NCD003188844_20010817_Carolina Transformer_FRBCERCLA RD_Remedial Design-Remedial Action 1993 - 2001-OCR

TRIP NOTIFICATION AND AUTHORIZATION FORM
Program: D CERCLA Site Assessment □ Brown fields
D State □ MGP
[;] NPUDOD □ Dry Cleaners
Site Name: Carolina Transformer
ID Number: NCD 003 188 844
Street Address: Int. Of Hwy 30 I and River Road
City: Fayetteville
County: Cumberland
Date(s) of Trip Trip Canceled: Trip Rescheduled (Date):
I
3 months
Reason For Trip:
D Surface Soi I
D Subsurface Soil
D Using Augers/Shovels to collect soil
D Using Little Beaver to collect soil
D Groundwater (from tap)
Proiect Team Leader
Nile Testerman
Authorized By:
(if sampling, check appropriate boxes below)
D Groundwater (hailers)
D Groundwater (pumps)
D Surface Water
D Sediment
Assistant Assistant
O[fice Use Onl~
County Health Department Official Contact: '/ /Ir
/ . Title: 1//,,
Phone Number: ( _) -:
Health Department Offl:l Contacted: Back Up Letter Required?: ' IIL lllv+ Notes:
I
'
D/.1.</b(TRIP _NOT_A urn. FRM)
Assistant
I
Yes No --
Reviwd: 01122/0/
.,
Mr. Luis Flores -RPM
U.S. EPA -Region IV
•
Sam Nunn Atlanta Federal Center
61 Forsythe Street, S. W.
Roy F. Weston, Inc.
1 fi2S Pumphrey Avenue
Auburn, Alabama Jh8]2-4]W
]]4-82h-0100 • Fax :U4-82ti-82]2
® www .rfweston.com _
•
~~:/: : :~i' ~
'
SUP[RFUND SECTION
17 August 200 I
Atlanta, Georgia 30303 Work Order No. 20064-119-l 00
Re: Recent Site Issues: Dewatering and Elevated PCB levels
Carolina Transformer Superfund Site
Fayetteville, North Carolina
U.S. EPA Contract No. 68-W7-0026
Work Assignment No. 019-RARA-04C2
Document Control No. RFWl l 9-3A-AIXU
Dear Mr. Flores:
This letter is being sent to provide an update regarding the water treatment issues and
at-the-water table PCB concentrations that we have been discussing via email and telephone
conversations over the last month. As you are aware, the site has received a significant amount
of rainfall during the summer. Although Terra Kleen has been responsive in attempting to limit
surface water collecting on non-excavated areas, there has still been a sizeable volume that has
ponded on various locations around the site.
Our discussions thus far have addressed the fact that because the water is in contact with
contaminated soil, it must be treated prior to pumping it to a different location on the site. If the
water is pumped offsite, it must meet very stringent water quality requirements and would also
require state permitting due to the volume that would be discharged. As a result, the workable
option to date involves filtering the water to achieve PCB concentrations of< 0.5 µg/L (ppb) and
then pumping the filtered water to a location on the site that is below most of the grids yet to be
excavated. This is only a temporary solution for some of the surface water. Depending on the
amount of rainfall that is received over the next three months, additional thought may be needed
to find a long term solution.
The larger problem that currently faces activities at the site involves excavating below the water
table. To date, Terra Kleen has not had to deal with this issue to the extent they are facing in the
"offsite" grids. As we have discussed, several of the grids on the extreme southwest end of the
site and the northern end of the "offsite" grids have been excavated well below the base volume
depth and have intercepted the water table. The "offsite" grid concentrations at approximately
four feet down range from 3.1 to 20 mg/kg (ppm). These grids are also covered to an average
depth of nine inches by accumulated storm and ground water.
K:1200(,,l\i 19\ALETTERSILF072MJ I .DOC
Mr. Luis Flores -RPM
U.S. EPA -Region IV
•
-2-
•
17 August 2001
In an effort to determine how much deeper the grids would need to be excavated in order to be
below goal, WESTON collected grab samples from each of the affected grids. The results of this
preliminary sampling may be reviewed in the memorandum from Mr. Badey that is included as
Attachment A. As can be seen, the screening results indicated contamination beneath the water
table. All but one of the grids were still significantly above the cleanup criteria for PCBs even at
the 18 inch screening depth. This would bring the grid area excavated depth to a minimum of six
feet in most of the grids and would require excavating in excess of two feet below the current
water table. Although it is possible that the water table may recede somewhat by late fall,
historical data indicates that excavation below the water table would still be required at that later
date as well.
Based on this information, it would appear that two options are available. The first option is
based on the assumption that the current soil remediation goals apply to all soil depths. This
option would require designing and implementing a full-scale pump and treat system for
dewatering the "offsite" grids, obtaining a NPDES permit to discharge the treated water,
excavating the soil, treating the soil using the existing Terra Kleen solvent extraction system, and
backfilling the area with the clean soil.
The second option would involve only treating the surface water in the grids (i.e. pump and treat
the discharge) and then immediate backfill of the grids. This option is based on the assumption
that the deeper soils (e.g. below four feet bgs) need not be remediated to the same level as
surface soils. It would include bringing in clay fill material to act as a soil cap as well as water
storage and treatment equipment. This option would also require a decision about changing the
site cleanup goals. Higher remediation goals for deeper soils are justified since the potential for
exposure to PCBs in deep soils is much less likely. A deed restriction may be required to
prohibit future excavation activities of these deeper soils. However, even with higher
remediation goals and deed restrictions, additional excavation beneath the water table may still
be required. As shown in the attached memorandum, concentrations greater than 160 ppm have
been found in soil approximately five feet below the ground surface. Additionally, a small
amount of free product was encountered that tested as high as 20,000 ppm. This presents the
possibility of a source point contamination as well as potential for migration to currently
unaffected areas.
WESTON has conducted some initial research into the first option and believes the effort could
be completed by installing a sheet pile corridor along the length of the excavation area. This
would allow only the water within the corridor to be pumped out. A clay layer located
approximately 15 feet below the surface would restrict inflow of water into the corridor area.
This would allow for complete excavation of the contaminated soil rather than only the initial
seven grids considered in Terra Kleen's assessment and costs. It would also be possible to use
this same method to excavate smaller areas as well.
K:120064\I I 1JIALETTERSl!S07260 I .DOC
,.
Mr. Luis Flores -RPM
U, S, EPA -Region IV
•
-3-
•
17 August 200 I
Since implementing the first option would go beyond the scope-ot~work (SOW) and RA WP
guidelines, WESTON would amend our SOW with EPA to design and operate the treatment
solution to the "offsite" water problem. The proposal would include costs for design,
construction, permitting, and operation of the water treatment system as well as estimated costs
for excavation, soil treatment, and site restoration of the affected soil (excluding the base volume
already included in the existing Work Assignment).
After you have had time to review this information, we would like to schedule a conference call
between WESTON, EPA, and NCDENR representatives to discuss how to proceed. In the mean
time, we would welcome any comments or questions,
rfwi
Enclosure
cc: [NileTesterman (NCDENI§}
Brian Magee (RFW)
Jim Burton (RFW)
Keith Badey (RFW)
K:\20064\l 19\ALETTERS\LF07260 I .DOC
Very truly yours,
ROY F, WESTON, INC.
cef~i:1e~
Site Manager
, •
Date: July 26, 2001
To: Bret Missildine
Cc:
From: Keith Badey
RE: Offsite Pre-sampling Results
a) Background
•
i) To date, offsite grids 3-8 have been excavated to ground water
elevation, approximately 4.5 feet below the current surface elevation.
Post excavation floor sampling indicates that all six grids remain above
the site limit of 1 ppm PCB. In an effort to determine the extent of
contamination below the water table, Weston performed soil sampling
below the water table in all six grid locations.
b) Sampling Procedure
i) Each grid was sampled to a depth of 18 inches using a three point
composite method. Each composite sample was split into two
samples for analysis; 0"-12" (top) and 12"-18" (bottom).
c) Soil Characteristics -General
0-12"
12-18"
Brown Clay with Sand -stiff; low plasticity; moist
Sand -light brown to gray; medium density; well
graded -fine to coarse; wet; trace clay
• •
Showing Clay Layer (0-12") and Sand Layer (12-18")
d) Sample Results
i) Analysis was performed using Terra Kleens onsite Hybrizyme Unit.
Grid Number PCB in PPM
Grid 3A (0-12") <6
Grid 3B (12-18") .99
Grid 4A (0-12") 18.5
Grid 4B (12-18") 26.6
Grid 5A (0-12") >160
Grid 5B (12-18") 89
Grid 6A (0-12") 137
Grid 6B (12-18") 61
Grid 7A (0-12") 11.4
Grid 7B (12-18") 42
Grid 8A (0-12") 3.4
Grid 8B (12-18") <12
Floating Oil >320 ppm
• •
e) Observations
i) Currently there is about 7-9 inches of standing water in grids 5,6,7, and
8. Grid 3 has 12 inches of water and grid 4 has 18 inches of water.
Water in all grids have a thin oily sheen covering the surface (rainbow
effect). This oily sheen covers an estimated 30-40% of the entire area.
Grids 5 and 7 have several areas of thick oil build-up.
Oil Build-up Grid 7 ->320 ppm PCB
Water Filtration and de-watering • Subject: Water Filtration and de-watering
Date: Fri, 29 Jun 200110:01:53 -0400
From: "Missildine, Bret C." <[e-mail]>
•
To: "Luis Flores (E-mail)" <[e-mail]>,
"Nile Testerman (E-mail)" <[e-mail]>
CC: "Badey, Keith" <[e-mail]>
Luis and Nile,
I sent a letter out yesterday to TK addressing the issues with the water
management at the site. Lanny Weimer later called me and said that if that
was the final word on how to respond to the volume of water at the site
(estimated at 115,000 gallons) then TK would not be willing to do that.
Lanny 1 s position, particularly for the ash area, is that the change in site
condition of the ash material prevented them from completing the excavation
and therefore the water that now covers that ash area has become part of the
change and will require a change order to treat. Lanny indicated that to
treat the water to 0.5 ppb for discharge to another area on site would be
costly and require them to bring in another sub to do the work (Senexan
Inc.) He also noted that this issue ties in with the problem of
intercepting the water table. We currently have two grids that were above
20 ppm PCBs at depth and had to stop because of water. One of these grids
has now filled with water. I had requested that Lanny provide a price for
treating the water and until now he has not done that because he said he
didn't have a "target goal" {actually he did, however, since I had asked
him in May to price three different clean up levels}. He also stated that to
meet the offsite discharge/disposal requirements (essentially nondetect)
would not be realistic considering the volume of water. He also questioned
if there were an "acceptable" concentration of PCBs in soil that could be
established for grids that intercept the water table. He suggested that if
the level was less than 5 ppm, that the grid be backfilled thus avoiding
dewatering and the associated problems/costs.
I am at a loss on this one (short of shooting the lot of them) and would
appreciate some input and guidance. The only avenue we haven't fully
explored is actual pump and disposal at a treatment facility offsite. As
usual, the main issue for TK is the cost. They are not willing to do any of
the dewatering for 11 free 11 as part of the standing contract and don't seem to
be even considering taking a small decrease in their overall profitability
in order to deal with the problem and move the project forward. Lanny
stated that if we stood our ground on this, they would wait until the ash
area got dry (unlikely to get completely dry for a while) to excavate it and
dispose of the material.
Either way, he would like direction on intercepting the water table since
that will become a bigger issue as we move farther offsite and down the
drainage ditch.
I have a meeting now but will try to call after that.
Thanks.
Bret
Bret C. Missildine, Project Scientist
1625 Pumphrey Avenue
Auburn, Alabama 36832
1 of 2 07/03/2001 8,28 AM
FW: Drilling Schedule • •
J of 2
Subject: FW: Drilling Schedule
Date: Wed, 2 May 200114:47:31 -0500
From: "Hicks, Edward C." <[e-mail]>
To: "'Jon Bornholm / EPA'" <[e-mail]>,
"' Nile Testerman'" <[e-mail]>
Nile and Jon,
Here's the current day by day drilling schedule. I plan to be onsite for the
DNAPL investigation Wed. PM 5/9 thru Fri. AM 5/11. Of course construction
activities will be going on concurrent with the drilling. I'll forward any
changes to the schedule if any arise.
Ed
> -----Original Message-----
> From: Brent Anderson [SMTP:[e-mail]]
> Sent: Wednesday, May 02, 2001 3:07 PM
> To: Reneger, Dane; Dekker, Jan G.; Hicks, Edward C.; Slykerman, Joseph
> P. /Joe)
> Cc: Anderson, Diane ; Mulligan, Mark; Carpenter, Dale ; Fung, DiDi ;
> Wheeler, Daivd
> Subject: Drilling Schedule
>
> Ed,
>
> Per your request, the following presents WRS's anticipated drilling
> schedule:
>
> Monday 5/7/01
> meeting, setting up
> Tuesday 5/8/01
Prosonic/WRS Mobilization. Anticipate holding H&S
decon, etc.
Prosonic Advance Soil Borings for Recovery Wells
Prosonic Complete Soil Borings for Recovery Wells,
of Air Sparge Wells
> Wednesday 5/9/01
> Begin Installation
>
> Investigation
> Thursday 5/10/01
>
> Friday 5/11/01
>
>
> Monday 5/14/01
> Wednesday 5/16/01
> Thursday 5/17/01
> Wells
> Friday 5/18/01
>
> Monday 5/21/01
> Tuesday 5/22/01
> Wednesday 5/23/01
> Thursday 5/24/01
>
Mobilization of Fugro/WRS for DNAPL
Prosonic Install Air Sparge Wells
DNAPL Assessment
Prosonic Complete Air Sparge Wells
Continue DNAPL Assessment (if necessary)
Prosonic Begin Recovery Wells
Prosonic Continue Recovery Wells
Prosonic Complete Recovery Wells, Begin Monitoring
Prosonic Continue Monitoring Wells
Prosonic Complete Monitoring Wells
Prosonic Develop All Wells
Prosonic Complete Development All Wells, Prep for Demob
Prosonic/WRS Demob
> WRS may initiate development activities simultaneously with drilling
> activities in order to complete well installation by Thursday 5/23/01.
>
> Due to recent personnel changes within our Tallahassee Office Cliff
> Tompkins will not be the assigned Geologist co the project. WRS has
> dedicated Mark Mulligan, PG to the project. Mark will oversee all
> drilling operations and coordinate with Didi Fung for project reporting
> activities.
>
05/03/2001 9c38 AM
• •
Date: 01/09/01
Re: Carolina Transformer-Status for Weeks of December 11 and 18
Thirteen bins were treated in the seven-day period ending 12/19 for an average of close to 2 bins per
day. The number of cycles per bin was low, probably because the grids being treated now have very
little contamination. A few bins have been plagued by clogged geotextile that prevents them from
draining. A small number have been dumped back on the soil stockpile because of this problem.
(They were dried prior to dumping) The clogged gee may be caused by the siltier soils on the south
end of the site.
Grid 14/17 was the only one backfilled.
TK says the cold weather has not been a serious problem. The caulk seals well with warm air from the
dryer. Brittle hoses are a minor problem. No progress on burying the water line.
The main problem this week was the water treatment system. Despite the new polymer, the effluent
isn't consistently clear. Sometimes the flock floats instead of sinking. The frac tank is full so the SDU
can't run. Lanny plans to rent another new frac tank. I don't think the water treatment system is broken
to the point where it's seriously affecting operation, just problematic in that it's time consuming and
clean solvent isn't always available when the SDU can't run.
Spent carbon that was changed out last week is in two bins parked next to the front gate awaiting
disposal. Meanwhile the four bins awaiting repairs in California are still awaiting.
In people news, John Lavender (TK equipment Ops) quit. TK is currently looking at their options for a
new operator . An excavator operator will not be needed for several weeks.
Jim has been trained by Charlie to use the Hybrizyme unit.
The Ash Work Plan has been discussed further with Lanny and Mel Miller. WESTON will submit the
information and a recommendation to the EPA and State sometime the first week of January.
Mike Heaney (current site leader for WESTON) has asked to transfer to our Raleigh office. His
replacement will be Keith Badey. Keith will relocate to Fayetteville from Atlanta this week. Keith has
excellent construction and oversight experience and has worked on USACE as well as EPA oversight
projects. He also has exceptional computer skills. Mike H. will be training and conducting orientation
for Keith next week so that he will be able to transition smoothly.
• Page 1
•
Mr. Alan Cash
Terra-Kleen Response Group, Inc.
Roy F. Weston, Inc.
Suile 200
5405 Metric Place
Norcross, Georgia 30092~2550
® 7i0-263-5400 • fax [phone]
www.rfweston.corn
3970 Sorrento Valley Boulevard, Suite B
San Diego, California 92121
RE: Future Site Activities
Carolina Transformer Superfund Site
Fayetteville, North Carolina
U.S. EPA Contract No. 68-W7-0026
Work Assignment No. 019-RARA-04C2
Document Control Number RFW0 19-3A-AFHI
Dear Mr. Cash,
•
May 10, 2000
RECEIVED
NII\'< 11 2000
SUPERfUNO SEC110N
In consideration of your letters dated April 24, 2000 and May 2, 2000, and the conference call
between Roy F. Weston, Inc. (WESTON®) and Terra-Kleen (TK) on May 8 ,2000, we are
issuing this letter to you to clarify WESTON's position on the issues raised in these letters in the
hope of a successful completion of this phase of the project. Please review the letter carefully a~
this will serve as guidance for the remainder of the performance demonstration (PD).
Please understand that your observations presented in your letters have been duly noted and we
appreciate that you have recognized that some of the "treated" performance demonstration (PD)
soils have been found to be above the project remedial goals for PCB constituents. We also
understand that TK has decided to re-treat the soil that has been found to be above the remedial
goal for PCBs. The re-treatment of this soil is reportedly in progress. We hope that the re-
treatment of the soil is in keeping with the scheduled termination date of the PD. For further
definition of the PD termination date, please see ou·r response to Issue 5.
Also, be aware that on May 9, 2000, I instructed the WESTON on-site representative to collect
three composite samples according to Section 3.5 of the Statement of Work in the May 26, 1999
contract. Further, if TK does not agree in writing to the responses presented in this letter and,
provided there is a need to discuss certain items, there is no decision reached regarding the issues
by May 17, 2000, the samples will be analyzed accordingly signifying the end of the PD.
k:\20064\019\lcllers\ltddnO 14
• •
Mr. Alan Cash
May 10, 2000
I. Issue# 1 -Terra Kleen has successfully completed the Pilot Scale Demonstration Test
There is no contractual basis for this statement, based on the following specific reasons:
I. As TK notes in its letter of April 24, 2000, Section 3.5 of the Statement of Work (SOW) in
the May 26, 1999 contract specifies that WESTON will collect "three composite samples to
confirm that the treated material meets the remediation goals for PCBs, PCDD/PCDF, and
TCLP metals." This is in reference to the activities that WESTON will perform and will not
be revised or dictated by the activities that TK needs to perform to ensure successful
treatment of soil.
Section 3.5 also states that TK "may also elect to sample and analyze representative samples
of the treated soil sediment." TK's sampling approach, which is contained in TK's TSCA
permit, was outlined in TK's Remedial Action Work Plan and the appended Sampling and
Analysis Plan (SAP). TK's sampling approach involves sampling of the top six inches of the
treatment system. Our hope was that your sampling would provide TK with an indication as
to whether the soil in each bin had been successfully treated, at which time the bin could be
emptied and readied for another batch of soil. At the completion of the PD, WESTON (again
referring to Section 3.5 of the SOW) will collect and analyze the samples necessary to
determine whether the remediation goals have been achieved. If the goals are not achieved,
TK may re-treat the soil and WESTON can then repeat the sampling, continuing this process
until the remediation goals are attained (as long as this process is completed within the
allotted PD time period).
Based on the sampling results from both TK's and WESTON's laboratories, it is clear that
TK's samples from the top 6 inches of each bin do not provide representative samples of the
treated soil, and certainly do not provide a "worst case scenario" (i.e., samples of soil with
the potentially highest PCB concentrations). Sampling soil near the top of the treatment bins
appears to underestimate the extent of contamination remaining in each bin. Factors
contributing to this less effective treatment at deeper depths include:
• Soil deeper in the bin contacts solvent that contains PCBs extracted from overlying
layers, so extraction of additional PCBs is reduced.
• Fine-grained soil particles, which adsorb more PCBs on a weight basis, will tend to
migrate downward in the bin over time.
TK's TSCA permit considers treatment uncertainties at varying depths by requiring the
collection of "bottom samples from the first five batches from a new site, then at an average
of one of five bins, analyzing the bottom sample for comparison with analysis of the samples
from the top of the containers." WESTON does not have any information as to whether TK
has performed this "bottom sampling."
k:\20064\019\Jctters\ltddnO 14 2
• •
Mr. Alan Cash
May 10, 2000
TK should clearly understand that the SAP and Quality Assurance Project Plan (QAPP)
incorporated into TK's Remedial Action Work Plan describe the activities performed by TK,
not by WESTON. WESTON's confirmation sampling activities rightfully cannot be bound
by the terms of a subcontractor's work plan. To do so would compromise WESTON's
obligation to U.S. EPA to objectively and independently determine subcontractor compliance
with the project's remediation goals. Please refrain from invoicing WESTON for the PD until
WESTON' s composite samples indicate that the treated soil does not contain PCB
concentrations exceeding I milligram/kilogram.
2. Item I in Table 3-2 of the SOW in the May 26, 1999 contract specifies the performance
criteria for the soil/sediment remediation system. Item I states that the Contractor " will
excavate and treat 500 cubic yards of soil sediment to concentrations no greater than I mg/kg
for PCBs ..... ". WESTON analyzed the laboratory analysis results of two composite samples
collected by WESTON representing approximately two-thirds of the 500 cubic yards (cy) to
be treated in the PD. Both samples contained concentrations exceeding I mg/kg. These
results reflect a failure of the TK sampling strategy to detect levels of PCBs above the
remedial goal while the soil is still within the treatment bin.
3. Item I of the Price Schedule for Solids Remediation at Carolina Transformer Site in the Soil
Remediation Action SOW requires of TK "All necessary supplies, labor, and equipment to
achieve performance as described in the SOW."
II. Issue #2: There is a changed site condition
At this time, WESTON does not agree, based on your current description of the material, that
there is justification for a changed site condition. Should TK desire to pursue this matter,
WESTON requests that TK provide us with a description of the material composition of the
debris. Further, include a discussion of how this "source" material is different than what was
described in all pertinent site documentation. TK is required to remove the debris from the site,
as stated in Section 3.7.1 of the Soil Remedial Action SOW in the December I, 1998 Solicitation
Package, and as required under Item 5 of the Price Schedule. This requirement is not limited to
surface debris as TK indicates. In addition, please remember that all rubber gaskets, hoses, belts,
etc. should be regarded as TSCA-regulated waste and disposed of accordingly.
WESTON agrees that TK should screen the soil/sediment prior to treatment and, as discussed
with TK representatives on December 16, 1999, in regards to debris encountered in Grid 27, we
expect TK to remove the debris prior to treatment. When WESTON suggested that TK consider
screening soil prior to treatment earlier in the project, WESTON was told that TK' s solvent
extraction system could handle treatment of soil and debris. Based on your experiences at other
similar projects, we expected that Terra-Kleen would be knowledgeable regarding the
management of site debris.
k:\20064\019\Jettcrs\ltddn0l 4 3
• •
Mr. Alan Cash
May IO, 2000
III. Issue #3: Proposed revised confirmation sampling strategy needed to reflect the
changed site condition
WESTON has reviewed your request to collect our PD confirmation samples from the treatment
bins to minimize or eliminate the need for TK to reload bins if the soil is found to not meet the
remediation criteria. Based on our telephone conversation of Monday, May 8, 2000, WESTON is
agreeable to revising the confirmation treated soil sampling strategy for the PD as follows.
• The soil will be collected from each extraction bin by TK personnel after TK has
determined that the soil is ready for confirmation sampling.
• The collection of soil will be observed by WESTON personnel. Any soil collected without
observation by WESTON personnel will not be considered for confirmation purposes.
• The soil will be collected by TK in each bin according to the following procedure: (I)
Three soil sample locations will be centered along the long axis of each bin at 3, 8, and 13
feet from the front of the extraction bin; (2) Sample collection elevations will be at IO, 22,
and 36 inches below the soil surface in the bin; (3) The soil will be composited according to
depth collected from within the extraction bin; and (4) The composited soil will be
presented to the WESTON representative for mixing and filling of bottles.
• After mixing the soil for composite purposes, WESTON will collect a split sample from
each of the three composite samples. WESTON will ship the three primary samples to TK's
laboratory, Hybrizyme, for PCB analysis and TK will reimburse the laboratory for the
sample analysis. The analytical data will be given directly to WESTON and TK personnel
at the same time. If TK personnel receive the data before WESTON personnel, the data will
not be considered valid.
• WESTON will hold the three composite split samples for later analysis and further
compositing. After WESTON receives the data from analysis of the primary soil samples,
the determination will be made if the soil in the bin has been treated to or below remedial
goals. If not, the soil will be re-treated and WESTON will dispose of the split sample from
that bin. After re-treatment, the soil will be resampled accordingly. Once again, split
samples will be collected. This process will be repeated until the sample analysis reveals
that the soil in the bin has been treated to remedial goals for PCBs, or until the performance
demonstration has ended.
• After the sample analysis reveals that the soil within each bin is at or below the remedial
goal for PCBs, then the soil may be dumped from the bin.
• After split samples have been collected from the soil of approximately 12 bins that have
been found to be at or below the remedial goal, the soil will be composited further to form
one composite sample. WESTON expects to have three composite samples by the
completion of the treatment and sampling of 500 cubic yards required under the PD. These
k :\20064\0 t 9\letters\ltddnO 14 4
• •
Mr. Alan Cash
May 10, 2000
samples will be analyzed for PCB, PCDD/PCDF, and TCLP metal constituents.
TK would benefit from performing analysis on each sample from the bins for PCDD/PCDF and
TCLP metals constituents as required in the SOW in the May 26, 1999 contract. If the samples
reveal constituents above the remedial goal, TK will have to consider further treatment within
the allotted PD timeframe.
In the event of full-scale operation, TK and WESTON will both collect independent samples to
determine achievement of treatment goals. Due to the low frequency of sampling, WESTON's
samples will most likely be composited from stockpiles of treated soil, and will be collected on a
frequency closer to one per 1,000 cubic yards. We hope by then that TK will be better able to
gauge achievement of treatment goals prior to emptying each bin.
IV. Issue #4 -Terra Kleen requests a waiver of Contract Article 25 -ten-day time limit
condition
WESTON does not recognize a changed condition at the site. Debris was highlighted as a site
concern in the SOW and in subsequent work plans from TK.
V. Issue #5: Terra Kleen requests a 30-day delay before the start of full-scale operations
TK's request for a 30-day delay before the start of the full-scale operations is denied because TK
has not completed the performance demonstration. However, because TK has made the effort to
begin re-treatment of the soil that has been found to be above the remedial goals, TK is granted a
30-day extension to complete the PD. Therefore, the PD will be considered complete at close of
business, June 7, 2000. If the PD proves successful, TK should begin treatment of the on site
soils immediately upon approval of the performance demonstration and complete the
remediation of these soils within 218 days.
If TK decides to refuse the extension to the PD, WESTON will analyze the three composite
samples collected on May 9, 2000, as described in Section 3.5 of the SOW. The samples will be
analyzed for constituents described in Section 3.5.
We look forward to the successful completion of this project. If you have any additional
questions or require clarification, please do not hesitate to contact me at [phone] or email
at: [e-mail].
k:\20064\0l 9\letters\11ddn014 5
• •
Thank you very much for your time and consideration.
cc: Luis Flores, EPA Region JV
Nile Testerman, NCDENR
Brian Magee
Dean Geers
Larry Magill
Bret Missildine
k:\20064\0I 9\1etters\ltddn014
Sincerely,
ROY F. WESTON, Inc.
David Nelson, P.G.
WESTON Site Manager
6
Mr. Alan Cash
May 10, 2000
TERRA-KL'!EN •
"Supplying Solutions for Contaminated Soil"®
May 2, 2000
Mr. David Nelson Sent Electronically and by Certified Mail
Project Manager
Roy F. Weston
5404 Metric Place
Norcross, GA 30092-2550
RE: Response to Weston Letter Dated April 28, 2000
Confirmatory Soil Sampling Plan
Carolina Transformer Superfund Site
Fayetteville, North Carolina
U.S. EPA Contract No. 68-W?-0026
Work Assignment No. 019-RARA-04C2
Document Control Number RFWOI 9-3A-AFID
Dear Mr. Nelson:
This correspondence addresses five issues regarding the Carolina Transformer Superfund Site
project. The five issues are:
I. Terra Kleen has successfully completed the Pilot Scale Demonstration Test.
2. There is a significant changed site condition.
3. Revised confirmation sampling strategy is needed to reflect the changed site condition
4. Waiver of the ten (10) day time limit for making a claim for additional compensation
under Article 25 of the contract
5. Terra Kleen requests a 30-day delay before the start of full-scale operations.
Corporate Hetu/quarters
TERRA-KLEEN Re!>ponse Group, Inc.
3970 Sorrento Valley Boulevard, Suite B • San Diego, CA 9212 I • [phone] • Fax [phone]
lklle••ue, Washi11gto11 Ellicott City, Maryland
\ .,, • •
Issue #1 -Terra Kleen has successfully completed the Pilot Scale Demonstration Test
Terra Kleen has provided Weston three treated soil sample aliquots collected using the confirmation
sampling and analyses strategy outlined in the approved Remedial Action Work Plan (RA WP),
Quality Assurance Project Plan (QAPP), and the Sampling and Analysis Plan (SAP). Weston
accepted these confirmation samples, and sent them to a third party laboratory for analyses. Weston
has provided Terra-Kleen with results from two of the three treated soil sample aliquots. These
results confirmed that the initial two treated soil sample aliquots have a PCB concentration below
PCB target treatment level of 1.0 mg/kg. Specifically, they are 0.62 mg/kg and 0.60 mg/kg.
Terra-Kleen completed confirmation sampling on April 27, 2000 and supplied the third and final
treated soil sample aliquot to Weston on April 28, 2000. Analysis on this sample is currently
pending. Terra Kleen contends that Weston, USEPA, and NCDENR approved the confirmation
sampling and analysis strategy detailed in the Remedial Action Work Plan. Therefore, Terra-Kleen
will have successfully completed the Pilot Scale Demonstration Test once analysis of the third
treated soil sample aliquot is completed, and it is also below the target treatment level.
Since the contract between Roy F. Weston, Inc. (Weston) and Terra-Kleen Response Group, Inc.
(Terra-Kleen) per Article 3 of the Contract is a "fixed price" type, there is a performance criterion
specified to demonstrate successful performance. The contract's Appendix A Section 1.1 states,
"Statement of Work defines performance criteria as "Performance level or standards that must be
met to satisfy the requirements of this contract'"'.
Section 1.3 of the Statement of Work (SOW) requires that Terra-Kleen "Prepare Work Plan for soil
remedial action which shall include the system design and layout. The Work Plan shall include a
remedial action schedule, which meets the requirements of this Statement of Work. After submission
of the Work Plan, Terra-Kleen was to then "Revise the Work Plan to address the Project
Representative's comments. "
Section I .4 of the Statement of Work documents the responsibilities of Weston's Project
Representative. "The Project Representative will provide the following services as part of this
project: I. Approve achievement of performance criteria and remediation goals. Thus, the Project
Representative is not only responsible for approving remediation goals, but also the performance
criteria, which includes the "standards that must be met to satisfy the requirements of this
contract".
• •
Section 3.2.4 of the Statement of Work directs Terra-Kleen to prepare the following supplementary
plans: Health and Safety Plan (HASP), Quality Assurance Project Plan (QAPP) and the Stormwater,
Erosion, and Sedimentation Control Plan. Section 3.2.4.2, QAPP, requires Terra-Kleen to
"establish and implement a comprehensive quality assurance program in order to define the
reliability oft he samples collected and analyses performed under this SOW. This program shall be
documented in the QAPP." Further, Section 3.2.4.2 states that Terra-Kleen "shall describe the
procedures/or the collection and handling of soil and sediment (untreated and treated) samples.
The procedures shall be in conformance with EPA Region IV Science and Eco1,ystem Division
Environmental Investigation Standard Operating Procedures and Quality Assurance Manual
(E!SOPQAM). "
Terra-Kleen has previously submitted the Remedial Action Work Plan (RA WP) ~nd the Quality
Assurance Project Plan (QAPP) to Weston, US EPA and NCDENR, and has responded to
comments made by all parties as per Section 1.3 of the Statement of Work (SOW). As per Section
1.4 of the SOW, Weston approved this QAPP, which includes the "standards that must be met to
satisfy the requirements of this contract". Terra-Kleen then proceeded with implementation of the
contract in accordance with the QAPP standards.
Section 3.5 of the Statement of Work discusses the demonstration performance on 500 cubic yards
of soil/sediment. Within the SOW, Weston "will collect nine aliquots to compose three composite
samples lo confirm that the treated material meets the remediation goals/or PCBs, PCDDIPCDF,
and TCLP metals. The collection of nine aliquots (composited to obtain three samples for analysis)
will be repeated until the soil remediation goals are attained." As confirmation sampling is part of
the SOW, it is subject to the approved QAPP that describes "the procedures for the collection and
handling of the soil and sediment (untreated and treated) samples".
Section 5.1.1 of the approved QAPP document details the procedures for the collection and
handling of the soil and sediment for the Pilot Scale Demonstration Test. Since confirmation
sampling is part of the SOW, it has to be in accordance with the QAPP (Section 3.2.4 of the SOW).
The sampling protocol specified is very specific and is:
"Terra Kleen will use the treated soil sampling procedure outlined in Figure 5. 1-2 during the Pilot
Demonstration Test. Terra Kleen will treat approximately 36 extraction vessels of PCB contaminated
soil during the Pilot Demonstration Test. Each extraction vessel contains approximately I 5 cubic
yards a/soil.
• Treated soil samples from a group of four (4) extraction vessels will be combined to create one
"treated soil composite sample aliquot". Therefore, nine (9) "treated soil composite sample
aliquots" will be created from the 36 extraction vessels "treated soil samples".
• Treated soil samples from a group of three (3) "treated soil composite samples aliquots", will
be combined to fimn one "treated soil confirmation sample aliquot''. Therefore, three (3)
"treated soil confirmation sample aliquots" will be created from the nine (9) "treated soil
composite sample aliquots".
• •
On April 27, 2000, Terra-Kleen completed processing the last batch of soil for the Pilot Scale
Demonstration Test.
Based upon the analytical results of treated soil sample aliquots collected using the confirmation
sampling and analysis strategy detailed in the approved RA WP, subject to the results of the pending
confirmation sample, Terra Kleen contends that the Pilot Scale Demonstration Test has been
successfully completed. Therefore, Terra-Kleen has enclosed an invoice for payment of line item
01 as per the contract, to be paid under the terms of Appendix B to the contract. Terra-Kleen
understands that until all parties (including Terra-Kleen) approve a new sampling plan that Weston
may be withholding 10% of Item O I of the contract as per Appendix B to the contract.
Please note that if the three treated soil confirmation sample aliquots previously forwarded lo
Weston, for third party laboratories for analysis, meet the remedial target treatment level of I mg/kg,
then Terra-Kleen is to be paid according to the terms of the contract. Should Weston not pay Terra-
Kleen under these terms or relays to any party any doubt that payment will be made, then Terra-
Kleen will be severely damaged. As a small business, Terra-Kleen is relying on cash flow from this
project to be paid in timely fashion. Any delays or uncertainties in payment will not only thwart
Terra-Kleen's ability to perform in the future on this contract, but could force it into bankruptcy.
Issue #2: There is a changed site condition
The soil excavated for the Pilot Scale Demonstration Test contains a significant quantity of
contaminant source debris. The background documentation provided with the Request for Proposal
does not mention the presence of buried contaminant source debris. Terra Kleen has collected and
analyzed samples of the contaminant source debris, which contains 390 mg/kg PCBs. The presence
of contaminant source debris complicates soil treatment because PCBs leach from the debris and re-
contaminate treated soil. Therefore, the soil requires pretreatment (screening) to remove the
contaminant source debris to allow successful treatment of the soil to below the target treatment
levels.
Issue #3: Proposed revised confirmation sampling strategy needed to reflect the changed
site condition
The presence of contaminant source debris in the soil requires development of a revised
confirmation sampling strategy. This confirmation sampling strategy must effectively determine
contamination concentration throughout the soil matrix. Terra Kleen developed and used a multi-
level sampling strategy in the extraction vessels at its NCS Stockton project to confirm treatment of
the heterogeneous soil/clay matrix of the site.
• •
Sampling will consist of a nine point composite from each extraction vessel collected from three
locations at three elevations. Specifically, the location of the samples will be 3', 8' and 13' from the
front of the extraction vessel along the longitudinal centerline. Sample elevations will be at 6"
below soil surface (bss), 18" bss, and 30" bss.
The selection of these sample locations is based upon Terra-Kleen's determination of the area with
the lowest soil permeability, hence the lowest solvent extraction efficiency.
Issue #4 -Terra Kleen requests a waiver of Contract Article 25 •ten-daytime limit condition
Because of the changed site condition, Terra-Kleen is providing written notification to Weston
under Contract Article 25 -Changes of the Contract, that Terra-Kleen will be making a claim for
additional compensation and extension of time. In addition, due to the complexity of the change,
Terra-Kleen requests a waiver from the ten (10) day time limit referred to in the Article 25. This
will allow Terra-Kleen to fully determine and document the impact of the change and to develop
accurate pricing and performance schedule. This waiver will provide an adequate time period for
Terra-Kleen and /or Weston, USEPA, NCDENR to develop a mutually acceptable sampling plan,
while minimizing Terra-Kleen's request for additional compensation. Because of the limited time
allowed Terra-Kleen in the presentation of a claim under the contract, Terra-Kleen requests an
expedited response to its request for a waiver from the ten ( I 0) day time limit.
Issue #5: Terra Kleen requests a 30-day delay before the start of full-scale operations
Terra Kleen requests a thirty-day delay prior to initiating full-scale treatment operations. This
thirty-day period will be used to pretreat (screen) the treated soil from the Pilot Scale Demonstration
Test to remove the contaminant source debris and to conduct additional treatment to ensure that the
entire soil matrix is below the target treatment levels. This additional soil treatment activity will
generate the data required to validate the revised confirmation sampling strategy as proposed above.
The confirmation sampling strategy can then be used by all parties on an ongoing basis, providing
quality assurance that the treated soil is consistently below the target treatment level.
If you have any question or require clarification of the issues discussed above, please call me
directly at [phone].
Sincerely,
TERRA-KLEEN Response Group, Inc.
U-~~r)
Alan B. Cash ·-~
President
Attachments: Invoice and Sampling Results
, • TERRA-KLEEN •
"Supplying Solutions for Contaminated Soil"®
April 24, 2000
Mr. David Nelson
Project Manager
Roy F. Weston Inc.
5404 Metric Place
Norcross, GA 30092-2550
RE: Carolina Transformer Superfund Site
Pilot Scale Demonstration Test Results
Dear Mr. Nelson:
Terra-Kleen Response Group Inc. (Terra Kleen) is completing the Pilot Scale Demonstration Test at
the Carolina Transformer Superfund Site. This Pilot Scale Demonstration Test is being conducted
in accordance with the project Scope of Work (SOW) -Section 3.5. According to the Scope of
Work Section 3.5, the purpose of the Pilot Scale Demonstration Test is:
1) "The Contractor shall use information gleaned from the pilot test to optimize the
treatment process in terms of number of extraction steps, solvent constitution,
temperature, and other operating parameters", and
2) "to demonstrate performance".
Section 3.5 specifies that Weston will collect "three composite samples to confirm that treated
material meets the remediation goals for PCBs, PCDD/PCDF, and TCLP metals." Section 3.2.4.2
defines "the reliability of the samples collected and analyses performed under this SOW. This
program shall be documented in the Quality Assurance Project Plan (QAPP)." The Remedial
Action Work Plan (RA WP) contained the QAPP and the Sampling and Analyses Plan (SAP). The
RA WP was reviewed and approved by Weston, US EPA and NCDNR.
Terra-Kleen used both 40 CFR 761 and Terra-Kleen's nationwide commercial treatment permit
issued by US EPA's Toxic Substance Control Act (TSCA) Office to develop the sampling strategy
for the SAP. Terra Kleen's TSCA Permit requires that treated soil samples be collected from 13
points within 6 inches of the soil level in the extraction bin. This sampling strategy assumes a
"worst case" scenario to ensure that the soils in the extraction bin are below the target treatment
level. Soil in this area is considered the "worst case" as it has the least contact time with the clean
solvent. This sampling strategy has been tested and found effective by three Superfund Innovative
Technology Evaluations (SITE), TSCA permitting staff, and at four other full scale commercial
Corporate Headquarters
TERRA-KLEEN Response Group, Inc.
3970 Sorrento Valley Boulevard, Suite B • San Diego, CA 92111 • [phone] • Fax [phone]
Bellevue, Washington Ellicott City, Maryland
• •
operations of the Terra Kleen Process. This sampling strategy forms the basis for contract
compliance that Terra Kleen has successfully completed the Pilot Scale Demonstration Test.
At the Carolina Transformer Superfund Site, Terra-Kleen collected 13 point composite samples
from each extraction bin of treated soil. These composite samples were analyzed and the results
show that the soil has been treated to below the target treatment level of I mg/kg PCBs. Terra
Kleen has prepared two aliquot treated soil samples: one from first ten extraction bins of treated and
another soil sample aliquot from the following twelve extraction bins of treated soil. These first two
treated soil sample aliquots were submitted to Weston for confirmation analyses. Within 7-10 days,
Terra Kleen will submit the final treated soil sample aliquot to Weston for confirmation analyses.
Once these treated soil sample aliquots are analyzed and confirmed to be below the target treatment
level of 1 mg/kg PCBs, PCDD/PCDF, and TCLP metals limits as per the RA WP, Terra Kleen has
successfully completed the Pilot Scale Demonstration Test by treating 500 yd' of PCB contaminated
soil. Our invoice will be submitted with our final composite sample.
Recently, Terra Kleen and Weston have collected and analyzed random grab samples of soil from
the clean soil stockpile. The analytical results indicate that the clean soil stockpile located near the
treatment pad contains some soils with PCB concentrations above I mg/kg. Terra-Kleen has
reviewed operation data from the site and determined that primary reason for the elevated PCB
concentrations in the clean soil stockpile is porous debris that is causing "hot spots" in the treated
soil. Based on this information, Terra Kleen has implemented more stringent sampling and analysis
strategy to confirm that the treated soil is below the target treatment level. The more stringent
sampling and analysis strategy consists of the 13 point composite soil sample plus monitoring the
extract solution concentration to less than 20 mg/L PCBs (site specific level) before the extraction
bin of soil is considered treated to below the target treatment level. Based on performance data
analysis from other sites, this sampling and analysis strategy should ensure consistent soil treatment
performance.
Review of the Pilot Scale Demonstration Test performance data indicates that seven extraction bins
of soil were considered treated to below the target treatment level based on the 13 point composite
soil samples detailed in the RA WP. However, these extraction bins had extract solution PCB
concentrations greater than 20 mg/L. Terra-Kleen recognizes that the "hot spots" may remain in the
treated soil from these extraction bins. Therefore, Terra Kleen will re-treat this soil during full-scale
operations, free of charge, in order to ensure that the overall site remedial goals are achieved.
Terra-Kleen is committed to achieving the remedial goals established for the Carolina Transformer
Superfund Site. As we approach successful completion of the Pilot Scale Demonstration Test, we
look forward to the successful completion of this project.
Sincerely,
TERRA-KLEEN Response Group, Inc.
Alan B. Cash
President
~-~ekly Upcjate for Carolina Transformer for Weeks o.1 10 and April 17, 2000 •
Subject: Weekly Update for Carolina Transformer for Weeks of April 10 and
April 17, 2000
Date: Tue, 25 Apr 2000 10:44:51 -0400
From: "Nelson, David" <[e-mail]>
To: 'LUIS FLORES' <[e-mail]>,
'NILE TESTERMAN' <[e-mail]>,
"Magee, Brian" <[e-mail]>
CC: "Geers, Dean" <[e-mail]>,
"Missildine, Bret C." <[e-mail]>
During the week of April 10, 2000, Terra-Kleen narrowed the gap between the
amount of soil to be treated during the performance demonstration and the
amount of soil treated by completing an additional 8 bins. This brought the
total amount of bins completed to 18 and the amount of soil treated to
approximately 279 cubic yards. In an effort to potentially advance payment
to Terra-Kleen for the soil that had been treated, WESTON composite sampled
approximately 139 cubic yards of treated soil and submitted this to an
off-site laboratory for analysis of PCB, TCLP Metals, and Dioxin content.
The sample was labeled as CT-PDT-Batch2A.
Previously, during the week of April 3, 2000, WESTON had composite sampled
the soil treated to date. At the time, Terra-Kleen had completed treatment
of nine bins or approximately 140 cubic yards of soil. This sample, labeled
CT-PDT-BatchlA, had also been submitted for laboratory analysis for the
same constituents. The analytical results for the PCB and TCLP Metal
constituents for this sample were received on April 12, 2000. According to
the results, the TCLP Metals detected were not above remedial goals. The PCB
constituents in the sample were revealed at 15,000 micrograms per kilogram
or 15 milligrams per kilogram (mg/kg). WESTON notified Terra-Kleen of the
exceedance during the week of April 17, 2000.
The second composite soil sample (CT-PDT-Batch2A), collected from the
treated soil during the week of April 10, 2000, was analyzed on April 22,
2000, and preliminary results for the PCB constituents indicated PCB levels
at 5,000 micrograms per kilogram or 5 mg/kg. This sample was analyzed as a
wet weight sample and, therefore, the results are only preliminary.
Typically, the final sample analyis result will be 20 percent higher than
the wet weight sample. If this remains true, then the second composite
sample will have a final result of 6 mg/kg.
During the week of April 17, 2000, Terra-Kleen emptied four more bins of
soil that were considered treated onto plastic at the site. This brought the
total amount of soil ''treated'' to 341 cubic yards. WESTON in an effort to
obtain analytical results on the soil from these four bins analyzed a
composite sample using the on site immunoassay kit. The immunoassay results
revealed a level of 2.167 mg/kg. In an effort to calibrate the immunoassay
results versus the off site laboratory, WESTON also analyzed the soil that
was composited to form sample CT-PDT-Batch2A. The results indicated PCBs at
3.22 mg/kg.
Terra-Kleen is continuing to treat the remaining amount of soil and has
begun to reload the soil used to form sample CT-PDT-BatchlA for further
treatment. However, Terra-Kleen does not anticipate completing the
re-treatment of this before the scheduled end of the performance
demonstration on May 8, 2000. Terra-Kleen has also issued the attached
letter stating their position on the collection of soils and the analysis of
these samples.
I of 2 04/25/2000 11'34 AM
~eekly ,Update for Carolina Transformer for Weeks o.110 ond April 17, 2000 •
2 of 2
<<PerDem AC>>
I suggest-that we (all that this email was issued to) assemble on a
conference call to discuss the sample analysis results obtained so far and
decide on a course of action regarding the performance demonstration and the
potential full-scale operations at the site. I would like to have the
conference call on Thursday April 27, 2000. Please email me and let me know
if you are available on that day. After I have everyone's input, I will
finalize the date and time for the call.
Thank you for your time and consideration.
David
~PerDem AC
Name: PerDem_AC
Type: unspecified type (application/octet-stream)
Encoding: base64
Download Status: Not downloaded with message
04/25/2000 11,34 AM
•
Mr. Lanny Weimer
Roy F. Weston, Inc.
1400 Weston Way
P.O. Box 2653
West Chester, PA 19380
® 610-701-3000 • fax [phone]
www.rf..veston.com
Terra-Kleen Response Group, Inc.
3630 Comus Lane
Ellicott City, Maryland 21042
U.S. EPA Contract No. 68-W?-0026
Document Control Number RFW019-3A-ADYZ
Work Assignment No. 20064. i9.100.1071
Subject: Miscellaneous Site Issues
Carolina Transformer Site Remediation
Dear Mr. Weimer:
•
I 6-!November I 999
REC£\\/ cu
NO\! 19 1999
.,-,ot--1 "0 S'i:.C I s1J?f..RrlJ1•
During the preconstruction conference held in Fayetteville, North Carolina on October 28,
1999, Terra-Kleen raised a number of questions that Roy F. Weston, Inc. (WESTON) agreed to 'i
evaluate. Each of these issues is discussed below.
Use of On-Site Well
Terra-Kleen may use the on-site well as a water source after collecting and analyzing a sample
of the well water to confirm that the water meets North Carolina Groundwater Standards for
PCBs, metals, volatile organics, and semivolatile organics, since Terra-Kleen intends to use the
water on-site for dust suppression and decontamination. The Baker Environmental
representative stated that, according to the RI Report, the well is over 300 feet deep. However,
the RI Report indicates that the depth of the well is unknown.
Discharge of Water in Excavations
Because of the high water table conditions this Fall, Terra-Kleen inquired about the handling of
water that may be encountered in the on-property deeper excavations. WESTON contacted Mr.
Paul Rawls at the North Carolina Department of Environment and Natural Resources, Division
of Water Quality, Fayetteville Office, who stated that he was uncomfortable with a direct
discharge from the excavations to the ditch, and believes that an NPDES permit would be
required. However, he had not yet determined what the likely requirements of the permit would
be.
G:\CARTRANS\TKNov99.DOC 11116199
• •
At this point, the hope is that the water table will continue to drop during the late fall and
winter, allowing excavation with minimal influx of groJndwater. Nevertheless, WESTON will
' continue our on-going discussions with Mr. Rawls. If you would like to contact Mr. Rawls
directly, his phone number is 910-486-1541.
Change in Design of Soil Stockpile Area
Alan Cash indicated that Terra-Kleen and Garrett were 1considering leaving the concrete pad in
the proposed soil stockpile area intact until all other I soil had been remediated. Instead of
removing concrete to ground level, he suggested placi'ng a watertight coating on the surface,
constructing a berm around the area, and installing su1mps within the pad. While WESTON
I does not object to this concept, Terra-Kleen must submit to WESTON a revised drawing and
text depicting this new approach.
WESTON is also awaiting Terra-Kleen's revised project schedule, reflecting the completion of
the work plan and commencement of field activities. I If you need any further clarifications,
please feel free to contact me or David Nelson.
cc: L. Flores, EPA Region IV
E. Greyboume, EPA Region V
D. t~elson, '.VESTOl'-I
D. Geers, WESTON
N. Testerman, NCDENR
G,ICARTRANSITKNov99.DOC
Very truly yours,
ROY F. WESTON, INC.
;~'/-/;7~
Brian R. Magee, P.E.
Te1chnical Manager
11/16/99
..,,
Date:
Fax To:
Fax Number:
Fax From:
Message:
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DI. CONTACT Pl!IIIBONNEL
N;n-..e Bob Go.-N-•e.+-f Job Title lt, •. ',,.,.-f-i;k, ,.,,,✓• e,.. Tai. No. 7?o~97'f-9 3{/ ·
IV. TANK REMOVAL, CLOSURE IN PLACE, CHANG!.-IN•SEAVIC!
1. ConlaC! 10cal Fire;Marshall-6. P~ a ll<eldl looating'.p(plng, tank8 under the supervision ~ a P.E. or
2-Plan tho onu,-closure event arn! SO!l nmplfng loca!Jonl, L.G., with all clooure •~e a.scesmenl
3. Conduet Site Sell Aa$1S$m1r,t e. Submtt e gloeuM rapol'I '1n 1hQ format ,eports oeMng s;gn;aM~ and •eat 01
4. ~ removing tenks er 01()9\ng 1n place cf UST-12 and lncludet>\e loon UST-the!'.!. orL.G. U a~•• hao nol
~trlOAPI l'Lt>llcaUon201!! C/eariin~ 2 W~hln OOdlly,, follOWin!l tho $Ito oocurred, ltte &up~rvision, signature,
l'et,olsum Stor11go Tlll'lka 1t11d 1504 !nvaatlgaUon, I or seal of a P.E. or L.G. i~ rot re\l.ulreo.
Rr.lOVIII 1111d Disposal cl UsfXJ · 7, If a rele66e lrcm the tanll(ii) nae 8. Keep closure r,eords for S years.
~lgll)Und Petro/sum ~ 000\llffC, 11v, o.'Tll assessment potfun
Tanks. . of the tank clcsurt must be COlldueled '
Oe>r.tractor Name r.,.,., ~ ,. ,, H C V. W~_,K TD B~PER~ORMl!D BY ,,,,s uY-, N' ·c.
A<!tlress ,!.,[/ ? () V u-1 O • 6 7'ra ,'j 7>/lf.1 i Stat.I G ft Zip Code 3 0 / J,;J_
COntaot P~rton '3r;.~ ~;£ • Tel ~o 2?Q -9.)2/,_-,:Z 3t/
PtimC!Y Ooneuilaril /!;r;;_f n Te~ ~o. / 7 0 --.tJ 2 </ 'i.3.F L
Tonk\OII
VI. TANK(S) SCHEDULED FOR CLOSURE OR CHANBe-lN•91!ftVICE
Twil< Cepa,ny UIIII Oontonlo I Propes&d ActMty
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1 ·¾!if l&..«:&:aG q 119'~ ' ,. C7 i a c.r...,t '2ib I ...
I
· VIL OWNiR OR OWNER'S AUTMOFIIZED REPAESeNTATIVE ·
I IJl'ldtmtana 1hat I can lie neld lor emlronmamal ~ "'9ulllftg trom 1"" . dtsi,osal
111u .. ~ ot lhlo f•"" ..,.,. el~ ) . . . 1 ,mp,oper of 11'\1 USTh. Flead aoto on
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Dat>;lgntd ,$CME "'™"'1AI. DATE N0tif'/ your OWM FhglOnBi Office 48
jq;,yof•., ~q /\IO.-.,-c; houl"o bef'Or& It'll$ C!ffllo If ~QhqdlJICI~
rU'1DV81 dat'I clW'!CGS.
/S','11 ""· 8189 v WNID -01!loo Vwllow....,.y,OonR.10\tl09 .Pin<~
f •
Mr. Alan Cash
Terra-Kleen Response Group, Inc.
Roy F. Weston, Inc.
Suite 200
5405 Metric Place
Norcross, Georgia 30092-2550
® 770-263-5400 • Fax [phone]
www.rfweston.com
•
3970 Sorrento Valley Boulevard, Suite B
San Diego, California 92121
RECEIVEn
RE: Notification of Notice to Proceed
Carolina Transformer Site NOV O 8 1999
Fayetteville, Cumberland County, North Carolina -·crtO
U.S. EPA Contract No.: 68-W7-0026 SUPERFUND Sl: 1'
Work Assignment No.: 019-RARA-04C2
Document Control No.: RFW019-3A-ADWZ
Dear Mr. Cash:
November 4, 1999
Roy F. Weston, Inc. (WESTON) has received the revised Final Remedial Action Work Plan
(RAWP) (and all amendments) for the Carolina Tran~forrner Site Remedial Action project in
Fayetteville, North Carolina. The revised RA WP has been reviewed and found acceptable.
Therefore, this letter is being sent to you as official dec)aration of the Notice to Proceed with the
construction and remedial activities ,described in the statement of work and contract between
WESTON and the Terra-Kleen Response ·Group.
Prior to beginning this phase of the project, please revise the schedule that was presented in the ' Final RA WP to reflect that the construction and remediation effort will begin as of November 4,
' 1999. Please forward one final copy of the schedule to WESTON.
If you have any questions or require clarification, please do not hesitate to call me at (770) 263-
5443. Thank you for your time and consideration.
k:1200641019\letters\ltddn003.doc
Sincerely,
David D. Nelson, P.G.
Work Assignment Manager
( •
cc: Mr. Luis Flores (EPA, Region IV)
Ms. Pat Vogtman, Project Officer (EPA, Region V)
Mr. Nile Testerman (NCDENR)
Mr. Dean Geers, Program Manager (WESTON)
•
Mr. Geoff Noakes, Administrative Support Manager (WESTON)
Mr. Brian Magee, Technical Manager (WESTON)
k:1200641019\letters\ltddn003.doc
1/ •
Mr. Lanny Weimer
Terra-Kleen Response Group, Inc.
3630 Comus Lane
Ellicott City, Maryland 21042
Roy F. Weston, Inc.
·suite 200
'5405 Metric Place 1
Norcross, Georgia 30092-?SS0
770-263-5400 • Fax [phone]
www.rfweston.com
RECE/VFn
SEP 27 7999
SUPERFUNu <.lt.,v I i1.;
I
RE: Additional Comment on the July 1999 Draft
Remedial Action Work Plan
Carolina Transformer Site
WA No. 019-RARA-04C2
Contract No. 68-W7-0026
Document Control No. RFW019-2B-ADLN
Dear Lanny:
•
September 21, 1999
After reviewing the RA WP and other documents pertinent to the Carolina Transformer project, Roy F.
Weston, Inc. (WESTON) ha_s_ found th~t Terra-Kleen_ may (disregard _a portion of Comment Number 63
from the August 23, I 999 Initial Comments letter. This comment'd1scusses the samplmg of Tank 3 and 5
at the site prior to removal of the tanks .. :WESTON has found that Tank 5 has never been sampled because
I the tank was previously thought to be dry. Based on recent information, the tank has been found to
contain some type of material and will be sampled by WESTON prior to removal from the site by Terra-
Kleen during the Remedial Action. Plea,;e retain all portions;ofthe comment related to Tank 3.
If you have any questions regarding thelcomment or require,clarification, please do not hesitate to contact
me at [phone] or via email at [e-mail]. Thank you very much for your time
and consideration. · '
k:IZOOb-tlO I 9\ktters\comnmls3 do,;
Sincerely,
Roy F. Weston, Inc.
p~
David D. Nelson, P.G.
Work_Assignment Manager
• •
COMMENT ON THE JULY 1999
I DRAFT REMEDIAL ACTION WORK PLAN
SPECIFIC COMMENTS
Comment Number 1:
Carolina Transformer Superfund Site
Fhetteville, North Carolina
Page 8-10, Section 8.1.5.2.2 --TK states that "Mineral oil is not a regulated substance and the
NCDENR does not regulate minerall oil US Ts." The type of oil/fuel contained in Tank No. 4 is
not known, so it should not be assu11;ed that the liquid is mineral oil. EPA's Rl Report, Appendix
A, states that the "tank appeared to be for fuel (gasoline) storage;" however, WESTON did not
noticed a gasoline odor during the RD Data Colletion. Eight naphthalene and phenanthrene
derivatives were detected in the fluid sampled from Tank 4 during the Rl. Sample analytical
results from the RD Data Collection ( l 998) indicated estimated concentrations of fluorene and
phenanthrene in Tank 4. In any case, information from NCDENR indicates that USTs
containing mineral oil would be covered because it is derived from petroleum. Therefore, TK
needs to comply with the NCDENR UST regulations, including soil sampling around the tank,
even if the material is mineral oil.
k:\20064101911cuer.;'commnliJ doc 2
•
Mr. Luis Flores
Roy f. Weston, Inc.
1400 Weston Way
P.O. Box 2653
\Nest Chester, PA 19380
® 610-701-3000 • Fax [phone]
www.rfweston.com
•
20 September 1999
RECEIVED
U.S. EPA Region IV
OPM-14th Floor
I 00 Alabama Street
Atlanta, Georgia 30303
SEP 2 7 7999
SUPERFUND Sl:CTIQhJ
w.o. # 20064-019-100-1040
RE: Review of Soil and Groundwater Data
Carolina Transformer Soil and Building Remediation
Contract No. 68-W7-0026
Document Control No. RFW019-2C-ADKP
Dear Luis:
During a conference call on September 14, Nile Testerman of the North Carolina Department
of Environment and Natural Resources (NCDENR) raised some questions regarding organic
compounds besides PCBs that are listed in the Record of Decision (ROD) Table 9-1,
Groundwater Remediation Goals, 'for the Carolina Transformers Site. Mr. Testerman was
concerned that some compounds that could contribute to groundwater contamination would
not being tested in the treated soil.
As discussed during the conference,call, three organic compounds (bis[2-ethylhexyl]phthalate,
benzene, and 1,4-dichlorobenzene) have been found at least once at a concentration exceeding
the groundwater remedial goal listed in the ROD. The purpose of this letter is to evaluate in
more detail the presence and exten/ of each of these compounds to determine whether any or
all of them should be tested in treated soil at the Carolina Transformers Site.
As part of this evaluation, Roy F. Weston, Inc. (WESTON) reviewed all known soil and
groundwater investigations in whi,ch volatile and semivolatile compounds were analyzed.
These data were obtained from the following:
• Remedial Investigation Report, U.S. EPA, August 1990 -Included 57 soil/sediment
and 21 groundwater samples analyzed for VOCs/SVOCs and other parameters. The
groundwater samples were collected from 11 temporary (sand point) wells, 5 potable
wells north and east of the site, and 5 monitor wells.
• Post-Remedial Investigation Technical Memorandum and Draft Technical
Memorandum (Post-RI/Pre~RD), Black & Veatch (B&V), June 1993 -Included
G:ICARTRANSITCLPOrg.DOC 09/20/99
IV\·
• •
results for VOCs/SVOCs ;(and other parameters) from 18 soil and 9 groundwater
sampling locations. Wells MW-I through MW-9 were sampled.
The results for each of the compounds of interest are discussed individually below.
Bis(2-ethylhexyl)phthalate
Bis(2-ethylhexyl)phthalate (BEHP) was found in two temporary wells during the RI at
concentrations exceeding the grouridwater remedial goal of 4 ug/L. BEHP, a plasiticizer, is a
I common !aborator; contaminant; however, it does not appear that any laboratory blanks were
analyzed as part of the RI. BEHP was not found in any permanent well sampled during ihe RI
or in the Post RI/Pre-RD lnvestiga\ion. BEHP was not d.etected in any of the 75 soil samples
for which SVOCs were analyzed. During the RD Data Collection in 1998, BEHP was
detected in the fluid sample from Tank I at 260 ug/L. However, the detection has a "B"
qualifier associated with it indicating that BEHP was detected in the laboratory blank as well.
Benzene
Benzene was detected during the RI in groundwater from an on-site temporary well (near the
current location ofMW-6) at 2.8 ug/L, and from MW-4 (northeast of the site) at 80 ug/L. The
groundwater remedial goal for benzene is I ug/L. Benzene was also detected in one soil ( I 6
ug/kg) and one sediment sample, (28 ug/kg) during the RI. However, during the 1993
sampling by B&V, benzene was not detected in any of the 9 monitor wells or in any of the 18
soil samples.
1,4-Dicholorobenzene
1,4-Dichorobenzene (1,4-DCB) was detected in off-site groundwater during both the RI and
the Post-RI/Pre-RD Investigation. The highest concentration in both investigations was
detected in MW-3 -37 ug/L during the RI, and 53 ug/L during the Post-RI/Pre-RD
Investigation. This well is located approximately 350 feet northwest of the site boundary.
' 1,4-DCB was also detected in soil and sediment during the RI, but not during the Post-RI/Pre-
RD Investigation.
The ROD lists the groundwater remedial goal for 1 ,4-DCB as 1.8 ug/L, citing the MCLG as
the basis for this value. The current Federal MCL and MCLG for 1,4-DCB is 75 ug/L. The
North Carolina Groundwater Remediation Goal is also 75 ug/L. WESTON could not
' determine the basis for the goal of 1.8 ug/L listed in the ROD. Concentrations of 1,4-DCB in
groundwater from the site have never exceeded the MCL of75 ug/L.
G:ICARTRANSITCLPOrg.DOC 2 09/20/99
• •
Conclusions
BEHP has not been detected in any of the 75 soil samples collected at the site. Therefore, it
does not seem warranted to require sampling for this compound in the samples of treated soil
samples.
Benzene was detected in two soil 1and two groundwater samples during the 1990 RI, but in
neither groundwater nor soil dunng the 1993 Post-RI/Pre-RD Investigation; therefore, its
presence is difficult to determine. IEPA may wish to analyze the samples of treated soil (one
per 3,000 cubic yards) collected by WESTON for benzene. Terra-Kleen's solvent extraction
is expected to remove benzene if present, so more frequent sampling is probably not
warranted. If benzene is detected at concentrations exceeding 20 ug/kg (20 times the
groundwater remedial goal), then' a TCLP test could be commissioned to determine the
benzene concentration in the leachate, which would then be compared to the groundwater
remedial goal or some other appropriate standard.
1,4-DCB was detected in ground\\'.ater at the site. The concentrations exceeded the remedial
goal listed in the ROD, but not the current MCL, MCLG, and North Carolina Groundwater
Remediation Goal of 75 ug/L. If the ROD adopts the current MCL as the remedial goal, then
' 1,4-DCB would not be considered a groundwater concern and could be dropped as a TCLP
parameter for soil.
Please call me at [phone] or David Nelson at [phone] if you wish to discuss
these issues further.
Attachments
cc: Nile Testerman
David Nelson
Dean Geers (w/o attachment)
G: \CA RTRANS\ TCLPOrg. DOC 3
Very truly yours,
ROY F. WESTON, INC.
~ft,~--
Brian R. Magee, P.E.
Technical Leader
09/20/99
•
Roy F. Weston, Inc.
1 Weston Way
West Chester. Pennsylvania 19380-1499
610-701-3000 • Fax [phone]
•
IO December 1998
RE: Addendum No. I to Solicitation Package for Carolina Transformers Site
U.S. EPA Contract No. 68-W8-0089
Work Assignment 019-RARA-04C2
Document Control No. RFW019-3A-ABRR
W.O. #.11821-019-100-3010 I
Interested Bidders:
Enclosed is Addendum No. I to the Solicitation Package for remediation (primarily soil/sediment)
at the former Carolina Transformers Site in Fayetteville, North Carolina. The addendum contains
replacement pages for the Remedial Action Statement of Work as follows:
Section 2:
Section 3:
Page 5, Tables 2-2 and 2-3, and Figures 2-2 and 2-3
Page 9, Tables 3-3 and 3-4, and Figures 3-1 and 3-2
Please discard the previous version of these pages.
Questions can be faxed to me at ( 610) 701-3187 on or before 16 December 1998.
Attachments
cc: Luis Flores, EPA Region IV
Peggy Hendrixson, EPA Region V
David Nelson, WESTON
Dean Geers, WESTON
G:\ WP\BRIAN\Bidden.doc
Very truly yours,
Brian R. Magee, P.E.
Technical Manager
Click to WESTON On The Web http://www.rfweston.com
• • Soil Remedial Action Statement ofW0rl-.
I
I
Carolina Transfonner Site
Section: 2
Revision: l
Date: December 1998
Page: 7 of24
Tables 2-1 and 2-2 and Figure 2-2 pro+de the l 998 soil 1ampling results. The results in Table 2-
1 were obtained using immunoassay :field test kits, while the results in Table 2-2 represent
laboratory analyses conducted on a subset of the sampl+. In most areas, the vertical extent of
PCB contamination exceeding l mg/Jg has not been determined; therefore, contamination is : I estimated to extend deeper than the deepest sample collected.
I I
Sediment sampling results from 1998 kre presented in Tables 2-1 (immunoassay tests) and 2-3
(laboratory results). Additional sedim~nt characterizatioh is provided in the RI Report and the
ROD. The areas of sediment contamiJation are primarilt off-site and are shown on Figures 2-3
and 2-4. For estimating purposes, the ~ertical extent of sldiment contamination is assumed to be
from the surface to a depth of 1.5 feet. I, On-site sediment!! contamination is assumed to extend to
depths of 1.5 or 2 feet.
. I I
2,3 OVERVIEW OF CONTAINER, DEBRIS, AND STRUCTURE
CHARACTERIZATION
EPA (1989) and WESTON (1998) sampled the contents of storage tanks and transformers
remaining at the site. WESTON also ~ollected samples \of concrete, debris, and drum contents
for disposal purposes. None of these solids was determine□ to be hazardous. I
The locations of the tanks and transfonners are shown on Figure 2-2. Most of the contents of the
storage tanks and transformers were pulped out into poly holding tanks or drums in an effort to
better quantify the volume of material Jemaining. The eJtimated volumes of the various liquids
are provided in Table 2-4. None of the liquids contaiAed PCB concentrations exceeding 50
mg/L. Sampling results for the contents
1
j of storage tanks dnd transformers are provided in Tables
I 2-5 and 2-6. Tank 5 was not sampled but was observed to contain oil similar to that found in I
Tank4. ·
1
1 I This document was prepared by Roy F Weston, Inc. expressly for EPA It shall not be released or disclosed m whole or m part without the express_ written permission of EPA. :
I G·\POMMERK\WP\BRIAN\CAROLINAIRASOWDN 12/08/98
• -Table 2-2
Soil Sample Laboratory Results
Carolina Transformer
~·;•;··•:.::.i.:::::.:,.!.::.~.•.;!~.·~.:.•~.Col.::_:;:l.:.·~ .. :·_ .••... •~-:.·•···••:·f•.·~.:. :m~ ::;;::,: .:!: Z:i: ;.;:;;; ~;~J~~~H ;:~ ~~,i~, ::c ::~ ~i :~~ ;:;;:o;:
~~.:tl.:!.:w.<~:!,w-.::~-~::... ...... _: .. :::.::.::~;~_:;. -.-.Lu? "tr» 3.::-.w vY'\ :......, ::..~~:::: <<. ·x;'··\~rn::>-/< t Vwc J> _:: ."<~~n<:'/~~~~: •••r·>tL:::~..:.b-::,;,<{\lhmr:....-.Zt:~~~~mm1k_:;:~ '_::;· · ~~: f:<.i~❖:;c;· "<•~J;): f <' .. 'i 71..w-xm:
Alpha-BHC 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Beta-BHC 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Delta-BHC 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Gamma-BHC (Lindane) 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Heptachlor 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Aldrin 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Heptachlor Epode 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Endosulfan 1 (Alpha) 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.8U 9.6U 2.0U
Dieldrin 77U 120 3.5U 3.8U 4.0U 30U 70U 90U 10U 3.8U 40U 40U 3.8U
4,4'-DDE (P,P'-DDE) 77U 72U 3.5U 3.8U 4.0U 46N 38U 18U 10U 3.8U 20U 19U 3.BU
Endrin 77U 72U 3.5U 3.8U 4.0U 160U 38U 18U 10U 3.8U 18 19U 3.8U
Endosulfan II (Beta) 77UR 72UR 3.5UR 3.BU 4.0UR 3.7UR 38UR 18UR 10U 3.8U 3.4UR 19UR 3.8UR
4,4'-DDD {P,P'-DDD) 77U 72U 3.5U 3.8U 4.0U 3.7U 38U 18U 10U 3.BU 3.4U 19U 3.8U
Endosulfan Sulfate 77U 72U 3.5U 3.8U 4.0U 3.7U 38U 18U 10U 3.8U 3.4U 19U 3.8U
4,4'-DDT (P,P'-DDT) 77U 72U 3.5U 3.8U 4.0U 360U 38U 18U 10U 3.8U BOU 19U 3.8U
Methoxychlor 400U 450U 18U 19U 4.0U 30U 310U 230U 53U 20U 130U 140U 20U
Endrin Ketone 77U 72U 3.5U 3.8U 4.0U 3.7U 38U 18U 10U 3.8U 3.4U 19U 3.8U
Endrin Aldehyde 77U 72U 3.5U 3.BU 4.0U 3.7U 38U 18U 10U 3.8U 3.4U 19U 3.8U
Alpha-Chlordane /2 40U 37U 1.8U 1.9U 2.0U 1.9U 20U 9.3U 5.3U 2.0U 1.BU 9.6U 2.0U
Gamma-Chlordane /2 40U 60U 1.8U 1.9U 2.0U 20U 60U 60U 5.3U 2.0U 30U 30U 2.0U
•
:;;~gJ)dK@i%Ei%%fo \~~,~~~ ::
3
,
7
~~~.,. E;~~~~••• >;
1
:~;~;, ''~~~~t· c'~:,~~<~ <~0~-~~ .c,;.:;~ .. ~ff ·E;~;~~::; •;<~.~~.~,; .. ;;;;;;,:,~~\L ¥~;.~;~;c ;;;;;~~~~;;;;; •
PCB-1016 (Aroclor 1016) 0.77U 0.72U 0.035U 38U 0.040U 0.037U 100U 38U 0.034U 0.19U 0.038U 0.380U 0.18U
PCB-1221 (Aroclor 1221) 1.60U 1.40U 0.070U 76U 0.081U 0.074U 210U 78U 0.070U 0.38U 0.078U 0.780U 0.37U
PCB-1232 (Aroclor 1232) 0.77U 0.72U 0.035U 38U 0.040U 0.037U 100U 38U 0.034U 0.19U 0.038U 0.380U 0.18U
PCB-1242 (Aroclor 1242) 0.77U 0.72U 0.035U 38U 0.040U 0.037U 100U 38U 0.034U 0.19U 0.038U 0.380U 0.18U
PCB-1248 (Aroclor 1248) 0.77U 0.72U 0.035U 38U 0.040U 0.037U 100U 38U 0.034U 0.19U 0.038U 0.380U 0.18U
PCB-1254 (Aroclor 1254) 0.77U 0.72U 0.035U 38U 0.040U 0.037U 100U 38U 0.034U 0.19U 0.038U 0.380U 0.18U
PCB-1260 {Aroclor 1260) 3.90C 18.00C 0.21 1200 0.11 2.499CJ 6700 62 9.20C 7.40C 0.038U 33.00C 23.00C
C"" Confirmed by gems: (1) When no value is reported, see chlordane constituents; (2) Constituents or metabolrtes of technical chlordane.
N = Presumptive evidence of presence of material.
R II qc indicates that data unusable. Compound may or may not be present.
Resampling and reanalysis is necessary for verification.
U II Material was analyzed for but not detected
µg/kg II micrograms per kilogram
ft/bgs--feet below ground surface
G:\POMMERK\EXCEL'CAROLINATS-RASOW.XLS (TBL 2-2)
• • Soil Remedial Action Statement of Work
Carolina Transfom1er Site
Sec1ion: 3
Revision: I
Date: December 1998
Page·. 9 of22
The key performance criteria are summarized by work item in Table 3-2.
3.4 EXCAVATION OF CONT AMINA TED MATERIAL
The Contractor shall excavate soil and sediment in the areas and to the depths indicated on
Tables 3-3 and 3-4 and shown on Figures 3-1 and 3-2. The Contractor shall carefully excavate so
as not to contaminate deeper soil/sediment horizons. The Contractor shall treat this soil and
sediment as described in Section 3.5.
Prior to commencement of remedial activities, the Contractor shall install a 6-foot chain-link
fence around the site property with at least two secured gates. The Contractor shall also install
fencing (minimum four-foot height) to surround off-site sediment excavation areas.
-Some soil and most sediment excavation locations will first require clearing of vegetation by the
Contractor. The Contractor shall be responsible for locating and avoiding underground utilities
in excavation areas, and shall replace to existing conditions any utilities damaged during
excavation. The Contractor shall remove existing fencing, trees, and other vegetation as
l}ecessary to access areas to be excavated, and shall dispose of these materials off-site.
The Contractor shall control dispersion of airborne soil/sediment during excavation such that the
airborne dust concentration does not exceed 5 mg/m3 outside of the excavation itself. The
Contractor shall continually monitor airborne dust concentrations downwind of the excavation
and maintain a daily log of these measurements for submission to the Project Representative at
the end of each week.
This document was prepared by Roy F. Wesion, Inc .. expressly for EPA. It shall not be released or disclosed in whole or in part without the express, written pennission of EPA.
G:\POMMERK'IINP\BRIANICAROLINAIRASOWDN 12/08/98
• • Table 3-3
Estimated On-Site Contaminated Soil Volume -Carolina Transfonners Site
PCB Cone. Depth of Proposed
of Deepest Known Excavation Grid Estimated Estimated
Sample Contamination Depth Area Volume Volume
Grid No. m!!/kg inches bgs ft bgs tt' tt' yd'
1 0.16 2 0.5 4950 2475 91.7
2 0.23 2 0.5 2500 1250 46.3
3 0.22 2 0.5 2500 1250 46.3
5 0.16 2 0.5 2500 1250 46.3
8 0.18 2 0.5 2500 1250 46.3
10 0.35 2 0.5 2500 1250 46.3
12 0.29 2 0.5 1800 900 33.3
13 0.45 2 0.5 3750 1875 69.4
15 0.85 2 0.5 1000 500 18.5
16 0.56 2 0.5 4250 2125 78.7
18 0.12 2 0.5 1250 625 23.1 19 0.15 2 0.5 2500 1250 46.3
20 1.9 10 1.5 2500 3750 138.9
21 0.12 2 0.5 2500 1250 46.3
22 16 10 2 2500 5000 185.2
23 0.74 2 0.5 2750 1375 50.9
24 22 10 2 2500 5000 185.2
25 0.05 10 1.5 2500 3750 138.9
26 7.79 24 3 2500 7500 277.8
27 5.99 24 3 2500 7500 277.8
28 100 2 3 3150 9450 350.0
30 12 10 2 1500 3000 111.1 31 2.4 10 1.5 4000 6000 222.2 32 0.11 10 1.5 2500 3750 138.9
33 8.9 10 1.5 2500 3750 138.9 34 16 10 2 2500 5000 185.2 36 18 10 2 2500 5000 185.2 37 1.2 48 5 2500 12500 463.0 39 1.3 10 1.5 2500 3750 138.9 40 2.2 10 1.5 2500 3750 138.9 41 7.6 10 1.5 2500 3750 138.9 42 7.1 10 1.5 2500 3750 138.9 43 15 10 2 2500 5000 185.2 44 5.3 10 1.5 2500 3750 138.9 45 3.8 10 1.5 2500 3750 138.9
46 2.7 10 1.5 2500 3750 138.9 47 9.3 10 1.5 2500 3750 138.9 48 7.4 10 1.5 2500 3750 138.9
49 7.98 24 3 2500 7500 277.8 50 12.1 24 3 2500 7500 277.8 51 23 10 3 2500 7500 277.8 52 11 10 3 2500 7500 277.8 54 6.675 24 3 2500 7500 277.8 55 23.8 48 5 2500 12500 463.0 56 0.795 10 1.5 2500 3750 138.9 57 6 10 2 2500 5000 185.2 58 22.1 24 3 3750 11250 416.7
Soilvolu.xls 12/8198
• • Table 3-3
Estimated On-Site Contaminated Soil Volume -Carolina Transfonners Site
PCB Cone. Depth of Proposed
of Deepest Known Excavation Grid Estimated Estimated
Sample Contamination Depth Area Volume Volume
Grid No. mg/kg inches bgs ft bgs tt' tt' yd'
59 4 10 1.5 3500 5250 194.4
60 1.5 10 1.5 3500 5250 194.4
61 8.7 10 1.5 2500 3750 138.9
62 15.2 48 5 2500 12500 463.0
64 6.7 36 5 2500 12500 463.0
65 0.82 10 3 2500 7500 277.8
66 8.165 24 3 2500 7500 277.8
67 12 10 3 2500 7500 277.8
68 3.4 24 3 3750 11250 416.7
69 4.8 10 2 2100 4200 155.6
71 7.4 10 2 2500 5000 185.2
72 0.25 2 0.5 2500 1250 46.3
75 7.135 6 1.5 2500 3750 138.9
76 1.42 6 1.5 2500 3750 138.9
79 5.02 6 1.5 3000 4500 166.7
85 3.98 6 1.5 2500 3750 138.9
SW Area 1 3 3700 11100 411.1
SW Area 2 1.5 1675 2512.5 93.1
TOTAL VOLUME 133500 291525 11,301
Notes: Contamination defined as PCB concentrations exceeding 1 mg/kg.
Concentrations from duplicate samples have been averaged.
Some excavation may be limited by depth to water table.
Soilvolu.xls 12/8198
Sediment PCB Cone.
Area mg/kg
West 1 46 to 212
West2 4.8 to 4400
West3 1.54 to 2200
South 1 3.3
South 2 11
East 15
North 31
• •
Table 3-4
Estimated Sediment Excavation Volume
Carolina Transformer Site
Proposed
Excavation Estimated Estimated
Depth Area Volume Volume
ft bgs ft2 ft3 ~d3 Comments
2 27500 55000 2037 Ditch along grid, 25' x 690'
1.5 48650 72975 2703 Downstream of driveway
1.5 60700 91050 3372 Further downstream, 1 O' to 50' wide
1.5 1500 2250 83 100' X 15'
1.5 1225 1837.5 68 50' X 12' + 25' X 25'
1.5 2800 4200 156 140' X 20'
2 5000 10000 370 50' x 100'; MW-8 soil 0.43 at 0-1 ft
TOTAL VOLUME 237,313 8,789
• ~ DRAINAGE DITCH
-------
3'-6.7
• 64
054
11.25
0.01
39[2]
4'-0.062
•65
55
[2]15.4
23.0
23.7
40
66 0 8.64
7.69
056
0.05
2.91
41
WOODED AREA
GRAPHIC SCALE
60 '------
1" = 60 FEET
120
67
57
42
X
X
068
3.40
058
11.28
43 _,,--,.___
•
44
59
45 46
X -x 31
U.S.T.#4
47 48
32
0.01 33
025
x24 0.05
X
X
X
X
X I _,
X
X
71
60
"
1
"
49 ~ 5 "1
07.98
4 ~01214 "51
3
34
26
0 2.35
6.92
11
35
027
5.9 28
13
PROJECT ITTLE:
CAROLINA TRANSFORMER SITE FAYETTEVILLE, NORTH CAROLINA
1998 SOIL SAMPLING PCB RESULTS
FIGURE 2-2
I
72
62
01.53
1.12
7.43
52
37 • 4'-1.2
1.EGEND
~l81 5~c~~e~~i.i'fD1X~ftC:U~Dft~J~~s ctN~~~fe:L_ES IMMUNOASSAY SAMPLE ANAi-YSIS RESULTS {MILLIGRAMS PER KILOGRAM)
,-x -CHAIN-LINK FENCE.
r,~2°14 ~~1iJtr!}f~ ~AM~lE
2
1N
1
~(~s1§ ~~§ULTS '-1 . {MILLIGRAMS PER KILOGRAM)
62 SOIL SAMPLES AT ONE FOOT INTERVALS [Zl STARTING AT 18-24 INCHES SGS. 1.53 IMMUNOASSAY SAMPLE ANAi-YSIS RESULTS {MILLIGRAMS PER KILOGRAM)
• DEPTH AND PCE CONCENTRATION (MGLKG) 4'-1.2 LABORATORY ANALYSIS, OCTOBER ~998.
WHERE MULTIPLE ANALYSIS WERE PERFORMED, CONCENTRATION REPRESENTS AVERAGE OF RESULTS.
BASE MAP PROVIDED BY THE ROSE GROUP SURVEYORS, AUGUST 1998.
-------!----TRANSFORMERS
I
DRAWN:
M.B.S.
CHECKED:
"--GRID AS ESTABLISHED BY EPA DURING 1990 RI
"---TANKS
DATE
7/23/98
DATE: APPROVED: ATE:
W.O. NO.:
04400-073-095
CAD rJLE NAME:
-
~:tPiftgJ~":=:::7t7=<:"\t?'773JD;•;: ''777~\/ '.Htf?tE:
Alpha-BHC 200U 2. 7U
Beta-BHC
Delta-BHC
Gamma-BHC (Lindane)
Heptachlor
Aldrin
Heptachlor Epoxide
Endosulfan 1 (Alpha)
Dieldrin
4,4'-DDE (P,P'-DDE)
Endrin
Endosulfan II (Beta)
4,4'-DDD (P,P'-DDD)
Endosulfan Sulfate
4,4'-DDT (P,P'-DDT)
Methoxychlor
Endrin Ketone
Endrin Aldehyde
Alpha-Chlordane /2
Gamma-Chlordane /2
Toxa hene
200U 2.7U
200U 2.7U
200U 2.7U
200U 2.7U
200U 2.7U
200U 2.7U
200U 2.7U
1500U e.ou
400U 5.2U
.640U 5.2U
400UR 5.2UR
400U 5.2U
400U 5.2U
400U 5.2U
7000U 27U
400U 5.2U
400U 5.2U
200U 2.7U
730U 2.7U
20000U 270U
-Table 2-3
Drainage Ditch Sediment Laboratory Results
Carolina Transformer Site
39U
39U
39U
39U
39U
39U
39U
76U
76U
76U
76U
76U ~i~ J/§'.7//{/)\ 3900U
49U
49U
49U
49U
49U
49U
94U
94U
94U
94U
94U
94U
94U
490U
94U
94U
49U
49U
4900U
20U
20U
20U
20U
20U
20U
38U
38U
38U
38U
38U
38U
38U
200U
38U
38U
20U
20U
2000U
21U
21U
21U
21U
21U
21U
21U
41U
41U
41U
41U
41U
41U
41U
210U
41U
41U
21U
21U
2100U
75U
75U
75U
75U
380U
75U
75U
38U
38U
3800U
5.9U
5.9U
5.9U
5.9U
5.9U
5.9U
11U
11U
11U
11U
11U
11U
11U
59U
11U
11U
5.9U
5.9U
590U
-
5:;,:;;;~;;;;;;z xzL;;;;;~:;~ :;;;xzx; )A;:iiili.
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0
1.9U 2.4U 49U 3.0
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
19U 24U 490U 30U
3.7U 4.6U 96U 5.8U
3.7U 4.6U 96U 5.8U
1.9U 2.4U 49U 3.0U
1.9U 2.4U 49U 3.0U
190U 240U 4900U 300U
P¢.$.~fbj~A='Met/iod,~A~~jp=:~~ ::::.,:·====·==·:=<,·, ·==·==··=·==:,:::;.:· \:f\::J<J?Y \'>i.\.'//5= 'h{":",'_{\:J/i<'.L,:,:,:,= \';::'.:,\;;_:_;:;_=_: :t{)\UF? t3D5kif 'TY<<Y> ;,/l/HL:f:(f/J<i:Y· Yt'/'_)L< '.LJY\R;_·:2 22\Y•'CJ(
tcB~101iii.t;;;;i~t'ioi"ii)"" • » ms • 4Li"' ·o.052U 760U 940U 380U 410U 750U 110U 37U 46U 960U 58U 85U 100U 22U
PCB-1221 (Aroclor 1221) 8.1U 0.110U 1500U 1900U 780U 840U 1500U 230U 74U 93U 1900U 120U 85U 100U 22U
PCB-1232 (Aroclor 1232) 4U 0.052U 46U 960U 58U 85U 100U 22U 760U 940U 380U 410U 750U 110U 37U
P.CB-1242 (Aroclor 1242) 4U 0.052U 46U 960U 58 85U 100U 22U 760U 940U 380U 410U 750U 110U 37U
PCB-1248 (Aroclor 1248) 4U 0.052U 46U 960U 58U 170U 210U 43U 760U 940U 380U 410U 750U 110U 37U
PCB-1254 (Aroclor 1254) 4U 0.052U 46U 960U 58U 170U 210U 43U 760U 940U 380U 410U 750U 110U 37U
PCB-1260 Aroclor 1260) 470C 0.17 94 68000 58U 2,200 4,000 no 93000 78000 30000 29000 60000 8900 37U
2,200 4,000 no TotalPCBs 470 0.17 94 68000 58U 93000 78000 30000 29000 60000 8900 37U
C = Confirmed by gems: (1) When no value is reported, see chlordane constituents;
(2) Constituents or metabolites of technical chlordane.
R = qc indicates that data unusable. Compound may or may not be present.
Resampling and reanalysis is necessary fOf verification.
U = Material was analyzed for but not detected
µg/kg = mk:rograms per kilogram
G.\POt,OMERK\EXCEL\CAAOLINA\TB-RASOW.XLS(2-3)
•
SD-22
[ <0.037)
0~
'
24" CMP
INV. = 83.29
•
-GRAPHIC SCALE
0 50 100 200
i !
( IN FEET )
1 INOi • 100 FEET
SD-18
[78)
•
SD-17
LEGEND
SD-2 ~ 1998 SEDIMENT SAMPLING LOCATION
~~S[:::::93
~] :::----SD-16 ~ [ 7 00) ,".
PCB CONCENTRATION IMMUNOASSAY (MG/KG) ( 4.8)
✓ z SD-23
[700] PCB CONCENTRATION -LABORATORY (MG/KG)
0[0.094)~~-=-==--------.._j
SD-15
[4,000]
0 ■ 1990 SEDIMENT SAMPLING LOCATION (APPROXIMATE) AND RESULTS (MG/KG)
---
18" RCP -~
----~,.. -~24
[68)...___
SD
[2,2 (ND) -NOT DETECTED
INV. = 83.90 so"!~
[ <0.058 -----SD-9 \
\ ~ (470) 0 SD-8
[ 470) (0.00)
SD-6
(1.54)
D-7
(21.2)
SD-5
(20.1)
0 SD-4
, (6. 76)
,0
■ (ND)
DIT
.8)
0
SD-1
(18.8
<)
(200) ■
\
\
\
\
\
\
\
\
\
IW.= 86.56 (75)
PROJECT TITLE:
CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
1998 DOWNSTREAM DRAINAGE DITCH
SEDIMENT PCB RESULTS
FIGURE 2-3
DRAv.N: DATE DES. ENG.: M.B.S. 12/08/98
CHECKED: DA TE: APPROVED:
W.O. NO.:
04400-073-095-0005
DATE: CAO FILE NAME: DRAINAGE.DWG
, SD-21
() (8.9]
•
90'
SD-19
(30/29]
SD-20
(60
24" CMP
INV. = 83.29
-GRAPHIC SCAl£
50 100 200
i ,
( IN FEET )
1 INCH -100 FEET
• 30'
LEGEND
SD-2
~
( 4.8)
1998 SEDIMENT SAMPLING LOCATION
PCB CONCENTRATION -IMMUNOASSAY (MG/KG)
[700] PCB CONCENTRATION -LABORATORY (MG/KG)
■ 1990 SEDIMENT SAMPLING LOCATION (APPROXIMATE) AND RESULTS (MG/KG)
(ND) = NOT DETECTED
fZ//1 PROPOSED EXCAVATION AREA
0 SD-8
(0.00)
(N
(
I
\
\
\
\
\
\
\
\
\
\
PROJECT TITLE: CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
PROPOSED OFFSITE SEDIMENT
EXCAVATION DRAV.W: DA TE DES. ENG.: M.B.S. 12/08/98
CHECKED: DA TE: APPROVED:
DA TE W.O. NO.:
04400-073-095-0005
DATE: FIGURE 3-2 _________ ..__ ______ ......_ ______ ___. _______ ---=..=...:....:.=--=---=-------•~-~--CAO FlLE NAME:
0RAINEXC.DWG
•
WOODED
-----,
-------X -------X
-------X -
GRAPHIC SCALE
0 60 120 1 '---1 1
1 INCH = 66 FEET
AREA
Q
X
I
X
I
LARRY'S SAUSAGE
MIDDLER OAD
UST
X _J _ _j ___
X _J_J
_J_ I I_J_J 7 _J_ 8 _J_ 5 _J_J 6 _J_
X _J_ _J_J _j_J_J
_j_J_J _J_J_J
:3.JJJ
_,_,_J~_J
±tf:J_J _J
_j_J
PROJECT TITLE: CAROLINA TRANSFORMER SITE
FAYETTEVILLE, NORTH CAROLINA
PROPOSED ON-SITE SOIL
AND SEDIMENT EXCAVATION
FIGURE 3-1
_J _J _J _J _J _J
_J_j_j 72J _j_J_J J
_J _J _J _J _J _J
_J _J _J _J _J _J
EXCAVATION KEY (FEET)
0.5
1. 5
2.0
3.0
5.0
WOODED AREA
~ ~ It
DRAWN: DA TE LA '1'RMAN: W.O. NO.: M.B.S. 0 29 98 04400-073-095
DES. ENG: OAT£ APPROVED:
--• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, s.w. A
ATLANTA, GEORGIA30303-3104 EGE IVED
DEC 2 4 1996 DEC 311996
Mr. Lyle Hunnicutt, Vice President Environmental Technologies Unlimited 9220 Industrial Blvd. NE
SUPERFUND SECTIOtc
Leland, North Carolina 28451
Dear Mr. Hunnicutt:
This letter is a follow-up to a meeting held in Atlanta on September 26, 1996, attended by both EPA Headquarters and Regional staff, in which you outlined a concept for the remedial action phase at the Carolina Transformer Superfund site in North Carolina. Your concept was for EPA to solicit bids for this fund-lead NPL site using a firm fixed price contract, and includ.e ·in the scope of the remedial action specific activities leading to a prospective purchaser agreement and a guaranteed reuse of the site for commercial purposes. The stated benefits of your concept included cost savings to the government and the indirect benefits of commercial reuse of the property.
As discussed at the meeting, EPA sees severai reasons why the Carolina Transformer site may not be an appropriate site for testing this concept. First of all, the Carolina Transformer site is not currently within the funding range for FY 1997 Superfund dollars. Secondly, even when funds do become available, EPA has already completed the design/and bid package for this site, and any reworking of this bid package would cause additional delays. This is also already an innovative design and bid package, which may end up with a significant cost savings over more conventional approaches.
As we have stated before, when the Carolina Transformer project is bid (or any other candidate site) ETUC is a welcome bidder. Also we would be glad to work with you or any third party on a prospective purchaser agreement for redevelopment of the site, consistent with our existing guidance and policies on such agreements (enclosed)_
If you would like to. discuss this further feel free to call me at 404/562-8789 or Luis Flores at 404/562-8807.
Si~~~
Philip H. Vars~, Chief North Carolina Site Management Section
Enclosure
Recycled/Recyclable. Printed wllh Vegetable Oil Based Inks on 100% Recycled Paper (40% Poslconsumer)
J
State of Nort~rolina Department ~vironment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Mr. Luis Flores
December I 5, I 994
Superfund Branch, Waste Management Division
US EPA Regi~;m 1,V
345 Courtland'Street
Atlanta, Georgia 30365
:RA
DEHNR
RE: Comments on Draft Performance Specification for Soil Treatment
Remedial Design (Phase II)
Carolina Transformer Site
Fayetteville, Cumberland County
Dear Mr. Flores:
The Superfund Section has received and reviewed this document and offers the following comments:
I) Page 2. Item (5). Sentence 2.
Comment: Sentence should read as follows:
The demonstration shall provide an indication of the ability of the treatment system to achieve soil clean-up objectives[, including modeling of metals to show that the ground water is protected,] while processing a waste feed representative of both the greatest degree of difficulty of treatment and the highest contaminant mass concentration on the site.
Addition is indicated by brackets.
2) Page 6. Section 2.2 STATE
Comment: Add the following:
A reference list of applicable State regulations follows. This listing may not be complete.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone] An Equal Opportunity Affirmat'1ve Action Employer 50% recycled/ l 0% post-consumer paper
'
Mr. Luis Flores
December 15, 1994
Page2
•
Reference
GSNC-143-21B et seq
GSNC-134-21A et seq
_GSNC-l 13A-3 ll et seq
NCAC-15A-2B
NCAC-15A-2C
NCAC-15A-2D
NCAC-15A-2H
NCAC-15A-2L
NCAC-15A-4
NCAC-15A-13A
NCAC-15A-13B
NCAC-l 5A-13C
•
Description
North Carolina Air Pollution Law
North Carolina Hazardous Waste Management Act
North Carolina Drinking Water Act
Surface Water Standards
Well Construction Standards
Air Pollution Control Requirements
Procedures for Permits
Groundwater Classifications and Standards
Sedimentation Control
Solid Waste Management Rules
Hazardous Waste Management Rules
Inactive Hazardous Substances and Waste Disposal
Sites
3) Page 8. Last Paragraph. Sentence 2. "Not less than three samples shall
characterize any portion of treated soil ( volume determined by Contractor as
schedule and available storage space dictates) for determination of clean backfill."
Comment: It is not appropriate to leave procedures for determination of cleanup
levels at the discretion of the Contractor. The volume to be tested should be
determined by EPA with State concurrence. Sampling should be more frequent
during startup and then the frequency of sampling lowered if the treatment can be
shown to operate properly.
4) Page 13. Section 4.3 SAMPLING AND ANALYSIS PLAN Item (I)
Comment: First Sentence should read as follows:
J • • Mr. Luis Flores
December 15, 1994
Page 3
Sampling of the treated soil shall consist of at least one composite sample ( with each composite consisting of five subsamples) [ and one set of samples to be submitted for metals analysis and soil/water
partition/distribution coefficient determination] for each batch of soil treated or each 250 cubic yards processed in a flow through reactor.
Addition is indicated by brackets.
We appreciate the opportunity to review this document. If you have any comments or questions please call me at [phone].
cc: Bruce Nicholson
Jack Butler
~~ncere~y, /0) (} (~kc'>J:y:~~
David J. Lown
Environmental Engineer
Superfund Section
State of North ctllina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
December 13, 1994
Memorandum
TO: Arthur Mouberry, Chief
Groundwater Section
• NA
DEHNR
Division of Environmental Management (DEM)
FROM:
RE:
David J. Lown '·-· / ,f..
Environmental Engineer
Superfund Section
Draft Performance Specifications
Remedial Design Report (Phase II)
Carolina Transformer Superfund _Site
Fayetteville, Cumberland County
EPA is completing a Remedial Design for the Carolina
Transformer Superfund Site, a National Priority List site. The NC
Superfund Section is reviewing the draft report and will be
submitting comments to EPA by December 15, 1994.
The documents being_ reviewed are attached. The report was
prepared by Black & Veatch Waste Science, Inc. out of Atlanta for
the US EPA, Region IV. Please forward these documents to the
appropriate sections of DEM 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 of DEM.
If you or your staff have questions, please call me at
( 919) 733-2801.
Attachment
P.O. Box 27687. Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
·' State of Nortr1 Ca;&a
Department of l::n~i'nmenr,
Health and Natural Resources
Division of Solid Wasfe Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
November 22, 1994
Mr. Luis Flores
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
RE: North Carolina Division of Environmental Management Comments on
Draft Remedial Design (RD) (August 15, 1994)
Carolina Transformer NPL Site
Fayetteville, Cumberland County
Dear Mr. Flores:
Attached are comments made by the DEM on the RD for this site. If you have any
questions or comments, please call me at [phone].
cc: Bruce Nicholson
Jack Butler
Since\y,~'.\
Q,~lX) \~-~·a-_
David J. Lown
Environmental Engineer
Superfund Section
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone 919-733-~996 FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
State of North Ca.ina Department of E nment,
Health and Natur Resources
Division of.Environmental Management
James B. Hunt, Jr., Governor
Jonathan B.,Howes, Secretary
A. Preston Howard, Jr., P.E., Director c----------,-· RE~!f~,e~D
NOV 2 2 1994
November 16, 1994
sUPERl'UND S£GTIOl1;
MEMORANDUM .. ---1,-i
TO:
FROM:
Jerome Rhodes, Chief
Hazardous Waste Section ~-
1
-/\
?,nPreston Howar4'-~
t0v 18 1004
~us~
SUBJECT: Carolina Transformer
Draft Remedial Design
Cumberland County
Project No. 94-57
The Di vision of Environmental Management has completed the
review of the subject document and offers the following comments
and recommendations.
Air Quality Section
1. Since a structure is to be demolished, the Asbestos
Control Management Branch must be contacted and advised
of planned action. A permit may be required. This
office has no known documentation proving that the site
is asbestos free.
2. Due to the nature of this operation (removal of PCB),
any dust control plan must address how emissions of
particulate matter (and associated PCB) are to be
prevented from exiting the property.
Water Quality Section
1. All offsite surface water should be diverted away from
excavation area prior to soil removal.
2. Surficial water table is not noted on plans provided.
Soils identification of the SHWT should be provided. A
plan of action should be developed for excavation
entering the groundwater table. All work should be
performed during the dry weather.
3. Contractor should have letter of acceptance for IDW
water from the Fayetteville PWC prior to project start
date.
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
• •
4. Has the?site been reviewed for threatened or endangered species.
5. Has the site been reviewed for historically significant
landmarks?
6. Has the contractor received a Sedimentation Erosion
Control Plan?
7. "Swamp" areas are denoted on the plans provided.
Wetlands should be delineated prior to excavation, and
a remediation plan should be developed for wetlands
excavated.
Based on the information provided and the above comments,
the project should have no off-site impacts to surface waters.
Groundwater Section
The two areas for groundwater concern are the excavation of
and stockpiling the contaminated soil.
Site remediation by excavation of the PCB contaminated soil
is an acceptable approach. The excavation of contaminated soil
will take place in various locations and will extend to various
depths. Based on the information provided in the Draft Remedial
Design (DRD) , the vertical extent of excavation has yet to be
determined. Therefore, we recommend that the contractor utilize
the following as guidelines:
1. The excavation shall not extend to a depth greater than
the water table elevation.
2. The excavation shall extend to the soil contaminate
action level, provided the action level is reached at
an elevation higher than the water table.
Another aspect of soil excavation is the potential risk of
rapid infiltration and collection of water within the excavation
from precipitation. While this risk cannot be totally
eliminated, it can be minimized by backfilling• the completed
areas as soon as possible. Ideally, the contractor should have
only the area of active excavation exposed.
The proposal for soil stockpiling appears to be adequate.
Steps are proposed to limit leachate production and for
collection of the leachate when it is produced. However, we
could not find any details in the design that discussed the
treatment and disposal of the leachate. The contractor should
submit additional information about this aspect of the project
before we consider approving it.
• •
If there are any questicns, please advise.
APHjr/sbp/SWM2.
cc: Alan Klimek
Steve Tedder
Fayetteville Regional Office
Central Files
Groundwater Section Files
State of North ~olina
Department otWvironment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
November 16, 1994
MEMORANDUM
TO: Jerome Rhodes, Chief
Hazardous Waste Section A-,-J\
FROM: ?,i,Preston Howar4J..,~
SUBJECT: Carolina Transformer
Draft Remedial Design
Cumberland County
Project No. 94-57
~AVA
DEHNR
RECIFl'-'~O
NOV 2 2 1994
suPERFUND SECTIOfll
~"~ cmH
The Division of Environmental Management has completed the
review of the subject document and offers the following comments
and recommendations.
Air Quality Section
1. Since a structure is to be demolished, the Asbestos
Control Management Branch must be contacted and advised
of planned action. A permit may be required. This
office has no known documentation proving that the site
is asbestos free.
2. Due to the nature of this operation (removal of PCB),
any dust control plan must address how emissions of
particulate matter (and associated PCB) are to be
prevented from exiting the property.
Water Quality Section
1. All offsite surface water should be diverted away from
excavation area prior to soil removal.
2. Surficial water table is not noted on plans provided.
Soils identification of the SHWT should be provided. A
plan of action should be developed for excavation
entering the groundwater table. All work should be
performed during the dry weather.
3. Contractor should have letter of acceptance for IDW
water from the Fayetteville PWC prior to project start
date.
P.O. Box 29536. Raleigh. North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
• •
4. Has the?site been reviewed for threatened or endangered species.
5. Has the site been reviewed for historically significant
landmarks?
6. Has the contractor received a Sedimentation Erosion
Control Plan?
7. "Swamp" areas are denoted on the plans provided.
Wetlands should be delineated prior to excavation, and
a remediation plan should be developed for wetlands
excavated.
Based on the information provided and the above comments,
the project should have no off-site impacts to surface waters.
Groundwater Section
The two areas for groundwater concern are the excavation of
and stockpiling the contaminated soil.
Site remediation by excavation of the PCB contaminated soil
is an acceptable approach. The excavation of contaminated soil
will take place in various locations and will extend to various
depths. Based on the information provided in the Draft Remedial
Design (DRD), the vertical extent of excavation has yet to be
determined. Therefore, we recommend that the contractor utilize
the following as guidelines:
1. The excavation shall not extend to a depth greater than
the water table elevation.
2. The excavation shall extend to the soil contaminate
action level, provided the action level is reached at
an elevation higher than the water table.
Another aspect of soil excavation is the potential risk of
rapid infiltration and collection of water within the excavation
from precipitation. While this risk cannot be totally
eliminated, it can be minimized by backfilling the completed
areas as soon as possible. Ideally, the contractor should have
only the area of active excavation exposed.
The proposal for soil stockpiling appears to be adequate.
Steps are proposed to limit leachate production and for
collection of the leachate when it is produced. However, we
could not find any details in the design that discussed the
treatment and disposal of the leachate. The contractor should
submit additional information about this aspect of the project
before we consider approving it.
. . • •
If there are any questions, please advise.
APHjr/sbp/SWM2.
cc: Alan Klimek
Steve Tedder
Fayetteville Regional Office
Central Files
Groundwater Section Files
•
October 14, 1994
Memorandum
TO:
FROM:
RE:
File
David
Telephone Call from Luis Flores
•
Response to Comments on Draft Remedial Design (August 15, 1994)
Carolina Transformer NPL Site
Fayetteville, Cumberland County
Luis Flores telephoned to discuss the comments on the Draft RD
for this site.
In response to Comment #1, which asks "how long will the
excavated soils be stockpiled?", Mr. Flores stated that a
contractor will be selected and work started within 90 days. The
exact length of time that the stockpile is to be in place is
dependent on the treatment method and contractor selected, which
are both unknown at present.
In reponse to Comment #2, which states "the stockpile must
meet all the requirements specified in 15A NCAC 13A Part 264
Subpart L," Mr. Flores said that the design specified by the
regulations is not cost effective. The design could be built, but
the EPA does not believe this to be the best use of the available
funds.
cc: Bruce Nicholson
Jack·Butler
State of North aolina Department of Environment, Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretory
William L. Meyer, Director
DEHNR
September 12, 1994
Mr. Luis Flores
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
RE: Comments on Draft Remedial Design (RD) (August 15, 1994) Carolina Transformer NPL Site
Fayetteville, Cumberland County
Dear Mr. Flores:
The North Carolina Superfund Section has reviewed the Draft RD for the Carolina Transformer Site and would like to make the following comments:
1. This RD covers only the activities necessary for excavation and stockpiling of contaminated soils and the demolition and removal of other site components.
How long will the excavated contaminated soils be stockpiled before being treated?
The RD refers to contaminated soil stockpile as a "permanent" stockpile. The stockpile is temporary, used to store the contaminated soil until it can be treated. The term "pre-treatment" stockpile may be more appropriate.
2. The stockpile must meet all the requirements specified in 15A NCAC 13A Part 264 Subpart L. These are the regulations for the design and operation
of hazardous waste piles in North Carolina.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone] An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
_,
Luis Flores •
September 12, 1994
Page 2 •
Thank you for the opportunity to comment on this Phase 1 Remedial Design. We look forward to seeing the designs for the soil and the groundwater treatment systems. If you have any questions, call me at [phone].
cc: Jack Butler
Sin. cer~lym.
~~\l,3/-~L0~
David J. Lown
Environmental Engineer
Superfund Section
State of North C.lina ·
Department of ronment,
· Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
August 23, 1994
Memorandum
TO:
FROM:
Arthur Mouberry, Chief
Groundwater Section
Division of E~J~o~ental
David J. Lown~ ·
Environmental Engineer
Superfund Section
Management (DEM)
RE: Draft Remedial Design Report
·Carolina Transformer Superfund Site
Fayetteville, Cumberland County
EPA is completing a Remedial Design for the Carolina
Transformer Superfund Site, a National Priority List site. The NC
Superfund Section is reviewing the draft report and will be
submitting comments to EPA by September 7, 1994.
The .. dqcuments being reviewed are attached. The report was
prepared by Black & Veatch Waste Science, Inc. out of Atlanta for
the US EPA, Region IV. Please forward these documents to the
appropriate sections of DEM 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 of DEM.
If you or your staff have questions, please call me at
[phone].
Attachment
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
,ptear:Lak~,s,ei:fi/fi~h .qciiecl .·
:Th~ .lJ.n~y~f~i~y!~J.~.~~if.om~a-p~yi$}rn~1~g~n ~, .
study .to determine .whether cleariing· up .. contami-, :, ;l•,"c>· '•,: ; ,•,\ ,-, , :·, _, ,; ,. ' , ,• , "·· ' ·', '. .. '·• • , ", , .
I}_~~~~-~-~cgf.Il~~l~1· o,~f~~~~~f}f},hf :?.~,~~~~ ~a!J~ . :·-,
Mercury Mine NPL site will reduce mercury in fish •• ,, < • .1,-11.'''· .. ,: :;,,,:·,, ·! .: ... ,,,,. : .•
t_o. ~cccpt_able level~·-._ . __ . .-;. '_ ·'EPA· says\¥·a~:t~-r~·on'i th~ mfnd -i-~take Count)',·
C~1ir.: 'i/lh~ 'm~~i '~lg~ifi~~-~tsci~}Ce-_.o'r'TI1erCUry i□·' .•. ' . ·t . . : .. ' i:, .. , •, :-' .. : .-' ''' •, . . '. ·. . . the lake. But because natural mercury 1s buned m ·
deeper s_edirne□~-~. _the ~gcncy says it may not be
pr_actic1afto de·an .~P t_he' Cohta'.n'li'natiOn bY dredgin"g
'o'r ic,Tio'Vin'g siirfaCc sedini.ents.
· ·"Th~ dilly prlidiCa1·c1eanup alternatives for the·
lake sedi_rl1ents may be to either cover them with
dean sand or'clay or:leavc them alone and let
natural sediITlentation form a clean cover over
time',':. EPA explains in a recent fact sheet.
, Hot springs throughout the lake also have added
small amounts of.:mercury,to the water for many
_c~n.tutj~_S_;_Low·l.~:Ye!s of:m~rcury __ ~av~ been round .
in dCCpcr sedilllcni throughout the.lake. This
; .cont~minati9n i_~-~~iev~d to pe from ancient hot
springs:;-,,: ~•.
La.st .y~ar B~~dley Mi~ing .Co. failed to persuade
a federal appeals court that EPA had wrongly listed
the company's .Sulfur Bank mine on the NPL. The
. corpp<'ll1y 3fiu~d t_l_1at thC ag~ncy failed to prove that
~erCUf)'· W3S th~-~Csult of rlli~ing rather than natural
geoit\'iriiiai"~cti~itf(S11pe,f1ind Week 914192).
. BUt'E.PA\aict.the hig'i-iCSt mcr·cury levels were.
found in sediment cores in the upper few inches of
sed.iITl1eBh:·011~Cted near'ih'e "IIline where thC age of
depcSsits'C'OITd:J)onds 'tcr thC period of mining during
the last century:·'.:=···
'::··A!s10, higheSt OVeiall mercury concentrations
were· folliid in .testS;of plankton, lake botlom plants,
worms and insects, in-the ·oaks Arm of the lake
neanhc·minc.-Gellerally lllercury concentrations
, ,detfeaSed.with distance from,the-mine.
Contact: Carolyn d"A/meida. EPA project
.,manager,.4 I 5-744-2225.
[Design-proc~eds !!_1_ Fay~tteville--. , --. Black & Veatch Science & Technology Corp. is
preparing d<;sign plans for a.fund-lead cleanup at.the
lCanJTrQa f ransf~r~~r NPL site in Fayetteville, N.C.
EPA plans for remedial action field activities to
·peg in _i_n; fate 199,_4:at_;the 5:-acr,e former electrical
lrans"rorffiCr r~pair'Sitc.
•··· .. · ;i,.'naly;i; of gi~undwater samples ;hows PCBs .
. ),clay co~finirig l~y~r isabout 15 feet belo_;,
g:fOlind ·anct ls ~t·1eaSt 100 feet thiCk, so downward
migration of contani.in'ants intO the 10:.V·er ~quifer
' "isii't likely .. · .. ' . . .
ThC $1051llillion present-worth ROD signed in
August 1991 called for solvent extraction of PCBs
exceeding 1 inilligram/kilogram in soils and metals
precipitation and aCtivated carbon adsorption to
remove metals and volatiles from groundwater.
Contact:Luis·Flores, EPA project manager,
800-435-9233.
Interior ,may se,g)i'.'{n,'.$4P¥.rf,l:-IQ9•'. '" >,,;5;,
. ' ' 'A,sehicir Interior Ocpt. official told Congress he is.pushing.a
. prq°!XJ~,f or ~e depal11llc~t io establish an ''i~f+,,nal 'superl'~~d'i f9r
lan~s .•t c~~tro!s. · .·. . · , ... : , ,.-, ;;, _
'" "I'm ·noi sure where .the secretary stands on this,'.' confessed;
Michael Heyman, deputy assistant secretary for policy, management
'ahil budget.
· • In testimony to tl1c .Senate Governmental Affairs Committee'and
in an'intervicw with Superfund Week, Heyman said he envisions a fund
that :,vould be established with nioney authorized by Congress and
recharged by damages department lawyers could recover from parties
responsible for polluting federal land.
His idea, he said, would leave the department free to spend the
fund balance on cleanup without further appropriations. This is unlike
the real Superfund, whose "fund" is· a Treasury account that keeps
track of receipts from special taxes, and most program spending. EPA
collects money through enforcement suits and settlements and that
money goes into the fund. But Congress gets to say how much EPA
can spend. Congress makes annual appropriations~·just as in other
· government programs, to EPA for the Superfund program.
One point of an internal Superfund program, Heyman said, is that
the department would have an incentive to pursue cases, since it would
keep any money recovered. EPA doesn't pursue private parties at
federal installations, since the government is assumed to be responsible
and Superfund dollars can't be spent on federal cleanups. That money
must come through departmental appropriations.
Heyman said he had no idea of an appropriate size of such a fund,
or how many cases it might pursue each year. He noted that the
department is spending about $64 million a year on cleanup now. Also,
the department has $8.3 million a year to assess natural resource
damages and pursue recoveries.
"Whether I'm going to be able to carry that (an internal
Superfund)fo my department I don't know, but if! do, we'll be
pursuing legislation," Heyman said.
Contamination of the public lands was one subject of the hearing.
Heyman said the department is organizing a common inventory and
· reporting system for its operating bureaus that, within a year, should be
able to provide a first estimate of how many contaminated sites deserve
further attention and how many ·do not.
Nobody knows the ·scope of those future cleanups now, and the
Governmental Affairs Committee said it could involve billions of dollars.
Interior has 432 sites on EPA' s list of federal installations that need further
investigations. There arc 60 abandoned mining sites on federal land on the
NPL. As many as IO million mining claims have been filed in U.S. history,
and hundreds of thousands of acres disturbed.
Residuals dechlorination nixed at Re-Solve
EPA has dropped the use ofa dechlorination process as the second
part of a treatment for PCBs at the Re-solve Inc. Superfund site in
North Dartmouth, Mass.
Soil treatment began last June with Chemical Waste Management
Inc.'s X*TRAX thennal desorption system.
X*TRAX heats soils to vaporize PCBs and volatile organics.
Vapors arc collected and cooled into liquid fonn. Rust Remedial
Services Inc. has a subcontract to run the X*TRAX system. ENSR
Corp. of Acton, Mass., is the prime contractor. Rust is a division of
Rust International Inc. of Binningham. Ala., which is 55% owned by
Chemical Waste Management.
Pasha P11blicatiom, 1616 N. For/ Myer Drive, Suite 1000, Arlington, Va. 22209 S11perfi1nd Week-September 24, 1991 3