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Valley Forge National Historical Park

A focused assessment of a very large data set and wide range of possible remedial alternatives enabled the selection of a recommended remedial alternative which was presented to the public and adopted as the selected remedy in a Record of Decision. The remedy is currently being implemented (2013/2014) which will allow for full enjoyment of the Park by the public on an unrestricted basis.


Valley Forge National Historical Park

Valley Forge, Pennsylvania

 

The Technical Challenge

Relying on Remedial Investigation and draft Feasibility Study reports prepared by others, JCO was tasked with preparing a Final Feasibility Study report, a Proposed Plan, a Record of Decision document, and Final Remedial Design and bid documents that met the requirements of the National Park Service.

The Solution

As part of an overall on-going technical support role for the National Park Service, JCO prepared the CERCLA (Comprehensive Environmental Response Compensation, and Liability Act, or “Superfund”) documents necessary to complete the remedial action at the Valley Forge National Historic Park Asbestos Release Site. These documents included the Final Feasibility Study Report, the Proposed Plan, the Record of Decision, and the Final Remedial Design.

Feasibility Study

Based on the results of the Remedial Investigation and preliminary drafts of the Feasibility Study, JCO prepared a Final Feasibility Study (FS) which evaluated alternatives for remediation of asbestos- and metals-contaminated soils utilizing different combinations of technologies, including excavation and off-site disposal, capping, and in-situ stabilization. Based on the ability to appropriately manage risks, compliance with Applicable or Relevant and Appropriate Requirements (ARARs), and cost-effectiveness, the National Park Service selected the remedial alternative of shallow soil excavation and off-site disposal in accordance with CERCLA and the National Contingency Plan.

Proposed Plan

JCO prepared the Proposed Plan document that summarized the results and findings of the Remedial Investigation (RI), Risk Assessment, and FS, and presented the National Park Services’ preferred alternative for cleaning up the contaminated soils at the site pursuant to CERCLA, including the rationale for that preference. The Proposed Plan presented a summary of all remedial alternatives considered in the FS including implementation cost estimates. The Proposed Plan was prepared as part of the public participation requirements of CERCLA, which also included a public comment period, a public meeting, and the preparation of a Responsiveness Summary which provided the NPS’ responses to comments received during the public comment period.

Record of Decision

Based on input received during the public participation process, JCO prepared the Record of Decision (ROD) for the National Park Service presenting the selected remedy. This ROD documented the steps completed that lead to the selected remedy (including the technical rationale for the selection), the remedial action objectives for the clean-up, and statutory determinations under CERCLA. The ROD also included remedial performance standards and remediation goal verification procedures.

Interim Response Action

During the development of the pre-remediation documents described above, JCO designed and implemented an interim response action for two portions of the site that posed a potential immediate risk and hazard to visitors to the Site. JCO prepared the response action design for these areas, along with contract bid documents, and a response contractor was selected. JCO oversaw response construction, which included capping of exposed asbestos-contaminated soils, installation of erosion control measures, and revegetation of the response action areas.

Remedial Design and Implementation

JCO completed the Remedial Design and all accompanying implementation documents, and bids for the remedial construction were solicited. The winning bid was within the Engineers budget estimate, and a construction contract was awarded. JCO engineers are currently providing full time construction oversight for the National Park Service.

The Proof

A focused assessment of a very large data set and wide range of possible remedial alternatives enabled the selection of a recommended remedial alternative which was presented to the public and adopted as the selected remedy in a Record of Decision. The remedy is currently being implemented (2013/2014) which will allow for full enjoyment of the Park by the public on an unrestricted basis.