# FINAL REMEDIAL ACTION REPORT**:~** 

# FULTON TERMINALS SITE SOILS REMEDY

Prepared by:


### MarkValentine de maximis, inc. Project Coordinator for the Fulton Terminals Site Remedial Action Trust


### SEPTEMBER24, 1996 /·INTRODUCTION This document presents the Final Remedial Action (RA) Report for the soil remedy at the FultonTerminals Superfund Site (the Site) in Fulton, New York. This final RA Report was prepared onbehalfofthe Fulton Terminals Site Remedial Action Trust and under the direction of the Site Management Committee, who represent the "Settling Defendants" as defined in the Remedial Design (RD)/RA Consent Decree (Consent Decree) for the Fulton Terminals Site, which was approved bythe U.S. District Court for the Northern District ofNewYork (the Court) on December 13, 1991. This report was prepared consistent with the requirements ofthe United States Environmental Protection Agency (USEPA)**gu~dance** entitled Remedial Action Report
.· D9>.cumentation for Operable Unit Completion (June 1!992). The final RA Reporthas beenba;;ed on the remedial action work completed at the Site by BBLEnvironmental Services,·Inc. (BBLES) pursuant to the USEPA-approved Final Design Submittal (FDS) for the soilremedy (BBLES, March 31, 1995). The FDS was prepared .consistent with the requirements ofthe:Consent Decree, which describes work performed at the Sitebased onthe**requir~l1lents** oftheUSEPA's 1989 Record ofDecision (ROD) for the Site.

SITE DESCRIPTION AND HISTORY Site Description The Site is located in an in,dustrial section ofthe City ofFulton in Oswego County, New •York- Residences;cityand c0unty offices, and**sever~l** businesses are located within a

1,500-footradius ofthe Site. The Site consists ofan approximately 2-acre former storage facility that was used for the storage ofraw materials used inthe manufacture ofasphalt roofing from the 1920s,through the 1960s: The storage facility, which formerly contained several above- and underground storage tanks, was also used in the 1970s and early 1980s for storage of solvents and othermaterials that were originally scheduled for incineration at the Pollution Abatement Services facility in Oswego, New York. The Site was listed onthe National Priorities List (NPL) in 1982. All aboveground tanks and known underground tanks, drums, and approximately 300 cubic yards ofcontaminated soil were removed during removal action activities in the mid-1980s. Initial and Supplemental Remedial Investigation/Feasibility Studies The initial Remedial Design/Feasibility Study (RI/FS) activities were conducted byNew York State Department ofEnvironmental Conservation (NYSDEC) contractors during 1985 toFulton Terminals RA Report Page 2 of9
1987. The USEPA and several potentiallyresponsible parties (PRPs) conducted the removal action addressing storage tank, drum, and visibly contaminated surface soil removal concurrently with the initial RI/FS activities. The results ofthe initial RI/FS activities were declared invalid byNYSDEC due to laboratory analysis problems. A revised RI/FS was prepared by a NYSDEC contractorbased on additional sampling performed in 1988. USEPA concluded that the revised RI/FS did not fully characterize the Site so a USEPA contractor conducted a Supplemental RI/FS. The Supplemental RI/FS was completed in 1989 and indicated that various volatile organic compounds (VOCs) were detected inunsaturated fill soil samples and in groundwater samples from the Site. In 1989, USEPA completed an Endangerment Assessment for the Site and concluded that minimal risks were associated with current site conditions based onthe Supplemental RI data. ··However, the.Supplemental RIIFS identified that the on-site soils were a potential future source ofVOCs leaching into groundwater. Record ofDecision USEPA issued the ROD in September 1989 following completion ofthe Supplemental RIIFS. The ROD, specified a remedial:action consisting ofboth soil and groundwater remedies to address VOC,s detected in the respectixre media. The soil remedyrequired excavation and low temperature**thermaldesorptidri(~TTD) ofuns~turated**  soil located above the water table (also referred to as ''fill soil"), within a localized area'ofthe site as defined by soil borings surrounding the former locatio!)ufa 1;000;000-gallon tank used for storage ofsolvents, as indicated inthe ROD. The goalofthe soil remedyintlie ROD 1was to reduce concentrations ofVOCs inthe fill soils to levels whichwould notcause an exceedance ofapplicable or relevant and appropriate requirements (ARARs) for groundwater due to percolation ofprecipitation through the

_, unsaturated soils. ·The soil cleanup'levels in the ROD, which were based onNew York State groundwater standards and site-specific criteria, were determined through application ofthe soil flushing model described inthe Supplemental RI/FS. The groundwater remedy specified in the ROD requires the reduction ofVOC concentrations in the shallow groundwaterbypumping groundwater from a saturated sand and gravel zone underlying the Site, treating the groundwaterby air stripping and carbon adsorption, and reinjecting the water into the saturated sand and gravel zone. Consent Decree The United States subsequently entered into a Consent Decree with the Settling Defendants for the Site that was approved bythe Court on December 13, 1991. The Consent Decree required the implementation ofthe remedial action described inthe ROD and specified a number ofwork plans, design documents, and other deliverables bepreparedbythe SettlingDefendants prior to site remediation. Pre-Remedial Site Investigations Fulton Tenninals RA Report Page 3 of9

Pre-remedial site investigations conducted during the period December 1992 to January 1993 resulted in the identification ofa new area ofVOC-impacted soil in a layer ofsaturated silt and claybelow the impacted fill soils and above the sand and gravel zone. The VOCs detected inthe silt and clay layer which were not identified during previous RIIFS activities, represented a potential continuing source ofVOCs to the sand and gravel groundwater zone. During this period, a pre-remedial groundwater investigation was also conducted, including the installation ofadditional monitoring wells, monitoring well sampling, and an aquiferpump test. The pump test brithe.sand andgravel,aquiferindicated that the permeability ofthe sand and gravel unit was muchhigher than anticipated it} the Supplemental RI/FS and that the unit has a direct hydraulic connection to the Oswego**Riv~r.** The groundwater sampling confirmed that VOC-impacted groundwater inj:he sand and gravel·zone was associated with the same general area ofVOC soil impacts in the silt and clay layer.

:. i , - : 1 :' Additional field activities were:conducted in July 1993 to further delineate the extent of



# . voeimpact's injhe silt and clay soils;,as well as to further characterize groundwater impacts in

· •the sand·and gravel zone.· These investigation results indicated that 1) the extent of · VOC-impacted siltand clay soils had been fully delineated bycompletion ofthese additional

- •• ' • fieldactivities;.:an_d2):isolated areas ofdense, non-aqueous phase liquids (DNAPLs) existed in the saturated silt and clay layer. -Additional groundwater investigations were also conducted during the period August 1994 to May 1995. These investigations confirmed that the upper p9rtion ofthe sand and gravel zone was beingimpacted byVOCs contained in soils inthe silt and clay layer. Focused Feasibility Study Various remedial alternatives to address the area ofimpacted soils contained in the silt and clay layer were evaluated in a Focused Feasibility Study (FFS) (Blasland, Bouck & Lee, Inc. [BBL], October 1993, As Addended January 1994). The FFS results provided the basis for USEPA to conclude that the soil remedy should be expanded beyond the area offill soils identified for remediation in the ROD to also include the impacted silt and clay soils located beneath the fill soils. The FFS also determined that specialized methods for stabilizing the deep excavation area wouldberequired for removal ofthe impacted silt and clay soils because ofthe excavation depth, the need for control ofgroundwater infiltration into the excavation area and the close proximityto the Oswego River. USEP A Explanation ofSignificant DifferencesFulton Terminals RA Report Page 4 of9

Based onthe results ofthepre-remedial investigations at the Site and the FFS described above, USEPA modified the soil remedyin an Explanation ofSignificant Differences (ESD) dated June 1994. This ESD required the excavation and treatment by LTTD technology ofsoils impacted byVOCs, including the impacted silt and clay soils located beneath the fill soils. Soil Remedy Remedial Design Following the June 1994 ESD, the Intermediate Design Submittal describing the expanded scope ofthe soil remedy was submitted to USEPA in September 1994. In November 1994, BBLES was selectedbythe Settling Defendants to complete the soil remedy design and ,., , " "' ,, .' perform the soil remediation

.. BBLES subcontracted two major remedial design components for

. the FDS and soilremediation: : Moretrench Environmental Services, Inc. (Moretrench) for the design andinstallation.ofatemporary ground-freezing system, or "Freezewall", and Maxymillian Techilologies, Inc. (Maxymillian) for the soils excavation and LTTD treatment designandremeqiation. The BBLES Final Design Submittal (FDS) incorporated the Moretrench "·Freezew,all" technology to allow excavation and removal ofimpacted soils from the saturated siltand claylayer,'ptjortoLTTDtryatment. The LTTD design was based upon an existing ·i{ ''·· • •· Maxymillian LTTDsystemthat would bemobilized and assembled at the Site. The FDS was approved byUSEPA on March 31, 1995.

SOIL REMEDY OVERVIEW

·· ·, Once allsite-related access agreements were obtained, BBLES initiated the soil remedyin**~·** .,·, April1995. The initial phase ofthe reinedy included installation ofthe Moretrench Freezewall system and mobilization and assembly ofthe Maxymillian LTTD system. Duringthis phase, Maxymillianalso installed.sheetpiling around the perimeter ofthe shallow excavation area targeted for impacted fill soils only (designated as Area2). The Freezewall system consisted of a series ofmore than two hundred interconnected freezepipes that were installed around the perimeter ofthe deeper excavation area targeted for the impacted fill and silt and clay soils (designated as Area 1). The freezepipes were arranged in an oval pattern and extended from ground surface into the top ofbedrock to a depth ofover sixty feet below ground surface. Once the interconnecting freezepipes were installed inJuly 1995, a saltbrine coolant was circulated through the freezepipes to create a frozen earth cofferdam around the excavation area targeted for the impacted silt and clay soils. Maxymillian temporarily demobilized excavation and treatment personnel due to unanticipated delays experienced byMoretrench in completing Freezewall closure at the Site. The Freezewall formation was completed in November 1995 byMoretrench, at which time Maxymillianremobilized their personnel to resume soil excavation and treatmentFulton Terminals RA Report Page 5 of9 operations at the Site. Moretrench monitored the Freezewall routinely during the soil excavation and backfillingphase to confirm that the Freezewall integritywas being maintained. Groundwater control was required during installation ofthe :freezepiping, as well as during the excavation ofsaturated soils within the Freezewall. Treatment ofgroundwater removed during these activities was provided through use ofMaxymillian's temporary groundwater treatment system, which discharged to the Oswego Riverunder the terms ofNew York State Pollutant Discharge Elimination System (SPDES) discharge requirements. Performancetesting conducted byMaxymillian as part ofsystem start-up, as well routine testing during full-scale operation, verified that the treated water discharged to Oswego River complied with SPDES discharge requirements. A performance test ofthe LTTQsystem was conducted in June 1995 following assembly ofthe LTTD**sys~em** and while the Freezewall was being installed. The performance testresults suc<;essfully demonstrated that the operation ofthe LTTD system satisfied the soil cleanup and air emissionperformance requirements. Excavation and treatment offill soils began in ·September 1995 subsequen,t to USEPA's approval ofthePerformance Test Report (Focus Environmental, Inc., August 19,95):' :Excavation and treatment ofsaturated silt and clay soils
· wereinitiated once the Freezewall formation was completed in November 1995. Maxymillian

monitored the LTTD system routinely and verified that all required soil cleanup and air emission performance standards were met during soil treatment. The soil excavation and treatment activities contiriueqthrough February: 1996. Approximately 10,200 cubic yards ofsoils were excavated and treated inthe LTTD system.

,Priorto backfilling Area 1, BBLES inspected the base ofthe excavation to confirm that all silt and clay and visibly-impacted soils had beenremoved. Maxymillian then installed the horizontal well groundwater collection system inthe upperpart ofthe sand and gravel zone and at the base ofthe Area 1. excavation. The horizontal well collection system is part ofthe groundwater remedy for the Site and consists ofa gallery ofperforated piping and a collection manhole (BBL Groundwater FDS, August 1994, Revised September 1994). ' PERFORMANCE STANDARDS/CONSTRUCTION QUALITY CONTROL General The soil remedyFDS described theperformance standards and construction quality control requirements. These perfonnance standards include excavation ofimpacted soils within the limits ofexcavation specified in the FDS and LTTD treatment ofthe excavated soils toFulton Tenninals RA Report Page 6 of9 satisfy the soil cleanup levels stated in the ROD prior to on-site backfilling. Construction quality control information required bythe FDS was generated routinely during construction activities byBBLES to document that soil remedyperformance standards were achieved. This section documents that required performance standards and construction quality control requirements described in the FDS were met during the course ofthe soil remedy. Initial Site Activities During April1995, existing features ofthe site were surveyedbyBBLES, including existing grades, utiHties, restricted wbrk areas and limits ofexcavation designated in the FDS. A lined and bermed asphalt pad was cohstructed on the eastern side ofthe Site as a contaimnent pad for the LTTD unit and treated soil stockpiles.
;,Maxim.illian mobilized theferp.porary groundwater treatment system to the Site in May

. 1995. This system inchlded portable tanks for storage, settling and equalization, and a mobile

. water**tre~tment** system.
.Wl:J.en mobilization was complete, Maxymillian conducted performance

testing ofthe temporary**groundwat~r** treatment system to demonstrate that SPDES discharge requirements were satis'Ued. ·Upon analytical confinnation that SPDES discharge levels were met, the treated effluent**WC~:S** discharged into the Oswego River. Following initial performance
· testing, routine monitoring ofthesystem was conducted byMaxymillian to document ongoing

conformance with SPDES discharge requirements. LTTD Performance Test Maxymillian conducted LTTD perfonnancetesting to demonstrate that VOC concentrations intreated soils met the cleanup levels. Theperformance test also served to determinethemaximumproductionrate at which the LTTD system could operate to meet soil cleanup and air emissions requirements for the LTTD system. Approximately 1,123 tons (800 cubic yards) ofsoils were processed during the LTTD performance test period between June 27, 1995 and June 29, 1995. Extensive monitoring ofthe LTTD system conducted during the test confirmed that all LTTD treatment requirements for soils and air emissions were met and LTTD system operations conformed with the FDS. The LTTD performance test results were documented in the Performance Test Report that was approved byUSEPA on September 12, 1995. Freezewall Installation The Freezewall was installed byMoretrench to provide excavation sidewall stability andFulton Tenninals RAReport Page 7 of9

to limit water inflow into the Area 1 excavation. Moretrench, the Freezewall subcontractor, drilled/installed freezepipes in an elliptical shape around Area 1 ofthe site approximately 3 feet apart to a depth ofapproximately 70 feet (10 feet into bedrock). These pipes were interconnected to brine refrigeration units. A brine solution was recirculated throughout the freezepipe system to serve as a coolant for the ground-freezing. As stated in the FDS, the Freezewall was required to reach fhll "closure" before any sub-water-table excavation could commence. Closure was detennined through periodic temperature profiling and water-level readings conducted byMoretrench. Moretrench monitoring results confirmed full closure on November 21, 1995. Following closure, Moretrench personnel continued to operate the refrigeration units and monitor the Freezewall to ensure that closure was sustained. Excavation ·Area 1 excavation activities. continued between September 1995 and February 1996

.

.Area2,produCtion.excavation which occurred in October 1995, included the fill area ·encompassedby**~heetpiling** and extended to th.e top ofthe silt and clay layer. All excavation activities were**cdndu~tedby**Ma'xymillian iri**complianc~** with the USEPA-approved FDS. The excavation ofAreaLcontinged.from ground surface to the bottom ofthe silt and clay layer •within the.Freezewall**bp1mdary.~** Excavationbottom elevations inArea 1 were, in some instances, lower than**tl~ose** defined in the FDS, due to the discovery and subsequent removal of •visually-stainedsoils at the,exca'vation depths specified in the FDS. BBLES surveyed the

completed excavation 'and confinned that the Area 1 excavation continued to thebottom ofthe silt and clay layer as specified in the FDS. In addition, the Area 1 excavationbottom was observedby a professional geologist from BBL to ensure that impacted silt and clay soils and any visibly-stained soils were excavated. Upon confirmation that the excavation process in Area 1was completed, Maxymillian installed the groundwater remedyhorizontal extraction well system at thebase ofthe Area 1 excavation. Due to the difference in as-built Area 1base elevations, the horizontal collection system depth was altered slightlyto adjust for the increased excavation depth described previously. However, this altered depth location was detennined to be effective and consistent with the overall groundwater remedy FDS requirements. LTTD Soil Treatment LTTD soil treatment occurred during the period September 1995 through February 1996, except for the period when Maxymillian discontinued LTTD operations due to delays in achieving closure ofthe Freezewall. Routine monitoring results confirmed that the performance requirements specified inthe FDS were achieved during LTTD production activities. LTTD 'i':

-._..:___.::_.:._.'....... -_j_:Fulton Tenninals RA Report Page 8 of9
treated soils were sampled routinely to verifythat soil cleanup levels were metprior to backfilling. LTTD production operations and air emissions were monitored routinely and determined to be consistent with FDS requirements and the approved Performance Test Report. Backfilling Backfilling commencedupon completion ofthe horizontal groundwater extraction system installation, and verification that all excavated soils met cleanup requirements. In accordance with the FDS, soils were backfilled in lifts ofless than 2 feet and were tested for compaction of greater than 85 percent. Decontamination/Demobilization

, After all·backfilling activities were completed, equipment decontamination and demobilization was conducted as required bythe FDS. Residual soils removed from the LTTD containmentp!;ld were treatedbythe'LTTD system prior to disassembly ofthe unit. The LTTD containmentpad was**press~ure-washed** to removeany visible soil residue. Water generated duringthe presspre·-waship.g prpcess was collected and processed through the temporary water treatment system.. Residual soilE;-beneath the LTTD feed system were collected and sampled and detennined to be clean and suitableforbackfill in Area 1. The LTTD containment pad was brokenup after it was washed to accommodate final site grading in accordance with the FDS. Proc<;ss equipment was decontaminated, visually inspected byBBLES and demobilized. Upon completion ofArea 1backfilling to levels above the water table, the Freezewall refrigeration system and associated above-ground piping was shut offand demobilized. The freezepipes and monitoring pipes were then decommissioned byremoving the brine coolant solution, decontaminating the annular freezepipe space, abandoning the pipes in placebycutting them offapproximately 5 feet below ground surface, and filling the annular space with a fly-ash -·flowable fill as;required bythe FDS and Freezepipe Abandonment Plan. Finally, the temporary groundwater treatment system was demobilizedbyfirst decontaminating the system byrecycling treated water through the system and then transporting the mobile components offsite. Final grading and hydroseeding, removal ofoffice trailers, restoration ofthe site fencing to its original pre-construction configuration, and disconnection of electrical and telephone services completed the demobilization process.
FINAL INSPECTION Pre-final post-construction inspections ofthe soil remedy work completed byBBLES wasFulton Terminals RA Report Page 9 of9
conductedbyde maximis, onbehalfofthe Settling Defendants, on July 3, 1996 and September 11, 1996. All punchlist work items identified during the pre-final inspections were completed by BBLES priorto the final site inspection, which was conducted byUSEPA, BBLES and de maximis personnel on September 24, 1996.

CERTIFICATION

· Based onthe field obseryations associated with de maximis' construction oversight and the results ofthe post-soil remedypre-fihal and final site inspections, it has been determined that

·construction ofthe soil remedyhas been completed consistent with the soil remedyFDS and conforms with the reme,dy selectedinthe 1989 ROD for the Site, as modifiedbythe 1994 ESD

.. ·Fiiuil suilremedydocumentation,.(Project Closeout Report) is currentlybeingprepared by

BBLES. This certification 'is contingent upon the BBLES submittal and subsequent approval by the SiteMariagement Committee and the USEPA ofthe BBLES Project Closeout Report for the soil remedy.

OPERATION AND MAINTENANCE The are no elements ofthe soil remedy that require operation and maintenance following the recent completion ofsoil remedy construction activities. There are operation and maintenancerequirements assodated with the horizontal well groundwater collection system that was installed during the soil remedy. Thehorizontal well collection system installation is part of the groundwater remedy, including the associated operation and maintenance requirements specified in the groundwater remedyFDS. Therefore, operation and maintenance requirements associated with the horizontal well collection system will be addressed during implementation of the groundwater remedy.


### * * * * * 

## * * * * * * 

## * * * * * * * * * * * * * * * 

## *References

BBL Environmental Services, Inc., Final Design Submittal

- Soil Remedy, Fulton Terminals Site, Fulton, New York, March 31, 1995. Blasland, Bouck & Lee, Inc., Focused Feasibility Study, Fulton Terminals Site, Fulton, New York, October 1993, As Addended January 1994. Blasland, Bouck & Lee, Inc., Groundwater RemedyFinal Design Submittal, Fulton Terminals
·Site, Fulton, New York, August 1994, Revised September 1994. Focus**Environmental/Inc.,.Perfofii1anc~** Test Report, Fulton Terminals Site, Fulton, New York, August 1995. U.S

..Environmental ProtectioiJ Agency, Office ofEmergency and Remedial Response, Remedial ActiqnReportDocumentation for Operable Unit Completion, June 1992.