NCD000770487_20030422_Johnson Controls Battery Group_FRBCERCLA RA_Remedial DesignRemedial Action Work Plan 2002 - 2003-OCR

►
North Carolina •
Department of Environmenr and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. ~1atthcws, Interim Director
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
6 l Forsyth Street, l i'th Floor
Atlanta, Georgia 30303
April 22, 2003
RE: Comments on the Draft Work Plan/Proposal
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores:
The Draft Groundwater Sampling Work Plan, dated March 21, 2003, for groundwater
at the Johnson Controls Battery Facility, located in Winston-Salem, NC has been received
and reviewed. The following comments by the North Carolina Superfund Section are
I . •
submitted for your consideration. Please Provide a Final Groundwater Sampling Work Plan
prior to mobilization _next Tuesday April 29.
Specific Comments:,
I. The second paragraph on page I of the report states that PCB and SVOCs were excluded
from the list of !groundwater analytes based on the first round of sampling results.
Monitoring well MW-01 should include analysis for SVOCs since it contained bis(2-
ethylhexyl)phthalate in the first round results. Phthalates are generally associated with
field or lab contamination due to contact with the rubber gloves used. SVOCs should
also be included in the parameters list under B. on page 2. Those doing the san1pling
should be instructed not to touch the water samples or the interior of the lids or sample
bottles during sampling and analysis. Please make appropriate corrections.
2. The sample schedule should be in spring of 2003 rather than spring 2002.
1646 Mail Service Center, Raleigh, North Carolina 27699-l646
Phone: [phone] \ FAX: [phone] \ Internet: ,vv-·w.enr.state.nc.us
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
-..
Mr. Luis Flores
4-22-2003
Page 2 of2
• •
The State apprcciate,s the opportunity to comment on this document and we look forward to
working with you on the project. If you have any questions or comments, please call me, at
(9 I 9) 733-280 I, extension 341 or email at randv. mccl vccnw)ncmai I.net.
Sincerely, c r j
'9}~ i ~. -~)t£Jl.Q.Q«
Randy_McE!veen · \
cc: Dave Lown, N.C. Superfund Section
Environmental Engineer
NC Superfund Section
,,,., ....
North Carolina • ,. • Department of Environment ~nd Natural Resources
Division of Waste Manageni~nt I
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Christopher Preston
ENTACT, Inc.
1360 North Wood Dale Road
Suite A
Wood Dale, lllinois 60 I 9 I
September 23, 2002
RE: Conditional Approval of the Revised Final Removal Design/Removal Action Work
Plan for the Johnson Controls Battery Group, Inc. (JCBG) Superfund Site
NCD 000 770 :487
Walkertown, Forsyth County, North Carolina
Dear Mr. Preston:
The Revised Removal Design/Removal Action (RD/RA) Work Plan insert pages, dated
September 2002, for the Johnson Controls Battery Facility, located in Walkertown, NC
have been received and reviewed. The NC Superfund Section approves the Revised
RD/RA Work Plan remedy, subject to the following conditions.
I, The State is in the process of finalizing the RCRA container design for staging and
treatment of the TCLP contaminated soils and sediment. State RCRA personnel are in the
process of evaluating an acceptable container design for general use throughout the State
for CERCLA Removal/R~medial Actions. Presently it appears that such a design will be
available this Wednesday September 25, 2002. The NC Superfund Section will fax or
mail a copy of a North Carolina Treatment Staging containment area design as soon as we
receive it from the RCRA, Section of DENR. This design should be constructed at the
site for staging and treatment of hazardous waste.
2. The State also request that ENT ACT continue to work with the Sediment and Erosion
Control Section of the City and State to assure that substantive requirements are met in
the design. Please assure that some time before or during the Removal Action process the
NC Superfund Section receives a concurrence letter or a copy of the Sediment and
Erosion Control permit for the work at the Johnson Controls Battery Group Site.
1646 M~il Service Center, Raleigh, North Carolina 27699-1646
Phone: 919-733~4996 \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER-50% RECYCLED/ 10% POST CONSUMER PAPER
....
Mr. Luis Flores
9-23-2002
Page 2 of2
• ' •
3. As we discussed in a recent conference call with Luis Flores, the public notification Fact
Sheets should be provided to the adjacent property owners prior to start of work.
If you have any questions or comments, please call me, at [phone], extension 341or
email at [e-mail].
Sincerely, \(J\
~ -~,.1)\R~
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Dave Lown, N.C. Superfund Section
-North Carolina • Department of Environment ,and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV .
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
September 17, 2002
&-!4;}\ -_ .. ,, m ,,;,.-, ___ _
NCDENR
RE: Comments on the Revised Final Removal Design/Removal Action Work Plan Insert
pages and language addressing the States comments
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores:
The Revised Removal Design/Removal Action Work Plan insert pages, dated 10
September 2002, for rill media of concern at the Johnson Controls Battery Facility, located in
Winston-Salem, NC tias been received and reviewed. The following comments by the North
Carolina Superfund Section are submitted for your consideration. Please have the JCBG
contractor provide additional pages and inserts as needed based on these comments. The
State will provide a final approval letter to the JCBG's contractor and copy the EPA when
appropriate corrections have been made and insert pages provided. JCBG representatives
should take care to properly order the pages and identify which State comment they address.
General Comments
I. The cover sheet for the notebook was not provided with the revised pages. The cover
sheet should be revised to read 'Final RD/RA Work Plan for the JCBGI. . .'etc. and
should include the revision date (September 2002).
2. The headers for all new inse11 pages should be revision I, September 2002. Please
resubmit with appropriate header changes.
3. The State is still in the process of finalizing the RCRA container design for staging and
treatment of the TCLP contaminated soils and sediment.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: 9 I 9-733-4996 \ FAX: [phone] \ Internet: www .enr.state.nc.us
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
Mr. Luis Flores
9-17-2002
Page 2 of3
•
Specific Comments
•
4. The first paragraph on page 26 does not designate the excavation depth for additional soil
located near the building and part of the sentence is left out (original comment #6).
5. The sediment and erosion control plans as discussed on page 36 are still not provided in
Appendix G and no explanation is given in the cover letter.
6. The last paragraph on page 4 of Section 2 states that the groundwater will not be
addressed before 6 months after completing the soil removal action. The groundwater
should be addressed as soon as possible after the soil removal process is completed. 6
months is too long to wait before addressing this aspect of the Site. This is especially true
at a Removal site., The word 'months' is miss-spelled in this paragraph.
'
7. The text of insert page 8-9 of Section 3.0, Appendix C, does not match up with original
page JO. Please resubmit insert pages I through 19 of Appendix C with corrected page
numbers and assure that the text matches-up.
8. The confirmation sampling procedure described at the bottom of page 11 is not consistent
with the original States comment #17 or sufficiently detailed. At a minimum one
composite sample should be collected from one container at the back of the facility in the
former unloading dock area and one composite sample should be collected from a
container at the sediment Basin #I area. This sampling pertains to TCLP hazardous
waste that has been treated. It is more appropriate to specify the areas which should be
sampled since less than 350 cubic yards ofTCLP hazardous soil is present at the site.
The more difficult areas of any container to mix are the bottoms and the sides. One
aliquot should be collected from each side of the container and a minimum of 2 aliquots
from the bottom of the container.
9. The Draft FSAP corifirmation sampling drawings provided in Appendix C appear
sufficient for the purpose. If additional changes are made to the FSAP drawings or any
other sections of the Work Plan, please notify the agencies in writing and clarify the
changes in the letter.
JO. Insert pages 1-5, 1-6, 1-9 and 1-10 were provided but no changes were made except the
header date and revision#, Were changes supposed to be made to these pages? If so
please provide the changes in the next submission.
11. The additional soil samples to be collected along the edge of the proposed excavation
areas as shown on drawings FSAP-1 through FSAP-4 and discussed in Section 02062,
Contaminated Soil and Sediment Treatment, Part I of Appendix E, should be located
between the EE/CA,investigation samples for best coverage of the areas.
Mr. J,uis Flores
9-17-2002
Page 3 of 3
• •
12. The public notification Fact Sheets should be provided to the adjacent property owners
prior to startup of work.
The State appreciates the opportunity to comment on this document and we look forward to
working with you on the project. If you have any questions or comments, please call me, at
[phone], extension 34lor email at [e-mail].
cc: Dave Lown, ~.C. Superfund Section
~~k~·1M0~
Randy McElveen
Environmental Engineer
NC Superfund Section
Sep-12-02 02:24.om from-North 'fund +404 5621.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4 .
Mr. Randy McElveen
NCDENR
ATLANTA FEDE.RAL CENTER
61 FORSYTi-l STR!cET
ATLANTA, GEORGIA 30303-8960
September 12, 2002
T-950 P 002/002 f-132
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Via fax and Fedei,:
SUBJ: RD/RA Work Plan Partial Approval
Johnson Control Battery Group Site
Walkertown, North Carolina
Dear Randy:
EPA has reviewed replacement pages dated September 10, 2002, for the Draft RD/RA
work plan and determined that all EPA's comments were addressed satisfactorily. As we
discussed, El'A is issuing a letter to Johnson Controls partially approving the RD/RA work plan.
The final RD/RA work plan approval letter should be issued by the State after all State's
comments have been addressed satisfactorily.
EPA's official RD/RA work plan approval date and notice to proceed will be the date
NCDENR issues the final approval letter.
I will be out of the office from September 13, 2000, thru September 25, 2002. If you have
any questions, please contact Phil Vorsatz at [phone].
Sincerely-----..
Project Manager
cc: Phil \'orsatz, EPA
lnteme: Address (UAL)• hnp:1/www,"p.i.gov
Recycled/Recyclable. Pnnted wltn vegelable 00 Based Inks on Recycled P.l.l)(lr (Minimum 30% Postcon:;1Jmer)
North Carolina • Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
6 I Forsyth Street, 11th Floor
Atlanta, Georgia 30303
August 29, 2002
•
RE: Comments on the Draft Removal Design/Removal Action Work Plans, all Media
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salern, Forsyth County, North Carolina
Dear Mr. Flores:
The Johnson Controls Battery Group responses to Agency comments Dated
August 19, 2002 for the Removal Design/Removal Action (RD/RA) Work Plan for all
media of concern at the Johnson Controls Battery Group Site, located in Winston-Salem,
NC has been received and reviewed. The following comments by the North Carolina
Superfund Section are submitted for your consideration.
'
Specific Comments to'Responses
l. The JCBG response to the States General Comment is not specific enough. A more
acceptable response is provided in Comment Response #16. It appears that the
average lead concentration located outside the proposed excavation area at Basin #1
has been calculated from the Engineering Evaluation/Cost Analysis (EE/CA)
investigation data. Since the Basin # I area has been fully delineated during the
EE/CA investigation and the average lead concentration outside of the proposed
excavation area is· 76.91 which is below the acceptable average for ecological
protection, additional confirmation sampling is not required in this area.
In the revised Work Plan the State will review the proposed additional grid areas in
Basins #2 & 3 where additional confirmation samples are proposed. If these areas
include all EE/CA investigation grid samples that exceed the 100 mg/kg or the
average of each basin area is below 100 mg/kg then proposed confirmation of these
areas is acceptable.
Please clarify these c_ritical details where appropriate in the final RD/RA Work Plan.
Mr. Luis Flores
8-21-2001
Page 2 of 4
• •
2. Response to comment #3 states that the wastewater from basin #I will only be used in
areas that are proposed for excavated or on impacted stockpiles. The use of the water
will be monitored to assure that these are the only areas that basin #I wastewater or
other potentially contaminated wastewater is used. Please clarify these critical details
in the appropriate sections of the final RD/RA Work Plan.
3. Comment/Response #4 is unacceptable to the State Superfund and State RCRA
Sections. The federal Hazardous Waste Identification Rule (HWIR) was not enacted
in North Carolina.' In North Carolina the substantive requirements of the Corrective
Action Management Unit (CAMU) permit must be met by providing appropriate
information to thf: Agency for review and concurrence by all appropriate parties
including the State RCRA Section. I have discussed this issue in detail with the
central and regional RCRA Sections and it may be possible if deemed necessary to
' develop some type of containment treatment/staging area. Contact Steve Phibbs at
the RCRA Regional office at [phone].
The estimated soil and sediment volumes that require treatment consists of a total of
347 cubic yards. Assuming each roll-off box can carry only 16 cubic yards due to
weight limitations this will only require approximately 22 .roll-off boxes. Staging
areas that do not involve RCRA hazardous waste will be easier to develop staging
areas for. Details of these containment areas may be worked out with Steve Phibbs.
4. Where additional information or clarification was provided in the response to agency
comments, assure that similar information or clarification or reference to them is
included in appropriate sections of the final RD/RA Work Plan for all agency
comments.
5. Comment/Response #IO is unacceptable. The groundwater in these areas is not at a
' depth 60 feet below grade. This was an estimated depth that was inappropriately
included in the EEiCA Report. If we look at the groundwater data from the wells
installed in these areas we will see a groundwater depth roughly ranging from 25 to
40 feet below groun~ surface (from memory).
If the topography in the area is observed it is obvious that IO to 20 feet of cut-
excavation has taken place in the areas of MW-01, MW-04 and MW-06. Only the top
3 or 4 feet of soil contains impermeable clay. The soil in the gravel grass and under
paved areas at the site is the weathered saprolite fine sandy silts with some clay (less
clay with depth). These saprolite soils are common to the piedmont physiographic
area and are weatheted from the underlying rock. Within the structure of these fine
sandy silty soils are intrusive fingers-of injected quartz and feldspar that are unevenly
weather to angular fractured or grainy lenses that can easily carry most contaminants
to groundwater. PAI-l's and VOCs are often found in the piedmont groundwater.
Mr. Luis Flores
8-21-2001
Page 3 of4
• •
Surface water runoff at the swale across from the lead unloading dock area presently
overflows the sw_ale during heavy rainfall and gravity flows in the direction of MW-
01. Former surface water runoff from the lead unloading dock area was the primary
flow path for rainwater at the location of MW-06. MW-04 is located in a parking
area and is near the path of the former drainage path from the facility to Basin #1. For
these reasons and others not noted, the state does not consider the subject monitoring
wells to be representative of background. If monitoring wells are non-detect for all
potential contaminants other than naturally occurring inorganic substances then they
could be acceptable background wells.
6. Comment/Response #11 is unacceptable .. For reasons noted above and in the original
comment #11, the State will require that Semi-volatile organic compounds (SVOCs)
be collected and analyzed as requested. A note to field personnel and the lab should
be provided. The. note should request that care be taken not to contact the sampling
equipment or sample jars with rubber gloves. It may also help to use gloves that are
not powdered. If, the results show non-detect for SVOCs then future sampling of
MW-01 would no longer require analysis for SVOCs.
7. Comment/Response #13 is acceptable. If the 25 feet by 25 feet sample grid also
represents the total excavation area for each grid then the 4 quadrant samples are
acceptable.
8. Table A should be-clarified in comment/response 16 on page 11 when including this
detail in the revised RD/RA Work Plan.
9. Comment response #17 is unacceptable. Actually 40 CFR 258.48 indicates that the
regulation is based on grab samples and does not limit verification of the contaminant
concentrations to grab samples only. If the landfill requires a grab sample to
characterize the batches then a grab sample would be necessary in addition to
composite samples as requested in the States original comment. Since only a small
volume of soil (< 350 CY) is being treated for hazardous constituent the State will
only require I composite sample be collected along with a grab sample for
comparison. If both samples are below the TCLP required limit then all future treated
soil may be confirmed by a grab sample. All soils not requiring treatment must be
confirmed using composite samples as discussed in the States original comment.
10. In regard to comment/response #23, where are we in regard to the community
relation's plan Fact Sheet, and placing a notice in the local newspaper.
11. I understand that the EPA only comments on the Health and Safety (H&S) Plan.
However, the State places great importance on health and safety procedures and
would at least like an acknowledgement that all appropriate corrections have been
made to the final Health and Safety Plan based on State comments. The agency and
the department expects all State and Federal health and safety regulations to be upheld
Mr. Luis Flores
8-21-200 I
Page 4 of 4
• •
Health and Safety Plan based on State comments. The agency and the department
expects all State and Federal health and safety regulations to be upheld to the fullest
extent during this removal work. Oversight personnel will be closely monitoring these
issues during the work. If JCBG representatives have any uncertainty as to the accuracy
of the H & S Plan it s)10uld be discussed prior to starting work.
The State appreciates the opportunity to comment on this document and we look forward to
working with you on the project. If you have any questions or comments, please call me, at
[phone], extension 341. c;c~;:y~~ ~~~
cc: Dave Lown, N.C. Superfund Section
Randy McElveen
Environmental Engineer
NC Superfund Section
August I 9, 2002
Mr. Luis Flores
Remedial Project Manager U.S.EPA Region IV
6 I Forsyth Street, I I 'h Floor
Atlanta. Georgia 30303
Re: Comments on the Draft Removal Design. Removal Action Work Plan for the
Johnson Controls Battery group, Inc. (JCBG), NCD 000 770 487, Wiriston Salem,
Forsyth County, North Carolina
Dear Mr. Flores.
The following are ENTACT's response to comments received from both the Region IV
U.S. Environmental Protection Agency (USEPA) and the North Carolina Department of
Environment and Natural Resources (NCDENR) for the above mentioned site as
received in a letter from you dated August I 5, 2002. If these responses are acceptable,
all necessary revisions will be m<1de and the revised pages submitted for replacement intq _
the existing RD/RA Workplan document.
U.S. EPA Comments dated August 15, 2002
I. Section 1.2.2 Double check dates when the facility started operations. Make
them consistent.
ENTACT: The information contained in the approved Final EEIC.4. prepared hy
,vfonrgomery Watson Harza (lvfWH) and dated ,I/arch 2002, stared that the facility was
constructed in the late I 970s and began operations in I 980. This is consistent with what
is stated in Section 1.2.2. However the text will he revised to clarify 1his.
2. Page 4 -first bullet, Delete the phrase "which could not be attributed to the
Site" and all second bullet text.
ENTACT: Tex/ has been revised as requested
3. Section 1.3.1 -Groundwater flow should be NORTH\VEST not northeast
ENTACT: Section 2.2.-1.2 of the approved Final EE/CA de/ermined 1ha1 groundwater
flow 11·a.1· to the H·es/ and nor1hwe.1·1. Therefore the text ll'il! he correc1ed 10 ref/eel a ll'est
lo nor/Invest groundll'aterflow.
p.630.616.2100 • www.enracr.com • f.630.616.9203
• 4. Section 1.5 -Change title to "Response Action"
ENTACT: Text has been revised as requested
•
5. Section 1.5 -First bullet for each Area: Use Action Memo language when
describing excavation requirement. I.e. Plant area: "Excavation and off-site
disposal of all soil exceeding a concentration of 750 mg/Kg ... "
Sedimentation Basin I Area: "Excavation and offsite disposal of all soil and
sediment exceeding 400 mg/Kg ... " Correct throughout the document and
Appendices.
ENTACT: Text revised as requested
6. Section 1.5, page 12 -Sedimentation Basins 2 and 3 -Delete "s" ... and
sediments exceeding a concentration" Correct throughout the document and
Appendices.
ENTACT: Text revised as requested
7. Page 13, 3'd bullet -It does not make sense. "Conduct pre-construction
sampling results .... " ? EPA is not considering abandoning the existing
monitoring wells at this time. Please delete that part of the sentence. Correct
throughout the document and Appendices.
ENTACT: The lex/ has heen reworded as jiJllml's: "Conduct pre-cons/rue/ion
groundll'ater sampling /0 de/ermine wherher developmenl of a long-rerm groundwarer-
moniloring program is needed and evaluare rhe effectiveness and necessity of the exisring
monitoring well network" The results of the groundwarer sampling will be used 1101 only
/0 determine wherher or 1101 long-rerm groundwater moniroring should he conduued hlll
also lo recommend any modifications or removal of rhe existing on-site monitoring wells .
. Vo modifications or ahando11me111 of \l'el!s will occur ll'ilholll prior apprornl o/ rhe
.·lgencies.
8. Section 2.2 Please include "Randy McElveen as the State Project Manager.
E.VT-lCT: Ranc(v McElreen has been added lo Sec1io11 2.2 as rhe NCDE:VR Projecr
Manager.
9. Section 8 -Construction Schedule -Submit a revised construction schedule
after the workplan is approved.
E:VT,lCT A rerised consrrucrion schedule will he suh111i11ed lo rhe U.S. EP. l and
.\iCDENRfol/o,ving approval o/rhe Work Plan
• •
10. Appendix B, Page 2 -See comment #5, 6 and 7
ENTACT: Text has been revised as requested.
11. Appendix B, Page 4 -Backfill Standards -If soil containing lead above I 00
mg/Kg is used as backfill, confirmatory sampling needs to be performed at
all disturbed areas to make sure that average concentration is below 100
mg/kg.
ENT.,JCT. Text will be revised lo state that if on-site soils from the Megabasin
construction are used as backfill, a -I-part composite sample will be collected from the
stockpiled soils at a frequency of one per every 500 cubic yards for laboratory testing to
ensure that lead concentrations are below I 00 mg/Kg. No soil in excess of I 00 mg/Kg
lead will be used as backfill. This will avoid adversely impacting the excavated areas
1ha1 have been determined to have successfi,lly met the average I 00 mg/Kg lead criterion
lhrough !he post-excavation conjirmawry sampling.
12. Appendix B, Section 4.0, 6.0 and 8.0 -Include in all these sections a brief
discussion on grid dimensions and horizontal sampling distances and
frequency.
ENTACT: Text in Section 2.0 Excavation has been revised to include a discussion on the
grid system as follows: "A coordinate grid system (CGS) will be established over the
areas requiring excavation in order lo /rack sampling and excavation activily in the field
The ( ·cs will employ grids of approximately 25 feel bv 25 feet (Basins) or IO by 50 feet
(Plwu .-1rea) superimposed completely over the excavation area. Section -I. 0, 6. 0 and
8. 0 will he referred to Sec/ion 2. 0 for the CGS discussion. The text will also be revised 10
reference the appropriate sec/ions of the FSA P for !he sampling methodology and
frequemy.
13. Appendix B, Section -1.0, Discuss VOCs post-excavation sampling
verification.
EAT-ICT. As stated in the QAPP Table 1-3. pos1-excuvation conjirnw101y sampling for
soils and sediments ,viii address lead ivith one loclllion sampled for benzo(a)pyrene. a
semi-rolatile organic compound (SVOC). Both can be collected J,-om 1he homogenized
sample us described in Sec/ion -I. 0. The text will he rCl'isecl as follows: "In the one
locaii::ecl area in 1he Flam .-lrea \\·here hen::o/a)pyrene H·as detec1cd above rhe 1.39-1
ug/Kg criterion. the sample will be also be analy::edfor henzo(aipyrene ...
f.'o/arile organic compoum/.1· 1VOC.1) 11·ill 1101 be wldressed in the post-excavmion
con/irnwtr!ly sampling but are i11cluded i11 groundirnter sampling and i11 the lanclji/1
rcuuircrl 11ustc profile .rnnwling iTCLf f 'OCI·,.
•
. 14. Appendix C -Page 2 .See comment #5, 6 and 7.
ENTACT: Text has been revised as requested
NCDENR Comments dated August 8, 2002
General Comments:
., .. StatisticaJ confirmation procedures and sample calculations should be provided
to show how average soil/sediment lead concentrations will be confirmed to meet the
100 mg/Kg total lead concentration in each of the Basin Areas. Some areas will
require data from the Engineering Evaluation/Cost Analysis (EE/CA) completed
last year or additional composite samples or XRF directed samples are required in
these areas. It is recommended that the XRF be used to screen these areas to
confirm that high levels of lead are not located in soil/sediment adjacent to areas
that exceeded 200 mg/Kg total lead during EE/CA. The State has commented on the
EE/CA Report; stating that meeting the 100 mg/Kg lead concentration for
protection of the ecological habitat is considered a critical part of the cleanup.
Therefore every effort should be taken to confirm that average lead concentration in
all contaminated soil/sediment at each of the basin areas is below 100 ·mg/Kg total
lead.
ENTACT: The Remo\'{// Action ll'i/1 focus on 1he areas de/inecaed in 1he EE/CA as
exceeding 1he performance swndards. These areas are illus/raled in Figure FSAP-1.
For Basin #/ and !he Plant Area. which were comp/e1e/y de/inea1ed as pcm of 1he
EE/CA. it is no/ necessary lo extend characterizalion sampling oulside and beyond !he
approximcile boundaries of the impacled areas defined as par/ !he ££/CA inves1igarion
Basin #2 and #3. which ,vere 1101 complelely delineated in the EE/CA ll'ill be screened
wilh the )(RF as par! ofrhe removal aclion ro complele de/inemion and de/ermine ll'hich
soils may be used as on-sire backfill in excava1ion areas.
As .,·wred in !he Workplan. the XRF ins/rumen/ will be used lo screen si1e soils and
sediments in order ro define the vertical and la/erctl exre111.1· of 1he excavmion in 1he
impacted areas. Once the XRF de/ermines the cleanup criterion has been mer. a sample
,.,ill be collec1ed for laboraro,y 1es1ing ro ,·erify rhar rhe appropriate pe,jormance
s/andard has been mer For the basin areas. the performance slandard is -100 mg/Kg
rowl lead. wilh an allowable m·erage lead conce/1/rarion for each of the basin areas
below I(}() mg/Kg.
The a,·erage lead concentrations H'i/1 be de/ermined fi,r each area by calculating rhe
arithmetic average of the .YRF measureme/1/s for each sedime111a1ion basin area (i.e.
Basin #I. Basin #2 and #3). Beginning in each basin areu. folloll'ing the re mom/ action.
rile irririal }our .\'RF 111eu.1ureme111s co/leered irr each ufrhe four ,1uuclrw11s ofrhejirsr grid
11·ill he uri1hme1ical/_1· m·erugecl lo obtain 1he 1owl lead co11ce111rorions jar rhur grid If
1he uri1hme1ic u,·eruge is abm·e I 0/J mg/Kg. uddilional soil 11·ill he remo,·ed wirhirr 1hm
.j
• • grid until the 100 mg/Kg averaged mlue is met. The subsequent XRF readings/or each
remaining grid will be rnmulativelv averaged (i.e .. the second grid will have 8 XRF
readings. the third grid will show 12 XRF readings. etc) to ensure that as the excavation
in that basin area progresses. the I 00 mg/Kg averaged criterion is met.
Specific Comments:
I. The 165 feet of 30" diameter RCP as shown on Figure 3 is proposed for
installation through a 6 to 8 foot mound of residual soil prior to reaching
the adjacent access road elevation.
ENTACT: ENTACT is aware of the grade change at that location and will undertake the
necessary steps to ensure successfid installation of the RCP.
2. Outlet pipes, railroad tract, existing catch basins, etc that are staged for
off site disposal should be properly decontaminated with a pressure
washer. Proper removal of contaminated soil is essential in areas where
Characteristic Hazardous Waste is contained in soils and sediments.
ENTACT: Any debris removed from impacted areas will be properly decontaminated
prior to off-site disposal. The text will be revised to clarify this.
3. The first paragraph on Page 25 of the Work Plan states that: "Any
collected wastewater will be used for dust suppression in areas requiring
excavation or on stockpiles awaiting treatment." The state docs not
recommend the use of Basin #I wastewater be used for these purposes in
areas of the site other than the Basin #I area since there arc higher levels
of lead in Basin #1.
ENTACT: The wastewater will only be used as a dust suppressant in areas requiring
excarntion and on impacted stockpiles requiring treatmem prior to disposal. not in clean
areas or areas where excavation has alreac(v been completed. The water is applied as a
jine 111ist to the impacted soils lo comrol any airborne migration of lead. These areas
will he surrounded wirh surface ll'aler and erosion conlrols lo prevent any oi·erland
migrarion of water coming i1110 contact ll'ith !he soils. This is an eswblished procedure
rhea has been approved and implemented ar numerous S11perfi111d sires across rhe country
and is designed so !hat it does 1101 pose any significanl risk 10 human healrh or lo the
envirunmenl. The ll·astewater ll·i/1 he combined in a remporarv holding lank Ji-om
deco111umina1io11 ac1ii·i1ies and ji-0111 um· pumping thm men-he necessarv in any o( rhe
,:xcarn1io11 areas including /Jasin #/. TlzerejiJre ii is possible 1hm \\·asre,rcuer Ji-om any
urea could be used in 01/zer impacred areas. but !his slw11/cl 1101 pose any undue risk as
prel'io11s/_1· described.
-L The first and second paragraphs on page 25 :--tatc that treatment staging
areas and treatment containment areas will be constructed for stockpiling
and treatment of the lead contaminated soil material. The Hazardous
5
,.
•• • Waste Section of the State does not think that the staging and treatment
areas as defined in these paragraphs is consistent with RCRA laws
governing staging and treatment of hazardous waste. It is recommended
that the staging and treatment containment areas be discussed and
verified by the Winston-Salem Regional Office Hazardous Waste Section
of Waste Management prior to use. This will eliminate the possibility of
receiving a notice of violation (NOV) in this matter ...
ENTACT: The treatment staging and treatment containment areas have been
determined by the USEPA to be consistant with RCRA and have been approved and
implemented effectively at USEP A-driven Superfund sites across the country. The federal
Final Hazardous Waste Identification Rule (HWIR) for Contaminated Media (November
30. 1998) allows for the excavation. staging and on-site treatment of hazardous
remediation wastes without triggering traditional RCRA permits. The Final HWIR ruling
introduced several major changes to traditional RCRA permilling procedures for the
management and treatment of hazardous remediation wastes, since traditional RCRA
regulations were not intended to address soil remediation waste per se. and were in fact
acting as a .wrong disincentive to remediating hazardous waste sites. Under the HW!R
rule. the USEPA has created different requirements for remediation waste management
sites than/or facilities managing "as generated" wastes.
As part of broad-based reforms of RCRA. the Final HWIR ruling provides major changes
to help streamline the RCRA process governing the management of hazardous waste and
facilitate cleanup.
Some of those changes included the ji,lloll'ing:
• Introduced streamlined procedures for obtaining approval for the treating, storing
and disposing ofhcccmlous remediation ll'astes through a Remedial Ac1ion Plan (-10
CFR 270.2, 270.68 and 270.80-270.230). The approved RD/RA Work Plan will ac1
us the equivalent of a special permit tha! allows for the slorage. lreatmen! and
disposal of hazardous remediation ll'aste at a remediation waste management site
lFhile not subjecting the o,mer or operator to facility-ll'ide corrective action.
traditional public participation requirements or traditional waste management and
design requiremenls.
Created a new kind of uni! callee/ a ··s1aging pile·· that allows more jlexibili1y in
storing remediation 11·as/e during cleanup (-10 CFR 26-1.554). The staging pile
pro,·ision allows Ji1r 1he acc1111111/c11ion of solid. non/lowing remedial ion was/e used
only during remedial operarions/i>r 1emporary storage at a facility. The staging pile
11111st he located wi1hin the co111iguo11s propertv under comrol of owner or operator
lFhere the wastes to he managed in the staging pile originated. As part of the HIY!R
rule. placemem ofha::arclous remediation wastes in a .1·taging pile will not suhject the
unit In LDRs. or 111i11imw11 rechnologi-req11ire111e111s (\fTR.1·1.
6
• • • Created Corrective Action ,\Ianagement Units (CAMU) and Temporary Units (TUs)
which are units designed for the storage and treatment of hazardous remediation
wastes that are not subject to traditional RCRA permit requirements and design
standards nor will placement of wastes into the CAMU or TU create a unit subject to
minimum technology requirements.
The ex situ stabilization treatment process using both an open treatment containment
area has been used by ENTACT at both federal Superfund Sites as well as State cleanup
sites with equal success. The treatment containment bed is constructed on an
impermeable concrete pad or compacted clay bottom, surrounded with concrete Jersey
barriers or clay berms. over which a liner will be placed to allow for the capture and
control of any run-off and is kept misted as part of dust control measures during all
loading,. unloading and treatment activity to prevent the release of airborne lead
Therefore it poses no undue risk to either human health of the surrounding environment.
The treatment containment area has been determined by the Agency to meet the definition
ofa container as defined in .l(J CFR Part 260, Subpart A, 260. IO in that both are portable
devices in which material is stored. lreated. disposed of or otherwise handled The
treatment containment area is, in effect, a temporary corrective action management unit
where hazardous waste is allowed to be stored and treated under the HWIR ruling.
5. The first paragraphs on page 26 states that: "An area with lead-impacted
soils greater than 750 mg/Kg but less thari 1,000 mg/Kg lead .... will be
excavated, hauled off-site and disposed at a non-hazardous waste
landfill." The NC Superfund Section requires that the landfill be notified
of the range of total l cad concentrations for the various areas of the site
and the TCLP concentrations for every 250 to 500 cubic yards. The
landfill to receive the waste should be informed that the soil contains
industrial risk concentrations of total lead. The landfill can also be told
that the lead impacted soil can be used for landfill cover at the end of
each day since it is only exposed for a few days or weeks and the risk
threat is for long term chronic exposure.
E:VT.-ICT. .-Ill applicable regulations ll'ill be followed/or the off-site disposal ofrhe lead-
impacted soils and sediments. As part of the approval process in procuring a landfill
that agrees lo accept the remedicllion H'aste. the range of lead concentrations for 1he
l'arious areas will be provided. The landfill will be informed that the soil can be used
for landfill cover at the end of the day due to the limited time of exposure. As stated in
Seer ion./. 9. all appropriate documemation will be generated and maintained/or all soils
rra11.1porrcdfi-om rhe Sire ro the landfill and disposed herein.
6. The first paragraph on page 26 does not designate the excavation depth
for additional soil located near the building and part of the sentence is left
out.
L\T-ICT· lhe se/Jlence hus heen correcred ro read us _rollu,rs: ·· The additional
cxn/\'ution area requiring re111ornl is csrimated ,If upproxi111melv IO Ji "icle hy I .JO _fi
long 10 a depth ofapproxi111a1ely IJ.5.feet. or 650 c/(2./ C\'J. ··
7
•
7. The second bullet.at the top of page 31 discusses two low areas near the
entrance to the employee parking lot.·. These low areas may actually be
high areas .. This parking area and the adjacent access road has been cut
.. down into residual · soil from as much as 8 to 12 feet or more. It is
recommended that the Plant Engineer confirm the two low areas
proposed to be backfilled for proper drainage.
ENTACT The two areas near the entrance to the employee parking lot will be visually
checked by ENTACT as part of pre-mobilization activities to confirm whether or not
these are high or low areas.
8. The Sediment and Erosion Control Plans are discussed on page 36 and
reference to Appendix G. Please provide the Sediment and Erosion
Control Plan drawings in Appendix G.
ENTACT The initial Sediment and Erosion Control Plans consist of Figures Fl. FJ,
and Fj -F7 that were provided in the RD/RA Workplan. The cross-reference sheet
describing their location was inadvertently left out Appendix G. ENTACT has had
supplemental conversations with Randy McElveen regarding the generation of additional
sheets based upon comments from the City of Winston-Salem. It is anticipated that up to
four (-I) additional or supplemental sheets will be created as part of the Sediment and
Erosion Control Plan. This work is currently underway and we will advise USEPA and
NCDENR of their status on a weekly basis.
9. Section 6.4 on page 38 references MWH project superintendent rather
than ENT ACT. Please make appropriate corrections.
ENT,ICT Text will he revised to eliminate A1WH reference
10. The last paragraph on page 39 states that monitoring wells M\V-01, M\V-
04 and MW-06 were considered representative of background
groundwater quality in the EE/CA. In comment to the EE/CA, the State
indicated that it docs not considered these 3 wells to represent
background groundwater quality since they arc located within the
operations areas or immediately adjacent to, or downgradient of, the
facility. These areas could easily have been impacted by loading and
unloading vehicles or equipment in these areas or as a result of former
operations in the adjacent paved areas.
LVTACT· Based on site topogrnphy and rhe derermined '"est ro northwesterly
ground,rnter flow. ENTACT agrees '"irh rhe MWH EEIC,I conclusions rhcll rhe wells
MW-01. MW-04 and AfW-06 should he considered represe111c11ive of background
gm,md,rnrer qua/in· {If rhe sire. .\lWJI I and .\!W-0./ {Ire locurecl upgmdienr of rhe
priman· .fc,cility operwiom· 1ha1 were deemed possible source areas including 1he acid
s1nragc wnk area. 1he lead oxide u11loacli11g clock and a .former drum srornge area. .\!W-
8
• • 06 is situated within 200 feet of the lead oxide unloading area and approximately 100
feet oft he former drum storage area. but exhibited the highest groundwmer elevation in
the last sampling event. Based on the water table configuration map (Figure 5. drawing
Number F-1) in the Final EE/CA all three wells could be used to determine representative
groumhrnter quality at the site.
Though there is no evidence of any impact in these areas due to former operations or
loading and unloading activities. any possible impacts would be mitigated by the
presence of the clay rich soils of the underlying geology whose relatively low hydraulic
conductivity of the would inhibit any appreciable dolt'nward migration of lead or
benzo(a}pyrene (the contaminants of concern at this site). Both lead and PAHs have
physicochemical properties that make them relatively immobile in the subsurface, with a
tendency to a//enuate near the point of deposition, and the groundwater is encountered
approximately 60 feet below the ground Sllrface. Based on this evidence and on the fate
and transport of the contaminants of concern at the site, the conclusions stated in Section
2. 2. -I oft he approval Final EE/CA are considered valid.
I I. The last paragraph on page 40 states that samples will he not be collected
and analyzed for SVOCs and PCBs during the second round of
groundwater sampling. Monitoring well MW-01 should include analysis
for SVOCs since it contained bis(2-ethylhexyl)phthalate in the first round
results. Please make appropriate corrections.
ENTACT Bis(2-ethy/hexy/) phthalate is a typical laboratory artifact. The presence of
this compound in this single upgr.:dient well. with no detections ,if this compound in site
soils or in any other well. indicates it is not a site contaminant of concern and therefore
is not included as a parameter in the groundwater sampling.
12. The Performance Standard Verification Plan (PSVP) and Field Sampling
and Analysis Plan should include a drawing or reference a drawing that
shows grid layout for the four areas and an example drawing of the
proposed XRF screening in each quadrant. The area with the highest
XRF screening value will be sampled for confirmation at a laboratory.
The PSVP and FSAP should also include a detailed discussion with
example calculations showing how the I 00 mg/Kg total lead average
concentration will be determined statistically in each area and how the
EE/CA analytical data could potentially be used adjacent to thee
excavation areas.
EN7:.J( T Dralt'ings will be included in the FSAP thw shall· rhe grid lt,yout and the
approxi111ate locations of the .\RF sampling and the conjirmuto1y sample. These
drc/\l'ings ll'il/ be referenced in the PSVP. Page 5 of the F<;AP alreadv states tha/ the
con/innution grab locmion ll'il/ he based on the highest XRF reading H'irhin that grid.
Tl,i., ,rill he added 10 rhe PSVP /i,r clari/icutirm. Please reference the Genem/ Co111111e111
response on page -I }or c/arijicution 011 hm1• the I 00 111g;kg rowled ll'i!/ he determined. A
section dcscrihing this H'ill he added to rhe PSVP and rejerenccd in the FS.-/1'.
9
• •
13. The Table ;it the bottom of page 4 Appendix C, Field Sampling and
Analysis Plan notes the XRF samples will be collected in each of the four
quadrants of each grid. It is recommended that several XRF center
samples also be taken in the Plant Area and Basin #I. If no statistical
variation occurs that finds greater significance to the center area samples
then the center area sample may be eliminated after 4 center samples are
taken in each area. The sampling system is also discussed as item (b) on
page 7 of Section 3.1 of the FSAP.
ENTACT. The grids are only 25 feel by 25 feet (Basin #I) or IO feet by 50 feel.
Therefore one XRF measure men/ is collecled for every I 2. 5-fool by I 2. 5-foo/ quadrant
(Basin #I) and one XRF for every IO fool by 12.5 foot quadram (Plan/ Area). This
frequency more than meets standard statislical requiremenl.s for an area 1ha1 size. Wi1h
the co/lee/ion of the confirmalory sample there are then jive samples per grid. The
quadranl XRF measurements will be collec1ed at random localions wilhin thal quadrant,
no! just al the corners, so the samples will be well distribwed throughout the sample grid
and should provide a valid representa1ion of the soil condi1ions.
14. Page 5 of the FSAP discusses the details of confirmation sampling. Please
include the vertical location along the wall of the excavation that the
sidewall samples will be taken from, e.g. will the 2-foot depth excavation
sidewall sample be taken from the I foot below grade and I foot from the
bottom of the excavation (half way)?
ENTACT. A discussion of the vertical sidewall sampling will he added as requested to
Section J 2 of the FSAP. Side1mll samples will be collected from any excavation at or
exceeding I foot in depth and will be collected at the mid-point between the original
ground s111jc1ce and the bollom oft he excavation.
15. The quadrant grid designation in the last paragraph on page 6 should be
SD2 rather than SDI.
ENTACT. The text will be corrected to read "X-SD2-B2-3."
16. XRF Fluorescence (XRF) Screening of excavation areas is discussed on
page 7 of the FSAP, Grab samples were taken in several areas around
the basins during the EE/CA field investigation. Many of these grab
samples were elevated in excess of 200 mg/Kg. The State requests that
additional grid samples he set-up in previous grab sample locations that
exceeded 200 mg/Kg total lead and screened using the XRF, The center
of the grid could he established as the original EE/CA grah location and
then additional screening could be completed in the four quadrants of the
grid as set forth in the XRF Screening Procedures.
10
• • ENTACT: A grid will be established over Basins 2 and 3 encompassing the previous
EE/CA investigation locations due to the limited characterization conducted in these
areas during the EE/CA. XRF screening will be conducted over these grids as set forth
in the XRF Screening Procedures. The grid layout and approximate XRF locations will
be presented in the FSAP drawings.
Basin # I however was delinecued during the EE/CA and the area requiring removal
defined. The grids will he established over these defined areas. The vertical and
horizontal extents of these defined areas will be guided by the XRF. No additional
characterization sampling will be conducted outside the limits of these areas. Existing
data can be used to ascertain the average lead concentrations outside the removal areas
as presented in the al/ached Table A.
Based on a total of 58 soil samples collected outside the defined removal action
boundaries in Basin #!, the average lead concentration is 76.91 mg/Kg, which falls
below I 00 mg/Kg. As part of the removal action, the average lead concentration will be
calculated during removal using XRF data to establish the average lead concentration in
the excavarion areas to ensure rhe I 00 mg/Kg average lead concentration is maintained.
17. Treatment confirmation sampling procedures are defined on page 9 of
the FSAP and are proposed to include "l grab sample from every roll off
box or from every 250 cubic yards oftreated material." One grab sample
collected in this manner is not representative of a mixing container of any
type. The following procedure is recommended. Each sample should
include 6 to 10 aliquots that are collected from various locations within
the treatment container. The more difficult areas of the any container to
mix are the bottoms and sides. One aliquot should be collected from each
side of the container and a minimum of 2 aliquots from the bottom of the
container. Other aliquots should be included within the mass of the
treated materials at equally spaced intervals.
ENTACT Under -10 CFR 26S-18(aJ and Table UTS Footnote (3). compliance wirh
Universal Treatment Standards fur non-wastewaters are measured by an analysis of grab
samples. not composite samples. Therefore grab samples must be collected to verifi.1 that
the treatmenr srandards have heen met for off-site disposal. For roll off box samples.
which appear to be the concern of the State. rhe grab sample can be collected Ji-om the
ho/lam or sides of the box which would represent rhe areas typically more diffirnlt to
access in the mixing process. Or all treatmenr could be conducred within the ex situ
treatmenr conrainmenr area ,.-hich al/o,rs jrJr a more rhorough mixing of materials than
rnn be achieved in roll ojf"boxes.
18. Attachment FSAP-1 docs not include sample locations as stated in Section
1.6.2 on page 1-12 of the Quality Assurance Project Plan (QAPP). Please
make appropriate corrections. The proposed sampling grids should he
included on a site map or drawing.
11
• ENTACT: The figures of the sample locations and grids will be included in the Final
FSAP.
I 9. There is no contaminated soil/sediment treatment Section, 02062, as
noted in theTable of Contents on page lof Attachment E-1
ENTACT: This specification was inadvertently left out of the Section A copy of this
section is provided as an a//achment to 1his feller.
20. Section 2.2 of page 2. of the Treatability Study Report in Appendix F
references the Jack's Creek Superfund Site. The last sentence of the first
paragraph on Section 2.4 on page 3 makes reference to Earth Tech.
Please make appropriate corrections.
ENTACT: The text has been corrected to eliminate these references.
21. The first bullet at the top of page 4 references paint residue. There is no
paint residue at the .JCBGI Site. Please make appropriate corrections.
ENTACT: The text has been corrected to eliminate 1hese references.
22. The headings of Tables I, 2, & 3 on page 4 ·and 5 of Appendix F are
blacked out. This makes it very difficult to understand the data. Please
make appropriate corrections.
ENTACT: The 1ab/es have been edi1ed 10 highlight the headings.
23. Specific contact with the adjacent property owners is not discussed in the
Community relations Plan, Appendix H. Based in my discussion with you
Luis, there should be at least a Fact Sheet mailing to adjacent property
owners and Town officials. The ENT ACT PR representative may be able
to help with some of the details of the Fact Sheet. And we discussed an
increase in traffic and brief discussion of the work being performed
would be appropriate.
ENTACT: In accordance with 1he AOC 1he process a/securing permission to access off-
site properties in order to comp/e1e 1he removal ac1ion is ongoing This informa1ion is
1ypica//v not included in 1he Comm,mif.v Re/a/ions Plan 1hat serves 10 provide 1he general
comm1111i1v wi1h overall sile infi;rmalion including a sile descriplion and hislOJY and a
descriplion of/he removal aclion In addi!ion !he plan idemijies !he signijica/11 .-1genc:v
and .IC! cu111ac1s lo voice </ 11es1 iom and concerns.
24. Some of the runoff calculations presented in Attachment I are not
readable. Please pnn·ide helter copies for the final Work Plan.
• • ENTACT· ENTACT will provide revised copies of the runoff calculations in the final
Work Plan.
Following your review and approval of the above·responses to the comments received
from the U.S.EPA and the NCDENR. the revised replacement pages will be submitted for
insertion into the RD/RA Workplan. Please feel free to contact us at [phone] if
you have any concerns or questions on any of the above comments.
Si;;ely/ n [) /
Utu{IAIII~
Christopher Preston, P.E.
ENT ACT & Associates. LLC
Enclosures
cc: Randy McElveen -NCDENR
Timothy Lafond, P.E. -JCBGI
Dennis Reis -Dennis Reis. LLC
file
(--· .
\__.,,~~
Patrici~Vojack, P.G.
ENT ACT & Associates, LLC
13
North Carolina • Department of Environment and Natural Resources
Division of Waste Managem~nt
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
August 8, 2002
•
RE: Comments on t.he Draft Removal Design/Removal Action Work Plan
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem'., Forsyth County, North Carolina
Dear Mr. Flores:
The Draft Removal Design/Removal Action Work Plan, dated July 2002, for all
media of concern at the Johnson Controls Battery Facility, located in Winston-Salem, NC has
been received and reviewed. The following comments by the North Carolina Superfund
Section are submitted for your consideration. Please Provide a Final RD/RA Work Plan or
insert pages as appropriate.
General Comments
This Draft Removal Design/Removal Action Work Plan appears to be in good order and
provides most of the detail for the Removal Work required at the Johnson Controls Battery
Group Site. Some details require clarification and performance verification field sampling
and other quality assurance issues need to be worked out.
The NC Superfund Section is in the process of reviewing the Health and Safety Plan (HSP)
for the RD/RA at the Site. We will provide comments on the HSP in the following week.
Statistical confirmation procedures and sample calculations should be provided to show how
average soil/sediment lead concentrations will be confirmed to meet the 100 mg/kg total lead
concentration in each of the Basin Areas. Some areas will require data from the Engineering
Evaluation/Cost Analysis (EE/CA) completed last year or additional composite samples or
XRF directed samples ar~ required in these areas. It is recommended that the XRF be used to
Screen these areas to confirm that high levels of lead arc not located in soil/sediment adjacent
to areas that exceeded 200 mg/kg total lead during the EE/CA. The State has commented on
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
Mr. Luis Flores
8-8-2002
Page 2 of 5
• •
the EE/CA Report; stating that meeting the l00 mg/kg lead concentrations for protection of
the ecological habitat is considered a critical part of the cleanup. Therefore, every effort
should be taken to confirm that average lead concentration in all contaminated soil/sediment
at each of the basin areas is below l00 mg/kg total lead.
Specific Comments
Drawings:
I. The 165 feet of 30" diameter RCP as shown on Figure 3 is proposed for installation
through a 6 to 8 f~et mound of residual soil prior to reaching the adjacent access road
elevation.
2. Outlet pipes, railrnad tract, existing catch basins, etc. that are staged for off site disposal
should be properly decontaminated with a pressure washer. Proper removal of
contaminated soil is essential in areas where Characteristic Hazardous Waste is contained
in the soil/sediment.
3. The first paragraph' on page 25 of the Work Plan states that: "Any collected wastewater
will be used for dust suppression in areas requiring excavation or on stockpiles awaiting
treatment." The State does not recommend the use of Basin #I wastewater be used for
these purposes in areas of the site other than the Basin # I area since there are higher
levels of lead in Basin #1.
4. The first and second paragraphs on page 25 state that treatment staging areas and
treatment containment areas will be constructed for stockpiling and treatment of the lead
contaminated soil material. The Hazardous Waste Section of the State does not think that
the staging and treatment areas as defined in these paragraphs is consistent with RCRA
laws governing staging and treatment of hazardous waste. It is recommended that the
staging and treatment containment areas be discussed and verified by the Winston-Salem
Regional office Hazardous Waste Section of Waste Management prior to use. This will
eliminate the possibility of receiving a notice of violation (NOV) in this matter. The
person to be contacted is Steve Phibbs at [phone].
'
5. The first paragraph on page 26 states that: "An area with lead-impacted soils greater than
750 mg/kg but less than 1,100 mg/kg lead ... will be excavated, hauled off-site and
disposed at a non-hazardous waste landfill." The NC Superfund Section requires that the
landfill be notified of the range of total lead concentrations for the various areas of the
site and the TCLP concentrations for every 250 to 500 cubic yards. The landfill to
receive the waste should be informed that the soil contains industrial risk concentrations
of total lead. The landfill can also be told that the lead impacted soil can be used for
landfill cover at the e,nd of each day since it is only exposed for a few days or weeks and
the risk threat is for long term chronic exposure.
Mr. Luis Flores
8-8-2002
Page 3 of5
•
6. The first paragraph on page 26 does not designate the excavation depth for additional soil
located near the building and part of the sentence is left out.
7. The second bullet at the top of page 31 discusses two low areas near the entrance to the
employee parking lot. These low areas may actually be high areas. This parking area and
the adjacent access road has been cut down into residual soil from as _much as 8 to 12 feet
or more. It is recommended that the Plant Engineer confirm the two low areas proposed
to be backfilled for proper drainage.
8. The Sediment
Appendix G.
Appendix G.
and Erosion Control Plans are discussed on page 36 and reference to
Please provide the Sediment and Erosion Control Plan drawings m
9. Section 6.4 on page 38 references MWH project superintendent rather than ENTACT.
Please make appropriate corrections.
10. The last paragraph on page 39 states that monitoring wells MW-01, MW-04 and MW06
were considered representative of background groundwater quality in the EE/CA. In
comment to the EE/CA the State indicated that it does not consider these 3 wells to
represent background groundwater quality since they are located wi_thin the operations
areas or immediately adjacent to or downgradient of the facility. These areas could easily
have been impacted:by loading and unloading vehicles or equipment in these areas or as a
result of former operations in the adjacent paved areas.
I I.The last paragraph on page 40 states that samples will not be collected and analyzed for
SVOCs and PCB during the second round of groundwater sampling. Monitoring well
MW-01 should incl~de analysis for SVOCs since it contained bis(2-ethylhexyl)phthalate
in the first round res~lts. Please make appropriate corrections.
12. The Performance Standard Verification Plan (PSVP) and Field Sampling and Analysis
Plan (FSAP) should include a drawing or reference to a drawing that shows the grid
layout for the four areas and an example drawing of the proposed XRF screening in each
quadrant. The area with the highest XRF screening value will be sampled for
confirmation at a laboratory. The PSVP and FSAP should also include a detailed
discussion with example calculations showing how the 100 mg/kg total lead average
concentration will be. determined statistically in each area and how the EE/CA analytical
data could potentially be used adjacent to the excavation areas.
13. The Table at the bottom of page 4 of Appendix C, Field Sampling and Analysis Plan
(FSAP) notes that XRF samples will be collected in each of the four quadrants of each
grid. It is recommended that several XRF center samples also be taken in the Plant Area
and Basin# I. If no statistical variation occurs that gives greater significance to the center
area samples then the center area sample may be eliminated after 4 center samples are
Mr. Luis Flores
8-8-2002
Page 4 of 5
• •
taken in each area. This sampling system is also discussed as item (b) on page 7 of
Section 3.1 of the FSAP.
14. Page 5 of the FSAP discusses the details of confirmation sampling. Please include the
vertical location along the wall of the excavation that the sidewall samples will be taken
from, e.g. will the 2 foot depth excavation sidewall sample be taken from 1 foot below
grade and 1 foot from the bottom of the excavation (half way)?
15. The quadrant grid designation in the last paragraph on page 6 should be SD2 rather than
SDI.
16. X-ray Florescence (XRF) Screening of excavation areas is discussed on page 7 of the
FSAP. Grab samples were taken in several areas around the basins during the EE/CA
field investigation. Many of these grab samples were elevated in excess of 200 mg/kg.
The State requests that additional grid samples be set-up in previous grab sample
locations that exceeded 200 mg/kg total lead and screened using the XRF. The center of
the grid could be established as the original EE/CA grab sample and then additional
screening could be' completed in the four quadrants of the grid as set forth in the XRF
Screening procedure. An alternative for smaller areas would be to excavate and treat
them.
17. Treatment confirmation sampling procedures are defined on page 9 of the FSAP and are
proposed to include." 1 grab sample from every roll off box or from every 250 cubic yards
of treated material." One grab sample collected in this manner is not representative of a
mixing container of any type. The following procedure is recommended. Each sample
should include 6 to 10 aliquots that are collected from various locations within the
treatment container.' The more difficult areas of the any container to mix are the bottoms
and the sides. One. aliquot should be collected from each side of the container and a
minimum of 2 aliquots from the bottom of the container. Other aliquots should be
included within the mass of the treated materials at equally spaced intervals.
If the first 20% of the samples collected in this manner pass for TCLP and the treatment
process and stabilizing additive blend remain the same then samples may be collected as
multiple aliquots (6 to 10) from anywhere within the treatment containers. The Same
procedure should be used for other waste profiling.
18. Attachment FSAP-1 does not include sample locations as stated in Section 1.6.2 on page
1-12 of the Quality Assurance Project Plan (QAPP). Please make appropriate
corrections. The proposed sampling grids should be included on a site map or drawing.
19. There is no contaminated soil/sediment treatment Section, 02062, as noted in the Table of
Content on page I of Attachment E-1.
Mr. Luis Flores
8-8-2002
Page 5 of 5
• •
20. Section 2.2 on page 2 of the Treatability Study Repo1t in Appendix F references the
jack's Creek Supi_rfund Site. The last sentence of the first paragraph on Section 2.4 on
page 3 makes reference to Earth Tech. Please make appropriate corrections.
21. The first bullet at the top of page 4 references paint residue. There are no paint residue at
the JCBG Site. Please make appropriate corrections.
i ' 22. The headings of Tables I, 2, & 3 on page 4 and 5 of Appendix F are blacked out. This
' makes it very difficult to understand the data. Please make appropriate corrections.
23. Specific contact with the adjacent property owners is not discussed in the Community
Relations Plan, Appendix H. Based on my discussions with you Luis, there should be at
least a Fact Sheet mailing to adjacent propctty owners and Town officials. The ENT ACT
PR representative may be able to help with some of the details of the Fact Sheet. As we
' discussed an increase in traffic and a brief discussion of the work being performed would
be appropriate.
24. Some of the runoff, calculations presented in Attachment 1-1 are not readable. Please
provide better copies for the final Work Plan.
I
The State appreciates th·e opportunity to comment on this document and we look forward to I
working with you on the project. If you have any questions or comments, please call me, at
[phone], extension 34lor email at [e-mail].
cc: Dave Lown, N.C. Superfund Section
Sincerely,
n J I
~yfjcElveen
Environmental Engineer
NC Superfund Section
North Carolina
Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director August I, 2002
Steve Phibbs/Steve Mauney
NCDENR, Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem. NC 27107
RE: Draft Removal,Design/Removal Action Work Plans
Johnson Controls Battery Group, Inc. (JCBG) Site
NCD 000 770 487
Winston Salem, Forsyth County, North Carnlina
Dear Mr. Phibbs:
I
The Draft Ren\oval Design/ Removal Action Work Plan for cleaning up the
remaining unacceptable lead levels in soil at the Johnson Controls Battery Group Facility
and adjacent storm water basins in Walkertown, NC is attached for your review and
comment. The NC Superfund Section is in the process of reviewing this document and
the associated Health and Safety Plan. If you have comments please forward them to me
and they will be appropriately addressed. As I stated in a voice mail message the
tentative starting date for the work at the JCBG Site is August 12, 2002 and should
continue for 3 to 4 months.
' If I can answer any questions or if you have any comments, please call me at (919)
733-2801, extension 34\, email: randy.mcelveen/@ncmail.net ·
cc: Dave Lown, N.C. Superfund Section
Sincerely,
/(_~ "111 er llu-u..,,-/ cJJ:..
Randy McElveen
Environmental Engineer
NC Superfund Section
1646 Mail Sen,ice Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: vvw.v.enr.state.nc.us
AN EQUAL OPPORTUNITI' \ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ JO% POST CONSUMER PAPER
I
TRIP NOTIFICATION AND AUTHORIZATION FORM
Program:
□ CERCLA Site Assessment □ □ □
Brown fields
□ State
0 NPUDOD
Site Name:
ID Number:
Street Address:
City:
County:
MGP
Dry Cleaners
Johnson Controls Battery Group Site
West Mountain Road
Winston-Salem
Forsyth
Date(s) of Trip Trip Canceled: Trip Rescheduled (Date):
August 12, Thru
November 22, 2002
Reason For Trip: Overview of Removal Action Work in Soil and Sediment
D Surface Soil
D Subsurface Soil
D Using Augers/Shovels to collect soil
D Using Little Beaver to collect soil
D Groundwater (from tap)
Pro"ect Team Leader
Randy McE!veen
Authorized By:
(if sampling, check appropriate boxes below)
D Groundwater (hailers)
D Groundwater (pumps)
D Surface Water
D Sediment
Assistant Assistant
O[fice Use Only_
County Health Department Official Contact: /:'r-1::cf C,v~I sf-rr;_~f-
Assistant
Title: /;11v. /.((a(#,_ f)crec&_r--
Phone Number: (~s'(,,) 7;>7 _ .J7co
Health Department Official Contacted: Back Up Letter Required?: Yes -No / -k'rJ... Ove,s-frr:d f-r-02..ctJ✓.:Jt) Notes: 11/,;J,C.,.J ()\r . nN.-,sfr J--r · ,,,~ \)?1c-eM~/
' /
I
DU,lb(TRIP_N01~AUTH.FRM) Revi.\'ed: 01122!0/
.