Environmental Resources Management 5788 Widewaters Parkway DeWitt, New York 13214 315-445-2554 315-445-2543 (fax) 23 December 2011 Michael J. Hinton, P.E. Division of Environmental Remediation – Region 9 New York State Department of Environmental Conservation 270 Michigan Avenue Buffalo, New York 14203 RE: Revised Addendum to the Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 Dear Mr. Hinton: ERM Consulting and Engineering, Inc. (ERM) is providing environmental services to Greenpac Mill, LLC (Greenpac) on the above-referenced project. ERM is documenting activities associated with the investigation and remediation of soil within the parcel identified as Brownfield Cleanup Program (BCP) Site Number C932150 located at 4001 Packard Road in the City of Niagara Falls, Niagara County, New York (the Site). The location of the Site is presented in Figure 1 (Attachment A). General Site layout and the location of selected Site features are presented in Figure 2 (Attachment A). The New York State Department of Environmental Conservation (NYSDEC) was consulted due to the discovery of radioactive materials at the Site. The removal of radioactive materials at the Site is being performed on behalf of Greenpac under the direction of Los Alamos Technical Associates, Inc. of Westerville, Ohio (LATA) and Greater Radiological Dimensions, Inc. of Lewiston, New York (GRD) under the oversight of NYSDEC and New York State Department of Health (NYSDOH) specialists in radioactive materials removal, in consultation with NYSDEC’s BCP Project Manager and ERM. Professional profiles for key LATA personnel are provided in Attachment B. The purpose of this Addendum is to present results available to date of the investigation of radioactive materials and to describe the approach being used at the Site by LATA for the removal of radioactive materials. The approach for radiological removal at the Site is outlined in four work plans prepared by LATA and previously approved by the NYSDEC and the NYSDOH: Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 2  Site Operations Plan dated 16 September 2011 (Attachment C);  Site-Specific Radiological Safety Plan dated 2 September 2011 (Attachment D);  Waste Management Plan dated 8 September 2011 (Attachment E); and  Transportation and Disposal Plan dated 31 August 2011 (Attachment F). The removal of radioactive materials at the Site is being incorporated into the overall BCP for the Site through the submission and approval of this Addendum. At the request of the NYSDEC, ERM has prepared this document as an Addendum to the NYSDEC-approved Soil Excavation Interim Remedial Measure (IRM) Work Plan for the Site prepared by ERM dated June 2011. This document supersedes the previous version dated 5 December 2011 and incorporates NYSDEC comments contained in the correspondence from the NYSDEC to Greenpac dated 13 December 2011. INTRODUCTION The Site is located in an industrial urban area in Niagara Falls, New York. Buildings, facilities, and operations at the Site are associated with the Former Mill No. 2 which historically housed paper manufacturing, finishing, and packaging operations of finished goods. The facility was originally constructed in the 1920s and was expanded several times. Former Mill No. 2 structures have been demolished to allow construction of a new, state-of-the-art fiberboard recycling facility. Excavation of soil is being performed to install foundations for the new facility and to address areas of chemical-affected soil that contains compounds of potential concern at concentrations above applicable NYSDEC Part 375 Soil Cleanup Objectives. Additionally, remedial investigation (RI) is ongoing at the Site. Data and information obtained from RI activities completed to date were reviewed and incorporated as appropriate into the Soil Excavation Interim Remedial Measure (IRM) Work Plan dated June 2011. This work plan was conditionally approved by the NYSDEC on 3 June 2011. Radioactive slag material was subsequently discovered in historic fill materials excavated at the Site when three trucks tripped the radiation portal at Allied Landfill on 9 August 2011. Soil from these three trucks was screened in the field using a radiation meter and samples were Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 3 collected for laboratory analysis. Initial evaluation of resulting data suggests that the source of the radiation is technically-enhanced naturally- occurring radioactive material (TENORM) associated with historic production of phosphorus slag in western New York. HEALTH AND SAFETY Radiological (rad) removal work is being performed under the direct supervision of LATA and GRD personnel in conformance with LATA’s Site-Specific Radiological Safety Plan (Attachment D). Attachment D was previously approved by the NYSDEC and the NYSDOH in e-mail correspondence dated 7 September and 8 September 2011, respectively. INVESTIGATION RESULTS The purpose of the radiological investigation was to delineate radiological conditions in areas within the BCP Site Boundary that exceed the NYSDEC-approved general guidance value of 10,000 counts-per-minute (cpm) as quantified using a Ludlum Model 2221 meter with a 44-10 probe (sodium iodide). Radiological screening activities included:  visual identification of slag material;  scanning of material surfaces by GRD radiological technicians using field instruments;  comparison of screening data against background measurements to evaluate whether the materials have elevated radioactivity; and  evaluation of survey results provided by site instruments. The investigation of TENORM at the Site was performed during the following activities. Results for each activity are summarized below. Field Screening During RI Activities All soil cores installed subsequent to the discovery of elevated radiation at the Site were screened for radioactivity by GRD using a Ludlum Model 2221 meter with a 44-10 probe. Radioactivity readings greater than 10,000 cpm were not encountered in soil borings with the exception of historic fill material at the following soil boring locations:  B-1A;  B-1B; Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 4  B-1C; and  B-1D. These borings are located west and north of the existing electrical substation. Field Screening During Excavation Activities Excavation activities in remaining phases associated with the main building construction are being directed by LATA and observed by a LATA Radiation Safety Officer. Excavated soil is being screened by GRD technicians using visual assessment and a Ludlum Model 2221 meter with a 44-10 probe (sodium iodide). Excavation activities have included excavations for construction of the new building and test pits installed in selected areas at the discretion of GRD radiological technicians. Results of the radiological investigation effort are being summarized in selected GRD Gamma Walkover Survey Forms (Attachment G) documenting investigation efforts in the following areas:  Initial walkover of Excavation Phase 3 and Phase 4 (GRD Survey #GPM-000);  The proposed new electrical substation (GRD Survey #GPM-004);  Dose rate survey for the characterization of soil (GRD Survey #GPM-005);  Survey of the concrete pad staging area in the Northern Extension (GRD Survey #GPM-008);  Survey of excavation quadrants beneath a portion of the formerly active steam line (GRD Survey #GPM-018);  Test pits near the western fence line south of Excavation Phase 2 (GRD Survey #GPM-033);  Test pits between the formerly active steam line and the former Building #10 (GRD Survey #GPM-034); and  Former Building #10 Pad perimeter characterization (GRD Survey #GPM-044. Results indicate that elevated radiation has been encountered in a majority of excavation Phases 3 and 4 as well as to foundation areas of the former Building #10. These areas are being remediated under the supervision of LATA and GRD. Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 5 Continued screening is being performed as each new layer is exposed. Field screening is being used to characterize and segregate excavated material for disposition. Pre-excavation and post-excavation readings are being collected to document radioactivity levels in excavated areas. Any intrusive excavation work performed within the BCP Site Boundary prior to the issuance of a Certificate of Completion will be scanned with appropriate radiation meters as the excavation proceeds. Each truckload of excavated material will be scanned for radiation prior to the trucks leaving the Site. Site-Wide Gamma Walkover Survey GRD performed a gamma walkover survey of all areas within the BCP Site Boundary that were not previously screened during RI investigation activities and/or building construction excavation activities to evaluate these remaining areas for elevated radiation. A Ludlum Model 2221 meter with a 44-10 probe (sodium iodide) was coupled to a Global Positioning System (GPS) unit and radioactivity readings were measured and their locations recorded. Site gamma walkover survey data were mapped by GRD to facilitate identification of areas of elevated radiation. The results of the Gamma Walkover Survey effort are presented in Figure 3 (Attachment A). Some areas within the BCP Site Boundary are currently not available for gamma walkover scanning due to various Site construction activities. These areas will be scanned when they become available in the future. While current data do not suggest that these other areas will be a concern, any areas that become available for scanning prior to preparation of the IRM/Alternatives Analysis (AA) Report will be required to be scanned with the results presented in the Final Engineering Report (FER). Any areas that become available for scanning after preparation of the IRM/AA Report will be addressed in the Site Management Plan (SMP). Radiological Zones Cumulative review of investigation results from the sources described above has resulted in the identification of seven radiological (rad) zones in areas outside of the main building excavation area. These seven rad zones are presented in Figure 2 (Attachment A). Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 6 Laboratory Analysis of Samples Selected samples were submitted to American Radiation Services, Inc. of Port Allen, Louisiana (ARS) on an as-needed basis as determined by NYSDEC and/or NYSDOH specialists in radiation and GRD’s radiological technicians. ARS is a laboratory specializing in environmental radiation analytical services and holds accreditation through the National Environmental Laboratory Approval Program (certification number E87558) and the Louisiana Environmental Laboratory Approval Program (certification number 01949). Based on input from the NYSDEC, selected samples were submitted for analysis by gamma spectroscopy, alpha spectrometry, and/or isotopic uranium and thorium. Results to date suggest that the main contributing elements are radioactive uranium, thorium, and radium. These analytical results are consistent with radioactive slag and slag-like material associated with historical processes involving phosphorus ores in western New York State. Data from laboratory analysis of samples for radiation collected at the Site will be presented in the upcoming Remedial Investigation (RI) Report. REMOVAL OF RADIOLOGICALLY-AFFECTED MATERIAL The investigation results were evaluated against measured background levels at the Site and approved cleanup criteria to evaluate an appropriate scope of the radiological remedial action. After consultation with the NYSDEC and the NYSDOH, excavation and off-Site disposal at a permitted disposal facility located out-of-state has been selected to remediate areas of elevated TENORM within the BCP Site Boundary. Details of the removal approach for radiologically-affected materials generated at the Site are presented in Attachment C. Excavation activities are being directed by LATA and observed by a LATA Radiation Safety Officer. Excavated soil is being screened by GRD technicians using visual assessment and a Ludlum Model 2221 meter with a 44-10 probe (sodium iodide). Continued screening is being performed as each new layer is exposed. Field screening is being used to characterize and segregate excavated material for disposition. Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 7 Excavation will continue until excavation guidance values are achieved. Excavated materials are being placed directly into trucks or other approved waste containers, or are being temporarily staged at the Site for later loading and transport. The exterior of each truck or container is being evaluated for radioactivity prior to moving the equipment and containers from controlled areas. WASTE TRANSPORT AND DISPOSAL Details of the management, transportation, and disposal of radiologically- affected soil and waste generated at the Site are presented in Attachment E and Attachment F. Excavated materials are being direct-loaded into trucks or temporarily staged at the site for later loading and transport. Designated loading areas are being lined with plastic sheeting to control any spillage of soil during the loading process and surface water/precipitation impacts. These designated waste areas are moving along with the movement of soil excavation activities. These areas are designated as radiological control areas and bounded with rad rope and appropriate signage. Waste will be sampled as necessary for profiling, re- surveyed if necessary, and transported from the Site to an approved disposal facility using standard (e.g., non-hazardous) waste manifest forms and procedures. Soil management by categories was originally summarized in the Soil Excavation IRM Work Plan dated June 2011 to provide information on the type of excavated materials anticipated during the project, field observation criteria, and sampling and analysis requirements. This table has been updated to incorporate the handling, management, and off-Site transport and disposal of radiological waste from the Site (Attachment H, Table 1). CONFIRMATION SOIL SAMPLING As previously approved by the NYSDEC and NYSDOH, the focus of the radiological investigation and removal effort is based on field instrumentation techniques using a Ludlum Model 2221 meter with a 44- 10 probe (sodium iodide) and the professional judgment of LATA and GRD radiological technicians and NYSDEC and NYSDOH specialists in radioactive materials removal. Therefore, collection of confirmation soil samples for laboratory analysis will not be performed subsequent to the completion or radioactive materials removal. Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 8 QUALITY ASSURANCE/QUALITY CONTROL If deemed necessary by the NYSDEC and/or NYSDOH, samples will be collected for laboratory analysis at selected locations based on the professional judgment of NYSDEC and NYSDOH specialists in radioactive materials removal. Any samples collected at the Site for laboratory analyses will be analyzed at an approved environmental laboratory by gamma spectroscopy or other analysis as deemed appropriate by the NYSDEC. As requested by the NYSDEC, reporting for gamma spectroscopy analysis will be limited to radioactive isotopes of uranium, thorium, and radium. SITE RESTORATION Removal is primarily being performed in areas that are being substantially modified as part of the ongoing construction of the new mill. Therefore, restoration will not be required in these areas. Areas of radiological removal that will not be substantially modified as part of the ongoing construction project will be restored to a grade and condition consistent with the pre-existing condition and/or with Greenpac’s future contemplated use of the areas. PROJECT SCHEDULE Removal of radiological hotspots outside of the main excavation areas is planned according to the tentative project schedule outlined below. The proposed schedule is subject to modification based on weather and other Site work conditions encountered. Rad Zone Estimated Timing of Soil Removal R-6 15 October to 11 November 2011 R-7 27 October 2011 R-4 7 November to 16 December 2011 R-5 7 November to 9 December 2011 R-2 28 November to 1 December 2011 R-3 28 November to 1 December 2011 R-1 3 December to 16 December 2011 CSX Parcel To be determined (if necessary) Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 9 PROJECT CLOSEOUT Pre-excavation and post-excavation readings are being collected to document radioactivity levels in excavated areas. Pre-removal and post removal data will be provided to the NYSDEC and the NYSDOH as Site work progresses to facilitate concurrent regulatory review and input regarding Site work and operations. Updates will also be provided during weekly site meetings to obtain timely NYSDEC and NYSDOH review and comment. Radiological investigation data will be summarized in the RI Report and radiological removal data will be summarized in the IRM/AA Report and/or the FER. As noted above, some areas within the BCP Site Boundary are currently not available for gamma walkover scanning due to various Site construction activities. These areas will be scanned when they become available in the future. While current data do not suggest that these other areas will be a concern, any areas that become available for scanning prior to preparation of the IRM/AA Report will be required to be scanned with the results presented in the FER. Any areas that become available for scanning after preparation of the IRM/AA Report will be addressed in the SMP. All of these reports and plans will be submitted to the NYSDEC for review and approval. Thank you and please contact the undersigned if you have any questions or comments. Sincerely, Jon S. Fox, P.G. Senior Consultant John Kuhn Partner-in-Charge Addendum to Soil Excavation IRM Work Plan.doc Michael J. Hinton, P.E. Addendum to Soil Excavation IRM Work Plan Former Mill No. 2 Site – Niagara Falls, New York NYSDEC BCP Site Number C932150 23 December 2011 Page 10 Attachment A – Figures Attachment B – LATA Professional Profiles Attachment C – LATA Site Operations Plan Attachment D - LATA Site-Specific Radiological Safety Plan Attachment E – LATA Waste Management Plan Attachment F – LATA Transportation and Disposal Plan Attachment G – Selected GRD Survey Reports Attachment H - Table Cc: Luc Nadeau (Greenpac Mill, LLC) Lucie-Claude Lalonde (Greenpac Mill, LLC) Yves Levesque (Cascades) Francois Mayrand (Cascades) Kamala Rajan (MiniMill Technologies) Ken Carter (MiniMill Construction) Elgie Harrison (MiniMill Technologies) Srini Balaji (MiniMill Technologies) Laurie Colson (MiniMill Technologies) Randy Bartels (MiniMill Construction) Craig Slater, Esq. (Harter, Secrest, & Emery) Gregory Sutton, P.E. (NYSDEC) James Charles, Esq. (NYSDEC) Tom Papura (NYSDEC) Cynthia Costello (NYSDOH) Matt Forcucci (NYSDOH) Steven Bates (NYSDOH) John Kuhn (ERM) John Mohlin, P.E. (ERM) Dave Myers, C.G. (ERM) John Trendowski, P.E. (C&S Engineers) Jason Brydges, P.E. (LATA) Ron Voorheis (LATA) Stuart Pryce (GRD) Addendum to Soil Excavation IRM Work Plan.doc