These questions were submitted to the CIG through the "Leave a Comment" section of this web site

Why would FMC endanger all residents with the remediation of the soil by digging it, hauling it to a CAMU, and then testing it? If it is tested positive then it has to be removed again. How is it tested? Per what measurement per load is it tested before more is dumped onto it?

If CAMU is filled, why is there not a plan in place prior to remediation for another site instead of waiting until it is near full to find an alternative site? To be able to get another site it must be approved through several sessions by the NYSDEC, correct? Then this would alternately stop remediation and open ground with contaminates at the remedial site, correct?

With out a liner doesn't contaminates run off and run through the soils of the surrounding areas. Isn't this why the remediation is taking place now because of run off from FMC that contaminated the soil in and around Middleport? Your response to protecting the residents in the area by stating, "Due to the levels and nature of the contaminated soil that would be placed in the CAMU, there will be "little prospect of any migration" from the CAMU. Moreover, FMC has an active groundwater control system in place to deal with any migration." Does it deal with migration or does it only detect migration? Please explain. Thank you

Click on the "Read Full Article" link below to read FMC's answers.
Question #1:
“Why would FMC endanger all residents with the remediation of the soil by digging it,
hauling it to CAMU, and then test it? If it is test positive then it has to be removed again.
How is it tested? Per what measurement per load is tested before more is dumped onto
it?”

Soils from many residential properties within the Middleport study areas have been tested
for total arsenic as part of FMC’s RCRA Facility Investigation (RFI). Based on review
of soil sample data collected during the RFI, the regulatory Agencies (United States
Environmental Protection Agency and New York State Department of Environmental
Conservation, in consultation with the New York State Department of Health) determined
that remediation of certain areas was required prior to completion of the RFI and
Corrective Measures Study (CMS) and directed that FMC perform Interim Corrective
Measures to remove (excavate) impacted soils. During the design and construction phase
of the Interim Corrective Measures or in some cases Early Actions, additional soil
sampling was performed 1) to identify the vertical and horizontal limits of soil excavation
and 2) to determine if the soil exhibits the characteristics of a “hazardous waste”, as
defined under the RCRA regulations. Only soil that did not exhibit the characteristics of
a “hazardous waste” was placed in the Eastern Surface Impoundment (ESI) Fill Area.
Testing of soil after placement in the ESI Fill Area and of soil in individual truck loads is
not necessary due to the existence of extensive soil sample results obtained prior to
excavation of the soil.

Similarly, any future remediation of soil in the community will be based on data obtained
prior to the decision that remediation is necessary. After a remediation decision has been
made, additional soil testing may be performed to determine if the soil is a hazardous
waste since hazardous waste cannot be placed in the CAMU. If sufficient existing data
do not exist for this purpose, testing may also be performed to establish the limits of soil
excavation. FMC’s goal is to transport or move excavated soil only once, either to the
CAMU or to an off-Site commercial disposal facility.


Question #2:
“If CAMU is filled, why is there not a plan in place prior to remediation for another site
instead of waiting until it is near full to find an alternative site? To be able to get
another site it must be approved through several sessions by the NYSEC, correct? Then
this would alternately stop remediation and open ground with contaminates site at the
remedial site, correct?”

At the present time, the extent of any remediation that may be required in the community
is not known. Therefore, the total volume of soil that would be excavated from
properties in the community can not be determined. FMC does not know if the proposed
three phases of the CAMU will have sufficient capacity to hold all that soils that may be
excavated from the study areas. If use of the CAMU is not approved by the Agencies, or
if it is determined that the capacity of the CAMU will be exceeded by the volume of soils
that will be excavated in the course of remediation, FMC will need to dispose of
remediation soils at a commercial landfill facility outside of the Middleport area.


Question #3:
“With out a liner doesn’t contaminates run off and run through the soils of the
surrounding areas. Isn’t this why the remediation is taking place now because of run off
from FMC that contaminated the soil in and around Middleport? Your response to
protecting the residents in the area by stating, “Due to the levels and nature of the
contaminated soil that would be placed in the CAMU, there will be “little prospect of any
migration” from the CAMU. Moreover, FMC has an active groundwater control system
in place to deal with any migration.” Does it deal with migration or does it only detect
migration? Please explain. Thank you.”

The potential presence of FMC-related contamination in off-Site study areas may have
occurred from historical air emission from past arsenical pesticide manufacturing
activities at the Plant Site and from historical discharges of surface water runoff from the
Plant Site. In the mid- 1970’s, FMC ceased arsenical pesticide manufacturing operations,
and FMC began collection and treatment of potentially contaminated surface water runoff
prior to discharge under the terms and conditions of a SPDES discharge permit.
Accordingly, FMC believes the sources of any potential air and surface water migration
of FMC-related arsenic from the Plant Site have been addressed.

With respect to the proposed CAMU, any remediation soils/materials placed will be
covered with a clean soil cover system that will be vegetated. The cover system will shed
rain water and prevent wind and water erosion. In other words, the cover system will
prevent the airborne and surface water migration of soils/material placed in the CAMU.

FMC believes that there will be “little prospect of any migration from the CAMU” as a
result of any water (direct precipitation) that may “run through” or percolate through the
soils/material placed in the CAMU for the following reasons:

a) No hazardous wastes, no liquid wastes, no municipal wastes and no wastes from
the FMC plant operations will be placed in the CAMU.
b) The levels of contaminants in the soil/materials that would be placed in the
CAMU are low and do not exhibit the characteristics of a hazardous waste (e.g.,
contaminants do not leach from the soil at a level above the regulatory limits).
c) Arsenic tends to bind to soil particles and is typically immobile, especially at the
low levels found in the soil/materials that have been and will be placed in the
CAMU.
d) Soil/materials have been/will be placed on top of the existing ground surface, well
above (and not in contact with) the underground water level where groundwater
completely saturates the soil or bedrock.
e) Any rain water or snow melt that may percolate “run through” or percolate
through soils/material placed in the CAMU will be captured and contained by
FMC’s blast-fractured bedrock collection trenches and groundwater well systems,
which include a series of groundwater collection trenches and14 groundwater
extraction wells, most of which are located along the northern and eastern
boundary of the Plant site. The collected groundwater is then treated at FMC’s
Water Treatment Plant.
f) FMC will continue routine monitoring of groundwater beneath and around the
proposed CAMU under FMC’s Groundwater Monitoring Program (GMP). The
GMP includes quarterly groundwater level measurements and quarterly, semi-
annual and biennial sampling and analysis of extraction wells and on and off-site
monitoring wells.
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