NCD991278540_20110901_Weyerhaeuser Company_FRBCERCLA RA_Operations and Maintenance Plan OU-2. January 2011 (Revised)-OCR

CTRC
Operations and Maintenance (O&M) Plan
Domtar Paper Company, LLC
Welch Creak Area OU-4, Plymouth, Martin County, North Carolina
January 2011, Revised September 2011
'Y --Domtar
00111tar Inc.
395, boul. de Mc1isonneuve Ou est
Montreal QC H3A ll6 Canada
T Sli\-St,8-5555
www.oomtc1r.com
September 15, 2011
Mr. Randy Bryant
Remedial Project Manager
Dorn tar Inc.
395 de Maisonneuve [ilvd. west
Montreal, QC H3A ll6 Canada
r 514-848-ssss
www.domtar.com
Superfund Remedial & Site Evaluation Branch
USEPA, Region 4, Atlanta Federal Center
61 Forsyth Street, SW, 11th Floor
Atlanta, GA 30303-3104
Subject: Final Document-Operable Unit-2 (OU-2); Lower Roanoke River, Remedial Design/
Remedial Action (RD/RA) Work Plan, Plymouth, NC
Dear Randy:
A negotiated Consent Decree (CD) for the RD/RA for OU-2 between Domtar and USEPA was filed
in January 2011, (Civil Action No. 4: I l-cv-00002; filed 1/04/09). Per the negotiated CD and
Statement of Work (SOW), Domtar is required to prepare a RD/RA Work Plan with associated
planning documents. These documents were submitted to US EPA and NCDENR in April 2011.
On July 21, 2011 Domtar received technical review comments on the above referenced document.
On August 18, 2011, Domtar submitted responses to USEPA's technical review comments.
Following discussions with Domtar, TRC Environmental Corporation and USEPA, acceptance of the
responses to the review comments was reached on August 29, 2011.
This letter transmits an electronic version of the documents revised in accordance with the accepted
responses to the Agency review comments. You will receive from TRC paper and CD copies of the
revised RD/RA Work Plan and associated documents.
Sincerely,
A__.,,,-· L---
Marce I Sylvestre
Director of Soil Rehabilitation
Marcel [e-mail]
Tel.: [phone], ext. 85324
Fax.: [phone]
cc: Nile Testerman -NCDENR
Amy Adams -NCDENR
Stephen Rynas-NCDENR
Bill Morris -Domtar
Diane Hardison -Domtar
Mike Parker-TRC
Karen Saucier-TRC
Encl. FSC
" .. ., ... ~""' , ........ ,,_ ..... , ......... o,
"''"""""'°""" "'""""'"' ....,..k,.-g o,.,.,~~,"-•• .. ~,..,,,,
n
H
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CTRC
f5) !Et!E~~IE~
ln1j SEP l 9 2011 IIW
SUPERFUND SECTION
Operations and Maintenance (O&M) Plan
Domtar Paper Company, LLC
Welch Creak Area OU-4, Plymouth, Martin County, North Carolina
January 2011, Revised September 2011
Robert W. Hanley, Ph.D.
Environmental Scientist
TRC E11viro11mental Corporation I Domtar Paper Company, LLC
O&M Plan
Principal-In-Charge
(?Z, ~£(! ~ E _QJL_
Michael B. Parker, P.E. ·
Senior Project Manager
\ \NT APA-GRNVILLE\GVL-VOLS\-\ WPGVL \P/T1 \00625\08\001 \R0062508001-003_REVISED.DOCX
30 PATEWOOD DRIVE, GREENVILLE, SC 29615, o 864.281.0030 PHONE o 864.281.0288 FAX o www.TRCSOLUTIONS.COM
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Table of Contents
1. Introduction ...................................................................................................................................... 1
1.1 History .................................................................................................................................... 2
1.2 Geographic Location ............................................................................................................. 2
1.3 SiteUse ................................................................................................................................... 3
1.4 Existing Data Summary ........................................................................................................ 4
1.5 eMNR'" Thin Layer Cap Description .................................................................................. 5
2. General Operation and Maintenance Requirements .................................................................. 9
2.1 Thin Layer Cap Maintenance .............................................................................................. 9
2.2 Sediment and Erosion Controls ........................................................................................ 10
2.3 Sampling Equipment Maintenance .................................................................................. 10
2.4 Site Access Maintenance .................................................................................................... 11
3. Safety Plan ...................................................................................................................................... 12
4. References ....................................................................................................................................... 13
List of Figures
Figure 1-1
Figure 1-2
Figure 1-3
List of Appendices
Appendix A
General Site Map ...................................................................................................... 6
Upper Reach -eMNR Cover Area ......................................................................... 7
Midstream Reach Plan View .................................................................................. 8
Maintenance and Inspection Checklist
TRC Environmental Corporation I Domtar Paper Company, LLC
O&M Plan
I I N'/'AP A-GRN\/ILLE\GVL-VOLS\-\ WPGVL \P/TI \00625\08\001 \R0062508001-003_REVIS£D,DOCX January 2011, Revised September 2011
I
I
I
I
I
I
I
I
B
R
I
Section 1
Introduction
The Welch Creek Area of the Domtar Paper Company, LLC (Domtar) 1 (formerly Weyerhaeuser
Company [Weyerhaeuser]) Plymouth Site, Martin County, North Carolina (site) is identified as
Operable Unit #4 (OU-4) of the site. A remedial investigation and feasibility study (Rl/FS) was
completed for this area under a negotiated Administrative Order of Consent during 1998
through 2007. The remedy for the Welch Creek Area was selected by United States
Environmental Protection Agency (USEPA) in accordance with Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by Superfund Amendment
and Reauthorization Act (SARA) and, to the extent practicable, the National Contingency Plan
(NCP). The remedy was summarized in the Record of Decision (ROD) and more fully outlined
in the Final Design Report (RMT, 2010). The remedial action selected in the ROD has five
components:
1. Enhanced Monitored Natural Recovery (eMNR™) of sediment contaminated with dioxin
above clean-up goals in the Upper Reach of Welch Creek;
2. Mobility monitoring for the less contaminated sediment in the Midstream Reach;
3. Long-term monitoring and maintenance of the eMNR™ sand cover;
4. Long-term testing and monitoring of sediment, surface water, and biota to document the
performance of the remedy and compliance with clean-up goals; and
5. Institutional controls.
The negotiated Consent Decree for the OU-4 Remedial Design/Remedial Action (RD/RA)
requires the preparation and submittal of a Performance Standard Verification and Operations
and Maintenance Plan (PSV/OM Plan). This Operations and Maintenance Plan (OMP), is
submitted under joint cover with the Performance Standards Verification Plan (PSVP) as a
component or RA Workplanning for Welch Creek Area. This OMP describes activities that will
be undertaken after the RA is completed. Operations and maintenance (O&M) activities will
provide a mechanism to maintain effectiveness of the selected remedy for OU-4, which is
installation of a thin-layer cap in the Upper Reach of OU-4 and mobility monitoring in the
Midstream Reach of OU-4.
1 Domtar Paper Company, LLC took ownership of the pulp and paper operations at the Plymouth Mill and assumed related
environmental obligations from Weyerhaeuser Company on March 7, 2007. Previous required reports under the AOC were
submitted by Weyerhaeuser.
YRC Environmental Corporation I Domtar Paper Company, LLC
O&M Plan l
\ \NT AP A-GRNVILLE\GVL-VOLS \-\ IVPGVL \ P/TI \ 00625 \08\001 \ R0062508001-Q03 _REVISED.DOCX January 2011, Revised September 2011
I
I
I
I
I
I
I
I
D
I
D
I
I
I
D
1.1 History
Welch Creek OU-4 of the Domtar Plymouth Site, Martin County has been defined as the
4.5-mile portion of the lower creek to the confluence of the creek with the Roanoke River. In the
OU-4 area, the creek averages approximately 120 feet in width, has an average maximum depth
of about 10.5 feet, and is bordered by wetlands approximately 1,000 feet in width. Figure 1-1
depicts OU-4.
The Domtar facility has been in continuous operation as an integrated, kraft process pulp and
paper mill since 1937. During this time frame, both unbleached and bleached pulp have been
manufactured by the facility. In 2009, Domtar announced plans to convert the facility to
manufacturing only bleached, kraft fluff pulp.
The facility operates a permitted (National Pollutant Discharge Elimination System [NPDES]
Permit No. NC000680) on-site wastewater treatment plant (WWTP) that treats wastewater from
the manufacturing operations. From 1957 until 1968, mill effluent was discharged into Welch
Creek at a point approximately 1.6 miles upstream from the confluence of Welch Creek and the
Roanoke River. In 1968, when the mill began constructing a series of wastewater treatment
ponds, a new Welch Creek outfall was constructed at a point approximately 2.3 miles upstream
from the confluence. In 1988, the treated effluent outfall was moved to the Roanoke River, and
this outfall is currently in use.
Due to the hydrologic setting and stable sediment conditions, wastewater treatment solids
discharged into Welch Creek have accumulated at the bottom of the creek. These accumulated
wastewater treatment solids were a main focus of the RI/FS activities conducted in OU-4 to
provide a mechanism to ensure that the RA for the Welch Creek Area achieves the overall RA
objectives (RAOs) by meeting both short and long term performance standards defined in this
plan. These performance standards incorporate the clean-up levels presented in the ROD
(USEP A, 2007) as well as other monitoring activities.
1.2 Geographic Location
Welch Creek is a tributary to the Roanoke River. The lower portion of Welch Creek forms the
boundary between Martin County (which lies to north and west from the creek) and
Washington County (which lies to the east and south). OU-4 extends 4.5 miles upstream from
the mouth of Welch Creek. The central business district of Plymouth, which is the county seat
of Washington County, is situated approximately½ mile to the east of OU-4.
Welch Creek is a slow-flowing, blackwater stream typical of the North Carolina Coastal Plain
physiographic region. Due to its proximity to the Roanoke River and Albemarle Sound, Welch
Creek is subject to both lunar and wind driven tides. From US Highway 64 to its mouth, the
TRC Environmental Corporation I Domtar Paper Company, LLC
O&MP/nn 2
\ \ NT AP A·CRNV/LLE\ GVL-VOl.5 \ -\ \VPGVL \ P/n \00625 \ OS \001 \R0062508001-Q03_REV/SED.DOCX January 2011, Revised September 2011
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
creek is bordered on both sides by wooded areas that extend landward from 50 to over 500 feet.
Much of the adjoining woodlands exhibit wetland characteristics. Dom tar's secondary
wastewater treatment facility and manufacturing facility border much of the left descending
bank. Domtar operations that border the right descending bank include a permitted solid waste
management facility, offices, and parking.
Most of the 4.5 mile stretch of Welch Creek which comprises OU-4 is located within the
property boundary of the active Domtar (formerly Weyerhaeuser) facility. The OU-4 portion of
Welch Creek is bounded by wooded wetlands along the east bank and the non-production Mill
facilities (parking areas, green space, wastewater settling ponds) along the west bank. Access to
the creek is restricted by Domtar, which maintains a perimeter fence along much of the facility's
boundary, and by a broad swath of wetlands bordering the creek. Vehicular access to Domtar's
site is through gates that are manned by security personnel.
Six bridges span the OU-4 portion of Welch Creek, and they are three railroad bridges, two
bridges for primarily mill-related automobile traffic and one bridge for mill-related utilities.
The low bridge clearances near the mouth restrict boat access from the river to upper reaches of
the creek except for small watercraft. There is one small boat ramp, accessible only from the
secured mill property along the central part of OU-4.
Upstream near US Highway 64, several private residences are located adjacent to the creek, but
downstream boat access is somewhat limited by natural obstructions. No public boat ramps are
located upstream from OU-4. Public boating access to OU-4 from the Lower Roanoke River
(LRR) is limited to the mouth of Welch Creek. Access to the Domtar (formerly Weyerhaeuser)
facility property boundary for ambulatory recreational activities along the creek is limited due
to the large expanse of dense vegetated wetlands and security fencing along most of the
property boundary.
The Domtar (formerly Weyerhaeuser) facility is expected to remain an active industrial facility
in the future, and site access is expected to continuously be controlled by perimeter fencing and
full time security.
1.3 Site Use
Welch Creek is a tidal water that is open to public access from the Roanoke River. No public
boat ramps directly access Welch Creek. A public boat ramp is located in Plymouth,
approximately 1 mile downstream from the mouth of Welch Creek. Small boats can access
OU-4 from the mouth of Welch Creek, and can navigate upstream of the Upper Reach (that
portion of OU-4 where the thin layer cap will be placed).
TRC Environmental Corporation I Dom far Paper Company, LLC
O&M Pinn 3
I I NTl\l'A-GRNVILLE\CV!.-V0/.5\• I WPGVL \!'{TI \00625\08 \001 \R0062508001-003_REV/SED.DOCX January 2011, Revised September 2011
I
I
I
I
D
I
I
g
I
I
I
I
I
I
I
Domtar owns the land on both sides of Welch Creek for most if this operable unit. Access to the
creek is restricted by Domtar, which maintains a perimeter fence along much of the facility's
boundary, and by a broad swath of wetlands bordering the creek. Domtar land on both sides of
Welch Creek is either undeveloped, flood-plain forest, or used for mill-related activities, such as
vehicle parking, material and equipment storage, and effluent treatment.
Since Welch Creek is accessible by fishermen, signage will be installed along both banks of the
Upper Reach notifying boaters of the thin layer cap and prohibiting the use of equipment that
could damage the cap, such as anchors, trot-lines or traps. Signage regarding the current fish
consumption advisory will also be maintained until North Carolina Department of
Environment and Natural Resources (NC DENR) removes the advisory.
1.4 Existing Data Summary
Existing data collected as part of the RI/FS activities for the Welch Creek Area are summarized
in the FS Report (RMT, 2006). Additional details regarding data collected during the RI are
included in the Final Remedial Investigation Report (RMT, 2003) and the Final Baseline Ecological
Risk Assessment (RMT, 2004). In addition, data were collected in March and May 2009 to gather
additional information for developing baseline data and information along with evaluating
monitoring techniques. These data will be incorporated into the monitoring reports.
Two reaches of Welch Creek, identified as the Upper Reach and the Midstream Reach, have
been targeted for post-RA monitoring activities. The Upper Reach (Figure 1-2) extends from
Master Transect MT-3 (immediately downstream from a CSX Transportation railroad bridge
that spans Welch Creek) downstream approximately 5,300 feet to MT-6. The Upper Reach
contains soft sediments attributed to treated wastewater effluent from the Domtar Mill. The
Midstream Reach (Figure 1-3) extends from MT-7 downstream to GT-15. Hydrologic modeling
of Welch Creek indicates that within the OU-4 limits, this portion of the creek is most
susceptible to erosion.
RGOs for the two final constituents of concern (COCs), dioxin and mercury, were addressed in
the Welch Creek ROD. For Welch Creek OU-4, the term remedial goal option (RGO) was used
to identify a dioxin concentration (as 1-TEQ) quantified in surficial sediment. The RGO was
then used to define the areas targeted for remediation in Welch Creek. The ROD selected a
clean-up goal of 1 ppb I-TEQ (within the desired range of risk protection) and consistent with
existing USEPA guidance for residential use. The USEPA also ad.dressed considerations for a
mercury RGO and determined that establishing a RGO for mercury was not appropriate at this
time due to the possibility of airborne deposition from other sources.
TRC Environmentnl Corporation I Domtar Paper Company, LLC
O&M Pinn 4
I I NT AP A-GRN\/ILLE;\CVI.-VOl.5\-\ W/'GVL IP/TI \00625\08\001 \R0062508001-003_REVISED.DOCX January 2011, Revised September 2011
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1.5 eMNR™ Thin Layer Cap Description
The ROD defined the general area requiring containment using the eMNRTM cover based upon
a clean-up criteria of 1 ug/kg dioxin (I-TEQ) in the bioactive zone of the sediment. Based on a
compilation of all investigation data to date including supplemental sampling during the
remedial design preparation, the area requiring containment was refined to extend bank to
bank from MT-3 immediately downstream of the railroad bridge (forming the upstream
boundary) to MT-6 (forming the downstream boundary). The containment area will not extend
into Little Mill Creek located near MT-5. Figure 1-2 identifies the area to be covered. The
containment area extends approximately 5,300 feet in length with an average width along this
length of approximately 125 feet bank to bank.
The cover system selected and designed for the Upper Reach of Welch Creek was developed to
address the defined manageable properties (surficial sediment concentrations and
bioavailability of COCs), accommodate the physical characteristics of the sediments in this area
of the creek, and consider the bathymetry of the creek bottom. The overall cover system
configuration consists of placement of a minimum of two lifts of sand from the top of bank on
one side, across the entire bottom and near shore submerged side slopes to the top of bank on
the other side. The first lift will be no more than 1 to 2 inches (2 to 5 centimeters) thick to avoid
destabilizing the sediment substrate. The targeted thickness of the eMNR™ cover to be placed
over exposed sediment is specified in the ROD to be 5 to 10 centimeters.
The eMNR™ cover system will consist of layers of sand that are placed to uniformly load the
underlying sediments without destabilizing the deposits, resuspending surficial sediments or
mixing with the fine grained wastewater solid deposits. The sand cover material will be placed
in two lifts. The initial lift will consist of a fine-grained sand and will target a 2 to 5 centimeter
thickness and will be placed across the bottom of the creek, which has a slope of less than 15°.
This initial lift will account for approximately 70 percent of the area being covered. The second
lift will consist of 3 to 10 centimeters of coarser sand. Placement will start in the deepest portion
for the creek channel and move toward the creek banks, eventually extending completely to the
top of the banks. When complete, the thickness of the eMNR™ cover will range from 5 to
10 centimeters, with a thicker cover along the bottom of the creek.
TRC Environmental Corporation I Domtar Paper Company, LLC
O&MP/an 5
\ \NT APA·GRNVILLE\ GVL-VOL..5\-\ WPGVL \P/Tl \00625\08\001 \R0062508001-003_REVISED.DOCX January 2011, Revised September 2011
I 0 500 1,000
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I D:\05119\40\GIS\51194009.mxd
2,000 _0
FEEW
1. WETlN() TYPE DATA FROM NORTH ~ COASTAi.
REGION EVALUATION Of WETlN() SIGNIFICANCE (NC-
CAEWS~ 19911,
DOMTAR PAPER COMPANY. LLC MARTIN COUNTY, NORTH CAROLINA
WELCH CREEK· OU-4
OPERATIONS AND MAINTENANCE PLAN
GENERAL SITE MAP
DRAWNIY ,.vuJ SCAll:
AS NOTED
()TRC
FIGURE 1·1
... ,_,.,..,,.
Nt.llitela ..
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
UPPER REACH -eMNR COVER AREA
.,. IC,U
-ASNOTII>
.. ,..__ ........ ............ ----.-.......
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
111 ZONE Of POTVITW.
sallMENT MOelfTY
/V PROPERTY BORY.
TRANSECTS
-GENERAi. TRANSECT
-MAS1£R TRANSECT
,,. D-0
OPERATIONS AND MAINTENANCE PLAN
MIDSTREAM REACH PLAN VIEW
~TRC
I'll.IMO
DOl2508001
ooat oaoo,
FIGURE 1-3
...........,0.,. .... ....,,."'*'' ... , ..... ., __ _
.I
I
I
I
I
I
I '
I
I
I
I
I
I
I
I
I
I
I
Section 2
General Operation and
Maintenance Requirements
O&M activities during the remedy construction and monitoring phases for Welch Creek Area
(OU-4) are anticipated to include:
■ O&M of sediment and erosion control features during and immediately following remedy
construction
■ Maintenance of the thin-layer cap component of the installed eMNRTh1 remedy
■ O&M of in-stream monitoring equipment during remedy construction and post-remedy
monitoring
■ Maintenance of access control features and signage during remedy construction and
post-remedy
2.1 Thin Layer Cap Maintenance
One challenge in monitoring thin layer caps is obtaining accurate determinations of cap erosion
and/or fresh sediment deposition. Several studies have indicated bathymetric profiling
instruments are not sensitive enough to confirm cap thickness (Merritt, et al., 2009), Alternative
approaches that have been used in other thin layer cap applications include sediment coring
(which is typically used in conjunction with post RA confirmation of RGOs for COC
concentrations in biologically active sediment), and installing marked stakes to confirm
sediment depth. For OU-4, cap integrity will be monitored by installing flexible stakes during
RA implementation and marking the cap:water interface after cap placement. During routine
monitoring, these stakes will be inspected to assess if either cap erosion or fresh sediment
deposition has occurred over time. In addition, cap thickness will be measured during
sediment sampling events, which are described in the PSVP that is being submitted concurrent
with this O&M plan,
As stated in Appendix B of the PSVP, sediment cap inspections via flexible stakes and
surveillance equipment will occur at 10 locations in the Upper Reach, corresponding,:o four
Master Transects (MT-3 through MT-6) and six General Transects (GT-5 through GT-10). Along
each transect, stakes will be spaced at 15 to 20 foot intervals from bank to bank, Distance
between the top of the stakes and the water surface is variable due to seasonality and flood
events, Installation will target a minimum distance of 24 inches between the top of the stakes
and the surface water interface at mean high water,
TRC Environmental Corporation I Domtar Paper Company, LLC
O&M Plan 9
\ \NT AP A ,GRNVILLE \ GVL-VOLS\-\ WPGVL \ PJTI \ 00615\08 \001 \R0062508001-003_REVISED,D0CX January 2011, Revised September 2011
I
I
'
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Cover integrity within the upper reach will be assessed by a combination of scheduled and
event-based visual inspections. During the first five years following remedy implementation,
regular inspections will be conducted annually using a camera suspended from a boat, or, if
necessary, by scuba diving. Only certified scuba diving professionals will perform underwater
inspections and/or work. Event-based inspections will be made following extreme weather
conditions, such as hurricanes or tornados, which impact the Welch Creek system with high
flows or extensive tree fall and debris.
Visual observations during each inspection will include examining the flexible stakes installed
during RA implementation to confirm that the targeted thickness (5 to 10 cm) is maintained. In
addition, the cap will be inspected for evidence of scouring, settlement, or damage. Finally,
inspections will also document deposition of leafy and woody material. Inspections will be
documented.
If needed, repairs to the cap will be performed by an appropriate method. The method to be
used will depend on the extent and location of the repair. Sand for repairs will of similar
physical properties to the sand originally placed on the cap. Upon completion, repairs will be
inspected visually either using a camera or by scuba diving. Repairs will be documented.
2.2 Sediment and Erosion Controls
As described in the Remedial Action Work Plan (RAWP; RMT, 2010), in order to install the thin
layer cap, land-based support facilities will be constructed on uplands adjacent to Welch Creek.
These support facilities include an area for sand delivery and storage, a construction trailer,
parking and a boat ramp to allow access to Welch Creek. Sediment and erosion controls
installed during these construction activities will be maintained until disturbed areas are
stabilized with permanent vegetation. Until stabilization of disturbed areas is attained,
sediment and erosion controls will be inspected regularly and following substantial rainfall
events, as required by NC DENR Division of Water, General Permit NCGOl0000.
Inspections and repairs, if needed, will be documented.
2.3 Sampling Equipment Maintenance
In order to implement mobility monitoring, automated samplers will be placed upstream of the
Upper Reach (to determine a "baseline" condition), upstream of the Midstream Reach and
downstream of the Midstream Reach. Samplers will be set up to collect from mid-depth of the
water column in the vicinity of the thalweg. The samplers will be able to be remotely controlled
to collect samples during the storm-event. Samples will be analyzed for total suspended solids
(TSS), volatile suspended solids (VSS), dioxin, and indicator elements.
TRC Environmental Corporntion I Domtar Paper Company, LLC
O&MP/an 10
\ \ NT AP A-GRN\//Ll.E\ GVl.-\/01..5\-\ WPGVL \ P/11 \ 00625 \08\ 001 \ R0062508001-00J _REVISED.DOCX January 2011, Revised September 2011
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Equipment at these sampling locations will include the following:
■ 6600EDS (or equivalent) Sonde unit configured to measure dissolved oxygen (DO),
conductivity, temperature, pH, and turbidity simultaneously;
■ Sontek Argonaut SL Current Meter to measure and record the water velocity and flow
direction;
■ ISCO Model Number 6712 or 3700 automatic sampler units (or equivalent) configured to
collect samples at mid depth of the water column; samples will be tested for VSS, TSS,
dioxin, and appropriate indicator elements (Mn, Mg, Fe, Ca, Ba, Al and Ti); and
■ Meteorological station may also need to be installed, depending upon local information
that may be available, to evaluate the wind conditions and precipitation events in order to
target sampling specific events.
All sampling equipment will be maintained according to the manufacturer's recommendations.
Equipment will be inspected during each scheduled and event-based thin layer cap inspection.
2.4 Site Access Maintenance
Since Welch Creek is accessible by fishermen, signage will be installed along both banks of the
Upper Reach notifying boaters of the thin layer cap and prohibiting the use of equipment that
could damage the cap. Proposed language on the signage is as follows:
Attention Anglers:
USEPA SEDIMENT REMEDIATION SITE
Do not disturb bottom sediments with motors, propellers, or propeller wash.
No bottom fishing No anchoring
No heavv sinkers No traos or trot lines
Signage regarding the current fish consumption advisory will also be maintained by NC DENR.
Those signs will indicate the area is subject to a bottom feeder (catfish and carp) consumption
advisory due to elevated levels of dioxin.
The fencing and other physical barriers restricting access to the Domtar property also restrict
access to OU-4 from the Domtar property. The Mill routinely inspects and repairs these barriers
as a part of the Mill's maintenance program to ensure a high level of on-site safety and to
protect its equipment. Any damage compromising the integrity of these barriers will be
repaired as soon as practicable.
TRC Environmental Corporation I Domtar Paper Company, LLC
O&M Plan 11
\ \NT APA·GRNVILLE\GVL-VOLS\-\ WPGVL \P{TI \00625\08\001 \R0062508001-003_REVTSED.DOCX January 2011, Revised September 2011
I
I
I
I
I
I
I
I
I
I
I
I.
I
I
I
I
I
Section 3
Safety Plan
Thin layer cap inspections and repairs will be done by boat. At least two people will be on
board any boat used for inspections or repairs. Before embarking, the boat operator will notify
Domtar's environmental management department, indicating the intended departure time,
nature of the work and approximate time frame for completing the task. The boat operator will
be responsible for inspecting the boat prior to departure to confirm the fitness of the craft and
that all United States Coast Guard (USCG) required safety equipment is on board and
operational. An adequate number of USCG approved personal floatation devices will be on
board the boat for all personnel.
Since inspections and repairs will not require coming in direct contact with creek sediments,
these activities can be done in Level D personal protection equipment. The health and safety
plan (HSP) for Welch Creek Area, OU-4 should be referenced for more site-specific health and
safety requirements.
All underwater activities will be conducted by certified scuba divers. At all times, a boat will be
at the surface during underwater activities to provide necessary support and warn other boaters
who may be in the area.
YRC Environmental Corporation I Domtar Paper Company, LLC
O&M Plan 12
\ \NT APA-GRNVILLE\GVI.-VOLS\-\ WPGVL \P/TI \00625\08\001 \R0062508001-003_REVISED.DOCX January 2011, Revised September 2011
I
I
I
I
I
I'
I
I
I
I
I
I
I
I
Section 4
References
RMT. 2003. Final Remedial Investigation Report, Welch Creek Operable Unit 4 (OU-4),
Weyerhaeuser Company Plymouth facility, Martin County, North Carolina. 2003.
RMT. 2004. Final Baseline Ecological Risk Assessment, Welch Creek Operable Unit 4 (OU-4),
Weyerhaeuser Company Plymouth facility, Martin County, North Carolina. 2004.
RMT. 2006. FS Report, Welch Creek Operable Unit 4 (OU-4), Weyerhaeuser Company
Plymouth facility, Martin County, North Carolina. 2006.
RMT. 2010. Remedial Action Work Plan, Welch Creek Operable Unit 4 (OU-4), Plymouth,
Martin County, North Carolina. Domtar Paper Company, LLC. November 2010.
RMT. 2010. Final Remedial Design Report, Welch Creek Operable Unit 4 (OU-4), Plymouth,
Martin County, North Carolina. Domtar Paper Company, LLC. November 2010.
USEPA. 2007. Record of Decision Welch Creek Operable Unit 4 (OU-4), Domtar Paper
Company, LLC (Domtar) facility, Martin County, North Carolina
TRC Environmental Corporation I Domtar Paper Company, LLC
O&M Plan 13
\ \NT AP A ·GRNVILLE\ GVL-VOLS \. \ WPGVL \ P/TI \ 006:25 \ 08 \ 001 \ R0062508001-003 _R F.V/SF. D. DOCX January 2011, Revised September 2011
,I
1·
••
I
l
I •
I
I
I
I
I'
I
I
I·
1.
I·
••
I'.
t
Appendix A
Maintenance and Inspection Checklist
TRC Environmental Corporation I Domtar Paper Company, LLC
O&M Pian A-1
\ \NT AP A-GRNVILLE \ GVL-VOLS \-\ WPG\ll. \ PJn \ 00625 \ OS \001 \ R0062508001--003 _REV/SW.DOCX January 2011, Revised September 2011
--...
Welch Creek OU-4 Thin Layer Cap Inspection Checklist
To be performed during routine inspections or after any storm event equal to or exceeding the 24-hour, 25-year storm
DATE INSPECTOR ITEM INSPECTED
Site Fencing:
Confirm fencing is in good
condition
Boat Ramp:
Confirm boat ramp condition
Thin Layer Cap:
Camera inspection of thin
layer cap using boat
Water Quality Sampling
Equipment -MT-3:
Water Quality Sampling
Equipment -GT-11:
Water Quality Sampling
Equipment -MT-8:
TRC Environmental Corporation I Domtar Paper Company, LLC
O&MP/an
\ \NT APA-GRNVILLE\GVL-VOL5\-\ WPGVL \PJTI \00625\08\001 \R0062508001-003_RCVISED.DOCX
CONDITION CORRECTIVE ACTION TAKEN
(only if needed)
A-2
January 2011, Revised September 2011
-