NCD000770487_20030922_Johnson Controls Battery Group_FRBCERCLA RMVL_Removal Design Removal Action 2002 - 2003-OCR

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, 11th Floor
Atlanta, Georgia 30303
September 22, 2003
RE: Comments on the Revised Response Action Completion Report Dated August 28,
2003
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Flores:
The Removal Action Completion Report Dated August 28, 2003 for the Johnson
Controls Battery Group Site located in Walkertovm/Winston-Salem, North Carolina has
been received and reviewed. -The following comments by the North Carolina Superfund
Section are submitted for your consideration.
Specific Comments
1. On page 1 please modify the last sentence in paragraph 1 to read " .... to incorporate
comments received from both regulatory agencies in March 2003 on the draft
report." The changes are marked in bold.
2. Please add a zero before the 9 in the latitude coordinate in Section 1.1 on page 2 of
the report to remain consistent in the coordinate representation.
3. Please change the verb in the last sentence of the first paragraph in Section 1.2 on
page 2 to read "The facility and Site layouts are depicted on Drawing l ."
4. In Section 1.3.2, please define the acronym EE/CA in the first sentence of the first
paragraph instead of the second sentence. Also please modify the third sentence in
the first paragraph to read "A description of the investigation and results are provided
in Section 1.3 of the Removal Design/Removal Action (RD/RA) Workplan:·
Also remove the acronym definition for MWH from the first paragraph since it was
previously defined in Section 1.0.
i
.i
Mr. Luis Flores
9-22-2003
Page 2 of 4 • •
5. Please define TCLP in the first bulleted item under Section 1.3.2 on page 4 and
remove the definition of this acronym from the fourth bulleted item in Section 2.1 on
page 6.
6. Please define SVOC in the last bulleted item under Section 1.3.2 on page 4 and
remove the acronym definition from Section 4.8 on page 24.
7. Create a title for the table on page 5 such as "Table of Removal Alternatives".
8. On page 5, please replace "the Agencies" in the last sentence of the first paragraph
with "both USEPA and NCDENR".
9. Please add the word "the" before each occurrence of the word "Sedimentation" in the
second bulleted item under Section 2.1 on page 6.
10. In the fourth bulleted item under Section 2.1, please delete the acronym definition for
TCLP since it sho_uld be defined on page 4.
11. In the seventh and eighth bulleted items under Section 2.1, please correct
"excavation" to "excavated".
12. The fourth and fifth bullets under Sedimentation Basin 1 Area on page 7 should be
the same as the second and third bullets under Sedimentation Basin 2 and 3 Arca
under Section 2.1. Also these two bullets in each section should be combined into
one bullet since the lead levels need to meet both conditions. It seems to be a little
more confusing when each condition is listed in separate bullets.
13. In the fourth bullet under Other Actions in Section 2.1 on page 7, please modify the
item to read "Installation of a temporary access road (with modified gravel)
from .... "
14. In Section 2.2 on page 8, please add a less than symbol, <, before the two occurrences
of"400 mg/kg" so that it reads "<400 mg/kg".
15. On pages 9, 12, 16, 20, 23 and 28, reference was made to a Field Sampling and
Analysis Plan (FSAP) (pages 9 and 16) and a Field Sampling Plan (FSP) (pages 12
and 20) and a Sarp.piing and Analysis Plan (Section 4.5 on page 23). Are these
references to the saine document? If so, please define the acronym on page 9 and use
the same one throughout the entire document. If not, please make sure each is
defined on its first occurrence in the document.
16. In the second bulleted item on page I 0, define the acronym, RPM, either here or on
page 9 when the tiile Remedial Project Manager is first used in Section 2.3. Also
please remove the acronym definition for RPM on the last bullet on page 11.
Mr. Luis Flores
9-22-2003
Page 3 of4 • •
17. In the first sentence of Section 3.2 on page 13. please modify the first sentence to read
"Once all regulatory requirements and approvals were obtained to implement. ... "
since no permits arc required for the cleanup activities on Superfund sites.
18. In Section 3.2.3 on page 14 in the second paragraph, remove the acronym definition
for CGS and define the acronym when first used in the second bullet on page 6 in
Section 2.1.
19. In the third paragraph under Section 4.1. l on page 16, please add "total lead" in the
first sentence after 750 mg/kg to identify what contaminant this performance standard
is associated.
20. In the first paragraph under Section 4.1.2 on page 17, please insert "TCLP" before the
word "threshold" in the second sentence to better identify the type of threshold.
21. In the second paragraph under Section 4.1.2 on page 17, please clarify that the value
of 1,100 mg/kg is 1a total lead value and not a TCLP value. One suggestion would be
to insert "total lead" before "TCLP" in the first sentence so that it reads, " .... excess of
the 1,100 mg/kg total lead TCLP threshold criterion ... "
22. In the third paragraph under Section 4.1.2, please capitalize the words "Treatment"
and "Standard" in the third sentence.
23. In the fifth paragraph under Section 4.1.2, please modify the first sentence to read
" ... approved Subtitle D landfill facility, Piedmont Landfill, located at 9900 Freeman
Road in Kernersville, North Carolina." Also please correct the position of the period
in the last sentence of this paragraph. The changes are marked in bold.
24. In the first paragraph under Section 4.2 on page I 8, please modif')' the second
sentence and the verb tense in the third. fourth, and fifth sentences. This paragraph
should read, "Basin # 1 was delineated into four removal areas designated Basin # 1 A
through Basin #1 D. The footprint of the actual holding basin, which measured
approximately 80 feet by 150 feet, delineated Basin #lA. Basin #JB lay to the
northeast of Basin #IA and measured approximately 60 feet by 1 IO feet. Basin # 1 C
consisted of the 10 feet by 10 feet area of stockpiled soils area related to prior
maintenance activities and was located outside of the Basin # 1 footprint. Basin # 1 D
was a 10 feet wide by 100 feet long area downstream of the outlet of Basin # 1 A in the
unnamed tributary leading to Lowery Creek. The locations of the four areas in the
Basin #1 remediation area are designated in Drawing 2." The changes are marked in
bold.
Mr. Luis Flores
9-22<W03
Page 4 of 4 • •
25. In Section 4.2.2 on page 19, please add "total lead" in the first sentence before
"TCLP" so the• sentence reads " .... exceeding the I, 100 mg/kg · total lead TCLP
threshold criterion was .... "
26. In the third paragraph under Section 4.2.2 on page 20. please modify the third
sentence to read ;' .... approved Subtitle D landfill facility, Piedmont Landfill, located
in Kernersville, North Carolina."
'27. In the las\ paragraph of Section 4.3.1 on page 21, please modify the first sentence to
read " ... maximum and average concentrations of the remaining lead were less than
400 mg/kg and 100 mg/kg, respectively."
28. Please remove the space between "rip rap" in the second sentence of paragraph two of
Section 4.3.3 on page 22 to match all other spellings of"riprap" on pages 20, 22, and
7' _.J.
29. Please remove the acronym definition for SVOCs from the first paragraph on page 24
in Section 4.8 since the acronym should be defined on page 4. Also please define the
acronym M CL in the fourth sentence of this paragraph.
30. Please correct the North Carolina regulatory citations found in the bulleted items in
Section 4.8 on page 24 so that each occurrence reads "15A NCAC 2L". Please also
define the first occurrence of the regulatory citation in the first bulleted item so that
the sentence reads " .... well below the groundwater standard of 15 µg/L found in Title
15A Chapter 2 Subchapter L ofthe North Carolina Administrative Code (15A NCAC
2L)."
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 299.
cc: File
Sincerelv. ;eftl~✓-vi~
Kyle R. Hagen
En\'ironmental 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
Ms. Beverly Hudson
Remedial Project Manager
Superfund Branch
Waste Management Division
•
August 12, 2003
United States Environmental Protection Agency
Region N
61 Forsyth Street, 11 th Floor
Atlanta, GA 30303
Re: Completion Report
J Street Site
Erwin, Hamett County
Dear Ms. Hudson:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received the above document for the J Street Site. The Superfund Section has
reviewed this document and offers the following attached comments.
We appreciate the opportunity to comment on this document. If you have any questions, please feel
free to call me at [phone], extension 349.
Sincerely,
D (l_L,1.Cf. 13. fYI_ oXu s· v,-' /c
David B. Mattison, CHMM ag
Environmental Engineer
Superfund Section
Attachment
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: w,vvi.enr.state.nc.us
AN EQUAL OPPORTUNm" \ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
Ms. Beverly Hudson
August 12, 2003
-Page I
•
COMPLETION REPORT
J Street Site
General
•
I. Please revise the Completion Report to include the owners' and engineers' certification
statements, signatures, dates, and stamps as appropriate in accordance with the Unilateral
Administrative Order (UAO) issued by the United States Environmental Protection
Agency (US EPA) on August 9, 1995, for the J Street Site.
2. Please revise the Completion Report to include a brief summary of the health and safety
procedures implemented during the course of the site work, an appendix containing the
actual Health and' Safety Plan utilized for this project and an appendix containing all
laboratory analyses and other forms of documentation used to demonstrate compliance
with the health and safety plan as well as all applicable local, state and federal laws.
3. Please revise the Completion Report to include a discussion of equipment
decontamination prior to its use in "clean" areas and prior to being transported offsite,
including methodologies and disposition of residual contamination.
4. Please revise the Completion Report to include a figure documenting the Toxic
Characteristic Leachate Procedure (TCLP) lead and cadmium laboratory analysis results
for the composite, soil samples collected from each grid. The color-coding scheme used
in Drawing No. 3 may be used to demonstrate the classification of soils requiring
stabilization and soils not requiring stabilization.
5. Please revise the Completion Report to include a list of references used in the
development of this report.
Section 1.0 Introduction
6. Please correct the first sentence of Section 1.0 to state "This Non-Time Critical
Removal Action (NTCRA) Completion Report has been prepared by Black & Veatch
Special Projects Corp. (BVSPC) for Burlington Industries, Inc., and Swift Textiles, Inc.,
to comply with the Unilateral Administrative Order (UAO) issued by the United States
Environmental Protection Agency (USEPA) on August 9, 1995, for the J Street Site
located in Erwin, Harnett County, North Carolina."
. 7. Please revise the last sentence of Section 1.0 to state, "Additionally, an US EPA Action
Memorandum, issued March 26, 1998, approved the remedy."
Ms. Beverly Hudson
August 12, 2003
-Page 2
•
Section 1.2.l Operations
•
8. Please correct the second sentence of Section 1.2.1 to state, "Burlington Industries, Inc.,
acquired Erwin Mills, Inc., in 1962 and merged the latter with itself in 1970."
Section 1.2.4 Description of Selected Remedial Action
9. Please correct the last sentence of Section 1.2.4 to state, "Major components of the
remedial action include soil classification, treatment, and disposal; site restoration and
drainage ditch improvements to prevent erosion from impact by the remedy."
Section 2.1 Mobilization
I 0. Please revise Section 2.1 to include greater detail regarding site preparation activities with
particular emphasis on such activities as laydown area preparation, temporary erosion
control measures installation, perimeter fencing installation, decontamination pad
construction, air monitoring devices setup, and establishment cif work zones.
Section 2.2.l Vegetation Clearing
11. The last sentence of Section 2.2.1 indicates that the removed vegetation was disposed in
the Sub-Title D Resource Conservation and Recovery Act (RCRA) facility, Sampson
County Landfill, in Roseboro, North Carolina. Please revise the Completion Report to
clarify if both the mulch and the sectioned trees were disposed at the Sampson County
Landfill and how many loads of each were disposed. Additionally, please revise the
Completion Report to include all manifests and disposal tickets associated with the
disposal of the removed vegetation.
Section 2.2.2 Soil Classification Sampling and Removal
12. Please correct the second sentence of Section 2.2.2 to state, "Composite soil samples
were constructed from five distinct grab samples collected in each grid and analyzed for
leachable lead and cadmium using the Toxicity Characteristic Leachate Procedure
(TCLP)."
13. Please revise Section 2.2.2 to include greater detail regarding the soil sampling activities;
means of excavation, stockpiling, loading and transportation for disposal; the quantity of
soils removed; confirmation of excavation of all contaminated materials, etc.
14. Please revise the Completion Report to include copies of all manifests and disposal
tickets for the transportation and disposal of soils not requiring stabilization.
Ms. Beverly Hudson
August 12, 2003
-Page 3
• •
Section 2.2.3 Ponded Water Management and Lagoon Soils Removal
15. Section 2.2.3 indicates that three surface water samples were collected and analyzed for
biochemical oxygen demand (BOD), chemical oxygen demand (COD), Target Analyte
List (T AL) metals, and cyanide. However, Appendix D indicates that three surface water
samples were collected and analyzed for volatile organic compounds (VOCs) and a
surfactant, MBAS, which is not identified. Additionally, Appendix D indicates that two
of the three surface water samples were analyzed for TAL metals content. Please clarify
this discrepancy.
16. Please revise Section 2.2.3 to include greater detail regarding the pumping and disposal of
the ponded water, including, but not limited to, how the water was pumped, use of the
settling tank, discharge into the manhole, quantity discharged, tank and ancillary
equipment decontamination, disposition of sediments, etc.
17. Section 2.2.3 indicates that the soils of the lagoon were characterized for disposal.
However, no documentation of the waste characterization has been included in the
Completion Report. Please revise the Completion Report to include the documentation
oflaboratory analyses performed in order to characterize the soils of the lagoon.
18. Please revise Section 2.2.3 to include greater detail regarding the excavation of the lagoon
soils, including, but not limited to, the determination of the vertical and horizontal extent
of contamination; means of excavation, stockpiling, loading and transportation for
disposal; issues associated with the high moisture content of the lagoon soils; the quantity
of soils removed from the lagoon; confirmation of excavation of all contaminated
materials, etc.
19. Please revise the Completion Report to include copies of all manifests and disposal
tickets for the transportation and disposal of the soils from the lagoon.
Section 2.2.4 Soil Stabilization and Removal
20. Please correct the third sentence of the second paragraph of Section 2.2.4 to state "The
results of the confirmation sampling and disposal of stabilized soils is presented in
Appendix E."
21. Please revise the Completion Report to include copies of all manifests and disposal
tickets for the transportation and disposal of soils requiring stabilization.
Ms. Beverly Hudson
August 12, 2003
-Page 4
•
Section 2.2.8 Michael Cox Property Improvements
•
22. Please correct he first sentence of Section 2.2.8 to state, "A depth of one foot of soils was
removed from Michael Cox's backyard, replaced with structural fill and topsoil, and
sodded."
23. Although Section 2.2.8 indicates that soil was removed from Michael Cox's backyard,
replaced with structural fill and topsoil, and sodded, none of the drawings document the
performance of these activities. Please correct this oversight.
Section 3.2 Changes from the Construction Work Plan
24. Please revise the first sentence of the second paragraph of Section 3.2 to state "Air
monitoring results conducted in the excavation area at the beginning of construction were
below action levels; therefore, personal protective equipment (PPE) levels for
excavations were downgraded to Level D without the requirement for respirators on
December 12, 200;2 (Appendix I)."
Section 4.0 Project Completion
25. Please correct the first bullet item in the first paragraph of Section 4.0 to state "David
Mattison, North Carolina Department of Environment and Natural Resources."
26. Please revise the last paragraph of Section 4.0 by deleting the unnecessary bullet.
27. Please revise Section 4.0 to describe all future operation and maintenance (O&M)
activities to be conducted at the site, including the frequency and the personnel/parties
responsible for performance of these O&M activities.
APPENDIX A SURVEYED SITE DIAGRAMS
28. Please revise the surveyed site diagrams submitted as Appendix A to include the
signature, date and stamp of the licensed surveyor responsible for certifying the surveyed
site diagrams.
Drawing No. 2 Existing Conditions Survey
29. Please revise Drawing No. 2 -Existing Conditions Survey to reflect all existing
elevations as indicated on Drawing No. 3 -Post Excavation Volume Surveys.
Ms. Beverly Hudson
August 12, 2003
-Page 5
Drawing No. 3
•
I ' I
Post Excavation Volume Surveys
•
30. Drawing No. 3 indicates that Cell 5 of Remediation Area (RA) I did not contain soils
requiring stabilization prior to disposal and that Cell 8 of RA-I contained soils requiring
stabilization prior to disposal. However, the laboratory analytical results submitted as
Appendix C indicate that Cell 5 of RA-1 contained leachable quantities of the
contaminants of concern (COCs) in excess of regulatory limits, therefore requiring
stabilization prior to disposal, and that Cell 8 of RA-I did not contain leachable quantities
of the COCs in excess of regulatory limits, therefore not requiring stabilization prior to
disposal. Please clarify these discrepancies.
31. Please revise Drawing No. 3 to indicate that the cells numbered in red did not require
stabilization of soil prior to disposal and that the cells numbered in blue required
stabilization of soil prior to disposal.
32. Drawing No. 3 indicates that less than 41 % of the surveyed points achieved the
performance criteria of excavation to a depth of one foot below land surface as specified
in the UAO, the Request for Non-Time Critical Removal Action (NTCRA), and the
Request for Modification of the NTCRA. Please provide justification for the excavation
of soils to the depths shown in Drawing No. 3.
33. Drawing No. 3 provides an estimate of the volume of soil removed from each
remediation area. However, these volume estimates do not necessarily agree with the
quantities of soil provided in Appendix C and Appendix F, assuming a soil density of
90.74 pounds per cubic feet (pcf) as is given on the last page of Appendix F. Please
clarify these discrepancies.
Drawing No. 4 Final As-Built Survey
34. Please revise Drawing No. 4 to indicate the type and locations of both temporary and
permanent erosion control structures.
APPENDIXB SAMPLE AND ANALYSIS PLAN
35. The Sample and Analysis Plan submitted as Appendix Bis incomplete as it does not
include Appendices A, B or C of the Sample and Analysis Plan. Please correct this
oversight.
36. The Sample and Analysis Plan submitted as Appendix B indicates that Soil Classification
Sample Logs, Material Acceptance Analyses Sample Logs, laboratory analyses and
manufacturer certifications for a variety of materials were to be submitted for review and
acceptance. However, much of this information was inadvertently omitted from the
Completion Report. Please correct this oversight.
Ms. Beverly Hudson
August I 2, 2003
Page 6
APPENDIX E
• •
STABILIZATION PLAN
37. The Stabilization Plan submitted as Appendix Eis incomplete as it does not include
Attachments A or B of the Stabilization Plan. Please correct this oversight.
•
April 16, 2003
Memorandum
TO: Van Sullivan
County Environmental Affairs Department
537 North Spruce Street
Winston-Salem, NC 271 OJ
From: Randy McElveen
Environmental Engineer
NC Superfund Section
•
RE: Removal Action Completion (RAC) Report
Johnson Controls Battery Group, Inc. (JCBG) Site
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Sullivan:
flLE COpy
I just wanied to give you a quick update on the work at the Johnson Controls
Battery Group Facility. The environmental cleanup of lead contaminated soil and
sediment was completed in mid January 2003. Additional work continued on the
renovation of the areas and new mega-basin into March. The site has also been graded
and seeded for a final vegetative cover that should be well established if you would like
to go look at the area. The settling basin is excellent and I expect that it is one of the best
settling basins in the State.
The NC Superfund Section and the EPA Region JV was very pleased with the
quality of the soil and sediment cleanup. Initially the intent was to excavate and treat the
lead contaminated soil and sediment to the residential lead level of 400 mg/kg in the
Basin areas and to the industrial level of 750 mg/kg in the facility area. In the final
document they changed the basin areas to no single area exceeding 400 mg/kg lead and
the average lead concentration was not to exceed I 00 mg/kg. We just received the ' Removal Action Completion Report with all site screening and laboratory confirmation
samples. The average lead concentration remaining in the basin areas ranged from 14 to
46 mg/kg. This is based on the laboratory confirmation samples that were the highest lead
contamination in each grid area chosen based on X-Ray Fluorescence (XRF) field
screening.
The laboratory results in the Plant area adjacent to the loading docks was 87 .55
mg/kg and the results in the swale across the paved drive was SS.51. Two times the
average background ~oncentration from 10 samples taken within a mile of the facility for
lead was 67 mg/kg. Therefore, the NC Superfund Section does not expect to see any lead
violations or concerns in the near future from surface water discharge locations associated
with the Johnson Controls Facility. If they occur in the future it will probably be due to
additional spills from ongoing operations at the facility. 1 personally overviewed the
Removal Acti-ork. It has not yet been confirmed -also understand that some
improvements to existing unloading dock areas and unloading practices are also
underway.
Attached is the Removal Action Completion Report. The Final "as builts".
analytical data and other details of the work are included in this document. The US EPA
should also place a copy of the document at the Walkertown Public Library.
If! can answer any questions or if you have any comments, please call me, at (919) 733-
2801. extension 341, email: randv.mcclv~cnr'iimcmai l.nc!
Attachment
Sincerely, , ,,
~/0 -f-1Al(,X'-cttl\
Randy McE!veen .
Environmental Engineer
NC Superfund Section
cc: Dave Lown, NC Superfund Section
P.O. Box 29603, Raleigh, North Carolina 2761i·9603 Telephone [phone]
An Eoual Opportunity Affirmative Action Employer 50¾ Recycled I 10% Post-Consumer Paper
l'<'orth 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, I Ith Floor
Atlanta, Georgia 30303
April l 1, 2003
•
RE: Comments on the Draft Removal Action Completion Report Dated March 2003
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores:
The Removal Action Completion Report Dated March 2003 for the Johnson
Controls Battery Group Site located in Walkertown/Winston-Salem, NC has been
received and reviewed. The following comments by the North Carolina Superfund
Section are submitted for your consideration.
General Comments
I. The Cover Page, Binder slip and all headers in this report need to be changed to
reflect that this was a Removal Action not a Remedial Action.
Specific Comments
2. The third paragraph on page 14 states that: "A containment Berm was also
constructed around the perimeter of the staging and treatment area to prevent any
surface water run-off and provide a means of collecting any water that may leach
through the stockpiled material." This statement needs to be changed to reflect the
real purpose of the "containment berm". The purpose of the secondary containment
berm around the perimeter of the staging and treatment area, is to contain splashing or
over-spills and emergencv overflow from the primary staging and treatment area. If A
better definition is available please use it in place of the definition provided. If not
please use the underlined definition l have provided above.
3. The last paragraph on page 14 states that "Excavated non-hazardous soils were staged
on polyurethane sheeting ... " non-hazardous soils were staged in a cleared area
adjacent to the office trailer on existing clay materials. These non-hazardous soils
Mr. Luis Flores
4-11-2003
Page 2 of2 • •
were not staged on polyurethane. Please change this sentence to state that the non-
hazardous soils were staged in a clear area with a clayey-silt surface. We need a
composite sample from this area to confirm that this area was not cross contaminated
to above the I 00 ppm average.
4. The first paragraph on page 15 states that the ."final inspection walk-through was
conducted. To my knowledge no final inspection walk-through has been scheduled
involving ENT ACT, USEPA, NCDENR, and JCBGI representatives. This paragraph
should be changed to reflect that only a preliminary walk-through inspection was
conducted by the NC DENR and ENT ACT after the cleanup was completed. The
same or similar language should be included in the last paragraph on page 23 and
throughout the report. At the time of this report no pre-final or final inspections were
completed.
5. A word is missing in the second sentence of the second paragraph on page 17. Where
Basin #1B lies in relation to Basin #IA is not clear in this sentence. Please make
appropriate correction. These 4 sub-areas of Basin #I and the two areas of Basin #2
and the Plant area should be included on drawing 2. The data in Tables I and 2 are
unclear unless these areas are shown and referenced in a drawing.
6. The Third paragraph on page 20 states that: "As presented in Table I, the average
lead concentrations within Basin #2 and #3 Area was determined to be 56. 73 ppm
lead." Average concentrations for Basin #3 are not included in Table I. 56.73 ppm is
the Average concentration for Basin #2 alone. Please make appropriate corrections.
7. According to my calculations the average concentrations in the basin areas both
laboratory and X-Ray Fluorescence (XRF) are below the background requirements
and does not need deed recorded or Restrictions. There are still some questions and
concerns about the Plant area averages and the concentrations at the ends of the two
sub-areas of the plant. A thorough discussion involving all parties will be required
for the Plant area before determining what deed restrictions, if any, will be required.
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 (9 I 9) 733-280 I, extension 341.
~~11.l~t, l(~,
cc: Dave Lown, N.C. Superfund Section
Randy McElveen
Environmental Engineer
NC Superfund Section
March 20, 2003
Luis E. Flores
United States Environmental Protection Agency
Region 4, North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, GA 30303
Dear Mr. Flores:
I •
,. I ·· MAR L c; 2003
I 360 North Wood Dale Road
Suite A
Wood .Dale, Illinois
60191
LTR-WNSA-27
Please find enclosed two (2) copies of the Removal Action Completion Report for the
above referenced site for your review and comment. This document has been prepared
in· accordance with the Administrative Order on Consent, the Action Memorandum and
the Statement of Work (SOW). Please feel free to contact us if you have any questions
at [phone].
Respectfully submitted,
A'IMll'/"-;JQ-
Chris opher D. Preston, P.E.
ENTACT
Enclosures
Cc: (RanpyrY!cElveen -'-.!:!_COEN~ (2 copi~
Timothy-J:-t:afona -JCBGI (1 copy)
Dennis P. Reis -Dennis Reis, LLC (1 copy)
Patricia Voja , P.G.
ENTACT
n.fi3n.6J6.J/()(} • www.entacr.com • (.63(),6/6.9203
TRIP NOTIFICATION AND AUTHORIZATION FORM
Program:
□ CERCLA Site As.5csmlcnt
□ State
□ NPUDOD
Site Name:
ID Number:
Street Address:
City:
County:
Reason For Trip:
□ □ □ □ □
Surface Soil
Subsurface Soil
Using Augers/Shovels to collect soil
Using Little Beaver to collect soil
Groundwater (from tap)
Authorized By:
DUs/b([RIP _NOT_ A UTH.FRM)
□ Brownfields
□ MOP
□ Dry Cleaners
I
Trip Canceled: Trip Rescheduled (Date):
(if sampling, check appropriate boxes below)
D Groundwater (hailers)
D Groundwater (pumps)
D Surface Water
D Sediment
Revised: 01/22101
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 7, 2003 •
RE: Overview of Removal Action Work and Backfill Operations and Confirmation Sampling
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 4 December 2002, a representative of the NC Superfund Section provided overview of
removal action at the Site. The staging/treatment area was still under construction at this time and
backfill of soils in the high berm over removed for the new storm drainage route to the new mega
basin was also underway. I observed preparation and layout of the hazardous level soil and sediment
excavation areas in the drainage swale upgradient of basin #2. After removing trees from the area
excavation and confirmation of the excavation area was completed using an XRF instrument in
accordance with the Work Plan. All lead contaminated soil/sediment was excavated using a large
backhoe and transported to the staging/treatment area using a large ATV dump truck. The materials
in the staging area were covered with heavy plastic until they can be treated and disposed at a subtitle
D landfill.
Four Grid areas were sampled and confirmed with the XRF. Most of the XRF sample results
were well below the 100 ppm average for the area. Soil/sediment samples were also recovered from
each of the 4 grids for verification at a CLP laboratory. IO confirmation Samples were also taken
from around the perimeter of the excavation. The upgradient and downgradient sides of the
excavation failed to meet the 100 ppm average excavation requirement. Additional excavation will
be completed after delineation of the extent of the boundary contamination.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
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•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 7, 2003 •
RE: Overview of Removal Action Work & Construction of Proposed Treatment Staging Area
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 3 December 2002, a representative of the NC Superfund Section provided overview of
preparation for the removal action including construction of the treatment/staging area for treatment
of all large volumes of hazardous levels of lead contaminated soil/sediment. The treatment/staging
area is being constructed consistent with the leiter/email discussions with Bob Glazer of the NC
DENR Hazardous Waste Section. 20 Mil Black HDPE liner material was placed over the several
feet of red silty clay materials soils from the area. The staging area is sloping to the southwest with
the upgradient side open for access by backhoes and dump trucks. Jersey barriers around 3 sides and
a clay berm on the upgradient side, along with the slope of the area prevents mate1ial from spilling
or leaching out of the staging area. Secondary containment be1ms are also placed around the 3 sides.
Additional work will be required on the staging area before hazardous lead containing
materials can be treated in the structure. Ronda Register, ENT ACT was directing the release of
surface water from basin #I at the time I arrived. A backhoe was used to dislodge the riser structure
at a lower joint. Initially the water was slightly turbid but within a few minutes after the release the
heavy flow was clear and had no visual turbidity and did not caITy sediment out of the basin. The
water had been sampled and exceeded the average discharge limits. I requested that no further
release be performed until they assure by re-sampling that the average surface water discharge
requirements for the State are met. I observed work at the other areas of the site. Construction of
diversion structures for storm drainage from basin I was complete.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
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JCBG Site Treatment Containment Uni<iStaging A.. <::t; r ·. -+-l · 0 t"'7 GrP· r RA '\J 0~VL~t·t~ Cm L'l.11 /-ti s D"-~ · = -t) '((a... l 1\-c.:t+.i V\
Subject: JCBG Site Treatment Containment UniUStaging Area
I of I
Date: Mon, 18 Nov 2002 '17:02:44 -0500
From: Randy McElveen <[e-mail]>
To: Pat Vojack <[e-mail]>
CC: Luis Flores <[e-mail]>, DAVID LOWN <[e-mail]>,
ROBERT GLASER <[e-mail]>,
Doug Holyfield <[e-mail]>
Dear Pat,
The RCRA representative in the Raleigh Regional Office reviewed the
Revised Treatment Containment Area Construction and Stabilization
Methodology for Lead Impacted Soils and Sediment at the Johnson Controls
Battery Group Site located in Winston-Salem, Walkertown, NC. I have a
verbal concurrence on the design and request that you distribute the
letter/ design to the appropriate locations including the Site Trailer,
and as an insert into the final RD/RA Work Plan and to the EPA and the
State and to all parties that received a copy of the RD/RA Work Plan.
The State Superfund Section looks forward to working with you to
complete the remedial action at the Johnson Controls Site. If you have
any questions please give me a call or reply to this email.
Thanks Bob, for working with me to provide a sound treatment/staging
area the is consistent with NC RCRA requirements (Temporary Unit (TU)
and/or Staging Piles).
Randy McElveen, NC Superfund Section
11/18/2002 5:03 PM
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
October 31, 2002 •
RE: Overview of Site Preparation and Sediment and Erosion Control
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 30 October 2002, a representative of the NC Superfund Section provided overview of the
proposed drainage re-route work and the sediment and erosion control measures put in place as
designed or requested by the State. There had been heavy rains in the area for 3 or four days prior
to this site reconnaissance. The check dams constructed downgradient of basins 2 and 3 and other
sediment and erosion control appeared to be working very effectively. The riser pipe and other
temporary drainage piping for the re-route of storm drainage from the employees parking area has
arrived and is located in the cleared area where it will be installed. Basin# I had the design check
dam in place and it appeared to be working fairly well. Only minor silt transport was noted down
gradient of this area. Hay bails were also placed downgradient of the check dam to reduce fines.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
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•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
• October 3 I, 2002
RE: Overview of Site Preparation and Sediment and Erosion Control
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 23 October 2002, a representative of the NC Superfund Section provided overview of the
proposed drainage surveying and mega-basin excavation between basins #2 and #3 and the sediment
and erosion control measures put in place as designed or requested by the State. The excavated
residual soils (uncontaminated) were being placed in the proposed stockpile area along the north side
of the property. This stockpile area was a heavily wooded area prior to the start of the work. Check
dams had been constructed downgradient of basins 2 and 3. This appears to be sufficient to stabilize
the soil erosion downgradient of the basin areas. The basin areas should stabilize the bulk of the
sediment from the work area and the downgradient check dams and hay bails should reduce the fines
and minimize sediment and erosion in disturbed areas downgradient of the basin areas.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
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• October 15, 2002 • kD/RI\
f:Bt~=( ~~sr(~-e~nevJ
P,-c-r/'o. '1 Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
RE: Overview of Sediment and Erosion Control Effectiveness
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 15 October 2002, a representative of the NC Superfund Section provided overview of the
effectiveness of the sediment and erosion control measures at the site around Basin #1, #2, and #3
areas and the dirt access roadway to Basins #2 and #3. I noted several concerns including the
absence of any silt fence downgradient of Basin #3 and silt build-up at the silt fence downgradient
of Basin #1. Silt had also been dispersed onto the downgradient tributary of basin #2. The disturbed
roadway was also distributing silt and sediment down the hill at the tum in the road before leaving
the sewer easement. I discussed these issues with Erik Gehringer, ENT ACT after the walkover of
the area. He indicated that they would take measures to improve these areas.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
• October 11, 2002
RE: Overview of C&G and Sediment and Erosion Control Construction and Surveying of New
Storm Drainage Locations, etc. Construction Meeting with Plant and Contractors
Representatives
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 9 October 2002, a representative of the NC Superfund Section provided overview of the
installation of Silt fence and observed the clearing and grubbing of Basin #1 area and the proposed
temporary bermed drainage from the employee parking area to the proposed mega-basin. While
present at the site there was a scheduled construction meeting with various representatives from the
Johnson Controls Battery Group Site and their contractor ET ACT and the EPA and the City of
Walkertown. The agenda from the meeting included Roles and Responsibilities, Schedule and Work
Status, Health and Safety, Documentation Control and other discussions of the proposed work. We
also completed a site walkover of the basin #1 and #2 areas and other Plant and drainage paths. See
the attached agenda for the meeting and the Attendance sheet.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
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•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
•
October 8, 2002
RE: Overview of Clearing and Grubbing of Basin Areas, Surveying of New Storm Water
Drainage and Erosion Control Measures
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 8 October 2002, a representative of the NC Superfund Section provided overview the
Preparatory Work at the Johnson Controls Battery Group, Inc. Site located in Walkertown, NC.
Clearing and grubbing of the Mega-Basin Area and proposed stockpile area and existing Basin #2
and #3 areas was observed. The surveyors STANTEC, Inc. was relocating control points and
locating the new stonn water drainage locations and structures to the proposed mega-basin area from
the worker parking area. Some Erosion Control was in place around the office trailer work area but
not in other areas of the site. I discussed the sediment and erosion control concerns with Erik
Gehringer, and Paul Medrano of ENT ACT, Inc.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
•
October 4, 2002
RE: Overview of Clearing and Grubbing of Staging Area, Surveying of Property Lines and
Installation of Proposed Sediment and Erosion Control Measures
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 3 October 2002, a representative of the NC Superfund Section provided overview the
initial start of work at the Johnson Controls Battery Group, Inc. Site located in Winston-Salem, NC.
Clearing and grubbing of the proposed site for the office trailers and the proposed treatment/ staging
area was underway, early, Thursday morning. I observed the clearing work and some survey work
around Sediment Basin #3 and discussed the proposed schedule and installation of sediment and
erosion control structures around the area with Erik Gehringer, ENT ACT, Inc. A Utility locating
company was also on-site identifying underground utilities. The surveying crew will also layout the
proposed excavation areas and contaminated soil areas.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
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10:40am From-North Superfund [phone] T-554 P.001/00, F-161
OPTIONAL FORM 99 (7-90) • FAX TRANSMITTAL
F'nane 11
GENERAL SERVICES ADMINISTRATION
4WD-NSMB
ACTION MEMORANDUM
•w~, /~~~a,.,,..J.
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CC., " • .:f;, ~ tfrl"J -2.}.., ~,,. .
~~
SUBJECT: Request for a Removal Action at the Johnson Control Battery Group Site in
Walkertown, Forsyth County, North Carolina
FROM: Luis E. Flores, Remedial Project Manager
North Site Management Branch
TO: Richard D. Green, Director
Waste Management Division
Site ID: NCD000778487
I. PURPOSE
The purpose of this Action Memo is to request and document approval of the proposed
removal action described herein for the Johnson Control Battery Group Site ("the Site'') located
at 2701 Johnson Controls Road, W.ilkertown, Forsyth County, North Carolina.
II. SITE CONDITIONS AND BACKGROUND
A. Site Description
1. Removal Site Evaluation
Johnson Controls Battery Group, Inc. (JCBGI) has operated a lead-acid automotive
battery manufacturing facility since the late 1970s. Historical releases of lead compounds to soils
and sedimentation basins, and releases of sulfuric acid to soils, have occurred at the Facility. In
1979, 3,000 gallons of sulfuric acid was spilled during transfer from a rail car. The sulfuric acid
impacted soil was neutralized with lime and drummed for off-Site disposal at a certified landfill.
In August l 981, approximately 1,000 gallons of lead oxide and lead sulfate containing
wastewaters we,e spilled into sedimentation basin #1. In 1983, approximately 324 tons of lead-
impacted sediment associated with the spill was removed from sedimentation basin #I and
disposed of off:Site at a RCRA landfill.
During the 1990s, several investigations were conducted by the North Carolina
~\ay-i 3-02 iO:lOam From-North Suporfund [phone] T-554 P 002/00i F-i62 • •
2
Department of Environment and Natural Resources (NCDENR) and the United States
Environmental Protection Agency (EPA), which revealed the presence of lead in soil at the Site.
The NCDENR conducted an Expanded Site Investigation (ESI) and recommended further action
under CERCLA. On April 23, 2000, JCBGI and the EPA Region 4 entered into an
Administrative Order on Consent, Docket No. 00-21-C, to conduct an Engineering
Evaluation/Cost Analysis (EE/CA) at the Site. The Consent Order required JCBGI to collect all
necessary data to determine the extent of contamination for all media (sediments, soil, surface
water and groundwater), and that support the necessary response action for each media of
concern. The final EE/CA report was issued on March 2002.
The EE/CA investigation concluded that leaawas detecteQ_in soil/sediments at Site,
mainly in areas where overland transport of materials occurs via storm water runoff. The highest
concentrations of lead contamination were found in the vicinity of the presumed source areas near
the manufacturing plant, and in particular, the lead oxide unloading area. Lead was also present at
elevated levels in the sedimentation basin I, which historically has received runoff from the source
area. Significantly lower levels of lead were present in the other two sedimentation basins 2 and 3,
which historically have received runoff from the warehouse side of the plant.
2. Physical Location
The Site is an automobile battery manufacturing plant on approximately 75 acres. The
Site is located at 2701 Johnson Controls Road, Walkertown, Forsyth County, Nonh Carolina.
The Site location is also identified as 36°07'9" North latitude and 80°09'38" West longituc!e as
scaled from the U.S. Geologic Survey (USGS) 7.5-minute topographic map of the area (Winston-
Salem East, North Carolina Quadrangle, 1950 Revised 1994).
The automobile battery manufactu1ing plant is located near the top of a ridge that slopes
to the west and northwest towards Lowery Mill Creek. Deciduous forest comprises the areas
north, west, and so11theast of the manufacturing plant (defined as outside the fenced area) down
to a riparian environment along Lowery Mill Creek. The riparian environment along Lowery Mill
Creek consists of wetland, deciduous forest, and not maintained grass areas. The not maintained
grass areas are associated with a power line easement running north-south, roughly parallel to
Lowery Mill Creek. Lowery Mill Creek flows to the south and discharges to Salem Lake.
The vicinity of the Site generally consists of light commercial industry, agricultural, and
residences. Light commercial and residences are located along the eastern and southern Site
boundaries. To the southwest of the Site land use is primarily agricultural. To the west and
northwest of the Site the land is. primarily undeveloped forest.
3. Site Characteristics
May-13-01 10:40am From-North Superfund •404 561 8768 T-554 P 003/00, F-161 • •
3
Johnson Controls Battery Group, Inc. (JCBGI) owns and operates a lead-acid automotive
battery manufacturing facility since the late 1970s. The facility is currently operating and consists
of a large l:iattery manufacturing building, a trailer maintenance building, a battery storage
warehouse, a concentrated acid storage building, an acid mixing building, a wastewater
pretreatment system, a guardhouse, and offices. Other areas of the Site include large asphalt
parking surfaces and maintained grass areas. A chain link fence encloses all the above-mentioned
areas with access controlled by a security guard. The Site also includes the sedimentation basins
area to the west of the main manufacturing plant, and wetland areas down gradient from the
basins.
4. Release or Threatened Release into the Environment of a Hazardous Substance or
Contaminant
The EE/CA investigation ,evealed the presence of lead on soil and sediments at the Site .
. Lead is a hazardous substance as defined by section 101(14) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended. Evidence of release
of a hazardous substance includes sampling data collected during the EE/CA investigation. The
EE/CA investigation concluded that lead contamination is presence in soil/sediments at the Site.
a. The high concentrations of lead contamination were found in soil in the vicinity of
the presumed source areas near the manufacturing plant, and in particular, in the
soil around the lead oxide unloading area (l2 -3100 mg/kg).
b. Lead was also present at elevated levels in soil and sediments in and around
sedimentation basin 1 (8.9 -2800 mg/kg), which historically has received runoff
from the source area; and in and around the other two sedimentation basins 2 and
3 , which historically have received runoff from the warehouse side of the plant
(8.9 -2200 mg/kg).
5. National Priority List (NPL) Status
This site is not on the NPL nor is it likely to go on the !'.'PL in the future.
6. Maps, Pictures, and Other Graphic Materials
Maps and other graphic materials are part of the EE/CA report attached to this Action
Memorandum.
B. Other Actions to Date
May-, 3-01 10:41am from-North Suporfund [phone] T-554 ? 004/009 H 62 • •
4
1. Previous Actions
There have been no known actions by other entities to mitigate conditions at the
Sire other than the ones mentioned on Section ILA. I of this Action Memorandum.
2. Current Actions
There are no other response actions currently being conducted at the Site.
C. State and Local Authorities' Roles
During the 1990s, several investigations were conducted by the North Carolina
Department of Environment and Natural Resources (NCDENR) and the EPA. The NCDENR
conducted an Expanded Site Investigation (ESI) and recommended further action under
CERCLA.
The NCDEi'.'R, Forsyth County and City officials were gi vcn the opportunity to
panicipate during the development of the EE/CA. They were kept involved by either reviewing ,,,
and providing input on draft documents, or by meetings to report and seek feedback after mayor
milestones were achieved. The NCDENR was also very involved providing field oversight during
sampling activities.
EPA will continue to coordinate with state, city and county officials to distribute and
disseminate relevant information regarding site activities to the local authorities and the public in
general.
III. THREATS TO PUllLIC HEALTH OR WELFARE OR THE ENVIRONMENT
Ai'iD STATUTORY AND REGULATORY AUTHORITIES
A. Threats to Publk Health or Welfare
The Human health risk assessment concluded that soil and sediments at the Site are the
media that pose ·a potential risk to humans. Potential risks to Facility workers and maintenance
contractors, as well as on-Site construction workers in the plant area and basin area can be
attributed primarily to lead and secondarily to benzo(a)pyrene in Site soils or sediments.
-Actual or potential exposur~ to hazardous subsrances or pollutants or contaminanrs by nearby
popularions or the food chain.
Lead and benzo(a)pyrene were evaluated in regard to their potential human health risk in
the plant area (fenced/access controlled area) by comparing soil and sediment concentrations to
IO: di am T-55• P 005/009 f-151
5
their generic industrial Soil Screening Levels (SSL) of 750 <llld 0.3 mg/kg, respectively. In the
basin areas, Lead was evaluated in regard to its potential human health risk by comparing soil and
sediment concentrations to its generic residential SSL of 400 mg/kg. Concentr:ations above these
limits were associated with hazard quotients (HQs) greater than l for lead and with cancer risks
greater than l x 10-6 for benzo(a)pyrcne.
The highest concentrations of lead contamination were found in surface soil in the vicinity
of the presumed source areas near the manufacturing plant, and in particular, in the surface soil
around the lead oxide unloading area (12 -3100 mg/kg). Lead was also present at elevated levels
in surface soil and sediments, in and around sedimentation basin l (8.9 -2800 mg/kg) and in and
around sedimentation basins 2 and 3 (8.9 -2200 mg/kg).
-High levels of hazardous subsra11ces or pollutants or contaminants i11 soils largely at or near
rhe surface, char may migrate.
Because of the location of the high concentrations of lead in surface soil and sediments, the
potential for migration exists. Sedimentation basins 1, 2 and 3 discharge outside of the Johnson
Controls property into unnamed tributaries and wetland environments of Lowery Mill Creek.
B. Threats to the Environment
An ecological nsk assessment was conducted to evaluate whether sensitive habitats on the
Site would be affected by the contamination from the JCBGI Facility. A screening level
ecological assessment (SL.ERA) was conducted, and sediment toxicity testing were conducted for
the wetland area located off the JCBGI property. This wetland area has received drainage from
the plant area and contains potentially sensitive ecological habitat. The plant orea and the basin
area will undergo major physical changes associated with clean up activities, and the upgrade of
the storm water management system. A qualitative assessment of the potential ecological
implications of the contaminant concentrations remaining in the basin area after the clean up and
storm water management improvements are completed, was also evaluated
-Actual or potelllial conraminario11 of sensitive ecosystems.
Lead was present at elevated levels in surface soil and sediments in and around
sedimentation basin I (8.9 -2800 mg/kg), which historically has received runoff from the source
area; and in and around the other two sedimentation basins 2 and 3 , which historically have
received runoff from the warehouse side of the plant (8.9 -2200 mg/kg).
-High levels of hazardous substances or pollutants or contaminants i11 soils largely at or near
the suiface, that may migrate.
The high concentrations of lead contamination were found in soil rn the vicinity of the
presumed source areas near the manufacturing plant, and in particular, in the soil around rhe lead
oxide unloading area (12 -3100 mg/kg). Lead was also present ar elevated levels in soil and
sediments in and arnund sedimentation basin I (8.9 -2800 mg/kg) , which historically has
10:42am From-North Suparfund • [phone], • i-ss, P oosiooe F-162
6
received runoff from the source area; and in and around the other two sedimentation basins 2 and ·
3, which historically have received runoff from the warehouse side of the plant (8.9 -2200
mg/kg). Because of the location of the high concentrations of lead in surface soil and sediments,
the potential for migration exist. Sedimentation basins 1, 2 and 3 discharge outside of the
Johnson Controls property into unnamed tributaries and wetland environments of Lowery l',,lill
Creek.
IV. ENDANGERMENT DETER.~INATION
Actual o, threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Action Memorandum, may present an imminent
and substantial endangerment to public health, or welfare, or the environment.
V. PROPOSED ACTIONS AND ESTIMATED COSTS
A. Proposed Actions
Due to the inherent unce11ainties associated with removal site actions, the RPM/OSC, in a
manner consistent with the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), remains obligated to modify removal procedures as conditions warrant.
1. Proposed Action Description
for the purpose of describing EPA's proposed actions, the Site was divided in three Areas.
The Plant Area, Sedimentation Basin 1 Area and Sedimentation Basins 2 and 3 Area. This
section describes the proposed action for each of the areas. Other Actions to be
implemented as part of this clean up action are also described. The proposed actions
include the following:
Plant Area -consists of a large manufacturing plant, a trailer maintenance building, a
warehouse, a concentrated acid storage building, an acid mixing building, a wastewater
pretreatment system, a guardhouse, offices, asphalt parking surfaces and maintained grass
areas. This Plant area encompasses the existing fenced/access controlled area.
Excavation and off site disposal of all soil exceeding a concentration of 7 50 mg/kg
lead and 1394 ug/kg Benzo(a)pyrene.
Treatment of all soil exceeding the Toxicity Characteristic Leaching Procedure
(TCLP) threshold for lead prior to disposal Off site disposal of all treated soil.
Collect and analyze confinnatory samples from all excavated areas to verify limits of
excavation. Soil concentrations shall be below 750 mg/kg lead and 1394 ug/kg
Benzo(a)pyrene.
May-jl-02 i0:42am from-North Suparlund • [phone] • T-554 P 007/008 H62
7
Pave excavation areas around building
Re-grade, backfill with clean soil, and reestablish vegetation in all other e,1cavated
areas.
The Plant area shall be kept fenced to restrict access.
Sedimentation Basin I Area -This area includes Sedimentation Basin 1 and all the area
around it and not covered as part of the Plant Area, and Sedimentation Basins 2 and 3 Area.
Excavation and off site disposal of all soil and sediment exceeding a concentration of
100 mg/kg lead .
Treatment of all soil and sediment exceeding the Toxicity Characteristic Leaching
Procedure (TCLP) threshold for lead prior to disposal. Off site disposal of all treated
soil and sediment.
Collect and analyze confirmatory samples from all excavated areas to verify limits of
excavation. Soil and sediment concentrations shall be below 100 mg/kg lead.
Re-grade, backfill with clean soil, and reestablish vegetation in all excavated areas.
Sedimentation Basins 2 and 3 Area -This area includes the Sedimentation Basins 2 and 3
and all the area around them, and not covered as part of the Plant Area, and Sedimentation
Basin 1 Area.
Excavation and off site disposal of all soil and sediments exceeding a concentration of
400 mg/kg lead .
Treatment of all soil and sediments exceeding the Toxicity Characteristic Leaching
Procedure (TCLP) threshold for lead prior to disposal. Off site disposal of all treated
soil and sediment.
Collect and analyze confirmatory samples from all excavated areas to verify limits of
excavation. Soil and sediment concenmnions shall be below 400 mg/kg lead.
Re-grade, backfill with clean soil, and reestablish vegetation in all excavated areas.
Other Actions
JCBGI shall implement stonn water management improvements to avoid and prevent
adverse environmental impact due to facility operations. Improvements to the
operation and maintenance of the sedimentation basins shall be implemented.
Mai-13-02 10:43am •404 562 8788 1-554 ? 008/009 F-161 From-North Sitund • cf/41,~6
Deed Res<nctions ;, ""°''"~ Sm: regolatioos JRANDY PL.i le< me know
State regulation to include here as a reference ).
Fence installation around Sedimentation Basins.
Existing monitoring wells will be sampled to detennine need of any additional
groundwater work.
3. Description of Alternative Technologies
EPA' s proposed action for the Site includes treatment, excavation and off-site disposal. ·-
The treatment technology selected is Stabilization/Immobilization. Stabilization/Immobilization
of aU soil and sediments exceeding the Toxicity Characteristic Leaching Procedure (TCLP)
threshold for lead prior to disposal will allow for disposal at a non hazardous waste landfill.
4. Engineering Evaluation/Cost Analysis (EE/CA)
An EEJCA was conducted for this Site. The EE/CA Approval Memorandum dated October
31, 2000 and the EE/CA repon dated March 2002 are anached to this action memorandum.
5. Applicable or Relevant and Appropriate Requirements (ARARS)
The removal action will be in full compliance with all Federal and State applicable or
relevant and appropriate chemical-, action-, and location-, specific requirements (ARARS) ..
6. · Project Schedule
The removal action is expected to be initiated during the Summer 2002. The estimated
completion tiine for the project is six months.
B. Estimated Costs
The estimated cost to implement this action, as documented in the EE./CA report, is
$749,000. This non-time critical removal action will be performed and funded by JCBGI, and
overseen by EPA and the NCDENR.
VI EXPECTED ClIANGE IN THE SITUATION SHOULD ACTION BE DELA YEO
OR NOT TAKEN
If action is significantly delayed or not taken at the Site, the threats explained in Section ill
of this Action Memorandum will significantly increase.
May-13-02 10:43am From-North Superfund [phone] T-554. P.009/009 F-161 • •
9
VII. OUTSTANDING POLICY ISSUES
None
VIII. El'.'FORCEMENT
Johnson Control Battery Group, Inc. has been identified as the potentially responsible party
(PRP) for this Site and they are expected to fund and conduct this removal action.
IX. RECOMMENDATION
This decision document represents the selected removal action for the Johnson Control
Battery Group, Inc .. Site in Walkertown, Forsyth County, North Carolina, developed in
accordance with CERCLA, as amended, and not inconsistent with the NCP. This decision is
based on the Administrative Record for the Sit,:,.
Conditions at the Site meet the NCP section 300 415 (b)(2) criteria for a removal and I
recommend your approval of the proposed removal action.
(Approval)
(Disapproval)
Richard D. Green, Director
Waste Management Division
Attachment
Luis E. Flores, RPM Phil Vorsatz, Chief NCStvlB
Richard D. Green, Director Wl'v!J)
Date: ________ _
Date: ________ _
Frankhn Hill, Chief NSMB