Due to additional questions from Middleport residents about the FMC proposed Corrective Action Management Unit (CAMU), FMC has submitted an article for posting on the CIG web site. It explains what type of material will be placed in the CAMU and presents questions and answers pertaining to the use of a bottom liner, the environmental effect on the area, soil source, if it's hazardous and long term responsibility. Click the Read Full Article link below to read the article. Please post your comments at the end.
In March of this year, FMC submitted an application to the Agencies requesting designation of a portion of the FMC Middleport plant site as a Corrective Action Management Unit, or CAMU.The materials that would be managed in this CAMU would be soils from remediation projects, together with some debris such as concrete or vegetation.

There will be no hazardous waste, no liquids, no trash, and no industrial waste materials placed in the CAMU. The levels of contaminants, such as arsenic, in the soils placed in the CAMU would be the same as those in yards, etc., from which the soils were excavated. The area where the CAMU would be situated has been used since the mid-1990s for management of these same remediation waste materials (soils).

The United States Environmental Protection Agency and delegated states are authorized under federal regulations to designate CAMUs, subject to controls and conditions, to implement faster and more aggressive cleanups than other remedial options while also complying with all applicable Resource Conservation and Recovery Act (RCRA) requirements.

The CAMU application is under review by the Agencies. There will be public comment opportunities and a community meeting/review session with the Agencies. Meanwhile, FMC has been providing information to the community on the proposed CAMU over the past year and a half, and will continue to do so.

FMC believes that this Web site provides an ideal opportunity for the company to answer some questions that have been raised recently by members of the community about the CAMU.

Question 1: Why has FMC proposed an alternative design for the CAMU that does not include construction of a liner under the CAMU?

The RCRA regulations allow a CAMU design without a bottom liner if the CAMU will be located within a contaminated area and if any arsenic and other hazardous constituents present in the materials placed in the CAMU will not jeopardize or adversely affect the long-term remedial goals of the FMC plant site.

In more simple terms, a liner is not needed to meet RCRA requirements. Soil in the CAMU will be placed atop the existing ground surface and will not be in contact with groundwater (found below the ground surface). A design will be developed to control drainage and manage surface water (from rain, snowmelt, etc.)

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.

Materials that have been and will be placed in the proposed CAMU consist of nonhazardous waste soil and debris removed as part of the FMC Middleport RCRA corrective Action program. Generally, they contain arsenic levels below, or similar to, levels found in the subsurface soils beneath the northern portion of the FMC plant site.

Question 2: Will the remediation soil and debris in the proposed CAMU area have an adverse affect on the environmental conditions and long-term remedial goals of
the FMC plant site?

There are many reasons why there will be no adverse effects from a CAMU on the plant site, including:
a) No hazardous wastes, liquid wastes, municipal wastes, or wastes from the FMC plant operations will be placed in the CAMU.
b) The remediation-generated soil and debris have been/will be placed on top of the existing ground surface, above the water table (the underground surface level where water completely saturates the soil or bedrock).
c) Existing soil and groundwater show that there is low potential for arsenic to leach. Arsenic tends to bind to soil particles and is typically immobile. This is especially the case with the relatively low average arsenic concentrations found in the off-site remediation soils.
d) Any water that may percolate through the soils placed in the CAMU and reach the groundwater beneath the CAMU will likely be contained by FMC’s existing groundwater collection and pumping systems.
e) Groundwater beneath and around the proposed CAMU will continue to be routinely monitored by FMC’s Groundwater Monitoring Program.
f) The CAMU, as designed, will have a cover system that will shed rainwater and prevent wind and water erosion. This cover will consist of a lightweight fabric topped with one foot of clean soil and vegetated. Rainwater runoff from the cover surface will be managed on the plant site and discharged in accordance with the plant’s water discharge permit.
g) The existing plant security and procedures will maintain the CAMU cover system and prevent unacceptable exposures to the materials placed in the CAMU.

Question 3: Will remediation soils from outside of the Village of Middleport be placed in the CAMU?

The RCRA regulations allow FMC to place remediation-related soil from all FMC Middleport RCRA Corrective Action areas in the CAMU. This includes soils that may have to be excavated from the north of the Pearson Road study areas.

However, with the concurrence of the Agencies, FMC expects to proceed with any necessary remediation of the study areas south of Pearson Road (that is, within the Village) before addressing any areas north of Pearson Road.

Additionally, FMC understands community concerns about the transportation of soils through the Village. Any soils that would be removed from remediation projects outside of the Village would not be transported to the CAMU on village owned and maintained streets. As in the past, FMC will utilize designated truck routes (e.g., Carmen Road and
Route 31) to transport soil to the CAMU.

Question 4: What happens when the CAMU is filled?

The volumes of soil that will need to be removed from the study areas south of Pearson Road and north of Pearson Road cannot be determined until the Corrective Measures
Studies have been completed for those areas, and a corrective measure alternative have been selected.

This means that FMC does not know if the CAMU will have sufficient capacity to hold all remediation soils from study areas south of Pearson Road and north of Pearson Road.

Since the actual quantities of remediation soil to be generated is not known, FMC has proposed construction of the CAMU in three phases, with a maximum height of 35 feet in all three phases. If the capacity of the CAMU is exhausted before necessary excavation has concluded, FMC will then have to find an alternative location for disposal of any remaining remediation soil (e.g., use an off-site commercial landfill facility).

Question 5: Isn’t the CAMU technically a hazardous waste dump?

No, it is not. FMC has proposed that only “non-hazardous” remediation soil and debris be placed in the CAMU. Any remediation soil and debris will be tested to ensure that it meets the RCRA “non-hazardous waste” thresholds. Any soils that meet the RCRA “hazardous waste” thresholds would be transported to a permitted, commercial disposal
facility.

Question 6: Who would be responsible for the CAMU if the Middleport plant closed?

FMC Corporation will continue to be responsible if the Middleport Plant is closed. The RCRA regulations require FMC to provide financial assurance (through a bank letter of credit, trust fund, surety bond or insurance) for costs associated with the continued operation, inspection, maintenance and monitoring of remediation systems at the FMC Plant Site (generally for a 30-year period).

These remediation systems will include groundwater collection and pumping systems, the water treatment plant, the North Site Cover, and the CAMU. If FMC Corporation goes out of business, the Agencies would likely take responsibility for the management of the environmental conditions at the site and would utilize the financial assurance established by FMC to pay for the activities.

FMC remains committed to full public input as the CAMU process unfolds.

There will be a Coffeehouse event at the FMC Neighborhood House, 17 Vernon Street, in Middleport at 7 p.m. on Thursday, May 29. Residents are encouraged to attend to learn more details and ask their questions about the CAMU.