NCD079044426_20000315_General Electric Co. Shepherd Farm_FRBCERCLA RA_Remedial Action Work Plan 1997 - 2000-OCR

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
. 61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
March 15, 2000
MEMORANDUM
RECEIVED
MAR 17 2000
SUPERFUND SECTION
SUBJECT:
FROM:
TO:
GE/Shepherd Farm NPL Site
East Flat Rock, North Carolina
Giezelle Bennett, RP~
Remedial Design Rter
David Mattison, NC DENR
Elmer Akin/Bill O'Steen, OTS
Scott Huling, O_RD
Tom Augspurger, US F&W
Lynn France, COM
Attached is the "Final" Remedial Design and Remedial Action Work Plan for the
GE Site. Please review these documents and send me any comments that you may
have no later than April 7, 2000.
As always, thank you for your continued support. I really appreciate the
timeliness of the last set of comments. If you have any questions, please give me a call
at 404-562-8824.
NA
:\, IMCP,E~R
.~:::.:,,:·:·:
JAMES 8. HUNT JR: ,
, GoVERNOR
WAYNE MCDEVITT
SECRETARY
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Ms. Giezelle Bennett
Superfund Branch
Waste Management Division
NORTH !.ROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
February 16, 1999
United States Environmental Protection Agency
Region IV
6 I Forsyth Street, I I th Floor
Atlanta, Georgia 30303
RE: Final (100%) Remedial Design &
Remedial Action Work Plan for Soils at the GE Subsite
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
Dear Ms. Bennett:
The Final (] 00%) Remedial Design & Remedial Action Work Plan for Soils at the GE
Subsite were received by the Superfund Section of the North Carolina Department of
Environment and Natural Resources (NC DENR). The Superfund Section has reviewed
these documents and offers the following attached comments.
We appreciate the opportunity to comment on these documents. If you have any
questions, please feel free to call me at (9 I 9) 733-280 I, extension 349.
Attachment
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
.401 OBERLIN ROAD, SUITE TSO, RALEIGH, NC 27605
PHONE [phone] FAX 919-715•3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
Ms. Giczcllc Bcnnell
Fehruary 16, 1999
Page 2
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REMEDIAL ACTION WORK PLAN FOR SOILS AT GE SUBSITE
List of Figures
I. The response to US EPA comment #6 stated that the List of Figures and the title of Figure
8.1 have been revised. However, the List of Figures in the revised document does not
include this correction. Please correct this oversight.
Section 2.4.4 Spot Excavation
2. The response to US EPA comment #I states that the cap design has been modified to address
the two areas of polychlorinated biphenyl (PCB) contamination that lie to the west of the dry
sludge impoundment (DSD. However, Section 2.4.4 has not been modified. Please revise
the first two sentences of Section 2.4.4 to state that "The cap to be installed at the DSI covers
the entire unit with the exception of a small area in the northwest comer and two areas along
the western perimeter of the fence and adjacent to Landfill A. These areas will be remediated
by excavation." Furthermore, please revise the fourth sentence of this section to include the
appropriate estimate of soil to be removed, based upon the excavation of these three areas.
Section 3.1.2 Confirmation Sampling
3. The response to US EPA comment is adequate but still does not address any contingencies
if volatile organic compound (VOC) contamination exceeds North Carolina soil remediation
standards. Please include the following statements at the end of the third paragraph in
Section 3.1.2:
"In the event that soil analytical results exceed North Carolina soil remediation
standards, HSIG shall determine the extent of VOC contamination. If the extent of
VOC contamination appears to be limited (i.e., <10 cubic yards), HSIG shall remove
the VOC contaminated soils and place in the DSI. If the extent of VOC
contamination appears to be excessive, HSIG shall consult with GE, the US EPA and
the NC DENR to determine the appropriate course of action."
4. The response to US EPA comment #20 states that a 10.2 electronvolt (eV) lamp has been
determined to be an appropriate lamp based on the ionization potential of the VOCs present
at the site. However, Section 7.3.1 of the Construction Health and Safety/Contingency Plan
(Attachment 3) states that a photoionization detector (PID) equipped with a 11.7 eV lamp
shall be used. Please clarify this discrepancy and make the appropriate revisions.
Ms. Giezelle Bennett
February I 6, I 999
Page 3
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5. The bullet list in the fourth paragraph of this section has several typographical errors. The
first sentence of the fifth bullet should state that "Two soil samples will be collected at each
confirmation sample location." The second sentence of the seventh bullet should state that "Sample shipments to the offsite laboratory will be transmitted as soon as practical and no
later than five days after sample collection to assure that the seven-day time limit for
extraction is met." Lastly, the first sentence of the eighth bullet should state that "If field
analysis shows that the samples has less than 10.0 ppm PCBs, the split sample will be
shipped to a fixed laboratory for PCB analysis using EPA Method 8081." Please correct
these oversights.
Figure 3.1 Decision tree for landfill excavation
6. Figure 3.1 should be revised to incorporate the text of Section 3.1.2 and the response to US
EPA comment #10. Specifically, following the action "Screen headspace for VOCs using
PID," Figure 3.1 should include the decision, "Does PID indicate VOCs > 1 ppm." Figure 3.1 should indicate that a "No" outcome should proceed to the action "Collect confirmation
soil samples." However, Figure 3.1 should indicate that a "Yes" outcome results in the action "Submit soil sample to a fixed laboratory for VOC analysis." This action should
further include the decision "Do results exceed NC soil remediation standards." The "No" outcome can proceed directly to the action "Collect confirmation soil samples." However,
the "Yes" outcome should proceed to the decision "Is VOC soil contamination< 10 cubic
yards." The "Yes" outcome for this decision should proceed to the action "Remove VOC contaminated soils" before proceeding to the action "Collect confirmation soil samples."
However, the "No" outcome should proceed to the action "Discuss options with US EPA and NC DENR" before proceeding to the action "Collect confirmation soil samples." Lastly, the
"No" outcome for the decision, "Total PCBs > 10 ppm" should be placed at the bottom of the decision box rather than at the top. Please correct these oversights.
Section 4.8.1 Sitewide Waste Management
7. The response to US EPA comment #21 states that "Washwater will not be spread on the landfilled soils if they are already wet from recent precipitation." Please revise the third
bullet of the second paragraph of this section, and all other appropriate sections of the
Remedial Design Work Plan, Final (100%) Remedial Design and associated
specifications/attachments, to include the above statement.
Ms. Giezelle Bennett
February 16, 1999
Pagc4
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FINAL (100%) REMEDIAL DESIGN FOR SOIL AT THE GENERAL ELECTRIC SUBSITE
List of Figures
8. The title for Figure 7 .1 should be given as "Schedule for soil remedial action at GE
Subsite." Furthermore, the title for Figure 7.2 should be given as "Detailed cap construction
schedule." Please correct these oversights.
Section 1.2 Site History
9. The last paragraph of this section is incorrect. The original September 1995 Record of
Decision (ROD) prescribed a multi-layer cap remedy for Landfill A, Landfill B and the DSI.
The September 1995 ROD was modified by the September 1998 Explanation of Significant
Difference (ESD) to include the excavation of Landfill A and Landfill B, the disposal of such
wastes into the DSI, and the installation of a multi-layer cap over the DSI. Please correct
these oversights.
Section 1.4 Report Organization
10. The fifth sentence of the second paragraph of this section should be revised to state that
"Section 6 summarizes the Operation and Maintenance (O&M) Plan, which is included as
Attachment 5." Please correct this oversight.
Section 1.5.3 Dry Sludge lmpoundment
1 I. The response to US EPA comment #47 states that the cap design has been modified to
address the two areas of PCB contamination that lie to the west of the DSI. However,
Section 1.5.3 has not been modified. Please revise the first two sentences of the third
paragraph of Section 1.5.3 to state that "The cap to be installed at the DSI covers the entire
unit with the exception of a small area in the northwest corner and two areas along the
western perimeter of the fence and adjacent to Landfill A. These areas will be remediated
by excavation." Furthermore, please revise the fourth sentence of the third paragraph of this
section to include the appropriate estimate of soil to be removed, based upon the excavation
of these three areas.
Section 4.2 Disposal of Excavated Material
12. The first sentence of this section should reference Section 4.8.2 of the Remedial Design
Work Plan. Lastly, the last sentence of this section states that a description of the disposal
of spent cleaning fluids is provided "above." However, this description was inadvertently
omitted. Please correct these oversights.
Ms. Giezelle Bennett
February 16, 1999
Page 5
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13. The response to US EPA comment #73 indicates that Section 4.2 was revised to include the disposal of organics from cleaning and grubbing operations into the DSI. However, this information was inadvertently omitted. Please correct this oversight.
Section 5.4 Drainage Layer
14. In accordance with the response to US EPA comment #69, please delete all references to the
Preliminary (30%) Remedial Design Report in this section.
Section 5.7.2 Slope Stability
15. The fourth sentence of this section should be revised to state that "The sideslopes are
moderately steep, however, the project drawings specify a maxirrium slope of 4 to I, or 25 % . " Please correct this oversight.
Section 6 Operation and Maintenance
16. The fourth sentence of the second paragraph of this section is incomplete. Please correct this
oversight.
Section 7 .2 Estimation of Project Cost
17. In accordance with Table 7.1, the last sentence of this section should state that "The total cost
estimate of $1,191,604 reflects a cost within ±15% of the anticipated actual cost." Please
correct this oversight.
ATTACHMENT 1 CONSTRUCTION SPECIFICATIONS FOR SOILS REMEDIAL
ACTION AT GE SUBSITE
Section 02776 Geosynthetic Materials
18. Please revise Paragraph 3.1.B.3(c) of this Section to state that "Geomembrane placement
shall not proceed at a sheet temperature below 0 degrees Celsius (32 degrees Fahrenheit) or
above 50 degrees Celsius (I 22 degrees Fahrenheit)."
Section 03300 Cast-In-Place Concrete
19. Paragraph 2.1.F of this Section should state "Geotextile: See Section 02776, Part 2.3." Furthermore, Paragraph 3.2.H of this Section should state that "A geotextile pipe wrap, as
described in Part 2.3 of Section 02776, shall be placed around gas vent pipes prior to
placement of concrete, as shown on the plans." Please correct these oversights.
Ms. Giezelle Bennett
February 16, I 999
Page6
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ATTACHMENT 3 CONSTRUCTION HEALTH AND SAFETY/CONTINGENCY PLAN
20. Figure I.I, Figure 2.1, Figure 5.1, Figure I I.I and Figure 12.l were inadvertently omitted.
Please correct these oversights.
Section 10.1 Introduction
21. The fifth sentence of the second paragraph of this section should state that "Only Section
10.8 below will generally be applicable to the RA work." Please correct this oversight.
Section 10.4 Pre-Entry Procedures
22. The second sentence of this section should state that "These steps, along with the
atmospheric requirements in Section 10.6, represent acceptable entry conditions." Please correct this oversight.
Section 11.3.1 Prevention
23. The seventh bullet of this section should state that "Portable fue extinguishers will be
available throughout the RA work area as describe in Section 10.S." Please correct this
oversight.
Appendix B Heat Stress Prevention Program
24. The page numbers for the text portion of this appendix should be in Arabic numerals rather
than Roman numerals. Please correct this oversight.
25. The titles for all of the headings in Section 2.3 should be in bold font. Please correct this
oversight.
ATTACHMENT 4 CONSTRUCTION QUALITY ASSURANCE PLAN
Section 1.3.4 Quality Assurance Team
26. The corrections to Section 1.3.4 are handwritten. Please type the corrections. Furthermore,
the third sentence of this section should state that "This individual will be NICET Level IV certified." Please correct these oversights.
Ms. Giczellc Bennett
February 16, I 999
Page 7
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Section 4.1 Common Fill Grading
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27. The response to US EPA comment #41 states that since the testing frequency and acceptance
criteria are referenced to the appropriate sections of the Specifications and the Construction
Quality Assurance Plan is located in the same binder as the Specifications, it should not be
necessary to repeat this information. However, the information provided in the first item of
Section 4.1.1 and the first item of Section 4.1.2 is inconsistent with the Specifications.
Please revise the two items given above to either provide the information as provided in the
Specifications or simply reference the app_ropriate sections of the Specifications.
Additionally, the third item of Section 4.1.2 should state that "The grading layer will be
measured to plus or minus three inches measured across any 100-foot section." Please
correct this oversight.
Section 4.2 Structural Fill Grading
28. The response to US EPA comment #41 states that since the testing frequency and acceptance
criteria are referenced to the appropriate sections of the Specifications and the Construction
Quality Assurance Plan is located in the same binder as the Specifications, it should not be
necessary to repeat this information. However, the information provided in the first item of
Section 4.2. l and the first item of Section 4.2.2 is inconsistent with the Specifications.
Please revise the two items given above to either provide the information as provided in the
Specifications or simply reference the appropriate sections of the Specifications.
Additionally, the third item of Section 4.2.2 should state that "The grading layer will be
measured to plus or minus two inches measured across any 100-foot section." Please correct
this oversight.
Section 4.3 Barrier Soil Layer
29. The response to US EPA comment #41 states that since the testing frequency and acceptance
criteria are referenced to the appropriate sections of the Specifications and the Construction
Quality Assurance Plan is located in the same binder as the Specifications, it should not be
necessary to repeat this information. However, the information provided in Section 4.3.1 and
Section 4.3.2 is inconsistent with the Specifications. Please revise the two Sections to either
provide the information as provided in the Specifications or simply reference the appropriate
sections of the Specifications. Additionally, the thirteenth item of Section 4.3.2 should state
that ''The final clay layer will be measured to plus or minus two inches measured across any
100-foot section." Please correct this oversight.
Ms. Giczelle Bennett
February 16, I 999
Page 8
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Section 4.5.2 Construction
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30. Please revise the first sentence of Item 8 of this section to state that "Geomembrane
placement shall not proceed at a sheet temperature below O degrees Celsius (32 degrees
Fahrenheit) or above 50 degrees Celsius (122 degrees Fahrenheit)."
ATTACHMENT 6 DESIGN CALCULATIONS
Slope Stability Calculations
31. The first sentence of Section B of these calculations should state that "the side slope for the
fill area is proposed to be 4:1 (25%) or 14 degrees." Please correct this oversight.
ATTACHMENT 7 PREFINAL DESIGN CONSTRUCTION DRAWINGS
32. The response to US EPA comment #85 stated that the drawing had been revised as requested.
However, the Final Design Construction Drawings do not include drawings of necessary
items such as the site layout, temporary buildings, job trailers, decontamination facilities, etc.
The design drawings must detail all components for the excavation of the Landfill A and
Landfill B and all components for the construction of the landfill cover, including ancillary
items. Please correct these oversights.
Drawing No. 1 Site Plan Existing Features
33. Drawing No. 1 indicates the approximate locations of four wetlands. The PreFinal (90%)
Remedial Design Report indicated that the southern tip of Landfill B lies in a wetland.
However, this submittal indicates that the wetland lies approximately 12 feet from the tip of
Landfill B. Please provide justification for this delineation of the wetland considering that
the previous correspondence has indicated that the wetlands had not been delineated as of
yet. Please provide the details of the exact locations of Landfill B and the wetlands. If the
wetlands have not been delineated as of yet, please clarify if the contractor is required to
complete this task and provide a schedule for implementation.
Drawing No. 3 Landfill A Excavation and On-Site Disposal Plan
34. The response to US EPA comment #47 states that the cap design has been modified to
address the two areas of PCB contamination that lie to the west of the OSI. However,
Drawing No. 3 has not been modified. Please revise Drawing No. 3 to include the
excavation of the two small areas along the western perimeter of the fence and adjacent to
Landfill A.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
4WD-NSMB
Mr. Michael Bush
GE Lighting Systems
3010 Spartanburg Hwy
Hendersonville, NC 28793
SUBJ: GE/Shepherd Farm NPL Site
East Flat Rock, NC
Dear Mr. Bush:
October 8, 1997
RECEIVED
OCT 141997
SUPERFUND SECTIO~'
The Final Remedial Action Work Plan for the Shepherd Farm soil removal dated
September 1997 has been reviewed. The.Work Plan is hereby approved. However, many
discrepancies still remain in the document as identified by the attached comments from NC
DEHNR. For future documents, please make sure that the level of quality assurance and
quality control is such that these types of comments will not have to be made on a "final"
document.
If you have any questions, or would like to discuss this matter further, please give
me a call at 404/562-8824.
cc: David Mattison, NC DEHNR V
Iezelle S. Bennett
Remedial Project Manager
L
NC SUPERFUND SECTIOtl Fax:[phone]
,Stole of North Coro/in.
Department of Environment,
Health, and Natural Resources
Division of Wmfo Managemant
Jomes B. Hunt, Jr., G9vernor
Wnyne McDevill. Secretary
William L. Meyer, Dir~ctor
... ----. ---------------
October 6, I 997
Ms. Gie~lle Dennett
Remedial Project Manag~
Superfund Branch j
Waste Management Div~ion
US EPA Region IV
61 l'orsyth Street, 11 1h Floor
Atlanta, Georaia 30303 •
•"""' ________ , ___ . ----------··-----. . .
RE; Fiual Remedial A~tion Work Plan
Shepherd Fann Surficial Soil Removal
General Electric/~bepberd Farm NPL Site
East Flat Rock, H~nderson County
l>ear Ms. Bennett:
. . I
The Final Remedial Action Work Plan forJhe Shepherd Fann Surfi¢ial Soil Removal was received
by tht: Supcrfwu.l &:\;t.ioa~ftlu: Nu1tli Carqliua Depa1tu1cnt ofEnvirooment and Natural.Resources
(NC DENR) on Septembet 24, 1997. TheSuperfund Section has reviewed this document and offers
the following attached co111lllents.
We.appreciate.the opportupity to (\Omment on this:document. :If you have any questions, please feel
free to call me at [phone], extension 349. • . -
Attachment
Sincerely,
:{JJZJI/J/5, aPH~
David B. Mattison, CHMM
Environmental Engineer
Superfund ~ection
NC SUPERFUND SECTION Fax:[phone]
Comments
Page I
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Shepherd Farm Surfici~I Soil Removal
Final Remedial Action Work Plan
List of Flg11res
Oct 8 '97 9:02 • P.02108
1. · The title for Figure 4,2 should ·be. cited~ ''Lo¢ation of Truck Entrance to the Dzy Sludge
Impoundment. • Please corre~tihis oversight,
2. The title for Figlll'C 6.1 is,citedas."Estim~d.schedule for RA Activities at the Shepherd
Farm subsite." However •. the title as provided~nJhe.figure is given as ''Proposed Schedule
for Shepherd Fam\. Surficial SoilE.xcavation.." Plea.st: clarify this discrepancy. ·
List of Tables
3. The titles of Table f•2 and Table 2J are S\Vitched. The.title for. Table 22 should. state "Total
PCB Concentration (in mg/kg) at ~e Shepherd Farm Subsite (from NUS, 1990)." The title
for Table 2.3 shoµld state "Total PCB Con~ntration {in mg/kg) at the Shepherd Farm
Subsite (from EP 4, 1995)." Please correct this oversight
Section 1,1 Purpose and Objectives of Work Plan
!
4, The first sentence ih this section should ~tale !', , . conducted at the Shepherd Farm Subsite
in East Flat Rock,!North Carolina." ~urthermore, the location citation for Figure 1.2 should
state "GFJShephei:d Farm Superfund. Site,. Ea~t Flat Rock, N.C," Please correct these
oversights. ·
Section 2.2.1.1 Pre;vious Investigations
5, The third sentence in the .first paragraph of this section should state "Based on a quantitative
risk analysis and ,µtA.Rs, •EPA c:Slab&hc:u . , . ~. Furthc:nuore, .!he fourth sentence itl the
third paragraph o(this section should state " ... is provided in Table 2.3." Please correct
these oversights.
Section 3.2 Landscap~ Sun,ey .
6. The last sentence 04 page 23 of this.section should state ''Photographs were keyed to the base
maps and a written d~ription accompanies. each photograph," Furtherpiore, the first
senteitce on page 24 of this section should state "Based on photographs and site inspection,
an as-built landscape drawing will be created ... " Please correct these oversights.
NC SUPERFUl~D SECTION Fax :[phone]
Comments
Page 2
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Section 3.5 Community Relations
Oct 8 '97 9:03 P.O31O8
~
7. The third scntcnc.: of the first pnro.grapb of th.is s.eotion should state " ... that describes the
project and the procedures for ~location." Furthennore, de\ete the word "and" in the
seventh sentence ~fthe third paragraph of this s¢ction. This sentence should state "GE will
provide 24-honr ~ecurity during the entire reloqition penod." Please correct these oversights.
Section 4.1 Surficial SoURemoval
8. The first sentenOC\ of the third paragraph of this section sµ.tes that Figure 2.3 depicts the
staging area. Figllfe 2.3 does not <iepict the s~ing area, nor does any other figure. Pl=e
correct this discrepancy.
9. The last sentence dfthethird paragraph of this section staiesthat .. "Decontaminated water will
b;; coutained w1d iecyckd: fw usc:;in ,dust.s~lon at contaminated, actiyc constrw:tion
· areas ( e.g., DSI).'; Please wnend this sectiort~ as well as the last sentence in the second
paragraph of Section 42, to state tbat"Decontamk,ate<I water will be contained and recycled
for use in dust suppression at the DSr only."
10. The last sentenceiofthe fifth pa!)lgl'aph of this.section should. Sf.ale "Contaminated soils
placed in clean areas will be placed on and covered with 30-mil plastw sheeting." Please
correct this oversight. 1 ·
Section 4.2 Soil Dispo~al
1 I. The first paragrap)l of.this sectj.on should co~letely reflect tlle.~sponse to comment #13
given in the Seple~ l 0, 1997 ~rise to.ColI\Illeilu; on theD,niI\ Rl;medial Action Work
Plan. Items to be included .in this paragraph shoµ41 include, but are not limited to, geotcxtile
placement, no daily· cove1 requirements, .soil plaoement, soil compaction, compaction
rcquirem~nts, moisture requirements, oompo.ctiqn/moisture testing requirements, etc. Please
correct this oversight.
Figure 4.1
12. The title of Figure 4.1 should state "Truck Route to the Dry Sludge lmpoundment" Please
correct this oversight
NC SUPERFUND SECTION
Comments
Page 3
Appendb.A
Helllth and Safety Plan
Table of Contents
I
1. Please correct the following typographi~ errors in this sectioti
P.04108
a. · Section 1.4 shouldibe.cited as being located on page A-8.
b. Se<ltion 3.3 .should state $ite Contaminant Sources and Data" Please note that this error sholtld be corr~ted on page.A-16 as well.
c. Th~ reference to "FishSa!npl~"-shouldbe deleted from Section 7.4.
List ofTable1
d. Thi~ section should be 8l1lellded to include the Air Monitoring Plan included
as pages A•53 through A·.58,
2. · Table 7.1 is incorrktly cited and Table 7.2. was inadvertently omitted. Please correct this
section to include the following citations: • · ·
7.1 Detailed Dc,scription of Tasks ................................. A-31
7 2 S•ary of Air Monitoring Requirements ........... , , .... , . . . A-57
I
Table 1.2
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Supervising Contractor's•StaO'Traimeg Summ11ry
. '
• 3. · This table. indicates; tliat. several stafi; mC111bers will be.required to have completed a medical
exam and all of th¢ staff are requ4ed to complete rcspiratot fit testing prior to conducting
work nt the GE/S~epherd. Fiirm Site, Pl-provide certification that onasitc stliff have
completed such requirements. ·
Section 2.1 Site Descriptions and Background Information·
4. The second senteiice of the third. p_lU'agraph <>f .this se<:tion. should state "This hilly,
approximately 31-a;:re subsite historkally receivjj(J waste in a 3-acre area." Please correct
tlus oversight.
Section 2.3 Scope of Work
5. The lost sentenceofthis section shouldstnte."Dctnilsofthe workore found in the Remedial
· Action Work Plan'." Please correct this oversight.
NC SUPERFUND SECTION
Comments
Page4.
1=919-733-4811
Section 3.2.1 Physical Hazards
P.05108
6. The first paragraph of.this section briefly mc:ntiom underground utilities. Please provide ·
additional information as to the llllderground U¥lity protection program to be hnplemeated.
Please include sue~ items as utility hotificatiori. utility identification and maintaining a safe
working distance. from all underground utilities.
7. The fourth paragral?h of this section.indicates that the Field Supervisor (FS) will evaluate the
potential heat stress hazards prior to b,,:ginning work..• The evaluation of potential heat s1ress
hazards must be c~mpleted prior to completion of this Health and Safety Plan. Please
complete the cval~tion of potential heat 81J'css hazards .and revise this section to reflect the
potential heat stre~ hazards as well as the appropriate control measures. ·
R. The fifth paragrarih of this section ,indic.ate~.that the. iltmospherie .tempernture will he
measured and used~ determine the appropriatework~rest regime. Please provide additional
information how tlie temperature .will be. measµred, the.frequency of measurement, where
· · the measurement~ be collected, ilocwneritation of measurements, how relative humidity
will be incorporated into the work-rest regime, etc. Additionally, the sixth paragraph of this
section indicates that the heart rate of the workers will be monitored. Plel\Se provide
additional informa~on about who will. conduct such monitoring, how will the monitoring
will be conducted, !'tc.
I
9. Th' first i;omplete sentence on page A-15 state.s that. "On sites wl!ere cold stress may beco~e
ii probl~m; HSI Otlt>Tillllll :shall follow, lhc whl:~Lr= r,uiili:lli1c::1." . PlalStl provide w.ldilioillll
information how t~ identify.if cold s~is a 'problem and what the cold stress guidelines
are.
' Section 3.3 Site Contai:ninantSources and Data
· 10. This section, includjng T.able 3.1, Section 3.3.1, Section: 3.3J, Section 3.4 and Table 3.2, is
confusing and mislf!ding. The PAlhnd pcsti~ide contamination is mentioned in Scotion
3.3.1, Section 3.3.2'and Section 3.4. However there isno indication as to the actual levels
of contamination nbr is any indi::ation provided as to the imnssible exposure limits and
physical/chemical propertlef. Although the P AH end pesticide contamination is recogni7ed
to be a secondary haz.ard, the Health l!lld Safety Plan should supply sufficient information
for the work to be completed in a safe manner regardless of the type .and extent of
contamination. Lil(.ewise, please provid~. additional information as to the permissible
exposure levels and:physical/cbemical properties for the metals contamination that exists in
the soil and groundwater.
NC SUPERFUND SECTION Fax:[phone]
• •
Comments
Page 5
Section 3.4 CbemkaJiHazards
Oct 8 •· 9:05 P.06108
12. The: ~cumd pai11Sfaph of this.section illdicatcs tluit a primary exposure hazard ofVOCs is
through injection.! Please clarify how VOCs llllly be injected into site personnel.
13. The second parasi-aph of this gection indit.ate--$: that J ,1-dich.lornethene is a major VOC of
concern. Howev'.er, 1,1-dichlorqethene is not listed on Table 3.1. Please clarify this
discrepancy.
· Health ancl Safety Field impicmentation ' . .
14. Please revise the ~.~~eto state "I tis anticipliled that all fieldwork activities.will begin
. in Level D peno~iil protective equipment.•·
Section 4.2 Air Moni\oring Requirements
15. The meaning of"opy detection" is,llll,clearfor vinyl chloride and PCE in the first paragraph
of this section. Please clarify the meaning of this .phrase as well as the detection limit to be
used to determine !the presence of vinyl <.:hloride and PC~. •
Table 4.1 Personal Protective Eqwpin1:ut
16. It is unclear as to t,'hY, after mentioning toxic dusts in other parts of the Health and Safety
Plan, orgnnic vapor/acid gas cartridges will be used in respirators and the uqe of HEP A filters
is not recommcn4ed, Please clarify this discrepancy in this table and in the appropriate
subsections of Section 7.
Table4.3 Monitorirtg Pn:,tocoh and Cont.,nlnant Action ~vcl&
17. · Please clarify ifa gas.chromatograph will be used in conjunction with the fll) and PID. If
not, specific chemicals cannot be identified with the proposed instrumentation. Additionally,
a concentration e~pressed as a volume ~o vohµne ratio (i.e., ppm) is meaningless; the
recommended term is "meter units." . Please clarify these tliiscrc:pancies in this table and in
the appropriate subsections of Section 7.
NC SUPERFUND SECTION .x:919-733-4811
I
Comments
Page6
Tehle 7.1 Dttailed Description of Tasks ,
'
Oct 8 •• 9:06 P.07108
I 8. Please delete the ref!:rence to "Fish:'. sampling included as the fourth item in this table.
i Section 7,2 Soil Gas Survey
19. I • : • The first sentence qf this _section fudi.cates that. all decontamination procedures will be conducred in accordtince willi the Coi:poiate Policies outlinedin Section 3. This section was inadvertently omittelf. Please clarify this.discrepancy. ·
Section 7.6 Surface Geo~bysical Sampling
20. The title of this sectipn should state \'Surface Geophysical Sampling."
; ' . Figure 7.1 · Locations ofExclllSion Zone, Qn1taininationReclnction Zone, and.Support Zone . . . \
21. Figure 7.1 indicates tJiat the staging ilrea is -nithin the exclusion zone. Is this staging area to be used for clean\ materials .or is thi~ staging area Jo be ,used for temporarily staging contaminated soils prior to their lo84jµg,.tra!:tsporlation and disposal at the dry sludge impoundment? Pleak clarify the intent of this staging area.
Table7.2 Summary of:Air Monitoring Requirements
I 22. . Table 7.2, located Ofl page A-S7,. is incorrectly,.cited .as Table 7.1. Please correct this oversight ·
NC :SUPEF<FUN!J SECTION .x:919-733-4811
Comments
Page 7
AppendixB
Construction Quality Assurance Project Plan
·Table of Contents
Oct 8 •· 9:06 P.08108
I. The title for Secµon 2, LI should-~ i:jted as _"General Electric Lighting Systems." The title for Section 4,.2.2 should be dted.ii.~ "Disposal of Excavated Soil." Please correct these oversights.
List of Figures
2. The title of Fi~ 3.1.should be cited as ~Proposed Schedule for Shepherd Farm Surficial Soll Excavation,'' Please correct this oversight
List of Tables
3. "lbe title of Table ~-1 shoiµd be cited as "Definable Features of Work." Please correct this oversight.
\
\
State of North Carol.
Department of Environment,
Health, and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
Ms. Giezelle Bennett
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 1 Ith Floor
Atlanta, Georgia 30303
October 6, 1997
RE: Final Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
Dear Ms. Bennett:
The Final Remedial Action Work Plan for the Shepherd Farm Surficial Soil Removal was received
by the Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) on September 24, 1997. 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.
Attachment
Sincerely,
fa-JiJI/Y6,aP11~
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
Comments
Page I
•
Shepherd Farm Surficial Soil Removal
Final Remedial Action Work Plan
List of Figures
•
1. The title for Figure 4.2 should be cited as "Location of Truck Entrance to the Dry Sludge
Impoundment." Please correct-this oversight.
2. The title for Figure 6.1 is cited as "Estimated schedule for RA Activities at the Shepherd
Farm subsite." However, the title as provided on pie figure is given as "Proposed Schedule
for Shepherd Farm Surficial Soil Excavation." Please clarify this discrepancy.
List of Tables
3. The titles of Table 2.2 and Table 2.3 are switched. The title for Table 2.2 should state "Total
PCB Concentration (in mg/kg) at the Shepherd Farm Subsite (from NUS, 1990)." The title
for Table 2.3 should state "Total PCB Concentration (in mg/kg) at the Shepherd Farm
Subsite (from EPA, 1995)." Please correct this oversight.
Section 1.1 Purpose and Objectives of Work Plan
4. The first sentence in this section should state " ... conducted at the Shepherd Farm Subsite
in East Flat Rock, North Carolina." Furthermore, the location citation for Figure 1.2 should
state "GE/Shepherd Farm Superfund Site, East Flat Rock, N.C." Please correct these
oversights.
Section 2.2.1.1 Previous Investigations
5. The third sentence in the first paragraph of this section should state "Based on a quantitative
risk analysis and ARARs, EPA established ... " Furthermore, the fourth sentence in the
third paragraph of this section should state " ... is provided in Table 2.3." Please correct
these oversights.
Section 3.2 Landscape Survey
6. The last sentence on page 23 of this section should state "Photographs were keyed to the base
maps and a written description accompanies each photograph." Furthermore, the first
sentence on page 24 of this section should state "Based on photographs and site inspection,
an as-built landscape drawing will be created ... " Please correct these oversights.
\
Comments
Page 2
•
Section 3.5 Community Relations
•
7. The third sentence of the first paragraph of this section should state" ... that describes the
project and the procedures for relocation." Furthermore, delete the word "and" in the
seventh sentence of the third paragraph of this section. This sentence should state "GE will
provide 24-hour security during the entire relocation period." Please correct these oversights.
Section 4.1 Surficial Soil Removal
8. The first sentence of the third paragraph of this section states that Figure 2.3 depicts the
staging area. Figure 2.3 does not depict the staging area, nor does any other figure. Please
correct this discrepancy.
9. The last sentence of the third paragraph of this section states that "Decontaminated water will
be contained and recycled for use in dust suppression at contaminated, active construction
areas ( e.g., DSI)." Please amend this section, as well as the last sentence in the second
paragraph of Section 4.2, to state that "Decontaminated water will be contained and recycled
for use in dust suppression at the DSI'only."
10. The last sentence of the fifth paragraph of this section should state "Contaminated soils
placed in clean areas will be placed on and covered with 30-mil plastic sheeting." Please
correct this oversight.
Section 4.2 Soil Disposal
11. The first paragraph of this section should completely reflect the response to comment #13
given in the September 10, 1997 Response to Comments on the Draft Remedial Action Work
Plan. Items to be included in this paragraph should include, but are not limited to, geotextile
placement, no daily· cover requirements, soil placement, soil compaction, compaction
requirements, moisture requirements, compaction/moisture testing requirements, etc. Please
correct this oversight.
Figure 4.1
12. The title of Figure 4.1 should state "Truck Route to the Dry Sludge Impoundment." Please
correct this oversight.
Comments
Page 3
Appendix A
• •
Health and Safety Plan
Table of Contents
I. Please correct the following typographical errors in this section.
List of Tables
a. Section 1.4 should be cited as being located on page A-8.
b. Section 3.3 should state "Site Contaminant Sources and Data." Please note
that this error should be corrected on page A-I 6 as well.
c. The reference to "Fish Sampling".should be deleted from Section 7.4.
d. This section should be amended to include the Air Monitoring Plan included
as pages A-53 through A-58.
2. Table 7.1 is incorrectly cited and Table 7.2 was inadvertently omitted. Please correct this
section to include the following citations.
7.1 Detailed Description of Tasks ................................. A-31
7.2 Summary of Air Monitoring Requirements ..................... A-57
Table 1.2 Supervising Contractor's Staff Training Summary
3. This table indicates that several staff members will be required to have completed a medical
exam and all of the staff are required to complete respirator fit testing prior to conducting
work at the GE/Shepherd Farm Site. Please provide certification that on-site staff have
completed such requirements. ·
Section 2.1 Site Descriptions and Background Information
4. The second sentence of the third paragraph of this section should state "This hilly,
approximately 31-acre subsite historically received waste in a 3-acre area." Please correct
this oversight.
Section 2.3 Scope of Work
5. The last sentence of this section should state "Details of the work are found in the Remedial
Action Work Plan." Please correct this oversight.
Comments
Page 4
•
Section 3.2.1 Physical Hazards
•
6. The first paragraph of this section briefly mentions underground utilities. Please provide
additional information as to the underground utility protection program to be implemented.
Please include such items as utility notification, utility identification and maintaining a safe
working distance from all underground utilities.
7. The fourth paragraph of this section indicates that the Field Supervisor (FS) will evaluate the
potential heat stress hazards prior to beginning work. The evaluation of potential heat stress
hazards must be completed prior to completion of this Health and Safety Plan. Please
complete the evaluation of potential heat stress hazards and revise this section to reflect the
potential heat stress hazards as well as the appropriate control measures.
8. The fifth paragraph of this section indicates that the atmospheric temperature will be
measured and used to determine the appropriate work-rest regime. Please provide additional
information how the temperature will be measured, the frequency of measurement, where
the measurement will be collected, documentation of measurements, how relative humidity
will be incorporated into the work-rest regime, et~. Additionally, the sixth paragraph of this
section indicates that the heart rate of the workers will be monitored. Please provide
additional information about who will conduct such monitoring, how will the monitoring
will be conducted, etc.
9. Thi first complete sentence on page A-15 states that "On sites where cold stress may become
a problem, HSI Geo Trans shall follow the cold stress guidelines." Please provide additional
information how to identify if cold stress is a problem and what the cold stress guidelines
are.
Section 3.3 Site Contaminant Sources and Data
10. This section, including Table 3.1, Section 3.3.1, Section 3.3.2, Section 3.4 and Table 3.2, is
confusing and misleading. The P AH and pesticide contamination is mentioned in Section
3.3.1, Section 3.3.2 and Section 3.4. However there is· no indication as to the actual levels
of contamination nor is any indication provided as to the permissible exposure limits and
physical/chemical properties. Although the P AH and pesticide contamination is recognized
to be a secondary hazard, the Health and Safety Plan should supply sufficient information
for the work to be completed in a safe manner regardless of the type and extent of
contamination. Likewise, please provide additional information as to the permissible
exposure levels and physical/chemical properties for the metals contamination that exists in
the soil and groundwater.
Comments
Page 5
•
Section 3.4 Chemical Hazards
•
12. The second paragraph of this section indicates that a primary exposure hazard of VOCs is
through injection. Please clarify how VOCs may be injected into site personnel.
13. The second paragraph of this section indicates that 1,1-dichloroethene is a major VOC of
concern. However, 1,1-dichloroethene is not listed on Table 3.1. Please clarify this
discrepancy.
Section 4 Health and Safety Field Implementation
14. Please revise the first sentence to state "It is anticipated that all fieldwork activities will begin
in Level D personal protective equipment."
Section 4.2 Air Monitoring Requirements
15. The meaning of"any detection" is unclear for vinyl chloride and PCE in the first paragraph
of this section. Please clarify the meaning of this phrase as well as the detection limit to be
used to determine the presence of vinyl chloride and PCE.
Table 4.1 Personal Protective Equipment
16. It is unclear as to why, after mentioning toxic dusts in other parts of the Health and Safety
Plan, organic vapor/acid gas cartridges will be used in respirators and the use of HEP A filters
is not recommended. Please clarify this discrepancy in this table and in the appropriate
subsections of Section 7.
Table 4.3 Monitoring Protocols and Contaminant Action Levels
17. Please clarify ifa gas chromatograph will be used in conjunction with the FID and PID. If
not, specific chemicals cannot be identified with the proposed instrumentation. Additionally,
a concentration expressed as a volume to volume ratio (i.e., ppm) is meaningless; the
recommended term is "meter units." Please clarify these discrepancies in this table and in
the appropriate subsections of Section 7.
Comments
Page 6
Table 7.1
• •
Detailed Description of Tasks
18. Please delete the reference to "Fish" sampling included as the fourth item in this table.
Section 7.2 Soil Gas Survey
19. The first sentence of this section indicates that all decontamination procedures will be
conducted in accordance with the Corporate Policies outlined in Section 3. This section was
inadvertently omitted. Please clarify this discrepancy.
Section 7.6 Surface Geophysical Sampling
20. The title of this section should state "Surface Geophysical Sampling."
Figure 7.1 Locations of Exclusion Zone, Contamin~tion Reduction Zone, and Support Zone
21. Figure 7.1 indicates that the staging area is within the exclusion zone. Is this staging area
to be used for clean materials or is this staging area to be used for temporarily staging
contaminated soils prior to their loading, transportation and disposal at the dry sludge
impoundment? Please clarify the intent of this staging area.
Table 7.2 Summary of Air Monitoring Requirements
22. Table 7.2, located on page A-57, is incorrectly cited as Table 7.1. Please correct this
oversight.
Comments
Page 7
Appendix B
•
Construction Quality Assurance Project Plan
Table of Contents
•
I. The title for Section 2.1.1 should be cited as "General Electric Lighting Systems." The
title for Section 4.2.2 should be cited as "Disposal of Excavated Soil." Please correct these
oversights.
List of Figures
2. The title of Figure 3.1 should be cited as "Proposed Schedule for Shepherd Farm Surficial
Soil Excavation." Please correct this oversight.
List of Tables
3. The title of Table 4.1 should be cited as "Definable Features of Work." Please correct this
oversight.
State of North Carolin,
Department of Environment,
Health, and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretciry
William L. Meyer, Director
October 6, 1997
Memorandum
TO:
FROM:
RE:
Arthur Mouberry, Chief
Groundwater Section
Division ofWater Quality
David B. Mattison, CHMMff;f}
Environmental Engineer
Superfund Section
Final Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
HSI Geo Trans, on behalf of General Electric, is completing the Final Remedial Action Work Plan
for Surficial Soil Removal at the General Electric/Shepherd Farm National Priorities List (NPL) Site.
The surficial soil to be removed is located at the Shepherd Farm subsite. The document being
reviewed is attached.
Please distribute this document to the appropriate sections and submit any comments to the NC
Superfund Section. We would like-to have the views and permitting requirements of Air Quality,
Groundwater, and Water Quality Sections.
If you or your staff have any questions, please feel free to call me at [phone], extension 349.
Attachment
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Aclion Employer ~ Recycl&d / 1 °" Post-Consumer Paper
i I
' _, • State of North Carolina
Department of Environment,
Health, and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
Ms. Giezelle Bennett
Remedial Project Manager
Superfund Branch
WaSte Management Division
US EPA Region IV
6 I Forsyth Street, I I u. Floor
Atlanta, Georgia 30303
RE: Response to Comments
September 17, 1997
Draft Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
Dear Ms. Bennett:
The Response to Comments on the Draft Remedial Action Work Plan for the Shepherd Farm Surficial.
Soil Removal was received by the Superfund Section of the North Carolina Department of
Environment and Natural Resources (NC DENR) on September 11, 1997. The Superfund Section
has reviewed this document and offers the following comments.
Response to Comments -Draft Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal
Response #11
I. This response did not address that all stockpiled soils will be placed on and covered with
plastic sheeting that has a minimum thickness of thirty mils. Please clarify this discrepancy.
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone] FAX [phone]
An Equal Opportunity Affnnallve Action Employar 50% Recycled / I~ Post-Consumer Poper
" i
Ms. Giezelle Bennett
9-17-97
Page 2
Response #13
• •
2. Please revise Item E of this response to reflect that "one sample should be taken for each lift
per acre for moisture content and density."
We appreciate the opportunity to comment on this document. If you have any questions, please feel
free to call me at [phone], extension 349.
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
61 Forsyth Street, S.W.
Atlanta, Georgia 3030}-3104
August 28, 1997
4WD-NSRB
I
Mr. Michael J. Bush, Manager
E0vironmental, Health, and Safety
G,E Lighting Systems, Inc
3010 Spartanburg Highway
Hendersonville, NC 28792
I
SUBJ: GE/Shepherd Farm NPL Site
East Flat Rock, NC
Dear Mr. Bush:
. Acr~-.. ·,:::o
.SEP O 2 1997
SUPERFL.. :CT/ON
Enclosed are the Agency's comments on the draft Remedial Action Work
Plan for the Shepherd Farm Surficial Soil Removal dated August 12, 1997.
Please provide a written letter response to these comments as well as the
· fi~alized Work Plan with the comments incorporated to EPA no later than I September 19, 1997.
If you have any questions, please give me a call at 404/562-8824.
cc: David Mattison, NC DEHNR
ezelle S. Bennett
Remedial Project Manager
L
• •
Draft Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal Comments•
GENERAL COMMENT
1.
•
•
•
•
•
•
•
2.
I
This work plan only gives a brief overview of the work to be performed and lacks
sufficient detail to perform a thorough review. For example, the following types
0
1f tasks should be included in the plan:
Jverall project organization (this is only briefly discussed in Section 3.5),
site health and safety controls and layout of site-controlled zones,
Jse of a decontamination pad and equipment decontamination (this will be
r~quired before trucks and earthmoving equipment leave the site),
measures for dust control, ·
air sampling approach,
confirmation sampling approach, and
t'ransportation plan for trucks and equipment both at the Shepherd Farm subsite
and between this site and the GE plant. •
I
EPA realizes that some of the topics may be encompassed within the
appendices that are yet to be developed. However, the general approach
should be included within the work plan since it will be the governing document
used by field personnel during the removal activity. Sufficient detail included
how will prevent questions and possible downtime in the field.
I
Mr. Dickason, in his agreement with EPA, had specific requests for the removal
_ knd relocation effort. While some of these provisions are in the work plan
klready, they need to be put in the work plan verbatim as they appear in the EPA I agreement. They are:
/_ restore the Respondent's property to its original condition to the extent
practicable upon completion of their work, provided however, that such
restoration does not include the replacement of non-landscaped, ordinary
vegetation cleared for access purpose;
not materially interfere with the other ongoing uses of such property, except
to the extent required to complete the work set forth in the September 29,
1995 Record of Decision for this Site;
•
not use the sanitary and other faci_lities at such property (except as independently provided by EPA); ·-
-upon request supply data and the opportunity to take split samples from such
property without charge, and
to the extent reasonably practicable, minimize the disruptions to residents of such property to be affected by EPA's work.
SPECIFIC COMMENTS
1. Plge 4, Section 1.2.2, 2nd paragraph -In the last sentence of this paragraph,
change the word "site" to "property". Readers may improperly imply that the entire site was deleted instead of just a portion.
· 2. · Plge 9, top of page, Section 2.2 Basis of Design -The last sentence should
re~d " ... total PCBs exceed the remedial goal of 1 mg/kg at Shepherd Farm."
3.
4.
5.
6.
Plge 9, paragraph one, Section 2.2, Tables 2.2 and 2.3 -Excavation is limited
toj the top foot of soil, yet the tables show PCB exceedances at other depths.
T?is may be confusing to the reader. Either include an explanation here of why
these soils are not being removed, or only report the surficial soil results and not thk others since these are not the basis of design.
Plge 12, Figure 2.1 -The preliminary area of excavation is incorrectly depicted
on the western side. This area should account for the exceedances at sample lobations 51, 53, and 04. · · -
Pkge 14, S~ction 2.3 -The NC Superfund Section recognizes the preliminary
_ s~rficial soil sampling activities have not been completed as of the date of this
s~bmittal. However, care should be taken to ensure that the residential lots
mentioned in the first paragraph of this section concurs with the information
ptovided in Section 3.5 -Community Relations, Figure 2.3 -Extent of Soil
Rkmoval and Layout of RA Work Area, and Table 3.1 -Residents Requiring Rklocation. ·
Plge 20, 1st complete paragraph -In the first line, it states that 25 feet is the threshold for relocation. Please delete this sentence and indicate that GE with
E'PA and the State concurrence, will determine based on health and safety,
abcess requirements etc. the residents that will be temporarily relocated.
2
7.
8.
• •
Page 20, 2nd complete paragraph -Need to input the updated dates of relocation. Delete the sentence that reiers to freezer storage and reimbursement. ·
Page 21, Table 3.1 -Figure 2.2 does not indicate that samples were collected within lots 116, 201, 203, 205, and 304. Why then, does this table indicate "pending results"?
Since many of the residents requested anonymity, delete the residents' names and only include the address and reason in this table. This report will be a part of the public record.
9. Page 22, paragraph two, Section 4.1 Surficial Soil Removal -The staging area is depicted on Figure 2.3 and not Figure 2.2 as the text states.
1 0. Page 22, paragraph three, Section 4.1 Surficial Soil Removal -What will happen to the grubbed material that is not reduced to mulch? All material (i.e., trees, stumps, shrubs, and other vegetation) should be stripped of contaminated -soil, to the extent possible, prior to disposal.
11. Page 22, Section 4.1 -The issue of confirmatory soil sampling has not been addressed. Please address this issue to ensure that all contaminated surficial soils are removed.
Please clarify in this section that all stockpiled soils will be placed on and covered with plastic sheeting. that has a minimum thickness of thirty mils.
12. Page 23, 2nd paragraph -Delete the word "draft" between "final" and "work" in the third sentence.
I 13. Page 24, Section 4.2 -This section states that ''The soil material placed in the impoundment will be compacted daily in one-foot lifts." However, there is no indication as to how compaction will be accomplished, what standards will be Lsed to determine adequate compaction efforts or if field density testing will be performed to verify adequate compaction efforts. Please provide additional information to clarify these issues.
I
This section does not address the placement of interim daily cover, a temporary cover prior to the landfill cap placement, or stormwater controls. Please provide additional details.
3
• •
14. Page 24, paragraph one, Section 4.2 Soil Disposal -To the.extent practicable,
the PRPs should ensure ihat tlie mulched vegetation is not contaminated (i.e.,
total PCBs above 50 ppm) before disposing offsite at a composting facility.
15. Page 25, Figure 4.1 -This figure should be titled "Truck route and entrance to
the impoundment".
The figure should show the entire route, from the Shepherd Farm property to the
GE sludge impoundment.
16. Page 26, Section 5 Site Restoration -Please provide additional details
regarding backfilling activities. This section should describe the soil to be used
as backfill, how the soil will be placed (e.g. six inch or twelve inch lifts) and any
compaction efforts to be utilized.
The plastic sheeting to be placed in accessible crawl space areas shall be of a
minimum thickness of 30 mils. Please change this section to reflect the use of
30 mil (minimum) plastic sheeting.
17. Page 27, Section 6.2 -In addition to the items mentioned, the data to be
presented to demonstrate compliance with the performance standards should
include confirmatory sampling locations, confirmatory sampling results and as-
built drawings that provide pre-excavation elevations, post-excavation elevations
and post-restoration elevations. The surveys should continue to be conducted
along a grid spacing of 25 fee_t.
18. Page 27, Section 6.2 -The O&M plan shall address any anticipated future
actions to ensure that a minimum of twelve inches of cover soil remains on the
·properties of the affected Spring Haven residents. Additionally, the plan should
address general O&M concerns that will affect the residents of Spring Haven.
19. The total PCB concentration numbers should be double-checked. Numerous
addition errors were found in the preliminary data sheets. As this is the basis for
removal, these additions should be correct. Please note, however, that no errors
have been found that would change the status of grid. Examples are as follows:
The total PCB concentration for surficial soils sample SF-8 should be 3,21 O
ug/kg instead of 2,940 ug/kg;
SF-118 should be 197 ug/kg instead of 205.81 ug/kg;
SF-136 should be 6,400 ug/kg instead of 66,201 ug/kg;
SF-156 should be non-detect instead of 77.3 ug/kg;
_SF-176 should be 760 ug/kg instead of 795.5 ug/kg.
4
-i
... ' • •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
4WD-NSRB
Mr. Michael J. Bush, Manager
Environmental, Health, and Safety
GE Lighting Systems, Inc
3010 Spartanburg Highway
Hendersonville, NC 28792
August 28, 1997
SUBJ: GE/Shepherd Farm NPL Site
East Flat Rock, NC
Dear Mr. Bush:
As we discussed yesterday, attached are the State's comments on the RD Work
Plan. The RD Work Plan has been approved by EPA and the Agency will not reopen
this document. However, some of the comments can be addressed in the upcoming
30% Remedial Design document.
Please prepare a letter report that states how these comments will be
considered in the 30% RD report. If you have any questions, please give me a call at
404/562-8824. .
Sincere! ~
Gie e S. Bennett
Remedial Project Manager
cc: David Mattison, NC DEHNR
• State of North Carolina
Department of Environment,
Health, and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
August 26, 1997 DEHNR
Ms. Giezelle Bennett
Superfund Branch, Waste Management Division
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
RE: Draft Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County
Dear Ms. Bennett:
The Draft Remedial Action Work Plan for the Shepherd Farm Surficial Soil Removal was received
by the Superfund Section of the North Carolina Department of Environment, Health and Natural
Resources (NC DEHNR) on August 14, 1997. Additionally, preliminary PCB laboratory analysis
results from surficial soil sampling at the Shepherd Farm subsite were received on August 12, 1997
and August 14, 1997. The Superfund Section has reviewed these documents and offers the following
comments.
Draft Remedial Action Work Plan
Shepherd Farm Surficial Soil Removal
Section 2.3 Remedial Action Approach
1. The Superfund Section recognizes that preliminary surficial soil sampling activities have not
been completed as of the date of this submittal. However, care should be taken to ensure that
the residential lots mentioned in the first paragraph of this section concurs with the
information provided in Section 3. 5 -Community Relations, Figure 2.3 -Extent of Soil
Removal and Layout of RA Work Area, and Table 3.1 -Residents Requiring Relocation.
Section 4.1 Surficial Soil Removal
2. The issue of confirmatory soil sampling has not been addressed. Please address this issue to
ensure that all contaminated surficial soils are removed.
3: Pease clarify in this section that all stockpiled soils will be placed on and covered with plastic
sheeting that has a minimum thickness of thirty mils.
P.O. Box 29603. Raleigh, North Caronna 27611-9603 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 5(1,t Recycled / 1 ()'JI, Posl-Comumer Poper
Ms. Bennett
8-26-97
Page 2
•
Section 4.2 Soil Disposal
•
4. This section states that "The soil material placed in the impoundment will be compacted daily
in one-foot lifts." However there is no indication as to how compaction will be accomplished,
what standards will be used to determine adequate compaction efforts or if field density
testing will be performed to verify adequate compaction efforts. Please provide additional
information to clarify these issues.
5. This section does not address the placement of interim daily cover, a temporary cover prior
to the landfill cap placement, or stormwater controls. Please provide additional details.
Figure 4.1 Dry Sludge Impoundment Map
6. Please denote the truck haul route on this map.
Section 5 Site Restoration
7. Please provide additional details regarding backfilling activities. This section should describe
the soil to be used as backfill, how the soil will be placed (e.g. six inch or twelve inch lifts)
and any compaction efforts to be utilized.
8. The plastic sheeting to be placed in accessible crawl space areas shall be of a minimum
thickness of30 mils. Please change this section to reflect the use of30 mil (minimum) plastic
sheeting.
Section 6.2 Reporting
9. In addition to the items mentioned, the data to be presented to demonstrate compliance with
the performance standards should include confirmatory sampling locations, confirmatory
sampling results and as-built drawings that provide pre-excavation elevations, post-excavation
elevations and post-restoration elevations. The surveys should continue to be conducted
along a grid spacing of 25 feet.
IO. The O&M plan shall address any anticipated future actions to ensure that a minimum of
twelve inches of cover soil remains on the properties of the affected Spring Haven residents.
Additionally, the plan should address general O&M concerns that will affect the residents of
Spring Haven.
Ms. Bennett
8-26-97
Page 3
•
Preliminary PCB Laboratory Analysis Results
Surficial Soil Sampling at the Shepherd Farm Subsite
August 12, 1997
•
I. The total PCB concentration for surficial soil sample SF-8 should be 3,210 micrograms per
kilogram (µg/kg) instead of 2,940 µg/kg as reported.
2. The total PCB concentration for surficial soil sample SF-118 should be 197 µg/kg instead of
205.81 µg/kg as reported.
3. The total PCB concentration for surficial soil sample SF-136 should be 6,400 µg/kg instead
of 66,201 µg/kg as reported.
4. The total PCB concentration for surficial soil sample SF-156 should be non-detect (NC)
instead of 77. 3 µg/kg as reported.
Preliminary PCB Laboratory Analysis Results
Surficial Soil Sampling at the Shepherd Farm Subsite
August 14, 1997
I. The total PCB concentration for surficial soil sample SF-176 should be 760 µg/kg instead of
795.5 µg/kg as reported.
We appreciate the opportunity to comment on this document. If you have any questions, please feel
free to call me at [phone], extension 349.
Sincerely,
JJ✓t~M~
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
August 14, 1997
4WD-NSMB
MEMORANDUM
SUBJECT: GE/Shepherd Farm NPL Site
East Flat Rock, NC
FROM:
TO:
Giezelle S. Benne
Remedial Proje
Work Plan Reviewers
David Mattison, NC DEHNR
Archie Lee, SESD
Lynn France, COM
RECEIVED
AUG 18 1997
SUPERFUND SECTIOt,'
Attached is the draft RA work plan for the surficial soil removal at the Shepherd
Farm portion of the Site. Please review it and provide any comments that you may have to
me no later than August 29, 1997. / ·
Please give me a call if you have any questions.
L
~I
+tDih A GEOTRANS
• 46050 Manekin Plaza
Suite 100
Sterling, Virginia
20166
A TETRA TECH COMPANY
August 12, 1997
Ms. Giezelle Bennett
U.S. Environmental Protection Agency
Atlanta Federal Center
100 Alabama Street, NW
Atlanta, Georgia 30303-3104
703-444-7000 FAX [phone]
RECEiVED
. AUG 14 1997
SUPERFUND SECTION
Reference: Draft Work Plan for Remedial Action at Shepherd Farm Subsite
General Electric/Shepherd Farm Superfund Site
HSI GeoTrans Project No. N048-400
Dear Ms. Bennett:
Attached please find four copies of the draft document "Remedial Action Work
Plan; Shepherd Farm Surficial Soil Removal." A copy has also been provided to
Mr. David Mattison. The plan incorporates the soil sampling results received to
date from the pre-design site characterization field investigation. Although the
sampling program is still underway, the addition of those results to the final draft
of the Work Plan is not anticipated to change the technical approach or procedures
significantly. Once all results are received a draft final work plan will be
submitted for your final approval. The draft final plan will contain all of the work
plan elements, including the Health and Safety Plan, the Construction Quality
Assurance Plan, and the Sediment and Erosion Control Plan.
GE is committed to maintaining the Remedial Action schedule and will work
closely with your office to minimize disruption of the local community. If you
have any questions prior to Todd Hagemeyer's return this week, please do not
hesitate to call me at 703-444-7000.
Sincerely,
(#J i)/! re;._).~
Peter Rich
Principal Engineer
ATTACHMENT
cc: Michael Bush, GE (w/attachment)
Todd Hagemeyer, HSI GeoTrans (w/attachment)
David Mattison, NC Waste Management Division (w/attachment)