Remediation of Contaminated
Sediment at the Unnamed Tributary
          to the Ottawa River
           Summary Report
              January 2000
                 Prepared for:
United States Environmental Protection Agency - Great Lakes National Program Office
            Ohio Environmental Protection Agency
                  City of Toledo


                 Prepared by:
              Blasland, Bouck& Lee, Inc.
                 6723 Towpath Rd.
              Syracuse, New York 13214

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Disclaimer
This  document was  produced by Blasland, Bouck  & Lee, Inc. (BBL).  Any reference to  a trademark name or
organization does not represent an endorsement by the United States Environmental Protection Agency (USEPA),
the Ohio Environmental Protection Agency (OEPA), or the City of Toledo.

Additional information on this project is available from Marc Tuchman, Sediment Assessment  and Remediation
Team Leader, Great  Lakes National Program Office, at (312) 353-1369 (e-mail:  tuchman.marc@epamail.epa.gov).

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Executive Summary
This document summarizes the successful sediment investigation and remediation recently
completed at the Unnamed Tributary to the Ottawa River located in Toledo, Ohio. As a result
of several factors, including a cooperative partnership between government representatives and
private industry, this site was successfully remediated in record time, culminating in the removal
of more than 56,000 pounds of PCBs.
      Investigating
            the Site
      Selecting the
      Site Remedy
In December 1988, the Ohio Environmental Protection Agency (OEPA)  initiated
sediment sampling in the Ottawa River and an Unnamed Tributary in Toledo, Ohio.
This  initial round was followed up  by two  additional OEPA-led sampling events.
During the  investigations, polychlorinated biphenyls (PCBs) were  reported  in a
number of sediment samples, ranging in concentration from 56 to 2,500 parts per
million (ppm). The highest PCB  concentration was reported in a sample collected
from the Unnamed Tributary nearest a 96-inch storm sewer outfall that served as
drainage for a number of nearby industrial facilities.

Although several potential sources were identified, the OEPA approached GenCorp,
a former owner of one of the local  industrial facilities — about remediation of the
Unnamed  Tributary.  At the same time, a grant  to remediate the site became
available from the  United States  Environmental Protection Agency's Great Lakes
National Program Office (USEPA's GLNPO).  GenCorp subsequently entered into
a partnership with  the OEPA, USEPA's GLNPO, City of Toledo, and during the
selection of a remedial alternative, the United States Fish and Wildlife Service.

After conducting two additional site assessments to further delineate the vertical and
horizontal extent of PCBs, a Remedial Options Evaluation (ROE) Report (BBL,  June
1997) was prepared, which  identified the following potential technology types to
address PCBs at the site: No Action, Institutional Controls, In-Situ  Technologies,
and Ex-Situ Technologies. Specific remedial options were assembled from each of
these technology types and evaluated on the basis of the screening criteria presented
by  the  USEPA's  Guidance for Conducting  Remedial Investigations  and
Feasibility Studies Under CERCLA (USEPA, October 1988).

Based on  a detailed and comparative analysis of the various alternatives, the ROE
Report recommended implementation of the PCB mass removal  option, which
included:
                Removal of -97% of the PCB mass in the Unnamed Tributary
                sediments;
                Removal of the highest concentration of PCBs detected within
                soils of the low-lying area;
                Extension and rerouting of the existing storm sewer pipes into a
                newly-constructed storm water drainage channel;
                Hydraulic isolation of the Unnamed Tributary; and
                Placement of 5 to 15 feet of clean fill over residual sediments.

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Implementing the
      Site Remedy
Mobilization to the site began  in January 1998 with remediation  activities
continuing though the end of June 1998.  Sheetpiling and earthen berms were
used to hydraulically isolate removal areas  allowing  excavations to proceed "in-
the-dry."  A total of 8,039 cubic yards of sediment and 1,653 cubic yards of soil
were excavated and disposed off-site  according to all applicable regulations. At
the conclusion of site remediation, the area was backfilled, graded, and seeded
with a variety of wetland species; sheetpiling was left in place at the former
mouth of the Unnamed Tributary serving as a permanent hydraulic barrier. In all,
it has been estimated that more than 56,000 pounds of PCBs were removed.
        Seven key elements led to the  successful and  expeditious cleanup  of
        this site, namely:

            Well-defined scope;
            Award  of the  U.S.  Environmental  Protection  Agency  GLNPO
            grant;
            Formation  of a  partnership  between  government  and  private
            industry;
            Thorough site characterization;
            Flexibility and support afforded by the City of Toledo;
            Extensive site preparation; and
        •   Ideal site conditions.

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Introduction
This project summary serves as a source of general information regarding the investigation and successful
remediation of contaminated sediment at the Unnamed Tributary to the Ottawa River in Toledo, Ohio. At the
project onset, a partnership was formed between several government Agencies, City representatives and
private industry to determine how to investigate and remediate sediment containing polychlorinated biphenyls
(PCBs).  By establishing an atmosphere of cooperation among the partners, with common goals and shared
objectives, the site was remediated in less than two years.
                          This report  outlines  the process used  at  the Unnamed  Tributary to successfully
                          investigate  and remediate  contaminated  sediment.   Upon completion  of the site
                          remediation,  approximately 16,000 tons of soil/sediment and  1 million gallons of water
                          were treated  and disposed. The following summary includes:
 Site Description
          & History
                                  Brief synopsis of the site description and history;
                                  Characterization of site contaminants;
                                  Description of remediation alternatives considered
                                  (including the selected remedy), together with a
                                  discussion of the remedial action and current status of
                                  the site; and
                                  Review of the factors that contributed to the success of
                                  the project.
The site of the former Unnamed Tributary is located within the City of Toledo, Ohio, and
is situated north of Interstate  Highway 75, between  LaGrange Street and  Stickney
Avenue (refer to Figure 1), approximately  6 miles upstream  of Maumee Bay.  Prior to
remediation, this tributary was hydraulically connected to the Ottawa River. The Ottawa
River flows into Maumee Bay in Lake Erie's Western Basin and is part of the Maumee
River Area of Concern (AOC).  Agricultural runoff, combined sewer overflows (CSOs),
and contaminated sediments lead the list of pollution problems that have led to the lower
Maumee River's designation as an AOC.
                                                                lew of
                                                               Unnamed
                                                                ributary
                                                               ooking north,
                                                               'efore
                                                               emediation.

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                       Historically, the Unnamed Tributary was  part of the Ottawa River's main channel.
                       Sometime prior to 1940, however, the Ottawa River was straightened and rechannelized
                       in this  area and a portion of the abandoned river channel was filled.  The remaining
                       unfilled portion of the channel, left to convey storm water to the Ottawa River, was
                       referred to as the Unnamed Tributary.

                       The Unnamed Tributary was bordered by a marshy, low-lying area to the west and high
                       soil banks on the south and east.  The mouth of the Unnamed Tributary (where it joins
                       the Ottawa River) is approximately 90-feet wide.  Proceeding upstream from the river
                       confluence, the former Unnamed Tributary tapered towards  the south for approximately
                       650 feet, and eventually turned towards the  west for approximately 325 feet before
                       ending  as a narrow (approximately 10-foot wide) channel.   Prior to remediation, three
                       storm sewers (including  96-inch,  54-inch and 30-inch pipes) and a concrete drainage
                       culvert discharged into the Unnamed Tributary in an area where the tributary turned
                       from the south to the west. Two additional sewers (24-inch and 12-inch pipes) were also
                       identified at the western end of the Unnamed Tributary.

                       In general, the former Unnamed Tributary flowed towards,  and into, the Ottawa River.
                       However, during periods of low flow when a strong wind was blowing from the east or
                       the north,  a reversal of flow, or  a seiche,  was noted.  Under these conditions, water
                       flowed upstream from Lake Erie, into the Ottawa  River and the river's tributaries
                       (including the former Unnamed Tributary).
GenCorp's involvement with this site stems from its former ownership of a 40-acre
industrial site located approximately 1,000 feet east of the Unnamed Tributary.
The industrial site included a 400,000-square-foot manufacturing plant and a three-
story office building. GenCorp manufactured plastic coated fabrics such as vinyl
upholstery used for car interiors and furniture covers. The industrial site is now
operated by another company.

From 1967 to 1972, GenCorp reportedly utilized a PCB-containing oil as an internal
heat exchange fluid in their manufacturing machinery.  GenCorp's use of this oil
reportedly ceased in 1972, when it was removed and replaced with non-PCB
containing fluids.

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Investigating the Site
In December 1988, the OEPA initiated sediment sampling within the Unnamed Tributary to determine
whether PCBs were present in sediment near the outfall of a 96-inch storm sewer pipe.  This initial
round of sampling was followed by two additional OEPA-led sampling events conducted in August and
September 1994.

In general, PCB concentrations in the sediments ranged from 56 to 2,500 parts per million (ppm), with
the highest concentration reported in a sample  collected near to the 96-inch storm sewer discharge.
According to OEPA "no actionable levels" of other constituents, except PCBs, were identified.
     Developing a
    Mechanism to
   Move Forward
   Additional Site
    Investigations
Based on the results of these initial sampling activities, the OEPA approached GenCorp
about remediation of the "very discretely bounded area	confined to sediments in a 700
by 50-foot area" (OEPA,  1996).  Although  other potential PCB sources have  been
identified in the area, GenCorp agreed to initiate studies for remediation of the site.

GenCorp subsequently entered into a partnership  with the City  of Toledo, OEPA,
USEPA/GLNPO,  and  during  the selection of  a remedial alternative, the Department of
the Interior Fish and Wildlife Service. This partnership worked cooperatively throughout
the entire investigation and remediation process, with periodic meetings held to promote
that work activities conducted and reports prepared met the interests and approval of all
parties involved.  Funding sources for the Unnamed Tributary activities included:
                              $500,000 grant from the GLNPO for remedial activities at
                              the site, following a joint request submittal by the
                              GenCorp, OEPA, and the City of Toledo;

                              $140,000 contributed for remedial activities through the
                              State of Ohio; and

                              Remainder of the funds to complete the investigation and
                              remediation supplied by GenCorp.
Assessing the Need ...

At GenCorp's request,  the parties agreed to let GenCorp  conduct a thorough, but
expedited investigation program to delineate the extent of PCBs and evaluate remedial
alternatives in the Unnamed Tributary, provided  that investigation activities did not
prolong implementation of remedial measures at the site.  As described later, timely and
successful implementation of remedial measures occurred, consistent with the remedial
design, due to the time/effort spent thoroughly  characterizing the site at the beginning of
the project.

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Conducting the Site Investigation (SI)...

In December 1996,  Blasland,  Bouck  and Lee, Inc.(BBL), on  behalf of GenCorp,
conducted an SI  of the Unnamed  Tributary.   During the  SI, sediment probing was
conducted at 101  locations along 17 transects to determine the sediment depths and to
calculate associated in-situ sediment volumes.  Two different types of sediments were
measured  and recorded: soft sediments  (i.e.,  sediments that  were penetrated with a
metal rod using little or no human force)  and stiff sediments (i.e., sediments penetrated
with a metal rod using reasonable human force). Approximately 10,500 cubic yards (cy)
of sediments were present in the Unnamed Tributary, of which approximately 8,800 cy
were considered soft sediments.

Based on visual observations and the sediment  probing results, 28 sediment cores were
collected from select locations within  the Unnamed Tributary.  The sediment cores
generally were segmented into 2-foot depth intervals  (where possible).  A total of 104
sediment samples were collected from the 28  sediment cores and analyzed for PCBs,
total organic carbon (TOC) and percent  solids. PCB concentrations  in these samples
ranged from non-detect to 74,000 parts per million (ppm) with an average of 3,500 ppm.
Approximately  one-half of the  sediment  samples  analyzed  contained total  PCBs at a
concentration of 50 ppm or less, and less than 10% of the sediment samples analyzed
contained  PCBs greater than  10,000  ppm.   In  general, PCB concentrations in  the
sediments  generally  decreased  to  less  than  5  ppm  as the  sediment core depths
progressed downwards towards  stiffer/underlying sediments.  PCB analytical results for
the sediments sampled and analyzed during the SI are presented on Figure 2.

Conducting the Supplemental  Site Investigation (SSI)...

Based on the results of the SI, GenCorp requested that additional investigative activities
be conducted in the low-lying area adjacent to the Unnamed  Tributary to assess the
potential presence and extent of PCBs  in this  area.   The SSI was conducted by BBL
during the week of February 22,  1997.

A total of 53 soil  samples were  collected from 19 locations within the low-lying area.
The samples were collected along four transect lines previously established during the
SI.   It  should be noted that not  all of the samples collected were  analyzed at  the
laboratory.  Rather the analysis of specific sample increments was performed using a
phased approach.  Initially, 16 soil samples obtained from the sampling locations closest
to the Unnamed Tributary were analyzed  for PCBs, TOC and percent solids; all other
samples were held  at  the laboratory.   Based on the results  of the  initial round  of
analyses, three additional samples  were  selected  and analyzed for PCBs, TOC and
percent  solids.  These samples were selected based on relative PCB concentrations and
trends noted during the first phase of analyses.

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In summary, PCB concentrations in the low-lying area soil ranged from 0.30 ppm to 440
ppm, with a median concentration of 13 ppm.  In general, PCB concentrations in the
low-lying area soils decreased substantially as the soil samples progressed downwards
(in depth) and away (west) from  the Unnamed Tributary.  The PCB analytical  results
for the low-lying soils sampled and analyzed are presented on Figure 2.

In addition to soil sampling and analyses, additional probing was  conducted to the north
of transect T-17 in the Unnamed  Tributary to determine the extent/volume of sediment
present between T-17  and the confluence of the Unnamed Tributary with the Ottawa
River. Based on this probing, approximately 900 cy of soft sediments (in addition to the
8,800 cy found during  the SI between transects T-l and T-17) were identified.

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Selecting the Site Remedy
Following completion of the investigative activities, a Remedial Options Evaluation (ROE) was
performed to develop and evaluate potential remedial alternatives for the site.  The 'remedial
action objectives' agreed to by the partnership to address PCB-containing sediments at the site
were:

  • Reduce the potential for PCB movement from the Unnamed Tributary; and
  • Minimize the potential for human and wildlife exposure to PCB-containing sediments in the
    Unnamed Tributary.

The potential technology types identified in the ROE Report, as well as the selected alternative,
are discussed below.
         Evaluating
          Potential
       Technology
              Types
Potential technology types were reviewed to evaluate the full range of potential remedial
options.  This review included an extensive literature search, a review of precedents set
at  similar remediated sites,  and  when appropriate, the incorporation of bench-scale
studies.  The following technology types  were retained from this initial screening to
undergo further analysis:
                                                 No Action;

                                                 Institutional Controls;

                                                 In-Situ Technologies; and

                                                 Ex-Situ Technologies.
                         These technology types were evaluated on the basis of screening criteria required by both
                         the USEPA and OEPA.   These criteria include effectiveness,  implementability, and
                         relative cost.

                         No Action ...

                         Consistent with the requirements  of the National  Contingency  Plan  (NCP), this
                         technology type was retained as a baseline against which other remedial options may be
                         compared.  It assumes that no activities would be  implemented to address the  PCB-
                         containing sediments in the Unnamed Tributary.  In general, since no remedial activities
                         would be conducted at the site, sediment transport from the Unnamed Tributary would
                         still exist and the potential for human or wildlife exposure to the PCB-containing sediment
                         would not be minimized.  As a result, this option was not expected to meet the remedial
                         action objectives for the site.

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Institutional Controls...

Institutional controls generally consist of non-intrusive efforts focused on  minimizing
potential contact with PCB-containing sediment  in  the  Unnamed Tributary.   These
controls could include site access restrictions (e.g., security fencing) and deed  restrictions.
However, because institutional controls would not treat, contain  or remove any PCB-
containing  sediments, they  alone would not  achieve  the remedial  action objective of
reducing the potential for PCB movement from the Unnamed Tributary.

In-Situ Technologies...

In-situ technology  types identified  during the  initial  evaluation as being potentially
applicable for the Unnamed Tributary included capping and in-situ treatment.  Although
capping  was retained  for further  analysis,   in-situ treatment options  such  as
solidification/stabilization  (S/S),  biodegradation  and  vitrification  were  screened  out.
Bench-scale studies indicated that, following several rounds of testing, a suitable in-situ
S/S agent  could  not be identified for the site  which would significantly reduce the
leachability of PCBs in  the Unnamed Tributary  sediment.   Furthermore, other in-situ
treatment options such as biodegradation and  vitrification also were not retained  due to
a lack of use and/or proven effectiveness for treating PCB-containing sediments in-place.

Ex-Situ Treatment...

Ex-situ treatment technology types considered during the initial screening process were
separated into three  general categories:  sediment removal,  sediment  treatment,  and
sediment  disposal.   Sediment removal  options  included  hydraulic,  pneumatic  and
mechanical removal.  Based on  the  limited water depth and  presence of debris, it  was
determined that mechanical removal struck the best balance of the three initial evaluation
criteria.  With regards to sediment treatment, several treatment technologies were initially
considered including biodegradation, chemical destruction, chemical extraction, thermal
extraction,  thermal destruction and soil washing.   Based on the large space requirements
to set up an ex-situ treatment operation, the prolonged time required for treatability testing
and permitting, and the high cost to treat such a relatively small volume of material  on-site,
the  ex-situ  treatment technologies were screened from further consideration.  In addition,
due to cost and implementability issues,  the only disposal option considered was placement
of sediments in  a chemical  waste landfill permitted to accept PCB-containing materials
greater than 50 ppm under the Toxic  Substances Control Act (TSCA).

Based on the results of the  initial technology screening, several  remedial options were
developed  and retained for a more detailed  evaluation.  To  implement any  sediment
remedial option  in  the  Unnamed  Tributary,  it was  determined  by  the partners  that
permanent rerouting of the  storm sewers and hydraulic isolation of Unnamed Tributary
would be necessary to eliminate concerns regarding transport of PCBs. The options
developed for further evaluation were therefore considered in two phases:

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  PCB Mass
    Removal
Alternative
(Option 2a)
                      1.   Phase I, Activity #1- Storm Sewer Reroute

                      2.   Phase I, Activity #2- Hydraulic Isolation of the Unnamed Tributary

                   With  the exception  of No Action, several Phase II remedial options  were proposed,
                   which, if implemented in conjunction with Phase I activities, would  accomplish the
                   remedial  action objectives for the site. These options included:

                      3.   Phase II, Option 1- No Action

                      4.   Phase  II,  Option 2a-  Dredging  with  Off-Site Landfill Disposal (PCB Mass
                          Removal)

                      5.   Phase  II,  Option  2b-  Dredging  with  Off-Site Landfill  Disposal  (Complete
                          Sediment Removal)

                      6.   Phase II, Option  3- Dredging with Off-Site Disposal (Complete Removal)  at a
                          Permitted,  Secure Landfill  Specifically Constructed for the Unnamed Tributary
                          Sediments

                      7.   Phase II, Option 4- In-Place Capping

                   Each  of these options was  further evaluated in detail against an additional set of criteria,
                   including:
                           Short-Term Effectiveness;
                           Long-Term Effectiveness and Permanence;
                           Reduction of Toxicity, Mobility, or Volume Through Treatment;
                           Implementability;
                           Compliance with state and federal regulations;
                           Overall Protection of Human Health and the Environment; and
                           Cost.
Based upon  a  detailed and comparative analysis  of the various  alternatives, the ROE
recommended that, along with both Phase I  activities (i.e., Storm Sewer Reroute and
Hydraulic Isolation), Option 2a (PCB Mass Removal) presented the best balance of the
seven aforementioned evaluation criteria.  This option is briefly described below.

Remediation of the Unnamed Tributary Site would be implemented in two phases.  As
part of Phase I, existing storm sewer pipelines that drain  into the Tributary would  be
extended and rerouted into a newly-constructed channel.  This channel would flow away
from the Unnamed Tributary (i.e., into the low-lying area), and ultimately drain directly
into the  Ottawa River. To facilitate this  pipeline extension/reroute, approximately 2,000
in-situ cy of sediment (adjacent to the 96-inch, 54-inch and 30-inch storm sewer outfalls)
containing the highest reported PCB concentrations would be removed, dewatered and
disposed in  an off-site  permitted,  secure landfill.   The area from which sediment is
removed would be backfilled with up to approximately 10 to  12 feet of material suitable

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to support the new storm sewer pipes. In addition, Phase I activities also would consist
of constructing  a  sheetpile dam at the mouth  of the Unnamed Tributary, physically
isolating it from the Ottawa River. Taken together, all Phase I activities would effectively
eliminate the Unnamed Tributary from acting as any sort of surface  water flow channel.

Phase II remedial  activities would include the  additional  removal of PCB-containing
materials from the  remainder of the Unnamed Tributary and the adjacent low-lying area,
with subsequent restoration/covering  through the placement of clean  fill.   More
specifically, this  option would target to additionally remove approximately 4,500 in-situ
cy of soft sediment.

Overall, this  operation  would target the reduction of the PCB mass present in the
sediments by approximately 97%, and theoretically would leave behind (beneath 5 to 15
feet of clean fill) residual PCB levels in sediments of approximately 25 ppm.

In addition to sediment removal, approximately 1,800 cy  of soil  (up to  a  depth  of
approximately 1 foot) would be removed from the low-lying area and managed consistent
with the excavated sediments.  This activity would remove the highest concentration of
PCBs detected within the low-lying  area.

Following completion  of the removal activities, confirmatory composite samples of both
the soil and  sediment would  be collected to  determine  whether the sediment PCB
cleanup goal  of 50 ppm had been achieved, or if additional  sediment removal was
warranted.  Following verification sampling, the  Unnamed Tributary would be backfilled
with clean fill to a final design grade, covering any residual materials with at least 5 feet
of backfill.  That portion of the  low-lying  area disturbed  as  part  of the construction
activities would be returned  to  original  grade  through  placement of clean  fill.   The
regrading of the site would be carried out such  that  all water is directed away from the
location of  the former Unnamed Tributary and towards the low-lying area.  As a  result,
the Unnamed Tributary would essentially be removed as an aquatic habitat.

The implementation of Option 2a not only hydraulically isolates the  Unnamed  Tributary
from the Ottawa River,  but it also targets the removal of approximately 97% of the PCB
mass (more than 56,000 Ibs.) from the Tributary.   This mass removal percentage is
extremely significant.  In addition to targeting the removal of this PCB mass, this  option
would also  provide  adequate protection against human/wildlife contact with any residual
PCBs through the placement of 5  to 15 feet of clean fill over the excavated areas.

Following  review and input,  the Agencies (City of Toledo, USEPA, OEPA, and the
Department of Interior Fish and  Wildlife Service) concurred with the ROE,  and asked
that GenCorp move forward with implementation of the PCB Mass  Removal Alternative
(Option 2a).

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Implementing the  Site  Remedy
After selecting and designing plans for the PCB Mass Removal Alternative (Option 2a) and receiving the
proper approvals, GenCorp moved forward with implementing the selected remedy. Cooperatively
working together, the team of agency personnel, GenCorp representatives, and technical specialists
successfully completed the remedial activities. According to William J. Burkett, the Project Manager for
the City of Toledo,  "the team effort put forth during this project has been nothing short of inspiring."
The following text provides a brief summary of the work tasks involved to implement the site remedy.
       Contracting
        Mechanism
      and Selection
GenCorp  was tasked with selecting a contracting mechanism and contractor(s) to
perform the sediment remedial activities  at the Unnamed Tributary.  To successfully
execute a remedial project of this magnitude, GenCorp recognized that ultimate control
of the day-to-day operations must be handled by an on-site representative (i.e., owner
or agent).   GenCorp decided to  contract the entire remediation  (i.e., oversight,
engineering and construction) through one firm.  This contracting mechanism eliminated
the more traditional owner-engineer-subcontractor "triangle" relationship (which exists
when the on-site representative does not hold the  contract with  the subcontractor),
which requires significantly more time/input from the owner, weakens the relationship
between the on-site representative and the subcontractor, and eliminates the ability of
the on-site representative to provide direction to the contractor.  GenCorp attributes the
success of the project, in part, to the contracting mechanism selected.

The Remediation Contract for  the  site was  awarded to BBL Environmental Services
(BBLES), while Sevenson Environmental Services, Inc (Sevenson)  was  selected as the
prime subcontractor for all construction related activities.

Storm Water Drainage Channel Construction ...

Mobilization to the site commenced  in January 1998.  In order to effectively navigate
equipment into and out of the site,  certain portions of the  site were cleared/grubbed,
temporary access roads were built, and an equipment/material  staging  area was
constructed.
                                                                                      View looking
                                                                                      Iwest of the
                                                                                      permanent storm
                                                                                      [water drainage
                                                                                      channel.
                                                                                                 10

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Initiation of the drainage channel construction activities began in January 1998.  To
mobilize excavation equipment to the area along the proposed drainage channel,  a
temporary bridge was constructed across the Unnamed Tributary just north of transect
T-8.

Once the temporary bridge was completed, the contractor prepared the site  for
excavation activities. As discussed previously, the potential for flooding at the site was
particularly high due to the seiche  events  often  experienced in the Ottawa River.
Therefore,  to minimize  the  potential  for  flooding to  impact excavation activities,
contingency measures, including the construction of temporary earthen berms, were
taken at the site to hydraulically isolate the excavation areas.

The new storm water  drainage  channel was cut using conventional earth-moving
equipment such as a bulldozer, modified backhoe, and off-road all-wheel drive hauling
vehicles. Based on previous  soil sampling conducted in 1997, soils excavated along the
proposed drainage  channel were either designated as  "clean"  and  staged on  site with
other backfill materials, or disposed off-site as regulated materials.

Storm Sewer Reroute/Sediment Removal Activities...

Prior to  extending the storm
sewer pipes  to the  newly
constructed   drainage
channel, storm water was
temporarily   diverted  and
sediment   was   removed
from  portions    of  the
Unnamed Tributary  where
the piping was to be placed.
Sediment  removal  was
accomplished in a step-wise
approach   by    first
       .      .               Typical sediment removal  operations from  the  Unnamed
hydraulically  isolating  and   Tributary  Swamphoe  (seen  in  sediment  bed)  excavates
dewatering   specific   sediment and transfers it to the edge of the bank. Trackhoe
sediment   areas    between   removes the  transferred sediment and loads it directly into
transects T-l and T-8  and   off-road hauler  to  be transported to the stabilization pond.
then excavating sediment using modified backhoes capable of maneuvering within the
sediment bed of the Unnamed Tributary. Once the pre-defined removal depths were
achieved, post-confirmation PCB sampling and (where determined necessary) additional
excavation were performed prior to backfilling.

Water infiltration to the excavation areas  was  easily  controlled and  the sediment
effectively dewatered in place, allowing sediment removal to occur essentially "in-the-
dry." Due to the  absence of standing water, and the dense cohesive nature of the
sediment and underlying clay, distinct layers of sediment were effectively removed with
little/no  recontamination of cleaner underlying material during removal.
                                                                              11

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Following implementation, the estimated sediment removal  volume totaled 642  cy
between transects T-l and T-5, and 3,295 cy between transects T-5 and T-8.  Upon
completion, the final post-removal PCB sediment concentrations in the excavation and
between transects T-l and T-8 were reduced from concentrations ranging up  to 74,000
ppm (pre-removal) to 4.6 ppm.

Sediment removal activities between transect T-8  and the permanent steel sheetpile
dam installed at the mouth of the Unnamed Tributary were conducted in a  step-wise
approach, similar  to removal of sediments  between transects T-l and T-8.  Overall,
approximately  4,102 cy  were removed from  transect  T-8  to the permanent  steel
sheeting dam installed at the mouth of the Unnamed Tributary.   Final post-removal PCB
sediment concentrations in these excavation areas ranged from non-detect to  38 ppm,
with an overall post-removal arithmetic average (entire Unnamed Tributary) reduced
from approximately 3,500 ppm (pre-removal) to approximately 8 ppm.

Soil Removal Activities...

Soil was  removed from the low-lying area using conventional earth moving equipment
such  as  bulldozers  and  loaders.   The  low-lying area was  dry and no water
collection/control measures were necessary.  Based on sampling conducted during site
characterization, an estimated 1,800 cy of soil was proposed for removal.

Following implementation, the actual soil removal volume estimate totaled 1,653 cy for
the low-lying area. Final post-removal PCB soil concentrations ranged from non-detect
to 0.37 ppm.

Material Disposition ...

In total, nearly 16,000 tons of material were properly characterized and disposed of off
site in either a  TSCA or Non-TSCA landfill.  All soil and sediment removed from the
Unnamed Tributary and the low-lying area was taken to the staging area for treatment
prior to disposal.   Initially, these materials were placed in  a covered pile and allowed to
gravity drain into a sump that was subsequently pumped through the on-site waste water
treatment plant. Drained material was fed into a hopper and then directly into  a pugmill.
In the pugmill, the soil/sediment was mixed with sufficient pozzament to stabilize the
material prior to off-site transport/disposal.

On-Site Wastewater Treatment...

Wastewater generated during the sediment remediation process was  collected, treated
on site, and discharged to the city's sanitary  sewer system.  A permit establishing
discharge limitations and monitoring requirements was obtained from the City of Toledo.
The  temporary wastewater treatment plant accepted wastewaters from three major
sources throughout the duration of this project:
                                                                            12

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Water generated during excavation/remediation activities in the
Unnamed Tributary and drainage swale;
Water captured in a sump at the staging area where materials were
stockpiled prior to stabilization; and
Decontamination water used for cleaning personnel and equipment
prior to leaving the site.
          As wastewater was generated, it was  initially pumped to an oil/water separator.  A
          coagulant was added to the wastewater  to promote oil separation and encourage settling
          of the suspended solids. Oil was skimmed off the top of the separator and the effluent
          overflowed into a pair of 50,000 gallon Influent Modutanks. Water was conveyed from
          the Modutanks, to a set of static mixers where a coagulant and polymer were added.
          These chemical additions facilitated further separation and removal of suspended solids.
          The solids were removed  from the system via an Inclined Plate Clarifier (IPC).  Water
          exiting the clarifier was passed through  a series of bag, sand and activated media filters,
          to remove remaining  particulates, oils  and dissolved phase organic  constituents,
          respectively.  Finally, treated water was routed to  an effluent tank, sampled, and
          discharged to the city sanitary sewer system.

          In all, approximately one million gallons of water were treated, and nearly 20 tons of
          sludge were generated by the temporary wastewater treatment plant. At the conclusion
          of water treatment activities, the sludge, bag filters, and other filter media (e.g.,  sand,
          activated media) were disposed of as TSCA-regulated wastes.

          Site  Restoration ...

          The low-lying  area and the  east bank adjacent  to the Unnamed Tributary  are both
          owned by the City of Toledo. With the City's permission, soil (borrow material) from
          the east bank and portions of storm water drainage channel were sampled for use as
          backfill during  site restoration. Results indicated that these materials contained less than
          1 ppm PCBs, with the majority of samples reported as "non-detect."
                                                                                      13

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  Remedy
Summary
                                                                                    Regrading of the
                                                                                    disturbed portion
                                                                                    of the low-lying
                                                                                    area following
                                                                                    remediation.
                                                                                    View is looking
                                                                                    north towards
                                                                                    the permanent
                                                                                    sheetpile dam
                                                                                    and the Ottawa
                                                                                    River.
Backfill materials were placed and compacted to regrade the site so rain water would
drain away from the area of the former Unnamed Tributary, and (in conjunction with
the permanent steel sheeting) hydraulically isolate the  site  from the Ottawa River.
Finally  topsoil was placed over the subbase, and the area  was hydro-seeded with  a
variety of grasses and wetland species to encourage revegetation of the area. The final
conditions of the site following restoration are shown on Figure 3.

The  site  investigation  assessment  and  remedial  activities have been  successfully
completed at the Unnamed Tributary Site. In fact, according to the  Project Manager for
the City of Toledo William J. Burkett, "The team effort put forth during this project has
been nothing short of inspiring."  The following is a summary of the mass/volume of
material removed from the site.
Estimated Volume of Sediment Removed:
Estimated Volume of Soil Removed:
Total Material Removed:
Mass of Sediment/Soil Disposed:
Estimated Mass of PCBs Removed:
Arithmetic Average PCB
Concentration
Pre-Removal
Post-Removal
8,038 cy
1,653 cy
9,691 cy
15,856 tons
56,782 Ibs
3,500 ppm
8 ppm
                                                                                                14

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Keys to  Success
As discussed in more detail below, seven key elements led to the successful and expeditious
cleanup of this site, namely:
  • Well-defined scope;
  • Award of the USEPA GLNPO grant;
  • Formation of a partnership between government and private industry;
  • Thorough site characterization;
  • Flexibility and support afforded by the City of Toledo;
  • Extensive site preparation; and
  • Ideal site conditions.
     Well-Defined
              Scope
     Award of the
   GLNPO Grant
     Formation of
  the Partnership
One  incentive  for  GenCorp  to  participate was  the  clearly  defined scope  of their
involvement, which was limited  to  remediation of the  "very  discretely  bounded
area...confined  to sediments in a 700 by 50-foot area". In the course of delineating the
extent of PCBs in the Unnamed Tributary sediments, GenCorp identified and voluntarily
addressed both sediment and soil within the bounds of the "site", as originally defined.
Due  primarily  to the relatively small  volume and the high PCB concentrations  of
materials, agreements were reached early on that this would be a removal project.

The  award  of  a GLNPO grant  to cover the "orphan's share" to partially fund the
cleanup work was instrumental in creating an atmosphere of cooperation and common,
shared objectives which  lasted throughout the duration  of the project.  Although it
represented a relatively small fraction  of the total project cost, the grant award served
as a catalyst to bring all of the affected parties together in a non-confrontational
environment, and encouraged  an open discussion of  all available  alternatives.   This
approach resulted in the site being characterized and remediated in less than 2 years.

At project onset,  a partnership  was  established  between the  Agencies, the City  of
Toledo, and GenCorp. Meetings were held every few months to identify the interests of
each party,  discuss technical issues related to sediment investigation/remediation, and
develop a strategic plan for moving forward.  At the meetings, each organization was
represented  by senior staff members  with a vast array of relevant knowledge and
experience. With senior staff present, decisions that were fundamental to progress of the
project could be made at the meetings, rather than deferred (e.g., recognition of the
factors inherent with dredging and achieving aggressive cleanup criteria, when selecting
a PCB cleanup  goal, such as sediment mixing, resuspension, and redeposition).  This was
a key component to the project's  success.

The sharing of information and timely review of submittals kept the project on track with
an aggressive schedule, and  resulted in a remedy that was acceptable  to  all parties.
According to David A  Ulrich, acting USEPA Region V Administrator, "This was  a
remarkably quick cleanup that shows what can be accomplished when there is a spirit
of cooperation."
                                                                                                      15

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    Thorough Site
 Characterization
   Upon review of available site data, the parties  agreed to let  GenCorp  conduct  an
   expedited investigation program to further characterize site conditions.  The focused site
   characterization program was developed and implemented to:
                  Characterize the distribution of PCBs in the Unnamed Tributary
                  sediment;
                  Evaluate the potential for PCB movement from the Unnamed
                  Tributary; and
                  Assist in development and evaluation of remedial measures to
                  address PCBs in the Unnamed Tributary sediment.
    Flexibility &
         Support
Afforded by the
 City of Toledo

  Extensive Site
    Preparation
The site characterization was effective in achieving these objectives.  The distribution of
PCBs in the Unnamed Tributary sediments and soil were thoroughly delineated through an
iterative process  of sediment probing  and  sampling.  The sediment and soil remedial
boundaries were established, based on the results of the site characterization data. Timely
and successful implementation of remedial measures occurred  (with no surprises  during
construction), consistent with the remedial design, due to the time/effort spent thoroughly
characterizing the site at the beginning of the project. Full funding of the comprehensive site
assessment by  GenCorp, on a voluntary basis, was  essential to timely  development  and
implementation of the remedy and the necessary initial team-building effort.


Flexibility and support provided by the City of Toledo was a key factor in  the success of the
project.  The City of Toledo helped to facilitate the remediation process by granting property
access to remediation areas, allowing the use of on-site borrow materials, and allowing
reconfiguration of the property and the institution of deed restrictions.
Before conducting sediment removal activities in the Unnamed Tributary, the following
site  preparation  activities   were  implemented  to  minimize  the  potential  for
disturbance/release of sediment containing PCBs during removal:
                Construction of large earthen berms, placed around sediment
                excavation areas to allow site dewatering and prevent flooding due to
                high river/seiche events;
                Construction of a pile-driven temporary bridge across the Unnamed
                Tributary;
                Construction of a new storm water drainage swale to re-direct flow
                from the storm sewer pipes to the Ottawa River;
                Temporary rerouting of the 94-inch, 54-inch, 30-inch and 12-inch
                storm sewer pipes (these activities were staged in phases, with
                sediment excavation activities); and
                Construction of a sediment/equipment staging area and set up of a
                pugmill and waste water  treatment plant.
                                                                                                   16

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  Ideal  Site
Conditions
Conclusion
In total, eight weeks were spent preparing the site for sediment excavation. The time and
effort spent preparing the site was key to the smooth and uneventful removal of sediments
from the Unnamed Tributary.

Site conditions  encountered  during the sediment removal activities allowed the contractor
to achieve low residual PCB concentrations without the need to significantly over excavate
(in an attempt to achieve low residual PCB concentrations).  Due to the absence of standing
water and the dense cohesive nature of the sediments,  a  distinct layer of sediment was
easily removed, with little/no recontamination of cleaner underlying material during removal.
In addition, water infiltration to the excavation areas was  easily controlled and the sediment
effectively dewatered  in place, allowing sediment removal to occur essentially "in-the-dry."

Overall, it was the site-specific culmination of these seven factors which resulted in a rapid
and well-strategized clean up. Due to the  dedication and  commitment by GenCorp, OEPA,
USEPA, the City of Toledo and the United States Fish  and  Wildlife Service  personnel to
expedite this project, all activities (investigation through remediation) were completed at the
site in less than two years. The total cost for the project was approximately $5 million.  This
cost included conductance of the site investigation and remedial option evaluation activities,
site remediation  and restoration, and treatment/disposal of approximately  16,000 tons of
soil/sediment and 1 million gallons of water.
                    For More Information .. .
                                                                                      Low-lying area
                                                                                      looking north
                                                                                      toward the
                                                                                      Ottawa River
                                                                                      several weeks
                                                                                      after completing
                                                                                      remedial
                                                                                      activities.
                   Additional information on this project is available from Marc Tuchman,  Sediment Team
                   Leader,   Great  Lakes   National  Program   Office,  at  (312)   353-1369  (e-mail:
                   tuchman.marc@epamail.epa.gov).
                                                                                                      17

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                                                                                                       :|s.-.  ••••
REFERENCE: BASE MAP SOURCE USGS 7.5 MINUTE QUADS. SERIES TOLEDO, OHIO-MICHIGAN, OREGON, OHIO-MICHIGAN, 1965, PHOTOREVISED 1980.
                                                                                            3000'
                                                                                                                    3000'
                                                                                                Approximate Scale: 1" = 3000'
                                                                                                                                               AREA LOCATION
                                                                                                                                               UNNAMED TRIBUTARY
                                                                                                                                                  TOLEDO, OHIO
                                                                                                                                    TRIBUTARY TO THE OTTAWA RIVER SEDIMENT
                                                                                                                                     REMEDIATION PROJECT / SUMMARY REPORT
                                                                                                                                              SITE  LOCATION
                                                                                                                                                                      FIGURE
                                                                                                                                                                        1

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» patuwa
-4 P.09
-5.5 B.064
5-e to


TIT-4
JwWft)
M>.5
1-2
!-4
1-6

7.8-8.5
*C8(ppm:
MO
480
MOO
L78JD

138
SES&MU.
                                                                                                                                                                                                                                 T-tl
EDGE OF WOODS
EDGE OF WATER
TRANSECT
SEDIMENT SAMPLE/PROBE LOCATION
(DEC. 1996)
GEOCHRONOLOGIC SEDIMENT CORE
LOCATION (APPROXIMATE)
SEDIMENT PROBE LOCATION  (DEC. 1996)
SOIL SAMPLE LOCATION (1997)
CHAIN LMK FENCE
PROPOSED DRAMAGE CHANNEL
      '/SOL CORE ID
                                                                                                                                                                                                                                 ND       NON-DETECT
                                                                                                                                                                                                                                 N        TENTATIVELY IDENTIFED COMPOUND
                                                                                                                                                                                                                                 J        ESTMATED VALUE
                                                                                                                                                                                                                                 D        DILUTED SAMPLE
                                                                                                                                                                                                                                 PCB       POLYCHLORMATED BIPHENYLS
                                                                                                                                                                                                                                          (TOTAL)
                                                                                                                                                                                                                                 ppm       PARTS PER MLUON
                                                                                                                                                                                                                                 dup       DUPLICATE SAMPLE RESULT

                                                                                                                                                                                                                                          0-2' SOFT SEDIMENT DEPTH
                                                                                                                                                                                                                                          2'-4' SOFT SEDMENT DEPTH
                                                                                                                                                                                                                                          4'-6' SOFT SEDMENT DEPTH
                                                                                                                                                                                                                                               SOFT SEDMENT DEPTH
                                                                                                                                                                                                                                          B'-9' SOFT SEDMENT DEPTH
                                                                                                                                                                                                                             NOTES:
                                                                                                                                                                                                                            1. ELEVATIONS BASED ON NAVD 198&
                                                                                                                                                                                                                            2. FELD SURVEY COMPLETED BY BBL ON NOV. 11. 1996.
                                                                                                                                                                                                                            1 SEDMENT SAMPLE LOCATIONS T7-A, T7-B. T11-A,
                                                                                                                                                                                                                             TI3-A, T16-A, AND TI7-9 WERE NOT PROBED PRIOR
                                                                                                                                                                                                                             TO SAMPUNa
                                                                                                                                                                                                                            *. DATA PRESENTED ON THIS FIGURE HAVE BEEN VAUDATED.
                                                                                                                                                                                                                            & ALTHOUGH NOT PRESENTED. SEDIMENT DEPTHS BETWEEN
                                                                                                                                                                                                                             TRANSECT 117 AND  THE PROPOSED EARTHEN BERM DAM
                                                                                                                                                                                                                             ARE ASSUMED TO AVERAGE 3.5 FEET.
                                                                                                                                                                                                                                      UNNAMED TRIBUTARY
                                                                                                                                                                                                                                         TOLfDO.  OHIO
                                                                                                                                                                                                                       TRBUTARY TO THE  OTTAWA MVER  SEDMENT
                                                                                                                                                                                                                                 PRE-REMEDIATION
                                                                                                                                                                                                                         SOIL/SEDIMENT  PCB  DATA
                                                                                                                                                                                                                                                                     FMURE

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96"» STORM
SEWER OUTFALL-
STORMWATER
DRAMAGE CHANNEL
DRAMAGE CHANNEL
MAMTENANCE ROAD
                                                                      PERMANENT SHEETPILE WALL
                                                                      FINAL ELEVATION - 574' MSL
                                                                                                   Illlll Ijll'il  I  /      If
                                                                                                    i //Ill/i//!/!//      /
                                                                                                '/llliill/ll/l//l>        11
                                                                                                 / ! f /  !  ! t ' i ! ////////        I  I
           LEGEND

           EXISTING EDGE OF WOODS

           EDGE OF WATER

           PERMANENT SHEETPILE WALL

           NEW EXTENDED STORMWATER
           DRAINAGE PIPE

           CHAIN LINK FENCE
NOTES

1. THE TOPOGRAPHICAL CONTOURS AND LOCATION OF THE NEWLY
  INSTALLED FENCING HAVE BEEN PROVDED BY SEVENSON
  ENVIRONMENTAL SERVICES. INC. M FIGURE DATED 7/16/W. (SEE
  APPENDIX D).

2. THE LOCATION OF THE "EDGE OF WOODS' HAS BEEN APPROXIMATED
  FROM AERIAL PHOTOGRAPHS OF THE SITE TAKEN B/26/Ba
                                                                                                                                                                                               TOLfDO. OHIO
                                                                                                                                                                             TRIBUTARY TO THE OTTAWA (OVER SEDIMENT
                                                                                                                                                                               REMEMATIOM PROJECT/SUMMARY REPORT
                                                                                                                                                                                 FINAL  SITE  GRADING PLAN
                                                                                                                                                                                                                          3

-------