NCD003446721_19890802_Celeanse Corporation - Shelby Fiber_FRBCERCLA RD_OU-2 Source Material - Remedial Design Work Plan July 1989-OCR

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
AUG O 2 1989
4WD-SFB
Ms. Charlotte Varlashkin
ATLANTA. GEORGIA 30365
North Carolina Department of Human Resources
P.O. Box 2091
Raleigh, Nor.th Ca.r.olina 27602
RE: Celanese Fibers Oper.ations
Shelby, Nor.th Carolina
RECEIVED
/\UG < 1989
SUPERFUND BRANCH
Please find enclosed a copy of the draft Remedial Design Work Plan
for Operable Unit II at the subject site. I am requesting you review
this plan and provide me with written comments no later. than August
25, 1989.
If you have any questions or. will be unable to r.etur.n comments by
August 25, please let me know at [phone].
i:;J:lt
Michelle Glenn
Remedial Project Manager.
Enclosure
cc: Lee Crosby, NCDHR (letter only)
Jack Butler., NCDHR (letter. only)
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Westinghouse Environmental
and Geotechnical Services. Inc.
4000 DeKalb Technology Parkway. NE
Surte 250
Atlanta. Georgia 30340
[phone]
FAX [phone]
REMEDIAL DESIGN WORK PLAN
OPERABLE UNIT 2 -SOURCE MATERIAL
HOECHST CELANESE FACILITY
SHELBY,NORTH CAROLINA
WESTINGHOUSE PROJECT 4124-85-0S0M
DOCUMENT CONTROL NUMBER SS0S0M-0156
Prepared For:
U.S. ENVIRONMENTAL PROTECTION AGENCY
ON BEHALF OF HOECHST CELANESE CORPORATION
SHELBY, NORTH CAROLINA
Prepared By:
WESTINGHOUSE ENVIRONMENTAL AND GEOTECHNICAL SERVICES, INC.
Michael K. Mays, P.E.
Atlanta, Georgia
July, 1989
Senior Environmental Engineer
Everett w. Glover, Jr., P.E.
Project Manager
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A Westinghouse Electric Corporation subsidiary.
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0S0M
Document Control Number 85050M-0156
Page i
TABLE OF CONTENTS
List of Figures
EXECUTIVE SUMMARY
ii
ES-1
1.0 INTRODUCTION
1. 1 Site Location and Description 1-1
1. 2 Site History and Regulatory Status 1-3
1. 3 Project Description and Type 1-10
1. 4 Scope of Work 1-11
2.0 REMEDIAL DESIGN SCOPE OF WORK 2-1
3.0 SCHEDULE OF ACTIVITIES 3-1
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Figure
1-1
1-2
3-1
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0S0M
Document Control Number 85050M-0156
Page ii
Site Plan
.LIST OF FIGURES
Title
Location of Fill Areas
Remedial Design Schedule
1-2
1-6
3-2
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Remedial Design Work Plan
Operable Unit 2 -source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-0156
Page ES-1
EXECUTIVE SUMMARY
This work plan describes the engineering services Westinghouse
Environmental and Geotechnical Services Inc. (Westinghouse),
formerly S&ME, will provide for the design of the recommended
remedial action at the Hoechst Celanese site in Shelby, North
Carolina. Westinghouse will conduct and perform all work
required as described in the work plan to prepare a remedial
design (RD) for the on-site incineration remedial action
alternative developed in the Feasibility Study (FS). This
alternative was selected and summarized by the U.S.
Environmental Protection Agency (EPA) in the Record of Decision
(ROD) for the Shelby site dated March 28, 1989.
The RD will provide the technical aspects of the bid document
package including the plans, design drawings and performance
specifications needed to accomplish the remedial action
recommended in the ROD. The recommended remedial action
consists of:
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excavation of glycol recovery unit (GRU) sludges,
plastic chips, burn pit residuals and stream sediments
on-site incineration of GRU sludges and associated
contaminated soils
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0S0M
Document Control Number 85050M-0l56
Page ES-2
chemical fixation (solidification) of incinerator ash,
plastic chips, burn pit residuals and stream sediments
on-site disposal of inert, solidified material
o regrading
0 monitoring
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-0156
Page 1-1
1,0 INTRODUCTION
This work plan outlines the engineering services required for
the· on-site thermal destruction facilities necessary for
remedial action at the Hoechst Celanese site in Shelby, North
Carolina. The selected remedial action is defined in detail in
EPA's Record of Decision (ROD) for the site dated March 28,
1989.
1.1 site Location and Description
The Hoechst Celanese site is a 469-acre property occupied by a
polyester resin arid fiber production facility (Figure 1-1). The
site is located in south-central Cleveland County east of North
Carolina Highway 198. It is approximately 1 mile north of
Earl, North Carolina and 6 miles south of Shelby. The nearest
major city is Charlotte, North Carolina, 35 miles northeast of
Shelby.
The plant facilities consist of the plant production area,
wastewater treatment area, former waste disposal areas, sludge
landfarm area, and the recreation and wooded areas to the south
of the main plant.
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0 4000
~~~==~
2000
Approximate Scale in Feet
CONTOUR INTERVAL -20 FEET
MAP REPRODUCED FROM U.S.G.S. BLACKSBURG 7.5 MIN. QUADRANGLE (1971)
Westinghouse Environmental
and Geotechnical Services. Inc.
FIGURE 1-1
SITE WCATION MAP
HG/SHELBY, North Carolina
Westinghouse Project No. 4124-85-0SOM
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-0156
Page 1-3
The majority of land surface reflects cultural modification by
construction, and by cutting and filling. The original soil
profile has probably been either truncated or covered across
much of the site, and was never conclusively identified as
undisturbed during the field investigations of the Remedial
Investigation (RI). The plant production area is predominantly
covered with buildings and paved or gravelled areas. However,
to the east, toward the wastewater treatment area, the site
becomes more open, with the majority of the land covered by
impoundments, with grass and access roads in between. The
sludge landfarm is north of the plant production area and over
grown with coarse grasses. The recreation area and wooded area
to the south have no facilities related to the plant process.
Adjacent land use is rural; some residences are located within 1
mile of the site.
1.2 site History and Regulatory status
Fiber Industries, Inc., a joint venture of Celanese Corporation
and Imperial Chemicals, Incorporated, (ICI), was the original
owner of the plant and operated it from 1960 until 1983 when the
Celanese Corporation bought out ICI's share of the facility.
American Hoechst and Celanese merged in 1987 to Hoechst
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-0156
Page 1-4
Celanese. It is now operated as Hoechst Celanese, Shelby Plant.
Operations at the Shelby facility began in April, 1960.
Manufacturing operations included the production of polyester
polymer resin and filament yarn. The principal chemicals
involved in polymer production are dimethyl terephthalate and
ethylene glycol. Other small quantity additives include
titanium dioxide and antimony trioxide.
The Hoechst Celanese wastewater treatment plant was constructed
in phases concurrent with the manufacturing plant. During part
of the early years, chemical wastes were discharged through a
ditch draining in a generally easterly direction. The ditch
began near the western edge of what is now know as the former
drum storage area, and travelled east to the northeast corner of
the present emergency spill ponds. The ditch was replaced with
pipes when the wastewater treatment plant became fully
operational in the mid-1960's. In 1973, the plant was expanded
with the addition of a polishing pond, two emergency spill
ponds, and an additional aeration basin. The treated effluent
from the wastewater treatment plant is piped to a discharge
point on Buffalo Creek.
The concrete-lined portions of the wastewater treatment facility
include a digester, three equalization basins, two aeration
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Remedial Design Work Plan
Operable Unit 2 -source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-050M
Document Control Number 85050M-0156
Page 1-5
basins, and two clarifiers. The unlined plant units include the
three polishing ponds, two sludge ponds, and two emergency spill
ponds.
In addition to the discharge from the wastewater treatment
plant, the Hoechst Celanese facility also discharges contact
process cooling water directly to Buffalo creek. The contact
process water is used to cool the polymer products. Both of
these discharges are covered by permits from the North Carolina
Department of Natural Resources.
Several areas around the plant have been used for waste
disposal. Normal plant wastes (primarily polyester and
miscellaneous trash) were disposed of in old burning pits
located just north of the aeration basins. North and east of
the burning in pits, glycol recovery unit (GRU) sludge was
buried in trenches during the early 1960 1 s. Figure 1-2 shows
the location of fill areas and differentiates the fill types.
West of the GRU sludge burial area is a former drum storage and
staging area. Solutions.which failed to polymerize were stored
here during the early 1960 1 s. The drums were removed in the
mid-1960's, and the storage area was backfilled. Two soak-away
ponds located west of the existing aeration basins were used to
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-------------------
Westinghouse Environmental
and Geotechnical Services, Inc.
LEGEND
--DEMOLITION FILL
{lJJffe -DISPOSAL FILL • -CLEAN FILL
E -EQUALIZATION BASIN
C -CLARIFIER
D -DIGESTER
AB -AERATION BASJN
SP -SLUDGE POND
EP -EMERGENCY POND
pp -POL IS HING POND
SC""-£ CHYll
~00
FIGURE 1-2
DISTRIBUTION OF FILL TYPES
HG/SHELBY, North Carolina
Westinghouse Project No. 4124-85-OSOM
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-050M
Document control Number 85050M-0156
Page 1-7
contain treated sanitary sewage during the period from 1960 to
1969.
Two other areas of buried waste are located to the north of the
main plant. The polymer and fiber landfill contains primarily
non-hazardous inert materials such as excavation spoil,
construction waste and yarn. The construction debris landfill
contains items such as old cinder blocks and steel strapping
bands.
Approximately 21 acres of the northwest quadrant of the property
have been issued permits by the North Carolina Department of
Natural Resources for sludge disposal since 1978.
In the period from 1970 to 1978, approximately 2000 to 3000
drums of waste chemicals and solvents, including lab packs, were
stored temporarily in the area know as the drum storage area
near the former burning pits. All drums were removed from the
area by 1978 and sent to outside disposal facilities.
Investigation of the Hoechst Celanese site began in October 1981
when Hoechst Celanese contracted with Westinghouse to install 23
groundwater monitor wells. In conjunction with the groundwater
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0S0M
Document Control Number 85050M-0156
Page 1-8
monitor well installation program, Westinghouse also conducted a
hydrogeologic evaluation. Subsequently, Hoechst Celanese
initiated a groundwater sampling and analysis program under the
supervision of Davis & Floyd Laboratories, Inc.
Westinghouse also conducted an electromagnetic survey and
excavated test pits at the site.
In October 1984, Hoechst Celanese was proposed for EPA's
National Priorties List (NPL). Also, in October 1984, there
were a series of meetings between the EPA and Hoechst Celanese
to discuss the preparation of a Work Plan for a Remedial
Investigation (RI) and Feasibility study (FS) by Hoechst
Celanese's contractor, Westinghouse. Concurrent with this,
EPA's contractor, Camp, Dresser & McKee, Inc. (COM), prepared a
report that included a review of the data collected during
previous site investigations and identified information
deficiencies and data gaps to provide a basis for development of
Remedial Investigation activities. These events resulted in the
submission of a draft Work Plan by Westinghouse, on behalf of
Hoechst Celanese, with final Order on consent to perform the
RI/FS on March 10, 1986. In June of 1986, the EPA added the
site to the NPL.
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-Ol56
Page 1-9
The RI report of for the site was final in July, 1987 and
determined that two areas of the site needed to be addressed:
former glycol recovery unit waste pits and other adjacent
disposal pits, and groundwater contaminated by the waste in
those pits. Due to the groundwater contamination and the
potential for it to move off-site, EPA approved Westinghouse's
proposal for a two-phased clean-up action. These two phases are
identified as Operable Unit 1 (OU #1), which focuses on
remediating contaminated groundwater, and Operable Unit 2
(OU #2), which addressess remediation of the sludges and soils
associated with the former glycol recovery unit trenches, of the
burn pit areas, and of specific stream sediments.
The Operable Unit FS for the groundwater was completed in
February, 1988. The ROD for that Remedial Action (OU #1) was
signed March 23, 1988, and required extraction and treatment of
contaminated groundwater associated with the site. Hoechst
Celanese agreed to conduct the Remedial Action for OU #1 in a
partial Consent Decree dated June 30, 1988. It has since been
entered with the Court. Construction is complete and start-up
testing is in progress.
The Operable Unit FS for OU #2 Remedial Action was final in
February 1989. This remedial action will address contaminant
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-0156
Page 1-10
source control at the site. A consent decree on OU #2 was
signed by Hoechst Celanese on June 19, 1989 and submitted to EPA
for processing.
1.3 Project Description and Type
The selected remedial action for the Hoechst Celanese, Shelby,
North Carolina site is outlined in the ROD and includes the
following remediation activities:
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excavation of approximately 2000 cubic yards of glycol
recovery unit (GRU) sludges. The 2000 cubic yards
includes a known GRU volume of 1500 cubic yards plus an
additional 1 foot of soil below the GRU/soil interface
excavation of approximately 1200 cubic yards of burn
pit residuals
excavation of approximately 600 cubic yards of plastic
chips
excavation of approximately 110 cubic yards of stream
sediments
incineration of GRU sludges and associated soils
chemical fixation (solidification) of incinerator ash,
plastic chips, burn pit residuals and stream sediments
on-site disposal of inert solidified materials
regrading
monitoring
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Remedial Design Work Plan
Operable Unit 2 -Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-0156
Page 1-12
Westinghouse will work with.Hoechst Celanese Corporation in RD
project management and scheduling. EPA will be informed of the
project status in monthly status reports and when necessary
project update meetings.
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Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-156
Page 2-1
2.0 REMEDIAL DESIGN SCOPE OF WORK
The following tasks are included in the RD scope of work.
Task 1
Task 2
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Review of Background Information and Work Plan
Preparation
Westinghouse will review pertinent data to perform and
manage the RD. This task also includes the preparation
of a RD Work Plan
Investigation Support
Westinghouse will conduct the preliminary work
necessary to perform the RD. This includes meetings
with the EPA regional project officer during
development of the RD. Additional investigation
support may include visits to the site, definition of
design parameters, preparation and award of
subcontracts, and preparation of site maps and
photographs.
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Task 3
5050M002
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-156
Page 2-2
Westinghouse will work with Hoechst Celanese in the
preparation of a bid package for selection of a
laboratory to perform sample analyses of solidified
soil and incinerator residue. Requests for bids will
be submitted to a least three laboratories with quality
assurance/quality control procedures following EPA's
Region IV CLP protocols. This subtask also includes
selecting, awarding, and subcontracting of the
laboratory analysis services. Preparation of the bid
package will begin prior to Work Plan approval by EPA.
Laboratory testing of residue samples and solidified
materials will be performed using a laboratory
qualified under EPA's Contract Laboratory Program (CLP)
protocols. EPA will have the opportunity to collect
duplicate samples to be sent to EPA-ESD (Environmental
Services Division) for comparative analysis. Data
verification packages are needed for all samples
analyzed by the outside laboratory for all duplicate
samples sent to EPA-ESD.
Health and Safety Plan
Westinghouse will modify the existing site-specific
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Task 4
Task 5
5050M002
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-OSOM
Document Control Number 85O5OM-156
Page 2-3
Health and Safety Plan, developed as part of operable
Unit 1, for the RD to protect on-site personnel from
the physical and chemical hazards of the site.
Included in this task is the preparation of a generic
health and safety plan to be used by the incineration
contractor. The incineration contractor will review
the generic plan and modify it to fit his equipment and
needs.
Quality Assurance Project Plan
Westinghouse will develop a site-specific Quality
Assurance Project Plan (QAPP). The plan will provide
guidelines for project organization which will outline
and identify quality assurance and quality control
responsibilities of the project team and
subcontractors. The QAPP will be consistent with EPA
and Westinghouse quality assurance/quality control
procedures. This plan will be modified as needed by
the remediation contractor to cover site operations.
Solidification/Fixation Testing_Plan
Westinghouse will collect representative samples of the
GRU, burn pit, plastic chips and stream sediments for
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Task 6
5050M002
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0S0M
Document Control Number 85050M-156
Page 2-4
solidification/fixation testing. Sample locations will
be determined based on data from the RI and expanded
characterization data. GRU samples will be ashed prior
to solidification testing. Westinghouse will conduct
the solidification testing in their soils laboratory
using different fixation agents and concentrations.
Analytical testing will be done for the Toxicity
Characteristic Leaching Procedure (TCLP) parameters.
Prior to sampling and solidification testing, a letter
report will be sent to EPA detailing the number and
location of samples and type and number of fixation
tests to be performed.
The purpose of the testing is to obtain chemical and
physical data on solidification of the soils and
incineration residues. These data will supplement
testing conducted as part of the Feasibility study.
Data obtained from this task will be incorporated into
the design specifications for use in competitive
bidding on the remedial action.
Permitting Plan
Westinghouse will identify what permits would be
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Task 7
5050M002
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-050M
Document Control Number 85050M-156
Page 2-5
required if this were a RCRA facility and how the
technical requirements of the permits are addressed in
the remedial action. Technical requirements may
include destruction removal efficiency, point source
discharge monitoring from a wet scrubber, and TCLP
requirements and others.
Preliminary Design and Operations Plan
The purpose of the preliminary design is to provide
information needed for competitive bidding on the
remedial action. A preliminary design report will be
submitted to EPA for approval prior to commencement of
final design activities. Prior to the submittal of the
preliminary design report, a meeting will be held among
Westinghouse, Hoechst Celanese, and EPA to review the
design basis and provide direction for the continuation
of the RD. The preliminary design report will address
the following topics:
o refined identification of stream segments
requiring remediation
o proposed operations area(s)
o performance specifications for incineration and
solidification
o storm water run-on and run-off control
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Task 8
5050M002
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-156
Page 2-6
o location of utilities
o excavation of contaminated soils
o area requirements
o recommended design
o regulatory requirements
o proposed stock piling location(s)
o equipment decontamination
o health and safety requirements
o monitoring during implementation
o verification testing of stream segments
Bid Package for Solidification and Incineration
Services
The ROD identified a mobile rotary kiln incinerator as
the recommended alternative for treatment of the GRU
material and adjacent soils at the Shelby site. The
incinerator ash, plastic chips, burn pit residuals and
stream sediments will be solidified using a fixation
agent.
To provide input to the bidding process, data are
needed on the thermal treatability of the material and
amount and type of solidification agent required.
Preliminary data on incineration and solidification are
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5050M002
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-050M
Document control Number 85050M-156
Page 2-7
included in the Feasibility Study. Additional
solidification data obtained as a part of Task 5 will
be supplied to prospective contractors. Westinghouse
will assist Hoechst Celanese in the preparation of a
bid package, supplying representative samples to
prospective contractors for analysis, and in the
evaluation, selection, awarding and subcontracting of
the on-site remediation activities. Data supplied to
the prospective contractors will include:
o type and physical characteristics of the soil
o type of contaminants
o range of contaminant concentrations
o volume of soils needing remediation
o moisture content
o chemical analysis of soils
o metal content of GRU materials
o BTU value
0 laboratory and bench-scale data from the
Feasibility Study
0 bench-scale solidification data from Task 5
0 basis of design and preliminary drawings
0 performance specifications
0 emission requirements
0 other requirements specified in the RD
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Task 9
Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document control Number 85050M-156
Page 2-8
Final Design
After the site remediation contractor is selected,
Westinghouse will work with the contractor to develop
drawings, specifications and the final design package. A
preliminary list of drawings and specifications that may be
applicable to this RD is presented below.
I. List of Drawings
I General
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5050M002
G-1. Index Sheet, Abbreviations and Legend
G-3 Process Schematic Diagram of Thermal Treatment and
Solidification System
Civil
C-1 Site Plan
C-2 Equipment Layout
C-3 Excavation Plan and Schedule
C-4 Solidification Plan and Schedule
C-5 Backfilling Plan and Schedule
C-6 Grading, Paving, and Drainage Plan
C-7 Piping Plan
Electrical
E-1 Electrical Site Plan
E-2 Single Line Power Diagram
E-3 Details
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Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0S0M
Document control Number 85050M-156
Page 2-9
II. List of Specifications
Division 1 -Site work
Excavation, Backfill and Compaction
Run-on and Run-off Control
Landscaping
Division 2 -Equipment
Thermal Treatment System -Performance
Specifications
Solidification System -Performance
Specifications
Division 3 -Electrical
Task 10 Thermal Destruction Unit Project Operations Plan
5050M002
Westinghouse will work with the remediation contractor
in the development of the project operations plan.
This task includes the following items:
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operational requirements for DRE and principal
organic and inorganic constituents
health and safety training requirements
trial burn plan
materials handling and blending plan
ash handling, stockpiling and analysis plan
contingency plan for meeting performance
criteria
emergency shut down procedures
equipment decontamination procedures
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Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-156
Page 2-10
incineration and solidification operations
monitoring plan
Task 11 Closure and Site Restoration Plan
A closure and site restoration plan will be submitted
to EPA by Westinghouse for review and approval. The
plan will include sampling and analysis plan to verify
cleanup. The RD will provide more detail on specifics
and degree of activities required.
Task 12 Operation and Maintenance Plan
5050M002
Post closure care and operation and maintenance
requirements will be submitted to EPA by Westinghouse.
The O&M plan will be consistent with response and
ongoing extraction and treatment system.
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Remedial Design Work Plan
Operable Unit 2-Source Material
Hoechst Celanese Facility-Shelby, North Carolina
Westinghouse Project 4124-85-0SOM
Document Control Number 85050M-156
Page 3-l.
3.0 SCHEDULE OF ACTIVITIES
The estimated schedule of implementation of the operable unit is
shown as Figure 3-1. The schedule shown in the figure is
contingent upon approval by EPA of the Work Plan and preliminary
design within 30 days of their submittals. In the figure, the
solid line at the end of December represents 120 days past the
assumed EPA Work Plan approval date of September 1, 1989.
5050M002
- - - - - - - - - - - - - - - - --·. -FIGURE 3-1
RE rv1 ED IAL DESIGN sou RC E MA-rER 1,.6,L
HOECHST CELANESE
SHELBY, NC
WC)RK PLAN
EP,t\ APPROVAL OF WORK PLAN
I~,J\/ESTIGATION SUPPORT
HE:,t\l_Tf-l & SAFETY PLAN
OA;/QC PLAN
SOLIDIFICATION & TESTING PLAN
PE RMITTlf'-JG PLAN
PREL_ltv1. DESIGN & OPER. PLAN
EPA APPROVAL OF DESIGN
COf'--ITRACTOR BID PREPARATION
COf'~TRACTOR SELECTION
Fl~IAL DESIGN
COf'-.JTRACTOR OPERATIONS PLAN
CL OS URE PLAf'--1
O&M PLAN
1989 1990
JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUI·-!
._._._.~_._,_,_,_ij_u-1.!_u__1JuL .LuJ1.1-1.Lu_ij1 11/tuJLu
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4124-85--050M