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Phase1 - Environmental Site Assessment
Report



 
 


6.2


Recommendations

 
 

Based on the results of the Phase 1 ESA of the Former Sydney Steel Plant Lands, and the potential environmental issues identified in Table 6-1, SEACOR Environmental has prepared the following recommendations:

Decommission and dispose of all petroleum storage tanks that have been out of service for 24 months or more.
As an extension of the ongoing decommissioning and storage tank removal program at the Sydney Steel Plant site, and in accordance with the Nova Scotia Petroleum Storage Tank Regulations, all tanks of capacity greater than 4000 litres that have been out of service for more than 24 consecutive months must be cleaned and disposed in a manner set forth in the "Nova Scotia Construction and Installation Standards for Petroleum Storage Tank Systems”. For the Sydney steel plant, this includes the four 13,000,000 litre tanks in the Tank Farm, the four 55,000/80,000 litre tanks located on lands recently acquired from DTPW , and all associated product piping. Two smaller aboveground tanks associated with the Old Rail Mill and Old Motor House were cleaned out as part of the 2001 decommissioning program, but should be removed and disposed.

Decommission all petroleum storage tanks not intended for future use.
As an extension of the ongoing decommissioning and storage tank removal program at the Sydney Steel Plant site, and in accordance with the Nova Scotia Petroleum Storage Tank Regulations, all tanks of capacity greater than 4000 litres that have been out of service for more than 12 consecutive months must be emptied of their contents and cleaned in a manner set forth in the "Nova Scotia Construction and Installation Standards for Petroleum Storage Tank Systems”. For the Sydney steel plant, this includes the Reheat Furnace bunker ‘C’ tanks.

Assess potential contaminant migration in priority areas.
Possible contamination sources in specific areas of the site may contain free product (i.e., liquid petroleum in the ground) that may be impacting adjacent lands and watercourses (such as Muggah Creek and Sydney Harbour). These areas include the High Dump, the Tank Farm, the Mobile Yard, and major process sewers in the Mills Area, Production Support Area and Steel Production Area. The investigation of these potential issues should be made a priority.

Prepare an approach for the remediation of the slag disposal areas, including the High Dump.
The existing Industrial Approval for SYSCO allows for the disposal of stable industrial wastes in the High Dump, including mill scale, refractory brick and slag. In the decades prior to 1989, disposal at the High Dump was not regulated, and anecdotal evidence strongly suggests that hazardous materials such as petroleum-impacted sludge were disposed therein. SYSCO’s Industrial Approval stipulates that a plan should be developed to address the disposal of petroleum hydrocarbon contaminated sludge at the High Dump. An approach for the environmental assessment, stabilization and reclamation of the High Dump should be developed in 2002.

Activities such as a cleanup of surface debris and waste materials could be initiated while the overall reclamation plan is developed. It is recognised that many considerations will figure into the design of a reclamation or closure plan, including the environmental condition of the High Dump area, the demand for industrial land on the site, the cost of various cleanup options and combinations of options, and the technical feasibility of various reclamation options.

If excavation and removal of High Dump material is selected as a component of the plan, a protocol should be developed to govern the removal and handling of materials, and for the identification and management of unknown or hazardous materials that may be encountered during excavation. The Solid Waste-Resource Management Regulations govern the disposal of waste materials in Nova Scotia.

If closure of the High Dump is chosen, an assessment of the environmental condition of the area should be conducted, followed by an evaluation of the need for remediation of specific areas, construction of hydrologic controls, and installation of vegetative cover.

Develop and implement a strategy for conducting a Phase 2 Environmental Site Assessment of the study area.
The results of this Phase 1 ESA have identified potential environmental issues in all of the 36 SCUs contained within the study area. In order for any portion of the properties to be leased or sold, environmental testing will be required. The need for such testing will be driven by due diligence requirements, either on the part of SYSCO, the lessee, or a lending institution. The Phase 2 ESA program should be carried out in accordance with the requirements of the Guidelines for the Management of Contaminated Sites in Nova Scotia that are administered by NSDEL.

Conduct hazardous material surveys in all remaining site buildings.
Environmental decommissioning of buildings slated for demolition in early 2002 is ongoing. Large numbers of lubricant and chemical containers have been removed from all site buildings. As an extension of this work, hazardous material surveys should be conducted in all other vacant buildings, in order to identify situations that require stabilization (e.g., chemical storage tanks), allow for the preparation of environmental decommissioning plans and facilitate reuse of the buildings. Hazardous materials, especially liquids and compressed gases, represent a significant environmental liability as tanks and containers located in inactive structures tend to deteriorate rapidly.

Continue with the systematic decommissioning and removal of surplus structures.
Included in this process is the preparation of Environmental Decommissioning Plans, and the removal and disposal of all hazardous materials in accordance with applicable regulations.

Identify all PCB-containing transformers, circuit breakers and capacitors.
In the 1990s, a comprehensive testing program of all in-service pad-mounted electrical transformers was undertaken at SYSCO. All PCB-containing transformers included in the inventory are inspected on a regular basis by Ernst & Young personnel (pers. comm., J. MacLean). Records of non-PCB containing units were not maintain, therefore testing of these units will be required to confirm that they do not contain PCBs. In addition, there is potential for additional small-volume units to be located in older areas of the plant. A survey of all remaining electrical equipment in the study area should be conducted in conjunction with the hazardous materials surveys recommended above in order to meet the requirements of the Federal PCB Storage Regulations, and the Nova Scotia PCB Management Regulations. The survey will include dielectric fluid testing for PCB content, and inclusion of all units in SEACOR’s transformer inventory. Following identification, surplus PCB-containing equipment should be decommissioned and removed from the site as a liability reduction effort. Equipment that is to remain on-site should continue to be inspected and maintained on a regular basis.

Identify and decommission all compressed gas lines.
This includes coke ovens gas, oxygen, and propane lines located primarily in the Mills and Steel Production Areas. PAH impacts, volatile compounds and flammable residues may be associated with the coke ovens gas lines.

Identify and decommission all wastewater treatment facilities not intended for future use.
Included in this process is the removal and disposal of wastewater and wastewater sludge from the Abandoned Cooling Pond, pits in the U-Mill, Donovan’s Hole.

Continue with the removal of waste and surplus materials from the site.
This includes hazardous materials, miscellaneous waste and debris piles located around the site, scrap metal, rail cars, aggregate, and surplus equipment. The Solid Waste-Resource Management Regulations govern the disposal of waste materials in Nova Scotia.

Stabilize Eroding Surfaces through the implementation of Erosion and Sediment Controls.
Certain slopes within the steel plant site show signs of erosion, especially in the vicinity of the High Dump. Large areas of level grade are covered with granular materials that are prone to dust creation. Due to the presence of stormwater catchbasins cross the site, the stabilization of such surfaces should be considered, through such techniques as the establishment of vegetation.

Conduct a geophysical survey in all former production and production support areas.
Although this technique presents great potential as a valuable utility identification tool, further evaluation of this recommendation is required prior to implementation due to the nature of fill materials present throughout the site. These fill materials generally contain significant levels of ferrous compounds that tend to interfere with the instruments. If feasible, such a survey would ideally be conducted prior to the start of a Phase 2 ESA activities, and in conjunction with a thorough review of infrastructure records aid in the identification of underground utilities and structures.

To aid in the planning of the above recommendations, specifically Phase 2 Environmental Site Assessment activities, Table 6-3 provides a matrix of investigation techniques applicable to each SCU. While a variety of techniques will be needed to effectively investigate many of the SCUs, the information is put forth as a general guide or suggestion of which techniques may be appropriate. The design of a Phase 2 ESA sampling program is beyond the scope of this report.

Many of the above recommendations will involve considerable planning to develop an effective approach, and considerable time to execute effectively. Significant costs will also be associated with the implementation of many of the recommendations. Furthermore, it is also understood that the implementation of certain recommendations may not be possible in the short term due to the ongoing liquidation of assets and demolition program at the site.

With these factors in mind, SEACOR has developed suggested criteria for the prioritisation of the preceding recommendations. The criteria are listed in order of relative importance, as follows:

1. The significance of the recommendation in relation to potential health and safety risks and associated liability.
2. The logistical practicality of implementing the recommendation, considering restraints introduced by the ongoing asset liquidation.
3. Recommendations that address regulatory violations.
4. The significance of the recommendation in relation to potential environmental risk and liability.
5. The significance of the recommendation in relation to facilitating the reuse of individual site areas.
6. The potential for the recommendation to decrease the likelihood of vandalism and theft.
7. The potential for the recommendation to improve the aesthetic quality of the site.

The above recommendations should be carried out in accordance with the recommendations of the focused Sydney Steel Corporation Phase I ESA completed by SEACOR Environmental in July 2001. All environmental testing, waste management, abatement and remediation programs will be subject to applicable regulatory guidelines, permitting and environmental compliance standards. All programs must incorporate environmental protection, health and safety and waste disposal/recycle planning. It is anticipated that all environmental issues as identified in this report can be addressed using conventional site assessment, remediation, site management, waste management, and demolition methods with minimal risk to human health and the environment.


 
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