REMEDIAL INVESTIGATION/ ALTERNATIVES ANALYSIS …

REMEDIAL INVESTIGATION/ ALTERNATIVES ANALYSIS REPORT

PHASE IA BUSINESS PARK

LACKAWANNA, NEW YORK BCP SITE NO. C915218

April 2012 0071-010-350 Revised May 2018 Revised September 2020

Prepared for:

Tecumseh Redevelopment Inc.

Prepared by:

In association with:

Bn v i ronme talng i neeri n gc ence,i

n

T Knvironmentalestoration,

REMEDIAL INVESTIGATION/ALTERNATIVES ANALYSIS REPORT Phase IA Business Park

Table of Contents

0071-010-350

i

1.0 INTRODUCTION .................................................................................................... 1 1.1 Background and History ............................................................................................................ 1 1.2 Purpose and Scope ...................................................................................................................... 2

2.0 SITE DESCRIPTION ............................................................................................... 3 2.1 Site Topography and Drainage .................................................................................................. 4 2.2 Remaining Site Structures .......................................................................................................... 4 2.3 Site Geology and Hydrogeology ............................................................................................... 4 2.4 Utilities .......................................................................................................................................... 5 2.5 Wetlands and Floodplains .......................................................................................................... 5 2.6 Previous Investigations............................................................................................................... 6 2.7 Interim Remedial Measures ....................................................................................................... 7

3.0 REMEDIAL INVESTIGATION APPROACH & RATIONALE ........................................ 8 3.1 General ......................................................................................................................................... 8 3.2 Constituents of Potential Concern ........................................................................................... 9 3.3 Soil/Fill Investigation ................................................................................................................. 9

Surface Soil ....................................................................................................................................... 9 Subsurface Soil/Fill .......................................................................................................................... 9 Methods of Chemical Analysis ........................................................................................................ 10

3.4 Groundwater Investigation ...................................................................................................... 10 Monitoring Well Installation ........................................................................................................... 11 Monitoring Well Installation Methodology ....................................................................................... 11 Monitoring Well Development ......................................................................................................... 11 Groundwater Elevation Measurements ............................................................................................ 11 Monitoring Well Sampling .............................................................................................................. 12

3.5 Quality Assurance/Quality Control ....................................................................................... 12 3.6 Data Usability Summary ........................................................................................................... 13 3.7 PCB Investigation ..................................................................................................................... 13 3.8 Barometric Condenser Cold Well Investigation ................................................................... 14

4.0 RI FINDINGS ....................................................................................................... 15 4.1 Field Observations .................................................................................................................... 15 4.2 Soil/Fill ....................................................................................................................................... 16

VOCs ............................................................................................................................................ 17 SVOCs .......................................................................................................................................... 17 Inorganic Compounds ...................................................................................................................... 17 Polychlorinated Biphenyls ................................................................................................................ 17

4.3 Groundwater .............................................................................................................................. 18 VOCs ............................................................................................................................................ 18 SVOCs .......................................................................................................................................... 18 Inorganic Compounds ...................................................................................................................... 18


Table of Contents

0071-010-350

ii

Polychlorinated Biphenyls ................................................................................................................ 19 Emergent Contaminants .................................................................................................................. 19 Groundwater Field Measurements ................................................................................................... 19

4.4 Electrical Equipment and Building Surfaces ......................................................................... 19 Completed Remedial Measures ........................................................................................................ 20

5.0 FATE AND TRANSPORT OF COPCS ..................................................................... 22 5.1 Airborne Pathways .................................................................................................................... 22

Fugitive Dust .................................................................................................................................. 22 Volatilization ................................................................................................................................. 22

5.2 Waterborne Pathways ............................................................................................................... 23 Surface Water Runoff ..................................................................................................................... 23 Leaching ......................................................................................................................................... 23 Groundwater to Surface Water Migration ....................................................................................... 23

5.3 Exposure Pathways ................................................................................................................... 24

6.0 QUALITATIVE HUMAN HEALTH EXPOSURE AND WILDLIFE IMPACT ASSESSMENT 25

6.1 Human Health Exposure Assessment ................................................................................... 25 Potential Receptors .......................................................................................................................... 25 Contaminant Sources ...................................................................................................................... 26 Contaminant Release and Transport Mechanisms ........................................................................... 26 Point of Exposure ........................................................................................................................... 27 Route of Exposure .......................................................................................................................... 27 Exposure Assessment Summary ..................................................................................................... 27

6.2 Fish and Wildlife Impact Assessment (FWIA) ..................................................................... 28 6.3 Qualitative Off-Site Exposure Assessment ........................................................................... 29

7.0 SUMMARY AND CONCLUSIONS ............................................................................ 31

8.0 DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES AND GENERAL RESPONSE ACTIONS ...................................................................................................................... 34

8.1 Remedial Action Objectives .................................................................................................... 34 8.2 General Response Actions ....................................................................................................... 35 8.3 Standards, Criteria and Guidance (SCGs) ............................................................................. 35

Chemical-Specific SCGs .................................................................................................................. 36 Location-Specific SCGs .................................................................................................................. 37 Action-Specific SCGs ..................................................................................................................... 37

8.4 Future Use Evaluation .............................................................................................................. 38

9.0 VOLUME, NATURE, AND EXTENT OF CONTAMINATION .................................... 39 9.1 Comparison to USCOs ............................................................................................................ 39 9.2 Comparison to CSCOs ............................................................................................................. 39


Table of Contents

0071-010-350

iii

9.3 Hotspot Soil/Fill ....................................................................................................................... 40

10.0 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES ...................... 42 10.1 Development of Alternatives .................................................................................................. 42 10.2 Evaluation of Alternatives ....................................................................................................... 42

Alternative 1: No Action ............................................................................................................. 44 Alternative 2: Unrestricted-Use (Track 1) Cleanup ...................................................................... 45 Alternative 3: Restricted-Use (Track 4) Cleanup with Placement of Soil Cover System Prior to

Redevelopment .............................................................................................................................................. 47 Alternative 4: Restricted-Use (Track 4) Cleanup with Deferred Cover System during Site

Redevelopment .............................................................................................................................................. 52 10.3 Proposed Remedy ..................................................................................................................... 54

11.0 POST-REMEDIAL REQUIREMENTS ..................................................................... 56 11.1 Final Engineering Report ......................................................................................................... 56 11.2 Site Management Plan .............................................................................................................. 56

Engineering and Institutional Control Plan ................................................................................... 57 Site Monitoring Plan .................................................................................................................... 58 Operation and Maintenance Plan .................................................................................................. 58 Inspections, Reporting, and Certifications ....................................................................................... 59

11.2.4.1 Inspections .................................................................................................................... 59 11.2.4.2 Reporting ..................................................................................................................... 59 11.2.4.3 Certification ................................................................................................................. 60 11.2.4.4 Corrective Measures Plan ............................................................................................. 61

12.0 REFERENCES ...................................................................................................... 62


Table of Contents

0071-010-350

iv

LIST OF TABLES

Table 1 Summary of April 2007 Analytical Data

Table 2A Electrical Transformer Inventory and Sampling Program

Table 2B Summary of Floor Wipe and Floor/Soil Sampling Program

Table 3 Groundwater Monitoring Well Construction Details

Table 4 Summary of Groundwater Elevations (2011-2016)

Table 5A Summary of Surface Soil Analytical Data Compared to USCOs

Table 5B Summary of Surface Soil Analytical Data Compared to CSCOs

Table 6A Summary of Subsurface Soil Analytical Data Compared to USCOs

Table 6B Summary of Subsurface Soil Analytical Data Compared to CSCOs

Table 7 Summary of Groundwater Analytical Data (2010-2016)

Table 8 Summary of Emergent Contaminants Groundwater Analytical Data

Table 9 Summary of Electrical Transformer Oil Analytical Data

Table 10A Summary of Building Surface Wipe and Floor/Soil Sample Data (June 2010)

Table 10B Summary of Building Post Cleaning Wipe Samples (March 2016)

Table 11 Potential Chemical-Specific SCGs

Table 12 Potential Location-Specific SCGs

Table 13 Potential Action-Specific SCGs

Table 14 Soil/Fill Alternative 2: Excavation of Impacted Soil/Fill to USCOs

Table 15 Soil/Fill Alternative 3: Hotspot Soil/Fill Removal with Placement of Soil Cover System Prior to Site Redevelopment

Table 16 Soil/Fill Alternative 4: Hotspot Soil/Fill Removal with Deferred Cover System During Site Redevelopment


Table of Contents

0071-010-350

v

LIST OF FIGURES

Figure 1 Site Location and Vicinity Map

Figure 2 Site Plan

Figure 3 RI Sample Locations

Figure 4A Fill Unit Isopotential Map (2/8/2011)

Figure 4B Fill Unit Isopotential Map (2/23/2016)

Figure 5 Soil/Fill Hotspot Areas to be Excavated

APPENDICES

Appendix A Previous Investigations Analytical Data Packages (included on CD)

Appendix A-1 Corrective Measures Study: NRWT

Appendix A-2 April 2007 Sampling Event

Appendix A-3 Site-Wide Asbestos Abatement Closeout Report

Appendix B RI Analytical Data Packages (CD)

Appendix C Test Pit Logs, Field Notes, Boring Logs and Well Completion Details

Appendix D Groundwater Well Sampling Logs

Appendix E Data Usability Summary Reports (CD)

Appendix F Fish and Wildlife Resource Impact Analysis Checklist

Appendix G 95% Upper Confidence Limit Calculations

Appendix H Land Use Evaluation


Certification

0071-010-350

vi

I, Thomas H. Forbes, certify that I am currently a NYS registered professional engineer as defined in 6 NYCRR Part 375 and that this Remedial Investigation/Alternatives Analysis (RI/AA) Report was prepared in accordance with all applicable statutes and regulations and in substantial conformance with the DER Technical Guidance for Site Investigation and Remediation (DER-10) and activities were performed in full accordance with the DER-approved work plan and any DER-approved modifications. Date: SEAL:

RI/AA REPORT PHASE IA BUSINESS PARK

0071-010-350 1

1.0 INTRODUCTION

1.1 Background and History Tecumseh Redevelopment Inc. (Tecumseh) owns approximately 1,100-acres of land

located on the west side of New York State Route 5 (Hamburg Turnpike) in the City of Lackawanna, NY (see Figures 1 and 2). Most of Tecumseh’s property is in the City of Lackawanna (the City), with portions of the property extending into the Town of Hamburg. Tecumseh’s property is bordered by NY State Route 5 on the east; Lake Erie to the west and northwest; and other industrial properties to the south and the northeast.

The property was formerly used to produce steel, coke, and related products by Bethlehem Steel Corporation (BSC). Steel production on the property was discontinued in 1983 and the coke ovens ceased activity in 2000. Tecumseh acquired its Lackawanna property from BSC’s bankruptcy estate in 2003.

A Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) of all Solid Waste Management Units (SWMUs) located on the 1,100-acre property was initiated by BSC under an Administrative Order issued by the United States Environmental Protection Agency (USEPA) in 1990. Tecumseh completed the RFI in January 2005 (Ref. 1). USEPA subsequently determined that the Site investigation requirements of the 1990 Administrative Order were satisfied, and Tecumseh’s obligations under the 1990 Administrative Order were terminated. Tecumseh entered into an Order on Consent with the New York State Department of Environmental Conservation (NYSDEC) to undertake corrective measures at certain solid waste management units (SWMUs) primarily on the western slag fill and coke manufacturing portion of the property. As indicated on Figure 2, the CMS area encompasses approximately 500 acres.

Outside of the CMS Area, Tecumseh designated five groups of parcels for redevelopment under the New York State Brownfield Cleanup Program (BCP). These include the Phase I, IA, II, and III Business Parks, which are at various points of investigation and cleanup under the BCP and are slated for or undergoing commercial/industrial redevelopment; and the Steel Winds Site, which was remediated under the BCP and redeveloped as a commercial wind farm.

The 12.31-acre Phase IA Business Park, which is the subject of this Remedial Investigation and Alternatives Analysis (RI/AA) Report, formerly supported BSC’s steel-


0071-010-350 2

making operations as detailed in Section 2.0; however, there are no SWMUs present on the Site. Remedial Investigation activities on the Phase IA Business Park were initiated in June 2010 and continued through the end of July 2010.

1.2 Purpose and Scope This RI/AA Report has been prepared on behalf of Tecumseh to present RI findings,

describe environmental conditions at the Site, and evaluate and recommend a remedial approach. This Report contains the following sections.

Section 2.0 presents a description of the Site and summarizes prior assessments and remedial efforts.

Section 3.0 presents a discussion of the RI sampling and methodology.

Section 4.0 presents the nature and extent of impacted Site media and completed remedial measures.

Section 5.0 discusses RI findings and describes potential chemical constituent migration pathways.

Section 6.0 provides human health exposure and fish and wildlife resources impact assessments.

Section 7.0 presents a summary of the RI with conclusions.

Sections 8.0 through 10.0 present the development and evaluation of remedial alternatives

Section 11.0 identifies post-remedial requirements that will be followed to assure the efficacy of the remedy.

Section 12.0 lists cited references.


0071-010-350 3

2.0 SITE DESCRIPTION The Phase IA Business Park is a 12.31-acre parcel located along Route 5, west of the

Phase I Business Park; and north, south, and east of lands currently owned by Gateway Trade Center (see Figures 1 and 2).

The Phase IA Business Park formerly supported BSC’s steel-making operations; however, there are no SWMUs present on the Site. Existing buildings and former operations located on the Site are shown on Figure 2. The existing structures within the Phase IA Business Park boundaries were used for the following purposes:

Blowing Engine House No. 3 was used as a repair facility for locomotives and other motor-driven vehicles employed on the site.

Boiler House No. 3/Steam Station No. 1 supplied steam for plant process equipment and instrumentation.

Power House No. 1 served as a power generation station, incorporating steam-driven turbines, transformers, and other electrical equipment to provide nearly all power required at the BSC site. Historical plant schematics indicate that a 19,900-gallon fuel oil tank may have been present to the south of Power House No. 1. The basement of the Power House also had an oil & electric room located in the southern portion of the building.

Pumping Station No. 1 supplied Lake water for use in production activities. This building was demolished in 2008 with the foundation remaining in place.

Overhead Coke Oven Gas and Other Aboveground Pipelines remain across a small portion the southwest corner of the Site. Based on previous work conducted in the Corrective Measures Study (CMS) Area (SWMU P-76) and BCP Phase II and III sites, the coke oven gas lines are known to contain hazardous constituents (naphthalene and benzene) in the condensate residuals. These overhead lines are former appurtenances of the coke over operations and are to be decontaminated and removed under a separate Order on Consent between Tecumseh and NYSDEC addressing implementation of RCRA corrective measures and are not considered part of the BCP Site.

North Return Water Trench (NRWT) is a man-made drainage channel along the eastern boundary of the Phase IA Business Park. The NRWT begins near former Pumping Station No. 1 and flows north to the Union Ship Canal via an open channel and culverts. Historically, the trench collected treated wastewater and non-contact cooling water from BSC operations. This trench will not be addressed under the BCP as it is specifically to be addressed under the RCRA Corrective Measures Order. The portion of the NRWT that flows through the Phase IA Site


0071-010-350 4

extends along the eastern side of Site Highway 7 from the southern end of the Boiler House northward to the property line, the majority of which is enclosed. Appendix A-1 includes the results of the CMS sampling of the NRWT that occurred within this stretch.

South Return Water Trench (SRWT) is a man-made drainage channel along the southern half of the Phase IA Business Park then continues flowing south across the CMS Area on Tecumseh lands to Smokes Creek. This trench will not be addressed under the BCP as it is specifically to be addressed under the RCRA Corrective Measures Order. The portion of the SRWT that flows through the Phase IA BP Site extends along the eastern side of Site Highway 7 from the northern end of the Blowing Engine House south to Times Square (see Figure 2). Appendix A-1 includes the results of the CMS sampling of the SRWT that occurred within this stretch.

2.1 Site Topography and Drainage The Phase IA Business Park is generally characterized as flat covered by sparse brush

and low-lying vegetation. The land surface is sparsely vegetated with voluntary indigenous shrubs, grasses, weeds, and emergent trees.

The United States Geological Survey Buffalo (SW), New York Quadrangle indicates that the surrounding area slopes gradually to the west toward Lake Erie (see Figure 1). Due to the granular nature of the slag/soil fill there is very little ponded stormwater or runoff as most of the precipitation seeps into the highly permeable slag/soil fill.

2.2 Remaining Site Structures As previously stated, the 12.31-acre Site and surrounding property is composed of

vacant land and three remaining buildings: the Blowing Engine House, the Boiler House, and the Power House that are remnants of the historical steel-making operations as shown on Figure 2.

2.3 Site Geology and Hydrogeology The United States Department of Agriculture Soil Survey of Erie County, New York

indicates that the Site is covered by surface soil classified as Urban Land; soil consisting of paved, foreign, or disturbed soils. Drilling logs from monitoring wells constructed on or near the Site indicate that the upper eight feet is typically composed of steel and iron-making slag, cinders, sand, and/or fill material. The fill is underlain by a peat layer and lacustrine clays and


0071-010-350 5

silts that are, in turn, underlain by shale or limestone bedrock. Bedrock is estimated to be present at approximately 60 feet below grade.

Historically, due to the proximity of Lake Erie and municipal supplied water, groundwater in the area has not been developed for industrial, agricultural, or public supply purposes. There is a deed restriction that prohibits the use of groundwater on the property. Consequently, no groundwater supply wells are present on the 1,100-acre Tecumseh property.

The groundwater isopotential map completed during the RI for the February 2011 sampling event indicates that shallow groundwater flows radially west and southwest across the Site towards the Gateway Metroport Ship Canal with a small component flowing northwest toward the Buffalo Outer Harbor. Measurements taken in Site monitoring wells indicate that the water table is generally 6 to 10 feet below ground surface (fbgs) within the soil/slag-fill unit. These flow directions and depths to the water table were confirmed during the May 2014 and February 2016 groundwater sampling events. Figures 4A and 4B are the isopotential maps for the 2011 and 2016 monitoring events.

2.4 Utilities The following utilities are present on or near the Site:

Electric Utility: Overhead electric power lines on wooden utility poles, owned by Niagara Mohawk Power Corporation (NMPC), run north and south adjacent to the Site. The electric utilities are located just east of the Site boundary and along the former Power House No. 1 (see Figure 2) but are not located within the Site boundary. The former Power House No. 1 is part of the Site.

Water: Erie County currently supplies potable water to the site. Lake Erie is not accessible from the Site without accessing other areas of the Tecumseh property or Gateway Trade Center.

Sanitary Sewers: Abandoned sewer lines are located within the Site boundaries and their exact locations and conditions are unknown. There are no plans for these utilities in the event they are destroyed during investigation activities.

2.5 Wetlands and Floodplains No State/Federal wetlands or floodplains exist at the Site.


0071-010-350 6

2.6 Previous Investigations In April 2007, TurnKey Environmental Restoration, LLC (TurnKey) field personnel

collected three surface (0-2”) soil samples, identified as BP1A-SS-01 through BP1A-SS-03 (see Figure 3), for analysis of base-neutral semi-volatile organic compounds (SVOCs), PCBs, and RCRA-regulated metals. The analytical results indicate concentrations of certain PAHs (primarily naphthalene at 1,500 mg/kg in sample BP1A-SS-03) and metals (arsenic at 54.6 mg/kg and barium at 6,630 mg/kg in sample BPA1A-SS-02) above NYSDEC Part 375 commercial soil cleanup objectives (CSCOs). PCBs were also detected at low concentrations (0.17-0.37 mg/kg) in these surface soil samples, well below the CSCO of 1 mg/kg. Table 1 summarizes the analytical data from the April 2007 sampling event and Appendix A-2 includes the analytical data package.

In August 2007, Watts Architecture & Engineering, P.C. (Watts) conducted a pre-demolition asbestos abatement project for Tecumseh prior to entry of the Phase IA Business Park into the BCP. Watts provided project monitoring and air sampling/analysis services. AAA Environmental, Inc. performed asbestos abatement. Benchmark Environmental Engineering & Science, PLLC (Benchmark) provided project management on behalf of Tecumseh. The asbestos abatement took place between May 2005 and October 2006. Business Park IA fell within what was referred to at the time as “Area VI” and the following areas were addressed:

Cleanup of Outdoor Asbestos Debris

Boiler House

Power House (ground floor only)

Pumping Station No. 1

The scope of work for the asbestos project involved the removal and disposal of thermal systems insulation, boiler gaskets, pusher car brake shoes, built-up roofing, roof patch tar, window caulk, light fixture insulation, transite pipe, transite lab hoods, transite roofing/ siding, transite electrical switches, galbestos roofing/siding, boiler insulation, exterior tank jacket insulation, exterior pipe/tank tar coating, resilient flooring, floor tile and floor tile mastic from former coke ovens, ancillary buildings and structures prior to their demolition. All work was performed in accordance with the requirements of NY Industrial Code Rule 56, OSHA, USEPA, and all other applicable regulations and standards.


0071-010-350 7

All air samples were analyzed by EMSL Analytical Inc., of Depew, New York. Air samples were considered satisfactory when all results were <0.01 fibers per cubic centimeter (f/cc) or the measured background level (the clearance criteria established by New York State Industrial Code Rule 56).

The manual provided in Appendix A-3 contains records that document the efforts of Watts to ensure the health and safety of the building occupants. Included are the laboratory reports, daily project logs, certifications, and licenses, and consultant’s certifications and licenses.

2.7 Interim Remedial Measures On December 17, 2012, during removal of an old building footer foundation within

the railroad corridor during the East Harbor Lead project, field evidence1 of potentially impacted soil/slag-fill (“black tar-like material”) was encountered. On January 2, 2013, Zoladz Construction Co., Inc. (Zoladz) removed the visually impacted soil/slag-fill and NYSDEC agreed that no further removal of soil/slag-fill was required. The impacted material was stockpiled on polyethylene sheeting east of the railroad corridor adjacent to the impacted area and covered with polyethylene sheeting to prevent infiltration of precipitation and wind erosion. As shown on Figure 3, the area of impact was approximately 20-feet by 30-feet. On January 7, 2013, the excavation area was backfilled with BUD-approved slag and compacted.

On January 24, 2013, TurnKey personnel collected two representative samples of the impacted soil/slag-fill for analysis of TCLP VOCs, TCLP RCRA metals, total PCBs, and ignitability by Test America Laboratories, Inc. of Buffalo. On October 2, 2013, Tecumseh received approval from the Chautauqua County Landfill (CCLF) for disposal as a solid waste. On October 18, 2013, a total of 87.91 tons of the impacted soil/slag-fill was hauled to the CCLF by Zoladz. Documentation is contained within the 2013 Construction Completion Report (Ref. 2).

1 Field evidence of impact is defined as having readily identifiable visual or olfactory signs of contamination, including product, tars, or elevated PID readings (i.e., sustained readings >20 ppm).


0071-010-350 8

3.0 REMEDIAL INVESTIGATION APPROACH & RATIONALE The RI was designed to provide defensible data to identify areas of the Site potentially

requiring remediation, define chemical constituent migration pathways, and qualitatively assess human health and ecological risks to allow for performance of a remedial alternatives evaluation. This section of the RI report presents a discussion of the rationale for the data collection program of the RI, including the methods employed to collect samples and make field measurements and observations, and the methods used to chemically analyze the environmental samples.

3.1 General The RI included the following field activities to delineate and characterize on-site

soil/fill and assess groundwater quality at the Site:

Visual, olfactory, and PID characterization of surface and subsurface soil/fill through test pit excavation.

Collection of surface and subsurface soil/fill samples.

Advancement of on-site borings completed as groundwater monitoring wells.

Collection and analysis of groundwater samples from existing and newly installed monitoring wells at the Site.

RI field activities were conducted by TurnKey in accordance with the approved April 2010 RI/AAR Work Plan for Phase IA Business Park (Ref. 3). Environmental sample collection was performed in accordance with TurnKey’s Field Operating Procedures (FOPs); USEPA- and NYSDEC-approved sample collection and handling techniques were employed. Samples for chemical analysis were analyzed in accordance with USEPA SW-846 methodology to meet the definitive-level data requirements. Analytical results were evaluated by a third-party data validation expert in accordance with provisions described in the RI Work Plan. Most field activities were conducted under NYSDEC oversight. Each sampling location was surveyed via GPS and plotted on the site base map. Appendices A and B include the analytical data packages for samples collected during the April 2007 and June 2010 sampling events, respectively.


0071-010-350 9

3.2 Constituents of Potential Concern The constituents of potential concern (COPCs) identified in the RI Work Plan were

based on Site operational history, groundwater sampling data, and prior investigation reports. The primary COPCs include base-neutral Target Compound List (TCL) semi-volatile organic compounds (SVOCs) and select metals in surface soil/slag-fill. SVOCs are associated with greases, lubricating and hydraulic oils, and fuels associated with the operation of the steel mills, foundry, petroleum bulk storage and other steel manufacturing operations historically conducted on the Site. Metals associated with steel manufacturing are also ubiquitous in surface and shallow subsurface soil/slag-fill at the Site. The investigation also checked for the presence of PCBs from former transformer use and VOCs from the historical use of solvents and fuel storage.

3.3 Soil/Fill Investigation

Surface Soil Twelve grab surface soil/fill samples identified as BP1A-SS-04 through BP1A-SS-15

(see Figure 3) were collected from the Phase IA Business Park Site in June 2010 to facilitate evaluation of potential health risks to current Site receptors that may be exposed to soil/fill via direct contact, incidental ingestion, or inhalation of airborne particulates. For each surface soil/fill grab sample, a dedicated stainless-steel spoon was used to collect a representative aliquot of soil from 0 to 2 inches below ground surface (bgs) following removal of any sod. Samples were transferred to laboratory supplied, pre-cleaned sample containers for analysis of the parameters listed in Section 3.3.3.

Subsurface Soil/Fill The subsurface investigation included the excavation of 17 test-pits, identified as

BP1A-TP-1 through BP1A-TP-17 (see Figure 3). Test pits were excavated using a track-excavator from ground surface to native soils or groundwater, whichever was encountered first. As outlined in the RI Work Plan, most of the test pit samples were biased toward the upper 2-foot interval, the depth where most exposure is likely to occur prior to and following redevelopment. At locations where field observations suggested a greater potential impact with depth, the sample was collected from the subsurface interval (i.e., 2 feet to native soil/


0071-010-350 10

groundwater depth). No visual or olfactory evidence of impact was observed in the native soils; therefore, samples were not collected for laboratory analysis.

Following test pit excavation, subsurface samples were retrieved by scraping the excavator bucket across the depth from 2 fbgs to the bottom of the test pit and were collected from the center of the excavator bucket using a dedicated stainless-steel spoon. Samples were transferred to laboratory supplied, pre-cleaned sample containers for analysis of the parameters listed in Section 3.3.3.

In accordance with the RI/AAR Work Plan, a representative aliquot was also collected from the sample interval and transferred to a sealable plastic bag for discrete headspace determination. PID headspace readings are shown on the individual test pit excavation logs included as Appendix C. In accordance with the Work Plan, since the PID headspace reading at BP1A-TP-10 was greater than 20 ppm, the sample originally to be analyzed for STARS List VOCs was analyzed for TCL VOCs.

Appendix C includes the field notes and logs for all test pits excavated at the Site. Following completion of each test pit, slag/fill material was returned to the excavation in the opposite order in which it was removed and compacted to match the existing grade.

Methods of Chemical Analysis Surface and subsurface soil/fill samples were couriered under chain-of-custody

command to TestAmerica, Inc., located at 10 Hazelwood Drive, Amherst, New York 14228 for chemical analysis. TestAmerica is an independent, NY State Department of Health (NYSDOH) Environmental Laboratory Approval Program (ELAP)-certified facility approved to perform the analyses prescribed for this RI. TestAmerica also has NYSDOH Contract Laboratory Program (CLP) certification while maintaining ASP accreditation. TestAmerica employed analytical testing methods described in USEPA Test Methods for Evaluating Solid Wastes contained in SW-846 (revised 1991). Surface and subsurface soil/fill samples were analyzed for TCL VOCs, TCL SVOCs, total metals, and PCBs. The soil/fill sample collected from BP1A-TP-9 was also analyzed for TCLP VOCs, SVOCs, and metals, as well as percent solids and flashpoint, to aid in evaluating remedial options.

3.4 Groundwater Investigation Based on previous investigations completed on the adjacent Phase I Business Park,

groundwater modeling indicated that shallow groundwater flows east to west, toward the


0071-010-350 11

Gateway Metroport Ship Canal and eventually Lake Erie. To supplement this data, three shallow overburden groundwater monitoring wells were installed on the Phase IA Business Park Site.

The following sections describe the groundwater investigation and sampling methodology. Figure 3 shows the monitoring well locations discussed in this section. Appendix C includes the boring and monitoring well construction logs for all wells at the Site.

Monitoring Well Installation Following completion of the soil/fill portion of the investigation, three new shallow

overburden monitoring wells (designated MWN-69A, MWN-70A, and MWN-71A) were installed to better determine groundwater flow direction and groundwater quality on the Phase IA Business Park. The monitoring wells were generally installed at the proposed (RI/AAR Work Plan) locations, with some minor adjustments made in the field as necessary to facilitate drilling.

Monitoring Well Installation Methodology In accordance with the RI/AAR Work Plan, all new wells were constructed of 2-inch

schedule 40 PVC with a lockable J-plug and protected by a vented, 4-inch diameter protective steel casing. Protective steel casings were installed to a depth of approximately 2 fbgs and anchored in a 2-foot by 2-foot concrete surface pad. Table 3 presents monitoring well construction details; the logs are included in Appendix C.

Monitoring Well Development Both the newly installed and existing monitoring wells were developed prior to

sampling using dedicated, disposable, bottom-discharging polyethylene bailers for surging and a peristaltic pump for purging in accordance with NYSDEC and TurnKey protocols.

Groundwater Elevation Measurements Following installation, the locations and elevations of the newly installed monitoring

wells were surveyed against a fixed benchmark and located on the Site plan. The PVC casing tops were referenced to existing Site vertical datum to provide a reference point for groundwater elevation measurements. Groundwater elevations measured on February 8, 2011 indicate that the water table is encountered between 6 and 10 fbgs within the soil/slag-fill unit.


0071-010-350 12

Groundwater flow direction at the Site was assessed using the following 10 well locations: existing off-site upgradient monitoring wells B-2, MWN-64A, and MW-14A through MW-17A; off-site upgradient piezometer P-45S; and three newly installed Site monitoring wells MWN-69A through MWN-71A. Figure 4A is an isopotential map prepared using groundwater elevations measured on February 8, 2011. Examination of the isopotential map indicates that shallow groundwater flows radially west/southwest across the Site towards the Gateway Metroport Ship Canal as well as northwest toward the Buffalo Outer Harbor. Figure 4B presents the isopotential map prepared using the groundwater elevations measured on February 23, 2016; groundwater flow directions are like those established in 2011. Table 4 summarizes the static depth to groundwater measurements from on-site and off-site wells/ piezometers obtained February 2011, May 2014, and February 2016.

Monitoring Well Sampling On June 30, 2010, groundwater quality was assessed by collecting samples from

upgradient wells B-2 and MW-16A; upgradient piezometer P-45S; and Site wells MWN-69A through MWN-71A. Sampling was conducted in accordance with the RI/AAR Work Plan using low-flow sampling methodology. Appendix D includes the well sampling logs.

Groundwater samples were couriered under chain-of-custody command to TestAmerica for analysis of TCL VOCs, TCL SVOCs, PCBs, and inorganic compounds. TestAmerica employed analytical testing methods described in USEPA Test Methods for Evaluating Solid Wastes contained in SW-846, revised 1991.

On May 7, 2014 and February 23, 2016, groundwater samples were collected from Site monitoring wells MWN-69A and MWN-70A for analysis of petroleum VOCs, base-neutral SVOCs, and RCRA metals. Well MWN-71A was damaged; therefore, no groundwater samples were obtained.

3.5 Quality Assurance/Quality Control Field investigation data were collected and processed using the procedures outlined in

the Work Plan to ensure representative sample collection and to achieve the data quality objectives of the Remedial Investigation. The field activities were recorded in bound project field books supplemented with TurnKey field forms, as necessary.

TurnKey collected blind duplicates and matrix spike/matrix spike duplicates (MS/ MSD) at a frequency of 1 per 20 samples for each environmental media (i.e., soil/fill and


0071-010-350 13

groundwater). A trip blank accompanied each cooler of aqueous media to be analyzed for VOCs.

3.6 Data Usability Summary In accordance with the RI/AAR Work Plan, the laboratory analytical data from this

investigation was assessed by an independent third-party data validator. Ms. Judy Harry of Data Validation Services located in North Creek, New York performed the data usability summary assessment for the soil/fill and groundwater samples. The validation involved a review of the summary form information and sample raw data, and a limited review of associated QC raw data. Specifically, the following items were reviewed:

Laboratory Narrative Discussion Custody Documentation Holding Times Surrogate and Internal Standard Recoveries Matrix Spike Recoveries/Duplicate Recoveries Field Duplicate Correlation Preparation/Calibration Blanks Control Spike/Laboratory Control Samples Instrumental IDLs Calibration/CRI/CRA Standards ICP Interference Check Standards ICP Serial Dilution Correlations Sample Results Verification

The data usability evaluations were conducted using guidance from the USEPA Region 2 Validation Standard Operating Procedures, the USEPA National Functional Guidelines for Data Review, as well as professional judgment. Appendix E includes the Data Usability Summary Report (DUSR), which was prepared in accordance with Appendix 2B of NYSDEC’s DER-10 guidance (Ref. 4). Those items listed above that demonstrated deficiencies are discussed in detail in the DUSR. Analytical results that were edited or qualified per the DUSR have been modified appropriately on the summary tables.

3.7 PCB Investigation In concert with the Site characterization activities, TurnKey personnel conducted an

inventory of the remaining electrical equipment within the three buildings on the Phase IA


0071-010-350 14

Business Park Site. As summarized on Table 2A, a total of 36 transformers and 2 oil-filled circuit breakers remained on-site. To determine disposal requirements, liquid samples (and/or wipe samples of the reservoir or housings, in the absence of liquid) were collected from these remaining pieces of equipment and analyzed for total PCBs in general accordance with USEPA Part 761 Subpart N (Cleanup Site Characterization Sampling for PCB Remediation Waste). In addition to electrical equipment sampling, areas of suspected staining not associated with existing or historic transformers were sampled as requested by the NYSDEC. Table 2B summarizes the floor wipe and soil/fill sampling performed within these buildings. Appendix C contains the field notes describing the sampling event.

3.8 Barometric Condenser Cold Well Investigation On June 28, 2010, an on-site assessment of the barometric condenser cold well was

performed to determine whether it was properly decommissioned. An excavator was used to uncover the remaining concrete surface structure. Field observations via exploratory test pits indicated no evidence of the condenser cold well. Following the test pit investigation, TurnKey and the NYSDEC met to review historic record drawings for the condenser cold well, which indicated that it was decommissioned and backfilled to existing grade in August 1973 (see Figure 2).

On September 16, 2010, at the request of the NYSDEC, a soil boring (BP1A-B-01) was advanced to a depth of approximately 23.7 fbgs in the location of the former condenser cold well to confirm record drawings (see Figure 3). Field observations based on split-spoon sampling indicated fill materials (i.e., brick debris/sand/fill) from ground surface to a depth of approximately 20 fbgs. Concrete was observed from approximately 20 to 22.7 fbgs followed by woody debris material. Based on soil boring results and field observations by TurnKey and NYSDEC personnel, no further action was required in the vicinity of the condenser cold well. Appendix C includes the soil boring log for BP1A-B-01.


0071-010-350 15

4.0 RI FINDINGS This Section describes pertinent field observations and chemical analytical results in

surface soil/fill, subsurface soil/fill, groundwater, electrical equipment, and building surfaces.

4.1 Field Observations The surface of the Phase IA Business Park Site is generally characterized as a flat area

covered by sparse brush and low-lying vegetation. The land surface is sparsely vegetated with voluntary indigenous shrubs, grasses, weeds, and emergent trees (mostly poplars).

Due to the nature of the slag/soil fill, there is very little ponded storm water or surface runoff as most of the precipitation seeps into the highly permeable slag/soil fill. Subsurface lithology generally consists of a soil/fill unit comprised of dark brown, non-plastic fines with fine to medium sand, slag, cinders, ash, gravel, cobbles, brick, metal debris, and concrete, all of which are ubiquitous at the Site. This unit is characterized as dense but loose when disturbed. Below the soil/fill unit is a silty clay layer, either native or suspected non-native. A peat layer was occasionally noted below either the soil/fill unit or silty clay unit. Groundwater within the soil/fill unit was generally encountered between 7 and 10 fbgs.

Remaining building structures on the Site include the former Blowing Engine House No.3, Steam Station No.1/Boiler House No.3, and Power House No.3, none of which are currently occupied. The floor surface inside the remaining structures is characterized as weathered concrete and/or slag/fill.

Field evidence of potential significant soil/fill impacts, characterized by moderate to strong odors, unusual discoloration, visible evidence of product layer, and/or PID readings above 50 ppm, was identified at certain test pit locations as presented below. These significant impacts have been noted on Figure 3 and on the test pit logs in Appendix C.

BPA1-TP-9: Strong petroleum-like odor was noted beginning at 1 fbgs through to the fill-groundwater interface. Free floating product was observed on the groundwater at approximately 6 fbgs. A maximum PID reading of 49 ppm was recorded in the subsurface. Through additional test pits near BPA1-TP-9, the extent of the impact was defined as a 15-foot by 45-foot area by 6 feet deep. Two, 3-inch steel pipes were encountered within the impacted area at a depth of 3 fbgs. The pipes were broken and contained tar product. A coal tar lens was identified from 0.5-1.0 fbgs. Sheen was observed on the water at 6 fbgs and petroleum odors were noted.


0071-010-350 16

BPA1-TP-10: Tar-like material was noted within the upper foot of the slag/black sand fill. A moth-ball like odor was detected in the upper 2 feet of the test pit. A PID reading of 44 ppm was detected at 6 inches below grade; the PID reading was 0.0 ppm at 2 fbgs.

BPA1-TP-11: Petroleum-like material was noted within the unsaturated slag/fill in the 0.5-1.0 fbgs interval, with a strong moth-ball like odor. The PID reading at 1 fbgs was 15 ppm and 0.0 ppm at 3 fbgs.

In addition, a sulfur odor was present in the groundwater during development of monitoring well MW-16A on June 25, 2010 but not during purging and sampling on June 30, 2010. Slight sheen was observed during development of monitoring well MWN-71A on June 28, 2010 but not during purging and sampling on June 30, 2010.

4.2 Soil/Fill Chemical data for surface and subsurface soil/fill samples collected during the RI are

discussed in the following sections. As a comparison, Tables 5A (surface soil) and 6A (subsurface soil) include

“Unrestricted Use” Soil Cleanup Objectives (USCOs) as published in 6NYCRR Part 375-6 “Remedial Program Soil Cleanup Objectives.” USCOs are deemed protective of human health and groundwater irrespective of end use of the property. Accordingly, the USCOs represent conservative soil/fill cleanup objectives that are often difficult to achieve on former industrial sites in urban areas. Tables 5B (surface soil) and 6B (subsurface soil) compare the data to CSCOs per 6NYCRR Part 375-6. These values are deemed protective of human health, in the absence of other controls, for sites where end use will be limited to commercial or more restrictive (e.g., industrial) uses, which are considered the reasonably anticipated future uses for the Phase IA Business Park per the land use analysis presented in Section 8.4. Sample locations where reported concentrations exceed respective SCOs are shaded on the data summary tables.

Based on the widespread nature of the USCO exceedances, the discussions below are limited to soil/fill quality as indicated by the more meaningful comparison to commercial use SCOs. To the extent commercial use SCOs are exceeded, USCOs would be exceeded as well.


0071-010-350 17

VOCs No surface soil or test pit locations/samples exhibited exceedance of the CSCOs for

VOCs.

SVOCs Several surface and subsurface samples exhibited exceedances of the CSCOs for one

or more SVOC. Specifically, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, and indeno(1,2,3-cd)pyrene) were reported above CSCOs at several locations; however, the exceedances of these PAHs were generally within one order of magnitude of the SCO. The exception is the sample from test pit BP1A-TP-12 with exceedances within one to two orders of magnitude above the CSCOs for these parameters. In addition, no SVOCs were detected in the TCLP extract of test pit sample BP1A-TP-9.

Inorganic Compounds Arsenic was reported above the CSCO of 16 mg/kg at several test pit locations with

exception of BP1A-TP-1, BP1A-TP-3, BP1A-TP-6, BP1A-TP-8, BP1A-TP-9, and BP1A-TP17. Three of the five surface soil sample locations (SS-09 through SS-11) were characterized by arsenic above the CSCO. Other inorganic compounds reported above CSCOs include cadmium (SS-09 through SS-11), lead (BP1A-TP-14, SS-09 through SS-11), manganese (SS-13 and SS-15), and mercury (BP1A-TP-8, BP1A-TP-10 through BP1A-TP-12, and SS-09 through SS-11). The reported exceedances were generally within one order of magnitude of the CSCOs, except for arsenic in BP1A-TP-2 (120 mg/kg) and SS-09 (158 mg/kg); cadmium in SS-11 (246 mg/kg); and mercury in SS-09 (280 mg/kg), SS-10 (320 mg/kg), and SS-11 (216 mg/kg). No metals were detected above CSCOs in the TCLP extract of test pit sample BP1A-TP-9.

Polychlorinated Biphenyls PCBs were not detected above CSCOs in any of the test pit or surface soil sample

locations.


0071-010-350 18

4.3 Groundwater Groundwater quality data was collected during the RI (June 2010) from existing off-

site upgradient wells/piezometers: MW-16A, P-45S, and B-2; and newly installed overburden wells MWN-69A, MWN-70A, and MWN-71A. Well MW-16A and piezometer P-45S were decommissioned in September 2012 during the Railroad Realignment project. Appendix D includes the decommissioning logs prepared by Earth Dimensions Inc. showing decommissioning via tremie grouting in place. In May 2014 and February 2016, groundwater samples were collected from Site monitoring wells MWN-69A and MWN-70A; a sample could not be obtained from MWN-71A as it has been damaged. In June 2018, emergent contaminant samples were collected from monitoring wells MWN-69A and MWN-70A. Table 3 summarizes groundwater monitoring well construction details. Tables 7 and 8 summarize the analytical data, including field QC samples, along with Class GA Groundwater Quality Standards and Guidance Values (GWQS/GVs) per NYSDEC June 1998 Division of Water Technical and Operational Guidance Series (TOGS) 1.1.1. The findings are discussed below.

VOCs Groundwater samples from June 2010 exhibited non-detectable or trace (estimated)

concentrations of VOCs well below the GWQS/GVs. No VOCs were detected in the samples collected in May 2014 and February 2016.

SVOCs All samples obtained from groundwater monitoring wells exhibited non-detectable,

low, or trace (estimated) concentrations of SVOCs below GWQS/GVs. No SVOCs were detected in the samples collected in May 2014 or February 2016.

Inorganic Compounds Total metal concentrations were reported as non-detect, or at concentrations well

below GWQS/GVs for all metals during the June 2010 sampling event except for iron, manganese, and sodium in well MWN-71A, and total lead (slightly above) in piezometer P-45S. During the February 2016 sampling event, there were slight exceedances of the GWQS/GVs for manganese in well MWN-69A and cyanide and manganese in well MWN-70A. Manganese was also detected in the method blank sample for both wells. Iron and


0071-010-350 19

manganese are naturally occurring elements in groundwater and are not considered a health risk. Cyanide was reported in well MWN-70A as an estimated concentration of 1.0 mg/L, which is slightly above the GWQS of 0.2 mg/L.

Polychlorinated Biphenyls Groundwater samples exhibited non-detectable concentrations of PCBs during the

June 2010, May 2014, and February 2016 sampling events.

Emergent Contaminants TurnKey submitted the results of the July 2018 emergent contaminant sampling event

to NYSDEC in a letter dated August 3, 2018. Low level concentrations of per- and polyfluoroalkyl substances (PFAS) were detected at both sampling locations above laboratory detection limits including the field blank. The individual PFOA and PFOS concentrations in well MWN-70A exceeded the proposed drinking water standard of 10 nanograms per liter (ng/L); however, the NYSDEC PFOA+PFOS action level of 70 ng/L was not exceeded. Total PFAS concentrations did not exceed the NYSDEC action level of 500 ng/L at either well; in fact, the highest total PFAS concentration was 66.5 ng/L. 1,4-Dioxane was reported as non-detect at both monitoring locations.

Groundwater Field Measurements Field pH was measured immediately before and after groundwater sample collection.

According to TOGS 1.1.1., the maximum allowable pH ranges between 6.5 and 8.5. As indicated on Table 7, the pH measurements at monitoring well MWN-69A (6.17 and 6.37) and MWN-70A (6.46) were slightly outside this range during the June 2010 sampling. During the May 2014 sampling, only the final pH reading from well MWN-69A (6.42) was slightly outside this range. All pH reading during the February 2016 sampling were within the allowable range.

4.4 Electrical Equipment and Building Surfaces Table 9 summarizes the transformer oil analytical results of the remaining electrical

equipment identified on Table 2A. Based on the analytical results, each of the remaining pieces of electrical equipment was characterized into one of the following three categories as defined


0071-010-350 20

by PCB analytical concentrations in accordance with USEPA Part 761.60 (Disposal Requirements).

Non-PCB Equipment contains liquid PCB concentrations <50 ppm or surface concentrations ≤10 ug/100 cm2.

PCB-Contaminated Equipment contains liquid PCB concentrations ≥50 ppm to <500 ppm or surface concentrations >10 ug/100 cm2 to <100 ug/100 cm2.

PCB-Equipment contains liquid PCB concentrations ≥500 ppm or surface concentrations ≥100 ug/100 cm2.

As indicated on Table 9, all remaining electrical equipment is characterized as “non-PCB.” Table 10A presents the results of wipe samples collected from the building surfaces in

Power House No. 1 (at the request of NYSDEC) in June 2010. Three wipe samples (T-118 North Floor Wipe, T-141-143 Floor Wipe, and T-144-146 Floor Wipe) were reported at levels above 10 ug/m2. In accordance with 40 CFR Part 761.125, low-contact impervious surfaces are to be cleaned to 10 ug/m2 following release of PCB-contaminated oil. The estimated areal extent requiring cleaning was approximately 300 square feet.

As shown on Table 10A, the sample collected from the fill material on the floor surface of the Blowing Engine House No. 3 building (at the request of NYSDEC) indicates a non-PCB material. A sample collected from the fill material on the floor surface of the Power House No. 1 building indicated a PCB concentration slightly above the CSCO of 1 mg/kg but below the industrial SCO (ISCO) of 25 mg/kg. Because indoor soils pose an exposure scenario more consistent with that of a commercial use scenario than an industrial scenario (e.g., potential for routine exposures by indoor workers and visitors), the NYSDEC has indicated that the presence of surface concentrations above 1 mg/kg in an indoor area warrants remediation consistent with DER-10 and its CP-51 Soil Cleanup Guidance Policy.

Completed Remedial Measures On April 22, 2016, TurnKey (in association with Benchmark Environmental

Engineering & Science, PLLC) scraped the dust/soil from the floor, swept, and vacuumed the areas to be cleaned. The NYSDEC Project Manager was on-site and selected five areas for cleaning and PCB wipe sampling due to suspect oil staining on the floor. A muriatic acid-based concrete etcher/cleaner was scrubbed into the concrete and rinsed with water. The areas were vacuumed to remove excess water. The cleaned surface was left to air dry. On April 25, 2016,


0071-010-350 21

TurnKey-Benchmark collected 10 PCB wipe samples, five near the transformers and five where oil staining was observed; NYSDEC was on-site to observe the wipe sampling.

As shown on Table 10B, 3 of the 10 sample results exceeded 10 ug/100 cm2. On May 3, 2016, TurnKey-Benchmark re-cleaned these areas and collected three additional wipe samples. Following this cleaning, only 2 of the 3 sample results exceeded 10 ug/100 cm2. The remaining impacted area near transformers T144-T146 was cleaned again on May 13 and 26, and two wipe samples were collected after each event. Although the concentrations were reduced through cleaning, this approximate 88 square foot area is still impacted by elevated levels of PCB Aroclor 1254; therefore, additional focused remedial work is required to address this portion of the building floor.

In 2016, TurnKey drained and segregated the oil from the transformers based on PCB concentration. The non-PCB oil (approx. 262 gallons) was picked up by NOCO Distribution LLC on May 2, 2016 for reuse. On March 21, 2016, Clean Harbors Environmental Service, Inc. transported the transformer oil drained from the equipment, transformer residuals and carcasses, and capacitors to its facility in Twinsburg, OH. Tecumseh received the Certificates of Disposal indicating the methods of disposal in May through August 2016.


0071-010-350 22

5.0 FATE AND TRANSPORT OF COPCS Soil/fill sample results exceed SCOs for certain chemicals of concern (COCs). In

addition, floating petroleum product was observed on the water within test pit BP1A-TP-9 at approximately 6 fbgs. Accordingly, the soil/fill data and field observations were incorporated with the physical characterization of the Site to evaluate the fate and transport of COCs in Site media. The mechanisms by which the COCs present above SCOs can migrate to other areas or media are briefly outlined below.

5.1 Airborne Pathways Potential migration pathways involving airborne transport of soil/fill COCs include

erosion and transport of soil particles and sorbed chemical constituents in fugitive dust emissions, and volatilization from subsurface soil vapor.

Fugitive Dust Chemicals present in soil/fill can be released to ambient air because of fugitive dust

generation. Since the Site is presently unoccupied and substantially vegetated with shrubs, grasses, and trees, and because most of the fill consists of large grained slag, suspension due to wind erosion or physical disturbance of surface soil/fill particles is unlikely under the current use scenario. Under the planned future commercial/industrial land use, much of the Site would be covered by asphalt and structures with only small areas covered by grass and/or ornamental landscaping. Fugitive dust may be generated during excavation activities either during or following redevelopment. Therefore, this migration pathway is potentially relevant under the reasonably anticipated future land use scenario.

Volatilization Volatile chemicals, when present in soil/fill at elevated levels, may be released to

ambient air or future building indoor air through volatilization from or through the soil/fill pore space. Volatile chemicals typically have a low organic-carbon partition coefficient (Koc), low molecular weight, and a high Henry’s Law constant. However, VOCs were not detected in Site soil/fill at concentrations above CSCOs. Similarly, groundwater samples yielded not-detectable or trace levels of VOCs below Class GA GWQS/GVs. Therefore, the soil and groundwater-to-air pathways are not relevant.


0071-010-350 23

5.2 Waterborne Pathways

Surface Water Runoff Under the current use scenario, the potential for soil particle transport via surface water

runoff is mitigated by the flat topography of the Site and significant amount of vegetative growth. In addition, the well-drained soil/fill matrix precludes surface water ponding. Uncontrolled off-site transport is further limited because the Site is outside the 100-year floodplain. Although the Site is transected by the North and South Return Water Trenches, they are constructed in this area of the property as brick-lined channels with elevated wall sections, preventing surface run-in.

Under the reasonably anticipated future use scenario, the Site will be substantially covered by asphalt, buildings, and landscaping, mitigating transport of subsurface (i.e., covered) soil/fill via storm water runoff. Although stormwater runoff during excavation activities is possible during the future use scenario, erosion controls are typical construction practice and would be implemented as a component of the Site Management Plan required for BCP sites that do not achieve unrestricted use conditions.

Leaching No exceedances of the Class GA Groundwater Quality Standards and Guidance Values

(GWQS/GVs) were identified in on-site or off-site upgradient groundwater monitoring wells samples except for select metals. In addition, the soil/fill sample from BP1A-TP-9 was analyzed for TCLP metals and VOCs; the TCLP concentrations were well below the regulatory limits for hazardous waste determination, indicating chemical leaching is not a likely migration pathway. Nevertheless, the presence of free floating product (LNAPL) observed on the groundwater at approximately 6 fbgs in BP1A-TP-09 indicates isolated smear zone impact by petroleum product, suggesting localized saturation conditions. Accordingly, chemical (petroleum) migration via leaching is considered a potentially relevant exposure pathway.

Groundwater to Surface Water Migration As indicated on Table 7, all parameters during the 2010 RI were reported at or below

the Class GA GWQS/GVs except for minor pH deviations recorded in wells MWN-69A and MWN-70A. This data indicates that although saturated soil impact by petroleum was observed


0071-010-350 24

at BP1A-TP-9, this impact is likely isolated. To further assess whether site-wide groundwater to surface water migration is a relevant pathway, groundwater was sampled in May 2014 and February 2016. As described in Section 4.3, Site groundwater near monitoring wells MWN-69A and MWN-70A is not impacted; therefore, impact to groundwater from source areas appears isolated. If groundwater is impacted near hotspot areas, the groundwater to surface water migration pathway would be relevant. Neither well exceeded the NYSDEC action level for PFOA+PFOS or total PFAS concentrations indicating groundwater does not require additional monitoring. Well MWN-70A slightly exceeds the individual PFOA and PFOS proposed drinking water maximum contaminant level; however, the existing deed restriction prohibits the use of groundwater for potable purposes.

5.3 Exposure Pathways Based on the analysis of chemical fate and transport provided above, the only pathways

through which Site COCs could potentially migrate to other areas or media are fugitive dust emissions via physical disturbance of soil particles and potential leaching of petroleum products from the smear zone to groundwater. However, given the absence of existing Site occupancy; the distance between the Site and occupied structures; the availability of a municipal water supply and NYSDEC/NYSDOH requirements for dust controls during excavation at remedial program construction sites, it is unlikely that site-related COCs would reach off-site receptors at significant exposure point concentrations.


0071-010-350 25

6.0 QUALITATIVE HUMAN HEALTH EXPOSURE AND WILDLIFE

IMPACT ASSESSMENT

6.1 Human Health Exposure Assessment A qualitative exposure assessment consists of characterizing the exposure setting

(including the physical environment and potentially exposed human populations), identifying exposure pathways, and evaluating contaminant fate and transport.

An exposure pathway describes how an individual may be exposed to contaminants originating from a site. An exposure pathway has five elements:

A receptor population A contaminant source A contaminant release and transport mechanism A point of exposure A route of exposure

The receptor population is the people who are or may be exposed to contaminants at a point of exposure. The source of contamination is defined as either the source of contaminant release to the environment (such as a waste disposal area or point of discharge), or the impacted environmental medium (soil, air, biota, water) at the point of exposure. Contaminant release and transport mechanisms carry contaminants from the source to points where people may be exposed. The point of exposure is a location where actual or potential human contact with a contaminated medium may occur. The route of exposure is the way a contaminant enters or contacts the body (i.e., ingestion, inhalation, dermal absorption).

An exposure pathway is complete when all five elements of an exposure pathway are documented; a potential exposure pathway exists when any one or more of the five elements comprising an exposure pathway is not documented but could reasonably occur. An exposure pathway may be eliminated from further evaluation when any one of the five elements comprising an exposure pathway does not exist in the present and will not exist in the future.

Potential Receptors The identification of potential human receptors is based on the characteristics of the

Site, the surrounding land uses, and the probable future land uses. The Phase IA Business Park Site is presently unoccupied. Under current Site use conditions, receptors would be limited to


0071-010-350 26

trespassers who may traverse the Site (although presently mitigated by fencing and security measures); and construction workers that may access the Site to service utilities or perform similar duties. Trespassers might be comprised of adolescents and adults, whereas construction workers would be limited to adults. During remedial actions, receptors would include remedial contractors, environmental oversight personnel, and staff from regulatory agencies. Consideration and mitigation of remedial contractor exposure is conservatively protective of regulatory staff.

In terms of future use, the current Site owner (Tecumseh Redevelopment) has developed a Master Plan for commercial/industrial redevelopment of the Site consistent with surrounding property use and site zoning. Future site use is further discussed under Section 8.4, which indicates that the reasonably anticipated future use of the Site is for commercial/ industrial purposes. Exposed receptors under the future use scenario may be comprised of indoor workers, outdoor workers (e.g., groundskeepers or maintenance staff), and construction workers who may be employed at or perform work on the property. Site visitors/ customers may also be considered receptors; however, their exposure would be like that of the indoor worker but at a lesser frequency and duration. Therefore, consideration and mitigation of indoor worker exposure is conservatively protective of the site visitor.

Contaminant Sources Section 4.0 discusses the COCs present in un-remediated Site media at elevated

concentrations. In general, these are limited to SVOCs and select inorganic COCs in both surface and subsurface soil/fill, and isolated petroleum impact to the smear zone.

Contaminant Release and Transport Mechanisms Contaminant release and transport mechanisms are specific to the type of contaminant

and site use. For the non-volatile COCs present in site-wide soil/fill, contaminant release and transport mechanisms will generally be limited to fugitive dust migration and direct contact during intrusive work (e.g., during construction and grounds keeping activities), as the Site is currently covered by vegetation and will be substantially covered by roads, parking lots, buildings, and landscaping after redevelopment. VOCs are not present in the surface or subsurface soil/fill and groundwater; therefore, the potential does not exist for exposure through pathways associated with soil gas migration (i.e., indoor vapor intrusion). For the


0071-010-350 27

petroleum product observed on the water table in test pit BP1A-TP-9, smear zone to groundwater is a potential contaminant release and transport mechanism.

Point of Exposure Based on the widespread exceedance of CSCOs for certain ubiquitous parameters (e.g.,

arsenic and PAHs), the point of exposure is defined as the overall Site. For both the current and future use scenarios, groundwater is not considered to pose a relevant mechanism due to the isolated smear zone impact, the availability of a local municipal potable water source, the depth to groundwater (greater than 4.5 feet; the standard depth of utilities and foundation footers), and the existence of a deed restriction that does not allow the use of Site groundwater.

Route of Exposure Based on the types of receptors and points of exposure identified above, potential

routes of exposure are listed below:

Current Use Scenario

Construction and Outdoor Worker – skin contact, inhalation, and incidental ingestion

During Remedial Action Scenario

Remedial Contractor and Environmental Professional – skin contact, inhalation, and incidental ingestion

Future Use Scenario

Indoor Worker – inhalation

Construction and Outdoor Worker – skin contact, inhalation, and incidental ingestion

Exposure Assessment Summary Based on the above assessment, the potential exposure pathways for the un-remediated

site condition are listed below.


0071-010-350 28

Current Use Scenario

Construction and Outdoor Worker – direct contact, incidental ingestion, and inhalation of non-volatile COCs present in site-wide soil/fill during intrusive and other dust-generating activities.

Remedial Action Scenario

Remedial Contractor and Environmental Professional – direct contact, incidental ingestion, and inhalation of non-volatile COCs present in site-wide soil/fill during intrusive and other dust-generating activities.

Future Use Scenario Construction and Outdoor Worker – direct contact, incidental ingestion, and

inhalation of non-volatile COCs present in site-wide soil/fill during intrusive activities

In most instances, these exposures can be readily mitigated during and following redevelopment through proper soil/fill management and placement of asphalt, building, and landscape cover.

6.2 Fish and Wildlife Impact Assessment (FWIA) The Site has been vacant since the former BSC steel plant ceased production in 1983.

The historical use of the Site has eliminated most native species. The Site is mainly populated by low-lying vegetation and small stature early successional trees (e.g., eastern cottonwood and poplar). Vegetative cover has recolonized the vacant industrial site with scrub-like brush and trees. A mixture of cover types exists on the site, ranging from asphalt roadways, rail, and concrete foundation, to spots of dense scrub-brush/cottonwood vegetation. Much of the fauna found on the Site are avian and small mammal species apart from the white-tailed deer. No federally listed or proposed threatened or endangered species are known to exist in the project area (USFWS 1999).

The Phase IA Business Park is slated for redevelopment as a commercial/light industrial area, consistent with surrounding property. Roadways, buildings, parking facilities, and maintained ornamental landscaping will substantially limit availability of suitable cover type for reestablishment of biota.

The only observed impact to groundwater/smear zone with the potential to affect surface water is present near BP1A-TP-9, where petroleum product was observed on the test


0071-010-350 29

pit water at approximately 6 fbgs. This impacted area is upgradient of the NRWT, which flows north to discharge near the confluence of the Union Ship Canal and Buffalo Outer Harbor. This portion of the NRWT is constructed of brick and concrete, is hemlock-wood lined, and extends approximately 8 to 10 fbgs. It is unlikely that the impacts observed in BP1A-TP-9 are discharging to the surface water via NRWT; however, if left unremediated, the potential for impact remains.

As such, based on the Fish and Wildlife Resource Impact Analysis Decision Key included as Appendix F (NYSDEC DER-10 guidelines, Appendix 3C), no fish and wildlife resource impact analysis is warranted.

6.3 Qualitative Off-Site Exposure Assessment During the RI, soil borings were advanced and monitoring wells were installed across

the Site, including locations proximate to Site property boundaries. These sampling locations were used in conjunction with previously collected data to complete this qualitative off-site exposure assessment and evaluate potential remedial measures to address Site contamination. Groundwater flow direction on the Site is southwesterly to westerly. The following evaluates the potential for off-site impacts:

Northern Boundary of Site: Analytical soil data from test pit BPIA-TP-17 near the northern property boundary

shows no concentrations above CSCOs and only two PAHs and four metals (i.e., cadmium, chromium, lead, mercury) above USCOs. There are no hotspots near the northern boundary of the Site. In 2010, monitoring well MWN-71A contained concentrations of iron, manganese, and sodium at concentrations above GWQSs; VOCs and SVOCs were not detected. Therefore, the potential for off-site impacts at the northern boundary is negligible.

Southern Boundary of Site: Analytical soil data from test pit BPIA-TP-1 (approx. 180 feet from the southern

property boundary) shows no concentrations above CSCOs and only one metal (i.e., chromium) above USCOs. There are no hotspots near the southern boundary of the Site. Monitoring well MWN-69A is the closed well to the southern boundary; the only exceedances of the GWQSs were pH slightly below the range. Therefore, the potential for off-site impacts at the southern boundary is negligible.


0071-010-350 30

Eastern Boundary of Site: Soil/fill impacts were observed along the eastern property boundary and have been

identified as Hotspots A, B, G, and H (petroleum, metals). Following excavation of these hotspots, off-site soil/fill impacts at this property boundary will be remediated. In addition, any visually impacted groundwater in Hotspot A would be treated. Therefore, the potential for off-site impacts at the eastern boundary is negligible.

Western Boundary of Site: Soil/fill Hotspot D (PAHs, lead) has been identified along the western property

boundary. Following excavation of this and other interior hotpot areas, off-site soil/fill impacts at this property boundary will be remediated. In 2016, only cyanide (estimated) and manganese (also in method blank sample) slightly exceeded GWQSs in monitoring well MWN-70A; VOCs and SVOCs were not detected. Therefore, following hotspot excavation, the potential for off-site impacts at the western boundary is negligible


0071-010-350 31

7.0 SUMMARY AND CONCLUSIONS The RI findings indicate conditions consistent with the historic use of the Site for steel-

making, and the widespread presence of fill materials containing slag. Key observations and findings from the soil/fill and groundwater investigations are listed below:

Field observation of potential subsurface impact by petroleum was recorded at test pit location BP1A-TP-9. As discussed in Section 4.1, strong petroleum-like odor was noted beginning at 1 fbgs through to the fill-groundwater interface. Free floating product was observed on the groundwater at approximately 6 fbgs. A maximum PID reading of 49 ppm was recorded in the subsurface. The sample collected from 1.0 to 5.5 fbgs yielded VOC and SVOC concentrations below CSCOs except for slight exceedances for individual PAHs, suggesting that the observations are representative of residual, weathered organics. Exploratory test pit investigation near BP1A-TP-9 documented that the visually impacted subsurface soil/fill appears to be a localized within a 15-foot x 45-foot area to a depth of 6 fbgs west of the former tank saddle. Two, 3-inch steel pipes were encountered within the impacted area at a depth of 3 fbgs; the pipes were broken and contained tar product. A coal tar lens was identified from 0.5-1.0 fbgs. Sheen was observed on the water at 6 fbgs and petroleum odors were noted. Based on the TCLP data, excavated soil/fill would be disposed as non-hazardous.

A moth-ball like odor was detected in upper unsaturated zones in test pits BP1A-TP-10 and BP1A-TP-11. The sample collected from BP1A-TP-10 (0 to 2 fbgs) yielded a total VOC concentration (4.7 ppm), which is below the CSCO for total VOCs of 10 ppm; naphthalene (known for its moth-ball like odor) was not detected. The sample collected from BP1A-TP-11 (0.5 to 3.0 fbgs) yielded a total VOC concentration of 279 ppm, which exceeds the CSCO for total VOCs of 10 ppm. The concentration of naphthalene in this sample was 260 ppm, which is below the CSCO of 500 ppm (see the following bullet for explanation of this SCO). SVOC concentrations, particularly the base-neutral PAHs, were above CSCOs. The naphthalene result has been flagged with a “B” qualifier indicating the presence of naphthalene in the associated blank QA/QC sample.

Base-neutral SVOCs (i.e., PAHs) were detected above the CSCOs at several test pit locations across the Site. As discussed in Section 8.3, NYSDEC’s CP-51 Soil Cleanup Guidance provides for an alternative soil cleanup objective of 500 ppm total SVOCs (in lieu of individual SCOs) for soils where: end use of the site will be for commercial or industrial purposes; a cover system (one foot of clean soil, building and/or pavement) will be constructed; and institutional controls and a Site Management Plan will be implemented. Total PAH concentrations were reported at less than 500 ppm, except for subsurface soil samples BP1A-TP-7 (1,192 ppm);


0071-010-350 32

BP1A-TP-11 (1,255 ppm); and BP1A-TP-12 (1,837 ppm). In addition, a total PAH concentration of 2,877 ppm was reported for April 2007 surface soil sample SS-03.

Arsenic was detected above the CSCO of 16 mg/kg at many of the surface and subsurface soil sample locations. Arsenic is a ubiquitous metal with urban background soils in New York State frequently containing concentrations above the CSCO, particularly at active and former industrial properties characterized by historic slag fill deposition and coal burning, such as that which occurred on the subject property. Accordingly, comparison of the arsenic data to site-specific background or average concentrations is considered appropriate. As discussed in Section 8.3, a site-specific SCO of 118 ppm has been established as the screening criteria for hotspot identification. Two areas on the Phase IA Business Park exceeded this site-specific SCO: BP1A-TP-2 (120 ppm) and SS-09 (158 ppm).

Although barium was detected in surface soil/fill sample SS-02 at a concentration (6,630 mg/kg) above the CSCO (400 mg/kg), the concentration is well below the ISCO of 10,000 mg/kg (i.e., cap for total metals) and barium was not detected in adjacent subsurface soil/fill samples collected from BP1A-TP-13 and BP1A-TP-14.

Cadmium concentrations in surface soil samples SS-09, SS-10, and SS-11 exceeded the CSCO of 9.3 mg/kg; however, only the concentration of cadmium at SS-11 (246 mg/kg) exceeded the ISCO of 60 mg/kg.

An elevated lead concentration of 2,530 mg/kg was detected at BP1A-TP-14; however, this concentration is below the ISCO of 3,900 mg/kg. Similarly, the lead concentration (1,090 mg/kg) in surface soil sample SS-03 (April 2007) slightly exceeded the CSCO but fell below the ISCO. The concentrations of lead in surface soil/fill samples SS-09 through SS-11 exceeded but were within one order of magnitude of the ISCO.

Manganese was detected in surface soil/fill samples SS-13 (17,300 mg/kg) and SS-15 (16,000 mg/kg) at concentrations above the CSCO of 10,000 mg/kg (i.e., cap for total metals). According to Table 9.1-10 of the NYSDEC’s BCP Technical Support Document (Ref. 5), the SCO for manganese after consideration of health risk is 67,000 mg/kg for industrial use.

Mercury concentrations in surface soil samples SS-09, SS-10, and SS-11 exceeded the CSCO of 2.8 mg/kg by two orders of magnitude. The concentrations of mercury in subsurface soil/fill samples BP1A-TP-10 through BP1A-TP-12 were within one order of magnitude of the CSCO. Mercury was detected in BP1A-TP-8 at a concentration (6.05 mg/kg) slightly above the ISCO of 5.7 mg/kg.

There were no exceedances of the Class GA GWQS/GVs in any of the groundwater samples collected, except for slight exceedances of cyanide in MWN-


0071-010-350 33

70A (2016), lead in piezometer P-45S (2010) and naturally occurring minerals iron, manganese, and sodium.

Groundwater pH was slightly outside the range during sampling of MWN-69A (2010, 2014) and MWN-70A (2010). A sulfur odor was present in the groundwater during development of monitoring well MW-16A on June 25, 2010 but not during purging and sampling on June 30, 2010. Slight sheen was observed during development of monitoring well MWN-71A on June 28, 2010 but not during purging and sampling on June 30, 2010. Petroleum product was observed floating on the water within test pit BP1A-TP-9 at approximately 8 fbgs, indicating potential localized impact to the saturated soil/fill (i.e., smear zone) due to past Site operations.

Although the individual PFOA and PFOS concentrations in well MWN-70A slightly exceeded the proposed drinking water standard, the NYSDEC action levels for PFOA+PFOS and total PFAS were not exceeded. Therefore, no remedial measures for emergent contaminants in groundwater is warranted.

PCB concentrations detected in low-contact building surfaces do not suggest a high concentration source release. Three floor wipe samples (T-118 North Floor Wipe, T-141-143 Floor Wipe, and T-144-146 Floor Wipe) exceed EPA recommended cleanup criteria for restricted access areas.

No PCBs were detected in any of sampled electrical equipment (i.e., transformers and circuit breakers) at levels above regulatory limits (i.e., 50 ppm).

Based on the RI Findings, remedial measures are warranted to address impacted unsaturated and saturated soil/fill as well as floor surface in the Power House. The remaining sections constitute an Alternatives Analysis Report (AAR) in accordance with NYSDEC DER-10 guidance.


0071-010-350 34

8.0 DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES AND

GENERAL RESPONSE ACTIONS The development of an appropriate remedial approach begins with definition of site-

specific Remedial Action Objectives (RAOs) to address substantial human health and ecological risk or other significant environmental issues identified. General Response Actions are then developed as potential means to achieve the RAOs.

8.1 Remedial Action Objectives RAOs for this Site have been developed based on the findings of the RI, which have

identified localized “hotspot” soil/fill in discrete portions of the Site and smear zone impact near test pit BP1A-TP-9. Hotspots are soil/fill areas where non-ubiquitous constituents significantly exceed ISCOs and/or had notable field observations indicating gross contamination (free product, significant staining, excessive odor, high PID readings). Those areas with soil/fill above the CSCOs will require cover under commercial reuse scenarios; however, unless these soils are also grossly impacted, no further investigation or remediation is warranted. The hotspots for the Site include:

Petroleum impact in test pit BP1A-TP-9 (i.e., petroleum odors with floating product on test pit water).

Visually impacted layer of fill material with moth-ball like odor in the upper 2 feet at test pit locations BP1A-TP-10 (tar-like) and BP1A-TP-11 (petroleum-like).

PAH-impacted surface and subsurface soil/fill near SS-03, BP1A-TP-7, BP1A-TP-11, and BP1A-TP-12 with total SVOC concentrations above 500 ppm.

Mercury-impacted surface soil/fill near SS-09 through SS-11, and subsurface soil/fill near BP1A-TP-10 through BP1A-TP-12.

Lead-impacted surface soil/fill near SS-09 through SS-11.

Cadmium-impacted surface soil/fill near SS-09 through SS-11.

Arsenic-impacted surface soil/fill near SS-09 and BP1A-TP-2.

In developing the RAOs, consideration is given to the reasonably anticipated future use of the Site as further discussed in Section 8.4 (i.e., for commercial and/or industrial purposes), and the applicable Standards, Criteria, and Guidance (SCGs), including soil cleanup guidance per 6 NYCRR Part 375 and GWQS/GVs per Technical and Operational Guidance Series (TOGS) 1.1.1. Accordingly, the RAOs for the Site are to:


0071-010-350 35

Remediate hotspot unsaturated surface and saturated subsurface soil/fill as described above.

Mitigate exposure to soil/fill where contaminant levels exceed CSCOs.

Mitigate exposure to PCBs on surfaces where contaminant levels exceed the cleanup criteria of 10 ug/100 cm2.

Implement and maintain engineering and institutional controls to assure that the Site is not used in a manner inconsistent with the reasonably anticipated future use scenario.

As discussed in Section 4.4.1, two post-cleaning floor wipe samples (i.e., T-144-146-2A and T-144-146-2B) collected from the Power House No. 1 building floor remain above the USEPA recommended PCB cleanup criteria for low-contact restricted access areas. While these areas are indoors in unoccupied buildings and do not necessarily represent an environmental condition under the current use scenario, they should be treated as building contaminants and addressed prior to building reuse and/or in concert with building demolition.

8.2 General Response Actions General Response Actions are broad classes of actions that may satisfy the RAOs.

General response actions form the foundation for the identification and screening of remedial technologies and alternatives. General Response Actions considered for the Site are:

Excavation and on-site treatment or off-site disposal of impacted soil/fill.

Engineering controls or cover to mitigate contact and contaminant transport.

Institutional controls (e.g., deed restrictions and other administrative measures) to restrict use of the Site and mitigate unacceptable exposure.

8.3 Standards, Criteria and Guidance (SCGs) This section provides a summary of the standards, criteria, and guidance (SCGs) that

are considered applicable or relevant and appropriate to remediation of the Site. SCGs include New York State laws, regulations, and guidance as well as more stringent Federal requirements.

Applicable SCGs pertain to cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under NY State or Federal environmental or facility siting laws that specifically address a hazardous substance, pollutant,


0071-010-350 36

contaminant, remedial action, location, or other circumstance at a site. An applicable requirement must directly and fully address the situation at the site.

Relevant and appropriate SCGs pertain to cleanup standards, standards of control, or other substantive requirements, criteria, or limitations promulgated under NY State or Federal environmental or facility siting laws that, while not “applicable” to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a site, address problems or situations sufficiently like those encountered at the site that their use is well suited to the particular site.

SCGs are classified as chemical-, action-, or location-specific. Additional discussions concerning the specific chemical, action and location-specific SCGs that may be applicable, relevant, or appropriate to remedy selection at the Site are presented below. In each case, the identified SCGs are generally limited to regulations or technical guidance in lieu of the environmental laws from which they are authorized, as the laws are typically less prescriptive in nature and are inherently considered in the regulatory and guidance evaluations.

Chemical-Specific SCGs Chemical-specific SCGs are usually health- or risk-based concentrations in

environmental media (e.g., air, soil, water), or methodologies that when applied to site-specific conditions, result in the establishment of concentrations of a chemical that may be found in, or discharged to, the ambient environment. The determination of potential chemical-specific SCGs for a site is based on the nature and extent of contamination; potential migration pathways and release mechanisms for site contaminants; the presence of human receptor populations; and the likelihood that exposure to site contaminants will occur.

The RI performed for the Phase IA Business Park provides this information. RI sampling events included the collection and analysis of surface soil, subsurface soil, groundwater, and PCB wipe samples. Table 11 presents a list of chemical-specific NY State and Federal SCGs that may be applicable or relevant and appropriate to the Site.

Groundwater samples collected during the RI were compared to NYSDEC Class GA GWQSs/GVs. According to NYSDEC CP-51 Soil Cleanup Guidance (Ref. 6), NYSDEC may approve a remedial program that achieves a soil cleanup level of 500 mg/kg for total PAHs for all subsurface soil on non-residential use sites. The 500 mg/kg soil cleanup level is in lieu of achieving all the PAH-specific SCOs in 6 NYCRR 375-6. Therefore, this CP-51 soil


0071-010-350 37

guidance level is proposed for the Site. One of the remedial alternatives to be assessed for the Site is a Track 4 cleanup for soil/fill; therefore, a site-specific action level (SSAL) for arsenic was developed for the Site. Arsenic is a ubiquitous metal with urban background soils in New York State frequently containing concentrations above the CSCO (16 mg/kg). Accordingly, comparison of the arsenic data to site-specific background or average concentration is considered appropriate. To determine the Site background concentration, all surface and sub-surface soil/fill arsenic data for the Phase IA Business Park was tabulated and the 95% upper confidence limit (95% UCL) on the mean was calculated (see Appendix G). Based on this analysis and further discussions with the NYSDEC, a site-specific SCO of 118 ppm has been established as the screening criteria for hotspot identification.

Location-Specific SCGs Location-specific SCGs generally are restrictions imposed when remedial activities are

performed in an environmentally sensitive area or special location. Some examples of special locations include floodplains, wetlands, historic places, and sensitive ecosystems or habitats.

The location of the Site is a fundamental determinant of its impact on human health and the environment. Location-specific SCGs are restrictions placed on the concentration of hazardous substances or the conduct of activities solely because they are in a specific location. Some examples of these unique locations include floodplains, wetlands, historic places, and sensitive ecosystems or habitats. Table 12 presents the location-specific SCGs that may be applicable or relevant and appropriate to the Site.

Action-Specific SCGs Action-specific SCGs are restrictions placed on certain treatment or disposal

technologies. Examples of action-specific SCGs are effluent discharge limits and hazardous waste manifest requirements.

Table 13 identifies action-specific SCGs that may significantly impact the selection of remedial alternatives for the Phase IA Business Park. This list of potential action-specific SCGs is based on the candidate remedial alternatives identified in Section 10.


0071-010-350 38

8.4 Future Use Evaluation In developing and screening remedial alternatives, NYSDEC’s Part 375 regulations

require that the reasonableness of the anticipated future land use be factored into the evaluation. The regulations identify 16 criteria that must be considered. These criteria and the resultant outcome for the Phase IA Business Park are presented in Appendix H. As indicated, the evaluation supports commercial and/or industrial redevelopment as the reasonably anticipated future use of the Site, consistent with surrounding Site use, zoning, and the Master Redevelopment Plan endorsed by Tecumseh, Erie County, and the City of Lackawanna. The remedial alternatives identified in Section 10 are evaluated against their consistency with the reasonably anticipated land use as well as other screening criteria.

In addition to the evaluation of alternatives to remediate to the likely end use of the Site, NYSDEC regulation and policy calls for evaluation of an unrestricted use scenario (considered under 6NYCRR Part 375-2.8 to be representative of cleanup to pre-disposal conditions). Per NYSDEC DER-10 Technical Guidance for Site Investigation and Remediation (Ref. 3), evaluation of a “no-action” alternative is also required to provide a baseline for comparison against other alternatives.


0071-010-350 39

9.0 VOLUME, NATURE, AND EXTENT OF CONTAMINATION Estimation of the volume, nature, and extent of media that may require remediation to

satisfy the RAOs or that needs to be quantified to facilitate evaluation of remedial alternatives is presented in this section. The estimates are a function of the cleanup goal. For the unrestricted use scenario, the cleanup goal would involve achieving USCOs, whereas for the reasonably anticipated future use scenario, the cleanup goal would involve achieving the CSCOs. The volume and extent of media requiring cleanup under these scenarios is presented in Sections 9.1 and 9.2. In addition, the volume and extent of “hotspot” material that may need to be addressed to achieve the RAO for remediation of these areas is discussed in Section 9.3. In all instances, these volume estimates (and associated cost estimates presented later in this AAR) are projected based on limited data and observations collected during the RI; additional pre-remedial investigation would be required to refine the estimates, particularly for hotspot areas.

9.1 Comparison to USCOs Exceedance of the USCOs was noted in many surface and subsurface soil/fill samples

collected, primarily for PAHs (petroleum SVOCs) and metal COCs (i.e., arsenic, cadmium, chromium, lead, and mercury). Due to the highly ubiquitous nature of the constituents observed in Site soil/fill and the extent to which they exceed the USCOs, it is likely that the entire 12.31-acre property defines the impacted soil/fill area. The depth of impact is assumed to extend into native material, with an average depth of approximately 8 fbgs. Thus, the volume of impacted soil/fill requiring remediation is approximately 126,500 cubic yards (CY).

9.2 Comparison to CSCOs The soil/fill data indicated exceedance of the Part 375 CSCOs for several ubiquitous

constituents. Specifically, nearly all samples collected exhibited an exceedance of the CSCO for total arsenic, with several samples also exceeding CSCOs for one or more of the PAHs. Based on these widespread exceedances it is likely that the volume of impacted soil/fill requiring remediation to achieve CSCOs is identical to that calculated above (i.e., approximately 126,500 CY).


0071-010-350 40

9.3 Hotspot Soil/Fill As discussed in Section 8.1, certain surface soil and test pit locations contained elevated

levels of COCs, with three locations corroborated by visual impacts. Figure 5 identifies the location of the impacted areas; except for Hotspot C, the dimensions of each area are approximated since the extent has not been fully defined. The estimated areal and vertical extent of impact in these source areas is described below. These volumes will be confirmed during remedial activities.

Hotspot A – Test Pit BP1A-TP-9: Petroleum product was observed floating on the groundwater at approximately 6 fbgs, together with strong petroleum-like odor. Exploratory test pits near BP1A-TP-9 were excavated to determine the extent of visually impacted fill material. The extent of impact is estimated to be a 15-foot x 45-foot area by 8 feet deep, for a corresponding in-place volume of approximately 200 CY. Accounting for contingency and excavation inefficiencies, the volume for ex-situ treatment and/or disposal alternatives is estimated to be 300 CY. Based on the TCLP data, the soil/fill is considered non-hazardous. Since the depth to water is approximately 6 fbgs, groundwater management may be required.

Hotspot B – Test Pits BP1A-TP-10, BP1A-TP-11 & BP1A-TP-12: A visually impacted layer of fill material was observed in the upper 2 feet at test pit locations BP1A-TP-10 (tar-like) and BP1A-TP-11 (petroleum-like). Subsurface test pit samples collected from BP1A-TP-11 (0.5-3.0 fbgs) and BP1A-TP-12 (0.5-6.0 fbgs) exhibited elevated concentrations of PAHs (above 500 pm). Mercury was also detected at slightly elevated concentrations in each test pit. Absent further delineation of the extent of the impact, an estimated 50-foot x 80-foot area to 6 fbgs has been assumed, for a corresponding in-place volume of approximately 890 CY. Accounting for contingency and excavation inefficiencies, the volume for ex-situ treatment and/or disposal alternatives is estimated to be 1,335 CY. Since the depth to water is approximately 6 fbgs, groundwater management will not likely be required.

Hotspot C – Test Pit BP1A-TP-7: This test pit exhibited elevated concentrations of PAHs in the subsurface soil from the 0.5 to 5.5 fbgs interval. An estimated 20-foot x 20-foot x 6-foot area of impact has been assumed, for a corresponding in-place volume of approximately 90 CY. Accounting for contingency and excavation inefficiencies, the volume for ex-situ treatment and/or disposal alternatives is estimated to be 135 CY. Further delineation of the extent of the impact will be required at this location.

Hotspot D – Surface Soil SS-03: This historic surface soil sample exhibited elevated concentrations of PAHs, as well as lead slightly above the CSCO. An estimated 20-foot x 20-foot x 2-foot area has been assumed, for a corresponding


0071-010-350 41

in-place volume of approximately 30 CY. Accounting for contingency and excavation inefficiencies, the volume for ex-situ treatment and/or disposal alternatives is estimated to be 45 CY. Further delineation of the extent of the impact will be required at this location.

Hotspot E, F, & G – Surface Soils SS-09, SS-10, & SS-11: These sample locations exhibited elevated concentrations of arsenic (SS-09 above its site-specific SCO), cadmium (SS-11 above its ISCO), lead, and mercury in the shallow soil/fill. An estimated 20-foot x 20-foot area with a depth of 2 fbgs has been assumed for each location, for a corresponding in-place volume of approximately 30 CY per location. Accounting for contingency and excavation inefficiencies, the volume for ex-situ treatment and/or disposal alternatives is estimated to be 45 CY per location.

Hotspot H – BP1A-TP-2: An elevated arsenic concentration was detected in the 0.5-3.5 fbgs sample in test pit BP1A-TP-2. Absent further delineation, an estimated 20-foot x 20-foot area has been assumed. Although the elevated arsenic is likely present in the upper 2 feet, a 4-foot depth has been assumed. The corresponding in-place volume is approximately 60 CY. Accounting for contingency and excavation inefficiencies, the total volume for ex-situ treatment and/or disposal alternatives is estimated to be 90 CY.

Based on the estimated and assumed extent of the impacts described above, the total estimated in-place volume of hotspot contamination is 1,360 CY. The volume of soil/fill for ex-situ treatment and/or disposal alternatives is estimated to be 2,040 CY.


0071-010-350 42

10.0 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES

10.1 Development of Alternatives The following remedial alternatives have been developed in accordance with the

General Response Actions and NYSDEC regulation and policy:

Alternative 1: No Action

Alternative 2: Unrestricted-Use (Track 1) Cleanup

Alternative 3: Restricted-Use (Track 4) Cleanup with Placement of Soil Cover System Prior to Site Redevelopment

Alternative 4: Restricted-Use (Track 4) Cleanup with Deferred Soil Cover System during Site Redevelopment

Institutional controls, though identified in the General Response Actions, were not identified as a stand-alone remedial alternative because a deed restriction prohibiting use of groundwater and limiting land reuse to industrial and similar non-residential settings already exists for the larger Tecumseh property. Accordingly, all alternatives inherently include these institutional controls. Similarly, all alternatives, except for the “no action” alternative, will include removal of the floor areas where surfaces remain above 10 ug/100 cm2 PCBs. In addition, Alternatives 3 and 4 will require development and enforcement of a Site Management Plan (see Section 11.2). Other institutional and engineering controls that would be considered applicable for this Site and would be incorporated into the remedial alternatives are described in greater detail in Section 11.2.1.

10.2 Evaluation of Alternatives NYSDEC’s Brownfield Cleanup Program calls for remedy evaluation in accordance

with DER-10 Technical Guidance for Site Investigation and Remediation (Ref. 3). In addition to achieving RAOs, the remedial alternatives are evaluated against the following criteria consistent with 6NYCRR Part 375-1.8(f):

Overall Protection of Public Health and the Environment. This criterion is an evaluation of the remedy’s ability to protect public health and the environment, assessing how risks posed through each existing or potential pathway of exposure


0071-010-350 43

are eliminated, reduced, or controlled through removal, treatment, engineering controls, or institutional controls.

Compliance with Standards, Criteria, and Guidance (SCGs). Compliance with SCGs addresses whether a remedy will meet applicable environmental laws, regulations, standards, and guidance.

Long-Term Effectiveness and Permanence. This criterion evaluates the long-term effectiveness of the remedy after implementation. If wastes or treated residuals remain on-site after the selected remedy has been implemented, the following items are evaluated: (i) the magnitude of the remaining risks (i.e., will there be any significant threats, exposure pathways, or risks to the community and environment from the remaining wastes or treated residuals), (ii) the adequacy of the engineering and institutional controls intended to limit the risk, (iii) the reliability of these controls, and (iv) the ability of the remedy to continue to meet RAOs in the future.

Reduction of Toxicity, Mobility, or Volume with Treatment. This criterion evaluates the remedy’s ability to reduce the toxicity, mobility, or volume of Site contamination. Preference is given to remedies that permanently and significantly reduce the toxicity, mobility, or volume of the wastes at the Site.

Short-Term Impacts and Effectiveness. Short-term effectiveness is an evaluation of the potential short-term adverse impacts and risks of the remedy upon the community, the workers, and the environment during construction and/or implementation. This includes a discussion of how the identified adverse impacts and health risks to the community or workers at the Site will be controlled, and the effectiveness of the controls. This criterion also includes a discussion of engineering controls that will be used to mitigate short term impacts (i.e., dust control measures), and an estimate of the length of time needed to achieve the remedial objectives.

Implementability. The implementability criterion evaluates the technical and administrative feasibility of implementing the remedy. Technical feasibility includes the difficulties associated with the construction and the ability to monitor the effectiveness of the remedy. For administrative feasibility, the availability of the necessary personnel and material is evaluated along with potential difficulties in obtaining specific operating approvals, access for construction, etc.

Cost-Effectiveness. Capital, operation, maintenance, and monitoring costs are estimated for each remedial alternative and presented on a present worth basis. Detailed cost estimates for each alternative, excluding the no action alternative, are presented on Tables 14 through 16.

Community Acceptance. This criterion evaluates the public’s comments, concerns, and overall perception of the remedy. The Community Acceptance criterion incorporates public concerns into the evaluation of the remedial


0071-010-350 44

alternatives. Therefore, Community Acceptance of the remedy will be evaluated after the public comment period required by the BCP.

Land Use. In addition to the above criteria, 6NYCRR Part 375-1 specifies that the criterion of Land Use (i.e., the current, intended, and reasonably anticipated future land uses of the Site and its surroundings) be considered in the selection of the remedy. The intended future land use was initially submitted to the NYSDEC via the BCP application. The reasonably anticipated future use of the Site in a commercial/industrial capacity (i.e., as a business park) is further discussed in Appendix H.

Alternative 1: No Action The no-action alternative is defined as taking no additional actions to address the

impacted soil/fill. The Site is presently subject to a deed restriction prohibiting groundwater use and limiting reuse to industrial and similar non-residential settings; the Site is fenced along NYS Route 5. While these controls would not be removed, the no action alternative assumes that there would be no maintenance, monitoring, or certifications to assure that these controls remain in place and effective. The no-action alternative also provides a baseline for comparison against the other remedial alternatives and justifies the need for any remedial action.

Overall Protection of Public Health and the Environment – This alternative would

protect public health under the current use scenario via the existing engineering and institutional controls; however, localized areas of environmental impact associated with hotpot areas would remain. This alternative would not meet the RAOs for the Site.

Compliance with SCGs – This alternative would not address source area materials or

mitigate exposure to contaminants above SCOs and would therefore not comply with SCGs per 6NYCRR Part 375.

Long-Term Effectiveness and Permanence – This alternative provides no long-

term maintenance measures and, as such, provides no reliable long-term control against exposure to impacted soil/fill. All current and future risks would remain under this alternative.


0071-010-350 45

Reduction of Toxicity, Mobility, or Volume with Treatment – This alternative provides no reduction in toxicity, mobility, or volume of COCs in soil/fill.

Short-Term Impacts and Effectiveness – There would be no additional risks posed

to the community, Site workers, or the environment associated with implementation of this alternative.

Implementability – No technical implementability issues or action-specific

administrative implementability issues are associated with this alternative. Cost-Effectiveness – There are no capital or operation, maintenance, and monitoring

costs associated with this alternative. Land Use – This alternative is consistent with the reasonably anticipated future use of

the Site but would not promote commercial and industrial redevelopment due to the absence of a release from liability and placement of the responsibility to assure protection of public health following redevelopment on the future buyer or developer.

Alternative 2: Unrestricted-Use (Track 1) Cleanup For unrestricted use scenarios, excavation and off-site treatment or disposal of

impacted soil/fill would be performed, obviating the need for engineering and institutional controls. This alternative would necessitate excavation of all soil/fill where COCs exceed USCOs per 6NYCRR Part 375, with transport of the excavated materials to and disposal at a permitted, off-site disposal facility. The estimated total volume of impacted soil/fill that would be removed from the Site and disposed off-site is approximately 126,500 CY. The same volume of clean soil would be necessary to backfill the excavation. For purposes of cost estimating, all excavated materials are assumed to be non-hazardous and would be transported to a commercial solid waste disposal facility. Previous experience during test pit excavations indicates the material is well-drained; however, provisions for managing groundwater will be in place.

Alternative 2 would also require removal of low-contact impervious surfaces with PCB concentrations above 10 ug/m2 in the Power House No. 1 Building.


0071-010-350 46

Overall Protection of Public Health and the Environment – Excavation and off-

site disposal to USCOs would be protective of public health under any reuse scenario. However, this alternative would permanently use and displace 126,500 CY of valuable landfill airspace, causing ancillary environmental issues due to reduced landfill capacity, and would require removal of 126,500 CY of clean soil from an off-site borrow source, also contributing to significant detrimental off-site environmental issues. Removing the PCB-impacted floor surfaces will mitigate any potential exposure.

Compliance with SCGs – Excavation and off-site soil/fill disposal as well as removal

of PCB-impacted floor surfaces would need to be performed in accordance with applicable, relevant, and appropriate SCGs. Soil excavation activities would necessitate preparation of and adherence to a community air monitoring plan for particulates in accordance with Appendix 1B of DER-10.

Long-Term Effectiveness and Permanence – This alternative would achieve

removal of all impacted soil/fill and potential for contact with PCB-impacted floor surfaces thereby providing long-term effectiveness and permanence. Post-remedial monitoring and certifications would not be required.

Reduction of Toxicity, Mobility, or Volume with Treatment – Through removal

of all impacted soil/fill and PCB-impacted floor surfaces, this alternative would permanently and significantly reduce the toxicity, mobility, and volume of contamination on the Site. However, since this alternative transfers Site soil/fill from one environment to another, an overall reduction of toxicity, mobility, and volume would not occur.

Short-Term Impacts and Effectiveness – The short-term adverse impacts and risks

to the community, workers, and environment during implementation of this alternative are significant. Site workers would be required to wear personal protective equipment (PPE) during excavation to prevent direct contact with soil/fill and PCB-impacted concrete. Dust control methods would be required to limit the release of particulates during placement of the backfill soils. Physical hazards, primarily related to potential accidents from heavy truck traffic


0071-010-350 47

on NY State Route 5, would be expected. Substantial disruption of the neighboring community would occur due to material transport and deliveries and noise from heavy equipment used to construct the remedy. The Remedial Action Objectives would be achieved once the soil/fill is removed from the Site and backfill soils are in place (est. 1 year).

Implementability – Significant technical and administrative implementability issues

would be encountered in construction of this unrestricted use alternative. These include but are not limited to the need for construction, maintenance, and operation of substantial dewatering facilities; and traffic coordination for trucks entering/exiting NY State Route 5.

Cost-Effectiveness – Capital costs for implementation of this alternative are

estimated at $15.6 million. There are no operation and maintenance costs associated with this alternative. Table 14 presents a breakdown of these capital costs.

Land Use – This alternative, although inconsistent with the reasonably anticipated

future use of the Site, would not preclude commercial and industrial redevelopment.

Alternative 3: Restricted-Use (Track 4) Cleanup with Placement of Soil Cover System Prior to Redevelopment

This alternative would initially involve removal of the eight hotspot areas described in Section 9.3. The petroleum-impacted soil/fill (Hotspots A and C) would likely be treated via on-site bioremediation (e.g., on a biopad constructed in Business Park IA) with relocation of the treated soils back into the excavation area. Since product was observed on the water at approximately 6 fbgs in test pit BPIA-TP-9 (Hotspot A), water encountered during excavation will be collected, if visually impacted, and treated prior to surface discharge. To address residual smear zone soil/fill impacts in Hotspot A, a chemical amendment such as oxygen release compound (ORC) or ORC Advanced will be mixed into the saturated soils at the bottom of the excavation prior to backfilling to enhance subsequent in-situ aerobic bioremediation of saturated soils and localized groundwater. The remaining hotspot soil/fill areas, containing metals and/or petroleum with metals, are assumed to be non-hazardous and would be excavated and disposed off-site at a permitted solid waste disposal facility. If during remedial actions, soil/fill fails TCLP then the soil/fill would be stabilized in-place using an


0071-010-350 48

amendment such as Portland cement. Previous experience during test pit excavations indicates the material is well-drained; however, if necessary, groundwater will be collected, treated via filtration and granular activated carbon (GAC), and discharged to an on-site soil surface with NYSDEC approval.

Like Alternative 2, this alternative also includes removal of low-contact impervious surfaces with PCB concentrations above 10 ug/m2 in the Power House No. 1 Building with off-site disposal.

Following hotspot soil/fill removal, a 12-inch soil cover would be installed over the approximate 8 acres not covered by buildings, concrete slabs, or competent asphalt prior to Certificate of Completion issuance and redevelopment. The estimated total volume of clean soil required for the cover system is approximately 12,900 CY. The cover would then be removed, as necessary, to accommodate build-out during the redevelopment period. Standard institutional and engineering controls would also be implemented under this alternative. Specifically, a Site Management Plan (SMP) incorporating an Excavation Plan; an Operation, Maintenance, and Monitoring (OM&M) Plan; and ongoing Engineering and Institutional Control certification requirements would be developed and enforced through an environmental easement. The environmental easement will restrict use of the Phase IA Business Park to commercial and industrial applications and preclude groundwater use without treatment.

Overall Protection of Public Health and the Environment – Removing the hotspot

soil/fill, treating impacted water, applying an amendment, and removing the PCB-impacted floor surfaces, followed by cover system placement will mitigate any potential exposure. This alternative meets NYSDEC requirements for a Track 4 cleanup under the BCP regulations and is therefore protective of public health and the environment at the Site. Accordingly, Alternative 3 would achieve the RAOs. However, placement of a 12-inch soil cover over 8 acres of the Phase IA Business Park would require immediate clearing of the Site and borrow source(s), resulting in rapid loss of 8 acres of greenhouse gas consuming plant life and cover for habitat and foraging on-site and a likely similar acreage off-site, which is inconsistent with NYSDEC’s DER-31 green remediation policy (Ref. 7). In addition, significant short-term impacts would result from implementation of this alternative as described below.


0071-010-350 49

Compliance with SCGs – Excavation and off-site soil/fill disposal, on-site biotreatment of petroleum-impacted soil/fill, and removal of PCB-impacted floor surfaces would need to be performed in accordance with applicable, relevant, and appropriate SCGs. Imported cover material would need to meet backfill quality criteria per 6NYCRR Part 375. Borrow source mining would require a permit and storm water pollution prevention plan (SWPPP) for all disturbed areas greater than 1 acre in size. Vegetative cover stripping and cover placement would be performed under the BCP and would therefore require an equivalent SWPPP to address on-site impacts. Subgrade preparation activities would necessitate preparation of and adherence to a community air monitoring plan for fugitive dust and particulate monitoring in accordance with Appendix 1B of DER-10. As indicated above, this alternative is inconsistent with NYSDEC’s DER-31 green remediation policy due to rapid loss of vegetative cover on the site and off-site, as well as significant air emissions attributable to use of heavy diesel equipment for excavation and transport onsite and at the borrow source.

Long-Term Effectiveness and Permanence – Removal of the hotspot soil/fill areas,

treatment of excavation water and smear zone soil/fill in Hotspot A, and removal of PCB-impacted floor surfaces as well as construction of a cover system prior to redevelopment would prevent direct contact with soil/fill exceeding CSCOs. The efficacy of the cover system will be maintained and monitored via the Site Management Plan. Periodic inspection and maintenance of the cover and possible repair of the soil and vegetative layers would be required to assure long-term cover integrity. The institutional controls outlined in Section 11 would be required for long-term effectiveness.

Reduction of Toxicity, Mobility, or Volume with Treatment – Bioremediation of

hotspot soil/fill would permanently and significantly reduce the toxicity, mobility, and volume of the soil/fill that could potentially be contacted or produce localized areas of environmental impact at the Site. Treatment of impacted excavation water and in situ treatment of smear zone soil/fill would reduce the toxicity, mobility, and volume of contamination. Excavation and off-site disposal of the metal-impacted soil/fill would reduce the toxicity, mobility, and volume of impacted soil/fill on-site; however, since this alternative transfers Site soil/fill from one environment to another, an overall reduction of toxicity and volume would not occur. Placement of a soil cover over the remaining areas would somewhat reduce the mobility of


0071-010-350 50

contaminants from erosion, although the RI concluded that this pathway is not likely significant under the current (undeveloped) scenario. Accordingly, the toxicity, mobility, and volume of remaining residual contaminants would not be appreciably reduced under this alternative. Removal of PCB-impacted floor surfaces would permanently reduce the toxicity, mobility, and volume of PCB contamination on the Site.

Short-Term Effectiveness and Impacts – Similar to Alternative 2, the short-term

adverse impacts and risks to the community, workers, and environment during implementation of this approach are significant. Because Site clearing and soil cover placement would occur in a single construction season as opposed to a gradual progression during build out, immediate disruption of wildlife habitat would occur due to material transport, deliveries, noise, and air emissions from heavy equipment used to strip the site and construct the cover.

Moreover, under this alternative, the Phase IA Business Park would require over 12,900 CY of imported cover soil, which would be stripped from an off-site borrow source and then transported to the Site in approximately 920 truckloads and graded/raked using heavy, diesel-fueled grading equipment. This action alone would result in storm water impacts at the borrow source(s) and on-site; diesel fuel consumption on the order of 2,300 gallons (assuming 20 miles round trip, 8 miles per gallon); and related traffic, dust, and air emissions. These impacts would be compounded when redevelopment is initiated, as much of the soil cover (est. 80%) would need to be removed and hauled off-site to allow for build out. Thus, an additional 1,840 gallons of diesel fuel may be consumed, resulting in total consumption of approximately 4,140 gallons of diesel fuel for transportation, with additional consumed by excavation and grading equipment. The USEPA’s estimated CO2 generation rate for diesel engines is approximately 22.2 pounds per gallon of diesel consumed. Accordingly, the transportation of soil cover to the Site and subsequent removal and off-site transportation would produce approximately 91,900 pounds of greenhouse gas while at the same time stripping hundreds of acres of CO2 consuming trees and shrubs.

Finally, the existing soil/fill currently allows for good surface water percolation and drainage. If a soil cover were placed over the Phase IA Business Park ahead of redevelopment, it would be absent the permanent storm water drainage system and Site grading that will be designed and constructed when redevelopment occurs. As a result, ponding, washout, and undesirable drainage patterns can be expected, damaging the cover system if soil cover is


0071-010-350 51

placed before final grading and storm water collection and conveyance systems are in place. The RAOs would be achieved upon cover placement.

Implementability – Technical implementability issues anticipated under this

alternative include traffic coordination for trucks entering and exiting NY State Route 5 and the need to design and provide for significant erosion and storm water controls to mitigate ponding, washout, and undesirable storm water drainage and runoff patterns. A pre-redevelopment cover system is also certain to be damaged and repaired multiple times by development work and buried infrastructure (sewer, water, gas, electric, telephone, etc.), necessitating multiple inspections by an environmental professional, and documentation/ explanation in annual Periodic Review Reports.

No significant administrative implementability issues are associated with this alternative.

Cost-Effectiveness – The estimated capital cost for this alternative is $1.0 million,

including hotspot removal, bioremediation, and off-site disposal; treatment of Hotspot A water and application of amendment; removal of PCB-impacted floor surfaces; construction of the 12-inch landscape cover over an approximate 8 acres; development of a Site Management Plan; and environmental-based redevelopment costs associated with removal of the temporary soil cover system. Annual OM&M costs for cover maintenance and annual certifications are estimated to be $24,000, resulting in an estimated 30-year present worth cost of $1.8 million. Table 15 presents a breakdown of these costs.

Land Use – This alternative would be consistent with the reasonably anticipated future

use of the Site. However, the placement of soil cover over the Site would significantly impair the ability and cost of redeveloping the Site. Redevelopment would require the removal and displacement of most if not all soil cover during infrastructure and building construction, would necessitate deeper excavation to access existing for utilities, and would limit the ability to locate existing foundations and other near-surface structures that may require removal during redevelopment.


0071-010-350 52

Alternative 4: Restricted-Use (Track 4) Cleanup with Deferred Cover System during Site Redevelopment

This alternative is the same as Alternative 3 in that it provides for construction of a 12-inch soil cover over exposed areas of the Site following hotspot soil/fill removal and in-situ treatment of saturated soil/fill in Hotspot A; however, the cover would be placed during the redevelopment stage to coordinate with and exclude the cover that inherently will be provided by building, road, parking areas and landscaping. COC issuance would occur following cover placement. A Site Management Plan and environmental easement (see Section 11) would be prepared.

Alternative 4 also includes removal of the low-contact impervious surfaces with PCB concentrations above 10 ug/m2 in the Power House No. 1 Building.

Overall Protection of Public Health and the Environment – Based on the removal

of PCB-impacted floor surfaces; removal of hotspot soil/fill; treatment of impacted water in Hotspot A and application of an amendment like ORC; and the fact that the Site is isolated, covered by indigenous vegetation, secured with fencing, and patrolled by security during off hours to discourage trespassing, this alternative is protective of public health and the environment under the current (undeveloped) remediated scenario. This alternative would be protective of public health and the environment under the future use scenario, as it provides for implementation of the 12-inch cover system in areas not otherwise covered by buildings, roads, etc. Therefore, Alternative 4 successfully achieves the RAOs for the Site.

Compliance with SCGs – Excavation and off-site soil/fill disposal, on-site

biotreatment of petroleum-impacted soil/fill, and removal of PCB-impacted floor surfaces would need to be performed in accordance with applicable, relevant, and appropriate SCGs. Imported cover material would need to meet backfill quality criteria per 6NYCRR Part 375. Borrow source mining would require a permit and SWPPP for all disturbed areas greater than 1 acre in size. Vegetative cover would be placed during the redevelopment period along with building, road, and other build-out and as such would be subject to storm water regulations. Soil excavation and cover activities would necessitate preparation of and adherence to a community air monitoring plan for fugitive dust and particulate monitoring in accordance with Appendix 1B of DER-10.


0071-010-350 53

Long-Term Effectiveness and Permanence – Removal of the hotspot soil/fill,

treatment of excavation water and smear zone soil/fill in Hotspot A, and removal of PCB-impacted floor surfaces as well as construction of a cover system prior to occupancy would prevent direct contact with soil/fill exceeding CSCOs. The efficacy of the cover system will be maintained and monitored via the Site Management Plan. Periodic inspection and maintenance of the soil cover as well as the “hardscape” cover provided by asphalt roads, concrete, etc. would be required to assure long-term cover integrity. The institutional controls outlined in Section 11 would be required for long-term effectiveness.

Reduction of Toxicity, Mobility, or Volume with Treatment – Bioremediation of

hotspot soil/fill would permanently and significantly reduce the toxicity, mobility, and volume of the soil/fill that could potentially be contacted or produce localized areas of environmental impact at the Site. Treatment of impacted excavation water and in situ treatment of smear zone soil/fill would reduce the toxicity, mobility, and volume of contamination. Excavation and off-site disposal of the metal-impacted soil/fill would reduce the toxicity, mobility, and volume of impacted soil/fill on-site; however, since this alternative transfers Site soil/fill from one environment to another, an overall reduction of toxicity and volume would not occur. Placement of a soil cover in conjunction with cover provided by build-out over the remaining areas may somewhat reduce the mobility of contaminants from erosion, although the RI concluded that this pathway is not likely significant under the current (undeveloped) scenario. Accordingly, the toxicity, mobility, and volume of remaining residual contaminants would not be appreciably reduced under this alternative. Removal of PCB-impacted floor surfaces would permanently reduce the toxicity, mobility, and volume of PCB contamination on the Site.

Short-Term Impacts and Effectiveness – Because cover will be placed on a gradual

basis as development occurs and will exclude hardscape cover inherently provided by buildings, roads, parking areas, etc. (which are anticipated to represent 50% of the Site acreage), short-term impacts will be minimized. As the cover soil placement will coordinate with the build-out, no additional removal work will be required. Community air monitoring, dust control, and soil erosion measures would only be required during Site development. The RAOs would be achieved upon cover placement.


0071-010-350 54

Implementability – No significant technical or administrative implementability issues

are anticipated under this alternative. Cost-Effectiveness – The estimated capital cost for this alternative is $813,000

including hotspot soil/fill removal, bioremediation, and off-site disposal; treatment of Hotspot A water and application of an amendment for treatment of saturated soil/fill in Hotspot A; removal of PCB-impacted floor surfaces; cover system construction during remediation (i.e., areas not covered by building, parking, or roads, assumed to be approximately 50% of the Site); development of a Site Management Plan; and environmental-based redevelopment costs associated with engineering oversight and air monitoring during intrusive work. Annual OM&M costs for cover maintenance and annual certifications are estimated to be $24,000, resulting in an estimated 30-year present worth cost of $1.5 million. Table 16 presents a breakdown of these costs.

Land Use – This alternative is consistent with the reasonably anticipated future use of

the Site. Furthermore, this alternative facilitates redevelopment by deferring final soil cover placement until redevelopment, thus avoiding the costs, time delays, and unnecessary disruption of placing, removing, and replacing cover during building, road, and utility construction.

10.3 Proposed Remedy The previous sections describe the remedial alternatives and evaluate these alternatives

against the screening criteria. This final section of the evaluation considers the information and evaluations contained in the previous sections to identify appropriate remedial measures to achieve the RAOs for the Phase IA Business Park.

The proposed remedial approach for the impacted soil/fill is Alternative 4 – Restricted-Use (Track 4) Cleanup with Deferred Cover System During Redevelopment because it satisfies the RAOs for the Site, is significantly less disruptive to the community, is consistent with current and future land use, and represents a lower cost than Alternatives 2 and 3. This alternative would involve removal of eight hotspot areas described in Section 9.3 followed by off-site disposal or on-site biotreatment of soil/fill. An estimated 2,040 CY of impacted soil/fill would be


0071-010-350 55

excavated (although confirmation of this volume would occur prior to or during remedy implementation). This alternative would also include treatment of Hotspot A water and in-situ treatment of residual impacts to saturated soil/fill following removal of Hotspot A, and removal of the remaining area of the floor impacted by PCBs. Regulated building materials, including residual asbestos containing material and fallen or deteriorated lead-based paint, if present, would be property abated and disposed off-site in accordance with NYS Department of Labor and NYSDOH requirements. If present, water in the Power House No. 1 basement will be pumped, characterized, and, if appropriate, treated with GAC and discharged to soil surface with NYSDEC approval.

As a condition of occupancy, the Site developer/owner would be required to cover all soil/fill areas that exceed the CSCOs with asphalt, building, or landscape cover. The landscape cover would involve placement of at least one foot of clean soil followed by seeding to promote vegetative growth. The clean soil would be required to meet NYSDEC DER-10 standards for commercial sites (i.e., lower of Part 375 human health or groundwater protection values).

The 30-year present worth cost is estimated to be $1.5 million with a projected $813,000 for capital expenditures and $24,000 for annual Site maintenance and environmental easement certification.


0071-010-350 56

11.0 POST-REMEDIAL REQUIREMENTS

11.1 Final Engineering Report Following completion of the hotspot area remedial measures, a Construction

Completion Report (CCR) documenting the cleanup activities and an associated Site Management Plan (SMP) and easement will be prepared for the Phase IA Business Park Site. A Final Engineering Report (FER) will be submitted to the NYSDEC once cover is placed. The FER will refer to the CCR and will include the following information and documentation, consistent with the NYSDEC regulations contained in 6 NYCRR Part 375-1.6(c):

Background and Site description.

Summary of the Site remedy that satisfied the remedial action objectives for the Site.

Certification by a professional engineer to satisfy the requirements outlined in 6 NYCRR Part 375-1.6(c)(4).

Description of engineering and institutional controls at the Site.

Site map showing the areas remediated.

Documentation of imported materials.

Documentation of materials disposed off-site.

Copies of daily inspection reports and, if applicable, problem identification and corrective measure reports.

Air monitoring data and reports.

Photo documentation of remedial activities.

Text describing the remedial activities performed; a description of any deviations from the Work Plan and associated corrective measures taken; and other pertinent information necessary to document that the site activities were carried out in accordance with this Work Plan.

Analytical data packages and data usability summary reports (DUSRs).

11.2 Site Management Plan A Site Management Plan (SMP) will be prepared and submitted concurrent with the

FER. The purpose of the Site Management Plan is to assure that proper procedures are in


0071-010-350 57

place to provide for long-term protection of human health and the environment after remedial construction is complete. The SMP is comprised of four main components:

Engineering and Institutional Control Plan

Site Monitoring Plan

Operation and Maintenance Plan

Inspections, Reporting, and Certifications

Engineering and Institutional Control Plan An institutional control in the form of a new Environmental Easement will be

necessary to limit future use of the Site to restricted (commercial or industrial) applications and prevent groundwater use for potable purposes. An existing deed restriction is on file for the Tecumseh Site limiting reuse to commercial/industrial applications. However, industrial uses are loosely defined and allow incidental commercial-type facilities such as offices and laboratories, provided they do not allow for occupancy by multiple numbers of persons under the age of 18. The deed restriction also prohibits construction or use of groundwater extraction wells (excluding monitoring and remediation wells).

Tecumseh will prepare an Engineering and Institutional Control (EC/IC) Plan that will include a complete description of all institutional and/or engineering controls employed at the Site, including the mechanisms that will be used to continually implement, maintain, monitor, and enforce such controls. The EC/IC Plan will include:

A description of all EC/ICs on the site.

The basic implementation and intended role of each EC/IC.

A description of the key components of the ICs set forth in the Environmental Easement.

A description of the features to be evaluated during each required inspection and periodic review, including the EC/IC certification, reporting, and Site monitoring.

A description of plans and procedures to be followed for construction of the 12-inch soil cover as a condition of occupancy.

Any other provisions necessary to identify or establish methods for implementing the EC/ICs required by the Site remedy, as determined by the NYSDEC.


0071-010-350 58

Site Monitoring Plan The Site Monitoring Plan will describe the measures for evaluating the performance

and effectiveness of the remedy to reduce or mitigate contamination at the Site, including:

Sampling and analysis of all appropriate media.

Assessing compliance with NYSDEC standards, criteria, and guidance, particularly Part 375 SCOs for soil.

Assessing achievement of the remedial performance criteria.

Evaluating site information periodically to confirm that the remedy continues to be effective in protecting public health and the environment; and

Preparing the necessary reports for the various monitoring activities.

To adequately address these issues, this Site Monitoring Plan will provide information on:

Sampling locations, protocol, and frequency.

Information on all designed monitoring systems (e.g., well logs).

Analytical sampling program requirements.

Reporting requirements.

Quality assurance/quality control (QA/QC) requirements.

Inspection and maintenance requirements for monitoring wells.

Monitoring well decommissioning procedures.

Annual inspection and periodic certification.

Operation and Maintenance Plan An Operation & Maintenance (O&M) plan governing maintenance of the cover system

will include:

Include the operation and maintenance activities necessary to allow individuals unfamiliar with the Site to maintain the soil cover system.

Include an O&M contingency plan.

Evaluate Site information periodically to confirm that the remedy continues to be effective for the protection of public health and the environment. If necessary, the


0071-010-350 59

O&M Plan will be updated to reflect changes in Site conditions or the way the cover system is maintained.

Inspections, Reporting, and Certifications

11.2.4.1 Inspections Site-wide inspection will be conducted annually or as otherwise approved by the

NYSDEC. All applicable inspection forms and other records, including all media sampling data and system maintenance reports, generated for the Site during the reporting period will be provided in electronic format in a Periodic Review Report (PRR).

11.2.4.2 Reporting

The PRR will be submitted to the NYSDEC annually, or as otherwise approved, beginning 18 months after the Certificate of Completion or equivalent document is issued. The PRR will be prepared in accordance with NYSDEC DER-10, be submitted within 45 days of the end of each certification period, and include:

Identification, assessment, and certification of all EC/ICs required by the remedy for the Site.

Results of the required annual Site inspections and severe condition inspections, if applicable.

All applicable inspection forms and other records generated for the Site during the reporting period in electronic format.

Data summary tables and graphical representations of contaminants of concern by media, which include a listing of all compounds analyzed, along with the applicable standards, with all exceedances highlighted. These will include a presentation of past data as part of an evaluation of contaminant concentration trends.

Results of all analyses, copies of all laboratory data sheets, and the required laboratory data deliverables for all samples collected during the reporting period will be submitted electronically in a NYSDEC-approved format.

A Site evaluation that includes the following:

- The compliance of the remedy with the requirements of the site-specific RAWP, ROD, or Decision Document.

- The operation and the effectiveness of all treatment units, etc., including identification of any needed repairs or modifications.


0071-010-350 60

- Any new conclusions or observations regarding site contamination based on inspections or data generated by the Site Monitoring Plan for the media being monitored.

- Recommendations regarding any necessary changes to the remedy and/or Site Monitoring Plan.

- The overall performance and effectiveness of the remedy.

11.2.4.3 Certification

The signed EC/IC Certification will be included in the PRR described in Section 11.2.4.2: For each institutional or engineering control identified for the Site, a Professional Engineer licensed to practice in New York State will certify that all of the following statements are true:

The inspection of the Site to confirm the effectiveness of the institutional and engineering controls required by the remedial program was performed under my direction.

The engineering and institutional controls employed at this Site are unchanged from the date the control was put in place, or last approved by the NYSDEC.

Nothing has occurred that would impair the ability of the control to protect the public health and environment.

Nothing has occurred that would constitute a violation or failure to comply with any Site Management Plan for this control.

Access to the Site will continue to be provided to the NYSDEC to evaluate the remedy, including access to evaluate the continued maintenance of this control.

If a financial assurance mechanism is required under the oversight document for the Site, the mechanism remains valid and sufficient for the intended purpose under the document.

Use of the Site is compliant with the Environmental Easement.

The engineering control systems are performing as designed and are effective.

To the best of my knowledge and belief, the work and conclusions described in this certification are in accordance with the requirements of the Site remedial program and generally accepted engineering practices.

The information presented in this report is accurate and complete.


0071-010-350 61

11.2.4.4 Corrective Measures Plan

If any component of the remedy is found to have failed, or if the periodic certification cannot be provided due to the failure of an institutional or engineering control, a Corrective Measures Plan will be submitted to the NYSDEC for approval. This plan will explain the failure and provide the details and schedule for performing work necessary to correct the failure. Unless an emergency condition exists, no work will be performed pursuant to the Corrective Measures Plan until it is approved by the NYSDEC.


0071-010-350 62

12.0 REFERENCES 1. URS Consultants, Inc. RCRA Facility Investigation (RFI) Report for the Former Bethlehem

Steel Corporation Facility, Lackawanna, New York, Parts I through VII, prepared for Bethlehem Steel Corporation. January 2005.

2. TurnKey Environmental Restoration, LLC in association with Benchmark Environmental Engineering & Science, PLLC. Construction Completion Report for Railroad Realignment, Tecumseh Phase I-III Business Park, Lackawanna, New York, BCP Site Nos. C915197-C915199. December 2013.

3. TurnKey Environmental Restoration, LLC. Remedial Investigation/Alternatives Analysis Report Work Plan for Phase IA Business Park Area. April 2010.

4. New York State Department of Environmental Conservation. DER-10/Technical Guidance for Site Investigation and Remediation. May 3, 2010.

5. New York State Department of Environmental Conservation and New York State Department of Health. New York State Brownfield Cleanup Program, Development of Soil Cleanup Objectives, Technical Support Document. September 2006.

6. New York State Department of Environmental Conservation. CP-51 Soil Cleanup Guidance. October 21, 2010.

7. New York State Department of Environmental Conservation. DER-31/Green Remediation. January 20, 2011.

RI/AA REPORT PHASE IA BUSINESS PARK AREA

0071-010-350

TABLES

TABLE 1

SUMMARY OF APRIL 2007 SURFACE SOIL DATA

RI/AA Report

Phase IA Business Park Area - Brownfield Cleanup Program


Sample Location and Analysis

BP1A-SS-01 BP1A-SS-02 BP1A-SS-03

TCL SVOCs (mg/Kg)

Acenaphthene 0.76 J 10 D 74 500 b

Acenaphthylene 0.88 J 26 D 300 D 500 b

Anthracene 1.7 J 15 D 110 500 b

Benzo (a) anthracene 8.9 5.1 69 5.6

Benzo (b) fluoranthene 15 4.3 46 5.6

Benzo (k) fluoranthene 5 J 1.5 12 56

Benzo (g,h,i) perylene 9.2 1.8 18 500 b

Benzo (a) pyrene 12 4.2 51 1f

Bis(2-ethylhexyl) phthalate ND 0.2 ND -

Chrysene 9.8 4.2 50 56

Dibenzo (a,h) anthracene 2.3 0.52 5.3 0.56

Dibenzofuran 0.51 J 2.8 34 -

Di-n-octyl phthalate 2 B 0.21 B ND -

Fluoranthene 13 16 D 110 500 b

Fluorene 0.56 J 16 D 170 D 500 b

Indeno (1,2,3-cd) pyrene 7.8 1.5 16 5.6

2 - Methylnaphthalene 0.53 J 61 D 800 D -

Naphthalene 11 J 110 D 1500 D 500 b

N-nitrosodiphenylamine ND ND 2.9 J -

Phenanthrene 6.1 48 D 480 D 500 b

Pyrene 11 22 D 110 J 500 b

TCL PCBs (mg/Kg)

Aroclor 1016 ND ND ND 1





Aroclor 1254 0.17 J ND ND 1

Aroclor 1260 ND 0.24 J 0.37 1

Metals (mg/Kg)

Arsenic 8.6 54.6 13.8 16 f

Barium 63.8 6630 80.4 400

Cadmium 1.6 6.3 3.4 9.3

Chromium 56.2 130 207 1500

Lead 676 373 1090 1000

Mercury 2.2 0.24 0.73 2.8 j

Silver ND 0.78 ND 1500

Notes:

1. Only those parameters detected at a min. of one sample location are presented in this table; all other compounds were reported as non-detect.

Definitions:

J = Estimated value; result is less than the sample quantitation limit but greater than zero.

B = Analyte is found in associated blank, as well as in the sample .

D = Identified in an analysis at the secondary dilution factor.

ND = parameter was analyzed for, but not detected

b = The SCOs for commercial use were capped at a maximum value of 500 ppm.

f = For constituents where the calculated SCO was lower than the rural soil background concentration as determined by the DEC/DOH

rural soil survey, the rural soil background concentration is used as the Track 2 SCO value for this site.

j = This SCO is lower of the values for mercury (elemental) or mercury (inorganic salts).

BOLD = Result exceeds Part 375 Commercial SCO.

Parameter1 Part 375

Commercial SCOs

ELECTRICAL TRANSFORMER INVENTORY AND SAMPLING PROGRAM

Tecumseh Redevelopment Inc.Phase IA Business Park

Building & LocationTurnKey

I.D.Number

SerialNumber

(if legible or present)

Date Sampled Type of Sample Comments Total PCB

results

Pum

ped

Out

Rem

oved

BLOWING ENGINE HOUSE NO. 3 16 TRANSFORMERST-100 NA 7/20/2010 oil Wagner-15 ND 08/15/12 9/25/2012T-101 59L16627 7/20/2010 oil Westinghouse 14R 9.8T-102 59L16618 7/20/2010 oil Westinghouse 25 9.5

T-103 5K27555 7/20/2010 wipe Wagner-25 ( no oil inside, very dry-like new) wipe sample on outside of transformer ND Empty 9/28/2012

T-104 24CX480 7/20/2010 wipe Wagner-25 ( no oil inside, very dry-like new) wipe sample on outside of transformer ND Empty 9/28/2012

T-105 5S34088 7/20/2010 wipe Wagner- slight oily sheen inside transformer, sampled inside wall ND Empty 9/28/2012

T-106 59L16629 7/20/2010 oil Westinghouse - 1/3 full 9.7T-107 853677 7/20/2010 wipe ME- dry slight oil sheen , sampled inside wall of transformer ND Empty 1T-108 5P28426 7/20/2010 oil Wagner- top missing, covered with bag ND 08/15/12T-109 119236 7/20/2010 oil STD Transformer Company- 1/2 full ND 08/15/12 9/25/2012T-110 21090-6 7/20/2010 oil Pennsylvania Transformer NDT-111 NA 7/20/2010 oil "10 t" painted on side, grey, 2/3 full , 15 gal cap (found empty June 2012) ND Empty 9/28/2012T-112 5P28427 7/20/2010 wipe Wagner- tipped over , empty, no lid, sampled inside wall ND Empty 9/28/2012T-131 284890 7/22/2010 oil NDT-132 5P28369 7/22/2010 oil Wagner-10 NDT-133 5P28435 7/22/2010 oil ND

POWER HOUSE NO. 1 32 TRANSFORMERS; 2 OIL-FILLED CIRCUIT BREAKERST-113 21320-2 7/21/2010 oil orange 3.7T-114 5S26484 7/21/2010 oil < 1-inch oil at bottom of transformer NDT-115 5P28448 7/21/2010 oil 1/3 full NDT-116 820487 7/21/2010 oil Westinghouse NDT-117 296863 7/21/2010 oil <1-inch oil at bottom, lid cracked NDT-118 65AJ12802 7/21/2010 oil Westinghouse NDT-119 14507-2 7/21/2010 oil 4.8T-120 5L65399 7/21/2010 oil NDT-121 5K27377 7/21/2010 oil NDT-122 L5G1873 7/21/2010 oil NDT-123 L5G1859 7/21/2010 oil 2.4 1T-124 L5G1871 7/21/2010 oil 2.3 1

Above locker room on east wall. T-125 NA 7/21/2010 oil Wagner -10 ND 1T-126 5T45201 7/22/2010 oil Wagner -10 NDT-127 697749 7/22/2010 oil ND

Staged on floor 1/2 way inside building

Hanging on east wall above office

Inside, hanging on east wall, above corrugated roof partition.

Inside, staged on floor in north end of building

Hanging on east wall

lori

Typewritten Text

TABLE 2A

ELECTRICAL TRANSFORMER INVENTORY AND SAMPLING PROGRAM

Tecumseh Redevelopment Inc.Phase IA Business Park

Building & LocationTurnKey

I.D.Number

SerialNumber

(if legible or present)

Date Sampled Type of Sample Comments Total PCB

results

Pum

ped

Out

Rem

oved

POWER HOUSE NO. 1 (CONTINUED) 32 TRANSFORMERS; 2 OIL-FILLED CIRCUIT BREAKERST-128 90792 7/22/2010 oil NDT-129 90791 7/22/2010 oil NDT-130 90793 7/22/2010 oil NDT-135 L5G1869 7/22/2010 oil 18T-136 L5G1854 7/22/2010 oil NDT-137 L5G1861 7/22/2010 oil 10

Inside, northwest corner of building, above partition T-138 283816 7/22/2010 oil NDT-139 65AK11270 7/23/2010 oil ND 1T-140 21517-11 7/23/2010 oil 2.2 1T-141 403591 7/23/2010 oil ND 1T-142 417982 7/23/2010 oil ND 1T-143 12904 7/23/2010 oil NDT-144 NA 7/23/2010 oil NDT-145 NA 7/26/2010 oil NDT-146 NA 7/26/2010 oil NDT-147 67AJ6503 7/26/2010 oil NDT-148 74AK18933 7/26/2010 oil NDC-1 NA 7/26/2010 wipe ND

C-2 NA 7/26/2010 oil ND

STEAM STATION NO. 1 / BOILER HOUSE NO. 3 1 TRANSFORMER

Notes:NA = Serial number not present or illegible.

Color Codes:Disposed off-site

Outside, hanging on east wall, approx 150 north of south east building corner oil clear oil in transformerT-134 74AK18934

Oil filled Westinghouse circuit breakers. Could not obtain oil from C-1; therefore, collected wipe sample from oil inside glass site tube plug

7/22/2010

Hanging inside half way along east wall of building

Hanging on east wall, south of office partition

Hanging inside half way along east wall of building

Hanging on wall, south west corner of building

Center of building, near control panels

Hanging inside half way along east wall of building, above man door

ND

Hanging on east wall, south of office partition

lori

Typewritten Text

TABLE 2A

TABLE 2B

SUMMARY OF FLOOR WIPE AND FLOOR/SOIL SAMPLING PROGRAM

RI/AA Report



Building & Location

TurnKey

I.D.

Number

Date

Sampled

Type of

Sample Comments

Floor Wipe/Soil Fill Samples

Wipe sample of corrugated roof below T-118 transformer T-118 Wipe 7/21/2010 wipe Staining below transformer observed

Floor of C-1 circuit breaker C-1 Floor Wipe 7/26/2010 wipe Wipe obtained below circuit breaker

Floor of C-2 circuit breaker C-2 Floor Wipe 7/26/2010 wipe Wipe obtained below circuit breaker

Wipe sample of floor approx 12 ft north of T-118 Transformer T-118 "North" Wipe 7/23/2010 wipe Sample collected as requested by NYSDEC

Floor wipe sample below Transformers T-128 through T-130 T-128-T-130 Floor Wipe 7/27/2010 wipe Sample collected as requested by NYSDEC




Floor/soil sample collected from Power House No. 1, center of

floor approx. 50 ft south of northwest overhead door

Power House Floor/Soil

Sample7/27/2010 soil/fill

Some oil staining observed, sample collected as requested by

NYSDEC

Floor/soil sample collected from Blowing Engine House No. 3

in area of staged Transformers T-100 through T-112

T-100-T-112 Floor/Soil

Sample7/27/2010 soil/fill

Oil staining on floor/soil observed in area of T-100 through T-112

transformers

TABLE 3

SUMMARY OF PHASE IA SITE MONITORING WELLS

RI/AA Report



top bottom top bottom

MWN-69A x 1027989.406 1075706.095 579.20 3.00 582.20 06/22/10Earth

Dimensions14.00 575.20 565.20 10 4.00 14.00 2 PVC/PVC 0.010 F Phase IA BPA well

MWN-70A x 1028982.583 1075187.427 580.08 3.00 583.08 06/22/10Earth


MWN-71A x 1030534.107 1074895.148 579.52 3.00 582.52 06/23/10Earth


B-1 x 1028890.730 1075210.270 581.76 2.55 584.31 02/08/91 Empire 15.92 575.84 565.84 10 5.92 15.92 2.5/2 PVC/PVC 0.010 F DESTROYED; Phase IA BCP well

B-2 x 1028983.349 1075449.540 583.54 2.06 585.60 02/11/91 Empire 16.00 577.54 567.54 10 6.00 16.00 2.5/2 PVC/PVC 0.010 F Phase IA BCP well

B-3 x 1029592.090 1074984.960 584.12 2.42 586.54 02/12/91 Empire 15.17 578.95 568.95 10 5.17 15.17 2.5/2 PVC/PVC 0.010 F DESTROYED

P-45S x 1029704.342 1075252.995 583.26 2.47 585.73 01/18/01 SJB 11.00 580.26 572.26 8 3.00 11.00 0.75 PVC/PVC 0.010 F Phase IA BCP WL well

MW-16A x 1029329.225 1075321.464 583.42 2.54 585.96 01/29/06 ED 14.24 579.18 569.18 10 4.24 14.24 2 PVC/PVC 0.010 F Phase I BPA BCP well / Phase IA BCP well

ES1-2 x 1030715.835 1074724.866 583.37 1.71 585.08 08/10/90 Empire 18.00 575.37 565.37 10 8.00 18.00 2 PVC/PVC 0.010 F DESTROYED

Stratigraphic Unit: Drilling Contractor: Notes: Color Scheme:F - Fill Empire - Empire Soils Inveigations, Inc. NA - Not Available/Applicable

SJB - SJB Services, Inc. PT - Porous Teflon = Destroyed Well Location

ED - Earth Dimensions, Inc. SS - Stainless Steel

TBD - To Be Determined

Well I.D. Northing Easting

Ground

Elev.

(fmsl)

Stick-up

(feet)

Mo

nit

ori

ng

Well

Pie

zo

mete

rRemarks

Riser /

Screen

Material

Screened Interval

(fbgs)

Screened Interval

(fmsl)TOR

Elev.

(fmsl)

Install

Date

Screen

Length

(feet)

Contractor

Total

Depth

(fbgs)

Riser /

Screen

Diam.

(in.)

Screen

Slot

Size

(in.)

Stratigraphic

Unit

Monitoring

TABLE 4

SUMMARY OF GROUNDWATER ELEVATIONS

RI/AA ReportPhase IA Business Park Area - Brownfield Cleanup Program


DTW 2

(fbTOR)GWE 1

(fmsl)DTW 2

(fbTOR)GWE 1

(fmsl)DTW 2

(fbTOR)GWE 1

(fmsl)DTW 2

(fbTOR)GWE 1

(fmsl)Phase IA Monitoring Wells

B-2 3 586.60 8.38 578.22 8.66 577.94 Decommissioned

MW-14A 586.30 NM NM 6.43 579.87 5.35 580.95 5.51 580.79

MW-15A 586.22 NM NM 6.04 580.18 4.86 581.36 4.21 582.01

MW-16A 3 585.96 7.81 578.15 7.79 578.17 Decommissioned

MW-17A 584.93 NM NM 6.97 577.96 6.44 578.49 6.51 578.42

MWN-64A 584.83 NM NM 8.30 576.53 7.90 576.93 7.82 577.01

MWN-69A 583.77 7.13 576.64 7.43 576.34 7.26 576.51 7.24 576.53

MWN-70A 584.97 9.15 575.82 9.26 575.71 8.90 576.07 8.61 576.36

MWN-71A 586.12 9.62 576.50 10.06 576.06 Damaged

Phase IA Piezometers

P-45S 3 585.73 6.77 578.96 6.93 578.80 Decommissioned

Notes:1. Top of Riser (TOR) elevation and Groundwater Elevation (GWE) are measured in feet; distance above mean sea level (fmsl).2. fbTOR = feet below top of riser or casing3. Monitoring well MW-16A and piezometers B-2 and P-45S were decommissioned on September 25, 2012 prior to the railroad relocation project.4. fmsl = feet above mean sea level.5. NM = not measured.

05/07/2014TORElevation 1

(fmsl)Location

02/23/201602/08/201106/30/2010

REV Table 4; Summary of Groundwater Elevations.xlsx

TABLE 5A

SUMMARY OF SURFACE SOIL ANALYTICAL DATA COMPARED TO UNRESTRICTED USE SCOs

RI/AA Report



April 2007 Sampling Event 3 June 2010 Sampling Event

SS-01 SS-02 SS-03 SS-04 Q4 SS-05 SS-06 SS-07 Q SS-08 Q SS-09 SS-10 SS-11 SS-12 SS-13 Q SS-14 SS-15 Q

Volatile Organic Compounds (VOCs) - mg/kg1,2,4-Trimethylbenzene 3.6 -- -- -- -- -- -- -- -- -- -- -- -- 0.0067 -- --Methylene Chloride 0.05 -- -- -- -- -- -- -- -- -- -- -- -- 0.0026 J -- --TOTAL VOCs (mg/kg) -- -- -- -- -- -- -- -- -- -- -- -- -- 0.0093 -- --

Base-Neutral Semi-Volatile Organic Compounds (SVOCs) - mg/kgAcenaphthylene 100 0.88 J 26 D 300 D -- -- -- -- -- -- -- 1.4 DJ -- -- -- --Anthracene 100 1.7 J 15 D 110 -- -- -- -- -- -- -- 1.5 DJ -- -- -- --Benzo(a)anthracene 1 8.9 5.1 69 -- -- -- -- -- -- -- 8.1 D -- -- -- --Benzo(b)fluoranthene 1 15 4.3 46 -- -- -- -- -- -- -- 11 D -- -- -- --Benzo(k)fluoranthene 0.8 5 J 1.5 12 -- -- -- -- -- -- -- 4.5 DJ -- -- -- --Benzo(g,h,i)perylene 100 9.2 1.8 18 -- -- -- -- -- -- -- 6 D -- -- -- --Benzo(a)pyrene 1 12 4.2 51 -- -- -- -- -- -- -- 6.1 D -- -- -- --Chrysene 1 9.8 4.2 50 -- -- -- -- -- -- -- 14 D -- -- -- --Dibenzo(a,h)anthracene 0.33 2.3 0.52 5.3 -- -- -- -- -- -- -- 1.8 DJ -- -- -- --Fluoranthene 100 13 16 D 110 -- -- -- -- -- -- -- 19 D -- -- -- --Indeno(1,2,3-cd)pyrene 0.5 7.8 1.5 16 -- -- -- -- -- -- -- 4.4 DJ -- -- -- --Phenanthrene 100 6.1 48 D 480 D -- -- -- -- -- -- -- 2.9 DJ -- -- -- --Pyrene 100 11 22 D 110 J -- -- -- -- -- -- -- 20 D -- -- -- --TOTAL SVOCs (mg/kg) -- 114 260 2877 -- -- -- -- -- -- -- 101 -- -- -- --

Polychlorinated Biphenyls (PCBs) - mg/kgAroclor 1248 -- ND ND ND ND ND ND 0.019 QSU, J J ND -- -- -- ND ND ND 0.1 QSU, D, J NJAroclor 1254 -- 0.17 J ND ND 0.06 QSU,D,J NJ 0.06 QSU,D,J 0.11 D,QSU 0.047 QSU, J J 0.16 D,QSU -- -- -- 0.025 QSU 0.61 D,QSU 0.13 QSU,D,J 0.15 QSU, D, J JAroclor 1260 -- ND 0.24 J 0.37 ND ND ND 0.045 QSU, J J 0.06 QSU, D, J NJ -- -- -- 0.011 QSU, J ND ND 0.34 QSU, D, J JTOTAL PCBs (mg/kg) 0.1 0.17 0.24 0.37 0.055 0.064 0.11 0.111 0.217 -- -- -- 0.036 0.61 0.13 0.59

Inorganic Compounds - mg/kgAluminum -- -- -- -- -- -- -- -- -- ND ND ND -- 5310 J -- 5930Arsenic, Total 13 8.6 54.6 13.8 -- -- -- -- -- 158 87.6 82.6 -- 4.7 -- 5Barium, Total 350 63.8 6630 80.4 -- -- -- -- -- ND ND ND -- 55.2 -- 59.4Beryllium 7.2 -- -- -- -- -- -- -- -- ND ND ND -- 0.725 -- 0.823Cadmium, Total 2.5 1.6 6.3 3.4 -- -- -- -- -- 56.2 29.2 246 -- 1.22 -- 0.842Calcium -- -- -- -- -- -- -- -- -- ND ND ND -- 153000 D -- 177000 DChromium, Total 1 56.2 130 207 -- -- -- -- -- 401 221 237 -- 381 -- 430Cobalt -- -- -- -- -- -- -- -- -- ND ND ND -- 3.85 -- 3.7Copper 50 -- -- -- -- -- -- -- -- ND ND ND -- 46.8 -- 33.4Iron -- -- -- -- -- -- -- -- -- ND ND ND -- 88200 D -- 106000 DLead, Total 63 676 373 1090 -- -- -- -- -- 8050 7840 6630 -- 80.1 -- 53.6Magnesium -- -- -- -- -- -- -- -- -- ND ND ND -- 16700 -- 18900Manganese 1600 -- -- -- -- -- -- -- -- ND ND ND -- 17300 D -- 16000 DMercury, Total 0.18 2.2 0.24 0.73 -- -- -- -- -- 280 D 320 D 216 D -- 0.388 -- 0.249Nickel 30 -- -- -- -- -- -- -- -- ND ND ND -- 16.6 -- 14.4

Potassium -- -- -- -- -- -- -- -- -- ND ND ND -- 363 -- 263

Vanadium -- -- -- -- -- -- -- -- -- ND ND ND -- 300 -- 336

Zinc 109 -- -- -- -- -- -- -- -- ND ND ND -- 220 -- 280

Notes:

1. Only those parameters detected at a minimum of one sample location are presented in this table; all other compounds were reported as non-detect.

2. SCO = Soil Cleanup Objective (Protection of Public Health - Unrestricted), per NYSDEC 6NYCRR Part 375-6.8(b), Final December 2006.

3. Additional SVOCs were detected but at concentrations well below unrestricted use. Samples only analyzed for RCRA Metals.

4. Data qualifiers per third-party Data Usability Summary Report (DUSR)

Acronyms:

ND = Parameter not detected above laboratory detection limit.

" -- " = not analyzed for this parameter or no individual SCO

BOLD = Value exceeds Unrestricted Use SCO

Laboratory Qualifiers (located next to the sample result):

J = Analyte was detected at a level less than the Reporting Limit (RL) and greater than or equal to the Method Detection Limit (MDL). Concentrations within this range are estimated.

D = Dilution required.

ID4 = Benzo(b)fluoranthene coelutes with Benzo(k)fluoranthene. The reported result is a summation of the isomers and the concentration is based on the response factor of Benzo(b)fluoranthene.

B = Analyte was detected in associated Method Blank.

QSU = Sulfur (EPA 3660) clean-up performed on extract.

W1 = Sample was prepared and analyzed utilizing a medium level extraction.

Data Validation Qualifiers (under separate column "Q"):

J = The analyte was positively identified; the associated numerical value is an approximate concentration of the analyte in the sample.

NJ = The detection is tentative in identification and estimated in value. Although there is presumptive evidence of the analyte, the result should be used with caution as a potential false positive and/or elevated quantitative value.

Parameter 1

Unrestricted

SCO

(mg/kg) 2

TABLE 5B

SUMMARY OF SURFACE SOIL ANALYTICAL DATA COMPARED TO RESTRICTED COMMERCIAL SCOs

RI/AA Report



April 2007 Sampling Event 3

SS-01 SS-02 SS-03 SS-04 Q4 SS-05 SS-06 SS-07 Q SS-08 Q SS-09 SS-10 SS-11 SS-12 SS-13 Q SS-14 SS-15 Q

Volatile Organic Compounds (VOCs) - mg/kg

1,2,4-Trimethylbenzene 190 -- -- -- -- -- -- -- -- -- -- -- -- 0.0067 -- --

Methylene Chloride 500 -- -- -- -- -- -- -- -- -- -- -- -- 0.0026 J -- --TOTAL VOCs (mg/kg) -- -- -- -- -- -- -- -- -- -- -- -- -- 0.0093 -- --

Base-Neutral Semi-Volatile Organic Compounds (SVOCs) - mg/kgAcenaphthylene 500 0.88 J 26 D 300 D -- -- -- -- -- -- -- 1.4 DJ -- -- -- --Anthracene 500 1.7 J 15 D 110 -- -- -- -- -- -- -- 1.5 DJ -- -- -- --Benzo(a)anthracene 5.6 8.9 5.1 69 -- -- -- -- -- -- -- 8.1 D -- -- -- --Benzo(b)fluoranthene 5.6 15 4.3 46 -- -- -- -- -- -- -- 11 D -- -- -- --Benzo(k)fluoranthene 56 5 J 1.5 12 -- -- -- -- -- -- -- 4.5 DJ -- -- -- --Benzo(g,h,i)perylene 500 9.2 1.8 18 -- -- -- -- -- -- -- 6 D -- -- -- --Benzo(a)pyrene 1 12 4.2 51 -- -- -- -- -- -- -- 6.1 D -- -- -- --Chrysene 56 9.8 4.2 50 -- -- -- -- -- -- -- 14 D -- -- -- --Dibenzo(a,h)anthracene 0.56 2.3 0.52 5.3 -- -- -- -- -- -- -- 1.8 DJ -- -- -- --Fluoranthene 500 13 16 D 110 -- -- -- -- -- -- -- 19 D -- -- -- --Indeno(1,2,3-cd)pyrene 5.6 7.8 1.5 16 -- -- -- -- -- -- -- 4.4 DJ -- -- -- --Naphthalene 500 11 J 110 D 1500 D -- -- -- -- -- -- -- ND -- -- -- --Phenanthrene 500 6.1 48 D 480 D -- -- -- -- -- -- -- 2.9 DJ -- -- -- --Pyrene 500 11 22 D 110 J -- -- -- -- -- -- -- 20 D -- -- -- --TOTAL SVOCs (mg/kg) -- 114 260 2877 -- -- -- -- -- -- -- 101 -- -- -- --

Polychlorinated Biphenyls (PCBs) - mg/kgAroclor 1248 -- ND ND ND ND ND ND 0.019 QSU, J J ND -- -- -- ND ND ND 0.1 QSU, D, J NJAroclor 1254 -- 0.17 J ND ND 0.06 QSU,D,J NJ 0.06 QSU,D,J 0.11 D,QSU 0.047 QSU, J J 0.16 D,QSU -- -- -- 0.025 QSU 0.61 D,QSU 0.13 QSU,D,J 0.2 QSU, D, J JAroclor 1260 -- ND 0.24 J 0.37 ND ND ND 0.045 QSU, J J 0.057 D,QSU NJ -- -- -- 0.011 QSU, J ND ND 0.3 QSU, D, J JTOTAL PCBs (mg/kg) 1 0.17 0.24 0.37 0.055 0.064 0.11 0.11 0.22 -- -- -- 0.036 0.61 0.13 0.59

Inorganic Compounds - mg/kgAluminum -- -- -- -- -- -- -- -- -- ND ND ND -- 5310 J -- 5930Arsenic, Total 16 8.6 54.6 13.8 -- -- -- -- -- 158 87.6 82.6 -- 4.7 -- 5Barium, Total 400 63.8 6630 80.4 -- -- -- -- -- ND ND ND -- 55.2 -- 59.4Beryllium 590 -- -- -- -- -- -- -- -- ND ND ND -- 0.725 -- 0.823Cadmium, Total 9.3 1.6 6.3 3.4 -- -- -- -- -- 56.2 29.2 246 -- 1.22 -- 0.842Calcium -- -- -- -- -- -- -- -- -- ND ND ND -- 153000 D -- 177000 DChromium, Total 1,500 56.2 130 207 -- -- -- -- -- 401 221 237 -- 381 -- 430Cobalt -- -- -- -- -- -- -- -- -- ND ND ND -- 3.85 -- 3.7Copper 270 -- -- -- -- -- -- -- -- ND ND ND -- 46.8 -- 33.4Iron -- -- -- -- -- -- -- -- -- ND ND ND -- 88200 D -- 106000 DLead, Total 1,000 676 373 1090 -- -- -- -- -- 8050 7840 6630 -- 80.1 -- 53.6Magnesium -- -- -- -- -- -- -- -- -- ND ND ND -- 16700 -- 18900Manganese 10,000 -- -- -- -- -- -- -- -- ND ND ND -- 17300 -- 16000 DMercury, Total 2.8 2.2 0.24 0.73 -- -- -- -- -- 280 D 320 D 216 D -- 0.388 -- 0.249Nickel 310 -- -- -- -- -- -- -- -- ND ND ND -- 16.6 -- 14.4Potassium -- -- -- -- -- -- -- -- -- ND ND ND -- 363 -- 263Vanadium -- -- -- -- -- -- -- -- -- ND ND ND -- 300 -- 336Zinc 10,000 -- -- -- -- -- -- -- -- ND ND ND -- 220 -- 280

Notes:


2. SCO = Soil Cleanup Objective (Protection of Public Health - Commercial), per NYSDEC 6NYCRR Part 375-6.8(b), Final December 2006.

3. Additional SVOCs were detected but at concentrations well below restricted-commercial SCOs. Samples only analyzed for RCRA Metals.


Acronyms:



BOLD = Value exceeds Restricted-Commercial SCO







NJ = The detection is tentative in identification and estimated in value. Although there is presumptive evidence of the analyte, the result should be used with caution as a potential false positive and/or elevated quantitative value.

Parameter 1

June 2010 Sampling EventRestricted-

Commercial SCO

(mg/kg) 2

TABLE 6A

SUMMARY OF SUBSURFACE SOIL ANALYTICAL DATA COMPARED TO UNRESTRICTED USE SCOs

RI/AA Report



0.5-3.0 Q3 0.5-3.5 Q 0.5-2.5 Q 0.5-4.5 Q 0.5-6.0 Q 0.5-6.0 Q 0.5-5.5 Q 0.5-5.5 Q 1.0-5.5 Q 1.0-5.5 Q 0.0-2.0 Q 0.5-3.0 Q 0.5-6.0 Q 0.5-4.0 Q 0.5-6.0 Q 0.5-6.5 Q 0.5-5.5 Q 0.5-7.5 Q

Volatile Organic Compounds (VOCs) - mg/kgAcetone 0.05 -- -- -- -- 0.0055 J -- -- -- ND ND ND -- -- -- -- -- -- --Benzene 0.06 -- -- -- -- ND -- -- -- ND ND ND ND 0.01 J -- -- ND -- --1,1-Dichloroethane -- -- -- -- -- ND -- -- -- 0.077 W1,J J 0.22 W1,J J ND -- -- -- -- -- -- --Ethylbenzene 1 -- -- -- -- ND -- -- -- ND J 0.23 W1,J J 0.056 W1,J ND 0.023 -- -- ND -- --n-Butylbenzene 12 -- -- -- -- ND -- -- -- ND J ND ND 1.5 D 0.04 -- -- ND -- --sec-Butylbenzene 11 -- -- -- -- ND -- -- -- 0.085 W1,J J 0.44 W1,J J ND ND ND -- -- ND -- --Isopropylbenzene -- -- -- -- -- ND -- -- -- ND J 0.13 W1,J J ND ND 0.0076 J -- -- 0.0059 J -- --p-Cymene -- -- -- -- -- ND -- -- -- 0.12 W1 J 0.65 W1,J J ND ND ND -- -- ND -- --n-Propylbenzene 3.9 -- -- -- -- ND -- -- -- ND J 0.22 W1,J J ND ND ND -- -- 0.002 J -- --Styrene -- -- -- -- -- ND -- -- -- ND ND 0.23 W1 -- -- -- -- -- -- --Toluene 0.7 -- -- -- -- ND -- -- -- ND J 0.13 W1,J J 0.24 W1 2.5 D 0.056 -- -- 0.025 -- --1,1,1-Trichloroethane -- -- -- -- -- ND -- -- -- 0.13 W1 J 0.15 W1,J J ND -- -- -- -- -- -- --Trichloroethene -- -- -- -- -- ND -- -- -- 0.34 W1 J 0.36 W1,J J 1.8 W1 -- -- -- -- -- -- --1,2,4-Trimethylbenzene 3.6 -- -- -- -- ND -- -- -- 0.79 W1 J 5.7 W1,J J 0.85 W1 8.1 D 0.057 -- -- 0.041 -- --1,3,5-Trimethylbenzene 8.4 -- -- -- -- ND -- -- -- 0.29 W1 J 1.9 W1,J J 0.36 W1 4 D 0.018 -- -- 0.012 -- --o-Xylene 0.26 -- -- -- -- ND -- -- -- 0.18 W1 J 1.3 W1,J J 0.33 W1 3.1 D 0.047 -- -- 0.035 -- --m-Xylene 0.26 -- -- -- -- ND -- -- -- 0.13 W1,J J 1.1 W1,J J 0.69 W1 -- -- -- -- -- -- --Xylenes, Total -- -- -- -- -- ND -- -- -- 0.3 W1 J 2.4 W1,J J 1 W1 11 D 0.14 -- -- 0.08 -- --Naphthalene -- -- -- -- -- -- -- -- -- -- -- -- 260 BD 0.85 B -- -- 0.2 B -- --Methylcyclohexane -- -- -- -- -- ND -- -- -- ND J 0.26 W1,J J 0.14 W1 -- -- -- -- -- -- --Methyl tert butyl ether 0.93 -- -- -- -- ND -- -- -- ND ND ND ND 0.021 -- -- ND -- --Methylene Chloride 0.05 -- -- -- -- 0.0067 -- -- -- ND ND ND ND -- -- -- -- -- --TOTAL VOCs (mg/kg) -- -- -- -- -- 0.0122 -- -- -- 2.14 12.79 4.70 279 1.13 -- -- 0.321 -- --

Base-Neutral Semi-Volatile Organic Compounds (SVOCs) - mg/kgAcenaphthene 20 ND ND ND ND ND ND 9.2 DJ ND 1.1 DJ J 1.8 DJ J 1.2 DJ 6.5 DJ 6.6 DJ 0.11 DJ ND ND 0.14 DJ NDAcenaphthylene 100 0.081 DJ 0.35 DJ ND 0.31 DJ ND 0.16 J 18 DJ ND 1 DJ J 2.4 DJ J 7.2 D 47 D 57 D 0.74 DJ 0.34 DJ 0.48 DJ 0.43 DJ 0.098 DJAnthracene 100 0.046 DJ 0.28 DJ ND 0.31 DJ 0.2 DJ 0.026 J 48 D 0.065 DJ 1.7 DJ J 2.7 DJ J 8.4 D 47 D 76 D 0.7 DJ 0.39 DJ 0.29 DJ 0.42 DJ 0.11 DJBenzo(a)anthracene 1 0.44 DJ 1.9 D 0.19 DJ 1.5 DJ 1.4 DJ 0.18 J 77 D 0.41 DJ 4.2 DJ J 22 DJ J 13 D 66 D 170 D 3.7 D 1.6 D 2.2 D 2.3 D 0.76 DJBenzo(b)fluoranthene 1 0.74 DJ 2.4 D 0.23 DJ 1.6 D,ID4,J 1.6 DJ 0.36 75 D 0.48 DJ 7.2 DJ J 22 DJ J 11 D 60 D 150 D 5.2 D 2 D 3 D 3.3 D 1.1 DJBenzo(k)fluoranthene 0.8 0.22 DJ 2.7 D 0.065 DJ ND 0.58 DJ 0.13 J 83 D 0.31 DJ 8 DJ J 24 DJ J 12 D 67 D 170 D 1.8 D 0.67 DJ 1.1 D 1 DJ 0.54 DJBenzo(g,h,i)perylene 100 0.32 DJ 0.55 DJ 0.09 DJ 0.4 DJ 1.4 DJ 0.32 18 DJ 0.45 DJ 3 DJ J 6.5 DJ J 2.9 DJ 15 DJ 31 D 3.4 D 1.4 D 1.9 D 1.9 DJ 0.8 DJBenzo(a)pyrene 1 0.56 DJ 1.4 DJ 0.17 DJ 1.1 DJ 1.4 DJ 0.32 50 D 0.44 DJ 5.3 DJ J 15 DJ J 8.3 D 41 D 110 D 4.2 D 1.7 D 2.6 D 2.5 D 0.91 DJBenzyl alcohol -- ND ND ND ND ND ND ND ND ND ND 0.39 DJ ND ND ND ND ND ND NDChrysene 1 0.47 DJ 1.9 D 0.17 DJ 1.4 DJ 1.7 DJ 0.21 71 D 0.65 DJ 4.4 DJ J 20 DJ J 12 D 61 D 140 D 3.4 D 1.4 D 2 2 D 0.87 DJ2-Chloronaphthalene -- ND ND ND ND ND ND ND ND ND ND 0.25 DJ ND ND ND ND ND ND ND4-Chloroaniline -- ND ND ND ND ND ND 13 DJ ND ND ND 9.1 D 61 D ND ND ND ND ND NDDibenzo(a,h)anthracene 0.33 ND 0.2 DJ ND 0.13 DJ 0.34 DJ 0.075 J 7.4 DJ 0.14 DJ ND ND 1 DJ 5.4 DJ 13 DJ ND ND 0.57 DJ ND 0.21 DJDibenzofuran -- ND ND ND ND ND 0.034 J 30 DJ ND ND ND 6.8 D 40 D 19 DJ 0.14 DJ 0.1 DJ 0.067 DJ 0.17 DJ ND2,4-Dichlorophenol -- ND ND ND ND ND ND ND ND 6.8 DJ J 4.2 DJ J ND ND ND ND ND ND ND NDDi-n-octyl phthalate -- ND ND ND ND ND ND ND ND ND ND ND ND 0.85 DJ ND ND ND ND NDFluoranthene 100 0.52 DJ 2.4 D 0.28 DJ 2.8 D 2 DJ 0.14 J 170 D 0.57 DJ 4.4 DJ J 19 DJ J 25 D 120 D 330 D 6.6 D 3.2 D 2.8 D 3.1 D 1.2 DJFluorene 30 ND ND ND 0.093 DJ ND ND 61 D ND ND J 1.3 DJ J 10 D 55 D 46 D 1.6 DJ 0.076 DJ ND 0.19 DJ NDIndeno(1,2,3-cd)pyrene 0.5 0.29 DJ 0.52 DJ 0.083 DJ 0.4 DJ 1 DJ 0.28 19 DJ 0.41 DJ ND J 5 DJ J 2.3 DJ 14 DJ 31 D 2.8 DJ 1.1 D 1.7 D 1.7 DJ 0.66 DJ2-Methylnaphthalene -- ND 0.084 DJ 0.037 DJ ND ND 0.082 J 21 DJ ND ND ND 11 D 77 D ND 0.1 DJ 0.037 DJ 0.091 DJ 0.15 DJ NDNaphthalene 12 ND 0.11 DJ ND 0.16 DJ ND 0.069 J 41 D ND ND ND 29 D 200 D 6.5 DJ 0.31 DJ 0.1 DJ 0.12 DJ 0.32 DJ 0.11 DJ4-Nitrophenol -- ND ND ND ND ND ND ND ND 25 DJ J 41 DJ J ND ND ND ND ND ND ND NDN-Nitrosodiphenylamine -- ND ND ND ND ND ND ND ND 1.2 DJ J ND J 0.54 DJ 1.6 DJ ND ND ND ND ND NDPhenanthrene 100 0.14 DJ 0.39 DJ 0.16 DJ 1.2 DJ 0.98 DJ 0.1 J 250 D 0.3 DJ 3.9 DJ J 6.1 DJ J 31 D 170 D 240 D 2.6 D 1.9 D 1.1 D 1.5 DJ 0.49 DJPyrene 100 0.55 DJ 2.3 D 0.24 DJ 2.6 D 2.2 D 0.14 J 130 D 0.62 DJ 5.2 DJ J 22 DJ J 22 D 100 D 240 D 5.6 D 2.6 D 2.3 D 2.8 D 1.1 DJTOTAL SVOCs (mg/kg) -- 4.38 17.5 1.72 14.0 14.8 2.63 1,192 4.85 82.4 215 224 1,255 1,837 43 18.6 22.3 23.9 8.96

Polychlorinated Biphenyls (PCBs) - mg/kgAroclor 1260 -- ND ND ND ND 0.22 D,QSU ND ND ND ND ND ND ND ND 0.03 0.027 ND ND NDTOTAL PCBs (mg/kg) 0.1 0 0 0 0 0.22 0 0 0 0 0 0 0 0 0.03 0.027 0 0 0

Inorganic Compounds - mg/kgAluminum -- ND ND ND ND 14900 J ND ND ND 2990 J 8590 J J ND ND ND ND ND ND ND NDArsenic, Total 13 ND 120 ND 17.8 J 36.3 14.7 31.9 15.2 14.6 J 34.3 J J 20.6 25.6 30.5 18.7 21.3 30.8 17.4 12.9Barium, Total 350 ND ND ND ND 155 J ND ND ND 72.3 J 92.4 J J ND ND ND ND ND ND ND NDBeryllium 7.2 ND ND ND ND 2.49 ND ND ND 0.577 J 1.29 J J ND ND ND ND ND ND ND ND

Cadmium, Total 2.5 ND 1.1 ND 1.12 J 1.68 0.75 2.35 6.86 0.679 J 1.61 J J 1.26 7.49 8.99 2.47 1.26 2.54 3.55 5.3

Calcium -- ND ND ND ND 134000 D J ND ND ND 8130 J 16000 J J ND ND ND ND ND ND ND ND

Chromium, Total 1 7.96 J 25.2 J 6.88 J 32 J J 26.2 J 8.28 J 58.9 J 164 J 28.8 J 43 J J 49.5 J 71.2 J 64.2 J 76.4 J 75.8 J 97.4 J 55.4 J 114 J

Cobalt -- ND ND ND ND 5.78 ND ND ND 4.95 J 7.59 J J ND ND ND ND ND ND ND ND

Copper 50 ND ND ND ND 57.9 ND ND ND 31.2 J 113 J J ND ND ND ND ND ND ND ND

Iron -- ND ND ND ND 118000 D ND ND ND 31800 J 70800 J J ND ND ND ND ND ND ND ND

Lead, Total 63 21.3 J 111 J 12.6 J 91.1 J J 180 44.8 J 258 J 542 J 46.4 j 131 J J 825 J 496 J 775 J 434 J 2530 J 531 J 351 J 454 J

Magnesium -- ND ND ND ND 31700 ND ND ND 1360 J 5400 J J ND ND ND ND ND ND ND ND

Manganese 1600 ND ND ND ND 3580 BD ND ND ND 1230 J 1480 J J ND ND ND ND ND ND ND ND

Mercury, Total 0.18 0.0658 0.141 ND 0.245 J 0.467 0.11 D 0.925 D 6.05 D 0.286 J 0.356 J J 17.7 D 13.6 D 30.5 D 1.47 D 1.5 D 0.261 0.587 0.292

Nickel 30 ND ND ND ND 12.2 ND ND ND 10.6 J 20.9 J J ND ND ND ND ND ND ND ND

Sodium -- ND ND ND ND 495 ND ND ND ND ND ND ND ND ND ND ND ND ND

Cyanide, Total 27 ND ND ND ND 1.5 ND ND ND ND ND ND ND ND ND ND ND ND NDTCLP - mg/L

Trichloroethene 0.5 -- -- -- -- -- -- -- -- 0.0068 DJ -- -- -- -- -- -- -- -- --Barium, Total 100 -- -- -- -- -- -- -- -- 0.478 B1, B -- -- -- -- -- -- -- -- --

Cadmium, Total 1 -- -- -- -- -- -- -- -- 0.01 -- -- -- -- -- -- -- -- --

Chromium, Total 5 -- -- -- -- -- -- -- -- 0.0079 BT, B -- -- -- -- -- -- -- -- --

Lead, Total 5 -- -- -- -- -- -- -- -- 0.178 BT, B -- -- -- -- -- -- -- -- --

Flashpoint (0F) -- -- -- -- -- -- -- -- -- >176 -- -- -- -- -- -- -- -- --

Notes:

1. Only those parameters detected at a minimum of one sample location are presented in this table; all other compounds were reported as non-detect.2. SCO = Soil Cleanup Objective (Protection of Public Health - Unrestricted), per NYSDEC 6NYCRR Part 375-6.8(b), Final December 2006.3. Data qualifiers per third-party Data Usability Summary Report (DUSR)4. Blind duplicate of BP1A-TP-9.

Acronyms:



BOLD = Value exceeds Unrestricted SCO










BLIND 4 TP - 12TP - 8 TP - 9

Unrestricted SCO

(mg/kg) 2 TP - 16

Sample Location and Depth Interval (fbgs)

TP - 17TP - 13 TP - 14TP - 6 TP - 7Parameter 1 TP - 1 TP - 2 TP - 3 TP - 4 TP - 15TP - 11TP - 10TP - 5

TABLE 6B

SUMMARY OF SUBSURFACE SOIL ANALYTICAL DATA COMPARED TO RESTRICTED-COMMERICAL SCOs

RI/AA Report



0.5-3.0 Q3 0.5-3.5 Q 0.5-2.5 Q 0.5-4.5 Q 0.5-6.0 Q 0.5-6.0 Q 0.5-5.5 Q 0.5-5.5 Q 1.0-5.5 Q 1.0-5.5 Q 0.0-2.0 Q 0.5-3.0 Q 0.5-6.0 Q 0.5-4.0 Q 0.5-6.0 Q 0.5-6.5 Q 0.5-5.5 Q 0.5-7.5 Q

Volatile Organic Compounds (VOCs) - mg/kgAcetone 500 -- -- -- -- 0.0055 J -- -- -- ND ND ND -- ND -- -- -- -- --Benzene 44 -- -- -- -- ND -- -- -- ND ND ND ND 0.01 J -- -- ND -- --1,1-Dichloroethane -- -- -- -- -- ND -- -- -- 0.077 W1,J J 0.22 W1,J J ND -- ND -- -- -- -- --Ethylbenzene 390 -- -- -- -- ND -- -- -- ND J 0.23 W1,J J 0.056 W1,J ND 0.023 -- -- ND -- --n-Butylbenzene 500 -- -- -- -- ND -- -- -- ND J ND ND 1.5 D 0.04 -- -- ND -- --sec-Butylbenzene 500 -- -- -- -- ND -- -- -- 0.085 W1,J J 0.44 W1,J J ND ND ND -- -- ND -- --Isopropylbenzene -- -- -- -- -- ND -- -- -- ND J 0.13 W1,J J ND ND 0.0076 J -- -- 0.0059 J -- --p-Cymene -- -- -- -- -- ND -- -- -- 0.12 W1,J J 0.65 W1,J J ND ND ND -- -- ND -- --n-Propylbenzene 500 -- -- -- -- ND -- -- -- ND J 0.22 W1,J J ND ND ND -- -- 0.002 J -- --Styrene -- -- -- -- -- ND -- -- -- ND ND 0.23 W1 -- -- -- -- -- -- --Toluene 500 -- -- -- -- ND -- -- -- ND J 0.13 W1,J J 0.24 W1 2.5 D 0.056 -- -- 0.025 -- --1,1,1-Trichloroethane -- -- -- -- -- ND -- -- -- 0.13 W1,J J 0.15 W1,J J ND -- -- -- -- -- -- --Trichloroethene -- -- -- -- -- ND -- -- -- 0.34 W1,J J 0.36 W1,J J 1.8 W1 -- -- -- -- -- -- --1,2,4-Trimethylbenzene 190 -- -- -- -- ND -- -- -- 0.79 W1,J J 5.7 W1,J J 0.85 W1 8.1 D 0.057 -- -- 0.041 -- --1,3,5-Trimethylbenzene 190 -- -- -- -- ND -- -- -- 0.29 W1,J J 1.9 W1,J J 0.36 W1 4 D 0.018 -- -- 0.012 -- --o-Xylene 500 -- -- -- -- ND -- -- -- 0.18 W1,J J 1.3 W1,J J 0.33 W1 3.1 D 0.047 -- -- 0.035 -- --m&p-Xylene 500 -- -- -- -- ND -- -- -- 0.13 W1,J J 1.1 W1,J J 0.69 W1 -- -- -- -- -- -- --Xylenes, Total 500 -- -- -- -- ND -- -- -- 0.3 W1,J J 2.4 W1,J J 1 W1 11 D 0.14 -- -- 0.08 -- --Naphthalene 500 -- -- -- -- ND -- -- -- -- -- -- 260 BD 0.85 B -- -- 0.2 B -- --Methylcyclohexane -- -- -- -- -- ND -- -- -- ND J 0.26 W1,J J 0.14 W1 -- -- -- -- -- -- --Methyl tert butyl ether 500 -- -- -- -- ND -- -- -- ND ND ND ND 0.021 -- -- ND -- --Methylene Chloride 500 -- -- -- -- 0.0067 -- -- -- ND ND ND ND -- -- -- -- -- --TOTAL VOCs (mg/kg) -- -- -- -- -- 0.0122 -- -- -- 2.14 12.79 4.70 279 1.13 -- -- 0.321 -- --

Base-Neutral Semi-Volatile Organic Compounds (SVOCs) - mg/kgAcenaphthene 500 ND ND ND ND ND ND 9.2 DJ ND 1.1 DJ J 1.8 DJ J 1.2 DJ 6.5 DJ 6.6 DJ 0.11 DJ ND ND 0.14 DJ NDAcenaphthylene 500 0.081 DJ 0.35 DJ ND 0.31 DJ ND 0.16 J 18 DJ ND 1 DJ J 2.4 DJ J 7.2 D 47 D 57 D 0.74 DJ 0.34 DJ 0.48 DJ 0.43 DJ 0.098 DJAnthracene 500 0.046 DJ 0.28 DJ ND 0.31 DJ 0.2 DJ 0.026 J 48 D 0.065 DJ 1.7 DJ J 2.7 DJ J 8.4 D 47 D 76 D 0.7 DJ 0.39 DJ 0.29 DJ 0.42 DJ 0.11 DJBenzo(a)anthracene 5.6 0.44 DJ 1.9 D 0.19 DJ 1.5 DJ 1.4 DJ 0.18 J 77 D 0.41 DJ 4.2 DJ J 22 DJ J 13 D 66 D 170 D 3.7 D 1.6 D 2.2 D 2.3 D 0.76 DJBenzo(b)fluoranthene 5.6 0.74 DJ 2.4 D 0.23 DJ 1.6 D,ID4,J 1.6 DJ 0.36 75 D 0.48 DJ 7.2 DJ J 22 DJ J 11 D 60 D 150 D 5.2 D s 3 D 3.3 D 1.1 DJBenzo(k)fluoranthene 56 0.22 DJ 2.7 D 0.065 DJ ND 0.58 DJ 0.13 J 83 D 0.31 DJ 8 DJ J 24 DJ J 12 D 67 D 170 D 1.8 D 0.67 DJ 1.1 D 1 DJ 0.54 DJBenzo(g,h,i)perylene 500 0.32 DJ 0.55 DJ 0.09 DJ 0.4 DJ 1.4 DJ 0.32 18 DJ 0.45 DJ 3 DJ J 6.5 DJ J 2.9 DJ 15 DJ 31 D 3.4 D 1.4 D 1.9 D 1.9 DJ 0.8 DJBenzo(a)pyrene 1 0.56 DJ 1.4 DJ 0.17 DJ 1.1 DJ 1.4 DJ 0.32 50 D 0.44 DJ 5.3 DJ J 15 DJ J 8.3 D 41 D 110 D 4.2 D 1.7 D 2.6 D 2.5 D 0.91 DJBenzyl alcohol -- ND ND ND ND ND ND ND ND ND ND 0.39 DJ ND ND ND ND ND ND NDChrysene 56 0.47 DJ 1.9 D 0.17 DJ 1.4 DJ 1.7 DJ 0.21 71 D 0.65 DJ 4.4 DJ J 20 DJ J 12 D 61 D 140 D 3.4 D 1.4 D 2 2 D 0.87 DJ2-Chloronaphthalene -- ND ND ND ND ND ND ND ND ND ND 0.25 DJ ND ND ND ND ND ND ND4-Chloroaniline -- ND ND ND ND ND ND 13 DJ ND ND ND 9.1 D 61 D ND ND ND ND ND NDDibenzo(a,h)anthracene 0.56 ND 0.2 DJ ND 0.13 DJ 0.34 DJ 0.075 J 7.4 DJ 0.14 DJ ND ND 1 DJ 5.4 DJ 13 DJ ND ND 0.57 DJ ND 0.21 DJDibenzofuran 350 ND ND ND ND ND 0.034 J 30 DJ ND ND ND 6.8 D 40 D 19 DJ 0.14 DJ 0.1 DJ 0.067 DJ 0.17 DJ ND2,4-Dichlorophenol -- ND ND ND ND ND ND ND ND 6.8 DJ J 4.2 DJ J ND ND ND ND ND ND ND NDDi-n-octyl phthalate -- ND ND ND ND ND ND ND ND ND ND ND ND 0.85 DJ ND ND ND ND NDFluoranthene 500 0.52 DJ 2.4 D 0.28 DJ 2.8 D 2 DJ 0.14 J 170 D 0.57 DJ 4.4 DJ J 19 DJ J 25 D 120 D 330 D 6.6 D 3.2 D 2.8 D 3.1 D 1.2 DJFluorene 500 ND ND ND 0.093 DJ ND ND 61 D ND ND J 1.3 DJ J 10 D 55 D 46 D 1.6 DJ 0.076 DJ 0.19 DJIndeno(1,2,3-cd)pyrene 5.6 0.29 DJ 0.52 DJ 0.083 DJ 0.4 DJ 1 DJ 0.28 19 DJ 0.41 DJ ND J 5 DJ J 2.3 DJ 14 DJ 31 D 2.8 DJ 1.1 D 1.7 D 1.7 DJ 0.66 DJ2-Methylnaphthalene -- ND 0.084 DJ 0.037 DJ ND ND 0.082 J 21 DJ ND ND ND 11 D 77 D ND 0.1 DJ 0.037 DJ 0.091 DJ 0.15 DJNaphthalene 500 ND 0.11 DJ ND 0.16 DJ ND 0.069 J 41 D ND ND ND 29 D 200 D 6.5 DJ 0.31 DJ 0.1 DJ 0.12 DJ 0.32 DJ 0.11 DJ4-Nitrophenol -- ND ND ND ND ND ND ND ND 25 DJ J 41 DJ J ND ND ND ND ND ND ND NDN-Nitrosodiphenylamine -- ND ND ND ND ND ND ND ND 1.2 DJ J ND J 0.54 DJ 1.6 DJ ND ND ND ND ND NDPhenanthrene 500 0.14 DJ 0.39 DJ 0.16 DJ 1.2 DJ 0.98 DJ 0.1 J 250 D 0.3 DJ 3.9 DJ J 6.1 DJ J 31 D 170 D 240 D 2.6 D 1.9 D 1.1 D 1.5 DJ 0.49 DJPyrene 500 0.55 DJ 2.3 D 0.24 DJ 2.6 D 2.2 D 0.14 J 130 D 0.62 DJ 5.2 DJ J 22 DJ J 22 D 100 D 240 D 5.6 D 2.6 D 2.3 D 2.8 D 1.1 DJTOTAL SVOCs (mg/kg) -- 4.38 17.5 1.72 14.0 14.8 2.63 1,192 4.85 82.4 215 224 1,255 1,837 43 16.6 22.3 23.9 8.96

Polychlorinated Biphenyls (PCBs) - mg/kgAroclor 1260 -- ND ND ND ND 0.22 D,QSU ND ND ND ND ND ND ND ND 0.03 0.027 ND ND NDTOTAL PCBs (mg/kg) 1 0 0 0 0 0.22 0 0 0 0 0 0 0 0 0.03 0.027 0 0 0

Inorganic Compounds - mg/kgAluminum -- ND ND ND ND 14900 J J ND ND ND 2990 J J 8590 J J ND ND ND ND ND ND ND NDArsenic, Total 16 ND 120 ND 17.8 J 36.3 14.7 31.9 15.2 14.6 J J 34.3 J J 20.6 25.6 30.5 18.7 21.3 30.8 17.4 12.9Barium, Total 400 ND ND ND ND 155 J J ND ND ND 72.3 J J 92.4 J J ND ND ND ND ND ND ND NDBeryllium 590 ND ND ND ND 2.49 ND ND ND 0.577 J J 1.29 J J ND ND ND ND ND ND ND NDCadmium, Total 9.3 ND 1.1 ND 1.12 J 1.68 0.75 2.35 6.86 0.679 J J 1.61 J J 1.26 7.49 8.99 2.47 1.26 2.54 3.55 5.3Calcium -- ND ND ND ND 134000 DJ J ND ND ND 8130 J J 16000 J J ND ND ND ND ND ND ND NDChromium, Total 1,500 7.96 J J 25.2 J J 6.88 J J 32 J J 26.2 J J 8.28 J J 58.9 J J 164 J J 28.8 J J 43 J J 49.5 J J 71.2 J J 64.2 J J 76.4 J J 75.8 J J 97.4 J J 55.4 J J 114 J JCobalt -- ND ND ND ND 5.78 ND ND ND 4.95 J J 7.59 J J ND ND ND ND ND ND ND NDCopper 270 ND ND ND ND 57.9 ND ND ND 31.2 J J 113 J J ND ND ND ND ND ND ND NDIron -- ND ND ND ND 118000 D ND ND ND 31800 J J 70800 J J ND ND ND ND ND ND ND NDLead, Total 1,000 21.3 J J 111 J J 12.6 J J 91.1 J J 180 44.8 J J 258 J J 542 J J 46.4 J J 131 J J 825 J J 496 J J 775 J J 434 J J 2530 J J 531 J J 351 J J 454 J JMagnesium -- ND ND ND ND 31700 ND ND ND 1360 J J 5400 J J ND ND ND ND ND ND ND NDManganese 10,000 ND ND ND ND 3580 BD ND ND ND 1230 J J 1480 J J ND ND ND ND ND ND ND NDMercury, Total 2.8 0.0658 0.141 ND 0.245 J 0.467 0.11 D 0.925 D 6.05 D 0.286 J J 0.356 J J 17.7 D 13.6 D 30.5 D 1.47 D 1.5 D 0.261 0.587 0.292Nickel 310 ND ND ND ND 12.2 ND ND ND 10.6 J J 20.9 J J ND ND ND ND ND ND ND NDPotassium -- ND ND ND ND 1680 ND ND ND 211 J J 568 J J ND ND ND ND ND ND ND NDSodium -- ND ND ND ND 495 ND ND ND ND ND ND ND ND ND ND ND ND NDVanadium -- ND ND ND ND 32.9 ND ND ND 17.3 J J 37.6 J J ND ND ND ND ND ND ND NDZinc 10,000 ND ND ND ND 732 ND ND ND 324 J J 461 J J ND ND ND ND ND ND ND NDCyanide, Total 27 ND ND ND ND 1.5 ND ND ND ND ND ND ND ND ND ND ND ND ND

TCLP - mg/LTrichloroethene 0.5 -- -- -- -- -- -- -- -- 0.0068 DJ -- -- -- -- -- -- -- -- --Barium, Total 100 -- -- -- -- -- -- -- -- 0.478 B1, B -- -- -- -- -- -- -- -- --Cadmium, Total 1 -- -- -- -- -- -- -- -- 0.01 -- -- -- -- -- -- -- -- --Chromium, Total 5 -- -- -- -- -- -- -- -- 0.0079 BT, B -- -- -- -- -- -- -- -- --Lead, Total 5 -- -- -- -- -- -- -- -- 0.178 BT, B -- -- -- -- -- -- -- -- --

Flashpoint (0F) -- -- -- -- -- -- -- -- -- >176 -- -- -- -- -- -- -- -- --

Notes:


2. SCO = Soil Cleanup Objective (Protection of Public Health - Commercial), per NYSDEC 6NYCRR Part 375-6.8(b), Final December 2006.


4. Blind duplicate of BP1A-TP-9.

Acronyms:



BOLD = Value exceeds Restricted-Commercial SCO










Restricted-

Commercial SCOs

(mg/kg) 2

Parameter 1 TP - 8 TP - 9TP - 2 TP - 3 TP - 14 TP - 15TP - 6 TP - 7TP - 4 TP - 5 BLIND

4 TP - 10 TP - 11 TP - 12 TP - 13 TP - 16

Sample Location and Depth Interval (fbgs)

TP - 17TP - 1

TABLE 7

SUMMARY OF GROUNDWATER ANALYTICAL DATA


Tecumseh Redevelopment Inc.Lackawanna, New York

Field Measurements 5 :Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final Initial Final

pH (units) 6.5 - 8.5 7.54 7.41 6.66 6.59 -- -- 6.56 6.42 -- -- 6.17 6.37 -- -- 7.17 7.18 7.52 7.22 6.46 6.60 7.12 7.14 8.35 8.23 6.79 6.83

Temperature (oC) -- 14.3 14.6 9.0 8.0 -- -- 9.4 10.1 -- -- 15.1 15.3 -- -- 7.2 6.7 8.8 9.8 17.0 17.4 14.8 14.4 15.4 15.5 14.3 14.8Sp. Conductance (uS) -- 776.5 759.2 1170 1321 -- -- 971 1468 -- -- 1625 1618 -- -- 42 40 102 103 102 104 723 732 638 642 1,664 1,719Turbidity (NTU) -- 15.6 4.5 18.80 12.30 -- -- 43.7 128 -- -- 45.2 50.6 -- -- 13.4 8.49 21.0 16.90 18.4 7.26 10.9 3.90 2.5 2.64 16.6 4.54DO (ppm) -- 1.23 1.12 4.37 2.40 -- -- 3.37 1.86 -- -- 1.44 1.14 -- -- 2.91 2.59 1.76 1.57 2.64 2.57 1.85 1.71 2.13 1.94 1.56 1.51Eh (mV) -- -120 -105 -17 -23 -- -- -15 -18 -- -- -64 -74 -- -- -34 -37 -94 -75 -74 -79 --126 --124 --101 --69 --106 --116

Total Inorganic Compounds (mg/L):Arsenic - Total 0.025Barium - Total 1Chromium - Total 0.05Copper 0.2Cyanide- Total 0.2Iron - Total 0.3**Lead - Total 0.025Magnesium - Total 35*Manganese - Total 0.3**Nickel - Total 0.1Potassium - Total --Sodium - Total 20Zinc - Total 2*

Volatile Organic Compounds (ug/L):Benzene 1m-Xylene & p-Xylene 5Toluene 5Xylenes, total 5

Semi-Volatile Organic Compounds (ug/L):Acenaphthene 20Carbazole --Dibenzofuran --Di-n-butyl phthalate 50Fluoranthene 50Fluorene 50Pyrene 50

ND

ND

NDNDNDNDND

NDNDND

0.0019 J0.14

--ND--

0.86 B0.002 J

----

0.0046 JB

NDNDNDND

NDNDNDND

ND

ND

ND

ND

NDND

NDND

NDND

0.0014 J0.002 J --

ND

B - 2

ND0.2

ND--

ND--

--

--

ND

----

--

ND

ND

--

0.96 B

0.0055 JB

--ND

0.002 J--

----

ND--

----

----

--

ND0.43 J

ND

NDNDND

ND

NDND

ND NDNDNDND

NDND

NDND

0.0031 JND

MWN - 70A 3

5/7/2014

ND0.35

MWN - 70A 3

6/30/2010 6/30/2010

--

--

0.0025 J

--

ND0.026 JNDND

ND 0.069 J

MWN - 69A 3 MWN - 70A

0.0091 J0.16ND

--

--

--

6/30/2010 2/23/2016

NDND

--

--

1 J

ND

-- --

ND

----------

--

ND

--

----

ND----

--

0.13--

------

NDNDNDND

ND

ND

PARAMETER 1MWN - 69A3

5/7/2014

ND0.12

2/23/2016MWN - 69A

ND

--------

ND

----

ND----

--

--

MW - 16A6/30/2010

ND

6/30/2010

--ND--

----

BLIND4

ND--

ND----

2/23/2016

0.0056 J0.18

0.0011 J

ND

ND--

ND------

ND

----

ND

----

----

0.53 BND

5/7/2014

ND0.34ND--

0.13 J0.069 J

------

NDND

--

0.15 J

NDND

--

MWN - 71A6

6/30/2010

ND0.0308

NDNDND3.45ND19.51.7ND22.5

23.9 J

NDNDND

ND

P - 45S6/30/2010

0.0127 JNDNDNDNDND

0.0462NDNDNDNDND

ND0.06 J

ND

5.1

0.67 J1.4 J

0.84 J2.7 J0.34 J1.2 J

ND

NDNDNDNDNDND

NDND

0.37 JNDND

NDNDNDNDND

NDNDNDND

ND

NDNDNDNDNDND

NDND

ND

NDNDNDNDNDND

ND

ND

NDNDNDNDNDND

NDNDND

GWQS 2

ND NDND

--

--

----

NDNDNDND

ND--

--

ND--

ND--

BLIND4

--ND

BLIND4

TABLE 7

SUMMARY OF GROUNDWATER ANALYTICAL DATA



Notes: 1. Only those parameters detected at a minimum of one sample location are presented in this table; all other compounds were reported as non-detect. 2. NYSDEC Class "GA" Groundwater Quality Standards/Guidance Values (GWQS/GV) as per 6 NYCRR Part 703. 3. Groundwater collected from the June 2010 and the May 2014 monitoring event were only analyzed for those parameters listed in the April 2010 Remedial Investigation Work Plan. 4. Blind duplicate of MWN-69A 5. Field measurements were collected immediately before and after groundwater sample collection. 6. After 2010 the well was damaged; no further samples collected.

Acronyms:ND = Parameter not detected above laboratory detection limit." -- " = not analyzed for this parameter or no individual SCO" * " = Groundwater Quality Guidance Value" ** " = Iron + Manganese GWQS = 0.5 mg/L

BOLD = Analytical result exceeds NYSDEC Class GA GWQS

Laboratory Qualifiers (located next to the sample result):J = Analyte was detected at a level less than the Reporting Limit (RL) and greater than or equal to the Method Detection Limit (MDL).B= Parameter was found in method blank.

Data Validation Qualifiers (under separate column "Q"):J = The analyte was positively identified; the associated numerical value is an approximate concentration of the analyte in the sample.

TABLE 8

SUMMARY OF EMERGENT CONTAMINANTS GROUNDWATER ANALYTICAL DATA

RI/AA ReportPhase IA Business Park - Brownfield Cleanup Program


Monitoring LocationMWN-69A MWN-70A

Semi-Volatile Organic Compounds 8270 SIM (ug/L):1,4 - Dioxane 0.35 ND ND --

Perfluorinated Alkyl Acids (ng/L): Action Level 2

Perfluorobutanoic acid (PFBA) -- 3.7 23.5 NDPerfluroropentanoic acid (PFPeA) -- 1.62 J ND NDPerfluorobutanesulfonic acid (PFBS) -- ND ND NDPerflurorohexanoic acid (PFHxA) -- ND 4.72 NDPerfluroroheptanoic acid (PFHpA) -- ND 3.76 NDPerfluorohexanesulfonic acid (PFHxS) -- ND 1.82 NDPerfluorooctanoic acid (PFOA) 10 0.884 J 17.3 ND1H,1H,2H,2H-Perfluorooctanesulfonic acid (6:2FTS) -- ND 1.17 J 1.39 JPerfluoroheptanesulfonic acid (PFHpS) -- ND ND NDPerfluorononanoic acid (PFNA) -- ND 2.67 NDPerfluorooctanesulfonic acid (PFOS) 10 0.368 J 10.5 0.178 JPerfluorodecanoic acid (PFDA) -- ND 0.85 J ND1H,1H,2H,2H-Perfluorodecanesulfonic acid (8:2FTS) -- ND ND NDN-Methyl Perfluorooctanesulfonamidoacetic acid (NMeFOSAA) -- ND ND NDPerfluoroundecanoic Acid (PFUnA) -- ND ND NDPerfluorodecanesulfonic acid (PFDS) -- ND ND NDPerfluorooctanesulfonamide (FOSA) -- ND 0.257 J NDN-Ethyl Perfluorooctanesulfonamidoacetic Acid (NEtFOSAA) -- ND ND NDPerfluorododecanoic Acid (PFDoA) -- ND ND NDPerfluorotridecanoic Acid (PFTrDA) -- ND ND NDPerfluorotetradecanoic acid (PFTA) -- ND ND ND

PFOA + PFOS 3 70 1.25 J 27.8 J 0.178 JTotal PFAS 3 500 6.57 66.5 1.57

Notes:1. Values per NYSDEC TOGS 1.1.1 Class GA Groundwater Quality Standard (GWQS).2. PFOA and PFOS results are compared to the NYSDEC proposed drinking water maximum contaminant level of 10 ng/L for each compound.3. Per NYSDEC guidance, action levels in groundwater requiring additional monitoring.

Definitions:SIM = Selective Ion Monitoring method usedng/L = nanograms per liter; parts per trillionJ = Estimated value ND = Indicates parameter was not detected above laboratory reporting limit and is reported herein as not detected (ND).

NYSDEC GWQS Class GA 1

FIELDBLANKParameter

1 of 4

TABLE 9

SUMMARY OF ELECTRICAL TRANSFORMER OIL ANALYTICAL DATA



Sample Location and Transformer I.D. Number

Blowing Engine House No. 3

T-100 T-101 T-102 T-106 T-107 T-108 T-109 T-110 T-111Polychlorinated Biphenyls (PCBs) - mg/kg

Aroclor 1016 ND ND ND ND ND ND ND ND NDAroclor 1221 ND ND ND ND ND ND ND ND NDAroclor 1232 ND ND ND ND ND ND ND ND NDAroclor 1242 ND ND ND ND ND ND ND ND NDAroclor 1248 ND ND ND ND ND ND ND ND NDAroclor 1254 ND ND ND ND ND ND ND ND NDAroclor 1260 ND 9.8 9.5 9.7 ND ND ND ND ND

TOTAL PCBs 0 9.8 9.5 9.7 0 0 0 0 0

Notes:1. Only those parameters detected at a minimum of one sample location are presented in this table; all other compounds were reported as non-detect.

Parameter 1

2 of 4

TABLE 9





Power House No. 1

T-113 T-114 T-115 T-116 T-117 T-118 T-119 T-120 T-121 T-122 T-123Polychlorinated Biphenyls (PCBs) - mg/kg

Aroclor 1016 ND ND ND ND ND ND ND ND ND ND NDAroclor 1221 ND ND ND ND ND ND ND ND ND ND NDAroclor 1232 ND ND ND ND ND ND ND ND ND ND NDAroclor 1242 ND ND ND ND ND ND ND ND ND ND NDAroclor 1248 ND ND ND ND ND ND ND ND ND ND NDAroclor 1254 ND ND ND ND ND ND ND ND ND ND NDAroclor 1260 3.7 ND ND ND ND ND 4.8 ND ND ND 2.4

TOTAL PCBs 3.7 0 0 0 0 0 4.8 0 0 0 2.4


Parameter 1

3 of 4

TABLE 9





Power House No. 1 Steam Station Blowing Engine House No. 3

T-124 T-125 T-126 T-127 T-128 T-129 T-130 T-135 T-134 T-131 T-132Polychlorinated Biphenyls (PCBs) - mg/kg

Aroclor 1016 ND ND ND ND ND ND ND ND ND ND NDAroclor 1221 ND ND ND ND ND ND ND ND ND ND NDAroclor 1232 ND ND ND ND ND ND ND ND ND ND NDAroclor 1242 ND ND ND ND ND ND ND ND ND ND NDAroclor 1248 ND ND ND ND ND ND ND ND ND ND NDAroclor 1254 ND ND ND ND ND ND ND ND ND ND NDAroclor 1260 2.3 ND ND ND ND ND ND 18 ND ND ND

TOTAL PCBs 2.3 0 0 0 0 0 0 18 0 0 0


Parameter 1

4 of 4

TABLE 9





Power House No. 1

T-136 T-137 T-138 T-139 T-140 T-141 T-142 T-143 T-144 T-145 T-146 T-147 T-148Polychlorinated Biphenyls (PCBs) - mg/kg

Aroclor 1016 ND ND ND ND ND ND ND ND ND ND ND ND NDAroclor 1221 ND ND ND ND ND ND ND ND ND ND ND ND NDAroclor 1232 ND ND ND ND ND ND ND ND ND ND ND ND NDAroclor 1242 ND ND ND ND ND ND ND ND ND ND ND ND NDAroclor 1248 ND ND ND ND ND ND ND ND ND ND ND ND NDAroclor 1254 ND ND ND ND ND ND ND ND ND ND ND ND NDAroclor 1260 ND 10 ND ND 2.2 ND ND ND ND ND ND ND ND

TOTAL PCBs 0 10 0 0 2.2 0 0 0 0 0 0 0 0


Parameter 1

TABLE 10A

SUMMARY OF BUILDING SURFACE WIPE AND FLOOR/SOIL SAMPLE ANALYICAL DATA (JUNE 2010)



Wipe Sample Location and I.D. NumberPower House No. 1

C-1 Floor Wipe C-2 Floor Wipe T-118 Wipe T-118 "North" Floor Wipe

T-128-T-130 Floor Wipe




Polychlorinated Biphenyls (PCBs) - ug/100 cm 2

Aroclor 1016 ND ND ND ND ND ND ND ND --Aroclor 1221 ND ND ND ND ND ND ND ND --Aroclor 1232 ND ND ND ND ND ND ND ND --Aroclor 1242 ND ND ND ND ND 2.6 ND ND --Aroclor 1248 ND ND ND ND ND ND 4.7 ND --Aroclor 1254 3.8 ND ND 140 6.7 3.1 26 280 --Aroclor 1260 ND ND ND ND ND ND 8.1 ND --

TOTAL PCBs 3.8 0 0 140 6.7 5.7 38.8 280 10

Sample Location and I.D. Number

Power House No. 1 Blowing Engine House No. 3

Floor/Soil Sample T-100-T-112 Floor/Soil Sample

Polychlorinated Biphenyls (PCBs) - mg/kgAroclor 1016 ND NDAroclor 1221 ND NDAroclor 1232 ND NDAroclor 1242 0.95 NDAroclor 1248 ND NDAroclor 1254 3.0 0.0053Aroclor 1260 3.4 ND

TOTAL PCBs 7.35 0.0053

Notes:1. USEPA Recommended Cleanup Criteria for Low Contact Restricted Access Areas (ug/m2).

BOLD = Result exceeds USEPA Cleanup Criteria

BOLD = Result above commercial SCO (1 mg/kg) but below industrial SCO (25 mg/kg)

USEPA Recommended

Cleanup Criteria1

Parameter

Parameter 1

TABLE 10B

SUMMARY OF BUILDING SURFACE POST CLEANING WIPE AND FLOOR/SOIL SAMPLE ANALYICAL DATA (MARCH 2016)



Wipe Sample Location and I.D. NumberPower House No. 1

Power House Post Cleaning Floor

Wipe No. 1


Wipe No. 2


Wipe No. 3


Wipe No. 4


Wipe No. 5

T-118 "North" Post Cleaning Floor

Wipe

T-141-T-143 Post Cleaning Floor

Wipe No.1


Wipe No.2T141-143-2A


Wipe No.1


Wipe No.2T-144-146-1A T-144-146-2A T-144-146-1B T-144-146-2B

Polychlorinated Biphenyls (PCBs) - ug/100 cm 2

Aroclor 1016 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND --Aroclor 1221 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND --Aroclor 1232 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND --Aroclor 1242 ND ND 0.265 J 0.353 J 0.254 ND ND ND ND ND ND ND ND ND ND --Aroclor 1248 ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND --Aroclor 1254 0.51 0.501 0.669 0.882 0.335 J 5.92 1.95 21.4 5.9 33.2 58.9 47.2 74.8 16.6 33.3 --Aroclor 1260 0.395 J 0.512 0.145 J 0.172 J 0.36 ND ND ND ND ND ND ND ND ND ND --

TOTAL PCBs 0.905 J 1.013 1.079 J 1.41 J 0.949 J 5.92 1.95 21.4 5.9 33.2 58.9 47.2 74.8 16.6 33.3 10

Sample Location and I.D. Number

Polychlorinated Biphenyls (PCBs) - mg/kgAroclor 1016Aroclor 1221Aroclor 1232Aroclor 1242Aroclor 1248Aroclor 1254Aroclor 1260

TOTAL PCBs

Notes:1. USEPA Recommended Cleanup Criteria for Low Contact Restricted Access Areas (ug/m2).

BOLD = Result exceeds USEPA Cleanup Criteria

BOLD = Result above commercial SCO (1 mg/kg) but below industrial SCO (25 mg/kg)

NDNDND20.5ND

20.5

NDND

USEPA Recommended

Cleanup Criteria1

Parameter

Parameter 1

Power House No. 1

Post Floor Sediment + Cleaning


TABLE 11

POTENTIAL CHEMICAL-SPECIFIC ARARs

RI/AA Report Phase IA Business Park Area – Brownfield Cleanup Program

Tecumseh Redevelopment Inc. Standard, Requirement, Criteria or

Limitation Citation or Reference Description/Comments

Groundwater/Surface Water: RCRA Groundwater Protection Standards and Maximum Concentration Limits

40 CFR 264, Subpart F Establishes criteria for groundwater consumption. Groundwater is/will not be used for potable purposes. Potentially relevant for off-site groundwater quality.

NYSDEC Surface Water and Groundwater Quality Standards and Groundwater Effluent Limitations

6NYCRR Parts 701- 703 Establishes groundwater and surface water quality criteria Applicable to on-site and off-site groundwater quality, and runoff/groundwater migration. Establishes criteria for groundwater consumption.

Ambient Water Quality Standards and Guidance Values

TOGS 1.1.1, June 1998 Establishes groundwater and surface water quality standards and guidance values. Applicable to on-site and off-site groundwater quality

Air: New York State Air Quality Classifications and Standards

6NYCRR Parts 256 and 257 Establishes air quality standards protective of public health. Potentially applicable to disruptive activities.

National Primary and Secondary Ambient Air Quality Standards (NAAQS)

40 CFR Part 50 Establishes primary and secondary ambient air quality standards to protect public health and welfare. Potentially applicable to disruptive activities.

New York State DOH Soil Vapor Intrusion Guidance

New York State Department of Health, Oct. 2006

Establishes sub-slab and indoor air thresholds for sites impacted by VOCs. Potentially relevant.

Soil: NYSDEC Environmental Remedial Programs

6NYCRR Part 375 Establishes procedures for inactive hazardous waste site remedy selection & identifies Soil Cleanup Objectives based on human health, ecological protection, and groundwater protection. Applicable to site soil/fill.

DER-10/Technical Guidance for Site Investigation and Remediation

DEC Program Policy; May 3, 2010

This guidance provides an overview of the site investigation and remediation process for the DEC remedial programs administered by the Division of Environmental Remediation (DER).

CP-51 Soil Cleanup Guidance DEC Program Policy, October 21, 2010

Procedures for the selection of soil cleanup levels appropriate for each of the remedial programs in the NYSDEC Div. Environmental Remediation.

USEPA Soil Screening Guidance Technical Background Document and Users Guide, May 1996 revisions

Presents a framework for developing risk-based, soil screening levels for protection of human health. Provides a tiered approach to site evaluation and screening level development for Superfund sites. Potentially relevant.

Other: USEPA Requirements for PCB Spill Cleanup

40 CFR Part 761.125 Low-contact impervious surfaces are to be cleaned to 10 ug/m2 following release of PCB-contaminated oil. Potentially relevant.

TABLE 12

POTENTIAL LOCATION-SPECIFIC ARARs



Standard, Requirement, Criteria or Limitation

Citation or Reference Description/Comments

Other: National Historic Preservation Act 16 CFR Part 470 Requires avoiding impacts on cultural resources having historical

significance. Potentially applicable to remedial alternatives involving soil/fill disruption.

NYSDEC Environmental Remedial Programs

6NYCRR Part 375 Requires consideration of future land use in remedy selection and soil cleanup criteria. Applicable to site soil/fill.

TABLE 13

POTENTIAL ACTION-SPECIFIC ARARs



Standard, Requirement, Criteria or Limitation

Citation or Reference Description/Comments

Groundwater: Clean Water Act, National Pretreatment Standards

40 CFR 403.5 General pretreatment regulations for discharge to POTWs – potentially applicable for soil excavation alternatives involving temporary discharges of storm water or perched groundwater to sanitary sewer.

Air: NYSDEC Guidance for Fugitive Dust Suppression and Particulate Monitoring

DEC Program Policy; May 3, 2010; Appendix 1B

Establishes guidance for community air monitoring and controls to monitor and mitigate fugitive dusts during intrusive activities at NY State inactive hazardous waste sites – applicable to disruptive activities.

OSHA General Industry Air Contaminants Standard

29 CFR 1910.1000 Establishes Permissible Exposure Limits for workers exposed to airborne contaminants. Applicable to disruptive activities.

Solid, Hazardous, and Non-Hazardous Waste: NYSDEC Inactive Hazardous Waste Disposal Sites

6NYCRR Part 375 Establishes procedures for inactive hazardous waste disposal site identification, classification, and investigation activities, as well as remedy selection and interim remedial actions. To be considered.

NY State Solid Waste Transfer Permits 6NYCRR Part 364 Establishes procedures to protect the environment from mishandling and mismanagement of all regulated waste transported from a site of generation to the site of ultimate treatment, storage, or disposal. Potentially applicable for alternatives involving off-site disposal.

DOT Rules for Hazardous Materials Transport

(49 CFR 107, 171.1 - 171.5). Establishes requirements for shipping of hazardous materials. Potentially applicable for alternatives involving off-site disposal

Occupational Safety and Health Act (29 USC 651 et seq.)

29 CFR Part 1910 and 1926 Describes procedures for maintaining worker safety. Applicable to site construction activities.

NYSDEC Land Disposal Restrictions

6NYCRR Part 376 Identifies hazardous wastes that are restricted from land disposal and defines those limited circumstances under which an otherwise prohibited waste may be land disposed. Applicable to soil/fill disposal alternatives

TABLE 14

ALTERNATIVE 2UNRESTRICTED-USE (TRACK 1) CLEANUP

RI/AA ReportPhase IA Business Park - Brownfield Cleanup Program


Item Quantity Units UnitCost

TotalCost

Impacted Soil/Fill RemovalClearing & Grubbing 9.8 ACRES 4,000$ 39,200$ Soil/Fill Excavation & Dewatering (to 8 fbgs) 126,485 CY 8$ 1,011,883$ Transportation and Disposal at TSDF 177,079 TON 55$ 9,739,371$ Building Demolition 1 LS 1,000,000$ 1,000,000$ Verification Sampling 1 LS 10,000$ 10,000$

Subtotal: 11,800,453$

PCB-Impacted Floor RemovalTransport & dispose PCB-impacted concrete off-site 2 CY 150$ 300$

Subtotal: 300$

Site RestorationPart 375 1 Compliant Backfill, Place & Compact 118,580 CY 15$ 1,778,700$ 6" Topsoil 7,905 CY 20$ 158,107$ Seeding 9.8 Acres 2,500$ 24,500$

Subtotal: 1,961,307$

Subtotal Capital Cost 13,762,060$

Contractor Mobilization/Demobilization 100,000$ Health and Safety/Air Monitoring 150,000$ Engineering/Contingency (10%) 1,376,206$

Total Capital Cost 15,389,000$

DOL-Required Abatement 250,000$

Total Capital Cost 15,639,000$

Notes:1. Per 6NYCRR 375-6.7(d)(ii)(b)


TABLE 15

ALTERNATIVE 3RESTRICTED-USE (TRACK 4) CLEANUP WITH

PLACEMENT OF A SOIL COVER SYSTEM PRIOR TO REDEVELOPMENT




TotalCost

Institutional ControlsDevelop Site Management Plan, Easement, Survey 1 LS 25,000$ 25,000$ Final Engineering Report 1 LS 20,000$ 20,000$

Subtotal: 45,000$

Soil Excavation/On-Site Biotreatment

Water Management & Amendment (if needed)GW Management/Treatment 3,000 GAL 10$ 30,000$ Amendment 1 LS 128,000$ 128,000$

Subtotal: 158,000$

Biopad PreparationClearing & Grubbing 0.5 ACRE 4,000$ 2,000$ On-Site Biopad Prep/Mulch 403 CY 12$ 4,840$

Subtotal: 6,840$

Hotspot A (Product on WT; PAHs)Soil/Fill Excavation (0-8 fbgs) 300 CY 10$ 3,000$ On-Site Hauling to/from biopad 300 CY 5$ 1,500$ Biotilling/fertilizing 5 DAYS 750$ 3,750$ Verification Sampling 2 EA 225$ 450$ Slag Backfill (furnish, place, compact) 510 TONS 10$ 5,100$

Subtotal: 13,800$

Hotspot C (PAHs)Soil/Fill Excavation (0-6 fbgs) 135 CY 8$ 1,080$ On-Site Hauling to/from biopad 135 CY 10$ 1,350$ Biotilling/fertilizing 5 DAYS 750$ 3,750$ Verification Sampling 2 EA 225$ 450$ Slag Backfill (furnish, place, compact) 230 TONS 10$ 2,295$

Subtotal: 8,925$


Page 1 of 4

TABLE 15






TotalCost


Soil/Fill Excavation, Off-Site Disposal

Hotspot B (PAHs, Mercury)Soil/Fill Excavation (0-6 fbgs) 1,335 CY 8$ 10,680$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 2,270 TONS 55$ 124,823$ Verification Sampling 12 EA 250$ 3,000$ Slag Backfill (furnish, place, compact) 2,270 TONS 10$ 22,695$

Subtotal: 164,198$

Hotspot D (PAHs, Lead)Soil/Fill Excavation (0-2 fbgs) 45 CY 8$ 360$ Stabilization of Lead (if needed) 1 LS 5,000$ 5,000$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 77 TONS 55$ 4,208$ Verification Sampling 5 EA 250$ 1,250$ Slag Backfill (furnish, place, compact) 77 TONS 10$ 765$

Subtotal: 14,583$

Hotspots E, F & G (Metals)Soil/Fill Excavation (0-2 fbgs) 135 CY 8$ 1,080$ Stabilization (if needed) 1 LS 5,000$ 5,000$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 230 TONS 55$ 12,623$ Verification Sampling 5 EA 50$ 250$ Slag Backfill (furnish, place, compact) 230 TONS 10$ 2,295$

Subtotal: 24,248$

Hotspot H (Arsenic)Soil/Fill Excavation (0-4 fbgs) 90 CY 8$ 720$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 153 TONS 55$ 8,415$ Verification Sampling 5 EA 50$ 250$ Slag Backfill (furnish, place, compact) 153 TONS 10$ 1,530$

Subtotal: 13,915$

Page 2 of 4

TABLE 15






TotalCost



Subtotal: 300$

Soil Cover SystemClearing & Grubbing 8.0 ACRES 4,000$ 32,000$ 6" Part 375 1 Compliant Cover, Place & Compact 6,453 CY 15$ 96,800$ 6" Topsoil 6,453 CY 20$ 129,067$ Seeding 8.0 ACRES 2,000$ 16,000$

Subtotal: 273,867$

Subtotal Remedial Cost 723,674$

Contractor Mobilization/Demobilization (5%) 36,184$ Health and Safety (2%) 14,473$ Engineering/Contingency (10%) 72,367$

Total Capital Remediation Cost 846,699$

Environmental-Based Redevelopment CostsClear/Remove & Transport Existing Cover Soil 2 10,325 CY 5$ 51,627$ Off-Site Transportation and Staging Off-Site 10,325 CY 10$ 103,253$ Oversight and Air Monitoring during Intrusive Work 1 LS 40,000$ 40,000$

Subtotal: 194,880$

TOTAL CAPITAL COSTS 1,042,000$

Page 3 of 4

TABLE 15






TotalCost


Annual Operation, Maintenance & Monitoring:Site Maintenance and Mowing 2 YR 3,000$ 6,000$ Groundwater Sampling / Reporting 2 YR 7,500$ 15,000$ Annual Certification 1 YR 3,000$ 3,000$

Total Annual OM&M Cost 24,000$

Number of Years ( n ): 30Interest Rate ( i ): 3%p/A value: 19.6004

OM&M Present Worth (PW): 471,000$


Total Present Worth (PW): Capital Cost + OM&M PW 1,763,000$

Notes:1. Per 6NYCRR 375-6.7(d)(ii)(b)2. Assumes 20% of vegetated cover remains in place; 80% removed off-site

Page 4 of 4

TABLE 16

ALTERNATIVE 4RESTRICTED-USE (TRACK 4) CLEANUP

WITH DEFERRED COVER SYSTEM DURING SITE REDEVELOPMENT




TotalCost

Institutional ControlsDevelop Site Management Plan, Easement, Survey 1 LS 25,000$ 25,000$ Final Engineering Report 1 LS 20,000$ 20,000$

Subtotal: 45,000$

Soil Excavation/On-Site Biotreatment

Water Management & Amendment (if needed)GW Management/Treatment 3,000 GAL 10$ 30,000$ Amendment 1 LS 128,000$ 128,000$

Subtotal: 158,000$

Biopad PreparationClearing & Grubbing 0.5 ACRE 4,000$ 2,000$ On-Site Biopad Prep/Mulch 403 CY 12$ 4,840$

Subtotal: 6,840$

Hotspot A (Product on WT; PAHs)Soil/Fill Excavation (0-8 fbgs) 300 CY 10$ 3,000$ On-Site Hauling to/from biopad 300 CY 5$ 1,500$ Biotilling/fertilizing 5 DAYS 750$ 3,750$ Verification Sampling 2 EA 225$ 450$ Slag Backfill (furnish, place, compact) 510 TONS 10$ 5,100$

Subtotal: 13,800$

Hotspot C (PAHs)Soil/Fill Excavation (0-6 fbgs) 135 CY 8$ 1,080$ On-Site Hauling to/from biopad 135 CY 10$ 1,350$ Biotilling/fertilizing 5 DAYS 750$ 3,750$ Verification Sampling 2 EA 225$ 450$ Slag Backfill (furnish, place, compact) 230 TONS 10$ 2,295$

Subtotal: 8,925$


Page 1 of 4

TABLE 16






TotalCost


Soil/Fill Excavation, Off-Site Disposal

Hotspot B (PAHs, Mercury)Soil/Fill Excavation (0-6 fbgs) 1,335 CY 8$ 10,680$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 2,270 TONS 55$ 124,823$ Verification Sampling 12 EA 250$ 3,000$ Slag Backfill (furnish, place, compact) 2,270 TONS 10$ 22,695$

Subtotal: 164,198$

Hotspot D (PAHs, Lead)Soil/Fill Excavation (0-2 fbgs) 45 CY 8$ 360$ Stabilization of Lead (if needed) 1 LS 5,000$ 5,000$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 77 TONS 55$ 4,208$ Verification Sampling 5 EA 250$ 1,250$ Slag Backfill (furnish, place, compact) 77 TONS 10$ 765$

Subtotal: 14,583$

Hotspots E, F & G (Metals)Soil/Fill Excavation (0-2 fbgs) 135 CY 8$ 1,080$ Stabilization (if needed) 1 LS 5,000$ 5,000$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 230 TONS 55$ 12,623$ Verification Sampling 5 EA 50$ 250$ Slag Backfill (furnish, place, compact) 230 TONS 10$ 2,295$

Subtotal: 24,248$

Hotspot H (Arsenic)Soil/Fill Excavation (0-4 fbgs) 90 CY 8$ 720$ Waste Profile 1 LS 3,000$ 3,000$ Transport & Off-Site Disposal 153 TONS 55$ 8,415$ Verification Sampling 5 EA 50$ 250$ Slag Backfill (furnish, place, compact) 153 TONS 10$ 1,530$

Subtotal: 13,915$

Page 2 of 4

TABLE 16






TotalCost



Subtotal: 300$

Soil Cover System 1

Clearing & Grubbing 6.2 ACRES 4,000$ 24,620$ 6" Part 375 2 Compliant Cover, Place & Compact 4,965 CY 15$ 74,476$ 6" Topsoil 4,965 CY 20$ 99,301$ Seeding 6.2 ACRES 2,000$ 12,310$

Subtotal: 210,706$

Subtotal Remedial Cost 660,514$

Contractor Mobilization/Demobilization (5%) 33,026$ Health and Safety (2%) 13,210$ Engineering/Contingency (10%) 66,051$

Total Capital Remediation Cost 772,801$

Environmental-Based Redevelopment CostsOversight and Air Monitoring during Intrusive Work 1 LS 40,000$ 40,000$

Subtotal: 40,000$

TOTAL CAPITAL COSTS 813,000$

Page 3 of 4

TABLE 16






TotalCost


Annual Operation, Maintenance & Monitoring:Site Maintenance and Mowing 2 YR 3,000$ 6,000$ Groundwater Sampling / Reporting 2 YR 7,500$ 15,000$ Annual Certification 1 YR 3,000$ 3,000$

Total Annual OM&M Cost 24,000$

Number of Years ( n ): 30Interest Rate ( i ): 3%p/A value: 19.6004

OM&M Present Worth (PW): 471,000$


Total Present Worth (PW): Capital Cost + OM&M PW 1,534,000$

Notes:1. Assumed to cover 50% of the Site (remainder covered by building, pavement, etc.)2. Per 6NYCRR 375-6.7(d)(ii)(b)

Page 4 of 4


0071-010-350

FIGURES

REMEDIAL INVESTIGATION/ALTERNATIVES ANALYSIS REPORT

TECUMSEH REDEVELOPMENT INC.

PHASE IA BUSINESS PARK AREALACKAWANNA, NEW YORK

SITE LOCATION AND VICINITY MAP

FIGURE 1

PHASE I A BUSINESS PARK

AREA

LEGEND:

EXISTING ON-SITE BUILDING / STRUCTURE

TECUMSEH PROPERTY BOUNDARY

NOTES:

1. The north and south return water trenches are excluded from the Phase IA BPA site.2. Building locations are based on historical surveys and maps, all locations should be considered approximate.3. All buildings known to exist on site since 1944 are shown, some buildings were expanded or demolished following 1944, maximum building extents are shown.

EXISTING OFF-SITE MONITORING WELLB-2

PHASE IA BPA PROPERTY BOUNDARY (see Note 1)

PHASE IA BPA MONITORING WELL (3)MWN-69A

UTILITY POLE

DEMOLISHED BUILDING AND HISTORICAL FEATURE (see Notes 2 & 3)

CONCRETE, FOUNDATION, RUINS, ETC. (shape & size varies)

EXISTING OFF-SITE BUILDING / STRUCTURE

DECOMMISSIONED OFF-SITE PIEZOMETERP-45S

B-1(destroyed)

ABANDONED MONITORING WELL

HIGHWAY 8

T I M E S

S Q U A R E

SIGN

GATE

N O R T H R E T U R N W A T E R T R E N C H

BP1A-B-01

N O R T H R E T U R N W A T E R T R E N C H ( B E L O W G R A D E )

BP3-B-01

BP3-B-02

1200 GALLON

FUEL OIL TANKSGAS MIXING

STATION

MILL NO. 2

HEATING BUILDING

WELDING

OPEN HEARTH HOT MIXERS

40' GANTRY CRANE

SCALE

HOUSE

OIL

HOUSE

OFFICE

TOOL

SHED

THAW SHED

CRANEWAY

OFFICELOCKERS

MOULD HEATING BUILDINGOIL HO.

HOT

MIXER

BUILDING

CLAY

STGE.

PUMP

HOUSESWITCH HO.

1-TRANSFORMER

ACETYLENE &

OXYGEN STORAGE

SUBSTA.

B I L L E T P R E P A R A T I O N B U I L D I N G N O . 2

COVERED MOULD YARD

FORGE SHOPWELFARE BLDG.

MACHINE SHOP

GARAGE

MASTER MECHANIC

OFFICE

2,500 GAL.

FUEL OIL TANK

(3' concrete w

all)

RAILROAD YARD

FOUNDRY

WELFARE BUILDING

OIL &

LOCKER

HOUSE

STRIPPER BUILDING

NO. 2

25,000 GAL

FUEL OIL TANK

(concrete wall 3' high

)

PITCH TANK

(concrete dike 3' above &

below groun

d)PUMP HOUSE

PITCH PUMP HOUSE

SUBSTATION

NO. 153-TRANSFORMERS

DUST COLLECTION

SILO

44" BLOOMING MILL MOTOR ROOM

40" MILL

(PIT FURNACE BUILDING)

SUBSTATION

(3 TRANS.)

COVERED BILLET

YARD

36" ROUGHING

MILL MOTOR ROOM

36" ROUGHING MILLOFFIC

E32"

FINISHING

MILL MOTOR

ROOM

H O

T

B

E D

S

RAIL COOLING BUILDING

RAIL MILL FINISHING DEPARTMENT

32" R A I L

M I L L

BUNG

FURNACE

BUILDING

CRANEWAYBILLET

YARD

MILLWRIGHT

SHOP & OFF.

WELFARE BUILDING

WEL

FARE

BUILD

ING

30" MILL

COOLING

BEDS

CRANEWAY

NO. 1

SETTLING BASIN

21" FINISHING MILL MOTOR ROOM30" - 21" FINISHING MILL

C E N T R A L

B I L L E T Y

A R D

(BILLET PREPARATION BUILDING NO. 1)

(FMR. MERCHANT MILL NO. 9)

ACID TANK

(elevated 15'

on steel legs

)

TRACK

HOPPER

SKIP HOIST

HOUSE

ASH

HOPPER

EX

HA

US

T S

TA

CK

S 7

3'

WELFARE BLDG.

6,800 GAL.

QUENCH OIL

TANK

OIL PUMP

HOUSE

32" RAIL MILL LOADING BUILDING

OXYGEN METER HO.9,000 GAL.

FUEL OIL TANK

(REPORTEDLY REMOVED)

27282930

31

SKIP HOIST HO.

VALVE HOS.

VALVE HO.

MAIN

VALVE HO.

INTAKE SUMP TUNNEL

WELFARESUBSTATION 7M

PICKELING

VATS

GAS BOOSTER HOUSE

1ST - PUMP HO. & GAS METER HO.

2ND - SWITCH ROOM

MILLWRIGHTS &

ELECT. OFF./SHOP

SUMP

40" BLOOMING

MILL MOTOR ROOM

44" MILL


44" BLOOMING MILL

PUMPING STATION NO. 1

HORIZONTAL TANKPUMP HO.

BAROMETRIC

CONDENSER COLD WELL

(capacity unlimited, base bel

ow lake level)

Decommissioned & backfille

d August 3, 1973 to 584 fmsl.

FEEDER STATION

NO. 2

LIGHT OIL

RECOVERY PLANTSWITCH HOUSE

FMR. FUEL DEPT.

GAS HOLDER

PUMP HOUSE

SUBSTATION 8-I (1-TRANSFORMER)

FILTER

HOUSE

MACHINERY

HOUSE

GAS MIXING HO.

BAROMETRIC CONDENSER

SUBSTATION

FMR. 19,900

GAL FUEL OIL AST

STEAM STATION NO. 3

COAL & SAND BIN

SCALE

AIR BLOWER &

GAS BOOSTER HOUSE

30" ROUGHING MILL

MOTOR ROOM

GAS MIXING STATION

AIR SAMPLER

STA. NO. 3B I L L E T P R E P A R A T I O N B U I L D I N G N O . 2 ( N O R T H )

( F M R . M E R C H A N T M I L L N O . 1 0 [ 8 " & 1 0 " ] )

MOTOR ROOM

SCALE PIT

HOT SCARFER

PIT

SETTLING BASIN

SETTLING BASIN

SETTLING BASINPUMP HO. &

SUBSTATION

40" BLOOMING MILL

HOT SCARFERPIT

SETTTLING BASIN

SUMP

SCARFER

HSE. #2

HOT SCARFER

PIT

SETTLING BASIN

HOLDING TANK

MAIN BACKWASH

SETTLING TANKSEVEN

SAND

FILTERS

30" ROUGHING MILL

SETTLING BASIN

CANTEEN

UNIT 2

SUB

STATION

7Q

COMPRESSOR

HO.

RE-HEATING

FURNACE BLDG.

CONTROL STA. #5

SHEAR BLDG.

COVERED RUNWAY

MILL PIT OFFICE

L O A D I N G D O C K

BILLET

STORAGE

G.T.C.

WAREHOUSE

LADLE HOUSE

THEISEN

DISINTEGRATOR

BUILDING

DISINTEGRATOR SUBSTATION

6-H-4 (2-TRANSFORMERS)

LOCA

MOT

IVE

& CR

ANE

REPA

IR SH

OP

ENVIRONMENTAL

BUILDING

P O W E R H O U S E N O . 1

SUBSTATION 7F

(3-TRANSFORMERS)STEAM STATION NO. 1

BOILER HOUSE

NO. 3

BLOWING ENGINE HOUSE NO. 3

SPRAY BOOTH FOG PROTECTION

OIL & ELECTRIC ROOM (BASEMENT)

FMR. COLD WELL

(FILLED IN)

FMR. HOT W

ELL

(FILLED IN)

CONCRETE DIKE

3' ABOVE/BELOW

GROUND SURFACE

AIR CONDITIONING EQUIP. SHOP

SUB. 8U1

WQCS #

9

BPP-26BPP-24

BPP-22

BPP-05R

RW-H


STEAM STATION NO. 1

BOILER HOUSE

NO. 3

ARTMEIERCOMMODITYSUPPLY(±3.34 AC)

SOUTH RETURN WATER TRENCH

FUHRMANN BLVD.

CO

CO-2

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FMFM FM

FMFM

FM

FMFM

FMFM

FMFM

FMFM

FM

FM

FM

FM

FM

RW

RWS-2

RWRWS-6

RWRWS-7

RWRWS-11

FM

FM

FM

FM

RW-FRW-H

OU4PZ-14

HIGHWAY 2

HIGHWAY 7

HIGHWAY 7

HIGHW

AY 1

HIGHWAY 7ES1-3ABAONDONED - 05/14/98

ES1-4ABANDONED - 05/14/98


G A T E W A Y M E T R O P O R T S H I P C A N A L

P-1A-M P-1B

-S

P-1B-D

P-1A-S

P-44S(destroyed)

MWN-70A

RW-HRW-F

MWN-27B

MW-08B

MW-15A

MW-14A

MW-17A

MWN-27A

MWN-27C

MWN-30A

MW-08A

MWN-45A

MWN-46A

MWN-48A

MWN-55A

MWN-54A

MWN-53A

MWN-47A

B-2

B-1(destroyed)

ES1-2(destroyed)

MWN-71A

MWN-69A

GATEWAY TRADECENTER (G.T.C.)

B-3(destroyed)

MWN-64A

P-45SDECOMMISSIONED

MW-16ADECOMMISSIONED

0'

SCALE IN FEET(approximate)

250' 250' 500'

SCALE: 1 INCH = 500 FEET

JOB

NO

.:T E RURN

nvironmental

esto

ration,EY

KLL

C

FIGURE 2

TEC

UM

SEH

RED

EVEL

OPM

ENT

INC

.

PHAS

E IA

BU

SIN

ESS

PAR

K AR

EALA

CKA

WAN

NA,

NEW

YO

RK

REM

EDIA

L IN

VEST

IGAT

ION

ALT

ERN

ATIV

ES A

NAL

YSIS

REP

OR

TSI

TE P

LAN

0071

-010

-350

N

F:\C

AD\T

urnK

ey\T

ecum

seh

Rede

velo

pmen

t\Br

ownf

ield

Cle

anup

Pro

gram

(BCP

)\Pha

se IA

Par

cel\R

I_AAR

Rep

ort\

Figu

re 2

; Site

Pla

n.dw

g, 9

/1/2

020

1:58

:36

PM

AutoCAD SHX Text

DRAFTED BY:

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

PREPARED FOR

AutoCAD SHX Text

SUITE 300

AutoCAD SHX Text

BUFFALO, NY 14218

AutoCAD SHX Text

2558 HAMBURG TURNPIKE

AutoCAD SHX Text

(716) 856-0635

AutoCAD SHX Text

SEPTEMBER 2020

AutoCAD SHX Text

RFL

LEGEND:



NOTES:

PHASE IA BPA TEST PIT (17)BPIA-TP-3

EXISTING OFF-SITE MONITORING WELL

PHASE IA BPA SURFACE SOIL SAMPLE (12)BP1A-SS-04

B-2



UTILITY POLE




PHASE IA BPA SURFACE SOIL SAMPLE [APRIL 2007] (3)BP1A-SS-01


B-1(destroyed)


BP1A-B-01 PHASE IA BPA BORING LOCATION (1)

HIGHWAY 8

T I M E S

S Q U A R E

SIGN

GATE



BP3-B-01

E A S T H A R B O R L E A D

1200 GALLON


STATION

ROLL SHOP

GANTRY CRANE

PIPE SHOP

WELDING

PLATE SHOP

OPEN HEARTH NO. 2


40' GANTRY CRANE

SCALE

HOUSE

OIL

HOUSE

OFFICE

TOOL

SHED

THAW SHED

OFFICELOCKERS


CLAY

PUMP

HOUSESWITCH HO.

1-TRANSFORMER

ACETYLENE &

OXYGEN STORAGE

SUBSTA.

COVERED MOULD YARD


MACHINE SHOP

GARAGE

MASTER MECHANIC

OFFICE

2,500 GAL.

FUEL OIL TANK

(3' concrete w

all)

RAILROAD YARD

FOUNDRY

WELFARE BUILDING

OIL &

LOCKER

HOUSE

STRIPPER BUILDING

NO. 2

25,000 GAL

FUEL OIL TANK


)

PITCH TANK


below groun

d)PUMP HOUSE

PITCH PUMP HOUSE

SUBSTATION


DUST COLLECTION

SILO


40" MILL


SUBSTATION

(3 TRANS.)

COVERED BILLET

YARD

36" ROUGHING

MILL MOTOR ROOM


E32"

FINISHING

MILL MOTOR

ROOM

H O

T

B

E D

S



32" R A I L

M I L L

BUNG

FURNACE

BUILDING

CRANEWAYBILLET

YARD

MILLWRIGHT

SHOP & OFF.

WELFARE BUILDING

WEL

FARE

BUILD

ING

30" MILL

COOLING

BEDS

CRANEWAY

NO. 1

SETTLING BASIN


C E N T R A L B I L L E T

Y A R D



ACID TANK

(elevated 15'

on steel legs

)

TRACK

HOPPER

SKIP HOIST

HOUSE

ASH

HOPPER

E X H A U S T S T A C K S 7 3 '

WELFARE BLDG.

6,800 GAL.

QUENCH OIL

TANK



FUEL OIL TANK


27282930

31

SKIP HOIST HO.

VALVE HOS.

VALVE HO.

MAIN

VALVE HO.

INTAKE SUMP TUNNEL


PICKELING

VATS

GAS BOOSTER HOUSE


2ND - SWITCH ROOM

MILLWRIGHTS &

ELECT. OFF./SHOP

SUMP

40" BLOOMING

MILL MOTOR ROOM

44" MILL


44" BLOOMING MILL



BAROMETRIC

CONDENSER COLD WELL


ow lake level)



FEEDER STATION

LIGHT OIL

RECOVERY PLANTSWITCH HOUSEGAS HOLDER

PUMP HOUSE


FILTER

HOUSE

MACHINERY

HOUSE

GAS MIXING HO.


SUBSTATION

FMR. 19,900

GAL FUEL OIL AST

STEAM STATION NO. 3

COAL & SAND BIN

SCALE

AIR BLOWER &

GAS BOOSTER HOUSE

30" ROUGHING MILL

MOTOR ROOM

GAS MIXING STATION

AIR SAMPLER



MOTOR ROOM

SCALE PIT

HOT SCARFER

PIT

SETTLING BASIN

SETTLING BASIN


SUBSTATION

40" BLOOMING MILL

HOT SCARFERPIT

SETTTLING BASIN

SUMP

SCARFER

HSE. #2

HOT SCARFER

PIT

SETTLING BASIN

MAIN BACKWASH

SETTLING TANKSEVEN

SAND

FILTERS

30" ROUGHING MILL

SETTLING BASIN

CANTEEN

UNIT 2

SUB

STATION

7Q

COMPRESSOR

HO.

RE-HEATING

FURNACE BLDG.

CONTROL STA. #5

SHEAR BLDG.

COVERED RUNWAY

MILL PIT OFFICE


BILLET

STORAGE

G.T.C.

WAREHOUSE

LADLE HOUSE

THEISEN

DISINTEGRATOR

BUILDING



LOCA

MOT

IVE

& CR

ANE

REPA

IR SH

OP

ENVIRONMENTAL

BUILDING


SUBSTATION 7F


BOILER HOUSE

NO. 3




FMR. COLD WELL

(FILLED IN)

FMR. HOT W

ELL

(FILLED IN)

CONCRETE DIKE

3' ABOVE/BELOW

GROUND SURFACE


SUB. 8U1

WQCS #

9

BPP-26BPP-24

BPP-22

BPP-05R

RW-H


STEAM STATION NO. 1

BOILER HOUSE

NO. 3



CO

CO-2

FMFM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FMFM FM

FMFM

FMFM

FMFM

FM

FM

FM

FM

FM

FMFM

FMFM

FMFM

FMFM

FMFM

FMFM

FM

FM

FM

FM

FM

FM

FM

FMFM

FM

RW

RWS-2

RWRWS-6

RWRWS-7

RWRWS-11

FM

FM

FM

FM

FM

FM

FM

RW-H

OU4PZ-14

HIGHWAY 2

HIGHWAY 7

HIGHWAY 7

HIGHW

AY 1





P-1A-M P-1B

-S

P-1B-D

P-1A-S

P-44S(destroyed)

P-45S

DECOMMISSIONED

BPIA-TP-3

BPIA-TP-4

BPIA-TP-5

BPIA-TP-6

BPIA-TP-7

BPIA-TP-10TAR-LIKE MATERIAL @ 1FTBGS

MOTHBALL LIKE ODORPID READING OF 44PPM

MWN-70A575.7

BPIA-TP-15

BPIA-TP-17

RW-HRW-F

MWN-27B

MW-08B

MW-15A

MW-14A

MW-17A

MW-16A

DECOMMISSIONED

MWN-27A

MWN-27C

MWN-30A

MW-08A

MWN-45A

MWN-46A

MWN-48A

MWN-55A

MWN-54A

MWN-53A

MWN-47A

BP1A-SS-03

BP1A-SS-11

B-2

B-1(destroyed)

ES1-2(destroyed)

BP1A-SS-04

BP1A-SS-05BP1A-SS-06 BP1A-SS-07

BP1A-SS-08

BP1A-SS-09

BP1A-SS-10

BPIA-TP-8

BPIA-TP-12

BPIA-TP-11PETROLEUM-LIKE MATERIAL @ 1FTBGS

STRONG MOTHBALL LIKE ODORBPIA-TP-13

BPIA-TP-14

BPIA-TP-16

BP1A-SS-02

BP1A-SS-01

BP1A-SS-13

BP1A-SS-12

MWN-69A

BPIA-TP-1

BPIA-TP-2


B-3(destroyed)

MWN-64A

BPIA-TP-9STRONG PETROLEUM-LIKE ODOR

FLOATING PRODUCTPID READING OF 49PPMGROUNDWATER 6FBGS

SUPPLEMENTALTEST PITS


BP1A-B-01

FOOTER FOUNDATION EXCAVATIONBLACK TAR-LIKE MATERIAL

20'X30' COMPLETED JAN. 2013

24" Ø DRAINAGECULVERT INSTALLED


MWN-71A

BP1A-SS-15BP1A-SS-14

NOTES:


PHASE IA BPA BORING LOCATION (1)

0'


120' 120' 240'


NO

.BY

DAT

E

REV

ISIO

NS

REM

ARKS

JOB

NO

.:

esto

ration,

nvironmental

URN

T REEY

KLL

C

FIGURE 3

RI S

AM

PLE

LOC

ATI

ON

SR

EMED

IAL

INVE

STIG

ATIO

N/A

LTER

NAT

IVES

AN

ALYS

IS R

EPO

RT

LAC

KAW

ANN

A, N

EW Y

OR

K

PHAS

E IA

BU

SIN

ESS

PAR

K AR

EA

TEC

UM

SEH

RED

EVEL

OPM

ENT

INC

.00

71-0

10-3

50

N

F:\C

AD\T

urnK

ey\T

ecum

seh

Rede

velo

pmen

t\Br

ownf

ield

Cle

anup

Pro

gram

(BCP

)\Pha

se IA

Par

cel\R

I_AAR

Rep

ort\

Figu

re 3

; RI S

ampl

e Lo

catio

nsRE

V.dw

g, 9

/1/2

020

2:32

:29

PM

AutoCAD SHX Text

PREPARED FOR

AutoCAD SHX Text

DRAWN BY:

AutoCAD SHX Text

CHECKED BY:

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

DISCLAIMER: PROPERTY OF BENCHMARK EES, PLLC. IMPORTANT: THIS DRAWING PRINT IS LOANED FOR MUTUAL ASSISTANCE AND AS SUCH IS SUBJECT TO RECALL AT ANY TIME. INFORMATION CONTAINED HEREON IS NOT TO BE DISCLOSED OR REPRODUCED IN ANY FORM FOR THE BENEFIT OF PARTIES OTHER THAN NECESSARY SUBCONTRACTORS & SUPPLIERS WITHOUT THE WRITTEN CONSENT OF BENCHMARK EES, PLLC.

AutoCAD SHX Text

SEAL

AutoCAD SHX Text

APPROVED BY:

AutoCAD SHX Text

LACKAWANNA, NY 14218

AutoCAD SHX Text

(716) 856-0635

AutoCAD SHX Text

SUITE 300

AutoCAD SHX Text


AutoCAD SHX Text

RFL

AutoCAD SHX Text

AUGUST 2020

LEGEND:

TECUMSEH PROPERTY BOUNDARY EXISTING OFF-SITE MONITORING WELL WITH GROUNDWATER ELEVATIONMWN-16A, B-2578.2

PHASE IA PARCEL BOUNDARY (see Note 1)

PHASE IA MONITORING WELL (3) WITH GROUNDWATER ELEVATIONMWN-69A576.3

UTILITY POLE

EXISTING BUILDING / STRUCTURE

EXISTING OFF-SITE PIEZOMETER WITH GROUNDWATER ELEVATIONP-45S578.8

GROUNDWATER ELEVATION CONTOUR (DASHED WHERE INFERRED)

GROUNDWATER FLOW DIRECTION

NOTES:

1. The North and South Return Water Trenches are excluded from the Phase IA Business Park site.2. The groundwater contours shown were developed using linear interpolation between groundwater well

water elevations, results of previous groundwater contour maps, and engineering judgement.3. The bottom of the North and South Return Water Trenches are at approximate elevation of 570 feet. It

is believed that when the groundwater elevation proximate to the trenches is above 570 feet, thetrenches are groundwater sinks.

577

T I M E SS Q U A R E

N O R T H R E T U R N W A T E R T R E N C H N O R T H R E T U R N W A T E R T R E N C H ( B E L O W G R A D E )


HIGHWAY 2

HIGHWAY 7

HIGHWAY 7

HIGHWAY 1

HIGHWAY 7


PHASE I BUSINESS PARK

578

579

580

577

576

578577576

P-45S578.8

MWN-70A575.7

MW-15A580.2

MW-14A579.9

MW-17A578.0

MW-16A578.2

B-2577.9

MWN-71A

576.1MWN-69A576.3

MWN-64A576.5

0'


300' 300' 600'


N

JOB

NO

.:T E RURN

nvironmental

esto

ration,EY

KLL

C

DIS

CLA

IME

R:

PR

OP

ER

TY O

F TU

RN

KE

Y E

NV

IRO

NM

EN

TAL

RE

STO

RA

TIO

N,

LLC

. I

MP

OR

TAN

T: T

HIS

DR

AW

ING

PR

INT

IS

LO

AN

ED

FO

R M

UTU

AL

AS

SIS

TAN

CE

AN

D A

S S

UC

H I

S S

UB

JEC

T T

O R

EC

ALL

AT

AN

Y T

IME

. I

NFO

RM

ATI

ON

CO

NTA

INE

D H

ER

EO

N I

S N

OT

TO

BE

DIS

CLO

SE

D O

R R

EP

RO

DU

CE

D IN

AN

Y F

OR

M F

OR

TH

E B

EN

EFI

T O

F P

AR

TIE

S O

THE

R T

HA

N N

EC

ES

SA

RY

SU

BC

ON

TRA

CTO

RS

& S

UP

PLI

ER

S W

ITH

OU

T TH

E W

RIT

TEN

CO

NS

EN

T O

F TU

RN

KE

Y E

NV

IRO

NM

EN

TAL

RE

STO

RA

TIO

N, L

LC.

FIGURE 4A

TEC

UM

SEH

RED

EVEL

OPM

ENT

INC

.

PHAS

E IA

BU

SIN

ESS

PAR

KLA

CKA

WAN

NA,

NEW

YO

RK

REM

EDIA

L IN

VEST

IGAT

ION

/ALT

ERN

ATIV

ES A

NAL

YSIS

REP

OR

TIS

OPO

TEN

TIA

L M

AP

- 2/8

/11

0071

-010

-350

F:\C

AD\T

urnK

ey\T

ecum

seh

Rede

velo

pmen

t\Br

ownf

ield

Cle

anup

Pro

gram

(BCP

)\Pha

se IA

Par

cel\R

I_AAR

Rep

ort\

Figu

re 4

A; Is

opot

entia

l Map

- Fe

b 20

11.d

wg,

9/1

/202

0 1:

49:3

1 PM

AutoCAD SHX Text

DRAFTED BY:

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

PREPARED FOR

AutoCAD SHX Text

SUITE 300

AutoCAD SHX Text

BUFFALO, NY 14218

AutoCAD SHX Text


AutoCAD SHX Text

(716) 856-0635

AutoCAD SHX Text

MARCH 2017

AutoCAD SHX Text

RFL

LEGEND:

TECUMSEH PROPERTY BOUNDARY EXISTING OFF-SITE MONITORING WELL WITH GROUNDWATER ELEVATIONB-2578.2

PHASE IA PARCEL BOUNDARY (see Note 1)

PHASE IA MONITORING WELL (3) WITH GROUNDWATER ELEVATIONMWN-69A576.3

UTILITY POLE

EXISTING BUILDING / STRUCTURE


GROUNDWATER ELEVATION CONTOUR (DASHED WHERE INFERRED)

GROUNDWATER FLOW DIRECTION

NOTES:

1. The North and South Return Water Trenches are excluded from the Phase IA Business Park site.2. The groundwater contours shown were developed using linear interpolation between groundwater well

water elevations, results of previous groundwater contour maps, and engineering judgement.3. The bottom of the North and South Return Water Trenches are at approximate elevation of 570 feet. It

is believed that when the groundwater elevation proximate to the trenches is above 570 feet, thetrenches are groundwater sinks.

4. Well MW-16A and piezometers B-2 and P-45S were decommissioned on September 25, 2012 as partof a separate railroad expansion project.

577

T I M E SS Q U A R E

N O R T H R E T U R N W A T E R T R E N C H N O R T H R E T U R N W A T E R T R E N C H ( B E L O W G R A D E )


HIGHWAY 2

HIGHWAY 7

HIGHWAY 7

HIGHWAY 1

HIGHWAY 7


PHASE I BUSINESS PARK

577578

582

581580

579

576

P-45S(decommissioned)

MWN-70A

576.4

MW-15A582.0

MW-14A580.8

MW-17A578.4

MW-16A(decommissioned)

B-2(decommissioned)

MWN-71A(damaged)

MWN-69A576.5MWN-64A

577.0

0'


300' 300' 600'


JOB

NO

.:T E RURN

nvironmental

esto

ration,EY

KLL

C

DIS

CLA

IME

R:

PR

OP

ER

TY O

F TU

RN

KE

Y E

NV

IRO

NM

EN

TAL

RE

STO

RA

TIO

N,

LLC

. I

MP

OR

TAN

T: T

HIS

DR

AW

ING

PR

INT

IS

LO

AN

ED

FO

R M

UTU

AL

AS

SIS

TAN

CE

AN

D A

S S

UC

H I

S S

UB

JEC

T T

O R

EC

ALL

AT

AN

Y T

IME

. I

NFO

RM

ATI

ON

CO

NTA

INE

D H

ER

EO

N I

S N

OT

TO

BE

DIS

CLO

SE

D O

R R

EP

RO

DU

CE

D IN

AN

Y F

OR

M F

OR

TH

E B

EN

EFI

T O

F P

AR

TIE

S O

THE

R T

HA

N N

EC

ES

SA

RY

SU

BC

ON

TRA

CTO

RS

& S

UP

PLI

ER

S W

ITH

OU

T TH

E W

RIT

TEN

CO

NS

EN

T O

F TU

RN

KE

Y E

NV

IRO

NM

EN

TAL

RE

STO

RA

TIO

N, L

LC.

FIGURE 4B

TEC

UM

SEH

RED

EVEL

OPM

ENT

INC

.

PHAS

E IA

BU

SIN

ESS

PAR

KLA

CKA

WAN

NA,

NEW

YO

RK

REM

EDIA

L IN

VEST

IGAT

ION

/ALT

ERN

ATIV

ES A

NAL

YSIS

REP

OR

TIS

OPO

TEN

TIA

L M

AP

- 2/2

3/16

0071

-010

-350

N

F:\C

AD\T

urnK

ey\T

ecum

seh

Rede

velo

pmen

t\Br

ownf

ield

Cle

anup

Pro

gram

(BCP

)\Pha

se IA

Par

cel\R

I_AAR

Rep

ort\

Figu

re 4

B; Is

opot

entia

l Map

- Fe

b 20

16.d

wg,

9/1

/202

0 2:

34:0

7 PM

AutoCAD SHX Text

DRAFTED BY:

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

PREPARED FOR

AutoCAD SHX Text

SUITE 300

AutoCAD SHX Text

BUFFALO, NY 14218

AutoCAD SHX Text


AutoCAD SHX Text

(716) 856-0635

AutoCAD SHX Text

MARCH 2017

AutoCAD SHX Text

RFL

LEGEND:



NOTES:


PHASE IA BPA TEST PIT (17)BPIA-TP-3

EXISTING OFF-SITE MONITORING WELL

PHASE IA BPA SURFACE SOIL SAMPLE (12)

B-2



UTILITY POLE




PHASE IA BPA SOIL/FILL HOTSPOT AREA

BP1A-SS-01


B-1(destroyed)


PHASE IA SURFACE SOIL SAMPLE (3)

BP1A-SS-04

HIGHWAY 8

T I M E S

S Q U A R E

SIGN

GATE


BP1A-B-01


BP3-B-01

1200 GALLON


STATION

ROLL SHOP

GANTRY CRANE

PIPE SHOP

WELDING

PLATE SHOP

OPEN HEARTH NO. 2


40' GANTRY CRANE

SCALE

HOUSE

OIL

HOUSE

OFFICE

TOOL

SHED

THAW SHED

OFFICELOCKERS


CLAY

PUMP

HOUSESWITCH HO.

1-TRANSFORMER

ACETYLENE &

OXYGEN STORAGE

SUBSTA.

COVERED MOULD YARD


MACHINE SHOP

GARAGE

MASTER MECHANIC

OFFICE

2,500 GAL.

FUEL OIL TANK

(3' concrete w

all)

RAILROAD YARD

FOUNDRY

WELFARE BUILDING

OIL &

LOCKER

HOUSE

STRIPPER BUILDING

NO. 2

25,000 GAL

FUEL OIL TANK


)

PITCH TANK


below groun

d)PUMP HOUSE

PITCH PUMP HOUSE

SUBSTATION


DUST COLLECTION

SILO


40" MILL


SUBSTATION

(3 TRANS.)

COVERED BILLET

YARD

36" ROUGHING

MILL MOTOR ROOM


E32"

FINISHING

MILL MOTOR

ROOM

H O

T

B

E D

S



32" R A I L

M I L L

BUNG

FURNACE

BUILDING

CRANEWAYBILLET

YARD

MILLWRIGHT

SHOP & OFF.

WELFARE BUILDING

WEL

FARE

BUILD

ING

30" MILL

COOLING

BEDS

CRANEWAY

NO. 1

SETTLING BASIN


C E N T R A L B I L L E T

Y A R D



ACID TANK

(elevated 15'

on steel legs

)

TRACK

HOPPER

SKIP HOIST

HOUSE

ASH

HOPPER

E X H A U S T S T A C K S 7 3 '

WELFARE BLDG.

6,800 GAL.

QUENCH OIL

TANK



FUEL OIL TANK


27282930

31

SKIP HOIST HO.

VALVE HOS.

VALVE HO.

MAIN

VALVE HO.

INTAKE SUMP TUNNEL


PICKELING

VATS

GAS BOOSTER HOUSE


2ND - SWITCH ROOM

MILLWRIGHTS &

ELECT. OFF./SHOP

SUMP

40" BLOOMING

MILL MOTOR ROOM

44" MILL


44" BLOOMING MILL



BAROMETRIC

CONDENSER COLD WELL


ow lake level)



FEEDER STATION

LIGHT OIL

RECOVERY PLANTSWITCH HOUSEGAS HOLDER

PUMP HOUSE


FILTER

HOUSE

MACHINERY

HOUSE

GAS MIXING HO.


SUBSTATION

FMR. 19,900

GAL FUEL OIL AST

STEAM STATION NO. 3

COAL & SAND BIN

SCALE

AIR BLOWER &

GAS BOOSTER HOUSE

30" ROUGHING MILL

MOTOR ROOM

GAS MIXING STATION

AIR SAMPLER



MOTOR ROOM

SCALE PIT

HOT SCARFER

PIT

SETTLING BASIN

SETTLING BASIN


SUBSTATION

40" BLOOMING MILL

HOT SCARFERPIT

SETTTLING BASIN

SUMP

SCARFER

HSE. #2

HOT SCARFER

PIT

SETTLING BASIN

MAIN BACKWASH

SETTLING TANKSEVEN

SAND

FILTERS

30" ROUGHING MILL

SETTLING BASIN

CANTEEN

UNIT 2

SUB

STATION

7Q

COMPRESSOR

HO.

RE-HEATING

FURNACE BLDG.

CONTROL STA. #5

SHEAR BLDG.

COVERED RUNWAY

MILL PIT OFFICE


BILLET

STORAGE

G.T.C.

WAREHOUSE

LADLE HOUSE

THEISEN

DISINTEGRATOR

BUILDING



LOCA

MOT

IVE

& CR

ANE

REPA

IR SH

OP

ENVIRONMENTAL

BUILDING


SUBSTATION 7F


BOILER HOUSE

NO. 3




FMR. COLD WELL

(FILLED IN)

FMR. HOT W

ELL

(FILLED IN)

CONCRETE DIKE

3' ABOVE/BELOW

GROUND SURFACE


SUB. 8U1

WQCS #

9

BPP-26BPP-24

BPP-22

BPP-05R

RW-H


STEAM STATION NO. 1

BOILER HOUSE

NO. 3



CO

CO-2

FMFM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FM

FMFM FM

FMFM

FMFM

FMFM

FM

FM

FM

FM

FM

FMFM

FMFM

FMFM

FMFM

FMFM

FMFM

FM

FM

FM

FM

FM

FM

FM

FMFM

FM

RW

RWS-2

RWRWS-6

RWRWS-7

RWRWS-11

FM

FM

FM

FM

FM

FM

FM

RW-H

OU4PZ-14

HIGHWAY 2

HIGHWAY 7

HIGHWAY 7

HIGHW

AY 1





P-1A-M P-1B

-S

P-1B-D

P-1A-S

P-44S(destroyed)

P-45S

BPIA-TP-3

BPIA-TP-4

BPIA-TP-5

BPIA-TP-6

BPIA-TP-7

BPIA-TP-10TAR-LIKE MATERIAL @ 1FTBGS

MOTHBALL LIKE ODORPID READING OF 44PPM

BPIA-TP-15

BPIA-TP-17

RW-HRW-F

MWN-27B

MW-08B

MW-15A

MW-14A

MW-17A

MWN-27A

MWN-27C

MWN-30A

MW-08A

MWN-45A

MWN-46A

MWN-48A

MWN-55A

MWN-54A

MWN-53A

MWN-47A

BP1A-SS-03

B-2

B-1(destroyed)

ES1-2(destroyed)

BPIA-TP-8

BPIA-TP-12

BPIA-TP-11PETROLEUM-LIKE MATERIAL @ 1FTBGS

STRONG MOTHBALL LIKE ODORBPIA-TP-13

BPIA-TP-14

BPIA-TP-16

BP1A-SS-02

BP1A-SS-01

BPIA-TP-1

BPIA-TP-2


B-3(destroyed)

MWN-64A

BPIA-TP-9STRONG PETROLEUM-LIKE ODOR

FLOATING PRODUCTPID READING OF 49PPMGROUNDWATER 6FBGS

SUPPLEMENTAL TEST PITS


P-45SDECOMMISSIONED

MW-16A

DECOMMISSIONED



MWN-70A

BP1A-SS-11

BP1A-SS-04

BP1A-SS-05BP1A-SS-06 BP1A-SS-07

BP1A-SS-08

BP1A-SS-09

BP1A-SS-10

MWN-71A

BP1A-SS-13

BP1A-SS-12BP1A-SS-15

BP1A-SS-14

MWN-69A

HOTSPOT A

HOTSPOT B

HOTSPOT C

HOTSPOT D

HOTSPOT EHOTSPOT F

HOTSPOT G

HOTSPOT H

0'


120' 120' 240'


NO

.BY

DAT

E

REV

ISIO

NS

REM

ARKS

JOB

NO

.:

esto

ration,

nvironmental

URN

T REEY

KLL

C

FIGURE 5

SOIL

/FIL

L H

OTS

POT

AR

EAS

TO B

E EX

CA

VATE

DR

EMED

IAL

INVE

STIG

ATIO

N/A

LTER

NAT

IVES

AN

ALYS

IS R

EPO

RT

LAC

KAW

ANN

A, N

EW Y

OR

K

PHAS

E IA

BU

SIN

ESS

PAR

K AR

EA

TEC

UM

SEH

RED

EVEL

OPM

ENT

INC

.00

71-0

20-4

00

F:\C

AD\T

urnK

ey\T

ecum

seh

Rede

velo

pmen

t\Br

ownf

ield

Cle

anup

Pro

gram

(BCP

)\Pha

se IA

Par

cel\R

I_AAR

Rep

ort\

Figu

re 5

; soi

l-fill

hot

spot

are

as.d

wg,

9/1

/202

0 2:

29:3

0 PM

AutoCAD SHX Text

PREPARED FOR

AutoCAD SHX Text

DRAWN BY:

AutoCAD SHX Text

CHECKED BY:

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

DISCLAIMER: PROPERTY OF BENCHMARK EES, PLLC. IMPORTANT: THIS DRAWING PRINT IS LOANED FOR MUTUAL ASSISTANCE AND AS SUCH IS SUBJECT TO RECALL AT ANY TIME. INFORMATION CONTAINED HEREON IS NOT TO BE DISCLOSED OR REPRODUCED IN ANY FORM FOR THE BENEFIT OF PARTIES OTHER THAN NECESSARY SUBCONTRACTORS & SUPPLIERS WITHOUT THE WRITTEN CONSENT OF BENCHMARK EES, PLLC.

AutoCAD SHX Text

SEAL

AutoCAD SHX Text

APPROVED BY:

AutoCAD SHX Text

LACKAWANNA, NY 14218

AutoCAD SHX Text

(716) 856-0635

AutoCAD SHX Text

SUITE 300

AutoCAD SHX Text


AutoCAD SHX Text

RFL

AutoCAD SHX Text

AUGUST 2020


0071-010-350

APPENDIX A

PREVIOUS INVESTIGATIONS ANALYTICAL DATA PACKAGES (INCLUDED ON CD)


0071-010-350

APPENDIX A-1

CORRECTIVE MEASURES STUDY: NRWT AND SRWT (INCLUDED ON CD)


0071-010-350

APPENDIX A-2

APRIL 2007 SAMPLING EVENT (INCLUDED ON CD)


0071-010-350

APPENDIX A-3

AUGUST 2007 SITE-WIDE ASBESTOS ABATEMENT CLOSEOUT REPORT

(INCLUDED ON CD)


0071-010-350

APPENDIX B

RI ANALYTICAL DATA PACKAGES (INCLUDED ON CD)


0071-010-350

APPENDIX C

TEST PIT LOGS, FIELD NOTES, BORING LOGS, AND MONITORING WELL CONSTRUCTION DETAILS


0071-010-350

APPENDIX D

GROUNDWATER WELL SAMPLING LOGS


0071-010-350

APPENDIX E

DATA USABILITY SUMMARY REPORT (DUSR) (INCLUDED ON CD)


0071-010-350

APPENDIX F

FISH AND WILDLIFE RESOURCE IMPACT ANALYSIS CHECKLIST


0071-010-350

APPENDIX G

95% UPPER CONFIDENCE LIMIT CALCULATIONS


0071-010-350

APPENDIX H

LAND USE EVALUATION

Documents

REMEDIAL INVESTIGATION/ ALTERNATIVES ANALYSIS …