Transportation and Consolidation Plan Final

Final Transportation and Consolidation Plan Non-Public Properties

Newhall Street Neighborhood Site

Hamden, Connecticut

Revision 0

Prepared for:

Olin Corporation Cleveland, Tennessee

Prepared by:

Sevenson Environmental Services

Niagara Falls, New York

August 2009

TRANSPORTATION AND CONSOLIDATION PLAN NON-PUBLIC PROPERTIES, NEWHALL STREET NEIGHBORHOOD

HAMDEN, CONNECTICUT

TABLE OF CONTENTS

August 2009 i

Section Page

1. INTRODUCTION ................................................................................................................................. 1-1

2. MATERIAL AND WASTE SOURCES AND CLASSIFICATIONS ............................................... 2-1 2.1 SOURCES OF MATERIALS AND WASTES ................................................................................ 2-1 2.2 MATERIAL AND WASTE CLASSIFICATIONS ......................................................................... 2-1

2.2.1 RCRA HAZARDOUS MATERIALS AND WASTE ..................................................... 2-2 2.2.2 OTHER MATERIALS AND WASTES .......................................................................... 2-2

3. REGULATORY REQUIREMENTS ................................................................................................... 3-1 3.1 SOIL MATERIALS AND DEBRIS WASTE .................................................................................. 3-2 3.2 OTHER MATERIALS AND WASTES .......................................................................................... 3-3

4. MATERIAL AND WASTE MANAGEMENT PROCEDURES ....................................................... 4-1 4.1 GENERAL ....................................................................................................................................... 4-1 4.2 MATERIAL AND WASTE HANDLING PRECAUTIONARY MEASURES .............................. 4-1 4.3 PRE-EXCAVATION AND/OR STOCKPILE SCREENING ......................................................... 4-2 4.4 MATERIAL AND WASTE HANDLING, STAGING, AND STORAGE ..................................... 4-2 4.5 MATERIAL AND WASTE SAMPLING AND ANALYSIS ......................................................... 4-5 4.6 MATERIAL AND WASTE PACKAGING ..................................................................................... 4-5 4.7 MATERIAL AND WASTE LABELING AND DATING .............................................................. 4-5 4.8 MATERIAL AND WASTE TRANSPORTATION AND DISPOSAL ........................................... 4-5

4.8.1 RCRA HAZARDOUS MATERIALS .............................................................................. 4-6 4.8.2 NON-HAZARDOUS MATERIALS (NOT ACCEPTABLE FOR REUSE) ................... 4-6 4.8.3 OTHER MATERIAL AND WASTES ............................................................................ 4-6

5. NOTIFICATIONS, DOCUMENTATION, AND REPORTING ...................................................... 5-1 5.1 NOTIFICATIONS ............................................................................................................................ 5-1 5.2 DOCUMENTATION PROCEDURES ............................................................................................ 5-1

5.2.1 DOCUMENTATION OF FIELD ACTIVITIES ............................................................. 5-2 5.2.2 DOCUMENTATION DURING TRANSPORTATION AND DISPOSAL .................... 5-2

5.3 SPILL RESPONSE CONTINGENCY PLAN ................................................................................. 5-3


HAMDEN, CONNECTICUT

LIST OF TABLES AND FIGURES

August 2009 ii

Table 4-1 Waste Management Disposal Options Matrix Figure 1 Site Map


HAMDEN, CONNECTICUT

LIST OF APPENDICES

August 2009 iii

Appendix A Tire Pond Site Materials Management Plan B Transportation Routes C Material and Waste Disposal Tracking Log D Facility Acceptance Letters


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LIST OF ACRONYMS

August 2009 iv

List of Acronyms BOL ................... Bill of Lading CTDEP ............... Connecticut Department of Environmental Protection CFR .................... Code of Federal Regulations IDW ................... Investigation Derived Waste LDRs .................. Land Disposal Restrictions PPE .................... Personal Protective Equipment ppm .................... parts per million POTW ................ Publically-Owned Treatment Works RCRA ................ Resource Conservation and Recovery Act SAP .................... Sampling and Analysis Plan TCP .................... Transportation and Consolidation Plan TSDF ................. Transfer, Storage and Disposal Facility USDOT .............. United States Department of Transportation USEPA ............... U.S. Environmental Protection Agency WP ..................... Work Plan


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1. INTRODUCTION Olin Corporation (Olin), as one of the Responsible Parties for the Non-Public Properties of the Newhall Street Neighborhood (the Site), has entered into a Consent Order for the remediation of selected residential properties within the town of Hamden, Connecticut (Figure 1). The Site is an approximate 18 block area in the southern portion of Hamden consisting of a main cluster of properties centered by Newhall Street (designated Remedial Blocks A through S), and a smaller cluster of properties in the Auger Street area (designated Remedial Block T). The overall Site area is generally bordered by Goodrich Street to the south, Prospect Lane and Wadsworth Street to the east, St. Mary Street to the west, and Morse Street and Bryden Terrace to the north. Block T is located off Newhall Street approximately 800 feet northwest of the main cluster.

The Site was historically a wetland and low-lying area prior to the placement of industrial waste and household trash from the late 1800’s to the mid-1900’s. Homes, public buildings, and parks were built on and adjacent to the waste disposal areas. Previous Site investigations have identified the former fill as including: batteries, empty ammunition shells, ash slag, coal waste, and industrial and household waste. It is anticipated that these materials, as well as the contaminated soils associated with them, will be removed to a depth not to exceed 4 feet as part of the remedial action.

The Remedial Contractor will coordinate and manage all aspects of the Site remediation of Site Blocks A through T. Work conducted at the Site will proceed in Phases by designated Property Blocks. The first Phase of properties anticipated to be remediated will be Blocks N, R, S, H and J in the spring/summer of 2009. Subsequent Phases will be managed on an ongoing basis, and as necessary, all Site Plans, including this TCP, will be updated and amended.

The remedial activities to be performed at the Site may result in the generation of various types of excavated materials and remediation wastes. Contaminants at the Site which may be present in these wastes include the heavy metals lead and arsenic. This TCP identifies the procedures and guidelines that will govern material and waste handling operations during the remedial action activities.

Specifically, this TCP describes the classifications of materials and wastes that may result from remedial activities and the regulatory requirements for management of such materials and wastes. It is anticipated that a majority of the material removed from excavations will be non-regulated waste that meets the criteria for reuse as fill material at the nearby Tire Pond Closure Site in Hamden, Connecticut. The TCP also includes the procedures to be followed during the segregation, transportation, potential reuse/offsite disposal, applicable notification, documentation, and reporting requirements associated with the material and waste management activities.


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2. MATERIAL AND WASTE SOURCES AND CLASSIFICATIONS This section describes the sources and classifications of the materials and wastes that may be generated during the remedial activities to be performed at the Site.

2.1 SOURCES OF MATERIALS AND WASTES

Implementation of the remedial action activities at the Site will result in the generation of materials and wastes which will require appropriate on-site and off-site management. These materials and wastes will be generated during the excavation of pre-determined portions of residential properties from designated areas of the Site, as well as during the execution of associated support operations (i.e., equipment decontamination, sampling, etc.). The anticipated materials and wastes to be generated from the implementation of the remedial action activities include, but are not limited to:

Source Potential Materials and Wastes

Contaminated Soil and Waste - Excavation and removal activities associated with remedial activities

• Soil and debris wastes from within the footprint areas • Construction debris (both contaminated and non-contaminated) • Water from excavation areas and surface run-off • Clearing & grubbing debris (i.e. vegetation) • Spent PPE, debris, disposable equipment and sampling debris

Decontamination Activities • Potentially contaminated sediments and residues

• Decontamination waters • Spent personal protective equipment (PPE), debris, and

disposable equipment

Other • Common trash and garbage (non-contaminated) • Sanitary Wastewater • Used Oil (from filters, equipment maintenance) • Asbestos • Antifreeze

2.2 MATERIAL AND WASTE CLASSIFICATIONS

The majority of material to be removed during the remedial action activities is anticipated to be soils and debris waste based upon previous Site investigations and sampling. Previously identified small areas of potentially hazardous material will be managed separately from general excavations at the Site. Sampling and analysis to pre-characterize the waste will be conducted. As necessary, additional sampling will be conducted to:

• Verify that material meets the requirements for reuse at the Tire Pond Closure Site as defined in the “Materials Management Plan for the Management of Designated Materials at the Tire Pond”. A copy of this document is included as Appendix A of this TCP.

• Further delineate or delimit any suspect or potential hazardous waste.

• Characterize for offsite transportation and disposal any waste that does not meet the criteria for management at the Tire Pond Site.


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All waste at the site will be sampled and analyzed per an approved site-specific Sampling and Analysis Plan (SAP), submitted under separate cover, which will be prepared and implemented by Olin’s Site Engineer.

Each of these potential material and waste classifications are discussed in detail below.

2.2.1 RCRA Hazardous Materials and Waste

Implementation of the remedial action activities at the Site may involve handling waste materials that are subject to the RCRA Hazardous Waste Regulations. A solid waste may be a RCRA hazardous waste if it is specifically listed as a RCRA Hazardous Waste, or if it exhibits any of the following characteristics of hazardous waste: ignitability, corrosivity, reactivity, and/or toxicity. The regulatory definitions for each of these characteristics are contained in 40 Code of Federal Regulations (CFR) Part 261.21 through 261.24. Any wastes identified as being either RCRA Listed or Characteristic Hazardous Wastes must be managed in accordance with all applicable RCRA hazardous waste management regulations.

It is not anticipated that any listed wastes are present at the Site. Therefore, for the purposes of this plan, discussion will be limited to RCRA Characteristic Hazardous Wastes.

Characteristic Hazardous Materials and Waste

RCRA characteristic hazardous wastes are materials that exhibit ignitability (Hazardous Waste Code D001), corrosivity (Hazardous Waste Code D002), reactivity (Hazardous Waste Code D003), and/or one or more of the toxicity characteristics (Hazardous Waste Codes D004 through D043). The hazardous waste characteristics are identified through laboratory analysis of waste materials or based on the waste generator’s knowledge of the process generating the waste. Previous investigations of the Site indicate that elevated levels may be present in limited portions of the NPP. Soils designated as RCRA hazardous will be managed separately and will be subject to additional analysis per the Site SAP. Any suspect materials encountered during the remedial action activities will be sampled for classification per the Site SAP.

2.2.2 Other Materials and Wastes

In addition to the waste classifications identified above, remedial action activities may also result in the generation of waste materials that are not classified as RCRA hazardous wastes but may contain substances requiring special management procedures including the following:

Hazardous and/or Non-Hazardous Wastewaters - Wastewaters generated during project activities may contain contaminants that must be treated or removed prior to discharge or disposal. Wastewaters will be disposed of at an offsite, permitted treatment facility or discharged to the sanitary sewer.

Construction Debris - This category includes material that has not been contaminated by or otherwise impacted by hazardous substances or wastes. Clean debris may be processed to meet the criteria for reuse at the Tire Pond Site, or may be disposed of at a licensed off-site construction debris landfill.

Trash and Rubbish - This material includes general garbage and trash that has not been impacted by hazardous substances removed from the excavation that may be deemed Municipal Solid Waste (MSW). MSW will be disposed of at a licensed off-site municipal solid waste facility. In addition, any trash and rubbish generated during Site operations will be stored on-site in appropriate containers for offsite management. This material will be transported by a licensed local municipal waste hauler.


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Asbestos - Asbestos waste may be generated during the project activities as a result of demolition. Asbestos wastes may be disposed of in a municipal landfill in accordance with the Special Waste Disposal Authorization process.

Antifreeze - This waste is a non-RCRA waste in most cases, but a RCRA hazardous waste determination should be made at least one time for verification purposes. If the antifreeze is determined to be non-hazardous it will be disposed of at an offsite permitted treatment facility.


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3. REGULATORY REQUIREMENTS Materials and wastes generated during the remedial action activities at the Site will be managed in accordance with the applicable local, State, and Federal regulations for each particular classification. In addition, all waste management activities will be performed in a manner that is protective of human health, safety, and the environment. The following sections describe the regulatory requirements for the wastes identified in Section 2 of this TCP. Transporters shall provide current proof of all appropriate permits and licenses required to transport the waste. No alternate disposal facilities may be used without prior consent by Olin Corporation.

The anticipated transporters are:

Dump Truck Transport (Non Hazardous Solids): To Be Determined (T.B.D.) US EPA ID Number: N/A Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes: per ton

Dump Truck or Roll-off Transport (Hazardous Solids): T.B.D. US EPA ID Number: Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes: per ton

Vacuum Trailer Transport (Hazardous/Non-RCRA Hazardous Liquids): T.B.D. US EPA ID Number: Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes: per load

Note that other transporters may be selected during the execution of the project.

The anticipated offsite disposal facilities are:

Facility Name (Non RCRA Hazardous Solids): Tire Pond Closure Site US EPA ID Number: N/A Facility Location: 2935 State Street, Hamden, Ct Name of Responsible Contact: T.B.D. Telephone Number: T.B.D. Unit of Measure for Costing Purposes: Not Applicable

This Site will accept materials which meet criteria for reuse as alternative fill as specified in the “Materials Management Plan for the Management of Designated Materials at the Tire Pond”. A copy of this document is included as Appendix A of this TCP. Upwards of 2,000 tons per day of material may be moved for storage prior to reuse at this site per operational day.


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Facility Name (Non-RCRA Hazardous Solids and Debris): To Be Determined (TBD) Permit Number: Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes: Per ton

Materials deemed Non-RCRA Hazardous that can not meet the requirements for reuse, or can not be processed to meet the requirements for reuse, at the Tire Pond Site will be transported for offsite disposal.

Facility Name (RCRA Hazardous Solids and Debris): TBD Permit Number: Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes:

Materials deemed RCRA Hazardous that can not be processed onsite will be transported for offsite disposal.

Facility Name (Non Hazardous Liquids): TBD US EPA ID Number: Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes: Per gallon

Sufficient 22,000 gallon temporary storage tanks will be maintained onsite to contain Site waters prior to shipment for offsite disposal. Four to five vacuum tank trucks will be scheduled on an as-needed basis to remove water as temporary storage tanks are filled.

Facility Name (Hazardous Liquids): TBD US EPA ID Number: Facility Location: Name of Responsible Contact: Telephone Number: Unit of Measure for Costing Purposes: Per gallon

Sufficient 22,000-gallon temporary storage tanks will be maintained onsite to contain Site waters prior to shipment for offsite disposal. Four to five vacuum tank trucks will be scheduled on an as-needed basis to remove water as temporary storage tanks are filled.

Note that other disposal facilities may be selected during the execution of the project.

3.1 SOIL MATERIALS AND DEBRIS WASTE

On-Site Management Requirements

Management of soil and debris waste materials involves removal of these materials from the Site. The majority of soils from within these defined Blocks have been classified through previous investigations with respect to regulatory requirements. Soil and wastes may be, as required, additionally tested in situ or removed to a storage area for analysis per the Site SAP. Wastes will be maintained at a stockpile area for subsequent loading and shipment off-site to an appropriate processing area, the Tire Pond reuse staging area or offsite disposal facility.


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All material management activities will be performed in accordance with applicable local, State, and Federal regulations for handling, labeling, and storage.

Off-Site Transportation Requirements

All waste material will be transported offsite via truck (dump trailers and/or end dump trailers or rolloffs for solids; vacuum tankers for liquids) by licensed/permitted companies. All vehicles will be inspected by The Remedial Contractor prior to loading to determine that they meet The Remedial Contractor’s company policy and DOT shipping requirements regarding minimum safety and operational requirements.

Off-Site Processing & Disposal Requirements

All waste material must be disposed of at a facility which is licensed/permitted to accept the specific materials and is approved by Olin Corporation. Soils meeting the Tire Pond Site reuse criteria will be staged at the direction of the Tire Pond Site Manager prior to placement for reuse. If necessary and practical, soils containing significant amounts of debris will be screened at a designated area of the Tire Ponds Site to meet reuse permit criteria. Large quantities of asphalt/concrete that are not amenable for reuse may be segregated for shipment to an offsite recycler. MSW, general debris or other materials not amenable to reuse at the Tire Pond Site will be staged for offsite transport and disposal at one of the designated disposal facilities listed previously.

3.2 OTHER MATERIALS AND WASTES

Disposal Options

The disposal options available for the various non-RCRA hazardous and non-regulated wastes that may be encountered during performance of the work are presented below:

• Waters - Waters from within the footprint of excavation or from well development/maintenance generated during remedial action activities at the Site will likely be disposed of offsite at a permitted Transport Storage and Disposal Facility (TSDF) and/or Publically-Owned Treatment Works (POTW). Waters may not be directly discharged to any local streams or waterways without an appropriate permit/approval from CTDEP. The Remedial Contractor shall contain, sample, and analyze water suspected to contain contamination which is encountered during site remediation prior to releasing it from the site. Water will be characterized for disposal as either RCRA-hazardous or non-hazardous based on this analysis and will be disposed of at one of the previously designated facilities.

• Trash and Rubbish - Trash and rubbish will be hauled by a local, licensed hauler to an appropriate municipal or industrial waste facility.

• Used Oil – Used oil generated from equipment maintenance at the Site will be sent for recycling at a local oil recycler.


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4. MATERIAL AND WASTE MANAGEMENT PROCEDURES This section presents the specific guidelines and procedures that will be followed for the management of material and wastes handled during the remedial action activities at the Site. These procedures are generally applicable to the management of wastes after they have been excavated/removed. Specific procedures for material and waste excavation, removal or placement onsite are presented in the Work Plan (WP), submitted under separate cover. Access to Town of Hamden property or private property shall occur only with the consent of the landowner. The procedures presented in this section are based on the project goals of minimizing threats to Site workers, human health, and the environment during all material and waste handling activities. Specific procedures and guidelines in support of the WP for handling, staging, storing, sampling, packaging, labeling, and transporting material and waste are presented in the following sections.

4.1 GENERAL

Material and waste handling activities will be performed in a manner that minimizes the threat of a release of potentially contaminated material to the environment and surrounding community, and protects worker health and safety. Care will be taken during operations and activities that will generate materials and wastes, such as excavation and dewatering, to prevent releases of material, waste, and dust to the surrounding environment. A waste management disposal options matrix is provided as Table 4-1. Dependent upon the rate of generation, it is anticipated that a combined average total of 20 loads (approximately 250 yards) may be shipped from the Site daily to either the Tire Pond Site (for reuse solids) or a designated offsite disposal facility (MSW/Hazardous solids).

4.2 MATERIAL AND WASTE HANDLING PRECAUTIONARY MEASURES

The following procedures may be implemented prior to or during remedial activities to ensure that there are no releases of material and/or waste to the environment and surrounding community, and to protect Site workers.

• Engineering controls such as water sprays may be used during activities that could potentially generate dust (i.e., excavation and loading, Tire Pond Site storage and screening) to prevent the spread of contaminants via wind dispersion.

• Plastic sheeting may be placed under and around transport vehicles while they are being loaded. Any material that falls onto the plastic sheeting during loading will be collected and placed in the vehicle.

• Site workers will wear PPE appropriate for the specific task being performed, in accordance with the Site Health and Safety Plan, submitted under separate cover. Spent PPE and contaminated disposable equipment and materials will be containerized and disposed of appropriately.

• Equipment used during construction activities in potentially contaminated areas will be properly decontaminated before moving through clean areas of the Site or leaving the Site.

• A “clean road” will be established within each Sub-Area (i.e., Blocks A through T) to allow material and waste hauling vehicles to enter and exit the individual areas of the Site without coming into contact with contaminated media. This will prevent contaminated soils and from being “tracked” onto the public roadways upon exiting each Sub-Area. The surface of hauling vehicles will be visually inspected to ensure that the vehicle is not contaminated when entering the clean road. Vehicles will undergo decontamination (dry brooming and/or water decon), as necessary.

• Haul roads and the loading area will be inspected periodically during excavation and at the end of the project day to verify that these areas have not been adversely effected during material and waste handling operations. More frequent surveying of the haul roads may be performed as


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August 2009 4-2

deemed necessary based on the schedule of activities, site conditions, and results of initial survey activities.

4.3 PRE-EXCAVATION AND/OR STOCKPILE SCREENING

Pre-excavation sampling of Sub-Area soil materials has been conducted under separate contract. Site excavation areas and waste management determinations have been established in the Contract Drawings for the Site. Excavation limits are based upon this previously conducted sampling. Additional sampling to determine the extent of excavations as they progress will be performed by Olin’s Site Engineer in accordance with the Site SAP, prepared and submitted under separate cover.

As necessary, or upon excavation of suspect material, Site soils may be segregated and stockpiled for additional analysis per the Site SAP. Additional sampling of stockpiled material may also be conducted for offsite disposal waste characterization and/or approval purposes based upon disposal facility acceptance criteria.

4.4 MATERIAL AND WASTE HANDLING, STAGING, AND STORAGE

The procedures and guidelines that will be used for handling, staging, and storage of waste materials generated during the remedial activities at the Site are presented below.

Materials transported to either the Tire Pond Site for reuse or for offsite disposal must not contain any free liquids and must pass the paint filter test. Therefore, any materials that are saturated upon excavation must be managed onsite prior to shipment offsite. Any water collected will be transferred to the on-site holding tank for reuse or, ultimately, offsite disposal.

Site soils and wastes shall be loaded into triaxle or end dump trucks by either direct loading from the excavation (for soils from pre-characterized areas or if soils have been sampled in situ) or at the Mill Rock Park stockpile. As necessary, rolloff-type boxes may be utilized to contain soils and solids prior to transport to the stockpile area(s). Trucks will be loaded with a front-end loader or excavator. Truck axle scales will be utilized to verify compliance with over-the-road weight limitations and to maximize the payload of each truck.

All trucks, excluding those dedicated to use within the exclusion zone of the excavation site(s), will remain either on the "contaminant-free" haul road within the exclusion zone or outside of the exclusion zone. Vehicles from within the exclusion zone will be decontaminated prior to release. Specific truck routes into/and out of each area in support of phased excavation activities will be developed prior to commencing site operations in any particular area.

All below-grade grubbed material (i.e. tree roots, foundations, etc.) removed during excavation that will not meet reuse criteria will be subject to a primary separation at the excavation. The excavator will shake tree root masses and scrape large concrete/asphalt debris as it is removed to dislodge clumps of soil.

This “gross” screening of excavated materials at the point of excavation in each Sub-Area is designed to remove the greatest amount of material which does not obviously meet the Tire Pond Site’s “Designated Materials” criteria for reuse as removed. This initially separated material will be transported to Mill Rock Park for stockpiling and further handling, or loaded directly into transport vehicles for offsite disposal at the approved licensed facility.

Once delivered to the Tire Pond Site staging area, the Remedial Contractor will coordinate with the Tire Pond Project Manager to further process or remove unacceptable materials prior to placement in a final stockpile area for direct reuse under the direction of the Tire Pond Project Manager. This processing may include a secondary screening of material to further remove non-reusable material, or sizing of materials.


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After secondary processing and removal of additional materials deemed “non-reusable”, materials will be again segregated into “reuse” stockpiles for materials now acceptable to the Tire Pond Project Manager and “offsite disposal” stockpiles.

In addition to Site soils and debris, all Investigation Derived Waste (IDW) and PPE, including discarded disposable sampling equipment and plastic sheeting, will be consolidated on a daily basis at the decontamination pad area at the Site. IDW/PPE will be placed in plastic bags on a daily basis prior to weekly consolidation into (55) gallon drums for storage. Once offsite transportation of waste commences, the (55) gallon drums will be emptied into loads of waste being shipped for offsite disposal.

Besides IDW and PPE generated during project activities, other components (i.e. tools, brooms, etc.), debris or refuse might be generated by contact with contaminated debris. These secondary wastes may contribute to overall handling and disposal costs. Planning, management and housekeeping practices will be employed that minimizes generation of secondary wastes. These management and housekeeping practices will include:

• Determine which tools or materials must be taken into designated contaminated areas and limit as

practical.

• Identify and maintain designated tools or materials for use in contaminated areas.

• Prevent excessive amounts of materials (i.e. bags, rags, etc.) from entering designated areas.

• Segregate and maintain contaminated materials from non-contaminated sources.

• Reuse contaminated materials within designated areas, as possible.

• Separate compactable from non-compactable contaminated materials.

All Site waters generated will be stored in temporary storage tanks onsite until samples are obtained for waste classification. Each tank of water generated will be sampled for chemical analysis. Based upon this analysis, each tanks’ contents will be classified for offsite disposal. Vacuum tankers, with a net payload of approximately 5000 gallons, will be scheduled on an as needed basis to remove water to the appropriate designated facility for treatment and disposal.

STOCKPILING/STAGING OF EXCAVATED MATERIALS

Stockpiling/Staging of Excavated Materials

Stockpiling Required?

Location Duration (Days)

Security Maintenance of Stockpile Material

Excavate and load out directly to the Tire Pond Area

No Individual Properties

1 During off-work hours, local security firm will patrol area.

N/A

Excavate and Stockpile within the limits of the excavation and load out to the Tire Pond Area

Yes Individual Properties

1-2 During off-work hours, local security firm will patrol area.

Spray water onto the pile to avoid wind dispersion. Cover pile with 6 millimeter (mL)


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STOCKPILING/STAGING OF EXCAVATED MATERIALS

Stockpiling/Staging of Excavated Materials

Stockpiling Required?

Location Duration (Days)

Security Maintenance of Stockpile Material

poly sheeting at end of day; add sandbags/hay bales/silt fence at toe of pile.

Encounter Municipal Waste during excavation: Excavate soil/municipal waste, stockpile material within the immediate work area, i.e., continuous properties in a given Site Sub-Area (A through T) load out & transport material to the Tire Pond Area for screening and disposal.

Yes Individual or Multiple Properties


Spray water onto the pile to avoid wind dispersion. Cover pile with 6 mL poly sheeting at end of day; add sandbags/hay bales/ silt fence at toe of pile as needed.

If Municipal Waste is predominately present during excavation: Excavate soil/municipal waste, stockpile material within a Site Sub-Area (A through T) load out & transport material directly to approved facility .

Yes/No, Load direct if possible

Multiple Properties

2-3 During off work hours, local security firm will patrol area.

Spray water onto the pile to avoid wind dispersion. Cover pile with 6 mL poly sheeting at end of day; add sandbags/hay bales/silt fence at toe of pile as needed.

If Municipal Waste is predominately present, (and testing of soils is required by the disposal facility) then Contractor will use Mill Rock Park as a Contingency Stockpile Area. Soil/municipal waste will be stockpiled at individual or multiple properties, loaded out & transported to Mill Rock Park for temporary staging until soils can be tested and analyzed for proper disposal.

Yes Mill Rock Park


Cover pile with 6 mL poly sheeting at end of day; add sandbags/hay bales at toe of pile as needed. Note: Area under the pile will be lined with two layers of 8-ounce geotextile fabric enveloping a 40 mL PVC or HDPE liner.


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4.5 MATERIAL AND WASTE SAMPLING AND ANALYSIS

Pre-characterization sampling of Sub-Area Site soils has been conducted under previous Site investigations. Materials will be managed as characterized in the Site Contract Drawings and the Property-Specific RAPs. Any additional sampling, as required and all post-excavation sampling, will be conducted per the approved SAP for the site by Olin’s Site Engineer.

4.6 MATERIAL AND WASTE PACKAGING

All material and waste scheduled for off-site transportation and disposal will be properly packaged in accordance with all applicable local, State and Federal regulations, including USDOT Hazardous Materials Regulations contained in 49 CFR Parts 171 through 180. Materials scheduled for shipment offsite will be packaged in end dump trailers or vacuum tankers for shipment by highway. All other material and wastes to be shipped off-site will be packaged in appropriate containers such as lined roll-off boxes or drums, as necessary. However, the packaging selected must be authorized for the specific material being shipped.

The following minimum packaging requirements apply for materials to be shipped:

Bulk Packaging

• Bulk packaging (e.g. dump trailers or tankers) must, at a minimum, meet the applicable requirements contained in 49 CFR 173.24, General Requirements for Packaging and Packages.

• Bulk packaging must be covered. The top must be completely enclosed with no opening along the sides or openings in the top. The containers will be covered and secured except when adding waste.

• Bulk packaging must be prepared to prevent material from leaking out or water from infiltrating in. Soil shipments for landfill containing free water will not be accepted by the disposal facility. Bulk containers must be equipped with an appropriate liner that can be folded and sealed to prevent contamination of the container itself and infiltration of water.

• Bulk packaging must be clean. It must not have any waste materials, or other material which could be mistaken for waste material, on the outer surface.

• Each bulk container which requires marking will be properly marked in accordance with 49 CFR 172 Subpart D.

• The tailgates of bulk solid trucks will be inspected prior to release from the site to verify that no leakage is occurring. Each tanker will be inspected to confirm all valves are closed and locked for transport.

4.7 MATERIAL AND WASTE LABELING AND DATING

Material and waste containers and packages will be marked in accordance with applicable local, State and Federal requirements (49 CFR 172 Subpart D). In addition, a unique Site-specific identification number will be assigned by Lot and/or Property or water tank generated and transport vehicle used for material transport to allow for proper tracking of the material from the time of shipment through off-site disposal and receipt of a certificate of disposal (if applicable). All offsite waste tracking information will be recorded in an information database. The material and waste management database will be periodically reviewed to ensure that no materials are stored on-site while awaiting shipment for a period of time longer than allowed by applicable waste accumulation regulations (90 days for hazardous wastes).

4.8 MATERIAL AND WASTE TRANSPORTATION AND DISPOSAL

This section describes the procedures for transportation and disposal of material and waste during remedial activities.


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A daily summary of loads managed onsite and loads for delivery offsite will be maintained by the Remedial Contractor. The Remedial Contractor will coordinate with all transporters of material designated for either Tire Pond Site reuse or offsite disposal to assure that adequate transport vehicles are available to meet the project schedule. The Remedial Contractor will maintain a master log of all transport companies, current permit numbers and licenses and individual truck ID’s onsite.

All transport vehicles will enter and leave the site and travel over public roads to their destination facility via a pre-approved, mandatory truck route (see Appendix B). A Traffic Control Plan will be developed and maintained at the Site. Flagmen may be posted during loading hours, as deemed necessary, to coordinate truck traffic. To the greatest extent possible, all trucks will be staged within site boundaries prior to loading.

The Remedial Contractor’s personnel and the designated on-site Transportation Coordinator will manage all aspects of transportation for disposal of all waste at the Site. This will include the scheduling, staging, directing from various Site locations, issuance of required paperwork, and final inspection prior to exit from the Site. The designated Remedial Contractor’s on-site Transportation Coordinator will report to Olin’s designated coordinator during completion of Site activities.

A Site Operating Log will be maintained at the Site to track shipment and receipt of all loads to either the Tire Pond Site staging area or offsite disposal facilities. This daily log, at a minimum, will contain the date shipped, trucking operator information, estimated weight, manifest number, staging area or offsite disposal facility to which the load was delivered, final disposition of waste and any other pertinent information pertaining to a particular shipment. A Bill of Lading will be utilized for each load for the Site records or billing purposes. All loads will be scheduled for delivery and operations will be coordinated to occur from between 7:00 am and 6:00 pm, Monday through Friday. Requests for extension of operating hours or additional working days (i.e., Saturday or Sunday) will be coordinated through the Tire Pond Site Project Manager.

4.8.1 RCRA Hazardous Materials

As required, any RCRA hazardous materials excavated during the remedial activities will be either treated in situ prior to excavation or transported to an Olin and/or CTDEP approved, licensed and permitted facility. Materials characterized as hazardous will not be transported to the Tire Pond Site, but will be managed either at the point of excavation or at the temporary Site staging area (Block D).

4.8.2 Non-Hazardous Materials (Not Acceptable for Reuse)

All Non-hazardous materials excavated during the remedial activities that are deemed unacceptable for reuse at the Tire Pond Site will be transported to an Olin approved, licensed and permitted facility; either a MSW or industrial waste or special waste landfill. Non-hazardous liquids will be disposed of at a designated TSDF/POTW facility.

4.8.3 Other Material and Wastes

Non-impacted Site trash and debris will be disposed of via a commercial refuse facility. A trash-only dumpster will be placed at the site and will be periodically maintained and emptied by the commercial refuse hauler.

Used oils and equipment fluids will be containerized, labeled and maintained onsite. These containers will be periodically removed by a local commercial recycler, as necessary.


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August 2009 5-1

5. NOTIFICATIONS, DOCUMENTATION, AND REPORTING The following sections present the procedures to be used for notifications, documentation, and reporting activities associated with management of excavated material during the remedial activities.

5.1 NOTIFICATIONS

Notifications of material and waste management activities at the Site will be made in accordance with the requirements of applicable local, State, and Federal requirements. In addition, a 30-day notice will be provided to the Tire Pond Site Project Manager prior to initiating shipments. A delivery confirmation notice will be issued 7-days prior to delivery to the Tire Pond Project Manager.

In the unlikely event that an incident occurs during transport, the Waste Transportation and Disposal Coordinator will notify the appropriate Olin representative as well as the required entities, as defined by USDOT requirements. At a minimum, this will require notification of the National Response Center at the earliest practicable moment. The type of information that must be provided includes:

• Location and name of person making report.

• Name and address of carrier represented by person making the report.

• Telephone number where person can be reached.

• Date, time, and location of the hazardous materials incident.

• Extent of injuries, if any.

• Classification, proper shipping name, and quantity of hazardous materials involved.

• Type of incident and nature of hazardous materials involved.

• Whether or not a continuing danger to life exists.

Notification procedures for events that result in a release, incident and/or emergency are described in Section 11.6 of the Health and Safety Plan (MACTEC, August 2009). Furthermore, as provided in Table 10, Emergency Telephone List, of the Health and Safety Plan (MACTEC, August 2009), the DEP 24-hour Hot Line number is 866-DEP-SPIL (866-337-7745 or 860-424-3338).

5.2 DOCUMENTATION PROCEDURES

Various types of documentation will be required for material management activities associated with the remedial activities to be performed at the Site. Field activities that generate material and waste will be documented to ensure that material and waste are managed appropriately. Material and waste characterization activities will be documented to ensure that material and waste characterization data can be easily and clearly correlated to a particular material or waste container or waste stream. Material and waste management activities will be closely documented to ensure that all materials and wastes are properly handled and disposed of.

Specifically, RCRA hazardous waste that will be managed at the temporary staging area will be inspected in accordance with applicable Federal and State regulations. Inspection log sheets will include:

• Name of the Inspector;

• Date and time of inspection;


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August 2009 5-2

• Physical condition of containment, etc.; and

• Labeling and marking eligibility, etc.

5.2.1 Documentation of Field Activities

Field activities, if any, that generate material and waste will be properly documented in order to establish the origins of such material and waste for proper disposal. The party who containerizes the material or waste is responsible for the initial documentation associated with generation of material or waste. At a minimum, the following information will be recorded when material or waste is generated and containerized:

• The date of generation.

• A description of the material or waste.

• Any pertinent observations about the material or waste.

• The approximate quantity of material or waste.

• The type of storage container used for the material or waste.

• Where the material or waste shall be staged while awaiting characterization and disposal.

The containers and/or stockpiles used for on-site storage of material or waste will be appropriately dated and labeled to assist in proper tracking of material or waste.

5.2.2 Documentation During Transportation and Disposal

Transportation and disposal activities will be documented using the Material and Waste Disposal Tracking Log presented as Appendix C to this plan. The information recorded on this log, when applicable, may include:

• The vehicle identification number for the material/waste.

• The material/waste disposal approval number.

• The quantity of the material/waste.

• The facility to which the material/waste was sent.

• The manifest number (if required) for shipment off-site.

• The date the material/waste was shipped.

• The date on which it was received at the facility.

• The date a certificate of acceptance, disposal or destruction was received from the facility (if applicable).

Acceptance certifications and/or certificates of disposal or destruction will be obtained from offsite disposal management facilities when hazardous wastes are sent to such facilities for disposal. These certificates will document that materials shipped off-site were sent to properly permitted facilities. In addition, such certificates will document that the subject material or wastes were properly managed and handled at the facility in accordance with applicable local, State, and Federal hazardous waste management regulations. When required by applicable regulations or by Olin, documentation will also be obtained from off-site facilities used for disposal of non-hazardous wastes.


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August 2009 5-3

5.2.2.1 Specific Requirements for Waste Shipments

• Highway shipments must include a uniform hazardous waste manifest (DOT/RCRA hazardous material); non-hazardous waste manifest or bill of lading (Non-DOT/Non-RCRA hazardous material).

• Hazardous material shipments must include Emergency Response Information meeting the requirements of 49 CFR 172 Subpart G.

• Hazardous waste shipments must include a Land Disposal Restrictions (LDR) Certification and/or Notice as required.

Draft versions of shipping documents will be forwarded to Olin and/or CTDEP for review and comment/approval prior to scheduling loads for offsite transport and disposal. Coordination for scheduling of transportation and management of paperwork shall be as follows:

• The Remedial Contractor’s site personnel will establish a tentative proposed load-out schedule for the upcoming week at the weekly project meeting; a copy of this will be forwarded to the Tire Pond Site Project Manager

• The Remedial Contractor will reconfirm each days’ load-out schedule the day proceeding load-out with the Tire Pond Manager;

• The Remedial Contractor will confirm that the designated Olin and/or CTDEP representative authorized to sign manifests/BOL’s will be onsite for the next day (for those materials requiring such paperwork);

• As loading proceeds, The Remedial Contractor will record individual load information and present each load’s paperwork to the designated Olin and/or CTDEP representative for review and signature;

• Signed Site copies of all paperwork will be maintained by The Remedial Contractor in the Site Project File. As necessary, regulatory copies will be forwarded to any/all state agencies. Signed hazardous waste manifest copies will be kept on file at the site. “Return to Generator” copies will be sent to the CTDEP.

• Signed paperwork will be supplied to each driver prior to release of load from the Site.

5.3 SPILL RESPONSE CONTINGENCY PLAN

All transportation subcontractors will have spill response contingency plans for handling spills ranging from small incidental releases to large releases caused by overturns. The Remedial Contractor’s personnel will handle small releases onsite. Large releases caused by full overturns or offsite incidents will be handled by teams of the transporter’s in-house response crews supplemented by subcontractors as required. Manpower, equipment and materials are handled on a case-by-case basis. Any subcontractor will notify The Remedial Contractor in the event that any spillage occurs during transit to its appropriate designation facility. Each transporter is required to maintain and follow a Spill Contingency Plan. Notification by the transporter of any incidents shall be made to The Remedial Contractor. In turn, will notify all appropriate individuals associated with this project of any spill and the response actions being taken.

Each transportation subcontractor (waste hauler) is required to have a contingency plan prepared for emergency situations (e.g., vehicle breakdown, accident, waste spill, waste leak, fire, and explosion) during transportation of excavated soils from the Site to the destined disposal facility. When the transportation subcontractor is contracted, a copy of the contingency plan(s) will be attached to this plan. This plan will be


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kept on-site throughout the duration of the project. Additionally, each hazardous waste transporter will have a transportation security plan.

Table 4-1

Waste Management Disposal Options Matrix Newhall Neighborhood Site, Hamden, Ct

Waste Matrix

Tire Pond Site Reuse

Off-Site Permitted Hazardous Waste

Disposal Site

Off-Site Permitted Non-Hazardous

Waste Disposal Site

Off-Site Aqueous TSDF

Recycler or Commercial

Refuse

Soil/Waste (from within Site footprint)

X X

X

Contaminated Spent PPE, Disposable Equipment, Filters, Miscellaneous Debris

X

X

Concrete and Steel (Contaminated)

X X

Concrete and Steel (Non-Contaminated)

X X X X

Managed Water (Construction, Decon)

X

Waste Oil From Oil Filters X

Common Non-Contaminated Trash, Garbage

X

PPE - Personal Protective Equipment


HAMDEN, CONNECTICUT

APPENDIX A

August 2009

MATERIALS MANAGEMENT PLAN

For the Management of Designated Materials at the Tire Pond


HAMDEN, CONNECTICUT

APPENDIX B

August 2009

TRANSPORTATION ROUTES


HAMDEN, CONNECTICUT

APPENDIX C

August 2009

MATERIAL AND WASTE DISPOSAL TRACKING LOG


HAMDEN, CONNECTICUT

APPENDIX C

August 2009

NEWHALL NEIGHBORHOOD SITE – HAMDEN, CT

MATERIAL AND WASTE DISPOSAL TRACKING LOG

Manifest Doc. No. Ship Date Time

In Time Out Type of Waste Manifest No. Hauling

Company Disposal Facility

Manifest Weight

Received Date Rec'd Weight COD

Received Daily Totals

00001

00002

00003

00004

00005

00006

00007

00008

00009

00010

00011

00012

00013

00014

00015

00016

00017

00018

00019

Totals 0 Tons 0 Tons


HAMDEN, CONNECTICUT

APPENDIX D

August 2009

FACILTY ACCEPTANCE LETTERS


HAMDEN, CONNECTICUT

APPENDIX D

August 2009

(PENDING)

Transportation and Consolidation Plan Final

Documents

Transcript of Transportation and Consolidation Plan Final