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Home My WebLink AboutNCD003200383_19920908_Koppers Co. Inc._FBRCERCLA FS_Feasibility Study 1991 - 1992-OCR' . . . . .• . ' .. • . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 4WD-NSRB September 8, 1992 Shannon Craig Beazer East, Inc. 436 Seventh Avenue 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Feasibility Study Report Koppers Superfund Site Morrisville, North Carolina Dear Ms. Craig: RECEIVED SEP 111992 SUi'i:RHiND SECTION Initial review of the costing tables for the Final. Feasibility Study Report, September 1992, has begun. The costs associated with offsite incineration appear extremely high. Greater detail is required for the offsite and as well as the onsite incineration alternatives. Each line item must be clearly defined indicating the basis for the costs, e.g. number of samples for analytical costs, details of restoration. Independant estimates indicate that th_e "going rate" for transport is $2. 70/mile with a truck liner included. Liners should be closer to $25. Provide information as to whether the costs have been developed at the high end for a specific purpose, whether the companies are volume dependant, etc. Detailed information is due no later than Friday, September 11, 1992. Please contact me at 404-347-7791 if you have any questions regarding this letter. Sincerely, 1. 611/Yi//A 'JZ/ ~/LGy( · Barbara H. Benoy ( J . Remedial Project Manager ·- Waste Management Division cc: Curt Fehn, NCS Chuck Mikalian, ORC / Bruce Nicholson, NCDEHNRV John Mitsak, Keystone KOP.9892.FSCOSTS.SCRA Printed on Recycled Paper • • MECtUVt.D SEP OS 1992 UNITED ST ATES ENVIRONMENTAL PROTECTION AGENcvSUPERfllNDSf.tTION REGION IV 345 COURTLAND STREET. N,E ATLANTA. GEORGiA 30365 4WD-NSRB Shannon Craig Beazer East, Inc. 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 Re: Draft Responses from Keystone on Feasibility Study Report Koppe~s Superfund Site Morrisville, North Carolina Dear Ms. Craig: The draft responses to EPA's comments on the Feasibility Study have been reviewed. Please refer to the attached itemized information. The Final document is due on September 8, 1992. Revised tables for volumes, dechlorination and costing information should be submitted on September 2, 1992, as per our discussions. I can be reached at 404-347-7791 if you have any questions regarding this letter. Sincerely, / l/J' t1. ~. ,. ../J ~ wU/Cl/lD--I _,, /'-::_./. Barbara H. Benoy Remedial Project Waste Management Enclosure ~ Manager Division cc: Curt Fehn, NCS Chuck Mikalian, ORC Bruce Nicholson, NCDEHNR ✓ John Mitsak, Keystone Jim Miller, Keystone KOP.9192.P'SBHS • • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 2 General Comments Comment #1 - Comment #2 - Comment #3 - Comment #4 - Comment #5 - Comment #6 - Comment ii 7 - Comment #8 - Comment #9 - Comment #10 Comment #11 Comment #12 Comment #13 Comment #14 - - - - - Response acceptable. Response acceptable, however, justification should be accompanied by cost figures. This assumes groundwater treatment system is already designed. Pump rates can be controlled. Response acceptable. This does not make sense. No indication of minimal operation have been provided. It would appear that a system such as this would be more feasible if automated and no labor was required. A carbon adsorption system is a rather simplistic system. What could possibly require man-power after initial start-up? Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. 1) The general criteria of delisting waste must be provided. 2) As we discussed, a local POTW discharge is not a truly viable option and therefore should be removed. Comment #15 -Response acceptable. KOP,81492.RI.SC • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study.Comments September 1, 1992 Page 3 • Comment #16 -The qualifying discussion regarding the unknown locations should be included in the text. Comment #17 -Response acceptable. Comment #18 -Response acceptable. Comment #19 -The qualifying discussion regarding these wells, and the unknown construct.ion should be .i.ncl11ded :i.n the text. Comment #20 -Response acceptable. Comment #21 -Response acceptable. Comment #22 -The figures indicate that X-1 is indeed on the site property and therefore, as per your explanation are inaccurate and require correction. Comment #23 -Response acceptable, but EPA will review upon submittal. Comment #24 -Response acceptable. Comment #25 -Response acceptable. Comment #26 -EPA will assume that the text will be changed though the response does not state so. Comment #27 -Response acceptable. Comment #28 -Response acceptable. Comment #29 -Response acceptable. Comment #30 -Response acceptable. Comment #31 -Response acceptable. Comment #32 -Response acceptable. Comment #33 -Response acceptable. Comment #34 -Response acceptable. Comment #35 -Response acceptable. KOP. 81492 .RI.SC • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 4 • Comment #36 -Paragraph 2 does provide an appropriate location for the fence discussion in the same discussion with the institutional controls being discussed. Comment #37 -Response acceptable. Comment #38 -Response acceptable. Comment .D2. -Response acceptable. Comment #40 -Response acceptable. Comment #41 -Response acceptable. Comment #42 -Respo_nse acceptable. Comment #43 -Response acceptable. Comment #44 -Response acceptable. Comment #45 -Response acceptable. Comment #46 -Response acceptable. Comment #47 -Response acceptable. Comment #48 -No further change necessary. Comment #49 -No further change necessary. Comment #50 -Comment is reiterated. More specific and detailed information concerning the "other sites and studies" is required. Comment· #51 The information in the text gives the perception that this technology has been demonstrated effectively at site(s). There is a clear implication that the technology is effective in site-specific situations. If Keystone/Beazer has information regarding site-related demonstrations, then that information must be provided. Otherwise, all references in the report are required to be qualified. For example, if "complete dechlorination" has been shown, the scenario and context must be provided, i.e., in laboratory conditions, in soils, in liquids, etc. KOP.81492 .RI. SC • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 5 • Comment #52 -See EPA comment above (#51). Comment #53 -Provide better justification of the elimination of this technology in the report. Comment #54 -Response acceptable. Comment #55 -Response acceptable. Comment #56 -Response acceptable. Comment #57 -Response acceptable. Comment #58 -Response acceptable. Comment #59 -Response acceptable. Comment #60 -1) Response acceptable. 2) Clarify in text. Comment #61 -Response acceptable. Comment #62 -Response acceptable. Comment #63 -Response acceptable. Comment #64 -As previously stated, the response to this comment is insufficient. Comment #65 -Response acceptable. Comment #66 -Response acceptable. Comment #67 -EPA disagrees with the response and strongly reiterates the original comment. Comment #68 -Response acceptable. Comment #69 -Response acceptable. Comment #70 -Response acceptable. Comment #71 -Response acceptable. Comment #72 -Response acceptable. Comment #73 -Response acceptable. KOP.81492.RI.SC • • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 6 Comment #74 -Response acceptable. Comment #75 -Response acceptable. Comment #76 -Response acceptable. Comment #77 -As per our discussion 8/31/92, the more current information on a RCRA cap is defined in the proposed plan. The cap defined in the proposed pian meets the current definition. Text/tables should be changed. Comment #78 -Response acceptable. Comment #79 -Response acceptable, however, all alternatives which LDRs may. be applicable or appropriate must include the information. Comment #80 - Comment #81 - Comment #82 - Comment #83 - Comment #84 - Comment #85 - Comment #86 - Comment #87 - Comment #88 - Comment #89 KOP.81492,RI,SC Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. Response acceptable. The information in the text gives the perception that this technology has been demonstrated effectively at site(s). There is a clear implication that the technology is effective in site-specific situations. If Keystone/Beazer has information regarding site-related demonstrations, then that information must be provided. Otherwise, all references in the report are required to be qualified. For example, if "complete dechlorination" has been shown, the scenario and • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 7 • context must be provided, i.e., in laboratory conditions, in soils, in liquids, etc. Comment #90 -Response acceptable. Comment j! 91 -Response acceptable. Comment #92 -Response acceptable. Comment #93 -Response acceptable. Comment #94 -Response acceptable. Comment #95 -Response acceptable. Comment --1!..2.§_ -Response acceptable, but must be appropriately described for all residuals for all alternatives. Comment #97 -Response acceptable. Comment #98 -EPA assumes text revisions will be made. Comment #99 -Response acceptable. Comment #100 -Response.acceptable. Comment #101 -Response acceptable. Comment #102 -Response acceptable. Comment #103 -Response acceptable. Comment #104 ·· EPA reiterates the need for th·e time required for protection as well as for construction. Comment #105 -Response acceptable. Comment #106 -Not appropriate/sufficient. comment #14. See EPA response on Comment #107 -Response acceptable; information should also include the fact that North Carolina requires health-based numbers of 10 E-06 for compounds where definitive cleanup standards have not been promulgated. Comment #108 -Provide the general information of the time that KOP.81492.RI.SC ; • • Koppers Compnay Inc. Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 8 Comment #109 Comment # 110 Comment #111 Comment #112 Comment #113 Comment #114 Comment #115 Comment #116 Comment #117 -- would be required to begin extraction as well as the estimated time that would be required to meet remediation objectives. Information concerning the unknown EPA review time is not necessary. There are typical times that are available for incorporation. Response acceptable. Response acceptable. -Response to comment # 67 is not acceptable. -See EPA response to comment #108. -Response acceptable. -Response acceptable. -Response acceptable. -Response acceptable. -See EPA response to comment #108. Comment #118 -The text revisions concerning the Medlin Pond and the final surface water discharge point appear acceptable. The disposal of fish is being reconsidered and in fact may require analytical data for disposal. Beazer/Keystone must contact the State of North Carolina to continue the search for possible applicable or appropriate requirements for the disposal of fish. Comment #119 -Response acceptable. Comment #120 -Response acceptable. Comment #121 -Response acceptable. Comment #122 - A more specific response is required. Comment #123 - A more specific response is required. Comment #124 Provide to EPA prior to report submittal. Comment #125 Provide to EPA prior to report submittal. KOP.81492.RI.SC • Koppers Compnay Inc, Site Morrisville, North Carolina Feasibility Study Comments September 1, 1992 Page 9 Comment #126 -Response acceptable. • Comment #127 -l) First part of comment is reiterated: brief description of the Recommended Action Alternatives in the first identifying all components of the recommended remedy. 2) When and where discussion? Between whom? This section revised as requested. Provide a Remedial section overall was this should be Comment #128 -Provide the explanation in the text of Appendix B, Comment #129 -Provide a detailed explanation why blended water was used. Comment #130 -Response acceptable. KOP. 81492 .RI. SC • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AUG 6 1992 4WD-NSRB Shannon Craig Beazer East, Inc. 436 Seventh Avenue Pittsburgh, Pennsylvania Re: Feasibility Study REGION IV 345 COURTLAND STREET. N.E. ATLANTA, GEORGIA 30365 15219 Koppers Company NPL Site Morrisville, ·North Carolina Dear Ms. Craig: Rtl;fgVtD AUG 1 3 1992 . SUfERfllNDSEQflJN Comments on the Feasibility Study are enclosed. Copies of comments generated by Fish & Wildlife, the State of North Carolina, and the community of Shiloh are also enclosed. The revised Feasibility Study is due no later than September 8, 1992, as specified in the Administrative Order by Consent. Responses to comments should. be submitted in writing prior to the submittal so that agreement can be reached on any issues that need to be discussed. I would also like to express a request for a submittal prior to the due date in light of the fact that the community has requested final approved documents to be available well before issuance of the ROD. Please call me to discuss this possibility. ,r can be reached at 404/347-7791 or fax number 404/347-1695 if you have any questions. Sincerely, -~·~ Barbara H. Benoy Remedial Project Manager Waste Management Division cc: C. Fehn, NCS c. Winokur, ORC C. Hooper, ESD J. Mitsak, Keystone B. ,V;chof ,,.,11 / NC. OE H )I~ KOP.8692.SC Printed on Rec1c·~'! :-_-..... • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 2 General Comments • All alternatives should be developed for the range in soil volumes from the 1000 CY to the 10,000 CY and taking the midpoint at 5000 CY as per previous discussions. The Medlin Pond must also be included in the remedial alternatives. Onsite disposal should be developed for alternatives which provide treatement for soil onsite and then dispose offsite. Costs should be developed for rail transport as well as trucking as presented. The Fire Pond water alternative is to rent a temporary carbon adsorption system and complete treatment within three months at a cost of about $1000K. Please provide the rationale that the treatment unit specifically for the surface water is included and why the permanent treatment system for the groundwater is not considered for the treatment of the surface water, also. Is it capacity, location? Two errors were cited in the discussions of the UV-oxidation groundwater treatment alternative: The UV lamp replacement costs are not provided, and the addition of O&M costs is incorrect. The total indicated is $294K, but the apparent total should be $245K. If the lesser amount is used to recalculate the present worth cost, it would be less than $4 mil, instead of greater than $5 mil. The carbon adsorption system is sized for a 50 gallon per minute flow, but the pumping rate for the extraction well is given at 10 gpm. This apparent over-design has increased the capital costs. If a higher pumping rate is actually used, additional equalization tank capaclty could be needed. Executive Summary. page ES-1. 2nd paragraph -Compliance of laws, regulations, ARARs, etc. should be mentioned here. Executive Summary. Page ES-3. 3rd paragraph -Isopropyl ether must be included as •constituents of interest". Executive Summary. Page ES-4. middle of page -Delete information concerning re-evaluation of dioxin from "It is unknown • . . . to the end of the paragraph. Executive Summary, Page ES-4. second full paragraph -Delete last sentence. Executive Summary, Page ES-4. bottom of page -Substitute "As described in the Baseline RA" with "Based on the results of the RI," and substitute "will" for "may" in same sentence. KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 3 • Executive Summary. Page ES-5. 1st full paragraph -Delete this paragraph. Executive Summary. Page ES-5. Remedial Action Objectives -Add "Remediate soils in the former lagoon area and Callon Process area to levels which are protective of dermal exposure. Executive Summary, Page ES-6. 1st full paragraph -Clarify better what the "end point" is. Either show conceptually on a figure or provide further definition and description. Executive Summary, Page ES-6, Development of Remedial Response Units -The former ditch and sand filter areas need to be shown on maps. Provide a reference as to where the derivation equation(s) for the estimated soil volumes can be found. These equations must be provide in the FS. Executive Summary, Page ES-8, 1st full paragraph -1) Discuss the potential of the ash being a listed waste and the criteria it must meet. 2) Is there a POTW that could even be considered a viable option for discharge. If so, which POTW? Page 1-2, Paragraph 2 and Figure 1-3 -The soil quality data is not shown on Figure 1-3 as stated in this paragraph. Section 1.1.2. page 1-3, 5th paragraph -Show the "south ditch" on a figure. Show locations of the two samples collected in 1976. Section 1.1.3. page 1-6, 1st full paragraph -Appendix I of RI Report should be referenced. Section 1.1.3, page 1-7, 1st sentence -Show the sawdust storage area on a figure. Section 1. 1. 3, page 1-7, 2nd full paragraph -Delete "newly installed•. Show these monitoring wells on a figure. Section 1.3.1, page 1-13, 2nd full paragraph. 3rd sentence -Add "proposed" just prior to "site-specific goal for .... ". Section 1.3.1, paae 1-13, 2nd full paragraph -Show the sand filter on a figure. Section 1. 3. 1, page 1-14, 3rd full paragraph -The approved location for the background soil sample, X-1, was at least 75 feet to the north of the actual sampled location. Why was the location moved into the site proper? KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Connnents on Feasibility Study August 6, 1992 Page 4 • Section 1.3.2, page 1-15, lat full paragraph -Discuss the quality of the offsite private wells here identifying pentachlorophenol concentrations. Section 1.3.2, page 1-15, 3rd full paragraph -Provide this data in a Table with units. Section 1.3.2, page 1-15, last paragraph -Delete "more sensitive". Section 1.3.2, page 1-17, 2nd paragraph -The IPE data for the second round of sampling is not shown on Figure 1-7. Section 1.3.2. page 1-17, 3rd paragraph -Delete "No correlation regarding the reported detections of PCDDs/PCDFs with those samples containing detectable levels of penta is evident". Section 1.3.2, page 1-17, 4th paragraph -Due to the complexity of fracture flow and the limited number of samples, it is not possible to conclusively determine that groundwater does not migrate to the north from the lagoon area. Furthermore, data indicates that some contaminants have migrated to the north and have been detected in monitoring well C-10B. Section 1 ~ 3. 6. 2 -The text contends that dioxins · are fairly ubiquitous in environmental media. The Agency does not concur with this statement. This statement and all associated implications must be removed from the FS. Section 1. 3. 6. 2. page 1-24 -Delete final paragraph of Section 1.3.6.2. Section 1.3.6.4, page 1-27, 1st paragraph -Text must be qualified to state that dioxins are not subject to degradation. Section 1.4.1, page 1-27, 1st paragraph -Substitute "solely due to the presence of penta and PCDDs/PCDFs", to "predominantly due to the presence of penta and PCDDs/PCDFs" . Section 1.4.1, page 1-28 teenager) in text. Delete (including a trespassing Section 1. 4. 1. page 1-31 Delete information concerning re- evaluation of dioxin from "It is unknown .... to the end of the paragraph. Section 1.4.3, page 1-33, 1st paragraph -Rewrite last sentence to read "Parallel analyses for ecological receptors suggest that remedial action may not be necessary, and therefore, RBTCLs have KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA comments on Feasibility Study August 6, 1992 Page 5 • not been proposed for ecological receptors. Section 1.4.3, page 1-33, 3rd paragraph -Fencing is an physical control that may be considered and should be included here. Section 1.4.3, page 1-33 -Table 1-2 has not been provided and is not listed on List of Tables but is referred to in the text. Section 1. 4. 3. page 1-33 -All references to what the specific cleanup levels are must clearly state that these are proposed cleanup levels. No final decisions have been made. The clean-up goals for surface soil in Area C, may in fact be based on dermal contact, not protection to groundwater. Section 2 .1 1 page 2-3. Paragraph 2 -K00l is the appropriate classification for the lagoon area, while F032 is probably appropriate for the process areas, warehouse areas and the driptrack area. ,.s.,.e.,.c:..,t,_,i,.,o..,n.,__2.,__,_.-=l..,_,__.p.,a'°'g"'e,._.,,_2_-_,4...,.'---'2..,n...,d.._.,,_f_,,u.,,l"'l'--'P~a'°'r'"a.,_g=r.,,a..,p=h -The "Six Nine's rule• applies here and must be listed. See CFR Vol. 56, No. 35, 266.104, February 21, 1991. Section 2.2 1 page 2-5, lat full paragraph -First sentence must provide the EPA acceptable risk range. Section 2.2. page 2-5 1 1st full paragraph -Delete last sentence. Section 2.2, page 2-Section 2.2, page 2-5 -Include dermal onsite surface soils discussion. Section 2.2. page 2-6 -Third bullet, text must state that these levels are proposed. Section 2.2. page 2-6 -The dermal exposure to surface soils onsite must be included here. Section 2.2, page 2-7 -North Carolina has promulgated standards for additional phenolic compound(s) and must be included. Section 2.4. page 2-8 -These cleanup goals must be qualified here as proposed. Section 2 .4. page 2-9 -Dermal exposure (direct contact). will be added. Section 2.4, page 2-9 -Explain PQL. KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 6 • Section 2.5, page 2-11, 2nd full paragraph -Provide more specific and detailed information concerning the other sites and studies. Section 2. 5. 4. page 2-21, second full paragraph -Where has definite demonstration of dechlorination ben shown for PCDDs and PCDFs? Section 2.5.4, page 2-22 -Where has APEG been shown effective for PCDDs and PCDFs? Section 2. 5. 4. page 2-27, 1st full paragraph -Doesn't thermal desorption temperature range go as high as 700 ° C? Thermal desorption should be retained through the detailed analysis. Table 2-1 -Container storage must be considered applicable. Onsite storage may occur. Clean Air Act should be identified in this table, and would be applicable. Table 2-3 -North Carolina's standards need to be included. Table 2-4 -15A NCAC 13A.0013. (40 CFR 270) must be considered applicable. G.S. 113a, Article 4 must be considered applicable. Activities may very well be land disturbing. Table 2-7 -Surface soils onsite must be retained here under direct exposure. In footnote (1), provide the date of the document. Table 2-9 -Add dermal exposure to surface soils in Area 1. Section 3.2.1, page 3~11, Alternative 8 -1) The ash must also be considered for onsite disposal here. 2) Permitting under CERCLA for onsite incineration may not be necessary. What permit is being referred to here? Section 3.2.1, page 3-13, top of page -This information concerning the Aptus facility needs to be updated. Section 3. 2. 2, page 3-16. Implementability -Add the sentence "Substantive requirements of an NPDES permit would have to be met." Section 3.2.3 -The discussions of the alternatives for RRU3 should identify the state ARAR along with the information of whether or not the alternative would meet the ARAR. KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 7 • Section 3.2.3 -In the discussions of surface water treatment, are these temporary mobile carbon adsorption units the same as would be used for groundwater treatment or are they different units. would the same units be considered? How would using the same or different units affect costs? Section 4.1.2, page 4-2, 1st paragraph -The surface cover would require a mini.mum cover of one (1) foot. Change text. Section 4.1.7, page 4-11, 2nd full paragraph -The ash must be considered for onsite landfilling. Section 4.1.9, General Comment -In the groundwater pump and treat system discussion, existing well PW-1 is proposed as the extraction well. Please note that additional wells may be necessary. Tow factors are involved: 1) In a fractured system such as is present at this site, the hydrologic characterization of the system is very difficult and it is to be expected that modifications are quite likely as extraction progresses. Monitoring wells should be used to measure water levels in.addition to constituent concentrations. The system will have to be modified as the operation of the system is assessed. 2) Confirmational sampling will be required of all monitoring wells and select private wells during the design phase. Figure 4-3 -This figure needs a pictorial scale of where this landfill would be located onsite. It is impossible to tell from the current figure. Figure 4-4 -This figure needs a pictorial scale of where this landfill would be located onsite. It is impossible to tell from the current figure. Section 5.0 -Long-term effectiveness (and permanence) should be developed better in all potential alternatives for all media. Specifically, the degree of certainty that the alternatives will prove successful. Factors that must be considered and better evaluated include1 1) Magnitude of residual risk remaining from untreated waste or treatment residuals remaining at the conclusion of the remedial activities. The characteristics of the residuals should be considered to the degree that they remain hazardous, taking into account their volume, toxicity, mobility, and propensity to bioaccumulate, 2) Adequacy and reliability of controls such as containment systems and institutional controls that are necessary to manage treatment residuals and untreated waste. This factor addres sea in particular the uncertainties associated with land disposal for providing long-term protection from residuals; the assessment of the potential need to replace technical components of the alternative, such as a cap, or a KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 8 • treatment system; and the potential exposure pathways and risks posed should the remedial action need replacement. Section 5.2 Short-Term Effectiveness -Include a statement that addresses that no protection regardless of time period. Add the word "be" after "obtained" in the first line. Reduction of Toxicity, Mobility, or Volume -Change the sentence to read . " ... except through potential natural biodegradation over time. II Section 5. 3 -First paragraph, last sentence should read "includes" instead of "include". Section 5. 3 .1 -Comments are provided for the surface cover. However, this alternative does not afford the protection that should be necessary to continue this alternative into the detailed analysis of remedial alternatives. Reduction of M,T,V -Change the word "would" to "may". This has not been adequately demonstrated to state conclusively that the mobility would be reduced. Implementability -The first statement does not provide adequate information regarding the technical feasibility of the alternative. Information should include technical difficulties and unknowns associated with the construction and operation of the technology, the reliability of the technology and the ability to monitor the effectiveness of the remedy. · Section 5.3.2 -This alternative must be brought up to the min:unum standards of a RCRA · cap. All aspects must be brought up to standard, costs, detailed description, etc. Page 5-8. top of page, first full sentence Delete "significantly•. Section 5. 3. 3 -The section dealing with compliance with ARARs needs much more detail, especially where LDR requirements are concerned. Short-Term Effectiveness, page 5-9 -This section must address the potential environmental impacts of this alternative. Long-Term Effectiveness, page 5-9 -Please refer to the general EPA comment regarding Long-Term effectiveness in Section 5.0. KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 9 • Page 5-10, Implementability -The statement "it has been used at other CERCLA sites", is not sound technical basis for addressing the implementability for this alternative at this site. The ease or difficulty of implementing the alternatives shall be assessed by considering the following types of factors: 1) Technical feasibility, including technical difficulties and unknowns associated with the construction and operation of a technology, the reliability of the technology, ease of undertaking additional remedial actions and the ability to monitor the effectiveness of the remedy, 2) Administrative feasibility, including activities needed to coordinate with other offices and agencies and the ability and time required to obtain any necessary approvals and permits from other agencies, 3) Availability of services and materials, including the availability of adequate off-site treatment, storage capacity, and disposal capacity and services; the availability of necessary equipment and specialists, and provisions to ensure any necessary additional resources; the availability of services and materials; and availability of prospective technologies. Section 5.3.4, Short-Term Effectiveness -Address potential environmental impacts and specify time period it would take until protection is achieved. Implementability -Administrative problems need to be addressed, such as problems associated with transporting materials. Also, FO32 may be the listing of some of the contaminated media for this site, however, KOO! and F027 more closely define the wastes associate with this site. Change report to reflect this. overall Protection of Human Health and the Environment -Second sentence, add "associated with soils" after "site remediation". Short-Term Effectiveness achieved. Specify Time until protection is Page 5-14 -Please refer to the general EPA comment regarding Long- Term effectiveness in Section 5. 0. This technology is not KNOWN to be effective for TCDD/TCDF. This section should be re-written to accurately represent this fact. The associated risks cannot be assumed to be eliminated. Identify the reference (GRC, 1991); it does not appear to be included in the reference section of the FS. Reduction of MTV -This section inadequately addresses the fact that.the majority of the risks associated with this site are based on the existence of TCDD/TCDF and in fact is written as if the site risks are associated with pentachlorophenol exclusively. Section must be rewritten. The degree· to which alternatives employ KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 10 • treatment that reduces toxicity, mobility, or volume shall be assessed, including how treatment is used to address the principal threats posed by the site. Factors that shall be considered include the following: 1) The treatment processes the alternative employs and materials it will treat, 2) the amount of h·azardous substances, pollutants, or contaminants that will be destroyed, or treated, 3) the degree of expected reduction in toxicity, mobility, or volume of the waste due to treatment and the specification of which reduction ( s) are occurring, 4) The degree to which the treatment is irreversible, 5) the type and quantity of residuals that will remain following treatment, considering the persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous substances and their constituents, and 6) the degree to which treatment reduces the inherent hazards posed by principal threats at the site. Implementability Second sentence states "One process in particular has been demonstrated ........ " Identify process. 'l'his section should also address the reliability of the technology. Cost -This alternative must be costed out for both onsite disposal and offsite disposal. Overall Protection of Human Heal th and the Environment -This section is not representative since the majority of the risks associated with the site are from the TCDD/TCDF concentrations at the site. This section should be rewritten. General -This alternative should include a diagram showing the treatment unit and the various steps in the treatment train. Section 5.3.6 -This alternative must be developed for both onsite and offsite disposal.. Costing must be developed for 5000 CY, as per discussions on the range of soil volumes, and for the potential use of rail line as well as transporting by truck. Compliance with ARARs -Section 266 .104 ( a) ( 3), ( e) are clearly ARARs that must be included in this section. The potential delisting options for the ash must be identified and addressed in this section. Short-term Effectiveness -Justify 6 months. This seems like a very short period of time given the requirement of the trial burn and the associated analytical confirmation of an adequate burn. Long-term Effectiveness -See general comment on information needs, but elaborate on residuals including the ash and scrubbers and associated carbon units, etc. KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 11 • Reduction of MTV -See comment of Reduction of MTV under Section 5.3.4. Implementability actual permit, but met. On-site incineration would not require the all substantive requirements would have to be Specify how public participation may affect the implementability of this alternative. This section implies that an on-site incinerator would be readily available; that has not necessarily been the case in Region IV. Mobile units sometimes take a substantial waiting period. This should be acknowledged in the text. Cost -This alternative must be developed (to include costing) for both onsite and offsite disposal. Number 1) under Cost, page 5-18, What is "Throughput"? Section 5. 3. 7 -Please note that the compliance history of a facility would be a factor in the selection of a facility, though this requirement would not be listed under Compliance with ARARs. Short-Term Effectiveness -Define the time until protection is achieved. Reduction of MTV -Please refer to the previous comments regarding the required information for this criteria under the detailed analysis. Implementability -This information needs to be updated. There is a permitted facility available. More thorough information concerning the transporting of the waste, administrative requirements (manifests, etc.) should be discussed at a level of detail in this section. Section 5.3.8 Short-term Effectiveness alternative would require -Define the time period that for implementation and protection. this Implementability -The potential administrative problems with this alternative must be addressed in this section. Specifically, the State of North Carolina should be contacted to provide further detail. Remedial Response Unit Two-Groundwater -All comments made for Alternative 5.4.1, Alternative 3, also apply to Alternatives 4 and KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 12 • 5, but will not be specifically reiterated. The headings for the alternatives imply that the discharge would be to the surface water, thus requiring an NPDES permit if discharged offsite, or the substantive requirements of such a permit if discharged onsite. Yet the text implies that the discharge may be to a local POTW. The text must clearly imply which is the more feasible and whether or not there is true consideration to discharging to a local POTW. Section 5.4.1 Compliance with ARARs -List the specific MCLs that apply to the site. Short-Term Effectiveness -Provide a specific time that would be required to begin extraction as well as the estimated time that would be required to meet remediation objectives. Reduction of MTV -Address the degree that the treatment is irreversible and the degree that the inherent site hazards are reduced. Implementability -The administrative activities of getting (or meeting) an NPDES discharge permit should be discussed at length in this section. Section 5.4.2, General Comment -See general comment associated with section 4.1.9. Short-Term Effectiveness -Define times for implementation and achieving cleanup standards. Page 5-29. fist paragraph. fourth sentence -Sentence should read "depending on" . Long-Term Effectiveness Provide more complete information regarding the breakthrough of pentachlorophenol, whether it happened, expectations of when breakthrough would occur for penta under site conditions if/when this alternative is implemented, etc. Section 5.4.3 - Short-Term Effectiveness -Clarify and identify the risks referred to in the first sentence in this paragraph. Reduction of MTV -Discuss the degree to which the treatment technology is irreversible. Implementability -Provide specific time periods for implementation KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, · 1992 Page 13 • as well as estimates for achieving protection. Section 5.5. Remedial Response Unit Three -Surface water -The Medlin Pond must be included and developed for this entire section. The same considerations regarding the final discharge point, whether to the local POTW or to the surface water (onsite or offsite) must be clarified. The disposal of the fish must be discussed in detail. This might best be addressed under the Implementability criteria, under administrative feasibility. Fish disposal requires analytical data to determine the proper disposal method. Short-term Effectiveness -Define the time periods required for implementing and achieving protection. Implementability -The administrative feasibility and associated requirements of permits should be addressed. Table 5-1 -Explain the difference between 60 and 70 CY in the capital costs. Provide a key that defines the units and any other abbreviations or acronyms used in the Tables. Costs must be developed out for a potentially greater area. More detailed information must be provided on the monitoring program. Fencing should be included as a component of the cover alternative due to security concerns. · Table 5-2 -What is the difference in the unit costs for different soils? for the differences between soils in capping and covering? Permits should be identified and associated costs explained. Table 5-3 Where is the cost associated with analytical determination of adequate soil removal? Define the permits •. The cap for onsite landfill would have to be BOAT, which is probably currently defined as a RCRA cap. Why are the costs for the Cap and for the cap over an onsite landfill so different? They should be fairly similar. Table 5-4 -Dollar amount for the analytical requirements appears KOP.8692.SC • Koppers Company Superfund Site Morrisville, North Carolina EPA Comments on Feasibility Study August 6, 1992 Page 14 greatly insufficient. • Table 5-6 -Costs should be developed for utilizing rail for transport as well as the costing for trucking as presented. Where are the costs for analytical confirmation of adequate soil removal? Table 5-14 -This table is illegible due to copying and reduction. Section 6. 0 -Provide a brief description of the Recommended Remedial Action Alternatives in the first section identifying all components of the overall remedy. Section 6 should be modified to incorporate all changes such as soil volume ranges and associated costs. Costing for rail in addition to trucking only. Appendix B, A laboratory evaluation of activated carbon adsorption for the Morrisville groundwater indicated a carbon use of 0.5 lbs per 1000 gallons, but the design value used was O. 7 lbs. Why the inconsistency? Page 2-1. Paragraph 3 -This paragraph discussed "two extra drums of C-29 groundwater" used in the treatability study. However, the preceding paragraph identified that the 1,000 gallons of groundwater used were collected from C-30 (550 gallons) and PW-1 (450 gallons). Why the inconsistency? ~A~p~p~e~n~d~i~x,,__,B"-'-1 ~P~a,..,.g~e__.4_-~2~d~,---=T~ab=l~e.__4~--=-3 -The title for the fifth column appears incorrect as "Percent % Removal ( % ) • Should this be percent TOC removed? KOP.8692.SC ECO .TEL N0.804 798 4305 • Jun 16-92 13:43 P.02 t- PROFESSIONAL WASTE MANAGEMENT CONSULTANTS Ms. Batbara Benoy E NVIRONMENT AL COMPLIANCE 0 RGANIZATION June 12, 1992 U.S. Environmental Protection Agency NC/SC Site MaDAgmnent Unit Superfund Branch Waste Management DiviGion 345 Courtland Strec,t, NE Atlanta, Georgia 30365 VIA fAAiJMD,p; ANP U,S, NAll1 Dear Batbart: I 06 ROBINSON STREI ASHV<NO, VIRGINIA 23()( (804) 798-43( This letter transmits comments to the Dratt Feasibility Study Report for the Koppers, Morrisville NC. sile. Please note that these oommems include the collOffllll and commentary of the citiz.ens of the Clean Water and Environment Projoot. For the sake ofb~ty. we have not included comments to this repon that would duplicate issues we have already discussed in previous submissions, or which you and J have dlscusaed in our telephone conversations. I would however, like to additionally convey to you the overwhelming enthusiasm on the part of the residents fur utilizing the dechlorination process described in the PS as Alternative 7 for R.RUI. Our chemists have thoroughly reviewed the trcatability analysis included in the PS appendices, and a.re researching fiinher literature regarding this process, which on the face appears to be a potentially viable option for the site. Any further infonnatlon, or results from EPA projects where this process bas been tested would be greatly appreeiated. Thank you fl>r keeping us up to date, and pr6viding us with nocess111y information in such a 001Jrtcou& and timely fuhion. Please let me know if you require further infurmation or clarification roprding community sentiment, concerns, or preferences. PME/ms s.• t\.U • tL 1•1u. tsu<l , 'jo 4.:,u::, ) U (I 1 0 • ·:• -l :, ; 4 0 r , U,) COMMUNITY AND TECHNICAL ADVISOR COMMENTS DRAFT FEASmlLITY STUDY REPORT FORMER KOPPERS COMPANY, INC. SUPERFUND SITE MORRISVILLE, NORTH CAROLINA General Comments The community, and ECO submit the followiug commeuts, which are intended to stand with previous comments and concerns. Specifically. we reiterate here, bul do not list in the body of comments, our concerns regarding the technical quality of sampling data. omission of major exposure pathways from evaluation. and the lack of sufficient sampling data for PCDD and PCDF. These. problems were noted in the Remedial Investigation end Baseline Risk Assessment Reports on which the Draft Feasibility Study is based, and therefore must be considered problematic in the FS. Above, and beyond existing concerns, we are troubled by the failure to address and evaluate any alternatives for remediation of Medlin Pond and its outflow. Although the Baseline RA fails to construct Md evaluate a scenario whereby the surface waters of Medlin Pond and its outflow represent a source for potential exposure, it is clear from extrapolating data generated regarding the Fire Pond that Medlin Pond poses a similar or greater risk. For instance, Fire Pond turface water penta levels range from 0.043 ug/kg to 0.168 ug/kg, in general correlation with the Medlin Pond levels of 0.079 ug/kg to 0.150 ug/kg. The Fire Pond, which ENSR calculated as exceeding the E.PA Target Risk Level for caroinogcns, largely due to dioxin content, had a PCDD/PCDF TEC high of 490 ng/kg. The Medlin Pond exhibited the highest PCDD/PCDF TEC of any surfiwe water body sampled, at 1,000 nglk:g. 2,4,6 tricblorophcnol, which is an EPA listed carcinogen., was detected in the outfall and discharge ditch of the Medlin Pond, further increasing the potential risk level for exposure to this area. Additionally, ENSR's evaluation of ecological chronic toxicity quotients for Medlin Pond fell into the range of possible concern. 1 E NVIRONMENT AL COMPLIANCE 0 ROANIZATION ECO • TEL N0.804 798 4:SuS • The access control (fence) currently in place arowid the Medlin Pond does not sufficiently address the real and potential risk, and cannot be considered as a final alternative. The pond area, although now owned by Beazer, lies outside the relatively secure industrial area, and is adjacent to solely residential, cW'I'Cntly inhabited pro~. The fence is not totally access proof: and the pond is an attractive nuisance due to its extensive use in the past for swimming. The outflow and ditches from Medlin Pond are not access controlled, and pose a risk according to the RI sampling data. Finally, all access and institutional controls fail to reduce the risk posed to ecological receptors, and the environment portion of the protecting human health and environment CERCLA mandate. Having noted our serious dispute with the area considered for remediation, the community is an agreement with the method (although not the possible extent) of remediation preferred to address RRU2 (ground water). The community is also in agreement over the preferred remediation method for RRU3, (swfacc water), but seriously questions the failure to consider sediment remediation in this unit. The community is not in agreement that the preferred alternative for RRUl(soils), involving excavation and off-site incineration, is the best remedial alternative. CWEPS believes that a revaluation of the option, based on comments provided below reflecting community sentiment, as well as technical concerns is wamnted. The citi.uns ofCWEPs, are ooanimous in their preference of Alternative 7, (excavation and treatment by dechlorination processing) for the remedjation of contaminated soils. This preference is in keeping with the original request made by the group. asking that alternative technology be seriously considered for the site, and is also In best accord with the intent of the Superfimd Amendment and Reauthoriz.ation Act. 2 E NVIRONMENTAL COMPLIANCE 0 RGANIZATI0N , ECO • EL N0.804 798 4305 • SECTION COMMENTS Executive Swnmary Page ES-5 • In evaluating ARARs, was there any calculation regarding dle levels of 2 Chlorophenol present in soils, that ere protective of the North Carolina MCLS for ground water? ECO believes that state water quality standards are applicable and releyant, and that some work is required in this regard. al1hough at present this constituent is non-detectable in the sampled ground water. Page ES-7 -As stated above, there is serious concern regarding the failure to address the sediment contamination documented for the Fire Pond. 111ere can be no adequate assllllUlce that ground water is being protected to MCL requirement, when heavily co11tarnioated sediments are allowed to remain in situ. Page ES-7, paragraph 2 -This section states that community acceptmce was 11 primary screening factor used to arrive at preferred remedial alternatives. We would like elucidation of how this acceptability was measured. since the community was not directly consulted. Section 1.0 -Introduction Page 1-5, paragraph 1 -Again, we would note demonstrated problems with Keystone'& analytical results in July, 1980. Page 1-12, paragraph 2 -This uction details the demonstrated oontarnioatin11 of die land&nn area soils with 2 Cblorophenol. Again, we would ask that some calculation be made correlating the soil levels present, VCl'lim the llOil lew:ls expected to be protective of groUDd water standards. 3 E NVIRONMENTAL COMPLIANCE 0 ROANIZATION , ECO .TEL NIJ. 804 738 4305 • Jun 16-92 13:so P.06 Page I -24, paragraph 3 -Low degradation rates for PCDD/PCDF in sediment are noted. · Page 1-32, full paragraph 2 -This section describes the chronic toxicity levels to ecological receptors in Medlin Pond as "of possible concern", but fails to give a discussion of why this unit is not further considered for remediation. Page 1-33, paragraph 2 -contains a typographical error that changes the meaning of the sentence. ECO will assllllle tluu land use restrictions would prevent future residential and recreational uses. Section 2.0 -Identification und Screenipg ofTechnologies/PrOQCss Options Page 2-7, paragraph 2 -ECO believes that cleanup goals derived to be protective of ground water quality were chosen because they represented the most aggressive cleanup standards. However, some statement should be made dutt lhcsc cleanup goals are more conservative than clean up goals based on lowering risk to acceptable health based levels. Section 6,0 • Recqmrnmdr4 RgpNtial Altematiyea 6.1 RRUl-soils . Page 6-2 ~ Since, there are no approved facilities in the_ United States capable of treating, storing or ttisposing of dioxin contaminated soila, we would like an explanation of how land filling or incineration meet the relevant standards. 4 E NVlllONMENTAL C OMPLIANCB 0 ROANIZATION , tLU • Jun 16,9:2 13:51 P.:J7 Page 6-3 -Long Tenn Effectiveness -We would disagree that incineration, either on or off site represents the most effective method of removing long tenn risks. As stated above, incineration is considered an experimental technology, and there are no cWTCDtly approved incinerator facilities capable of h.andling dioxin, Combustion of any constituent is not complete under variable conditions of the kiln, and by· products such u air emissions and ash, which may oontain toxic contaminants, are always produced. Solid by-products mutt additionally be disposed of, normally in a landfill, and the generator retains a degree of liability should the land fill facility require future remediation. We would also question the weighting of Alternative 7 as a potential for long tenn risk. ECO's evaluation of the treatability study for the dechlorination process suggests that the resulting soil levels of the COis will be much lower than the levels that Keystone has presented as being conservatively protective of health and ground water quality. It is also our understanding that because the site will not be remediated to clean, background levels under any scenario, that continued monitoring and use restrictions will be required regardless of which remedial alternative is employed. Therefore, it seems incorrect to weight the universal need for these controls against onJy selected remedial options, and doing ao results in false bias for Alternatives 6, 8 and 9. Page 6-4 • Reduction of Toxicity, Mobility, or Volume -Again, it appears that this comparison is not subjective as to all altcmativc:s analyzed. The potential for producing PCDD containing treatment waste is weighted against Alternative 7 only. Conversely, no mention is made of the fact that fly ash from any organic combustion reaction is likely to contam dioxins and furans, and this potential is not weipled apinst Alternatives 6, 8 and 9. Page 6-5 -Implementability -Alternative 9, as well as Alternatives 6 and 8, is not implementable given the non-existence of facilities licensed to handle dioxin contaminated soils. s E NVIR.ONMENTAL COMPLIANCE 0 RGANJZATION ECO • TEL l~O. 304 798 430S • Jun 16,92 13:51 P.OB Page 6-6 -Present Worth Costs· We disagree with giving cost factors equal weight to technical, health and practical concerns. It is proper to evaluate cost, only in tenns of orders of magnitude. Therefore, since all alternatives have associated monetaly costs that are within relatively the same range, this evaluation should be dropped from consideration in the numerical charting (table 6--1), or all alternatives should be assigned equal weight. Page 6-7-Overall Protection ofHwnan Health and the Environment• Again, there appears to be arbitrary assignment of assets and faults ascribed to the discussed alt.ernatives. Since incineration is listed as destroying COis, Alternative 7 must also be listed in the most protective group. As stated above, incineration doe5 not completely destroy all organic compounds, and there is a potential for conoemration of heavy metals, dioxin and funulS in the ash that rctnains for long tenn disposal. While, the removal, incineration and ultimate disposal of contaminants may be effective in regard to this site, it is does not provide the best overall protection in general, as it rcprcscuts the paradox of moviug a problem, at great expense, from one location to another where it may eventually present a health or environmental risk. This type of ineffective problem shifting prompted the reforms of SARA, which emphasized on-site treatment, the use of alternative technologies wherever feasible, detoxification of c~tatniuants and a preference for permanent solutions. CWEPS believes that proposed Alternative 7 best meets the letter and the spirit of the statutOty requirements of SARA, as well as its goal ofprotectins human health and the environment. 6 E NVIRONMENTAL C OMPUANCE 0 ROANIZATION .. • • United States Department of the Interior OFFICE OF TIIE SECRET ARY Office of Environmental Affairs Richard B. Russell Federal Building 75 Spring Street, S.W. Atlanta, Georgia 30303 May 26, 1992 ER-89/337 Ms. Barbara H. Benoy North Carolina Remedial Section North Superfund Remedial Branch U.S. Environmental Protection Agency 345 Courtland street, N.E. Atlanta, GA 30365 Dear Ms. Benoy: This letter is in response to your April 20, 1992, request to the Fish and Wildlife Service (Service), Rale.igh Field Office for comments on the revised draft FS for the Koppers Company, Inc. Site, Morrisville, Wake County, NC. These technical assistance comments are intended to assist your investigation, assessments, and the planning process being conducted pursuant to Section 104 (a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (42 u.s.c. 9601 et seq.). We are concerned that the remedial alternatives evaluated in the FS may not be addressing the full scale of environmental hazards at the site. The Service has identified, through written comments on the draft Derivation of Clean-Up Levels Report, draft Public Health and Environmental Assessment, draft Revised Remedial Investigation Report, and the draft Baseline Risk assessment, the following data gaps and inadequacies in the ecological risk assessments performed for the site: The ecological risk assessment for the belted kingfisher, particularly dose-response values used as the foundation for the assessment, should be revised after review of available toxicological literature concerning sensitive avian species and sensitive endpoints. Until the avian risk assessment is revised, the Department cannot concur with statements on page ES-4 of the FS that remedial actions are not necessary for ecological receptors or that clean-up levels based on risk to eqological receptors are not required. 11 t:SIT EPA -REG!Oll IV ATLANTA, GA • Fish tissue and sediment dioxin and furan residues should be further evaluated, particularly the extent to which contaminated sediments influence water and fish tissue dioxin concentrations. Sediment and surface water bioassays are recommended. There is a lack of data for dioxins and furans in the western drainage ditch and associated wetlands. We refer you to Department's October 20, 1989, Preliminary Natural Resources Survey, and the Service's March 12 and April 10, 1992, letters on the site for further details on these issues. We emphasize that these technical deficiencies are not merely academic; the results of a revised avian risk assessment and evaluation of the significance of sediment dioxin concentrations may influence numerical clean-up goals, the media in need of remediation, and the areal extent of clean-up needed for the site. Finally, the FS 's discussion of wetland mitigation related to remedial alternatives for the Fire Pond should be revised to include restoration of aquatic and upland habitats lost due to filling the pond. A habitat restoration plan, of which wetlands mitigation will be an essential component, as the final stage of the ultimate remedy would be appropriate. We encourage the U.S. Environmental Protection Agency to address these data needs so that the Final FS, Record of Decision, and Proposed Remedial Action Plan for the Koppers Company, Inc. site are based on an adequate information base with respect to ecological risks. If you have any questions, please contact Mr. Tom Augspurger in the Service's Raleigh Field Office (919/856- 4520). Sincerely, James H. Lee Regional Environmental Officer cc: FWS, Raleigh, Atlanta OEA, Washington • • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary Ms. Barbara Benoy U.S. EPA Region IV May 22, 1992 North Sites Remedial Branch 345 Courtland Street, N.E. Atlanta, GA 30365 Re: Comments on the Feasibility Study Koppers Company NPL Site Morrisville, Wake County, NC Dear Ms. Benoy: William L. Meyer Director The NC Superfund Section has reviewed the April 1992 Feasibility Study (FS) and offers the following comments: 1. Page ES-4. The FS States that EPA is re-evaluating the slope factor for dioxins and that "when more recent and scientifically appropriate and defensible estimates of the carcinogenic potential of PCDDs/PCDFs [dioxins) are employed, then the upper bound assumed excess lifetime cancer risks fall within the EPA's target risk range ••• " This statement should either be explained in complete detail or left out of the report entirely. The current wording and placement of the statement is confusing. It seems to imply that they know what the new EPA slope factor will be and that dioxin risks have definitely been· overstated in the past. The risk for the site is based on the current EPA slope . factor which is, at the moment, the most defensible and scientifically appropriate risk riumber. 2. Page ES-5, Remedial Action Objectives. One of the stated objectives is to clean·up soils to 95 mg/Kg pentachlorophenol _and 7.0 mg/Kg for PCDDs/PCDFs. Please note that the State of North Carolina has not accepted these levels and has made comment to this effect in the past (20 April 1992 letter). We see their inclusion in this report as necessary to make remedial volume and cost estimates. However, the final decision on cleanup levels. will be made in the ROD. The State's position remains consistent with our previous comments concerning cleanup levels. M Equal Opporturity AfflrmadYe Actlon Empio)'cr • Ms. Barbara Benoy April 20, 1992 Page 2 • 3. Page 2-9. The FS provides estimates of the volume of contaminated soil in various areas. These estimates are based on information from the Remedial Investigation. However, the volumes of soil are based on one or two sampling locations and two or three depths. Furthermore, it does not account for factors such as volume expansion upon excavation and for the fact that the excavations will have to have sloped sides to excavate 8 to 10 feet deep. It seems that 946 cubic yards would be a minimum amount and that the soil needing treatment is likely to be more than that. Furthermore, the estimated excavated amounts are based on cleanup levels that may not be appropriate (see Comment 2, above) . 4. Page 5-26. The FS states that "the fluidized bed biological reactor would remove 90% of the constituents of interest and the activated carbon units would remove the remaining 10%.11 It is suggested that this be revised to say that the carbon units will remove X% of the remaining 10% of the constituents of interest so that it is not misconstrued that 100% of the constituents of interest will be removed by this method. Furthermore, are these percentages based on anything real or are they assumptions for the purposes of estimating costs? Either way, please clarify. 5. Table 5-7. If appears that cost for RRUl-Alternative 9 has been slightly underestimated. The final cost is $2,000 per cubic yard. This is the approximate gate rate alone for incinerators we have costed in the last year. 6. Tables 5-9 and s-10. When comparing RRU2-Alternative 3 with RRU2-Alternative 4, the difference lies in the fact that alternative 3 uses carbon to "polish" treated water and Alternative 4 uses carbon for the entire treatment. This should make a difference in the size.and design of the carbon adsorbers required to do the job. Alternative 3 should· require a less expensive carbon adsorber than does Alternative 4. However, in these cost estimates it appears that the same carbon adsorber would be used in both. 7. After our discussions last week, the state is aware of potential problems with having incinerators accept dioxin-containing wastes. Have these potential problems been examined and is acceptance of the.waste anticipated? • Ms. Barbara Benoy April 20, 1992 Page 3 • The NC superfund Section appreciates this opportunity to provide these comments, and we look forward to continued cooperation on this site. If you have any questions concerning these comments, please contact me at (919)733-2801. bin\let\kopfscom attachment cc: Jack Butler Bruce Nicholson Chemical Engineer Superfund Section • KEYSTONE E:,,;\'JR<lNMENT,\L RESOURCES. li",C. 3000 Tech Center Drive Monroeville, PA 15146 412 825-9600 FAX 412 825-9699 May 4, 1992 Ms, Barbara Benoy, Remedial Projects Manager U.S. Environmental Protection Agency NC/SC Site Management Unit Superfund Branch, Waste Management Division 345 Courtland Street, NE Atlanta, GA 30365 Dear Barbara: Re: Koppers Superfund Site Morrisville, NC Feasibility Study Report -Inserts SUPERFUl\lD SECTION Ref No, 179280-09 In a subsequent review of the "Draft Feasibility Study Report, Former Koppers Company, Inc. Superfund Site, Morrisville, North Carolina" dated April 1992 submitted to you April 16, it was discovered that there were some inadvertent omissions from the report. Therefore, enclosed for inclusion in the document are Table 1-2 and the revised list of tables, to be included with the tables for Section 1.0, and a List of Acronyms, to be inserted immediately after the Table of Contents. Eleven copies of the inserts are enclosed for you use and distribution, Copies are also being sent to the individuals listed below. I apolo~ize for the over.sig\1~.-. If you ~ave __ any questions on the enclosures, please do not hesitate to call Ms. ,Shannon Cra1g-or_mei"· · ,· · ,1,: .,;:--,; ,:-,_. . ' •II .:.It: ~! ·' .,t :~· :~.:-'. Very truly yours, c:,,:/4,v. e.: //Jl{, ~ /2:.e;ti r'ohn C. Mitsak, P,E,, .__ · Manageir, Bal.!i,ili.?r,eOp_~ta~ons JRM:JE:~j&w jm,444 .. , • • ' • •• 'w''' ,\, ,/ '•• • • Attach. ~ 11 Copie~ .... l' '• ./:,•' ;·,.-.~ ; I " . . . . cc: Ms. Pat DeRosa, NC Superfund (2) Ms. Doris Giles -TAG : - · Ms. Pauline Ewald'~'-'(A_G'? Mr, Robert Krasko, Dyrtamac,·· Mr. Tom Augspurge,J-0 .. NOAA'::·:, Shannon Craig~ BEi 0·•,,< ·.-. '-· A CHESTER Environmental Company • • • • Table Title SECTION 1 LIST OF TABLES • 1-1 Chemical and Physical Constants of Potential Constituents of Interest (COis) 1-2 Summary of Remedial Goals, Clean-up Levels Evaluation Morrisville FS 179280-09 BM(DCC#R0302 4/'12 • COMMERCIAL/INDUSTRIAL SITE USE TABLEJ6. SUMMARY OF RE!.9AL GOALS CLEAN-UP LEVELS EVALUATION FORMER KOPPERS COMPANY, INC. SITE BEAZER EAST, INC., MORRISVILLE, NC Human Health Soil Target Level Existing Maximum RBTCL(a) for the Protection of Medium/ Area Constituent Concentration (ppm) Surface Soil/ Area C Pentachlorophenol PCDDIPCDF Subsurface Soil/ Area C Pentachlorophenol Fish/Fire Pond PCDDIPCDF RESIDENTIAL SITE USE Surface Soil/ Arca C Pcntachlorophenol PCDDIPCDF Subsurface Soil/ Area C Pentachlorophenol Surface Water/Fire Pond PCDDIPCDF Fish/Fire Pond PCDDIPCDF Groundwater/ Pentachlorophenol Former Lagoon Area PCDDIPCDF Groundwater/ Pentachlorophenol Eastern Area PCDDIPCDF Notes: ARAR -Applicable and Relevant or Appropriate Re.quirement. MCL -Maximum Contaminant Level. RBTCL -Risk-Based Target Clean-up Level. 3220 0.3 560 4E--05 3220 0.3 560 3E--07 4E--05 1.5 BE--08 0.05 2E--07 (ppm) Grouodw~r (b) (ppm) 2250• 95 0.001 0.007 2250• 95 2E--05 - 500 95 0.0001 0.007 2250• 95 2E--08 - 5E--06 - 0.004 - 3E--09 - 0.004 - 3E--09 - (a) -Human Health RBTCls were derived for the IE-OS risk level, using alternate degradation rates for soil (sec text). Soil RBTCLs for PCOD/PCDF for Commercial/Industrial Site use arc for On-Site workers. (b) -Soil Target Levels for the Protection of Groundwater (Keystone, 1992a) arc compared to maximum concentrations. (c) -ARARs for PCDDIPCDF arc derived for 2,3,7,8-TCDD. • -RBTCL for sub-chronic effects (sec text). --Does not apply. North Carolina Federal ARAR ARAR (MCL) (c) (ppm) (c) (ppm) - - - - - - -- -- - - - - -- - - -0.001 2E-l0 5E--08 -0.001 2E-10 5E--08 (Adapted from Table 9-2 of ENSR Draft Baseline Risk Assessment for The Former Koppers Company Inc. Site, Morrisville, NC, March 1992) BMIDCCR0302 4192 • Recommended Clean-up Goal (ppm) 95 0.007 95 • 2E--05 95 0.007 95 2E--08 5E--06 0.001 SE--08 0.001 SE--08 • • • • • • MORRISVILLE FEASIBILITY STUDY ACRONYM INDEX FORMER KOPPERS COMPANY, INC. SITE BEAZER EAST, INC. MORRISVILLE, NORTH CAROLINA ACRONYM DESCRIPTION APEG- ARAR- atm- BAT- BCT- BDAT- CERCLA COi- C\VA- DAF- DMSO- EPA- FS- g- GC- HDPE- HI- IPE- Morrisville FS A patented dechlorination process using an alkaline solution of potassium hydroxide and polyethylene glycol Applicable or Relevant and Appropriate Requirement atmosphere best available technology best conventional technology Best Demonstrated Available Technology Comprehensive Environmental Response, Compensation, and Liability Act of 1980 Constituent of Interest Clean Water Act Dissolved Air Flotation dimethyl sulfoxide Environmental Protection Agency Feasibility Study gram gas chromatography high density polyethylene hazard index isopropyl ether 179280-09 BM/DCC#RD302 5/92 • • • ACRONYM Kg- Koc- Kow- Kp- 1, L - LDR- MCL- mg- MI- mol- MS - NAPL- NCDHR- NCP- ng- NPDES- NPDWR- PAH- PCA- PCB- PCDD- PCDF- Penta - PEP- PHEA- pKa- Morrisville FS DESIPTION kilogram organic carbon partition coefficient octanol water partition coefficient soil-water partition coefficient liter Land Disposal Restriction • Maximum Concentration Limit, Maximum Contaminant Level milligram Mobility Index mole mass spectroscopy Non-aqueous Phase Liquid North Carolina Department of Human Resources National Oil and Hazardous Substances Pollution Contingency Plan nanogram National Pollution Discharge Elimination System National Primary Drinking Water Regulations polynuclear aromatic hydrocarbon pentachloroanisole polychlorinated biphenyl polychlorinated -p-dibenzodioxin polychlorinated dibenzofuran pentachlorophenol Potential Exposure Pathway Public Health Environmental Assessment dissociation constant 179280--09 BM/DCC#R0302 5/92 ACRONYM DES"P'fION • • ppb-parts per billion ppm-parts per million PO'IW-Publicly Owned Treatment Works PQL-practical quantitaion limit PW-Pumping Well RA-Risk Assessment RBTCLs-risk based target cleanup levels RCRA-Resource Conservation and Recovery Act RI-Remedial Investigation RI/FS-Remedial Investigation/Feasibility Study RRU-Remedial Response Unit SARA-Superfund Amendments and Reauthorization Act SBR-Sequencing Batch Reactor • SOWA-Safe Drinking Water Act TAL-Target Analyte List TCDD-tetrachloro isomers of dioxin (PCDDs) TCDD-TE-TCDD toxic equivalents TCE-Toxicity Equivalent Concentration TCL-Target Compound List TEA-triethylamine TEC-Toxicity Equivalent Concentration for dioxins TOC-total organic carbon ug-microgram USEPA-United States Environmental Protection Agency USGS-United States Geological Survey UV-Ultraviolet • Morrisville FS 179280--09 BM/DCC#R0302 5/92 • • ACRONYM DESCRIPTION • voe-Volatile Organic Compound WAO-Wet Air Oxidation • Morrisville FS 179280-09 BM/DCC#R0302 5/92 . -.~ . .,. ROUTING AND TRANSMITTAL SUP 2. 3. 4. 5. Action FIie NotEI and REltum Approval For Clearance Per Conversation As Requested For Correction Prepare Reply Circulate For Your lnformBtion See Me Comment Investigate Signature Coordination JuStity DO· _NOT use this form as a RECORD of approvals, concurrences, dl~posals, clearances, and similar actions FROM: (Name, org. symbol, Agency/Post) Room No.-Bldg. OPTIONAL FORM 41 (Rev. 7-76) PrHcdbed bJ' GSA FPMR(41 CfR)1O1-11.2O8 ---;;~;--'----•'------'-----Date ROUTING AND TRANSMITTAL SLIP TO: (Name, office symbol, room number, Initials Date building, Agency/Post) 1. 2. -3. 4. 5. Action File Not& and Return Approval For Clearance Per Conversation As Requested For Correction Prepare Reply Circulate For Your Information See Me Comment Investigate Signature Coordination Justify 'REMARKS DO _NOT use this form aS a RECORD of approvals. concurrences. disposals, · clearances, and similar actions FROM: (Name. org, symbol, Agency/Post) 5041-102 11, U.S. CPO: 1990-254-313 Room No.-Bldg. Phone No. OPTIONAL FORM 41 (Rev. 7. 76) _Pr11erlb1d by GSA FPMR(41 CFR)101-11.208 • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV APR 2 0 1992 4WD-NSRB Pat DeRosa Bruce Nicholson Superfund Section N.C. Division of Solid Suite 150 401 Oberlin Road 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Waste Management Raleigh, North Carolina 27605 Re: Koppers Company Superfund Site Morrisville, North Carolina Dear Ma. DeRoaa and Mr. Nicholson: This letter is to request comments on the Revised Draft Koppers Feasibility Study (FS) Report. Please review the FS and submit your comments to me by Friday, May 15, 1992. If you are unable to provide your comments by this date, please inform me as to when I can expect them. In the event I do not hear from you by May 15, 1992, I will assume you are not planning to submit {___,,, C-y_ ./-(_,.,Id fe, /YI "'q-2.--2.. 1 l'l'l ,._ ~ comments. Please contact me if you have any questions or suggestions concerning this letter. I can be reached at 404/347-7791. ~~· •='=• •. '"""' ~ Remedial Project Manager Waste Management Division cc: Curt Fehn, EPA Elmer Akin, EPA Cathy Winokur, EPA-ORC Lee Crosby, NCDEHNR William Meyer, NCDEHNR Robert Kraska, Dynamac Shannon Craig, Beazer John Mitaak, Keystone Printed on Recycled Paper ~ c~~,1~/ .. -. ~ o «c . • • ~A <'c ~t~ <'~ ·-::-<"/\ ~ ~v State of North Carolina ~),; 1/ Department of Environment, Health, and Natural Resources :Z:,1-- Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27604 James C. 1"1.artin, Governor \\'.filliam W. Cobey, Jr., Secretary December 10, 1991 George T Everett, Ph.D Din:ctor M E M O R A N D U M TO: FROM:- SUBJECT: Lee Crosby, Head Superfund Section t . t ,:\ 1c6._ ~ George T. Everet , Di rec or ,,J;}1. I Division of Environmental Management Koppers Co., Inc. NPL Site Review of Feasibility Study Report Proj # 97-62 Wake County Morrisville, NC The Division of Environmental Management has reviewed the subject report as requested, The comments· from our Water Quality, Air Quality and Groundwater Sections are provided below: Water Quality Section: In reference to the subject document, it is stated in Section 6.2 {page 6.4) that alternative 4, "groundwater collection, pretreatment and carbon acisorbtion with surface water discharge", is being considered to treat groundwater at the Koppers Company Site. Although an application for a National Pollutant Discharge Elimination System (NPDES) surface water permit is not required, we would like to emphasize that you still have to comply with all NPDES regulations if surface water discharge is planned. Additional information concerning surface water discharge regulations can be obtained from Dale Overcash at 733-5083. Asheville 704/251-<5208 Fayettev·1l1e 919/48&154I Mooresville 704/663-1699 Regional Offices Raleifrn 919/733-2314 Wash'1ngton 9191946-<548I Pollution Prevention Pays Wilmington 919/395-3900 PO. Box '2?535, R.1!eigh, North Carolina 27626-0535 Telephone 919-733-70!5 An EquJ.I Opportunity Affimmivt· Action Employer Winston-Salem 919/761-235 I • • Air Quality Section: The subject document appears to contain no significant air quality concerns. Other than possible on-site groundwater remediation, i.e. air stripping, which would require source registration as per 15A NCAC 2d Section .0202. Otherwise, no further Air Quality review is warranted at this time. Groundwater Section: The system design should allow for the restoration of the groundwater to the levels at 15A NCAC 2L .0202. All recovery wells installed at the facility shall be permitted by the Division of Environmental Management in accordance with 15A NCAC 2C. Additional information will be necessary to determine the effectiveness of the corrective action system and to prove that the location of the recovery wells will clear up the groundwater and prevent further migration of the contaminant plume. Should you need any additional information, please contact Arthur Mouberry, Raleigh Regional Office at (919) 571-4700. 002.RGE Attachments cc: Perry Nelson Steve Tedder Lee Daniel Arthur Mouberry Nargis Toma File • • • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary William L. Meyer Director October 21, 1991 Ms. Darcy Duin NC/SC Site Management Unit Superfund Branch Waste Management Division 345 Courtland Street, NE Atlanta, GA 30365 Subject: Koppers, Company, Inc. NPL Site Draft Feasibility Study Report, August 1991 Dear Ms. Duin: I have reviewed the subject draft Feasibility Study and my comments are listed below for your review. In addition, parts of the report were also reviewed by Dr. Luanne K. Williams, Toxicologist, NC Superfund Section, and her comments are also attached. Overall, the most significant problem with this draft Feasibility Study is the limited nature of the Remedial Action Objectives identified. These address only the current or future scenarios where increased cancer risks are anticipated to exceed 1 x lo-4. Currently, the State of North Carolina considers any carcinogenic risk exceeding 1 x la" to be a significant risk which should be addressed. A complete listing of the additional scenarios with risks exceeding 1 x lo-6 are included in Dr. Williams' comments. Page. Para. # ES-5, 3 Comment 1. The risk levels calculated during the Baseline Risk Assessment pertain to PCDD's/PCDF's as discussed in p. ES-4. The first point of the Remedial Action objectives deals only with 2378 TCDD. Unacceptable risks posed by all PCDD's/PCDFs should be reduced as a Remedial Action Objective. . An Equal Opportunity Affirmative Action Employer 1-3, 1 1-6, 1 1-8, 2 1-12, 1 1-14, 2 1-16, 2 1-16, 4 1-17, 2 • • 2. What about dermal adsorption of PCDD /PCDF from the Fire Pond? This was identified as an unacceptable risk at the site (1.5 x lo-4) on p. ES-4. This risk is not addressed in the Remedial Action Objectives. 1. 1. 1. 1. What was the glycol-based co-solvent which was reportedly used for a short time on site? The thickness of the weathered bedrock unit was previously reported as "less than 10 to 30 feet" in the Draft RI p. 3-6, paragraph 1. However, on page 3-13 of the RI it says that competent bedrock was encountered at depths ranging from 20- 30 feet". Please explain. No penta was measured in the landfarm, eastern or western areas, however, acid extractable phenolics were detected. Please explain the statement regarding having defined· the vertical extent of contamination in the· former lagoon area. Was the hydraulic connection between these wells and the deep off-site wells checked during the pumping test? 2. Please explain how the horizontal extent of contamination has been defined. Where is the "clean" zone around the site in the "A and B" depth wells? Also, the off-site "C" depth wells and the residential wells in the area show traces of contamination. Where is the clean zone in the "C" depth wells? 1. 1. 1. 1. The TEC level in the Medlin Pond sediments (1000 ng/kg) at locations S-22 is significantly higher than the level in the Fire Pond sediments (35 ug/kg) at location S-4. The TEC levels in the Medlin Pond sediments are comparable to the TEC levels in the Fire Pond outflow sediments. In looking at the soil exposure pathways shouldn't the subsurface soil contamination pathway also include current local residents and on-site workers? How are teenaged trespassers evaluated as opposed to local residents? In the surface water exposure pathway, were future local residents considered? What about current residents at the Medlin property? Please explain how these were considered. What about excess cancer risks associated with ingestion of penta from groundwater in the former lagoon area by hypothetical future on-site residents (1.1 x 10"3)? A total HI of Fig 1-7 2-1, 1 2-4, 3 2-5, 3 Table 2-4 • 1. 1. 1. 1. 1. 2. 3. 4. 5. • 1.05 was calculated for this same pathway indicating adverse noncarcinogenic effects. These numbers would not change even if dioxin's carcinogenic potential is re-evaluated. The Round 2 samples are incorrectly labeled RDl instead of RD2. What are remedial response units? Same comments as ES-5, 3. Removal: "Measures to remove potential..." Add Article 1 to GS 130A, Article 9 under NG Solid and Hazardous Waste Management Act. Omit the word Chapter from regulatory citations. 15A NCAC 2H.0100. 15A NCAC 2H.0500-Water Quality Certification (Description). 15A NCAC 2B.0200 specifies Classifications and Water Quality Standards Applicable to Surface Waters of North Carolina. 6. 15A NCAC 2H.0900-Local Pretreatment Programs (Description). 7. 8. 9. 10. 11. NC Surface Water Standards: Monitoring, 15A NCAC 2B. 15A NCAC 2B.0200-Classification and Water Quality Standards Applicable to Surface Waters of North Carolina (Description). Effluent Limitations are described in 15A NCAC 2B.0400. Why was 15A NCAC 13A.0011 omitted? NC Groundwater Classifications and Standards 15A NCAC 2L .0100, .0200., .0300. 15A NCAC 2C Well Construction Standards; .0100 Criteria and Standards Applicable to Water Supply and Certain Other Type Wells; .0200 Criteria and Standards Applicable to Injection Wells. Table 2-5 Table 2-6 3-5, 3 4-2, 3 • • 12. Groundwater treatment systems may be subject to permitting as per 15A NCAC 2 D Air Pollution Control Requirements, specifically .0200 Air Pollution Sources. 1. 1. North Carolina Inactive Hazardous Sites Act. Citation: GS 130A, Article 9. Regulations cited in 15A NCAC 13C. The surface water quality standard for dioxins in WS Class waters of North Carolina is 0.000013 ng/1 as per 15A NCAC 2B p.24. \. 2. The groundwater quality standard citation in Note (a) should read 15A NCAC 2L.0202 3. In 15A NCAC 2B, p. 24 the State has established a water quality standard of 1 ug/1 for phenolic compounds. Section .0211 (b), (c), (d) or (e) of the same subchapter also dictate standards for phenolic compounds. 4. The groundwater and surface water quality standards for NC list "dioxin" rather than 2,3, 7,8-TCDD. The standard includes all the PCDD's/PCDF's addressed in the RI expressed in toxicity equivalent concentrations which are based on the toxicity of the 2,3,7,8-TCDD isomer. 1. 1. Although a permit is not required, discharge will need to meet the substantive requirements of a permit. Generally, there is some additional information we would like to have in order to determine whether the proposed groundwater pumping regime will induce a sufficient gradient to capture the contaminant plume. Some specific data gaps include: a) Areal and cross-sectional maps of the contaminant plume. b) Estimated cone of influence, pumping rates, and years of operation. c) Remediation of contaminants in wells which do not appear to be hydraulically connected to PW-l(i.e. C-25, C-11). 4-3, 5 4-4, 3 4-5, 1 4-8, 1 5-8,2 5-12, 1 • 1. 1. 1. 1. 1. 1. d) • Any special design considerations due to the density of PCP (i.e. precautions to ensure that contaminants are not drawn into deeper zones). How will solids from the backwash settling tank be handled? What is the purpose of the 24 hour residence time in the effluent tank? What evidence is their to support the assumption that 90% of the dissolved organics in the influent would be removed by the fluidized biological reactor? References? Please provide references documenting the effectiveness of this treatment for the contaminants of concern. This does not address contamination in wells (i.e. C-25) which may not be hydraulically connected to PW-1. This statement indicates that the removal efficiency of carbon adsorption of PCDD's/PCDF's is not known. If so, how can the effectiveness of this method be presumed? Thank you for the opportunity to review and submit comments on this Draft Feasibility Study report. Copies of the report have also been routed to the North Carolina Division of Environmental Management's Groundwater Section, Water Quality Section, and Air Quality Section for review, and their comments will be forwarded to you through the Superfund Section. I anticipate that KER will address the comments submitted herewith and I would appreciate a copy of their response. If you require additional information or clarification, please contact me at (919) 733-2801. attachment cc: Luanne Williams Pat DeRosa, Head CERCLA Branch Superfund Section • .,.<::.S{ATf~.~ ...-,,· ...... ,.. ~ /,>:_'f"f.; ~ ~- '" Y:i···t· ":.. ' ! ~ 'r-i1 ~·'-. <;., I~ ':, I ,"'· . ·ig, "\, ·'14 'V l(Jl '{'-:, .... ." .::::: .. ~::::; • State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary 15 October 1991 William L Meyer Director MEMORANDUM TO: FROM: RE: Pat DeRosa, Head CERCLA Branch Luanne K. Williams, Pharm.D. Environmental Toxicologist Inactive sites Branch Feasibility Study for Beazer East, Inc. (Formerly Koppers Company, Inc. Site) NCD003200383 Morrisville, Wake County After reviewing the feasibility study for Beazer East, Inc., I have the following comments: 1. The following objectives should be added to the remedial action objectives if the target risk range of l.OE-04 to 1. OE-06 is used: Reduce hypothetical future on-site residents' exposure to 2378-TCDD by ingestion and dermal contact of surface water in the Fire Pond to concentrations below promulgated ARARs. Reduce hypothetical future on-site residents' exposure to pentachlorophenol [NOT PENTA] by ingestion of groundwater in the former lagoon area to concentrations below promulgated ARARs. 2. It is stated on page 1-17 that noncarcinogenic adverse health effects are not expected to occur in either current or future scenarios. There is a potential concern that noncarcinogenic adverse health effects may occur following ingestion of groundwater by hypothetical future on-site residents living in the former lagoon area (stated on page ES-4 of the feasibility executive summary). An Equal Opportunity Affirmative Action Employer • ·• Pat DeRosa 15 October 1991 Page 2 3. rt is stated on page 1-18 of the feasibility executive summary that remediation is likely required for only on-site groundwater underneath the former lagoon area and that remediation is not necessary.for other environmental media. Remediation should be considered for the folowing areas and media if a 1.0E-04 to 1.0E-06 risk range is used: Hypothetical on-site resident (#1) future scenario The total risk is 7.83E-04. There are two pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is l.50E-04, and (2) Eastern Area groundwater ingestion (as drinking water) risk is' 5. 48E-04. Hypothetical on-site resident /#2) future scenario The total risk is 7.92E-04. There are two pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is 1. 50E-04, and (2) Eastern Area groundwater ingestion (as drinking water) risk is 5.48E-04. Hypothetical on-site resident (#3} future scenario The total risk is l.54E-03. There are two pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is 1. 50E-04, and (2) Former Lagoon Area groundwater ingestion (as drinking water) risk is l.30E-03. Hypothetical on-site resident /#4} future scenario The total risk is 2.36E-04. There is one pathway that significantly increased the total risk; -Fire Pond surface water ingestion and dermal contact risk is l.50E-04. The superfund Section of the State of North Carolina currently considers any carcinogenic risk exceeding l.OE-06 a significant risk to the population. Therefore, remediation should be considered for the following areas and media: Hypothetical on-site resident (#ll future scenario The total risk is 7.83E-04. There are five pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is l.50E-04, (2) Eastern Area groundwater ingestion (as drinking water) risk is 5.48E-04, (3) Western ditch surface water dermal contact risk is l.18E-06, (4) Fire Pond discharge stream sediment ingestion and dermal contact risk is l.68E-06, and (5) Fire Pond ingestion of fish risk is 8.16E-05. • • Pat DeRosa 15 October 1991 Page 3 Hypothetical on-site resident (#2) future scenario The total risk is 7.92E-04. There are six pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is l.50E-04, (2) Eastern Area groundwater ingestion (as drinking water) risk is 5.48E-04, (3) Area B soil exposure risk is 9.0SE-06, (4) Western ditch surface water dermal contact risk is l.lSE-06, (5) Fire Pond discharge stream sediment ingestion and dermal contact risk is l.68E-06, and (6) Fire Pond ingestion of fish risk is 8.16E-05. Hypothetical on-site resident (#3) future scenario The total risk is l.54E-03. There are six pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is l.50E-04, ( 2) Former Lagoon Area groundwater ingestion ( as drinking water) risk is l.30E-03, (3) Area C subsurface soil exposure risk is l.96E-06, (4) Western ditch surface water dermal contact risk is 1. lSE-06, ( 5) Fire Pond discharge stream sediment ingestion and dermal contact risk is l.68E-06, and (6) Fire Pond ingestion of fish risk is 8.16E-05. Hypothetical on-site resident /#4) future scenario The total risk is 2.36E-04. There are four pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is l.50E-04, (2) Western ditch surface water dermal contact risk is 1. lSE-06, ( 3) Fire Pond discharge stream sediment ingestion and dermal contact risk is l.68E-06, and (4) Fire Pond ingestion of fish risk is 8.16E-05. Local resident current scenario The total risk is 3.lSE-05. There are four pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is 6.63E-06, (2) Fire Pond ingestion of fish risk is l.93E-05, (3) Western ditch surface water dermal contact risk is l.lSE-06, and (4) Fire Pond discharge stream sediment ingestion and dermal contact risk is 4.42E-06. On-site worker current scenario The total risk is l.32E-06. There is one pathway that significantly increased the total risk; Area B surface soil exposure risk is l.30E-06. Local resident future scenario The total risk is 3.45E-05. There are five pathways that significantly increased the total risk: (1) Fire Pond surface water ingestion and dermal contact risk is 6.63E- • • 06, (2) Fire Pond ingestion of fish risk is l.93E-05, (3) Medlin Pond ingestion of fish risk is l.35E-06, (4) Western ditch surface water dermal contact risk is l.18E-06, and (5) Fire Pond discharge stream sediment ingestion and dermal contact risk is 4.42E-06. on-site worker future scenario The total risk is l.85E-06. There is one pathway that significantly increased the total risk; Area B surface soil exposure risk is l.30E-06. • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 345 COURTLAND STREET. N.E. 4WD-NSRB OCT 1 7 1991 Shannon Craig Project Manager Beazer East, Inc. 436 Seventh Avenue ATLANTA, GEORGIA 30365 -tttGtlVED OCT B 1 1991 Pittsburgh, PA 15219 SUPERFUNO SECTION Re: Comments on the Draft Feasibility Study (FS) Former Koppers Company Superfund Site Morrisville, North Carolina Dear Ms. Craig: The Draft Feasibility Study for Koppers Company Superfund Site has been reviewed by the EPA and North Carolina Department of Health, Environment, and Natural Resources (NCDHENR). Enclosed are comments from the EPA. NCDHENR comments will be forwarded to you as soon as they are received by the Agency. The report was found to be deficient in several areas; Therefore, this draft report is not approved. I have sent a copy of these comments to your consultant, Keystone Environmental. As you are well aware, additional work is in progress in order to finalize the Remedial Investigation (RI). The final submittal of the FS will be 45 days after the final submittal of the RI. Initially, I feel it would be beneficial to address EPA's comments in the same fashion as you addressed the RI comments. The responses were submitted in the form of a typed comment followed by a response. The responses are due thirty days after receipt of this letter. As we have discussed on the phone, another meeting might be beneficial to discuss issues relating to modeling and other unresolved RI issues. At that time any of these comments could also be discussed. If you have any questions, please do not hesitate to call me at 404/347-7791. :E~ Remedial Project Manager Enclosure cc: Curt Fehn·, EPA Barbara Benoy, EPA Cathy Winokur, EPA ~at DeRosa, NCDHENR.---., John Mitsak, ·Keystone Environmental Printed on Recycled Paper • • COMMENTS ON THE FEASIBILITY STUDY: KOPPERS COMPANY SUPERFUND SITE Morrisville, North Carolina October .17, 1991 PREPARED BY: Darcy Duin Remedial Project Manager The U.S. Environmental Protection Agency North Superfund Remedial Branch Waste Management Division • EPA'S COMMENTS ON THE FEASIBILITY STUDY KOPPERS COMPANY, INC. SUPERFUND SITE • A review has been conducted of the Feasibility Study for the Koppers Company Superfund site in Morrisville, N.C. In general, a draft FS is premature at this stage since the RI has not been completed. However, much of the work will be applicable when the RI is completed and comments are offered to help to improve the final FS. Since there has been a significant amount of work completed on the FS, the submission of the early version will doubtless make the completion of the final FS an easier task. SOIL REMEDIATION A major omiss·ion of the FS is the lack of consideration of any type of soil remediation. Since the soil may represent an ongoing source of contamination to ground-water and possibly other media, the FS will be incomplete until an evaluation of soil remediation is conducted. Soil remediation goals for the protection of ground-water are now being established by Keystone Environment.al for the Site. At this time they are collecting more Site-specific data for soil clean-up goals. Once these numbers have been approved by the Agency, a complete FS would include consideration of remedial alternatives for the volume of soils contaminated at concentrations above these levels. SOURCE REMEDIATION Similar to the soil contamination, the RI has failed to consider any type of source control to prevent ongoing ground-water contamination. Failure to consider any source remediation could result in the ground-water remediation being greatly prolonged. The FS should evaluate whether it is more cost effective to directly remediate source materials or to reply on the indefinite operation of a round-water extraction system. EVALUATION O~ GROUND-WATER REMEDIATION The evaluation of ground-water remediation is based on an incomplete delineation of the ground-water plume. Analytical problems have resulted in contradictory data for pentachlorophenol and unquantified data for some of the dioxin isomers. The EPA must take a conservative stance on this issue until the analytical problems have been resolved. For this reason the extent of contamination which should be considered in the FS is greater than Kopper_s has indicated. -1- . ' • • The relevance to the ground-water remediation scheme is that the ground-water pump and treat system is likely to require more than one well (as presently proposed) to produce a capture zone that will capture the plume. Of greatest concern is the off Site contamination which is most likely to create endangerment since it is nearer to receptors and_ more accessible to receptors than any on-site ground-water contamination. An additional concern with the ground-water remediation at this Site is that some alternatives have been eliminated for unacceptable r~asons. For example, in the section on ground-water isolation, Section 2.5.6, grout curtains are eliminated based on the assumption that ground-water is not off-site at unnacceptable concentrations. However, water supply wells have been contaminated off-site with constituents that are of concern at the Koppers Site. Thus the elimination of methods for ground-water isolation from further consideration is based on incorrect assumptions. The FS should reevaluate these alternatives realistically. Another misconception that relates to the ground-water remediation is the performance standard in Section 5.3.1.3 where it is indicated that the ground-water remedial objectives will be met when all the potentially impacted ground-water is extracted. Unfortunately, the contaminants are likely to be sorbed onto the acquifer, and will only desorb gradually. Once the plume is removed additional ground-water extraction will likely be required to ensure that the release of sorbed contamination does not result in ground-water contamination after the cession of pumping. Frequently, the most successful scheme involves a pulse system of extraction where pumping alternates with non pumping periods to allow the sorbed contamination to desorb into ground-water. Long term ground-water monitoring will be required to ensure that the contamination from the Site is no longer a threat to ground-water. REMEDIAL ACTION OBJECTIVES The remedial action objectives are presented only at the El0-4 level in Section 2.2. However, 40 CFR 300.430 (e) (2) mandates that the El0-6 level be used as a point of departure for determining remediation objectives. Thus the selection of the El0-4 level is inconsistent with the level required by the NCP. CHEMICAL SPECIFIC ARARS FOR GROUND-WATER The chemical specific ARARs are presented in Table 2-3. However, the list is incomplete. First, for constituents where there are no specific promulgated standards, sufficient information exists to estimate health-based risk levels for ground-water consumption. For phenol this concentration is 4200 ug/1, for 2,4-dichlorophenol 20 ug/1, and for 2,4-dinitrophenol 14 ug/1. These numbers are based on -2- \ • • EPA's reference dose including a 20% relative source contribution. Second, Koppers should be aware that the MCL for 2378-TCDD does not apply to all dioxin isomers after being adjusted by EPA's toxicity equivalency factors. SPECIFIC COMMENTS 1. Page 1-15, General A section should be included in the Introduction which discusses the fate and transport of contaminants present in the various media. Contaminant fate and transport can be estimated on the basis of site physical characteristics, some characteristics and chemical and physical properties of the media, and the contaminants of concern. This information is important for determining contaminant pathways and sources. 2. Page 1-15, Paragraph 3 Isopropyl ether (IPE) should be included as a constituent of interest (COI) since it was detected in groundwater samples from several monitoring wells. 3. Figure 1-4 The symbol under the legend for offsite deep monitoring well location should be changed to correspond to the onsite and near offsite monitoring wells pictured on the map. 4. Figure 1-6 see Comment No. 3. 5. Page 2-5, Paragraph 2 An estimation of the volume of groundwater to be treated should be included in the General Response Actions Section. This information is important in choosing and designing a remediation technology. 6. Page 2-6, Paragraph 3 The other rlevant work (i.e., treatability studies) cited should be referenced so the reviewer may refer to these documents. 7. Page 2-18, Paragraph 5 The pKa of Penta is 5.25 and depending fraction of the Penta may be ionized. may be feasible as a pre-treatment. -3- on groundwater pH a high Therefore, ion exchange • • ···-··~ .,,,..,.,._STAT(<> .. ·' ....... ""~ '<?' • , ""'~"-{.:Jr ,,r: ' '..,,.~, 1-~· r1r~,:· "." ~· .5 . "' .... ~I i\S ,. r; 81 \:'1:-{1.J_-:: . /0 ~'"'-""""°·,:/ ---State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary MEMORANDUM TO: Perry Nelson, Chief Groundwater Section September 23, 1991 FROM: Lee Crosby, Chief fl .. , ,,,.· Superfund Sectionp- William L. Meyer Director RE: Request for Review and Comments on the Koppers Company, Inc. NPL Site Morrisville, Wake County Feasibility Study Please find attached 3 complete copies of the above report. It is my understanding that your Section is still coordinating all comments on the National Priorities List sites. Would you please forward one copy each to the Water Quality Section and Air Quality Section for review? At this time, EPA is requesting review and comments only for the first five sections of this report since the preceding Remedial Investigation report has not yet been finalized. We request that the Sections review and comment on the subject document at their earliest opportunity. The US EPA has requested that we submit comments to them by October 11, 1991. Please return all comments back to the Superfund Section. Should you have any questions or require additional time for review, please contact Pat DeRosa or me at (919) 733-2801 before October 11, 1991 so that we can notify US EPA. LC/kc Enclosures An Equal Opportunity Affinnative Action Employer • UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 4WD-NSRB SEP 2 0 1991 Ms. Pat DeRosa N.C. DEHNR 401 Oberlin Road Raleigh, N.C. 27605 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Re: Koppers Company, Inc. Superfund Site Feasibility Study Report Dear Ms. DeRosa: The EPA received the Feasibility Report for Koppers Co., Inc. on September 3, 1991. As I have discussed with you on the phone, Shannon Craig of Beazer said she would mail directly to you two more copies of the FS Report. If you have not received these documents or you need more copies, please notify me immediately. As you know the FS will definitely need to be revised after the RI and the Risk Assessment have been finalized; therefore, in order to save reviewers time, I am only asking for the first five sections to be reviewed. Please review the first five sections of the report and return comments to me no later than October 11, 1991. If you cannot comment by this date or have any questions regarding this Site, please do not hesistate to call me at 404/347-7791. Sincerely, ~v~ Darcy Duin Remedial Project Manager cc: Curt Fehn, EPA Cathy Winokur, ORC, EPA Printed on Recycled Paper • KEYSTONE E:,,.\'IR(>:-..\IE:',T,\I. RES(HHKES. l;,.;C. 3000 Tech Center Drive Monroeville, PA 15146 412 825-9600 FAX 412 825-9699 September 18, 1991 FEDERAL EXPRESS Ms. Darcy Duin NC/SC Site Management Unit Superfund Branch, Waste Management Division U,S. EPA Region IV . 345 Courtland Street, NE· Atlanta, GA 30308 Dear Ms. Duin: • Ref. No. 179280-09 As you requested during your telephone conversation with Shannon Craig of Beazer East, Inc. on September 18, attached are two additional copies of the Feasibility Study Report for the Morrisville, North Carolina site. We are also submitting three copies of the report to Ms. Pat DeRosa of the NC Superfund Branch. If you require any more copies, please contact Shannon Craig at ( 412)227-2684 or me at (412)825-9712. Very truly yours, ~{~ -me-cA Diane E. McCausland Project Manager DEM:dac dm-129 Attachments cc: CPat.DeRosa---NG-Superfund-Branch=> Shannon Craig-Beazer (w/o attachment) John Mitsak -Keystone (w/o attachment) A CHESTER Environmental Company • KEYSTONE EN\'IR(JN:\1ENTAL RESl)URCES. INC. 3000 Tech Center Drive Monroeville, PA 15146 412 825-9600 FAX 412 825-9699. June 27, 1991 Ms. Barbara Benoy NC/SC Site Management Unit Superfund Branch, Waste Management Division US EPA Region IV . 345 Courtland Street, NE Atlanta, GA 30308 Dear Barbara: • On behalf of Beazer East and with the approval of their Program Manager, Ms. Shannon Craig, we · request your consideration to bifurcate submittal of the Feasibility Study Report for the Koppers Superfund Site, Morrisville N.C. As you are aware, the Consent Order requires Beazer to submit the FS Report within 60 days of the submittal of the RI, or August 18, 1991. Beazer proposes that Chapters 1,2 and 3 (preliminary technology screening, development of alternatives, and screening of alternatives) be completed and submitted to you on July 31st. The remaining chapters of the FS Report, which include detailed analysis of alternatives and conclusions, will be submitted to you within 60 days of Beazer's submittal of the final RI Report and PHEA. . . . We are making this request because revisions to the RI and PHEA will directly affect and most likely cause corresponding revisions to the FS. For example, revisions to risk calculations in the PHEA could result in the need to remediate an area previously assumed to have no unacceptable risks or similarly, a request by EPA for addit10nal field work could result in a change to the volume of a specific media requiring remediation. In addition, to comply with an August submittal, we will be required to make assumptions regarding clean up goals and remediation levels prior to these levels being established by the agency. Since the viable technologies which have been retained after Keystone's preliminary screening cannot be developed for detailed analyses until potential volumes are known or at least agreed to by EPA, a meaningful FS Report cannot, we believe, be prepared. • We are not making this request to obtain additional time, but rather to allow the decision makers adequate time to establish site cleanup goals and remediation levels. A CHESTER Environmental Company .. • • • Ms. Barbara Benoy NC/SC Site Management Unit • June 27, 1991 Page 2 On behalf of Beazer we thank you for the opportunity io express our concerns and look forward to your reply. We would like to discuss this proposal for bifurcation of the delivery of the FS Report with you before you begin your maternity leave and will call you to see if this is possible. Very truly yours, Diane McCausland Project Manager JCM:DM/dac jmll cc: Shannon K. Craig John Mitsak PaCQe Ros_m