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FMC Corporation Middleport, New York

Corrective Measures Study Soil Tilling/Blending Pilot Study Work Plan October 2009

Corrective Measures Study Soil Tilling/Blending Pilot Study Work Plan FMC Corporation Middleport, New York

Prepared for:

FMC Corporation

Prepared by:

ARCADIS 6723 Towpath Road P.O. Box 66 Syracuse New York 13214-0066 Tel 315.446.9120 Fax 315.449.0017

Our Ref.:

B0037736

Date:

October 2009

G:\Project Docs\Div20\lryfun - 11222\LAR09\FMC Middleport\Soil Mixing\230911222_plan.doc


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Table of Contents

1. Introduction 1

2. Background 1

3. Pilot Study Objectives 2

4. Soil Tilling/Blending Does Not Constitute Unacceptable Dilution 3

5. Scope of Work 4

5.1 Task 1 – Securing Property Access 4

5.2 Task 2 – Pilot Study Implementation 4

5.3 Task 3 – Pre- and Post-Tilling/Blending Soil Sampling 5

5.4 Task 4 – Pilot Study Report 6

6. Schedule 7

Figures

1 Facility Location and Pilot Study Locations Map

2 Property AD1 Soil Tilling/Blending Plots

3 Agricultural Field (AF) Soil Tilling/Blending Plot

Appendices

A Relevant Documents on Soil Tilling/Blending to Address Arsenic in Soil

B Existing Soil Arsenic Concentration Data at Study Sites

C Summary of Community Air Monitoring Plan Requirements

D Description of Soil Tilling/Blending Mixing Approaches

E Mixing Head Equipment Information



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1. Introduction

This Corrective Measures Study Soil Tilling/Blending Pilot Study Work Plan (Work Plan) has been prepared on behalf of FMC Corporation (FMC) to obtain information needed to evaluate the effectiveness and feasibility of soil tilling/blending as a corrective measures alternative or part of an alternative to address soil with elevated arsenic levels in FMC study areas in Middleport, New York. Figure 1 illustrates the location of the FMC Plant Site (Site or Facility) and proposed pilot study sites (Study Sites). The pilot study will be performed under the terms and conditions of the 1991 Administrative Order on Consent, Docket No. II RCRA-90-3008(h)-0209, entered into by FMC, the New York State Department of Environmental Conservation (NYSDEC) and the United States Environmental Protection Agency (USEPA) (collectively, the latter two entities are referred to herein as “Agencies”). This work plan includes background information on soil tilling/blending, a description of the study objectives, detailed scope of work for the pilot study, and schedule.

2. Background

FMC is performing a Corrective Measures Study (CMS) for the Suspected Air Deposition and Culvert 105 Study Areas to address soil impacted by FMC-related constituents (predominantly arsenic). One of the corrective measures alternatives or part of an alternative proposed for evaluation in the CMS is the use of soil tilling/blending to achieve lower arsenic soil levels and to recycle and preserve land/soil.

Soil tilling/blending involves the physical mixing of existing soils within the area of concern to achieve an acceptable area wide arsenic concentration in soil. Equipment used in the construction and agriculture industries can be used for soil tilling/blending and various contractors provide this service. The applicability of the technology and equipment is dependent on physical constraints of the area to be addressed (e.g., access, size of area and presence of obstructions), the distribution of the contaminant soil concentrations, and the ability to effectively mix the soils to achieve the desired arsenic concentrations.

Arsenic concentrations in soil can vary significantly within the boundaries of each property. For properties with soils exhibiting generally low concentrations with less frequent instances of more elevated concentrations, or where most of the arsenic concentration is within the upper few inches of soil, tilling or blending may enable the overall soil arsenic concentrations to achieve acceptable levels while avoiding unnecessary generation of remediation wastes and conserving soil (by minimizing the need to import large quantities of soil from a borrow source, which occurs as part of a “dig and haul” remedy). Soil mixing has been used in conjunction with other treatment



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technologies (e.g., landfarming/bioremediation, soil stabilization) to address soil contamination at other sites. In fact, soil tilling/blending has been endorsed by the following Regulators to address pesticide contamination through written guidance as noted below:

• New Jersey Department of Environmental Protection - Findings and Recommendations for the Remediation of Historic Pesticide Contamination (NJDEP, March 1999)

• Pennsylvania Department of Environmental Protection -Addressing pesticide Contamination on Agricultural Land Proposed for Development (PADEP, April 2005)

• Monroe County (NY) Department of Health - Protocol for Characterizing Potential Chemical Contamination in Proposed Realty Subdivisions (MCDOH, July 1995)

Appendix A includes reprinted sections of these documents from the respective regulatory agencies (and website addresses for the documents) that provide information on the use of soil till/blending to address arsenic in soil. These documentations are attached to provide information on the application of soil tilling/blending as an accepted remedial technology to address arsenic in soils.

3. Pilot Study Objectives

The primary objective of the pilot study is to provide site-specific information concerning the implementability and effectiveness of the various soil tilling/blending techniques/methods for possible inclusion in the Corrective Measures Study (CMS).

The effectiveness of remedial techniques being tested will be based on their ability to achieve concentrations of arsenic in soil that meet corrective action objectives as measured by the sampling task described below. Implementability of remedial techniques being tested will be based on the ability of the equipment to access the areas and complete the pilot study. The pilot study will address the following study questions:

1. What pre-existing distributions and concentrations of arsenic in the soil are appropriate for use of tilling or blending?

2. What level of mechanical effort is required to effectively till or blend the soil?

3. What mechanical equipment is most suitable for tilling or blending the soil?



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4. What depths can the mechanical equipment effectively till/blend soil?

5. What are the effects of tilling or blending on the distributions of arsenic in the soil in the test areas?

6. What conditions (e.g., land use, property configuration, soil type) are appropriate for use of tilling or blending?

7. What are the effects of tilling or blending on the physical characteristics of the soil in the test areas?

Site-specific information and data (e.g., depth of mixing, level of effort required, maximum and average resulting arsenic concentrations, and associated relative costs) which would be obtained during the pilot study will be presented in the Soil Tilling/Blending Pilot Study Report and, as appropriate, will be incorporated into the CMS.

4. Soil Tilling/Blending Does Not Constitute “Unacceptable Dilution”

In comments transmitted by letter dated June 24, 2009 on the draft Corrective Measures Study Work Plan for Suspected Air Deposition and Culvert 105 Study Areas (CMS Work Plan) that FMC submitted on May 15, 2009, the Agencies directed that an eighth question be added to the “study questions” in Section 5.3.2 of the draft CMS Work Plan, relative to evaluation in the pilot study of the effectiveness and feasibility of soil tilling/blending. This eighth question was added and appears in the final CMS Work Plan, as follows: “Does soil tilling or blending constitute unacceptable dilution?” The Agencies’ comments did not include any explanation or citation of authority for the proposition that soil tilling/blending might constitute “unacceptable dilution,” or any discussion of “dilution” or the criteria by which it might be deemed “unacceptable.”

Rather than defer this subject to the pilot study, it is appropriate to address it here. Therefore, presented below is an explanation on why the soil tilling/blending pilot study proposed in this work plan does not constitute “unacceptable dilution.” The information provided below would also apply to the full-scale implementation of soil tilling/blending.

Other regulatory agencies (see Appendix A), including the Monroe County (NY) Department of Health, have recommended or approved soil tilling/blending as a remediation technology to address residual levels of pesticides in agricultural properties that are proposed for residential development. These guidance/regulatory documents do not characterize or refer to tilling/blending as possibly constituting “dilution,” and do not discuss the possibility that it might be “unacceptable” on those grounds. The absence of such references and discussion is warranted. The provisions



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of the RCRA or TSCA PCB regulations that deal with “dilution” (e.g., 40 C.F.R. Section 268.3) pertain to a substitute for treatment under, for example, land disposal restrictions, and would not apply to soil tilling and mixing. Moreover, in the case of the soil tilling/blending pilot study described in this work plan, no soils would be excavated and no additional soils (e.g., from off-site) are proposed to be used as an amendment.

5. Scope of Work

The scope of work for this pilot study consists of four tasks, described below.

5.1 Task 1 – Securing Property Access

The proposed Study Sites identified below have been selected based on a review of the existing soil sampling data for the Study Sites (presented in Appendix B):

Property AD1: The Study Site at Property AD1 is located in an undeveloped, grass-covered field (shown on Figures 1 and 2) to the northeast of the north end of Maedl Lane (which leads north off of Sleeper Street). The Study Site is approximately 200 feet east of the Culvert 105 stormwater drainageway. There will be two approximate 100-foot by 100-foot plots evaluated within this Study Site.

Property AF: The Study Site at Property AF is located within an agricultural field (shown on Figures 1 and 3) to the northeast of the FMC Middleport Facility and adjacent to the southeastern portion of the Royalton-Hartland School property. This is the location of the 2008 phytoremediation pilot study site at Property AF. Because there are ferns still growing within a portion of the phytoremediation pilot study area, the area with ferns will not be part of the soil tilling/blending pilot study. To avoid the ferns and obtain a rectangular-shaped study area, there will be one approximate 30-foot by 75-foot plot evaluated within this Study Site.

The Study Sites, at Properties AD1 and AF, are in undeveloped areas and have relatively flat, open terrain. Written access permission from the respective owners of the Study Sites must be obtained prior to performing any field activities. The pilot study may proceed at one or both of the Study Sites, depending upon access permission.

5.2 Task 2 – Pilot Study Implementation

The following activities will be involved in the field pilot study implementation:

• Survey and stake the Study Sites, remove large brush and/or other vegetation, as needed.



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• Collect pre-tilling/blending soil samples (as described below in Task 3).

• Install sediment erosion control measures consisting of silt fence and/or staked hay bales around the perimeter of the Study Site and establish an adjoining decontamination area.

• Establish air monitoring stations and conduct real-time air sampling for particulates and documentation air sampling for particulates and arsenic in accordance with the Agencies-approved Community Air Monitoring Plan (CAMP) provided in the 2007 Early Actions Work Plan (August 2007), as amended (see Appendix C for a summary of the CAMP requirements).

• Mix soil using the applicable mixing approach (see Appendix D for details).

Study Site Approximate Area

Mixing Approach

Target Mixing Depth (inches below grade)

AD1 North 100’ x 100’ Mixing Head 18 inches

AD1 South 100’ x 100’ Roto-tiller 18 inches

AF 30’ x 75’ Mixing Head 36 inches

• The soil in the plots will be wetted down, as needed, to minimize fugitive dust during the soil mixing.

• Equipment will be decontaminated by removing visible material using dry removal methods in an appropriate area before being taken offsite, and all disposable equipment will be properly disposed offsite.

• Post-tilling/blending soil samples will be collected as part of Pilot Study Task 3.

After completion of soil tilling/blending and collection of post-tilling/blending soil samples, the soil will be compacted and then seeded to promote re-vegetation. Erosion controls will remain in place until vegetation has been re-established (i.e., Spring 2010).

5.3 Task 3 – Pre- and Post-Tilling/Blending Soil Sampling

Pre- and post-tilling/blending soil sampling will be performed as part of this pilot study, as described below. In each pilot study area, the area will be divided into quadrants,



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and discrete pre- and post-mixing soil samples will be collected from the center of each of these quadrants. The pre- and post-mixing sampling depth intervals reflect the sampling depth intervals of the pre-existing data.

Property AD1 North (mixing head): Collect samples from the 0- to 6-inch, 6- to 12-inch and 12- to 18-inch depth intervals from each quadrant, prior to the soil tilling/blending and after the second and fourth passes of the mixing head (12 pre-tilling/blending samples total and 24 post-tilling/blending samples total).

Property AD1 South (roto-tiller): Collect samples from the 0- to 6-inch, 6- to 12-inch and 12- to 18-inch depth intervals from each quadrant, prior to the soil tilling/blending and after the second and fourth iterations of soil turnover (12 pre-tilling/blending samples total and 24 post-tilling/blending samples total).

Property AF: Collect samples from the 0- to 6-inch, 6- to 12-inch, 12- to 18-inch, 18- to 24-inch, 24- to 30-inch and 30- to 36-inch depth intervals from each quadrant, prior to the soil tilling/blending and after the second and fourth passes of the mixing head (24 pre-tilling/blending samples total and 48 post-tilling/blending samples total).

All laboratory analyses will be conducted for arsenic using USEPA SW-846 Method 6010B by a New York State Department of Health (NYSDOH) Environmental Laboratory Accreditation Program (ELAP)-approved laboratory. All laboratory analytical reports will be reported with Category B deliverables and the data will be validated.

In addition to the above sampling and analysis, pre-tilling/blending samples and 1 round of post-tilling/blending samples (collected following completion of the tilling/blending efforts) will be collected from each quadrant from the 0-6-inch depth interval for analysis for total organic content. Samples will be submitted for laboratory analysis for organic content using ASTM Method D 2974-00 (SOP-S8).

5.4 Task 4 – Pilot Study Report

Upon completion of the field pilot study and receipt of the post-tilling/blending sample results, a Soil Tilling/Blending Pilot Study Report will be prepared. The report will document the pilot study activities, present the sampling results, evaluate performance of the mixing technologies, and present conclusions and recommendations (if any) with respect to the study objective. The report will include a comparison of pre- and post-mixing soil arsenic concentrations using tables and figures.



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6. Schedule

The soil tilling/blending pilot study will be implemented following approval of the Work Plan by the Agencies. The following summarizes the schedule for implementing the field pilot study tasks:

• Submit work plan – early October 2009. • Receive Agencies’ approval – late October 2009. • Obtain written access permission from property owners – late October 2009. • Perform field study – November 2009 (weather dependent). • Perform pre- and post-soil tilling/blending soil sampling – November 2009. • Restore plots – November 2009/spring 2010 (weather dependent). • Submit report on findings to the Agencies – late January 2010.

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FACILITY LOCATION ANDPILOT STUDY LOCATIONS MAP

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FMC CORPORATION - MIDDLEPORT, NEW YORKCORRECTIVE MEASURES STUDY

SOIL TILLING/BLENDING PILOT STUDY WORK PLAN

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Appendices

Appendix A

Relevant Documents on Soil Tilling/Blending to Address Arsenic in Soil

Contents of Appendix A

1. Monroe County Department of Health – Protocol for Characterizing Potential Chemical Contamination in Proposed Realty Subdivisions (July 1995)

2. Pennsylvania Department of Environmental Protection – Addressing Pesticide Contamination on Agricultural Land Proposed for Development (April 2005)

3. New Jersey Department of Environmental Protection – Findings and Recommendations for the Remediation of Historic Pesticide Contamination (March 1999)

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MONROE COUNTY DEPARTMENT OF HEALTH

PROTOCOL FOR CHARACTERIZING POTENTIAL CHEMICAL CONTAMINATIONIN PROPOSED REALTY SUBDIVISIONS

[ JULY 1995 ]

The New York State Department of Health (NYDOH) requires the evaluation of previous landusage prior to approval of realty subdivision applications. (Reference: 10NYCRR 74.7 6NYCRR Part617 - State Environmental Quality Review) The New York State Department of Health Bureau of ToxicSubstance Assessment (BTSA) has developed draft guidance to local Health Departments whichrecommends the consideration of past land uses during the permit review process.

Previous usage of lands should be evaluated for agricultural activities involving the application ofpesticides to orchards or other crops, industrial activity, disposal of municipal wastes, construction anddemolition debris, household trash, hazardous wastes, landfilling, sludge application and the potentialfor the presence of harmful degradation products. This evaluation is necessary to minimize potentialpublic exposure to pesticides or other chemical residues in soils, ground water and surface watersduring construction and site occupancy.

The Supplemental Application Form should be completed and submitted to MCDOH aspart of the submission for realty subdivision approval process.

Information to complete this form may be available from a number of sources including: pastproperty owners, site neighbors, local municipal officials, New York State Department of EnvironmentalConservation (NYSDEC), Monroe County Environmental Management Council (MCEMC) and theMonroe County Department of Health (MCDOH). Historical aerial photos are also an important sourceof information. Photos can be examined at MCEMC – 50 West Street, 7th Floor; (716) 760-7610 ext.7041; Fax: (716) 760-4780.

Exposures can occur due to windborne soils and fugitive dust emissions affecting residents andconstruction personnel, contamination of shallow groundwater or proposed drinking water wells, directingestion of surface soils by young children and by the ingestion of fruits and vegetables grown incontaminated soils.

Areas exhibiting concentration levels above guidelines established by the NYSDOH/MCDOH mayrequire special construction procedures along with area remediation before or during on sitedevelopmental activities.

The following remediation alternatives may be used for contaminated soils: limited excavation anddisposal at permitted waste disposal sites; limited excavation and stockpiling for use as fill material on-site to establish required grades; bottom plowing and disking to achieve background levels;emplacement below parking lots, roadways or other low permeable surfaces; use of deed restrictions togive notice to future residents of areas where use may be restricted. These alternatives should not beconsidered all-inclusive to allow for remediation flexibility.

An assessment of contaminant levels will be made by comparison to available information ontypical background occurrences in residential soils. Published data can provide valid information forassessing significance of contaminated levels in soils in addition to consultations with BTSA.

The Developers, their agents/consultants (D/A) can utilize a variety of documents for theirevaluation such as the USEPA Health Based Criteria For Carcinogens, Health Based Criteria forSystemic Toxicants, Element and Chemical Concentrations in Eastern US, NY and Monroe CountySoils. The NYSDOH Drinking Water Standards, the NYSDEC Groundwater Standards and the USEPAHealth Based Criteria will be used for evaluating groundwater. Other publications with scientificallysupported guidance values can also be used.

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SOILS

The subdivision developer should submit a supplemental application indicating past site usage.D/A will be responsible for conducting the preliminary evaluation and if indicated develop the soilsampling plan, overseeing the field sampling investigation and if required by MCDOH developing,overseeing and certifying compliance with a soils management plan(SMP). Upon completion of theSMP, soils monitoring may be required to document the effectiveness of the remediation project.

If there is evidence of possible residual contamination, the D/A will prepare a sampling plan and

submit it to the MCDOH. The plan will detail the number of samples to be collected, sampling locations,soil depth intervals to be sampled, the analyses to be performed along with the rationale for selectingthe locations. Sampling location selection should be based on historic patterns; suspected mixing,storage and disposal areas; differences in surface topography, swales, surface drainage and differentsoil drainage conditions; variations in soil type across the site or other site-specific conditions. Theproposed locations should be plotted on a site plan which shows the topography, roadways andproposed lot boundaries.

Prior consultation with the MCDOH regarding the sampling plan as to the samplinglocations, their number along with monitoring and analytical requirements is stronglyrecommended.

The number of sampling locations should be adequate to characterize the distribution ofcontaminant levels across the project area. In order to identify distinct areas of contamination, samplesshould not be composited. Cross-contamination between samples should be prevented by the use ofclean equipment.

Initial samples should be obtained in the top two inches of soil. Soils at deeper levels should becollected at the same time as surface samples. They should be held for analysis under appropriatelaboratory conditions following USEPA and NYSDOH laboratory protocols pending the analytical resultsof the surface samples. Analysis of deeper soil samples should be done when significant elevated levelsin the upper interval are encountered or when a soils management plan involves top soil removal.

Sample analysis should be performed by a laboratory certified by the New York StateEnvironmental Laboratory Approval Program. Pesticides are to be analyzed by Method 8080 - EPA SW-846. Other pesticides and their appropriate metabolites should be analyzed by appropriate methodsbased on years of usage, half-life, and time of last application. Lead, arsenic and mercury should beevaluated under the appropriate EPA 7000 series and prepared under EPA-3050.Analytical protocols for industrial, commercial or waste disposal sites should be discussed withMCDOH.

The TCLP (leaching procedure) is not recommended because some exposure pathways involvethe entire soil metal content. TCLP may be appropriate where elevated levels of metals indicate that thesoils may be considered hazardous waste (NYSDEC should be consulted in this regard).

GROUNDWATER

Test wells should be drilled and sampled if: (1) a potable water source is to be located on site -refer to the MCDOH Policy on Wells Serving Realty Subdivision;(2)contaminated groundwater may beencountered during construction or in basement sumps.

SURFACE WATER / SEDIMENTS

Surface water and sediment locations should be included if ditches, streams, ponds, etc. are onthe subject property. Upgradient and downgradient locations should be sampled.

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RESPONSIBILITIES

Developers, their agents/consultants are responsible for interpretation of monitoring data,evaluating the site and determining the need for any remedial measures prior to or during sitedevelopment. MCDOH will either agree or disagree with the submitted information.

LIST OF REFERENCES

(1) 10 NYCRR 74.7

(2) Criteria for Contaminated Soils/Sediment Cleanup, J. Fitchko, 1989

(3) Draft NYS AIR GUIDE I - Guidelines for Control of Toxic Air Contaminants, NYSDEC Division ofAir Resources, 1991

(4) Fugitive Dust Suppression & Particulate Monitoring Program at Inactive Hazardous Waste Sites,Division Technical & Administrative Guidance Memorandum HWR-89-4031, NYSDEC Division ofHazardous Waste Remediation, October 1989

(5) Exposure Factors Handbook, USEPA, Publication # EPA 600-8-89-043, July 1989

(6) RCRA Facility Investigation (RFI) GUIDANCE, Volume I-IV, USEPA, Publication # PB89-200299,May, 1989

(7) Background Concentrations of 20 Elements in Soils with Special Regard for New York State,NYSDEC, undated

(8) NYSDEC TAGM Determination of Soil Cleanup Objectives and Cleanup Levels, November 16, 1992

(9) NYSDEC STARS Memo #1 Petroleum Contaminated Soil Guidance Policy, August 1992

ADDRESSING PESTICIDE CONTAMINATION ON AGRICULTURAL LAND PROPOSED FOR DEVELOPMENT

The Land Recycling and Environmental Remediation Standards Act of 1995 (Act 2) was enacted principally to facilitate the cleanup of former industrial sites and return them to productive use. The Legislature envisioned this Act as an integral part of a sound land use policy that would help prevent the needless development of prime farmland, open space areas and natural areas. Consequently, the liability relief provided as a development incentive under Act 2 is not applicable to the development of lands that have been farmed in the normal course of farming practices.

Purpose

The purpose of this document is to clarify the protocol and standards that apply to farm land developments where substances such as arsenic and lead are present. Some former agricultural lands can pose concerns because of historical pesticide use. Of particular concern are arsenic and lead, which can remain in the soil for years at levels that can be a threat to human health. Since the liability relief afforded by Act 2 is not available, the Department has developed a procedure for addressing contamination on former agricultural lands to reduce risk to human health and the environment. This procedure applies to properties with pesticide contamination in excess of the residential or nonresidential Statewide health standard and is intended to be used by developers who propose to convert certain contaminated agricultural lands to other use.

Recommended Procedure

On orchard areas, after removal of the trees, scrape the first six inches of soil from the area within the drip lines of the former trees and other areas where contaminant concentrations are most likely to be greatest and stockpile this soil. Thoroughly till (with a deep disc) the soil between the rows of trees with the soil remaining within the drip lines.

For other former agricultural lands, scrape and stockpile the first six inches of soil from areas where contaminant concentrations are most likely to be greatest, such as at ends of rows or in areas where mixing of agricultural pesticides may have occurred prior to application. Thoroughly till (with a deep disc) the remaining soil.

For residential developments on both types of agricultural land, after soil tilling and the residential lots have been laid out, collect two composite samples from each lot, one in the front yard and one in the rear yard. Each composite sample is to be blended from a minimum of 12 discrete samples.

For nonresidential developments, after soil tilling 12-part composite samples should be taken at the rate of two samples per lot for lots up to one acre in size, and at the rate of two samples per acre for larger properties.

At a minimum, the samples are to be analyzed for arsenic, lead, DDT, DDD, DDE, aldrin, and dieldrin. The developer is to use environmental due diligence to determine any additional agricultural chemicals for analysis.

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http://www.depweb.state.pa.us/ocrlgs/cwp/view.asp?A=1459&Q=517163

2 04/04/2005

If any one of the sample results exceeds the Act 2 Statewide health standard, the developer may either scrape an additional four inches of soil and add it to the stockpiled soil and retill, or thoroughly retill the entire lot. The lot is then to be resampled following the same protocol as the initial sampling.

The stockpiled soil may be used where exposure is controlled, such as under roads in the development or in other capped areas including basketball courts, tennis courts, or bike paths. Institutional controls are appropriate for all areas where the stockpiled soil is placed. The control is to include a health and safety plan for future disturbance of the area involved. If soil is placed under a large area such as a playground or park area, it is to be covered by a geomembrane material and at least two feet of clean soil.

The stockpiled soil may not be placed in drainage swales, stormwater management facilities, or within 100 feet of a surface water body including wetlands. If stockpiled soil is moved offsite, waste regulations or the Management of Fill policy apply.

Disclaimer

The Department recognizes that the soil blending described in this document represents a substantial departure from current Department policy, and therefore such blending may only be used on agricultural properties with historic pesticide contamination that are being converted to other use under the terms of this document. A developer must still comply with existing regulatory requirements, including the development of erosion and sedimentation control plans and permitting under the NPDES program. For example, sampling to determine the scope and extent of existing contamination may be necessary before the developer performs earth-moving activities.

Normal farming operations typically do not result in a release of a regulated substance as defined in Act 2, even though pesticides contain substances that are regulated by the Department. Therefore, this document is not suggesting that any additional regulatory requirements be placed on persons engaged in normal farming practices.

This procedure is not an adjudication or a regulation. There is no intent on the part of the Department to give this document that weight or deference. This document establishes the framework within which the Department will exercise its administrative discretion in the future.

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http://www.state.nj.us/dep/special/hpctf/final/hpctf99.pdf

Appendix B

Existing Soil Arsenic Concentration Data at Study Sites

TABLE B-1 - EXISTING SOIL ARSENIC CONCENTRATION DATA PROPOSED SOIL TILLING/BLENDING AREAS FMC CORPORATION - MIDDLEPORT, NEW YORK

Property AD1 - Plot #1 (North)

0-3" 3-6" 6-12" 12-18" 18-24"AD1-E5 18.0 22.8 17.0 4.2 4.3AD1-E6 16.4 14.7 12.1 5.0 4.5AD1-F5 35.7 30.4 27.5 10.5 5.9AD1-F6 29.0 29.0 12.2 4.5 5.1

Property AD1 - Plot #2 (South)

0-3" 3-6" 6-12" 12-18" 18-24"AD1-C5 16.9 21.6 18.1 5.1 6.0AD1-C6 23.1 25.1 9.1 5.3 16.0AD1-D5 36.8 36.2 28.1 7.9 3.6AD1-D6 19.4 16.6 27.2 21.4 12.2

Property AF (Agricultural Field)

0-6" 6-12" 12-18"AF-SF1 57.9 49.5 5.7AF-SF2 58.1 56.0 6.8AF-SF3 55.8 57.3 6.3AF-SF4 56.0 56.3 5.7AF-SG1 56.9 28.5 5.3AF-SG2 52.7 37.5 4.6AF-SG3 49.8 41.9 12.0AF-SG4 51.2 37.4 5.3AF-R1 56.5 22.8 4.9AF-R2 53.9 50.0 4.7AF-R3 68.1 42.4 5.8AF-R4 57.8 44.5 4.2AF-T1 55.2 37.8 6.6AF-T2 54.4 55.0 6.3AF-T3 53.6 53.6 7.7AF-T4 50.3 36.9 4.7AF-T5 47.9 36.7 4.4AF-T6 51.1 28.4 5.6AF-A1 53.6 46.5 4.9AF-A2 51.8 45.2 11.3AF-UK1 48.0 40.3 7.3

Sample ID

Sample ID

Sample ID Arsenic Concentration (mg/kg)

Soil Arsenic Concentration (mg/kg)

Soil Arsenic Concentration (mg/kg)

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Appendix C

Summary of Community Air Monitoring Plan Requirements

Property AD1 Property AF

2 Airborne Particulates: Real Time Monitoring (using dust monitor)

• one upwind station continuous• two downwind stations continuous• one station at work area perimeter of closest occupied residence (may also serve as upwind or downwind station depending on wind direction)

• one upwind station continuous• two downwind stations continuous• one station at work area perimeter towards Roy-Hart Elementary School Building (may also serve as upwind or downwind station depending on wind direction)

• during all soil handling and ground intrusive activities, including, but not limited to, soil excavation, tilling, blending, handling, removal, backfilling, grading and compaction.

• as measured for particulate matter less than 10 microns in size (PM-10):• above 100 ug/m3 or dust observed leaving work area: employ dust suppression techniques• above 150 ug/m3 with dust suppression techniques: stop work and re-evaluate

• monitoring results daily to DEC field rep

• one sample at each location where real time particulate monitoring is performed (for frequency of sample collection refer to "Applicability" column)

• one sample at each location where real time particulate monitoring is performed (for frequency of sample collection refer to "Applicability" column)

Notes: 1. Table does not include separate requirements for worker breathing zone air monitoring. 2. Wind direction to be measured at the start of each work day and periodically using wind sock, wind vane or other appropriate equipment. Upwind and downwind monitoring stations may need to be relocated if a significant shift in wind direction occurs. 3. Reference 2007 Early Actions Work Plan CAMP, Revision No. 1 , August 2007, ARCADIS BBL and Field Modification No. 11.

Airborne Particulates: Documentation Sampling and

Laboratory Analysis

3

1 VOCs: Real Time Monitoring

(using PID)

• PID available for use if odor or unknown materials are encountered

• PID available for use if odor or unknown materials are encountered

• all samples analyzed at laboratory for arsenic

Reporting / NotificationWork Areas

• monitoring results daily to DEC field rep

• during all soil handling and ground intrusive activities, including, but not limited to, soil excavation, tilling, blending, handling, removal, backfilling, grading and compaction.

• as measured with PID: • 5 to 25 ppm: temporary work halt, identify source and abate • above 25 ppm: shut down work and implement emission control measures

• prior to start of any work to establish background (upwind only) • daily during first week of work at each study area • weekly after the first week (work not expected to extend more than one week at study area)

Monitoring Requirement

• compare to background results

• laboratory data to DEC field rep as received

• all samples analyzed at laboratory for arsenic

Item

TABLE C-1: SUMMARY OF COMMUNITY AIR MONITORING PLAN [CAMP] REQUIREMENTSCMS SOIL TILLING/BLENDING PILOT STUDY WORK PLAN

FMC CORPORATION - MIDDLEPORT, NEW YORK

Applicability Action Levels

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Appendix D Description of Soil Tilling/Blending Approaches

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1

Appendix D

Soil tilling/blending will be applied using two different techniques: 1) in situ mixing with a mixing head attached to an excavator; and 2) roto-tilling combined with turning-over soil using an excavator or bulldozer. The two mixing approaches to be used in the pilot study are described below.

Mixing Approach #1 – In-Situ Mixing Head

Using a “cutter head” (rotating and articulating mixing head) attached to an excavator, soil will be mixed in place to a given target mixing depth (see summary table at the end of this task). During the mixing process, several passes with the mixing head will be made within the Study Site. First, a complete pass of the entire area will be made in one direction with the mixing head. Then, the mixing head will be reoriented and another complete pass will be made in the new direction. Altogether, no less than four passes will be made using the mixer head.

Specifications for a representative mixing head/excavator unit are provided in Appendix E. A similar size mixing head, or smaller, is proposed to be used for the pilot study.

Mixing Approach #2 – Roto-Tilling

Using a roto-tiller (disc plow) rear-mounted to a tractor, soil will be tilled to a depth of approximately 6 inches. After initial tilling, an excavator/bulldozer will be used to scrape down to the target depth (e.g., 18 inches) and soils will be overturned and within the study area. The area will then be roto-tilled again and then scraped again to the target depth (e.g., 18 inches). The latter step will be repeated two times for a total of four iterations of roto-tilling and scraping/overturning soil.

Pilot Study Design Summary

The mixing head is proposed to be used at two locations and the roto-tiller is proposed at one location. The target mixing depth varies by location, as determined based on existing data. A summary of the study design is provided below.

Study Site Area Mixing Approach

Target Mixing Depth (inches below grade)

Pre-Existing Arsenic Data in

0- to 12-inch Depth Interval

(mg/kg)

Calculated Post-Mixing Average

Arsenic Concentration

(mg/kg)

Number of Samples to be collected After

Second and Fourth Mixing

Passes

AD1 North 100’ x 100’ Mixing Head 18 inches 9.1 to 36.8 18.0 12

AD1 South 100’ x 100’ Roto-tiller 18 inches 12.1 to 35.7 16.0 12

AF 30’ x 75’ Mixing head 36 inches 28.4 to 55.2 20.0 24

Appendix E

Mixing Head Equipment Information