NCD079044426_19980910_General Electric Co. Shepherd Farm_FRBCERCLA RA_Draft Final Work Plan - Soil Remedial Action-OCR

JAMES B. HUNT JR.
GOVERNOR
Ms. Giezelle Bennett
Superfund Branch
Waste Management Division
NOffrH,AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
September I 0, 1998
United States Environmental Protection Agency
Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
RE: Draft Final Work Plan for Soil Remedial Action at GE Subsite
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
Dear Ms. Bennett:
The Draft Final Work Plan for Soil Remedial Action at GE Subsite for the General
Electric/Shepherd Farm National Priorities List (NPL) Site was received by the
Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR). The Superfund Section has reviewed this document and
offers the following attached comments.
We appreciate the opportunity to comment on this document. If you have any
questions, please feel free to call me at [phone], extension 349.
Attachments
Sincerely,
1) J Eiir~~~,~(
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHoNE9l9•733-4996 FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/10% POST-CONSUMER PAPER
•
Ms. Giezelle Bennett
Superfund Branch
Waste Management Division
NORTH,AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
September I 0, 1998
United States Environmental Protection Agency
Region IV
61 Forsyth Street, 11"' Floor
Atlanta, Georgia 30303
RE: Draft Final Work Plan for Soil Remedial Action at GE Subsite
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
Dear Ms. Bennett:
The Draft Final Work Plan for Soil Remedial Action at GE Subsite for the General
Electric/Shepherd Farm National Priorities List (NPL) Site was received by the
Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR). The Superfund Section has reviewed this document and
offers the following attached comments.
We appreciate the opportunity to comment on this document. If you have any
questions, please feel free to call me at [phone], extension 349.
Attachments
Sincerely,
1) J.Elffr~~'",~(
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919•715-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
Ms. Giezelle Bennett
September 10, 1998
Page 1
• •
: DRAFT FINAL WORK PLAN FOR SOIL REMEDIAL ACTION AT GE SUBSITE
General
1. The Prefinal Design Construction Drawings were submitted for the 90% Remedial Design
(RD). However, these drawings represent only one component of the 90% RD. Please
submit the text portion of the 90% RD, including, but not limited to, the material
specifications, material testing requirements, the installation procedures, quality
assurance/quality control measures to be implemented, durability, specific operation and
maintenance requirements, durability and load bearing capacity. Additionally, please provide
all design criteria that will be used to excavate and backfill both Landfill A and Landfill B.
Please use available US EPA guidance as an aid in developing the cap design.
2. Per the applicable or relevant and appropriate requirements (ARARs) of the 1995 Record
ofDecision (ROD), the final cover for the landfill must be designed in accordance with Title
40, Part 264 of the Code ofFederal Regulations (40 CFR 264). Please demonstrate that the
design criteria for the 90% RD meet the requirements of 40 CFR 264.
Table of Contents
3. The section entitled, Sample Analysis, should be shown as Section 3.1.3 in the Table of
Contents. Please correct this oversight.
List of Figures
4. The title ofFigure 2.3 should be shown as "Extent of the DSI" in the List of Figures. Please
correct this oversight.
5. The title for Figure 8.2 should be shown as "Schedule for soil remedial action at GE
Subsite" in the List of Figures. Please correct this oversight.
Section 1.1 Background
6. The last sentence of this section is misleading. The last sentence states that groundwater does
not flow from the GE Subsite offsite north of Tabor Road or offsite west of Spartanburg
Highway. Although generalized flow conditions indicate eastwardly flow toward Bat Fork
Creek, the last sentence of this section implies that groundwater contamination, which is
discussed in the following section, is limited to the GE Subsite. However, groundwater
monitoring has demonstrated that groundwater contamination is not limited to the GE
Subsite. Please either delete this sentence or restate this sentence to indicate that the
groundwater level survey indicates generally eastwardly flow conditions.
Ms. Giezelle Bennett
September 10, 1998
Page 1
• •
DRAFT FINAL WORK PLAN FOR SOIL REMEDIAL ACTION AT GE SUBSITE
General
1. The Prefinal Design Construction Drawings were submitted for the 90% Remedial Design
(RD). However, these drawings represent only one component of the 90% RD. Please
submit the text portion of the 90% RD, including, but not limited to, the material
specifications, material testing requirements, the installation procedures, quality
assurance/quality control measures to be implemented, durability, specific operation and
maintenance requirements, durability and load bearing capacity. Additionally, please provide
all design criteria that will be used to excavate and backfill both Landfill A and Landfill B.
Please use available US EPA guidance as an aid in developing the cap design.
2. Per the applicable or relevant and appropriate requirements (ARARs) of the 1995 Record
ofDecision (ROD), the final cover for the landfill must be designed in accordance with Title
40, Part 264 of the Code ofFederal Regulations (40 CFR 264). Please demonstrate that the
design criteria for the 90% RD meet the requirements of 40 CFR 264.
Table of Contents
3. The section entitled, Sample Analysis, should be shown as Section 3.1.3 in the Table of
Contents. Please correct this oversight.
List of Figures
4. The title ofFigure 2.3 should be shown as "Extent of the DSI" in the List of Figures. Please
correct this oversight.
5. The title for Figure 8.2 should be shown as "Schedule for soil remedial action at GE
Subsite" in the List of Figures. Please correct this oversight.
Section 1.1 Background
6. The last sentence of this section is misleading. The last sentence states that groundwater does
not flow from the GE Subsite offsite north of Tabor Road or offsite west of Spartanburg
Highway. Although generalized flow conditions indicate eastwardly flow toward Bat Fork
Creek, the last sentence of this section implies that groundwater contamination, which is
discussed in the following section, is limited to the GE Subsite. However, groundwater
monitoring has demonstrated that groundwater contamination is not limited to the GE
Subsite. Please either delete this sentence or restate this sentence to indicate that the
groundwater level survey indicates generally eastwardly flow conditions.
Ms. Giezelle Bennett
September 10, 1998
Page 2
•
Section 2.2.2 Remedial Action Approach
•
7. The fourth sentence of this section states that up to 19,000 cubic yards (cy) of soil may be
excavated from Landfill A if the entire 1.3 acres is excavated to an average depth of eight
feet. However, the design calculations included in Attachment 5 indicate that 16, 779 cy of
soil may be excavated from Landfill A if the entire 1.3 acres is excavated to an average depth
of eight feet. Furthermore, the second sentence of the third paragraph of Section 2.2.1
indicates that the series of bum trenches extend to a total depth of nine feet. Please clarify
these discrepancies.
8. The last sentence states that the Landfill A excavation will be brought to grade using clean
fill similar to the fill used at Shepherd Farm. Please demonstrate that the fill used previously
meets the backfill requirements as specified in the Construction Specifications included as
Attachment I and the Construction Quality Assurance Plan included as Attachment 4.
Alternatively, please revise this section to include the provision that the soils used previously
shall be tested according to the aforementioned documents and that the soils shall only be
used once laboratory results have demonstrated that the soils meet the required specifications.
Additionally, there is no mention of the material to be used for the final cover. Please provide
a description of the final cover to be placed over Landfill A
Section 2.3.2 Remedial Action Approach
9. The fourth sentence of this section states that up to 1,100 cy of soil may be excavated from
Landfill B if the entire 0.1 acres is excavated to an average depth of seven feet. However, the
design calculations included in Attachment 5 indicate that 1, 793 cy of soil may be excavated
from Landfill A if the entire 0.14 acres (110 feet x 55 feet I 43,560 square feet per acre) is
excavated to an average depth of eight feet. Please clarify these discrepancies.
10. The last sentence states that the Landfill B excavation will be brought to grade using clean
fill similar to the fill used at Shepherd Farm. Please demonstrate that the fill used previously
meets the backfill requirements as specified in the Construction Specifications included as
Attachment 1 and the Construction Quality Assurance Plan included as Attachment 4.
Alternatively, please revise this section to include the provision that the soils used previously
shall be tested according to the aforementioned documents and that the soils shall only be
used once laboratory results have demonstrated that the soils meet the required specifications.
Additionally, there is no mention of the material to be used for the final cover. Please provide
a description of the final cover to be placed over Landfill B.
Ms. Giezelle Bennett
September 10, 1998
Page 2
•
Section 2.2.2 Remedial Action Approach
•
7. The fourth sentence of this section states that up to 19,000 cubic yards (cy) of soil may be
excavated from Landfill A if the entire 1.3 acres is excavated to an average depth of eight
feet. However, the design calculations included in Attachment 5 indicate that 16, 779 cy of
soil may be excavated from Landfill A if the entire 1.3 acres is excavated to an average depth
of eight feet. Furthermore, the second sentence of the third paragraph of Section 2.2.1
indicates that the series of bum trenches extend to a total depth of nine feet. Please clarify
these discrepancies.
8. The last sentence states that the Landfill A excavation will be brought to grade using clean
fill similar to the fill used at Shepherd Farm. Please demonstrate that the fill used previously
meets the backfill requirements as specified in the Construction Specifications included as
Attachment 1 and the Construction Quality Assurance Plan included as Attachment 4.
Alternatively, please revise this section to include the provision that the soils used previously
shall be tested according to the aforementioned documents and that the soils shall only be
used once laboratory results have demonstrated that the soils meet the required specifications.
Additionally, there is no mention of the material to be used for the final cover. Please provide
a description of the final cover to be placed over Landfill A.
Section 2.3.2 Remedial Action Approach
9. The fourth sentence of this section states that up to 1, I 00 cy of soil may be excavated from
Landfill B if the entire 0.1 acres is excavated to an average depth of seven feet. However, the
design calculations included in Attachment 5 indicate that I, 793 cy of soil may be excavated
from Landfill A if the entire 0.14 acres (110 feet x 55 feet/ 43,560 square feet per acre) is
excavated to an average depth of eight feet. Please clarify these discrepancies.
10. The last sentence states that the Landfill B excavation will be brought to grade using clean
fill similar to the fill used at Shepherd Farm. Please demonstrate that the fill used previously
meets the backfill requirements as specified in the Construction Specifications included as
Attachment I and the Construction Quality Assurance Plan included as Attachment 4.
Alternatively, please revise this section to include the provision that the soils used previously
shall be tested according to the aforementioned documents and that the soils shall only be
used once laboratory results have demonstrated that the soils meet the required specifications.
Additionally, there is no mention of the material to be used for the final cover. Please provide
a description of the final cover to be placed over Landfill B.
Ms. Giezelle Bennett
September I 0, I 998
Page 3
•
Figure 2-3 Extent of the DSI
•
11. Figure 2-3 indicates that the polychlorinated biphenyl (PCB) contamination extends beyond
the fenced portion of the DSI to the northwest. However, the PreFinal Design Construction
Drawings only address those areas of the DSI that lie within the chain link fence. Please
describe how the PCB contaminated soils that lie outside of the fenced portion of the DSI are
to be addressed.
Section 2.4.3 Post-Closure Activities
12. The Operation and Maintenance (O&M) Plan for the DSI must.be prepared and approved
prior to the implementation of post-closure activities. Please submit the O&M Plan with the
90%RD.
Section 3.1.1 Excavation
13. The second sentence of the second paragraph states that clean material may be stockpiled for
subsequent use as backfill at the Engineer's discretion and according to the specifications
(Section 02221). However, Section 02221 of the Construction Specifications included in
Attachment I does not provide the criteria that will be employed by the Engineer in making
this decision. Additionally, Section 01450 of the Construction Specifications states that only
new materials are to be incorporated in the work. Please revise this section and Sections
02221 and 01450 of the Construction Specifications to include the criteria that the Engineer
shall use in determining if excavated material may be staged for subsequent use as backfill.
Additionally, the Engineer shall be prepared to demonstrate that the fill meets the backfill
requirements as specified in the Construction Specifications included in Attachment A and the
Construction Quality Assurance Plan included as Attachment 4.
Section 3.1.2 Confirmation Sampling
14. The first sentence of this section proposes collecting confirmatory samples according to a grid
spacing of 50 feet (ft). Although this may be appropriate for large excavations, Landfill B
would only require 3-4 confirmatory samples under this sampling scheme. Furthermore, the
sidewalls should be addressed according to a separate sampling scheme as only sample would
need to be collected approximately every 300 linear feet (assuming an excavation depth of
eight feet). Please revise the sampling scheme to account for sidewalls and for the smaller
excavation at Landfill B.
15. Please describe the excavation/shoring procedures and the confined space entry procedures
to be implemented to enter the excavations to place the grid stakes.
Ms. Giezelle Bennett
September 10, 1998
Page 3
•
Figure 2-3 Extent of the DSI
•
11. Figure 2-3 indicates that the polychlorinated bi phenyl (PCB) contamination extends beyond
the fenced portion of the DSI to the northwest. However, the PreFinal Design Construction
Drawings only address those areas of the DSI that lie within the chain link fence. Please
describe how the PCB contaminated soils that lie outside of the fenced portion of the DSI are
to be addressed.
Section 2.4.3 Post-Closure Activities
12. The Operation and Maintenance (O&M) Plan for the DSI must be prepared and approved
prior to the implementation of post-closure activities. Please submit the O&M Plan with the
90%RD.
Section 3.1.1 Excavation
13. The second sentence of the second paragraph states that clean material may be stockpiled for
subsequent use as backfill at the Engineer's discretion and according to the specifications
(Section 02221 ). However, Section 02221 of the Construction Specifications included in
Attachment I does not provide the criteria that will be employed by the Engineer in making
this decision. Additionally, Section 01450 of the Construction Specifications states that.only
new materials are to be incorporated in the work. Please revise this section and Sections
02221 and 01450 of the Construction Specifications to include the criteria that the Engineer
shall use in determining if excavated material may be staged for subsequent use as backfill.
Additionally, the Engineer shall be prepared to demonstrate that the fill meets the backfill
requirements as specified in the Construction Specifications included in Attachment A and the
Construction Quality Assurance Plan included as Attachment 4.
Section 3.1.2 Confirmation Sampling
14. The first sentence of this section proposes collecting confirmatory samples according to a grid
spacing of 50 feet (fl). Although this may be appropriate for large excavations, Landfill B
would only require 3-4 confirmatory samples under this sampling scheme. Furthermore, the
sidewalls should be addressed according to a separate sampling scheme as only sample would
need to be collected approximately every 3 00 linear feet ( assuming an excavation depth of
eight feet). Please revise the sampling scheme to account for sidewalls and for the smaller
excavation at Landfill B.
15. Please describe the excavation/shoring procedures and the confined space entry procedures
to be implemented to enter the excavations to place the grid stakes.
Ms. Giezelle Bennett
September I 0, 1998
Page 4
• •
16. The first bullet item in the second paragraph of this section states that soil samples will be
collected from the bucket of the excavator. Please provide justification for this sampling
strategy since workers shall already have to enter the excavation to place grid stakes.
17. This section does not include any provisions for the collection of soil samples for headspace
analysis for volatile organic compound (VOC) content, although the VOC content of the
landfills is acknowledged in Section 02221 of the Construction Specifications included as
Attachment I. Due to the presence ofVOCs in Landfill A and Landfill B, headspace analysis
for VOC content should be conducted in conjunction with field screening analysis for PCB
content. Please make the necessary revisions to this section and to all other appropriate
sections and documents.
Section 3.1.3 Sample Analysis
18. This section should be shown as Section 3.1.3. Please correct this oversight.
Section 3.1.4 Clean-Closure Determination
I 9. This section does not state whether the GE shall be submitting the results of the PCB
laboratory analysis to an independent, third party to validate the results and assure that the
data meets the Contract Laboratory Protocol (CLP). To prevent under-or over-excavation
of Landfill A and Landfill B, GE should employ an independent third party to validate the
laboratory results. Please make the necessary revisions to this section and to all other
appropriate sections and documents.
Section 3.2 Backfill and Site Restoration
20. The second sentence of this section states that the borrow source used for backfill during the
Shepherd Farm remedial action will be used as the primary source of backfill for the GE
Subsite. Please revise this section to note that all alternate sources of backfill shall meet the
backfill requirements as specified in the Construction Specifications included in Attachment
A and the Construction Quality Assurance Plan included as Attachment 4.
2 I. The third sentence of this section states that clean soil from the excavation may also be
returned to the excavation at the discretion of the Resident Engineer. However, Section
01450 of the Construction Specifications states that only new materials are to be incorporated
into the work. Please revise this section and Section O I 450 to include the criteria that the
Resident Engineer shall employ in making this decision. Additionally, the Engineer shall be
prepared to demonstrate that the fill meets the backfill requirements as specified in the
Construction Specifications included in Attachment A and the Construction Quality
Assurance Plan included as Attachment 4.
Ms. Giezelle Bennett
September 10, 1998
Page4
• •
16. The first bullet item in the second paragraph of this section states that soil samples will be collected from the bucket of the excavator. Please provide justification for this sampling
strategy since workers shall already have to enter the excavation to place grid stakes.
17. This section does not include any provisions for the collection of soil samples for headspace
analysis for volatile organic compound (VOC) content, although the VOC content of the landfills is acknowledged in Section 02221 of the Construction Specifications included as Attachment 1. Due to the presence ofVOCs in Landfill A and Landfill B, headspace analysis for VOC content should be conducted in conjunction with field screening analysis for PCB
content. Please make the necessary revisions to this section and to all other appropriate
sections and documents.
Section 3.1.3 Sample Analysis
18. This section should be shown as Section 3.1.3. Please correct this oversight.
Section 3.1.4 Clean-Closure Determination
19. This section does not state whether the GE shall be submitting the results of the PCB laboratory analysis to an independent, third party to validate the results and assure that the data meets the Contract Laboratory Protocol (CLP). To prevent under-or over-excavation
of Landfill A and Landfill B, GE should employ an independent third party to validate the
laboratory results. Please make the necessary revisions to this section and to all other appropriate sections and documents.
Section 3.2 Backfill and Site Restoration
20. The second sentence of this section states that the borrow source used for backfill during the Shepherd Farm remedial action will be used as the primary source of backfill for the GE Subsite. Please revise this section to note that all alternate sources of backfill shall meet the
backfill requirements as specified in the Construction Specifications included in Attachment
A and the Construction Quality Assurance Plan included as Attachment 4.
21. The third sentence of this section states that clean soil from the excavation may also be returned to the excavation at the discretion of the Resident Engineer. However, Section
01450 of the Construction Specifications states that only new materials are to be incorporated
into the work. Please revise this section and Section O 1450 to include the criteria that the
Resident Engineer shall employ in making this decision. Additionally, the Engineer shall be
prepared to demonstrate that the fill meets the backfill requirements as specified in the
Construction Specifications included in Attachment A and the Construction Quality
Assurance Plan included as Attachment 4.
Ms. Giezelle Bennett
September I 0, I 998
Page 5
•
Section 3.4 Installation of Final Cover System
•
22. The word, "geomembrane," was misspelled in the second sentence of this section. Please correct this oversight.
23. The second sentence of this section indicates that a drainage composite geonet shall be employed as the drainage component for the landfill cover design. However, the design calculations included in Attachment 5 indicate that a twelve-inch layer of sand with a minimum hydraulic conductivity of 5.8 x 10·3 centimeters per second (emfs) shall be used on the crown of the cover and a composite geonet with a minimum transmissivity of0.0005
square feet per second (ft/s) shall be used on the sideslopes. Please revise this section to include all design elements of the landfill cover as well as demonstrate that the landfill cover meets the requirements of 40 CFR 264.
24. This section is very general and provides no detail as to how the waste is to be consolidated, how the subbase is to be placed and compacted, how the geosynthetic materials are to be placed, how the drainage materials are to be installed, how the passive gas venting system is to be installed, how the vegetative layer is to be installed, etc. Please provide much greater detail to completely describe how the landfill cover is to be constructed.
Section 4.5 Personal Hygiene and Decontamination Facilities
25. The second sentence of this section states that the Contamination Reduction Zone (CRZ) will provide an area for the donning of personal protective equipment (PPE). However, PPE must be donned in the Support Zone prior to entry into the CRZ. Please revise this section accordingly.
26. The third sentence of this section states that a temporary shed will be installed to store supplies including potable water, disposable wipes and cleaning solutions. Although it is recognized that some of these materials should be stored in the CRZ for immediate use, the bulk of the supplies must be stored in the Support Zone. Please revise this section accordingly.
Ms. Giezelle Bennett
September I 0, I 998
Page 5
•
Section 3.4 Installation of Final Cover System
•
22. The word, "geomembrane," was misspelled in the second sentence of this section. Please correct this oversight.
23. The second sentence of this section indicates that a drainage composite geonet shall be em ployed as the drainage component for the landfill cover design. However, the design calculations included in Attachment 5 indicate that a twelve-inch layer of sand with a minimum hydraulic conductivity of 5.8 x 10·3 centimeters per second (emfs) shall be used on the crown of the cover and a composite geonet with a minimum transmissivity of 0.0005 square feet per second (ft/s) shall be used on the sideslopes. Please revise this section to include all design elements of the landfill cover as well as demonstrate that the landfill cover meets the requirements of 40 CFR 264.
24. This section is very general and provides no detail as to how the waste is to be consolidated,
how the subbase is to be placed and compacted, how the geosynthetic materials are to be placed, how the drainage materials are to be installed, how the passive gas venting system is to be installed, how the vegetative layer is to be installed, etc. Please provide much greater
detail to completely describe how the landfill cover is to be constructed.
Section 4.5 Personal Hygiene and Decontamination Facilities
25. The second sentence of this section states that the Contamination Reduction Zone (CRZ) will provide an area for the donning of personal protective equipment (PPE). However, PPE must be donned in the Support Zone prior to entry into the CRZ. Please revise this section accordingly.
26. The third sentence of this section states that a temporary shed will be installed to store supplies including potable water, disposable wipes and cleaning solutions. Although it is recognized that some of these materials should be stored in the CRZ for immediate use, the bulk of the supplies must be stored in the Support Zone. Please revise this section
accordingly.
Ms. Giezelle Bennett
September I 0, 1998
Page6
• •
27. The second paragraph of this section indicates that spent fluids and cleaning solutions from
decontamination activities shall be collected daily and disposed on the DSI (prior to
installation of the cap). Please detail how these wastewaters are to be applied to the DSI.
Additionally, the second paragraph of this section indicates that wash water from general
cleaning activities (i.e., that has not contacted contaminated materials) will be poured on the
ground, taking care not to produce a slip/trip hazard. A more appropriate approach is to
apply contaminated wastewaters to the DSI (prior to installation of the cap) and apply general
cleaning wash waters to the DSI (prior to and after the installation of the cap) or discharge
to the GE wastewater treatment system. Please revise this section accordingly.
28. The last paragraph of this section indicates that dry decontamination procedures will be
implemented for the vehicle decontamination. Please include provisions in this section for wet
vehicle decontamination.
Section 4.6.1 Utilities
29. The last paragraph of this section indicates that an underground pipeline crosses the Landfill
A excavation area and that provisions have been made for Duke Power to protect or re-route
the pipeline. However, no mention is made in this section of the overhead lines, street lights
and resulting overhead/underground lines that will require removal prior to excavation
activities in Landfill A. Furthermore, no mention is made in this section of the street lights
that cross Landfill B, presumably indicating the presence of overhead or underground lines
in Landfill B. Please correct these oversights.
Section 4. 7 Permits
30. The second paragraph of this section describes the preparation of the sediment and erosion
control plan. Please provide a schedule for the completion of this task. Please bear in mind
that this plan will require approval by the NC DENR Division of Land Quality prior to
initiating any land disturbing activities.
Section 4.8.1 Sitewide Waste Management
31. The third bullet item in this section indicates that dilute fluids generated during personal
hygiene and equipment cleaning activities that do not involve decontamination of
contaminated materials will be dispersed to the ground around the cleaning station. Please
detail what personal hygiene activities, other than decontamination activities, that could not
be conducted in the Command Post (Brown House). Furthermore, the equipment cleaning
activities may result in oil/grease contaminated waters. These wash waters must be collected
for discharge to the DSI or to the GE wastewater treatment system. Please revise this section
accordingly.
Ms. Giezelle Bennett
September I 0, 1998
Page 6
• •
27. The second paragraph of this section indicates that spent fluids and cleaning solutions from
decontamination activities shall be collected daily and disposed on the OSI (prior to
installation of the cap). Please detail how these wastewaters are to be applied to the OSI.
Additionally, the second paragraph of this section indicates that wash water from general
cleaning activities (i.e., that has not contacted contaminated materials) will be poured on the
ground, taking care not to produce a slip/trip hazard. A more appropriate approach is to
apply contaminated wastewaters to the OSI (prior to installation of the cap) and apply general
cleaning wash waters to the OSI (prior to and after the installation of the cap) or discharge
to the GE wastewater treatment system. Please revise this section accordingly.
28. The last paragraph of this section indicates that dry decontamination procedures will be
implemented for the vehicle decontamination. Please include provisions in this section for wet
vehicle decontamination.
Section 4.6.1 Utilities
29. The last paragraph of this section indicates that an underground pipeline crosses the Landfill
A excavation area and that provisions have been made for Duke Power to protect or re-route
the pipeline. However, no mention is made in this section of the overhead lines, street lights
and resulting overhead/underground lines that will require removal prior to excavation
activities in Landfill A. Furthermore, no mention is made in this section of the street lights
that cross Landfill B, presumably indicating the presence of overhead or underground lines
in Landfill B. Please correct these oversights.
Section 4. 7 Permits
3 0. The second paragraph of this section describes the preparation of the sediment and erosion
control plan. Please provide a schedule for the completion of this task. Please bear in mind
that this plan will require approval by the NC DENR Division of Land Quality prior to
initiating any land disturbing activities.
Section 4.8.1 Sitewide Waste Management
3 I. The third bullet item in this section indicates that dilute fluids generated during personal
hygiene and equipment cleaning activities that do not involve decontamination of
contaminated materials will be dispersed to the ground around the cleaning station. Please
detail what personal hygiene activities, other than decontamination activities, that could not
be conducted in the Command Post (Brown House). Furthermore, the equipment cleaning
activities may result in oil/grease contaminated waters. These wash waters must be collected
for discharge to the OSI or to the GE wastewater treatment system. Please revise this section
accordingly.
Ms. Giezelle Bennett
September I 0, 1998
Page 7
•
Section 4.8.2 Excavation Wastes
•
32. This section states that construction debris will be sized for disposal in the DSI and that other
manufactured products will be physically inspected and sampled to determine the appropriate
disposal options. If one option is placement in the DSI, please provide the criteria that GE
shall employ in determining if a waste material may be placed in the DSI.
Table 8.1 Contact Information for Key Project Personnel
33. Please amend Table 8.1 to include the phone number (919/733-2801 ext 349) for the NC
DENR Project Manager, David Mattison.
Section 8.3.1 Meetings with EPA
34. Please delete the period between the acronym "HSIG" and the word "Project" in the last
sentence of the second paragraph.
Section 8.3.4 Final RA Report to EPA
3 5. The fourth bullet item indicates that the Final Remedial Action Report shall include as-built
drawings for the DSI closure including final grade, cap cross-sections, stormwater runoff
system, and final site plan. Please revise this section to include as-built drawings for the final
grade of the waste/fill, the final grade of the compacted barrier soil and the passive gas
venting system.
ATTACHMENT 1 CONSTRUCTIONS SPECIFICATIONS FOR SOILS REMEDIAL
ACTION AT GE SUBSITE
General
36. The page numbers at the bottom center of each page of this document do not present a logical
order to this document. Please revise the page numbers and the Table of Contents to provide
an easy reference to locating specific items located in this document.
3 7. This document does not include the specifications for the removal of fencing which lies in the
proximity of Landfill B and the DSI. Please correct this oversight.
38. This document does not include the specifications for the abandonment of the groundwater
monitoring wells that lie within and in the immediate proximity of Landfill A. Please correct
this oversight.
Ms. Giezelle Bennett
September 10, 1998
Page 7
•
Section 4.8.2 Excavation Wastes
•
32. This section states that construction debris will be sized for disposal in the DSI and that other
manufactured products will be physically inspected and sampled to determine the appropriate
disposal options. If one option is placement in the DSI, please provide the criteria that GE
shall employ in determining if a waste material may be placed in the DSI.
Table 8.1 Contact Information for Key Project Personnel
33. Please amend Table 8.1 to include the phone number (919/733-2801 ext 349) for the NC
DENR Project Manager, David Mattison.
Section 8.3.1 Meetings with EPA
34. Please delete the period between the acronym "HSIG" and the word "Project" in the last
sentence of the second paragraph.
Section 8.3.4 Final RA Report to EPA
3 5. The fourth bullet item indicates that the Final Remedial Action Report shall include as-built
drawings for the DSI closure including final grade, cap cross-sections, stormwater runoff
system, and final site plan. Please revise this section to include as-built drawings for the final
grade of the waste/fill, the final grade of the compacted barrier soil and the passive gas
venting system.
ATTACHMENT 1 CONSTRUCTIONS SPECIFICATIONS FOR SOILS REMEDIAL
ACTION AT GE SUB SITE
General
36. The page numbers at the bottom center of each page of this document do not present a logical
order to this document. Please revise the page numbers and the Table of Contents to provide
an easy reference to locating specific items located in this document.
' 3 7. This document does not include the specifications for the removal of fencing which lies in the
proximity of Landfill B and the DSI. Please correct this oversight.
38. This document does not include the specifications for the abandonment of the groundwater
monitoring wells that lie within and in the immediate proximity of Landfill A. Please correct
this oversight.
Ms. Giezelle Bennett
September I 0, 1998
Page 8
•
3 9. This document does not include the specifications for the removal of the overhead lines, street
lights and resulting overhead/underground lines that will require removal prior to excavation
activities in Landfill A. Furthermore, this document does not include the specifications for
the removal of the overhead or underground lines in Landfill B that presumably cross Landfill
B for the street lights that lie on either side of Landfill B. Please correct these oversights.
Table of Contents
40. The Table of Contents indicates that the General Provisions and the Special Provisions were
not included in this draft. However, these items must be included for a complete review of
this document. Please correct this oversight.
Section 01300 Control of Work
41. The second sentence of Section I. I.A should state "Nighttime refers to all other times
including all day Saturday, Sunday and legal holidays." Please correct this oversight.
Section 0 1700 Temporary Facilities
42. Paragraph 2.1.F of this Section states that a vehicle/equipment wash station shall be
constructed. Please either rephrase this paragraph to state that the vehicle/equipment wash
station is to used for decontamination purposes or provide justification for conducting
vehicle/equipment washing in addition to conventional decontamination procedures.
Section 01750 Health and Safety Provisions
43. This section does not include specifications for conducting air monitoring of the site during
the course of remedial action activities. Please correct this oversight.
Section 02222 Common Fill
44. Please revise Paragraph 3 .2.A of this Section to include the provision that the Particle Size
Analysis and Standard Proctor tests shall be conducted every 5,000 cy and for every change
in material type.
45. Please revise Paragraph 3.2.A of this Section to include the provision that the Moisture
Content test shall be conducted every 2,500 cy and for every change in material type.
Ms. Giezelle Bennett
September 10, I 998
Page 8
•
39. This document does not include the specifications for the removal of the overhead lines, street
lights and resulting overhead/underground lines that will require removal prior to excavation
activities in Landfill A. Furthermore, this document does not include the specifications for
the removal of the overhead or underground lines in Landfill B that presumably cross Landfill
B for the street lights that lie on either side of Landfill B. Please correct these oversights.
Table of Contents
40. The Table of Contents indicates that the General Provisions and the Special Provisions were
not included in this draft. However, these items must be included for a complete review of
this document. Please correct this oversight.
Section 01300 Control of Work
41. The second sentence of Section I. I.A should state "Nighttime refers to all other times
including all day Saturday, Sunday and legal holidays." Please correct this oversight.
Section 01700 Temporary Facilities
42. Paragraph 2.1.F of this Section states that a vehicle/equipment wash station shall be
constructed. Please either rephrase this paragraph to state that the vehicle/equipment wash
station is to used for decontamination purposes or provide justification for conducting
vehicle/equipment washing in addition to conventional decontamination procedures.
Section 01750 Health and Safety Provisions
43. This section does not include specifications for conducting air monitoring of the site during
the course of remedial action activities. Please correct this oversight.
Section 02222 Common Fill
44. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis and Standard Proctor tests shall be conducted every 5,000 cy and for every change
in material type.
45. Please revise Paragraph 3.2.A of this Section to include the provision that the Moisture
Content test shall be conducted every 2,500 cy and for every change in material type.
Ms. Giezelle Bennett
September 10, 1998
Page9
•
46. Please revise Paragraph 3.2.B of this Section to state that the frequency of testing for In-Situ
Moisture and In-Situ Density shall be five tests per acre per lift. Furthermore, the selected
In-Situ Moisture test method is a rapid moisture test method and should be checked against
a direct oven drying method (ASTM D-2216) at a frequency of one test per every 10 rapid
moisture tests. Additionally, the method selected for In-Situ Density testing is a nuclear
method and should be calibrated against a sand cone density test method (ASTM D-1556)
at a frequency of one test per twenty nuclear density tests.
Section 02223 Structural Fill
47. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis, Standard Proctor and Soil Classification tests shall be conducted every 5,000 cy and
for every change in material type.
48. Please revise Paragraph 3.2.A of this Section to include the provision that the Moisture
Content test shall be conducted every 2,500 cy and for every change in material type.
49. Please revise Paragraph 3.2.B of this Section to state that the frequency of testing for In,Situ
Moisture and In-Situ Density shall be five tests per acre per lift. Furthermore, the selected
In-Situ Moisture test method is a rapid moisture test method and should be checked against
a direct oven drying method (ASTM D-2216) at a frequency of one test per every 1 O rapid
moisture tests. Additionally, the method selected for In-Situ Density testing is a nuclear
method and should be calibrated against a sand cone density test method (ASTM D-1556)
at a frequency of one test per twenty nuclear density tests.
Section 02225 Barrier Soil
50. Please revise Paragraph 2. l.B.8, Paragraph 3. l.C, Paragraph 3.4.C. l, and Paragraph 3.4.C.3
of this Section to state the soil shall have an installed, in-place hydraulic conductivity no
greater than 10·7 emfs, in accordance with 40 CFR 264. ·
51. Please revise Paragraph 3.4.B.l of this Section to include the provision that the Moisture
Content test shall be conducted every 2,500 cy and for every change in material type.
52. Please revise Paragraph 3.4.B. l of this Section to include the provision that the Atterburg
Limits, Particle Size Analysis, Soil Classification and Standard Proctor tests shall be
conducted every 5,000 cy and for every change in material type.
53. Please revise Paragraph 3.4.B. l of this Section to include the provision that the Hydraulic
Conductivity test shall be conducted every I 0,000 cy and for every change in material type.
Ms. Giezelle Bennett
September 10, 1998
Page 9
• •
46. Please revise Paragraph 3.2.B of this Section to state that the frequency of testing for In-Situ
Moisture and In-Situ Density shall be five tests per acre per lift. Furthermore, the selected
In-Situ Moisture test method is a rapid moisture test method and should be checked against
a direct oven drying method (ASTM D-2216) at a frequency of one test per every 10 rapid
moisture tests. Additionally, the method selected for In-Situ Density testing is a nuclear
method and should be calibrated against a sand cone density test method (ASTM D-1556)
at a frequency of one test per twenty nuclear density tests.
Section 02223 Structural Fill
47. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis, Standard Proctor and Soil Classification tests shall be conducted every 5,000 cy and
for every change in material type.
48. Please revise Paragraph 3 .2.A of this Section to include the provision that the Moisture
Content test shall be conducted every 2,500 cy and for every change in material type.
49. Please revise Paragraph 3.2.B of this Section to state that the frequency of testing for In-Situ
Moisture and In-Situ Density shall be five tests per acre per lift. Furthermore, the selected
In-Situ Moisture test method is a rapid moisture test method and should be checked against
a direct oven drying method (ASTM D-2216) at a frequency of one test per every IO rapid
moisture tests. Additionally, the method selected for In-Situ Density testing is a nuclear
method and should be calibrated against a sand cone density test method (ASTM D-1556)
at a frequency of one test per twenty nuclear density tests.
Section 02225 Barrier Soil
50. Please revise Paragraph 2.1.B.8, Paragraph 3.1.C, Paragraph 3.4.C. l, and Paragraph 3.4.C.3
of this Section to state the soil shall have an installed, in-place hydraulic conductivity no
greater than 10·7 emfs, in accordance with 40 CFR 264. ·
51. Please revise Paragraph 3.4.B.I of this Section to include the provision that the Moisture
Content test shall be conducted every 2,500 cy and for every change in material type.
52. Please revise Paragraph 3.4.B. l of this Section to include the provision that the Atterburg
Limits, Particle Size Analysis, Soil Classification and Standard Proctor tests shall be
conducted every 5,000 cy and for every change in material-type.
53. Please revise Paragraph 3.4.B. l of this Section to include the provision that the Hydraulic
Conductivity test shall be conducted every I 0,000 cy and for every change in material type.
Ms. Giezelle Bennett
September 10, 1998
Page 10
•
54. Please revise Paragraph 3.4.B.2 of this Section to state that the sand cone density test method
(ASTM D-1556) will be tested at a frequency of one test per twenty nuclear density tests ..
Furthermore, the selected In-Situ Moisture test method is a rapid moisture test method and
should be checked against a direct oven drying method (ASTM D-2216) at a frequency of
one test per every 10 rapid moisture tests.
55. Please revise Paragraph 3.4.D. l of this Section to state that powdered bentonite or bentonite
pellets shall be hydrated in place for repairing all Shelby tube sample holes.
Section 02226 Vegetative Soil
56. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis and Soil Classification tests shall be conducted every 5,000 cy and for every change
in material type.
Section 02229 On-Site Disposal
57. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis and Soil Classification tests shall be conducted every 5,000 cy and for every change
in material type (i.e., Landfill A soils, Landfill B soils).
58. Please revise Paragraph 3.2.B of this Section to state that the frequency of testing for In-Situ
Moisture and In-Situ Density shall be 5 tests per acre per lift. Furthermore, the selected In-
Situ Moisture test method is a rapid moisture test method and should be checked against a
direct oven drying method (ASTM D-2216) at a frequency of one test per every 10 rapid
moisture tests. Additionally, the method selected for In-Situ Density testing is a nuclear
method and should be calibrated against a sand cone density test method (ASTM D-1556)
at a frequency of one test per twenty nuclear density tests.
59. Please provide justification for specifying compaction criteria in Paragraph 3.4.C. l that is less
than the compaction criteria specified in the upper layers of the landfill cover.
Section 02230 Rock, Stone, and Granular Material
60. Paragraph 2.1.A of this Section states that sand is not to be used for the landfill cover. Please
revise this Section to include the use of sand for the drainage layer on the crown of the landfill
cover.
Ms. Giezelle Bennett
September 10, 1998
Page 10
•
54. Please revise Paragraph 3.4.B.2 ofthis Section to state that the sand cone density test method
(ASTM D-1556) will be tested at a frequency of one test per twenty nuclear density tests ..
Furthermore, the selected In-Situ Moisture test method is a rapid moisture test method and
should be checked against a direct oven drying method (ASTM D-2216) at a frequency of
one test per every IO rapid moisture tests.
55. Please revise Paragraph 3.4.D. l of this Section to state that powdered bentonite or bentonite
pellets shall be hydrated in place for repairing all Shelby tube sample holes.
Section 02226 Vegetative Soil
56. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis and Soil Classification tests shall be conducted every 5,000 cy and for every change
in material type.
Section 02229 On-Site Disposal
57. Please revise Paragraph 3.2.A of this Section to include the provision that the Particle Size
Analysis and Soil Classification tests shall be conducted every 5,000 cy and for every change
in material type (i.e., Landfill A soils, Landfill B soils).
58. Please revise Paragraph 3.2.B of this Section to state that the frequency of testing for In-Situ
Moisture and In-Situ Density shall be 5 tests per acre per lift. Furthermore, the selected In-
Situ Moisture test method is a rapid moisture test method and should be checked against a
direct oven drying method (ASTM D-22 I 6) at a frequency of one test per every IO rapid
moisture tests. Additionally, the method selected for In-Situ Density testing is a nuclear
method and should be calibrated against a sand cone density test method (ASTM D-1556)
at a frequency of one test per twenty nuclear density tests.
59. Please provide justification for specifying compaction criteria in Paragraph 3. 4. C. l that is less
than the compaction criteria specified in the upper layers of the landfill cover.
Section 02230 Rock, Stone, and Granular Material
60. Paragraph 2. l.A of this Section states that sand is not to be used for the landfill cover. Please
revise this Section to include the use of sand for the drainage layer on the crown of the landfill
cover.
Ms. Giezelle Bennett
September 10, I 998
Page 11
•
61. Please revise Paragraph 1.4.A of this Section to include hydraulic conductivity analyses to be
conducted at a frequency of one test per 2,500 cy and for every change in material type.
Furthermore, please revise this Paragraph to include the provision that the Grain Size
Distribution, Soil Classification and Standard Proctor tests shall be conducted every 2,500
cy and for every change in material type.
62. Please revise Paragraph 3.5.A of this Section to include the provision that the Grain Size
Distribution, Permeability of Granular Soils and In-Place Density tests shall be conducted for
every change in material type.
Section 02611 Plastic Piping
63. Please demonstrate the adequacy of conformance test method ASTM D-2564 for Solvent
Cements for Polyvinyl Chloride (PVC) Plastic Pipe and Fittings. The US EPA technical
guidance document, Quality Assurance and Quality Control for Waste Containment Facilities,
specifies conformance test method ASTM D-3034.
64. Paragraph 2.1 of this Section does not specify the minimum and maximum allowable
perforations for the corrugated polyethylene drainage pipe. Please correct this oversight.
Section 02715 Geocomposite Drainage Layer
65. Paragraph 3.2.C of this Section should be revised to specify a testing frequency of one test
per 50,000 square feet with a minimum of one test per lot.
66. Please delete the portion of Paragraph 3.4.B. l of this Section that allows for the butting of
the geonet.
67. Please delete Paragraph 3.4.B.2 of this Section. Horizontal seams are not allowed on
sideslopes. This requires that the geocomposite be provided in rolls that are at least as long
as the sideslopes.
Section 02776 Geosynthetic Materials
68. Please revise Paragraph 1.6.B.2.c of this Section to state that the geosynthetic manufacturer
shall have experience in the manufacture of three polyethylene landfill covers of at least
I 0,000,000 square feet per facility.
69. Please revise Paragraph 1.6.D .3. d of this Section to state that the geosynthetic installer shall
have experience in the installation of three polyethylene landfill covers ofat least 10,000,000
square feet per facility.
Ms. Giezelle Bennett
September 10, 1998
Page 11
• •
61. Please revise Paragraph 1.4.A of this Section to include hydraulic conductivity analyses to be
conducted at a frequency of one test per 2,500 cy and for every change in material type.
Furthermore, please revise this Paragraph to include the provision that the Grain Size
Distribution, Soil Classification and Standard Proctor tests shall be conducted every 2,500
cy and for every change in material type.
62. Please revise Paragraph 3.5.A of this Section to include the provision that the Grain Size
Distribution, Permeability of Granular Soils and In-Place Density tests shall be conducted for
every change in material type.
Section 02611 Plastic Piping
63. Please demonstrate the adequacy of conformance test method ASTM D-2564 for Solvent
Cements for Polyvinyl Chloride (PVC) Plastic Pipe and Fittings. The US EPA technical
guidance document, Quality Assurance and Quality Control for Waste Containment Facilities,
specifies conformance test method ASTM D-3034.
64. Paragraph 2.1 of this Section does not specify the minimum and maximum allowable
perforations for the corrugated polyethylene drainage pipe. Please correct this oversight.
Section 02715 Geocomposite Drainage Layer
65. Paragraph 3.2.C of this Section should be revised to specify a testing frequency of one test
per 50,000 square feet with a minimum of one test per lot.
66. Please delete the portion of Paragraph 3.4.B. l of this Section that allows for the butting of
the geonet.
67. Please delete Paragraph 3.4.B.2 of this Section. Horizontal seams are not allowed on
sideslopes. This requires that the geocomposite be provided in rolls that are at least as long
as the sideslopes.
Section 02776 Geosynthetic Materials
68. Please revise Paragraph 1.6.B.2.c of this Section to state that the geosynthetic manufacturer
shall have experience in the manufacture of three polyethylene landfill covers of at least
10,000,000 square feet per facility.
69. Please revise Paragraph 1.6.D.3 .d of this Section to state that the geosynthetic installer shall
have experience in the installation of three polyethylene landfill covers ofat least 10,000,000
square feet per facility.
Ms. Giezelle Bennett
September I 0, 1998
Page 12
•
70. Please revise Paragraph 3.1.B.c of this Section to specify the upper ambient temperature
limits of geomembrane installation.
71. Please revise Paragraph 3. I .B of this Section to specify that horizontal seams are not allowed
on sideslopes. This requires that the geomembrane be provided in rolls that are at least as
long as the sideslopes.
72. Please revise Paragraph 3.1.C.6.a of this Section to state that each seamer shall conduct two
trial seams per day, one at the start of the day and one at approximately half-way through the
day (immediately following lunch generally works well).
73. Please revise Paragraph 3.1.C.7.d of this Section to state thatthe patch of the same
geomembrane material shall extend a minimum of 12 inches beyond the cut in all directions.
Section 02900 Topsoil, Mulching and Seeding
74. Please revise Paragraph 3.2.A of this Section to state that in addition to the testing frequency
specified, conformance testing shall be conducted upon each change in material type.
ATTACHMENT 3 CONSTRUCTION HEALTH AND SAFETY/CONTINGENCY PLAN
75. Additional comments from Mr. David Lilley, Superfund Section Industrial Hygienist, are
attached. Please address these comments as well.
Table of Contents
76. The Table of Contents should include the entries for Section 8.2.2.1, Section 8.2.2.2 and
Section 8.2.2.3. Please correct this oversight.
Section 5.1.5 Break Areas
77. The first sentence of this section should state "Break areas will be established and maintained .
. . " Please correct this oversight.
Section 9.0 Confined Space Entry
78. Although this section is very thorough, please revise this section to make it very clear that
entry into the proposed excavations constitutes confined space entry. Furthermore, please
provide additional discussion of the excavation/shoring activities, including the inspection
procedures, in order to provide for the safety of those workers that enter the excavation.
Ms. Giezelle Bennett
September 10, 1998
Page 12
•
70. Please revise Paragraph 3.1.B.c of this Section to specify the upper ambient temperature
limits of geomembrane installation.
71. Please revise Paragraph 3. l .B of this Section to specify that horizontal seams are not allowed
on sideslopes. This requires that the geomembrane be provided in rolls that are at least as
long as the sideslopes.
72. Please revise Paragraph 3.1.C.6.a of this Section to state that each seamer shall conduct two
trial seams per day, one at the start of the day and one at approximately half-way through the
day (immediately following lunch generally works well).
73. Please revise Paragraph 3.1.C.7.d of this Section to state thatthe patch of the same
geomembrane material shall extend a minimum of 12 inches beyond the cut in all directions.
Section 02900 Topsoil, Mulching and Seeding
74. Please revise Paragraph 3.2.A of this Section to state that in addition to the testing frequency
specified, conformance testing shall be conducted upon each change in material type.
ATTACHMENT 3 CONSTRUCTION HEALTH AND SAFETY/CONTINGENCY PLAN
75. Additional comments from Mr. David Lilley, Superfund Section Industrial Hygienist, are
attached. Please address these comments as well.
Table of Contents
76. The Table of Contents should include the entries for Section 8.2.2.1, Section 8.2.2.2 and
Section 8.2.2.3. Please correct this oversight.
Section 5.1.5 Break Areas
77. The first sentence of this section should state "Break areas will be established and maintained .
. . " Please correct this oversight.
Section 9.0 Confined Space Entry
78. Although this section is very thorough, please revise this section to make it very clear that
entry into the proposed excavations constitutes confined space entry. Furthermore, please
provide additional discussion of the excavation/shoring activities, including the inspection
procedures, in order to provide for the safety of those workers that enter the excavation.
Ms. Giezelle Bennett
September 10, 1998
Page 13
Table 10.1 Emergency Response Contacts and Resources
•
79. Please amend Table I 0.1 to include the phone number (919/733-280 I ext 349) for the NC
DENR Project Manager, David Mattison.
Section 11.2.3 Response
Organic Vapor Emission Control
80. The second sentence of this section states that " ... PPE upgrades will be implemented as
described in Section xx." Please revise this document to include a section describing the
procedures for determining the necessitiy for a PPE upgrade and revise this sentence
accordingly.
Emergency Response
81. Please revise this section to include notification of the appropriate US EPA and NC DENR
representatives.
Section 11.3.3 Response
82. Please revise this section to include notification of the appropriate US EPA and NC DENR
representatives.
Section 11.4.3 Response
83. Please revise this section to include notification of the appropriate US EPA and NC DENR
representatives.
Appendix B Heat Stress Prevention Program
Table of Contents
84. The page numbers for the entries in the Table of Contents were inadvertently omitted. Please
correct this oversight.
Appendix C Hazard Communication Program
Table of Contents
85. The page numbers for the entries in the Table of Contents were inadvertently omitted. Please
correct this oversight.
Ms. Giezelle Bennett
September 10, 1998
Page 13
•
Table 10.1 Emergency Response Contacts and Resources
•
79. Please amend Table 10.1 to include the phone number (919/733-2801 ext 349) for the NC
DENR Project Manager, David Mattison.
Section 11.2.3 Response
Organic Vapor Emission Control
80. The second sentence of this section states that " ... PPE upgrades will be implemented as
described in Section xx." Please revise this document to include a section describing the
procedures for determining the necessitiy for a PPE upgrade and revise this sentence
accordingly.
Emergency Response
81. Please revise this section to include notification of the appropriate US EPA and NC DENR
representatives.
Section 11.3.3 Response
82. Please revise this section to include notification of the appropriate US EPA and NC DENR
representatives.
Section 11.4.3 Response
83. Please revise this section to include notification of the appropriate US EPA and NC DENR
representatives.
Appendix B Heat Stress Prevention Program
Table of Contents
84. The page numbers for the entries in the Table of Contents were inadvertently omitted. Please
correct this oversight.
Appendix C Hazard Communication Program
Table of Contents
85. The page numbers for the entries in the Table of Contents were inadvertently omitted. Please
correct this oversight.
Ms. Giezelle Bennett
September I 0, I 998
Page 14
• •
ATTACHMENT 4 CONSTRUCTION QUALITY ASSURANCE PLAN
General
86. Please ensure that the Construction Quality Assurance Plan encompasses all conformance
testing as specified in the Construction Specifications included as Attachment I as well as all
encompassing all comments made by the US EPA and the NC DENR.
87. This document does not include provisions for the documentation that the remedial action
meets appropriate air monitoring requirements. Please correct this oversight.
Table of Contents
88. The page number for Section 2.1.2 should be given as page 6 in the Table of Contents.
Please correct this oversight.
Section 1.3 Parties
89. This section does not identify the laboratory or laboratories that shall be responsible for
quality assurance testing of the soil, geotextiles and other appropriate materials. Please revise
this section accordingly.
Section 1.3.4 Quality Assurance Team
90. This section states that HSI GeoTrans (HSIG) is to be responsible for quality assurance of
the landfill cover construction. Although HSIG, as the engineering design firm, must
participate in the quality assurance of the landfill cover construction, please provide
justification for not employing an independent, third party for quality assurance/quality
control functions.
Section 2.3.3 Level of Experience
91. Please revise this section to include the provision that the quality assurance monitor be
certified by the National Institute for Certification in Engineering Technologies (NICET).
Section 3.2.1 Level of Experience
92. Please revise this section to state that the geosynthetic manufacturer and the geosynthetic
contractor both have experience in the manufacture and installation of three polyethylene
landfill covers ofat least 10,000,000 square feet per facility.
Ms. Giezelle Bennett
September JO, 1998
Page 14
• •
ATTACHMENT 4 CONSTRUCTION QUALITY ASSURANCE PLAN
General
86. Please ensure that the Construction Quality Assurance Plan encompasses all conformance
testing as specified in the Construction Specifications included as Attachment I as well as all
encompassing all comments made by the US EPA and the NC DENR.
87. This document does not include provisions for the documentation that the remedial action
meets appropriate air monitoring requirements. Please correct this oversight.
Table of Contents
88. The page number for Section 2.1.2 should be given as page 6 in the Table of Contents.
Please correct this oversight.
Section 1.3 Parties
89. This section does not identify the laboratory or laboratories that shall be responsible for
quality assurance testing of the soil, geotextiles and other appropriate materials. Please revise
this section accordingly.
Section 1.3.4 . Quality Assurance Team
90. This section states that HSI GeoTrans (HSIG) is to be responsible for quality assurance of
the landfill cover construction. Although HSIG, as the engineering design firm, must
participate in the quality assurance of the landfill cover construction, please provide
justification for not employing an independent, third party for quality assurance/quality
control functions.
Section 2.3.3 Level of Experience
91. Please revise this section to include the provision that the quality assurance monitor be
certified by the National Institute for Certification in Engineering Technologies (NICET).
Section 3.2.1 Level of Experience
92. Please revise this section to state that the geosynthetic manufacturer and the geosynthetic
contractor both have experience in the manufacture and installation of three polyethylene
landfill covers ofat least 10,000,000 square feet per facility.
Ms. Giezelle Bennett
September 10, 1998
Page 15
•
A TIACHMENT 5 DESIGN CALCULATIONS
•
Drainage Layer Design -Composite Geonet/Geotextile Analysis
93. Per the ARARs of the ROD, the final cover for the landfill must be designed in accordance
with 40 CFR 264. Therefore, the hydraulic conductivity of the barrier soil must be no greater
than 10·7 emfs. Please correct this oversight.
94. The diagram shown on page 1 of this section provides the hydraulic conductivity values for
the various layers of the landfill cap design. Please provide the source of these values.
95. Please provide an analysis of the anticipated settlement and slope stability given the proposed
landfill cover design.
Hydraulic Evaluation of Landfill Performance (HELP Model Version 3.04)
96. The HELP Model output indicates that the flexible membrane liner (FML) is 1.60 inches
thick. However, Section 02776 of the Construction Specifications indicates that the FML is
40 mil linear low density polyethylene (LLDPE). Please clarify this discrepancy.
Rainfall Runoff Analysis of Final Site Plans by Rational Method
97. This section reference several tables from the "Erosion and Sediment Control Planning and
Design Manual" (NC DENR), "Applied Hydrology" (Chow, et al), Braeter and King, and TP-
40. Please provide copies of all tables used in the Rational Method analysis, including those
used to size the drainage channels.
98. Figure l included in this section does not depict the topographic relief at the site.
Furthermore, it is unclear as to whether the hydrologic analysis was conducted on existing or
proposed conditions. Please correct these oversights.
PREFINAL DESIGN CONSTRUCTION DRAWINGS
General
99. The PreFinal Design Construction Drawings do not include drawings of necessary items such
as, but not limited to, site layout, temporary buildings, job trailers, decontamination facilities,
FML panel layout, geonet panel layout, FML seam detail, FML patch detail, sand drainage
layer/geonet interface, sand drainage layer/downchute interface, sediment/erosion control
structures, etc. Please correct these oversights.
Ms. Giezelle Bennett
September 10, 1998
Page 15
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ATTACHMENT 5 DESIGN CALCULATIONS
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Drainage Layer Design -Composite Geonet/Geotextile Analysis
93. Per the ARARs of the ROD, the final cover for the landfill must be designed in accordance
with 40 CFR 264. Therefore, the hydraulic conductivity of the barrier soil must be no greater
than 10·7 emfs. Please correct this oversight.
94. The diagram shown on page 1 of this section provides the hydraulic conductivity values for
the various layers of the landfill cap design. Please provide the source of these values.
95. Please provide an analysis of the anticipated settlement and slope stability given the proposed
landfill cover design.
Hydraulic Evaluation of Landfill Performance (HELP Model Version 3.04)
96. The HELP Model output indicates that the flexible membrane liner (FML) is 1.60 inches
thick. However, Section 02776 of the Construction Specifications indicates that the FML is
40 mil linear low density polyethylene (LLDPE). Please clarify this discrepancy.
Rainfall Runoff Analysis of Final Site Plans by Rational Method
97. This section reference several tables from the "Erosion and Sediment Control Planning and
Design Manual" (NC DENR), "Applied Hydrology" (Chow, et al), Braeter and King, and TP-
40. Please provide copies of all tables used in the Rational Method analysis, including those
used to size the drainage channels.
98. Figure 1 included in this section does not depict the topographic relief at the site.
Furthermore, it is unclear as to whether the hydrologic analysis was conducted on existing or
proposed conditions. Please correct these oversights.
PREFINAL DESIGN CONSTRUCTION DRAWINGS
General
99. The PreFinal Design Construction Drawings do not include drawings of necessary items such
as, but not limited to, site layout, temporary buildings, job trailers, decontamination facilities,
FML panel layout, geonet panel layout, FML seam detail, FML patch detail, sand drainage
layer/geonet interface, sand drainage layer/downchute interface, sediment/erosion control
structures, etc. Please correct these oversights.
Ms. Giezelle Bennett
September I 0, 1998
Page 16
Drawing No. 0
• •
Project Title Sheet
I 00. The title for Drawing No. 3, as shown on the Drawing Index on Drawing No. 0, should be
given as Landfill A Excavation and On-Site Disposal Plan. Please correct this oversight.
Drawing No. 1 Site Plan Existing Features
IO I. Drawing No. I indicates the approximate locations of four wetlands. However, although
Drawings 1-3 reference the protection of wetlands in accordance with the Section 01800 of
the Construction Specifications, none of the submitted documents including Section 01800
present any specific details how the wetlands are to be protected. Specifically, the southern
tip of Landfill B lies in a wetland. The submitted documents must provide specific details
how GE proposes to mitigate impacts to this wetland. Please correct these oversights.
Furthermore, the Preliminary Design (30%) Report indicated in Appendix F -Wetland
Delineation Report (ESC, Ltd., 1998) that the jurisdictional boundaries of the wetlands are
to be verified by the United States Army Corps of Engineers (USACE) and that GE would
perform a metes and bounds survey following the USACE inspection. Please provide a
timeframe for these tasks to be completed. All reports generated by this verification
inspection and the metes and bounds survey must be submitted to the US EPA and the NC
DENR.
Drawing No. 2 Landfill B Excavation and Site Plan
I 02. The first note for Drawing No. 2 indicates that the maximum depth of excavation shall be
eight feet below existing grade. Please revise the first note for Drawing No. 2 to indicate .
that the maximum depth of excavation shall be eight feet below existing grade or as
determined by confirmatory sampling.
Drawing No. 3 Landfill A Excavation and On-Site Disposal Plan
103. The first note for Drawing No. 3 indicates that the maximum depth of excavation shall be
eight feet below existing grade. Please revise the first note for Drawing No. 3 to indicate
that the maximum depth of excavation shall be eight feet below existing grade or as
determined by confirmatory sampling.
104. The third note for Drawing No. 3 states that the asphaltic concrete paving is to be restored
as shown in detail 1, cut sheet no. 3, plan drawing no. 9. However, the detail for the asphaltic
concrete paving is actually shown in detail no. 3, cut sheet no. 3, plan drawing no. 9. Please
clarify this discrepancy.
Ms. Giezelle Bennett
September I 0, 1998
Page 16
Drawing No. 0
• •
Project Title Sheet
100. The title for Drawing No. 3, as shown on the Drawing Index on Drawing No. 0, should be
given as Landfill A Excavation and On-Site Disposal Plan. Please correct this oversight.
Drawing No. 1 Site Plan Existing Features
IO I. Drawing No. I indicates the approximate locations of four wetlands. However, although
Drawings 1-3 reference the protection of wetlands in accordance with the Section 01800 of
the Construction Specifications, none of the submitted documents including Section 01800
present any specific details how the wetlands are to be protected. Specifically, the southern
tip of Landfill B lies in a wetland. The submitted documents must provide specific details
how GE proposes to mitigate impacts to this wetland. Please correct these oversights.
Furthermore, the Preliminary Design (30%) Report indicated in Appendix F -Wetland
Delineation Report (ESC, Ltd., 1998) that the jurisdictional boundaries of the wetlands are
to be verified by the United States Army Corps of Engineers (USACE) and that GE would
perform a metes and bounds survey following the USACE inspection. Please provide a
timeframe for these tasks to be completed. All reports generated by this verification
inspection and the metes and bounds survey must be submitted to the US EPA and the NC
DENR.
Drawing No. 2 Landfill B Excavation and Site Plan
I 02. The first note for Drawing No. 2 indicates that the maximum depth of excavation shall be
eight feet below existing grade. Please revise the first note for Drawing No. 2 to indicate .
that the maximum depth of excavation shall be eight feet below existing grade or as
determined by confirmatory sampling.
Drawing No. 3 Landfill A Excavation and On-Site Disposal Plan
I 03. The first note for Drawing No. 3 indicates that the maximum depth of excavation shall be
eight feet below existing grade. Please revise the first note for Drawing No. 3 to indicate
that the maximum depth of excavation shall be eight feet below existing grade or as
determined by confirmatory sampling.
104. The third note for Drawing No. 3 states that the asphaltic concrete paving is to be restored
as shown in detail 1, cut sheet no. 3, plan drawing no. 9. However, the detail for the asphaltic
concrete paving is actually shown in detail no. 3, cut sheet no. 3, plan drawing no. 9. Please
clarify this discrepancy.
Ms. Giezelle Bennett
September I 0, I 998
Page 17
Drawing No. 4
• •
Cap Final Site Plan
105. Drawing No. 4 indicates that the area to be capped by the landfill cover extends only to those
areas within the fenced portion of the DSI. However, Figure 2-3 of the Work Plan for Soils
Remedial Action at GE Subsite indicates that the PCB contamination extends beyond the
fenced portion of the DSI to the northwest. Please describe how the PCB contaminated soils
that lie outside of the fenced portion of the DSI are to be addressed.
I 06. Drawing No. 4 references Note I under the leader arrow which indicates the location of the
Gas Trench. However, this reference should be made to Note 7. Please correct this
oversight.
Drawing No. 5 Cap Cross-Sections
I 07. The cap cross-sections included as Drawing No. 5 do not show the maximum extent of waste
as the waste extends to the outer edges of the cap system. Additionally, it appears that there
is insufficient compacted barrier soils on the sideslopes. Please correct these deficiencies.
Drawing No. 6 Cap Cross-Sections
108. The cap cross-sections included as Drawing No. 6 do not show the maximum extent of waste
as the waste extends to the outer edges of the cap system. Additionally, it appears that there
is insufficient compacted barrier soils on the sideslopes. Please correct these deficiencies.
Drawing No. 7 Cap Cross-Sections
109. The cap cross-sections included as Drawing No. 7 do not show the maximum extent of waste
as the waste extends to the outer edges of the cap system. Additionally, it appears that there
is insufficient compacted barrier soils on the sideslopes. Please correct these deficiencies.
Drawing No. 8 Cap Details
110. The Landfill Cap Cross-Section, Typical, shown on Drawing 8 indicates the cross-section of
the landfill cap along what is presumed to be the sideslopes ( due to the presence of the geonet
for drainage). However, a landfill cap cross-section depicting the crown of the cap should
be included in order to accurately depict the twelve inch drainage layer of sand with a
minimum hydraulic conductivity of 5.8 x 10·3 emfs (as indicated in the design calculations
included in Attachment 5). Additionally, a detail should be included to depict how the water
collected at the crown is to be transferred to the downchutes. Furthermore, please provide
a detail indicating the geonet is to be secured at the crown.
Ms. Giezelle Bennett
September 10, 1998
Page 17
Drawing No. 4
• •
Cap Final Site Plan
105. Drawing No. 4 indicates that the area to be capped by the landfill cover extends only to those
areas within the fenced portion of the DSI. However, Figure 2-3 of the Work Plan for Soils
Remedial Action at GE Subsite indicates that the PCB contamination extends beyond the
fenced portion of the DSI to the northwest. Please describe how the PCB contaminated soils
that lie outside of the fenced portion of the DSI are to be addressed.
I 06. Drawing No. 4 references Note 1 under the leader arrow which indicates the location of the
Gas Trench. However, this reference should be made to Note 7. Please correct this
oversight.
Drawing No. 5 Cap Cross-Sections
107. The cap cross-sections included as Drawing No. 5 do not show the maximum extent of waste
as the waste extends to the outer edges of the cap system. Additionally, it appears that there
is insufficient compacted barrier soils on the sideslopes. Please correct these deficiencies.
Drawing No. 6 Cap Cross-Sections
108. The cap cross-sections included as Drawing No. 6 do not show the maximum extent of waste
as the waste extends to the outer edges of the cap system. Additionally, it appears that there
is insufficient compacted barrier soils on the sideslopes. Please correct these deficiencies.
Drawing No. 7 Cap Cross-Sections
109. The cap cross-sections included as Drawing No. 7 do not show the maximum extent of waste
as the waste extends to the outer edges of the cap system. Additionally, it appears that there
is insufficient compacted barrier soils on the sideslopes. Please correct these deficiencies.
Drawing No. 8 Cap Details
110. The Landfill Cap Cross-Section, Typical, shown on Drawing 8 indicates the cross-section of
the landfill cap along what is presumed to be the sideslopes ( due to the presence of the geonet
for drainage). However, a landfill cap cross-section depicting the crown of the cap should
be included in order to accurately depict the twelve inch drainage layer of sand with a
minimum hydraulic conductivity of 5.8 x 10·3 emfs (as indicated in the design calculations
included in Attachment 5). Additionally, a detail should be included to depict how the water
collected at the crown is to be transferred to the downchutes. Furthermore, please provide
a detail indicating the geonet is to be secured at the crown.
Ms. Giezelle Bennett
September 10, 1998
Page 18
• •
111. The Passive Gas Vent Detail shown on Drawing No. 8 indicates that the exposed casing and
riser shall be painted bright (NC Department of Transportation) orange. Solvent-based paints
should not be applied to the exposed casing and riser to prevent the potential for solvent
migration. Although a minute possibility, there are documented cases of this occurring.
Please correct this oversight.
Drawing No. 9 Miscellaneous Details
112. Drawing No. 9 indicates that both the Drainage Channel, Section, Typical Detail and the
Drainage Downchute, Section, Typical Detail are detail no. 2. Please clarify this discrepancy.
Furthermore, this discrepancy is noted on the cut sheet no. 4. Please resolve this discrepancy.
Ms. Giezelle Bennett
September I 0, 1998
Page 18
• •
111. The Passive Gas Vent Detail shown on Drawing No. 8 indicates that the exposed casing and
riser shall be painted bright (NC Department of Transportation) orange. Solvent-based paints
should not be applied to the exposed casing and riser to prevent the potential for solvent
migration. Although a minute possibility, there are documented cases of this occurring.
Please correct this oversight.
Drawing No. 9 Miscellaneous Details
112. Drawing No. 9 indicates that both the Drainage Channel, Section, Typical Detail and the
Drainage Downchute, Section, Typical Detail are detail no. 2. · Please clarify this discrepancy.
Furthermore, this discrepancy is noted on the cut sheet no. 4. Please resolve this discrepancy.