NCD980602163_20031121_Warren County PCB Landfill_SERB C_No 56 - Decontamination Sampling Plan-OCR

A:;rA
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director Division of Waste Management Michael F. Easley, Governor
Wi lliam G. Ross Jr., Secretary
November 21, 2003
Mr. Craig Brown
USEP A Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Re: Warren County PCB Landfill Detoxification Project
Sampling and Analysis Plan
Dear Mr. Brown:
Enclosed is the final version of the Sampling and Analysis Plan for the Warren County PCB Landfill
Detoxification Project prepared by our detoxification contractor, Shaw Environmental and Infrastructure. This
is the hard copy of the plan I sent to you electronically last week.
The new procedures in this revision deal primarily with post-remediation site sampling and decontamination
confirmation procedures. The plan incorporates the method for concrete pad sampling that we discussed
previously.
If there are any questions, please contact me.
Sincerely.
Patricia M. Backus, P.E.
Attachments
CC: Hiroshi A. Dodahara
Mike Kelly, DENR-DEH (Cover only)
John Funk, Earth Tech, Inc. (Cover only)
Gary Duke, Shaw Environment and Infrastructure (Cover only)
1646 Mail Service Center, Raleigh , North Carolina 27699-1646
Phone [phone] \ FAX [phone] \ Internet http://wastenotnc.org
· An Equal Opportunity / Affirmative Action Employer -Printed on Dual Purpose Recyc!ed Paper
SAMPLING AND ANALYSIS PLAN
WARREN COUNTY PCB LANDFILL DETOXIFICATION PROJECT
WARRENTON, NORTH CAROLINA
Prepared for:
North Carolina Department of Environment and Natural Resources
Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Prepared by:
Gary Duke
Project Manager
Shaw Environmental & Infrastructure, Inc.
200 Horizon Center Boulevard
Trenton, New Jersey
Revision 5
November 14, 2003
Shaw E&I Project 827062
NC SCO Project 101440101A
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SAMPLING AND ANALYSIS PLAN
TABLE OF CONTENTS
1.0 INTRODUCTION ............................................................................................................................... 1
2.0 LABORATORIES .............................................................................................................................. 1
3.0 SAMPLE COLLECTION AND ANALYSIS ....................................................................................... 1
4.0 POST-REMEDIATION SOIL SAMPLING ......................................................................................... 5
U Landfill Area ................................................................................................................................................. 5
4.2 Other Post-Remediation Soil Samoling ........................................................................................................ 5
4.2.1 Haul Road and Ran1p ............................................................................................................................ 6
4.2.2 Drainage Swale ..................................................................................................................................... 6
4.2.3 Sedin1entation Basins ............................................................................................................................ 6
4.2.4 Lined Drainage Pond ............................................................................................................................ 6
4.2.5 Unlined Drainage Pond ......................................................................................................................... 6
4.2.6 Access Road .......................................................................................................................................... 7
4.2.7 Area of Decontamination Trailer and Boot Storage Rack. .................................................................... 7
5.0 TREATED SOIL ................................................................................................................................. 7
ti Treated Soil Analysis During Performance Demonstration Test.. ................................................................ 7
5.2 Treated Soil Analysis by Shaw (all except during PD test) .......................................................................... 7
6.0 UNTREATED SOIL ANALYSES FOR DIOXIN AND FU RANS ....................................................... 7
7.0 TREATED WATER ............................................................................................................................ 8
8.0 DISPOSAL ANALYSES .................................................................................................................... 8
U Sand and Carbon ........................................................................................................................................... 8
8.2 Concrete ........................................................................................................................................................ 8
8.3 Condensed Oil ............................................................................................................................................... 8
8.4 Rinse Fluids from Equipment Decontamination ........................................................................................... 9
8.4.1 Diesel Fuel ............................................................................................................................................ 9
8.4.2 Rinse \Vater ........................................................................................................................................... 9
Ll Oversize Material .......................................................................................................................................... 9
9.0 DECONTAMINATION CONFIRMATION SAMPLING .................................................................... 10
2.J. Equipment Sampling (except Midwest Soil Remediation's Equipment).. .................................................. 10
9.2 Midwest Soil Remediation's Equipment .................................................................................................... 10
9 .3 Concrete Barriers ........................................................................................................................................ 10
9.4 Concrete Pads ............................................................................................................................................. 11
9.5 Soil Under Concrete Pads ........................................................................................................................... 12
10.0 SAMPLE NUMBERING ................................................................................................................... 12
10.1 Landfill Post-Excavation Samples .............................................................................................................. 12
10.2 Treated Soil Samples .................................................................................................................................. 12
10.3 Other Samples ............................................................................................................................................. 12
11.0 CHAIN OF CUSTODY RECORD .................................................................................................... 13
12.0 REPORTING .................................................................................................................................... 13
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SAMPLING AND ANALYSIS PLAN
LIST OF TABLES
Table 1
Table 2
Table 3
Table 4
.•.••••.••••...•••••••••...•.•••..•.•••••..•••••••••••••••••••••.••••••••••••••••••••••••••••••••• 2
.................................................................................................. 2
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.........................................................................•...........•............ 4
LIST OF FIGURES
Figure 1 .................................................................................................... 15
Figure 2 ............................................................. _ ...................................... 16
Figure 3 ................................................................................................... 17
Figure 4 ................................................................................................... 18
Figures ................................................................................................... 19
Figure 6 ................................................................................................... 20
APPENDIX
Treated Soil Batch Approval Form .............................................................. 22
Treated Soil Batch Log .............................................................................. 23
Midwest Soil Remediation Inc's TSCA Permit Application, Section 22 ............ 24
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SAMPLING AND ANALYSIS PLAN
1.0 INTRODUCTION
Shaw Environmental & Infrastructure, Inc. (Shaw E&I) has prepared this Sampling and Analysis Plan to
guide the sampling and analytical tasks required for the successful remediation of polychlorinated
biphenyl (PCB) contaminated materials at Warren County PCB Landfill, Warrenton, North Carolina.
This work is being performed under a contract with the North Carolina Department of Environment and
Natural Resources (NCDENR), Division of Waste Management.
The site consists primarily of two areas to be excavated, the landfill and the unlined drainage pond, both
of which require post-excavation sampling to confirm that the site cleanup criteria have been met. In
addition, the site includes the pre-existing leachate treatment system consisting of concrete tanks
containing sand and carbon, which must be sampled to determine disposal options.
Treatment processes performed as part of the remediation activities will create treated soil and treated
stormwater, which must be sampled to confirm that treatment criteria have been met. Other wastes that
will be created or exposed by remediation activities include condensed oil, oversize material from the
landfill, sand and carbon from the new stormwater treatment systems, and other miscellaneous debris, all
of which must be sampled to determine disposal options.
2.0 LABO RA TORIES
As required by the project specifications, all laboratories subcontracted by Shaw E&I for this project will
have current approvals from the state of North Carolina for the types of analyses they perform. Names
and qualifications of the individual laboratories are covered under separate submittals. Most analyses will
be performed by either Paradigm Analytical Laboratories of Wilmington, NC or Toxicon Corp of
Bedford, MA.
Samples associated with the Performance Demonstration Test (PD) will be sampled and analyzed in
accordance with the Quality Assurance Project Plan (QAPP) prepared by Environmental Quality
Management, Inc. (EQM) under a contract with the U.S. Environmental Protection Agency (USEPA).
This document is dated December, 2001 and was transmitted by EQM as Final, Revision 0, under a cover
letter dated December 27, 2001 to Mr. Terrence Lyons ofUSEPA with copy to Ms. Pat Backus of
NCDENR, copy subsequently provided by Shaw E&I to Earth Tech.
3.0 SAMPLE COLLECTION AND ANALYSIS
Table 1 summarizes the anticipated sample frequency for each type of sample. Table 2 summarizes the
required analyses and methods. Table 3 covers the required reporting limits for each type of analysis.
Table 4 covers sample containers, preservatives and holding times. Additional discussion for each type of
sample can be found in Sections 4 through 9.
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Sample Area
Landfill Excavation
Roads, Swales & Ponds
Soil, Treated (PCBs)
Soil, Untreated (dioxin
TEQ)
Condensed Oil, Untreated
Wipe sampling
Sample Area
Landfill Excavation
Roads, Swales & Ponds
Soil, Treated
Soil Untreated
Water, Treated
Condensed Oil, Untreated
Sand Filters
Carbon Filters
Concrete Tank
Decon rinse water
Wipe Samples
Oversize Material
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TABLE 1
ANTICIPATED SAMPLE FREQUENCY
Sample Frequency Sample Area
1 composite/ 2500 sq ft Sand Filter
1 composite/up to 10 Carbon Filter
grabs, min 1 grab/300 sq ft
1 composite / storage bin Concrete Tank
Bimonthly after PD test Water, Treated
1 grab Decon rinse water
Varies, see text Oversize material / debris
TABLE2
REQUIRED ANALYSES & METHODS
Analytes Method(s)
PCBs 8082
PCBs 8082
PCBs 8082
Dioxins/furans as TEQ 8280A/8290
PCBs 8082
PCBs &pH 8082
PCBs, BTEX, 8082, 8021,
Total TCLP Metals 6010/7471
PCBs 8082
PCBs 8082
PCBs 8082
PCBs 8082
Warren County PCB Landfill
2
Sample Frequency
1 grab / vessel
1 grab / vessel
1 composite / tank
1 grab / million gallons
1 grab
1 composite / waste stream
Anticipated Quantitv
Analytical QA/QC
50 5
25 3
250 25
4 0
10 1
1 0
7 0
7 0
2 0
1 0
40 4
1 0
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TABLE3
CONTAMINANTS OF CONCERN AND MAXIMUM ALLOW ABLE PRACTICAL
(1UANTITATION LIMITS (see note 1)
Analyte(s) Maximum Analyte(s) Maximum
Allowable Allowable
Practical Practical
Quantitation Quantitation
Limit (PQL) Limit (PQL)
PCBs -solids 0.2 mg/kg PCBs -water 0.5 ug/L
PCBs -wipe samples 10 ug/100 sq cm
Dioxins / furans TEQ 0.2 ug/kg TCLP Semivolatiles
Benzene o-Cresol 200.0mg/L
Toluene m-Cresol 200.0 mg/L
Ethylbenzene p-Cresol 200.0 mg/L
Xylenes Cresol 200.0 mg/L
TCLP Volatiles l ,4;Dichlorobenzene 7.5 mg/L
Benzene 0.5 mg/L 2,4-Dinitrotoluene 0.13 mg/L
Carbon Tetrachloride 0.5 mg/L Hexachlorobenzene 0.13 mg/L
Chlorobenzene 100.0 mg/L Hexachlorobutadiene 0.5 mg/L
Chloroform 6.0 mg/L Hexachloroethane 3.0 mg/L
1,2-Dichloroethane 0.5 mg/L Nitrobenzene 2.0 mg/L ·
1, 1-Dichloroethylene 0.7 mg/L Pentachlorophenol 100.0 mg/L
Methylethyl Ketone 200.0 mg/L Pyridine 5.0 mg/L
Tetrachloroethylene 0.7 mg/L 2,4,5-Trichlorophenol 400.0 mg/L
Trichloroethylene 0.5 mg/L 2,4,6-Trichlorophenol 2.0 mg/L
Vinyl Chloride 0.2 mg/L TCLP Metals
TCLP Herbicides/Pesticides Arsenic 5.0 mg/L
Chlordane 0.03 mg/L Barium 100.0 mg/L
2,4-D 10.0 mg/L Cadmium 1.0 mg/L
Endrin 0.02 mg/L Chromium 5.0 mg/L
Heptachlor (and its Epoxide) 0.008 mg/L Lead 5.0 mg/L
Lindane 0.4 mg/L Mercury 0.2 mg/L
Methoxychlor 10.0 mg/L Selenium 1.0 mg/L
Toxaphene 0.5 mg/L Silver 5.0 mg/L
2,4,5-TP (silvex) 1.0 mg/L
Note I to Table 3: Maximum allowable practical quantitation limits were established based on project
specifications for PCBs and dioxin TEQ or on disposal facility criteria for other parameters such as
TCLP. No limit was established for BTEX as the disposal facility requires this information to establish a
waste profile but did not preset limits. Analytical methods and laboratory capabilities will generally result
in actual PQLs below the allowable maximums.
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TABLE4
SAMPLE CONTAINERS, PRESERVATIVES AND HOLDING TIMES
Analvte(s) Method Matrix Container
250 mL Glass w/
PCBs 8082 Solid Teflon®-lined
cap
1000 mL Glass
Liquid w/ Teflon®-
lined cap
PCBs 8082 Wipes Suoolied bv lab
Dioxin/furans 125 mL Glass w/
TEQ 8290 Solid Teflon®-lined
cap
BTEX 8021 Solid 3-EnCore
samplers
125 mL Glass w/
TCLP voes 1311/8260 Solid Teflon®-lined
cap
TCLP SVOCs 1311/8270 --------------------------------
TCLP PIH (2) 1311/8081/
8151 2-500 mL Glass
--------------------------------Solid w/ Teflon®-
TCLP Metals 1311/6010/ lined cap 7470 --------------------------------Ignitability 1010
Reactivity SW846 Ch?
Corrosivity 9040
1 -days to extraction / days to analysis ( except where noted)
2 -pesticides and herbicides
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Preservative(s) Holdin2 Time (1)
4°c 14/40
4°c 7/40
4°c 7/40
4°c 30/45
4°c 14
4°c 14/14
14 until TCLP
extraction
7 until prep
extraction
___ 40_ until analysis ___ 4° C 6 mo 16 mo
... -~~~~~!Y. ?.~ !.?? ....
ASAP
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
4.0 POST-REMEDIATION SOIL SAMPLING
This section covers soil samples that will be taken to verify that the target cleanup levels for the site have
been met.
4.1 Landfill Area
Materials to be excavated from the landfill for treatment or disposal include the cap liner, a portion of the
overlying fill material, the PCB contaminated material, the underlying filter fabric and sand layer and the
top 6" of the 60" underlying clay layer. As this excavation progresses the remaining underlying clay layer
will be divided into grids as shown in Figure 1.
The 50 foot by 50 foot excavation grids are shown in Figure 1. The contaminated area footprint is 420 ft
by 176 ft. The grid area measures 450 ft by 200 ft, thus allowing for possible expansion due to post-
excavation sampling.
Within each grid, nine (9) grab samples, well distributed over the grid, will be collected from a depth of
zero to three (0 -3) inches. The sampler will determine the exact location of each sample, although
samples will be collected from stained areas, if present. Soil samples will be collected using chemically
inert, disposable sample scoops. The same scoop may be used for all grab samples making a single
composite sample. Soil from each grab sample location will be placed in a decontaminated stainless steel
mixing bowl for mixing after all grab samples in a grid are collected, to create a composite sample for
analysis. The sample jar will be filled with the composited soil for laboratory analysis. One in ten
composite samples will be submitted in duplicate.
The location of each grab sample that makes up a composite will be marked by a stake. If the composite
sample results are below the USEPA Toxic Substances Control Act (TSCA) high-occupancy cleanup
level of 1.0 mg/kg (ppm) total PCBs, then the location and elevation of these stakes will be surveyed
before the area is backfilled so that a permanent record of the location of the final verification samples
can be maintained.
If any post-excavation grid sample result is greater than or equal to 1.0 mg/kg (ppm) total PCBs then
excavation will continue in 6 inch cuts until the sample concentration is less than 1.0 mg/kg (ppm) total
PCBs.
4.2 Other Post-Remediation Soil Sampling
Figure 2 shows locations other than the landfill where Shaw E&I will perform post-remediation soil
sampling to confirm that the target cleanup level for PCBs has been met. Generally applicable procedures
are described below, followed by a subsection on each type of location.
Within each location, a number of grab samples will be collected from a depth of zero to three (0 -3)
inches. At least one grab sample will be taken for each 300 square feet of area in that location, up to a
maximum of 10 grab samples per location. Each number in Figure 2 (e.g., 4C) represents a composite
PCB sample.
The sampler will determine the exact location of each grab sample, although samples will be collected
from stained areas, if present. Soil samples will be collected using chemically inert, disposable sample
scoops. The same scoop may be used for all grab samples making a single composite sample. Soil from
each grab sample location will be placed in a decontaminated stainless steel mixing bowl for mixing after
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all grab samples in ~n area are collected, to create a composite sample for analysis. The sample jar will be
filled with the composited soil for laboratory analysis.
The location of each grab sample that makes up a composite will be marked by a stake. If the composite
sample results are below the USEP A TSCA high-occupancy cleanup level of 1.0 mg/kg (ppm) total
PCBs, then the location and elevation of these stakes will be surveyed before the area is backfilled so that
a permanent record of the location of the final verification samples can be maintained.
If any post-remediation area sample result is greater than or equal to 1.0 mg/kg (ppm) total PCBs then the
area will be further excavated and resampled until the sample concentration is less than 1.0 mg/kg (ppm)
total PCBs. If the results are > 1 ppm but < 50 ppm the excavated material will be disposed of at a subtitle
D landfill operated by Waste Management in Kernersville, NC. If the results are >50 ppm the material
will be disposed of at the TSCA permitted subtitle C landfill operated by Waste Management in Emelle,
AL.
4.2.1 Haul Road and Ramp
The haul road and ramp are shown in Figure 2 as locations 1 A through 4A. These areas are used by trucks
hauling contaminated soil from the landfill to the treatment area and will likely become contaminated by
dirt on the truck tires. As excavation of the landfill progresses and these areas are no longer required, each
will be cleaned in sequence. Visibly contaminated material will be removed for onsite thermal treatment
and the underlying soil sampled. Final sample locations will be surveyed.
4.2.2 Drainage Swale
A drainage swale that could become contaminated due to its proximity to the haul road and treatment
areas is shown on Figure 2 as locations lB to 6B. After the haul road and concrete pads have been
cleaned , to preclude the possibility of recontamination, the soil in these areas will be sampled. Final
sample locations will be surveyed.
4.2.3 Sedimentation Basins
Two sedimentation basins that serve the site are shown on Figure 2 as locations 7B and 8B. After the
drainage swale discussed in subsection 4.2.2 is confirmed clean, these basins will be mucked out and the
underlying material sampled. Previous sampling of these basins on several occasions throughout the
course of the project has shown the material in them to be <5 ppm. No changes in site operations have
occurred since those sampling events that would have allowed more highly contaminated soil to reach
these basins, rather removal of the stockpile of contaminated cap material has removed the source of even
the low levels of contamination previously found in the basins. Based on that information the material
removed from them will be disposed of at a subtitle D landfill operated by Waste Management in
Kernersville, NC. Final sample locations will be surveyed.
4.2.4 Lined Drainage Pond
The area of the lined drainage pond is shown on Figure 2 as locations 1 C to 4C. After this pond is no
longer needed the liner will be removed and disposed of at the TSCA permitted subtitle C landfill
operated by Waste Management in Emelle, AL. The underlying material will then be sampled. Final
sample locations will be surveyed.
4.2.S Unlined Drainage ·Pond
The area of the unlined drainage pond is shown on Figure 2 as locations 5C to 8C. After this pond is no
longer needed the soil in this area will be sampled. Final sample locations will be surveyed.
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4.2.6 Access Road
The area of the access road is shown on Figure 2 as location 9C. After this road is no longer needed the
soil in these areas will be sampled. Final sample locations will be surveyed. Excavated areas will be
refilled with crushed stone as needed to maintain the road grade.
4.2. 7 Area of Decontamination Trailer and Boot Storage Rack
The area of the decontamination trailer and boot storage rack is shown on Figure 2 as location 1 0C. After
these facilities are removed any the soil in this area will be sampled. Final sample locations will be
surveyed. Excavated areas will be refilled with crushed stone as needed to maintain proper drainage.
5.0 TREATED SOIL
5.1 Treated Soil Analysis During Performance Demonstration Test
Treated soils will be sampled and analyzed during the Performance Demonstration Test in accordance
with the QAPP prepared by Environmental Quality Management, Inc. (EQM) under a contract with the
USEPA. This document is dated December, 2001 and was transmitted by EQM as Final, Revision 0,
under a cover letter dated December 27, 2001 to Mr. Terrence Lyons ofUSEPA with copy to Ms. Pat
Backus of NCDENR, copy subsequently provided by Shaw E&I to Earth Tech.
5.2 Treated Soil Analysis by Shaw (all except during PD test)
Verification sampling of thermally treated soil will be performed by taking one grab sample per operating
hour from the surface of an active face of the treated soil stockpile ( an area where the discharge conveyor
is dropping fresh material as the sample is being taken). Each hourly grab sample will immediately be
placed in a stainless steel mixing bowl. The bowl will be covered between samplings. Sampling will
continue until the bin is full, at which point the soil in the bowl will be mixed thoroughly to create a
composite sample for laboratory analysis.
In order for treated soil to be considered as treated in accordance with the contract performance standards
the analytical results for any batch must not exceed 0.5 ppm (500 ppb) PCBs. In addition, accepting it
must not raise the weighted average for all accepted batches above 0.2 ppm (200 ppb) PCBs. Batches
which are reported as non-detect (ND) or below quantitation limits (BQL) will be recorded as containing
PCBs at a value equal to half of the highest quantitation limit for any congener. A sample form for
recording this information and approvals by Shaw and Earth Tech is included in the Appendix at the end
of this document.
6.0 UNTREATED SOIL ANALYSES FOR DIOXIN AND FURANS
Untreated soils will also ·be analyzed periodically for dioxins and furans (reported as TCDD TEQ), in
addition to the dioxin testing done as part of the Performance Demonstration (PD) Test. This will serve
to confirm historical data as well as the results of the PD test as to the low levels of dioxin in the untreated
soil.
Since the PD test confirmed previous results from similar thermal treatment units showing that they do
not create dioxin and that the dioxin removal efficiency is well in excess of 90% it can be inferred that if
the untreated soil contains dioxin at levels below 2.0 ug/kg (ppb) TEQ then the untreated soils will be
below the project standard of 0.2 ug/kg (ppb) TEQ. The reason for sampling untreated soils is that it is
more likely that dioxins will be found at quantifiable levels in the untreated soil.
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These periodic samples will be taken bimonthly, beginning 2 months after the full 3 run PD test. The
samples will be taken as a composite of five single point grab samples taken from the stockpile of
screened untreated soil stored under the pole barn.
7.0 TREATED WATER
One (1) grab sample will be collected for every one million gallons of storrnwater treated on-site. The
sample will be collected from the sample port on the discharge side of the trailing treatment unit. Water
will be allowed to flow through the port for a minute prior to sampling, to ensure that stagnant water will
not be sampled. The purge water will be collected and placed with the untreated water. The samples will
be analyzed for PCBs by Method 8082.
8.0 DISPOSAL ANALYSES
Anticipated materials for disposal include sand and carbon from both preexisting and new water filtration
systems, concrete tanks for the preexisting filters, condensed oil, rinse fluids from equipment
decontamination and oversize material and debris from the remedial action. Sampling and analytical
requirements for each waste stream are described below. The analytical parameters were selected based
on the requirements of the disposal facilities selected for use on this project.
8.1 Sand and Carbon
Sand and carbon samples will be collected from the top three (3) inches of the respective pre-existing
leachate collection system filters. Since leachate was fed to the top of these sand and carbon beds
sampling of only the top 3" is intended to produce a conservative result. Most of the sampling will be
done using chemically inert, disposable sample scoops. These samples will be grab samples, and will be
collected for PCBs (Method 8082), and RCRA metals (Methods 6010B & 7471A). Additional samples
will be taken for benzene, toluene, ethylbenzene and the xylene isomers (BTEX, Method 8021B), these
samples will each be taken using 3 EnCore samplers.
Sand and carbon from the new storrnwater treatment system will be sampled as replaced, or at the end of
the job, whichever comes first. Again, the top 3" will be sampled using chemically inert, disposable
sample scoops, but in this case each sample will be taken as a 5 point composite that will then be
analyzed only for PCBs (Method 8082).
8.2 Concrete
Concrete tanks exist that housed the pre-existing filters. The inside of each tank will be sampled by
chipping the concrete and placing it in a sample container for PCB analysis (Method 8082). The chisel
will be decontaminated before sampling each tank.
8.3 Condensed Oil
Condensed oil was sampled and analyzed during the PD test in accordance with the QAPP prepared by
Environmental Quality Management, Inc. (EQM) under a contract with the USEP A. This document is
dated December, 2001 and was transmitted by EQM as Final, Revision 0, under a cover letter dated
December 27, 2001 to Mr. Terrence Lyons ofUSEPA with copy to Ms. Pat Backus ofNCDENR, copy
subsequently provided by Shaw E&I to Earth Tech.
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The results from the PD test will be used to prepare a waste profile for the disposal facility. After at least
80% of the soil has been treated the condensate storage tank will be mixed and a grab sample taken and
submitted to the disposal facility for confirmation that the accumulated oil matches the profile.
8.4 Rinse Fluids from Equipment Decontamination
It is anticipated that equipment and facility decontamination activities will generate two types of rinse
fluids. Each are addressed below.
8.4.1 Diesel Fuel
Diesel fuel will be used as the rinse fluid for much of the liquid and gas treatment sections of the thermal
treatment plant, and may be used in some other highly contaminated areas if necessary. Used diesel fuel,
which is not expected to exceed a maximum quantity of 2,000 gallons, will be assumed to be PCB
contaminated and will be combined with the condensed oil for shipment to an offsite TSCA permitted
incinerator located in Port Arthur, Texas. The quantity of condensed oil will be measured for payment
purposes under the contract prior to the addition of any diesel fuel to the condensed oil storage tanks.
Sampling of condensed oil is addressed in Section 8.3 of this ·plan. If requested by the disposal facility, a
composite sample may be taken from the onsite condensate storage tanks after the addition of the diesel
rinsate to confirm such parameters as may be requested by the facility. As of this writing, they have
indicated that they do not intend to request any additional sampling or analyses, as the characteristics of
the diesel fuel are expected to be well within the acceptance criteria for the condensed oil waste p~ofile.
8.4.2 Rinse Water
Decontamination activities will also generate rinse water containing small amounts of surfactant. It is also
anticipated that this water will be contaminated with PCBs at levels which will require it to be disposed
of at the same off site TSCA permitted incinerator as the condensed oil and diesel fuel. For the most part,
rinse water will be accumulated in a tank truck during decontamination activities, although in some cases
small amounts may be accumulated in drums for later transfer to the tank truck. One grab sample will be
taken from the tank truck and analyzed for PCBs. If, as expected, the PCB levels are such as to require
off site incineration then representatives of the disposal facility have stated to Shaw E&I that no further
analyses would be required prior to shipment.
8.5 Oversize Material
PCB contaminated soils at this site will be treated by a thermal desorption process. To prevent damage to
components of that system, soils will first be screened to remove objects with a nominal size of >2". It is
expected that the vast majority of these screened materials will consist of rock, which will be disposed of
at an appropriate offsite disposal facility as described below. ·
To characterize for disposal, select 4 rocks that appear to be representative of all of the oversize rocks in
terms of size, surface texture and degree of dirt still adhering to them, if any. Use a hammer to break each
rock so as to separate off at least 2 pieces of each rock. Select two pieces from each rock, each piece
must have at least one face that was part of the exposed exterior of the original rock. Use the hammer to
further crush each of the selected pieces into fragments no larger than 1/8 inch and place the fragments in
a 4-ounce sample jar. Send sample to Paradigm Analytical Laboratories, Inc, Wilmington, NC for
analysis for PCBs; they will further crush the sample pieces prior to extraction.
A sample of oversize material will be analyzed for PCBs. If the results are> 1 ppm but< 50 ppm the
material will be disposed of at a subtitle D landfill operated by Waste Management in Kern~rsville, NC. If
the results are >50 ppm the material will be disposed of at the TSCA permitted subtitle C landfill operated
by Waste Management in Emelle, AL.
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9.0 DECONTAMINATION CONFIRMATION SAMPLING
This section addresses the sampling to be performed after the conclusion of onsite treatment operations to
confirm that equipment and facilities used during the project are decontaminated. For wipe samples, the
relevant regulatory limits are:
Per 40 CFR 761.61 (a)(4)(ii)-Non-porous surface wipe sample limits:
For high occupancy areas (without dermal or respiratory protection for >840 hrs/year (average of 16.8
hours/week) -~ 10 µg / 100 cm2
For low occupancy areas (without dermal or respiratory protection for <840 hrs/year (average of 16.8
hours/week) -~ 100 µg / 100 cm 2
Per 40 CFR 761.79 (b)(4) -Porous surface wipe sample limits are~ 10 µg / 100 cm2
9.1 Equipment Sampling (except Midwest Soil Remediation's Equipment)
Each piece of mobile equipment such as excavators, trucks, loaders, etc. will be wipe sampled in at least 2
locations. Equipment will be clean of visible soil and other deleterious materials prior to sampling. One
sample will be taken from the interior of the operator's cab. A second sample will be taken from a point
on the exterior of the machine. Results for both samples will be compared to the high occupancy area
criteria of~ 10 µg / 100 cm2•
Wipe sampling will also be performed on at least one exterior location of each major piece of static
equipment such as water treatment plant tanks and compared to the low occupancy area criteria.
9.2 Midwest Soil Remediation's Equipment
Equipment that makes up the thermal treatment plant owned and operated at this project site by Midwest
Soil Remediation, Inc. (MSR) is covered by their application for a nationwide TSCA permit for that unit.
The decontamination and demobilization of that unit is covered by section 22.3 "Demobilization
Procedures (Temporary Closures) of that application; a copy of that section is appended at the end of this
plan. By letter dated March 30, 2003 the National Program Chemicals Division (NPCD) of the USEPA
authorized MSR to continue operations at the Warren County PCB Landfill site until NPCD issues the
nationwide PCB disposal approval. Based on previous experience with similar permits issued by NPCD it
is anticipated that the decontamination and demobilization of the unit from the Warren County site will be
performed under this interim approval.
MSR's decontamination activities, like Shaw E&I's, will generate diesel fuel and rinse water, which will
be combined with those generated by Shaw E&I's activities and sampled as described in section 8.4 of
this plan.
While the TSCA permit application for this unit does not require confirmatory wipe sampling as part of
temporary closure it is anticipated that MSR may elect to perform wipe sampling on a limited basis for
internal purposes.
9.3 Concrete Barriers
Any portable concrete barriers (aka Jersey barriers) which may be selected for reuse at the end of the
project will be wipe sampled (standard wipe test as defined in 40 CFR 761.123) at a minimum frequency
of 1 sample for every 10 barriers (each barrier has a surface area of approximately 75 sq. ft.). Barriers
that were used in feed soil areas and barriers that were used in treated soil or other "clean" areas will be
grouped separately for sampling to avoid any potential for "dilution" effects. Prior to sampling, the
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barriers will initially be washed using a pressure washer to remove soil and other visible contamination.
Barriers will be considered suitable for unrestricted reuse if the wipe sample results meet the~ 10 µg /
100 cm2 criteria which applies to both porous surfaces and to non-porous surfaces in high occupancy
areas.
Barriers which cannot be decontaminated to this standard or which for any other reason are not to be
reused will be considered as debris for offsite disposal and sampled accordingly.
9.4 Concrete Pads
It is anticipated that the four concrete pads used during the project for soil storage and treatment units will
still be in good condition at the end of the project, and if so are scheduled to be left on site for potential
future use. These pads were constructed to the standards required for TSCA secondary containment areas.
All are 6" thick reinforced concrete which used a minimum 4,000 psi concrete mix, which was verified
during construction using numerous concrete break tests which were reviewed by the state's independent
third party oversight contractor. All of the pads received at least one coat of concrete sealant. Pad 3,
where the thermal treatment plant is located, was considered potentially more likely to be subjected to a
spill of condensed oil with high concentrations of PCBs, so it received additional coats of a high grade
epoxy sealant to resist this.
The decontamination and sampling methods described below were discussed in a September I 0, 2003
telephone conversation with Mr. Craig Brown ofUSEPA Region IV by Ms. Patricia Backus ofNCDENR
and Mr. Gary Duke of Shaw E&I.
The pads will initially be washed using a pressure washer to remove soil and other visible contamination.
Based on a trial run of this method conducted on August 23, 2003 it appears possible that this will be all
that is necessary. In that test a wipe sample taken after washing from the relatively heavily contaminated
pad #1 was reported as 2.6 µg / 100 cm2 and a sample taken from the lightly contaminated pad #4 was
reported as below quantitation limits, with a reported quantitation limit of 1.0 µg / 100 cm2 • Both results
are well below the~ 10 µg / 100 cm2 criteria which applies to both porous surfaces and to non-porous
surfaces in high occupancy areas.
For sampling, each pad has been divided into a number of sections as shown in Figures 3 through 6,
which are located at the end of this document. As shown, each section is then further subdivided into 9
grids. During the discussion with Mr. Brown it was tentatively agreed that each grid could be up to 15 ft
by 15 ft square, which would result in a surface area of 225 sq ft per grid and 2,025 sq ft per 9 grid
section. As shown in the figures, the actual dimensions of the sections and grids have been modified to
adjust to the actual overall dimensions of each pad. In doing so, the adjustments were made in such a way
that the surface area of each grid and section is no greater than the areas that were discussed; detailed
dimensions and surface area calculations are shown on each figure.
Following the initial wash, each section will be wipe sampled (standard wipe test as defined in 40 CFR
761.123). The actual grid to be sampled within each section will be randomly selected. As can be seen
from the figures, this will result in a total number of samples as shown below:
Pad I = 5 samples, Pad 2 = 6 samples, Pad 3 = IO samples, Pad 4 = IO samples, Total = 31 samples
If any section of a pad fails to met the decontamination criteria described below that section may be
recleaned using the same method as the initial wash or by more aggressive methods such as solvent wash
or scarification. That section will then be resampled.
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Each concrete pad will be considered suitable for unrestricted reuse if the final wipe sample results for all
of the sections of that pad meet the~ 10 µg / 100 cm2 criteria which applies to both porous surfaces and
to non-porous surfaces in high occupancy areas.
Any of the four pads which cannot be economically decontaminated using the procedures and criteria
described above will be demolished .. In the unlikely event that this occurs, bulk samples of the concrete
will be collected prior to demolition to assess off-site disposal requirements. If the results are > I ppm
but< 50 ppm PCBs the material will be disposed of at a subtitle D landfill operated by Waste
Management in Kernersville, NC. If the results are >50 ppm PCBs the material will be disposed of at the
TSCA permitted subtitle C landfill operated by Waste Management in Emelle, AL.
9.5 Soil Under Concrete Pads
The concrete pads will be inspected by representatives of Shaw E&I and the oversight contractor, Earth
Tech, for cracks which could potentially have allowed PCB contaminated materials to penetrate the pad
and contaminate the underlying soil. If such cracks are found a concrete core drill will be used to drill a
hole at the approximate center of the crack. The underlying soil will then be sampled_ to a depth of 0 -6"
using an auger and the sample will be analyzed for PCBs. If the results are <1.0 ppm PCBs then no
further action will be required. ·
10.0 SAMPLE NUMBERING
10.1 Landfill Post-Excavation Samples
Landfill post-excavation samples will be numbered using the format WCLF-LF-GG-N-O where:
LF designates landfill post-excavation sample
GG letter and number designating grid location per map included as Figure I
N number designating excavation sequence represented by sample, use 0 for bottom of
initial excavation, 1 for after first reexcavation, etc.
0 optional identifier, used to differentiate samples if required, example would be the use of
D to designate a duplicate sample
10.2 Treated Soil Samples
Treated soil samples will be numbered using the format WCLF-ST-L-NNN-O where:
ST designates soil (treated) sample
L number designating treated soil bin that sample represents
NNN sequential batch number
0 optional identifier, used to differentiate samples ifrequired, example could be the use of
D to designate a duplicate sample
10.3 Other Samples
All other samples will be given a unique number in order to identify the location the sample was collected
from, as shown below:
Shaw Project 827062SAP-Rev 5
WCLF -LL -NNN-0
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
where: WCLF-Warren County Landfill
LL -Location of Sample Area
• DP -Drainage Pond
• DS -Disposal (sand, carbon, concrete, PPE, oversize material, debris, wipe
samples, post-remediation soil samples per section 4.2)
• SU -Soil, untreated (primarily for dioxin analyses per section 6.0)
• WT-Water, Treated
NNN -Consecutive sample number beginning at 00 I
0 -Optional identifier, used to differentiate samples if required, example could be the use
of D to designate a duplicate sample.
• For wipe samples from concrete pads per Section 9.4 the O suffix shall be a 3
digit identifier in the form 1-5-3, where the first digit identifies the pad, the
second identifies the section, and the third identifies the grid, see Figures 3
through 6 for locations.
• For post-remediation soil samples taken per Section 4.2 the O suffix shall be
in the form 2A, designating the sample location as shown on Figure 2.
11.0 CHAIN OF CUSTODY RECORD
Documentation of sample custody following collection is accomplished using a standard
Chain-of-Custody Record. This document traces possession of every sample from the time of collection
through sample analysis.
In general, chain of custody protocols follow those outlined in USEPA guidelines. This documentation
begins immediately following sample collection and proper labeling. The chain-of-custody record
provides information on the sealing of samples, the sample number, sample description, date and time of
collection, number of containers for the sample, type of analysis requested, and any pertinent remarks are
entered onto the chain of custody record form. The chain-of-custody record form also documents the
condition of sample containers upon their receipt from the support laboratory. This form is completed
using indelible black ink.
12.0 REPORTING
At a minimum, data reports to NCDENR and their oversight contractor, Earth Tech, will include
analytical results for the samples and any duplicates or field/ laboratory blanks. Reports covering post-
remediation soil samples and treated soil samples analyzed for PCBs will also include the percentage
moisture of the sample and the surrogate spike recovery percentage.
A sample form for recording analytical and other information for each batch of treated soil and approvals
for the batch by Shaw and Earth Tech is included in the Appendix at the end of this document.
Analytical results will be compared to the applicable site clean-up or treatment criteria for PCBs, or the
appropriate disposal guidelines.
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Copies of all analytical reports will be provided to NCDENR at the end of the project for inclusion in the
final report.
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Shaw Project 827062SAP-Rev 5
FIGURES
Warren County PCB Landfill
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SAMPLING AND ANALYSIS PLAN
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Figure 1
-----~ ----------•---~ a a
D
C
B , __ _
A
1 2 3 4 5 6 7 8
The 50 foot by 50 foot excavation grids are shown above. The contaminated area footprint
is 420 ft by 176 ft. The grid area measures 450 ft by 200 ft.
Figure l -landfill post-excavation sampling grid
Shaw Project 827062SAP-Rev 5 Warren County PCB Landfill
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
•
Figure 2
·---
_/
a
-·······.·~---."'I
\ \
TI N G LANDFI L.L \
lC
3C 4C
I r;;;; .A _·· SAMPLES TAKEN BEFORE THE END OF PROCESS ING / u I B -SAMPLES TAKEN AFTER MSR DEMOB c________j C -SAMPLES TAKEN AFTER PAD CLEANING
Figure 2. Location of post-remediation soil samples
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Figure 3
Pad 1 Sampling Areas
Pad 1 measures 115 ft by 79'-9" with an area of9,171 ft2• To separate the pad into sampling sections of2025 ft2
each ( an area equal to a 45' x 45' section) would require 9, 171/2,025 = 4.53 sections. Use 5 sections. Each section
will have an area of9,171/5 = 1834.2 ft2. Pad 1 will be divided into 5 equal area sections as shown below. The
figure below also shows how each of the 5 sections will be broken into 9 sampling grids.
r-----79'-9"-----,
38[.
L SECTION SECTION
1-1 1-4
1
4
7
2 3
5 6
8 9 d--9" _J
J.
j SAMPLING GRIDS IN SECTIONS
115' SECTION 1-1 THROUGH 1-3
1-2
SECTION
r710'-7.7"
SECTION 1-5 1 2 3 1-3
4 5 6
L_47' -1 o•--,____3, • -11 ._J
7 8 9
PAD 1
9,171 SF SAMPLING GRIDS IN SECTIONS
Figure 3. Pad 1 Sampling Sections and Grids
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1-4 AND 1-5
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Fig 4
Pad 2 Sampling Areas
Pad 2 measures 115 ft by 100' with an area of 11 ,500 fr. To separate the pad into sampling sections of
2025 ft2 each (an area equal to a 45' x 45 ' section) would require 11 ,500 /2,025 = 5.68 sections. Use 6
sections. Each section will have an area of 11,500 /6 = 1,916.67 ft2• Pad 2 will be divided into 6 equal
area sections as shown below. The figure below also shows how each of the 6 sections will be broken
into 9 sampling grids .
115'
.---------100·------,
r---so·
SECTION
2-1
SECTION
2-2
SECTION
2-3
:o·~
SECTION
2-4
SECTION
2-5
SECTION
PAD 2
11,500 SF
2-6
)4.
1 ..
1 ..
J
Figure 4. Pad 2 Sampling Sections and Grids
1 2 3
4 5 6
7 8 9
SAMPLING GRIDS IN SECTIONS
2-1 THROUGH 2-6
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Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Figure 5
Pad 3 Sampling Areas
Pad 3 measures 129 ft by 144'-3" with an area of 18,608.25 fr. To separate the pad into sampling
sections of 2025 ft2 each (an area equal to a 45' x 45' section) would require I 8,608.25/2,025 = 9.19
sections. Use 10 sections. Each section will have an area of 18,608.25/10 = 1,860.82 ft2• Pad 3 will be
divided into 10 equal area sections as shown below. The figure below also shows how each of the 10
sections will be broken into 9 sampling grids .
.-----------144'-3"-------~
z z 0 0 i: ":' UM i: I? UM w w II) II)
129'
z z 0 0 i: <':I UM
i: .,
UM w w II) II)
z 0 i: u;, UM w II)
z 0 i: ~ UM w II)
PAD 3
18,608.25 SF
z z 0 0 i: ":' i: ~ UM UM
7 ..
w w II) II)
z z 0 Oo i= op i: .... UM frl cJi w II) II)
Figure 5. Pad 3 Sampling Sections and Grids
Shaw Project 827062SAP-Rev 5 Warren County PCB Landfill
20
1 2s·-1o·l
r-,9'-7.4"
1 2 3
4 5 6
7 8 9
SAMPLING GRIDS IN SECTIONS
3-1 THROUGH 3-10
November 14, 2003
ShQ ..
Shaw Environmental & Infrastructure, Inc. SAMPLING AND ANALYSIS PLAN
Figure 6
Pad 4 Sampling Areas
Pad 4 measures 168 ft by 140'-8" with a 40 ft by 40 ft extension on one comer. The area is 25,232 ft2.
To separate the pad into sampling sections of 2025 ft2 each (an area equal to a 45 ' x 45' section) would
require 25,232 /2,025 = 12.46 sections. Use 13 sections. One section will be the 40 ft by 40 ft extension
with an area of 1600 ft2• The remaining area will be divided into 12 sections with an area of (25 ,232-
1600) /12 = 1.969.33 ft2 each. The figure below shows how each of the 13 sections will be broken into 9
sampling grids.
168'
-------140'-B'------~
,--46' -10.67"--i
SECTION
4-1
SECTION
4-2
SECTION
4-3
SECTION
4-4
SECTION
4-5
SECTION
4-6
SECTION
4-7
SECTION
4-8
PAD 4
25,232 SF
SECTION
4-9
SECTION
4-10
SECTION
4-11
SECTION
4-12
J
I
----40' ~
SECTION
4-13
l.
J
Figure 6. Pad 4 Sampling Sections and Grids
Shaw Project 827062SAP-Rev 5 Warren County PCB Landfill
21
r---45• -1 o.67" 1
r-715'-7.6'
1 2 3
4 5 6
7 8 9
SAMPLING GRIDS IN SECTIONS
4-1 THROUGH 4-12
1 2 3
4 5 6
7 8 9
SAMPLING GRIDS IN SECTION
4-13
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Shaw Project 827062SAP-Rev 5
APPENDIX
Warren County PCB Landfill
22
SAMPLING AND ANALYSIS PLAN
November 14, 2003
Warren County PCB Landfill Detoxification Project NC SCO Project ID#010440101A
( Shaw E&I Project #827062
Treated Soil Batch Weight and Treatment Certification Form
Sequential Batch #: Treated soil bin location #:
Treated tonnage information
Date batch completed: Time completed: Belt Scale reading : tons
Date batch started: Time started: Belt Scale reading : tons
Residuals Recycled tons
Reject material placed into bin# Total Reject Mt'I tons
Calculated net tons for this batch: 0
Sampling and confirmation analysis information
Note, sample ID# format is WCLF-ST-LL-NNN, where:
Shaw sample ID#: ST=soil treatment, LL = location (bin number for treated soil),
NNN=sequential batch #, X=optional extra identifier
for example, could use X=2 to designate a duplicate sample
Name of lab performing analysis:
Laboratory report #: Report Date: Attach copy of report to this sheet
Analytical results: mg/kg (ppm) PCBs Note: 1 mg/kg = 1,000 ug/kg
1 ppm = 1,000 ppb
ug/kg (ppb) PCBs
Acceptance criteria: to be considered as treated in accordance with the contract performance standards
the analytical results for the batch must not exceed 0.5 ppm (500 ppb) PCBs AND
accepting it must not raise the weighted average for all accepted soils above 0.2 ppm
(200 ppb) PCBs. Any batch that does not meet both criteria must be reprocessed.
Approval information and signatures
Based on the analytical information provided above, this batch should be considered:
I I Acceptable, can be transferred to clean stockpile or backfilled.
I I Acceptable, but contractor chooses to reprocess.
I I Unacceptable, must be returned to pad #1 for reprocessing.
for Shaw Environmental, Inc. (prime contractor):
Print name:
Date:
Signature:
for Earth Tech ( owner's representative):
Print name:
Date: -
Signature:
file name for blank form: batch form 100802.xls
(. Warren County PCB Landfill Detoxification Project NC SCO Projecl I0#010440101A Shaw prujecl #827062 Treated Soll Batch Waight and Treatment Certification Log A B C D E F G H I J K L M N 0 p a R s T u V w Results of PCB analysis approved Weighted Balch# Bin# Date Time Date Time Bell scale Belt scale Bell Residuals Net tons Shaw Name of Lab Lab (mg/kg=ppm) Approved, Rejected, Total Ions Total tons batch Running Avg PCB complete complete start start complete start scale recycled for batch sample# lab report# report or0.5 of BQL can be must be approved rejected tons•PCB Total of =V/S (tons) (tons) net tons (Ions) date must be <0.5 backfilled retreated =K•P col U must be <0.2 1 1 08/24/02 20:15 08/23/02 16:45 354.22 30.61 323 61 1.75 321.86 01-001 Toxikon 0208307-01A 08/24102 1.1 1 321.86 0.0000 0.0000 #OIV/0! 2 2 06127102 18:30 08124/02 20:15 780.39 354.22 426.17 15.75 41042 02-002 Toxikon 208306 08/29/02 0.91 1 732.28 0.0000 0.0000 #DIV/0! 3 3 08129/02 20:12 08127/02 18:30 1,182.98 780.39 402.59 5 30 397.29 03-0030 Toxikon 209086 09/11/02 6 1 1,129.57 0.0000 0.0000 #DIV/0I 4 4 08/30/02 4:05 08129/02 20:12 1,269.07 1,182.98 86.09 1.80 84.29 04-004 Toxikon 209087 09/11/02 0.0285 1 84.29 1 12957 2.4023 2.4023 0.029 5 1/6 07/09/02 18:30 09/06/02 16:27 1,538.22 1,276 72 261 50 8.58 252 92 06-008 Paradiam 52679 09/17/02 0.98 1 84.29 1 382.49 0.0000 2.4023 0.029 6 2 This was small amount of material returned lo lhe pole barn 01-006 Toxikon 020987-03A 09/11/02 3.2 1 84.29 1,382.49 0.0000 2.4023 0.029 7 2 09/12/02 11:16 109/11/02113:23 1,904.07 1 544.99 35908 5.93 35315 02-007 Paradiam 52519 09/13/02 0.55 1 84.29 1,735.64 0.0000 2.4023 0.029 8 Batch 8 was created when batch 5 was moved from bin 1 to bin 6 -Results are shown under batch 5 84.29 1,735.64 0.0000 2.4023 0.029 9 4 09/13/02 18:57 09/12/02 11:16 2,403.90 1,904.07 499 83 23.04 476.79 04-009 Paradiam 52680 09/17/02 0.17 1 561.08 1 735.64 81.0543 83.4566 0.149 10 3 09/14/02 12:18 09/13/02 19:10 2,652.76 2,403.90 248.86 8.25 240.61 03-010 Paradiqm 52681 09/17/02 0.19 1 801.69 1,735.64 45.7159 129.1725 0.161 11 3 09124/02 14:04 09/23/02 20:30 2,894.67 2 652.76 241.91 955 232.36 03-011 Paradiam 53245 09125102 0.18 1 1 034.05 1 735.64 41.8255 170.9980 0.165 12 2 09125102 14:06 09124/02 14:04 3232.12 2,894.67 337.45 12.60 324.85 02-012 Paradiqm 53346 09/26/02 0.1 1 1,358.90 1,735.64 32.4850 203.4830 0.150 13 1 09126/02 5:42 09125102 14:06 3,476.49 3,232.12 244.37 23.00 221 37 01-013 Paradiam 53477 09127102 0.0165 1 1 580.27 1,735.64 3.6526 207.1356 0.131 14 3 09/27/02 14:25 09/26/02 13:45 3,839.83 3,476.49 363 34 24.82 338.~-2 03-014 Paradiqm 53540 09/30/02 0.28 1 1,918.79 1 735.64 94.7856 301.9212 0.157 SHAW INVOICE #19 FOR PERIOD THROUGH 9/30/02 COVERED THROUGH BATCH #14, TOTAL INVOICED TONS TO DATE E 1,918.79. 1,918.79 1,735.64 0.0000 301.9212 0.157 13ICORRECTION TO BATCH 13 ACTUAL RECYCLED TONS •23.95 0.95 (0.95) I I 0.017 1 1,917.84 1,735.64 -0.0162 301.9050 0.157 CORRECTION ON LINE ABOVE WAS MADE AFTER SHAW INVOICE #19 WAS PREPARED ADJUSTMENT TO BE REFLECTED ON INVOICE #20 FOR OCTOBER WORK. 1,917.84 1,735.64 0.0000 301.9050 0.157 15 2 10/01/02 14:15 09/30/02 10:15 4,248.00 3,839.83 408 17 888 399.30 02-015 Paradiqm 53722 10/14/02 0.375 1 2,317.14 1 735.64 149.7356 451.6407 0.195 16 1 10/02/02 11:07 10/01/02 14:15 4 582.00 4,248.00 334 00 8.23 325.77 01-016 Paradiam 53834 10/03/02 0.017 1 2,642.91 1 735.64 5.5381 457.1788 0.173 17 3 10/03/02 10:10 10/02/02 11:07 4,947.30 4,582.00 365 30 6.37 358.93 03-017 Paradiqm 53970 10/04/02 0.017 1 3 001.84 1 735.64 6.1018 463.2806 0.154 18 4 10/04/02 14:37 10/03/02 10:10 5,405.90 4,947.30 458.60 8.60 450.00 04-018 Paradiam 54090 10/07/02 0.06 1 3,451.84 1 735.64 27.0000 490.2806 0.142 19 1 10/05/02 6:30 10/04/02 14:37 5 634.49 5 405.90 228.59 4.26 224.33 01-019 Paradiom 54091 10/07/02 0.017 1 3,676.17 1,735.64 3.8136 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3 676.17 1 735.64 0.0000 494.0942 0.134 3,676.17 1,735.64 0.0000 494.0942 0.134 TOTALS 5,589.46 177.65 5,411.81 3676.17 1 735.64 GRAND TOTAL NET TONS OF TREATED SOIL 5,411.81 <---VALUES IN THESE TWO CELLS MUST MATCH --------> 5,411.81 file name f0< bfank form: batcf'l log form 100802
SECTION 22 -CLOSURE PLAN
This section describes the closure procedures to be followed when waste treatment using the HCI
TDU is completed at one project site, before moving the unit to another site, and when the unit is
permanently removed from service. This section also describes the financial responsibility
mechanism provided by MSR to ensure adequate resources for these closure activities. Appendix
F contains the closure cost estimate based upon the final closure procedures described in this section.
The approved Closure Plan and any subsequent authorized amendments will be kept with the TDU
until final closure is completed. MSR will review the plan periodically to reflect changes in the unit
design or operating plans that will affect closure activities. Amendments will be made in accordance
with procedures to modify the Closure Plan at the same time an application for permit modification
is submitted for authorization of planned changes in operations. If a permit modification is not
needed, the modified Closure Plan will be updated at least 60 days before a planned change or within
60 days after an unexpected change in the unit occurs.
22.1 Responsible Personnel
Owner/Operator Name:
Address and Telephone Number:
Person Responsible for
Maintenance of the
Closure Plan:
Revision O -Original Issue
Michael Fetherling, VP Operations
Midwest Soil Remediation, Inc.
1480 Sheldon Drive
Elgin, IL 60120
[phone]
Carl Palmer, Thermal Engineer
TD*X Associates, LLC
P.O. Box 13216
Research Triangle Park, NC 27709
[phone]
22-1 June 25 , 2001
22.2 Closure Policies
The HCI TDU is a transportable unit for treatment of PCB-contaminated solids and sludges. The
auxiliary service requirements for the unit include a fuel storage tank, nitrogen supply tank or
cylinders, 460 V three-phase electrical supply, 120 V electrical supply, and raw water makeup. This
Closure Plan addresses closure of the TDU only.
This Closure Plan addresses both demobilization (temporary closures) and final closure of the unit.
The Closure Plan is designed to ensure that the TDU will not require further maintenance and
controls and will minimize or eliminate threats to human health and the environment. MSR will
achieve this standard of closure by treating the inventory of wastes, removing all residues to
appropriate off-site disposal, demobilizing the unit, and either decontaminating all process and
associated equipment or land disposing the equipment in an approved facility. The following
sections discuss in detail the procedures and actions that will be taken in order to satisfy this closure
performance standard for either demobilization or final c_losure.
The closure plan was prepared using the following scenario:
1. Prior to the initiation of temporary or final closure, the flow of PCB materials entering the
treatment unit will cease.
2. The TDU is operating at a facility with its own Closure Plan. TDU closure procedures will
be consistent with the site's Closure Plan. MSR personnel and equipment will be utilized
for closure of the HCI TDU. However, the Closure Cost Estimate presented in Appendix
F of this permit application assumes third-party labor costs.
3. The unit is expected to be operational at the time of temporary or final closure, so that all
remaining inventory of waste feed material can be treated through the thermal separation
process.
4. Following removal of all inventory, the TDU will be demobilized using the procedures
described in Section 22 .3.
5. Final closure of the TDU will be conducted at the MSR Elgin, IL maintenance facility,
using the procedures described in Section 22.4.
The principal governing specifications for equipment decontamination during closure are those from
the TSCA regulations at 40 CFR 761.79, Decontamination Standards and Procedures.
Revision O -Original Issue 22-2 June 25, 2001
.J
22.3 Demobilization Procedures (Temporary Closures)
Prior to transferring the TDU from one operating location to another, or from an operating location
to the final closure location, the unit will be demobilized. The demobilization procedures are as
follows:
1. All remaining PCB feed material inventory will be treated through the TDU.
2. All wastes that were received for treatment with the TDU but were not treated will be
transferred to another facility for approved treatment, storage and/or disposal.
3. Treatment residuals, including organic condensate, waste waters, spent filters and carbon,
and sludges, will be transported for disposal at an approved industrial waste treatment
facility or other approved waste management facility. TSCA approved facilities will be
used for residual material whose PCB level requires that type of waste management.
4. The feed handling and dryer equipment will be decontaminated by running clean sand or
soil through the unit and operating the dryer at maximum temperature for a period of
several hours. The solids discharged will be disposed in a similar manner as was the
treated product. If the product is shown to contain less than 2 ppm PCB after this
operation, the dryer will be considered PCB decontaminated.
5. Flexible hosing and liquid transfer piping will be drained.
6. Tanks and piping will be decontaminated by flushing the internal surfaces three times with
an appropriate solvent (one in which PCBs are soluble at up to five percent or more by
weight). The solvent may be reused for decontamination as long as it contains less than 50
ppm PCB. Alternatively, non-porous equipment (tanks, piping, loader, feed conveyors)
may be flushed until visibly clean according the Visual Standard No. 2, Near-White Blast
Cleaned Surface Finish, of the National Association of Corrosion Engineers (NACE).
7. Movable equipment used for waste handling upstream of the actual treatment step ( e.g.,
feed hoppers, conveyors) will be scraped, washed flushed with an appropriate solvent (as
indicated in item 6 above).
8. Any spills within the secondary containment system will be covered with absorbent. The
spent absorbent will be swept into a container and disposed in an approved disposal facility.
9. The metal secondary containment system on the trailers will be decontaminated by flushing
or swabbing the surfaces as indicated in item 6 above.
Revision O -Original Issue 22-3 June 25 , 2001
.,
10. The solvent used in all rinses will contain less than 50 ppm PCB prior to the start of the
nnse. The concentration of PCBs in the solvent rinse will be tested following the final
nnse.
11. Spent solvent and other residuals from decontamination procedures will be managed
according to the same requirements as solid and liquid residues from operation of the TDU
and disposed, if required, in an approved hazardous waste or PCB waste management
facility. For example, waste water will be TSCA regulated unless it meets the water
decontamination standards of 40 CFR 761.79 (i.e. <3 ppb PCB for NPDES or POTW
discharge, <0.5 ppb PCB for unrestricted use). The same would be true for solids or non-
aqueous liquids, with the decontamination standard being <2 ppm PCB.
NOTE:
For some projects, a transition may be made at this point to
operation on non-TSCA regulated materials, prior to complete
disconnection and disassembly of the unit. TSCA rules will not
apply to the subsequent operations in this decontaminated unit.
12. The utility hookups to the system will be disconnected.
13. All equipment will be secured within the TDU, the unit will be disassembled and
equipment packaged to prevent damage during transport. The trailers and skids will be
prepared for transport to another location, or back to the MSR Elgin, IL facility.
Revision O -Original Issue 22-4 June 25, 2001