FMC Corporation. Transmitted Via and FedEx. June 13, 2011

Transcription

1 FMC Corporation FMC Corporation 1735 Market Street Philadelphia PA phone fax Transmitted Via and FedEx June 13, 2011 Mr. Matt Mortefolio, P.E. NYSDEC Project Coordinator Remedial Bureau E Division of Environmental Remediation New York State Department of Environmental Conservation 625 Broadway, 12 th Floor Albany, NY Mr. Michael Infurna USEPA Project Coordinator Environmental Planning and Protection Division United States Environmental Protection Agency, Region II 290 Broadway, 20 th Floor New York, NY Re: Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park Monitoring and Maintenance Plan Relative to 2007 Early Actions Remedial Work Revision No. 1 RCRA Section 3008(h) Administrative Order on Consent (AOC) Docket No. II-RCRA (h)-209 FMC Corporation, Middleport, NY Facility EPA I.D. No. NYD Dear Messrs. Mortefolio and Infurna: FMC Corporation (FMC) is submitting the Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park Monitoring and Maintenance Plan Relative to 2007 Early Actions Remedial Work Revision No. 1 in accordance with the terms and conditions of the above-referenced AOC. As discussed below, the enclosed document is a revised version of the Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park Monitoring and Maintenance Plan Relative to 2007 Early Actions Remedial Work which was approved by the New York State Department of Environmental Conservation (NYSDEC) and the United States Environmental Protection Agency (USEPA) (jointly, the Agencies), in consultation with the New York State Department of Health (NYSDOH), by letter to FMC dated March 5, By letter to the Agencies dated August 23, 2010, FMC submitted a request to reduce the frequency of stormwater sampling and sediment measurement/sampling in sediment chamber MH-N9 and manhole MH-N8B from quarterly to annually. By letter dated February 23, 2011, the Agencies approved this request, with implementation of this revision beginning in the first calendar quarter In addition, the Agencies requested that FMC submit revised pages of the Monitoring and Maintenance Plan for review. FMC submitted an e-draft of revised pages (in redline/strikeout format) of the plan to the Agencies by dated April 4, 2011, and the Agencies approved the proposed revisions by dated June 3, As requested in the June 3, 2011 approval, enclosed is a hard copy of the revised plan. G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan transmittal.docx

2 Messrs. Mortefolio and Infurna June 13, 2011 Page 2 If you have questions or need additional information, please contact me. Sincerely, Brian M. McGinnis Remediation Project Manager (215) Enclosure cc: With enclosure: M. Hinton, NYSDEC, Buffalo R. Locey, NYSDEC, Buffalo S. Radon, NYSDEC, Buffalo N. Freeman, NYSDOH, Troy D. Dodge, Village of Middleport Coordinator Middleport Library Document Repository K. Kerins, (Buffalo Division Canals) New York State Canal Corporation W. Lachell, AMEC Geomatrix E. Rankin, P.E., ARCADIS Without enclosure: K. Bricke, USEPA, NYC A. Everett, USEPA, NYC T. Killeen, NYSDEC, Albany M. Cruden, NYSDEC, Albany S. Bates, NYSDOH, Troy Mayor Richard Westcott, Village of Middleport D. Seaman, Esq., Village Attorney, Village of Middleport W. Arnold, Middleport Community Input Group P. Cousins, Middleport Remediation Advisory Group D. Watts, Technical Consultant to MCIG/MRAG Senator George Maziarz, Wheatfield Assemblywoman Jane Corwin, Clarence G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan transmittal.docx

3 Imagine the result FMC Corporation Middleport, New York Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work February 2009 Revision No. 1 June 2011

4 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York Table of Contents 1. Purpose 1 2. Background 2 3. Monitoring and Maintenance Activities Stormwater Sampling Sediment Monitoring and Sampling Removal of Sediments 5 4. Reporting and Review of Plan 6 5. References 7 Figures 1 Location Map 2 Margaret Droman Park Site Plan 3 Cross-Sectional View of Sediment Chamber MH-N9 and Transition Box Appendices A B C Inspection Form, Pre-Inspection Checklist, and Monitoring, Maintenance, and Documentation Schedule Sediment Measurement, Sediment Sampling, and Stormwater Sampling Procedures Copy of Record Drawings for 2007 Early Actions at Margaret Droman Park G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc i

5 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York 1. Purpose In 2007 and 2008, FMC Corporation (FMC) conducted remedial measures outlined in the 2007 Early Action Work Plan, Revision No. 1 (Work Plan) and in the Revised Addendum 1 to the August 2007 Early Action Work Plan (Addendum) for properties near FMC s pesticide formulating facility in Middleport, New York (herein Facility). The 2007 Early Action remedial work was performed under the terms and conditions of an Administrative Order on Consent (AOC), Docket No. II RCRA (h)-0209, entered into by FMC, the United States Environmental Protection Agency (USEPA) and the New York State Department of Environmental Conservation (NYSDEC) (the latter two entities are jointly referred to hereafter as the Agencies ), effective July 2, Details on implementation of the 2007 Early Action remedial work are provided in the 2007 Early Action Construction Report ( Construction Report ). The 2007 Early Actions involved work at several areas, including along sections of the Village of Middleport s Culvert 105 storm sewer system. Sediment chamber MH-N9, which is the subject of this Monitoring and Maintenance Plan, is located along Culvert 105 within Margaret Droman Park, immediately north of the Erie Canal (see Figures 1 and 2 for the locations of Margaret Droman Park and sediment chamber MH-N9, respectively). Activities in this plan also involve manhole MH-N8B, which is located approximately 50 feet north of, and downstream from, sediment chamber MH-N9. The Work Plan stated that following completion of the 2007 Early Action remedial work, FMC would develop a Monitoring and Maintenance Plan for sediment chamber MH-N9. A plan titled Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work ( Monitoring and Maintenance Plan ) was developed by FMC to address this requirement, and was approved by the Agencies, in consultation with the New York State Department of Health (NYSDOH), by letter dated March 5, This plan described the following monitoring and maintenance activities for sediment chamber MH-N9 and downstream manhole MH-N8B: Sampling stormwater at sediment chamber MH-N9 and manhole MH-N8B on a quarterly basis and submitting samples for analysis of Total Dissolved Solids (TDS), Total Suspended Solids (TSS), arsenic (total and dissolved), lead (total and dissolved), hardness and certain specific chlorinated pesticides (total and dissolved), as described in Section 3.1 of the plan Monitoring the thickness of sediment within sediment chamber MH-N9 and manhole MH-N8B on a quarterly basis, as described in Section 3.2 of the plan G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 1

6 Sampling sediment in manhole MH-N8B, or if sufficient sediment is not present in manhole MH-N8B, attempting to sample sediment in sediment chamber MH-N9, on a quarterly basis, and submitting samples for analysis of arsenic, lead and certain specific chlorinated pesticides, as described in Section 3.2 of the plan Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York Removing sediment from sediment chamber MH-N9 and manhole MH-N8B, when necessary, as described in Section 3.3 of the plan Section 4 of the Monitoring and Maintenance Plan specified that after one year of quarterly events, FMC would review the analytical data and evaluate whether modification of the monitoring activities (e.g., frequency of events, scope of analyses) described in the plan was appropriate. Based on review of the results of five quarterly events (second, third and fourth calendar quarters of 2009 and first and second calendar quarters of 2010), FMC identified proposed modifications to the monitoring activities. By letter dated August 23, 2010, FMC submitted a request to the Agencies to reduce the frequency of stormwater sampling and sediment measurement/sampling in sediment chamber MH-N9 and manhole MH-N8B from quarterly to annually. By letter dated February 23, 2011, the Agencies approved this request, with implementation of this revision beginning in the first calendar quarter of This revision is reflected in the remainder of this Monitoring and Maintenance Plan. 2. Background MH-N9 is located in the southeastern corner of Margaret Droman Park, which is owned by the New York State Canal Corporation. The Village of Middleport owns and maintains the Culvert 105 storm sewer system, with the exception of the portion that flows beneath the Canal, which is owned and maintained by the Canal Corporation. Figure 3 provides a cross-sectional sketch of sediment chamber MH-N9. The bottom sump portion of sediment chamber MH-N9 is approximately 5 feet by 6 feet in area, with a bottom depth of approximately 10 feet below the standing water level, and approximately 16 feet beneath the top grate cover. Stormwater enters sediment chamber MH-N9 through the 30-inch-diameter cast-iron pipe that passes beneath the Canal. The invert of this pipe as it enters sediment chamber MH-N9 is approximately 2 feet above the sump base (based on a plan provided by the Canal Corporation). As originally constructed, stormwater would flow out of sediment chamber MH-N9 into an open drainage ditch at an elevation approximately 8 feet higher than the invert of the 30-inch inlet pipe, or approximately 10 feet higher than the sump base. G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 2

7 Following implementation of the 2007 Early Action remedial work, stormwater flow out of sediment chamber MH-N9 is now carried into a new buried pipe, via a new transition box, that passes through new manhole MH-N8B, also located within Margaret Droman Park. MH-N8B is a standard precast manhole having an inside diameter of 48 inches and a total depth of approximately 6 feet. The bottom of the sump within manhole MH-N8B is approximately 10 inches below the invert of its outlet pipe. Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York During the 2007 Early Actions, the following activities were conducted with respect to sediment chamber MH-N9, manhole MH-N8B and Culvert 105 at Margaret Droman Park: Sediment was removed from sediment chamber MH-N9, solidified, and disposed as non-hazardous waste at an appropriate permitted landfill Soil along the open drainage ditch crossing Margaret Droman Park from the outlet of sediment chamber MH-N9 to an existing buried pipe inlet at Mechanic Street was excavated to depths ranging from 12 to 24 inches below existing surface grade and placed in FMC s Eastern Surface Impoundment (ESI) Fill Area, and a new 24-inch-diameter buried high-density polyethylene (HDPE) pipe was installed in place of the former open drainage ditch, along with two precast manholes (MH- N8A and MH-N8B). A new transition box was installed on the downstream (north) side of MH-N9 to allow transition from sediment chamber MH-N9 to the new HDPE pipe (refer to Figure 3 for cross-sectional view of the transition box and its relation to sediment chamber MH-N9). Copies of the Record Drawings for the 2007 Early Action remedial work completed at Margaret Droman Park are provided in Appendix C. 3. Monitoring and Maintenance Activities This section describes monitoring and maintenance activities for sediment chamber MH-N9 and manhole MH-N8B, including collecting and analyzing stormwater samples, monitoring the thickness of sediment in the base of the structures, collecting and analyzing samples of the sediment, and removing the sediment when necessary. FMC entered into an agreement with the Village of Middleport (Village) for access to Culvert 105 work areas to conduct the 2007 Early Action remedial work and for continuing access to perform the work described in this Monitoring and Maintenance G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 3

8 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York Plan. In addition, FMC has obtained and will continue to obtain work permits from the Canal Corporation to conduct this work. Personnel conducting the monitoring and sampling will complete the Pre-Inspection Checklist and the Inspection Form included in Appendix A to this Monitoring and Maintenance Plan. The Pre-Inspection Checklist identifies the items (i.e., notifications, past inspection reviews) that must be completed and/or reviewed prior to performing monitoring activities. As shown in the Pre-Inspection Checklist, FMC will notify the required parties by either telephone or at least three business days prior to a scheduled monitoring event. The Inspection Form is a checklist for documenting the monitoring and maintenance activities. Copies of the completed Inspection Form will be maintained in the Facility s records and will be provided to the Agencies, upon request. 3.1 Stormwater Sampling Stormwater samples will be collected from sediment chamber MH-N9 and manhole MH-N8B on an annual basis. Stormwater sampling is to be conducted during the first calendar quarter of each year, if feasible. If stormwater samples cannot be collected from both locations during the first calendar quarter, then the locations will be checked and samples collected during the subsequent quarter (and thereafter, as needed) with the objective of obtaining stormwater samples once from MH-N9 and MH-N8B within the calendar year. Stormwater sampling will be performed when sufficient water is observed flowing out of the MH-N9 transition box. Weather conditions (i.e., rainfall amounts, temperature, etc.) on the day of sampling and two days preceding sampling will be documented. Stormwater samples will be collected from both sediment chamber MH-N9 and manhole MH-N8B in accordance with the stormwater sampling procedure provided in Appendix B. Stormwater samples will be collected before collection of any sediment samples to minimize potential suspension of sediment into the stormwater samples. The samples will be submitted to a NYSDOH ELAP certified laboratory for analysis of the following constituents and parameters by the indicated methods: total and dissolved arsenic (USEPA SW-846 Method 6010B) total and dissolved lead (USEPA SW-846 Method 6010B) total dissolved solids (Standard Methods for the Examination of Water and Wastewater [SMEWW] Method 2540C) total suspended solids (SMEWW Method 2540D) hardness (SMEWW Method 2340C) G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 4

9 total and dissolved specific chlorinated pesticides (4,4 -DDT, 4,4 - DDD, 4,4 -DDE, dieldrin, and BHC isomers) (USEPA SW-846 Method 8081A) All analytical data will be reported by the laboratory with NYSDEC Analytical Services Protocol Category B deliverables. Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York 3.2 Sediment Monitoring and Sampling Monitoring the thickness of sediment in sediment chamber MH-N9 and manhole MH- N8B will be performed on an annual basis. Monitoring is to be conducted during the first calendar quarter of each year. During each monitoring event, the thickness of sediment in the sump base of sediment chamber MH-N9 and of manhole MH-N8B will be measured in accordance with the sediment measurement procedure provided in Appendix B. If the sediment thickness in manhole MH-N8B appears to contain sufficient sample volume for laboratory analysis of samples, then sediment samples will be collected from MH-N8B in accordance with the sediment sampling procedures provided in Appendix B. If sufficient sediment sample volume cannot be collected from manhole MH-N8B, then assuming that sediment is present in a sufficient amount in MH-N9, an attempt will be made to collect a sediment sample from MH-N9 in accordance with the procedures in Appendix B. The sediment samples will be submitted to a New York State Department of Health (NYSDOH) Environmental Laboratory Approval Program (ELAP) certified laboratory for analysis of the following constituents by the indicated methods: arsenic (USEPA SW-846 Method 6010B) lead (USEPA SW-846 Method 6010B) specific chlorinated pesticides (4,4 -DDT, 4,4 -DDD, 4,4 -DDE, dieldrin, and BHC isomers) (USEPA SW-846 Method 8081A) All analytical data will be reported by the laboratory with NYSDEC Analytical Services Protocol Category B deliverables. 3.3 Removal of Sediments The only maintenance that will be conducted under this Monitoring and Maintenance Plan by FMC is the removal of sediments from sediment chamber MH-N9 and manhole MH-N8B, as described below, when necessary. If other conditions are noted in the course of the inspection that need attention, such as damage to the metal grate cover, G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 5

10 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York these conditions will be communicated to the Village Engineer or an appropriate Village representative. If the thickness of sediment in the base of MH-N9 is at least 18 inches, which corresponds to 6 inches of freeboard beneath the invert height of the inlet pipe with respect to the sump base, or if the thickness of sediment in the base of MH-N8B is within 3 inches of the invert of its outlet pipe, then the sediment in that structure will be removed, properly containerized for transport, and disposed at an appropriate facility. Prior to removal of sediment from sediment chamber MH-N9 or manhole MH-N8B, FMC will implement the following: 1. Provide the Agencies and the Village with the sampling results and a summary of the removal activities (including proposed sediment disposal option) 2. Notify the Agencies, property owner (Canal Corporation) and the Village at least 3 business days prior to start of the sediment removal field activities by telephone or 4. Reporting and Review of Plan Within 90 days after the date of the inspection, the following will be submitted to the Agencies: A copy of the completed Inspection Form that documents the conditions observed and the sampling conducted A table summarizing the analytical data (the laboratory analytical reports will be maintained in FMC s records) Any recommendations for additional downstream sampling and analysis if the sample results suggest that there is potential downstream migration of contaminants (no additional sampling and analysis will be conducted without prior written approval from the Agencies) If sediment is removed, a brief summary of the sediment removal activities, including documentation of its characterization and disposition In addition, FMC will review the analytical data and evaluate whether further modification of the monitoring and maintenance activities (e.g., frequency of events, G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 6

11 scope of analyses) described in this plan is appropriate. Any proposed modifications will be submitted to the Agencies for approval prior to implementation. Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York 5. References Agencies Letter to Brian McGinnis, FMC Corporation, from Matt Mortefolio, NYSDEC and Michael Infurna, USEPA, providing approval of the Monitoring and Maintenance Plan. Letter dated March 5, 2009 Agencies Letter to Brian McGinnis, FMC Corporation, from Matt Mortefolio, NYSDEC and Michael Infurna, USEPA, in response to FMC s request for modification to monitoring activities. Letter dated February 23, 2011 ARCADIS. 2009a Early Actions Construction Report, dated February Prepared for FMC Corporation, Middleport, NY ARCADIS. 2009b. Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work, dated February Prepared for FMC Corporation, Middleport, NY ARCADIS BBL. 2007a Early Action Work Plan, Revision No. 1, dated August Prepared for FMC Corporation, Middleport, NY ARCADIS BBL. 2007b. Revised Addendum 1 to the August 2007 Early Action Work Plan, dated September Prepared for FMC Corporation, Middleport, NY FMC Corporation Letter to Matt Mortefolio, NYSDEC and Michael Infurna, USEPA from Brian McGinnis, FMC Corporation, requesting modification to monitoring activities. Letter dated August 23, 2010 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9 plan_june2011.doc 7

12 Figures

13 Margaret Droman Park REFERENCE: BASE MAP USGS 7.5 MIN. QUAD., MEDINA, NY, /31/08 SYR-141ENV-DJH B /0000/00017/CDR/37736n01.cdr 1000' ' FMC CORPORATION MIDDLEPORT, NEW YORK Approximate Scale: 1" = 1000' CULVERT 105 SEDIMENT CHAMBER MH-N EARLY ACTIONS MONITORING AND MAINTENANCE PLAN Area Location LOCATION MAP FIGURE 1

14

15 CITY: SYRACUSE GROUP: ENV-141 DB: PGL LD: PGL PM: D. WRIGHT LYR: ON=*;OFF=REF, (FRZ) G:\ENVCAD\SYRACUSE\ACT\B \0000\00017\DWG\37736N01.DWG LAYOUT: 3SAVED: 12/22/2008 8:38 AM ACADVER: 17.0S (LMS TECH) PAGESETUP: ----PLOTSTYLETABLE: PLTFULL.CTB PLOTTED: 12/22/2008 8:40 AM BY: LISTER, PAUL CATALOG: IMAGES: XREFS: 37736XPA GROUND SURFACE STORM WATER FLOW FROM BENEATH CANAL NOTES: CONCRETE 30" C.I. PIPE TOP OF CONCRETE APPROX. 24" TOP OF GRATE 1. APPROXIMATE INSIDE DIMENSIONS BASED ON TAPE MEASUREMENTS IN THE FIELD BY ARCADIS ON AUGUST 22, CONSTRUCTION OF BURIED PORTIONS BASED ON UNDATED "GENERAL LAYOUT OF CULVERT 105" DRAWING PROVIDED BY THE NEW YORK STATE CANAL CORP. SEDIMENT CHAMBER MH-N9 APPROX. 16' WATER LEVEL CONCRETE TOP OF GRATE TRANSITION BOX GROUND SURFACE 24" HDPE PIPE FMC CORPORATION - MIDDLEPORT, NEW YORK CULVERT 105 SEDIMENT CHAMBER MH-N EARLY ACTIONS MONITORING AND MAINTENANCE PLAN CROSS-SECTION SKETCH OF SEDIMENT CHAMBER MH-N9 AND TRANSITION BOX FIGURE 3

16 Appendix A Inspection Form, Pre-Inspection Checklist, and Monitoring, Maintenance, and Documentation Schedule

17 CULVERT 105 SEDIMENT CHAMBER MH-N9 AT MARGARET DROMAN PARK 2007 EARLY ACTIONS MONITORING AND MAINTENANCE PLAN RELATIVE TO REMEDIAL WORK FMC CORPORATION MIDDLEPORT, NEW YORK PRE-INSPECTION CHECKLIST Inspector Name: Proposed Inspection Date: I. Notifications (check when completed and enter date and means of notification) Note: All notifications must be made by telephone or at least 3 business days prior to inspection date. Person: Date: Telephone # / address: NYSDEC Field Representative Village of Middleport NYS Canal Corporation Comments: II. Review Items (check when completed) Monitoring & Maintenance Plan Inspection Protocols (Appendix B of Plan) Results of Prior Inspections Comments: III. Inspection Equipment (check when collected) Inspection Form Camera Equipment for sediment measurement listed in Appendix B of Monitoring & Maintenance Plan Equipment for sediment and stormwater sampling listed in Appendix B of Monitoring & Maintenance Plan Other: (Describe) 2/18/09 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9_Form_checklist.doc Page 1 of 1

18 CULVERT 105 SEDIMENT CHAMBER MH-N9 AT MARGARET DROMAN PARK 2007 EARLY ACTIONS MONITORING AND MAINTENANCE PLAN RELATIVE TO REMEDIAL WORK FMC CORPORATION - MIDDLEPORT, NEW YORK INSPECTION FORM I. Stormwater Conditions Inspector Name: Date/Time: Current Weather: Weather Previous Two Days: Other Parties Present (and affiliation): Yes No [ ] [ ] [ ] [ ] Is stormwater observed flowing out of the MH-N9 transition box? Sampling of stormwater required? (If storm water observed flowing out of MH-N9 transition box, water sampling is required) Additional Comments: II. Stormwater Samples Inspector Name: Date/Time of Sampling: Weather: Other Parties Present (and affiliation): a. Sample Information Sample ID Location (i.e., MH-N9 or MH-N8B) Describe the water sample characteristics (i.e., turbidity, color, presence of debris, odor): b. Collection Method Used / Additional Comments: III. Sediment Depth Inspector Name: Current Weather: Other Parties Present (and affiliation): Date/Time: Weather Previous Two Days: Yes No [ ] [ ] [ ] [ ] Are there sediments in sediment chamber MH-N9? Are there sediments in manhole MH-N8B? a. Depth of sediments in MH-N9 is approximately inches (to nearest 1/2-inch). b. Depth of sediments in MH-N8B is approximately inches (to nearest 1/2-inch). Additional Comments: 6/8/2011 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9_Insp_form.xls Page 1 of 2

19 CULVERT 105 SEDIMENT CHAMBER MH-N9 AT MARGARET DROMAN PARK 2007 EARLY ACTIONS MONITORING AND MAINTENANCE PLAN RELATIVE TO REMEDIAL WORK FMC CORPORATION - MIDDLEPORT, NEW YORK INSPECTION FORM IV. Sediment Samples Inspector Name: Date/Time of Sampling: Other Parties Present (and affiliation): a. Sample Information Sample Number Location (i.e., MH-N9 or MH-N8B) Describe the sediment sample characteristics (i.e., texture, color, presence of debris, biological structures, odor): b. Collection Method Used / Additional Comments: V. Photographic Documentation Photo Number Sample ID Photo Description 6/8/2011 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _MHN9_Insp_form.xls Page 2 of 2

20 CULVERT 105 SEDIMENT CHAMBER MH-N9 AT MARGARET DROMAN PARK 2007 EARLY ACTIONS MONITORING AND MAINTENANCE PLAN RELATIVE TO REMEDIAL WORK FMC CORPORATION MIDDLEPORT, NEW YORK MONITORING AND MAINTENANCE SCHEDULE Activity Frequency Collect storm water samples for analysis Inspect/monitor depth of sediment Collect sediment samples for analysis Remove sediment and properly dispose Annually Annually Annually, if feasible If sediment within 6 inches of invert of outlet pipe in MH-N9, or if sediment within 3 inches of invert of outlet pipe in MH-N8B DOCUMENTATION SCHEDULE Documentation Requirement Frequency Inspection Form Summary table of laboratory data analysis results Documentation of proper disposition of removed sediments Annually Annually When sediment removal conducted during the reporting period, based on results of inspection and testing (see above table) The above items to be submitted to the Agencies along with any recommendations, if appropriate, within 90 days following completion of the monitoring event associated with the quarterly event. From the second calendar quarter 2009 through the first calendar quarter 2011, stormwater sampling and sediment measurement/sampling in sediment chamber MH-N9 and manhole MH-N8B were conducted quarterly. Beginning in the first calendar quarter 2011, stormwater sampling and sediment measurement/sampling are conducted annually. Stormwater sampling is to be conducted during the first calendar quarter of each year, if feasible. If stormwater samples cannot be collected from both locations during the first calendar quarter, then the locations will be checked and a sample collected during the subsequent quarter (and thereafter, as needed), with the objective of obtaining stormwater samples from MH-N9 and MH-N8B once within the calendar year. G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _table 1.doc Page 1 of 1

21 Appendix B Stormwater Sampling, Sediment Measurement, & Sediment Sampling Procedures

22 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York Appendix B I. Stormwater Sampling Stormwater sampling from sediment chamber MH-N9 and manhole MH-N8B will be performed prior to sediment probing or sampling to minimize potential for suspension of sediment in the stormwater samples. The procedures to be followed to obtain stormwater samples, without manned entry into the structures, are outlined below. A. Equipment/Supplies: The following materials will be available, as required, during stormwater sampling: 1. Personal protective equipment (PPE) per the Health & Safety Plan (HASP) 2. Inspection Form (Appendix A to the Monitoring & Maintenance Plan) 3. Surveyor's rod 4. Appropriate water sampling equipment (e.g., peristaltic pump, pump tubing, disposable in-line water filters, and Teflon lined sampling tubing) 5. Appropriate sample containers 6. Transport container with ice 7. Chain of custody form B. Procedures: 1. Measure the total depth of the water column with the manhole or chamber by extending the surveyor's rod into the water until it reaches the bottom. 2. Attach the sample tubing to the surveyor s rod at 0.5 times the total water column depth and lower rod through the grate cover of the structure to its base. 3. Utilize the peristaltic pump and tubing to transfer water directly into appropriate lab supplied bottles. 4. Field filtered samples will be collected by connecting the disposable filters directly to the effluent tubing of the peristaltic pump. 5. Secure all sample jar caps tightly. 6. Label all sample containers. 7. Place filled sample containers on ice in a cooler. 8. Collect field duplicate and MS/MSD samples during each sampling event. Field duplicates and MS/MSD samples will be prepared by filling additional sets of sample containers with water collected at the same time and depth. One additional set of sample containers will be filled for field duplicates and two sets of containers will be filled for MS/MSD samples. 9. Follow outlined procedures for preservation of samples and packing, handling, and shipping with associated chain-of-custody procedures for samples. 10. Record required information on the Inspection Form. 11. Complete the chain-of-custody forms. 12. With NYSDEC Analytical Services Protocol Category B deliverables, request laboratory analyses of the following: total and dissolved arsenic (USEPA SW-846 Method 6010B) total and dissolved lead (USEPA SW-846 Method 6010B) Total Dissolved Solids (SMEWW Method 2540C) Total Suspended Solids (SMEWW Method 2540D) hardness (SMEWW Method 2340C) total and dissolved chlorinated pesticides (4,4 -DDT, 4,4 -DDD, 4,4 - DDE, dieldrin, and BHC isomers) (USEPA SW-846 Method 8081A) Page 1 of 4 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _appendix B procedures.doc

23 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York II. Measuring the Thickness of Sediment in Sediment Chamber MH-N9 and Manhole MH-N8B The procedures to be followed in measuring the thickness of sediment in the sump base of sediment chamber MH-N9 and manhole MH-N8B, without manned entry into the structures, are outlined below. A. Equipment/Supplies: 1. PPE per the HASP. 2. Marker for tubing and pen for form. 3. Approximately 30 feet of clean, unmarked 1.25-inch outer diameter (O.D.) Lexan tubing or other appropriate sediment tube coring device fitted with a liner and retaining tip. 4. Measuring tape or ruler. 5. Inspection Form (Appendix A to the Monitoring & Maintenance Plan) B. Procedure: Measuring the thickness of sediment will be performed in accordance with the following procedure: 1. Record the date, time, weather, and other appropriate information on the Inspection Form (Appendix A to the Monitoring & Maintenance Plan). 2. Don personal protective equipment (as required by the HASP). 3. Lower the Lexan tubing through the grate cover of the structure until it just reaches the top of the sediment. For sediment chamber MH-N9, lower the tubing through the grate cover, approximately 1 to 2 feet from the southern end headwall and mid-width (east-west) to be in the approximate center of the flat sump base. For MH-N8B, lower the tubing through the grate cover in the approximate center of the manhole. Mark the tubing to indicate the length that was lowered to the top of sediment, relative to the top of the metal grate cover. 4. Slowly push the tubing into the sediment by hand until refusal/base of structure is reached. 5. Mark the tubing when at the final depth (at refusal/base of structure) using the same datum selected in step Measure the distance between the two marked depths to the nearest ½-inch and record as the thickness of sediment on the Inspection Form. III. Sediment Sampling If the sediment thickness in manhole MH-N8B appears to contain sufficient sample volume for laboratory analysis, then an attempt to collect a sediment sample from MH- N8B will be completed using Procedure 1 outlined below. If sufficient sediment sample volume cannot be collected from manhole MH-N8B using Procedure 1, then an attempt to collect a sediment sample from manhole MH-N8B will be completed using Procedure 2 outlined below, or another appropriate grab sampling method to be determined in the field that does not involve manned entry into the structure. If sufficient sediment sample volume cannot be collected from manhole MH-N8B using Procedure 1 and Procedure 2, then an attempt to collect a sediment sample from sediment chamber MH-N9 will be completed using first Procedure 1, and then if needed, Procedure 2, without manned entry into the structure. Page 2 of 4 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _appendix B procedures.doc

24 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York A. Additional Equipment/Supplies: In addition to the equipment and supplies listed above in Task II for sediment measurement, the following items will be needed for sampling. All equipment used for sediment sampling shall be clean disposable equipment or shall be decontaminated prior to use in accordance with approved Standard Operating Procedures (SOPs). 1. End caps for Lexan tubing or other appropriate tube coring device 2. Appropriate water sampling equipment (e.g., peristaltic pump, pump tubing, disposable in-line water filters, and Teflon lined sampling tubing) 3. Several wide mouth jars sufficient to contain 2 to 3 gallons of water 4. Surveyor s rod 5. Hand vacuum pump 6. Stainless-steel spoons or disposable plastic spoons 7. Stainless-steel mixing bowl or disposable aluminum bowl 8. Cleaning supplies and equipment, if needed 9. Digital camera 10. Appropriate sample containers 11. Transport container with ice 12. Chain of custody form B. Procedure 1 for Sediment Sampling: 1. Identify the proposed sample location on the Inspection Form along with other appropriate information collected during sediment sampling activities. 2. Don personal protective equipment (as required by the HASP). 3. Lower the tubing or other tube coring device into the structure until it just reaches the top of sediment. 4. Slowly push the tubing / device through the grate cover of the structure into the sediment by hand until refusal / base of the structure is reached. 5. Place plug on the top end of the Lexan tube to create a vacuum to retain the sediments in the tube during core retrieval. If not sufficient to maintain vacuum, then a hand vacuum pump may be used. 6. Slowly pull the tube from the sediment, twisting it slightly as it is removed (if necessary) to retain as much material in the tube as possible. 7. As soon as the tube is fully removed from the structure, place a cap on the bottom end of the tube to prevent loss of sample material. 8. Measure the length of sediment recovered and evaluate the integrity of the sample. If the sample is not suitably intact, repeat sampling procedure near the first location attempted. Photograph the sample next to a calibrated measuring rod or ruler and fill out the Photograph Log (included with the Inspection Form). 9. Transfer the sediment to a stainless-steel mixing bowl (or a disposable aluminum mixing tray) for homogenization. 10. A minimum of 4 ounces of sediment is required for testing each sample; therefore, if a split sample is requested, additional volume will be required. Repeat steps 3 through 9, as needed to obtain sufficient volume. 11. After a sufficient volume of sediment is transferred to the mixing bowl, homogenize the contents of the bowl using a spoon until texture and color of the sediments appears to be uniform. 12. Transfer sample material to laboratory-supplied sample containers, label samples, and pack for shipping per laboratory instructions. Page 3 of 4 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _appendix B procedures.doc

25 Culvert 105 Sediment Chamber MH-N9 at Margaret Droman Park 2007 Early Actions Monitoring and Maintenance Plan Relative to Remedial Work FMC Corporation Middleport, New York 13. Record the following sediment characteristics on the Inspection Form: a. Texture and color b. Presence of debris, oily sheen, odor, or biological structure, if applicable 14. Complete the chain-of-custody forms. 15. With NYSDEC Analytical Services Protocol Category B deliverables, request laboratory analysis of the following: arsenic (USEPA SW-846 Method 6010B) lead (USEPA SW-846 Method 6010B) chlorinated pesticides (4,4 -DDT, 4,4 -DDD, 4,4 -DDE, dieldrin, and BHC isomers) (USEPA SW-846 Method 8081A) C. Procedure 2 for Sediment Sampling: 1. Identify the proposed sample location on the Inspection Form along with other appropriate information collected during sediment sampling activities. 2. Don personal protective equipment (as required by the HASP). 3. Measure the total depth of the water column in the structure by extending the surveyor's rod into the water until it reaches the bottom. 4. Attach the sample tubing to the surveyor s rod at 0.5 times the total water column depth and lower rod through the grate cover of the structure to its base. 5. Utilize the peristaltic pump and tubing to transfer water and sediment directly into the wide mouth jars. Collect between 2 and 3 gallons of water/sediment. 6. Decant the water from the wide mouth jars. 7. Photograph the sediment and fill out the Photograph Log (included with the Inspection Form). 8. Transfer the sediment from the wide mouth jars to a stainless-steel mixing bowl (or a disposable aluminum mixing tray) for homogenization. 9. A minimum of 4 ounces of sediment is required for testing each sample; therefore, if a split sample is requested, additional volume will be required. Repeat steps 3 through 8, as needed to obtain sufficient volume. 10. After a sufficient volume of sediment is transferred to the mixing bowl, homogenize the contents of the bowl using a spoon until texture and color of the sediments appears to be uniform. 11. Transfer sample material to laboratory-supplied sample containers, label samples, and pack for shipping per laboratory instructions. 12. Record the following sediment characteristics on the Inspection Form: a. Texture and color b. Presence of debris, oily sheen, odor, or biological structure, if applicable 13. Complete the chain-of-custody forms. 14. With NYSDEC Analytical Services Protocol Category B deliverables, request laboratory analysis of the following: arsenic (USEPA SW-846 Method 6010B) lead (USEPA SW-846 Method 6010B) chlorinated pesticides (4,4 -DDT, 4,4 -DDD, 4,4 -DDE, dieldrin, and BHC isomers) (USEPA SW-846 Method 8081A) Page 4 of 4 G:\Project Docs\Div20\lryfun \LAR11\FMC Middleport\MHN9 Plan Final\ _appendix B procedures.doc

26 Appendix C Copy of Record Drawings for 2007 Early Action Remedial Work Conducted at Margaret Droman Park

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