Singer Furn_ RFI Work Plan-OCR

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REVIEW O~ lll'I WORK PLAN
SINGER FURNITO'RE COMPANY
LENOIR, NORTH CAROLINA
EPA I.D. NO. NCD000604322
sUBnTTED TO:
MS. ROWENA SllEFPIBLD
REGIONAL PROJECT OFFICER
U.S. ENV~RONHEN'l'AL PROTECTZON AGENCY
REGION IV
345 COO'R'?LANJ) STREET HE
ATLANTA, GEORGIA 30365
BtJBMl'l'TED BY:
A .. 1'. KEARNEY, IHC.
1100 ABERNATHY ROAD, SUITE 900
ATLAN'l'A, GEORGIA 30328-5603
IN RESPONSE 'l'O:
llPA CONTRACT HO. 68-Wt-0040
WOJl.lt ASSIGNMENT NO. R04•23-04
SEPTEMBER 1992
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SINGER FURNITURE COMPAHY
LENOIR, BOR'l'H CAROLINA
BPA I.D. NO. HCD00060,322
TABLE OF CONTENTS
GENERAL COMMENTS •••••••••••••••••••••••••••••••••••••••••••••
SPECIFIC DEFICIENCIES •••••••••••••••••••••.••••••••••••••••••
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SIHGEJl FOlUIITtJRB COMP.ANY
LENOIR, NORTH CAROLINA
BPA I.D. NO. NC0000604322
GENERAL COMHEN'l'S
singer Furniture Cotnpany (Singer} ·submitted a revised RF.I Work
Plan (RFI work Plan) in response to a number of technical
deficiencies noted in previOU$ Notices of Technical Inadequacy
(NTis) provided by the U.S. EPA, Region IV. The current revised
RFI Work Plan includes a cross-reference table (attached to the
end of this review) citinq locations where NTI concerns are
addressed in the RFI Work Plan. However, comparison of this
cross-reference table with the noted deficiencies and facility
responses indicates that the facility responded inadequately in a
number of instances. Specific technical inadequacies which were
not addressed sufficiently by the facility are discussed within
the Specific Comments section.
singer has proposed a phased approach for the RFI. This approach
may be used to perform additional sampling and analysis after
initial data acquisition and evaluation, but interpretation of
data acquired during the Phase I must not be postponed until
Phase II. The RFI Work Plan must be modified to include the
majority of the proposed Phase II tasks within Phase I.
The RFI Work Plan is much too general, and does not provide
sufficient detail oonoerninq proposed RFI assessment activities,
such as specific sample collection locations. Furthermore, the
facility provides very little environmental settinq information
(although these data are available), and apparently has not used
this information to develop the RFI Work Plan strategy. Because
the facility has not used available environmental setting
information to develop the RFI approach and does not indicate
that this information will be acquired/assessed during the RFI,
Singer has not assured that the RFI Work Plan approach will
sufficiently address RF! objectives. The R..F! must eitner provide
sufficient enviromnental setting information to interpret
contaminant occurrence/migration, or include plans to acquire
this information as part of the RFI. Modify the RFI Work Plan
according~y.
The Technical Approach and Sampling and Analysis Plan within
the RFI Work Plan are very general, and neither provides
sufficiently detailed information concerning the proposed RFI
tasks. These two sections of the RFI Work Pl.an must be modified
to speoif ically address the proposed assessment for each Solid
Waste Management Unit (SWMTJ). Furthermore, the sampling and
Analysis Plan has nQt includeQ requirements set forth in the
Region IV Environmental compliance Branch standard Operating
Procedures and Quality Assurance Manual (ECBSOPQAM).
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RFI implies that at least SWMU No . 3 is floored by an
undetermined thickness of saprolite upon bedrock;
should bedrock and overlying saprolite exhibit
openings/fractures (as bedrock often does), then
vertical/horizontal migration of hazardous constituents
could be significantly affected.
b. An analysis of any topographic features that might
influence the ground-water flow system must be
included.
c . Based on field data, tests, and cores, a representative
and accurate classification and description of the
hydrogeologic units which may be part of the migration
pathways at the facility must be acquired and presented
in the RFI Work Plan, including hydraulic conductivity
and porosity, lithology, vertical/horizontal hydraulic
gradient, and attenuation mechanism of the soil/aquifer
material. Within the RFI Work Plan text, discuss more
completely information provided in RFI Work Plan
Appendices, and indicate that any missing information
will be acquired as part of the RFI activities.
d . Discuss availa~le ground-water flow direction and rate
information, including that presented in Appendices VI
and VII.
e . Man-made influences that may affect site hydroqeology
must be evaluated. For example, both the Landfill and
Glue Evaporation Pond could have produced ground-water
mounding that would significantly affect contaminant
distribution, yet the RFI Work Plan fails to examine
this possibility.
The RFI Work Plan fails to include any discussion concerning
site soils, even thouqh some of this info:r.--mation is readily
available f r om local U.S. Department of Agriculture (USDA)
Soil Survey~. Since the facility propo~es to "phase" the
RFI and evaluate contaminant releases in the soil column
before performing ground-water assessments, it is ve-cy
important that the facility acquire and utilize all
available soil data. Provide the following information, or
indicate how these data will be acquired under the RFI
investigation:
a. Surface soil distribution;
b. soil profile, including American Society of
Testing Mater ials (ASTM) classification;
c. Transects of soil stratigraphy;
d. Hydraulic conductivity (saturated and unsaturated);
e . Relative permeability;
f. Bulk density;
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q. Porosity;
h. Soil sorptive capacity;
i. cation exchanqe capacity;
.j. Soil organic content;
k. Soil pH;
l. Particle size distribution;
m. Depth of water table;
n. Moisture content;
o. Effect of stratification on unsaturated flow;
p . Infiltration;
q . Evapotranspiration;
r . Storage capacity;
s . Vertical flow rate; and
t. Mineral content.
Alternatively, specifically identify those properties which
must be assessed to accomplis~ RFI Work Plan objectives,
indicating why evaluation of the other parameters is not
necessary.·
The facility briefly discusses local surface water features
but does not discuss required inf ormation listea in Appendix
B, Section II.A.3. of the Permit, does not indicate whether
this information will be acquired under the RFI, and does
not justify why thi$ information may not be necessary for
the RFI. Provide information concerninq temporal and
permanent surface water bodies near the facility as required
in the Perinit.
Project Hanaqeaent Plan (p. 3)
5. The facility provides little of the information required in
the Permit for a Project Management Plan. For example,
personnel are not specifically listed in the Project
Manaqement Plan or under the·Personnel section of the
Technical Approach. 'Furthermore, qualifications for people
(including contractors) ·performing or directinq the RFI are
not provided. The referenced schedule was not included in
the RFI Work Plan for review. Also, while the Technical
Approach was included in the Project Management Plan, the
over~ll management approach to the study was not provided.
Include this missing information, which the facility is
required to provide under the Permit.
Th• Technieal Approach (pp. '•5)
6. Sinc e t he Work Plan fails to provide ~he recr~ired
specificity concerning the propos~d RFI investigations
within any other sections of the RFI Work Plan, the
Technical Approach must Qe modified to include the required
detail. The Technical Approach currently prov ides only a
generalized discussion o! the intended progral\\ and fails to
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SlfXO Bo. 1 -014 Landfill (pp. '-9)
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12. In previous NTis, the facility was required to include a E ·1
diseussion of monitoring wells within the body of the text.
The RFI Work Plan does not include this information, but
instead references Appendices VI and VII to the Work Plan IJl
for the required data. While it is appropriate to provide II
detailed information in appendices or attachments, the body
of the RFI work Plan JIUlU include sufficient detail to IS ,
provide the reader an understanding of available technical • I
data. Modify the RFI Work Plan to include the required
detail, including a description of the generalized I
stratigraphic interval the wells are completed within.
13. The presentation format for Table l is unclear. Modify
Table l to pre.sent data on a minimum nulllber of pages which
clearly present the concentrations of each constituent.
Additionally, the RFI Work Plan must provide a summary
interpretation of data presented in Table l to denionstrate
an understanding of historical site conditions which
presUlllably affected the development of proposed RPI
activities. For example, data presented in Appendices VI
and VII imply that Well W-lB is downgradient of the
Landfill, and ground ~ater from this well contained
perchloroethylene (PCE) in the last sampling round •.
However, the significance of this contamination in
developing RFI activities has not been noted. The facility
has failed to indicate what this data might mean in terms of
either lateral or vertical contaminant distribution, even
though this information is readily available for
interpretation and must be used to develop the RF! strategy.
14. In the previous NTI, the facility was required to define the
conditions of the Landfill cap, amount of ero~ion,
permeability of the soil cover, and specific thickness of
soil cover relative to the Landfill. The facility proposes
an investigation to acquire ·some of this information, but
only states that a "significant thickness" of soils between
the bottom of the Landtill and ground water "does not
exist". Furthermore, the RFI Work Plan does not
specifically state that the required information will be
acquired durinq the soil cap investiqation. Prov.ide the
required intormation, or indicate that all of the required
data will be· acquired as part of the RFI.
15. The facility has indicated that seepage and soil ~alyses
will be performed at the Landfill, as required in previous
NTis. However, additional detail regarding the number,
.depth, type, etc. of soil samples to be collected is
required, as is significant detail concerning the seepage
samples (i.e., definition of a "set", number of seeps to be
sampled, how maximum volumes and rates of seepage will be
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19. The facility must consider the possibility that additional
~s may be buried below ground surface, since the origin
of the drums is unknown. Modify the RFI Work Plan to
address the possibility of performing a maqnetometer survey
in the drum burial area .following initial drum extraction.
20. The RFI work Plan indicates that releases to surface water
would occur through cross-media contamination via qround-
water discharge to surface water bodies. While cross-media
contamination may occur, overland flow from the drums to
adjoining surface water features is the more likely release
pathway. Modify the RFI Work Plan to indicate this.
Discuss in more detail how cross-media contamination via
ground water occurs.
21 . Specify how the facility will determine each type of waste
in the drums. The RFI Work Plan does not clearly indicate
the criteria which must be met for soil samplinq to occur,
implying that soil will not be sampled below intact drums,
and that soil will only be sampled if drum contents are in
contact with the soil. While chemical analysis of drum
contents must be performed to characterize the waste, all
soil below drums should also be sampled to determine whether
releases of hazardous constituents have occurred. Modify
the RFI Work Plan to indicate that soil below the drums will
be sampled, and provide a sampling qrid based upon the known
location of drums at the SWMU.
22. The facility has not provided any logical rationale for the
limited soil sample collection depth. Since the drums have
been present in the area for a number of years, it is highly
likely that vertical migration of contaminants has occurred.
Furtnermore, Table 1 of the RFI indicates that
trichloroethylene (TCE) and other dense nonaqueous phase
liquids (DNAPLs) could be present in 9round water in the
qeneral area (with no source defined). Therefore, it is
possible that the drums could have contained DNAPL material
which may not currently be present in the upper soil layer.
Sampling of the uppermost soil "crust" could result in
"missing" a release that is currently present at depth.
Modify the RFI Work Plan to include the proposed at-depth
sampling (Phase II) in Phase I, with approximately Jot of
the samples in the <Jt:id to be collect.ed from ground surface
to the water table. specify (and modify the sampling and
Analysis Plan accordinqly) that discreet samples will be
collected within a 1 foot sample interval, with samples
collected ever/ two feet (i.a., 0-1 feet, 3-5 feet, s-;
feet, etc.), to the water table.
23 . The RFI Work Plan must specifically indicate that all
required elements of the Sampling and Analysis Plan will be
followed in conformance with the ECBSOPQAM. For example, on
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are present in the mixture. Furthermore, the RFI Work Plan
does not discuss whether any glue chemistry changes have
occurred through time, or if the pond was ever used to hold
other waste material. Therefore, makinq performance of the
Phase I soil sampling dependent upon the occurrence of
formaldehyde in the current qlue-water mixture is
inappropriate because a variety of hazardous constituents
could be present in the current and historic glue-water
mixtures. Because of the uncertainty associated with
historical waste management practices and glue chemistry,
the RF! Work Plan inust be modified to indicate that soil
sampling will be performed, regardless of the hazardous
constituents present within the current glue-water mixture.
Modify the RFI Work Plan accordingly. Indicate that all
soil samples collected will be analyzed .for Appendix IX
constituents, unless the facility can demonstrate that
historical glue chemistry and waste management are well
understood.
31. The proposed soil satnplin9 associated with the Glue
Evaporation Pond is not adequate. The facility indicates
that it will Salllple "surficial" crust within the pond, but
provides no justification for this limited initial samplinq.
Furthermore, the facility does not discuss how vertical
contaminant distributiort may have been affected by unit
operation, therefore qoverninq vertical sample collection
depth. Therefore, collection of three surficial samples
alone during Phase I is not adequate. Modify the RPI work
Plan to include peripheral and at-depth soil sample
collection during Phase I to ensure full evaluation of the
potential hazardous constituents released from the unit.
The Phase II program may be modified to accomplish this by
increasing the number of samples collected within the pond
from one to three, and by indicating that at least four
peripheral samples wil l be collected around the basin from
ground surface to the water table. All samples must be
discrete (collection o~ samples at intervals of two feet is
appropriate). Also provide a map showing the proposed
sample locations.
32 . Although the majority of the proposed soil sampling should
be performed under Phase I, some activities could remain
under Phase II. Clarify whether ground-water monitoring
well installation is intended to remain under Phase II
activities.
33. "Continuance~ of soil sampling if contamination is detected
could be performed under modified Phase II activities once
the nature and initial extent of contaJDination has been
determined under Phase I. Modify the RFI Work Plan to
include these act~vities under Phase II. Also, specify that
all Phase II samples (soil and ground-water) will be
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47. Modify the Sampling and Analysis Plan to include site-
specific information for each SWMU so that any person
performing the RFI can use this plan when in the field .
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Appendix I, saaplinq and Analysi• Plan ·samplinq P~•qu•ncy _I
(p. ,3.2A)
48 . Paragraph 2 on this page is unclear, and has numerous J
incomplete sentences. Rewrite this par·agraph so that the .
intent of the in£ormation is clearly understood. Paragraph
3 is also unclear, as it does not indicate whether proposed j quarterly sampling will be performed and reported under the
RFI .. Clarify the sampling frequency in~ended .
~ppan4iz I, Saaplinq and Analysis Plan, sample containers all4 J
Preservation (p. 63.t)
49. Clarify the followinq statement in Paragraph 2: "The water j jl
will be analyzed for parameters associated with the bottle
type." Indicate whetheJ:" "laboratory pure water" is
equivalent to deionized or distilled water. Furthermore, 1 discuss the use of equipment blanks, and specify the nlll:Qber
of trip, equipment, a~d sample ~uplicates and media sampled
at this SWMU .
Appen4iz I, sampling and Analy•i• Plan, BqUipaent Decontaaination
(p. 63.1,)
so. Modify Paragraph 1 to read: "The bailers will be inscribed
with the identification of tbe sampling location to which it
is dedicated."
51. state specifically within Paragraph 2 whether the solvent
cleansing step will be omitted for containers intended for
VOC collection. Also indicate whether this procedure is
consistent with those required under 'the Region IV
ECBSOPQAM. .
52. The Technical Approach section of the RPI Work Plan must be
modified to collect all-ground-water samples and obtain
water levels during the same sampling event. While it is
appropriate to sample wells from "least contaminated" to
"most contaminated", this is generally performed after
contamination bas been addressed. The RPI Work Plan has not
indicated that any follow-up sampling and analysis of the
ground-water monitoring wells will be performed under this
RFI (althouqh quarterly samplinq is eluded to); therefore,
the technique of sampling from "least" to "most"
contaminated is not applicable. Clarify specifically
whether quarterly samplinq of qround-water monitoring wells
will be performed.
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47. Modify the Sampling and Analysis Plan to include site-
speeific information for each SWMU so that any person
performing the RFI can use this plan when in the field.
Appendiz I, Saapling an4 Analysis Plan Sa1tplia9 Frequency
(p. 63.2A)
48. Paragraph 2 on this page is unclear, and has numerous
incomplete sentences. Rewrite this paragraph so that the
intent of the informati~n is clearly understoOd. Paragraph
3 is also unclear, as it does not indicate whether proposed
quarterly sampling will be performed and reported under the
RFI •. Clarify the sampling frequency intended.
Appendi~ x, samplinq an4 Analysis ~lan, sample containers and
Preservation (p. 63.9)
49. Clarify the following statement in Paragraph 2: "The water
will be analyzed for parameters associated with the bottle
type." Indicate whether "laboratory pure water" is
equivalent to deionized or distilled water. Furthermore,
discuss the use of equipment blanks, and specify the number
of trip, equipment, a~d sample quplicates and media sampled
at this SWMU.
Appendiz I, Samplinq and Analy•i• Plan, Equipaent Deeont.amination
(p. ,3.16)
so. Modify Paragraph 1 to read: "The bailers will be inscribed
~ith the identification of tbe sainpling location to which it
is dedicated."
51. State specifically within Paragraph 2 whether the solvent
cleansing step will be omitted for containers intended for
VOC collection. Also indicate whether this procedure is
consistent with those required under the Region IV
ECBSOPOAM.
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52. The Technical Approach section of the RFI work Plan must be U
modified to collect all ground-water samples and obtain
water levels during the same sampling event. While it is
appropriate to sample wells from "least contaminated" to Ill
"most contaminated", this is generally performed after Ii
contamination haa been addressed. The RFI Work Plan has not
indicated that any follow-up sampling and analysis of the Ii
qround-water monitoring wells will be performed under this 6
RFI (although quarterly sampling is eluded to); therefore,
the technique of sampling from "least" to ":most"
contaminated is not applicable. Clarify specifically I .
whether quarterly sampling of ground-water monitoring wells
will be performed.
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Defici.ency
Nuabe~
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STaluation of Facility R••pon•• to April 1991
llotic• of ~ecbnical Inadequacy
X.1::u:•tion Addr•••ed. ia 1:echnieally A.T. J\••ru•r
!!:! w21:!5 Plan Adequate Co-eni: Humb!!r
YIM
Throughout y -
36 ... 51 y -
10, 41, 46, 51 Y* 6
Apoendix r, p. 63 Y* 43 ... 46
2A-2C N l .. 4
Map 2A N 1
6 y -
6 N 14
8 y -
8 y -
9 y -
37 N 21, 25
39 ff 27, 28
41 Y* 29
43, 44 N 30, 31
45 Y* ll
44 y -
49 N 39
49 N 40, 41
so Y* 42
50 Y* ll
63 .29 y -
63 .38 y -
38 y -
44 y• 30, 31
63.29-63.30 y -
*Modified to reflect original NTI requirement~, but must he changed again to
include revieione required in thie review.