for discussion purposes only - middleport … · 2007 early action work plan for culvert 105 south...

FOR DISCUSSION PURPOSES ONLY DRAFT

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--- FOR DISCUSSION PURPOSES ONLY --- DRAFT SCOPE OF WORK

2007 EARLY ACTION WORK PLAN FOR CULVERT 105 SOUTH OF MECHANIC STREET AND

NORTH COMMERCIAL/INDUSTRIAL AREA – WOODED PARCEL

FMC CORPORATION MIDDLEPORT, NEW YORK

1.0 OVERVIEW OF 2007 EARLY ACTION ITEMS During a November 8, 2006 meeting that included representatives of the New York State Department of Environmental Conservation (NYSDEC), the United States Department of Environmental Protection (USEPA), the New York State Department of Health (NYSDOH), the Village of Middleport, and other community members, FMC Corporation (FMC) discussed the next phases of the Resource Conservation and Recovery Act (RCRA) Corrective Action program for the FMC Middleport facility and the offsite study areas. During the discussions, FMC proposed to perform permanent remedies at distinct portions of the offsite study areas beginning in 2007, with the remedies (referred to hereafter as “Early Actions” or “EA”) being final corrective measures for the areas in which they are implemented. FMC also proposed to establish options to permanently manage any soils removed during Early Actions and to continue completion of the RCRA Facility Investigation and Corrective Measures Study under the terms and conditions of the Administrative Order on Consent, Docket No. II RCRA-90-3008(h)-0209, entered into by FMC, the USEPA, and the NYSDEC, effective July 2, 1991. In addition, during the November 8, 2006 meeting, FMC proposed to implement the Early Actions with early input from the Village of Middleport, the community, affected property owners, and adjacent neighbors. The early input was proposed as a supplement to the public comment opportunities that will occur later in the process. In response, the Community Input Group (CIG) was established to provide comments and early input on the proposed Early Action remedial activities, the identification and scheduling of such activities, and the restoration/future use of the affected properties, including any grant opportunities for redevelopment funds. As discussed during the November 8, 2006 meeting, the 2007 Early Actions are proposed to be performed for Culvert 105 south of Mechanic Street and an area collectively referred to as the “Wooded Parcel” that consists of the eastern wooded portion of the North Commercial/Industrial Area, located north of the FMC facility. The Wooded Parcel includes an undeveloped access corridor on the south side of Park Avenue through which Culvert 105 traverses. Figure 1 identifies the existing layout of the Culvert 105 storm sewer system south of Mechanic Street and identifies the Wooded Parcel of the North Commercial/Industrial Area. This Scope of Work (SOW) has been prepared to identify the remedial areas and describe the conceptual approach for


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conducting 2007 EA remedial activities. The following identifies the remedial objectives; key design components; and describes pre-construction and construction activities, general health, safety and security measures, and post-construction monitoring and maintenance activities associated with the EAs proposed for implementation in 2007. During meetings (November 30 and December 11, 2006) that included the CIG, FMC, and the Agencies (USEPA, NYSDEC, and NYSDOH), potential remedial alternatives for the 2007 EA areas were discussed and the CIG provided input and comments on the proposed alternatives and on the potential future use of the 2007 EA areas. In addition, input and comments were sought and obtained from the affected property owners and the adjacent residential neighbors through individual meetings and/or telephone conversations. This SOW was developed with consideration of the input and comments from the CIG, property owners, and adjacent neighbors.

1.1 DESCRIPTION OF CULVERT 105 SOUTH OF MECHANIC STREET AREA • The 2007 EA area of “Culvert 105 South of Mechanic Street” consists of the section

of Village-owned stormwater sewer from the Culvert 105 inlet at North Ditch on the shared property boundary of FMC-owned North Railroad Property boundary to the southern edge of Mechanic Street. The Culvert 105 storm sewer system conveys collected stormwater in a northwest direction, traversing several public roads and residential/commercial properties. The piping components of the Culvert 105 storm sewer system consist of several different types of pipe (e.g., tile, polyvinyl chloride, high-density polyethylene) in varying conditions. Culvert 105 South of Mechanic Street consists of buried storm sewer pipe, except for an open ditch section that begins at the northern edge of the Erie Canal and terminates at the southern edge of Mechanic Street, and approximately 18 storm sewer catch basins/manholes, including a sediment chamber/manhole (MH-N9) located on the north side of the Erie Canal. Figure 1 presents the existing layout of the Culvert 105 storm sewer system south of Mechanic Street. The Culvert 105 storm sewer system is part of the Village of Middleport municipal stormwater sewer system. The portion of the Culvert 105 storm sewer system that runs beneath the Erie Canal has been maintained by the New York State Canal Corporation.

• The open-ditch section (approximately 138 lineal feet) of Culvert 105 South of Mechanic Street and north of the Erie Canal is situated within the Village of Middleport’s Margaret Droman Park (situated on land owned by the Erie Canal Corporation.

• As noted in a report entitled Culvert 105 Video Inspection Results, which was submitted to the Agencies by cover letter dated July 13, 2004, portions of Culvert 105 storm sewer system (i.e., between catch basin/manhole CB-2 and the inlet at the north ditch) south of Park Avenue (which traverse the Wooded Parcel) are in poor


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condition due to root penetration and structural damage. The damaged Culvert 105 inlet sections impede drainage of the north drainage ditch that runs along the north side of the railroad tracks that was remediated in 2005 as part of the Phase 1 North Railroad Property Interim Corrective Measures (ICM).

1.1.1 CULVERT 105 SOUTH OF MECHANIC STREET 2007 EARLY

ACTION OBJECTIVES The objectives of the 2007 EAs to address Culvert 105 South of Mechanic Street are as follows:

• Replace a portion of the section of the Culvert 105 storm sewer system that is

situated on the Wooded Parcel between the inlet from the North Ditch (including the inlet structure) and catch basin CB-2 (referred to as “inlet section” or “Culvert 105 inlet section”) in order to improve stormwater drainage from the remediated North Ditch situated within the North Railroad Property Phase 1 ICM Area.

• Remove existing sediments, if any, within catch basins located along the Culvert 105 storm sewer system south of Mechanic Street.

• Retain the existing sediment chamber/manhole (MH-N9) located on the north side of the Erie Canal so it can be utilized for continued collection of any sediments that may be conveyed from the upstream sections of Culvert 105.

• Convert the open ditch section of Culvert 105 (which traverses Margaret Droman Park) to a buried storm sewer pipe. This conversion would enhance and facilitate any future development of Margaret Droman Park.

1.2 DESCRIPTION OF NORTH COMMERCIAL/INDUSTRIAL AREA –

WOODED PARCEL

• The North Commercial/Industrial Area – Wooded Parcel consists of approximately 3.7 acres of overgrown and vacant land, and is situated north of the FMC-owned North Railroad Property. The Wooded Parcel is bounded to the west by Alfred Street and the Royalton-Hartland Central School District property, to the south by the FMC-owned North Railroad Property, to the east by the former Norco Machine Corporation Property, and to the north by Park Avenue and/or residential properties along Park Avenue. The Wooded Parcel also includes an undeveloped grass-covered access corridor situated between two residential properties on Park Avenue, which extends from the interior portions of the Wooded Parcel to the southern edge of Park Avenue. Portions of the Culvert 105 storm sewer system traverse this undeveloped access corridor as well. The remaining portion of the North Commercial/Industrial


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Area is not proposed for 2007 EA activities. The Wooded Parcel has been and is currently zoned for commercial and industrial uses.

• A portion of the Wooded Parcel historically has been occupied by various buildings/structures, which were occupied by various manufacturing operations (i.e., Niagara Sprayer, Welkley Brothers Vinegar Works), and a small orchard (based on review of historic Sanborn maps and aerial photographs). In 2003, the last remaining building on the Wooded Parcel burned down. The burned-down building debris and the foundations of other demolished structures remain on the Wooded Parcel. In addition, other debris and rubble have been placed in the overgrown/wooded portion of the property.

• The Wooded Parcel also includes the inlet section of the Village of Middleport’s existing Culvert 105 storm sewer system, originating at the northern edge of the FMC-owned North Railroad Property. The inlet section of Culvert 105 located within the Wooded Parcel also includes three existing concrete catch basins between the North Railroad Property boundary and Park Avenue. Portions of the Culvert 105 storm sewer system located within the Wooded Parcel will be addressed as part of activities associated with the Culvert 105 South of Mechanic Street EA Area. The stormwater runoff from the Wooded Parcel drains into the Culvert 105 storm sewer system via the existing catch basins within the Wooded Parcel.

1.2.1 NORTH COMMERCIAL/INDUSTRIAL AREA – WOODED PARCEL

2007 EARLY ACTION OBJECTIVES The objectives of the 2007 EAs to address the North Commercial/Industrial Area Wooded Parcel are as follows:

• Minimize the potential for human contact with impacted soils within the

North Commercial/Industrial Area – Wooded Parcel based on reasonably expected future land use of this area (i.e., non-residential).

• Restrict future uses of the remediated Wooded Parcel to protect and maintain the integrity of the EA and to prevent a change to unrestricted residential uses in the future without review and approval on the part of the Agencies.

• Maintain or, to the extent practicable, improve drainage conditions of the Wooded Parcel and abutting properties that drain to Culvert 105 on the Wooded Parcel.

• Remove the debris and the overgrown vegetation on the Wooded Parcel and restore the property to a vegetated open area. Provide opportunity for a post-Early Action use of the Wooded Parcel, which considers the Village of Middleport’s anticipated future economic development plans.


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2.0 KEY DESIGN COMPONENTS

The key design components, requirements, parameters, and potential issues for the 2007 Early Action activities associated with the Culvert 105 South of Mechanic Street and the North Industrial/Commercial – Wooded Parcel are presented below.

2.1 GENERAL COMPONENTS OF THE 2007 EARLY ACTIONS

• Preparation, submittal, and Agencies’ approval of the 2007 Early Action Work Plan and other project-specific plans, as necessary.

• Preparation and distribution of a Request for Proposal to prospective Contractors, review of Contractor bid proposals, and selection of a qualified Contractor.

• Preparation and execution of access agreements with owners of the affected 2007 EA properties and abutting properties, as needed.

• Identify suitable cover/backfill material source(s) and backfill source qualification sampling, if necessary.

• Mobilization and site preparation, including establishing construction support facilities, site security measures, access routes, exclusion zones, decontamination pad locations, air monitoring locations, erosion control measures, soil handling areas, clearing activities, and installation and maintenance of temporary erosion and sediment control measures related to construction activities.

• Preparation and implementation of a Community Air Monitoring Plan (CAMP). • Construction of the remedies during the 2007 construction season. • Implementation of stormwater management controls (e.g., construction of any

permanent erosion and sediment control). • Restoration of areas disturbed by construction activities. • Post-construction maintenance activities. 2.2 CULVERT 105 SOUTH OF MECHANIC STREET

2.2.1 2007 EA COMPONENTS

• Removal of vegetation along the proposed installation corridor of the new

Culvert 105 inlet section (between CB-2 and the inlet at the North Ditch). • Excavation and proper disposal/management of existing soils to facilitate

installation of the new Culvert 105 inlet section and new catch basin (replacement of existing CB-2). Any removed soil determined to be a nonhazardous material will be permanently placed within FMC’s ESI Fill Area or, if determined to be hazardous, transported to an appropriate offsite disposal facility.


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• Removal of existing catch basin CB-2 (placed in the ESI Fill Area in accordance with the most current ESI Filling and Grading Plan or as C&D debris at an offsite NYSDEC-permitted solid waste disposal facility).

• Installation of a new catch basin in the vicinity of the removed catch basin CB-2.

• Installation of a new Culvert 105 section from the inlet of Culvert 105 to the new catch basin in the vicinity of the removed catch basin CB-2.

• Abandonment of existing portions of the Culvert 105 storm sewer system between the inlet and new catch basin by grouting the ends of the pipe and backfilling existing catch basin CB-1.

• Installation of a buried storm sewer pipe in the open ditch section(s) of Culvert 105 at Margaret Droman Park (south of Mechanic Street).

• Removal of sediments from manholes and catch basins within the Culvert 105 sewer system south of Mechanic Street. Any removed sediments determined to be a nonhazardous material will be permanently placed within FMC’s ESI Fill Area or, if determined to be hazardous, transported to an appropriate offsite disposal facility.

2.2.2 KEY DESIGN REQUIREMENTS • Surface-water drainage needs for Culvert 105 replacement options on the

Wooded Parcel and on Margaret Droman Park will be evaluated to determine if additional drainage structures (i.e., catch basins and/or drains) are needed.

• Invert elevations and design of the new Culvert 105 pipe section to be installed within the open ditch on Margaret Droman Park.

• Culvert 105 replacement inlet section (upstream of CB-2) routing/alignment on the Wooded Parcel.

• Design of the new Culvert 105 inlet piping and new catch basin on the Wooded Parcel.

• Appropriate temporary and permanent erosion and sediment control and stormwater management measures.

• Construction site access points, staging areas, material haul routes, decontamination areas, and security measures.

• Necessary survey control/procedures during installation of the new piping/catch basin.

• Abandonment options for the existing portion of Culvert 105 between the inlet and CB-2 and for catch basin CB-1 on the Wooded Parcel.

• Site restoration requirements for the construction areas on Margaret Droman Park and the Wooded Parcel.


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2.2.3 PROPOSED CULVERT 105 KEY DESIGN PARAMETERS

• The surface-water drainage needs will be evaluated for the Wooded Parcel, the open ditch area of Margaret Droman Park, and abutting properties. Topography, cover types, flow paths, and storage conditions will be taken into consideration during design activities to evaluate surface-water flow conditions necessary for design of the new Culvert 105 inlet section on the Wooded Parcel, catch basin, and the conversion of the open ditch section of Culvert 105 to a buried pipe at Margaret Droman Park. Additional surveying of the surface topography of these areas will be performed to better identify the existing surface-water drainage patterns and flow paths. In addition, the pre- and post-construction hydrologic conditions will be evaluated by calculation of unified stormwater sizing criteria, as described in the New York State Stormwater Management Design Manual.

• Figure 1 identifies the proposed alignment of the new inlet section of Culvert 105, upstream of CB-2. In 2005, pre-design probing for subsurface obstructions was performed along the proposed alignment of the new inlet section of Culvert 105. A new catch basin/manhole will be installed at the approximate location of CB-2. Additional catch basins or lawn drains may be installed to facilitate proper drainage of stormwater runoff on and adjacent to the Wooded Parcel.

• A buried pipe design (e.g., pipe type, pipe diameter, invert elevations, location of lawn drains or catch basins, pipe trench/backfill material placement) for the new Culvert 105 inlet section will be prepared after identification of the surface-water conditions and drainage requirements at and around the Wooded Parcel. The design will include appropriate excavation and backfilling requirements for the new Culvert 105 inlet pipe sections and new manholes and/or catch basin(s), as necessary. Figure 2 illustrates a conceptual cross-section of the new Culvert 105 inlet section.

• After identification of the surface-water drainage conditions near the open ditch section of Culvert 105 at Margaret Droman Park, a buried pipe design (e.g., pipe type, pipe diameter, invert elevations, location of lawn drains or catch basins, pipe trench/backfill material placement) will be prepared to replace the open ditch section. It is anticipated that the alignment of the new buried pipe will follow the alignment of the current open ditch section. The depth and width of the pipe trench that will be excavated to facilitate installation of the new buried pipe section will be determined after identification of the surface-water drainage requirements. Figure 3 illustrates a conceptual cross-section of the proposed buried pipe within the existing open ditch section of Culvert 105 at Margaret Droman Park.


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• Existing vegetation within the proposed alignment corridor of the new Culvert 105 inlet section and along the portion of Culvert 105 that traverses Margaret Droman Park will be removed. Abovegrade portions of small trees and woody vegetation will be chipped and the wood chips will be spread evenly within the work area, or stockpiled for later use as ground cover during restoration activities. Belowgrade portions of small trees and woody vegetation will be transported offsite for disposal at an NYSDEC-approved disposal facility.

• Temporary erosion and sediment controls will be installed adjacent to the new Culvert 105 inlet section corridor during construction to minimize the potential for migration of sediment and soils during construction activities.

• Excavated soils will be temporarily stockpiled on the Wooded Parcel and/or at the ESI Fill Area on the FMC Plant Site for waste characterization sampling. If the waste characterization sampling results determine that the excavated soil is nonhazardous, the excavated soil will be permanently placed in the ESI Fill Area. Alternatively, pre-excavation waste characterization sampling and analysis may be performed in the proposed excavation areas. Excess soil from installation of the new Culvert 105 inlet sections determined to be characteristically hazardous based on the results of the waste characterization sampling would be disposed of offsite at an appropriate disposal facility in accordance with applicable regulatory requirements.

• Following installation of the new Culvert 105 inlet sections and catch basin, the existing Culvert 105 inlet pipes will be abandoned by filling the ends of the pipes with concrete. Existing catch basin CB-1 and any voids around the catch basin structure will be filled with concrete to meet existing grades. The disturbed areas on the Wooded Parcel will be restored consistent with the remedy construction for the property (see below).

• Following installation of the new buried pipe section and new catch basin(s) at Margaret Droman Park, the areas disturbed during construction will be graded and restored by placing topsoil, seed, and mulch.

• Temporary erosion and sediment controls will be installed adjacent to the new buried pipe corridor at Margaret Droman Park during construction to minimize the potential for migration of sediment and soils during construction activities.

• Existing catch basins and manholes within the Culvert 105 storm sewer system south of Mechanic Street will be inspected following construction of the new inlet section on the Wooded Parcel. Accumulated sediments within the catch basins and manholes will be removed by vacuum truck or other appropriate method, beginning with the farthest upstream locations and


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moving downstream. Prior to removal of the sediment, any water in the catch basin/manhole will removed/pumped out and discharged down stream. Sediment from existing sediment chamber/manhole MH-N9 will be removed after cleanout of the upstream manholes/catch basins. The removed sediments will be staged at the FMC facility for waste characterization sampling prior to proper disposal.

• Sediments removed from catch basins/manholes and excess soil from installation of the new Culvert 105 inlet sections determined to be nonhazardous based on the results of the waste characterization sampling would be permanently placed in the ESI Fill Area or transported to an appropriate offsite disposal facility.

• Post-construction inspection and maintenance requirements will include inspection, monitoring, sediment sampling, and/or removal of accumulated sediments from the sediment chamber/manhole MH-N9.

Potential Issues • The existing pipe sections of Culvert 105 that will be connected to the new

buried pipe sections may not be at the necessary elevations or may not be adequately designed to meet the drainage requirements.

• Subsurface obstructions (e.g., building foundations, brick, concrete, and debris) may be encountered during excavation activities associated with installation of the new Culvert 105 pipe sections and catch basins/lawn drains. Additional excavation may be required to remove these obstructions. These materials would either be permanently placed in the ESI Fill Area or disposed of as C&D debris at an offsite NYSDEC-permitted solid waste disposal facility.

• A Stormwater Pollution Prevention Plan (SWPPP) may need to be developed to address drainage conditions on the Wooded Parcel and at Margaret Droman Park.

• The Village of Middleport currently does not have a drainage easement for Culvert 105 on the Wooded Parcel. FMC will help the Village of Middleport obtain drainage easements on the affected properties for future operation and maintenance activities.

• Access permission/permit is required from the Erie Canal Corporation to perform work on Margaret Droman Park and in the portions of Culvert 105 situated on the Canal Corporation property.

• The Village of Middleport will need to review and approve the proposed design for the new sections of Culvert 105.


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• Traffic control, safety, and permit requirements associated with access and sediment removal from Culvert 105 manholes and catch basins needs to be evaluated.

• Construction sequencing needs to be evaluated to minimize the potential of disruption to stormwater flow within the Culvert 105 storm sewer system during construction activities.

• Need to coordinate and sequence work associated with the implementation of the offsite 2007 Early Action remedial activities with the work to be performed in 2007 for the North Railroad Property Phase 2 ICM.

2.3 NORTH COMMERCIAL/INDUSTRIAL AREA – WOODED PARCEL

2.3.1 WOODED PARCEL REMEDIAL ALTERNATIVES/EVALUATION Four potential remedial alternatives were previously identified for the North Commercial/Industrial Area – Wooded Parcel and discussed during the November 8, 2006 meeting with the Agencies, the Village, and other community members. These remedial alternatives include the following: • Alternative 1 – No Further Action; • Alternative 2 – No Excavation; Soil Cover System Construction; • Alternative 3 – 2-Foot Soil Removal and Soil Cover System Construction;

and • Alternative 4 – Soil Removal to Background Level and Backfilling.

Two additional remedial alternatives have been subsequently identified for evaluation purposes. These alternatives include: • Alternative 5 – 1 Foot Soil Removal and Soil Cover System Construction;

and • Alternative 6 – 2-Foot Soil Removal at the Wooded Parcel Property

Boundary, 6-Inch Soil Removal Over the Interior Portions of the Wooded Parcel, 9-inch Soil Removal within the limits of the undeveloped access corridor portion of the Wooded Parcel, and Grade Restoration.

These six alternatives are compared based on existing arsenic concentrations in the surface and subsurface soil from samples previously collected within the boundary of the Wooded Parcel and presented in the Draft 2002 Sampling Program Report, dated June 2003, and the Technical Report on Data Sufficiency for the North Railroad Property, dated April 2005. Existing arsenic


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concentrations in surface and subsurface soil from samples previously collected within the limits of the undeveloped access corridor of the Wooded Parcel, which were identified in the Draft Soil Sampling Work Plan Areas Potentially Affected by Historic Deposition, dated May 2004, were also utilized in the alternatives evaluation. Soil data collected from two boreholes (A2J21 and A2J23) installed within the North Railroad Property Phase 1 ICM area have been excluded from this comparison since those locations were remediated in 2005. The following table provides a summary of the soil removal volumes and the average and maximum arsenic concentrations of remaining soils within Wooded Parcel for each identified alternative. NORTH COMMERCIAL/INDUSTRIAL AREA – WOODED PARCEL REMEDIAL ALTERNATIVES ANALYSIS SUMMARY

ALTERNATIVE

DESCRIPTION

REMAINING ARSENIC CONCENTRATION

Average Maximum

(ppm) (ppm)

ESTIMATED EXCAVATION

VOLUME (CY)

Alternative 1 No Action. 68.4 435 NA

Alternative 2 No excavation and installation of a 2-foot-thick soil

cover system.

68.4 435 NA

Alternative 3 Excavation of 2 feet of soils throughout the Wooded

Parcel and the installation of a 2-foot soil cover system.

36.9 239 12,500

Alternative 4 Excavation of the Wooded Parcel to background levels

and restoration to pre-excavation grades.

NA NA 50,400

Alternative 5 Excavation of 1 foot of soils throughout the Wooded

Parcel and the installation of a 2-foot soil cover system.

76.9 435 6,300

Alternative 6 Excavation depths of 6 inches of soil within interior

portions, 2 feet of soil along a 20-foot-wide perimeter

corridor of Wooded Parcel, 9 inches of soil within the

undeveloped access corridor south of Park Avenue,

and restoration to pre-excavation grades.

39.6 239 6,000

Based on the existing soil data, arsenic levels within the Wooded Parcel exhibit an average of approximately 68.4 parts per million (ppm), with a maximum level of approximately 435 ppm. Under Alternatives 1 and 2, these conditions would remain. Under Alternative 3 (2-Foot Soil Removal), the average remaining arsenic concentration would be approximately 36.9 ppm and the maximum remaining arsenic concentration would be approximately 239 ppm. This


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alternative would result in the excavation and disposal of approximately 12,500 cubic yards of soil from the Wooded Parcel. Alternative 4 would involve the excavation of approximately 50,400 cubic yards of soil from the Wooded Parcel and would result in remaining arsenic levels in soil at or below background levels. Alternative 5 would require excavation and disposal of approximately 6,300 cubic yards of soil from the Wooded Parcel and result in an average remaining concentration of arsenic of approximately 76.9 ppm with a maximum arsenic concentration of approximately 435 ppm. Alternative 6 would require excavation and disposal of approximately 6,000 cubic yards of soil from the Wooded Parcel and result in an average remaining concentration of arsenic of approximately 39.6 ppm with a maximum arsenic concentration of approximately 239 ppm. Based on this evaluation, FMC proposes Alternative 6, which entails excavation of 6 inches of soil from within the interior portions of Wooded Parcel, excavation of 2 feet of soil from a 20-foot-wide corridor around the Wooded Parcel property boundary, and backfill of clean, imported soils to existing grades. Alternative 6 provides a situation where the average and maximum concentrations of arsenic in remaining soils is significantly reduced, the amount of soil to be removed from the Wooded Parcel is minimized, while providing the best opportunity for maintaining and/or improving surface-water drainage conditions of the Wooded Parcel and adjacent (i.e., abutting) properties. As part of Alternative 6, the undeveloped access corridor of the Wooded Parcel south of Park Avenue would be excavated to a depth of 9 inches below existing grade, and backfilled with 9 inches of clean backfill soil to restore this parcel to existing grades. Under this approach, the average concentration of arsenic in remaining soils within the undeveloped access corridor of the Wooded Parcel would be approximately 10.9 ppm, with a maximum concentration of 18.9 ppm. Figure 4 depicts the proposed soil excavation limits within the Wooded Parcel for the preferred remedial alternative. 2.3.2 OFFSITE 2007 EARLY ACTION COMPONENTS • Removal of vegetation, surface debris, and rubble and the aboveground

remnants of the burned-down building within the property limits of Wooded Parcel.


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• Excavation and removal of soils to a depth of 6 inches below existing grades over the interior portions of the Wooded Parcel, excavation and removal of soil to a depth of 2 feet below existing grades in a 20-foot-wide corridor along the inside of the Wooded Parcel property boundary, and excavation and removal of soils to a depth of 9 inches below existing grade within the undeveloped access corridor of the Wooded Parcel.

• Excavated soils will be sampled and analyzed for waste characterization purposes. Any removed soil determined to be nonhazardous waste will be permanently placed in the ESI Fill Area. Any removed soil or material determined to be a hazardous waste will be disposed at an appropriate offsite disposal facility. All abovegrade building debris will be transported offsite for disposal at an approved solid waste management facility as C&D debris.

• Placement of a demarcation layer and subsequent backfilling with clean imported soils, suitable of sustaining vegetative cover, to existing grades.

• Re-vegetation with grass over the backfilled area and installation landscape planting.

2.3.3 KEY DESIGN REQUIREMENTS • The excavation areas and depths within the Wooded Parcel will be pre-

determined to eliminate the need for any additional soil sampling and analysis.

• Design of the post-construction final grades and stormwater drainage pattern based on the evaluation of the surface-water drainage needs and with consideration of the proposed design for the new Culvert 105 inlet section pipes and catch basin(s), as discussed above.

• Define the backfill requirements and site restoration requirements (i.e., final landscaping). The final landscaping design will be determined with consultation of the property owner, abutting property owners, and the CIG.

• Appropriate temporary and permanent erosion and sediment control and stormwater management measures.

• Construction site access points, staging areas, material haul routes, decontamination areas, and security measures.

• Identify necessary survey control/procedures to allow for establishment and verification of post-construction conditions.

• Determine the appropriate post-construction inspection and maintenance activities, if necessary.


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2.3.4 NORTH COMMERCIAL/INDUSTRIAL AREA – WOODED PARCEL PROPOSED DESIGN PARAMETERS

• Figure 4 illustrates the proposed excavation limits and depths for the Wooded

Parcel. A concrete pad is located at the southwest corner of the Wooded Parcel and will remain in place. Subsurface portions of foundations will not be removed and soil will not be excavated from beneath the burned-down building footprint/foundation.

• Following excavation activities, the Wooded Parcel will be restored to pre-construction grades utilizing the following conceptual design: - the excavation base may be regraded and/or excavated, if needed, to

facilitate adequate drainage conditions of the Wooded Parcel; - a demarcation layer will be placed over existing soils at the base of the

excavation; - 6 inches of clean soils, suitable of sustaining vegetative cover, will be

backfilled over the interior portions of Wooded Parcel; - 18 inches of clean soil, followed by 6 inches of clean soils suitable of

sustaining vegetative cover, will be backfilled over the 20-foot-wide perimeter corridor; and

- 9 inches of clean soils suitable of sustaining vegetative cover will be backfilled over the limits of the undeveloped access corridor of the Wooded Parcel.

• Debris from the burned-down structure on the Wooded Parcel will be removed to the existing ground surface and transported for disposal at an NYSDEC-approved solid waste management facility as C&D debris. Clean, imported backfill soils placed over or within the remaining footprint/foundation associated with the burned-down structure during restoration activities, if necessary, to meet adjacent grades and facilitate surface drainage.

• Excavated soils removed from the Wooded Parcel will be stockpiled onsite or at the ESI Fill Area for waste characterization sampling and analysis. Alternatively, pre-excavation waste characterization sampling and analysis may be performed in the proposed excavation areas. Soils determined to be nonhazardous based on the results of the waste characterization sampling will be permanently placed in the ESI Fill Area. Any soil determined to be characteristically hazardous will be disposed at an appropriate offsite disposal facility.

• Unless identified prior to detailed design, the restoration design will not include constructing facilities that require subsurface utility lines (e.g.,


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sanitary, water) and the design will not include any other intrusive features that may compromise the integrity of the restoration design.

• After completion of the backfilling activities, the area will be seeded and any landscaping plantings will be installed.

• Post-construction inspection and maintenance requirements will include inspection of the remediated Wooded Parcel and placement of use and other restrictions through an environmental easement on the property deed, if determined to be necessary.

Potential Issues • The post-construction final grading design can not adversely impact the

surface-water drainage of abutting properties. • Determination of the post-remedial use of the Wooded Parcel, considering

the Village of Middleport’s development plans, has yet to be determined. • The need for property use restrictions on the Wooded Parcel will need to be

evaluated. • Need to evaluate if the portions of the burned-down building need to be

excavated and/or backfilled to meet the final grading design for the Wooded Parcel.

• Evaluation of ESI Fill Area material placement sequencing in accordance with the current ESI Area Filling and Grading Plan.

• Additional survey of the property boundaries may need to be performed. • Coordination and sequencing associated with the implementation of the

offsite 2007 Early Action remedial activities and North Railroad Property Phase 2 ICM to be performed on the former Northwest Conrail Area.

3.0 2007 EARLY ACTION PRE-CONSTRUCTION ACTIVITIES

3.1 TASK PC1 – PROJECT-SPECIFIC WORK PLAN DEVELOPMENT AND

APPROVAL • Proposed 2007 Early Action Work Plan contents:

- Description of the Culvert 105 storm sewer system south of Mechanic Street and the North Industrial/Commercial Area – Wooded Parcel.

- 2007 Early Action SOW. - Description of work tasks. - Description of proposed public communication activities. - Description of anticipated excavation, filling, and grading activities.


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- Description of the proposed restoration work and final grades for the Wooded Parcel.

- Description of proposed new Culvert 105 inlet sections and catch basin. - Abandonment procedures for existing sections of the Culvert 105 inlet sections. - Description of the proposed buried pipe in the existing open ditch section of

Culvert 105 at Margaret Droman Park. - Description of the proposed sediment removal and disposition procedures at

existing manholes and catch basins within the Culvert 105 storm sewer system south of Mechanic Street.

- Pre- and post-construction survey requirements. - Sampling and Analysis Plan (e.g., backfill, waste characterization) (appendix). - Health and Safety Plan (HASP) (appendix). - CAMP (appendix). - Preliminary project schedule (appendix). - ESI Fill Area disposition sequence plan (appendix). - SWPPP, including erosion and sediment controls (appendix). - Filling and grading plan (appendix). - Operation and Maintenance Plan (separate submittal after completion of the

construction activities).

3.2 TASK PC2 – CONTRACTOR PROCUREMENT • Preparation and distribution of a Request for Proposal to prospective Contractors. • Review of Contractor bid proposals. • Selection of a qualified Contractor. 3.3 TASK PC3 – PUBLIC COMMUNICATIONS PLAN Proposed Activities • Activities intended to establish open communications with public and inform

adjoining property owners, public officials and community of projects. • Project-related contact list will be included in the 2007 Early Action Work Plan. • Draft and final 2007 Early Action Work Plan to be placed in the Middleport Free

Library. • FMC activities may include meetings or phone calls to affected property owners,

information sessions, progress newsletters, and fact sheets.


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3.4 TASK PC4 – ACCESS AGREEMENTS Proposed Activities

• Describe proposed work activities to adjacent property owners and possible activities on their properties.

• Obtain access agreements from affected property owners (i.e., owner of the Wooded Parcel, the Village of Middleport, the Erie Canal Corporation and, if necessary, owners of properties abutting the 2007 EA Areas).

• Document pre-construction conditions of the work areas and adjacent properties. • Perform topographic and property boundary survey, as necessary, by New York State

licensed surveyor. • Identify existing surface-water drainage issues, if any.

3.5 TASK PC5 – PRE-QUALIFICATION OF BACKFILL MATERIALS Proposed Scope • Backfill materials may include, but may not be limited to, any or all of the following:

a) Soil fill b) Granular fill c) Topsoil

• Sampling and analysis program for sources of backfill materials will be similar to that used and approved by the Agencies during previous remedial programs (e.g., North Railroad Property Phase 1 ICM).

Potential Issues

• Approval of backfill sources will be required prior to the start of construction

activities to confirm timely availability of necessary fill materials.

3.6 TASK PC6 – WASTE CHARACTERIZATION SAMPLING

Proposed Scope • The need for additional waste characterization soil sampling and analysis will be

determined during final design and will be based on existing soil analytical data and the need for excavation/grading of existing soils.

• In excavation areas/depths (if any) where existing waste characterization data are not sufficient for soils management planning purposes, additional soil samples may be


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collected for analyses of toxicity characteristic leaching procedure (TCLP) arsenic, TCLP lead, and TCLP chlorinated pesticides. The need for additional waste characterization sampling will be determined following agreement on final design requirements and determination of final excavation requirements.

• Soil sampling and analysis procedures will be similar to those used and approved by the Agencies during previous remedial programs (e.g., North Railroad Property Phase 1 ICM).

4.0 2007 EARLY ACTION CONSTRUCTION ACTIVITIES

4.1 TASK C1 – SCHEDULING AND PROGRESS MEETINGS Proposed Activities

• Preparation of detailed construction schedule. • Kick-off meeting and weekly progress meetings. 4.2. TASK C2 – MOBILIZATION AND STARTUP Proposed Activities

• Mobilization of equipment, materials, and personnel. • Setup of construction offices and facilities. 4.3 TASK C3 – SITE PREPARATION Proposed Activities

• Prior to beginning any work, site features and adjacent properties will be inspected

and documented to verify existing conditions, as noted under Task PC4.

• To extent possible, haul roads will be constructed on the FMC property, as necessary, to minimize truck traffic on public streets.

• Vegetation will be removed from the Wooded Parcel to the ground surface and chipped. Wood chips may be used as mulch following seeding and/or planting operations, or transported for placement in the ESI Fill Area.

• All nearby utilities and monitoring wells will be located, marked, and protected from damage.

• A New York State licensed surveyor will mark the property boundaries and survey pre-excavation elevations.


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• Appropriate exclusion zones, decontamination areas, staging/stockpile areas, security measures, and temporary erosion controls will be setup/installed and maintained.

• Portions of the FMC facility fence may need to be removed to facilitate construction and transportation activities.

4.4 TASK C4 – INSTALLATION OF NEW CULVERT 105 INLET SECTIONS

AND NEW CATCH BASIN Proposed Activities • Soils within the proposed Culvert 105 inlet section corridor will be excavated to the

lines and grades developed during detailed design. Excavated soils will be managed in accordance with Task C8 below.

• The new inlet sections of the Culvert 105 storm sewer system will be installed in accordance with the detailed design. Conceptual details are provided on Figure 2.

• Following installation of the Culvert 105 inlet sections, existing catch basin CB-2 will be removed and replaced with a new catch basin. Downgradient pipes associated with the Culvert 105 storm sewer system will be extended to meet the new catch basin.

• Following the completion of installation activities associated with the new Culvert 105 inlet section pipes and new catch basin, the ends of the old (existing) Culvert 105 inlet sections between the FMC-owned North Railroad Property and existing catch basin CB-1 and inlet sections between CB-1 and the new catch basin will be abandoned in-place by filling the ends of these sections with concrete. Catch basin CB-1, as well as any voids immediately around the outside of CB-1, will be backfilled with concrete to meet existing grades.

4.5 TASK C5 – INSTALLATION OF BURIED PIPE IN THE OPEN DITCH

SECTION OF CULVERT 105 AT MARGARET DROMAN PARK Proposed Activities • Soils in the open ditch section of Culvert 105 at Margaret Droman Park will be

excavated to lines and grades developed during detailed design. Excavated soils will be placed adjacent to the excavation for use as backfill material. Excavated soils deemed unsuitable for use as backfill will be managed in accordance with Task C8 below.

• The new buried pipe in this section will be installed in accordance with the detailed design. Conceptual details are provided on Figure 3.


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4.6 TASK C6 – REMOVAL OF SEDIMENTS FROM EXISTING MANHOLES AND CATCH BASINS WITHIN CULVERT 105 STORM SEWER SYSTEM SOUTH OF MECHANIC STREET

Proposed Activities Following completion of all pipe/catch basin installation activities, the existing manholes and catch basins within the Culvert 105 storm sewer system south of Mechanic Street will be inspected for the presence of accumulated sediments at the base of the manhole/catch basin. If present, sediments will be removed, to the extent possible, using a vacuum truck. Removed sediments will be managed in accordance with Task C8 below. Following the removal of sediments, each manhole/catch basin will be photographed and the condition of the structure will be documented. 4.7 TASK C7 – NORTH COMMERCIAL/INDUSTRIAL AREA – WOODED

PARCEL BACKFILL AND REGRADE

Proposed Activities

• Existing soils may be regraded and/or excavated to facilitate final drainage conditions of the cover system. The need for excavation and the depths and limits of any such excavation will be determined during detailed design.

• Debris from the burned-down building within the Wooded Parcel will be removed to the ground surface and managed in accordance with Task C8 below.

• The Wooded Parcel will be backfilled with clean, imported soils to restore the area to pre-construction grades.

• Appropriate efforts shall be made so that the construction activities do not compromise the integrity of any permanent structures (i.e., the public roads, nearby adjacent properties, buried utilities). If needed, the limits and/or depths of the surface cover and/or any anticipated excavations may be adjusted in the field, in consultation with the Agencies’ field representative, at the time of construction to avoid such compromising conditions.

• Soil requiring removal from the Wooded Parcel will be loaded into hauling vehicles (dump trucks or containers) for permanent placement in the ESI Fill Area or will be disposed at an appropriate offsite disposal facility. Soil loading and unloading will be performed in a manner that minimizes the potential for contact of excavated soils


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with the truck tires and undercarriage. As a result, excavated soil haul routes/roads shall be considered clean.

• Appropriate controls will be implemented to reduce the potential for dust generation during excavation, loading, hauling, and unloading. The hauling vehicles will be covered or the excavated soil shall be wetted down to reduce dust generation prior to transport to the ESI Fill Area or the FMC facility for waste characterization.

• All open excavations will be marked and protected (e.g., placement of barrier fencing) at the end of each workday.

• Unexpected items or unexpected soil impacts encountered (if any) during excavation activities will be characterized to determine appropriate soil management requirement for the materials. The Agencies’ field representative will be notified of the discovery of unexpected items or unexpected soil impacts (if any) that may require special handling, characterization, and/or disposal.

4.8 TASK C8 – EXCAVATED MATERIAL/DEBRIS DISPOSITION

Proposed Activities

• Excavated materials and removed sediments determined to be nonhazardous waste

will be transported and permanently placed in the ESI Fill Area.

• Debris associated with the burned-down building within the Wooded Parcel will be transported and disposed of at an NYSDEC-approved solid waste management facility as C&D debris.

• Materials permanently placed in the ESI Fill Area will be placed and covered in conformance with the most current version of the ESI Area Filling and Grading Plan.

• A haul route for transporting excavated soils to the ESI Fill Area will be established to eliminate the need for transport of such materials on public roads.

4.9 TASK C9 – RESTORATION

Proposed Activities

• Facility fencing removed to facilitate construction activities will be re-installed along

the southern limits of the Wooded Parcel.

• Disturbed topsoil areas will be seeded and mulched.

• Restoration of the Wooded Parcel will be based on anticipated future use of the property and determined in consultation with the owner of the Wooded Parcel and the


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community through the CIG and other groups such as the Middleport Remedial Advisory Group and the Village of Middleport governing bodies.

4.10 TASK C10 – PROJECT CLOSEOUT/DEMOBILIZATION

• Any monitoring wells affected by the work will be inspected, sounded, and re-

surveyed upon completion of the restoration activities.

• A final topographic survey will be prepared to show the recorded information for the new Culvert 105 pipes and catch basin(s), cover system limits, and final surface elevations.

• Demobilization of equipment and materials after completion of the project.

• Final restored areas will be documented by photographs and/or videotaping.

• Temporary erosion and sediment control measures will be removed from the site once all disturbed areas have been adequately stabilized.

4.11 TASK C11 – FINAL CONSTRUCTION REPORT

• A Final Construction Report will be prepared to document the work activities

performed, any deviations from the 2007 Early Action Work Plan, health and safety procedures performed, and air monitoring results.

5.0 HEALTH, SAFETY, AND SECURITY

Proposed Activities • Temporary chain-link fencing will be installed along the perimeter of the Wooded

Parcel and the open ditch section of Culvert 105 south of Mechanic Street prior to implementation of intrusive activities.

• An orange safety fence will be installed and maintained around all open excavations areas.

• Appropriate management plans will be developed and implemented for erosion control, water management, soil management, waste management, and emergency maintenance and contingencies.

• Exclusion zones will be established, as necessary, and only authorized personnel will be permitted to enter.

• Proper decontamination procedures will be followed. • A safe work environment will be maintained and safe work practices will be

followed.


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• The contractor will develop and implement a project-specific HASP, including a worker exposure monitoring program.

• A community air monitoring program will be implemented and will include: i) real-time air monitoring for respirable dust at one upwind and two downwind

locations and at areas where materials handling is being conducted; and ii) air monitoring for arsenic, lead, and chlorinated pesticides will be initially

performed daily during the first week of excavation and weekly thereafter (or more frequently based on the first week of sampling results).

6.0 POST-CONSTRUCTION OPERATION AND MAINTENANCE

• Following the completion the 2007 Early Action activities, FMC will prepare an Operation and Maintenance Manual for the 2007 EA. This Operation and Maintenance Manual will consider the timing of operation and maintenance activities and subsequent reporting activities (as required) throughout the FMC Plant Site (e.g., North Site Cover, Phase 1 ICM).

• Operation and maintenance activities described in the Operation and Maintenance Manual will include, but may not be limited to: i) inspection, sediment sampling, and/or removal of accumulated sediments from

the sediment chamber/manhole MH-N9; ii) maintenance activities; and iii) reporting requirements.

for discussion purposes only - middleport … · 2007 early action work plan for culvert 105 south...

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