october 22, 2009 mr. hugo martinez cazon waste management division sites ... - vermont ·...

October 22, 2009 Mr. Hugo Martinez Cazon Vermont Department of Environmental Conservation Waste Management Division Sites Management Section 103 South Main Street Waterbury, Vermont 05671-0404

RE: Moran Plant Rehabilitation

475 Lake Street Burlington, Vermont SMS #2005-3357 LAG Project #09031

Dear Mr. Cazon: Lincoln Applied Geology, Inc. is pleased to provide you with this report outlining tasks performed at the Moran Plant, which is located at 475 Lake Street in Burlington, Vermont. Activities conducted at this site were part of the rehabilitation being performed at the Moran Plant. If you have any questions or comments regarding this report, please do not hesitate to contact us at your convenience. Sincerely, Lincoln Applied Geology, Inc. Iossy Medvinsky, CPG, CHMM Senior Geologist and Chief of Operations cc: David Weinstein and Nick Warner - CEDO IM/SR/LR:hr Enclosures F:\CLIENTS\2009\09031\Reports\Moran Plant Restoration.doc

hrichards

Dagan

Moran Plant Rehabilitation

Moran Plant Rehabilitation 475 Lake Street

Burlington, Vermont SMS #2005-3357

LAG Project # 09031

October 22, 2009

Prepared for:

Vermont Department of Environmental Conservation Waste Management Division Sites Management Section

103 South Main Street Waterbury, Vermont 05671-0404

Prepared by:

Lincoln Applied Geology, Inc. 163 Revell Road Lincoln, Vermont

Iossy Medvinsky, CPG, CHMM

Senior Geologist and Chief of Operations

TABLE OF CONTENTS

1.0 INTRODUCTION.................................................................................................. 1 2.0 SCOPE OF WORK............................................................................................... 1

2.1 Site Safety Preparation ..................................................................................... 1 2.2 Basement Dewatering....................................................................................... 2 2.3 Guano Removal ................................................................................................ 2 2.4 Removal of Miscellaneous Debris and Scrap Metal.......................................... 3 2.5 Lead-based Paint Stabilization.......................................................................... 3 2.6 Asbestos Abatement......................................................................................... 4

3.0 CONCLUSIONS ................................................................................................... 4 Figures Figures 1 .............................................................................................................Site Plan Appendixes Appendix A..................................................................... Laboratory Certificate of Analyses Appendix B....................................................................... Asbestos Inspection Certification

Moran Plant Rehabilitation October 22, 2009 Moran Plant, Burlington, Vermont

Lincoln Applied Geology, Inc. 1

1.0 INTRODUCTION

The Moran Plant (the “Site”) consists of a 120 ft by 140 ft vacant steel, brick, and

concrete building which operated as a coal-burning power plant by the Burlington Electric Department between the years 1953 and 1986. Former operations at the Site, including the burning of coal and the cleaning of coal burning machinery, resulted in the contamination of the basement with metals and other residual contaminants. Prior to 1953, the general area occupied by the Site included railroad property, a lumber yard and mill, and the storage and transportation of petroleum substances. One petroleum bulk tank was partially located within the Site property. Until January 2009 the building was connected to Lake Champlain by a sub-basement channel system which filled the basement with water. Although this passage has been sealed, ground water and rainwater (that percolates through the roof) contribute to the existing water in the basement.

In early June 2009, Lincoln Applied Geology, Inc. (LAG) initiated corrective action

operations at the Site which included the dewatering of the basement, the removal of metal fragments also located in the basement, the removal of guano throughout the building, the stabilization of lead-based paint, and an asbestos abatement. Figure 1 depicts the Site, surrounding area, and the piping layout for the dewatering of the basement. 2.0 SCOPE OF WORK

2.1 Site Safety Preparation

A Health and Safety Plan (H&SP) was developed per the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120 prior to commencing any activity at the Site. The H&SP outlined safe working conditions and described hazards present at the Site, designated zones of operation, required protective equipment, decontamination procedures for equipment and personnel, means of communication in the event of an emergency, escape routes, and directions to nearby medical facilities. All workers performing remedial tasks at the Site were in strict compliance with the H&SP, including wearing hard hats, steel boots, and tyvek suits. Full face respirators and other accessories per Level C personal protection (PPE) were also used, as needed. Respirator Fit Data Collection Forms were filled out for personnel working under Level C conditions. Meetings were conducted at the Site to discuss the H&SP, clarify any questions, and emphasize strict safety measures. In addition, in order to access the building, every individual was required to familiarize himself/herself with all the safety procedures, sign the H&SP, and Log In/Log Out forms. Daily Activity Logs were also completed during the Site operations.

Between June 18 and 26, 2009, LAG, working in conjunction with ENPRO

Services, Inc. (ENPRO) of Williston, Vermont, proceeded to make the building safe for future work. Temporary construction lights were installed in all working



areas. The smaller floor openings were covered with plywood and secured to the concrete floor while the larger openings were barricaded off with orange fencing and caution tape. In addition, these areas were marked with orange paint so that they would be more easily noticed. The upper floors metal grates were properly adjusted and safety lines and harnesses were provided prior to any work. Following this activity, LAG thoroughly inspected the building to ensure that all safety precautions were in place in accordance with all OSHA regulations. As a certain floor was secured, specific operations were immediately commenced to avoid any delays.

2.2 Basement Dewatering Between June 26 and July 8, 2009, dewatering operations were commenced at the Site. Two double diaphragm pumps were used to pump the basement water to one 21,000-gallon frac tank located outside the building (see Figure 1). Both pumps were operated simultaneously and were placed on the east and west sides of the basement. The pump located on the west side forced water to the east portion of the basement for faster recovery. The frac tank was used to dewater the basement more expeditiously and to allow for sediments to settle in the tank. A 25 micron bag filter was attached to the discharge line (post frac tank) to filter out any sediment/particulate matter. In addition, a flow meter was connected to the discharge line to keep a record of the amount of discharged water and a valve attached to regulate the flow. Water was pumped at an average rate of 50 gallons per minute (gpm) into a sanitary sewer lift station located approximately 250 feet south of the Site (see Figure 1). A ramp was originally constructed to protect the discharge line in areas exposed to traffic; however, the line did not withstand heavier/speeding vehicles. A 35-foot long trench was instead excavated under Lake Street and a 4-inch diameter PVC pipe placed in the trench. The excavation was backfilled with the native soil and the surface covered with asphalt cold patch. Following dewatering operations the piping was retrieved and the surface restored to its original condition. 342,150 gallons were pumped until the water was below basement floor level.

2.3 Guano Removal

Prior to proceeding with the guano removal, one composite sample from the first and second floors was collected and submitted to Endyne, Inc. of Williston, Vermont, for toxicity characteristic leaching procedure (TCLP) lead and polychlorinated biphenyls (PCB) analyses (see Appendix A). The purpose of these analyses was to fulfill disposal requirements and to ensure that the guano has not mixed with the lead-based paint making it a hazardous waste. According to the analytical results, the TCLP lead tests indicated a concentration of less than 0.2 parts per million (ppm) making the guano non-hazardous. The PCB analysis indicated aroclor 1016 – 1248 at levels below the laboratory detection limit; however, aroclor 1254 and 1260 revealed concentrations of 183 and 67.1 parts per billion (ppb), respectively. Nevertheless, these concentrations are below regulatory levels.



Between June 22 and July 8, 2009, miscellaneous debris and guano were removed from the building. A mini excavator and skid steer were mobilized to the Site to assist with this activity. Additionally, a vactor truck and associated hoses were used to create a negative pressure vacuum to recover the guano, thus preventing the spread of airborne infectious particles. In addition to the vactor truck, air guns, brooms, and brushes were used to accomplish this operation. Personnel involved in guano removal performed this task in Level C PPE. The guano was temporarily stored outside the building in one 30 cubic yard roll-off container. Four tons of guano were disposed as municipal waste at the Moretown Landfill in Moretown, Vermont. After the guano was recovered, the surfaces were washed with a bleach/water solution. 2.4 Removal of Miscellaneous Debris and Scrap Metal Between July 8 and 10, 2009, and after the water in the basement was pumped out; the loose debris and scrap metal was gross cleaned of any sediment. The debris and scrap metal was originally intended to be retrieved from the basement with a mini excavator and skid steer; however, the many built-in trenches and piping as well as the lack of structural integrity of parts of the building prohibited this operation. Instead, this material was removed by hand and piled up on the first floor to be later transported to the roll-off container by the skid steer. Debris such as old bricks, construction rubble, and wood were stored outside the building in two 30 cubic yard roll-off containers for disposal. 4.75 tons of debris were disposed as municipal waste at the Moretown Landfill. The scrap metal was stored in three 30 cubic yard roll-off containers. Approximately 25 tons of scrap metal was picked up free of charge by Burnett Scrap Metals, LLC and transported to their facility in Hinesburg.

2.5 Lead-based Paint Stabilization Prior to commencing the lead-based paint stabilization on the steel structure, polyethylene sheets were placed on the floors to contain any fallen paint. Between August 11 and 19, 2009, Alderson, Inc. (Alderson) of Burlington, Vermont, a lead-based paint contractor, proceeded to stabilize the paint located on the metal beams according to OSHA 29 CFR 1926.62. All employees were required to wear Level C PPE, including full face respirators with appropriate cartridges. Various scraping tools were used to remove the peeling paint and negative pressure vacuum equipment was used to contain the fallen paint. The paint was temporarily stored into eleven 8 cubic yard boxes. Per LAG’s proposal to the VDEC, two boxes containing lead-based paint were picked up by ENPRO and disposed as hazardous waste at a certified landfill. Currently, nine boxes still remain in the building, which will be disposed of by the City of Burlington. In order to dispose of the two previously mentioned boxes, one composite paint sample was collected and submitted to Endyne, Inc. for total lead analysis to determine its disposal status (see Appendix A). According to the laboratory results, the paint contained a concentration of 4,500 parts per million (ppm), which classifies it as hazardous waste.



2.6 Asbestos Abatement Between August 20 and September 21, 2009, Alderson, a Vermont certified asbestos contractor, removed all the asbestos containing window caulking at the Site, abiding by all state and federal regulations. Prior to commencing the asbestos abatement, Alderson posted danger signs in accordance with OSHA 29 CFR 1926.1101. This work was performed using Level C protection, including full face respirators with suitable cartridges. In some areas of the building, the entire window was removed using a blow torch or other means. In addition, some windows contained an exterior hardboard asbestos containing material, which was also removed to gain access to the window caulking. Alderson removed approximately 800 square feet of asbestos containing caulking material and approximately 600 square feet of asbestos containing hardboard. Upon completion of the asbestos removal on September 18, 2009, the work area was cleared of visible debris utilizing wet methods and High Efficient Particulate Air (HEPA) vacuums to maintain negative pressure in those areas. A visual inspection was conducted then by a third party Vermont licensed project monitor (see Appendix B). A final cleaning was completed on September 21, 2009, and all equipment and material were removed. Asbestos contaminated waste was placed in double 6-mil properly labeled polyethylene bags prior to transportation as hazardous waste to a certified landfill for final disposal.

3.0 CONCLUSIONS Based on the field operations presented herein, the following conclusions are presented:

All operations were performed per OSHA regulations and in accordance with the VDEC requirements;

Floor openings were covered with wood and the building secured prior to

commencing corrective activities;

Work was conducted under strict QA/QC protocols including a comprehensive H&SP;

Between June 26 and July 8, 2009, the basement was dewatered allowing the

removal of loose metal debris from the basement floor. Water was pumped at an average rate of 50 gpm into a sanitary sewer lift station located approximately 250 feet south of the Site. 342,150 gallons of water were pumped into the sanitary sewer;

Between June 22 and July 8, 2009, miscellaneous debris and guano were

removed from the building using a vactor truck, air guns, brooms, and brushes. Following the guano removal, the surfaces were washed with a bleach/water



solution. The guano was temporarily stored outside the building in a roll-off container. Four tons of guano were disposed as municipal waste at the Moretown Landfill in Moretown, Vermont;

Between July 8 and 10, 2009, loose debris and scrap metal in the basement was

removed by hand and stored in a roll-off container located outside the building. 4.75 tons of debris were disposed as municipal waste at the Moretown Landfill while approximately 25 tons of scrap metal was picked up free of charge by Burnett Scrap Metals, LLC and transported to their facility in Hinesburg;

Between August 11 and 19, 2009, the metal beams’ lead-based paint was

stabilized. The paint was stored into 8 cubic yard boxes and disposed by ENPRO as hazardous waste at a certified landfill; and

Between August 20 and September 21, 2009, the asbestos containing window caulking was abated from the building. Approximately 800 square feet of asbestos containing caulking material were removed and placed in properly labeled double 6-mil polyethylene bags prior to transportation as hazardous waste at a certified landfill for final disposal.

The hazardous waste manifests/certificates of disposal will be submitted to the

VDEC when they become available. F:\CLIENTS\2009\09031\Reports\Moran Plant Restoration.doc

Figure 1

Site Plan

Appendix A

Laboratory Certificate of Analyses

Appendix B

Asbestos Inspection Certification

october 22, 2009 mr. hugo martinez cazon waste management division sites ... - vermont ·...

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