Pre-Design Investigation

A remedial design program will be implemented to provide the details necessary for the design, construction, operation, optimization, maintenance, and monitoring of the remedies selected for the site. Pre-Design Investigation (PDIs) will be implemented to fill data gaps and inform the remedial designs for the various Operable Units (OUs) at the site. A PDI Work Plan will be developed for each OU, and approved by the Department, to ensure that adequate information is available to complete the remedial designs.

The PDIs will include, but are not limited to, the following elements:

  • Additional soil sampling (e.g., borings and/or test pits/trenches) to determine the extent of areas where the upper one foot of exposed surface soil exceeds commercial (OU-05 only) or industrial soil cleanup objectives (SCOs) and a site cover may be needed to allow for commercial or industrial use of the site;
  • Additional soil/fill/waste/sediment sampling to further characterize the nature and extent of soil/fill/waste/sediment to inform remedial design decisions regarding disposition of excavated/dredged materials and site cover needs;

Location of OU-5
Location of OU-5

  • Additional soil/fill/waste sampling in Solid Waste Management Units (SWMUs, which are any discernible unit at which solid wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous waste) where waste extends into, or close to, the groundwater table (i.e., SWMU S-04 in OU-05, see location of SWMUs in the below figure, more information on these areas can be found on the NYS Department of Environmental Conservation (DEC) website: https://www.dec.ny.gov/chemical/122928.html), to verify these wastes are not contributing contaminants to groundwater; reduce exposure to environmental contaminants. The SCOs are contained in DEC’s Environmental Remediation Program regulations (see http://www.dec.ny.gov/chemical/34189.html).

Figure illustrating waste that extends below the water table at SMWU S-04
Figure illustrating waste that extends below the water table at SMWU S-04

  • Exploratory investigations (e.g., borings and/or test pits/trenches) to determine the presence of grossly contaminated materials;
  • Radiation surveys and/or sampling to identify material exhibiting elevated radiological readings and inform remedial design decisions regarding disposition of excavated materials and site cover needs;
  • Utilizing a utility locator to determine the location of any underground wind turbine utilities or other obstructions that may impact remedial construction activities. This information would be utilized to either re-route these utilities outside the remediation or to identify, accommodate, and protect their locations, including during any future anticipated maintenance activities;
  • Geotechnical sampling to provide the details necessary to inform the remedial design;
  • Surveys/investigations will be performed prior to any demolition activities to identify and quantify the presence of asbestos, lead-based paint, PCBs, or other hazardous/regulated materials in order to inform the demolition design; and/or
  • Locational Surveying, including the location of any additional soil sampling, appropriate to support the remedial design and implementation of the remedy.

What was the purpose of taking the soil samples?

The soil sampling has several purposes:

  • To examine the nature and extent of constituents of concern in site soils;
  • To see if contaminant levels in the soil exceed the applicable New York State soil cleanup objectives (SCOs); and
  • To see if the soil (fill) is “grossly contaminated” or meets the criteria that would make it “hazardous waste.”

What are soil cleanup objectives or “SCOs”?

SCOs are contaminant-specific soil concentrations that are protective of public health and the environment for specified uses of a property (e.g., commercial [OU-05 only, see below the Figure showing locations of OUs] and industrial). SCOs are set at a soil level at which health effects are unlikely to occur and are used, along with other considerations, to guide decisions about the need to reduce exposure to environmental contaminants. The SCOs are contained in DEC’s Environmental Remediation Program regulations (see http://www.dec.ny.gov/chemical/34189.html).

An SCO is not a “bright line” between soil concentrations that will result in health effects and those that will not. The degree of public health concern when an SCO is exceeded depends on several factors, including (among others) the extent to which the SCO is exceeded, the potential for human exposure, other sources of exposure to the chemical, and the strength and quality of the available toxicological information on the chemical.

What is meant by “grossly contaminated”?

“Grossly contaminated media” means soil, sediment, surface water or groundwater which contains sources or substantial quantities of mobile contamination in the form of Non-Aqueous Phase Liquid (NAPL), as defined in subdivision 375-1.2 (ac), that is identifiable either visually, through strong odor, by elevated contaminant vapor levels or is otherwise readily detectable without laboratory analysis. NAPLs are organic liquid contaminants that do not dissolve in, or easily mix with, water (hydrophobic), like oil, coal tar, and some chlorinated solvents.

What is meant by hazardous waste?

The term hazardous waste is a regulatory designation. In New York State, hazardous wastes are defined by U.S. Environmental Protection Agency and DEC regulations (see http://www.dec.ny.gov/chemical/100401.html) based on whether the materials have certain traits. Fill material in the study area was tested to see if it should be designated hazardous waste by using a test known as the Toxicity Characteristic Leaching Procedure (TCLP). TCLP simulates leaching through a landfill to assess the potential for contamination in the material being tested (typically soil) to migrate into groundwater. Designation of the target fill materials in the study area as hazardous waste is not directly related to the potential for human exposure or health risks; rather, it tells us that the materials, if removed, require special handling and disposal in a hazardous waste landfill.

How long will the PDIs Take?

PDI activities may involve drill rigs, backhoes, and other noisy equipment. Residents and businesses close to a site may see a slight increase in traffic near the site. Dust from drilling and excavation activities can be controlled by spraying water or covering stockpiled materials with tarps. All activities will be performed following a Health and Safety Plan (HASP) and a Community Air Monitoring Program (CAMP).

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Examples of typical PDI activities: Drilling (left) and digging trench pits (right)

Demolition

Why is demolition needed?

Although most of the buildings and structures associated with the former BSC steel making and coke oven operations have been razed, some still remain on site. Most of the remaining buildings and structures are not suitable for reuse, and their presence actually impedes redevelopment of the property. Some are dilapidated, and may pose a physical hazard to the public, while others may contain contamination or hazardous materials. These remaining buildings and structures require demolition and disposal to remove hazards to the public and the environment and to facilitate the proposed industrial redevelopment of the site.

Where is demolition needed?

The former Tank Farm area in OU-06 has two derelict structures, a former laboratory and small pump house, and remnant tank pads that require demolition. The majority of the remaining buildings and structures requiring demolition are located in BSC’s former coke oven operations area in OU-07, where activities were terminated in September 2001. Since then, portions of the coke batteries and the coke gas by-products processing infrastructure have been razed. However, the remnants of two coke batteries remain in the northeast part of OU-07, as well as a number of structures, pits, vaults, chimney stacks, cracking towers, piping, roadways, and railroad tracks.

SITE FIGURE SHOWING OPERABLE UNIT AREAS

What will demolition activities entail?

The former facility buildings, structures, and associated appurtenances will be razed to ground level. Prior to demolition, structures and components will be appropriately characterized to identify lead-based paint, asbestos, PCBs, hazardous materials, etc. to determine the appropriate disposal location - either off-site or on-site. Dust suppression will be utilized to control fugitive dust emissions, dust suppression fluid and storm water run-off control measures will be employed to minimize any short-term impacts from demolition activities.

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Example of existing buildings/structures in OU-07 to be demolished

A comprehensive Community Air Monitoring Program (CAMP) will be developed and implemented during demolition activities. Hazardous soil and building materials will be sent to a RCRA-regulated facility for disposal. Pits, vaults and subgrade structures known or discovered during demolition activities will be cleaned and their bottoms broken and backfilled with Department-approved fill. Contractors responsible for demolition activities will be required to obtain a demolition permit, and any other applicable permits required, from the City of Lackawanna.

During investigation and remediation DEC inspectors will be on-site to observe activities associated with the remedial program. DEC personnel or a DEC-contracted inspector will oversee implementation of the health and safety plan, review planned activities, and respond to community questions through a dedicated telephone number. Additional dedicated third-party personnel will be in place if needed during specific work activities to support DEC with providing noise or vibration monitoring, air monitoring, and independent oversight inspections.

How long will the demolition take?

Developing demolition work plans, including regulatory agency review and approval, may take several months. Contactor procurement and completion of the demolition work may take several months to over a year, depending upon site conditions.

How might it affect me?

Demolition may involve bulldozers, excavators, dump trucks, and other noisy equipment. Residents and businesses close to a site may see increased truck traffic if demolished materials are transported off-site for disposal. Dust from demolition activities can be controlled by spraying water or covering stockpiled materials with tarps. No fugitive dust emissions will be tolerated and to this effect the agencies ensure the implementation of an approved Community Air Monitoring Plan (CAMP) that requires continuous upwind and downwind air monitoring during all excavation, soil handling and backfilling activities (for more information, refer to the Public Health section).

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Typical activities, equipment, and setup to expect in the area during demolition