfill will be tarped. Drivers will be required to conduct a walk around
after loading and unloading contaminated soil to minimize contamination during transportation operations.

8.6 BACKFILL

Backfill and topsoil will comply with the specification outlined in The Final Remedial Design for High Priority
Zone 2 Properties (SulTRAC March 23, 2017). Clean backfill will be delivered from the borrow source to a
stockpile located at the Chemours Company property on Kennedy Ave. From Chemours the fill will be
trucked to each property using the 5yd3 dump trucks; all trucks will be tarped for dust abatement during
transportation.

Fill will be placed and spread using a track skid-steer in 6” lifts and compacted with a plate compactor after
each lift is installed. In-place field density testing will be conducted by the U.S. EPA START contractor to
ensure backfill compaction specifications have been met. The final 6” of the excavation will be filled with
topsoil and shall be compacted by a lightweight, hand-towed roller or equivalent. The upper one-to-two
inches of topsoil will be raked and made ready to accept sod. Each location will be backfilled to meet the
pre-excavation elevation and contours except to correct drainage issues. Backfill will be placed so that
water will not pool and will drain away from the residences.

At the completion of each work day during backfill/topsoil activities, an external hose bib (or basement utility
sink if there is no external hose bib near the service line) will be flushed for 15 minutes with valve fully open.
Flushing may be longer if water is still visibly turbid after 15 minutes.

8.7 RESTORATION

Properties will be restored as closely as possible to the condition that existed before remediation. Any
property features damaged by remediation activities, including structures, foliage, pavement, fences,
outbuildings, ramps, driveways, walkways, and other features will be restored to pre-remedial conditions or
the property owner will be offered a suitable replacement. The fences and fence gates removed to facilitate
access to the property for remediation will be reinstalled to pre-remediation condition. Any damage to these
items will be repaired to the satisfaction of the property owner or will be replaced. Any other items,
structures, or site features which were removed to facilitate the soil excavation will be reinstalled to their
pre-excavation condition at their original locations as directed by the EPA TOCOR.

Following backfill activities, the restoration team will prepare final grade for sod placement. Vegetation and
landscaped areas will be replaced according to the homeowner agreement signed during the pre-
excavation property assessment and inspection. This will include replacement of bushes, shrubs, trees,
flowers, and similar plantings removed during soil excavation. Upon property owner request and in
consultation with EPA, if the property owner prefers to reinstall landscaping products themselves, a voucher
for landscaping products, such as trees, shrubs, flowers, and vegetable plants may be provided in lieu of
replacement in kind of preexisting plants. The property owner will only be able to use the voucher at the
designated nursery.

Sod will be used to restore each yard and will comply with the specification outlined in the Final Remedial
Design for High Priority Zone 2 Properties (SulTRAC, March 23, 2017). The sod will be installed by a
subcontractor overseen by ER’s Response Manager. Sod will be rolled with a roller not exceeding 90
pounds.

Sod and replacement trees and shrubs will be watered and maintained by ER for a period of 30 days after
installation; any sod and/or vegetation installed in June or July will have a two-month maintenance period.
Trees and shrubs will be warranted for a period of one year from the date of acceptance of work; it the
vegetation is not healthy it will be replaced.

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 9 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

After completion of all earth work and installation of sod, the property’s walkways, driveways, and other
surfaces will be swept clean. Punch list items will be completed in preparation for the post-excavation
interview and homeowner completion agreement. A post-excavation survey will be conducted at this time.

9.0 RESPONSE EQUIPMENT DECONTAMINATION ACTIVITIES

Response equipment will be dry decontaminated prior to demobilization. Residual material will be brushed
or scraped from the equipment until visually clean. If deemed necessary, the equipment will be washed
with high pressure water.

10.0 WASTE MANAGEMENT

10.1 ANTICIPATED WASTE STREAMS AND WASTE STREAM SAMPLING

ER anticipates the following waste steams:

 General trash & debris
 Contaminated PPE, poly sheeting, etc.
 Decontamination water
 Construction Debris

A small 2-yd3 or 3-yd3 dumpster will be placed at the office trailer location for general trash. Contaminated
PPE and poly sheeting will be comingled with the waste soils. Decontamination water will be used for dust
suppression. When significant volumes of buried construction debris are encountered, the debris will be
segregated from soil. The EPA TOCOR will make this determination.

10.2 RECYCLING AND REUSE

ER will consider recycling and beneficial reuse of all materials prior to designation of the material as a
waste. Decontamination water will be used as a dust suppressant on lead contaminated soil.

ER along with EPA and START will recycle paper, plastic and metals generated in the Site field office.

10.3 WASTE TRACKING

Excavated soil leaving each property will be accompanied by an Impacted Soil Haul Sheet. The following
information will be tracked:

 DATE
 DRIVER NAME
 TRUCK #
 LOAD #
 QUANTITY
 PROPERTY ID NUMBER
 TIME ARRIVING AT AND LEAVING PROPERTY

11.0 SITE SECURITY (SITE SECURITY PLAN)

A sign board will be placed at the entrance to the field office. The sign board will indicate that a USEPA
Removal Action is underway and direct visitors to sign-in at the Site Office. Visitors making planned visits
should be directed to meet site personnel at the field office located at 5135 Kennedy Avenue.

All equipment, hand tools, materials and miscellaneous supplies will be returned to the laydown yard at the
end of each workday. Small tools and supplies will be locked up in the equipment trailer or storage box
during overnight hours. The field office will be locked during non-working hours and when unoccupied
during the day.

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 10 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

During working hours, all visitors to the site will be directed to sign in on the site entry/exit log maintained
at the field office. An entry/exit log will be maintained to track all personnel onsite. Visitors/observers will
be kept out of the work areas while site activities are underway and should be escorted at all times.
Trespasser(s) should be asked to leave work areas and the local police should be notified if the trespassers
fail to comply. In the event trespasser(s) enter work areas, work should immediately cease, workers should
exit the area, and the EPA TOCOR should be notified. Work should not restart until the trespasser(s) have
left the site.

Access to the Chemours facility will be monitored by ER personnel stationed at the entryway. Any
unauthorized personnel will be stopped from entering the property and reported directly to the response
manager.

Properties that are being excavated, backfilled or restored will be fenced with 4’ orange barricade fence.
Excavations will be enclosed completely when not in the direct control of Environmental Restoration. As a
general work practice, personnel will not work alone and will adhere to the buddy system. The City of East
Chicago and its police department will be notified when soil excavation and loading will be scheduled in
each street or alley.

All ER personnel supporting activities at the USS Superfund Site will be required to wear a company picture
identification badge, identifying them as ER employees and EPA contractors. Personnel in the field will be
also be required to wear safety vests and hard hats with the ER company logo.

12.0 ENVIRONMENTALLY FRIENDLY PRACTICES

ER will attempt to employ environmentally friendly practices consistent with Part III Section J Attachment
7 of the contract during the execution of this task order. Where cost is increased by adherence to these
practices, the EPA TOCOR will be consulted prior to incurring the additional cost. These practices
include, but are not limited to the following:

 Utilizing environmentally conscious hotels Consider the use of compost for restoration

 Utilizing alternative fuels  Exploring the beneficial reuse of wastes

generated onsite
 Carpooling
 Procurement of goods and services from
 Utilizing green office supplies local vendors

 Recycling plastic, paper and metals  Institution of a no-idle policy for heavy
generated onsite equipment and vehicles

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 11 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

ATTACHMENT A
PROPERTY DESIGN SHEETS

(72)

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 1 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

ATTACHMENT B
ERRS CREW ORG CHART

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 2 of 10



TotaJs:
Response Manager - l ERRS Crew Zone 2
Health & Safety Officer - 1 Exca,•ation
Field Cost Accountants - 2
Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.

Foreman - l
Laborers - 16
Truck Drivers - 9
Equipment Opers. - 5

Runner / Laborer

Prope11y
Excavation Team #1 Punch List Team Staging Arca Team Backfill Team #1
Coordination Team

USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

2 - Laborers 2 - Laborers l - Field Cost Accountant I - Laborer 2 - Laborers
I[ 2 - Truck Drivers I - Truck Drivers 2 -Laborers I - Equipment Oper. 2 - Tmck Drivers
l - Equipment Oper. I - Equipment Oper.

ERRS REGION 5, CONTRACT EP-S4-16-02

ENVIRONMENTAL RESTORATION, LLC.
Excaration Team #2 Backfill Team #2

2 - Laborers 3 - Laborers
2 - Truck Drivers 2 - Truck Drivers

SITE WORK PLAN

I - Equipment Oper. 1 - Equipment Oper.
Page 3 of 10
 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

ATTACHMENT C
SCHEDULE

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 4 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

ATTACHMENT D
FORMS

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 5 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

ATTACHMENT E
BACKFILL QUALITY REQUIREMENTS
(RSLS)

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 6 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

Table 2 Backfill Quality Requirements

USS Lead Superfund Site, OU‐1
East Chicago, Indiana

Analyte Name Soil RSL (mg/kg)

HERBICIDES
2,4,5‐T (Trichlorophenoxyacetic Acid) 630

Silvex (2,4,5‐TP) 510

2,4‐D 700
2,4‐DB 510
Dalapon 1900
Dicamba 1900
Dinoseb 63
MCPA 32
MCPP 63
METALS
Arsenic1 14.1
Barium 15,000
Cadmium 71
Chromium, Total 120,000
Lead1 56.6
Mercury 11
Selenium 390
Silver 390
PAHs2
2‐Methylnaphthalene 340
Acenaphthene 5,000
Anthracene 25,000
Benzo(a)anthracene 2.2
Benzo(a)pyrene 0.22
Benzo(b)fluoranthene 2.2
Benzo(k)fluoranthene 22
Chrysene 220
Dibenz (a, h) anthracene 0.22
Fluoranthene 3,400
Fluorene 3,400
Indeno(1,2,3‐CD) pyrene 2.2

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 7 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

Table 2 Backfill Quality Requirements

USS Lead Superfund Site, OU‐1
East Chicago, Indiana

Analyte Name Soil RSL (mg/kg)

PAHs2 (continued)

Naphthalene 53

Pyrene 2,500

PCBs

PCB-1016 (Arochlor 1016) 4.1

PCB-1221 (Arochlor 1221) 0.2

PCB-1232 (Arochlor 1232) 0.17

PCB-1242 (Arochlor 1242) 0.23

PCB-1248 (Arochlor 1248) 0.23

PCB-1254 (Arochlor 1254) 0.24

PCB-1260 (Arochlor 1260) 0.24

PESTICIDES

Aldrin 0.04

alpha-BHC 0.09

beta-BHC 0.3

gamma-BHC 0.57
Chlordane3 1.7

DDD 2.3

p,p'-DDE 2
DDT 1.9

Dieldrin 0.03

Endosulfan 470

Endrin 19

Heptachlor 0.13

Heptachlor epoxide 0.07

Methoxychlor 320

Toxaphene 0.49

SVOCs
1,1'-Biphenyl 47

1,2,4,5-Tetrachlorobenzene 23

2 2'-Oxybis(1-chloropropane) 3 100
2,3,4,6-Tetrachlorophenol 1,900

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 8 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

Table 2 Backfill Quality Requirements
USS Lead Superfund Site, OU‐1
East Chicago, Indiana

Analyte Name Soil RSL (mg/kg)

SVOCs (continued)
2,4,5‐Trichlorophenol 6,300
2,4,6‐Trichlorophenol 49
2,4‐Dichlorophenol 190
2,4‐Dimethylphenol 1,300
2,4‐Dinitrophenol 130
2,4‐Dinitrotoluene 1.7
2,6‐Dinitrotoluene 0.36
2‐Chloronaphthalene 4,800
2‐Chlorophenol 390
2‐Methylphenol 3,200
2‐Nitroaniline 630
3,3'‐Dichlorobenzidin 1.2
4,6‐Dinitro‐2‐methylphenol 5.1
4‐Chloro‐3‐methylpheno 6,300
4‐Chloroaniline 2.7
4‐Nitroaniline 27
Acetophenone 7,800
Atrazine 2.4
Benzaldehyde 170
Butylbenzylphthalate 290
bis(2‐Chloroethoxy) Methane 190
bis(2‐Chloroethyl) ether 0.23
bis(2‐Ethylhexyl)phthalate 39
Caprolactam 31,000
Dibenzofuran 73
Diethyl Phthalate 51,000
Dimethyl Phthalate4 1,100
Di‐N‐Butyl Phthalate 6,300
Di‐N‐Octylphthalate 630
Hexachlorobenzene 0.21
Hexachlorobutadiene 1.2

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 9 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

Table 2 Backfill Quality Requirements

USS Lead Superfund Site, OU‐1
East Chicago, Indiana

Analyte Name Soil RSL (mg/kg)

SVOCs (continued)
Hexachlorocyclopentadiene 1.8
Hexachloroethane 1.8
Isophorone 570
Nitrobenzene 5.1
N‐Nitrosodi‐N‐propylamine5 0.078
N‐Nitrosodiphenylamine 110
Pentachlorophenol 1
Phenol 19,000
VOCs
1,1,1‐Trichloroethane 8,100
1,1,2,2‐Tetrachloroethane 0.6
1,1,2‐Trichloro‐1,2,2‐Trifluoroethane 40,000
1,1,2‐Trichloroethane 1.1
1,1‐Dichloroethane 3.6
1,1‐Dichloroethene 230
1,2,3‐Trichlorobenzene 63
1,2,4‐Trichlorobenzene 24
1,2‐Dibromo‐3‐chloropropane 0.01
1,2‐Dibromoethane 0.04
1,2‐Dichlorobenzene 1800
1,2‐Dichloroethane 0.46
1,2‐Dichloropropane 1
1,4‐Dichlorobenzene 2.6
1,4‐Dioxane (P‐Dioxane) 5.3
2‐Butanone 27,000
2‐Hexanone 200
4‐Methyl‐2‐pentanone 33,000
Acetone 61,000
Benzene 1.2
Bromochloromethane 150
Bromodichloromethane 0.29

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 10 of 10

 ENVIRONMENTAL RESTORATION, LLC.
ERRS REGION 5, CONTRACT EP-S4-16-02
SITE WORK PLAN
RESTORATION USS LEAD SITE – ZONE 2 (2017 RESIDENTIAL EXCAVATIONS)

Table 2 Backfill Quality Requirements

USS Lead Superfund Site, OU‐1
East Chicago, Indiana

Analyte Name Soil RSL (mg/kg)

VOCs (continued)
Bromoform 19
Bromomethane 6.8
Carbon disulfide 770
Carbon tetrachloride 0.65
Chlorobenzene 280
Chloroethane 14,000
Chloroform 0.32
Chloromethane 110
cis‐1,2‐Dichloroethene 160
cis‐1,3‐Dichloropropene 1.8
Cyclohexane 6,500
Dibromochloromethane 8.3
Dichlorodifluoromethane 87
Ethylbenzene 5.8
Isopropylbenzene 1,900
m,p‐Xylene 550
Methyl Tert‐butyl Ether 47
Methyl Acetate 78,000
Methylene chloride 57
o‐Xylene 650
Styrene 6,000
Tetrachloroethene 24
Toluene 4,900
trans‐1,2‐D ichloroethene 1,600
trans‐1,3‐Dichloropropene 1.8
Trichloroethene 0.94
Trichlorofluoromethane 23,000
Vinyl chloride 0.06
Xylenes (total) 580

Information herein is proprietary and confidential and not to be used or released to others with explicit written permission of ERLLC.
Page 11 of 10

Footnotes:

1 14.1 mg/kg is the site‐specific background concentration for arsenic. 56.6 mg/kg is the background
threshold value [BTV] for lead in 6‐ to 12‐inch soils (SulTRAC 2012).

2 For PAHs, backfill must not exceed the higher of the EPA RSL or the Tiered Approach to Corrective
Action (TACO) metropolitan areas concentration.

3 Chlordane is a mixture of chemicals; the major components include trans‐chlordane, cis‐chlordane, and
heptachlor (ATSDR Toxicological Profile for Chlordane). The sum of concentrations of these compounds
must not exceed the listed RSL for chlordane.

4 Indiana Department of Environmental Management (IDEM) has established a default closure limit of
1,100 mg/kg for dimethyl phthalate in soil.

5 Commonly employed analytical methods are unable to achieve a detection limit lower than the RSL
for NNitrosodi‐N‐propylamine, therefore this compound has been excluded from the list of required
backfill chemical quality analytes.