NCD001810365_19980220_Martin-Marietta Sodyeco Inc. (Clariant)_FRBCERLA RI_Remedial Investigation Area D Sampling Plan-OCR

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Clarlant Co,;:•
Mt. Holly Plant
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P.O. Box 669246
Charlotte, NC 28266 Q\,J
704.827.9651 11,-~•-
~ C1ariant RECEIVED
FEB 25 1998
SUPERFUND.SECTION
February 20, 1998
Mr. Michael F. Townsend
Remedial Project Manager
Waste Management Division
U.S. Environmental Protection Agency, Region IV
61 Forsyth Street
Atlanta, Georgia 30303
Re: Clariant Corporation -Mount Holly East Plant
CERCLA Area D Sampling Plan
Dear Mr. Townsend:
Certified Mail
Z 188 183 918
Please find the attached Final Soil Sampling and Analysis Plan, CERCLA Area D (February 19,
1998) prepared by Law Engineering and Environmental Services, Inc. ("Law"). This sampling
plan basically involves the resampling of the CERCLA Area D "arc" of soil contamination
described in the Record of Decision and sampling the surficial soils around the perimeter of the
former fuel oil storage tank.
Clariant is submitting this plan for approval by the USEP A, Region IV Waste Management
Division. Please understand that Clariant would like to receive USEP A, Region IV approval in
writing before proceeding with the sampling plan. Once the written approval is received, Clariant
will contract with Law to perform the sampling described in the plan. The soil samples will then
be submitted to a North Carolina approved laboratory (probably General Engineering
Laboratories, Charleston, South Carolina).
Also per your-voice mail message of February 12, it is now confirmed that the Fire Training Area·
is not a part of CERCLA Area D. Clari ant understands that this area is a stand alone Solid Waste
Management Unit identified in the site's RCRA Part B permit.
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Should you have any questions regarding the sampling plan, please call me at [phone].
I look forward to your response.
Very truly yours,
)iJli b fi~
Victor B. Ethric!ge
Senior Environmental Chemist
cc: P. Rack (USEPA, Region IV)
R. McElveen (NCDEHNR)
K. Pathan (NCDEHNR)
M. Griffin (Clariant)
· B. Grier (Clariant)
G. Sanderson (Clariant)
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FINAL SOIL SAMPLING AND ANALYSIS PLAN
CERCLA AREA D .
CLARIANT CORPORATION
-MOUNT HOLLY, NORTH CAROLINA
Prepared for:
Clariant Corporation
by:
Law Engineering and Environmental Services, Inc .
. Charlotte, North Carolina ·
. LAW Project 30100-5-0036-02-900
February 19, 1998 _
1
Clur;unt Corporation -Final Sui9mpling & Analysis Plan
UW Project J0I00-5-0036-1/2-900 • February 19, 1998
TABLE OF CONTENTS
Page
I. PROJECT INFORMATION .................................................................................. 1-1
2. SITE DESCRIPTION ......................................... : ................................................. 2-l
2.1 INTRODUCTION ................................................................................... 2-1
2.2 AREA GEOLOGY .................................................................................. 2-l
3. SOIL SAMPLING PLAN ...................................................................................... 3-l
3.1 SAMPLING RATIONALE ........................................................................ 3-l 3. I. I "Arc" Defined in the Record of Decision ............................................... 3-1 3.1.2 Surficial Soils Around the Perimeter of the Former Fuel Oil Tank ................ 3-1 3.2 SITE STAGING ACTIVITIES AND PREPARATION ..................................... 3-2
3.3 SOIL SAMPLE LOCATIONS .................................................................... 3-2
3.3.l Area D "Arc" ............................................................................ .' .... 3-3 3.3.2 Former Fuel Oil Tank Perimeter .......................................................... 3-3 3.4 SAMPLE PREPARATION ........................................................................ 3-3
3.5 SOIL SAMPLING PROCEDURES .............................................................. 3-4
3.5.l Sampling Devices and Jars ................................................................. 3-4 3.5.2 Sample Collection ............................................................................ 3-4 3.6 SAMPLE DESIGNATION ........................................................................ 3-5
3.7 DOCUMENTATJON ............................................................................... 3-5 3.7.l Field Sampling ................................................................................ 3-5 3.7.2 Chain-of-Custody ............................................................................ 3-6 3.8 SAMPLE CONTAINERS AND SHIPPING ..................... : ............................. 3-7
3.9 MEASUREMENTS ................................................................................. 3-7
3.10 DECONTAMINATION PROCEDURES ..................................................... 3-7
3.11 QUALITY ASSURANCE AND QUALITY CONTROL ................................. 3-8
4. SOIL ANALYSIS ............................................................................................... 4-l
5. REPORTING AND SCHEDULE ............................................................................ 5-l
FIGURE
Figure 1 -Area D "Arc" Location Map
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• Clarialll C()rporation -flnul Soil Sampling & Analysis Plan • February /9, /998 LAW Project 30l00-5-0036-02-900
I. PROJECT INFORMATION
Clariant Corporation Mount Holly East Plant is a 1,500-acre site containing active manufacturing,
administration and storage facilities. The East Plant originally produced liquid sulfur dyes, but later
expanded into intermediate and specialty chemical production for various industries. In December
1982, the site was placed on the National Priority List (NPL). In February 1986 the United States
Environmental Protection Agency (USEPA) and Sandoz (i.e., former operator of the site) entered
into a Consent Order to evaluate environmental conditions at the site. As a result of this work the site
was found to have five areas (i.e., Areas A through E) which are regulated by CERCLA.
Subsequently, remedial alternatives were evaluated for each of these five areas. The enclosed· soil
sampling and analysis plan addresses CERCLA Area D.
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• • Clariant Corporation~ Final Soil Smnpling & Analysis Phm February 19, /998 LI W Project Jli/00-5-0036-02-900
2. SITE DESCRIPTION
2.1 INTRODUCTION
The Clariant Corporation Mount Holly East Plant is located on North Carolina State Highway 27 in
Mecklenburg County, North Carolina. The East Plant site is bounded by the Catawba River on the
west and Long Creek to the east. The majority of the site is covered by woodlands and grassed areas.
Active manufacturing, administrative and storage facilities cover about 150 acres of the
approximately 1,500-acre site.
Topography within the Mount Holly East Plant manufacturing area is gently rolling. Elevations
range from approximately 570 feet above National Geodetic Vertical Datum (NGVD) near the
Catawba River to about 670 feet above NGVD east of the plant area.
The woodlands which surround the Mount Holly East Plant and the waste treatment areas to the
north, east and south are characterized by small knolls which are dissected by numerous natural
drainage features. Several knolls exceed elevations of 650 feet above NGVD.
The area surrounding the Mount Holly East Plant site is predominantly undeveloped woodland with
some residential and light industrial areas. The Catawba River and Long Creek are the primary
hydrologic features at the site. Long Creek enters the plant site at its eastern boundary and flows
southwesterly across the site before flowing into the Catawba River. Surface runoff from the site
drains primarily into Long Creek, except in the production area where it is channeled to the
wastewater treatment facility.
2.2 AREA GEOLOGY
The Clariant Corporation Mount Holly East Plant site is located in the Piedmont Physiographic
Province, an area underlain by ancient igneous and metamorphic rocks. The Piedmont Physiographic
Province is a generally northeast-trending physiographic belt. The virgin soils encountered in this
area are the residual product of in-place chemical weathering of rock which was similar to the rock
presently underlying the site. In areas not altered by erosion or disturbed by the activities of man, the
typical residual soil profile consists of near-surface clayey soi is and underlying sandy silts and silty
sands. The boundary between soil and rock is gradational. A transitional zone termed "partially
weathered rock" is normally found overlying the parent bedrock. Partially weathered rock.is defined,
for engineering purposes, as residual material with standard penetration resistances in excess of I 00
blows per foot (bpt). Weathering is facilitated by fractures, joints and by the presence of less
resistant rock types. Consequently, the _topography of the bedrock surface is uneven, even over short
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Clur;11nt Corporation -Final Soi,mpling & Anuly.,is Plan
Ll W Project 30100-5-0036-02-900 • February 19, 1998
horizontal distances. It is not unusual to find lenses and boulders of hard rock and zones of partially
weathered rock within the soil mantle, well above the general bedrock level.
Ground water is primarily recharged by rainfall and is contained in the pores of the weathered rock.
Ground water flows toward the major drainage features, such as the Catawba River.
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0 C/(lriant Corporation -Fintll Soil Sllmpling & Analysis Plan • February /9, /998 UW Project 30/00-5-0036-02-900
3. SOIL SAMPLING PLAN
3.1 SAMPLING RA TI ON ALE
3.1.1 "Arc" Defined in the Record of Decision
The "arc" of impacted soil defined by the Record of Decision (ROD) was to be excavated and
incinerated per the remedy specified in the ROD. However, because of concerns that the original
investigation may not have accurately characterized the "arc," Clariant proposed to USEPA that
additional sampling be performed to better delineate any actual impacts within the "arc". A
sampling plan was submitted to USEPA, Region IV, and after receiving comments from the
agency, a revised plan was submitted on March 7, 1997. That plan has not yet been approved or
implemented. In addition, after several years of natural attenuation, Clariant believes that some
natural remediation of constituents may have occurred. Recent discussions with USEPA, Region
IV indicated that the agency agrees with the resampling approach.
Therefore, the first part of the sampling will involve only the "arc". The purpose of the sampling
is to determine whether some or all of the soils within the "arc" are below the ARAR
concentrations, and may not require the remedy specified in the ROD: The sampling plan
presented in Section 3.2.1 is essentially the same plan submitted to USEPA Region IV by Clariant
on March 7, I 994.
3.1.2 Surficial Soils Around the Perimeter of the Fonner Fuel Oil Tank
Per the recent discussions between Clariant and USEPA, Region IV personnel, it was agreed that
the surficial soils around the perimeter of the former fuel oil storage tank would be sampled also.
Samples will be taken at twenty-five (25) foot intervals around the perimeter of the tank. The
. depth of these samples will be from zero (0) to twelve (12) inches.
These samples will also be analyzed for ARAR constituents per the methods described in Section
4.
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C/ari~nt Corpomrion • Final Soil~ling & Analysis Plan LAW Project JOJ00-5-0036-02-900
3.2 SITE STAGING ACTIVITIES AJ"I/D PREPARATION
• February 19, /998
Prior to initiating the sampling events, the following steps will be taken by the responsible on-site
sampling personnel:
I. Review all sampling locations.
2. Assemble and inspect field equipment necessary for sample collection; confirm that equipment is clean and in proper working order.
3. Note and replace items that are in short supply or that are showing indications of wear; maintain an adequate supply of spare parts for sampling equipment.
4. Examine sample shuttles, bottles, and preservatives; contact laboratory if any problems are found.
5. Confirm sample delivery time and method of sample shipment with the laboratory.
6. Establish a sampling team consisting of enough trained people to perform the planned sampling event efficiently and without undue haste.
7. Establish a sampling schedule for the activities of the day.
3.3 SOIL SAMPLE LOCATIONS
The following sampling procedures will be performed and appropriate information will be recorded
in the field book:
• Record the date. time, soil sample coordinate address and person(s) performing the sampling.
• Record observations pertaining to surface soils in the area around the fuel oil tank.
• Measure to the nearest ±0. I ft the comers of the "arc" within which the soil samples are to be collected.
• Locate the surface point _for the soil samples to be collected from within the "arc" around the fuel oil tank. Also locate the ·perimeter soil samples to be collected_ around the fuel oil tank at 25-foot spacings around the tank. ·, ---
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Clari~n/ Corpomtion -Final Soil,mpling & Analysis Plan
LAW Project JOI 00-5-11036-0l-900
3.3.1 Area D "Arc"
• February I 9, I 998
The "arc" within Area D that is to be sampled will be measured out in accordance with the Record of
Decision (ROD) (see Figure I). Semi-permanent comer markers will be used to delineate the "arc".
Sample locations will be determined on site by laying out a surface grid, so that there are IO intervals
on both axes of the plan view. This surface grid will produce I 00 discrete subareas. The specified
depth of excavation is from ground surface to a depth of live feet below ground surface, so the depth
interval will be in 6-inch steps, providing IO intervals in the z-axis.
The 3-axis location of each sample will be determined by using a hand-held calculator with a random
number generator. The random number generator provides 3-place numbers ranging from 0.000 to
0.999. Each number will be multiplied by IO and rounded off to the nearest whole number, and will
be used to specify a coordinate. For example, 0.354 becomes 4, and this number will represent
interval 4 for the particular axis being found. Each individual sample point will have all three axes .
found, before the next sample point is addressed. These coordinate addresses will be documented in
a table format. A plan view (or isometric view) will be made to show the location of each sample so
that they can be cross referenced with the field notes in the field book. These coordinate addresses
and plan view will be included in the final report. A total of live soil samples will be collected from
the Area D "arc" shown in Figure I.
3.3.2 Former Fuel Oil Tank Perimeter
In addition to the live soil samples to be collected within the Area D ·'arc", an additional nine soil
samples will be collected at 25-foot intervals from around the perimeter of the fuel oil tank. The
depth of each of these samples will be from zero (0) to twelve (12) inches below ground surface.
3.4 SAMPLE PREPARATION
Prior to beginning the soil sampling, a section of dean plastic sheeting will be placed at the
location for the proposed soil sample in order to insulate the ground surface from sampling
equipment and vice versa .. Also, disposable gloves will be donned prior to making contact with
soil to be extracted from either a split-spoon sampler or a hand-held auger. ·:,:,.
A. hand or power auger with a split-spoon sampler will be used to collect the soil sample. The
sample bottles will be labeled before the samples are collected, and the identification will be
recorded in a field book by the sampler at the time of sample collection_.
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Clar;unt Corpormion. Fint1I Soil aling & Ana(rsis Plan
L1W Project 30100-5-0036-1/2-901/
3.5 SOIL SAMPLING PROCEDURES
3.5.1 Sampling Devices and Jars
• February 19, 1998
The North Carolina approved laboratory will provide necessary sample containers and will be fully
responsible for preparing the sample containers so that they comply with applicable container
preparation methods and quality assurance procedures.
Either a hand-held auger or split-spoon samplers will be used for extracting soil from each of the soil
sample locations marked on the ground. The auger and the spilt-spoon sampler will be cleaned
before each use by scrubbing with water/detergent and a stiff brush, a tap water rinse, a pesticide-
grade isopropyl alcohol rinse and a final rinse with de-ionized water. Commercially prepared
precleaned brown glass bottles with Teflon cap liners will be used to collect the samples.
The following information is to be documented on the sample jar identification label:
• Sample location number
• Date and collection time
• Type of sample
• Preservatives used, if any
• Name of sampler
• Project number
• Analyses requested
Sample labels will be filled out with indelible ink. If the field sampler determines that additional
information is pertinent to the sample being taken, such data will be recorded in the site field book.
3.5.2 Sample Collection
A new set of disposable gloves will be worn for each soil sampling. The split-spoon sampler or
hand-held auger will be decontaminated after each use.
Split-Spoon Sampler
• _The auger bit will be drilled down to the depth of the proposed sample. The split-spoon sampler will
be hammered into the underlying soils at the base of the auger hole to collect a relatively undisturbed . soil sample. The split-spoon sampler will provide an 18-inch long soil sample_ with 1.4 inch
diameter. The soil samples will be tested for volatile organic compounds identified in the March 7,
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C/a;iant Corporation -Final Soi,.mpling & Analy.,is Plan
LAW Project J0/lll/-5-0036-02-900
1994 submittal to the USEPA.
Hand Auger
• February 19, 1998
Borings will be advanced by manually twisting a sharpened auger into the ground. The soils
encountered will be identified in the field from cuttings brought to the surface by the drilling process.
When the desired sample depth is reached, the auger will be removed and representative portions of
the soils encountered will be sealed in glass jars and transported to the laboratory. Soil descriptions
will be recorded in the field book.
Immediately after collection, each soil sample will be preserved according to USEPA Region IV
protocol; typically, preservatives are added to sample jars at the laboratory. Sample containers and
preservatives will ?e in accordance with test methods. Samples requiring preservation at
approximately 40c will be placed in a cooler with "freezer-pacs" or bags of ice to maintain sample
integrity. Any preservatives to be added in the field will be so directed by the laboratory according to
USEPA protocol. Shipment to the laboratory by overnight courier or direct delivery will be done if
necessary to meet analytical holding time restrictions.
J.6 SAMPLE DESIGNATION
Each sample collected during the project will be assigned a unique designation code number. The
sample designations will consist of an alpha-numeric code, which will identify the sample type,
location and sampling event. The following sample type will be used:
SS -soil sample
If duplicates are taken they will be assigned a unique location code not immediately identifiable with
the sample location to avoid potential laboratory analytical bias. The sample will be indicated as a
duplicate in the site field book.
3.7 DOCUMENTATION
J_7,l Field Sampling
The sampling team will record the following information at each sampling location in the site field
book:
• Day/Date/Weather Conditions
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C/ar;ant Corporation -Final Soil.piing & Ana(.-sis Plan Ll IV Project J0I00-5-01136-112-901/
• Approximate Air Temperature
• Sampling Team Members
• Type of Sampling Equipment Used
• Physical Properties of the Samples: color, texture, odor
• Types of Sample Jars and Preservation Used
• February 19, 1998
Each sample will have a corresponding site field book entry. The following items are the
responsibility of the field sampler to record in the site field book:
• Identify properly the exact location of the sample taken;
• The date on which the sample was obtained;
• Time of sample collection; the type of sample;
• Whether or not a preservative has been used, and if so what type;
• The name of the sampler; and the project number.
• A unique sample I.D. name or number
• Sample type (composite or grab water)
• Analyses for which sample was collected
• Additional comments as necessary
3. 7.2 Chain-of-Custody
To document sample possession from the time of collection until the sample has been received by the
laboratory's sample custodian, a chain-of-custody record will be completed by the field personnel and
accompany every sample shipment. It is extremely important to maintain proper custody of the
samples. While in the field, the care and custody of the samples are the field sampler's personal
responsibility until the samples are transferred or properly dispatched. This chain-of-custody
procedure will be followed during all sampling assignments, regardless of the ultimate use of the
sample data.
To provide for proper identification in the field and proper tracking in the laboratory, all samples will
be labeled in a clear and consistent fashion. Sample labels are to be waterproof, and have a pre-
assigned unique number. Field activities will be recorded into the site field book (see Section 3.6.1).
The site field book. along with the chain-of-custody record, must contain sufficient information to
allow reconstruction of the sample collection and handling procedures at a later time.
Each sample must have a corresponding entry on a chain-of-custody record. The forrn is to include:
• Site name·
• The unique sample I.D. name or number
• Sample type
• Date and time of the collection
• Number of containers
Cla;iant Corporation • Final Soi.mpling & Analysis Plan
LAW Project 30/00-5-0036-//2-900
• Parameters for which analyses are requested
• Signature of sampler(s)
• Signature of persons involved in the chain-of-custody
• Condition of samples upon arrival at the laboratory•
•Noted on Log-In Form, by laboratory.
• February 19, /998
In cases where the samples leave the immediate control of the sampling team (e.g .. shipment via a
common carrier), the shipping container must be sealed with custody tape.
Copies of field notes and chain-of-custody forms will be submitted to NCDENR along with
analytical results in the final report (Section 5.).
3.8 SAMPLE CONTAINERS AND SHIPPING
The North Carolina approved laboratory will provide all the necessary sample containers. Sample
containers will be pre-cleaned and contaminant free. The cleanliness of a batch of containers is to be
verified by the laboratory prior to use. The laboratory will supply the necessary preservation
solutions. QNQC of sampling procedures is discussed in Section 3.10.
3.9 MEASUREMENTS
The location of the soil sample will be measured to the nearest ±0.1 foot with a measuring tape as
discussed in Section 3.2.
3.10 DECONTAMINATION PROCEDURES
Sampling equipment (split-spoon sampler, hand auger, trowel, etc.) will be decontaminated between
samples and measurements using the following procedures:
• washed with tap water and laboratory grade phosphate-free detergent solution
• rinsed with tap water
• rinsed with pesticide-grade isopropyl alcohol
• rinsed with de-ionized water
Sampling equipment which is decontaminated at a location other _than the sampling location will be
wrapped in aluminum foil (shiny side out) to reduce contamination poiential during transportation to
the sampling location. As appropriate, certain instruments (such as trowel) will be placed in a new
polyethylene (plastic) bag to reduc_e the possibility of contamination during storage or transit.
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Cl~riam Corporation.-Fi11lll So.mpling & Analysis Plan
UW Project 30100-5-0036-02-900
3.11 QUALITYiASSURANCE AND QUALITY CONTROL
• February /9, 1998
Quality assurance-and quality control will be maintained by following the procedures detailed in this
plan and by means of analytical testing performed during the collection of each soil sampling event.
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Clarjllnt Corporation -Final Soil.piing & Ana(rsis Plan
LAW Project 30/00-5-0036-02-900
4. SOIL ANALYSIS
• February /9, /998
Soil samples will be subjected to a TCLP zero-headspace extraction, and the liquid portion will be
used as the leachate surrogate. Analysis will be according to EPA SW-846/Contract Laboratory
·1 Protocols (CLP) methods for the ARAR constituents as follows:
Lontammant A" A 1,1 ueanup Goat (ug/L)
·1 nchloroethylene 1-./
I etracnioroethylene U.M
Lhlorobenzene OU
ethyl tlenzene MU
I ,2-u1cn1orobenzene 4UU
I oluene 2,uuu
.Xylene 44U
Although polynuclear aromatic hydrocarbons are on the ARAR list, Clariant does not propose
analyzing for them. They have never been found in ground water samples at the Mount Holly East
Plant. The list above was approved in the document "Soil Remedial Technologies and Treatability
Study Workplan, Sodyeco Site" (Engineering-Science, May 1990).
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Clar;t1nt Corporation -Fint1I Soil e,/i,,g & ,1na(l'sis Plan
U W Project 30100-5-0036-02-900
5. REPORTING AND SCHEDULE
• Febr11ary 19, 1998
The final report with analytical results for the soil samples will be submined to Clariant Corporation
approximately two weeks after receipt of the analytical results from the laboratory. The report will
discuss whether the results of the sample analyses met the ARARs for the Mount Holly East Plant.
The report will be signed by an engineer registered in the State of North Carolina. The report will
also include field notes from the sampling event.
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AREA D "ARC"
FUEL
OIL TANK
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REF: FAX RECEIVED FROM a..ARIAHT CORPORATION ON 12/22/97.
~ LAW.;~:
~ ENGINEERING ANO EN'<!RONMENTAL SER'<ICES
CHARI.OTTE, NORlH CAROUNA
11 J08 NO.
20 10 0 20
APPROlllllATE SCALE IN FEET
AREA D "ARC" LOCATION MAP
CLARIANT CORPORATION
MOUNT HOLLY, NORTH CAROLINA
30100-5-0036 FlGURE