Fort Sheridan Performance Based Contract
KEMRON was awarded and completed a $17.1 FFP remediation with performance-based remediation for the US Army at Fort Sheridan, an Army installation being closed under BRAC. KEMRON successfully managed 13 task areas which included regulatory agency negotiation, remedy selection, remedy implementation, LTM, O&M, construction, site documentation, community relations, and managing the Administrative Record. Under this contract, KEMRON was responsible for achieving RIP or RC for task areas. RC was achieved for seven task areas including an NFA DD for another task area which encompassed seven separate sites. For the additional task areas, KEMRON was responsible for implementing land use controls (LUC), closing monitoring wells and/or preparing an approved DD. For the RIP sites, KEMRON was responsible for LTM. KEMRON developed and received regulatory approval for site plans including safety plans and other reports and documents. In addition, KEMRON prepared all CERCLA documentation and the first CERCLA five-year review. The following is an overview of a few task areas.
KEMRON finalized the design and constructed a 13-acre RCRA Subtitle C cap over Landfills 6 & 7. The RCRA cap consists of multiple layers of geosynthetics, drainage layers, and low permeability clay. KEMRON also installed a leachate and gas collection system. The finished area is used as an open green field and hiking trail with prairie grasses, plants, shrubs and trees. KEMRON gained approval from IEPA, Army and the Navy to irrigate a 1.8-acre parcel using leachate collected from Landfills 6 & 7 as part of a pilot study for alternative disposal of leachate (compliant with EPA Region 2 Clean Program). The six-month study saved $50,000 in off-site disposal costs for the summer watering season. This pilot study, approved as a long-term disposal option, could ultimately save the Army approximately $2 million in life cycle costs over the next 30 years.
Five additional task areas included the demolition of a lead-based paint contaminated structure and the remediation of four areas with contaminated soils. KEMRON elected to meet residential standards on these five sites, thus eliminating the need for LTM and LUCs. KEMRON’s SOW required preparation of DDs. As a means to accelerate closure and gain immediate regulatory concurrent, KEMRON proposed to the BCT to prepare a non-time critical Action Memorandum instead. As a result, the approval time was cut dramatically and the remediation was completed a year ahead of schedule. The excavated soils were transported to the low areas in Landfill 6 & 7 as part of the required subgrade preparation beneath the liner, thus saving disposal costs.
KEMRON prepared the DD and design documents including LUCs for Landfill 5 and Coal Storage Area No. 3 (CSA3). The key design features of the 2.2-acre modified Subtitle C landfill cap on Landfill 5 included two feet of compacted clay overlying an impervious geosynthetic clay liner which included improvements to the existing storm water control system beneath the landfill, installation of a new perimeter drainage pipe, ravine slope stabilization, and elimination/realignment of the overhead utilities. The CSA3 consisted of excavation of PAH contaminated soils from remnants of the former CSA. The removal action was completed in and around residences which required coordination with homeowners. KEMRON managed a comprehensive community involvement program designed to keep the local residents informed and involved. KEMRON developed a project website to provide construction updates, pictures, and other information, providing immediate status to stakeholders.
One of the challenges at Fort Sheridan was the management of the remedial activities amid the concerns of multiple stakeholders. Although the Army maintains environmental liability on a majority of the site that has not already been transferred to the community, the Navy and Army Reserve now occupy all of the properties that were covered under this contract. As a result, it was necessary for KEMRON to ensure that the remedial approaches being proposed and conducted site-wide met the requirements of all of the multiple stakeholders to include the Navy, Army, AEC, USACHPMM, Reserve, the surrounding towns and the community.