NC0002374445_20230301_Hemphill Road TCE_SMP and WMP RA Source Area Remediation

Site Management and Waste
Management Plan
Hemphill Road TCE Superfund Site
Gastonia, Gaston County, North Carolina
Prepared for:
United States Environmental Protection Agency – Region 4
Prepared by:
EQ CH Remediation 1800 Carrillon Blvd. Cincinnati, OH 45240
Remedial Engineering Services (RES) Contract Line Item Number (CLIN) 2
Contract 68HERH19D0009 Task Order Number 68HE0422F0081 DCN RES-R4-22F0081-02005
March 2023
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb i
Contents
Acronyms and Abbreviations ................................................................................................................... iv
1. Introduction ................................................................................................................................. 1-1
1.1 Site Description ................................................................................................................ 1-1
1.2 Site History ...................................................................................................................... 1-2
1.3 Project Organization and Responsibility ......................................................................... 1-7
1.3.1 U.S. Environmental Protection Agency .............................................................. 1-7
1.3.2 Program Manager ............................................................................................... 1-7
1.3.3 Project Manager .................................................................................................. 1-7
1.3.4 Qualified Personnel............................................................................................. 1-7
1.3.5 Site Safety Liaison and Responsible Health and Safety Manager ...................... 1-8
1.3.6 Environmental Manager ..................................................................................... 1-8
1.3.7 Waste Manager ................................................................................................... 1-8
1.3.8 Subcontractors .................................................................................................... 1-8
2. Site Operations and Management ............................................................................................. 2-1
2.1 Site Access ....................................................................................................................... 2-1
2.2 Security ............................................................................................................................ 2-1
2.3 Site Identification Information ......................................................................................... 2-1
2.3.1 Site Address ........................................................................................................ 2-1
2.3.2 Key Contacts ....................................................................................................... 2-1
3. Onsite Activities .......................................................................................................................... 3-1
3.1 Mobilization ..................................................................................................................... 3-1
3.2 Environmental Sample Collection ................................................................................... 3-1
3.3 Remedial Action Implementation .................................................................................... 3-2
3.3.1 Site Preparation ................................................................................................... 3-2
3.3.2 Permanent Monitoring Well Installation ............................................................ 3-2
3.3.3 Permanent Well Sampling and Analysis ............................................................. 3-3
3.3.4 Temporary Monitoring Well Installation ............................................................ 3-3
3.3.5 Temporary Well Sampling and Analysis ............................................................ 3-3
3.3.6 In situ Chemical Oxidation Injections ................................................................ 3-4
3.3.7 Performance Monitoring ..................................................................................... 3-4
3.3.8 Quarterly Monitoring .......................................................................................... 3-5
3.4 Sample Handling and Custody......................................................................................... 3-5
3.5 Waste Management .......................................................................................................... 3-5
3.6 Site Restoration ................................................................................................................ 3-5
3.7 Demobilization ................................................................................................................. 3-5
4. Contingency Plan and Emergency Response Plan ................................................................... 4-1
4.1 Site-specific Training and Orientation ............................................................................. 4-1
4.2 Pre-emergency Planning .................................................................................................. 4-1
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb ii
4.3 Emergency Coordinator ................................................................................................... 4-2
4.4 Emergency Equipment and Supplies ............................................................................... 4-2
4.5 Arrangements with Local Authorities .............................................................................. 4-3
4.6 Emergency Medical Treatment ........................................................................................ 4-3
4.7 Evacuation ....................................................................................................................... 4-4
4.8 Working Alone ................................................................................................................ 4-4
4.9 First Aid Medical Information ......................................................................................... 4-4
4.10 Route to Hospital ............................................................................................................. 4-4
4.11 Emergency Numbers ........................................................................................................ 4-5
4.12 Posting Emergency Information ...................................................................................... 4-6
4.13 Emergency Notification Procedure .................................................................................. 4-6
4.14 Severe Weather and Natural Disasters ............................................................................. 4-6
4.14.1 Tornado ............................................................................................................... 4-6
4.14.2 Earthquake .......................................................................................................... 4-7
4.14.3 Flood ................................................................................................................... 4-7
4.14.4 Other Severe Weather ......................................................................................... 4-7
4.15 Fire, Utility, and Other Emergency Procedures ............................................................... 4-7
4.15.1 Fire ...................................................................................................................... 4-7
4.15.2 Natural Gas Leak ................................................................................................ 4-8
4.15.3 Bomb Threat ....................................................................................................... 4-8
4.15.4 Power Failure ...................................................................................................... 4-8
4.15.5 Theft .................................................................................................................... 4-9
4.15.6 Criminal or Violent Behavior ............................................................................. 4-9
4.16 Spill Management and Reporting .................................................................................... 4-9
4.16.1 Spill Management Procedures—Water ............................................................... 4-9
4.16.2 Spill Documentation and Reporting ................................................................. 4-10
5. Environmental Compliance and Controls ................................................................................ 5-1
5.1 Chemical Storage and Use ............................................................................................... 5-1
5.1.1 CERCLA and EPCRA Reportable Quantity and Associated Spill Reporting—Potentially Applicable ......................................................................................... 5-1
5.1.2 EPCRA Reporting Requirements ....................................................................... 5-1
5.1.3 Chemical Security Anti-terrorism Standards ...................................................... 5-3
5.1.4 Fire Codes ........................................................................................................... 5-4
5.2 Equipment Decontamination Procedures ......................................................................... 5-5
5.3 Noise Control ................................................................................................................... 5-5
5.4 Clean Diesel Requirements .............................................................................................. 5-5
6. Waste Management Plan ............................................................................................................ 6-1
6.1 Waste Streams .................................................................................................................. 6-1
6.2 Waste Characterization .................................................................................................... 6-2
6.2.1 Land Disposal Requirements .............................................................................. 6-3
6.3 Waste Sampling Procedures ............................................................................................ 6-3
6.3.1 Liquids ................................................................................................................ 6-3
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb iii
6.3.2 Soil ...................................................................................................................... 6-3
6.4 Waste Accumulation Time Limit..................................................................................... 6-4
6.5 General Waste Management Requirements ..................................................................... 6-4
6.5.1 Requirements for Accumulating Waste in Drums and Small Containers ........... 6-4
6.5.2 Requirements for Accumulating Waste in Roll-off Boxes ................................. 6-5
6.5.3 Requirements for Accumulating Waste in Totes ................................................ 6-5
6.6 Labels and Tracking ......................................................................................................... 6-5
6.7 Inspection of Waste Accumulation Areas ........................................................................ 6-6
6.8 Waste Transportation ....................................................................................................... 6-7
6.9 Transportation and Disposal Documentation ................................................................... 6-7
6.10 Transporter Requirements ................................................................................................ 6-7
6.10.1 Department of Transportation Requirements ...................................................... 6-8
6.11 Disposal Requirements .................................................................................................... 6-9
6.12 Training ............................................................................................................................ 6-9
6.13 Recordkeeping ................................................................................................................. 6-9
7. References .................................................................................................................................... 7-1
Appendix
A Example Waste Tracking Log
Tables
Table 1-1. Site History ................................................................................................................................................1-3 Table 4-1. Emergency Numbers .................................................................................................................................4-5 Table 4-2. Emergency Notification Contacts..............................................................................................................4-6 Table 6-1. Waste Management ...................................................................................................................................6-1
Figures
Figure 1-1. Site Location Figure 1-2. Site Layout Figure 1-3. Site Topography
Figure 3-1. TCE Source Area Figure 4-1. Hospital Route Map

Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb iv
Acronyms and Abbreviations
Acronym Definition
µg/L microgram(s) per liter
ASB Analytical Services Branch
bgs below ground surface
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CLP Contract Laboratory Program
cPA/SI Combined Preliminary Assessment/Site Inspection
CPR cardiopulmonary resuscitation
DHS Department of Homeland Security
DOT Department of Transportation
EM environmental manager
EPA U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ERRB Emergency Response and Removal Branch
EQ CH JV EQ CH Remediation (an EQM CH2M JV)
GCEHS Gaston County Environmental Health Services
GIT Gastonia Industrial Truck, Inc.
HASP health and safety plan
IAROD Interim Action Record of Decision
ID identification
ISCO in situ chemical oxidation
LEPC Local Emergency Planning Committee
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb v
Acronym Definition
MCL maximum concentration level
MRO Mooresville Regional Office
NCDEQ North Carolina Department of Environmental Quality
NCDWQ North Carolina Division of Water Quality
OSHA Occupational Safety and Health Administration
PM Project Manager
PSRG Protection of Groundwater Preliminary Soil Remediation Goal
PTZ Piedmont Transition Zone
PVC polyvinyl chloride
QA quality assurance
QC quality control
RCRA Resource Conservation and Recovery Act
RDW remediation-derived waste
RES Remedial Engineering Services
RHSM responsible health and safety manager
RI remedial investigation
RQ reportable quantity
SDS safety data sheet
SERC State Emergency Response Commission
site Hemphill Road TCE Superfund Site, Gastonia, Gaston County, North Carolina
SMWMP Site Management and Waste Management Plan
SRR Site Reassessment Report
SSL site safety liaison
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb vi
Acronym Definition
TBD to be determined
TCE trichloroethene
TO task order
TOCOR Task Order Contracting Officer’s Representative
UFP-QAPP Uniform Federal Policy Quality Assurance Project Plan
UN United Nations
UST underground storage tank
VOC volatile organic compound
WM waste manager
DISCLAIMER: If using a screen reader, adjustment to your default settings may be required.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-1
1. Introduction
This Site Management and Waste Management Plan (SMWMP) was prepared under Contract
68HERH19D0009, Task Order (TO) Number 68HE0422F0081 for the Hemphill Road TCE Superfund Site (site) located at 5009 Hemphill Road, Gastonia, Gaston County, North Carolina. Figures 1-1 and 1-2 depict the location and the layout of the site, respectively. The selected remedy for the site is in situ
chemical oxidation (ISCO), groundwater monitoring, alternate water supply, and institutional controls (Versar, 2020).
The Site Management Plan describes the processes, procedures, monitoring, and safeguards that EQ CH
Remediation (an EQM CH2M JV) (EQ CH JV) will use to prevent the release of contaminants or pollutants during the TO implementation and how wastes that are encountered during TO activities will be managed and disposed, as appropriate. The Site Management Plan will also describe how EQ CH JV
will conduct field sampling and data acquisition activities, communications, and waste management.
The Waste Management Plan, provided in Section 6, specifies the safe handling of containerized waste in addition to procedures for offsite transportation and disposal of waste. Profiling, manifesting, and
Department of Transportation (DOT) shipping will be described.
1.1 Site Description
The site is in a mixture of residential and commercial/industrial area of South Gastonia and is currently owned and operated by Gastonia Industrial Truck, Inc. (GIT). GIT, located near the center of the property on the developed northwestern parcel, sells and repairs forklifts. Current structures on the GIT property include a metal main facility building and a smaller garage located approximately 150 feet south of the
main facility building. A concrete pad and a loading dock are located on the northern side of the main facility building. The loading dock and concrete pad were used to store equipment and miscellaneous parts. The land around the GIT buildings consists of either a gravel driveway/parking lot or a grass field that was used in the forklift repair operations. Some junked automobiles and a dilapidated semi-trailer are present that the property owner uses as storage. The wooded areas onsite generally consist of hardwood trees and dense to moderately dense underbrush (for example, brambles). Fallen trees, tree limbs, and leaf matter cover the floor of the wooded areas.
The site is bordered to the northwest by an unnamed tributary, to the west by Hemphill Road, and to the
northeast, east, and south by private/residential property. Two individual residences and the Kensington Estates subdivision are located to the southwest of the site directly across Hemphill Road. Kensington Estates contains approximately 60 housing units. Wesley Acres is located toward the southwest along
Forbes Road, and the Wesley Acres community potable water well serves approximately 66 homes. Several other residences are located along Hemphill Road, and several additional subdivisions, mobile home communities, and individual homes are located within a 0.5-mile radius of the site (Versar, 2020).
Surface drainage at the site is generally to the northwest. Surface water features on the site include an unnamed tributary along the northern border that flows northeast to southwest, and a small unnamed pond located just north of the northeastern boundary (Figure 1-3). There are also two natural drainageways that
drain northwestward to the unnamed tributary. One drainageway is located on the western portion of the site and the other is located west of the site between the private residences along Hemphill Road and the Kensington Estates subdivision. Reportedly, the offsite drainageway was previously large, deep, and
filled in with rubble when the Kensington Estates subdivision was constructed.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-2
The onsite and adjacent surface water features ultimately flow to an unnamed creek, then to Crowders Creek, and then to Lake Wylie in South Carolina. There are no water supply intakes located within a the 15-mile surface water pathway. The nearest fishery, Crowders Creek, is located approximately 2.2 miles
downstream of the site. The nearest wetland (as defined in the EPA Hazard Ranking System) along the 15-mile surface water pathway is located approximately 3.5 miles downstream of the site (Versar, 2020).
Groundwater beneath the site is made up of the Piedmont aquifers. Although simply described as a two-component (regolith and bedrock) groundwater system, the aquifers are quite complex systems (USGS, 2008). In general, the groundwater-flow system at the site consists of saturated unconsolidated regolith (residuum saprolite and alluvium) overlying saturated fractured bedrock. The primary direction of groundwater flow within the residuum on the southern side of the unnamed tributary is to the northwest toward the unnamed tributary. Groundwater flow within the residuum on the northern side of the unnamed tributary is to the south-southwest toward the unnamed tributary. Groundwater flow in the fractured bedrock aquifer is complex but is apparently to the west toward the Crowders Creek drainage basin. Private and community water supply wells are screened within the fractured bedrock.
TCE contamination is present in the subsurface soils at concentrations greater than the North Carolina Department of Environmental Quality (NCDEQ) Protection of Groundwater Preliminary Soil Remediation Goals (PSRGs) for subsurface soil, possibly representing a continuing source of
groundwater contamination. Cobalt, iron, manganese, and thallium were detected in nearly every subsurface soil sample collected and exceeded the NCDEQ Protection of Groundwater PSRGs at several sampling locations, including the background location, possibly indicating that the metal concentrations
are naturally occurring. TCE is present in the groundwater both in the residuum and in the fractured bedrock (Versar, 2020).
1.2 Site History
In the 1950s, the southeastern portion of the site was reportedly used for storage and disposal of industrial waste materials. During the early 1950s, 500-pound bales of waste cardboard from local cotton mills reportedly were stored on the property. An estimated 1 million pounds of this material accumulated but
was then destroyed by fire. The parcel was sold in 1955 and was reportedly used by that property owner to recycle chemical drums by emptying their residual contents onto the ground surface, burning, and crushing the drums for scrap metal recycling.
Based on analysis of the historical aerial photographs (Versar, 2020), both GIT parcels and surrounding areas were used for agriculture in 1951 and a residential home was present on the western side of site. The 1956 aerial photograph showed new roads, a fenced-in area, light-toned mounded material, ground
scarring, and a shed in the southeastern portion of the site. This is within the same timeframe that the drum recycling activities were reportedly occurring. The northern parcel remained agricultural during this time period. EPA used the 1956 aerial photograph to focus the remedial investigation (RI).
The previous property owner re-acquired the southeastern land parcel in 1957 and reportedly planted the property with trees. During tree clearing on the southeastern parcel to construct a residence, the property owner reportedly encountered buried debris of an unspecified nature and stopped the clearing activities. The property was sold to GIT in 1972.
During the late 1980s, Gaston County Environmental Health Services (GCEHS) collected water samples
from the GIT facility’s production well and two domestic wells at 4901 and 4825 Hemphill Road. The results revealed a high concentration of TCE, which significantly exceeded North Carolina Groundwater
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-3
Standards (NCAC, 2022) and EPA benchmarks. Upon being notified of the contamination, the homeowners installed carbon filtration units on their respective domestic wells, and the GIT facility stopped using its production well for potable water. During the late 1980s and early 1990s, sampling by
GCEHS and the North Carolina Division of Environmental Management (NCDEM) detected VOCs at additional domestic wells near the site. Table 1-1 summarizes the environmental investigations that followed the initial VOC discovery.
Table 1-1. Site History
Name of Event or Report Date(s) Summary
1 NCDEM sampling events at GIT facility 1989 and 1992 Chlorinated chemical cis-1,2-dichloroethene detected at less than 0.5 part per billion in a waste oil underground storage tank northeast of the facility’s main building; NCDEM issued a Notice of Violation to GIT in November 1992.
2 GIT wastewater sampling 1989 A wastewater sample from the facility detected toluene, ethylbenzene, xylenes, phenol, phthalates, and possible fuel-oil residue.
3 GIT soil investigation 1993 A soil investigation at the underground storage tank and in a loading dock area revealed petroleum contamination in the surface soil, affecting approximately 88 cubic yards of soil. Based on the findings of the soil investigation, GIT removed the petroleum-contaminated soil.
4 NCDEM monitoring well
sampling events
1993 and 1994 NCDEM installed monitoring wells on and adjacent to the site property; sampling data indicated that TCE groundwater contamination was concentrated beneath the southeastern parcel but extended northwest beneath the adjacent forklift repair facility toward
Hemphill Road.
5 EPA and North Carolina Superfund Section cPA/SI 1999 TCE contamination was found in both of the Kensington Estates community wells, greater than 10 µg/L and exceeding federal benchmarks and state groundwater standards. Gaston County and the NCDWQ MRO shut down both Kensington Estates community wells, provided a temporary alternative drinking water supply to the residents, and subsequently connected the subdivision to two existing community wells at the neighboring Amy Acres subdivision.
In July 1999, sampling by NCDWQ detected TCE breakthrough at the domestic well carbon filtration units at 4825 and 4901 Hemphill Road. In response, the property owners replaced the saturated filtration media in each well.
The cPA/SI Report recommended further RA under CERCLA.
6 North Carolina Superfund Section SRR March 2001 The SRR reversed the cPA/SI recommendation.
7 North Carolina Superfund Section letter April 2001 The North Carolina Superfund Section sent a letter to the NCDWQ MRO and GCEHS recommending:
 Amy Acres (and Kensington Estates) subdivision be connected to Gastonia municipal water lines, or alternatively, that the Amy Acres community wells be sampled quarterly or semi-annually for TCE.
 Residences at 4825 and 4901 Hemphill Road be connected to Amy Acres via Kensington Estates.
 Domestic well contamination and water usage at 4708 Hemphill Road be further evaluated.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-4
Table 1-1. Site History
Name of Event or Report Date(s) Summary
8 NCDWQ MRO reporting 2008 TCE concentrations in two community wells supplying the Cedar Grove subdivision, located approximately 1.5 miles southeast of GIT,
had been increasing, approaching the 5.0 µg/L federal National Primary Drinking Water Regulations MCL. In 2009, MRO notified the North Carolina Superfund Section that TCE contamination existed in additional community wells near the site. TCE reportedly existed in the two community wells supplying the Wesley Acres subdivision, located directly across Forbes Road, south of Kensington Estates.
9 NCDWQ MRO reporting 2009 NCDWQ MRO notified the North Carolina Superfund Section that TCE contamination existed in the two community wells supplying the Wesley Acres subdivision, located directly across Forbes Road, south of Kensington Estates.
10 North Carolina Superfund Section Removal Request 2009 A Removal Request was transmitted to EPA Region 4 Emergency Response and Removal Branch, incorporating the previously described information. EPA assigned an On-scene Coordinator who sampled the GIT facility production well, two of the onsite monitoring wells, and the domestic wells at 4825, 4901, and 4708 Hemphill Road. Sampling revealed that TCE breakthrough had occurred again in the carbon filters at 4825 and 4901 Hemphill Road; the On-scene Coordinator arranged for replacement of the filtration media in both units. Sample data at GIT and 4708 Hemphill Road were consistent with results from previous investigations.
11 North Carolina Superfund Section SRR 2012 The second SRR recommended the site for further RA under CERCLA.
12 North Carolina Superfund Section Expanded Site Inspection
2012 A well survey within approximately 0.5 mile of the GIT property identified 7 community wells and approximately 150 homes served by private drinking water wells. In March 2012, a total of 9 monitoring wells, 1 production well, 7 community wells, 76 private wells, and 5 surface water locations were sampled. TCE contamination exceeding the MCL was found in the private wells at 4727, 4825, and 4901 Hemphill Road, and the Emergency Response and Removal Branch replaced filter systems at 4825 and 4901 Hemphill Road and added a new filter system at 4727 Hemphill Road. TCE contamination was also found in the three surface water samples located in the northwestern corner of the site and downstream.
In August 2012, eight private wells were sampled for VOC analysis. TCE contamination exceeding the MCL was found in the pre-filter samples collected at 4727, 4825, and 4901 Hemphill Road but was nondetect in the post-filter samples. TCE was not detected in the
remaining private wells sampled.
In November 2012, eight private wells and the two community wells at the Wesley Acres subdivision were sampled for VOC analysis. TCE contamination exceeding the MCL was found in the pre-filter samples collected at 4825 and 4901 Hemphill Road but was nondetect in the post-filter samples. TCE contamination was detected at the Wesley Acres North Well at a concentration of 2.5 µg/L, which is less than the MCL. TCE was not detected in the Wesley Acres South Well or any of the remaining private wells sampled.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-5
Table 1-1. Site History
Name of Event or Report Date(s) Summary
13 North Carolina Superfund Section Expanded Site
Inspection
2013 The private potable wells at 4825 and 4901 Hemphill Road were sampled and analyzed for VOCs in three quarterly sampling events.
During each sampling event, TCE contamination exceeding the MCL was found in the pre-filter samples collected at 4825 and 4901 Hemphill Road but was nondetect in the post-filter samples.
14 RI 2013–2017 The RI consisted of the following:
 Geophysical magnetic anomaly surveys were performed in the southeastern parcel, the western area of the site along Hemphill Road, and the southern area of the site along Hemphill Road; no
presence of buried metallic debris was detected.
 Surface and subsurface soil sampling was conducted both onsite and offsite. Low levels of VOCs, SVOCs, and pesticides were found in many of the surface and subsurface soil samples. TCE exceeded the NCDEQ PSRG of 21 micrograms per kilogram at three locations; the high TCE concentrations in the subsurface soil in these locations could be a continuing source of groundwater contamination.
 Groundwater samples were collected from temporary wells on the GIT property and surrounding private properties. In addition, groundwater samples were collected from permanent monitoring wells and private potable wells on the GIT property and surrounding private properties. The TCE contaminant plume generally follows the surface topography to the west/northwest and extends across Hemphill Road toward the unnamed tributary, as predicted by the water table aquifer potentiometric surface gradient. The source of TCE contamination in the residuum appears to be within the southeastern parcel in the vicinity of temporary well DPT-31 and in the vicinity of temporary wells DPT-22 and DPT-24 and permanent well GIT-006, where the drum dumping and recycling activities were reported to have taken place. The lateral and vertical extent of detectable groundwater contamination in the fractured bedrock aquifer was not determined.
 Surface water and sediment sampling was performed within the unnamed tributary and the small pond to the north of the GIT property. TCE was detected at 11 of the 18 sampling locations at concentrations ranging 0.81 µg/L to 17 µg/L; the highest TCE concentration was found in the seep sample located about 300 feet downstream of the northwest corner of the GIT property.
 An extensive vapor intrusion study was conducted over a period from July 2013 through April 2017 at onsite and offsite properties. The private residential properties near the northwestern border of the GIT property and the GIT facility building are within the residuum TCE plume and are potentially susceptible to vapor
intrusion.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-6
Table 1-1. Site History
Name of Event or Report Date(s) Summary
15 IAROD 2018 The major components of the IAROD consisted of the following:
 Predesign investigation to further define areas requiring remediation and collect additional data needed to design the remedy.
 Bench-scale and pilot-scale treatability studies conducted during the remedial design phase to select the appropriate ISCO product and determine appropriate product loading rates.
 ISCO treatment of contaminated groundwater using an appropriate oxidant.
16 Predesign Investigation 2019–2020 The predesign investigation consisted of the following:
 Installation of five new monitoring wells onsite and sampling of permanent monitoring wells, temporary monitoring wells, and potable wells (onsite and offsite). Analytical results and groundwater elevation data were consistent with previous data.
 Bench-scale and pilot-scale treatability studies were performed to assess the potential for ISCO using permanganate and activated persulfate to oxidize chlorinated solvents, primarily TCE in aquifer samples. The results suggested that the use of permanganate injection using hydraulic fracturing was the preferred method.
 Pilot-scale treatability study results showed that hydraulic fracturing was successful at distributing permanganate and that potassium permanganate is effective at reducing TCE concentrations within the 15-foot radius of influence.
Source: Versar, 2020.
Notes:
µg/L = microgram(s) per liter
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
cPA/SI = Combined Preliminary Assessment/Site Inspection
ERRB = Emergency Response and Removal Branch
IAROD = Interim Action Record of Decision
MCL = maximum concentration level
MRO = Mooresville Regional Office
NCDWQ = North Carolina Division of Water Quality
SRR = Site Reassessment Report
SVOC = semivolatile organic compound
UST = underground storage tank
The site is in the vicinity of Textron, Inc. and A B Carter, Inc., which are Resource Conservation and Recovery Act (RCRA) properties and are known to have historically used chlorinated solvents tetrachloroethene or TCE, or both, in their manufacturing processes. The Falls Dump Site is a pre-1983
unregulated landfill less than 0.5-mile from the site. The Falls Dump Site is being evaluated by NCDEM as part of their Pre-Regulatory Landfill program. In addition, the Davis Park Road TCE Superfund Site is about 5 miles north of the site. These current or former industrial facilities potentially could have
contributed to the chlorinated solvent contamination observed in many of the potable bedrock wells in this general area.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-7
1.3 Project Organization and Responsibility
The following subsections describe the overall organizational structure of the project team.
1.3.1 U.S. Environmental Protection Agency
The EPA is the lead agency for all activities at the site. Donna Seadler is the EPA Task Order Contracting Officer’s Representative (TOCOR) for the activities associated with this TO.
1.3.2 Program Manager
The program manager, Juliana Hess, has the overall responsibility for assuring EQ CH JV meets EPA’s project objectives and quality standards. The program manager is also responsible for technical quality control (QC) and project oversight.
1.3.3 Project Manager
The Project Manager (PM), Christopher Allen, P.E., is the primary point of contact with EPA. He reports directly to the EPA Region 4 TOCOR for all activities associated with this TO.
The PM is responsible for implementing the project delivery and is authorized to commit budgeted and planned resources to meet project objectives and requirements. The primary PM functions include achieving EPA’s technical and scheduling objectives and management of the project budget.
Additionally, the PM is responsible for the following:
 Defining project objectives and developing a detailed work plan and schedule
 Establishing project policy and procedures to address specific project requirements
 Acquiring and applying technical and corporate resources to meet budget and schedule requirements
 Chartering field team leaders and support staff with regard to the project’s special considerations
 Monitoring and directing team members
 Developing and accessing ongoing project or task staffing requirements
 Reviewing the work performed on each task to ensure quality, responsiveness, and timeliness
 Reviewing and analyzing overall task performance compared to planned schedule and budget
 Reviewing external reports (deliverables) before submittal to the EPA Region 4 TOCOR
 Representing the overall project team at meetings and public hearings
 Supervising staff and assisting them in resolving project-related issues
1.3.4 Qualified Personnel
Qualified personnel support the PM in strategic, technical, and planning activities, as follows:
 Linda Colella, P.E., Certified Professional in Erosion and Sediment Control – Regulatory and compliance subject matter expert
 Monica Fulkerson, P.E. – Engineer of record
 Lisa Schwan, Certified Hazardous Materials Manager – Waste management subject matter expert
 Mike Perlmutter, P.E. – Senior remediation engineer
 Teg Williams, P.G. – Senior hydrogeologist
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-8
1.3.5 Site Safety Liaison and Responsible Health and Safety Manager
A site safety liaison (SSL) will be onsite during all field activities conducted under this TO. The SSL for field sampling oversight activities is Blane Houck. The SSL will be responsible for pre-emergency
planning and will assume charge during an emergency if one occurs during completion of the TO. Specific aspects of the SSL’s role are described in the contingency plan section of the Site Management Plan, as well as in the site-specific health and safety plan (HASP).
The Responsible Health and Safety Manager (RHSM) will be Carl Woods. The RHSM is responsible for developing, reviewing, and updating the HASP, reviewing subcontractor qualifications, job safety analysis documentation, responding to incidents, and performing site audits, if necessary. The specific
aspects of the RHSM are further outlined in the HASP.
1.3.6 Environmental Manager
The environmental manager (EM) for the site is Linda Colella. The EM supports the PM in protecting the
environment during all phases of project delivery as follows:
 Providing project technical guidance to support development and implementation of the environmental program, plans, and procedures
 Identifying regulations that may be triggered and the associated compliance requirements
 Establishing compliance tracking measures, when appropriate
 Reviewing subcontractor plans and submittals
 Serving as the point of contact for all environmental incidents and associated reporting
1.3.7 Waste Manager
The waste manager (WM) for this site is Lisa Schwan. Responsibilities of the WM include the following:
 Preparing the Waste Management Plan
 Guiding the project team on waste storage, handling, and management procedures
 Characterizing wastes associated with the project
 Reviewing and approving waste profile forms and shipping documentation, manifests, waste transporters, and disposal facilities
1.3.8 Subcontractors
Walker-Hill Environmental will provide drilling, well development, and grab groundwater sampling services for up to 5 permanent and 35 temporary monitoring wells. They will also drill and install up to 26 ISCO injection wells. The temporary monitoring and ISCO injection wells will be properly abandoned at the completion of the scoped work.
FRx will provide hydraulic fracturing and ISCO injection services.
An undetermined subcontracted surveyor will provide surveying services for the newly installed monitoring wells.
The Underground Detective will provide underground utility locations services prior to the commencement of subsurface instructive activities.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 1-9
Analytical sample analyses will be completed by EPA’s Analytical Services Branch (ASB) laboratory. If ASB is unable to analyze samples, an EPA Contract Laboratory Program (CLP)-assigned laboratory will be used. Groundwater and waste characterization samples will be analyzed in accordance with the Unified
Federal Policy Quality Assurance Project Plan (UFP-QAPP). Standard operating procedures, responsibilities, and criteria for the laboratories are detailed in the UFP-QAPP.
An undetermined subcontractor will provide waste transportation and disposal services.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 2-1
2. Site Operations and Management
This section outlines access, security, contingency procedures, and management responsibilities that will
be used during field activities conducted under this TO.
2.1 Site Access
The site consists of a contaminated groundwater plume that extends offsite, encompassing approximately 11.2 acres in the residuum portion of the aquifer and an estimated 26.3 acres in the bedrock portion of the aquifer. A site laydown and remediation-derived waste (RDW) accumulation area will be identified with EPA and property owner approval prior to the start of work. Entrance to the site is via a single driveway secured by a locked gate. Access will be coordinated with the property owner.
Work is currently planned within the site boundary, except for offsite private potable wells. EQ CH JV will obtain the necessary access agreements with the offsite landowners.
2.2 Security
During field activities, field oversight staff will conduct activities from vehicles that remain locked when not in use. Additionally, a site laydown and RDW accumulation area will be identified by EPA prior to the start of work. The driveway used to access the site is secured by a locked gate. Temporary security fencing will be erected to further secure materials and equipment. Work hours during field activities are to be determined (TBD). Sampling equipment and other valuables will be secured in the vehicles, out of sight with larger equipment secured at the laydown area. Field personnel will carry cell phones for communication and use in emergencies, but cell phones should be secured out of sight because they are a common burglary item. The area has an established 911 emergency call number that may be used for emergency assistance.
2.3 Site Identification Information
The site’s National Superfund Database/EPA identification (ID) number is NC0002374445 and is in Gastonia, Gaston County, North Carolina.
2.3.1 Site Address
The site address is 5009 Hemphill Road, Gastonia, North Carolina 28056.
2.3.2 Key Contacts
Donna Seadler EPA TOCOR Office: 404-606-1158
Lisa Schwan WM
Office/Cell: 404-414-2505
Blane Houck SSL Office/Cell: 704-207-6072
Juliana Hess Program Manager Office/Cell: 201-602-1557
Linda Colella EM Office/Cell 720-320-2590
Carl Woods RHSM Office/Cell: 513-319-5771
Christopher Allen PM Office: 404-978-7475 Cell: 770-733-6188

Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 3-1
3. Onsite Activities
The onsite activities described in the following subsections will be performed as part of the remedial
activities for the site under the current TO. Following are the planned onsite activities:
 Mobilization and demobilization activities, including underground utility locates, migratory bird survey, and vegetation clearance
 Installation and development of 5 permanent and up to 35 temporary monitoring wells
 Groundwater sampling of 34 permanent monitoring wells (29 existing and 5 new) and up to 35 temporary monitoring wells to further delineate the area requiring treatment and optimize ISCO
injections
 Installation of up to 26 temporary ISCO injection wells
 Injection of potassium permanganate using hydraulic fracturing
 Abandonment of the 35 temporary monitoring wells and 26 ISCO injection wells
 Surveying
 Performance monitoring of 14 permanent monitoring wells at 1 month, 3 months, and 6 months
following the ISCO application to evaluate VOC concentrations within the target treatment zone and identify whether additional ISCO injections are warranted
 Quarterly monitoring of 34 permanent monitoring wells and 4 residential potable wells to evaluate VOC concentrations within the target treatment zone and monitor for contaminant migration; up to eight quarterly events will occur every 3 months starting at 9 months after ISCO injections
 Characterization and disposal of the RDW
Mobilization is planned for April 2023. Abandonment of temporary wells will occur after sampling has been completed, which is anticipated to occur in July 2023. ISCO injection wells will be abandoned once
remediation objectives are achieved. It will be the SSL’s responsibility to conduct the tasks according to the specified procedures.
General descriptions of these activities are provided in the following subsections. A detailed description
of all tasks, including a description of project deliverables, can be found in the Technical Management Plan (EQ CH JV, 2023).
3.1 Mobilization
This activity consists of mobilizing equipment and personnel before the commencement of onsite activities and will occur prior to each field event.
3.2 Environmental Sample Collection
EQ CH JV will collect groundwater and RDW characterization samples in accordance with the UFP-QAPP. EPA’s Scribe software will be used to generate sample and tag labels and chain-of-custody forms for samples collected in the field. The Scribe sample manager will set up the Scribe database,
prepare sample labels, and coordinate with the field team prior to sample collection. The samples will be properly packaged and sent under proper chain of custody for VOC analysis using EPA Method 8260C,
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 3-2
Volatile Organic Compounds by Gas Chromatography-Mass Spectrometry, by EPA’s ASB laboratory or approved EPA CLP-assigned laboratory. Quality assurance (QA) and QC samples will be collected in accordance with the UFP-QAPP.
3.3 Remedial Action Implementation
3.3.1 Site Preparation
Prior to remedial action implementation, a migratory bird survey will be completed in the area where brush clearing and drilling will occur. If nests or migratory bird habitats are discovered, EPA will be contacted, and field work will be postponed until the issue is resolved.
Vegetation clearance from the source area will be completed prior to the first drilling event. Grass and
undergrowth will be mowed, and small trees up to 10-inches in diameter (at breast height) will be removed only if needed. All material will be shredded or chipped in place, and trees will be removed from the site. Any shredded or chipped material will be spread onsite to a thickness of less than 4 inches.
Utility clearance will be conducted by a third-party locator (in addition to call North Carolina One-Call). Utility clearance will be conducted three times: (1) prior to drilling the 5 permanent monitoring wells, (2) prior to drilling the 35 temporary monitoring wells, and (3) prior to drilling the 26 injection wells.
The location of the laydown area, RDW accumulation area, and decontamination pad will be coordinated with the property owner and EPA. The RDW accumulation area will likely be the concrete area in front of one of the garage’s bays.
3.3.2 Permanent Monitoring Well Installation
The five permanent monitoring wells will be installed within the source area, as shown on Figure 3-1, and
expected to be no more than 60 feet below ground surface (bgs), with an average of 50 feet bgs. The borings will be advanced to the top of bedrock (bottom of the Piedmont Transition Zone [PTZ]).
Lithology and discontinuity characteristics will be recorded by the EQ CH JV field geologist. The licensed well driller onsite will be requested to provide input on drilling data during drilling activities. Following placement of the well screen and casing, the sand pack will be placed in the borehole annulus adjacent to the screen. The screen will be factory slotted to 0.020-inch, 10-foot screens, 2-inch threaded
polyvinyl chloride (PVC). Blank casing will be 2-inch, factory threaded as a stickup well. Following placement of the well screen, 8-16 grade sand pack will be placed in the borehole annulus. The sand pack will extend a minimum of 2 feet above the top of the screen. This will be followed by a minimum 2-foot-thick bentonite seal and cement and bentonite grout from the seal to approximately 3 feet bgs. No soil samples will be collected during well installation.
Surface completion will include a 2-foot by 2-foot by 4-inch-deep concrete well pads with a protective
steel cover and four protective bollards placed around each well pad to protect the well stickup. Boring logs and construction completion logs will be prepared for each monitoring well.
The permanent monitoring wells will be developed following installation to remove as much fine-grained material as possible from the well casing, sand pack, and borehole wall and to stabilization parameters according to standard operating procedures included in the UFP-QAPP.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 3-3
A site laydown and RDW accumulation area will be identified with EPA and property owner approval prior to the start of work. All soil cuttings generated during drilling and fluids generated by well development and equipment decontamination will be contained in new United Nation (UN)-approved
55-gallon steel drums or roll-offs within the RDW accumulation area. The containers will be staged onsite for transportation and disposal offsite.
The five permanent monitoring wells will be surveyed by a North Carolina registered surveyor to within
0.01 foot to establish location and within 0.1 foot to establish casing elevations.
3.3.3 Permanent Well Sampling and Analysis
A synoptic round of groundwater elevations will be collected from the permanent monitoring wells prior to groundwater sampling. Groundwater samples will then be collected from 34 permanent monitoring wells (including the 5 new monitoring wells discussed in Section 3.3.2). Samples will be analyzed for VOCs using EPA Method 8260C. If approved by EPA, 2- or 3-day turnaround time will be requested for
preliminary results to streamline the remaining delineation effort.
Groundwater samples will be collected using low-flow sampling procedures using a submersible pump,
such as a Grundfos or Bladder type. Purging prior to sampling will continue until water quality parameters and water levels stabilize in accordance with the UFP-QAPP.
Groundwater samples will be collected along with appropriate QA and QC samples.
3.3.4 Temporary Monitoring Well Installation
Up to 35 temporary monitoring wells will be installed to refine the ISCO target treatment zone. A subset of the 35 temporary monitoring wells will be installed based on the results from the permanent
monitoring well sampling and analysis. The temporary monitoring wells will be installed as described in Section 3.3.2, except that no surface completions will be installed and the surveying coordinates will be documented using sub-meter GPS equipment rather than via a North Carolina registered surveyor.
The initial temporary monitoring wells will be sampled and analyzed in accordance with Section 3.3.5, then additional temporary monitoring wells will be installed (up to a total of 35), sampled, and analyzed. All required temporary monitoring wells will be installed and sampled during one mobilization.
Following analysis of the results, the temporary wells will be abandoned in accordance with North Carolina regulations.
3.3.5 Temporary Well Sampling and Analysis
Groundwater samples will be collected from up to 35 temporary monitoring wells and analyzed for VOCs using EPA Method 8260C. A 24-hour turnaround time will be requested for preliminary results to
streamline the remaining delineation effort.
Groundwater elevations will be measured in each well prior to sampling.
Groundwater samples will be collected using low-flow sampling procedures using a submersible pump,
such as a Grundfos or Bladder type. Purging prior to sampling will continue until water quality parameters and water levels stabilize in accordance with the UFP-QAPP.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 3-4
3.3.6 In situ Chemical Oxidation Injections
ISCO injection work will begin once the permanent and temporary monitoring well sampling results are assessed. A drilling subcontractor will drill 26 borings within the saprolite, PTZ, and bedrock assuming
expected to be to an average maximum depth of 57 feet bgs (7 feet into the bedrock). Using sonic drilling methods, an 8-inch borehole will be advanced to a depth of 7-feet below the treatment interval. Lithology and discontinuity characteristics will be recorded by the EQ CH JV field geologist. The licensed well
driller onsite will be requested to provide input on drilling data during drilling activities.
A 4-inch diameter PVC blank casing with end cap will then be installed from termination depth of the boring to the surface. Centralizers will be employed above and below the treatment zone and every 20 feet above to the surface. The surveying coordinates will be documented using sub-meter GPS equipment rather than via a North Carolina registered surveyor
The injection subcontractor, FRx, will perform the ISCO injections using a potassium permanganate slurry based on a radius of influence of 15 feet. Unless physical obstructions are present, injection points will be 30 feet from the next closest injection point in a grid layout. Injections will begin just above the
partially weathered rock and fractured bedrock interface and then progress upwards at 5-foot intervals to the water table. FRx will complete all reagent procurement, management, and usage.
As presented in the remedial design, approximately 1,000 pounds of potassium permanganate will be
injected into each fracture. Each injection borehole is expected to have an average of 7 fractures; therefore, the 30 injection boreholes (including the 4 pilot-scale treatability study boreholes) will result in a total of 203 fractures. A total of 203,000 pounds of permanganate will be injected into the source area,
which equals just under three pore volumes. During the injections, grab groundwater samples will be collected from permanent monitoring wells closest to the active injection wells and evaluated for water quality parameters and the presence of permanganate. The field data will be used to optimize the injection
process to improve reagent distribution as necessary.
Following injections, the drilling subcontractor will abandon the wells in accordance with North Carolina regulations.
3.3.7 Performance Monitoring
Performance monitoring will be completed to evaluate the effectiveness of the injections in distributing ISCO amendments into the subsurface. Groundwater will be collected from 14 permanent monitoring wells in the TCE source area and submitted for VOC analysis using EPA Method 8260C. A synoptic round of groundwater elevations will be collected from the permanent monitoring wells prior to
groundwater sampling.
Groundwater samples will be collected using low-flow sampling procedures using a submersible pump, such as a Grundfos or Bladder type. Purging prior to sampling will continue until water quality
parameters and water levels stabilize in accordance with the UFP-QAPP.
Performance monitoring will occur at 1 month, 3 months, and 6 months following completion of ISCO injections, for a total of three events.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 3-5
3.3.8 Quarterly Monitoring
Quarterly monitoring of 34 permanent monitoring wells and 4 residential potable wells will be conducted to evaluate VOC concentrations within the target treatment zone and monitor for contaminant migration.
Eight quarterly events will be conducted every 3 months starting at 9 months after ISCO injections. Groundwater samples will be submitted for VOC analysis using EPA Method 8260C to evaluate the progress of the remedy in accordance with the UFP-QAPP. A synoptic round of groundwater elevations
will be collected from the permanent monitoring wells prior to groundwater sampling.
Groundwater samples will be collected using low-flow sampling procedures using a submersible pump, such as a Grundfos or Bladder type. Purging prior to sampling will continue until water quality
parameters and water levels stabilize per the UFP-QAPP.
3.4 Sample Handling and Custody
Sample handling and custody will be performed in accordance with the UFP-QAPP sample handling and chain-of-custody procedures and shipped via FedEx for next-day delivery. The location and details of the nearest FedEx facility are as follows:
FedEx Ship Center
1555 Rankin Lake Road Gastonia, North Carolina 28052 Phone: [phone]
Hours of Operation: Monday through Friday: 9:00 a.m. to 7:00 p.m. Saturday: 9:00 a.m. to 3:00 p.m. Sunday: Closed
3.5 Waste Management
Waste generated by site activities will be managed in accordance with processes described in Section 6.
3.6 Site Restoration
Site restoration activities will be performed to restore those areas disturbed by drilling and injection rig activity only. Site restoration will include soil raking and/or regrading so that the disturbed area drains,
grass seeding, and placement of straw material. Restoration activities will include the areas where chipping and shredding was completed for vegetation clearance. In areas covered by chipped and shredded trees and shrubs, reseeding is not required, but the chipped and shredded material should be
leveled to not exceed an average thickness of 4 inches.
3.7 Demobilization
Upon completion of field activities, all personnel and equipment will be decontaminated and, along with
any support facilities, will be demobilized from the site.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-1
4. Contingency Plan and Emergency Response Plan
This section outlines emergency response procedures and supplements the HASP. The elements included
in this emergency response plan will be reviewed by field staff before work commences. The purposes of this emergency response plan are as follows:
 Supplement the site-specific HASP.
 Minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or gradual release of hazardous waste constituents or polluting materials to air, soil, or surface water.
 Summarize procedures and instructions to efficiently respond to an emergency.
 Provide a document that all team members (including new team members) can use easily, which includes emergency contacts, inclement weather procedures, and emergency equipment supplies.
 Comply with the requirements of 40 Code of Federal Regulations (CFR) 262.16(b)8-9 for a small-quantity generator, including, but not limited to, Contingency Planning, Emergency Response Procedures, and Preparedness and Prevention. Should the facility become a large-quantity generator, this plan will be revised.
4.1 Site-specific Training and Orientation
The PM and RHSM are responsible for ensuring the site personnel are properly trained and that a site-specific orientation for all personnel has been completed before work is conducted under this TO.
Training will ensure that employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies.
4.2 Pre-emergency Planning
By using pre-emergency planning, as well as the other practices described in this document, the facility will minimize the possibility of a fire, explosion, or any unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water that could threaten human
health or the environment.
The SSL will perform the applicable pre-emergency planning tasks before starting field activities, as follows:
 Confirm staff working onsite have applicable phone numbers (emergency phone numbers and site personnel phone numbers) preprogrammed into their personal cell phones before commencing site work.
 Identify chemical, safety, and biological hazards, and discuss with site personnel.
 Confirm and post emergency telephone numbers and a map of the route to the hospital as specified in the HASP.
 Post the site map, marked with locations of emergency equipment and supplies.
 Review emergency response plan for applicability to any changes in site conditions, alterations to field activities, or personnel availability as specified in the HASP.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-2
 Place hospital directions and map inside each vehicle for emergency use. Keep keys accessible during field activities.
 Inventory and check site emergency equipment and supplies.
 Review emergency procedures for personnel injury, exposures, fires, explosions, and other potential hazards to field personnel as specified in the HASP.
 Verify local emergency contacts, hospital routes, evacuation routes, and assembly points.
 Drive route to the hospital.
 Review the names of onsite personnel trained in first aid and cardiopulmonary resuscitation (CPR).
 Review the notification procedures for contacting EQ CH JV’s medical consultant and team
members’ occupational physicians.
 Brief new workers on the emergency response plan, spill management, and reporting procedures.
4.3 Emergency Coordinator
The SSL will be the designated emergency coordinator, available to respond to an emergency by reaching the facility within a short period of time, and responsible for initially coordinating the emergency response measures specified as follows and in subsequent sections.
The emergency coordinator or their designee must respond to any emergencies that arise. The applicable responses are as follows (and further described in Sections 4.14 through 4.16):
 In the event of a fire, call the fire department or attempt to extinguish it using a fire extinguisher.
 In the event of a spill, contain the flow of hazardous waste to the extent possible, and as soon as is practicable, clean up the hazardous waste and any contaminated materials or soil. Such containment and cleanup can be either self-performed or performed by a contractor.
 In the event of a fire, explosion, or other release that could threaten human health outside the facility or when a spill has reached surface water, immediately notify the EM, who will contact the National Response Center (using their 24-hour toll free number 800-424-8802). The report must include the following information:
– The name, address, and EPA ID number of the small-quantity generator
– Date, time, and type of incident (for example, spill or fire)
– Quantity and type of hazardous waste involved in the incident
– Extent of injuries, if any
– Estimated quantity and disposition of recovered materials, if any
4.4 Emergency Equipment and Supplies
During field activities associated with this TO, all vehicles being used will have the following:
 ABC fire extinguisher
 First aid, bloodborne pathogen, and eyewash kits (stored in field vehicles)
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-3
 Cell phones for each field person for summoning emergency assistance and for use as an internal communications system capable of providing immediate emergency instruction
 Larger eyewash kits and chemical shower stations during active injections as required by the
site-specific HASP
 Spill response equipment and supplies, including oxidant neutralization supplies during injection activities, as required by the site-specific HASP
 Water at adequate volume and pressure to supply water hose streams, foam-producing equipment, automatic sprinklers, or water spray systems.
Communications, fire protection equipment, spill control equipment, and decontamination equipment, where required, will be tested and maintained as necessary to assure proper operation during an emergency.
Personnel will have immediate access (that is, direct or unimpeded access) to a cell phone, either directly
or through visual or voice contact with another employee.
4.5 Arrangements with Local Authorities
Attempts will be made to make emergency response arrangements with the local police department, fire
department, other emergency response teams, emergency response contractors, equipment suppliers, and hospitals, considering the types and quantities of hazardous wastes handled at the facility. Arrangements may be made with the Local Emergency Planning Committee if it is determined to be the appropriate
organization with which to make arrangements.
As part of this coordination, attempts will be made to make arrangements, as necessary, to familiarize the listed local authorities with the layout of the facility, the properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility, and possible evacuation routes, as well as the types of injuries or illnesses that could result from fires, explosions, or releases at the facility.
Where more than one police or fire department might respond to an emergency, attempts will be made to designate primary emergency authority to a specific fire or police department and support authority to any
other departments.
Records will be maintained documenting the arrangements with the local fire department as well as any other organization necessary to respond to an emergency. This documentation must include documentation in the operating record that either confirms such arrangements actively exist or, in cases in which no arrangements exist, confirms that attempts to make such arrangements were made.
4.6 Emergency Medical Treatment
The SSL will assume charge during a medical emergency until an ambulance arrives or the injured person is admitted to the emergency room. The following procedures will be implemented:
 Prevent further injury.
 Initiate first aid and CPR if necessary.
 Call the ambulance and hospital.
 Determine if decontamination will make injury worse.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-4
 Make certain that the injured person is accompanied to emergency room.
 Notify the PM, who will be responsible for notifying the RHSM.
 Perform other actions as directed by the PM and RHSM.
4.7 Evacuation
Evacuation routes will be designated by the SSL before beginning work. In the event of an evacuation, the SSL will assume charge of the situation as follows:
 Evacuation routes will be designated by the SSL before beginning work.
 Onsite and offsite assembly points will be designated before beginning work.
 The SSL and a “buddy” will remain onsite after the site has been evacuated (if possible) to assist local
responders and advise them of the nature and location of the incident.
 The SSL will account for all personnel in the onsite assembly zone.
 A person designated by the SSL (before work) will account for personnel at the offsite assembly area.
 The SSL will collect and prepare information (such as photos and notes) for submitting an incident report. The incident report will be prepared as soon as possible after the incident occurs and submitted to the RHSM.
4.8 Working Alone
It is unlikely work will be completed by personnel working under a “lone worker” scenario. However, if deemed necessary and appropriate to have a lone worker situation, all staff will be required to follow the
lone worker provisions of the HASP and notify the PM or PM designee of their status at the onset of work, at 2-hour intervals during work completion, and at the end of the workday.
4.9 First Aid Medical Information
One person who is trained in first aid and CPR will be onsite during all field activities. The SSLs are trained in first aid and CPR and will be responsible for first aid during emergencies. The SSLs will review the names of trained personnel, note them at the health and safety briefings, and designate a trained
individual for those occasions when the SSL is not onsite.
In the event of an emergency, the information noted on the Emergency Response Numbers form will be provided to the emergency response provider.
4.10 Route to Hospital
The nearest hospital is the CaroMont Regional Medical Center, as shown on Figure 4-1. Directions are as follows:
Depart: Gastonia Industrial Truck Inc, 5009 Hemphill Rd, Gastonia, North Carolina 28056
1) Head north on Hemphill Road toward Benfield Road, 0.4 mile
2) Turn right onto Little Mountain Road, 1.3 miles
3) Bear left onto Robinson Road, 0.6 mile
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-5
4) Turn left onto North Carolina Highway 274 (NC 274)/Union Road, 0.3 mile
5) Turn right onto Robinwood Road, Marathon Gas – Times Turn Around 22 on the corner, 0.9 mile
6) Turn left to stay on Robinwood Road, 2.0 miles
7) Turn left onto Babington Drive, 0.2 mile
8) Turn left onto NC 279/South New Hope Road, 0.8 mile
9) Turn right onto U.S Route 29 (US 29) North/US 74/ East Franklin Boulevard, then immediately bear
right onto Aberdeen Boulevard, 1.1 miles
10) Turn left onto Hospital Drive, 495 feet
11) Keep straight to get onto road, 0.1 mile
12) Turn right, 505 feet
13) Arrive at your destination on the left; the last intersection before your destination is Aberdeen Boulevard
Arrive: CaroMont Regional Medical Center, approximately 22 minutes
4.11 Emergency Numbers
Table 4-1 lists relevant emergency numbers.
Table 4-1. Emergency Numbers
Emergency Service Address Telephone
Ambulance Not applicable 911
Hospital CaroMont Regional Medical Center, 2525 Court Drive, Gastonia, North Carolina 28054
704-834-2000
Police Department Gastonia Police Department, 200 East Long Avenue, Gastonia, North Carolina 28052
911
704-866-6880
Fire Department Gastonia Fire Department, 1335 Easy Ozark Avenue, Gastonia, North Carolina 28054
911
704-866-6806
Poison Control Center Not applicable 800-382-9097
When calling 911, be prepared to discuss the following questions:
 Who?
 Where?
 How many are injured?
 What is the nature of the injuries or illnesses and is first aid being administered?
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-6
4.12 Posting Emergency Information
The following information, at a minimum, will be posted next to the telephone or in areas directly involved in the generation and accumulation of hazardous waste:
 The name and emergency telephone number of the emergency coordinator
 The location of fire extinguishers and spill control material, and, if present, fire alarm
 The telephone number of the fire department, unless the facility has a direct alarm
4.13 Emergency Notification Procedure
An emergency can be an injury to a worker, evacuation, fire, environmental release, or other scenario. An unusual situation could involve equipment failures, work that is not being performed appropriately, or anything involving risk or exposure to the public. If an emergency or unusual situation is identified by an onsite worker, it is their responsibility to notify others of the situation. If an emergency or unusual situation occurs, emergency services will be notified, followed by notification to the PM as soon as conditions allow. Table 4-2 lists relevant emergency notification contacts.
Table 4-2. Emergency Notification Contacts
Name Work Telephone
Christopher Allen, PM Office: 404-978-7475
Cell: 770-733-6188
Blane Houck, SSL Office/Cell: 704-207-6072
Carl Woods, RHSM Office/Cell: 513 319 5771
Linda Colella, EM Office/Cell: 720-320-2590
Lisa Schwan, WM Office/Cell: 404-414-2505
Attempts to contact the PM, SSL, RHSM, EM, or WM must continue until at least one has been notified
of the situation and the status of emergency services, effect on the public, and any other pertinent information has been identified.
Communication with members of the press will be through the EPA TOCOR. The TOCOR will be
contacted by the PM as needed.
4.14 Severe Weather and Natural Disasters
Several types of natural disasters may occur during the work seasons. The crews and SSL will use the
following emergency steps for specific types of natural disasters. These disasters may include tornadoes, earthquakes, floods, and other severe weather.
4.14.1 Tornado
When a tornado warning is issued by sirens or other means, seek inside shelter. Consider the following:
 Seek shelter in small interior rooms on the lowest floor and without windows; hallways on the lowest floor away from doors and windows; and rooms constructed with reinforced concrete, brick, or block, without windows.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-7
 If nearby and accessible, seek shelter in known tornado shelters, such as police stations.
 Stay away from outside walls and windows.
 Use arms to protect head and neck.
 Remain sheltered until the tornado threat is announced as over.
4.14.2 Earthquake
In the event of an earthquake, take the following actions:
 Stay calm and await instructions from the SSL or the designated official.
 Keep away from overhead fixtures, windows, filing cabinets, and electrical power.
 Assist people as needed in finding a safe place.
 Evacuate as instructed by the SSL or the designated official.
4.14.3 Flood
If indoors during a flood, take the following actions:
 Be ready to evacuate as directed by the SSL or the designated official.
 Follow the recommended primary or secondary evacuation route.
If outdoors, take the following actions:
 Evacuate the area for higher ground.
 Avoid walking or driving through floodwater.
 If a car stalls, abandon it immediately and climb to higher ground.
4.14.4 Other Severe Weather
During inclement weather, take the following general response actions:
 Monitor the weather radio.
 Direct employees to sites and shelters, as required.
 Monitor continuation of power.
 Initiate snow removal and other winter storm procedures if the severe weather is a winter storm.
 Survey sites and operating systems for damage.
 Establish recovery operations as needed.
4.15 Fire, Utility, and Other Emergency Procedures
4.15.1 Fire
Whoever first discovers fire or smoke, regardless of its location, should immediately take the following
actions:
 Verbally raise the alarm.
 Dial emergency number 911.
 Clear anyone in immediate danger.
 Use a fire extinguisher, if trained and conditions are safe to do so; never attempt to put out a fire alone.
 Evacuate and walk calmly to the closest safe assembly point.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-8
To ensure the fastest, most accurate accountability, all staff and visitors should gather after evacuation at an assembly point. The SSL will document that all staff have been accounted for. The SSL will liaise with the fire department to confirm whether all staff and visitors from the office have evacuated the building.
The SSL will identify the names and last known locations of anyone (including visitors) remaining within the work area and give this information to the fire department.
4.15.2 Natural Gas Leak
If there is a gas leak or you smell natural gas, take the following actions:
 Cease all operations immediately.
 Turn off all equipment.
 Evacuate as soon as possible to the designated assembly point.
 Call 911 or the gas utility company.
 Notify the SSL.
4.15.3 Bomb Threat
This plan covers two possible scenarios in relation to bomb threats: (1) the presence of a suspect package
or bag found at the work site and (2) the receipt of a phone call to a member of staff indicating a bomb threat. Packages that could pose a bomb threat could be received through the mail system or could be unidentified packages or bags left in work areas. If staff finds a suspicious package, take the following
actions:
 Do not attempt to move or open the package.
 Report the situation to the supervisor and the SSL.
 Clear the immediate area of personnel.
 Make further inquiries regarding a possible owner.
 Note that the SSL will report the situation to the security staff or contact the police.
 Evacuate if told to do so.
In the event of receipt of a telephone call indicating a bomb threat, take the following actions:
 Be calm, be courteous, listen carefully, and do not interrupt the caller.
 Write down the caller’s message in its entirety and any additional comments.
 Treat all bomb threats as real.
 Report the situation to your supervisor and the SSL.
 Note that the SSL will contact the police and will report the situation to the PM and health and safety manager.
 Evacuate if told to do so.
4.15.4 Power Failure
In the event of a general power failure, take the following actions:
 Turn off all electrical equipment, except lighting.
 The SSL will contact the power company to determine the cause and estimated duration of power failure.
 Await further instructions.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-9
4.15.5 Theft
If any member of staff suspects that their premises or vehicles have been broken into or items are found to be missing, the SSL should be notified. The SSL will immediately contact the local police.
4.15.6 Criminal or Violent Behavior
If an armed attacker is in the area, take the following actions:
 Stay calm and signal for help. Alert anyone when possible or send someone to alert other occupants if
safe to do so.
 Call 911 and say “Police” when answered.
 If faced with demands from the attacker, comply.
 Recognize that sudden movements may prove fatal. Move with caution.
 Become invisible. Take cover behind a door, file cabinet, or other furniture.
 Try to notice the attacker’s distinguishing traits, which may be important for further investigations: clothing, ethnicity, weight, age, hair color, presence of facial hair, type of weapon used, voice, and presence of accent.
 When police arrive, follow their directions.
 Do not discuss the situation with anyone other than the police and internal staff.
4.16 Spill Management and Reporting
4.16.1 Spill Management Procedures—Water
If spills occur during field activities, implement the following procedures:
 Estimate the quantity of release, document the situation, and notify the PM. The PM will notify the EM. The EM must be notified before reporting to any government agency.
 Clean up the spill, if possible and if it can be done safely, using spill-kit materials and resources.
 Note that if spill management is beyond the capabilities of the field staff, then the PM will contact emergency response personnel to ensure the spill is cleaned up as soon as possible and will take steps to ensure that the failed container is replaced immediately and documented.
 Note that the PM will contact the EM within 15 minutes of the release and be responsible for ensuring the spill is properly documented and reported.
 The EM will determine if a spill or release is reportable to any agency.
 The WM will advise on characterization and disposal of affected media.
EQ CH JV will verify that the subcontractors have taken precautions to prevent spills and a satisfactory plan and equipment for responding to spills.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 4-10
4.16.2 Spill Documentation and Reporting
Spills will be documented in the field daily notes, which will be provided to the EM. The EM may require information in addition to what is described and will provide advice about reporting obligations. In the event of
a reportable spill, a spill report will be prepared. The report will, at a minimum, include the following:
 Description of the material spilled (including identity and quantity)
 When and to whom the spill was reported
 Time, location, and a description of the area involved
 Receiving stream or waters, including ephemeral streams, storm drains, or drainage ditches
 Cause of the spill and the equipment and personnel involved
 Injuries or property damage
 Containment procedures initiated
 Summary of contact with government agencies, contracting officer, engineer, or owner
 Description of the cleanup procedures employed or to be employed, including the disposal location of contaminated material
 Description of actions to be taken in the future to prevent reoccurrence of the spill
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 5-1
5. Environmental Compliance and Controls
This section outlines the general process, procedures, and safeguards used to comply with environmental
regulations and to prevent contaminants or pollutants from being released offsite during the implementation of field activities. During field activities, the field team leader is responsible for ensuring tasks are conducted according to the site-specific plans and procedures. The project organization structure
and description of management responsibilities will be provided, with additional details, in the updated UFP-QAPP. This plan assumes no disturbance to wetlands, no construction of access roads, and no locations warranting a cultural resources evaluation due to the limited scope of the disturbance.
5.1 Chemical Storage and Use
5.1.1 CERCLA and EPCRA Reportable Quantity and Associated Spill Reporting—Potentially Applicable
The CERCLA and Emergency Planning and Community Right-to-Know Act (EPCRA) reportable quantity (RQ) is the amount of a chemical that triggers a report to a regulatory agency when released. The definition of release may vary depending on location and circumstance. Other spill reporting requirements
may also apply and affect spill reporting. CERCLA spill reporting is required by law in CERCLA Section 103 and as detailed in regulation 40 CFR 302. There are five specific conditions that must be met to trigger the CERCLA requirement for notifying the National Response Center (NRC):
 A release has occurred.
 The substance released was hazardous.
 The amount of substance released equals or exceeds an RQ.
 The substance was released from a vessel or facility.
 The release occurred within a 24-hour period.
CERCLA excludes petroleum products from the definition of a CERCLA hazardous substance. The Clean Water Act, however, includes petroleum substances as reportable, with a reporting threshold of any amount that threatens a surface water or the presence of a sheen.
Spills should be reported to the project EM immediately for assistance (refer to Section 4 for emergency contacts).
5.1.2 EPCRA Reporting Requirements
EPCRA does not place limits on which chemicals can be stored, used, released, disposed of, or transferred at a facility. It only requires a facility to document, notify, and report information. Each section of EPCRA applies different requirements, has different deadlines, and covers a different group of chemicals.
5.1.2.1 Emergency Release Notification (Section 304)
A facility may be subject to the reporting requirements even if it is not subject to the provisions of EPCRA Sections 301 to 303. A facility must report a release of an extremely hazardous substance or a CERCLA hazardous substance in quantities equal to or greater than the RQ. The releases are reported to the Local Emergency Planning Committee (LEPC), State Emergency Response Commission (SERC), or local emergency response personnel within 15 minutes, with follow-up required within 30 calendar days.
If the amount of a chemical released to the environment exceeds the RQ, the facility must immediately
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 5-2
report the release to the appropriate LEPC and SERC and provide a written follow-up statement as soon as practicable. Contact information for the National Response Center, LEPC, and SERC (North Carolina Division of Emergency Management) is provided in Section 4 of the Spill Control Plan.
For an EPCRA Section 304 notification, the following criteria apply:
 A release has occurred with the potential to affect offsite persons.
 The substance released was a hazardous substance or extremely hazardous substance.
 The amount of substance released equals or exceeds an RQ.
 The substance was released from a vessel or facility where a hazardous substance or extremely hazardous substance is produced, used, or stored.
 The release occurred within a 24-hour period.
Immediate notification must include the following:
 The name of the chemical
 The location of the release
 Whether the chemical is on the “extremely hazardous” list
 How much of the substance has been released
 The time and duration of the incident
 Whether the chemical was released into the air, water, or soil, or some combination of the three
 Known or anticipated health risks and necessary medical attention
 Proper precautions, such as evacuation
 A contact person at the facility
In addition to immediate notification, facilities are required to provide a follow-up report, in writing, updating the original notification, providing additional information on response actions taken, known or anticipated health risks and, if appropriate, advice regarding medical care needed by exposure victims. Failure to notify the proper authorities may result in civil penalties of up to $55,000 per day for each day of noncompliance and criminal penalties of up to $55,000 in fines and prison sentences of up to 2 years.
A release that results in exposure to persons solely within the facility boundary or a release that is
federally permitted does not have to be reported. In addition, continuous pesticide and radionuclide releases meeting specified conditions are exempt.
Potassium permanganate is a CERCLA hazardous substance with an RQ of 100 pounds.
5.1.2.2 Community Right-to-Know Safety Data Sheet and Tier I/II Reporting Requirements (Sections 311 and 312)
The purpose of the requirements is to increase community awareness of chemical hazards and to facilitate emergency planning. This section applies to a facility that is required by the Occupational Safety and Health Administration (OSHA) under its Hazard Communication Standard to prepare or have available a
safety data sheet (SDS) for a hazardous chemical or that has for 1 day in a calendar year an amount of a hazardous chemical onsite equal to or greater than at least one of the following threshold limits established by EPA:
 For Extremely Hazardous Substances (EHSs) (40 CFR Part 355 Appendix A and Appendix B), the threshold level is either 500 pounds or the threshold planning quantity, whichever is lower.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 5-3
 For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely underground and was in compliance at all times during the preceding calendar year with all applicable underground storage tank (UST)
requirements from 40 CFR Part 280 or requirements of the state UST program approved by EPA under 40 CFR Part 281.
 For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicable UST requirements from 40 CFR Part 280 or requirements of the state UST program approved by EPA under 40 CFR Part 281.
 For all other hazardous chemicals, the threshold level is 10,000 pounds (equal to about 1,200 gallons or 22 drums).
40 CFR 370.12 defines “hazardous chemical” as anything that has an SDS. If a facility is subject to reporting under EPCRA Sections 311 and 312, it must submit information to the SERC, LEPC, and local fire department with jurisdiction over the facility. The required information falls under two categories:
(1) DS reporting and (2) inventory reporting.
5.1.2.3 Safety Data Sheet Reporting
SDS reporting requirements specifically provide information to the local community about mixtures and
chemicals present at a facility and their associated hazards. For substances with onsite quantities that exceed the threshold limits, the facility must submit the following:
 Initially, a copy of the SDS for chemical onsite above its threshold or a list of the chemicals grouped
into categories
 Within 3 months of a change, an SDS or list for additional chemicals that meet the reporting criteria
 Refer to submission details under North Carolina-specific Emergency Planning and Tier II Inventory
Reporting
5.1.2.4 Tier II Inventory Reporting
Inventory reporting is designed to provide information on the amounts, location, and storage conditions of hazardous chemicals and mixtures containing hazardous chemicals present at facilities. The inventory report has two forms. The Tier I form, the simpler of the two, contains aggregate information for applicable hazard categories and must be submitted yearly by March 1. The Tier I form is no longer accepted by most states. The Tier II form contains more detailed information, including the specific names of each chemical.
Tier II reporting is required for potassium permanganate I the quantity onsite is greater than or equal to 10,000 pounds. North Carolina uses E-Plan for electronic Tier II reporting submittals. The Tier II submittal will be made by the EM. An annual report is due by March 1.
5.1.3 Chemical Security Anti-terrorism Standards
The Department of Homeland Security (DHS) establishes Chemical Security Anti-terrorism Standards (6 CFR 27), which apply to facilities that possesses a chemical on the Chemical Facility Anti-Terrorism
Standard (CFATS) DHS Chemicals of Interest List. Applicable facilities must complete a Chemical
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 5-4
Security Assessment Tool top screen to further evaluate and identify applicable requirements within 60 days of the chemical arriving onsite.
Potassium permanganate requires a top screen submittal if the quantity onsite is greater than or equal to
400 pounds. The project EM is registered with the DHS and can prepare and submit the top screen submittal, or the subcontractor can submit the top screen submittal if they are appropriately registered with the DHS.
5.1.4 Fire Codes
Fire code requirements apply in three general categories:
 Hazardous chemicals with non-quantity-specific requirements
 Hazardous chemicals present in quantities that exceed the permitting threshold
 Hazardous chemicals that exceed maximum allowable quantities for the site usage (for instance, indoor/outdoor and open/closed use)
In addition, interactive chemistry concerns must be addressed by the engineer and designer based on knowledge of the chemicals and their interactive chemistry.
If the quantity staged onsite exceeds the fire permit threshold of the fire code requirements, a permit will be required from the local fire code official. Fire code requirements also apply for storage and use of chemicals at quantities less than the thresholds. Coordination is required with the fire department and includes providing requested information and obtaining a permit if the fire official requires it. Applications for a permit are made to the fire code official in such form and detail as prescribed by the fire code official. Applications for permits will be accompanied by such plans as prescribed by the fire
code official. The fire code official may require a hazardous materials management plan or hazardous materials inventory statement with a fire permit.
The fire permit threshold for potassium permanganate, a Class II oxidizer, is 100 pounds; however, a simple letter that includes storage and information (description of activities, time frame, chemicals, amounts stored, methods of storage, and SDSs) rather than a fire permit typically is sufficient for temporary storage and use of remediation chemicals.
Other fire code requirements for potassium permanganate storage and use include the following:
 Submit the informational packet to the local fire department a minimum of 2 weeks in advance of receiving the chemicals onsite, and determine if the department will indeed issue a permit.
 Ensure the staging area is 35 feet from property line.
 Keep the staging area clear of combustibles and vegetation within 30 feet.
 Segregate incompatible materials by at least 20 feet from the chemicals, and do not place them within the same secondary containment.
 Conduct secondary containment procedures.
 Ensure proper labeling of the chemicals with “oxidizer.” These are typically manufacturer-applied labels.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 5-5
5.2 Equipment Decontamination Procedures
Sampling equipment decontamination specifics are detailed in UFP-QAPP Field Standard Operating Procedure 6. Nondisposable sampling equipment used during field activities will be decontaminated by
washing with a phosphate-free detergent (for example, Liquinox) followed by a water rinse prior to reuse. Decontamination of down-hole drilling and injection equipment will be completed after each hole and allowed to dry at a designated decontamination pad constructed before use at another location.
All contaminated equipment will be cleaned until no contamination is visible before leaving the site. All equipment decontamination will be documented in the field logbooks. All wash waters will be containerized for offsite transportation and disposal. Groundwater sampling results will be used to
characterize the aqueous waste.
5.3 Noise Control
EQ CH JV will comply with the applicable local noise regulations. Truck idling will be minimized.
5.4 Clean Diesel Requirements
All diesel nonroad construction equipment and generators used onsite by EQ CH JV and its subcontractors for more than 10 calendar days will have either of the following: (1) engines meeting EPA Tier 2 or greater nonroad emission standards or (2) emission-control technology verified by the EPA for
use with nonroad engines to reduce particulate matter emissions by a minimum of 85%.
EQ CH JV and its subcontractors will properly maintain all diesel nonroad equipment and generators according to manufacturers’ recommendations.
During periods of inactivity, all diesel nonroad equipment and generators will meet minimum idle requirements at the state and local level.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-1
6. Waste Management Plan
The following sections detail procedures that will be followed for waste management.
6.1 Waste Streams
It is anticipated that waste streams will be generated and managed as indicated in Table 6-1. The project WM should be contacted for waste streams generated or anticipated to be generated that are not identified in Table 6-1.
Table 6-1. Waste Management
Waste Stream Source or Process Staged In Staged At Final Disposition
Soil and bedrock
cuttings
Drilling UN-approved, 55-gallon
steel drums or roll-off boxes
Designated RDW accumulation area (TBD)
Offsite disposal
Decontamination water, development water, and purge water
Well installation, development, and groundwater sampling
New, UN-approved, 55-gallon steel or poly drums or totes
Designated RDW accumulation area (TBD)
Offsite disposal
Contaminated debris,
including personal protective equipment plastic sheeting, disposable sampling equipment
Drilling,
injections, well development, and groundwater sampling
UN-approved, 55-gallon
steel drums or roll-off boxes
Designated RDW accumulation area (TBD)
Offsite disposal with soil or segregated
Accumulated rainwater and liquid in secondary containment
Precipitation or Secondary containment releases
Portable tanks or 55-gallon drums Secure onsite location Rainwater must be inspected and can be pumped to the ground if the liquid in the containment appears to be only
rainwater and appears clean. Such discharges must be documented in the Stormwater Pollution Prevention Plan.
If releases occur or if accumulated rainwater appears contaminated, containerize and dispose offsite.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-2
Table 6-1. Waste Management
Waste Stream Source or Process Staged In Staged At Final Disposition
Spill response materials, if applicable (such as neutralized soil and absorbent pads)
Spill response (including daylighting)
UN-approved, 55-gallon steel drums or roll-off boxes
Designated RDW accumulation area (TBD)
Offsite disposal with soil or segregated
Empty chemical drums and totes Empty drums and totes once containing potassium permanganate
Triple-rinsed totes and drums Designated RDW accumulation area (TBD)
Removal by subcontractor for proper recycling or disposal
Note:
UN = United Nations
6.2 Waste Characterization
In accordance with the Point of Generation regulations, available historical data will be reviewed prior to
installation of borings and generation of waste. Waste will be segregated from areas where there are known or suspected hazardous concentrations of contamination.
Soil and bedrock cuttings will be placed in new, UN-approved, 55-gallon drums or roll-offs and managed at a designated waste accumulation area. Samples will be collected from the segregated (suspected hazardous and nonhazardous) containerized waste within 30 days after generation or when drilling is complete.
Liquid waste including decontamination water, purge, and development water generated during well installation and sampling events will be contained in new UN-approved drums or totes and managed at a designated waste accumulation area. Liquids will be characterized based on the groundwater sampling results. Samples from the containerized liquids may be collected for waste characterization if additional analytical data are required for disposal. A disposal facility will be chosen based on the waste classification results.
Personal protective equipment and disposable sampling equipment generated (such as nitrile gloves, sample tubing, and core liners) will be properly contained for disposal in new, UN-approved, 55-gallon
drums or placed in roll-off boxes with the contaminated soil and transferred to the accumulation area.
Waste will be sampled, analyzed, and classified in accordance with 40 CFR Part 261 Subpart C. Generated waste is anticipated to include both hazardous and nonhazardous waste. No wastes generated at the site meet
the definition of a listed hazardous waste, as defined in 40 CFR 261 Subpart D. Wastes will be sampled and analyzed using appropriate SW-846 methods for the compounds listed in 40 CFR 261.24 Table 1. The toxicity characteristic leaching procedure extraction (SW-846 Method 1311) will be used for soils waste characterization. Wastes are assumed nonreactive by generator knowledge. The receiving disposal facility will be contacted to determine whether additional analyses will be required.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-3
6.2.1 Land Disposal Requirements
If a waste is determined to be hazardous, the applicable RCRA land disposal restriction standards for that waste will be identified. In general, hazardous wastes that will be land disposed of must meet certain
treatment standards (either a specified technology or a specified concentration). If applicable, land disposal restriction documents will be prepared and submitted with the profile or with the first load of waste delivered to the facility.
6.3 Waste Sampling Procedures
Analytical samples will be collected as discussed in the following subsections, as appropriate. Proper chain-of-custody procedures will be followed for waste characterization samples.
6.3.1 Liquids
Liquids will be characterized based on the groundwater sampling results. If the receiving facility requires additional analyses, samples will be collected from the 55-gallon drums or 275-gallon totes for analysis;
1 sample will be collected per 10 drums or 1 per tote.
The procedure for collecting water samples is as follows:
 Collect a water sample from each of the 10 drums using a peristaltic pump and appropriate tubing or a
bailer and composite into one sample (except for VOC analysis, which should be one single sample collected from the drum expected to have the highest concentrations).
 Fill the sample containers for volatile analyses first. Fill the 40-milliliter vials so there is no
headspace or bubbles in each vial.
 Fill the sample containers for the remaining analyses.
 Label and package the sample containers for shipment to the laboratory.
6.3.2 Soil
Soil samples will be collected according to the following procedures (potentially hazardous soil will be segregated from expected nonhazardous soil in containers and sampled separately):
 Procedure for collecting toxicity characteristic leaching procedure VOC samples:
– Retrieve a core from the selected sample location (drum or roll-off) with the highest photoionization
detector reading.
– Fill the appropriate sample jars completely, packed tightly with no headspace, with the sample
from the core.
– Close the jars, label them, and package them for shipment to the laboratory.
 Procedure for collecting nonvolatile samples:
– Place several spoonsful of soil from randomly selected drums into a stainless-steel bowl.
– Use a stainless-steel spoon and quartering techniques to homogenize the composite sample.
– Fill the appropriate sample jars completely with the homogenized sample.
– Close the jars, label them, and package them for shipment to the laboratory.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-4
6.4 Waste Accumulation Time Limit
The accumulation start date for solid waste is the date when waste is first placed into the container. The waste accumulation time will be generally limited to 90 days for all waste. Longer periods require review
and approval from the WM.
6.5 General Waste Management Requirements
Containers will be inspected upon arrival at the site for signs of disrepair or contamination and to verify the containers are empty and clean. If the container or associated equipment (such as roll-off tarp or bows) do not arrive in good condition, are contaminated, or are not empty, they will be rejected and documented. Upon arrival of the containers, existing damage (such as dings or significant paint scratches), if not significant enough to result in rejection, will be documented using photos and written documentation.
The requirements for waste management for different accumulation methods are outlined in the following subsections.
6.5.1 Requirements for Accumulating Waste in Drums and Small Containers
Requirements for accumulating waste in drums and small containers are as follows:
 Drums will be UN-rated and compatible with the contents.
 Drums for liquids or sludges will be new, UN-rated drums; reconditioned drums may be used only for dry solids.
 Open-head drums: Drum lids will be inspected to verify that the gasket is in good shape and that the lid will seat properly on the drum.
 Closed-head drums: Drums will be inspected to verify that the bung will close properly.
 The drums will be arranged in rows of no more than two drums, with at least 3 feet between rows to allow the visual inspection and unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment.
 Each container will be have its own label, and labels will be visible.
 Drums will remain completely closed, with all lids, covers, bolts, and locking mechanisms engaged, as though ready for immediate transport, except when removing or adding waste to the drum.
 Drums will be disposed of with the contents. If the contents are removed from the drums for offsite transportation and treatment or disposal, the drums will be decontaminated prior to reuse or before leaving the site.
 Drums containing hazardous waste will be provided with secondary containment.
 Empty drums will be marked with the word “Empty.”
 Drums will not be placed within 50 feet of a stormwater conveyance.
 Verify drums are filled three-fourths full for soil and with at least 6 inches of freeboard for liquids.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-5
6.5.2 Requirements for Accumulating Waste in Roll-off Boxes
The following guidelines relate to roll-off or sludge boxes that may be used onsite for the temporary storage of soils or other solid media prior to transport for offsite disposal:
• Boxes for contaminated waste will be provided with covers, bows, and disposable liners. Liners will be disposed of as contaminated debris.
• When not adding or removing waste, covers will be properly secured. Covers will be properly secured at the end of each workday.
• Old labels will be removed, and each box will be provided with its own label, which will be placed in a visible location. Multiple labels may be used for full visibility.
• Boxes will be inspected by the transporter after removing the liner and decontaminated in the event of evidence of liner failure.
• Free liquids may not be added to waste in a roll-off box.
• Saturated soils may be placed into roll-off boxes that are in secondary containment. Saturated soil will be immediately solidified.
• Boxes will be filled only half full or otherwise monitored to verify that they will meet DOT weight restrictions.
• Boxes will not be within 50 feet of a stormwater inlet or conveyance.
6.5.3 Requirements for Accumulating Waste in Totes
Requirements for accumulating waste in totes are as follows:
 Totes will have lids or covers.
 Totes will be UN-approved.
 Each tote will be labeled.
 Each tote will be provided with its own label, which will be placed in a visible location. Multiple labels may be used for full visibility.
 Totes will remain closed with lids or covers tightened, except when removing or adding waste to the tank.
 Totes will have secondary containment and may not be located within 50 feet of a stormwater inlet or
conveyance.
6.6 Labels and Tracking
Labeling and tracking procedures will be implemented as follows:
 Each container will be assigned a unique ID number and will be tracked through every step of the process managed by EQ CH JV staff using the Waste Tracking log.
 Waste containers will be labeled with one of the following labels. Until the waste is classified via
analytical data or generator knowledge, or both, the waste will be labeled as analysis pending. Once the waste is characterized by the WM, the waste labels will be changed to the appropriate label as soon as possible. Waste container labels are as follows:
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-6
– “Analysis Pending” or “Hazardous Waste Pending Analysis”—preprinted or handwritten label until analytical results are received and reviewed. This label will include the accumulation start date.

– “Non-Hazardous Waste”—preprinted labels with the following information:
• Shipper (generator name)
• Address
• City, state, Zip Code
• Contents (waste-specific information [for example, contaminated soil])
• Contact name and number

– “Hazardous Waste”—preprinted hazardous waste labels with the following information:
• Accumulation start date
• RCRA Waste Numbers/Codes
• Hazardous waste characteristics (toxic, ignitable, corrosive, reactive)
• Generator name and address
• EPA ID number
• Manifest tracking number (TBD)
• DOT proper shipping name
• DOT ID number

6.7 Inspection of Waste Accumulation Areas
Waste accumulation areas will be inspected and documented at least weekly for conditions that could result in a release of waste to the environment. Inspections will focus on container or containment
deterioration, or signs of leakage or discharge. Specifically, containers will be inspected for leaks, signs of corrosion, or signs of general deterioration. Secondary containment will be inspected for liner failures, berm failure, deterioration, or other issues.
Any deficiencies observed or noted during inspection will be documented and corrected immediately. Appropriate measures can include transferring waste from a leaking container to a new container, replacing the liner or cover, or repairing the containment berm.
Inspections will be recorded in the project logbook. Deficiencies and corrections will also be documented.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-7
6.8 Waste Transportation
Site personnel may transport nonhazardous waste to the RDW accumulation area. Hazardous waste may be transported within site property and on nonpublic roads. While transporting waste, the weight limits of
the vehicle or trailer used must be followed. Do not overload the vehicle or trailer. Spill kits will also be kept with the vehicles transporting waste. Containers used to transport will be labeled. If hazardous waste must be transported on public roadways, a licensed hazardous waste hauler will be utilized. Site personnel may not transport hazardous waste on public roads.
Requirements under 49 CFR 171 Code of Federal Regulations (CFR) 171 Collect a water sample from each of the 10 drums using a peristaltic pump and appropriate tubing or a bailer and composite into one
sample (except for VOC analysis which should be one single sample collected from the drum expected to have the highest concentrations).will apply to all offsite shipments of hazardous materials. Requirements specific to each hazardous material will be determined by the WM. It is the responsibility of a DOT-trained individual (the WM) to ensure that the requirements of 49 CFR 171 are met. Transporters may not mix or combine incompatible hazardous waste within a common container.
The trucks will be inspected to verify that the loads are secure, proper placarding is provided as
necessary, and shipping documentation is accurate. Waste will be tracked on a Waste Tracking log on the project SharePoint site. An example log form is included as Appendix A.
6.9 Transportation and Disposal Documentation
Before offsite disposal of nonhazardous waste, EQ CH JV will review the waste approval package for each waste stream. This package will include a waste profile naming the EPA as the generator of the waste, analytical summary table(s) applicable to the waste, a completed example waste manifest, any
other applicable information necessary to complete review of the disposal package, and signature as the generator. Profiles and associated documentation will be signed by the EPA. The signed profile will then be submitted to the disposal facility for acceptance and approval. Once the approval is received from the
disposal facility, transportation can be scheduled.
Prior to shipping any waste, draft shipping documents must be reviewed by the WM. All wastes will be shipped via the appropriate manifests for their designation (EPA Uniform Hazardous Waste Manifest or Non-hazardous Waste Manifest). Bills of lading may not be used for waste shipments. Once the manifest is reviewed and approved, preprinted manifests will be prepared for waste transportation.
EQ CH JV staff have the authority to sign waste manifests and land disposal restriction notifications on behalf of the Unites States Environmental Protection Agency.
The EQ CH JV designated representative and the transporter must sign the manifest before the load of waste leaves the site. A copy of the manifest will be retained in the project file. The original signed manifest will be returned to the agent for the generator (EQ CH JV).
6.10 Transporter Requirements
Offsite disposal trucks will be equipped with appropriate appurtenances (for example, liners and tarps) in acceptable working condition. All roll-off loads will be lined and covered before departure. Liners and covers will be properly secured and inspected to ensure the vehicles are not leaking or releasing waste
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-8
constituents from loading at the source site, along the haul route, and until offloading at the approved disposal site. Waste will be loaded in a designated area.
Each transportation vehicle and load of waste will be inspected before leaving the site and documented.
Loads will be inspected to ensure the loads are secure, proper placarding is provided as necessary, and shipping documentation is accurate. The quantities of waste leaving the site will be documented, at a minimum, on the Waste Tracking log. A transporter licensed for commercial transportation with a valid DOT number will transport nonhazardous wastes. A copy of the documentation indicating the selected transporter has appropriate licenses will be received and approved by EQ CH JV before transport of waste.
The transporter will observe the following practices when hauling and transporting wastes offsite:
 Minimize impacts to general public traffic.
 Repair road damage caused by construction or hauling traffic.
 Line and cover trucks used for hauling waste to prevent spills or releases.
 Verify that seals on trucks transporting liquids are in good condition.
 Decontaminate vehicles before reuse.
 Do not combine wastes or materials from other sites with wastes generated during the project.
Personnel involved in offsite disposal activities will follow safety and spill response procedures outlined
in the HASP.
6.10.1 Department of Transportation Requirements
Requirements under 49 CFR 171 will apply to all offsite shipments of hazardous materials. The
information contained in this section is provided as a general guide. Requirements specific to each hazardous material will be determined prior to shipment. A DOT-trained individual is responsible for verifying that the requirements of 49 CFR 171 are met. Transporters may not mix or combine
incompatible hazardous waste within a common container.
Shipping Name: Material that exhibits one of the nine DOT hazard class characteristics (explosives, gases, flammable liquids, flammable solids, oxidizing substances, toxics or poisons, radioactive materials, corrosive substances, or miscellaneous hazards) is regulated under DOT rules for the transportation of hazardous material.
Each shipment of hazardous material will be provided with a proper shipping name using the Hazardous
Materials Table in 49 CFR 172.101. All determinations will be made by DOT-trained personnel.
Packaging, Marking, and Labeling: The shipping name, hazard class, ID number, technical names (if
applicable), EPA markings and waste code numbers, and consignee and consignor designations will be marked on packages for shipment (49 CFR 172.301). Once a waste is characterized as hazardous, reference will be made to the Hazardous Materials Table in 49 CFR 172.101 to determine the appropriate label.
Placards: Appropriate placards will be determined by DOT-trained personnel. Specific placard descriptions are found starting in 49 CFR 172.521. If a placard is required, it will be affixed on each side and each end of the vehicle. Placards are not required for shipment of nonhazardous wastes.
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 6-9
6.11 Disposal Requirements
Offsite disposal facilities will use the waste profile and supporting documentation, such as analytical results, to determine if the facility will accept a waste. The disposal facility will be responsible for
providing a copy of the final waste manifest and for a certificate of treatment or disposal for each load of waste received. Wastes are expected to be disposed of as follows:
Nonhazardous soil and debris will be disposed of in a permitted RCRA Subtitle D facility (TBD).
Hazardous waste will be disposed of at a properly permitted RCRA Subtitle C facility (TBD).
Contaminated water will be disposed of offsite at a properly permitted disposal facility (TBD).
Uncontaminated or decontaminated materials may be sent to municipal landfills.
Wastes must be disposed of at facilities that are approved under the CERCLA Off-site Rule (40 CFR 300.440).
6.12 Training
Field personnel managing hazardous or potentially hazardous waste will meet the hazardous waste generator training requirements of 40 CFR 265.16 through the following:
OSHA 1910.120, Hazardous Waste Operations and Emergency Response, training, including theRemediation Waste Management Module from the internal EQ CH JV class
On-the-job training that includes the following:
–Site-specific HASP review—each site worker and guests must review and sign the plan
–Activity hazard analysis and daily “tailgate” meetings
–Project-specific review of this SMWMP
Dangerous goods shipping (internal class)
6.13 Recordkeeping
The following records and documents will be maintained:
A Waste Tracking log will be kept separately from the project logbook that contains the followingminimum information for each container as it is generated:
–A specific ID number corresponding to each container generated at the site (the container will bemarked with the same ID)
–The date that waste was first placed in the container (accumulation date)
–The profile number associated with the waste
–The date that the container was transported for final disposal and the name of the transportermoving the container
–Manifest number (offsite disposal only)
Transportation and offsite disposal records, including the following:
–Signed profiles and associated characterization data
–Initial manifests (generator and transporter) and facility-signed manifests
Training records
Inspection records
Site Management and Waste Management Plan Remedial Action Hemphill Road TCE Superfund Site Gastonia, North Carolina
230227225229_fb145dbb 7-1
7. References
EQ & CH Remediation Joint Venture (EQ CH JV). 2023. Technical Management Plan, Hemphill Road
TCE Superfund Site Remedial Action, Gastonia, North Carolina. January.
U.S. Environmental Protection Agency (EPA). 2018. Interim Action Record of Decision, Hemphill Road TCE Superfund Site, Gastonia, Gaston County, North Carolina, EPA ID NC0002374445. September.
U.S. Geological Survey (USGS). 2008. Hydrologic Setting, Ground-Water Flow, and Ground-Water Quality at the Langtree Peninsula Research Station, Iredell County, North Carolina, 2000-2005. Scientific Investigations Report 2008-5055.
Versar, Inc. (Versar). 2020. Final (100%) Remedial Design, Hemphill Road TCE Site, Gastonia, Gaston
County, North Carolina. July.
Figures
Figure1-2_Site_Layout
Hemphill Site
Gastonia City Limits
Streams
LEGEND
Figure_1-1_Site_Location_v2
Source: Versar, 2020. Final (100%) Remedial Design, Hemphill Road TCE Site, Gastonia, Gaston County, North Carolina.
Figure 1-1. Site Location
Hemphill Road TCE Superfund Site
Gastonia, Gaston County
North Carolina
LEGEND
Hemphill Site
Streams
Figure_1-2_Site_Layout_v2
Source: Versar, 2020. Final (100%) Remedial Design, Hemphill Road TCE Site, Gastonia, Gaston County, North Carolina.
Figure 1-2. Site Layout
Hemphill Road TCE Superfund Site
Gastonia, Gaston County
North Carolina
Unnamed T
r
i
b
u
t
a
r
y
Unnamed T
r
i
b
u
t
a
r
y
Unnamed T
r
i
b
u
t
a
r
y
Unnamed T
r
i
b
u
t
a
r
y
City Limits
Countour at 100 feet
Countour at 500 feet
Countour at 20 feet
Countour at 4 feet
Countour at 2 feet
LEGEND
Figure_1-3_Site_Topography_v2
Source: Versar, 2020. Final (100%) Remedial Design, Hemphill Road TCE Site, Gastonia, Gaston County, North Carolina.
Figure 1-3. Site Topography
Hemphill Road TCE Superfund Site
Gastonia, Gaston County
North Carolina
Unnamed T
r
i
b
u
t
a
r
y
U n n a m e d T r i b u t a r y
U n n a m e d T r i b u t a r y
Unnamed T
r
i
b
u
t
a
r
y
Figure_3-1_TCE_Source_Area_v2Figure 3-1. TCE Source AreaHemphill Road TCE Superfund SiteGastonia, Gaston CountyNorth CarolinaLEGENDSource: Versar, 2020. Final (100%) Remedial Design, Hemphill Road TCE Site, Gastonia, Gaston County, North Carolina.Residuum WellBedrock WellRD InvestigationTemporary WellsRI Temporary WellsPilot-scale Study Injection WellPilot-scale Study Temporary WellHemphill SiteTCE Source Areas > 300 μg/L300 μg/L300 μg/L300 μg/L
North Figure 4-1. Hospital Route Map
Hemphill Road TCE Superfund Site
Gastonia, Gaston County
North Carolina
Figure_4-1_Hospital_Route_Map_v2

Appendix A
Example Waste Tracking Log
EPA - Bunker Hill - ROM Cost EstimateDudley Reach Dredged Tailings Repository on CIAConceptual Quantities
No CADD Take-offsApprox Hand Calcs Only 2/10/2023 KJDQuantities based on assumed 540'x1080' rectangular cell with 4:1 slopes and 15' wide bench every 30' vertically (see cell size sheet)
Category Item Explanation Quantity Units Unit Cost Cost Reference SourceRepository ConstructionMobilization and Site Prep
Submittals/Implementation Plans (WP/HASP/QCP)Prepare project submittals including Work Plan, Health & Safety Plan, Quality Control Plan)1 LS 22,925.00$ 22,925$ Work plan, health and safety plan, permits, etc. Pricing based on RSMeans 01 31 13.20 (0140, 0220, and 0280)
Mobilization/Site Setup - Earthwork subcontractor Mobilization of personnel and equipment and Site Setup for Earthwork subcontractor 1 LS 34,200.00$ 34,200$
Pricing based on project similar in nature. Includes RSMeans Crews #B-1, #B-10T, #B-11Q, #B-12B, and #B-34E, plus Delivery of all heavy equipment
Mobilization/Site Setup - Liner subcontractor
Mobilization of personnel and equipment and Site
Setup for Liner Subcontractor 1 LS 24,750.00$ 24,750$ Pricing based on project similar in nature with subcontractor pricing.
Site Survey - Pre-Construction 1 LS 11,275.00$ 11,275$ Pricing based on RSMeans #01 71 23.13 (1200)
Remove and stockpile existing topsoil beneath
cell total liner area x 9" thick 188,444 CY $10.00 1,884,440$
This line item includes excavation and on site Hauling of soil near the Cover Area. Quantity of excavated materials estimated based on the area shown in Figure 1-1, to be revised during predesign investigation. Pricing is per RSMeans Crews #B-1, #B-10T, #B-12B, and #B-34E for
excavation and for hauling onsite.Access Road 24' top width, 2H:1V slopesRemoval of vegetation layer and topsoil Total area = 2700 LF x 32' wide @ 9"2,400 CY 12.70$ 30,480$ Pricing is per RSMeans #32 91 13.23 (1450)
Geotextile Total road = 2700 LF x 32' wide 9,600 SY 1.60$ 15,360$ Pricing is per RSMeans #31 32 19.16 (1550) Pit run sand and gravel Total road = 2700 LF x 1.5' thick 4,350 CY 25.00$ 108,750$ Pricing is from recent project similar in nature
CSBC Total road = 2700 LF x 0.5' thick 1,250 CY 35.00$ 43,750$ Pricing is from recent project similar in nature
Rough Grading / Final Grading Total area = 2700 LF x 32' wide 9,600 SY 1.50$ 14,400$ Pricing is per RSMeans #31 22 16.10 (1020)TESC
temporary cover over placed tailings each winter
assume temporary cover will eventually be equal in
size to entire area of tailings 752,400 SF 1.50$ 1,128,600$ Pricing is from recent project similar in natureCell Preparation Perimeter Berm -Pit run sand and gravel 12' top width, 5.5' deep, 2H:1V slopes, 3360 LF 23,271 CY 25.00$ 581,775$ Pricing is from recent project similar in nature
Geomembrane Liner - 60 mil HDPE,
Area depends on if perimeter berm material is considered contaminated or not and if eventual closure cover ties to liner inside or outside perimeter
berm. For this level calc, area set equal to outside dimension of perimeter berm.684,000 SF 2.00$ 1,368,000$ Pricing is from recent project similar in nature
(includes QC Testing)
Drainage Layer Concrete sand 43,200 CY 44.00$ 1,900,800$ Pricing is per RSMeans #04 05 13.95 (0200) plus RSM Crew #B-11Q
Filter Geotextile Over drainage layer 64,800 SY 2.80$ 181,440$ Pricing is per RSMeans #33 41 23.19 (0110) Interior temp drainage sumps, interior access berms/roads arbitrarily set at 10% of other cell preparation items??1 LS 403,202$ 403,202$ Pricing set at 10% of total cost for all other cell preparation items.Temporary runoff collection and treatment
6" HDPE pipe, anchored on existing surface
with sandbags 1,800 LF 19.30$ 34,740$ Pricing is per RSM #33 14 13.35 (0200)
Valve at upstream end 1 LS 1,420.00$ 1,420$ Pricing is per hdpesupply.com
Trenching and casing under bike path 1 LS 4,810.00$ 4,810$ Pricing is per RSMeans Crew #B-3B plus RSM #33 41 16.25 (2260)
Valve and sump at low point 1 LS 5,800.00$ 5,800$ Pricing is per hdpesupply.com plus RSM Crews #B-1 and B-12B for sump
Discharge to Lined Pond 1 LS 15,300.00$ 15,300$ Pricing is per RSM #01 54 33 (40-3230, -3280, -5650)Operation
Treatment at CTP
Vol ~ 684,000 SF X 30" rain/year X 3 years X 1.2 to
account for tailings drainage??44,323,200 gallon 0.08$ 3,545,856$
Calculation = 684,000 SF x 0.6 gal/SF for 1" of rainfall = 410,400 gal x 30" = 12,312,000 gallons x 1.2 = 14,774,400 gallons per year x 3
years
EPA - Bunker Hill - ROM Cost EstimateDudley Reach Dredged Tailings Repository on CIAConceptual Quantities
No CADD Take-offsApprox Hand Calcs Only 2/10/2023 KJDQuantities based on assumed 540'x1080' rectangular cell with 4:1 slopes and 15' wide bench every 30' vertically (see cell size sheet)
Category Item Explanation Quantity Units Unit Cost Cost Reference Source
Dredged tailings haul 25 miles R/T??, 300,000 CY bank measure X 1.25 swell??375,000 CY 15.00$ 5,625,000$ Pricing is per recent quote for trucking ($120/hour for an 18 cy dump truck with driver)
Tailings placement in cell Assume three staff, 2 dozers, full time for 6 (??) months for 3(??) years + 1 admin 18 MO 88,900.00$ 1,600,200$
Pricing is per RSM for 2 Equipment Operators and Admin person, plus Travel - Lodging and
M&IE, Modified D PPE, plus Rental of 2 each Bulldozers (Mo. rate), and diesel fuel Closure
Final grading Fine grading to drain 1 LS 108,500$ 108,500$ Pricing is per RSM #31 22 13.20 (0170) for grading of 17.25 acres
Site Surveying Services during construction 6 MO 11,275.00$ 67,650$ Pricing based on RSMeans #01 71 23.13 (1200). Estimate 5 days per month
60 mil HDPE cover added 10% to flat area to account for slopes 752,400 SF 2.00$ 1,504,800$ Pricing is from recent project similar in nature (includes QC Testing)
geocomposite drainage layer added 10% to flat area to account for slopes 752,400 SF 1.00$ 752,400$ Pricing is from RSMeans #33 41 23.19 (0170)
24" clean cover soil added 10% to flat area to account for slopes 55,733 CY $30.00 1,671,990$
Includes all material excavated as shown in Figure 1-
1, to be revised during predesign investigation.
Pricing is per RSMeans Crews #B-1, #B-10F, and
#B-11Q and includes purchase/delivery of cover soil.
compost amendment vol=4" over entire area??9,288 CY $50.00 464,400$
Pricing is per internet website for compost material
plus RSM Crew #B-11Q, travel - per diem, and vehicle
seeding and mulching added 10% to flat area to account for slopes 752,400 SF $0.12 90,288$ Pricing is per RSMeans #32 92 19.14 (5400) [total of 17.27 acres (752,400 sf)]
Final ditch construction for runoff control Assume ditch with permanent erosion control blanket on 3 sides of cell (2*1080 +540 LF)1 LS 39,180.00$ 39,180$ Pricing is per RSM #G1030 807 (1420)
Site Teardown and Demobilization
Site Survey - Post-Construction 1 LS 22,550.00$ 22,550$
Pricing based on RSMeans #01 71 23.13 (1200)
Site Teardown and Demobilization - Earthwork
subcontractor
Demobilization of personnel and equipment and Site
Teardown for Earthwork subcontractor 1 LS 17,100.00$ 17,100$
Pricing based on project similar in nature. Includes RSMeans Crews #B-1, #B-10T, #B-11Q, #B-12B, and #B-34E, plus Delivery of all heavy equipment
Site Teardown and Demobilization - Liner subcontractor Demobilization of personnel and equipment and Site Teardown for Liner Subcontractor 1 LS 14,500.00$ 14,500$ Pricing based on project similar in nature. Includes RSMeans Crews.
SUBTOTAL 23,340,631$
Contingency Contingency (15%)Contingency 1 LS 3,501,100$ 3,501,100$ Pricing based on project similar in nature. Includes RSMeans Crews. SUBTOTAL 26,841,731$
18,789,000$ 40,263,000$
Note 2: This ROM Cost Estimate does not include any cost for Project Management or Construction Management.
Note 3: This ROM Cost Estimate includes pricing per the RSMeans Heavy Construction Cost Reference Manual, estimator experience, estimator judgement, per projects similar in nature, historical pricing, and internet sources.
Note 1: This is a Class 4 Rough Order-of-Magnitude (ROM) Cost Estimate per the AACE Cost Estimate Classification, that is expected to be within the -30% to +50% accuracy range of the actual project costs.