United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/140
September 1990
« EPA
Superfund
Record of Decision
Hooker Chemical S-Area, NY
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60272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R02-90/140
4. TO* and Subtitle
SUPERFUND RECORD OF DECISION
Hooker Chemical S-Area, NY
First Remedial Action - Final
7. Auttior(a)
8. Performing Organization Name Mid Addreaa
12. Sponaoring Orginlzitlon Name and Addraaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
a. Redpienfe Accaaaion No.
S. Report Date
09/21/90
6.
8. Performing Organization RepL No.
10. Protectrraak/Work Unit No.
11. ContractJC) or Grarrt(G) No.
(C)
<0)
13. Type of Raporl & Period Covered
800/000
14.
15. Supplementary Note*
16. Abatract (Limit: 200 worda)
The Hooker Chemical S-Area site is a former landfill area located in Niagara Falls,
New York. The site lies adjacent to the Niagara River. Approximately 63,000 tons of
chemical processing wastes were disposed of at the landfill. Ground water beneath
the site also has been contaminated from aqueous phase and non-aqueous phase liquid
chemicals. Chemicals have migrated toward the Niagara Falls Drinking Water Treatment
Plant (DWTP) which lies to the east of the site, contaminating the Bedrock intake
structures. This Record of Decision (ROD) addresses the landfill, a contaminated
ground water plume, bedrock contamination, and the DWTP. The primary contaminants of
concern affecting the soil, sediment, and ground water are VOCs including PCE; and
other organics including chlorinated organics and pesticides.
The selected remedial action for this site includes abandoning in place, underground
utility and service lines; closing and capping onsite lagoons; capping the landfill
and surrounding area; constructing a site barrier wall containment system; installing
a drain tile collection system; pumping and treatment of ground water and/or leachate
• from the landfill area, overburden, and bedrock using gravity separation to separate
(See Attached Page)
NY
17. Document Analyaia a. Deacriptora
Record of Decision - Hooker Chemical S-Area,
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (PCE), other organics (chlorinated organics, pesticides)
b. Identifiera/Open-Ended Terma
c. COSAT1 Field/Group
18. Availability Statement
19. Security Claaa (Thia Report)
None
20. Security Claaa (Thle Page)
None
21. No. ol Pagea
337
22. Price
(See ANS1-Z39.18)
See Instruction* on Revene
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-90/140
Hooker Chemical S-Area, NY
First Remedial Action - Final
Abstract (Continued)
aqueous phase liquids (APLs) from non-aqueous phase liquids (NAPLs); treating APL at an
onsite carbon treatment facility with onsite discharge to a permitted outfall; treating
NAPL and any associated sediment at an onsite incinerator; monitoring ground water;
closing and demolishing part of the adjacent drinking water treatment plant, and
constructing a new drinking water treatment facility at another location. The present
worth cost for this remedial action is $117,000,000, which includes an annual O&M cost
of $2,600,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Action levels for bedrock ground water include PCE
5 ug/1 and 2,3,7,8-TCDD 0.0005 ug/1. If these levels are exceeded, operational
modifications may be implemented.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date):
NPL Rank:
Hooker Chemical S-Area
Niagara Falls, New York
USEPA Region II
51.62; 9/83
177
ROD
Date Signed:
Remedy/ies:
Capital Cost:
O & M/Year:
Present Worth:
RA; 09/21/90
Landfill; Barrier wall containment
system, drain tile collection system
and recovery wells, clay cap of
landfill, carbon adsorption
groundwater treatment, incineration of
non-aqueous phase chemicals at
Occidental Chemical Corporation's
Buffalo Avenue Plant
Water Treatment Plant: Construction of
a new drinking water treatment plant
at a new location
$ 25 Million (Landfill)
$2.6 Million annual (Landfill)
$ 50 Million (Landfill), $ 67 Million
(City Drinking Water Treatment Plant)
LEAD
Remedial/Enforcement:
Primary Contact (phone):
Secondary Contact (phone)
FE
Mark-D. Purcell, Project Manager,
WNYCS-ERRD (212) 264-6282
Kevin Lynch, Section Chief, WNYCS-
ERRD (212) 264-6194
WASTE
Type (metals/ PCB, &c) :
Medium (soil, g.w./ &c):
Origin:
Est. Quantity cu.yd.:
Volatile Organic Compounds, Pesticides
Soil and groundwater
Landfill (chemical processing waste)
63,000 tons
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK, NEW YORK 10278
LETTER OF TRANSMITTAL
TO:
FROM:
DATE: April 10, 1991
Irene Johnson
USEPA - Headquarters
401 M Street, Southwest
Washington, D.C. 20460
Mark D. Purcell, Project Manager
New York/Caribbean Superfund Branch, Western New York
Section II
SUBJECT: Consent Decree entitled "Stipulation on Requisite
Remedial Technology (RRT) Program," for the Hooker
Chemical S-Area Landfill, Niagara Falls, New York
Description
Date
Copies
1. Stipulation on Requisite Remedial
Technology (RRT) Program
Volumes I and II
9/12/90
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VOLUME I
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA, )
THE STATE OF NEW YORK, )
Plaintiffs, )
v. ) Civil Action No.
) 79-988 (JTC)
OCCIDENTAL CHEMICAL CORPORATION and )
THE CITY OF NIAGARA FALLS, NEW YORK, ) (S-Area Landfill)
Defendants. )
STIPULATION ON
REQUISITEREMEDIAL TECHNOLOGY (RRT) PROGRAM
STIPULATION
APPENDIX I - S-AREA RRT REMEDIAL PLAN
APPENDIX II - ENVIRONMENTAL HEALTH AND SAFETY
APPENDIX III - CITY DRINKING WATER TREATMENT
PLANT REMEDIAL PROGRAM
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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
THE STATE OF NEW YORK,
Plaintiffs,
V.
OCCIDENTAL CHEMICAL CORPORATION and
THE CITY OF NIAGARA FALLS, NEW YORK,
Defendants.
Civil Action No.
79-988 (JTC)
(S-Area Landfill)
STIPULATION ON
REQUISITE REMEDIAL TECHNOLOGY (RRT) PROGRAM
8/16/90
DRAFT FOR SETTLEMENT
AND REVIEW PURPOSES ONLY
SUBJECT TO APPROVAL
BY EACH PARTY
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I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
TO WHOM IT MAY CONCERN
HOOKER S-AREA
The attached "Stipulation of Requisite Remedial Technology
Program" (signed Sept. 12, 1990 by the Regional Administrator)
is for all technical purposes the equivalent of a Superfund
Record of Decision and should be so treated and entered into
the RODS System.
The document concerns the Hooker S-Area dump, listed on the
National Priorities List, making it a Superfund site. The
document contains specific remedies, making it the functional
equivalent of a ROD. The document is the result of a negotiated
settlement that began before the enactment of CERCLA and was
therefore negotiated under RCRA, the Safe Drinking Water Act,
and the Clean Water Act. There has been public comment and
the settlement also complies with all applicable and relevant
and appropriate requirements. There is a proposed remedial
action plan (although it is not part of the attached document).
This document has been included in the CERCLIS system along
with all the other RODs. This document takes the place of a
ROD and there will be no separate ROD published later.
Accordingly, the attached document is submitted for inclusion
into the RODS system.
Date / Richard L. Caspe, P.E.
f*~ Director
t Emergency and Remedial
Response Division
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CONTENTS
Page
A. INCORPORATION OF RRT STIPULATION. . . ....... 4
B. MODIFICATION .......... . ......... 5
C. COMMITMENT TO PERFORM REMEDIAL ACTIVITIES
AND TO COMPLY WITH APPLICABLE LAW ......... 7
D. SCHEDULES ..................... 7
E. CITY DRINKING WATER TREATMENT PLANT ....... . 15
F. REMEDIAL WASTE MANAGEMENT PLAN ........... 22
G. ENVIRONMENTAL HEALTH AND SAFETY PLAN ........ 30
H. ENGINEERING AND CONSTRUCTION OVERSIGHT ....... 30
I. ASSESSMENT REPORTS ................. 32
j. CWTP IMPACTS .................... 36
K. RETENTION OF RECORDS. . . ........ ..... 36
L. RESERVATION OF RIGHTS ................ 39
M. INDEMNIFICATION AND INSURANCE ...... ...... 42
N. NOTICES .............. ......... 44
0. PUBLIC PARTICIPATION ................ 46
P.. EFFECTIVE DATE ............. ...... 49
Q. EXECUTION OF RRT STIPULATION .......... . . 49
LIST OF APPENDICES
APPENDIX I — S-AREA RRT REMEDIAL PLAN
APPENDIX II — ENVIRONMENTAL HEALTH AND SAFETY PLAN
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APPENDIX III - CITY DRINKING WATER TREATMENT PLANT REMEDIAL
PROGRAM
ATTACHMENT A - PLAN A MILESTONE SCHEDULE
ATTACHMENT B - CITY DRINKING WATER TREATMENTK
PLANT CLOSURE/REMEDIAL PLAN
ATTACHMENT C - DRINKING WATER TREATMENT PLANT
CLOSURE/REMEDIAL PLAN
ATTACHMENT D - CITY DRINKING WATER TREATMENT PLANT
PROJECT COST ESTIMATE
APPENDIX IV - REMEDIAL WASTE MANAGEMENT PLAN
ATTACHMENT A - REMEDIAL WASTE TREATMENT MILESTONE
APPENDIX V - OCC S-AREA PKOJECT SCHEDULE
APPENDIX VI - INSURANCE CERTIFICATE FORM
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(1) Whereas, the parties to this action are described and
set out in Paragraph 1 of the document captioned "Stipulation and
Judgment Approving Settlement Agreement" ("Judgment"), except
that Hooker Chemicals & Plastics Corp. is now called Occidental
Chemical Corporation ("OCC"), and that all named defendants other
than OCC and the City were dismissed in consideration of
Occidental Petroleum Corporation's agreement, pursuant to the
terms and conditions of Paragraph 12 of the Judgment, to execute
a guarantee, which was filed with the Court on or about August
13, 1985;
(2) Whereas, the signatory parties to this action — EPA,
the State, tho City, and OCC — agreed and stipulated that the
settlement agreement embodied in the Judgment should be entered
and, therefore, the signatory parties signed and lodged that
document with the Court on January 10, 1984;
(3) Whereas, the Court, after a hearing, concluded that the
Judgment provides for appropriate programs to protect against
endangerment to human health or the environment in and about the
S-Area Landfill Site ("Landfill Site"), and to protect the users
of the City of Niagara Falls' drinking water from endangerment,
see Judgment, at 1-2; and that the Judgment is fair, adequate,
and consistent with public policy, United States v. Hooker
Chemical & Plastics Corp.. 607 F.Supp. 1052, 1070 (W.D.N.Y.
1985);
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(4) Whereas, the Court approved and entered that Judgment
on April 15, 1985, and the Second Circuit affirmed the approval
and entry, 776 F.2d 410 (2d Cir. 1985);
(5) Whereas, the Judgment approved and entered by the Court
provided, among other things, that OCC and the City (where
appropriate) must implement containment, monitoring and
maintenance programs at and in the vicinity of the Landfill Site,
see Judgment f 6, at 8, and Addendum I $ A; Addendum II J A,
Addendum III J A; that OCC must conduct further surveys and
studies concerning the migration of chemicals into the
environment at and in the vicinity of the Landfill Site, see
Judgment, Addendum I J B(l)(a), at 1-1; and that, if chemicals
are identified migrating from the Landfill Site in areas not
addressed by the containment system, OCC must conduct and submit
to the Governmental Parties a study to determine what Requisite
Remedial Technology ("RRT"), if any, is required to address such
chemicals, see Judgment, f 4, at 6, and Addendum I 55 B(6), B(8),
at 1-8-9, 1-13;
(6) Whereas, on or about November 1, 1988, OCC submitted to
the Governmental Parties a document captioned "Requisite Remedial
Technology Study of Chemicals in the Overburden and Bedrock,
S-Area Landfill, S-Area Remedial Program";
(7) Whereas, on or about February 28, 1989, EPA/State and
the City submitted a response to OCC's RRT Study, and OCC
subsequently submitted a rejoinder to the governments' response;
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(8) Whereas, after lengthy and comprehensive negotiations
and technical discussions, the undersigned have determined that
OCC and the City will meet their respective obligations under the
Judgment by implementing the remedial, monitoring, and remedial
waste management programs and other activities described in the
addenda and appendices to the Judgment and the RRT Stipulation
(as defined below) and that these programs and other activities
are necessary and appropriate to protect human health and the
environment, and are consistent with the goals of the Judgment;
(9) Whereas, the RRT Stipulation (as defined below)
provides that the public have an opportunity to comment on the
programs and other activities specified herein during the notice
and comment period after this RRT Stipulation's lodging with the
Court and before the parties move the Court to approve and enter
the RRT Stipulation;
NOW THEREFORE, IT IS STIPULATED, ADJUDGED, ORDERED, AND
DECREED as follows:
a*
A.
INCORPORATION OF RRT STIPULATION
1. Upon its effective date, this document captioned
"Stipulation on Requisite Remedial Technology (RRT) Program"
("RRT Stipulation") shall be incorporated into, and become
enforceable as a part of, the Judgment in accordance with
Subparagraph B(9)(c) of Addendum I of the Judgment. As used
herein, the term RRT Stipulation shall include this document and
the following appendices to this document and any attachments
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thereto: S-Area RRT Remedial Plan (Appendix I); the
Environmental Health and Safety Plan (Appendix II); the City
Drinking Water Treatment Plant Remedial Program, including the
attached Plan A and Plan B Schedules and the Drinking Water
Treatment Plant Closure/Remedial Plan (Appendix III); the
Remedial Waste Management Plan (Appendix IV); the OCC S-Area
Project Schedule (Appendix V); and the Insurance Certificate Form
(Appendix VI). All documents submitted to the Governmental
Parties and which are required to be approved by them pursuant to
the Judgment (including without limitation, any attachments,
plans, specifications, and protocols) shall also be incorporated
into and become enforceable as part of the Judgment upon
approval.
2. Unless otherwise specified herein, words and phrases
used in this RRT Stipulation shall be defined as they are in the
Judgment. To the extent that the provisions of the Judgment are
explicitly inconsistent with this RRT Stipulation, the provisions
of the RRT Stipulation shall control and the Judgment shall be
deemed to be so modified or superseded. Those provisions of the
Judgment not so modified or superseded remain in full force and
effect.
B.
MODIFICATION
3. (a) Modifications to pages 1-36 of the Judgment, pages
1-49 of this RRT Stipulation or any non-technical sections of
future stipulations or modifications that materially alter the
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addenda or appendices to those documents shall be accomplished in
written form, either by agreement of OCC and the Governmental
Parties with the approval of the Court, or by order of the Court
upon the petition of any signatory party. When agreement is
reached by the appropriate signatory parties, OCC shall promptly
file such written consent with the Court.
(b) Non-material modifications to addenda or
appendices shall be accomplished by written consent of the
Project Coordinators for OCC and the Governmental Parties.
Thereafter, OCC shall promptly file such written consent with the
Court.
(c) Modifications to any other documents approved by
the Governmental Parties, including plans, specifications and
protocols, shall be accomplished by written consent of the
Project Coordinators for OCC and the Governmental Parties.
During field activities such modifications may also be
accomplished by oral agreement of the field representatives of
OCC and the Governmental Parties, under the following
circumstances:
(i) where emergency conditions exist
at the Project Site, or
(ii) where unexpected conditions are
encountered at the Project Site and
time is of the essence.
Such oral modifications shall be confirmed in writing by the OCC
Project Coordinator to all other Project Coordinators within
three (3) working days. Such confirmations shall be deemed
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consented to unless objected to by any Project Coordinator within
five (5) working days of receipt. All modifications pursuant to
this subparagraph (c) shall be consistent with the objectives and
goals of the Judgment and good engineering practice.
(d) No oral modifications of the Judgment shall be
effective except as provided in subparagraph (c) above.
(e) All modifications made pursuant to this Section
shall be incorporated into and made enforceable as a part of the
Judgment .
(f) Nothing in this Section shall be deemed to alter
the Court's power to supervise or modify the Judgment.
C.
COMMITMENT TO PERFORM REMEDIAL ACTIVITIES
AND TO COMPLY WITH APPIJCAPLE L*jW _
4. The Governmental Parties have determined that the
activities required under this Judgment are consistent with
applicable laws and regulations. OCC and the City shall perform
their respective activities required by the Judgment pursuant to
the terms and conditions of the Judgment and in accordance with
applicable Federal, State and local laws and regulations.
D.
5. (a) The OCC S-Area Project Schedule is attached hereto as
Appendix V.
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(b) The City Drinking Water Treatment Plant Plan A
Milestone Schedule ("Plan A Milestone Schedule") (as described in
Section E herein), containing milestone dates for the financing,
permitting, design, and construction of a proposed new City
Drinking Water Treatment Plant ("CWTP11) is Attachment A to
Appendix III. During the implementation of Plan A, EPA/State may
propose that additional Milestone dates be added to the Plan A
Milestone Schedule. Such dates will be added either by agreement
of the EPA/State and the City or by order of the Court. All
documents to be submitted to the State for permits and other
authorization for the new CWTP shall also be submitted to EPA for
concurrent review and comment. Additionally, documents
constituting the Facilities Plan and Detailed Design plans and
specifications shall be submitted to EPA for concurrent review,
comment and approval as per this subparagraph. EPA's approval of
the Facilities Plan and Detailed Design plans and specifications
shall be limited to those systems and structures which, if
needed, are intended to prevent contamination of the City's
drinking water to a level of assurance equal to or greater than
the remedial programs for the existing CWTP as set forth in the
Judgment. EPA shall, within 60 days of receipt of either the
Facilities Plan or the Detailed Design plans and specifications,
provide written comments, and/or approval or disapproval to all
signatory parties. If the New York State Department of Health
has approved the Facilities Plan or the Detailed Design plans and
specifications and EPA does not provide its comments, approval or
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disapproval for the document in question within such sixty (60)
day period, that document shall be deemed approved by EPA. Any
disputes among the signatory parties concerning such EPA
comments, approval, or disapproval which cannot be promptly
resolved informally, will be submitted to the Court for
resolution.
(c) No later than 90 days after the lodging of this RRT
Stipulation with the Court, the City shall submit, for
informational purposes only, to the signatory parties a City
Drinking Water Treatment Plant Plan A Project Schedule ("Plan A
Project Schedule") detailing implementation dates for Plan A
which will be no later than the dates contained in the Plan A
Milestone Schedule. Such schedule shall be provided to all
signatory parties but will not be subject to EPA/State approval
in this proceeding; provided, however, that EPA/State reserve any
right they may have to require approvals as part of their usual
regulatory functions outside this proceeding.
(d) The City Drinking Water Treatment Plant Plan B Bar
Sequencing Schedule ("Plan B Bar Sequencing Schedule") (described
in Section E herein), containing the sequencing of, and time
frames for, the implementation of Plan B, is Attachment B to
Appendix III.
(e) No later than sixty (60) days after a determination
either by agreement of the signatory parties or by order of the
Court that Plan B shall be implemented, pursuant to Paragraph 15
of Section E, the City and OCC shall jointly prepare and submit a
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City Drinking Water Plant Plan B Project Schedule ("Plan B
Project Schedule"). The implementation dates set forth in the
Plan B Project Schedule shall be consistent with the Plan B Bar
Sequencing Schedule, unless it is determined by agreement of the
signatory parties or by order of the Court that such consistency
would be inappropriate under specific circumstances. Thereafter,
the parties shall proceed as provided in Paragraphs 6(c) and (d)
of the Judgment. After the Plan B Project Schedule is adopted
either by agreement of the signatory parties or by order of the
Court, it shall be made an attachment to Appendix III and (if
adopted by agreement) filed with the Court.
(f) The Remedial Waste Treatment Milestone Schedule
("RWTMS") is Attachment A to Appendix IV. If OCC and EPA/State
cannot resolve any dispute concerning OCC submissions or
EPA/State responses under the RWTMS within thirty (30) days, any
signatory party may seek Court resolution of any such disputes
which relate to compliance with the provisions of subparagraph
•*
5(g). If the Court decides that delay in meeting the RWTMS is
attributable to EPA/State's non-compliance with
subparagraph 5(g), then OCC's time for compliance with the RWTMS
may be extended in the Court's discretion, as appropriate. If
the Court decides that delay in meeting the RWTMS is attributable
to OCC's non-compliance with subparagraph 5(g), then OCC may be
subject to any appropriate penalty or action under this Judgment,
in the Court's discretion, as appropriate, including the
possibility of providing additional storage capacity per
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subparagraph 20(d) to meet the starting date provided by the OCC
S-Area Project Schedule for operation of Phase II remedial
systems. For purposes other than this Judgment, nothing herein
shall be construed to limit the authority or alter any legal
standard or time period of review regarding EPA/DEC processing of
OCC's incinerator permit applications, including but not limited
to the ability to require additional information or revised
submissions, and shall not limit or alter OCC's rights applicable
thereto.
(g) With respect to all the above schedules, OCC and the
City will use their best efforts to supply, in an expeditious
manner, complete permit applications and other submissions
required by this Judgment, including all information required by
EPA/State to process such permit applications and submissions.
In accordance with Paragraph 8(d) of the Judgment, EPA and the
State shall use their best efforts, consistent with their legal
authority, to expeditiously review and make timely final
determinations on permit applications and other submissions of
the City and OCC required by the.OCC S-Area Project Schedule, the
Plan B Project Schedule, the Plan A Milestone Schedule and the
Remedial Waste Treatment Milestone Schedule. The signatory
parties will take all actions, consistent with their legal
authority, to assure compliance with the aforementioned
schedules. To the extent that applicable statutory and
regulatory requirements and this Judgment provide the signatory
parties with discretion to act in a timely manner, such actions
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shall be undertaken in a manner which is consistent with the
aforementioned schedules; provided, however, that nothing herein
shall be construed to require any party hereto to act in a manner
which is arbitrary and capricious or otherwise unlawful. If any
signatory party completes an activity required under the Judgment
on a date earlier than scheduled or otherwise required, the
parties shall use best efforts to correspondingly move up
subsequent activities under the Judgment dependent on such
completed activity, to the extent practicable, consistent with
the other activities on that schedule. To the extent that the
Uniform Procedures Act, New York Environmental Conservation Law,
Article 70, is applicable to State permits required under this
Judgment, nothing herein shall alter the obligations of the New
York State Department of Environmental Conservation to meet the
requirements of that Act.
6.(a) Whenever OCC believes that revisions to the OCC
S-Area Project Schedule or its portion of the Plan B Project
Schedule should be made, OCC shall submit proposed revisions in
writing to the Governmental Parties for their respective review
and approval, as appropriate. In proposing revisions to those
Project Schedules due to any delays, including failure to obtain
timely governmental authorizations and/or approvals, OCC shall
propose only an additional amount of time necessary to perform
the activities in a professional manner and pursuant to the terms
of the Judgment. OCC's submission of proposed revisions shall be
accompanied by a report which fully explains why such revisions
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are necessary. If OCC or any signatory party has already fully
advised EPA/State or the Court of a particular period of delay
pursuant to the terms of Paragraph 8(a) or 8(c), as appropriate,
of the Judgment, then OCC may cross-reference that submission.
Proposed schedule revisions pursuant to this subparagraph shall
be reviewed by the Governmental Parties pursuant to Paragraphs
6(c) and (d) of the Judgment. Upon agreement of the Governmental
Parties and OCC or order of the Court, OCC shall promptly file
with the Court all revisions to the OCC S-Area or Plan B Project
Schedule, together with a complete explanation of the revisions.
Revisions to the RWTMS shall be addressed pursuant to
subparagraph 5(f) of this Section.
(b) Whenever the City believes that revisions to its
portion of the Plan B Project Schedule should be made, the City
shall submit proposed revisions in writing to the EPA/State for
their review and approval. At such time, the City shall also
provjde copies of such proposed revisions tp OCC. In proposing
revisions to those schedules due to any delays, including failure
to obtain timely governmental authorizations and/or approvals,
the City shall propose only an additional amount of time
necessary to perform the activities in a professional manner and
pursuant to the terms of the Judgment. The City's submission of
proposed revisions shall be accompanied by a report which fully
explains why such revisions are necessary. If the .City or any
signatory party has already fully advised EPA/State or the Court
of a particular period of delay pursuant to the terms of
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Paragraph 8(a) or 8(c), as appropriate, of the Judgment, then the
City may cross reference that submission. Proposed schedule
revisions pursuant to this subparagraph shall be reviewed by
EPA/State pursuant to Paragraphs 6(c) and (d) of the Judgment and
Section E herein. Upon agreement of the Governmental Parties and
OCC or order of the Court, the City shall promptly file with the
Court all revisions to its Plan B schedule, together with a
complete explanation of the revisions. Proposed changes to
milestone dates in the Plan A Milestone Schedule shall be
addressed pursuant to Section E.
(c) Nothing in the Plan A or Plan B Schedules shall
affect the scheduling and implementation of any activities
required pursuant to the OCC S-Area Project Schedule; provided,
however, that advancing the scheduled date for the installation
of portions of the eastern Barrier Wall that cross service lines
to the CWTP shall be evaluated, if after installation of all
other portions of the Barrier Wall and the collection systems
adjacent to 53rd Street, response actions are triggered by the
monitoring criteria for NAPL presence and inward hydraulic
gradient set forth in subsection 2.3, Appendix I of the KRT
Stipulation.
7.(a) No later than March 15, 1991, and no later than March
15 of each succeeding year, OCC will submit to all other
signatory parties and the Court a complete report describing the
progress of its activities during the previous twelve (12) months
under the Judgment and this RRT Stipulation.
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(b) On such dates, the City shall also submit to all other
signatory parties and the Court a complete report describing the
progress of its activities during the previous twelve (12) months
under the Judgment and this RRT Stipulation, including, without
limitation, its progress under the Plan A Milestone Schedule.
(c) Any signatory party may submit to the Court its own
progress report at such times as it deems appropriate, and any
signatory party may submit a response to a progress report
submitted pursuant to this Section.
E.
CITY DRINKING WATER TREATMENT PLANT
8. OCC and the City will implement activities relating to
the City Drinking Water Treatment Plant (CWTP), as described in
this Section and in Appendix III. As described below and in
Appendix III, this Program consists of the Interim CWTP
Monitoring and Response Action Plan and a plan for either (a)
construction of a new water treatment plant and closure of the
existing CWTP ("Plan A"), (b) re-lining of the raw water intake
system and other remedial actions at the existing CWTP ("Plan
B"), or (c) an alternative drinking water supply plan and closure
of the existing CWTP ("Plan C").
9. Plan A will be implemented to completion and no portion
of either Plan B or C will be implemented, unless and until a
determination is made pursuant to Paragraph 15 of this Section
that either Plan B or Plan C will be implemented.
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10. The obligations and responsibilities of the signatory
parties with respect to Plan A shall be as follows:
(a) The City shall construct and operate a
new City Drinking Water Treatment Plant ("new -
CWTP") on property located east of the
existing CWTP.
(b) The City shall use its best efforts to
initiate construction and "full-scale operation"
of the new CWTP consistent with the requirements
of the Plan A Milestone Schedule. As used herein,
"full-scale operation" is defined as the date
upon which the new CWTP has received its Completed
Works Approval from the New York State Department
of Health.
(c) The City shall use its best efforts to make
timely submission of applications and submissions,
which it believes in good faith to be complete,
relating to permits and other required governmental
authorizations and approvals, consistent with the
Plan A Milestone Schedule.
(d) The City shall obtain and/or provide financing
to build the new CWTP.
(e) OCC shall make payments to the City to help
pay for construction of the new CWTP, in accordance
with the provisions of a contemporaneous separate
agreement between OCC and the City.
(f) Upon initiation of full-scale operation
of the new CWTP or Plan C, as appropriate, OCC
and the City, will implement the Drinking Water
Treatment Plant Closure/Remedial Plan,
Appendix III, Attachment C. Any modification,
reassessment, reduction, or termination of the
plan's remedial systems or monitoring programs
shall be made as provided in Sections 5.2 through
5.5 of Appendix I.
11. Based on the fact that the Court is ordering Plan A to
be implemented pursuant to this RRT Stipulation, no environmental
impact statement and no other processing under the State
Environmental Quality Review Act, or any State or local
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regulations or enactments pursuant thereto, shall be required
regarding permits and authorizations or any other governmental
approval or action required for implementation of Plan A, or
regarding selection of the site for a new CWTP or associated
property transfers.
12. As used herein, "Plan B" will consist of the
implementation by OCC and the City of the remedial systems and
associated activities described in the following provisions of
the Judgment, as modified by Section 2.0 of Appendix III:
Paragraph E of Addendum I; Paragraphs C through I of Addendum II;
and Paragraphs C, D(l) and E of Addendum III.
13. The signatory parties have determined that the
implementation of either Plan A or Plan B, as set forth in the
Judgment, would be consistent with the goal of the Judgment to
protect the users of CWTP drinking water from endangerment.
14.(a) During the implementation of Plan A, the City shall,
or another signatory party may, promptly notify the other
*4>
signatory parties in writing in the event one of the following
circumstances occurs prior to the City's issuance of the notice
to proceed for the first major construction contract for the new
CWTP:
(i) A milestone date set forth in the Plan A
Milestone Schedule is not met or facts exist
which demonstrate a milestone date will
not be met;
(ii) Facts exist which demonstrate that full
scale operation of the new CWTP will be
delayed for at least two years beyond the date
for such operation set forth in the Plan A
Milestone Schedule, Attachment A of Appendix III,
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as a result of "force majeure" or other cir-
cumstances beyond the City's control;
(iii) Despite the best efforts of the signatory
parties, the City is not able to obtain real
property rights, permits, or other authorizations
required to construct and operate the new CWTP;
(iv) Facts exist vhich demonstrate that it is
technically infeasible to construct or initiate
operation of the new CWTP substantially as
designed; or
(v) The estimated cost for completing the project
will be "unreasonably high" and, based on this cost
estimate, the City has decided not to implement Plan
A. As used herein, such costs may be deemed
"unreasonably high" only if the product of (i) the
estimated project costs for the new CWTP (in millions
of dollars) and (ii) the estimated true interest cost
(in percent) on fixed rate debt obligations to finance
the project exceeds the following:
651 if contract award is to occur in 1992,
678 if contract award is to occur in 1993, or
705 if contract award is to occur in 1994 or
thereafter.
In estimating the project cost and the true
interest cost for the purpose of this sub-
paragraph, the same methodology shall be used
as was utilized by the City in calculating the
June, 1990 estimates, Attachment D, Appendix III.
In that attachment the City estimated that the
project cost is $67.8 million and the true interest
cost is 8.0 percent; and the product of these
parameters is 542 (67.8 x 8.0).
(b) Following the City's issuance of the notice to proceed
for the first major construction contract for the new CWTP, the
City will finance and implement the remaining portions of Plan A
to completion according to the Plan A Milestone Schedule and the
provisions of Paragraphs 14(a) and 15 shall be inapplicable;
except however, the events described in subparagraphs 14(a)(iii)
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and 14(a)(iv) shall continue to trigger notifications and actions
pursuant to Paragraphs 14 and 15 until full scale operation of
the new CWTP.
15. Within 30 days following notification that any one of
the circumstances set forth in Paragraph 14(a) has occurred, the
party providing the notice shall submit to the other signatory
parties a complete written description of the particular
circumstances and the basis upon which the notification was
given. If the signatory parties determine by agreement that a
subparagraph 14(a) circumstance has occurred, but nonetheless
Plan A should continue to be implemented, the signatory parties
shall confirm said agreement in writing and make any appropriate
revisions to the Plan A Milestone Schedule, RRT Stipulation, and
any other documents necessary to reflect such agreement.
Thereafter, the City shall promptly file such revisions with the
Court. If the signatory parties determine by agreement that a
subparagraph 14(a) circumstance has occurred and that Plan A ^
should not continue to be implemented, the signatory parties
shall confirm said agreement in writing and the City shall
promptly file said agreement with the Court. Thereafter, Plan A
shall be terminated and Plan B shall be implemented pursuant to
Paragraph 5(e) of this Stipulation, unless a Plan C is
implemented pursuant to the requirements of Paragraph 15(d). If
no such determination by agreement among the signatory parties
can be reached, any signatory party may, within 30 days following
.submission of the aforementioned written description of the
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subparagraph 14(a) event, petition the Court for a determination
that Plan A should be terminated and that Plan B or Plan C should
be implemented. It the petitioning party demonstrates to the
Court that any of the circumstances described in subparagraph
14(a) has occurred, the Court shall order that Plan A shall be
terminated and Plan B shall be implemented unless a signatory
party demonstrates to the Court that:
(a) with respect to an occurrence described in
subparagraph 14 (a) (i) that:
(i) Despite failure to meet one of the
milestone dates, the City will be able to
meet the milestone date for initiation of
full-scale operation of the new CWTP;
(ii) The city's failure to meet its
milestone date was primarily the result
of the failure of the EPA/State to use
best efforts, consistent with subparagraph
5(g), to make timely determinations on
permits, authorizations and/or approvals;
(iii) The City's failure, despite its
best efforts to meet its milestone date,
was primarily the result of the failure
to obtain approvals or authorizations
from any party other than EPA/State and
any resultant delay will be less than two years;
or
(iv) There is good cause to extend the
milestone dates for construction and
initiation of full-scale operation for a
period not to exceed two years; or
(b) Notwithstanding any occurrence described in
subparagraphs 14(a)(ii);(iii) or (iv), there is good
cause to proceed with the implementation of
Plan A and such implementation shall not cause an
unreasonably high project cost as defined in sub-
paragraph 14(a)(v), unJess the City agrees to proceed
despite such cost; or
(c) Notwithstanding the occurrence described
in subparagraph 14(a)(v), there is good cause
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to proceed with the implementation of Plan A
and the City so agrees; or
(d) The City demonstrates, that subject to
achievement of an agreement with OCC pursuant
to paragraph 16, it is willing and able
to promptly implement a Plan C to obtain
its drinking water supplies from a source other
than from the existing CWTP or the new CWTP
described in Plan A and that Plan C is:
(i) Technically and financially feasible;
(ii) Capable of being implemented and
meeting all the then-existing CWTP supply
requirements within, substantially the
same time frame as that remaining for
completion of Plan A pursuant to the
Plan A Milestone Schedule; and
(iii) Consistent with the goal of the
Judgment to protect users of the CWTP
drinking water from endangerment.
In the event the City makes such a demon-
stration pursuant to this subparagraph (d) and
reaches an agreement with OCC, pursuant to
paragraph 16, within thirty (30) days, OCC
and the City shall not be required to implement
Plan B, unless Plan C is not implemented as per
paragraph 17, below. If no such City/OCC agree-
ment is reached within thirty (30) days. Plan B ~
shall be implemented pursuant to Appendix III,
unless the City demonstrates to the Court that
despite not having reached an agreement with OCC,
Plan C will be implemented as per the time
requirements of subparagraph 15(d)(ii).
15. OCC shall have no obligation with respect to Plan C,
other than its obligations under the CWTP Closure/Remedial Plan,
unless it enters into a separate agreement with the City, which
sets forth specific obligations with regard to Plan C. Any
disputes arising regarding the achievement, interpretation or
implementation of such agreement which OCC and the City cannot
promptly resolve .informally will be submitted to the Court for
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resolution. Any such agreement shall not affect the obligations
of the City and OCC, as appropriate, under this Judgment.
EPA/State shall have no financial obligations with regard to Plan
C; provided, however, that this provision will not be construed
to affect the City's eligibility for any otherwise-available
State or federal assistance.
17. If the Court determines pursuant to Paragraph 15(d)
that Plan C shall be implemented and if an agreement pursuant to
Paragraph 16 between OCC and the City has been achieved, the city
shall promptly implement such plan in accordance with the Court's
order.
18. The Interim CWTP Monitoring and Response Plan set forth
in Appendix III, Section 3.0 will be undertaken until either (a)
the initiation of full-scale operation described in Plan A; (b)
the installation and initial operation of remedial systems
described in Plan B; or (c) the provision of a satisfactory
drinking water supply pursuant to Plan C, whichever first occurs.
•V •
F.
REMEDIAL WASTE MANAGEMENT PLAN
19. (a) All solid, semi-solid, and liquid waste generated
as a result of programs and activities described in the Judgment
shall be managed as described therein, as modified by the RRT
Stipulation and Appendix IV and in accordance with the Remedial
Waste Treatment Milestone Schedule attached thereto.
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(b) Except as provided herein below and in
Paragraph 20, OCC shall initiate operation of remedial systems as
provided in the OCC S-Area Project Schedule. However, nothing in
the Judgment shall be construed to require OCC to:
(i) install or operate remedial systems
which generate solid or semi-solid wastes
until a waste cell(s) at the Landfill Site,
as described in Appendix IV, has been
constructed by OCC and approved by EPA/State
to accept such wastes;
(ii) conduct Phase I remedial activities
described in Section 4.3 of Appendix I until
the APL/NAPL Storage Facility described in
Appendix IV has been constructed and has
received written governmental authorization
to accept liquid wastes;
(iii) operate remedial systems which
generate liquid wastes until (a) the APL/NAPL
Storage Facility has been constructed and has
received written governmental authorization
to accept such wastes, and (b) the APL
Carbon Treatment Facility has been
constructed by OCC per approvals by EPA/State
and authorized by the appropriate parties, at
that time, to discharge effluent from the
facility. (Nothing herein modifies any EPA
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authority to regulate such discharge to the
City waste water treatment plant under U.S.
v. Citv of Niagara Falls. Civ. No. 81-
\
363 (C».
20. The starting operation date for the remedial systems
which generate NAPL (other than Phase I activities described in
Section 4.3, Appendix I) shall be governed by the OCC S-Area
Project Schedule and by the determinations, activities, and
conditions relating to the storage and treatment of NAPL as set
forth in this Paragraph.
(a) OCC's existing incinerator at its Niagara Plant
("OCC Liquids Incinerator") is currently permitted to incinerate
certain process and remedial hazardous liquid wastes. OCC has
also applied for governmental authorizations to construct and
operate a thermal destruction unit at its Niagara Plant ("OCC
Solids Incinerator") to incinerate hazardous solid wastes
generated at OCC-associated remedial sites in Western New York.
OCC shall submit revised applications for permit modifications to
allow incineration of liquid remedial wastes, including S-Area
NAPL, at the OCC Solids Incinerator in accordance with RWTMS
Schedule C. If these incinerators are determined, separately or
in combination, to have sufficient capacity and be capable of
incinerating NAPL generated by activities under the Judgment in
accordance with all applicable permitting requirements designed
to protect human health and the environment, EPA and the State
have agreed with OCC that these incinerators will be the
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preferred facilities for the incineration of NAPL generated by
activities under this Judgment; provided, however, as follows:
(i) The foregoing preference shall not be
construed to limit or delay OCC's obligations
described in subparagraphs (b) or (c) below
or to preclude utilization of available
capacity at permitted facilities described in
subparagraph (c) for the incineration of NAPL
generated by activities under the Judgment,
if, separately or in combination, the OCC
Liquids Incinerator and/or the OCC Solids
Incinerator are unavailable to accept NAPL
from the remedial system as provided in the
OCC S-Area Project Schedule;
(ii) The foregoing preference shall be
terminated if, following either the
assessment described in subparagraph (b)
=«
below or the EPA/DEC determination on OCC's
application for approval to incinerate S-Area
NAPL (Item A5 of the RWTMS) it is determined
that, separately or in combination, the OCC
Liquids Incinerator and/or the OCC Solids
Incinerator do not have technical capability
or sufficient capacity to incinerate NAPL in
accordance with applicable permitting
requirements;
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(ill) Termination of the preference
described in subparagraph (ii) shall not be
construed to limit or delay the obligations
of any party under Paragraph 5(g).
(b) Within 90 days following completion of the Phase I
pump tests as provided by the OCC S-Area Project Schedule, OCC
shall submit to EPA/State an assessment report described in this
subparagraph. The purpose of this assessment is to evaluate
whether there will be sufficient incineration capacity authorized
by permit and, if such capacity is not available by the date for
initiation of operation of Phase II remedial systems provided by
the OCC S-Area Project Schedule, when and by what means OCC will
obtain sufficient capacity to treat NAPL to be generated by
activities under the Judgment. Such assessment shall also
consider, among other things, the characterization and the
projected volumes of NAPL to be generated by remedial systems
installed under the Judgment and by other sources of liquid
remedial waste which OCC plans to incinerate; and the permitted
projected capacity of the OCC Liquids Incinerator, the OCC Solids
Incinerator and permitted storage facilities .to treat or store
NAPL to be generated by activities under the Judgment. If this
assessment indicates that, separately or in combination, OCC's
Liquids Incinerator and/or OCC's Solids Incinerator will not be
available or will not have sufficient capacity for treating
S-Area NAPL generated by activities under the Judgment by the
scheduled start of operation of remedial systems that will
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generate NAPL, OCC shall/ by the scheduled start date, have
available 316,000 gallons of NAPL storage (inclusive of NAPL
storage provided pursuant to Section 4.4.6(a) of Appendix IV) to
allow for start-up of the Phase II remedial system.
(c) If it is determined (either under the subparagraph (b)
assessment or under Item A5 of the RWTMS) by agreement of OCC and
EPA/State or by order of the Court that there will not be
sufficient permitted incineration capacity to accommodate NAPL
generated by activities under the Judgment within six months
after scheduled initial remedial system operation start-up, or
within the period of time for which there will be available NAPL
storage capacity, whichever is longer, OCC shall proceed as
described in this subparagraph (c). OCC will conduct an
assessment which evaluates obtaining NAPL treatment capacity from
among the following alternatives:
(i) a commercial incinerator permitted by EPA and the
State;
(ii) an on-site mobile incinerator able to be permitted or
authorized by EPA and the State; or
(iii) on-site pre-treatment and subsequent incineration at
an incinerator permitted or authorized by the State.
M t
As part of that assessment, OCC shall also include
evaluation of the following:
(i) Subject to subparagraph (d) below, installation of
additional storage capacity.
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(ii) Deferral of scheduled start-up of remedial system
operations or start-up of remedial system operations
under modified conditions (including modified
performance monitoring criteria).
(iii) Some combination of the five alternatives set forth
above.
The assessment report shall be submitted to EPA/State within 90
days after the aforementioned determination. The report shall
include proposed milestone dates for obtaining sufficient NAPL
treatment capacity from the alternative(s) recommended in the
assessment. Upon EPA/State approval of the assessment report,
the RWTMS Schedule D shall be amended to include milestone dates
to implement such alternative(s). Once the RWTMS is amended
pursuant to this subparagraph, OCC shall proceed with best
efforts to expeditiously obtain sufficient treatment capacity,
pursuing those alternatives set forth in subparagraphs (a) and
(c) on parallel paths according to the schedules for those
alternatives under the RWTMS unless otherwise agreed to by
EPA/State or ordered by the Court.
(d) If it is determined by agreement of EPA/State and OCC
or by order of the Court that NAPL storage capacity beyond
316,000 gallons installed pursuant to subparagraph (b) is
reasonable and necessary to satisfy the goals of the Judgment,
the total combined APL/NAPL storage capacity will be increased to
a maximum of 948,000 gallons. In installing APL/NAPL storage up
to 948,000 gallons, OCC shall also reevaluate the APL Treatment
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Facility operational needs and the APL storage installed pursuant
to Section 4.4.6(a) of Appendix IV. Based on that evaluation,
the amount of APL storage may be reduced or increased, as
appropriate. Additional APL/NAPL storage capacity, beyond
948,000 gallons, may be ordered by the Court, in its discretion,
only if it determines that delays in the RWTMS were the result of
OCC's unjustified non-compliance with its obligations under
Paragraph 5(g) and the RWTMS. Likewise, if the Court determines
that NAPL treatment capacity is unavailable and that
unavailability is the result of EPA/State's unjustified non-
compliance with its obligations under paragraph 5(g) and the
RWTMS, the scheduled date for initial remedial system operations
may be extended by such time period as the Court deems
appropriate, in its discretion.
(e) If, following submission of the assessment reports
described in subparagraphs (b) and (c) and the resolution of all
issues relating thereto, it is determined, by agreement of OCC
and EPA/State or by order of the Court, that none of the
alternatives set forth in subparagraphs (a) and (c) can or will
be implemented by December 31, 1995, OCC shall submit to
EPA/State an assessment described in this subparagraph. This
assessment will include an evaluation of the availability of
permitted incineration, its performance equivalent, and treatment
facilities other than those described in subparagraph (c) and the
installation of additional storage capacity notwithstanding the
limitation described in subparagraph (d). OCC's assessment
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report shall be submitted within 90 days following the
aforementioned determination. The appropriate action to be taken
thereafter will be determined by agreement of EPA/State and OCC
or order of the Court and shall be consistent with the goals of
the Judgment.
G.
ENVIRONMENTAL HEALTH AND SAFETY PLAN
21. The Environmental Health and Safety Plan set forth in
Addendum V of the Judgment shall be applicable to activities
(other than Plan A; Plan C; and activities on the Eastern Portion
of the Treatment Plant, as defined in Appendix III, Section 4.0)
undertaken pursuant to the Judgment, except as modified pursuant
to Appendix II of this RRT Stipulation.
H.
ENGINEERING AND CONSTRUCTION OVERSIGHT
22. All the design and construction work to be performed by
OCC under the Judgment shall be under the direction and
supervision of a qualified professional engineer licensed and
currently registered to practice in the State of New York.
Within 30 days of the lodging of this RRT Stipulation, OCC shall
notify the Governmental Parties in writing of the name, title,
and qualifications of the engineer who will be responsible for
directing or supervising such work. EPA/State, by written notice
to OCC, may disapprove any such engineer based upon professional
qualifications and other reasonable and appropriate criteria.
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EPA/State's approval shall not be unreasonably withheld. Nothing
in this Section shall preclude OCC from hiring a field manager,
who does not meet the above engineering requirements, provided
that the field manager is otherwise qualified and is under the
direction and supervision of a qualified engineer who meets the
licensing and registration requirements of this Paragraph. At
least 30 days prior to the commencement of remedial system
construction activity, OCC shall provide the name and
qualifications of OCC's selected field manager.
23. At least 30 days prior to the commencement of each
construction activity identified on the OCC S-Area Project
Schedule, OCC shall notify the Governmental Parties, in writing,
of the name and qualifications of any civil, mechanical or well
drilling contractor who has been retained to perform or
participate in any portion of such work. EPA/State, by written
notice to OCC, may disapprove any such contractor(s) based upon
professional qualifications and other reasonable and appropriate
criteria. EPA/State's approval shall not be unreasonably
withheld.
24. Except if previously set forth in the OCC S-Area
Project Schedule, OCC shall give the Governmental Parties at
least 14 days advance notice of all field activities (including,
without limitation, sampling activities, but not including
routine operational and maintenance activities) to be performed
pursuant to the Judgment. If it is not possible for OCC to give
at least 14 days advance notice, OCC shall provide written
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notice to the Governmental Parties on the earliest working day
possible.
25. OCC shall, following the installation of each remedial
system described in the Judgment, provide the Governmental
Parties with a certification from a licensed professional
engineer currently registered to practice in the State of New
York that the system was installed in conformance with the plans
and specifications and any approved revisions for that work.
I.
ASSESSMENT REPORTS
26. Whenever the Judgment requires OCC to assess a
situation or condition (other than a study conducted pursuant to
Paragraph B(8), Addendum I of the Judgment) or conduct a focused
feasibility study, OCC shall submit an assessment report pursuant
to the provisions of Paragraphs 27 through 32 of this RRT
Stipulation unless otherwise specified in Appendix I or Appendix
III.
27. Each assessment report shall be prepared in accordance
with appropriate professional standards and shall include,
without limitation, the following:
(a) a title sheet and a table of contents;
(b) a complete statement of why the assessment
report is required, including a clear statement
of the problem addressed;
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(c) a complete discussion of how the assessment
was performed, including assumptions made and the
technical and computational methods and procedures
used for all assessments;
(d) all data used in the assessment and an
explanation of how the data was collected; or,
in the alternative, reference to the data .if
that data was previously provided;
(e) a description and evaluation of all action (s.)
analyzed;
(f) all conclusions drawn by the assessment;
(g) a recommendation for actions, if any, to be
taken;
(h) a complete discussion of the basis for OCC's
recommendation;
(ij estimated implementation costs of any action(s)
(including no-action alternatives) recommended
in the assessment report; and
(j) an implementation schedule for all recommended
actions.
(k) an assessment report for a focused feasibility
study shall evaluate all applicable alternatives
utilizing the same criteria used to evaluate the
recommended alternative and shall report such
evaluation in a fashion that allows for a full
comparison between alternatives.
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28. Unless submission of an assessment report is otherwise
scheduled, or unless notification is first provided by the
Governmental Parties/ OCC shall notify the Governmental Parties
in writing within 7 days after determining that an assessment
report is required by the Judgment. OCC shall complete and
submit an assessment report to the Governmental Parties within 30
days after such notification, unless otherwise specified.
29. The Governmental Parties shall review each submitted
assessment report and, within 30 days, notify OCC in writing of
its agreement or disagreement with the assessment or the
assessment report. In the case of disagreement, the Governmental
Parties will provide the basis for that disagreement -- including
a complete statement of the disagreement, assumptions made, data
used, analyses performed, and conclusions drawn — and, in the
discretion of the Governmental Parties, may provide a
recommendation for action by OCC.
30. If the Governmental Parties notify OCC either that the
•*
assessment or the assessment report is incomplete or otherwise
fails to comply with this Section, or that the Governmental
Parties disagree with the report's conclusions, OCC shall revise
the assessment report to address the Governmental Parties'
concerns and recommendations and shall resubmit the report,
within 21 days of receipt of the Governmental Parties' response.
In the alternative, OCC may, by the required resubmittal date,
petition the Court to resolve the dispute.
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• 31. Upon receiving OCC's revised assessment report/ the
Governmental Parties shall within 30 days of receipt of OCC's
revised assessment report, notify OCC in writing of their
position regarding the revised report. If the Governmental
Parties do not approve the revised assessment report the
Governmental Parties will provide a recommendation for what is
required to address their concerns and a complete discussion of
the basis for their recommendations. If the Governmental Parties
do not approve the revised report (or portions of the revised
report), OCC shall promptly implement the Governmental Parties'
recommendation unless, within 14 days following receipt of the
Governmental Parties' response to the resubmitted report, OCC
petitions the Court to resolve the dispute.
32. Prior to the submittal of any assessment report or
during any review period any signatory party may request that
informal meetings or negotiations be held within the specified
time frames. Furthermore, the time frames for submittals, review
•w
and approval specified in this Section may be extended by
agreement of OCC and the Governmental Parties or order of the
Court, for good cause shown.
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J.
CWTP IMPACTS
33. Whenever the Judgment requires OCC to:
(a) conduct an assessment or focused feasibility study
of Operational Modifications, System Modifications and
supplements, Monitoring Program Reassessments and Modifications,
System Operation Reductions, or Terminations; or
(b) conduct an RRT Study or focused RRT Study;
the impact of any alternative actions analyzed upon the existing
CWTP remedial systems, structures, underground pipelines or
utilities shall be included in the assessment. If the existing
CWTP remedial systems, structures, underground pipelines or
utilities may be adversely affected by the proposed actions
pursuant to such assessment study, OCC shall include in its
assessment an evaluation of measures designed to eliminate or to
mitigate, as appropriate, such impacts. The Governmental Parties
shall consider these impacts and any proposed measures in their
review and approval process for any proposed actions.
K.
RETENTION OF RECORDS
34. (a) Except as provided in subparagraphs (b) or (c)
below, following the lodging of this RRT Stipulation, each
signatory party shall keep, as "Retained Records," all data,
records, documents and information of any kind which are in, or
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which nay cone into, its possession or control and which provide
information on or relate to:
(i) the disposal or presence of chemicals
in, or the migration of chemicals at or
from, the Landfill Site;
(ii) any analysis or evaluation of actual
or potential health or environmental
impacts due to the disposal, presence,
or migration of chemicals at or from
the Landfill Site;
(iii) geology, hydrogeology, remediation, or
regulation of the Landfill Site, and
(iv) any activity in the Area of Concern (AOC)
required under the Judgment,
regardless of any document retention policy to the contrary. As
used herein, Retained Records shall include, without limitation,
originals, and duplicate copies with informational marks or.
notations or microfiche or microfilm of originals, whether
privileged or non-privileged. A party shall, upon written
request of any other signatory party, make available for
inspection and copying any non-privileged Retained Records and
identify privileged Retained Records, as per subparagraph (d) of
this Section, within fourteen (14) days of such request, except
where the party with Retained Records is otherwise specifically
required to provide such material under other provisions of the
Judgment.
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(b) A party nay at any tine destroy Retained Records
which have been photocopied, microfilmed, microfiched or
duplicated using equivalent techniques provided that ninety (90)
days prior notice is given to all other signatory parties and
that upon request such parties are afforded the opportunity to
take custody of any non-privileged Retained Records proposed for
such destruction, and all privileged Retained Records proposed
for destruction have been identified as per subparagraph (d) of
this Section.
(c) A party may, after May 1, 2000, destroy Retained
Records which are at least ten (10) years old provided that at
least ninety (90) days prior notice is given to all signatory
parties and that upon request such parties are afforded the
opportunity to take custody of such non-privileged Retained
Records; and all privileged Retained Records proposed for
destruction have been identified as per subparagraph (d) of this
Section. If such Retained Records consist of OCC's "as-built"
drawings of remedial systems described in the Judgment, OCC shall
submit such drawings to EPA without a request having been made.
(d) Any signatory party shall have the right to
contest the validity of any other party's assertion that certain
Retained Records are privileged. The party claiming a privilege
shall produce, upon request of another signatory party, a list of
such Retained Records with sufficient information about those
records to permit an evaluation of the validity of the assertion
of privilege.
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L.
RESERVATION OF RIGHTS
35. The signatory parties hereto acknowledge that OCC is
undertaking certain surveys and investigations regarding chemical
migration from areas of its Niagara Falls Buffalo Avenue Plant,
(separate from the surveys and investigation undertaken for the
Landfill Site) pursuant to the requirements contained in permits
issued by EPA and the State and pursuant to a stipulation
approved by this Court in the State of New York and Henry G.
Williams. Commissioner of Environmental Conservation of the State
of New York v. Occidental Chemical Corporation, et al.. Civil
Action No. 83-1393. OCC is also required to take appropriate
remedial action, in response to such chemical migration.
EPA/State reserve all rights in the aforementioned proceedings to
require that any identified plumes from the Landfill Site not
addressed by remedial systems under this Judgment which commingle
with Buffalo Avenue Plant Site plumes be addressed in conjunction
with those Plant Site plumes under the Buffalo Avenue Plant Site
remedial programs, as appropriate. Furthermore, EPA/State
reserve all rights in the aforementioned proceedings to require
that Buffalo Avenue Plant Site remedial programs, otherwise
installed pursuant to those proceedings, be operated in a manner
which address chemicals migrating in an identified plume from the
Landfill Site where such action is Requisite, as defined in
Paragraph 4 of the Judgment, or where such migration triggers
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response actions developed to address Buffalo Avenue Plant Site
plumes.
36. Similarly, nothing herein is intended to preclude the
signatory parties from assessing the effectiveness of remedies
implemented under the Buffalo Avenue Plant Site remedial programs
in meeting the goals of the Judgment and the objectives of the
remedial systems implemented at the Landfill Site pursuant to
this RRT Stipulation, or from petitioning this Court to modify
the Judgment/ in accordance with applicable lav, based on the
results of any such assessment. If OCC proposes such a
modification to the Court, it shall first prepare an assessment
report for the Governmental Parties pursuant to Section I of this
RRT Stipulation. OCC may not move to modify the Judgment
pursuant to this Section until:
(i) the Site Containment System and RRT
Overburden Containment System as set forth
in Appendix I, Section 2.0 have been installed
and are operating, and
(ii) the Bedrock System (including the Prototype
and/or Bedrock RRT System) described in the
Judgment has been installed and operating for
at least ten (10) years after initial operation
of the Prototype System.
37.(a) EPA/State have determined that any presently known
or reasonably anticipated conditions which are associated with
chemicals that have migrated from the Landfill Site into the
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Bedrock beneath the Niagara River will be addressed by the
remedial programs, associated response actions, monitoring
programs, assessments and studies described in the Judgment. If
new data or information reveal conditions associated with these
chemicals which have migrated into the Bedrock beneath the
Niagara River which are not presently known or could reasonably
be anticipated by EPA/State, and if those conditions are not
adequately addressed pursuant to the Judgment, EPA/State reserves
its rights under Paragraph ll(c)(i) of the Judgment to seek
appropriate relief, including requiring OCC to study and/or
remediate such conditions.
(b) This subparagraph (b) is subject to the provisions
of subparagraph (a), including specifically, but not limited to,
the EPA/State reservation of rights under Paragraph ll(c)(i) of
the Judgment. Implementation of all the requirements and
activities of the Judgment and the RRT Stipulation shall satisfy
OCC's obligations under Paragraphs B(6)(a) and (b) of Addendum I
of the Judgment. Except as provided in subparagraphs E(9)-(14),
Addendum I of the Judgment and in the Drinking Water Treatment
Plant Remedial/Closure Plan (see RRT Stipulation, Appendix III,
Attachment C), OCC shall not be required pursuant to this
Judgment (including the RRT Stipulation) to install wells, take
samples, or conduct surveys in the Bedrock beneath the Niagara
River. Any RRT study, associated actions, or operational or
system modifications which may be required pursuant to the plans
and programs described in the Judgment shall not include
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technologies which require installation in or beneath the Niagara
River, or which address the issues described in subparagraph
(7)(a) of Addendum I of the Judgment.
38. All signatory parties reserve their rights to assert
any rights or make any arguments that otherwise may be available
to them prior to the date on which this RRT Stipulation is signed
by the parties; provided/ however, nothing herein shall modify
any explicit waiver, discharge, or release set forth in the
Judgment approved by the Court in 1985, including but not limited
to, those set forth in Paragraphs 3(b) and 11 of that Judgment.
39. To the extent that any signatory party reserves rights
pursuant to this Section, all other signatory parties reserve all
rights and defenses relating thereto.
M.
INDEMNIFICATION AND INSURANCE
40. OCC agrees to defend, indemnify and hold harmless the
United States and the State (including their officers, agents,
employees, contractors and subcontractors or representatives) for
any and all claims and causes of action asserted against the
United States or the State, arising from or on account of
tortious acts or omissions of OCC, its officers, directors,
employees, contractors, subcontractors or any persons acting on
its behalf or under its control in carrying out activities
pursuant to the Judgment. OCC shall not hold out the United
States or the State as a party to any contract entered into by or
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on behalf of OCC in carrying out obligations pursuant to this
Judgment. OCC shall not be considered an agent of the United
States or the State for any purpose under the Judgment.
41. OCC waives, and agrees to defend, indemnify and hold
harmless the United States and the State, in respect to any
claims for damages or reimbursement from the United States or the
State (or for set-off of any payments made or to be made to the
United States or the State) arising from any agreement or
arrangement between OCC and another party arising out of OCC's
obligations under the Judgment, including but not limited to
claims arising out of construction delays.
42. Within 20 days after the effective date of this RRT
Stipulation and thereafter so long as activities under the
Judgment require, OCC shall name the United States and the State
as additional insureds on OCC policies for comprehensive general
liability and automobile insurance which are applicable to OCC
activities in Western New York. Such policies shall contain
liability limits no less than those specified on the Insurance
Certificate Form (Appendix VI). Within 30 days after the
effective date of this RRT Stipulation, OCC shall submit to
EPA/State a certificate of such insurance. OCC shall resubmit to
EPA/State such a certificate if the previously submitted
certificate becomes inoperative. In addition, for so long as
activities under the Judgment require, OCC shall require that its
contractors and subcontractors satisfy all applicable laws
regarding provision of workers compensation insurance for all
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persons performing activities on behalf of OCC in furtherance of
this Judgment.
N.
NOTICES
43. Written notices, reports or other documents referenced
in the Judgment shall be sent to the following individuals at the
addresses specified below (unless those individuals or their
designated successors give written notice of a change of
identities or addresses to the other signatory parties) where
such documents (a) are required to be submitted to the Court or
to the signatory parties pursuant to the Judgment; (b) relate to
modifications or proposed modifications to the Judgment described
in Paragraph 3(a) and written confirmations pursuant to 3(c)
supra; (c) provide notice of delays in the performance of work
required under the Judgment; or (d) relate to disputes under the
Judgment which are under discussion by counsel for the parties or
under consideration by the Court. All other written notices,
««
reports, and other documents referenced in the Judgment may be
forwarded only to the Project Coordinators at the addresses set
forth below, and, in those instances, the Project Coordinators
will take responsibility for assuring that all such documents are
appropriately disseminated.
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a. As to -the United States;
1 copy: Chief, New York/Caribbean Superfund Branch
Office of Regional Counsel
U.S. Environmental Protection Agency, Region II
26 Federal Plaza, Room 437
New York, N.Y. 10278
Attention: S-Area Attorney
5 copies: Chief, New York/Caribbean Compliance Branch
Emergency and Remedial Response Division
U.S. Environmental Protection Agency, Region II
26 Federal Plaza, Room 747
New York, New York 10278
Attention S-Area Site Project Coordinator
1 copy: Chief, Special Litigation Branch
Office of Enforcement-Superfund (LE-134S)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Attention: S-Area Attorney
b. As to the State;
4 copies: Director
Bureau of Western Remedial Action
Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
Attention: S-Area Site Project Coordinator
2 copies: Director
Bureau of Environmental Exposure Investigation
New York State Department of Health
2 University Place
Albany, New York 12203
1 copy: New York State Department of Law
Environmental Protection Bureau
120 Broadway
New York, New York 10271
Attention: S-Area Attorney
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c. As to OCC;
5 copies: Mr. John Nichter
S-Area Project Coordinator
Special Environmental Programs
Occidental Chemical Center
360 Rainbow Boulevard South
P.O. Box 728
Niagara Falls, New York 14302
1 copy: J. Alan Mack, Esquire
Associate General Counsel
Occidental Chemical Corporation
5005 T-R-T Freeway
Dallas, Texas 75244
d. As to the City;
3 copies: Mr. John R. Westendorf
S-Area Project Coordinator
City of Niagara Falls Water Treatment Plant
53rd Street & Buffalo Ave.
P.O. Box 69
Niagara Falls, New York 14302
1 copy: Michael B. Gerrard, Esquire
Berle, Kass & Case
45 Rockefeller Plaza
New York, New York 10111
O.
PUBLIC PARTICIPATION
44. Court approval and entry of this RRT Stipulation are
subject to the public participation requirements set forth in
this Section. The consent of EPA and the State to this RRT
Stipulation is on the condition that an opportunity be afforded
persons (natural or corporate) who are not signatories hereto to
comment on the RRT Stipulation. Promptly after the filing of the
RRT Stipulation by the parties, notice of the filing will be
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provided in the Federal Register and copies of the RRT
Stipulation will be made available to the public at the EPA
Public Information Office, Carborundum Center, Suite 530, 345
Third Street, Niagara Falls, New York 14303, and at the
Department of Environmental Conservation, Region 9 Office,
Buffalo, New York. EPA and the State may withdraw or withhold
consent to this RRT Stipulation, or propose modifications to the
RRT Stipulation, if comments received disclose facts or
considerations that indicate that the RRT Stipulation is
inappropriate, improper, or inadequate. EPA/State will receive
public comments for sixty (60) days after the date the RRT
Stipulation is filed with the Court. Within sixty (60) days
thereafter, EPA/State will respond in writing to public comments
received during the comment period and submit any public comments
received and responses to those comments to the Court. Within
ten (10) days of that submission, EPA/State will advise the Court
by letter or motion whether they wish to withdraw from, to
<*>
withhold consent to, to propose modifications or to move to have
the RRT Stipulation entered and incorporated into the Judgment.
45. In the event that EPA/State withdraws or withholds its
consent to the entry of this RRT Stipulation, or proposes
modifications to the RRT Stipulation, the signatory parties shall
promptly initiate discussions relating to the comments received
or to any proposed modifications to the agreement embodied in the
lodged RRT Stipulation and shall notify the Court and the public
of these discussions. In the event that the signatory parties
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are able to agree to the proposed modifications within 30 days of
the date of notification of the Court pursuant to this paragraph,
they shall lodge the RRT stipulation, as modified, with the
Court. In the event that the signatory parties are unable to
agree to any proposed modification within said 30 days the RRT
Stipulation lodged with the Court shall be deemed withdrawn, null
and.void, and shall be inadmissible in this or any other action;
however, nothing herein shall preclude agreement between OCC and
the Governmental Parties that certain portions of the RRT
Stipulation shall become effective. In the event that the RRT
Stipulation is deemed withdrawn, in whole or in part, the
Judgment which was approved and entered in 1985, together with
any stipulations filed with the Court pursuant to that Judgment,
shall continue to have full force and effect, and any disputes
shall be resolved by the Court.
46. The 60-day public comment period may be extended by
EPA/State for an additional 30 days, in their discretion, and if
prior to the granting of such extension, EPA/State notifies the
Court of its intent to grant the extension. The 30-day period
for discussing any proposed modifications may. be extended by
agreement of the signatory parties, with prior notification to
the Court, or by order of the Court.
47. OCC and the City consent to the entry of this RRT
Stipulation, unless the withdrawal or modifications provisions of
Paragraphs 44 and 45 become applicable, without further notice.
- 48 -
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p.
EFFECTIVE DATE
48. The effective date of this RRT Stipulation shall be the
date on which it is entered by the United States District Court
for the Western District of New York. The activities set forth
in any applicable schedule or in any revised schedule to be filed
pursuant to Section D shall not be affected by the effective date
of this RRT Stipulation or by the pendency of any appeal from
such entry, unless the Court orders otherwise.
Q.
EXECUTION OF RRT STIPULATION
49. This RRT Stipulation nay be executed in two or more
identical counterparts, each of which shall be deemed an
original, but all of which together shall constitute one and the
same instrument. The parties represent to the Court that counsel
of record have authority to signify the parties' consent and
approval of this RRT Stipulation, subject to the provisions of
Section 0, above, by signing below.
UNITED STATES OF AMERICA
UNITED STATES DEPARTMENT OF JUSTICE
By:.
RICHARD STEWART
Assistant Attorney General
Land and Natural Resources Division
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By:
DENNIS C. VACCO
United States Attorney
Western District of New York
MICHELE GIULIANI
TriaA Attorney - Environmental
Enforcement Section
- 50 -
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U.S. ENVIRONMENTAL PROTECTION AGENCY
-------
STATE OF NEW YORK
By:.
ROBERT L. OSAR
Assistant Attorney General
NEW YORK STATE DEPARTMENT OF LAW
EDWARD 0. SULLIVAN-J
Deputy Commissioner
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Commissioner
NEW YORK STATE DEPARTMENT OF HEALTH
• 52 -
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CITY OF NIAGARA FALLS
' - • ;
By; ;/'.-/ ..•/ //
MICHAEL 0 • LAUGHLIN
Mayor
Bv:
CARL E. MOORADIi
Corporation Counsel
By;
MICHAEL B. GERRARD
BERLE, KASS & CASE
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OCCIDENTAL CHEMICAL CORPORATION
By:_
fc*
THOMAS H. TRUITT
KEITH S. WATSON
PIPER & MARBURY
By; ffNtt^JUx
LOUIS NIZER
MARTIN B. WASSER
PHILLIPS, NIZER, BENJAMIN,
KRIM & BALLON
By:
DMTfD K. FLOYD /
PHILLIPS, LYTLE, HITCHCOCK,
ELAINE & HUBER
Dated: September 12, 1990
ENTER:
Stipulation is hereby approved in
accordance with the foregoing.
UNITED STATES DISTRICT JUDGE
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APPENDIX I
S-AREA RRT REMEDIAL PT.AN
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
2 . 0 OVERBURDEN REMEDIAL SYSTEMS 1-3
2.1 SITE CONTAINMENT SYSTEM 1-3
2.1.1 OBJECTIVES 1-3
2.1.2 REMEDIAL SYSTEM 1-3
2 . 2 OVERBURDEN RRT SYSTEM 1-10
2.2.1 OBJECTIVES 1-10
2.2.2 REMEDIAL SYSTEM 1-10
2 .3 OVERBURDEN MONITORING PROGRAM 1-15
2.3.1 NAPL MONITORING 1-15
2.3.2 OVERBURDEN HYDRAULIC MONITORING.. 1-18
3.0 CAPPING 1-22
3.1 1-22
3.2 1-22
4 . 0 BEDROCK RRT SYSTEM 1-24
4.1 OBJECTIVES 1-24
4 .2 PHASED APPROACH 1-24
4.3 PHASE I - INITIAL TESTING OF
SHALLOW BEDROCK (Top 30 Feet)........... 1-25
4.3.1 NAPL RECOVERY TESTING 1-25
4.3.2 HYDRAULIC TESTING
APL/NAPL CONTAINMENT 1-26
4.4 PHASE II - PROTOTYPE BEDROCK SYSTEM 1-27
4.4.1 PROTOTYPE BEDROCK SYSTEM
(Shallow Bedrock) 1-27
4.4.2 PROTOTYPE BEDROCK SYSTEM
(Intermediate and Deep
Bedrock Zones) 1-40
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Paoe
4.5 PHASE III - BEDROCK RRT SYSTEM
(Shallow Bedrock, Intermediate/
Deep Zones) 1-43
4.5.1 REMEDIAL SYSTEM 1-43
4.5.2 MONITORING PROGRAMS 1-45
5.0 REMEDIAL SYSTEM -
RESPONSE ACTIONS, REASSESSMENTS, ETC 1-57
5.1 Procedures Regarding Response Actions... 1-57
5.1.1 Operational Modifications 1-57
5.1.2 System Modifications and
Supplements 1-60
5.1.3 RRT Study 1-64
5.2 Monitoring Program Reassessment
and Modification 1-65
5.2.1 Reassessment 1-65
5.2.2 Modification 1-65
5.3 System Operation Reduction 1-65
5.4 Termination 1-68
5.5 City Review and Approval
Responsibilities 1-70
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- RRT PFMRHfAL PLAN
1.0 INTRODUCTION
A. To attain the goals of the Judgment and the RRT
Stipulation, OCC shall design, install, operate, maintain and
monitor the RRT remedial systems to remediate chemicals within
the Landfill Site and chemicals which have migrated beyond the
Landfill Site and beyond areas addressed by other remedial
systems described in the Judgment, as described in this
Remedial Plan.
B. The RRT remedial systems described in this
Remedial Plan consist of the following:
0 Site Containment System
0 Overburden RRT System
0 Bedrock RRT System
C. The design objectives of the Site Containment
System are: (1) to contain APL and NAPL; (2) to maximize the
collection of NAPL within the Site Barrier Wall (as defined
below) at the Landfill Site; and (3) to minimize the migration
of chemicals toward the City's Drinking Water Treatment Plant
(hereinafter "CWTP"). Subject to Section 1.0.F. below, the
Site Containment System will be operated to attain these design
objectives.
D. The design and remedial objectives of the
Overburden RRT System are: (1) to contain APL and NAPL within
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1-2
the existing S-Area Overburden NAPL plume; and (2) to collect
NAPL outside the Site Barrier Wall to the maximum extent
practicable. Subject to Section 1.0.F. below, the Overburden
RRT System will be operated to attain these objectives.
E. The design and remedial objectives of the Bedrock
RRT System are: (1) to contain APL and NAPL within the
existing S-Area Bedrock NAPL plume; (2) to prevent further NAPL
migration in the bedrock under the Niagara River; and (3) to
collect NAPL within this plume to the maximum extent
practicable. The Bedrock RRT System will be operated to attain
these objectives.
F. The Bedrock RRT System will be operated to attain
its objectives even if doing so prevents maintaining the
specified upward hydraulic gradients into the Site Containment
and Overburden RRT Systems.
G. The design and operating objectives of the City
Drinking Water Treatment Plant Remedial Program as set forth in
Appendix III of this RRT Stipulation are to prevent chemicals
which have migrated from the Landfill Site from entering the
CWTP water supply structures and service lines in order to
protect the users of the City of Niagara Falls' drinking water
from endangerment and to minimize structural impacts on CWTP
pipelines, utilities, buildings, or other CWTP structures due
to remedial activities.
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1-3
2.0 OVKKBURDEN
2.1 SITE CONTAINMENT SYSTEM
2.1.1 OBJECTIVES
The design objectives of the Site Containment System
are: (1) to contain APL and NAPL; (2) to maximize the
collection of NAPL within the Site Barrier Wall (as defined
below) at the Landfill Site; and (3) to minimize the migration
of chemicals toward the CWTP. Subject to Section I.O.F., the
Site Containment System will be operated to attain these design
objectives.
2.1.2 REMEDIAL SYSTEM
A. Installation;
Al. The Overburden area at the Landfill Site will be
addressed by a remedial system (Site Containment System),
consisting of barrier walls (Site Barrier Wall)/ a drain tile
system (Tile Collection System), seven Overburden (Site
Containment) purge wells installed in Confining Layer
Discontinuities and a cap. The Site Barrier Wall shall consist
of a slurry wall on the west/ north, and east. These
components/ except the cap, are shown on Figure 1. The Site
Barrier Wall refers to those portions of the Overburden Barrier
Walls (as defined in Section 2.2.2.B1) located north of the
Industrial Intake Pipe Trench (IIPT).
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1-4
A2. Site Barrier Wall:
(a) The Site Barrier Wall shall be installed at
least one foot below the top of the Confining Layer; provided,
however/ that in the event any routes of chemical migration are
identified which are expected to pass under the Site Barrier
Wall in the Overburden after Hydraulic Stabilization (as
described in Sec. 4.4.1.A3), the depth of the Site Barrier Wall
shall be lowered so as to intercept any such routes in the
Overburden. If the Site Barrier Wall traverses a Confining
Layer Discontinuity, it shall be installed to a depth and in a
manner which will assure the integrity and intended function of
the Site Barrier Wall.
(b) The Site Barrier Wall shall consist of
material or materials at least two feet wide having a maximum
permeability of 1 x 10 cif?/sec, or its performance
equivalent. Prior to submission of plans and specifications
concerning the Site Barrier Wall, OCC shall conduct an
accelerated test of any material it intends to use to
demonstrate to what extent, if any, the permeability of the
material will be affected by chemicals in the adjacent
Overburden. The results of such testing and all underlying
data related thereto shall accompany OCC's submission of plans
and specifications concerning the Site Barrier Wall.
A3. Tile Collection System;
(a) The Tile Collection System shall be located
and installed in a manner which will maximize the containment
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1-5
of APL and NAPL located within the Site Barrier Wall. The Tile
Collection System drain which is adjacent to the Industrial
Intake Pipe Trench (IIPT) shall be hydraulically connected to
the bedding of the IIPT in such a manner as to allow collection
of APL and NAPL from the IIPT bedding.
(b) The Tile Collection System shall be
installed at least to the top of the Confining Layer; provided,
however, that it shall be installed to a depth which will
maximize the collection of NAPL located within the Site Barrier
Wall. If the Tile Collection System traverses a Confining
Layer Discontinuity, it shall be installed to one foot above
the top of Bedrock. The drain tile shall be sloped toward Wet
Well A at a minimum grade of 0.5%.
(c) OCC shall promptly submit to the
Governmental Parties plans, specifications and protocols for
the accelerated compatability testing of all permanent
materials, (e.g.. pipe, filter fabric) associated with Tile
Collection System installation that OCC intends to use to
demonstrate to what extent, if any, the material will be
affected by chemicals in the adjacent overburden.
Implementation of the testing program shall commence
immediately following the Governmental Parties approval of the
plans, specifications and protocols. The results of such
testing and all underlying data related thereto shall accompany
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1-6
OCC's submission of plans, and specifications concerning the
Tile Collection System.
A4. Site Containment Purge Wells:
The Site Containment Purge Wells shall be located
approximately as shown on Figure 1. The wells shall be
installed in such a manner and to such depths as to meet the
objectives set forth in Section 1.0.
A5. Cap;
The Landfill Site shall be capped in accordance
with the provisions of the Waste Management Plan and Section
3.0 herein.
A6. Underground Utilities:
Underground utility and service lines located
within the perimeter of the Site Barrier Wall shall be
abandoned in place. Whenever a utilit* or service line
previously abandoned or to be abandoned pursuant to this
subparagraph crosses the Site Barrier Wall, OCC shall remove
that portion of such line crossing the Wall, seal the ends of
each line remaining in place by plugging with appropriate
grouting material, or its performance equivalent, and backfill
the trench from which such portion was removed. If
appropriate, utility and service lines abandoned pursuant to
this subparagraph shall be replaced by installations above
ground or outside the Site Barrier Wall. The 003 storm sewer
outfall shall be relocated to the alignment shown on Figure 1.
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1-7
A7. Laaoons:
OCC shall terminate the operation and use of the
existing lagoons, and the area encompassed by the existing
lagoons shall be capped and closed in accordance with Section
3.0 and the Waste Management Plan.
B. Operation?
Bl. The Tile Collection System and seven Site
Containment purge wells will be operated to achieve an inward
gradient across the Site Barrier Wall, except in those areas
where the installation or operation of the CWTP or RRT systems
make the achievement of such inward gradients impracticable.
In those areas where an inward gradient is not achieved, any
migration of S-Area APL and NAPL will be addressed by other
installed remedial system(s).
B2. The Tile Collection System will be operated to
maximize an upward gradient across the Confining Layer within
the area encompassed by the Site Barrier Wall such that the wet
well water level is maintained at the lowest drain tile invert
elevation at the wet well.
B3. The static water table elevation of each Site
Containment Purge/Recovery Well measured after Hydraulic
Stabilization as defined in Subsection 4.4.1.A3, will be used
to determine the need for Site Containment Purge/Recovery Well
operation. If the static water table elevation at a Site
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1-8
Containment Purge/Recovery Well is greater than one foot above
the top of the Clay/Till Layer, or Bedrock where no Clay/Till
Layer exists, and a nine foot upward head differential does not
exist at that well, then that Site Containment Purge/Recovery
Well will be operated to maintain the pumping water level in
the well at one foot or less above the Clay/Till Layer or top
of Bedrock where no Clay/Till Layer exists.
C. NAPL Recovery-Testing and Operation;
Cl. Identification of Wells for Testing: Thirty days
after the installation of the 7 Site Containment System
purge/recovery wells, each well that encounters NAPL during
installation will be tested to evaluate NAPL recovery potential.
C2. Recovery Testing Procedure: When testing
purge/recovery wells, the objective will be ~o evaluate the
capability of the well to produce NAPL and to define
operational requirements needed to maximize NAPL recovery.
Initially, each purge/recovery well that encounters NAPL upon
installation will be pumped for APL and NAPL at the maximum
rate achievable (to a maximum of 5 gal/min) for a duration of
five days. The test will be conducted to quantify the ratio of
NAPL to APL produced as a function of time. The radius of well
influence on NAPL will also be evaluated for the overburden
wells that are tested. No additional new wells will be
installed solely for the purpose of evaluating the radius of
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well influence. Test results will be evaluated during each
well test, and upon approval by the Governmental Parties, the
pump rates and duration will be varied to enhance the
effectiveness of the test.
C3. Operation of NAPL Recovery Wells: Based on the
results of the NAPL recovery testing, any well shown to be
capable of producing reasonable amounts of NAPL will be
operated in such a manner as to recover NAPL to the maximum
extent practicable. In evaluating whether the amount of NAPL
which can be recovered by a well is reasonable, the following
factors will be considered:
Ratio of NAPL to APL collected
Depth of NAPL in a well
Volume of water pumped to recover NAPL
Radius of well influence
Production decline
Use of non-continuous pumping, i.e..
periodic pumping of NAPL.
Any well which is shown not to be capable of producing
reasonable amounts of NAPL and which is not being pumped
pursuant to Subsection 2.I.2.B. or 2.2.2.C. will be monitored
as described in Section 2.3.1.
Based on the results of the NAPL recovery
testing, OCC will, within 30 days of test completion, identify,
subject to the Governmental Parties approval, which wells will
be operated as NAPL recovery wells and how and when those wells
will be operated to maximize NAPL recovery.
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2.2 OVERBURDEN RRT SYSTEM
The Overburden area outside the Site Containment
System will be addressed by the RRT system (Overburden RRT
System) described below.
2.2.1 OBJECTIVES
The design and remedial objectives of the
Overburden RRT System are: (1) to contain APL and NAPL within
the existing S-Area Overburden NAPL plume; and (2) to collect
NAPL outside the Site Barrier Wall to the maximum extent
practicable. Subject to Section I.O.F., the Overburden RRT
System will be operated to attain these objectives.
2.2.2 REMEDIAL SYSTEM
A. Introduction;
This Section addresses the installation,
operation and testing of the components of the Overburden RRT
System.
B. Installation:
Bl. The Overburden RRT System shall consist of
barrier walls south of the Site Barrier Wall and the Robert
Moses Parkway (RRT Barrier Wall), drain tiles/ Grout Plugs
installed across the Industrial Intake Pipe Trench (IIPT) and
Robert Moses Parkway (RMP), Overburden RRT Purge/Recovery
Wells, and a cap. These components, except the cap, are shown
on Figure 1. The Site Barrier Wall and RRT Barrier Wall are
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referred to collectively in this Plan as the Overburden Barrier
Walls.
B2. RRT Barrier Wall:
(a) The RRT Barrier Wall refers to that portion
of the Overburden Barrier Wall located south of the Site
Barrier Wall. The approximate location of the RRT Barrier Wall
is shown on Figure 1.
(b) All design and installation requirements
specified for the Site Barrier Wall under Subsection 2.1.2
shall apply to the design, installation and performance of the
slurry wall portion of the RRT Barrier Wall.
B3. Drain Tiles;
Drain tiles shall be designed and installed in
accordance with the criteria specified for the Tile Collection
System drain tiles under Subsection 2.1.2. The location of the
drain tiles shall be approximately as shown on Figure 1.
B4. Grout Plugs:
(a) Grout Plugs shall be installed across the
IIPT and RMP at the location where these facilities are
intersected by the centerline of the RRT Barrier Wall/ as shown
on Figure 1.
(b) The depth to which the Grout Plugs are
installed shall be in accordance with the criteria specified
for Site Barrier Wall installation under Subsection 2.1.2.
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(c) The Grout Plugs shall be installed by a
prescriptive grouting program designed and implemented to allow
for maintenance of the hydraulic gradients specified under
Subsection 2.2.2.C. Once the Governmental Parties-approved
prescriptive grouting program has been implemented the
installation of Grout Plugs shall be deemed complete.
(d) OCC shall promptly submit to the
Governmental Parties plans/ specifications and protocols for
the accelerated testing of grout material associated with Grout
Plug installation that OCC intends to use. The objective of
the accelerated testing is to demonstrate to what extent, if
any, the permeability of the grout material will be affected by
chemicals in the adjacent overburden. Implementation of the
testing program shall commence immediately following the
Governmental Parties approval of the plans, specifications and
protocols. In lieu of such testing, OCC may promptly submit
technical documentation that adequately demonstrates, subject
to the Governmental Parties approval, the appropriateness of
grout material for use in the prescriptive grouting program
defined in this Section 2.2.2.54. The results of such testing
and all underlying data related thereto shall accompany OCC's
submission of plans and specifications concerning the Grout
Plugs.
B5. Overburden RRT Purge/Recovery Well Systems;
(a) Two Overburden purge/recovery well systems
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will be installed as shown on Figure 1. These systems will
consist of:
(i) a well system consisting of six wells
located immediately south of the HPT and
north of the RMP; and
(ii) a well system consisting of ten wells,
including nine wells located south of the
RMP and one well located north of the RMP
and east of the HPT.
(b) The Overburden RRT Purge/Recovery Wells
shall be installed in such a manner and to such depths as to
meet the objectives set forth in Section 1.1.
B6. Cap;
The Overburden RRT System area shall be capped in
accordance with the provisions of Section 3.0 herein.
C. Operation;
Cl. The Overburden RRT purge/recovery well system
will be operated to achieve:
(a) an inward gradient, across the RRT Barrier
Wall and grout plugs on the west, south and east; and
(b) an upward gradient within these walls and
grout plugs, as described in Section C2. below.
C2. Each RRT purge/recovery well will be operated to
maintain an inward gradient and/or to increase the upward
gradient cited in Subsection Cl. above, if, after Hydraulic
Stabilization (as defined in Subsection 4.4.1.A3.), but no
later than 12 months after start of operation of both the Tile
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Collection System and the Prototype Bedrock System, any of the
following conditions exist:
(a) an inward gradient does not exist across the
RRT Barrier Wall or the grout plugs shown on Figure 1;
(b) static water levels in any of the six wells
adjacent to the IIPT are higher than one foot above the
Clay/Till Layer, or the Bedrock where no Clay/Till Layer
exists, and there is less than a nine foot upward head
differential from the Bedrock;
(c) static water levels in any of the ten
remaining wells which are installed in the defined areas with
less than three feet of Confining Layer are higher than one
foot above the Clay/Till Layer and there is less than a nine
foot upward head differential from the Bedrock; or
(d) static water levels in any of the ten
remaining wells which are installed in the defined areas of
greater than three feet of Confining Layer are higher than one
foot above the Clay/Till Layer and indicate no net upward
gradient from the Bedrock.
D. NAPL Recovery Testing in the Overburden RRT
Puroe/Recoverv Wells;
Dl. Identification of Test Wells: Thirty days after
the 16 P.RT purge/recovery wells are installed, each well that
encounters NAPL during installation will be tested by pumping
to evaluate NAPL recovery potential.
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D2. Recovery Testing Procedure: When testing
purge/recovery wells, the objective will be to evaluate the
capability of the well to produce NAPL and to define
operational requirements needed to maximize NAPL recovery. The
testing for NAPL recovery by Overburden RRT purge/recovery
wells will be as described in Section 2.1.2.C2, infra.
D3. Operation of NAPL Purge/Recovery Wells: Based on
the results of the NAPL recovery testing, any well shown to be
capable of producing reasonable amounts of NAPL will be
operated as described in Section 2.1.2.C3, infra.
2.3 OVERBURDEN MONITORING PROGRAM
2.3.1 NAPL MONITORING
A. Monitoring Objective;
The objective of the Overburden NAPL Monitoring
Program (ONP) is:
0 to evaluate the NAPL recovery by the
Site Containment and Overburden RRT
Systems and to facilitate the selection
and/or addition of Overburden wells to
be pumped for NAPL recovery pursuant to
Section 2.3.I.C.
0 to assess whether the S-Area Overburden
NAPL plume is contained within the
Overburden Barrier Walls.
B. Program Implementation;
Bl. Each purge/recovery well within the Overburden
Barrier Walls will be evaluated for NAPL recovery as follows:
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0 Monitoring will be initiated at the
same time as Overburden Hydraulic
Monitoring (see Subsection 2.3.2.B1.
below).
0 Quarterly frequency.
0 Each well pumped solely for the purpose
of NAPL recovery will be monitored for
the following:
NAPL and APL production rates
(measured);
NAPL/APL ratio (calculated);
NAPL production decline
(calculated);
Volume of water pumped to recover
NAPL (measured); and
radius of well influence
calculated and/or measured.
0 Wells not being pumped will be
monitored for depth of NAPL.
52. The cumulative volume of NAPL recovered by the
Overburden RRT purge/recovery well system will be monitored and
calculated monthly.
B3. Piezometers outside the Overburden Barrier Walls
will be monitored for NAPL presence as follows:
0 Monitoring will begin one year after
completion of the Overburden Barrier
Walls.
6 Annual frequency.
0 Each of the nine Overburden piezometers
outside the Overburden Barrier Walls
will be visually inspected for NAPL
using hand bailing to the bottom of the
piezometer (or a performance equiva-
lent) .
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C. Response Actions;
Cl. During the ONP, an Overburden NAFL recovery
test/ as per Subsection 2.1.2.C2., will be conducted on any
Overburden purge/recovery well where:
0 ONP monitoring indicates NAPL in any
previously non-NAPL bearing,
non-pumping well.
0 The level of NAPL in a NAPL-bearing
well which is not being pumped
increases to pumpable levels between
ONP monitoring observations.
If any well is shown by the pump test to be
capable of recovering reasonable amounts of NAPL (as defined in
Section 2.1.2.C3.)/ it will be operated as described in Section
2.1.2.C3.
C2. Any Overburden purge/recovery well which is being
operated solely for the purpose of NAPL recovery will be shut
off if it is no longer recovering reasonable amounts of NAPL
based upon the considerations stated in Subsection 2.1.2.C3.
However, that well will continue to be subject to monthly ONP
monitoring, and, if the NAPL level increases to pumpable levels
between monitoring observations, the NAPL will be pumped out.
If the well is determined to be capable of producing a
reasonable amount of NAPL, operation of the well will be
reinitiated as described in Subsection 2.1.2.C3.
C3. One year after initiation of ONP monitoring, the
selection of Overburden Wells which are being pumped for NAPL
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recovery will be assessed. OCC shall submit this assessment to
the Governmental Parties within 30 days.
C4. As a result of the assessment, additional
Overburden wells for NAPL recovery will be installed if data
indicate that such wells would collect reasonable amounts of
NAPL (as described in Subsection 2.1.2.C3).
C5. If ONP monitoring indicates NAPL presence in any
piezometer immediately outside the Overburden Barrier Walls,
OCC will proceed pursuant to Section 5.1.1 to determine what
Operational Modifications (as defined in Section 5.1.1) to the
Overburden RRT System and/or the Site Containment System are
required to contain NAPL.
C6. If further ONP monitoring indicates that the
action taken pursuant to Subsection C5. above is not effective
in containing NAPL within the existing Overburden NAPL plume,
OCC will proceed pursuant to Section 5.1.2.
2.3.2 OVERBURDEN HYDRAULIC MONITORING
A. Monitoring Objective; ......
The objective of the Overburden Hydraulic Monitoring
Program (OHP) is to evaluate the effectiveness of the Site
Containment System and the Overburden RRT System in maintaining
inward gradients across the Overburden Barrier Walls and upward
gradients into the Site Containment System and Overburden RRT
System from the Bedrock.
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B. Program Implementation;
Bl. OHP monitoring frequency will be as follows:
0 Water level monitoring will begin no
more than 90 days after the start of
operations of the Site Containment and
Overburden RRT Systems;
0 Monthly frequency/ except that one
Overburden well, one Bedrock well, and
water level in the Niagara River will
be monitored continuously. The wells
to be continuously monitored may be
changed from time to time.
B2. Water levels to calculate inward gradients will
be monitored using the following wells and piezometers:
0 four piezometers inside and six
piezometers outside the eastern,
northern and western portion of the
Overburden Barrier Walls, as shown on
Figure 4.
0 a piezometer placed on each side of the
three grout plugs near the middle of
each of the plugs.
0 Niagara River (stilling well)
0 Any of the purge/recovery wells
installed immediately north of the
Niagara River which are not operated
for NAPL recovery or water level
reduction.
B3. Water levels to calculate upward gradient will be
monitored using the following wells, shown conceptually on
Figure 4:
0 12 maintenance piezometers;
0 23 purge/recovery wells in the
Overburden, and
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0 21 Shallow Bedrock wells selected from
those wells that presently exist.
Where existing wells become unusable, new wells will be
installed.
B4. An assessment of OHP monitoring procedures and
well locations will be initiated one year after the start of
operation of the Site Containment and Overburden RRT Systems
and submitted to the Governmental Parties within 60 days after
initiation of the assessment.
C. Response Actions;
Cl. If OHP monitoring indicates that an inward
hydraulic gradient is not being achieved across the Overburden
Barrier Walls in an area not influenced by any other installed
overburden remedial system(s), OCC will proceed pursuant to
Section 5.1.1 to determine what Operational Modifications (as
defined in Section 5.1.1) are required either to achieve the
specified gradients or otherwise contain NAPL and APL in the
affected area. Such measures may include increased pumping
and, if necessary, installation of additional wells and/or
drain tiles to draw down the overburden water table as required
to maintain specified inward gradients across the Overburden
Barrier Walls.
C2. If further OHP monitoring indicates that the
action(s) taken pursuant to Cl., above, are not effective in
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maintaining inward gradients across the Overburden Barrier
Walls,- OCC will proceed pursuant to Section 5.1.2.
C3. If OHP monitoring indicates that upward gradients
specified in Subsection 2.2.2.C between the Bedrock and
Overburden are not being achieved/ OCC will proceed pursuant to
Section 5.1.1 to determine what Operational Modifications (as
defined in Section 5.1.1), are required to achieve the
specified gradients. For the Site Containment System, such
Operational Modifications may include increasing the pumping
rates or other operational changes to existing wells, but shall
not include installation of new wells. For the Overburden RRT
System/ such Operational Modifications may include, among
others, increased pumping rates or other Operational
Modifications (as defined in Section 5.1.1) to drawdown the
overburden water table within the RRT Barrier Walls.
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3.0 CAPPING
3.1 The areas at and around the Landfill Site will be
capped as follows:
(a) The area within the Site Barrier Wall west
of the existing 003 Outfall alignment will be capped with clay
or asphalt and may be used in the future as a storage or
parking area.
(b) The area within the Site Barrier Walls east
of 53rd Street shall be asphalted and may be used in the future
as a storage or parking area.
(c) The area south of the northern (westbound)
lanes of the RMP may be capped to reduce infiltration.
(d) The area within the Site Barrier Wall north
of Adams Avenue shall be capped with asphalt or concrete and
mi/ be used in the future as an area for storage of APL and
NAPL generated by remedial activities required by the Judgment
or the Stipulation.
(e) All other areas within the Overburden
Barrier Walls will be capped as described in Section 3.2.
3.2 Except as provided in Section 3.1, all other
areas within the Overburden Barrier Wall will be capped as
follows:
(a) The cap shall consist of clay and have a
_7
maximum permeability of 1 x 10 cm/sec. The clay cap shall
consist of a minimum of three feet of clay, an 18-inch layer of
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silty soil or loam, and a six-inch layer of topsoil seeded with
native vegetative growth. All areas capped with clay shall be
crowned by the construction of one or more apexes, each of
which slopes at a minimum of 5% grade toward a surface drainage
system having a minimum of 0.5% grade.
(b) The following actions shall be taken
concerning the cap to verify compliance with design
specifications:
(i) before installation, the clay to be
used for the cap shall be tested; permeabilities
at various soil compaction densities shall be
determined; and the density required to attain a
maximum permeability of 1 x 10~7cm/sec. shall
be identified;
(ii) during installation, the clay used for
the cap shall be evaluated before it is placed to
insure the material meets specifications; and the
compacted density in each six-inch layer shall be
tested to insure it meets requirements to attain
the specified permeability; and
(iii) after installation, six undisturbed
samples (Shelby Tubes) shall be collected at
representative locations and density tested; the
thickness of the clay cap and topsoil also shall
be verified at these six locations; and the holes
created in accordance with this subparagraph
shall be appropriately plugged and the cap
restored.
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4.0 BEDROCK RRT SYSTfcJf
NAPL and APL in the Bedrock at and around the Landfill
Site will be addressed by the RRT System (Bedrock RRT System)
described below.
4.1 OBJECTIVES
The design and remedial objectives of the Bedrock RRT
System are: (1) to contain APL and NAPL within the existing
S-Area Bedrock NAPL plume; (2) to prevent further NAPL
migration in the Bedrock under the Niagara River; and (3) to
collect NAPL within this plume to the maximum extent
practicable. The Bedrock RRT System will be operated to attain
these objectives. The Bedrock RRT System will be operated to
attain its objectives even if doing so prevents maintaining the
specified upward hydraulic gradient? into the Site Containment
and Overburden RRT Systems.
4.2 PHASED APPROACH
The design, installation, operation and monitoring of
the Bedrock RRT System will proceed in a three-phased approach:
Phase I - Initial Testing of Shallow Bedrock
Zone.
Phase II - Design, Installation, Operation
and Monitoring of Prototype
Bedrock System in the Shallow,
Intermediate and Deep Bedrock
Zones.
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Phase III - Design, Installation, Operation
and Monitoring of Bedrock RRT
System in the Shallow,
Intermediate and Deep Bedrock
Zones.
Three zones within the Bedrock are defined for the RRT System:
Shallow Zone: Top 30 feet of Bedrock
Intermediate Zone From the bottom of the
Shallow Zone to 30 feet above
the top of the Gasport
Formation
Deep Zone: From 30 feet above the
Gasport Formation down to the
top of the Rochester Formation
4.3 PHASE I - INITIAL TESTING OF SHALLOW BEDROCK (Top 30
Feet)
4.3.1 NAPL RECOVERY TESTING
A. A network of eleven recovery wells which are
designed to maximize NAPL collection will be installed into the
top 30 feet of the Bedrock (Shallow Bedrock) as shown on Figure
2 and subsequently tested. Testing will be designed to evaluate
the capability of wells to recover NAPL and to define
operational requirements. Initially, each well will be pumped
for APL and NAPL at the maximum rate achievable (to a maximum of
5 gal/min) for a duration of five days. The test will be
designed to quantify the ratio of NAPL to APL collected as a
function of time.
B. Test results will be evaluated during each well
test and the pump rates and duration may be varied to enhance
the effectiveness of the test and to determine the most
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effective operation to maximize the collection of NAPL.
Modifications to the initial test procedure may be made, subject
to approval by the Governmental Parties. After completion of
the recovery testing, all data generated by the testing will be
evaluated and used to design the NAPL recovery component of the
Prototype Bedrock System.
4.3.2 HYDRAULIC TESTING - APL/NAPL CONTAINMENT
A. A second network of eight Shallow Bedrock purge
wells, which are intended to effectively characterize the
hydraulic properties of the Bedrock, will be installed at the
locations shown on Figure 3. Each well will be sized for a
pumping rate up to 150 gallons per minute. Water level
measurements will be taken: i) from each pumped well; ii) from a
maximum of ten observation wells for each test, two of which
will be instrumented with continuous recorders; and iii) from
the Niagara River via a continuous recorder. Existing wells may
be used if their location and construction are appropriate for
the test; no new wells will be installed solely for the purpose
of this test. However, new wells required for other programs
under this RRT Remedial Plan shall be installed ahead of
schedule if needed for this test. Water levels will be measured
every four hours for a period of one day prior to each test
start. Due to the effects of the Niagara River fluctuations,
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the maximum time permitted between water level measurements in
any well during the test period will be two hours.
B. Initially, each of the first two wells will be
pumped for APL at the maximum rate achievable (to a maximum of
75 gal/min) for a duration of 24 hours. After these two wells
are tested, the results will be evaluated and the test protocols
reviewed. If higher pump rates are required for the. remaining
tests., the pump rates will be adjusted up to 150 gal/min. After
the completion of the hydraulic testing, all data generated by
the testing will be evaluated and used to design the hydraulic
containment component of the Prototype Bedrock System.
4.4 PHASE II - PROTOTYPE BEDROCK SYSTEM
Based on the data obtained during the Phase I testing,
a Prototype Bedrock System, which consists of NAPL recovery
wells and APL/NAPL containment purge wells, will be designed and
installed as described below.
4.4.1 PROTOTYPE BEDROCK SYSTEM (Shallow Bedrock)
A. Remedial System:
Al. System Design and Installation: The Prototype
Bedrock System will be designed and installed in the Shallow
Bedrock based on the data obtained from the Phase I testing.
The Prototype Bedrock System shall be designed and installed, as
the second phase of a three-phase program, to attain the design
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and remedial objectives of the Bedrock RRT System described in
Section 4.1 and to collect data for the final design of the
Bedrock RRT System. The prototype design will include the
number of wells, well locations and the well, pump, and
operation specifications.
A2. System Evaluation: The Prototype Bedrock System
will be operated and monitoring data will be collected until
implementation of the Bedrock RRT System pursuant to Section
4.5.1. The monitoring data will be used to evaluate the
effectiveness of the Prototype Bedrock System in recovering NAPL
and containing APL and NAPL. Based upon evaluation of generated
data and subject to the Governmental Parties approval, the
system will be adjusted during the first 12 months of operation
of the Prototype Bedrock System by varying pumping rates and, if
necessary, by the addition or deletion of NAPL recovery wells
and APL/NAPL containment purge wells. Evaluation for the above
adjustment will be made by OCC 6 months and 12 months following
startup of the Prototype Bedrock System. OCC will conduct one
additional evaluation doing this 12-month period if so requested
by the Governmental Parties.
After the initial 12-month period, pumping rates
in the Prototype Bedrock System's wells may be adjusted at three
month intervals to evaluate the effect on inward hydraulic
gradients and NAPL recovery rate. Data collected during
operation of the Prototype Bedrock System will be used to: (i)
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evaluate Bedrock conditions; and (ii) design the Bedrock RRT
System and monitoring programs per Section 4.5.
A3. Hydraulic Stabilization: Hydraulic Stabilization
in the Bedrock is defined to have occurred when the head
measurement of the inside Bedrock piezometer of a piezometer
pair no longer declines more than 0.2 feet per quarter, taking
appropriate account of barometric pressure, water level
fluctuations in the Niagara River, and seasonal effects. When a
modification of the Prototype Bedrock System is implemented,
only the area affected by that modification will be evaluated to
determine if Hydraulic Stabilization is re-established.
Hydraulic monitoring will continue for those areas not affected
by the modification. If the head measurement of the inside
piezometer does not achieve a decline rate of 0.2 feet or less
per quarter, then Hydraulic Stabilization is assumed to have
occurred one year after implementation or modification of the
Prototype Bedrock System.
B. Monitoring Program:
Bl. Shallow Bedrock NAPL Monitoring:
(a) Monitoring Objective; The objective of the
Shallow Bedrock NAPL Monitoring Program (SBNP) is to evaluate
the effectiveness of the Prototype Bedrock System in attaining
the objective set forth in Subsection 4.4.1.A1.
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(b) Program Implementation;
1. The following SBNP monitoring to assess NAPL
recovery by the Prototype Bedrock System will be conducted in
purge/recovery wells within the existing Bedrock NAPL plume
along the River:
0 A monitoring program for NAPL recovery
by the Prototype Bedrock System will be
developed after completion of the
Initial Testing Program (described in
Section 4.3) and from data resulting
from the NAPL Tracer monitoring program
(see Section 4.4.1.B3 below).
0 Elements of SBNP monitoring for the
Prototype Bedrock System will include
quarterly evaluation of cumulative
total NAPL/APL recovery data for the
Prototype Bedrock System and annual
assessment of the following:
NAPL/APL ratios on individual
purge/recovery wells;
NAPL/APL ratios on five monitoring
wells located south of the Robert
Moses Parkway;
evaluation of NAPL collection
decline curves and the radius of
well influence, on an individual
well basis.
2. The following SBNP for the Prototype Bedrock
System will be conducted in purge/recovery wells within the
existing Bedrock NAPL plume not along the River to monitor NAPL
recovery:
0 Monitoring will begin upon installation
of the Prototype Bedrock System and
will continue until implementation of a
SBNP for the Bedrock RRT System.
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0 Quarterly monitoring of NAPL/APL ratios
in NAPL wells currently being pumped.
0 Annual monitoring of NAPL/APL ratios in
NAPL recovery wells which have been
shut off.
0 Quarterly evaluation of cumulative
NAPL/APL recovery data for Prototype
Bedrock System.
0 Annual evaluation of NAPL collection
decline curves and radius of well
influence/ on an individual well basis.
0 Quarterly measurement of NAPL levels in
all inner piezometers of the piezometer
pairs.
3. The following monitoring for the presence of
NAPL beyond the existing Bedrock NAPL plume will be conducted:
0 Monitoring will begin when piezometer
pairs and Prototype Bedrock System are
installed.
0 Quarterly frequency.
0 Method: hand bailing bottom of
well/piezometer or performance
equivalent.
0 Monitor each outside piezometer of the
piezometer pairs.
0 Monitor each Shallow Bedrock well
within 200 feet of the outside boundary
of the Bedrock NAPL plume.
(c) Response Actions;
If/ at any time during the operation of the
Prototype Bedrock System, SBNP monitoring in any Shallow
Bedrock well or piezometer indicates the presence of NAPL
outside the previously-defined Bedrock NAPL plume/ OCC will:
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0 Within 30 days thereafter, modify the
operation of the Prototype Bedrock
System and/or install additional wells,
if necessary, subject to the
Governmental Parties approval, to
contain NAPL, unless the source of the
NAPL is demonstrated not to be from the
S-Area NAPL plume. However, following
OCC's submission of the final design
for the Bedrock RRT System per Section
4.5.1., and until implementation of the
Bedrock RRT System, the response
actions triggered by the SBNP under
this Subsection 4.4.1.B1 shall be
limited to Operational Modifications
(as defined in Subsection 5.1.1).
0 Following implementation of the above
action(s), adjust the monitoring
program, as appropriate, to assess the
effectiveness of the modified remedial
system.
0 Utilize data collected from the
adjusted monitoring program in
designing of Phase III - Bedrock RRT
System per Section 4.5.1.
B2. Shallow Bedrock Hydraulic Monitoring Program:
(a) Monitoring Obiactive; The objective of the
Shallow Bedrock Hydraulic Monitoring Program (SBHP) is to
evaluate the effectiveness of the Prototype Bedrock System in
maintaining an inward gradient across the areal boundary of the
S-Area Shallow Bedrock NAPL plume.
(b) Program Implementation;
1. SBHP monitoring will utilize the following
wells:
0 12 Shallow Bedrock piezometer pairs to
be installed around the areal boundary
of the Shallow Bedrock NAPL Plume:
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each pair spaced no more than 400
feet apart;
inner well of each pair within and
no more • than 100 feet from the
areal boundary of the Shallow
Bedrock NAPL plume.
0 Selected S-Area and Niagara Plant
Shallow Bedrock wells available for
SBHP monitoring will be utilized for
SBHP monitoring/ as appropriate.
2. Following the Prototype Bedrock System
installation and until Hydraulic Stabilization (as defined in
Section 4.4.1.A3.), the following monitoring of the Prototype
Bedrock System will be conducted:
0 Water levels will be measured weekly in
all Bedrock Piezometer pairs and
selected existing Shallow Bedrock wells.
0 Continuous water level measurements
will be taken on two well pairs
(locations to be changed from time to
time).
0 Hydraulic data and pumping rates from
Bedrock purge wells will be evaluated
quarterly, and pumping rates will be
modified, as appropriate, at that time.
3. After Hydraulic Stabilization following
installation of the Prototype Bedrock System, or after
Hydraulic Stabilization following any modification to the
System or its operation, the following SBHP monitoring will be
conducted, and will continue until implementation of the SBHP
for the Bedrock RRT System:
0 Water levels in all paired piezometers
will be measured at least weekly for 12
months after the initial Hydraulic
Stabilization and then the monitoring
frequency will be assessed.
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0 Only piezometer pairs will be
monitored, unless response action
criteria from any monitoring program
(tracer, chemical, or hydraulic) are
triggered, in which case other wells in
the affected area also will be
monitored.
(c) Response Actions:
1. If, after Hydraulic Stabilization, the
monthly average of the water level elevation difference between
any piezometer pair is less than 0.1 foot (inward gradient),
OCC will within 30 days modify the operation of the Prototype
Bedrock System and/or install additional wells, if necessary,
subject to the Governmental Parties approval, to achieve the
specified inward gradient. Nothing in this Subsection 4.4.1.B2
shall require the installation of additional wells after the
first 12 months of operation of the Prototype Bedrock System.
2. After implementation of the above action(s),
only the area affected by the modification will be evaluated to
determine when Hydraulic Stabilization occurs, although
monitoring will continue in all areas.
B3. Tracer Monitoring:
(a) APL Tracer Dispersion Testing Program;
1. Objective:
The objective of the Tracer Dispersion Test is to
ccllecc information (including groundwater velocity, tracer
concentration profiles at receiving wells and Bedrock porosity)
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for use in assessing the feasibility of an APL Tracer
Monitoring Program and, if feasible/ for designing a Tracer
Monitoring Program for the Bedrock RRT System.
2. Program Implementation:
(i) The Tracer Dispersion Test will be
conducted as follows:
0 Perform promptly following the
installation of the Bedrock purge well
selected for the test.
0 Inject a water soluble tracer (Tracer
I) into a Shallow Bedrock well to be
installed in the northern portion of
the existing Bedrock NAPL plume, 100
feet southeast of the Bedrock purge
well to be used for the test.
0 Select Tracer I which satisfies the
following criteria: a chemical which
is highly soluble in water, unlikely to
have significant chemical or physical
interaction with the Bedrock, and is
readily capable of interference-free
detection using generally accepted
analytical methods.
0 Take and analyze APL samples for Tracer
I from six Shallow Bedrock wells
(OW-225, OW-23O, OW-231, OW-232,
OW-233, and Bedrock RRT purge well used
for test).
0 Base the initial sampling frequency for
each well on estimated travel time from
the injection point to the well.
0 Continue sampling until the first of
the following three conditions occurs:
the concentration of Tracer I in
each of the target wells has
fallen to 50% of the peak
concentration measured in that
well; or
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the start of the pumping test
described in (ii) below; or
one year after injection, if
Tracer I is detected in any target
well within three months of
injection or before the start of
the pumping test (see (ii) below).
(ii) The pumping test will be conducted as
follows:
0 Perform if Tracer I is not detected in
any target well within three months of
injection.
0 Perform after injection of the addition
of Tracer I or injection of a second
tracer (Tracer IA) if use of Tracer IA
is demonstrated by OCC or the
Governmental Parties to be practicable.
0 The duration of well pumping will be
five times the estimated travel time
from the injection point to the Bedrock
purge well under pumping conditions.
0 APL samples from the Bedrock purge well
used for the test will be taken and
analyzed for Tracer I or Tracer IA at a
frequency to be determined prior to the
start of well pumping.
(iii) The following performance criteria
for the Tracer Dispersion Test will be
utilized:
0 Performance "Successful" if Tracer I is
detected in a target well before the
start of the Pumping test.
0 Performance "Unsuccessful" if Tracer I
or IA is not detected in any target
well before or during the pumping test.
0 If Tracer I or IA is detected during,
but not before the pumping test/ OCC
will submit a report to the
Governmental Parties assessing whether
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APL tracer monitoring is appropriate
for the Bedrock RRT System.
(b) NAPL Tracer Monitoring Program?
1. Monitoring Objective: The objectives of the
NAPL Tracer Monitoring Program (NTP) are as follows:
0 During the first stage of the program,
to collect information on the volume
and velocity of southward NAPL plume
migration across the line of NAPL
recovery wells immediately north of the
Niagara River, as shown on Figure 2,
prior to the installation and operation
of the Prototype Bedrock System, and;
0 During the second stage of the program,
to collect information to assist in
evaluating the effectiveness of the
Prototype Bedrock System in containing
southward* NAPL plume migration across
the line of NAPL recovery wells
immediately north of the Niagara River,
as shown on Figure 2.
•
2. Program Implementation:
(i) During the first stage of the
program, NTP monitoring will be conducted as
follows:
0 Monitoring will be initiated as soon as
possible
0 OCC will select a hydrophobic tracer
(Tracer II), mix it with S-Area NAPL,
and inject this mixture into wells
OW-244 and OW-245.
0 APL and NAPL from four NAPL recovery
wells and from five Shallow Bedrock
monitoring wells along the Niagara
River will be sampled and analyzed
serai-annually for two years after
injection, and annually thereafter,
until Hydraulic Stabilization following
installation of the Prototype Bedrock
System.
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(ii) During the second stage of the
program, NTP monitoring will be conducted as
follows:
0 Program will be initiated promptly
after Hydraulic Stabilization following
the Prototype Bedrock System
installation.
0 An appropriate second tracer (Tracer
HA) will be injected into wells OW-244
and OW-245.
0 NAPL will be sampled and analyzed for
Tracer HA from appropriate Bedrock
purge/recovery wells and Bedrock
monitoring wells semi-annually for two
years after injection and annually
thereafter.
0 Tracer HA will be replenished by
additional injections over time, as
appropriate.
0 Monitoring for Tracer II in APL and
NAPL from wells along the River will
continue after Hydraulic Stabilization,
in parallel with the monitoring for
Tracer HA in NAPL from these and other
appropriate wells.
0 The . results of the monitoring will be
submitted annually to the Governmental
Parties.
(c) Response Actions: If NAPL sampling and
analysis indicate the presence of Tracer II and/or Tracer IIA
in non-pumping wells adjacent to the River, OCC will within 30
days submit to.the Governmental Parties a report assessing what
modifications to the operation of the Prototype Bedrock System
and/or installation of additional wells are necessary to
contain southward NAPL plume migration across the line of NAPL
recovery wells immediately north of the Niagara River, as
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shown on Figure 2. Nothing in this Subsection 4.4.1.B3(b)
shall require installation of additional wells after the first
24 months of operation of the Prototype Bedrock System.
Following implementation of the above action(s),
OCC will adjust the monitoring program/ as appropriate, to
assess the effectiveness of the modified remedial system.
B4. Baseline Chemical Monitoring;
(a) Monitoring Objective! The objective of the
Baseline Chemical Monitoring is to collect information for use
in designing the Shallow Bedrock Chemical Monitoring Program
(SBCP) for the Bedrock RRT System.
(b) Program Implementation:
1. Baseline Chemical Monitoring and SBCP
monitoring will be conducted on wells within the upper 30 feet
of the Bedrock selected from three concentric "rings,"
including:
0 an outer ring considerably beyond the
S-Area Bedrock NAPL Plume and inside
the EMP wells (outside the influence of
Bedrock RRT System and, if technically
practicable, outside any chemical
plumes);
0 a middle ring beyond the Bedrock NAPL
plume areal boundary (i.e.. within the
S-Area APL plume but outside the NAPL
plume), with approximately equal
numbers of wells immediately adjacent
to and somewhat removed from the areal
boundary of the NAPL plume;
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0 an inner ring within the S-Area Bedrock
NAPL Plume;
Existing wells and wells installed for other
monitoring programs will be used wherever feasible; however,
installation of up to eight new Shallow Bedrock monitoring
wells may be necessary.
2. SBCP baseline monitoring will be conducted
as follows:
0 . Monitoring will begin in accordance
with the RRT Schedule.
0 APL samples from four inner ring, eight
middle ring, and four outer ring wells
will be collected quarterly for two
years, and semi-annually thereafter
until the start of SBCP monitoring
following Hydraulic Stabilization of
the Bedrock RRT System.
0 Samples will be analyzed for TOX and
baseline parameters.
4.4.2 PROTOTYPE BEDROCK SYSTEM (Intermediate and Deep
Bedrock Zones)
A. Remedial System:
Al. Refinement of NAPL Plume Boundary: In order to
design the Prototype Bedrock System for the Bedrock zones
beneath the Shallow Bedrock, the extent of the NAPL plume on
the eastern portion of the Site will be defined by installing a
supplemental boring about 250 feet west of the CWTP pump
station. The supplemental boring will be installed to the top
of the Gasport Formation using the same protocols specified for
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1-41
conducting prior survey activities (Judgment, Addendum I,
Paragraph B).
Following installation, the supplemental boring
will be grouted if OCC concludes and the Governmental Parties
agree that it is inappropriate to use this boring in
conjunction with the Monitoring Programs described in Section
4.5.2.
A2. System Design and Installation: Based on data
generated by the refinement of the NAPL plume boundary and
other available data, the Prototype Bedrock System for the
Intermediate and Deep Zones will be installed as follows
0 Four purge/recovery wells will be
installed, two in each of the
Intermediate and Deep Zones (maximum
depth to top of Gasport Formation).
0 If NAPL has been found in the
supplemental boring installed in the
Intermediate/Deep Zones, a third
purge/recovery well will be installed
in each zone where NAPL was so detected.
A3. System Evaluation: The following actions will be
taken to evaluate the capability of the Prototype Bedrock
System in attaining the objectives set forth in Subsection 4.1.
0 Six monitoring wells/piezometers will
be installed in each of the
Intermediate and Deep Zones (12 wells)
outside any existing NAPL plume. The
wells in the Deep Zones shall be
installed tc the top of the Rochester
Formation.
0 Each purge well in the Prototype
Bedrock System will be pumped at the
maximum rate achievable (to a maximum
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of 20 gal/min.) for a duration of 48
hours. Pumping rates and water
elevations in the pump test wells and
monitoring wells/piezometers will be
recorded and evaluated.
0 Based on the data generated by the
individual pump testing/ the entire
system, including the individual purge
wells, will be assessed to determine if
it is capable of creating an inward
gradient across the areal boundary of
the Bedrock NAPL Plume.
B. Intermediate/Deep Hydraulic Evaluation Program:
Bl. Objective: The objective of the Intermediate/
Deep Zones Hydraulic Evaluation Program (IDHP) is to collect
hydraulic data for use in designing the Intermediate/Deep
components of the Bedrock RRT System and designing the
hydraulic monitoring program for that System.
B2. Program Implementation:
(a) Based on pump test results/ pumping rates
will be set to maximize NAPL/APL containment and NAPL
recovery. Pumping rates will be measured and water elevations
will be taken in purge/recovery wells. Inward gradient
monitoring will oe performed.
(b) OCC will also measure water elevations in
six observation wells in the Intermediate Zone and in six
observation wells in the Deep Zone and in selected/
then-existing wells located in these Zones within 1000 feet of
the Landfill Site. These wells will be installed during Phase
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II and monitored immediately following installation. This
monitoring shall include:
0 monthly frequency;
0 two continuous digital recorders
installed, one in the Intermediate Zone
and one in the Deep Zone;
0 reassessment after two years.
B3. Program Evaluation: Five years after program
initiation, OCC will submit to the Governmental Parties a
report assessing the pump test results and all the hydraulic
data collected to date pursuant to the Hydraulic Evaluation
Program. This assessment will be used to design a final
hydraulic monitoring program for the Intermediate/Deep Bedrock
Zones pursuant to Section 4.5.2.B, infra.
4.5 PHASE III - BEDROCK RRT SYSTEM (Shallow Bedrock,
Intermediate/Deep Zones)
4.5.1 REMEDIAL SYSTEM
A. The Bedrock RRT System will be designed and
installed in the Shallow Bedrock and Intermediate/Deep Zones
based on the data generated from the Phase I initial Testing
Program and Phase II Prototype Bedrock System. Evaluation of
that data base to determine whether there are sufficient data
to complete final Bedrock System design will occur one year
after start-up of the Prototype Bedrock System. OCC will
submit a report to the Governmental Parties assessing whether
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the data are sufficient for this purpose. If OCC and the
Governmental Parties agree that the data are sufficient for the
final design/ OCC will submit a final Bedrock RRT System design
within 90 days thereafter. If OCC and the Governmental Parties
agree that the data are not sufficient, the additional data to
be collected will be identified by OCC and the Governmental
Parties and will be collected by OCC. A re-evaluation of the
data base will be made every six months. Twenty-four months
following startup of the Prototype Bedrock System, sufficient
data will be deemed to have been collected and a final design
will be submitted by OCC to the Governmental Parties within 90
days thereafter. Following approval of final design by the
Governmental Parties, OCC will install, operate, monitor and
maintain the Bedrock RRT System to attain system design and
remedial objectives.
B. The design of the Bedrock RRT System may modify
among other things, the number of wells, pumping rates and well
locations used in the Prototype Bedrock System. The design may
also consider installation of a Bedrock grout curtain along the
edge of the River. The design for the Bedrock RRT System shall
include a monitoring program as per Section 4.5.2. However,
under the Bedrock RRT System design, OCC will not be required
to install purge/recovery wells in the Deep Zone below the top
of the Gasport Formation unless data is collected showing NAPL
below the Gasport Formation.
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4.5.2 MONITORING PROGRAMS
A. NAPL Monitoring;
Al. Shallow Bedrock NAPL Monitoring:
(a) Monitoring Objective; The Objective of
Shallow Bedrock NAPL Monitoring Program (SBNP) is to evaluate
the effectiveness of the Bedrock RRT System in attaining its
objectives as set forth in Section 1.0.
(b) Program Implementation;
1. The SBNP to monitor NAPL recovery by the
Bedrock RRT System will be designed after two years of SBNP
monitoring of the Prototype Bedrock System.
2. The following monitoring for the presence of
NAPL beyond the existing Bedrock NAPL plume will be conducted:
0 Monitoring will begin when the Bedrock
RRT System is installed.
0 Quarterly frequency.
0 Method: hand bailing bottom of
well/piezometer or performance
equivalent.
0 Monitor each outside piezometer.
0 Monitor each Shallow Bedrock well
within 200 feet of the outside boundary
of the Bedrock NAPL plume.
(c) Response Actions;
1. Response actions will be determined for the
SBNF monitoring of NAPL recovery by the Bedrock RRT System
based upon the data generated from the Phase I Initial Testing
Program, the Phase II Prototype Bedrock System and the
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associated SBNP monitoring. Response actions relating to NAPL
recovery will consist of monitoring of then-existing
non-pumping wells to determine if they are capable of producing
reasonable amounts of NAPL (and thus become NAPL recovery
wells) and/ if necessary, implementation of Operational
Modifications (as defined in Section 5.1.1), such as the
installation of new NAPL recovery wells.
2. If SBNP monitoring in any Shallow Bedrock
well or piezometer indicates the presence of NAPL outside the
previously-defined Bedrock NAPL plume, OCC will:
0 Proceed pursuant to Section 5.1.1 to
determine what Operational
Modifications (as defined in Section
5.1.1) to the Bedrock RRT System are
required to contain NAPL, unless the
source of the NAPL is demonstrated not
to be from the S-Area NAPL plume.
0 Following implementation of the
Operational Modifications described
above, adjust monitoring program, as
appropriate, to assess the
effectiveness of the modified remedial
system.
0 If further SBNP monitoring indicates
that action described above is not
effective in containing NAPL within the
newly-defined Bedrock NAPL plume, OCC
shall proceed pursuant to Section 5.1.2.
A2. Intermediate/Deep NAPL Monitoring:
(a) Monitoring Objective; The objective of the
Intermediate/Deep NAPL Monitoring Program (IDNP) is to monitor
the effectiveness of the Bedrock RRT System at containing NAPL
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in the Intermediate and Deep Zones within the vertical
projection of the existing Bedrock NAPL plume.
(b) Program Implementation; IDNP monitoring
will be conducted as follows:
0 Begin monitoring immediately following
the installation of the
Intermediate/Deep Zones Hydraulic
Evaluation Program observation wells;
0 Hand bail from selected
wells/piezometers within 400 feet of
the Bedrock NAPL plume in Deep and
Intermediate Zones;
0 Annual monitoring frequency.
(c) Response Actions; If IDNP monitoring
indicates the presence of NAPL in any well outside of the
previously-defined NAPL plume in the Intermediate or Deep
Bedrock Zones/ OCC will take response actions as described in
Section 4.5.2 Al.(c)(2).
B. Hydraulic Monitoring;
Bl. Shallow Bedrock Hydraulic Monitoring: The
objective of the Shallow Bedrock Hydraulic Monitoring Program
(SBHP) is to evaluate the effectiveness of the Bedrock RRT
System in maintaining an inward gradient across the areal
boundary of the S-Area Shallow Bedrock NAPL plume.
A hydraulic monitoring program for the Bedrock
RRT System will be developed following the completion of the
Prototype Bedrock program. Final monitoring criteria and
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response actions for the Bedrock RRT System will be developed
as part of the finalization of the Bedrock RRT System design.
B2. Intermediate/Deep Zones Hydraulic Monitoring: A
hydraulic monitoring program for the Intermediate and Deep
Bedrock Zones will be assessed after completion of the IDHP
pursuant to Section 4.4.2.B, infra. Based on the results of
this assessment/ OCC will design a hydraulic monitoring
program, including final monitoring criteria and response
actions, as part of the Bedrock RRT System design.
C. Chemical Monitoring;
Cl. Shallow Bedrock Chemical Monitoring:
(a) Monitoring Objective: The objective of the
Shallow Bedrock Chemical Monitoring Program (SBCP) is to
evaluate, in conjunction with other applicable monitoring
programs, the effectiveness of the Bedrock RRT System.
(b) Program Implementation: SBCP monitoring for
indicator chemicals will be conducted as follows:
0 Upon Hydraulic Stabilization following
installation of the Bedrock RRT System,
indicator chemicals characteristic of
the S-Area Landfill will be selected
based on detection frequency of
baseline parameters analyzed during
Baseline Chemical Monitoring.
0 The need to include additional
indicator chemicals which are
characteristic of N-Area or other Plant
Site chemicals will be assessed at this
time.
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0 Monitoring will begin within 60 days
after Hydraulic Stabilization of the
Bedrock RRT System (Shallow Zone) and
selection of indicator chemicals.
Baseline Chemical Monitoring will
continue until indicator chemicals have
been selected by OCC and approved by
the Governmental Parties.
0 APL samples from six inner ring, 16
middle ring/ and six outer ring wells
will be collected and analyzed
send-annually for indicator chemicals.
0 Monitoring of some or all of the six
inner ring wells may be discontinued
based on the Baseline Chemical
Monitoring results.
(c) Response Actions;
1. OCC will proceed pursuant to Section 5.1.1
to determine the need for Operational Modifications (as defined
in Section 5.1.1) to the System if:
0 A statistically significant increase in
SBCP indicator chemical concentrations
in any one or more middle ring well(s)
occurs. "Significance" is defined as
an increase, over an appropriate number
of sampling rounds, in the
concentrations of at least one-half of
the SBCP indicator parameters which are
detected in each sampling round, with a
confidence level greater that 95%.
2. If further SBCP monitoring indicates a
statistically significant increase in SBCP indicator chemical
concentrations following implementation of Operational
Modifications, OCC shall proceed pursuant to Section 5.1.2.
3. The SBCP, including sampling frequency,
number of wells sampled, and indicator chemicals analyzed, will
be reviewed and the need for SBCP modifications assessed if:
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9 over an appropriate number of sampling
rounds, the concentrations of between
one-quarter and one-half of the SBCP
parameters which are detected in each
sampling round increase with a
confidence level greater than 95%; or
0 the level of TOX in any well increases
with a confidence level greater than
95% on two consecutive or three of five
consecutive sampling events.
C2. Intermediate/Deep Zones Chemical Monitoring
Program:
(a) Monitoring Obiactive: The objective of the
Intermediate/Deep Zones Chemical Monitoring Program (IDCP) is
to collect chemical data in the Intermediate and Deep Zones and
to utilize the data in developing a final chemical monitoring
program for those zones.
(b) Program Implementation; IDCP monitoring
will be conducted as follows:
0 Following installation, sample and
analyze each well once for SBCP
baseline parameters.
0 Begin monitoring upon the start of
Phase III (Start of Operation of
Bedrock RRT System).
0 Sample six wells (new or existing) in
each of the Intermediate and Deep Zones.
0 Sample and analyze semi-annually.
0 Analyze samples for SBCP indicator
chemicals selected as discussed above.
(c) Response Actions;
Five years after initiation of IDCP, OCC will
submit a report to the Governmental Parties assessing whether a
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Chemical Monitoring Program (CMP) in the Intermediate and Deep
Zones is useful in evaluating system performance. Based on the
results of that assessment, OCC will, if appropriate, design a
CMP, including final monitoring criteria, and develop response
actions, subject to the Governmental Parties approval.
D. Tracer Monitoring:
Dl. APL Tracer Monitoring Program:
(a) Monitoring Objective: The objective of the
APL Tracer Monitoring Program is to evaluate, in conjunction
with other applicable monitoring programs, the performance of
the Bedrock RRT System.
(b) Program Implementation: APL Tracer
Monitoring will be conducted as follows: if the Tracer
Dispersion Test is deemed successful or if APL Tracer
monitoring is deemed appropriate pursuant to Section
4.4.1.B3.(a):
0 APL Tracer Monitoring will be initiated
after all piezometer pairs have
satisfied the hydraulic monitoring
criteria (i.e.. at least 0.1 ft. inward
head differential between the outer and
inner piezometer of each pair).
0 Tracer I or Tracer IA will be injected
in the inner piezometer of the pair
which displays the smallest inward
gradient.
0 APL samples will be taken from the
outer piezometer of that pair and at
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other appropriate Bedrock RRT purge
wells at a frequency based on the
results of the dispersion test.
0 Tracer I or Tracer IA will be
replenished by injecting additional
tracer/ as appropriate.
0 Two years after initial injection of
tracer for APL Monitoring/ OCC will
initiate an assessment whether ATP
monitoring is useful in evaluating
system performance and submit a report
containing the assessment to the
Governmental Parties within 60 days
after initiation. Such assessment will
consider continuation/ modification/
and termination of ATP monitoring.
(c) Response Actions; If ATP monitoring
indicates the presence of Tracer I or Tracer IA in an outer
piezometer, OCC will proceed pursuant to Section 5.1.1. to
i
determine what Operational Modifications (as defined in Section
5.1.1.) are required to contain APL within the existing Bedrock
NAPL plume. Following implementation of Operational
Modifications described above/ OCC will adjust the monitoring
program/ as appropriate/ to assess the effectiveness of the
modified remedial system.
0 Following Operational Modifications
described above/ if ATP monitoring
again indicates the presence of Tracer
I or Tracer IA and at least two years
have elapsed since initial Tracer I or
Tracer IA injection/ OCC shall proceed
as per Section 5.1.2
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D2. NAPL Tracer Monitoring Program:
(a) Monitoring Objective; The objective of the
NAPL Tracer Monitoring Program (NTP) is:
0 To collect information to evaluate the
effectiveness of the Bedrock RRT System
in containing southward NAPL plume
migration across the line of NAPL
recovery wells immediately north of the
Niagara River, as shown on Figure 2.
(b) Program Implementation; NTP monitoring
will be conducted as follows:
0 The program described in Section
4.4.1.B3.b(2) will be continued
following installation of the Bedrock
RRT System.
0 The results of the monitoring will be
submitted annually to the Governmental
Parties. Five years after the Tracer
HA injection, OCC will submit a report
to the Governmental Parties assessing
whether NTP monitoring is useful in
evaluating system performance and
whether the program should be
continued, modified or terminated.
(c) Response Actions; If NAPL sampling and
analysis indicate the presence of Tracer II or Tracer HA in
non-pumping wells adjacent to the River, OCC will proceed
pursuant to Section 5.1.1.
Following implementation of the Operational
Modifications described above, OCC will adjust the monitoring
program, as appropriate, to assess the effectiveness of the
modified remedial system. If further NTP monitoring indicates
that the Operational Modifications described above are not
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effective in containing southward NAPL plume migration across
the line of wells immediately north of the Niagara River, as
shown on Figure 2, OCC will proceed pursuant to Section 5.1.2.
E. Environmental Monitoring Program
El. Monitoring Objective; The objective of the
Environmental Monitoring Program (EMP) is to evaluate the
effectiveness of the Bedrock RRT System in protecting human
health and the environment from endangerment by chemical
migration from the Landfill Site.
E2. Program Implementation:
(a) Plans and specifications for the installa-
tion of the EMP wells will be submitted to the Governmental
Parties in conjunction with the Bedrock RRT System design.
(b) Eight EMP wells will Ls installed in the
Shallow Bedrock Zone in an area extending from west to
northeast of the Landfill Site and located beyond the
groundwater capture zone of the Bedrock RRT System. (See
Figure 5.)
(c) Following Hydraulic Stabilization of the
Bedrock RRT System, samples will be collected quarterly from
the EMP wells and analyzed.
(d) Groundwater flow will be calculated based on
quarterly elevation data gathered from the EMP wells. As
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necessary/ piezometers or other wells will be used to
supplement the EMP wells for the purpose of calculating
groundwater flow hydraulic data.
(e) The collected data will be used to calculate
the average groundwater concentration in the monitored aquifer
for each EMP Parameter on a guarterly basis/ as follows:
0 The samples collected from the eight
EMP wells will be analyzed for the EMP
Parameters listed in subparagraph (f).
EMP Parameters not detected will be
assigned a value of one-half the
detection level for that sampling
period if during such sampling the
parameter is detected in a sample from
any of the eight wells; otherwise, it
will be assigned a value of zero.
0 The groundwater flow weighted average
aguifer concentration (AAC) of each EMP
Parameter identified in the monitored
aguifer will then be calculated.
(f) For the purposes of the EMP/ the following
action levels will be applicable:
EMP Parameter EMP Action Level (PPB)
1/1 Oichloroethylene 5
Endosulfan 10
Hezachlorocyclohezane
(each isoraer) 7
2/3/7/8 TGDD equivalents 0.0005
Hezachlorobenzene 7
Mirex (CIQ Cli2> 7
Tetrachloroethylene 5
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E3. Response Actions:
(a) If the AAC level calculated per subparagraph
E2(e) exceeds the EMP Action Level for the same EMP Parameter
for two consecutive quarters, OCC will, within 30 days
thereafter, submit a report to the Governmental Parties-
assessing what Operational Modifications (as defined in Section.
5.1.1), if any, are required to reduce the AAC levels for those
parameters.
(b) If further EMP monitoring indicates that the
Operational Modifications undertaken pursuant to (a) were
ineffective in reducing the AAC level(s) below the indicated
EMP Action Level(s), OCC will proceed pursuant to Section 5.1.2.
(c) With respect to Hezachlorocyclohezane and
Tetrachloroethylene, response actions under this subparagraph
E3 need not be undertaken unless the total chemical flux of all
EMP Parameters exceeds a calculated response action flux
level. This response action flux level will be calculated as
the sum of the EMP Action Levels times the total monitored*
aquifer flow. The total chemical flux will .be calculated, as
the product of the AAC, calculated pursuant to subparagraph
E2(e), and the total monitored aquifer flow.
(d)The EMP will continue unless or un 1 it is
superseded by applicable Niagara Plant monitoring progr s.
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5.0 REMEDIAL SYSTEfl - RESPONSE ACTIONS. REASSESSMENTS.
5.1 Procedures Regarding Response Actions
Sections 2.0, 3.0, and 4.0 above set forth the
remedial systems selected to address the environmental
conditions identified at the Landfill Site. The monitoring..
programs selected for these remedial systems, as described in
Sections 2.0 and 4.0, are intended to determine whether the
objectives of these remedial systems are being met and whether
response actions are required.
The following is the process which the parties have
agreed to follow if a response action is triggered by the
monitoring programs.
5.1.1 Operational Modifications
A. "Operational Modifications" are defined to
consist of upgrading existing equipment, changes in operating
pumping rates of existing wells, and installation of new*wells
or other equipment in order to attain the objectives of the
remedial system being monitored. Operational Modifications
shall be consistent with good engineering practice.
Operational Modifications do not include: (i) actions which
exceed the "maximum" modifications pursuant to Section 5.1.1.B,
or (ii) if such maximums have not been established, actions
which significantly alter the basic features of the initially
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installed remedial system or associated treatment or storage
facilities with respect to scope or cost.
B. OCC shall propose, as part of the c ign of the
Site Containment System, the Overburden RRT Sys¥ ,a, and the
Bedrock RRT System, specified maximum modifications to that
system (e.g.. maximum number of additional wells or maximum
increase in pumping rates) which constitute Operational
Modifications. OCC and EPA/State shall, prior to approval of
the design for a final remedial system, use their best efforts
to agree to specified maximum modifications to the system. If
OCC and EPA/State cannot agree to such maximums at the time of
design approval, OCC will implement the approved design without
such maximums and either OCC or EPA/State may pursue the
resolution of maximums through dispute resolution.
C. If, during operation of any of the remedial
systems described in Paragraph B, the monitoring program
applicable to the specific remedial system(s) triggers
Operational Modifications, OCC will implement Operational
Modifications to those systems as provided below:
Cl. OCC shall submit an assessment report to
EPA/State proposing what Operational Modifications OCC will
implement. However, such report shall not be : quired for
Operational Modification(s) involving only increase rates of
operation.
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C2. For those Operational Modifications not requiring
an assessment report, OCC shall implement the response action,
as soon as practicable/ and shall notify the EPA/State within
fourteen (14) days of the initial response action trigger
date. Such notification shall be in writing and shall describe
the Operational Hodification(s) taken or to be takene* the*
reason for taking such raodification(s)/ and the justification
for the selected level of response.
C3. For Operational Modifications requiring an
assessment report/ OCC will submit such report within
twenty-one (21) days of the initial response action trigger
date. The report shall include: a description of the problem/
including data and analyses; Operational Modification(s) that
OCC has considered; an evaluation of the proposed Operational
Modification(s)/ including assumptions and analyses used and
justifications for the proposal; and the total time estimate to
implement each alternative. As soon as practicable but* not
later than thirty (30) days after EPA/State approval of- the
Operational Modif ieation(s), OCC shall submit an implementation
schedule and plans and specifications (to the extent not
already approved for such use) for the approved Operational
Modification(s). OCC shall implement Operational Modifica-
tions/ following ZPA/State approval/ in accordance with; the
approved schedule.
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5.1.2 System Modifications and Supplements
Al. As used herein, "System Modifies HIS" are
defined to consist of physical alterations to an J remedial
system that:
0 are above and beyond Ope.ational
Modifications;
0 are compatible with the installed RRT
remedial systems;
0 are designed to meet the same goals and
objectives as the installed RRT
remedial systems. (System
Modifications may be accompanied, as
necessary/ by revisions to specific
monitoring program requirements.)
A System Modification/ in general, is a physical
alteration that will augment or otherwise enhance the
performance of the installed RRT remedial system without
significantly altering the installed system in either
'technology, scope, or function. System Modifications are
intended to include only alterations using engineering and
construction practices used or accepted for use in landfill
containment projects or other industrial projects which are
applicable to the materials and hydrogeologic conditions found
at the S-Area/Treatment Plant area and will not include
unproven new technologies or source control efforts such as
full or partial excavation, vitrification, etc. Examples of
System Modifications include, among others, additional or
relocated hydraulic collection or containment installations
(e.g.. well installations, slurry or grout walls). System
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Modifications shall be designed and installed to be consistent
with good engineering practice and cost-effective in compliance
with Paragraph C.
A2. As used herein, "System Supplements" are defined
as remedies using Remedial Technology (as defined in Paragraph
4(a) of the Judgment) which are different than those used? in
the installed RRT remedial systems and which are designed to
supplement an RRT system by specifically addressing the
conditions triggering the response action. System Supplements
shall be designed to be consistent with good engineering
practice and cost-effective in compliance with Paragraph C.
B. If, after OCC has implemented all required
Operational Modifications pursuant to Section 5.1.1, and one or
more response action triggers described in Sections 2.0 or 4.0
require OCC to take further action pursuant to Section 5.1.2,
OCC will proceed as follows:
Bl. NAPL and Certain Hydraulic Monitoring; The
procedures of this subparagraph B.I will be applicable if a
response action for System Modifications is triggered by the
monitoring described in Section 2.3.1.C6 (Overburden NAPL
Monitoring), Section' 2.3.2.C2 (Inward Gradient Overburden
Hydraulic Monitoring), Sections 4.5.2.A1.C.2 and 4.5.2.A2.C
(Bedrock NAPL Presence Monitoring), or Section 4.5.2.B1
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(Shallow Bedrock Hydraulic Monitoring). OCC will submit to
EPA/State, within 90 days of the response action trigger date/
a focused feasibility study which evaluates alternative System
Modifications to the remedial system which would enable the
system to prevent further response action triggers and meet the--
system objectives of Section 1.0. OCC's focused feasibility-
• -"/w
study will address at least the following factors:
0 The nature and extent of the condition
triggering the response action;
0 The degree to which each modification
alternative will enable the remedial
system to prevent further response
action triggers and meet system design
objectives of Section 1.0; and
0 The cost and schedule for implementing
such modification alternative.
After submission of the focused feasibility study to EPA/State,
the parties will proceed as described in Paragraph C of this
Section.
B2. Other Monitoring: For those monitoring programs
not identified in subparagraph Bl, the procedures of this
subparagraph B2 will be applicable if a response action is •
triggered by any monitoring program described in Sections 2.0
or 4.0 which requires response under Section 5.1.2. OCC will
prepare the same type of focused feasibility study of System
Modifications set forth in subparagraph Bl. The feasibility
study shall also identify and evaluate System Supplements. In
addition, if OCC chooses/ the feasibility study may also
evaluate whether System Modifications or System Supplements are
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"Requisite* (as defined in Paragraph 4(a) of the Judgment) and
whether the Environmental, Chemical or Tracer Monitoring
Programs accurately evaluate the Remedial System's performance
in meeting the remedial objectives in Section 1.0.
OCC will submit this focused feasibility study to
EPA/State within 90 days after the response action trigger
date. After submission of the focused feasibility study to
EPA/State, the parties will proceed as described in Paragraph C
of this Section.
C. Within 120 days following receipt of an OCC
submission described in Paragraph B, EPA/State will respond in
writing to the submission. EPA/State will either approve the
recommendations in OCC's feasibility study or propose (either
from OCC's feasibility study or any similarly prepared study of
its own) cost-effective System Modifications or System
Supplements, as appropriate, which enable the system to meet
the objectives of Section 1.0 and effectively prevent further
response action triggers. OCC will be required to implement
the System Modifications or System Supplements proposed by
EPA/State in accordance with the terms and conditions of this
Section 5.0 unless, upon the evidence, the Court determines:
Cl. That the EPA/State proposal does not satisfy the
definition of System Modifications or System Supplements, as
appropriate, set forth in subsection 5.1.2.A; or
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C2. That considering the factors set forth in
Bl(a)-(c) and all relevant monitoring date it would be
arbitrary and capricious to require OCC to implement the
proposed System Modifications or System Supplements; or
C3. That, in the case of System Modifications.
triggered by the monitoring programs referenced in subsection
B.2 or System Supplements:
(i) the proposed System Modifications or
System Supplements are not "Requisite" (as
defined in Paragraph 4(b) of the Judgment; or
(ii) those monitoring triggers are not
accurate measurements of meeting the
applicable objectives.
5.1.3 RRT Study
If, after OCC implements all required System
Modifications or System Supplements to the remedial system,
pursuant to Section 5.1.2, a response action described in
Section 2.0 or Section 4.0 is still being triggered by- a
monitoring program requiring response and if OCC and EPA/State
agree or the Court determines that no further modification(s)
will enable the system to meet the system objectives of Section
1.0, OCC shall undertake an RRT Study. The RRT Study shall
include an evaluation of whether the implementation of any
other Remedial Technology (including source control) would be
more effective in achieving the goals of the Judgment than the
installed remedial systems. That evaluation will be based on
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will be based on the Requisite Remedial Technology criteria of
Paragraph 4 of the Judgment. OCC will implement any remedy
selected pursuant to Paragraph 4 of the Judgment in accordance
with a schedule approved by EPA/State.
5.2 Monitoring Program Reassessment and Modification
5.2.1 Reassessment
Every five years after the beginning of the operation
of the Bedrock RRT System, OCC will submit to EPA/State a
reassessment of such monitoring programs (including associated
response action triggers) then in effect. EPA/State may
require OCC to conduct a monitoring program reassessment sooner
or at more frequent intervals, if at any time, it is determined
either by agreement of EPA/State and OCC or by order of the
Court, that there is an endangerment to human health, the
environment, or the users of the City of Niagara Falls drinking
water resulting from chemical migration from the Landfill Site-
which is not triggering response actions then in effect under
Sections 2.0 and 4.0. In addition, EPA/State, the City (when*
conditions at the CWTP are specifically affected) or OCC at its
option, may conduct and, for good cause, submit to the other
parties a reassessment of such monitoring programs, provided
that it is conducted after the first five year assessment has.
been conducted and reviewed.
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1-66
5.2.2 Modification
As a result of any reassessment conducted p»- -suant to
Section 5.2.1, EPA/State, the City (when conditions s the CWTP
are specifically affected) or OCC may propose .onitoring
program (including associated response actior triggers)
modifications, if any, consistent with applicable objectives
described in Section 1.0. Such modifications may include,
without limitations, the following: the number and location of
monitoring sampling points, the response action triggers
associated with that program, the frequency of such sampling,
the parameters to be analyzed, the levels related to such
parameters, and the frequency of future reassessments required
in Section 5.2.1. In the event EPA/State and OCC do not agree
regarding the proposed modification of a monitoring program,
the party seeking such modification may petition the Court to
resolve the dispute. The petitioner shall bear the burden to
demonstrate to the Court that the continued utilization of the
existing monitoring program is inappropriate in assessing
whether a remedial system is attaining its objectives- as
described in Section 1.0 and that the proposed modification is
consistent with those objectives. If the petitioner seeks to
change any response action triggers which are agreec. uo as part
of the RRT Stipulation, there will be a rebuttable i sumption
that the response actions triggers then in efft.t under
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Sections 2.0 and 4.0 are appropriate measures of meeting the
objectives of Section 1.0.
5.3 System Operation Reduction
A. Operation of any component of a final remedial
system installed under the S-Area RRT Remedial Plan may*1 be?
reduced if it is determined by agreement of OCC and EPA/State,
or by order of the Court, that the following conditions are
met: (1) the remedial system as installed and without
reductions is not triggering any applicable monitoring program
response actions then in effect under Sections 2.0 and 4.0 and
(2) the operation of the proposed reduced system would not
trigger any of the applicable monitoring program response
actions then in effect under Sections 2.0 and 4.0. Such
reduction may include a reduction of pumping rates and/or in
the number of purge wells and/or recovery wells. If such
reduction triggers a response action as stated above/ or if
NAPL collection is reduced as a result of the system reduction,
OCC shall reinstitute the program as it existed before the
reduction.
B. Prior to any system reduction described in
Section 5.3.A. OCC shall make a submission to EPA/State setting
forth its proposed action and 5.ts assessment of the impact
thereof, along with all underlying data. Such submission shall
include, without limitation, an evaluation of whether more
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frequent monitoring of the reduced system for a defined period
of time is required/ the need for continued maintenance of the
subject system, and the circumstances under which pre-reduction
system operations would be resumed.
C. Within 60 days of receipt of such submission,
EPA/State will respond to OCC in writing stating either its
agreement or disagreement with OCC's position. The operation
and/or maintenance of the affected remedial system may be
reduced by agreement of EPA/State and OCC. In the event
EPA/State disagrees with OCC's proposal/ the reasons for such
disagreement will be set forth in its written response.
D. In the event that OCC and EPA/State do not agree
regarding reduction of a remedial system/ OCC may petition the
Court to resolve the dispute. The operation and/or maintenance
of the affected remedial system may be reduced if OCC
demonstrates to the Court that after such reduction the system
would not trigger any of the response actions then in effect
under Sections 2.0 and 4.0. During the pendency of the Court's
review of the matter, OCC shall continue operation/ monitoring/.
and maintenance of the affected remedial system without
implementing the proposed reductions.
5.4 Termination
A. Operation/ monitoring/ and maintenance activities
undertaken in order to comply with the terms and conditions of
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1-69
the Judgment and the RRT Stipulation shall not be terminated
for 35 years following submission of the final design for the
Bedrock RRT System as per Section 4.5.1. After such 35 year
period, all or a portion of such activities may be terminated
if it is determined, by agreement of EPA/State and OCC or by
order of the Court, that such activities are no longer
necessary to satisfy the goals of the Judgment.
B. Prior to any termination under this Section, OCC
shall submit an assessment report to all other signatory
parties setting forth the basis for its proposed termination
along with all data relied upon by OCC in support of its
position. The submission shall include, without limitation,
the following: the impact of such termination with regard to
the objectives of Section 1.0; the basis for OCC's conclusion
that the activities are no longer necessary to satisfy the
goals of the Judgment; proposals for a minimum three year
post-termination monitoring program(s); maintenance programs
for the terminated systems; and the response actions triggers
which would require resumption of terminated activities.
C. Within 60 days of receipt of such submission,
EPA/State will respond to OCC in writing stating either its
agreement or disagreement with OCC's position. In the event
EPA/State disagrees with OCC's proposal, the reasons for such
disagreement will be set forth in its written response. The
operation, monitoring and/or maintenance of the subject
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1-70
remedial system(s) may .be terminated by agreement of the
parties and notice to the Court or by order of the Court.
D. In the event that OCC and EPA/State do not agree
regarding termination under this Section/ OCC may petition the
Court to resolve the dispute. OCC shall not terminate any
activities pursuant to this Section until a deterstoafcioir
described in Paragraph A has been made, either by agreement of
EPA/State and OCC or by order of the Court.
5.5 City Review and Approval Responsibility
A. Submittals
Any time a submittal or notice is required under
Section 5.0, copies shall be provided to the City.
B. Approval
Any time review, approval, determination or
concurrence is required of EPA/State under Section 5.0, the
City (when conditions at the CWTP are specifically affected)
may also conduct a concurrent review, approval, determination
or concurrence process except that failure of the City to issue
its approval, determination or concurrence decision timely in a
particular instance shall be deemed a waiver of that right in
that particular instance.
C. Comments
Nothing herein shall prevent the City from submitting
timely comments on any other submittals; however, the parties
shall consider, as appropriate, but are not obligated to
respond to or adopt any such comments.
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FIGDRES
-------
BARMEM WALLS
ALTERNATIVE BARRJCR WALL
OVERBURDEN
PUROE/REDIMEXr 1GLJL
OVERBURDEN
PURGE/RECOVERY
USED AS PCZOMETER
NOT PUMPED
PROPOSED 005 OUTFALL
REMJONMENT
NOTE 1
PO*O mm* nonto a LOCATED
M 1HC OVERBURDEN. FCU>
9PAOMO MAY RCOUMC 1HAT
WALL K RELOCA1ED NOR1HWARO
AS SHOWN.
IAGOONS
\ \\ \
figure 1
SITE CONTAINMENT AND
OVERBURDEN RRT SYSTEM
S-AREA REMEDIAL PROGRAM
Occidental Chemical Corporation
-------
too zson
LEGEND
@ MAPI RECOVCTr TEST KU.
— OWKBURDEN NAPL PLUME
——— BEDROCK NAPL PLUME
(Si) COMMON TO BOTH BEDROCK PUMP TEST
=X AND NAPL RECOVERY TESTMO
figure 2
NAPL RECOVERY TEST WELLS
S-AREA REMEDIAL PROGRAM
Occidental Chemical Corporation
1789-21/06/W- 68-0
-------
0 100 290ft
CRA
LEGEND
(§) BEDROCK PUMP TEST «EU
~ OVERBURDEN NAPL PLUME
BEDROCK MAPL PLUME
/Sh COMMON TO BOTH BEDROCK PUMP TEST
AND NAPL RECOVERY TESTMC
figure 3
BEDROCK PUMP TEST WELLS
S-AREA REMEDIAL PROGRAM
Occidental Chemical Corporation
1789-21/06/89-66-0
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I
so
LEGEND
BARRIER WALLS
ALTERNATIVE BARKER WALL
PRESCWPTTVE GROUT PLUG
Tl£ DRAM
PURGE^ECOVERY
PROPOSED 005 OUTFALL
REALIGNMENT
MAINTENANCE KZDMCRX
ORAOENT IMMrrORMO
WATER TREATMENT
..PLANT
i son
WEU
POROE/TCCOVERY WELL
USED AS PIEZOMETER
NOT PUMPED
NOTE 1
PUWIR TOWER FOOTING S LOCATED
M THE OVERBURDEN. FKLD VERTED
SPACMG MAY REQURE THAT BARRCR
WALL BE RELOCATED NORTHWARD
AS SHOWN.
NIAGARA RIVER
figure 4
OVERBURDEN MONITORING
S-AREA REMEDIAL PROGRAM
Occidental Chemical Corporation
5/89- 66-1
-------
WATER TREATMENT PLANT
EMP WELL IN SHALLOW AQUIFER
ESTIMATED BEDROCK APL PLUME
BEYOND THE NAPL PLUME
PRIOR TO REMEDIATION
DEFINED NAPL PLUME
V.,—ESTIMATED EXTENT OF
\ NAPL PLUME MIGRATION IN
V BEDROCK BENEATH RIVER
figure 5
ENVIRONMENTAL MONITORING PROGRAM
MONITORING WELLS AND
ZONES IN SHALLOW AQUIFER
Occidental Chemical Corporation
CRA
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APPENDIX II
ENVIRONMENTAL HEAT.T^ AND SAFETY PLAN
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APPENDIX II
ENVIRONMENTAL HEALTH AND SAFETY PLAN
1.0 The Environmental Health and Safety Plan set forth In Addendum V of the
Judgment is modified as follows:
2.0 Section D - PERSONNEL EQUIPMENT. CLOTHING AND HYGIENE
2.1 Subparagraph (2)(c) shall be replaced by the following:
(c) Samples collected pursuant to subparagraph (a) at the Survey Site and the
Working Site shall be assessed for the major components of the organic
vapors (Subparagraph K(1)(c)). In the event that the time weighted
average (TWA) exposure for any major component exceeds the
appropriate American Conference of Government and Industrial Hygienists
(ACGIH) Guideline, then the Safety Officer shall proceed as described in
subparagraph (f).
2.2 Subparagraph (2)(d) shall be replaced by the following:
(d) Samples collected pursuant to subparagraph (a) at the Working Site shall
be assessed for tetrachlorobenzene and hexachlorobenzene. In the event
the levels exceed 1 ppm (8 mg/nr) or 0.1 ppm (1 mg/nr) respectively,
the Safety Officer shall proceed as described in subparagrapn (f).
2.3 Subparagraph (2)(e) shall be replaced by the following:
(e) Within seven days of the receipt of the analytical results, Hooker shall
submit to the Governmental Parties all data relating to such detected
organic vapors and/or particulate levels.
3.0 Section J - SURVEY MONITORING
3.1 Subparagraph (1)(a) shall be replaced with the following:
(1) (a) Organic vapor levels shall be monitored periodically at the perimeter of the
Survey Site downwind of each Survey Site by use of a photoionization
detector (PID), or its performance equivalent In addition, the major
components of the organic vapors shall be periodically monitored at the
Survey Site.
3.2 Subparagraph (1)(b) shall be replaced by the following:
(b) If the Time Weighted Average (TWA) exposure for any major component
exceeds one-half of the appropriate ACGIH Guideline, then the Safety
Officer and EPA/State on-srte representative shall determine what
corrective action, it any, shall be taken. (The turnaround time for analytical
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Page 2
Appendix II
results will be specified in the plans.specifications and protocols.) Within
seven days following receipt of analytical results, Hooker shall submit to
the Governmental Parties all data relating to such detected organic vapor
levels and the results of corrective action, if any, taken pursuant to this
subparagraph.
4.0 SECTION K - SPECIAL CONSTRUCTION MONITORING
4.1 Subparagraph (1)(a) shall be replaced by the following:
(1) (a) Organic vapor levels shall be monitored continuously at each Working Site
by use of a photoionization detector (PID), or its performance equivalent.
In addition, the major components of the organic vapors shall be
periodically monitored at each Working Site.
4.2 Subparagraph (1)(b) shall be replaced by the following:
(b) If the Time Weighted Average (TWA) exposure for any major component
exceeds the appropriate ACGIH Guideline then the Safety Officer arid
EPA/State on-site representative shall determine what corrective action, if
any, shall be taken. Within seven days following receipt of analytical
results, Hooker shall submit to the Governmental Parties all data relating to
such detected organic vapor levels and the results of corrective action, if
any, taken pursuant to this subparagraph.
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APPENDIX III
CITY DRINKING WATER TREATMENT PLANT REMEDIAL PROGRAM
-------
APPENDIX III
CITY DRINKING WATER TREATMENT PLANT REMEDIAL PROGRAM
TABLE OF CONTENTS
Page
1. 0 INTRODUCTION III-l
2.0 PLAN B III-l
2.1 Collection System Configuration III-2
2.2 Collection System Design III-3
2.3 Collection System Operation III-4
2.4 CWTP Service Line Monitoring
and Response Actions III-5
2.4.1 Purpose III-5
2.4.2 Monitoring Program III-5
2.4.3 Response Actions III-5
2.5 O/TTP Vertical Gradient Monitoring III-6
2.5.1 Objective III-6
2.5.2 Program Implementation III-6
2.6 Emerald Channel Intake Tunnel
Monitoring III-7
2.7 Distribution Water Monitoring 111-12
2.8 Monitoring Program Assessment 111-23
2.9 Inoperative Paragraph 111-24
2.10 48-Inch Raw Water Line Monitoring 111-24
2.11 48-Inch Raw Water Line Protection 111-24
6667o:KSW:06/05/90
Revised: 07/19/90
13493-6:0.C.
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Page
3.0 INTERIM CWTP MONITORING
AND RESPONSE ACTION PLAN 111-26
3.1 Interim Drinking Water Monitoring
and Response Actions Program 111-26
3.1.1 Purpose 111-26
3.1.2 Water Monitoring 111-26
3.1.3 Response Actions 111-28
3.2 Interim NAPL Presence Monitoring
and Response Action Program 111-32
3.2.1 Purpose 111-32
3.2.2 Investigations 111-32
3.2.3 Monitoring Program 111-33
3.2.4 Response Actions 111-33
4 . 0 EASTERN PORTION STUDY 111-35
5.0 EXISTING CWTP REMEDIAL/CLOSURE PLAN 111-39
FIGURES
ATTACHMENT A Plan A Milestone Schedule
ATTACHMENT B Plan B Bar Sequencing Schedule
ATTACHMENT C DWTP Closure/Remedial Plan
ATTACHMENT D New CWTP Project Cost Estimate
6667o:KSW:06/05/90
Revised: 07/19/90
13493-6:0.C.
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DRAFT
July 20. 1990
APPENDIX III
CITY DRINKING WATER TREATMENT PLANT REMEDIAL PROGRAM
1.0 INTRODUCTION
The City Drinking Water Treatment Plant (CWTP)
Remedial Program described in Section E of the RRT Stipulation
shall include the Interim CWTP Monitoring and Response Action
Plan described below in Section 3.0 and either Plan A, Plan B,
or any alternative plan (Plan "C") agreed to pursuant to
Paragraphs 15 and 16, Section E, of the RRT Stipulation. Plan
A consists of the activities described in Paragraph 10, Section
E, of the RRT Stipulation; the Plan A Milestone Schedule is
attached as Attachment A. Plan B consists of the activities
described iu Section 2.0 below; the Pl-n B Bar Sequencing
Schedule is attached as Attachment B.
2.0 PLAN B
Plan B consists of the implementation by OCC and the
City of the remedial systems and associated activities as
described in Paragraph E of Addendum I; Paragraphs C through I
of Addendum II; and Paragraphs C, D(l) and E of Addendum III,
of the Judgment, except as modified as set forth in this
Section 2.0.
6344o:KSW:03/20/90
Revised: 07/19/90
13493-6:0.C.
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III-2
2.1 Collection System Configuration
(a) OCC will install Collection Systems ("hereinafter
CWTP Collection Systems") for the pump station, Filtration
Plant "A" and the reservoir at the current CWTP, which will
include the conceptual elements shown on Figures E-2, E-3, and
E-4 of the Judgment.
(b) OCC will repeat the performance of soil and
groundwater surveys at the five existing survey well locations
adjacent to Filtration Plant "B," as shown on Figure III-2, and
shall assess, as described in subparagraph E(3)(d), Addendum I
of the Judgment, whether there are chemicals in the Overburden
in the vicinity of Filtration Plant "B" which have migrated
from the Landfill Site. OCC shall not be required to install
the component of the collection system adjacent to Filtration
Plant "B" unless it is determined, either by agreement of the
signatory parties or by order of the Court, following the
aforementioned survey and assessment, that chemicals have
migrated to the vicinity of Filtration Plant "B" in the
Overburden from the Landfill Site in excess of the survey
levels described in subparagraph E(3)(c), Addendum I of the
Judgment. OCC shall submit a report describing the results of
the assessment described in this Paragraph at least 120 days
prior to the scheduled date for submission of plans and
specifications for design of the Filtration Plant/Reservoir
Collection System.
6344o:KSW:03/20/90
Revised: 07/19/90
13493-6:D.C.
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III-3
(c) In addition, the conceptual elements of the CWTP
Collection Systems for Filtration Plant "A" and the reservoir/
as shown on Figures E-3 and E-4 of the Judgment, will be
augmented to include french drain laterals to the 30-inch
ductile iron waste water drain to provide groundwater control.
The conceptual location of these laterals is shown on Figure
III-l. OCC shall, as a component of the plans and
specifications to be submitted for the monitoring systems
described in Paragraphs C and D of Addendum II, include alarms
which are triggered if a collection system is not functioning
properly.
2.2 Collection System Design
In addition to the design considerations set forth in
Paragraph E(2), Addendum I of the Judgment, design
considerations applicable to the CWTP Collection Systems
described in Section 2.1 will include the following:
(a) Drain tile systems will be capable of
achieving an Overburden groundwater elevation
lower than that of finished floors in the Plant A
clearwell, the filtered water reservoir, control
chambers, raw water forebays and high service
pump forebay.
(b) The design of the CWTP Collection
Systems will allow for partially flooded and
non-flooded operation, and provide operational
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III-4
flexibility sufficient to adjust Overburden
groundwater elevations adjacent to critical
pipelines and structures. This operational
flexibility may require/ but is not limited to,
additional sump installations, added pumping
capacity, or modifications of alignments
conceptually indicated in the Judgment.
2.3 Collection System Operation
(a) The CWTP Collection Systems will be operated over
a range of groundwater elevations so as to allow the systems to:
(i) minimize the submergence of active
pipelines and structures in Overburden
groundwater.
(ii) minimize partial dewatering of timber
support pilings beneath these structures.
(iii) maintain, in conjunction with appropriate
CWTP operations, an outward gradient from
CWTP structures and water lines to the
surrounding Overburden, and
(iv) seek to minimize upward vertical gradients
from the Bedrock to the Overburden at the
CWTP outside of the RRT and Site Barrier
Walls.
(b) The operations described in subparagraph (a)
shall be defined and limited by operating procedures described
in a collection system operations manual to be included in the
design plans and specifications for this system submitted to
the Governmental Parties.
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III-5
(c) Subparagraphs (a) and (b) shall be deemed to
supersede the requirements of Paragraphs C(4)-(6) and D(4),
Addendum II of the Judgment.
2.4 CWTP Service Line Monitoring
and Response Actions
2.4.1 Purpose
The position and potential movement of the CWTP
42-inch diameter low service lines will be monitored to
evaluate the effects on the timber piles supporting these lines
of lowering the Overburden water table as a result of remedial
system operations at the CWTP.
2.4.2 Monitoring Program
The CWTP Service Line Monitoring Program shall be
implemented as follows:
0 Proceed with the installation of the
tile collection system and dewatering
as provided in Plan B;
0 Monitor the position of the 42-inch
diameter low service discharge line for
any movement; and
0 Monitor the volume of groundwater
collected from the drain tile system
pursuant to Paragraph C(l)(b), Addendum
II of the Judgment, to determine
possible leakage from the 41-inch
diameter low service lines due to
dewatering by remedial systems.
2.4.3 Response Actions
If movement of the low service lines is detected, or
if there is leakage from those lines/ due to dewatering by
remedial systems, OCC shall promptly so notify the Governmental
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Parties and take action (including, as appropriate, raising of
the groundwater table) in consultation with the City which is
necessary and appropriate to provide adequate support for the
service lines in all affected areas and adequate water pressure
in the City's water distribution system.
2.5 CWTP Vertical Gradient Monitoring
OCC shall implement the CWTP Plant Vertical Gradient
Monitoring Program described in this section.
2.5.1 Objective
The objective of this monitoring program is to monitor
and record the vertical hydraulic gradient between the Bedrock
and Overburden at the CWTP.
2.5.2 Program Implementation
(a) Three shallow Bedrock piezometers shall
be installed by OCC outside of the Site and RRT
Barrier Walls at the CWTP, as shown on Figure
III-2.
(b) Water levels will be measured monthly
by OCC in the three shallow Bedrock piezometers
described above at the same time as water levels
are measured in the CWTP maintenance piezometers
and in the CWTP Collection System wetwells
pursuant to Paragraph D, Addendum II of the
Judgment. Measurements will be evaluated to
determine the direction and magnitude of the
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vertical hydraulic gradient between the Bedrock
and Overburden at the CWTP outside of the Site
and RRT Barrier Walls. Results will be reported
monthly to the Governmental Parties.
(c) This monitoring system shall be
installed concurrent with installation of the
CWTP Collection Systems described in Section 2.1
above. This monitoring program shall be
initiated upon operation of the CWTP Collection
System.
2.6 Emerald Channel Intake Tunnel Monitoring
(a) Paragraph E(ll)(l), Addendum I of the Judgment is
replaced by the following:
"(1) In lieu of the activities described in
subparagraphs (a)-(j), Hooker may, at its option,
undertake the sleeving described in subparagraph
(k). If Hooker undertakes such sleeving, Hooker
and the City shall not thereafter conduct any
activities described in subparagraphs (a)-(j) or
subparagraph (14)."
(b) After the last sentence of Paragraph E(2),
Addendum II of the Judgment, the following sentence is added:
"Hooker shall submit the statistical
protocol to the Governmental Parties for their
review and approval. The submission shall
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III-8
include all data and methodologies used in
developing the statistical protocol."
(c) The introductory sentence of Paragraph E(5),
Addendum II of the Judgment is replaced by the following:
"If statistical analysis of data pursuant to
subparagraphs (2)-(4) indicates that both of the
conditions described in subparagraph (4) exist,
and if the Emerald Channel Intake Tunnel and
Shaft have not been sleeved by Hooker, the City
and Hooker shall take the following actions:"
(d) Paragraph E(7), Addendum II of the Judgment is
replaced by the following new paragraphs £(7), E(8) and E(9):
"(7) If Hooker undertakes the sleeving of
the Emerald Channel Intake Tunnel and Shaft, the
City shall thereafter conduct Emerald Channel
Intake Tunnel Monitoring to determine the long
term effectiveness of the newly relined intake
tunnel and shafts. Hooker and the City shall
proceed as described below if both of the
conditions described in subparagraph (4) exist.
"(a) The City shall immediately so
notify Hooker and the other Governmental
Parties.
"(b) The City shall promptly make any
appropriate modifications to its operational
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or maintenance activities at the Treatment
Plant which are required to address CWTP
Monitoring Parameters (as defined in
Paragraph 3.1.2.1.(c), Appendix III of the
RRT Stipulation) entering the Treatment
Plant water supply.
"(c) Upon receiving said notification,
Hooker shall promptly undertake an
assessment, using all available data, to
evaluate the extent, if any, to which the
condition is a result of the migration of
chemicals from the Landfill Site or the
Hooker Buffalo Avenue Plant through the
lining of the New Intake System. To the
extent required to achieve this objective,
the assessment shall include the analysis of
water samples from the Niagara River in the
vicinity of the Emerald Channel and/or East
Branch Intake Shafts, as appropriate; from
the shoreshaft of the New Intake System; and
from appropriate locations within Treatment
Plant structures. Hooker shall submit the
assessment, together with all underlying
data, to the Governmental Parties within
sixty (60) days following notification. If
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it is determined, either by agreement of
Hooker and the Governmental Parties or by
the order of the Court, that chemicals which
have migrated from the Landfill Site or the
Hooker Buffalo Avenue Plant are entering the
Treatment Plant water supply through the
lining of the New Intake System, the parties
shall proceed as described in subparagraph
(8) below.
"(d) Hooker shall reimburse the City
for reasonable costs incurred under
Subparagraph (b) to address chemicals which
have migrated from the Landfill Site or
Hooker Buffalo Avenue Plant.
"(8) If so required pursuant to subparagraph
(7)(c), the following response actions will be
undertaken:
"(a) If such chemicals entering the
Treatment Plant water supply as described in
subparagraph (7)(c) are not adequately
addressed pursuant to subparagraph (7)(b),
Hooker shall, upon written request by the
Governmental Parties, conduct a study to
determine what Requisite Remedial
Technology, if any, is required to address
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III-ll
the condition. This study shall be
submitted no more than 120 days following
the aforementioned request.
"(b) Following such submission,
pursuant to Paragraph 6(9), Addendum I of
the Judgment, a determination shall be made
regarding what Requisite Remedial
Technology, if any, shall be implemented to
address chemicals entering the Treatment
Plant water supply as described in
subparagraph (7)(c).
"(9) Hooker shall implement all remedial
action required by the RRT determination
described in subparagraph (8)(b). The City will
be responsible for those costs whicn represent
maintenance, repairs or replacements which the
City would otherwise be required to perform at
the same level and in the same manner in the
absence of chemicals in the Treatment Plant water
supply which have migrated from the Landfill
Site."
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2.7 Distribution Water Monitoring
Paragraph F, Addendum II, of the Judgment is replaced
by the following:
"F. Within 30 days following completion of all
activities described in Paragraph E of Addendum I, as modified
pursuant to Appendix III, Section 2.0 of the RRT Stipulation,
the City and Hooker shall initiate the following actions to
monitor the quality of water supplied to the distribution
system by the Treatment Plant:
"(1) The City shall take a daily (work day)
grab sample of distribution water from a
distribution water tap located at the Treatment
Plant. Such samples shall be analyzed by the
City for chemical parameters described in
subparagraph E(l)(b) of Addendum II at the
detection levels specified therein.
"(2) (a) In addition to the above, the
City may develop and implement a distribution
water monitoring program for any additional
chemical. If any such chemical is detected in
four consecutive samples, any signatory party may
propose that such chemical be added to chemical
parameters described in subparagraph (1). Such
chemicals shall be added if it is determined,
either by agreement of Hooker and the
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Governmental Parties or by order of the Court,
that such action is appropriate to collect data
necessary to assess the impact, if any, on the
quality of the Treatment Plant distribution water
resulting from chemicals which may have migrated
from the Landfill Site.
"(b) As used in this Paragraph F, the
term "Treatment Plant Monitoring Parameter(s)"
refers to each chemical described in subparagraph
F(l) and each chemical added thereto pursuant to
subparagraph F(2)(a).
"(3) The City shall make available to
Hooker and EPA/State all data generated by the
monitoring program, including QA/QC data.
"(4) (a) Using all City monitoring data
for Treatment Plant Monitoring Parameters
collected during the initial 12 months of
observation, Hooker shall establish a baseline
level of finished water quality against which
subsequently-collected chemical concentration
data will be evaluated. In addition, Hooker
shall develop a statistical protocol, using
non-parametric methods, comparable to the methods
described in subparagraph E(2), Addendum II, to
assess whether subsequently-collected chemical
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concentration data indicates a statistically
significant increase over the baseline level;
provided, however, that the statistical analysis
shall be carried out using the 0.01 significance
level (99% confidence level). The protocol shall
take appropriate account of seasonal trends in
water temperature and other factors in selecting
time periods and intervals for comparison.
Hooker shall submit the statistical protocol to
the Governmental Parties for their review and
approval. The submission shall include all data
and methodologies used in developing the
statistical protocol.
"(b) Every five years during the
course of such distribution water monitoring,
Hooker shall assess the appropriateness of the
baseline level taking into account the then
existing quality of the water in the Emerald
Channel and/or East Branch Intake Shaft, the
shoreshaft, and the distribution water. Based on
such data, the baseline level shall be modified,
as appropriate, to reflect such water quality
conditions.
"(5) Prior to and after the establishment
of the baseline level and statistical protocol
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111-15
described in subparagraph (4), the City and
Hooker shall proceed as described in subparagraph
(7) if monitoring described in subparagraph (1)
or (2) indicates either of the following: (a)
four consecutive samples having a Treatment Plant
Monitoring Parameter concentration level in
excess of one-half of the maximum contaminant
level established under federal or state statutes
applicable to any such parameter; or (b) a
verified sample having a Treatment Plant
Monitoring Parameter concentration level which
requires the City to make a notification,
pursuant to State Sanitary Code, Public Water
Supplies, Subpart 5-1, that a violation of a
maximum contaminant level has occurred.
"(6) After the establishment and approval
of the baseline level and statistical protocol
described in subparagraph (4), the City and
Hooker shall proceed as described in subparagraph
(7) in the event concentrations of a Treatment
Plant Monitoring Parameter indicate a
statistically significant increase over the
established baseline level.
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"(7) If so required pursuant to
subparagraph (5) or (6), the City and Hooker
shall take the following actions:
"(a) All signatory parties shall be
immediately so notified;
"(b) The City shall promptly make any
appropriate modifications to its operational or
maintenance activities at the Treatment Plant
which are required to address Treatment Plant
Monitoring Parameters entering the Treatment
Plant water supply. Likewise/ Hooker shall make
any modifications to its operational and
maintenance activities relating to the Treatment
Plant remedial systems (excluding the New Intake
System) which are so appropriate.
"(c) Hooker shall promptly undertake
an assessment of the data collected pursuant to
this Paragraph F, data from the CWTP Vertical
Gradient Monitoring Program (see RRT Stipulation,
Appendix III, Section 2.5) and all other
available data, to evaluate the extent, if any,
to which the condition is a result of the
migration of Treatment Plant Monitoring
Parameters from the Landfill Site. If the
condition is to any extent the result of such
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111-17
migration, Hooker shall identify the location
where such chemicals are entering the Treatment
Plant water supply. To the extent required to
achieve this objective, the assessment shall
include the analysis of water samples from the
Niagara River in the vicinity of the Emerald
Channel and/or East Branch Intake Shafts, as
appropriate; from the shoreshaft of the New
Intake System; and from appropriate locations
within Treatment Plant structures. In addition
if such condition occurred during and/or
immediately subsequent to the use of the
Treatment Plant 48-inch raw water line, Hooker's
assessment shall also include the analysis of
water samples from the Niagara River in the
vicinity of the Treatment Plant 48-inch raw water
line intake structure and the pump station
forehcy. Hooker shall submit the assessment
report, together with all underlying data, to the
Governmental Parties within sixty (60) days
following the aforementioned notification. In
the event it is determined either by agreement of
Hooker and the Governmental Parties or by the
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order of the Court, that chemicals which have
migrated from the Landfill Site are entering the
Treatment Plant water supply, the parties shall
proceed as described in subparagraph (8) below.
"(d) The City shall be reimbursed by
Hooker for reasonable costs incurred under
subparagraph (7)(b) to address chemicals entering
the Treatment Plant water supply which migrated
from the Landfill Site.
"(8) If so required pursuant to
subparagraph (7)(c), the following response
actions shall be undertaken:
"(a) If Landfill Site chemicals
determined to be entering the Treatment Plant
water supply per subparagraph (7)(c) are not
adequately and promptly addressed pursuant to
subparagraph (7)(b), Hooker shall, upon written
request by the Governmental Parties,
ezpeditiously conduct a focused feasibility
study. The purpose of the study is to evaluate
alternative Treatment Plant Remedial System
Modifications, if any, which could be implemented
to address the conditions. As used herein,
Treatment Plant Remedial System Modifications
("TPRS Modifications") are defined to consist
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solely of either the installation of additional
components to the Treatment Plant Collection
\
Systems/ or the installation of purge wells which
would achieve the same performance objective as
such additional Collection System components. In
addition, in the event that chemicals which
migrated from the Landfill Site are determined to
be entering the Treatment Plant water supply in
the vicinity of the Treatment Plant 48-inch raw
water line, the TPRS Modification alternatives
shall also include lining or sealing interior
portions of such line. OCC's focused feasibility
study will address at least the following factors:
(1) The nature and extent of the condition
triggering the response action;
(2) The degree to which the TPRS Modifications
will enable the Treatment Plant remedial
program to prevent further response action
triggers and to meet the system design
objectives of Paragraph G, Section 1.0,
Appendix I; and
(3) The cost and schedule for implementing such
TPRS Modifications.
This study shall be submitted to the Governmental
Parties within 60 days after the aforementioned
request by the Governmental Parties.
"(b) Within 60 days following receipt
of Hooker's focused feasibility study, the
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Governmental Parties will respond in writing to
the submission. The Governmental Parties will
either approve the recommendations in Hooker's
feasibility study or propose (either from
Hooker's feasibility study or any similarly
prepared study of its own) cost effective TPRS
Modifications which enable the Treatment Plant
remedial systems to meet the system design
objectives of Paragraph G, Section 1.0, Appendix
I, and effectively prevent further response
action triggers. Hooker will be required to
implement the TPRS Modifications proposed by the
Governmental Parties unless, upon the evidence,
the Court determines:
(1) that the Governmental Parties proposal does
not satisfy the definition of the TPRS
Modifications set forth in subparagraph
(8)(a), or
(2) that considering the factors set forth in
subparagraph (8)(a)(l)-(3) and all relevant
monitoring data, it would be arbitrary and
capricious to require Hooker to implement
the proposed TPRS Modifications.
"(9) TPRS Modifications implemented as a
result of a focused feasibility study will be
deemed effective when the Treatment Plant
Monitoring Parameter concentration levels have
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been reduced to previously existing baseline
levels and trend analyses for each parameter do
not indicate a statistically significant
increasing trend.
"(10) If, after Hooker implements all
required TPRS Modifications pursuant to
subparagraph (8)(b), a response action described
in subparagraph (5) or (6) is still being
triggered, and if Hooker and the Governmental
Parties agree or the Court determines that no
further TPRS Modification(s) will enable the
Treatment Plant remedial systems to meet the
system design objectives of Paragraph G, Section
1.0 of Appendix I and to prevent response action
triggers, Hooker shall undertake an RRT study to
assess what response actions, if any, using
Requisite Remedial Technology, should be
implemented to satisfy the goals of the
Judgment. The RRT Study shall include analysis,
review and consideration of all available data
regarding Treatment Plant Monitoring Parameters
and other relevant data that is available at that
time or that is provided to Hooker by EPA/State.
The RRT Study shall also include an evaluation of
whether the implementation of any other remedial
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technology, including without limitation, lining
the interior of water-bearing structures, the
relocating of underground water lines to the
ground surface, or the placing of water lines in
dewatered vaults, would be more effective than
modifications to the installed remedial systems
in achieving the goals of the Judgment; provided,
however, that such technology satisfies the
definition of Requisite Remedial Technology set
forth in Paragraph 4 of the Judgment. This study
shall be submitted to the Governmental Parties
within 60 days following the aforementioned
notification.
"(11) Hooker shall implement all remedial
actions required by the determination described
in subparagraph (10) above in accordance with a
schedule approved by the Governmental Parties.
The City will be responsible for those costs
which represent maintenance, repairs or
replacements which the City would otherwise be
required to perform at the same level and in the
same manner in the absence of chemicals in the
Treatment Plant water supply which have migrated
from the Landfill Site.*
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2.8 Monitoring Program Assessment
Paragraph G, Addendum II of the Judgment is
replaced by the following:
"G. Based on all available data, an
assessment of monitoring programs referenced in
Paragraphs E and F of Addendum II shall be made
five years after the New Intake System is put
into operation by the City, and a reassessment
shall be made once every ten years thereafter by
Hooker to evaluate the following, at a minimum:
the number and location of sampling points
referenced in Paragraphs E and F of Addendum II;
the frequency of such sampling; the parameters to
be analyzed; the detection and action levels
related to such parameters; the adequacy of the
statistical procedures used to assess the data;
and frequency of future reassessments per this
section. An unscheduled reassessment may be
undertaken if the party seeking the .reassessment
demonstrates that such reassessment is
necessary. Following such assessment or
reassessment, appropriate modifications to the
monitoring programs described in Addendum II
shall be made either by agreement of Hooker and
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the Governmental Parties, or by order of the
Court."
2.9 Inoperative Paragraph
Paragraph E(13), Addendum I, of the Judgment is
inoperative.
2.10 48-Inch Raw Water Line Monitoring
The City shall develop sampling and analysis protocols
to assess the quality of water in the 48-inch raw water line
for each of the following events:
(i) Use of the 48-inch raw water line during a
non-emergency maintenance and/or cleaning
activity; and
(ii) Use of the 48-inch raw water line during an
emergency which requires a supplemental
source of raw water.
The protocols shall include sampling and analysis of an
appropriate number of water samples representative of the water
in such line, and/or being supplied by such line. The samples
shall be analyzed for the Treatment Plant Monitoring Parameters
set forth in subsection 2.7, paragraph F(2)(b). The protocols
will be submitted to EPA/State for approval at least 120 days
prior to the scheduled date for City use of the newly relined
bedrock intake tunnel.
2.11 48-Inch Raw Water Line Protection
Based on the Additional Investigations (as defined in
subsection 3.2.2 below), and monitoring programs undertaken
pursuant to Section 3.2 and all other relevant and available
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data/ OCC shall prepare and submit to the Governmental Parties
an RRT study assessing what actions, if any, using Requisite
Remedial Technology, are required to protect water in the
48-inch intake line from impact by the NAPL plume (including
the associated APL within the NAPL plume). In no event will
the eastern portion of the Barrier Wall be located east of the
48-inch line. If NAPL is found east of the Barrier Wall
location, then it will be addressed pursuant to Appendix I,
Subsection 2.3.1 C5 and C6. OCC shall prepare and submit the
RRT study no later than 120 days following the determination
that Plan B will be implemented.
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3.0 INTERIM CWTP MONITORING
AND RESPONSE ACTION PLAN
3.1 Interim Drinking Water Monitoring
and Response Actions Program
3.1.1 Purpose
The purpose of this Program is to monitor for the
possible presence of chemicals which migrated from the Landfill
Site in the water supplied by the CWTP during the interim
period before the new CWTP described in Plan A or remedial
systems described in Plan B are fully operational and to take
response actions in the event that any such chemicals are
detected.
3.1.2 Water Monitoring
3.1.2.1 (a) The City shall continue to monitor
the current raw and finished drinking water from sampling
locations currently being utilized for the following list of
CWTP Monitoring Parameters at the levels specified in
subparagraph E(l)(b), Addendum II of the Judgment:
trichlorobenzenes
hezachlorobutadiene (C-46)
hezachlorocyclopentadiene (C-56)
tetrachlorobenzenes
hezachlorobenzene (HCB)
2,4,5 trichlorophenol (2,4,5 TCP)
(b) In addition to the above, the City may
develop and implement a water monitoring program for any
additional chemicals. If any such chemical is detected in four
consecutive samples, any signatory party may propose that such
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chemical be added to the list described in subparagraph
3.1.2.1(a). Such chemicals shall be added if it is determined,
either by agreement of OCC and the Governmental Parties or by
order of the Court, that such action is appropriate to collect
data necessary to assess the impact, if any, on the quality of
the CWTP water supply resulting from chemicals which may have
migrated from the Landfill Site.
(c) As used in this Section 3.0, the term "CWTP
Monitoring Parameter(s)" refers to each chemical listed in
subparagraph (a) and each chemical added to the list pursuant
to subparagraph (b).
3.1.2.2 The City shall make available to OCC
and EPA/State all data generated by the monitoring program,
including QA/QC data.
3.1.2.3 Using City monitoring data provided to
OCC for CWTP Monitoring Parameters for at least 12 consecutive
months prior to September 1. 1990, OCC shall establish baseline
levels of raw water and finished water quality against which
subsequently-collected chemical concentration data will be
evaluated. In addition, OCC shall develop a statistical
protocol, using non-parametric methods, to assess whether
subsequently-collected chemical concentration data indicates a
statistically significant increase over the baseline level;
provided, however, that the statistical analysis shall be
carried out using the 0.05 significance level (95% confidence
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level) for raw water results and the 0.01 significance level
(99% confidence level) for finished water. The protocol shall
take appropriate account of seasonal trends in water
temperature and other factors in selecting time periods and
intervals for comparison. Within 90 days following the lodging
of the RRT Stipulation, OCC shall submit the statistical
protocol to the Governmental Parties for their review and
approval. The submission shall include all data and
methodologies used in developing the statistical protocol.
3.1.3 Response Actions
3.1.3.1 Prior to and after the establishment of
the baseline level and statistical protocol described in
subparagraph 3.1.3.2, the City and OCC shall proceed as
described in subparagraph 3.1.3.3 if monitoring pursuant to
subparagraph 3.1.2 indicates either of the following: (a) four
consecutive samples having a CWTP Monitoring Parameter
concentration level in excess of one-half of the maximum
contaminant level established under federal or state statutes
applicable to any such chemical; or (b) a verified sample
having a CWTP Monitoring Parameter concentration level which
requires the City to make a notification/ pursuant to State
Sanitary Code, Public Water Supplies, Subpart 5-1, that a
violation of a maximum contaminant level has occurred.
3.1.3.2 After the establishment and approval of
the baseline level and statistical protocol described in
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111-29
subparagraph 3.1.2.3, the City and OCC shall proceed as
described in subparagraph 3.1.3.3 in the event concentrations
of a CWTP Monitoring Parameter indicate a statistically
significant increase over the established baseline level.
3.1.3.3 If so required pursuant to subparagraphs
3.1.3.1 or 3.1.3.2, the City and OCC shall take the following
actions:
(a) All signatory parties shall be
immediately so notified; and
(b) The City shall promptly make any
appropriate modifications to its operational and
maintenance activities which are required to
address CWTP Monitoring Parameters entering that
CWTP water supply.
(c) OCC shall promptly undertake an
assessment to evaluate whether the condition is
the result of the migration of chemicals from the
Landfill Site into the CWTP water supply system
and/ if so, shall identify the location where
such chemicals are entering the CWTP water
supply. To the extent required to achieve this
objective, the assessment shall include the
analysis of water samples collected from the
Niagara River in the vicinity of the 48-inch
intake, from the shoreshaft and from appropriate
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111-30
locations within CWTP structures. OCC shall
submit an assessment report, together with all
underlying data, to the Governmental Parties
within 60 days following the aforementioned
notification. In the event it is determined,
either by agreement of OCC and the Governmental
Parties or by order of the Court, that chemicals
which have migrated from the Landfill Site are
entering the CWTP water supply, the parties shall
proceed as described in subparagraph 3.1.3.4.
(d) The City shall be reimbursed by OCC for
reasonable costs incurred under subparagraph (b)
to address chemicals entering the CWTP water
supply which migrated from the Landfill Site.
3.1.3.4 If so required pursuant to subparagraph
3.1.3.3(c), the following actions shall be undertaken:
(a) If Landfill Site chemicals determined
to be entering the CWTP water supply per
subparagraph 3.1.3.3(c) are not adequately and
promptly addressed pursuant to subparagraph
3.1.3.3.(b) above, OCC shall ezpeditiously
conduct a "focused RRT study" to assess what
response actions, if any, using Requisite
Remedial Technology, should be implemented to
satisfy the goals of the Judgment. The study
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111-31
shall include analysis, review and consideration
of all available data regarding CWTP Monitoring
Parameters and other relevant data that is
available at that time or that is provided to OCC
by EPA/State. This study shall be submitted to
the Governmental Parties within 60 days following
the aforementioned determination. As used in
this subsection and subsection 3.2.3 below,
•focused RRT Study" means a study described in
Paragraph B(8), Addendum I of the Judgment which
evaluates only the following actions using
Requisite Remedial Technology:
The lining of operative CWTP water
service lines,
Installation of CWTP collection
system(s); and/or
Installation of purge wells at the CWTP.
(b) Following the submission described in
subparagraph (a), a determination shall be made,
pursuant to Paragraph B(9), Addendum I of the
Judgment, regarding what Requisite Remedial
Technology, if any, should be implemented by OCC
to address chemicals entering the CWTP water
supply which have migrated from the Landfill Site.
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111-32
(c) OCC shall implement all remedial
actions required by the determination described
in subparagraph (b). The City will be
responsible for those costs which represent
maintenance, repairs or replacements which the
City would otherwise be required to perform at
the same level and in the same manner in the
absence of chemicals in the CWTP water supply
which have migrated from the Landfill Site.
3.2 Interim NAPL Presence Monitoring
and Response Action Program
3.2.1 Purpose
The purpose of this program is to assess whether NAPL
is present on CWTP property in the Overburden outside
identified areas of the defined S-Area Overburden NAPL plume
and to take appropriate response actions in the event NAPL is
identified.
3.2.2 Investigations
OCC shall undertake the investigations regarding the
presence of NAPL in the vicinity of the 48-inch raw water
intake described in the document "Additional Investigations,
City of Niagara Falls Drinking Water Treatment Plant, July 31,
1989" ("Additional Investigations"). OCC will use its best
efforts to complete field work for the Additional
Investigations by November 1, 1990. If NAPL is identified
during installation of any borings or wells installed pursuant
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111-33
to the Additional Investigations, OCC shall conduct NAPL
mobility testing as described in Paragraph E(4)(b), Addendum I
of the Judgment on appropriate soil samples.
3.2.3 Monitoring Program
Each of the four NAPL monitoring wells, the existing
well OW-265, and the monitoring wells east and west of the
D-Building at the CWTP, as shown in Figure III-2, shall be
initially monitored quarterly for the presence of NAPL. This
will be accomplished by lowering a bottom loading bailer to the
bottom of the well and examining the contents of the bailer
upon removal from the well. The field observation data shall
be submitted to the Governmental Parties following each
quarterly monitoring event. After completion of construction
of the eastern-most barrier wall between the Landfill Site and
the existing CWTP, such monitoring will be conducted annually.
Such monitoring shall be continued until the earlier of the
following: (i) OCC demonstrates that remedial or monitoring
systems have been installed which render such monitoring
unnecessary; or (ii) drinking water supply operations have
ceased at the existing CWTP.
3.2.4 Response Actions
If NAPL is identified in any boring or well described
in subparagraphs 3.2.2 or 3.2.3, OCC shall, within 60 days,
submit to the Governmental Parties a focused RRT Study (as
defined in subsection 3.1.3.4) assessing what response actions,
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13493-6:0.C.
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111-34
if any, are required to assure that the NAPL (including the
associated APL within the NAPL plume) will not impact Jtllfi CWTP
water supply.
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111-35
4.0 EASTERN PORTION STUDY
Paragraph E(23), Addendum I of the Judgment is
replaced by the following:
"(23)(a) The eastern portion of the
existing CWTP, as shown conceptually in Figure
E-9 of the Judgment ("Eastern Portion"),
including all studies, investigations and
remedial measures, if any, relating thereto, will
be initially addressed by the City under the
State's Inactive Hazardous Waste Disposal Site
Program, Environmental Conservation Law, Article
27, Title 13. The City shall perform the "Phase
II" investigation which, under the Judgment, was
to be performed by EPA. Within 60 days after DEC
approval of the City's "Phase II" study, the City
shall make a determination whether to proceed
with an RRT Study under subparagraph (b) or
whether to continue to proceed under the State's
Inactive Hazardous Waste Disposal Site Program.
If a consent order between the State and the City
is achieved, the City will perform the
investigation and any necessary remediation of
the Eastern Portion pursuant to the terms of that
consent order, and may apply, as appropriate,
subject to all eligibility requirements, for
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111-36
reimbursement under the Environmental Quality
Bond Act of 1986 ("EQBA") and any subsequent
Environmental Bond Acts. The City shall not be
eligible for reimbursement under EQBA for any
"Phase II" investigation or for any investigation
of, or remediation costs for, any OCC wastes
identified on said Eastern Portion. Such consent
order under the State's Inactive Hazardous Waste
Disposal Site Program may require disposal of
Eastern Portion wastes in facilities other than
the S-Area Landfill.
(b) If the City determines to proceed with
an RRT Study in accordance with subparagraph (a),
the City shall conduct a study to assess what
Requisite Remedial Technology, if any, is
necessary to address such situation. Thereafter,
the parties shall proceed as described in
subparagraphs B(8) and (9); provided, however,
that for the purposes of such. study and any
subsequent action relating thereto pursuant to
subparagraphs B(8) and (9) and Paragraph 4 of the
Judgment, whichever obligations are applicable to
Hooker in those subparagraphs shall instead be
solely applicable to the City, and Hooker shall
have no obligations in such instance.
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(c) Regardless of which of the two options
described in subparagraph (a) the City chooses to
pursue/ OCC shall have no obligations for any
studies, investigations or remedial measures
regarding the Eastern Portion performed under
either option, except that, consistent with good
engineering practice and prior to final Landfill
Site capping, OCC will provide in accordance with
the Remedial Waste Management Plan (Appendix IV
to the RRT Stipulation) (i) disposal capacity at
the Landfill Site prior to final capping for any
solid waste generated by such investigative and
remedial measures, if any, undertaken on the
Eastern Portion, and (ii) treatment and/or
incineration capacity at OCC's Buffalo Avenue
Plant Site for liquid waste generated during such
investigative activities. The City shall be
responsible for transporting such wastes for
disposal at the Landfill Site or treatment and/or
incineration, as appropriate. Issues relating to
City compensation to OCC, if any, for disposal of
Eastern Portion solid waste at the Landfill Site
and treatment and/or incineration of Eastern
Portion liquid waste shall be the subject of a
separate agreement between OCC and the City.
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II1-38
(d) If the City proceeds under the State's
Inactive Hazardous Waste Disposal Site Program,
after completion of the "Phase 11" investigation
pursuant to subparagraph (a) above, the City and
State shall furnish to EPA copies of all reports
concerning the above investigation and remedial
activities at the Eastern Portion. Nothing
herein
shall prevent the EPA from submitting timely
comments on reports related to the Eastern
Portion; however, the parties shall consider, as
appropriate, but are not obligated to respond to
or adopt any such comments."
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111-39
5.0 EXISTING CWTP REMEDIAL/CLOSURE PLAN
The plan for the existing CWTP remediation and closure
is set forth in Attachment C hereto.
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13493-6:0.C.
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FIGURES
-------
OMH6A
I 9610
MANHOLE INVERT ELEVATION
PREVIOUSLY PROPOSED WTP GROUNOWA1ER
COLLECTION SYSTEM
ADDITIONALLY PROPOSED GROUNDWA1ER
COLLECTION SYSTEM
FILTERED WATER
RESERVOIR
NEWLY PROPOSED MANHOLE
INVERT ELEVATION
TOP OF CLAY ELEVATION
SLUDGE
THICKENER
PUMP
STATION
III-
COLLECTION SYSTEM FOR
30*0 WASTEWATER DRAIN
DPHHPAU
MH20A
(555.8]
GROUNDWATER
CHEMICAL BLDa
6 OFFICES
-------
CONCEPTUAL
FUTURE
PROPERTY BOUNDARY FOR
WESTERN PORTION OF DWTP
W28I®
W280®
DRINKING
WATER TREATMENT PLANT
figure III-2
MONITORING WELLS
DRINKING WATER TREATMENT PLANT
Occidental Chemical Corporation
NAPL MONITORING WELL
BEDROCK PIEZOMETER
OVERBURDEN SURVEY
WELLS (EXISTING)
1769-23/05/90-L-0
-------
ATTACHMENT A
Plan A Milestone Schedule
-------
ATTACHMENT A
Plan A Milestone Schedule
(New City Water Treatment Plant)
CONSTRUCTION
1. All Parties Sign and Lodge the RRT
Stipulation with the Court
2. City Council Pass Bond Resolution
3. City Submit Process/Treatability Studies/
Pilot Plant Program to NYSDOH for Approval
4. Receive NYSDOH Approval of Studies/Pilot
Work
5. Start NYSDOH Approved Studies/Pilot Work
6. Start Facilities Planning
7. City Submits Facilities Plan to NYSDOH
8. Receive NYSDOH/EPA Endorsement of Facility Plan
9. Supplemental Bond Resolution or Other
Financial Authorization Passed by City
Council (if needed)
10. Start Detailed Design
11. City Submit Final Application for 601 and
608 Permits to NYSDEC
12. Receive Approved 601 and 608 Permits from
NYSDEC and associated Corps of Engineers
Permits
13. City Submits Detailed Design to NYSDOH
14. Receive NYSDOH/EPA Approval on Design
15. Supplemental Bond Resolution or Other
Financial Authorization Passed by
City Council (if needed)
Months afte:
Stipulation
Lodging wit!
the Court
5
6
12
21
23
24
26
29
32
36
38
39
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- 2 -
Months Afte
Stipulation
Lodging Wit
the Court
16. Notice to Proceed to Contractor(s)
17. Receive First Payment Check from OCC
18. Construction Substantially Complete
19. NYSDOH Completed Works Approval Received
and New Water Plant On-Line
20. Demolition of Existing Plant Complete
21. Title to Existing Plant Transferred to OCC
45
46
69
71
76
77
SITE ACQUISITION
1. Remedial Investigation and Delisting Petition
for Portion of NYPA Buffalo Avenue Site
Submitted to NYSDEC
2. Delisting Action Approved by NYSDEC or Other
Acceptable Authorization(s) by NYSDEC
3. Site Acquisition Completed
17
20
21
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13493-6:D.C.
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APPENDIX VI
INSURANCE CERTIFICATE FORM
-------
Duration
(months)
L.
CAPPING PROCTAMS
L1A. Plans & Specifications
LIB. EPA/State Review If
Approval
L1C Award Contract
LID. Installation
LIE. Install East Cap
3
2
6
4
M.
N.
SPECIAL CONSTRUCTION . HEALTH k SAFETY
MIA. EPA/State Review fc
Approval 1
M1B. Install Monitoring Stations 2
MIC. Perform 30 day Background
Study 1
MID. EPA/State Review &
Approval 3
WASTE CELL CONSTRUCTION
N1A. Plans and Specifications 2wks
NIB. EPA/State Review &
Approval 3
NIC. Award Contract 2
N1D. Contraction of Cell 1 1
Float
(months)
17
17
17
26
0
2
2
2
2
21/2
21/2
21/2
1
Critical
No
No
No
No
Yes
No
No
No
No
No
No
No
No
Activity is not critical. However, no float time is shown on the bar chart since the activity is
tied to an on-going monitoring, operational or data collection activity. Some float time may
actually be available as a delay in the start-up of the monitoring, operational or data
collection activity would not affect the critical path.
11
-------
Duration
(months)
Float
(months)
Critical
K. BEDROCK MONITORING SYSTEM
Kl. Performanrp PipmmPt^
K2.
K3.
K4.
K1A. Plans and Specifications
K1B. EPA/State Review fc
Approval
K1C Award Contract
KID. Installation
K1E. Perform Hydraulic,
Monitoring
APL Dispersion Testing
K2A. Award Contract
K2B. Installation
K2C. Inject Tracer
K2D. Collect Data
K2E. Submit Results
K2F. Plans and Specifications
Monitoring Program (if required)
NAPL Tracer Testine
K3A. Award Contract
K3B. Installation
K3C. Inject Tracer Stage I
K3D. Collect Data Stage I
K3E. Submit Results
K3F. Inject Tracer Stage U
K3G. Monitor Stage n
Chemical Monitorine Program
K4A. Award Contract
K4B. Installation
K4C. Perform Monitoring
2
3
2
6
ongoing
1
1
Iwk.
58
2
ongoing
1
1
Iwk.
35
2
Iwk.
ongoing
2
1
ongoing
K5.
Environmental Monitoring Program
K5A. Plans and Specifications 2
K5B. EPA/State Review &
Approval 3
K5C. Award Contract 2
K5D. Installation 2
K5E. Monitoring ongoing
maximum
•
»
•
»
maximum
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
10
-------
J2.
J1E
J1F.
JIG.
J1H.
JH.
JU.
J1K.
J1L.
JIM.
JIN.
API
J2A.
J2B.
J2C.
J2D.
J2E.
J2F.
J2G.
J2H.
J2I.
J2J.
J2K.
J2L
J2M.
J2N.
J2O.
Duration
(months)
NAPL Recovery Tests and Plans
and Specifications Phase I
EPA/State Review &
Approval
Award Contract Phase n
Install Phase II
Operate Phase II
Plans and Specifications
Phase III
EPA/State Review &
Approval
Award Contract Phase HI
Install Phase III
Operate Phase III
Recovery Wells
Plans, Specificaitons and
Protocols
EPA/State Review &
Approval
Award Contract
Installation
Pump Tests and Evaluate
Data
Complete Remaining Pump
Tests and Plans and
Specifications Phase II
EPA/State Review &
Approval
Award Contract Phase n
Install Phase II
Operate Phase II
Plans and Specificaitons
Phase in
EPA/State Review *
Approval
Award Contract Phase HI
InstallPhase HI
Operate Phase HI
5
3
2
5
23
2
3
2
2
ongoing
(
3
2
2
2
4
3
2
5
24
2
3
2
2
ongoing
Float
(months)
14
14
14
14
0
0
0
0
completed
12
12
12
0
0
0
Critical
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
No
No
No
Yes
(first 2 months)
Yes
No
No
No
Yes
(first 15 months)
Yes
Yes
Yes
Yes
Yes
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H2.
Overburden Collection Wells
H2A. Plans and Specifications
H2B. EPA/State Review fc
Approval
H2C. Award Contract
H2D. installation
H2E. Pei f 01 in Pump Tests on
NAPL Wells
H2F. Select NAPL Recovery
Wells
H2G. EPA/State Review &
Approval
H2H. Operate NAPL Recovery
Wells and O/B Collection
Wells
OVERBURDEN MONITORING SYSTEM
11.
12.
Gradient Monitoring Wells
11 A. Plans and Specifications
I1B. EPA/State Review &
Approval
I1C. Award Contract
I1D. Installation
Maintenance Piezometers
I2A. Plans and Specifications
I2B. EPA/State Review fc
Approval
I2C. Award Contract
I2D. Installation
Duration
(months)
2
3
' 3 '^"'•••~ •
2
1
1
ongoing
2
3
2
2
2
3
2
2
Float
(months)
12
12
12
. -*• » — - • ••
» .
*
.
12
12
12
*
12
12
12
•
Critic
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
13. Conduct Monitoring Program
ongoing
No
J. BEDROCK RRT SYSTEM
Jl. NAPL Recovery Wells
J1A. Plans, Specifications and
Protocols
JIB. EPA/State Review &
Approval
J1C Award Contract
J1D. Installation
3
2
4
completed
12
12
16
No
No
No
No
8
-------
Duration Float
(months) (months) Critical
F. ITTTLTTY REMEDIATION
F1A. Plans and Specifications 2 91/2 No
FIB. EPA/State Review and Approval 3 91/2 No
F1C. Award contract 2 » No
FID. Construction 1 * No
BARRIER WALL CONSTRUCTION
Gl. Slurry Wall •
G1A. DWTP Option A or Option B 74 0 No
GIB. Plans and Specifications 4 * No
G1C EPA/State Review &
Approval 3 * No
G1D. Award Contract 2 * No
G1E. Installation of Utility
Severance Plugs 1 * No
GIF. Installation of N., S. and W.
Walls 5 • No
GIG Install East Wall 2 0 Yes
G2. Prescriptive Grout Plugs
G2A. Plans and Specifications 4 4 No
G2B. EPA/State Review fc
Approval 3 4 No
G2C Award Contract 2 4 No
G2D. Installation 4 • No
H. OVERBURDEN REMEDIAL SYSTEM
HI. Tile Collection System ••.....
H1A. Plans and Specifications 4 8 No
H1B. EPA/State Review it
Approval 3 8 No
H1C. Award Contract 2 * No
HID. Installation 6 * No
HIE. Operate Tile Collection
System ongoing No
-------
Duration Float
(month*) (months) Critical
DID. Award Contract 2 0 Yes
DIE. Construction 9 0 Yes
DIP. Startup 1 0 Yes
DIG. Additional Storage
Assessment/Approval 2 0 Yes
D1H. Award Contract 3 0 Yes
D1I. Construction • Additional
Required Storage 10 0 Yes
D2. APL Treatment
D2A. Plans and Specifications
Process Design/ 8 11 No
D2B. Plans and Specifications
Detailed Design 10 12 No
D2C. EPA/State Review &
Approval 13 11 No
D2D. Process & Approve Discharge
toPOTW 4 12 No
D2E. Award Contract 2 11 No
D2F. Construction 12 11 No
D2G. Startup 4 11 No
D2H. EPA/State Approval -
Additional Treatment
Capacity 3 17 No
D2I. Award Contract -
Additional Treatment
Capacity 3 17 No
D2J Construction - Additional
Treatment Capacity 12 17 No
D3. NAPL Treatment
D3A. Design, Install 4 Test
Incinerator APCE 32 13 No
D3B. Assess Incineration 3 16 No
D3C EPA/State Review &
Approve APCE 5 13 No
LAGOON DECOMMISSIONING
El. Provide Alternate Treatment
System 12 6 No
E2. dean Out Lagoons 2 6 No
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4.0 DURATION OF ACTIVITIES
The following list of Activities identifies the scheduled
duration, the available float time for each Activity before the critical path is
affected and identifies those Activities which are currently on the critical path
which controls the timely completion of the S-Area program.
B.
ACCELERATED MATERIALS TESTING
Bl. Slurry Materials
B1A. Conduct Testing
BIB. Submit Results
B1C. EPA/State Review &
Approval
B2. Grout Materials
B2A. Conduct Testing
B2B. Submit Results
B2C. EPA/State Review &
Approval
Duration
(months)
6
2
9
2
Float
(months)
4
4
Critical
No
No
No
No
No
No
ADDITIONAL SURVEY WORK
CIA. Award Contract
C1B. Installation (IIPT Wells,
Water Plant Borings/Wells)
C1C Submit Results
completed
31/2
2
71/2
5
No
No
No
SITE FACILITIES
Dl. APL/NAPL Storage
D1A. Plans and Specifications
Process Design
DIB. Plans and Specifications
Detailed Design
D1C EPA/State Review k
Approval
completed
4 0
7 0
Yes
Yes
Yes
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3.0 GOVERNMENTAL APPROVAL PROCEDURES
Most RRT Components listed in Section 4.0 include a
90-day procedure for review and approval of OCC submissions of plans,
specifications and protocols by EPA/State. This time interval is shortened
from that provided in Paragraph 7 of the Judgment.
The elements of this procedure are as follows:
1) OCC prepares plans, specifications and protocols and submits them to
the EPA/State.
Scheduling Duration - as individually noted in Section 4.0.
2) EPA/State reviews the submitted plans, specifications and protocols.
Scheduling Duration - 45 days
3) OCC reviews the EPA/State comments and subsequently revises and
resubmits the plans, specifications and protocols.
Scheduling Duration -15 days
4) EPA/State reviews re-submission and approves plans, specifications
and protocols.
Scheduling Duration • 30 days
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2.0 ASSUMPTIONS
The Bar Chart and Network Diagram are based on the
following assumptions:
(1) OCC will utilize the amount of time indicated in Section 4.0 to
complete each of the listed Activities.
(2) EPA/State will utilize the amount of the time indicated in Sections 3.0
and 4.0 for review and approval of all OCC submissions.
(3) Seasonal variations and weather conditions will have no adverse
impact on the scheduled duration of Activities.
(4) Both governmental and private approvals and other authorizations
necessary to perform an Activity will be obtained in a timely manner
prior to initiation of such work.
(5) All prior dependent Activities and RRT Components listed in
Section 4.0 are completed as scheduled.
-------
addition, the initiation and completion of certain RRT Components is
directly dependent upon the satisfactory completion of other RRT
Components. Therefore, if any of these RRT Components or Activities are
not completed as scheduled, it will have a consequential direct effect on the
initiation and completion of the dependent RRT Component or Activity.
RRT Components and Activities which could be effected in this manner are
presented on both the Network Diagram and the Bar Chart.
The performance of certain RRT Components and
Activities listed in Section 4.0 also is directly dependent upon the accuracy of
each of the assumptions described in Section 2.0.
All revisions to the S-Area Project Schedule will be made
in accordance with Section F of the RRT Stipulation.
-------
1.0 INTRODUCTION
This project schedule ("S-Area Project Schedule") is
applicable to activities related to implementation of the S-Area RRT
Remedial Plan.
The S-Area Project Schedule consists of the following:
a) the assumptions set forth in Section 2.0;
b) the procedure relating to submission, review and approval of plans,
specifications and protocols set forth in Section 3.0;
c) the major RRT components listed in Section 4.0 and the duration of
each of the activities included under each component;
d) the Network Diagram included as an attachment hereto; and
e) the Bar Chart included as an attachment hereto.
Section 4.0 identifies the major components of the S-Area
RRT Remedial Plan ("RRT Components"). It also includes various activities
which will be carried out in implementing each RRT Component
("Activities"). However, the list cannot take into account additional
unscheduled tasks and extensions in performance time of currently
undefined Activities resulting from required response actions, such as
Operational Modifications, System Modifications, focused feasibility studies,
and RRT Studies.
The performance of certain activities listed in Section 4.0
is directly dependent upon the satisfactory completion of prior Activities. In
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
2.0 ASSUMPTIONS 3
3.0 GOVERNMENTAL APPROVAL PROCEDURES 4
4.0 DURATION OF ACTIVITIES 5
-------
APPENDIX V
OCC S-AREA PROJECT SCHEDULE
-------
ATTACHMENT A Page 3 of 3
TO APPENDIX IV
C5. Complete Trial Burns and, if Authorized, Initiate November, 1993
Restrictive Burning of Remedial Wastes, Including
S-AreaNAPL(OCC)
C6. All Required Complete Submissions for final February, 1994
Authorization (OCC)
C7. Authorization to Incinerate S-Area NAPL in Solids July 1994~ (five months
Incinerator Under Final Permit Conditions (EPA/DEO after Item C6)
Schedule D: Other EPA/State Permitted Incineration/Treatment and Storage Alternatives
specified in § 2
-------
ATTACHMENT A
TO APPENDIX IV
Schedule B: Upgrade for Liquid Incinerator Air Pollution Control Equipment (APCE)
Page 2 of 3
Bl. Approval Determination of APCE Technology
(EPA/DEC)
B2. Submit Complete Final APCE Design (OCO
B3. Authorization Determination of APCE Construction
(EPA/DEC) Start of APCE Construction (OCO
64. Submit Complete APCE Trial Bum Plan (OCC)
B5. APCE Trial Burn Plan Approval (EPA/DEC)
B6. Completion of APCE Construction and APCE Start-up
(OCC)
B7. Submit complete APCE Trial Burn Report (OCC)
B8. Submit Remedial Waste Treatment Assessment Report
Per Stipulation § 20(b) Assessing Status of APCE
Upgrade (OCC)
B9. Approval Determination for NAPL Incineration with
APCE (EPA/DEC)
•JCptCfllOd f 1990
March 1991 (six months
after Item Bl)
July 1991 (four months after
ItemB2)
January 1992 (six months
after Item B3)
June 1992 (five months after
ItemB4)
July 1992 (twelve months
after Item B3)
March 1993 (eight months
after Item B6)
January 1993 (three months
after Phase I pump tests)
August 1993 (five months
after Item B7)
Schedule C: OCC s Solid Hazardous Waste Incinerator
Cl. Incorporate Liquid Remedial Waste Streams into Permit
Applications and DEIS for OCCs Solids Incinerator
(OCO
C2. AU Required Complete Submissions Made (OCO
C3. Permit Determination for OCCs Solids Incinerator
(EPA/DEO
C4. Submit Remedial Waste Treatment Assessment Report
per Stipulation § 20(b) Assessing Status of OCCs Solids
Incinerator (OCO
Ongoing, concurrent with
Schedules A & B
February, 1991
* December 1991* (ten months
after Item C2)
January 1993 (three months
after Phase I pump tests)
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ATTACHMENT A Page 1 of 3
TO APPENDIX IV
The dates set forth below for OCC to make complete submissions require OCC to make its best
efforts to provide complete submissions in compliance with § 5(g) of the RRT Stipulation. It is
contemplated that these submissions will be followed by written and oral communications between
EPA/DEC and OCC during governmental reviews prior to final governmental determinations that the
OCC submissions are complete.
Final governmental determinations or approvals on the permit applications are dependent
on receipt of OCC submissions which are complete.
REMEDIAL WASTE TREATMENT MILESTONE SCHEDULE (RWTMS)
Schedule A: Approval to Incinerate S-Area NAPL at OCCs Liquid Incinerator
Al. Submit Preliminary S-Area NAPL Characterization
Data Report (OCO October, 1990
A2. Submit Representative S-Area NAPL Sample Collection December 1990 (two months
Plan (OCC) after Item Al)
A3. Approval Determination of Item A2 Submission March 1991 (three months
after Item A2)
A4. Complete Implementation of Item A2, Submit Complete July 1991 (four months after
Application for Approval to Incinerate S-Area NAPL Item A3)
per permit (OCO
A5. Approval Determination for S-Area NAPL Incineration September 1991 (two
(consistent with confirmatory analyses required pursuant months after Item A4)
to the permit) (EPA/DEO
A6. If APCE is required for capacity to treat all of S-Area NAPL, continue authorization process to
incinerate S-Area NAPL under (RWTMS) Schedule B. If APCE is not required to treat all
S-Area NAPL, men schedule B is inoperative.
A7. Submit Remedial Waste Treatment Assessment Report January 1993 (three months
per Stipulation § 20(b) Assessing Status of Liquid after Phase I pump test)
Incinerator (OCO
-------
ATTACHMENT A TO APPENDIX IV
REMEDIAL WASTE TREATMENT MILESTONE SCHEDULE (RWTMS)
-------
APPENDIX F
GROUTING PROCEDURE FOR WELL CLOSURE
In the event that any well is to be grouted and removed from service, the
following procedures are to be implemented:
1) Place polyethylene on ground surface around well.
2) Install a water tight connection with tremie tube access over well.
3) Set up water collection tank on polyethylene.
4) Insert tremie tube to bottom of hole.
5) Pump groud into the well lifting the tremie tube as the grouting proceeds.
6} Place tremie tube into a steel barrel (placed on top of polyethylene) as it
is removed from the well.
7} Pump fresh water used to purge the tremie tube at the completion of grouting
into the grout mixing drum.
8) Cover the tremie tube with polyethylene and return to the cleaning area
where the tubing exterior will be cleaned along with all other equipment
used in the grouting procedure.
9) Contain all well water and transport to a permitted treatment facility.
Depending on the volume, wastewater may be pumped into a wastewater haul
vehicle or into 55-gallon drums as appropriate. Excess grout will be placed
into 55-gallon drums for transport to the spoils cell.
10) Retop the grout with additional grout.
11) Cut casing off at or below grade.
12) Dispose of appropriate safety equipment and material in 55-gallon steel
drums and transport to the drum storage facility.
13) Restore site to original condition or better.
The above procedure will be used for all wells screened in the bedrock or above
the top of the confining layer (clay/till). For overburden wells screened in
the clay or till unit, the well will be overdrilled, the well pipe removed to
the extent practicable and then the grouting procedure will be implemented.
-------
APPENDIX F
GROUTING PROCEDURE FOR WELL CLOSURE
-------
MINIKUN REQUIRED STEEL SLIP-IN BLANK THICKNESS
PIPE SIZE
INCHES 1 5 10 25 50 75 100 150 200
1 1/16 1/16 1/16 1/16 1/8 1/8 1/8 1/8 3/16
2 1/16 1/16 1/8 1/8 3/16 3/16 3/16 3/16 1/4
3 1/16 1/8 1/8 3/16 3/16 3/16 1/4 1/4 5/16
4 1/16 1/8 1/8 3/16 1/4 1/4 5/16 5/16 3/8
6 1/8 3/16 3/16 1/4 5/16 3/8 3/8 7/16 1/2
8 1/8 3/16 1/4 5/16 3/8 7/16 1/2 9/16 11/16
10 1/8 3/16 1/4 5/16 7/16 1/2 9/16 11/16 13/16
12 3/16 1/4 5/16 3/8 1/2 5/8 11/16 13/16 15/16
E-6
-------
YES MO
LJ Q Process fluids removed from equipment or lines broken.
Necessary blanks Installed?
Drain valve to be Installed?
p.
|— j On-Slte Personnel assigned to job Instructed In proper
method?
Has safety shower been located and tested?
p a
r—| i-i Line or equipment has been properly prepared and Is
p
safe to break Into.
All pumps and starters locked out?
SPECIAL PRECAUTIONS
I certify that the precautions checked and/or written out above have
been taken, and will be followed for the duration of the job.
OCC SAFETY OFFICER
Signed •
E-5
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CHECK LIST MUST BE COMPLETED
BEFORE ANY PROCESS LINE IS OPENED WHICH
CONTAINS OR HAS CONTAINED HAZARDOUS MATERIAL
Date . Fran TO*
Department Location
Work TO Be Done
MATERIAL 7055IBLY IN LINE
Name of Material
Complete this section before checklist Is signed. Check the precaution
to be taken before line opening starts. Cross out those not applicable
to the particular job being done at the tine.
YES NO
LJ LJ All necessary protective equipment. Including rubber
suits, face shield (or hood) rubber foot wear, liquid
proof gloves to be worn?
nr-i Respiratory protection needed and/or available? If so
U state type .
Dp-i Area barricaded for maximum protection of other On-S1te
U Personnel?
i—i i Scaffolding Installed or other safe access to equipment
provided?
•Hot Work Permit' provided as needed?
D P
p. Line or equipment drained Into a suitable container?
p. All valves properly Identified, tagged and locked out?
i—i p. All pumps and starters locked out?
E-4
-------
A. Pipelines Containing Hazardous Materials
(1) When these pipelines are worked on, valves that stop
material flow oust be closed, locked, tagged and tried.
(2) Where possible, at least two valves on the upstream side of
the point of work should be closed, locked, tagged and
tried. No dependence should ever be placed upon check
valves to prevent flow of materials.
a. If lines are tied to a common header, It may also be
necessary to lock out and tag additional valves to
prevent backflow.
b. All material should be bled from the lines and, where
possible, a positive means of keeping the line vented,
such as a double block and bleed, should be used.
c. When a bleed point 1s not available, the source of
pressure on the material 1n a pipe line should be
removed (shutting down and locking out a pump feeding
the line).
(3) When lockout of the valve or valves, due to its construction
1s Impractical, a "Danger" tag, properly filled out, dated
and signed, must be securely affixed to the valve stem.
(4) The contaminated lines will be flushed with clean water than
cutup and placed in 55 gal. barrels and disposed at the
secure landfill. (All water used for flushing will be
collected and treated according to the Hyde Park Consent
Agreement).
E-3
-------
4. The On-Slte Personnel will fill out the checklist before starting
the job and the Safety Officer will periodically audit to Insure
that this Is being done. This checklist will be given to the Safety
Officer upon completion of the line breaking job. Mho will review
and Initial the work permit sheet and retain 1t for or* calendar
quarter.
5. Barricading Area
Before the moment of breaking occurs, the surrounding area shall be
barricaded for maxima protection of other On-S1te Personnel.
6. Downtime After Line Breaking
A. When line break-ing Includes a period of downtime greater than
the shift during which the breaking occurred, the open system
shall be secured or closed by one of the following means:
(1) double block and bleed
(2) blind flanges - refer to blank flange sizes
(attached)
(3) a properly designed closure
Exceptions to 6a would be where a crew can maintain continuity
thru a shift change.
Where there 1s a possibility of a line refilling and no other
drain exists, a drain valve shall be attached to the blank
flange or closure.
B. Safeguards such as locked switches and locked valves shall be
continued until the system Is again closed.
7. Safety Showers
Before breaking Into equipment, a safety shower will be situated
within IS1 of the equipment before making the break.
8. Plastic Piping and Fittings 1n Hazardous Service
Some forms of plastic piping can become brittle with age and
chemical exposure, others are affected by extreme temperatures.
Cart oust be exercised when working with these plast.ics.
9. Safety locks and "Danger - Do Not Operate" tags must be installed on
closed valves when:
The flow of air, steam, water, flammable liquids or chemicals
through unblanked pipe lines would present a hazardous condition.
E-2
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S-AREA REMEDIAL PROGRAM
Safety Operating Procedure S110
SUBJECT
Line Or Equipment Breaking Checklist
PURPOSE
To establish a standard procedure for minimum safe preparation and opening of
equipment or pipeline which have or could contain hazardous materials.
Individual circumstances may require more stringent procedures.
AFFECTS
All Construction Activities during the S-Area Remedial Program.
PROCEDURE
1. Checklist
A. Line breaking checklist (Appendix E, Page E-4) shall be filled out
before Personnel break into equipment or pipelines which have or could
contain hazardous materials.
2. Required Protective Apparel
A. Face Shield and Goggles
B. Safety Hard Hat
C. Liquid Proof Gauntlet Gloves
D. Protective Footwear Covered by Rain Suit
E. Respiratory Equipment ad Defined in SI3
3. Duration of Mode of Operation
A. The protective equipment must be worn when On-Site Personnel open as
isolated line or equipment for the first time and work on open lines
and/or equipment as long as the hazard of exposure exists. The hazard
of exposure may be considered eliminated and the Safety Officer may
approve removal of protective equipment to the minimum requirement of
goggles, gloves, respirator, and hard hats when all of the following
exist:
(1) The line or equipment is drained and vented to a proper means of
containment.
(2) The line is physically disconnected (opened) at all low points.
(3) Interconnecting lines are blanked or locked out and tested not to
leak through.
(4} Lines or equipment which have contained hazardous materials have
been flushed.
E-1
-------
APPENDIX E
SAFETY OPERATING PROCEDURE S#10
LINE OR EQUIPMENT BREAKING CHECKLIST
-------
i. Washable coveralls - cotton jump suit type.
j. Cold weather gear - when and if needed, jackets, hats, insulated underwear.
k. Disposable shoe covers.
Protection level S-4 - Project Site Workers. There is no need for the
following classification of workers to enter a Survey Site or to handle any
potentially contaminated material or equipment: equipment operators outside the
Survey Site, technicians,*/ supervisors, engineers, office workers who must go
to a Survey Site, service personnel, janitorial service personnel, and general
site visitors. These Project Site Personnel will be provided with and wear:
a. Respirator - Scott 64-OAF or approved equivalent. (Available for immediate
use)
b. Hard hat. (to be worn}
c. Safety glasses with side shields, (to be worn)
d. Protective rubbers - neoprene reusable. (Available if required by Site
conditions.)
e. Outer gloves - janitorial personnel only.
Protection Level S-5. Office workers, clerical workers, visitors, and others
who remain within the fenced area near the offices will not need nor be issued
any special personal protective equipment. Scott 64-OAF or approved equivalent
respirators will be available in the office for emergency purposes.
_V the air monitoring technician will adjust his personal respiratory
protection depending on the readings from his instruments.
-------
c. Hard hats.
d. Safety glasses with side shields.
e. Full face shields or approved equivalent will be used when drilling through
waste or through the lower section of the Lockport Dolomite.
t. Cotton gloves (inner glove).
g. Outer gloves (two sets).
h. Work boots.
i. Outer boots (neoprene reusable).
j. Washable coveralls - cotton jump suit type.
k. Cold weather gear - when and if needed - jackets, hats, insulated
underwear.
1. Sock and underwear.
m. Disposable Hood (unlaminated Tyvek type 2196).
Protection Level 8-3 - Survey Site Morkers with Minisnsi Potential of Bxpoaure to
Surrey Liquids. The following classification of worker will be working at
Survey Sites located in areas other than on the S Area Landfill or in areas with
minimum potential for contact with Survey Liquids. These workers include: soil
and water samplers, sample handlers, and personal protective equipment cleaners.
They will be provided with :
a. Respirator - Scott 64-OAF or approved equivalent. (Available for immediate
use).
•b. Disposable coveralls - For expected wet conditions use item b in Level S-2
above; for expected dry conditions, uncoated TYVEK may be used.
c. Hard hat. (to be worn)
d. Safety glasses with side shields, (to be worn)
e. Cotton gloves (inner glove), (to be worn)
f. Outer gloves, (to be worn)
g. Work boots, (to be worn)
h. Protective rubbers (neoprene reusable), (to be worn)
-------
APPENDIX D
Subject
Levels of Worker Protection
Protection Level S-1 - Confined Space Survey Site Workers. Because of the
higher potential for exposure to chemicals while in a confined space or while
drilling within the interior of the S-Area Landfill, worker classification for
Survey-Site Personnel who work in these areas will be provided with and wear:
a. Pressure Demand Supplied air (1980 ANSI Standard Z88.2).
b. Five minute positive pressure escape air pack independent of primary air
source. (Available for emergency use)
c. Fully encapsulating chemical resistant suit (Coated Chemical Resistant
TYVEK, Kapplar Model 77 or approved equal).
d. Washable coveralls.
e. Socks and underwear.
f. Gloves outer (chemical resistant neoprene) - the most effective glove
will be provided.
g. Gloves inner (cotton).
h. Work boots - the most effective work boot will be provided.
i. Outer boots (neoprene reusable) will be provided.
j. Hard hat - an ANSI approved hard hat equivalent to Wilson Alpha Safety Cap
I82AC and compatible with item c. will be provided.
Protection Level S-2 - Survey Site Workers. The following classification of
workers might on occasion handle potentially contaminated material or equipment.
They will be working around mobile equipment, wells and the spoils cell and will
include drillers and driller helpers drilling on the immediate perimeter of the
S Area Landfill, equipment operator cleaners and those involved in the operation
of the spoils cell.
a. Respirator - Scott 65-OAF or approved equivalent (Cartridges to be replaced
daily).
b. Disposable coveralls - splash resistant polylaminated coated TYVEK type
P2126-1 with closure capacity at wrists and neck. Equipment cleaner to have
laminated hood.
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APPENDIX D
LEVELS OF WORKER PROTECTION
-------
APPENDIX C
Soil Testing Procedures - OA/OC Plan
All imported clay to be used for the construction of the Disposal Area berms and
capping of the Site (interim and final) shall be tested for the following parameters at the
frequency noted:
• Grain Size Distribution (ASTM D-422-63) - once/1,000 c.y.
• Moisture Content (ASTM D-2216-80) - once/1,000 c.y.
• Atterburg Limits (ASTM D-4318-84) - once/1,000 c.y.
• Triaxial Permeability Engineering Manual - once/5,000 c.y.
Number EM 1110-2-1906:
Appendix VII
"Permeability Test with
Back Pressure"
• Moisture Density Test (ASTM D698 OR D1557) -once/5,000 c.y. and at
least once during base
placement, once
during each interim lift
cover placement
(3-inch layer) and
once during final
cover placement
Physical testing data from proposed clay sources will be provided prior to bringing the
materials to the Site (grain size, moisture content, Atterburg limits, triaxial
permeability and moisture density relationship). Results of three historic test sets will
be forwarded to the EPA/State Field Representative for review and approval.
In the case where day is being used for capping purposes, the following testing shall be
performed at the frequency indicated:
• In-place Compaction Test (ASTM D-2922-81
orD-1556-82) - nine tests/acre/lift
• In-place Moisture Content (ASTM D-3017-78) - nine tests/acre/lift
• Triaxial Permeability
(Final Cap Only) Engineering Manual - one/acre
Number EM 1110-2-1906:
Appendix VII
"Permeability Test with
Back Pressure"
In the case where clay is being used for berm construction, the following testing shall be
performed at the frequency indicated:
• In-place Compaction Test - one test/150 LF of berm
• In-place Moisture Content - one test/150 LF of berm
\
-------
APPENDIX C
SOIL TESTING PROCEDURES - QA/QC PLAN
-------
It is to be noted that:
i) The Safety Officer is responsible for inspecting all
vehicles/equipment prior to final release from the Site.
ii) All wash water will be contained and treated at the Niagara
Plant Calgon Unit.
iii) All sediment from wash water will be drummed and disposed at
the Landfill Site.
iv) All dirty haul roads will be removed and disposed on Site at
the conclusion of each phase of the remedial program unless
programs are running concurrently or consecutively.
-------
APPENDIX B
On-Site Traffic Standard Operating Procedures
All vehicles and equipment entering the Landfill Site are required
to adhere to the following SOP for cleaning prior to leaving the
Site:
Condition A - Vehicles/equipment that do not handle waste and do
not use dirty haul roads or enter open sections of
waste disposal areas are not required to undergo
cleaning.
Condition B - Vehicles/equipment used to haul/handle waste
material are exempt from cleaning between loads if
all of the following conditions are met:
* provisions are made to protect the exterior of the
haulage vehicle during the loading and unloading
operations.
* The vehicle/equipment does not use dirty haul
roads or enter open sections of the waste disposal
area (unless clean haul roads are extended into
the area). Otherwise, the undercarriages must be
cleaned at a wash station prior to leaving the
defined work zone. All waste material adhering to
the exterior of the vehicle (excluding the inside
face of the box container) will also be removed at
the wash station.
Condition C - Vehicles/equipment permanently leaving the Site
which have been used to haul/handle waste material
must have:
* their undercarriages cleaned as noted in
Condition B before leaving the defined dirty work
zone.
* Drive to or be transported to the decontamination
facility (if transported, the undercarriage
cleaning can be deleted)..
* Clean the entire exterior of the vehicle/equipment
with a pressurized water wash.
-------
APPENDIX B
ON-SITE TRAFFIC STANDARD OPERATING PROCEDURES
-------
7. Proper placing and maintenance of fifth wheel jack supports.
A. Fifth wheel jack supports must be properly adjusted so it is
against the face of the fifth wheel.
B. The surface of which the jack is placed must be level.
C. Fifth wheel jacks must be maintained in good operating condition
and if damaged must be replaced.
A-3
-------
surface. When a tanker or trailer is spotted for purpose of
loading or unloading, the driver will place a nose jack support.
If the tanker or trailer Is spotted for storage only, a nose
jack need not be used.
After a loading or unloading operation has been completed, the
tractor driver must never couple to a trailer or tanker without
first getting consent from the loader or unloader.
3. Stake Trucks and Dump Trucks
Wheel chocks need not be used with these vehicles, unless mobile
equipment is being driven onto them.
When chocking 1s needed, they must be placed at the front and rear
of an outer rear wheel on both sides of the truck.
4. Parked Trailers, Tankers and Trucks
If there 1s no loading or unloading to be done and trailers, tankers
or trucks are to be left parked on an even surface, it will not be
necessary to chock the wheels.
However, if there Is work to be done on any unit whether it be
loading, unloading, maintenance or painting, the wheels must be
chocked to prevent both backward and forward movement.
In either case, the brakes must be applied after spotting the unit.
5. Removal of Wheel Chocks
A. Wheel chocks MUST NEVER be removed from position until approval
has been given by the loader or unloader. After getting this
approval, the tractor or truck driver may remove the wheel
chocks.
B. The loader must closely examine all drain valves and other
outlets to insure that all outlets are secure and not leaking
prior to giving approval for removal of the wheel chocks.
6. Proper Placing and Maintenance of Wheel Chocks
A. Chocks must be squarely placed against the tire-of the vehicle
with the toothed edge gripping the surface on which it rests..
B. The surface on which the wheel chock is placed must be free of
ice and snow. If it *s a concrete surface, the area where the
chocks are placed must be free of gravel, dirt and etc.
C. Wheel chocks must be maintained in good condition and if
damaged, must be replaced.
A-2
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a-nrea
Safety Operating Procedure si6
SUBJECT
Loading and Unloading of Trailers, Tankers, and Trucks
PURPOSE
To prevent accidental movement of trucks, trailers and tankers during
loading and unloading operations.
AFFECTS
All construction activities during the s-Area Remedial Program.
PROCEDURE
1. Loading or unloading trucks and trailers or tankers with tractor
attached.
A. Responsibilities of the Tractor Driver or Truck Driver
After spotting the unit at Us loading or unloading position,
the driver must test the brake system on both the tractor and
trailer. This is done by applying the air brakes to the trailer
and the hand emergency brake to the tractor and with the motor
running and transmission in gear attempt to move the unit
forward. The test must show that there is enough restraining
force of the applied brakes to prevent forward movement. After
this test has been satisfactorily completed, the driver Mill
shut off the tractor motor and place the transmission in reverse
gear.
Trailers or tankers must have chocks placed at the front and
rear of an outer wheel or set of wheels on both sides of trailer
to prevent movement in either direction. The tractor driver
must then notify the On-Site Personnel responsible for the
loading or unloading operations that the above precautions have
been taken.
The tractor driver must never pull the trailer or tanker away
from this secured position until he has received permission from
the On-Site Personnel responsible for the loading or unloading
operations.
2. Loading or unloading trailers or tankers without the tractor
attached.
A. Responsibilities of Tractor Driver
Before uncoupling the tractor the driver must set the trailer or
tanker air brakes. He must then test these brakes by attempting
to move the trailer or tanker forward with the tractor as the
moving force. The driver must then place the wheel chocks as
previously outlined and then lower the trailer or tanker dolly
wheels making sure that the dolly wheels are setting on a firm
A-l
-------
APPENDIX A
SAFETY OPERATING PROCEDURE S#6
LOADING AND UNLOADING OF TRAILERS, TANKERS AND TRUCKS
-------
h) All areas outside the placement cell which are impacted by leakage will
be cleaned up according to the procedures described in the appropriate
Health and Safety Plan.
The pump and hoses will be transferred from cell to cell as
work progresses. Upon completion of the final cell, the pump and hoses shall
be buried with the final waste placement prior to final capping.
5.10 HEALTH AND SAFETY PLAN
The Health and Safety Plan to be followed during the
placement of the waste in the placement cell will be in accordance with the
Health and Safety Plan applicable to the remedial work which generates the
waste. The Health and Safety Plan will typically be one of the following:
• Environmental Health and Safety Plan for Survey Activities, or
• Environmental Health and Safety Plan for Special Construction Activities.
In cases where two waste generating activities are ongoing
concurrently, the more stringent Health and Safety Plan will be implemented
at the waste placement cell.
41
-------
a) Immediately shut down any operating pumping equipment.
b) Notify the appropriate personnel that repairs are required immediately.
c) Drain and collect all liquid from the hoses and isolate the leaking
portion.
d) Perform all line breaking in accordance with Safety Operating
Procedure S#10 "Line or Equipment Breaking Checklist" (See
Appendix E).
e) Repair or replace the leaking portion of hose as necessary.
f) Should repairs be lengthy or further pumping be required before
repairs can be completed, make provisions for temporary bypass of the
damaged area.
g) In addition to the normal safety clothing requirement, the following
safety equipment must be worn for work on leaking hoses:
- rubber rain suit
- rubber gloves
- rubber boots
- face shield
- respirator (Scott 64 OAF or approved equivalent).
40
-------
Precipitation falling within a prepared area that has begun
to receive waste material will be contained within the excavation and shall be
removed to a trailer or storage on the AOC Where possible, precipitation
landing on placement areas that have been capped with day will be diverted
to the local surface drainage courses for discharge off the Landfill Site. The
daily inspections will insure that this precipitation remains as non-waste
contact surface water.
If water is sediment-laden, it will be allowed to settle until
the water is of reasonable clarity so as not to impair the operation of OCC's
Treatment facilities. In order to reduce the potential for sediment discharge
with the waste contact surface water, OCC will install a filter (See Plan 1)
around the pump to reduce the sediment intake.
A submersible pump and dedicated flexible
chemical-resistant hose will be used to pump the water from the waste cell
area. At OCCs option, either manually-controlled or level-activated pumps
may be used to pump water from the disposal area. Any joints in the hose
shall be wrapped with duct tape and shall be inspected once per day during
pumping operations to monitor the integrity of the line. If
manually-activated pumps are used, single hoses with hourly inspections
will be used. If level-controlled pumps are used, encased hoses and daily
inspections will be used.
In the event that leakage is detected in any of the hoses,
the following procedures will be followed:
39
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above-grade haul roads will be scraped down and made level with the
existing grade. This material will be placed within the waste cell area.
Dust control measures on haul roads shall be
implemented on an as-needed basis. These measures will include the
application of water or calcium chloride. Maximum speed on haul roads will
be limited to ten miles per hour to further reduce dust generation.
5.9 SURFACE WATER HANDLING
The waste placement and cell preparation areas shall be
constructed in such a sequence as to maintain positive surface drainage of
rainwater away from the active cell placement area and toward existing
surface water drainage systems. Surface water shall be diverted around the
prepared areas by means of swales as shown on enclosed Plan 1. Wherever
possible, sheet flow conditions are preferred as opposed to concentrating
surface water flow in swales.
Precipitation falling within a prepared area that has not
yet begun to receive waste material will be pumped from the cell and
discharged to the surrounding drainage swale. A dean pump and discharge
line \
-------
b) During cell placement activities for personnel within prepared area but
not within waste cell use Level S-3 protective equipment (See
Appendix D).
c) During times of entry with all waste covered or sealed use Level S-3
protective equipment.
The above levels of worker protection will be upgraded by
the Safety Officer should the air monitoring being conducted indicate that
such an upgrade is warranted. The Safety Officer will follow the guidelines
for the pertinent health and safety plan per Section 5.10 in determining
whether such actions are required.
Access into the prepared cell areas will be through an
opening in the temporary fence. The openings will be dosed nightly with
fencing or similar material.
The location of haul roads and accesses into the cell areas
will depend upon the cell location. The intent will be to maximize the use of
haul roads once they are constructed.
Haul road requirements must be determined in the field
to suit the conditions and needs encountered. Haul roads within cell areas
will simply consist of a layer of stone consistent with the intended purpose
and estimate of usage and will be upgraded as required. If deemed
appropriate by the OCC Field Representative, a filter fabric may be used in the
haul road construction. Prior to final capping of the Landfill Site, all
37
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- collection systems,
- site benchmarks,
- advisory signs, and
- fences.
Based upon the inspections made, OCC shall promptly repair or modify any
problems identified.
All records shall be kept available at the OCC Field Office
for reference.
Upon completion of each cell placement area, OCC shall
submit a copy of the records of waste placement and a record drawing
stamped by a New York State registered Professional Engineer to the
EPA/State.
5.8 SECURITY FENCE AND ACCESS REQUIREMENTS
A temporary security fence (snow fence) will be placed
around the perimeter of the prepared area. Access within the fenced areas
will be restricted to personnel equipped with the following equipment:
a) During cell placement activities for personnel entering waste cell use
Level S-2 protection equipment (See Appendix D).
36
-------
In addition to the above activities, a daily record of waste
placement and inspection activities shall be maintained at the project site.
The daily record shall include:
• records of waste placement in cells:
- date,
- type,
- quantity,
- container type or bulk,
- location (accurate to 50'+), and
- disposal method;
• records of Landfill Site testing, (soil density, moisture for clay cap), and
• records of daily inspections:
- day cover,
- disposal area inspections (and sideslopes under interim cover),
- surface water control and discharge, and
- haul roads.
Regular maintenance inspections shall be made on a
weekly basis as specified in Addendum HI of the Settlement Agreement for
the following:
- slopes,
- vegetation,
- drainage structures,
35
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aspects of the waste cell placement program to ensure compliance with
approved plans and specifications:
- cell construction,
- benn construction,
- waste placement,
- waste compaction,
- material transfer,
- haul road conditions,
- requirement for dust control,
- equipment cleaning,
- interim cover placement,
- surface water control,
- health, safety and personal hygiene, and
- air monitoring.
The air monitoring requirements during the period of
active cell operation will be identical to the air monitoring program
implemented at the point of waste generation. In cases where two waste
generating activities are ongoing concurrently, the more stringent air
monitoring plan will be implemented at the waste disposal cell.
It is to be noted that air monitoring of the waste cell
operation will not be required in cases when the waste material being placed
into the cell is contained in sealed units (i.e. 55-gallon steel drums or fiber
drums).
34
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The preferred source of loam to be used for the final cap is
the residual from incineration of OCC remedial wastes at the proposed
Niagara Plant solid waste incinerator. It is currently estimated that this
incinerator will generate approximately 35/000 cubic yards of ash residue per
year.
OCC will apply for governmental "de-listing" of the
residual ash from its status as a hazardous waste. Concurrently with this
application to de-list the residual ash, OCC will petition NYSDEC for the
beneficial use of this residual ash for use as fill, including its use as
intermediate loam in the final caps at the S-Area and the DWTP.
If the ash is delisted and its use satisfies all applicable state
and federal regulations, it will be used as intermediate loam for the final cap..
If, at the time of final capping, the residual ash has not been de-listed and
accepted for beneficial use, does not meet applicable state and federal
regulations, or is not available, it will not be used, and an alternate source of
intermediate loam will be readily available for immediate use.
5.7 SUPERVISION, DOCUMENTATION AND
MONITORING REQUIREMENTS
The OCC Safety Officer shall be present at the project site
whenever waste materials are being placed into the daily cells. The Safety
Officer or his appointed designee will provide oversight of the following
33
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The final top slope of each waste cell will be set at a
minimum of two percent grade. This will not only promote surface drainage,
but also provide a base for any required additional lifts. The exterior side
slopes of each cell will be kept to a minimum of 1:2 and in those cases where
the cell lies along the outside edge of the Landfill Site, the slope shall be
graded according to the final Landfill Site closure plan.
Typical waste cell construction progression is presented in
enclosed Plan 1.
5.6.2 Final Capping
As major portions of the Landfill Site reach final grade,
OCC will install the final cap, as specified in the S-Area Settlement
Agreement, over the completed areas. The final landfill cap shall consist of:
• 6 inches of topsoil, overlying
• 18 inches of intermediate loam, overlying
• 36 inches of day (KS1 x 10~7 on/sec).
The 18-inch intermediate loam layer described above will
required the use of approximately 11,000 cubic yards of material as a part of
the final cap at the Landfill Site. In addition, if the DWTP is removed, the
DWTP structures will be demolished and most of the DWTP will be capped as
described above. This will require approximately 6,500 cubic yards of loam
material as part of the final cap at the DWTP.
32
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- 30 mil polyethylene film or equivalent.
The polyethylene film will only be used in cases in which
disposal activities are planned to be resumed within 72 hours.
It should be noted that fiber drums may be kept within the
designated drum storage area in the disposal areas for extended periods as
long as the drums are covered with polyethylene.
In all other cases, the waste will be capped with a
minimum compacted thickness of six inches of day. The clay will be obtained
from sources as directed by OCC. The clay will have a permeability of
1 x 10~7 cm/sec or less with a minimum of 40 percent fines passing the #200
sieve. Prior to and during use at the Landfill Site, the imported clay shall be
tested in accordance with the requirements specified in Appendix C. This
includes the clay used for the initial six-inch base.
Results of these tests will be forwarded to EPA/State prior
to use of the material on the Landfill Site.
The size of each daily spoils cell will be based on the
volume of waste available for disposal on that particular day. Sections of the
disposal cell which will not be reused for periods in excess of 180 days will be
capped with an additional three inches of day. The additional three inches of
day will be compacted with a smooth drum roller to the density spedfied to
meet the 1 x 10"? cm/sec requirements.
31
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5.5 LAGOON DECOMMISSIONING
The S-Area lagoons will be decommissioned. This will
involve the cleaning of the lagoons in accordance with standard plant
operating procedures and then dismantling the water handling functions of
the lagoons including:
- removal of the slurry inlet pipe, and
- plugging the outfall structure with cement.
The outfall pipe is connected to the portion of the
003 Outfall within the Site Barrier Wall that is to be severed and plugged.
Severing and plugging of the 003 Outfall will effectively isolate the outfall
pipe.
5.6 WASTE CAPPING
5.6.1 Interim Capping
At the conclusion of each working day, or as necessitated
to control vapor emissions, the waste cell shall be covered with one of the
following caps:
- six inches of low-permeability clay (K£l x 10'? cm/sec); or
30
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• crane, or
• conveyor system
- dump/unload directly into place from within the cell (requires dirty haul
road designations)
Depending upon the waste volume and character, the
methodology for waste placement and transfer will vary and is not necessarily
limited to those described above.
5.4 OTHER CONSIDERATIONS
Placement of waste on the Landfill Site will not interfere
with the installation of the proposed wells and collection systems. The
condition of the Landfill Site at the time of construction of various
appurtenances will be taken into consideration. Possible additional loading
due to increased heights of fill will also be considered.
Any wells in existence at the time the waste cells are
constructed will either be removed or extended as appropriate. Wells not
included in the ongoing monitoring programs will be removed subject to
EPA/State concurrence and the others will be extended as appropriate. Any
well included in the ongoing monitoring programs which become damaged
will be replaced with a new installation unless an appropriate alternate well
already exists. Wells installed after the waste cells are constructed will be
integrated into the cover design. Removal of wells will be undertaken in
accordance with the protocols described in Appendix F.
29
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"contaminant reduction zone" at the equipment wash facility or other agreed-
upon location. Standard Operating Procedures for On-Site Vehicle Traffic are
presented in Appendix B.
Construction and maintenance of haul roads will be an
on-going operation with dean gravel being added on an as-needed basis.
Specific details of waste placement, haul road designations
(i.e. clean, dirty), contaminant reduction zone locations and container loading
and unloading will be determined in the field by the OCC Field
Representative, when concurrences by the EPA/State Field Representative
prior to implementation. The following options are available for waste
placement:
Waste Transport Containers
- 55-gallon steel drums - secured lid
- watertight dump truck with polyethylene cover
- watertight lugger box with polyethylene cover
- DOT approved fiber waste container
- fiber drums
Waste Transfer
- dump/unload directly into cell from edge of cell
- dump /unload into a staging area and transfer into place using a:
• backhoe
• bulldozer
»
• dragline
28
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areas recompacted by large equipment when they return to the Landfill Site
for the larger waste volume programs. Typical equipment to be used for
compaction include:
• Self-propelled vibratory Sheeps Foot Compactor typical model numbers:
- Raygo 320
- Dynapac CA25
- Bomag BW605
• A small vibratory roller available at the Landfill Site for all of the small
programs for compaction purposes.
Compaction procedures will be determined in the field by
the OCC Field Representative, taking all of the pertinent factors into account.
The test results will be reviewed with the EPA/State Field Representative.
Prior to proceeding to the second and third lifts of waste placement, all of the
waste disposal areas will be proof-rolled with a 20-ton (static)
smooth-drummed roller to reduce the potential for future subsidence. Care
will be taken in the area of drummed waste placement to maintain the
integrity of the underlying drums while proofrolling. The OCC and
EPA/State Field Representatives shall determine the level of compaction
required in drum disposal areas.
Vehicles hauling waste material to the placement area
will not enter and leave the waste cell unless appropriate haul road
provisions have been made. These provisions will include construction and
maintenance of "dean" and "dirty" haul routes and allowances for a
27
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5.3 PLACEMENT IN WASTE WELLS
All waste placement into the landfill site will be
completed under the direction of the OCC Field Representative in accordance
with the overall grading plan and an individual plan describing the proposed
disposal activities for each individual disposal area. The individual plan will
be subject to concurrence of the EPA/State Field Representative.
All bulk and drummed wastes will be placed into the
prepared placement area in the corner opposite the lowest base elevation.
The size of the area prepared to receive waste will be consistent with the
estimated volume of waste expected to be generated during that disposal
period. A disposal period typically would last for one to six months
depending upon the type and amount of remedial activity scheduled for the
Site. Typical cells will range in size from 7,500 square feet to 85, 000 square
feet.
The material shall be shaped into a lift of approximately
five feet in height consistent with the final grading plan which has been
designed to improve the surface water runoff characteristics from the Landfill
Site. The material shall be compacted to the extent practicable, given the
equipment available at the time of placement. For the large volume waste
placement programs, specific heavy equipment will be dedicated to the
compaction and interim operations. The small volume waste placement
programs for which heavy compaction equipment will not be available at the
Landfill Site will utilize alternate compaction equipment. Further
compaction of these small volume wastes will be addressed by having these
26
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to insure that precipitation landing on completed areas maintains its
non-waste contact status and can, therefore, be allowed to discharge off the
Landfill Site.
The berms will be constructed using clay which shall be
compacted in six-inch to nine-inch lifts to a density at least equal to 90 percent
of the Maximum Modified Proctor Density or to the density specified by the
day testing laboratory to attain an in-place permeability of 1 x IQ~? on/sec,
whichever is greater. The berm will be keyed three inches into the six-inch
compacted clay base to prevent surface water from entering or leaving the
cell. In the case of cells constructed on top of previous cells, the berms shall
key into the interim cap of the underlying cells. The clay key will be
constructed by pressing pieces of lumber into the lower berm, removing the
lumber, and then placing the upper day berm. All upper cells are to be
constructed in such a manner as to provide the same drainage configuration
as that constructed for the first layer of cells.
The berms will have an interior slope of 1:1 and an
exterior slope of 1:2 or be constructed to match the final contours of the
Landfill Site, allowing for the five-foot cap, if the cell lies along the edge of the
Landfill Site. The berms shall be three feet wide.
Plan 1 presents a typical cell construction detail for
disposal area 3A.
25
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CITY OF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
NIAGARA MOHAWK
POWER CORP.
COSTING GROUND CONTOUR
769-10/07/89-68
figure 9
EXISTING TOPOGRAPHICAL FEATURES
S-Area Landfill
-------
5.2 LANDFILL SITE PREPARATION
Prior to waste placement at the site, a layer of day
(minimum six-inch compacted thickness) will be placed on the Landfill Site
on which all waste will be placed. This day placement will take place as each
disposal cell is constructed. No pregrading will be done as the first lift of
waste will vary somewhat in thickness to accommodate the topographical
irregularities. Efforts will be made to overcome the irregularities in grade
over the first two waste lifts to even out lift heights to the extent practicable.
A map depicting existing topographical features is presented in Figure 9.
To prepare cells for each five-foot lift of waste, clay berms
will be constructed around the entire perimeter of the proposed disposal cell
area. The berms will be at least two feet in height at all locations around the
perimeter and shall be of sufficient height to contain a 25-year storm event
(approximately four inches of rain in a 24-hour period).
In order to insure that the placement can continue to
accommodate a 25-year storm event while the available storage area within
the cell shrinks due to waste placement, surface water landing on top of the
completed placement area (daily day cover in place) will be directed away
from the unused portion of the disposal area. This will be accomplished by
leaving a windrow of clay along the edge of the covered cells to direct dean
surface water to adjacent completed areas and ultimately off the Landfill Site.
Inspection of the day capped waste areas will be induded in a daily inspection
24
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JF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
NIAGARA MOHAWK
POWER CORP.
ROBERT MOSES PARKWAY
LEGEND
9SO PROPOSED FINAL CONTOUR
figure SB
PLAN A
FINAL GRADING PLAN
S-Argo Landfill
-------
A CITY OF NIAGARA FALLS
y\ DRINKING WATER TREATMENT PLANT
NIAGARA MOHAWK
POWER CORP.
LEGEND
PROPOSED FINAL CONTOUR
figurt 8A
PLAN B
FINAL GRADING PLAN
S-Araa Landfill
-------
CITY OF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
ROBERT MOSES PARKWAY
mm PROPOSED uuir or s -ARE*
*»*» WASTE PlACtUfNT
7 PLACEMENT AREA OCSOHAIKM
figure 7A
PLAN B
PLACEMENT AREA 22'-26' LIFT
S-Area Landfill
-------
CITY OF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
PHOPOSU) uuir or s -AREA
WASTE PLACEMENT
NIAGARA MOHAWK
POWER CORP.
5 PtACEUENI AREA
ROBERT MOSES PARKWAY
figure 6A
PLAN B
PLACEMENT AREA 16.5'-21.5' LIFT
S-Aroa Landfill
-------
ln\\ CITY OF NIAGARA FALLS
\3\\ DRINKING WATER TREATMENT PLANT
LEGEND
ROBERT MOSES PARKWAY
man PROPOSED UUIT or S-AREA
2^J WASTE PLACEMEN r
5 PLACEMENT AREA DESIGNATION
figure SB
PLAN A
PLACEMENT AREA 11f-13' LIFT
S-Aroa Landfill
CRA
-------
\
CITY OF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
LEGEND
NO FIUJNG ON VCST Of
rtu \rt « OROOI TO
»T ttmj» d£v»noN$ \
OH BOIH SDCJ «r -nc IAOOONS'.
NIAGARA MOHAWK
POWER CORP.
\
ROBERT MOSES PARKWAY
INDUSTRIAL WHARF
mm PROPOSED LIMIT or s -AREA
*«a WASTE PLACEMENT
1 PLACEMENT AKEA DESICNATION
U f»l FKOM CtlTDNG UO«N
"" CREST OF LAGOON MOUNDS
figure 5A
PLAN B
PLACEMENT AREA 11'-16' LIFT
S-Areo Landfill
-------
CITY OF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
ROBERT MOSES PARKWAY
LEGEND
IWfl PROPOSED UMT OF S-AKEA
"Eil WASTE PLACEMENT
2 PIACCUCNT AKEA DKSCNAIIOh
figure 48
PLAN A
PLACEMENT AREA 5.5'-10.5* LIFT
S-Area Landfill
-------
CITY OF NIAGARA FALLS
DRINKING WATER TREATMENT PLANT
LEGEND
NIAGARA MOHAWK
POWER CORP.
ROBERT MOSES PARKWAY
•jri PROPOSED UHir or s -AWA
*^l WAS1E PLACEMENT
1 PLACEMENr AREA DESIGNATION
figure 4A
INDUSTRIAL WHARF PLAN B
PLACEMENT AREA 5.5'-10.5' LIFT
S-Area Landfill
-------
*f 100'
\\
,P>\\ CITY OF NIAGARA FALLS
w" DRINKING WATER TREATMENT PLANT
LEGEND
RI«3FI PROPOSED UMT OF S-AREA
[&&J WASTE PLACEMENT
1 PLACEMENT AREA DESGNAIlnN
~*^^£>
CRA
figure 3B
PLAN A
PLACEMENT AREA 0'-5' LIFT
S-Aroa Landfill
-------
CITY OF NIAGARA FALLS
y\ DRINKING WATER TREATMENT PLANT
LEGEND
NIAGARA MOHAWK
POWER CORP.
ROBERT MOSES PARKWAY
mm PROPOSED uuir or S-AREA
&LJ WASH: PLACEMENT
1 PLACEMENT AREA DESIGNATION
figure 3A
PLAN B
PLACEMENT AREA 0'-5* LIFT
S-Area Landfill
-------
to minimize erosion and still provides a reasonable slope which facilitates
maintenance of the final cap. The actual final Landfill slope and area will
vary to accommodate the actual waste volume requiring placement. A
minimum three percent slope has been used for the top surface of the
landfill.
Based upon the S-Area Remedial Program Schedule and
the estimate of waste volume to be generated, a general plan has been
prepared identifying where the wastes from each phase of the 5-Area
Remedial Program will be placed. The preliminary disposal area locations for
Plan B waste staging are presented in Figures 3A through 7A for the five
successive lifts of waste planned for placement. Figures 3B through 5B
illustrate the waste staging for Plan A indicating three successive lifts of
waste. Based on the fact that the waste volumes expected are only estimates,
it is understood that actual disposal volumes and conditions will change and,
therefore, it will be necessary to periodically update the estimated volumes
shown in Tables 4A and 4B and to account for the differences encountered.
Based on a cap with 20 percent grade and the generation
volumes of Table 4, preliminary final grading plan for the Landfill Site have
been developed for both plans and are presented in Figure 8A and 8B. These
grading plans will accommodate a 5-foot cap over the expected required
capacity of 66,000 cubic yards (65,100 cubic yards bulk; 900 cubic yards drums)
for Plan B and 33,700 cubic yard, (32,000 cubic yard, bulk; 900 cubic yards
drums) for Plan A. The S-Area Remedial Program will be undertaken in a
manner which minimizes solid waste generating activities so that the height
of waste placement areas can be kept as low as possible.
*•
23
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TABLE 4B
Disposal
Area
Areal
Area2
AreaS
Area 4
AreaS
SOLID WASTE VOLUMES AND
WASTE STAGING PLAN
(PLAN A - RELOCATED DWTP)
'Remedial Construction
Survey/Activity
Northern Containment System
Boreholes (1)
Water Treatment Plant Wells (1)
Chemical Monitoring Wells (1)
Tracer Monitoring Wells (1)
S-Area Bedrock/Overburden Study
Wells (1)
S-Area Barrier Well Investigation (1)
Bedding Study (1)
Monitoring Program-Bedrock Wells
48" Intake Line Survey
day Trench Investigation
DWTP Rehabilitation Wastes
Trench:
Underground Utilities relocation
Severance of Underground Utilities
at Barrier Wall
S-Area Barrier Wall Construction
S-Area Collection System
Lagoon Cleaning
Northern Area Capping (2)
DWTP Collection System
DWTP Capping
Waste Volume
Bulk (cy) Drums
Areal Totals
Area 2 Totals
Area 3 Totals
Area 4 Totals
1,000
2,500
12,900
15,400
10,500
10300
450
1,125
1,575
2,500*
0_
2300
* DWTP ColL System - assume 1000* length, 4' wide, 14' depth average
and 1,2 bulking factor = 2500 cy.
S-Area Capping
Area 5 Totals
Combined Area Totals
1,800
1,800
32300 cy
1348
300
11
10
50
1,898
1,898
(or900c.y.)
Survey Waste from DWTP - Eastern Area (EPA Investigation) - estimated volume = 10 drums
Total available capacity at S-Area is 90,000 cubic yards
Total remaining available capacity for additional S-Area wastes is 56,300 cubic yards.
Notes:
(1) Completed Activities, combined number of drums from these
activities is 1548.
(2) Assuming day cap for the whole area north of Adams Ave. (i.e. worst case)
-------
Page 2 of 2
TABLE 4A
SOLID WASTE VOLUMES AND
WASTE STAGING PLAN
(PLAN B - DWTP IN PLACE)
Disposal Remedial Construction Waste Volume
Area Survey/Activity Bulk(cy) Drums
Area 6 Water Treatment Plant Capping 12,300
Water Treatment Plant Monitoring 60_
Area 6 Totals 12,300 60
Area 7 Concrete Liner Removal/Intake
Tunnel 1,300 -_
Area7Totals 1,300
Area 8 S-Area Capping 2,200
Area 8 Totals 2,200
Combined Area Totals 65,100 cy 1,970 Drums
(or900c.y.)
Survey Waste from DWTP - Eastern Area (EPA Investigation) - estimated volume * 10 drums
Total available capacity at S-Area is 90,000 cubic yards
Total remaining available capacity for additional S-Area wastes is 24,000 cubic yards.
Notes:
(1) Completed Activities, combined number of drums from these
activities is 1548.
(2) Assuming day cap for the whole area north of Adams Ave. (i.e. worst case)
-------
Page .1 of 2
TABLE 4A
SOLID WASTE VOLUMES AND
WASTE STAGING PLAN
(PLAN B - DWTP IN PLACE)
Disposal Remedial Construction Waste Volume
Area SinroeylActivity Bulk(cy) Drums
Area 1 Northern Containment System
Boreholes (1)
Water Treatment Plant Wells (1)
Chemical Monitoring Wells (1)
Tracer Monitoring Wells (1)
S-Area Bedrock/Overburden Study
Wells (1)
S-Area Barrier Well Investigation (1)
Bedding Study (1) - 1348
Monitoring Program-
Bedrock Wells - 300
48" Intake Line Survey 11
day Trench Investigation 10
DWTP Test Pits 8,100
DWTP Rehabilitation Wastes 1,000 -
Area 1 Totals 9,100 1369
Area 2 Trench:
Underground Utilities relocation 2,500
Severance of Underground Utilities
atBarrierWaU 50
S-Area Barrier Wall Construction 12,900 •_
Area 2 Totals 15,400 50
Area 3 S-Area Collection System 10,500
Area 3 Totals 10300
Area 4 Lagoon Cleaning 450
Replace 42" High Service
Discharge Lines 100
Access Shaft 825
Northern Area Capping (2) 1,125
Collection System Pump Station 3300
Area 4 Totals 5,800
Area 5 Optional Collection Systems
i) Filtration Plant "A" 1,600
2) Filtration Plant "B" 1,400
3) Filtered Water Reservoir 5300
Area 5 Totals 8300
-------
10' 100'
\\
CITY OF NIAGARA FALLS
ADRINKING WATER TREATMENT PLANT
NIAGARA MOHAWK
POWER CORP.
LEGEND
AVAHABtE LANW1U. AREA
FOR WASTE PLACEMENT
figure 2B
PLAN A
UMIT OF PLACEMENT AREA
S-Area Landfill
-------
CITY OF NIAGARA FALLS
i\ DRINKING WATER TREATMENT PLANT
NIAGARA MOHAWK
POWER CORP.
"OBERT MOSES PARKWAY
AVAILABLE IANOF1U. AREA
FOK WASH: PLACEMEN r
CRA
figure 2 A
PLAN B
LIMIT OF PLACEMENT AREA
S-Areo Landfill
-------
5.0 SITE PLACEMENT
5.1 SOLID WASTE DISPOSAL AREA
Solid and Semi-Solid Waste materials will be placed
within the area defined by the Site Barrier Wall at the Landfill Site. For the
purposes of this plan, OCC intends to use only those areas historically utilized
for S-Area waste disposal.
Because the existing lagoon at the landfill will be taken
out of service, this area can be available for waste placement disposal for
. Plan B, the area! extent of the proposed Site placement area is presented in
Figure 2A. Figure 2B indicates that the area! extent of the proposed Site
placement area for Flan A has been restricted to the east side of the lagoons as
a smaller volume of waste is available for disposal. Table 4A and 4B present a
sequential plan for waste placement in various areas and the anticipated
volumes depending upon whether the DWTP is left in place (Table 4A) or
relocated (Table 4B).
All waste will be placed in lifts of up to approximately five
feet in height in accordance with the final grading plan. During the first lift,
some areas may be in excess of five feet thick to account for present
topographic irregularities. Waste cells will be stacked on top of each other to
accommodate waste placement and to match the final grading plan. The final
grading plan is based on assumed final side slopes of approximately 20 percent
although a final slope of up to 25 percent is acceptable. A final slope of 20
to 25 percent is stable, provides good surface water drainage, can be controlled
22
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Judgment. Discharge to a permitted outfall at the Buffalo Avenue Plant will
require OCC to obtain permit authorization for such discharge. OCC shall use
its best efforts to obtain all permits, approvals or authorizations for discharge
by the scheduled start of remedial systems operation that will require AFL
Treatment.
4.4.7 Containment Dike
The design of the S-Area APL/NAPL storage facility will
include a concrete containment dike to be constructed surrounding an area
sufficient to permit the construction of 6 tanks of 158,000 gallons each. This
containment dike will have a capacity of at least 110 percent of the capacity of
the largest tank plus allowances for rainwater. The floor of the containment
area will be sloped to direct spills, leaks, and rainwater to a sump from which
it will be pumped back to a storage tank for subsequent treatment.
21
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for installation of APCE equipment on OCC's Liquid Incinerator, for
permitting CXCs Solids Incinerator to incinerate liquid waste and for
other incineration, treatment and storage alternatives, if required.
c) APL Treatment
Initially, all APL collected from the sources described in
Section 2.2 will be trailered or piped directly to OCCs existing Niagara Plant
Carbon Treatment facility following the separation of NAPL in the decanters
at the S-Area APL/NAPL Storage Facility. Once the rates of APL collection are
better defined following Phase I remedial activities, OCC plans to construct a
Carbon Treatment facility adjacent to the existing Carbon Treatment facility.
It is presently anticipated that this new treatment facility will be capable of
handling approximately 300 gpm. This facility will also be designed with an
allowance for expansion capacity in the event the actual APL treatment
requirements are higher than anticipated. The new treatment facility will use
two stages of carbon adsorption to remove organic compounds from the APL.
The carbon from the first stage (sacrificial bed) will be
containerized and stored in permitted facilities at the Niagara Plant pending
incineration in the OCC Solids Incinerator. The spent carbon from the second
stage adsorbers will be returned to the carbon vendor for regeneration.
Effluent from both carbon treatment facilities will be
discharged to the City of Niagara Falls POTW or to a permitted outfall at the
OCC Buffalo Avenue Plant. Discharge to the City's POTW shall be subject to
the requirements of subparagraph G(l) and (2) of Addendum I of the
20
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OCC's activities to obtain governmental authorizations to
incinerate NAPL generated by activities under the Judgment at the OCC
Liquids Incinerator and the OCC Solids Incinerator will include the following:
(i) OCC will collect samples of NAPL from the Landfill Site from two
existing bedrock wells and two existing overburden wells selected in
consultation with EPA/State. A total of 100-200 gallons will be collected.
The sample from each well location will be analyzed for heavy metals,
ash, and BTU value. OCC will submit a report describing the results of
the sampling and analysis to EPA/State in accordance with Schedule A
of the Remedial Waste Treatment Milestone Schedule (RWTMS).
Within 60 days following such submission, the Program Coordinators or
their designees will meet to discuss the report.
(ii) Pursuant to the Supplementary Approval Procedures described in
paragraph 4(b), Section B, Attachment F-2, of OCC's Liquids Incinerator
permit, OCC will submit to EPA/DEC a plan to collect a representative
sample of NAPL from the Landfill Site ("NAPL Collection Plan") for
characterization in accordance with permitting requirements. The Plan
will include a description of collection procedures and a schedule for
completing sample collection and analysis. OCC will submit the plan in
accordance with Schedule A of the RWTMS and will implement the
Plan following approval by EPA/DEC permitting authorities in
accordance with the schedule set forth in the approved plan.
(iii) In addition to these activities, OCC will pursue governmental approvals
as described in Paragraph 20 of the RRT Stipulation and in the RWTMS
19
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Treatment Facility. Following completion of the Phase I activities per
Section 4.3 of Appendix I, OCC will estimate whether the installed APL
storage tanks provide sufficient capacity for APL volumes expected to be
collected during one day's normal operations of remedial programs installed
under the Judgment and if one day storage is sufficient or necessary for
operational needs. Within 30 days following completion of Phase I activities,
OCC will submit a report to EPA/State describing the results of the estimate.
If that estimate concludes that the installed APL tanks do not provide
sufficient storage capacity, OCC shall promptly install additional tanks to
provide such storage capacity.
The facility has been designed and will be authorized to
accommodate a maximum of six storage tanks. In no event will OCC be
required to install more than six tanks at the S-Area APL/NAPL Storage
Facility except as provided in Paragraph 20(d) or 20(e) of the Stipulation.
b) NAPL Treatment
NAPL collected from sources described in Section 2.2 and
from the investigation activities described in Section 4.0, Appendix I will be
treated at a facility which satisfies all applicable regulatory and permitting
requirements. As described in the RRT Stipulation, the OCC Liquids
Indrierator and the OCC Solids Incinerator, either singly or in combination,
are the preferred facilities for the treatment of NAPL generated during
activities under the Judgment.
18
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4.4.6 APL/NAPL Storage and Treatment
a) AFL/NAPL Storage
APL and NAPL collected from the sources described in
Section 2.2 and from the investigation activities described in Section 4.0,
Appendix I will be temporarily stored in tanks pending APL treatment or
NAPL incineration. The S-Area APL/NAPL Storage Facility will be located
north of Adams Avenue, west of 53rd Street (see Plan 1). Each tank at the
facility will be approximately 30 feet in diameter and 32 feet high, with a
capacity of approximately 158,000 gallons.
Initially, one NAPL storage tank will be installed at the
facility to meet the anticipated operational needs of the thermal treatment
facility that is authorized or expected to be authorized for the S-Area NAPL.
Within 30 days following the completion of the Phase I activities per
Section 4.3 of Appendix I, OCC will estimate the monthly NAPL volumes
expected to be generated by normal remedial system operations under the
Judgment and will submit a report to EPA/State describing the results of its
estimate. If that estimate indicates that three months of NAPL generation
will exceed the capacity of the installed NAPL storage tank, OCC will also
include in its submissions an assessment whether the installation of
additional NAPL capacity is required to meet the operational needs of the
NAPL thermal treatment facility.
Initially, two APL storage tanks will be installed at the
facility to meet the anticipated operational needs of the Niagara Plant APL
17
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Dimensions and capacity of the decanters are as follows:
Decanter dimensions: 8 feet diameter
32 feet high
Decanter Capacity: 11,200 gal
A total of five decanters for the separation of NAPL from
the recovered APL/NAPL will be used.
Two decanters to process all of the APL/NAPL from the
overburden (purge wells and collection systems) will be used. The flow from
the overburden purge wells (6 gpm) into a single decanter creates a detention
time of 1,900 minutes. The flow from the combined landfill site (6 gpm) and
Pump Station (22 gpm) Collection Systems into a single decanter creates a
detention time of 400 minutes. If the DWTP is relocated the Pump Station
Collection System would not be constructed. However, a drain tile collection
system would be constructed at the DWTP. How rates will be determined
after realization of the reduced system location.
Flow from the bedrock purge wells, which is estimated to
be 270 gal/min., will be directed to three decanters. The use of three decanters
will result in an average detention time of 120 minutes.
16
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Handling Facility. As such, the decanter size, decanting times, and storage
volumes are consistent with the Hyde Park system.
The NAPL (having a Specific Gravity of 1.6) will settle to
the bottom of the decanter while the APL (Specific Gravity « 1.0) will remain
above the NAPL. NAPL will then be drawn off from the bottom of the tank
and APL can be removed from the top of the tank.
A small proportion of the NAPL may be lighter than
water and will float on top of the APL. The conceptual design of the decanters
provides for a number of pipe outlets situated at varying heights.
Lighter-than-water NAPL will be removed from the decanter periodically
using these outlets by reducing the fluid volume in the decanter to a level
below a selected pipe outlet. A small increase in the fluid volume will then
allow the light NAPL to flow out of the selected outlet and it can then be
piped to the NAPL storage tank.
The required settling time is dependent on the physical
characteristics of the liquids being separated. The rate of settling is more rapid
for larger droplet sizes, large density difference between phases, and low
viscosity of the continuous phase (APL).
The volume of the decanter vessel is selected to provide a
detention time sufficient to allow adequate separation of the two phases.
Detention time is calculated from the relation:
Holding time = decanter voL/flow rate. „.
15
\
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4.4.3 Chemical Composition
Chemical analyses of samples from overburden and
bedrock survey wells are compiled in the reports entitled "Information
Summary Report, Volume II, Appendix 6 • Analytical Results, S-Area
Remedial Program" and "NAPL in Bedrock Beneath the Niagara River,
Assessment of Human Endangennent, S-Area Remedial Program".
4.4.4 Piping of APL/NAPL to Storage Facility
Efficient separation of NAPL from the collected
APL/NAPL and treatment of APL must take into consideration the
differences in the APL/NAPL characteristics from each area (volume fraction
and chemical composition). For this reason, APL/NAPL from the
overburden collection systems, overburden purge wells, and bedrock purge
wells will be piped separately to the S-Area APL/NAPL Storage Facility.
4.4.5 APL/NAPL Separation
Separation Method
NAPL will be separated from the recovered APL/NAPL
using gravity separation (decanting). It should be noted that the conceptual
design of separation methods for this plan are based on the separation
methods incorporated in the design of the Hyde Park Leachate Storage and
14
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The water from construction dewatering activities will be
pumped through a filtration unit such as a sand filter to remove suspended
material. Thereafter, the water will be trailered or piped to the S-Area Storage
Facility and carbon treated at an OCC Facility and discharged in accordance
with all applicable laws and regulations at the OCC Niagara Plant. Solid or
semi-solid sediment will be collected, solidified and placed in sealed units and
placed in the landfill site as described in Section 4.1.
Chart 2 presents the flow diagram for handling liquid
wastes.
4.4.2 Physical Characteristics of APL/NAPL
Specific Gravity of NAPL
Based on the results of physical testing completed on a
number of S -Area bedrock samples of NAPL, the specific gravity of NAPL was
determined to be approximately 1.6.
Viscosity of NAPL
Based on the results of physical testing completed on a
number of S-Area bedrock samples of NAPL, the viscosity of NAPL was
determined to be approximately 0.000118 Ib sec/ft2 (5.6 centipoise).
13
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The design of the separation decanters, storage tanks, and
ancillary equipment for S-Area AFL/NAFL will be based on the design of the
Hyde Park Leachate Storage and Handling Facility, including the
requirements of detention times for APL/NAPL separation. The design
capacity of the storage facility is discussed in Section 4.4.6 and 4.4.7.
4.4.1 Tunnel Water/Construction Water
In order to perform the visual inspection of the Emerald
Channel Intake Tunnel, it will be necessary to dewater the tunnel and
maintain it in a dewatered state for the duration of the inspection. It is
anticipated that approximately two days will be required to complete the
inspection. This activity will not be undertaken if a new DWTP is
constructed.
It is estimated that the initial volume of water in the
tunnel is 860,000 gallons. This water will be discharged to the sanitary sewer
at the DWTP for treatment at the City of Niagara Falls POTW. Once this
volume of water has been discharged, pumping will continue to keep the
tunnel dewatered. It is presently anticipated that a pumping rate of 70 gpm
will be required to accomplish this. The pumping of water beyond the initial
860,000 gallons will be handled in the same manner as construction
dewatering activities as described in the next paragraph.
12
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treatment of the APL. This storage facility will be located north of Adams
Avenue, west of 53rd Street (see Plan 1).
This section discusses the conceptual design of the S-Area
APL/NAPL Storage Facility. This conceptual design addresses the
requirements of the APL/NAPL Storage Facility regarding:
1) expected volumes of APL/NAPL to be pumped from the overburden
collection systems, the overburden purge wells and the bedrock purge
wells, as discussed in Section 3.2.1 and 3.2.2;
2) estimated volume of NAPL to be recovered, as discussed in
Section 3.2.2;
3) physical properties of the APL/NAPL as they relate to separation of
NAPL;
4) temporary storage of the APL/NAPL; and
5) treatment of the APL at the Niagara Plant APL Treatment Facility and
incineration of the NAPL at the Niagara Plant Liquid Incinerator.
The 5-Area KRT Program provides for pumping and
collection of APL/NAPL from the overburden and bedrock. This APL/NAPL
will be transported from their source to the APL/NAPL Storage Facility,
NAPL and APL will be separated, and the NAPL and APL will be stored prior
to incineration or treatment, respectively.
11
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spread over semi-solid wastes to promote stabilization. The use of absorbent
material will be at the direction of OCC's Representative in the field.
Materials which do not stabilize will be reworked until suitable stabilization
has been achieved. Where appropriate, the paint filter test methodology
(Method 9095 as described in EPA Publication SW846) will be used to
determine stability of semi-solid wastes. In cases where OCC and EPA/State's
Field Representatives do not agree as to when stabilization has occurred, a
paint filter test shall be conducted to confirm the degree of stabilization that
has been achieved.
Absorbent materials to be used for stabilization purposes
may include flyash, portland cement and "speedi-dry" type materials. OCC's
Field Representative will select the absorbent to be used in each case and will
inform the EPA/State Field Representative of the selection. Should a
material other than one of the above be selected, concurrence with the
EPA/State Field Representative will be obtained prior to use.
4.4 LIQUID WASTE
Due to the anticipated volume of S-Area liquid wastes to
be handled, it will be necessary to construct a permanent storage facility
within the AOC. The proposed S-Area APL/NAPL Storage Facility will be
designed to be consistent with all applicable regulations and will include
decanters for the separation of NAPL from the APL and tanks for the
temporary storage of all the liquids prior to incineration of the NAPL and
10
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implemented. If the changes implemented do not resolve the handling
problems, the use of fiber drums will be discontinued.
4.2 BULK SOUP WASTES
All bulk solid waste will be transferred from its area of
generation or storage to the waste placement area on the Landfill Site. The
wastes will be placed into the daily spoils cell and covered in accordance with
the specified operating procedures in Section 5.0. All loading and unloading
of waste from trucks will be done per Section 5.3 and Safety Operating
Procedure S#6 (see Appendix A).
4.3 SEMI-SOLID WASTES
Semi-solid wastes described in Section 2.1 will be placed
directly into a selected area of the active waste disposal cell and allowed to
decant. The area chosen for semi-solid decanting will be field selected by the
OCC Field Representative in concurrence with the EPA/State Field
Representative. Factors such as weather conditions, volume of semi-solid
waste, amount of observed decanting occurring and other relevant
information shall be taken into consideration in this matter. Any collectable
liquid will be pumped out to a trailer or stored within the AOC on a daily
basis. Once suitably decanted, the material shall be capped in place (or
consolidated as appropriate) and the waste cell closed in accordance with the
specified operating procedures. If necessary, an absorbent material will be
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generated drummed waste to insure that drums contain no greater than
five percent void space. Any identified unfilled drums shall be topped up
with waste material. In the case of sludge wastes to be drummed/ the OCC
Field Representative shall perform a paint filter test for free liquids (Method
#9095 as described in EPA Publication SW846). The test shall be performed
once for every ten drums of each sludge-type waste or more often at the
discretion of the OCC and EPA/State Field Representatives. Material failing
the test shall have absorbent material added in sufficient amounts and mixed
to achieve stabilization.
Any drum placement at the Landfill Site will be upright,
side by side and covered so that material enters the voids between them. The
drums may be double stacked. As an alternative to steel drums, OCC may, at
its option and with the EPA/State Field Representative's concurrence, use
fiber drums for non-saturated waste materials or DOT-approved fiber waste
containers. These substitute containers would be placed in the cell in the
same manner as the drums. The use of fiber drums will be restricted to
materials which are compatible (based on moisture conditions, size, chemical
reactivity and corrosivity and shape) with the specific containers proposed for
use.
The use of fiber drums is further restricted to cases where
the drums will be placed either directly into a waste cell for placement at the
end of each working day or stored in the drum storage area for no longer than
one work day unless suitably covered with polyethylene. If fiber drums
exhibit handling problems, changes in the handling procedures will be
8
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WASTE MANAGEMENT STEPS
WASTE GENERATI
*
UCUD
I
APL
APL/NAPL
— _, SOLD /
^ SEE
NAPL
SEPARATION
'
FILTRATION
(SEDIMENT REMOVAL) ApL
{
SEDMENT
i
STORAGE DECANT
*
pH ADJUSTMENT pREOPtTATE
t
TRANSFER TO fl) TRUCK
PUMT 00 PIPELINE
FILTRATION
NApL (SEDIMENT REMOVAL)
t
SEDIMENT
blUKAUt
\
PLACED IN TRANSFER TO
EALED UNTTS WONERATION
FACLTY
|
MSPECT
1
INCINERATE
*
TREATMENT AT
CARBON ABSORPTION
FAOUTY
t
DISPOSAL - DISCHARGE TO
SANITARY SEWER
SYSTEM
X
COVFP •
ASH
F
L
FULL | 1 1
NOT FULL INCWERATE
CHART 1
(0 TRUCK
ADD
WASTE
1
PAINT FILTER TEST
WHERE APPROPRIATE
FAIL
STABttJZED
^
1 PASS
-p SOLD
I
CLOSE UNITS
*
E IN CELL
• REMOVAL OF PREOPITATE, IF ANY. DUE TO pH ADJUSTMENT
chart 2
BASIC WASTE MANAGEMENT STEPS - UQUID
S-AREA WASTE MANAGEMENT PLAN
CRA S—Area Landfill
1769-30/10/89-68-0 (C-7)
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CRA
WASTE MANAGEMENT STEPS
'
LKXJ
SEE CHi
LIQUID
ID
vn 2
sa
nrrvA
CE
f
ll-SOUD
I
MT (M
ILS
UfACTr fiClfCDATCn
*
SCUD/SEMI-SOLID
1
PLACE M CELL
r
INSPECT WASTE
1
T
SCUD
P
SE
fUl
L
! '
LACED IN
ALED UNITS
{
INSPECT
tnot
ftjll
ADO WASTE
CLOSE UNITS
1
njMtft IN uu
SCUDS
PAINT FILTER TEST
WHERE APPROPRIATE
STABOJZED
SOLD
r T
COMPACT TO EXTENT
PRACTICABLE
COVER
chart 1
BASIC WASTE MANAGEMENT STEPS
SOUDS / SEMI-SOLIDS
S-AREA WASTE MANAGEMENT PLAN
S-Area Landfill
1769-24/11/87-68-0 (C-1)
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4.0 WASTE MATERIAL STORAGE & HANDLING
The basic steps describing waste material handling are
presented in Charts 1 and 2.
4.1 DRUMMED SOUP WASTES
Drummed solid waste materials described in Section 2.1
will be placed in a staging area in the active waste disposal cell in the S-Area.
This staging area will be field selected by the OCC Field Representative subject
to concurrence with the EPA/State Field Representative. As drums are
accumulated in the staging area, the inventory of drums will be regularly
reviewed. The decision to remove the drums from the staging area to the
operating disposal face within the disposal area will be made by the OCC Held
representative in concurrence with EPA/State field representative. The
drums will then be covered in accordance with the disposal protocols detailed
later in this section. In the event that other remedial activities are taking
place at the same time that drummed solid wastes are being generated, the
drums may, at OCC's option, be disposed directly into the operating
placement face in concurrence with the EPA/State field representative. The
drums will be filled to the maximum extent practicable with waste. Empty
drums disposed at the Landfill Site will be crushed prior to disposal.
As drummed wastes are generated or prior to site
placement, the drums will be filled to contain less than five percent void
s.pace. The OCC Field Representative shall make daily inspections of
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TABLES
NAPL VOLUME FLOW RATES
APL/NAPL
Source
System
Estimated
Start APUNAPL
Date Flow Rate
(gpm)
NAPL
NAPL Flow
Rate
(gpm)
Total NAPL
Volume/Time
Period
(gallons)
Note
Overburden
Collection
System and
Purge Wells
May 1993
12
1
0.1
0.12
0.01
5,200
First 30 Days
After 30 Days
Pump Station*1* March 1993
Collection
System
22
Bedrock
Purge
Wells
June, 1995
270
270
270
8
4
0.4
21.6
10.8
1.1
31,100
15350
1,584
(91,000)
First Day
Second Day
Third Day and
thereafter
First 30 Days
Note:
(1)
If the DWTP is relocated, the Pump Station Collection System would be eliminated and a smaller collection
system will be implemented in its place.
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TABLE2
NAPL GENERATION RATES
Estimated
Duration
1 month (1993)
4 months (1993)
Continuous
in 1993
2 Weeks
(1992)
One Month
(1992)
One Month
(1993)
Continuous
(1993)
Incremental
Rate
032
Description
Overburden Collection System and
Purge Wells (0.12)^ > (During Initial
Startup Period) and Pump Tests on
11 Bedrock Purge Wells (02) G)
Overburden Collection System and
Purge Wells (0.01)(3) + Pump Test on 11 BR
Purge Wells (0.2) (4)
Overburden Collection System and
Purge Wells (Estimated Long Term
NAPL Collection Rate)
Pump Test on 2 Bedrock Wells
Pump Test on 6 Bedrock Wells
Prototype Bedrock Purge Well System
(During initial Startup Period)
Prototype Bedrock Purge Well System
(Estimated Long Term NAPL Collection
Rate)
Notes:
(1) 1% of OBCS How (see Table 3) for first 30 days
(2) Test 11 wells for 5 days each at 5 gpm. Allow week for recovery between tests
5x11
therefore, Q = 5 gpm x7 x 22 =1.79 gpm
Assume 10% NAPL = 02 gpm
(3) 0.1% of OBCS flow (see Table 3) after first 30 days
(4) See (2) above
(5) Test 2 wells for 24 hours each at 75 gpm. Allow one week to perform both tests
2
therefore, Q = 75gpmx= =21.4 gpm
Assume 8% NAPL =171 gpm
(6) Test 6 wells for 24 hours each at 100 gpm. Allow three weeks to perform all tests.
therefore, Q = lOOgpmx_-r =28.6 gpm
Assume 8% NAPL = 2.4 gpm
(7) 9 wells at 30 gpm each. Q = 270
NAPL = 270 x (1 x 0.08 + 1 x 0.04 + 28 x 0.004)/30 = 2.1 gpm (see Table 3)
(8) See Table 3 - Bedrock Purge Wells
0.21
0.01
1.71
2.4 (6)
2.1
1.1
NAPL
Volume
(gallons)
13,820
40,820
Continuous
17240
72,580
90,720
Continuous
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the operation of the bedrock purge wells. A total of 9 wells are included in
the initial design of the bedrock remediation system. Each well is planned to
operate at 30 gpm. This is based on the experience gained at the Hyde Park
Landfill where well yields of up to 20 gpm were measured. Since S-Area is
expected to have more groundwater available for extraction than Hyde Park
therefore a factor of 1.5 was applied to the 20 gpm. In addition, a pump test
performed at 53rd Street identified well yields in excess of 100 gpm with
considerable drawdown criteria. Pump tests will be conducted as a part of
RRT Remedial Plans (see Appendix I, Section 4.3.2). Data collected from these
tests will be used to determine appropriate pumping rates for each well.
Based upon current information, an initial pumping rate of 270 gpm is
reasonable.
3.2.2 NAPL Volume
This section addresses the volume of NAPL generated for
future treatment from the S-Area Remedial Program.
The estimated NAPL volumes and rates generated for
future incineration are summarized on Tables 2 and 3, respectively.
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Source
A. Construction Water
1) Testexcavationsd)
Waste Cell runoff
Equipment decontamination
2) Utility Relocations
Waste Cell Runoff
Equipment decontamination
3) Slurry Walls
DWTP Tile Collection Systemd)
S-Area Tile Collection System
Waste Cell Runoff
Equipment Cleaning
TABLE 1
APL VOLUME ESTIMATES
Estimated
Flow Rate Range APL Volume
(CPD)
(gallons)
APL
Flow Rate
(gpm)
(with DWTP)
14704,410
1440
200
2^10-9,950
0.0-40,600
1440
200
1440-12,140
0.0
720-11410
2,960-13,100
200
51,700
14,700
2,200
68,600
590,900
104400
11400
717,200
0.0
231,100
471,200
332400
35,400
5,220-26,450
4) Continued Dewatering of DWTP
Tunnel (for inspection only of
Emerald Channel TunnelXl)
Total Construction Waste Water Quantity
Dewatering Activities
5) Initial Dewatering of DWTP Tunnel(l)
Total Dewatering Waste Water Quantity
C S-Area Remedial System Operation
6) i) Overburden collection system(2)
ii) Overburden purge wells (12 wells © 0.5 gpm)
iii) Bedrock purge wells (9 wells ffl 30 gpm)
iv) DWTP overburden collection systems(3)
• Pump Station
• Optional Systems
100,800
Total Operations Waste Water Quantity
Notes:
1,070,000
201,600
2,057,400 Gallons
860,000
860,000 Gallons
6
6
270
22
not estimated
304 Gallons/Minute
T) These activities would be deleted if the DWTP is relocated
2) APL flow rate is for scenario of completed Barrier Wall bui no capping.
3) These activities would be reduced if the DWTP is relocated.
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"No Migration Variance Permit
Centralized Storage Facility
UFA 90-86-0707
EPA ID No. NYD 000824482
Niagara Plant"
3.2 LIQUID WASTE VOLUME
Estimates have been made of the anticipated volumes of
liquid waste to be generated by the S-Area Remedial Programs.
The APL and NAPL liquid volume estimates are
individually calculated in the following sections.
3.2.1 APL Volume
APL generated by the S-Area Remedial Programs will be
treated at the existing Niagara Plant Carbon Treatment Facility or an
additional carbon facility to be built at the Niagara Plant Effluent from the
existing treatment facility will be discharged to the Niagara Falls POTW. The
effluent from the new treatment facility will be evaluated to determine
whether it will be discharged to the City of Niagara Falls POTW or a Niagara
Plant permitted outfall as per Paragraph 4.4.6.
The estimated APL sources and volumes generated are
presented on Table 1. The major portion of the APL waste generated is from
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3.0 WASTE VOLUMES
3.1 SOUP WASTE VOLUME
Estimates have been made of the anticipated volumes of
solid waste to be generated by the S-Area Remedial Programs. The estimated
waste volume is as follows:
Plan A (new DWTP is constructed)
• 33,700 cubic yards of S-Area and DWTP Remedial Activity Wastes
(32,800 c.y. bulk and 900 cy. drums);
Plan B (DWTP remains in place)
• 66,000 cubic yards of S-Area and DWTP Remedial Activity Wastes
(65,100 c.y. bulk and 900 cy. drums);
The S-Area solid wastes generated during the
investigation phases of the programs that have already been completed are
currently stored in Building V-60. These wastes will be incinerated at OCC's
proposed solid waste incinerator. Details of the CSF, its operation, remote site
locations, and waste volume estimates are found in the following document:
-------
In addition, as set forth in Section 5.6.2, ash residue from
OCC's proposed thermal destruction unit at its Niagara Plant (OCC's Solids
Incinerator), may be used as intermediate fill for the contouring and final
capping. Any waste generated within the AOC mat is removed from the AOC
will not be returned to the Landfill Site unless such waste is treated pursuant
to applicable regulations.
2.2 LIQUID WASTE
All APL and NAPL wastes from the S-Area Remedial
Program activities will be separated and subsequently treated at OCC's facility
at the Niagara Plant. The sources of APL and NAPL wastes will include the
following:
1. Ground water from dewatering activities during construction including
APL and NAPL collected during S-Area Remedial Programs.
2. Cleaning liquids generated from washing operations, including
solvents.
3. APL/NAPL recovered from S-Area Remedial Program operations,
including overburden collection systems, overburden and bedrock
purge wells and overburden and bedrock NAPL recovery wells.
-------
0 100 230ft
CRA
figure 1
AREA OF CONCERN
S-Areo Landfill
I769-IO/O7/89 68-1
-------
2.0 WASTE SOURCES
2.1 SOLID WASTE
The following solid and semi-solid waste from the
following sources (resulting from investigative and remedial activities) will
be disposed of at the landfill site:
1. Solid and semi-solid waste from the S-Area Remedial Programs,
2. S-Area Survey wastes to be generated in the future and stored within
the Area of Concern (AOC) at the Niagara Plant as shown on Figure 1,
3. Any waste related to the remediation activities on the eastern portion
of the Drinking Water Treatment Plant (DWTP), and
4. Any waste generated from rehabilitation work at the DWTP which
cannot be disposed at a sanitary landfill.
All solid and semi-solid waste managed by this section
will be generated within the AOC as shown in Figure 1 and will remain
within the AOC, until placement in the landfill. Because the AOC
encompasses the area impacted by the migration of chemical residue from the
S-Area Landfill, activities under this plan relating to solid waste placement
may be considered "replacement" of material historically deposited at the
landfill. All solid and semi-solid waste will be placed within the boundaries
of the historic S-Area disposal area.
-------
1.0 INTRODUCTION
This document describes the plan of Occidental Chemical
Corporation (OCC) to manage waste materials generated during the S-Area
Remedial Program (all investigation and remedial programs required under
the S-Area Settlement Agreement, including court-approved modifications
such as the RRT program) including remedial and rehabilitation work at the
DWTP. These plans includes the handling, treatment and placement of solid,
semi-solid, aqueous phase liquids (APL), and non-aqueous phase liquids
(NAPL) waste materials.
At the present time, either of two alternative remedial
plans will be implemented at the City of Niagara Falls Drinking Water
Treatment Plant (DWTP). One remedial plan will be essentially as described
in the S-Area Settlement Agreement (Plan B) and the alternative plan will
involve the construction of a new DWTP at a different location and closure of
the existing plant (Plan A). In order to make this waste management plan as
complete as possible, both plans are considered throughout the remainder of
this report. Whenever wastes generated by the S-Area Remedial Program
(solid, semi-solid, APL or NAPL) are referenced to in this document, these
wastes are intended to include wastes from both the S-Area and the selected
remedial plan for the DWTP.
-------
LIST OF TABLES
Following
Page
TABLE 1 APL VOLUME ESTIMATES 5
TABLE 2 NAPL GENERATION RATES 6
TABLE 3 NAPL VOLUME FLOW RATES 6
TABLE 4A SOLID WASTE VOLUMES AND WASTE
STAGING PLAN (PLAN B - DWTP IN PLACE) 22
TABLE 4B SOLID WASTE VOLUMES AND WASTE
STAGING PLAN (PLAN OPTION B - RELOCATE DWTP) 22
-------
LIST OF PLANS
PLAN 1 CELL CONSTRUCTION
AREA NO. 1
LIST OF APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
SAFETY OPERATING PROCEDURE S#6
ON-SITE TRAFFIC STANDARD OPERATION PROCEDURES
SOIL TESTING PROCEDURES QA/QC PLAN
LEVELS OF WORKER PROTECTION
SAFETY OPERATING PROCEDURE S#10
GROUTING PROCEDURE FOR WELL CLOSURE
LIST OF ATTACHMENTS
ATTACHMENT A REMEDIAL WASTE TREATMENT MILESTONE
SCHEDULE
-------
T T!?r OF FIGURES
CHART 1 BASIC WASTE MANAGEMENT STEPS
- SOLID/SEMI SOLIDS
CHART 2 BASIC WASTE MANAGEMENT STEPS
-LIQUIDS
Following
Page
FIGURE 1 AREA OF CONCENTRATION
FIGURE 2A UMTT OF PLACEMENT AREA - PLAN B
FIGURE 2B LIMIT OF PLACEMENT AREA - PLAN A
FIGURE 3A PLACEMENT AREA O1 - 5'LIFT - PLAN B
FIGURE 3B PLACEMENT AREA 0' - 5' LIFT - PLAN A
FIGURE 4A PLACEMENT AREA 5.5' -10.5' LIFT - PLAN B
FIGURE 4B PLACEMENT AREA 5.5' - 10.5' LIFT - PLAN A
FIGURE 5A PLACEMENT AREA 11' -16' LIFT - PLAN B
FIGURE 5B PLACEMENT AREA 11'-13'LIFT-PLAN A
FIGURE 6A PLACEMENT AREA 16.5' - 21.5' LEFT - PLAN B
FIGURE 7A PLACEMENT AREA 22' - 26' LIFT - PLAN B
FIGURE 8A FINAL GRADING PLAN - PLAN B
FIGURE 8B FINAL GRADING PLAN - PLAN A
FIGURE 9
EXISTING TOPOGRAPHICAL FEATURES
2
22
22
23
23
23
23
23
23
23
23
23
23
24
-------
TABLE OF
1.0 INTRODUCTION 1
2.0 WASTE SOURCES 2
2.1 SOLID WASTE 2
2.2 LIQUID WASTE 3
3.0 WASTE VOLUMES 4
3.1 SOLID WASTE VOLUME 4
3.2 LIQUID WASTE VOLUME 5
3.2.1 APL Volume 5
3.2.2 NAPL Volume 6
4.0 WASTE MATERIAL STORAGE & HANDLING 7
4.1 DRUMMED SOLID WASTES 7
4.2 BULK SOLID WASTES 9
43 SEMI-SOLID WASTES 9
4.4 LIQUID WASTE 10
4.4.1 Tunnel Water/Construction Water 12
4.4.2 Physical Characteristics of APL/NAPL 13
4.4.3 Chemical Composition ~. 14
4.4.4 Piping of APL/NAPL to Storage Facility 14
4.4.5 APL/NAPL Separation 14
4.4.6 APL/NAPL Storage and Treatment 17
4.4.7 Containment Dike 21
50 SITE PLACEMENT 22
5.1 SOLID WASTE DISPOSAL AREA 22
5.2 LANDFILL SITE PREPARATION : 24
5.3 PLACEMENT IN WASTE WELLS 26
5.4 OTHER CONSIDERATIONS 29
5.5 LAGOON DECOMMISSIONING 30
5.6 WASTE CAPPING 30
5.6.1 Interim Capping 30
5.6.2 Final Capping 32
5.7 SUPERVISION; DOCUMENTATION AND
MONITORING REQUIREMENTS 33
5.8 SECURITY FENCE AND ACCESS REQUIREMENTS 36
5.9 SURFACE WATER HANDLING 38
5.10 HEALTH AND SAFETY PLAN 41
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APPENDIX IV
REMEDIAL WASTE MANAGEMENT PLAN
-------
VOLUME II
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
THE STATE OF NEW YORK,
Plaintiffs,
v.
OCCIDENTAL CHEMICAL CORPORATION and
THE CITY OF NIAGARA FALLS, NEW YORK,
Defendants.
Civil Action No.
79-988 (JTC)
(S-Area Landfill)
STIPULATION ON
REQUISITE REMEDIAL TECHNOLOGY (RRT) PROGRAM
APPENDIX IV
APPENDIX V
APPENDIX VI
REMEDIAL WASTE MANAGEMENT PLAN
OCC S-AREA PROJECT SCHEDULE
INSURANCE CERTIFICATE FORM
-------
COST REDUCTION SUMMARY
New WTP Transmission Pipelines
(August 1988 Dollars)
1. Porter Road Location;
48-inch Raw Hater Pipeline 14,000 l.f.
48-inch High Service Pipelines 5000 l.f.
20-inch Hich Service Pipeline 2000 l.f.
$4,300,000
1,500,000
400.000
Sub-Total: $6,200,000
Engineering, Legal, Admin. (25V)
Contingency (10%)
1,600,000
600.000
Total:
$8,400,000
2. Adjacent Buffalo Avenue Location
Raw Water Pipeline 500 l.f.
High Service Pipelines 1500 l.f.
$ 150,000
470.000
Sub-Total: $ 620,000
Engineering, Legal, Admin. (25%)
Contingency (10%)
210.000
Total:
$ 830,000
-------
JVVUODUVt
PIRNIE
April 19. 1990
MALCOLM PIRNIE. INC.
ENVIRONMENTAL ENGINEERS. SCIENTISTS A PLANNERS
Mr. John R. Hestendorf
Director of Hater Facilities
City of Niagara Falls Hater Treatment Plant
5317 Buffalo Avenue - P.O. Box 69
Niagara Falls, New York 14302-0069
Re: Costs for New Hater Treatment Plant Transmission Pipelines
Dear Mr. Hestendorf:
As you know, Malcolm Pirnie assisted the City's independent consultant in
August 1988 by preparing a preliminary cost estimate for a new water
treatment plant located on Porter Road. This cost estimate was conceptual
in nature, as no detailed facility planning had been authorized, and the
actual site had not been selected. The August 1988 estimate included
$8.400,000 in new transmission pipelines, in addition to approximately
$310,000 for re-routing existing pipelines along Buffalo Avenue.
In accordance with your request, we have attached a worksheet which
documents the reduction in transmission pipeline costs associated with
siting a new treatment plant adjacent to the existing facilities instead
of at Porter Road. Essentially, the amended conceptual estimate of
$830,000 (which was provided to the City in December 1988) assumed that
only about 2000 linear feet of 48-inch diameter pipeline would be required
for the adjacent location, instead of the four miles of pipe needed to
service the Porter Road site. As before, the transmission pipeline costs
do not include re-routing the existing Buffalo Avenue pipelines.
Please note that all of the above costs remain in August 1988 dollars, as
requested, and include a "nominal" 25 percent surcharge for hazardous
construction activities. Please feel free to contact us if you have any
questions about this estimate.
Very truly yours,
MALCOLM P4RNIE, INC.
David B. Schendel, P.E.
Senior Project Engineer
enc.
. c: E. Markus, Ernst Young
P. Herthman, Malcolm Pirnie
. File: 0337-24-1, CE-1
0337-24-1
S. 3515 ABBOTT ROAD P.O. BOX 1938 BUFFALO, NY 14219 71&S28-1300 FAX71&828O431
-------
Demolition of the Existing Plant-
Mid -1988 Bid Estimate:
Mid -1994 Bid Estimate-
Water Storage Facilities:
Mid -1988 Bid Estimate:
Mid - 1994 Bid Estimate:
Relocation of Offices:
Mid -1988 Bid Estimate:
Mid -1994 Bid Estimate:
Transmission Mains (Buffalo Ave.):
Mid • 1988 Bid Estimate:
Mid -1994 Bid Estimate:
Total Construction Costs:
$1,800,000
$2.412.000
$3,800,000
$5.092.000
$900,000
$1.206.000
$310,000
$415JQQQ
$6,000,000
52,009,000
2,412,000
5,092,000
1^06,000
415.000
$67,134,000
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CITY OF NIAGARA FALLS
WATER TREATMENT FACILITIES
CONSTRUCTION COST UPDATE - 4/16/90
Raw Water Intake:
Mid - 1988 Bid Estimate by Malcolm Pirnie, Inc.: $16£00,000
Treatment/Pumping:
Mid • 1988 Bid Estimate by MPL $30,500,000
New Transmission Lines - Buffalo Ave. Plant Site:
Mid -1988 Bid Estimate by MPL $830,000
Total Costs for the Intake, Treatment/Pumping and Transmission Lines in
Mid -1988: $48,230,000
Using a 5% annual inflation factor for construction costs:
Mid -1988 Bid Estimate: $48,230,000
Mid -1989 Bid Estimate: $50,642jOOO
Mid -1990 Bid Estimate: $53,174000
1990-1 Design & Related Expenses: $6.000.000
Remaining Mid -1990 Bid Estimate: $47,174,000
Mid -1991 Bid Estimate: $49,532,000
Mid -1992 Bid Estimate: $52.009.000
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Ernst & Young
":" Seventh Avenue
Kr.v York. New Yofk 10019
, ., ,„ ..„«« Tesonone: (212) 830-6000
Apnl 17,1990
Mr. John R. Westendorf
Director of Water Facilities
City of Niagara Falls Water Treatment Plant
Buffalo Avenue & 53rd Street
Niagara Falls, New York 14302
Dear Mr. Westendorf:
This letter is to confirm our recent telephone conversation relative to the updating
of previous project cost estimates for the proposed new water treatment plant.
The October 1988 report of Arthur Young & Company and Hazen & Sawyer, Inc.
evaluated alternative water supply options for the City using preliminary
construction cost estimates prepared by Malcolm Pirnie, Inc. Given the most
recent City schedule for implementing the new plant and the time which has
elapsed since the date of our report, you requested that the October 1988 cost
estimates be updated.
The enclosed calculations have been prepared to update the previous construction
costs to the expected project timetable of the City. As we understand, the design
phase will occur from 1990 - 91, with construction to begin in mid-1992. The
updated costs reflect the original estimates of Malcolm Pirnie, Inc. for each item
of the proposed work, adjusted for an assumed 5% annual increase in
construction costs due to inflation. In addition, the site for the new water plant
used in our October 1988 report was on Porter Road, requiring substantial new
transmission piping. The current proposed location for the new water plant is
adjacent to the current plant along Buffalo Avenue, resulting in a significant
savings in transmission main cost.
We are pleased to have the opportunity to assist the City in its efforts to implement
the new water treatment facilities. Should you have any questions or comments,
please do not hesitate to contact the undersigned at (212>773-6365.
Very truly yours,
ERNST & YOUNG
•^
By
Edward J jMarkus
-------
- 2 -
costs associated with any real property acquired by the City to
proceed with the new CWTP project and ancillary facilities.
Investigation and remedial costs for any City wastes identified
on the site acquired by the City shall not be included in
project costs. Any design modifications to the new CWTP
required by any state or federal agency shall be included in
the project cost. Any EQBA reimbursement received by the City
for investigation or remediation of wastes other than
identified City wastes, if any, on this property shall be
subtracted from the project cost to offset cost overruns.
6850o:KSW:07/19/90
13493-6:D.C.
-------
ATTACHK^HT D
Project Cost
New City Water Treatment Plant
June 1990
The project cost for the new City Water Treatment
Plant (CWTP) has been estimated based on preliminary
engineering and water supply options studies performed for the
City by Malcolm Pirnie Engineers/ Inc./ and by Ernst & Young.
The attached letters dated April 17, 1990 (Ernst & Young) and
April 19, 1990 (Malcolm Pirnie) predict that the new CWTP,
assuming a mid-1992 construction start/ will cost $67,134/000,
which includes a 25% allowance for engineering, legal and
administrative costs and a 10% contingency. Included in these
costs are provisions for relocating the Meter Shop and Outside
Maintenance Division facilities and offices. In addition to
the above construction costs, the cost of site acquisition and
associated investigations and remedial actions (if any) must be
added to the project costs. Current estimates are as follows:
Site acquisition, investigations
and remedial costs $ 700,000
Construction costs from 04/17/90
Ernst & Young letter 67.100.000
Project Cost $67/800,000
Investigation and remedial costs included in project
costs shall be limited to those investigation and remedial
6850o:KSW:07/19/90
13493-6:0.C.
-------
ATTACHMENT D
Hew CWTP Project Cost Estimate
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A swale for controlling surface water runoff will be
constructed to run parallel to the west side of the access road and will
discharge into the existing 60-inch flood relief sewer south of the tile
collection system located to the south of the pump station. On the east side of
the parking lot, a swale will be located over the existing 24-inch wash water
sewer and wifl discharge to the 24-inch wash water sewer south of tile tile
collection system.
16
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DRINKING
WATER TREATMENT
T. CATOM MM TO K UU««TCJ
24k
or PUJG.
CA1W IA9N TO BE UMO.ITIU TO
iTM«i«ir *ok nooo
GROUND ELCVA1HN 1 UMTT OF CAP TO UM> W TO
ACEWAH* MMOrr
4. ncroiMCA me HAU.
POOR
ORIGINAL
figure 5
PROPOSED CAPPING AND GRADING PLAN
DOT? CLOSURE REMEDIAL PLAN
Occidental Chemical Corporation
-------
3.6 FINAL GRADING AND CAPPING PLAN
Prior to final grading it is estimated that additional
materials will be required to bring the demolition areas up to grade. The
storage capacity for demolition debris within the existing reservoirs and
sedimentation basins is approximately 47,000 cubic yards. This has been
calculated from the elevation of the existing ground surface to the basement
elevation of the respective structures. The volume of debris created by
demolition activities is approximately 37,000 cubic yards. A shortfall of
10X300 cubic yards occurs, necessitating additional fill materials to bring the
demolition areas up to final grade prior to capping. Subject to EPA/State
approval delisted OCC Solid Waste Incinerator ash approved for use pursuant
to the Waste Management Plan, Appendix IV will be used as fill or, if
unavailable, another suitable dean fill will be imported.
It is proposed that the final grading plan for the DWTP
property will consist of an asphalt parking lot surrounded by grass covered
areas. Figure 5 presents the proposed capping and grading plan.
Access to the parking lot will be from Buffalo Avenue.
The access road and the parking lot will consist of a light traffic asphalt cap.
The remainder of the site will be sealed with a clay cap
and covered with grass. The clay cap will extend from the edge of the Barrier
Wall to approximately 10 feet east of Filtration Plant A and from Buffalo
Avenue to the existing fenceline on the southern property boundary.
15
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collected. If the second collection of NAPL does not provide a substantial
amount of NAPL, OCC will secure the entire intake tunnel and the
shoreshaft as shown on Figure 4. If the second collection produces a
substantial amount of NAPL, the tunnel will be secured south of a location to
be determined by OCC and the governmental parties based on all the
available data. OCC will submit a plan for monitoring and/or NAPL removal
for the portion of the runnel left open.
Securement of the 48-inch intake Line will be performed
in accordance with Table 2. Both inlet crib structures will be removed.
14
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600 —
580 —
560 —
540 ~
520 —
500 —
CRA
INSTALL CONCRETE PLUG
CEMENT-BENTONITE GROUT
.^INSTALL
if ce
HIGH WATER
INSTALL CONCRETE PLUG
CAPPED EAST CHANNEL
INTAKE SHAFT
EMERALD
CHANNEL
SHAFT
1953 TUNNEL
1937 TUNNEL
CONCRETE
PLUG
I
52+00
figure 4
SECUREMENT OF INTAKE STRUCTURE
DWTP CLOSURE REMEDIAL PLAN
Occidental Chemical Corporation
1769-29/1f/89-76-0
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3.5 SECUREMENT OF RAW WATER INTAKE STRUCTURES
The existing raw water intake structures requiring
securement are:
• Shoreshaft, East Branch Intake Tunnel and Shaft Intake, Emerald Channel
Intake Tunnel and Shaft Intake;
• East Channel Intake Line (48"0) and Intake Crib.
Securement of the Intake Tunnel network, including the
shaft intakes and shoreshaft will be performed by grouting the entire system
with cement/bentonite grout. To the extent that the tunnel underdrain is
connected to the runnel it will also be grouted. Figure 4 presents the tunnel
closure concept
Within 90 days after the start of construction of the new
DWTP pursuant to Plan A, 1,000 feet of the northern portion of the Intake
Tunnel commencing at the shoreshaft will be inspected with a video camera
equipped with a TV monitor on the surface. Copies of the video tapes
produced will be provided to the governmental parties. If collectable
quantities of NAPL are present in the Tunnel, the NAPL will be removed. If
substantial quantities of NAPL are not collected, OCC will secure the entire
intake runnel and the shoreshaft as shown on Figure 4. If substantial
quantities of NAPL are collected, OCC shall schedule a followup inspection
for 90 days prior to the start of grouting operations of the runnel. If the
followup inspection finds collectable quantities of NAPL, that NAPL will be
13
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TABLE 2
SUMMARY OF AFFECTED UTILITIES
Utility
6" 0 Sanitary
42V36" high service
discharge
24" 0 Sanitary
gas
Abandoned Electrical
Service
12" Forcemain
30" Wastewater line
to sludge facility
48" Raw Water Line
60" Wastewater Line
24" Washwater Sewer
Preliminary Activity
abandoned
abandoned
abandoned
closed
has been abandoned
abandoned
abandoned
abandoned
severed
severed
Plug Detail
plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement
plug River Side per S-Area
Settlement Agreement
plug River Side per S-Area
Settlement Agreement
plug River Side per S-Area
Settlement Agreement
-------
3.4 UTILITY ABANDONMENT. REROUTING AND REPLACEMENT
Table 2 presents a listing of all known utilities affected by
the closure of the DWTP. Except for those utilities with the bedding tied into
the tile system (see Section 33), both ends and bedding of the severed utility
will be plugged.
12
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No groundwater flow, as monitored by the gradient
monitoring, from within the existing AFL Plume within the boundaries of
the western portion of the DWTP will be allowed to flow east onto property
owned by the Qty.
Hie DWTP overburden tile collection system (i.e. wet well
and manholes) will be inspected weekly to confirm system operation.
II
-------
It is to be noted that the operation of the proposed DWTP
overburden tile collection system may impact the achievement of an inward
gradient across the south-eastern leg of the S-Area Barrier Wall. Preliminary
zone of influence estimates indicate an inward gradient to contain API and
NAPL within the S-Area Barrier Wall will be achieved. This is due to the fact
that the S-Area Collection System will be operated to maintain the lowest
achievable water level within the S-Area Barrier Wall. Conversely, the
DWTP overburden tiie collection system will lower the water table only low
enough to create the zone of influence necessary to intercept the API plume
within the boundaries of the western portion of the DWTP as shown on
Figured
MONITORING
To evaluate the long term effectiveness and-operation of
the DWTP overburden tile collection system, hydraulic monitoring will be
performed on a regular basis. The frequency of monitoring shall be consistent
with the programs established to address the S-Area RRT Systems.
To determine that an inward gradient toward the DWTP
overburden tile collection system across the existing APL plume within the
boundaries of the western portion of the DWTP is achieved, additional
monitoring wells shall be installed to evaluate groundwater gradients. To the
extent possible, existing wells will be utilized. Efforts will be made during
closure activities to prevent existing monitoring well destruction.
10
-------
Installation of the overburden tile collection system may
encounter subsurface utilities and appurtenances. Severance of the respective
utilities encountered shall be performed when necessary to permit placement
of the perforated piping. The utilities/bedding severed will have an
appropriate section of piping removed and both ends of the pipe will be
plugged and the respective River side bedding will be plugged. The bedding
on the north side will be tied into the tile system.
Along the alignment of the overburden tile collection
system, OCC will drill a line of borings at 50-foot centers down to the clay /till
interface Data from the borings will be used to determine if any NAPL is
present along the alignment and to assist in the design and final location of
the drain tile. If NAPL is encountered, then OCC will address the NAPL
using appropriate technologies.
Details of typical utility severance and plugging are
presented within Section 3.4.
System operation shall be adjustable to permit a greater or
smaller zone of influence by variation of the liquid level within the wet well.
Hydraulic monitoring, as discussed below, will be utilized to evaluate
whether the desired zone of influence is achieved within the DWTP areas.
Groundwater collected within the wet well structure shall
be pumped via HOPE forcemain and its companion containment/leak
detection piping to the proposed S-Area APL Storage Facility.
-------
570-
565-1
560H
555-1
550-f
545-1
540-
535
CRA
FILL
AVERAGE 1989
"GROUNDWATER
WATER LEVEL
EXISTING GROUND SURFACE
/-PROPOSED MANHOL£
100
N.T.S.
1789-29/11/89-76-0
figure 3
WEST - EAST
COLLECTION SYSTEM CROSS SECTION
DWTP CLOSURE REMEDIAL PLAN
Occidental Chemical Corporation
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DRINKING
WATER TREATMENT PLANT
CONCEFTUAL FU1URE
PROPERTY BOUNDARY
FOR WESTERN PORTION
OF OWTP
FORCEUAM
TO APL
TREATMENT
PROMUSLD
OWTP 0>£RBUROEN
SYSTEM TO CROSS
THE 48*«. 60V * 24V LMES
POOR QUALITY
ORIGINAL
DWTP OVERBURDEN TILE COLLECTION SYSTEM
OWTP CLOSURE REMEDIAL PLAN
Occidental Chemical Corporation
-------
33 APL CONTAINMENT AND COLLECTION
Figure 2 presents the areas of identified APL presence in
the overburden groundwater at the DWTP as determined by the S-Area
Remedial Program survey described in the document entitled "City of
Niagara Falls Drinking Water Treatment Plant - • Assessment of Overburden
Chemical Migration to the Water Treatment Plant".
This APL will be contained and collected by a DWTP
overburden tfle collection system as shown on Figure 2 and as described
below:
i) wet well located south of the existing pump station building;
ii) perforated High Density Polyethylene Pipe (HOPE) collection tile
installation/ extending 40Q± feet east of the wet well, terminating at a
manhole;
iii) HOPE forcexnain within a HOPE containment pipe complete with leak
detection manholes; and
iv) a submersible type effluent pump (size and type to be determined) with
variable level controls installed within the wet well. The level
controls shall be adjustable to permit flexibility in the system operation.
Figure 3 presents the cross-sectional view of the West/East collection
system alignment.
8
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• water treatment chemicals, i.e. chlorine, fluoride, and associated
handling equipment;
- solvents/oils, paints, ie. materials in bulk quantities within
shops/service areas;
• laboratory components, Le. chemicals/ acids, solvents, and associated
equipment, storage areas; and
- fuel and storage tank removal and associated distribution piping.
iii) Identification, quantification, cleaning (if required) and removal of
salvageable process equipment, appurtenances, furniture, office
equipment, valuable metals, electrical generator and water tower;
iv) Identification and closure/shutoff of incoming/outgoing utilities
including:
• electrical, subsurface and overhead;
• natural gas;
• telephone; and
• watermain closure at plant boundary;
. sanitary and storm sewers; and
• wastewater drain and forcemain to sludge facility.
v) Identification of subsurface utilities /services proposed for severance
and/or plugging. Details of these are presented in Sections 3.4 and 3.5.
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TABLE 1
PROPOSED
BUILDING/STRUCTURE DEMOLITION SUMMARY
Structures/BuUdittgs Proposed for Demolition Program:
Guard House
Filtration Plant *B' and Sedimentation Basins
Sewer Department (Building D) and Underlying Reservoir
Filtered Water Reservoir and Adjacent Control Chamber
Former Carpenter Shop
Filtration Plant 'A' and Sedimentation Basins
Pump Station and Electrical Station
Shore Shaft Enclosure
Emergency Generator Station
Underground Fuel Storage Tanks
Water Tower
Structures/Buildings Remaining:
• Former Fire Hall
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32 BUILDING DEMOLITION
Table 1 presents a summary of the buildings and
structures proposed for demolition.
DEMOLITION APPROACH
Demolition of the DWTP facilities will be implemented by
the City and includes demolishing existing structures in place and utilizing
existing reservoirs and sedimentation basins as receptacles for debris. Filter
media will be disposed at the historic S-Area Landfill.
DEMOLITION CONSIDERATIONS
The following is a listing of the major components
requiring consideration when the decommissioning and demolition of a
facility of this size is performed:
i) Accurate listing of buildings /facilities to be demolished and a listing of
structures/utilities equipment to be saved.
ii) Identification, quantification and prior removal (regardless of disposal
option selected) of potentially hazardous components and associated
handling/storage systems, including but not limited to the following:
- asbestos materials, i.e. insulation;
• PCBs, i.e. transformer fluids and transformers;
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3.1 NAPL CONTAINMENT AND COLLECTION
It is intended that prior to the implementation of this
Plan at the DWTP, the S-Area RRT Program and Systems will address all
NAPL present on the western portion of the DWTP. The S-Area RRT
Program will detail the plan to address this NAPL presence. This closure
remedial plan assumes that the overburden NAPL plume will be contained
and collected by the S-Area RRT Systems, as described below:
i) Containment shall be performed by slurry wall construction through the
overburden materials keying one foot into confining layer materials.
Pending the final NAPL plume definition, the S-Area Overburden
Barrier Wall alignment may be modified to address NAPL in the
western portion of the DWTP.
ii) Collection of NAPL shall be performed by the S-Area tile collection
system which will be located within the Barrier Wall. Pending the final
NAPL plume definition, the location of this system may also be
modified to address NAPL in the western portion of the DWTP.
If NAPL is not addressed by the S-Area RRT Program, this
NAPL will be addressed using appropriate technologies.
Any underground utilities from the DWTP property that
cross the alignment of the Barrier Wall shall be addressed by the S-Area RRT
Program.
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3.0 PLAN ACTIVITIES
The major Flan activities identified are listed as follows
and discussed individually in the following sections.
• NAPL CONTAINMENT AND COLLECTION
• BUILDING DEMOLITION
• APL CONTAINMENT AND COLLECTION
• UTUJTY ABANDONMENT, REROUTING AND REPLACEMENT
• SECUREMENT OF RAW WATER INTAKE STRUCTURES
• FINAL CAPPING AND GRADING
To achieve the proposed objectives identified in
Section 2.0, the remedial closure plan concepts have been developed giving
due consideration to:
. i) hydrogeological and environmental conditions existing at the DWTP;
ii) structural conditions at the DWTP;
iii) proposed S-Area RRT Systems; and
iv) compatible construction techniques and methods.
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2.0 OBTECnVES
The objectives of this Plan are as follows:
• demolish existing structures in an environmentally acceptable manner;
• contain, collect and treat Aqueous Phase Liquids (APL) in areas not
addressed by the S-Area RRT Program;
• contain, collect and treat Non-Aqueous Phase Liquid (NAPL) in areas not
addressed by the S-Area RRT Program.
• abandon and plug existing utilities and bedding (underground watermain,
sewers, etc.);
• secure raw water intakes;
• cap the demolished structures and surrounding areas with impervious
surfaces that will minimize groundwater infiltration; and
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CONCEPTUAL
FUTURE
PROPERTY BOUNDARY FOR
WESTERN PORTION OF DWTP
/-NSLUOCC
(JlHOONCR
DRINKING
WATER TREATMENT PLANT
figure I
PLAN VIEW
DRINKING WATER .TREATMENT PLANT
DWTP CLOSURE REMEDIAL PLAN
Occidental Chemical Corporation
1769-27/11/89-76-0
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ii) CTTY OF NIAGARA FALLS DRINKING WATER TREATMENT PLANT
• Assessment of Groundwater Table Contours and Geologic Conditions
S-Area Remedial Program . June 1988
iii) CITY OF NIAGARA FALLS DRINKING WATER TREATMENT PLANT
PUMP STATION
• Hydrogeologic and Environmental Conditions
• Collection System Design Consideration June 1988
iv) CITY OF NIAGARA FALLS DRINKING WATER TREATMENT PLANT
• Assessment of Overburden Chemical Migration to the Water
Treatment Plant
S-Area Remedial Program June 1988
v) REQUISITE REMEDIAL TECHNOLOGY STUDY OF CHEMICALS IN
THE OVERBURDEN AND BEDROCK S-AREA LANDFILL
S-Area Remedial Program October 1989
Figure 1 presents the DWTP existing facilities and adjacent
S-Area Landfill. A conceptual property boundary to define the boundary of
the DWTP property after closure is indicated on Figure 1.
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LO INTRODUCTION
Occidental Chemical Corporation (OCC) has prepared the
following Plan for the remediation and closure of the western portion of the
City of Niagara Falls Drinking Water Treatment Plant (DWTP) property in
the event that operations of the Plant at this site are discontinued. OCC will
take title to the western portion of the DWTP and the City will retain title to
the eastern portion of the DWTP property and a strip immediately south of
Buffalo Avenue.
This Plan incorporates engineering and construction
practices accepted for use in containment projects and is applicable to the
materials and hydrogeologic conditions at the S-Area/DWTP.
The geologic, hydrogeologic, environmental and
structural conditions of the DWTP have been evaluated and are presented
within the following S-Area/DWTP documents:
i) INFORMATION SUMMARY REPORT
• S-Area Remedial Program - June 1988
Volume 1 Text
Volume n Drawings
Appendix 1 Overburden Stratigraphic and Instrumentation Logs
Appendix 2 Bedrock Stratigraphic and Instrumentation Logs
Appendix 3 Historical Stratigraphic and Instrumentation Logs and
Hydraulic Monitoring
Appendix 4 Well Development and Sampling Summary
Appendix 5 Soils Physical Testing Results
Appendix 6 Analytical Results
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LIST OF TART PQ
Following
Page
TABLE 1 PROPOSED BUILDING/STRUCTURE
DEMOLITION SUMMARY 6
TABLE 2 SUMMARY OF AFFECTED UTILITIES 12
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LIST OF FIGURES
Following
Page
FIGURE 1 PLAN VIEW DRINKING WATER
TREATMENT PLANT 2
FIGURE 2 DWTP OVERBURDEN TILE COLLECTION SYSTEM 8
FIGURE 3 WEST-EAST COLLECTION SYSTEM
CROSS-SECTION 8
FIGURE 4 SECUREMENT OF INTAKE STRUCTURE 13
FIGURE 5 PROPOSED CAPPING AND GRADING PLAN 15
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION I 1
2*U ^J&SJCi^ 11V fcj n-nTiKi»»T«-tt--i--T—tr-ii T—I— r ' 1?
3.0 FLAN Ai:iiViiiES.......~.~ ^.^,.^...^ ~~~..~.........—.4
3.1 NAPL CONTAINMENT AND COLLECTION 5
3.2 BUILDING DEMOLITION 6
33 APL CONTAINMENT AND COLLECTION A
3.4 UnLTTY ABANDONMENT, REROUTING
35 SECUREMENT OF RAW WATER INTAKE STRUCTURES 13
3.6 FINAL GRADING AND CAPPING PLAN 15
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ATTACHMENT C
DWTP Closure/Remedial Plan
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I
ATTACHMENT B
ACTIVITY
CWTP TUNNEL REMEDIATION
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rnwni IPT i IKIFR TF^T PI AM
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ACCESS SHAFT INSTALLATION
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CWTP SITE REMEDIATION
REPLACE 10" AND 42" HIGH SERVICE LINES-
rUMr* SIAIIUN CULLLUIIUN STaltM- • • •
FILTRATION/RESERVOIR COLLECTION SYSTEM-
Wlr rtnlMt ItK CArrlNw
C*WIP LLLANINU AC IIV1 IILb
START DISTRIBUTION WATER MONITORING* •
DURATION(MONTHS)
2
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4
^••i
6
••
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8
•••
10
^
12
14
••
16
M
^m
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20
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22
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•
24
26
28
30
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32
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34
M
—
36
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mmm
40
42
44
46
48
50
52
54
56
58
60
* USING S-AREA TILE TEST PROTOCOL. IF APPROPRIATE
** SCHEDULE ASSUMES THE 1953 TUNNEL WILL NOT REQUIRE SLEEVING
PLAN B BAR SEQUENCING SCHEDULE
^. Occidental Chemical Corporation
CRA r
1769-1B/07/90-L-1 (S-04)
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ATTACHMENT B
Plan B Bar Sequencing Schedule
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INSURANCE CERTIFICATE FORM
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