EA Engineering, Science, and Technology, Inc. 225 Schilling Circle, Suite 400 Hunt Valley, MD 21031 Telephone: 410-584-7000 Fax: 410-771-1625 13 May 2013 Ms. Liza Finley U.S. Army Corps of Engineers - Baltimore District Engineering Division-HTRW Branch 10 South Howard Street 10th Floor – CENAB-EN-HT Baltimore, Maryland 21201 Subject: Technical Memorandum for Performing Well Abandonment, Abandonment of Underground Piping, and Debris Removal Marsh Run Park FUDS Project No. C03PA040301 New Cumberland, Fairview Township, York County, Pennsylvania Contract No. W912DR-09-D-0018 Delivery Order No. 0003 Dear Ms. Finley, EA Engineering, Science, and Technology, Inc. (EA) prepared this Technical Memorandum to present the approach for abandonment of monitoring wells, soil-vapor extraction (SVE) wells, groundwater extraction wells, and associated underground piping at the Marsh Run Park Formerly Used Defense Site (FUDS) located in New Cumberland, Fairview Township, York County, Pennsylvania. This Memorandum also describes debris at the site that will be disposed during this field effort. The abandonment of the wells and underground piping and debris removal will be performed to allow for the restoration and return of the site to the property owner, Fairview Township. The field located on the FUDS will be restored to its former use as a recreational facility, Marsh Run Park, and, in particular, to soccer fields. The site will have an environmental covenant to restrict groundwater use and limit the disturbance of site soils. Wells were installed at the site during various stages of investigation and monitoring by the U.S. Army Corps of Engineers (USACE). In 1987, Woodward-Clyde Consultants installed MW-1A, MW-2A, and MW-3A as part of the Confirmation Study. EA installed wells MW-1, MW-2, MW-4, MW 4A, MW-5, MW-5A, MW-6, MW-6A, MW-7, MW-7A, WP-1, WP-2, and WP-3 during the Remedial Investigation in 1989. EA also installed EW-1 and EW-2 in 1990, and EW-3 in 1993. As part of remedial activities at the site, Plexus Scientific Corporation installed well pairs MW-8/8A and MW-9/9A in 2003, and MW-10, MW-11, MW-12, MW-13, and MW-14 in 2005. EA installed monitoring well MW-15 in 2010. EA anticipates initiating well and piping abandonment in June 2013 using the methodology outlined below. Abandonment/decommissioning of the wells and piping will be scheduled in consultation with USACE once approval and concurrence on the approach is received from USACE. Well abandonment will be performed in accordance with the Pennsylvania Department of Environmental Protection (PADEP) Ground Water Monitoring Guidance Manual, Chapter 7, which complies with the Pennsylvania Department of Conservation and Natural Resources Ms. Liza Finley 13 May 2013 Page 2 of 6 (DCNR) Pennsylvania (PA) Act 610, the Water Well Drillers License Act, and USACE Engineering Manual 1110-1-4000, Monitoring Well Design, Installation, and Documentation and Hazardous, Toxic, and Radioactive Waste Sites. In accordance with the Water Well Drillers License Act, EA notified DCNR, Bureau of Topographic and Geologic Survey (BTGS) on 8 October 2012, of the intent to decommission the wells at least 10 days before the wells are sealed or filled. 1. Scope of Well and Piping Abandonment and Debris Removal Efforts The abandonment and debris removal effort is detailed in the Scope of Work (SOW) dated 28 June 2010 for Modification No. 2 to Delivery Order (D.O.) No. 0003, Contract No. W912DR- 09-D-0018. In the referenced SOW, 23 monitoring wells, 58 SVE wells, 3 groundwater extraction wells, and associated underground piping are identified for abandonment. During site reconnaissance, additional wells requiring abandonment were discovered; specifically two observation well points (WP-1 and WP-2) and a well near each of MW-1 (UN-1) and Extraction Well (EW)-2 (UN-2). Each of these wells will also be abandoned. With the exception of MW-9, all wells will be abandoned during the mobilization. The proposed dates for the abandonment of these wells will be between 3 and14 June, 2013. Figure 1 (depicting well locations), Table 1 (summarizing well construction details), and Table 2 (presenting details on SVE wells) are included in Attachment A. Monitoring and extraction well abandonment will include removal of aboveground appurtenances, including casings, to at least 1 ft below ground surface (bgs). Protective bollards also will be removed. The SVE wells have protective boxes with a ½-in. water line and 1½-in. vapor line exiting the box at approximately 1½ft below the box lid (Attachment A, Figure 2). The boxes also house a pressure gauge. The appurtenances within the boxes and the boxes themselves will be removed and disposed. EW-2 and EW-3 each have an associated adjacent manhole which will be removed as part of future site restoration work. Two underground soil vapor lines and one water line from the SVE well system, as well as the outfall line from the treatment building, will be abandoned in place. The approximate trenching locations for accessing these lines for abandonment are presented in Attachment A, Figure 3. Procedures are described below. In addition, debris located along the southern perimeter fence line (in the vicinity of MW-3A) will be removed during this field effort. The debris consists of PVC pipes, manhole frames and covers, several unused bollards, miscellaneous building materials and a partial roll of ethylene propylene diene monomer (EPDM) (synthetic cap material). The partial roll of EPDM will be placed on top of the existing EPDM synthetic cap prior to departure from the site. Ms. Liza Finley 13 May 2013 Page 3 of 6 2. Underground Piping Abandonment Procedures Selected portions of underground piping associated with the existing soil-vapor extraction system will be abandoned in place to eliminate a potential migration pathway. The Plexus Scientific As-Built Yard Piping drawing includes a depiction of the pipelines that will be abandoned (Attachment A, Figure 3). Specific pipelines to be abandoned are the 6-in. “V-1” and “V-2” lines, the 2-inch “L” line present in the Extraction Piping Trench, and the terminus of the Marsh Run Creek effluent discharge pipeline. (This pipeline is depicted, but not labeled, in Figure 3, the Plexus Scientific As-Built Yard Piping drawing.) The lines are expected to be approximately 30 in. below ground surface. Three trenches to approximately 3 ft below ground surface are proposed to access the lines (Attachment A, Figure 3). If the depth of the excavation must exceed 4 feet below ground surface to access the pipes, then the work will cease to allow additional required trench excavation safety procedures to be implemented. Prior to excavation, utility clearance will be conducted via the PA One Call System. Electrical service is currently supplied to the SVE building. Although no live electrical lines currently service the blower shed (located in the vicinity of one of the proposed excavations), the main breaker for the SVE building will be turned off prior to performing any excavation in order to de-energize the lines. A tag indicating that the lines have been de-energized to allow excavation will be placed on the breaker circuit box and the building door, which will be locked during excavation. An excavation approximately 2 ft wide by 5 ft long by 3 ft deep will be installed to expose the piping. The pipes will be severed and inert material, such as paper, will be placed approximately 8 -10 in. into the line as a backing support. Bentonite chips will then be placed within the pipe and hydrated, to form a bentonite plug inside the pipe between the inert backing and the cut end of the pipe. A cement grout mixture consisting of Portland cement, bentonite powder, and water will be prepared using a ratio of one 94 lb bag of cement and 6 lbs of bentonite, per 6 gallons of water. Cement grout will be placed in and around the cut end of the pipe. Following confirmation of the set-up of the grout (approximately 2 hours), the excavated soil will be gently placed back into the trench to minimize disturbance of the grout, and will be left slightly mounded to allow for settlement. It is estimated that the abandonment of the above- described piping will be completed in one day. Field and photo-documentation will be collected during piping abandonment activities. 3. Well Abandonment Procedures PADEP guidance stipulates that, provided that the monitoring wells are functioning as designed, it is permissible to abandon the wells in place, unless “the well design precludes complete and effective placement of sealant and wells are in locations subject to future disturbance that could compromise the abandonment. In such instances all tubing, screens, casings, aggregate, backfilling, and sealant should be cleared from the boring and the hole should be completely filled with an appropriate sealant.” Wells located onsite have been functioning as designed, have no impediments that would affect sealant, and will not be disturbed in the future. Future disturbances will be precluded by an environmental covenant being placed on the property that will prohibit excavation. The offsite wells also have been functioning as designed, have no impediments that would affect sealant, and are located on the Defense Depot, Susquehanna Post (DDSP) or are adjacent to the Susquehanna River on property that is unlikely to be developed. Therefore, wells will be abandoned in place using the procedural guidance detailed below. Ms. Liza Finley 13 May 2013 Page 4 of 6 • Bladder pumps, if present, will be removed, bagged, labeled with the well from which they were removed, and stockpiled inside of the onsite building for reuse or disposal by USACE. One functioning bladder pump will be reserved for placement into MW-9. • With the exception of the SVE well boxes, protective casings, riser pipes, tubing, and other appurtenances at the surface which cannot be removed will be cut off (to approximately 1 ft below grade). The pressure gauges at each SVE well will be removed and disposed. Appurtenances and depth of casing removed will be recorded. • Total well depth and water level will be recorded, and total well volume to be grouted will be calculated and recorded. In the event grouting is anticipated to displace groundwater in the well, groundwater will be collected and managed appropriately by pumping into a temporary holding container as the well is being grouted, and will be disposed through carbon filtration to the surface. • Portland cement, in a ratio of one 94-lb bag and 6 lb of bentonite powder (6 percent) per 6 gallons of water, will be used as cement grout. • Grout material will be combined in an aboveground container and mechanically blended to produce a lump-free mixture. The mixed grout will be recirculated through the grout pump prior to placement. • It is anticipated that prior to and as part of SVE protective box removal, the lines entering the box will be severed. No abandonment in-place or grouting of the ½ inch diameter water line or the 1 ½ inch diameter vapor lines is required. • The cement grout mixture will be placed into the well from the bottom using a grout pump and Tremie pipe to grade, and allowed to settle for 24 hours. After 24 hours, the grout will be checked for settlement. Any settlement depression will be filled with grout and rechecked 24 hours later. This process will be repeated until firm grout remains. • Dates, descriptions, and total quantities of bentonite chip, water, and cement grout (including the quantities of cement, water, and bentonite powder used will be recorded. • The area of the abandoned wells will be photographed before and after abandonment efforts. Wells located on DDSP property (i.e., MW-5, 5A, 6, 6A, and 7) will require coordination with the facility to gain access. A form for coordinating access to DDSP is included in Attachment B. This form will be submitted to Mr. Brian Hurlbut (717-770-7092) or Mr. Tom Haskell (717-770- 7280) of DDSP a minimum of 72 hours in advance of the scheduled work. Refuse from well abandonment and debris from inside and along the southern perimeter fence will be disposed at a Subtitle D landfill (see also Item 6 below). Ms. Liza Finley 13 May 2013 Page 5 of 6 4. Well Abandonment Subcontractor The proposed PA-licensed well driller to be subcontracted for well abandonment services is Eichelbergers, Inc. EA will perform oversight of the PA-licensed drilling contractor during field activities and will ensure that onsite personnel follow established work and health and safety procedures. The Eichelbergers, Inc. onsite representative will report directly to the EA Site Manager. It is estimated that the abandonment of the wells; with the exception of MW-9, will be completed within 10 working days, plus a 1-day mobilization for removal of wastes. After well abandonment, EA’s subcontracted, PA-licensed well driller will provide completed BTGS standard Well Abandonment Forms to BTGS online using the WebDriller program, and will forward the completed and signed forms to EA. Attachment C presents an example of the BTGS Well Abandonment Form. 5. Submittal of Pennsylvania Well Abandonment Forms After receipt of the signed Well Abandonment Forms from Eichelbergers, Inc., EA will submit a package of information to the PA DCNR BTGS. This package of materials will be prepared in accordance with the PADEP Ground Water Monitoring Guidance Manual and Act 610 and will include the Well Abandonment Forms, available construction details for the abandoned wells, photographs of before and after conditions, and a brief table of well abandonment details. 6. Debris Removal and Disposal The debris located inside and adjacent to the southern perimeter fence line includes concrete- filled bollards, piping, building materials, manhole covers, and well casing (PVC). A representative from Fairview Township was contacted to determine whether the Township will take possession of the material (e.g., manhole covers, concrete pipe sections). The Township declined; therefore these materials will be recycled and/or disposed. Attempts will be made to recycle the manhole covers, although many recycling centers do not accept manhole covers. Therefore, as needed, a letter stating their origin will be submitted to the recycling facility to gain concurrence from the facility that they will be accepted. If the facility will not accept the covers, they will be disposed with the other debris in a roll-off container that will be delivered and picked up by a waste disposal firm. Due to the weight limit on the Marsh Run Bridge, transport of the roll-off container through DDSP will be arranged. The form for arranging transport through DDSP is included as Attachment B. 7. Safety Considerations The Site-Specific Addendum to the General Health & Safety Plan (GHASP) For Hazardous Waste & Environmental Service for Sampling at Marsh Run Park (Formerly New Cumberland Army Depot) New Cumberland, Pennsylvania, dated May 2011, will be utilized as the health and safety plan during this field effort. Additional activity hazard analyses for well abandonment and excavation are included in Attachment D, Tables 3 and 4. Ms. Liza Finley 13 May 2013 Page 6 of 6 8. Submittal of Letter Report At the completion of the well and piping abandonment and debris removal, EA will submit copies of the well abandonment forms to BTGS. Fairview Township and USACE will both be provided a copy of what is submitted to BTGS. We appreciate the opportunity to continue to support USACE on this project. Should you have any questions or comments, please do not hesitate to contact us. Respectfully yours, EA ENGINEERING, SCIENCE, AND TECHNOLOGY, INC. Michael Dorman, PMP Project Manager Attachments: A: Information on Wells to Be Abandoned and Underground Line Abandonment Locations B: Form DL 1818 (for access to DDSP) C: Example BTGS Well Abandonment Form D: Activity Hazard Analyses ATTACHMENT A INFORMATION ON WELLS TO BE ABANDONED AND UNDERGROUND LINE ABANDONMENT LOCATIONS SSuussqquueehhaannnnaa RRiivveerr SSuussqquueehhaannnnaa RRiivveerr SSuussqquuRReeiihvhveaearnrnnnaa MW-13 MW-10 Site MW-14 Regional Dual Phase MW-11 Groundwater Extraction System Flow Building EW-1 NNoorrffoollkkSSoouutthheerrnnRRaaiillrrooaadd MW-12 Legend MW-6 UN-2 MW-4 Monitoring Well/ MW-4A MW-1 Injection Well/ EW-2 UN-1 Extraction Well/ MW-6A MW-8A MW-9 MW-1A EW-3 MW-15 Well Point MW-8 To Be Abandoned MW-9A MMiiffffllii Synthetic Cap MToo Rnietomrianign Well nn AA vvee OP-1/WP-1 Formerly Used Defense WP-3* MW-2A Site (FUDS) Boundary DDeeffeennssee DDeeppoott Stream MW-2 SSuussqquueehhaannnnaa MW-7A dd PPeennnnssyyllvvaanniiaa RR MW = Monitoring Well nn EW = Extraction Well ((DDDDSSPP)) WP-2 MW-3A RRuu WP/OP = Observation Well Point d MW-7 MMaarrsshh U N = IAndjedcittiioonna Wl Oebll s-e orbvasetiorvne odr ent.mx RR uu nn during site reconnaissance onm MM aarrss hh (details unknown) band A Note: ell W * Well was not located during n\ o site reconnaissance. d MW-5 n a b A MW-5A ell W d\ x M n\ u R h s ar M a\ ni a v yl s n n e P PPeennnnssyyllvvaanniiaaTTuurrnnppiikkee Aerial Photograph Source: heast\ PAMAP Program, PA Department of Nort Conservation and Natural Resources, a\ at Bureau of Topographic and Geologic D S Survey, 2008 GI L\ A R Project Number: 0 100 200 DE Marsh Run Park FUDS 6233003 Figure 1 FE N Fairview Township, New Cumberland, Pennsylvania Date: Feet Wells To Be Abandoned ETO FUDS Project No. C03PA040301 V May 2013 1 inch = 200 feet O L \\ TABLE 1: ABANDONMENT OF WELLS AT MARSH RUN PARK SUMMARY OF WELL CONSTRUCTION INFORMATION Approximate Approximate PVC Borehole Total Well Screen Position Outer Casing Casing Diameter Well ID Aquifer Location Construction Type Depth (ft) (ft bgs) Depth (ft) Diameter (in.) MW-1 Bedrock Onsite PVC Screen 50 40-50 18.5 2 6 MW-1A Overburden Onsite PVC Screen 15 5-15 NA 2 8 MW-2 Bedrock Onsite PVC Screen 50 40-50 20 2 6 MW-2A Overburden Onsite PVC Screen 13 3-13 NA 2 8 MW-3A Overburden Onsite PVC Screen 15 10-15 NA 2 8 MW-4 Bedrock Onsite PVC Screen 50 40-50 30 2 6 MW-4A Overburden Onsite PVC Screen 15 5-15 NA 2 8 MW-5 Bedrock Offsite PVC Screen 50 40-50 25 2 6 MW-5A Overburden Offsite PVC Screen 15 5-15 NA 2 8 MW-6 Bedrock Offsite PVC Screen 50 40-50 20 2 6 MW-6A Overburden Offsite PVC Screen 15 5-15 NA 2 8 MW-7 Bedrock Offsite PVC Screen 50 40-50 20 2 6 MW-7A Overburden Offsite PVC Screen 15 5-15 NA 2 8 MW-8 Bedrock Onsite Open Borehole 55 NA 23 NA 8 MW-8A Overburden Onsite PVC Screen 14 4-14 4 2 8 MW-9* Bedrock Onsite Open Borehole 60 NA 23 NA 6 MW-9A Overburden Onsite PVC Screen 12 4-12 4 2 8 MW-10 Bedrock Offsite Open Borehole 35 NA 26 NA 6 MW-11 Bedrock Offsite Open Borehole 38 NA 28 NA 6 MW-12 Bedrock Offsite Open Borehole 60 NA 26 NA 6 MW-13 Bedrock Offsite Open Borehole 41 NA 30 NA 6 MW-14 Bedrock Offsite Open Borehole 41 NA 28 NA 6 MW-15 Bedrock Onsite PVC Screen 205 156-166 18 2 6 EW-1 Bedrock Onsite PVC Screen 100 50-100 25.5 4 8 EW-2 Bedrock Onsite PVC Screen 100 50-100 23.5 4 8 EW-3 Bedrock Onsite PVC Screen 100 50-100 4 10 OP-1/WP-1 Overburden Onsite Unknown Unknown Unknown Unknown Unknown Unknown WP-2 Overburden Onsite Unknown Unknown Unknown Unknown Unknown Unknown WP-31 Overburden Onsite Unknown Unknown Unknown Unknown Unknown Unknown UN-1 Unknown Onsite Unknown Unknown Unknown Unknown Unknown Unknown UN-2 Unknown Onsite Unknown Unknown Unknown Unknown Unknown Unknown All wells presented above are targeted for abandonment, with the exception of the well with "*" * = Wells targeted for abandonment during subsequent mobilization NA = Not Applicable ft = feet bgs = below ground surface in. = inches 1 Well was not located during site reconnaissance Table 2