NCD980557656_19980819_NC State University (Lot 86 Farm Unit 1)_FRCBERCLA RA_Remedial Design Remedial Action 1997 - 1998-OCR

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NORTH IROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
'
DIVISION OF \:VASTE MANAGEMENT
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11 th Floor
Atlanta, Georgia 30303
August 19, 1998
RE: Draft Project Delivery Strategy
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Draft Project Delivery
Strategy for the North Carolina State University (NCSU) Lot 86' National Priority
List Site. The Superfund Section offers the following comments.,
DRAFT PROJECT DELIVERY STRATEGY
i
I. The first page of the Draft Project Delivery Strategy inadyertently omitted.
Please correct this oversight.
2. This document does not include the reporting requirements for this project.
At a minimum, a brief discussion of the monthly reports a~d the final report
should be made in this document. '
The Superfund Section appre·ciates the opportunity to comment on this document.
If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Sincerely,
y,J_ Z//Y61c~~~
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE I SO, RALEIGH, NC 27605
PHONE 91 g.733J4995 FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
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Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
NORTH !tROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
' DIVISION OF WASTE MANAGEMENT
August 19, 1998
RE: Draft Construction Management Plan
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Dfaft Construction
Management Plan for the North Carolina State University (NCSU)' Lot 86 National
Priority List Site. The Superfund Section offers the following comment.
I
DRAFT CONSTRUCTION MANAGEMENT PLAN
I. The first page of the Draft Construction Management Plan was inadvertently
omitted. Please correct this oversight.
' The Superfund Section appreciates the opportunity to comment oh this document.
If you have any questions or comments, please feel free to contact i;ne at (919) 733-
280 I, extension 349. i
Sincerely, I
r;'J ·/l ,t,11~ l y .,___j( 17; I iµ ,vf "'f
' David B. Mattison, CHMM I
Environmental Engineer 1
Superfund Section I
I 401 OBERLIN ROAO, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919•715-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· SO% RECYCLE Oil 0% POST-CONSUMER PAPER
I
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Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
NORTH !ROLINA qEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 19, 1998
RE: Pre-Final Plans and Specifications
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department ofEnvirontnent and Natural
Resources (NC DENR) has received and reviewed the Pre-Final Plans and Specifications
for the North Carolina State University (NCSU) Lot 86 National Priority List Site. The
• I Superfund Section offers the attached comments.
I The Superfund Section appreciates the opportunity to comment on this document. If you
have any questions or comments, please feel free to contact me at: [phone],
extension 349.
Attachment
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
' I
401 OBERLIN ROAD, SUITE_ 150, RALEIGH, NC 2.7605
PHONE[phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/I 0% POST-CONSUMER PAPER
• •
Mr. Michael Townsend
August I 9, I 998
Page 1
PRE-FINAL PLANS AND SPECIFICATIONS
Section 01110 Summary of Work
I. Paragraph 1.2.B provides a list of the tasks to be completed for the remedial, action activities.
However, the following items have not been addressed: tree removal, location/construction
of site benchmarks, drum removal activities, verification of achievement of the performance
standards, and well abandonment. Please correct these oversights and de~cribe these items
' in greater detail in the appropriate sections of this report. i
Section 01320 Construction Progress Documentation
2. Paragraph 1.3.B of this Section details the minimum requirements to be1submitted in the
progress reports. Please amend this paragraph to include a description ;of any problems
encountered as well as a description how the problems were resolved. !
Section 01330 Submittal Procedures
I 3. Paragraph 2.6.E, Paragraph 2.6.G, and Paragraph 2.6.H of this Section in9icate that an Air
Monitoring Plan and a Spill Control and Countermeasures Plan shall be submitted if required
by the EPA and the University. Please revise these paragraphs to include ~he submission of
these items.
Section 01410 Regulatory Requirements
4. Paragraph 3.1.C.3 of this Section states that "Ifinstructed by the EPA and the University, the
I Site Safety Officer (SSO) shall conduct appropriate personal breathing zone and perimeter
I monitoring for known and expected airborne hazards in accordance with 29 CFR 1910.120
(i.e., organic and explosive vapors, oxygen deficiency)." Please amend this paragraph to
reflect air monitoring will be performed in accordance with the Air Mqnitoring Plan as
detailed in Section 01330.
Section 01510 Temporary Utilities
' 5. Paragraph 3.1.F of this Section should be revised to state that all electrical work shall be
conducted according to state and local code and that, if required, arrangeme~ts shall be made
to acquire all necessary permits and inspections. '
6. Paragraph 3.3.C ofthis Section indicates that the staging area for the J,000°gallon tank shall
be prepared as specified in Section O I 550. However, the specifications fot the staging area
have been inadvertently omitted from Section 01550. Please correct this oversight.
• •
Mr. Michael Townsend
August 19, 1998
Page 2
7. This Section should provide for spill prevention and spill containment procedures as well as
provide a specific reference to the Spill Control and Countermeasures Plan.
'
8. Paragraph 3.5.D of this Section indicates that a wooden ramp shall be built to protect the
water supply line in any area that the line traverses a road. Please provide additional details,
including drawings and calculations, as to the construction of this ramp to demonstrate the
adequacy of the system. This system must be adequate to support the point loading which
may occur in this area due to heavy construction traffic.
I
9. Paragraph 3.5.E of this Section indicates the total quantity of water may be metered if
required. Although metering of the water supply is not required, metering will be useful for
determining the exact amounts of water required for slurry mixing in the b~tch plant during
remedial activities. '
Section 01520 Construction Facilities
10. Paragraph 3.1.A of this Section indicates that the area around the trailer shall be graded to
provide drainage away from the building. Please indicate whether this area shall be seeded,
covered with gravel, etc. to prevent erosion. ·
Section 01550 Vehicular Access and Parking
11. Paragraph 3.1.C of this Section indicates that the ABC base course aggregate is to be
compacted prior to placing the surface course. At a minimum, please provide details how the
compaction is to be implemented, to what degree compaction is to occ~r, and how the
adequacy of compaction is to be determined. 1
I
12. Paragraph 3.1.D of this Section indicates that the No. 57 course aggregate is to be compacted
to serve as the surface course. At a minimum, please provide details how the compaction is
to be implemented, to what degree compaction is to occur, and how the adequacy of
compaction is to be determined.
13. Paragraph 3.3.B of this Section indicates that damage to existing paved areas shall be repaired
in a timely manner. Please amend this paragraph to include that repairs I will be made in
accordance with appropriate standard paving repair materials and procedures.
• •
Mr. Michael Townsend
August I 9, 1998
Page 3
Section 1560 Temporary Barriers and Enclosures
14. This Section and the appropriate Drawings describe the materials and procedures necessary
to build perimeter and zone demarcation fencing. Please provide verification that the
necessary space has been provided in which to move the Shallow Soil Mixing rig into the
exclusion zone and conduct the remedial activities. Areas noted of potential :concern include
ingress/egress through the support/contaminant reduction/exclusion zone's and along the
suspected contaminant perimeter.
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I
I 5. Paragraph 3. l.B of this Section indicates that orange fencing shall be attached to metal stakes
every twenty feet. However, Detail C on Drawing C-50 I shows that the orange fencing is
attached to metal stakes every ten feet. Please clarify this discrepancy.
16. Paragraph 3.2 of this Section briefly describes the installation of the perimeter fence. Please
provide additional details regarding the fence installation, including the meJns of anchoring
the fence posts (i.e., setting the posts in concrete).
17. Paragraph 3.2 describes the installation of the perimeter fencing. However,. no indication is
provided how portions of the existing perimeter fence are to be removed or how the new
perimeter fence is to be tied into the existing perimeter fence. Please corredt this oversight.
I
Section 01570 Erosion and Sediment Control
18. This section does not provide for the development of a sediment or erosi6n control plan.
Furthermore, this section does not include any reference to the notification of the land
disturbing activities to the NC DENR Land Quality Section. In accordance ,with Title I SA,
Chapter 4 of the North Carolina Administrative Code, an erosion and sedimentation control
plan must be submitted at least 30 days before land disturbance begins on ahy site one acre
or larger. The erosion and sedimentation control plan must be approved by the NC DENR
Land Quality Section before any land disturbing activities are begun. 1
Section 01730 Execution of Work
' 19. Paragraph 1.13 of this Section indicates that stored materials shall be located as to facilitate
their inspection. Drawing G-102 indicates that the Materials Staging Area shall be placed in
the Exclusion Zone. Please provide details as to the location of the "Clean"Materials Staging
Area. This area should be located to facilitate the unloading of materials ~rior to moving
within the Exclusion Zone or materials that may not be required within the Exclusion Zone.
In accordance with applicable health and safety regulations and this document, personnel
without the required training and expertise are not permitted in the Contaminant Reduction
Zone or the Exclusion Zone. ·
• •
Mr. Michael Townsend
August 19, 1998
Page 4
Section 02055 Soils
l
20. Paragraph 3.1 of this Section indicates that subsoil and topsoil are to be excavated from the
work area, to a depth of no more than 18 inches in the suspected waste trerich areas. Please
provide additional details how workers prevent contaminated soil from being accidentally
stockpiled with clean subsoil and topsoil (i.e., soils disturbed during recent data acquisition
I activities).
Section 02070 Geosynthetics
21. Paragraph 1.3. of this Section references the use of the minimum standards as specified by
NSF Standard 54 for high density polyethylene (HDPE) liners. Please: provide a table
providing the minimum standards that will be used for this project. '
22. Paragraph 1.3.C of this Section indicates that field welding will be used to:correct material
defects. Please provide additional details how the field welding is to be performed and the
quality assurance/quality control (QNQC) measures to be implemented to assure the
adequacy of the field weld.
23. Paragraph l .3E of this Section indicates that the membrane shall meet the spticification values
according to the specification sheet for HDPE. Beyond providing the minimum values to be
used for the liner, please describe the sampling procedures and sampling :frequency to be
implemented to verify compliance with the HDPE standards. I
I
24. Paragraph 3. I of this Section indicates that the sub grade shall be free of all protrusions of any
kind. However, Section 2, Detail 2 of Drawing H-50 I shows that six inches of coarse
aggregate is to be placed upon the prepared subgrade prior to liner installation. Please justify
the use of the coarse aggregate. This appears to be unnecessary for the cbnstruction of a
materials staging area and a decontamination area.
25. Paragraph 3.2.D of this Section states that dragging items across the surface cifthe membrane
shall be minimized. Please revise this sentence to state that dragging of items across the
surface of the membrane shall not be pennitted. Although Section 2, Detail 2 of Drawing H-
501 indicates that four inches of compacted coarse sand shall be placed upon the membrane,
dragging of material shall still not be permitted as this wearing course will not prevent
puncturing of the liner. :
' I
Mr. Michael Townsend
August I 9, I 998
Page 5
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26. Paragraph 3.3.A of this Section indicates that no seaming is to be performed.1 However, each
individual liner sheet shall be overlapped a minimum of twelve inches to th,e adjoining liner
sheet. Please provide additional details as to how overlapping will prevent the release of
potentially contaminated articles from the Materials Staging Area or decontamination fluids
from the Decontamination Pad. '
27. Paragraph 3.4.A of this Section indicates that chemical adhesive methodi will be used to
install any required patches. Please provide additional details as to patthing materials,
patching methods and QA/QC measures to be implemented to assure tlie kdequacy of the
patch.
28. Paragraph 3.7.A of this Section states that "excessive" wrinkles shall be inspected and
repaired or replaced as necessary. Please provide additional details as: to defining an
"excessive" wrinkle and these installation defects are to be addressed.
I 29. This Section does not provide any details as to the qualifications of the contractors to be
employed in: the installation of the liners; the welding of the seams; the repairing of all
material, manufacturing or installation defects; or the implementation of QA/QC measures.
Please provide additional details to address these subjects. i
Section 02105 Chemical Sampling and Analysis
30. This section should reference the Construction Quality Assurance Plan in addition to the
' Performance Standards Verification Plan. Please correct this oversight. '
Section 02110 Excavation, Removal, and Handling of Hazardous Materials
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31. Paragraph 1.3.B of this Section should state "The decontamination pad will be suitable for
decontaminating personnel and equipment." Please correct this oversight.
3 2. Paragraph I .5.A of this Section indicates that the Material Staging Area is to be used for the
storage of potentially contaminated articles until disposal arrangements can be made.
However, Paragraph 1.1.3 of Section 01730 indicated that storage ofraw materials shall be
placed in the Material Staging Area as well. Please clarify this discrepancy. Raw materials
must be stored separately from potentially contaminated articles to lessen the ris~ of spreading
contamination. · 1
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•
Mr. Michael Townsend
August I 9, I 998
Page 6
' 33. Paragraph 3.1.B of this Section indicates that the personnel decontamination area is to be
lined with gravel. A gravel lined corridor is inadequate for the containment of personnel
decontamination wastes, particularly waste waters. This decontamination area must be
I improved to prevent the contamination of "clean" areas.
I 34. Section 2, Detail 2 ofDrawing H-501 indicates that a four-inch sand layer isto be placed on
top of the geomembrane to act as a wearing course. Please be aware that this wearing course
will not protect the geomembrane from punctures due to dragging materials across the
wearing course/geomembrane. This wearing course may not protect the geoinembrane from
punctures due to heavy point loading (i.e., heavy equipment and vehi,cular loading).
Additionally, the sand may present some difficulties in collection of any accidentally released
waste materials. In the event of spillage, all contaminated materials shall be collected,
contained and properly disposed. :
35. Paragraph 3.1.D of this Section indicates that decontamination waters shall b~ contained and
transferred to the concrete batch mixing plant for reuse. Please provide the criteria for
evaluating the reuse potential of the decontamination waters as well as the procedures to be
implemented to verify the water's adequacy for reuse. Additionally, please provide the
procedures for decontaminating the concrete batch mixing plant (i.e., flushing oflines, etc.).
36. The third sentence of Paragraph 3.2.C of this Section should be revised to state that "a layer
of 40 mil HDPE shall be placed on top of the ground ... " Please correct tnis oversight.
I
Section 02120 Off-Site Transportation and Disposal
37. This section references the document entitled, Plan for Satisfying Permitting Requirements.
This section should be revised to certify that all waste transportation and disposal activities
' shall be conducted according to the aforementioned plan. · '
Section 02125 Drum Handling
' 38. Paragraph 3.2.A of this Section states that "Drums which are deteriorated or in fragments will
I be placed in the Materials Staging Area until they are disposed of" Please revise this
statement to state that drums that are deteriorated or in fragments shall be immediately
containerized before handling. Upon containerization, the drums may be transported to the
Materials Staging Area to await sampling and disposal.
0 • I
I
Mr. Michael Townsend
August 19, 1998
Page 7
Section 02150 Hazardous Waste Recovery Process
39. This Section does not address the operation of the catalytic oxidizer, the air monitoring to be
performed, how the destruction efficiency is to be determined, the shutdown procedures in
the event of off-gassing, the detennination of potentially damaging hydrochloric acid content,
etc. Please correct these oversights.
Section 02195 Remediation Soil Stabilization
I 40. Paragraph 3.1.E of this Section states that fresh, potable water, free of deleterious substances,
shall be obtained from the temporary water connection. This section' does: not include any
references to the use of decontamination fluids for the concrete batch mixing plant. Please
clarify this discrepancy. If decontamination fluids are to be used, criteria must be developed
for its acceptance and procedures for verifying the fluid's adequacy as a water source.
Decontamination procedures for the concrete batch mixing plant must be developed as well.
41. Paragraph 3.2.A of this Section indicates that the single shaft auger head must be capable of
achieving a maximum depth of ten feet. However, previous documentation (i.e., Section 4.0
of the Preliminary Design Criteria Report) has indicated that a minimum depth of 12 feet of
waste soil is to be stabilized. Please clarify this discrepancy. Furthermore, NCSU must bear
in mind that all contaminated soil and debris, including secondary sources, a~e to be treated
in accordance with the Record of Decision: Please detail how the vertical and horizontal
' extent of contamination are to be detennined and verified. Please detail how the Shallow Soil
Mixing rig is to achieve soil-stabilization at depths greater than ten feet, should this condition
exist.
Section 02520 Well Abandonment
' 42. It is recognized that this task must be completed in order to conduct the remedial action.
However, this task has not been detailed in the project schedule nor in the ot~er appropriate
documents included in this Pre-Final Design Submittal. Please correct this oversight.
Section 2950 Site Restoration
43. Paragraph 2.1.A of this Section indicates that topsoil shall be stripped from the current
surface area and from the borrow area. Please detail how "clean" soils are to be differentiated
' from contaminated soils. ,
Mr. Michael Townsend
August 19, 1998
Page 8
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Drawing G-102 Proposed Site Layout
•
44. Please provide an approximate location for the two permanent site benchmarks as provided
on Detail 8 of Drawing C-501.
, . • . .. ' •
Mr_ Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11 th Floor
Atlanta, Georgia 30303
NORTH I.ROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 19, 1998
RE: Pre-Final Design Criteria Report
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear ML Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the P're-Final Design
Criteria Report for the North Carolina State University (NCSU) 1-ot 86 National
Priority List Site, The Superfund Section offers the attached comments,
I
The Superfund Section appreciates the opportunity to comment on, this document
If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349_
Attachment
Sincerely,
David B_ Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE tso,:RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
• •
Mr. Michael Townsend
August 19, 1998
Page 1
PRE-FINAL DESIGN CRITERIA REPORT
Table of Contents
I. The following table and figure titles do not agree with those given in the Table of Contents.
Please correct these oversights. 1
Table 3
Table 4
Table 5
Table 8
Table 9
Figure 3
Figure 4
Figure 5
Section 2.5.1 Soil Impact
Treatability Study -Laboratory Analytical Results of Untreated Waste
Characterization
Treatability Study -Physical Parameter Testing of Treated Waste
Treatability Study Results · ·
Estimated Loading Rates
Estimated HCI Loading Rates
Test Pit Locations
Limited Site Assessment Soil Boring Locations
Geophysical Survey
, ' 2. The information provided in this section is inadequate in delineating the· horizontal and
vertical distribution of contaminants present at the site. Additionally, : this section is
inadequate in accurately describing the variety of contaminants present at the site. The
statement that "other compounds, including semivolatiles, organics, and pesticides as well as
radioactive parameters, were only identified at trace concentrations in a veryJimited number
of locations" is inaccurate and misleading. In accordance with NC DENR comments
following the Revised Remedial Investigation Report (Brown and Cald~ell, 1994), all
references to trace amounts of contaminants were to be removed. Furthermore, Table 3
indicates that the majority of Geoprobe samples that had maximum concentrations were
located at soil sampling location G-4 at a depth of 39-40 feet. However, Table 3 fails to
include the details from the Limited Site Assessment and Source Area Characterization
Report (S&ME, 1996), including the fact that this soil sample was analyzed with a dilution
factor of 125 and that sample analysis was conducted although the samples' holding times had
expired or were near expiration for several analyses. Lastly, the lack of adequate site
characterization, primarily vertical delineation, at this site is cited in Section 4.0 as a potential
problem. NCSU should bear in mind that all sources of soil contamination, including
secondary sources, must be remediated in accordance with the Record ofDJcision (ROD).
Please make the appropriate changes to this section.
• •
Mr. Michael Townsend
August 19, 1998
Page 2
Figure 3 Test Pit Locations
i 3. The symbol that indicates the presence of bottles ("B") was inadvertently omitted from test
pit TP-2b. Additionally, the symbol that indicates the presence of plastic containers ("P") was
inadvertently omitted from test pit TP-3c. Please correct these oversights.
Table 4 Treatability Study -Physical Parameter Testing of Treated W~ste
4. Table 4 indicates that the permeability testing results for soil sample TP-4 are not yet
' available. Although it is recognized that the addition of30% reagent will not be used in the
actual remedial action activities, this data should be included in the Final i Design Criteria
Report.
Table 5 Treatability Study Results
5. Table 5 indicates that a number of the soil samples, both treated and i;mtreated waste
mixtures, were not analyzed for a number of parameters (manganese, 1-met_hylnaphthalene,
fluorene, total cresol, and fifteen pesticides). Please provide justification for;not conducting
these laboratory analyses. '
Section 2.5.2 Groundwater Impact
6. This section provides very little detail as to the groundwater contamination present at this site.
Although the Superfund Section acknowledges that the groundwater conta!T)ination is to be
addressed by natural attenuation through additional remedial activities to be conducted at the
site, this section should include greater detail in order to accurately characterize the site.
Please correct this oversight.
Section 4.0 Potential Problems
7. This section does not address the difficulty in meeting the Performance Standards nor the
inability of the remedy to address secondary source soils beneath the waste t~enches. These
potential problems were raised in the Preliminary Design Criteria Report but were not raised
in the Pre-Final Design Criteria Report. Please address these potential problems and how
these problems have been resolved.
i •
Mr. Michael Townsend
August 19, 1998
Page 3
8. The paragraph entitled, Encountering Drums during the Mixing Process, indicates that intact
drums may bind the mixing head. However, no mention is made as to whether the
overlapping pattern of boreholes may bind the mixing head as the head encounters
solidified/stabilized soils. Please address this issue as well as the issue of complete mixing of
solidified and non-solidified soils. '
Section 5.1 Temporary Water
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9. This section states that a three inch diameter (minimum) temporary water line will be used to
convey water to the cement mix batch plant. However, the Preliminary' Design Criteria
Report stated that a four inch diameter (minimum) temporary water line will be used. Please
provide the rationale and the required calculations used to demonstrate the 'adequacy of the
three inch diameter temporary water line. Furthermore, the Hazen-Williams equation for the
calculation of the minimum pipe diameter required to supply water to the cement mix batch
plant uses a constant, C, which is a function of the pipe material. The actual xalue used in the
Preliminary Design Criteria Report for C is 135. Please provide the rationale and source of
the constant used in this calculation. Additionally, please provide justification for not
employing a safety factor in this calculation.
Section 5.4 Decontamination Equipment
10. The first sentence of this section indicates that personnel decontamination will be performed
' in a " ... gravel lined corridorlocated upwind of the waste trench area." •Please end this
sentence with a period (.). Secondly, a gravel lined corridor is inadequate for the containment
of personnel decontamination wastes, particularly waste waters. This decontamination area
must be improved to prevent the contamination of" clean" areas.
Table 8 Estimated Loading Rates
I 1 I. The conversion from milligrams per cubic meter (mg/m3) to pounds per cubic feet (lb/ft)
contained in the legend of Table 8 is incorrect. The correct conversion is:
(mg/m3)(kg/106 mg)(2.2 lb/kg)(m/3.28 ft)3 = (lb/ft3)
Please correct this oversight.
Mr. Michael Townsend
August 19, 1998
Page4
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Table 9 Estimated HCI Loading Rates
•
12. The conversion from mg/m3 to lb/ft contained in the legend of Table 9 is incorrect. The
correct conversion is:
(mg/m3)(kg/106 mg)(2.2 lb/kg)(m/3.28 ft)3 = (lb/ft3)
Please correct this oversight.
Section 5.9 Performance Standards
13. This section indicates that the Unconfined Compressive Strength Test and th.e monitoring of
the cement addition rate will be used as the performance standards for this remedial action.
Please describe how these tests will directly demonstr.ate compliance with the Record of
Decision. The Superfund Section recognizes that the Unified Compressive Strength Test is
an excellent indicator of performance compliance. However, a minimum of I 0% of all
samples should be submitted for toxicity characteristic laboratory analysis. Furthermore, all
samples which, after seven days of curing, do not achieve 30 pounds per square inch (psi)
strength but do achieve 30 psi after 28 days of curing, shall be submitted for toxicity
characteristic laboratory analysis. '
14. This section does not address how NCSU proposes to demonstrate the destruction efficiency
and the performance of the catalytic oxidizer. Please correct this oversight.'
I
Section 5.11 Volume of Waste
I 5. This section states that the area of waste soil is 29,430 square feet (ft2). : However, the
Preliminary Design Criteria Report stated that the area of waste soil is 30,781 ft2• Please
clarify this discrepancy.
:-.,_ __ :----i:iie;~ t--~·
;,::
•
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
NORTH .ROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
I
DIVISION OF WASTE MANAGEMENT
I
August 19, 1998
(
RE: Draft Construction Quality Assurance Plan
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
· Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Draft Construction
Quality Assurance Plan for the North Carolina State University (NCSU) Lot 86
National Priority List Site. The Superfund Section offers the attached comments.
' The Superfund Section appreciates the opportunity to comment on this document.
If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Attachment
Sincerely, ,
7)J &(~;e~rJ.,,
' David B. Mattison, CHMM '
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· SO% RECYCLED/I 0% POST•CONSUMER PAPER
Mr. Michael Townsend
August 19, 1998
Page I
DRAFT CONSTRUCTION QUALITY ASSURANCE PLAN
General
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1. The intent of this document is unclear. A more appropriate format may be to include the
discussion of the quality control organization in the document entitled, Draft Construction
Management Plan, and to include the quality assurance, performance standards testing and
material sampling procedures in the document entitled, Performance Standards Verification
Plan. Currently, this document is not complete and the reader is forced to refer to these
documents regardless.
2. This document does not detail how NCSU proposes to demonstrate that the remedial
activities meet the cleanup specifications as set forth in the Record ofDecisioil. Furthermore,
there is no mention of air sampling to demonstrate that the hood is capturing all vapors at the
mixing head or that the catalytic oxidizer is achieving its reported destruction efficiency.
These items are to be included in this document in accordance with Par~graph 2.5.D.4,
Section 01330 and Section 01450 of the PreFinal Plans and Specifications. ;
3. This document does not include the reporting procedures and for reporting format for the
QA/QC activities as required in Paragraph 2.5.D.5, Section 01330 and Section 01450 of the
PreFinal Plans and_ Specifications.
4. This document does not detail the sampling label procedures or the chain of custody
procedures and documentation. Furthermore, no decontamination procedures have been
established for these sampling procedures. Please correct these oversights. :
' 5. This document does not provide any details as to the sampling and analysis o(the cement to
ensure that the grout conforms to ASTM Designation C-150 "Requirements for Portland
Type I-II Cement" (in accordance with Paragraph 3.1.F, Section 02195 of the Pre-Final Plans
and Specifications). Please correct this oversight. '
6. This document does not detail how the crane operator is to ensure that complete mixing of
the grout and the soils has occurred throughout the trenches and the contaminated soils which
surround the trenches. Please correct this oversight.
Section 6.3 Sample Designation
7. The second sentence of this section should state that "the sample identification number
consists of three identifying symbols separated by hyphens." Please correct this oversight.
Mr. Michael Townsend
August 19, 1998
Page 2
•
8 This section states that the use ofa global positioning system (GPS) should provide relatively
accurate positioning often to twenty feet. The accuracy of the GPS should be greater than
ten to twenty feet, despite the slurried mass of soil and concrete. Please provide justification
for not using conventional surveying techniques if the accuracy of the GPS is this poor.
Section 6.4 Field Quality Control Samples
9. The field quality control samples to be collected during the remedial action should be detailed
in this section if this document is to act as a stand-alone document. Please correct this
oversight. '
Section 6.6 Laboratory Testing
10 This section does not include any information regarding the laboratory that will conduct the
laboratory testing. Please provide the name and location of the laboratory as well as
additional information regarding the laboratory's ability to perform the work.
I
~, ,y.•• • •-.,. •--••..,,: ,• •""• • .• , ••r • ,,J>~·~·_:·:~f.~~ .t' .-·~ : .·~-.:--, '.-~·:_·
'
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 1 I th Floor
Atlanta, Georgia 30303
NORTH !ROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August I 9, I 998
RE: Draft Performance Standards Verification Plan
Draft Performance Standards Verification Quality Assurance/
Quality Control Plan
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Draft Performance
Standards Verification Plan and the Draft Performance Standards Verification Quality
Assurance/Quality Control Plan for the North Carolina State University (NCSU) Lot
86 National Priority List Site. The Superfund Section offers the attached comments.
I
The Superfund Section appreciates the opportunity to comment on th~se documents.
If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349. '
Attachment
Sincerely, :
7} J b /1( ~clH~
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE I 50, RALEIGH, NC 27605
PHONE [phone] FAX 919-715•3605
AN EQUAL OF'F'ORTUNITY / AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/I 0% F'OST•CONSUMER F'AF'ER
•
Mr. Michael Townsend
August 19, 1998
Page I
DRAFT PERFORMANCE STANDARDS VERIFICATION PLAN
Table of Contents
i
I. The following table and figure titles do not agree with those given in the Table of Contents.
Please correct these oversights.
Table 2
Table I
Table 2
Table 3
Figure 2
Treatability Study-Laboratory Analytical Results of Untreated Waste
' Characterization I
Treatability Study -Physical Parameter Testing ofJ:reated Waste
Treatability Study Results !
S=~~D~re .
Treatability Study -Physical Parameter Testing of Treated Waste
I
I 2. Table 2 indicates that the permeability testing results for soil sample TP-4 are not yet
available. Although it is recognized that the addition of 30% reagent will not be used in the
actual remedial action activities, this data should be included in the Final Performance
Standards Verification Plan. ·
Table 3 Treatability Study Results
3. Table 3 indicates that several the soil samples, both treated and untreated !waste mixtures,
were not analyzed for many parameters (manganese, 1-methylnaphthalen~, fluorene, total
cresol, and fifteen pesticides). Please provide justification for not conducting these laboratory-
analyses. '
Section 4.1 Performance Parameters
4. This section indicates that the Unconfined Compressive Strength Test and the monitoring of
the cement addition rate will be used as the performance standards for this iemedial action. . ' Please describe how these tests will directly demonstrate compliance with the Record of
Decision. The Superfund Section recognizes that the Unified Compressive :strength Test is
an excellent indicator of performance compliance. However, a minimum of I 0% of all
s=ples should be submitted for toxicity characteristic laboratory analysis. Furthermore, all
' samples that, after seven days of curing, do not achieve 30 pounds per square inch (psi)
strength but do achieve 30 psi after 28 days of curing, shall be submitted for toxicity
characteristic laboratory analysis. i
f
Mr. Michael Townsend
August 19, 1998
Page 2
•
5. This document does not detail how NCSU proposes to demonstrate that the remedial
activities meet the cleanup specifications as set forth in the Record of Decision. Furthermore,
there is no mention of air sampling to demonstrate that the hood is capturing, all vapors at the
mixing head or that the catalytic oxidizer is achieving its reported destruction efficiency.
Please correct these oversights.
' 6. This document does not provide any details as to the sampling and analysis of the cement to
ensure that the grout conforms to ASTM Designation C-150 "Requirements for Portland
Type I-II Cement" (in accordance with Paragraph 3.1.F, Section 02195 of the Pre-Final Plans
and Specifications). Please correct this oversight.
Section 5.3.2 Sample Designation
7. This section states that the use of a global positioning system (GPS) should provide relatively
accurate positioning often to twenty feet. The accuracy of the GPS shoul,d be greater than
ten to twenty feet, despite the slurried mass of soil and concrete. Please provide justification
for not using conventional surveying techniques if the accuracy of the· GPS is this poor.
8. The second sentence of the second paragraph should state that "the sample identification
number consists of three identifying symbols separated by hyphens." Please correct this
oversight.
Section 5.6 Laboratory Testing
I 9. This section does not include any information regarding the laboratory that will conduct the
laboratory testing. Please provide the name and location of the labo~atory as well as
additional information regarding the laboratory's ability to perform the work.
'
Section 6.2 Sampling Equipment
I 0. The second and third decontamination procedures for sampling equipment have been
inadvertently inverted. The potable water rinse is the second step and the analyte-free water
rinse is the third step. Please correct this oversight.
. ' . . ..
Mr. Michael Townsend
August 19, 1998
Page 3
DRAFT PERFORMANCE STANDARDS
ASSURANCE/QUALITY CONTROL PLAN
Section 4.0 Performance Parameters
•
VERIFICATION QUALITY
I. This section indicates that the Unconfined Compressive Strength Test and the monitoring of
the cement addition rate will be used as the performance standards for this 'remedial action.
Please describe how these tests will directly demonstrate compliance with the Record of
Decision. The Superfund Section recognizes that the Unified Compressive ,Strength Test is
an excellent indicator of performance compliance. However, a minimum of 10% of all
samples should be submitted for toxicity characteristic laboratory analysis. Furthermore, all
samples that, after seven days of curing, do not achieve 30 pounds per s_quare inch (psi)
strength but do achieve 30 psi after 28 days of curing, shall be submitted for toxicity
characteristic laboratory analysis.
2. This document does not detail how NCSU proposes to demonstrate that the remedial
activities meet the cleanup specifications as set forth in the Record of Decision. Furthermore,
there is no mention of air sampling to demonstrate that the hood is capturing all vapors at the
mixing head or that the catalytic oxidizer is achieving its reported destruction efficiency ..
Please correct these oversights.
3. This document does not provide any details as to the sampling and analysis of the cement to
ensure that the grout conforms to ASTM Designation C-150 "Requirements for Portland
Type I-11 Cement" (in accordance with Paragraph 3.1.F, Section 02195 of the Pre-Final Plans
and Specifications). Please correct this oversight.
Section 10.0 Data Reduction, Validation, and Reporting
4. The word "duplicates" is misspelled in the second sentence of this section. Please correct this
oversight.
•
'
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
'/?Al#P
NORTH AoL1NA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 19, 1998
RE: Draft Remedial Action Work Plan
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
I
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Draft Remedial Action
Work Plan for the North Carolina State University (NCSU) Lot 86 National Priority
List Site. The Superfund Section offers the attached comments.
The Superfund Section appreciates the opportunity to comment on this document.
If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349 . •
Attachment
j)j 8/i( ~ C4N~
David B. Mattison, CH.MM:.
Environmental Engineer
Superfund Section
' 401 OBERLIN ROAD, SUITE 1 SO, RALEIGH, NC 27605
PHONE 91 9·733-4996 FAX 919•715-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/I 0% POST-CONSUMER PAPER
•
Mr. Michael Townsend
August 19, 1998
Page 1
DRAFT REMEDIAL ACTION WORK PLAN
Table of Contents
i I. The following table and figure titles do not agree with those given in the Table of Contents.
Please correct these oversights.
Table 5
Figure 3
Figure 4
Figure 5
Treatability Study -Laboratory Analytical Results ofliJntreated Waste
Characterization
Limited Site Assessment Soil Boring Locations
Geophysical Survey
Test Pit Locations
Figure 5 Test Pit Locations
2.
. I
The symbol that indicates the presence of bottles ("B") was inadvertei;itly o\nitted from test
pit TP-2b. Additionally, the symbol that indicates the presence of plastic containers ("P") was
inadvertently omitted from test pit TP-3c. Please correct these oversights.;
Section 4.0 Potential Problems
3. This section does not address the difficulty in meeting the Performance Standards nor the
inability of the remedy to address secondary source soils beneath the waste trenches. These
potential problems were raised in the Preliminary Design Criteria Report but I were not raised
in the Draft Remedial Action Work Plan. Please address these potential problems and how
these problems have been resolved.
Section 5.3.1 Site Preparation Activities
4. This section should be amended to include the task of abandoning monitoring well MW-4
prior to initiating shallow soil mixing. · I
Section 5.3.2 Drum Removal Operation
5. This section is very general and provides little detail as to how the drum removal operations
are to be performed. Please correct this oversight. '
..
Mr. Michael Townsend
August I 9, I 998
Page 2
Section 5.7 Operation and Maintenance
•
6. This section states that no operation and maintenance functions are anticipated at the site
because disturbance of the area may cause the encapsulated area to fail., However, the
PreFinal Plans and Specifications call for restoration of this area. Please detail how NCSU
proposes to restore this area without disturbing the encapsulated area. Furthermore, although
intrusive activities at the site are to be avoided, maintenance activities at,the site should
include visual inspections to ensure the integrity of the encapsulated waste has not been
compromised, that ponding of waters on the waste does not occur, and that there is no
erosion of the surrounding surficial soils.
•
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I I th Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 19, 1998
RE: Draft Construction Health and Safety Plan/Contingency Plan
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Draft Construction
Health and Safety Plan/Contingency Plan for the North Carolina ~tate University
(NCSU) Lot 86 National Priority List Site. The Superfund Section offers the
attached comments.
The Superfund Section appreciates the opportunity to comment on :this document.
If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Attachments
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBE::RLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/I 0% POST-CONSUMER PAPER
Mr. Michael Townsend
August 19, 1998
Page I
• •
DRAFT CONSTRUCTION HEALTH AND SAFETY PLAN/CONTINGENCY PLAN
General
I. Additional comments from Mr. David Lilley, Superfund Section Industrial Hygienist, are
attached. Please address these comments as well.
Table of Contents
2. The following table, figure and appendices' titles do not agree with those given in the Table
of Contents. Please correct these oversights.
Table 3 Treatability Study -Laboratory Analytical Results of Untreated Waste
Figure 3
Characterization
Figure 3 Test Pit Locations
Figure 4 Limited Site Assessment Soil Boring Locations
Figure 5 Geophysical Survey
Figure 6 Zone Delineation
Figure 7 Medical Emergency Route
Appendix D Crane Safety Information
Appendix D-3 Crane Operator Qualifications
Test Pit Locations
3. The symbol that indicates the presence of bottles ("B") was inadvertently olnitted from test
pit TP-2b. Additionally, the symbol that indicates the presence of plastic cont~iners ("P") was
inadvertently omitted from test pit TP-3c. Please correct these oversights.
Section 5.0 General Safety Issues
4. A section describing open excavation safety should be included in this sectio_n as excavation
activities are anticipated for drum removal activities in the northwest portion of the site.
'
Section 5.4.5 Respiratory Hazards
5. The last sentence of this section should reference Section 7.0 -Personal Protective Equipment
(PPE) and Section 8.0 -Respiratory Protection Program. Please correct this oversight.
-..
Mr. Michael Townsend
August 19, 1998
Page 2
•
Section 7.0 Personal Protective Equipment (PPE)
•
6. The last sentence should reference Section 10.0 -Decontamination Procedures rather than
simply referencing standard decontamination protocol. Please correci this oversight.
'
Figure 7 Medical Emergency Route
7. Figure 7 does not indicate the location of West Chase Boulevard as given in Section 12.7 -
Route to Nearest Hospital. Please correct this oversight.
Section 12.5 Emergency Actions
8. The last bullet item of this section was inadvertently omitted. Please correct this oversight.
• • NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT .
August 13, 1998
TO: David Mattison
FROM: David Lilley ,]) 13, L
RE: Comments prepared on the Construction Health and Safety Plan for
the NCSU Lot 86 Site, Raleigh, NC
June, 1998
After reviewing the above mentioned document, I offer the following
comments:
1. Page 24, Section 4.2, last line: Do you really have the authority to deny access
to federal, state, or local government agencies if 24 hour notice is not
given?
2. Page 43, Section 11.0, Air Monitoring Plan: Action limits for each air monitor
should be listed in this section.
dl/DL/shsp.com/58
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE[phone] FAX [phone]S
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/I Oo/o POST-CONSUMER PAPER
..
North Carolina State University is ·d·
grant university and a constituent institution
of The University of North Carolina
An Equal Opportunity/Affirmative Action Employer
http:/ /www2 .ncsu .ed u/ncsu/ehs/
June 30, 1998
Michael Townsend
Superfund Branch, Waste Management Division
US EPA Region IV
Atlanta Federal Center
I 00 Alabama Street, SW
Atlanta, GA 30303-3104
Dear Mr. Townsend:
71>
Office of Finance and Business
Business Division
Environmental Health & Safety Cent
Campus Box 8007
Raleigh, North Carolina 27695-8007
Director
Environmental Affairs
Industrial Hygiene
Health and Safety
·Radiation Protection
(fax)
919.515.4238
919.515.6859
919.515.6860
919.515.6858
919.515.5208
919.515.6307
Enclosed are five copies of the following pre-final soil remediation design documents for the Lot 86 site:
Design Criteria Report
Construction Management Plan
Project Delivery Strategy
Construction Quality Assurance Plan
Remedial Action Work Plan
Performance Standards Verification Plan
Construction Health and Safety Plan/Contingency Plan
Plans and Specifications
These documents are being submitted for review per the January 15, I 998, Proposed Soil Remediation Schedule.
If there are any questions on this submittal, please let me know.
Sincerely, ~
Enclosures
cc: David Matison, NCDENR (w/enclosures)
David Rainer
Jeff Mann
Sylvia Thibaut
Charles Case
JAMES B. HUNT JR.
GoVCRNOR
~~1aw ,.,,...,~..,. -.. ,__...,,.., __ :;:~ay.~~
;~~~ ::::-:-• ~;.e=-J-~~Rk~ • ," •l., ~•'9~;•, ~·~~"l£:~~-2?li~ .. --~ •:r,,,,..,_....-,__;;:::.~:-....:~.-i,·~~
!c.,~i ·-.~-1>,:.:,.zr .... ~--~~
I •' I•.··• -~j -..,:~tv.,~• .. {"'' , ...... ~-·~•!.::r,-.e.:w .... r..;i:,~, ~~ Etf~\I
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I I th Floor
Atlanta, Georgia 30303
April 21, 1998
RE: Off-Site Groundwater Quality Investigation -
Groundwater Natural Attenuation Demonstration
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
DIVISION OF WASTE MANAGEMENT
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the above document for the North
Carolina State University (NCSU) Lot 86 National Priority List Site. ·The Superfund
Section offers the following comments.
Off-Site Groundwater Quality Investigation -
Groundwater Natural Attenuation Demonstration
Table 1
I
Monitoring Well and Direct-Push Sampling Depth and Elevation
Data
I. The screened interval elevations for monitoring well MW07 should be 401.3 feet
(ft) to 396.8 ft. However, Table I indicates that the screened interval elevations
for monitoring well MW07 are 401.3 ft to 396.3 ft. Please clarify this
discrepancy.
Figure 3 Compound Concentrations and Sampling Screen Int~rvals
2. The abbreviation given m Note 7 for I, 1,2,2-TCA should be I, 1,2,2-
tetrachloroethane. Please correct this oversight.
3. The abbreviation given in Note 7 for 1,2,3-TCB should be 1,2,3-trichlorobenzene.
Please correct this oversight.
401 OBERLIN ROAD, SUITE ISO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL. OPPORTUNITY/ AFl'"JRMATIVE ACTION EMPLOYER· SO% RECYCLED/I 0% POST•CONSUMER PAPER
Mr. Michael Townsend
April 21, 1998
Page 2
•
The Superfund Section appreciates the opportunity to comment on this document. If you
have any questions or comments, please feel free to contact me at [phone],
extension 349.
Sincerely,
7)J J)//t;lt-7~ C fltl'f/'l
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
'
/ ... J.-,. t'.: -· ... ,
\}~~WA :,,~--.. ,~ , MCDENR
JAMES 8, HUNT JR;
GoVt;RNOR Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I I th Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF wAsTE MANAGEMENT
April 21, 1998
RE: Task 2 Bioattenuation Screening Analysis -
Groundwater Natural Attenuation Demonstration
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has.received and reviewed the above document for the North
Carolina State University (NCSU) Lot 86 National Priority List Site.· The Superfund
Section offers the attached comments.
The Superfund Section appreciates the opportunity to comment on this document. If you
have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachment
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
-PHONE [phone] FAX 919-715•3605
AN EQUAL OPPORTUNITY/ AFF'IRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% PO.S:T•CONSUMER PAPER
Mr. Michael Townsend
April 21, 1998
Comments
Page 1
Task 2 Bioattenuation Screening Analysis -
Groundwater Natural Attenuation Demonstration
Table of Contents
•
1. The page number citation for the References should be Page 19. Please correct this oversight.
2. The title given for Table I is Groundwater Potentiometric Surface and Monitoring Well
Screen Elevations. However, the title for Table 1 is Groundwater Potentiometric Surface.
Please clarify this discrepancy.
Section 4 Groundwater Sampling and Analyses Conducted for Bioattenuation Screening
' 3. The fifth paragraph of this section states that the "bedrock groundwater at wells MW38 and
MW35D was not affected by VOC contamination migration (the sample from well MW38
contained I µg/1 of chloroform)." It is doubtful that one can demonstrate that the bedrock
groundwater at these wells h,as not been affected by the volatile organic compound (VOC)
contamination. Furthermore, MW38 still exhibited chloroform contamination, albeit with a
"J" uncertainty factor, which equaled the remedial objective for chloroform (I µg/1) as set by
the Record of Decision. Please make the appropriate revisions to this section.
4. The first sentence of the last paragraph of this section indicates that the depth to groundwater
was measured in 18 shallow groundwater monitoring wells in June 1997. However, Figure
2 suggests that the depth to groundwater was measured in 22 shallow groundwater
monitoring wells. Please clarify this discrepancy.
Section 5 Application of the Bioattenuation Screening Process to the Site
5. The first item, Select BiodegradatiDn Rates, indicates that GEI believes the groundwater
monitoring wells MW04, MW! 1 and MW27 should be included in Zone 2, wells in the
dissolved contaminant plume downgradient of the most contaminated portion of the aquifer.
These wells may be influenced by local variations in hydraulic gradient caused b)' groundwater
"mounding" around the source area and/or diffusion of VOCs from the source area.
However, groundwater monitoring wells MW04 and MW! 1 exhibit VOC concentrations that
exceed the remedial objectives by a factor greater than 1,000. Furthermore, there is very little
data to delineate the contaminant plume to the north and to the east of the site. Therefore,
the zone delineation as depicted in Figure 2, is largely arbitrary. Without the required data
in which to support GEI's premise, the elevated VOC concentrations exhibited by
groundwater warrant the inclusion of these wells in Zone 1, wells in the most contaminated
portion of the aquifer. Please make the appropriate revisions.
Mr. Michael Townsend
April 21, 1998
Comments
Page 2
•
,·
Table 2 Groundwater Quality Data Sorted and Reduced by Biodegradation Zone
6. Table 2 indicates that the minimum and average Zone 4 nitrate values were 0 milligrams per
liter (mg/I) and "not calculable," respectively. However, the minimum and average Zone 4
nitrate values are 0.2 mg/I and 0.2 mg/I, respectively. Please correct these oversights.
7. Table 2 indicates that the minimum and average Zone 4 dissolved manganese values were 0
mg/I and "not calculable," respectively. However, the minimum and average Zone 4 dissolved
manganese values are 0.01 mg/I and 0.01 mg/I, respectively. Please correct these oversights.
8. Table 2 indicates that the median Zone 4 alkalinity value was "not calculable." However, the
median Zone 4 alkalinity value is 16 mg/I. Please correct this oversight.
9. Table 2 indicates that the average Zone 5 oxidation-reduction potential (ORP) was 66
millivolts (mV). However, the average Zone 4 oxidation-reduction potential (ORP) is 72.5
m V. Please correct this oversight.
Figure 2 Site Map, Groundwater Contours, and Biodegradation Zones
10. Bedrock groundwater monitoring well MW36D was inadvertently omitted from Note 6 on
Figure 2. Please correct this oversight.
Appendix A Table 2 -Summary of Fixed-Base Laboratory Analyses, Mobile Laboratory
Analyses, and Field-Measured Parameters
11. The word, dissolved, was consistently misspelled for the parameters dissolved hydrogen and
dissolved oxygen in Table 2. Please correct this oversight.
12. Table 2 provides chlorodibromoethane results for the field duplicate sample FD02. However,
Table 1 indicates that the results are actually for chlorodibromomethane. Please clarify this
discrepancy.
13. Table 2 indicates that, for groundwater sample MW3, o-xylene was detected at an estimated
concentration below the laboratory's reporting limit (i.e., with a "J" qualifier). However,
Table I does not indicate that the MW3 sample was reported with a "J" qualifier. Please
clarify this discrepancy.
14. The compound name, 1,1,2-dichloroethane, is misspelled for groundwater sample MW16 in
Table 2. Please correct this oversight.
Mr. Michael Townsend
April 21, 1998
Comments
Page 3
•
..
15. The first eleven lines ofresults for groundwater sample MW32 have been duplicated in Table
2. Please correct this oversight.
16. The results for the 1,4-dichlorobenzene analysis for groundwater sample MW37 have been
omitted from Table 2. Please correct this oversight.
17. The compound name, benzene, is misspelled for groundwater sample MW37 in Table 2.
Please correct this oversight.
18. Table 1 indicates that chlorobenzene was not detected in groundwater sample MW3 7 at a
concentration of 500 micrograms per liter (µg/1). However, Table 2 indicates that
chlorobenzene was detected in groundwater sample MW3 7 at a concentration of 100 µg/1,
with a "J" qualifier. Please clarify this discrepancy.
19. The word, meter, is misspelled in Note 5 of the notes section of Table 2. Please clarify this
discrepancy.
20. The following discrepancies were noted between the dilution factors indicated in Table 1 and
Table 2. Please clarify these discrepancies.
MW02 1,2-Dibromoethane 50 500
MW02 1,2-Dichloropropane 50 500
MW02 Chloroform 50 500
MW02 Methylene chloride 50 500
MW02 Toluene 50 500
FD02 1,2-Dibromoethane 500
FD02 1,2-Dichloropropane 500
FD02 Carbon tetrachloride 1 20
FD02 Chlorobenzene 1 100
FD02 Chloroform 1 500
Mr. Michael Townsend
April 21, 1998
Comments
Page 4
FD02
FD02
FD02
FD02
FD02
FD02
FD02
MW3
MW3
MW3
MW3
MW3
MW3
MW3
MW3
MW3
MW3
MW16
•
Ethylbenzene
m-Xylene &
p-Xylene
Methylene chloride
o-Xylene
Tetrachloroethene
Toluene
Trichloroethene
1,2-Dibromoethane
1,2-Dichloropropane
Benzene
Carbon tetrachloride
Chlorobenzene
Chloroform
Methylene chloride
o-Xylene
Toluene
-
Trichloroethene
Total Organic Carbon
•
I 100
I 100
I 500
I 100
I 100
I 100
I 20
I 100
I 100
I 100
I 100
I 100
I 500
I 100
I ,JOO
I 100
I 100
I 4
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• NORTH !ROLINA D.EPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
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April 20, 1998
/\.~AMES B: HUNT JR.·,,,p;. ,, 1/f~ -~··· , Mr. Michael Townsend
,,, · · · .,.,, Superfund Branch .·,. Waste Management Division
,: '} US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
RE: Preliminary Plans and Specifications
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the above document for the North
Carolina State University (NCSU) Lot 86 National Priority List Site. The Superfund
Section offers the attached comments .
. The Superfund Section appreciates the opportunity to comment on this document. If you
have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachment
Sincerely,
V ~ J> I{ y;6 I
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919•715-3605
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER PAPER .
Mr. Michael Townsend
April 20, 1998
Comments
Page 1
PRELIMINARY PLANS AND SPECIFICATCONS
Document 00005 Certifications Page
•
1. This page should be signed, dated and stamped as appropriate. Please correct this oversight.
Document 00007 Seals Page
2. This page should be signed, dated and stamped. Please correct this oversight.
Document 00010 Table of Contents
3. Section 01420 -References was inadvertently omitted. Please correct this oversight.
4. The title for Section 01570 should be Erosion and Sediment Control. Please correct this
oversight.
Section 011 I 0 Summary of Work
5. The construction schedule provided in Section O 1 I IO indicates that the Pre-Construction
Conference is to be held approximately three weeks prior to remedial activities. However,
Paragraph 1.4.A of Section 01310 indicates that the Pre-Construction Conference is to be
held a minimum of 30 days prior to commencing construction activities. Pl_ease clarify this
discrepancy.
Section 01320 Construction Progress Documentation
6. Paragraph 1.3.A and Paragraph 3.1.A of this Section indicate that the Contractor shall
provide monthly update reports to the University and the appropriate regulatory agency
documenting the progress of the Work. Please revise these paragraphs to provide for the
submission of weekly update reports.
7. Paragraph 1.3.B of this Section details the minimum requirements to be submitted in the
progress reports. Please amend this paragraph to include a description of any problems
encountered as well as a description how the problems were resolved.
Mr. Michael Townsend
April 20, I 998
Comments
Page 2
Section 01330 Submittal Procedures
•
8. Paragraph 2.6.E, Paragraph 2.6.G, and Paragraph 2.6.H of this Section indicate that an Air
Monitoring Plan and a Spill Control and Countermeasures Plan shall be submitted if required
by the EPA and the University. Please revise these paragraphs to include the submission of
these items.
Section 01410 Regulatory Requirements
9. Paragraph 3, l .C.3 of this Section states that "If instructed by the EPA and the University, the
Site Safety Officer (SSO) shall conduct appropriate personal breathing zone and perimeter
monitoring for known and expected airborne hazards in accordance with 29 CFR 1910.120
(i.e., organic and explosive vapors, oxygen deficiency)." Please amend this paragraph to
reflect air monitoring will be performed in accordance with the Air Monitoring Plan as
detailed in Section 01330.
Section 0 1510 Temporary Utilities
10. Paragraph 3.5.D indicates that a wooden ramp shall be built to protect the water supply line
in any area that the line traverses a road. Please provide additional details, including drawings
and calculations, as to the construction of this ramp to demonstrate the adequacy of the
system. This system must be adequate to support the point loading which may occur in this
area .due to heavy construction traffic.
11. Paragraph 3.5.E of this Section indicates the total quantity of water may be metered if
required. Although the Superfund Section does not require metering of the water supply,
metering may be useful in the fine tuning of the batch plant and the remedial activities.
Section 01520 Construction Facilities
12. The word "storage" is misspelled in the heading for Paragraph 2.5 of this Section. Please
correct this oversight.
13. · Paragraph 3.1.A of this Section indicates that the area around the trailer shall be graded to
provide drainage away from the building. Please indicate whether this area shall be seeded,
covered with gravel, etc. to prevent erosion. ·
14. The word "maintenance" is misspelled in the heading for Paragraph 3.3 of this Section. Please
correct this oversight.
Mr. Michael Townsend
April 20, 1998
Comments
Page 3
Section 01550 Vehicular Access and Parking
•
15. Paragraph 3.1.C of this Section indicates that the ABC base course aggregate is to be
compacted prior to placing the surface course. At a minimum, please provide details how the
compaction is to be implemented; to what degree compaction is to occyr, and how the
adequacy of compaction is to be determined.
16. Paragraph 3.3.B of th.is Section indicates that damage to existing paved areas shall be repaired
in a timely manner. Please amend this paragraph to include that repairs will be made in
accordance with appropriate standard paving repair materials and procedures.
Section 1560 Temporary Barriers and Enclosures
17. This Section and the appropriate Drawings describe the materials and procedures necessary
to build perimeter and zone demarcation fencing. Please provide verification that the
necessary space has been provided in which to move the Shallow Soil Mixing rig into the
exclusion zone and conduct the remedial activities. Areas noted of potential concern include
ingress/egress through the support/contaminant reduction/exclusion zones as well as along
the suspected contaminant perimeter.
18. Paragraph 3. l.B of this Section indicates that orange fencing shall be attached to metal stakes
every twenty feet. However, Detail C on Drawing C-501 shows that the orange fencing is
attached to metal stakes every ten feet. Please clarify this discrepancy.
19. Paragraph 3.2 of this Section briefly describes the installation of the perimeter fence. Please
provide additional details regarding the fence installation, including the means of anchoring
the fence posts (i.e., setting the posts in concrete).
20. Paragraph 3.2 describes the installation of the perimeter fencing. However, no indication is
provided how portions of the ·existing perimeter fence are to be removed or how the new
perimeter fence is to be tied into the existing perimeter fence. Please correct this oversight.
Mr. Michael Townsend
April 20, 1998
Comments
Page4
Section O 1730 Execution of Work
•
21. Paragraph 1.1.3 of this Section indicates that stored materials shall be located as to facilitate
their inspection. Drawing G-102 indicates that the Materials Staging Area shall be placed in
the Exclusion Zone. The Superfund Section recommends that the staging area be placed in
the Support Zone to facilitate the unloading of such materials without the necessity of
handling the materials twice or more times. In accordance with this document, personnel
without the required training and expertise are not permitted in the Contaminant Reduction
Zone or the Exclusion Zone. However, if the Materials Staging Area is to be used exclusively
for the storage of potentially contaminated materials, a separate raw material storage should
be designated.
Section 02055 Soils
22. Paragraph 3.1 of this Section indicates that subsoil and topsoil are to be excavated from the
work area, to a depth ofno more than 18 inches in the suspected waste trench areas. Please
provide additional details as to how workers prevent contaminated soil from being
accidentally stockpiled with clean subsoil and topsoil (i.e., soils disturbed during recent data
acquisition activities).
Section 02070 Geosynthetics
23. Paragraph 1.3. of this Section references the use of the minimum standards as specified by
NSF Standard 54 for high density polyethylene (HOPE) liners. Please provide a table
providing the minimum_ standards that will be used for this project.
24. Paragraph 1.3.C of this Section indicates that field welding will be used to correct material
defects. Please provide additional details how the field welding is to be performed and the
quality assurance/quality control (QNQC) measures to be implemented to assure the
adequacy of the field weld.
25. Paragraph 1.3E of this Section indicates that the membrane shall meet the specification values
according to the specification sheet for HOPE. Beyond providing the minimum values to be
used for the liner, please describe the sampling procedures and sampling frequency to be
implemented to verify compliance with the HDPE standards.
Mr. Michael Townsend
April 20, I 998
Comments
Page 5
•
26. Paragraph 3.1 of this Section indicates that the subgrade shall be free of all protrusions of any
kind. However, Section 2, Detail 2 of Drawing H-50 I shows that six inches of coarse
aggregate is to be placed upon the prepared subgrade prior to liner installation. Please justify
the use of the coarse aggregate. This appears to be unnecessary for the construction of a
materials staging area and a decontamination area.
27. Paragraph 3.2.D of this Section states that dragging items across the surface of the membrane
shall be minimized. Please revise this sentence to state that dragging of items across the
surface of the membrane shall not be permitted. Although Section 2, Detail 2 of Drawing H-
50 I indicates that four inches of compacted coarse sand shall be placed upon the membrane,
dragging of material shall still not be permitted as this wearing course will not prevent
puncturing of the liner.
28. Paragraph 3.3.A of this Section indicates that no seaming is to be performed. However, each
individual liner sheet shall be overlapped a minimum of twelve inches to the adjoining liner
sheet. Please provide additional details as to how overlapping will prevent the release of
potentially contaminated articles from the Materials Staging Area or decontamination fluids
from the Decontamination Pad.
29. Paragraph 3 .4.A of this Section indicates that chemical adhesive methods will be used to
install any required patches. Please provide additional details as to patching materials,
patching methods and QNQC measures to be implemented to in order to assure the adequacy
of the patch.
30. Paragraph 3.7.A of this Section states that "excessive" wrinkles shall be inspected and
repaired or replaced as necessary. Please provide additional details as _to defining an
"excessive" wrinkle and these installation defects are to be addressed.
31. This Section does not provide any details as to the qualifications of the contractors to be
employed in: the installation of the liners; the welding of the seams; the repairing of all
material, manufacturing or installation defects; or the implementation of QNQC measures.
Please provide additional details to address these subjects.
Section 02110 Excavation, Removal, and Handling of Hazardous Mater_ials
32. Paragraph 1.3.B of this Section should state "The decontamination pad will be suitable for
decontaminating personnel and equipment." Please correct this oversight.
Mr. Michael Townsend
April 20, 1998
Comments
Page 6
•
33. Paragraph 1.5.A of this Section indicates that the Material Staging Area is to used for the
storage of potentially contaminated articles until disposal arrangements can be made.
However, Paragraph 1.1.3 of Section 01730 indicated that storage of raw materials shall be
placed in the Material Staging Area as well. Please clarify this discrepancy. The Superfund
Section recommends that raw materials be stored separately from potentially contaminated
articles in order to lessen the risk of spreadi~g contamination.
34. Paragraph 1.5.B of this Section indicates that the area will be surrounded by an earthen berm
to prevent runoff onto the Site. However, Detail 2 of Drawing H-50 I indicates that the
earthen berm is to be placed on three sides of the Materials Staging Area and that drainage
shall be from the Materials Staging Area onto the Site. Please correct this detail to indicate
that drainage will be maintained to prevent the potential release of contamination from the
Materials Staging Area to the Site. Furthermore, please detail how simply overlapping
geomembrane panels is to prevent the discharge of contaminants to the .subsurface in the
event of a release.
35. Section 2, Detail 2 of Drawing H-501 indicates that a four inch sand layer is io be placed on
top of the geomembrane in order to act as a wearing course. Please be aware that this
wearing course will not protect the geomembrane from punctures due to dragging materials
across the wearing course/geomembrane. This wearing course may not protect the
geomembrane from punctures due to heavy point loading (i.e., heavy equipment and vehicular
loading). Additionally, the sand may present some difficulties in collection of any accidentally
released waste materials. In the event of spillage, all contaminated materials shall be
collected, contained and properly disposed.
36. Paragraph 3.1.D of this Section indicates that decontamination waters shall be·contained and
transferred to the concrete batch mixing plant for reuse. Please provide the criteria for
evaluating the reuse potential of the decontamination waters as well as the procedures to be
implemented to verify the water's adequacy for reuse. Additionally, please provide the
procedures for decontaminating the concrete batch mixing plant (i.e., flushing of lines, etc.).
Section 02125 Drum Handling
37. Paragraph 3.2.A of this Section states that "Drums which are deteriorated or in fragments will
be placed in the Materials Staging Area until they are disposed of." Please revise this
statement to state that drums that are deteriorated or in fragments shall be immediately
containerized prior to handling. Upon containerization, the drums may be transported to the
Materials Staging Area to await sampling and disposal.
Mr. Michael Townsend
April 20, I 998
Comments
Page 7
•
Section 02195 Remediation Soil Stabilization
•
38. Paragraph 3.1.E of this Section states that fresh, potable water, free of deleterious substances,
shall be obtained from the temporary water connection. This section does not include any
references to the use of decontamination fluids for the concrete batch mixing plant. Please
clarify this discrepancy. If decontamination fluids are to be used, criteria must be developed
for its acceptance as well as procedures for verifying the fluids adequacy as a water source.
Decontamination procedures for the concrete batch mixing plant must be developed as well.
39. Paragraph 3.2.A of this Section indicates that the single shaft auger head must be capable of
achieving a maximum depth often feet. However, previous documentation (i.e., Section 4.0
of the Preliminary Design Criteria Report) has indicated that a minimum depth of 12 feet of
waste soil is to be stabilized. Please clarify this discrepancy. Furthermore, NCSU must bear
in mind that all contaminated soil and debris, including secondary sources, are to be treated
in accordance with the ROD. Please provide additional details as to how the vertical and
horizontal extent of contamination are to be determined and verified. Please detail how the
Shallow Soil Mixing rig is to achieve soil stabilization at depths greater than ten feet, should
this condition exist.
Drawing G-102 Proposed Site Layout
40. Please provide an approximate location for the two permanent site benchmarks as provided
on Detail 8 of Drawing C-50 I.
,: '1. .
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JAMES B, HUNT JR.
G0VE.RNOR
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Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
6 I Forsyth Street, I I 1h Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
April 13, 1998
RE: Plan for Satisfying Permitting Requirements
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received and reviewed the Plan. for Satisfying
Permitting Requirements for the North Carolina State University (NCSU) Lot 86
National Priority List Site. The Superfund Section offers the following comments.
Section 2.1 Drums
I. The word "pits" is misspelled in the fourth sentence of the first paragraph of
this section. Please correct this oversight.
2. The last two sentences of this section state that drums that are not intact will
be removed, staged in the Materials Staging Atea and handled as hazardous
waste. Please provide additional details as to how drums with questionable
integrity are to be handled and moved without releasing potentially hazardous
constituents. A more appropriate course of action may call for repackaging
of the container and the container's contents prior to handling. Please provide
complete details as to how wastes are to be handled, sampled and stored,
including pertinent information regarding the Materials Staging Area.
401 OBERt.JN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER• 50% RECYCLED/I 0% POST-CONSUMER PAPER
0
•
Mr. Michael Townsend
Comments
April 13, I 998
Page 2
•
The Superfund Section appreciates the opportunity to comment on this document. If you have any questions or comments, please feel free to contacrme at [phone],
extension 349.
Attachment
Sincerely,
7)J B Ji(Yt5; e NM~
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
JAM CS B. HUNT JR.
G0VCRNOR
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Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
April 13, 1998
RE: Preliminary Design Criteria Report
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the above document for the North
Carolina State University (NCSU) Lot 86 National Priority List Site. The Superfund
Section offers the attached comments.
The Superfund Section appreciates the opportunity to comment on this document. If you
have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachment
Sincerely, Y~r! ;3/fp<c-i c~v,.~
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919•71S-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EM PL.OYER· SO% RECYCLE0/1 0% POST-CONSUMER PAPER
l • •
Mr. Michael Townsend
April 13, 1998
Comments
Page 1
PRELIMINARY DESIGN CRITERIA REPORT
Table of Contents
1. The following table and figure titles do not agree with those given in the Table of Contents.
Please correct these oversights.
Table 5
Figure 3
Figure 4
Figure 5
Section 2. 7.1 Soil Impact
Treatability Study-Laboratory Analytical Results of Untreated Waste
Characterization
Limited Site Assessment Soil Boring Locations
Geophysical Survey
Results ofTreatability Study Excavations
. 2. The information provided in this section is inadequate in delineating the horizontal and
vertical distribution of contaminants present at the site. Additionally, this section is
inadequate in accurately describing the variety of contaminants present at the site. The
statement that "other compounds, including semivolatiles, organics, and pesticides as well as
radioactive parameters, were only identified at trace concentrations in a very limited number
of locations" is inaccurate and misleading. In accordance with NC DENR comments
following the Revised Remedial Investigation Report (Brown and Caldwell, 1994), all
references to trace amounts of contaminants were to be removed. Furthermore, Table 3
indicates that the majority of Geoprobe samples that had maximum concentrations were
located at soil sampling location G-4 at a depth of 39-40 feet. However, Table 3 fails to
include the details from the Limited Site Assessment and Source Area Characterization
Report (S&ME, 1996), including the fact that this soil sample was analyzed with a dilution
factor of 125 and that sample analysis was conducted although the samples' holding times had
expired or were near expiration for several analyses. Lastly, the lack of adequate site
characterization, primarily vertical delineation, at this site is cited in Section 4. 0 as a potential
problem. NCSU should bear in mind that all sources of soil contamination, including
secondary sources, must be remediated in accordance with the Record of Decision (ROD).
Please make the appropriate changes to this section.
Section 2. 7.2 Groundwater Impact
3. This section provides very little detail as to the groundwater contamination prese~t at this site.
Although the Superfund Section acknowledges that the groundwater contamination is to be
addressed by natural attenuation through additional remedial activities to be conducted at the
site, this section should include greater detail in order to accurately characterize the site.
Please correct this oversight.
Mr. Michael Townsend
April 13, I 998
Comments
Page 2
•
Section 3.0 Selected Remedial Approach
•
4. The fifth sentence of the second paragraph of this section should be changed to "The reagent
selection, water-to-reagent ratios and additive rates will be determined during treatability
testing." Please correct this oversight.
Figure 5 Results of Treatability Study Excavations
5. The symbol that indicates the presence of bottles ("B") was inadvertently omitted from test
pit TP-2b. Additionally, the symbol that indicates the presence of plastic containers ("P") was
inadvertently omitted from test pit TP-3c. Please correct these oversights.
Section 5.1 Temporary Water
6. The calculation of the minimum pipe diameter required to supply water to the cement mix
batch plant uses a constant, C, which is a function of the pipe material. The actual value used
for C is 135. Please provide the rationale and source of the constant used in this calculation.
Additionally, please provide justification for not employing a safety factor in this calculation.
Section 5.8 Volume of Waste
7. The second sentence ofthis section references Drawing G-102. However, this drawing was
inadvertently omitted from this submittal. Please correct this oversight.
8. The calculation of the volume of waste soil that requires stabilization employs a depth often
feet. However, the seventh paragraph of Section 4.0 states that a minimum depth of 12 feet
of waste soil is to be stabilized. Please clarify this discrepancy. Furthermore, NCSU must
bear in mind that all contaminated soil and debris, including secondary sources, are to be
treated in accordance with the ROD.
March 6, 1998
Mr. Michael Townsend
Superfund Branch, Waste Management Division
US EPA Region IV
Atlanta Federal Center
I 00 Alabama Street, SW
Atlanta, GA 30303-3104
Dear Mr. Townsend:
• North Carolina State University is a land•
grant university and a constituent institution
of The University of North Carolina
An Equal Opportunity/Affirmative Action Employer
http://www2 .ncsu. edu/ncsu/ehs/
Rcc~'"'fo
MAR 10 1998
SUPERFUNO SECTION
Office of Finance and Business
1Business Division
Environmental Health & Safety Cent
•Campus Box 8007
Raleigh, North Carolina 27695-8007
Director
Environmental Affairs
Industrial Hygiene
Health and Safety
Radiation Protection
[Fax)
919.515.4238
919.515.6859
919.515.6860
919.515.6858
919.515.5208
919.515.6307
The following reports and/or plans (five copies) for the North Carolina State University Lot 86 Superfund Site
are being submitted for EPA review:
• Results of Data Acquisition Activities
• Design Criteria Report -Preliminary
Plans and Specifications -Preliminary
Plan for Satisfying Permitting Requirements
Also enclosed are soil and groundwater remediation schedules, per your request.
If you have any questions or comments on this submittal, please let me know.
Enclosures
cc: David Schaad, Marshall Miller & Associates
David Matison, NCDENR
Sincerely,
Duane Knudson
Environmental Affairs Manager
' #~' ,.,,
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• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL. RESOURCES
DIVISION OF WA;STE MANAGEMENT
February 4, 1998
TO:
FROM:
David Mattison
David Lilley DBL·
RE: .Comments prepared on the Health and Safety
Plan for NCSU, Lot 86, Raleigh, NC
January, 1998
After reviewing the above mentioned document, I
offer the following comments:
1. Page 19, 3rd paragraph under Section 4.1: The
last line reads "Workers will not be allowed to
return to these areas until conditions improve".
Please quantify the term "improve".
2. Page 19, last paragraph: A list of direct reading
instruments is included, along with the statement
that each instrument "will have an alarm set to
activate prior to vapor concentrations reaching
constituent based health levels". However, there
is no mention of what those levels are. Please
include this information.
3. Page 20: The conventional term for a "lower
explosive limit meter" is "combustible gas
indicator". A PID measures total volatile
ionizables, not just organics.
4. Page 20, 2nd paragraph under Section 4.2: The use
of leather gloves as an outer garment is not
recommended.
5. Page 20, Section 4.4: It is stated that "All
other OSHA requirements regarding excavations (29
CFR Parts 1926.650 through 652) will be observed".
What are those requirements, and how and when will
the workers be informed of the requirements?.
6. Page 22: Why would stepladders be used if you are
not entering the excavations?
7. Page 23, 2nd bullet item: "Awareness of
surroundings and operations in the immediate
vicinity is required". What does this mean?
401 OBERLIN ROAD, SUITE 1 SO, RALEIGH, NC 2760S
PHONE 919-733·4996 FAX 919-71 S-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· SO% RECYCLED/I 0% POST-CONSUMER PAPER
•
8. Page 23, Section 4.6.4: If excavation work will be
conducted with a trackhoe, why would hand augering be
necessary? Keeping clear of the auger handle in the event
of an explosion is not realistic (how do you know something
is about to explode?). This augering procedure seems
unnecessary, and a good way to loose body parts.
9.
10.
Page 24, Section 4.6.5, 1st bullet item:
respiratory protection? The safety plan
place to put this information.
Page 24, Section 4.6.6, 2nd bullet item:
term "sensible lifting limits".
dl/DL/shsp.com/45
What is "proper"
is the appropriate
Please define the
R!J>
North Carolina State University is •.
grant university and a constituent institution
of The University of North Carolina
Office of Finance and Business
Business Division
An Equal Opportunity/Affirmative Action Employer Environmental Health & Safety Center
Campus Box 8007
Raleigh, Nonh Carolina 27695-8007
http //www2.ncsu. edu/ncsu/ehs/ Director
Environmental Affairs
Industrial Hygiene
Health and Safety
·'Radiation Protection
{Fax)
9t9.515.4238
919.515.6859
919.515.6860
919.515.6858
919.515.5208
919.515.6307
January 28, I 998
RECEIVED
JAN 3 0 1998
SUPERFUND SECTION
Mr. Michael Townsend
Superfund Branch, Waste Management Division
US EPA Region IV
I 00 Alabama St, SW
Atlanta, GA 30303-3 I 04
Subject: North Carolina State University Lot 86 Site
Transmittal of Plans for Review and Revised Project Schedule
Dear Mr. Townsend:
As we discussed, enclosed are five copies of the following plans:
Treatability Study Plan
• Health and Safety Plan
• Remedial Design Work Plan
Sampling and Analysis Plan
Not included in this submittal are the Preliminary Plans and Specifications, Results of Data Acquisition,,Design
Criteria Report, and the Permitting Plan. The current schedule calls for submittal of the Preliminary Design
Documents (50% design) on February 5, which is before the results of the Treatability Study are available.
However, it has been determined by Marshall Miller and Associates (Contractor) and the University that
preparing a preliminary remedial design, without incorporation of the Treatability Study results will not provide
enough information to confidently prepare the design plans. This creates the potential for significant later
revisions to the design documents based upon the results of the Treatability Study.
To avoid this situation, the Contractor is planning to collect the treatability study samples during the first week
of February, These data will be incorporated into the Preliminary Plans and Specifications, Results of Data
Acquisition, Design Criteria Report, and the Permitting Plan. These reports will be submitted to EPA
according to the following schedule.
• Submit the Preliminary Design documents (Plans), with the preliminary results from the Treatability
Study, to EPA for review on March 6.
• Allow EPA 50 days to review the Preliminary Design documents.
i
Michael Townsend
January 28, 1998
Page 2
• This will start the preparation draft final design on May 20.
•
• Incorporate EPA comments into the Draft Final (90% complete) design to be submitted by June 30.
This only allows the Contractor 30 days lo prepare the final draft design plans.
This essentially places the project on the SOW schedule at the point of submitting the Final Design and RA
plans lo EPA for approval on July I, and meets our objective of beginning construction in December of this
year.
A revised project schedule is enclosed.
If there are any questions on this submittal, or if you need additional copies of any of the plans, please let me
know.
Sincerely,
dfJ ' -~~
Duane A. Knudson
Environmental Affairs Manager
Enclosure
cc: Dave Matison, NCDENR
Davi c aad, Marshall Miller & Associates
NCSU Lot 86 Soil Proposed Remediation Schedule (Jan 98)
'971Mar 23, '971 Jun 1, '97 !Aug 1 O, •gnoct 19, '97 Dec 28, '971 Mar a, '98 ,..,ay 17, '981 Jul 26, '981 Oct 4, '98 IDec 13, '981Feb 21, '991 Mav 2, ~991 Jul 11, '99 lseo
ID Task Name Duration 'FIT IS WIS TIM IF IT IS IW IS IT IM IF IT IS WIS IT IM IF IT IS 1W IS IT IM IF IT IS IW IS IT IM IF IT IS IW
1 Begin Contractor Search 1d :~~~··· ----•-------------,---·----·-·--·--· ---·-· ---➔-----------
2 RD/RA Contrctr Selection Proc 120d .. ..... ............ :::::::::::::~/16 ......... ········· ··:.':.·: ..... -
3 Rqst Apprval of Contrctr from EPA 1d
:~: ~::.~ 1~15
-· -----
4 EPA Contrtor review and apprval 20d -
5 Submit EA to State 1d
9n9~
6 State EA Review 30d 9fJQ :·.-.-.-.cc·.::·.· 11/10 ............
7 Receive State apprvl of EA 1d 11/11 ~ 1/11
8 Issue RD/RA Contract 1d 11/12 ~1/12
9 Plan Preparation • Soils 1d 11/13111/13
10 Work Plan -Soils 60d 11114 I ··:::::::::. ?\ti] 2/5
~
11 Sampling and Analys Plan -Soils 60d 11114 I• 2/5
12 H&S Plan -Soils 60d 11/14 ~ 215 I
13 Permit Plan -Soils 60d 11/14 1. :.:.:•:•:•:•:· ......... .... ' ········
14 EPA Review Plans -Soils • 60d 2/6 i:... ..................... ... •••••:d 4130
I
15 Treatability Study Field Work 5d 2/2 a 2/6 !
16 Treatability Study Data• Soils 1d 2116 j 2115 I
17 Design Criteria Report -Soils 40d 1/12 i••·········•·''"?J 3/6
18 Preliminary Plans and Specs -Soils 40d 1112 k•••••••••••••••••:•:••••Jt/6 I
19 Submit to EPA for Review 1d
3ffi~
20 EPA Review 50d 3/1 0 •\\/\i\•••? SN 8 I
21 Prefinal/Final Design -, 1d 5/19 ~ '
22 Complete Design Analysis -Soils 30d 5/20 6/30 I
I,
I I 23 Final P~ns and Specs -Soils , 30d 5/20 .mzm 6/30
/
24 Final Const Schdl & Cost Est -Soils 30d 5/20 •GBJ 6/30 I
25 RA Planning {All Plans) -Soils i 30d 5/20 ·:::::::::.·.·. 6/30 I ' 26 EPA Apprvl of Final design -Soils 60d .7N 9/22
--------··--·---·----·-·----
27 EPA Rev of RA plans -Soils 60d 7/1 9/22 I
28 Modifcation of RA plans -Soils 30d 9/23 11/3 I
··········-····· ..... ··-·---··-···----····------··-""··-----I 29 Plans to EPA -schdl conf -Soils 30d 11/4 12/15
30 Submit Prelim Nat Allen Report 1d 9/1 !
' 31 EPA Review of NA Report 60d 9/24 12/16 '
32 EPA Prelim Decision on Nat Atten 1d 12111112111 -. -----,I,, '
33 Preconstruction Conf -SOils . -1d ,--
: ::: ~ •• ::.,: •••• ,-••••• , ............. ,....:~/3;
I --
34 Construction 1mplem -Soils 75d
35 Prefinal Construe lnsp -Soils 1d
4/1~
36 Construction fixes -Soils 25d , 4/2 \::ii 5/6
37 Final Construction lnspe -Soils 1d 5ll bsn
38 Final Const Rept -Soils 40d 5/10 L: • iiltl]112
39 Remedial Act rep! -Soils 75d 7/5 i::. :::::f::::::::•:: /•::ii?J
'
40 0 & M Plan and Manual 1d 2/11 I 2/11
41 Performance Stds Verification Plan 1d 10/13 j
• • NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
February 18, 1998
Mr. Michael Townsend
Superfund Branch
Waste Management Division
US EPA Region IV
6 I Forsyth Street, 1 l lh Floor
Atlanta, Georgia 30303
RE: Remedial Design Work Plan
Treatability Stud,, Plan
Sampling and Analysis Plan
Health and Safety Plan
North Carolina State University Lot 86 NPL Site
Raleigh, Wake County
Dear Mr. Townsend:
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the above documents for the North
Carolina State University (NCSU) Lot 86 National Priority List Site. The Superfund
Section offers the attached comments. ·
The Superfund Section appreciates the opportunity to comment on these documents. If
you have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachments
Sincerely,
YJ2>(,-;1p
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· SO% RECYCLED/1O't0 POST•CONSUMER PAPER
Mr. Michael Townsend
Comments
Page 1
•
REMEDIAL DESIGN WORK PLAN
Table of Contents
•
I. The Table of Contents inadvertently omitted Section 2.7.2 -Groundwater Impact and
Appendix A -Abbreviated Resumes of Key Personnel. Please correct this oversight.
Section 2.2.4 Geology
Residual Soils and Saprolite
2. The first sentence of this section should state" ... which comprise the area's shallow water-
bearing unit." Please correct this oversight.
Section 2.7.1 Soil Impact
3. The information provided in this section is inadequate in delineating the horizontal and
vertical distribution of contaminants present at the site. Additionally, this section is
inadequate in accurately describing the variety of contaminants present at the site. The
statement that "other compounds, including semivolatiles, organics, and pesticides as well as
radioactive parameters, were only identified at trace concentrations in a very limited number
of locations" is inaccurate and misleading. In accordance with NC DENR comments
following the Revised Remedial Investigation Report (Brown and Caldwell, 1994), all
references to trace amounts of contaminants were to be removed. Furthermore, Table 3
indicates that the majority of Geoprobe samples that had maximum concentrations were
located at soil sampling location G-4 at a depth of 39-40 feet. However, Table 3 fails to
include the details from the Limited Site Assessment and Source Area Characterization
Report (S&ME, 1996), including the fact that this soil sample was analyzed with a dilution
factor of 125 and that sample analysis was conducted although the samples' holding times had
expired or were near expiration for several analyses. Lastly, the lack of adequate site
characterization, primarily vertical delineation, at this site is cited in Section 4.0 as a potential
problem. NCSU should bear in mind that all sources of soil contamination, including
secondary sources, must be remediated in accordance with the Record of Decision (ROD).
Please make the appropriate. changes to this section.
• •
Mr. Michael Townsend
Comments
Page 2
Section 2.7.2 Groundwater Impact
4. This section provides very little detail as to the groundwater contamination present at this site.
Although the Superfund Section acknowledges that the groundwater contamination is to be
addressed by natural attenuation through additional remedial activities to be conducted at the
site, this section should include greater detail in order to accurately characterize the site.
Please correct this ove~sight.
Section 4.0 Potential Problems
5. This section provides a variety of potential problems that may be encountered during remedial
activities to be conducted at the site. However, this section should be expanded to include
the remedies to be used in the event of such problems. Instead of apparent remedies for these
potential problems, this section may be expanded to those steps necessary to arrive at the
potential solution to be implemented in the event of such a potential problem. Please make
the appropriate changes to this section.
Section 5.1.1 Sampling and Analysis Plan
6. The first sentence of this section indicates that no further sampling is anticipated at the site.
This sentence should be changed in order to reflect, at a minimum, the sampling of soils for
treatability analysis, the sampling of decontamination water for disposal and the sampling of
air for health and safety purposes. Please correct this oversight.
Mr. Michael Townsend
Comments
Page 3
•
TREA TABILITY STUDY PLAN
•
Section 2.3 Present Nature and Extent of Contamination in Waste Trench Areas
1. The information provided in this section is inadequate in delineating the horizontal and
vertical distribution of contaminants present at the site. Additionally, this section is
inadequate in accurately describing the variety of contaminants present at the site. The
statement that "other compounds, including semivolatiles, organics, and pesticides as· well as
radioactive parameters, were "only identified at trace concentrations in a very limited number
of locations" is inaccurate and misleading. In accordance with NC DENR comments
following the Revised Remedial Investigation Report (Brown and Caldwell, 1994), all
references to trace amounts of contaminants were to be removed. Furthermore, Table 3
indicates that the majority of Geoprobe samples that had maximum concentrations were
located at soil sampling location G-4 at a depth of 39-40 feet. However, Table 3 fails to
include the details from the Limited Site Assessment and Source Area Characterization
Report (S&ME, 1996), including the fact that this soil sample was analyzed with a dilution
factor of 125 and that sample analysis was conducted although the samples' holding times had
expired or were near expiration for several analyses. Lastly, the lack of adequate site
characterization, primarily vertical delineation, at this site is cited in Section 4.0 of the
Remedial Design Work Plan as a potential problem. NCSU should bear in mind that all
sources of soil contamination, including secondary sources, must be remediated in accordance
with the Record of Decision (ROD). Although the Superfimd Section recognizes that the
purpose of this section is to merely provide an overview of the nature and extent of
contamination located at the site, this section lacks the accuracy required for this document.
Please make the appropriate changes to this section.
Section 3.0 Treatability Study Objectives and Rationale
2. The last sentence in the third paragraph ofthis section should state "Potential concerns related
to the treatability testing which may arise include ... " Please correct this oversight.
Section 4.3.1 Initial Exploratory Borings
3. This section does not provide sufficient detail as to how this task is to be completed. This
section should include relevant information including the depth of the exploratory boring, the
type of hand auger (i.e., brass or non-sparking), monitoring port construction, vapor
monitoring equipment, health and safety considerations for the workers conducting the
intrusive activities, etc. Please make the appropriate changes to this section.
Mr. Michael Townsend
Comments
Page 4
•
Section 4.3.2 Excavations
•
4. This section does not address whether blast shields will be employed on the track hoe.
Additionally, this section does not address how the open excavations will be marked to
prevent falling into the excavation. Please correct these oversights.
Section 4.4 Sample Collection
5. The first sentence in this section appears to be incorrect. This sentence should state "To
mimic the soil mixing process ... " Please correct this oversight.
6. The Superfund Section recognizes that the mixing of the containers and the soil must occur
in order to simulate the soil mixing process. However this section should be expanded to
include methods employed to prevent further release of contaminants into the subsurface (i.e.,
the smashing of containers ~hich may contain liquid waste). Please make the appropriate
changes to this section.
Section 5.0 Benchscale Testing of Collected Samples
7. Please delete the word "a" in the second sentence of this section. This sentence should state
"Since Kiber does not represent. .. "
Appendix A Grid Sampling Analysis
8. The coefficient of variation (CV) is incorrectly stated as 0.46 in the ninth step. The
coefficient of variation should be 2.2. Please correct this oversight.
Mr. Michael Townsend
Comments
Page 5
•
SAMPLING AND ANALYSIS PLAN
Section 1.0 Introduction
•
1. The third and fourth sentences of this section indicate that no further sampling is anticipated
at the site. These sentences should be changed in order to reflect, at a minimum, the shmpling
of soils for treatability analysis, the sampling of decontamination water for disposal ,and the
sampling of air for health and safety purposes. Please correct this oversight.
Section 2.2.4 Geology
Residual Soils and Saprolite
2. The first sentence of this section should state" ... which comprise the area's shallow water-
bearing unit." Please correct this oversight.
Section 2.5.1 Soil Impact
3. The information provided in this section is inadequate in delineating the horizontal and
vertical distribution of contaminants present at the site. Additionally, this section is
inadequate in accurately describing the variety of contaminants present at the site. The
statement that "other compounds, including semivolatiles, organics, and pesticides as well as
radioactive parameters, were only identified at trace concentrations in a very limited number
of locations" is inaccurate and misleading. In accordance with NC DENR comments
following the Revised Remedial Investigation Report (Brown and Caldwell, 1994), all
references to trace amounts of contaminants were to be removed. Furthermore, Table 3
indicates that the majority of Geoprobe samples that had maximum concentrations were
located at soil sampling location G-4 at a depth of 39-40 feet. However, Table 3 fails to
include the details from the Limited Site Assessment and Source Area Characterization
Report (S&ME, 1996), including the fact that this soil sample was analyzed with a dilution
factor of 125 and that sample analysis was conducted although the samples' holding times had
expired or were near expiration for several analyses. Lastly, the lack of adequate site
characterization, primarily vertical delineation, at this site is cited in Section 4. 0 of the
Remedial Design Work Plan as a potential problem. NCSU should bear in mind that all
sources of soil contamination, including secondary sources, must be remediated in accordance
with the Record of Decision (ROD). Please make the appropriate changes to this section.
Mr. Michael Townsend
Comments
Page6
•
Section 2.5.2 Groundwater Impact
•
4. This section provides very little detail as to the groundwater contamination present at this site. Although the Superfund Section acknowledges that the groundwater contamination is to be
addressed by natural attenuation through additional remedial activities to be conducted at the
site, this section should include greater detail in order to accurately characterize the site.
Please correct this oversight.
Section 3.0 Soil Sampling Procedures
5. The second sentence of this section indicate that no further sampling is anticipated at the site.
This sentence should be changed in order to reflect, at a minimum, the sampling of soils for treatability analysis. Please correct this oversight.
Section 3.1 Soil Sampling Objectives
6. The first sentence of this section indicate that no further sampling is anticipated at the site. This sentence should be changed in order to reflect, at a minimum, the sampling of soils for treatability analysis. Please correct this oversight.
Section 3.2 Soil Sampling Location and Frequency
7. This section should be expanded to, at a minimum, name the EPA Region IV protocols to be
used and briefly describe those protocols. Please correct this oversight.
Section 4.2 Air Sampling Location and Frequency
8. This section should be expanded to, at a minimum, name the EPA Region IV protocols to be used and briefly describe those protocols. Please correct this oversight.
Section 4.6 Air Sampling Screening and Analysis
9. This section should be expanded to, at a minimum, name the EPA Region IV protocols to be used and briefly describe those protocols. Please correct this oversight.
Mr. Michael Townsend
Comments
Page 7
•
Section 5.4 Air Sampling Equipment
•
10. This section states that decontamination is to be conducted by " ... purging the tools with ambient air for a given amount of time." Please provide additional information for the
decontamination of air sampling tools. This should include the amount of time required for purging, how the ambient air is to be assured of being contaminant free, etc.
Appendix B Standard Operating and Preventative Maintenance Procedures
11. The title on the title page of this section is incorrectly spelled. Please correct this oversight.
12. This section is very general and does not provide adequate information for the operation and
maintenance of the photoiGnization detector. Additionally, this section should ·provide
calibration procedures. Please make the appropriate changes to this section.
QUALITY ASSURANCE PROJECT PLAN
Section 2.4.1 Soil Impact
1. The information provided in this section is inadequate in delineating the horizontal and
vertical distribution of contaminants present at the site. Additionally, this section is inadequate in accurately describing the variety of contaminants present at the site. The statement that "other compounds, including semivolatiles, organics, and pesticides as well as
radioactive parameters, were only identified at trace concentrations in a very limited number
of locations" is inaccurate and misleading. In accordance with NC DENR comments
following the Revised Remedial Investigation Report (Brown and Caldwell, 1994), all references to trace amounts of contaminants were to be removed. Furthermore, Table 3
indicates that the majority of Geoprobe samples that had maximum concentrations were
located at soil sampling location G-4 at a depth of 39-40 feet. However, Table 3 fails to include the details from the Limited Site Assessment and Source Area Characterization
Report (S&ME, 1996), including the fact that this soil sample was analyzed with a dilution
factor of 125 and that sample-analysis was conducted although the samples' holding times had
expired or were near expiration for several analyses. Lastly, the lack of adequate site characterization, primarily vertical delineation, at this site is cited in Section 4.0. of the
Remedial Design Work Plan as a potential problem. NCSU should bear in mind 'that all
sources of soil contamination, including secondary sources, must be remediated in accordance
with the Record of Decision (ROD). Please make the appropriate changes to this section.
Mr. Michael Townsend
Comments
Page 8
•
Section 2.4.2 Groundwater Imp:i.ct
•
2. This section provides very little detail as to the groundwater contamination present at this site. Although the Superfund Section acknowledges that the groundwater contamination is to be addressed by natural attenuation through additional remedial activities to be conducted at the site, this section should include greater detail in order to accurately characterize the site.
Please correct this oversight.
Section 3.1 Quality Assurance Objectives For Measurement Data
3. The last sentence in the second paragraph of this section states that "In general, the guidelines
established in the EPA's SOPQAM will be adhered to." Please clarify the message and intent
of this statement.
Section 4.2 Sampling Methods
4. This section should be expanded to, at a minimum, name the EPA Region IV protocols to be used and briefly describe those protocols. Please correct this oversight.
HEALTH AND SAFETY PLAN
Table of Contents
I. Table 5 -Volatile Constituents List was inadvertently omitted from the List of Tables. Please
correct this oversight.
2. Additional comments from Mr. David Lilley, Superfund Section Industrial Hygienist, are
attached. Please address these comments as well.
• • NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
February 4, 1998
TO: David Mattison
FROM: David Lilley
RE: .comments prepared on the Health and Safety Plan for NCSU, Lot 86, Raleigh, NC January, 1998
After reviewing the above mentioned document, I offer the following comments:
1.
2 .
3.
4 •
5.
Page 19, 3rd paragraph under Section 4.1: The last line reads ''Workers will not be allowed to return to these areas until conditions improve". Please quantify the term "improve".
Page 19, last paragraph: A list of direct reading instruments is included, along with the statement that each instrument "will have an alarm set to activate prior to vapor concentrations reaching constituent based health levels". However, there is no mention of what those levels are. Please include this information.
Page 20: The conventional term for a "lower explosive limit meter" is "combustible gas indicator". A PID measures total volatile ionizables, not just organics.
Page 20, 2nd paragraph under Section 4.2: The use of leather gloves as an outer garment is not recommended.
Page 20, Section 4.4: It is stated that ''All other OSHA requirements regarding excavations, (29 CFR Parts1926.650 through 652) will be observed". What are those requirements, and how and when will the workers be informed of the requirements?
6. Page 22: Why would stepladders be used if you are not entering the excavations?
7. Page 23, 2nd bullet i tern: "Awareness of surroundings and operations in the immediate
vicinity is required". What does this mean?
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919-71 S-3605 AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLE0/10% POST-CONSUMER PAPER
• •
8. Page 23, Section 4.6.4: If excavation work will be conducted with a trackhoe, why would hand augering be necessary? Keeping clear of the auger handle in the event of an explosion is not realistic (how do you know something is about to explode?). This augering procedure seems unnecessary, and a good way to loose body parts.
9.
10.
Page 24, Section 4.6.5, 1st bullet item: respiratory protection? The safety plan place to put this information.
Page 24, Section 4.6.6, 2nd bullet item: term "sensible lifting limits''.
dl/DL/shsp.com/45
What is "proper"
is the appropriate
Please define the
4WD-NSMB
\. • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
March 11, 1997
Dr. Abu M. Z. Alam
National Starch & Chemical Company
10 Finderne Avenue
P.O. Box 6500
Bridgewater, NJ 08807-0500
SUBJ: Extension of Due Date for the Field Investigations Summary Report and Conceptual Design Report for Operable Unit #3 and Operable Unit #4 at the National Starch & Chemical Company Superfund Site
Dear Dr. Alam:
The Agency concurs with National Starch & Chemical Company's request to postpone the submittal dates for the two documents referenced above due to the delay experienced by the driller. The new due date is March 24, 1997 for these two documents. And as discussed during our March 7 telephone conversation, this delay will not impact the' due date of the draft Remedial Design documents.
If you have any questions, please call me at [phone].
cc: David Lown, NCDEHNR
Stedman Southall, EPA
Sincerely yours,
1::=~ Remedial Project Manager
Recycled/Recyclable• Printed with Vegetable OIi Based Inks on 100% Recycled Paper (40% Postconsurner)