RCRA Corrective Action – Former Stanley Tools Facility
Client: Confidential Client
CTI is providing comprehensive remediation services for the Former Stanley Tools Facility located on the Red Cedar River in Fowlerville, Michigan. Remediation at this former plating facility was completed under a December, 2002 “streamlined” Agreement on Consent (AOC) with USEPA Region 5 RCRA Corrective Action (CA) Section. Corrective Action work included:
- Soils characterization and remediation was completed on an expedited basis by simultaneously excavating and confirming the excavation side walls. Over 800 soil samples were collected and over 90,000 tons of soils impacted with PCBs and/or chlorinated solvents were excavated, virtually replacing the site’s vadose zone. The final Corrective Measure Proposal’s recommendation of no further action for soils was accepted by Region 5 USEPA RCRA CA Section.
- Groundwater characterization and remedy selection for dissolved-phase chlorinated solvents, including aquifer interaction with underlying bedrock formations and the adjacent Red Cedar River. In total, 65 new groundwater monitoring wells were installed, and sampled to demonstrate the viability of Monitored Natural Attenuation (MNA) remedy accepted by Region 5 USEPA RCRA CA Section. Since 2005, CTI has been implementing long-term groundwater monitoring and reporting accordance with the site’s MNA groundwater remedy approved by RCRA CA.
- Sediment characterization and remedy selection was achieved by the collection of over 90 Vibracore sediment samples to define the horizontal and vertical extent of impact in the Red Cedar River. Using soft sediment quantification and laboratory analyses to develop SWAC values for sediment impacts, and the Final Corrective Measure proposal’s recommendation for dredging following a baseline Ecological Risk Assessment to establish site-specific ecological cleanup criteria was accepted by Region 5 USEPA RCRA CA Section.
Following establishment of sediment cleanup criteria for the Red Cedar River, CTI began work on the design and implementation of the dredging remedy for the site. The dredging corrective action was completed in the September 2013 and included the following tasks:
- Dredging planning and design under an approved dredging design plan that recommended in-channel dredging after the river had been diverted and the sediments were dewatered and stabilized with Portland cement.
- Specifications, contract management, construction oversight with post-dredging verification accomplished using a metal probe, and laboratory analytical sampling was not required. A total of 1,300 cubic yards of impacted sediment was removed.
- Post construction monitoring. CTI successfully negotiated on behalf of the client to reach Agency concurrence that no post construction monitoring is required because all impacted sediment was removed.