NCD003200383_19930824_Koppers Co. Inc._SERB C_Treatability Study 1991 - 1993-OCR

August 24, 1993
TO: I Curt Fehn\ EPA Region IV
Patrick Watters -NC Superfund P~~cSth,...,. FROM: . . I. . . SUBJECT: Air Quality Regulations for the Koppers Site
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Attached are portions of the regulations relevant to the Air
Quality concerns for the Koppers BCD treatability study. The
regulatory references quoted to me by the Air Quality Section are:
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15A NCAC 2H!.0600 This section (specifically .0601)
establishes that the treatability study cannot be exempted
from meeting th'.e requirements. Section . 0610 establishes
toxic air pollutant limits for sources. I
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15A NCAC 2D\0500 This section (specifically .0515)
establishes part'iculate. emission limits.
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-15A NCAC 2D. ~100 This section establishes the ambient
(beyond properti boundary) toxic air pollutant limits for
various compounds.
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'.' EHNR -EN\JRONME,\'TAf.-MAN.•1GEMENT TI SA: 02H . 0600
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I • • SECTION .0600 -AIR QUALITY PER!>IlTS
I I .0601 PURPOSE M'D SCOPE
(a) The following ·sources o~ activities are not likely to contravene any applicable ambient air quality or emission control standard, and '
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therefore, are not required to obtain a permit:
(l) air conditioning or comfort ventilation systems which do not transport, remove, or exhaust product I or byproduct to the atmosphere;
.:,\.,mbustion sources kerving heating systems which provide comfort heat for residences; I laboratory equipment used for chemical or physical analysis; ·
nonstationary intema
1I combustion engines and vehicles; ·
equipment which emits only nitrogen, oxygen, carbon dioxide, and/or water vapor; '
(2)
(3)
(4)
(5)
(6) maintenance or repair of ex.jsting equipment that does not result in an increase to the emissjon of
air pollutants; I
(7) replacement of existillg equipment with like equiprnen_t of same size, type, and function that does
not result in an incrk.se to the emission of air pollutants a'nd that is described by the current .
permit, including the 1application, except for characteristics that could not affect pollution control,
for example, serial nJmbers;
(8)
(9)
smudge pots for orchdrds or small outdoor heating devices to prevent freezing of plants;
fuel burning equipmdnt firing exclusively gaseous fuel with the total heat input rating of 250
million BTU per hour\ or less; · ·
(10) fuel burning equipment firing exclusively No. I or No. 2 fuel oil with the total heat input rating
of I 00 milliori BTU pbr hour or less;
(11) fuel burning equipment firing a mixture of gaseous fuel, No. 1 fuel oil or No. 2 fuel oil, in any
, . •. · proportion; with the t6tal! heat input rating of 100 million BTU per hour or less. · . (b) The owner or operator of ahy .source required to have a permit may request the Director to exempt the
source from having to have a penhit. The request shall be in writing. Along with the request, the owner or operator shall submit_.supporting (focumentation to show that ai~.quality and emission control standards will not be, nor, are likely to be, contrii.vened. If the documentation shov.'S to the satisfaction of the Director that
air quality and emission ·control dtandards will not be, nor are likely to be, contravened, a permit shall not
be required, -• \ .
(c) The owner. or operator of all sources .for which there is an ambient air quality or emission control
standard that is not exempted by Paragraph (a). or ib) of this Rule shall apply, for a permit. The owner or operator of a source required to hkve a pennit shall not begin constructing or operating the ·source if it is a I new source or modify the source if it is an existing source without first obtaining a permit.
(d) Any person who constructs Jr modifies a complex source subje,:t to Section 15A NCAC 2D .0800 shall
obtain a permit in accordance with Rules .0602 through .0609 of this Section. If the source is excepted in
Section 15A NCAC 2D .0800, a pbrmit shall not be required.
(e) Any exemption allowed by f'1'ragraph (a) or (b) of this Rule does not apply to ·sources subject to 15A
NCAC 2D .0524, .0525, or .0530. The owner or operator of these sourc<:s shall obtain a pern1it before
beginning construction or operatiori.. · I
History Note: Stnt111ory Authorit), G. S. 143-215. 3(a)(1 ); 143-215. 108; 143-215. 109;
Elf February 1, 1 R76;
.0602
Readopted Elf Jun;e 1, 1981;
· Amended Elf August 1, 1991; October 1, 1989;July 1, 1988;January 1, 1985.
DEFINITIONS
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Unless the context otherwise requires, the terms used ir. this Section shall be used as defioed in G.S. 143-213
and as follo\\'S: \
(I) "Director" means the Director of the Division of EnvironrnentaJ }..1:anagemenl. . I , (2) "Plans and Spe,:ifications"i means the completed application (AQ-22 or AQ-81) and any other
documents required· to defi.Ile the operating conditions of the air pollution source. I
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! NORTH CAROLINA ADMINISTRATIVE CODE
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02/02193 Page I
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EHNR -ENV1RONMr:MANAGEMENT • TISA: 02H .0600
(I) A fee payer with multiple pennits may arrange to consolidate the payment of annual administrative and
compliance monitoring fees intojone annual pa)'ment.
(m) H, within 30 days after, being billed, the permit holder fails to pay an annual administering and
compliance monitoring fee or fails to certify an exemption under Paragraphs (e) and (j) or (k) of this Rule,
the Director may initiate action t~ revoke the permit.
(n) In order to avoid violation1 of the statutory limit that total permit fees collected in any year not exceed ' 30 percent of the total budge! from all sources of environmental permitting and compliance programs, the
Division shall in the first half of bch stale fiscal year project revenues from all sources including fees for the
next fiscal year. If this projection sho"~ thal the statutory limit will be exceeded, rulemaking shall be
commenced in order to have aA appropriately adjusted fee schedule. which will avoid excessive revenue
collection from permit fees. \
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History Note: Statutory Authoriry G. S. I 43-215. J(a)(J ), (I a), (I b);
Ejf. August 1, I k88;
Amended Ejf. D~cember I, 1992.
I .06!0 PERMIT REQUIREl\1ENTS FOR TOXIC AJR POLLUTANTS .
(a) No person shall cause or all6w any toxic air pollutanl named in 15A NCAC 2D .1104 lo be emitted into
the atmosphere from any source ~ithout having received a permit from the commission in accordance with
the following: \ · .
(l) Sources and modifications of sources which require a pennit or pennit modification because of the
· ·· applicability of Seclion1s in Subchapter 2D of this Chapter other than Section . I 100 and which
began construction afte; April 30, 1990, shall have received a permil or permit modification lo emit
toxic air pollutants befo}e beginning constructio·n and shall be in compliance with their permit when
beginning op~rations. \
(2) The owner or operator of any incinerator subj eel to I.SA NCAC 2D . I 200 which began·
construction or was in•:operation-before October I, 1991, shall apply for a permit or a permit
. modification to emit toxic air pollutants·in accordance with the compliance schedules contained. in
15A NCAC 2D .1209. IAJI other sources at the facility with lhe incinerator shall be included, and
the owner.or operator ~f these sources shall .apply for a pennit or a permit modification to emit
toxic air .pollutants from\ these sources in ,accordance with Paragraph (b) or (c) of this Rule.
(3) Paragraph (a)(I) of this \Rule does not apply to sources whose emissions resull from cornbus1ing
only unadulterated fossil\fuels or unadullerated wood if the permit application is only for this type
of combustion source an,d if the facility has not already been permitted or applied for a pennit to
emil toxic air pollutants. I
(4) The owner or operator of any source other than sources required to have a permit under Paragraph
(a)(I) of this Rule shall have 180 days to apply for a permit or permit modification for the
emissi.ons of toxic air pollutants. after receiving written notification from the division.
' (5) When the director calls for permit applications for facilities pursuant to Paragraph (a)(4) of this
Rule, he shall call for pe/mi1 applications on the basis of standard industrial classificalions, that is,
he shall call at one time for permits for all fucililies stalev.ide lhal have lhe same four-digit standard
industrial classification cbde, except those facilities located ·in certified local air pollution control
agency areas. All sourcek, regardless of their standard industrial classificalion code and including
sources combuSting only 1unadulterated fossil fuels or unadulterated wood, at the faci°lity shall be
included in the call for permit applications.· All members of a source or facility category not
· having a standard industri:al classification code shall similarly be ·called at one time.
(6) The owner or operator a\ a source required to obtain a permit or permit modification before the
dale on which the guidelines in ISA tlCAC 2D . I 104(b) become effective shall be required to
obtain the perm ii or perm ii modification only for toxic air pollutants named in I 5A NCAC 2D
. l 104(a). However, the otvner or operator of the source will later be required in accordance \Vith
Paragraph (a)(4) of this Rile lo obtain perm ii modifications covering toxic air pollutants named in
15A NCAC 2D .l104(b).\ ' . (7) Permit calls made under this Rule shall be limited to the emissions of toxic air pollutants.
(b) The owner or operator of a s01urce who is applying for a permit or pennit modification to emit toxic
air pollutants shall:
NORTH CAROLINA ADMINISTJTTVE cooi'.
I 02/02/93
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EHNR -ENVIRONi\.4 MAJ\'AGEMENT • TJSA: 02H .0600
(I) demonstrate to the Jatisfuction of the Director through dispersion modeling that the emissions of
toxic air pollutants 1from the facility will not cause any acceptable ambient level listed in 15A
(2)
NCAC 2D .1 I 04 to be exceeded; or
demonstrate to the ~atisfaction of the commission or its delegate that the ambient concentration
beyond the premises1 (contiguous property boundary) for the subject toxic air pollutant will not . I
adversely affect human health even though the concentration is higher than the acceptable ambient
level in 15A NCAC 2D . I 104 by providing one of the following demonstrations:
(A) · the area where the\ambient concentrations are expected to exceed the acceptable ambient levels
in 15A NCAC 2D .1104 are not inhabitable or occupied for the duration of the averaging time
I of the pollutant of concern, or
(B) new toxicological d'ata that shows that the acceptable ambient level in 15A NCAC 2D .1104 for
the pollutant of con1cern is too low and the facility's ambient impact is below the level indicated
by the toxicological I data.
(c) This Paragraph shall not apply to any incinerator covered under Section 15A NCAC 2D .1200. The ·I owner or operator of any source constructed before May I, 1990, who cannot supply a demo.nstration ' described in Paragraph (b) of this Rule shall:
(I) submit a compliance\schedule acceptable to the Director that will reduce the subject toxic air
pollutant ambient coricentration within three years af1er receiving written notification from the
Director pursuant to Paragraph (a)(4) of this Rule to a level that will not exceed any acceptable
(2)
(3)
ambient level.listed inl ISA NCAC 2D .1104;
demonstrate to the sati_sfaction of the commission or its delegate that complying with the guidelines
in 15A NCAC 2D .1104 is technically infeasible (the technology necessary to reduce emissions to
a level to prevent the i/cceptable ambient levels in I 5A ·NCAC 2D . I 104 from being exceeded does
• ) I not exist ; or !
demonstrate to the satisfaction·of the commission or its delegate that complying with the guidelines
in 15A NCAC 2D .1104 would result in serious economic hardship.
(d) If the owner or operator r!iakes a demonstration lo the satisfaction of the commission or its delegate ' ' ' 'pursuant lo Paragraph (c)(2) er (3) of this Rule, the Director shall require the owner or operator of the source
to apply·.maximum-feasible control. Maximum feasible control shall be in place and operating within three
years after receiving written notification from the Director pursuant to Paragraph (a)(4) of this Rule. . .
I • (e), If the owner·or operator ofla source chooses. to make a-demonstration pursuant to Paragraph (b)(2) or
(c)(2) or (3) of this Rule, the commission or its delegate shall approve or disapprove the permit after a public
notice with an opportunity for a Jublic hearing. The public notice shall meet the requirements of Paragraph
(d) of Rule .0603 of this Section.I .Any subsequent public hearing shall meet the requirements of Paragraph
(e) of Rule .0603 of this Section except that the permit, if approved, shall not become part of the North
Carolina State Implementation Plan for Air Quality.
(f) If the owner or operator of al facility demonstrates by modeling that any toxic air pollutant emitted from
his facility contributes an incrernchtal concentration to the ambient air concentration of that pollutant beyond
his premises which is less than th6 acceptable ambient level values given in 15A NCAC 2D .1104, he does
not have to provide any further\ modeling demonstration with his permit application. However, the
commission may still require morelstringent emission levels in accordance with its analysis under 15A NCAC
2D .1107. I
(g) A permit to emit tox.ic air pollutan_ts shall not be required for:
(I) the noncommercial use bf household cleaners, household chemicals, or household fuels in private
· residences; [ , ·
(2) asbestos demolition and renovation projects that comply with I 5A NCAC 2D .0525 and that are
being done by persons adcredited by tlie Department of Environment, Health and Natural Resources
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(3)
(4)
under the Asbestos Hazard Emergency Response Act;
emissions from gasoline! dispensing facility or gasoline service station operations performed as a
part of petroleum distri\Jution to the ultimate consumer where the emissions comply with 15A
NCAC 2D .0524, .0925,, .0928, .0932 and .0933 and that receive gasoline from bulk gasoline
plants or bulk gasoline t~rminals that comply •with 15A NCAC 2D .0524, .0925, .0926, .0927,
.0932, and .0933 via tank trucks that comply with ]5A NCAC 2D .0932;
the use for agricultural \operations by a -funner of fertilizers, pesticides, or other agricultural
chemicals containing on~ or more of the compounds listed in ISA NCAC· 2D . I 104 if such
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' i NnRTTl rARnT.TNA AnMTNT.,TRATnrr: rnnr:
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EIINR -ENVTRONM.L ~fAJVAGEMENT • TISA: 02H .0600
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compounds are appli~ in accordance with agronomic practices acceptable to the North Carolina
Deparlment of Agricul,rure and the Commission;
(5) manholes and customer vents of wasteVvater collection systems;
(6) emissions of ethylene \oxide resulting from use as a sterilant in the production and subsequent
storage of medical devices or the packaging and subsequent storage of medical devices for sale
provided that the emi4ions from all new and existing sources located at the facility described in
Paragraph (d) of 15A NCAC 2D .0538 are controlled at least to the degree described in Paragraph
(d) of 15A NCAC 2D 1.0538 and the facility complies with Paragraphs (e) and (f) of 15A NCAC
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538
;f b 1k I 1· 1 · 1 d'. · · f h d h di' ff 1 ·1 (7) em1ss1ons rom u · gaso me p ants, inc u ing em1ss1ons rom t e storage an an mg o ue 01 s,
kerosenes, and jet fuelk but excluding emissions from the storage and handling of other organic
liquids, that comply vJith I 5A NCAC 2D .0524, .0925, .0926, .0932, and .0933 unless the
Director finds that a pe'rrnit to emit toxic air pollutants is required under this Ruic for a particular
bulk gasoline plant; \ . .
(8) emissions from bulk ga~oline terminals, including emissions from the storage and handling of fuel
oils, kerosenes, and jet fuels but excluding emissions from the storage and handling of other
organic liquids, that con\ply with 15A NCAC 2D .0524, .0925, .0927, .0932, and .0933 if the bulk
gasoline terminal existed before November I, 1992, unless: ' (A) the Director finds tha,t a permit to emit toxic air pollutants is required under this Rule for a
particular bulk gasoline terminal, or
(B) the owner or operator\ of the bulk gasoline terminal meets the requirements of I 5A NCAC 2D
.o927(i). I
(h) A permi! to emit toxic air po,llutants shall not be required for any facility whose actual emissions from
all sources are no .more .than the following:
(I) acetaldehyde
(2) acetic acid
(3) acrolein
(4)· acrylonitrile
(5) .ammonia'
(6) ammonium chromate
(7) ammonium dichromate
(8) aniline
(9) arsenic and inorganic arsenic\compounds
(I 0) asbestos
(II) aziridine \ ·
(12) benzene
(13) benzidine and salts
(14) benzo(a)pyrene '
( 15) benzyl chloride
( I 6) beryllium
( 17) beryllium chloride
(18) beryllium fluoride
( 19) beryllium nitrate
(20) bis-chloromethyl ether
(21) bromine
(22) 1,3-butadiene
(23) cadmium
(24) cadmium acetate
(25) cadmium bromide
(26) calcium chromate
(27) carbon disulfide
(28) carbon tetrachloride
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J\'()RTII r.i\R()LTNA ADMTNTSTRATTVF. rnm:
I
lliYr
10
0.016.
l.9xlo·•
8.1
0.0010
2.2
0.28
0.28
0.28
0.28
0.025
12
0.37
. 0.37
0.37
0.0056
460
~ I b/hr lb/15 .;,in.
1.7
0.24
0.005
0.17
0.013
0.013
0.25
0. 13
0.13
0.013
3.9
p,,.,,,.,. n
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I EHNR -E!VvIRON~TAf-MANAGEMENT
(29) chlorine !
(30) chlorobenzene \
(31) chlorofonn
(32) chloroprene I
(33) chromic acid I
(34) chromium (VI) I ' (35) cresol I
(36) p-dichlorobenzene
(37) dichlorodifluorometbane
(38) dichlorofluoromethane \
(39) di(2-ethylhexyl)phthalate
(40) dimethyl sulfate
(41) 1,4-dioxane
(42) epichlorohydrin
(43) ethyl acetate
(44) ethylened_iarnine
(45) ethylene dibromide
(46) ethylene dichloride
(47) ethylene glycol monoethyl ether
(48) ethylene oxide I
(49) ethyl mercaptan
(50) fluorides
(51) formaldehyde
(52) hexachlorocyclopentadien~
(53) hex.achlorodibenzo-p-dioxln
(54) n-hexane · . \
(55) hexane isomers except n-Hexane
(56) hydrazine \
(57) hydrogen chloride
(58) hydrogen cyanide ·
(59) . hydrogen fluoride
(60) hydrogen sulfide
(61) maleic anhydride
(62) manganese and compounds
(63) manganese cyclopentadien~l tricarbonyl I (64) manganese tetroxide I
(65) mercury, alkyl :
(66) mercury, aryl and inorgani6 compounds
(67) mercury, vapor I,
(68) methyl chlorofonn I
' (69) methylene chloride I
(70) methyl ethyl ketone I
(7 I) methyl isobutyl ketone I
(72) methyl mercaptan I
(73) nickel carbonyl I
(74) nickel metal · I
(75) nickel, soluble compounds, las nickel
(76) nickel subsulfide I
(77) nitric acid \
(78) nitrobenzene
(79) N-nitrosodimethylamine
(80) pentachlorophenol
(81) perchloroethylene
(82) phenol
(83) phosgene
I NORTH CAROLINA ADMINISTRATIVE CODE
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TISA: 02H .0600 1-------
290
0.0056
5600
27
260
1.8
0.0051
1600
0.14
3.4
13,000
02102/93
0.79
46
9.2
0.013
5200
IO
0.63
0.063
12
6.3
2.5
0.34
0.013
23
0.013
2.9
0.63
0.25
0.63
0.013
0.13
0.0013
0.013
0.013
250
78
52
0.013
0.13
0.013
1.3
0.063
0.052
0.89
0.56
36
0.64
0.48
. 0.025
0.064
0.0025
0.28
0.025
0.013
0.057
4.2
0.010
23
0.045
0.016
0.13
16
5.6
1.9
0.064
0.13
0.0064
0.24
Page IO
EHNR -EJ\'VIRONA.4 MANAGEMENT
(84) phosphine I . • _____ T_1_s_A_:_0_2H_._06_00_
(85) polychlorinated' biphenyls
(86) potassium chromate \
(87) potassium dichromate
(88) sodium chromate
(89) sodium dichromate
(90) strontium chromate
(9 I) styrene
(92) sulfuric acid
(93) tetrachlorodibenzo-p-d io~i n
(94) I, I, I ,2-tetrachloro-2,2-d,ifluoroethane
(95) I, 1,2,2-tetrachloro-1,2-difluoroethane
I (96) I, I, 1,2-tetrachloroethane
I (97) toluene
(98) toluene-2,4-diisocyanate
(99) trichloroethylene
(100) trichlorofluoromethane
(IOI) I, 1,2-trichloro-l ,2,2-trifliJoroetbane
(102) vinyl chloride 1
· (103) vinylidene chloride
(104) xylene
(I 05) zinc chromate I
5.6
0.0056
0.00020
I 100
I 100
430
4000
26
0.0056
0.013
0.013
0.013
0.013
2.7
0.25 0.025
98
0.01 I
140
2.5
57
History Note: I ' Statutory Authority G. S. l 43-215. 3(a)(l ); l 43-215. 108; l 43B-282; .1
0.008
3.6
0.001
60
4.1
Ejf. May l, 199?: · , ,
Amended E{f. December l, l 992; September l, l 992; Marci, l, l 992; October l, l 991. . I
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I NORTil C4ROLINA ADMINISTRATIVE CODE
I 02/02193 Pnr,r. l T
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EF!NR -ENVIRO.NA·~ MAll'AGEMENT • Tl SA: 02D . 0500
20,000 25.10
Any foundry existing before JaAua:ry 2, I 972, having a capacity greater than shown in the table and any ne\1..'
foundry, regardless Of size, sh!all control particulate emissions in accordance with the limits specified in
Regulation .0515 of this Sectioh.
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History Nore: Statutory Authority G. S. 143-215. 3(a)(l ); 143-215. 107(a)(5);
' £.ff February 1, 1976;
Amended £.ff April 1; 1986; January 1, 1985.
I .0515 PARTICULATES FROM MISCELLAJ\'EOUS INDUSTRIAL PROCESSES
(a) Emissions of particulate ~atter from any stack, vent, or outlet of any industrial process for which no
other emission control standardJ are applicable shall not exceed:
Process
Weight
Rate
Lb/Hr
100
200
400
600
800
1,000
1,500 ,
2;000
2,500
3,000
3,500
4,000
5,000
6,000
7,000
8,000
9,000
10,000
12,000
' AIIO\vable
Emi~sion Rate
for Particulate
~-latter
I ' Ton/Hr Ub/Hr
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1. 75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
I
0.551
0.877
1.39 ' 1.83
i.22
' 2.58 ' 3_.38
~.JO
4,76
5,-38
51_97
61.52
7!_58
s\56
. 9!49
10)4
1 il2
12.li
13.16
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Process
Weight
Rate
Lb/Hr
16,000
18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
120,000
140,000
160,000
200,000
1,000,000
2 'CXX) 'CXX)
6,000,000
Allowable
Emission Rate
for Particulate
Matter
Ton/Hr
8
9
10
15
20
25
30
35
40
45
50
60
70
80
100
500
1,000
3,000
Lb/Hr
16.5
17.9
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49. I
51.3
69.0
77.6
92.7
For process weight rates up to 60,0CX) lb/hr, allowable emission rates for particulate matter shall be calculated
by the equatio; E = 4.10 times P;to the power of0.67. For process weight rates greater than 60,000 lb/hr,
allowable emission rates for particulate matter shall be calculated by the equation E = 55.0 times P to the I
power of 0. J}. minus 40. E = all~\l.>able emission rate for particulate matter in lb/hr. P = process weight
rate in tons/hr. I . . ·
(b) Process weight per hour means the total weight of all materials introduced into any specific process that
may cause any emission of partic~late matter. Solid fuels charged are considered as part of the process
weight, but liquid and gas~us fuel~ and combustion air are not. For a cyclical or batch operation, the process
weight per hour is derived by di\jiding the total process v,:eight by the number of hours in one complete
operation from the beginning of an~' given process to the completion thereof, excluding any time during which
the equipment is idle. For a continuous operation, the process weight per hour is derived by dividing the
process weight for a typical period 1\of time by the number of hours in that typical period of time.
History Nore: Statutory Authori!)•, G. S. 143-215. 3(a)(l ); 143-215. 107(a)(5);
£.ff February 1, 1976;
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EHNR • BNVIRONM•AL\MANAGEMENT
14:18 No.003 P.01
TISA: OJD .1100
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I SECTION .1100 • CONTROL OF TOXIC AIR POLLtJrANTS I
.1101 PURPOSE \ . Thi• Soetlon 1m ·rorth the rule• for the control of to:o;lc air pollutants to protect human health. I
I History Nore: Srarwory Awhorlry G.S. 143-215.J(a)(l); 143-215.107(a)(l), (3), (4), (5): 143B-282; I .
Eff. May 1, l Slro,
.1102. APPLICABlLITY II . .. . ·. (a) The toxic air pollutant rulcs 1ln this Soctlon apply to all facilities that emit a toxic air pollutant that aro required to have permit under 151 NCAC 2H .0610. · · · (b) Sources at facllitie, ,ubject .to thls Section ,hall oomply with the requirements of this Section a, well as with any appllcablo requlremen\" In Sootlons .:05p(), .0900, and . I 200. .
History Nore: Sta1urory Authority G.S. 143-215.J(a)(l); 14J-215.107(a)(1), (3), (4), (5):
J4JB-282; I
Eff. May J, IWJ:: .
A=ndtd Eff. Dec'emher 1, 1991.
.1103 DEFINITION
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I For the purpo•c of 1h11 Section, Ibo following doftnltlon, apply:
(I) ,'Toxlc:alr pollutant' me..i,s any of.thoac.carcinogens, .chronic toxlcant., acute •>••temio. toxlcanto, .or acute.lrril1lnt1 that are listed In Rule ,1104 of this Section.
(2) "A,bestos" mean•.a.ibcstoi fibers u defined In 40 CPR 61.141.
I History Nore: .. Srarutory AuthorltyjG.S. 143-213; 143-215.3(a)(J): 1438-282;
Eff. May 1, 1990. I . . ....
. 1104 TOXIC AIR POLLUTANT GUIDELINES
(a) A facility shall not emit any of.Ibo following toxic air pollutants ln,,uch·quantitiea that may cause or oontribntc beyond the premises (coritlguou, property boundary) to any significant ambient air concentratlnn • that may adversely affect human health. In determining lhe1e significant ambient air oonOCDtratlons, tho . . . dlvlalon shall be guided by the followin2 list of aooeptabie ambient levels In mllllgrama per cubic mctcc at 77' F (25' C) and 29.92 lncbes (760 mih) of morcury pl'll81ure (except for asbeatos): .
(!)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(IO)
(11)
aeeu.ldehyde
acetio acid
acroleln
ammonl~
aniline
arsenic and Inorganic
arsenic oompound,
ubestos
fibers/ml
azirldlne
benzidine and salta •
bcnzo(a)pyreno
benzyl chloride
I Annual .. . 24-bour !-hour 1S-mlnuto '
(Can:\ inogcns) (Chronlo (Acute (Acute · · ToxiCAntJ) Systemic Irritant,)
Toxicant,)
. r, I 3~
I. 0.08
' I I ·.
2.3xl0"
'2.SxI0-11
i
I l.Sxto·•
~.3x!O·'
1
Z.1
1
0.006
NORTH CAROUNA ADMINISTJ.TIVR CODE 10/20/92 ·•rai61 ..... , . .., .. ,--:, ... •-·····. . · . .--·~= ~s!tt:'r,\ ~~,, <,t,,;.;., .. ,:,:
I
TEL;:
EHNR • ENVIRONMEf,t LAGEMBNT
(12) beryllium
(13) beryllium chloride
(14) beryllium fluoride
(15) beryllium nitrate
(16) bls-chloromethyl ether
(17) bromine .
(18) cadmium
(19) cadmium acetate
(20) cadmium bromide
(21) · carbon dlsulfido
(22) chlorine
(23) chlorobcll%cno
(24) chloroprcne
(25) crcsol
(26) · p-dlchlorobenzene ,
(27) dlchlorodlfluoromothane i
(28) dicblcirofluoromethane
(29) di(2-etbylhexyl)phthalate
(30) dlmotbyl sulfate
(31) 1,4-dloxanc
4. I xto·•
4. lxlO-'
4.lxIO-'
4.lx!O-'
3.7x!0~
5.5x10 ..
5.5xto◄
5.Sxlo◄
(32) _eplcblorobydrin B.3xtO·'
(33) ethyl _acetate
(34) ethylonedlamine
(35) ethylene dlbromldc 4.0xlo-'
(36). -ethylene dichloride ! 3.BxlO·'
(37) ethylene glycol monocthyl
. ether · I
I (38) , ~thy! mcrcaptan ,
(39) · fluorides \
(40) · fo~aldchyde I
(41) .. hexaehlorocyclopentadiene.
(42) •·hexachlorodibonzo-p-dioTJn .7 ,6x10-1
• ( 43) n·boxane !
(44)
(45)
(46)
(47)
(48)
(49)
(SO)
(51)
(52)
(53)
(54)
(55)
(56)
(57)
(58)
(59)
(60)
. (61)
(62) .
hexane Isomers except
n-hoxanc
. hydrazloo
hydrogen chloride
hydroeen cyanide
hydrogen fluoride ·
hydrogen sulfide
malelc anhydride 1
I manganese and compounde
manganese cyclopentadienyl
trlcarbonyl '
mangane&O tetroxlde
mercury, all:yl
mercury, aryl and Inorganic
compound,
mercury, vapor
methyl chloroform
methyl ethyl ketone
methyl lsobutyl ketone
methyl mercaptan
nickel carbonyl
nickel molal
0.186
0.0375
0.44
248
0.5
0.03
0.003
0.56
0.3
0.12
0.016
0.0006
0.0006
0.14
0.03
0.012
0.031
0.0006
0.0062
0.00006
0.0006
0.0006
12
3.7
2.56
0.0006
0.006
NORTH CAROLINA ADMINISTRATIVE CODE 10/J0/92
I
Ruq 23,93 ••
2.2
3.5
2.2
140
2.5
1.9
0.1
0.25
0.1
o.os
14:19 No.004 P.01
TlSA: 02D ,1100
0.2
0.9
66
. 0.15
0.01
360
.0.7
0.25
2.1
245
88.5
.:.0 ,::_'.: ', .. _,.·
·\"/lT·::>;-::;._•.
···) ·:
· i, ),rage j
. ! ....... :..:,~ .. ..,;.~-~ ... ,,, :.•~,: .
' I
)
I,
)
I
I
. • \ EHNR -ENVIRONM · -f1ANAGEMENT
(63)
(64)
(65)
(66)
(67)
(68)
(69)
(70)
(71)
(72)
(73)
(74)
(75)
(76) .
(77)
(78)
(79)
(80)
(81)
I nickel, soluble compourlds
as nickel \
2. Ix IO·' nickel subsullide \
nitric acid
nitrobenzcrie I I N-nitrosodimcthylamine\ · 5.0x10·-1 ·
pentachlorophenol '
\ phenol
phosgene I
I phosphine I polychlorinated biphenyls 8.3x!O''
I styrene
I sulfuric acid I I, I, l ,2-tetrachloro-2,2-
\ difluoroethane
I I, I ,2,2-tetrachloro-1,2-
\ difluoroethane
I, l, 1,2-tetrachloroethane \ 6.3xJO·'
toluene 'I
toluene-2,4-diisocyanate
1
1, l ,2-trichloro-1,2,2-
tri fl uoroethane
trichlorofluoromethane \
(82) vinyl chloride 3.8x!O~
0.0006
0.06
0003
0.0025
0.012
52
52
4.7
0.0005
(83) vinylidene chloride I 0. 12
•
0.5
0.025
0.95
10.6
0.1
560
TISA: 02D .Jl00
0. 13
56
0.015
' 950
(b
(8)4) fxyl
1
ene h II . . f \h . c II . .2. 7. _
11
. h .. 65 A. ac1 ity s a not emit any o t e 10 owrng toxic air po utant.s in sue quantities that may cause or contribute beyond the premises to any kignificant ambient air concentration that may adversely affect human health. In determining these signific~nt ambient air concentrations, the division shall be guided by the following list ofacceptable•ambient lcv'els ir.·milligrams per cubic meter at 77° F (25° C) and 29.92 inches I (760 mm) of mercury pressure: 1 · • I
\
Annual 24-Hour (Carcinogens) (Chronic I
(I) acrylonitrile .
(2) ammonium chromate
(3) ammonium dichromate
( 4) benzene
(5) I .3-butadiene
(6) calcium chromate
(7) carbon tetrachloride
(8) chloroform
(9) chromic acid
(I OJ chroniium (VJ)
(11) ethylene oxide
(I 2) methylene chloride
(13) perchloroethylene
(I 4) potassium chromate
(I 5) potassium dichromate
( I 6) sodium chromate
(17) sodium dichromate
(l 8) strontium chromate
(19) tetrachlorodibenzo-p-dioxin
(20) trichloroethylene
I
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\
I
I I
I
i
\
I I
I
I
J .5x!O"
l .2x!O"'
J.7xi0"'
8.3xJO·'
6.7x10·1
4.3x10·1
8.3xJO·'
2.7xIO·'
2.4x10·2
J.9x 10·1
8.3xIO·'
. 3.0x!O-"
5 .9x10·2
Toxicants)
6.2x!O"
6.2x!O"
6.2x!O"
6.2x!O"'
6.2x IO"'
6.2x!O"'
6.2x!O"
• •
August 19, 1993
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\ TO: Koppers File
I
I FROM: Patrick Watters
i SUBJECT: Record of Telephone Calls
On 8/10/93 I received a return phone call from Mr. Terry Lyons -
EPA_ Cincinnati regarding NC Superfund comments on the draft BCD
Technology Demonstration Quality Assurance Project Plan for the
Koppers NPL site. ' Mr. Lyons noted that equipment is being
mobilized for this demonstration this week (8/9-13/93). Dry run
testing is expected: during 8/16-20/93 with hot run testing
scheduled during the next two weeks (8/23/93 through 9/3/93). Up
until 8/10, the NC Superfund was under the impression that the
original starting dat.e (approximately 8/9/93) was to be delayed
until September. In '.light of this information, I _told Terry that
I should delay review of my comments until I advise Bruce Nicholson
and Jack Butler of this apparent schedule change.
'
This schedule chknge led to two conference calls (8/11 and
8/13) with EPA regarding the activities and timing of the
treatability stud_y for the Koppers site.
' ' 8/11/93 Conference Call@ 9:30 AM
I NC Superfund Attendees!
Jack Butler \
Patrick Watters
Bruce Nicholson \
Richard Lasater NC-DEM
Dr. Donald Vander Vaart NC-DEM
Rob Gelblum :
EPA Attendees
Beverly Hudson
Curt Fehn
This call was made based on the conversation with Terry Lyons on
the previous day. This call was made to express our concerns about
the scheduling and : lack of sufficient notification and
documentation given the NC Superfund Section regarding the BCD
Treatability study. We noted that NC Superfund and the Air Quality
Section had comments on:the Quality Assurance Project Plan (QAPP)
for the study and that the schedule had been established and
equipment was being mobilized before these concerns had even been
heard. We also noted that the Health and Safety Plan had not been
completed and that NC Superfund had not received this document.
I ' One specific issue noteq by Air Quality was the need to have some
perimeter type of ambient monitoring. This would provide specific l
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data to demonstrate' that contamination did not reach the site
boundary. \
We told EPA that we: would fax the NC Superfund and Air Quality
comments to Region IV and to Terry Lyons at EPA-Cincinnati. EPA
indicated that a copy of the Health & Safety Plan would be sent via
overnight mail. We a'greed to have another conference call after-we
had reviewed the H&SP. '
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8/13/93 Conference Call@ 9:30 AM
' NC Superfund Attendees
Jack Butler i
Patrick Watters i
Bruce Nicholson I
Richard Lasater -NC~DEM
I Randy McElveen 1 Ernie Fuller -NC-DEM
David Lilley
EPA Attendees
Beverly Hudson -EPA Reg. IV
Curt Fehn -EPA Reg. IV
Terry Lyons -EPA Cinn. ·
Tracy Poole -PRC
Rob Foster -PRC
Robert Hutcheson -PRC
Cindy Loney -PRC
This was a follow up to the conference ._call on the 11th to discuss
the State comments on the QAPP and the H&SP. Topics discussed
' were: I ..
-Emergency shutdown provisions. It was noted that the BCD
equipment has procedures and operational guides that provides
emergency shutdown in~tructions.
-The general schedule for the study is as follows:
Dry run testing (8/16-20)
Hot run testing (8/23-9/3)
Equipment is on I site and wiring of the equipment was in
progress. It is: expected that CP&L will have power to the
site on Monday the 16th.
It was also noted that various PCP analytical test kits were
to be evaluated during the BCD study.
-EPA stated that personnel associated with this study had been on
site at least as early; as 8/9/93.
-Site Phone Numbers: 919-460-3864; (FAX) 919-319-9180 [call other
# before transmitting·the fax]
-Cindy Loney was identified as the PRC Community Relations person
who is working with Diane Barrett.
-NC Superfund commerited that a "public availability" meeting
should be scheduled before the last week of the study. EPA
indicated that they would be providing a limited site visit for
some of the local residknts during the dry run testing. There will
still be a Community Day on 8/31 which is scheduled to start@
10:30 AM from EPA-RTP with a bus tour to the site. EPA also noted
that telephone notifications would be made to selected residents
and that a fact sheet is to be issued.
-The NC Superfund and Air Quality Sections reiterated the need for
ambient monitoring at the site boundary. A verbal commitment was
·made by EPA/PRC to provide sufficient perimeter monitoring during
operations involving co'ntaminated soils.
-Concerns were raisedi about the inherent safety of the liquid
I el e I !
"reactor". It was iJdicated that the operating temperatures of the
reactor fluids are below their relevant flash points and that there
should not be a fireior explosion concern. It was also noted that
there is no oil/water separator associated with the scrubber
system. The source1 of the scrubber water will be from tankers
filled from the city:water system.
-.The reference to an ETG "Work Plan" was explained as a short (-2
page) document that was mostly a work schedule outline.
-NC Superfund asked ,about the design of the containment pad. This
pad is a 40'x60' area with 3 1 walls
-NC Superfund expressed some dust control concerns about the
material handling procedures (i.e. manual screening/ pug mill).
-Some specific H&S concerns were discussed but we indicated that
these would be faxed to Tracy Poole (FAX# [phone]) and Curt
Fehn today (the 13th') . EPA agreed to respond to NC Superfund' s
comments on the QAPP!and the H&SP in writing.
I
8/13/93 call to HopeiTaylor by B. Nicholson
I
This call was made to notify Ms. Taylor about the treatability
study activities currently underway at the Koppers site. We
indicated to Ms. Tayl!or that we found out about this on Wednesday
(11th) and that EPA contact the community prior to the study. EPA
did not delay deployment to send out fact sheet(s) but agreed to
call key community members.
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I .! I • I August 27, 1993
I
MEMORANDUM
TO: File I
I FROM: Randy McELveen
Environmen'tal Engineer
' NC Superfund
i . RE: Koppers Company Inc. NPL Site
Morrisville, Wake County, N.C.
Overview of Pre-remedial Treatability Test
i
Bruce Nicholson1, Patrick Waters and myself arrived at the
Koppers Site around \9:30Am on August 28 and reviewed the Sarex
(Thermal Dechlorination) Unit operations. A hot run was scheduled
for today. However,ldue to delays the hot (contaminated) sample
runs were delayed unt'.il tomorrow/Saturday August 28, 1993. Sample
mixing, homogenizing ~nd containerizing of the contaminated filter
materials was underway. The sample material type, color and other
properties were also ',observed. Railroad ties were buried in this
area and were dug up\with the sample materials. Mr. Terry Lyons
and Robert Hutchuson :escorted us around the site. We questioned
Mr. Lyons about the validity of the sample type for any meaningful
results since the matei,rials being tested were not representative of
the fine grained silts and clays noted in the borings at the site.
Previous documentatioh seemed to indicate that testing of the fine
grained clay soils noted at the site was the primary purpose for
the test runs. Mr. Lyons seemed to agree or at least he did not
disagree with these fa¢ts. We left the site at approximately 11: 3 o
Am. Sampling and Unit! operations were photographed and videotaped
and will be included with this file.
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MEMORANDUM
TO:
FROM:
RE:
•
August 17, 1993
File
Randy McElveen
Environmental Engineer
NC Superfund
Koppers Company Inc. NPL Site
Morrisville, Wake County, N.C.
Overview of Pre-remedial Treatability Test
Arrived on site at approximately 10:15 Am checked in at the
front office and waited on other NC Superfund personnel. Signed in
at PRC (EPA contractor) trailer at the direction of Mr. Darrell
Hamelton then proceeded to the Thermal Dechlorination (TD) Unit.
Set-up and pre-testing of the Unit was underway. Mr. Coleman King
with ETG explained the TD Process, and showed me the proposed
sampling location, which he said was from filter material for the
wood treatment process and therefore should contain the high levels
of contamination necessary for the best test runs in the TD Unit.
We also discussed air monitoring and perimeter monitoring and
then joined Mr. Patrick Waters and Mr. Bruce Nicholson in the on-
site office trailer. Mr. Waters contacted Mr. Robert Hutchuson
with PRC by telephone at [phone] in Atlanta, Ga. about
perimeter monitoring of the air which was not yet in place as
previously agreed. Mr. Waters contacted the DEM Air Quality
personnel to discuss the absence of air monitoring at the site.
We then went to the on-site Lab trailer to observe the SITE
Program analytical comparison for the COC's being performed by PRC
lab personnel. The lab personnel stated that the SITE Lab Analysis
called TER should be completed this year. The NC Superfund
personnel left the site at approx. 12:30 Pm and returned to .the
office.
r.. , UZ.: \4P ()po2!l.S -T/\.OA vi£ I <.. I i) S 1\/ D 1/
State of North ~ollna
Department ofWlironment,
Health and Natural Resources
Division of Environmental Management
Post-It~ brand fax lransmittal mem
James B, Hunt, Jr., Governor
Jonathan B. Howes, Secretory L.J' It=. u---111 ......... r------'i A. Preston Howard, Jr,, PE., Director
August 23, 1993
ivIFMORANDUl\1
TO;
FROM:
SUBJECT: Koppers Superfund Site Cleanup
Wake County
Morrisville, North Carolina
Air Qu.aljty Concems
The Division of Environmental Manageme.nt has been contacte<l and requested to
provide con11JJents ancl guidance on Air Quality matters at the subje.ct site. Even though the
site .ls registered as a Superfund Site and is not required to obtain an Air Quality pem1it
under the. Superfund regulation, the Air Quality standards must be met during the cleanup
operations. To date, ow staff has still nor rece.ived information that iJidic;.ites that all Air
Quality standards will be met at the site, Our specific comments are addressed below:
I. Sufficient infonnation on proc.ess operating parameters and pollutant ernfasion
rates has not heen provided to date to allow completion of a.n engiJ1eering
review demonstratiJ1g compliance with all applicable Ai.r QuaJjty regulations.
2. Ambient ai.r quality monitoring at the property l.hie to evaJ.uate the PMJO
(inhalable particulate) impact on surrounding homes is needed a.s the Triassic
clay soil to be treated is very prone to dusting when handled. The site plan
addresses only ambient pollutm1t concentratioo rnon.itming on site. A detailed
off-site ambient monitoring plan should be submitted to the Air Quality
Technical Services Branch for approval prior to a.cn1al operation,
• 3. Toxic air pollmants listed i.n 15A NCAC 2H .0610 will be emitted from the
operation. An A.i.r Toxics Review is there.fore required. If potential facility-
wide emissions of a listed toxic air pollutant exceeds the tlu·eshold levels given
i.n .l5A NCAC 2H .0610, demonstration of compliance with ambient air limits
in l5A NCAC 2D , I 100 umst be provided by dispersion computer modeling.
Prior approval of a modeling protocol must be obtained.
P.O. Bo, 1◊535, Rol,.igh, North Corolina 27626-0535
An Equol Opportunity Affirmd."lve Act!oo Emp!oy8r
Telephone 919-73.'J-3.'340 FAX [phone]
, 50% recycled/ I 0% poot-con11mor pooer
• Page 2
Thank you for your August 20th telephone ca.U regarding this project. I appreciate
your attitude and assistance in attempting to secure cooperation from Environmental
Protection Agency in working with the Division of Solid Waste Management and the
Division of Environmental Management staff to .resolve these issues. If I can be of any
assistance in that effon, please call me.
If you have any questions conct:ming th.is matter, please contact Mr. Richard L1.sater
at [phone].
cc: Alan Klimek
Laura S. Butler
Ken Schuster
Richarcl Lasater
•
Environmental, Inc.
660 Sentry Parkway
Blue Bell. Pennsylvania I 94 2 2
(215/ 832-0700 • Fax [phone]
Mr. Jack Butler, P.E.
Environmental Engineering Supervisor
FIL~: \lvl'P<-2.s un.,
,(\IZA-.l.-11'/ Stvb'i'
Providing creative environmental solutions
Ktt;t\Vt.U
August 11, 1993 AUG 1 7 l:J:JJ
-;uPERFIINI' SELTION
Division of Solid Waste Management Superfund Section
North Carolina Department of Environment, Health &
Natural Resources
Post Office Box 27687
Raleigh, NC 27611-7687
Dear Jack:
I received your NPL list package today, and wanted to thank you for providing that
information. It will be very helpful in our efforts to contact companies with environmental
problems in North Carolina. As of today we do not have a firm date from the EPA for the
thermal desorption SITE demonstration at the former Koppers site in Morrisville, NC. As
soon as I learn of the date I'll get a letter off to you advising you of same.
As discussed in our conversation, I am enclosing a Statement of Qualifications on our
company which you will see after review presents a very broad scope of capabilities in the
remediation arena.
We certainly would like to be included in any State Superfund managed projects
where ETG would be working directly for the State of North Carolina.
In closing, I look forward to meeting you at the SITE demonstration and further
discussions we might have relating to work that ETG would perform for the State of North
Carolina.
enc:
Loren A. Martin
Vice President
Sales Development
\
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AUG 12 '93 13:53 IJ3EP REL,STDD,TSB 513-559-7575 (:IU: ~~ S111, P.1
u
511'2,-PRQ.PA/2Ai10..i ll J -T12J2ATA-6IL. I ST'llfJY
EPA Fax Transmittal
Jransmi tted Fronu .
Risk Reduction Eng1neer1ng Laboratory
Superfund Technology Demonstration Division
Technical Support Branch
Cincinnati, Oh1o 45268
Phone: [phone]
Fax: [phone]
DATE: pf,., /t;13 PAGES TRANSMITTED:_ .. _ _...,,__ __ _
. · ~ (Includ1ng'Covor) . . .
'• .. ' • ' TO:_, _....::J:...;,A...:..:;;..C.i.:;f::...--...;..16.:...;U::..T',:__'-:::.€.le.=·o...· __ '_, --------
LOCATION:_r/_. _e.;c___ __________ _
FAX NUMBER: (1 r 1 J · 73 3 'fl'! I
...P
FROM: 'lr:#t L.T'ON s
PHONE NUMBER: (f;'-1 .3) s-c;,f-zs'cf:J :>
L-P,fc; PtA.v, THct. i;;· A otGAUK:; fR.c;bvr7: tMT A S(l;·e,
'f teo'{')vcT, r KC!, '-''/2E:P IS <2 v'S,, SIT? Pt(q&,nf 77QN'.
1:cr1v,rr ~,tt"o,c:r 7/11:T MU'zHT A..t;;wu. St»ti if
to v ia. co ,if<...£,,e,{ s •
li/03/441'1UG 12 '93 13:54 USEP-REL,STDD,TSB 513-559-7575
July 20, 1993
Mr, T8l'T)' Lyo111
Technical Project Managtr
U.S. Environmental Protection Aaency
Office ·of Research and Developmont
26 W. Martin Luther Kina Drive
Clnclnnacl, Ohio 45268
N0,:l87
PRC
l\ r ._Subject: Conlract No. 68-C:0-0047 ·, V } ; . . . ; . ,.
!:· ?-:1~~~1~::'~~f;1~~\or the S&r~i:~M:h:oiiox SITE ~lion
Dear Mr. Lyons:
Enclosed pleue find attached one copy of the Site Preparation Actl\/ltl111 tor Ibo Saru THERM-O-
DETOX SITE Demonstration. Activities dlacuoed Include soil contamlnltlon dellnoatlon, uca\/atlon,
f~ preparation, as!embly of the Sarex THERM-0-DETOX containment p,tld, cont.lnmellt of tr.aiOd
residues generated from the process, and scheduling of sit• acdvltlN. Tiit allacbmt!M dl1oua1G1 actl\/ltlj!II
not covered In the draft quality as~ure.nc~ project i:,1-11 for the demonstration, Op«atlon of the Sa.rex
THERM-0-DETOX system will he covered In a work plan by ETO Environmental, 1'1c,, wbldl wUI bt
completed by July 26, 1993.
If you have any questions or comments concern Ina site preparation actlvitlet d\10110,d In the attacb.mellt,
please call me 11 (4~) 522-2867 .
. Sincerely,
µ,,~
Robe" Hutcheson
Proje.:t Mana1er
11nachment
cc: Beverly Hudson, EPA Region 4 R,,.-nedl.J ProJ~ Milllier
Bruce Nicholson, North Carolina Division of Solid Wa&te, Superfund Branch
Mitchell Moss, ETG Environmental Project Manager
Shannon Cral&, Bwer Erwlmnmental, Inc,
li/03/4<:AUG 1:;: '9} 13:54 USEP-EL,STDD,TSB 513-569-7676 N0,387 P.3 •
SITE PREPARATIONS ACTIVITIES
Site preparation a.ctlvltl&.~ for the Sare1 THERM•O-DETOX SITS Demp111tratlon Include 101l
contamination del lneatlon; c~cavation; f~ preparation;, a.uembly of the proc.a, equipment containmollt
pad; cont~lnment and storaae (lf tr~aied rcddues; sito utlllty and facility reqult11111enta; ltld the Cllttent
schedule fur site preparailon demonstration activities. Thl'n ltema are dlacuaaad bdow.
!. SOIL CONTAMINATION DELINEATION, EXCAVATION, AND PEED PREPARATION
Solla to be treated uMln11 the BCD toohnoloaY will be obtainlld from th• area nor1h of the fol'!llw
Cellon proce&a bulli.lln11, Surface liOII sampllni conducted durln, th, remedial lnvestlaatlon
indicated PCP C(lncentratloni iircatcr than 1,000 part por million In this aru, WI dloxlna/furans
concentrations 11re1ter than 270 part pe·r bllllon, Actlvlllea to be performod In chis area, whlell
Include contaminant dellmmtl~n, ioil exc.avatlon, and ioll feed preparation; an dlSCll.l8td below.
a.
. . ... .-, i ~
,._
Soll Coo1amlnarlon P,liaM\lon '. .
. Surface soils to he excHvaled for trsatml!!lt usln11 the Sarex THERM•O-DETOX 1ysttm
wlll be dellneati,d during the flrst week on site using tho fleld lll&lytlcal and aampHni
service provided by PRC. Th~ 1urta~e soils wlll be analyt"1 tor PCP, 2,3,7,8•
tctrachlorlnate.i.l dlhenzo-p-dloxln, 2,3,7,8-tetr&chlorlnat.ed dlbetltotvra.n, IOial dloxln.c,
and total furans. A portable aas chromaioaraph wlll be uaod l->r the acalyall,
Approxlmauly ,o 1urfHce soil sample1 wlU be collected for analyala, Tb• samples wUI
be collected from A ~rid, with samplln11 points bfi1111 a'l)atatod appro11mately 10 ftet by
IO feet from each other, The grid will be located l.n th d vicinity at' 1011 borlnp X-26 and
X-28, which w~re Ir.stalled durlni the remedial lnveatl1atlon. All110ll aamplLna loCltloiu
wlll be m11tked by a pin tlaa and clearly lde1:1tlfled with the ccrroapoDdln& aoll wnple
number. This will aid lo~tion and ldentlflCitlon durlna l'IIQltt soil oootamlnatloa
lnvestlaations to be conducted durin1 the remedial doslan,
b. Soll Excavation and Screanins
Approximately 10 to 15 10111 of soil will be excavated for treatment. The aolla wlll
excavated to an approximate depth of o,, foot below land aurface u1ln11 a t'ront eod
loader, Tho aroa of excavation will meaauro approxlmatlly 25 teec b~ l5 feet contln11ent
upon one area cvntalnlni soils contamlnated wltb high concentratlooa of PCP, dlo~IIU,
and furans. High varlablllty In surface soil contamination may requite o,;cavatlon of 10Qs
from more than one area to obtain tho nocessary volume for troatment.
The solls will be exc~vated usln1 a back.hoe and placed IDIO 55•&~1011 druma. The aoll1
will he ficreene<l manually t\1 remove soil particles lar11er than 0,5 inch prior to placement
In drum&, Drums containing acreent:d aoils will be sta1ed near dui feed preparation area,
· the location or which is undetermined at thla time,
. I
N0;387 P005/005 P.5 •
Facility requlr1m1111u for the demonstration Include a work trallu, baduoom, and pbolM Ml'Vlc.t,
The work trailer currently on site Is !Mina ptovldtd by Bwtr But, Ille, tbr 1114 durlnJ the
demonstration. Portable toilets wlll he brou1ht to th• sit, If the Btu.-trailer do111 not oontaln
tnllet facilitl~. Phone service will be provided by portable telepho1111 bro111bt to the site.
Electrical and water utility service and and portable toll et facUltlo. pro'l'lded for the domolllttatiOtl
will be billed to. PRC Environmental Manaaijment, Inc, for pa)'l'llent un<iet BPA Wort
Assl11nment No. 0-1 !, as Kpecifled ln the work plan for the project,
5. SCHEDULE
rl
(
The demonstration currently Is scheduled to start durlna the week ot Au1111t 2, 1993 and bo
oompleted by Au&ult 25, 1993, ·
• .. . . . : .:· i;;' . . . . . .
Activities scheduled fn~ the week of AuguRt 2 Include mobUlzatloa of equipment to ·the site,
as8embly of the prefabricated containment pad, and delineation, e,;~availon, 1111d mlxln1 ot foed soils, · · · · ·
Activltle& scheduled for the w~k of AuiUBt 9 include shake-down teatlnc of the Sarei. THERM•
0-DETOX system in preparation for treatment of contaminated soU•, pteparatlona tor th• alt
quality te-~ting of the process equipment by Radian Corporation, a.od 11!6 Vlsltnn' D&y actlvltlea.
Actlvitle3 scheduled for the week of Auau,t 16 include demonstration 111d leltlna ot the SiNllt
THERM-Q.DETOX system through the processlni of contamlnattd 1001,
Activities scheduled for the week of Aui',lst 23 Include demobUlnelon of d6mo11&tr11tlon
&qulpm~nt and personnel. ·
?\/03/4AUG 12 ''33 13:55 USEP-EL,STDD,TSB 513-569-7676 NO,JS7 • P004/005 · P.4
feed PlOMrNlon
Soil$ to be treated need. to b, prepartl(J prior to food In& Into the Sann THEJlM·O.
DETOX system processini •qulpmont. Feed preparation wlll co111lai of ntlxl!IJ aollt with
sodium bicarbonate powdered reageni ln a pui mill. The feed preparation area wut be
linod with plastic to contain splll\!d soil and reaaent, ·
The contaminated soils will be tnnsferred from the S5•S•llon dnuns 1taaed near the teed
preparatiM area Into the pus mill by use of a front-end loader, Soils mixed with the
iodlum bicarbonate r~aient will bo placed back Into 55-sallon d~ IDd 1tqld near the
cont~lnmant pad to bij built for the demonstration procNt equlp111ect,
2. CONTAINMENT PAD'
,,
A pre-fabricated containment pad for tho Sar~ THERM-0-DETOX l;'llelll wUI bo conslructod
adjacent to the on-site concrete dccontainination pad, The pad it belna constructed to contain the
possible spilla11e of row soil, treated soil, and coollna water. The liner of the 0011talnm111t pad
will consist of a ge.1-textile base overlain by a hla)i dinslty plastic llnsr aad plywood, 'Ibo walh
of tht containment pad will b~ comtructod of metal to provide support for the plutlc llnor.
Soils that are spilled within the containment pad will be colll!Cttd dally and stored In 55-eallon
drums. The stored aoils will bij fed lnw the THERM-0-DETOX a)'IUlll for treatment.
At the end of lh• demoMtration, the containment plld will be diuuembled. 1be liner •)'Item wlll
bo drummed and prepared for off-site di~J)<)sal, The remal~er of oontilnment pad wUI be
prepared for shipment to El'A.
3. TREATED RESIDUES
Residue, g~neratod by the Sarex THERM-0-DBTOX system wUt ooaallt of treated 10l11, water,
and oil. Resld\lH produced by the 1ystem will be stored in 55•iallon dnlma and ate anticipated
to contain con~en\1'atlons of pentachlorophcnoi, dloi1l115, and flirana at slenltlcmrtly rtducod levels,
The eoaJ of the system is to produce tr1.1attd soils that can be dl1p0Md of on 11lto, ire.red wutt
water that can b• discharged to the local treatment works, and wuto oU which can be dlapoMd
of as non-huardous oil. Analytical te11tin& of all resld11os wlll bo perfonnod prior to 4ewm!nlna
the method of disposal.
4. UTILmES AND FACILITY REQUIREMENTS
Utillty requlrementll for the demonstration Include water and el~trlclly.
Electrical service for the Saru THERM-O-DB'tOX ayatem wlll requltt up1rlldl111 1h11 curreot
on site powor ~11pply, Electrical see'Vlce improvement.I to the 1lte wnl be provided by Carolina
Power & Ll&hl and a local subcontractor.
Water requlrcmenL~ for the demonstration will require leaslns water tanker tr11ck1 to 1provldt the
ne~e&ury dally volume requir~ for tbe Sarex THERM-0-DBTOX 1yatem,
• C .. STER
ENVIRONMENTAL
Ref. No. 179285-01
Via: Facsimile and Federal Express
July 6, 1993
Ms. Beverly Hudson, Remedial Project Manager
USEPA Region IV
NC North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Dear Beverly:
Re: Soil Treatability Study
Koppers Site -Momsville, NC
Ntt:tnitu
JUL 12 1993
SUPERFIIND SEC110N
On behalf of Beazer East, Inc. and in accordance with your request, please find
attached four (4) copies of drawing C69621 which presents a site plan of the soil
treatability study area at the Koppers Superfund Site, Morrisville NC.
We have identified two alternate locations, denoted as Option A and Option B,
for placing the proposed 40 foot by 100 foot decon pad, m the Soil Treatability
Study area. Please note that Option B (highlighted) is preferred since it 1s
located as close as possible to the impacted soils.
Should you need additional information regarding this drawing, please let
Shannon Craig at [phone] or me know.
Very truly yours,
~~ <. ~ fiv-
John C. Mitsak, P.E.
Manager, Baltimore Operations
TCH\13rall
Attachment
cc: Ms. Shannon K. Craig -Beazer East, Inc.
Ms. Cindy Zuch -Beazer East, Inc.
Mr. Jim Cook -Beazer East, Inc.
Mr. Bill Giarla -Beazer East, Inc.
Mr. Bruce Nicholson -NC Superfund (Two copies) ✓
formerly Keystone Environmental Resources
8600 LaSalle Road, Suite 502
York Building
Towson, Maryland 21286
410-821-2900: Fax [phone]
., 59
X19
SAMPLE-AREA 1
(FORMER LAGOON AREA) c::::::z
. X56
X16 ., X18 ~ ~ X2i
F I R E
APPROXIMATE
P O N D
EXISTING
TRANSFORMER\
EXISTING DIRT ROAD_,_
A., 'li//4 xy 1/✓:/
-' A / X22
., X57 X17
/
/
_ _ TRAILER --/ --EX. DEGON PAD C27B ,, .,,. .,,. ----
---/,,XS!-_,,, -(26' X 17 ') -,, i, A X20
LEGEND
OPTION B
(40' X 100')
DEGON PAD
~ ........
----------'-----/
I
I X54
EX. STORAGE ,, -TANKS ,,-
'
FORMER LOCATION OF SAND FIL'.TER
SAMPLE AREA 2
(FORMER CELLON PROCESS
AND SAND FILTER AREA)
APPROXIMATE FORMER LOCATION
OF TREATING CYLINDER
--/ ----I
OPTION A
(40' X 100')
DEGON PAD
-·------X53 A \
X37 X32 .) /
• x:4 . / 6--_/
Q
X35
~--0 .... ......., I I
I I
I I + -MONITORING WELL LOCATION
A -FORMER SOIL BORING LOCATION
-0--UTILITY POLE
.,.,....., • ..,. -BEAZER EAST, INC. PROPERTY BOUNDARY
OWN BY: CHK 'D BY:
R#
FILE NAME SCALE
APPR BY:
DATE
6/30/93
~--~
........
SCALE (FEET)
50 0 50
CHESTER
ENVIRONMENTAL
-
I I
I I I
I I
I I
--J I -....__ ✓ I
'---
OWG NO.
SITE PLAN
SOIL TREATABILITY STUDY c 6 g 6 2 1 FORMER KOPPERS COMPANY, INC. SITE BEAZER EAST, INC.
MORRISVILLE, NC.
EXISTING
TRANSFORMER\
EXISTING DIRT ROAD_,__
X16 _, X18
x~~
, ...
-, X57 X17
X~EX. OFFICE 4 TRAILER ----/
OPTION B
(40' X 100 ')
DEGON PAD
-' X59
X19
X56
/ X21
/~
X22
EX. DEGON PAD
_ (26' X 17 ') --
I
/
SAMPLE AREA 1
(FORMER LAGOON AREA)
APPROXIMATE FORMER LOCATION
OF SAND FILTER
F I R E
SAMPLE AREA 2
(FORMER CELLON PROCESS
AND SAND FILTER AREA)
--===r-*
' p 0 N D
APPROXIMATE FORMER LOCATION OF TREATING CYLINDER
----/ X54 '-/ ------EX. STORAGE ,, -' TANKS r
C28A
---------
-----/ ·--. I
OPTION A
(40' X 100 ')
□ECON PAD
·-·---...
X53 .a. \
X37 X32 .) /
... x:4 . I &_/ X35
LEGEND ~ ........ o .
~ ...
---X5 t-..._
---
-------------
------
Q
I I
I I
I I
-MONITORING WELL LOCATION
-FORMER SOIL BORING LOCATION
-0--UTILITY POLE
---=• .. -BEAZER EAST, INC. PROPERTY BOUNDARY
OWN BY: CHK 'D BY: APPR BY:
RN
FILE NAME SCALE DATE
5/30/93
------------------
~ .... .... ------------
SCALE (FEET) ~ ---
I f•·9 49J +-*53 E a ad ..._ ... 50 0 50
CHESTER
ENVIRONMENTAL
100
SITE PLAN
SOIL TREATABILITY STUDY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NC.
---
I I
I I I
I I
I I -I I
----✓ \
' ----------------------------'
DWG NO.
C69621
MEMO
TO:
FROM:
RE:
January 28, 1993
File
Randy McElveen
Environmental Engineer ·
NC Superfund Section
••
Telephone Record of Conversation with AYTIJS, Inc. in Coffeyville, Kansas
Incineration of soils contaminated with PCP's and dioxins/furans.
Koppers site, Morrisville, Wake County, N.C.
Mr. Greg Dody, the NC Sales representative for APTUS, Inc. was contacted by
telephone on the above stated date at approximately 11:00 a.m., telephone number (316)
251-6380.
Mr. Dody stated that they are presently a permitted facility, but one of the permit
limitations prohibits the incineration or burning of waste that contains dioxins. However,
Mr. Dody stated that this restriction is for a limited time period and hopes that it will be
removed sometime this year.
RM/dk/1
cc: Jack Butler, NC Superfund Section
• • UNITED ST ATES ENVIRON MENTAL PROTECTION AGENCY
REGION IV
4WD-NSRB
September 4, 1992
Shannon Craig
Beazer East, Inc.
436 Seventh Avenue
345 COURTLAND S!REET. N.E.
ATLANTA. GEORGIA 30365
Pittsburgh, Pennsylvania 15219
Re: Feasibility Study Report
Koppers Superfund Site
Morrisville, North Carolina
Dear Ms. Craig:
RIECE~V!EO
'.SEP l 1199;;'
SUPERFUNO SECTI011
The Agency has become aware of the following four facilities that
are permitted to receive and treat K00l and F032 waste. Please
develop accurate costs for these four facilities for 1000 cubic
yards and 5000 cubic yards, (at a minimum), for off-site
incineration. These costs should be comprehensive, self-
explanatory and will supplement the Feasibility Study. These costs
are due to EPA on September 9, 1992.
ENSCO
Thermal Chem
Rollins
Chem Waste
Eldorado, Arkansas
Rock Hill, South Carolina
Deer Park, Texas
Ft. Arthur, Texas
Please contact me at 404-347-7791 if you have any questions
regarding this letter.
;Ji;J:;;~$~r-/
Barbara H. Benoy~ 0
Remedial Project Manage
Waste Management Divisi
cc: Curt Fehn, NCS
Chuck Mikalian, ORC
Bruce Nicholson, NCDEHNR ✓
John Mitsak, Keystone
KOP.9492.TRECOST,SCRA
Printed on Recycled Paper
:llL',_ . , f~i?it:·:.
iil~f,£C. _f ;:;..~....... '
'Xl·.'.:t.•:.·: •• 1r·-'"''"
0
·=="-'·"'•·'"'"~---United States Risk Reduction -;!t~~ . · Environmental Protection Engineering Laboratory
,;_lf-:Jf:. Agency Cincinnati, OH 45268 -T~· ·=.:c'4uG · 1 f 1992 "' Research and Development EPA/600/SR-92/065 May 1992
-r,t ·\ o EPA Pro1·ect Summary
.4.\' ) '>?" 1/ rf · !"o. ,i.·3/
,1 _'Z~
.t,
•
,,
'''
Pilot-Scale Evaluation of the
Thermal Stability POHC
lncinerability Ranking
I
DEM
LABORATORY SECTION
A series of pilot-scale incineration
tests was performed at the Environ-
mental Protection Agency's'(EPA's) In-
-clneration Research Fac:lity to evalu-
ate the thermal-stability-based princi-
pal organic hazardous constituent
(POHC) incinerability ranking. In the
tests, mixtures .of 12 POHCs with pre-
dicted incinerabilities spanning the
range of most-to least-difficult-to-in-
cinerate classes were combined with a
clay-based sorbent and batch-fed to the
facility's pilot-scale rotary kiln incin-
erator via a fiberpack drum ram feeder.
Five tests were completed. Kiln operat-
ing conditions were varied to include a
baseline operating condition, 3 modes
of attempted incineration failure, and a
worst-case combination of the 3 failure
modes.
Kiln exit POHC destruction removal
efficiencies (DREs) were in the 99.99%
range for the volatile POHCs during
the base,line, mixing failure (increased
charge mass), and matrix failure (de-
creased feed H/CI) tests. Semivolatile
POHCs were not detected in the kiln
exit for these tests; corresponding
DREs were generally greater than
99.999%. The thermal failure (low kiln
temperature) and worst-case (combina-
tion of thermal, mixing, and matrix fail-
ure) tests resulted in substantially de-
creased kiln exit POHC DREs. These
ranged from 99¾ or less for Freon 113
to greater than 99.999% for the less-
stable-ranked POHCs. General agree-
m'ent betWeen relative kiln exit POHC
DRE and predicted incinerability class
was observed for those two tests.
This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, Ohio, to an-
nounce key findings of the research
project that is fully documented in a
separate report of the same title (see
Project Report ordering information at
back).
Introduction
One of the primary functions of the
EPA's Incineration Research Facility (IRF)
is to conduct research activities for the
EPA's Office of Solid Waste (OSW) in
support of regulation develop_ment and
implementation. One major regulatory is-
sue of high priority during 1990 concerned
the evaluation of an incinerability ranking
system for POHCs. The system was de-
veloped over the past several years by
the University of Dayton Research Insti-
tute (UDR!) under contract to EPA's Risk
Reduction Engineering Laboratory (RREL).
The 1981 hazardous waste incinerator
regulations require that an incinerator un-
dergo a trial burn performance test in or-
der to become permitted to operate. This
trial burn is required to show that the
incinerator is capable of achieving the
mandated 99.99% POHC DRE. In tri~I
burn .planning, the incinerat~r operate~ 1s
required to select POHCs using two cr~~-
ria: concentration in the waste and diffi-
culty to thermally destroy, or "incinerability." ·
The incinerability ranking included In the
1981 regulations was based on compound -----
heat of combustion. -~---::-:.
The heat of combustion ranking has ·
several acknowledged deficiencies, how-
ever. Thus, EPA initiated studies to define · _.,_,-. -~--.
@ Printed on Recycled Paper ·, ·,,
. -. ~.,.~"-
':t;~-~-
~ .. }.
•
or-ileyelop alternate, more suitable
!iiclnerability ranking approaches. One
such";approach is the thermal-stability-·=based POHC ranking, developed by UDRI.
. '.~Tliis'ranking is based on the.temperature
· .',\ifrequired to achieve 99% destruction at 2 · 11 sec residence time under oxygen-starved =. Conditions as measured in laboratory ex-
1#':;" periments. As of early 1990, the funda-
'.,:']il:-•.: mental basis supporting the ranking ap-
:~: preach had been documented and suffi-~~ cient information to rank the organic haz-
~l:'ardous constituents had been collected.
~;;,, Since it is based only on laboratory-scale -lilt' data, evaluation of the thermal stability
ii!?f.: POHC incinerability ranking under actual
~-iricineration conditions became a high-pri-1L ority research need for 1990. :L The test program described in the full
·:; report was designed to develop the data
', to evaluate the POHC incinerability rank-
,, ing at the pilot scale. The specific objec-
~: tive of the test program was to measure
the DRE of a number of POHCs under
each of several modes of incinerator op-
eration, and compare relative POHC DR Es
as a function of incineration conditions
· and feed char8cteristics. The comparison
would facil~ate a determination of how
relative POHC "DREs compared with ex-
pectations based on the thermal stability
ranking.
In the tests, a mixture of 12· POHCs
with:predicted incinerabilities spanning the
range from the most-difficult-to-incinerate
class to the least-difficulHo-incinerate class
was tested. This "POHC soup" mixture
was combined with ·a clay-based· sorbent
solid matrix and packaged into fiberpack
d~un:15 !or incineration testing in the rotary
krln rncrneration system (RKS) at the IRF.
The drums containing the soup/clay mix-
ture were batch fed to the RKS via a
fiberpack drum ram feeder.
A-series of five incineration tests was
P~rformed. ~uring which incinerator oper-
~tmg condrt1on~ and test mixture composi-
tJo~ were vaned. Specific test program vanables were:
Kiln temperature
:::,I ~-:;.1-• · Feed batch charge mass
'-::; Feed composition, specifically i' H/CI ratio
{'°"'::' One_ test was pertormed under typical
r~.E; .. ;,._-operating conditions with a baseline mix-
:""fi't,rn-~·-.::;ture composition. The other te t . d
. i"" the ab . s s vane
["-"" f.,,~. ave m a~ attempt to simulate vari-
1 ~-·~ ~es o~ incineration failure, where
i ~~tron failure is defined to exist when ·--~s"· REs are l~ss. than 99.99%. The __ !tir,Cit.;ci'!!<>des of rncrneration failure at-
. --~,,foocl ~ .thermal failure, mixing fail-
CDiit»iiuttioh" ( effects, and a worst case " .~_Jhese.
-
•':~'>!:::.._
Test Program
Test Facility
•
• The IRF's RKS was used for this test
program. A process schematic of the RKS
is shown in Figure1. The IRF RKS con-
sists of a primary combustion chamber, a
transition section, and a fired afterburner
chamber. After exiting the aherburner, flue
gas flows through a quench section fol-
lowed by a primary air pollution control
system (APCS). The primary APCS for
these tests consisted of a venturi scrub-
ber followed by a packed-column scrub-
ber. Downstream of the primary APCS, a
backup secondary APCS, comprised of a
demister, an activated-carbon adsorber,
and a high-efficiency particulate (HEPA)
filter, is in place.
Synthetic Waste Mixture
Twelve POHCs were selected for inclu-
sion in the synthetic waste mixture em-
ployed in the test program. The
incinerability ranking groups 333 POHCs
included into 7 stability classes from most
stable (class 1) to least stable (class 7).
UDRI recommended that 2 compounds
from each class be included in the test
mixture and provided a list of candidates
for selection. The selection of compounds
from this candidate list was guided by
sampling and analysis, compound com-
patibility, compound availability, and safety
considerations.
The compounds selected for the test
mixture are listed in Table 1. The .table
also. notes the ·composition of two test
mixtures containing the POHCs. Test mix-
ture 1 was the baseline test mixture. The
POHC concentrations in test mixture 2
represent adjustments to relative POHC
concentrations to yield a mixture with de-
creased H/CI ratio.
The mixtures incinerated in the test pro-
gram were prepared using commercially-
available pure cher.iicals and materials.
Test material formulation consisted of add-
ing weighed quantities (1.3 kg, 3 lb total)
of the mixture of the 12 organic constitu-
ents to a weighed quantity (2.3 kg, 5 lb) of
an absorbent clay. The clay/organic mix-
tures were packaged into 1.5-gal fiberpack
drums lined with polypropylene bags, the
mouths of which were closed with wire
ties.
Test Conditions
The variables for the test program were
the H/CI ratio in the synthetic waste feed,
kiln temperature, and synthetic waste feed
charge mass. Five tests, specified to be
conducted with various combinations of
these parameters, were selected to evalu-
ate the relative incinerability of the POHCs.
2
:t:"1:~ii"":;:"r~~-.. -.. v
The target test matrix is shown in Table 2.
Test 1 represented a baseline, or normal,
set of incinerator operating conditions. Test
2 attempted thermal failure by decreasing
the kiln exit temperature to a target of
649°C (1200°F). To further promote ther-
mal failure, 0.9 kg (2 lb) of water was
added to each waste feed charge for Test-
2. In Test 3, mixing failure was attempted
by doubling the drum charge mass from
3.6 to 7.3 kg (8 to 16 lb). This doubled
charge mass was introduced at hatt the
baseline frequency, so as to maintain the
overall waste feedrate equal to that for
the other test conditions. Test 4 was de-
signed to investigate the effects of reduc-
ing the H/CI ratio (matrix failure) in the
waste feed. Test 5 combined the three
failure-promoting conditions to produce a
''worst-case" condition by operating with
the kiln exit temperature at a target of
649°C (1200°F), introducing the waste at
double the baseline charge mass, and by
using a low H/CI ratio waste mixture.
For all tests, the average kiln exit tem-
peratures were within 14°C (26°F) of the
respective target temperatures. However,
actual 0 2 levels in the kiln exit flue gas
. were generally higher than the target con-
centrations. The higher 0 2 levels were
generally the result of higher than ex-
pected air in-leakage into the kiln cham-
ber.
Sampling and Analysis
Procedures
The scope of the sampling effort under-
taken during this test program is illus-
trated in Figure 2, in which the sampling
locations and the .corresponding sample
collection methods are identified. Specifi-
cally, the sampling effort during each test
consisted of:
• Obtaining a sample of the POHC/clay
feed mixture by compositing the con-
tents of 3 waste fiberpack drums ran-
domly selected during the test
• Obtaining a sample of the scrubber
blowdown liquor composited from grab
samples taken at hourly intervals over
the test period
• Obtaining a sample of the kiln ash by
compositing three samples from the
ash collection bin at the end of the
test
• Continuously measuring 0 2, CO, CO2,
and unheated total unburned hydro-
carbon (TUHC) concentrations in the
flue gas at the kiln exit; 0 concentra-
tions at the afterburner e~it; O , NO ,
unheated TUHC, and heated 'ruHC
concentrations at the scrubber exit;
• •
Single-stage Ionizing
I Wat ScrobbBr I
I I
I I Quench -..
Afterburner
I Scrobbar Liquor I
I Recirculation l
1Atmosphera
I
Air t-------------1 I Stack
I I I Natural
Gas,
Liquid
Faod
s /"d I I J.6!r-1'J----l---f<, lo Fan 01 s I JCarbon Bod I Faadar
Transfer
Duct
Mai~ 1Adsorb8r H PA I
_.,Burner Pack89 Filter I Co/um~
Air I Venturi Scrubbsr I Ash
Bin Rotary
Kiln
Natural I Scrobbar I I
Gas, Uquid I Scrubber Liquor I 1
FsfKi I Racirculation I I
I I I
Rotary Kiln
Incinerator
I Modular Pn"mary Air I Rsdundant Air I
Pollution Control Devices Pollution Control
System
Rgure 1. Schematic of the /RF rotary kiln incineration system.
Table 1. Synthetic Wasta Mixture Composition
Concentration (Wt %l
Mixture t Mfrture 2
Component High HICI LowHICI T../21 ('CJ Ranx:°
Banzena 8 4 1.150 3
Ch/orobenzana 8 4 990 22
TatrachloroBthemJ 8 33 890 43
1,2,2-T n·chforo-8 4 780 92
1, 1,2-Tdfluoroathane
/Fmon 113)
Banzanethiol 8 4 725 122
Nitrobenzena 8 4 655 150/151
Haxachlorocyclohaxans 10 5 645 159
/Lindana)
Haxachloroethans 10 25 585 213
1, 1, 1-Trichloroethans 10 5 545 233
p-Dimethylaminoazobenzsne 10 5 -400 268
/mathy/ ya/low)
Nicotine 10 5 <320 285 to289
N-nitroso--di-n-butyl amine 2 2 <320 316 to 331
HICI /molar) 3.6 1.2
Temperature fBquired to achieve 99 % destruction in 2 ssc.
b fncinerability rank in list range from most refractory (No. I) to most labile (No. 333).
3
Stability
Class
2
3
3
4
4
5
5
6
7
7
I
Sampling
point
2
3
4
5
6
7
,:,·.:.-;.7,.
p. ___ ,;\~;:
....... '"''"-·~· . ,:.~:;-
Kiln
2 3
After-
•
Kiln axit
tamporatura
•C('F)
871 /1600)
649 /1200)
871 /1600)
871 /1600}
649 /1200)
Quench
burner Section
4
Feeds and msiduals
POHCI
Clay Kiln Scrubber Mixture ash blowdown
X
X
X
Figure 2. Sampling matrix.
•
Kiln Aftarbumar axit Alterbumor Organic/clay exit CY tsmporaturo oxit CY per fibarpack Foad regimen Charg• (%} •c('F) (%) kg (lb) drums/charga hr
10.4 982 /1800) 9.0 3.6 /8) 12 12.6 982 /1800) 9.1 4.5 /10)' 12 10.4 982/1800) 9.0 3.6 /8} 2 6 10.4 982 /1800) 9.2 3.6 /8) 12 13.2 982 /1800) 9.2 3.6 /8) 2 6
VenturVPacked
Carbon -CO:umn HEPA Demister Bed Fi/tar Scrubber
5 6 7
Sample.Location
•·.Continuous monitors Flue ga:i
Method 0010 Method 0030 Method 5 co, Unheated Heated ( semivolatile (volafl1e (Particulate o, co, NO, TU/IC TUHC organics) . organics and HCI)
X X X X X X X ,-
X X X X X X X X X X X X
4
• • Ii,'.-~ -, -~ ----------------------------------------------==,.,n.:..J?.~~
. . ~~ , ... ~-, and o,. CO, co,, and heated TUHC and that the measured DRE was greater operation, which, from past experienc:e'S
concentrations in the stack than that computed using the POL. would result in acceptable POHC clestnii:!-ie:
The POHC DREs illustrated in Figures tion. As shown in Figure 3, kiln extt DREs-~ Sampling llue gas at the kiln extt, f JI POH "'-3 through 7 were calculated using pre-were 99.99% or greater or a Cs,,-, scrubber exit, and stack for the B hi b hi ··· Pared synthetic waste feed formulation enzene, c oro enzene, tetrac oro--semivolatile and volatile POHCs us-F d · hi data. Feed samples were analyzed for ethene, reon 113, an 1, 1, 1-tric oro--
ing Method 0010 and Method 0030, each test, as noted above. However, ana-ethane were quantitatively measured at
respectively Jyzed POHC concentrations in feed the kiln exit and their corresponding DREs
The laboratory analysis procedures used samples were substantially lower than the are shown by the single bars. The remain-
to characterize the samples collected over concentrations corresponding to the POHC ing POHCs were not detected at the kiln
the test program included: quanttties used to form the POHC mix-exit and their respective DREs were rap-
tures. On average, only between 12 and resented by the two-segment stacked bars,
Analyzing the composite feed, kiln 29% of the volatile organic constituents the significance of which was discussed·
·ash, and scrubber blowdown samples and between 27 and 82% of the above.
from each test for volatile and. Th h' h POHC DRE f' d th t semivolatile organic constituents in the pre-e Ig s con irme a
semivolatile organic constituents pared mixtures could be accounted for in this baseline incinerator operating condi-
• Analyzing Method 0010 train samples the feed analyses. Fiberpack weights mea-tion was indeed capable of satisfactorily
from each test for semivolatile organic sured during the tests rule out mass evapo-destroying even the predicted most diffi-
hazardous constituents rative loss as the explanation for differ-cult to incinerate POHC, benzene. A weak
• Analyzing Method 0030 train samples ences between prepared and analyzed correlation might exist between DRE and
from each test·for volatile organic haz-concentrations. One possible explanation the POHC incinerability ranking, in that,
ardous constituents is that the organic liquid constituents were except for 1, 1, 1-trichloroethane which had
so tightly adsorbed to the porous clay that a DRE of about 99.99%, DREs for POHCs
Semivolatile organic analyses were per· the sample preparation procedures asso-ranked in class 4 and above were higher
formed by Method 8270. Solid samples, ciated with Methods 8240 and 8270 analy-than the class 3 and below POHCs. It
including waste feed and kiln ash, and ses could not quantitatively free the or• bears emphasis, however, that the mea•
Method 0010 samples were Soxhlet-ex-ganic constituents for detection in the sured POHC DREs only varied by small
tracted by Method 3540 in preparation for analyses. All test .program .data· supi:;crt degree (from 99.994% to 99.9997+%).
ar,alysis. Liquid samp:,,s were liquid-liquid this hypothesis-and it is believed that what This, coupled with the lack of gross Incm-
extractec by Method J510. Method 0030 was. prepared was .. indeed fed. For this eration failure to broaden the incinerability
•'(VOST) sample analysis was by thermal reason, prepared-composition-based --·response, could explain the inability to
desorption p~irge and trap GC/MS (Method OREs alone are presented. N.sverthele'>s, · establish a clear correlation between DRE
.·5040) analysis with an ion trap:detector. all conclusions ·regarding relative -DREs and the incinerability ranking index from
I
'
r
are also supported· using analyzed feed the baseline test data. ·'.TeSt Results composition data. It is interesting to note that 1,1,1-
The POHC-measurements at the kiln Table· 1 noted, that benzenethiol was trichloroethane, a POHC ranked in class
·exit :::re the most' relevant with·respect to selected as one of the class 3· POHCs in . 5 and believed to be relatively easy to
evaluating the incinerabi!ity ranking in that the POHC mixture. However, while per• incinerate, had a measured DRE substan•
the incineraiion failure conditions tested forming tests to verify that stable synthetic tially lower than similarly ranked POHCs.
involved varying kiln operation. Thus, in-waste organic feed mixtures could be pre-One possible explanation is that 1, 1, 1:
cineration failures achieved would be most pared, it was discovered that benzenethiol trichloroethane is a common product ot
evident and best measured at the kiln quite rapidly and completely reacts, in the incomplete combustion (PIC), and can be
exit. presence of the other organics and the formed during the incineration process,
Figures 3 through 7 show kiln exit POHC clay matrix, to form diphenyl disulfide. a potentially from hexachloroethane, another
DREs measured in bar chart form. The class 6 compound. As a result, diphenyl component of the POHC mixture.
POHCs are ordered along the horizontal disulfide, not benzenethiol, was actually
axis by their thermal stability index rank-fed to the incinerator. Thus, the DRE for Test 2-Thermal Failure
ing from predicted most-stable (benzene) diphenyl disulfide is shown in Figures 3 (Quenching)
to least-stable (N-nitroso-di-n-but,i_ amine). through 7 bar charts, and its bar location Test 2 was intended to simulate a ther-
The vertical axis is the quantity [-!og (1-corresponds to its class 6 incinerability mal failure condition through incineration
DRE/100)] for each POHC, which rep,e-order. quench. This was accomplished by lower-
sents the "number oi 9's" of POHC de-No DREs for nicotine are shown in ing the kiln temperature from nominally
struction. A value of 1 signifies 90% DRE, Figures 3 through 7. Nicotine recoveries 371,c (1600"F) to 649'C (1200'F) via 2
a value of 2 signifies 99% DRE, and so from matrix spike Method 0010 samples means. A measured amount of water con·
on. Each bar represents the measured were generally poor. These poor recover~ tained in a polyethylene bag was added
DRE for the corresponding POHC. Where ies prevented making accurate assess• to each waste feed fiberpad,; drum and
flue gas analysis indicated that the par-ments of the OREs for this compound and the kiln was fired at very high air/fuel ratio.
ticular POHC was below its detection limit, it has been omitted from the figures. These two actions in combination would
a stacked bar format is used to convey The following discusses relative POHC be expected to create conditions condu-
this information. The height of the bottom DREs measured for each test in turn. cive to the formation of cold POHC-con-
bar of the stack represents the DRE cal-taining pockets of gas which would es-culated Using trle pract·1cal quantitation limit Test 1 Basetr·ne Jnc1·nerat1·on •' -cape the kiln prior to being destroyed. (POL). The combined stacked bar is ex-Conditions Figure 4 presents the kiln-exit POHC
tended to the top of th e chart, as a visual The incinerator operating conditions for DREs for this test. The data clearly indi-reminder that the POHC was not detected Test 1 represented baseline incineration
5
:.z .. :i
!!l'ia
Stability Class I·~~"~! I Denotes POHC Not Detected
Figure 3. Kiln exit POHC DREs for Tast 1,
2 3 4 4 5
Stability Class EJ Denotes POHC Nor Detected
Figure 4. Kiln exit POHC DREs for Test 2.
5
§' 4 iii ct c;, 3 "-is' -/ 2
0
~ • § s ~ • -1l co C: .s;
~
2 3 4 4 5
Stability Class 0 Denotes POHC Not Detected
~~Rgure 5. K:l · . :lf:t!!i::: .•.:"'_' 1 n exit POHC DR Es tor Tast 3. '· ~::c--,.:~
,_ :-, .
~ltffit.i:1. g1;:~:o:,:.,-....:--""" . .
6
5 6 6
5 6 6
7
7
7
6
cate that this test condition resulted in
significantly different POHC DREs com-
pared to the baseline test. A wide range
of POHC DREs was observed, from less
than 99% for Freon 113 to greater than
about 99.999% for diphenyl disulfide,
methyl yellow. and N-nitroso-di-n-butyl
amine. The low DREs for several POHCs
confirmed that incineration failure did oc-
cur during this test.
With the exception of a few anomalies
(discussed below), a general correlation
between DRE and indnerability ranking
seems apparent for this test. The observed
DREs for the class 3 to 7 POHCs ap-
peared to follow the incinerability ranking
predicted behavior. Some POHC-to-POHC
variability existed within this sub-group of
POHCs. Lindane exhibited a higher DRE
than the neighboring ranked POHCs.
A considerably more significant devia-
tion from incinerability ranking expectation
involved the DREs of the 4 most-stable
ranked POHCs within classes 1, 2 and 3.
The relative DREs measured for these
four POHCs were in an order opposite to
the ranking predictions. The relative ex-
tent of incineration failure fol' these 4
POHCs was not in accordance with ex-
pectations from the thermal. stability rank-
ing.
Test 3 -Mixing Failure
One of the modes by which POHCs
can escape an incinerator undestroyed
results from the lack of adequate mixing
between POHC and oxidizer. For Test 3,
the weight of each waste charge to the
kiln was doubled, while the hourly waste
feedrate was maintained at a level consis-
tent with the other four tests. The doubled
waste charge was thought to increase the
likelihood of creating oxygen-deficient
pockets of POHCs in the kiln chamber.
The expectation was tha: if the oxygen-
deficient conditions persisted through the
kiln, undestroyed POHCs could escape
the kiln chamber.
However, as the data in Figure 5 show,
no clear failure was apparent during this
test. All POHC DREs were greater than
99.99% and exhibited trends similar to
those observed for the baseline condition
test (Test 1). DREs for nitrobenzene and
the group of POHCs ranked easier to in-
cinerate were high. Within this group, only
1, 1, 1-trichloroethane was detected in the
kiln exit flue gas sample at a level above
its POL. The other less-stable ranked
POHCs were not detected in the kiln exit
flue gas.
The four most difficult to incinerate
POHCs, benzene, chlorobenzene,
tetrachloroethene, and Freon 113 were
present in the kiln exit flue gas sample at
• •
~ • "' ...: -9--· Cl
2 3 4 4 5 5 6 6 7
Stability Class
Dsnotss POHC Not Ostectod
Figure 6. Kiln exit POHC DREs for Test 4.
5
• § s •
J
e ~
i a " • .u ,_ ~ "-s ...: • -· ::;;
2 3 4 4 5 5 6 6 7
Stability Class
l~'l..~-.j Dsnotss POHC Not Detected
Figure 7. Kiln exit POHC DREs for Test 5.
levels corresponding to between 99.99 and
99.999% DRE.
No correlation between POHC DREs
and POHC incinerability ranking w~s ap-
parent for this test. DREs for the volatile
POHCs (detected in the flue gas) were
comparable to the DREs associated with
the POLs for the semivolatile POHCs (not
detected in the flue gas).
Test 4-Matrix Failure
This test (Test 4) attempted to cause
incineration failure by decreasing the H/CI
ratio in the organic feed to the kiln. The H/
Cl ratio in the feed waste for Test 4 was
1.2, as compared to a H/CI ratio of 3.6 for
the baseline Test 1.
·u.s. Governmem Printing Office: 1992 -648-000;60020
The kiln exit POHC DREs for this test
are shown in Figure 6. These were uni-
formly high: all exceeded 99.99%. As in
Test 3, no correlation between POHC DRE
and incinerability ranking was apparent
because the POHC DR Es were uniformally
high.
One possible explanation for the inabil·
ity to achieve POHC DRE failure in this
test is that the actual H/CI ratio in the kiln
environment as a whole was quite differ-
ent from that in the waste feed itsett. This
was so because the auxiliary fuel for the
burner, in this case natural gas, was a
significant additional source of hydrogen.
If this source of hydrogen is included, the
H/CI ratio in the total kiln environment for
7
this test would be 15.7, which may be
considerably higher than the H/CI ratio
required to cause DRE failure.
Test 5 -Worst Case
Combination
This last test was conducted to present
the most challenging combination of the
mechanisms tested in terms of POHC de·
struction failure. The kiln was operated at
the reduced temperature of 640°C
(1184°F) to induce thermal failure; the
waste feed charge size was doubled to
promote mixing failure; and the chlorine
content in the feed waste was elevated to
promote matrix failure. It should be noted
that, in a departure from Test 2 proce·
dures, no water was added to the feed
waste fiber drums, because doing so would
introduce a quantity of hydrogen that might
nullify any potential elevated chlorine (ma·
trix failure) ettect.
Figure 7 shows the POHC DREs for this test condition. In this test, 8 of the
11 POHCs were detected in the kiln exit
flue gas. This was in contrast to only five
POHCs being found at concentrations
above their POLs ·during baseline Test 1.
The 3 most easily predicted incinerated
POHCs, namely, diphenyl disulfide, methyl
yellow, and N-nitroso-di-n-butyl amine were
not found above their POLs. Assuming
that these POHCs were present at their
respective POLs would lead to computed
POHC DREs > 99.998% for these 3
POHCs. These DREs, being higher than
-· those measured for the remaining POHCs,
were consistent with their incinerability
ranking indices .
The DREs for the 8 quantifiabla POHCs
ranged from over 99 to almost 99.999%,
calculated based on feed formulation data.
Lindane had the highest DRE at
99.9989%. Freon 113· and 1, 1, 1 ·
trichloroethane exhibited the lowest DRE
at about 99.8%. While no monotonic cor-
relation between POHC DREs and
incinerability ranking order existed for this
test, a weak relationship may have ex-
isted for the class 3 through class 7
POHCs. As observed in Test 1 , 1 , 1 , 1 ·
trichloroethane exhibited a DRE signifi·
cantly below that of its neighboring ranked
POHCs.
It is interesting to note how well the
relative POHC DREs of this ''worst-case"
test compared to those observed for Test·
2. Recall that Test 2 simulated only quench
failure. The relative DREs for these two
tests exhibited similar patterns although 2
differences could be noted. One differ·
ence is the absolute DRE levels, which
for this test were generally higher than
those observed for Test 2. The other dif·
ference relates to the DREs for benzene
. . ' .. •
and 1, 1, 1-trichloroethane:-•The DR Es for
benzene and 1, 1, 1-trichl6roethane were
nearly 2 "nines" higher for Test 2 than for
Test 5.
Conclusions ti Conclusions from the tests include the
:following:-_·-_
•
exit flue gas; corresponding lower
bound DREs were generally greater
than 99. 999%.
• Neither the mixing failure nor matrix
failure attempts resulted in incinera-
tion failure. Kiln exit POHC DR Es were
comparable to those measured in the
baseline test for all POHCs. . . · :: • The baseline operation condition re-
~· ~-.!; .~1.1.,sulted in effective POHC destruction.
,-,~C:Kilri1exit POHC DREs ·were in the
'., ,,ii~~/f99_",:'.~ range for the volatile_POHCs
¥·,. =· :··;!-'.-:l-lln ?:the;-test mixture. Sem1volatlle
· 1 iL_,:,,.iJ;:.P.OHCs were not detected in the kiln
\-.• , .,-....••• -r.. .•••
• The thermal failure and worst-case
tests resulted in kiln POHC destruc-
tion failure. For both tests, kiln exit
POHC DRE ranged from 99% or less
for Freon 113 to greater than 99.999%
-:~~~~: -...... _.~
·i~~;-...... r-------------------------------~ . ;.
, ..
J. W. Lee, W.E. Whitworth, and L.R. Water/and are with Acurex Corporation,
Jefferson, AK 72079.
R.C. Thurnau is the EPA Project Officer isee below).
The complete report, entitled "Pilot-Scale Evaluation of the Thermal Stability POHC
lncinerability Ranking," {Order No. PB92-766 966/AS; Cost: $35.00, subject to
change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: [phone]
for the highest-ranked (least-stable)
POHCs.
• For the incineration failure tests, there
was general agreement between ob-
served relative kiln exit POHC DRE
and thennal stability incinerability rank-
ing expectations. However, two de-
viations occurred for both tests .
The class 1 compounds (benzene
and chlorobenzene) and the class
2 compound (tetrachloroethene)
were less stable (had greater kiln
exit DRE) than the c!ass 3 com-
pound Freon 113.
1, 1, 1-trichloroethane was appar-
ently more stable in the baseline
and worst-case tests than tts class-
5 ranking would suggest, when
compared to the other class 5 and
the class 4 compounds; production
of 1, 1, 1-trichloroethane as a PIC
could account for this observation.
The full report was submitted in
fullfillment of Contract 68-C9-0038 by
Acurex Corporation under the sponsor-
ship of the U.S. Environmental Protection The EPA Project Officer can be contacted at:
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
· -Agency. ·
United States
Environmental Protection
Agency
Official Business
Center for Environmental
Research Information
Cincinnati, OH 45268
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT NO. G-35
Penalty for Private Use $300 ,{
EPNS00/SR-92/065 ((
-~~·--· ...
. ·# ·: .. '•
-tifil~
·=~~'.=.: "'!'.:; . .::..~-•:..--::-::--
:.7:~,..,.~~-..
~-~Eg·; .. __ ~-
-j:•··-"-··'·-· ..... ......... ,_,,:i.::,,,.._,_ ..r ·--•• - .
~~~!A~~'!7rtj:_;!!"":'" ~:::::-;;=::;o-.
ffiS4~iiJiit~~:~ ~:.=:: .. ,.,~\""~-=~_;=-=·_=-:C-:.-'"~.~-:-~-: ~; ..
000046274 HWERL
•ILLI.\M L 11EYEil NC DEPT ~ii-& NH
PO BOX 27637
RALEIGH NC 27611-7687
• KEYSTONE
3000 Tech Center Drive
Monroeville. PA 15146
4 12 825-9600
FAX [phone]
May 8, 1991
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch, Waste Management Division
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Ms. Benoy:
Re: Treatability Study \\'.ork Plan
Koppers Site -Mornsv1lle, NC
Beazer East, Inc.
•
Ref. No. 179280-10
SUPERFIJND SECTION
-On behalf of Shannon Craig and Beazer East, Inc., Keystone Environmental
Resources, Inc. is pleased to submit for your review four bound copies and one
unbound copy of the Treatability Study Description for the Morrisville, North
Carolina site. We request that you send one of the enclosed copies to Mr. Terry
Lyons at EPA's Risk Reduction Laboratory in Cincinnati, Ohio, for his review.
This document is the revised version of the Treatability Study Work Plan. The
revisions, as agreed during your meeting with Beazer and Keystone on April 17,
include the following:
o Change the document title from 'Treatability Study Work Plan" to
"Treatability Study Description." ·
o Include a references section.
o Describe the handling of any residuals produced if these technologies
are implemented on a full-scale basis.
o Present a·n outline of theTreatability Study Report.
A CHESTER Environmen1al Company
Ms. Barbara B!,
NC/SC Site Management Unit • May 8, 1991
Page 2
I(you have any questions or comments regarding the Work Plan, please contact me
at [phone] or Shannon Craig at [phone].
Very truly yours,
At~? ffe-L~~
Diane E. McCausland
Project Manager
DEM:jsw W-2205
Ends.
cc: Pat DeRosa (NC Superfund Branch)
Shannon Craig (Beazer)
John Mitsak (Keystone)
l
l • •
TREATABILI1Y STUDY DESCRIPTION
KOPPERS SUPERFUND SITE MORRISVILLE, NORTH CAROLINA
Prepared for:
BEAZER EAST, INC.
436 SEVENTH A VENUE
PITTSBURGH, PENNSYLVANIA 15219
Prepared by:
KEYSTONE ENVIRONMENTAL RESOURCES, INC. 3000 TECH CENTER DRIVE
MONROEVILLE, PENNSYLVANIA 15146
PROJECT NO. 179280
MAY 1991
• •
2.0 SAMPLE COLLECTION AND HANDLING
2.1 Groundwater
The laboratory carbon column study will treat approximately 1,000 gallons of
groundwater. Half of the water, obtained during a pump test in February 1991, was
collected at PW-I, a pumping well located near monitoring well C-298. This well,
located along the eastern plant border, north of the fire pond, is 49 feet deep into
the bedrock groundwater aquifer. Results from Round I sampling of C-298
indicated that no PCDD /PCDF were detected above the method detection limit of
0.001 ng/L. Generally, results from sampling and analysis of deeper (B or C) wells
· indicated that no PCDD/PCDF was present in those wells.
The other half of the treatability sample was collected from well C-30, a shallow
well near the northern plant boundary, in the former landfarm area. C-30 contains
detectable concentrations of PCDD/PCDF based upon Round 1 groundwater
sampling and analysis. Past sampling has also indicated that well C-30 contains low
concentrations of PCP. If needed, the groundwater treatability samples can be
spiked with PCP before use in the carbon column study.
Upon review of three laboratory carbon treatment options, ACT test, carbon
isotherms, and column study, it was recommended that, due to the low
concentrations of PCP in the groundwater, a carbon column study would be
necessary to detect PCP breakthrough at the 0.01 ug/L detection limit desired for
the site. The column study will generate sufficient sample volumes so that PCP
analysis can be conducted by Method 515, which requires a 1 liter sample volume,
and the sample will still be representative of a time period which can reasonably be
scaled up to full-scale.
Calgon's ACT test was evaluated for use because it requires a smaller groundwater
volume and shorter run time; however, the ACT test cannot be used to obtain the
0.01 ug/L PCP detection .limit required. One liter of water from the ACT test
represents months of run time through the small ACT carbon absorber. The normal
PCP detection limit obtained in the ACT test is I ug/L (by GC).
Raleigh
179280-10 DCC#R0042 5/91 2 -I
'i
• •
Laboratory carbon isotherm tests could not be used to predict carbon usage rates
because of the dilute concentrations of PCP and PCDD/PCDF expected in the
groundwater.
The details of the carbon column treatability study are presented in Section 3.0.
2.2 Soil
The treatability testing of site soil samples will be performed by GRC to evaluate
the effectiveness of the APEG™ chemical dechlorination treatment process.
GRC requires 2 kg (4.4 lbs) of soil for testing. To help ensure that the site soil
samples to be tested contain detectable concentrations of PCP and PCDD/PCDF,
two separate 13-pound grab samples of surface soil were collected by Keystone
Environmental Resources, Inc. (Keystone) personnel at sample point X-48 (near the
treatment cylinder). Results of characterization work performed as part of the
Remedial Investigation (RI) at this location indicated that elevated concentrations
of PCP and PCDD/PCDF are present. Both soil samples were shipped from the
site to GRC by overnight delivery. One sample will serve only as a back-up sample
in the event that the first soil sample characterized contains very low or non-
detectable concentrations of PCP and/or PCDD/PCDF.
GRC personnel will screen the soil sample to be tested and reject particles that are
larger than 1/4 inch in diameter. After completing the testing, GRC will return
both the unused and treated site soil samples, along with the rejected particles,
reagent, and wash waters generated, to Keystone for storage at the Morrisville site
until the material can be handled during remediation.
Details of the APEG™ treatability are presented in Section 4.
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3.0 ACTIVATED CARBON COLUMN STUDY
3.1 Technical Approach
The PCP concentration in the groundwater sample is expected to be 1 mg/Lor less,
and the PCDD/PCDF concentration is anticipated to be 0.02 ng/L or less.
Activated carbon has a high affinity for adsorbing PCP; therefore, it is expected that
a large volume of groundwater will have to be treated through the columns before
PCP breakthrough will occur.
Physical characteristics of PCDD/PCDF compared to PCP indicate that
breakthrough of PCDD/PCDF should occur after PCP breakthrough.
PCDD/PCDF have a lower solubility, higher molecular weight, and a greater
affinity to adsorb to particles; therefore, PCDD/PCDF breakthrough should occur
after PCP breakthrough.
Carbon column studies performed on similar groundwater indicated that at an
average groundwater PCP concentration of 0.46 mg/L, the estimated carbon usage
rate for PCP was 0.17 lb/1,000 gal. The average isopropylether (IPE) influent
concentration was 0.097 mg/Land the estimated carbon usage rate for IPE was 0.15
lb/1,000 gal. The carbon usage rate for the Morrisville site groundwater is expected
to be similar in magnitude.
Due to the constraints of time and budget, approximately 1,000 gallons of site
groundwater will be treated in the proposed carbon column treatability experiment.
It may be possible that no PCP breakthrough will occur after treating the 1,000
gallon groundwater sample. If this is the case, the carbon usage rate can be
reported as less than 0.5 lb/1,000 gal ofsite groundwater treated.
3.2 Procedure
The treatment system will consist of a sand filter column followed by two 4-foot
high, I-inch diameter glass columns, each packed with three feet of activated carbon
(0.0164 cubic feet). The carbon columns will be operated in series with the
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groundwater pumped downflow through the columns to provide a 15 minute contact
time.
The sand filter and carbon columns will be backwashable
accumulated solids that may create pressure in the columns.
installed before and after the sand filter will be monitored daily.
to remove any
Pressure gauges
Table 3-1 summarizes the number of analyses to be performed during the carbon
column study. A composite sample from the groundwater will be initially
characterized for pH, PCP, PCDD/PCDF, iron, manganese, and TOC upon arrival
at Keystone. The groundwater influent to the carbon columns will be analyzed for
PCP, TOC, iron, and manganese three additional times during the study. The
influent will be analyzed twice for PCDD/PCDF, once initially and again at PCP
breakthrough ( or at the end of the study if no PCP breakthrough occurs).
The effluent samples from carbon Column # 1 will be collected daily and
refrigerated for possible future submittal for PCP and TOC analyses. The effluent • from Column #1 will be analyzed once each week for PCP and TOC, and three
times during the study for iron and manganese. If PCP breakthrough occurs in
Column #1 before all of the water is treated, daily effluent samples from carbon
Column #2 will be refrigerated and analyzed once per week for PCP and TOC, and
three times for iron and manganese. The effluent from Column # 1 will be sampled
for PCDD/PCDF at PCP breakthrough or at the end of the study if no PCP
breakthrough occurs.
The carbon columns will be attended daily by Keystone laboratory personnel. The
influent flowrate will be measured daily and adjusted if needed. The pressure in the
sand filter column will be monitored daily and backwashed as needed. If PCP
breakthrough is detected in the weekly Column # 1 effluent sample analyzed, the
previous six daily effluent samples which were banked in the refrigerator will be
analyzed for PCP. This technique will he! p to determine when PCP breakthrough
occurred.
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Parameter
PCP
IRON
MANGANESE
TOC
PCDD/PCDF
TREAT ABILITY
LAB pH
NOTES:
IX= One time
2X = Two times
3X = Three times
4X = Four times
I W = Once per. week
• TABLE 3-1
ANALYTICAL SAMPLING SCHEDULE
11 WEEK CARBON COLUMN STUDY
Frequency
Sample of EPA
Location Analysis Method
Influent 4X 515
Column #I !W 515
Column #2• IW 515
Influent 4X 200.17
Column #I JX 200.17
Column #2• JX 200. 17
Influent 4X 200.17
Column #I JX 200.17
Column #2• JX 200.17
Influent 4X 415.1
Column #I !W 415.1
Column #2• IW 415.1
Influent 2X 8290
Column #I IX 8290
Column #2• IX 8290
Influent !W !50. l
Column #I IW 150.1
Column #2 !50. l
• only after breakthrough of Column #I
3-2a
DCCR0042 5191
Number
of
Samples
4
II
4
4
4
4
4
11
2
II
II
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4.0 APEG-PLusn1 SOIL TREATME!\1 STUDY
The APEGTM process is a patented alkaline dechlorination treatment technology
which breaks the chlorine bonds in chemicals of interest such as PCP and
PCDD /PCDF. These aromatic halide compounds are chemically changed by
reacting with the APEG™ reagent. According to GRC, "the reagent mixture
dehalogenates the aryl halide contaminant to form a glycol ether, which may further
degrade to form a totally dechlorinated species. The products formed have been
tested and have shown very low toxicity (LOSO > 5,000 mg/kg) and do not appear to
bioaccumulate or cause mutagenic effects."
GRC claims to have performed approximately thirty treatability studies to date, all
successful and primarily for Superfund sites. Soils are typically cleaned to 1 ug/kg
PCDD/PCDF and less than 2 ug/kg PCP.
4.1 Procedure
The site soil is placed into a reactor tank, slurried and heated to 15QoF with a
proprietary chemical reagent. The reaction time for PCP is usually about 10 hours.
Soil samples are withdrawn from the reactor periodically for PCP analysis to
determine the extent of treatment. Once sufficiently treated, the soil/reagent slurry
is discharged, centrifuged, and rinsed with water to recover the chemical reagent.
Clean soil is conveyed from the centrifuge with wash and rinse waters that have
been generated during the process. The APEGTM process is a closed process, with
no air emissions.
During treatability testing, an _initial reaction will be run to determine if the site soil
can be treated by APEG™. If the initial run is successful, an optimization run will
be performed. During the optimization run, several parameters will be varied to
determine the most economic and effective reaction. The parameters to be varied
during optimization will be determined based on the initial reaction.
GRC uses a PCP analysis method which is specifically designed to avoid
interferences with their reagent and differs from standard EPA-specified methods
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for soil analysis. Outside laboratories are used for confirmation of PCP
concentrations, and any other chemical analyses, using EPA test methods.
GRC will analyze the untreated soil sample for PCP and send out a split sample
portion of the untreated soil sample for PCDD/PCDF analyses. Keystone will split
both treated and untreated soil samples from the most successful optimization run
with GRC for PCP analyses. Triangle Laboratories will perform PCDD/PCDF
analysis of treated and untreated soil samples from the most successful optimization
run.
After completion of the treatability study, all residuals such as spent reagent,
rejected particles, and wash water will be contained appropriately and returned to
the site for handling during remediation. If APEG™ is selected as the final
alternative for full-scale remediation, handling of residuals will be evaluated during
the Remedial Design.
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5.0 TREATABILilY STUDY REPORT
At the conclusion of the groundwater and soil treatability evaluations, a report will
be prepared which summarizes the work performed, analytical results, and
conclusions regarding the applicability of the technologies for use at the Morrisville·
site. The ·Treatability Report will be included as an appendix to the Feasibility
Study Report for the Morrisville site. Table 5-1 presents an example Table of
Contents for the Treatability Report.
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TABLE 5-1
EXAMPLE TABLE OF CONTENTS
TREATABILITY STUDY
MORRISVILLE, NORTH CAROLINA
EXECUTIVE SUMMARY
1.0 INTRODUCTION
2.0 SAMPLE COLLECTION AND HANDLING
2.1 Groundwater
2.2 Soil
3.0 ACTIVATED CARBON COLUMN GROUNDWATER STUDY
3.1 Technical Approach
3.2 Procedure
3.3 Chronology of Events
3.4 Treatability Results
3.5 Analytical Results
3.6 Spent Carbon Disposal/Regeneration
3.7 Cost Estimation
3.8 Conclusions and Recommendations
4.0 APEG™ SOIL TREATABILITY STUDY
4.1 Technical Approach
4.2 Procedure
4.3 Chronology <if Events
4.4 Galson Treatability Results
4.5 Analytical Results
4.6 Cleaned Soil Backfill/Disposal Issues
4.7 Cost Estimation
4.8 Conclusions and Recommendations
5.0 REFERENCES
APPENDICIES
LIST OF TABLES
LIST OF FIGURES
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6.0 SCHEDULE
The schedule to perform the treatability work described in this document is limited
by the need to receive information concerning the feasibility of the selected
technologies in sufficient time to be used during preparation of the Feasibility
Study, and the Treatability Study Report described in Section 5.0 must be completed
for inclusion as an Appendix to the Feasibility Study Report. Table 6-1 presents the
schedule for implementation of the treatability studies described by this document.
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TABLE 6-1
SCHEDULE FOR
IMPLEMENTATION OF TREAT ABILITY WORK
Task Start Finish
I. Sample Collection 0 14
2. Carbon Column Study 15 91
3. Initial Groundwater Analysis 15 56
4. Final Treated Groundwater Analysis 92 133
5. APEG-PLUS(TM) Study (1) 22 91
6. Activated Carbon Report Preparation 106 161
NOTES:
( l) Report preparation is included as part of this task.
DCCR0042 5/91
6-la
Duration
14
77
42
42
70
56
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7.0 REFERENCES
Confidential Client: Treatability Report PCP Contaminated Process Water, British
Columbia, April 10, 1991.
In-house bench scale and pilot scale data for an ozone/UV and activated carbon
groundwater treatment system for a window manufacturer in Wisconsin.
"Characterization/Treatability Study Report, Koppers Company, Inc. Feather River
Plant", Water Quality Engineering, July 1986.
Pilot scale treatability data evaluating activated sludge, trickling filter, aeration tank,
activated carbon, biofiltration and Engineered BioDegradation Study5m
technologies for the Feather River California Site, Keystone Environmental
Resources, Inc. 1985.
Confidential Client: Wastewater Treatability Study II, Treated Wood Products
Plant, South Carolina, Water Quality Engineering, Keystone Environmental
Resources, July 1986.
"Results of Field Work . Evaluating Engineered BioDegradation Systemsm
Treatment of Soils at a Former Wood Treating Site Located at Nashua New
Hampshire", Keystone Environmental Resources,lnc. October.1988.
Magee, B.R., Milicic, E., Prince, J., and J.N. Motwani, 1990. 'The Treatment of
Soils Containing DDT and Related Compounds Using Chemical
Dechlorination," for the American Institute of Chemical Engineers Summer
National Meeting, "Environment, Energy & Safety: Challenges,
Opportunities, Solutions," August 19-22, 1990. Session: Application of
Reaction Engineering to Aid Degradation and Detoxification of Toxic
Pollutants. Unpublished; Roy F. Weston, Inc.
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des Rosiers, Paul E., "Chemical Detoxification of Dioxin-Contaminated Wastes
Using Potassium Polyethylene Glycolate," Chemosphere, Vol. 18, Nos. 1-6
pp. 343-353, 1989, printed in Great Britain.
DeMarini, D.M. and J.E. Simmons, "Toxicological Evaluation of By-Products from
Chemically Dechlorinated 2,3,7,8-TCDD," Chemosphere, Vol. 18, Nos. 11/12
pp. 2293,2301, 1989, printed in Great Britain.
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The total 1,000-gallon sample of groundwater will be treated. The columns will
continue to be operated if PCP breakthrough occurs in Column #1 and effluent
monitoring from Column #2 will then be performed.
If activated carbon adsorption is selected as the preferred remedial alternative in
the approved FS Report, an evaluation of treatment and/or disposition of residuals
(spent carbon) from a full-scale carbon adsorption system will be conducted during
the Remedial Design.
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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
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
Remedial Project Manager
Waste Management Division
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
April 23, 1991
William L. Meyer
Director
Subject: Koppers Co., Inc. NPL Site
Morrisville, NC
Comments on Treatability Study Work Plan
Dear Ms. Benoy:
Please find listed below my comments and questions on the subject Treatability Study
Work Plan.
Page, Par.
1-1, 3
2-1, 1
Comments
I. What concentration ranges of PCP, PCDD/PCDF, IPE and other
contaminants were measured in groundwater and soil at the site
during Rounds I and 2 of the RI?
2. How were treatment goals set?
3. What is the treatment goal for PCDD/PCDF in groundwater?
I. Which well was the water drawn from, PW-1 or C-29B? Which
well is 49 feet deep, PW-I or C-29B? If the water was taken from
PW-I, are we assuming that since PW-I is of similar depth to C-
29B and that since C-29B contained no PCDD/PCDF in round 1,
that the water from PW-1 is also PCDD/PCDF free? What about
PCP contamination? If this water is free of contaminants, why was
it chosen for use in the treatability study?
•
Ms. Barbara Benoy
April 23, 19191
Page 2
2-1, 2
2-1, 3
2-2, 4
3-1, 3
3-2, 3
3-2, 4
•
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•
What concentrations of PCP and PCDD/PCDF were measured in
C-30? Why were these two wells (PW-I and C-30) selected to
supply water for the treatability study?
What does ACT stand for?
2. What are the "low concentrations" of PCP in groundwater?
I.
I.
I.
What levels of PCP, PCDD/PCDF were measured at X-48? Is this
the location of highest contamination at the site?
How do these concentrations compare to the average concentrations
of PCP, IPE and PCDD/PCDF's in groundwater at the Morrisville
site? Can the concentrations measured on site be provided in the
Treatability Study?
Does "a composite sample from the groundwater" refer to a
mixture of the two 500-gallon samples previously discussed?
2. Why were the parameters pH, PCP, PCDD/PCDF, iron,
manganese, & TOC selected for initial characterization of the
groundwater? Are other contaminants (ie. phenols, IPE) present
in groundwater which might compete for binding sites on the
carbon? Should the presence of these other contaminants be
characterized?
3. Will the groundwater influent to the carbon columns be collected
before or after sand filtration?
4. What is the purpose of the 3 additional samplings of the influent
prior to carbon adsorption?
5. What is the purpose of monitoring the PCDD/PCDF level in the
influent at the time of PCP breakthrough in the effluent?
I. What volume of the effluent from Column #1 will be collected
daily? Will equal portions of the daily effluent samples be
combined and mixed for the weekly samples for PCP and TOC?
2. Could PCDD/PCDF breakthrough occur before or after PCP
breakthrough? If so, how will this be monitored?
•
Ms. Barbara Benoy
April 23, 1991
Page 3
3-2a
4-1, 2
4-1, 3
4-2, 2
•
1.
1.
1.
•
What are the breakthrough levels which will be monitored for each
parameter? Detection limits?
How do the typical soil clean-up levels listed for PCDD/PCDF
(lug/kg) and PCP (2 ug/kg) compare with the levels present in soil
at this site?
What are the waste products generated by this process? Are less
halogenated species, such as vinyl chloride, formed? How are
these reaction products and their concentrations monitored? Do
residual dechlorinated or less chlorinated species remain bound to
"cleaned" soil particles or are these washed off and recovered with
the APEG reagent?
2. What is the reaction time for PCDD/PCDF's? If the soil/reagent
slurry is only monitored for PCP's, how can you tell when
PCDD/PCDF's are sufficiently treated?
1. How does the untreated soil sample initally analyzed by GRC differ
from the untreated soil sample for the most successful optimization
run analyzed by KER and GRC?
Thank you for the opportunity to review and submit comments on this Treatability Study
Work Plan. I would appreciate a copy of any information forwarded to you by KER in response
to my questions. If you require any additional information, please contact me at [phone] .'
PD/kc
Sincerely,
Pat DeRosa, Head
CERCLA Branch
NC Superfund Section
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/-----,, -----------------------------\ _,..,,,' ,
r/c.;;
ROUTING AND TRANSMITTAL SLIP "-I I
Date
TO: (Name, office symbol, room nurriber, I Initials Date ·11ng, Agency/Post) ,. + [)Ll't A A.
2. /J(I.J')f.f:1 Al !2__
3.
.
4.
5.
Action File Not& and Return Approval For Clearance Per Conversation (" :.:. Requested'> For Correction Prepare Reply Circulate For Your Information See Me Comment Investigate Sig.nature Coordination Justify REMARKS.
I
OO·_NOT use this form as a RECORD of approvals, concurrences, disposals, clearances, and similar actions FROM: /Name, org. symbol, Agency/Post) Room No.-Bldg.
•
•
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
April 8, 1991
Koppers superfund site
Morrisville, North Carolina
Barbara H. Benoy
Remedial Project Manager
waste Management Division
Review Team
Please find a copy of the Treatability study Work Plan for the
subject site. Due to the fact that the document is only eleven
pages, a two week turn-around time is requested. Please provide
written comments to me no later than April 23, 1991. Do not hesitate
to contact me if you cannot meet this schedule or if you have any
questions concerning the site. Your cooperation in this matter is
appreciated.
Attachment
Pat DeRosa
Winston smith
Jim Scarbrough
Bernie Hayes
Elmer Akin
Chuck Pietrosewicz
Terry Lyons
NCDEHNR ✓ ,;l/o e,,,._cls<,lA-'1.-<_., -{1,cuJrv-t,.,J-~
Air Division J_,,)u_-v:ju th<-µ,,,~
RCRA I ()
Water Division
Waste Division
ATSDR
EPA-START
• KEYSTONE
E~\'IRl),\':'-IE:-;T.\L RES<HiRU:S, l,\C.
3000 Tech Center Drive
/v1onroeville, PA 15746
412 825-9600
FAX [phone]
April 2, 1991
HAND DELIVERED
Ms. Barbara Benoy
NC/SC Site Management Unit
Superfund Branch, Waste Management Division
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Ms. Benoy:
RE: Treatability Study Work Plan
Koppers Site -Morrisville, NC
Beazer East, Inc.
•
Ref. No. 179280-10
On behalf of Shannon Craig and Beazer East, Inc., Keystone Environmental
Resources, Inc. is pleased to submit for your review four bound copies and one
unbound copy of the Treatability Study Work Plan for the Morrisville, North
Carolina site. This Work Plan is a more detailed outline of the treatability work we
discussed with you during our meeting on March 6, 1991. \Ve request that you send
one of the enclosed copies to Mr. Terry Lyons at EP A's Risk Reduction Laboratory
in Cincinnati, Ohio, for his review. ·
During our meeting, it was brought to Keystone's attention that Standard Operating
Procedures (SOP) for various treatability studies have been or are being developed
by the EPA. These SOPs would be very helpful to Keystone in performing
treatability studies for the Morrisville site. \Ve would greatly appreciate_ your
assistance in obtaining copies of any of the treatability study SOPs which are
available to you. ·
If you have any questions or comments regarding the \Vork Plan, please contact me
at [phone] or Shannon Craig at [phone] ..
Vc:r-; ;ruly yours,
IJ , C/JI · 1
/k~~·• 1/fc(a-J!~Z
Diane E. McCausland
P:-oject ~v1anager
DEM:dac dm-57
cc.: Pat DeRosa (NC Superfund Branch)
Shannon Craig (Beazer)
John Mitsak (Keystone)
;.._ CHESTER Er,vircnrr.er,;al _Cor.ioany
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TREATABILI'IY STUDY WORK PLAN
KOPPERS SUPERFUND SITE
MORRISVILLE, NORTH CAROLINA
Prepared for:
BEAZER EAST, INC.
436 SEVENTH A VENUE
PITTSBURGH, PENNSYLVANIA 15219
Prepared by:
KEYSTONE ENVIRONMENTAL RESOURCES, INC.
3000 TECH CENTER DRIVE
MONROEVILLE, PENNSYLVANIA 15146
PROJECT NO. 179280
APRIL 1991
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION .................................................................................................. 1-1
2.0 SAMPLE COLLECTION AND HANDLING ................................................... 2-1
2.1 Groundwater .............................................................................................. 2-1
2.2 Soil ............................................................................................................... 2-2
3.0 ACTIVATED CARBON COLUMN STUDY ...................................................... 3-1
3.1 Technical Approach .................................................................................. 3-1
3.2 Procedure .................................................................................................... 3-1
. 4,0 APEG-PLUS™ SOIL TREATMENT STUDY .................................................. 4-1
4.1 Procedure .................................................................................................... 4-1
5.0 TREATABILITY STUDY REPORT .................................................................... 5-1
6.0 SCHEDULE ............................................................................................................ 6-1
LIST OF TABLES
3-1 Analytical Sampling Schedule .... : ................... : ...................................... 3-2a
6-1 Schedule for Implementation of Treatability Work .......................... 6-la
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1.0 INTRODUCTION
Beazer East, Inc. (BEi) submitted a final revised Work Plan to the United States
Environmental Protection Agency (USEPA) in November 1989 to perform a
Remedial Investigation and Feasibility Study (RI/FS) at the Morrisville, North
Carolina site. A preliminary technical screening of candidate remedial technologies
for possible remediation of the site was performed as part of the Work Plan. Each
of the technologies was screened for applicability based upon site specific
characteristics, waste characteristics, technology feasibility, and implementability.
This document is a Treatability Study Work Plan for a laboratory evaluation of two
of the potentially effective remedial technologies: .(1) activated carbon adsorption
for site groundwater and (2) the APEG-Plus™ chemical dechlorination process
from the Galson Remediation Corporation (GRC) for site soils. For both
groundwater and soils the target parameters of concern are pentachlorophenol
(PCP) and polychlorinated · dibenzodioxins/polychlorinated dibenzofurans
(PCDD/PCDF).
For the purposes of the treatability evaluations described in this document, several
treatment goals have been specified. The goal for PCP in groundwater is 0.01 ug/L
and the goals for PCP and dioxins/furans in soils are 10 mg/kg and 1 ug/kg,
respectively. These treatment goals are not to be construed as site clean up levels
because no such determination has yet been completed. It is anticipated that site
clean up goals will be greater than the treatment goals specified in this document.
This Work Plan is divided into six sections. Section 2.0 describes the samples which
will be collected for testing and the ways in which they will be handled. Sections 3.0
and 4.0 present the procedures for aciivated carbon column testing and APEG™
soil treatment testing. Section 5.0 describes the Treatability Study Report which will
be prepared after completion of the studies and attached to the Feasibility Study
(FS) report, and Section 6.0 includes the schedule for implementation of the Work
Plan.
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2.0 SAMPLE COLLECTION AND HANDLING
2.1 Groundwater
The laboratory carbon column study will treat approximately 1,000 gallons of
groundwater. Half of the water was collected during a pump test in February 1991
performed at PW-1, a pumping well located near monitoring well C-29B. This well,
located along the eastern plant border, north of the fire pond, is 49 feet deep into
the bedrock groundwater aquifer. Results from Round 1 sampling of C-29B
indicated that no PCDD/PCDF were detected above the method detection limit of
0.001 ng/L. Generally, results from sampling and analysis of deeper (B or C) wells
indicated that no PCDD/PCDF was present in those wells.
The other half of the treatability sample was collected fr9m well C-30, a shallow
well near the northern plant boundary, in the former landfarm area. C-30 contains
detectable concentrations of PCDD/PCDF based upon Round 1 groundwater
sampling and analysis. Past sampling has also indicated that well C-30 contains low
concentrations of PCP. If needed, the groundwater treatability samples can be.
spiked with PCP before use in the carbon column study. J'--"1J-.AC ~ "irG l,.c, ·
I -:; , I ..--/.'. )C,.···· \"
Upon review of three laboratory carbon treatment options,( ACT tes,t, carbon ------isotherms, and column study, it was recommended that, due to the low
concentrations of PCP in the groundwater, a carbon column study would be
necessary to detect PCP breakthrough at the 0.01 ug/L detection limit desired for
the site. The column study will generate sufficient sample volumes so that PCP
analysis can be conducted by Method 515, which requires a 1 liter sample volume,
and the sample will still be representative of a time period which can reasonably be
scaled up to full-scale.
Calgon's ACT test was evaluated for use because it requires a smaller groundwater
volume and shorter run time; however, the ACT test cannot be used to obtain the
0.01 ug/L PCP detection limit required. One liter of water from the ACT test
represents months of run time through the small ACT carbon absorber. The normal
PCP detection limit obtained in the ACT test is 1 ug/L (by GC).
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Laboratory carbon isotherm tests could not be used to predict carbon usage rates
because of the dilute concentrations of PCP and PCDD/PCDF expected in the
groundwater.
The details of the carbon column treatability study are presented in Section 3.0.
2.2 Soil
The treatability testing of site soil samples wiH be performed by GRC to evaluate
the effectiveness of the APEG™ chemical dechlorination treatment process.
GRC requires 2 kg (4.4 lbs) of soil for testing. To help ensure that the site soil
samples to be tested contain detectable concentrations of PCP and PCDD/PCDF,
_ two separate 13-pound grab samples of surface soil were collected by Keystone
Environmental Resources, Inc. (Keystone) personnel.at.sample point X-48 (near the
treatment cylinder). Results of characterization work performed as part of the
Remedial Investigation (RI) at this location indicated that elevated concentrations
of PCP and PCDD/PCDF are present. Both soil samples were shipped from the
site to GRC by overnight delivery. One sample will serve only as a back-up sample
in the event that the first soil sample characterized contains very low or non-
detectable concentrations of PCP and/or PCDD/PCDF.
GRC personnel will screen the soil sample to be tested and reject particles that are
larger than 1/4 inch in diameter. After completing the testing, GRC will return
both the unused and treated site soil samples, along with the rejected particles,
reagent, and wash waters generated, to Keystone for storage at the Morrisville site
until the material can be handled during remediation.
Details of the APEG™ treatability are presented in Section 4.0.
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3.0 ACTIVATED CARBON COLUMN STUDY
3.1 Technical Approach
The PCP concentration in the groundwater sample is expected to be 1 mg/Lor less,
and the PCDD/PCDF concentration is anticipated to be 0.02 ng/L or less.
Activated carbon has a high affinity for adsorbing PCP; therefore, it is expected that
a large volume of groundwater will have to be treated through the columns before
PCP breakthrough will occur.
Physical characteristics of PCDD/PCDF compared to PCP indicate that
breakthrough of PCDD/PCDF should occur after PCP breakthrough.
PCDD/PCDF have a lower solubility, higher molecular weight, and a greater
affinity to adsorb to particles; therefore, PCDD/PCDF breakthrough should occur
after PCP breakthrough.
Carbon column studies performed on similar groundwater indicated that at an
average groundwater PCP concentration of 0.46 mg/L, the estimated carbon usage -
rate for PCP was 0.17 lb/1,000 gal. The average isopropylether (IPE) influent
concentration was 0.097 mg/L and the estimated carbon usage rate for IPE was 0.15
lb/1,000 gal. The carbon usage rate for the Morrisville site groundwater is expected
to be similar in magnitude.
Due to the constraints of time and budget, approximately 1,000 gallons of site
groundwater will be treated in the proposed carbon column treatability experiment.
It may be possible that no PCP breakthrough will occur after treating the 1,000
gallon groundwater sample. If this is the case, the carbon usage
reported as less than 0.5 lb/ 1,000 gal of site groundwater treated.
3.2 Procedure
rate can be
The treatment system will consist of a sand filter column followed by two 4-foot
high, I-inch diameter glass columns, each packed with three feet of activated carbon
(0.0164 cubic feet). The carbon columns will be operated in series with the
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groundwater pumped downflow through the columns to provide a 15 minute contact
time.
The sand filter and carbon columns will be backwashable to remove any
accumulated solids that may create pressure in the columns.
installed before and after the sand filter will be monitored daily.
Pressure gauges i\d-QA\ ir)
·7 r, -~ ,,-(/ c
' ,f
-~-
✓
Table 3-1 summarizes the number of analyses to be performed during the car!Son
column study. A 5omposite samp~ from the groundwater will be in)tially
characterized for pH, PCP, PCDD/PCDF, iron, manganese, and TOC upon arrival
I at Keystone. The groundwater influent to the carbon columns will be analyzed for _
PCP, TOC, iron, and manganese three additional times during the study. The
influent will be analyzed twice for PCDD/PCDF, once initially and again at PCP
breakthrough ( or at the end of the study if no PCP breakthrough occurs).
,ii)',:'·, The effluent samples from carbon Column #1 will be collected daily and
0 refrigerated for possible future s~bmittal for PCP and TOC analyses. The effluent
from Column #1 will be analyzed once each week for PCP and TOC, and three
times during the study for iron and manganese. If PCP breakthrough occurs in
Column # 1 before all of the water is treated, daily effluent samples from carbon/
Column #2 will be refrigerated and analyzed once per week for PCP and TOC, and
three times for iron and manganese. The effluent from Column #1 will be sampled
for PCDD/PCDF at PCP breakthrough or at the end of the study if no PCP
breakthrough occurs.
The carbon columns will be attended daily by Keystone laboratory personnel. The
influent flowrate will be measured daily and adjusted if needed. The pressure in the
sand filter column will be monitored daily and backwashed as needed. If PCP.
breakthrough is detected in the weekly Column # 1 effluent sample analyzed, the
previous six daily effluent samples which were banked in the refrigerator will be
analyzed for PCP. This technique will help to determine when PCP breakthrough
occurred.
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Parameter
PCP
IRON
MANGANESE
TOC
PCDD/PCDF
TREAT ABILITY
LAB pH
NOTES:
IX= One time
2X = Two times
3X = Three times
4X = Four times
I W = Once per week
• TABLE 3-1
ANALYTICAL SAMPLING SCHEDULE .
11 WEEK CARBON COLUMN STUDY
Frequency
Sample of EPA
Location Analysis Method
Influent 4X 515
Column #I IW 515
Column lf2,• IW 515
Influent 4X 200.17
Column #1 3X 200.17
Column lf2. • 3X. 200.17
Influent 4X 200.17
Column #I 3X 200.17
Column lf2. • 3X 200.17
Influent 4X 415.1
Column #I IW 415. I
Column lf2. • IW 415.1
Influent 2X 8290
Column #I IX 8290
Column lf2. • IX 8290
Influent IW 150.1
Column #I IW 150.1
Column lf2. ISO.I
• only after breakthrough of Column #I
3-2a
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of
Samples
4
II
4
4
4
4
4
II
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The total 1,000-gallon sample of groundwater will be treated. The columns will
continue to be operated if PCP breakthrough occurs in Column # 1 and effluent
monitoring from Column #2 will then be performed.
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4.0 APEG-PLUsni SOIL TREATMENT STUDY
The APEG™ process is a patented alkaline dechlorination treatment technology
which breaks the chlorine bonds in chemicals of interest such as PCP and
PCDD/PCDF. These aromatic halide compounds are chemically changed by
reacting with the APEG™ reagent. According to GRC, "the reagent mixture
dehalogenates the aryl halide contaminant to form a glycol ether, which may further
degrade to form a totally dechlorinated species. The products formed have been
tested and have shown very low toxicity (LDS0 > 5,000 mg/kg) and do not appear to
bioaccumulate or cause mutagenic effects."
GRC claims to have performed approximately thirty treatability studies to date, all
successful and primarily for Superfund sites. Soils are typically cleaned to 1 ug/kg
PCDD/PCDF and less than 2 ug/kg PCP.
4.1 Procedure
The site soil is placed into a reactor tank, slurried and heated to lSQoF with a
proprietary chemical reagent. The reaction time for PCP is usually about 10 hours.
Soil samples are withdrawn from the reactor periodically for PCP analysis to
determine the extent of treatment. Once sufficiently treated, the soil/reagent slurry
is discharged, centrifuged, and ri,nsed with water to recover the chemical reagent.
Clean soil is conveyed from the centrifuge with wash and rinse waters that have
been generated during the process. The APEG™ process is a closed process, with
~ no air emissions.
During treatability testing, an initial reaction will be run to determine if the site soil
can be treated by APEG™. If the initial run is successful, an optimization run will
be performed. During the optimization run, several parameters will be varied to
determine the most economic and effective reaction. The parameters to be varied
during optimization will be determined based on the initial reaction.
GRC uses a PCP analysis method which is specifically designed to avoid
interferences with their reagent and differs from standard EPA-specified methods
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for soil analysis. Outside laboratories are used for confirmation of PCP
concentrations, and any other chemical analyses, using EPA test methods.
GRC will analyze the untreated soil sample for PCP and send out a split sample
portion of the untreated soil sample for PCDD/PCDF analyses. Keystone will split
both treated and untreated soil samples from the most successful optimization run
with GRC for PCP analyses. Triangle Laboratories will perform PCDD/PCDF
analysis of treated and untreated soil samples from the most successful optimization
run.
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5.0 TREATABILI1Y STUDY REPORT
At the conclusion of the groundwater and soil treatability evaluations, a report will
be prepared which summarizes the work performed, analytical results, and
conclusions regarding the applicability of the technologies for use at the Morrisville
site. The Treatability Report will be included as an appendix to the Feasibility
Study Report for the Morrisville site .
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6.0 SCHEDULE
The schedule to perform the treatability work described in this Work Plan is limited
by the need to receive information concerning the feasibility of the selected
technologies in sufficient time to be used during preparation of the Feasibility
Study, and the Treatability Study Report described in Section 5.0 must be completed
for inclusion as an Appendix to the Feasibility Study Report. Table 6-1 presents the
· schedule for implementation of this Work Plan.
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SCHEDULE FOR
IMPLEMENTATION OF TREAT ABILITY WORK
Task Start Finish
I. Sample Collection 0 14
2. Carbon Column Study 15 91
3. Initial Groundwater Analysis 15 56
4. Final Treated Groundwater Analysis 92 133
5. APEG-PLUS(TM) Study (I) 22 91
6. Activated Carbon Report Preparation 106 161
NOTES:
(I) Report preparation is included as part of this task.
DCCR0042 2/91
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Duration
14
77
42
42
70
56