FOTH - PHASE 1 2007-2008 REMEDIAL ACTION FINAL SUMMARY … · Figure 2-2 Phase I - Sile...

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Lower Fox River Phase 1 2007-2008 Remedial Act ion Final Summary Report

IDe Pere, Wisconsin Project I.D.: 08N009

INCR Corporation & U.S. Paper Mil ls Corporation Oe Pere, Wisconsin

January 12 ,2009

#Fotli - ^

LOWER FOX RIVER

PHASE 1 2007-2008 REMEDIAL ACTION

FINAL SUMMARY REPORT

Prepared for:

NCR Corporation

and

U.S. Paper Mills Corporation

For submittal to:

Wisconsin Department of Natural Resources

U.S. Environmental Protection Agency

Prepared by:

#Foth Foth Infrastructure & Environment, LLC

January 12, 200C|

Table of Contents

List of Tables iii List of Figures iii Lift of Appendices iii .Acronyms iv Ziistribution List vi 1 fMTRODUCTlON 1

1.1 Consent Decree Objectives 2 1.2 ROD Remedial Goals 2 1.3 Project Organization, Responsibility and Authority 3

1.3.1 NCR Corporation and U. S. Paper Mills Corp 3 1.3.2 Fox River Phase 1 RA Project Coordinator- Roger McCready, NCR 4 1.3.3 Respondents' Project Manager - George Hicks, Shaw 4 1.3.4 Project Resident Engineer - Jim Hutchison, Foth 5 1.3.5 Laboratory Quality Assurance/Quality Control - Eddie Weaver, Shaw 5 1.3.6 Technical Support- Anchor 5 1.3.7 Respondents' Construction Contractor- SES 5 1.3.8 SES Project Manager- Dave Burger 5 1.3.9 SES Site Superintendent - Jack Morrison 6 1.3.10 SES Subcontractors 6 1.3.11 Agency Involvement 6

1.4 Project Notifications and Permitting Activities 7 1.5 Remedial Action 7

1 5.1 Remedial Action Schedule 7 1.5.2 Regulatory Submittal Summary 8

2 DEMOBILIZATION : 12 2.1 In-River 12 2.2 Upland 15

2.2.1 Equipment Demobilization 16 2.2.2 Water Quality Management 17 2.2.3 Asphalt Removal/Recycling 19 2.2.4 Gravel (Crushed Stone) Removal 20 2.2.5 Synthetic Liner Removal 21

3 SITE RESTORATION 22 3 1 Stone Characterization 22 3 2 Clearing and Grubbing 23 3.3 Re-Grading 23 3.4 Re-Grading Documentation 24 3.5 Subgrade Characterization 25 3.6 Topsoil Placement, Discing 26 3.7 Wetland Development 26 3.8 Post Construction Monitoring 27

4REF1:R£NCES 28

Sun m.u7 Report :r l f 7-20118 ii January 12, 2009 Lov^crFoit K ivc r - - ^hase ! Remedial Action

Table of Contents (continued)

List of Tables

Table 1-1 Remedial .Action Schedule — Planned vs. Actual Table 1-2 Remedial Regulator)- Submittal Summary Table 2-1 Hand-Held Turbidity Readings Collected During In-River Demobilization Activities Table 2-2 Surface Water and Effluent Sampling Results During 2008 Demobilization Table 2-3 Asphalt Pad Sample Results Table 2-4 Gravel Pad Sample Results Table 3-1 Stone Fill Sample Locations Table 3-2 Survey Schedule

List of Figures

Figure l-I Phase I Project Dredge Area Figure 1-2 Organization Chart Figure 2-1 Phase 1 - Site Deconstruction Asphalt & Gravel Drive Sample Locations Figure 2-2 Phase I - Sile Deconstruction Approximate Liner Location Figure 3-1 Phase 1 - Site Deconstruction Stone Fill Sample Locations Figure 3-2 Phase 1 - Post-Closure Site Layout Figure 3-3 Phase 1 - Stone Fill Material Thickness Figure 3-4 Phase 1 - Process Facility Subgrade Sample Locations Figure 3-5 Phase 1 - Post-Closure Channel Area

List of Appendices

Appendix A Tables

Appendix B Post Construction Stormwater Operation and Maintenance Plan

Summary Repoil 2007-2008 iii January 12.2009 Lower Fox River — Phase 1 Remedial .ALUCII

List of Acronyms

.^.nchor

.\/DT

^OD

CD

CERCLA

CQAPP

( R Z

DCU

DMU

l-Dlh

(lAC

(IIS

GPS t;prn

HDPE

Hydro.seed

KS

LTL

McKeefp'

ni l

NCR

NE

OU

C7.

Pace

F.\H

PCB

pH

ppm

ProSource

OA

C'APP

oc PAL

P \

PA?

PAWP

Respondents

POD

Anchor Environmental, LLC

Agency/Oversight Team

biochemical oxygen demand

Consent Decree

Comprehensive Environmental Response, Compensation Construction Quality and Assurance Project Plan

contamination reduction zone

cubic yard(s)

dredge certification unit

dredge management unit

Foth Infrastructure & Envirormient, LLC

granulated activated carbon

geographic information system

global positioning system

gallons per minute

high density polyethylene

Hydroseed of Wisconsin Kohnogorov-Smimov

Lower Tolerance Limit

McKeefry «fe Sons Excavating

millimeter

NCR Corporation

Northeast

Operable Unit

ounce(s)

Pace Analytical Services, Inc.

polynuclear aromatic hydrocarbons

polychlorinated biphenyl

power of hydrogen

parts-per-million

ProSource Technologies, Inc.

quality assurance

Quality Assurance Project Plan

quality control

remedial action level

Remedial Action

Remedial Action Plan

Remedial Action Work Plan

NCR Corporation and U.S. Paper Mills Corporation

Record of Decision

and Liability Act

Siinrran R.-po1 201)7-2008 Lti-.e] Fox ^ iviT - - Phase 1 Remedial Action

January 12, 2009

List of Acronyms (continued)

RTK Real Time Kinematic

SAP Sampling and Analysis Plan

SAP/QAPP Lower Fox River Operable Units 2 to 5 Pre-Design Sampling Plan

SCCU sand cover certification unit

SCMU sand cover management unit

SES Sevenson Environmental Services, Inc.

Shaw Shaw Env ironmental and Infrastructure, Inc.

SOW Statement of Work

SWAC surface weighted average concentration

TSCA Toxic Substances Control Act

TSS total suspended solids

|ig/Kg micrograms per kilogram

u s e s Unified Soil Classification System

USEPA U.S. Environmental Protection Agency

Veolia Landfill Veolia Hickory Meadows Landfill

VOC volatile organic compound

WDNR Wisconsin Department of Natural Resources

WPSC Wisconsin Public Service Corporation

ZID zone of initial dilution

Summary Report 2007-200J! Lower Fox River — Phase 1 Remedial Act,on

January 12.2009

Distribution

lames Hahnenberg L ' S E P A Project Coordinator ^Jnited S:ates Envirormiental Protection Agency 77 West Jackson Blvd. (SR-6J) Chicago. IL 60604-3590

1 CD Copy

^ ic:hard Ivlurawski ijflce of Regional Counsel I .S. Environmental Protection Agency Region 5 "ij West .lac<son Blvd. C hicago, IL 60604

I CD Copy

Bruce Baker ^ ''DNR Project Coordinator VN/isconsin Ciept. of Natural Resources

01 S. Webster St. - AD/8 Madison. Wl 53703

1 CD Copy

Jay Grosskopf Boldt J'echnical Services 2525 North Roemer Rd. Appleton WI 54912

1 CD Copy, 3 Paper Copies

P'ichard Fox Natural Resource Technology 2J1713 West Paul Rd .#D Pewaukeo. V/I 53072

1 CD Copy

Jennifer Kahler ^Jatural Resource Technology 2:.713 West PaulRd#D Pcwaukec, V/I 53072

1 CD Copy

Gary Kincaicl Vv'DNR On-Site Engineer Wisconsin Dept. of Natural Resources 2':'84 Shaivario A\ e. Green Bay, WI.54313

I CD Copy

Poger McCrc;ady C orporate Environmental Engineer ^ in^ ("orjjoration 1 :'00 S. Patterson Blvd. WHQ-4 D,.iyton OH 45479

I CD Copy

Si rnmarx K:po:1 2007-2008 L(.i' cT Fox Rivtr - - Phase 1 Remedial Action

January 12.2009

Distribution (continued)

John M. Heyde 1 CD Copy Sidley Austin, LLP One South Dearborn St. Chicago, IL 60603

Jeffrey T. Lawson 1 CD Copy Project Control Companies. Inc. 20 Trafalgar Square Nashua, NH 03063

Larry Pattengill 1 CD Copy Sonoco - U.S. Paper Mills Coi"p. Consultant 716 Fort Howard Ave. P.O. Box 5850 DePere, WI 54115-5850

Clay Patmont 1 CD Copy Anchor Environmental, LLC 1423 Third Ave. Suite 300 Seattle, WA 98101

Paul LaRosa I CD Copy Anchor Environmental, LLC 10 New England Business Ctr. Dr. Suite 102 Andover, MA0I8I0

Jim Hutchison 1 CD Copy, 1 Paper File Copy Foth Infrastructure & Environment, LLC 2737 S. Ridge Rd. Green Bay WI 54307

Matt Oberhofer 1 CD Copy Foth Infrastructure & Enviromnent, LLC 2737 S. Ridge Rd. Green Bay WI 54307

Summary Report 2007-2008 vii January 12. 2009 Lower Fox River — Phase 1 Remedial Actini

Section 1 Introduction

1 INIRODUCTION

Fo:h Infrastmclure & Environment, LLC (Foth) has prepared this Lower Fox River Phase 1 2007-:'0n8 Remedial Action Final Summary Report (Foth, 2008) (2007-2008 RA Summary Report) on Dehalf of N(?R Corporation (NCR) and U.S. Paper Mills Corporation. (U.S. Mills) to document project iemobilization and site restoration.

[n February 2008, Shaw Environmental & Infrastructure, Inc. (Shaw), Foth, Anchor Environmental, LLC (,\nchor) and Sevenson Environmental Services, Inc. (SES), prepared a Lower Fox River Phase I 2007 Remedial Action Draft Summary Report (Shaw et al., 2008) (2007 RA Draft Summary Report) on behalf of NCR and U.S. Mills. The 2007 RA Draft Summary Report was submitted to iJocument fnal dredge elevations. The U.S. Environmental Protection Agency (USEPA) and the Wisconsin Department of Natural Resources (WDNR) acknowledged the submission of the 2007 RA Draft Summary Report in a letter dated April 25, 2008. The 2007 RA Draft Summary Report is ;iicoip(3ratec by reference in this 2007-2008 RA Summary Report.

I he USEP.\ and the WDNR (the "Response Agencies") have requested this 2007-2008 RA Summaiy fiepor a;; part of activities under a Consent Decree (CD) and accompanying Statement of Work (SOW I eitei-ed into between the USEPA and WDNR (the "Response Agencies"), and NCR and 1- .S. Mills (the "Respondents") in March 2006. The CD required the Respondents to perform the Phase I PLemedial Action within 0U4 of the Lower Fox River in Green Bay, Wisconsin (the "Phase I Project") (USEPA 2006).

The Phase 1 Project area is located on the west shore of the Fox River, just downstream of the De Pere Dan, located in the city of De Pere, Wisconsin. In order to achieve the cleanup objectives outlined by the CD, the sediments within the Phase I Project limits were removed by hydraulic dredging, transported to an on-shore treatment site, dewatered, and loaded in trucks (after achieving the minimum landfill strength requirements) for offsite disposal.

The dredge area extended approximately 750 feet out from shore and was approximately 1,100 feet wide, i:o\ering approximately 20 acres (22 acres including anticipated side slopes), as shown on F gure 1 -1 . A portion of the sediments targeted for removal from the Phase 1 Project required handling and disposal under the Toxic Substances Control Act (TSCA). All other sediment dredged from the PliEise J Project area was disposed of as non-TSCA waste.

7[ie major tasks involved in performing the work were generally as follows:

• Eieir.onstrating compliance with the substantive requirements of regulations under which permits would have been required but for the "permit bar" under the Comprehensive Ens'ironmental Response, Compensation and Liability Act (CERCLA)

• Additional treatability studies to support the design of the dewatering and wastewater treatment plant

• Mobilization and site preparation including proper erosion control features • Installation and maintenance of an in river turbidity curtain containment system for

dredging and sand cover operations • Mechanical debris removal operations as required, prior to, and during dredging

0 Derations • Hyd'auiic dredging to remove targeted sediments in the Phase 1 Project area • Processing and dewatering of the dredged sediments • Transportation of dewatered sediments removed from the vertical and horizontal extents

d;lirieated as TSCA, based on remedial design sampling, to an appropriate TSCA landfill

^umin.ir^ Rcptrt200"-;008 1 January 12. 2009 1 cwci Fc X Ri.er-- Ph isc 1 Remedial Action


Transportation of dewatered sediments removed from the areas, not otherwise delineated as TSCA, to an appropriate landfill subtitle D landfill Treatment of filtrate and all other wastewater generated by the processing and dewatering operations through an on-site temporary wastewater treatment plant with discharge within the work zone through a submerged diffuser Monitoring of treated water discharged back to the ri\'er Monitoring of surface water (turbidity) during in-water operations Post-dredge bathymetric sur\'eys and sediment sampling to verily that cleanup objectives were achieved Placement of a sand cover over a portion of the dredge areas, based on the results of post-dredge sediment sampling Post-sand cover sampling to verify that required thicknesses had been achieved Demobilization and winterization Monitoring of site between 2007 and 2008 dredging seasons

1.1 Consent Decree Objectives

The following cleanup objectives for the Phase 1 Project were set forth in the Phase 1 CD:

•

•

The final post-dredge confirmatory bathymetric surveys of the Phase 1 Project area must indicate that sedimeni removal to an agreed-upon set of target elevations (designed to achieve removal of sediment above 1.0 part per million [ppm]l has been achieved over at least 95% of the Phase 1 Project area.

The final post-removal confirmatory sediment sampling within the Phase 1 Project area must indicate that all sediments containing polychlorinated biphenyls (PCBs) at a concentration of 50 ppm or greater ha\ e been removed.

• If final post-removal confirmatory sampling revealed that sediment with PCB concentrations exceeding I.O ppm remains within the Phase 1 Project area, the Respondents must place a minimum of 6 inches of "clean sand" over that area, consistent with the Record of Decision (ROD). Any clean sand used for this purpose must be received from an off-site source. The Respondents also have the option of performing additional dredging to address sediments with PCB concentrations exceeding 1.0 ppm remaining after removal of sediment to the required project limits.

• The Respondents must establish side slopes adjacent to the Phase 1 Project Area that are sufficient to ensure the stability of remaining sediments. All side slopes with surface PCB concentrations exceeding 1.0 ppm must be covered with a minimum of 6 inches of clean sand, consistent with the ROD.

1.2 ROD Remedial Goals

While achieving the CD objectives was required, the Respondents also had the option of satisfying the remedial goals described in the 2007 Lower Fox River ROD Amendment (USEPA and WDNR, 2007) in the Phase I Project area. As presented in the Agency-approved Optional SAP Addendum for Phase 1 Verification of Project Completion (Shaw et al., 2007a), the Phase I post-dredge verification sampling and analysis activities performed in the various dredge certification units (DCUs) were aimed at determining whether removal (dredging) actions within these areas had achieved the ROD Amendment remediation goals.

Summary Report 2007-2008 2 January 12.2009 Lower Fox River — Phase 1 Remedial Actic>ji


The ROD .Amendment used the term "generated residuals" for sediment that was re-suspended and n;-deposited on the surface of newly-dredged areas (assumed to be within the top six inches of the sediment, pijssibly dependent on dredge technique), and it used the term "undisturbed residuals" for •;ediment that was more than six inches from the surface of the sediment. If post-removal jonfirmator/ sampling in a sediment removal area revealed generated residuals with PCB .oncentriitions exceeding the 1.0 ppm PCB remedial action level (RAL), then the following (jquirements can be applied for management of the generated residuals:

• Generated residuals with a PCB concentration between 1.0 ppm and 10.0 ppm must be covered with at least 6 inches of clean sand from an off-site source (referred to as a "residual sand c()\er") if placement of a residual sand cover in the area was necessary to meet the surface weighted average concentration (SWAC) goal for the operable unit (OU) (i.e., a SWAC of 0.28 ppm PCBs in OU 3 and a SWAC of 0.25 ppm PCBs in OU 4).

• Gen£:rated residuals with a PCB concentration equal to or greater than 10.0 ppm must the subject of an engineering analysis to determine next steps, which could include: (I) removal (typi;ally by re-dredging) in accordance with the sediment removal requirements specified above; (2) capping, if the eligibility criteria for that alternate remedial approach can be met, as specified below; or (3) placement of a residual sand cover.

I'or management of undisturbed residuals:

• Undisturbed residuals exceeding the 1.0 ppm PCB RAL must be the subject of an engineering analysis to determine next steps. Unless the Response Agencies approve use of a different resid jals management approach in a particular area within an OU, undisturbed residuals with a P<rB concentration exceeding the 1.0 ppm PCB RAL must be removed (typically by re-dredging) in accordance with the sediment removal requirements specified above. However, as a result of the engineering analysis, the Response Agencies may approve use of a different residuals management approach (such as a cap or a residual sand cover) for undisturbed residuals in limited areas.

1.3 Project Organization, Responsibility and Authority

' h e Phase 1 Project organizational structure includes the Respondents (NCR and U.S. Mills); the Respondents' Construction Management Team (including Project Manager, Technical Director, Resident Engineer, Engineering Support Team, and other support personnel); the C'ontractor and its subcontractors; and the Response Agencies (USEPA and WDNR, along with an Agency/Oversight Tegm j A'Ol]). The project organization chart is provided in Figure 1-2. Details of the roles and res])onsibilit es for each of the key personnel are provided in the following sub-sections. Additional infomiation regarding project responsibilities and authorities is provided in the Phase 1 (^onstniCiiur: Quality Assurance Project Plan (Shaw and Anchor, 2006a).

The project organization chart is provided in Figure 1-2. Details of the roles and responsibilities for each of the key personnel are provided in the following subsections.

1 3 1 ^JCR Corporation and U.S. Paper Mills Corporation

NCR and U.IS. Mills entered into a CD to perform the Lower Fox River Phase 1 R/\.. NCR and LLS. Mills funded the project and provided overall project coordination for the Phase 1 Project.

S iinnary Fepcrt :007-2O08 3 January 12. 2009 L,'.vcr Fo> Ri\er - Phase 1 Remedial Action


1.3.2 Lower Fox River Phase 1 RA Project Coordinator — Roger McCready, NCR

Roger McCready was responsible for the following tasks during the 2007 RA:

Monitored overall progress and compliance with the Lower Fox River Phase 1 RA Work Plan (RAWP); Informed the Respondents of significant issues during the 2007 remedial activities and worked with Respondents' Construction Managemeni Team and Contractors to resolve these issues; Communicated with USEPA and WDNR on an ongoing basis regarding significant issues during the 2007 remedial acti\'ities and responded to Agency concerns (after consultation with Respondents' Construction Management Team, Vk-hen needed); Prepared and submitted the R.A Monthly Progress Reports required by the CD with the assistance of Respondents' Construction Managemeni; Team, and others as needed; Reviewed and approved invoices directed to Respondents; and Assisted with public and government affairs as needed.

1.3.:

Geo

Respondents' Project Manager — George Hicks, Shav\

ge Hicks was responsible for the following tasks during the 2007 RA:

Informed Respondents of project progress and any significant issues, and worked with Respondents, the Project Coordinator and the Contractor to resolve significant issues as identified by the Contractor; Communicated with USEPA and WDNR on an ongoing basis regarding day to day operations during the 2007 remedial activities and responded to Agency concerns (after consultation with the Respondents' Project Coordinator and with the Respondents, when needed); Coordinated the development of all RAWPs; Notified USEPA and WDNR of releases or threatened releases when required by the CD and served as a point of contact for Agency officials aind contractors regarding actions to address the release or threatened release; Provided necessaiy project-related approvals as authorized by the Respondents; Reviewed monthly RA progress reports prepared by the Project Coordinator, as required by the CD; Made recommendations to Respondents' Construction Management Team regarding proposed changes in the implementation of the field work and means to reduce costs and/or make the project more effective: Coordinated RA acti\ ities between the Contractor (SES) and the Respondents; Monitored Construction Quality Assurance (CQA) activities; Assisted with public and government affairs as appropriate, including acting as a spokesman and community liaison for Respondents; and Managed activities of subcontractors, who performed site activities on behalf of the Respondents including pre-construction archaeological surveys, bathymetric surveys, environmental monitoring, and post-dredge/cover quality assurance sampling. Contributed to the 2007 RA Draft Summary Report.

Summary Report 2007-2008 4 January 12. 2009 Lower Fox River — Phase 1 Remedial Aclimi


1.3.4 Respondents' Project Resident Engineer — Jim Hutchison, Foth

Jim Hutchison was responsible for the following activities during the 2007 RA:

Implementation of the CQAPP; Managed demonstration of compliance with substantive provisions of WDNR's Chapter 30 regulation; Directed post-dredge bathymetric surveys; Performed and supervised environmental monitoring and quality assurance sampling, including surface water (turbidity), effluent, air quality, sediment removal verification, and sand cover thickness verification; (Coordinated on-site sampling activities in accordance with 2007 Remedial Action Work Plan (Shaw etal., 2007); Performed dewatered sediment strength characterization per landfill requirements; Reported directly to the Respondents' Project Manager and communicated and coordinated activities with SES's Project and/or Site Manager; Assisted Respondents' Project Manager in ongoing communication with USEPA and WDNR regarding project performance and other issues as requested; Mariaged generation of Resident Engineer daily reports; Mar aged the project Sharepoint website; Assisted in performing site monitoring between 2007 and 2008 dredge seasons; and Contributed to this 2007-2008 RA Summary Report.

1.3.5 Laboratory Quality Assurance/Quality Control — Eddie Weaver, Shaw

Eddie Weaver was responsible for the following activities during the 2007 RA:

• Coo:-dinated on-site sampling activities with laboratory and Resident Engineer in accordance with 2007 RAP; and

• Maintained laboratory test data and results.

1.3.6 Technical Support — Anchor

.'\nchoi Environmental, LLC (Anchor) was responsible for the following activities during the 2007 Phase 1 Prc>ject:

• Provided technical support and assistance in developing the 2007 RAP; • Developed Phase 1 Project Sampling and Analysis Plan; and • P-ovided technical support throughout the 2007 RA.

1.3.7 Respondents' Construction Contractor — SES

SF;S \\'as ihe Construction Contractor for the Phase 1 Project. SES managed and performed all on-siie construction activities on behalf of the Respondents. The following subsections summarize the n;5ponsib lities of key SES personnel who performed management roles for the RA..

1.3.8 SES's Project Manager — Dave Burger

E)a\e Burger was responsible for the following tasks during the 2007 RA:

• Responsible for providing overall direction and management of 2007 RA project activities on site including dredging, dewatering, water treatment, and disposal;

Si.iiiiran R.-pel 201) -2008 Lc'.c] Fox iliviT - Phase 1 Remedial Action

January 12.2009


• Responsible for communicating to Respondents' Project Manager regarding project progress and issues needing their involvement for resolution;

• Prepared and implemented contingency plans as described in the CD; • Performed administrative and decision-making activities: • Implemented health and safety plans; • Responsible for maintaining updates to the construction schedule; • Prepared and submitted monthly invoices to Respondents; and • Responsible for coordinating with the Respondent's Project Resident Engineer.

1.3.9 SES's Site Superintendent — Jack Morrison

Jack Morrison was responsible for the following tasks during the 2007 Phase 1 Project:

• Instructed and coordmated activities with field staff; • Coordinated subcontractor and SES schedules; • Ensured that field activities were conducted in accordance with the 2007 RAP; • Ensured that field staff vvere properly trained to perform field activities in accordance

with the 2007 RAP. possessed proper certification (e.g., current Hazardous Waste Operations and Emergency Response [HAZWOPER] training), and complied with medical monitoring requirements;

• Inspected and accepted supplies and equipment; • Communicated construction and operations issues to the project team; • Performed oversight of subcontractor activities; and • Notified the Respondent's Project Resident Engineer when QA bathymetric surveys

were required.

1.3.10 SES's Subcontractors

The main SES's subcontractors were as follows:

• Dixie Environmental - provided chemicals for dewatering and water treatment processes. • Mc Keefry & Sons, Inc. - performed dewatered sediment trucking to non-TSCA landfill. • ProSource Technologies, Inc. - performed poling and! hydrographic surveys.

1.3. II Agency Involvement

1.3.11.1 USEPA's Project Coordinator — Jim Hahnenberg

Jim Hahnenberg was responsible for the following tasks during the 2007 RA:

Reviewed all project deliverables and plans and/or appro\'ed project strategies; Reviewed and approved the 2007 RAP; Provided technical assistance to Respondents' Project Coordinator; Reviewed progress reports detailing work accomplished; Reviewed and provided comments on all reports in draft version prior to their finalization; and Provided USEPA approval of final reports.

Summary Report 2007-2008 6 January 12. 2009 Lower Fox River— Phase 1 Remedial Action


1.311.2 WDNR's Project Coordinator — Greg Hill

Greg Hill was responsible for the following tasks during the 2007 RA:

• Reviewed all project deliverables and plans and/or approved project strategies; • EMrected 2007 RAP review and approval; • Prov ided technical assistance to USEPA and Respondents' Project Coordinator; • Reviewed progress reports detailing work accomplished; • Reviewed and provided comments on all reports in draft version prior to their finalization; and • Provided WDNR approval of final reports.

1.3113 WDNR's Oversight Contractor

Boldt (Coiistiuction and its subcontractors (Oversight Team) operated as WDNR's designated oversight contractor. They provided technical assistance to the WDNR during the 2007 Phase 1 Project.

1.4 Project Notifications and Permitting Activities

LInder the CERCLA, the procedural requirements of federal, state and local permit programs are \v aived, hut ihe substanfive requirements of the programs must still be satisfied. For the Lower Fox River Phase 1 Project the following project notifications and compliance demonstration activities were conducted:

• WDNR Chapter 30 • WDNR Stormwater Management Notice of Intent • Army Corps of Engineers Section 404 Program • City of De Pere Floodplain Zoning Approval

1 5 Remedial Action

I 5 1 l^emedial Action Schedule

Table 1-1 depicts key milestones dates as proposed in the 2007 RAP schedule and actual dates of completion for work performed during the 2007 construction season.

Siminai) l;eport 2f 07-2008 7 January 12, 2009 LMW(r Ft'.-; Ri\er - Phase 1 Remedial Action


Table 1-1. Remedial Action Schedule Planned vs. Actual

Key Milestones

Site kick-off meeting

Begin mobilization to the site

Completion of construction oii'the dewatering and water treatment processes

Mobilization and constmction of the dredging equipment and installation of the silt curtains

Initiation of dredging operations

Initiation of sand cover operations

Completion of dredging operations

Completion of sand cover operations

Demobilization from the site

Key Milestone Dates

June 22. 2006

July 16,2006

November 10,2006

April 27, 2007

May 1,2007

July 1.2007

September 30, 2007

October 15,2007

October 27, 2007

Actual

June 22, 2006

July 16,2006

April 27, 2007

March 23, 2007

May 1,2007

September 5, 2007

November 14, 2007

To be completed by others

November 2007' a. Partial demobilization ocxurred iti November 2007; however, a portion of the sile infrastructure was retained on-site for

anticipated future use in 2008.

1.5.2 Regulatoi7 Submittal Summary

For documentation purposes. Table 1-2 provides a summary of key submittals which substantially met permit requirements of the Phase 1 project.

Summary Report 2007-2008 Lower Fox River— Phase 1 Remedial Actior

January 12.2009

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Section 2 Remedial Action 2008

2 DEMOBILIZATION

Demobilization activities were partial in 2007 due to the potential for 2008 remediation work, which resulted from the completion of Contractor's dredging. Demobilization that occurred in 2007 included the removal of marine equipment from the river and some upland rental equipment. Other on-site equipment was winterized. During the winter of 2007-2008, the decision was made to incorporate the potential 2008 remediation v.ork into the overall OU 2-5 remedial action as it progresses downstream. As a result, demobilization of Phase 1 in-river and upland equipment was completed in 2008. A general list of the 2007 and 2008 demobilization activities along with associated dates can be found in Table 1 of Appendix A.

2.1 In-River

In general, in-water demobilization activities for 2007 included the following:

Deconstruction of temporary dock.

Removal of marine equipment from the project area.

Decontamination of marine equipment.

Removal of sheet piling and silt curtain containment system.

Removal of dredge pipe.

The temporary dock sections were pressure-washed over the river before being placed on the north end of the dewatering pad for storage during the winter season. The dredges, support boats, barges and scows were removed from the river, decontaminated and demobilized off-site for use on other projects. All but two of the sheet piles were removed from the river, decontaminated and placed on the north end of the dewatering pad for storage during the winter season. Approximately 7 sheet piles remained onshore during 2007. Due to low water levels, SES was not able to reach two of the sheet piles on the north end of the dredge area. Leaving the two sheet piles in-placc over the winter season was contingent upon the following:

• The sheet piles were painted orange for high visibility.

• A 2-ft long pole (with colored reflectors) reaching above the piles was placed next to each of the piles to provide \ isibility in the event of significant snow accumulation.

• A white light and a yellow strobe light were placed on each sheet pile.

• The warning lights on the sheet piles were monitored and maintained.

There were no reported incidents regarding the 2 sheet piles in the river over the 2007-2008 winter.

Some of the silt curtain containment system was removed during 2007 following the above referenced decontamination activities; however, due to low water levels and freezing conditions, the majority of the silt curtain was left in the river. When demobilization activities resumed in the spring of 2008, the remaining silt curtain system was removed and disposed of at the landfill. The dredge pipeline was pulled up along the shoreline of the dredge area during 2007, in anticipation of the 2008 dredge activities. The effluent discharge pipeline and marker buoys were left in-place for the winter 2007-2008 season.

Summary Report 2007-2008 12 January 12.2009 Lower Fox River— Phase 1 Remedial Action


/Vs previously stated, a portion of the in-river demobilization activities were conducted in 2008. The 2008 demobilization activities included the following:

• E>econtamination and removal of temporary dock from the river. • Peiroval of marine equipment from the river project area. • E'econtamination of marine equipment. • Removal of sheet piling and silt curtain contairunent system from the river. • Removal of dredge, sand placement and effluent pipe from the river.

Jour ol'the cock pieces previously pressure-washed and stored on site were placed back in the river during thi; 2008 demobilization to create a barge used to remove the remaining sheet piles left in the ri vvr over thi; winter. A backhoe on the barge was utilized to remove the majority of the in-river sheet piles; hov/ever, it was unable to pull out four sheet piles along the shoreline. SES rented a vibrating uni; which v\ as attached to a crane or backhoe. This method allowed the Contractor to remove the sheet piles from the shore on June 19, 2008.

T.M. floating dock pieces, including those used for the barge after in-river activities were completed, \v ere furtiier decontaminated and placed on flatbed trailers for transporting off-site. Support boats and scows remai ling on-site were also placed on flatbed trailers and transported off-site.

The remaining turbidity curtain left in the river over the winter season was brought to shore using Jon boats, on Jurie 11. 2008 and was placed on the dewatering pad for ultimate disposal at the landfill.

On June 23, 2008, the anchor weights were removed from the effluent discharge pipeline using the backlioe on the barge. The effluent pipe and marker buoys were then pulled up on shore, the effluent pipe cut i ito sections, and decontaminated on the pad in the south yard using pressure washers before hieing stackdJ on flatbed trailers and transported off-site over the period June 10, 2008 through Augu.st 1. 2008.

During the 2008 demobilization activities, ProSource was sub-contracted by SES to perform a poling siir/ey of the dredge area. A Foth surveyor observed and performed checks periodically during the sur.'ey. A hydrographic survey was also attempted by SES/ProSource, on June 24. 2008, through June 26. 2008; however, attempts were unsuccessful due to apparent equipment failure.

During in-ri\'er activities, primarily when the barge was active in the water, Foth mionitored the water ciuality b)' ta<ing hand-held turbidity readings. River flow, weather changes, open/close De Pere dam c.attjs, lite were also monitored during in-river activities. Turbidity readings are summarized in Table M .

Siiminai> Keport 2(07-2008 13 January 12.2009 Lower Fo\ Ri\er - Phase 1 Remedial Action


Table 2-1. Hand-Held Turbidity Readings Collected During In-River

Demobilization Activities

Date

6/13/2008

6/13/2008

6/13/2008

6/13/2008

6/13/2008

6/14/2008

6/14/2008

6/19/2008

6/19/2008

6/19/2008

6/19/2008

6/20/2008

6/20/2008

Time

08:25

08:25

13:27

13:29

13:33

09:10

09:10

11:54

11:54

11:54

11:54

15:30

15:30

Location

In approximate location of former upstream nirbidit>' raft In approximate location of former downstream turhidit> raft - downstream of sheet pile

50 yards north from the A.M. upstream reading

In approximate location of former upstream Uirbiditv raft In approximate location of fomier downstream Uirbiditv' raft

In approximate location of former upstream nirbidirv raft In approximate location of former downstream Uirbiditv raft

In approximate location of former upstream Uirbiditv raft In approximate location of former downstream turbidirv raft Between upstream and downstream locations -near former effluent outfall Nortli side of the dock'"

In approximate location of former upstream turbidity raft In approximate location of former downstream Uirbidiry raft

Turbidity ReafUag (NTUs)

156.4

190.2

297.8

155.4

151.4

186.8

189.7

I8.I

29.0

26.8

11,9

244.1

44.8

Noted CoBdMoBS

10 of 11 flood gates open, high turbidity due to relatively high flows from recent precipitation

10 of II floodgates open. Brown County under flash flood advisory

Water level high, flowing fairly fast, 6 of 11 flood gates open, little wave action (0.25-0.5')

Strong flow from dam, fish spawning activity in upstream location

6/20/2008

6/20/2008

6/23/2008

6/23/2008

15:30

15:30

10:22

10:22

Between upstream and downstream locations -near fomier effluent outfall North side of the floating dock

In approximate location of former upstream turbidity raft Middle of the dredge area along the east edge

30.0

13.8

30.6

36.2

Breezy, waves _ ~0.25-0.75', 5 of 11

flood gates open.

6/23/2008 i 10:22 In approximate location of former downstream 27.6 \ turbidity raft

moderate to strong flow

6/23/2008 10:22 East side of the floating dock 23.7

Notes: (1) Floating dock located east of former V-tank on eastern end of dewatering pad.

Prepared by: TMK1 Checked by: WRV

Summary Report 2007-2008 Lower Fox River — Phase 1 Remedial Acti iii

January 12.2009

http://~0.25-0.75'


2.2 Upland

In general, demobilization and winterization activities for 2007 of the upland facilities included the fcllowing:

• Eiecontamination of equipment, as necessary; • V isual inspection of erosion control features; repairs and additions made as necessary; • E'eirobilization of equipment; and • Backwashing/flushing the water treatment system.

Dewatering and water treatment equipment and other ancillary equipment, including the backhoe, front-end loader, presses, shakers, and polymer tanks, pumps and light plants were pressure-washed Etter all sediment had been loaded off of the pad. The asphalt processing/dewatering pad and concrete bar-ier blocks were also pressure-washed. The decontamination water which went to the sump was pumped tirough the water treatment system and discharged to the river.

^ isual inspei;tions were made of the erosion control features, and repairs were made as necessary. A : 6-ft section of silt fence was placed across the docking area for protection against overflow discharge from the ilewatering pad. Sand bags were used to reinforce the silt fence.

The water trcratment system was backwashed and blown out to protect the water lines from freezing.

The water treatment system was not operational during the 2007-2008 winter season. The asphalt processing, dswatering pad was designed to slope towards the sump areas. Overland flow from melting snow'ice anc. precipitation during winter 2007-2008 pad overflow events was directed towards the silt fence across the docking area to the Fox River. An overland flow from the pad to the river occurred on Janaar)' 7, 2008 due to relatively high (above freezing) temperatures and precipitation in the form of rain. It is estimated that approximately 30,000 gallons of surface water was discharged to the Fox River. Mr. CJary Kincaid, of the WDNR, observed site conditions prior to and during discharge.

During the discharge event, the surface water was sampled at the pad and tested for the effluent parameters that were analyzed for during project production. The results are shown in Table 2-2 (Section 2.2.2).

The demobilization activities of the upland facilities for 2008 included the following:

• Removal of office, break, storage, lab and tool trailers; • Removal of all heavy equipment including excavators, dozers, loaders, forklifts, skidsteer,

pumps, filter presses, mix tanks, filter vessels, shakers, de-sanders, dredges, marine debris removal equipment, and cranes;

• Breakdown and removal of the dewatering, waste water treatment plant, and sand placement equi]3ment;

• Removal and recycling of asphalt from the processing and staging areas; • Removal and load-out of gravel under the asphalt from the processing and staging areas; • Removal and disposal of the geotextile and geosynthetic liners from the processing and staging

ai^eas; • Visual inspection and collection of near surface soil samples to verify that no project-related

PCBs remain; • Removal and disposal of stone fill with elevated levels of PCBs;

Su nnaty kepi.rt 2C07-2I)OS 15 January 12, 2009 I. civcr Fc.\ River - Pha.se 1 Remedial Action


• Re-grading of stone fill to bring elevation of area within original floodplain back to approximate pre-project grades; and

• Decontamination of equipment, as necessary.

The following sections discuss upland de-mobilization activities in further detail.

2.2.1 Equipment Demobilization

Upland deconstruction and demobilization activities began on June 9, 2008 with dismantling water treatment piping and removing tent structures over the filter presses. Water treatment, dewatering and sand placement equipment \\ as dismantled, decontaminated, placed on flatbed and lowboy trailers and transported off-site. Decontamination of this equipment was accomplished using biodegradable cleaning products, scrub brushes, hoses and pressure washers.

The filter covers were removed from press plates and loaded into roll-off dumpsters for disposal in the Veolia Hickory Meadows Landfill (Veolia Landfill). The press plates were decontaminated, removed from the presses, stacked onto pallets, shrink-wrapped in plastic and secured with metal bands for load-out. Sediment and excess granular material were removed from the shakers and presses and stockpiled near the northeast comer of the processing /staging area in a containment area for storage and/or dewatering prior to placement into lined roll-off dumpsters for disposal in the Veolia Landfill. The remaining sediment and sludge from the bottom of seven of the mix tanks was removed by hand using shovels, scrapers and wheel barrows and placed on the sediment containment area. The spent filter media was flushed from the filter vessels onto the pad and placed either into unlined roll-off dumpsters or stockpiled on the pad for dewatering prior to placement into lined roll-off dumpsters for disposal in the Veolia Landfill. The remaining media and sludge in the bottom of the filter vessels and the last three mix tanks were pumped out by a Stordeur Sanitation pump truck and discharged into the sediment containment area for dewatering prior to load-out to the Veolia Landfill. The presses, mix tanks and filter vessels were cleaned inside and out prior to transport off-site. After the majority of the sediment and filter media were removed from the pad and stockpiled in the sediment containment area, Quikrete Portland Cement was amended to it. The material was then loaded into roll-off dumpsters and transported to the Veolia Landfill.

Equipment and supplies from the storage area at the south end of the site were brought to the processing/ staging pad for decontamination prior to load-out. Scows were utilized on-site for storage; when SES no longer had use for them, they were decontaminated on the processing /staging area and transported off-site. The structures delineating the contamination reduction zone (CRZs) in the marine staging area and at the south end of the pad were demolished, placed in roll-off dumpsters and transported to the Veolia Landfill.

Throughout the demobilization process, liquid accumulating in the fuel storage basin was pumped into either empty polymer totes and loaded out by Garrow Oil or pumped directly into Garrow Oil storage tanks. After the barrels and tanks were relocated from the fuel storage basin to the dewatering pad, the fliel storage basin liner was removed and disposed of in the Veolia Landfill.

The wood ties used as a platfonn during sediment load-out, the concrete barrier blocks, miscellaneous tools, hoses, cables, and wires were decontaminated and placed on flatbed and lowboy trailers for transport off-site.

Empty Veolia and Midwest Metals roll-off dumpsters were frequently delivered and full ones loaded out as necessary throughout the demobilization process. Metal determined to be scrap after decontaminafion was completed, was placed into the Midwest Metals roll-off dumpster for recycling.

Summary Report 2007-2008 16 January 12, 2009 Lower Fox River — Phase 1 Remedial Actinti


.'Kfter the majority' of the equipment was removed from the dewatering pad, the asphalt pad itself was decontaminated using methods including hand-sweeping/scraping, sweeping with a rotary broom, hosing with water and pressure washing using metered municipal water.

One mix tarL<, one sand filter vessel and one granular activated carbon (GAC) filter vessel were left on-site until all 3ther equipment was decontaminated and removed from the pad to allow for treatment of the water accumulating on the pad. When the majority of the equipment and aspheJt pad were cl(;contaminated, the water on the pad and stored in the final mix tank was treated and discharged, then the mi> tank itself was decontaminated. The filter vessel area was then prepared for filter vessel flushing and decontamination. Concrete blocks were placed on the north and south sides of the area. A silt fence and layer of sand were placed against the northern barrier to fiher water released from the f i lt(;r vessels. Wash water and spent filter media flushed from the vessels, were pumped into a Stordeur Sanitation pump truck and transported to the Veolia Landfill. The filter vessels were then cli:;contaminated and transported off the pad and ultimately off-site. The concrete retaining blocks were di;contaminated and placed on the U.S. Mills property and/or transported to the McKeefry & Sons I;:<cavatirig (McKeefry) yard. The asphalt pad in the former filter vessel area was then decontaminated; water and remaining filter media were pushed towards the northeast (NE) comer sump, which was pumped iito the Stordeur Sanitation truck. Once decontamination of the pad was completed, water at cumulating on the pad was pumped directly to the river, filtered through hay bales and silt fence.

Tiie water line supplying municipal water to the dewatering pad was cut into sections, placed onto a flatbed trailer and transported off-site. The connection to the water main located in Fort Howard Street and meter valve were removed and capped by Competitive Water and Sewer Company on September 1 9, 2008.

>'0S Ellec trie discormected electrical cables from the machinery/equipment/project trailers. Wisconsin Public 5er\'ice Corporation (WPSC) disconnected and removed electrical lines, transformers, security 1 ights and power poles from the site. SES shut off the water supplied by the city of De Pere and rerroved he metering equipment.

2.2.2 Water Quality Management

Prior to decontamination activities on the dewatering pad, water accumulating on the pad during precipivation events was allowed to be discharged direcfly to the river (as approved by A/OT). Water \v a.' directly discharged to the river on July 25, 2008. The water was pumped from the sump in the Iciwest portiC'n of the pad (NE comer sump) and filtered through a silt fence prior to discharge to the ri'/cr.

Once decontamination activities began on the pad, all water accumulating on the pad due to cticontamination of equipment and precipitation events was required to be treated before being c ist:harged to the river. Using a pump and a 4-inch hose, water was pumped out of the NE comer sump i ito a mi.>. ta ik. At times, up to three mix tanks were utilized for storage depending on the quantity' of V, ater requiring treatment. From the mix tank, water was pumped through one sand filter vessel and crie GAC filler vessel prior to being discharged to the existing rip rap drainage swale outfall located scuth of fie dewatering pad.

During each discharge event, samples were collected for the same effluent parameters analyzed during t le 2007 reiriedial action (with the exception of low-level mercury). The samples were collected on a time and flow-proportional basis. During a given sampling event, an approximate one-liter grab siimple was typically collected every 10 to 20 minutes depending on the quantity of water stored in the

Su unary Fepc.n2C07-2008 17 January 12.2009 l.i ivcr Fc?; Ri\er - Pha.'.e 1 Remedial Action


tanks, the length of time expected for discharging and the flow rate of the discharge. If the flow rate changed during the sampling event, the time between samples was adjusted accordingly. Each grab sample was placed on ice for preservation during the samipling event. After discharging was complete, the individual grab samples were poured into a single plastic jug (10-liter jug used in the ISCO sampler during the 2007 remedial action), homogenized and transfened into appropriate laboratory supplied sample bottles for total suspended solids (TSS), PCB, ammonia, power of hydrogen (pH), and biochemical oxygen demand (BOD) analyses. The samples v ere placed in a cooler containing ice and delivered to Pace Analytical Services, Inc. (Pace), a state of V isconsin certified laboratory, for analysis. The results of the effluent samples are summarized below in Table 2-2.

Table 2-2. Surface Water and Effluent Sampling Results During 2008 Demobilization

SanqikDate (INscharge

Date) Sample ID

Performance Standards

1/7/2008

6/25/2008

6/30/2008

7/2/2008

7/2/2008

7/3/2008

7/8/2008

7/9/2008

7/14/2008

7/16/2008

7/16/2008

7/17/2008

7/22/2008

7/23/2008

4-RA-08-Phase 1 -EF-170

4-RA-08-Phase I -Demob-EF-01

4-RA-08-Phasel-Demob-EF-02

4-RA-08-Phase 1 -Demob-PW-02

4-RA-08-Phase 1 -Demob-TW-01

4-RA-08-Phase 1 -Demob-EF-03

4-RA-08-Phase 1 - [)emob-EF-04

4-RA-08-Phasel-Demob-EF-05



4-RA-08-Phase 1 -Demob-EF-07-Dup 4-RA-08-Phasel-Demob-EF-08

4-RA-08-Phase I-Demob-EF-09


Total PCBs

<0.5 ne/L <0.24

<0.23

<0.23

<0.23

0.39'"

<0.23 <0.29

<0.23

<0.23

<0.26

<0.26 <0.23

<0.23

<0.23

BOD (ms/L)

No Limit

<2.0

4.!^

3.0 8.6

16.6

4.8

<2.0

3.:>

2 'i

2.0

2.0 <2.0

<2.0

<2.0

pH

6-9 7.1

6.5

6.8 7.7

7.4

7.1

6.7

6.8

7.0

7.0

7.0 6.9

6.9

6.9

TSS(iiiE«.)

5mg/L/IOmg/L" ' 25

6.9

10.2

38.2

31.3

9.8

1.5 0.94'"

1.2

2.5

2.3 4.3

0.9'''

0.8'"

Ammonia Nta-egen (mm

150mg/L'" <0.5

18.7

5.4

0.92

1.3

6.1

2.5 1.2

1.3

1.1

l.I 1.3

2.1

1.6

Notes: (1) For TSS, the performance standards are 5 mg/L monthly average and 10 mg/L daily maximum. (2) For ammonia, the performance standard is 24.28 mg/L, which is equivalent to 150 mg,/L at the point of discharge. (3) Analytical result flagged with ",l" in lab report meaning the value is estimated above the adjusted method detection limit

and below the adjusted reporting limit. Prepared by: TMKl Checked by: DJM4

As seen above in Table 2-2, on July 2, 2008, grab samples of the water on the dewatering pad (4-RA-08-Phase 1-Demob-PW-02) and of the water in mix tanks 2 and 3 (4-RA-08-Phasel-Demob-TW-01) were collected in order to determine whether or not decontamination water (specifically that stored in the mix tanks) needed to be treated or could be discharged directly to the river. Based on these results, the A/OT detennined that all water, including that accumulating due to precipitation events, would require treatment prior to discharging to the river.

At times during discharging events, the sand filter vessel required backwashing. The water from the mix tank was redirected up through the sand filter media and allowed to discharge back onto the pad where it would then be pumped back into a mix tank or pumped directly through the filters for treatment prior to discharging to the river.

Summary Report 2007-2008 Lower Fox River — Phase 1 Remedial Action

January 12,2009

Section 2 Remedial Action 200S.

y\.s pari of water quality management, the silt fence along the east side of the site was continuously rna ntained and restored during demobilization activities. Based on A/OT and Foth inspections and rccomrnendftions, repairs and additions to erosion control measures were made including installing hay bales along the former dock area and a rip rap drainage swale outfall. In addition, based on direction Irom the WE)NR, equipment stored within the rip rap drainage swale at the south end of the site was ri;:nio\id to allow for free drainage of water within the swale.

.2 3 ,\sphalt Removal/Recycling

Thv. dewatering and processing area consisted of approximately 1.5 acres of 2 to 4-inches of asphalt overl)ing approximately 8-inches of gravel and a system of geosynthetic liners consisting of a -tO Tiillimeler (mil) high density polyethylene (HDPE) flexible liner between two layers of 10-oz. non-woven geotextile. On July 28 and 29, 2008, an estimated 1,600 tons of asphalt was removed and transported offsite for recycling.

Prior tci removal, the asphalt pad was decontaminated using methods including hand-sweeping'scraping, sweeping with a rotary broom, hosing with water and pressure washing using rneierei] launicipal water. Areas where the asphalt pad had been penetrated, including sump locations, were exca\a:ed to depths of 6-inches into the underlying gravel. The excavated material was placed into roll-off dumpsters and delivered to the Veolia Landfill.

During demobilization and decontamination activities on July 17, 2008, four composite samples of the asphalt pad were collected by SES at locations shown on Figure 2-1. The following sampling procedure was used by SES's personnel:

1. 2 3. 4. 5.

Cut 12-inch X 12-inch square in asphalt. Chipped top and side of asphalt square (composite). Placed asphalt chips in 16 oz. glass sample jars. Presiiure-washed sampling equipment using city water prior to collecting next sample. Replaced asphalt piece back into hole cut at each location.

Tiie samples were analyzed for PCBs. The results are included in Table 2-3 below. Based on these results, the asphalt pad was approved for recycling by the WDNR.

Table 2-3. Asphalt Pad Sample Results

Sample ID

SPl-A

SP2-A

SP3-A

SP4-A

PCB Result (ppm)

<0.394

<0.376

<0.485

<0.481

Prepared by: TMKl Checked by: WRV

>/lclCeefn' was sub-contracted by SES to perform the asphalt removal and transportation. On July 28, 2008. using a tracked backhoe, McKeefry began removing asphalt at the south end of the dewatering pad. Asphalt was progressively removed from the pad from south to north and then removed from the casi and \y'est perimeter roads. Pieces of asphalt missed by the backlioe were pushed to the north t jwards the backhoe and stockpiled using a bulldozer. Asphalt removal was completed at the bottom

Sunrnarv fepcrt :C07-200« l.ikvcr Fc\ River - Phase I Remedial Actioti

January 12,2009


of the ramp of the access road on July 29, 2008. The asphalt was placed into dump trucks and transported to the Northeast Asphalt's Green Bay plant (11475 .A.tkins Drive) for recycling (incorporation into their asphalt mix). The asphalt on the ramp down to the site was later removed by Hydroseed of Wisconsin (Hydroseed), on September 15, 2008 and transported to the Northeast Asphalt's Green Bay plant for recycling.

2.2.4 Gravel (Crushed Stone) Removal

As described above, the dewatering and processing area consisted of approximately 1.5 acres of 2 to 4-inches of asphalt overlying approximately 8-inches of gravel and a system of geosynthetic liners consisting of a 40 mil HDPF, flexible liner between two layers of 10-oz. non-woven geotextile. The majority of an estimated 2,150 tons of gravel was transported off-site for beneficial re-use from July 30, 2008 through August 6, 2008.

During demobilization and decontamination activities on July 17, 2008, four grab samples of the gravel underlying the asphah pad were collected by SES at locations shown on Figure 2-1. The following sampling procedure was used by SES's personnel:

1. Cut 12-inch x 12-inch square in asphalt and collected asphalt sample, as described in Section 2.2.3 above.

2. Using a stainless steel spoon, sampled gravel under asphalt to a depth of approximately 6-8-inches.

3. Placed gravel sample (grab) in 16 oz. glass sample jars. 4. Spoon was pressure washed using city water prior to collecting next sample. 5. Replaced asphalt piece back into hole cut at each location.

The samples were analyzed for PCBs. The results are included in Table 2-4 below. Based on these results, the gravel was approved for recycling.

Table 2-4. Gravel Pad Samplis Results

Sample ED

SPl

SP2

SP3

SP4

PCB Result (ppm)

<0.446

<0.434

<0.432

<0.478


McKeefry was sub-contracted to perform the gravel removal and transportation. On July 30, 2008, using a backhoe equipped with a smooth-edge bucket, McKeefry began removing gravel at the south end of the dewatering pad, carefully scraping the gravel off the system of synthetic liners below. Gravel was progressively removed from the pad from south to north (ending at the north end of the former location of SES's trailers). The gravel was placed into dump trucks and transported to one of two locations: Veolia Landfill, if a significant amount of liner materials was incorporated in the gravel or the gravel contained known contamination; or Shell Property. Green Bay, Wisconsin (for beneficial reuse on Lower Fox River Phase 2 dredging project land-based facilities), if the gravel was free of any liner or known contamination. Gravel removal up to the asphalt ramp was completed on August 6, 2008. On September 15, 2008. the remainder of the gravel under the asphalt ramp was graded into the berm at the north end of the project site.

Summary Report 2007-2008 Lower Fox River — Phase 1 Remedial Actii

January 12,2009

Section 2 Remedial Action 200!i

]i should be noted that during refueling procedures by McKeefry (on July 29, 2008), a small area of jKavel was containinated by diesel fuel spillage (approximately 1.5 cy). The contaminated gravel was ri:;moved (approximately one backhoe bucket-load) and placed in a dump truck for disposal in the 'v'eolia Landfill. During the excavation of the stone fill material to adequately remediate the impacted stone. ap]Dro!iimately 5 additional yards of stone material was excavated and loaded into a dump truck for dis])o,>al in the Veolia Landfill.

?. 2.5 Synthetic Liner Removal

As desrribed above, the processing and staging area consisted of approximately 1.5 acres of 2 to 4 inches of asphalt overlying approximately 8-inches of gravel and a system of geosynthetic liners (•(insisting ol'a 40 mil HDPE flexible liner between two layers of 10-oz. non-woven geotextile. The location of the liner is shown in Figure 2-2. The system of liners was removed during the removal of tl iC gravel beginning on July 30, 2008 and completed on August 6, 2008.

In gen£;ral, fiDllowing the gravel removal, SES used a backhoe to remove the liner materials and place If em into M:Keefry dump trucks for disposal at the Veolia Landfill. Care was taken not to disturb the J tone f II material below the liner. Following the removal of the liner on the dewatering pad, the liner ir a;erials in the anchor trench were removed by SES, and the perimeter berm/roadway was re-graded to a stable slop;.

SuTinarv kep(.rt2C07-2llOS 21 January 12,2009 Ll wcr Fcj; Ri\er - Phase 1 Remedial Action

Section 3 Site Restoration

3 SITE RESTORATION

In general, site restoration activities involved restoring all disturbed areas to their original condition, which included clearing and grubbing, re-grading, topsoiling. seeding, and wetland development.

3.1 Stone Fill Characterization

As part of the site restoration plan. SES proposed to re-grade and reuse the stone fill placed across the site upon the natural sub-grade and below the dewatering pad synthetic liner during site preparation activities. In order to evaluate potential PCB and/or polynuclear aromatic hydrocarbons (PAH) impacts due to remediation activities which occurred on the site during 2007 and 2008, Foth personnel collected samples at pre-determined locations based upon the operations conducted on the asphalt pad (e.g. near pad /liner sumps).

Nineteen stone fill material samples were collected by Foth personnel, on August 1, 2008, from within the footprint of the foiTner asphalt containment pad, around the access drives, around the former fuel storage area, and from the former lay-down area on the south side of the site. The samples were collected at the stone fill material interface with the synthetic liner to a depth of approximately 6-inches. Samples were analyzed for PCB (8082) and PAH (8270C SIM). Samples from two of the 19 sample locations near the former fliel storage area (SF-18 and SF-19) were also tested for volatile organic compounds (VOCs).

The sample locations are identified on Figure 3-1. The sample locations were staked using survey grade global positioning system (GPS) for mapping and future reference.

The samples were collected by digging with a stainless steel spoon to a depth of up to 6-inches below the exposed surface. The collected material was placed into a stainless steel bowl and homogenized before filling appropriate sized laboratory-supplied containers:. The collected samples were placed in a cooler with ice for submittal to Pace. For quality control and assurance, one duplicate sample was collected per 10 samples analyzed.

Analytical results of the stone fill sampling are included in Table 2, of Appendix A.

Based on the analytical results of the stone fill samples, locations were selected for removal and landfill disposal of some of the stone fill. Table 3-1 summarizes the excavated locations and extents:

Table 3-1. Stone Fill Sample Locations

Sample Location

SF-2

SF-6*

SF-9*

SF-I2

SF-I7*

SF-18 & 19*

D^criptlon of Excavation

10' x 10' area centered on the sample location, -4-12" deep

10' X 10' area centered on the sample location, -4-6" deep

10" x 10' area centered on the sample location, -4-6" deep

8'

15

15'

wide N-S centered on the sample location by 25' long E-W, -4-6" deep

wide E-W centered on the sample location by 79' long N-S, -4-6" deep

wide N-S centered on the sample locations by 25' long E-W, ~4-6" deep

*Ultimately excavated to subgrade. Prepared by: TMKl Checked by: WRV

Summary Report 2007-2008 22 January 12,2009 Lower Fox River— Phase 1 Remedial Action


The cxcavatijd material was placed into a dump truck and transported to the Veolia Landfill for dsposal.

Following the excavafions on August 8 and 11, 2008, Foth personnel re-sampled at the seven sample Icications listed above. The same procedures as discussed above for the previous sampling event were followed; hcwever, the samples were analyzed for PCBs only. During re-sampling of SF-6, natural It laterial was encountered approximately 2-inches below the excavated grade. Therefore, remaining .'tone fill uilhin the excavation at sampling location SF-6 was removed to natural grade and disposed of, and the re-sampled material was not analyzed. The resuhs for the re-sampled locations are included in "able .1, of Appendix A. Based on the PCB results from the re-sampling event, the stone encountered at the bottom of excavafion at SF-2 was found to be below detection for PCBs. The other 1( cations were found to contain trace levels of PCBs (less than 0.5 ppm except for SF-17-RS at ] 6.2 ppm).

Farther excavating and re-sampling was completed on August 15, 2008 for the remaining areas. The areas desi;ribed above for SF-9, SF-17, SF-18, and SF-19 were excavated to natural grade. Another 4 to 6-inches of stone fill was excavated from the area described above for SF-12, and re-sampling was fierfonned for PCB analysis. The result for the re-sampled SF-12 location was found to be below the detection limit for PCBs and is included in Table 2, of Appendix A. The results of the fill sampling i rid testing indicate that PCB-impacted stone fill material beneath the lining system was efficiently excavated and landfilled.

Tie subgradi; below the stone fill was subsequently sampled and tested as described in Section 3.5.

:-2 Clearing and Grubbing

(bearing and grubbing was performed by SES in designated areas along the west slope of the site in which stone fill (relocated from the flood plain) and 30-ft wide sections of geotextile were placed to enhance erosion control. These areas are shown in Figure 3-2.

Prior to c earing and grubbing, Foth personnel surveyed and staked the comers of the areas. SES removed :he majority of the vegetative cover and, using a small bulldozer, smoothed out areas in which the geotextil; would be placed. Areas on either side of the geotextile where stone ifill was placed were also ckarjd of smaller and mid-sized standing and larger fallen vegetation. Per the request of the Owner's l^epresentative for U.S. Mills, larger standing trees were left in place to provide visual screening for the mill.

'f he removed vegetative cover was placed into McKeefry dump trucks and hauled off-site to the McKeefpj' yard.

3.3 Re-Grading

The floodplain elevation in the area of Phase 1 is +585 NGVD as depicted on Figure 3-2. During the i litial site preparation activities in 2006-2007, approximately 9,300 (cubic yards) cy of stone fill were placed on the site to allow construction of a liner/base course/asphalt dewatering pad as shown on r ig are 3-.5. The isopach contours on Figure 3-3 depict the approximate thickness of stone fill placement. As previously described, the liner/base course/asphalt pad materials were removed and appropriately recycled and/or disposed of

Sjinnary f cport 2007-2OOS 23 January 12. 2009 L, .verFo. River - Pha. -e 1 Remedial Action


It should also be noted that three temporary groundwater monitoring wells located in the east perimeter road were properly abandoned on August 6, 2008.

Between August 11, 2008 and August 27, 2008, SES removed approximately 9,300 cy of stone fill material and re-graded the underlying area located within the 100 year flood plain elevation of the Fox River in order to re-establish prc-project grades. A tracked backhoe, bulldozer and front-end loader were utilized to excavate, relocate, place and grade the stone 1111 along the west slope of the site in designated areas to provide slope stabilization and erosion control as shown in Figure 3-2. The stone fill was excavated from the flood plain and stockpiled using the backhoe, leaving residual stone material on the native soil over the majority of the site. A front-end loader transported the stockpiled stone fill to the required fill areas, while a bulldozer was utilized to grade the stone fill to the required grades. The designate fill areas were graded to an approximate 3:1 slope; the toe to an approximate 10% slope. The re-graded design allows for sheet flow of surface water to occur across the site, which is expected to bring the site to the same general flow patterns that existed prior to the project.

After excavation to the 585 ft elevation was complete, using a bulldozer and backhoe, SES removed the residual stone material in order to expose the pre-existing native soil. The native soil (in areas not receiving topsoil) was then disced in preparation to receiv'e the selected seed mix.

Because the site restoration plan required the addition of stone material along the west slope of the site, the existing city of De Pere sanitary manholes (see Figure 3-2) located on-site were raised to accommodate the proposed elevations. The city of De Pere contracted with De Groot Construction (De Groot) to perform the work. On August 18, 2008, De Groot raised three sanitary manholes on the site by adding concrete risers to the existing manholes. On August 28, 2008, De Groot returned to the site to raise the manhole towards the south end of the site, near the 10-inch diameter roof drain/condensate pipe in the west slope, another 4-feet to the planned elevation.

On September 3, 2008, McKeefry began re-grading the stockpiled sand, located on the south end of the site, moving it to the west and south outside of the floodplain as shown in Figure 3-2. On September 4, 2008, an approximate 3-ft berm was placed around the toe of the sand stockpile (east and north sides) using some of the excavated stone fill to contain potential sand erosion during rain events (see Figure 3-2). On September 5. 2008, the sand stockpile was re-graded after the previous evening's rain event had caused sand to wash out along the north slope. In addition, the stone fill at the top of the stockpile was re-graded to direct water from the U.S. Mills parking lot towards the stone fill and geotextile-lined slope to the north rather than down the sand stockpile.

On September 10, 2008, the site restoration subcontractor, Hvdroseed, mobilized to the site. From September 10, 2008 through 25, 2008, Hydroseed completed the following activities associated with site restoration: necessary placement and re-grading of stone fill on slopes; residual stone removal within the flood plain; completion of the wetland berm construction; rip rap dam construction northwest of the constructed wetland; removal of the stone fill and grading of the underlying material on the access ramp; re-grading the fonner perimeter roadway and leveling excess stone fill around the silt fence. Final re-grading of the sand stockpile to enhance slope stability was completed on September 20, 2008, by Hydroseed.

3.4 Re-Grading Documentation

During re-grading activities by SES and subsequent subcontractors, Foth survey persormel performed a series of surveys and grade reviews. Table 3-2 summarizes the surveys/reviews performed:

Summary Report 2007-2008 24 January 12.2009 Lower Fox River — Phase 1 Remedial Aclniii


Table 3-2. Survey Schedule

Date

August 11,2008

August 15. 2008 August 18, 2008 August 20, 2008 August 25, 2008

August 26, 2008 (noon)

August 27, 2008 September 4, 2008

September 11, 2008 September 19.2008 September 24, 2008 September 25, 2008

October 3, 2008

Survey Event

Staked comers of designated fill areas along the west slope and 585' flood plain elevation Staked break lines on west slope Staked toe of west slope and re-staked 585' flood plain elevation Re-staked break point locations and elevations for fill areas Re-staked break point locations in fill areas #1 & #3 (topographic survey). Staked comers of wetland Topographic survey of most of the site (Review of site grades requested by SES, on August 25, 2008, p.m.) Re-staked 585' flood plain elevation at the south end of the site Re-staked 585' flood plain elevafion around the sand stockpile and took as-built shots of the wetland berm Topographic survey of the site Final re-staking of pre-project 585' flood plain elevation Verify wetland berm elevation (east and south berms) Verified wetland berm elevation (north berm) As-built site topography


Subgrade Characterization

Ir order \D evaluate potential PCB and/or PAH impacts to the preconstmction subgrade due to remediation activities during 2007 and 2008, Foth persormel collected samples of the subgrade material irom witliin the footprint of the former asphalt containment pad. Seventeen sub-grade samples were collected by Foth personnel on August 28, 2008 in the same general locations and depths and in the s;i.me matuier as the September 7, 2006 pre-construction soil sampling event by Shaw. Shaw originally sampled ,9 locations; however, two of the locations (18.1 and 19.2) were covered with approximately :-feet of ;itone fill and could not be re-sampled or legitimately relocated.

7lie sample locations are shown on Figure 3-4. The sample locations were staked using survey grade ( J P S for rnapiping and fliture reference.

Ilie samples were collected by digging with a stainless steel spoon to a depth of up to 6-inches from the exposed surface. Each sample was placed into the appropriate sized laboratory-supplied container, which was then placed in a cooler with ice for submittal to Pace. The samples were submitted for analysis of PCB (8082) and PAH (8270C SIM) compounds. For quality control and assurance, one duplicate sample was collected per 10 samples analyzed. Analytical results and methods for the subgrade characterization sampling are included in Table 2, of Appendix A. A comparison table of the pite-construction and post constmction sample results is found in Table 3, of Appendix A.

It may be concluded with a high level of statistical certainty from an analysis of the total PCB results, the mcim 2008 concentration did not significantly increase from site activities. In essence, the tme (unknown) mean of the 2008 total PCB results is not significantly greater than the tme (unknown) inean cf the 2006 total PCB results. In fact, the 2008 sample average concentration is 2,244 (xg/Kg and the 20(i6 sample average concentration is 3,011 pg/Kg. The data is presented in the Table 4, of /\ppeniii>. A

Siiminaiy Report 2007-2008 1 (iwcr 1 (K Rjver - Phase 1 Remedial Action

25 January 12.2009


A Statistical paired t-lest of the hypothesis HQ: P2008*^^M2006 ^ - ^a- 1^2008-^^2006 indicated that

we could not reject HQ in fax or of H^ with 95% confidence, that is, we carmot conclude the tme mean

concentration of the 2008 data exceeds the tme mean concentration of the 2006 data. In addition, with the observed sample averages of 2,244 |ig/Kg for 2008 and 3,011 |.ig/Kg for 2006, the probability of reaching this conclusion in eiTor (Type II error) is less than 0.20. That means there is less than a 20% chance that, given this data, ihe tme mean concentration following site activities increased.

3.6 Topsoil Placement, Discing

On September 10, 2008, seeding preparation of the site began with the placement of topsoil within the newly constmcted wetland area. From September 12, 2008 through September 25, 2008, top-soil was placed on the remaining areas as identified on Figure 3-2,

Upon completion of the topsoil placement and site grading, these areas were fertilized and hydroseeded with the seed mixtures identified in the Site Restoration Plan. The wetland was seeded with the specified wetland mix. The sand stockpile was raked, fertilized, and hydroseeded with a perennial rye and oat seed mixture. The former access road area was seeded with a turf seed mix to blend into the existing turf grass on the adjacent U.S. Mills property. From September 17, 2008 through September 25, 2008, the native soil material within the flood plain was disked, raked, fertilized, and hydroseeded with the specified riparian forest mix. All Hydroseed seed mixes included a mat blend mulch along with PAM 12, a soil polymei. Topsoiling, discing, and seeding work was performed by Hydroseed.

3.7 Wetland Development

From September 3, 2008 through September 25, 2008, an approximate 0.25-acre wetland was constmcted on the site by McKeefry and Hydroseed during restoration activities to mitigate wetland impacts from site remediation activities. Portions of the wetland are located within the floodplain, as shown on Figure 3-2. McKeefry began the constmction of the berm surrounding the wetland area (approximately 1-1.5 ft high), on September 3, 2008, using excavated stone fill.

On September 4, 2008, two loads of rip rap were tmcked in by McKeefry for placement along the west side of the wefland for construction of the energy dissipater and to the south of the wetland for constmction of the rip rap drainage channel as shown in Figure 3-5. The rip rap and underlying 10-oz. geotextile were placed on September 5, 2008. The energy dissipater was constmcted approximately 30 ft long by 10 ft wide by 6-inches thick. The rip rap drainage channel was constmcted from the south berm of the wetland and tied into the existing drainage swale outfall.

On September 4 and 5, 2008. McKeefry extended the existing 10-inch roof/condensate drain from the outfall in the west slope (near the south end of the site) to the rip rap energy dissipater located just west of the wetland, as shown in Figure 3-5. The pipe was then backfilled with stone fill material. The storm drain routes water from the roof of the U.S. Mills plant to the wetland through the energy dissipater for use as a source of water for the wetland. In addition to the rainfall related flow from the roof of the plant, condensate from air conditioners located on the plant roof will provide a trickling of water throughout the year to the wetland.

On September 10 and 11, 2008, Hydroseed placed approximately 4-inches of topsoil on the wetland berm, inner berm included. Following the placement of topsoil, the wetland was seeded with the seed mix specified in the Site Restoration Plan. Hydroseed also completed the necessary grading of the

Summary Report 2007-2008 26 January 12,2009 Lower Fox River — Phase 1 Remedial Aetitin

Section 3 Site Restoratio:ii

v/etland area including final wetland berm constmction and rip rap check dam constmction north of the -ondenst.te jjipe outfall. Wetland constmction activities were completed on September 25, 2008.

?.8 Post Constmction Monitoring

During the demobilization and restoration activities on-site, per the recommendation of the WDNR, iivasive species, including purple loosestrife and phragmites, were managed by SES and the Resident Engineer. These invasive species were removed/sprayed for eradification along the west slope near the :iiDuthwest comer of the former observation deck and along the shoreline of the site. Further monitoring md management of invasive species will be performed under the Post Constmction Stormwater DperaiioT and Maintenance Plan included in Appendix B.

Si miliar) Report 2(07-2008 27 January 12, 2009 Lktwtr Ft'.t Ri\er - Phase 1 Remedial Action

Section 4 References

4. REFERENCES

Shaw and Anchor, 2004. Lower Fox River Operable Units 2 - 5 Pre-Design Sampling Plan. Prepared for Fort James Operating Company, Inc. and NCR Corporation by Shaw Environmental and Infrastmcture. Inc. and Anchor Environmental, LLC. June 7, 2004.

USEPA and WDNR, 2007. Record of Decision Amendment: Operable Unit 2 (Deposit DD), Operable Unit 3, Operable Unit 4. and Operable Unit 5 (River Mouth). Lower Fox River and Green Bay Superflind Site. June 2007.

USEPA 2006. Consent Decree for Performance of Phase I of the Remedial Action in Operable Units 2 - 5 of the Lower Fox River and Green Bay Site. March 2006.

Shaw and Anchor, 2006. Phase I Construction Quality' Assurance Project Plan. Prepared for NCR Corporation and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, and Foth Infrastmcture and Envirormient, LLC. July 24, 2006.

Shaw and Anchor, 2007. Lower Fox River Phase 1 Remedial Action - Remedial Action Plan. Prepared for NCR Corporation and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc.. -'\nchor Environmental, LLC. and Foth Infrastmcture and Environment, LLC. April 2007.

Shaw et al., 2007a. Optional SAP Addendum for Pha.se 1 Verifcation of Project Completion. Prepared for NCR Corporation and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture. Inc.. .A.nchor Envirormiental, LLC, and Foth Infrastmcture and Environment, LLC. July 16,2007.

Shaw et al., 2007b. Lower Fox River Operable Units 2 to 5; Remedial Design Sampling Plan Addendum for Phase 1 Remedial Action (Final). Prepared for NCR Corporation and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, Foth Infrastmcture and Environment, LLC, and Sevenson Environmental Services, Inc. October 1,2007.

Shaw et al., 2008. Lower Fox River Phase 1 2007 Remedial Action Draft Summaiy Report. Prepared for NCR Corporation and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture. Inc., .Anchor Environmental, LLC, and Foth Infrastmcture and Environment, LLC. Febmary 2008.

Summary Report 2007-2008 28 January 12,2009 Lower Fox River — Phase 1 Remedial ACIKIII

http://Pha.se

FIGURES

Summary Report 2i)07-2008 January 12, 2009 l.iiw;r Fo> River - Phase 1 Remedial Action

M M>enOOInnM«'hiw1_20Oe«B(i»l.l 1 «> 71

^

Thistt^wmg IS neither a tegatiy recorded rnsp nor a suni«y and is no) htemled to be used as one Ttiis drawing is a compilation ol

i, intonmation arid data used for reference purposes only.

#Foth M <WBnCat1iiW)Wii« I _C»ml , 11Kt7 R M

NCR/US PAPER MILLS INC

FIGURE 1-2

PHASE 1 - ORGANIZATIONAL CHART

Scale: NOT TO SCALE

Drawn By: DAT

Date: JANUARYS. 2009

Checked By MRO Scope: 08NC09

232,S00 N

LEGEND

A S P J SP2 » GRAVEL SAIilPLE ^ S P 2 - " SP2-A = ASPHALT SAMPLE

SITE LIMITS

NOTE:

1. SAMPLES COLLECTED AND LOCATIONS PROVIDED BY SES.

0 AOr to-

•Foth NCR/US PAPER MILLS INC.

FIGURE 2-1 PHASE 1 - SITE DECONSTRUCTION

ASPHALT & GRAVEL SAMPLE LOCATIONS

Dates NOVEMBER, 2008 Revision Dote:

Prepared By: JOW ChecKsd Byi JSHI 08N009 Xt\C(IM\2<IOB\QIN009\cad\flgurM\Bn01.otX]*al.Mnoi».iecatlo#ii.f3.<fgn

232,500 N 232,750 N

4 - 2,470,500 E

+ 2,470,750 E

- | 2,471,000 E

APPROXIMATE LIMITS OF GEOMEMBRANE LINER

1. APPROXIMATE LIMITS OF GEOMEMBRANE LINER PROVIDED BY SES. V-'

0 SO' 100'

4Foth Pom lirfwaWwchw^ & bHfJnMMnnd, LLC

NCR/us PAPER MILLS INC.

FIGURE 2 - 2 PHASE I - SITE DECONSTRUCTION

APPROXIMATE LINER LOCATION

Date: NOVEMBER, 2008 Revision Dote:

Prepared By: JOW Checked By: JBHI

SAMPLE NUMBER

SF-1 SF-2 . SF-3 SF-4 SF-5 SF-6 SF-7 SF-8 SF-9 SF-10 SF-11 SF-12 SF-13 SF-1 4 SF-15 SF-16 SF-17 SF-18 SF-19

EASTING

232188 232230 232282 232222 232359 232346 232441 232445 232435 232523 232539 232480 232634 232683 232669 232636 231866 232061 232062

NORTHING

2471001 2470971 2471029 24 71060 2471042 2471139 2471055 24T1100 2471184 2471076 2471098 2471216 2470998 2471050 2471076 2471094 2470992 2470960 2470973

- | - 2,471,250 E

LEGEND

<3r_1 A STONE nLL SAMPLE ^ ' Mk UUMBER AND LOCATION

S F - 1 4 * SAMPLE COLLECTED AT FORMER SUMP LOCATION

-". I - AOOEO PARAMETER

NOTES:

SAMPLES OBTAINED BY FOTH AT ALL LOCATIONS ON 8 /1 /08 . SELECT SAMPLES RE-SAMPLED ON B/B, 8/11 It 8 /15 /08

HORIZONTAL DATUM USED FOR SURVEY: NAOBJ WISCONSIN STATE PLANE CENTRAL (SPC), HORIZONTAL DATUM USED FOR REFERENCE: NADe3/97 WISCONSIN TRANSVERSE MERCATOR (WTM). CONVERTED TO U.S. SURVEY FEET.

VERTICAL DATUM NAVOSB AND CONVERTED TO IGLDB5, U.S. SURVEY FEET.

X:VCBME\»M\Mttt09\c<K:\ftgi>-oa\Bnn.DNlS9l.BaiioiB.locatKins.ri.i:gn

#Foth Path tnfrastnicture ft Cnviramnmt, IXJC


FIGURE 3-1 PHASE I - SITE DECONSTRUCTION STONE FILL SAMPLE LOCATIOJS

Dote: NOVEMBER. 2008 Revision Date:

Prepored By: JOW Checked By: JBHI

232,250 N

SAND STOCKPILE

STONE BERM

2.470,750 E

2,471,000 E

FORMER ACCESS RAMP

2.471,250 E

LEGEND

— » — EXISTING GRADE

i _ D EXISTING BUILDING

@ EXISTING SANITARY MANHOLE

- 5 9 0 - POST CLOSURE CONTOUR

FLOODPLAIN ELEVATION 585

» FENCE

TOP OF SLOPE

TOP OF WETLAND BERM

APPROXIMATE LIMITS OF SAND FILL AND SAND SEED MIX

>«« APPROXIMATE LIMITS OF • ^ RIPARIAN FOREST SEED MIX

• • 1 APPROXIMATE LIMITS ^ ^ OF WETLAND SEED MIX

APPROXIMATE LIMITS OF TURF SEED MIX

!i2S5 «

APPROXIMATE LIMITS OF STONE PUCEMENT

APPROXIMATE LIMITS OF EROSION MAT

APPROXIMATE LIMffS OF STONE BERM

NOTES: FIEIO roPO SURVEY PtRFORMED a t FOTH INFRASTRUCTURE ic ENVIRONMFNT, LLC.. ON JULY 10 ft 15 ANO OCTOBER 2 * 15. ?008.

HORI^ONIAL DATUM USED FOR SURVEY. HA0a3 WISCONSIN STATE PLANE CENTRAL (SPC), HORIZONTAL DATUl,! USED FOR REFERENCE; NADflVST WISCONSIN TRANSVERSE MERCATOR (WIM). CONVERTEO TO U.S. SURVEY FEET.

APPROXIMATE LIMITS OF GEOTEXTILE PLACEMENT

XXXXX SILT FENCE

1 ^ ^ AREA TOP-SOILED

#Foth Fotti InfraifntGtitff i A SniriroiHneftti LLC


FIGURE 3-2

PHASE 1 - POST-CLOSURE SITE LAYOUT

D a t e : NOVEMBER. 2008 Revis ion D o t e :

P r e p o r e d By: JO* Checked By: JBHI

3.471,250 E

LEGEND

— » — EXISTING GRADE

I I EXISTING BUILDING

APPROXIMATE LIMITS OF FOTH GRAVEL SURVEY

— 2 ISOPACH CONTOUR

ORDINARY HIGH VKATER MARK

NOTES:

1. ISOPACH CONTOURS REPRESENT THE THICKNESS OF THE STONE FILL MATERIAL PLACED BENEATH THE PAD UNER.

2 . FIELD TOPO SURVEY PERFORMED BY FOTH INFRASTRUCTURE » ENVIRONMENT, L L C . ON JULY 10 * 15 AND OCTOBER 3 * 15 . 2 0 0 8 .

3 HORIZONTAL DATUM USED FOR SURVEY: NADB3 WISCONSIN STATE PLANE CENTRAL (SPC). HORIZONTAL DATUM USED FOR REFERENCE: N A D 8 3 / 9 7 WISCONSIN TRANSVERSE MERCATOR (WTM), CONVERTED TO U.S. SURVEY FEET

4 . VERTICAL DATUM NAVD88 AND CONVERTED TO IGLDB5. U S . SURVEY F E H .

4V BO-

•Foth NCR/us PAPER MILLS INC.

FIGURE 3-3

PHASE 1 - STONE FILL MATERIAL THICKNESS

Date: NOVEMBER. 200B Revision Dote:

Prepared By; JO* Checked By: JBHI 0BN009

DITCH BERM

LEGEND

- 5 9 0 — EXISTING CONTOUR

- 5 9 0 — PROPOSED CONTOUR

1.1 • SUBGRADE SAMPLE LOCATIONS

2.471.250 E

AREA WITHOUT ROAD 64 ,806 SO. FT. 1.49 ACRES

NOTES:

1. PRE-CONSTRUCTION SUBGRADE SAMPLES OBTAINED BY SHAW ENVIRONMENTAL ON SEPTEMBER 7, 2006

2. SAMPLE LOCATIONS SURVEYED BY FOTH & VAN DYKE ON SEPTEMBER 7, 2 0 0 6

3. SUBGRADE POST RA SAMPLES COLLECTED BY FOTH ON AUGUST 28 , 2008 AT SAME LOCATIONS AS SHAW SEPT. 7, 2 0 0 6 SAMPLING

<0' BO'

#Foth Fo lh ln l rM ime tu fe A gwvlfOiiMMii, L

N C R / U S PAPER MILLS INC.

FIGURE 3 - ^ PHASE 1 - PROCESS FACILITY

SUBGRADE SAMPLE LOCATIONS

D o t e ; NOVEMBER. 2008 Revis ion D a t e :

P r e p a r e d By: JOW Checked By: JBHI 08N009

LEGEND

— " > — EXISTING GRADE

C T l EXISTING BUILDING

® CLEANOUT

- 5 9 0 - POST CLOSURE CONTOUR

TOP OF WETLAND 8ERM

XXXXX SILT FENCE

APPROXIMATE LIMITS OF UPLAND SEED MIX

APPROXIMATE LIMITS OF WETLAND MIX

i M

[ ^ 3

APPROXIMATE LIMITS OF STONE PLACEMENT

APPROXIMATE LIMITS OF RIPRAP PLACEMENT

DRAINAGE DITCH

AREA TOP-SOILED

XISTING 10" DIA ROOF DRAIN/: CONDENSATE PIPE

0 DIA PVC KOOf DRAII-I OiSCHARCE PIPE EXTENSION NSTALLED SEPT 5, 2008

NOTE:

1. FIELD TOPO SURVEY PERFORMED BY FOTH INFRASTRUCTURE & ENVIRONMENT, LLC. ON JULY 10 & 15. OCTOBER 3 4 15, 2008.

EXISTING RIPRAP CHANNEL

f raatraolDK ft envf t« i in i« i : , I

NCR/US PAPER MILLS INC.

FIGURE 3-5

PHASE 1 - POST-CLOSURE CHANNEL AREA

Dote: NOVEMBER. 2008 Revision Ootoi

Prepared By: JOW Checked By: JBHI

APPENDIX A-Tables

Table 1 2007-2008 Demobilization Activities and Occurances Table 2 Aggregate Fill Sample Results - August 2008 Table 3 Shaw September 2006 Preconstmction Subgrade Results & Foth August 2008

Subgrade Re-Sampling Results Table 4 Pre vs. Post Native Subgrade PCB Concentrations

Summaiy Report 2007-2008 j ^ 200g Lower Fox River — Phase 1 Retneilial Action

Table 1 2007 - 2008 Demobi l izat ion Ac t i v i t i es and Occur rences

Date Activity Contractor

Fall 2007 Deconstniction of temporary dock Removal of marine equipment from project area. Decontamination of marine equipment Removal of sheet piling and silt curtain containment system Removal of dredge pipe

SES

January 7, 2008 June 9, 2008

June 10, 2008 - August 1, 2008 June 11,2008

June 13-23,2008 June 19,2008 June 23, 2008

June 24 - 26, 2008 June 25 - July 23, 2008

July 17,2008 July 28 - 29, 2008

July 30 - August 6, 2008 August 1-15, 2008 August 11 - 27, 2008

August 11 - October 3, 2008 August 18 & 28, 2008

August 28. 2008 September 3, 2008

September 3 - 4, 2008 September 4 -5,2008

Overflow of site surface water to river from snow melting and precipitation event Upland deconstniction and demobilization activities began Dismantling of water treatment piping and removing of tent structures over filter presses Water treatment, dewatering and sand placement was dismantled, decontaminated, and loaded out Effluent pipe removal, decontamination, and load out Remaining turbidity curtain brought to shore for removal Hand held turbidity readings Removal of sheet piles from shoreline Anchor weights removed from effluent discharge pipe Poling survey and hydrographic survey of dredge area Treated water effluent sampling Asphalt and gravel sampling Asphalt excavating and removal Synthetic liner and gravel (crushed stone ) removal Stone fill sample collection and re-sampling Removed and re-graded stone within floodplain area Site survey and construction staking City of De Pere sanitary manholes raised (by others) Pad area subgrade soil samples collected Wetland berm construction Re-grading sand stock pile Extend roof/condensate drain

-SES

SES SES Foth SES SES

Prosource Foth SES

McKeefry McKeefry

Foth SES Foth

De Groot Foth

McKeefry McKeefry McKeefry

September 10-25,2008 Re-grading of stone fill on slopes Top soil placement on selected slope areas Residual stone removal within flood plain Completion of wetland bemi construction Rip rap check dam construction Removal of asphalt access ramp and crashed stone graded to slope Sand stockpile re-grading Fertilizing, seeding and mulching of wetland, sand stockpile, floodplain area and access road area

Hydroseed

September 19,2008 Water line connection to city water main disconnected Competitive Water and Sewer

Prepared by: WRV Checked by: JBHI

J:\sc()pes\06''"^')l\Resident Engineer\2008 communlcation\Phase I 2007-2008 Summary Report\T-Table 1, Der ' -lization Activities and Occurrences.doc

Table 2 Aggregate Fill Sample Results • August 2008

A»ffrt t. WW • n i ^ h n t u w l

m n j IJI13

l - lBB (UJ -<<H iy™iy i ^ , l

I p - ^ ' - ' B r p ™ " •» *« '

' p - * * " * " * — w ^

Hcf ty lmc lT i l i i nk ln tm

tlllplllMe lUlf i lc (al Sr-11 ' " :Oi*)yiic*l ruulr l l i u ° ^ * ^ l > " ' " ' " DupiEiK ani i lE for SF-IR-RS ' " Snp ie ST-t-KS WH c<dleci«l. h

A a m . PAH • EPA «2Tfl by SIM. VI

! I 2Ml-2<!m S u a n v y RqurrT-Ti e 2. \ $ f n p f r Fill S H ^ W RauJli i

TmbleS

ShMw September 2006 Preconstmction Subgrade Sample Results vs Foth August 2008 Subgrade Re-sampling Results

Sample ID .Sample Year

NoHhing

PCB*

P ( • B - 1 0 l h ( A r o l l . . ^ l H 1 f i ) ( ^ ^ l ^ S i

l > C R - n : i ( A r . N . l i ) r 122l) fMg. lLg)

P ( 'B -12 . * : ( A m t l i i r 1232) ( f j s ' l i s )

PCB- I2d2 (Ann- ln r I 2 4 2 | ( | i& l tg )

PCB- I2JK (A roc lo r 124f() ( f i g i g )

PCB-1254 ( A w l o r 1254) ( j i g i g l

P C B - l 2 W I ( A n K l . i r n f t O H t i p . i ) ; )

T . i i a l P C m M l i l ' g l

T o l . , I P l - H ( p | . m |

FRSO-Ofll 2006

2321R7

2471001

PS-l. l 20(1N

2.121R7

2471001

• ; U l^tp

• H i h d

< l i - - I h l l

<. l . ! If. (I

460 ^h2

ISO ' I f i O

52 M h

700 f i l '

0 7 0 1,12

F R S O - M l P S - I . I

200h 2tK)8

Z m m 2.1211M

2471029 2471029

- 4 7 0 • : |4V

• 4 7 0 ' : |4 .4

<47l)

<470

< l 4 y

< f 4 9

120(H) 413

-.470 •=14 .»

• '470 l i t .

12000 4 1 ^

12 114^ '

FR.SO-00.3 PS-.3.I

2006 200K

2322S2 2122K2

2471029 2471029

FRSO-«04

2006

2122H6

24710S2

PS-4.1

200f<

2322K6

2471082

F H S O - M S

20 (»

PS.5.1

2D0H

232327 232327

2471036 2471036

FRS(>-no6

2(MI6

232(29

2471»7fi

PS-6.1

2008

212129

2471076

FR.SO-0n7

2006

PS-7.1

2 («8

2471117 2471117

mso-ftOi 2006

212359

2471042

PS-8.1

200B

232359

2471042

• l t d • MK

• 130 - M K

- .1.10 •;15B

' 1 3 0 - ^ 1 . "

S700

2.';on 450

6460

•:|5S

2 "

1200(1 fiTlKl

12 I ' - '

• 1 6 0 I I I

•^160 111

•=:l6fl 111

• ; | 60 -111

3900 «2<*u

<160 •111

< I 6 « 111

3900 S2»n

,» .» ^ 3 0 '-14.6

•:.30 ' I4.h

820 3.12

330 141

110 415

1100 <IK

1 ( 0 5 I N

• I t ' 1 4 9

- 1 ! -14 9

• i l ^ U . l

•;11 - 1 4 9

KXX) 16 1

410 18.8

84 <149

1500 14 9

1 5 0 0149

15(1 - h ' <

150 • f . * 5

' I S O (.5.5

4100 IH.W

- I S O -65.5

510 -65 (

ISO 83 4

4t(00 191(1

J N 1 9 1

• r - - 7 !

- 17 - ^7 1

' 3 7 •-77.3

<17 -77 .1

120 2120

55 ' 7 7 . 1

' 3 7 110

ISO 2410

i n s 3 41

FRStWMW

20(16

212.362

2471084

PS-». I

2IM)X

212162

2471084

- n o 6 0 *

n o • M K

- 1 (1) .-60 5

30(MI

•^130

-ftO.S

2020

800 -.60 5

290

4 ( 0 0

641

2080

.1 1 2 08

F R S O - O i a

2006

232.165

ps-ia.i 2008

232365

^ 10 • 14 S

• 3(1 • 14 K

' .10 -;|4.B

62 48 2 1

' 3 0 ' I 4 . R 1

1.10

54

240

98,2

40

186

0 24 0 186 1

PAH* 1

I -Mc lhy lnaph lha l t n t ( j i g l t g )

A« ;n^ l . l hy l en« (Mp . ' kg )

Anihracenc ( f ig /kg)

Ben» i (a )py rc rw(pp /k ( r l

(nuysenc t l i g l i g )

r ) iberK(a ,h)«n ihr«« iK ( U R I I B )

nuonuHhen i ; i \ ig fkg)

Indeao< l,2..1-ciJ)pyreiK ( j ig /kg)

P y r e n c f t i g k g )

• t N I , -

' - .19 12 1

• : J 7 12

< i 6 1.4

<4.S '^5.8

<6.6 I I A

< 1 f t I f t f i

<-V5 2(12

<4 5 117

<3.S 15 8

<5.5 IR

^.V5 •-•;•>

<3,6 2').l

•r4..1 1 (.

< 3 ! U1

<5.n 126

<J.7 17

-^ l 1 14 1

• i r " IK

1 3 ' " 11

< 1 5 16

<3,4 1

<4 2 ft6

< h 3 17,v

S 1 ' " 32

5 1 ' " 24.9

--4 2 1. '

5 6 ' " 23..i

• i 3 <5..<

S -0 ' " 43.6

<4 0 2 !

<3.0 11 1

9 K ' " 24.,''

7 6 " 24 ••

7 4 ' " 2 S I

• ) h " ' 1 4 '

1 6 ' " 214

<3 7 5 1

< 1 6 15 7

5 5 ' " ' 4X1

2 1 ' " 51.1

33 51 1

42 56 7

2 3 ' " .10 2

2 H ' " M l

2 7 ' " 57 2

.5 9 ' " 10

34 147

< 4 1 16.2

1 4 ' " 2 ' !4

1 0 ' " l - * !

1 9 ' " 112

1 0 ' " 111'

211 ' " 4 < ;

n M l

•-3 5 14

' 3 . 4 K.I

I S " " 22 ' *

,34 4 1 2

42 67.fl

40 76.N

2 5 ' " i i ' ) Mi 61S

37 5)1 f

8 0 ' " U K

61 H4.4

A H ' " (..<

2 1 ' " 15 3

2 0 ' - ' w i

44 60

SO « i

2 1 ' " H h l

60 137

* 1 4 2 6

' 3 3 14

' 4 1 H6

<5 1 14 1

<3,3 12.6

<3 2 15.9

' 4 1 111.5

<3 5 116

' 5 0 30 2

<r12 • * '

<1 3 26.4

' 1 9 4,1

<2 9 1 3

441 95.7

< \ i 579

n ' " IKK

U 8 6 1

48 127

- 1 4 3.6

-.3 1 14

5 1 ' " ft 6

1 6 ' " 14 1

2 4 ' " 126

2 6 ' " 15.9

40 10.5

I K ' " 136

2 4 ' " 20 2

1 0 ' " • : < '

2 8 ' " 264

• 3 9 4 1

1 9 ' " 1 1

11 95 7

10 57 9

2 5 ' " IR8

121) ' " 7>9

2 1 0 ' " 125

2100 6 1

' 7 9 5 1

6000 21 1

8600 19 9

8700 M. I

9100 (4 4

3700 t l h

6600 60

S9(10 *7 9

l.iOO 14 1

2!«K)(I 108

2200 12.2

3S(M) 3(1.5

5 6 ( 1 ' " 91 <

2-3000 99

21000 8M

- 4 2 1^2

5 1 ' " 37 1

< 4 I 4 2

< 4 0 4 9

- 5 0 12.7

1 2 ' " 27.1

1 3 ' " 15.5

1 4 ' " 46 5

9 4 ' " 21

t l ' " 15.1

1 6 ' " 18

4 5 ' " ' 8.1

1 9 ' " 67.9

' 4 . 8 4.8

8 . 9 ' " 211

<5 6 17 6

n ' " 46 7

1 7 ' " (2.(1

29 9 1

41 159

15 19

1 9 " ' 1 1

97 H.5

160 30 3

220 26 7

220 13 1

81 172

190 3 *6

2(m 29 9

3K - 5 6

450 51 1

18 2 f t

91 14 1

19 14 2

340 27 *

14(1 Ih I

7 9 ' " 7 h

1 2 ' " 11.6

R O ' " 6 2

6 6 " ' ' 2 0

10 17 5

100 15 1

150 w,.- 1 110 .15.6

77 318

110 19.5

n o 4 M

11 9 4

210

8 . 9 ' "

78.0

W,8

5S

22 5

13'" 13 1 1 110.0 61 ( 1 170 0 ... 1

Sample I D

Sample Year

Nunh in i i

Fa i l i ng

FRSa«l l 2006

rs-11.1 2008

232405 212>105

2471051 2471053

F R - S O - a i l

2(XI6

112409

3471098

P S - I I . 1

2008

212409

247109S

F R S O - a t a

IWIf ,

212414

2471141

FS.13.1

200S

232414

2471147

F R S 0 ^ 1 4

2006

332441

3471055

PS-14.1

2008

232441

2471015

F R S O - f l l S

2006

232445

2471 KM!

PS-15.1

2008

212445

247 f too

F S M M I I *

2 IX»

212449

2471157

P S - t 6 . l

2008

212449

2471157

F H S 0 4 1 T

2006

232521

2471076

ps-n. i 2008

212523

2471076

F11S<>«IB<"

2006

233596

2471046

F R S 0 4 W ' "

2006

212683

:4 - '1050

ps-M-n ' " 2008

232414

2471147

p s . j i . a " •

2008

313382

3 -P I029

«.• 1 P C B - 1 0 1 6 ( A r o c l m 1 0 1 6 3 ( p g \ g |

P C - B - 1 2 2 l ( A r o c l o r ! 2 2 1 ) ( p f L l i p )

PCB- ]232 (A roc1o r 12-12) (pB.l iB)

P<"B-1242 ( A r o t l n r 1242) ( f i g ^ )

PCB-124K ( A r o t l n r 124S) ( i ig /kg)

K B - 1 2 5 4 ( A m c l i K 1254) ( f i g l i g )

P C B - l 2 W M A n > c l o [ l 2 6 0 t r i . E / l c g )

T o l a l K B ( | i g l i g l

Tula l P C B i p p m l

PAH'

Acenaph lhc-ne lMgl t i )

A««aph . ) , yk™. - (MS. ig l

A n l h r a c e n c l i i R l t n l

BennXalwi l l i ia i 'e i ie (PK / ICK I

Be«.-.(a)pyrcnc.(M«'kp)

Benar iMnunrBu lhen* (MB'kgl

Ben7u( | j .h . i lpcry lc iK ( l i f j i f ]

BenaMli l f l iMiranlhene ( M E kp)

l - h r y ^ « ( ^ g . 1 . B .

Diben/ (a ,h)an lhra iene ( t i e \ f )

Fluoranlhct ic ( J i g l i g l

F l iH i renc lpp /kp)

IndeniK 1,2.1- fd lp jTCM l^l(^'kpl

N > h i h » l « . c < , i g k g l

PhenanMiTfnc ( I I H I \ B )

Pyrene(p f r 'kg)

- 1 0 •^••• .

<10 -15 5

' 1 0 • 75 5

' 1 0 •-15,5

1100 1340

400 . 15 5

110 n t

16(81 14111

1 6 111

- 1 8 ' " ' • '

' 3 8 ' 7 1 7

' 3 8

270

•;1K

-:77 7

1890

-.77 7

190 431

66 294

520 :63ri

0 ^2 2 62

• 1 0 - U H

' ,10 ' 14 8

' 1 0 ' 14.8

190 444

' 3 0 '-14 8

< f l ' 1 4 K

' .10 27 2

I W 4- ' l

0 19 11471

' 1 5 0 156

' 1 5 0 -156

< I 5 0 •^1*6

' 1 5 0 • 156

3500 5351!

120(1 • 1*6

200 ; * i

4900 *<i)ll

- 6 3 - - ' H I

' 6 2 - 58 7

' 6 2 -58 7

2(KI 163(1

- 6 2 -58 7

1 KM) 499

\ M 2 1 '

rco :nii 1 1 2 31

• 1 0 ' 1 * 1

<30 -15 1

' 3 0 -15 1

160 119

- 3 0 < 1 5 |

-.3(1 22 8

• 10 - 1 * 1

164) j f t i

1)16 0 161

' 3 1 14 9

' 1 1 ' 1 4 9

< M •-14-9

890 111

< M ' 1 4 9

170 221

120 68 2

MOO 433

! • ! 0 432

' 3 3

' .33

'.1.1

' 3 3

1000

480

110

IWM)

1 6

' 3 3

<33

<33

<J3

<33

<31

' 3 3

- | 4 N

• N-S

- I 4 K

19 1

• 148

- 1 4 8

• 148

19 1

I I 0 I 9 1

- 14"

- U 9

•-149

-149

8550

- 149

4113

H^hl)

N9ft

1 I K ' " 13.5

2 7 " ' 30.5

1 0 ' " 4 7

4 . 3 ' " 1.7

52 15.5

66 24.3

88 2K.5

90 11 I

47 20 7

73 10 9

I K ' " 6

150 62 6

12 '•" 1 9

46 16 2

2 2 ' " 19

100 5 1 1

110 42.6

' 4 1 27 9

.-4 A 45 2

8 4 ' " 36 7

' 4 1 5 4

1 5 ' " 85 t

2 ) t ' " |7ft

2 2 ' " 202

2 1 ' " 220

7 2 ' " 121

2 1 ' " 18S

.36 311

< 1 9 45 5

76 511

9 5 " ' 29 1

K l ' "

' 5 7

75

60

114

542

316

342

• 15 16

16 * 4

•=14 2 7

<3 1 2 2

< 4 | 8.1

<6 1 16.8

' 1 . 3 194

<3 2 20.9

• 4 1 12 1

' 3 5 16 7

- 5 0 209

' 3 2 - ' 4

4 0 ' " 48 4

' 1 9 2 9

2 9 t o *

•^46 6 2

' 1 4 2 , ,

4 . 3 -

6 . 2 ' " 119

1 1 ' " 20 1

• ; i 3 112

< J 2 146

5 5 ' " 37 4

1 8 ' " 65 1

33

37 6 6 9

2 0 ' " 48 2

31 711

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Pre vs : Post Nat ive Subgrade PCB Concent ra t ion

Sain£lc ID

FRSO-OOI

F R S O - 0 0 2

F R S O - n 0 3

F R S O - 0 0 4

F R S O - 0 0 5

F R S O - n 0 6

F R S O - 0 0 7

F R S O - n 0 8

F R S O - 0 0 9

F R S O - n i O

FRSO-011

FRSO-012

F R S O - 0 1 3

F R S O - 0 1 4

F R S O - 0 1 5

F R S O - 0 1 6

F R S O - 0 1 7

A v g .

Y e a r

2006

2006

2006

2006

2006

2006

2006

2006

2006

2 0 0 6

2006

2006

2006

2006

2006

2006

2006

ToUlPCB(uE/ke)

700

12000

12000

3900

1300

1500

4800

180 4100

240

1600

520

190 4900

1700

160 1400

1 3011.2

S a m p l e I D

P S - l . l

PS-2.1

PS-3.1

PS-4.1

PS-S.l

PS-6.1

PS-7.1

PS-8.1

PS-9.1

PS-10.1

P S - l l . l

PS-12.1

PS-13.1

PS-14.1

PS-15.1

PS-16.1

PS-17.1

1

Y e a r

2008

2008

2008

2008

2008

2008

2008

2008

2008

2008

2008

2 0 0 8

2008

2008

2008

2008

2008

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632

435 6700

8290

518

34.9

1930

2430

2080

186

3410

2620

471 5500

2330

161

422

1 2244.1 1

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to.05.16

W

Difference

-68

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4390

-782

-1465.1

-2870

2250

-2020

-54

1810

2100

281

600 630

1

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300

450

600

750 900

1050

1200

1350

1500

1650

1800

1950

2100

2250

2400

2550

2700

2850

3000

3150

3300

3450

3600

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1.571275146

1.396666073

1.222056999

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0 .523620706

0 .349011633

0 .174402559

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0 .24752861

0 .303859747

0 .365815635

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0 .500081111

0 .568291223

0 .634336447

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0 .752597063

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0 ,880383408

0 .909267101

0 .932206821

0 .950036883

0 .963627268

0 .973806403

0 .981313317

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Prepared by; SGL

Cheeked by: JBHI

J:\scopes\06N00l\Resident Engineer\2008 comniunication\Phase I 2007-2008 Summary Report\T-TabIe 4, Native Subgrade PCB Concentration,xls Statistical Calcs

APPENDIX B - Post Construction Stormwater Operation and Maintenance Plan

Summary Report 2007-2008 January 2009 Lower Fox River — Phase I Remedial Action

Lower Fox River Phase 1

Post Const ruc t ion S to rmwa te r Operat ion and iViaintenance Plan

linspection and Maintenance

The Operation and Maintenance Plan has been prepared to document the activities proposed to aspect and maintain the Best Management Practices (BMPs) constructed ai; the Lower Fox S.iver Phasi; 1 property, during the site restoration. As identified in the Site Restoration Plan ;md the Final Site Restoration Plan Construction Details, BMPs constructed at the site are i:omptisi;d of an energy dissipater, riprap channels to stabilize the outfall discharge, along with i;rosion mat and silt fence. The energy dissipater, riprap channels, and outfall discharge are ]?eiTnanent stnictures, where as the erosion mat and silt fence are temporary measures required i.in:il rtie site is vegetated by at least 70% cover.

:>ite inspeciion is proposed as per the requirements of the Construction Stormwater Permit and ifie submitted Site Restoration Plan. The following Stormwater Operation, Maintenance Plan Manageme It Inspection checklist provides recommended inspection and maintenance activities, the structures to inspect, and their suggested frequency. Repairs will be made nhencvtr tie performance of a stormwater control structure is compromised.

Inspections are to be performed by qualified personnel, approved by the Owner and all findings are to be reported to the Owner.

BMP Components of the Stormwater System

rh3 BMPs consists of the following components:

• E!nergy Dissipater • F.ipiap Channels at Outfall Discharge • Exosion Control Mat • Silt Fence

Prohibitions

Applicatiors of fertilizers, herbicides, pesticide or other chemical applications are prohibited (except ibr invasive species eradication) on the site adjacent to the wetland, riprap channels and outfall discharge.

J: sc3pes^06N0OrRe.'.idem Engineer\2008 communicationVPhase I 2007-2008 Summary ReportVApp, BStormwater Mgmt Plan.doc

s t o r m w a t e r Operat ion, IViaintenance, and Management Inspect ion

Inspection Item 1. Energy Dissipater

1) Storm Drain Pipes

2) Riprap Failure

3) Invasive Species

4) Floating or floatable debris removal required

5) Visible Pollution

6) Excessive Sediment Accumulation

7) Other (Specify)

2. Riprap Channels at Outfall Discharge

1) Riprap Failure

2) Invasive Species

3) Floating or floatable debris removal required

4) Visible Pollution

5) Excessive Sediment Accumulation

Inspection Frequency

Semi-,\nnual

Semi-Annual

Condition Maintenance Action Date

6) Other (Specify)

3. Erosion Control Mat None Specified

1) Mat Failure (Erosion)

2) Invasive Species

3) Other (Specify)

4. Silt Fence Weekly or '/," Raini'all

1) Silt Fence Failure

2) Other (Specify)

J:\scopes\06N001\Resident Engineer"2ii(ix communication\Phase I 2007-2008 Siummary Repcn'App. B_Stormwater Mgmt Plan.doc

s t o r m w a t e r Operat ion, IViaintenance, and IVIanagement inspec t ion Checlci ist

Comments.

Actions to Be Tal(en

J:'sc oe>\C(iN(XM'Rtsident Engineer\2008 communication\Phase 1 2007-2008 Summary RcportV'ipp. BStormwater Mgmt Plan,doc

•Report

-m i ! 11

Lower Fox River Phase 1 2007-2008 Remedial Final Summary Report De Pere, Wisconsin I 'roject I.D.: 08N009

IMCR Corporation & U.S. Paper IViiiis Corporation De Pere, Wisconsin

January 12, 2009

#Foti i ^ ^

LOWER FOX RIVER

PHASE 1 2007-2008 REMEDIAL ACTION

FINAL SUMMARY REPORT

Prepared for:

NCR Corporation

and

U.S. Paper Mills Corporation

For submittal to:

Wisconsin Department of Natural Resources

U.S. Environmental Protection Agency

Prepared by:

#Fotl i Foth Infrastructure & Environment, LLC

January 12, 2009

Table of Contents

List of Tiiblcs iii List of Figures iii List of Appendices iii Acronjms iv Distribution List vi 1 INTRODUCTION I

1.1 Consent Decree Objectives 2 1.2 ROD Remedial Goals 2 1.3 Project Organization, Responsibility and Authority 3

1.3.1 NCR Corporation and U. S. Paper Mills Corp 3 1.3.2 Fox River Phase 1 RA Project Coordinator - Roger McCready, NCR 4 1.3.3 Respondents' Project Manager - George Hicks, Shaw 4 1.3.4 Project Resident Engineer - Jim Hutchison, Foth 5 1.3.5 Laboratory Quality Assurance/Quality Control - Eddie Weaver, Shaw 5 1.3.6 Technical Support - Anchor 5 1.3.7 Respondents' Construction Contractor - SES 5 1.3.8 SES Project Manager- Dave Burger 5 1.3.9 SES Site Superintendent - Jack Morrison 6 1.3.10 SES Subcontractors 6 1.3.11 Agency Involvement 6

1.4 Project Notifications and Permitting Activities 7 1.5 Remedial Action 7

1.5.1 Remedial Action Schedule 7 1.5.2 Regulatory Submittal Summary 8

2 DEMOBILIZATION 12 2.1 In-River 12 2.2 Upland 15

2 2.1 Equipment Demobilization 16 2,2.2 Water Quality Management 17 2 2.3 Asphalt Removal/Recycling 19 2 2.4 Gravel (Crushed Stone) Removal 20 2 2.5 Synthetic Liner Removal 21

3 SITE RESTORATION 22 3.1 Stone Characterization 22 3.2 Clearing and Grubbing 23 3.3 Re-Grading 23 3.4 Re-Grading Documentation 24 3.5 Subgrade Characterization 25 3.6 Topsoil Placement, Discing 26 3.7 Wetland Development 26 3.8 Post Construction Monitoring 27

4 REFERENCES 28

Suminar>-Repiin 2(107-2008 ii January 12,2009 I owtT Fox Ri\ er — Phase I Remedial Action

Table of Contents (continued)

List of Tables

Table l-I Remedial Action Schedule — Planned vs. Actual Table I -2 Remedial Regulatory Submittal Summary Table 2-1 Hand-Held Turbidity Readings Collected During In-River Demobilization Activities Table 2-2 Surface Water and Effluent Sampling Results During 2008 Demobilization Table 2-3 Asphalt Pad Sample Results Table 2-4 Gravel Pad Sample Results Table 3-1 Stone Fill Sample Locations Table 3-2 Survey Schedule

List of Figures

Figure 1-1 Phase I Project Dredge Area Figure 1 -2 Organization Chart Figure 2-1 Phase 1 - Site Deconstruction Asphalt & Gravel Drive Sample Locations Figure 2-2 Phase 1 - Site Deconstruction Approximate Liner Location Figure 3-1 Phase 1 - Site Deconstruction Stone Fill Sample Locations Figure 3-2 Phase I - Post-Closure Site Layout Figure 3-3 Phase 1 - Stone Fill Material Thickness Figure 3-4 Phase 1 - Process Facility Subgrade Sample Locations Figure 3-5 Phase 1 - Post-Closure Channel Area

List of Appendices

Appendix A Tables Appendix B Post Construction Stormwater Operation and Maintenance Plan

Summary Report 2007-2008 iii January 12, 2009 Lower Fox River — Phase 1 Remedial Action

List of Acronyms

Anchor Anchor Environmental, LLC y\/OT Agency/Oversight Team BOD biochemical oxygen demand ("D Consent Decree CERCLA Comprehensive Environmental Response, Compensation and Liability Act (rQAPP Construction Quality and Assurance Project Plan CRZ contamination reduction zone cy cubic yard(s) DCU dredge certification unit DMU dredge management unit I-'oth Foth Infrastructure & Environment, LLC GAC granulated activated carbon GIS geographic information system GPS global positioning system gpm gallons per minute HDPE high density polyethylene Hydroseed Hydroseed of Wisconsin KS Kolmogorov-Smimov LTL Lower Tolerance Limit McKeefr;/ McKeefry & Sons Excavating mil millimeter NCR NCR Corporation NE Northeast OU Operable Unit oz ounce(s) Pace Pace Analytical Services, Inc. PAH polynuclear aromatic hydrocarbons PCB polychlorinated biphenyl pH power of hydrogen ppm parts-per-million ProSource ProSource Technologies, Inc. ( A quality assurance (!?APP Quality Assurance Project Plan ( C quality control RAL remedial action level RA Remedial Action RAP Remedial Action Plan RAWP Remedial Action Work Plan Respondents NCR Corporation and U.S. Paper Mills Corporation ROD Record of Decision

Summary Rep^jn 21107-2008 l.c: wor F(n Ri"er - Phase 1 Remedial Action

January 12,2009

List of Acronyms (continued)

RTK Real Time Kinematic SAP Sampling and Analysis Plan SAP/QAPP Lower Fox River Operable Units 2 to 5 Pre-Design Sampling Plan SCCU sand cover certification unit SCMU sand cover management unit SES Sevenson Environmental Services, Inc. Shaw Shaw Environmental and Infrastructure, Inc. SOW Statement of Work SWAC surface weighted average concentration TSCA Toxic Substances Control Act TSS total suspended solids Hg/Kg micrograms per kilogram u s e s Unified Soil Classification System USEPA U.S. Environmental Protection Agency Veolia Landfill Veolia Hickory Meadows Landfill VOC volatile organic compound WDNR Wisconsin Department of Natural Resources WPSC Wisconsin Public Service Corporation ZID zone of initial dilution

Summary Report 2007-2008 Lower Fox River— Phase 1 Remedial Action

January 12,2009

Distribution

James Hahnenberg USEPA Project Coordinator United States Environmental Protection Agency 77 West Jackson Blvd. (SR-6J) Chicago, IL 60604-3590

I CD Copy

Richard Miuawski Office of Regional Counsel U.S. Environmental Protection Agency Region 5 '"^ West Jackson Blvd. Chicago, IL 60604

I CD Copy

Bruce Baker ^VT)NR Proji;ct Coordinator Wisconsin Dept. of Natural Resources 101 S. Webster St. - AD/8 Madison, W.: 53703

I CD Copy

Jay Grosskopf Boldt Technical Services 2525 North Roemer Rd. Appleton. WI 54912

I CD Copy, 3 Paper Copies

Richard Fox Natural Rescurce Technology 23713 West Paul Rd.#D Pewaukee, V/I 53072

1 CD Copy

Jennifer Kahler Natural Resource Technology 23713 West Paul Rd#D Pewaukee, V/I 53072

I CD Copy

Gary Kincaid \V DNR On-Site Engineer \V isconsin Dept. of Natural Resources 2984 Shawano Ave. Green Bay, WI 54313

I CD Copy

Roger McCready Cijrporate Environmental Engineer NCR Corporation 1700 S Patterson Blvd. WHQ-4 Davton, OH 45479

1 CD Copy

Summary Pepcrt 2007-2008 Lo*er Fox River — Phase I Remedial Action

January 12,2009

Distribution (continued)

John M. Heyde 1 CD Copy Sidley Austin, LLP One South Dearborn St. Chicago, IL 60603

Jeffrey T. Lawson 1 CD Copy Project Control Companies, Inc. 20 Trafalgar Square Nashua, NH 03063

Larry Pattengill 1 CD Copy Sonoco - U.S. Paper Mills Corp. Consultant 716 Fort Howard Ave. P.O. Box 5850 DePere,WI 54115-5850

Clay Patmont 1 CD Copy Anchor Environmental, LLC 1423 Third Ave. Suite 300 Seattle, WA 98101

Paul LaRosa 1 CD Copy Anchor Environmental, LLC 10 New England Business Ctr. Dr. Suite 102 Andover, MA 01810

Jim Hutchison 1 CD Copy, I Paper File Copy Foth Infrastructure & Environment, LLC 2737 S. Ridge Rd. Green Bay WI 54307

Matt Oberhofer 1 CD Copy Foth Infrastructure & Environment, LLC 2737 S. Ridge Rd. Green Bay WI 54307

Summary Report 2007-2008 vii January 12, 2009 Lower Fox River — Phase 1 Remedial Action


1 INTRODUCTION

I'oth Infrastructure & Environment, LLC (Foth) has prepared this Lower Fox River Phase 1 2007-2008 Remedial Action Final Summary Report (Foth, 2008) (2007-2008 RA Summary Report) on behalf of NCR Corporation (NCR) and U.S. Paper Mills Corporation. (U.S. Mills) to document project demobilization and site restoration.

In February 2008, Shaw Environmental & Infrastructure, Inc. (Shaw), Foth, Anchor Environmental, LLC (Anchor) and Sevenson Environmental Services, Inc. (SES), prepared a Lower Fox River Phase I 2007 Remedial Action Draft Summary Report (Shaw et al., 2008) (2007 RA Draft Summary Report) on behalf of NCR and U.S. Mills. The 2007 RA Draft Summary Report was submitted to document final dredge elevations. The U.S. Environmental Protection Agency (USEPA) and the Wisconsin Department of Natural Resources (WDNR) acknowledged the submission of the 2007 RA Draft Summary Report in a letter dated April 25, 2008. The 2007 RA Draft Summary Report is incorporated by reference in this 2007-2008 RA Summary Report.

The USEPA and the WDNR (the "Response Agencies") have requested this 2007-2008 RA Summary Report as part of activities under a Consent Decree (CD) and accompanying Statement of Work (SOW) entered into between the USEPA and WDNR (the "Response Agencies"), and NCR and U.S. Mills (tie "Respondents") in March 2006. The CD required the Respondents to perform the Phase ] Remedial Action within 0U4 of the Lower Fox River in Green Bay, Wisconsin (the "Phase I Project") (USEPA 2006).

The Phase 1 Project area is located on the west shore of the Fox River, just downstream of the De Pere Dam, located in the city of De Pere, Wisconsin. In order to achieve the cleanup objectives outlined by the CD, the sediments within the Phase 1 Project limits were removed by hydraulic dredging, transported to an on-shore treatment site, dewatered, and loaded in trucks (after achieving the minimum landfill strength requirements) for offsite disposal.

1 he dredge area extended approximately 750 feet out from shore and was approximately 1,100 feet wide, covering approximately 20 acres (22 acres including anticipated side slopes), as shown on Figure I-1. A portion of the sediments targeted for removal from the Phase I Project required handling and disposal under the Toxic Substances Control Act (TSCA). All other sediment dredged from the Phase I Project area was disposed of as non-TSCA waste.

The major tasks involved in performing the work were generally as follows:

• Demonstrating compliance with the substantive requirements of regulations under which permits would have been required but for the "permit bar" under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

• Additional treatability studies to support the design of the dewatering and wastewater treatment plant Mobilization and site preparation including proper erosion control features

• Installation and maintenance of an in river turbidity curtain containment system for dredging and sand cover operations

• Mechanical debris removal operations as required, prior to, and during dreiiging operations

• Hydraulic dredging to remove targeted sediments in the Phase 1 Project area • Processing and dewatering of the dredged sediments • Transportation of dewatered sediments removed from the vertical and horizontal extents

delineated as TSCA, based on remedial design sampling, to an appropriate TSCA landfill

•

Sumirir> Repcrt 2007-2008 1 January 12, 2009 l.cwcr Fox R i v e r - - Phise 1 Remedial Action


Transportation of dewatered sediments removed from the areas, not otherwise delineated as TSCA, to an appropriate landfill subtitle D landfill Treatment of filtrate and all other wastewater generated by the processing and dewatering operations through an on-site temporary wastewater treatment plant with discharge within the work zone through a submerged diffuser Monitoring of treated water discharged back to the river Monitoring of surface water (turbidity) during in-water operations Post-dredge bathymetric surveys and sediment sampling to verify that cleanup objectives were achieved Placement of a sand cover over a portion of the dredge areas, based on the results of post-dredge sediment sampling Post-sand cover sampling to verify that required thickjiesses had been achieved

• Demobilization and winterization • Monitoring of site between 2007 and 2008 dredging seasons

•

1.1 Consent Decree Objectives

The following cleanup objectives for the Phase 1 Project were set forth in the Phase 1 CD:

• The final post-dredge confirmatory bathymetric surveys of the Phase 1 Project area must indicate that sediment removal to an agreed-upon set of target elevations (designed to achieve removal of sediment above 1.0 part per million [ppm]) has been achieved over at least 95% of the Phase 1 Project area.

• The final post-removal confirmatory sediment sampling within the Phase 1 Project area must indicate that all sediments containing polychlorinated biphenyls (PCBs) at a concentration of 50 ppm or greater have been removed.

• If final post-removal confirmatory sampling revealed that sediment with PCB concentrations exceeding 1.0 ppm remains within the Phase 1 Project area, the Respondents must place a minimum of 6 inches of "clean sand" over that area, consistent with the Record of Decision (ROD). Any clean sand used for this purpose must be received from an off-site source. The Respondents also have the option of performing additional dredging to address sediments with PCB concentrations exceeding 1,0 ppm remaining after removal of sediment to the required project limits.

• The Respondents must establish side slopes adjacent to the Phase 1 Project Area that are sufficient to ensure the stability of remaining sediments. All side slopes with surface PCB concentrations exceeding 1.0 ppm must be covered with a minimum of 6 inches of clean sand, consistent with the ROD.

1.2 ROD Remedial Goals

While achieving the CD objectives was required, the Respondents also had the option of satisfying the remedial goals described in the 2007 Lower Fox River ROD Amendment (USEPA and WDNR, 2007) in the Phase 1 Project area. As presented in the Agency-approved Optional SAP Addendum for Phase 1 Verification of Project Completion (Shaw et al., 2007a), the Phase 1 post-dredge verification sampling and analysis activities performed in the various dredge certification units (DCUs) were aimed at determining whether removal (dredging) actions within these areas had achieved the ROD Amendment remediation goals.

Summary Report 2007-2008 2 January 12, 2009 Lower Fox River — Phase 1 Remedial Action


The ROD Amendment used the term "generated residuals" for sediment that was re-suspended and le-deposited on the surface of newly-dredged areas (assumed to be within the top six inches of the sediment, possibly dependent on dredge technique), and it used the term "undisturbed residuals" for sediment that was more than six inches from the surface of the sediment. If post-removal confirmaton/ sampling in a sediment removal area revealed generated residuals with PCB concentrations exceeding the 1.0 ppm PCB remedial action level (RAL), then the following requirements can be applied for management of the generated residuals:

• Generated residuals with a PCB concentration between 1.0 ppm and 10.0 ppm must be covered with at least 6 inches of clean sand from an off-site source (referred to as a "residual sand cover") if placement of a residual sand cover in the area was necessary to meet the surface weighted average concenfration (SWAC) goal for the operable unit (OU) (i.e., a SWAC of 0.28 ppm PCBs in OU 3 and a SWAC of 0.25 ppm PCBs in OU 4).

• Generated residuals with a PCB concentration equal to or greater than 10.0 ppm must the subject of an engineering analysis to determine next steps, which could include: (1) removal (t;/pii:ally by re-dredging) in accordance with the sediment removal requirements specified above; (2) capping, if the eligibility criteria for that alternate remedial approach can be met, as specified below; or (3) placement of a residual sand cover.

For management of undisturbed residuals:

• Undisturbed residuals exceeding the 1.0 ppm PCB RAL must be the subject of an engineering analj'sis to determine next steps. Unless the Response Agencies approve use of a different residuals management approach in a particular area within an OU, undisturbed residuals with a PCB concentration exceeding the 1.0 ppm PCB RAL must be removed (typically by re-dredging) in accordance with the sediment removal requirements specified above. However, as a resuh of the engineering analysis, the Response Agencies may approve use of a different residuals management approach (such as a cap or a residual sand cover) for undisturbed residuals in limited areas.

1 3 Project Organization, Responsibility and Authority

The Phase I Project organizational structure includes the Respondents (NCR and U.S. Mills); the Respondenti' Construction Management Team (including Project Manager, Technical Director, Resident Engineer, Engineering Support Team, and other support personnel); the (Contractor and its subcontractors; and the Response Agencies (USEPA and WDNR, along with an .Agency/Oversight Team [A'OT]). The project organization chart is provided in Figure 1-2. Details of the roles and responsibilities for each of the key personnel are provided in the following sub-sections. Additional information regarding project responsibilities and authorities is provided in the Phase 1 Construction Quality Assurance Project Plan (Shaw and Anchor, 2006a).

The project organization chart is provided in Figure 1-2. Details of the roles and responsibilities for each of t le key personnel are provided in the following subsections.

13.1 NCR Corporation and U.S. Paper Mills Corporation

NCR and U.S. Mills entered into a CD to perform the Lower Fox River Phase I K\. NCR and U.S. MiLs funded the project and provided overall project coordination for the Phase 1 Project.

Summary Report 2iX)7-2008 3 January 12,2009 l.ow^r Fox River - - Phase 1 Remedial Action


1.3.2 Lower Fox River Phase 1 RA Project Coordinator — Roger McCready, NCR

Roger McCready was responsible for the following tasks during the 2007 RA:

Monitored overall progress and compliance with the Lower Fox River Phase 1 RA Work Plan (RAWP); Informed the Respondents of significant issues during the 2007 remedial activities and worked with Respondents' Construction Management Team and Contractors to resolve these issues; Communicated with USEPA and WDNR on an ongoing basis regarding significant issues during the 2007 remedial activities and responded to Agency concerns (after consultation with Respondents' Construction Management Team, when needed); Prepared and submitted the RA Monthly Progress Reports required by the CD with the assistance of Respondents' Construction Management Team, and others as needed; Reviewed and approved invoices directed to Respondents; and Assisted with public and government affairs as needed.

1.3.

Geo

Respondents' Project Manager — George Hicks, Shaw

ge Hicks was responsible for the following tasks during the 2007 RA:

Informed Respondents of project progress and any significant issues, and worked with Respondents, the Project Coordinator and the Contractor to resolve significant issues as identified by the Contractor; Communicated with USEPA and WDNR on an ongoing basis regarding day to day operations during the 2007 remedial activities and responded to Agency concerns (after consultation with the Respondents' Project Coordinator and with the Respondents, when needed); Coordinated the development of all RAWPs; Notified USEPA and WDNR of releases or threatened releases when required by the CD and served as a point of contact for Agency officials and contractors regarding actions to address the release or threatened release; Provided necessary project-related approvals as authorized by the Respondents; Reviewed monthly RA progress reports prepared by the Project Coordinator, as required by the CD; Made recommendations to Respondents' Construction Management Team regarding proposed changes in the implementation of the field work and means to reduce costs and/or make the project more effective; Coordinated RA activities between the Contractor (SES) and the Respondents; Monitored Construction Quality Assurance (CQA) activities; Assisted with public and government affairs as appropriate, including acting as a spokesman and community liaison for Respondents; and Managed activities of subcontractors, who performed site activities on behalf of the Respondents including pre-construction archaeological surveys, bathymetric surveys, environmental monitoring, and post-dredge/cover quality assurance sampling. Contributed to the 2007 RA Draft Summary Report.



1,3 4 Respondents' Project Resident Engineer — Jim Hutchison, Foth

Jim Hiitchiscm was responsible for the following activities during the 2007 RA:

• Implementation of the CQAPP; • Managed demonstration of compliance with substantive provisions of WDNR's Chapter 30

regulation; • Directed post-dredge bathymetric surveys; • Performed and supervised environmental monitoring and quality assurance sampling,

including surface water (turbidity), effluent, air quality, sediment removal verification, and sand cover thickness verification;

• Coordinated on-site sampling activities in accordance with 2007 Remedial Action Work Plan (Shaw et al., 2007);

• Performed dewatered sediment strength characterization per landfill requirements; • Reported directly to the Respondents' Project Manager and communicated and

coordinated activities with SES's Project and/or Site Manager; • Assisted Respondents' Project Manager in ongoing communication with USEPA and

V/DNR regarding project performance and other issues as requested; • Managed generation of Resident Engineer daily reports; • Managed the project Sharepoint website; • Assisted in performing site monitoring between 2007 and 2008 dredge seasons; and • Contributed to this 2007-2008 RA Summary Report.

1.3.5 Laboratory Quality Assurance/Quality Control — Eddie Weaver, Shaw

Eddie Weaver was responsible for the following activities during the 2007 RA:

• Coordinated on-site sampling activities with laboratory and Resident Engineer in accordance with 2007 RAP; and

• Maintained laboratory test data and results.

1.3.6 Technical Support — Anchor

Anchor Environmental, LLC (Anchor) was responsible for the following activities during the 2007 Phase I Project:

• Provided technical support and assistance in developing the 2007 RAP; • Developed Phase 1 Project Sampling and Analysis Plan; and • Provided technical support throughout the 2007 RA.

1.3.7 Respondents' Construction Contractor — SES

SES was ;he Construction Contractor for the Phase 1 Project. SES managed and performed all on-siie constmc :ion activities on behalf of the Respondents. The following subsections summarize the responsibilities of key SES persoimel who performed management roles for the Kk.

1.3.8 SES's Project Manager — Dave Burger

Dave Burger was responsible for the following tasks during the 2007 RA:

• Resfionsible for providing overall direction and management of 2007 RA project activities on site including dredging, dewatering, water freatment, and disposal;

Sunrnary Report 2C07-2008 5 January 12,2009 Lower Fox River — Phase 1 Remedial Action


• Responsible for communicating to Respondents' Project Manager regarding project progress and issues needing their involvement for resolution;

• Prepared and implemented contingency plans as described in the CD; • Performed administrative and decision-making activities; • Implemented health and safety plans; • Responsible for maintaining updates to the construction schedule; • Prepared and submitted monthly invoices to Respondents; and • Responsible for coordinating with the Respondent's Project Resident Engineer.

1.3.9 SES's Site Superintendent — Jack Morrison

Jack Morrison was responsible for the following tasks during the 2007 Phase 1 Project:

• Instructed and coordinated activities with field staff; • Coordinated subcontractor and SES schedules; • Ensured that field activities were conducted in accordance with the 2007 RAP; • Ensured that field staff were properly trained to perform field activities in accordance

with the 2007 RAP, possessed proper certification (e.g., current Hazardous Waste Operations and Emergency Response [HAZWOPER] training), and complied with medical monitoring requirements;

• Inspected and accepted supplies and equipment; • Communicated construction and operations issues to the project team; • Performed oversight of subcontractor activities; and • Notified the Respondent's Project Resident Engineer when QA bathymetric surveys

were required,

1.3.10 SES's Subcontractors

The main SES's subcontractors were as follows:

• Dixie Environmental - provided chemicals for dewatering and water treatment processes. • Mc Keefry & Sons, Inc. - performed dewatered sediment trucking to non-TSCA landfill. • ProSource Technologies, Inc. - performed poling and hydrographic surveys.

1.3.11 Agency Involvement

1.3.11.1 USEPA's Project Coordinator — Jim Hahnenberg

Jim Hahnenberg was responsible for the following tasks during the 2007 RA:

• Reviewed all project deliverables and plans and/or approved project strategies; • Reviewed and approved the 2007 RAP; • Provided technical assistance to Respondents' Project Coordinator; • Reviewed progress reports detailing work accomplished; • Reviewed and provided comments on all reports in draft version prior to their

finalization; and • Provided USEPA approval of final reports.

Summary Report 2007-2008 6 January 12,2009 Lower Fox River — Phase I Remedial Action


] ,3,11.2 WDNR's Project Coordinator — Greg Hill

(jreg Hill was responsible for the following tasks during the 2007 RA:

• Revewed all project deliverables and plans and/or approved project strategies; • EHrected 2007 RAP review and approval; • Provided technical assistance to USEPA and Respondents' Project Coordinator; • Reviewed progress reports detailing work accomplished; • Reviewed and provided comments on all reports in draft version prior to their finalization; and • Pro\ ided WDNR approval of final reports.

]. 3,11,3 WDNR's Oversight Contractor

Boldt (Constmction and its subcontractors (Oversight Team) operated as WDNR's designated oversight co:itractor. They provided technical assistance to the WDNR during the 2007 Phase 1 Project,

] ,4 Project Notifications and Permitting Activities

Under the CliRCLA, the procedural requirements of federal, state and local permit programs are waived, but the substantive requirements of the programs must still be satisfied. For the Lower Vox River Phase 1 Project the following project notifications and compliance demonstration activities were conducted:

• WDVR Chapter 30 • V/DNR Stormwater Management Notice of Intent • Ajmy Corps of Engineers Section 404 Program • City of De Pere Floodplain Zoning Approval

1,5 Remedial Action

1,5 1 Remedial Action Schedule

Table 1-1 depicts key milestones dates as proposed in the 2007 RAP schedule and actual dates of completion for work performed during the 2007 construction season.

SuTirnary Report 2C07-2008 7 January 12,2009 Lower Fox Ri%er — Phase I Remedial Action


Table 1-1. Remedial Action Schedule Planned vs. Actual

MmiMestonea ;: Site kick-off meeting

Begin mobilization to the site

Completion of construction of the dewatering and water treatment processes

Mobilization and construction of the dredging equipment and installation of the silt curtains

Initiation of dredging operations

Initiation of sand cover operations

Completion of dredging operations

Completion of sand cover operations

Demobilization from the site

KevUmsmsBms > h -.• ,>-*i«i*l%V* : June 22, 2006

July 16,2006

November 10, 2006

April 27, 2007

May 1, 2007

July 1,2007

September 30, 2007

October 15,2007

October 27, 2007

June 22, 2006

July 16,2006

April 27, 2007

March 23, 2007

May 1,2007

September 5, 2007

November 14, 2007

To be completed by others

November 2007^ a. Partial demobilization occurred in Novetnber 2007; however,

anticipated ftiture use in 2008, a portion of the site infrastructure was retained on-site for

1.5.2 Regulatory Submittal Summary For documentation purposes. Table 1 -2 provides a summary of key submittals which substantially met permit requirements of the Phase 1 project.


January 12,2009

^ccliuii I liiiiuductiuii

I aoie ^-'^. Kemeaiai Keauiatorv îuDmlTTal f i i immarv

i - . - i V i f i i i S i ^ ^

Foth/WDNR

1 knAu^

f "T^ ' ' ^ ' ^ ^ ' " ' " ^ " ' ' ^ ^ " - ^

t h(nyl Bougie • i ^ .

NOI Permit Application - Phase I Remedial Action

7 ^ t^ "&T^ J j ^ ^ y T ^ - .

July 19,2006 -IÎSJgjiJ

Submittal Tuih.'WnNR 'like Licbman rhcr\i fJougic

[WDNR reviewer

NOI Clearing & Cirubbing Pcmiit Application - PliA,st: 1 RriiK-ilirfl Aiiinn July 74, 7006 Si i l . i i i JMi i l

JFNcwAVDNR Dan Sales Natural Heritage Information review request (Form 1700-047) Julv 24. 2006 Submittal

Shaw, Anchor. Folh'EPA, WDNR Icoryc Micks'Taul LaRosa^' lay Fuiiiiuiii/Jiiii riuiciiiiiuii

EPA^/WDNR Phase 1 Pre-Dcsign Plan including Appendix A, the Constmction Assiimnce Projeci Phin) July 24, 2006 Submittal

WDNR/Foth Cheryl Bougie Mike Liebman Stormwater NOI Submittal to DNR for clearing and gmbbing July 24. 2006 Verbal Approval - email

Shaw, Anchor, Foth/EPA, WDNR lames Hahnenberg George Hicks Phase 1 Pre-Design Plan (including Appendix A, the Construction Assurance Project Plan July 27,2006 Approval

WDNR/Sonoco-U.S. Mills Cheryl Bougie Larry Pattengill Storm Water Discharges Associated with Land Disturbing Construction Activities July 28, 2006 Conditional approval

FothAVDNR Mike Liebman Cheryl Bougie NOI Permit Application - Site Development, Phase 1 Remedial Action August 4, 2006 Submittal

Jurisdictional determination and navigable waterways request. Attachment - Wetland Delineation Report

I l ^ e w (on behalf of Foth)/WDNR Dan Sales Mike Russo/Linda Kurtz

August 9, 2006 Submittal

FothAVDNR Mike Liebman Cheryl Bougie Lower Fox River Phase t NOI Follow-up, Attachment - 01570 Temporary Erosion and

Sediment Control Plan

August 10, 2006 Email submittal

FothAVDNR Mike Liebman Kristy Rogers Property Ownership Documentation, Photographs of site before and after reclamation. Remedial Action Plan

August 11.2006 Submittal

Department of the Army (Corps of Engineers) Robert J. Whiting Larry Pattengill Permitting Regulations within Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act of 1899

August 16,2006 Approval

FothAVDNR Mike Liebman Kristy Rogers Lower Fox River Phase I Chapter 30 Follow-up, Attachment - Revised site restoration plan August 16,2006 Email submittal

EPA/Wisconsin Historical Society Mike Liebman Kristy Rogers Lower Fox River Phase I Chapter 30 Follow-up, Attachment - Dewatering site map with adjusted ordinary high water mark

August 18, 2006 Email submittals

Wisconsin Historical Society/EPA James Hahnenberg Sherman Banker Phase I Archaeological Investigation of the Lower Fox River Phase 1 Remediation Site along

the West Bank of the Lower Fox River

August 21,2006 Submittal

FothAVDNR Sherman Banker James Hahnenberg Lower Fox River PCB Remediation, De Pere - July 21 and August 21, 2006 submittal review August 22,2006 Approval

Foth/SES/SonocoAVDNR Mike Liebman Cheryl Bougic/Kristy Rogers

Lower Fox River Phase 1 NOI and Chapter 30 Follow-up, Attachments - Grading Plan,

SHPO Approval

August 23,2006 Email submittal

FothAVDNR Jim Hutchison/Dave Burger/Larry Pattengill

Alan Nass Form 4400-226 and 4400-226A, Revised Grading Plan, Approximate Disposal Area Locations

August 30,2006 Submittal

WDNR/Sonoco-U.S. Mills Mike Liebman Kristy Rogers/Cheryl Revised Grading Plan, Approximate Disposal Area Locations August 30,2006 Submittals

WDNR/Sonoco-U S, Mills Bruce Urben Larry Pattengill Conditional (E.\pcdited) Grant of Exemption for the Development of a Property Where Solid Waste has been Disposed

August 31, 2006 Approval

FothAVDNR Cheryl Bougie Larry Pattengill Storm Water Discharges Associated with Land Disturbing Constmction Activities August 31.2006 Approval

WDNR/Sonoco-US. Mills Mike Liebman Cheryl Bougie NOI Narrative Description Amendment - Site Development - Phase I Remedial Action August 31,2006 Submittal WDNR/JF>Iew Kristy Rogers Larry Pattengill Approval - Chapter 30 and s.281.15 and 281.36 of Wisconsin Statutes and Wis Adm Code

Chapters NR 299 and NR 103 Substantive Requirements - Land Constmction Activities September 1,2006 Approval

Village of Ashwaubenon Park Board Andrew P. Galvin Dan Salas Endangered Resources Review (ERIR Log # 06-243) October 13,2006 Approval

iJ l lctW, I U l l l , J l - , i3 uuuigc niuKvJuu Hutchison

wuiNK. reviewer ucwaicnng racuicy Lmer Lônstruction i est uata iNovcmoer b, zuub

Shaw, Anchor, Foth / EPA, WDNR George Hicks/Paul LaRosa/ Clay Patmonl/Jim Hutchison

Jim Hahnenberg/Greg Hill

Lower Fox River Phase 1, Remedial Action Plan November 3,2006 Submittal

Wisconsin Historical Society/EPA Tcrri Lewis Meeting Minutes - Fox River Dredging Staff Parking November 21,2006 Submittal

FothAVDNR Sherman Banker James Hahnenberg Lower Fox River PCB Remediation, De Pere -January 12, 2007 archaeological submittal February 7,2007 Approval

Foth/US Coast Guard Jim Hutchison Kristy Rogers Chapter 30 (Waterway) Permit Information for In-stream Activities (Inc. Form 3500-053) March 2. 2007 Submittal

WDNR/Sonoco-U.S, Mills Doug Sharp Mike Liebman Fox River Dredging - Aids to Navigation March 16,2007 Email Approval

Summary Report 2007-2008 Lower Fox River — Phase I Remedial Action

January 12.2009


^mmmmn^mm''^ •"* -•'>•' WDNR/Sonoco-U S Mills

EPA

WDNR

EPA/Wiseonsin Historical Society

5haw, Anchor, Foth / EPA, WDNR

EPA / WDNR / Boldt

Shaw, Anchor, Foth/EPA, WDNR



EPAShaw


Siiaw, Anchor, Fotli/EPA, WDNR

EPA/Shaw

EPA/Shaw

EPA/Shaw

EPA'Shaw

EPA'Shaw

EP/VShaw


Shaw, Anchor, FothEPA, WDNR

Shaw, /Anchor, Foth/EPA, WDNR

lay GrosskopPShaw

EPA/Shaw

EPA/Shaw

Shaw, /Anchor, Foth/EPA, WDNR


EPA/Shaw

Shaw. Anchor, LTl/EPA, WDt>ffi

"-•" -~ f^mkiih'r ' ' •» v1b*M 1 Knsty Rogers

Jim Hahnenberg

Kristy Rogers

lim Hahnenberg

jeorge Hicks/Paul LaRosa/ Clay Patmont/Jim Hutchison

A/OT

George Hicks/Paul LaRosa/ Clay Patmont/Jim Hutchison



lim Hahnenberg

George Hicks/Paul LaRosa^

Clay Patmont/Jim Hutchison

George Hicks/Paul LaRosa/

Clay Patmont/Jim Hutchison

lim Hahnenberg

lim Hahnenberg

George Hicks/Paul LaRosa/ lim Hutchison

Jim Hahnenberg

James Hahnenberg

lames Hahnenberg

George Hicks/Paul LaRo,' a/ Clay Patmont/Jim Hutchison Cicorgc Hick,s/Paul LaRosa/' Clay Patmont/Jim Hutchison George Hicks/Paul LaRosa/ Clay Patmont/Jim Hutchison

lay Grosskopf on behalf of the AGENCIES

lim Hahnenberg

Jim Hahnenberg

George Hicks/Paul LaRosa/

George Hicks/Paul LaRosa/ Clav Patmonl/Jim Hutchison lim Hahnenberg


Larry Pattengill

George Hicks

lIsTMiilsRcp

George Hicks

lim Hahnenberg/Greg Hill

George Hicks


lim Hahnenberg/Greg rtill

lim Hahnenberg Greg Hill

George Hicks



George Hicks

George Hicks

lim Hahncnberg/Grcg Hill

George Hicks

George Hicks

George Hicks

lim HahncnbcTg/Grcg Hill lim Hahiiciibcrg'Grcg Hill

lim Hahncnberg/Grcg Hill

George Hicks

George Hicks

George Hicks

Jim Hahnenberg/Greg Hill Jim Hahnenberg/Greg Hill jcorge Hicks

lim Hahnenberg/Greg ^ill

Phase 1 Project - 0U4 (Chapter 30 Substantive Requirements) March 28, 2007 ICondnional Approval

Lower Fox River Phase 1, Remedial Action Plan

Approval - Chapter 30 Substantive Requirements - In-Water Activities

Lower Fox River Phase 1, Sampling Analysis Plan (dated April 2007)

L,ower Fox River Phase 1 Sand Cover Verification Plan

Comments to Lower Fox River Phase 1 Sand Cover Verification Plan

Response to Comments - Lower Fox River Phase 1 Sand Cover Verification Plan

Lower Fox River Phase 1: Documentation of QA/QC Evaluation for TSCA Unit #1 Post-Dredge Survey

Standard Operating Procedure, High Sub-Grade Sampling

Lower Fox River Phase 1: Documentation of QA/QC Evaluation for TSCA Unit#l Posl-Drcdgc Survey

Lower Fox River Phase 1 Sand Cover Source Analysis Results Memorandum

Optional SAP Addendum for Phase 1 Verification of Project Completion

Lower Fox River Phase 1 Sand Cover Source Analysis Results Memorandum

Standard Operating Procedure, High Sub-Grade Sampling

Lower Fox River Phase 1, TSCA Unit #4; High Sub-Grade Determination

Optional SAP Addendum for Phase 1 Verification of Projeci Completion

Lower Fox River Phase 1, TSCA Unit #4; High Sub-Grade Determination

Lower Fox River Operable Units 2-5 Remedial Design Sampling Plan Addendum for Phase 1 P-cmcdi.' ! .^rlion Lower Fox River Operable Units 2-5 Remedial Design Sampling Flan Addendum for Phase 1 Remedial Action Lower Fox RIVLT Phase I, Modification to the Post-Dredge Bathymetric Survey Method

Lower Fox River Phase 1, Non TSCA DCU 2; Verification of Completion ^

Email approving the procedures from; Lower Fox River Phase 1, Modification to the Post-Dredge Bathymetric Survey Method

Approval of Sand Cover for DMUs 1,2 & 7

Interim Sand Cover (between 2007 and 2008 constmction seasons)

FINAL VERSION - Lower Fox River Operable Units 2-5 Remedial Design Sampling Plan Addendjim for Phase 1 Remedial Action Lower Fox River Phase 1, Non-TSCA DCU 1; Verification of Completion

Lower Fox River Phase 1, Non-TSCA DMUs 21 & 22 High Sub-Grade Shoreline Delineation

Lower Fox River Phase 1, Non-TSCA DCU 3; Verification of Completion

April 9, 2007 Conditional Approval

April 10, 2007

April 25, 2007

Approval

Conditional Approval

May 24, 20007 Submittal

June 3, 2007

June 12,2007

July 5, 2007

July 7, 2007

July 10,2007

luly 11,2007

luly 16, 2007

luly 17, 2007

luly 18,2007

luly 19, 2007

luly 23, 2007

luly 24, 7007

August 8, 2007

August 9, 2007

August 211, 21107

September 10,2007

September 20,2007

SeptcmbCT27,2007

ScptembCT28,2007

October 1,2007

October 2,2007

October 3,2007

October 5,2007

Submittal

Submittal

Submittal - FYl Only

Submittal, Anachment C 0 TSCA Unit #4: High Sub-Grade Memo

Acknowledgement Receipt

Submittal

Submittal

Approval

Approval

Submittal

Conditional Approval

Approval

Approval, with comments

Response to Comments

Submittal

Submittal

Email Approval

Approval

Acknowledgement Receipt

Submittal

Submittal

Apprxjval

Submittal


January 12,2009

bici^llull I ilUjL>iJlli,;lluil

:•:::—~:?^rS= '•>'•'""tfifSi'^'^-^^^^^Ef- -•"-r-^~'»#i>rf^;:^g^-:~--:B;.*iii*t • • 4 . - **!«t

.Shaw, Anchor, FoirvbFA, WDNR Geuiye Hicks/Paui LaRosa/ pirn Haiuieribeig/Greg t l a v Pamiont/John Wolfe hil l

Shaw, Anchor, i-oth/EPA, wuNi<

Shaw, Anchor. Foth'FPA, WDNR

Straw, Anchor, lo thEPA, WDNR

EPA/Shaw

EPA/Shaw

Shaw, Anchor, Foth / EPA, WDNR

Shaw. Anchor, Foth / EPA, WDNR


EPA/Shaw

EPA/Shaw




EPA

FothWDNR

Foth/WDNR

George Hick&Paui LaRosa/ hm Hiilrhisnn im Hahnmhcrg

George Hiek'Paul LaKosa/Jim Hutchison

lim Hahnenberg

Jim Hahnenberg

George Hicks/Paul LaRosa/Jim Hutchison

George Hicks/Paul LaRosa /Jim Hutchison

George Hieks/Paul LaRosa/Jim Hutchison

Jim Hahnenberg

Jim Hahnenberg

George Hicks/Paul LaRosa/ Clay Pahnont/Jim Hutchison

EPA/WDNR

George Hieks/Paul LaRosa/ Clay Pahnont/Jim Hutchison

James Hahnenberg

Jim Hutchison

Gary Kincaid

im 1 lanncnDcrg/ureg Hill Cirnrgc Hicks

Jim Hahncnberg'Circg Hill

George Hicks

George Hicks

Jim Hahnenbcrg/Grcg Hill

lim Hahnenberg/Cjreg tJill

Jim Hahnenberg/Greg Hill

George Hicks

George Hicks

Jim Hahnenbcrg/Grcg ^ill

Phase 1 Owners

James Hahnenberg/Greg 4ill;

Roger McCready

Gary Kincaid

Jim Hutchison

uuwei Fux Rivei Plla,sc 1, Veiificaliuiiof-SaiidCitvei Piaeeiiiciil foi SCCU 1

RD Team's responses lo Agency/Oversight Team comments on ihc September i 2, 20l")7

[ owcr Fox RivtT Pha.sc . Non TSCA DCl 11; VcrificaTion of Complelion

Lower Fox River Phase 1, Sampling of the Non-l>edgcd Area Identified During 1 ligh Sub Grade Shoreline Uelmeation

Lower Fox River Phase 1, Non-TSCA DCUs 2 and 3: Verification of Completion

Lower Fox River Phase 1, Sampling of the Non-Chedgcd Area Identified During High Sub Grade Shoreline Delineation

Lower Fox River Phase 1, Sampling of the Non-Dredged Area Identified During High Sub

Grade Shoreline Delineation (Final)

Lower Fox River Phase 1 - Project Completion Plan for 2007

Verification of Sand Placement for SCCU #1

Verification of Sand Placement for SCCU #1

Lower Fox River Phase 1 - Project Completion Plan for 2007

Lower Fox River Phase 1, Non-TSCA DCUs 4, 5 and 6; Verification of Completion

Lower Fox River Phase 1, Non-TSCA DCUs 4 ,5 , and 6, Verification of Completion

Lower Fox River Phase 1, Remedial Action Draft Summary Report 2007

Acknowledgement of Submission of Phase 1, Remedial Action Draft Summary Report 2007

Final Restoration Grading Plan submittal

Fund Restoration Grading Plan

D g » • ••_,

Otiober iO, 2007

October 12, 2007

October 22, 2007

October 22, 2007

October 2ft, 2007

October 31,2007

November 4,2007

November 6,2007

November 10,2007

November 27,2007

November 29,2007

January 21,2008

October 26,2007

Febmary 2008

April 25, 2008

September 8,2008

September 19,2008

Submillai

Submittal

Approval of meeting required dredge eievaiions 2.",d less Lhan 50 ppm

Submittal

Pnnditional Approval, met required dredge elevations and less than SO DDm Conditional Approval

Submittal

Submittal

Submittal

Approval

Condihonal Acceptance

Submittal

Conditional Approval, met required dredge elevations md less than 50 ppm

Submittal

Acknowledges submittal of Suitimary Report 2007

Submittal

Approval

Prepared by; Shaw Revised by; JBHI

Checked by; WRV


January 12,2009


2 DEMOBILIZATION

Demobilization activities were partial in 2007 due to the potential for 2008 remediation work, which resulted from the completion of Contractor's dredging. Demobilization that occurred in 2007 included the removal of marine equipment from the river and some upland rental equipment. Other on-site equipment was winterized. During the winter of 2007-2008, the decision was made to incorporate the potential 2008 remediation work into the overall OU 2-5 remedial action as it progresses downstream. As a resuh, demobilization of Phase 1 in-river and upland equipment was completed in 2008. A general list of the 2007 and 2008 demobilization activities along with associated dates can be found in Table 1 of Appendix A.

2.1 In-River

In general, in-water demobilization activities for 2007 included the following:

• Deconstruction of temporary dock. • Removal of marine equipment from the project area. • Decontamination of marine equipment. • Removal of sheet piling and silt curtain containment system. • Removal of dredge pipe.

The temporary dock sections were pressure-washed over the river before being placed on the north end of the dewatering pad for storage during the winter season. The dredges, support boats, barges and scows were removed from the river, decontaminated and demobilized off-site for use on other projects. All but two of the sheet piles were removed from the river, decontaminated and placed on the north end of the dewatering pad for storage during the winter season. Approximately 7 sheet piles remained onshore during 2007. Due to low water levels, SES was not able to reach two of the sheet piles on the north end of the dredge area. Leaving the two sheet piles in-place over the winter season was contingent upon the following:

• The sheet piles were painted orange for high visibilit)'. • A 2-ft long pole (with colored reflectors) reaching above the piles was placed next to each of

the piles to provide visibility in the event of significant snow accumulation. • A white Hght and a yellow strobe light were placed on each sheet pile. • The warning lights on the sheet piles were monitored and maintained.

There were no reported incidents regarding the 2 sheet piles in the river over the 2007-2008 winter.

Some of the silt curtain containment system was removed during 2007 following the above referenced decontamination activities; however, due to low water levels and freezing conditions, the majority of the silt curtain was left in the river. When demobilization activities resumed in the spring of 2008, the remaining silt curtain system was removed and disposed of at the landfill. The dredge pipeline was pulled up along the shoreline of the dredge area during 2007, in anticipation of the 2008 dredge activities. The effluent discharge pipeline and marker buoys were left in-place for the winter 2007-2008 season.



i\s previously stated, a portion of the in-river demobilization activities were conducted in 2008. The 2008 demobilization activities included the following:

• Decontamination and removal of temporary dock from the river. • Removal of marine equipment from the river project area. • Decontamination of marine equipment. • Removal of sheet piling and silt curtain contairunent system from the river. • Rem oval of dredge, sand placement and effluent pipe from the river.

I-oiir oi" the clock pieces previously pressure-washed and stored on site were placed back in the river during the 2008 demobilization to create a barge used to remove the remaining sheet piles left in the river over the winter. A backhoe on the barge was utilized to remove the majority of the in-river sheet piles; hov/ever, it was unable to pull out four sheet piles along the shoreline. SES rented a vibrating unit which was attached to a crane or backhoe. This method allowed the Contractor to remove the sheet piles fiom the shore on June 19, 2008.

The floating dock pieces, including those used for the barge after in-river activities were completed, were further decontaminated and placed on flatbed trailers for transporting off-site. Support boats and scows rernaiiing on-site were also placed on flatbed trailers and transported off-site.

The remaining turbidity curtain left in the river over the winter season was brought to shore using Jon boats, on June 11, 2008 and was placed on the dewatering pad for ultimate disposal at the landfill.

On June 23, 2008, the anchor weights were removed from the effluent discharge pipeline using the backhoe on the barge. The effluent pipe and marker buoys were then pulled up on shore, the effluent pipe cut i:ito sections, and decontaminated on the pad in the south yard using pressure washers before being stacked on flatbed trailers and transported off-site over the period June 10, 2008 through August 1. 2008.

During the 2008 demobilization activities, ProSource was sub-contracted by SES to perform a poling survey of th«: dredge area. A Foth surveyor observed and performed checks periodically during the survey. A hydrographic survey was also attempted by SES/ProSource, on June 24, 2008, through June 26, 2008; however, attempts were unsuccessftil due to apparent equipment failure.

During in-ri\'er activities, primarily when the barge was active in the water, Foth monitored the water quality b)' taking hand-held turbidity readings. River flow, weather changes, opeti'close De Pere dam gates, etc wi;re also monitored during in-river activities. Turbidity readings are summarized in T;ible2-I.

Summarj'Report 2007-2008 13 January 12,2009 I (iwer Fox Ri\ er — Phase 1 Remedial Action


Table 2-1. Hand-Held Turbidity Readings Collected During In-Rlver

Demobilization Activities

Date

6/i:i/200^

6/i:!/200^

6/i:i/200^

6/13/2008

6/13/2008

6/14/2008

6/14/2008

6/19/2008

6/19/2008

6/19/2008

6/19/2008

6/2(»/2008

6/20/2008

6/20/2308

6/20/2008

6/23/2 308

6/23/2308

6/23/7 308

6/23/2308

Time

08:25

08:25

13:27

13:29

13:33

09:10

09:10

11:54

11:54

11:54

11:54

15:30

15:30

15:30

]5:30

10:22

10:22

10:22

10:22

Location

In approximate location of former upstream turbidity raft In approximate location of former downstream mrbidity raft - downstream of sheet pile

50 yards north from the A.M. upstream reading

In approximate location of former upstream turbidity raft In approximate location of former downstream turbidity raft

In approximate location of former upstream turbidity raft In approximate location of fonner downstream turbidity raft

In approximate location of former upstream turbidity raft In approximate location of former downstream turbidity raft Between upstream and downstream locations -near former effluent outfall North side of the dock'"

In approximate location of former upstream turbidity raft In approximate location of former downstream turbidity raft Between upstream and downstream locations -near former effluent outfall North side of the floating doclc

In approximate location of former upstream turbidity raft Middle of the dredge area along the east edge

In approximate location of former downstream turbidity raft East side of the floating dock

Tari>idity Rudlag (NTUs)

156.4

190.2

297.8

155.4

151.4

186.8

189.7

18.1

29.0

26.8

11.9

244.1

44.8

30.0

13.8

30.6

36.2

27.6

23.7

Noted GondHiMis

10 of 11 flood gates open, high mrbidity due to relatively high Hows from recent precipitation

10 of 11 flood gates open. Brown County under flash flood advisory

Water level high, flowing fairly fast. 6 of 11 flood gates open, little wave action (0.25-0.5')

Strong flow from dam, fish spawning Eictivity in upstream location

Breezy, waves -0.25-0.75', 5 o f ] ] flood gates open, moderate to strong flow

Notes: 11 I I'lo.iting dock located east of fomier V-tanlc on eastern end of dewatering pad.


Mimmaiy Kep.m 2007-2008 1 (iwir I (K River - Phase I Remedial Action

January 12, 2009


2 2 Upland

In general, demobilization and winterization activities for 2007 of the upland facilities included the following:

• Decontamination of equipment, as necessary; • \'isiial inspection of erosion control features; repairs and additions made as necessary; • Demobilization of equipment; and • Backwashing/flushing the water treatment system.

Dewatering and water treatment equipment and other ancillary equipment, including the backhoe, iront-end loader, presses, shakers, and polymer tanks, pumps and light plants were pressure-washed after all sediment had been loaded off of the pad. The asphalt processing/dewatering pad and concrete barrier blocks were also pressure-washed. The decontamination water which went to the sump was pumped through the water treatment system and discharged to the river.

Visual inspections were made of the erosion control features, and repairs were made as necessary. A 3(5-ft section of silt fence was placed across the docking area for protection against overflow discharge from the dev/atering pad. Sand bags were used to reinforce the silt fence.

The water tn;atment system was backwashed and blown out to protect the water lines from freezing.

The water treatment system was not operational during the 2007-2008 winter season. The asphalt processing/dewatering pad was designed to slope towards the sump areas. Overland flow from melting snow/ice and precipitation during winter 2007-2008 pad overflow events was directed towards the silt fence across the docking area to the Fox River. An overland flow from the pad to the river occurred on January 7, 2008 due to relatively high (above freezing) temperatures and precipitation in the form of rain, ll is esiimated that approximately 30,000 gallons of surface water was discharged to the Fox River. Mr. (iary Kincaid, of the WDNR, observed site conditions prior to and during discharge.

During the discharge event, the surface water was sampled at the pad and tested for the effluent parameters that were analyzed for during project production. The results are shown in Table 2-2 (Section 2.2.2).

The demobilization activities of the upland facilities for 2008 included the following:

• Removal of office, break, storage, lab and tool frailers; • Removal of all heavy equipment including excavators, dozers, loaders, forklifts, skidsteer,

pumps, filter presses, mix tanks, filter vessels, shakers, de-sanders, dredges, marine debris removal equipment, and cranes;

• Breakdown and removal of the dewatering, waste water treatment plant, and sand placement equipment;

• Removal and recycling of asphalt from the processing and staging areas; • Removal and load-out of gravel under the asphalt from the processing and staging areas; • Removal and disposal of the geotextile and geosynthetic liners from the processing and staging

areau; • Visual inspection and collection of near surface soil samples to verify that no project-related

PCBs remain; • Ren-ioval and disposal of stone fill with elevated levels of PCBs;

S ummarj' Report 2007-2008 15 January 12, 2009 1 owcr F(M Rjver —- Phase I Remedial Action


• Re-grading of stone fill to bring elevation of area within original floodplain back to approximate pre-project grades; and

• Decontamination of equipment, as necessary.

The following sections discuss upland de-mobilization activities in fiirther detail.

2.2.1 Equipment Demobilization

Upland deconstruction and demobilization activities began on June 9, 2008 with dismantling water treatment piping and removing tent structures over the filter presses. Water treatment, dewatering and sand placement equipment was dismantled, decontaminated, ]3laced on flatbed and lowboy trailers and transported off-site. Decontamination of this equipment was accomplished using biodegradable cleaning products, scrub brushes, hoses and pressure washers.

The filter covers were removed from press plates and loaded into roll-off dumpsters for disposal in the Veolia Hickory Meadows Landfill (Veolia Landfill). The press plates were decontaminated, removed from the presses, stacked onto pallets, shrink-wrapped in plastic and secured with metal bands for load-out. Sediment and excess granular material were removed from the shakers and presses and stockpiled near the northeast comer of the processing /staging area in a contaimnent area for storage and/or dewatering prior to placement into lined roll-off dumpsters for disposal in the Veolia Landfill. The remaining sediment and sludge from the bottom of seven of the mix tanks was removed by hand using shovels, scrapers and wheel barrows and placed on the sediment contaitmient area. The spent filter media was flushed from the filter vessels onto the pad and placed either into unlined roll-off dumpsters or stockpiled on the pad for dewatering prior to placement into lined roll-off dumpsters for disposal in the Veolia Landfill. The remaining media and sludge in the bottom of the filter vessels and the last three mix tanks were pumped out by a Stordeur Sanitation pump truck and discharged into the sediment contaitmient area for dewatering prior to load-out to the Veolia Landfill. The presses, mix tanks and filter vessels were cleaned inside and out prior to transport off-site. After the majority of the sediment and filter media were removed from the pad and stockpiled in the sediment containment area, Quikrete Portland Cement was amended to it. The material was then loaded into roll-off dumpsters and transported to the Veolia Landfill.

Equipment and supplies from the storage area at the south end of the site were brought to the processing/ staging pad for decontamination prior to load-out. Scows were utilized on-site for storage; when SES no longer had use for them, they were decontaminated on the processing /staging area and transported off-site. The structures delineating the contamination reduction zone (CRZs) in the marine staging area and at the south end of the pad were demolished, placed in roll-off dumpsters and transported to the Veolia Landfill.

Throughout the demobilization process, liquid accumulating in the fiiel storage basin was pumped into either empty polymer totes and loaded out by Garrow Oil or pumped directly into Garrow Oil storage tanks. After the barrels and tanks were relocated from the fuel storage basin to the dewatering pad, the fijel storage basin Uner was removed and disposed of in the Veolia Landfill.

The wood ties used as a platform during sediment load-out, the concrete barrier blocks, miscellaneous tools, hoses, cables, and wires were decontaminated and placed on flatbed and lowboy trailers for transport off-site.

Empty Veolia and Midwest Metals roll-off dumpsters were frequently delivered and full ones loaded out as necessary throughout the demobilization process. Metal determined to be scrap after decontaminafion was completed, was placed into the Midwest Metals roll-off dumpster for recycling.

Summary Report 2007-2008 16 January 12,2009 Lower Fox River — Phase 1 Remedial Action


After the majority of the equipment was removed from the dewatering pad, the asphalt pad itself was decontaminated using methods including hand-sweeping/scraping, sweeping with a rotary broom, hosing with water and pressure washing using metered municipal water.

One mix tan.<, one sand filter vessel and one granular activated carbon (GAC) filter vessel were left on-site until all ather equipment was decontaminated and removed from the pad to allow for treatment of the water accumulating on the pad. When the majority of the equipment and asphalt pad were decontaminated, the water on the pad and stored in the final mix tank was treated and discharged, then the mix t mk itself was decontaminated. The filter vessel area was then prepared for filter vessel flushing and decontamination. Concrete blocks were placed on the north and soutli sides of the area. A silt fence and layer of sand were placed against the northern barrier to filter water released from the filter vessels. Wash water and spent filter media flushed from the vessels, were pumped into a Stordeur Sanitation pump truck and transported to the Veolia Landfill. The filter vessels were then (l(;contaminated and transported off the pad and ultimately off-site. The concrete retaining blocks were decontaminated and placed on the U.S. Mills property and/or transported to the McKeefry & Sons Excavating (McKeefry) yard. The asphalt pad in the former filter vessel area was then decontaminated; w aler and re:Tiaining filter media were pushed towards the northeast (NE) comer sump, which was pumped into the Stordeur Sanitation truck. Once decontamination of the pad was completed, water accumidating on the pad was pumped directly to the river, filtered through hay bales and silt fence.

The water line supplying municipal water to the dewatering pad was cut into sections, placed onto a flatbed trailer and transported off-site. The coimection to the water main located in Fort Howard Street and meter valve were removed and capped by Competitive Water and Sewer Company on September 19, 2008.

VOS Electric disconnected electrical cables from the machinery/equipment/project trailers. Wisconsin Public Service Corporation (WPSC) discormected and removed electrical lines, transformers, security lights and power poles from the site. SES shut off the water supplied by the city of De Pere and removed the metering equipment.

2.2.2 Water Quality Management

Prior to decontamination activities on the dewatering pad, water accumulating on the pad during precipitation events was allowed to be discharged directly to the river (as approved by A/OT). Water was directly discharged to the river on July 25, 2008. The water was pumped from the sump in the lowest portion of the pad (NE comer sump) and filtered through a silt fence prior to discharge to the river.

Once decontamination activities began on the pad, all water accumulating on the pad due to decontamination of equipment and precipitation events was required to be treated before being discharged to the river. Using a pump and a 4-inch hose, water was pumped out of the NE comer sump into a mi.x tank. At times, up to three mix tanks were utilized for storage depending on the quantity of water requiring treatment. From the mix tank, water was pumped through one sand filter vessel and one GAC filter vessel prior to being discharged to the existing rip rap drainage swale outfall located south of the dewatering pad.

Dming each discharge event, samples were collected for the same effluent parameters analyzed during the 2007 :remedial action (with the exception of low-level mercury). The samples ^vere collected on a time and flow-proportional basis. During a given sampling event, an approximate one-liter grab sample was typically collected every 10 to 20 minutes depending on the quantity of water stored in the

Suminar> Report 2f'07-2008 17 January 12,2009 lowtr Fci,x Ri^er — Phase 1 Remedial Action


:anks, the length of time expected for discharging and the flow rate of the discharge. If the flow rate ;hanged during the sampling event, the time between samples was adjusted accordingly. Each grab sample was placed on ice for preservation during the sampling event. After discharging was complete, the individual grab samples were poured into a single plastic jug (10-liter jug used in the ISCO sampler during the 2007 remedial action), homogenized and transferred into appropriate laboratory supplied sample bottles for total suspended solids (TSS), PCB, ammonia, power of hydrogen (pH), and niochem cal oxygen demand (BOD) analyses. The samples were placed in a coolt r containing ice and lei i\ creel to Pace Analytical Services, Inc. (Pace), a state of Wisconsin certified laboratory, for malysis. The results of the effluent samples are summarized below in Table 2-2.

Table 2-2. Surface Water and Effluent Sampling Results During 2008 Demobilization

Sample Date (Discharge

Date) Sample ID

Pjrformance Standards

1 '7''20()8

i 25/2008 1

6 3(1/20(18

7'2''2008 I

7'2'2008

7'3'2008

7'8'2008

7'9'200 8

- 14/2008

7 16/2008

: 16/2008 ' r'/20()8

' 2:'./20()8

•; 2;;/20()8

4-RA-08-Phase 1-EF-170

4-R A-08-Phase 1 -Demob-EF-01

4-RA-08-Phase 1 -Demob-EF-02 4-RA-08-Phase 1 -Demob-PW-02

4-RA-08-Phase 1 -Demob-TW-01

4-R,A-08-Phase 1 -Demob-EF-03

4-R A-08-Phase 1 -Demob-EF-04




4-RA-08-Phase 1 -Demob-EF-07-Dup




Total PCBs

<0.5 Hg/L <0.24

<0.23

<0.23 <0.23

0.39"' <0.23

<0.29

<0.23

<0.23

<0.26

<0.26

<0.23

<0.23

<0.23

BOD (inert.)

No Limit

<2.0

4.8

3.0

8.6

16.6

4.8

<2.0

3.5

2.5

2.0

2.0 <2.0

<2.0

<2.0

pH

6-9 7.1

6.5

6.8 7.7

7.4

7.1 6.7

6.8 7.0

7.0

7.0 6.9

6.9

6.9

-mdmm

5 mg/L/10 mg/L'" 25

6.9 10.2

38.2

31.3

9.8

1.5 0.94"'

1.2

2.5

2.3 4.3

0.9'"

0.8"'

\ .Anuawiia

imJU

150 mg/L*"

<0.5

18.7

5.4

0.92

1.3 6.1

2.5

1.2

1.3

1.1

1.1 1.3

2.1

1.6

^fote5..•

; I) For rS5. the performance standards are 5 mg/L monthly average and 10 mg/L daily maximum. (2) For ammonia, the performance standard is 24.28 mg/L, which is equivalent to 150 mg/L at the point of discharge. ;.i) Analyt cal result flagged with "J" in lab report meaning the value is estimated above the adjusted method detection limit

and be ow the adjusted reporting limit. Prepared by: TMKl Checked by: DJM4

t\i seen abcve in Table 2-2, on July 2, 2008, grab samples of the water on the dewatering pad (4-RA-O^Phase 1-Demob-PW-02) and of the water in mix tanks 2 and 3 (4-RA-08-Phasel-Demob-TW-0 1) we-e collected in order to determine whether or not decontamination water (specifically that stored in the; mix tanks) needed to be treated or could be discharged directly to the river. Based on tilcse lesult;;, the A/OT determined that all water, including that accumulating due to precipitation events, v/ould require treatment prior to discharging to the river.

\ i times during discharging events, the sand filter vessel required backwashing. The water from the mix tank was redirected up through the sand filter media and allowed to discharge back onto the pad vk'here it would then be pumped back into a mix tank or pumped directly through the filters for treatment prior to discharging to the river.

Sunimi-v Re;)on ;:007-:008 I ov er r \ River — Phase 1 Remedial Action

January 12.2009


\ s part of water quality management, the silt fence along the east side of the site v/as continuously iiaintain' d and restored during demobilization activities. Based on A/OT and Foth inspections and iJcomjTiendations, repairs and additions to erosion control measures were made including installing hay 3ales along the former dock area and a rip rap drainage swale outfall. In addition, based on direction from the WDNR, equipment stored within the rip rap drainage swale at the south end of the site was removed to allow for free drainage of water within the swale.

:2.2.3 Asphalt Removal/Recycling

Ih: dcwatciing and processing area consisted of approximately 1.5 acres of 2 to 4-inches of asphalt Mvcrly ng approximately 8-inches of gravel and a system of geosynthetic liners consisting of a 40 millimeter (mil) high density polyethylene (HDPE) flexible liner between two layers of 10-oz. non-'.\ovcri g<:otextile. On July 28 and 29, 2008, an estimated 1,600 tons of asphalt was removed and iiansported offsite for recycling.

J'rior to removal, the asphalt pad was decontaminated using methods including hand-s'veeping/scraping, sweeping with a rotary broom, hosing with water and pressure washing using metered municipal water. Areas where the asphalt pad had been penetrated, including sump locations, 'vere ?>ccavated to depths of 6-inches into the underlying gravel. The excavated material was placed into roll-off dumpsters and delivered to the Veolia Landfill.

llluring demobilization and decontamination activities on July 17, 2008, four composite samples of the asphalt pad 'vere collected by SES at locations shown on Figure 2-1. The following sampling procedure was used by SES's persormel:

1. Cut 12-inch x 12-inch square in asphah. 2. Chipped top and side of asphalt square (composite). 3. Placed asphalt chips in 16 oz. glass sample jars. 4. Pressure-washed sampling equipment using city water prior to collecting next sample. 5. P.epaced asphalt piece back into hole cut at each location.

The samples were analyzed for PCBs. The results are included in Table 2-3 below. Based on these It sult.s. tie asphalt pad was approved for recycling by the WDNR.

Table 2-3. Asphalt Pad Sample Results

Sample ID

SPl-A

SP2-A

SP3-A

SP4-A

PCB Result Cppm)

<0.394

<0.376

<0.485

<0.481


Fv'IcKecfr/ was sub-contracted by SES to perform the asphalt removal and transportation. On July 28, rOOS, using a tracked backhoe, McKeefry began removing asphalt at the south end of the dewatering pad. Asphalt was progressively removed from the pad from south to north and then removed from the < ast and west perimeter roads. Pieces of asphalt missed by the backhoe were pushed to the north t(iv\ards tne backhoe and stockpiled using a bulldozer. Asphalt removal was completed at the bottom

Miminaiy Kepiirt 2(i07-20O8 1 tiwir F(i:( Ri\cr - Phase 1 Remedial Action

January 12,2009


of the ramp of the access road on July 29, 2008. The asphalt was placed into dump trucks and transported to the Northeast Asphalt's Green Bay plant (1475 Atkins Drive) for recycling (incorporation into their asphalt mix). The asphalt on the ramp down to the site was later removed by Hydroseed of Wisconsin (Hydroseed), on September 15, 2008 and transported to the Northeast Asphalt's Green Bay plant for recycling.

2.2.4 Gravel (Crushed Stone) Removal

As described above, the dewatering and processing area consisted of approximately 1.5 acres of 2 to 4-inches of asphah overlying approximately 8-inches of gravel and a system of geosynthetic liners consisting of a 40 mil HDPE flexible liner between two layers of 10-oz. non-woven geotextile. The majority of an estimated 2,150 tons of gravel was transported off-site for beneficial re-use fi^om July 30, 2008 through August 6, 2008.

During demobilization and decontamination activities on July 17, 2008, four grab samples of the gravel underlying the asphalt pad were collected by SES at locations shown on Figure 2-1. The following sampling procedure was used by SES's personnel:

1. Cut 12-inch x 12-inch square in asphalt and collected asphalt sample, as described in Section 2.2.3 above.

2. Using a stainless steel spoon, sampled gravel under asphalt to a depth of approximately 6-8-inches.

3. Placed gravel sample (grab) in 16 oz. glass sample jars. 4. Spoon was pressure washed using city water prior to collecting next sample. 5. Replaced asphalt piece back into hole cut at each location.

The samples were analyzed for PCBs. The results are included in Table 2-4 below. Based on these results, the gravel was approved for recycling.

Table 2-4. Gravel Pad Sample Results

^^m^mW ' SPl SP2

SP3 SP4

: ' f<Mmm^)^f^^^] <0.446

<0.434

<0.432

<0.478


McKeefry was sub-contracted to perform the gravel removal and transportation. On July 30, 2008, using a backhoe equipped with a smooth-edge bucket, McKeefry began removing gravel at the south end of the dewatering pad, carefiilly scraping the gravel off the system of synthefic liners below. Gravel was progressively removed from the pad from south to north (ending at the north end of the former location of SES's trailers). The gravel was placed into dump trucks and transported to one of two locations: Veolia Landfill, if a significant amount of liner materials was incorporated in the gravel or the gravel contained known contamination; or Shell Property, Green Bay, Wisconsin (for beneficial reuse on Lower Fox River Phase 2 dredging project land-based facilities), if the gravel was free of any liner or known contamination. Gravel removal up to the asphalt ramp was completed on August 6, 2008. On September 15, 2008, the remainder of the gravel under the asphalt ramp was graded into the berm at the north end of the project site.


20 January 12,2009


It should be noted that during refueling procedures by McKeefry (on July 29, 2008), a small area of gravel was contaminated by diesel fuel spillage (approximately 1.5 cy). The contaminated gravel was ic;moved (approximately one backhoe bucket-load) and placed in a dump truck for disposal in the \eolia Landfill. During the excavation of the stone fill material to adequately remediate the impacted stone, approximately 5 additional yards of stone material was excavated and loaded into a dump truck for disposal in the Veolia Landfill.

2,2.5 Synthetic Liner Removal

As described above, the processing and staging area consisted of approximately 1.5 acres of 2 to 4-inches of asphalt overlying approximately 8-inches of gravel and a system of geosynthetic liners consisting o :"a 40 mil HDPE flexible liner between two layers of 10-oz. non-woven geotextile. The location of the liner is shown in Figure 2-2. The system of liners was removed duiing the removal of Ihe gravel beginning on July 30, 2008 and completed on August 6, 2008.

In general, following the gravel removal, SES used a backhoe to remove the liner materials and place them into McKeefiy dump trucks for disposal at the Veolia Landfill. Care was taken not to disturb the stone fill material below the liner. Following the removal of the liner on the dewatering pad, the liner materials in the anchor trench were removed by SES, and the perimeter berm/roadway was re-graded to a stable slope.

Summary Report 2007-2008 21 January 12,2009 1 ower Fox Ri\er — Phase 1 Remedial Action


3 SITE RESTORATION

In general, site restoration activities involved restoring all disturbed areas to their original condition, which included clearing and grubbing, re-grading, topsoiling, seeding, and wetland development.

3.1 Stone Fill Characterization

As part of the site restoration plan, SES proposed to re-grade and reuse the stone fill placed across the :ii:e upon the natural sub-grade and below the dewatering pad synthetic liner during site preparation activities. In order to evaluate potential PCB and/or polynuclear aromatic hydrocarbons (PAH) impacts due to remediation activities which occurred on the site during 2007 and 2008, Foth personnel collected samples at pre-determined locations based upon the operations conducted on the asphalt pad (e.g. near pad /liner sumps).

Nineteen stone fill material samples were collected by Foth personnel, on August 1, 2008, from within ihe foot]5ririt of the former asphalt contairunent pad, around the access drives, around the former fuel storage area, and from the former lay-down area on the south side of the site. The samples were collecteii at the stone fill material interface with the synthetic liner to a depth of approximately iS-inches.. Slamples were analyzed for PCB (8082) and PAH (8270C SIM). Samples from two of the 19 sample locations near the former fuel storage area (SF-18 and SF-19) were also tested for volatile organic compounds (VOCs).

The sarrpk locations are identified on Figure 3-1. The sample locations were staked using survey grade global positioning system (GPS) for mapping and fiiture reference.

The sarrples were collected by digging with a stainless steel spoon to a depth of up to 6-inches below Ihs expc'Sed surface. The collected material was placed into a stainless steel bowl and homogenized before filling appropriate sized laboratory-supplied containers. The collected samples were placed in a. ccoler with ice for submittal to Pace. For quality control and assurance, one duplicate sample was ccllecteii pt r 10 samples analyzed.

Ajialvtical -esults of the stone fill sampling are included in Table 2, of Appendix A.

Based o i the analytical results of the stone fill samples, locations were selected for removal and landfill dispersal of some of the stone fill. Table 3-1 summarizes the excavated locations and extents:

Table 3-1. Stone Fill Sample Locations

Samfile Lo<»tJon

SF-::

SF-6'^

SF-9*

SF-12

5F-1''*

SF-18 & 19*

Descriptioii of ExcavatiffiB


10' x 10' area centered on the sample location, -4-6" deep


8' wide N-S centered on the sample location by 25' long E-W, -4-6" deep

15' wide E-W centered on the sample location by 79' long N-S, -4-6" deep

15' wide N-S centered on the sample locations by 25' long E-W, -4-6" deep

L Itiiiiately e<ca\aled to subgrade. Prepared by: TMKl Checked by: \VRV

Sutnmar; Report 2007-2008 22 January 12,2009 I..0WC1 Fox Fiver ~ Phase I Remedial Action


The excavated material was placed into a dump truck and transported to the Veolia Landfill for disposal.

Following the excavations on August 8 and 11, 2008, Foth personnel re-sampled at the seven sample locations lis:ed above. The same procedures as discussed above for the previous sampling event were followed, however, the samples were analyzed for PCBs only. During re-sampling of SF-6, natural material was encountered approximately 2-inches below the excavated grade. Therefore, remaining stone fill wiihin the excavation at sampling location SF-6 was removed to natural grade and disposed of, and the re-sampled material was not analyzed. The results for the re-sampled locations are included in Table 2, cf Appendix A. Based on the PCB results fi"om the re-sampling event, the stone encountered at the bottom of excavation at SF-2 was found to be below detection lor PCBs. The other locaUons were found to contain trace levels of PCBs (less than 0.5 ppm except for SF-17-RS at 16.2 ppm).

Fuilher excavating and re-sampling was completed on August 15, 2008 for the remaining areas. The areas described above for SF-9, SF-17, SF-18, and SF-19 were excavated to natural grade. Another 4 to 6-mches of stone fill was excavated fi-om the area described above for SF-12, and re-sampling was performed for PCB analysis. The result for the re-sampled SF-12 location was found to be below the detection limit for PCBs and is included in Table 2, of Appendix A. The results of the fill sampling and testing indicate that PCB-impacted stone fill material beneath the lining system was efficiently excavated and landfilled.

The subgrade below the stone fill was subsequently sampled and tested as described in Section 3.5.

3.2 Clearing and Grubbing

Clearing and grubbing was performed by SES in designated areas along the west slope of the site in which stcne fill (relocated fi-om the flood plain) and 30-ft wide sections of geotextile were placed to enhance erosion control. These areas are shown in Figure 3-2.

Prior to clearing and grubbing, Foth personnel surveyed and staked the comers of the areas. SES icmoved the majority of the vegetative cover and, using a small bulldozer, smoothed out areas in which the geotextile would be placed. Areas on either side of the geotextile where stone fill was placed were also cleared of smaller and mid-sized standing and larger fallen vegetation. Per the request of the (Dwner's Representative for U.S. Mills, larger standing trees were left in place to provide visual screening for the milk

The rerncved vegetative cover was placed into McKeefiy dump trucks and hauled off-site to the McKeefi / yard.

3.3 Re-Grading

The floodplain elevation in the area of Phase 1 is -1-585 NGVD as depicted on Figure 3-2. During the initial site preparation activities in 2006-2007, approximately 9,300 (cubic yards) cy of stone fill were I)laced on the site to allow construction of a liner/base course/asphalt dewatering pad as shown on Figure 3-3. The isopach contours on Figure 3-3 depict the approximate thickness of stone fill jilacement. .\s previously described, the liner/base course/asphalt pad materials were removed and a])propriately recycled and/or disposed of.

Summary Rep^jrt 21)07-2008 23 January 12,2009 [.iwer Fox Ri"er - - Phase 1 Remedial Action


It should also be noted that three temporary groundwater monitoring wells located in the east perimeter road were properly abandoned on August 6, 2008.

Between August 11, 2008 and August 27, 2008, SES removed approximately 9,300 cy of stone fill material and re-graded the underlying area located within the 100 year flood plain elevation of the Fox River in order to re-establish pre-project grades. A tracked backhoe, bulldozer and front-end loader were utilized to excavate, relocate, place and grade the stone fill along the west slope of the site in designated areas to provide slope stabilization and erosion control as shown in Figure 3-2. The stone fill was excavated fi^om the flood plain and stockpiled using the backhoe, leaving residual stone material on the nafive soil over the majority of the site. A front-end loader transported the stockpiled stone fill to the required fill areas, while a bulldozer was utilized to grade the stone fill to the required grades. The designate fill areas were graded to an approximate 3:1 slope; the toe to an approximate 10% slope. The re-graded design allows for sheet flow of surface water to occur across the site, which is expected to bring the site to the same general flow patterns that existed prior to the project.

After excavation to the 585 ft elevation was complete, using a bulldozer and backhoe, SES removed the residual stone material in order to expose the pre-existing native soil. The native soil (in areas not receiving topsoil) was then disced in preparation to receive the selected seed mix.

Because the site restoration plan required the addition of stone material along the west slope of the site, the existing city of De Pere sanitary manholes (see Figure 3-2) located on-site were raised to accommodate the proposed elevations. The city of De Pere contracted with De Groot Construction (De Groot) to perform the work. On August 18, 2008, De Groot raised three sanitary manholes on the site by adding concrete risers to the existing manholes. On August 28, 2008, De Groot returned to the site to raise the manhole towards the south end of the site, near the 10-inch diameter roof drain/condensate pipe in the west slope, another 4-feet to the plaimed elevation.

On September 3, 2008, McKeefry began re-grading the stockpiled sand, located on the south end of the site, moving it to the west and south outside of the floodplain as shown in Figure 3-2. On September 4, 2008, an approximate 3-ft berm was placed around the toe of the sand stockpile (east and north sides) using some of the excavated stone fill to contain potential sand erosion during rain events (see Figure 3-2). On September 5, 2008, the sand stockpile was re-graded after the previous evening's rain event had caused sand to wash out along the north slope. In addition, the stone fill at the top of the stockpile was re-graded to direct water from the U.S. Mills parking lot towards the stone fill and geotextile-lined slope to the north rather than down the sand stockpile.

On September 10, 2008, the site restoration subcontractor, Hydroseed, mobilized to the site. From September 10, 2008 through 25, 2008, Hydroseed completed the following acfivities associated with site restoradon: necessary placement and re-grading of stone fill on slopes; residual stone removal within the flood plain; completion of the wetland berm constmction; rip rap dam construcfion northwest of the constructed wetland; removal of the stone fill and grading of the underlying material on the access ramp; re-grading the former perimeter roadway and leveling excess stone fill around the silt fence. Final re-grading of the sand stockpile to enhance slope stability was completed on September 20, 2008, by Hydroseed.

3.4 Re-Grading Documentation

During re-grading activities by SES and subsequent subcontractors, Foth survey persoimel performed a series of surveys and grade reviews. Table 3-2 summarizes the surveys/reviews performed:

Summary Report 2007-2008 24 January 12,2009 Lower Fox River — Phase I Remedial Action

Section 3 Site Restorat icn

Table 3-2. Survey Schedule

I>ate

August 11,2008

August 15,2008 August 18,2008 August 20, 2008 August 25, 2008

August 26. 2008 (noon)

Aug ast 27, 2008 September 4, 2008

September 11, 2008 September 19,2008 September 24. 2008 Septembt:r 25. 2008

October 3, 2008

Surv^ Event

Staked comers of designated fill areas along the west slope and 585' flood plain elevation Staked break lines on west slope Staked toe of west slope and re-staked 585' flood plain elevation Re-staked break point locafions and elevations for fill areas Re-staked break point locations in fill areas #1 & #3 (topographic survey). Staked comers of wetland Topographic survey of most of the site (Review of site grades requested by SES, on August 25, 2008, p.m.) Re-staked 585' flood plain elevation at the south end of the site Re-staked 585' flood plain elevation around the sand stockpile and took as-built shots of the wetland berm Topographic survey of the site Final re-staking of pre-project 585' flood plain elevation Verify wetland berm elevation (east and south berms) Verified wetland berm elevation (north berm) As-buih site topography


:;.5 Subgrade Characterization

In order to e 'aluate potential PCB and/or PAH impacts to the preconstmction subgrade due to tcmediation activifies during 2007 and 2008, Foth persoimel collected samples of the subgrade material from within the footprint of the former asphalt containment pad. Seventeen sub-grade samples were collected by Foth personnel on August 28, 2008 in the same general locafions and depths and in the jame maimer as the September 7, 2006 pre-constmction soil sampling event by Shaw. Shaw originally sampled 19 locations; however, two of the locations (18.1 and 19.2) were covered with approximately -•••feet of :>tone fill and could not be re-sampled or legitimately relocated.

.'hv. sample locations are shown on Figure 3-4. The sample locations were staked using survey grade (JPS for rnapiping and fttmre reference.

Tie samples were collected by digging with a stainless steel spoon to a depth of up to 6-inches from the exposed surface. Each sample was placed into the appropriate sized laboratory-supplied container, which was then placed in a cooler with ice for submittal to Pace. The samples were submitted for Eiialysis cif PCB (8082) and PAH (8270C SIM) compounds. For quality control and assurance, one duplicnte sample was collected per 10 samples analyzed. Analyfical results and methods for the subgrade characterization sampling are included in Table 2, of Appendix A. A comparison table of the pre-const Taction and post constmction sample results is found in Table 3, of Appendix A.

It ma>' be coicluded with a high level of statistical certainty from an analysis of the total PCB results, the mean 2008 concentration did not significantly increase from site activities. In essence, the tme (unknown) mean of the 2008 total PCB results is not significantly greater than the i:me (unknown) mean of tlie 2006 total PCB resuhs. In fact, the 2008 sample average concentration is 2,244 ng/Kg and the 2006 lianiple average concentration is 3,011 |xg/Kg. The data is presented in the Table 4, of ,'Sp]5endix A.

Sii unary F.cpdrt :C07-2l)08 l.f ivcr Fcj. River - Phase 1 Remedial Action

25 January 12.2009


A statistical paired t-Test of the hypothesis HQ: ^2008'^'^1^2006 ^ - ^a- M2008' l 2006 indicated that we could not reject HQ in favor of H^ with 95% confidence, that is, we cannot conclude the tme mean concentration of the 2008 data exceeds the tme mean concentration of the 2006 data. In addition, with the observed sample averages of 2,244 |ig/Kg for 2008 and 3,011 ng/Kg for 2006, the probability of reaching this conclusion in error (Type 11 error) is less than 0.20. That means there is less than a 20% chance that, given this data, the tme mean concentration following site activifies increased.

3.6 Topsoil Placement, Discing

On September 10, 2008, seeding preparation of the site began with the placement of topsoil within the newly constmcted wetland area. From September 12, 2008 through September 25, 2008, top-soil was placed on the remaining areas as identified on Figure 3-2.

Upon completion of the topsoil placement and site grading, these areas were fertilized and hydroseeded with the seed mixmres identified in the Site Restoration Plan. The wetland was seeded with the specified wetland mix. The sand stockpile was raked, fertilized, and hydroseeded with a perennial rye and oat seed mixture. The former access road area was seeded with a mrf seed mix to blend into the exisfing turf grass on the adjacent U.S. Mills property. From September 17, 2008 through September 25, 2008, the nafive soil material within the flood plain was disked, raked, fertilized, and hydroseeded with the specified riparian forest mix. All Hydroseed seed mixes included a mat blend mulch along with PAM 12, a soil polymer. Topsoiling, discing, and seeding work was performed by Hydroseed.

3.7 Wetland Development

From September 3, 2008 through September 25, 2008, an approximate 0.25-acre wetland was constmcted on the site by McKeefry and Hydroseed during restoration activities to mitigate wetland impacts from site remediation activities. Portions of the wetland are located within the floodplain, as shown on Figure 3-2. McKeefry began the constmction of the berm surrounding the wetland area (approximately 1-1.5 ft high), on September 3, 2008, using excavated stone fill.

On September 4, 2008, two loads of rip rap were tmcked in by McKeefry for placement along the west side of the wetland for constmction of the energy dissipater and to the south of the wetland for constmcfion of the rip rap drainage channel as shown in Figure 3-5. The rip rap and underlying 10-oz. geotextile were placed on September 5, 2008. The energy dissipater was constmcted approximately 30 ft long by 10 ft wide by 6-inches thick. The rip rap drainage channel was constmcted from the south berm of the wefland and tied into the existing drainage swale outfall.

On September 4 and 5, 2008, McKeefry extended the exisfing 10-inch roof/condensate drain from the outfall in the west slope (near the south end of the site) to the rip rap energy dissipater.located just west of the wetland, as shown in Figure 3-5. The pipe was then backfilled with stone fill material. The storm drain routes water from the roof of the U.S. Mills plant to the wetland through the energy dissipater for use as a source of water for the wetland. In addition to the rainfall related flow from the roof of the plant, condensate from air conditioners located on the plant roof will provide a trickling of water throughout the year to the wetland.

On September 10 and 11, 2008, Hydroseed placed approximately 4-inches of topsoil on the wetland berm, inner berm included. Following the placement of topsoil, the wetland was seeded with the seed mix specified in the Site Restoradon Plan. Hydroseed also completed the necessary grading of the



wetland area including final wetland berm constmction and rip rap check dam constmction north of the condensate pipe outfall. Wetland constmction activities were completed on September 25, 2008.

3.8 Post Constmction Monitoring

During the demobilization and restoration activities on-site, per the recommendation of the WDNR, in\ asive species, including purple loosestrife and phragmites, were managed by SES and the Resident Engineer. These invasive species were removed/sprayed for eradification along the west slope near the southwest cijraer of the former observation deck and along the shoreline of the site. Further monitoring and management of invasive species will be performed under the Post Constmction Stormwater Operation and Maintenance Plan included in Appendix B.

Summao'Report 2(107-2008 27 January 12, 2009 t ower Fo.x Ri\er — Phase 1 Remedial Action

Section 4 References

4. REFERENCES

Shaw and Anchor, 2004. Lower Fox River Operable Units 2 - 5 Pre-Design Sampling Plan. Prepared for Fort James Operating Company, Inc. and NCR Corporation by Shaw Environmental and Infrastmcture, Inc. and Anchor Environmental, LLC. June 7, 2004.

USEPA and WDNR, 2007. Record of Decision Amendment: Operable Unit 2 (Deposit DD), Operable Unit 3, Operable Unit 4, and Operable Unit 5 (River Mouth). Lower Fox River and Green Bay Superfund Site. June 2007.

USEPA 2006. Consent Decree for Performance of Phase 1 of the Remedial Action in Operable Units 2 - 5 of the Lower Fox River and Green Bay Site. March 2006.

Shaw and Anchor, 2006. Phase 1 Construction Quality A.ssurance Project Plan. Prepared for NCR Corporafion and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, and Foth Infrastmcture and Environment, LLC. July 24, 2006.

Shaw and Anchor, 2007. Lower Fox River Phase 1 Remedial Action - Remedial Action Plan. Prepared for NCR Corporafion and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, and Foth Infrastmcture and Environment, LLC. April 2007.

Shaw et al., 2007a. Optional SAP Addendum for Phase 1 Verification of Project Completion. Prepared for NCR Corporation and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, and Foth Infrastmcture and Environment, LLC. July 16,2007.

Shaw et al., 2007b. Lower Fox River Operable Units 2 to 5; Remedial Design Sampling Plan Addendum for Phase 1 Remedial Action (Final). Prepared for NCR Corporafion and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, Foth Infrastmcmre and Environment, LLC, and Sevenson Environmental Services, Inc. October 1,2007.

Shaw et al., 2008. Lower Fox River Phase 1 2007 Remedial Action Draft Summary Report. Prepared for NCR Corporafion and U.S. Paper Mills Corporation by Shaw Environmental and Infrastmcture, Inc., Anchor Environmental, LLC, and Foth Infrastmcture and Environment, LLC. Febmary 2008.

Summary Report 2007-2008 28 January 12, 2009 Lower Fox River — Phase I Remedial Action

FIGURES

S iinriary Pepcn :007-2()08 January 12. 2009 l..'A'crFo> Ri\'er - Phase 1 Remedial Action

ProcramtoagBr-MkeCrys'a

Sur/sys-FclhiVanDyiif

This drawing is neHtier a )egaii)r recorded map not a survey and is no) intended lo be used as one This drawing is a compilation of records, ^formation and data used for releretKe purposes onty

#F6th W jJOftnOO t •nmwf fww I _ Chirt 11 ¥t T m

NCR/US PAPER MILLS INC

FIGURE 1-2

PHASE 1 - ORGANIZATIONAL CHART

Scale: NOT TO SCALE Dale: JANUARY 8, 2009

Drawn By: DAT Checked By: MRO Scope: OeNOOS

2.471.250 E

LEGEND

A S P 2 SP2 = GRAVEL SAMPLE ^ 3 P 2 - . ' . SP2-A = ASPHALT SAMPLE

SITE LIMITS

NOTE:

1. SAMPLES COLLECTED AND LOCATIONS PROVIDED BY SES.

0 *(y BO'

#Foth FoHt tn)r«(itraeinrD ft Snvhonnwnt, LIX

NCR/US PAPER MILLS INC.

FIGURE 2-1 PHASE 1 - SITE DECONSTRUCTION

ASPHALT & GRAVEL SAMPLE LOCATIONS

Dote: NOVEMBER. 2008 Revision Ootet

Prepored By: JOW ChackecJ Byi *H1 08N009

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