LOWER FOX RIVER REMEDIAL DESIGN I … · LOWER FOX RIVER REMEDIAL DESIGN ANTHOLOGY EPA Region 6 Records Ctr 349171 Prepared for ... protectiveness of human health

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LOWER FOX RIVER REMEDIAL DESIGN ANTHOLOGY

EPA Region 6 Records Ctr

349171

Prepared for Appleton Papers Inc

Georgia Pacific Consumer Products LP

NCR Corporahon

For Submittal to

Wisconsin Department of Natural Resources

U S Environmental Protection Agency

Prepared by Anchor Environmental LLC

Tetra Tech EC Inc

July 31, 2008

Table of Contents

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1 Final Feasibility Study Lower Fox River and Green Bay Wisconsin Remedial Investigation and Feasibility Shidy RETEC (December 2002)

2 Remedial Investigahon Report Lower Fox River and Green Bay Wisconsin RETEC (December 2002)

3 Remedial Design Work Plan A Work Plan for the Remedial Design of Operable Units 2 3 4 and 5 Lower Fox River and

Green Bay Site (June 27 2004) • Agency Approval June 28 2004

B RD Work Plan Addendum (Apnl 21 2008) • Agency Approval April 29 2008

4 Pre Design Sampling Plans A Lower Fox River Operable Units 4 and 5 Pre design Sediment Poling Plan (June 10 2004)

• Agency Approval June 22 2004 B Lower Fox River Operable Units 2-5 Pre design Sampling Plan (July 2 2004)

• Agency Approval June 14 2004 C Addendum No 1 to Pre-Design Sampling Plan A Procedural Changes to the

SAP/QAPP (August 24 2004) • Agency Approval September 3 2004

D Addendum No 2 to Pre Design Sampling Plan Supplemental / Phase 2 Samplmg (Spring 2005) • Agency Approval May 3 2005

E Addendum No 3 to Pre Design Samplmg Plan Sediment Charactenzahon For Disposal Purposes (June 10 2005) • Agency Approval July 5 2005

F Addendum No 4 to Pre Design Sampling Plan Shoreline Data Collection (May 31 2006) • Agency Approval June 1 2006

G Addendum No 5 to Pre Design Sampling Plan Supplemental Sampling Plan (August 13 2007) • Agency Approval August 29 2007

5 Basis of Design Report A Basis of Design Report Gune 16 2006)

• Agency Approval July 11 2006 B Supplemental Data & Memos (March 6 2006)

6 Baseline Monitoring A Baseline Monitormg Plan Qune 23 2006)

• Agency Approval July 24 2006 B Baseline Momtonng Data Report (July 8 2008)

• Agency Approval Pending

Remedial Design Anthology July 2008 Loiuer Fox Rwer Remedial Design I 080295 03

Table of Contents

7 Cap Design Documentation A Contingent Remedy Tech Memo (June 21 2005) B Lower Fox River OUs 2 to 5 Engineered Cap Design Technical Memo (60% Design

Report Appendix B 1) (June 10 2008)

8 Dredge Design Documentahon A 60 Percent Design Dredge Plan Development Memorandum (April 11 2008)

• Agency Acceptance April 18 2008 B Difficult or Inefficient to Dredge Areas

• Summary of Difficult or Inefficient to Dredge Areas Evaluated through 60 Percent Design (May 28 2008)

• Difficult of Inefficient to Dredge Area Tech memos

9 Summary of Remedy Delmeahon and Changes Since BODR

10 Preliminary (30 Percent) Design (November 30 2007) • Agency Approval February 15 2008

11 Intermediate (60 Percent) Design Qune 16 2008) • Agency Approval Pending

12 Pre Final (90 Percent) Design

13 Final (100 Percent) Design

14 2004 - 2007 Remedial Design Database (MS Access)

Remedial Design Anthology July 2008 Lower Fox Rwer Remedial Design 2 080295 03 B

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Introduction

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INTRODUCTION

This document presents the Remedial Design (RD) Anthology for Operable Units (OUs) 2 to 5

of the Lower Fox River and Green Bay Site This RD Anthology presents a compilation of the

data and documents used to support the remedial design for remediahon of polychlormated

biphenyls (PCBs) m OUs 2 to 5 The printed version of this RD Anthology presents an

abbreviated version of each major design document including the table of contents and

executive summary or introductory paragraph The attached set of DVDs and CDs include

complete electronic versions of each submittal and/or data set along with Agency approval

informahon (if applicable)

Remedial Design Anthology July 2008 Lmuer Fox River Remedial Design 3 080295 03

S5

CA

o

HS^RETEC

Final Feasibility Study

Lower Fox River and Green Bay, Wisconsin Remedial Investigation and Feasibility Study

Prepared for:

Wisconsin Dept of Natural Resources

Prepared by: The RETEC Group, Inc.

December 2002

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Final Feasibility Study |

Lower Fox River and Green Bay, | Wisconsin Remedial! Dnvestigation and Feasibality | Study

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RETEC Project No WISCN-14414-561 |

Prepared by

The RETEC Group, Inc 1011 S W Klickitat Way, Suite #207 Seattle, Washington 98134

Prepared for

Wisconsin Department of Natural Resources 101 S Webster Street Madison, Wisconsin 55703

Senior Authors

Alessandro Battaglia Ph D P E Senior Engineer Erie Kovatch R G NRT Senior Geologist

Technical Review by

Timi

December 2002 \\Blueberry\My Documents\Fox River\FS\PDF FinalFS wpd

I I I I Grant Hamsworth P E Project Engineer

Merv Coover P E Project Engineer Anne G Fitzpatnck Senior Environmentai Scientist ^ Jennifer P Topel P E Environmentai Engineer H Alessandro Battaalia Ph D P E Sftninr PnnineAr HI

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tthy^A ^ o m p s o n ^Ssnic/ Technical Advisor

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EXECUTIVE SUMMARY FEASIBILITY STUDY Lower Fox River and Green Bay

The Feasibility Study (FS) developed and evaluated a range of remedial alternatives for the Lower Fox River and Green Bay (Figure 1) to manage the risk associated with the presence of industrial contaminants discharged to the river. This RI/FS report is consistent with the findings of the National Academy of Sciences Research Council Report entitled A Risk Management Strategy for PCB-Contaminated Sediments (NAS, 2001).

Each altemative was compared to nine evaluation criteria including: 1) risk reduction, 2) overall protectiveness of human health and the environment, 3) implementability, 4) short-term effectiveness associated with the remedy action, 5) permanence, 6) reduction in toxicity, mobility and volume, 7) cost, 8) regulatory acceptance, and 9) community acceptance.

The area of concern includes the Lower Fox River extending 63 Ion (39 mi) from Lake Winnebago to the mouth of Green Bay, and includes the entire 4,150 km^ (1,600 mi^) of the bay. Remedial alternatives were developed for the four reaches of the Lower Fox River including: Little Lake Butte des Morts, Appleton to Little Rapids, Little Rapids to De Pere, and De Pere to Green Bay (same as Green Bay Zone 1); as well as the four zones of Green Bay: Zone 2, Zone 3A, Zone 3B, and Zone 4.

The purpose of the FS is to support the selection of a remedy that will eliminate,

reduce and/or control short-term and long-term risks. The evaluation in the FS used data developed in the Remedial Investigation (RI), Risk Assessment (RA), and Model Documentation reports to support the screening of alternatives. This screening of alternatives followed EPA's Superfund Guidance document for conducting RI/FS studies under CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act of 1980).

Figure 1 (Fitzgerald & Steuer, 1996)

Site History and PCB Discharges

Between 1954 and 1971, paper mills in the Lower Fox River valley manufactured and recycled carbonless copy paper that contained polychlorinated biphenyls (PCBs), resulting in the release of an estimated 300,000 kg (600,000 pounds) of PCBs to the river. The highest PCB concentrations detected in site sediments were 223 mg/kg in the Little Lake Butte des Morts Reach and 710 mg^cg in the De Pere to Green Bay Reach. WDNR issued PCB consumption advisories in 1976 and 1983 for fish and waterfowl, respectively. The State of Michigan also issued consumption advisories for Green Bay fish in

E.xecutive Summary


1977 today

These advisories are still in effect

PCB Distribution, Volume, and Transport

The Remedial Investigation identified the sources of PCBs the estimated mass and volume of PCBs in bedded sediments The RI also estimated the sediment and PCB mass transport rates Between 65 and 175 kg of PCBs are transported downstream annually from each reach and 280 kg of PCBs move mto Green Bay annually A significant portion of the PCB loading that occurs in Green Bay is derived from the Lower Fox River This transport of PCBs also extends to Lake Michigan

PCBs discharged into the river in large part today remain in the bedded sediments of the nver and bay For sediments contammg more than 50 iig/kg PCBs approximately 28 600 kg (63 050 pounds) of PCBs remain in the Lower Fox River (Figure 2) compared to approximately 68 200 kg (150 300 pounds) of PCBs in Green Bay (Figure 3) As stated in the RI report the PCBs are contained within about 11 8 million cy of sediment in the river In Green Bay the PCBs are dispersed m a much greater volume of sediment approximately 610 million cy

Risks to Human and Ecological Receptors

The chemicals of concern (COCs) from the Baseline Risk Assessment (RA) included polychlonnated biphenyls (PCBs) (total and selected congeners) mercury and DDE as the pnmary compounds of risk to human health and the environment with PCBs presenting the highest risk The exposure pathway presenting the greatest

level of risk to both human health and ecological receptors is through fish consumption (other than direct risk to benthic invertebrates) Receptors at risk include recreational anglers high intake fish consumers benthic invertebrates fish birds and rivenne mammals PCBs contribute more than 70 percent of the cancer risks found from the consumption of fish and waterfowl

The risk assessment also derived sediment quality thresholds (SQTs) that were linked to estimated magnitudes of risk to valued receptors SQTs were developed for over 100 pathways and receptors and arrayed to show the magnitude and protectiveness of potential risks SQTs themselves are not cleanup criteria but were used to evaluate levels of PCB risk and help develop FS action levels

Remedial Action Objectives

The FS reviewed multiple community state federal and private documents to identify common expectations for the Fox River and Green Bay From this review five remedial action objectives were formulated These objectives lay the foundation for remedial expectations for the FS and provide a metrics to measure long term success These objectives include

1 Achieve surface water quality cnteria to the extent practicable

2 Protect humans who consume aquatic I organisms (i e remove consumption advisories)

4 Reduce transport of PCBs from the nver into Green Bay and Lake Michigan and

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I Protect ecological receptors (i e healthy invertebrate bird fish mammal M populations) |

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Excaitive Summary

I Final Feasibility Study

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5 Minimize contaminant releases during remediation

These objectives can be further defined mto measurable metncs for evaluatmg long term remedial success These measurable expectations were defined by WDNR and EPA as the ability for recreational anglers to consume fish within 10 years following completion of a remedy and 30 years for high'intake fish consumers for human health (RAO 2)

Ecological expectations were defined by WDNR and EPA as the ability to achieve safe ecological thresholds for piscivorous birds and mammals Although not a specific metnc the FS used 30 years followmg remedy completion (RAO 3) These expectations assumed several years of active remediation followed by 30 years of recovery after which the endpoints are measured and compared to protective fish tissue levels

Other metrics used to measure remedial success include the time to achieve state surface water cnteria (RAO I) and the time for PCB loading rates from the Lower Fox River into Green Bay to equal the combined loading estimates from other tributaries into Green Bay (10 kg/yr PCBs) (RAO 4) For relative comparison between different remedies and action levels the FS used 30 years following remedy completion to achieve these goals

Array of Remedial Action Levels

The FS evaluated remedial alternatives risks duration and costs relative to a series of potential sediment cleanup values These values termed remedial action levels were 125 250 500 1 000 and 5 000 ppb PCBs For all action levels it

was assumed that different levels of residual nsk would remain after remediation Natural processes would be relied upon to further decrease COC sediment concentrations to protective levels

Remedial Alternatives

Over 100 technologies were screened dunng the feasibility study The remedial alternatives retained for detailed analysis included

A No action

B Monitored natural recovery (MNR)

C Dredge and off site disposal

D Dredge and on site disposal (CDF)

E Dredge and thermal treatment

F In situ containment (capping) and

G Dredge to confined aquatic disposal (CAD) site

The alternatives were considered for each of the four nver reaches and Green Bay zones (Table 1) All of the active remedies are designed to be completed in 10 years in combination with natural recovery after remedy completion with the degree of recovery dependent on the action level selected Each of these remedial options categories is discussed below However final selection of a remedy will be governed by site specific conditions and expectations

Monitored Natural Recovery Natural recovery refers to the processes by which COCs decline over time by biodegradation dilution or transport mechanisms Institutional controls will remain in place to restnct site use until the system has recovered to protective thresholds Natural recovery of sediments

Exemtive Summary 111


primarily occurs through three processes burial mixing and transport or dechlorination/ biodegradation The FS determmed that all three of these processes occur in the Lower Fox River system but the success of these processes is continually

Table 1 Summary of Evaluated Remedial Alternatives by Reach and Zone

areas community disturbance and potential release of contaminants to the environment dunng implementation Removal of impacted sediments is a permanent solution and does not require long term maintenance or access

A l t e r n a t i v e D e s c n p t i o n

A

B

C

D

E

F

G

N o A c t i o n

M on i t o r e d N a tu ra 1 R e c o v e r y

D r e d g e and

O f f S i t e

D i s p o s a l

D r e d g e to C D F

D r e d g e and T h e r m a 1 T r e a t

C a p

D r e d g e to

C A D

L i t t l e L a k e B u t t e d e s

M o r t s

•

•

•

•

•

•

L o w er Fox

A p p l e t o n to L i t t l e R a p i d s

•

•

•

•

R i v e r R e a c h e s

L i t t l e R a p i d s t o De P e r e

•

•

•

•

•

•

De P e r e to G r e e n

B a y

•

•

•

•

•

•

Z o n e 2

•

•

•

•

•

Gree n Ba

Z o n e 3A

•

•

•

•

•

y Z o n e s

Z o n e 3 8

•

•

•

•

Z o n e 4

•

•

influenced by ongoing physical processes resulting in limited overall effectiveness in many areas To evaluate a natural recovery option It was assumed that the current systems of dams on the nver would remain in perpetuity A long term monitoring program would be implemented to ensure that sediment water and fish tissue PCBs would decline over time

Removal (Dredging) Removal involves excavation of site sediments using mechanical or hydraulic dredging techniques Dredging is a common practice for managing impacted sediments but would require careful consideration of dewatering methods disposal options physical obstructions site access staging

restnctions

Treatment The FS also evaluated treatment and non treatment options Retained treatment options included thermal technologies such as desorption and vitrification where the resulting product would have the potential for beneficial reuse

Disposal Disposal of dredged material can managed m three ways permanent placement in upland nearshore and in water facilities It IS generally expensive and requires intensive dewatering techniques to adequately prepare sediments for long term disposal Several on site and off site disposal options were retained in the FS including nearshore fills free standing confined disposal facilities (CDFs) submerged aquatic disposal

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Executive Summary IV

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Fmal Feasibility Study

Sites (CADs) and upland landfills where impacted sediments are placed in containment structures designed to isolate and contain contaminants over the long term

Containment (Capping) Containment involves the physical isolation and immobilization of chemicals in sediments Capping IS a common method for containing impacted sediments in place It would require long term restrictions on site access and land use nghts in addition to long term monitoring and maintenance to ensure integrity of the capping structure The capping alternative would require careful consideration of site conditions navigational channels nver currents vessel propeller wash water depths and ice scour as well as other factors that may limit the installation and subsequent permanence of cap placement

Comparative Analysis

Each alternative was compared to the nine evaluation criteria defined above for each nver reach and Green Bay zone Risk reduction and overall protectiveness are discussed below Implementablity and effectiveness were determined as feasible for each retained alternative based on availability previous experience and performance based results Reduction of toxicity mobility and volume is related to cost Both are dependent on the action level selected Thermal treatment is the only alternative that permanently reduces PCB volume and mass Relative costs are discussed below and community acceptance of the retained alternatives will be evaluated dunng public comment periods and outreach programs

Risk Reduction

The ability of the seven remedial alternatives to achieve the FS expectations were quantified by relative risk reduction over time using hydrodynamic and bioaccumulation models over a projected 100 year time frame These models predicted the number of years required to reach protective thresholds for human health and the environment (e g number of years required to remove fish consumption idvisones) The projected number of years required to consistently meet protective water quality human health ecological health and PCB transport thresholds following remediation (the RAOs) were compared to different action levels and costs for each alternative Results are presented on Figures 2 and 3 A comparative analysis of action levels that meet protective levels between the different nver reaches is presented on Figures 4 and 5

Water Quality The state surface water quality criteria for protection of human health are not met for any combination of remedial scenario and action level in the river Only the wildlife criteria (0 12 ng/L) is met in 16 years after remediation for the 125 ppb action level increasing to 69 years for the 1 000 ppb action level

Human Health As shown on Figures 4 and 5 in order to remove recreational fish consumption advisories within 10 years following remediation (WDNR s expectation) remedies implemented to the 1 000 ppb PCB action level for surface sediments would be required for most of the river reaches Action levels ranging from 250 ppb to 1 000 ppb would be required to remove high intake consumer advisories within 30 years following remediation depending upon the specific reach of the

Exeaittve Suniniaty


nver For Green Bay none of the remedies are projected to achieve the protective human health values These model projections account for dynamic physical properties of the system including water velocity water depth currents flooding natural deposition scour events and storm events

Ecological Health To meet the protective ecological thresholds m the expected 30 year time frame following remedy completion an estimated minimum action level of 1 000 ppb would be required in the Little Lake Butte de Morts and Appleton to Little Rapids reaches A minimum action level of 250 ppb would be required in the Little Rapids to De Pere and De Pere to Green Bay reaches The No Action alternative (passive remediation) would require greater than 100 years to meet protective ecological thresholds in the Lower Fox River (Figure 4) In Green Bay none of the remedies will meet protective ecological thresholds in 100 years based on projected fish tissue concentrations regardless of the action taken in the Lower Fox River (Figure 5)

PCB Transport One of the long term goals of the project is to reduce the transport and load of PCBs to Green Bay and subsequent movement to Lake Michigan The total annual average loading rates of PCBs to Green Bay from all tributaries combined (without the Fox River) is currently 10 kg/year PCBs The Fox River fate and transport models were used to predict the number of years required to reduce the PCB loads from the Fox River into Green Bay over time after remedy completion At the expected 30 year time frame following remedy completion the projected loading rates from the Fox River

were compared to the loading rates of all other Green Bay tributaries combmed These levels could be considered background levels

Remedies to at least the 5 000 ppb action level would be required in the De Pere to Green Bay Reach to meet projected expectations PCB load expectations for these two action levels would require 24 years to meet tributary levels At the 1 000 ppb action level the target level is achieved in 4 H years followmg remediation The model predications for PCB loading rates from the M mouth of the Fox River (De Pere to Green | Bay Reach) takes into consideration the cumulative PCB loads from the upper reaches B therefore only the last reach was evaluated in " t heFS

FS Costs

action level (±30 percent) as presented on Figures 2 and 3 In the Lower Fox River the

I It IS important to note there is uncertainty associated with these projected estimations of risk reduction and duration to meet H protective thresholds The model projections were calibrated over a finite time interval and m projected out to 100 years based on the B trends observed durmg the short calibration period The projected risk M reductions/durations cannot predict the actual •" number of years to reach protective _ thresholds with considerable precision H However the strength of these models is the relative risk reduction estimates for I comparing between different action levels and remedial alternatives More information on the models may be found in the Lower Fox • River and Green Bay Model Documentation Report I Total remediation costs were estimated for H each remediation alternative and each PCB

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Executive Summaiy VI


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costs for active remediation (Alternatives C through F) range from approximately $38 300 000 to $769 100 000 per nver reach (Table 2) In Green Bay the costs for active remediation (Alternatives C D and G) range from approximately $11 000 000 to $1 155 100 000 (Table 3) Costs include land acquisition mobilization permits facility construction dredging and dewatenng disposal materials labor oversight public outreach site restoration efforts operation and maintenance costs in addition to long term monitoring efforts for 30 years following remediation

The cost for passive remediation or monitored natural recovery (Alternative B) IS approximately $9 900 000 per reach/zone over a 30 year period MNR costs include maintenance of institutional controls along with sediment surface water bird and fish tissue sampling and invertebrate sampling events conducted every 5 years for 30 years Costs are calculated as net present worth costs

The largest variability in costs are observed between different action levels Remediation costs are directly proportional to sediment volumes therefore as the action level decreases (becomes more protective) the sediment volume reqiiiring removal increases and the cost increases For example the cost to place an in situ sand cap (Alternative F) in the Little Lake Butte des Morts Reach will cost approximately $145 200 000 at the 125 ppb action level but only $66 200 000 at the 5 000 ppb action level

When comparing costs between different alternatives in the Lower Fox River the active remedy costs are 3 to 78 times

higher than the passive remedy costs Among the active remedies the Dredge and Treat /Vlternative is the least cost remedy (ranging from a 3 fold to 40 fold increase over the MNR Alternative) The Capping Alternative and Dredge to CDF Alternative are generally the medium cost remedies (ranging from a 4 fold to 60 fold increase over the MNR Alternative) The Dredge and Off site Disposal Alternative is the highest cost remedy (ranging from a 4 fold to 78 fold increase over the MNR Alternative) In Green Bay the active remedy costs are similar when compared within a single action level

Further Information

Remedy selection for the Lower Fox River and Green Bay will be based on the information contained within the RI RA and FS as well as numerous opportunities for input by the public and interested parties For further information regarding the Lower Fox River RI FS RA or MDR documents please contact

Mr Edward Lynch (608/266 3084) Wisconsin Department of Natural Resources 101 S Webster Street Box 7921 Madison Wisconsin 53703

I Exeaittve Summary Vll

Figure 2 Lower Fox River Summary of Remedial Action Levels and Projects Risk Reduction by Reach

Lower Fox River Reaches

Remediation Alternative

PCB Act ion Level (ppb) Maximum Act ion Level that Meets Risk Reduction Criteria

Related to Project RAOs

125 250 500 1,000 5,000 R A 0 1 SWQ

RAO 2 HH

RAOS Eco

RAO 4 Transport

Applcion Lo Liule Rapids

LiLlIc Rapids LO De Pere

Lilllc Lake Bullc InipacLcd Volume (cy) des MorLs PCB Mass (kg)

Remedial Cosi (in 1,000s S) A/B: No AcLion CI: Dredge, Off-siLc Disp. (Pass. DewaLer) C2: Dredge, Off-siLe Disp. (Mech. DewaLer) D: Dredge Lo CDF, Ofl-siLe TSCA Disp. E: Dredge and Thermal TreaLmcnl F: Cap and Dredge Lo CDF

ImpacLcd Volume (cy) PCB Mass (kg) Remedial CosL (in 1,000s S)

A/B: No AcLion C: Dredge, OII'-siLc Disp. E: Dredge and Thermal 'FreaimenL

ImpacLcd Volume (cy) PCB Mass (kg) Remedial CosL (in 1,000s S)

A/B; No Action C1: Dredge to NR 500 FaciliLy (Pass. Dewater) C2A: Dredge LO Comb. DewaLcr/Disp. FaciliLy C2B: Dredge to Sep. DewaLcr/Disp. Facilities C3: Dredge Lo NR 500 FaciliLy (Mech. Dewater) D: Dredge to CDF, Ofl-siLc TSCA Disp. E: Dredge and Fhermal Frcatmcnt F: Cap and Dredge LO CDF

De Pere Lo Impacted Volume (cy) Green Bay TSCA Volume (cy)

PCBMa.ss(kg) Remedial CosL (in 1,000s S)

A/B: No AcLion Cl: Dredge to NR 500 Facility (Pass. DewaLer) C 2A: Dredge to Comb. Dcwaier/Disp. FaciliLy C2B: Dredge Lo Sep. Dewater/Disp. Facilities C3: Dredge to NR 500 Facility (Mech. Dewater) D: Dredge to CDF, Ofl-siLc TSCA Disp. E: Dredge aitd Thermal TreaLmcnL F: Cap and Dredge LO CDF

1,689,173

1,838

S9,yoo 5231,500

5126,200

$116,000

$117,200

5145,200

182.450

106

59,900

538,300

$26,200

1,483,156

1,210

59,900

5224,200

$72,300

$179,800

$161,700

572,300

5142,700

$143,700

6,868,500

240,778

26,620

59,900

$769,100

$196,000

5564,500

5595.200

5611,800

5404,500

5432,600

1,322.818

1,814

59,900

5185.600

5102.500

$110,300

596,000

5138,600

80,611

99

59,900

525,000

$19,700

1,171,585

1,192

59,900

$180,700

563,200

5152,800

$130,800

$66,800

$123,800

5114,300

6,449,065

240,778

26,581

59,900

$723,100

$186,900

5534,100

5561,000

5566,400

5384,000

5403,900

1,023,621

1,782

$9,900

5147,800

$82,800

$105,100

$78,500

$99,300

56.998

95

59.900

521.700

517,900

776.791

1.157

59.900

5124.200

551.400

5118.300

$90,300

558,400

599,500

587,800

6,169,458

240,778

26,528

59,900

$692,3(X)

$ 180,400

$513,500

$537,800

$536,200

$370,000

$381,900

784,192

1,715

$9,900

5116,700

$66,200

568,000

$63,600

$90,500

46,178

92

$9,900

$20,100

$17,100

586,788

1,111

$9,900

595,100

543,900

599,900

$69,100

552,500

586,200

562,900

5,879,529

240,778

26,433

59,900

5660,600

5173,500

5491,800

5513,500

5505,100

$355,100

$357,100

281,689

1,329

$9,900

548,500

528,300

554,500

$29,300

$66,200

20,148

67

$9,900

516,500

$15,200

186,348

798

59,900

538,100

532,400

565,300

528,400

$44,400

$61,900

534,700

4,517,391

240,778

24,950

$9,900

$511,100

$138,700

$388,000

$397,200

$360,700

$283,300

$234,4(J0

'CD^ e 'CD^ O 1

NA

e'3 NA

NA

Notes: Thresltold criteria used lo evaluate risk reduclion:

RAO 1 : 1 = Wildlife Criteria 30-ycar, 2 = Human Surface Waicr Drinking Criteria 3U-ycar. RAO 2 : 1 = 1 ligli-inLake Fisli Consumer Cancer 30-year, 2 = I ligh-inlake Fish Consumer Noncancer 30-year,

3 = Recreational Angler Cancer 10-year, 4 = ReereaLional Angler Noncancer 10-ycar. RAO 3: 1 = Carnivtjrous Bird Oefonnily NOAEC 3()-year, 2 = Piscivorous Manunal NOAEC 30-ycar. RAO 4: 1 = Tributary Load UJ Reach Green Bay Level 30-year.

NA - Nol applicable.

Action Level (ppb) that Consistently Meets Criteria after 10 or 30 Years of Recovery after Remediation Completion

^ ^ ^ ^ • l i d H H Crileria

Never

Mel after

30 Years

|l25| 250| |500| |l,000| |5,000| No

Action

Taken

Figure 3 Green Bay Summary of Remedial Action Levels and Projected Risk Reduction by Zone

Green Bay Zone Remediation Alternative 125 250

Action Level (ppb)

500 1,000 5,000 RA01 SWQ

Maximum Action Level that Meets Risk Reduction Criteria Related to Project RAOs

RAO 3 RA0~4 Eco Transport

RAO 2 HH

Green Bay Zone 2

Green Bay Zone 3A

Green Bay Zone SB

Green Bay Zone 4

ImpacLed Volume (cy) PCB Mass (kg) Remedial Cost (in 1,000s $)

A/B: No Action C: Dredge. Off-site Disp. D: Dredge to CDF. Off-sice TSCA Disp. G: Dredge to CAD

Impacted Volume (cy) I'CB Mass (kg) Reinedial Cost (in 1,000s $)

A/B: No Action C: Dredge, Off-site Disp. D: Dredge to CDF, Off-site TSCA Disp. G: Dredge to CAD

Impacted Volume (cy) PCB Mass (kg) Remedial Cost (in 1,000s $)

A/B: No Action D: Dredge to CDF, Off-site TSCA Disp. G: Dredge to CAD

Impacted Volume (cy) PCB Mass (kg) Remedial Cost (in l,(X)Os $)

A/B: No Action

NE NE

NA NA NA NA

NE NE

NA NA NA NA

NE NE

NA NA NA

NE NE

NE NE

NA NA NA NA

NE NE

NA NA NA NA

NE NE

NA NA NA

NE NE

29,748,004 29,896

$9,900 NA

$824,700 $707,400

16,328,102 2,156

$9,900 NA

$474,300 $389,100

43,625,096 4.818

$9,900 $1,155,100 $1,010,900

0 0

29.322,254 29.768

$9,900 NA

$814,100 $697,800

14,410 2

$9,900 $11,000

NA NA

NE NE

NA NA NA

NE NE

4,070,170 6,113

$9,900 $507,200 $166,500 $124,000

NE NE

NA NA NA NA

NE NE

NA NA NA

NE NE

•®2

NE

© ©

NA

NE NA

NE

NE

NA NA $9,900 NA NA

NA

NA

Notes: Threshold criteria used to evaluate risk reduction:

RAO 1 : 1 = Wildlife Criteria 30-year, 2 - Human Surface Water Drinking Criteria 30-year. 1 = High-intake Fish Consumer Cancer 30-year, 2 = High-intake Fish Consumer Noncancer 30-year,

3 = Recreational Angler Cancer 10-year. 4 = Recreational Angler Noncancer 10-year. 1 = Carnivorous Bird Deforirtity NOAEC 30-year. 2 = Piscivorous Mammal NOAEC 30-year. I = Tributary Load to Reach Green Bay Level 30-year.

RAO 2:

RAO 3: RAO 4:

NA - Not applicable. NE - Not evaluated.

Action Level (ppb) that Consistently Meets Criteria after 10 or 30 Years of Recovery after Remediation Completion

^ ^ ^ ^ ^ ^ ^ d ^ H C^riieria Never

Mel after 30 Years

[ ^ | 250 | 500 1.000 5.0001 No Action Taken

Figure 4 Comparison of Human Health Protectiveness - All Reaches

Human Health (Recreational Angler, Noncancer) (288 Mg/kg RME, HI = 1.0)

Little Lake Butte des

Morts

Appleton to Little Rapids De Pere to

Little Rapids to De Pere Green Bay

Reach

10-year Criteria

Human Health (High-intake Fish Consumer, Noncancer) (181 Mg/kg)

120 ^

Little Lake

Butte des

Morts

Appleton to

Little Rapids

Little Rapids

to De Pere

De Pere to Green Bay

Reach

-No Action

•125

•250

•500

•1,000

•5,000

— 30-year Criteria

Human Health (Recreational Angler, Cancer)

(106 Mg/kg RME 10'^)

Human Health (High-intake Fish Consumer, Cancer) (71 MQ/kg)

Little Lake

Butte des Morts

Appleton to Little Rapids De Pere to

Little Rapids to De Pere Green Bay

Reach

10-year Criteria


Morts

Appleton to

Little Rapids

Little Rapids to De Pere

Reach

Figure 5 Comparison of Protection - All Reaches

Wildlife Surface Water (Human Health Surface Water Is Never Met)

120

Little Lake Appleton to Little Rapids De Pere to Butte des Little Rapids to De Pere Green Bay

Morts Reach

Ecological Risk (Based on Bird Deformity) (121 Mg/kg NOAEC)

120


Morts

Appleton to Little Rapids De Pere to Little Rapids to De Pere Green Bay

Reach

- ^ No Action

125

# 250

• 500

A 1,000

• 5.000

30-year

Criteria

Ecological Risk (Based on Piscivorous Mammal) (50 Mg/kg NOAEC)

120

100 0)

S

i 80 in

£ £ 60


Morts

Appleton to Little Rapids De Pere to Little Rapids to De Pere Green Bay

Reach

30-year Criteria


[THIS PAGE LEFT INTENTIONALLY BLANK ]

I

Executive Summaty xii

I Table of Contents

I

1 Introduction 1 1 I 1 Site Description 1 2 1 2 Feasibility Study Process 1 3

1 2 1 Summary of the Remedial Investigation Section 2 14 1 2 2 Summary of the Baseline Human Health and Ecological

Risk Assessment Section 3 14 1 2 3 Development of Remedial Action Objectives and General

Response Actions Section 4 15 12 4 Development of PCB Action Levels for the Lower Fox

River and Green Bay Section 5 1 6 1 2 5 Identification and Screening of Technologies Section 6 1 6 12 6 Reach specific Remedial Alternatives Section 7 16 1 2 7 Alternative specific Risk Assessment Section 8 1 7 1 2 8 Detailed Analysis of Remedial Alternatives Section 9 17 1 2 9 Comparative Analysis of Alternatives Section 10 18 12 10 References Section 11 19

1 3 Application of NRC Findings and Recommendations 1 9 1 4 Section 1 Figures 1 10

2 Remedial Investigation Summary 2 1 2 1 Environmentai Setting and Background 2 1

2 1 1 Lower Fox River Setting 2 1 2 1 2 Green Bay 2 2 2 1 3 Site History 2 3 2 1 4 Current Land Use 2 3

2 2 Physical Characteristics 2 4 2 2 1 Geologic Characteristics 2 5 2 2 2 Sediment Grain Size 2 6 2 2 3 Lower Fox River Bathymetry 2 7 2 2 4 Lower Fox River Surface Water Hydrology 2 8 2 2 5 Green Bay Bathymetry 2 12 2 2 6 Green Bay Surface Water Hydrology 2 13 2 2 7 Green Bay and Lower Fox River Ice Cover 2 18 2 2 8 Total Organic Carbon 2 19 2 2 9 Other Physical Parameters 2 19 2 2 10 River and Bay Sediment Dredging 2 20

2 3 Soft Sediment Thickness 2 21 2 3 1 Calculation of Thickness 2 21 2 3 2 Mapping the Occurrence of Sediment 2 21

Table of Contents xiu

Table of Contents

2 4 Nature and Extent of Chemicals of Concern 2 22 2 4 1 Historical Sources of Chemicals of Concern in the Lower

Fox River 2 22 2 4 2 PCB Distribution in Sediments 2 24 2 4 3 Extent of PCB Chemical Impacts 2 28 2 4 4 Extent of Other COPC Impacts 2 32

2 5 Chemical Fate and Transport 2 34 2 5 1 Lower Fox River Sediment Deposition 2 34 2 5 2 Green Bay Sediment Deposition 2 36 2 5 3 PCB Transport 2 37

2 6 Time Trends of Contaminants in Sediment and Fish 2 39 2 6 1 Sediment Methods 2 39 2 6 2 Fish Methods 2 40 2 6 3 Time Trend Results 2 41 2 6 4 Conclusion 2 46

2 7 Section 2 Figures Tables and Plates 2 48

3 Summary of the Baseline Human Health and Ecological Risk Assessment 3 1 3 1 Human Health Risk Assessment 3 3 3 2 Ecological Risk Assessment 3 5

3 2 1 Little Lake Butte des Morts Reach 3 6 3 2 2 Appleton to Little Rapids Reach 3 7 3 2 3 Little Rapids to De Pere Reach 3 7 3 2 4 De Pere to Green Bay Reach (Green Bay Zone 1) 3 8 3 2 5 Green Bay Zone 2 3 8 3 2 6 Green Bay Zone 3A 3 9 3 2 7 Green Bay Zone 3B 3 9 3 2 8 Green Bay Zone 4 3 10 3 2 9 Ecological Risk Summary for PCBs Mercury and DDE 3 10

3 3 Sediment Quality Thresholds 3 11 3 3 1 Human Health SQTs 3 12 3 3 2 Ecological SQTs 3 13

3 4 Section 3 Figures and Tables 3 13

4 Development of Remedial Action Objectives and General Response Actions 4 1 4 1 Media and Chemicals of Concern 4 2

4 1 1 Media of Concern 4 2 4 12 Chemicals of Concern 4 2

XIV Table of Contents I

I I I I I I I I I I I I

Table of Contents

I I I

I I

4 2 Remedial Action Objectives for Lower Fox River and Green Bay 4 3 4 2 1 Surface Water Quality 4 3 4 2 2 Human Health Risks 4 4 4 2 3 Ecological Risks 4 5 4 2 4 Transport of Contaminants to Lake Michigan 4 5 4 2 5 Contaminant Releases During Remediation 4 6

4 3 Applicable or Relevant and Appropriate Requirements (ARARs) and To Be Considered (TBC) Information 4 6 4 3 1 Chemical specific ARARs and TBCs 4 7 4 3 2 Location specific ARARs 4 8 4 3 3 Action specific ARARs 4 8 4 3 4 To Be Considered Information 4 10 4 3 5 Numeric Surface Water and Drinking Water TBCs 4 11

4 4 Development of General Response Actions (GRAs) 4 11 4 4 1 Description of GRAs 4 12 4 4 2 Summary of GRAs and Expectations 4 13

4 5 Section 4 Tables 4 14

5 Development of PCB Action Levels for the Lower Fox River and Green Bay 5 1 5 1 Rationale 5 2

5 1 1 Array of SQTs 5 3 5 1 2 Array of Action Levels 5 3

5 2 Procedures for Estimating Sediment Volume Mass and SWAC 5 4 5 3 Lower Fox River Results 5 5 5 4 Green Bay Results 5 6 5 5 Selection of Action Levels for Evaluation of Remedial Alternatives 5 7 5 6 Section 5 Figures and Tables 5 7

6 Identification and Screening of Technologies 6 1 6 1 Identification of Technologies 6 2 6 2 Screening of Technologies 6 3

6 2 1 Screening Criteria 6 3 6 2 2 Screening Process 6 5

6 3 Results of Technology Screening 6 5 6 3 1 No Action 6 5 6 3 2 Institutional Controls 6 6 6 3 3 Monitored Natural Recovery 6 6 6 3 4 Containment 6 6

Table of Contents xv

Table of Contents

6 3 5 Removal 6 7 6 3 6 In situ Treatment 6 7 6 3 7 Ex situ Treatment 6 8 6 3 8 Disposal 6 8 6 3 9 Ancillary Technologies 6 8 6 3 10 Monitoring 6 9

6 4 Description and Selection of Retained Process Options 6 9 6 4 1 No Action 6 9 6 4 2 Institutional Controls 6 10 6 4 3 Monitored Natural Recovery 6 11 6 4 4 Containment 6 21 6 4 5 Removal 6 28 6 4 6 In situ Treatment 6 42 6 4 7 £r 5itM Treatment 6 42 6 4 8 Disposal Process Options 6 48

6 5 Identification of Ancillary Technologies 6 57 6 5 1 Dewatering 6 58 6 5 2 Wastewater Treatment 6 64 6 5 3 Residuals Management and Disposal 6 67 6 5 4 Transportation 6 68 6 5 5 Water Quality Management 6 69

6 6 Monitoring 6 70 6 6 1 Baseline Monitoring 6 71 6 6 2 Implementation Monitoring 6 71 6 6 3 Verification Monitoring 6 71 6 6 4 Operation and Maintenance Monitoring 6 71 6 6 5 Long term Monitoring 6 72

6 7 Section 6 Figures and Tables 6 72

7 Reach specific Remedial Alternatives 7 1 7 1 Basis for Selection of Remedial Alternatives 7 2

7 1 1 Generic Remedial Alternatives 7 2 7 1 2 Retained Action Levels 7 5 7 1 3 Physical and Capacity Limitations 7 5 7 1 4 Summary of Selected Remedial Alternatives 7 6 7 1 5 Basis for Costs 7 6 7 16 Section 7 1 Figures and Tables 7 7

7 2 Little Lake Butte des Morts Reach 7 21

XVI Table of Contents

I I

I I I

Table of Contents

I

7 2 1 General Site Characteristics 7 21 7 2 2 Selected Remedial Alternatives 7 22 7 2 3 Description of Process Options 7 23 7 2 4 Development of Alternatives and Associated Costs 7 30 7 2 5 Section 7 2 Figures and Tables 7 42

7 3 Appleton to Little Rapids Reach 7 59 7 3 1 General Site Characteristics 7 59 7 3 2 Selected Remedial Alternatives 7 60 7 3 3 Description of Process Options 7 60 7 3 4 Development of Alternatives and Associated Costs 7 66 7 3 5 Section 7 3 Figures and Tables 7 73

7 4 Little Rapids to De Pere Reach 7 83 7 4 1 General Site Characteristics 7 83 7 4 2 Selected Remedial Alternatives 7 84 7 4 3 Description of Process Options 7 84 7 4 4 Development of Alternatives and Associated Costs 7 91 7 4 5 Section 7 4 Figures and Tables 7 106

7 5 De Pere to Green Bay Reach (Green Bay Zone 1) 7 119 7 5 1 General Site Characteristics 7 119 7 5 2 Selected Remedial Alternatives 7 120 7 5 3 Description of Process Options 7 120 7 5 4 Development of Alternatives and Associated Costs 7 129 7 5 5 Section 7 5 Figures and Tables 7 145

7 6 Green Bay Zone 2 7 163 7 6 1 General Site Characteristics 7 163 7 6 2 Selected Remedial Alternatives 7 163 7 6 3 Description of Process Options 7 164 7 6 4 Development of Alternatives and Associated Costs 7 170 7 6 5 Section 7 6 Figures and Tables 7 178

7 7 Green Bay Zone 3A 7 187 7 7 1 General Site Charactenstics 7 187 7 7 2 Selected Remedial Alternatives 7 187 7 7 3 Description of Process Options 7 188 7 7 4 Development of Alternatives and Associated Costs 7 194 7 7 5 Section 7 7 Figures and Tables 7 202

7 8 Green Bay Zone 3B 7 207 7 8 1 General Site Characteristics 7 207 7 8 2 Selected Remedial Alternatives 7 207

Table of Contents xvii

Table of Contents I

7 8 3 Description of Process Options 7 8 4 Development of Alternatives and Associated Costs 7 8 5 Section 7 8 Figures and Tables

7 9 Green Bay Zone 4 7 9 1 General Site Characteristics 7 9 2 Selected Remedial Alternatives 7 9 3 Description of Process Options 7 9 4 Development of Alternatives and Associated Costs 7 9 5 Section 7 9 Table

7 208 7 210 7 215 7 221 7 221 7 221 7 222 7 222 7 224

8 Alternative specific Risk Assessment 8 1 8 1 Remedial Action Objectives 8 2 8 2 Lower Fox River/Green Bay Modeling 8 6

8 2 1 Whole Lower Fox River Model (wLFRM) 8 7 8 2 2 Enhanced Green Bay Toxics(GBTOXe) Model 8 7 8 2 3 Fox River Food (FRFood) Model 8 8 8 2 4 Green Bay Food (GBFood) Model 8 9

8 3 Description of Detailed Analysis Process 8 9 8 3 1 Lower Fox River and Green Bay Total PCB Residual Risk

Evaluation 8 9 8 3 2 Non PCB COC Residual Risk Evaluation 8 10

8 4 Reach and Zone specific Risk Assessment 8 11 8 4 1 Little Lake Butte des Morts 8 13 8 4 2 Appleton to Little Rapids 8 16 8 4 3 Little Rapids to De Pere 8 19 8 4 4 De Pere to Green Bay 8 22 8 4 5 Green Bay Zone 2 8 24 8 4 6 Green Bay Zone 3A 8 26 8 4 7 Green Bay Zone 3B 8 26 8 4 8 Green Bay Zone 4 8 27

8 5 Uncertainty Analysis 8 28 8 6 Section 8 Figures and Tables 8 29

9 Detailed Analysis of Remedial Alternatives 9 1 9 1 Description of the Detailed Analysis Process 9 1 9 2 Threshold Criteria 9 2

9 2 1 Overall Protection of Human Health and the Environment 9 2 9 2 2 Compliance with ARARs and TBCs 9 4

XVlll Table of Contents

I I I I I I I I I I I

Table of Contents

I I

I I I

9 2 3 ARARs Applicable to Process Options Included in the Remedial Alternatives for the River and Bay 9 12

9 3 Balancing Criteria 9 15 9 3 1 Long term Effectiveness and Pemianence 9 16 9 3 2 Reduction of Toxicity Mobility or Volume Through

Treatment 9 16 9 3 3 Short term Effectiveness 9 16 9 3 4 Implementability 9 17 9 3 5 Total Cost 9 18

9 4 Community and Regulatory Acceptance 9 18 9 5 Detailed Analysis of Remedial Alternatives for the Lower Fox

River and Green Bay 9 20 9 5 1 Alternative A No Action 9 20 9 5 2 Alternative B Monitored Natural Recovery and

Institutional Controls 9 21 9 5 3 Alternative C Dredge and Off site Disposal 9 22 9 5 4 Alternative D Dredge and CDF Disposal 9 27 9 5 5 Alternative E Dredge and Ex situ Thermal Treatment 9 28 9 5 6 Alternative F Cap to the Maximum Extent Possible 9 29 9 5 7 Alternative G Dredge to CAD Site 9 31

9 6 Summary of Detailed Analysis 9 32 9 7 Section 9 Figure and Tables 9 33

10 Comparative Analysis of Alternatives 10 1 10 1 Descnption of Comparative Analysis Process 10 1 10 2 Summary of Alternatives 10 5 10 3 Comparative Analysis of Alternatives Little Lake Butte des

Morts Reach 10 7 10 4 Comparative Analysis of Alternatives Appleton to Little Rapids

Reach 10 9 10 5 Comparative Analysis of Alternatives Little Rapids to De Pere

Reach 10 11 10 6 Comparative Analysis of Alternatives De Pere to Green Bay

Reach 10 13 10 7 Comparative Analysis of Alternatives Green Bay All Zones 10 15 10 8 Comparative Analysis of Actions Levels on a System wide Basis 10 16 10 9 Comparative Analysis Summary 10 18 10 10 Section 10 Figures and Tables 10 21

Table of Contents xix

Table of Contents

11 References 11 1

I I I

I I I I

XX Table of Contents

I I I I I I I I I I

List of Figures

I I I I

I I

Figure 1 1 Lower Fox River Study Area 1 11 Figure 1 2 Green Bay Study Area 1 12 Figure 1 3 Overview of Feasibility Study Process 1 13 Figure 2 1 Little Lake Butte des Morts Reach 2 51 Figure 2 2 Appleton to Little Rapids Reach 2 52 Figure 2 3 Little Rapids to De Pere Reach 2 53 Figure 2 4 De Pere to Green Bay Reach 2 54 Figure 2 5 Soft Sediment Thickness (m) and Bathymetry (ft) Little Lake

Butte des Morts 2 55 Figure 2 6 Soft Sediment Thickness (m) and Bathymetry (ft) Appleton to

Little Rapids 2 56 Figure 2 7 Soft Sediment Thickness (m) and Bathymetry (ft) Little Rapids

to De Pere 2 57 Figure 2 8 Soft Sediment Thickness (m) and Bathymetry (ft) De Pere to

Green Bay 2 58 Figure 2 9 Soft Sediment Thicloiess (cm) and Bathymetry (m) Green Bay 2 59 Figure 2 10 Lower Fox River Elevation Profile 2 60 Figure 2 11 Green Bay Monthly Mean Bottom Circulation—July 1989 2 61 Figure 2 12 Green Bay Monthly Mean Bottom Circulation—^August 1989 2 62 Figure 2 13 Estimated Annual Sediment Transport Rates and Stream Flow

Velocities 2 63 Figure 2 14 Lower Fox River and Green Bay System Estimated PCB Mass and

Major PCB Flux Pathways 2 64 Figure 2 15 Time Trends of PCBs in Sediments for Depths from 0 to 10 cm

and from 10 to 30 cm 2 65 Figure 2 16 Time Trends of PCBs in Sediments for Depths from 30 to 50 cm

and from 50 to 100 cm 2 66 Figure 2 17 Time Trends of PCBs in Sediments for Depths over 100 cm 2 67 Figure 3 1 Maximum Cancer Risks for Recreational Anglers and High intake

Fish Consumers 3 15 Figure 3 2 Maximum Hazard Indices for Recreational Anglers and High

intake Fish Consumers 3 16 Figure 3 3 Selected Mercury HQs that Exceed 10 3 17 Figure 3 4 Selected PCB HQs that Exceed 1 0 for Little Lake Butte des

Morts Appleton to Little Rapids and Little Rapids to De Pere Reaches 3 18

Figure 3 5 Selected PCB HQs that Exceed 1 0 for Green Bay Zones 1 2 3A 3B and 4 3 19

Figure 3 6 Selected DDT or Metabolite HQs that Exceed 10 3 20

Table of Contents xxi

List of Figures

Figure 5 1 Action Levels and Sediment Quality Thresholds for Human Health 5 9

Figure 5 2 Action Levels and Sediment Quality Thresholds for Ecological Health 5 10

Figure 5 3 Total Sediment Volume versus Action Level by Reach in the Lower Fox River 5 11

Figure 5 4 Total PCB Mass versus Action Level by Reach in the Lower Fox River 5 12

Figure 5 5 Total PCB Mass versus Sediment Volume by Reach in the Lower Fox River 5 13

Figure 5 6 Residual SWAC versus Action Level by Reach in the Lower Fox River 5 14

Figure 5 7 Total Sediment Volume versus Action Level by Zone in Green Bay 5 15

Figure 5 8 Total PCB Mass versus Action Level by Zone in Green Bay 5 16 Figure 5 9 Total PCB Mass versus Sediment Volume by Zone in Green Bay 5 17 Figure 5 10 SWAC versus Action Level by Zone in Green Bay 5 18 Figure 6 1 Examples of Armored Caps 6 75 Figure 6 2 Examples of Mechanical Dredges 6 76 Figure 6 3 Typical Mechanical Dredge Operations 6 77 Figure 6 4 Examples of Hydraulic Dredges 6 78 Figure 6 5 Conceptual Hydraulic Dredging to Dewatering Pond 6 79 Figure 6 6 Conceptual Layout of a Gravity Dewatering Pond 6 80 Figure 6 7 Cross Section of Confined Aquatic Disposal 6 81 Figure 6 8 General Landfill Location Map 6 82 Figure 6 9 Cross Section of Cellular Cofferdam CDF 6 83 Figure 6 10 Plan View of Waste Cellular Cofferdam CDF 6 84 Figure 7 1 Lower Fox River Cleanup Alternative Process Dredge and Off

site Disposal 7 9 Figure 7 2 Lower Fox River Cleanup Alternative C2A Process Dredge and

Offsite Disposal 7 10 Figure 7 3 Lower Fox River Cleanup Alternative C2B Process Dredge and

Off site Disposal 7 11 Figure 7 4 Lower Fox River Cleanup Alternative C3 Process Dredge and

Off site Disposal 7 12 Figure 7 5 Lower Fox River Cleanup Alternative Process Dredge and

Disposal to Confined Disposal Facility (Non TSCA Sediments) Off site Disposal of TSCA Sediments 7 13

XXll Table of Contents

I I


List of Figures

Figure 7 6 Lower Fox River Cleanup Alternative Process Dredge and Vitnfication 7 14

Figure 7 7 Lower Fox River Cleanup Alternative Process In situ Sediment Capping 7 15

Figure 7 8 Lower Fox River Cleanup Alternative Process Sediment Cap and Partial Dredge Remaining Sediments 7 16

Figure 7 9 Sediment Management Area Overview Little Lake Butte des Morts 7 45

Figure 7 10 Preliminary Concept Design for the Arrowhead Confined Disposal Facility 7 46

Figure 7 11 Preliminary Concept Design for the Menasha Confined Disposal Facility 7 47

Figure 7 12 Process Flow Diagram for Little Lake Butte des Morts Alternative Cl Dredge Sediment with Off site Disposal 7 48

Figure 7 13 Process Flow Diagram for Little Lake Butte des Morts Alternative C2 Dredge Sediment with Off site Disposal 7 49

Figure 7 14 Alternative C Dredge and Off site Disposal Little Lake Butte des Morts 7 50

Figure 7 15 Process Flow Diagram for Little Lake Butte des Morts Alternative D Dredge Sediment CDF and Off site Disposal 7 51

Figure 7 16 Alternative D Dredge Sediment to Confined Disposal Facility Little Lake Butte des Morts 7 52

Figure 7 17 Process Flow Diagram for Little Lake Butte des Morts Alternative E Dredge Sediment with Thermal Treatment 7-53

Figure 7 18 Alternative E Dredge with Thermal Treatment Little Lake Butte des Morts 7 54

Figure 7 19 Process Flow Diagram for Little Lake Butte des Morts Alternative F Cap Sediment to Maximum Extent Possible Dredge to CDF and Off site Disposal 7 55

Figure 7 20 Alternative F Cap to Maximum Extent Possible and Dredge Remaining Sediment to CDF Little Lake Butte des Morts 7 56

Figure 7 21 Sediment Management Area Overview Appleton to Little Rapids 7 75 Figure 7 22 Process Flow Diagram for Appleton to Little Rapids Alternative

C Dredge Sediment with Off site Disposal 7 76 Figure 7 23 Alternative C Dredge Sediment to Off site Disposal Appleton

to Little Rapids 7 77 Figure 7 24 Process Flow Diagram for Appleton to Little Rapids Alternative

E Dredge Sediment with Thermal Treatment 7 78

Table of Contents xxui

List of Figures

Figure 7 25 Alternative E Dredge Sediment and Treatment Using Thermal Treatment Appleton to Little Rapids 7 79

Figure 7 26 Sediment Management Area Overview Little Rapids to De Pere 7 107 Figure 7 27 Process Flow Diagram for Little Rapids to De Pere Alternative

Cl Dredge Sediment with Off site Disposal 7 108 Figure 7 28 Process Flow Diagram for Little Rapids to De Pere Alternative

C2A Dredge with Combined Dewatering and Disposal Facility 7 109 Figure 7 29 Process Flow Diagram for Little Rapids to De Pere Alternative

C2B Dredge with Separate Dewatenng and Disposal Facility 7 110 Figure 7 30 Process Flow Diagram for Little Rapids to De Pere Alternative

C3 Dredge Sediment with Off site Disposal 7 111 Figure 7 31 Alternatives C D and E Little Rapids to De Pere 7 112 Figure 7 32 Process Flow Diagram for Little Rapids to De Pere Alternative

D Dredge Sediment to CDF 7 113 Figure 7 33 Process Flow Diagram for Little Rapids to De Pere Alternative E

Dredge Sediment with Thermal Treatment 7 114 Figure 7 34 Process Flow Diagram for Little Rapids to De Pere Alternative F

Cap Sediment to Maximum Extent Possible Dredge and Off site Disposal 7 115

Figure 7 35 Alternative F Cap to Maximum Extent Possible and Dredge Remaining Sediment to CDF Little Rapids to De Pere 7 116

Figure 7 36 Sediment Management Area Overview De Pere to Green Bay 7 147 Figure 7 37 Preliminary Concept Design for the De Pere Confined Disposal

Facility 7 148 Figure 7 38 Process Flow Diagram for De Pere to Green Bay Alternative Cl

Dredge with Disposal at an Existing NR 500 Commercial Disposal Facility (Passive Dewatering) 7 149

Figure 7 39 Process Flow Diagram for De Pere to Green Bay Alternative C2A Dredge wath Combined Dewatering and Disposal Facility 7 150

Figure 7 40 Process Flow Diagram for De Pere to Green Bay Alternative C2B Dredge Combined Dewatenng and Disposal Facility 7 151

Figure 7 41 Process Flow Diagram for De Pere to Green Bay Alternative C3 Dredge Sediment with Off site Disposal 7 152

Figure 7 42 Alternative C Dredge and Off site Disposal De Pere to Green Bay 7 153

Figure 7 43 Process Flow Diagram for De Pere to Green Bay Alternative D I Dredge Sediment CDF and Off site Disposal 7 154

I XXIV Table of Contents

I I I I

List of Figures

Figure 7 44 Alternative D Dredge Sediment to Confined Disposal Facility De Pere to Green Bay 7 155

Figure 7 45 Process Flow Diagram for De Pere to Green Bay Alternative E Dredge Sediment with Thermal Treatment 7 156

Figure 7 46 Alternative E Dredge with Thermal Treatment De Pere to Green Bay 7 157

Figure 7 47 Process Flow Diagram for De Pere to Green Bay Alternative F Cap Sediment to Maximum Extent Possible Dredge CDF and Offsite Disposal 7 158

Figure 7 48 Alternative F Cap to Maximum Extent Possible and Dredge Remaining Sediment to CDF De Pere to Green Bay 7 159

Figure 7 49 Sediment Management Area Overview Green Bay 7 179 Figure 7 50 Preliminary Concept Design for the Green Bay Confined Disposal

Facility Cat Island Cham 7 180 Figure 7 51 Process Flow Diagram for Green Bay Zone 2 Alternative C

Dredge Sediment and Off site Disposal 7 181 Figure 7 52 Alternatives C D and G Zones 2 and 3 Green Bay 7 182 Figure 7 53 Process Flow Diagram for Green Bay Zone 2 Alternatives D

andG Dredge Sediment to CDF/CAD 7 183 Figure 7 54 Process Flow Diagram for Green Bay Zone 3A Alternative C

Dredge Sediment and Off site Disposal 7 203 Figure 7 55 Process Flow Diagram for Green Bay Zone 3A Alternatives D

and G Dredge Sediment to CDF/CAD 7 204 Figure 7 56 Process Flow Diagram for Green Bay Zone 3B Alternatives D

and G Dredge Sediment to CDF/CAD 7 217 Figure 8 1 Surface Sediment Total PCB and Mercury Distnbution Little

Lake Butte des Morts Reach 8 33 Figure 8 2 Surface Sediment Total PCB and DDE Distribution Little Lake

Butte des Morts Reach 8 34 Figure 8 3 Surface Sediment Total PCB and Mercury Distnbution

Appleton to Little Rapids Reach 8 35 Figure 8 4 Surface Sediment Total PCB and DDE Distribution Appleton to

Little Rapids Reach 8 36 Figure 8 5 Surface Sediment Total PCB and Mercury Distnbution Little

Rapids to De Pere Reach 8 37 Figure 8 6 Surface Sediment Total PCB and DDE Distribution Little

Rapids to De Pere Reach 8 38

Table of Contents xxv

List of Figures

Figure 8 7 Surface Sediment Total PCB and Mercury Distribution De Pere to Green Bay Reach 8 39

Figure 8 8 Surface Sediment Total PCB and DDE Distribution De Pere to Green Bay Reach 8 40

Figure 8 9 Surface Sediment PCB and Mercury Distribution in Green Bay 8 41 Figure 8 10 Surface Sediment PCB and DDE Distribution in Green Bay 8 42 Figure 9 1 Criteria for Detailed Analyses of Alternatives 9 35 Figure 10 1 Comparison of Human Health and Ecological Protectiveness

Little Lake Butte des Morts to Appleton Reach 10 23 Figure 10 2 Comparison of Cleanup Duration Mass Removal and Cost

Little Lake Butte des Morts 10 24 Figure 10 3 Comparison of Human Health and Ecological Protectiveness

Appleton to Little Rapids Reach 10 25 Figure 10 4 Comparison of Cleanup Duration Mass Removal and Cost

Appleton to Little Rapids Reach 10 26 Figure 10 5 Comparison of Human Health and Ecological Protectiveness

Little Rapids to De Pere Reach 10 27 Figure 10 6 Comparison of Cleanup Duration Mass Removal and Cost

Little Rapids to De Pere Reach 10 28 Figure 10 7 Comparison of Human Health and Ecological Protectiveness

De Pere to Green Bay Reach 10 29 Figure 10 8 Comparison of Cleanup Duration Mass Removed and Cost

De Pere to Green Bay Reach (Green Bay Zone 1) 10 30 Figure 10 9 Comparison of Cleanup Duration Mass Removal and Cost

Green Bay Zone 2 10 31 Figure 10 10 Comparison of Cleanup Duration Mass Removal and Cost

Green Bay Zone 3A 10 32 Figure 10 11 Comparison of Cleanup Duration Mass Removal and Cost

Green Bay Zone 3B 10 33 Figure 10 12 Comparison of Human Health Protectiveness All Reaches 10 34 Figure 10 13 Comparison of Protection All Reaches 10 35 Figure 10 14 Total PCB Sediment Loading for All Remedial Action Levels

De Pere to Green Bay Reach 10 36

I I I

XXVI Table of Contents

I List of Tables

I I

Table 2 1 Table 2 2 Table 2 3 Table 2 4 Table 2 5 Table 2 6

Table 2 7 Table 2 8 Table 2 9

Table 2 10

Table 2 11 Table 2 12

Table 3 1 Table 3 2

Table 3 3 Table 4 1

Table 4 2

Table 4 3


Table 5 2 Table 5 3


Physical Characteristics of the Lower Fox River Physical Charactenstics of Green Bay Land Use Classification for Counties Bordering Green Bay Lower Fox River Gradient and Lock/Dam Information Lower Fox River Stream Velocity Estimates Lower Fox River Discharge Results Rapide Croche Gauging Station Lower Fox River and Green Bay Maximum PCB Sampling Depth Lower Fox River Mouth Gauging Station Results (1989-1997) Total Suspended Solid (TSS) Loads from the Lower Fox River into Green Bay Results of Sediment Time Trends Analysis on the Lower Fox River Results of Fish Time Trends Analysis on the Lower Fox River Mass weighted Combined Time Trend for 0 to 10 cm Depth by Reach Ecological Risk Summary Table Sediment Quality Thresholds Estimated for Human Health Effects at a 10^ Cancer Risk and a Noncancer Hazard Index of 1 0 Sediment Quality Thresholds Estimated for Ecological Effects Remedial Action Objectives for the Lower Fox River and Green Bay Potential Federal ARARs and TBCs for the Lower Fox River and Green Bay Potential State ARARs and TBCs for the Lower Fox River and Green Bay Surface Water Quality Criteria Remediation Goals and Project Expectations Procedure for Computing PCB Mass Removed by Dredging Sediments above Selected Action Levels Procedure for Computing SWAC for Selected Action PCB Mass and Sediment Volume by Action Level—Lower Fox River SWAC Based on Action Levels—Lower Fox River PCB Mass Volume and SWAC—Green Bay Guidance and Literature Resources Used to Develop the List of Potentially Applicable Technologies for Cleanup of the Lower Fox River and Green Bay

2 69 2 71 2 72 2 73 2 74

2 75 2 76 2 77

2 78

2 79 2 80

2 81 321

3 22

3 23

4 15

4 16

4 18 4 22 4 23

5 19 5 20

5 21 5 23 5 24

6 85

Table of Contents XXVll

List of Tables

Table 6 2 Summary of Technologies Reviewed and Retained 6 86 Table 6 3 Description of Potential Remedial Technologies 6 88 Table 6 4 Screening of Potential Remedial Technologies No Action

Containment and Removal 6 92 Table 6 5 Screening of Potential Remedial Technologies Treatment 6 95 Table 6 6 Screening of Potential Remedial Technologies Disposal 6 101 Table 6 7 Ancillary Technologies 6 103 Table 6 8 Deposit N Demonstration Project Summary 6 106 Table 6 9 SMU 56/57 Demonstration Project Summary 6 107 Table 6 10 Summary of Selected Wisconsin Landfills Within Approximately

40 Miles of the Lower Fox River 6 109 Table 6 11 Sediment Melter Demonstration Project Summary 6 110 Table 7 1 Summary of Selected Generic Remedial Alternatives 7 17 Table 7 2 Volume Allocation Table 7 18 Table 7 3 PCB Mass Allocation Table 7 19 Table 7 4 Physical Capacity and Process Limitations 7 20 Table 7 5 Cost Summary for Remedial Alternatives Little Lake Butte des

Morts 7 57 Table 7 6 Cost Summary for Remedial Alternatives Appleton to Little

Rapids 7 81 Table 7 7 Cost Summary for Remedial Alternatives Little Rapids to

De Pere 7 117 Table 7 8 Cost Summary for Remedial Alternatives De Pere to Green Bay

(Green Bay Zone 1) 7 161 Table 7 9 Cost Summary for Remedial Alternatives Green Bay Zone 2 7 185 Table 7 10 Cost Summary for Remedial Alternatives Green Bay Zone 3A 7 205 Table 7 11 Cost Summary for Remedial Alternatives Green Bay Zone 3B 7 219 Table 7 12 Cost Summary for Remedial Alternatives Green Bay Zone 4 7 225 Table 8 1 Relationship of Models Used for Risk Projections in the Lower

Fox River or Green Bay 8 43 Table 8 2 Whole Body Fish Tissue Concentrations Estimated for Human

Health Effects at a 10 Cancer Risk and a Hazard Index of 1 0 8 44 Table 8 3 No Action Non interpolated Sediment Concentrations of Total

PCBs Oug/lcg) 8 45 Table 8 4 No Action Sediment Concentrations of Mercury and

DDT/DDD/DDE 8 46 Table 8 5 Projected Surface Water Concentrations RAO 1 8 47 I

I XXVlll Table of Contents

List of Tables

I I I

Table 8 6 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Little Lake Butte des Morts Reach 8 48

Table 8 7 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Appleton to Little Rapids Reach 8 49

Table 8 8 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Little Rapids to De Pere Reach 8 50

Table 8 9 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) De Pere to Green Bay Reach 8 51

Table 8 10 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Green Bay Zone 2 8 52

Table 8 11 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Green Bay Zone 3A 8 54

Table 8 12 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Green Bay Zone 3B 8 56

Table 8 13 Remedial Action Levels and Attainment of Human Health and Ecological Thresholds (Years until Thresholds Are Met) Green Bay Zone 4 8 58

Table 8 14 RAO 2 Years to Reach Human Health Thresholds for Lower Fox River Remedial Action Levels 8 60

Table 8 15 RAO 2 Years to Reach Human Health Thresholds for Green Bay Remedial Action Levels 8 61

Table 8 16 RAO 3 Years to Reach Ecological Thresholds for Lower Fox River Remedial Action Levels 8 62

Table 8 17 RAO 3 Years to Reach Ecological Thresholds for Green Bay Remedial Action Levels 8 63

Table 8 18 RAO 4 Sediment Loading Rates 30 Years Post remediation (kg/yr) 8 64

Table 9 1 Detailed Analysis of Alternatives Summary Little Lake Butte des Morts 9 37

Table 9 2 Detailed Analysis of Remedial Alternatives Summary Appleton to Little Rapids Reach 9 39

Table of Contents xxix

List of Tables

Table 9 3 Detailed Analysis of Alternatives Summary Little Rapids to De Pere Reach

Table 9 4 Detailed Analysis of Alternatives Summary De Pere to Green Bay Reach (Green Bay Zone 1)

Table 9 5 Detailed Analysis of Alternatives Summary Green Bay Zone 2 Table 9 6 Detailed Analysis of Alternatives Summary Green Bay Zone 3A Table 9 7 Detailed Aiialysis of Alternatives Summary Green Bay Zone 3B Table 9 8 Detailed Analysis of Alternatives Summary Green Bay Zone 4 Table 10 1 Comparative Evaluation Measures Table 10 2 Summary of Remedial Costs and Risk Reduction for Lower Fox

River Remedial Alternatives Table 10 3 Summary of Remedial Costs and Risk Reduction for Green Bay

Remedial Alternatives

9 4 1

9 43 9 45 9 47 9 49 951 10 37

10 40

1041

XXX Table of Contents

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List of Plates

Plate 2 1 Interpolated PCB Distribution in Sediments Little Lake Butte des Morts Reach 2 83

Plate 2 2 Interpolated PCB Distribution in Sediments Appleton to Little Rapids Reach 2 84

Plate 2 3 Interpolated PCB Distribution in Sediments Little Rapids to De Pere Reach 2 85

Plate 2 4 Interpolated PCB Distribution in Sediments De Pere to Green Bay Reach 2 86

Plate 2 5 Interpolated PCB Distnbution in Sediments Green Bay 2 87

Table of Contents xxxi

Final Feasihdity Study

[THIS PAGE LEFT INTENTIONALLY BLANK ]

xxxii Table of Contents I

I I I I

List of Appendices

I I

Appendix A Summary of Previous Remedial Action Objectives

Appendix B Sediment Technologies Memorandum

H Appendrx C Long term Monitoring Plan

Appendix D Summary of Capping Projects

Appendix E Wisconsin Disposal Information

Appendix F Dechlorination Memorandum

I Appendix G Glass Aggregate Feasibility Study

_ Appendix H Detailed Cost Estimate Worksheets

I I I I I I I I I I

Table of Contents xxxiii

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9.

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Remedial Investigation Report

Lower Fox River and Green Bay, Wisconsm

Prepared for:

Wisconsin Dept of Natural Resources

Prepared by: The RETEC Group, Inc. Natural Resource Technology, Inc.

December 2002

HS^RETEC ^ • r

4S^RETEC

Remedial Investigation Report

Lower Fox River and Green Bay, Wisconsin

Prepared by:

The RETEC Group, Inc. 413 Wacouta Street, Suite 400 St. Paul, Minnesota 55101-1957

RETEC Project No.: WISCN-14414-345

Natural Resource Technology, Inc. 23713 W. Paul Road, Unit D Pewaukee, Wisconsin 53072

NRT Project No.: 1300

Prepared for:

Wisconsin Department of Natural Resources 101 S. Webster Street Madison, Wisconsin 53707-7921

December 2002

I I I Remedial Investigation Report

I Lower Fox River and H Green Bay, Wssconsin

I

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Prepared by

The RETEC Group, Inc 413 Wacouta Street, Suite 400 St Paul, Minnesota 55101-1957 RETEC Project No WISCN-14414-345

' Natural Resource Technology, Inc l_ 23713 W Paul Road, Unit D I Pewaukee, Wisconsin 53072

NRT Project No 1300

Prepared for

Wisconsin Department of Natural Resources 101 S Webster Street Madison, Wisconsin 53707-7921

Prepared by ^ A X ^ Enc Kovatch Natural Resource Technology Inc

Technically Reviewed by

^

Robert Karnauskas Natural Resource Technology Inc

I i^^j^-T w^T/^--^ Paul Putzier The RETEC Groups' Inc

I December 2002

I I

Table of Contents

Executive Summary XLX

1 Introduction 1 1 1 1 Project Overview and Objectives 1 1 1 2 Study Area Overview 1 2

1 2 1 Lower Fox River 1 2 1 2 2 Green Bay 1 3

1 3 Study Area River Reaches and Bay Zones 1 6 1 3 1 Lower Fox River Reaches 1 6 1 3 2 Green Bay 1 7

1 3 2 1 Green Bay Zones 1 7 1 3 2 2 Inner and Outer Bays 1 8 1 3 2 3 Lower Green Bay 1 8

1 4 Background 1 8 I 4 1 Site History 1 8 1 4 2 Historical PCB Use and Discharges 1 12 1 4 3 Regulatory Response 1 14

1 4 3 1 Clean Water Act 1 14 1 4 3 2 Wisconsin Pollution Discharge Elimination

System 1 14 1 4 3 3 Great Lakes Areas of Concern 1 14

1 5 Application of NRC Findings and Recommendations 1 15 1 6 Section 1 Figures 1 17

2 Database and Investigation Summaries 2 1 2 1 Data Quality Evaluation 2 2 2 2 Sediment Investigations Included in the FRDB 2 3

2 2 1 1989 1990 Fox River Mass Balance Study Data and 1989 1990 Green Bay Mass Balance Study Data 2 3

2 2 2 1994 Woodward Clyde Deposit A Sediment Data 2 6 2 2 3 1992/93 BBL Deposit A Sediment Data 2 6 2 2 4 1993 Tnad Assessment 2 7 2 2 5 1994 GAS/SAIC Sediment Data 2 8 2 2 6 1995 WDNR Sediment Data 2 8 2 2 7 1996 FRG/BBL Sediment/Tissue Data 2 9 2 2 8 Sediment Remediation Demonstration Projects Data 2 9

2 2 8 1 Deposit N Demonstration Project 2 11 2 2 8 2 SMU 56/57 Demonstration Project 2 12

2 2 9 1998 FRG/Exponen t Da ta and 1998 FRG/BBL Sediment/Tissue Data 2 15

I Table of Contents

I

2 2 101998 RETEC RI/FS Supplemental Data 2 15 2 2 11 Lake Michigan Mass Balance Data 2 17 2 2 12 Fox River Fish Consumption Advisory Data 2 17 2 2 13 USGS National Water Quality Assessment Program (NAWQA)

Data 2 17 2 2 141997 WDNR Caged Fish Bioaccumulation Study Data 2 17 2 2 15Minergy Mineralogical Data 2 17

2 3 Ecological Sampling Studies 2 18 2 4 Section 2 Tables 2 19

3 Physical Characteristics 3 1 3 1 Land Use 3 1

3 1 1 Historical Land Use 3 1 3 1 2 Current Land Uses 3 3

3 2 Meteorology 3 5 3 3 Geologic Characteristics 3 6

3 3 1 Regional Geologic Setting 3 7 3 3 11 Bedrock Geology 3 7 3 3 12 Glacial Geology 3 8

3 3 2 Regional Soils 3 9 3 3 3 Hydrogeology 3 11

3 3 3 1 Regional Hydrogeology 3 11 3 3 3 2 Water Use (1995) 3 15

3 4 Lower Fox River Surface Water Hydrology 3 17 3 4 1 Surface Water Flow Controls 3 17

3 4 11 Dams in Wisconsin and on the Lower Fox River 3 17

3 4 12 Lower Fox River Dams and Navigational Controls 3 23

3 4 13 Neenah Menasha (Lake Winnebago) 3 24 3 4 2 Lower Fox River Surface Elevation 3 25 3 4 3 Low Flow and Flood Frequencies 3 26 3 4 4 Measured and Estimated Stream Flow Velocities 3 27 3 4 5 Lower Fox River Bathymetry 3 29

3 4 5 1 LLBdM Reach 3 29 3 4 5 2 Appleton to Little Rapids Reach 3 29 3 4 5 3 Little Rapids to De Pere Reach 3 29 3 4 5 4 De Pere to Green Bay Reach 3 30

11

Table of Contents

3 5 Green Bay Surface Water Hydrology 3 30 3 5 1 Green Bay Water Level Elevations 3 30 3 5 2 Green Bay Water Circulation Currents and Mixing

Patterns 3 31 3 5 2 1 Lower Fox River Discharge into Green Bay 3 33 3 5 2 2 Fox River Plume Studies 3 34 3 5 2 3 Inner Bay/Outer Bay Mixing Studies 3 36 3 5 2 4 Green Bay/Lake Michigan Mixing Studies 3 38

3 5 3 Green Bay Bathymetry 3 39 3 5 3 1 Zone 2 Bathymetry 3 41 3 5 3 2 Zone 3 Bathymetry 3 42 3 5 3 3 Zone 4 Bathymetry 3 43

3 5 4 Green Bay Ice Cover 3 45 3 6 Sediment Characteristics 3 46

3 6 1 Sediment Deposition 3 46 3 6 11 Lower Fox River Sediment Transport and

Deposition 3 46 3 6 12 Green Bay Sediment Transport and Deposition 3 49 3 6 13 River and Bay Sediment Dredging 3 51

3 7

4 Ecological 4 1

4 2

3 6 2 Sediment Grain Size/Lithology 3 6 3 Estimated Sediment Thickness and Areal Extent

3 6 3 1 LLBdM Reach 3 6 3 2 Appleton to Little Rapids Reach 3 6 3 3 Little Rapids to De Pere Reach 3 6 3 4 De Pere to Green Bay Reach 3 6 3 5 Green Bay (Zones 2 through 4)

3 6 4 Total Organic Carbon 3 6 5 Other Physical Parameters Section 3 Figures Tables and Plates

Characteristics Overview 4 1 1 Habitats 4 1 2 Wildlife Groups Wildlife Habitat 4 2 1 Open Lands 4 2 2 Woodlands 4 2 3 Wetlands

3 52 3 53 3 55 3 55 3 55 3 56 3 56 3 56 3 57 3 58

4 1 4 1 4 2 4 3 4 5 4 5 4 6 4 8

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4 2 3 1 Wetland Areas and Types 4 8 4 2 3 2 Wetland Losses 4 14 4 2 3 3 Proposed Wetland Restoration Projects 4 18

4 2 4 Rivenne Habitat of the Lower Fox River 4 20 4 2 5 Lacustrine Habitat of Green Bay 4 22

4 2 5 1 Overview 4 22 4 2 5 2 Inner Bay Water Quality 4 23 4 2 5 3 Outer Bay Water Quality 4 24

4 3 Benthic Communities 4 25 4 4 Fish 4 27

4 4 1 LLBdM to De Pere Dam Fish Surveys 4 27 4 4 2 De Pere to Green Bay/Duck Creek Fish Surveys 4 28 4 4 3 Green Bay Fishery Observations and Habitat 4 30 4 4 4 Life Histories of Fish Species in the Lower Fox River and

Green Bay 4 35 4 4 4 1 Shiners (Minnows) 4 35 4 4 4 2 Gizzard Shad 4 36 4 4 4 3 Rainbow Smelt 4 37 4 4 4 4 Alewife 4 39 4 4 4 5 Yellow Perch 4 41 4 4 4 6 Carp 4 43 4 4 4 7 Walleye 4 45 4 4 4 8 Brown Trout 4 46 4 4 4 9 Sturgeon 4 48

4 5 Birds 4 49 4 5 1 Passenne Birds 4 50 4 5 2 Gulls/Terns 4 51 4 5 3 Diving Birds 4 53 4 5 4 Shorebirds 4 54 4 5 5 Wading Birds 4 55 4 5 6 Waterfowl 4 56 4 5 7 Raptors 4 57

4 6 Mammals 4 59 4 6 1 Mink 4 60

4 6 11 Mink Habitat 4 60 4 6 12 Domestic Mink Production in Wisconsin 4 61 4 6 13 Wild Mink in the Study Area 4 62

4 6 2 Otter 4 62

IV

Table of Contents I I

4 7 4 8

Endangered and Threatened Species Section 4 Figures and Tables

5 Nature and Extent of Detected Chemicals 5 1

5 2

5 3 5 4

Detected Compound Sources 5 1 1 Point Sources

5 1 1 1 Industrial/Municipal Discharges 5 1 1 2 Landfills 5 1 1 3 Spills

5 1 2 Non Point Sources 5 12 1 River and Bay Sediments 5 12 2 Stormwater Runoff 5 12 3 Atmospheric Deposition and Volatilization

Summary of Detected Chemicals 5 2 1 Overview 5 2 2 PCBs 5 2 3 Dioxm/Furan 5 2 4 Pesticides 5 2 5 Inorganic Compounds 5 2 6 TCLP Results 5 2 7 Semi Volatile Organic Compounds (SVOCs) Lake Winnebago (Background) Results Chemical Distribution in Sediments 5 4 1 Overview 5 4 2 PCB Distnbution

5 4 2 1 Bed Maps and Sediment Data Interpolation Methods

5 4 2 2 Lower Fox River and Green Bay PCB Results 5 4 2 3 LLBdM Reach PCB Results 5 4 2 4 Appleton to Little Rapids Reach PCB Results 5 4 2 5 Little Rapids to De Pere Reach PCB Results 5 4 2 6 De Pere to Green Bay Reach PCB Results 5 4 2 7 Green Bay Zone 2 PCB Results 5 4 2 8 Green Bay Zone 3 PCB Results 5 4 2 9 Green Bay Zone 4 PCB Results 5 4 2 10 General PCB Homolog Distnbution

5 4 3 Dioxm/Furans 5 4 4 Pesticides

4 63 4 64

5 1 5 1 5 1 5 1 5 5 5 6 5 7 5 8 5 9

5 11 5 12 5 12 5 14 5 18 5 19 5 19 5 22 5 22 5 23 5 24 5 24 5 25

5 25 531 5 32 5 36 5 40 5 42 5 46 5 48 5 50 5 52 5 55 5 56

V

1

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Table of Contents

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5 4 4 1 LLBdM Reach Results 5 56 5 4 4 2 Appleton to Little Rapids Reach Results 5 57 5 4 4 3 Little Rapids to De Pere Reach Results 5 57 5 4 4 4 De Pere to Green Bay Reach Results 5 57

5 4 5 Inorganic Compounds 5 58 5 4 5 1 Mercury 5 58 5 4 5 2 Lead 5 59 5 4 5 3 Arsenic 5 61

5 4 6 Other Organic Compounds 5 62 5 4 6 1 LLBdM Reach SVOC Results 5 62 5 4 6 2 Appleton to Little Rapids Reach SVOC Results 5 63 5 4 6 3 Little Rapids to De Pere Reach SVOC Results 5 63 5 4 6 4 De Pere to Green Bay Reach SVOC Results 5 64 5 4 6 5 Green Bay SVOC Results 5 64

5 4 7 Other Inorganic Compounds 5 64 5 4 7 1 Cadmium/Chromium 5 64 5 4 7 2 Ammonia 5 65

5 5 Surface Water Sampling Results 5 65 5 5 1 Overview 5 65 5 5 2 PCB Distnbution 5 66

5 5 2 1 Distribution in the Lower Fox River 5 67 5 5 2 2 PCB Distnbution in Green Bay 5 69 5 5 2 3 PCB Distnbution in Lake Michigan 5 69

5 5 3 Mercury Distnbution 5 70 5 5 4 Pesticide Distnbution 5 70

5 6 Chemical Loading to Green Bay 5 71 5 6 1 PCB Loading to Green Bay 5 71 5 6 2 Mercury and DDT Loading to Green Bay 5 71

5 7 Summary of PCBs in Biota 5 72 5 8 Time Trends of Contaminants in Sediment and Fish 5 72

5 8 1 Sediment Methods 5 72 5 8 2 Fish Methods 5 74 5 8 3 Results 5 75

5 8 3 1 Little Lake Butte des Morts 5 76 5 8 3 2 Appleton to Little Rapids 5 78 5 8 3 3 Little Rapids to De Pere 5 78 5 8 3 4 De Pere to Green Bay (Zone 1) 5 79 5 8 3 5 Green Bay Zone 2 5 80

VI

Table of Contents

5 9

6 Chemical 6 1 6 2

6 3

6 4

6 5

7 Summary 7 1 7 2 7 3

5 8 4 Conclusion Section 5 Figures Tables and Plates

Transport and Fate Introduction Transport and Fate Processes 6 2 1 Chemical Transport Interactions 6 2 2 Physical Transport 6 2 3 Biological Interactions Compounds of Potential Concern 6 3 1 Organic Constituents

6 3 11 PCBs 6 3 12 Dioxins and Furans 6 3 13 DDT 6 3 14 Dieldnn

6 3 2 Inorganic Constituents 6 3 2 1 Mercury 6 3 2 2 Lead 6 3 2 3 Arsenic

Lower Fox River/Green Bay Modeling 6 4 1 GBTOXe Model 6 4 2 GBFood Model 6 4 3 Fox River Food (FRFood) Model 6 4 4 Whole Lower Fox River Model Section 6 Tables

of Findings Introduction Physical and Ecological Characteristics Nature and Extent of Sediment Impacts 7 3 1 Overview 7 3 2 Lower Fox River PCB Impacts

7 3 2 1 Overview 7 3 2 2 Little Lake Butte des Morts Reach 7 3 2 3 Appleton to Little Rapids Reach 7 3 2 4 Little Rapids to De Pere Reach 7 3 2 5 De Pere to Green Bay Reach

7 3 3 Green Bay PCB Impacts

5 80 5 82

6 1 6 1 6 1 6 1 6 3 6 4 6 5 6 5 6 5 6 6 6 7 6 8 6 9 6 9

6 10 6 11 6 12 6 12 6 12 6 13 6 14 6 15

7 1 7 1 7 2 7 4 7 4 7 6 7 6 7 6 7 7 7 8 7 8 7 9

I I I I I

VII

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Table of Contents

7 3 3 1 Overview 7 9 7 3 3 2 Green Bay Zone 2 7 10 7 3 3 3 Green Bay Zone 3 7 11 7 3 3 4 Green Bay Zone 4 7 12

7 3 4 Other Chemical Compounds 7 12 7 4 Chemical Transport and Fate 7 15 7 5 Investigative Assumptions/Uncertainties 7 16

8 References 8 1

Vl l l

Table of Contents

Appendix A

Appendix B

Appendix C

Appendix D

Appendix E

Appendix F

Appendix G

Appendix H

Appendix I

Data Management Summary Report (EcoChem, 2000) Addendum 1 to the Data Management Summary Report (EcoChem, 2002)

Time Trends Analysis (Mountain-Whisper-Light, 2001)

A Windrose diagram, developed from the National Oceanic and Atmospheric Administration

Stratigraphic cross-sections and other pertinent information conceming the regional geology of the area (Kjohelsld and Brown, 1986).

Bathymetry information available from the NOAA recreational charts for Lake Winnebago and the Lower Fox River (NOAA, 1992)

The USGS hydrographs for two storm events in November 1998

Physical parameters tables

PCB Congeners and Homolog Group List (ATSDR, 1997a)

PCB congener results for each reach and zone

IX

I I

List of Figures

I I

Figure 1 1 Lower Fox River Study Area Figure 1 2 Green Bay Study Area Figure 1 3 Little Lake Butte des Morts Reach Figure 1 4 Appleton to Little Rapids Reach Figure 1 5 Little Rapids to De Pere Reach Figure 1 6 De Pere to Green Bay Reach Figure 3 1 Lower Fox River Elevation Profile Figure 3 2 Green Bay Monthly Mean Surface Circulation August 1989 Figure 3 3 Green Bay Monthly Bottom Surface Circulation August 1989 Figure 3 4 Green Bay Zone 2 Bathymetry Figure 3 5 Green Bay Zone 3 Bathymetry Figure 3 6 Green Bay Zone 4 Bathymetry Figure 3 7 Estimated Annual Sediment Transport Rates and Stream Flow Velocities Figure 4 1 Lower Fox River Wetland Habitat and Animal Distribution Little Lake

Butte des Morts Reach Figure 4 2 Lower Fox River Wetland Habitat and Animal Distribution Appleton to

Little Rapids Reach Figure 4 3 Lower Fox River Wetland Habitat and Animal Distribution Little Rapids

to De Pere Reach Figure 4 4 Lower Fox River Wetland Habitat and Animal Distribution De Pere to

Green Bay Reach Figure 4 5 Wetland Distribution Green Bay Zones 2 and 3 Figure 4 6 Wetland Distribution Green Bay Zone 4 Figure 4 7 Wetland Losses in Green Bay Duck Creek Cat Island Chain and Long

Tail Point Figure 4 8 Green Bay Spawning Areas by Fish Types Salmon/Trout and Benthic Fish Figure 4 9 Green Bay Spawning Areas by Fish Types Pelagic and Game Fish Figure 4 10 Green Bay Spawning Areas by Fish Species Walleye Yellow Perch and

Sturgeon Figure 4 11 Green Bay Spawning Areas by Fish Species Carp and Alewife Figure 4 12 Green Bay Spawning Areas by Fish Species Emerald Shiners and Gizzard

Shad Figure 4 13 Distnbution of Birds in Green Bay Select Species and Groups Figure 4 14 Lower Fox River Mink Habitat Suitability Little Lake Butte des Morts

Reach Figure 4 15 Lower Fox River Mink Habitat Suitability Appleton to Little Rapids Reach Figure 4 16 Lower Fox River Mink Habitat Suitability Little Rapids to De Pere Reach Figure 4 17 Lower Fox River Mink Habitat Suitability De Pere to Green Bay Reach Figure 4 18 Green Bay Mink Habitat Suitability Zone 2 Figure 4 19 Green Bay Mink Habitat Suitability Zone 3

List of Figures 1

Figure 5 1 PCB Sampling Frequency Distribution in Lower Fox River and Green Bay Sediments

Figure 5 2 Summary of Total PCB Concentrations in Lower Fox River and Green Bay Sediments

Figure 5 3 PCB Mass Distribution in Sediments for Each River Reach and Bay Zone Figure 5 4 PCB Mass by Concentration Ranges in Lower Fox River Sediments Figure 5 5 Contaminated Sediment Volume by Concentration Ranges in the Lower

Fox River Figure 5 6 PCB Mass by Concentration Ranges in Green Bay Sediments Figure 5 7 Contaminated Sediment Volume by Concentration Ranges in Green Bay Figure 5 8 PCB Mass Distribution in Lower Fox River and Green Bay Sediments Figure 5 9 Ratios of PCB Mass/Sediment Volume in the Lower Fox River and Green

Bay Sediment Figure 5 10 Distribution of PCB Mass/Sediment Volume Ratios in Sediments with

More Than 50 j x ^ g PCBs Figure 5 11 Aroclors 1242/1254/1260 PCB Homolog Plots Figure 5 12 PCB Homolog Distribution in Lower Fox River and Green Bay Sediments Figure 5 13 1994/95 Total PCB & Mercury Concentrations in Lower Fox River Water Figure 5 14 1998 Total PCB Concentrations in Lower Fox River Water Figure 5 15 PCB Homolog Distribution in Water De Pere Dam Through Green Bay Figure 5 16 Lower Fox River and Green Bay System Estimated PCB Mass and Major

PCB Flux Pathways Figure 5 17 Time Trends of PCBs in Sediments for Depths from 0 to 10 cm and from

10 to 30 cm Figure 5 18 Time Trends of PCBs in Sediments for Depths from 30 to 50 cm and from

50 to 100 cm Figure 5 19 Time Trends of PCBs in Sediments for Depths over 100 cm

XI

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List of Tables

Table 2 1 Fox River Database Studies and Data Classification Table 2 2 Lower Fox River Supplemental Data Collection Sampling List Table 3 1 Land Use Classification for Counties Bordering Green Bay Table 3 2 Temperature and Precipitation Data for the City of Green Bay Wisconsin Table 3 3 Temperature and Precipitation Data for the City of Appleton Wisconsin Table 3 4 Temperature and Precipitation Data for the City of Marinette Wisconsin Table 3 5 Temperature and Precipitation Data for the City of Sturgeon Bay

Wisconsin Table 3 6 Temperature and Precipitation Data for the City of Fayette Michigan Table 3 7 Water Use in the Lower Fox River/Green Bay Watersheds (1995) Table 3 8 Lower Fox River Dams Table 3 9 Lower Fox River U S Army Corps of Engineers Dam Stability and

Inspection Information Table 3 10 Lower Fox River Gradient and Locl</Dam Information Table 3 11 Lower Fox River Discharge Results Rapide Croche Gauging Station Table 3 12 Lower Fox River Stream Velocity Estimates Table 3 13 Fox River Mouth Gauging Station Results (1989 1999) Table 3 14 Lower Fox River Total Suspended Solid (TSS) Loads Table 3 15 USAGE Navigation Channel Dredging Records (1957 1999) Table 4 1 Major Green Bay Wetland Areas/Complexes Table 4 2 Lower Fox River Habitats Table 4 3 Lower Fox River Shoreline and Substrate Types Table 4-4 Lower Fox River Fish Species Composition Table 4 5 Lower Fox River Fish Populations in the De Pere to Green Bay Reach Table 4 6 Green Bay Fish Species Table 4 7 Lower Fox River and Green Bay Bird Species Table 5 1 Lower Fox River and Green Bay Sediment Sampling Results Summary

of Detected Compounds Table 5 2 Lower Fox River and Green Bay Distribution of Total PCBs in Sediment Table 5 3 Lower Fox River Dioxin/Furan ( 2 3 7 8 TCDD/F) Results Table 5 4 Lower Fox River and Green Bay Pesticide Results Table 5 5 Lower Fox River and Green Bay Mercury Lead and Arsenic Results Table 5 6 Lower Fox River and Green Bay Other RCRA Metals Copper Nickel

and Zinc Table 5 7 Lower Fox River and Green Bay Miscellaneous Inorganic Compounds Table 5 8 Lower Fox River and Green Bay Ammonia Results Table 5 9 Lower Fox River Toxicity Characteristic Leaching Procedure (TCLP)

Results Table 5 10 Lower Fox River and Green Bay Semi Volatile Organic Compound

Results (PAHs) Table 5 11 Lower Fox River and Green Bay Miscellaneous SVOC Results

Xll

List olP Tables D D 0 Q

D

D

0

Table 5 12 Lake Winnebago Background Sediment Results Table 5 13 Lower Fox River PCB Mass and Sediment Volume by Concentration

Range Table 5 14 Lower Fox River PCB Mass and Sediment Volume by Deposit/SMU

Layer Table 5 15 Green Bay PCB Mass and Sediment Volume by Concentration Range and

Layer Table 5 16 Lower Fox River and Green Bay Water Sampling Results Summary of

Detected Compounds Table 5 17 Lower Fox River Total PCB Results in Water Table 5 18 Green Bay Total PCB Results in Water Table 5 19 Lower Fox River and Green Bay Mercury and DDT (DDD/DDE) Water f\

Sampling Results ^ Table 5 20 PCB Transport within the Lower Fox River and Green Bay System _ Table 5 21 Distribution of Resident Tissue Samples over Time in the Lower Fox River 1

Total PCBs Only Table 5 22 Distribution of Resident Tissue Samples over Time in Green Bay Total

PCBs Only Table 5 23 Results of Sediment Time Trends Analysis for the Lower Fox River Table 5 24 Mass Weighted Combined Time Trend for 0 to 10 cm Depth by Reach j l Table 5 25 Results of Fish Time Trend Analysis on the Lower Fox River Table 6 1 Lower Fox River Fate and Transport Chemical Factors py

0 D 0 D 0 0

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I I

List of Plates

I Plate 3 I Sample Locations and Interpolated Thicloiess of Sediment with PCBs Little Lake Butte des Morts Reach

Plate 3 2 Sample Locations and Interpolated Thickness of Sediment with PCBs Appleton to Little Rapids Reach

Plate 3 3 Sample Locations and Interpolated Thicloiess of Sediment with I PCBs Little Rapids to De Pere Reach

Plate 3 4 Sample Locations and Interpolated Thickness of Sediment with PCBs De Pere to Green Bay Reach

Plate 3 5 Sample Locations and Interpolated Thicloiess of Sediment with PCBs Green Bay

Plate 5 1 Interpolated PCB Distribution in Sediments Little Lake Butte des Morts Reach

Plate 5 2 Interpolated PCB Distnbution in Sediments Appleton to Little I Rapids Reach

Plate 5 3 Interpolated PCB Distribution in Sediments Little Rapids to De

I Pere Reach

Plate 5-4 Interpolated PCB Distribution in Sediments De Pere to Green Bay Reach

• Plate 5 5 Interpolated PCB Distnbution in Sediments Green Bay

XIV

EXECUTIVE SUMMARY The Remedial Investigation (RI) report summarizes the physical, chemical, and biological characteristics of the Lower Fox River and Green Bay. The purpose of the RI report is to compile and evaluate these data to support development of the Baseline Human Health and Ecological Risk Assessment (RA) and Feasibility Study (FS). The RA identifies the risks posed to h u m a n h e a l t h and t h e environment by compounds of concern. The FS develops and evaluates a range of remedial alternatives to support the selection of a remedy that vsall eliminate, reduce and/or control these risks. This RI/FS report is consistent with the findings of the National Academy of Science's National Research Council Report ent i t led A Risk Management Strategy for PCB Contaminated Sediments. (NRC, 2001).

The RI study area includes the Lower Fox River extending 63 km (39 mi) from Lake Winnebago to Green Bay as well as the entire 4,150 Icm^ (1,600 mi^) of the bay. Green Bay is 190 km (119 mi) in length and averages 37 1cm (23 mi) in width. The Lower Fox River was subdivided into four r iver r eaches . Green Bay is subdivided into zones 2 , 3 , and 4 (Figure 1). The Green Bay Area of Concern, as designated by the International Joint Commission, is defined as the De Pere to Green Bay Reach and much of Green Bay Zone 2.

The RI evaluated data from numerous investigations conducted within the study area since 1971, which comprise the Fox River Database (FRDB). Sediment, water, and biological samples in the FRDB include analyses for over 200

chemical parameters . Based on these analyses, a Screening Level Risk Assessment identif ied polychlor ina ted biphenyls (PCBs), dieldrin, DDT, dioxins/furans, mercu ry , lead , a n d a r s e n i c as t he compounds present in the study area that represent potential risks to human health and the environment. However, PCBs are the primary compounds of concem.

Site History and PCB Discharges In the early 1950s, carbonless copy paper was developed through a process that applied an emulsion containing PCB on paper in a manner that would create document copies. Lower Fox River valley paper mills manufactured and recycled this carbonless paper between 1954 and 1971. About 45 million pounds of PCB were used in the Fox Valley during this time period.

PCBs were released to the environment through manufacturing waste waters and from the de-inking/recycling of waste carbonless copy paper. The Wisconsin Department of Natural Resources (WDNR) estimates the amount of PCB that was discharged to the Lower Fox River from these activities is 313,600 kg (691,370

XIX

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pounds) with a range from 126 450 kg to 399 450 kg (278 775 to 880 640 pounds) WDNR believes that five facilities contributed over 99 percent of the total PCBs discharged to the Lower Fox River by the end of 1971

In the late 1970s commercial production of PCBs in the United States was prohibited due to concerns for human health and the environment At the present time some minor unavoidable point source discharges along with atmosphenc deposition of PCB continue but are small compared to the PCB mass present in the nver and bay sediments

Pnor to implementation of the federal Clean Water Act in 1972 rough fish were the main species that could live in t h e L o w e r Fox R i v e r W i t h implementation of the Clean Water Act and more str ingent control over wastewater discharges water quality in the nver improved and game fish began to return to the nver PCBs were detected in trout from Green Bay as early as 1971 Due to continued elevated PCB levels WDNR issued advisories for public consumption of fish (1976) and waterfowl (1983) derived from Green Bay and the Lower Fox River The state of Michigan also issued consumption advisories for Green Bay fish in 1977

PCB Distr ibution and Sediment Volumes Considenng sediments containing more than 50 )tig/kg PCB about 28 600 kg (63 050 pounds) of PCBs are contained v^thin about 9 million m^ (11 8 million yd"') of sediment in the Lower Fox River In Green Bay approximately 68 200 kg (150 300 pounds) of PCBs are dispersed in about 465 million m^ (610 million

yd^) of sediment The distribution of PCB mass sediment volume and sediment areal extent are shown on Figure 2 Also shown on Figure 2 is the ratio of PCB mass to sediment volume The reaches upstream of the De Pere dam are combined on Figure 2 because of their relatively small PCB mass sediment volume and areal extent

Much of the PCB discharged into the Lower Fox River has already been transported downstream and is now concentrated in sediments within specific areas

• The De Pere to Green Bay Reach contains almost 26 000 kg of PCB which represents about 91 percent of the mass remaining in the nver This reach contains just under 27 percent of the total PCB mass in the system and is concentrated wathin a relatively small area comprising just over one percent of the total sediment volume This reach also exhibits the highest mass of PCB per volume of sediment

• Approximately 70 percent of the total PCB mass in the system has migrated from the river into Green Bay

• The PCB mass in Green Bay is dispersed over an extraordinarily large area and in an extremely large sediment volume Almost half of the total PCB mass in Green Bay is found in Zone 2

Sediment and PCB Transport Particle size and cohesion along with river/bay conditions especially current speeds c o n t r o l the d e p o s i t i o n resuspension and transportation of sediments (and the PCBs absorbed to them) In the Lower Fox River sediments have accumulated in 35 separate deposits above

XX

36,000-1 «W • -n

LLBdMtoDaPsre ] DePwatoOfMnBw

GraanBvZDin2 QnaaBafZaim3 GnMBqr20M4

PCB MASS DISTRIBUTION

SEDIMENT VOLUME DISTRIBUTION

PCB MASS/SEDIMENT VOLUME RATIO

SEDIMENT AREAL EXTENT

Figure 2. PCB Mass & Sediment Volume/Area Distribution by river reach and bay zone

the De Pere dam. Below the De Pere dam and in Green Bay, where current speeds tend to be lower, sediments cover large areas of the river and bay bottom, except in areas where the sediments are dredged to maintain ship navigation. The highest PCB concentrations have also been observed in the LLBdM and De Pere to Green Bay reaches, in the vicinity of historic discharge points.

The average river discharge was about 122 mVs (4,300 cfs) between 1989 and 1998. Due to storm events and spring snowmelt, the river discharge exceeds 272 mVs (9,600 cfs) more than 10 percent of the time. These faster currents have the capability to resuspend and transport larger particle sizes and greater volumes of sediment and, therefore, a greater mass of PCB. Field m e a s u r e m e n t s and computer modeling results suggest that

these less-frequent, high-discharge events transport much of the PCB mass in the river over the De Pere dam and into Green Bay. In addition to sediment transport, PCB migrates due to dissolution in water and adsorption onto algae and other organic matter. The PCB mass transported from reach to reach increases along the river. Based on sampling data collected as part of the Green Bay Mass Balance study in 1989-90, about 280 kg (610 pounds) of PCB were transported to Green Bay during the study period. Based on work done in 1994-95 as part of the Lake Michigan Mass Balance, it was estimated that 220 kg (485 pounds) of PCB moved from the river into the bay. PCB loads to the bay vary as the river flow varies. This mass represents up to 1 percent of the PCB mass in the river.

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Sediment discharged from the Lower Fox River is directed toward the east shore of Green Bay by counterclockwise currents This sediment rich water can extend between 20 km to 40 km (12 mi to 24 mi) along the east shore Fluctuating water levels wave action and reverses in stream flow in this area facilitate sediment t r anspor t and mixing Consequently large volumes of sediment containing PCB are present along the southern and eastem portions of Green Bay At least 68 200 kg (150 300 pounds) of PCBs already reside in the bay Over 95 percent of the PCB that occurs in Green Bay is derived from the Lower Fox River

This transport of PCB also extends into Lake Michigan Dunng 1989/90 it was estimated as part of the Green Bay Mass Balance Study that about 122 kg (270 pounds) of PCBs were transported from Green Bay to Lake Michigan Other mass t r a n s p o r t p a t h w a y s ( s u c h as volatilization) also exist

E c o l o g i c a l S a m p l e s a n d Characteristics Exposure of biota to sediments and water containing PCB fosters uptake of PCBs into the food chain Wet l ands submerged aquatic vegetation and islands along the Lower Fox River and Green Bay offer nesting/spawning feeding and refuge opportunities for fish birds and animals Other lacustrine rivenne and estuary features also provide habitat for regional wildlife In addition to birds and fish the FRDB contains information on PCBs in deer otter mink and various insects and invertebrates The RA evaluates PCB uptake and accumulation in selected species and the a s s o c i a t e d h u m a n h e a l t h a n d

environmentai risks Areas with higher PCB concentrations tend to pose a greater risk of exposure

Effects of Time The FRDB includes sediment and water results from over a 10 year period while tissue samples were collected between 1971 and 1999 Dunng the 1970s after PCB discharges into the river ceased PCB concentrations in fish tissue showed significantly declining concentrations However since the mid 1980s changes in the rate of PCB decline in fish tissue have been observed Changes in PCB levels in fish tissue have either slowed remained constant or is some cases actually increased

PCB concentration trends in the upper 10 cm (4 in) of sediment are inconsistent but generally appear to be decreasing over time as more PCB is transported downstream Soil eroded from the watershed mixes with and may further dilute PCB concentrations in the sediments

Further Information The selection of remedies for the Lower Fox River and Green Bay will consider the information within the RI RA and FS as well as input by the public and interested parties For further information please contact

Mr Edward K Lynch P E WI Department of Natural Resources 101 S Webster Street Box 7921 Madison WI 53703 (608/266 3084) or visit the WDNR website at http //iviviv dnr state wi us/org/water/mn/loiverfox

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WORK PLAN

FOR THE REMEDIAL DESIGN

OF OPERABLE UNITS 2 3 4 AND 5

LOWER FOX RIVER AND GREEN BAY SITE

BROWN OUTAGAMIE AND WINNEBAGO COUNTIES WISCONSIN

Prepared by

Shaw Environmentai & Infrastructure Inc

Anchor Environmentai LLC

Prepared for

Fort James Operating Company Inc

NCR Corporation

For Submittal to

Wisconsm Department of Natural Resources

U S Environmentai Protection Agency

June 27 2004

T bl fC 1 1

TABLE OF CONTENTS 1 INTRODUCTION 1

1 1 PROJECT BACKGROUND _ _ _ _ _ _ _ i

I 2 GENERAL DESCRIPTION OF ROD REMEDIAL ACTIONS _ _ _ _ _ i / 2 I Operable Umt 2 {Excluding Deposit DD) / / 2 2 Operable Units 3 and 4 (Including OU '> Deposit DD) 2 1 ' i Operable Unit 5 i 1 ^ 4 Contingent Remedy ~ In Situ Capping 3

1 3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS— _ _ _ _ _ _ _ _ _ 3

1 4 REMEDIAL DESIGN APPROACH - - _ _ _ _ 3

2 REVIEW AND ANALYSIS OF EXISTING DATA 6

2 I LOWER Fox RIVER DATABASE FOR OUs 2 3 4 AND 5 _ _ _ _ 6

2 2 PHYSICAL HYDRAULIQ AND GEOTECHNICAL CONDITIONS _ _ _ _ _ _ _ _ 7

2 ' / Geology md H\diogeolog\ 8 2 ^ '> Balh)melrv and Water Depth 10 2 2 3 Sediment Thickness and Stratigraphy — 12 ^ ^ 4 Lower Fox Ri\er Navigational Sinicliires 16 2 2 5 Infrasn iicture and Obstructions • 18 ' ' <! River H\drodvnamics • 19 ' 2 7 SedimenI Transpoi I 20

2 3 LOWER Fox RIVER SEDIMENT QUALITY CHARACTERISTICS — 22

^ 3 1 Data Sources ' ' ^ 3 2 PCB Composition in Lot er Fox River '4 2 3 3 E.xteni of PCBs in the Lower Fox Ri\er ^5 ^ 3 4 Other Constituenis of Conce n 29

2 4 L A N D U S E WITHIN THE SITE A R E A - _ _ _ _ _ _ _ _ _ _ _ 30

2 5 EXISTING HABITAT CONDITIONS _ _ _ _ - _ _ - - _ - - - _ — _ _ _ 3 o

' 5 I Habitat and Wildlife Overvien' 30 ' 5 ' Habitat Description bv Operable Umi 3')

2 6 PRE DESIGN DREDGING EVALUATION 33

2 6 1 Extent oj Required Cleanup —- 34 ' 6 ' Dredge Plan Design Considerations 35 2 6 3 Preliminarv Dredge Volumes and Production Rates 41 ^ 6 4 Equipment Selection Considerations '12 2 6 5 Potential Environmentai Impacts During Dredging and Best Management Practices 48 '> 6 6 Post Diedge Residual Management 50

2 7 PRE DESIGN TRANSPORT AND DISPOSAL EVALUATION 51

' 7 / Initial Inventor) of Potential Disposal Facililies 51 '> 7 '> Dewatei mg Material Handling and Water Treatment Considerations 53 ' ' 7 3 Potential Permitting and Approval Considerations (Disposal Facilities) 55

2 8 PRE DESIGN MONITORED NATURAL RECOVERY EVALUATION 55

' S / Natural Reco\ erv Objectives 56 ' S ' Natural Recoverv Processes 56 7 8 3 PCB Source Load Reductions 58

2 9 CONTINGENT CAPPING REMEDY EVALUATION - - _ _ _ _ _ _ _ _ _ _ 5 8

i PRE DESIGN DATA COLLECTION 59

3 1 DREDGE DESIGN DATA G A P S _ _ _ _ _ _ 59

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3 11 Dredge Plan Data Requirements 59 3 12 Equipment Selection Data Requirements 67 3 1 3 Dredge Plan Design Considerations 70

3 2 MATERIAL HANDLING DEWATERING AND DISPOSAL SITE DESIGN DATA GAPS —70

3 2 1 Data Needs for Remedial Design Evaluation of SedimenI Disposal Options 71 3 '> 2 Data Needs for Transpoi t (Matenal Handling) 74 3 2 3 Data Needs for Dei atering 77 3 ^ 4 Data Needs for Effluent Treatment 81 3 ^ 5 Data Needs for Solids Treatment 82

3 3 CONTINGENT CAPPING REMEDY DATA GAPS _ _ _ _ _ g3

3 3 1 Physical Properties 83 3 3 2 Chemical Piopeilies 84

3 4 BASELINEMONITORING AND NATURAL RECOVERY DATA GAPS - 84

4 REMEDIAL DESIGN PHASES 86

4 1 INITIAL REMEDIAL DESIGN ACTIVITIES - — — —86

4 2 PREPARATION OF BASIS OF DESIGN REPORT 87

4 3 CONTINGENT REMEDY EVALUA riONS, PILOT PROJECTS^ AND SUPPLEMENTAL INVESTIGATIONS

88 4 4 PREPARATION OF REMEDIAL DESIGN DOCUMENTS 90

4 4 I Preliminary Design (30/) 90 4 4 ' Intermediate Design (60/) • 91 4 4 3 Pre-Final Design (90 ' ) 91 4 4 4 Final Design (100/) 9 ' 4 4 5 Content of Siippoi ling Plans 92

5 REMEDIAL DESIGN PROJECT SCHEDULE 94

5 I RATIONALE AND ASSUMPTIONS- — - - _ _ _ _ _ _ _ 94

6 REMEDIAL DESIGN PROJECT MANAGEMENT 96

6 1 RESPONDENT TEAM ORGANIZATION RESPONSIBILITIES, AND AUTHORITIES —96

6 1 1 Fort James Operating Company Inc and NCR Corporation 96

6 1 ' Shaw/Anchor Team 96 6 2 AGENCY ORGANIZATION RESPONSIBILITIES, AND AUTHORITIES —98

6 ' I WDNR Project Coordinator Greg Hill 98 6 ' 2 WDNR Projecl Manager Ben Hung 98 6 2 3 USEP4 Project Coordinator Jim Hahnenberg — — 99 6 2 4 USEPA Quality Assurance Re\ fei er Richard Byvik 99 6 2 5 WDNR Quality Assurance Manager Donalea Dinsmore 99

6 3 COMMUNICATIONS — - — — — • — — 99

6 3 1 Monthlv Progress Reports 99 6 3 2 Meetings — 99 6 3 3 Work Groups — — — ——-99 6 3 4 Response Agenc\ Communication Plan 100

7 REFERENCES 102

T bl r c tcnl

LIST OF APPENDICES Appendix A Geostatistical Methods and Results

Appendix B Contingent Capping Remedy Evaluation

LIST OF TABLES Table 2 I Summary of Data Layers by Data Type

Table 2 2 Lower Fox River Locks and Dams

Table 2 3 Data Sources for Charactenzation of LFR Sediment Bed Properties

Table 2-4 Summary of Grain Size Data

Table 2 5 Alterberg Limits - Lower Fox River

Table 2 6 Summary of Physical Properties

Table 2 7 Lower Fox River Discharge Data

Table '' 8 Lower Fox River Stream Velocity Estimates (fps)

Table 2 9 Statistical Summary of Chemicals of Concem

Table 2 10 Estimated PCB (kg) by Depth Interval

Table 2 11 Estimated Contammated Sediment Volume (m ) by Depth Interval

Table 2 12 Average Total PCB Concentration (Estimated) by Depth

Table "> 13 Lower hox River Land Use

Table 3-1 Landflll and Confined Disposal Facility Data Needs - Dewatered Sediment


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LIST OF FIGURES Figure 1 1 Lower Fox River Area Location Map

Figure 2 1 Base Map/Site Geography Operable Units 3 and 4

Figure 2 2 Conceptual Level Cross Section of Lower Fox River Valley Aquifers

Figure 2 3 Lake Michigan Huron Hydrograph (1918 - Present)

Figure 2-4 Water Depth Map Operable Units 3 and 4

Figure 2 5 Soft Sediment Thickness Operable Units 3 and 4

Figure 2-6 Total Organic Carbon Operable Units 3 and 4

Figure 2 7 Bulk Density Operable Units 3 and 4

Figure 2 8 Riverbed Characterization Operable Units 3 and 4

Figure 2 9 Maximum PCB Concentration (Knged) Operable Units 3 and 4

Figure 2 10 Contaminated Sediment Thickness (WDNR PCB >l ppm) OUs 3 and 4

Figure 2 11 Contaminated Sediment Thickness (Shaw/Anchor PCB >l ppm) OUs 3 and 4

Figure 2 12 Cross Section Location Maps

Figure 2 13 Typical Cross Sections (A - C)

Figure 2 14 Typical Cross Sections (D - F)

Figure 2 15 Mercury Concentration Operable Units 3 and 4

Figure 2 16 Conceptual Cross Section and Dredge Plan

Figure 3-1 Semivanogram Analysis of Surface and Subsurface Sediments

Figure 5-1 Lower Fox River OU 2 through OU 5 Initial Remedial Design Schedule

Figure 6-1 Organization Chart

I

ACRONYMS F

Anchor AOC ARAR

ASCII BBLES

BMP CAD CDF

CERCLA c6

cm cm/s COC

CQAPP CST

cy DEA DMU

DRET En Chem

EDD ESD FGDC

FIELDS Fort James

Ips FRDB FRG

FS g/cm'

GAS/SAIC

GBMBS

GIS GLNPO HASP IDW IGLD

kg lb LTA

LTI

degree Fahrenheit

Anchor Environmental LLC Administrative Order on Consent Applicable or Relevant and Appropnate Requirements

Amencan Standard Code for Infonnauon Interchange BB&L Environmentai Services

best management practice confined aquatic disposal confined disposal facility Comprehensive Environmentai Response Compensation and Liability Act cubic feet per second

centimeter centimeter per second contaminant of concem construction quality assurance project plan column settling test

cubic yard Detailed Evaluauon of Alternatives dredge management unit

Dredging Elutriate Test En Chem Inc

electronic Data Deliverable Explanation of Significant DilTerence Federal Geographic Data Committee

Field Environmentai Decision Support Fort James Operating Company Inc feet per second Fox River Database Fox River Group

feasibility study grams per cubic centimeter

Graef Anhalt Schloemer & Associates/Science Applications Intemanonal Corporation Green Bay Mass Balance Study

Geographic Information System Great Lakes National Program Office Health and Safety Plan inverseKiistance weighted International Great Lakes Datum

kilogram pound long term average

Limno fech Inc

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MET mg/L

MNR

NCP

NCR

NOAA NRC NTU OMMP OSI

OU PCA PCB pcf PCLT ppm

psf

psi

QAPP

RAL

RAO

RD

RI

RM ROD SAP SAV

Shaw

SMU

SOW SPT

SRD

SWAC

TBD

TCLT

TIN

TOC

TSCA

TSS

Mg/kg

Ug/L

USACE

USEPA

USGS

UU

Modified Elutnale Test

milligram per liter

Monitored Natural Recovery

National Contingency Plan

NCR Corporation

National Oceanic and Atmosphenc Administration

National Research Council

Nephelometric turbidity unit Operations Maintenance and Momtonng Plan

Ocean Surveys Inc

Operable Unit Project Cooperation Agreement

polychlonnated biphenyl pounds per cubic foot

pancake column leach test

part per million

pounds per square foot

pounds per square inch

Quality Assurance Project Plan

remedial action level

remedial action objective

remedial design

remedial investigation

nver mile

Record of Decision

Sampling and Analysis Plan

submerged aquatic vegetation


sediment management unit

Statement of Work

Standard Penetration Test

sediment redevelopment

surface weighted average concentration

to be determined

thin layer column leach test

tnangulated irregular network

total organic carbon

Toxic Substances Control Act

total suspended solids

microgranVkilogram

microgram/liter

U S Army Corps of Engineers


U S Geological Survey

unconsolidated undrained

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A ym

VST vane shear test WDNR Wisconsin Department of Natural Resources WPDES Wisconsin Pollution Discharge Eliminanon System WRDA Water Resources Development Act


I I

1 INTRODUCTION This Remedial Design (RD) Work Plan presents the design phases tasks and sequencing necessary to complete remedial design in Operable Units (OU) 2 3 4 and 5 of the Lower Fox River and Green Bay Site (Site Figure 1 1) The requirements for RD are set forth in the Administrative Order on Consent (AOC) and associated Statement of Work (SOW) for OUs 2-5 (USEPA 2004) executed in March 2004 by Fort James Operating Company Inc (Fort James) and NCR Corporation (NCR) (collectively the Respondents ) in cooperation with the Wisconsin Department of Natural Resources (WDNR) and the

U S Environmentai Protection Agency Region (USEPA)(collectiveIy the Response Agencies ) This RD Work Plan addresses only OUs 2-5 The remedial design of OU 1 is being addressed under a separate agreement between WDNR USEPA and the WTM 1 Company

I I

Remedial Design Work Plan Addendum - April 15, 2008

Attached is a printable version of the Lower Fox River OUs 2 to 5 Remedial Design (RD) Work Plan Schedule incorporating your edits This submittal also addresses the Response Agencies request for a detailed RD schedule as conveyed in a letter from Richard Murawski dated March 17 2008 The attached schedule replaces the previously submitted RD Work Plan Addendum

The attached schedule highlights required submittal dates for those RD deliverables identified or referenced in the October 30 2007 revised Administrative Order on Consent (2007 RD AOC) between the Respondents and Response Agencies which modified the previous Statement of Work (SOW) and AOC to ensure consistency with the 2007 ROD Amendment Such deliverable milestones are identified as AOC Submittals in the Notes column of the attached schedule and are subject to the Plans and Submissions provisions of the AOC as amended As you indicated in your e mail the dates listed for the AOC Submittals are consistent with the Agency/Oversight Team (A/OT) Task List that has been reviewed and agreed to previously

In addition to the AOC Submittals the schedule also contains other information that describes the idenhty and timing of other tasks that the Respondents plan to undertake in order to ensure that the AOC Submittals are submitted in accordance with the schedule The dates associated with these tasks other than the AOC Submittals are included for reference and planning purposes only and are not enforceable dates pursuant to the AOC as amended It is expected that during the course of the remedial design the timing of these non AOC Submittal tasks may change However due dates for the AOC Submittals will not be changed without the approval of the Response Agencies

The attached schedule will be separately provided to Boldt in Microsoft Project ( mpp) format to facilitate ongoing coordination of collaborative RD tasks and A/OT reviews The mpp schedule will be updated at least every two weeks during 2008 and at least monthly thereafter unhl complehon of RD The mpp schedule is provided for reference and planning purposes only it is not the ofhcial schedule Mr Paul LaRosa of Anchor will be the individual responsible for the management of the schedule document

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LOWER FOX RIVER OPERABLE UNITS 4 AND 5

PRE-DESIGN SEDIMENT POLING PLAN

PREPARED BY

SHAW ENVIRONMENTAL & INFRASTRUCTURE, INC AND ANCHOR ENVIRONMENTAL, LLC

PREPARED FOR

FORT JAMES OPERATING COMPANY, INC

NCR CORPORATION

JUNE 8, 2004

Table of Contents

TABLE OF CONTENTS Project Management 1 1 Introduction 1 2 Project Organization

1 2 1 Shaw Project Coordinator Anchor Technical Director Shaw Quality Assurance Manager Shaw/Anchor Team Senior Consultants Shaw/Anchor Field Team Leaders Shaw Database and Geographic Information System Manager Shaw/Anchor Health & Safety Program Manager Shaw/Anchor Health & Safety Manager Shaw/Anchor Project Delivery Manager Shaw Subcontractors USEPA Project Coordinator WDNR Project Coordinator WDNR Project Manager USEPA QA Reviewer Error' Bookmark not defmed WDNR Quality Assurance Manager 1 6 Response Agency Oversight Contractor The Boldt Company

122 123 124 125 126 127 128 129 1210 1211 1212 1213 1214 1215 1216

1 1 1 1 1 2 1 3 1 3 1 3 1 3 1 4 1 4 1 4 1 5 1 5 1 5 1 5 1 5 1 5

1217 Response Agency Communication Plan 1 3 Problem Definition/Background 1 4 Project Description and Schedule 1 5 Data Quality Objectives and Criteria for Measurement Data

1 5 1 Step 1 State the Problem 15 2 Step 2 Identify the Decision 15 3 Step 3 Identify Inputs to the Decision 15 4 Step 4 Define the Boundanes of the Study 15 5 Step 5 Develop a Decision Rule 15 6 Step 6 Specify Limits on Decision Errors 15 7 Step 7 Optimize the Design

1 6 Quality Objechves and Criteria 1 6 1 Precision 16 2 Accuracy 16 3 Representativeness 16 4 Comparability 16 5 Completeness 16 6 Sensitivity

1 7 Special Training Requirements/Certification 1 8 Documentahon of Records

1 8 1 Field Logbooks 18 2 Field Forms 18 3 Photographs 18 4 Data Reporting 18 5 Progress Reports and Notification to WDNR and USEPA 18 6 Project Record Maintenance and Storage

1 6 1 6 1 7 1 8 1 8 1 8 1 9 1 9 1 10 1 11 1 12 1 13 1 14 1 14 1 15 1 15 1 16 1 17 1 17 1 17 1-18 1 18 1 18 1 18 1 19 1 20 1 20


Table of Contents

2 Data Generation and Acquisition 2 1 2 1 Poling Survey Design 2-1

2 1 1 Sediment Thickness Delineation 2 1 2 1 2 Decontamination Procedures and Disposal of Investigahon Derived

Waste 2 2 2 2 Poling Methods Requirements 2 3

2 21 Station Location Positioning 2 3 2 2 2 Sediment Poling Procedures 2 3 2 2 3 Field Sample Identification System 2-3

2 3 Quality Control Requirements 2 4 2 3 1 Field Quality Control Samples 2 4 2 3 2 Correchve Action 2 4

2 4 Instrument/Equipment Testing, Inspection and Maintenance Requirements 2 5 2 5 RTK DGPS Instrumentation Daily Checks 2 5 2 6 Data Acquisition Requirements 2-6

2 61 Data Acquisition Planning 2 6 2 6 2 Field Data Acquisihon 2 6

2 7 Data Management Plan 2 6 2 7 1 Data Types 2 7 2 7 2 Documentation 2 8 2 7 3 Data Tracking and Management 2 8 2 7 4 Electronic Data Management 2 8 2 7 5 Hard Copy Data Management 2 9 2 7 6 Evidence File 2-9 2 7 7 Presentahon of Site Characterization Data 2 10 2 7 8 Data Analysis 2 10 2 7 9 Technical Work Group Meetings 2 10

3 Assessment and Response Actions 3-1

4 Data Validation and Usability 4-1 4 1 Data Review Validahon and Evaluahon Requirements 4 1

4 1 1 Validahon Approach 4 1 4 2 Validahon and Verification Methods 4 1 4 3 Reconciliation with Data Quality Objectives 4 2

5 References 5-1

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Table of Contents

UST OF APPENDICES A Field Standard Operating Procedures

B Sediment Poling Log

C Leica GPS Technical Specihcations

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LIST OF TABLES | 1 Station Location Information

LIST OF FIGURES 1 Organization Chart I

2 Area Location Map

3 OU 4 (and OU 5) PCB Contaminated Sediment Thickness •

4 OU 4 (and OU 5) Proposed Poling Locations

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IV ^

Section 1 - Project Management

I I I

1 PROJECT MANAGEMENT

1 1 Introduction

Shaw Environmentai and Infrastructure Inc (Shaw) and Anchor Environmentai L L C

(Anchor) have prepared this Pre design Sediment Poling Plan (Poling Plan) for the Lower Fox

River Operable Units (OU) 4 and 5 on behalf of the Fort James Operahng Company Inc (Fort

James) and the NCR Corporation (NCR) as part of the Lower Fox River OUs 2-5 Remedial

Design This Poling Plan is an accompanying document to the Pre design Sampling Plan

(SAP/QAPP) (Shaw and Anchor 2004a) which is a requirement of the March 2004,

Administrative Order on Consent (AOC) for the Lower Fox River Operable Units 2 5 Remedial

Design which was entered into by Fort James NCR the United States Environmentai

Protection Agency (USEPA) and the State of Wisconsin through the Wisconsin Department of

Natural Resources (WDNR) (USEPA 2004) This document has been prepared in accordance

with EPA Requirements for Quahty Assurance Project Plans (USEPA 2001) and Region 5

Instructions on the Preparation of a Superfiind Division Quality Assurance Project Plan (USEPA

2000a)

The Lower Fox River OUs 4 and 5 Pre-design Sediment Poling Plan consists of the poling

survey design and methodology combined with associated data quality objechves (DQOs) and

criteria All field activities associated with this Poling Plan are subject to the requirements of the

Health and Safety Plan (HASP) found in Appendix I of the SAP/QAPP (Shaw and Anchor

2004a) This Poling Plan serves as guidance for the project (field and laboratory) personnel in

conducting the pre design poling achvihes

The purpose of the pre design sediment poling inveshgation is to gather sediment field data

from OU 4B and portions of OU 5to support the remedial design for the OUs 2 5 cleanup

remedy The OU 4B and OU 5 pre design poling inveshgation will generate sediment thickness

data essential to the engineering design of the remedial action in these areas

Pre design baseline surveying activities are not included in the scope of the AOC or the

associated Statement of Work (SOW) The baseline surveying achvihes will be performed by

WDNR and their contractor and are not detailed in this Poling Plan The WDNR will be

performing survey control and both topographic and bathymetric mapping within anci around

the project area Pre-design activities in OUs 2-5 will be referenced to these controls and

presented on the base maps generated from these mapping efforts or on equivalent

1 1


controls/base maps generated to the same level of accuracy or higher Specifications for the

survey work are provided in the Sampling and Analysis Plan Lower Fox River Pre design

Characterization Shidy (RETEC et al 2003)

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1 2

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LOWER FOX RIVER OPERABLE UNITS 2-5

PRE DESIGN SAMPLING PLAN

PREPARED BY

SHAW ENVIRONMENTAL & INFRASTRUCTURE INC AND ANCHOR ENVIRONMENTAL LLC

PREPARED FOR

FORT JAMES OPERATING COMPANY INC

NCR CORPORATION

JUNE 29 2004

TABLE OF CONTENTS 1 Project Management

I 1 Introduction I 2 Project Organization

I 2 I I 2 2 1 23 1 24 1 25 1 26 1 2 7 1 28 1 29 1 2 10 1 2 I I 1 2 12 1 2 13 1 2 14 1 2 15 1 2 16 1 2 17

Shawf Project Coordinator Anchor Technical Director Shaw Quality Assurance Manager Shaw/Anchor Team Senior Consultants Shaw/Anchor Field Team Leaders Shaw Database and Geographic Information System Manager Shaw Project Chemist Shaw/Anchor Health & Safety Program Manager Shaw/Anchor Health & Safety Manager Shaw/Anchor Projecl Delivery Manager Shaw Subcontractors USEPA Project Coordinator WDNR Project Coordinator WDNR Project Manager USEPA QA Reviewer WDNR Quality Assurance Manager Response Agency Communication Plan

I 3 Problem Definition/Background 1 4 Project Descnption and Schedule

1 4 I 1 4 2

Project Description Projecl Schedule

1 5 Data Quality Objectives and Cntena for Measurement Data 1 5 1 1 52 1 5 3 1 54 1 5 5 1 5 6 1 5 7

Step I State the Problem Step 2 Identify the Decision Step 3 Identify Inputs to the Decision Step 4 Define the Boundanes of the Study Step 5 Develop Decision Rules Step 6 Specify Limits on Decision Errors Step 7 Optimize the Design

I 6 Quality Objectives and Cntena 1 6 I 1 6 2 I 63 1 6 4 I 6 5 I 6 6

Precision Accuracy Representativeness Comparability Completeness Sensitivity

I 7 Special Training Requirements/Certification I 8 Documentation of Records

I g 1 1 8 2 I 83 1 84

Field Logbooks Field Forms Photographs Data Reporting

I I 1 I 1 2 1 2 1 3 1 3 1 3 1 3 1-4 1-4 1-4 M 1-4 1 5 1 6 1 6 1 6 1 7 1 7 1 7 1 g 1 9 1 9 1 9 1 9 1 9

I 10 1 11 I 13 1 14 I 16 1 18 1 22 I 22 I 23 1 24 1 25 1 25 I 26 I 26 I -'9 1 29 I 29 I 29 I 30

T bl fC I 1

I 8 5 Electronic Record Format 1 33

I 8 6 Progress Reports and Notification to WDNR and USEPA 1 33 1 8 7 Project Record Maintenance and Storage 1 33

Data Generation and Acquisition 2 1 2 I Infrastructure and Obstructions 2 I 2 2 Sampling Process Design 2 2

2 2 I Sediment Chemical Delineation 2 2 2 2 2 Sediment Geotechnical Charactenzation 2 5 2 2 3 Contaminant Mobility Testing 2 13 2 2 4 Dredge Solids and Carnage Water Treatability Testing 17 2 2 5 Decontamination Procedures and Disposal of Investigation Derived Waste2 19

2 3 Sampling Methods Requirements '' 20 2 3 1 Station Location Positioning 2 20 2 3 2 Vibracore Sampling Procedure "> 20 2 3 3 Vibracore Processing 2 22 2 3 4 Geotechnical Bonng Procedures and Sample Collection 2 23 2 3 5 Cone Penetration Testing Procedures 2 24 2 3 6 In Situ Vane Shear Testing Procedures 2 24 2 3 7 Field Sample Identification System 2 24

** 4 Sample Handling and Custody Requirements 2 25 2 4 1 Sample Handling Preservation Transportation and Storage Procedures 2 25

2 4 2 Sample Chain-of Custody 2 26 2 5 Method Requirements 2 29

2 5 I Chemical Test Procedures 2 30 2 5 2 Geotechnical Test Procedures '' 30

2 6 Quality Control Requirements 2 31 2 6 I Field Quality Control Samples 2 31 2 6 2 Laboratory Quality Control Samples 2 32 2 6 3 Field and Laboratory Corrective Action 2 33

2 7 Instrument/Equipment Testing Inspection and Maintenance Requirements 2 35

2 8 Instrument Calibration and Frequency 2 35 2 8 I Field Instruments 2 36 2 8 2 Laboratory Instruments 2 36

2 9 Inspection/Acceptance Requirements for Supplies and Consumables 2 36 2 10 Data Acquisition Requirements 2 36

2 10 1 Data Acquisition Planning 2 36 2 10 2 Field Data Acquisition "* 37

2 10 3 Laboratory Data Acquisition and Reporting 2 37 2 10 4 Data Quality Evaluation (Validation) Data Entry and Reporting 2 37

2 11 Data Management Plan 2 37 2 111 Data Types 2 38 2 112 Documentation 2 39 2 1 1 3 Data Tracking and Management 2 39 2 114 Electronic Data Management 2 39 2 1 1 5 Hard Copy Data Management 2-40 2 11 6 Evidence File -40 2 117 Presentation of Site Charactenzation Data 2^1

Assessment and Response Actions 3 I Field Audits 3 2 Laboratory Audits

3 3 Technical Work Groups

Data Validation and Usability 4 I Data Review Validation and Evaluation Requirements

4 1 1 Validation Approach 4 2 Validation and Venfication Methods

4 2 1 Data Validation Forms Review

4 3 Reconciliation with Data Quality Objectives

References

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3 1 32 32

4-1 4 1 4 1 42 43 43

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LIST OF APPENDICES A En Chem Inc and STL Sacramento QA Plans and Certificates

B CQM Inc STL Pittsburg and STS Consultants Qualifications

C Data Validation Qualifiers

D Laboratory Standard Operating Procedures

E Field Standard Operating Procedures

F Electronic Data Deliverable Format

G Sediment Core Log

H Example Chain-oPCustody Form Sample Label and Custody Seal

1 Health and Safety Plan

J Resumes

LIST OF TABLES IA Latxjratory Analytical Methods and Reporting Limits - Sediment

IB Laboratory Analytical Methods and Reporting Limits - Water

'' Proposed Sample Location Information and Sampling Requirements

3A Chemical Analytical Testing Program for OU '' and OU 3

3B Chemical Analytical Testing Program 6r OU 4 and OU 5

3C Contaminant Mobility Testing Program

4A Geotechnical Testing Program - Vibracore Locations

4B Geotechnical Testing Program - Geotechnical Bonng Locations

4C Geotechnical Testing Program - Seepage Induced Consolidation Test Samples

5A Method Quality Control - Analytical

5B Quality Control Checks and Cortective Actions

5C Method Quality Control - Geotechnical

6 Estimated Sample Summanes for PCB Delineation and Geotechnical Evaluation

7 Required Sample Containers Preservation and Holding Times

I LIST OF FIGURES I Organizauon Chart

"* Area Location Map

3 OU 2 (DD) and OU 3 PCB Contaminated Sediment Thickness

4 OU 4 (and 5) PCB Contaminated Sediment Thickness

5 OU 3 and OU 2 Deposit DD Proposed Sample Locations and Maximum PCB Concenh^tions

6 OU 4 and OU 5 River Mouth Proposed Sample Locations and Maximum PCB Concentrations


1 1 introduction

Shaw Environmentai and Infrastructure Inc (Shaw) and Anchor Environmentai L L C (Anchor) have

prepared this Pre-design Sampling Plan for Ihe Lower Fox River Operable Units (OU) 2 (Deposit DD

only) 3 4 and a portion of 5 on behalf of the Fort James Operating Company Inc (Fort James) and the

NCR Corporation (NCR) as part of the Lower Fox River OUs "> 5 Remedial Design This Pre-design

Sampling Plan is a requirement of the March 2004 Administrative Order on Consent (AOC) for the

Lower Fox River Operable Units 2 5 Remedial Design which was entered into by Fort James NCR the

United States Environmentai Protection Agency (USEPA) and the State of Wisconsin through the

Wisconsin Department of Natural Resources (WDNR) (USEPA 2004) This document has been prepared

in accordance with EPA Requirements for Qualitv Assurance Projecl Plans (USEPA 2001a) and

Region 5 Instructions on the Preparation of a Siipeifimd Division Quality Assurance Projecl Plan

(USEPA 2000a)

The Lower Fox River OUs 2 5 Pre-design Sampling Plan consists of a Sampling and Analysis Plan

(SAP) combined with a Quality Assurance Project Plan (QAPP) and the associated Health and Safety

Plan (HASP see Appendix 1) This Sampling Plan serves as guidance for the project (field and

laboratory) personnel in conducting the pre-design sampling activities

The puipose of the pre-design investigation is to gather OUs 2 5 sediment field and analytical data

necessary to support the remedial design for the OUs 2 5 cleanup remedy The OUs 2 5 pre-design

investigation will generate sediment charactenzation data essential to the engmeenng design of the

OUs 2 5 remedial action The pnmary activities associated with the OUs 2 5 pre-design investigation

include baseline surveying (by WDNR) delineation of the I part per million (ppm) polychlonnated

biphenyl (PCB) remedial action level (RAL) both horizontally and vertically and physical

charactenzation of the OUs 2 5 sediments as needed for design of the following remediation activities

removal (dredging) contingent capping sediment handling sediment dewatenng sediment and/or

wastewater treatment as appropnate and sediment transport and disposal

Pre-design baseline surveying activities arc not included in the scope of the AOC or the associated

Statement of Work (SOW) The baseline surveying activities were performed in 2003 by WDNR and

their contractor and are not detailed in this SAP/QAPP The WDNR performed survey control and both

topographic and bathymetnc mapping within and around the project area Pre-design activities in OUs 2 5

will be referenced lo these controls and presented on the base maps generated from these mapping efforts

or on equivalent controls/base maps generated to the same level of accuracy or higher Specifications for

the survey work are provided in the Sampling and Analysis Plan Lower Fox River Pre-design

Charactenzation Study (Retec et al 2003)

1 1

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ADDENDUM #1, Lower Fox River and Green Bay Site, Operable Units 2 through 5, Pre-Design Sampling Plan

Pursuant to the Administrative Order on Consent (Docket No V-W 04 C-781) the following represents Addendum #1 to the Lower Fox River and Green Bay Site, Operable Units 2 - 5 , Pre Design Sampling Plan submitted to WDNR and EPA on July 2 2004

A Procedural Changes to the SAP/QAPP

Following the respondents July 2 2004 submission of the modified Lower Fox River and Green Bay Site Operable Units 2 - 5 Pre Design Sampling Plan [including Sampling Analysis Plan (SAP) Quality Assurance Project Plan (QAPP), and the site specific Health and Safety Plan] that incorporated comments from WDNR and EPA dated June 14 2004, and observations dunng one full week of field activities the following specific changes were implemented for the Summer 2004 Sampling Effort These changes supercede/replace the (previously approved) June 7, 2004 draft

1 On the sample tracking forms, all subinterval samples from a given core marked with an A will be archived

2 All replicate samples will have subintervals archived for the same depths as the onginal core location when available

3 To adequately differentiate between OU 4 and OU 5 core locations locations on transects 4093 4094 and 4095 have been renamed as locations 5001 5002 and 5003, respectively The suffix (i e 01, 02 ) remains the same for consistency purposes This update was given to the field crews and changes made to the location maps on site (Note the map attached with this addendum contains the updated core location designations)

4 Equipment nnsates will be performed on the core sampling and processing equipment at the end of each ten (10) day shift The nnsate will be associated to all samples for that penod

5 All analytical results requinng a full data package will require 10% validation by MAKuehl This includes PCBs TOCs and contaminant mobility testing

B Fox River Oversight (P1700) OU 2-5 Field Observations

Dunng the week of June 28 2004, NRT provided oversight for the OU 2 5 Pre design characterization work in OU 4 Rick Fox and Jody Barbeau were present fi-om NRT BBLES provided the field team for the respondents NRT observed sediment

I I core collection activities and sub samplmg of cores in the shore based processing

facility

Six (6) issues arose dunng field activities These issues, along with the agreed resolutions are discussed below

1 Cores are sub sampled into six-inch segments starting from the top If the bottom section IS less than six inches, a decision was made to consider sections > 4 inches as a separate sample Sections < 4 inches will be combined with the section above AGREED This methodology has been implemented for the entire Summer 2004 Samphng Effort

2 Core samples are collected one day then processed the next day There will likely be settling of the core overnight If the sample settles such that the recovery becomes less than 75%, the station will not be re sampled Further, there will be no attempt to re-expand the core or apply a correction factor to the length recorded as collected in the field The thought is that some expansion of the surficial matenals occur dunng collection (as a result of the vibration of the conng device) and this is the matenal that settles to a condition similar to in situ conditions AGREED This methodology has been implemented for the entire Summer 2004 Samphng Effort

3 Core recovery in the field Some stations will have matenal that will preclude attainment of the 75% recovery requirement At the first station sampled dunng this survey two attempts were made to collect a core The recovenes were 58% (2 6 penetrated 1 5 recovered) and 65% (2 6 penetrated 1 7 recovered) A third attempt yielded an 83% recovery (within the 75% cntenon, however 1 0 was recovered from a core that penetrated 1 2 ) A decision was made to keep the best core In this case it was the 65% recovery core since this yielded more

information from the sediment column This process will be followed for fiiture cores that may not yield 75% recovery AGREED This methodology has been implemented for the entire Summer 2004 Samphng Effort

4 A grab sample is collected from the same location as each core The grab sample generally penetrates approximately 4 This grab sample will be analyzed as the surface layer The top 6 of each core will be archived The PRPs acknowledged that there is approximately 2 of matenal that is not being analyzed If only the surface grab is > 1 ppm but the remaining sections are < 1 ppm this area will likely not be dredged If the surface grab is < 1 ppm and any section below is > 1 ppm, the surface matenal will be dredge anyway Therefore, the approach is considered acceptable AGREED This methodology has been implemented for the entire Summer 2004 Samphng Effort

5 Permission was granted for En Chem to analyze PCBs prior to approval of the QAPP (which will not occur until on or after July 6) because En Chem will follow procedures that have been approved for the OU 1 QAPP AGREED

Depth of coring The WDNR and USEPA have and will continue to strongly recommend that all cores be advanced to native material However the PRPs have pre established target coring depths These are based on their poling efforts and other existing information Their goal is to core to two feet beyond this target depth or refijsal At times this could mean that they have not cored through the entire recent sediment column (e g silt) This is done for practical purposes as the deeper the core, the lower core recovenes They also pre cut core tubes to minimize waste and because shorter cores are easier to handle and process The nsk IS that the bottom section (that is always archived) will be analyzed and have > 1 ppm PCBs They acknowledge this Further they acknowledge that if the bottom section of the core does have > 0 5 ppm PCBs they will be required to resample Also they acknowledge that if they do not resample this station, they will be required to perform post-remediation sampling at this point to verify all materials with > 1 ppm PCBs have been removed If there are samples that do have PCBs greater than 0 5 ppm below the cored depth the sampling scheme should be modified to core to native for samples that will not have complete PCB analyses before conng activities are completed in 2004 Respondents agree with WDNR and EPA that all cores will be advanced to native material or to refusal (the practical limits of vibracoring methods) Respondents also agree that if the bottom section of the core exceeds 1 ppm PCBs there may be a need to re-sample that core location, potentially towards the end of the initial 2004 field sampling effort, to adequately inform the remedial design The need for supplemental coring will be discussed in the context of the Dredged Sediment/Disposal Work Group

C Additional Core Locations in OU 4B

Following completion of the Poling Survey in OU 4B it was determined that additional samples (cores) locations would be located in areas where increased definition of PCB distribution may be helpful for defining the dredge pnsm more accurately The proposed cores would provide increased control in the following areas

a ) Lenses of thick sediment accumulation as determined by the sediment thickness isopach map (attached)

b ) Areas of steep topography, where riverbed elevation and PCB distnbutions may change rapidly pnmanly in the vicinity of the Fort James turning basin

c ) Three previously unsampled side slips and inlets on the west side of the nver

In addihon to these new core locations that provide data on current PCB concentrations for the remedial design (under the CERCLA action) the respondents have voluntanly identified additional core locations within the OU 4B navigation

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channel that will be collected as part of the coordinated maintenance dredge planning (under WRDA) Figure 1 (attached), OU 4B Additional Core Locations and Onginal Cores identifies all the sample core locations to be collected dunng the Summer 2004 Sampling effort

D ADDENDUM #2, Lower Fox River and Green Bay Site, Operable Ll Units 2 through 5, Pre-Design Sampling Plan n Pursuant to the Administrative Order on Consent (Docket No V W 04 C-781) the '-' following represents Addendum #2 to the Lower Fox River and Green Bay Site Operable Units 2 - 5 Pre-Design Sampling Plan submitted to WDNR and EPA on j j July 2 2004 '-^

A Addendum#l, July 24, 2004 fl

Following the respondent s July 2 2004 submission of the modified Lower Fox River and Green Bay Site Operable Units 2 - 5 , Pre-Design Sampling Plan [including Sampling Analysis Plan (SAP) Quality Assurance Project Plan (QAPP) and the site specific Health and Safety Plan] that incorporated comments from _ WDNR and EPA dated June 14 2004 and observations dunng one full week of field I activities, specific changes were implemented for the Summer 2004 Sampling Effort These changes were documented in Addendum #1 to the Lower Fox River and Q Green Bay Site, Operable Units 2 - 5, Pre Design Sampling Plan IJ

B Addendum #2, Supplemental / Phase 2 Sampling, Spring 2005

Following completion of the Summer 2004 Sampling effort it was determined that additional sample locations would be located in areas where increased definition of PCB distnbution may be helpful for defining the dredge prism more accurately In addition it was determined that there was a need for additional geotechnical information to support the evaluation of the contingent remedy The Spnng 2005 Sampling objectives are as follows

a ) Further delineation of PCB distnbutions > 50 ppm along the prospective TSCA boundaries

b ) Further delineation of PCB distributions > 1 ppm along the outer boundanes of OU 3 and 4

c ) Determination of PCB distnbutions within the upstream off-limit boundaries of the DePere (OU 3) and Little Rapids (OU 2) Dams

d) Geotechnical analysis of the prospective Cat Island Confined Aquatic Disposal (CAD) area

The proposed sample location information and sampling requirements are included in table form in Attachment A These tables define the actual Vibracore Geotechnical Bonng and In-situ Vane Shear Test locations, and all proposed analytical parameters The Phase 2 Sediment Sampling Locations maps, for OU 2 through OU 5, are included in Attachment B

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All work performed dunng the proposed Spnng 2005 Sampling Effort will adhere to the procedures, methods and requirements of the Lower Fox River and Green Bay Site Operable Units 2 - 5 , Pre Design Sampling Plan [including Sampling Analysis Plan (SAP), Quality Assurance Project Plan (QAPP) and the site specific Health and Safety Plan], and the revisions descnbed in Addendum #1 (July 24 2004) NOTE The only change for the Spnng 2005 Samplmg is replacement of the In-Situ Vane Shear Test SOP included as Attachment C

C Schedule

The proposed schedule is as follows (subject to change due to weather delays)

Apnl 26 through 29 Equipment Mobilization and Processing Facility Set Up Mav 2 through Mav 9 Vibraconng in OU 3 & 4 (eight days) Mav 3 through Mav 10 Processing Samples from OU 3 & 4 (eight days) Mav 10 and 11 In situ Vane Shear Testing (one to two days) Mav 16 through May 19/20* Vibraconng Directly Upstream of the DePere (OU 3) and Little Rapids (OU 2) Dams Mav 23 through Mav 27 SPT Bonngs in OU 4 & 5 (five days)

(ADDENDUM #2 Lower Fox River and Green Bay Site Operable Units 2 through 5 Pre Design Sampling Plan Page 2)

I I

ADDENDUM NO 3 TO THE PRE-DESIGN SAMPLING PLAN

FOR OPERABLE UNITS 2, 3, 4, AND 5

LOWER FOX RIVER AND GREEN BAY SITE

BROWN, OUTAGAMIE, AND WINNEBAGO COUNTIES, WISCONSIN

SEDIMENT CHARACTERIZATION FOR DISPOSAL PURPOSES

Prepared by

Shaw Environmentai & Infrastructure Inc and

Anchor Environmentai L L C

Prepared for

Fort James Operahng Company Inc

NCR Corporation

June, 2005

I I

Table of Contents

1 INTRODUCTION 1 1 Project Background

2 CHARACTERIZATION OF MATERIAL FOR DISPOSAL PURPOSES 2 1 Dredge Plan Design Considerations 2 2 Methodology to Delineate Regulated Materials for Disposal Purposes

List of Figures

Figure 1 Typical Schemahc of Dredge Prism for Disposal Characterization

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Addendum No 3 to the Pre Design Sampling Plan * yft June 2005 Loiver Fox River and Green Bay Site i ^ ' 040179 01

I I

Introduction

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1 INTRODUCTION

This Pre-Remedial Design Field Sampling Plan Addendum No 3 describes the sampling

analysis and data interpretahon methodologies to be used to characterize sediments within

Operable Units (OUs) 2 3 4 and 5 of the Lower Fox River and Green Bay Site (Site) for disposal

purposes The requirements for remedial design (RD) are set forth in the Administrative Order

on Consent (AOC Docket No V-W 04 C 781) and associated Statement of Work (SOW) for

OUs 2 - 5 executed in March 2004 by Fort James Operahng Company Inc (Fort James) and

NCR Corporation (NCR) (collectively the Respondents ) in cooperahon with the Wisconsin

Department of Natural Resources (WDNR) and the U S Environmentai Protechon Agency

Region (USEPA)(collectively the Response Agencies ) The RD Work Plan and accompanying

Sampling and Analysis Plan (SAP) Quality Assurance Project Plan (QAPP) and site specific

Health and Safety Plan were approved by the Response Agencies in June 2004 Addenda Nos 1

and 2 to the Pre Design Sampling Plan were approved by the Response Agencies in September

2004 and May 2005 respechvely

1 1 Project Background

The PCB cleanup remedy for the Lower Fox River is set forth in Records of Decision (ROD)

for OUs 2-5 signed by WDNR and USEPA in December 2002 and June 2003 As set forth in

the AOC the Respondents have agreed to design the remedy for OUs 2 3 4 and 5

consistent with the ROD requirements (i e dredging and transport to an upland disposal

facility) and where appropnate to explore prachcable design alternatives The RD is

addressing the hming and sequencing of the remedial achon to account for the multifaceted

and multi-year components of the remedy The Response Agencies and Respondents are

collaborahvely seeking to resolve key technical and implementation issues through the

timely use of Work Groups and other communicahons The Respondents and Response

Agencies are also incorporating into the RD process the conhngent remedy provisions of the

ROD and such other supplemental investigations as proposed and/or conducted by the

Respondents under the AOC

The overall purpose of the pre-design investigation is to gather sediment field and analyhcal

data necessary to support the remedial design for the OU 2 5 cleanup remedy The various

pre design investigations will generate sediment characterization data essential to the

engineering design of the OU 2-5 remedial action Primary activities associated with the OU

Addendum No 3 to the Pre Design Sampling Plan » yft June 2005 Loiver Fox Rwer and Green Bay Site 1 ^ ' 040179 01

Introduction I I 2 5 pre design investigation include baseline surveying delineation of the 1 part per million

(ppm) polychlormated biphenyl (PCB) remedial action level (RAL) both horizontally and

vertically and physical characterization of the sediments as needed for design of the |

following remediation achvities removal (dredging) contingent capping, sediment

handling sediment dewatenng sediment and/or wastewater treatment as appropriate and

sediment transport and disposal

Addendum No 3 to the Pre Design Samphng Plan » ^ June 2005 Lower Fox Rwer and Green Bay Site 2 ^ ' 040179 01

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LOWER FOX RIVER OPERABLE UNITS 2 THROUGH 5

REIi\/IEDDAL DESIGN SAMPLING PLAN ADDENDUM

SHORELINE DATA COLLECTION PLAN

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SHAW ENVIRONMENTAL & INFRASTRUCTURE, INC AND n ANCHOR ENVIRONMENTAL, LLC

PREPARED BY

PREPARED FOR


NCR CORPORATION

MAY 31, 2006

Table of Contents

TABLE OF CONTENTS Project Management 1 1 1 1 Introduction 1 1 1 2 Project Organization 1 1

1 2 1 Project Team and Responsibilities 1 2 12 2 Shaw Subcontractors 1 3 12 3 Response Agency Communicahon Plan 1 3

1 3 Problem Definition/Background 1 3 1 4 Project Description and Schedule 1 4 1 5 Data Quality Objectives and Criteria for Measurement Data 1 4

15 1 Step 1 State the Problem 1 5 15 2 Step 2 Idenhfy the Decision 1-5 15 3 Step 3 Idenhfy Inputs to the Decision 1 6 15 4 Step 4 Define the Boundaries of the Study 1 8 15 5 Step 5 Develop a Decision Rule 1 8 15 6 Step 6 Specify Limits on Decision Errors 111 15 7 Step 7 Optimize the Design 111

1 6 Quality Objectives and Criteria 112 1 7 Special Training Requirements/Certification 112 1 8 Documentahon of Records 112

1 8 1 Field Forms 1 12 1 8 2 Photographs 1 13

Data Generation and Acquisition 2-1 2 1 Shoreline and In River Structure Survey Design 2 1 2 2 Sediment Sampling Process Design 2-3

2 2 1 Sediment Chemical Delineation 2 3 2 2 2 Sediment Geotechnical Characterization 2 4

2 3 Sampling Method Requirements 2 4 2 3 1 Stahon Location Positioning 2 5 2 3 2 Field Sample Identihcahon System 2 5

Assessment and Response Actions 3-1 I

4 Data Validation and Usability 4-1

5 References 5-1

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Table of Contents

LIST OF TABLES 1 Proposed Sample Locahons and Transects of Survey Interest

LIST OF APPENDICES A Shoreline and In water Feature Data Collechon Form

B SOP for GeoXT DGPS Unit

Q LIST OF FIGURES 1 Organization Chart

2 Sample Locahons - OU 4

3 Sample Locations - OU 2 and 3

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1 1 Introduction


(Anchor) have prepared this Remedial Design Shoreline Data Collection Plan (Addendum) for

the Lower Fox River Operable Units (OU) 2 through 5 on behalf of the Fort James Operahng

Company Inc (Fort James) and the NCR Corporation (NCR) as part of the Lower Fox River

OUs 2 5 Remedial Design This Plan is an addendum to the Lower Fox River OU 2 5 Pre design

Sampling Plan (SAP/QAPP) (Shaw and Anchor 2004a), which is a requirement of the March

2004 Administrative Order on Consent (AOC) for the Lower Fox River Operable Units 2 5

Remedial Design which was entered into by Fort James NCR the United States Environmentai


Natural Resources (WDNR) (USEPA 2004) This document has been prepared in accordance

with EPA Requirements for Quality Assurance Project Plans (USEPA 2001) and Region 5

Instructions on the Preparation of a Superfund Division Qualtty Assurance Project Plan (USEPA

2000a)

This Addendum consists of the shoreline structure and sediment data collechon design and

methodology combined with associated data quality objectives (DQOs) and criteria All field

activities associated with this Addendum are subject to the requirements of the Health and

Safety Plan (HASP) found in Appendix I of the SAP/QAPP (Shaw and Anchor 2004a) This

Addendum serves as guidance for the project (held and laboratory) personnel in conducting the

pre design shoreline data collechon activities

The purpose of the pre design shoreline data collection investigahon is to gather shoreline

condition and sediment field data from OUs 2 3 and 4 to support the detailed Intermediate (60

Percent) Remedial Design for the OUs 2 5 cleanup remedy The inveshgations described in this

Addendum will provide detailed information on shoreline conditions and provide sediment

data essential to the engineering design of the remedial achon along the edges of the nver and

adjacent to in water structures

1 1

I I LOWER FOX RIVER OPERABLE UNITS 2 THROUGH 5

I REMEDIAL DESIGN SAMPLING PLAN ADDENDUM

2007 SAMPLING

PREPARED BY

SHAW ENVIRONMENTAL & INFRASTRUCTURE, INC AND ANCHOR ENVIRONMENTAL, LLC

PREPARED FOR


NCR CORPORATION

AUGUST 13, 2007

I I

Table of Contents

TABLE OF CONTENTS Introduchon 1 1

1 Project Management 1 1 1 1 Project Organization 1 1

1 1 1 Project Team and Responsibilities 1 2 1 1 2 Shaw Subcontractors 1 2 1 1 3 Response Agency Communication Plan 1 2

1 2 Problem Definition/Background 1 3 1 3 Project Description and Schedule 1 3 1 4 Data Quality Objechves and Criteria for Measurement Data 1 3 1 5 Quality Objectives and Criteria 1 3 1 6 Special Training Requirements/Certification 1 3 1 7 Documentation of Records 1 3

2 Data Generation and Acquisition 2 1 2 1 Shoreline and In River Structure Survey Design 2 1 2 2 Sediment Sampling Process Design 2 1

2 2 1 Sediment Chemical Delineation 2 2 2 2 2 Sediment Geotechnical Characterization 2 2

2 3 Sampling Method Requirements 2 3 2 3 1 Station Location Positioning 2 3 2 3 2 Field Sample Identification System 2 3

3 Assessment and Response Actions 3 1

4 Data Validahon and Usability 4 1

5 References 5 1

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Table of Contents

LIST OF APPENDICES A Standard Operating Procedure for Piston Core

I LIST OF TABLES 1 Proposed Sample Locahons and Transects of Survey Interest

LIST OF FIGURES I 1 Sample Locations - OUs 2 and 3

2 Sample Locations - OUs 4 and 5


i l l


INTRODUCTION


(Anchor) have prepared this Remedial Design Sampling Plan Addendum for the Lower Fox

River Operable Units (OU) 2 through 5 on behalf of the Fort James Operating Company Inc

(Fort James) and the NCR Corporahon (NCR) as part of the Lower Fox River OUs 2 5 Remedial

Design This Plan is an addendum to the Lower Fox River OU 2 5 Pre design Sampling Plan

(SAP/QAPP) (Shaw and Anchor 2004a) which is a requirement of the March 2004

Admmistrahve Order on Consent (AOC) for the Lower Fox River Operable Units 2 5 Remedial

Design which was entered into by Fort James NCR the United States Environmentai


Natural Resources (WDNR) (USEPA 2004)

This Addendum consists of the collection of supplemental sediment field and analytical data

necessary to support the remedial design for the OUs 2 5 cleanup remedy In addition this

Addendum consists of the collection of additional investigations of selected shoreline areas to

provide detailed information on shoreline condihons and conditions of in-water structures

All sediment sampling analytical and shoreline investigation procedures will be consistent

with the previously approved Sampling Plan (Shaw and Anchor 2004) and associated Addenda

(Shaw and Anchor 2006) unless otherwise noted herein All field activihes associated with this

Addendum are subject to the requirements of the Health and Safety Plan (HASP) found in

Appendix I of the SAP/QAPP (Shaw and Anchor 2004)

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FINAL BASIS OF DESIGN REPORT

LOWER FOX RIVER AND GREEN BAY SITE BROWN, OUTAGAMIE, AND WINNEBAGO COUNTDES,

WISCONSIN

I Prepared by Shaw Environmentai & Onfrastructure, Inc

I Anchor Env i ronmenta l , LLC Foth & Van Dyke

I L imno-Tech

Prepared for Fort James Operatong Company, Inc

NCR Corporat ion

For SubmittaD to : Wiscons in Depar tment of Natural Resources

U.S. Envi ronmentai Pro tec t ion Agency

June 16, 2006

Table of Contents

DISTRIBUTION LIST

ACRONYMS

LIST OF TABLES

LIST OF APPENDICES

1 INTRODUCTION

1 1 PURPOSE

1 2 SITE DESCRIPTION

1 3 REMEDIAL DESIGN APPROACH

1 4 CLEANUP LEVELS AND PERFORMANCE STANDARDS

1 5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs) 1 6 REMEDIAL DESIGN OPTIONS

/ 6 I ROD Remedy 16 2 Optimized Remedy

1 7 RELATIONSHIPS TO OTHER PROGRAMS

1 7 1 Oil 1 Remedial Actions 17 2 Water Resources Development Act Authorities

2 SITE CHARACTERISTICS

2 1 SAMPLING AND ANALYSIS DATA

2 11 Pre Design Data 2 12 2004 Sampling and Analysis Program 2 13 2005 Sampling and Analysis Program

2 2 SUMMARY OF PHYSICAL SITE CHARACTERISTICS

2 2 1 Site Units and Uses 2 2 2 Site Constraints 2 2 3 Regional Geologic Conditions 2 2 4 Regional Hydraulic Conditions 2 2 5 Geotechnical Conditions 2 2 6 Standard Penetration Tests 2 2 7 Cone Penetration Tests

2 3 EXTENT OF P C B S IN LOWER FOX RIVER SEDIMENTS

2 3 1 Geostatistical Delineation of Remediation Boundaries 2 3 2 PCB Mass Estimates 2 3 3 Spatial Extent of PCBs Exceeding the RAL 2 3 4 Depth of Contamination (DOC) Relative to the RAL

2 4 CHARACTERIZATION OF MATERIAL FOR BENEFICIAL USE AND DISPOSAL PURPOSES

2 4 1 Dredge Plan Considerations 2 4 2 Methodology to Delineate Regulated Materials for Disposal Purposes

2 5 POTENTIAL FOR RECONTAMINATION

2 5 1 Ongoing Downstream Transport of PCB Contaminated Sediments in Lower Fox 2 5 2 Dredging Related Resuspension and Residuals 2 5 3 Ongoing PCB Loads 2 5 4 Long Term Monitormg of Sediment Water and Fish Tissue

3 ROD REMEDY SEDIMENT DREDGING

3 1 SITE CHARACTERIZATION CONSIDERATIONS

3 11 Dredged Material Transport Considerations 3 12 Dredgeability 3 13 Seasonal Construction Windows and Weather Related Work Impacts

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Table of Contents

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3 14 Federal Navigation Channel Considerations 59 3 2 EQUIPMENT SELECTION AND PRODUCTION RATES 59

3 2 1 Equipment Selection Process 60 3 2 2 Production Rate Considerations 65 32 3 Equipment Selection to Remove PI ospective TSCA Sediments 66

3 3 METHODOLOGY FOR DEVELOPING AND OPTIMIZING DREDGE PRISM DESIGN 67

3 3 1 Define the Neatline Area 68 3 3 2 Specify Site and Project Design Criteria 69 3 3 3 Designing the Dredge Prism 74 3 3 4 Iterative Refinements through the Remedial Design Process 75 3 3 5 Minimizing Volume vs Constnictability - Cost/Benefit Assessments 76

3 4 DREDGE PRISM DESIGN FOR SEDIMENTS POTENTIALLY SUBJECT TO TSCA DISPOSAL

REQUIREMENTS 77

3 5 DREDGE VOLUMES 77

3 5 1 Volume Estimates in the ROD 77 3 5 2 Basis for Computing Volumes 77 3 5 3 Sediment Volume Estimates 78

3 6 POTENTIAL IMPACTS FROM DREDGING 78

3 6 1 Slope and Structural Considerations 79 3 6 2 Navigation Considerations 80 3 6 3 Short term Water Quality Considerations 80 3 6 4 Dredge Residual Management 94 3 6 5 Noise and Air Quality Considerations 96

3 7 ROD REMEDY STAGING AREA REQUIREMENTS AND DESIGN 98

3 8 SEDIMENT HANDLING SEDIMENTS POTENTIALLY SUBJECT TO TSCA DISPOSAL REQ 101 3 8 1 Potential Offloading Procedures 102

3 9 SEDIMENT HANDLING NON TSCA SEDIMENTS 102 3 9 1 Hydraulically Removed Sediment Transport in OU 2 103 3 9 2 Hydraulically Removed Sediment Transport in OU 3 104 3 9 3 Hydraulically Removed Sediment Transport in OU 4 105

ROD REMEDY SEDIMENT TRANSPORT & DISPOSAL 106

41 SEDIMENT CHARACTERISTICS 107

4 11 Sediment Transport 108 4 12 Water Quality Considerations at the Disposal Site 111

4 2 POTENTIAL UPLAND DISPOSAL FACILITIES 120

4 2 1 Initial Screen of Disposal Alternatives - Step 1 121 42 2 Threshold Criteria Step 2 123 4 2 3 Implementability Criteria - Step 3 124 4 2 4 Modifying Criteria - Step 4 126

4 3 INITIAL SCREENING OF BENEFICIAL USE OPPORTUNITIES FOR SUITABLE MATERIAL 127

4 3 1 Desandmg Technologies 127 4 3 2 Materials Potentially Suitable for Beneficial Use 128 4 3 3 Description of PotenUal Beneficial Use Alternatives 128 4 3 4 Bayport Material Disposal Facdity 129 4 3 5 Regional Beach Nourishment 130 4 3 6 Landfill Construction 131 43 7 Manufactured Sod 132 4 3 8 Renard Island Closure 134 4 3 9 Roadway Construction 134 4 3 10 Upland Development 135 4 3 11 Wetland Construction 136 4 3 12 Sediment Cap Base Material 136

4 4 SCREENING OF BENEFICIAL USE ALTERNATIVES 137

44 1 InUial Screening 137 44 2 Threshold Criteria 137

111

Table of Contents

4 4 3 Implementability Criteria 4 4 4 Modifying Criteria 4 4 5 Evaluation Process

OPTIMIZED REMEDY

5 I DESIGN GOALS

5 11 New RD Information 5 12 ROD Capping Contingency 5 13 EPA Sediment Guidance 5 14 Sediment Stability Assessments

5 2 OPTIMIZED REMEDY DREDGE PLAN DESIGN

5 2 1 Define the Neatline and Dredge Prism 5 2 2 Sediment Characteristics 5 2 3 Equipment Selection 5 2 4 Dredge Volumes 5 2 5 Potential Impacts from Dredging

5 3 OPTIMIZED REMEDY - CAP DESIGN

5 3 1 Cap Design Criteria 5 3 2 Additional Optimized Remedy Cap Design Considerations 5 3 3 Capping Designs and Areas 5 3 4 Equipment Selection and Production Rates

5 4 OPTIMIZED REMEDY - SAND COVER DESIGN

5 5 WATER DEPTH AND HYDRODYNAMIC CONSIDERATIONS

5 5 1 Bathymetric Changes Resulting from the Optimized Remedy 5 5 2 Navigation and Recreational Use Impacts 5 5 3 Aquatic Habitat Functional Changes 5 5 4 Hydrodynamic Modifications

5 6 POST OPTIMIZED REMEDY SWAC ESTIMATES

5 6 1 Dredge Residual and Undredged Inventory Management 5 7 MONITORING MAINTENANCE AND INSTITUTIONAL CONTROLS FOR CAPPING

5 8 OPTIMIZED REMEDY - MATERIALS HANDLING TRANSPORT AND DISPOSAL

5 8 1 Initial Water Transport of Debris and Dredged Material 5 8 2 Potential Offloading Procedures 5 8 3 Potential Dewatering Options 5 8 4 Water Treatment Options 5 8 5 Staging Area Requirements 5 8 6 Beneficial Use Considerations for the Optimized Remedy 5 8 7 Most Promising Transport and Disposal Options

5 9 COMPARATIVE EVALUATION ROD AND OPTIMIZED REMEDIES

5 91 Threshold Criteria 5 9 2 Primary Balancing Criteria 5 9 3 Modifying Criteria 5 9 4 Comparative Evaluation Summary

CONSTRUCTION SCHEDULE AND SEQUENCING

6 1 OPERATIONS SEQUENCING

6 2 ROD REMEDY SCHEDULE

6 3 OPTIMIZED REMEDY SCHEDULE

MONITORING AND MAINTENANCE MEASURES

7 1 CONSTRUCTION QUALITY ASSURANCE PLAN ( C Q A P )

7 1 1 Operation Maintenance and Monitoring Plan (OMMP) 1 2 CONSTRUCTION WATER QUALITY MONITORING

7 2 1 Monitoring Locations 7 2 2 Pre Construction Monitoring

138 138 138

140

141 142 144 147 148 149 150 154 155 157 158 158 159 165 166 167 168 170 /// 171 171 172 172 174 176 178 178 179 179 180 181 182 183 186 188 190 196 196

200

200 201 204

207

207 207 208 208 208

IV


I Table of Contents

7 2 3 Water Quality Monitoring Schedule 209 7 2 4 Response Actions 209

7 3 AIR AND NOISE MONITORING 209

73 1 Air Monitoring 209 7 3 2 Noise Monitoring 211

7 4 POST DREDGE SEDIMENT CONFIRMATION SAMPLING 211

7 4 1 Confirmation Sampling Plan 212 7 4 2 Evaluation of Confirmation Sampling Results 214

7 5 CAP PERFORMANCE MONITORING 214

7 5 1 Cap Monitoring during Construction (CQAP) 215 7 5 2 Long Term Cap Performance Monitoring and Maintenance (OMMP) 216

7 6 LONG TERM MONITORING 220

76 7 LTMP Objectives 220 7 6 2 Water Quality Monitoring Plan 221 7 6 3 Fish Tissue Monitoring Plan 223

7 1 SCHEDULE 225

8 SUMMARY OF COST ESTIMATES 226

8 I COST ESTIMATING FRAMEWORK 226

8 2 ROD REMEDY COST ESTIMATE 227

82 1 Cost Estimate Assumptions 227 8 3 OPTIMIZED REMEDY COST ESTIMATE 232

8 3 1 Optimized Remedy Cost Estimate Assumptions 232 8 4 COMPARISON OF ROD REMEDY AND OPTIMIZED REMEDY COSTS 235

9 IDENTIFICATION OF ADDITIONAL STAKEHOLDER OUTREACH ACTIVITIES 236

9 1 STAGING/DEW ATERING SITES 236

9 2 DISPOSAL SITES 236

92 1 Non TSCA Disposal Alternatives Stakeholder ActivUtes 237 9 2 2 TSCA Disposal Alternatives Stakeholder Activities 237

9 3 BENEFICIAL USE ALTERNATIVES 237

9 4 TRANSPORTATION 238

9 5 FUTURE R D MILESTONES 238

10 REFERENCES 240

BASDS OF DESIGN REPORT

LOWER FOX RDVER AND GREEN BAY SITE BROWN, OUTAGAMIE, AND WINNEBAGO COUNTIES,

WISCONSIN

Executive Summary I I This Basis of Design Report (BODR) summanzes the results of the pre design investigation of

polychlorinated biphenyls (PCBs) in Operable Units 2 through 5 (OUs 2 5) of the Lower Fox River

delineates remediation areas and describes remedial approaches and technologies The subject area

encompasses the Lower Fox River from the Appleton Locks to the mouth and the Bay of Green Bay (the I

Site )

Following the 2003 Record of Decision (ROD) for the Site a 2004 Administrative Order on Consent

(AOC) was executed by the Fort James Operating Company Inc and NCR Corporation (collectively the

Participating Companies ) in cooperation with the Wisconsin Department of Natural Resources

(WDNR) and the U S Environmental Protection Agency (collectively the Response Agencies ) In the

AOC the Participating Companies agreed to design the remedy for the Site consistent with ROD

requirements and where appropriate to explore alternative remediation approaches Throughout the

remedial design (RD) process the Response Agencies and Participating Companies have collaboratively

and collectively addressed key technical and implementation issues through workgroups During the RD

process the Participating Companies and Response Agencies also addressed the contingent remedy

provisions of the ROD and other remedial concepts as provided under the AOC and the approved

Remedial Design Work Plan (RD Work Plan)

This report includes a summary of new information collected and analyses conducted during the RD

process to date In developing the RD Work Plan data available as of early 2004 were compiled and

summarized to provide an assessment of current information on the extent of contamination and physical

characteristics of the areas potentially subject to remediation Data gaps identified from this review were

addressed through extensive sampling in 2004 and 2005

The RD investigation included collecting sediment cores at more than 1 300 locations and analyzing

PCBs and physical parameters in more than 10 000 sediment samples The RD investigation generated

new sediment characterization data essential to the engineering design of the remedial action and included

detailed bathymetric surveys (by WDNR) delineation of the 1 part per million (ppm) PCB sediment

I I

boundary both honzontally and vertically detailed hydrodynamic investigations and analysis and

physical charactenzation of sediments The new information was used m performing engmeenng

evaluations of sediment dredging capping handling dewatering water treatment transport disposal

and/or beneficial reuse options

The new information collected dunng the RD investigation identified a number of site characteristics that

are substantively different than those contemplated at the time of the ROD Fmdings of the new data that

are particularly relevant to RD include

• PCB mass is not uniformly spread throughout the Site but tends to be concentrated in smaller

definable areas

• A small deposit of relatively highly contaminated near surface PCBs has been identified

downstream and west of the De Pere Dam

• Deeply buned contaminated sediments are present at depth (between approximately 6 to 13 feet

below mudline) below the bottom of the authonzed federal navigation channel Relatively

cleaner sediments overlie these areas

• Contaminated sediments were detected in several developed shorehne areas downstream of the

De Pere Dam In these areas it may not practicable to dredge all buried contaminants because

dredging could damage nver banks and stmctures along the shore line Based on the current and

ongoing evaluations and data gathenng during RD these nearshore areas may require engineered

capping to achieve an implementable remedy that is protective of human health and the

environment

• Several contiguous areas within the Site particularly in shallow water bench zones are

characterized by a relatively thin layer (often only 4 inches) of sediments that marginally exceed

1 ppm PCBs While such lower nsk areas collectively represent only about 0 5 percent of the

total PCB mass in the study area they represent roughly 18 percent of the remedial action area

• The limitations of modem dredging equipment in removing contaminated sediments have

recently been documented Post dredge sediment residuals which can make achievement of nsk

based goals difficult in dredging only remedies are now understood as inevitable due to the

inability of existing dredging equipment to remove all contaminated sediment within a dredge

prism

• There is limited landfill disposal capacity in Wisconsin and no regional landfill individually has

the capacity to accept the relatively large sediment disposal volumes that would be generated

under the ROD Remedy

This BODR evaluates different combinations of dredging capping of specific areas and other alternative

remedial measures to address areas of sediment containing over 1 ppm PCBs and to achieve the required

risk based surface weighted average PCB concentration (SWAC) consistent with the ROD AOC and

RD Work Plan As detailed m this BODR the ROD Remedy includes dredging of areas over 1 ppm

PCBs followed by placement of sand covers in approximately 50 to 60 percent of the dredged area to

address any post dredging low level contamination that may remain In addition the ROD Remedy

includes capping of certain areas over 1 ppm PCBs where side slope bulkhead and utility requirements

preclude dredging The ROD Remedy also includes monitored natural recovery for most of the nver

between the Appleton Locks and Little Rapids Dam and in Green Bay as set forth in the ROD

Geostatistical analyses of the RD data were used to charactenze the neatline boundary of sediments at

the Site exceeding 1 ppm PCBs This information was used to design the ROD Remedy dredge prism

The dredge prism represents the elevation grades and honzontal extent of sediment with concentrations

greater than 1 ppm PCBs that a dredging contractor would be required to remove In addition to the

dredge prism the RD incorporates an allowable overdepth for dredging The allowable overdepth is a

constant thickness of sediment below the required dredge prism to account for dredging equipment

accuracy and tolerances The dredge prism design utilizes multiple sets of data such as bathymetry

neatline depth and extent as defined by geostatistical methods and constructability factors Based on the

RD data and analyses the ROD Remedy dredge prism volume is approximately 7 6 million cubic yards

(cy) This sediment volume is more than 1 million cy greater than the volume contemplated by the ROD

This BODR also uses the considerable new information collected during RD to develop design

components associated with an Optimized Remedy The Optimized Remedy builds on the ROD

Remedy in that dredging would remove the bulk of the PCB mass in the nver While the Optimized

Remedy is pnmanly a dredging action it would remove a lower volume of sediment with PCB

concentrations near or below the 1 ppm RAL than the ROD Remedy The Optimized Remedy also

recognizes that because of dredge residuals or location specific engmeenng implementability or

practicability considerations supplemental or alternative technologies must be applied to achieve the

RAL and SWAC in some locations The Optimized Remedy includes engineered capping in selected

areas consistent with the contingent remedy provisions of the ROD Caps would be used only where

permanent stability and performance can be assured and without adversely affecting navigation

(commercial or recreational) flood capacity orhabitat uses of the nver

Like the ROD Remedy the Optimized Remedy uses sand covers for areas that have been dredged to

address any low level residual contamination In addition the Optimized Remedy uses this sand cover

technique to address certain non dredged areas that have sufficiently low PCB concentrations and

thicknesses to ensure protectiveness such as areas where no more than one sediment sampling interval

contains PCBs above 1 ppm and where the maximum PCB concentration is less than or equal to 2 ppm

I I I

I I I I I I I I I I I I I I I I

The Optimized Remedy applies these sand covers to specific areas of the Site based on the sediment

conditions of those areas as shown by the detailed new information collected dunng RD

The Optimized Remedy also uses combinations of remedial technologies to achieve ROD goals such as

dredging to a specified elevation followed by placement of an engineered cap The Optimized Remedy is

designed to meet the nsk based SWAC goals and remedial timeframe set forth in the ROD and will

address all sediment that exceeds 1 ppm PCBs The Optimized Remedy also has been designed to

maximize implementability considenng the constructability of different dredge and cap plans the

implementability of various transportation options the availability of upland disposal facilities and the

feasibility of beneficial reuse opportunities

The ROD Remedy and Optimized Remedy provide comparable levels of human health and environmental

protection The ROD predicted that the selected remedy would achieve acceptable fish tissue PCB

concentrations within approximately 20 to 60 years following completion of construction depending on

the specific receptor The Optimized Remedy is expected to achieve acceptable fish tissue PCB

concentrations in a shorter time frame pnmanly because it is expected to attain a lower post construction

SWAC within a shorter implementation penod than the ROD Remedy Both remedies are expected to

comply with applicable or relevant and appropriate requirements (ARARs)

The dredge plan design for the ROD Remedy removes approximately 92 percent of the near surface mass

within the remedial action area and approximately 83 to 89 percent of the total mass of PCBs in this area

Dredged sediments (approximately 7 6 million cy) will be disposed of in off site upland landfills

The dredge plan design for the Optimized Remedy includes many elements similar to the ROD Remedy

dredge plan but focuses dredging toward those areas where PCB mass removal can be more readily

achieved based on a core by core examination Similar to the ROD Remedy the Optimized Remedy is

primarily a dredging action and removes approximately 92 percent of the near surface mass within the

remedial action areas The Optimized Remedy removes approximately 62 to 66 percent of the total mass

of PCBs in this area or roughly 74 percent of the total mass of PCBs that would be removed under the

ROD Remedy Under the Optimized Remedy dredged sediments (approximately 3 7 million cy) can be

disposed of in a single existing landfill

Both the ROD Remedy and the Optimized Remedy are believed to be implementable but the Optimized

Remedy presents fewer uncertainties and implementability issues than the ROD Remedy for reasons such

as the following

• Utilizing the new information from the sampling data the Optimized Remedy focuses dredging

on areas of higher PCB concentrations and available mass and uses other remedial techniques

such as engineered capping to isolate and effectively remove PCBs from the environment in

I I

lower risk areas This results in a less complex dredge pnsm that is easier to implement from a

dredging perspective but includes a more complex combination of remediation technologies in

some reaches of the nver that requires careful planning and sequencing The ROD Remedy

dredge pnsm is significantly more complex and would be difficult to implement from a dredging

perspecUve

I I I I

The Optimized Remedy includes mechanical dewatering of dredged sediments to ensure that

sufficiently high solids contents are achieved for landfill disposal using processes similar to those •

implemented successfully during the earlier Fox River demonstration projects At this scale

redundant dewatenng equipment is planned to reduce operational uncertainty associated with

mechanical dewatenng Due to the larger dredge volumes the most effective material handling

method for the ROD Remedy is pipeline transport with a passive dewatering basin At the

volume of the ROD Remedy this combination has greater uncertainties and very few identified I

locations for the requisite dewatering basin (at any existing or proposed solid waste management

facility) Other factors such as varying dredge material physical characteristics and weather also

can affect the speed and effectiveness of a passive dewatenng system Any difficulties with

dewatering will increase the duration and cost of the ROD Remedy

• The lesser sediment disposal requirements associated with the Optimized Remedy allow for more

transport options including trucking and a single regional landfill would probably be sufficient

The relatively large disposal requirements associated with the ROD Remedy would require a

minimum of two separate landfill disposal facilities and pipeline transport Depending on the

specific site(s) targeted for disposal uncertainties relating to necessary state and local approvals

may extend the construction schedule In addition the pipeline easement negotiated by WDNR

for possible use under the ROD Remedy is subject to termination under certain conditions

Because of the large sediment volumes involved any unavailability of the pipeline to transport

sediments over the life of the project would have a major impact on the schedule and cost of the

ROD Remedy

• The ROD Remedy assumes concunent operation of 2 hydraulic cutterhead dredges discharging

into a common receiving tank and single pipeline for transport Such a transport system has not

been implemented in any other environmentai dredging project on the scale of the ROD Remedy

and its implementability under these circumstances is more uncertain than that of the single

hydraulic cutterhead dredge anticipated to be used under the Optimized Remedy

Engineered caps have been designed in both remedies with substantial margins of safety to ensure the

permanent containment of contaminated sediments The engineered caps provide protective and reliable

chemical isolation that prevents erosion of the underlying sediment even in the face of major erosion

events (e g floods propeller wash ice scour and wind waves)

I


I I I I

To ensure the adequacy and reliability of controls for an in situ cap a long term monitoring maintenance

and contingency response plan including institutional controls and repair (as needed) of damaged capping

areas will be part of the Optimized Remedy This is similar to controls normally included with upland

landfill confinement options The long term cap momtonng plan will include both physical integnty

monitoring (e g bathymetry surveys) and chemical analyses of surface sediments and cores collected

from within the capped areas to verify the continued protectiveness of the caps over time Many

institutional controls necessary to ensure long term cap integrity are already in place (e g no anchor

zones in the navigation channels and operation and maintenance agreements for the De Pere Dam) and

will be assessed further dunng later stages of design

Vitnfication was previously tested by the Response Agencies on a pilot scale The results of these

evaluations and supplemental analyses performed dunng RD revealed that large quantity vitnfication is

not a cost effective alternative

In summary

• Both remedies provide overall protection of human health and the environment and comply with

ARARs The remedies also provide comparable levels of long term effectiveness permanence

and reduction of toxicity mobility and volume

• The ROD Remedy relies on dredging as the primary remedial action and due to the very large

volumes involved has transport and dewatenng uncertainty The ROD Remedy will also

consume a large amount of the existing landfill capacity The Optimized Remedy also relies on

dredging as the primary remedial action but uses a combination of remedial actions that reduce

the dredged volume (particularly of sediments at or near the RAL) and requires less landfill

capacity

• The ROD Remedy will require 15 or more years to complete The Optimized Remedy can be

completed in 9 years providing more short term effectiveness The Optimized Remedy will also

achieve the long term objective of acceptable fish tissue PCB concentrations and will do so more

quickly than the ROD Remedy

• The ROD Remedy is estimated to cost S580 million The Optimized Remedy is estimated to cost

$390 million

A summary of the elements of the ROD Remedy and Optimized Remedy is presented in Table ES 1 A

summary of the comparative evaluation of the two remedies under the National Contingency Plan (NCP)

remedy selection cntena is presented in Table ES 2 Through its presentation of the RD investigation

results and the basis of design for both the ROD Remedy and the Optimized Remedy the BODR achieves

the goals and satisfies the requirements of the AOC the RD Work Plan and the ROD

Table ES-1 Summary of Lower Fox River Remedial Design Scenarios

Component Units

1 Prospective TSCA Dredging and Disposal

a Estimated Dredge Volume (OU 4)

b Dredging Method

c Dewatenng Method

d Assumed Handling Facility

e Assumed Off Site Transport Method

f Assumed Disposal Facility

g Altemate Disposal Facility

2 Non TSCA Dredging and Disposal

in situ cy

a Estimated Dredge Volume (with overdredge)

0U2

0 U 3

0 U 4

Total

b Dredging Method

c Desandmg Method

d Estimated Separated Sand Volume

e Assumed Desanding/Storage Facility

f Off Site Sediment Transport Method

g Estimated Disposal Wt (dewatered)

h Assumed Dewatenng Method

1 Assumed Disposal Facility

k Altemate Transport Method

1 Altemate Dewatenng Method

m Altemate Disposal Facility

n Average Production Rate

0 Approximate Dredging Duration

3 Beneficial Use of Separated Sand

a Estimated Beneficial Use Volume

b GP/Shell Staging Facility Fill

c Post Remedy Staging Area Use

d Non Remedial Beneficial Use Volume

e Non Remedial Beneficial Use Options

4 Sediment Caps and Covers

a Target Sand Volume

b Target Gravel Volume

c Target Quarry Spalls Volume

d Transport and Placement Method

5 Overall Performance Metrics

a Total Project Duration

b OU 3 /OU 4 SWAC

c Near Surface PCB Mass Removed

d Total PCB Mass Remediated

e Total PCB Mass Removed

f Total Cost

in situ cy

in situ cy

in situ cy

in situ cy

cy

tons

in situ cy/day

years

cy

cy

cy

cy

cy

cy

years

ppm PCBs

/ / /o

Present worth

RODiRemedy

210 000

Mechanical

Amendment

GP/Shell Property

Truck

EQ Wayne Disposal (Ml)

Peona Disposal Company (IL)

81000

716 000

6 552 000

7 349 000

2 Hydraulic Cutterheads

Desanding/Flotation/Attntion Scmbbing

530 000

GP/Shell Property

Mixing Tank / Pipeline

5 604 000

NR 213 Basin at Brown County South

Brown County South AND Onyx

N/A

Dewatenng Landfill

VandeHey

4 790

11 to 15

530 000

20 000

Site redevelopment & wharf use

510 000

See Section 4 3

660 000 (pnmanly residual cover)

65 000 (shoreline caps)

0

Barge & Rehandling Bucket

15 +

< 0 26 / < 0 25

9 2 /

9 9 /

83 to 8 9 /

$580 million

Optimized Remedy

200 000

Hydraulic Cutterhead

Mechanical Press

GP/Shell Property

Tmck

EQ Wayne Disposal (Ml)

Peona Disposal Company (IL)

24 000

204 000

3 258 000

3 486 000

1 Hydraulic Cutterhead

Desanding/Flotation/Attntion Scmbbing

225 000

GP/Shell Property (w/ shoreline fill)

Tmck

1 815 000

Mechanical Press

Onyx Hickory Meadows

Pipeline (w/out mixing tank)

Dewatering Landflll

Brown County South or VandeHey

3 190

8

225 000

150 000

Site redevelopment & wharf use

75 000

See Section 4 3

890 000

390 000

20 000

Barge & Rehandling Bucket

9

< 0 26 / < 0 25

9 2 /

99/o

62 to 66 / (74 / of ROD Remedy removal)

$390 million

I

CERCLA Criteria

1 Overall Protection of Human Health

2 Compliance with ARARs

3 Long Term Effectiveness and Permanence

4 Reduction of Toxicity Mobility or Volume through Treatment

5 Short Term Effectiveness

6 implementability

7 Cost (in millions of dollars)

8 Agency Acceptance

9 Community Acceptance

Table ES 2 Evaluation Criteria ROD Remedy

YES - Acceptable nsks achieved 20 to 60 years after completion of remedial actions depending on the receptor Long term monitoring plan (and maintenance and contingency response plan for shoreline capping) to ensure protectiveness

YES Expected to meet ARARs

YES Requires some degree of institutional controls (i e fish consumption advisories until the remedial action objectives are met) ROD Remedy removes approximately 92 percent of near surface PCB mass in OU 2 to 5 project area sediments Nearshore areas that cannot be dredged without adverse impacts to shoreline structures will be permanently contained below engineered caps

YES Overall mobility reduction through upland containment Possible treatment of approximately 210 000 cy of sediments potentially subject to TSCA disposal requirements pending venfication of performance implementability and cost effectiveness

YES Project duration estimated to range from 15 to 24 years depending on difficulties encountered with concurrent operation of 2 dredges and the time required to obtain pipeline easements and landfill disposal agreements (see Section 6 2)

YES Services materials and equipment are locally available (except hydraulic dredges) However landfill capacity is limited (at least 2 separate NR 500 landfills will be required for disposal) Necessary pipeline easements are also uncertain Operational difficulties of two dredges to a common pipeline are also uncertain Capping included in ROD Remedy near shoreline structures and utilities

$580 million (see Section 8 2)

ROD Remedy was previously selected by EPA and WDNR though certain changes to the remedy as described in this BODR are contingent upon approval from EPA and WDNR through an ESD or ROD Amendment

Pnor public opposition to pipeline easements and landfill disposal in certain locations

Comparison Optimized Remedy

YES Acceptable nsks achieved 20 to 60 years after completion of remedial actions depending on the receptor Long term momtonng maintenance and contingency response plan to ensure protectiveness

YES - Expected to meet same ARARs as ROD Remedy plus additional ARARs regarding capping

YES Requires some degree of institutional controls (i e fish consumption advisones until the remedial action objectives are met) Optimized Remedy removes approximately 92 percent of near surface PCB mass in OU 2 to 5 project area sediments Overall the Optimized Remedy removes approximately 74 percent of the PCB mass targeted for removal under the ROD Remedy Remaining sediment with PCB concentrations greater than 1 ppm will be permanently contained

YES - Overall mobility reduction through a combination of upland and cap containment Possible treatment of approximately 200 000 cy of sediments potentially subject to TSCA disposal requirements pending venfication of performance implementability and cost effectiveness

YES Project duration estimated to be approximately 9 years (see Section 6 3) Shorter penod of construction water quality impacts and other construction related impacts

YES Services matenals and equipment are locally available (except hydraulic dredges) Smaller sediment disposal volume allows more transport and landfill options (only one of several existing and/or potential future NR 500 landfills required) Capping included in Optimized Remedy near shoreline structures and utilities and in other areas of the site to optimize the remedy

$390 million (see Section 8 3)

Contingent upon approval from EPA and WDNR through an ESD or ROD Amendment

Public comments will be solicited through ESD or ROD Amendment process

I z m

g


I I I

LOWER FOX RIVER REMEDIAL DESIGN 60 PERCENT DESIGN REPORT FOR

2010 AND BEYOND REMEDIAL ACTIONS

VOLUME 2 OF 2

Prepared for

Appleton Papers Inc

Georgia-Pacific Consumer Products LP

NCR Corporation

For Submittal to



Prepared by

Anchor Environmental LLC

Tetra Tech EC Inc

J F Brennan Co Inc

Boskahs Dolman

June 2008

I

I

LOWER FOX RIVER BASELINE MONITORING PLAN

June 23, 2006

Prepared for

Fort James Operating Company Inc NCR Corporation

For Submittal to

Wisconsin Department of Natural Resources U S Environmentai Protection Agency

Prepared by

^ ^

S h a w " Shaw Enwonmental, Inc


and

\ / ANCHOR ^ $ L - . 7 E N V I R O N M E N T A L L L C


I I I I I I I I I I I

Lower Fox River Baseline Momtonng Plan Revision 0

6/23/2006

Table of Contents

I

I I I I

List of Tables List of Figures List of Appendices Acronyms and Abbreviations

1 0 Project Management and Objectives 11 12

13

14

Introduction Project Organization 121

122

123 124

125

Shaw/Anchor Team 1211 Project Coordinator 1212 Technical Director 1213 Baseline Momtonng Project Manager 1214 Field Quality Assurance Manager 1215 Analytical Quality Assurance Manager 1216 Baseline Momtonng Field Supervisors 1217 Corporate Health and Safety Manager 1218 Other Key Personnel Subconsultants/Subcontractors 1221 Analytical Laboratory Project Managers 1222 Laboratory Quality Assurance Managers 1223 Independent Data Quality Validator Oversight Agencies - General Responsibilities Wisconsin Department of Natural Resources (WDNR) Team 1241 Project Coordinator 1242 Project Manager 1243 Quality Assurance Manager 1244 Other Key Personnel U 8 Environmentai Protection Agency (EPA) Team 1251 Remedial Project Manager 1252 Quality Assurance Manager 1253 Other Key USEPA and Federal Agency Personnel

Communication Plan 131 132 133 134 135 136 137

Monthly Progress Reports Semimonthly Meetings Long Term Momtonng Work Group Electronic Data Transmittal Hard Copy Data Transmittal Notification Procedures Modifications to the Baseline Momtonng Plan

Problem Definition 141 142

Problem Statement Baseline Momtonng Objectives 1421 Establish Pre Remediation Conditions

VI

VI

VII

VIII

1 1 2 2 2 3 3 3 4 4 5 5 5 5 5 6 6 6 6 6 7 7 7 7 8 8 8 8 8 8 9 9

10 10 11 11 12 12

Lower Fox River Baseline Monitoring Plan Revision 0

6/23/2006

I I I

I

1422 Confirm Statistical Assumptions 12 1423 Refine Field and Laboratory Procedures 12

14 3 Long term Momtonng Objectives 13 1431 Monitor Reductions in Water and Fish Tissue Concentrations 13 1432 Monitor Progress toward Achieving Human Health Risk Goals 13 1433 Monitor Progress toward Achieving Ecological Risk Goals 13 ft 1434 Monitor Reductions in PCB Loadings to Green Bay 13 •

144 Relationship to Other Momtonng Activities 13 1441 Long term Momtonng Plan (LTMP) 14 I 1442 Constmction Quality Assurance Plan (CQAP) 14 • 1443 Operations Maintenance and Monitoring Plan (OMMP) 14

145 Modifications to ROD Momtonng 15 • 15 Background Information 17

151 Site Descnption 18 15 2 Lower Fox River Database 18 153 Site Water Quality 19

1531 Water Quality Summary Statistics 19 — 1532 Distnbution of Water Column PCB Concentrations 20 I 1533 Seasonal Trends in PCB Concentrations 20 1534 Seasonal Trends in PCB Loads 21 ->

154 Fish Tissue Quality 21 | 1541 Fish Tissue Summary Statistics 21 1542 Fish Consumption Acjvisones 22 1543 PCB Concentration by Species 22 1544 Spatial Distnbution of PCBs in Fish Tissue 22

15 5 Conceptual Site Model 23 1551 Predicted Reduction in SWAC due to Cleanup Action 23 1552 Predicted Reduction in Water Concentrations 23 1553 PCB Concentrations vs PCB Loads 23 1554 Seasonal Effects on Water Quality 24 1555 Bioaccumulation Exposure Pathways 24

16 Project/Task Descnption 24 161 Standards and Cntena 24

1611 Remedial Action Levels 24 1612 Human Health Target Tissue Goals 25 1613 Ecological Target Tissue Goals 25

16 2 Overview of Baseline Momtonng Activities 25 1621 Water Quality Plan 25 1622 Fish Tissue Plan 26

16 3 Special Equipment and Personnel Requirements 26 1631 Equipment Requirements 26 1632 Personnel Requirements 26

16 4 Baseline Momtonng Schedule 27 16 5 Preliminary Long Term Momtonng Schedule 27

17 Data Quality Objectives 28 171 Stepi State the Problem 28

I I I I I I I I I I

I I I

172 173

174

175 176

177

Lower Fox River Baseline

Step 2 Identify the Decisions Step 3 Identify Inputs to the Decision 1731 Existing Data 1732 Existing Momtonng Guidance 1733 Summary Statistics for PCBs in Water 1734 Summary Statistics for PCBs in Fish Tissue 1735 Key Inputs to Momtonng Plan Design Step 4 Define the Boundanes of the Study 1741 Geographic Boundanes 1742 Temporal Boundanes for Baseline Momtonng 1743 Temporal Boundanes for Long Tenri Momtonng Step 5 Develop Decision Rules Step 6 Specify Limits on Decision Errors 1761 Minimum Detectable Relative Difference (MDRD) 1762 Statistical Confidence and Power Step 7 Optimize the Design 17 71 Number of Samples 1772 Analytical Sensitivity

18 Documentation and Records 181 182 183 184

Data Tracking Electronic Data Management Hard Copy Data Management Evidence File

2 0 Data Generation and Acquisition 21 Water Quality Momtonng Plan

211 212 213 214 215

Number of Water Samples Water Quality Momtonng Stations Water Quality Momtonng Schedule Water Quality Sample Identification Water Quality Sampling Procedures 2151 Location Control 2152 USGS Quarter Point Sampling 2153 Field Parameters 2154 Green Bay Stratification

2 2 Fish Tissue Momtonng Plan 221 222 223 224 225 226

Number of Fish Samples Fish Tissue Momtonng Stations Fish Momtonng Schedule Target Fish Species and Size Ranges Fish Tissue Sample Identification Fish Sampling and Preparation Methods 2261 Location Control 2262 Fish Sampling Methods 2263 Compositing 2264 Fish Tissue Preparation 2265 Tissue Archiving

' Monitoring Plan Revision 0

6/23/2006

29 31 31 31 31 32 32 36 36 36 36 36 38 38 38 38 38 41 43 43 43 44 44 46 46 46 46 47 47 48 48 48 49 49 50 50 50 51 51 52 53 53 53 54 55 55

23

24

25

26

27

Sampl 231

232

Lower Fox River Baseline

e Handling and Custody Requirements Sample Handling Preservation Transportation and Storage 2311 Sample Packaging 2312 Shipping Airbills Cham of Custody 2321 Field Custody Procedures 2322 Laboratory Sample Receipt and Storage

Laboratory Analytical Methods 241

242

243

Water Analysis 2411 Analytical Parameters 2412 Methods and Reporting Limits Fish Tissue Analysis 2421 Analytical Parameters 2422 Methods and Reporting Limits Estimated Values below Reporting Limit

Quality Control Requirements 251 252 253

254 255

Precision Accuracy Representativeness 2531 Representativeness in Space 2532 Representativeness in Time Comparability Completeness

Instrument Testing Inspection and Maintenance 261 262

Field Instruments Calibration Laboratory Instruments Calibration

Data Management 271

272

273

Field Documentation 2711 Field Logbooks 2 712 Field Forms 2 713 Photographs Laboratory Documentation 2721 Laboratory Logbooks 2722 Laboratory Project File 2723 Electronic Data Storage Data Reporting 2731 Field Data Reporting 2732 Laboratory Data Reporting 2733 Electronic Data Deliverable (EDD) Format

3 0 Assessment and Oversight 31 32 33 34

Field Audits Laboratory Audits Reports to Management Corrective Actions 341 342

Field Corrective Action Stop Work Order

Momtonng Plan Revision 0

6/23/2006

55 55 56 56 56 56 57 57 57 58 58 58 58 58 59 59 60 60 61 61 62 62 63 64 64 64 64 64 64 64 65 65 65 66 66 67 67 67 69 70 70 71 72 72 72 73

IV


6/23/2006

343 Laboratory Corrective Action 73 3 5 Field Contingency Plans 75

3 51 Water Sampling Contingency Plan 75 352 Fish Sampling Contingency Plan 75

3 6 Assessment of Sample Size Adequacy 76 4 0 Data Validation and Usability 77

41 Data Review and Validation 77 411 Field Screening Data 77 412 Laboratory Data Validation and Venfication 78 41 3 Reconciliation with Data Quality Objectives 79

42 Data Analysis 80 421 PCB Summation 80

4211 Aroclors versus Congeners 80 4212 Minimum Detected Congeners 80

422 Blank Qualification 81 423 Statistical Analysis of Momtonng Data 81

4231 Descnptive Statistics 81 4232 Statistical Distnbution Tests 82 4233 Con-elations and Controlling Vanables 82 4234 Trend Analysis 82 4235 PCB Loading Calculations 84 4236 Effects of Ongoing Remedial Activities 84

5 0 References 85

I I

Lower Fox River Baseline Momtonng Plan Revision 0 6/23/2006

List of Tables

I I I Table 1 1 Water Column PCB Data Summary

Table 1 2 Fish Tissue PCB Data Summary Table 1 3 Fish Consumption Advisory Summary I Table 1 -4 Water Column PCB Summary Statistics ™ Table 1 5 Fish Tissue PCB Summary Statistics Table 1 6 Estimated Sample Sizes for Water and Fish Table 2 1 Water Sampling and Analysis Plan Table 2 2 Water Sampling Locations _ Table 2 3 Target Fish Species and Size Ranges H Table 24 Fish Sampling and Analysis Plan Table 2 5 Fish Habitat and Collection Methods Table 2 6 Sample Containers Holding Times and Preservation Requirements Table 2 7 Analytical Methods Detection Limits and Control Limits Table 2 8 PCB Congener Reporting Limits n Table 2 9 Quality Control Procedures Cntena and Corrective Actions - PCB Aroclors | {

Mercury and Conventionals Table 2 10 Quality Control Procedures Cntena and Corrective Actions - PCB Congeners m

List of Figures |

I Figure 1 1 Site Vicinity Map Figure 1 2 Project Organization Chart Figure 1 3 Downstream Trends in Water Column PCB Concentrations Figure 1 -4 Seasonal Trends in Water Column PCB Concentrations Figure 1 5 Seasonal Trends in Water Column PCB Loads Figure 1 6 Average PCB Concentrations in Fish Species Figure 1 7 Spatial Distnbution of PCBs in Fish Tissue Figure 1 8 Baseline Momtonng Schedule Figure 1 9 Long Term Momtonng Schedule Figure 2 1 Index Map for Sampling Location Plans Figure 2 2 Sampling Location Plan Lake Winnebago Figure 2 3 Sampling Location Plan OU 1 Figure 2-4 Sampling Location Plan OU 2A I Figure 2 5 Sampling Location Plan OU 2B " Figure 2 6 Sampling Location Plan OU 2C Figure 2 7 Sampling Location Plan OU 3 H Figure 2 8 Sampling Location Plan OU 4 • ' Figure 2 9 Sampling Location Plan Green Bay Figure 3 1 Field Decision Flow Chart for Fish Sampling I

I I I

VI

I Lower Fox River Baseline Monitoring Plan

Revision 0 6/23/2006

List of Appendices

Appendix A Pace and STL QA Plans and Certificates Appendix B Data Validation Qualifiers Appendix C Field Standard Operating Procedures Appendix D Laboratory Standard Operating Procedures Appendix E Electronic Data Deliverable Format Appendix F Health and Safety Plan Appendix G Field Sampling Details Appendix H Histonc PCB Congener Data Appendix I Other Supporting Data

VII


6/23/2006 Page 1 of 100

/ 0 Project Management and Objectives

11 Introduction

The Lower Fox River extends 39 miles from the outlet of Lake Winnebago over a series of locks and dams to the mouth of the river where it discharges into Green Bay (Figure 1 1) The Lower Fox River is the most industrialized nver in Wisconsin since the early 1900s water quality has been degraded by expanding industnes and commumties discharging sew age and industnal wastes into the nver Polychlonnated biphenyls (PCBs) were discovered in the Lower Fox River in the 1970s Due to their persistence in the environment PCBs remain the focus of current remedial design efforts

This Baseline Monitoring Plan (BMP) descnbes the sampling and analytical tasks necessary to charactenze water and fish tissue quahty in the Lower Fox River and Green Bay (the Site) pnor to initiation of full scale sediment remediation Data collected under this effort are in tended to serve as a baseline to monitor future progress toward achieving agency established Remedial Action Objectives (RAOs) for the Site A coordinated baseline monitoring program will be implemented throughout the entire Site inclusive of Operable Units (OUs) 1 through 5 although remedial design and remedial action are being addressed separately by two groups of Respondents in different parts of the Site

The requirements for remedial design (RD) in OU 2 5 are set forth in the Administrative Or der on Consent (AOC) and associated Statement of Work for OU 2 5 executed in March 2004 by Fort James Operating Company Inc and NCR Corporation (collectively the OU 2 5 Respondents ) in cooperation with the Wisconsin Department of Natural Resources and the U S Environmentai Protection Agency (collectively the Response Agencies ) Remedial design and remedial action in OU 1 are being addressed under separate agreements between the Response Agencies and the WTMl Company and P H Glatfelter Co (collectively the OU 1 Respondents )

Dredging of approximately 80 000 cubic yards (cy) of sediments containing roughly 240 kilograms (kg) of PCBs occurred within the upper reaches of OU 1 in 2005 and additional dredging will be performed in 2006 A Phase I removal action within the upstream reach of OU 4 targeting removal of approximately 140 000 cy of sediments containing roughly 6 000 kg of PCBs, is scheduled to occur between May and October 2007 Further staged remedial actions throughout the Site (i e , generally proceeding from upstream areas of OU 1 to the mouth of the Lower Fox River at the OU 4/OU 5 boundary) will likely occur over the next 10 to 15 years

s t ^ O^ ANCHOR <%tiaw F n ^ n w t u w i A1 A I n f m u i^ m* tnr I

I

I I I I I I

BASELINE MONITORING DATA REPORT 2006-2007

I I I I LOWER FOX RIVER, WISCONSIN

I Prepared for

H Georgia Pacific Consumer Products LP

and NCR Corporahon

I I I I I Chicago Illinois 60606

Prepared by


6650 SW Redwood Lane Suite 333

Portland Oregon 97224

Shaw Environmentai and Infrastructure Inc

100 S Wacker Suite 1130

LimnoTech Inc

501 Avis Drive

Ann Arbor Michigan 48108

For Submittal to


U S Environmentai Protechon Agency

July 2008

Table of Contents

1 INTRODUCTION 1 1 1 Site Description 1 12 Monitoring Objechves 2

1 2 1 Long Term Monitoring Objectives 3 12 2 Baseline Monitoring Objechves 4

3 4 3 3 Gizzard Shad PCB Concentration versus Length 17 3 4 3 4 Smallmouth Bass PCB Concentration versus Season 18

Lower Fox River » ^ July 2008 Baseline Monitoring Data Report i ' 040179 01

I I I

2 OVERVIEW OF BASELINE MONITORING PROGRAM 5 21 Fish Tissue Monitoring Program 5 H

2 1 1 Sampling Locations and Methods 5 2 1 2 Target Fish Species and Numbers 6 _ 2 1 3 Fish Compositing 6 I 2 1 4 Overview of Analytical Teshng 7

2 2 Water Quality Monitoring Program 7 2 21 Sampling Locations and Methods 7 2 2 2 Water Quality Field Parameters 8 2 2 3 Water Compositing Scheme 8 2 2 4 Overview of Analytical Teshng 9

I I I 3 FISH TISSUE DATA ANALYSIS 10

3 1 Deviations from the Baseline Monitoring Plan 10 3 1 1 Field Deviations 10 3 1 2 Laboratory Deviations 12 H

3 2 Field Completeness Assessment 12 3 3 Summary of Laboratory Data Validation 13 3 4 Stahstical Analysis of Fish Tissue Data 14

3 41 Descriphve Statistics 14 3 4 2 Normal/Lognormal Distnbuhon Testing 15 3 4 3 PCB Correlations and Controlling Variables 15 3 4 3 1 Linear Regression 15 3 4 3 2 Two-Variable Regression 16 •

I I

4 WATER QUALITY DATA ANALYSIS 19 4 1 Deviations from the Baseline Monitoring Plan 19

4 1 1 Field Deviations 19 4 1 2 Laboratory Deviations 21

4 2 Field Completeness Assessment 22 4 3 Summary of Laboratory Data Validation 23 4 4 Blank Correchon Procedures 24

4 5 Statistical Analysis of Water Quality Data 26 • 4 51 Descriptive Statishcs 26 * 4 5 1 1 Spatial Trends in PCB Concentrations 26

I I I

I I

Table of Contents

I 4 512 Seasonal Trends in PCB Concentrations 27 4 5 2 Normal/Lognormal Distnbuhon Teshng 28 4 5 3 PCB Correlahons and Controlling Variables 28 4 5 31 Linear Regression 29 4 5 3 2 Two-Variable Regression 29 4 5 3 3 Water Column Strahficahon in Green Bay 30

4 6 PCB Mass Loading Eshmates 30 4 61 Load Estimation Methods 31 4 6 2 Eshmated Annual Loads 31

5 PROGRAM ASSESSMENT AND RECOMMENDATIONS 33 51 Adaptive Management Strategies 33

511 Fish Sampling Program 33 512 Water Sampling Program 35

5 2 Adequacy of Sample Numbers 36 5 21 Adequacy of Fish Tissue Samples 37 5 2 2 Adequacy of Water Samples 37

5 3 Recommendations for Long Term Monitoring Program 38 5 3 1 Fish Monitoring Program Recommendations 38 5 3 2 Water Monitoring Program Recommendations 40

6 REFERENCES 42

List of Tables Table 3-1 Total PCB Concentrations in Fish Tissue Table 3 2 Field Completeness Summary for Fish Sampling Program Table 3 3 Descriptive Summary Stahshcs for Fish Tissue Data Table 3 4 Statistical Distribution Test Results for Fish Tissue Data Table 3 5 Two-Variable Regression Results - Fish Tissue PCBs vs Lipids and Length Table 4 1 Water Quality Field and Analyhcal Parameters Table 4 2 Field Completeness Summary for Water Quality Program Table 4 3 Water Column PCB Concentrations and Blank Correction Effects Table 4 4 Water Quality Summary Statistics Table 4 5 Statistical Distribution Test Results for Water Column Total PCB Concentrations Table 4 6 Two-Variable Regression - PCBs vs Temperature and Suspended Solids Table 4 7 Paired t Test Results for Green Bay Strahhcahon Table 4 8 Summary of PCB Mass Loading Estimates Table 5-1 Adaptive Management Strategies Used in the Baseline Monitoring Program Table 5-2 Eshmated Stahshcal Confidence for Detecting 50% Reduction in PCB

Concentrahon

Lower Fox Rwer «pft July 2008 Baseline hAonitoring Data Report i; 040179 01

Table of Contents

List of Figures Figure 1 1 Site Location Map Figure 2 1 Index to Sampling Maps Figure 2 2 Lake Winnebago Sampling Stations Figure 2 3 Operable Unit 1 Sampling Stations Figure 2 4 Operable Unit 2A Sampling Stations Figure 2 5 Operable Unit 2B Sampling Stahons Figure 2 6 Operable Unit 2C Sampling Stations Figure 2 7 Operable Umt 3 Sampling Stations Figure 2 8 Operable Unit 4 Sampling Stations Figure 2 9 Lower Green Bay Sampling Stations Figure 3 1 Box and Whisker Plots of Fish Tissue Data by Species Figure 3 2 Box and-Whisker Plots of Fish Tissue Data by Operable Unit Figure 3 3 PCB Correlations with Length and Lipids in Walleye Figure 3 4 PCB Correlations with Length and Lipids in Drum Figure 3 5 Gizzard Shad Length versus PCB Concentration Figure 3 6 Bass Seasonal Variahon - Lipids versus Concentrahon and Length Versus

Concentration Figure 4 1 Time Series of Field Blank and Method Blank PCB Concentrahons Figure 4 2 Box and Whisker Plots of Water Data by Operable Unit Figure 4 3 Seasonal Variation in Water Column PCB Concentrations Figure 4-4 Water Column PCB Correlations with Temperature and Suspended Solids Figure 4-5 Lower Fox River Hydrograph during Baseline Monitoring Year Figure 4 6 Estimated Annual PCB Load

List of Appendices Appendix A Sampling Coordinates Appendix B Field Sampling Forms Appendix C Fish Tissue Compositing Plans Appendix D Water Quality Field Parameters Appendix E Fish Tissue Laboratory Analytical Reports (Pace Analytical) Appendix F Fish Tissue Data Validation Reports (MAKuehl) Appendix G Water Quality Laboratory Analytical Reports (TestAmerica) Appendix H Water Quality Data Validahon Reports (MAKuehl) Appendix I PCB Congener Profiles in Water Appendix J LimnoTech Memoranda - PCB Load Estimates for the Fox River 2006-2007

Lower Fox Rwer » ^ July 2008 Baseline Monitoring Data Report m ' 040179 01

I I

I

Introduction

1 INTRODUCTION

This Baseline Monitoring Data Report presents the results of sampling and analysis to

characterize baseline water and hsh tissue quality condihons in the Lower Fox River and Green

Bay (the Site) prior to implementation of full scale sediment remediahon in Operable Units

(OUs) 2 to 5 of the Site Data collected under this effort are intended to serve as a baseline to

monitor future progress toward achieving agency established remedial action objectives

(RAOs) for the Site Between August 2006 and June 2007 a coordinated baseline monitoring

program was conducted throughout the entire Site in accordance with the Baseline Monitoring

Plan developed for the project (Shaw and Anchor 2006)

Lower Fox Rwer *yft July 2008 Baseline Monitoring Data Report 1 040179 01

0

\ ^ / ^ A N C H O R /-N Internal Agency Review Draft


'^te. '? BNViRONMBNTAL L L C w l t 3 W

llVlemoranclym To Jim Hahnenberg (United States Environmentai Protection Agency)

Greg Hill and Jim Killian (Wisconsin Department of Natural Resources)

From John Verduin Paul LaRosa Clay Patmont and Carl Shvers (Anchor Environmental)

Craig Jones (Sea Engineering Inc )

John Wolfe (Limno Tech Inc )

Danny Reible (University of Texas)

CC Paul Montney Chip Hilarides Richard Moser and Al Toma (Georgia Pacihc)

Roger McCready (NCR)

John Heyde (Sidley)

Steve Jawetz (Bevendge and Diamond)

George Hicks (Shaw)

Denis Roznowski (Foth & Van Dyke)

Mike Palermo (Palermo Consulting)

Rick Fox and Rich Weber (NRT)

Rich Johnson (Boldt)

Mike Jury (CH2M Hill)

Steve Jaeger and Garry Kincaid (Wisconsin Department of Natural Resources)

Date June 21 2005

Re Contingent Capping Remedy Comparative Evaluation Memorandum

EPA and WDNR June 21 2005

Page 2

Table of Contents

1 INTRODUCTION 3

2 PRELIMINARY IDENTIFICATION OF CAPPING AREAS 4 2 1 Authonzed Navigation Channel 5 2 2 Infrastructure and Utilities 6 2 3 PCB Concentrations Greater Than 50 ppm 7 2 4 Geotechnical Stability Analysis 9 2 5 Resultant (Post Cap/Dredge) Water Depth 10 2 6 Other Considerations 13 2 7 Potential Capping Areas 13

3 TECHNICAL DESIGN OF IN SITU CAP 15 3 1 Chemical Isolation of Contaminants and Bioturbation 17 3 2 Consolidation 25 3 3 Erosion—Stability of Cap Matenals in Response to Potential Scour Forces 27

3 3 1 Hydrodynamic Flows 28 3 3 2 Ice Scour 32 3 3 3 Wind Wave Induced Currents 33 3 3 4 Propeller Wash 36

3 4 Operational Considerations 36 3 5 Geotechnical Stability Considerations 38

3 51 Beanng Capacity 38 3 5 2 Slope Stability 44

3 6 Ebullition Considerations 45 3 7 Summary of Cap Design 47

4 COMPARATIVE EVALUATION WITH THE ROD SELECTED REMEDY 48 4 1 General Descnptions of Contingent and Optimized ROD Remedies 50 4 2 Threshold Cntena 52

4 2 1 Overall Protection of Human Health and the Environment 52 4 2 2 Compliance with Applicable or Relevant and Appropnate Requirements (ARARs) 53

4 3 Pnmary Balanang Cntena 55 4 3 1 Long Tenri Effectiveness and Permanence 55 4 3 2 Reduction of Toxicity Mobility or Volume through Treatment 56 4 3 3 Short Tem Effectiveness 56 4 3 4 Implementability 57 4 3 5 Cost 58

4 4 Modifying Cntena 67 4 4 1 Agency Acceptance 67 4 4 2 Community Acceptance 67

5 REFERENCES 68

I I I I I I

I I I

Internal Agency Review Draft

I I I

I I I t I I I I I I I I I I I I

I I


Pages

1 INTRODUCTION

This memorandum presents a comparahve evaluahon of the conhngent capping remedy

integrating capping and dredging technologies as appropriate with the dredging only remedy

selected in the Record of Decision (ROD) for Operable Units (OUs) 2 through 5 of the Lower Fox

River (WDNR and EPA 2003) This memorandum begins with an inihal conceptual design of

the contingent capping remedy and concludes with a comparahve evaluahon of the conhngent

capping/dredging remedy and the dredging only ROD remedy following the nine

Comprehensive Environmentai Response Compensation and Liability Act (CERCLA)

evaluation criteria As descnbed in the ROD one of the key CERCLA evaluation criteria in the

contingent remedy evaluation concems the relative cost of the contingent remedy Accordingly

this memorandum presents a detailed cost comparison of the two remedies including capital as

well as operation maintenance and monitoring plan (OMMP) costs The cost eshmates

presented herein have been developed to a 10 percent design level for both remedy options at a

similar level of detail

Consistent with the ROD and with the approved Remedial Design Work Plan for OUs 2 to 5

(Shaw/Anchor 2004a) the design goals for the conhngent capping remedy are as follows

> Reduce the flux of dissolved contaminants of concern (Polychlonnated Biphenyls

[PCBs]) into the surface water column

> Physically isolate contaminated sediment to protect ecological receptors considering

exishng and potential future sediment stability remobilization and other exposure

factors

> Stabilize contaminated sediment to reduce transport of PCBs to Green Bay and Lake

Michigan

These design objectives are intended to be general goals and are not viewed as specific cap

design or performance standards which are addressed in Section 3 of this memorandum for

the various aspects of the cap design

Figure 1 1 shows a flow chart of the process used to identify potenhal contingent capping areas

and the process to design the cap in these areas The flow chart describes a process that

includes the following three key elements



Page 4

1 Identify potenhal contingent capping areas

2 Develop conceptual designs of the contingent capping remedy to ensure protectiveness

3 Perform a comparative CERCLA evaluahon of the blended dredging and contingent

capping alternative relative to the ROD selected dredging only option

The evaluation and design of the contingent capping remedy is an iterahve process whereby

the initial technical design may be modihed in order to comply with the vanous criteria Each

of the three steps listed above is discussed in further detail in this memorandum In general

potential areas for capping were identified using preliminary exclusionary criteria defined in

Sechon 2 (exclusionary cnteria may be modified as appropriate during remedial design based

on a more detailed location by location evaluahon) The conceptual design of the cap was then

developed for those potential capping areas as discussed in Section 3 Section 4 presents the

comparison of the integrated dredging and capping remedy to the selected dredging only ROD

remedy using the nine CERCLA evaluation criteria



I xf- ANCHOR ^h -mJT e N V I R O N M B N T A L L L C

IMIemorandiiim

To 60 Percent Design File

From Paul LaRosa Clay Patmont and Kim Powell (Anchor Environmental)

cc

Date June 10 2008

Re Lower Fox River OUs 2 to 5 Engineered Cap Design Technical Memo

1 INTRODUCTION

This memorandum presents a summary of engmeenng evaluations necessary to complete the

remedial design (RD) of engineered sediment caps as part of the remedial achon for Operable

Units (OUs) 2 through 5 of the Lower Fox River consistent with the June 2007 Record of

Deasion [ROD] Amendment for OUs 2 5 This memorandum builds upon and incorporates by

reference preliminary cap designs presented in the OUs 2 5 Basis of Design Report [BODR]

(Shaw and Anchor 2006) approved in July 2006 by the U S Environmentai Protection Agency

(USEPA) and the Wisconsin Department of Natural Resources (WDNR) In addihon this

memorandum presents a summary of additional cap design evaluations that have been

conducted subsequent to the BODR which will be integrated into the final remedial design for

OUs 2 5

Addihonal engineering evaluations will be performed dunng subsequent stages of RD,

including standardized actions for post dredge management of undisturbed and generated

residuals considering feasibility and cost effectiveness Further design details will be

developed as part of the Construction Quality Assurance Project Plan (CQAPP) and Adaphve

Management Plan

5 5

I

I I

\ f ANCHOR

I I I I I I I I I I I I I I I

^ ^ ^ ^ ^ Marino Prdosalonalo ^ h m J ^ BNVIRONMBNTAL L L C L ! ^ ^ — t l La Crosse Wl

Remedial Design Tecl in ical Memorandum To Dredge Plan Design Sub Group Coordinators Tim Harrington (Hard Hat Services) and

Rich Weber (NRT)

From Clay Patmont Paul LaRosa Rebecca Desrosiers and Ram Mohan (Anchor)

Steve McGee (Tetra Tech) and Greg Smith (f F Brennan)

cc Jim Hahnenberg (U S Environmentai Protection Agency) Greg Hill (Wisconsin

Department of Natural Resources) George Berken (Boldt)

Date Apnl 11 2008

Re 60 Percent Design Dredge Plan Development Memorandum

This remedial design (RD) technical memorandum describes the generalized 60 Percent Design

dredge plan design process proposed for Operable Units 2 to 5 (OU 2 to 5) of the Lower Fox

River During inihal project planning leading up to the 30 Percent Design submittal and the

subsequent selechon of the remedial contractor in February 2008 the dredge plan design was

developed as a traditional set of engineered prisms (or boxes) each with a constant elevation or

slope For dredge only areas these engineered dredge prisms were designed to remove

sediments exceeding the 1 0 part per million (ppm) remedial achon level (RAL) for

polychlormated biphenyls (PCB) at an appropriate stahshcal confidence level as delineated

using a refined geostahshcal model developed using remedial design sampling data collected

between 2004 and 2005 However since the geostahshcally modeled surface for the Lower Fox

River is an undulating surface an engineered dredge plan designed with areas of constant

elevations inherently results in the planned removal of some volume of sediment with PCB

concentrations below the RAL typically resulhng in higher material processing and disposal

volumes and associated costs

An altemate dredge plan design approach based on the neatline (i e geostatishcally

modeled surface representing the extent of PCB contaminated sediments exceeding the RAL at

an appropriate statistical confidence level) was evaluated during the preliminary design

phases but was initially not selected because the dredging surface is more complicated and

requires precise removal techniques which not all remedial contractors can efhciently achieve

Instead the engineered dredge plan approach was selected for the 30 Percent Design because it

60 Percent Dredge Plan Design Development Memorandum April 11 2008

Page 2

was anhcipated to offer the most flexibility and bidder competition and potentially the lowest

overall cost during a tradihonal design bid build project However the Respondents recently

selected the Tetra Tech / J F Brennan team to join the RD team and perform the remedial action

(RA) in a design-build format J F Brennan is one of a few contractors that have experience

with neatline based dredge plans as recently demonstrated through their remedial dredging

work in OU 1 of the Fox River

The following sections describe the updated dredge design to be utilized in the 60 Percent

Design for remedial action areas involving dredging alone or prior to capping The 60 Percent

Design submittal will incorporate this approach with a particular focus on a detailed design for

areas targeted for dredging in 2009 (Volume 1 of the forthcoming 60 Percent Design submittal)

Subsequent submittals (e g 100 Percent Design - Volume 2 and annual RA Work Plans) will

present additional details of the dredge design for the subsequent years of dredging

I I

I I I I

2 » ii M m g Z S 3D a S * is 00 t Tl o E m 7) ^ 3

rt tn

m S

I Summary of Remedy Dehneatoon and Changes Since BODR

The attached provides a summary of the delmeahon of remedial achon areas by remedy type including the following

Summary of Dredge Volumes - This includes a comparison of design dredge volumes at each stage of the remedial design (Basis of Design Report 30 Percent Design and 60 Percent Design) Summary of Cap Areas - This includes a comparison of design cap areas at each stage of the remedial design (Basis of Design Report 30 Percent Design and 60 Percent Design) Summary of Remedial Achon Plans - This depicts the delmeahon of remedial achon areas (from the BODR and 60 Percent Design) and remedial design core locations

I I

Operable Unit

BODR°

Dredge Volume with 6 Inch Overdepth Allowance

(cy)

Summary o f Dredge Volumes

30 Percent Design

Required Dredge Volume

(cy)

Required Dredge Volume with 6-inch Overdepth

Allowance

(cy)

60 Percent Design **

Required Dredge Volume

(cy)

Required Dredge Volume with 6 Inch Overdepth

Allowance

(cy) TSCA

OU2

0 U 3

0U4/5

0

0

170 000

0

0

170 000

0

0

170 000

0

0

170 000

0

0

170 000

Non TSCA

OU2

OU3

OU4/5

Sub-Tofa/No/iTSC/l

Total OUs 2 5 Volume

24 000

204 000

3 143 000

3 371 000

3 541 000

19 900

160 400

2 915 300

3 095 600

3 265 600

24 500

221 200

3 388 000

3 633 700

3 803 700

24 600

155 700

3 388 000

3 633 700

3 803 700

31 300

214 400

3 388 000

3 633 700

3 803 700

Notes a The BODR volume summary excludes approximately 145 000 cy of sediment removed as part of the Phase 1 project b The total volume was not explicitly computed for the 60 Percent Design as minimal changes were made between the 30 and 60 Percent Designs

Cap Type

Cap A

CapB

CapC

All Engineered Caps

Shoreline Caps ' '

BODR

Total OU 2 5 [acres]

350

25

25

400

41

Summary o f Cap Areas 30 Percent Design

0 U 2 [acres]

6

1

0

7

0

OU 3 OU 4/5 Total OU 2 5 [acres] [acres] [acres]

54 155 215

16 37 54

0 ' 103 103

70 295 372

1 40 41

60 Percent Design

0 U 2 [acres]

3

2

0

5

2

OU 3 OU 4/5 [acres] [acres]

49 147

15 1 50

0 102

64 299

3 20

Total OU 2 5 [acres]

199

67

102

368

25

(a) Shoreline capping may be necessary in those areas where dredging will adversely impact the stability of existing slopes Areas presented above are preliminary estimates subject to further RD engineering evaluations including a location specific review of these areas during 60 Percent Design

I I I

I I I I I

•V 71 m C o s

m ? (fl 5 a So z -< 71 "72 m e u

m

I I I I I I I

LOWER FOX RIVER 30 PERCENT DESIGN

November 30, 2007

I I I I I I • Prepared for

IFort James Operating Company Inc

NCR Corporation

I I I I Prepared by

For Submittal to

Wisconsin Department of Natural Resources U S Environmental Protection Agency

/A^

S h a w ^ Shaw Environmental, Inc


and

t / ANCHOR i f isBST E N V I R O N M E N T A L L L C


Table of Contents

LIST OF TABLES

LIST OF FIGURES

ACRONYMS AND ABBREVIATIONS

1 INTRODUCTION 1 1 Site Description 1 2 Site Characteristics 1 3 Summary of OUs 2 to 5 Remedy 1 4 Organization of this Document

2 SITE CHARACTERISTICS 2 1 Sampling and Analysis Data

2 1 1 Pre Design Data 2 1 2 2004 Sampling and Analysis Program

2 1 2 1 Data Validahon 2 1 3 2005 Sampling and Analysis Program

2 1 3 1 Testing Methods (Chemical and Geotechnical) 2 1 3 2 Data Validahon

2 1 4 2006 Sampling and Analysis Program 2 1 4 1 Teshng Methods (Chemical and Geotechnical) 2 1 4 2 Data Validahon

2 1 5 2007 Sampling and Analysis Program 2 1 5 1 Teshng Methods (Chemical and Geotechnical) 2 1 5 2 Data Validahon

2 2 Summary of Physical Site Characteristics 2 2 1 Geotechnical Conditions

2 3 Summary of Spahal Extent of PCBs 2 3 1 Improved Geostatistical Delineation of Remediation Boundaries 2 3 2 Spatial Extent of PCBs Exceeding 1 0 ppm

2 4 Characterization of Material for Beneficial Use and Disposal Purposes 2 4 1 Beneficial Use Opportunihes 2 4 2 Sediments Subject to Non-TSCA Disposal Requirements 2 4 3 Sediments Subject to TSCA Disposal Requirements

3 SITE PREPARATION AND STAGING AREA DEVELOPMENT 3 1 Staging Area Requirements and Design 3 2 Potential Staging Area Locations 3 3 Real Estate Easement Requirements and Locahon Specific ARARs

3 3 1 Real Estate and Easement 3 3 2 Possible Location Specihc ARARs

4 SEDIMENT DREDGING

V

V

VII

1

3

3

4

7

9

9

9

9

10

10

11

11

11

11

12

12

12

12

12

13

14

14

17

17

17

18

18

20

20

21

23

23

23

28


I I

Table of Contents

I

4 1 Summary of Sediment Physical Properhes 28 4 1 1 Dredgeability 28 4 1 2 Seasonal Construchon Windows and Weather-Related Work Impacts 29 4 1 3 Federal Navigation Channel Considerations 29

4 2 Equipment Selechon and Production Rates 30 4 2 1 Equipment Selechon Process 30 4 2 2 Produchon Rate Considerahons 30 4 2 3 Equipment Selechon to Remove Prospective TSCA Sediments 31

4 2 3 1 Hydraulic Dredge Removal of Prospective TSCA Sediments 32 4 2 3 2 Mechanical Dredge Removal of Prospechve TSCA Sediments 32

4 3 Methodology for Developing and Optimizing Dredge Prism Design 33 4 3 1 Dehne the Neatline Area 33 4 3 2 Specify Site and Project Design Criteria 34 4 3 3 Iterative Design Refinements 35 4 3 4 Cost/Benefit Assessments and Contract Alternatives 37

4 4 Dredge Plan Design for Sediments Potentially Subject to TSCA Disposal Requirements 37 4 5 Dredge Plan Design Basis 38

4 5 1 Sediment Volume Eshmates 38 4 5 2 PCB Mass Eshmates 38

4 6 Potential Impacts from Dredging 39 4 6 1 Slope and Structural Considerahons 39 4 6 2 Short term Water Quality Considerahons 40 4 6 3 Dredge Residual Management 41 4 6 4 Noise and Air Quality Considerations 43

5 MATERIALS HANDLING TRANSPORT AND DISPOSAL 45 5 1 Transport of Debris and Dredged Material 45 5 2 Sediment Handling - Sediments Potentially Subject to TSCA Disposal Requirements 45 5 3 Sediment Handling - Non-TSCA Sediments 46

5 3 1 Mechanically Removed Sediment Transport in OUs 2 3 & 4 46 5 3 2 Hydraulically Removed Sediment Transport in OU 3 47 5 3 3 Hydraulically Removed Sediment Transport in OU 4 48

5 4 Mechanical Dewatenng Operahons 48 5 5 Water Treatment Operations 51 5 6 Equipment Selection and Produchon Rates 52

5 6 1 Process Flow of Major Unit Operations 52 5 6 2 Preliminary Mass Balance 56

5 7 Benehcial Use Considerahons 56 5 7 1 Desandmg Technologies 56 5 7 2 Materials Potenhally Suitable for Benehcial Use 57 5 7 3 Descnphon for Potential Benehcial Use Alternatives 57

5 8 Transport and Disposal of Dewatered Sediment and Debris 58

Table of Contents

5 9 Potenhal Upland Disposal Facilities 58

6 ENGINEERED CAP DESIGN 60 6 1 Cap Design Criteria 61

6 1 1 Chemical Isolahon Component 61 6 1 2 Bioturbation Component 62 6 1 3 Consolidahon Component 63 6 1 4 Erosion Protection Component 63

6 1 4 1 Supplemental Vessel Induced Propeller Wash Analysis 63 6 1 4 2 Supplemental Hydrodynamic Flow Analysis 65 6 1 4 3 Vessel Wake Analysis 66

6 1 5 Operational Component 69 6 2 Additional Cap Design Considerations 70

6 2 1 Federal Navigation Channel 70 6 2 2 Infrastructure and Utilities 71 6 2 3 Geotechnical Stability 72 6 2 4 Ebulhhon 73 6 2 5 Post Cap Water Depth 73

6 3 Capping Designs and Areas 73 6 3 1 Cap Designs 73

6 3 1 1 Engineered Shoreline Caps 75 6 3 2 Delineation of Cap Areas 17

6 4 Equipment Selection and Production Rates 78

7 SAND COVER DESIGN 80 7 1 Sand Cover Design and Areas 80 7 2 Equipment Selection and Production Rates 80

8 INSTITUTIONAL CONTROLS 81 8 1 Institutional Control Definitions 81 8 2 ROD Amendment Requirements 82 8 3 Specific Instituhonal Controls under Consideration for OUs 2 to 5 82

8 3 1 Water Use Restnctions 83 8 3 2 Construction Limitahons 85 8 3 3 Monitoring and Maintenance 86 8 3 4 Public Information and Advisories 87

9 CONSTRUCTION SCHEDULE AND SEQUENCING 89 9 1 Operations Sequencing 89 9 2 Construction Schedule 90 9 3 Contrachng Strategy 93

10 MONITORING MAINTENANCE AND ADAPTIVE MANAGEMENT 95 10 1 Construction Monitoring 95

Table of Contents

I I I

10 11 Post Dredge Venhcation 96 10 12 Engineered Cap and Sand Cover Placement Venficahon 101

10 2 Post Construction Operahon Maintenance and Monitoring 106 10 2 1 Cap Performance Monitoring and Maintenance 106 10 2 2 Natural Recovery Monitoring 110

10 3 Long Term Monitoring 111 10 31 LTMP Objechves 111 10 3 2 Water Quality Monitoring Plan 112 10 3 3 Fish Tissue Monitoring Plan 114

10 4 Adaptive Management 115 10 5 Monitoring Maintenance and Adaphve Management Schedule 117

11 REFERENCES 118

I w

Table of Contents I

List of Tables

Table 2 1 Low Water Pool Elevations in OUs 2 to 5 Table 2 2 Summary of all RD Geotechnical Data Table 2 3 Summary of Kriging Cross Validation Metrics for OUs 3 to 4 Table 4 1 Geotechnical Properties of Sediments Targeted For Dredging Table 4 2 Summary of Dredge Volumes Table 4 3 Lower Fox River PCB Mass Estimates Table 5 1 Built in Over Capacity Based on the Current Equipment Design Criterion Table 5 2 Effluent Discharge Monitoring Requirements Table 6 1 Engineered Cap Designs Developed in BODR Table 6 2 Summary of Cap Armor Recommendations for Recreational Propwash Table 6 3 Summary of Design Vessels for Vessel Wake Analysis Table 6 4 Summary of Cap Armor Recommendations for Vessel Wakes Table 6 5 Potential Shoreline Remedial Design Considerations Table 6 6 Summary Baseline Water Elevahons Table 6 7 Preliminary Eshmate of Shoreline Capping Areas Table 6 8 Summary of OUs 2 to 5 Engineered Cap Designs

List of Figures

Figure 1 1 Fox River OU2 to 5 Project Area Figure 2 1 Sample Locahon Map OUs 2 to 5 2004-2007 Figure 2 2 2006 Sample Location Map OUs 2 to 5 Figure 2 3 2007 Sample Locahon Map OUs 2 to 5 Figure 2 4 Spatial Distribution of PCB Mass OU 3 Figure 2 5 Spatial Distnbution of PCB Mass OUs 4/5 Figure 2 6 Estimated Depth of PCB Contamination OU3 Figure 2 7 Estimated Depth of PCB Contamination OU4 Figure 2 8 Eshmated Remediation Footprints OU 3 Figure 2 9 Estimated Remediation Footprints OUs 4/5 Figure 3 1 Sediment Dewatering & Process Water Treatment System Site Layout Figure 3 2 Sediment Dewatering & Process Water Treatment System Equipment Layout Figure 4 1 Sample Locations with Hard Substrate Immediately Underlying Contaminated

Sediments OUs 2 and 3 Figure 4 2 Sample Locations with Hard Substrate Immediately Underlying Contaminated

Sediments OUs 2 and 3 Figure 4 3 Example LOS Evaluation OU4 Figure 4 4 Dredge Plan for OUs 2 and 3 Figure 4 5 Dredge Plan for OUs 4 and 5 Figure 5 1 Process Flow Diagram Sediment Dewatering System Updated Mass Balance Figure 5 2 Process Flow Diagram 5000 GPM Water Treatment Figure 6 1 Maximum Predicted Shear Stress For Extreme Flow Event OUs 4 and 5


Table of Contents

Figure 6-2 Maximum Predicted Shear Stress Dunng June 23 1990 Flow Event OU 3 Figure 6 3 Maximum Predicted Shear Stress During June 23 1990 Flow Event OUs 4 and 5 Figure 6-4 Engineered Cap and Sand Cover Plan for OUs 2 and 3 Figure 6-5 Engineered Cap and Sand Cover Plan for OUs 4 and 5 Figure 9 1 Preliminary Construction Schedule Figure 10 1 Preliminary Example Layout of DMUs and DCUs for Example Area in OU 4

List of Appendices

Appendix A Dredge Design Support Documentahon Appendix B Cap Design Support Documentation Appendix C Engineered Plan Drawings Appendix D Outline of Technical Specihcations

Section 1 - Introduction

1 INTRODUCTION

This document presents the Preliminary (30 Percent) Design for the remediation of polychlonnated

biphenyls (PCBs) in Operable Units (OUs) 2 3 4 and 5 of the Lower Fox River and Green Bay Site

(Site Figure 1 1) Included in this document are summaries of remedial design (RD) analyses completed

to date along with engmeenng design plans cross sections and drawings that descnbe the design in

more detail The ongoing RD is also addressing the sequencing of remedial actions to account for the

multi faceted and multi year components of the OUs 2 to 5 PCB cleanup remedy

The PCB cleanup remedy for the Lower Fox River was originally set forth in Records of Decision

(RODs) for OUs 2 to 5 issued in December 2002 and June 2003 by the United States Environmentai

Protection Agency (USEPA) and the Wisconsin Department of Natural Resources (WDNR) under the

authonty of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as

amended 42 U S C §§ 9601 9675 In order to support detailed RD analyses consistent with the RODs

intensive data collection was performed in 2004 2005 including analysis of approximately 10 000

sediment samples collected from more than 1 400 locations Much of that new information was compiled

and analyzed in the Basis of Design Report (BODR) for OUs 2 to 5 (Shaw and Anchor 2006) approved

by USEPA and WDNR m July 2006 In June 2007 a ROD Amendment was issued by USEPA and

WDNR that made changes to parts of the remedy described in the original RODs in response to new

mformation obtained from the 2004 2005 data collection effort and analyzed in the BODR and also from

experience with pnor remediation activities in OU I (USEPA and WDNR 2007) The design of remedial

actions in OU 1 is being addressed under a separate agreement between USEPA WDNR and the WTMl

Company This RD submittal addresses only OUs 2 to 5

This 30 Percent Design submittal builds off of the BODR and ROD Amendment and was prepared

consistent with requirements set forth in the Administrative Order on Consent (AOC) and associated

Statement of Work (SOW) for OUs 2 to 5 (USEPA 2004) executed in March 2004 by Fort James

Operating Company Inc ' (Fort James) and NCR Corporation (NCR) (collectively the Participating

Companies ) in cooperation with the USEPA and WDNR (collectively the Response Agencies )

USEPA and WDNR are overseeing the RD process and design documents prepared by the Participating

Companies are subject to review and approval by USEPA and WDNR Throughout the RD process the

Response Agencies and Participating Companies have collaboratively sought to resolve key technical and

implementation issues through the timely use of workgroups and other communications

The requirements for the 30 Percent Design submittal are more specifically described in the Remedial

Design Work Plan (RD Work Plan) approved by the Response Agencies on June 28 2004 This 30

Percent Design submittal includes the following

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

D D D Q

D 0 D 0 D D 0 D D D 0 D D 0 Q

Section 1

Determination of specific technologies for sediment capping and dredging dewatenng transportation and disposal of dredged sediments and associated wastewaters

Design assumptions and parameters including design restnctions process performance cntena appropnate unit processes for the treatment train and expected removal or treatment efficiencies

Detailed plans cross sections drawings and sketches including design calculations

Outline of technical specifications

Proposed siting/locations of processes/construction activities

Proposed disposal locations based upon effectiveness implementability and cost

Preliminary constmction schedule including contracting strategy

Preliminary sections of the Construction Quality Assurance Project Plan (CQAPP) including draft sediment removal and cappmg venfication plans

Outline of the Operations Maintenance and Monitoring Plan (OMMP) including expected long term monitoring and operation requirements

Outline of the Adaptive Management Plan to modify the cleanup plan as appropriate in response to new information and experience during initial remediation activities in OUs 2 to 5

Outline of institutional control requirements and

Significant new information from other projects and activities

Subsequent design phases (e g 60 90 and 100 percent) will include further development and refinement

of the remedial design for OUs 2 to 5

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sir o 3 3g


I I I I

LOWER FOX RIVER REMEDIAL DESIGN 60 PERCENT DESIGN REPORT FOR 2009 REMEDIAL ACTIONS

VOLUME 1 OF 2

Prepared for

Appleton Papers Inc

Georgia Pacihc Consumer Products LP

NCR Corporation

For Submittal to



Prepared by


Tetra Tech EC Inc

J F Brennan Co Inc

Boskahs Dolman

June 2008

Table of Contents

1 INTRODUCTION 1 1 1 Site Descnphon 4 12 Site Characterishcs 5 1 3 Summary of OUs 2 to 5 Remedy 7 1 4 Summary of 2009 Remedial Actions 12

1 5 Summary of Remedial Achons in 2010 and Beyond 14 16 Report Organization 15

2 SITE CHARACTERISTICS 19 2 1 Sampling and Analysis Data 19

2 1 1 Remedial Design Data 19 2 1 2 Ongoing 2008 Sampling and Analysis Program 21

2 2 Summary of Physical Site Characteristics 21 2 3 Summary of Geotechnical Conditions 22 2 4 Summary of Spatial Extent of PCBs 22

2 41 Planned Refinements after 2008 Sampling 22 2 5 Charactenzahon of Material for Beneficial Use and Disposal Purposes 23

2 5 1 Debris Disposal Requirements 27 2 5 2 Sand and Coarser Sediments for Potential Beneficial Reuse 28 2 5 3 Sediments Subject to Non TSCA Disposal Requirements 30 2 5 4 Sediments Potentially Subject to TSCA Disposal Requirements 31

2 6 Project Datum 33

3 SITE PREPARATION AND STAGING AREA DEVELOPMENT 35 31 Staging Area Requirements 35 3 2 Staging Area Layouts and Site Development Plans 39

3 21 OU 4 - Former Shell Property Staging and Matenal Processing Facility 39 3 2 2 OU 2/3 - Little Rapids Staging Facility 50

4 SEDIMENT DREDGING 56 4 1 Summary of Sediment Physical Properties 56

4 1 1 Dredgeability 57 4 1 2 Seasonal Construchon Windows and Weather Related Work Impacts 63 4 1 3 Federal Navigation Channel Considerations 64

4 2 Equipment Selechon and Production Rates 64 4 21 Equipment Selechon Process 64 4 2 2 Shallow Water and Final Clean up Pass Dredging 73 4 2 3 Production Rate Considerations 73

4 3 Survey and Position Control 78 4 3 1 Equipment Position Control 79 4 3 2 Pre Construction and Post Construction Surveys 80 4 3 3 Survey Methods and Equipment 80 4 3 4 Data Management 81

6 0 / Design Report Volume 1 June 2008 Lower Fox River Remedial Design i 080295 03


Table of Contents

I

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4 3 5 Dredge and Survey Software 82 4 4 Dredge Plan Development 83

4 4 1 2009 Dredge Plan and Neatline Refinements 86 4 4 2 Channel Adjustments in Dredge Only Areas 92 4 4 3 Dredge Plan Design in Dredge and Cap Areas 92 4 4 4 Dredge Plan Design near Uhlihes and Infrastructure 93 4 4 5 Dredge Plan Design in Shoreline Areas 95

4 5 Sediments Potenhally Subject to TSCA Disposal Requirements 97 4 6 2009 Dredge Plan Design Summary 98

4 6 1 2009 Sediment Removal Eshmates 98 4 6 2 2009 PCB Mass Removal Eshmates 101 4 6 3 2009 Post-Dredge SWAC Eshmates 101

4 7 Management of Potential Impacts from Dredging 103 4 7 1 Best Management Practices for Dredging Operations 103 4 7 2 Dredge Residual Management 104 4 7 3 Slope and Structural Considerations 106 4 7 4 Short term Water Quality Considerahons 107 4 7 5 Noise and Air Quality Considerations 108

5 MATERIALS HANDLING TRANSPORT AND DISPOSAL 113 5 1 2009 Transport of Debris and Dredged Material 113

5 1 1 2009 Transport of Debris (Including Equipment Loading and Off-Loading) 113 5 1 2 2009 Transport of Dredge Materials (Including Equipment Loading and Off Loading) 114

5 2 Dredge Pipeline 117 5 2 1 Pipeline Design 120 5 2 2 Marking System 120 5 2 3 Booster Stations 125 5 2 4 Monitoring 126

5 3 Dredge Sediment Handling 126 5 3 1 Hydraulically Removed Sediment Transport 127 5 3 2 Contingency for Mechanically Removed Sediment Transport 127

5 4 Mechanical Dewatering Operations 128 5 4 1 Dewatenng Plant 128 5 4 2 Processing of Hydraulically Dredged Sediment 129 5 4 3 Processing of Mechanically Dredged Sediment 133 5 4 4 Segregahon of Sand 135 5 4 5 Monitoring 135 5 4 6 Best Management Practices for Dewatering Operations 137 5 4 7 Physical Characterishcs of Processed Material 138 5 4 8 Preliminary Mass Balances 139

5 5 2009 Water Treatment Operahons 144 5 5 1 Water Treatment System Overview 144

60 /o Design Report Volume 1 June 2008 Lower Fox River Remedial Design ti 080295 03

Table of Contents

5 5 2 Treatment Components 145 5 5 3 Effluent Performance Standards 152 5 5 4 Effluent Discharge Monitoring Requirements 154 5 5 5 Waste Load Allocation Transfer 154

5 6 2009 Transport and Disposal of Dewatered Sediment and Debris 155 5 6 1 Introduction 155 5 6 2 General Traffic Controls 155 5 6 3 Truck Cleanliness and Decontaminahon 156 5 6 4 OU 4 Former Shell Property Staging and Material Processing Facility Outbound 157 5 6 5 OUs 2 and 3 Little Rapids Staging Area 160 5 6 6 Beneficial Use Considerations 160 5 6 7 Upland Disposal Facilities 164 5 6 8 Spill Prevention Measures 165

5 7 Handling of Clean Import Materials 166 5 71 Former Shell Property 166 5 72 OUs 2 and 3 Staging Area 167

6 CONSTRUCTION SCHEDULE AND SEQUENCING 168 61 Operations Sequencing 169 6 2 Construction Schedule 169

7 LOCATION SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 173

7 1 Federal Clean Water Act and WDNR Chapter 30 Shoreline Fill Requirements 173 7 2 Treated Wastewater and Stormwater Discharge Requirements 174 7 3 Waterway Marker Requirements 175 7 4 Cultural Resource Requirements 175 7 5 Endangered Species Requirements 175 7 6 Waste Management Requirements 176 7 7 Substanhve Regulatory Requirements at the Little Rapids Staging Facility 176 7 8 Notifications to Local Mariners and Adjacent Property Owners 177

7 8 1 Nohfication to Local Mariners 177 7 8 2 Notification to Adjacent Property Owners 178

8 REFERENCES 180

List of Tables

Table 2 1 Hickory Meadows (non TSCA) Landfill Acceptance Criteria 31 Table 2 2 Low Water Pool Elevahons in OUs 2 to 5 34 Table 3 1 WTP Monitoring and Discharge Parameters 49 Table 4-1 Typical Dredging Equipment Production 76 Table 4 2 2009 Dredge Produchon Estimates 78

60 / Design Report Volume 1 June 2008 Lower Fox Rwer Remedial Design in 080295 03 I

Table of Contents

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Table 4 3 Lower Fox River 2009 PCB Mass Removal Estimates 101 Table 4 4 Lower Fox River 2009 Post Dredge SWAC Eshmates 102 Table 4 5 Maximum Recommended Sound Pressure Within and Between Zones 108 Table 5 1 Booster Station and Pump Informahon 125 Table 5 2 Sediment Dewatering Process Overview 132 Table 5 3 Estimated Daily Sediment Dewatenng Produchon 139 Table 5 4 Preliminary Mass Balance for Site Process Water 141 Table 5 5 Equipment Load Summary Analyses 142 Table 5 6 Dewatering Equipment Sizing Analyses 143 Table 5 7 Estimated Daily Sediment Dewatering Produchon 157 Table 5 8 Inihal Suitability Criteria for Beneficial Reuse 161 Table 5 9 Additional Analyses to Determine Reuse Suitability 162 Table 5 10 Beneficial Reuse Opportunihes 164 Table 7 1 Regulatory Agency/Local Authority Approvals & Submittals 179

List of Figures

Figure 1 1 Fox River OUs 2 to 5 Project Area 17 Figure 1 2 Planned 2009 Dredge Areas 18 Figure 2 1 Sample Location Map OUs 2 to 5 2004 - 2007 20 Figure 2 2 2009 Non-TSCA Dredge Matenal and Debns Characterization Process 25 Figure 2 3 2009 TSCA Dredge Matenal and Debris Characterizahon Process 26 Figure 3 1 Former Shell Property Staging and Material Processing Faality 37 Figure 3 2 Little Rapids Dam Staging Facility 38 Figure 3 3 Former Shell Property Site Development Plan 41 Figure 3 4 Preliminary Open Cell Bulkhead^ Sheetpile Plan 44 Figure 3 5 Little Rapids Dam Staging Area - Site Development Plan 53 Figure 4 1 Core Refusal Locations OUs 2 and 3 59 Figure 4 2 Core Refusal Locations OUs 4 and 5 60 Figure 4 3 2009 Dredge Plan OUs 2 and 3 99 Figure 4 4 2009 Dredge Plan OU 4 100 Figure 5-1 8-Inch Dredge Pipeline - Y Connection Detail 119 Figure 5 2a Dredge Pipeline Marking System 122 Figure 5 2b Dredge Pipeline Marking System 123 Figure 5-2c Dredge Pipeline Marking System 124 Figure 5-3 Sediment Desandmg and Dewatering Process Flow Diagram 131 Figure 5-4 Process Flow Diagram of Water Treatment System 151 Figure 6-1 Inputs to Construchon and Operahons Integrated Schedule 170 Figure 6 2 Sequence of Construchon and Operations Activities for 2008 2009 171 Figure 6 3 Integrated Construchon and Operations Schedule 2008 2009 172

60% Design Report Volume 1 June 2008 Loiuer Fox Rwer Remedial Design tv 080295 03

Table of Contents

6 0 / Design Report Volume 1 June 2008 Lower Fox Rwer Remedial Design v 080295 03

I I List of Appendices

Appendix A Dredging and Materials Handling Design Support Documentahon Appendix B Engineered Plan Drawings I Appendix C Specifications/Construction Work Plans for Key Design Elements • Appendix D Construction Quality Assurance Project Plan Appendix E Health and Safety Plan I Appendix F Community Protection Plan

I I I

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Introduction

1 INTRODUCTION

This document presents Volume 1 of the 60 Percent Design Report for the remediation of

polychlonnated biphenyls (PCBs) in Operable Units (OUs) 2 to 5 of the Lower Fox River and

Green Bay Site (Site Figure 1 1) This Volume 1 submittal presents the remedial design (RD) of

construction activities scheduled for implementation in 2009 including remedial action (RA) in

OU 2 upper OU 3 a portion of upper OU 4 and associated material processing and staging

facilihes The accompanying Volume 2 of this 60 Percent Design Report presents the RD for

remaining activities within OUs 2 to 5 to be performed in 2010 and beyond Included in the

Volume 2 document are summaries of sampling analysis and engineering evaluations

completed to date that form the basis for the overall RD in OUs 2 to 5

The PCB cleanup remedy for the Lower Fox River was originally set forth in Records of

Decision (RODs) for OUs 2 to 5 issued in December 2002 and June 2003 by the United States

Environmentai Protection Agency (USEPA) and the Wisconsin Department of Natural

Resources (WDNR) under the authority of the Comprehensive Environmentai Response

Compensahon and Liability Act (CERCLA) as amended 42 U S C §§ 9601 9675 The RD

requirements for OUs 2 to 5 were originally set forth in the Administrative Order on Consent

(AOC) and associated Statement of Work (SOW) for OUs 2 to 5 (USEPA 2004) executed in

March 2004 by Fort James Operating Company Inc ' (Fort James) and NCR Corporation (NCR)

(collectively the RD Respondents ) in cooperahon with the USEPA and WDNR (collectively

the Response Agencies ) USEPA and WDNR are overseeing the RD process and design

documents prepared by the RD Respondents are subject to review and approval by USEPA and

WDNR

In order to support detailed RD analyses consistent with the RODs intensive data collection

was performed beginning in 2004 resulhng in collechon and analysis of approximately 10 200

sediment samples from 1 900 locations at the Site through 2007 The resulhng sampling density

vaned across OUs 2 to 5 averaging approximately one core per 1 3 acres within the 2 200-acre

samphng area Much of that new informahon was compiled and analyzed in the Basis of

Design Report (BODR) for OUs 2 to 5 (Shaw and Anchor 2006) approved by USEPA and

WDNR in July 2006 The BODR concluded that approximately 1 170 acres of OUs 2 to 5

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

60 /o Design Report Volume 1 June 2008 Lower Fox River Remedial Design 1 080295 03

Introduction I exceeded the 1 0 part per million (ppm) PCB remedial achon level (RAL) specified in the RODs I

representing approximately 7 56 million cubic yards (cy) of in situ sediment In June 2007 a _

ROD Amendment was issued by USEPA and WDNR that made changes to parts of the remedy |

described in the original RODs in response to the new information analyzed in the BODR and

also from experience with prior remediation activihes at the Site (USEPA and WDNR 2007) | |

Brief summaries of site characterishcs and the OUs 2 to 5 remedy (including ROD Amendment

requirements) are provided in Sechons 1 2 and 1 3 respectively A more complete summary is •

provided in the accompanying 60 Percent Design Report Volume 2 submittal Design of RAs in

OU 1 is being addressed under a separate agreement between USEPA WDNR and the WTM I •

Company (WTM I)

The October 30 2007 revised AOC and the Admmistrahve Order for Remedial Achon (2007 RD

AOC) between the RD Respondents and the Response Agencies modified the previous SOW

and AOC to ensure consistency with the 2007 ROD Amendment On November 30 2007 the

RD Respondents submitted to the Response Agencies the Preliminary (30 Percent) Design for

OUs 2 to 5 The 30 Percent RD submittal included summaries of RD analyses completed to

date along with engineering design plans cross sechons and drawings that described the

design of the 2007 ROD Amendment remedy in more detail On February 1 2008 the Response

Agencies approved the 30 Percent Design Report with modificahons

Throughout the RD process the Response Agencies and RD Respondents have collaboratively

sought to resolve key technical and implementation issues through the timely use of

workgroups and other communications (e g technical memoranda) Many of the technical

memoranda and data collected during each phase of the RD have been included with the design

deliverable for that phase of the work (e g technical memoranda produced during the 30

Percent Design Phase were included with the 30 Percent Design) At the recommendation of

the Response Agencies each successive RD deliverable has not duplicated technical

memoranda data and other information that were previously included in or attached to an

earlier design deliverable Rather a RD Design Anthology is currently being developed that

will include all information that forms the basis of the design including the project analytical H

database technical memoranda documenting key parts of the RD and each RD submittal (e g

BODR 30 Percent Design 60 Percent Design etc ) The intent is to continually update the H

Design Anthology as the RD progresses in order to maintain a complete set of RD documents

I I I I I I I I I

60 / Design Report Volume 1 June 2008 Lower Fox River Remedial Design 2 080295 03

I I

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Introduction

I

The RD Respondents currently plan to submit the Design Anthology including RD informahon

through the 60 Percent Design phase in July 2008

This 60 Percent Design submittal builds on the BODR the ROD Amendment the 30 Percent

Design and follow on collaborahve workgroup efforts Since submittal of the 30 Percent

Design Report the team of Tetra Tech EC Inc (Tetra Tech) J F Brennan and Company Q F

Brennan) and Boskahs Dolman (collechvely the Tetra Tech Team ) have been selected to

perform the RA for OUs 2 to 5 The equipment and methods proposed by the Tetra Tech Team

have been included in this 60 Percent Design Report

The requirements for the 60 Percent Design submittal are more specifically described in the RD

Work Plan approved by the Response Agencies on June 28 2004 and the RD Work Plan

Addendum Schedule approved by the Response Agencies on April 29 2008 This 60 Percent

Design Report has also been developed in accordance with the Response Agencies Requirements

for the 60 Percent Design Report provided on April 29 2008 (USEPA 2008) Consistent with these

requirements the 60 Percent Design Report is being presented in two volumes This Volume 1

submittal presents the RD of actions that will be performed in 2009 while Volume 2 describes

those activities that will occur in 2010 and beyond This Volume 1 submittal includes the

following

Determination of specific technologies for sediment dredging dewatering

transportahon and disposal of dredged sediments and associated wastewaters to be

performed in 2009

Design assumptions parameters and specifications including design restnchons

process performance criteria appropriate unit processes for the treatment train and

expected removal or treatment efficiencies during 2009

Detailed plans cross-sechons drawings sketches and design calculations for specific

elements of the 2009 RA

Selected sihng/locations of 2009 processes and construction activities

Draft construchon schedule for the implementahon of the 2009 RA

Draft Construction Quality Assurance Project Plan (CQAPP) including verification

plans and contingency plans to be implemented in 2009

Draft 2009 Health and Safety Plan (HASP)

6 0 / Design Report Volume 1 June 2008 Lower Fox Rwer Remedial Design 3 080295 03

Introduction

The RD Work Plan approved by the Response Agencies in 2004 originally called for Agency

review and approval of a comprehensive 60 Percent Design Report followed by subsequent

design submittals and approvals of Pre Final (90 Percent) and Final (100 Percent) Design

Reports to allow further development and refinement of the RD for OUs 2 to 5 However in

order to facilitate inihahon of full scale RA at the start of the 2009 in water construchon season

pursuant to the Administrative Order for RA USEPA Docket Number V W 08 C 885 (the

Order USEPA 2007) the Response Agencies are considering providing approval of this

Volume 1 submittal (2009 actions) following a more streamlined RD submittal process and

schedule Subject to Response Agency approval of this streamlining option the RD

Respondents will address Response Agency comments on this 60 Percent Design Report

Volume 1 in the Final Design Volume 1 submittal (and 2009 RA Work Plan) currently targeted

to be submitted for Agency review on December 30 2008 Follow on Agency comments on the

60 Percent Design Report Volume 2 (2010 and later actions) would be addressed through

sequential submittal of the 90 Percent Design Volume 2 and Final Design Volume 2 Reports as

provided in the current AOC schedule In the event that the Response Agencies do not approve

the RD documentation streamlining approach outlined above the RD Respondents will

sequentially submit the Pre Final (90 Percent) and Final (100 Percent) Design Reports for

Volumes 1 and 2 in accordance with the approved RD Work Plan The Response Agencies will

make their determinahons on appropriate streamlining opportunities based on their review of

the completeness and level of detail provided in the overall 60 Percent Design submittal

Consistent with the RD Work Plan Addendum Schedule approved by the Response Agencies

on Apnl 29 2008 the Final Design Report Volume 2 and Long-Term Monitoring Plan (LTMP)

are currently targeted for Response Agency approval by May 2009 at which point the

requirements of the 2007 RD AOC will have been met Follow on RA activihes will occur under

the Order

I


I LOWER FOX RIVER REMEDIAL DESIGN 60 PERCENT DESIGN REPORT FOR

2010 AND BEYOND REMEDIAL ACTIONS

VOLUME 2 OF 2

Prepared for

Appleton Papers Inc

Georgia Pacific Consumer Products LP

NCR Corporation

For Submittal to



Prepared by


Tetra Tech EC Inc

J F Brennan Co Inc

Boskahs Dolman

June 2008

I

Table of Contents I 1 INTRODUCTION

1 1 Summary of OUs 2 to 5 Remedy 1 2 Summary of 2009 Remedial Actions 1 3 Summary of Remedial Actions in 2010 and Beyond

13 1 Dredging 13 2 Cap and Cover Placement 13 3 Long term Monitoring

1 4 Report Organization

1 2 6 7 8 9

10 11

2 SITE CHARACTERISTICS 2 1 Sampling and Analysis Data

2 1 1 Pre 2007 Remedial Design Data 2 1 2 2007 Sampling and Analysis Program 2 1 3 Ongoing 2008 Sampling and Analysis Program

2 2 Summary of Physical Site Charactenstics

2 3 Summary of Geotechnical Conditions 2 4 Summary of Spahal Extent of PCBs

2 4 1 Geostatistical Delineation of Remediahon Boundaries 2 4 2 Spatial Extent of PCBs Exceeding 1 0 ppm 2 4 3 Planned Refinements after Follow on Sampling

2 5 Characterization of Matenal for Beneficial Use and Disposal Purposes 2 6 Project Datum 2 7 Sequential Design Anthology

27

27

27

27

30

30

30

32

32

35

42

42

42

42

3 SITE PREPARATION AND STAGING AREA DEVELOPMENT 3 1 Staging Area Requirements 3 2 Staging Area Layouts and Site Development Plans (2010 and Beyond)

3 21 OU 2/3 - Little Rapids Dam Area 3 2 2 OU 4 - Former Shell Property

43

43

43

43

43

4 SEDIMENT DREDGING 4 1 Summary of Sediment Physical Properties 4 2 Equipment Selection and Production Rates

4 21 Equipment Selechon Process 4 2 2 Shallow Water and Cleanup Pass Dredging 4 2 3 Produchon Rate Considerations 4 2 4 Survey Methods and Equipment 4 2 5 Data Management 4 2 6 Dredge and Survey Software

4 3 Dredge Plan Development 4 4 2010 and Beyond Dredge Plan Design Summary 4 5 Management of Potential Impacts from Dredging

44

44

44

44

44

45

45

45

45

46

46

46

60/o Design Report Volume 2 Lower Fox Rwer Remedial Design

June 2008 080295 03

Table of Contents

I 5 MATERIALS HANDLING TRANSPORT AND DISPOSAL 47 5 1 Transport of Debris and Dredged Material 47 5 2 Dredge Pipeline 47 5 3 Dredge Sediment Handling 47

5 3 1 Hydraulically Removed Sediment Transport 47 5 3 2 Conhngency for Mechanically Removed Sediment Transport 48

5 4 Mechanical Dewatering Operahons 48 5 5 Water Treatment Operations 48 5 6 Transport and Disposal of Dewatered Sediment and Debris 48

5 6 1 Beneficial Use Considerations 48 5 6 2 Upland Disposal Facilihes 61 5 6 3 Spill Prevention Measures 61

5 7 Handling of Clean Import Materials for Capping 61 5 7 1 Former Shell Property 61 5 7 2 OUs 2 and 3 Staging Area 62

6 ENGINEERED CAP DESIGN 63 61 Cap Components 64

6 1 1 Chemical Isolation Component 64 6 1 2 Bioturbation Component 65 6 1 3 Consolidation Component 65 6 1 4 Erosion Protection Component 65

6 2 Addihonal Cap Design Considerahons 70 6 21 Federal Navigation Channel 70 6 2 2 Infrastructure and Utilihes 74 6 2 3 Geotechnical Stability 75 6 2 4 Post Cap Water Depth 76

6 3 General Cap Designs and Areas 77 6 4 Localized Cap Design Refinements 81

6 4 1 Engineered Shoreline Caps 81 6 4 2 Cap Design Near Uhlihes and Infrastructure 85

6 5 Delineation of Cap Areas 91 6 6 Engineered Cap Construchon 93

6 6 1 Material Staging 94 6 6 2 Equipment Selechon and Produchon Rates 95 6 6 3 Broadcast Spreading Delivery Equipment 97 6 6 4 Mechanical Placement 100

6 7 Position Control and Measurement 101 6 7 1 Geodehc Control 101 6 7 2 Verification of Placement 103

6 8 Sequencing of Capping Operations (2010 and beyond) 103

7 SAND COVER DESIGN 107 7 1 Sand Cover Design and Areas 107

60 / Design Report Volume 2 June 2008 Lower Fox River Remedial Design u 080295 03

Table of Contents

7 2 Equipment Selection and Production Rates 107 7 2 1 Material Staging 107 7 2 2 Broadcast Spreading 108

7 3 Postion Control and Measurement 109 7 3 1 Venficahon of Placement 109

7 4 Sequencing of Cover Operations (2010 and beyond) 109 •

8 INSTITUTIONAL CONTROLS 113

9 CONSTRUCTION SCHEDULE 116 9 1 Operations Sequencing 116 9 2 Construchon Schedule (2010 and Beyond) 119

10 MONITORING MAINTENANCE AND ADAPTFVE MANAGEMENT 122

11 COST ESTIMATE 124 111 Summary of Project Estimate 124 11 2 Pre Construchon Work Elements 125

1121 Pre Construchon Investigations (Line Item 1) 125 112 2 Remedial Design and Support (Line Item 2) 125

113 During Construction Work Elements 125 1 1 3 1 Mobilization/Demobilization (Line Item 3) 125 113 2 Staging Area Site Preparation (Line Item 4) 126 113 3 Site Support Construction Management and Monitoring (Line Item 5) 126 113 4 Debris Removal (Line Item 6) 127 113 5 Dredging (Line Item 7) 127 113 6 Sediment Dewatering and Water Treatment (Line Item 8) 127 113 7 Transport Disposal and Beneficial Reuse (Line Item 9) 128 113 8 Engineered Capping and Sand Cover (Line Item 10) 128

114 Post Construction Work Elements 128 1 1 4 1 Long Term Monitoring and Maintenance (Line Item 11) 128

12 LOCATION SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 131

12 1 Nohficahons to Local Mariners and Adjacent Property Owners 131 1 2 1 1 Notification to Local Mariners 131 1212 Notification to Adjacent Property Owners 132

13 REFERENCES 133

List of Tables

Table 2 1 Summary of RD Geotechnical Data Representative of 60 Percent Removal Areas Only 31

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Table 2 2 Summary of Knging Cross Validahon Metrics for OUs 3 4 and 5^ 34 Table 5 1 Beneficial Reuse Opportunihes 50 Table 6 1 Engineered Cap Designs Developed in BODR 64 Table 6 2 Summary of Cap Armor Recommendations for Recreational Propwash 67 Table 6 3 Summary of Preliminary Cap Armor Recommendahons for Vessel Wakes 69 Table 6 4 Potential Shoreline Remedial Design Considerations 74 Table 6 5 Summary Baseline Water Elevations 77 Table 6 6 Summary of Cap Delineation 79 Table 6 7 Summary of OUs 2 to 5 Engineered Cap Designs 80 Table 6 8 Potential Material Suppliers 95 Table 6 9 Engineered Cap Placement - Yearly Installation 2010 to 2017 104 Table 6 10 Area of Cap Placement by Year 106 Table 7 1 Potential Material Suppliers 108 Table 7 2 Sand Cover Placement Sequence 111 Table 7 3 Area of Sand Cover Placement by Year 112 Table 9 1 Anhcipated Dredging Produchon Rates 2010 Through Completion 117 Table 111 Summary of Cost Eshmates for OUs 2 to 5 Project 130

List of Figures

Figure 1 1 Fox River OUs 2 to 5 Project Area Figure 1 2 Planned 2009 Dredge Areas Figure 1 3 OUs 2 to 5 Remedial Achon Areas Figure 1 4 2010 to 2015 Dredging Areas Figure 1 5 2010 to 2017 Engineered Capping and Sand Cover Areas Figure 2 1 Sample Location Map OUs 2 to 5 Figure 2 2 Spahal Distribution of PCB Mass OU 3 Figure 2 3 Spatial Distribution of PCB Mass OUs 4/5 Figure 2 4 Estimated Depth of PCB Contammahon OU 3 Figure 2 5 Estimated Depth of PCB Contammahon OU 4 Figure 2 6 Eshmated Remediahon Footprint OU 3 Figure 2 7 Estimated Remediation Footprint OU 4/5 Figure 6 1 Conceptual Depichon of Propwash in Navigahon Channel Figure 9 1 Sequence of Recurring Operations for 2010 through Completion Figure 9 2 Construchon Schedule 2010 to Complete (part 1 of 2) Figure 9 2 Construction Schedule 2010 to Complete (part 2 of 2)

13 14 15 19 23 29 36 37 38 39 40 41 73 118 120 121

List of Appendices

Appendix A Dredging and Materials Handling Design Support Documentation Appendix B Cap Design Support Documentation Appendix C Engineered Plan Drawings

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Table of Contents

Appendix D Specifications/Construction Work Plans for Key Design Elements Appendix E Adaptive Management and Value Engineering Plan Appendix F Addendum to the Volume 1 Construction Quality Assurance Plan Appendix G Instituhonal Control Implementahon and Assurance Plan Appendix H Operation Maintenance and Monitoring Plan Appendix I Long Term Monitoring Plan Appendix J Health and Safety Plan

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Introduction

1 INTRODUCTION

This document presents Volume 2 of the 60 Percent Design Report for the remediahon of

polychlonnated biphenyls (PCBs) in Operable Units (OUs) 2 to 5 of the Lower Fox River and

Green Bay Site (Site Figure 1 1) The accompanying Volume 1 submittal presents the remedial

design (RD) of construchon activities scheduled for implementation in 2009 including remedial

action (RA) in OU 2 upper OU 3 a porhon of upper OU 4 and associated material processing

and staging facilities Volume 1 also describes the background of the OUs 2 to 5 RD/RA project

and including a Site descnphon which are not repeated herein This Volume 2 submittal

presents the RD for remaining activihes within OUs 2 to 5 to be performed in 2010 and beyond

Also included in this Volume 2 document are summaries of sampling analysis and engineering

evaluations completed to date that form the basis for the overall RD in OUs 2 to 5

This 60 Percent Design Report Volume 2 builds off of the Basis of Design Report (BODR Shaw

and Anchor 2006) the Record of Decision (ROD) Amendment (USEPA and WDNR 2007) the 30

Percent Design Report (Shaw and Anchor 2007) follow on collaborative workgroup efforts and

the 60 Percent Design Report Volume 1 As discussed in Volume 1 the Response Agencies and

RD Respondents have collaboratively sought to resolve key technical and implementation

issues throughout the RD process through the timely use of workgroups and other

communications (e g technical memoranda) Many of the technical memoranda and data

collected during each phase of the RD have been included the design deliverable for that Phase

of the work (i e technical memoranda produced during the 30 Percent Design Phase were

included with the 30 Percent Design) At the recommendation of the Response Agencies each

successive RD deliverable has not duplicated technical memoranda data etc that were

previously included in or attached to an earlier design deliverable Rather a RD Design

Anthology is currently being developed that will include all information that forms the basis of

the design including the project analyhcal database technical memoranda documenting key

parts of the RD and each RD submittal (e g BODR 30 Percent Design 60 Percent Design etc )

The intent is to continually update the Design Anthology as the RD progresses to maintain a

complete set of RD documents The Respondents currendy plan to submit the Design

Anthology including RD informahon through the 60 Percent Design phase in July 2008

The equipment and methods proposed by the team of Tetra Tech EC Inc (Tetra Tech) J F

Brennan and Company (J F Brennan) and Boskahs Dolman (collechvely the Tetra Tech

60 /o Design Report Volume 2 June 2008 Lower Fox River Remedial Design 1 080295 03

Introduction

Team ) selected to perform the RA for OUs 2 to 5 have been included in this 60 Percent Design

submittal This Volume 2 submittal includes the following

Determination of specific technologies for sediment capping dredging dewatering

transportation and disposal of dredged sediments and associated wastewaters

Design assumptions parameters and specificahons including design restnchons

process performance criteria appropriate unit processes for the treatment train and

expected removal or treatment efficiencies during 2010 and beyond

Detailed plans cross sections drawings sketches and design calculations

Selected sihng/locations of processes and construchon activihes

Draft construction schedule for the implementahon of the RA

Draft Adaptive Management and Value Engineering (VE) Plan to modify the cleanup

plan as appropriate in response to new information and experience during initial

remediation achvities in OUs 2 to 5

Addendum to the Volume 1 Construction Quality Assurance Project Plan (CQAPP)

including verification plans and contingency plans to be implemented in 2010 and

beyond

Draft Institutional Control Implementation and Assurance Plan (ICIAP)

Draft Operahons Maintenance and Monitoring Plan (OMMP) including expected long

term monitoring and operation requirements

Preliminary Draft Long Term Monitoring Plan (LTMP) for surface water and biota

Draft Capital and Operahon and Maintenance Cost Estimates for the entire RA

(including 2009 achvities)

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SDMS US EPA REGION V

DUE TO SCANNING EQUIPMENT CAPABILITY

LIMITATIONS, THE FOLLOWING PORTIONS OF THIS

DOCUMENT HAVE NOT BEEN SCANNED INTO SDMS:

SECTION 6

SECTION 7

SECTION 8

SECTION 9

SECTION 10

SECTION 11

EXCEL FILE: DESIGN ANTHOLOGY REMEDY CHANGE TABLE

EXCEL FILE: FOX DEPTH CORRECTED CHEMISTRY (2004-2008)

THESE FILES MAY BE VIEWED AT

FOX RIVER AR ADDITIONAL DOCUMENTS DISK #2

FILE 349171