NCD980557805_20090223_Kerr McGee Corporation_FRBCERCLA RA_Phase 3 Remedial Action Work Plan-OCR

iRONOX
Robert E. Pounds
Project Manager
Phone [phone]
Fax [phone]
e-mail [e-mail]
February 23, 2009
By Overnight Mail
Mr. Erik Spalvins
USEPA Region 4
Waste Management Division, SERRB
61 Forsyth Street
~ ~ CC ~ ~ '1//l _!f .~,
I.
FEB 2 4 2009 / 1/
Atlanta, GA 30303
Re: Response to Recommendations and Work Plan Submittal
Phase 3 Remedial Investigation
Kerr-McGee Chem Corp Site
Navassa, Brunswick County, NC
U.S. EPA Region 4, CERCLA 04-2006-3772; June 28, 2006
Dear Mr. Spalvins:
,__ ____ I i
SUPERFUND SECTICJI\J
On August 13, 2008, U.S. EPA Region IV provided Tronox LLC with recommendations for Phase
3 Remedial Investigation activities at the Navassa, North Carolina Site. A conference call was
held between Tronox, ENSR, U.S. EPA, and other regulatory stakeholders on August 21, 2008 to
discuss these recommendations.
Subsequent to the above activities, Tronox retained KU Resources, Inc. to assume responsibility
for completing the Remedial Investigation/Feasibility Study (RI/FS) activities at the Site, including
the preparation of the Phase 3 RI Work Plan. The following presents our point-by-point response
to the August 13, 2008 recommendations. A Phase 3 RI Work Plan is also enclosed for your
review and approval.
RESPONSE TO RECOMMENDATIONS
The Navassa Site has been extensively characterized via pre-RI activities (including an extensive
Environmental Site Investigation that supported the development of the RI Work Plan), as well as
Phase 1 and Phase 2 RI activities. This work has included the installation of more than 75 soil
borings, 77 cone penetrometer/ROST points, 34 temporary monitoring wells, 21 permanent
monitoring wells, 10 test pits; and the collection and analysis of more than 190 soil, 75
groundwater, 14 surface water, 115 sediment, and 6 waste samples. As has been previously
discussed between Tronox and U.S. EPA, we are confident that, with minor exceptions, the Site
physical and environmental quality conditions have been adequately characterized to support
human health and ecological risk evaluations and corresponding remedial decisions. The
following responses and the enclosed Phase 3 RI Work Plan focus on filling the remaining data
gaps at the Site.
Shallow Groundwater
1. Adequacy of MW-11 to delineate groundwater plume from the former process area:
Well TMW-10, installed in the former process area, was screened between approximate
elevations +19 and +14. The groundwater level elevation measured in this well in 2004 was
approximately +18. Based on the boring log, the depth of setting, and the water level elevation, it
appears that TMW-10 monitored a perched water zone in the former process area.
Tronox LLC • P.O. Box 268859, Oklahoma City, OK 73126-8859
One Leadership Square, Suite 300,211 N. Robinson Ave., Oklahoma City, OK 73102-7109
Well MW-11 is screened between approximate elevations +2 and -8, with the filter pack extending
above the screen to approximate elevation +5. The groundwater level elevation in this well in
January 2008 was +3.22. Based on this information, this monitoring well appears to be
appropriately screened to monitor shallow groundwater quality at this location. The groundwater
quality data for this well indicates that the well delineates the eastern edge of the groundwater
plume originating in the former process area.
We do not believe that an additional monitoring well(s) between existing wells MW-2 and MW-11,
as suggested by U.S. EPA, is warranted. The former process area is a known source, and has
been characterized by numerous soil borings, CPT/ROST borings, temporary monitoring wells,
and existing monitoring well MW-3 (impacted), located north of the suggested additional well(s).
Groundwater quality results from MW-16, located downgradient of the former process area and
upgradient of the former wastewater pond indicate that the process area plume does not extend
to this location. With the exception of further delineation to the west (discussed below), the
groundwater quality in the former process area has been adequately characterized.
2. Shallow groundwater characterization west of Navassa Road: We agree that additional
shallow groundwater quality evaluation is warranted in the area west of Navassa Road, and
propose to install a shallow monitoring well at the southeastern edge of the clearing on the radio
station property, roughly across Navassa Road from the RICPT-38 location. Should evidence
during well installation indicate the presence of impacts in this area, we propose to complete the
planned well installation, and then install an additional well further to the west in the radio station
clearing, beyond any observable impacts that may be noted during drilling. This may involve the
step-wise installation of several soil borings within the radio station clearing area to finalize the
contingent western well location.
We do not believe that a monitoring well on the east side of Navassa Road is warranted, given
the groundwater quality results available for MW-2 and MW-4.
Two sediment samples will also be collected in the marsh, to the west of Navassa Road in
locations selected to attempt to avoid potential impacts from the road/bridge.
We agree that a deep well west of Navassa Road is not warranted.
3. Adequacy of screen settings at MW-7 and MW-14: The screen setting of MW-14 is
between approximate elevations -7 and -17, with the filter pack extending above the screen to
approximate elevation -3. The groundwater level elevation in January 2008 was +2.26. Well
TMW-12 was screened between approximate elevations+3 and -2, with the filter pack extending
to approximate elevation +4. The groundwater level elevation in TMW-12 was approximately +3.
It appears that TMW-12 and MW-14 are monitoring generally the same unit. We agree that the
MW-14 groundwater quality results are inconsistent with TMW-12, as well as with the noted
presence of creosote odors in the MW-14 boring log. We recommend resampling MW-14 to
further evaluate this discrepancy.
The screen setting at MW-7 is between elevations -18 and -28; similar to the settings of MW-4,
MW-5, MW-6, and MW-15 (all of which show groundwater quality impacts). Based on the data,
and groundwater quality information from the areas around MW-7, it appears that MW-7
delineates the eastern extent of the groundwater plume originating in the former process area.
We do not propose any further evaluations in this area.
A shallow temporary monitoring well will be installed south of MW-8, in an equipment-accessible
area along the edge of the marsh.
2
4. Groundwater/pore water quality in the marsh near MW-8: As noted above, a shallow
temporary monitoring well will be installed along the marsh, south of MW-8. Pore water sampling
in known impacted areas of the marsh is not warranted.
Deep Groundwater
5. Additional well cluster between MW-2 and MW-11: As discussed above, we believe that
the former process area groundwater quality has been adequately characterized. Additional wells
in this location are not warranted.
6. Deep groundwater quality downgradient of the wastewater pond area: A deep
monitoring well will be installed at the southeast corner of the former wastewater pond, near
existing well MW-15. The well will be installed using direct-push methods, to a targeted depth of
approximately 65 feet (similar to the depth setting of MW-14O and MW-16O). An offset soil
boring will be installed in the area first, to evaluate physical conditions. If this boring shows
obvious impacts in the shallow zone, relocation of the deep well will be necessary to avoid the
potential for impacting the deeper unit via the well borehole.
Groundwater
7. Analysis for benzene: The constituent benzene appears to have been inadvertently omitted
from the lists of Chemicals of Potential Concern included in the Phase 2 Work Plan. Phase 3
groundwater analysis will include benzene.
Surface Soil
8. Characterization of possible additional pond area: Three shallow soil borings will be
installed in this area, shown on the 1975 aerial photograph. Termination depth will be determined
based on field observations. If field observations indicate that this area represents a potential
source area, soil samples will be submitted for laboratory analysis.
9. Detection limits versus screening levels: We have reviewed the analytical detection limits
for the soil analyses. In some instances, elevated constituent concentrations resulted in
increased reported detection limits for constituents not detected. However, in those cases,
multiple constituents were detected at concentrations above the identified comparison levels. For
the samples that did not exhibit notable constituent concentrations, the detection limits appear to
be sufficient to allow appropriate evaluation. A table comparing analytical detection limits in soil
versus the identified comparison levels is attached.
10. Drainage ditches along Navassa Road: Shallow test pits will be installed in two drainage
swales located along the northwestern side of the site. The termination depth will be determined
based on field observations, but will be sufficient to observe the interface between the ditch/ditch
sediment base and the underlying soil. If field observations indicate that this area represents a
potential source area, soil samples will be collected and submitted for laboratory analysis. This
information will be used to determine whether additional evaluations should be conducted for the
drainage ditches across (west of) Navassa Road. Should such sampling be warranted, a
supplemental work scope will be prepared and access permission will be sought from the
appropriate property owners.
Subsurface Soil
11. As discussed above, the existing information base indicates that the former process area
represents a source area, and additional sampling in this area is not warranted. It is recognized
that supplemental sampling may be necessary in the Pre-Design phase to support the final
design and implementation of certain remedial measures that could be selected for this area.
3
We appreciate the opportunity to provide these responses and the enclosed Phase 3 RI Work
Plan. Should you have any questions or require additional information, please contact me by
telephone at [phone] or by e-mail at [e-mail].
ec: Tom Dillon/Michel Gielazyn -NOAA
Dave Kerschner -KU Resources
Ray Livermore -USACE Wilmington, NC
Dave Mattison -NCDENR
Sara Ward -US Fish and Wildlife
File
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Sincerely,
12~~~/Cr
TABLE
COMPARISON OF PHASE 2 RI REPORTED CONSTITUENTS AND DETECTION LIMITS
Kerr-McGee Chem Corp. Site
Navassa, North Carolina
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SW8081 ALDRIN 309-00-2 u9/k9 1800 1.9
SW8081 BETA BHC 319-85-7 uglk9 1260 1.9
SW8081 DIELDRIN 60-57-1 u9/k9 3100 1.9
SW8081 ENDOSULFAN SULFATE 1031-07-8 uglk9 370000 1.9
SW8081 ENDRIN 72-20-8 ug/k9 18500 1.9
SW8081 ENDRIN ALDEHYDE 7421-93-4 ug/kg 18500 1.9
SW8081 ENDRIN KETONE 53494-70-5 ug/kg 18500 1.9
SW8081 GAMMA BHC · LIN DANE 58-89-9 u9/k9 1740 1.9
SW8081 GAMMA CHLORDANE 5103-74-2 ug/kg 6500 1.9
SW8081 METHOXYCHLOR 72-43-5 u9/k9 308000 3.8
SW8081 P,P-DDT 50-29-3 u9/k9 7020 1.9
SW8081 TOXAPHENE 8001-35-2 ug/k9 1570 38
SW8260 1,1,2,2-TETRACHLOROETHANE 79.34.5 ug/k9 929 5.2
SW8260 1,2-DIBROMO-3-CHLOROPROPANE 96-12-8 ug/k9 2020 11
SW8260 CARBON DISULFIDE 75-15-0 u9/kg 720000 11
SW8260 CYCLOHEXANE 110-82-7 ug/k9 140000 11
SW8260 ETHYLBENZENE 100-41-4 u9/kg 740000 5.2
SW8260 ISOPROPYLBENZENE 98-82-8 u9/k9 52100 5.2
SW8260 METHYL ACETATE 79-20-9 u9/k9 9150000 11
SW8260 METHYL TERTIARY BUTYL ETHER 1634-04-4 u9/kg 36400 5.2
SW8260 METHYLCYCLOHEXANE 108-87-2 u9/kg 872000 11
SW8260 TOLUENE 108-88-3 u9/kg 220000 5.2
SW8260 TRICHLOROTRIFLUOROETHANE 76-13-1 u9/k9 5600000 5.2
SW8270 1,1-BIPHENYL 92-52-4 u9/kg 2330000 360
SW8270 1,2,4-TRICHLOROBENZENE 120-82-1 u9/k9 21600 180
SW8270 1,2-DICHLOROBENZENE 95-50-1 ug/kg 410000 180
SW8270 1,4-DICHLOROBENZENE 106-46-7 ug/k9 7870 180
SW8270 2,4,5-TRICHLOROPHENOL 95.95.4 u9/k9 6160000 180
SW8270 2,4,6-TRICHLOROPHENOL 88-06-2 ug/k9 61600 180
SW8270 2,4-DICHLOROPHENOL 120-83-2 ug/kg 185000 180
SW8270 2,4-DIMETHYLPHENOL 105-67-9 ug/k9 1230000 180
SW8270 2,4-DINITROPHENOL 51-28-5 u9/kg 123000 700
SW8270 2,4-DINITROTOLUENE 121-14-2 u9/kg 123000 180
SW8270 2,6-DINITROTOLUENE 606-20-2 u9/k9 61600 180
SW8270 2-CHLORONAPHTHALENE 91-58-7 ug/k9 2340000 180
SW8270 2-CHLOROPHENOL 95-57-8 ug/kg 23600 180
SW8270 2-METHYLNAPHTHALENE 91-57-6 ug/k9 18800 180
SW8270 2-METHYLPHENOL 95-48-7 ug/k9 3080000 180
SW8270 2-NITROANILINE 88-74-4 u9/k9 183000 180
SW8270 2-NITROPHENOL 88-75-5 u9/k9 23600 700
SW8270 3,3-DICHLOROBENZIDINE 91-94-1 uglk9 3830 700
SW8270 3-NITROANILINE 99-09-2 u9/k9 82100 180
SW8270 4,6-DINITRO-2-METHYLPHENOL 534-52-1 uglk9 6160 700
SW8270 4-BROMOPHENYL PHENYL ETHER 101-55-3 u9/k9 180
SW8270 4-CHLORO-3-METHYLPHENOL 59-50-7 u9/k9 180
SW8270 4-CHLOROPHENYL PHENYL ETHER 7005-72-3 u9/k9 180
Page 1 of 2
TABLE
COMPARISON OF PHASE 2 RI REPORTED CONSTITUENTS AND DETECTION LIMITS
Kerr-McGee Chem Corp. Site
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
SW8270
Navassa, North Carolina
4-NITROPHENOL
ACENAPHTHENE
ACENAPHTHYLENE
ACETOPHENONE
ANTHRACENE
ATRAZINE
BENZALDEHYDE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(G,H,l)PERYLENE
BENZO(K)FLUORANTHENE
BI5(2-CHLOROETHOXY)METHANE
BI5(2-CHLOROETHYL) ETHER
BIS(2-CHLOROISOPROPYL)ETHER
BI5(2-ETHYLHEXYL) PHTHALA TE
CAPROLACTAM
CARBAZOLE
CHRYSENE
DIBENZ(A,H)ANTHRACENE
DIBENZOFURAN
DIETHYL PHTHALA TE
DIMETHYL PHTHALATE
DI-N-BUTYL PHTHALATE
FLUORANTHENE
FLUORENE
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
INDENO(1,2,3-CD)PYRENE
ISOPHORONE
M-DICHLOROBENZENE
NAPHTHALENE
NITROBENZENE
N-NITROSODI-N-PROPYLAMINE
N-NITROSODIPHENYLAMINE
P-CHLOROANILINE
PENTACHLOROPHENOL
PHENANTHRENE
PHENOL
PYRENE
PYRIDINE
100-02-7
83-32-9
208-96-8
98-86-2
120-12-7
1912-24-9
100-52-7
56-55-3
50-32-8
205-99-2
191-24-2
207-08-9
111-91-1
111-44-4
108-60-1
117-81-7
105-60-2
86-74-8
218-01-9
53-70-3
132-64-9
84-66-2
131-11-3
84-74-2
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
193-39-5
78-59-1
541-73-1
91-20-3
98-95-3
621-64-7
86-30-6
106-47-8
87-86-5
85-01-8
108-95-2
129-00-0
110-86-1
Page 2 of 2
u9/k9
u9/k9
u9/k9
ug/kg
u9/k9
u9/k9
u9/k9
u9/k9
u9/k9
u9/k9
u9/k9
ug/kg
u9/k9
u9/k9
u9/k9
u9/k9
u9/kg
u9/k9
u9/kg
ug/kg
u9/kg
ug/kg
ug/kg
ug/k9
ug/k9
ug/kg
ug/kg
ug/k9
ug/kg
ug/kg
u9/k9
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ugik9
ug/kg
ug/k9
ug/kg
ug/k9
ug/k9
23600
2920000
2920000
100000000
7760
6160000
2110
211
2110
2910000
21100
575
7350
123000
100000000
86200
211000
211
156000
100000000
100000000
6160000
2200000
2630000
1080
22100
366000
123000
2110
512000
600000
18800
10300
246
352000
246000
9000
24000000
18000000
2910000
61600
700
180
180
360
180
360
360
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
180
700
180
180
180
700
Kerr-McGee Chemical Corporation Site Summary
The Kerr-McGee Chemical Corporation Site (Site) is located within the limits of the Town of
Navassa, in Brunswick County, North Carolina. The Site is bounded to the north by North Navassa
Road and the Rampage Boat Company; to the east by the Brunswick River; to the south by
Sturgeon Creek, which empties into the Brunswick River at the southeast corner of the Site; and to
the west by South Navassa Road and several private residences. Coordinates for the central
portion of the Site are 35'14'48" N latitude and 77'59'57" W longitude.
The Site was utilized as a creosote based wood treating facility from the mid 1930s until 1974. The
original creosoting plant at the Site was constructed by Gulf Coast Creosoting Company in
approximately 1936. American Creosoting purchased the facility in 1958, and sold it to Kerr McGee
in 1965. Kerr McGee discontinued site operations for economic reasons in 1974. The plant was
decommissioned and dismantled in 1980 (Kerr McGee, 1984). Tronox LLC (Tronox) was formed
as a subsidiary of Kerr McGee in 2005, and in 2006 was spun off into an independent company.
Tronox has assumed the liability of the Site and has agreed to perform an RI/FS at the Site.
The Site is approximately 301 acres in size. The western half of the Site was utilized during the
wood treatment activities. The northwestern portion of the Site was used primarily for storage of
treated and untreated wood. The southwestern portion of the Site was used in the creosote wood
treatment process. The eastern portion of the Site has never been developed, as verified by
historical aerial photographs. It is heavily wooded and bound to the east by salt water marsh. A
small parcel of private property, approximately two acres in size, is located within the east central
portion of the Site. There are three houses located on the residential property. The residential
property is connected to Navassa Road East by Canal Road. Canal Road is an unpaved road
approximately 1/.-mile long and partially maintained by the town of Navassa.
There is little evidence of any wood treating operation related structures remaining at the Site. The
majority of the Site is overgrown with trees and underbrush. The topography of the Site is generally
flat, sloping slightly to the east and south towards the Brunswick River and Sturgeon Creek.
Proceeding west to east, elevation drops from a high of approximately 25 feet above mean sea
level (MSL) to approximately sea level in the salt marsh that bounds the southern and eastern sides
of the Site. Groundwater is encountered beneath the site at depths ranging from approximately 2
feet below land surface (BLS) along the southern and eastern edges of the Site to greater than 15
feet BLS in the northern portion of the Site.
Currently, the Site is not included on the USEPA National Priorities List (NPL); however, USEPA
Region 4 has classified the Site as an "NPL-Equivalent". As such, the USEPA is the lead agency
and the NC DENR is the support agency for the remedial investigation of the Site. It is my
understanding that all NC DENR costs incurred to date have been paid via the support agency
agreement with the USEPA.
An Expanded Site Inspection (ESI) was completed at the Site in August 2005. The ESI included
collection of soil, sediment, surface water and groundwater samples from several areas at the Site.
In July 2006, the USEPA and Tronox entered into an Administrative Order on Consent (AOC)
pursuant to the Comprehensive, Environmental Response, Compensation and Liability Act of 1980
(CERCLA) for a Remedial Investigation/Feasibility Study (RI/FS) at the Site. Based on the results
of the ESI, Tronox developed a RI/FS Work Plan to further evaluate environmental media at the
Site and, as part of the RI, Tronox investigated several areas of the Site. In conjunction with the RI
activities, a baseline risk assessment was being conducted as well. However, the RI and baseline
risk assessment have not been completed to date.
The ESI and subsequent RI identified several areas at the Site with concentrations of creosote
related Polynuclear Aromatic Hydrocarbons (PAHs) in soil, sediment, and groundwater on or
beneath the Site, primarily beneath the Former Process Area, Former Evaporation Pond, and the
southern end of the Site downgradient of the Former Wastewater Ponds. RI groundwater quality
data indicates that dissolved phase concentrations of creosote related compounds are present in
groundwater beneath the Site. A small amount of dense non-aqueous phase liquid (DNAPL) was
also encountered in two wells (MW5 and MW6) located on the south side of the Former Wastewater
Ponds. Small areas of DNAPL have also been detected in the subsurface beneath the former
process area and the former wastewater treatment ponds.
Slug tests in the eight monitoring wells have allowed the calculation of an average K between 3.46
and 3.74 ft/day for the upper portion of the surficial aquifer beneath the Site. This K value, the
hydraulic gradient, and an assumed porosity for the soils in the upper portion of the surficial aquifer
have been used to calculate a groundwater flow rate in the surficial aquifer of 0.04 ft/day or 14.6
ft/year. Based on the direction of groundwater flow, the length of time since the facility started
operation (over 70 years ago), and the calculated groundwater flow velocity~ appears that
dissolved phase contaminants are migrating with groundwater flow to the tidal marsh to the south
and southeast.
Results of a tidal study indicate an interaction between surface water and groundwater as
evidenced by directly proportional fluctuations in groundwater and surface water elevations. This is
also evidenced by the increases in conductivity levels in groundwater as groundwater elevations
decrease due to r_educed freshwater influx. The study has indicated that tidal influence is more
prominent in the surficial aquifer near the tidal marsh.
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PHASE 3 REMEDIAL INVESTIGATION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA, NORTH CAROLINA
Prepared for:
TRONOX, LLC
P.O. BOX 268859
OKLAHOMA CITY, OKLAHOMA 73126-8859
FEBRUARY 2009
KU Resources, Inc.
ENVIRONMENTAL MANAGEMENT -SITE DEVELOPMENT ENGINEERING
22 SOUTH LINDEN STREET
DUQUESNE, PA 15110
[phone]
FAX [phone]
WWW.KURESOURCES.COM
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PHASE 3 REMEDIAL INVESTIGATION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA, NORTH CAROLINA
Prepared for:
TRONOX, LLC
P.O. BOX 268859
OKLAHOMA CITY, OKLAHOMA 73126-8859
Prepared by:
KU RESOURCES, INC.
22 SOUTH LINDEN STREET
DUQUESNE, PENNSYLVANIA 15110
FEBRUARY 2009
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PHASE 3 REMEDIAL INVESTIGATION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA, NORTH CAROLINA
FEBRUARY 2009
TABLE OF CONTENTS
1 ,0 INTRO DU CTIO N , .. , , , , ....... , , , .. , , , , , , .. , , , , ..... , , , , , , , .. , , , , , , , ...... , , .. , , , , , .. , , , , .. , ..... , , , , , , .. , , , , , , , .. , ... , .... , , , , , , , , , , , , , ..... , 1
2,0 PHASE 3 RI SCOPE OF WORK ..................................................................................................... 2
2,1
2,2
2,3
2.3.1
2,3,2
2.4
2,5
2,6
Off-Site Access and Phase 3 RI Utility Clearance ................................................................. , 2
Investigative Methodologies.,,,,,,,, .. ,,,, .. ,,, ...... ,, ... , .. ,, .. ,,,,.,,, ....... ,,,, .. ,, .... , .. , ... , .... , .. , .. , .... ,, .. ,,,, .. , .. 2
Monitoring We II Installation , , , , , , , .. , , , ...... , .. , , , , , , , , , , , .... , .. , , , , , , , , , , , , , , , ....... , .. , , , , , , , , , , , ... , .... , .. , , , , , , , , , , .. , .. , 3
Shallow Monitoring Wells,,,,,,, ....... , ... ,,,,, .. , .. , ........... ,,,,,,, .. , ..... ,,,,,,,,,,.,,,, ........ ,,,,,,,,,,,, .. , ....... , 3
Deep Monitoring Well ................................................ , ........................................... , .............. , 3
So ii Boring and Test Pit Installation ........................................................................... , ............ 4
Sediment Sampling ... , , , , , , .. , , , , , , , , , , , , , .. , , , , , .. , , .. , .... , , ...... , , .. , , , , , , , . , , , ... , . , , , .. , , , , , , .. , , . , , , ... , .. , , , , , , , , , , .. , , , , .. , , 4
Groundwater Sampling , , ........ , , , , , .. , , , , , , .. , ..... , , , , , , , , , .. , , , .. , ... , . , .. , , .. , , , , , , . , , ....... , .. , .. , , , , , , , .. , .... , , , , , , .... , , , 5
3. 0 REFERENCES,,,,, .. ,, ....... ,, .. , .. ,,, .. ,, ......... ,,,,,,,,,,,,,, ...... ,.,,, .. ,,,,,,,,,, ... ,, .. ,,,,,,,,,,,,,,.,, .. , .. ,,,, .. ,,,,,, ...... ,,,,,, 6
TABLE
Table 2-1 Analytical Parameters and Methods
I FIGURE
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Figure 2-1 Phase 3 RI Sampling Locations
TRON.09040NAV.P
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1.0 INTRODUCTION
PHASE 3 REMEDIAL INVEST/GA TION WORK PLAN
KERR-MCGEE CHEM CORP SITE
NAVASSA, NORTH CAROLINA
FEBRUARY 2009
On June 28, 2006, Tronox, LLC and the United States Environmental Protection Agency (U.S. EPA)
signed an Administrative Order on Consent, CERCLA 04-2006-3772 (AOC) pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) for a
Remedial Investigation/Feasibility Study (RI/FS) at the Kerr-McGee Chem Corp. Site (Site) in Navassa,
North Carolina.
The Site is not currently included on the U.S. EPA National Priorities List (NPL); however, U S EPA
Region IV has classified the Srte as an "NPL-Equivalent." The Site operated as a creosote-based wood
treating facility from the late 1930s until 197 4. Wood treating operations ceased in 197 4 and the facility
was completely decommissioned in 1980. Several companies operated the facility during its operating
history. Tronox, LLC was spun off into an independent company in 2006. Pursuant to the AOC, Tronox,
LLC is performing the RI/FS at the Site.
Phase 1 and Phase 2 RI activities were performed at the Site in 2006 and 2008, respectively, pursuant to
U.S. EPA approved Work Plans (ENSR/AECOM, 2006a and 2007). Following receipt and evaluation of
the Phase 2 analytical results, the results were transmitted to the U.S. EPA for review. On August 13,
2008, the U.S. EPA provided recommendations for the Phase 3 RI activities. Subsequently, and with
U.S. EPA approval, Tronox, LLC retained KU Resources, Inc. to complete the RI/FS activities.
Thrs document serves as the Work Plan for Phase 3 of the RI at the Site. This Phase 3 RI Work Plan
outlines the technical approach that will be used for further characterization of the Site (see Section 2.0)
and provides a detailed description of the Phase 3 RI field activities to be completed (see Section 3.0).
TRON 09040NAV.P
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2.0 PHASE 3 RI SCOPE OF WORK
PHASE 3 REMEDIAL INVEST/GA TION WORK PLAN
KERR-MCGEE CHEM CORP. $/TE
NAVASSA, NORTH CAROLINA
FEBRUARY 2009
Phase 3 RI activities will involve the installation of shallow and deep monitoring wells in on-Site and off-
Site locations, installation of on-Site shallow soil borings and associated collection/analysis of soil
samples, collection/analysis of off-Site sediment samples, and collection and analysis of on-Site and off-
Site groundwater samples The following describes the various Phase 3 RI activities to be performed.
2.1 Off-Site Access and Phase 3 RI Utility Clearance
Prior to the initiation of field sampling activities, the off-Site property owner will be notified of the need to
access the radio station property, in accordance with the existing access agreement. In addition, utility
clearances will be performed for all intrusive sampling locations, and sampling locations will be finalized
as appropriate if obstructions are identified.
2.2 Investigative Methodologies
Methods used to collect, prepare, preserve, ship, and analyze the environmental samples to be obtained
during Phase 3 RI activities are described in detail in the Sampling and Analysis Plan (SAP) and/or the
Quality Assurance ProJect Plan (ENSR/AECOM, 2006b and 2006c, respectively) that were prepared in
conjunction with the RI/FS Work Plan (ENSR/AECOM, 2006a). The table below lists the activities/actions
to be performed during the Phase 3 RI and identifies specific sections in the RI/FS plans where the
applicable methodologies are detailed.
ACTIVITY DOCUMENT SECTION
Soil Sampling Sampling and Analysis Plan 3.2.3
Soil Classification Sampling and Analysis Plan 3.2.1.2
Permanent Well Installation Sampling and Analysis Plan 3.2.2
Well Development Sampling and Analysis Plan 3.2.2.3
Well Sampling Sampling and Analysis Plan 3.2.6
Sediment Sampling Sampling and Analysis Plan 3.2.4
Equipment Decontamination Sampling and Analysis Plan 3.2.10
IDW Management and Disposal Sampling and Analysis Plan 3.2.8
Quality Control Sample Collection Quality Assurance Project Plan B.2.3
Sample Handling and Custody Quality Assurance Project Plan B.3
Table 2-1 identifies the analytical parameters and analytical methods that will be used for the Phase 3 RI
activities. These parameters, consisting of volatile organic compounds (VOCs) and creosote-related
semi-volatile organic compounds (SVOCs) were previously included in the listing of human health and
ecological Constituents of Potential Concern (COPCs) (ENSR/AECOM, 2007) It should be noted that
the constituent benzene, which appears to have been inadvertently omitted from the 2007 list of COPCs,
has been included on the Phase 3 RI voe analytical parameter list
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2.3 Monitoring Well Installation
2.3.1 Shallow Monitoring Wells
PHASE 3 REMEDIAL INVEST/GA TION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA. NORTH CAROLINA
FEBRUARY 2009
Two shallow groundwater monitoring wells (one on Site and one off Site) will be installed at the locations
shown on Figure 2-1. The purpose of these wells is to determine the western extent of the shallow
groundwater plume (the off-Site well), and groundwater quality at the edge of the salt marsh in the on-Site
location. The wells will be installed with direct-push equipment, using drive casing with expendable drive
points. Prior to well installation, continuous direct-push soil samples will be collected from grade to the
termination depth. Well depth settings will be similar to other shallow monitoring wells in these general
areas. Depths are anticipated to be approximately 30 feet below grade (targeting the base of the surficial
unit/top of the Peedee Formation), with the final termination depth to be determined in the field.
Soil samples will be logged in the field, and examined for the visible/odorous presence of wood treating
constituents. In the event that visible or odorous evidence of wood treating constituents is noted in the
planned off-Site location, the monitoring well will be installed in that location and a second (contingent)
well will be installed in a location further to the west. The initial contingent location will be approximately
100 feet further to the west. Should soil sampling again indicate the visible/odorous presence of wood
treating constituents, that boring will be sealed with hydrated bentonite chips, and an additional boring(s)
will be installed at 50-foot distances westward within the radio station clearing until no evidence of wood
treating constituents is noted during soil boring activities. The contingent shallow monitoring well will be
installed at that location, for the purpose of attempting to delineate the western extent of the shallow
groundwater plume.
Monitoring wells will be constructed using pre-packed PVC screens, which will be 10 feet in length. Pre-
packed bentonite seals with foam bridges will be used to construct the seals above the screens. Wells
will be extended to grade using threaded flush-joint PVC riser. The remainder of the borehole annulus
around the riser will be backfilled with hydrated bentonite. chips, and steel protectors (flush-mount for the
off-Site well) will be installed at grade. Wells will be secured with padlocks.
Following installation, the wells will be developed, and the top-of-casing and ground surface elevations
will be determined.
2.3.2 Deep Monitoring Well
One deep groundwater monitoring well will be installed at the location shown on Figure 2-1. The purpose
of this weli is to evaluate deep groundwater quality conditions downgradient of the former wastewater
pond. Prior to well installation, continuous direct-push soil samples will be collected from grade to the
termination depth at a location off-set approximately 1 O feet from the well location, for the purpose of
classifying the subsurface materials and determining the termination depth. The well depth setting will be
similar to other deep monitoring wells in this general area, and is anticipated to be approximately 60 to 65
feet below grade. Soil samples will be logged in the field, and examined for the visible/odorous presence
of wood treating constituents. Following completion, the borehole will be backfilled with hydrated
bentonite chips.
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PHASE 3 REMEDIAL INVEST/GA TION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA, NORTH CAROLINA
FEBRUARY 2009
The well will be installed with direct-push equipment, using drive casing with an expendable drive point.
The monitoring well will be constructed using pre-packed PVC screen, which will be 10 feet in length. A
pre-packed bentonite seal with foam bridges will be used to construct the seals above the screens. The
well will be extended to grade using threaded flush-joint PVC riser. The remainder of the borehole
annulus around the riser will be backfilled with hydrated bentonite chips, and a locking steel protector will
be installed at grade.
Should the direct-push equipment be unable to advance the drive casing to the desired depth, the well
will be installed using Rotosonic drilling methods.
Following installation, the well will be developed, and the top-of-casing and ground surface elevations will
be determined.
2,4 Soil Boring and Test Pit Installation
Three shallow soil borings will be installed in the area of a suspected pond feature shown on the 1975
aerial photograph, at the general locations shown on Figure 2-1. The purpose of these soil borings is to
determine whether this historical feature represents a potential source area. The soil borings will be
advanced using direct-push equipment, and the termination depths will be determined in the field. Soil
samples will be logged and examined for the visible/odorous evidence of wood treating constituents.
Should such evidence be noted, a minimum of two samples from selected depth intervals will be
submitted for laboratory analysis of the VOCs and creosote-related SVOCs identified in Table 2-1. Upon
completion, the boreholes will be backfilled with hydrated bentonite chips.
Two shallow test pits will be installed in each of two drainage swales located in the northwestern area of
the Site, to be determined in the field based on proximity to culvert connections between the eastern and
western roadside ditches. The purpose of these test pits is to determine whether these drainage features
were historically impacted, and could potentially represent a source of impacts to the west of Navassa
Road. The test pits will be advanced with a mini-excavator or equivalent The test pits will extend to the
ditch bottom (or sediment)/natural soil interface to allow examination of that soil interval. The test pit soils
will be logged and examined for the visible/odorous evidence of wood treating constituents. Should such
evidence be noted, a minimum of two samples from selected depth intervals will be submitted for
laboratory analysis of the VOCs and SVOCs identified in Table 2-1. Upon completion, the test pits will be
backfilled with the material excavated, in the reverse order of excavation (last excavated is first replaced).
In addition, if evidence of the significant presence of wood treating constituents is noted, a field
reconnaissance of potential off-Site sampling locations west of Navassa Road will be performed to
support obtaining access to these areas, as warranted.
2,5 Sediment Sampling
Two sediment samples will be collected from the marsh area to the west of Navassa road, in the general
locations shown on Figure 2-1. Sampling locations will target areas that are not anticipated to be affected
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PHASE 3 REMEDIAL INVESTIGATION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA, NORTH CAROLINA
FEBRUARY 2009
by the presence of the road/bridge. Samples will be examined in the field for visible/odorous evidence of
·wood treating constituents, and_ will be submitted for the SVOCs identified in Table 2-1.
2.6 Groundwater Sampling
The newly installed wells will be sampled approximately two weeks following the completion of
development activities. In addition, existing well MW-14 will be sampled to confirm the results of the
January 2008 sampling event for that well. Prior to sampling, the depth to water will be measured in all
wells at the Site, and each well will be evaluated for the presence of non-aqueous phase liquids (NAPLs).
Wells to be sampled will be purged in accordance with the SAP (ENSR/AECOM, 2006b). Purging
activities will include the collection of field measurements of dissolved oxygen, oxidation-reduction
potential, pH, temperature, specific conductivity, and turbidity.
Shallow and deep groundwater samples will be submitted for laboratory analysis of the VOCs and
SVOCs identified in Table 2-1.
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3.0 REFERENCES
PHASE 3 REMEDIAL INVEST/GA TION WORK PLAN
KERR-MCGEE CHEM CORP. SITE
NAVASSA, NORTH CAROLINA
FEBRUARY 2009
ENSR/AECOM, 2006a, Remedial Investigation/Feasibility Study Work Plan, Kerr McGee Chem Corp.
Site, Navassa, North Carolina, June 2006.
ENSR/AECOM, 2006b, Sampling and Analysis Plan, Kerr McGee Chem Corp. Site, Navassa, North
Carolina, June 2006.
ENSR/AECOM, 2006c, Quality Assurance ProJect Plan, Kerr McGee Chem Corp. Site, Navassa, North
Carolina, June 2006.
ENSR/AECOM, 2007, Phase 2 RI Work Plan, Kerr McGee Chem Corp. Site, Navassa, North Carolina,
November, 2007.
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TABLE
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TABLE 2-1
ANALYTICAL PARAMETERS AND METHODS
PHASE 3 REMEDIAL INVESTIGATION
Kerr-McGee Chem Corp. Site
Navassa, North Carolina
Analytical Soil Sediment Shallow
Method Groundwater
Deep
Groundwater
Creosote-Related SVOCs i~'.-•?'ft~1~1Pll:~~:.:OO:if.f~'f~~1\;fl~-;J:~~,·:J'ili:~1:'.~~i;;,15,:;i~i~~f::':'~1:~%f,,~~~~~1.~i~1':.~';:f
2-methylnaphthalene 8270
Acenaphthene 8270
Acenaphthylene 8270
Anthracene 8270
Benzo(a )anthracene 8270
Benzo(a)pyrene 8270
Benzo(b )fluoranthene 8270
Benzo(g. h.i)perylene 8270
Benzo(k)fluoranthene 8270
Chrysene 8270
Oibenz( a, h )anthracene 8270
Fluoranthene 8270
Fluorene 8270
lndeno( 1.2.3-cd)pyrene 8270
Naphthalene 8270
Phenanthrene 8270
Pyrene 8270
1, 1-Biphenyl 8270
Carbazole 8270
Dibenzofuran 8270
2-methylnaphthalene 8270C SIM
Acenaphthene 8270C SIM
Acenaphthylene 8270C SIM
Anthracene 8270C SIM
Benzo(a)anthracene 8270C SIM
Benzo(a)pyrene 8270C SIM
Benzo{b)fluoranthene 8270C SIM
Benzo(g,h, i)perylene 8270C SIM
Benzo( k) f I uo ran then e 8270C SIM
Chrysene 8270C SIM
Dibenz(a,h)anthracene 8270C SIM
Fluoranthene 8270C SIM
Fluorene 8270C SIM
lndeno(1,2,3-cd)pyrene 8270C SIM
Naphthalene 8270C SIM
Phenanthrene 8270C SIM
Pyrene 8270C SIM
voes -~" ':"i'
1, 1,2,2-Tetrachloroethane 8260
1,2,4-Trichlorobenzene 8260
1,2-Dibromo-3-chloropropane 8260
1,2-Dichlorobenzene 8260
1,4-Dichlorobenzene 8260
Carbon Disulfide 8260
Cyclohexane 8260
Benzene 8260
Ethylbenzene 8260
Toluene 8260
!sopropylbenzene 8260
M-Dichlorobenzene 8260
Methyl Acetate 8260
Methyl Tertiary Butyl Ether 8260
Methylcyclohexane 8260
Freon 113 8260
Constituents identified in ENSR/AECOM, 2007
"X" indicates analysis to be performed.
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X
X X X X
X X X X
X X X X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
V
X X X
X X
X X X
X X
X X
X X X
X X X
X X X
X X X
X X X
X X X
X X
X X X
X X X
X X X
X X X
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I FIGURE
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-C
NAVASSA, NORlH CAROLINA BY
ENSR/AECOM, COLUMBIA, SOUTH
CAROLINA DATED 01/07.
DATE
SCALE -FEET
0 300
DESCRIPTION
APPROVED -KU R ESOURCES, INC.
t-C_H_EC_K_ED_-:--:-_:--:-'."'.~:-:-:-1 22 SOUTH LINDEN STREET
DRAWN RAM 02/16/2009 DUQUESNE. PA 15110
[phone] CAD FILE NO. 090408001 FAlt [phone]
PROJECT NO.TRON.09040NAV.P www kuresourcesc:an
Cl FORMER PRODUCllON AREA
1111 FORMER UNlREATED WOOO STORAGE
11111 FORMER TREATED WOOO STORAGE
.. FORMER P<N>S
8 EXISTING MONITORlfG Y1ELL
~ PLANNED SHALLOW MONITORNG Y1ELL
■ PLANNED DEEP MONITORNG YIELl
• PLANNED SEDIIENT SAMPl£
• PLANNED SOL BORN.
FIGURE 2-1
PHASE 3 R1 SAMPLING LOCATIONS
KERR-McGEE CHEMICAL CORPORATION SITE
NAVASSA
BRUNSWICK COUNTY, NORTH CAROLINA
PREPARED FOR
TRONOX LLC
OKLAHOMA CITY OKLAHOMA