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Lower Fox River Site Operation & Maintenance Plan for the Sediment Desanding and Dewatering Plant

Volume I

Prepared for Appleton Papers Inc. Georgia-Pacific Consumer Products LP NCR Corporation

For Submittal to Wisconsin Department of Natural Resources U.S. Environmental Protection Agency

Prepared by Tetra Tech EC, Inc. Anchor Environmental J.F. Brennan Co, Inc. Stuyvesant Dredging Inc.

September 2009

Document Control Number: LFRR-09-0323

Package Status Date Prepared By Approved By Pages Affected RevO 9/11/09 M.R. Bilimoria T.L. Blackmar All

R. J. Feeney H.W. VanDam

EPA Region 5 Records Ctr.

9/11/09 I 376909

It TETRA T E C H EC. INC.

Lower Fox River Remedial Action OUs 2-5

CONTROLLED DOCUMENT FORM

CONTRACTOR:

PROJECT NO.:

PROJECT NAME:

DOCUMENT CONTROL NO.

WORK PHASE:

DATE OF DOCUMENT:

DOCUMENT TITLE:

RECIPIENT GROUP:

SPECIFICATION SECTION AND PARAGRAPH NO. OF REQUIREMENT:

RECIPIENT:

METHOD OF DELIVERY:

SUBMITTED MATERIALS:

FILE NO.:

Tetra Tech EC Inc.

106-3876

Lower Fox River Remediation of OUs 2-5

LFRR-09-0323

2B

September 2009 Operations & Maintenance Plan for the Sediment Desanding

and Dewatering Plant, Volume I

US Environmental Protection Agency

Name Jim Hahnenberg - USEPA

Address Chicago, IL 60604

Phone (312)353-4213

Paper Copy

Volume I

10.1.3 SDDPO&MPlan

CONTROLLED DOCUMENT NO.: LFRR-09-0323-006

THIS FORM MUST REMAIN WITH THE ASSOCIATED DOCUMENT

September 2009 Rev. 0

Lower Fox River Site Operation & Maintenance Plan for the Sediment Desanding and Dewatering Plant

Volume I

Prepared for Appleton Papers Inc. Georgia-Pacific Consumer Products LP NCR Corporation

For Submittal to Wisconsin Department of Natural Resources U.S. Environmental Protection Agency

Prepared by Tetra Tech EC, Inc. Anchor Environmental J.F. Brennan Co, Inc. Stuyvesant Dredging Inc.

September 2009

Document Control Number: LFRR-09-0323

Package Status RevO

Date 9/11/09

Prepared By M.R. Bilimoria R. J. Feeney

Approved By T.L. Blackmar H.W. VanDam

Pages Affected All

9/11/09

TABLE OF CONTENTS Volume I

1.0 INTRODUCTION 1 1.1 Purpose 1 1.2 Organization of the O&M Plan 4 1.3 Using the O&M Plan 5 1.4 Site Location and Background 5 1.5 Description of OUs 5 1.6 Project Overview and Objectives 6 1.7 General Description of the SDDP 6

1.7.1 ....General Process Flow and Layout 9 1.8 Staffing and Training 16

1.8.1 ....Staffing 16 1.8.2 ....Training 17

1.9 Supporting Documentation 17 2.0 REGULATORY COMPLL\NCE 18

2.1 Beneficial Reuse of Separated Sand 18 2.1.1 ....Beneficial Reuse Suitability Criteria 19 2.1.2....Desanding andRewashingTechnologies 22

2.2 Storage, Transportation and Disposal of TSCA and non-TSCAPCB Wastes 23 2.2.1 ....TSCA Wastes and TSCA Landfill 25 2.2.2 ....Non-TSCA Wastes and Non-TSCA Landfill 29

3.0 RECORDS MANAGEMENT 32 3.1 Introduction 32 3.2 Process Control Recording 32

3.2.1 ....Process Monitoring 32 3.2.2 ....Equipment Operation Monitoring 34

3.3 Laboratory Data 34 3.4 Inventory Monitoring and Recording 34 3.5 Personnel Management 34

4.0 SAMPLING AND ANALYSIS PLAN DESCRIPTION 35 4.1 Purpose 35 4.2 Sampling and Analysis Data Objectives 35

4.2.1 ....Generalized Scope of Work 35 4.2.2 ....Data Quality Objectives 36

4.3 Sampling and Monitoring Program Procedures and Requirements 37 4.3.1 ....Sampling and Monitoring Programs 37 4.3.2 ....Quality Control Sample Requirements 42 4.3.3 ....Equipment Decontamination Procedures 43 4.3.4....Sample Identification, Documentation, Chain of Custody, Packaging, and Shipping 43

4.4 Laboratory Analytical Procedures and Requirements 47 4.4.1 ....Analytical Procedures 47 4.4.2 ....Laboratory Reporting Requirements 47 4.4.3 ....Data Review 48

5.0 HEALTH AND SAFETY 50 5.1 Introduction 50 5.2 Summary of Major Risks 50 5.3 Zero lacident Performance 50 5.4 Activity Hazard Analyses 51

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5.5 Personal Protective Equipment 51 6.0 PROCESS DESCRIPTION AND OPERATION 52 7.0 OPERATIONS 53

7.1 Initial Testing and Commissioning Procedures 53 7.2 Weekly Start-up and Shut-down Procedures 54 7.3 Operations 55

8.0 SYSTEM TROUBLESHOOTING 66 9.0 EQUIPMENT MAINTENANCE 68

9.1 General 68 9.2 Weekly Servicing and Maintenance 69 9.3 Winter Shut-Down (Annual) Maintenance 70 9.4 Spare Parts 70

10.0 WASTE TRANSPORTATION AND DISPOSAL 71 10.1 Background 71 10.2 Waste Disposal Criteria and Methods 71 10.3 Waste Disposal Facilities 71

10.3.1 ..Disposal Facility for TSCA Wastes 71 10.3.2 ..Disposal Facility for Non-TSCA Wastes 71

10.4 Waste Transportation Contractor Requirements 71 10.4.1 ..Qualifications 72 10.4.2 ..Trucking Equipment 72

10.5 Waste Quantity Determination 72 10.6 Shipping Documentation 72 10.7 Safety 72

10.7.1 ..Facility Safety 72 10.7.2 ..Public Road Transport Safety 72 10.7.3 ..Landfill Facilities Safety 73

10.8 Spill Response and Contingency Plan 73 10.8.1 ..Spill Procedures 73 10.8.2 ..Notification 73

LIST OF FIGURES

Figure 1-1 Lower Fox River and Green Bay Site 2 Figure 1-2 Sediment Processing/Water Treatment Building on the Former Shell Property 3 Figure 1-3 Sediment Desanding and Dewatering Plant Building 8 Figure 1-4A Process Flow Schematic Diagram - Screening and Desanding 10 Figure 1-4B Process Flow Schematic Diagram - Pre-thickening and Dewatering 11 Figure 1 -5 Process Equipment Layout - Sediment Desanding and Dewatering Plant 12 Figure 2-1 2009 Non-TSCA Dredge Material and Debris Characterization Process 26 Figure 2-2 2009 TSCA Dredge Material and Debris Characterization Process 27 Figure 10-1 Uniform Hazardous Waste Manifest Form 74 Figure 10-2 Bill of Lading Form 75 Figure 10-3 Non-Hazardous Waste Label 76 Figure 10-4 Hazardous Waste Label 77

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LIST OF TABLES

Table 2-1 Initial Suitability Criteria for Beneficial Reuse 19 Table 2-2 Separated Sand Testing Requirements for Beneficial Reuse Suitability 22 Table 2-3 Estimated Daily Sediment Desanding and Dewatering Production 23 Table 2-4 Hickory Meadows (non-TSCA) Landfill Acceptance Criteria 30 Table 3-1 CMCS Monitoring - Digital Signals 33 Table 3-2 CMCS Monitoring - Analog Signals 33

LIST OF APPENDICES Volume n

Appendix A

Appendix B Tools and Equipment

Appendix C Spare Parts

Final Process Design Basis Technical Memorandum

Tools and Equipment List

Spare Parts List

Appendix D Manufacturers' O&M Manuals Master Equipment List

ni 9/11/09

1.0 INTRODUCTION

This document presents the Operation & Maintenance Plan (O&M Plan) for the Sediment Desanding and Dewatering Plant (SDDP) for the remediation of polychlorinated biphenyls (PCBs) in Operable Units (OUs) 2 to 5 of the Lower Fox River and Green Bay Site (Site; Figure 1-1). The design of the SDDP has been completed by Boskalis Dolman (Boskalis) and Tetra Tech EC, Inc. (Tetra Tech), with support from various subcontractors. The equipment needed for the SDDP has been specified and procured by Boskalis and dredging will be performed by J.F. Brennan (Brennan). The SDDP operations will be conducted in the sediment processing building located on the former Shell property (see Figure 1-2). The water generated by the SDDP operations will be treated in the adjacent Water Treatment Plant (WTP) to meet the discharge performance goals contained in the Design Report (Volume 1, Tetra Tech EC, Inc, et al, April 2009) before being returned to the Lower Fox River. The operation and maintenance procedures for the WTP are not included in this document and are described separately in a companion document, the Operation & Maintenance Plan for the Water Treatment Plant.

The PCB cleanup remedy for the Lower Fox River was originally set forth in Records of Decision (RODs) for OUs 2 to 5 issued in December 2002 and June 2003 by the United States Environmental Protection Agency (USEPA) and the Wisconsin Department of Natural Resources (WDNR) under the authority of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended, 42 U.S.C. §§ 9601-9675. The RD requirements for OUs 2 to 5 were originally set forth in the Administrative Order on Consent (AOC) and associated Statement of Work (SOW) for OUs 2 to 5 (USEPA 2004), executed in March 2004 by Fort James Operating Company, Inc.' (Fort James) and NCR Corporation (NCR) (collectively the "RD Respondents") in cooperation with the USEPA and WDNR (collectively the "Response Agencies"). USEPA and WDNR are overseeing the RD process, and design documents prepared by the RD Respondents are subject to review and approval by USEPA and WDNR. In June 2007, a ROD Amendment was issued by USEPA and WDNR that made changes to parts of the remedy described in the original RODs in response to the new information analyzed in the Basis of Design Report (BODR), and also from experience with prior remediation activities at the Site (USEPA and WDNR 2007).

1.1 Purpose

This O&M Plan was written to provide a generalized set of instructions of the methods and procedures required to maintain and operate the SDDP at the site. This Plan includes information pertaining to the operation and maintenance of the facility, regulatory requirements for plant operation, management of plant records, qualifications of plant personnel, sampling and analysis requirements, health and safety procedures, and waste handling procedures.

This Plan is supplemented by equipment manufacturer O&M manuals for each major equipment component. As the project progresses, additional equipment manufacturer O&M information may be added, as it is obtained. This Plan is to be treated as a living document that will require periodic updating as information and operational experience is obtained.

' In January 2007, Fort James Operating Company, Inc was converted to Georgia-Pacific Consumer Products LP.

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o

/ \ y USACE Channe) Derfinilron

/^\y American Transmission Company Line

fr^\y Transmission System

/ \ / Natural Gas Pipeline

I I Fox Rivar Boundary

I I Municipal Bour̂ dary

Figure 1-1 Lower Fox River and Green Bay Site

Lower Fox River OU 2-OU 5

TETRA TECH

V£<^<;HOR

1.2 Organization of the 0«&M Plan

The purpose of this O&M Plan is to facilitate the understanding of key operations and maintenance features of this facility. The following gives a brief overview of the remaining sections of this O&M Plan.

• Section 2.0, Regulatory Compliance, outlines local, state and federal codes and regulations pertaining to the operation and maintenance of the SDDP. Initial suitability criteria for beneficial reuse of the sand separated from the dredged material under Wisconsin Statute 289.43 and Wisconsin Department of Natural Resources (WDNR) Administrative Code requirements under Chapter NR 538 (beneficial use of industrial byproducts), paint filter test and other test parameters required by Veolia ES Hickory Meadows Landfill, Wayne Disposal Landfill and other operational requirements are contained in this section.

• Section 3.0, Records Management, describes record keeping forms and procedures for recording data from the operation and maintenance of the SDDP.

• Section 4.0, Sampling and Analysis Plan Description, outlines the schedule and procedures for sampling and analyzing the various influent, intermediate, and effluent process streams associated with the operation of the SDDP. Adherence to the quality standards and schedules for sampling and analysis described in this section are critical to the compliant, safe and efficient operation of the SDDP.

• Section 5.0, Health and Safety, contains safety standards and procedures for all aspects of SDDP operation and maintenance. This section along with the Health and Safety Plan must be consulted prior to the execution of any tasks performed by Operators and contractors to ensure they are performed in compliance with applicable safety procedures.

Section 6.0, Process Description and Operation, describes the functions and relationships of the major pieces of equipment in the 19 process loops of the SDD system. The Computer Monitoring and Control System (CMCS) programming is developed from these descriptions to ensure the process equipment fiinctions properly with respect to the rest of the system. Manual and remote electronic controls and equipment interlocks are detailed in this section.

Section 7.0, Operations, contains procedures for the daily operation of process equipment. Set points and ranges of operational parameters for normal function of the desanding and dewatering process are found in this section.

Section 8.0, System Troubleshooting, highlights procedures for diagnosing and solving problems with the major pieces of equipment in the SDDP. Additional troubleshooting information is also found in Appendix D, Manufacturers' Operation and Maintenance Manuals.

Section 9.0, Equipment Maintenance, includes a matrix outlining the schedule and procedures for performing preventive maintenance on system equipment. This section also describes maintenance record keeping procedures and instructions for housekeeping and the general upkeep of the SDDP.

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• Section 10.0, Waste Transportation and Disposal, describes the requirements for on-site storage, marking, transportation, and disposal of all liquid and solid waste generated at the SDDP. This section includes the requirements for selecting and approving subcontractors to handle and dispose of the waste generated at the facility, as well as record keeping requirements for waste generation and disposal.

1.3 Using the O&M Plan

The purpose of this O&M Plan is to facilitate the understanding of key operations and maintenance features of the SDDP. A cursory review of this Plan by a new Operator will not qualify him/her to operate and maintain the Facility. Side-by-side training with an experienced Operator, a comprehensive review of this O&M Plan, and the appropriate State of Wisconsin Operator Certification are recommended to qualify a new Operator.

This O&M Plan should be updated periodically to remain current. The Plan should be revised when new and improved techniques are devised for operating and maintaining the SDDP.

1.4 Site Location and Background

The Lower Fox River Site (CERCLIS ID # WIOOO1954841) as defined by the Response Agencies extends 39 miles from the outlet of Lake Winnebago to the mouth of the river where it discharges into Green Bay (Figure 1-1). The Lower Fox River is the most industrialized river in Wisconsin. Since the mid 1800s, water quality has been degraded by expanding industries and communities discharging sewage and industrial wastes into the river as well as by agricultural activity (USEPA and WDNR 2003). PCBs were discovered in the Lower Fox River in the 1970s. As set forth in the RODs, PCBs are the focus of current RD and RA efforts. This section of the Fox River includes what is considered the highest concentration of paper mills in the world, and also includes six publicly owned treatment works (POTWs). Approximately 270,000 people reside in the communities along the river. Although the river is no longer used for commercial shipping, twelve dams and locks are located on the Fox River near towns and industries. PCBs have been detected in both surface water and sediment throughout the Lower Fox River and Green Bay. Fishing is common throughout the Lower Fox River and Green Bay. Fish consumption advisories issued by WDNR are still in effect for many species in the Fox River, Green Bay and Lake Michigan.

1.5 Description of OUs

The Lower Fox River is divided into five OUs:

• OU 1 is also known as Little Lake Butte des Morts. The Neenah and Menasha Dams control the pool elevation of Lake Winnebago and the discharge to the upstream end of OU 1 at river mile (RM) 39. RD and RA activities in OU 1 were addressed under a separate SOW and Consent Order.

• OU 2 extends from the Appleton Locks at RM 31.9 to the Little Rapids Dam at RM 13.1. This unit contains the majority of locks and dams in the Lower Fox River system and the greatest elevation drop and gradient. Sediments have a very patchy distribution in this reach with extensive intervening bedrock exposures. The OUs 1 to 2 ROD calls for active remediation in Deposit DD only, while monitored natural recovery (MNR) is the selected remedy for the remainder of OU 2.

• OU 3 extends from the Little Rapids Dam to the De Pere Dam at RM 7.1. Soft sediment covers most of this unit.

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• OU 4 extends from the De Pere Dam to the river mouth at Green Bay. This OU contains a federal navigation channel, the northern portion of which is currently maintained by the U.S. Army Corps of Engineers (USACE). The area around OU 4 is highly urbanized, and includes the City of Green Bay.

• OU 5 begins at the river mouth, and includes the entire bay of Green Bay, which is approximately 119 miles long and is an average of 23 miles wide (USEPA and WDNR 2003). The OUs 3 to 5 ROD specified MNA as the selected remedy for OU 5, with the exception of dredging and capping near the river mouth.

1.6 Project Overview and Objectives

In 2009, two 8-inch hydraulic dredges and one 12-inch hydraulic dredge will be used for removal of TSCA and non-TSCA sediments at OUs 2, 3, and 4. The dredges will remove the sediment to the neatline in OUs 2 and 3 and pump the material through the pipeline and accompanying floating booster stations to the upstream De Pere Dam easement, crossing into OU 4 on the parcel owned by USACE between the De Pere Dam and lock and proceeding through OU 4 to the dewatering facility at the former Shell property staging and material processing facility (Design Report Volume 1, Tetra Tech EC, Inc. et al, April 2009). Mechanical dredging will be used as an option only if hydraulic dredging cannot be conducted in certain areas. The sand fraction of contaminated sediment that is removed from OUs 2 to 5 will be separated from the finer-grained dredge material, washed or otherwise treated as practicable, and beneficially reused to the extent feasible. The sediment will be processed through several stages to enable efficient and effective mechanical dewatering of the fines using membrane-type filter presses. The initial stages of desanding will include coarse debris separation, coarse and fine sand separation, and pre-thickening.

Geotechnical characterization of the sediment that is present within the targeted sediment removal areas in OUs 2 to 5 indicates that the sediment contains a significant percentage of sand that could potentially be separated from the sediment slurry. This is shown in the RD investigation samples collected between 2004 and 2007, the additional geotechnical samples obtained by Boskalis in October 2007, and the more recent in-fill sampling data obtained during 2008. The primary objective of the SDDP is to separate the dredged sediment from the water slurry in the form of a filter cake and make it suitable for cost effective disposal, enabling optimal performance of the dredge production rates without interruption and thereby permitting the achievement of planned remedial action goals of the amended ROD to complete the RA within 10 years. As an initial part of the SDD process, the sand fraction dredged from the river will be separated from the sediment. The benefits of sand separation are to:

• Reduce the solids loading to the dewatering system; • Provide a supply of relatively clean sand that could be sold for off-site use or used beneficially

on site, subject to approval by the WDNR; • Significantly reduce dewatering, transportation and disposal costs associated with the

production of waste filter cake, thereby reducing the flow of truck traffic on local roads and conserving local landfill disposal space; and,

• Reduce wear on the dewatering equipment and the need for subsequent maintenance.

1.7 General Description of the SDDP

Starting in 2009, contaminated sediment will be dredged by Brennan from the OUs 2-5 target areas using the two 8-inch hydraulic dredges Ashtabula and Palm Beach and the 12-inch hydraulic dredge Mark Anthony. The dredged sediment will be accompanied by river water and transported at a maximum rate of approximately 6,000 gallons per minute (gpm) to the SDDP via submerged 8-inch and 12-inch dredge

6 9/11/09

material transfer pipelines. The estimated sustained maximum production rate for the two 8-inch hydraulic dredges operating at 65 percent uptime in OUs 2 and 3 and the 12-inch dredge operating at 80 percent uptime in OU 4 (likely to be the maximum uptime as per Brennan) will be approximately 220 in situ cy per hour. The solids content in the slurry is assumed to be approximately 9 to 11 percent by weight, but will likely fluctuate in the range of 5 to 15 percent by weight.

The SDDP and filter cake storage will be housed at the former Shell property in two adjacent buildings that have been sized based on equipment and filter cake storage needs. The equipment sizes and storage requirements are based on sediment mass balance calculations for sediment dewatering and filter cake production. The SDDP process design and results of equipment sizing calculations are presented in the Final Process Design Basis Technical Memorandum for Sediment Desanding and Dewatering System and Water Treatment System, dated April 17, 2009 (Process Design Technical Memorandum). A copy of this Technical Memorandum is presented in Appendix A.

The entire plant will consist of the following major structures, as depicted on Figure 1-3: • 100,000-square-foot building housing the mechanical operations • 36,000-square-foot debris and sand staging area • 16,500-square-foot filter cake area • Two 260,000-gallon water buffer storage tanks in addition to an overflow storage tank.

Assumptions regarding dredging production rates and maximum flow rates to the SDDP were provided by Brennan and Boskalis, respectively, and are summarized in the sections below. These assumptions, and the sediment characterization data mentioned above, were used to specify and size the equipment needed for the desanding and dewatering operation discussed herein.

Maximum, average, and minimum production rates were also established in the Process Design Technical Memorandum, and are 250 in situ cubic yards (cy) per hour (short-term maximum), 220 in situ cy per hour (sustainable maximum), 150 in situ cy per hour (average required to meet targeted annual sediment removal rates), and 120 in situ cy per hour (short-term minimum). These production rates are equivalent to a solids content of approximately 9 to 11 percent by weight. These rates were developed based on the RD investigation samples and dewatering tests performed by press manufacturers Siemens Water Technologies (formerly U.S. Filter) in Holland, Michigan and Andritz in Arlington, Texas on the six composite sediment samples collected by Boskalis, and the more recent in-fill sampling data obtained during 2008..

The minimum production rate of 120 in-situ cy per hour anticipated for the dredges is based on minimum sediment transport velocity requirements for the HDPE pipelines. The sediment characterization data indicate the sediment to be dredged will consist primarily of silts and fine sand, with occasional coarse sand. An 8-inch HDPE dredge line transporting silts and fme sands has a minimum required flow velocity of approximately 3.1 feet per second (fps) to maintain suspension of fine particles in the slurry. An additional 1.0 foot-per-second above this minimum velocity has been added as a factor of safety in the design, for a resulting flow velocity of 4.1 fps. This is approximately 642 gpm for each 8-inch dredge, or approximately 1,284 gpm for the two 8-inch dredges. For the 12-inch dredge, the minimum required flow velocity for silts and fine sands through the 12-inch HDPE dredge line is approximately 3.9 fps, or 4.9 fps with the 1 fps added for factor of safety. This is equivalent to approximately 1,800 gpm. Therefore, the minimum flow requirements for sediment suspension, with 1 fps added to allow a minimum 1.25 factor of safety for flow, is 1,284 gpm plus 1,800 gpm, or a total flow of approximately 3,084 gpm for the three dredges. This is 51.4 percent of the maximum flow of 6,000 gpm that the

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SERVICE DOOR

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- 16" X 25' H TRUCK ENTRANCE OVERHEAD DOOR

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desanding and dewatering system is designed to handle. The 120 in-situ cy per hour is just slightly under the corresponding solids load of 128.5 in situ cy per hour (51.4 percent of 250 in-situ cy per hour) for the minimum flow of 3,084 gpm. Therefore, this would yield a lower nominal percent solids value in the slurry. The flow of 3,084 gpm with 120 in-situ cy/hr of production is considered a minimum anticipated short-term rate for dredge production.

Although the production capabilities of the individual dredges are greater than the planned production rate, no dredge will operate at higher-than-planned production rates unless directed to do so to compensate for lower-than-planned production by another dredge, hi addition, solids flow through the dewatering system will be monitored at key points and dredge production adjusted as needed to optimize the dredging, desanding, and dewatering process.

The dredged material will initially be processed through oversize (i.e., >6mm) material separation, coarse and fme sand separation, and pre-thickening, to enable subsequent mechanical dewatering of the fines using eight membrane filter presses (see process flow diagrams Figures 1-4A and 1-4B). Although the addition of two more presses has been considered, the conditions under which these additional presses would be needed are very unlikely to occur. However, if this critical combination of conditions does occur, another option would be to simply adjust the dredge production rate accordingly, for a temporary period of time.

1.7.1 General Process Flow and Layout

Two Process Flow Schematic Diagrams are presented on Figures 1-4A and 1-4B, which illustrate the design flow rates through the desanding and dewatering processes. These drawings also include a list of key equipment needed for each process. A general equipment layout is shown on Figure 1-5, Process Equipment Layout - Sediment Desanding and Dewatering, and includes additional equipment that may be added as needed to provide additional capacity. A brief description of each step of the desanding and dewatering processes is provided in the following sections. Mass balance calculations prepared by Boskalis, along with equipment capacity and sizing information are presented in the Final Process Design Basis Technical Memorandum in Appendix A.

1.7.1.1 Initial Screening and Thickening Process

Slurried sediment will be pumped to the former Shell property facility in separate 8-inch diameter and 12-inch diameter HDPE pipelines that extend from the dredged areas. These pipelines will enter the sediment processing building and will be combined into a manifold that will discharge into the Scalping Screen and then to the slurry thickening units. These units have been sized to handle the maximum design flow rate of 6,000 gpm and 250 in-situ cy/hr of solids, but should be operating at the average production flow rate of 3,600 gpm and 150 in situ cylhx most of the time. The initial screening will remove wood, gravel and debris larger than 6 mm in size (equivalent to 6,000 microns) that could hinder the desanding process, and the screened material will be conveyed outdoors to a roll-off box or stockpile for subsequent removal.

The Wash and Sieve Drum (Drum) is not installed in the SDDP building, it will be located at the offloading station on the bank of the Lower Fox River on the Former Shell Property. It can be considered as an optional pre-treatment step before the Scalping Screen. Although the Drum can be used for processing hydraulically dredged sediment slurry, it is primarily intended for use with mechanically dredged material that will be off-loaded from transport barges using cranes.

Dredged material slurry from the separate 8-inch diameter and 12-inch diameter HDPE dredge pipelines along with mechanically dredged material will be transferred into the input hopper that feeds the Dram

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o R PROCESSlScromikig 1

LOWER FOX RIVER SITE OPERABLE UNITS 2-5 GREEN BAY, WISCONSIN

PROCESS FLOW DIAGRAM

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PROCESS FLOW DIAGRAM

PRE-THICKENING AND DEWATERING

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(Trommel). Process water will be used to slurry the mechanically dredged sediment and flush it into the Drum. Here the coarse debris (material that is larger than 1 inch) will be sprayed with process water for cleaning and separated for disposal. The remaining slurry, free from larger particles will flow into the Drum Slurry Tank, from where it will be pumped via the Drum Slurry Pump to the Scalping Screen. Following the initial screening, the sediment slurry will be pumped to Slurry Holding Tank No. 1.

From this tank the slurry (at approximately 5 to 15 percent solids) will be pumped using two large pumps (3,300 gpm each) to the Slurry Thickener Tank, which is designed to flatten out expected short term density variations and to provide a minimized but constant hydraulic load to the desanding equipment. When processing relatively dense, sandy sediment, a flow of 2,200 gpm (500 cubic meters per hour) will be pumped to a set of 63 micron Thickener Separators. The overflow of these Separators (fines less than 63 microns) will be redirected to the Residue Tank and the underflow (sand greater than 63 microns) will flow back to the Slurry Thickener Tank for subsequent flow to the sand separation units. To minimize the misplacement of sand to the overflow, the negative pressure in the separators will be set at a minimum. The thickened slurry will be pumped to the two parallel treatment trains of the coarse sand desanding unit at a constant flow of approximately 4,400 gpm (1,000 cubic meters per hour) using two 2,200 gpm (500 cubic meters per hour) pumps (note: pump capacities in gallons per minute are included in the Major Equipment List on Figure 1-4A).

When processing relatively fine, soft sediment, the solids load to the desanding step will be sufficiently low that one of the two parallel sand separation treatment trains will be sufficient to handle the desanding. To minimize the hydraulic load to the desanding step, a total flow of 4,400 gpm (1,000 cubic meters per hour) will be pumped to the thickener separators, where a larger flow will be redirected to the Residue Tank. The thickened slurry will be pumped to one treatment train in the coarse sand desanding unit, using one slurry pump at a constant flow of 2,200 gpm (500 cubic meters per hour). Both Slurry Tank No. 1 and the Slurry Thickener Tank will be equipped with an overflow weir to redirect the incoming flow to the Overflow Tank in case of an emergency plant shutdown.

1.7.1.2 Desanding Process

The desanding operation consists of screening and thickening of the dredge slurry and removal of sand greater than 63 microns using a two-stage removal process. The desanding operation will produce two sand products that will be evaluated for beneficial reuse. The desanding plant has been designed to handle the variation in in-situ sediment characteristics as determined during the 2007 sampling event performed by Boskalis. Since this sediment generally exhibited a higher sand content and higher solids content than the sediment characterized as part of the RD investigations, the desanding process is also designed to accommodate the sediment characterized during the RD.

The first Sand Separation Unit includes two parallel treatment trains that separate the coarse fraction (150 -microns to 6mm) using hydro cyclones, cone-shaped ("T-type") upstream classifiers, dewatering screen and Slurry Tank No. 2. The hydro cyclones are so-called "separators", operating with an adjustable negative pressure inside the cyclone and an underflow regulator. These cyclones are capable of handling some input density variations and are used to produce a relatively dry underflow even at low input sand concentrations.

The separator underflow will be polished using an upstream classifier. For this purpose, clean water will be injected through a series of pipes and nozzles inside the upstream classifier. The polished coarse sand will be dewatered on a dewatering screen and stockpiled using a conveyor belt equipped with a belt weighing device. The separator, upstream classifier and dewatering screen will be constructed above

13 9/11/09

Slurry Tank No. 2. All overflow water will be collected in this tank to be used as feed for the Fine Sand Separation Unit. The level in Slurry Tank No. 2 will be kept constant through the use of a recovery separator, which sends overflow to the Residue Tank.

The fine sand collected in Slurry Tank No. 2 will be pumped to the Fine Sand Separation Unit, which includes parallel treatment trains with 63 micron separators, a flat-bottom-type upstream classifier, dewatering screen and Slurry Tank No. 3. The fine sand will be separated in the same manner and using the same flow rates as described for the coarse sand above using 2,200 gpm or 4,400 gpm (500 or 1,000 cubic meter per hour) flow rates, depending on the solids load in the input material. The separator, upstream classifier and dewatering screen will be constructed above Slurry Tank No. 3. Separator overflow water will be collected in the Residue Tank; and the overflow from the upstream classifier will be collected in Slurry Tank No. 3. Recovery separators will be used to recover the fme sand passing the dewatering screen. The recovered fine sand will be directly dropped on the front end of the dewatering screen. The polished and dewatered fine sand will be stockpiled using a conveyor belt equipped with a belt weighing device. Excess overflow from the recovery separators will be partially routed to the Residue Tank, which feeds the pre-thickening and dewatering process.

The desanding process follows the screening process, which removes debris and solids larger than 6mm. Sand is the inorganic coarse fraction passing the No. 4 sieve, which is equivalent to 4.75 millimeters (mm,) and fme fraction not passing the No. 230 sieve, which is equivalent to 0.063 mm or 63 microns. The initial screening will therefore remove all gravel and the portion of the coarse sand with particle sizes ranging from 4.75 mm to the 6mm screen opening size. The process design characteristics, equipment loads estimated based on the composite samples, and sizing of the fine and coarse sand separation equipment are provided in the Final Process Design Basis Technical Memorandum in Appendix A

1.7.1.3 Dewatering Process

Sediment slurry that collects in the Residue Tank will be pumped through four separate pipelines to the Pre-thickener Tanks, with coagulant/polymer added in each pipeline. In addition, coagulant will be added to the Residue Tank. The Residue Tank will be equipped with a flow/density measurement system, which will be monitored and used to adjust the coagulant/polymer dosing automatically and minimize overdosing. A coagulant/polymer make-up and dosing system will be linked to each pump system on each pipeline.

After coagulant/polymer dosing, the full flow of material will be directed to four 59-foot (18-meter) diameter circular Pre-thickener Tanks. The flow will enter these tanks in the center and supernatant water will leave through an overflow weir and collection system on the upper outer limits of each tank. Settled sludge will be removed from these tanks using a bottom scraper system, which moves the sludge into a center sump area in the bottom of the tanks. The sludge will then be pumped from the sump area using two large sludge pumps for each tank. The pre-thickened sludge, with 15 to 25 percent solids, will be pumped at a constant flow rate of approximately 700 gpm (160 cubic meters per hour) from each Pre-thickener Tank into the Sludge Holding Tanks. Supernatant in the Pre-thickener Tanks will drain via overflow weirs to the Water Buffer Tanks, which routes excess water to the water treatment system. Treated water from the water treatment plant will be piped to the Process Water Tank that supplies water back into the desanding and dewatering plant, as needed, for process operations such as coagulant/polymer make-up and sand polishing.

The sludge pumps and coagulant/polymer systems have each been designed to handle the total flow even with one of the pumping systems out of order. The hydraulic load from the sludge pumps into the Pre-thickener Tanks and from the Pre-thickener Tanks to the Sludge Holding Tanks can be split in such a

14 9/11/09

way that the fiill pre-thickening and sludge holding capacity can be used at all times, even with one of the three sludge pumping systems out of order.

The final step in the dewatering process is the mechanical dewatering using Membrane Presses. The pre-thickened sludge, at approximately 15 to 25 weight percent solids, will be pumped into these presses using two 660 gpm (150 cubic meters per hour) centrifugal pumps. Polymer will be dosed downstream of the pumps, before entering the presses, to optimize the sediment dewatering characteristics.

During the filling of the presses, water from the pre-thickened and flocculated sludge draining through the filter cloth will be allowed to leave the presses and will drain to a Filtrate Water Tank. The increasing pressure in the press and the total flow and amount of solids pumped into each press will be measured continuously. After the relevant set-points are reached, the filling of the press will be stopped and the membranes slowly inflated. To further dewater the filter cake, additional pressure of up to 225 pounds per square inch (psi) will be applied using the membrane water inflation system. Filtration will be achieved through a woven polypropylene filter fabric selected during field pilot testing performed in June and July 2008. After the pressure has been applied for a sufficient period and the flow of filtrate has reached a preset minimum, the system pressure will be lowered to normal atmospheric levels. The presses will then be opened and the filter cake discharged to a conveyor belt. The conveyor belt from each press will transport the filter cake onto another conveyor belt (with a weighing device) that will convey the cake to the storage area. Water collected in the Filtrate Water Tank will be recycled back to the Pre-thickener Tanks.

The Sludge Holding Tanks will hold conditioned sludge that will be pumped into the Membrane Presses on a cycle time of approximately 75 minutes, which includes the time to open the press, drop the filter cake and be re-closed.

1.7.1.4 Excess Capacity Dewatering System

To allow a measure of additional capacity, the dewatering system has been sized for an incoming flow rate of 5,280 gpm from the dredges with a solids load of 220 in situ cy/hr as a sustainable maximum with 100 percent press uptime. This will provide operational flexibility to handle fluctuations in dredge production rate, variations in sediment properties, and varying press uptime. This operational flexibility will exist in the production range of approximately 120 to 200 in situ cy/hr, and additional capacity of approximately 10 percent will exist with the potential increase in the production rate of 200 in situ cy/hr to the sustained maximum rate of 220 in situ cy/hr, as shown below:

(220 cy/hr - 200 cy/hr) / 200 cy/hr = 10%

In addition to this excess capacity for solids, the dewatering plant includes an Overflow Tank to handle emergency overflows, and the potential to add two Membrane Presses, a Sludge Holding Tank, and a Pre-thickener Tank to the dewatering system if needed. The proposed location for two additional Membrane Presses is shown on Figure 1-5. The addition of these Membrane Presses would require relocation of the Filtrate Water Tank. The additional Sludge Holding Tank would be added next to the other Sludge Holding Tanks, and the Pre-thickener Tank would be sized to fit in the remaining space available without limiting maneuverability in the area for necessary maintenance activities. Additional pumps and pipelines will also be provided to allow units to go out of service for regular maintenance.

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1.7.1.5 Water Treatment

The water treatment system has been designed to treat wastewater generated during the desanding and sediment dewatering processes. It will operate continuously during dredging operations which are expected to be 24 hours/day, 5 days a week. If necessary, the treatment system will be capable of operating 24 hours/day, 7 days a week. The system is designed to continuously treat a maximum flow volume of 6,000 gpm but can efficiently operate at lower flow volumes expected to average 3,500 to 4,500 gpm depending upon dredging and dewatering operations. As described previously, a flow of 3,000 gpm is considered a minimum flow required to maintain suspension of silt and fine sand particles in the pipelines. It is also the minimum flow rate which results in a velocity of at least 10 ft/sec at the diffuser nozzles in the river, which is necessary to achieve an acceptable dilution of ammonia. The two 260.000 gallon Water Buffer Tanks upstream of the water treatment system allow for balancing throughput with operations in the desanding and dewatering facilities. The water treatment system will be staffed continuously during operation by trained and qualified wastewater treatment Operators.

From the Water Buffer Storage Tanks the wastewater will be pumped in a once-through process through the water treatment system and into a 260,000 gallon Effluent Holding Tank. The treatment system consists of the following processes:

• Twenty-four (24) 20,000 lbs. mixed media filtration vessels • Six (6) multi bag filter vessels • Three (3) high flow cartridge filters; and • Eighteen (18) 20,000 lbs. granular activated carbon vessels.

The water treatment system has been generally arranged as three treatment trains. Individual vessels or entire treatment trains can be brought online or taken offline and isolated as needed depending on the flow volumes, contaminant concentrations and maintenance requirements.

The system has been primarily designed as a suspended solids removal process reducing total suspended solids (TSS) from a peak concentration of 50 ppm to non-detectable levels. The system has been designed to backwash each mixed media filter vessel up to once a day. The filtration system will accept and effectively treat variable TSS influent concentrations. PCBs and mercury are strongly associated with the suspended solids and will be substantially removed in conjunction with the suspended solids. Any remaining dissolved-phase PCBs will be removed by the activated carbon. The activated carbon may also have an affinity for mercury and BOD as well. The activated carbon vessels will be arranged in series with half of the vessels serving as primary and the other half as secondary so that any breakthrough of PCBs or other monitored contaminants can be detected during routine sampling at the midpoint between carbon vessels. Change-out of the primary carbon vessels will be initiated when breakthrough is detected at the mid-point. Once changed out, these vessels will become the new secondary vessels while the old secondary vessels are placed in the primary position.

1.8 Staffing and Training

1.8.1 Staffing

The WTP which is adjacent to the SDDP will be staffed by Operators who are certified under the requirements of WDNR Chapter NR 114 of the Wisconsin Administrative Code. These requirements are not applicable to the SDDP. Boskalis also plans to work with a team of Operators from Miron Construction Company.

16 9/11/09

Staffing at the SDDP will initially be approximately 16 hours per day (2 shifts), five days per week. Following the first few weeks of operation, it is anticipated that staffing levels will be increased to 24 hours per day. Emergency or back-up personnel will be available as required to support repair or complex maintenance activities. Technical support and alternate Operators will be provided by Boskalis for operational or equipment problems of a technical nature and additional operations support.

A contracted maintenance crew or authorized equipment service representatives will perform repairs of mechanical/electrical equipment which are in excess of the Operator's capabilities.

1.8.2 Training

The Operator will participate in a fleld training program provided by Boskalis and selected equipment manufacturer representatives. The training will address equipment operation, maintenance, equipment, safety requirements and troubleshooting and other subjects required to properly operate the SDDP including regular communication with the Site management, the dredging operation, and the WTP.

In order to keep the plant running as designed, the Operator will have to communicate regularly with the Boskalis SDDP Plant Manager and the Boskalis Process Engineer. The Boskahs Process Engineer will maintain regular contact with the dredging operations being conducted by Brennan so that the anticipated sediment properties from areas targeted for dredging on any given day can be evaluated and plant set points can be adjusted as required.

1.9 Supporting Documentation

The following supporting documents and manual have been used as technical references for this Operations and Maintenance Manual:

1. 100 Percent Design Report Volume 1, April, 2009, by Tetra Tech EC et al. 2. Final Process Design Basis Technical Memorandum for Sediment Desanding and

Dewatering System and Water Treatment System April 17, 2009, by Tetra Tech EC 3. O&M Manuals, Appendix D (Manufacturers' Operation & Maintenance Manuals),

17 9/11/09

2.0 REGULATORY COMPLIANCE

This section of the O&M Plan identifles the Federal, State and local regulations that are applicable to the operation of the SDDP. The applicable regulations have been summarized relative to the following activities:

• Beneficial Reuse of Separated Sand • Storage, Transportation and Disposal of TSCA and non-TSCA PCB Wastes

The specific regulations are identified below. The agency names, addresses and telephone numbers are provided for reference.

2.1 Beneficial Reuse of Separated Sand

Under the requirements of the Wisconsin Department of Natural Resources Administrative Code, beneficial reuse is defined as the reuse of dredge material (or some portion of it) as a resource instead of disposing of it as a solid waste. This involves using the dredge material in a productive manner, such as habitat creation or restoration, landscaping, soil/material enhancement, construction fill, or land reclamation. The benefits can be derived from the dredge material itself or from the placement of it on a site. By definition, beneficial reuse does not include disposal into a landfill or other permitted facility such that disposal capacity is used by the material. In order to meet the definition of beneficial reuse, the material has to have some benefit for construction or operation, or allowing for facility expansion.

Dredged material can have significant value when it is applied for beneficial reuse. These benefits can be realized through proper planning and coordination between the parties involved, including regulatory agencies, potential users of sand, and other interested stakeholders. Selecting the most appropriate beneficial reuse alternative for the sand requires an evaluation of the physical and chemical characteristics of the material, defining how the material can be safely used, and understanding how the interests of various stakeholders can be integrated into the project. The Agencies have determined that sediment characterized as in-situ TSCA will always be considered TSCA. Therefore, sand separated in the SDDP from sediment characterized as in-situ TSCA will have to be disposed of as TSCA waste. The Agencies have agreed that sand separated in the SDDP from sediment characterized as in-situ non-TSCA can be beneficially reused provided it meets the criteria provided by or otherwise agreed to by the Agencies. Beneficial reuse of the sand on the former Shell property as backfill behind the bulkhead wall is subject to CERCLA and the application of the substantive requirements of the Wisconsin Low Hazard Exemption regulations, but not the formal approval process. The CERCLA exemption from State permits or approvals does not extend to areas beyond the actual onsite remedial activites on or adjacent to the Fox River and does not include the State approved landfill(s) receiving the remediation wastes.

At present, it is anticipated that approximately 350,000 to 700,000 tons of sand may be generated through the dredging, desanding, and dewatering process. Desanding and beneficial use volume estimates will continue to be refined throughout the project.

Initial suitability criteria for beneficial reuse of the sand separated from the dredged material under Wisconsin Statute 289.43 and Wisconsin Department of Natural Resources (WDNR) Administrative Code requirements under Chapter NR 538 (beneficial use of industrial byproducts) are described below.

9/11/09

2.1.1 Beneficial Reuse Suitabilitv Criteria

The suitability of separated sand for beneficial reuse will be evaluated on a case-by-case basis using the guidance and criteria below.

Dredged material is regulated as solid waste in Wisconsin. WDNR approval of the beneficial use of separated sand from sediment characterized as in-situ non-TSCA under a Wisconsin Statue 289.43 low hazard exemption (LHE) has been requested.

Initial suitability of material for beneficial reuse for off-site uses will be determined by the PCB concentration thresholds in the separated sand, as described in Table 2-1.

Table 2-1 Initial Suitability Criteria for Beneficial Reuse

Sand <• PCB Concentration Action'to be taken PCB > 1 0 ppm Need to determine reuse potential PCB < 1 .Oppm PCB > 0.25 ppm

PCB < 0.25 ppm PCB < 0.05ppm

Can be used for beneficial reuse Requires capping or covering Does not require capping or covering Unrestricted reuse

Beneficial reuse suitability requirements that pertain to off-site uses include: Any proposed beneficial reuse alternative for the sand would be in a non-residential setting, thereby minimizing direct contact. Any proposed beneficial reuse project would need to meet the NR 500 performance standards of not causing an adverse effect on wetlands, surface water, groundwater, or endangered/threatened species. No other chemical parameters are present at levels of concem, and physical parameters are defined. These parameters are an abbreviated list of NR 347 parameters (see Table 2-2). The contaminant concentration in NR 538 will be used as a guideline for deciding if this sand would need to be covered, and if so, whether it would require covering with clean soil or some sort of capping soil. Sand with PCB concentrations greater than 0.25 ppm would require some sort of capping or covering. Sand with PCB concentrations of less than 0.25 ppm would generally not require any sort of capping. Sand with PCB concentrations less than 0.05 mg/kg, or less than the level of detection (with a level of detection of less than 0.05 ppm), would be considered clean relative to PCBs and available for relatively unrestricted use, assuming no other parameters were present at levels of concem.

The sand separation study completed in early 2009 included a sand separation/washing process followed by analysis of the sand fraction for the constituents and the geotechnical properties listed in Table 2-2. The results of this study are presented in Appendix B to the Phase 2B Work Plan for 2009 RA (Tetra Tech EC et al., 2009). However, analysis of fiall-scale production sand separated from non-TSCA sediment will be required and will be used for the flnal acceptability determination of the various beneficial use options.

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All of the sand separated from non-TSCA sediment in 2009, 2010 and likely some from 2011 is intended to be used as backfill behind the proposed bulkhead wall, provided it meets the approved beneficial reuse criteria. It was originally estimated that 30,000 to 60,000 cubic yards of sand would be produced each year in 2009 and 2010 assuming an average of 30 to 40 percent sand removal by weight and an in-situ dredge production rate of approximately 150 in situ cubic yards per hour. However, through August 2009 only about 12,000 to 15,000 CY of separated sand has been produced. An estimated 55,000 cubic yards of sand will be needed to fill the bulkhead wall to elevation 577 feet NAVD88 in 2010, and an estimated 54,000 cubic yards of sand or other suitable fill material is needed to fill the bulkhead wall to approximately elevation 590 in 2010 and most likely 2011.

After the bulkhead wall area is filled to elevation 577 feet NAVD88 at the end of 2010, or perhaps early 2011, a wick drain system will be installed to aid in consolidation of the underlying low-strength soils. The consolidation water released from the organic silt and clay layers will be collected in the drainage layer of the wick drain system and routed to 12 extraction sumps using a piping network. The proposed piping network and sump locations are shown on STS/AECOM Drawing No. 11 of 13 - Wick Drainage Blanket Plan, submitted to the A/OT (under separate cover) as part of the Open Cell Bulkhead Wall Installation Work Plan in March 2009 (J.F. Brennan et al. 2009). Water will be pumped from the sumps into a nearby holding tank for temporary storage before being periodically hauled or pumped to the overflow tank in the SDDP. The water will then initially be processed through the WTP, but if repeated sampling indicates the water is clean (i.e., it meets the WTP effluent performance standards), Tetra Tech will propose discharging the water directly to the Fox River.

Based on the revised dredge plans developed for the bulkhead wall area, the post-dredge surface is expected to have a maximum average concentration of 1.0 ppm PCB in the undisturbed residuals (6 to 12 inches below the post-dredge surface) and a maximum average concentration of less than 10 ppm in the generated residuals (0 to 6 inches below the post-dredge surface). The Agencies have determined that if generated residuals average less than 10 ppm PCB and undisturbed residuals and separated sand used as backfill average 1 ppm or lower PCB concentration (and a maximum of 5 ppm in any single or composite sample), the site will not be subject to long-term monitoring or institutional control requirements, so long as there are no other limiting parameters. The landowner agrees with this plan.

The sand will be tested as it is separated, prior to any placement or possible mixing with other sand. The frequency of testing will be as described in Table 2-2, although additional testing may be performed initially to gain an understanding of expected results.

Composite samples are collected directly from the sand slab stockpiles for fine and coarse sand (and filter cake, when it is sampled). The sample collection process will comply with ASTM D-75. A front end loader will be used to dig into the stockpile in a number of places, typically three to five (depending on the size of the stockpile), and then this material will be spread out away from the stockpile. To create a composite sample, a shovel size aliquot of material will be collected from each one of these small piles created by the loader. This process helps in the collection of a sample that is more representative of the material in the entire stockpile by reducing segregation.

An immunoassay PCB test kit, obtained from Strategic Diagnostics Inc., may be used for measuring total PCB levels in separated sand and filter cake onsite. This kit is primarily used to measure PCB levels in the separated sand, for onsite management purposes. Initial reliance will be on the results of analyses performed by Pace, to determine whether sand can be moved off of the sand slab, to an onsite staging area. The immunoassay sampling kit may be used at the same time and the results compared with those received from Pace. After a period of time, if there is a favorable correlation, the immunoassay test kit

20 9/11/09

alone may be used for this purpose if WDNR agrees. Refer to SOP-005 of the QAPP, which contains the manufacturer's instructions on use of the immunoassay PCB test kit.

21 9/11/09

Table 2-2 Separated Sand Testing Requirements for Beneficial Reuse Suitability

Beneficial' '̂ Reuse-L Criteria/Giiidance' -

Chemical Parameters Total PCBs

Total 2,3,7,8 TCDD Total 2,3,7,8 TCDF DDT Arsenic

Barium Cadmium

Chromium

Copper

Cyanide Iron Lead

Manganese Mercury

Nickel

Selenium Zinc

Physical Parameters Grain-Size

Percent Solids Total Organic Content Moisture Content Settleability

^Test Method -

Fox River Method

EPA 6000/7000

EPA 6000/7000 EPA 6000/7000 EPA 6000/7000

EPA 6000/7000

EPA 6000/7000 EPA 6000/7000

EPA 6000/7000

Sieve and Hydrometer

ASTMD2974 ASTMD2216 If required

s.Test Fret|uency«,v "Z-̂ "̂ - V<^' ^ ^ - ^

One sample/1,000 cy for the first 10,000 cy then One sample/10,000 cy for 10,000 to 50,000 cy then One sample/50,000 cy thereafter

Acceptable Range,,-

IBD for all parameters *

* Determined by uses approved by WDNR

2.1.2 Desanding and Rewashing Technologies

Dredged material will be screened to remove debris, and then screened to separate the sand fraction from PCB-contaminated sediment fractions. The use of coarse- and fine-grained sand separation before dewatering is important to reduce the amount of equipment wear on the filter presses and also has the

22 9/11/09

potential to provide material for suitable reuse, thereby reducing disposal weight and costs. The remaining slurry consisting of PCB-contaminated sediment fractions (finer than No. 230 sieve) material will be pumped to the dewatering facility for further processing. The resultant sand fraction from non-TSCA sediment is the material slated for beneficial reuse.

2.2 Storage, Transportation and Disposal of TSCA and non-TSCA PCB Wastes

The dredged materials will be desanded and dewatered in the SDDP. Excess moisture will be removed during this process and the desanded and dewatered sediment will be disposed of as a filter cake at a non-TSCA or TSCA landfill, as appropriate based on the in-situ sediment characterization. Non-TSCA sand obtained from the desanding process will be used for beneficial reuse provided it meets the regulatory requirements described in Section 2.1.

The SDDP will operate 5 days per week, 24 hours per day for approximately 7 months per year (typically April 15 through November 15). Trucks are assumed to carry 20 tons per load in accordance with WDOT regulations.

The dredging and subsequent process treatment is expected to generate the following amounts of material shown in Table 2-3.

Table 2-3 Estimated Daily Sediment Desanding and Dewatering Production

Average Sand Production Average Filter Cake Production Peak Sand Production Peak Filter Cake Production Total Average Output Total Peak Output

^Pirolluction Based on Average Sediment Composition ^ - " 26 shon tons/hr or 624 tons/day 80 tons/hr or 1,920 tons/day 38 tons/hr or 912 tons/day 117 tons/hr or 2,808 tons/day 2,544 tons/day 3,720 tons/day

Average Truck Loads Per' D a y ' ..-^v-Y

(20 tons per load) 31 loads per day 96 loads per day 46 loads per day 141 loads per day 127 loads per day 186 loads per day

4.

Total outputs include output of sand plus filter cake and are shown are on a "per day" basis "Average" output is estimated based on an average sediment properties (density, percent solids) and the average production rate of 150 in situ cy per hour. Average output also assumes 35 percent sand removal by weight. "Peak" output is estimated based on the same sediment properties and the maximum sustained dredge production rate of 220 in situ cy per hour. Peak output also assumes 35 percent sand removal by weight. The sediment dewatering plant and associated storage (2 days of storage capacity for filter cake under roof) have the ability to even out peaks and valleys in sediment flow rate, to some extent, and minimize swings in filter cake production. The number of trucks can be increased or decreased through communication with the subcontractor. Details are provided in the Transportation Plan in Appendix A, Attachment A-12 of the 100 Percent Design Report, Volume 1. Tons reported above are wet short tons with an assumed water content of 15 percent.

Based on the estimated sand and filter cake production rates shown on Table 2-3, approximately 250,000 ± 40,000 tons of non-TSCA filter cake will require disposal in 2009, assuming an average sand removal rate of 35 percent by weight and dredging of approximately 460,000 in situ cubic yards of non-TSCA sediment. The filter cake after leaving the presses will be conveyed to the sediment processing building, where it will be stockpiled to await loading onto disposal trucks. The material will be loaded onto the trucks with a wheeled loader. Loading of trucks will take place from approximately 6:00 a.m. to 3:30 p.m. each day to accommodate the disposal facility's schedule of 6:30 a.m. to approximately 4:30 p.m., Monday through Friday, for disposal activities. If necessary, after hours loading of trucks may be performed to facilitate transport early in the following day. The number of trucks scheduled will be increased or decreased, as needed, based on anticipated increases or decreases in production. All trucks

23 9/11/09

going offsite will be weighed at the certified truck scales inside the building. The Final Lower Fox River OU 2 - 5 Remedial Action Transportation Plan (Transportation Plan, Tetra Tech and STS/AECOM, September 2008), containing detailed information regarding traffic routes and volumes, waste staging and loading, waste transporter requirements, traffic control procedures, and other pertinent information on project-related traffic has been submitted to the Agency/Oversight Team and approved.

The Transportation Plan, includes additional detailed information regarding the movement of trucks hauling waste and other materials out of and/or into the material staging and dewatering facility located at the former Shell property. This information includes decontamination procedures for trucks that are loaded with filter cake and ready to leave the facility. Dedicated trucks will haul sand to be used beneficially as backfill behind the bulkhead wall. Since only about 26 wet tons of sand are estimated to be produced per hour (based on the assumptions stated for Table 2-3), only one dedicated truck will be needed to haul sand from the sand storage pad to the bulkhead wall. Initially, this truck will move sand from the storage area to a stockpile area on the bank, after analytical results confirm the material meets the approved criteria for beneficial re-use behind the bulkhead wall. This stockpile will remain in place until dredging is deemed complete in the bulkhead wall area. At that time, the sand will be placed behind the wall, and future loads will be dumped directly behind the wall. This traffic is also discussed in the Transportation Plan.

For haulers transporting DOT-regulated shipments of PCB-contaminated sediments or debris (i.e., loads containing equal to or more than 1 pound of PCBs), Tetra Tech required the transporters to confirm their company has prepared a DOT Hazardous Materials Security Plan.

Coarse and fine sand separated from the dredge slurry may be stockpiled outside the sediment processing building, on a concrete-lined and curbed sand storage slab and segregated using movable concrete Jersey barriers, while awaiting characterization. Based on the sampling performed to date, it appears that there may be as much as twice the amount of fine sand as coarse sand. Coarse sand will be accumulated in a single pile while the fine sand may be separated into two piles. Sand placement on the slab will be accomplished using the conveyors purchased for this purpose. The Storm Water Pollution Prevention Plan (SWPPP) includes best management practices for control of surface water from these storage areas. The non-TSCA material may be reused provided it satisfies regulatory requirements. Stormwater runoff from the sand storage stockpiles will be initially characterized and appropriately managed in accordance with the SWPPP.

When dredging operations and dredged material treatment are initiated in May 2009, two types of waste will be generated; non-TSCA and TSCA wastes, and these two types of wastes will be kept and managed separate from each other. This section summarizes the current estimates of the amounts of non-TSCA and TSCA wastes that are expected to be generated and the status of landfill selection for the disposal of non-TSCA and TSCA wastes for OUs 2 to 5.

The in-water survey work performed in 2008, as detailed in the Phase 2A Site Surveys Report, included collection of additional data to update the debris information collected during previous RD surveys. Large debris identified within 2009 dredge areas during the in-water surveying is being removed using mechanical equipment prior to dredging a specific dredge area, unless otherwise approved by the Response Agencies. This includes debris identified adjacent to the former Shell property and in OU 2. Such debris is being transported to the former Shell property for processing, and subsequently to the appropriate off-site disposal or recycling facility. The Phase 2B Work Plan for 2009 RA describes procedures for leaving relatively large debris, such as boulders, in place, should such materials be encountered.

24 9/11/09

Debris not removed in a pre-dredge mechanical removal event is to be removed by the hydraulic dredge and entrained in the dredge slurry. Debris in the sediment slurry will be screened out when the sediment slurry passes through a vibrating screen (for hydraulically dredged material). Debris in mechanically dredged sediment will be removed by passing the material through a screening drum and then through a vibrating screen.

Debris should be segregated into porous and non-porous fractions. Porous debris from non-TSCA dredge areas will be disposed of as non-TSCA waste and porous debris from TSCA dredge areas will be disposed of as TSCA waste. If feasible, non-porous debris from dredge areas designated as "TSCA" may be decontaminated in accordance with Section 02 81 00 of the Project Plan in Appendix C, Attachment C-0. Non-porous materials with surface PCB concentrations of less than 100 micrograms (|ig) per 100 square centimeters based on wipe sampling of surfaces after decontamination may be disposed as non-TSCA waste, subject to Response Agency approval. Non-porous materials with surface PCB concentrations of 10 ng per 100 square centimeters or less based on wipe sampling of surfaces after decontamination may be released for unrestricted use and will be recycled, subject to Response Agency approval. The standard wipe test per 40 CFR 761.79 and 761.123 will be used. The majority of the nonporous debris is expected to be disposed as non-TSCA waste or to be recycled. Debris larger than 1 cy will be resized as required by the non-TSCA and TSCA landfill disposal contracts. Debris and recyclable materials will be staged and containerized in designated areas at the former Shell property prior to shipment off-site for disposal or recycling.

Flow charts of the general process to be used for characterizing non-TSCA and TSCA material and debris dredged in 2009 for disposal and beneficial reuse purposes are presented in Figures 2-1 and 2-2, respectively.

2.2.1 TSCA Wastes and TSCA Landfill

TSCA wastes will be disposed of at a landfill permitted for this type of waste. Currently, disposal of the TSCA filter cake is anticipated to be at the EQ Wayne Disposal Inc. [(313) 480-8085] landfill located in Belleville, Michigan.

This section summarizes the estimated extent and volume of sediments that would be subject to TSCA regulation when removed and disposed. As discussed in the Agency-approved Addendum No. 3 to the Pre-Design Sampling Plan (Shaw and Anchor 2005), when targeting the removal of subsurface (buried) sediments with PCB concentrations greater than 50 ppm using the 8-inch to 12-inch-diameter hydraulic cutterhead dredge equipment anticipated for the project, on average, a 2.5 feet total thickness is the most practicable amount of sediment that can be removed efficiently. Thus, for the purpose of characterizing dredged material for beneficial use or disposal purposes based on in situ sediment PCB concentrations in the 100 Percent Design Report, 6-inch sample depth data were averaged across non-overlapping 2.5-foot (30-inch) sediment intervals beginning at the mudline. For example, if the 2.5-foot vertically averaged sediment concentration exceeds 50 ppm, neatline and associated sediments (including over-dredge

25 9/11/09

allowances) dredged from this depth would be subject to TSCA disposal requirements. This relatively straightforward designation procedure uses detailed sediment sampling data to consistently designate sediments potentially subject to TSCA disposal requirements that result from successive cuts using the equipment planned for use in OU 4 (12-inch hydraulic dredges).

Using this designation procedure, approximately 10,000 cy of the 470,000 cy of in situ sediment targeted to be dredged in 2009 will require disposal in a TSCA-licensed landfill following desanding and dewatering. All OUs 2 to 5 sediments potentially subject to TSCA disposal requirements are in OU 4. No sediments requiring disposal in a TSCA-licensed landfill have been identified in OUs 2 or 3 based on the delineation method described in the Agency-approved Addendum No. 3 to the Pre-Design Sampling Plan and summarized herein.

While on the former Shell property, these materials will be stored in accordance with TSCA storage requirements within the sediment processing building. Given the distance to potential TSCA disposal facilities, some on-site storage of TSCA wastes will likely be necessary at the former Shell property staging area; however, this is not anticipated to exceed 30 days, and trucking will continue at the end of each dredging season after dredging and processing have been completed until all wastes have been removed. It is currently estimated, based on sediment sampling, that up to 265 trucks (at 20 tons per truck) of TSCA filter cake wastes will require disposal in 2009.

26 9/11/09

Non-TSCA • Dredge Material

and Debris

Washing of non-Porous Debris and Coarse Materials

> 3 m m

Segregation of Debris And Coarse Material

(>3mm)

Wipe Sampling

< lO^ig/lOOcm*

Resizing as Necessaiv for

Recycling

I >I0 lOiig/lOOcm* PCBs

Resizing as Necessafy for

Disposal

Screening and Dewatering of Sand

Desanding of Dredge Material

<3min

Coarse Sand (150 t i in to<3n im)

LL Fine Sand

(63nmto<150nin)

Conflmtation Sampling and

Testing of Coane Sand

Transport to Recycling

Facility

Transport and Disposal at Non-TSCA

Landfl]]

i Meets Beneficial

j Reuse Criteria JAnd WDNR has i Granted an ! Exemption

I Transport I Coarse Sand to j Beneficial 1 Reuse Site

Does Not Meet Criteria - Initial

Testing

Confirmation Sampling and

Testing of Fine Sand


Testing

Rewashing and/or

Addition or Additives

Does Not Meet Criteria - 2'^

Round Testing

Pre-Thiclcening p j And Dewatering H I I of Fines I I

Additional Characterization As Required for Waste Profiling

Meets Beneficial

Reuse Criteria And Agency has Granted a Low

Hazard Exemption

Decant Water To Water

Treatment Plant

Transport and Disposal of

Filter Cake at Hickory

Meadows Undfill

Evaluate Potential Additional Treatment or Dispose of Sand at Hickory Meadows Landfill

Transport Fine Sand to

Beneficial Reuse Site

l b TETRATECH O^ ANCHOR VWF iMvinsaMtMT'i ,L L c .

Figure 2-1 2009 Non-TSCA Dredge Material and Debris Characterization Process

Lower Fox River - OUs 2 to 5

Seotember 2009

TSCA Dredge Material and

Debris

Washing of Non-Porous { Debris and Coarse Material > 3 mm

Porous Debris

Wipe Sampling

< lOOiig/lOOi PCBs

)cm' [ [~>100| lOOng/lOOcm' PCBs

Resizing as Necessary for

Disposal

Resizing as Necessary for

Disposal

Segregation of Debris And Coarse Material

(>3mm)

Screening and Dewatering of Sand

Desanding of Dredge Material

<3mm

Coarse Sand (150nmto<3mm)

Fine Sand { (63)imto'<lS0|im)|

Pre-Thickening And Dewatering

of Fines

Confinnational Sampling and


Transport and Disposal at non-TSCA Landfill* i

Transport and Disposal at

TSCA Landfill

Meets Beneficial

Reuse Criteria and Agency has Granted a Low

Hazard Exemption**

**Also subject to EPA approval in accordance with 40 CFR 761.61 (c).


Testing

Confirm ational Sampling and



Testing

Rewashing and/or

Addition or Additives

Does Not Meet Criteria - 2"^ Round Testing

Decant Water To Water

Treatment Plant

\L Additional

Characterization As Required for Waste Profiling

i Meets I Beneficial I Reuse Criteria I And Agency has { Granted a Low I Hazard i Exemption **

Transport and Disposal of Filter

Cake at TSCA Landfill

Evaluate Potential Additional Treatment or Dispose of Sand at Landfill

TETRATECH i / ANCHOR VkM."? E M V i a O H H I N T f t L . l . t . C .

Figure 2-2 2009 TSCA Dredge Material and Debris Characterization Process

Lower Fox River- OUs 2 to 5

Seotember 2009

2.2.2 Non-TSCA Wastes and Non-TSCA Landfill

Non-TSCA PCB wastes, including filter cake and river debris with less than 50 ppm of PCBs will be disposed of at a permitted non-TSCA landfill. Much of the sand segregated from the dredge slurry is expected to be suitable for beneficial reuse and therefore will not require landfill disposal. Sand that is not suitable for beneficial reuse, along with gravel and other minor debris, will need to be disposed at the Veolia Hickory Meadows Landfill.

The Veolia Hickory Meadows Landfill near Hilbert, Wisconsin has been selected as the non-TSCA landfill for the OUs 2 to 5 project. Hickory Meadows is a non-TSCA PCB sediment disposal and Subtitle D facility. It is approximately 34 miles away from the treatment facility, and the materials will be transported by truck.

Based on Boskalis Dolman sampling data and mass balances, dredging and processing roughly 484,000 cy of non-TSCA sediments will produce approximately 250,000 ± 40,000 tons of filter cake (± one standard deviation; based on bench-scale testing of six composite samples, and assuming a final solids content of the filter cake of approximately 50 percent). As discussed above in Section 1.7.1, additional field sampling, bench-scale testing, and pilot testing was performed in 2008 as part of Phase 2A RA activities to refine estimated production quantities and optimal operating parameters.

USEPA and WDNR have determined that sediments designated for non-TSCA disposal using the in situ methodology (i.e., interval average PCB concentrations less than 50 ppm) meet the substantive requirements for PCB testing for receiving landfill facilities, obviating the need for fiirther PCB verification testing. The Agencies have determined that the in-situ data and non-TSCA determination will meet the disposal requirements for characterization of the dredged sediment for the Veolia Hickory Meadows landfill facility, which has been selected as the non-TSCA disposal facility. The Agencies have further determined that it is acceptable to provide annual in-situ characteristics of the non-TSCA sediment that will be disposed of at the landfill that year to satisfy the characterization requirement for the landfill. The landfill also requires testing for strength properties as part of the waste acceptance criteria and this testing will be performed prior to disposal in order to meet contract requirements.

Non-TSCA material will be tested per the waste acceptance criteria in Hickory Meadows' disposal contract with the Respondents. Additional testing of the filter cake, such as grain size, consolidation, Atterberg limits, etc., will be performed if required, but is not part of the waste acceptance criteria. Use of the Hickory Meadows landfill has been approved by the WDNR and a contract has been executed by the Fox River Remediation LLC on behalf of the Respondents. The potential requirements are listed in Table 2-4.

29 9/11/09

Table 2-4 Hickory Meadows (non-TSCA) Landfill Acceptance Criteria

i i ^ i l S i l i i ^ f i l l Cnteria --• ' In-situ sediment characterization as non-TSCA based on core averaging procedure approved for the Lower Fox River

Ability to support its own weight

Ability to support the over burden weight of material placed over it Passes paint filter test Minimum cohesive strength of 800 psf, or minimum fiictional strength of 25 degrees, or a combined cohesive and fiictional strength that provides an equivalent factor of safety for slope stability'

Test Method. - " - • . ' - ' "'" Based on m-situ determmation and averaging of non-overlapping 2.5-foot intervals fi-om sediment cores (Shaw and Anchor 2005) Field observation by the low ground pressure dozer operator Field observation by the low ground pressure dozer operator SW846 Method 9095A ASTM D 6528-07, ASTM D 4648-05, ASTM D 4767-04, or ASTM D 2166-06

Test Frequency > N/A

For each load delivered to the disposal facility For each load delivered to the disposal facility As required One sample every 10,000 cy for first 30,000 cy and one sample every 30,000 cy thereafter to represent each of the areas dredged

Notes: 1

ASTM cy ppm psf

The equivalent factor of safety for slope stability is as described in the Plan of Operation for the Hickory Meadows landfill. American Society for Testing and Materials cubic yard part per million

pound per square foot

Agency Contacts Information:

• NR 157 - WDNR Management of PCBs, NR 500 series codes

Wisconsin Department of Natural Resources

Mr. Jim Zellmer Northeast Region Headquarters 2984 Shawano Avenue Green Bay, WI 54313 (920)662-5431

• 40 CFR 761 - Regulations for Polychlorinated Biphenyls under the Toxic Substances Control Act (if identified as a TSCA waste)

U.S. Environmental Protection Agency Region 5 Mr.Tony Martig, Regional PCB Contact

77 West Jackson Boulevard, Chicago,IL 60604

(312)353-2291

30 9/11/09

or o Disposal of Remediation Waste containing Polychlorinated Biphenyls

U.S. Environmental Protection Agency Headquarters Ms. Molly Finn, Office of Solid Waste Ariel Rios Building 1200 Pennsylvania Avenue NW Washington, D.C. 20460 (703) 347-8785

• 49 CFR 100-180 - Transportation

U.S.Department of Transportation Pipeline and Hazardous Materials Safety Administration Central Region Office 2300 East Devon Avenue, Suite 478 Des Plaines,n. 60018 (847) 294-8580

or

U.S.Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2"'' floor 1200 New Jersey Avenue, SE Washington, D.C. 20590 (202) 366-0656

or

DOT Hazardous Materials hiformation Center: (800) 467-4922

31 9/11/09

3.0 RECORDS MANAGEMENT

3.1 Introduction

A comprehensive Records Management Program is essential to the efficient operation of the SDDP. Information relative to: facility usage, equipment preventative maintenance, sampling analysis and monitoring, process control monitoring, bench scale test results, chemical usage, personnel management, etc. must be collected by the Plant Operator and reported upon to meet regulatory and client requirements. This Section briefly summarizes the recommended records management program for the Lower Fox River Site Sediment Desanding and Dewatering Plant.

In accordance with the requirements of the client contract and the requirements of the AOC, a bound operation and maintenance log and an electronic log is to be maintained by the Operator on-site, to include all collected records and events as described in this Section.

3.2 Process Control Recording

Process control recording is to be completed by the Operator on a daily basis. It is divided into two categories: 1) process monitoring via the Computer Monitoring and Control System (CMCS) and 2) equipment operation monitoring via manual/visual inspections.

3.2.1 Process Monitoring

Process control data will be transmitted from the instrumentation to the CMCS system. The Operator will download selected process control data into a daily report. Tables 3-1 and 3-2, CMCS Monitoring, include a listing of systems that are to be monitored by the CMCS.

The process monitoring reports will include at a minimum the following information:

Total daily flow and average daily flow rate of dredged material slurry from the 8-inch diameter and 12-inch diameter HDPE hydraulic dredge pipelines (from CMCS);

Density of dredged material slurry from the 8-inch diameter and 12-inch diameter HDPE hydraulic dredge pipelines (from CMCS);

Total daily flow and average daily flow rate through each treatment unit (from CMCS);

Total daily tormage of debris/coarse fraction separated from influent dredged material slurry (from CMCS and Operator records);

Total daily tonnage of coarse sand separated from influent dredged material slurry from each treatment train (from CMCS);

Total daily tonnage of fine sand separated from influent dredged material slurry from each treatment train (from CMCS);

Average daily flow rate of wastewater pumped to the WTP (from CMCS);

32 9/11/09

• Total suspended solids concentration of wastewater pumped to the WTP (from laboratory analysis);

• Total daily tonnage of filter-cake produced from each filter press (from CMCS);

• Total daily amounts of coagulant and cationic polymer used (from CMCS and Operator records);

• Daily recording of maintenance and repairs made to equipment (from Operator records); and

• Daily recording of instrument alarms and process control system upsets (from CMCS).

This information will be made available through summarized spreadsheets via the CMCS software program.

During 2009, the operation of the various subsystems of the SDDP will be monitored and the data collected will be utilized to conduct value engineering studies in order to determine how the SDDP process can be optimized and/or modified to improve the efficiency and reduce operating costs. Depending on the results of these studies, the operation of the SDDP is anticipated to be modified for 2010 and later years.

NOTE: Tables 3-1 and 3-2 contain confidential business information that is the intellectual property of Boskalis Dolman BV and Stuyvesant Dredsins Inc. fSDI). Therefore, they are only available for review purposes to those parties that have obtained written permission from SDI and have signed the required Confidentiality Asreement and have agreed to be bound by this aereement. Tables 3-1 and 3-2 will be removed from any document that is made available to parties that have not obtained the required permission from SDI and blank pases will be substituted.

Table 3-1 CMCS Monitoring - Digital Signals

Table 3-2 CMCS Monitoring - Analog Signals

33 9/11/09

3.2.2 Equipment Operation Monitoring

Reports will be generated to document regular equipment inspections and operational parameters, including the following:

• Visual inspection of all piping, valves, fixtures, pumps and tanks to check for leaks or visible signs of wear;

• Visual inspection of sediment slurry, sand, polymer, filter cake, process water and wastewater flow throughout system via designated sight tubes within the system; and

Specific preventative maintenance on the equipment is described in Section 9.0, Equipment Maintenance of the Manual.

3.3 Laboratory Data

Laboratory results from the SDDP process and waste sampling will be summarized in the quarterly status and monitoring reports to be prepared by Tetra Tech.

Prior to and periodically during SDDP system operations, bench scale testing of the influent streams to the pre-thickener tanks and to the membrane filter presses is proposed to be performed to determine polymer dosage rates.

3.4 Inventory Monitoring and Recording

It is recommended that the Operator monitor and record all equipment used during regular treatment system operations on at least a weekly basis and make an inventory. This includes process equipment and chemicals (polymer and coagulant), as well as, building maintenance supplies/equipment. Reference is also made to the "Tools and Equipment List" found in Appendix B, Tools and Equipment, and the "Spare Parts Inventory " located in Appendix C, Spare Parts.

Chemical usage is to be recorded for all process chemicals consumed during operations.

3.5 Personnel Management

On-site personnel management is an important part of the efficient operation and maintenance of the SDDP. Location of on-site personnel is essential in order to meet site health and safety protocol.

Personnel management includes records of time on-site for the Operator, as well as, visitors and security personnel. Operators are to prepare daily logs for inclusion in weekly employer timesheets.

34 9/11/09

4.0 SAMPLING AND ANALYSIS PLAN DESCRIPTION

4.1 Purpose

The purpose of this sampling and analysis plan (SAP) section is to describe data acquisition procedures, numbers and types of samples, methods of analysis, and quality control measures associated with data collection and analysis for the SDDP. The detailed definition of quality assurance (QA) and quality control (QC) for all sampling related project activities to be implemented at the Lower Fox River Site is covered in a separate document, the Quality Assurance Project Plan (QAPP), which ensures the integrity of the work to be performed at the Site and ensures that the data collected will be of the appropriate type and quality needed for their intended use. This SAP is intended to be a procedural guide for all Tetra Tech team personnel and subcontractors (Boskalis and Andritz) involved in sampling and analysis and data acquisition while implementing remedial actions for the Lower Fox River Site OUs 2 to 5.

4.2 Sampling and Analysis Data Objectives

This section gives an overview of sampling and analysis activities and their data objectives. Sampling and analysis activities for the SDDP consist of: 1) process monitoring and sampling; and, 2) monitoring and characterization of the product/waste streams (separated sand, filter cake, and process wastewater) from the SDDP for waste disposal, treatment and/or beneficial reuse.

4.2.1 Generalized Scope of Work

Process monitoring and sampling and product/waste stream characterization activities for this project will include the following:

• Sampling and monitoring of intermediate process streams within the SDDP for the purpose of evaluating the operation and performance of the process equipment used for screening, coarse sand separation, fine sand separation, pre-thickening, and dewatering.

• Sampling and monitoring of the SDDP performance during the start-up period in 2009 in order to ensure that the system is operating properly and that product/waste streams meet all regulatory, beneficial reuse, and disposal facility requirements.

• Sampling and monitoring of the SDDP during the prove-out period in 2009 in order to ensure that the system is operating in accordance with the design specifications and meets all regulatory, beneficial reuse, and disposal facility requirements.

• Sampling and analysis of SDDP process influent, intermediate, and product/waste streams for the purpose of conducting value engineering studies in order to optimize the operations and determine ways to improve the efficiency and reduce operating costs.

Other activities include sampling and analysis for health and safety related monitoring of the indoor air within the SDDP building. Sampling and analysis requirements for indoor air monitoring are discussed in detail in the Site Health and Safety Plan (SHSP).

35 9/11/09

4.2.2 Data Quality Objectives

Data Quality Objectives (DQOs) are requirements needed to support decisions relative to the various site activities. Sampling procedures and analytical data collected must be of a quality that supports the decision making process and ensures that project objectives are achieved. The sampling and analysis program will ensure that data meet the requirements for precision, accuracy, representativeness, comparability, completeness, and sensitivity defined in the QAPP. Project Quality Objectives and Systematic Planning Process Statements are stated in QAPP Worksheet #11. Measurement Performance Criteria for the various matrices and analyses are stated in QAPP Worksheet #12. The Reference Limits and Evaluation Table for the various matrices and analyses are provided in QAPP Worksheet #15.

Samples will be analyzed in strict accordance with the analytical test methods and procedures in NR 219 utilizing approved USEPA and ASTM methods. Analytical methods will provide results with detection limits sufficiently below designated action levels, and the methods will be accurate enough to quantify contamination at concentrations below action levels. Sample collection will utilize approved techniques that will ensure that the sample is representative of current environmental and operational conditions. QA/QC samples will be collected and analyzed for the purpose of assessing the quality of the sampling effort and of the analytical data. A description and frequency of QA/QC samples to be collected is specified in Section 4.3.2.

Samples for regulatory compliance will be collected by Tetra Tech. Samples for in-process monitoring will be collected by Boskalis. A reduced level of quality will be utilized for the in-process analyses. Neither the compliance nor the in-process monitoring samples will undergo data validation, although the compliance samples results will be verified. Further information on data verification is presented in the QAPP. As shown in Section 4.3.1, sampling for PCBs will not have to be performed for process monitoring samples because decisions will be based on in-situ sediment characterization as directed by the Agencies. Only sand earmarked for placement behind the sheet pile wall or for beneficial reuse will require having samples collected (while on the sand slab) for PCB analyses by an offsite laboratory.

Laboratories providing chemical measurements for the purposes of determining the effectiveness of the remediation must be certified by the State of Wisconsin under NR 149 for solids media and the appropriate analytes and methods, including parameters of interest related to the beneficial reuse of separated sand, and all laboratory methods must meet the reporting limit requirements acceptable to both the USEPA and WDNR. Tetra Tech plans to send samples for a particular analytical parameter only to those laboratories that have been certified by the State of Wisconsin for that parameter. To the extent possible, Tetra Tech plans to utilize local certified laboratories with the samples being delivered to the certified laboratory by a local courier service instead of shipping samples via an overnight delivery service to laboratories that are further away. Only if required during the project (e.g., the chosen laboratory loses its certification for the parameter, etc.) will additional laboratories be utilized for analysis of a particular parameter. Section 2.5.1 of the QAPP provides information on substitution of laboratories. The primary subcontract laboratories are as follows:

• Pace Analytical, Green Bay, Wisconsin (Chemical Analytical Laboratory); • Ann Arbor Technical Services (ATS), Ann Arbor, Michigan (Chemical Analytical Laboratory); • AECOM, Green Bay, Wisconsin (formerly STS Consultants, Physical/Geotechnical

Laboratory); and • TtMM, Wausau, Wisconsin (Physical/Geotechnical Laboratory).

A Project Manager and QA Manager will be assigned by each laboratory to the project, and they will provide technical guidance to the project team, oversee laboratory requirements (including QA/QC

36 9/11/09

requirements) for the project, review laboratory data for compliance with approved planning documents, maintain laboratory documentation, and coordinate corrective action procedures as necessary. The Tetra Tech Field QA/QC Manager, in concert with the Tetra Tech Database Management Specialist, will coordinate with the laboratories on the number and type of analytical samples necessary. The subcontractor laboratory(ies) will be responsible for the delivery of sample bottles (pre-preserved as necessary) to the Site, and subsequent pick-up/shipment and analysis of collected samples. Data packages will be submitted by the subcontractor laboratories directly to the Tetra Tech Team.

4.3 Sampling and Monitoring Program Procedures and Requirements

This section discusses and summarizes the sampling and monitoring activities described in the Scope of Work and summarized in Section 4.2.1, and identifies chemical, physical, and geotechnical sampling requirements for this program.

4.3.1 Sampling and Monitoring Programs

Several sampling and monitoring programs will be conducted as part of the SDDP operations. These include:

1) sampling and monitoring of process streams for routine operations; 2) sampling and monitoring of infiuent and product/waste streams during the start-up period; 3) sampling and monitoring of infiuent and product/waste streams during the prove-out period; and, 4) sampling and analysis for value engineering studies.

These sampling and monitoring programs are identified below. QA/QC samples will be collected as identified in Section 4.3.2. All procedures for decontamination of equipment, identification, labeling, chain-of-custody, packing, and transportation will be followed as identified in Section 4.3.3 and 4.3.4.

4.3.1.1 Sampling and Monitoring for Routine Operations

In order to keep the plant rurming as designed, the Operator will have to communicate regularly with the Boskalis SDDP Plant Manager and the Boskalis Process Engineer. The Boskalis Process Engineer will maintain regular contact with the dredging operations being conducted by Brennan so that the anticipated sediment properties from areas targeted for dredging on any given day can be evaluated and plant set points can be adjusted as required. Based on the information collected for the in situ sediment properties during the RD, the Boskalis Process Engineer will discuss plant set points and polymer and coagulant dosing rates (dose per dry tons of solids fed) with the SDDP Plant Manager and the Operator.

Routine operations will commence at the end of the prove-out period. During routine operations, the following process streams will be sampled and/or monitored. It should be noted that most of this sampling and monitoring is for the purpose of tracking and documenting routine plant operations and not for regulatory compliance reporting purposes. Only the product/waste streams from the SDDP will be sampled for regulatory compliance purposes for the parameters identified by WDNR, USEPA, and the disposal facilities at the designated frequency described in Section 2 of this O&M Plan. The in-process streams will be collected by Boskalis as frequently as needed to clarify/evaluate process performance. Based on experience gained in operating the SDDP, following the start-up and prove-out periods as discussed below, Boskalis may reduce the frequency of sampling and analyses for some of the process streams. All analytical parameters for regulatory compliance will be collected and analyzed at a laboratory certified by the State of Wisconsin for these parameters. As applicable, samples for regulatory compliance will be refrigerated or maintained at 4°C by other means during the collection period.

37 9/11/09

Sampling and Monitoring for Routine Operations

Process Stream

Infiuent Slurry 8-inch diameter HDPE pipeline Influent Slurry 12-inch diameter HDPE pipeline Coarse Sand from DWSl Coarse Sand from DWS2 Coarse Sand from Conveyor Belt

Fine Sand from DWS3

Fine Sand from DWS4

Fine Sand from Conveyor Belt

Slurry from Residue Tank Sludge from Pre-thickener 1

Sludge from Pre-thickener 2


Sampling/Monitoring Location

Sample port in sample bypass loop


DWSl discharge

DWS2 discharge

CVB 20 stockpile

DWS3 discharge

DWS4 discharge

CVB 30 stockpile

Sample port

Sample port

Sample port

Sample port

Analytical Parameters

Grain size distribution. TOC, Percent solids, Total solids Grain size distribution. TOC, Percent solids. Total solids Grain size distribution, TOC Grain size distribution. TOC PCB Aroclors based on in-situ sediment characterization (testing required for beneficial reuse) Grain size distribution, TOC Grain size distribution, TOC PCB Aroclors based on in-situ sediment characterization (testing required for beneficial reuse) Grain size distribution. TOC Grain size distribution. TOC, cationic polymer and coagulant concentration Grain size distribution. TOC, cationic polymer and coagulant concentration Grain size distribution. TOC, cationic polymer and coagulant concentration

Required for Regulatory Compliance No

No

No

No

Yes

No

No

Yes

No

No

No

No

9/11/09 38


Sludge from Sludge Holding Tank 1




Fiher Cake from Press 1 Filter Cake from Press 2 Filter Cake from Press 3 Filter Cake from Press 4 Filter Cake from Press 5 Filter Cake from Press 6 Filter Cake from Press 7 Filter Cake from Press 8 Filter Cake from Collecting Conveyor Belt

Filtrate Water from Tank Process Water from Tank Wastewater to WTP from Water Buffer Tanks

Sample port

Sample port

Sample port

Sample port

Sample port

CVB 100 discharge

CVB200 discharge

CVB300 discharge

CVB400 discharge

CVB500 discharge

CVB600 discharge

CVB700 discharge

CVB800 discharge

CVB 180 stockpile

Sample port

Sample port

Sample port

Grain size distribution, TOC, cationic polymer and coagulant concentration Grain size distribufion, TOC, cafionic polymer concentration Grain size distribution, TOC, cationic polymer concentration Grain size distribution, TOC, cationic polymer concentration Grain size distribution, TOC, cationic polymer concentration Grain size distribution, TOC Grain size distribution, TOC Grain size distribution, TOC Grain size distribution, TOC Grain size distribution, TOC Grain size distribution, TOC Grain size distribution, TOC Grain size distribution, TOC PCB Aroclors based on in-situ sediment characterization, Paint Filter Test, Veolia acceptance geotechnical parameters Total suspended solids

Total suspended solids


No

No

No

No

No

No

No

No

No

No

No

No

No

Yes

No

No

No

Sampling Locations and Methods and SOP Requirements are identified in QAPP Worksheet #18. Analytical SOP Requirements are detailed in QAPP Worksheet #19. Field Quality Control Samples are

39 9/11/09

summarized in QAPP Worksheet #20. Project Sampling SOPs are referenced in QAPP Worksheet #21. Analytical SOPs are referenced in QAPP Worksheet #23. Sampling of waste material is described in SOP004 in Attachment 2 of the QAPP.

4.3.1.2 Sampling and Monitoring SDDP Performance during Start-up Period

Sampling and monitoring of the SDDP performance will be implemented during the start-up period in 2009 in order to ensure that the system is operating properly. Sampling and analysis of sand and filter cake will also be performed and compared to levels established for beneficial reuse and disposal facility requirements, respectively. The start-up period is defined as the first 30 days of operations following the commencement of dredging. During this period, dredging will be conducted for approximately 16 hours per day and 5 days per week. As discussed above, the Operator will have to communicate regularly with the Boskalis SDDP Plant Manager and the Boskalis Process Engineer. The Boskalis Process Engineer will maintain regular contact with the dredging operations being conducted by Brennan so that the anticipated sediment properties from areas targeted for dredging during this start-up period can be evaluated and plant set points can be adjusted as required. Based on the information collected for the in situ sediment properties during the RD for these target areas, the Boskalis Process Engineer will discuss plant set points and polymer and coagulant dosing rates with the Plant Manager and the Operator. It is anticipated that non-TSCA sediments from D-58 adjacent to the former Shell property will be targeted for dredging during the start-up period.

During the start-up period, the following process streams will be sampled and/or monitored. The purpose of this sampling and monitoring is for tracking and documenting SDDP operations performance as well as for regulatory compliance. During the system start-up period, samples will be collected at the frequencies indicated on QAPP Worksheet #18 as a minimum. All analytical parameters for regulatory compliance will be collected and analyzed at a laboratory certified by the State of Wisconsin for these parameters. As applicable, samples for regulatory compliance will be refrigerated or maintained at 4°C by other means during the collection period.

Sampling and Monitoring during the Start-up Period

Process Stream

Influent Slurry 8-inch diameter HDPE pipeline


Coarse Sand from Conveyor Belt Fine Sand from Conveyor Belt




CVB 20 stockpile

CVB 30 stockpile


Grain size distribution. TOC, PCB Aroclors based on in-situ sediment characterization. Total Solids, Percent Solids Grain size distribution, TOC, PCB Aroclors based on in-situ sediment characterization. Total Solids, Percent Solids See Secfion 2 and QAPP Worksheet #18 See Section 2 and QAPP Worksheet #18

Required for Regulatory Compliance No

No

Yes

Yes

9/11/09 40

Filter Cake from Collecting Conveyor Belt Wastewater to WTP

CVB 180 stockpile

Sample port

See Section 2 and QAPP Worksheet #18


Yes

No

Sampling Locations and Methods and SOP Requirements are identified in QAPP Worksheet #18. Analytical SOP Requirements are detailed in QAPP Worksheet #19. Field Quality Control Samples are summarized in QAPP Worksheet #20. Project Sampling SOPs are referenced in QAPP Worksheet #21. Analytical SOPs are referenced in QAPP Worksheet #23. Sampling of waste material is described in SOP004 in Attachment 2 of the QAPP.

4.3.1.3 Sampling and Monitoring SDDP Performance during Prove-Out Period

Sampling and monitoring of the SDDP performance will be implemented during the prove-out period in 2009 in order to ensure that the system is operating in accordance with the design specifications and meets all regulatory, beneficial reuse, and disposal facility requirements. The prove-out is defined as 30 days following the start-up period. As discussed above, the Operator will have to communicate regularly with the Boskalis SDDP Plant Manager and the Boskalis Process Engineer. The Boskalis Process Engineer will maintain regular contact with the dredging operations being conducted by Brennan so that the anticipated sediment properties from areas targeted for dredging during this prove-out period can be evaluated and plant set points can be adjusted as required. Based on the information collected for the in situ sediment properties during the RD for these target areas, the Boskalis Process Engineer will discuss plant set points and polymer dosing and coagulant rates with the Plant Manager and the Operator. It is anticipated that during the prove-out period, only sediments with non-TSCA concentrations of PCBs will be targeted for dredging. However, sediments with TSCA concentrations of PCBs that lie within non-TSCA target areas may also be dredged during the prove-out period.

During the prove-out period, the following process streams will be sampled and/or monitored. The purpose of this sampling and monitoring is for ensuring that the SDDP is operating in accordance with the design specifications and to obtain analytical and geotechnical data for the sand and filter cake produced. During the system prove-out period, samples will be collected at the frequencies indicated on QAPP Worksheet #18 as a minimum. All analytical parameters for regulatory compliance will be collected and analyzed at a laboratory certified by the State of Wisconsin for these parameters. As applicable, samples for regulatory compliance will be refrigerated or maintained at 4°C by other means during the collection period.

Sampling and Monitoring during the Prove-out Period

Process Stream





Grain size distribution. TOC, PCB Aroclors based on in-situ sediment characterization. Total Solids, Percent solids

Required Regulatory Compliance No

for

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Coarse Sand from Conveyor Belt Fine Sand from Conveyor Belt Filter Cake from Collecting Conveyor Belt Wastewater to WTP


CVB 20 stockpile

CVB 30 stockpile

CVB 180 stockpile

Sample port

Grain size distribution. TOC, PCB Aroclors based on in-situ sediment characterization, Total Solids, Percent Solids See Section 2 and QAPP Worksheet #18 See Secfion 2 and QAPP Worksheet #18 See Section 2 and QAPP Worksheet #18


No

Yes

Yes

Yes

No

Sampling Locations and Methods and SOP Requirements are identified in QAPP Worksheet #18. Analytical SOP Requirements are detailed in QAPP Worksheet #19. Field Quality Control Samples are summarized in QAPP Worksheet #20. Project Sampling SOPs are referenced in QAPP Worksheet #21. Analytical SOPs are referenced in QAPP Worksheet #23. Sampling of waste material is described in SOP004 in Attachment 2 of the QAPP.

4.3.1.4 Sampling and Monitoring for Value Engineering Studies

In order to optimize the operations and determine ways to improve the efficiency and reduce capital and operating costs, value engineering studies will be conducted by Boskalis and Tetra Tech during the remainder of the project. Items that are slated to be examined as part of these studies are the types and concentrations of the coagulant and cationic polymers used for pre-thickening, as well as an examination of the operating cycle of the membrane filter presses. Most of this testing is anticipated to be done on a bench-scale and some of it may be done on a larger scale as part of a pilot study based on the results obtained from bench-scale testing.

4.3.2 Oualitv Control Sample Requirements

QC samples are analyzed for the purpose of assessing the quality of the sampling effort and of the analytical data. QC samples include field QC samples and laboratory QC samples. Field QC samples are described in Section 8.1 of the QAPP and include environmental field duplicate samples, co-located field replicates, equipment rinsate blanks, and cooler temperature blanks. Laboratory QC samples include method blanks, matrix spike/matrix spike duplicates, surrogate compounds, internal standards, laboratory control samples, and laboratory duplicate samples. The general information and guidance regarding the different types of field QC samples is provided below. Similar information for laboratory QC samples including their definifions and frequency of collection is provided in Section 8.2 of the QAPP. Field QC samples and their acceptance criteria are summarized in QAPP Worksheet #20. A summary of QC procedures, frequencies, criteria, and corrective actions for the laboratory QC samples, as determined by the applicable guidelines is provided in QAPP Worksheet #28.

4.3.2.1 Environmental Field Duplicate Samples

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Field duplicates are used to monitor the precision of the field sampling procedures and the variability of sample data. Field duplicates are field split samples collected by homogenizing enough sand or filter cake volume for two samples. Field duplicates will typically be collected and analyzed at a frequency of 1 for every 20 samples (approximately 5 percent); exceptions to this rate are noted on QAPP Worksheet #20. Field duplicates will only be collected for material that is analyzed for regulatory purposes. Field duplicates will be analyzed for the same parameters, as applicable, as the original samples.

4.3.2.2 Equipment Rinsate Blanks

Equipment rinsate blanks are used to monitor cleanliness of the sampling equipment and the effectiveness of the decontamination procedures. Dedicated sampling equipment will be used during the project to the extent possible, reducing the need and frequency of equipment rinsate blanks. As required, equipment rinsate blanks will be collected once per week (assuming 6-day work week) and sent to the off-site laboratory for analysis of the same parameters (chemical only) as the original samples.

4.3.2.3 Cooler Temperature Blanks

Temperature blanks are used to monitor the receipt temperature of the samples upon arrival at the analytical laboratory. Temperature blanks will consist of an unpreserved 40-milliliter glass or plastic vial filled with tap water. A temperature blank must be included in each sample container sent to an analytical laboratory. However, Wisconsin regulations include provisions for omitting sample receipt temperature at the laboratory if the samples are received on ice.

4.3.3 Equipment Decontamination Procedures

For this sampling and analysis program, both disposable and non-disposable sampling equipment may be used. All non-disposable sampling equipment will be decontaminated prior to collecting each sample. The following sequence will be used:

• Remove all visible contaminants using laboratory detergent and potable water.

• Rinse with potable water.

• Rinse with deionized water.

• Rinse organic sampling equipment with hexane. For inorganic sampling equipment, rinse with 9.9% nitric acid in water. In both cases, then rinse with deionized water again.

Decontamination fluids generated will be collected and stored on site for later disposal as specified in the Transportation/Disposal Plan.

4.3.4 Sample Identification, Documentation, Chain of Custody, Packaging, and Shipping

Identification, documentation and strict custody of samples are important for ensuring the integrity of the environmental samples and maintaining data quality. The subsections below and QAPP Worksheets #26 and #27 address sample identification, packaging, shipping, and documentation.

4.3.4.1 Sample Identification and Labeling

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Samples collected from the SDDP will be uniquely identified. Each sample will be denoted with an identification code as to the process stream (i.e., the location of sampling and type of material being sampled). These codes are outlined in the table below. The date of the sampling (e.g., "011609") will then be added to the identification to segregate different process sampling events. If required, further differentiation may be added (such as "01" and "02" if sampled twice during the same day).

Process Stream



Porous Debris

Non-porous Debris

Coarse Sand from DWSl

Coarse Sand from DWS2

Coarse Sand from Conveyor Belt

Fine Sand from DWS3

Fine Sand from DWS4

Fine Sand from Conveyor Belt

Slurry from Residue Tank









Filter Cake from Press 1








Filter Cake from Collecting Conveyor Belt

Location/Material Code

IS8

IS12

PD

ND

CSl

CS2

CSB

FS3

FS4

FSB

SLT

SLPl

SLP2

SLP3

SLP4

SLHl

SLH2

SLH3

SLH4

FCl

FC2

FC3

FC4

FC5

FC6

FC7

FC8

FCB

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Filtrate Water from Tank FW

Process Water from Tank PW

Wastewater to WTP WW

For example, the fine sand sample collected from the conveyor belt on February 14, 2009 would be denoted as "FSB-021409." If two samples of the filter cake from Press 7 were obtained on March 17, 2009, then the first sample would be "FC7-031709-01" and the second would be "FC7-031709-02."

Sample labels will be completed by field personnel. Labels will include the project identification, sample identification, date and time of sampling, sampler, analyses to be performed on the specific sample bottle, type of sample (grab or composite) and preservative (if applicable). Each sample label will be filled out completely with indelible ink.

4.3.4.2 Sample Documentation

The sampling team or any individual performing a particular field investigation activity will be required to maintain a field logbook. Each logbook will be controlled and assigned a unique sequential identification by the Field Team Lead (e.g., the second logbook devoted to the SDDP sampling activities may be designated "SDDP Sampling Logbook No. 2"). In addition, a list of field logbooks will be maintained by the Field Team Lead, and will include the name of the logbook, purpose, person to whom assigned (i.e., name of task lead), date assigned, and date returned to the Field Team Lead.

The field logbook will be a bound weatherproof notebook, and entries to the logbook must be filled out legibly in black waterproof ink. Pertinent information to be recorded in field logbooks includes all information that is necessary to reconstruct the investigative/sampling operations. Documentation of sample activities in the field logbook will be completed immediately after sampling at the location of sample collection. Logbook entries will contain all sample information, including sample number, collection time, location, descriptions, field measurements, and other site- or sample-specific observations. Difficulties with recovery and field observations (e.g., staining, visible contamination, etc.) must be noted if encountered. Any additional information, such as generated instrument output, will be attached into the field logbook with clear tape in the order of generation or will be filed in a specific folder for inclusion with project files.

Logbook pages (for both the master site logbook and the field logbooks) will have the name of the Site and a description of the location/activity discussed, as well as the calendar date, written on the top of each page. Logbook pages will be consecutively numbered, and upon entry of data, the logbook pages require the date and the signature of the responsible project team member at the bottom of each page. Corrections to the logbooks will consist of a single strike line through the incorrect entry, the new accurate information, the initials of the corrector, and the date of amendment. Any blank spaces/pages in the logbooks will be crossed out with a single strike mark and signed by the person making the notation.

4.3.4.3 Sample Chain of Custody

Sample custody must be strictly maintained and carefially documented each time the sample material is collected, transported, received, prepared, and analyzed. Custody procedures are necessary to ensure the integrity of the samples, and samples collected during the field investigation must be traceable from the time the samples are collected until they are disposed of and/or stored, and their derived data are used in the final report.

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A sample is considered under custody if it is/was:

• In a sampler's possession; • In a sampler's view after being in his/her possession; • In a sampler's possession and locked up in a secured container; or • In a designated secure area.

Personnel collecting samples are responsible for the care and integrity of those samples until they are properly transferred or dispatched. Therefore, the number of people handling a sample will be kept to a minimum.

Chain of Custody (COC) records will be completed by the sampler and shall accompany the samples at all times. The following information shall be indicated on the COC record:

• Project identification; • Signature of samplers; • Sample identification, sample matrix, date and time of collection, grab or composite sample

designation, number of containers corresponding to that sample identification, analyses required, remarks or sample location (if applicable), and preservation method(s);

• Signature of the individual relinquishing the samples; and • Name of the individual(s) receiving the samples and air bill number, if applicable.

The COC preparer will then check the sample label and COC record for accuracy and completeness.

4.3.4.4 Sample Tracking

When transferring custody of samples, individuals relinquishing custody and individuals receiving custody will sign, date, and record the time on the COC. When samples are being shipped to the laboratory via courier, the COC record will be signed as "receiver" by the courier when he/she accepts possession of the samples, and a signed copy will be retained by the Tetra Tech Team. For samples transported by an overnight shipping company (e.g.. Federal Express), the shipping company will be indicated as receiving custody. Upon receipt of shipment at the laboratory, a designated sample custodian will accept custody of the samples and verify that information on the sample labels matches the COC record. Pertinent information on shipment, air bill number, pickup, courier, date, and time will be recorded on the COC. It is then the laboratory's responsibility to maintain logbooks and custody records throughout sample preparation and analysis.

4.3.4.5 Sample Packaging and Shipping

Samples for off-site laboratory analysis will be shipped via Federal Express or by courier for overnight delivery in waterproof coolers using the procedures outlined below. The samples taken for this project shall be considered low-level or environmental samples for packaging and shipping purposes. Prior to packing and shipping, as applicable, samples will be stored on ice. The sample packing procedures are as follows:

• After filling out the pertinent information on the sample label, if necessary cover the label with clear tape.

• Place about 3 inches of inert cushioning material, such as bubble wrap, in the bottom of the cooler.

• Place containers upright in the cooler in such a way that they will not touch during shipment.

46 9/11/09

• Put in additional inert packing material to partially cover the sample containers (more than halfway).

» Place ice, when necessary, sealed in plastic bags, around and on top of the containers. As applicable to specific analyses (outlined in Worksheet #19 of the QAPP), the temperature of the samples shall be maintained at or below 4 °C during shipment to the laboratory. The addition of ice will not be necessary for those parameters that do not require cooling as a preservation technique.

• Fill cooler with cushioning material. • Tape the drain on the cooler shut.

If the samples are sent directly via courier service from the Site to a local laboratory certified by the State of Wisconsin, the COC record will not be placed inside the cooler. The sample cooler(s) will be secured, with signed and dated custody seals affixed over the lid opening in at least two locations, and the cooler wrapped with strapping tape (without obscuring the custody seals). Orientation "this end up" arrows will be drawn or attached on two sides of the cooler. The COC record will be signed by the receiver (e.g., the courier, the laboratory sample custodian) when he/she accepts possession of the samples, and a signed copy will be retained by the Tetra Tech Team.

For samples being shipped by an overnight delivery service to a laboratory certified by the State of Wisconsin, the COC record will be placed in a waterproof plastic bag and taped with masking tape to the inside lid of the cooler. The cooler lid will be secured with strapping/shipping tape (wrap the cooler completely with tape at a minimum of two locations), and a completed shipping label will be attached to the top of the cooler. Orientation "this end up" arrows will be drawn or attached on two sides of the cooler. Two signed and dated custody seals will be placed on opposite comers of the cooler so that the cooler cannot be opened without breaking the seals.

4.4 Laboratory Analytical Procedures and Requirements

4.4.1 Analytical Procedures

As stated previously, samples will be analyzed in strict accordance with the analytical test methods and procedures in NR 219, utilizing approved USEPA, ASTM, and/or British Standard methods. Samples for regulatory compliance will be collected by Tetra Tech. Samples for in-process monitoring will be collected by Boskalis. A reduced level of quality will be utilized for the in-process analyses. The anticipated number of samples, analytical methods, and number of QC samples are identified in Section 4.3.1 and the QAPP Worksheets identified above.

Analytical methods selected for the Site will provide results with detection limits sufficiently below designated action levels, and the methods will be accurate enough to quantify contamination at concentrations below action levels.

4.4.2 Laboratory Reporting Requirements

As applicable for the compliance samples, laboratory reports will include a full data package in order to support QA/QC review. Reporting requirements will include, but are not limited to the following:

• The name, address, and phone number of the analytical laboratory.

• Signature of an authorized laboratory individual, indicating the acceptability of the data.

47 9/11/09

• A copy of signed chain of custody forms, indicating the condition of samples at the time of receipt by the laboratory.

• Sample results reported in units of g or mg per liter or kg, or other standard units as appropriate. Results will be reported on a dry weight basis and will include correction for dilution/concentration factors.

• Sample results will include a summary of pertinent chain of custody and tracking information (i.e., dates of preparation and analysis, analytical instrumentation, calibration information, associated QC samples, etc.). Other raw data including chromatograms must be on file at the laboratory and available for review upon request.

• Quality control results reported are to include spiking concentrations and acceptable limits. QC results that exceeded criteria and corrective actions should be discussed by the laboratory.

4.4.3 Data Review

All data will be reviewed by laboratory QC personnel prior to submittal to Tetra Tech and Boskalis. In addition, the Tetra Tech chemistry staff will perform a review of QA/QC data for the regulatory compliance sample analysis results. After these reviews, the data will be provided to the Boskalis and Tetra Tech persormel who are responsible for monitoring the performance of the SDDP operation. They will utilize the analytical results to verify that the plant is operating in the normal expected range of operation for each variable reported.

The review will include the following:

• Review of chain-of-custody and sample receipt documents to verify sample identities.

• Review of sample log-in documents to verify any potential problems with sample custody, integrity, preservation, labeling, etc.

• Review of field blank data to ascertain any problems with container or preservative contamination, or field contamination.

• Review of method blank data to determine the presence and approximate concentration of sources of contamination in the analytical process.

• Review of matrix spike data as a measure of matrix effects and analytical precision.

• Review of field and laboratory duplicate data as a measure of sampling technique applicability, homogeneity, and analytical precision.

• Review of standard reference material or laboratory control sample data as a measure of analytical accuracy. Data will be compared to the certified acceptable ranges of analytical values.

48 9/11/09

• Review of sample dates, extraction/digestion dates, and analysis dates to determine whether maximum holding times were met or exceeded.

Where appropriate, data qualifiers will be incorporated into certain data summary tables generated for this project. A brief summary of the data QA/QC review will be included in the final report.

49 9/11/09

5.0 HEALTH AND SAFETY

5.1 Introduction

All activities performed at the SDDP are governed by the Site Health and Safety Plan (SHSP). The SHSP presents procedures to be followed by Tetra Tech and its subcontractors (including Boskalis) and all other on-site personnel in order to avoid and, if necessary, protect against health and/or safety hazards. The SHSP is designed to protect on-site personnel and area residents from physical, chemical, and all other hazards posed by activities conducted as part of the Phase 2B Work conducted at the Site. The SHSP takes into account the hazards inherent to the planned construction/marine activities. In addition. Section 10.0 of the SHSP includes the Emergency Response and Contingency Plan for the Phase 2B activities as required by the Administrative Order. The SHSP will comply with applicable parts of Occupational Safety and Health Administration (OSHA) Regulations, primarily 29 CFR Parts 1910 and 1926, and Tetra Tech's Environmental Health and Safety (EHS) Program. In addition, since the majority of site activities are being performed on or adjacent to water, they must also comply with 29 CFR 1917 Marine Terminals and the US Coast Guard Regulations. Many programs from the EHS Program are referenced in the SHSP and are included in the appendices. Modifications to the SHSP may be made with the approval of the Project Environmental and Safety Manager (PESM) for this project using the Field Change Request Form found in Appendix A of the SHSP.

5.2 Summary of Major Risks

Work near the river. Heavy equipment hazards. Slips, Trips, and Falls. Exposure to PCBs. Rotating Machinery. Electrical Hazards. Pressurized air and process stream pipelines and process equipment.

5.3 Zero Incident Performance

Zero Incident Performance (ZIP) describes Tetra Tech's approach and expectations for both safety and project execution. Tetra Tech will achieve this level of performance excellence through teamwork and partnering with our client and our Subcontractors, and through the participation of every person on this project.

We (Tetra Tech and our client) believe that: • All incidents are preventable through proper planning, tasking, and execution of plans as

written. • Any goal besides Zero Incident Performance is unacceptable and sends the message that

incidents cannot be prevented and that losses are tolerated. Incidents are defined as OSHA recordables, property damage cases, fires, explosions, spills or releases to the environment and safety-related work stoppages. In addition, an incident includes an event which could have resulted in one of these outcomes had the circumstances been different ("near miss").

• Active participation by all personnel is required to achieve Zero Incident Performance. This includes Tetra Tech, the client, and all Subcontractor personnel.

• Each person on this project is individually responsible and accountable for their safety performance.

50 9/11/09

• If any incident does occur, it must be reported and investigated to identify root causes, take corrective actions, and communicate the lessons learned.

All Tetra Tech and Subcontractor personnel will sign a ZIP pledge poster affirming their belief in and commitment to ZIP. The ZIP Banner will be posted conspicuously at the project site and the hours worked without a loss time incident will also be posted. The Tetra Tech EHS will continually evaluate planning and project execution to ensure that ZIP is embedded in the work process. In addition, awareness programs are utilized to assist in implementation of Tetra Tech's ZIP initiative. A Subcontractor, after award of a contract, shall be required to attend a pre-construction Health and Safety Orientation meeting. This meeting will involve the Subcontractor's key personnel, and will cover such items as ZIP expectations and the Employee Participation Program (EPP).

5.4 Activity Hazard Analyses

The Activity Hazard Analysis (AHA) is a systematic way of identifying the potential health and safety hazards associated with major phases of work on the project and the methods to avoid, control and mitigate those hazards. The AHAs follow the guidance of the Tetra Tech Corporate Program EHS 3-5. AHAs are developed for all activities and will be used to train workers in proper safety procedures during phase preparatory meetings. AHAs for the 2009 and beyond site activities are included in Appendix C of the SHSP. AHAs that are applicable to activities at the SDDP and adjacent areas include:

• General Site Hazards • Desanding and Dewatering Operations • Transportation and Disposal • Wastewater Treatment Plant Operations • Sampling (Sediments and Process Operations)

5.5 Personal Protective Equipment

The personal protective equipment specified in Table 5-1 of the SHSP represents the initial level of PPE selection for each activity required by 29 CFR 1910.132. Specific information on the selection rationale for each activity can be found in the Activity Hazard Analyses. Personal protective equipment selection shall be made by the ESS and approved by the PESM. Additional tasks not included in Table 5-1 of the SHSP shall be reviewed by the ESS and PESM.

Due to the nature of the activities it is not anticipated that upgrading to Level C or B will be required during the Lower Fox River site activities. Level D or modified Level D is anticipated for all site work but the ESS has the responsibility for monitoring site and work conditions and deciding the appropriate level of protection based on indications of potential exposure.

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6.0 PROCESS DESCRIPTION AND OPERATION

NOTE: Section 6 contains confidential business information that is the intellectual property of Boskalis Dolman BV and Stuyvesant Dredsins Inc. (SDI). Therefore, it is only available for review purposes to those parties that have obtained written permission from SDI and have sisned the required Confidentiality Asreement and have asreed to be bound by this agreement. Section 6 will be removed from any document that is made available to parties that have not obtained the required permission from SDI and blank pases will be substituted.

The process descriptions for the LFRR SDDP, provide the written narrative which explains the individual process system loops and their inter-relationship. They were used to program the Computer Monitoring and Control System (CMCS) by describing the setpoints and relationships between the process equipment and the instrumentation used for monitoring the desanding and dewatering process. The process loops are shown in Table 6-1 and the functional descriptions are provided in the following sections.

52

7.0 OPERATIONS

7.1 Initial Testing and Commissioning Procedures

At the conclusion of construction activities, all mechanical systems will be hydrotested to ensure that welds and cotmections are water-tight. Subsequently, before any contaminated sediment is processed in the SDDP, all piping and equipment in the plant will be tested with river or municipal water to ensure all units are fiinctioning properly.

The following sequence will likely be used to test the plant and to prepare for actual operation:

a. When the sand separation unit is installed and all slurry tanks and all related piping and pumps are in place, water will be pumped from Slurry Holding Tank No. 1 to the Slurry Thickener Tank and from there to the Coarse and Fine Sand Separation. All water will be collected in the Residue Tank and pumped back into the Slurry Holding Tank No. 1;

b. When the Pre-thickener Tanks are installed and all related piping and pumps are in place, water will be pumped from the Residue Tank to the Pre-thickener Tanks. Overflow water from the Pre-thickener Tanks will be collected in the Process Water Tank. From there the water will be pumped back into the Residue Tank or to Slurry Holding Tank No.l;

G. When the Sludge Holding Tanks and the Membrane Presses are installed and all related piping and pumps are in place, water will be pumped from the Pre-Thickener Tanks through Sludge Holding Tanks into the Membrane Presses. All water will be retumed to the Pre-Thickener Tanks as filtrate water.

All conveyor belts, level controls, valves, switches, the Overflow Tank and all related pumps, and piping will be checked one by one prior to and/or during the three testing cycles described above.

After all systems are found to be water-tight, the full plant will be run with water only, to test all pump system, level and flow indicators, valves, alarms, and interlocks.

• The system will be started with the Residue Pumps pumping water from the Residue Tank into the Pre-thickener Tanks. When the pumps are started, the level in the Residue Tank will be lowered. At low level, the Residue Tank will be re-filled with water from the Process Water Tank. Supernatant water, overflowing from the Pre-thickener Tanks, will feed the Process Water Tank, closing the loop.

• The sludge pumps will be started, to pump water from the Pre-thickener Tanks into the Sludge Holding Tanks. The water level in the Sludge Holding Tanks will rise and the level in the Process Water Tank level will fall. At low level, the water in the Process Water Tank will be adjusted by pumping water from one of the Water Buffer Tanks. When a high level in the Sludge Holding Tanks has been reached, the sludge pumps will be stopped.

• Next, the screening and separation part of the SDDP will be started. Water will be pumped from Slurry Holding Tank No.l to the Slurry Thickener Tank and from there to the sand separation. First, one separation treatment train will be started, with half of the flow bypassing through the Thickener Cyclones. The Residue Tank will be filled with this water, automatically minimizing or stopping the flow from the Process Water Tank. Overflow water from the Pre-thickener Tanks will still fill the Process Water Tank. Excess water however will now no longer be rerouted to the Residue Tank but will be used to fill up the Slurry Holding Tank. With all systems running smoothly, the second separation treatment train will be started, switching part of the

53

flow from Thickener Separator No. 2 to separation treatment train No. 2. After testing treatment train No.2 it will be shut down again, as it will only have to be run when there is sufficient sand in the incoming slurry from the dredging operation.

• With all systems in operation, all eight membrane press systems will be tested hydraulically one by one. As there is no sediment in the system, all water pumped into each press will leave the system as filtrate water. This water will be retumed into the Pre-thickener Tanks. After testing the presses, all Sludge Holding Tanks will be fiilly emptied to be ready for sediment processing.

With the plant tested and running on water, feeding the system with a dredge can be started. First feed will be water, to test the interaction of the dredging operation and the SDDP. As surplus water will have to leave the system now, the interaction between the SDDP and WTP will be tested also.

With all systems mnning smoothly, the operation of the Overflow Tank will be tested. The input coming from the dredge will be routed into the Overflow Tank by closing the main inlet valves. At low level, the Overflow Tank pump will start pumping supematant water from this tank into Slurry Holding Tank No. 1 or the Slurry Thickener Tank.

The first actual start of the system will be performed by dredging non-TSCA sediment. By slowly filling the system with sediment, extra attention will be given to the polymer dosing after the Residue Tank. This is to ensure that only sufficiently clarified water will be overflowing the system and stored in the Water Buffer Tanks, for further treatment.

Pre-thickened sludge will be pumped into one Sludge Holding Tank. This material will be used for a first dewatering mn, using one press.

After balancing the system as described, an increased load of sediment will be fed into the system. One by one, the other Sludge Holding Tanks will be filled with sediment, depending on the number of presses necessary to keep up with the sludge production.

7.2 Weekly Start-up and Shut-down Procedures

All start-up and shut-down procedures for the SDDP are controlled by a programmable logic controller (PLC), operated from the Control Room.

The PLC program starts up immediately after switching the main power switch to 'On'. The program arranges for a fully controlled start-up of the SDDP after pushing the 'Start' button on one of the main control panels. The Scalping Screen, Slurry Holding Tank No. 1, the Slurry Thickener Tank, Slurry Tank No. 2, Slurry Tank No. 3, and all the Upstream Classifiers are equipped with a jet water system to fluidize any sand that may have settled in this equipment after a previous shut-down and enable the pumps to be restarted. Once the system is up and mnning the jet water system will be shut-down. After finishing the start-up procedure, plant operations can be started by introducing a first flow of water onto the Scalping Screen. The plant will adapt automatically to the incoming flow. As surplus water will leave the plant from the Water Buffer Tanks to the WTP, the WTP has to be operational before actual start-up of the SDDP. When all systems are fiinctioning correctly, sediment can be introduced into the plant and the hydraulic load can be raised.

When the SDDP has to be shut-down, first step is to stop dredging, thus shutting down the input of sediment into the SDDP. Depending on the type of sediment to be dredged and the distance from the dredge to the SDDP, water will still be pumped into the plant to flush the lines. During this period of time, any gravel and sand in the separation equipment will also be flushed out. After emptying all

54

dewatering screens and conveyor belts, the separation equipment can be switched off The dewatering equipment will continue to dewater the residue that will still be present in the Pre-thickener Tanks and Sludge Holding Tanks. After emptying all tanks and processing all pre-thickened sludge, the dewatering equipment can also be switched off and the main switch can be put to 'Off.

It is possible to switch off the dewatering equipment without processing all pre-thickened sludge. However, depending on the type of sludge it might be necessary to keep the mixers in the Sludge Holding Tanks in operation.

Procedures for Operations Change-over from TSCA to non-TSCA sediments.

All of the TSCA sediments are in OU4 and are likely to be materials containing fine sands, silts, and clays. After dredging of TSCA sediments in a given target area has been completed, the following procedures will be followed before dredging of non-TSCA materials is initiated.

In order to completely flush the 8-inch and 12 inch HDPE dredge pipelines, the dredges will pump river water from a maximum distance of 4 miles or less to the former Shell property. The two 8-inch dredges will pump approximately 1500 gpm and the 12-inch dredge will pump approximately 2000 gpm for a minimum of 90 minutes. This river water will be flushed through all of the process equipment in the SDDP and the WTP. If the all of Pre-thickeners and the Sludge Holding Tanks in the SDDP are ftill at the time this flushing begins, it will take approximately 14 hours to process the sludge and convert it to filter cake and complete a shut-down of the system. The dredges would continue to pump river water for this time period.

Some of the sludge that is below the pump suction level in the Pre-thickeners and Sludge Holding Tanks will not be removed during the shut down procedures described above. If the change-over from TSCA to non-TSCA material occurs during the middle of a dredging season, after dredging of non-TSCA sediment is initiated, the initial batch of filter cake will have to be disposed of as TSCA material. All of the filter cake produced during the flushing time period and as part of the first batch of non-TSCA material processed will be loaded onto tmcks from the floor of the filter cake storage area and the entire area will then be washed until it is visually clean.

When TSCA sediments are dredged at the end of a dredging season, all of the tanks in the SDDP will be emptied and cleaned before the winter shut-down. All filter cake will be removed from the filter cake storage area and the entire area will be washed with clean water until visually clean.

7.3 Operations

This section describes the main operating details of each specific unit in the SDDP.

Wash and Sieve Drum Description The Wash and Sieve Dmm (Dmm) is an optional pre-treatment step

before the Scalping Screen. It will receive mechanically dredged sediment from barges, via a crane. The purpose of the Dmm is to remove all gravel and debris greater than 1 inch in size. The Dmm will be installed outside the plant building. Coarse debris will be stockpiled directly adjacent to the dmm to be removed for disposal.

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Start-up After the Dmm is started, wash water from the wash water tank will be pumped into the hopper and through the jet system. With all systems fianctioning, sediment will be loaded into the dmm, washed and screened. The main flow of material will pass into the Dmm Slurry Tank situated under the Dmm. From this tank it will be pumped to the Scalping Screen inside the SDDP building.

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Normal Operation

Emergency operations

Shutdown

Maintenance

Under normal operation, only removing very coarse materials on top of the grizzly screen inside the Dmm Hopper will require attention. The Dmm shall be loaded carefully, taking care to avoid overloading it. Not applicable. Under emergency conditions, the Dmm will be shut down for repair. The Dmm is not a critical in line part of the SDDP During shutdown periods, loading of the Dmm will be stopped and water will be pumped into the Dmm until it is fiilly flushed with river or municipal water and free of sediment. After the Dmm Slurry Tank is flushed, all pumping systems can be stopped. When the Dmm is free of sediment, it can be stopped. Functioning of the Dmm, screen, spray nozzles and dmm chain drive should be checked and serviced regularly.

Scalping Screen

Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The Scalping Screen will receive incoming flow from the dredges. The purpose is to remove all gravel and debris greater than 6mm in size. A conveyor belt will be used to convey the debris and greater than 6mm material outside the building, where it will be transferred to another conveyor operated by Tetra Tech that will transfer it to a roll-off box on the south end of the sand slab. The Scalping Screen and conveyor belt will be started 'dry'. When the dredges start pumping material onto the screen, debris removal starts automatically. The main flow of material will pass into Slurry Holding Tank No.l, situated directly under the Screen. Under normal operation, the Scalping Screen will require little attention. Occasionally, water nozzles might have to be checked and replaced. Material buildup or lack thereof will be noted. The Scalping Screen will be by-passed into the Overflow Tank, using special valves that even fianction with full power failure During weekends or another shutdown period, the incoming flow will stop and the Screen and conveyor belt will empty automatically. When empty, the Screen can be turned off. Functioning of screen, spray nozzles, conveyor belt scrapers and rollers to be checked and serviced regularly. Motors and drives, bearings and conveyor belt according to maintenance schedule.

Slurry Holding Tank No.l Description

Start-up

Normal Operation

Slurry Holding Tank No. 1 will receive screened material through the above positioned Scalping Screen. All material passing the Screen will be smaller in size than 6mm. The Holding Tank will start filling directly after the dredge(s) start pumping material onto the Scalping Screen. Pumping slurry from the Holding Tank is PLC controlled, using tank level monitoring. Under normal operation, the Holding Tank will require little attention. Occasionally, the tank might have to be cleaned and level control checked.

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Emergency Operation

Shutdown

Maintenance

When a pump is broken or blocked or the level control is out of order, water overflowing the Holding Tank will be directed into the Overflow Tank through an overflow pipeline. This is to prevent water and sediment to flow onto the building floor. During weekends or other shutdown periods, the system will be cleaned by pumping river water through the system. At the moment all sediments have been flushed out of the system, the incoming flow will be shut down. With no water and sediments entering the Holding Tank, the PLC controlled system will shut down the slurry pumps. If necessary, all water will be pumped out of the Holding Tank. There is hardly any maintenance expected for this Tank. Tank might be cleaned from time to time and during Winter Maintenance, paint condition will be checked and improved.

Overflow Tank

Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The Overflow Tank is meant to receive screened or unscreened material during major plant failures. This is to prevent spill of material. During normal operations, the Overflow Tank will serve as holding tank for backwash water coming from the water treatment plant. The Overflow Tank will start filling at the moment the first filter of the water treatment plant starts backwashing. Pumping settled backwash water from the Overflow Tank back into the Sediment Treatment Plant is PLC controlled, using tank level monitoring. Under normal operation, the Overflow Tank will require little attention. Occasionally, settled material will be removed from the tank bottom using jet water and a special waste water pump. This settled material will be pumped back into the SDDP. During an emergency situation at the SDDP, the Overflow Tank will hold all sediment slurry coming from the dredges. If the emergency can not be solved, approximately 30 minutes are available to stop the dredges and to clean the transport pipes. With no backwash water or emergency overflow water entering the Overflow Tank, the PLC controlled system will shut down any pumping from the tank. Maintenance will be limited to the removal of settled material from the tank bottom as described under Normal Operation.

Slurry Thickener Tank Description

Start-up

The Slurry Thickener Tank is meant to minimize density variations in the incoming flow and to increase the density of the slurry pumped to the Coarse Sand Separation Unit. The Thickener Tank and Thickener Separators are all parts of this thickening system. The Slurry Thickener Tank will receive screened sediment from Slurry Holding Tank No. 1. Once the level in the tank reaches a preset level, pumping the (thickened) material from the tank starts automatically through the PLC control system.

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Normal Operation

Emergency Operation

Shutdown Maintenance

Under normal operations, incoming and outgoing flows are balanced by the optional recycling of overflow from the Thickener Separators. The Slurry Thickener Tank requires little attention, as flows and levels are monitored constantly and PLC controlled. When a pump is broken or blocked or the level control is out of order, water overflowing the Slurry Thickener Tank will be directed into the Overflow Tank through an overflow pipeline. This is to prevent water and sediment to flow onto the building floor. If one of the pumps or a part of the Coarse Sand Separation System is out of order, the system will adjust to a lower flow rate. See 'Shutdown' under 'Slurry Holding Tank No. 1'. See 'Maintenance' under 'Slurry Holding Tank No. 1'.

Thickener Separators Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The Thickener Separators are meant to minimize density variations in the incoming flow and to increase the density of the slurry pumped to the Coarse Sand Separation Unit. The Slurry Thickener Tank and Thickener Separators are all parts of this thickening system. The Thickener Separators will receive screened sediment from the Slurry Thickener Tank. Once the level in this tank reaches a pre-set level, pumping the (thickened) material from the tank starts automatically through the PLC control system. Under normal operations, the underflow of the Thickener Separators flows back into the Slurry Thickener Tank while the overflow is directed into the Residue Tank. If the level in the Slurry Thickener Tank is too low, the PLC system will redirect overflow material back into the tank to balance the system. There is no emergency operation. When a pump feeding one of the Thickener Separators is blocked or broken, this separator will be out of order. When the system has been flushed with (river or municipal) water, the PLC controlled system will automatically shut down the pumps feeding the separators. There is very little maintenance expected for the separators during the annual operating period. If necessary, the underflow regulator might be replaced during weekend downtime. During winter maintenance, the separators might be taken apart for checking the condition of the liner.

Coarse Sand Separation Unit Description

Start-up

The Coarse Sand Separation Unit is meant to separate, wash and dewater all +150 micron sand from the sediment slurry. The system uses 150 micron separators, upstream classifiers, sand dewatering screens and a conveyor belt. At start-up, the dewatering screens and conveyor belt are started 'dry'. When the level in the Thickener Tank is sufficient, the feed pumps to the Coarse Sand Separators are started automatically.

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Normal Operation

Emergency Operation

Shutdown

Maintenance

Under normal operations, the overflow of the 150 micron separators flows into Slurry Tank No. 2. The separated sand (underflow) flows into the upstream classifier for polishing. Polished sand flows down onto the dewatering screen. A conveyor belt transports the sand to the stocking area outside of the processing building. When a pump is blocked or another part of the system is not functioning, the Coarse Sand Separation Unit will be shut down automatically. As there are two parallel treatment trains, in most situations only one treatment train will be out of order, the other treatment train still fiilly operational. When the system has been flushed with (river or municipal) water (see above items), the PLC controlled system will automatically shut down the pumps feeding the separators. When the classifiers are empty and all sand has passed the dewatering screens and conveyor belt, all items will be shut down. For separator maintenance see 'Maintenance' under 'Thickener Separators'. The classifier water injection system needs to be checked regularly for blocking, to guarantee a constant and stable water flow. For dewatering screen and conveyor belt maintenance, see 'Maintenance' under 'Scalping Screen'.

Fine Sand Separation Unit Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The Fine Sand Separation Unit is meant to separate, wash and dewater all 63 to 150 micron sand from the (remaining) sediment slurry. The system uses 63 micron separators, (flat bottom) upstream classifiers, sand dewatering screens and a conveyor belt. At start-up, the dewatering screens and conveyor belt are started 'dry'. When the level in Slurry Tank No. 2 is sufficient, the feed pumps and the Fine Sand Separators are started automatically. Under normal operations, the overflow of the 63 micron separators flows into the Residue Tank. The separated sand (underflow) flows into the upstream classifier for polishing. Polished sand flows down onto the dewatering screen. A conveyor belt transports the sand to the stocking area outside of the processing building. When a pump is blocked or another part of the system is not functioning, the Fine Sand Separation will be shut down automatically. As there are two parallel treatment trains, in most situations only one treatment train will be out of order, the other treatment train still fiilly operational. When the system has been flushed with (river or municipal) water (see also descriptions above), the PLC controlled system will automatically shut down the pumps feeding the separators. When the classifiers are empty and all sand has passed the dewatering screens and conveyor belt, all items will be shut down. See 'Maintenance' under 'Coarse Sand Separafion Unit'.

Residue Tank Description The Residue Tank is meant to collect all conditioned (screened and

de-sanded) slurry. The Residue Tank is built as a circular steel tank.

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Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

At start-up, the Residue Tank will be filled with overflow material coming from the thickener separators, the coarse sand separation unit and the fine sand separation unit. Coagulant will be also be added to the Residue Tank. A flow/density measurement system will monitor the density in the tank. When the tank level reaches a certain set point, the sludge pumps are started automatically pumping the residue into the Pre-Thickener Tanks. Under normal operation, the Residue Tank will require little attention. Four pumps are used to pump the residue out of the Residue Tank. The flow of these pumps will be adjusted automatically to the flow into the Residue Tank, using level and flow monitoring. The system is able to function with only 3 of the 4 pumps available. If one of the pumps that brings material from the Residue Tank is not operating, the flow of the remaining pumps will be adjusted automatically (PLC controlled) to handle all incoming slurry. Polymer dosing per pump will also be adjusted accordingly. If the incoming flow is too high for the available number of pumps, the PLC system will shut down the system step by step. In all situations, the Overflow Tank can be used to temporarily store the incoming flow of material. When the system has been flushed with (river or municipal) water, the PLC controlled system will automatically shut down the system. For the Residue Tank this will mean that the pumps to the Pre-Thickeners will stop pumping once the incoming flow has stopped. There is hardly any maintenance expected for this Tank. The Residue Tank might be cleaned from time to time and during Winter Maintenance paint condition will be checked and improved. The flow/density measurement system needs to be checked and cleaned regularly, as the density measurement is a very important and critical factor for proper operation of the dewatering system.

Coagulant Dosing Description

Start-up

Normal Operation

Emergency operations Shutdown

Coagulant dosing is meant to improve the settlement characteristics of the sludge flow pumped into the pre-thickeners. Coagulant will be dosed into the Residue Tank, before the first stage polymer dosing. Coagulant solution will be stored in a special storage tank from where it is fed directly into the Residue tank. Dosing will be started immediately after the first sediment slurry is pumped into the Residue Tank. Under normal operation, sediment will be pumped into the Residue Tank at a more or less constant flow and density. The amount of coagulant dosed into the system will be monitored and controlled by the PLC system and is dependent on the level in and flow from the Residue Tank Not applicable. When the SDDP system has been flushed with river or municipal water, the PLC controlled system will automatically shut down the system. With no residue being pumped into the Residue Tank, coagulant dosing will be shut down automatically.

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Maintenance The coagulant dosing system needs regular control and cleaning during the operation of the SDDP, to ensure proper and ongoing dosing. The coagulant will be delivered as a solution ready for use, pumped into the Coagulant Storage Station.

Cationic Polymer Dosing ( r ' stage) Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The 1̂ ' stage Polymer Dosing is meant to prepare (dilute) and dose polymer into the residual (conditioned) sediment, to improve the settlement characteristics of the material pumped into the Pre-thickener Tanks. At start-up of the operations, polymer powder will be mixed and diluted with clean water up to a pre-set density. Diluted polymer solution will be stored in the dosing tank. In line dosing is started immediately when the first sediment slurry is pumped to the Pre-thickener Tanks. Under normal operation, sediment will be pumped into the Pre-thickener Tanks at a more or less constant flow and density. The amount of polymer dosed into the system is monitored and controlled by the PLC system and is dependent on the flow/density measurement in the Residue Tank. The capacity of the polymer dosing system is such that 3 out of 4 systems can be used to handle the expected flow. When the system has been flushed with (river or municipal) water, the PLC controlled system will automatically shut down the system. With no residue being pumped from the Residue Tank, the polymer dosing system will be shut down automatically. The dosing system will not be flushed for the weekly shutdown. The polymer dosing system needs regular control and cleaning during the operations, to guarantee proper and ongoing dosing. As the polymer powder will be delivered to the dosing station from a big bag, the empty bags will have to be changed regularly.

Pre-thickener Tank Description

Start-up

The Pre-thickener Tanks are meant to separate the (flocculated) solids in the conditioned sediment flow from free water. This separation is performed by gravity. The solids settle to the tank bottom and are transported to the center of the tank by a scraper mechanism. Supematant water leaves the tank through an overflow weir. At start-up, the Pre-thickener Tanks will be filled with sediment material pumped from the Residue Tank. Polymer will be injected and mixed in line. The amount of settled sludge on the tank bottom is measured using a level sensor.

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Normal Operation

Emergency Operation

Shutdown

Maintenance

Under normal operation, the supematant water will leave the Pre-thickener Tank through the overflow weir. Settled thickened sludge will be pumped into the Sludge Holding Tank(s). The flow of the sludge pumps depends on the sludge levels in both the Pre-thickener Tank and the Sludge Holding Tank. These levels can be optimized to certain set points by the Plant Operators, amongst other things depending on the (expected) type of sludge pumped into the SDDP. The PLC system will adjust flows and levels automatically to these set points. If the pre-thickening is not functioning correctly and the supematant water is not clear, the flow into the pre-thickeners will be stopped. The incoming flow from the dredges will be redirected into the Overflow Tank as discussed above. When the system has been flushed with (river or municipal) water and the input from the dredges has been stopped, there will be no supematant water anymore overflowing the tank weir. Depending on the length of the shut down period, the pre-thickener will be emptied by pumping all sludge to the Sludge Holding Tank(s) or the sludge will be left on the tank bottom for the next operating period. There is hardly any maintenance expected for these Tanks. The Pre-thickener Tanks might be cleaned from time to time and during Winter Maintenance a thorough check might be necessary on all moving parts (scraper mechanism).

Sludge Holding Tank Description

Start-up

Normal Operation

Emergency Operation

Shutdown

The Sludge Holding Tank is meant to store pre-thickened sludge coming from the Pre-thickener Tanks before it is pumped into the Membrane Presses. The Sludge Holding Tank uncouples the continuous operations of the pre-thickening from the batch-wise filter press operations. It also serves as a holding tank, to guarantee feed for the presses during dredge downtime or problems in the separation plant. At start-up, the Sludge Holding Tanks will be filled with sediment material pumped from the Pre-thickener Tanks. The sludge level is monitored using a level sensor. If sufficient sludge is available in the Sludge Holding Tanks, the filter press cycle may be started. Under normal operation, the Sludge Holding Tanks will be filled continuously with sludge from the Pre-Thickeners. At the beginning of every filter press cycle, sludge will be pumped from the Sludge Holding Tanks into the Presses. A level sensor will assure that a filter press cycle will not be started with insufficient sludge in the tank. If the tank level decreases in time, the flow from the Pre-thickener Tanks might be increased, depending on the set points used. As the Sludge Holding Tank serves as a buffer between the sand separation and the dewatering operations, the Filter Press operations can continue during separation unit downtime and vice versa. Depending on the length of the shut down period, the Sludge Holding Tanks will be emptied by pumping all sludge into the Filter Presses or the sludge will be left on the tank bottom for the next operating period.

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Maintenance There is little maintenance expected for these Tanks. The Tanks might be cleaned from time to time and during Winter Maintenance a thorough check might be necessary on all moving parts (mixing device).

Cationic Polymer Dosing (2"'* stage) Description

Start-up

Normal Operation

Emergency operations

Shutdown

Maintenance

The 2"'' stage polymer dosing is meant to prepare and dose polymer into the pre-thickened residual sediment, to improve mechanical dewatering characteristics of the material pumped into the Membrane Presses. At start up of the operations, polymer powder will be mixed and diluted with clean water up to a pre-set density. Diluted polymer solution will be stored in the dosing tank. In line dosing is started immediately when the first sediment slurry is pumped from the Sludge Holding Tanks into the Membrane Presses. The amount of polymer dosed into the system is monitored and controlled by the PLC system and is dependent on the flow/density measurement to the Membrane Press. Each Membrane Press operates using a dedicated Polymer Dosing Station. If a Polymer Dosing Station is not operating, the particular Press will be shut down until the dosing system is fully operafional again. The remaining Presses will handle the expected flow. When the SDDP system has been flushed with river or municipal water, the PLC controlled system will automatically shut down the system. With no pre-thickened sludge pumped into the presses, the polymer dosing system will shut down automatically. The polymer dosing needs regular control and cleaning during the operation of the SDDP, to ensure proper and ongoing dosing. As the polymer powder will be delivered to the dosing system from big bags, the empty bags will have to be changed regularly.

Membrane Press Description

Start-up

Normal Operation

Emergency Operation

Shutdown

The Membrane Presses are meant to mechanically dewater the pre-thickened slurry from the dredging and de-sanding process. Operation of the filter presses is started at the moment sufficient pre-thickened sludge for a full filter press cycle is present. Under normal operations, the membrane presses are operated cycle by cycle, 24 hrs per day. Fiher cloth washing will be performed regularly, probably once per day, to optimize the filter press performance. The filter press cycle is a fully automated process, based on a few set points related to sediment density and filter cake solid content. The filter press cycle is mainly dependant on the dewatering characteristics of the sediment, with very little options for adjustments. If the material has very poor de-watering characteristics, a relatively long squeezing period will help improve filter cake characteristics. At shutdown, the Filter Press should be emptied thoroughly and the filter cloth washed.

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Maintenance During operations very little maintenance is expected. During shutdown periods, the plates and filter cloth will be inspected and replaced if necessary. During Winter Maintenance, all moving parts will be checked and maintained, to prepare the Press for the next season.

Process Water Tank Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The Process Water Tank is meant to temporarily store process water necessary in the de-sanding and de-watering operations. At start-up the process water tank will be filled with (river or municipal) water to be able to bring process water where needed. Under normal operations, supematant water from the Pre-thickener Tanks will flow into the Process Water Tank. A part of this water will be re-used in the de-sanding and de-watering processes, excess water will be directed to the Water Buffer Tanks There is no emergency operation foreseen. With no water flowing into the Process Water Tank, level monitoring will detect a shortage of process water. The PLC system will correct this by filling the Process Water Tank with clean water from the Water Treatment Plant or will start shutting down the SDDP. There are no special conditions for shutting down the system, as the Process Water Tank is only filled with relatively clean process water. There is hardly any maintenance expected for this Tank. The Process Water Tank might be cleaned from time to time if necessary.

Water Buffer Tank Description

Start-up

Normal Operation

Emergency Operation

Shutdown

Maintenance

The Water Buffer Tanks are meant to temporarily store excess water from the Sediment Dewatering before final treatment in the WTP. At start up, the Water Buffer Tanks will be filled with excess water coming from the Dewatering System. Under normal operations, excess water from the Process Water Tank will flow into the Water Buffer Tanks. These Tanks will be used as input for the WTP. There is no emergency operation foreseen. With no water flowing into the Water Buffer Tanks, level monitoring will detect a low water level and the water treatment system will start operating at a lower capacity. There are no special conditions for shutting down the system, as the Water Buffer Tanks are only filled with relatively clean process water. There is little maintenance expected for these Tanks. The Water Buffer Tanks might be cleaned from time to time if necessary.

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8.0 SYSTEM TROUBLESHOOTING

If any portion of the SDDP is not operating properly, the Operator will be required to take steps to restore the particular part of the SDDP to its proper state of operation. This Section summarizes general actions which can be taken to troubleshoot potential problems. Troubleshooting activities will be performed in compliance with the safety guidelines in Section 5.0, Health and Safety, and applicable Federal and local safety regulations.

For the Operator to troubleshoot the proper operation of the SDDP, recognition of the safety hazards and the ability to follow safe procedures, along with the knowledge of how the equipment is supposed to function and the physical and chemical processes involved are required.

System troubleshooting will be focused on mechanical / electrical operation of the SDDP as well as on product quality.

Troubleshooting of the mechanical / electrical operation of the plant will be part of the daily work of the SDDP Operator. All portions of the SDDP and specific items will be inspected regularly and serviced weekly (see Section 9: Equipment Maintenance) to prevent plant downtime as much as possible.

Portions of the SDDP, that are difficult to reach or observe for inspection purposes will be equipped with closed circuit television (CCTV), to enable visual control from the control room. Furthermore, the plant's PLC system will alert the Operator of equipment malfunction.

Product quality troubleshooting will focus on the screening operation and separation efficiency of the plant and the performance of the membrane dewatering presses. The Boskalis Process Engineer will be assigned to coordinate this work. Input material, sand and filter cake samples will be taken regularly, to be checked for grain size distribution, total organic content and percent dry solids concentration. Misplacement (amount of sand in filter cake; amount of organic residue in sand) will be monitored, as these numbers give insight regarding the separation efficiency. Total organic content of the residue and density of the filter cake will be monitored for insight into the performance of the membrane presses.

As polymer and coagulant dosing and flocculation is most significant to the system performance, one of the Process Engineer's main tasks is to verify exactly what sediment is expected to be dredged and pumped into the system and to check necessary polymer and coagulant types and dosing levels. When floe quality and/or supematant water quality is lowered, the dosing rate and polymer or coagulant type will be checked immediately.

During operations, samples will be taken at relevant spots around the SDDP to control the sand separation and sand washing, the flocculation and pre-thickening, and the mechanical dewatering. Specific items for control are described in the table below:

Control item Misplacement of fine sand into the residue

Organics in separated and washed sand Misplacement of organic residue into the sand

Control through Grain Size Distribution

Total Organic Content

Grain Size Distribution

Location Thickener cyclones Overflow from separators Overflow from upstream classifiers Filter Cake Underflow from separators Dewatered sand Underflow from separators Dewatered sand

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Organics in residue

Flocculation and polymer/coagulant dosage

Total Organic Content

Flocculation tests Dry solids content

Pre-thickened sediment Filter Cake Residue Tank Pre-Thickener Tank Sludge Holding Tank Filter Cake

More specific equipment troubleshooting information is provided by the equipment Manufacturers' Operations and Maintenance Manuals located in Appendix D. In conjunction, this information will assist the Operator in locating and eliminating sources of dysfunction in the equipment or process operation. Should the Operator require assistance in troubleshooting, the equipment manufacturers' representatives and the Boskalis Dolman Technical Department in The Netherlands will provide the required support.

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9.0 EQUIPMENT MAINTENANCE

First and foremost, it is imperative that all operations and maintenance tasks be performed with strict adherence to the Site Health and Safety Plan. Lock-out and tag-out (LO/TO) safety procedures will be followed during all equipment maintenance in accordance with requirements specified in Section 5.0, Health and Safety. CAUTION: Maintenance work performed on exposed live electrical conductors and connections will be done by a licensed electrician using the N.F.P.A. 70 E standard. Routine service to the equipment beyond the Operator's experience, will be performed by 40 Hour trained OSHA field technicians.

Vita Automation and Van Ert Electric will provide all service needed for the CMCS. An operation and maintenance manual prepared by Vita Automation and Van Ert Electric is located on-site for general O&M by the Operator.

The SDDP should be kept in a neat and orderly condition to provide a safe and pleasant working environment. To maintain a clean and safe workplace, the Operator should create a housekeeping plan and schedule. The housekeeping tasks should include both interior and exterior work. Daily yard pickup and inside sweeping, weekly mopping, along with seasonal snow removal will be performed by plant staff

The key to good maintenance is regular and systematic inspection of all equipment. Inspection frequency and preventative maintenance is determined by the process application.

A sound program carried out by qualified individuals will greatly increase equipment reliability and productivity. The manufacturers' instmction manuals, referenced in Appendix D, Manufacturers' O&M Manuals and located on-site, must be carefully studied by the Operator before any attempt is made to service a particular piece of equipment.

Master Equipment List, Appendix D, has been created to act as a quick reference for the Operator to all necessary maintenance information. The list is an electronic spreadsheet defining all major equipment, instmments and valves with respect to part number, equipment description, vendor name and contact telephone number. To maintain and repair equipment, the proper tools must be readily available on-site. A complete list of available site tools is included as Appendix B, Tools and Equipment List. Spare parts, lubricants and other supplies necessary for routine equipment repairs and maintenance are to be stocked in the treatment plant. A spare parts inventory list is included as Appendix C, Spare Parts Inventory. Manufacturers' recommended parts constitute most of the list.

9.1 General

The SDDP is scheduled to be in operation 5 days per week, 24 hours per day, except during the start-up period during which the plant will be operated for 16 hours per day..

During operating hours, maintenance work will be limited as much as possible only to those parts that can be serviced while the plant is running. Most of the maintenance work will be limited to inspection, using inspection lists prepared by the Technical Plant Manager.

To ensure maximum plant uptime during operations, the emphasis is on preventive maintenance and not on repair work.

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9.2 Weekly Servicing and Maintenance

Based on the inspection reports, small preventive and necessary maintenance work will be scheduled on Saturdays or possibly Sundays. This will include work on items listed below:

Main Plant Operation Scalping Screen

Slurry Thickening Tank

Sand Separation

Polymer Dosing

Pre-Thickener Tank

Sludge Holding Tank

Membrane Presses

Pumps

Valves Level controls Tanks Piping

Items Screens Spray nozzles Motors and drives Bearings Conveyor belt Conveyor belt scrapers and rollers Separators Separator regulators

Separators Separator regulators Classifier valves Screens Screen motors, drives, bearings Dosing system (screw) Valves and level controls Dosing pump Polymer mixing unit Scraper mechanism Motor, drive, bearings Mixing device

Filter plates Plate shifting mechanism Filter cake discharge mechanism Filter cloth Filter cloth cleaning unit Drip tray mechanism Conveyor belt Conveyor belt scrapers and rollers Motors and drives Seals Bearings Impellers Packing, if applicable

Wear plates Hangers Wear

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9.3 Winter Shut-Down (Annual) Maintenance

To the extent possible, major (preventive) maintenance work will be scheduled during the winter shut down period. At the end of each operating season, the plant will be emptied and cleaned and prepared for maintenance. The aim is to do all necessary work to prevent downtime for maintenance activities during the next operating season as much as possible.

All items listed above in the previous section will be re-inspected and serviced. Further, the following activities will be scheduled:

Tanks

Piping

Pumps

Hydraulic components

Membrane Presses

Separation Equipment

Tanks will be inspected for wear and tear; wear plates will be replaced when necessary Piping will be inspected for wear and tear, with special attention to the sand separation plant; Pipes will be rotated and/or replaced if necessary Pumps will be checked and maintained thoroughly, to prepare for the following season Oil and filter replacement Thorough inspection of all piping and (especially) hoses All plates will be cleaned and inspected and replaced if necessary Filter cloth will be inspected and replaced if necessary All mechanisms to be checked and inspected Separation equipment will be taken apart and inspected, with special attention to the liner and the outlet regulators. All water nozzles in the classifiers will be checked; nozzles will be replaced when necessary.

9.4 Spare Parts

Sufficient spare parts will be available on or near the jobsite to enable quick repair work, to ensure that optimal plant uptime is maintained.

The type and number of spare parts are thoroughly discussed with all suppliers of the equipment in use and are depending on 1) local part availability; 2) expected life cycle of specific part; 3) relevance of specific part; 4) numbers of the specific part in the plant.

Spare part stock will be updated continuously by the Technical Plant Manager, in close cooperation with the Operator and the Boskalis Dolman Technical Department in The Netherlands.

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10.0 WASTE TRANSPORTATION AND DISPOSAL

10.1 Background

The Lower Fox River Operable Units 2-5 remedial action will result in the generation of waste materials at the Former Shell Property Staging and Material Processing Facility (Green Bay Facility). This section describes the process and methods that will be used to address the safe and compliant handling and transport of generated project wastes from the SDDP at the Green Bay Facility. The Green Bay Facility will serve as the central location for processing TSCA and non-TSCA sediments. The Facility will operate 24 hours per day, 5 days per week, Monday through Friday. Maintenance activities will be performed on Saturdays or possibly Sundays, if necessary. Wastes at the SDDP will consist of scalpings/screenings (debris/coarse fraction separated by the Wash and Sieve Dmm and the Scalping Screen), separated sand, filter cake, and used personal protective equipment (PPE). The scalpings/screenings, separated sand, and the filter cake will be classified as non-TSCA or TSCA based on an in-situ sediment characterization. The wastes will be manifested as either non-hazardous/non-TSCA waste or as TSCA waste for offsite transportation and appropriate disposal.

10.2 Waste Disposal Criteria and Methods

Before TSCA and non-TSCA wastes are transported from the Green Bay Facility, they will be sampled and analyzed as described in Sections 2 and 4 of this document and the associated QAPP Worksheets. This sampling and analysis will comply with the regulatory requirements as well as the requirements of the disposal facilities identified in Section 2 of this document.

10.3 Waste Disposal Facilities

10.3.1 Disposal Facility for TSCA Wastes

The EQ Wayne Disposal Inc. Landfill in Belleville, Michigan is the current designated facility for the disposal of TSCA wastes from the Lower Fox River Site OUs 2 to 5. The EQ Wayne Disposal Inc. Landfill operations personnel will provide Certificates of Disposal and original signed manifests to the Generator identified on the manifest no later than 30 days following receipt of the waste. Upon receipt of the Certificate of Disposal, the Generators will contact the facility to verify disposal in accordance with TSCA requirements and maintain a PCB verification Log.

10.3.2 Disposal Facility for Non-TSCA Wastes

The Veolia Hickory Meadows Landfill near Hilbert, Wisconsin is the current designated facility for the disposal of all non-TSCA wastes from the Lower Fox River Site OUs 2 to 5. Upon receipt of waste shipments, the Veolia Hickory Meadows Landfill operations personnel will sign the Special Waste Manifest Ticket and issue a weight ticket to the driver who will provide this documentation to the Green Bay Facility operations personnel.

10.4 Waste Transportation Contractor Requirements

All Waste Transportation Contractors (transporters) must use the disposal facilities identified above, or perhaps others, that have been approved in advance by Tetra Tech, the USEPA and WDNR.

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10.4.1 Qualifications

All waste transporters will be prequalified according to Tetra Tech's regulatory compliance screening process prior to being awarded a transportation subcontract to work on the project.. All drivers will have a current commercial driver's license (CDL) with HAZMAT endorsement as required. Additionally, transporters involved in shipping TSCA and non-TSCA wastes will meet the following USEPA and WDNR requirements:

Completed Notification of PCB Waste Activity submitted to USEPA as a commercial waste transporter and an assigned USEPA Identification Number (required for transport of TSCA or hazardous waste only).

Current registration with WDNR as a Hazardous Waste /PCB Waste Transporter (as applicable) or as a Solid Waste /Recyclables Transporter.

10.4.2 Tmcking Equipment

Transport vehicles brought to the Green Bay Facility will be in good operating condition and substantially free of mud or other contamination. Owners and operators of transport vehicles will be responsible for maintaining their equipment in a safe operating condition suitable for transport over public roads in accordance with applicable motor carrier safety requirements.

Transport vehicles will meet the required specifications for hauling TSCA and non-TSCA wastes. These specifications include use of covers and tight dump bodies to prevent leakage and display of the appropriate USDOT-required placards.

10.5 Waste Quantity Determination

Estimated quantities of wastes likely to be produced are presented in Section 2.2 of this document.

10.6 Shipping Documentation

Tracking and documentation of waste transport is required by the federal and state solid waste, hazardous waste, TSCA PCB, and USDOT transportation and hazardous materials regulations. Non-TSCA waste is classified as solid waste subject to the requirements in WDNR regulations (NR 500). TSCA waste is classified as PCB waste subject to the requirements in 40 CFR 761. For TSCA wastes, a Uniform Hazardous Waste Manifest and a weight ticket are required. For non-TSCA wastes, a Shipping Paper/Special Waste Manifest Ticket and a weight ticket are required.

10.7 Safety

10.7.1 Facility Safety

Facility personnel and transporters will receive training in the project-specific SHSP at the Green Bay Facility. The SHSP includes requirements for traffic control, loading/unloading operations, and site mles to follow when driving within the facility.

10.7.2 Public Road Transport Safety

Transporters of hazardous and solid waste materials will comply with applicable federal and state regulations for transportation of wastes over public roadways. These regulations include:

72 9/11/09

USDOT Hazardous Materials Requirements (49 CFR 171-397); USEPA PCB Requirements (40 CFR 761); WDOT Height/Weight, Special and Seasonal Restrictions (s. 348); Wisconsin Solid Waste Disposal Act Regulations (NR 500).

10.7.3 Landfill Facilities Safety

Transporters will adhere to the landfill-specific mles for access and unloading of wastes at the two landfills identified in Section 8.3 above. When tmcks enter the landfill facilities, drivers will be informed about and will abide by site-specific traffic control procedures for each landfill. Before exiting the facility, tmcks will be visually inspected and decontaminated as needed to remove any residue on the exterior of the tmck. The receiving landfill will coordinate and manage incoming tmck traffic such that delays and traffic impacts are minimized. Green Bay Facility operations personnel will coordinate delivery of waste with offsite landfills in advance of shipments so that they are informed about the composition, delivery method, and schedule for the waste. Waste profiles and supporting documentation (e.g., sample results) will be prepared, signed by the Generators, and forwarded to the landfills in advance of shipment as required.

10.8 Spill Response and Contingency Plan

10.8.1 Spill Procedures

The primary obligation for reporting and cleaning up a hazardous materials spill that occurs during transportation lies with the owner and operator of the tmck from which the material has been released. Tetra Tech will require that transporters of hazardous materials be familiar with the contents of the spill response and contingency plan, comply with all current mles governing the transportation, and have an emergency spill response plan in effect as part of their contract. Drivers will be trained in transportation spill response and be equipped with spill response equipment appropriate for responding to spills of TSCA and non-TSCA wastes. Such response equipment will include a shovel, bags, booms, cones, or other means to demarcate the spill area. Training will also address the general spill response objectives and procedures, which include:

Safeguard life and property Notify the proper authorities Begin containment and cleanup Follow-up with reporting.

10.8.2 Notificafion

Transporters will immediately report spills of hazardous substances in accordance with the WDNR spill reporting requirements. In addition, if a spill of 1 pound or more of PCBs occurs, it will be reported to the National Response center. Spills of greater than 10 pounds or releases of PCBs to water must be immediately reported to the appropriate USEPA Region 5 TSCA Coordinator. Additionally, any transportation incident involving hazardous materials will be reported to the USDOT as required by the regulations.

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Please print or type. (Form designed for use on elite (12-pitch) typewriter.) 0 3 Form Approved. 0MB No. 2050-0039

UNIFORM HAZARDOUS

WASTE MANIFEST

1. Generator ID Number 2, Page 1 of 3. Emergency Response Phone 4. Manifest Tracking Number

5. Generatoi's Name and Mailing Address

Generator's Phone:

Generator's Site Address (if different than mailing address)

6. Transporter 1 Company Name U.S. EPA ID Number

7. Transporter 2 Company Name U.S. EPA ID Number

8. Designated Facility Name and Site Address

Facility's Phone:

U.S. EPA ID Number

9b. U.S. DOT Description (Including Proper Shipping Name, Hazard Class, ID Number, and Packing Group (if any))

10. Containers

No. Type

11. Total Quanlily

12. Unit Wt./Vol.

13. Waste Codes

14. Special Handling Instmctions and Additional Information

15.IJ GENERATOR'S/OFFEROR'S CERTIFICATION: I hereby declare thai the contents of this consignment are tully and accurately desaibed above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects m proper condition tor transport according to applicable intematkjnal and national governmental regulations. If export shipment and I am the Primary Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.

I I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is tnje.

Generator's/Offeror's Printed/Typed Name bignature Month Day Year

16. International Shipments D Import to U.S. D ExportfromU.S.

Transporter signature (for exports only):

Port of entry/exit:

Date leaving U.S.:

17. Transporter Acknowledgment of Receipt of Materials

Signature Month Day Year Transporter 1 Printed/Typed Name

Signature Month Day Year Transporter 2 Printed/Typed Name

18. Discrepancy

18a. Dixrepancy Indication Space [ " ] Qngptjty D Type I I Residue I I Partial Rejection

Manifest Reference Number.

D Full Rejection

18b. Alternate Facility (or Generator)

Exility's Phone:

U.S. EPA ID Number

18c. Signature of Alternate Facility (or Generator) Month Day Year

19. Hazardous Waste Report Management Method Codes (I.e., codes for hazardous waste treatment, disposal, and recycling systems)

20. Designated Facility Ovmer or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a

Printed/Typed Name Signature Montfi Day Year

EPA Fonti 8700-22 (Rev. 3-05) Previous editions are obsolete. DESIGNATED FACILITY TO DESTINATION STATE (IF REQUIRED)

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NON-HAZARDOUS WASTE

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FEDERAL LAW PROHIBITS IMPROPER DISPOSAL IF FOUND. CONTACT THE NEAREST POUCE Ofl PU8UC SAFETY

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