NCD003200383_19900126_Koppers Co. Inc._FBRCERCLA RI_Remedial Investigation Work Plan 1989 - 1990-OCR

Beazer Materials and Services, Inc. p D 'f'(os l'f
A Member of THE B.R GROUP •
Dear Barbara:
Environmental Servi
436 Seventh Avenue, Pitt.sburgh, PA 15219
Phone: [phone] Fax: 412/fff'C/I:.iVEo
D~ D JAN :11 1990 m vd cJ s UPERFllND SECTION
January 26, 1990
Ms. Barbara Benoy
NC/SC Site Management Unit
U.S. EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Re: Morrisville
This will confirm our telephone conversation of
January 10, 1990 in which we concluded an agreement
concerning EPA's conditions for accepting BM&S's Work Plan
for the Morrisville site.
During our conversation we discussed the difficulties BM&S
foresees associated with the revised, shortened schedule
for submitting the draft FS Report. We agreed that it is
necessary to have a certain level of confidence in the
finality of field sampling done to delineate the extent of
the potential contaminants of concern before a draft FS
can be completed for EPA review. We agreed that
confidence in the finality of the sampling results could
be assured if we hold regularly scheduled monthly or
bimonthly meetings to review project status. We" further
agreed that we will hold project status meetings at
mutually convenient times on a regular basis either at the
site or 1n Atlanta.
With our agreement to hold regular project status
meetings, BM&S is willing to accept the revised schedule
and the other conditions outlined in your letter. EPA's
conditional acceptance of the Work Plan should be rendered
final by BM&S's acceptance of the EPA conditions on the
terms set forth above. Unless we hear from you to the
contrary, we will revise the Work Plan schedule consistent
with your letter and forward it to you for attachment to
the ACO. Please note concerning the schedule that we
assume any change in the date for submitting the draft RI
Report would effect a corresponding change in the date for
submitting the draft FS.
Writer's Direct Dial _____ _
.I
I trust you
January 17,
questions.
cc: P. DeRosa
W. Giarla
• January 26, 1990 •
Ms. Barbara Benoy
2.
received the Project
call
Operations
me if you 1990. Please
Very truly yours,
;iJ //_tc,w_ ,~ r<. {{ ~
Shannon K. Craig
Plan
have
on
any
.I
• • KEYSTONE
ENVIRONMENTAi. RESOURCES. INC.
Phone: [phone] Tech Center Dr., Monroeville, PA 15146
Dear Barbara:
November 14, 1989
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch, Waste Management Division
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
On behalf of Beazer Materials and Services, Inc., I am pleased to submit to you for
your review and approval, five (5) copies of "Work Plan to Perform Remedial
Investigation and Feasibility Study, Morrisville, NC Site" dated November 1989. We
are also sending two (2) copies to the State of North Carolina.
Please note that a computer generated critical path schedule has been prepared in
Section 6 of the Work Plan for the RI/FS, as we discussed with you November 1. We
have included the PHEA (Risk Assessment) in the RI Report. We believe this
schedule depicts a realistic time to complete the tasks described in the Work Plan.
Any suggestions which you may have to shorten the project we would most certainly
like to discuss and consider.
We will submit to you under separate cover your comment letter indicating the pages
of the Work Plan that address your comments. Thank you again for your attention
and consideration.
JCM:dac
cc: Ms. Lee Crosby
Ms. Shannon Craig
Very truly yours,
~ (_' /f),,,t37t./-l;,L
John C. Mitsak, P.E.
Senior Project Manager
• •
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
3WD-SFB
ncr !. s 1.98'!
Shannon Craig
Beazer Materials and Services
436 Seventh Avenue
REGION IV
345 COURTLAND STREET. N.E.
ATL.A.NTA. GEORGl,-'l. 30365
Pittsburgh, Pennsylvania 15219
Subject: Koppers Superfund Site
Morrisville, North Carolina
Dear Ms. Craig:
·RECEIVE[)
ocr 1 B 19s9
SUPERFUND SECTION
Enclosed please find the comments developed on the Revised Draft Work
Plan for the Koppers Superfund Site located in Morrisville. Many of
these comments are reiterations. A copy of the comments submitted by
the NC-DHS is also included; the content of which should be
considered as comments submitted by the EPA to you. All comments
should be incorporated into the second revision.
The second revision of the work plan should be submitted no later
than November 15, 1989 as this is the second revision of the draft.
Please do not hesitate to contact me if you have any suggestions or
questions. I can be reached at 404/347-7791.
Sinc;(\'rely,
. c.:Ji-{tcz/j:c_
Barbara H. Benoy
Remedial Project
Enclosure
cc: Bill Giarla, Beazer Materials
John c. Mitasak, Keystone
Pat DeRosa, NC-DHS .,.,,.,-
Comment#
1
2 __ _
3 __ _
4 __ _
5 __ _
6 __ _
7 __ _
• KOPPERS MORRISVILLE NPL SITE •
DRAFT RI/FS WORK PLAN
REVISION 1
EPA's Review Comments
Reference
General
General
General
General
Section 1.0
ES-1
Section 2.1
Comments
The work plan must adhere to the
ESD SOP. The decon procedural
change requested for this site is
written and included in the SOP.
The historical data is still
presented in a manner that is not
presented as a package. It is
presented in numerous documents.
For example, Appendix A, Summary of
Existing Data, was prepared in
August of 1987, and does not
include much of the available data
now in existence.
The cleaning and decontamination
procedures for all drilling and
sampling activities shall be in
accordance with ESD's SOP.
There are no references included.
This is assumed that a mistake was
made in the reproduction of the
document. Please supply the
reference page including all
appropriate site-specific
documents.
The RI/FS objectives should still
include characterization of
sediments of the Koppers Pond, and
the confirmation of the nature of
groundwater contamination and the
determination of the extent of the
groundwater contamination.
The site was proposed for NPL
listing in June 1988.
Existing monitoring well system is
questionable. Please refer to
comments 55, 61 and 69. The
integrity of the existing
monitoring well system is
questionable because of these
wells.
• Comment j/ Reference
8. __ _ Page 2-3
9 __ _ Figure 2-7
10 __ _ Page 2-5
11_ Page 2-5
12 __ Section 2.1
13 __ Page 2-6
14 __ Page 2-7
15 __ Page 2-7
•
Comments
In paragraph 1, it would be helpful
to distinguish between the seven
air rotary drilled monitoring
wella, the twelve piezorneter
inatallationa, and the fifteen aoil
borings aa they are labeled on
Figure 2-3 and 2-4.
It ia very difficult to translate
thia figure to the main aite map.
Please add aorne aort of key to eaae
this translation.
In paragraph 1, please reference
the source document which describes
the 2 water aamplea collected from
the fire pond in 1976. Ia thia
data available?
In the laat paragraph, please
indicate by number which wells you
are referring to as the "seven
existing wells" sampled in 1980.
The existing monitoring well logs
were presented, but the is
confusion due to the use of
inconsistent codes. The Figures
and text identify M-1 and W-1 and
subsequent codes. However, the
well loga included in Appendix D
identify MW-1, MW-2, and etc.
Please correct by using consistent
nomenclature.
On July 24, 1980, £ offaite wells
and 1 onsite well were each sampled
by KER and the NC-OHS (See Appendix
H). No contaminants were detected.
In line 2, the detection limit
should be in ug/kg, not mg/kg.
Paragraph 2, the 1984 sampling waa
conducted in July, not June.
Groundwater and soil sampling were
alao conducted in December of 1984
(aee Appendix C). There are no
aoil sampling reaulta listed for
June of 1984 in Appendix C.
• Comment II Reference
16 __ Page 2-7
17 Page 2-9
18 __ Page 2-9
19 __ Section 3. 1. 1
20 __ Section 3.1
21 __ Page 3-2*
22 Figure 3-lA
23 __ Page 3-10
• Comments
Approximately 1100 cubic yards of
contaminated soil were removed from
the lagoon area in July 1986,
however, the total volume of
contaminated material removed form
the site in July 1986 was reported
as 1250 cubic yards (see attached
reference Ill).
Clarify the parties involved in the
Consent Orders.
The word "owner" should be added to
the first sentence of the second
paragraph.
Text should read "Figure 2-4
displays the boring locations in
these two areas."
Contour maps should be included to
indicate the extent of
contamination and size of the plume
and direction of migration
Section 3.1.2 indicates that if PCP
is detected in a trip blank, all
samples having up to 5 times the
concentration of PCP in the trip
blank will not be considered
positive sample results. This
procedure is not acceptable for
drinking water samples. At a
minimum, immediate resampling of
drinking water wells would be
required.
Please include the most up-dated
well survey.
Pentachlorophenol (PCP) has been
reclassified as a B2 carcinogen and
is undergoing public comment
presently. As a result, the Agency
will be maintaining a conservative
position and will be using the
newly proposed levels, as per the
Federal Register, Vol. 54, No. 97
May 22, 1989. All data developed
for risk assessment and/or for
public health reference should be
presented and reported as a B2
carcinogen until a decision
contrary to this is made.
• Comment jl Reference
24 ____ _ Table 3-9
25 ___ _ Page 3-17
26 ___ _ Page 3-24
27 __ Page 3-26
28 __ Section 5.3.2
29 __ Page 5-6
30 __ Section 5.3.3
31 ___ _ Page 5-9
•
Comments
The Agency does not concur that
isopropyl ether should be
eliminated for further evaluation
in soil or sediment, or that
PCDDs/PCDFs be eliminated for
further evaluation in surface
water. The RI can be the only
mechanism to generate
substantiation for elimination.
Potential inhalation of PCOCs
volatilized from surface
water/sediment during remediation
should be considered an exposure
pathway. If not, reasons should be
presented.
There is new Risk Assessment
Guidance that is appropriate to use
in place or in addition to of the
1986 Exposure Assessment Manual.
An additional objective for surface
water is to define the extent of
surface water contamination.
Addition soil sample locations
should be added in the teepee area
and should definitely be subjected
to PCDD/PCDF analysis.
Core sampling may not adequately
characterize the sediments of the
Koppers Pond. The major source of
potential contamination in
sediments would be found from the
top of the sediment to the upper l
foot to upper 2 feet. Request
dredge-type samples be collected in
addition to the corings. Five feet
in depth of sediment to be
composited will not be
representative.
Sieve tests should be conducted
prior to selection of sand grain
size or well screen slot size.
The wells must be developed until
the water is clear. Three volumes
are specifically for purging a well
prior to sampling. Proper
development of a well upon
installation is critical.
• Comment /I Reference
32 __ Page 5-10
33 __ _ Page 5-13
34 ___ _ Page 5-15
35 ___ _ Figure 5-1
36 ___ _ Page 5-4
37 ___ _ Table 5A-1
• Comments
Filtering in not permitted for
groundwater samples collected for
RI/FS characterization. Filtered
samples are allowable only when
paired with unfiltered samples.
The unfiltered sample results are
considered the primary measurement
and representative sample for
interpreting the analytical
results.
Why is there such a long period
between the different rounds of
sampling? Please present rationale
and also consider decreasing the
time period between the different
rounds of sampling.
At least three, rather than two,
observation wells will be needed
around each pumping well to
determine the anisotropic ellipse,
.and the orientation of the wells
should be adjusted to the fracture
patterns determined rather than to
the strike and dip of the bedrock.
Interconnections between the
different groundwater levels· can
also be evaluated when pumping from
the deeper zones by including
observation wells in the shallower
zone(s).
Text proposes TCL/TAL analysis at
SW-13. This location is not shown
on Fig. 5-1. Text reference is on
page 5-4.
There is an existing drainage
system that runs parallel to
Koppers Road, along the "wooded
area". Surface water sampling and
sediment sampling should be
conducted on this location and
should at least be conducted on the
north side of Koppers Rd.
In the volatiles list,
1,1-dichloroethane is listed twice.
One should be 1,1-dichloroethene
(also known as
1,1-dichloroethylene).
Comment j/
39 ___ _ Well Info.
40 ___ _ Section 5.1
41 ___ _ Section 5.3.1
42 ____ _ Figure 5-1
43 ____ _ Section 5.3.1
Comments •
There is no comprehensive list of
wells and the corresponding
information. Figure 2-3 gives
locations of monitoring wells
offsite, codes are M-1 through at
least M-12, and W-1 through at
least W-15. However, the
monitoring wells logs presented as
Appendix D gives logs of MW-1
through MW-12. There should be no
confusion to the reader as to which
logs belong to which well. This
must be deciphered and presented in
a manner such that the data is
easily interpreted.
The POP must be consistent with and
incorporate all of the requirements
which are set forth in the EPA
Region IV SOP, not just generally
conform to. Please reference the
Administrative Order and reword as
appropriate.
Surface water characterization is
conducted to determine the nature
and extent of contamination.
Drainage has been identified along
Koppers Road adjacent to the wooded
area. Additional sampling is
necessary. In addition, the work
plan must indicate provisions for
any additional sampling based on
field determination and
observations. The work plan is
written to limit this potential to
specific locations.
Indicate the effluent stream that
flows from the Koppers Pond on all
appropriate figures. A sediment
and surface water sample should be
collected from the effluent north
of the Koppers Road.
Sampling locations on the Koppers
Pond include areas closer to the
lagoon and treatment areas.
Comment#
44 ___ _ Figure 5-1
45 ____ _ Table 5-1
46. ____ _ Figure 5-2
47 ____ _ Page 5-6
48 ____ _ Section 5.3.2
49 ____ _ Page 5-6
50 ____ _ Page 5-6
Comments •
SW-31 does not appear to be a good
candidate for TCL-TAL analysis.
Suggest SW-24.
Temperature, pH, and conductivity
readings should be performed on all
water samples collected.
Figures 5~2 and Figure 5-3 do not
agree.
Top of page, please conduct full
scan metals on the samples
collected within the teepee burner
area instead of "primary drinking
water metals".
The land farming area needs surface
soil sample locations in addition
to the boreholes. If this is
already within the scope, please
clarify with specification.
Decon procedures for downhole
drilling equipment are still not
written to adhere to SOP protocol.
In addition, the rinse water is
organic-free water and not analyte
free water. The EPA SOP contains
definitions of the appropriate
cleaning materials. There is no.
appropriate definition of
"analyte-free water".
"The number of borings installed
will be at the discretion of the
supervising hydrogeologist in
charge of the project and will be
based on physical indications of
pentachlorophenol such as odors,
staining, oil sheens or the
presence of pentachlorophenol
crystals." The statement is
inappropriate and gives the
authority to decide on only two
borings if so desired by the
supervising hydrogeologist. Please
reword. The Agency must assume
that the intent is to drill all
proposed boreholes unless major
problems with location are
• Comment# Reference
51 ____ _ Page 5-7
53 ___ _ Table 5-3A
54 ____ _ Soil/Sediments
55 ___ _ Section 5.3.3
56 ____ _ Section 5.3.3
•
Comments
encountered. Please specify in
text. In addition, at least some
of the locations for TCL/TAL
analysis should be identified in
the work plan.
The methodology for sediment
sampling is not appropriate. If
necessary, the Agency will agree on
the Ponds sediment sampling
locations for the work plan and
reserve sediment sampling
methodology review for the POP.
Coring will not adequately
characterize the pond sediments. Be
aware that PVC piping is not be
appropriate for sediments
collection.
The table does not identify which
sediment samples will be analyzed
for PCDD/PCDF isomers. Please
correct. In addition, some
sediment samples from the Koppers
Pond should be analyzed for
PCDD/PCDF isomers.
Suggest some soil and sediment
samples be analyzed for isopropyl
ether.
Many of the existing monitoring
wells cannot be considered as
legitimate monitoring wells because
of damage to the wells, unknown
construction or dry conditions.
These need to be either deleted
from the work plan or identified as
damaged wells.
The locations of some of the
proposed monitoring, wells are now
obsolete. Please update to
incorporate all existing
groundwater sampling data to date.
• Comment# Reference
57 ____ _ Section 2,3, 5
58 ___ _ Section 5.3.3
59 ___ _ Section 5.3.3
60 ___ _ Section 5.3.3
61 ___ _ Section 5.3.3
•
Comments
The geological, hydrogeological
information presented in the work
plan is extremely general in
nature. Very extensive work has
been conducted by Koppers/Keystone/
Beazer regarding the groundwater at
this site. The 1984 Koppers
Company Inc. Hydrogeologic
Investigation of the Raleigh, NC,
Plant draws some very specific
conclusions concerning the
groundwater and the flow
direction(s). Based on information
obtained historically, the
groundwater flow direction is not
in the same general direction of
surface water flow. Please address
this lack of presentation of data.
Sieve tests should be conducted
prior to selection of screen slot
size.
Page 5-10, the locations proposed
for the deep monitoring wells may
be subject to change in response to
the quarterly monitoring of private
wells. It would appear that the
locations need to be relocated now.
Page 5-13, top of the page
indicates that the well water may
not become sediment-free from
development. Be advised that the
sieve test conducted before
selection of screen slot size will
increase the probability of
sediment-free water.
Page 5-13, The use of the existing
on-site monitoring wells is a good
use of the available resources.
However, the integrity of some of
the existing wells is extremely
questionable. It must be ensured
that the existing monitoring wells
to be sampled (specifically as part
of the RI/FS), must have all
Comment ii
62 ___ _ Section 5.3.3
63 ___ _ Section 5.3.3
64 ____ _ Section 5.3.3
65 ____ _ Section 5.3.3
66 ____ _ Section 5.3.3
Comments •
appropriate documentation of
construction and thorough well logs
and be in technically sound
condition.
Groundwater samples collected for
volatile organic analysis should be
collected with hailers. Pumps
generate too much agitation.
Groundwater samples collected in
the field should not be filtered.
Filtered samples are not considered
representative of the groundwater.
Page 5-13,-14 states that all
laboratory procedures and test
methods will be in accordance with
the Quality Assurance Project Plan
(QAPP). Since this document is not
in existence (or at least not yet
available to EPA), the text
" ... must be consistent with and
incorporate all of the requirements
which are set forth in the EPA,
Region IV Support Branch Standard
Operating Procedures and Quality
Assurance Manual (SOP Manual)."
Please be advised that the SOP has
been amended for soil/sediment
sample collection for volatile
analysis in that no soils/sediments
are mixed prior to being placed in
the respective containers.
40 CFR Part 264.94 is specifically
referring to an active RCRA
facility permit. This is not
appropriate for determining the
PCOCs at this site.
The second paragraph on page 5-14
indicates that Phase II sampling
will only be subjected to analysis
of limited parameters. Either the
list of parameters for Phase II
should be specified clearly prior
to work plan approval or the
criteria for selection. The Agency
must be advised of any "refining"
of the list of PCOCs.
Comment #
67 ____ _ Section 5.3.3
68, ____ _ Section 5.3.3
69 ____ _ Section 5.3.3
70 ___ _ Section 5.3.3
71 ___ _ Section 5.3.3
72, ___ _ Section 5.3.4
Comments •
The criteria of this selection
process must be agreed upon by the
Agency, as it is an integral part
of the RI/FS.
Well C-9 should also be included in
the wells to be sampled for
isopropyl ether.
Aquifer characterization indicates
that certain information will be
collected during the installation
of wells and borings. Please be
advised that section 4.7, page 8
and 9 describe the minimum that
must be included in the drilling
logs as well as any other data
collection.
Table 5-5 indicates that all
TCL-TAL analysis will be conducted
on samples from existing wells.
This is completely inappropriate.
TCL-TAL analysis should be
performed on new wells because of
construction, protocol, procedures
and the integrity of the new
wells. Some of the existing wells
are of questionable integrity, as
stated before. This is also true
for wells subjected to PCDD/PCDF
analysis.
As stated previously, the pump
tests should include three
observation wells.
Additional field parameters that
should be taken at all wells prior
to sampling are temperature, pH,
and conductivity. Elevations and
survey results must be included and
tied into a "real-world" benchmark.
Schedule information provided is
proposed with much allowance of
extra time. From development of
POP to completion is 20 months.
The time recommended to complete a
RI/FS from consent order on, is 18
months. The proposed schedule is
too lengthy for the tasks proposed
to date.
Comment jl
73 ____ _ Section 5.4
74 ____ _ Section 5.4
75 ___ _ Section 5.5
76 ___ _ Section 5-6
77 ____ _ Section 5.6.1
Comments •
Appropriately, copies of the
transferred data, (i.e. floppy
discs, tape), must be submitted to
EPA on validated data. There are
reporting requirements for format
and content which will be discussed
no later that approval of the POP.
The RI Report Format is very
simplistic and needs to include
more information. Please refer to
October 1988 guidance for the
required report format. A section
"Contaminant Fate and Transport",
as included in the guidance, has
not been included and needs to be.
Likewise, the baseline risk
assessment should also include an
environmental assessment. The
Appendices should also be
identified.
Page 5-17, last paragraph, first
sentence, it appears that the word
11 if" is ~iasing.
The screening process of the
Feasibility Study is a little more
comprehensive than presented. The
comparative analysis of
alternatives includes nine
criteria, each of which have
specific factors. These criteria
are as follows: 1) Overall
protection of human health and the
environment, 2) Compliance with
ARARs, 3) Long-term effectiveness,
4) Reduction of toxicity, mobility,
or volume, 5) Short-term
effectiveness, 6) Implementability,
7) Cost, 8) State acceptance, 9)
Community Acceptance. Though the
State and community acceptance is
not a technical factor that can be
implemented into the screening
process in the work plan, the other
seven criteria must be.
Table 5-7 attempts to identify some
technologies. So that there is no
misunderstanding, these
7
Comment jl
78 ____ _ Section 5.6.1
79 ____ _ Section 5.6.1
80 ____ _ Section 5.6.1
81 _____ _ Section 5.6.1
82 ____ _ Section 5.6.1
83 ___ _ Section 5.6.1
84 ___ _ Section 6
Comments •
technologies should be presented
with a brief description. Some
detail is necessary.
Vitrification should be included in
the technologies.
The information used to conduct the
initial screening must be
presented. All site specific
information concerning remedial
technologies must also be
presented. What exactly is "other
relevant work"?
Table 5-9 must include information
such as the soil characteristics
that are sited as being prohibitive
of certain technologies. "Not
appropriate" for the removal of
constituents of interest is not
sufficient rationale or
justification to eliminate
a technology. There must be a
technical presentation made. Same
is true for "not applicable to
anticipated concentrations of
soil/sediment constituents".
Considering the fact that the
proposed schedule for this work is
approximately two years, some of
the eliminated technologies may be
better developed and more
"fine-tuned" by the time the work
is completed.
There is no supporting information
provided in the work plan to
indicate chemical treatment is not
a proven option for PCP
remediation. Must be presented.
All supporting data must be
presented for elimination of a
slurry wall/grout curtain
elimination. Present the technical
rationale.
The schedule can be shortened and
should be. The following
suggestions are made:
* •
*
*
*
*
*
*
Mobilization for. the conducting
of Round 2 sampling could occur two
weeks ahead of proposed schedule.
Round 2 analysis and validation
should not take more than 1 month.
Mobilization for and the conducting
of Round 3 sampling could occur a
full month ahead of proposed
schedule.
Round 3 analysis and validation
should not take more than 1 month
The RI Draft Report should be
submitted no later than 3 months
after completion of RI field work.
The FS Draft Report should be
submitted no later than 4.5 months
after completion of RI field work.
The PHEA is part of the RI and
therefore should be conducted
simultaneously with the RI and
submitted simultaneously.
• •
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
December 9, 1988
Ms. Barbara Benoy
Re!re::lial Prcgram Manager
SUperfurrl Branch
North Site Management section
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Dear Ms. Benoy'
SUBJECT: Koppers COmpany, Inc., NCD980844518
Morrisville, NC
State Health Director
The NC SUperfund Branch has been informzd that on. December
14, 1988, EPA will begin fonnal negotiations with Koppers,
COmpany, Inc. regarding the Administrative Order on Consent to
corxluct a RI/FS at the subject site. As per our telephone
conversation today, I would like to suggest that the following
State concerns be included in the negotiations.
As the RI/FS pr=ess continues, we ask that Koppers provide
the SUperfund Branch with copies of:
1. All reports submitted to EPA.
2. All sarrq::,ling results from on and off-site sarrq::,les
collected by Koppers.
3. All work plans submitted to EPA.
4. All correspondence to local residents regarding the
site. ·
5. All additional correspondence submitted to the public
infonnation repository designated for the site.
We · also ask that Koppers notify the Branch of any sarrq::,ling
they plan to corxluct at or around the site so that we nay
accurately respond to questions from local residents and the
:rredia.
Ms. Barbara Beno,
December 9, 1988
page 2
As a separate issue regardin3' Koppers, I have been informed
that roadside mnstruction for the extension of the Morrisville
water line along Highway 54 has begun. 'Ihis line is scheduled to
turn west on Koppers Road and mntinue west past Omrc:h Street.
Please note that Koppers Road drains urx:l.er Kremrn Road to the
Medlin Pond. Soil mntamination along Koppers Road should
therefore be evaluated prior to installation of the water lines.
We feel that this issue needs to be addressed soon to prevent
delay to the water line installation.
Lastly, I will be nailin3', urx:l.er separate aJVer, a list of
camnunity mntacts with whom I have dealt regarding the Koppers
site. If you have any questions, please feel free to contact me
or Olarlotte Varlashkin at [phone].
PD/pb/31
== Lee Crosby
S~y)Jd. I
,,,,,._.....t DeRosa, Env~Olemist
SUperfurx:l. Branch
Olarlotte Varlashkin
Grover Nicholson
•
Phone: [phone]
FEDERAL EXPRESS
Dear Ms. Benoy:
• KEYSTONE
ENVIRONMENTAL RESOURCES, INC.
3000 Tech Center Dr., Monroeville, PA 15146
August 4, 1989
Fax: [phone]
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch
Waste Management Division
U.S. Environmental Protection Agency
345 Courtland Street, N.E;
Atlanta, GA 30365
RE: Koppers Comgany
Morrisville, NC Site
RI/FS Work Plan (Final)
On behalf of Beazer Materials and Services, Inc., attached please find five copies of
"Work Plan to Perform a Remedial Investigation and Feasibility Study at Morrisville,
NC Site (FINAL)," dated August 1989. The Work Plan has been revised based on
Region IV's comments received on June 21, 1989. We have attempted to revise the
Work Plan to include, in as much detail as possible, the numerous items discussed
with you and Ms. Craig during the last few weeks. If, however, you feel that
additional revisions can be made to clarify or substantiate the Work Plan, pkase call
either me or Shannon so that we may discuss and consider your recommendations.
Two copies are also being sent to the State of North Carolina per the Consent Order.
Thank you for your attentiveness and understanding during this review.
JCM:dac
Enclosures (5)
cc: Ms. Lee Crosby
Very truly yours,
~ C. M!,tiJ'-YAf
John C. Mitsak, P.E.
Senior Project Manager
c/o Ms. Charlotte Varlashkin
North Carolina Department of Health Services
Ms. Shannon Craig
• •
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ms. Evelyn l.llrnley
Mo=isville Town Hall
222 N. Church Street
ro Box 166
Mo=isville, NC 27560
Dear Ms. l.llrnley:
Ronald H. Levine, M.D., M.P.H.
State Health Director
June 14, 1989
Enclosed please find one (1) copy of the Koppers Company,
Inc. Site Inspection Report (Part 1 and II) completed by the
CERCIA Unit, NC Division of Health Services, in May 1987. Ms.
Barbara Benoy, US EPA Region IV, requested that a copy of this
report be :mailed to you to be included as part of the information
repository for the Koppers Company, Inc. site.
If you have any questions, please contact Ms. Benoy at (404)
347-7791.
PD/pb/Koppers.doc
Enclosures (2)
Sincerely,
#✓tix 7)/4 ___
Pat DeRosa, Environmental Chemist
Superfund Branch
Solid Waste Management Section
• .•·:1'w.Tt~
h .• ·t~~\ //.~r;)r~.?--·_,,~; 1< , l _, -·-> j" . I /--1~ ~~,.., .-'tu··! r-i':, \;-,, ·-·-i' ,. .;, .... ""',,,•
-~ .. ",,,".:.:,:,.,,,.
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
J amcs G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
Remedial Project Manager
tebruary 9, 1989
US Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Comments on the Koppers Co., Inc. NPL Site, Morrisville, NC
FSP, QAPP, _Health and Safety Plan for RI/FS January 1990
Dear Ms. Benoy:
The referenced project plans for the Koppers Co., Inc. Site in
Morrisville, NC, have been reviewed and the following comments are
offered:
I. Health and Safety Plan
No comments.
II. Quality Assurance Project Plan (QAPP)
Page i: How do the elements of this signature page
correspond to the elements of a title page as
specified in "Guidance for Conducting RI/FS
Under CERCLA", October 1988, p. B-10?
William L. Meyer
Director
Page ii-iii: Where is the list of recipients of official
copies of QAPP as specified in above guidance
document?
Page 2-2
thru 2-10:
Tables· 2-1 thru 2-4 differ from the
corresponding tables in the Nov. 1989 Work Plan
(Tables 5-1, 5-2, 5-3A, 5-3B, and 5-5) and in
the FSP (1'ables 3-1, 3-2, 3-3A, 3-3B, 3-5). The
differences appear in the columns for analytical
methods, trip blank, comments and footnotes.
Inconsistencies in these tables should be
corrected.
Ms. Benoy
2-9-90
Page 2
Page 2-11
thru 2-15:
Page 3-1:
Page 4-2:
Page 4-3:
Page 4-4:
Page 5-1
thru 5-29:
Page 5-1:
Page 5-3:
Page 5-7:
Page 5-8:
Page 5-9
thru 5-14
Page 5-10:
• •
Please site the reference documents for detection
limits listed in this table.
Please explain which of these individuals is with
BMS, KER, EPA.
Parameters have been added under Section 4.3 which do
not appear in the corresponding Section 4.1.3 in the
November 1985 Work Plan. Inconsistencies in these
tables should be corrected.
The dioxin/furan analysis method 8290 differs from
what appears in the Work Plan. Is this an
intentional change and if so, why?
Why have 11 Representativeness11 and 11Comparability11
been deleted from Section 4.6?
Section 5. 0, 11Sampling Equipment and Procedures11
,
appears in both the QAPP and FSP. If it is to appear
in both, references to figures and sections should be
clarified to state which document they appear in.
Currently, references are made to sections · in the
QAPP and FSP without distinction. For example,
Figure 3-1 and Tables 6-lA ad 6-1B are in the FSP.
Please note in text or consolidate all relevant
tables and figures into one section.
Under Section 5.1.2 in sampling the east and west
drainage ditches, locations upgradient of the site
(SW-25, SW-29) should be sampled prior to
downgradient locations along these ditches. The
intent here is to sample the least contaminated areas
first.
Please site the source of this cleaning procedure.
At what depth will the sediment samples be collected?
Please site the source of this cleaning procedure?
Will an HNu or OVA be used during boring to screen
for volatiles?
Please site the source of these cleaning procedures.
Use new bottles for the VOA samples.
Ms. Benoy
2-9-90
Page 3
Page 5-17:
Page 5-19:
Page 5-21
thru 5-22:
Page 5-25:
Page 6-4:
Page 13-1:
• •
It appears that if purging is done with a bailer the
well would be emptied from the bottom, however, .if
purging is done using a pump the well would be purged
from the top of the water column. llll purging should
be done from the top of the water column ( See EPl\
Region IV SOPQAM, Section 4.7.5.3, l\prU 1986).
In polnt l/6, it appears that all purged groundwater
will be collected. This contradicts Page 5-13 of the
Work Plan which indicates that some off-site wells
will be developed and purged without containment of
the water.
Will bailers be used for sampling after purging with
pumps?
What is "sufficient recovery" before sampling wells
after purging?
Site the section of the Work Plan where filtration of
samples for inorganics analysis is discussed. Please
explain why filtered samples will be analyzed and
non-filtered . samples will be maintained as the
11 samples of record 11 •
Omit last sentei1ce on sampling for radionuclides
since this is not applicable.
Please site the sources of these holding times.
Please site the source of these cleaning procedures.
Why do these procedures vary from those indicated in
Section 5.6.1?
III. Field Sampling Plan (FSP)
Page 1-8:
Page 3-2:
Page 3-7:
On September 24, 1980, EPA also sampled 3 off-site
wells (see Appendix H, Work Plan, November 1989). No
contaminants were detected.
In the 3rd paragraph, no sampling for PCDD/PCDF is
scheduled for the Medlin Pond water. Is the
information from previous sampling sufficient to
characterize surface water in the Medlin Pond for
remediation? If so, explain.
Under "Intermediate Depth Monitoring Wells", is the
first 50 feet of 6" steel welded joint casing
stainless steel? If not, why?
Mr. Benoy
2-9-90
Page 4
Page J-8
thru 3-9:
Page 3-2a
thru 3-lla:
Page 3-10:
Page 3-11:
Page 3-12:
Page 5-1
thru 5-27:
Page 6-1:
Page 6-la:
Page 6-lb:
• •
Since wells C-9C, C-12C, and C-15C are all cluster
wells,, shouldn't the deep po~tions of all 3 be
grouted to 80 feet to prevent communicati.on with the
adjacent intermediate wells installed to 10 feet? If
not, why?
Secti.on 3.0, Tables 3-1, 3-2, 3-3A, 3-38, 3-5. (See
comments under QAPP, Page 2-2 thru 2-10).
Please provide rationale for non-containment of water
from wells C-17, C-18, C-19, C-15, C-20, C-21, C-22
as opposed to containment of water from other
off-site wells. The purge water from all the wells
should be contained and sampled prior to disposal to
ensure that contaminated purge water is not being
released into the environment.
In the last paragraph, please explain what is meant
by 11 concurrent11 •
Under "Geochemical Analysis of Groundwater Sample",
fifty wells will be included in the analyses listed.
However, in the Work Plan p 5-16, this number in 44.
Please correct.
(See QAPP comments p. 5-1 thru 5-27.)
In the first paragraph, reference is made to cleaning
procedures elaborated in Section 5.6.1. This
section addresses only bottles for groundwater
samples.
Please site source documents for preservatives,
containers, and cleaning procedures listed in Table
6-lA.
Please site source document for holding times listed
in Table 6-lB.
Ms. Benoy
2-9-90
Page 5
• •
\'le appreciate this opportunity to offer comments and look forward to
continued jnvol.vement with RI/FS activities. Please contact me at ( 919)
733-2801 il' you have any question concerning these comments.
cc: Lee Crosby
LC/PD/db/Koppers.doc
Sincerely,
Pat DeRosa, Environmental Chemist
Superfund Section
Solid Waste Management Division