| 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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