FINAL REMEDIAL ACTION REPORT 

:~ FULTON TERMINALS SITE 

SOILS REMEDY 

Prepared by: 

Mark Valentine 

de maximis, inc. 

Project Coordinator for the 

Fulton Terminals Site Remedial Action Trust 

SEPTEMBER 24, 1996 

/· 
INTRODUCTION 

This document presents the Final Remedial Action (RA) Report for the soil remedy at the 

Fulton Terminals Superfund Site (the Site) in Fulton, New York. This final RA Report was 

prepared on behalf of the 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 by the U.S. District Court for the Northern District ofNew York (the Court) 

on December 13, 1991. This report was prepared consistent with the requirements of the United 

States Environmental Protection Agency (USEP A) gu~dance entitled Remedial Action Report 

.· D9>.cumentation for Operable Unit Completion (June 1!992). 

The final RA Report has been ba;;ed on the remedial action work completed at the Site by 

BBL Environmental Services,·Inc. (BBLES) pursuant to the USEPA-approved Final Design 

Submittal (FDS) for the soil remedy (BBLES, March 31, 1995). The FDS was prepared 

.consistent with the requirements ofthe:Consent Decree, which describes work performed at the 

Site based on the requir~l1lents ofthe USEPA's 1989 Record of Decision (ROD) for the Site. 

SITE DESCRIPTION AND HISTORY 

Site Description 

The Site is located in an in,dustrial section of the City of Fulton in Oswego County, New 

• York- Residences;cityand c0unty offices, and sever~l businesses are located within a 

1,500-foot radius ofthe Site. The Site consists of an approximately 2-acre former storage 

facility that was used for the storage of raw materials used in the manufacture of asphalt 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 other materials that were originally scheduled for incineration at the Pollution 

Abatement Services facility in Oswego, New York. The Site was listed on the National 

Priorities List (NPL) in 1982. All aboveground tanks and known underground tanks, drums, and 

approximately 300 cubic yards of contaminated 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 by New 

York State Department of Environmental Conservation (NYSDEC) contractors during 1985 to 
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1987. The USEP A and several potentially responsible 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 of the initial RI/FS activities were declared invalid 

by NYSDEC due to laboratory analysis problems. A revised RI/FS was prepared by a NYSDEC 

contractor based on additional sampling performed in 1988. USEP A concluded that the revised 

RI/FS did not fully characterize the Site so a USEP A contractor conducted a Supplemental 

RI/FS. The Supplemental RI/FS was completed in 1989 and indicated that various volatile 

organic compounds (VOCs) were detected in unsaturated 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 on the 

Supplemental RI data. ··However, the.Supplemental RIIFS identified that the on-site soils were a 

potential future source ofVOCs leaching into groundwater. 

Record of Decision 

US EPA issued the ROD in September 1989 following completion ofthe Supplemental 

RIIFS. The ROD, specified a remedial: action consisting of both soil and groundwater remedies 

to address VOC,s detected in the respectixre media. The soil remedy required excavation and low 

temperature thermaldesorptidri(~TTD) ofuns~turated soil located above the water table (also 

referred to as ''fill soil"), within a localized area' of the site as defined by soil borings surrounding 

the former locatio!) uf a 1 ;000;000-gallon tank used for storage of solvents, as indicated in the 

ROD. The goalofthe soil remedy in tlie ROD1was to reduce concentrations ofVOCs in the fill 

soils to levels which would not cause an exceedance of applicable or relevant and appropriate 

requirements (ARARs) for groundwater due to percolation of precipitation through the 

_, unsaturated soils. ·The soil cleanup'levels in the ROD, which were based on New York State 

groundwater standards and site-specific criteria, were determined through application of the soil 

flushing model described in the Supplemental RI/FS. 

The groundwater remedy specified in the ROD requires the reduction ofVOC 

concentrations in the shallow groundwater by pumping groundwater from a saturated sand and 

gravel zone underlying the Site, treating the groundwater by 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 by the Court on December 13, 1991. The Consent 

Decree required the implementation of the remedial action described in the ROD and specified a 

number of work plans, design documents, and other deliverables be prepared by the Settling 
Defendants prior to site remediation. 

Pre-Remedial Site Investigations 

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Pre-remedial site investigations conducted during the period December 1992 to January 

1993 resulted in the identification of a new area of VOC-impacted soil in a layer of saturated silt 

and clay below the impacted fill soils and above the sand and gravel zone. The VOCs detected 

in the 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 

of additional monitoring wells, monitoring well sampling, and an aquifer pump test. The pump 

test bri the .sand and gravel, aquifer indicated that the permeability of the sand and gravel unit was 

much higher 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 

. voe impact's in jhe 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 by completion of these additional 

- •• ' • field activities;.:an_d2):isolated areas of dense, 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 of the sand and gravel zone was being impacted by VOCs contained in soils in the silt 

and clay layer. 

Focused Feasibility Study 

Various remedial alternatives to address the area of impacted 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 

USEP A to conclude that the soil remedy should be expanded beyond the area of fill 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 would be required for removal of the impacted silt and clay soils because of the 

excavation depth, the need for control of groundwater infiltration into the excavation area and the 

close proximity to the Oswego River. 

USEP A Explanation of Significant Differences 
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Based on the results ofthe pre-remedial investigations at the Site and the FFS described 

above, USEP A modified the soil remedy in an Explanation of Significant Differences (ESD) 

dated June 1994. This ESD required the excavation and treatment by LTTD technology of soils 

impacted by VOCs, 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 selected by the Settling Defendants to complete the soil remedy design and ,., , " "' , , . ' 

perform the soil remediation .. BBLES subcontracted two major remedial design components for . 

the FDS and soil remediation: : Moretrench Environmental Services, Inc. (Moretrench) for the 

design andinstallation.ofa temporary ground-freezing system, or "Freezewall", and 

Maxymillian Techilologies, Inc. (Maxymillian) for the soils excavation and LTTD treatment 

design and remeqiation. The BBLES Final Design Submittal (FDS) incorporated the Moretrench 

"·Freezew,all" technology to allow excavation and removal of impacted soils from the saturated 

siltand claylayer,'ptjortoLTTDtryatment. The LTTD design was based upon an existing ·i{ ''·· • •· 

Maxymillian LTTD system that would be mobilized and assembled at the Site. The FDS was 

approved byUSEPA on March 31, 1995. 

SOIL REMEDY OVERVIEW 

·· ·, Once all site-related access agreements were obtained, BBLES initiated the soil remedy in ~· . ,·, 

April1995. The initial phase of the reinedy included installation of the Moretrench Freezewall 

system and mobilization and assembly of the Maxymillian LTTD system. During this phase, 

Maxymillianalso installed.sheetpiling around the perimeter of the shallow excavation area 

targeted for impacted fill soils only (designated as Area 2). The Freezewall system consisted of 

a series of more than two hundred interconnected freezepipes that were installed around the 

perimeter of the 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 of bedrock to a depth of over sixty feet below ground surface. Once 

the interconnecting freezepipes were installed in July 1995, a salt brine 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 by Moretrench in completing Freezewall 

closure at the Site. The Freezewall formation was completed in November 1995 by Moretrench, 

at which time Maxymillian remobilized their personnel to resume soil excavation and treatment 
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operations at the Site. Moretrench monitored the Freezewall routinely during the soil excavation 

and backfilling phase to confirm that the Freezewall integrity was being maintained. 

Groundwater control was required during installation of the :freezepiping, as well as 

during the excavation of saturated soils within the Freezewall. Treatment of groundwater 

removed during these activities was provided through use ofMaxymillian's temporary 

groundwater treatment system, which discharged to the Oswego River under the terms of New 

York State Pollutant Discharge Elimination System (SPDES) discharge requirements. 

Performance testing conducted by Maxymillian as part of system 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 of the LTTQsystem was conducted in June 1995 following assembly 

of the LTTD sys~em and while the Freezewall was being installed. The performance test results 

suc<;essfully demonstrated that the operation of the LTTD system satisfied the soil cleanup and 

air emission performance requirements. Excavation and treatment of fill soils began in 

·September 1995 subsequen,t to USEPA's approval ofthe Performance Test Report (Focus 

Environmental, Inc., August 19,95):' :Excavation and treatment of saturated silt and clay soils 

· were initiated 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 contiriueq through February: 1996. Approximately 10,200 cubic yards of soils were 

excavated and treated in the L TTD system. 

, Prior to backfilling Area 1, BBLES inspected the base of the excavation to confirm that 

all silt and clay and visibly-impacted soils had been removed. Maxymillian then installed the 

horizontal well groundwater collection system in the upper part of the sand and gravel zone and 

at the base of the Area 1. excavation. The horizontal well collection system is part of the 

groundwater remedy for the Site and consists of a gallery of perforated piping and a collection 

manhole (BBL Groundwater FDS, August 1994, Revised September 1994). 

' 

PERFORMANCE STANDARDS/CONSTRUCTION QUALITY CONTROL 

General 

The soil remedy FDS described the performance standards and construction quality 

control requirements. These perfonnance standards include excavation of impacted soils within 

the limits of excavation specified in the FDS and LTTD treatment of the excavated soils to 
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satisfy the soil cleanup levels stated in the ROD prior to on-site backfilling. Construction 

quality control information required by the FDS was generated routinely during construction 

activities by BBLES to document that soil remedy performance standards were achieved. This 

section documents that 

required performance standards and construction quality control requirements described in the 

FDS were met during the course of the soil remedy. 

Initial Site Activities 

During April1995, existing features of the site were surveyed by BBLES, including 

existing grades, utiHties, restricted wbrk areas and limits of excavation designated in the FDS. 

A lined and bermed asphalt pad was cohstructed on the eastern side of the 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 of the 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 of the system was conducted by Maxymillian to document ongoing 

conformance with SPDES discharge requirements. 

LTTD Performance Test 

Maxymillian conducted LTTD perfonnance testing to demonstrate that VOC 

concentrations in treated soils met the cleanup levels. The performance test also served to 

determine the maximum production rate 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) of soils were processed during the LTTD performance test period between June 27, 

1995 and June 29, 1995. Extensive monitoring of the 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 by USEPA on September 12, 

1995. 

Freezewall Installation 

The Freezewall was installed by Moretrench to provide excavation sidewall stability and 
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to limit water inflow into the Area 1 excavation. Moretrench, the Freezewall subcontractor, 

drilled/installed freezepipes in an elliptical shape around Area 1 of the site approximately 3 feet 

apart to a depth of approximately 70 feet (1 0 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 by Moretrench. 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 

·encompassed by ~heetpiling and extended to th.e top of the silt and clay layer. All excavation 

activities were cdndu~tedby Ma'xymillian iri complianc~ with the USEP A-approved FDS. The 

excavation ofArea Lcontinged.from ground surface to the bottom of the silt and clay layer 

• within the. Freezewall bp1mdary.~ Excavation bottom elevations in Area 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 the bottom of the 

silt and clay layer as specified in the FDS. In addition, the Area 1 excavation bottom was 

observed by 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 1 was completed, Maxymillian 

installed the groundwater remedy horizontal extraction well system at the base of the Area 1 

excavation. Due to the difference in as-built Area 1 base elevations, the horizontal collection 

system depth was altered slightly to 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. 

L TTD 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 of the Freezewall. Routine monitoring results confirmed that the performance 

requirements specified in the FDS were achieved during LTTD production activities. LTTD 

'i': 

-._..:___.::_.:._.'....... -_j_: 
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treated soils were sampled routinely to verify that soil cleanup levels were met prior 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 commenced upon completion of the horizontal groundwater extraction system 

installation, and verification that all excavated soils met cleanup requirements. In accordance 

with the FDS, soils were backfilled in lifts of less 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 by the FDS. Residual soils removed from the LTTD 

containment p!;ld were treatedbythe'LTTD system prior to disassembly of the unit. The LTTD 

containment pad was press~ure-washed to remove any visible soil residue. Water generated 

during the 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 suitable for backfill in Area 1. The LTTD containment pad was 

broken up after it was washed to accommodate final site grading in accordance with the FDS. 

Proc<;ss equipment was decontaminated, visually inspected by BBLES and demobilized. 

Upon completion of Area 1 backfilling to levels above the water table, the Freezewall 

refrigeration system and associated above-ground piping was shut off and demobilized. The 

freezepipes and monitoring pipes were then decommissioned by removing the brine coolant 

solution, decontaminating the annular freezepipe space, abandoning the pipes in place by cutting 

them off approximately 5 feet below ground surface, and filling the annular space with a fly-ash 

-·flowable fill as; required by the FDS and Freezepipe Abandonment Plan. 

Finally, the temporary groundwater treatment system was demobilized by first 

decontaminating the system by recycling treated water through the system and then transporting 

the mobile components offsite. Final grading and hydroseeding, removal of office trailers, 

restoration of the 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 of the soil remedy work completed by BBLES was 
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conducted by de maximis, on behalf of the Settling Defendants, on July 3, 1996 and September 

11, 1996. All punchlist work items identified during the pre-final inspections were completed 

by 

BBLES prior to the final site inspection, which was conducted by USEP A, BBLES and 

de maximis personnel on September 24, 1996. 

CERTIFICATION 

· Based on the field obseryations associated with de maximis' construction oversight and 

the results of the post-soil remedy pre-fihal and final site inspections, it has been determined that 

· construction of the soil remedy has been completed consistent with the soil remedy FDS and 

conforms with the reme,dy selected in the 1989 ROD for the Site, as modified by the 1994 ESD .. 

· Fiiuil suilremedydocumentation,.(Project Closeout Report) is currently being prepared 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 of the soil remedy that require operation and maintenance following 

the recent completion of soil remedy construction activities. There are operation and 

maintenancerequirements assodated with the horizontal well groundwater collection system that 

was installed during the soil remedy. The horizontal well collection system installation is part of 

the groundwater remedy, including the associated operation and maintenance requirements 

specified in the groundwater remedy FDS. 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 Remedy Final 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 of Emergency and Remedial Response, Remedial 

ActiqnReportDocumentation for Operable Unit Completion, June 1992.