NCD001810365_19981130_Martin-Marietta Sodyeco Inc. (Clariant)_FRBCERCLA RA_Remedial Design - Remedial Action 1988 - 1998-OCR

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• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
November 30, 1998
Mr. Michael Townsend
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, Eleventh Floor
Atlanta, Georgia 30303
RE: State Concurrence with the Explanation of Significant Difference
to the ROD Remedy for the Martin Marietta/Sodyeco NPL Site
Area "C" Stockpile and Area "D" Soil Remedy
Mechlenburg County, NC
NCD 001810365
Dear Mr. Townsend:
The State of North Carolina has reviewed the Explanation of Significant
Difference (ESD) to the Martin Marietta/Sodyeco NPL Site, Area "C" stockpile and Area
"D" soil remedy, received by E-mail from you on November 30, 1998. The State ofNorth
Carolina concurs with the remedy changes, subject to the following conditions.
1. Tetrachloroethylene (PCE) is a contaminant of concern (COC) included
in the Record of Decision (ROD). The biological degradation products
of PCE are trichloroethene (TCE), cis-1,2 dichloroethene '(DCE), and
vinyl chloride (VC). The degradation products from PCE should be
included in the ESD as COCs and in all future work plans for confirmation
analysis.
2. State concurrence on this Explanation of Significant Difference (ESD) and
the selected remedy for thi: site is based solely on the information
contained in the subject ESD received by E-mail on November 30, 1998.
Should the State receive new or additional information which significantly
affects the conclusions or remedy selection contained in the ROD or this
ESD, it may modify or withdra'Y this concurrence with written notice to
EPA Region IV.
3, State concurrence on this ESD in no way binds the State to concur in
future decisions or commits the · State to participate, financially or
otherwise, in the clean up of the site. The State reserves the right to
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401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/I 0% POST-CONSUMER PAPER
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Mr. Townsend
11-30-98
Page2
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review, overview, comment, and make independent assessment of all
future work relating to this site.
4. If, after remediation is complete, the total residual risk level exceeds I 0"0,
the State may require deed recordation/restriction to document the
presence of residual contamination and possibly limit future use of the
property as specified in NCGS 130A-310.8.
The State of North Carolina appreciates the opportunity to comment on the ESD
. for the subject site, and we look forward to working with EPA on the final remedy. If
you have any questions or comments, please give me a call at, [phone], extension
291.
Sincerely,
~-R.1~c~
Grover Nicholson
Remediation Branch Head
Superfund Section
cc: Phil Vorsatz, NC Remedial Section Chief .
Jack Butler, Chief NC Superfund Section
Randy McElveen, NC Superfund Section
,.
MEMORANDUM
DATE: November 30, 1998
SUBJECT: Explanation of Significant Difference
Sodyeco (Martin Marietta) Superfund
FROM: Michael F. Townsend
Remedial Project Manager
THRU: Philip Vorsatz, Chief
North Carolina Section
Robert Jourdan, Chief
North Superfund Remedial Branch
TO: Richard D, Green, Director
Waste Management Division
•
The Subject report has been prepared in accordance with CERCLA § 117 (c) and NCP §
300.435(c)(2)(i) to provide the public with detailed information.on the changes made to the ROD.
This Explanation of Significant Difference Document (ESD), will become a part of the
Administrative Record File, located at the Belmont Branch of the Gaston County Library System
Approved: __________ _
Richard D. Green, Director
Waste Management Division
Date: _____ _
•, .•
INTRODUCTION
• •
EXPLANATION OF SIGNIFICANT DIFFERENCE
SODYECO SUPERFUND SITE
CHARLOTTE, NORTH CAROLINA
The United States Environmental Protection Agency (EPA) , the lead Agency for the
Sodyeco Site (the Site), located in Charlotte, North Carolina, in collaboration with the state of
North Carolina's Department of Environmental And Natural Resources (NCDENR), is prepared
to make minor changes to the remedy as presented in the September 1987 Record of Decision
(ROD) for this site and as modified by the September 1994 Explanation of Significant Difference
for a portion of the site known as Area C.
EPA has prepared this Explanation of Significant Difference Document (ESD ), in accordance
with CERCLA § 117 (c) and NCP § 300.435(c)(2)(i) to provide the public with detailed
information on the changes made to the ROD. The ESD will become a part of the Administrative
Record File, located at the Belmont Branch of the Gaston County Library.System.
Site History and Enforcement Analysis
The Southern Dyestuff Company (Sodyeco ) began operation at the current location in
1936. Initially, the plant produced liquid sulfur dyes from purchased raw materials. American
Marietta (which become Martin Marietta in 1961) purchased the Sodyeco site in 1958. In the
early 1960's the company's product lines expanded to include bat dyes and disperse dyes. Since
that time, the company has produced specialty chemical products for the agrochemical, electronic,
explosive, lithographic, pigment, plastic, rubber and general chemical industries. Sandoz
purchased the Sodyeco Plant from Martin Marietta in 1983. Sandoz Chemicals Corporation as of
July 1, 1995, changed its name to Clariant Corporation.
The first indication of potential groundwater contamination at the Sodyeco Site was the
discovery of organic solvents in the company's potable water well in September 1980.
Contaminated groundwater was also detected in water supply wells adjacent to the plant.
Residents of five company-owned homes were vacated and the plant water supply was changed
from groundwater to surface water (Catawba River). The soils at the site were contaminated
with several volatile organic compounds ( 1,2-Dichlorobenzene, Chlorobenzene, Xylenes,)
In June 1982, a hazardous waste site investigation of the Sodyeco Site was conducted by EPA.
•
Results of surface water, groundwater and sediment samples revealed the presence of organic
contaminants in the groundwater and small amounts in surface water.
The Sodyeco Site was placed on the National Priorities List in December 1982, in'part due
to the presence of potable water wells within a three mile radius and the presence of two
municipal surface water intakes on the Catawba River. EPA and Sandoz signed a Remedial
Investigation/ Feasibility Study (RI/FS} Consent Agreement on February 10, 1986. The final
Remedial Investigation (RI) report was issued August 17, 1987, and the draft Feasibility Study
(FS) was released to the public August 19, 1987. The Record of Decision (ROD) selecting the
remedy for groundwater and soil contamination was issued in September 1987.
The remedial design and remedial action was conducted under an amendment to the
Resource Conservation and Recovery Act (RCRA) Part B Permit Number NCD00l 810365,
issued March 31, 1987.
During the evaluation of the various treatment systems, vacuum extraction technology was
utilized on a trial basis. The in-situ vacuum technology involved the installation of underground
pipes which were to be used to strip volatile organic contaminants from soil in the vadose zone.
While in the process of installing the piping, waste materials were encountered. Subsequently, a
geophysical survey and exploratory trenching was conducted to determined the extent of the
source material. The waste materials found consisted of buried drums, glass jars containing
"chemical crystals" and a tar-like substance in one central location.
Sandoz contracted GSX Services, Inc., of Pinewood, South Carolina to remove the buried
drums and contaminated soil. The excavated drums were emptied of tars and disposed of as non-
hazardous waste at the GSX Pinewood secure landfill. The tarry contents of the drums ( approx.
82 tons) were composited and disposed ofby fuel blending at the SE Chemicals/ Giants Cement.
Two thousand cubic yards of excavated contaminated soil were removed and sent to the GSX
facility located at Pinewood, South Carolina. A national capacity variance expired before the
remaining 700 cubic yards ( current estimates place the volume to be 1, 700 cubic yards) could be
sent to Pinewood, so the soils were stockpiled within Area C. The excavated area was backfilled
with clean soil.
Description of the Selected Remedy
The recommended alternatives in the ROD for the remediation of groundwater and soil
contamination at the Sodyeco Site include extraction, treatment and discharge of groundwater;
excavation and off-site treatment of soils in Area D; the capping of Area B; and treatment of
contaminated soil at Area C . The treatment of Area C soil, as further defined in the Explanation
of Significant Difference prepared in September 1994, provides for the in-situ flushing of the
residual soil contamination and vacuum extraction of the existing stockpile.
Description of Significant Difference
The September 1994 ESD provided for vacuum extraction of the existing stockpile in Area C and
• •
subsequent sampling to determine the effectiveness of the treatment . The subsequent sampling of
the stockpile demonstrated that the treatment was ineffective and that continued treatment via this
method would be equally ineffective (Letter report dated August 8, 1996, "Mounts Holly Plant
CERCLA Area C Soil Pile Sampling"). The stockpiled soils still contain relatively high levels of
Xylene, Ethylbenzene, 1,2 Dichlorobenzene and toluene. The stockpiled soil will now be included
in the off-site treatment and disposal of area D soils. This action will increase the volume being
shipped off-site by approximately I, 700 cubic yards.
Conclusion
The EPA and NCDENR believe that the change to the remedy is.protective of human
health and the environment, and complies with federal and state requirements that were identified
as applicable or relevant and appropriate to this remedial action. The revised remedy utilizes a
permanent solution and alternative treatment technologies to the maximum extent practicable for
this site.
Approved: ____________ Date: _____ _
Richard D. Green, Director
Waste Management Division
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EVENTS AT SANDOZ/MT. HOLLY PLANT AREA C
AUGUST THROUGH DECEMBER, 1990 RECE/\'F'"' REPORT ON
I. summary of Communications. NOV 17 199B
On August 23, 1990 Midwest Water Resources, S!ilREAF~TTf~~
at work in Cercla area C installing vacuum remediation wails
for a pilot plant project pursuant to Sandoz' approved
"Soils Workplan." At that time, the drillers bored into an
apparent deposit of drummed distillation tars. Sandoz
immediately investigated and asked MWRI to terminate their
work. In a letter (attachment No. l) to Mr. Kelly Ewing
dated August 28, 1990 these events were carefully
communicated to EPA.
Further investigations were conducted and the results
assembled as a report entitled, "Delineation of additional
waste deposits, CERCLA area C", dated October 15, 1990,
which was provided to both EPA and the NC Division of Health
Services, Hazardous Waste Management Branch. This report
presented the results of an electromagnetic conductivity
survey and a magnetometer survey by Law Environmental as
well as two direct physical investigations conducted by
Sandoz personnel. It is advisable to have the
"Delineation .•• " report at hand when reviewing the present
report.
Sandoz asked EPA to provide guidance for our proposed plan
to excavate the drums and remove the contaminated soil and
debris to the GSX/Laidlaw secure landfill ("Pinewood")
before the November a, 1990 land disposal variance end date.
In a letter dated October 11, 1990 (attachment No. 2) Mr.
James Scarborough provided specific guidance for this
project. Sandoz and its contractors adhered to Mr.
Scarborough's letter in our subsequent actions.
In a letter dated October 29, 1990 to James H. Scarborough
Sandoz informed EPA that excavation in area C would begin
October 31, 1990. A copy is provided in attachment No. 2.
Ms. Spring Allen of the NC Dept. of Environment, Health, and
Natural Resources was at the site during the excavation as
an observer. A letter from Ms. Allen to Ms. Jackie Miller
of EPA documenting her observations is provided in
attachment No. 3. ·
II. Regulatc,ry Considerations.
Sandoz was granted approval by the State of South Carolina
to dispose of the soil and debris from the excavation of
area C, ARF No. PW-0036-3115T.
The drums and distillation ,tars were excavated with track
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-REPORT ON EVENTS •••
page 2
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excavators.
deformed or
were placed
The drums were deteriorated and were
broken during removal. The drums and
in covered roll-off boxes.
often
contents
Contaminated soils were removed to Pinewood. Approximately
/100 cubic yards of contaminated soils were left stockpiled
on the ground because the November 8 cut-off date prevented
Sandoz from transporting and disposing of these materials at
Pinewood. These soils are presently located within the
boundaries of the CERCLA unit as depicted in the approved
RI/FS documents. They were placed on three layers of heavy
plastic and protected from weather by further layers of
plastic sheeting.
Sandoz believes that since these materials have not been
removed from the boundaries of the CERCLA treatment unit
they have not become subject to RCRA requirements.
The drums have been separated from the distillation tars so
that the drums are now considered RCRA-empty per 40CFR261.7
(b) (l)(iii) (A). GSX Services used a reinforced roll-off box
and a heavy track excavator to empty these drums. Sandoz
believes the tars have substantial BTU value, and we are
thus actively seeking vendors for fuels-blending.
Sandoz believes that since the drums and distillation tars
have not been removed from the boundaries of the CERCLA
--treatment unit they have not become subject to RCRA
requirements.
Ms. Spring Allen of NC Division of Health Services,
Hazardous Waste Management Branch was on site as an
observer. Ms. Allen was given an access badge and allowed
free entry to the site. She was present October Jl,
November 1, and November 5, 1990. A copy of Ms. Allen's
original handwritten report to Ms. Jackie Miller of EPA is
appended as attachment No. J.
III. Remediation Activities
After the ARF was granted, Sandoz moved rapidly to excavate
the materials. GSX/Laidlaw Remediation Services were
contacted to perform the work. Mobilization began October
JO, excavation began November 2, and transportation was
accomplished on November 6 and 7, 1990.
3,901,980 lb. (100 tandem-dump truckloads) of contaminated
dirt and debris were transported to Pinewood. 164,360 lbs.
of drums and distillation tars were placed in roll-off
containers. About 700 cubic yards of contaminated soils
(see attachment 4 for the results of 5 random samples) were
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REPORT ON EVENTS •••
page 3
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stockpiled in the CERCLA area. These soils were placed on
plastic sheeting and covered likewise with plastic. The
roll-offs have sturdy plasticized fabric covers to protect
their contents from rain.
Before beginning the major excavation we excavated to 15 ft.
depth all the anomalies found by the Law geophysical survey.
In the Law report the cells were numbered 1 through 6. No
materials were found in cells 1, 2, and 4. In cell 3 a few
metal fragments were found, as well as a few glass jars
(samples?). The HNu reading in cell 3 was 1 ppm. In ceJl 5
stained soil and a few sample jars (fewer than cell 3) was
found. The HNu reading in cell 5 was 5 ppm. Contamination
in cells 3 and 5 was judged to be very slight. The sample
jars and pieces of metal were removed from the soil which
was then pushed back in the holes.
We excavated cell 6 to a depth of 10 ft. and found no
contamination. However, since it was the protocol to
excavate to at least 15 ft., we continued the excavation.
At 12 ft. we began to encounter drummed distillation tars.
In fact, cell 6 proved to be about 2/3 the size of the main
excavation, significantly increasing the amount of waste.
Sandoz believes that our investigation of area Chas been
exhaustive, and that all buried materials have been located
by our techniques.
Attachment 5 is a figure prepared by Law Environmental which
shows the outline of the excavation made to remove the
buried wastes. The pit was excavated to a depth of
approximately 20 ft. The limit to excavations was set by
encounter with hard rock.
We found that as long as soil remained, more waste was
found. Rock indicated the limits of the emplacements of the
drums in both the vertical and horizontal dimensions. A
thin layer of soil (typically 5 ft.) was found above the
top-of-rock, but few drums were found in this layer. Most
drums were found beneath the level of top-of-rock. That is,
the wastes were actually located in trenches which had been
either excavated in the partially weathered rock (PWR) or
were naturally occurring within the PWR.
It is noteworthy that the excavation pit was divided into a
north part and a south-part. A rock ridge, interrupted by a
"gateway", separated the two parts.
The excavation pit area was estimated at 6000 sq. ft. The
depth was estimated at 18-20 ft., for an estimated volume of
4000-4400 cubic yards.
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REPORT OF EVENTS •••
page 4
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After the waste handling portion of the project was
completed, Lanier Grading (Matthews, NC) backfilled the
excavation with clean fill from Sandoz' on-site borrow pit.
Lanier•s estimate of the fill was 4800 cubic yards, loose-
fill. After backfilling, the area was seeded to re-
establish a ground cover.
Sandoz personnel were present at all times in order to
monitor the work and to provide guidance as required.
As of mid-December, 1990 no further work has been done at-
area C since the completion of the backfill and seeding
work.
IV. Proposed Activities
Sandoz believes that as a result of the above work, no
further remedial activities are necessary for the in situ
soils at area C. Essentially, the RI/FS and ROD argued that
the soils in area C required treatment because they formed
the source for the groundwater contamination in the area.
At this time, however, it is clear that the source has been
removed, and that further work in this area will not
substantially contribute to the reduction of mobility,
toxicity, or volume of the contaminants.
Further, EPA has typically endorsed the idea that
remediation in PWR and groundwater is limited to the pump-
and-treat alternative. The RI/FS monitoring showed
contamination only in PWR layers. Thus, we assert that no
further treatment of soils in area C is required, and that
the continued operation of the existing CERCLA groundwater
extraction wells south of area c will be appropriate for
remedial purposes.
A brief examination of attachment 3 shows that the
monitoring wells drilled in the area of pit "C-211 were
placed right among the drums in the new pit (C-4). It is
surprising that no direct hits were made on buried drums.
See attachment 6 for pages taken from the Remedial
Investigation which detail the concentrations in the
monitoring wells and present the boring logs. The figures
in attachment 6 are apparently sketches. The locations are
properly surveyed and located on the attachment 5 drawing.
Attachment 5 also shows that pit c-2 was excavated right on
top of the deposit of drums recently removed. Evidently the
waste materials were put in these pits in two phases, with a
substantial depth of fill between the top layer of wastes
and the bottom layer. It is most unfortunate that Sodyeco
(the predecessor company to Sandoz at the Mt. Holly site)
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REPORT ON EVENTS •••
page 5
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·did not discover the hidden deposits. However, it is noteworthy that the non-invasive detection methods used by Sandoz in September, 1990 (electromagnetic conductivity measurements and magnetometric techniques) did delineate the deep emplacements of drums in area c.
These two pieces of evidence strongly support the assertions that the major source of the contaminants was the recently-excavated buried wastes, and that no other undiscovered emplacements of wastes are present in area C.
Sandoz intends to vacuum remediate the 700 cubic yard pile of contaminated soils to ARARs. Five samples were taken at equal intervals along the west side of the pile. Results are shown at attachment 4, and it is clear that the distribution of the indicator compounds in the pile is quite uniform. The vacuum remediation system will include an incinerator, and will be permitted under the Mecklenburg County Air Pollution Control Ordinance. Upon reaching the ARARs, the soil pile will be spread out in the vicinity, compacted, and reseeded. ·
The RCRA-empty drums will be disposed of.at Pinewood.
The distillation tars will be incinerated or fuels-blended.
Sandoz will commission an experienced engineering consultant to further investigate the facts at area C. The results of this investigation will be presented in an amendment to the approved "Evaluation of Soil Remediation Technologies and Treatability study Workplan, Sodyeco Site" (Engineering-Science, May, 1990). We anticipate submitting this document about April 1, 1991.
v. Area D
No changes have been made in the plan for remediating area D. However, during the flurry of activity caused by the unexpected discoveries in area c, the progress of area D has been impeded. We will proceed with this work in the first quarter of 1991.
. ley, PE
vironme and Safet Manager
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October 6. 1998
Mr. Vic Ethridge
Clariant Corporation
P.O. Box 669246
Charlotte. North Carolina 28266
Subject: Report of Soil Sampling and Analysis
CERCL.-\ .-\rea D
Clariant Corporation
Mount Holly. North Carolina
L.-\ W Project 30100-5-0036-02-900
Dear Mr. Ethridge:
Law Engineering and Environmental Services. Inc. (LAW) is pleased to present this Report of Soil
Sampling and Analysis of soil samples collected from CERCLA Area D. This report has been prepared
as outlined in LA w· s Final Soil Su111p/i11g and .-1nalvsis Plan. Re,·isiun I. (Plan) dated April 17. 1998.
This report includes a brief description of the sampling, results obtained and recommendations.
On June I 0, 1998. a LAW representative was on site to collect soil samples from around the abm e
ground former fuel oil tank located in CERCLA area D. A representative from United States
Environmental Protection Agency (USEPA) was also on site to observe the sampling. Due to weather
conditions and standing water at several of the sample locations. US EPA. Cla,iant and LAW agreed to
reschedule the sampling.
In July 1-l, 1998 a LAW representative was on site to collect the soil samples from around the perimeter
of the above ground former fuel oil tank. Samples were collected using a decontaminated stainless steel
hand auger. The soil samples were analyzed for the list of constituents included in Section 4 of the Plan.
Sample locations (9 total locations) were as shown on the anached Figure I. Two soil samples were
col,lected from each location and were taken from the 0-to 6-inch depth range and at the 3-foot depth
below ground surface. A total of seventeen soil samples were collected, as opposed to the eighteen
proposed in the Plan. LAW was unable to collect one soil sample because hand-auger refusal was
encountered at sample SS-1 • s original location and at the offset approximately 3 feet west of the original
LAW Engineering and Environmental Services, Inc.
2801 Yorkmont Road · Charlotte, NC 28208
704-357-8600 • Fax [phone]
Mr. Vic Ethridge
Octoqer 6. I 998
Page 2 • •
location. Because of auger refusal during both attempts at this sampling location. only one soil sample
was collected from SS-1 at the 0-to 6-inch depth range. A duplicate soil sample of SS-2 (0-6") was also
collected and labeled SS-10 (0-6"), because it was in an area of obvious contamination. Six of the
seventeen soil samples were concentrated at three boring locations in the area of the "arc" (see Figure I).
Results of the collected samples are summarized on the attached table. The ARAR for 1.2-
Dichlorobenzcne was exceeded in borings SS-2 (3 ') and SS-10 (0-6"). The ARAR for chlorobenzene was
exceeded in borings SS-3 (0-6'"). SS-3 (3") and SS-6 (0-6''). The ARAR for tetrachloroethylene was
exceeded in boring SS-9 (3'). The ARAR for anthracene was exceeded in borings SS-2 (3'). SS-3 (0-6")
and SS-3 (3'). The ARAR for fluorene was exceeded in borings SS-2 (3'). SS-3 (0-6''), SS-3 (3') and SS-
10 (0-6"). (Note: SS-10 (0-6'') was an estimated value. see laboratory report). The ARAR for
phenanthrene was exceeded in borings SS-2 (0-6''), SS-2 (3'), SS-3 (0-6"). SS-3 (3') and SS-10 (0-6").
Sample locations SS-2 and SS-3 appear to be in an area of soil which has been impacted by constituents
at levels above their respective ARARs.
Laboratory results indicate ARAR exceedances at sample locations SS-6 and SS-9. Sample SS-6 had a
reported result of 70.6 micrograms per liter (ug/1) of chlorobenzene which exceeds the ARAR for
chlorobenzene of 60 ug/1. However. the reported result of 70.6 ug/1 is an estimated concentration.
Sample SS-9 had a reported result of 15.8 ug/1 of tetrachloroethylene which exceeds the ARAR for
tetrachloroethylene of 0.8 ug/1. The Practical Quantitation Limits (PQL) for tetrachloroethylene.
anthracene, lluorene and phenanthrene exceeded the ARARs for these constituents.
Based on the reported results. the ARARs for the Mount Holly East Plant have been met except for
sample locations SS-2 (0-6'' and 3'). SS-3 (0-6" and 3') and SS-9 (3'). and in those cases where the PQLs
exceed the ARARs. constituents were not detected based on the PQLs.
Additional soil samples are proposed to define the extent of impacted soil around the perimeter of the
former fuel oil tank in the vicinity of SS-2, SS-3 and SS-9 to determine the amount of soil to be excavated
at a later date. The soil sampling and analysis plan for the proposed additional soil sampling in the
vicinity of SS-2, SS-3 and SS-9 is included for review and approval. This plan has been updated to
include organic-free water. The locations of the proposed additional soil samples are shown on the figure
included in the plan.
Mr. Vic Ethridge
Octot)er 6, 1998.
Page 3 • •
LAW appreciates the opportunity to provide Clariant Corporation with our consulting services. Please
contact Mr. Dave Wallace at [phone] if you have any questions regarding this subminal.
Sincerely,
~EERING AND ENVlRONMENTAL SERVlCES, '"U 11 4
Rob Th=~ Cliff~P,G,
Project Geologist Senior Geologist
~t~
Principal Engineer
Registered. NC No. 20055
RT/CRL/JD\V:rt
Anachments: Table
Field Notes
Laboratory Report
Soil Sampling and Analysis Plan for Additional Assessment. CERCLA Area D
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TABLE
RESULTS OF SOIL SAMPLING
Soil Samples Collected ,July I~, 1998
Sample
Identification
1.2-Dichlorohcnzene
(ug/1)
Chlornhcnzcnc Ethylhenzcne Tricl1hm1e1!1ylcnc
(ug/1)
Tctrachloroethyknc
(ug/1) (ug/1) (ug/1)
SS-1 (0-6") < IO <2.5 <10 <2.7 <2.3
SS-1 (3') ---------------------------------------------------------------------------A ugc r Re fusa 1------------------
SS-2 (0-6") 138 <2.5 < IO <2.7 <2.3
SS-2 (3') 15,800 13.21 <10 <2.7 <2.3
SS-3 (0-6") 119 1091 < 10 <2.7 <2.3
SS-3 (3') 76.3 1341 < IO <2.7 <2.3
SS-4 (0-6") < JO <2.5 <10 <2.7 <2.3
SS-4 (3') 69.1 <2.5 <10 <2.7 <2.3
SS-5 (0-6") <10 <2.5 <10 <2.7 <2.3
SS-5 (3') 23.9 <2.5 <10 <2.7 <2.3
SS-6 (0-6") < 10 7ll:6J <JO <2.7 <2.3
SS-6 (3') 97.2 <2.5 <10 <2.7 <2.3
SS-7 (0-6") <10 I I.OJ <10 <2.7 <2.3
SS-7 (3') 68.3 <2.5 <10 <2.7 <2.3
SS-8 (0-6") < Ill <2.5 < IO <2.7 <2.3
SS-8 (3') 41.3 7.51 <10 <2.7 <2.3
SS-9 (0-6") <10 <2.5 < to <2.7 <2.3
SS-9 (3') 21.2 <2.5 < IO <2.7 15.81
SS-10 (0-6") 1,080 5.51 <10 <2.7 <2.3
Rinse Blank < Ill <2.5 <Ill <2.7 <2.3
ARAR (ug/1) 400 60 680 2.7 0.8
NOTES:
I. ug/1 = Micrograms per liter
2. Analytical method = TCLP Zero l-leadspace Extraction (ZllE)
Toluene Xyle11cs Anthract:ne Flu11rene Phenanthre11c
(ug/1) (ug/1) (ug/1) (ug/1) (ug/1)
< IO <20 <0.005 <0.005 <0.005
< IO <20 <0.005 <0.005 0.00887!
< 10 64.9 0.007751 0.009461 0.0184
<JO <20 0.005011 0.006961 0.0144
< 10 <20 0.0100 0.0108 0.0387
<10 < 21l < 0.005 <0.005 <0.005
<10 <20 <0.005 < 0.005 < 0.005
<10 <20 <0.005 <0.005 <0.005
< iO <20 <0.lX15 <0.005 <0.005
< 10 <20 <0.005 <0.005 < 0.(Xl5
<10 <20 <0.005 <0.005 < 0.()(l5
< IO <20 <0.005 <0.005 <0.005
<10 <20 <0.005 <0.005 <0.005
< IO <20 <0.005 <0.005 <0.005
<10 <20 <0.005 <0.005 <0.005
<10 <20 <0.005 <0.005 <0.005
<10 <20 <0.005 <0.005 <0.005
< IO <20 <0.005 0.007041 0.0176
< 10 <20 NA NA NA
2,000 440 0.0028 0.0028 0.0028
Prepared/Dale: RT 9/16/98
Checked/Dale: CRL 9/29/98
3. J = presence of analyte at a concentration less than the reporting limit and greater thau 1hc detection limit. See laboratory report for tleiails.
4. NA = Not Analyzcll
•
•
•
AREA D "ARC"
N-------~-
• SS-9
SS-3
FUEL OIL TANK
6' • SS-8 f ✓
SS-7
EXPLANATION
• EXISTING SOIL SAMPLE LOCATION
(SAMPLED 7 /14/98)
,.::F: FAX RECEIVED FROM CLARI ANT CORPORATION ON 12/22/97.
•
SS-4 •
• SS-5
/ss-6
'],.;
20 0
APPROXIMATE SCALE IN FEET
20
~ ~~! AND EN~R~MENTAL SER~CES
CHARLOTTE, NORTH CAROLINA
SAMPLING LOCATION MAP
DATE (o/ DATE J08 NO.
CLARI ANT CORPORATION
MOUNT HOLLY, NORTH CAROLINA
30100-5-0036 nGURE
. '
~ ;_ .'.::
'
.. :1t~l
·I :: ;,;,;
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T -

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tan I I
T • 5otan t_!
Sin.
Sin.
}
. ·--------------
CURVE FORMULAS
R-Tcol.11
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
SCIENCE AND ECOSYSTEM SUPPORT DIVISION
REGION 4
1
lhe d
1
F
amid
F
'the g
1
by·°'
& EPA-=--=-======-==-
,I
ROGER E. CARLTON
Environmental Engineer
980 COLLEGE STATION RD.
ATHEJ,IS, GA 30605-2720
CAALTON.ROGEROEPAMAIL.EPA.GOV
-~1,c.n"L Ul'l IM.
[phone]
FAX [phone]
y
C
RIGHT ANGLE TRIANGLES. Sf1narc the alti1u1lt·, 1livi,lt· 1,y I wire the
_bue. Arid quo1ient to 1,ase for hypolenuse.
Civen Ha,;e 100, Alt. io.101 +200=.~-1nn t--s~• 100 . .c; hn1.
Civrn llyp. 100, .1\lt. 2~.251 +200 = 3.125: IOO-J.12~ ""'9(,.H7 5 = llaM".
Error in first e:rnmplr, .<H)2; in last, .n.v;.
To fiml Tons or Rail in onr milt: of track: 111ultiplr ·.-.-l·i;.;lit 11rr yard
hy 11, and diviile I.Jy 7.
LEVELING, The correction for curvuture arnl rf'rrnrlinn, iu foet
and decimals of feet is equal to 0.674 d1, where d is the it is lance i11 mil{'fl.
The correction for curvature nlone is clo::;l'ly, Jd•. 'l'ht! r.omhinrd cor-
rection ia negative.
PROD.\UI.E ERROR. If di_,d,,d~,ete. are the discrepandC's of vnriuu~
results from the mean, and ,r :rd1 the sum of the squares o( Lhr.se 11iflcr•
ences and n=the number of observations, then the prohnhlr. ('rror o( the
mean=± 0.6746 ✓· :rd•::_
n (n-1)
MINUT[S IN DECIMALS or A D[GREE
l' ,Ui67 11· • lh33 ... .:JMIU ... .5107 fl' .011:1:i .. . .H:,ou
• .0333 n .2000 •• .3U07 .. .53:U " .70011 .. ,>,W\7
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• ·"""' .. • 233:1 .. • .fiOtM) .. . f,fiU7 ll .n:1:1 .. ,!IIMNI
I ,OHJJ .. .2500 •• • tl07 .. . /iSJJ .. • 751KI •• .!Jlli7
I • ICNXI .. • 21il\7 •• ,.f,333 .. . OOIMJ .. .7G07 .. .u:1:u
' .1167 l7 .:?~'.IJ ., .Hoo ., .I\Hl7 " . 783:1 ., .~r,ou
• .1333 •• . :10011 •• . 1667 •• .6JJ3 , . . HIMKI • • .nun7
I . uuo II • :11117 ,. .48:1:1 •• .MIKt .. . Mlli7 .. .!IM:U
10 .1007 .. .:1:i:1:i 30 .~XMJ •• . 11007 •• .1'-.1:13 .. 1.1111110
INCH[S IN Dt:CIMALS or A P"OOT
1-lO :1-32 '' :1.111 J• ~-IU ,, !! .. ii JI , .
.onr,i .tJt17H • 111111 .UIM .O:ZOR .0200 .tJ:113 .11417 .llf12I ,Ul\13 .117 :ro
I 2 ' I ' • ·--,--" u "' II
.0833 .1007 .2.·,00 .:1:u:1 ,.f,167 .5000 . 5833 .6f.07 .7!,(JQ .R:133 .0167
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A\ 11 /16/98+
CERCLA AREA D SAMPLING
14-Jul-98
SS1
0-6"
SS1
3'
SS2
0-6"
SS2
3'
SS3
0-6"
SS3
3'
TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE
(ppb) (ppb) (ppb) (ppb) (ppb) ppb
. . . . . . . . . . . . . . . . . . . ·.·.·.·.,.·.·.·.·.·.·.·.·.·.·.·.·.·.· ·•·.·.······························· ·.·.· .. ·.·.·.,.·.,.·.·.············ ·.·.·.·.,.·:.•····•·""'·•······· ····· ........ · ........ =· . ' . ·J ::::-::::::::::::::::::::,::::::::::::~~~='-1'1~~~~,::::: :,:::::·:: ::: ::: : : ::,::::: ::: ;:: ::;: : ::. ·.••·· ::: . :;:: :,::;;,;:::
1,2-Dichlorobenzene 400 <10 Auger 138
Chlorobenzene 60 <2.5 Refusal <2.5
Ethylbenzene 680 <10 <10 <10 <10 <10
Trichloroethylene 2.7 <2.7 <2.7 <2.7 <2.7 <2.7
Tetrachloroethylene 0.8 <2.3 <2.3 <2.3 <2.3 <2.3
Toluene 2000 <10 <10 <10 <10 <10
Xylenes 440 <20 <20 64.9 <20 <20
111111111111111111111111111111111111 llllllllllllllll 1111111111111111111111111111111111111 I llllllllllllllllll 111111111111111111 111111111111111111 11111111111111111
Anthracene 0.0028 <.005 <.005 ©©ilili&!J■ ©©§©i1~■ 0.01
Fluorene 0.0028 <.005 <.005 ©©9~6!J■ ©©696!1■ 0.0108
Phenanthrene 0.0028 <.005 ©©88fldl■ 0.0184 0.0144 0.0387
: ! . . l i .. _ ! ' I ) I · . . . I
Detected Above ARAR Limit
Above ARAR Limit but Below Reporting Limit J Value
Detected Below ARAR Limit
Detected Below ARAR Limit and Below Reporting Limit
"J" indicates the presence of the analyte at a concentration less than the reporting limit
and greater than the detection limit
•
•
A\ 11 /16/98+
CERCLA AREA D SAMPLING
14-Jul-98
■ S54 S54 S55 S55 S56 S56 S57
0-6" 3' 0-6" 3' 0-6" 3' 0-6" ~~~...:,___,i.....~~ ARAR TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE Contaminant
(ppb) (ppb) (ppb) (ppb) (ppb) (ppb) (ppb) (ppb)
··· ···:::·· ,:::::,:,:::::::::::::·····:·""··: :'.·············· ... • ... • .... ·.:.·:.•:.: L · . _ ,_ ' l 1,.. . .......... ,, ...... : ......... , •. ,. . .,, ... , 11-.. ·. · 1 •· ---.-.·.·;·.·.·.·.·.·:,:· ......... _ .. :.·.·.·.·.·.·.·.·. ·.·.·. ____ ... . . . l l
1,2-Dichlorobenzene 400 _-=-:..:.::::_---1-----'-':.........-1 • <10 69.1 <10 23.9 <10 97.2 <10
11.0J Chlorobenzene 60 <2.5 <2.5 <2.5 <2.5 rll©.6!J <2.5
Ethyl benzene 680 <10 <10 <10 <10 <10 <10 <10
Trichloroethylene 2. 7 <2.7 <2.7 <2.7 <2.7 <2.7 <2.7 <2.7
Tetrachloroethylene 0.8 <2.3 <2.3 <2.3 <2.3 <2.3 <2.3 <2.3
Toluene 2000 <10 <10 <10 <10 <10 <10 <10
Xylenes 440 <20 <20 <20 <20 <20 <20 <20
1±a±illl I I I I I I I I I ! 111 i 1111111111111 111111111 IUHU ! I 111111111111111 I 1111111111111111 111111111111111 I I i I 111111111111111 I I 111111111111111 I I 111111111111111 I I I I I I I I 11111111.
Anthracene 0.0028 <.005 <.005 <.005 <.005 <.005 <.005 <.005
Fluorene 0.0028 <.005 <.005 <.005 <.005 <.005 <.005 <.005
Phenanthrene 0.0028
Detected A
Above ARI
Detected B
Detected B
"J" indicates
and greater
<.005 <.005 <.005 <.005 <.005 <.005 <.005
l ! ,. l l
e
"\ 11 /16/98+
CERCLA AREA D SAMPLING
14-Jul-98
~ I ---Contaminant ARAR
I : < :::::: :: (ppb)
·.•;•,•.•-·:·.·.•,,,•,···-· .. •: :::::::::::::?: -· ....
1,2-Dichlorobenzene 400
Chlorobenzene 60
Ethyl benzene 680
Trichloroethylene 2.7
Tetrachloroethylene 0.8
Toluene 2000
Xylenes 440
Ullllllll!l!l!lllllllll!IIIIUttnt 1!11111111111111
Anthracene 0.0028
Fluorene 0.0028
Phenanthrene 0.0028
SS7 SSB
3' 0-6"
TCLP ZHE TCLP ZHE
(ppb) (ppb)
; . I 1 . --' ..
68.3 <10
<2.5 <2.5
<10 <10
<2.7 <2.7
<2.3 <2.3
<10 <10
<20 <20
I 111111111111 lffi 11111111111111111
<.005 <.005
<.005 <.005
<.005 <.005
-· ' ---i 1'
. !r l ~ . .. -' '
Detected A
Above ARI-
Detected B,
Detected B,
"J" indicates
and greater
SSB SS9 SS9 SS10 Rinse
3' 0-6" 3' 0-6" Blank
TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE TCLP ZHE
(ppb) (ppb) (ppb) (ppb) (ppb)
'. . I --l ~ _;:--: ~ l '! I . ' l [,.,,_,. i -• ... ., . -_, ~--' 41.3 <10 21.2 n©B© <10 • ?.SJ <2.5 <2.5 5.SJ <2.5
<10 <10 <10 <10 <10
<2.7 <2.7 <2.7 <2.7 <2.7
<2.3 <2.3 Hl.8!J <2.3 <2.3
<10 <10 <10 <10 <10
<20 <20 <20 <20 <20
1111111111111111 1111111111111111 11111111111111111 11111111111111111 11111111111111111
<.005 <.005 <.005 <.005 No Analysi~
<.005 <.005 <.005 0.00704 No Analysi~
<.005 <.005 <.005 0.0176 No Analysis
11 .. J ~--' -l I ! _--. '. ' " . '' -•
. .; . •
February 18, 1997
Mr. Michael Townsend
U.S. Environmental Protection Agency, Region IV
345 Courtland Street NE
Atlanta, Georgia 30365
Clariant Corporation
Mt. Holly Plant •
Re: Clariant Corporation -Mount Holly Plant
CERCLA.Area C Soil Pile -Off-Site Disposal
Dear Mr. Townsend:
' ')' . '
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
Rf=0r.:n/EO
FEB 18 1997
SUPEFIFUND SECTION
,_ r,.· 1r 1~ ,;·, . , :i_. • ,·, .. ,. . ";· ·.c , _, •~ ._... 1,-1 • , , •. ,~. ': . 1 •• , , • ,, •
Thank you fqr your heir, i,n.g~tting things under way)ri_the disposaJ of thy Area,C soil pilt;. -l;'rom
om conversation of February 12, ·1996, I ~nd~rsiand ih,it' t~chriically the soil pile is not c~✓ert'd
by the remedy specified in the ROD document. Therefore, an Explanation of Significant . . .
Difference (ESD) is ·all that is needed for Clari ant to begin the dismantling and proper off-site
disposal of the Area C soil pile.
From the sampling of the pile conducted in June 1996, Clariant learned that the soils still remain
highly contaminated even after several years of the soil vapor extraction treatment. This
revelation along with favorable pricing in the waste disposal industry has lead Clariant to pursue
off-site disposal as the method for addressing this soil pile. Clariant views this pile as a highly
contaminated source material which needs to be remediated so that it causes no further untoward
impact to the environment. It is believed that off-site disposal ( even though significant cost is
involved) would be the simplest, most expeditious, and most decisive way to treat this source
material.
Therefore, Clariant requests that an ESD document be created to allow the disposal of the
CERCLA Area C soil pile in an approved off-site location (namely, Stablex Canada and/or .The
Environment~l 5~~al!ty Compa~y),.. · ... : ·:c .. , : :--_ : _ . · · ,, ; ~: . . · · ·
:::·. :: ,_, _ _. .. ~r<':1..:I~() ·_' .,") ! .' ·,--n~·~",:1'. ,; ·r '.!:': M ,_·,:~r_\,;1~ ·;.,:.· -;, "(,r:.·· ,....:_ .. :' .. ;
It is important to note that Clariant would like to pursue off-site disposal of the· Area Csoil pile , 1 ,,,M ·.·c ,_,, · · '·,:_1 ~-:, ~·1':· ....... -•i.','"-,.J:~-.-~• . .-· .. ·~ ~ ,,r., _ .··•JJl
while it is economically favorable. Current pricing is favorable for this; however; this situation
could change at any t_ime. For this reason, Clariant believes that it is very important that the
Agency act expeditiously to generate the ESD so that Clari ant can dispose of the soil pile while
this favorable pricing is available.
RJ>/1v4
•
Furthermore, Clariant's understands that it must have in its possession a signed ESD before it
proceeds with the off-site disposal of the soil pile. Clariant cannot begin the project until it has
received this written approval.
Since there exists the possibility that the costs of off-site disposal could rise significantly,
Clariant would like to reserve the option of pursuing other treatment technologies for the soil pile
should pricing of off-site disposal become cost prohibitive.
I have enclosed some information on both Stablex Canada and The Environmental Quality
Company (EQ). Clariant will probably utilize both of these disposal facilities in the treatment
and disposal of the CERCLA Area C soil pile. It should be noted that both of these facilities are
pennitted to accept waste from CERCLA sites. Furthermore, the soils have been approved into
both facilities (approval letters enclosed).
The soils from the pile would be loaded at Clariant's site and transported to these facilities by
either rail car or by dump trailer. Of course, EQ would treat the waste material to the appropriate
Land Disposal Restriction standards for all of the contaminants. The treated material would then
be buried in a Subtitle C landfill. Stablex would treat and stabilize the waste material to the
standards described in the attached literature. The resulting "Stablex" mixture would then be
buried in Stablex Canada's on-site landfill. Stablex Canada, Inc. is located north of Montreal in
the province of Quebec.
Clariant would also like to take advantage of the favorable off-site disposal pricing to address
Area D contaminated soils, if necessary.
The ROD stated that about I 00-150 cubic yards of soil (in an area which is essentially an arc
around the northwest quadrant of the fuel oil tank) would be excavated and disposed of at an off-
site location. The ROD stated that this remedy would "effectively eliminate the area that
contains the highest level of contamination". To date, this excavation has not yet been
completed.
In March 1994, Clariant proposed that Area D be resampled. This was done because it was
believed that natural attenuation had occurred so that soil contaminant concentrations had
decreased significantly.
Taking this I 994 recommendation into consideration, Clariant now proposes to reevaluate the
CERCLA Area D "arc" of gross contamination. Clariant will perform an initial "unofficial"
sampling of the "arc" around the oil tank. Clariant personnel will simply use a hand auger to
collect samples from O to 4 feet. The soil samples will then be field screened with an OVM. All
samples which have elevated OVM readings will be submitted to an outside laboratory for
volatile organics analysis (8260). If this testing shows that gross contamination still exists, then
Clariant will proceed with the ROD remedy and excavate the grossly contaminated soils in the
"arc".
•
If this preliminary testing fails to show that the soils are grossly contaminated, Clariant will hire
a qualified environmental engineering firm to prepare a sampling plan for.the Agency's approval.
The purpose of this sampling plan will be to determine whether gross contamination still exists
in the area defined by the ROD. Based on the results of this sampling performed under an
approved plan, it may or may not be necessary to proceed with the excavation of the "arc".
If it is true that the gross contamination has actually naturally attenuated, there may be no need to
excavate the area, and Clariant may propose an alternative remedy for the area. If the sampling
shows that gross contamination still exists in the area, then Clariant will proceed with the
original ROD remedy.
If there is any information I can provide to you which will expedite this matter, please do not
hesitate to call me. I can be reached at 704/822-2708.
I appreciate your help, and I look forward to your response.
Sincerely,
Victor B. Ethridge
Senior Environmental Chemist
cc: R. McElveen (NCDEHNR)
K. Pathan (NCDEHNR)
G. Sanderson (Clariant)
M. Teague (Clariant)
B. Grier (Clariant)
P.O. Box 669246
• •• • Clariant Corporatio.n
Mt. Holly Plant Charlotte, NC 28266 /2.._~cy fl'\_
104.821.s6s1 o R fr
~Clariant
'·
August 8, 1996
Mr. Michael Townsend
U.S. Environmental Protection Agency, Region IV
345 Courtland Street NE
Atlanta, Georgia 30365
Re: Clariant Corporation -Mount Holly Plant
CERCLA Area C Soil Pile Sampling
Dear Mr. Townsend:
RECEIVED
AUG 127996
SUPEAFUND SECTION
On June 12, 1996, Law Engineering and Environmental Services conducted sampling of the Area
C soil pile. Randy McElveen ofNCDEHNR was present for oversight of the sampling event.
Sampling began on the southern end of the pile at discrete predetermined sample locations. A
hand auger was used to penetrate the pile and take samples a_t depths ranging from 30 to 48
inches.
At each sample location it was noticed that there were solvent odors throughout the depth of t_he
hole. Also, OVM readings of the soil cuttings were high, ranging from 84 ppm to 622 ppm.
Because of these obvious signs of substantial contamination, Clariant decided that further
sampling was pointless. Thus, the original sampling plan was abandoned.
A total of six (6) soil samples were taken instead of the twelve (12) described in the sampling
plan. Out of the six samples taken only four ( 4) were submitted to a laboratory for analysis.
Samples were submitted to the laboratory solely for informational purposes to determine the
current level of contamination.
As you will see in the attached analytical summary and laboratory reports, contaminant
concentrations in the four (4) samples submitted are well above this site's ARAR concentrations.
Therefore, it is obvious that the specified corrective action for this soil pile was ineffective at
properly remediating the soils. Since the contaminant concentrations were very high, Clariant
believes that another more effective corrective action will be necessary. Clariant plans to evaluate
other technologies as potential candidates for remediating this soil pile.
. ·~-.:-
' .~·.·.
----· ·-·--·-···-·······-. ----....... ,, ...•. ,. _______ ---~----·-... .
i .. ,
• •
As soon as the alternative corrective action for the soil pile is detennined, Clariant will submit the
conceptual plan for your review and approval.
Clariant certainly appreciates all of your help in getting the sampling plan approved. We
apologize for any in_convenience that the unproductive sampling of the pile has presented.
Should you have any questions please do not hesitate to call me at 704/822-2708 .
. Sincerely,
Victor B. Ethridge
Senior Environmental Chemist
cc: R. McElveen (NCDEHNR)
G. Sanderson (Clariant)
i·'·~-..:,,;.....,~~1,Q!S\•--...,..,~~-
'
AREACSMO.WK4\08/08/9611 :09 AM
... ,:."·' /.
CLARIANT CORPORATION • MOUNT HOLLY PLANT
CERCLA AREA CANAL YTICAL SAMPLING SUMMARY
~ : ,t, ..
·r::,:;.._~.
Sample S-2 Sample S-3
TCLP ZHE TCLP ZHE
...... Jppb)
,2-Dichlorobenzene 400 17000 9510
Chlorobenzene 60 < 1000 < 1000
Trichloroeth lene 2.7 < 200 < 200
Tetrachloroeth lene 0.8 < 200 < 200
Toluene 2000 < 200 840
s Total 440 3580 47200
680
Sample S-11 Sample S-5
TCLP ZHE TCLP ZHE VOA Total
11600 35100 2150000 • < 1000 < 1000 1630
< 200 < 200 < 40
< 200 < 200 < 40
< 200 < 200 575
620 7730
•
• • GENERAL ENGINEERING LABORATORIES
Client:
Mee1ing /oday's needs H'ith a vision for tomorrow.
CERTIFICATE OF ANALYSIS
Clariant Corporation
PO Box 669246
Contact:
Charlotte, North Carolina 28266-9426
Mr. Vik Ethridge
cc: SNOC00694
Parameter
Volatile Organics
1,2-Dichlorobenzene
Chlorobenzene
Trichloroethylene
Tetrachloroethylene
Toluene
Xylene, (fOT AL)
Sample JD
Lab ID
Matrix
Date Collected
Date Received
Priority
Collector
Qualifier Result
<
<
<
9510
1000
200
200
840
47200
The following prep procedures were performed:
TCLP Extraction -Volatiles
Comments:
Report Date: June 26, 1996
: S-3
: 9606267-01
:TCLP
: 06/121')6
: 06/14,'96
: Routine
: Client
Units Method
ug/1 EPA 8260
ug/1 EPA 8260
ug/1 EPA8260
ug/1 EPA 8260
ug/1 EPA8260
ug/1 EPA 8260
EPA 1311
A dilution was required for Volatile Organics due to the high
concentration of target analytes. As a result, the detection limits are
elevated.
GEL Laboratory Certifications
AL-41040
. CA-2089
AZ-AZ0514
CT-PH-0169
EPI Laboratory Certifications
AL-41050
CA -l-1023/2056
Page 1 of2
Analyst Date Time Batch
RMB. 06/21/96 1547 86230
RMB ~6/24/96 1212 86230
JL 06/19/96 1905 86034
AZ-AZ0514
CT-PH-0175
I ~~11111 Iii ml Iii ii~~! 11111111 1111111111111
P O Box 30712 • Charleston, SC 29417 • [phone] • Fax [phone] *9606267-01 •
ft, . . _ \_4'. ~nted on recycled paper. -~-~<~·:•:-~ ~--~ ..
I
!
j
• • GENERAL ENGINEERING LABORATORIES
A1eering today's needs wirh a vision for tomorro11·.
CERTIFICATE OF ANALYSIS
Client: Clariant Corporation
PO Box 669246
Contact:
Charlone, North Carolina 28266-9426
Mr. Vik Ethridge
cc: SNDC00694 Report Date: June 26, 1996
Sample ID
GEL Laboratory Cert!Hcatlons
DE -SC012 FL -E87156/87294
ME-SC012 MS -10120
NC-233 NY -11501
RI -135 SC -10120
TN -02934 UT-E-251
VA-00151 WA-C223
WI -999887790
This data report has been prepared and reviewed
in accordance with General Engineering Laboratories
standard operating procedures. Please direct
: S-3
EPI Laboratory Certlflcat!ons
FL -E87472/87458
NY-11502
SC -10582
UT-E-227
WA-C225
PA -68-485
any questions to your Project Manager, Karen Blakeney at [phone].
Analytical Report Specialist ~
.. -
MS -29417
RI -138
TN -02934
VA-00111
NJ -79002
WV-235
•9606267-01• PO Box 30712 ; Charleston, SC 29417 • [phone] • Fax [phone] -. ·, \i.J Print~d on_rc:ycled ~aper ..
,-,:;;-. . .,_ -,
:rr-.. -···------.-.~--.-------.. ---__ :.-; __ ~ '--~--0· ... -~:.:__ : __ ,!...,_ . ..; __ ,_..,....:. .•·• .. ·--~ -----_: ~:·. -___ ' -----.
Page 2 of2
• • GENERAL ENGINEERING LABORATORIES
Afeeting today's needs wi1h a vision for tomorrow.
CERTIFICATE OF ANALYSIS
Client:
Contact:
Clariant Corporation
PO Box 669246
Charlotte, Nonh Carolina 28266-9426
Mr. Vik Ethridge
cc: SNJX:00694 Repon Date: June 26, 1996
Sample ID : S-5
Lab ID : 9606267-02
Matrix :TCLP
Date Collected : 06/121')6
Date Received : 06/141')6
Priority : Routine
Collector : Client
Parameter Qualifier Result Unlts Method
Volatile Organics
1,2-Dichlorobenzene 35100 ug/1 EPA 8260
Chlorobenzene < 1000 ug/1 EPA 8260
Trichloroethylene < 200 ug/1 EPA 8260
Tetrachloroethylene < 200 ug/1 EPA 8260
Toluene < 200 ug/1 EPA 8260
Xylenes (!'OT AL) 7730 ug/1 EPA 8260
The following prep procedures were performed:
TCLP Extraction -Volatiles EPA 1311
Comments:
A dilution was require.cl for Volatile Organics due to the high
Page 1 of2
Analyst Date Time Batch
RMB 06/241')6 1329 86230
RMB 06/211')6 1703 86230
JL 06/191')6 1905 86034
concentration of target analytes. As a result, the detection limits are •
elevated.
GEL Laboratory Certlllcatlons EPI Laboratory Certifications
AL-41040
CA-2089
-·-·--·--·······-·-·----~ ,,,. . ' ..
AZ-AZ0514
CT-PH-0169
AL-41050
CA -l-1023/2056
AZ-AZ0514
CT-PH-0175
PO Box 30712 • Charleston, SC 29417 • [phone] • Fax [phone] •9606267-02* -. . \i;J Printed on recycled pa~~· : .
• • GENERAL ENGINEERING LABORATORIES
Meeting today's needs with a Fisionfor tomorrow.
CERTIFICATE OF ANALYSIS
Client: Clariant Corporation
PO Box 669246
Contact:
Charlotte, Nonh Carolina 28266-9426
Mr. Vik Ethridge
cc: SNDC00694 Report Date: June 26, 1996
Sample ID
GEL Laboratory Certlficatlons
DE-SC012
ME-SC012
NC -233
RI-135
TN· 02934
VA-00151
WI • 999887790
FL -E87156/87294
MS -10120
NY -11501
SC. 10120
UT-E-251
WA-C223
This data repon has been prepared and reviewed
in accordance with General Engineering Laboratories
standard operating procedures. Please direct
: S-5
EPI Laboratory Certifications
FL-E87472/87458
NY-11502
SC -10582
UT-E-227
WA-C225
PA-68-485
any questions to your Project Manager, Karen Blakeney at [phone].
Analytical Report Specialist \
MS -29417
RI -138
TN-02934
VA-00111
NJ -79002
WV -235
PO Box 30712 • Charleston, SC 29417 • [phone] • Fax [phone]_ ..,.. .
\.., ~ntcd on recycled pa~r.
Page 2 of2
1 I, • '
• • GENERAL ENGINEERING LABORATORIES
Meeting today's needs 1virh a vision for to111orro1V.
CERTIFICATE OF ANALYSIS
Client:
Contact:
Clariant Corporation
PO Box 669246
Charlotte, North Carolina 28266-9426
Mr. Vik Ethridge
cc: SNDC00694 Report Date: June 21, 1996
Sample JD
Lab JD
Matrix
Date Collected
Date Received
Priority
Collector
Parameter Qualifier
Volatile Organics
Priority Pollutani Volatiles -34 items
1, 1, 1 -Trichloroethane <
I, 1,2,2-Tetrachloroethane
1, 1,2-Trichloroethane
l, 1-Dichloroethane
1, 1-Dichloroethylene
1,2-Dichlorobenzene
1,2-Dichloroethane
1.2-Dichloropropane
1,2-trans-Dichloroethylene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2-Chloroethylvinyl ether
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon Tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
Chloroform
Dichlorobromomethane
Dichlorodifluoromethane
Ethylbenzene
Methyl Bromide
Methyl Chloride
Methylene Chloride
Tetrachloroethylene
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
<
Result
40.0
40.0
40.0
40.0
40.0
2150000
40.0
40.0
40.0
4630
12800
100
400
1000
40.0
40.0
40.0
1630
40.0
40.0
40.0
40.0
40.0
2780
40.0
40.0
94.4
40.0
: S-5 Total
: 9606267-05
: Soil
: 06/12/96
: 06/14/')6
: Routine
: Client
Units Method
ug/kg EPA 8260
ug/kg EPA8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA8260
ug/kg EPA 8260
ug/kg EPA8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA8260
ug/kg EPA 8260
ug/kg EPA8260
ug/kg EPA8260
ug/kg EPA 8260
ug/kg EPA 8260
ug/kg EPA8260
Page I of3
Analyst Date Time Batch
THL 06/17 /96 1801 86067
THL 06/20/96 1015 86067
THL 06/17/96 1801 86067
THL 06/18/96 1401 86067
THL 06/17/96 1801 86067
THL 06/18/96 1401 86067
THL 06/17/96 1801 86067
I ~Iii 111111111111111111 ill~! II~ 1111 II~ I~ 1111 ·
P0Box30712• Charleston,SC29417• [phone]• Fax[phone] •9606267-05*
ft f..1 Pri~led on recycled paper .
cc: SNDC00694
Client:
Contact:
• • GENERAL ENGINEERING LABORATORIES
Meeling today's needs H'ith a risio11for tomorrm1,1.
CERTIFICATE OF ANALYSIS
Clariant Corporation
PO Box 669246
Charlotte, North Carolina 28266-9426
Mr. Vik Ethridge
Report Date: June 21, 1996
Sample ID : S-5 Total
Page 2 of3
Parameter Qualifier Result Units Method Analyst Date Time Batch
Toluene 575 ug/kg EPA8260
Trichloroethylene < 40.0 ug/kg EPA 8260
Trichlorofluoromethane < 40.0 ug/kg EPA 8260
Vinyl chloride < 40.0 ug/kg EPA 8260
cis-1,3-Dichloropropylene < 40.0 ug/kg EPA 8260
lrans-1,3-Dichloropropy Jene < 40.0 ug/kg EPA 8260
Comments:
A dilution was required for Volatiles Orgartics due to large amounts
of hydrocarbons. As a result, the detection limits were elevated.
GEL Laboratory Certiflcadons
AL-41040
CA-2089
DE-SC012
ME-SC012
NC-233
RI -135
TN-02934
VA-00151
WI -999887790
AZ-AZ0514
CT· PH-0169
FL -E87156/87294
MS· 10120
NY -11501
SC. 10120
UT-E-251
WA-C223
EPI Laboratory Certifications
AL-41050
CA· I-1023/2056
FL· E87472/87458
NY -11502
SC -10582
UT-E-227
WA-C225
PA-68-485
THL 06/17 /96 1801 86067
AZ-AZ0514
CT-PH-0175
MS -29417
RI -138
TN -02934
VA-00111
NJ -79002
WV -235
•9606267-05• POBox30712• Charleston,SC29417• [phone]• Fax[phone] -~/ Printed on recycled paper.
• • GENERAL ENGINEERING LABORATORIES
Meeting today's needs with a vision for romorrow.
CERTIFICATE OF ANALYSIS
Client:
Contact:
Clariant Corporation
PO Box 669246
Charloue, North Carolina 28266-9426
Mr. Vik Ethridge
cc: SNDC00694 Report Date: June 26, 1996
Parameter
Vollltlle Organics
1,2-Dichlorobenzene
Chlorobenzene
Trichloroethylene
Tetrachloroethylene
Toluene
Xyleoes (TOT AL)
Sample ID
Lab ID
Matrix
Date Collected
Date Received
Priority
Collector
Quallfler Result
<
<
<
<
IJ600
1000
200
200
200
620
The following prep procedures were performed:
TCLP Extraction • Volatiles
Comments:
: S-IJ
: 9606267-03
:TCLP
: 06/12/96
: 06/14f}6
: Routine
: Client
Units Method
ug/1 EPA8260
ug/1 EPA 8260
ug/1 EPA 8260
ug/1 EPA 8260
ug/1 EPA 8260
ug/1 EPA 8260
EPA 131J
A dilution was required for Volatile Organics due to the high
concentration of target analytes. As a result. the detection limits are
elevated.
GEL Laboratory Certifications
AL-41040
CA-2089
AZ-AZ0514
CT-PH-0169
EPI Laboratory Certlllcatlons
AL-41050
CA-1-1023(2056
Page I of2
Analyst Date Time Batch
RMB 06/24fi6 1445 86230
RMB 06/2lfi6 1818 86230
JL 06/19f}6 1905 86034
AZ-AZ0514
CT-PH-0175
•
PO Box 30712 • Charleston, SC 29417 • [phone] • Fax [phone] •9606267-03•
. -. ~, Printed on recycled paper.
• • GENERAL ENGINEERING LABORATORIES
cc: SNDC00694
Client:
Contact:
Meeting today's needs with a \'is ion for to1J1orro1v.
CERTIFICATE OF ANALYSIS
Clariant Corporation
PO Box 669246
Cluirloue, Nonh Carolina 28266-9426
Mr. Vik Ethridge
Report Date: June 26, 1996
Sample ID : S-11
GEL Laboratory Certifications EPI Laboratory Certlflcatlons
DE -SC012
ME-SC012
NC-233
RI -135
TN -02934
VA-00151
WI -999887790
FL -E87156/87294
MS -10120
NY -11501
SC -10120
!IT-E-251
WA-C223
This data report has been prepared and reviewed
in accordance with General Engineering Laboratories
standard operating procedures. Please direct
FL -E87472/87458
NY-11502
SC-10582
!IT -E-227
WA-C225
PA -68-485
any questions to your Project Manager, Karen Blakeney at [phone],
•
MS -29417
Rl-138
TN -02934
VA-00111
NJ -79002
WV -235
•9606267-03• PO Box 307 J2.• Charleston, SC 294 I 7 • [phone] • Fax [phone]
~-. . --··
~.,_. Printed on_rcc~·clM ~~per. _
Page 2 of2
·-.. -'".
I , ,
I ,
• • GENERAL ENGINEERING LABORATORIES
Meeting today's needs wilh a vision for tomorroll-'.
CERTIFICATE OF ANALYSIS
Client:
ConLaCt:
Clariant Corporation
PO Box 669246
Charlotte, Nonh Carolina 28266-9426
Mr. Vik Ethridge
cc: SNDC00694 Report Date: June 26, 1996
Sample ID : S-2
Lab ID : 9606267-04
Matrix :TCLP
Date Collected : 06/12/96
Date Reteived : 06/14/96
Priority : Routine
Collector : Client
Parameter Qualifier Result Units Method
Volatile Organics
1,2.Dichlorobenzene 17000 ug/1 EPA 8260
. Chlorobenzene < 1000 ug/1 EPA 8260
Trichloroethylene < 200 ug/1 EPA 8260
Tetrachloroethylene < 200 ug/1 EPA 8260
Toluene < 200 ug/1 EPA 8260
Xylenes (TOT AL) 3580 ug/1 EPA 8260
The following prep procedures were performed:
TCLP Extraction -Volatiles EPA 1311
Comments:
A dilution was required for Volatile Orgartics due to the high
concentration of target analytes. As a result. the detection limits are
elevated.
GEL Laboratory Certifications
AL-41040
CA-2089
AZ-AZ0514
CT-PH-0169
EPI Laboratory Certifications
AL-41050
CA-1-1023/2056
Page 1 of2
Analyst Date Time Batch
RMB 06/24/96 1604 86230
RMB 06/21/96 I 934 86230
JL 06/19/96 1905 86034
AZ-AZ0514
CT-PH-0175
•
I mil ~ii ~II mil II~ H~ ~! 1rn Im! rni Ill ~11.
PO Box 307i2 • Charleston, SC 29417 • [phone] • Fax [phone] *9606267-04•
'~ . . \.;I Printed on recycled paper.
' 'I
• • GENERAL ENGINEERING LABORATORIES
Meeting today's needs with a risionfor 1011101.,-01\I.
CERTIFICATE OF ANALYSIS
Client: Clariant Corporation
PO Box 669246
Contact:
Charlotte, North Carolina 28266-9426
Mr. Vik Ethridge
cc: SNDC00694 Report Date: June 26, 1996
Sample ID
GEL Laboratory Certifications
DE-SC012
ME-SC012
NC-233
RI-135
TN -02934
VA-00151
WI -999887790
FL -£87156/87294
MS -10120
NY -11501
SC -10120
UT-E-251
WA-C223
. This data report has been prepared and reviewed
in accordance with General Engineering Laboratories
st.andard operating procedures. Please direct
: 5-2
EPI Laboratory Certifications
FL-E87472/87458
NY -11502
SC -10582
UT-E-227
WA-C225
PA-68-485
any questions to your Project Manager, Karen Blakeney at [phone].
Analytical Report Specialist \
MS-29417
RI -138
TN -02934
VA-00111
NJ -79002
WV -235
•9606267-04• P O Box 30712 • Charleston, SC 29417 • (803) 556-817 I • Fax [phone] . . '"' . . '
~, Printed On recycled paper." •
Page 2of2
Client:
Contact:
cc: SNDC00694
• • GENERAL ENGINEERING LABORATORIES
Meeting today's needs with a vision for tomorrow.
CERTIFICATE OF ANALYSIS
Clariant Corporation
PO Box 669246
Charlotte, Nonh Carolina 28266-9426
Mr. Vik Ethridge
Report Date: June 21, 1996
Sample ID : S-5 Total
GEL Laboratory Certifications
This data repon has been prepared and reviewed
in accordance with General Engineering Laboratories
standard operating procedures. Please direct
EPI Laboratory Certifications
any questions to your Project Manager, Karen Blakeney at [phone].
C=:>eoO.oo, b)
Analytical Report Specialist
*9606267-05• PO Box 30712.• Charleston, SC 29417 • [phone] • Fax [phone]
ft, \.I Printed on recycled paper.
Page 3 of3
• •
June 20, 1996
MEMORANDUM
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Remedial Overview
Site Reconnaissance and Oversight of Soil Sampling
Martin Marietta/Sodyeco
NCO 001 810 365
Mechlenburg County, North Carolina
On 11 June 1996, a representative of the NC Superfund Section and 4 Hazardous Waste
Section representatives did a facility/ site reconnaissance of the RCRA and CERCLA areas of the
Plant operations at the Martin Marietta/ Sodyeco Plant located in lvlechlenburg County. Those in
attendance included Karim Pathan, Rob McDaniel, Jill Burton, and Doug Roberts with the Hazardous
Waste Section, and Gary Sanderson, Victor Etheridge, Paige Straley, and Earl Coleman with Clariant
Corporation. The Hazardous Waste group site reconnaissance was performed in preparation for
closure of several RCRA Solid Waste Management Units (SWMUs).
On 12 June 1996, a representative of the NC Superfund Section provided the EPA remedial
oversight of the soil pile sampling event at Area "C" of the CERCLA cleanup of soils excavated from
the area and stockpiled for soil vapor extraction treatment at the Martin Marietta/Sodyeco Plant
located in Mechlenburg County, North Carolina. The Soil sampling was performed by Danny Hefner
with Law Engineering using hand auger techniques. Soil cuttings were screened by Victor Etheridge
with the Clariant Corporation using a Photo Ionization Detector (PID) and representative soil
samples were obtained from the bucket of the auger at various depths ranging from 2 to 4 feet in the
soil pile. The depth of the soil pile ranges from 6 to 8 feet above natural grade with PVC and metal
piping distributed throughout the pile at a depth of 2 to 3 feet from the natural grade and spaced
approximately 4 to 6 feet apart.
cc: NC Superfund Section
~ _LA:_Ml_• __ ~ ENGINEERING AND ENVIRONMENT Al SERVICES
March 2, 1994
Sandoz Chemicals Corporation
Highway 27 West
P.O. Box 669246
Charlotte, NC 28266
Attention:
Subject:
Gentlemen:
Mr. Michael A. Teague, Ph.D
Environmental Manager
Conceptual Work Plan
CERCLA Area C Soil Remediation Review
Sandoz, Mt. Holly Plant
Charlotte, North Carolina
LEI Job No. 56-253 lA
•
The CERCLA Area C Soil Remediation Conceptual Work Plan for the Sandoz (formerly Sodyeco) Site
is presented herein for your comments and review. Site background information is provided in Section
1 and the soil assessment is discussed in Section 2. The conceptual work plan for Area C is presented
in Section 3 and ground water is discussed in Section 4. Section 5 addresses reporting.
Law Environmental appreciates the opportunity to continue to provide our environmental-related services
to Sandoz Chemicals Corporation. If you have any questions or comments regarding this work plan
please feel free to call us at [phone].
Sincerely,
LAW ENVIRONMENTAL, INC.
Bernard B. Schumak, P.G.
Principal Hydrogeologist
~tf~~
Principal Water Resources Engineer
LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, STE. 300
CHARLOTTE, NC 28208
P.O. BOX 240674
CHARLOTTE, NC 28224-0674
704-357-1747
FAX 704·357 ·1622
OIIE OF THE lA'NCOMPAAIES
•
EXECUTIVE SUMMARY
Sandoz Chemicals Corporation Mount Holly Plant is a 1,500 acre site containing active manufacturing,
administration and storage facilities. The plant originally produced liquid sulfur dyes, but later expanded
into intermediate and specialty chemical production for various industries. The site contains five areas
(Areas A through E) which are regulated by CERCLA.
Area C previously had three disposal pits which contained drums of waste solvents, distillation tars, and
laboratory samples. An in-situ vacuum extraction system was initially proposed for remediation of soils
in Area C. During the installation of this extraction system, unknown waste materials were encountered.
The area was further assessed and contaminated materials were excavated. A soil infiltration system was
evaluated to remediate remaining contaminated soils.
Soil remediation in Area C can be facilitated by the installation of a spray infiltration system. The
conceptual design of the system includes applying plant process water using a sprinkler system and
recovering the infiltrated water downgradient from the application area. The proposed spray infiltration
system would enhance soil remediation by flushing and leaching remaining constituents from the soil.
A new ground-water recovery well (i.e., in addition to the existing ground-water recovery system for
Area C) will pump the infiltrated water from the subsurface and route it to the existing site wastewater
treatment system.
The spray infiltration system would be controlled by timers and a tensiometer. The spray application rate
will be optimized based upon tensiometer readings of soil moisture. To minimize evapotranspiration, the
timers will be set to operate the system mainly at night and early morning.
The effectiveness of the spray infiltration system will be monitored by four new monitoring wells. Water
levels in the wells will be monitored for six months before evaluation of the spray infiltration system is
completed and as-built drawings are submitted. The four new monitoring wells will be used to determine
if leachate meets ARAR standards.
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TABLE OF CONTENTS
PAGE
1.0 BACKGROUND INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
I.I Site History .............................................. 1-2
1.2 Site Geology and Soil Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3
1.2.1 Site Geology ....................................... 1-3
1.2.2 Subsurface Characteristics of Area C . . . . . . . . . . . . . . . . . . . . . . . . 1-4
1.3 Nature and Extent of Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5
I .4 Results of Previous Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6
2.0 CONCEPTUAL WORK PLAN ...................................... 2-1
2.1 Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.2 Spray Infiltration System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.2.1 Purpose for Spray Infiltration System ....................... 2-1
2.2.2 Conceptual Design for Spray Infiltration System . . . . . . . . . . . . . . . . . 2-2
2.2.3 Operation and Maintenance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3
2.3 Additional Ground-Water Recovery Well and Monitoring Well . . . . . . . . . . . . . . 2-4
2.3.1 Design Concept for Additional Recovery Well . . . . . . . . . . . . . . . . . . 2-4
2.3.2 Design Concept for Monitoring Wells . . . . . . . . . . . . . . . . . . . . . . . 2-5
2.3.3 Well Installation and Construction . . . . . . . . . . . . . . . . . . . . . . . . . 2-5
2.3.4 Well Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6
2.3.6 Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
2.3.7 Pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
2.3.8 Operation and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8
3.0 GROUND WATER .............................................. 3-1
3.1 Existing Ground-Water Recovery System . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.2 Modification to Existing Ground-Water Recovery System ................ ,• 3-1
3.3 Ground-Water Transport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.4 Treatment System . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.5 Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3
4.0 REPORTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
TABLES
No.
I
2
FIGURES
No.
I
2
3
4
5
6
7
8
9
10
APPENDICES
A
•
LIST OF TABLES AND FIGURES
Ground-water Cleanup Goals From ROD
Monitoring and Recovery Well Design/Pumping Rates
Title
Site Location Map
Location of CERCLA Area
Area C -Boring Location Plan
Area C -Generalized Profile
Analyte Concentrations (ppb) in Soil and in Ground-water Samples
Area C -Site Plan
Spray infiltration Location Plan
Typical Monitoring wells
Schematic of Typical Recovery Well
Ground-water System
Well Completion Record
•
1.0 BACKGROUND INFORMATION
Sandoz Chemicals Corporation Mount Holly Plant (formerly Sodyeco and herein referenced as such for
CERCLA activities) is located on Highway 27 West in Mecklenburg County, North Carolina (see Figure
1). The facility is bounded by the Catawba River on the west and Long Creek to the east. The majority
of the Sodyeco site shown on Figure 1 is covered by woodlands and grassed areas. Active
manufacturing, administrative, and storage facilities cover about 150 acres of the approximately 1,500
acre site. The wastewater treatment facilities are located near the Catawba River. The site contains five
areas which are regulated under CERCLA (Areas A, B, C, D and E; see Figure 2). The plant's RCRA
Part B Permit has been revised to include all CERCLA activities.
Topography within the plant manufacturing area is gently rolling. Elevations range from approximately
570 feet above NGVD (National Geodetic Vertical Datum of 1929) near the Catawba River to 670 feet
above NGVD east of the plant area.
The woodlands which surround the plant and waste treatment areas to the north, east and south are
characterized by small knolls which are dissected by numerous natural drainageways. Several knolls
exceed elevations of 650 feet above NGVD.
The area surrounding the Sodyeco site is predominantly undeveloped woodland with some residential and
light industrial areas. The outskirts of the City of Mount Holly, a power substation, a sewage disposal
plant, industrial facilities and some residential areas are located west of the Catawba River.
The Catawba River and Long Creek are the primary hydrologic features at the site. The waters of the
Catawba River are controlled by the Mountain Island Dam, located approximately 3 miles upstream of
the Sodyeco site, and the Wylie Dam located approximately 25 miles downstream of the site. The
Catawba River has a 100-year flood elevation of 575.5 feet above NGVD in the vicinity of the Sodyeco
site.
Long Creek enters the Sodyeco site at its eastern boundary and flows southwesterly across the site until
it meets the Catawba River. Surface runoff from the Sodyeco site drains primarily into Long Creek,
except in the production area where it is channeled to the wastewater treatment facility. None of the plant
facilities or CERCLA areas are within the 100-year flood plain of Long Creek. An intermittent stream
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flows southward to Long Creek along the eastern portion of the site. A small unnamed tributary is
located at the northwest corner of the site boundary and empties into the Catawba River.
The area is characterized by mild winters and warm summers: average monthly temperatures throughout
the year range from 42"F to 79°F. The mean monthly precipitation ranges from 2. 7 inches in November
to 4.7 inches in July. The annual mean precipitation is approximately 45 inches and the annual net
precipitation (i.e., annual mean precipitation minus potential evapotranspiration) is 13.8 inches.
The Sodyeco site is located in the Piedmont Province which is a generally northeast-trending
physiographic belt. A typical soil profile consists of clayey surface soil underlain by sandy silts/silty
sands and residual saprolite, which is a product of in-place weathering of rock. Partially weathered rock
forms a transition zone between soil and bedrock. Both the partially weathered rock and unweathered
rock contain fractures and joints.
Ground water is primarily recharged by precipitation and is contained in the pores of the weathered rock.
In general, fractures are not interconnected and do not provide a continuous path for ground-water flow .
over long distances. Ground water flows toward the major drainage features (such as the Catawba River,
which acts as a ground-water sink).
1.1 Site History
The Dyestuff Company began operations at the site in 1936. Initially, the plant produced liquid sulfur
dyes from purchased raw materials. American Marietta (which became Martin-Marietta in ,1961)
purchased the Sodyeco site in 1958. In the early 1960s, as the company's product lines expanded to
include vat dyes and disperse dyes, Martin-Marietta began a major effort to expand into intermediate
chemical production. Since that time, the company has produced specialty chemical products for the
agrochemical, electronic, explosive, lithographic, pigment, plastic, rubber and general chemical
industries. Sodyeco, Inc. (a former subsidiary of Sandoz U.S.A.) purchased the plant from Martin-
Marietta in 1983. The name Sodyeco, Inc. was changed to Sandoz Chemicals Corporation in 1986.
During the early years of Sodyeco's operations, wastes consisted primarily oflow volume, aqueous acidic
or alkaline streams containing inorganic salts which were discharged untreated to the Catawba River.
As production diversified and expanded, the quantity and variety of wastes also increased. The first .
waste treatment activities included the implementation of settling ponds for suspended solids,
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neutralization of waste streams, and equalization/aeration prior to discharge. Organic solvents were used
at the site in increasing amounts after World War II. Among the materials landfilled at the Sodyeco site
were residual distillation tars from solvent recovery operations, empty drums and cartons, discarded
chemicals, off-specification products, general plant wastes and construction debris. The majority of the
solid waste disposed at the site was diatomaceous earth filter cake which consisted of water, diatomaceous
filter cells and residual dye containing sulfide.
The first indication of potential ground-water contamination at the Sodyeco site was the discovery of
organic solvents in the company's potable water well in September 1980 (Law Engineering, Final Report,
Hydrogeologic Study, Sodyeco Plant, 1981). Organic constituents were also detected in the ground water
from water supply wells adjacent to the plant. Corrective action was taken by Sodyeco by providing well
owners either on-line treatment or an alternate drinking water supply. The constituents detected in the
ground water included chlorobenzene, ethylbenzene, toluene and xylene.
In December 1982, the site was placed on the National Priority List (NPL). In February 1986, the
United States Environmental Protection Agency (USEPA) and Sandoz entered into a Consent Order to
evaluate the extent of the constituent plumes in the ground water and the threat to public health and the
environment. Subsequently, Sandoz evaluated remedial alternatives at five areas designated as CERCLA
Areas A through E.
Wastewater treatment and discharge activities are regulated under the National Pollutant Discharge
Elimination System (NPDES) program.
1.2 Site Geology and Soil Characteristics
1.2.1 Site Geology
The site is located in the Piedmont Province, which is underlain by igneous and metamorphic rock. The
soil within this province is characterized by residual soils developed from the in-place weathering of
bedrock. The bedrock is a crystalline, igneous/metamorphic complex composed primarily of diorite and
granite.
The surficial soils near the Catawba River and Long Creek are alluvial materials (i.e., alluvium),
composed of silty sand and sandy silt. Variable amounts of clay, gravel and organic matter are found
within the alluvium.
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Residual soils underlie the alluvium and cover the remainder of the site, except where man-made
excavation and fill activities have altered the natural surface. The upper portion of the residuum consists
primarily of silty clays and is limited in areal extent at the site. The underlying residuum is typically
composed of micaceous silty sands and sandy silts, with a relatively low percentage of fine materials.
A partially weathered rock zone forms a transition between soil and bedrock and is characterized by
lenses of relatively sound rock separated by seams of sandy silt and silty sand.
The bedrock underlying the soils is found in varying stages of weathering. The bedrock surface is
irregular and erratic due to weathering facilitated by fractures and joints in the rock. Lenses and boulders
of hard rock and zones of partially weathered rock are commonly found within the soil mantle, well
above the general bedrock level. Thus, the boundary between soil and bedrock is poorly defined and is
transitional in nature.
1.2.2 Subsurface Characteristics of Area C
Fifteen soil borings were previously completed in Area C (see Figure 2) at the approximate locations
shown on Figure 3. A generalized northeast-southwest sectional view of Area C is shown on Figure 4.
Fill material was encountered in several of the borings at the time of installation. The fill material
consisted primarily of sandy silt and silty sands with variable amounts of wood, rock fragments, and
glass.
Beneath the fill or topsoil, most of the borings encountered residual soils. However, Borings C-3-1 and
C-3-5 encountered soil of possible alluvial origin beneath the fill within depth ranges of 13 to 17 feet
below land surface, and 9 to 17 feet below land surface, respectively. The possible alluvium consisted
of stiff to very stiff to hard sandy silt and firm to very dense silty sand.
Partially weathered rock was encountered at Borings C-1-1 through C-1-5, and C-2-1 through C-2-5,
except for Borings C-1-2 and C-1-2A, at depths varying from approximately 12 to 25 feet below land
surface. Lenses of partially weathered rock were encountered within the residual soil at Borings C-1-4
(at the 2.5-to 7-foot depth range below land surface), C-2-5 (at the 19.5-to 22-foot depth range below
land surface), and C-3-4 (at the 14.5-to 17-foot depth range below land surface). The partially weathered
rock was composed of sandy silts and silty sands with rock fragments. Ground water was encountered
at depths ranging from 12 to 23 feet below land surface.
2531·885,wP 1-4
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Borings WQ-29D and WQ-34 were completed as monitoring wells to depths of 130.5 and 159.5 feet
below land surface, respectively. In Boring WQ-29D, quartz diorite lenses were encountered from 18.5
to 30.5 feet below land surface and then partially weathered rock was present to a depth of 60.4 feet
below land surface. Bedrock encountered in the 60.4-to 130.5-foot depth range below land surface was
primarily quartz diorite, with minor amounts of quartz monzonite and granodiorite. Boring WQ-34
encountered fill to a depth of 7 feet below land surface, residuum to 23 feet below land surface, and
partially weathered rock to 110 feet below land surface. Bedrock was encountered in Boring WQ-34 in
the interval from 110 to 159.5 feet below land surface and consisted of quartz monzonite. These boring
data and information were previously presented in the "Evaluation of Soil Remedial Technologies and
Treatability Study Work Plan, Sodyeco Site", May 1990, Engineering-Science, Inc.
1.3 Nature and Extent of Contamination
Soil at each CERCLA area was sampled and analyzed, as discussed in the Record of Decision (ROD)
reached with USEPA in 1987, for the following indicator parameters:
• Trichloroethylene
• Tetrachloroethylene
• Chlorobenzene
• Ethyl benzene
• 1,2-dichlorobenzene
• Toluene
• Xylenes
Ground-water Cleanup Goals from the ROD are illustrated on Table 1. The polynuclear aromatics were
not detected in ground-water samples and the Sandoz CERCLA Ground-water Program does not require
analytical testing for these constituents (see page 3-4 of "Evaluation of Soil Remedial Technologies and
Treatability Study Work Plan, Sodyeco Site", May 1990, Engineering-Science, Inc.).
The soil boring locations and the analytes detected (October 1986 -January 1987) in the three pits in Area
Care depicted on Figure 5. The soil boring locations in Pit 1 were designated Borings C-1-1 through
C-1-5. Similarly, the soil boring locations in Pits 2 and 3 were designated Boring C-2-1 through C-2-5
and Borings C-3-1 through C-3-5, respectively. Indicator parameters were detected in soil samples in
and along the pit boundaries, with higher concentrations in the center and hydraulically downgradient of
the pits. The general direction of ground-water flow in the vicinity of Area C is toward the southwest.
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1.4 Results of Previous Investigations
Between 1986 and 1987, a Remedial Investigation (RI) was performed at the Sodyeco site to characterize
sources of the organic constituents in the ground water which originated from past disposal activities and
to assess the nature and extent of the constituents. Data were collected in sufficient detail to assess the
impact of the site on public health and the environment. On May 22, 1990, Engineering-Science of
Atlanta, Georgia submitted to Sandoz their "Evaluation of Soil Remedial Technologies and Treatability
Study Work Plan" for the Sodyeco site. This document contained the work plan for conducting
treatability studies.
Area C previously had three disposal pits which contained drums of waste solvents, distillation tars, and
laboratory samples. An in-situ vacuum extraction system for soil gas removal was proposed for closing
these three disposal pits in CERCLA Area C. These pits were designated as Pits C-1, C-2 and C-3 in
CERCLA Area C (see Figure 6). The ground-water remediation and the three former pits are described
in "Groundwater Recovery System and Area B Cap Remedial Design" (Engineering Science and Law
Environmental 1989). The waste material in these disposal pits and the visually contaminated soil were
excavated and .removed to an off-site, USEPA-permitted facility (now Laidlaw of Pinewood, South
Carolina) in 1981 and 1983. The pits were backfilled and are now grassed areas.
During the treatability study for Pit C-3, low volatile organic constituents (VOCs) concentrations were
indicated. To evaluate Pit C-3, a three dimensional grid was established with 5-foot spacing between
nodes. The grid was extended to a depth of 15.0 feet below land surface. Random soil sampling
following the above referenced work plan indicated that VOC concentrations were statistically below
Applicable, Relevant and Appropriate Requirements (ARARs). The results of this soil sampling and the
statistical analyses are contained in a report prepared by Sandoz.
During the installation of the in-situ vacuum extraction system at Pits C-1 and C-2, unknown waste
materials were encountered. In September, 1990 Law Environmental performed a geophysical survey
in the vicinity of the newly discovered waste materials. The geophysical survey was used to locate
possible buried drums. Areas were delineated in which anomalous electromagnetic responses were
detected in the surveyed area. Those areas of anomalous electromagnetic responses were grouped into
four zones based on relative intensities (Figure 6) and other characteristics (Law Environmental report
dated September 26, 1990; LEI Job No. 56-0594). Exploratory trenching with a backhoe confirmed the
presence of buried drums, glass jars containing "chemical crystals" and a tar-like substance in one central
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location while the other areas were essentially free of waste materials (Law Environmental report dated
October 10, 1990; LEI Job No. 56--0594.20).
Sandoz contracted GSX Services, Inc. of Pinewood, South Carolina to remove the discovered buried
drums and contaminated soil. Figure 6 shows the area of excavation. The excavated drums were
emptied of tars and disposed of as non-hazardous waste at the GSX Pinewood secure landfill. The tarry
contents of the drums were composited and disposed of by fuel blending at SE Chemicals/Giant Cement.
Two thousand cubic yards of excavated contaminated soil were removed and sent to the GSX (now
Laidlaw) facility located at Pinewood, South Carolina. A national capacity variance expired before the
remaining 700 cubic yards could be sent to Pinewood, so the soils were stockpiled within Area C. A
vacuum extraction system was installed and is~in oP,eration in order to bring these soils below
ARARs. . Mo c.-pl,t•J ( ~I, ,-t' ~J -s"°"""".._,,.. l 991 •
Sandoz will continue the vacuum remediation of the stockpiled soil until a TCLP ZHE leachate analysis
meets the ARARs as established in the ROD (Table I). Six equally spaced locations will be determined
on each side of the pile for a total of twelve samples. A flap will be cut through the plastic covering mid-
way up the slopes. Samples will be taken a minimum of 18 inches deep into the pile, and TCLP ZHE
leachate analysis for ARAR constituents will be performed. Refusal (from a rock or a piece of debris)
will require offsetting the hole within two feet and re-augering. If the average concentration of the
constituents is below ARARs, the pile will be considered to be remediated. Such determination will be
documented to USEPA and the State of North Carolina in a separate report.
Following remediation, the soils will be screened to remove any remaining debris. Debris will be
characterized by Sandoz environmental personnel and will be disposed of properly. The screened
material will be spread over the Area C site and tilled to mix it with the top layer of existing soil.
Appropriate amendments of lime and fertilizer will be made at this time, according to the
recommendations of an agronomist. Next, an infiltration system as described in Section 2.2.2 of this
report will be installed. After the infiltration system is installed, the area will be heavily seeded with
grass.
As shown on Figure 6, the area of contamination and the area of excavation includes a large part of Pit
C-2, where soil remediation was to take place. The purpose of the infiltration system is to enhance
remediation of remaining contaminated soils in the vicinity of former Pits C-1 and C-2.
1-7
i'
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2.0 CONCEPfUAL WORK PLAN
Based on the background information and recent source removal, the previously approved soil
remediation methods in former Pits C-1 and C-2 located in CERCLA Area C need to be modified. The
work plan described herein was developed to enhance remediation of remaining soil contamination.
2.1 Health and Safety
All personnel executing field activities will present to Sandoz evidence of compliance with the health and
safety training required under OSHA 29 CFR 1910.120. Sandoz will provide a brief site safety meeting
and address safety rules for their site. Personnel will be instructed to comply with these safety rules. A
field safety coordinator will be appointed to oversee the field activity.
During previous CERCLA-related field activities conducted at Sodyeco, a Health and Safety Plan was
prepared to safeguard the health and safety of personnel. The Health and Safety Plan will be up-dated
to meet site-specific needs for the work described herein. The field safety coordinator will provide a
copy of the updated Health and Safety Plan to the field personnel. Both the field safety coordinator and
the project manager will read, initial and date the Health and Safety Plan prior to initiating the field
activities. The field safety coordinator will complete a summary of the health and safety-related activities
after completion of the field work and return this summary to both the Law Environmental Health and
Safety Officer and the project manager.
2.2 Spray Infiltration System
The following sections outline the purpose of, conceptual designs for and the operation and maintenance
plan for the proposed infiltration system.
2.2.1 Purpose for Spray Infiltration System
The method of soil remediation will consist of spray infiltration of water over the remaining contaminated
soil zone (near former Pits C-1 and C-2) and the subsequent extraction of ground water by a proposed
recovery well. The proposed recovery well will be located in the weathering feature which is located
between the former pits and the existing ground-water recovery system (Figure 7).
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L ·· The purpose of the spray infiltration system is to enhance the flushing of the remaining constituents from
i.
the soil. The remediation methodology would consist of maintaining a good grass cover over the subject
area and increasing the infiltration through the soil zone by use of a sprinkler system. Sandoz would use
process water for irrigation purposes and the rate of application would be controlled based on several
factors: timers, a tensiometer, the water levels in wells, and routine site inspections. The application
rate is difficult to predict because of variables such as rainfall, evapotranspiration, and infiltration rate;
therefore, the system will be "fine tuned" based on observations made during routine inspections. The
system has been designed with flexibility to make adjustments if modifications are required. The
application rate is discussed in more detail in Section 2.2.3.
An additional recovery well will be placed downgradient of the application area and will be located in
the elongated weather feature. The purpose of the recovery well is to recover infiltrated water from the
spray infiltration system near the spray application area. It is a precaution against the infiltrated water
potentially moving vertically into the deeper fractured rock. The existing ground-water recovery system
is also designed to continue recovery of ground water downgradient of former Pit C-3. The proposed
recovery well will expedite remediation of ground water in CERCLA Area C and provide a better control
of ground water in the vicinity of the former pits. The proposed recovery well is discussed in more detail
in Section 3.
Four new monitoring wells will be installed. The wells will be installed topographically downgradient
of the former pits and will be used to evaluate leachate. Water level measurements from these wells will
also assist in evaluating the influence of Recovery Well R-16. Monitoring wells are discussed in
greater detail in Sections 2.3.2.
2.2.2 Conceptual Design for Spray Infiltration System
As illustrated on Figure 7, the spray infiltration system will consist of a series of gear driven spray heads.
The spray heads will be situated to provide application of water over an area encompassing former Pits
C-1 and C-2. The system will consist of twelve commercial duty, gear driven pop-up sprinklers with
adjustable nozzles. The sprinklers will be placed in a triangular configuration with an approximately 30-
foot head and 26-foot row spacing. Each sprinkler will be capable of distributing water evenly over a
30-foot radius and up to 360 degree arc. Sprinklers will be constructed of non-corrosive, heavy duty
acrylonitrile-butadiene-styrene (ABS) or stainless steel. Water will be transported to the sprinklers
2531-BBS.WP 2-2
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through a minimum 3/4-inch diameter polyvinyl-chloride (PVC) water line. The PVC water line will be
installed to a minimum of 18 inches below grade to hinder freeze problems. Shut-off valves will be
installed below grade. The water source will be able to maintain a 40 to 60 pounds per square inch (psi)
working pressure at a flow rate of 20 gallons per minute (gpm).
The water source will be routed to the main shut-off value and will be a minimum 18 inches below grade.
Process water will be used for the sprinkler system. The process water will be sampled and analyzed
once prior to system start-up for volatile organics by SW-846, Third Edition, EPA Method 8240 as
specified under the existing RCRA permit.
The water flow to the sprinklers will be controlled by a timer control system which will have delay
capabilities and multiple tensiometer inputs. One tensiometer will be placed in the root zone (approximate
depth of one foot below land surface). The tensiometer will be wired to the controller using underground
wiring.
2.2.3 Operation and Maintenance Plan
The spray infiltration system will be operated on a continuous basis with daily activation/deactivation
cycles being controlled by the timer controller. The application rate will be controlled based on the
design criteria, the tensiometer, water levels in the monitoring wells and regular site inspections.
The sprinkler head nozzle size will be selected to provide even distribution over the infiltration area at
a rate ranging from 0.15 inches/hour to 0.20 inches/hour. The anticipated percolation rate of the on-site
soils is approximately 0.15 inches/hour based on conversations with an irrigation system designer. The
operating design pressure for the spray infiltration system will be 40 to 60 psi.
The proposed operation of the spray infiltration system will be controlled by a tensiometer. The timer
controller will be set to operate mainly at night and early morning to decrease losses by
evapotranspiration. The timer controller will run the spray infiltration system. When the tensiometer
indicates saturation, the sprinklers will run up to two hours before shutting off. The sprinklers will
commence spraying water again when the tensiometer exhibits a moisture condition below saturation.
This mode of operation should allow the root zone of the grass to dry enough to help prevent root rot,
while providing enough water to percolate through to the deeper vadose zone.
2531-BBS.WP 2-3
I" .,
\.'.
i
'.
•
The spray infiltration system will also be able to be solely controlled by the timer, in the event of
tensiometer failure. Based on an assumed potential evapotranspiration rate of approximately 6 inches per
month, the system will be operated for five continuous hours (night or early morning) every third day
for an application rate of approximately 8 inches per month above normal precipitation.
The new monitoring wells will initially be monitored for water levels on a weekly basis for the first two
months of the spray infiltration system operation and then on a monthly basis for the next four months.
The purpose of water level measurements is to assist in assessing the overall influence of the spray
infiltration system. Subsequent measurements will be made during CERCLA well samplings (semi-
annual) or additionally as determined necessary based on the results of the first six months of operation.
The application rate of the sprinkler system may also be modified based on unforeseen events such as
excessive runoff or the occurrence of ground-water seeps downgradient from the application area.
Modification may consist of, but will not be limited to, the following:
• changing timing schedule
• changing nozzle sizes
• adjusting application rate
• increasing/decreasing the number of spray units
2.3 Additional Ground-Water Recovery Well and Monitoring Wells
The installation of an additional recovery well and the new ground-water monitoring wells are discussed
below.
2.3.1 Design Concept Cor Additional Recovery Well
The additional recovery well (designated R-16) is designed to recover the infiltrated water from the
infiltration system before the water migrates beyond the area of the former pits, thus eliminating the
possibility of infiltrated water from migrating vertically into the deeper fractured rock. Downgradient
areas, near existing Recovery Wells R-3 and R-4, have exhibited an upward component of ground-water
flow. The additional recovery well may also reduce the time required for overall ground-water
remediation in Area C.
2531-BBS.wP 2-4
2.3.2 Design Concept for Monitoring Wells
Four new monitoring wells will be installed in CERCLA Area C. The wells will be located
topographically downgradient of the former pits (C-1 and C-2). Two of the monitoring wells will be
installed before operation of the spray infiltration system. One of these monitoring wells will be installed
within 25 feet of proposed Recovery Well R-16. The purpose of this monitoring well will be to monitor
the influence of the new proposed recovery well. The two additional monitoring wells will be installed
after one month of operation or after water-levels become relatively stable. It is anticipated that the spray
infiltration system will artificially cause a mounding of subsurface water. The initial results of water-
level measurements will be used to assist in determining screen intervals and locating the additional wells.
2.3.3 Well Installation and Construction
The additional wells will be attempted using conventional hollow-stem auger drilling techniques. Augers
will have a minimum ten-inch outside diameter. The drilling procedures used may require modification
based upon the material being drilled and the depth of the well. Actual methods used will be detailed
in the as-built report.
Drill cuttings will be collected and screened for volatile organic emissions using either an photoionization
(HNu) meter (10.2 eV bulb) or an organic vapor analyzer (OVA) meter. Drill cuttings which release
organic vapors above background levels or which are obviously contaminated (as evidenced by odor or
staining) will either be stored on site and later remediated with contaminated soils, or will be disposed
of at an off-site permitted facility. Drill cuttings showing no evidence of contamination will be spread
on the ground surface near the well-head or at a central on-site location. Drilling mud, if used, will
likewise be collected, screened for contamination, and disposed of in the same manner as the drill
cuttings.
Recovery Well R-16 will be advanced to a depth of approximately 50 ft, or until auger refusal. The
intent of Recovery Well R-16 will be to recover near surface ground water and leachate water from the
spray infiltration system. Actual depth will be dependent on actual conditions encountered at the time
of drilling. This recovery well will be constructed of 4-inch diameter Schedule 40 stainless steel casing
and continuous wire-wrapped 35-foot (anticipated length) long stainless steel well screens (0.020-inch slot
2531·BBS.WP 2-5
•
size) with end plugs. The well screen slot size is based on the results of previous drilling. The most
conductive or contaminated zone, as identified during drilling, will be screened.
Monitoring Wells CMW-17, CMW-18, CMW-19 and CMW-20 will be advanced to approximately 25
feet, or to auger refusal. Actual depth may be modified based on the actual depth rock and/or ground
water is encountered. The monitoring wells will be constructed of 2-inch diameter Schedule 40. PVC
casing with 10-foot long PVC slotted well screens (0.010 slot size).
A sand pack will be placed in the annular space around the recovery and monitoring well screens to a
minimum of two feet above the top of the well screen. The gradation of this sand pack, along with the
well screen slot size, may be modified based upon the actual aquifer materials encountered.
A 2-foot thick bentonite seal will be placed in the annular space at the top of the sand pack. Above the
bentonite seal, the annular space between the well casing and borehole will be grouted to an approximate
depth of three feet below land surface. The grout will consist of a cement/bentonite slurry produced from
three to five pounds bentonite and approximately 6.5 gallons water per 94-pound sack of Type I Portland
cement. The remaining annular space will then be completed to land surface with concrete. A lockable
stand-up cover will be placed over the monitoring wells.
Typical well installations are illustrated on Figures 8 and 9. Well installations will conform to well
construction standards specified by the North Carolina Division of Environmental Management (DEM).
Well Completion Records will be completed and submitted to DEM. A copy of a well completion record
is included in Appendix A.
2.3.4 Well Development
Prior to developing each well, the well construction will be inspected and any deficiencies recorded and
submitted to the drilling contractor. Measurements of the depth to ground water will be taken in each
well. The volume of standing water in the well casing will be calculated based on the depth to ground
water and total depth of the well. Newly installed wells will then be developed until each of the
following minimum criteria are met:
• A minimum of six well volumes are removed from the well
2531-BBS.wP 2-6
•
• Two hours of well development
• Until field measurements of temperature and specific conductivity are
consistent for at least three consecutive readings
Sufficient water may not be present at the time of monitoring well installation such that well development
may need to be delayed until after operation of the spray infiltration system. To comply with North
Carolina State regulations, development water will be collected and discharged to the plant sewer system
and treated in the existing site biological treatment system.
2.3.6 Decontamination
Both the drill rigs and all downhole drilling equipment will be steam-cleaned before being brought onto
the site. Heavy rust and paint will be removed from equipment to be placed down a borehole. All
downhole equipment will be thoroughly cleaned between each borehole installation. Prior to drilling each
well, all downhole equipment, including augers and bits, will be decontaminated by the following
procedure:
• using a high-pressure steam-jenny, clean with municipal tap water and
laboratory detergent, using a brush when necessary to remove particulate
matter and surface films;
• rinsing thoroughly with municipal tap water.
Prior to leaving the site, the drill rig and the downhole equipment will be appropriately cleaned.
2.3.7 Pumps
A stainless steel Grundfos Redio-Flo environmental submersible pump (or similar) will be placed near
the bottom of the new recovery well. The pump will be operated by an above ground control panel
which is weather resistant. The discharge from the recovery well will be routed through a high density
polyethylene (HOPE) pipe to the nearest sewer line leading to the on-site wastewater treatment plant.
An estimate of the discharge anticipated from the new recovery well and a well design summary is
included in Table 2.
2531-BBS.WP 2-7
•
2.3.8 Operation and Maintenance
Toe ground-water recovery well will be operated continuously to act as a barrier to migration of ground-
water constituents by removing the ground water from the aquifer system. Toe ground-water recovery
system is designed to continually influence the horizontal and vertical gradients of ground-water flow.
Well construction materials have been selected to be compatible with known constituents in the ground
water. The equipment utilized as part of the ground-water recovery system will be maintained per
manufacturer's recommendations and as required to maintain effective operation. The system should
provide service with few maintenance requirements. Any required repairs will be performed in a timely
manner. Toe operation and maintenance plan previously submitted by Sodyeco, prepared after installation
of the existing ground-water recovery system, will be followed for the new recovery well. This plan will
include any additional operation and maintenance criteria required for the expansions of the ground-water
recovery systems. The existing operation and maintenance schedule for the existing biological treatment
system has been provided to the USEPA.
2-8
• •
3.0 GROUND WATER
Area C surface runoff flows toward a low-lying trough located hydraulically downgradient of both Pits
C-1 and C-2. Based on our understanding of site hydrogeology, ground water also flows toward this
feature, generally in a southwest direction. The existing ground-water recovery system in Area C is
designed to intercept shallow ground water within the trough feature.
3.1 Existing Ground-Water Recovery System
The existing and proposed modification to the ground-water recovery system are shown on Figure 10.
Two existing ground-water recovery wells are located in the shallow aquifer zone of CERCLA Area C.
These recovery wells are designed to capture constituents before they enter Long Creek. The recovery
wells are located approximately 270 feet apart. The spacing between recovery wells was determined
using capture zone analyses. For further information on the existing ground-water recovery system for
CERCLA Area C, refer to "Groundwater Recovery System and Area B Cap Remedial Design, Sodyeco
Site, Mt. Holly, North Carolina" submitted to Region IV of the EPA by Engineering-Science and Law
Environmental, Inc., July 1989.
Based on the general direction of ground-water flow in the vicinity of former Pits C-1 and C-2 (Area C),
the existing ground-water recovery system (Recovery Wells R-3 and R-4) is situated downgradient of the
former pits and is capable of capturing contaminated ground water.
3.2 Modification to Existing Ground-Water Recovery System
Proposed Recovery Well R-16 will be connected to the existing ground-water recovery system or to the
nearest sewer line leading to the on-site wastewater treatment plant as discussed in Section 3.3. The
existing I 1/2-inch diameter, high density polyethylene (HOPE) pipes are capable of transporting up to
the estimated five gallons per minute (gpm) from the new recovery well. The flow rate is based on
previous well yields from Recovery Wells R-3 and R-4 (Figure 10). Check valves will be installed
wherever recovery well discharge pipes join into a single discharge line.
2531-BBS.WP 3-1
• •
3.3 Ground-Water Transport
Recovered ground water from new Recovery Well R-16 will be routed to the plant's biological
wastewater treatment plant. · Flow meters monitor the volume of ground water extracted from each
recovery well and the amount recovered by the ground-water recovery system. The pumping rate and
volume of ground water recovered from the CERCLA areas will be provided in the semi-annual remedial
effectiveness evaluation report. The piping system and pumps are designed to handle the expected
additional flows from the new recovery well. The transport pipes consist of 1 1/2-inch inside diameter
HDPE. Pipe lengths greater than 400 feet were constructed with a subsurface access cover and a cleanout
fitting. Pipes and connections to the recovery wells were installed 18 inches below land surface where
practical. Exposed pipes are appropriately insulated. Details of a typical recovery well and cleanout
fitting are shown on Figure 9. To minimize back pressure possibilities, check-valves were installed
wherever recovery well discharge pipes join into a single discharge line. Recovery Well R-16 will be
constructed and connected to the existing using similar standards.
3.4 Treatment System
Biological degradation and aeration of the ground water will take place within Sodyeco's existing
treatment system. As discussed previously, the recovered ground water is pumped from the recovery
wells to the existing Sodyeco sewer system which currently transports wastewater to the biological
treatment system. The combined ground water and wastewater (both plant wastewater and ground water)
enters a pre-aeration basin followed by an activated sludge basin. The organic compounds are
biodegraded within these basins; a portion of the organics volatilize as a result of aeration. , The
wastewater then flows into two secondary clarifiers where the sludge is separated and returned to the
activated sludge basin. The treated ground water then is discharged to the Catawba River under an
existing NPDES permit. This treatment system is more than 98 percent efficient based on the removal
of o-dichlorobenzene (an average of 950 ug/1 in the influent to less than 20 ug/1 in the effluent as
determined in an USEPA study for effluent guidelines ["Groundwater Recovery System and Area B Cap
Remedial Design, Sodyeco Site", July 19891). Of the organic constituents, o-dichlorobenzene is the most
difficult to remove. Removal efficiencies of at least 99 percent are expected for the other constituents.
The present treatment system has the capacity to easily accommodate the additional up to five gpm, or
approximately 7,200 gpd expected from Recovery Well R-16 since the design capacity is 3.9 million
2531-885.WP 3-2
• •
gallons per day (MGD) and the current daily flow rate is approximately 2 MGD. The results of the
sampling and analysis are reported to the USEPA in the semi-annual remedial action effectiveness
evaluation.
3.5 Monitoring Requirements and Remediation Verification
The new recovery well (R-16) will be sampled at initial startup. The four new monitoring wells (CMW-
17, CMW-18, CMW-19 and CMW-20) will be sampled after 60 days of spray infiltration operation. If
the arithmetic average of the four wells constituent concentrations is below ARARs, two additional
samples, 60 days apart will be obtained to confirm these constituent concentations. Three consecutive
below-ARAR samplings will constitute a showing that the leachate in area C has met ARAR standards.
When the ARARs are met, the sampling wells (CMS-17, 18, 19, 20) and the local recovery well (R-16)
will be properly abandoned.
If the initial sampling shows the four-well average to be above ARARs, then one monitoring well will
be sampled for indicator parameters on the regular CERCLA sampling schedule. The choice of well will
be made based on a practical review of the data. Sandoz may do an ARAR-compliance sampling at any
time. All sampling and analysis for ARAR compliance will be according to SW-846 (CLP).
Operation of the main ground water recovery system (Recovery Wells R-3 and R-4) for CERCLA Area
C (Figure 10) will continue per the Record of Decision (ROD).
3-3
i-•
4.0 REPORTING
Upon the completion of the field activities described in Sections 2 and 3, an "as-built" report will be
submitted to Sandoz. This report will generally include, but not be limited to a background section,
system concept, and as-built drawing of the infiltration system and ground-water recovery system.
Because the infiltration system has been designed with significant flexibility to adjust to modifications
likely to occur over the first three months of operation, the "as-built" report will be submitted
approximately four months after system start-up.
2531-BBS.WP 4-1
r· I
!
Notes:
•
TABLE 1
GROUND-WATER CLEANUP GOALS FROM RECORD OF DECISION
SODYECO MT. HOLLY PLANT
LEI JOB NO. 56-2531.10
Trichloroethylene
Tetrachloroethylene
Chlorobenzene
Ethyl benzene
1 ,2-dlchlorobenzene
Toluene
Xylene
2.7 ug/I (2)
0.8 ug/I (2)
60 ug/I (1)
680 ug/I (1)
400 ug/I (5)(3)
2,000 ug/I (1)
440 Ug/1 (1)
(1) Proposed Maximum Contaminant Level Goals, 50 Emmi Register 46936 (November 13, 1985).
(2) The proposed concentration given for potential carcinogens corresponds to a cancer risk level of 10-6. (3) Includes all isomers.
(4) As total polynuclear aromatic hydrocarbons, no criteria set for these compounds alone.
(5) USEPA, •superfund Public Health Evaluation Manual," Office of Emergency and Remedial
Response, Washington, DC, 1986. USEPA Ambient Water Quality Criteria for Aquatic
Organisms and Drinking Water.
Reference: Record of Decision (ROD), 1987.
2531TB1.WK1 Revised 26-May-92
R-16
CMW-17
CMW-18
CMW-19
CMW-20
Table 2
MONITORING AND RECOVERY WELL DESIGN DESIGN/PUMPING RATES
CERCLA AREA C
50
25
25
25
25
SODYECO MT. HOLLY PLANT
LEI JOB NO. 56-2531.10
Soil/Residuum
Soil/Residuum
Soil/Residuum
Soil/Residuum
Soil/Residuum
15 -50
5 -25
5 -25
5 -25
15 -25
NOTES: NA -Not Applicable
Actual Completion Depth will be based on Actual Site Conditions Encountered At Time of Drilling.
5
NA
NA
NA
NA
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REFa U.S.G.S. 7.5-. TOPOGRAPMC MAPS;
MOUNTAIN ISLAND LAKE. NORTH CAAOUtA (19119)
& MOUNT HOU.Y, NORTH CAR0UNA (1970)
QUADRANGLES.
N
LAW ENVIRONMENTAL, INC;
CHARLOTTE, NORTH CAROLINA
SITE LOCATION MAP
SANDOZ, SODYECO SITE
MOUNT HOLLY, NORTH CAROLINA
JOB NO. SS-2531 FIGURE 1
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EXPLANATION
II CERCLA AREA
AP~X. SC::. FT. "
LAW ENVIRONMENTAL, INC.
CHARLOTTE, NORTH CAROLINA 1-----------------t
JOB NO.
LOCATION OF CERCLA AREAS
SANDOZ .CHEMICALS
SODYECO SITE
56-2531 FIGURE 2
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SCALE (FU
LAW ENVIRONMENTAL, INC.
CHARLOTTE, NORTH CAROLINA
AREA C -GENERALIZED PROFILE ·
SANDOZ. CHEMICALS
SODYECO SITE
JOB NO. 56-2531 FIGURE 4
• •
NALYTE CONCENTRATIONS(ppb) IN
SOIL AND IN GROUNDWATER /
SAMPLES FROM AREA C • ~<\
October, 1986 to January, 1987 eJ .. ~¥-v-!'V·"-o"' .~,.; •
1.5-3'
CB -780
OOCB -70
13.5-15'
EB -1,700,000
ooce -11.000,000
~----~ X -15,000,000
,~_g_a_•:_•_;_,_• .... ~o-~_~·-:_:_•·-~-·--1 ~~7e::,,· ~/
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1--------1 ooca -soo.ooo
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X -210,000
23.5-25'
ODCB -1,300,000
X -480,000
D•pth■: 1.s-3·. ,.s-s·. 1.s-10·, u.s-1s·
NO
11.s-20·
DOCS -'8,000
X -72,000
S -ND
I -ND
D -ND
1.5-3'
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1.5-10 ca -1,:,00
EB -940
W0-34
13.5-15'
EB -770,000
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X -4,800,000
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X -S, 100 EB -450,000 '------I coca -1.:ioo.0OO
X -2,700,000
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EB -20
ODCB -270
T -51
X -1,000
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T -13
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ODCB .-520
8,5-tO'
CB -25
EB -6.1 ooca -c.1100
X -22
13.5:--tS
DOCS -28
D•plh■: 0-f, 1.s-3· & 3.5-5" Ui·l· 13.5-15"
HD ~-------NC,:D-------➔I ooce -1, ,oo X -2,900 a.s-10·
EB -580,000 ooce -190,000
X -2,600,000
13.5-15'
EB -860,000
OOCB -550,000
T -411,000
X -4,100,000
111.5-20"
EB -300,000
aces -00.000
X -2,100,000
23.5-25'
coca -2ao
X -220
J.s-s·
EB -12,000
,a.s-20·
ND
X -270,000 23.5-25"
11--------i ODCB -3,600
a.s-10·
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X -l2
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,a.s-20
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LAW ENVIRONMENTAL
CHARLOTTE, NORTH CAROLINA
ANALYTE CONCENTRATIONS (ppb) IN SOIL
ANO IN GROUND-WATER SAMPLES
AREA C
SANDOZ CHEMICALS. SODEYCO SITE
JOB NO. 56-2531 IFIGURE 5
•
N568,400
01 01 co .,,
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·.·.·.·.·.· .. ~-:~.2.·.·;.·.·.·.·.·.·.·.·.·.·.·.·.·.·
I • ' C-3-5
I
FORMER
PIT C-3
REF.: SANDOZ CHEMICAL CORPORATION CERCLA AREA C PITS.
NOV. 13. : 990 SURVEYS BY CARD AN SYSTEMS CORP.
NOTE: THIS COMBINATION MAP
UTIUZlNG DATA OBTAINE
ENGINEERING -SCIENCE.
REMEDIAL TECHNOLOGIE::
AND LAW ENVIRONMENT 1-
•
!
l
•)RYER
,T C-2
-aEIP
<CLA AREA C WAS PREPARED
M CARDEN SYSTEMS CORP.,
MAY. 1990 EVALUATION OF SOIL
TREATABIUTY STUDY WORK PLAN,
lMITTALS JOB NO. 56-0594.
I
EXPLANATION
♦ t.lONITORING WELL
0 SOIL TEST BORING (PREVIOUSLY SURVEYED
BY CARDAN SYSTEMS CORP.) @ APPROXIMATE LOCATION OF FORMER PITS
D ,\PPROXIMA TE LOCATION OF PROPOSED
301L TREATMENT SYSTEMS
APPROXIMATE LOCATION OF ANOMALOUS RESPONSE
_. (GEOPHYSICAL SURVEY, l.£1 JOB NO. 56-0594)
EXCAVATION PIT OUTLINE
•:Nov. 13, 1990 SURVEY BY CARDEN SYSTEMS CORP.)
O EIP IRON EST ABU SHED DURING
,EOPHYSICAL SURVEY (LEI JOB NO. 56-0594)
1
GRAPlilC SCALE
'° I
( IN Fl!Xr )
1 Inch a ♦O IL
Al L LOCATIONS ARE APPROXIMATE.
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§~ LAW ENVIRONMENTAL, INC.
~'i!iilfi CHARLOTTE, 'NORTH CAROLINA
AREA C -SITE PLAN
SANDOZ CHEMICALS
SODYECO SITE
DF'.AWN AR 05/o•/92 APPROVED BS 05/05/92
DCA f'll£ 25J1S/7M/AR JOB NO. 56-2531 FIGURE 6
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1'1568.400
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REF.: SANDOZ CHEMICAL CORPORATION C ERCLA AREA C PITS,
NQV_ 13, 1990 SURVEYS BY CARDAN SY~TEMS CORP.
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NOTE:
-THIS COMBINA
UT!UZING DAT.
ENGINEERING -
REMEDIAL TEC
ANO LAW ENV,
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------------
----(
-,iAP -CERCLA--AREA-C WAS--PREPARED-
AINED FROM CARDEN SYSTEMS CORP.,
:NCE. INC. MAY, 1990 EVALUATION OF SOIL
;1ES AND lREA TABIUTY STUDY WORK PLAN,
~NTAL SUBMITTALS JOB NO. 56-0594.
I
EXPLANATION
WQ-34S -♦--~ONITORING WELL
., PROPOSED MONITORING WELL
CMW-17
D
PROPOSED RECOVERY WELL
APPROXIMATE AREA OF PROPOSED
SPRAY INFIL lRA TION SYSTEM
LOCATION OF SPRINKLER SPRAY HEAD
APPROXIMATE SCAIE IN FEET
iJi LAW ENVIRONMENTAL, INC.
F _ CHARLOTTE. NORTH CAROLINA
--SPRAY INFILTRATION LOCATION PLAN
PREPARED BY
JOB NO.
CERCLA AREA C
SANDOZ CHEMICALS, SOOYECO SITE
IOATE a-tECKED
56-2531 FlGIJR( 7
·-------------------
JOB NAME ___________ JOB NUMBER ___________ _
WELL NUMBER __________ GROUND SURFACE ELEVATION ____ _
LOCATION ____________ MEASURING POINT ELEVATION ____ _
(TOP OF PVC CASING)
INSTALLATION DATE _______ _
PVC CAP
PROTECTIVE STEEL CASING -~fr=~(_(_VENTED)
GROUND SURFACE ' '-' ' :7>._y>
CONCRETE PAD
10-INCH DIA. BOREHOLE
STICKUP
DEPTH TO
BASE OF
GROUT
DEPTH TO
TOP OF
SAND
TOTAL DEPTH
OF WELL
BENTONITE SEAL
SAND PACK-----
2-INCH DIA. SCHEDULE 40 PVC SCREEN ----I
(0.010 INCH SLOTS)
CAP-~~
NOTE: ALL PVC JOINTS ARE FLUSH THREADED.
t
SCREENED
INTERVAL
SANDOZ CHEMICALS
SODYECO SITE
•-• LAW ENVIRONMENTAL, INC.
,.;;,, CHARLOTTE, NORTH CAROLINA
TOTAL DEPTH
OF BOREHOLE
TYPICAL
IIONITORING WB.L
INSTALLATION RECORD
FIGURE 8
INSULATED COVER
FLOV METER,
FLOV RESTRICTER,
1
PRESSURE RELIEF,
SAMPLING VAL VE
GROUND SURFACE
CONCRETE PAD
4' SCH. 40
CABLE Tu,
CONTROL
PANEL
STAINLESS STEEL-----;,'74,-,
PIPE
SELECT FILTER SAND
STAINLESS STEEL
SUBMERSIBLE PUMP---
<NOT SHOl,/M)
..... :: .. t
HEADER PIPE
<MINIMUM 18-IN. BELO',/ GRADD
/.::.J. ___ BENTONITE CEMENT GROUT
BENTONITE SEAL
CONTINUOUSLY SLOTT~D
STAINLESS STEEL
SCREEN
TYPICAL RECOVERY \.JELL
--iii45
45 •y•
\//THREADED PLUG
FOR CLEANOUT
ENCASEMENT ',//COVER
l 1/2' DIA. HDPE y FLO',/
MANHOLE STRUCTURE-/
TYPICAL CLEAN □UT
NOTE,
1. CLE,\NOUT INSTALLED ON PIPE VITH
LEt-lGTHS GREATER THAN 400 FEET.
2. RECOVERY \/ELL DEPTH AND
VELL SCREEN LENGTH DESCRIBED
IN TABLE 1.
NOT TO SCALE
ALL LOCATIONS ARE APPROXIMATE !P"""""---------------t
_ :~ CHALR:;~~~~:M~~;;L~NA
SCHEMATIC OF TYPICAL RECOVERY WELL
SANDOZ CHEMICALS, SODYECO SITE
MOUNT HOLLY. NORTH CAROLINA
ACAD/DEEPVEL2/S0 JOB NO. 56-2531 FIGURE 9
-
• •
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
Ms. Giezelle Bennett
Remedial Project Manager
14 August 1989
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
State Health Director
RE: Comments on the Sodyeco Groundwater Recovery System and
Area B Cap Remedial Design Report and Sampling and
Analysis Plan for Groundwater Remedial Action
Dear Ms. Bennett:
The Sodyeco site Groundwater Recovery System and Area B
Cap Remedial Design Report and the Sampling and Analysis Plan
for Groundwater Remedial Action have been reviewed. Comments
from the North Carolina Superfund Section are attached. The
State may have additional comments at a later date.
If you have any questions, please contact me at (919)
733-2801.
CV/acr
Attachment
Sincerely,
~-~~
Charlotte Varlashkin, P.G.
Superfund Section
•
Superfund 0 Section
Sodyeco Site
14 August 1989
•
GROUNDWATER RECOVERY SYSTEM AND AREA B CAP REMEDIAL DESIGN
Section 1 -Introduction
Figure 1. 17 shows only one deep moni taring well and one
intermediate monitoring well (Wells WQ-29I and WQ-29D)
downgradient of Area C. Since Figure 1. 13 indicates the
groundwater flow to be due south, then wells WQ-29I and WQ-29D
may not be directly downgradient of some of the disposal areas
in Area C. These wells do not adequately characterize
contamination of the "intermediate" and "deep" portions of the
aquifers. Also, the concentrations of contaminants in well
Wl-3 were not presented in Figure 1. 17. Please add this
information.
No information was provided on the depths of wells shown in
Figure 1.23. This information needs to be added.
Well WQ-27 shown in Figure 1.17 is not listed on Table 3.2.
Please add Well WQ-27 to this table.
Section 3 -Groundwater Recovery and Treatment
The concentration of tetrachloroethylene given in Figure 1.17
for the intermediate aquifer zone in Area C exceeds the ARAR
listed on page 3-3. At the completion of shallow recovery,
intermediate recovery will be necessary to meet the ARARs for
all contaminated zones of the aquifer. Also, in Area E since
contaminants exceed ARARs in the deep zone of the aquifer, deep
recovery should be performed at the completion of intermediate
recovery in Area E.
The first paragraph in Section 3.4.1.1 states that groundwater
from recovery wells will be pumped to existing alkaline sewer
lines. The same paragraph then indicates that high density
polyethylene (HOPE) pipes will be used. Please clarify whether
alkaline (concrete) pipes or HOPE will be used. Concrete pipes
will leak over time.
The sludge generated by the waste treatment system after
groundwater recovery may contain the contaminants present in
the groundwater. Information needs to be provided on sludge
treatment.
The effluent from the waste treatment system should be analyzed
for the groundwater contaminants.
• •
The reasons should be presented on why there is no overlap of
capture zones in the Area D deep recovery system.
Section 4 -Implementation Considerations
The third paragraph on page 4-1 indicates well installation
will conform to the standards specified by NC-DEM. Well
permits should be obtained for well installations. The
permitting procedure is important for State record keeping.
Appendix C -Cap DesigTT Calculations
Page C-1 indicates the cap for Area B has a lifespan of 20
years. Provisions for replacement of the cap in 20 years
should be provided.
Appendix D -Support Information on Groundwater Recovery System
The equation on page D-7 needs to either be referenced or
derived.
The units on for Q (expected well yield) in Table D.l do not
match the units for estimated flow rate in Table 3 .1. The
numbers or the units will need correction.
The reasons for incorporating a 68 year recovery time for Area
D deep should be provided.
Appendix E -Support Information on the Existing Biological
Treatment System
Table E. 1 indicates the removal efficiency for
o-dichlorobenzene is 98.1%. A 98.1% removal of the maximum
concentration estimate for this compound given on page 3-3
exceeds the ARAR given on the same page. The time allowed for
treatment may have to be adjusted so not to exceed the ARARs in
the· effluent being discharged. Also, since the removal
efficiency for trichloroethylene is not determined (Table E.l),
effluent samples after groundwater treatment begins may
indicate an adjustment to the treatment time is required.
Appendix F -Site Health and Safety Information
Page F-7 gives the limit which respirators (Level C) will be
donned. The lowest TLV for the voes present at the site is the
same-as ... this limit. Relative response of the HNU for each voe
should be factored in to this limit for upgrading to Level c.
The limit may need to be lowered.
• •
An evacuation limit for voe air monitoring while in Level C
protection should be provided in the safety plan.
Page F-8 indicates workers will receive training in wearing
respirators. Site workers should have the 40-hour hazardous
site safety training.
General Comments
Details of the existing cap covering Area A are not provided.
The Area A cap should meet the same design and maintenance
requirements as the proposed_Area B cap. -
No information is provided on whether soils and groundwater
have ever been sampled for priority pollutant metals. Please
provide this information.
SAMPLING AND ANALYSIS PLAN FOR GROUNDWATER REMEDIAL ACTION
The first paragraph on page 4-1 indicates the last 4 sampling
events will be analyzed by CLP protocols. The following
sentence states that the last sampling event will be the only
event to use CLP protocols. Please clarify.
• • 1
. .
f,. ~ <-,.., c.,'-'~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV ◄t P~O'~
JUL 2 1 1989 345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-SFB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. J. Paige Straley, P.E.
Environmental Manager
Sandoz Chemicals Corporation
Highway 27 West
P.O. Box 669246
Charlotte, NC 28266
RE: Sodyeco RD/RA
Charlotte, NC
Dear Mr. Straley:
RECEIVED
JUL 24 198\:l
SUPERfUND BRANCH
The Agency has reviewed the July 1989 Groundwater Recovery
System and Area B Cap Remedial Design Report. The comments
below should be incorporated as soon as possible. Instead of
submitting a new report, replacement pages for the sections
affected will suffice. If you have any questions, please give
me a call at 404/347-7791.
1. The language on page 2-2, Sectinn 2.2.2 needs to be changed
to the original language in the May 1989 document. Sodyeco
proposed 14 inches for the cap in '::!'l.e FS, and this was approved
and subsequently incorporated in the Record of Decision. The
design will not be changed now.
2. Comment Numi::er 19 was not addressee. proper'y. The comment
states that the c::ilumn should show the Maximum Concentration
Found, not: a Flow Weighi:ed concem::::ation. T!'lis needs to be
changed.
3. Page 3-13 and Figure 3.4 -WQ-33S needs to be added as a
monitoring well ( Check the 6/ 14/ 89 letter from ES).
4. The last step of the monitoring section (Section 3.5.1.1)
has been omitted. Comment No. 20 of the February 28, 1989
le1:ter to Sandoz states that after the extraction system is
turned off, quarterly sampling should be conducted for 2 years
to confirm the completion of the remediation.
5. The number of monitoring wells described in the text and the
numi::er listed in Table 3.2 do not correspond. A footnote should
be added to Table 3.2 which states that monitoring wells are
used to obtain water quality and water level data.
• •
6; Comment No. 34 has not been addressed. Please· include· in
this section the semi-annual reporting requirements for the
duration of the remedial action.
7. Comment No. 33 has only been partially addressed. The data
must not only be plotted on maps and cross-sect.ions, but must
also be interpreted to define the spacial variation of the
contaminant plume ..
Sincerely,
~ /1 ,,-------,1 0 ~ (:~,~=-:1-/~\/--\
Giezelle S. Bennett
Remedial Project Manager
cc: Bill Archer, Sandoz
Cindy Draper, ES
Jeff Crane, EPA
Doug Roberts, NC OHR
Jack Butler, NC Solid & Hazardous Waste
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
• • UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
SEP o 1 1988
345 COURTLAND STREET
ATLANTA, GEORGIA 3031!5
Sodyeco Remedial Design
Charlotte, North Carolina
CERCLA Project Manager
Sodyeco Remedial Design Team
Gail Vanderhoogt, Water
Lee Crosby, NC
Doug Lair, ESD
Ken Barry, VERSAR
Attached is the Remedial Design for the Sodyeco Site in Charlotte, South
Carolina. This includes the groundwater pump and treat system and the
soil biodegradation design. Please review and return comments to me by
September 15 1 1988.
Thank you for your cooperation.
Bennett
,I~