NCD003200383_19921217_Koppers Co. Inc._FBRCERCLA FS_Remediation Investigation Feasibility Study Work Plan 1989 - 1992-OCR

• •
BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219
Ms. Barbara Benoy
Remedial Project Manager
NC/SC Site Management Unit
Superfund Branch
Waste Management Division
December 17, 1992
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Re: Koppers Superfund Site
Morrisville, North Carolina
Dear Barbara:
The purpose of this letter is to inform you of activities undertaken by Beazer East, Inc.
with regard to both permanent access to Beazer property and surface run-off
improvements at the Koppers Superfund Site, Morrisville, NC. A~ you recall, in order to
conduct the RI/FS activities, we negotiated a temporary access agref:ment with Unit
Structures, Inc. (USI), since the only access to Beazer's property was by way ofUSI's
roadways. As part of the settlement of USI's lawsuit in 1992, Bea~er obtained the right
to acquire additional acreage which included land for an unobstructed access to the site.
We are working on finalizing the acquisition of this property.
While the land to be acquired incorporates some of the plant's existing roadways, we
anticipated when the settlement was negotiated that it would allow construction of a
roadway for permanent access to parts of the Beazer property ( office trailer, staging
area, etc.) not serviced by the roadways we wili acquire.
Earlier during 1992, we proceeded with the engineering design of the roadway. We now
want to build the road, and we want to obtain your concurrence before we begin with its
construction. For the design, we employed Bass, Nixon, & Kennedy, Inc. (BNK), the
consulting engineers responsible for the design of the Morrisville water system extension
which is currently providing service to the community. Additionally, Soil &
Environmental Consultants, Inc. (S&EC), of Raleigh, N.C., were selected to perform a
wetlands delineation of the property. The attached "Jurisdictional Wetland Delineation"
drawing accurately depicts the wetland boundaries at the Site. ·
Following an on-site survey by S&EC's wetlands specialist, Kevin Martin, and the U.S.
Army Corps of Engineers (COE) representative, it. was agreed that the planned road
• •
construction and surface run-off improvements would result in minimal disturbance of
··wetlands. Based on the results of the on-site survey, we have been told the Division of
Environmental Manag~1nent (DEM) will be issuing a Section 14 wetlands permit to
Beazer in January 1993 for purposes of roadway construction and surface run-off
improvements.
The proposed roadway as shown on the attached drawings and highlighted as Division I
(sheet 1 of 2 & sheet 2 of 2) will use the existing "Beazer" entrance off of Church Street.
The road continues easterly for approximately 750 feet to a location directly south of the
steel shop. At this point, the road turns approximately 90° to the southeast, parallel to
the railroad tracks, continues for approximately 480 feet (through a small area delineated
as wetlands) and crosses the existing railroad spur into the area where the Beazer office
trailer is located. The road will be constructed of compacted crushed stone with minimal
cutting and filling during construction.
Surface run-off construction work (highlighted as Division II on the enclosed drawings)
will entail improvement of the Drainage Ditch ( carrying surface run-off from USI
property) located directly west of the railroad spur. Division II construction work is not
anticipated to occur at the same time as the road construction work.
We would like to )Jroceed with the construction of the roadway during the first quarter
of 1993 and perform construction work on the drainage ditch during the second quarter
of 1993. We believe the RI Report supports that no constituents of interest were
detected in the area of the proposed road or drainage area. Accordingly, the contractor
selected to perform the work will NOT be required to receive 40-Hour Hazardous Waste
and Emergency Response Training.
The construction of the road is necessary for the continuation of environmental work at
the site. Beazer feels it should be undertaken without delay. We trust you concur.
Should you have questions or comments regarding this activity, please give me a call.
SKC/ldh
Enclosure
Very truly yours,
<;fllh-,l /X_, cjf./;; A, ; _/
Shannon K. Craig~-(J
Program Manager
cc: B. F. Giarla (w/o encl.)
R. A. Fisher (w/o encl.)
J. Mifsak -KER (w/o encl.)
1.)3.,-Nicholson -NC DEHNR (w/o encl.)
• • KEYSTONE
ENVIRONMENTAi. RESOURCES, INC.
Phone: [phone] Tech Center Dr., Monroeville, PA 15146
October 4, 1990
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch, Waste Mgt. Div.
US EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Dear Barbara:
Re: Validation of Laboratory Data
Koppers Superfund RI/FS
Fax: [phone]
Ref. No. 179280-04
Enclosed, please find two summary tables (Tables 1 and 2). Table 1 presents
information regarding those analytical results (for samples collected from the
Koppers Morrisville site during the first round of sampling), for which laboratory
data validation reports have been completed and received from A WD during the
period of September 7, 1990 (the date of the last data validation update) through
October 4, 1990. This table includes an AWD reference (job) number
corresponding to each validation report; the Keystone work order number( s)
included in each validation report; the sample types and the numbers of samples in
each validation report; the validated analyses contained within each report
(indicated by an "X" in the appropriate column under "ANALYTICAL
PARAMETERS"); and a "COMMENTS" column showing AWD comments (if any)
regarding laboratory performance and Keystone comments (if any) regarding the
validation reports.
Table 2 presents a validation status summary, as of October 4, 1990, for all first
round data (by work order number) submitted to A WD. The Keystone work order
numbers are listed in the left-hand column by date of submission to A WD. The
table shows the type of data (i.e., Non-CLP, CLP, inorganics, dioxins, etc.) within
each work order; the date the laboratory data in each work order was submitted to
A WD; and the date the validation report for each work order was completed by
A WD. Please note that Table 2 shows that 46% of the data submitted for validation
has been completed as of October 4, 1990. A WD has been notified of the Agency's
requested completion date of October 31, 1990 for all validation procedures, per
your letter to Shannon Craig, dated September 26, 1990.
In addition to the two attached summary tables, please find enclosed, a copy of each
data validation report, received from A WD durmg the period of September 7, 1990
through October 4, 1990.
Ms. Barbara Benoy.
US EPA Region IV • October 4, 1990
Page 2
This information is being submitted for your review as part of the Monthly Progress
Report #9, for September 1990. Copies have also been sent to Mary Jane Rigatti at
Dynarnac, Wade Knight at the ESD laboratory in Athens and Pat DeRosa at the
N.C. Department of Human Resources (NCDHR). Future validation report
updates, similar to the enclosed, will also be submitted for your review as the
remaining validation reports are completed and received from A WD.
Please note that you will be receiving a second coly of the September Progress
Report and all relevant information, via certified mai early next week.
If you require additional information, please call me at [phone] or John
Mitsak at [phone]. Thank you for your attention to this matter.
'5 regards, ~j
ft--1:;///A(~
Patrick B. Moroney
Risk Analyst
PBM:rb pm-3
cc: Shannon Craig -Beazer
Wade Knight -ESD,Athens
Mary Jane Rigatti -Dynamac
Pat DeRosa -NCDHR
John Mitsak -Keystone
Jim Zubrow -Keystone
AWDREF.NO. NO. OF SAMl'I...ES
(DATE USED [f NO KEYSTI>NB AND SAMPLE TYPE
REF. NO. GIVEN) /wotUC OltlEl(S lN A WD REPOI.T (I )(l) IPI!
PGH-90-DAL-326 M9D-04.109 10 SOlL
M90---04.107 "son.
M9D-04.92 19 SOlL
PGH-90-TMJ-330 M9o-o6.10 SOW: IOFW X
PGH-90-TMJ-334 M90-0-'.111 3 OW: 25 SED: 20 SOIL X
I SP; I CEM; 2 BENT
PGH-90-TMJ-340 M90-06.95 6GW
PGH-90-TMJ-340 M90-06.9 24 SOIL; 28 SEO X
PGH-90-0AL-351 M9o-o6.107 4 SOIL X
PGH-90-DAL-352 M90--06.22 IOSOll.: 3 GW
NOTES:
PHEN WC
X
X
X
X
X
X
X
TABLE I
SUMMARY OF VALIDATED ANALYTICAL RESI.Jl.TS
FOR ROUND II SAMPLES
REallVED FROM AWD BEl1iEEN SEPTEMBER 7, 1990 AND OCTOBER 4, 1990
KOPl'EllS SrTE. MOIUUSVILLE. N.C.
ANALYTICAL PAR.AMlm:RS (I)
PEST/ DIS-
svoc PCB DIOX MIIT CYAN BOD coo roe TSS MIIT •SOL
X
X
X
X
X
X
X
X
X X X
(I) Tho following abbreviation k.ey may be uKd indiilCIClcing I.Dllytical F9-n.mctcr1 and ample t:n-:
IPE
PHEN
voe
svoc
PEST/PCB
MET
CYAN
lsopropyl ether -Yob.tile Orpnic Compounds
Semi.-Vob.tilo Orpnic Compound.s
Pcaicidc/Polycblorinatcd Biph::ayl
Mdal,
C,.mdc
BOD Biochmuc:al Cb.ygm Dcmu>d
COD Oacmi<;,aJ Cbygcn Demand
Analytical Pan.rneten
TOC
TSS
DIOX
DIS-MET
OSOL
ALK
SULF
Total Orpni,;: C..rboa
Total Suspended Solid•
Dio:tlm/Fun.m
Di..olYed Mc:ul, -IDC!udcl Sodium. Potau:iwn, Magnmiwn, C..kium
Pcrccm Solid,
AU.alini.ty -Includes Total, C..rboouc and Bio::arbonate Alb.linity
Solf-.
a.. Cbloride
ALK SULF a.
X X X
SampleTypea
GW °""""'_,.,
Surf--icr
Soil -
KEYSl'ONB COMMENTS REGARDING VALIDATED DATA/
AWD COMMENfS REGAR.DINO LJ.BORATOllY P£1UIOllMANai
A WD COMMENT: Laboratory blanl coaaminatioa Vlll,-
f01: 2,4-dhzdhylpb,::l:1ol 11m 2,4-diloropb:aol _,., subuaaod
aw: ol tho ml.ire -=t ol -.mplc,I. A compound duting at tho
-rdcnlioa limo u pbrnol in a laboratory bb.nk -.
5Ubtra<.1.od from tho ample resullli.
A WO COMMENT: A compound dWDg at tho am£ n:u:d.ioa limo
pbenol in a laboratory blanl -• sublfad.ed from tho ample ........
AWD COMMENT: A compound duting al tho am£ te1cm.ioalimo u
phcuol in a laboratory bb.nk -. Sllbtfad.ed fro,n tho ample -~-
N=.
AWD COMMENT: Laboratory LIIOO'l"rectly reported IPE fCfWl ol
122 ug/k.g for S-22-MP (1.5 lo 3.5 foc:t). Tbooorrec:t result
UI <122 ug/lg.
AWD COMMENT: OCDD-. dctcdcd in tho laboratory 11m field
blanu, thcrdorc, pomjVG OCOO ~ arc qualified "R •,
umdiabk. 0-:U ol respomc fadon 11m rcu.ntioa timot
could DOI. be performed bccau.a laboratory clidn'I supply n.w
data and chromatograms for tho individual ca.libn.tlom.
N-.
AWDCOMMENT, S,~n<tioo by•bomo,y, oll,4-dim<OSyl~
cco,;,cdratioa detcctod in laboratory blank, f rorn ample
00Dl;ledratiom U1 incomi.stcat with EPA methodology.
N=.
(2) Tho following is an e11&n1ple for iotcrprc:ti.ag the rolumn
depicting the an:,pi& lypel 11m number ol auipL:,. containtd
wilhin mc:b AWD validation report (Note: Number of amplea; indu
ampb, ridd duplicatai and EPA split ampler, numbeT doe.
not include trip, field or rinate blanu):
SW
SOIL
SEO
OFW
MUN
STM
Orpmc free -ieT
Municipal-. ...........
SP Smdpack
CTM Caooo<
EXAMPLE: 10 SW -ten Nrl--ier ampk,I
8 SEO -c:ighl -1imenl ampk.
BENT Bcaoaile po:,wderfpdku
• TABLE2 • VALIDATION STATUS SUMMARY
AS OF OCTOBER 4, 1990 FOR
ROUND #I DATA
KOPPERS SITE, MORRISVILLE, N.C.
KEYSTONE
WORK ORDER
NO.
(I)
M90--04. 87
M90-04.91
M90--04. 92
M90-OU07
M90--04 .109
M90--05.3
M90-05.4
M90--05.5
M90--05.14
M90--05.16
M90--05.28
M90--05.40
M90--05. 105
M90--05.106
M90--05.29
M90--05.110
M90--05.11 l
M90--06.lk
M90--06.95
M90--06.10
M90--06.37
M90--06.9
M90--06.22
M90--06.53
M90--06.153
M90--06.112
M90--06.141
M90--06.95
M90--06.78
M90--06.95
M90--06.95
M90--06.107
M90--06.142
M90--06.95
M90--07. ITT
M90--07.34
M90--06.95
M90--07.53
M90--07.63
M90--06.139
M90--06.95
M90--06.95
TABLE SUMMARY:
DATA
PACKAGE
1YPE
Non-CLP
CLP Dioxins
Organic• (3 Volume,)
Inorganic,
Non-CLP
Non-CLP
Noa-CLP
Non-CLP
Non-CLP
CLP Dioxins
Organic, (3 Volum.c1)
Inorganic•
Non-CLP
Non-CLP
Non-CLP
Noo-CLP
Noa-CLP
Noa-CLP
CLP Organic•
Inorganic•
CLP Organic•
Inorganic•
Noo-CLP
CLP Organic•
Inorg1nic1
CLP·Dioxin1
Non-CLP
Non-CLP
Non-CLP
CLP Org1nic1 (3 Volwne1)
Inorganic,
CLP Organic• (2 Volwnes)
CLP Organic• (2 Volumes)
CLP Inorganic
CLP Inorganic
CLP Dioxinl
Non-CLP
CLP Dioxin•
CLP Dioxina
Non-CLP
Noa-CLP
CLP Dioxin• (3 Volwne1)
Non-CT.P
Non-cLP
CLP Dioxin• (3 Volwne1)
Noo-CLP
Noo-CLP
Non-CLP
CLP Dioxiru (2 Volwne1)
CLP Diodn1 (2 Volwne1)
Total No. of Jobi Submitted= SO
No. of Completed Jobi H of October 4, J 99()::,: 23 (46.0%)
DATE LABORATORY
DATA PACKAGE SENT
PROM KEY5I'ONE TO
AWDTECH.
June 29, I 990
June 29, 1990
June 29. 1990
June 29. 1990
June 29, 1990
June 29, 1990
June 29. 1990
June 29, 1990
June 29, 1990
Juoc 29, 1990
June 29, 1990
Juoc 29, 1990
June 29. 1990
June 29, 1990
June 29, 1990
June 29, 1990
July 5. 1990
Julys, 1990
Julys. 1990
Julys, 1990
July 11, 1990
July 11. 1990
July 11, 1990
July 11, 1990
July 11, 1990
July II, 1990
July 20, 1990
July 20, 1990
July 20, 1990
July 27, 1990
July 27, 1990
Augud3, 1990
August 3, 1990
August 3, 1990
August 3, 1990
August 3, 1990
Augt.m 7, 1990
August 7, 1990
Augull IS, 1990
Auglllt 15, 1990
Auglllt 15, 1990
August 23, 1990
August 23, 1990
August 23, 1990
August 31, 1990
August 31. 1990
August 31, 1990
August 31, 1990
September IO, 1990
September 19, 1990
Average time between date submitted and date completed= 44. 7 day1
TABLENOTFS:
NC Not Completed a1 of October 4, 1990
--Not determined 1ince job not complete
{I) Wort. Ordcn 0eft column) arc lilted by date submitted to validaton.
DA TE OP VAUDA TION
COMPLETION BY
AWDTP.CH.
NC
NC
August 24, 1990
August 24, 1990
September 11, 1990
NC
September 11, 1990
August 1, 1990
NC
NC
August 24. 1990
August I, 1990
August 1. I 990
NC
AugUlt 1. 1990
NC
NC
August I, 1990
AugU1124, 1990
Aug\llf. 1, 1990
NC
AugUlt 24, 1990
September It, 1990
NC
August 24, I 990
September 14, 1990
September II, 1990
Augu,t 24, 1990
September 14, 1990
NC
September 14, 1990
NC
NC
August 24. 1990
NC
NC
August 24, 1990
NC
NC
September 14, 1990
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
TIME TO COMPUITE
VALIDATION REPORT
PROM SUBMISSION DA TE
(CALENDAR DAYS)
56
56
74
74
33
56
33
33
33
r,
50
r,
44
62
44
65
53
35
56
49
21
17
30
• • KEYSTONE
ENVIRONMENTAi. R[SOURCES, INC.
Phone: [phone] Tech Center Dr., Monroeville, PA 15146
September 7, 1990
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch, Waste Mgt. Div.
US EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Dear Barbara:
Fax:[phone]
Ref. No. 179280-06
Re: Summary of Received Validated Analytical Results/Status of Remaining
Dioxin Analvses
Koppers Superfund RI/FS
Enclosed, please find two sets of summary tables (Tables 1 and 2). Table 1 presents
information reiiarding those analytical results (for samples collected from the
Koppers Mornsville site during the first round of sampling) for which data
validation reports have been completed and received from A WD. This table
provides the Keystone work order numbers included in the validation reports; the
A WD reference (job) number corresponding to each validation report; the sample
types (i.e., soil, groundwater, etc.) and numbers of samples in each validation report;
the validated analyses in each report (indicated by an "X" in the appropriate column
under "ANALYTICAL PARAMETERS"); and a "COMMENTS" column showing
A WD comments regarding laboratory performance and Keystone comments
regarding the validation reports. Accompanying this table are copies of the
validation reports themselves, as received from A WD.
Table 2 presents a status summary of remaining dioxin/furan analyses as of
September 7, 1990. Included in this table are lists of samples and analyses for which
(1) reanalysis (due to saturation in a previous analysis) data is pending; and (2) no
data has been received to date.
This information is being submitted as part of Keystone's monthly progress report.
Copies have also been sent to Mary Jane Rigatti at Dynamac, Wade Knight at the
ESD laboratory in Athens and Pat DeRosa at the N.C. Department of Human
Resources. Future validation report updates, similar to the enclosed, will also be
submitted for your review each month as they are received from A WD.
• Ms. Barbara Benoy
US EPA Region IV • September 7, 1990
Page 2
Upon receipt of all remaining dioxin/furan analyses, complete data and 2378-
TCDD equivalent concentration summary tables (updated versions of those sent to
you preVJously), in addition to the laboratory data dackages for all analyses
indicated in the status summary table, will be submitte to you, Wade Knight and
Mary Jane Rigatti.
If you require additional information, please call me at [phone] or John
Mitsak at [phone]. Thank you for your attention to this matter.
Best Regards, 11
;tk// _,fr~l
Patrick B. Moroney
Risk Analyst
PBM:rb pm-3
cc: Shannon Craig -Beazer
Wade Knight -ESD,Athens
Mary Jane Rigatti -Dynamac
John Mitsak -Keystone
Jim Zubrow -Keystone
Pat DeRosa -NCDHR
AWDREF.NO. NO. OF SAMPLES
KEYSTONE (DATE USED IF N AND SAMPLE 1YPE
WORKOllDER REF. NO. GIVEN) lN AWD REPORT (1)(2) IPE PHEN voe svoc
M90-05.3 Augwt I, 1990 16 SW X X
M90-05.05 Augwt 1, 1990 9 sw: 9 son..
M90-05.I◄ Augwt I. 1990 ◄GW:JSW X X
M90--05.28 Au.gu..t I, 1990 7SW X X
M90--05.29 Au.g\Ul I, 1990 ISW;5SED
M90-05.l06 Augu.a I, 1990 6GW; I OFW X X
M90--06.37 PGH-90-DAL-309 II GW X X
M90--06.78 JGW: I OFW X X
M90--06.0◄ PGH-90-DAL-310 8SED
M90-◄.91 POtt-90-DAL-315 I son..: I OWF; I MUN:
I STM
M90--06 .11 l PGH-90-DAL-298 1 son..
M90--06.l ◄I IOFW
M90-05.05 PGH-90-TMJ-311 SSW X X
M90-05.l9 5SED X X
M90-05.IIO PGH-90-MKL-307 16 GW: l SED: l son..
M9D-04.91 PGH-90-TMJ-308 l SW: I MUN: I OFW: X X
M90-05.05 I STM: \OSOll.. X X
(I) The following abbrcvialioa kC)' may be uaxl in disc:crnicg a!l;ll.!ytical p,uamtters aDd ample typa:
!PE
PHEN
lsopropyl ctb:r -VOC Vdatilc Orpcie Compound,
SVOC Semi-Volatile Org&mC Compounds
PEST/PCB
MET
CYAN
BOD
COD
Pcatic:idcJPolychlorimlcd Bipbmyl
M<uh
Cyanide
Bio::homict.l Oxygen Demand
Chemical Oxygen Demand
Amlrtk!I Paramttcn
TOC
TSS
DIOX
DIS-MET
SSOL
ALI(
SULF
CL
TABLE 1
SUMMARY OF VALIDATED ANALYTICAL RESULTS
FOR R.OUND II SAMPLES
RECEIVED RtOM AWD AS OF SEPTEMBER 7, 1990
KOPPERS SITE, MOIUUSWLE. N.C.
ANALYTICAL PARAMETERS (I)
PESf/
PCB DIOX MET CYAN
X
X
X
X
X
X
X
X
X
X
X
Total Organk Carbori
TOW Suape:t,dcd Solid•
Dioxins
X
X
X
X
X
X
X
BOD COD
X X
X X
X X
TOC TSS
X X
X X
X X
DIS-
MIIT
X
X
•=
Di-,iw:d Mcu.h -Includes Sodium, Pol&mum, Mag.r-=iu..:n. Calcium
Perocm Solid,
Alkalinity -lacludcc Total, Carbonate and Biaorbonatc Allwinity
'"'-Chloride
AU< SULF a.
X X X
X X X
X X X
Sample Tr:pes m:: Groucd-i.a
sw sun--=
son.. Soil
SED Scdimc:nl
KEYSTONE COMMEl'fn J.EGAllDING VAUDAlE> DATA/
AWD COMMENTS REGAkDING IABOltATORY PE1FOR.MANCE
N-
N-
N=
AWO COMMENT: Su.btndioa by laboratory, ol ◄-dlloro-3-
mdhylpbc:nol ~rat.ioa (1.39 u&IL), ddoa.ed In laboratory
comrol. blaolr., from ample CODCICllln.tioos I& DOI
N=
AWD COMMENT: Su.btndiou by lt.boratory, ol l-aitropbenol
(QDl:llratioa (0.523 u.g/L), d«ectcd In laboratory coa1rol.
blank, from a.mploccw:cnlratiom b DOI. iOCOillllUdcd.
AWD COMMENT: Su.btndion by laboratory, ol l-Mcthyl-◄,6-diaitropbenol
CODOCDnotioa detec:tod In laboratory blam., from ample oonocntnotiom
ia incoaalitml with EPA irdbodology.
N-
N-
N=
N-
N=
N=
(l) The foUowicg ia an c;umple for iclcrprdicg ls eohmm
dcpiding ls ainpk typm and numbci ol ampb comaiDcd
within caeb A WD validatioc r,:pon (NOlC: Nu.mbcr ol-.mplc,I inclu.de
ample&, rdd duplalcl: ltd EPA split amplcs; iwmbcr doc.
DOI include trip, field or rinatc blam.1):
OFW
MUN
STM
Orgmic: free water
Mu.nic::ir-] _,_ EXAMPLE: 10 SW• tea surf-_, amplcs
8 SED • cigbl -'.imc:m. sampb ·--
•
•
STATUS OP
REMAINING
DATA
Data Pending Rcanalyaia for
Saturation:
No Data Received to Date:
NOTES:
•
TABLE2
STATUS OP REMAINING DIOXJN/PURAN ANALYSES
ASOP9n/90
ROUND #1 SAMPLES
KOPPERS SITE. MORRISVILLE, N.C.
SAMPLE ID COMMENTS
S-13A-FP 0-2.0 feet
S-13A-PP 2.D-4.0 feet
S-22-MP 0-0.5 foct
SS-1 0-0.5 feet
SS-2 0--0.5 feet
X-10-TP Three depth intcrvala
X-50-PL 4.0-8.0 feet
• "Recheck" indicates a recheck of a previous analy11i1
ANALYSES
OCOD (Recheck•)
OCDD (Recheck)
All analyses
All analyses
All analyses
All analysc1
All analyse•
• •
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV /,
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
MAY 3 0 1990
4WD-SFB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Shannon Craig
Beazer Materials and Services, Inc.
436 Seventh Avenue
Pittsburgh, PA 15219
RE: Koppers Site
Morrisville, North Carolina
Dear Ms. Craig:
-Ht.Gt.IV ED
JUN 5 1990
SUPERfUND SECTION
This letter is written to respond to the request to relocate some of
the offsite monitoring wells for the Koppers RI/FS. Based on the
review of the domestic well sampling results, the Agency will approve
the proposed locations with one exception. The new location of
monitoring well C-21 is acceptable; however, moving this monitoring
well will lead to a void space for the determination of the nature
and extent of contamination in the area northeast of the intersection
of Highway 54 and Watkins Road. The relocation of monitor well C-21
must be accompanied by an additional monitoring well to fill in this
·void.
Please do not hesitate to contact me at 404/347-7791 if you have any
questions. ·You may also contact Rich Muza of the Ground-water
Technology Unit to discuss any recommendations the Ground-water
Technology Unit may ·have concerning the relocation of C-21.
Sincyrely, ,. /
/3ii/4tteeXl6!;ii-cy / .·
, Yarbara H. Benoy //
Remedial Project Manager / /
! I ·.,__/
cc: Pat DeRosa, NCDEHNR _.,........
Jack Williams, Dynamac
John Mitsak, Keystone
Rich Muza, EPA-GTU
• Mid Atlantic Office
'
• KEYSTONE
ENVIRONMENTAL RF.SOURCF.S, INC.
P.O. Box 27131, Baltimore, MD 21230
ttt.CtlVEO
MAY ~ 1 l~~O
SUPERfUND SECTION
May 14, 1990
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch, Waste Management Division
USEPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Ms. Benoy:
On behalf of Beazer East and with the approval of Shannon
Craig the topics listed below are requested for
modification/clarification for the Koppers Remedial
Investigation/Feasibility study. This letter has been
prepared based on our conversation of May 8 and as a follow-
up to my letter to you of May 3rd.
QA-4-11-1
QA-4-11-2
QA-4-11-3
Sample Locations SW-16B, S-17, SW-28, S-28, and
S-27.
We wish to notify you that the above referenced
locations have been adjusted in the field to
allow for sampling beyond where the ditch is
enclosed in a concrete drainage pipe.
Sample Container Volumes.
We request that the sample volumes as stated in
the Field Sampling Plan and QAPP be reduced
since, in discusstion with the laboratories, we
discovered that less volume of sample is
required. Any change will be consistent with
Region IV's SOP.
Dechlorinization of VOA samples with Ascorbic
Acid.
We wish to clarify that a 25% Ascorbic Acid
solution will be used (2 to 3 drops per 40 ml
VOA vial) for dechlorinization. This is a
clarification of the EPA Region IV August 29,
1988 memorandum.
• •
Ms. Barbara Benoy
May 14, 1990
Page Two
QA-4-17-1
QA-4-18-1
QA-4-27-1
QA-4-27-2
QA-5-4-1
Deletion from the Target Compound List (TCL)
2-Chloroethyl Vinyl Ether.
We wish to notify you that 2-chloroethyl vinyl
ether has been deleted from EPA's Target Com-
pound List (TCL), and, accordingly request that
this compound be deleted.
Rinsate Blanks for Metals on Soil and Sediment
Sampling.
We request that metal analyses on rinsate blanks
for soil and sediment sampling be deleted due to
the natural occurrence of metals in high concen-
trations of soils and sediments.
EPA Method 9060. Total Organic Carbon (TOC)
Analysis for Sediment Sampling.
We request that the substitution of the Walkey-
black Method in place of EPA Method 9060 for TOC
analysis of sediment samples. The Walkey-Black
Method is a titrimetric method that does not
require combustion of the sample as in Method
9060. Since TOC analyzes have a low Data
Quality Objective, this change will provide
appropriate results.
8040 Analysis of the Bentonite, Grant Mix,
and Sand Pack.
We request that EPA Method 8040 be used for
analysis of PCP for the above mentioned
materials in place of Method 515 since Method
515 is for aqueous solutions. The FSP and
QAPP did not specify an analytical method for
these analyzes.
Boring X-7.
We wish to notify you that due to a waterline
in the proposed are of X-7, this boring will be
relocated to approximately 100 feet west of
boring X-9. This will also accommodate EPA's
• •
Ms. Barbara Benoy \
May 14, 1990
Page Three
concern for a boring in the western area of the land farm.
Thank you for your attention to these matters. Your timely response is anticipated. Should you wish to discuss in more detail, please contact either Jim Zubrow or Bob Smith [phone] at the Field Office or me at [phone].
Sincerely,
,Jof\Jv\, t. Al~bclk
John C. Mitsak, P.E.
Senior Project Manager
JCM/jrmm
cc: Ms. Shannon K. Craig
Ms. Pat DeRosa -NC Superfund
File
• • !J1'1il.=:D ST ATC:S EN V! RONMENT AL PROTECTlON AGENCY
R~G!Ol"l IV
3--lS COURTL1\NO STREET. N.E.
ATL,~NTA. GE:ORGiA 30365
4WD-SFB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Shannon Craig
Beazer Materials and Services, Inc.
436 Seventh Avenue
Pittsburgh, PA 15219
RE: Koppers Site
Morrisville, North Carolina
Dear Ms. Craig:
·!fl' ff:, ef ... : ~ .fJ it [J
fl ' '. J 1989.
~': ·~ :r::r-ur~n SECTION
This letter is submitted to you as conditional approval of the
Remedial Investigation and Feasibility Study (RI/FS) Work Plan for
the Koppers Superfund Site located in Morrisville, North Carolina.
Receipt of this letter constitutes the tentative approval date for
the Work Plan. As you and I have previously agreed, the FS report
preparation begins with the initial data receipt and continues
concurrently with the RI report preparation. Therefore, the proposed
date for the draft RI report submittal, January 7, 1991, is
acceptable and therefore finalized. The draft FS report should be
submitted to the Agency no later than approximately two (2) months
after the draft RI report submittal. An acceptable date for draft FS
report submittal is March 15, 1991.
Please also note that EPA approval of the RI report is not required
prior to the draft FS report submittal. Please advise me as soon as
possible if thes schedule condition cannot be agreed upon.
In addition, there are also certain criteria that have been
established and must be adhered to as the RI/FS progresses. Please
note the following:
a) After Round I, a minimum of 10% of the samples must continue
to be analyzed by CLP protocol, commonly known as the "CLP
data package", for QA/QC procedures and should be submitted
to the Agency as soon as the results become available.
b) Any change of the Phase I list of Potential Contaminants of
Concern, (PCOCs), must be specifically approved by EPA.
Work Plan approval does not constitute PCOC change approval.
c) All sampling data points must be surveyed; coordinate data
should be provided in the monthly reports when available.
d) Data generated during the RI should be reported using the
enclosed format.
• -2-•
Please do not hesitate to contact me if you have any questions
concerning this letter. As you know, I can be contacted at
404/347-7791 during business hours. I look forward to the Project
Operations Plan (POP) submittal. The POP is due to the Agency 30
days from receipt of this letter as per the Administrative Order on
Consent.
,,;s;e;;vlc~;) JS~u1-,...
Barbara H. Benoy
Remedial Project Manager
Enclosure
cc: William F. Giarla, BMS
John C. Mitsak, Keystone
vPat DeRosa, NCDHS
Lee Crosby, NCDHS
Dennis Clark, Dynamac
.. • • N/JL~l
. .,: .,
--.. ~----- --------1/ -"--~-----•• -----------, .. ---. -· --.. ---· --· --. ' . -------•~ ...... ----
North Carolina Department of Human Resources
Division of Health Services
--------P.O.-Box.209.L~ Raleigh, North.Carolina 27602-2091
==---,tl,l,ttlfmn,ee,9"6,-E;,._+l\.+.4aOTrt-tii1M11r.-, EG;,o,_,..,e,.,I1m16'n·,= .... --...-.s-..,..------==,.....--,-.,...,---'~Ro1-1aleLU: Levine, H.D., M.P--.1 L--····
David T. Flaherty, Secretary State Health Director
21 August 1989
Ms. Barbara Benoy
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Comments on the Koppers Site
RI/FS Work Plan, 2nd Draft
Dear Ms. Benoy:
The Koppers Site RI/FS Work Plan has been reviewed and the
following comments are offered:.
Page ii-iii:
Page ES-1:
Page 2-3:
Page 2-5:
·Page---2-6:
The· list of REFERENCES included in the -Draft Work
Plan has been omitted from _the· Table of Contents
and this Final Work Plan. Please include the
references.
The site was proposed for NPL listing in June
1988, not July.
In paragraph 1, it would be helpful to identify
the seven air rotary drilled monitoring· wells
(W-9 to W-15) ;--twelve piezometer installations
(M-1 to M-12), and fifteen soil borings (B-1 to
B-15) as they are labeled on Figure 2-3 and 2-4.
In paragraph 1, please reference the source
document which describes the 2 water samples ·
collected from the fire pond in 1976. Is this
data available?
In the last paragraph, please indicate by number
which wells you. are referring to as the "seven.
existing wells". sampled in 1980.
In paragraph·· 1, use consistent nomenclature when ·
referring to wells depicted in Figure 2-3.
Instead of " ( Numbers 9 to 15)" use ( W-9 to W-15)
as they appear in the figure.
Ms. ·Benoy---
page 2
B-21-89
• •
On July 24, 1980, I off-site wells and 1 on-site
wef f-. ·wet@ edttt samp.ted .. -bY-· KER .. •an□werre= NC --oi-rs-rs=---,-.,,. . ..,-,._-::_,_.,,, __ --. __ c-_ •""·""· -~-=--,
Appen_dix HJ . _ PCP was detected by both labs in 1
the on-site well east of the steel shop. ,,
On ·September ·24·, -1980·, EPA also sampled· 3
off-site wells (See Appendix HJ. No contaminants •-------~= ._ ... Y•-----•-~~-----------•
I
. . ~,
Page 2-7:
Page 2-8:
were detected.
In li_ne 2, the detection limit should be 6400
"9./kg not mg/kg .. ( See Appendix HJ.
In paragraph 1, "A series of eight supply wells
(Wl to W-8) had been installed ... ".
In paragraph 1, again use consistent nomenclature
when referring to the wells on site, i.e.
W-1, W-2, and W-3 instead of Well No.1, etc.
In paragraph 2, "Another round· of groundwater
sampling was conducted in July of 1984 ... "
Groundwater and soil sampling was also conducted
in December of 1984 (see Appendix CJ. There are
no soil sampling results listed for June of 1984
in Appendix C.
Also in paragraph 2, approximately 1100 cubic
yards of contaminated soil were removed from the
lagoon area in July 1986, however, the total
volume of contaminated material removed from the
site in July 1986 was reported as 1,250 cubic
yards (see attached-reference #lJ.
In the last paragraph, again identify the twelve
monitoring wells ( M-1 to M-12 J ·and soil bar ings
(B-1 to B-15) for easy reference to Figure 2-3
and 2-4.
It would be clearer to separate paragraph 1 into
2 paragraphs; one discussing the on-site sampling
and the second discussing the off-site sampling.
Also, there are some inaccuracies in the
information as presented.
Groundwater samples were collected by KER during
September 1986 from-the·· twelve newly installed
monitoring wells (M-1 to M-12) and also 13 of the
15 existing wells (W-1 to W-8, W-10, W-12 to
W-lSJ. These results are listed in Appendix C.
*
Ms: Benoy··-
8-21 ·89
page 3
Page 2-8:
Page·2-9:
• •
.. ·--··. ---··· ---··
4 ._;.ii ~ Iii .'r)
Ji :i ~i •. ';,.! t
\~
In addition to on·site monitoring, BM & S ;:
inict•iated .a .. domestic well--sampling. ,progi;am-of---··· ··· ·········--··-----1';,
potentially affected wells. Off-site wells were
S@tipl@d ny KER 111 septenil5er 19155, Noventber
1986 . .§.i,d January 1987. ( In December 198(i_, __ the NC
Division of Health Services, Superfund Branch,
began sampling off·site wells around this site.
In-March 1987, BM & S released the results·of its
3 rounds of . sampling. BM & S results were
questionable-due to high blanks and problems with
lab.contamination (see attached reference #2 and
"Summary of Existing Data ... " Appendix B, D) .
They were also inconsistent with .results obtained
by the State lab. Representatives of BM & S,
KER, the Wake County Health Dept. and the State
met and decided to resample immediately. At that
time, BM & S began off·site well sampling in
conjunction with the State and the Wake County
Health Dept. )
Samples were collected· by· KER· in March 1987,
November 1987, September 1988, and October 1988.
BM&. S committed to ongoing.quarterly monitoring
of selected· domestic wells· in February 1989.
Off-site domestic well results indicate that both
pentachlorophenol and isopropyl ether have been
detected approximately 4000·5000 feet from the
suspected source areas. (PCP, around 5,000' at
llH, or 121; IPE, around 4,000' at lOH).
Affected wells were located generally to the
north and northwest although the highest
concentrations of pentachlorophenol and isopropyl
ether were found less than 1000 feet northeast of
the former lagoons and Cellon treatment area. In
addition to off·site well sampling, an extensive
domestic well survey within a mile radius was
conducted during October-December 1988.
In the last paragraph, again 1250 cubic yards
total contaminated material were removed from the
site in 1986 (see attached reference #1).
In paragraph 2, the first sentence doesn't make
sense. Concerns were expressed by property
owners.
In paragraph 3 and 4, the Consent Order is
mentioned··twice and it is also unclear ·with··whom ·
the Consent Order was signed.
Ms Benoy
8-21-89'
page 4
Page 3-1:
Page 3-2:
Page 3-5:
thru 3-7:
•
·---·-------.. ·---~-.. ,,_ ------·
•
In February 1989., BM & S, in cooperation with the
----town-of--Mor.:i,isv-il-le,-agreed-to -the .. installation .... --· -----
of municipal water lines to the affected areas
atrd .. to --Ute -ex LErrsiorr of wa Ler-service Lo-affec Led
resi_d_<e_nces. BM & S and EPA Region IV entered
into negotiation concerning a Consent Order for
the construction of the water.line." An agreement
was reached--and the Order -was effective--May 15,
1989.
In line 1, the date should be 1982.
Section 3 .1.1 is misleading. There has been no
report of soil ·removal from the land treatment
area on site. Also, the excavation of soil and
contaminated material in 1986 (1250 cubic yards)
occurred in July 1986. According to the
documentation provided to the State, samples
collected 7/86 were not analyzed until 1/87 (see
attached reference #3). Note that no soil
sampling data for -7 /86 or 1/87 is reported in
Appendix C. Sampling was done in September 1986
as reported in Table 3-1. However, this was done
after excavation. Therefore, PCP was still
detected in 1986 after excavation was. complete.
Paragraph 1 and 2 could more accurately read:
"On-site studies between 1980 and 1986 located
four principal source areas: Cellon treatment
area, former lagoon area, warehouse, and the land
treatment area. Between 1980 and 1984
approximately 460 cubic yards of material were
excavated from the site. An additional 1250
cubic yards of contaminated materials were
removed from the site in July 1986,"
"During the subsequent hydrogeologic investigation
of September 1°986, however, contamination was
detected in the former lagoon area and the former
Cellon .treatment area. Figure 2-3 displays the
boring locations in these two areas. In the
former lagoon area two borings, B-9 and B-10,
were drilled ... "
In paragraph 3, exert should read excerpts.
Section 3.1.4 has many omissions and errors. A
brief chronology of domestic well sampling by
BM -&--S · and the· State· since···September 1986-is·
listed below:
Ms. Benoy --
8-21-89
page 5
• • .. t ti .,,
' ... _! ---.... -~ ··----. ..£!' I !i f
In September 1986, BM & S initiated a domestic ~
~------·well-sampl-ing-,pi,ogram---of--potBntially-af.fected---------------~ .---~
wells. Nine domestic wells were sampled by KER • i ---·f'ot BM & s 111 s0ptembet and -November 1986. -~
Samples were analyzed for IPE_and PCP using EPA f
Methods (as stated in Work Plan). A third round t
of sampling was conducted in January 1987 by KER. ~
Eight of the -previously sample wells were --------t
re sampled ( one was out of service). Samples we.re t
analyzed for-1PE ·and Pei< using EP!CMethods ( as .. --~--·-··· .. ·-·---------~
stated in Work Plan). ~ • •Ii,
In Dece~er--EJ86, NC DHS Sup·erfund-Branch sampled
6 of same off-site wells. Samples were submitted
to the State Laboratory of Public Health for
analyses. No PCP was detected but IPE was
measured in two of the wells. On March 19, 1987,
a meeting was held to review KER's three rounds
of data and the State's data. Due to high blanks
and inconsistencies .. within KER' s own data and
between KER and the State's data, it was agreed
to res ample the wells· immediately ( see attached
reference #3; also original sampling data is in
"Summary of Existing Data ... " August 1987, KER,
Appendix Band D).
(The problem with lab. contamination and high
field blanks in these 3 sampling rounds by KER
should be stated in the Work Plan. Also this
needs to
the Work
be noted in the table in Appendix C of
Plan) .
On March 20, 1987, 13 off-site wells were sampled
by NC DHS with duplicates collected by KER for BM
& S. State samples were again -submitted to the
State Laboratory of Public Health. KER samples
were submitted ·to Compuchem in RTP for analysis.
The results from samples analyzed for BM & S by
Compuchem indicated no compounds present above
reportable detection limits of 10 ug/L for EPA
Method 624, and 10 to 50 ug/L for EPA Method 625.
Results from splits taken by NC DHS and analyzed
by the State Laboratory of Public Health
indicated that IPE was found in four w_ells,
ranging from trace to 28 ug/L; PCP was detected at
trace levels in-six wells and at a concentration
of O. 21 in OS-8; all PCP values were below the
reported detection level of O. 50 ug/L. Based on
these results, NC DHS recommended that the water
from the wells surrounding the site did not
represent a significant health risk; however,
further monitoring was advised at six month
intervals.
t ·----·· .... Y:; J;
\ .. ~ .I;
"f: ·~ ~ J ·/, '1
f,
~ ~ l ¾·
1)
:j) -·,;,; l)
I
%
l 1
1 !
l '
· -----Ms: Benoy · -----------·--
8-21-89
page 6
• • ~
·~
~~ }
,. -•····~--...... 12 " ' " ' ij
~ }\
In November 1987, · after discussion with NC OHR, T, i --------------~i-t--was--decided-to-resample-selee-t--we-l-ls--and-to---------------~----
employ a blood urine analytic technique for_ PCP f
~as usea Dy cu@-state cao. rwerve---01-1-:::uce weirs · .,. .. ,. -{\' were resampled __ l;>y KE:R_ and NC OHS. _ State samples ,. ---:r were again submitted to the State Laboratory of ;.·
Public Health and BM & S samples were analyzed by , ..
----KER. Both labs-found-·no-PCP-or-rPE-in nine of f_
the wells sampled. The State Lab found PCP in t
----·------------------~~o 3 ;~~!s:~~~' s;~~; O~~~-~: -ti~~~n=a~~!:~e~:~~-:-~-------------------"~
. 05 ug/1. IPE was detected in three wells; OS-8 .l
----:-----------ai: 68 u-g/l,--Os~·12 at 20 ug/1;-a:na-cis-9, William ---, •.
Barbee residence at 13 ug/1. The KER lab found f
Page 3-7:
Page 3-10:
Page 3-lOa:
Page 3-13
Page 3-14:
PCP in the same two wells; OS-8 at 71. 2 ug/1, and ~
OS-12 at .567 ug/1. They also found IPE in the t
same three wells; OS-B had 57 ug/1, OS-12 had 23 t
ug/1, and OS-9 had 13 ug/1. The KER results from I.:
the March and November 1987 sampling rounds are f:
summarized on Table 3-5: I
In Paragraph 1, "Figure 3-lA depicts location of
off-site ... 11
In Paragraph 4, "IPE ranged from 1. 71 uq/L at
OS-27 to 150 ug/1 at 14K."
Under the Section on PCP, who is CRAVE {EPA?)?
Also, please give a reference for -the last
sentence, "If classification of PCP as a group
B-2 carcinogen ( by whom?) occurs, the EPA is
proposing a MCLG of zero and a MCL of 0.0001
mg/1."
What are the reasons for not considering some
contaminants for further evaluation in certain
media when identifying the Preliminary
Contaminants of Concern {PCOC) as shown in Table
3-9? The "E" values in this table contradict the
sampling outlined in Section 5.
In the first paragraph under ·pcDDs and PCDFs,
where in the Work Plan report is the data-to
support the sentence "Both classes of compounds
were detected in composite soils throughout the
site"? If this -data is available, please make it
------available for ·our review. · ---------
In paragraph 1, "A water and sediment system
study ... "
' r ~·
Ms. Benoy
8-21-89
page 7
• •
It would be useful to have a separate heading
---------~.!cT!2AL,!d/;.!cT~C:!cL--analyses-to .be---conducted.,------------------·· --·-··· -·-
Page 3-15: for
Page 3 18. --
Page 3-17:· ··
Page 3-18:
Page 3-19:
Page 3-20:
Page 3-21
Page 3-26:
Page 4-3:
Page 4-4:
dttder Foteiil-iai Migtation--RuabdS,., sl1ou½dt1..,,t: ~"}=be---
listed as on-site surface water and sediment
rather than "the fire pond"?
Under-Potential Human Receptors and Routes of
Exposure nearby residence should read nearby residents. .. ----------------------·· ------
Under Surface Water/Sediments, potential
inhalation· of · PC0Cs . volatilized from
surface water/sediment during remediation should
be considered an exposure pathway. If not,
reasons should be presented.
Also, under Groundwater, for consistency, point
number two should read "potential inhalation of
PC0Cs volatized from groundwater".
Under Surface Water/Sediments, potential
inhalation of PC0Cs volatilized from. surface
wai:er/sediment during remediation should be
conside_red an exposure pathway. If not, reasons
should be presented.
Potential inhalation of PC0Cs Adsorbed to Wind
blown Soil and Potential Inhalation of
Volatilized PC0Cs should be retained for both
on-site and off-site receptors.
Und~r Groundwater, note on-site groundwater uses
(i.e. drinking water, bathrooms·, cleaning
equipment) if any, and if no longer used please
note when groundwater usage ceased.
In the section entitled "Potential Ingestion of
PCOCs in Surface Water," the recreational use of
the fire pond by residential children should also
be considered. The fire pond is not secured by a
fence. Please retain this exposure pathway.
Please spell out ARARs as it is used here for the
first time.
Is method 8040 used for both water and soil?
What about the ·methods for inorganics,
What is the QAPP (please spell out) and where is
it?
Ms. Benoy
8-21-89
page 8
• •
Page 5-4b: What are the reasons for analyzing for IPE only
----------+·-n-the-f-i-rst-round--of---surface--water--sampl-ing?
Page 5-4e:
Page 5-6:
Page 5-6a:
Page 5-7:
Page 5-8a:
Page 5-8b
Page 5-9d
Also, are the samples previously collected in the
-dirt.:ii and==t1e'd:I.:tttt.s=~ .. pona sur11c1ent to wctrtatlt no
additional _S_i'l!]lpling-in thes_f ar_e_as for
PCDDs/PCDFs?
-In Table-5A-1-what·--do Low Water and Low
Soil/Sediment mean~
On line 3, what is the teepee burner area? What
was it used for? Why not sample this area· for
PCP?
Is hexane the EPA recommended solvent for field
cleaning equipment? Why not use isopropanol?
IPE should be analyzed for in the soil
samples. IPE was found in the on-site monitoring
well (M-5 )-sampled by EPA in-October 1988. There
may still be high levels of IPE in subsurface
soils.
Are there septic tanks on site which could have
received contaminated waste water and act as -a
contaminant -source?_ Please-identify the
locations of septic tanks.
Are pond sediment samples to be collected at each
1 foot interval from 0-5 ft.(Table 5-3A) or only
at 0-2.5 feet and 2.5-5 feet as stated on Page
5-8? Surface samples from each pond sampling
location should be collected in addition to
composite samples at depth since PCP is most
likely in the surface sediments.
Are drainageway sediment samples to be collected
at intervals of 0-1' and 1-2' (Table 5-3B) or
from the top 6" as stated on page 5-8? The top
6" should be collected as a surface sample where
contaminants are most likely located.
The deep wells C-15C thru C-22 are no longer
beyond the outermost affected domestic wells.
These wells will need to be relocated prior to
construction (see Figure 5-13b).
-why is C-15C grouted•-in to 80 ,-·rather· than 50'
like the other deep wells?
Why are the deep wells 6" diameter?
Ms. Benoy
8-21-89
page 9
• •
" ~------Page-5-1-2---i<ather -than-containing--the well· purge-water-in-------------~1
small lined pits beside each well, use 55 gallon
arums whlCrt can cnen oe pwnpea into--·a ••t-rlicK ·an=a
_______ _transported. Also, the purge water _from all the ... ., ....
monitoring wells should be containerized and
sampled prior to disposal to ensure that
·--··contaminated purge water is not being released
____ i_n_t_~_Jh§. ~-9_.yj.ro[!!!le~.t..:-___ _ _________ -•--
Page 5-14a
Page 5-19c
Page 5-2lc
Appendix C
Why aren't all wells on site being sampled for
IPE?
In Table 5-8, Interceptor-Trenches is misspelled?
In Table 5-10, Interceptor Trenches is
misspelled?
In the table on Domestic Well Results please note
with an asterisk and footnote that in September
1986·, November 1986, and January 1987 there were
problems. with the data as indicated in Section
2.1 and 3. 1.4
Also, the March 1987 data is not included in the
Table.
Also, the Table does not include data_ collected
by the State or EPA on domestic wells. This
should be noted in a footnote.to the table.
We appreciate this opportunity to offer comments and look
forward to conti.nued involvement with RI/FS activities. Please
contact Pat DeRosa or me at [phone] if you have any questions
concerning these comments.
Sincerely,
~OS~~
Superfund Section
Division of Solid Waste Management
Attachments
cc: Pat DeRosa
LC/PD/db/koppers.doc
····-····•• ..... _______ _
To
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•. , . ·, ,. l:
. . . --•-,•· .. .· ... ·---~ ··--·-,J::.
S. M. Tymi2.k From R. A. Fisher-
~ •·----4
}
t· .:~
0
l:ocation -K-/-l:9·2-8-----'·-----~-~~-•--.-,-···-•:;
FINAL REPORT ...
"•-sOIL REMOV·A·L·PROJECT
RALEIGH, NC
Date A.;gust' 25, 1986
GSX Services Inc. mobilized Monday, July 7, 1986
· ___ .: initiating the Raleigl:i._s()jJ _r_e\:noval project. _ The cleari_:.U.P.
-~~-n~~~tr;.:t,;d on th-ree (3) sp~;ifi2° areas: ·· ------------· ·-
Former Lagoon Area
Filter Bed Area, and
The Blowndown Pit Area.
Location of sll.bject
shown on -Figllre .1.
areas within the Raleigh Plant Site are
Excavation and _stockpiling of PCP contaminated soil from
the Lagoon .. Area comme;:iced. Tu:_esday,. __ Jll.ly · 8, 1986. ,The f.irs.t. co,.-
voy of trllcks arrived Wednesday, _Jllly 9tb. Figure IL depicts
graphically the location of old. lagoons,· e>..'i:ent and depth of ex-
cavation, and a 200 ft. x 100 ft. grid sampling network. Approx~
im.ately 1100 cll_: yds. of contaminated soil was excavated and re-
moved from the 20, 000 sq. ft. · area encompassing. the old lagoons.
The filter Bed Area contained aboll.t 50 Cll. yds. of contaminated
concrete, piping and soil. The Blowndown Pit Area consisted
o_f ·approximately 100 cu. yds. of contaminated soil.
All contaminated rn.aterial, •·totalling 1250 cu. yds. (1552 tons)
was mani.fested and transported to Pinewood Landfill,
Sou th Carolina.
Upon completion of 2.ll excavation ~nd tr2.nsport activities,
soil surface samples were collected at all three (3) subject
areas; former Lagoon P-.rea (forty-eight (~8) samples at designated
locations), F1lter Bed P.rea (ooe (1) sample), and Blowdown Pit
(one (1) sample). All sample_.:3 _were shipped to _Monroeville
---Jlll y 15, 198 6.' .
Sheet 1 of 2
·11 .. ;:; .. '' . ·' '•, '• ··:, ... ,. .._,. 1't->rt:i1:~1{r .· __ •_ ... -.. -
1:
1:
I
I.
I.
I
I
I' ' !
S.ite· restoration commenced July 16, 1 986 with the backfilling of
subject areas.· Fill dirt con..-sisted of -silt and topsoil. Due to
·previous excavations, performed in 1980 around the Cellon Tre~ting
Area and Old Lagoons, the required volume of fill dirt ,;;-as doubled.
-;
' f .~
All excavatenarea:s were· re·sto·red to grade--l·evel-·arrd··-s·e·E,dEd:----'rhe·---·,-·-------"'i ,,
enh re soi) .IJ>WPy&J ;groject w_2:_X finalized ~p-~--~o_1?pleted Julx 22 == g:
R.AF:m
Enclosures
Copies to:
M;.R. Urbassik
M::Dvprsky
D.R. ~erschner
~-R .. Campbell
File
R. A. TISHER
.. 'J
· .... --
She_et 2 of 2
~
=
~
~
*
/
/
( S-1 + ~
' \
Ueilll
EXISTING YELLS
):,;x:POS [D >IEL l S
~
Blow down
,_, ··--·-----_., Pit Area
Excavated Material from
·Blowdown Pit, Filter Bed and
Former Lagoon Areas,
D,c ME !K: Y
Fl RE PLl"#°l · ,rose ·
i
.\)./XCX
sr~IH !
; ;I
so£1£· (FCUJ I i o n J)t:J
KS!tKNCC,
.. ''.) ,:~--,~-~/,!' :~:
I
i. 436 Seventh Avenue, Suite 1940, Pittsburgh, PA 15219
Solid and Hazardous ~aste
Management Branch
Nortl1 Carolina Department
Human Resources.
P. o. Box 2091
Raleigh, NC 27602-2091
Attention: Pat DeRosa
of
Waste ManagemE r;,t• ·section
Re: Koppers Morristown Site,,
Information Request·
Dear·, Pa.t,
Enclosed is the information you requested in
letter ~hich we discussed during our visit. mation is enclosed: your December, 1986
The following infer-
l.
Letter to. Mr. Paige, ·from D. R. Kerschner, dated February 14,
1986 which discusses the soil. removal from the area of the former lagoqns.
2 ... Letter to Mr. R. A. Fisher from R. K. Garner (GSX) dated
July 24, 1986 covering the actions of GSX during the soil removal.
3. Memo to S, M. Tymiak fiom R. A. Fisher, dated August 25, 1986
titled ''Final Report, Soil Removal Project, Raleigh, NC'',
4. • Site Maps (2) showing locations of borings, monitoring wells.
5. A short history of the lagoons and their closure.
·.: 1' ••
North
:-.. Paa"e '·i'-·.: -
Carolina Dep~rt~ent'of Human Resources
January 26 ,· 1987
' 6. A letter, addressed to the families which particip~~~@~M-----~-~
---===-=s-suuT-rvey of Di i sxte oomestTc··griJundwater quality. As we dis-_ -~:
cussed durin.g_ our meeting.,--Koppers will release the res(ilts· ·-: ,
;f this investigation upon its completion.
.£
The-ana-1-ysis of the so·il samples-·-taken -cTuring the soil removal are .J
currently _:i_n_~p_r_Qgress_._ .However , __ due--to-the large number of ana·l::{ses..'::=:~c-c:.·:::.~-'-··--l
·of.-:-thics-:type in our· ·1·aboratory, I ~ao-·n_ot foresee i;-eceiving the results -j
until latEc February .. __ They will ... be---f0-1:war.ded to your office wh·en r~r·e·:.. ceive them; -· . ·
Please feel free to call me at this office if you have any questions
regarding this submitt~l or our activities at the site.
MMS/wl
Enclosures
cc: J. Blunden
J. Campbell
M. Dvorsky
C. Beck
. C. Cramer
155500 ,
Sincerely yoursi
Martin M. Schlesinger
Assistant Program Manager
Previously.Operated Properties
. ~""' ..,_ .. ~· ,: ... ,-. --• -· ... : ::1>;.
."1 6-
Location
., ·-. . ' .. . ' ..
· .. ·KEYSTO&E:;~}/\
E:-i\'JROS!-.{EKT AL R ESOURCES,"lKC.
Interoffice Correspondence
From R. D. fie~onec
Location ;-ionroeville
Subject ;;.a1ei.9h·,--Nc
(l}92c77cOOl
Date :•!arch 17,. 1987 ·
Rcleigh soil samples
?e~~achlo=o~henol as
,,.,, ► •• •
;,0)):/r:\:.'
,;:,;: ,.
cc: l•!. Schl2singer-
·5 _ Colton
B. Fisher
.-··-
collecteci-iul~ 15, 1986 have been tested for
req~ested. Results are attached.
i
..;~~~) .. ·i•'1.it!., .. •/:·
l
i!tt. :_•;,_;i\_1_:; __ :;,(_/!" ·· • . s Ce c rn ' , Mi,; ~os, ,.C ft , ; • ,' I
.,.
•._.··.· • • :' ~ _·; ;·---~ ~ c--7 "'.:::::: .--7 -~ ~ ~ --~--:_:·_'_:: ___ -_-.·-._.·.:-:-,•,_~ • .' __ :._~~---·_,-. __ ,;·,· .. ,·'._~.--,\ __ · __ ,.-_.·: ·~ - - -~ :.·_-_ -~ ·:,1 :;r • · ·:/ . ,.·-;%~</.··~
PRO~UCE~-ON 03/17/87 AT 09 50 ::;-;:~Pil
11
SAMPLE_# S_OURCE ----------------
-87.Q)0142·-'. A-.8
B7010143 B-7··
~-g70·10144-··C-3--
fi B7010145 C-6
:;-870.101 46 0-4
E-8
I.
"'~"'''· :c_,,.L-._..,,.1~.
-------~--------------===---------~
OESCRIPT --------------------
SO I LS
::)QJ_L6 -
SO I LS
SOILS
· ···S0·H=S---
OAT-COL DATE-REC
----------------
:~ ,,
~ • -'.~ ·-1 07/15/86 01/l3/87
07/15/86 01/13/B7
o 7 1 1 5 , 8 6 · 0·1 ,-1 3·T§i""1r· ··"'••s.··ee·•,;;··;,;··;a··.,··ae•aa,· """==.,;
07/15/86 0.1.!.i.31.87
07/15/86 01/13/87
07/15/86 01/13/87
LE 1: SUM'"1ARY OF ORGANIC COMPOUNDS
~~~u~=~~~~=~=~~~~u•~~~=~~~~~========~~ ~--. -
,, ,RSL T. LNE
PRODUCED ::ON
SOURCE
0.3/17/87 AT 09:53·.'·
---=-=--------=--====--------
MPLE # -------------------------------------------------------------', :r,AQ;!LOROPHENOL ( EPA METHOD 8040)
·0\0-142 -:Peri C dCt 1 IV f--op1.1c1 .. 10 .. 1 .1.".:Urn
309000 ,.·o1'◊·~1 43 1Pent_achloroph_~_n_ol
6i0144 p~ntacn1oropnenol
\;1·0145 ·pentac111orooneno1
·'o'10146 'p-entacn 1orop11er101-.
:1.·).~-1.4·1~. --~P.e_ntach l_?_r_~-~~t-~~~<?.
.·: .. .. a r.e ... ,_epo,r-t ed.
1670
165000
4020
136000
···aoove
\;;dent
·resu ,1,t s,
·ffcations are from retention
.,-:;_:·;;.:.· ~---~ _:_~/~-:
,·;._•·
.·'c ~ '.
,-
-·,·
',..-~,-·
. -:-·--· >•-,
-~---·
A 8
B 7
C-3-
c-6·
_D _:-,i
-E-8
lr1_: . .-._, .. __ ,._·_1,:J;,~_i.\.:.~.,¥,._:-._, : _· _ . ~ ... · · /. ·.·· -,.·:.,,:t': :--. l
~,;0 .,_-'c.y•<i-,V"':; . -. . · • FORM.c,R :~~GQ,?~''./1,R-.;·;: . , <•, · , .·, :;_;,,,,.,i,•'·'·'' .. ,,,. j w "'!:il:'.';.f., i:. > .· •.. . .. ·.•· · .. ... > . / \.'if''.. • . ·· . · , •,ll; r,.~
1
r~;::~
?'/ LOCATIO,~ (48 SAMPL:SS) j
0:~ 1
f:; .. ·· ...,, _ .... , ... ,:--,-----~..,...,.,..,.;,,._=~-~~.....;..,~,.,,...,,,,,,,,,.,_.===ae=..,,,.,,..,-.,,====----··-~ .. c.,
0
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0
------
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. OUTLINE OF OLI
LAGOON
-----•--·· ·------
?. . l,. FISHER
8-18-36
F,r, TT
-.. ·-__,__ _
436 Seventh Avenue, Suite 1940, Piitsburgh. PA 15219
March 5, 1987'
N.C. Department of Human Res·ources
Division of Health Services
P; 0. Box 2091
Raleigt,, __ _N.C_~ ___ 27602 _______________ . ______ _
____ .. _ -~ ··---'-ATTN:
----· -· .
Dear Ms. DeRosa:
Keystone-Environmental Resources has. bien contracted by Koppers to
conduct the environmerital ·affairs associated.with its former
Morrisville,_N.C. Facility. In conjunction v1ith the sale of this
property to Unit Structures Inc., an environmental base-1 ine study was
conducted, This included a survey of :he off-site groundwater used for
h0~an consumption.
The off-site survey consisted of three.rounds of samples, taken from
,,;~e ~:-i'.'?.':e 1·!:>.ter \·!ells. The firs.t rou.ndC:was sampled on October 24,
lS36··, and v1as analyzed by the Keysto·n·e ·Environmental Resources
Laboratory in Monroeville, Pa. ·The-~nalysis included both. conventional·
w2ter quality parameters, and volatile orcganics. The latter was done
_using gas chromatography (GC).
A-second round of iamples were taken-on ·Ntivember 20, 1986. Duplicate
samples v1ere analyzed by the Monroeville Lab and by Spectrix
Laboratory in· Houston, Texas. _The Houston laboratory utilized GC/MS
. (gas -chromatography/mass spectrophotoi~try) for organic analysis. The
. ,-Monroeville Lab used a modified procedufe in the extraction step prior
· to GC. a'rialysis,· using four:. liters o.(·\'amp]e instead of the normal one
liter. A Koppers' method.of analysis for· pentachlorophenol was also
run in addition to the standard GC method.
lhe third round of sampling was conducted on January 14, 1987. The
samples were split between the Monroeville and Houston Laboratories,
and analyzed like the samples from round two. That is, 4L of sample
1;ere extracted for organic analysis inste_ad of the normal 1 L.
Both gas chromatography .(GC) and gas chromatography/mass
spectrophotometry (GC/MS) are accepted methods of_ organic analysis
, which can dete_ct contamination at .the ug/_l leve_l (parts. per bil.lion).
· Of the two methods, GC normally can detect organic compounds at lower
. concentration levels, but does not positively identify the compound.
· GC/MS provides a more positive identification of the compound but at a
slightly higher level of detection.
I
I
I;
1:
I
-:
'
·: I
.. :_~?.' ..... --·-;..~ . ;:..,:_ '
This.difference jn lower detection levels, and the actual
conci:,ntrations found, present some problems in the 9iscussion_of ___________ __
·contamination liivels. It appears inappropriate to state a definite
concentration of a compound when the contamination levels are so low.
C_onse9uently we,wi_l1_gresentthe:ra~,~~-s of contam~nat_ion levels; no.t.ing:
tna'rin eacli case, at least one rouna of sampling exn161tea no """"~"",.
detectable contamination. l
Well 0S-8 (Shiloh Baptist Church)
Pentachlorophenol
Isopropylether
\·Jell_ 0S-9 (\·Jilliam Barber)
I sopropyl ether
8.8 to 28.8 ppb
(Avg. Detected 19.4 ppb)
26 to 85.5 ppb
(Avg. Detected 57.5 ppb)
13.3 to i7 .5 ppb
(Avg. Detected .15.4 ppb)
,·
Please note that the average values do not include several "Not
Detected'' analytical results. I
The constituents were found at low levels and not consistently
detected in repeat sampling .. The levels measured of these chemicals
,. are not associated with ~dverse:health effects.· The highest
•Goncentrations found, 28 .ppb .pentachl orophenol, and 85 ppli
·isopropylether, are not considered dangerous_ to the health of
individuals using the water·on a daily basis for routine activities,.
i.e._, drinking, cooking, bathing, and laundry. Regulatory standards
. have not been promulgated for either chemical in drinking water;
however, the U.S. EPA has issued a lifetime health advisory guideline
of 220 ppb for pentachlorophenol in drinking water. The most
stringent guideline established for oentachlorophenol in drinking
water is that of the State of California which has set a level of 30
ppb on the basis of the taste and odor imparted by the contaminant on
·the water.
··r ·•
.-.•-,. . . ! •
;ii,~c:,;tt"})i\f,;; ... !
," ,:_':. . . . :---· .. .-, •
I.
l-·~---
1::-
1 ·
I
I
I
I
I
I
,,,-:, .
.. >_1.
We have included the analjtical res~lts
for your inspection. These include the
of custody docu·ments·are available upon
"
from all the
QA/QC data.
request.
sampling rounds
The sa~ple chain
We are looking forward to discussing this information with you next
week." Please cal I if you have any-questions co11CetW'i'1'fg""·t°h'1-s~cra·ta~"'·"'i""'~====~=-=•1 ' '
-····--··--···
Si ncererf·youYs,
Martin M. Schlesinger, Assistant Program
Manager
Previously Operated Properties
I'-, \ I "::> __[_ ( .
CJ' ti ) )cb½,{ r;}--
j _ H. Butala,:O.A.B.T.
Manager, Toxicology and Product Registration,
i'.opp2rs Company, Inc.
j
-j . J
... ·1
l l
'\
I
I
i
I
•
I . -
; .·~ , .,
. '"lie
. ,
Page 4
' ·:Jtf ,0:'ci
ANALYTICAL INTERPRETATION
(
l ' ' .~ ( Wells OS-1 to OS-4 ~
-~ ~ RQ.,\!f}.i,,.#J ~-~="'''-..~,~~T.h!.Se""2.am.r.Jes-1ie.r~ filtered in a ro~m w~_j_01;'-======'=""=""".....,,.,; -contain·ecC .. sawdust contaminateo with Pentachloropli'enol. J.·
;•:•.i,,;L
Route #2 -
Wel 1 0S-5
Because PCP was not found in the other samples these are to
be dfsregarded. . .
I:;, r-' r~,._ rJ ,,; r,!, /. ,\{. ----·----· --'\. .,.: ··-· . . . -• -----• The (Penta)contamination found in Wells 0.5-1 to
_-;.:.5 ·::,;~Oi:A}iere be 1 ow th~-~ CO_T}_~en_t_ra_!:_ iQD~=j_Q_--,both ....
·--_the field and trip blinki and are therefore to be
·di'scountecL·--·-·----,-· --------·--
The only constituent identified was PCP in round #3 6y the Monroeville
Lab at 0.6 ppb, using GC. However, the Houston.Laboratory did not
find the compound at a higher detection limit. 3ecause this trace
level was found only once, this figure should be discounted.
l·iel 1. 0S-6
Unfortunat~lY~ the third sample rciund was destroyed in shipment.
However; only a trace level of !PE \-1as found by one lab during round
#2. Bas·ed on the lo.w level of !PE (1.46 ppb) and the lack of
.confirmation, this figure should be discounted .
i·lel 1 OS-7
A trace level (8.6 ppb) of PCP was found via GC by the Monroeville
Laboratory during the·third round, However, the same laboratory did
:not. find PCP using the more serisitive Koppers' method, nor was PCP_
found by the Houston Lab:using GC/MS. Based on the level of
contamination and the lack of confirmation in other rounds, this
figure should be discounted.
\,ell 0S-8
Pentachlorophenol was found at trace levels (8.82-28.8), and confirmed
by GC/MS in two rounds of sampling. Additionally, !PE was found at
26-85.~ ppb levels. Three phenolic compounds were identified in only
.one_of the samples, but their .. presence was not confirmed. ________ _
;
· ... -.-
~Jell 05-9 ..
1sopropylether was found in
GC/MS. Concentrations were
two samples, but not
13.3 and 17 .5 ppb.
confirmed by the
' i
' ' f :i I ,I !, ,!
• l 1 l l ' 1
1
•
North Carolina Department of Human Resources
Division of Health Services
P.O. llox 2091 • Ru!~igl·:, 1,;01·i.h Carolina 27602~2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
Ms. Barbara Benoy
Remedial Project Manager
10 April 1989
us Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
SUBJECT: Comments on the Koppers
RI/FS Workplan
Dear Ms. Benoy:
State Health Director
We have received and are currently reviewing the Koppers RI/FS .workplan. we anticipate being in a position to submit comments by 21 April. If this delay will cause a problem, please contact Charlotte Varlashkin or me at [phone].
Sincerely,
~
Lee Crosb~~
Superfund Branch
LC/acr
.. . ·-... • •
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-Barbara .Benoy
20 April 1989
Ronald H. Levine, M.D., M.P.H.
State Health Director
Remedial Project Manager
US'Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Comments on the Koppers Site
RI/FS Work Plan
Dear Ms. Benoy:
The Koppers site RI/FS Work Plan has been reviewed and the
following comments are offered:
' Page ES-1:
Page 2-3:
Page 3-1:
The Executive Summary indicates that a soil
removal action was performed in 1984.
since we do not have this information, I
would appreciate being sent a copy of any
documentation of the removal.
The fourth paragraph states that shallow
groundwater flow directions are depicted in
Figure 2-lA. No flow directions are
indicated in this figure.
The second paragraph indicates 1,600 cubic
yards· of material was removed from the
source areas between 1980 and 1984. Our
records show that 460 cubic yards were
removed between 1980 and 1984, and 1,710
cubic yards between 1980 and 1986. Also,
the maximum PCP soil concentration was
found at a depth of 4.5-6.0 ft. at BH9.
•
Ms. Barbara Benoy
20 April 1989
Page 2
Page 3-2:
Page 3-5:
Page 3-6:
Page 3-7:
Page 3-7c:
•
Section 3.1.2 indicates that if PCP is
detected in a trip blank, all samples
having up to 5 times the concentration PCP
in the trip blank will not be considered
positive sample results. This procedure is
not acceptable for drinking water samples
and should be re-evaluated for other
samples.
The facts in paragraphs 4 and 5 are not,
consistent with our records. The Superfund
Branch (NCDHR) did not contact Koppers
( BMS) regarding this site until December
1986. Samples were collected at 2 off-site
wells by KER for Koppers in September and
November 1986. EPA Method 624 is for
purgeable organics (volatiles) and not acid
extractables. Prior to discussion with
NCDHR, KER had already scheduled a third
round of sampling to be conducted in
January 1987. Analytical methods were
selected by KER.
The fourth paragraph states that a NC
toxicologist concluded that IPE was found
in 4 wells. The presence of IPE was
confirmed by the laboratory results, not a
toxicologist.
The fifth paragraph indicates that IPE was
only found in 2 wells. KER and NCDHR
analytical data show IPE contamination of 3
wells: OS-8, OS-12, and OS-9.
Thirteen wells showed no detectable levels
of PCP or IPE.
In October, 1988, twentv-one wells were
sampled. Nine wells from September were
resampled and twelve additional wells were
selected.
The value for IPE in well OS-6 should be
11 <1. Q Ug/1. II
•
Ms. Barbara Benoy
20 April 1989
Page 3
Page 3-10:
Page 3-lOa:
Page 3-11:
Page 3-17:
Page 3-18 to
3-21:
Page 3-19:
Page 3-20:
•
Dr. Ted Taylor of the North Carolina
Epidemiology Section {NCDHR) indicated that
the reference dose representing
non-carcinogenic toxicity for PCP is O. 03
mg/kg/day. In January, 1989, EPA set a
lifetime health advisory level for PCP at
200 ug/1. Also PCP has. tentative
classification as a B2 carcinogen while
undergoing agency review.
What are the reasons for not considering
some contaminants in certain media when
identifying the Preliminary Contaminants of
Concern (PCOC)?
Paragraph 5 only indicates that PCP has
been detected in surface water and soils.
PCP has also been detected in groundwater
and sediment.
Potential inhalation of PCOCs volatilized
from surface water/sediment during
remediation should be considered an
exposure pathway. If not, reasons should
be presented.
On-site workers at Unit Structures Inc.
should be considered receptors for all of
the pathways except the "Potential
Ingestion of Biota that have Bioaccumulated
PCOCs" pathway.
The "Potential Incidental Dermal Contact
with PCOCs in Soil" should be retained with
the other pathways for evaluation in the
final PHEA.
In the section entitled "Potential
Ingestion of PCOCs in Surface Water,'' the
recreational use of the fire pond by
residential children should also be
considered. The fire pond is not secured
by a fence.
•
Ms. Barbara Benoy
20 April 1989
Page 4
Page 3-21:
Page 4-4c:
Page 5-3:
Page 5-4a:
Page 5-4c:
Page 5-5:
•
Dermal contact with PCOCs in surface water
(Medlin Pond or the fire pond) by
residential children should also be
retained as an exposure pathway for
evaluation in the Final PHEA.
Why are the PCDD/PCDF compounds listed on
page 3-5a not the same as those on page
4-4c? Does the analytical method used in
October, 1988, differ from Method 8280
proposed for the RI samples? If so, what
are the reasons for selecting a different
method?
Samples from the drainage ditch on the east
side of the site have shown contamination
in the past. This ditch should probably be
included in the surface water sampling.
All other ditches draining the site should
also be investigated.
What are the reasons for analyzing for IPE
only in the first round of surface water
sampling and not analyzing for PCDDs and
PCDFs?
A survey to locate septic tanks and buried
pipes and lines could provide information
on conduits for surface water drainage and
shallow groundwater flow.
What is the "teepee burner area?" What was
burnt? It may be necessary to sample for
PCDDs and PCDFs in this location.
What ''physical indications of IPE or PCP''
will be used to determine how many borings
are necessary and at what depths samples
will be collected? One sample at each
boring is inadequate to define the vertical
extent of contamination. Since only 1 or 2
samples were collected from previous
borings (page 23), large gaps exist between
sample intervals. More information should
be obtained through more continuous
sampling of soil borings. Also, these
samples should be analyzed for all PCOCs.
•
Ms. Barbara Benoy
20 April 1989
Page 5
Page 5-6:
Page 5-8:
Page 5-9:
Page 5-10:
•
What are the reasons for selecting Oto
1-foot and 3 to 5-feet sample intervals for
pond sediments? If actual contamination
extends to a 2-foot depth, will it be
assumed from the analytical data that only
the 0-1 foot horizon is contaminated? Why
not sample Oto 2.5 feet and 2.5 to 5 feet
or o to 2, 2 to 4, and 4 to. 6 feet or some
similar manner?
Consideration should be given to the
fact that 50 to 200 feet open intervals in
the deep wells could provide conduits for
contaminant migration to deeper areas of
the aquifer.
A large amount of purge water will have to
be removed from these wells (maybe over 300
liters per well) prior to sampling.
Containing large amounts of water is
identified as a concern on page 5-9.
Is proposed well C-9C the only deep well
from which core will be obtained and
logged? Core descriptions could provide
information on fracture and joint systems.
This information could be important in
characterizing groundwater flow.
The seventh paragraph indicates that
development will be accomplished by
removing 3 casing volumes from each well.
It should be noted that development should
continue until the water is relatively
silt-free. Purging prior to sampling will
require the removal of at least 3 casing
volumes.
What types of pumps will be used to collect
samples? Are all the parts which contact
the sample either teflon or stainless
steel? How will the lines be
decontaminated between samples? What
quality control checks will be used to
recognize cross-contamination between
samples?
I' •' ... •
Ms. Barbara Benoy
20 April 1989
Page 6
Page 5-l0c:
Page 5-16b:
Section 5.0:
Section 5.0:
•
It is not clear from Table 5-5 which
samples will be analyzed for which
parameters. All groundwater samples should
be analyzed for all PCOCs.
Pages 5-16a and 5-16b are the same. Is
some additional informatio11 missing from
Table 5-9 due to this error?
Continued testing of drinking water wells
should be addressed in the RI.
Have complete GC/MS volatile and
semi-volatile organic scans ever been
performed on any on-site soils or
groundwater?
We appreciate this opportunity to offer comments and look
forward to continued involvement with RI/FS activities. Please
contact me at {919) 733-2801 if you have any questions
concerning these comments.
CV/acr
Sincerely,
~-J~1wvi-
Charlotte Varlashkin, P.G.
Superfund Branch
• •
M.!.Y 11 1 1998
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