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HomeMy WebLinkAboutNCD003200383_19960502_Koppers Co. Inc._FBRCERCLA C_General Correspondence 1988 - 1996-OCRI• • Memorandum Date: May 2, 1996 To: David Lown Environmental Engineer NC Superfund Section From: Douglas Moore Environmental Chemist NC Superfund Section • Subj.: Notes on April 30, 1996 Meeting between Cummings-Riter, Consultants, Inc. and Watec, L.P. Koppers Company, Inc. Morrisville, North Carolina US EPA ID: NCO 003 200 383 On April 30, I 996, Doug Moore of the NC Superfund Section traveled to the Koppers Co. NPL .•site to oversee a meeting between members of Cummings-Riter Consultants and Watec. Doug arrived at the site at 10:55 a.m. and met with Mr. Bruce Geno, project engineer with Cummings-Riter Consultants ("Cummings"). The night before the meeting, it had rained heavily. A slow but steady rain came down in the morning and the temperatures were in the upper 60's to low 70's. Mr. Geno provided a brief overview of the surface water remediation at the subject site. Mr. Geno indicated that the surface water remedial action at the Fire pond and the Medlin pond was contracted to Watec. He indicated that the southeast corner of the Fire pond had to be regraded due to surface drainage concerns. Mr. Geno specifically mentioned that a "mud wave" and pockets of standing water were indicators of storm water drainage problems on the surface of the Fire Pond. He characterized these drainage problems as primarily isolated to the Fire pond and not the Medlin pond. Mr. Geno thinks its is due to the differences in grade over the surface of the Fire pond. The site generally slopes to the northeast toward the Fire pond; thus, the grade at the southwest end of the pond is greater than the grade at the northeast end. At 11 :20, a meeting was held between Bruce Geno of Cummings and Joseph Gunn and Rodney Jones of Watec. Mr. Bill Smith of Cummings arrived about 15 minutes into the discussion. Mr. Geno provided a copy of the preliminary punchlist submitted by Cummings to Watec. The punchlist outlines tasks that Cummings wants Watec to complete at the Fire pond and Medlin pond remedial areas. The punchlist had • • 15 items listed for Watec to complete at the Fire pond and 9 items for Watec to complete at the Medlin pond. Mr. Geno had previously discussed these points with Watec, but agreed to review them for the benefit of Doug Moore. A copy of the punchlist with notes about comments made during the meeting is attached. Checkmarks denote tasks suggested by Cummings that have already, or were in the process of being, completed by Watec. 1.0 I.I Meeting Notes Fire Pond Mr. Geno opened the meeting by reviewing the punchlist items for the Fire pond. Of the 15 items on the list, 7 items were cosmetic, 7 items were related to storm water drainage issues and 1 item (abandon monitoring well MW-9) was apparently carried over from previous work. As of April 30, 1996, Watec had completed 5 punchlist items at the Fire pond; 3 items were cosmetic, 1 item was related to storm water drainage and I item was from previous work. The cosmetic items completed include disposal of plastic tubs, removal and disposal of bridge diversion ditch culvert sections and removal of large rocks stockpiled near the Fire pond. Mr. Gunn indicated that Watec had started blading of the Fire pond diversion ditches that morning and would continue to regrade and finally reseed the ditches. Mr. Geno stated that Watec had abandoned monitoring well #9 as requested. Of the remaining items on the punchlist to be completed at the Fire pond, 5 items were cosmetic and 5 items were related to storm water drainage issues. The cosmetic issues consisted of (I) removal and disposal of plastic sheeting and old tires, (2) chipping trees stockpiled by others, (3) removal of limbs and root matter from the Fire pond fill surface, (4) repair of damaged fence east of Fire pond and (5) placing topsoil over the processed fill at the southeast comer of the Fire pond prior to seeding. Mr. Gunn's response to each of these items was: (I) the plastic sheeting and old tires were to be landfilled as construction waste. (2) the trees were going to a mill to be used as pulpwood. (3) Watec would have a Field Technician clean the root matter from the Fire pond surface within the next week. ( 4) the fence contractor would return to the site and repair the damaged fence. (5) Mr. Gunn agreed that the area in question needs to be corrected. Watec will use existing fill on the site and regrade the area. The 5 remaining items address potential storm water drainage issues at the Fire pond. These items are (6) regrade and reseed the disturbed Fire pond perimeter road ditch near the northwest comer, (7) Install an underdrain in the Fire pond (8) Grade the area south of remaining concrete pad at north end of the Fire pond and adjacent to the proposed soil excavation area #3 to drain. (9) Grade the ruts created during disking/planting operations in the Fire pond and (I 0) Fine grade the Fire pond surface. Mr. Gunn's response to each of these items was: (6) Watec will correct Fire pond perimeter road ditch to allow better drainage and reseed. (7) Watec will correct as soon as the weather conditions and the stability of the surface fill permit (at this time, the fill is too wet and too soft to use heavy equipment). (8) Watec will grade the area as soon as the weather permits. Will probably be within the next 2 weeks. (9) Mr. Gunn stated that 2 • Watec will complete regrade and contractor will do the seeding, in probably 2-3 weeks. (10) Mr. Gunn said that Fire pond is too wet to do fine grade with heaiy equipment. Watec will bring in Field Technicians to do hand-work with wheelbarrows and fine grade using the existing fill. Note: The last item included to address Cummings doncerns over standing pockets of water on the fill surface at the Fire pond. Other additional areas discussed include the stabilization of the Fire 1 pond dam, construction and stabilization of a retention basin below the Fire pond dam and construction and stabilization of a headwall on the northwest side of McCririlmons Road. Mr. Smith indicated that the headwall and basin were adjustments from\ the original construction designs that were previously approved by the Superfund Section and EPA. Mr. Gunn indicated that Watec will excavate a section below the Fire pond darn (leaving the dam as much in place as possible) to serve as a retention basin. This\ area will be stabilized by rip-rap to slow the flow rate and control erosion. The main idea is to allow the runoff from the Fire pond to lose energy prior to entering the storrri pipe under ' McCrimmons road. The basin will be constructed in a flare-pattern that will ,hold a larger I volume of runoff and direct it to the headwall and through the pipe under McCrimrnons Road. In addition, Mr. Gunn stated that rip-rap will be placed in the drainage\ ditch on the southeast side of McCrimmons road to slow the flow rate and control erosion as well. Mr. Gunn was concerned about how the construction of the headwall will ~ffect utility lines (water lines) that run along the northwest side of McCrimmons road. Mr. Smith commented that the basin and headwall plan would meet DOT regulations. 1.2 Medlin Pond Mr. Geno continued to outline items on the punchlist to be corrected at the Medlin pond. Of the 9 items listed on the punchlist, 6 items are cosmetic and 3 aie related to ' storm water drainage issues. According to Mr. Geno, Watec has completed 3 of the 6 cosmetic items. These are (I) seed Medlin pond berms and disturbed area d6wnslope of the last berm, (2) remove the Medlin pond perimeter fence and (3) remote and chip remaining logs and limbs. Item (I) is currently under a separate contract fiom Watec. ' Watec is currently in the process of completing item 3. Mr. Gunn will probable place the remaining wood logs and limbs in municipal landfill. He requested inforrilation from the State on facilities that recycle yard waste in Wake county? \ The remaining 3 cosmetic issues outlined by Cummings are: (4) place topsoil over the processed fill at the north end of the Medlin pond, (5) cover the exposed se1diments on the east side and south end of the Medlin pond and (6) remove the plastic fle~ pipe from the overflow drainage ditch connecting the Fire pond and Medlin pond. Mr. Gunn's response to these items was: (4) ?, (5) Watec has already covered the expbsed areas. ' Watec proposed to add geotextile and rock to prevent further erosion. (6) WI atec will remove the plastic pipe at the final regrade. The 3 storm water drainage issues at the Medlin pond were: (7) remove, grade ' and line the overflow drainage ditch leading to the Medlin pond with rock. (8) smooth grade and place seed/soil amendments in removed access road area to Medlin\pond, and (9) fine grade the Medlin pond berms to form a v-shape. Mr. Gunn indicated that: (7) 3 • • Watec will regrade and shape the overflow drainage ditch with a swale that slopes toward the Medlin pond. This area will also be reseeded. (8) Watec currently waiting for weather to break to bring in equipment to reshape the road area so that it slopes towards the Medlin pond (9) The berms do not match those outlined in the original plans. Watec plans to modify the berms to match the plans. They will protect the berms with matting. I Mr. Smith mentioned the as-built drawing that were to be provided to Cummings following completion of the project. Watec agreed to provide a final base\ map of both ponds using 50' x 50' grids showing drainage ditches and lines. Smith commented that I 50' x 50' grids are adequate, but that the surveyor (Post and Associates) should be able tie the points and that map should show the depth of fill, elevations and have co6rdinates. Mr. Geno requested the priority in which the project would be c~mpleted by I Watec. Mr. Gunn indicated that Watec would be working on several of these projects concurrently and that he expects to reseed/stabilize the Medlin porid dam and construction of the headwall and retention basin to take priority. Mr. Gunn ihdicated that some of the regrade projects at both ponds are weather dependent and that hJ could make no promises about the exact completion date. However, if the weather holds) he expected to have the projects completed within 3 week. Mr. Smith and Mr. Gunn agrJed to have a follow-up site inspection, tentatively arranged for May 24, 1996. 2.0 Site Inspection At 12: 15, the entire group walked to the northwest corner of the Fire pond. The ground at this location was saturated and very soft. Fresh grass covers a m./jority of the northwest corner of the Fire pond surface. Small pools of standing water were observed ' on the surface of the Fire pond. Two piles of debris ( one small pile of car tires and one medium pile of trees, stumps and limbs) were observed at the northeast come~ of the Fire pond. We walked to a small brick building and concrete pad at the western edge of the Fire pond. The drainage ditch along the perimeter road northwest of these structures was clogged with fill and debris. As a result, the upgradient areas were drainin~ across the perimeter road and runoff was pooling at the north end of the brick building.I Mr. Gunn I stated that the ditch had been inadvertently blocked and that Watec would clean out the ditch to route the runoff away from the Fire pond. Numerous pools of struiding water were observed over the surface soil at the eastern edge of the concrete pad.\ Mr. Gunn commented that this area was usually wet. This is one the areas to be addressed on the punchlist. \ We walked to the southeast comer of the Fire pond. This area had been recently graded to improve the drainage. However, there were numerous pools of stariding water I over the surface. This is another area to be addressed by Watec as part of the final grade. A small pile of concrete drainage pipes (approx. 12 inch diameter) was obsehed in this area. \ We walked northeast along McCrimmons road to the point where runoff from the Fire pond drains under the road. The vegetation on the northwest side of MdCrimmons road has been cleared from the dam. Some soil was apparently excavated frohl the dam ' face and from the bottom of the ditch that runs parallel to McCrimmons road. A small 4 • cut has been made into the face of the dam to allow runoff to pass through the dam. The dimensions of the cut are estimate to be IO feet wide at the top by 7 feetJ high. A silt fence has been placed across the cut to slow the velocity of runoff leaving the Fire pond. ' A low velocity stream of water was observed running through the cut and down the face of the Fire pond dam to the ditch along McCrimmons road. A buildup of silt and sediment was observed in the ditch at the base of the dam. At this point, the lrunoff enters an 18 inch concrete pipe that directs it underneath McCrimmons road. I Mr. Smith indicated that the headwall will be constructed along the northwest face of McCrimmons road. Mr. Gunn commented that Watec plans to stabilize the basin area with 1rip-rap. We walked southeast to the drainage ditch on the opposite side of McCrimmons road. A 12-14 inch diameter corrugated plastic pipe connected to the conctete drainage pipe, ran through the center of the drainage ditch and under a secondary! access road towards the Medlin pond. According to the punchlist, this pipe will be removed from the drainage ditch. Mr. Gunn confirmed Watec's commitment to grade and line. the drainage ditch with rip-rap to slow the velocity of runoff and control erosion. There was a small pile of wood chips and logs stacked at the north end of the Medlin pond secondary access road adjacent to McCrimmons road. J We walked south along a secondary access road to the north end of the Medlin pond. The Medlin pond has been filled with clean, native soil. Three sfuall earthen berms are constructed at 30-40 foot intervals in the drainage path over the sfuface of the Medlin pond. The berms were designed by EAP, contractors for Beazor East! as part of a wetland mitigation plan. According to Mr. Gunn, EAP recently planted maples, black ' willows and arrowroot over the surface of the Medlin pond to establish a '!'transitional wetland". The surface water backs up behind each of the berms, then through a gap in the berm and flows downgrade to the next berm and ultimately to the Medlin pond dam. According to Mr. Gunn, the berms are designed to slow the runoff long enoJgh to cause the soil behind each berm to become saturated. A silt fence has been placdd along the length of the Medlin pond dam to control erosion. The berms and dam ar~ to be final graded, stabilized and reseeded. We walked back to the trailers and I departed the site at 13:15 p.m. 5 State of North Carolin- Department of Environment, Health and Natural Resources Division of Waste Management James B. Hunt, Jr., Governor Jonathan B: Howes, Secretary William L. Meyer, Director Mrs. Peggy Medlin, Director April 9, 1997 ,__ Copy _MA Z &IIJl!IL J . iiilWI • DEHNR ' Clean Water and Environmental Project for Shiloh 5711 McCrirnmon Parkway Morrisville, NC 27560 RE: Garden Soil Samples Koppers Company, Inc. Site Morrisville, Wake County Dear Mrs. Medlin: Hope Taylor recently informed me that the Board of Directors had not receiv,ed the results of the garden samples collected in 1995 by Beazer. Attached are the results of that sampling (Beazer Monthly Progress Report #27) and the sampling protocol (excerpt from Monthly Progress I Report #26). Fortunately, the samples were reported as non-detect for pentachlorophenol for all four samples collected. If I can answer any questions please contact me at (919) 733-2801, extension 349. Attachments cc: Grover Nicholson P.O. Box 27687. Raleigh, North Carolina 27611-7687 Voice 919-733-4996 Sin~erely, David J. Lown, LG, PE Geological Engineer Superfund Section FAX 919-715C3605 An Equal Opportunity Affirmdtive Action Employer I 50% recycled/10% post-consumer paper /~<--~~:~;/}~~:~.;,.;;~;;,\:-{\::~?·~i~~i;:_.;~:i:/~---:: ;_#;-. ·, ': . ----'-"-'---'"--"----=-\ . -~-,..~-.i~Cr'A-clllUw?plit'nll1-::;11.t::-ae,,sung·-~------·---·----•---------·r-··-----•-------. . . . tio:!:s~~:~~~:g:i~:sr:'0°!~~:~~·rtial dele-lKoppers-ihcineratil» revisited in N.C. The new policy allows sections of NPL sites that Soil remediation at the Koppers Co. NP~ site in Morrisville. N.C .• have been cleaned up or where cleanup is not needed has been held up while EPA decides whether to use base catalyzed to be removed from the NPL to foster economic dechlorinization (BCD) or incineration. \ development. EPA considered excavation and BCD treatment when treatability Partial or full deletions will be considered when studies looked promising. but now is revisitink the original remedy of EPA determines no further cleanup is needed or a incineration as doubts·surface about the effectiveness ·of full-scale BCD release of hazardous substances poses no significant treatment. \ threat to public health or the enviionment. The ROD called for excavation and off-site incineration and Before EPA required an entire site to be cleaned. up · disposal for 1,000 cubic yards of soil contami~ated with pentachlo- -befoie .i(cciuld be drojiped from the lisi. rophenol and dioxin, but allowed for the BCD\contingent if studies An individual. business, state, local government or looked promising. · · federal_agency can petition to delete a site listing. A The PRP. Beazer,East Inc., will solicit bids for the work once state must concur with EPA 's decision to remove a EPA has made a final decision. The project hak been estimated at $1 site or portion of a site. \ million. EPA announced the policy in a Nov. I Federal Register notice. The agency emphasized delisting Meanwhile. Rust Engineering and Wast~ Abatement Technol- does not free responsible parties from liability for site ogy are building a grollndwater pump-and-treatment system at the site. The PRP solicited bids for the work in July1 through its prime cleanup. "Whether property is part of an NPL site is unrelated to CERCLA liability because neither NPL contractor Cummings Riter Consultants Inc.lof Newark, Del. listing nor deletion assigns liability to any party or the (Superfund Week 6/2194). owner of any specific property," the notice said. Site groundwater is contaminated with pentachlorophenol and The policy falls in line with the Clinton adminis-dioxin and will be treated at a rate of IO gallon~ per minute. Treatment tration goals for Superfund, which were outlined by will include flow equalization, removal of susphnded solids and carbon EPA Administrator Carol Browner Oct. 2 (Supe,fund adsorption. \ Week 10/6). EPA ordered Beazer to design and do the cleanup in April 1993. Contact: Hugo Paul Fleischman, EPA, 703-Waste Abatement Technology of Marietta,\Ga., was also selected 603-8769. to dewater two ponds. Water from the two ponds will be treated with Pasha Puhlicarions. 1616 N. Fort Myer Drive, Suite /000, ArlinRtOn, Va. 22209 Supetf1md welk-Novemher JO, 1995 5 Availability key to bioremediation Availability is one of the most critical engineering challenges to the success of soil bioremediation at hazardous waste site, an industry expert contends. "You've got to get the bacteria in contact with the contamination," said Susan Henry. an environmental engineer with Kennedy/Jenks Consultants. Henry's remarks came at theHaz Mat West '95 conference this week in Long Beach, Calif. Making the jump from laboratory-scale to field-scale success is another source of frustration to proponents of the technology. The site-specific conditions dictate what type of technology will work, Henry said. "Each site possesses its own unique challenges," she added. And not all bacteria are created equal. Sometimes microorganisms will work effectively to break down an melange of contaminants, but if the wrong contami- nant is present, the whole system can break down. "Mixtures [of contaminants] have a great impact" on the success of soil bioremediation, Henry said. Trace metals in the soil are a major source of frustration at some sites. Competitive. inhibition also works against some cleanups, as two or more compounds fight for space on a particular enzyme. Client acceptance still poses a barrier to the use of carbon adsorption and the pond area will be backfilled with clean soil. Treated water will be discharged to an on-site dra 1 inage ditch. Glue-laminated wood products were manufaJtured at the site beginning in 1962. Wood treating with PCP ceast!d in 1975. Contact: Beverly Hudson, EPA project minager, 800-435- 9233, ext. 2080; Shannon Craig, Beazer East pioject coordinator, 412-227-2684. Researchers work to define "clean" soil When soil is contaminated with hydrocarbons\ the key question is: How clean is clean? \ The goal is to end up with conditions considered environmentally I acceptable so no further action required. However there is substantial debate on what is an environmentally acceptable c6ncentration of contaminants in soil. \ Research in the past nine years shows hydrocarbons are biode- graded by indigenous soil microorganisms to a con~entration that no longer decreases, or that decreases very slowly, with continued · treatment. 'l Studies by the Gas Research Institute also show reductions in contamination levels below this concentration are lihlited by the availability of the hydrocarbons to the microorganidms. In addition, residual hydrocarbons that remain ~fter biological __ L_LI_ "---·-•--_J__, -'.--'.~---•'-· I ~RYER· ETRO WEDNESDAY, NOVEMBER 8, 1995 .Community ijghts hazardous waste in all bacli yards BY LYNN BONNER STAff WRITER MORRISVILLE -When members of Others I?ay benefit from push for new technology the Shiloh commwtity found out Having the dirt trucked out and they were living next to hazardous burned was unacceptable to resi- waste, U1ey did something sW"pris-·. dents, who empathized with people ing: They fought lo spare some living near hazardous-waste incin- other town from having to take . era tors and landfills. their contaminated tlirL ."There were other neighbor- Not wanting to shove their prob-hoods like ours that would be 1cm onto 0U1er people, residents in affected," said Shiloh resident . U1e predominantly black neighbor-Sarah Harris. "That's why we were hood pushed the federal Environ-.. hoping this process would work." mental Protect.ion Agency to try a Residents were pleased when a new technology that would have 1993 demonstration of the new cleansed the soil at Ute Superfwtd BCD process, which strips soil of site and left it there. . harmful chem_icals, seemed to work. But during tests of the BCD method on tainted soil in Califor• nia this· summer, worrisome amounts of dioxin leaked from Ute machine into the air. So Shiloh residents reluctantly agreed to something they never wanted -having the dirt trucked · to another state; "We tried not to carry our prolr lems to somebody else's baCk yard," said resident Peggy l\ledlin. "We didn't have a choice but to give · up the fighl" State and federal environmental agencies told the community last monU1 that more tests of the BCD process could delay Ute cleanup another year. Even Uten, there's no · guarantee that more lime would fix the dioxin problem, they said. Shiloh is one of a handful of com• munities in the SouU1, most of them black or poor, trying to deal respon- sibly wiUt the poisons Uiat indus- tries have left in their neighbor• hoods, said Hon Nixon of the Insti- tute for Southern Studies. Com- munities searching for new ways to treat tainted soil know it often ends up in landfills near other-pre- dominantly black neighborhoods. "That's what distinguishes the environmental justice movement from Ute 'not in my backyard' men- tality," Nixon said. · Medlin and Hope Taylor, the com- munity's technical advisor, said they were most disappointed by the attitude of ETG Environmental Inc., the company in Blue Bell, Pa., that's developing the soil-cleansing technique. · Even after she learned of the SEE SHILOH, PAGE l 08 • SHILOH CONTINUED FROM PAGE 1 B dioxin leaks in California, Taylor wanted to have the BCD process tested again in Morrisville. But ETG didn't provide satisfactory information on improvements it would make to the air pollution con- trol equipment, or a timetable for finishing them, she said. "We felt pretty disappointed in the performance of the company and their ability to respond in a timely fashion to the concerns of the EPA folks," Taylor said. When the BCD method was test- ed iri Morrisville in 1993, dioXin emissions registered a 4 on the scale used to measure emissions, slightly above the state guideline of 3. When BCD was tested in Cal- .· ifornia this summer, dioxin emis- ,. sions hit 400. For its part, ETG representatives said they have responded to every- one's questions about the BCD technology. The machines worked, but the results were misinterriret- ed, they said "There seems to be a position that if there's any dioxin released, there's a problem," said Steve Detwiler; director of market devel- opment for ETG. "There was an extremely small risk to the com- munity." Nevertheless, the company has improved the process, he said, and will test its new apparatus within the next six months. · "In response to some of these issues, we have developed our third-generation design that would meet a standard of 3," Detwiler said. . Loren Martin, vice president of business development at ETG, said the company would have used the updated technology in Morrisville. "It doesn't look like we'll get that chance, unfortunately." The Koppers Chemical Co. pol- luted the soil and water in Shiloh when it treated wood with penta- chlorophenol, or PCP, between 1968 and 1975. Tainted water was poured into lagoons and sprayed on the ground nearby, contaminat- ing soil, ponds. and groundwater. The EPA estimates that 700 cubic yards of soil will have to be exca- vated and carted away. Beazer East Inc., a Pittsburgh stone and gravel firm, bought the 52-acre property off N.C. 54 in 1988. • Beazer is paying for the cleanup, estimated to cost between .$8 mil- lion and $10 million. The Koppers site was added to the Superfund list in 1989, but it was just last week that a contractor started to drain and treat water from two ponds on the property. Even as she watches the cleanup she waited years to see, Medlin's relief is clouded by disappointrnenl "I feel that the company [ETG] let us down," Medlin said. Nixon, however, places the blame on regulatory agencies that auto- matically look to incineration to handle contamination problems · rather than working full-force on new solutions. Communities like Shiloh that are willing to try some- thing new ofte~ get tired or frus- trated trying to work with the EPA .. "It's a long fighl And there are a lot of elderly people. They just can't sustain a fight like that," Nixon said. If Shiloh hadn't fought to take responsibility for its pollution prob- lem, the community would have been cleared of the contaminated dirt by now. But state environmental officials say residents deserve credit for try- ing to do the right thing. "These folks really made history by trying to have the waste treated in their back yard," said Pat Williamson, spokesman for the state Division of Solid Waste Man- agement. "They really twisted EPA:s arm to try some other proces.s, rather Ulan shipping the waste off to some other area," she said. Although it didn't get the results it wanted, Shiloh is putting up one more fight. Residen~ don't want the polluted soil from their neigh- borhood taken to a hazardous- waste incinerator that's been forced on some other community. State solid-waste officials are Looking for an EPA-approved incin- erator that meets Shiloh's criteria, and think a plant in Kansas might be a candidate. · And the Shiloh residents' efforts might yet benefit a North Carolina community, said Mike Kelly, deputy director of the solid-waste division. ETG might test its refined process at a contaminated landfill in War- ren County, Kelly said, essentially picking up with the new technology where Shiloh left off. "This by no means is a failure," he said. • WE ARE MOVING .... RECEIVED Beginning September 8, 1995, the Delaware office of Cummings/Riter SEP 111995 Consultants will be located at the following address: 258 Chapman Road, Suite 202 Newark, Delaware 19702 Phone: (302) 731-9668 Fax: (302) 731-9609 SUPERFUND SECTION Please note that the Delaware telephone/fax numbers will remain the same. ALSO, WE ARE PLEASED TO ANNOUNCE •••. The following individuals have joined our firm during the past several months: • Scott Anderson -Project Geologist • Joe Bradley -CADD Operator • Jamie Cole -Administrative Assistant • Bruce Geno -Senior Project Engineer • Scott Roberts -Engineer • Paul Womax -Scientist Scott, Paul and Scott have joined our Delaware office and Joe, Jamie and Bruce have joined our Pittsburgh office. We are very pleased to have them aboard, and we hope you will join us in making them welcome. CUMMINGS/RITER CONSULTANTS, INC. 339 Haymaker Road ■ Parkway Building, Suite 201 Monroeville, Pennsylvania 15146 Phone: (412) 373-5240 Fax: (412) 373-5242 II ■ CUMMINGS/RITER CONSULTANTS, INC, 258 Chapman Road, Suite 202 Newark, Delaware 19702 Phone: (302) 731-9668 Fax: (302) 731-9609 ■ ■ ■ EPA needs support co . ctor EPA will solicit bids for an analytical and support contractor for Superfund sites in Regions 4, 6, 7, 8, 9 and 10 after an existing contract for the work expires Sept. 30. Work will include sample analyses and data reporting, analytical data review, logistical and administrative support, mobile laboratoi-y operation and other analysis support activities, said the May 30 Commerce Business Daily. EPA plans to conduct sole source negotiations with ICF Technology Inc. to extend its existing contract (number 68Dl0135) during its final option year for up to three months (from Oct. I to Dec. 31) with up to three more one month options (from Jan. I to March 31, 1996) in order to minimize disruptions and allow for a smoother transition period. Contact: Sandra Holland, EPA contracting officer 919-541-2213. Tribes get state envlro powers EPA has signed a series of agreements with 11 Minnesota Indian tribes granting them the power to formulate and enforce their own environmental regulations, much as states have now. Under a number of agreements signed May 24 at the Mille Lacs Reservation, EPA's Region 5 deemed the tribes to have sufficient technical expertise. EPA will continue to ensure that the regulations comply with federal standards but will provide assistance only when asked. Also, the agency agreed to institute a stronger Indian office in Region 5 (which also includes Illinois, Indiana, Michigan, Ohio and Wisconsin) and to incorporate the tribes into federal budgeting and planning considerations. Region 5 is formulating similar agreements with another 18 tribes in Michigan and Wisconsin. Contact: John Haugland, EPA technical contact, 312-886-9853; Dan Cozza, EPA Region 5 Waste Management Div., 312-886-7252; Shirley Nordrum, environmental specialist representing the tribes, 218-335,8241, . L-P no further action proposed EPA has issued a proposed plan for no further action at the Louisiana-Pacific Corp. NPL site in Oroville, Calif., following soil and groundwater sampling that indicate the site poses no environmen- tal or human health threats. Additional limited groundwater monitoring west of the plant will be required, however, under an order issued in April by the state Regional Water Quality Control Board. Soil and groundwater sampling was required under an interim ROD signed in 1990, which also called for deed restrictions prohibiting residential development and well permit restrictions. These controls would also be abolished under the proposed plan. Contact: Fred Schauffler, EPA project manager, 415-744-1305. CK.oppers..1pump-••treat bids near in N.C. Bids for on-site groundwater pump-and-treatment with carbon adsorption could be solicited in four to six weeks at the Koppers Co. Inc. NPL site in Morrisville, N.C. Also to be bid in the same package is the excavation and on-site treatment via base catalyzed dechlorination (BCD) of between 500 and 1,000 cubic yards of contaminated soil. Cummings Riter Consultants Inc. of Newark, Del., as the prime contractor for PRP Bea7.er East Inc., is preparing bid packages for the work but cannot solicit the bids until EPA approves the remedial action work plan, which is under agency review. EPA is expected to get back to the consultant with its work plan comments/approval in four to six weeks. Groundwater and soil are contaminated primarily with pentachlo- rophenol (PCP) and dioxin. Groundwater will be treated at a rate of 10 gallons per minute. Treatment will include flow equalization, filtration for the removal of suspended solids, and carbon adsorption. Extracted groundwater will be sent to a yet-to-be built treatment plant, and treated water will be discharged to an existing on-site surface water drainage ditch if the technology can achieve state surface water discharge requirements. EPA set the soil cleanup goals for PCP at 95 parts per million and dioxin/furans at seven parts per billion. However, EPA said that Beazer has imposed a more stringent cleanup goal of 9.5 ppm for PCP to ensure that 90% reduction is achieved. Most of the soil to be addressed is in the vicinity of the Unit Structure Inc. property. EPA estimates that BCD treatment will take about 12 weeks. Also, the gardens of about six local residents in the immediate area will be sampled in response to citizens' concerns that past land farming practices and rain runoff from the site may have had an impact. EPA unilaterally ordered Beazer East to design and construct the cleanup in April 1993. The ROD called for excavation and off-site incineration of affected soil but allowed for BCD contingency if treatability tests looked promising. The test results show BCD as a viable technology, EPA said. EPA said that if the operating conditions prove to be "significantly different" from those of the treatability tests or if the volume of soil to be addressed turns out to be much greater than expected, the agency may decide to go back to plan A-incineration. The 52-acre site at Koppers Road southwest of Highway 54 is bounded on the southwest by Church Street, and on the east by Southern Railway. Glue-laminated wood products were manufactured there beginning in 1962. Wood treating with PCP ceased in 1975. Contact: Beverly Hudson, EPA project manager, 800-435- 9233; Shannon Craig, Beazer East project coordinator, 412-227- 2684. Design for soil nearly done at Peerless Design for remediation of soil is complete at the Peerless Plating NPL site in Muskegon, Mich., but the threatened rescission of Superfund money this fiscal year has put a construction start this summer in doubt The project's status might change with President Clinton's threatened veto of Congress' rescissions package, which contained $100 million in Superfund cuts. But chances are that the construction will be held up regardless, because uncertainty has already caused delays and priority shifts. The groundwater system is 95% designed and would be ready to Pasha Publications, 1616 N. Fort Myer Drive, Suite 1000, Arlington, Va. 22209 Sup,,jundWuk-Jun, 2, 1995 5 State of North cSl11na Department of Environment, Health and Natural Resources James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Richard Whisnant, General Counsel Beverly T. Hudson Remedial Project Manager Waste Management Division EPA IV 345 Courtland Street, N.C. Atlanta, GA 30365 Re: Koppers Site Habitat Mitigation Plan Dear Ms. Hudson: August 9, 1994 AUG 191994 ::Ur'!::·-·--- I reviewed the Habitat Mitigation Plan Preliminary Report dated January 1994 ("the Plan") for the Koppers Superfund Site ("the Site"). My review is on behalf of the Secretary of this Department in his capacity as trustee for the State's natural resources. We believe the Plan represents a good step towards natural resource restoration at the Site. However, we have several concerns at this stage of the design work: • it is not clear to us that the area proposed for the mitigation work has itself been delineated and found not to be jurisdictional wetlands. • we concur with the recommendations of Mr. Augspurger of U.S. Fish & Wildlife that greater emphasis be given to plantings in the mitigation area that are typical of mature systems, rather than recently disturbed systems, e.g. water oaks, willow oaks, and black gum. • we also concur with Mr. Augspurger's recommendations regarding a preference for forested wetlands over open water habitats in the mitigation area. We appreciate the chance to comment on the Plan at this stage. We may have further comments as the design and implementation proceed. cc: · Dave Lown, Superfund Section P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone 919-733-4984 An Equal Opportunity Affirmative Action Employer 5(n, recycled/ l 0% post-consumer paper J National Priorities 1..I Superfund hazardous waste. site listed under the Comprehensive Environmental Response, Compensation. and Liability Act (CERCLA) as amended in 1986 KOPPERS CO .. , INC. (MORRISVILLE PLANT) Morrfsville, North Carolina The Koppers Co., Inc., Site covers 52 acres on Highway 54 West, approximately 1 mile northwest of Morrisville, Wake County, North Carolina. The site was used as a sawmill until 1959, when it was sold to unit Structures, Inc., which produced glue-laminated wood products on-site. Koppers co., I_nc. purchased the site in 1962 and continued the glue-la~inating process. During 1968-75, Koppers used the southeast portion of the site for treating wood. with pentachlorophenol (PCP). Production of laminated wood continued until. September 1986, when the plant was sold .back to Unit Structures. Koppers retained 10 acres of the original site where PCP was used. waste water from the PCP process was discharged to a pond pn-site. for the first 6 months of operation and then to two unlined lagoons nearby. Kopl)ers closed the lagoons in 1977. Liquid from the lagoons was sprayed over a field on the northeast corner of the property, and the sludge was mixed with soil and spread over the lagoon area in the southeast corner. Ir, 1980 and 1981, Koppers found PCP in on-site soil, wells, and pond water and sediment. In 1980 and 1986, Koppers removed some PCP-contaminated soil fran the lagoon area and transported it to a hazardous waste facility regulated under Subtitle C of the Resource conservation and Recovery Act. contaminated soil remains on-site, however, according to tests conducted by Koppers. Ground water within 3 miles of the site is the primary source of drinking water for an estimated 2,200 people. The North carolina Solid and Hazardous Waste Branch has detected trace contaminants in some off-site wells. Run-off from the northeast corner of the site drains eastward to an intermittent creek that flows southeast approximately 2.25 miles to Crabtree Creek. Run-off fran the southeast corner of the site drains to Koppers Pond, which supplies water for fire protection. Intermittent overflow fran Koppers Pond drains south approximately 1,000 feet to Medlin's Pond, which is used for fishing and irrigation of garden crops. The site is unfenced, making it possible for people and animals to cane into direct contact with hazardous substances. U.S. Environmental Protection Agency/Remedial Response Program South.rolina ·oepartment of .altli \ and Environmental Control \ PLEASE PP.INT or TYPE (fa.rm 00"1"ned for use on elite /12-pitchj tyoewriterl Form Approved. 0MB No. 2050•0039 E•p1res 9-30-91 UNIFORM HAZARDOUS I' Generator's U.S EPA IC'!<o. M•~~~t\.,, 12. Page 1 WASTE MANIFEST N, c, D, 0, 0, 3, 2, o, 0, 3, 8. 3. 0o'.'crtcf'a~ 01 I llnlormation in !he shaCleel areas is not required by Federal law. but is by State law l 3. Generator's Name and Mailing Address Beazer East, Inc. Site Address Church Street Morrisville, NC A. State Manilest Oocumenl Number 436 Seventh Ave., Suite 1050 Pittsburgh, PA 15219-1822 4 Generator'sPhonet 412 I 227-2955 5 Transporter 1 Company Name Dart Truckin~ Comoanv, Inc. 7. Transporter 2 Company Name 9 Designated Facility Name and Sile Address Laidlaw Environmental Services, Inc. Route I, Box 255 Pinewood, SC 29125 27560 B. State Generator's ID 6. U.S. EPA 10 Number ,c:c·~Sect!,!a!!tec.Tc!r!!an~s~-~·rt~e!..r'se_l:;D"""~-~--~~---1 ,0 1 Hr D, 0 1 0, 9, 8, 6 5, 8, 2, 5 D. Transnorter's Phone 800-423-0220 8. U.S. EPA ID Number ~E"'.-'S"'ta,et!!e'-T~r>!an'"s""'="rt"ercc·s,_1,,Dc.._ _________ _J 1 1 1 1 1 1 , 1 • 1 1 1 F, Trans""rter's Phone 10. U.S EPA 10 Number G Stale Facility's 10 H. Facility's Phone ,S,C,D,0,7,0,3,7,5 9,8,5 803-452-5003 11 U.S. DOT Description (including Proper Shipping Name. Hazard Class. and ID Number) 12. Containers 13. Total Ouan11ty 14. Unit L Waste Number No. Type W1iV04 a Hazardous Waste, Solid, G NA-3077, PG Ill (F032) ~ L _________ ----1f'L2211✓-2<1..!'.'-;;c:e3'.!"; :2.__ ___ ---l-:'..L:'..J...+::'..L'...'..µ:'..i:'..O.:'..+ N.O.S., Class 9, I El 01 31 21 0, 0, I C,M 3,6,o,o,o p l l l l I E n b. l I I I I A T ol-----------------------l.....L_l_4--L.j._L...L.LJL I ' ' ' I I ' l l I l I R c l l I, I I I ' ' ' ' ' ' ' ' ' ' ' ' d. l l l l I ' I I ' I ' ' l I I I I J. Additional Descriptions for Materials lis!ed Above K. Handling Codes for Wastes Listed Above a. l.!:i.!'!.j-1 o, 41 81 2, 11-141 11 01 11 C LL_J-1 I I I I 1-1 l I l b LLJ-1 I l I I 1-1 l I l I 15. Soec,ai Handing lnstruct,ons and Additional lnlo,malii Laidlaw Work Order No. / , 0 Emergency Contact 412/227-2955 d LLJ-1 I I l I 1-1 ,;..; f l l l (Ila.) See Exhibit "A" ' ' -IP~~ .. ( rep0r1,n9 0.,,oen 1u, in,~ cc,hec110n OT ,n1c,,ma1,on ~;•;,.~ 10 d•eragt 37 m,nu1e~ lo, 9en .. ,a10ri 1!:, m,nule!. lo• 1t11nsc,0ne,s ano 10 I m,n.,1e1 lo, nu,1men1110,119\' ano 0<\00$.111 lac,u1oe1 Tn01 ,nciuOII! hme •o• re,oen,n9 ,n1touc1,0ns gamer,ng 0.lla ano c0mo1e1on9 ano re.-,e,.,ng "'" •orm Senc:i cc:immenis , .. ga,o,ng "'" owoen e!.1rma1e ,nciuo,n, [ ,u99es1,ons To, reouc,ng 1n,s Ou!Of'ro 10 Cn,e1 1n!o,m11,on Polle~ 61a~C" PM.~il US E.n,11onr,,.,n1a1 P•olt"Chon Agency. 401 M St. S w I W,n.,,ng1on O :.: 20•60 .. ano 10 Tl'f 011,ce oT 1n10,ma1oon 1no Re9~1110,, A!'J•'~ 011,cf o• '"1ana0em,.,, .iM Buogf'I W,1~'1•n9ton DC 2'C!,03 16, GENERA TOR'S CERTIFICATION: I hereb'/ aec1a,e !hal 1he con1ents o! th,s cons,gnmenl a,e !ul!y and acc,Hately aescrrbea aoove by proper Sh1pp,ng nanie And are class111ed. packed, ma,OCed. and labeled. and are ,n all respects m proper cond111on tor 1ransport by highway accoro,ng 10 app11cable ,n1erna1,ona1 ana na1,ona1 governmeni regulations ano ttle laws of the State :::,1 South Ca,olma 111 am a large ouan!ny generator. I certrlv that I nave a program ,r. place 10 reduce~h e ano 10•1c1!y 01 waste genera •a 10 tr>e oegree I h,w .. deH,,rm,neo 10 oe econom,ca:1y prac11c.101e ana 1na11 nave seiec1ed the prac1,cable m,nnod of treatment, storage , e1,s sa1 currently <ha,1ao1e to mew ,en ,n.,,.m,1e:, !he prtJ:.e"1 and lu!u,e lhrea! 10 n1,man health ano the en,,,onment. OR. 1T I om a small quant,ty generator. I have made a g Od I ,t'l'h Jt!orl lo r1nim-1~y was1e gen •ill•~ind se1ec11he best waste m.inagement method thal ,s ava,lable to me and that t can <1'1ord ). / / / /1 , ---,, Printed/Typed Name Robert A. Fisher Month Day x_e~'f • 0 .3 ,,Z.,'L. 'f, 'f ~ 17. Transponer 1 Acknowledgement of Receipt ol Matena!s I A-l\'\~ted/Typed~me ~ \ c. \1)a,r,\IP ,,...._ Month Day Year D,3,2.,1.,"I,'-/ ~ 18. Transponer 2 Ackno~!edgemenl of Receipt o! Materials T E R F A Printed/Typed Name 19. Discrepancy Indication Space I Signature ' I Monti', • ' (~libs cl I Day Year • ' ' ' I I I l poo ~ ~~ /Lf Jt>:,L' '~ "'''LIL /,j--'&2::.'L-,,C::1:./£2-'LL!, .nj_~c?.-::t.'//a:J. ,,-r~/:.::z.:,/,ca_;i-",.2,?~~~:___ ____________ -I ~ 20. Facility Owner or Operator: Cert1!1cation of receIot o! haza,aous materials covered by this maniiest e.x.c~ noted in Item 19. ,...-;, 'I l l l I I I IDS ' I I I I I I jlos Printed/Typed Name Jaa Todd I Signat,ce \ >.a,1, af rr d) EPA Form 8700 (Rev. 9188) Previous Editions are Obsolete [OHEC 1988 (Re..-. 5189)] V ---If-:~,~ ~~Sout,.arolina Departmento.ealt ~-~:'.~•Oou,2 eMg<. ~~~ ii \· and Environmental Control \c ~I ~~i=·~l8L: 01 , ~~~ \ VS 18031253-6488 PLEASE PP.INT or TYPE /Far_m 4eti.1nned !or use on eltte (12-p11ch] typewnter) . rm Approved. O~B No 2050-0039 Expires 9-30-9' ' UNIFORM HAZARDOUS \'· Gene,a<ors U.S. EPA'°""'· M•"""" 12. P,ag,..!.-ftn101ma1ion "lhe shaoeo a,eas is no1 WASTE MANIFEST N, C, D, o, 0, 3, 2, o, 0, ~ 8, 3, "cr~m'ei;.'~0 / of 1 l,eQuiredbyFe0e,allaw.bulisbySlatelaw. 3 Generator's Name and Mailing Address Beazer East, Inc. 436 Seventh Ave., Suite 1050 Pittsburgh, PA 15219-1822 4 Generaio,·sPhonei 412 I 227-2955 5. Transoorter 1 Company Name Dart Trucking Comoanv, Inc. i. Transporter 2 Company Name 9 Designated Fc:1ctl1ty Name and Site Address Laidlaw Environmental Services, Route 1, Box 255 Pinewood, SC 29125 Site Address Church Street Morrisville, NC 27560 6. U.S. EPA ID Number ,O,H,D,O,O,9,8,6,5,8,2,5 8. U.S. EPA 10 Number I 1 I I I I I I I I ' ' 10. U.S. EPA 10 Number Inc. 9,8,5 A. State Manifest Document Number B State Generator's ID c. State Transnnrter's 10 D. Transoorters Phone 800-423-0220 E. State Trans""ner's tO F. Transporter's Phone G. State Facihty"s ID -.,. H. Facility's Phone 803-452-5003 11. U.S. DOT Description (mcludmg Proper Shipping Name. Hazard Class. and ID Number) 12. Containers 13. Total Quantity ::. Unit I. Waste Number I • Hazardous Waste, Solid, N.O.S., Class 9, NA-3O77, PG III (FO32) No Type ',',~ 'IOI I El Q1 :Ji 21 G E Nl--------------'------------l-.:'..L:LP.'..'.+-:~.L..!L E o, o, 1 C,M 3,6,o,o,o p I I I I I n b I I I I I A T oi-----------------------+__L..L.-l---J-/-...L.i_L ' ' ' ' I ' ' I i i i I R C ' ' I ' I d. J. Additional Descriptions !or Ma1eri<1ls Listed Above a l..f.JJij-1 O, 41 8, 2111-141 1, O, 11 b Lu-I 1 , , 1 1-1 1 1 1 I cLL_J-l~1~1~1~i~I-) I 0.1 · 1-j I I 1-1 L..L...J.I 1 1 15. Special Handing Instructions ana Additional !ntorma~ • / j <J Laidlaw Work Order No. _/C-O{,~,_lO_'i'_'f-'-'6"----- Emergency Contact 412/227-2955 ' I ' I I I I I I ' I I I I ' ' ' I I I ' I I I ' I I I i ' I I I K. Handling Codes tor Wastes Listed Above (1 la.) See Exhibit "A" J.L,_T._ I PulJl•l repon,n,;, o..,rcJ,:on •o, !n,i, co ·e~1.on o• •n•u•mal•on ,s esi.maled !O a~e,a9e Ji m,ri.,1,:,s 10, 9ene,a1o•s 1~ minutes 1o• i,an,pe,1e" and 10 I m,nu1es 10, Heatme,n s10,ag.-ano a socs.at 1ac,,.1oes Tn,s ,ncludes 1,me !o• '""'""''n9 ,n,1, ~c11ons g;,tnt>•,r-; ~la •"d como,e1on9 ano ,e_.,.,,.,,ng tne 10,m Sena commem!o •e9••0 ~; me Du•Oen .s1orni11e. ,nc1udu19 I suQgesi.on!o 1,ir re1luc,n9 m,s o.r,Jeri. to Cn,e!. l"!ormahon P011cy 9,a.,cn PM-?2:1 "JS ln,lfon,,.~r1;,• <>roll.'Cl•On Agency 401 M St.SW I wasn,n-.ton cl C 10•60. 11no 10 l~t 0",ce 011n10,ma11or. ano Regu1a1or1 AT!,1,rs 01,ct oi M;,na9erre~I anJ 6,oget v,asn,n91on. 0 C 2C!>O.l 16 GENEAATOA"S CERTIFICATION: I nereb:; oec1are 1ria1 the con1ents 01 1n1s cons,gnmen! are !ully anCI a,ccura1eJy oescribed above by D•OPt>• sn,oo,ng name <1nd are class,1,ed. packed. marked. and labeled. ano a,e m a11 respects in propel cond111on !o, 1ransoor1 Oy n,gnway according 10 aDol,cable mtema1,ona1 ana na11ona• government ,egu1ar,ons and 1ne laws of tne Slate :,1 Soutn Carolina • 1: 1 am a large Quanll!y genera10, 1 certi1y mat I nave a program ,r. place to ,educ'.•~'" :ime an<:110 .. c1ty of waste general 10 1~e °'egree I nave Oe1e,nuned to be econom,cally neaun ano 1rie en11,ronmen1. OR. 1! 1 am a small Quantt1y generator. I have maoe a oo I n,e11on ;oj.°in,m1z y ·--~~he'"1 '." a7e1 se•ec1 Hie ces: .-.aste managemerit method prac1,cdble anCI that I na11e selected tne pract,cao!e mt>tnoo ot 1,eatment. Storage , (1':S osa1 currently ~va ble 10 me wn,, n uruzes me onise~: and hilu•e 1nrea! to numan Iha! ,s a,va,1ac1e to me and tnat I cari af1o•d. / / / ',/ Printed/Typed Name Robert A. Fisher Month Dai ):•')' ,, ,? ,1-,7. ,'1,J, ; , 7. Transporter 1 Acknowledgement o! Receipt o! Materials . / ~ {:e~"nf<d ~h"e 1:,Kp._ Oi::>S.1 ~ 18. Transponer 2 Acknowledgemen1 o1 Recl1pt o! Materials ~ Printed/Typed Name R F A C 19. Discrepancy tnd1cat1on Space I Signalure ' l~(p I~? I'" Month Day Year ,o ~ ,.;2,) r, Ft Month Day Year ' ' I ' I ' C I I I ' I I )lbs 1-- ~ Lf/r.J~-~-;t;-~~~~~,<'~~-;6;;/_~,A-~./~~,...,~,,~-~~~/',.,,2,,~~'=c;,~P~~=:;::;'.:;;:;;;;::--;:::;:-;;::-;~--====--===~ t \ 20. Facil'lty""Owner or Operator: Certification of receipt o! haza~dous materials covered by this manifest "'""'epi""a-s..noted in Item 19 'I ' ' I I I I •OS ' I I I ' I I /lbs Printed/Typed Name Jan I o~d I Signatu<e \ / lf1"' rdcO Mx,tn Day, _;(~ay , c,,3...-+, 3,'1 )+ EPA Forrr. 6700 (Rev. 9188) p,~ "'US Ed111ons are Oosolele {DHEC 1988 (Rev. 5189)] 1/ EPA licenses process-TG 171c Environmental Prolcctio~cncy 011 March 15 licensed its base catalyzed dccomposi- Lion process lo ETG Environmemal Inc. of Blue Bell. Pa. E. Timmolhy Oppelt, director of Lhe Risk Reduction Engineering Laboratory, where the technology was developed, signed the license agreement in a ceremony at EPA's 20th annual research symposium in Cincinnati. 171e process dchalogcnatcs organics such as polychlorinaled biphenyls, dioxins, funms, pesticides. herbicides and insecticides. Last year. ETG demonstrated the process wilh its partner, Separation & Recovery Systems Inc .. in an EPA Supcrfund Innovative Technology Evaluation program pilol on soil tainted with pentachlorophenol and dioxon at the Koppers Superfund site in Nonh Carolina. ETG is negotiating with McClellan Air Force Base, Calif .. to start a pilot there on PCBs and dioxins, possibly by May or June. Contact: ETC President & CEO Ronald Bacskai, 610-832-0700. DsfBnss (?la~nup (ISSN: .1052-0635) is published weekly by Pasha Publlcat1ons 1nc., an independent newsle\ler firm, which a!so publishes Superfund, E&P Environment, Mino Regula1ion Report~r._ The Energy Report and Improved Recovery Week. Subscr1p11ons to Defense Cleanup are $475/year m the U.S., Canada and Mexico: delivered airmail for $505 elsewhere. Authorization 10 photocopy items for in1ernal or personal use, or Iho internal or persona\ usa al specilicclienis, is granted by Pasha Publications for libraries and other users registered with the Copy_righ_l Clearance Center provided Iha1 a lee al $2.50 per page is paid directly IC CCC, 29 Congress Sl., Salem, Mass. 01970. 1052-0635/90-94 O + $2.50 e 1994 by Pasha Publications Inc. Elec1ronic versions cl Defense Cleanup are available on News Net and lnlorrnation Access. Phone Newsnet at 800-952- 0122 (toll-free) or 215-527-8030. Phone inlormat1on Access at 800-2~7-8431 (toll-lree) or 415-378-So.oo Jar morn inlorma1ion. Bowman Cox, Edi1or (Santa Fe, N.M.) ........... 505-474-0375 Fax: ............................................................ 505-474-0083 Ron Kaulman, Associate Editor ...... .. ............ 703-816-8631 Tod Sedgwick, Publisher .............. .. .. 703-816-8600 Harry Baisden, Group Publisher ........ . ...... 703-816-8617 Beth McConnell, 1-Aanaging Editor.... .. ... 703-816-8639 Wade Martin, 1--Mrkoting .................. . ............ 703-816-861 O ~~ts{:!); ~~n, ,s P rOCiu·c·,,,o .. n·. · .. ·. . . . . 800.4 2 4-29oa ... 703-816-8611 Circulation Fax: 703-528-1253 POSTMASTER: Send address changes 10 Defense C/oanup. 1616 N. Fort Myor Or1vo. Suite 1000. Adtngton. V;_i. ?.2209. Er11m my subscr1pIion to Oofenso Cleanup. U Ono-yew subscription -$4"/S ($505 airmail) Name ________________ ~ Company ____________________ _ Addross ________________ ~ City/Stato/Zip ____________ _ Signa1ura ________________ . ___ _ Mall lo: OofBnsa C/Bllnup, 1616 N. Fon Myer Drive, Suite_ 1000, Arlinglon. Va. 22209 or cal\ 1011-!reo 800-424-2908. In Vi1ginia, call 703-528-1244. Hotline Service • 505-474-0375 , Your suhscription to Defense Cl,!<lnup i11d1ul<'s our ed,wrial l/01/1ne .~erv1re (,oil om ,,d,1urs u,1y11111e vo11 need "M,roon,1/ dermll o" ony 110ry 01 ntll<'r /J,,j,nsr ( l<'11nup "we, ---~--------~-·----------------·--·--·. ·····-·. Fe~,:rf!:er~ !~~;}"Wis ~~,~~b~i,t ~~,?:~,~~1erwise dim market for environmental services. a Washington consulting finn said last month. In its annual state of the industry report, Farkas Berkowitz & Co. said growth halted in 1993 for environmental complimlcc-relatc<l consulting and engineering services. But lhe federal market rose 8%, growing to 30% of the $9 billion total market for such.services. Remediation services held steady at $7 billion. Of Lhe total. 64% was for consulling, the otl1er 36% for construction. But the breakdown varied by sector. The constrnction share was 45% for non-Superfuutl cleanups such as private underground storage tcmk job~. corrective actions and voluntary remedies. But it was only 20% or !cs . .;; for the Environmental Protection Agency's Superfund projects and Defense Dept. cleanups. The finn's Alan Farkas warned the Environmental Business Conference '94 in Boston that the Defense Dept. marketplace may look bigger tlian it really is. "At DOD, remediation contracLOrs may have anted up for an expensive shell game, given the prospect that the billions of dollars in contract capacity being generated could be considerably greater than future actual expenditures." He added, "most DOD bases have over a half dozen contract vehicles from which to chose." Farkas said DOE's assistant secretary for environmental manage- ment, Tom Grumbly, "is playing hardball with DOE contraclOrs and employees alike, and Lhis LOugh approach is likely to lead to a promis- ing market for remediation services." 1l1e finn 's Joan Berkowitz said federal clients account for 15% of lhe S 1.5 billion analytical services sector, which is in the midst of a shakeout. For a copy of the report, send a $150 check ,a Farkas /Jerkowit: at 1220 19th St. NW, S11ite 300, Washingron D.C. 20036, or call 202-833- 7530. Walker highlights need for personnel Wann lXJdies. That's what the Anny's environmental progr;un needs more than anything else. according to it.,;; deputy w;sistant secretary for environment, Lewis Walker. Walker told a meeting last week that his first priority after he gets a new boss is 10 ask for help in gelling i;nvironmental field staff exempted from strict personnel ceilings . 111e Senate is considering whether to approve tht.: Clinton administration's nomination of Mike Walker, a Senate military construction appropriations sutx;ommittec staffer. as assisuint secretary for installations, logistics and environment (Defense C!eonup. I I 129/93). For the first time ever, Walker told the American Ddcn.-;c Pre- paredness Assn. meeting in Sm1 Antonio l<.L"il week that tile Anny h<L"i r<..:qucslecl more money for complim1ce th;rn for environmental restora- tion at active bases. The FY 1995 request reflects Lile irnpacl of the 1992 Fctleral Facilities Complinncc Act. The Army must request more money for ha:t.ardous waste compliance 10 avoid penalties for violations. Walker showed a table of budget numbers for comparison pur- poses. But keep in mind the table tracks neither closure cleanup funds nor cle;mup of formerly used defense sites (FUDS), which the Army handles !"or all scrvicx:s. Dollars arc in millions: 2 fJi'[rn.l"I' Cle11111111 -April I. /()()4 ['o.\'lu1 /'11};/ir:o1ions. Jri/0 N. F//rl My,,r IJril'c, S111/1' J()(X). i\rli11x10,1, Va. 22209 • BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 USA TEL: 412 227-2430 FAX: 412 227-2042 LAW DEPARTMENT Jill M. B!undon General Counsel Thomas Burgunder Mary Dombrowski Wright Billie S. Flohcrcy December 7, 1993 1i~ECEIVF-(t.' lEC 1 4 JS:-1 \X'il!iam F. Giarla Mary C. Fairh:y Terrance Gilco Faye Robert M. Lucas VIA AIRBORNE EXPRESS //4062687462 :"RFUNo SEc-n, Ms. Beverly Hudson Remedial Project Manager North Superfund Remedial Branch Waste Management Division U.S. EPA, Region IV ---- 345 Courtland Street, N.E. Atlanta, Georgia 30365 Re: Morrisville Site~·;;:_ ~:l£da,]J.. Beazer East, Inc. Dear Ms. Hudson: In May of 1993 the Unilateral Administrative Order for the RD/RA of the Morrisville, North Carolina Site was recorded and indexed to the property deed for Beazer's property at the above site as required in Section VIII, paragraph 44 of the Order. For you information and file, enclosed please find a copy of the stamped cover sheet for the Order evidencing the indexing of it to the title of Beazer's Morrisville property. If you should have any questions, please call me at (412) 227- 2635, or Terri Faye, to whom responsibility for the Raleigh site is presently assigned within our organization, at (412) 227- 2624. Yours truly, gf l!l#.:1~\ :;r}µtJ William F. Giarla Enclosure cc: T. Faye I s. Craig c. Zuch B. Nicholson, NCDEH . ,, I ' NOV-24-1'3'33 TO 14122272042 P.02 13:35 FROM MOORE & VAN ALLEN • • BX S 6 I 4 PG O O O 7 UNITED STATES ENVIRONMRNTAL PROTECTION AGlrnCY RBGION IV· t . 1 In the Matter· of: ) I KOPPERS co., me., (MORRISVILLB -PLANT) SOPBRFUND SI'I'E . . BEAZER BAS'l', me., RBSPOBDE?ff I Proceedi.llg Onder Section I 1 O 15 (a) of the Camprehensi ve ) . Environmental Re•ponae , ___ -... _ .. ) Compan.ation, ami Liability ) kt of 1980, as amended by ) the Superftmd Amandments and J Reauthorization Act of 19815 _ ) ) BPA Docket Ro. i 93-09-C _____________ ) tmILATERAL ADMllllS'l'RA'?IVK ORDBB. FOR RRMBDIAL DBSIGN Am> RBMBDIAL ACTION 0 0 Q ~-0 _, ! ::, ;,:; ~ ri,rr. =£c:'l~ s: ;a l> <7.·t!", -<' ,... -~ ;:,; -, .... '~ .x, n,rT', ···· N -~ "1 r. ::-; c-; C .:. .. ..,,v: oC· ::,;,01'1"1 C:..,, -· .,, _.;oz zo::'.= -::i: ◄ ~ .... ,.,,--l'1"I -<m'.:,:: ~ 0 Q oz·(N z VJv,_-. ~ TOTAL P. 02 i I i I i, -I I ' i ·1 i I !i i_l \i I II I • BEAZER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Dear Ms. Moss: Ms. Gloria Moss Route 2, Box 247 Morrisville, NC 27560 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the looks forward to continuing good relations with you. should have any questions or concerns, please call me 227-2684 or Cindy Zuch at (412) 227-2225, or leave a Beazer's toll-free information line 1-800-352-2668. will return your call within a day. Yours truly, :;i}'!,,, , , , ,J.) / , , !.J /(/~•}\._ Ti , (A :1,cr Shannon K. Craig past and If you at (412) message on Cindy or I Program Manager -Environmental Group SKC/dlk cc: c. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester • BEAZER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA I 52 I 9 October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Dear Mr. Tyndal: Mr. Ray Tyndal Route 2, Box 245B Morrisville, NC 27560 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the looks forward to continuing good relations with you. should have any questions or concerns, please call me 227-2684 or Cindy Zuch at (412) 227-2225, or leave a Beazer's toll-free information line 1-800-352-2668. will return your call within a day. Yours truly, / . . ,jlcoµ..,,"--t'). lea.~ Shannon K. Craig past and If you at (412) message on Cindy or I Program Manager -Environmental Group SKC/dlk cc: C. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Jessie and Mary Joyner Route 2, Box 78 Morrisville, NC 27560 Dear Jessie and Mary Joyner: You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the past and looks forward to continuing good relations with you. If you should have any questions or concerns, please call me at (412) 227-2684 or Cindy Zuch at (412) 227-2225, or leave a message on Beazer's toll-free information line 1-800-352-2668. Cindy or I will return your call within a day. Yours truly, ,)Ao->½,~,__ 11. t( OJ~ Shannon K. Craig Program Manager -Environmental Group SKC/dlk cc: C. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester • BEAZER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA I 52 I 9 October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Dear Ms. Jenkins: Ms. Gracie Jenkins P.O. Box 265 Morrisville, NC 27560 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the looks forward to continuing good relations with you. should have any questions or concerns, please call me 227-2684 or Cindy Zuch at {412) 227-2225, or leave a Beazer's toll-free information line 1-800-352-2668. will return your call within a day. Yours truly, ;dllC-{-4J,<_ K Ct '1- Shannon K. Craig' past and If you at (412) message on Cindy or I Program Manager -Environmental Group SKC/dlk cc: c. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson {2 copies) J. Mitsak, Chester • BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 Dear Mr. Grant: October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Ralph E. Grant Rollins Leasing Corp. One Rollins Plaza, P.O. Box 1791 Wilmington, DE 19899 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the past and looks forward to continuing good relations with you. If you should have any questions or concerns, please call me at (412) 227-2684 or Cindy Zuch at (412) 227-2225, or leave a message on Beazer's toll-free information line 1-800-352-2668. Cindy or I will return your call within a day. Yours truly, ;tJ~q{l,T Shannon K. Craig Program Manager -Environmental Group SKC/dlk cc: c. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester • BEAZER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA I 5219 October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Dear Mr. Quate: Mr. David Quate Quate Welding P.O. Box 131 Morrisville, NC 27560 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the looks forward to continuing good relations with you. should have any questions or concerns, please call me 227-2684 or Cindy Zuch at (412) 227-2225, or leave a Beazer's toll-free information line 1-800-352-2668. will return your call within a day. Yours truly, .:;:,r~t-;.,,~n.-t<. Ctc~ Shannon K. Crai.£.I past and If you at (412) message on Cindy or I Program Manager -Environmental Group SKC/dlk cc: C. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester BEAZER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA 15219 Dear Mr. Myers: October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Charles Myers Route 2, Box 250 Morrisville, NC 27560 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the past and looks forward to continuing good relations with you. If you should have any questions or concerns, please call me at (412) 227-2684 or Cindy Zuch at (412) 227-2225, or leave a message on Beazer's toll-free information line 1-800-352-2668. Cindy or I will return your call within a day. Yours truly, ;l)tv-~'"-. I< {c? Shannon K. Craig Program Manager -Environmental Group SKC/dlk cc: c. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 October 29, 1993 CERTIFIED MAIL RETURN RECEIPT REQUESTED Dear Mr. Avery: Triangle Graphics c/o Mr. Mike Avery Route 2, Box 67 Morrisville, NC 27560 You recently received a letter from Beverly Hudson, the EPA Project Coordinator for the U.S. EPA, regarding the discontinuation of your supply of bottled drinking water. Per the U.S. EPA's instructions, Beazer has notified Crystal Springs to discontinue service to your home on November 1, 1993. If you wish to continue having drinking water supplied to your home after November 1, at your own cost, you may call Misty Pharr at Crystal Springs at 1-800-443-8144. Please mention that you were supplied with bottled water in the past under the Beazer Material and Services contract. Crystal Springs will be making one more trip to your home to collect any bottles and the water cooler unit. Beazer will not be responsible for any additional costs past November 1. Beazer East, Inc. appreciates your cooperation in the looks forward to continuing good relations with you. should have any questions or concerns, please call me 227-2684 or Cindy Zuch at (412) 227-2225, or leave a Beazer's toll-free information line 1-800-352-2668. will return your call within a day. Yours truly, ¢&,vi-c~ 1Y ltLi- shannon K. Craig past and If you at (412) message on Cindy or I Program Manager -Environmental Group SKC/dlk cc: C. Zuch, Beazer T. Faye, Esq., Beazer J. Cook, Beazer B. Hudson, U.S. EPA B. Nicholson (2 copies) J. Mitsak, Chester • Ht.Gt I" f:.VER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA 15219 OCT O 7 199J SUPERF/INOSECHON Dear Ms. Hudson: October 1, 1993 AIRBORNE EXPRESS Ms. Beverly Hudson Remedial Project Manager North Superfund Remedial Branch Waste Management Division U.S. EPA, Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 Re: Morrisville Site Beazer East, Inc. Financial Assurance {&iepooCo' I Tue · 1&~=? In accordance with Section XXIII Assurance of Ability to Complete Work, paragraph 102 of the Unilateral Order issued to Beazer East, Inc. ("Beazer") by the U.S. EPA on April 21, 1993, the enclosed documentation is being provided to fulfill the requirements for financial assurance to perform the work described by the Record of Decision (ROD). The attached documentation consists of the financial information for Beazer's most recent fiscal year, ending October 3, 1992, in the form of a copy of Beazer's Consolidated Balance Sheet and Independent Auditor's Report thereon. our next fiscal year ends on October 2, 1993, and within ninety days thereafter, a new financial submission will be forwarded to you containing the audited financial information for that period. If you should have any questions or require additional information, please call me at (412) 227-2684 or Cindy Zuch at (412) 227-2225. Yours truly, Sh CZl)'l.MoJtJZ U\CU Ci/uw Shannon K. Craig IJ U Program Manager -Environmental Group SKC/dlk Enclosures cc: C. Zuch J. Cook T. Faye B. Nicholson • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF RESEARCH AND DEVELOPMENT RISK REDUCTION ENGINEERING LABORATORY CINCINNATI, OHIO 45268 Mr. Bruce Nicholson NC-DEHNR P.O. Box 27687 Raleigh, NC 27611-7687 Dear Mr. Nicholson: Septe~t.Ct.,vtu OCT O ;; 1993 SUPfRF/JNO SEGrlON The U.S. Environmental Protection Agency (EPA) Superfund Innovative Technology Evaluation (SITE) Program appreciates your participation in Visitors' Day activities for the demonstration of the BCD Technology and the SAR EX® THERM-0-DETOX™ System conducted at the Koppers Company Superfund Site in Morrisville, North Carolina. Enclosed is a list of attendees from the Visitors' Day. EPA hopes that the presentations were beneficial and that you gained a greater understanding of the SITE Program, the technologies, and the Koppers Company site. These SITE demonstrations will yield valuable performance, engineering, and cost data that will be used to determine each technology's effectiveness. The EPA will publish data from these demonstrations in an Applications Analysis Report (AAR), which will be available in 1994. If you have questions regarding the SITE Program or the technologies, please call me at (513) 569-7589. For additional copies of the information distributed at the Visitors' Day, please call Cindy Loney of PRC Environmental Management, Inc., at (513) 241-0149. Again, thank you for your participation in the Visitors' Day; you helped to make it a great success. Enclosure Sincerely, TL~?£ Project Manag~- Demonstrat ion Section, SDEB Superfund Technology Demonstration Division Risk Reduction Engineering Laboratory @ Printed on Recycled Paper • U.S. EPA Demonstration Visitors' Day Research Triangle Park, North Carolina August 31, 1993 Ms. Della Adams Meals on Wheels Route I. Box 64 Morrisville. NC 27560 Phone: 9 I 9-467-7972 · Mr. Mike Allway Community Development Director Town of Morrisville P.O. Box 166 Morrisville, NC 27560 Phone: 9 I 9-469-1426 Mr. Ken Babb Resident 2008-A Smallwood Dr. Raleigh, NC 27605 Phone: 919-834-9278 Mr. Ron Bacskai President ETG Environmental. Inc. 660 Sentry Parkway Blue Bell. PA 19422 Phone: 215-832-0700 Ms. Maggie L. Barbee Resident 919 Church Street Morrisville, NC 27560 Phone: 919-467-0876 Ms. Diane Barrett Community Relations Specialits U.S. EPA, Region 4 345 Courtland Street, NE Atlanta, GA 30365 Phone: 404-347-7791 Final Roster Mr. Randy Basinger Staff Writer N.C. Beacon 10 Park Plaza. P.O. Box 14125 RTP, NC 27709 Phone: 9 I 9-549-7340 Mr. Bruce H. Bechtold Hercules Incorporated Hercules Plaza. 5483 N. E. Wilmington, DE 19894-000 I Phone: 302-594-7400 Mr. Tom Benton Photographer Impact Visuals Photo & Graphics 1308 Glenwood Avenue Raleigh, NC 27605 Phone: 9 I 9-828-9527 Ms. Rebecca Biggers Supervisory Chemical Engineer Naval Energy & Environmental Support Activity 1001 Lyons St., Suite I Port Hueneme. CA 93043 Phone: 805-982-2640 Mr. Michael Bolen Project Manager SAIC 1735 N. Ocean Avenue Medford. NY 11763 Phone: 516-475-9408 Mr. J. Biff Boyter Vice President ETG Environmental. Inc. 4900 Olympic Blvd. Erlanger, KY 41018 Phone: 606-282-6137 Ms. Beverly Brown Reporter The News and Observer 215 S. McDowell Street Raleigh, NC 27602 Phone: 919-829-4881 Mr. Jack Butler Section Chief NC-DEHNR P.O. Box 27687 Raleigh, NC 27611-7687 Phone: 919-733-280 I Ms. Gail V. Cannccady Resident 11202 Chapel Hill Road Morrisville, NC 27560 Phone: 9 I 9-941-6252 Mr. David M. Cosgriff Environmental Engineer Champion International 952 East Spruce Street Libby, MT 59923 Phone: 406-293-4141 Ms. Lucille Crowe Resident 10804 Chapel Hill Road Morrisville, NC 27560 Phone: 919-467-8603 Mr. John Crumpton Town Manager Town of Morrisville P.O. Box 166 Morrisville, NC 27560 Phone: 919-469-1426 Ms. Christine Daniels Resident Route I, Box I Morrisville, NC 27560 Phone: 919-467-4685 • Mr. William Daniels Resident Route I. Box 1 Morrisville, NC 27560 Phone: 919-467-4685 Mr. Daniel C. Deer Vice-President AKJ Industries, Inc. 14 N. Washington Street Easton, MD 21601 Phone: 410-822-0 I 00 Mr. Herb Dempsey ERO Operations Manager Acurex Environmental Corporation P.O. Box 13109 Research Triangle Park, NC 27709 Phone: 919-544-4535 Mr. James Duffy Technical Manager OxyChem Technology Center 2801 Long Road Grand Island, NY 14072 Phone: 716-773-8476 Ms. Helen Dunigan Resident 11202 Chapel Hill Road Morrisville, NC 27560 Phone: 919-941-6252 Ms. Martha R. Dysart Research Associate Reichhold Chemicals, Inc. P.O. Box 13582 Research Triangle Park. NC 27709 Phone: 919-990-8002 Mr. Curt Fehn Chief, NC Superfund Section Waste Management Division U.S. EPA, Region 4 345 Courtland Street. NE Atlanta, GA 30365 Phone: 404-347-7791 ' . • Mr. Rob Foster PRC SITE Program Manager PRC EM! 233 N. Michigan Ave .. Suite 1621 Chicago. IL 6060 I Phone: 312-856-8700 Mr. Michael D. Gallagher Senior Project Manager !EA. Inc. I 20 South Center Court. Suite 200 Cary. NC 27560 Phone: 9 I 9-460-0852 Mr. D. Kent Geis Project Manager OHM Remediation Services Corp. I 00 Dominion Dr .. Suite I 07 Raleigh. NC 27560 Phone: 919-467-2349 Ms. Doris Giles CWEPS Board Member CWEPS P.O. Box 462 Morrisville. NC 27560 Phone: 9 I 9-481-9590 Mr. Allen K. Glover Deputy Director Wake County Department of Health P.O. Box 14049 Raleigh, NC 27620 Phone: 9 I 9-250-4370 Mr. Syed H. Hasnain Project Manager CTL Engineering, Inc. 6301-A Angus Drive Raleigh, NC 27613 Phone: 9 I 9-782-9895 Mr. William Heatley Principal Project Manager Roy F. Weston I 000 Parimeter Park Drive Morrisville, NC 27560 Phone: 919-380-7410 • Mr. William Hicks. Sr. Resident 12 I 9 Church Street Morrisville. NC 27560 Phone: 9 I 9-941-5843 Ms. Beverly Hudson Remedial Project Manager U.S. EPA. Region 4 345 Courtland Street. NE Atlanta, GA 30365 Phone: 404-347-779 I Mr. Farley Hunter Environmental Engineer CIBA Rt. 37 West Toms River, NJ 08754 Phone: 908-9 I 4-2802 Mr. Robert Hutcheson PRC Project Manager PRC EM! 285 Peachtree Center Ave .. Suite 900 Atlanta. GA 30303 Phone: 404-522-2867 Ms. G Kingsbury Chemical Engineer Research Triangle Institute P.O. Box 12194 Research Triangle Park, NC 27709 Phone: 919-541-586 I Mr. Omer Kitaplioglu Mechanical Engineer SAIC 411 Hackensack Ave .. 3rd Floor Hackensack, NJ 0760 I Phone: 201-489-5200 (X 150) Dr. K. Thomas Klasson Martin Marietta Energy Systems, Inc. P.O. Box 2008 Oak Ridge, TN 37831-7044 Phone: 615-574-6813 Mr. Mike Kowalski Director, Site Remediation Reichhold Chemicals, Inc. P.O. Box 13582 • Research Triangle Park. NC 27709 Phone: 919-990-755 I Mr. Eugene G. Laukonen Manager, Development PPG Industries, Inc. 440 College Park Drive Monroeville. PA 15146 Phone: 412-325-5370 Mr. Roger Lee Vice-President Maryland Nationai Bank 502 Washington Avenue Towson, MD 21204 Phone: 410-256-1423 Mr. Jerry Lisiecki V.P. -Great Lakes ETG Environmental, Inc. 7707 Rickie Road Lansing, Ml 48917 Phone: 517-322-9311 Ms. Cindy Loney Community Relations Coordinator PRC EM! 644 Linn Street, Suite 719 Cincinnati, OH 45203 Phone: 513-241-0149 Mr. Chris Lutes Atmospheric Chemist Acurex Environmental Corporation P.O. Box 13109 Research Triangle Park, NC 27709 Phone: 9 I 9-544-4535 Mr. Terry Lyons EPA Project Manager U.S. EPA, SITE Program 26 W. ML King Drive Cincinnati, OH 45268 Phone: 513-569-7589 Mr. D.C. Marshhurn 704 Church Street Morrisville, NC 27560 Phone: 919-467-6575 Ms. Helen Marshburn 704 Church Street Morrisville. NC 27560 Phone: 919-467-6575 Mr. Loren Martin V.P. -Sales Development ETG Environmental, Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Mr. Haren Master Senior V.P. -Operations ETG Environmental, Inc. 660 Sentry Parkway Blue Bell, PA I 9422 Phone: 215-832-0700 Mr. Pierre Matthys Executive Vice-President Separation and Recovery Systems. Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Philippe J. Matthys Manager, Strategic Planning Separation and Recovery Systems, Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Nathaniel Mayo Resident Box 660 I, Route I Morrisville, NC 27560 Phone: 919-941-5716 Ms. Ruby P. Mayo Resident 660 I Kitts Creek Road Morrisville, NC 27560 Phone: 919-941-5716 .. Mr. Mark T. McGuire Vice-President. Finance AIU Industries. Inc. 14 N. Washington Street Easton. MD 21601 Phone: 410-822-0100 Ms. Peggy Medlin Resident 57 l l Koppers Road Morrisville. NC 27560 Phone: 919-467-762 l Mr. Bradford H. Miller Technical Sales Separation and Recovery Systems, Inc. l 762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Thomas Mineo Senior Project Manager Metcalf & Eddy, Inc. P.O. Box 1500 Somerville, NJ 08876 Phone: 908-685-6052 Mr. John Mitsak Project Manager Chester Environmental, Inc. 8600 LaSalle Road York Building, Suite 502 Towson. MD 21286 Phone: 410-821-2909 Mr. Herald Moats Technical Manager CIBA 410 Swing Road Greensboro, NC 27419 Phone: 919-632-7714 Ms. Aree Monroe Resident 115 Barbee Road Morrisville, NC 27560 Phone: 919-467-9696 • Mr. Mitchdl Moss Technology Developer ETG Environmental. Inc. 660 Sentry Parkway Blue Bell. PA I 9422 Phone: 215-832-0700 Mr. Mike Nemecek Account Executive Technical Knowledge Communications 4020 West Chase Blvd .. Suite 370 Raleigh, NC 27607 Phone: 9 l 9-821-0900 Mr. Bruce Nicholson Project Manager NC-DEHNR P.O. Box 27687 Raleigh, NC 27611-7687 Phone: 919-733-2801 Ms. Gina Norman Account Executive Technical Knowledge Communications 4020 West Chase Blvd .. Suite 370 Raleigh, NC 27607 Phone: 9 I 9-821-0900 Dr. Ken Partymiller PRC Project Engineer PRC EM! 719 Sawdust Road, Suite 103 The Woodlands. TX 77380 Phone: 713-364-7 l 3 7 Mr. Fred Payne Senior Vice President ETG Environmental. Inc. 7707 Rickie Road Lansing, MI 48917 Phone: 517-322-93 l l Mr. Kent Penny Water Quality Manager Wake County Department of Health P.O. Box 14049 Raleigh, NC 27620 Phone: 9 I 9-250-4367 • Mr. William Peters. III Y.P. -Finance and Administration ETG Environmental. Inc. 660 Sentry Parkway Blue Bell. PA I 9422 Phone: 215-832-0700 Mr. Kumar Ramanathan Staff Engineer Ciba-Geigy Corporation P.O. Box 18300 Greensboro. NC 27455 Phone: 919-632-2643 Mr. Scott Rehmus Project Manager Duke University DPC 90097 Durham, NC 27708-0097 Phone: 919-660-1830 Ms. Rosemarie Roberts Project Manager NC-DEHNR 'P.O. Box 27687 Raleigh, NC 27611-7687 Phone: 919-733-2801 Mr. Phil Scarito Project Manager Chester Environmental 8600 LaSalle Road Towson, MD 20286 Phone: 410-821-2903 Ms. Susan Schrader PRC Project Engineer PRC EM! I 0600 Bloomfield Dr., # 1118 Orlando, FL 32825 Phone: 407-273-3550 Ms. Mollie Scott Resident Route 2, Box 222 Morrisville, NC 27560 Phone: 919-467-8167 Mr. James Serne Technical Director Roy F. Weston l 000 Parimeter Park Drive Morrisville. NC 27560 Phone: 919-380-7410 Mr. Robert Shanks Technical Supervisor SoilTech ATP Systems. Inc. 6300 S. Syracuse Way, Suite 300 Englewood, CO 80111 Phone: 303-290-8336 Dr. Yei-Shong Shieh Technology Developer ETG Environmental. Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Mr. Sam Sury Technical Director CIBA 410 Swing Road Greensboro, NC 27419 Phone: 919-632-20 l 7 Mr. Christopher G. Swanberg Sr. Vice President-Operations Separation and Recovery Systems. Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 7 l 4-261-8860 Mr. Gene Tatsch 5911 Grandale Drive Durham, NC 277 l 3 Phone: 9 l 9-541-6930 Ms. Hope C. Taylor Biochemist/Environmental Consultant Clean Water & Environmental Project for Shiloh 811 Hurdle Mill Road Cedar Grove, NC 27231 Phone: 9 I 9-684-2217 • Ms. Suzie Terres Environmental Protection Specialist Naval Energy & Environmental Support Activity Navy. Code I 12E4 1001 Lyons St., Suite I Port Hueneme. CA 93043 Phone: 805-982-2194 Ms. Emma Trice Resident Rte. I, 5812 Koppers Road Morrisville, NC 27560 Phone: 9 I 9-48 I -IO 17 Mr. W. Al Ward Environmental Health Program Specialist Wade County Department of Health P.O. Box 14049 Raleigh, NC 27620-4049 Phone: 919-250-4394 Mr. Patrick Watters Project Manager NC-DEHNR P.O. Box 27687 Raleigh, NC 276 I 1-7687 Phone: 9 I 9-733-280 I Mr. Malcoom Watts Special Projects Manager ZENECA Concord Pike Wilmington, DE I 9897 Phone: 302-886-8085 Mr. Allen Weed Photographer The Cary News P.O. Box 4949 Cary, NC 27713 Phone: 9 I 9-460-2604 • Ms. Sherry Williamson Reporter The Cary News P.O. Box 4949 Cary. NC 27519-4949 Phone: 9 I 9-460-2604 Mr. Dee Worden Environmental Health Supervision II Wake County Department of Health P.O. Box 14049 Raleigh, NC 27620 Phone: 9 I 9-250-4396 Mr. Robert Wright Elf Atochem North American 900 First Ave .. P.O. Box 1536 King of Prussia, PA 19406 Phone: 215-337-6810 Ms. Karen Yates Safety/Environmental Manager Acurex Environmental Corporation P.O. Box 13109 Research Triangle Park. NC 27709 Phone: 9 I 9-544-4535 Ms. Cynthia Zuch Associate Program Manager Beazer East, Inc. 436 Seventh Avenue. Suite 1150 Pittsburgh, PA 15219-1822 Phone: 412-227-2950 • • ttltt;tJVtU OCT O 1 199J UNITED STATES ENVIRONMENTAL PROTECTION OFFICE OF RESEARCH AND DEVELOPMENT AGENc_5tJPfRFUNns£cnoN Mr. Jack Butler NC-DEHNR P.O. Box 27687 RISK REDUCTION ENGINEERING LABORATORY C!NCINNAT!. OHIO 45268 September 24, 1993 Raleigh, NC 27611-7687 Dear Mr. Butler: The U.S. · Environmental Protection Agency (EPA) Superfund Innovative Technology Evaluation (SITE) Program appreciates your participation in Visitors' Day activities for the demonstration of the BCD Technology and the SAREX® THERM-0-DETOX™ System conducted at the Koppers Company Superfund Site in Morrisville, North Carolina. Enclosed is a list of attendees from the Visitors' Day. EPA hopes that the presentations were beneficial and that you gained a greater understanding of the SITE Program, the technologies, and the Koppers Company site. These SITE demonstrations will yield valuable performance, engineering, and cost data that will be used to determine each technology's effectiveness. The EPA will publish data from these demonstrations in an Applications Analysis Report (AAR), which will be available in 1994. If you have questions regarding the S !TE Program or the tech no l ogi es, please call me at (513) 569-7589. For additional copies of the information distributed at the Visitors' Day, please call Cindy Loney of PRC Environmental Management, Inc., at (513) 241-0149. Again, thank you for your participation in the Visitors' Day; you helped to make it a great success. Enclosure Sincerely, ~~~ Terrence . yons Project ager Demonstration ection, SDEB Superfund Technology Demonstration Division Risk Reduction Engineering Laboratory @ Printed on Recycled Paper • • U.S. EPA Demonstration Visitors' Day Research Triangle Park, North Carolina August 31, 1993 Ms. Della Adams Meals on Wheels Route I . Box 64 Morrisville. NC 27560 Phone: 919-467-7972 Mr. Mike Allway Community Development Director Town of Morrisville P.O. Box 166 Morrisville, NC 27560 Phone: 919-469-1426 Mr. Ken Babb Resident 2008-A Smallwood Dr. Raleigh. NC 27605 Phone: 919-834-9278 Mr. Ron Bacskai President ETG Environmental. Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Ms. Maggie L. Barbee Resident 919 Church Street Morrisville, NC 27560 Phone: 919-467-0876 Ms. Diane Barrett Community Relations Specialits U.S. EPA, Region 4 345 Courtland Street, NE Atlanta. GA 30365 Phone: 404-347-7791 Final Roster Mr. Randy Basinger Staff Writer N.C. Beacon 10 Park Plaza. P.O. Box 14125 RTP. NC 27709 Phone: 919-549-7340 Mr. Bruce H. Bechtold Hercules Incorporated Hercules Plaza. 5483 N. E. Wilmington, DE 19894-0001 Phone: 302-594-7400 Mr. Tom Benton Photographer Impact Visuals Photo & Graphics 1308 Glenwood Avenue Raleigh. NC 27605 Phone: 9 I 9-828-9527 Ms. Rebecca Biggers Supervisory Chemical Engineer Naval Energy & Environmental Support Activity 1001 Lyons St., Suite I Port Hueneme. CA 93043 Phone: 805-982-2640 Mr. Michael Bolen Project Manager SAIC 1735 N. Ocean A venue Medford, NY 11763 Phone: 516-475-9408 Mr. J. Biff Boyter Vice President ETG Environmental. Inc. 4900 Olympic Blvd. Erlanger, KY 4!018 Phone: 606-282-6137 Ms. Beverly Brown Reporter The News and Observer 215 S. McDowell Street Raleigh. NC 27602 Phone: 9 l 9-829-4881 Mr. Jack Butler Section Chief NC-DEHNR P.O. Box 27687 Raleigh, NC 27611-7687 Phone: 9 l 9-733-280 l Ms. Gail V. Cannccady Resident 11202 Chapel Hill Road Morrisville, NC 27560 Phone: 9 l 9-941-6252 Mr. David M. Cosgriff Environmental Engineer Champion International 952 East Spruce Street Libby, MT 59923 Phone: 406-293-4141 Ms. Lucille Crowe Resident l 0804 Chapel Hill Road Morrisville, NC 27560 Phone: 919-467-8603 Mr. John Crumpton Town Manager Town of Morrisville P.O. Box 166 Morrisville, NC 27560 Phone: 9 l 9-469-1426 Ms. Christine Daniels Resident Route 1, Box l Morrisville, NC 27560 Phone: 919-467-4685 • Mr. William Daniels Resident Route I. Box l Morrisville, NC 27560 Phone: 9 l 9-467-4685 Mr. Daniel C. Deer Vice-President AIU Industries, Inc. 14 N. Washington Street Easton, MD 2 160 l Phone: 410-822-0 l 00 Mr. Herb Dempsey ERO Operations Manager Acurex Environmental Corporation P.O. Box 13109 Research Triangle Park, NC 27709 Phone: 919-544-4535 Mr. James Duffy Technical Manager OxyChem Technology Center 280 l Long Road Grand Island, NY 14072 Phone: 716-773-8476 Ms. Helen Dunigan Resident 11202 Chapel Hill Road Morrisville, NC 27560 Phone: 919-94 I -6252 Ms. Martha R. Dysart Research Associate Reichhold Chemicals, Inc. P.O. Box 13582 Research Triangle Park. NC 27709 Phone: 919-990-8002 Mr. Curt Fehn Chief, NC Superfund Section Waste Management Division U.S. EPA, Region 4 345 Courtland Street, NE Atlanta, GA 30365 Phone: 404-347-7791 • Mr. Rob Foster PRC SITE Program Manager PRC EMI 233 N. Michigan Ave .. Suite 1621 Chicago, IL 6060 I Phone: 312-856-8700 Mr. Michael D. Gallagher Senior Project Manager !EA, Inc. 120 South Center Court, Suite 200 Cary, NC 27560 Phone: 919-460-0852 Mr. D. Kent Geis Project Manager OHM Remediation Services Corp. 100 Dominion Dr., Suite 107 Raleigh, NC 27560 Phone: 9 I 9-467-2349 Ms. Doris Giles CWEPS Board Member CWEPS P.O. Box 462 Morrisville, NC 27560 Phone: 919-48 1 -9590 Mr. Allen K. Glover Deputy Director Wake County Department of Health P.O. Box 14049 Raleigh, NC 27620 Phone: 919-250-4370 Mr. Syed H. Hasnain Project Manager CTL Engineering, Inc. 6301-A Angus Drive Raleigh, NC 27613 Phone: 919-782-9895 Mr. William Heatley Principal Project Manager Roy F. Weston 1000 Parimeter Park Drive • Morrisville, NC 27560 Phone: 919-380-7410 • Mr. William Hicks. Sr. Resident 12 I 9 Church Street Morrisville. NC 27560 Phone: 919-941-5843 Ms. Beverly Hudson Remedial Project Manager U.S. EPA. Region 4 345 Courtland Street. NE Atlanta, GA 30365 Phone: 404-347-7791 Mr. Farley Hunter Environmental Engineer CIBA Rt. 37 West Toms River, NJ 08754 Phone: 908-914-2802 Mr. Robert Hutcheson PRC Project Manager PRC EM! 285 Peachtree Center Ave .. Suite 900 Atlanta, GA 30303 Phone: 404-522-2867 Ms. G Kingsbury Chemical Engineer Research Triangle Institute P.O. Box 12194 Research Triangle Park, NC 27709 Phone: 9 I 9-541-5861 Mr. Omer Kitaplioglu Mechanical Engineer SAIC 411 Hackensack Ave .. 3rd Floor Hackensack, NJ 07601 Phone: 201-489-5200 (X 150) Dr. K. Thomas Klasson Martin Marietta Energy Systems, Inc. P.O. Box 2008 Oak Ridge, TN 37831-7044 Phone: 615-574-6813 Mr. Mike Kowalski Director, Site Remediation Reichhold Chemicals, Inc. P.O. Box 13582 • Research Triangle Park, NC 27709 Phone: 919-990-755 I Mr. Eugene G. Laukonen Manager, Development PPG Industries, Inc. 440 College Park Drive Monroeville, PA 15146 Phone: 412-325-5370 Mr. Roger Lee Vice-President Maryland Nationai Bank 502 Washington Avenue Towson, MD 21204 Phone: 410-256-1423 Mr. Jerry Lisiecki V.P. -Great Lakes ETG Environmental, Inc. 7707 Rickie Road Lansing, MI 48917 Phone: 517-322-9311 Ms. Cindy Loney Community Relations Coordinator PRC EM! 644 Linn Street, Suite 719 Cincinnati, OH 45203 Phone: 513-241-0149 Mr. Chris Lutes Atmospheric Chemist Acurex Environmental Corporation P.O. Box 13109 Research Triangle Park, NC 27709 Phone: 919-544-4535 Mr. Terry Lyons EPA Project Manager U.S. EPA, SITE Program 26 W. ML King Drive Cincinnati, OH 45268 Phone: 513-569-7589 Mr. D.C. Marshburn 704 Church Street Morrisville, NC 27560 Phone: 9 I 9-467-6575 Ms. Helen Marshburn 704 Church Street Morrisville, NC 27560 Phone: 919-467-6575 Mr. Loren Martin V.P. -Sales Development ETG Environmental, Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Mr. Haren Master Senior V.P. -Operations ETG Environmental, Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Mr. Pierre Matthys Executive Vice-President Separation and Recovery Systems, Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Philippe J. Matthys Manager, Strategic Planning Separation and Recovery Systems, Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Nathaniel Mayo Resident Box 6601, Route 1 Morrisville, NC 27560 Phone: 919-941-5716 Ms. Ruby P. Mayo Resident 6601 Kitts Creek Road Morrisville, NC 27560 Phone: 919-941-5716 • Mr. Mark T. McGuire Vice-President. Finance AIU Industries. Inc. 14 N. Washington Street Easton, MD 2 I 60 I Phone: 410-822-0100 Ms. Peggy Medlin Resident 5711 Koppers Road Morrisville. NC 27560 Phone: 919-467-7621 Mr. Bradford H. Miller Technical Sales Separation and Recovery Systems, Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Thomas Mineo Senior Project Manager Metcalf & Eddy, Inc. P.O. Box 1500 Somerville, NJ 08876 Phone: 908-685-6052 Mr. John Mitsak Project Manager Chester Environmental, Inc. 8600 LaSalle Road York Building, Suite 502 Towson. MD 21286 Phone: 410-821-2909 Mr. Herald Moats Technical Manager CIBA 410 Swing Road Greensboro, NC 27419 Phone: 919-632-7714 Ms. Aree Monroe Resident 115 Barbee Road Morrisville, NC 27560 Phone: 919-467-9696 • Mr. Mitchell Moss Technology Developer ETG Environmental. Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Mr. Mike Nemecek Account Executive Technical Knowledge Communications 4020 West Chase Blvd .. Suite 370 Raleigh, NC 27607 Phone: 919-821-0900 Mr. Bruce Nicholson Project Manager NC-DEHNR P.O. Box 27687 Raleigh. NC 27611-7687 Phone: 9 I 9-733-280 I Ms. Gina Norman Account Executive Technical Knowledge Communications 4020 West Chase Blvd., Suite 370 Raleigh, NC 27607 Phone: 919-821-0900 Dr. Ken Partymiller PRC Project Engineer PRC EM! 719 Sawdust Road, Suite 103 The Woodlands, TX 77380 Phone: 713-364-7137 Mr. Fred Payne Senior Vice President ETG Environmental, Inc. 7707 Rickie Road Lansing, Ml 489 I 7 Phone: 517-322-9311 Mr. Kent Penny Water Quality Manager Wake County Department of Health P.O. Box 14049 Raleigh, NC 27620 Phone: 919-250-4367 • Mr. William Peters. Ill V. P. -Finance and Administration ETG Environmental. Inc. 660 Sentry Parkway Blue Bell. PA 19422 Phone: 215-832-0700 Mr. Kumar Ramanathan Staff Engineer Ciba-Geigy Corporation P.O. Box 18300 Greensboro. NC 27455 Phone: 919-632-2643 Mr. Scott Rehmus Project Manager Duke University DPC 90097 Durham, NC 27708-0097 Phone: 9 I 9-660-1830 Ms. Rosemarie Roberts Project Manager NC-DEHNR P.O. Box 27687 Raleigh, NC 27611-7687 Phone: 919-733-280 I Mr. Phil Scarito Project Manager Chester Environmental 8600 LaSalle Road Towson, MD 20286 Phone: 410-821-2903 Ms. Susan Schrader PRC Project Engineer PRC EMI 10600 Bloomfield Dr., # 1118 Orlando, FL 32825 Phone: 407-273-3550 Ms. Mollie Scott Resident Route 2, Box 222 Morrisville, NC 27560 Phone: 919-467-8167 Mr. James Serne Technical Director Roy F. Weston 1000 Parimeter Park Drive Morrisville. NC 27560 Phone: 919-380-7410 Mr. Robert Shanks Technical Supervisor SoilTech ATP Systems. Inc. 6300 S. Syracuse Way, Suite 300 Englewood, CO 80 I I I Phone: 303-290-8336 Dr. Yei-Shong Shieh Technology Developer ETG Environmental, Inc. 660 Sentry Parkway Blue Bell, PA 19422 Phone: 215-832-0700 Mr. Sam Sury Technical Director CIBA 410 Swing Road Greensboro, NC 27419 Phone: 9I9-632-2017 Mr. Christopher G. Swanberg Sr. Vice President-Operations Separation and Recovery Systems, Inc. 1762 McGaw Avenue Irvine, CA 92714-4962 Phone: 714-261-8860 Mr. Gene Tatsch 5911 Grandale Drive Durham, NC 27713 Phone: 919-541-6930 Ms. Hope C. Taylor Biochemist/Environmental Consultant Clean Water & Environmental Project for Shiloh 811 Hurdle Mill Road Cedar Grove, NC 27231 Phone: 919-684-2217 • • Ms. Suzie Terres Environmental Protection Specialist Naval Energy & Environmental Support Activity Navy, Code 112E4 1001 Lyons St., Suite 1 Port Hueneme. CA 93043 Phone: 805-982-2194 Ms. Emma Trice Resident Rte. 1, 5812 Koppers Road Morrisville, NC 27560 Phone: 919-481-1017 Mr. W. Al Ward Environmental Health Program Specialist Wade County Department of Health P.O. Box 14049 Raleigh, NC 27620-4049 Phone: 9 I 9-250-4394 Mr. Patrick Watters Project Manager NC-DEHNR P.O. Box 27687 Raleigh, NC 27611-7687 Phone: 919-733-2801 Mr. Malcoom Watts Special Projects Manager ZENECA Concord Pike Wilmington, DE 19897 Phone: 302-886-8085 Mr. Allen Weed Photographer The Cary News P.O. Box 4949 Cary, NC 27713 Phone: 9 I 9-460-2604 • Ms. Sherry Williamson Reporter The Cary News P.O. Box 4949 Cary. NC 275 I 9-4949 Phone: 919-460-2604 Mr. Dee Worden Environmental Health Supervision II Wake County Department of Health P.O. Box 14049 Raleigh, NC 27620 Phone: 919-250-4396 Mr. Robert Wright Elf Atochem North American 900 First Ave .. P.O. Box 1536 King of Prussia. PA I 9406 Phone: 215-337-6810 Ms. Karen Yates Safety/Environmental Manager Acurex Environmental Corporation P.O. Box 13109 Research Triangle Park. NC 27709 Phone: 919-544-4535 Ms. Cynthia Zuch Associate Program Manager Beazer East, Inc. 436 Seventh Avenue. Suite I 150 Pittsburgh, PA 15219-1822 Phone: 412-227-2950 ~ • '. , Alf 12 '93 13:53 USEP8 ,REL,STDD,TSB 513-569-7676 -=--------=,i I EPA Fax Transmittal ~,~o sr,i~ · Transmitted From1 ~ -iS> ( c,; ~!...,_, 1 .-?/ :.,..'i"t'ui Risk Reduction Eng1neer1ng Laboratory ~ ~ Superfund Technology Demonstration Division Technical Support Branch ~1'>. 7 C1nc1nnat1, Ohio 45268 'fl. PR0'1t: Phone: (513) 569-7519 Fax: (513) 569-7676 DATE:~: ~AGES(ITc~~~~!;fED: ____ _ .,;. 1;'.-: ·1 /, ' ,,· ~ ~ 0 TO: _ __::Jc..;.A...:...;;;..c ...:;;~:....:_ . ..,,B~u=-,~•' t...:::::;€..te.='--·. _____ --'-___ · -'-'- COMPANY:_..........:,,-✓..:...· .,__C ........ __.:;.,::;.....::r.J:...:.A-=~:..;_· t:..=-,,:=.-'-v; ___ l"1! ..... !)'---"-_'5-'--'€""" ...... c :Z:-. ......... i,z .... ,:V~--- LOCATI ON: _d_. --=<:.::___ __________ _ FAX NUMBER: (1 r 1) 73 3 'fE-! I ., FROM: 71-#t '-',-ON s PHONE NUMBER: ($-, 3) s-r,,f-zs'rfc _, \&cf<: PfAN', Tf<r!; Is II 8 64.Utg fRL;bvcr: t{Or A 5'1 'r.{$;, 'f teo () v CT I d'. c 4 '-' 'l2 E'. P I '> cJ' Vr'!!. S: I re Pl( V,4,0, 770 N'. ,1cr1 kt rt t<-fr"or(.1'" V,,tr MU•H r A"';; wu. $o,,,,t£ ec u 7'0 v ~ Ct:-,l('r.€/€1{ <;. ,: 11/03✓44AUG 12 '93 13:54 I_ISEP-EL,STDD,TSB 513-569-7575 July20, 1993 Mr, Terr}' Lyona · Technical Project Manager U.S. Environmental Protection Aaency Office of Research and Developmont 26 W, Martin Luther King Drive Clnclnnali, Ohio 45Ui8 NO,:lB? • MC Subject: Contract No; 68-C:0-0047. ,. ~• Woi:t Aulpment No. O-il ~ . . . · Site Preparation ActiY!lles ror the· Sarn llfERM-0-DETOX SITE Dc:momttjaUon ' ' . Dear Mr. Lyons: Enclosed plwe find attached one copy of tho Site Propa:atlon Actlvltlea tor Ibo Sarex THERM-O- DETOX SITE Demonstration. Activities dlacuued Include soil contamlnltioll dollnOlllon, ucavatlon, f~ preparation, assembly of the Sarex THERM-0-DETOX contalnmtnt pad, tolltll.nm&m of tr-.! residues generaited from the proce,,;s, and schedullna of alt• actlvltl11. nt aitacb~ dl1c11aae, act.lvltl1111 not covered In the draft quality 0.1iuranc~ project plan for the demonstration. Optratlon of the Saru THERM-0-DETOX system will lie covered In a wock plan by ETO Bnvlronmelltll, 1'1c,, wbldl will ht completed by July 26, 1993. If you have any questions or comments concernln11 site preparation &etlvltlet dltoi1u.i In the attacllmellt, please call me 11 (4(),4) 5Zl·Z867, Slnceroly, ~~ Roben Hutcheson ProJ~t Manlljer Knachment cc: Beverly Hudson, EPA Region 4 R,,.iiedl.J ProJ•ct M11111er Bruce Nicholson, North Carolina Division of Solid Wute, Superfllnd Branch Mitchell Moss, BTO Envlronmen1al Project Manaaer Shannon Crala, Bouer Envlr(mmental, Inc, ll/03/4<HLIG lC: ':'.3 13: 54 USEP,REL, 5TDD, T5B 513-5E,9-7E,7c N0,387 P.3 • SITE PREPARATIONS ACTIVITIES Site preparation activities for the Sarex THERM-O-DETOX SITS Demoaatratlon Lacludt aoll eontumlnatlon delineation; ~~cavation; f~ preparation;, UHmbly of the proc.a, equipment containmll!t pad; contulnment and storaae <lf trijated re$1due11; site utility and facility reqult11111ent11; a!ld the current schedule fur site preparation demnnstratlon activities. Then ltema are dlsculled below. I SOIL CONTAMINATION DELINEATION, EXCAVATION, AND PEEi) PREPARATION Solla to be treated uMln11 tho BCD te-chnoloaY will ~ obtalnCKI trom th• area north of the tornw Cellon procm bulldlni, Surface soil sampllni condui:tod durln, the remedial lnvestlaatlon indicuted PCP ccmcentratlonK 11reater rhan t ,000 part per mllllon In thla area, WI dloxln,/furans eoncentrations sreate.r than 270 part per billion,·. Activities to be performed In this area, whlell Include .contaminant dellnlllltlon, ¥oil excavation,· and .soil f~ prtparatlon, an dlSCUNtd below, a. b. Soll Contamloarloo Pelioatlon Surface soils to be excavated for trsatmimt u.slna tho Sarex THERM•O-DBTOX systtm will be dellneatlj(j during the fll'1it week 011 slto uslna the f1eld a.oa!ttl~al and 1ampHn11 service provided by PRC. The ,urfaco soils will be analyi-.1 for PCP, 2,3,7,8• totrachlorlnated dlhenio-p-dloxin, 2,3, 7,8-teu:achlorlnated dlbelulo11.1ran, total dloxlna, and total furans. A portahlc 11as chromatoaraph wlll be 111od lor the analyal.s,. Approxlmauly 50 turf~ce soil sample& will be collected for analy,l1, Th• samples wUI be collected from A arid, with sampllns point.I btina sopazated appro:tr.l.mately 10 feet by 10 feet from each othor. The grid will be located In thd vicinity aftoll borlnp X-26 and X-28, which wer~ Installed durln£ the remedial lnvettlratlon. A.11'1011 aamplLaa locatlona will be marked by a pin flaa and clearly kle:itlfled with the corrt1pondln& toll ll!llple number. This will aid lo~tlon and ldentifl~on durlna t\lQltt soil ooclllmlna%ioa lnvest11ations to bu conducted durin1 the remedial dosl1n, sou Excav1tJoo any Screooln1 Approximately 10 to 15 tons of soil will be excavated for tretnnont. The aolla will excavatod to an approximate depth of 0,5 foot below lllld 1urface uslni a front eod loader, Th~ ar~a of excavation wUI measure approximately 25 teec b}' l!I ftet contln11ent upon one area contalnln11 soils contaminated with hlah concentrations of PCP, dlo~hu, and furan1. High variability In surface soil contamination may roquirt oxcavatlon of soils from more than one area to obtain tho nocessary volume for troatment. The soils wlll be excavated uslna a backhoe and placed Into S!l·a4llon druma. Tho 1oll1 will he screened manually t\1 remove &0II particles larsec than O,!I Inch prior to pJaQement In druma, Drums containing iCreened soils will be staied neat did feod preparation area, the location of which Is undetermined at th!J time, ...... _, 11/03/MAUG 12 -,93 1::::: 56 USEP-El, STDD, TSB 51'.::-569-7676 N0,387 • P.5 Facility req11lrem111u for the demonatratlon Include I work trallu, badlrooin, and pbont MrVlc., The work iraller currontly on site 11 betnr provldtd by Bwtr But, tac, lbr 11M durlna the demonstration, Portable tollll!s will be brou&ht to th• sit, If th, Btaut trailer dom not oontaln toilet facilitlea, Phone Kervlce will be provided by portable telephonea brou1bt to the 1lte, Electrical and water utility service and and P<'"able toilet facUltlea provldtd for tho demollltratl<Mi will be billed to PRC Environmental Manaatment, Inc, for payment under EPA Wori Asst11nment No, 0-11, as Kpecifled in the work plan for the project, ~. SCHEDULE The demonstration currently ii ich~ule,d to start durlna the wook ot Auauat Z, 1993 and bt completed by August 25, 1993. · · • . ; ~ .~ ' . ; ' ,-.. . Actlvli'tes scheduled fo~ the we=k of AuguRt 2 Include mobUlzatlo1('of; oqulpmeDt to the site, assemblyrof the prefabricated containment pad, and dollneatlon, e,;~availon, and mlxln1 ot fold soils, · Activitle& scheduled for the w~k of AuiU!t 9 include shake-down testln, of the Sarex THERM• 0-DETOX aystcru in preparation for treatment of contaminated 10U1, pteparatlona for tht alt quality te-,tina of the process equipment by Radian Corporation, and the Vlslton' Day actlvltlea, ActlvitlM scheduled for the week of AuiUJt 16 lncludo demoll8tratlon 111d teetlna of the Sarex THERM-0-DETOX sy8tem through the procesalna of contamlaattd 10D1, Activities scheduled for the week of Aurust 23 Include domobUlutlon of demo11&tr11tlon equipment and personnel. .11/03/4RUG 12 793 13: 55 USEP-EL, STDD, TSB 513-569-7676 N0,387 • 1"004/005 P.4 C, Feed Ptopuatlon Soil$ to be treated need to b, prepartld prior to foodln& Into the Sun THBRM-0. · DETOX system i:,rocessin& ijqulpmont. Feed preparation wlll comlal of ntlxlDJ 10ll1 with sodium bicarbonate powdered reagent In a pua mill. The feed preparation area wUI be linoo with plastic to contain spllll!d soil and reaaent, The contamln11ted soils will be tnnsferred from the 55-sallon dl\lllla 1111ed near the feed proparaticm area Into the pua mill by use of a front-end load«, Solla mixed with the sodh1m bicarbonate re11111nt will be placed back Into 55-&llllon drwnt tlDd •taalkl naar the cont~lnmant pad to be built for the demonstratloc proceu tq11lpmemt, 2. CONTAINMENT PAD ,A pre-fabricated containment pad for tho Sarex THERM-0-D~OX 1yste111 will be comtructod adjacent to the on-site concrete de.contamination pad. The pad 11 belna 00111tructed to contain the ·possible splllaae of fffi! soil, treated soil, and coolln& water: The liner of the contalnmeat pad will consist of a geo•te~tile base overlain by a hl"1 density plastic llntr aad plywood, Tho wall1 of th~ containment pad will b~ collitructed of meital to provide support for the plutlc liner. Soils that are spillod within th11 containment pad will be coll~ daUy 111<1 stored ID 55-iallon dNms. The stored soils will b~ fed Into the THERM-0-DETOX l)'ltelll for treatment. At the end oflh• demon~tratlon, the contalMlent plld will be dluuen:iblod. 1be liner a)'llem wlll be drummed and prepared for off"llite di"posal, The remainder ot i;ontalnment pad wUl be prepared for ahlpment to EPA. 3. TREATED RESIDUES Residu~ g~nerated by lite Sarex THERM-0,DETOX system wilt ooultt of treated 10111, water, and oll. Reaid11" produced by the 1ystem will be stored In '5·1allon dr\111111 and are anticipated to contain concentrations of pentachlorophcnol, dioxins, and t\lrans at •lph'lcantly Nlducod levels, The 1oal of the system Is to produce treated soils that can be dltpOMd of on site, trllllled wa.w water that can b~ discharged to the local treatment works, and wuto oU wblch can be dlspoltd of as non-hawdo11s oil. Analytical teiitina of all residues will bo perlonnod prior to detMmlnlna the method of disposal. 4. UTILmES AND FACILITY REQUIREMENTS Utility requlrementll for the demonstration Include water and eltctrlclly. Electrical service for the Saru THERM-O-DB'FOX ayatem wUI requite IIP&tldlna the curreot on site power ~11pply. Electrical service Improvements to the 1lte will be provided by Carolina Power & Light &nd a local subcontra~-tor. Water requlremenu for th$ demonstration will require leas In& water tanker U"Uckl to1provldt m, neceasuy daily Yolume requirtld for the Sarex THERM-0-DBTOX 1yne111. State of North Qiii::illna Department of W✓ironment, Health and Natural Resources Division of Environmental Management Post-It~ brand fax transmittal memo 7671 • or pa9u • ~From o~pt. James B, Hunt, Jr., Governor Jonathan B. Howes, Secretory A. Preston Howard, Jr., PE., Director August 23, 1993 MEMORANDUM TO: FROM: SUBJECT: Koppers Superfund Site Cleanup Wake County Morrisville, North Carolina Air Quality Concems TI1e Division of Environmental Management has been contacted and requested to provide comments and guidance on Air Quality matters at the subject site. Even though the site is registered as a Superfund Site and is not required to obtai.n ar1 Afr Quality pennit under the Superfund regulation, the Afr Quality standards must be met during the cleanup operations. To date, our staff has still not received infonnation that iJ1dicates that all Air Quality standards will be met at the site. Our specific comments are addressed below: 3. Sufficient infonnation on process operating parameters and pollutant emission rates has not been provided to date to al.low completion of an engiJ1eeting . review demonstrati;1g compliance with all applicable Afr Quality regulations. Ambient air quality monitoring at 'the propeny line to evaluate the PMJO (inhalable particulate) impact on surrounding homes is needed as the Triassic clay soil to be treated is very prone to dusting when handled. The site plan addresses only ambient. pollutant concentration nJc:nJ.i.to.ring on site. A detailed off-site ambient monitoring plan should be submitted to the Air Quality Technical Services Branch for approval prior to acmal operation, Toxic ai.r pollutams listed in 15A NCAC 2H .0610 will be emitted from the operation. An Air Toxics Review is therefore required. If poteritial facility- wide emissions of a listed toxic air pollutant exceeds the threshold levels given in 15A NCAC 2H ,0610, demonstration of compliance with ambient ai.t liJnits in 15A NCAC 2D .1100 must be provided by dispersion computer modeling. Prior approval of a modeling protocol must be obtained. P.O. Box 2Q5.3S, Ral<>igh, North Carolina 2762&-0535 Telephone 919-73:l-3340 FAX 919-733-5317 An Equal Qpponunity Affilma:lve Actlcn Employ~, 50'!. recycled/ I 01I, poot-con,umer paper • • Page 2 Thank you for your August 20th telephone ca.l.l regardi.ng this project. I appreciate your ,tttitude am! assistance in attempting to sccm:e 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 que:stions concerning this matter, please contact Mr. Richard L,snter at (919) 733-3340. cc: Alan Klimek Laura S. Butler Ken Schuster Richard Lasater \ t·; •. ---·---------i • ~-.. • l'fl • ~) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION,IV 345 Courtland Street, N.E. Atlanta, Georgia 30365 FACSIMILE TRANSMITTAL COVER SHEET --~~---,,---------------------- TO: •B ru er. Vv i r h-J ~ b iJ1 SA(_. JC G (A ,+-1-c e, COMP~Y/ORGANIZATION: ~~, Ci (-E-/VV ' /i fA \i h c/ ~L'.>" v, r ( < .', ' PHONE NUMBER: q I 4 '133 ,, ?]o I FAX NUMBER: 9/ o/ '7 3_3 -'18 fl NUMBER OF PAGES SENT (Including this cover sheet): --.1-- P/ease contact the person sending this tax If It Is received poorly or Incomplete, !FROM: g . COMMENTS: NORTH SUPERFUND REMEDIAL BRANCH WASTE MANAGEMENT DIVISION Phone Numbers: (404) 347-7791 or BD0-435-9233 Fax Number: (404) 347-1695 ,--------------------------- 1 ' I • i----,-------'-.,'.,_ _______________ _ 1--------- 1--------------------------l I l i __________ _.:_ ___________ _ ! . .;. EPA .lted $tote• Environmental Protection Agency Offi.olld Waste and Emergency Response Office Reseerch and Development Washington, DC 20460 August 1993 PROGRAM FACT SHEET Demonstration of the Base-Catalyzed Decomposition Teclmology and SAREX~' THERM-0-DETOX™ System DRAFT Koppers Company Superfund Site Morrisville, North Carolina TIITS FACT SHEET TELLS YOU A.BOUT ... EPA 's Supcrfond lnnovat.ivcTechnology Evaluation (SJTE) Program A technology dcmo1)stratio11 to be pcrfonncd at the Koppers Company Superfunct site, located in Morris,illc, Nortl1 Carolina A Visitors' Dav tv be held on i\:ugast ~3, 1993 at t!ie Koppers Company site S-c)'t,Ml.{r 11 I~~.:, INTRODUCTION 171e U.S. Enviromncn1.11 Protection Agency (EPA) identilics new methods for haz.irdous waste cleanup through its SITE Program. Under this prognun, created in 1986, innovative treatment tech- nologies tha1 may significantly reduce the toxicity, mobility, or volume of hazardous waste are demonstrated and evaJuauxl. The SITE Program also g~ncrares reliable performance and cost infonna1ion on the technologies for use in c\'aluating cleanup altemaiivcs for similarly contaminated sites. TI,c tcclu,olo5:· proposed for demonstration is thcBasc-Caulyzcd Deromposition (BCD) technology developed by EPA's Risk Reduction Engineering L1bora1ory in Cincinnati, Ohio, using the SAREX.,TI-lERM-0-DETOX s,'Slcrn developed by ETG Emi- ronmental, Lie. (ETG). and Separation Md Recovery Systems, Inc. (SRS). ·n,, l)U[])O,c of this rlr.monm.tion ic w i<:cooo hew well the technology removes pentachlorophenol (PCP), dioxim, and f~rans from tJ,e soil at the Koppers Company Superfund site in Morrisville. Nonh Carolina. EPA'S SITE PROGRAM Each year, EPA solicits proposals from private tcclmology devel- oper,; to demonstrate innovative technologies under the SITE Pro3ram. Toclmology developers can submit demonstration proposals any tin1e throughout the year. For each technology selected, EPA, oft..."!l 110th input from state and regional agencies, docs tl1e following: Identifies a site \\oth wastes suitable for lrc.1□nent Prcp:u-es a tcclmology demonstration plan Notifies appropriate agencies for intergovernmental and conununity re1ic11·s Prepares a fuct sheet for the public, proposing tl,e site and wclmology match Prepares tl,e dcrnonstralion site Conducts and audits field sampling and laboratory analyses Organizes a Visitors' Daytovicwtl1e tc~hnologydcmonstra- tion Evaluates technology performance P, "l'"'"' w, Appliradons Analysis Kepo1t and a Tcdrnology Eva I nation Repor; swrnnarizing the dcmmLstration rcsulis. as we!! as several oth~r informational itcn1S such as bullc1ins, sununaiics, and a \~deo DRAFT --C-OMA-,,-,T-;-:R-1~-.."-L~-E-D ____ U_i':\_t __ l __________________________ V~A~P_,!ECOVERY SYST.,e;< ____ a~ ~4 r," OR SCREENED SOILS ~ • r . I VAPOR DISCHARGES FEED HOPPER SCREW CONVEYOR MEDUIM TEMP. n<ERMAL D::'.SO~P1 ION UtJ1T (MTTD) COOLHIJG \.'✓ATER TO ATMOSPHERE CARBON POLISHER 1',0Uf.OV5 COtlC,5:NSAfE STORAO,!; OIL WATER SCRLOBERS SCRU38ERS CONDENSOR UNIT DECHLORINATION ~-<-_;;OIL ADL>llWE REAGENTS OllY COND~NS~T'Ef----~ STORM!: -;::__.:,..,c__~L__~:....J COOLING SCREW CONVEYOR C.t..RBO~• A.:>SORf>TIO rnE.AlW WATER Ofl-SITE BACKFILL ~ OR ------1· ~:t_~: ~ OFF-SITE DISPOSAL LIQUID TANK REACTOR (LTR) DECOl<TAMINATED SOLIDS CONTAINER I OILfrlG f7J:urr 1: BClJ 'J'cehnolo£Y and SARl-:,\'.c THERM-0-DETOX Syi»e,:n TECHNOLOGY DESCRl.PTION 11,cBCD technology is an EPA-patented process to remediatc soil and sludge contaminated \\1th cblorinnted organic compounds. Based on the process requircn1cnts of the BCD technology, ETG and SRS have develor...d the SAREX•· 1BERM-O-DETOX system in cooperation \\itl, EPA to evalu:uc the effectiveness of this prOC<..-ss under rcnl-time conditions in the field. 1l1e SAREX~THERJ\!-O-DETOX S)'stcm is based on a proven indirect-heal medium temperature thennal desorinion (MTITI) unit. 1l1c unit is equipp-"'11vith a multiple-shaft agitator for high he..,t transfer efficiency and e-,ceUent local mixing action. 1l1e BCD physical/chemical process dc,1oxifies and chemically deeomooses conlaminants bv removin~ chlorine atoms. Com-. . ~ p0tmds tr.,t the BCD process can decompose include polychlori- natC<I biphcnyls (PC!3), PCP. chlorinated dibenwdio:uns and furans, insecticides, and herbicides. 111t~ process beg.ins by mixing an inorganic reagent with the contamirunod soil, sediincnl, or liquid. Tnc mixturcis heated in the M1TD unit for about I hour at 650 °F to 80(1 °F. Some of the chlorinac:d oontaminams are decomposed during this stcp. TI,e remaining organic contaminants arc thermally desorbcd and re- mo\'ed "ith the off gas. 2 Cleai1 soil exiting the solid reactor can lx: returned to the site. Tne remaining contaminants from thl: vapor condensate and residual dust arc captured and tl"~ted for 2 to 4 hours ar approximately 650 °f in a liquid-tank reactor (L TR). 1i1c L TR uses a high- boiling-poinL hydrocarbon, a proprict,ry catalySt, and soclium hydroxide. Nitrogen is purged through the L TR to control o",'gen levels, preventing tk tank contents from oxidizing or igniting. Oily residuals remaining in the LTR contain dust and sludge and arc combustible. 1l1ey .can be bumed in an oil-fired power plant or trca1C<i and reclaimed by waste oil recyclers. The aqueous condensate from lhe process can be dischnrged to a publicly- 0\\7led treauncm works after being polished through an activated ca,bon=~ncm proe<..,s. Decontaminntcd sludge can bedisposoo ofin tl1e same mrumcr as mwiicipal sludge. Spent carbon from the water polishing can also be treated in this process. 1i1c only by-proclucts produced by the BCD proces, arc biphenvl and low-boiling olefinics, and sodium chloride. SIT£ DESCRJPTION ·111c Koppers Company site is loc:uc<l in tiie Shiloh community, several niilcsnorth of Morrisville, Nortl, Carolina. 1i1esitc covers approximate!,• 52 acres at tiie intersection of Highway 54 and Koppers Road (see Figure 2). I ~tc south=tem section of the site ,.e CELLON processing area and fom1er lagoon area. 11,e CELLON process involved prcssure-:n:,;tillg wood ""th PCP and then steaming it. The water generated from this process, c.alled rinsate. was collected, pro- cessed to remove the PCP by flocculation. and placed in two lagoons at the: site for farther trenonent. The rinsatc did however conrain PCP. 11,e CELLON process was used at the site from 196810 l 975. The two lagoons were closed and emptied in 1976. Water from the lagoons was sprayed onto tl,e ground at the nortl, end of the site, and tlte boMm sludges from the lagoons were spread ~~-- In 1980, high levels of PCP were fowid in the soils in the fom1er lagoon are;, 1U1d CELLON processing area. PCP was also detected in tl,e groundwater. lll 1989 tlie site was added to EPA's National Priorities List (NPL). A remedial investigation (RI) was con- ducted, identifying the primary contaminants at tl1c site as PCP, pol)·cl~orinatcd dibcnzo-p"'1ioxins (PCDD), polychlorinatJJd dibenzofitrans (PCDF), and isopropyl ether (!PE). Titc RI indicated that the CELLON processing area and lagoon area served as sou recs for the migration of contaminants into the groundwater. TECHNOLO~EMONSTRA TION . 2 "IF1 The BCD technology and SAREX'·THERM-0-DETOX system demonstration at the Koppers Company site is scheduled to oxur during August 1993. Thcprimaiyobjectivesofthis demonstrntion are to: Dctcmune how efficiently the BCD process removes PC!', dioxins, and furans from tl1c contaminated $Oil Dctcnninc whether treatment n,-siduals (air, water, oil) meet cleanup levels Evaluatcthcpotential fortl,eBCD process toforin addirional volatile organic compounds when heated to high tempera tures Obtain infom1J1tion required to estimate treatment costs. in::luding capital and operating expenses, for fururc Supcrftuid decision-making purposes CHURCH ROAD KOPPERS ROAD LEGEf'JD 0 EX!STltiU WELLS PROPERTY BOUNDARY U1'1T STi\UCl URESI KOPPERS SITE PHOPERTY LIIJE FIRE POND 3 l', aleigh · ffice ppl); Company, Inc. 712 TUCKER STREET, P.O. BOX 2060 RALEIGH, NORTH CAROLINA 27602 ·.,~OMER NUMBER ] I I I I I I I SALES ORDER No. □~_1_8_2_3~8 O_ Page _____ of ______ _ o [ Elfi<J/? s----------------------------- H ,,, cf} S ecb e:J> p T o __ o ________________________________ _ -·--I ORDERED BY "" -,_?fa C) -'") I CUSTOMER ORDER N?. l CUSTOMER REQUISITION NO. I PHONE NO. lsc CDIOS CD ::/ --<; Reuc,.f-f.Ju: 1-1,n c. o~ I . 7 :'; -:; ---"2.~Cl l ··TCIAL INSTRUCTIONS ,S~LESMAN . : I! ·•-, O~ERRIDES i!.; ~ ' •·c;, Wi_~F:RE.fl.~Mf'~ ,i,ra,'!l~BlltrrE.~tiJJ~ilef!.lj;!iltt~~"!l!!!il ., OU.t.NTlTY <-, t=rovri ~re:A:bii1.1 tJt~gf1i ifil£r~}j if l HJ ~~1:]t DL41~l~tm~1tm ~~ ii o_E~CR!f.rr10N iil V ~ ] ; ~ j !(( ~~ jj ~: ,(j;f-Li:.r~'•,·1,. . UNIT PRICE . % . ~fl !iOROEREO·~ ' 1 .fi Jl I" $ 0 7' /) ; -' .:J ,:} Pn 1\/,~/o 1, I /) . ff ./Y -c::s,e r .1 ' / ' 2 / i 3 hw-· ' \(~o~(<: /\' I L ( ,~-k-' ' s : 11 ·JLL Cl ' -1 u u) Ot:r,-f-"-C-'-1 ~) I t V 0 G L• --! ' 1l ·•1·'.1 ' 9 : l; :,;,\~-,. __ ;,•· ., .. 0 !I ,, : ' I '' . i:RMS: NET 10th PROX. ;,r : ,ll r(~; . ~ OTE: A l ½% ( 18% per annurTt) Service l ·;1 At ;.:iJ;j, 1 .. lteins marked Back Ord" are temporarily out and will be shipped at an early • >. ·l• ··•<! ' :., •. ' J I CHECK ONE D PURCHASED BY : D RECEIVED BY t1arge wilt be added to your statement if!}\··!> t',if.;:':' •: f. date. , J ... , , )Jr payments are not in accordance wit_h :1·• ,. ;!, .! il-',fi." 2. No returns accepted without authorization. ~ i• l ' ,._, ccnci!tons of sale. · · . · · . f~l ~J. ;{-' ;t;/i:'.! 3. All claims must be made within 10 days. .,J: · · ·J:: ti· ~-:): · 4. Returns of special ordered. non-stoi:;k items may be subject ,. charges. tSignatur acknowledges receipt of the a c!S noted.) • hipped items in good condition e~cept BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA Kt.Gt\\Jt.U June 2, 1993 JUff 2 2 1':l':lJ Dear Nathaniel Mayo: Nathaniel Mayo Route 2, Box 77 Morrisville, NC 27560 SUPERfUND SE.t110N As part of the continuing well sampling program conducted by Beazer East, Inc. (formerly Koppers Company, Inc.), in the vicinity of its former plant, Chester Environmental will sample wells the week of June 7, 1993. This sampling program is conducted with the coopera- tion and assistance of the Wake County Department of Health, North Carolina Department of Environment, Health and Natural Resources, and the U. S. Environmental Protection Agency, Region IV. Please . complete the enclosed consent form and give it to the Chester Environmental representative when he calls to perform the sampling.; 1 ,;ou'. wi;I:l:,b~; Pf_~~";'1ic\e~ a copy of the analytical results. ' l'"I J__, . ~· ' ' ..• ,· ~ '.' . • If you.have. any questions, please do not hesitate to call me at . . ' (412) 227-2684 or leave a message at 800-352-2668. your continued cooperation in permitting the collected. SKC/dkm Enclosure cc: B. Nicholson, NCDHS K. Glover, WCDOH A. Ward, WCDOH J. Mitsak, KER Sincerely, J~ we-½ .,; . .,~ {} Shannon K. Craig Program Manager - Environmental Group Thank you for sample to be .. , ... M.· Norman, EPA Region IV· B. Hudson, EPA, Region IV ,, 13':· Giarl'.a BEI · ,· .. · '.: . · ~ ! -•• ' I .~ I • • ·, ·'\ , . .-;J-:-; qj_ ... ·::;~··:.r.:7..:;7 -:. ::\:~ .. r·::8 .c. ·zuch, BEI ' , ';, •• i: I .' ~ ,•·•jJ:,;; J::· GS:_T~-· .. } :• · .. ~· .. ·:_;-·· :·,r·· ,... · .. ·.r ·,:1.>,:r ,; .... _1• :·r: : 1 •1 ,._; • WELL SAMPLING CONSENT FORM I, _________________________ , GIVE CHESTER ENVIRONMENTAL AND WAKE COUNTY DEPARTMENT OF HEALTH AND U.S. EPA PERMISSION TO SAMPLE AND/OR SPLIT SAMPLES OF MY WELL THE WEEK OF JUNE 7, 1993 AND RELEASE THE ANALYTICAL DATA TO THE NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES AND THE U.S. ENVIRONMENTAL PROTECTION AGENCY. DATE: Mr. Levee Barbee Route 2, Box 64 Morrisville, NC Paul Wilkins Route 2, Box 36 Morrisville, NC 27560 Ed and Mary Branch Route 2, Box 79 Morrisville, NC 27560 Nathaniel Mayo Route 2, Box 77 Morrisville, NC 27560 Mr. Frank Burges Route 2, Box 76 Morrisville, NC 27560 David Quate/Quate Welding P. o. Box 131 Morrisville, NC 27560 Mr. & Mrs. Maryland Jones Route 2, Box 14 Morrisville, NC 27560 Gracie Jenkins P. o. Box 265 Morrisville, NC 27560 William Harrington Route 2, Box 8 Morrisville, NC 27560 Ms. Doris Mayo Route 2, Box 6 Morrisville, NC 27560 Mr. Pau.hrrison Route 2, Box 62 Morrisville, NC 27560 Mr. H. D. Copeland Route 2, Box 126 Morrisville, NC 27560 Jessie & Mary Joyner Route 2, Box 79 Morrisville, NC 27560 Dunnig·an Route 2, Box 77 Morrisville, NC 27560 Ms. Rita Balentine Route 2, Box 73 Morrisville, NC 27560 Mr. & Mrs. Wille Davis Route 2, Box 119 Morrisville, NC 27560 Queen & Otto Lyons Route 2, Box 9 Morrisville, NC 27560 Mr. Mack Baker Route 2, Box 11 Morrisville, NC 27560 Randy & Robin Marshburn Route 2, Box 5 Morrisville, NC 27560 Wayne Kennedy 580 N. Church Street Morrisville, NC 27560 Gloria Moss Route 2, Box Morrisville, 247 NC 27560 Mr. & Mrs. Randy Watkins Route 2, Box 245 Morrisville, NC 27560 c. W. Conkling P.O. Box 168 Morrisville, NC 27560 Air & Land Transport, Ltd P.O. Box 30961 Raleigh, NC 27622 Zelda Hughes Route 2, Box 83 Morrisville, NC 27560 Salem Leasing P. o. Box 451 Morrisville, NC 27560 Ms. Flora King Route 2, Box 66 Morrisville, NC 27560 Ms. Helen Hovey P.O. Box 317 Morrisville, NC 27560 Mr. Lawrence W. Giles P. o. Box 462 Morrisville, NC 27560 Mr. Steve Wintermute Route 2, Box 119 Morrisville, NC 27560 Mr. Cha·~ Myers Route 2, Box 250 Morrisville, NC 27560 Mr. Ray Tyndal Route 2, Box 245B Morrisville, NC 27560 DeHaven Transfer & Storage Inc. P. o. Box 163 Morrisville, NC 27560 Ms. Rebecca Barnhill Route 2, Box 27 Morrisville, NC 27560 Mr. and Mrs. Clarence Mayo Route 2, Box AM Morrisville, NC 27560 Triangle Graphics Route 2, Box 67 Morrisville, NC 27560 Mr. & Mrs. Bobby Davis Route 2, Box 119A Morrisville, NC 27560 Ms. Dora Davis Rt. 2, Box 119 Morrisville, NC 27560 Ms. Linda Cooley Davis Road Morrisville, NC 27560 Truss Builders, 54 Box, Highway Morrisville, NC Inc. 54 27560 • • {j,f(M,CJL- BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 USA LAW DEPARTMENT Jill M. Blunden General Counsel Thomas Burgunder Mary Dombrowski Wright Billie S. Flahertv Willtam F. Giaria Mary C. Fairley Donna J. Morris Terrance Gi\eo Faye Dear Ms. Hudson: TEL 412 227-2430 FAX: 412 227-2042 May 26, 1993 Ms. Beverly Hudson Remedial Project Manager tttGt;~tt.U JUNO 1 1993 SUPERFIIND SEtTTON North superfund Remedial Branch Waste Management Division U.S. EPA, Region IV 345 Courtland Street, N.E. Atlanta, Georgia 30365 Re: Morrisville site Beazer East, Inc. Beazer East, Inc. (''Beazer'') certifies that it has not altered, mutilated, discarded, destroyed or otherwise disposed of any records, documents or other information relating to our potential liability with regard to the Morrisville, N.C. Site since the notification of potential liability by the United States. Beazer will not dispose of any documents without the prior approval of the EPA. If you should have any questions, please call me at (412) 227- 2635. WFG/dlk cc: s. Craig C. Zuch B. Nicholson, NCDEHNR I Wri[t'r's Direct Dill! Number 412-227-2635 . J • • BEAZER EAST, INC., 436 SEVENTH A VENUE, PITTSBURGH, PA May 20, 1993 VIA AIRBORNE EXPRESS Beverly Hudson Remedial Project Manager North Superfund Remedial Branch Waste Management Division U.S. EPA, Region IV 345 Courtland street, N.E. Atlanta, GA 30365 Re: Morrisville site Beazer East, Inc. Dear Ms. Hudson: Beazer East, Inc. ("Beazer") has selected Chester Environmental, Inc. ("Chester") as the Supervising Contractor for the · Morrisville Site. Chester will develop and implement the Remedial Design Work Plan for the site. The RI/FS for the Morrisville site was developed and implemented by Chester (formerly known as Keystone Environmental Resources, Inc.). Therefore, Chester is very familiar with the site and its history. John Mitsak is the Project Manager for Chester. years of experience in industrial environmental a registered Professional Engineer. Chester's address is: Chester Environmental, Inc. 8600 LaSalle Road, Suite 502 York Building Towson, MD 21286 He has over 12 compliance and is If you should have any questions, please call me at (412) 227- 2684 or Cindy Zuch, Associate Program Manager, Beazer at (412) 227-2225. SKC/dlk Attachment Yours truly, ~?( . · Shannon K. cr::-:-C Program Manager -Environmental Group cc: J. Mitsak, Chester (w/o attachment) B. Nicholson, NC DEHNR (w/attachment) R. McElveen, NC DEHNR (w/attachment) c. Zuch, Beazer (w/o attachment) w. Giarla, Beazer (w/o attachment) • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 345 COURTLAND STREET, N.E. ATLANTA, GEORGIA 30365 MAY 17 1993 4WD-NSRB Bruce Nicholson North Carolina Department of Environment, Health & Natural Resources 401 Oberlin Road Raleigh, North Carolina 27605 Re: Koppers Co. Inc., (Morrisville Plant) NPL Site Morrisville, North Carolina Dear Mr. Nicholson: NOU.'BS ONO!lBdOS tf{i:il 1·g ~'1W n'J~t~~~~ This letter notifies you that Beverly Hudson has been assigned as the new Remedial Project Manager of the Koppers Co. Inc., (Morrisville Plant) site. All correspondence and further communications should be directed to her. No·address or telephone changes will be required. Please contact me or Beverly if you have any questions concerning this notification. Chuck Mikalian will continue as. the regional attorney for this site. Sincerely, ~!!~ Remedial Project Manager North Superfund Remedial Branch cc: Curt Fehn, NCS Beverly Hudson, NCS Chuck Mikalian, ORC Kim Dao, CRS ' .. --. ' . .... ·-' .. Printed on Recycled Paper • • BEAZER EAST. INC., 436 SEVENTH A VENUE. PITTSBURGH, PA Dear Ms. Benoy: May 14, 1993 AIRBORNE EXPRESS Barbara H. Benoy Remedial Project Manager North Superfund Remedial Branch Waste Management Division U.S Environmental Protection Agency Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 Re: Project Coordinator Morrisville, NC Beazer East, Inc. As stipulated in Section XVIII, paragraph 91 of the Unilateral Administrative Order for Design/Remedial Action for Koppers, Co., Morrisville Site, I am notifying you that I am the Project. Coordinator for this site. My address and phone number are: Beazer East, Inc. 436 Seventh Avenue suite 1101 Pittsburgh, PA 15219-1822 (412) 227-2684 If you should have any questions, please call me. Yours truly, Shannon K. Craig Program Manager -Environmental Group SKC/dlk cc: B. Nicholson (NC DEHNR) R. McElveen (NC DEHNR) w. Giarla C. Zuch • • R!EC(~l~!1EJJ liO'✓ 1,; 1992 State of North Carolina Si.iPER,.·:-::i SECTION Department of Environment, Health, and Natural Resources Division of Epidemiology P.O. Box 27687 o Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr .. Secretary J. N. Maccormack, M.D., M.P.H. Director MEMORANDUM TO: FROM: SUBJECT: November 13, 1992 Bruce Nicholson, Chemical Engineer NC Superfund Section Kenneth Rudo, Ph.D., Toxicologist µt,tr1.,, Environmental Epidemiology Sec'tion Koppers Company NPL Site Morrisville, Wake County As requested in your November 6, 1992 memo, I am providing to your Section a 1 x 10-6 cancer risk value for groundwater contamination for pentachlorophenol (PCP). The use of the 1 x 10-6 cancer risk value has been the recommendation of the Environmental Epidemiology Section as an appropriate health protective action level. For PCP, the 1 x 10-6 value would correspond to 0.3 ppb. If you have any questions, please feel free to contact me at (919) 733-3410. KR: trn cc: Pat Derosa An Equal Opportunity Affirmative Action Employer \ ., 1 ..-1/:::~~:~. f§ r , " "ID /~ ;~_-'/il~.(:;;. ~ ~"" ··:., ! 1--:<.~ -,o !:-'-' ·u I I ~-~ •• 1 ,v'.s' . . .. ,. ,, ,,~ ,. :::.;: ........ • • 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 William L. Meyer Director MEMORANDUM To: From: November 6, 1992 Dr. Ken Rudo, Toxicologist Environmental Epidemiology Section Bruce Nicholson, Chemical Engineer1ot,J Superfund Section · Subj: (Kgpp_ers_Company) NPL Site q{\5f_ $565-fr)eJ'l~? Morrisville, Wake county As we. had discussed previously, the U.S. EPA has proposed a pentachlorophenol (PCP) cleanup goal of 1 ug/liter (which is the MCL for PCP) for the Koppers Company NPL Site. As you had indicated, this concentration is not equivalent to the 1 x 10-6t-isk level. As you know, the State is continuing to monitor Beazer's private well sampling effort. One issue to resolve is setting an action level at which Beazer will provide bottled water. The State would like to continue its consistent policy of an~action level associated with the 1 x 10-6t-isk level. Therefore, we request that you provide the Superfund Section with a groundwater concentration of PCP associated with the 1 x 10-6t-isk level. It is our intention t_o use this concentration as an action level at which Beazer will provide bottled water. Also, as a conservative measure at a time when the toxicological studies for PCP were still under revision, Beazer has been providing bottled water to residents that have had any detectable level (with detection limit of 0.01 ug/liter) of PCP in there sampling results. Beazer continues to do so, even for residents who have not had positive hits since. Now that the health studies have been completed and an appropriate action level can be set, it may affect the status of those who are currently receiving bottled water. Depending on the new action level, some An Equal Opportunity Affirmative Action Employer Dr. Ken Rudo 11-6-92 Page 2 • • of the residents now receiving bottled water may have no risk basis for receiving it in the future. If you have additional comments about this approach, please let me know. BIN\mem\kopken2 cc: Mike Kelly Jack Butler Pat DeRosa • MEMORANDUM TO: FROM: RE: Mike Kelly Bruce Nicholson Pat DeRosa @j) Koppers Co., Inc. NPL Site • July 16, 1992 Dianne Barrett, US EPA, NC Community Relations Coordinator, (404) 347-7791, called me today to ask if Mike and I would meet with Barbara Benoy and Dianne on the morning of Wednesday, July 23, 8:30 am in our office. This would be an informal meeting so that EPA could brief us on what they plan to discuss at the Public Meeting that night (July 23, 7:00pm). A proposed plan fact sheet is attached. Dianne indicated that the proposed plan includes off-site incineration as the preferred remedy for treatment of contaminated soils. She said the purpose of the Public Meeting would be to discuss the proposed plan and present findings of the RI/FS. The public comment period on the proposed plan begins July 17. I told Dianne that Bruce Nicholson is the current project lead for the site and that it would be more appropriate for him to meet with EPA rather than myself. I told her that both Bruce and Mike were out of the office until Monday and that I would relay the information. She asked that we call her on Monday, July 20 to confirm the morning meeting on July 23. Mike, please let me know if you need me to attend either the morning meeting or the Public Meeting on the 23rd. I will be available. Attachment • • BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 USA Dear Barbara: VIA FACSIMILE & FEDERAL EXPRESS June 22, 1992 Ms. Barbara Benoy RECEIVED JUN ;~9 1992 SUPERFUND SECTION U, s. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, GA 30308 RE: Koppers Superfund Site Morrisville, N.C. Off-site Disposal Options In reference to you letter dated June 3, 1992 concerning disposal options for material from the Morrisville site, I apologize for not responding sooner. When I received your request I did, however, assign my consultant the task of reviewing the availability of current options. Based on their review, I am pleased to report that currently Aptus, a subsidiary of Westinghouse Corporation, operates a permitted hazardous waste incinerator in Coffeyville, Kansas. According to their representative, John Blandamer (l-800- 292-2558), the facility is currently permitted to process FO32 soils containing pentachlorophenol and dioxin. My consultants also contacted several other companies with operating incinerators, but found that none were currently permitted. We feel this is encouraging news that there is a facility available for offsi te incineration. We thank you for the opportunity to provide you with this information. If you have any questions, please feel free to contact me at 412-227-2684. Very truly yours, ~~' Shannon K. Crai~ Program Manager -Environmental Group JCM/dkm cc: C. Eehfi, EPA, Region IV vB"."""'"Nicholson, NCDEHNR W. Giarla, BEI L. Crosby, NCDEHNR B. Krasko, Dynamac J. Mitsak, KER • l(EYSTONE E;-..-v11m,-.::-.n::-:T,\L 1n:smmcEs. 1:-.:c. 3000 Tech Center Drive Monroeville, PA 15146 412 825-9600 FAX 412 825-9699 June 22, 1992 Ms. Barbara Benoy NC/SC Site Management Unit Superfund Branch, Waste Management Division U.S. EPA Region IV 345 Courtland Street, NE Atlanta, GA 30308 Dear Barbara: ~EiVt:.U JUN 2 :1 i99l SUPERFUND SECTION Ref. No. 179280-08 Re: Responses to State of North Carolina Comments Attached please find our responses to the State of North Carolina, Division of the Environment, comments dated April 6,1992. Should you have any questions on· these responses, please call me. Sincerely, -? I ~1-, c. $:.!&.IC-/Jr.:111 Sbhn C. Mitsak, P.E. Manager, Baltimore Operations JCM:dc jm470 Attachment cc: Ms. Pat DeRosa Mr. Bruce Nicholson Ms. Shannon Craig Mr. Robert Kraska A CHESTER Environmental Cornrany Pa1,:e. Par. 2-8 2 2-10 3 • • RESPONSES TO STATE OF NORTH CAROLINA COMMENTS DATED APRIL 6, 1992 Comment #1 Please note that the current name for the agency is the Department of Environment Health and Natural Resources, Division of Environmental Management. Groundwater Section. Response to Comment #1 Comment is noted. Comment #2 Do any of the monitoring :,yells, either on or off-site, intercept water producing zones at depths greater than 70 feet? If so, which ones are these? Response to Comment #2 During the initial drilling of monitoring wells, water-bearing zones were intercepted at depths generally less than 55 feet. This necessitated the revision of the drilling program so that monitoring wells were completed in water-bearing fracture zones. Those deep wells where water bearing fractures were encountered greater than 70 feet were wells C-15B and C-32C. The C-15B well location is within the drainage feature between the Fire Pond and the Medlin Pond, and C-32 is proximal to the diabase dike referred to as the Morrisville dike. Raleigh NCDEHNR Comments 179281).()8 DD/DCC#M0068-C 6/92 C-1 2-10 3 2-14 3 2-23 6 • • Comment #3 Is C-12C a dry hole? Response to Comment #3 Mani.taring well C-12C is a 2-inch monitoring well completed with a screen interval from 201 feet to 191 feet below surface; water-bearing fracture intervals were encountered at 45 to 49 feet and 62 feet which were cased off in installation of surface casing. Since this well was completed over an interval where no water-bearing fractures were encountered, yield to the well is extremely low. As stated in the RI text, between July 3 and October 2, 1991, only 1.83 feet of water accumulated, or approximately 0.02 gallons per day. Though well C- 12C is not "dry", based upon this yield from the bedrock to the well, it would never be considered a productive water supply well. Comment #4 Does this mean that water generated during the drilling of all wells in Figure 2-2 was containerized? Response to Comment #4 All monitoring wells were drilled either by hollow stem auger or air rotary methods. No water was generated during these drilling operations. The circulation water generated from well coring operations at wells C-12C, C-9C and PW-1 was containerized. Well development water from the on-site wells and other offsite wells specified in Response #6 was also containerized. Comment #5 The well 7-K is listed twice regarding wells at which geological logging was conducted. Response to Comment #5 The redundant listing of well 7-K will be deleted. Raleigh NCDEHNR Comments 179280-08 IJIJ/DCC#M0068-C 6/92 C-2 ' ' 2-28 2 2-30 3 • • Comment #6 Does this mean that water generated during the drilling of all wells in Figure 2-2 plus C16-C was containerized? Response to Comment #6 All purge water from the onsite monitoring wells was containerized. Purge water that was containerized from near off-site monitoring wells included those listed, namely C-9A, Band C, C-llA and B, as well as C-lA and B, C-2A and B. In Section 2, page 2-28, the first complete paragraph will be changed to state: "Purge water from offsite monitoring wells was discharged onto the ground, away from the well head except for near offsite monitoring wells C-1A, C-1 B. C-2A, C-2B, C-9A, C-9B, C-llA and C- 1 lB, whose purge water was drummed and . stored onsite in accordance with the RI/FS Work Plan. Purge water from off-site well C-16C was containerized during the first round sampling event only. Based upon Round 1 analytical data. no further groundwater containerization occurred at well C-16C." Comment #7 Doesn't the SOPQAM call for upstream sampling to precede downstream sampling? Response to Comment #7 The EPA Region IV ESB SOP /QAM (1986) does not specifically state an order of collection in Section 4.6. The rational used for sampling as specified in Section 5.1.2 of the approved Field Sampling Plan was to proceed from downstream to upstream locations, as incorporated into the Work Plan, in order to prevent potential sediment disturbances from impacting sampling operations. Raleigh NCDEI-INR Comments 179280-08 BB/DCC# M0068-C 6/92 C-3 Table 2-6 Table 2-9 Table 2-9 3-13 2 • • Comment #8 How did the results for filtered samples differ from the results for the unfiltered samples analyzed for PCDDs/PCDFs in Round 1? Response to Comment #8 The · analytical results for PCDDs/PCDFs for the filtered and unfiltered samples are presented in Table 4-50. The corresponding TECs are presented on Table 4-50A The "Filtered/Unfiltered" designations of the samples were accidentally deleted from Table 4-50 and will be reinserted. Comment #9 In Table 2-9, Round 1 lists location S-16 as being sampled for PCDDs/PCDFs. As per your previous response to comments, this should read S-16B. There is no location S-16 in Figure 2-7. Response to Comment #9 Table 2-9 will be changed to read that S-16B was sampled for PCDDs/PCDFs. Comment #10 There is no location S-17 A shown on Figure 2-7. Is S-17 equal to S- 17 A? Please change in Figure 2-7 or Table 2-9 as appropriate. Response to Comment #10 The figure and table will be corrected to be consistent. Comment #11 Is a copy of EPA's fracture trace study for the site available? Response to Comment #1 l A copy is available from EPA Region IV. Please contact Ms. Barbara Benoy, EPA Remedial Project Manager. Raleigh NCDEIINR Comments 179280-08 BB/DCC# M0068-C 6/92 C-4 . ' 3-22 2 • • Comment #12 If no significant groundwater was encountered below 55 feet during drilling, I would expect this was the same for off-site wells. Are the off-site residential wells also less than 55 feet deep? If not, how can the off-site monitoring wells be said to reflect conditions in the water bearing zones tapped by the residential wells? Response to Comment #12 The rationale for deep off-site well construction is discl.!ssed in Section 2.2.1.2, which states that if there was no information available regarding depths of nearby domestic wells, then the boreholes were terminated at 200 feet. Domestic wells drilled, where fractures occur, will yield more water than in massive unfractured rock. In the Morrisville area, water supply wells are typically completed to intercept water-bearing fractures occurring at shallow depths and subsequently drilled deeper to have an open hole reservoir capacity beneath the fractured water-producing zone. 4-3 2 & 4 Comment #13 4-11 2 Since background levels of constituents of interest in soils are discussed in Section 4.1.1.1 and Section 4.1.1.2, background levels of IPE should also be discussed in these sections. Response to Comment #13 The following will be added to Section 4.1.1.2, second paragraph; "No IPE was detected in the soil sample from X-1." The only soil sample in which a detectable concentration of IPE was measured was location X-37, which is discussed on page 4-7 of the text. Comment #14 Why was X-1 selected as a background location for PCDD/PCDF analyses? If burning in the teepee area was of concern, how w~s Raleigh NCDEHNR Comments 179280-08 DB/DCC#M0068-C 6/92 C-5 ' ' 4-13 5 4-29 1 • • prevailing wind direction taken into account here m selecting an appropriate background? Response to Comment #14 X-1 was chosen as a background location.due to its proximity to the site, and because no industrial activity was known to take place in this area. The area is in a farmers field and is higher in elevation than the landfarm area. Consequently, the area would not have been effected by runoff from the landfarm area, Cellon Process area or the lagoon areas. Comment #15 The total TEC value measured at SS-1-TP is 3 times higher (4.9 E + 01 J) than the total TEC value measured at X-1-OSN (L6 E + 01 J). The total TEC value at SS-2-TP (1.3 E + 02 J) is 8 times higher than the total TEC value measured for X-1-OSN. Are these not considered significantly above background? Response to Comment #15 The total TEC of samples SS-1-TP and SS-2-TP are not considered to be significantly above the background concentration in X-1-OSN. This is especially true in the context that Beazer's proposed soil cleanup goal protective of groundwater quality for 2,3,7,8-TCDD in soil was determined to be 7 ug/kg, a concentration that is over 50 times the maximum TEC of 130 ng/kg. Comment #16 Please state the depth of these ponds somewhere in the report so that we can understand what you mean by "shallow". Response to Comment #16 The following information will be inserted into the discussion on surface water in Section 3.3: "The maximum depth of the Fire Pond Raleigh NCDEHNR Comments 179280.()8 BB/DCC#M0068-C 6/92 C-6 4-30 2 • • G as well as the Medlin Pond is approximately ]()' feet. Both of these ponds are man-made." Comment #17 Could evaluated phenolics in samples SW-25 be attributable to upstream sediment or runoff from surface soils contaminated by fallout from the teepee burner? Response to Comment #17 It is doubtful that the low levels of phenolics detected in the surface water sample (12.75 ug/L Round 1 and 1.75 ug/L Round 2) is attributable to fallout from the TeePee burner which was dismantled between April 1972 and February 1974. Surface water analyses are generally considered to be indicative of current conditions. There are other sources of phenolics in the environment which may have contributed to the low levels of total phenolics detected. Figure 4-13 Comment #18 If SW-27 was never sampled it should be omitted from Figure 4-13 or listed as NA. Response to Comment #18 The figure will be corrected. 4-38 2 and Comment #19 Figure 4-16 It appears that the highest TEC values are measured from O -.5 feet in sediments. Are we failing to address the risk of PCDDs/PCDFs in sediment from the Fire Pond outflow by not assessing the TEC level at O -.5 feet along the entire Fire Pond outflow ditch to the Medlin Pond? These areas are highly accessible to the public. Response to Comment #19 The Baseline Risk Assessment did assess exposure to sediments along the entire length of the outflow ditch from the Fire Pond to Medlin Raleigh NCDEHNR Comments 179280--08 llll/DCC#M0068-C 6/92 C-7 KEYSTONE t i'<\"1110:-'~lt.l'<l ,._L Rl-'>Ulillt'I~. l~C. 4-37 4 • • Pond. The potential risk, as calculated using EPA guidelines, was shown to be insignificant. Comment #20 Due to the high TEC level in S-30, sampling S-29 would help determine whether these contaminants were contributed by sources upgradient of the site. Response to Comment #20 This may be true. However, it should be noted that sample S-29 is situated on a surface drainage divide (see Figure 3-3), with a runoff coming from areas to the east. Also, sample S-29 was negative for penta and the concentration of PCDDs/PCDFs in S-30 is not considered high comparatively speaking. Finally, there may be other potential sources of PCDDs/PCDFs from residential burning of trash. Tables 4-7, Comment #21 and 4-8 If additional soil sampling was done in the former lagoon area, it is not reflected in Table 4-7 or Table 4-8. Please indicate where this data appears in the RI (see Comment #126 in the KER response document September 1991). Response to Comment #21 Tables 4-7 and 4-8 present the subsurface soil data from the former lagoon area. For the additional soil sampling performed in October 1991, only surface soil samples were collected. These data are presented in Table 4-6. Table 4-2b, Comment #22 etc. Please define SOL. Is this not a sample specific level? Raleigh NCDEIINR Comments 179280-08 DD/DCCNM0068-C 6/92 C-8 5-1 2 • • Response to Comment #22 A sample quantitation limit (SOL) is a quantitation limit that varies from sample to sample due to the application of dilution/concentration factors and percent solids (for conversion from wet to dry weights in soil/sediment samples). Comment #23 Section 2.2 of the revised Draft BRA discusses constituents of potential interest at the site to include phenolics (12 including PCP), PCDD/PCDFs and isopropyl ether. It then proceeds to say that the list can be shortened to PCP and PCDD/PCDFs, IPE, and:± phenolic compounds (including PCP) as the site COis. Which is the list of COis and why? Response to Comment #23 Section 5.1 will be revised to discuss all potential constituents of interest that were presented in the Baseline Risk Assessment. Eight additional phenolic compounds will be discussed in detail. The Baseline Risk Assessment evaluated the health and environment risk for all potential COis. However, over 99% of the risk is attributed to two constituents penta and PCDDs/PCDFs. The other constituents detected on-site included semi-volatile and volatile organics, metals, and pesticides. Detected semivolatile and volatile organic compounds are limited primarily to those constituents commonly associated with laboratory solvents. The detected concentrations of metals, which are also not related to past site activities, were detected at concentrations in soils that arc commonly found in nature, and at concentrations in water that do not exceed any standard or criteria. The frequencies of detection and concentrations of pesticides in the various analyzed media are very low and were not discussed because they pose no discernable risk. In summary, it would therefore seem inappropriate to discuss in detail the environmental fate and transport of these constituents. Raleigh NCDEI-INR Comments 179280-08 llll/DCCHM0068-C 6/92 C-9 6-1 1 • • Comment #24 Are the former lagoon area monitoring wells hydraulically connected to the off-site "C" depth monitoring wells? Response to Comment #24 In response to Region IV EPA comments, Keystone is preparing a table which presents the monitoring wells which have been demonstrated to be hydraulically connected. During the February 1991 pumping test conducted at well PW-1, hydraulic connection was demonstrated to extend to the northwest to wells C-9B and C-9C. During the packer injection testing conducted in October 1991, hydraulic connection was demonstrated between wells OS-8 and C- 9B/C. Figure 6-7 Comment #25 Units should be changed to ngl[ from ug/1. Response to Comment #25 The figure will be corrected. Raleigh NCDEHNR Comments 179280--08 BB/DCC#M0068-C 6/92 C-10 • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV . t<t.GEIVtU MAY 7 1992 Shannon Craig Beazer East, Inc. 436 Seventh Avenue 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Koppers Company Superfund Site Morrisville, North Carolina TAG Recipient -Contact Person Dear Ms. Craig: MAY 13 1992 Doris Giles, Project Officer and contact for the TAG recipient grbup in the Morrisville, North Carolina community has notified me that Peggy Medlin will be the Project Officer and contact person ,for an undetermined length of time. All document submittals and correspondence that were previously sent to Ms. Giles should be submitted to: Ms. Medlin Clean Water and Environment Project Officer Rt. ii 2, Box 19 Morrisville, North Carolina 27560 This is the only change affected. Please contact me if you have any questions or suggestions concerning the project. I can be reached at 404/347-7791. Sincerely, fj,:u/1fltd_ rx/A;Jetu:J-7), .. -----· Barbara H. Benoy Remedial Project Manager Waste Management Division Enclosure cc: Curt Fehn, EPA Cathy Winokur, EPA-ORC Rosemary Patton, EPA Pat DeRosa, NC-DEHNR ✓ John Mitsak, Keystone Pauline Ewald, ECO Doris Giles Printed on Recycled _Paper I • ..,..--::..SIATl;;•~ ,·~·· ...• .,, ~). f:x'.r.-~ '°'-=:~\ ll~~r&!JJ· ~ ., .,. •'" ,.:JI ""·~"..'::.:::..... • 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 Willia:n W. Cobey, Jr., Secretary Ms. Barbara Benoy NC/SC Site Management Unit Superfund Branch Waste Management Division 345 Courtland street, NE Atlanta, GA 30365 April 6, 1992 Subject: Koppers Company, Inc, NPL Site William L. Meyer Director Development of Soil Cleanup Goals Protective of Groundwater Quality. December 1991 Draft Derivation of Cleanup Levels for the Former Koppers Company. Inc. Site; February 1992 Dear Ms. Benoy: Please find enclosed comments on the subject draft documents submitted by the NC Water Quality Section to the Superfund section. Please include these comments with the other comments already submitted by the State. If you have any questions, please feel free to contact me at (919) 733-2801. Attachment cc: Bruce Nicholson PD /kc/koppers Si erely , f/. Pat DeRosa, Head CERCLA Branch NC Superfund section An Equal Opportunity Affirmative Action Employer • • '··,:'\ I '· .'·,,:: .. State of North Carolina SU Pf RFU ND SECTION Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27604 James G. Martin, Governor William W. Cobey, Jr., Secretary George T. Everett, Ph.D. March 31, 10.92 MEMORANDUM TO: Lee Crosby, Chief S1,per:f:und Section .FROM: Steve Tedder, Chief Water Quality Secti SUBJECT: Comments on the Koppers Company, Inc. NPL Site, Morrisville, Wake County Development of Soil Cleanup Goals Protective of Groundwater Quality Draft Derivation of Cleanup Levels for the Former Koppers Company, Inc. Site Water Quality Section staff have reviewed the subject document and offer the following comments. Director We do not have any specific concerns regaraing the proposal to determine compliance with soil cleanup goals using a quantitation limit of 50 ppq (parts per quadrillion) for dioxin. I want to make you aware, though, that compliance with surface water quality standards or permit limitations is determined using method detection limits. In the case of dioxin, a detection limit of 10 ppq is used to determine compliance with surface water quality standards or permit limitations. Should it become necessary to issue a discharge permit for a surface water discharge at the Koppers site, such as a groundwater remediation discharge, we would use the 10 ppq limit to determine compliance of that discharge. It is possible that a permit limitation greater than ~O ppg could be issued, but this would require that 1'.he dilution ratio of the flow in the receiving stream (under low flow conditions) to that in the discharge would have to be approximately 1,000:1 or greater. It is likely, therefore, that 10 ppq would be t:he limiting factor. Asheville 704/251-ol0S F;iycttcvillc 919/486-1541 Moorewillc 704/663-1699 REGIONAL OFFICES R..ikigh 919/571-4700 \\'.-ilshington 919/946-648! Pollution Prevention Pays Wilmington 919/395-39(X} P.O. Box 29535, Rakigh, Nonh Cirolina 27626---{)535 Tdcrhone 919-733-7015 \1/in,ron-Sall'lll lJl~V896-7(Xl7 Lee Crosby March 31, 1992 Page Two • • I also want to make you aware that, while it is true that North Carolina's current surface water quality standard for dioxin applies only to 2,3,7,8-TCDD as stated in the subject. report, our rules allow us to develop site-specific water quality standards or permit limitations for any chemical of concern, based upon available toxicity data. Most of the other congeners of either dioxin or the furans are not of immediate concern•due to their lower bioaccumulation in fish tissue relative to 2,3,7,8-TCDD, with the possible exception of 2,3,7,8-TCDF (furan), which also tends to accumulate in the food chain. I understand that no surface water discharge is planned for the site, but I wanted to bring these comments to your attention, should the issue arise. If you have any questions or need additional information, please call Greg Thorpe at (919) 733-5083. Crosby.mem/GT-Dl7 • .,,•~ST~TC~ ,/\.° "'''/' .. ,, ~ . •:x" r:: I '""~ f 5 ;ft:t ~:"" ~! ru• l ~'-;J,r:§J . . .'1,FJ//i'/ ~--J -~ 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 NC/SC Site Management Unit EPA Superfund Branch Waste Management Division 345 Courtland Street, NE Atlanta, GA 30365 March 26, 1992 Subject: Koppers Company, Inc. NPL Site William L. Meyer Director Development of Soil Cleanup Goals Protective of Groundwater Quality, December 1991 Dear Ms. Benoy: Please find attached a copy of my comments and comments submitted by the North Carolina Division of Environmental Management, Groundwater Section, regarding the subject document. I understand that the comments will be submitted to KER and I would appreciate a copy of their response. If you require additional information or clarification, t . ' . . • please contact me at (919) 733-2801. .. ·· . ' ·'.::··:1', / .1 . ·.J' Attachments cc: Bruce Nicholson Pat DeRosa, Head CERCLA Branch NC Superfund Section An Equal Opportunity A/!lrmath,e Actlon Employer • • --~ r_...,SIAT(c,~ --·...,"'~···•.,,,~'). t>.~ _r; ,-: :,_ ,c, ~\ i< ;IJ•if~" ~ <;\ ,:: ,~·~' \"_ r,· .. V ;-cl ' ' IP -~__, i'_!) I lj!) ~{.~.;~•::.:·; .. ,• ....... __.... 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 William L. Meyer Director Ms. Barbara Benoy NC/SC Site Management Unit EPA Superfund Branch Waste Management Division 345 Courtland Street, NE Atlanta, GA 30365 March 2, 1992 Subject: Koppers Company, Inc. NPL Site Development of Soil Cleanup Goals Protective of Groundwater Quality, December 1991 Dear Ms. Benoy: I have reviewed the subject document and prepared the preliminary comments outlined below. The document is currently under review by other State programs and final comments will be provided as soon as review is complete. Page. Paragraph 1-1, 1 Fig. 1-1 2-1, 2 Comment 1. 1. 1. How were EPA preliminary soil cleanup goals established? Please cite documentation (PCP = 32mg/kg, 82.5 ng/kg 2, 3, 7, 8 TCDD). Since areas of higher PCP contamination have been identified outside the two potential source areas shown in Fig. 1-1, why weren't these locations included as part of the source areas? What about horizontal movement in the unsaturated zone and vertical movement in the fractured bedrock? Please cite the support for this paragraph in Draft RI. An Equal Op!)Ortunity Affirmative Action Employer V Ms. Barbara Benoy 2 March 1992 page 2 2-1, 4 2-2, 1 2-2, 3 2-4, 1 2-4, 2 • 1. 1. 1. • Does the first model consider only vertical migration in the saturated portion of the weathered bedrock? If so, why? Please cite section in RI that supports this paragraph. Is model 1 more protective than model 2? · Since the Summers model assumes saturated flow in the unsaturated zone, I would assume it would be estimating maximum transport velocity through the unsaturated zone. Is this correct? 2. Has TCLP been conducted to look at constituent leaching through the unsaturated zone? It would be useful to use this procedure to verify the model's predictions. 1. Why is dispersion considered negligible with respect to downward velocity? 2. The model does not account for degradation, therefore, it assumes no loss due to degradation, is this correct? 3. How is constituent concentration applied in this model? Is the maximum constituent concentration used or are the concentrations at various sampling points averaged to estimate a constituent concentration at the source. 4 Does the model assume that movement from the source to the saturated zone is strictly vertical? 5. Does the model assume homogeneity of the source or the unsaturated zone underlying the source? 6. Is vertical migration assumed to occur from the entire area of the source? How does the estimated source area affect the outcome predicted by the model? 1. Does the model assume that once contaminants reach the saturated zone they are simply moving through water? · Ms. Barbara Benoy 2 March 1992 page 3 2-5, 1 2-2, 1 3-1, 2 3-2, 1 3-2, 2 3-2, 3 3-3, 1 3-3, 4 3-4, 1 3-4, 3 3-5, 1 3-6, 2 • 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. • Does Ap equal the area of the source? If model 1 assumes no horizontal movement until a contaminant hits fractured bedrock, how do we explain the apparent horizontal movement of contaminants from sources on site to shallow monitoring wells which are not in bedrock? How do these Kp's for penta and 2,3,7,8-TCDD compare to any that have been reported in the literature? Is Ap equal to the estimated area of source 1 and 2 combined? Why were the samples for hydraulic conductivity taken outside the potential source areas? Was the horizontal hydraulic conductivity also examined to determine which was greater? Where is this information found in the RI report? This assumption makes the model less conservative. Please explain how you came up with 3m as the depth to · the water table rather than 6 ft? How does substituting 6 ft. for 3m change results of the model? Why are you using horizontal hydraulic conductivity in the weathered bedrock while using vertical hydraulic conductivity in the unsaturated zone? What are the dimensions of the fractures used to estimate fracture flow rate? Is there just one fracture used in the estimate? Why? Sample locations for geotechnical parameters are all outside the identified source area. Why? How does using the lower TOC value (2400 mg/kg) affect the results of the model? Ms. Barbara Benoy 2 March 1992 page 4 3-6, 5 3-7, 2 4-1, 2 4-1, 2 4-2, 1 • 1. 1. 1. • Source delineation. How did EPA come up with their numbers? Locations X-48 and X-29 had PCP levels above the preliminary EPA cleanup goals. Locations X-48, X-49, and X-55, had TCDD levels above preliminary EPA cleanup goals. These are separate from the Lagoon area but clustered amongst themselves. Shouldn't the Cellon process area be considered. as another source area? Note that the highest reported TCDD values in Fig. 1-1 are at locations X-48 and X-49. Since these calculated cleanup goals are lower than the levels found outside some of the source areas, will the source area be redefined to include all areas with concentrations above the cleanup goals? If so, won't this change the calculated value again? 2. Since the TCDD value is so low, will additional sampling be done to analyze TCDD content in soil for further source delineation? Many of the locations in Fig. 1-1 were not analyzed for dioxin. 1. 1. Cleanup levels of 55 mg/kg PCP and 4.1 ug/kg 2378 TCDD were calculated to be protective of the water table aquifer. Shouldn't these numbers be used for protection of groundwater? Does the assumption of only 1 fracture mm1m1ze dilution? How does this assumption affect the calculation overall? -. Ms. Barbara Benoy 2 March 1992 page 5 • • Thank you for the opportunity to review and submit comments on this draft document, Development of Soil Cleanup Goals Protective of Groundwater Quality. Copies of the report have also been routed to the NC Division of Environmental Management's Groundwater Section and Water Quality Section, and the Environmental Epidemiology Section for review, and their comments will be forwarded to you through the Superfund Section. I anticipate that KER will address the comments submitted herewith and I would appreciate a copy of their response. If you require additional information or clarification, please contact me at (919) 733-2801. · PD /kc/koppers Sincerely, Pat DeRosa, Head CERCLA Branch NC Superfund Section • • State of North Carolina Department of Environment, Health, and Natural Resources Divi,ion of Environmental Management 512 North Salisbury Srreet • R;ileigh, North Carolina 27604 James G. Martin, Governor George T Everett, Ph.D. William W. Cobey, Jr., Secretary DIVISIOO OF ENVIIDMENI'AL MANAGEMENJ' GROONIJilATER SEX::I'Iel'< Rc~,;onal Offices Asheville 7041251-6208 March 2, 1993 Fi!_vettevilli: M E M O R A N D U M 9I91486-I54I Mooresville· 'IO: 7041663-1699 Lee Crosby, Chief SujY"--rfund Section Raleigh 919/733-2314 Washington 919!9-+6-6481 FRCM: Division of Solid waste Management Perry Nelson, Chief~ Groundwater Section \X'i!mington SUB.JECI': 9l9/395-39(X) Soil Cleanup Goals and Groundwater Quality Protection Former Koppers Co. Superfund Site · 'X'ins1on-Salcm 9!9/896-7007 Wake County -Project No. 179280-11 Section staff have reviewed the December 1991 report prepared by Keystone Environmental ReSOJrces on the subject facility. Per your request, particular attention was given to (1) the applicability, of the hydrogeologic m:xlel used, (2) the use of practical quantitation limits (PQLs) versus met.'-iod detection limits (MDLs) as the preferred level of analytical accuracy, and ( 3) the level of soil cleanup necessary to achieve ccmpliance with the groundwater quality standards ( 1 SA NCAC 2L) . Our cnnnents 0:1 those three issues, as discussed in the Keystone report, are as follcws: ( 1 ) The solute transport cx:rnputer m:xlel used ( SUITTners, 1980) appears to applicable to the pIXCess covered in this report, and we have no reason to question data input values and m:xlel results. (2) We 1,QU]_d agree that the use of PQLs, rather than MDLs, is the proper analytical level to be used in tracking progress of cleanup OjY"--rations, since PQLs are reproducible while MDL's often are not. ( 3) l>.s to cleanup levels for soils, Section 4. 1 of the repoit specifies that it will require renaval of all soils oontaining nore than 55. 0 rrq/kg of penlachorophenol, and 4. 1 ug/kg of 2,3, 7,8 -ro:io, to preclude contravention of groundwater quality standards. Therefore, those are the soil cleanup goals that should be specified. Director • • We appreciate the opportunity to review this report arrl b:ust that these =-rrnents will be helpful. PN:hl:Crosby cc: Arthur M::Juberry Jay Z:imnerm3n Bob Cheek • • HEGt:.IVED SllPERF!JND SECTION 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 MEMORANDUM TO: THROUGH: FROM: RE: February 20, 1992 John Freeman, D.V.M. M.P.H., Chief Environmental Epidemiology Section / Bill Meyer, Director/ .·, I ·~ Mike Kelly, Deputy Directot~ Division of Solid Waste Manage?nent Lee Crosby, Chief Jlu Superfund Section /' Request for Comments on Cleanup Goals Koppers Company, Inc. NPL Site Morrisville, Wake County William L. Meyer Director As you are aware, copies of the document, Development of Soil Cleanup Goals Protective of Groundwater Quality, were distributed to Dr. Ken Rudo and yourself during the February 14 conference call with US EPA. We have received a second document, Draft Derivation of Cleanup Levels for the Former Koppers Company Inc. Site. This document identifies risk-based target cleanup levels and remediation goals for constituents of concern at the Koppers NPL site. The US EPA has requested the State's comments on these documents by March 2, 1992. We would appreciate your review and comments on these documents at your earliest opportunity. In addition, as we discussed during the telephone conference call February 14, we would appreciate any comments or concerns regarding EPA's PQL of 5 x 10-2 mg/I for dioxin. Please submit any comments to the Superfund Section by March 2, 1992 so that they may be forwarded to US EPA. Should you have any questions please contact Pat DeRosa or me at (919) 733-2801 before March 2nd so that we can notify US EPA. Enclosure An E.qual Opportunity Affirmative Action Employer • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV :'EB 1 9 1992 4WD-NSRB Pat DeRosa North Carolina 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 Department of Environment, Health and Natural Resources 401 Oberlin Road Raleigh, North Carolina 27605 RE: Koppers Company Superfund Site Morrisville, North Carolina cleanup Levels Derivation Report Dear Ms. OeRosa: A copy of the Cleanup Levels Derivation Report has been submitted to you by Beazer East, Inc. This letter formalizes a request for review. Please submit any comments to me as soon as possible. our next meeting with the PRP is scheduled for February 25, 1992 to discuss some of these issues. If at all possible, any comments that can be forwarded to them prior to the meeting would be welcome. Please contact me if you have any questions. I can be reached at 404/347-7791 or fax number 404/347-1695. / si,~-~erely, > / /' 11Jc2-~l:'lllt< ,,AJ _,{J::;,~-v- Barbara H. Benoy /J Remedial Project Manager Waste Management Division Enclosure cc: Lee Crosby, NC-DEHNR William Meyer, NC-DEHNR Curt Fehn, EPA Kathy Winokur, EPA-ORC Bruce NicholsonV Printed on Recycled Paper • February 17, 1992 MEMORANDUM TO: FROM: RE: Lee Crosby, Chief Superfund Section Pat DeRosa, Head ,;J_,.,~ CERCLA Branch Koppers Company, Inc. NPL Site Conference Call, February 14, 1992 • This memo summarizes the issues discussed during our telephone conference call with US EPA last week. As you are aware, the State participants included: Lee Crosby and Pat DeRosa, Superfund Section; Perry Nelson, Groundwater Section; Greg Thorpe, Water Quality Section; and John Freeman and Ken Rudo, Environmental Epidemiology Section. The US EPA participants included Barbara Benoy, Curt Fehn, Elmer Akin, Becky Fox, all with Region IV EPA and Bob Krasko, Dynamac Corporation. The first issue discussed was EP A's position on an action level for dioxin in groundwater at the Koppers site. EPA recommends an action level of 5 x 10·2 ng/1 which they contend is equal to the Practical Quantitation Limit (PQL) and which represents an approximate 1/10,000 increased cancer risk. This level has also been proposed as an MCL for public drinking water supplies. EPA recommends that this level be used as the "detection limit" and that results below 5 x 10·2 ng/1, including Estimated Maximum Probable Concentration (EMPC) values, be considered not-detected. This would provide a reproducible detection limit for dioxins. An explanation of how the PQL value for dioxins was established by EPA appears in 55 FR No. 143, Wednesday, July 25, 1990 p 30416. The general consensus was that 5 x 10·2 ng/1 would be acceptable as a detection limit assuming the methodology used to derive the PQL was valid. Ken Rudo will be reviewing this information. The second issue discussed was the report generated by KER developing soil clean- up goals protective of groundwater at the Koppers site. A copy of this report was distributed to the meeting participants. KER incorporated EPA MCL's for PCP (1 ug/1) and State groundwater standards for dioxin (2.2 x 104 ng/1) to develop soil cleanup levels of 95 mg/kg for PCP and .007 mg/kg for dioxins. Perry Nelson indicated that further review of this report by hydrogeologists in his Section would be necessary. The Superfund Section will also be reviewing this document and submitting comments to EPA. • • The third issue discussed was the issue of treatment and/ or disposal of dioxin contaminated soil. EPA is currently under the opinion that the only' method of treatment available for dioxin contaminated soils is incineration. Currently, they estimate that 1000 cubic yards of contaminated soil will require treatment. We discussed the options of on-site incineration and disposal of residuals. Apparently, ash from wastes incinerated on site would be more readily delisted than ash generated from off-site incineration. In addition, there are no permitted facilities currently accepting dioxin-contaminated soils. This option would therefore entail some sort of storage ori site until such a facility is permitted. A question arose regarding the State policy supporting on-site treatment as opposed to off-site treatment. EPA would like to know whether the State would concur in selection of a remedy involving off-site treatment/ disposal. Fourth, EPA indicated that they would like to schedule a public meeting as early as April 1st to discuss the results of the RI and to introduce the options available for treating dioxin-contaminated soils. The goal here is to ensure public participation at the earliest stages of remedy selection. The revised RI is not yet available and it is unclear whether the final RI will be released before the public meeting. • • 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 William Claxton Pennington 303 Watkins Road Morrisville, North Carolina 27560 Dear Mr. Pennington: 10 February 1992 William L. Meyer Director I am writing in response to your letter to Ms. Barbara Benoy, US EPA Region IV, of 9 January 1992. The Koppers Company Inc. Site, former location of Unit Structures, Inc., was designated as a National Priorities List (NPL) site in March 1989. As an NPL site, it has been targeted by the US EPA with support from the North Carolina Superfund Section, Solid Waste Management Division, for remediation of environmental problems, including groundwater contamination. As part of this remediation, all groundwater users in the Morrisville area with contaminated wells have been identified and supplied with bottled water and are presently being connected to public water service from an unthreatened source. The North Carolina Superfund Section maintains an extensive file on the Koppers Company Site. The file contains all pertinent reports and findings that the US EPA has generated on the site to date. You are welcome to review the file for information that may assist you. I If you have any questions concerning the ongoing cleanup activity at this site or would like to review our files, please contact Lee Crosby, North Carolina Superfund Section Chief, or me at (919) 733-2801. cc: Congressman David Price Bill Meyer Mike Kelly Lee Crosby Bruce Nicholson Chemical Engineer Superfund Section An Equal Opportunity Affirmative Action Employer •, • William Claxlon Penninglo. 303 Wat kins Road Morrisville, Nori h Carolina 27560 RESIDENTIAL PHONE: (919i 469-4247 January 9, 1991 Ms. Barbara Benoy Remeriial Project Manager iJ S. -EPA Region 4 345 Court land SI reel , N . E. Allai1la, GA 30365 Dear i.is. Benoy• I, WilFam Claxlon Pennington am totally disabled lo work due lo being e~poseci. on my former job at Urril Structures, Incorporated, Morrisville, Nori h Carolina. l have peen unable to work numerous lime; however, my skin problems have golten worse. My medical reports provides diagnosis of severe topical demalitis due lo chem;cals useri lo preserve wood per· the aforementioned work site. The chemicals ulilized '"Penlachlorophenol (PCP) and I sopropy lei her (IPE )'' . The United Slates Environmental Protection Agency conveyed that both chemicals as indicated above were ;n the waler and wells localed in Morrisville, North Carolina where I've resided for over 30 years. I am requesting ass;stance from The North Carolina Superfund Section of the Norlh Caroina Div'sion of Health Services. I have not received workmen's compensation or any funds since rny doctor declareri me disabled; October 14, 1991. I look forward to hearing from you , Sincerely, P~~ t. w;lliam Claxton Pennington SSSN (239-40~3168 WCP 'pb .•.. , cc: Congressman Dav'd Price 225 Hillsborough Slreel Suite 330 Raleigh, l-iorl h Carolina 27603 • • 3--!.'.: ..:::.:::~·F.;:_.,!-t~C STREi::7. ,'J.::::. 4WD-llS'.<3 ('/ i -!.. l ia.~-, c. Pennin(JtGn 303 Wati:i!ls Road AT1-.-~:,;:_;, ·3C:Cf;GiA 3C3ci:': Morrisville, North Carolina 27560 Re: C-:>rraspondence c.::ar Hr. Pe:mington: 'l'hc Ag-ency is in receipt cf your January _9, 1992 letter. Copies of your letter were forwarded to tha Agency for Toxic Substances and Disease Registry (ATSDR) a~d to the National Institute of Occupational Safety and Health (NIOSH). Occu!?atioi~a.l exposure comes under the jusrisdiction of NIOSH. The contact for i-iIOSH is Stanley Salisbury in Atlanta, Georgia. His nllmber is 404/331-2396. A -=~t'Y a£ tho letter to NIOSH was forwarded to ycur attention. Th.:! En~Jircnmcntal Pictection Agency (EPA) has received a response from ATSDR ::oncerning your letter. ATSDR has reviewed the private well data on the well that supplied your residence. It has been deterr.iined that the amount of pentachlocophenol detected in that well does not pose a health threat due to exposure to pentachlorophenol. The levels detected in the well were 2pproxi~ately 100 times less than the current EPA safe drinking water standard cf 1 ug/1. The highest concentration detected was 0.024 ug/1 in October 1988. The occupants were provided bottled water in February of 1989 and hooked up to a municipal system in September 1990. ?lease contac~ me if you have any questions or suggestions concerning this letter. I can be reached at 404/347-7791. E2::::a.:::-.3. H. Benoy !ls;:-,,-:::G.:..i~ P:::-oject ~ias:e Management Division cc: .::·,.:.rt Fehn, EPA C~thy Winokur, EPA-ORC Pat DeRcsa, NC-DEHNR Chuck Pia~rosewicz, ATSDR Bob Safay, ATSDR 1-ielody !".awamoto, NIOSH • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 JAN 3 1 1992 4Wll-NSRB Pat DeRO0a Superfund section ffEGtfV · Fi:i; ... ,, , ED ,j 199:, N.C. Division of Solid ~aste Management Sltite 150 -101 Oberlin Road Raleigh, North Carolina 27605 Re: Koppers Company Superfund Site Morrisville, North Carolina D::?ar M£i. DeRosa: SlJPERFiJNo SEc110~ 'l'his lc:.:tter is written to emphasize the importance of defining the Horth Carolina Applicable or Relevant and Appropriate Requirements {ARARs) for the Koppers Company Superfund Site. The contaminants of concern for the site have been identified for quite some time. I would like to propose a meeting in February between EPA and North Carolina. Since the ROD is scheduled for June '92, this issue needs to resolved as soon as possible. Please contact me if you have any questions or suggestions concerning this letter. I can be reached at 404/347-7791. ~1/4 . · Barbara H. Benoy~ Remedial Project Manager Waste Management Division cc: Curt Fehn, EPA Elmer Akin, EPA Cathy Winokur, EPA-ORC Lee Crosby, NCDEHNR William Meyer, NCDEHNR Robert Kraska, Dynamac Shannon Craig, Beazer John Mitsak, Keystone Printed on Recycled Paper • • UNITED STATES ENVIRONMENTAL PROTECTION t!.fk"f:.Ur;fin REGION IV JIJ.('{ J ( , 1/,/J JAN 1 4 1992 4WD-NSRB Shannon Craig Beazer East, Inc. 436 seventh Avenue 345 COURTLAND STREET. N.E. ATLANTA, GEORGIA 30365 Pittsburgh, Pennsylvania 15219 Re: Koppers Company superfund site Morrisville, North Carolina Groundwater Sampling -Analytical Methods Dear Ms. Craig: SUA 199_;, 'ERFUJIJD S£C71g~ The January 9, 1992 letter from John Mitsak, Keystone Environmental. ,was received onl:January 13 ,. 1992. Page 2 of the ··letter·· stated.1that: ....• you had .suggested . .that Method 515 be used ;,.s the ... "results,..,of. record.•: c:•-.tand that::''.no :8270 penta [pentachlorophenol, >(,PCPJ.] · results· be· .::...:;._ ·•'•'~-~. :'.-;_~repor.ted· .. •~-~~-:This.:.:.was· not. discussed· during our,:c~mference· :call• ·;_:,,..EPA.-:~:: .. ::.t . ..;:: :·, ·:>:'.·y---:u,~:.:.:-: ..... ,':;. .-:--i.Wil·b::Con·siderJ.M0thod,-.515· ,th~~·:primary.· guanti tatiofl.·":.methodiforL·PCP.•;.r.1 ·-~· J ~., :".•:.;,;·i · ;,:.:-· .:.n:.:.. ·;·: :_:;;•. -.J.': -:a·::":·.:.:-::::r~. ·.J.;~EPA'-:;Wf-1.'1ffriOt·.r.ignore':n:·esults~:for PCP~·· generated.~qy.~rMethOdJ?':!t~]O~:~~nd:::.will'.::l:L:.-, ·_;·:1 ... • ,. r;;i.:,.~·J .• : .. ., . .:.:.::.:.::.-:!~_eport .. those,,.reSlilts: .for. .alL.-EPA samples., Fur.th~pnore~ ... ,EPA ... r~quests .. _· .. . , .. ,,,, ,,,.,,,.,.,.,,,5 · , ,,.that,'anyosdetectable amounts of··•PCP determined by,,,Method, ·.8270,:be · "·, ,,,~···• · ,,., . .., ,. -reported .for all .. .those saffiples collected dul:'ing-.the week. of . .-January.; 6, 1992. Please ·contact me if you have any questions or suggestions concerning this letter. I can be reached at 404/347-7791. Barbara H. Benoy Remedial Project Manager Waste Management Division cc: Elmer Akin, EPA Charlie Hooper, EPA Tom Bennett, EPA Curt Fehn, EPA Cathy Winokur; EPA-ORC .Pat• DeRosa,. NC-DEHNR J Robert Krasko, Dynamac · :1?~n __ Mits~k,, -~,eystone '"r - ·! Printed on Recycled Paper • BEAZER EAST, INC., 436 SEVENTH AVENUE, PITTSBURGH, PA 15219 USA Dear Barbara: December 3, 1991 Ms. Barbara Benoy NC/SC Site Management Unit Superfund Branch, Waste Management Division U.S. EPA Region IV 345 Courtland Street, NE Atlanta, GA 30308 As we discussed during our last meeting on November 19, 1991, confirmational sampling and analysis of select groundwater wells to resolve the questionable phenolic data has been delayed until the week of January 6, 1992 in order to accommodate EPA lab's required lead time. Consequently, you also informed me that it is your hope to issue the ROD on June 30, 1992 rather than April 30, 1992, and that, to accomplish this, a schedule of submittal dates should be submitted by Beazer. I am happy to submit a schedule to you but I feel I should reiterate my earlier concern that this schedule, due to circumstances beyond our , or our consultants' control, may be difficult to meet. That having been said, based upon the scope of work contained in the proposed confirmational sampling program submitted to you by Keystone on November 14, a tentative schedule is as follows: RI Report (Final) Submittal Risk Assessment (Final) Report Submittal FS Report (Draft) Submittal March 31, 1992 March 31, 1992 April 30, 1992 1 • • This schedule is predicated and is conditional on completion of the following tasks: Confirmational sampling Analyses and Validation Completed by 1/14/92 45 days following sampling If these dates are met, we will be able to complete the RI and Risk Assessment Reports on the dates indicated above. Please note that to incorporate EPA split results, the validated analytical data should be submitted to me by no later than February 29, 1992. In order to submit the FS Report by April 30, we must have agreement on clean-up levels by March 11 to allow Keystone enough time to complete the detailed evaluation of alternatives and incorporate these levels into the Risk Assessment Report. In order to facilitate reaching agreement, Beazer is willing to submit a separate clean-up level document for EPA approval which will present both the results on the soil modeling as well as the risk- based clean-up goals for the site. This document will be submitted to you by February 10, 1992. If we can reach agreement on clean-up goals within 28 days following that submittal, we should be able to make the date for issuing the ROD. Obviously, hard work and mutual cooperation will be required in order to make that date, along, perhaps, with a little luck. The fact that we have had these ingredients so far has been very helpful in advancing the project to this point. I look forward to your continued assistance. I have been informed by Keystone that they are unable to complete the modeling report which we had earlier agreed to submit to you by December 6. Due to the changes in the schedule outlined above, the modeling report submittal is no longer critical to the progress of the RI/FS completion. I have been assured that the report will be submitted to you on or before December 18. I apologize for the delay. After your review of this letter, please to discuss any questions you may have. this schedule is requested. do not hesitate to call me Your written approval of SKC/dkm cc: J. Mitsak, . ~/ Zubrow, VP. DeRosa, B. Giarla, KER KER EPA BEI Very truly yours, cffU-,u_,ty1._/( tj. ~hannon K. Craig Program Manager -Environmental Group 06/29/94 13:34 fiASTE MA~GMENT PRffiRAM 1ST FLR. ➔ 919 733 4811 • OPTIO'-'l FORM 9' (7-,0I• FAX TRANSMITTAL .•. .,. -·· . -... BYLAWS OF THE It Cl p11g&1 ► CLEAN WATER AND ENVIRONMENT PROJECT FOR SHILOH a non-profit corporation April 19, 1991 06/29/94 13:34 ARTICLE I ARTICLE U l\RTICLE III WASTE MANAGMENT PRffiRAM 1ST FLR. •• , •. BYLAWS OF E CWEPS Pu:rpose: The Clean Watcir and ·Environment Project for Shiloh, rnc., (hereafter referred to as CWEPSJ, is a non-profit, c;;ommuni ty based organii:ation concerned about the safe and permanent cleanup of hazardous wastes in the Shiloh Coromunity, including National Priorities List superfund sites, such aa the Koppers Site. Its purpose is to help educate the coll1!llunity regarding the proposed cleanup methods and to provide citizens with a voice in that process. CWEPS will also act aa Technical Assistance Grant recipient from the United states Environmental Protection Agency and to represent all concerned cit_izens in the adnlinistration of said grant. · Membership: Membership· is open to all citizens concerne'd about ·the· · cleonup of the Shiloh community and the impact the ·cleanup will have on the local environment, -All piairsons are eligible for membership by demonstrating an interest in the purposes of this organization, regardless of race, ·sex or age. All members shall affix their signature to a roster, indicating their membership. Oftices: Section 1. Principal Place of Business. CWEPS shall hold monthly meetings at the Shiloh . Community Center, Morrisville County Line Road, Morrisville, North Carolina. However, the meeting place may be changed to any public place or private residenc;;e within the Shiloh Co111II1unity, section 2. Registered Office. The registered office shall be at 5711 Koppers Road, MorriBville, North Carolina. . , .2 05/29/94 13:35 ARTICLE IV WASTE MANAGMENT PRffiRAM 1~.Sc.:T_..:..:FLc:.R;.:._➔_;9:;;1~9-7'-'3;:.3_48;:.1_1 ____ ~_N□_._s_33~--Q0~3---'-"-• - • ~®; :;:•::tll .. I'., BYLAWS OF THE CWEPS Board of Directors; Section 1. General Powere, The Members of the Steering Committee shall have general charge and control of the affairs, funds and direction of CWEPS. Section 2. Number and Oualificgtions. The nwnber of Members of the Steering Committee of CWEPS shall be seven ( 7) , ancl each member shall have on vote. Th" initial Members of the Steering Committee shall be elected and shall resid" in Wake County. The Member:, of the Steering ColllDlittee may elect to name honorary board members, but there shall be 110 residency requirement for Honorary Directors, nor shall they have voting powers. Section 3. Term of Office. Upon inetallation of the Members of the. S_teering CollDll1.ttee; all members !!hall serve for three years, unless he/ she resigns or is removed from office as hereinafter provided. Section · 4, · · !1eetinga; ·Th·e Members of the ··Steering Committee shall meet at least four times per year, of which one meeting·: !!hall he the annual meeting: . The annual meeting shall be for the purpose of appointing new officers and other appropriate busineaa. The meetings will be conducted in general accord with Roberts Rules of Order. Sectj.on 5. Quorum. The majority of the nwnber of the· Members of the Steering Committee fixed by these Bylaws shall constitute a quorum. Section 6. Resignation. A member may resign from membership on the Steering Committee at any time by preaenting a written reaignation in person at a regular meeting or special meeting of the Members of the Steering Committee. Section ? • vacancie!l. A vacancy occurring among the Members of the Steering Committee may be filled by anyone belonging to CWEPS, providing that person is a resident of Wake county. All such vacancies shall be filled by a vote of the remaining Members of the Steering Committee. Section 8, Compensation. Members of the Steering committee shall not receive any compensation for thoir services. Section 9. Absence. Should any_Members of the Steering 3 05/29/94 13:35 ARTICLE V WASTE MANAGMENT PRffiRAM 1ST FLR. • ➔ 919 733 4811 ·~ 'i;_i'lf) N0.533 i,04 BYLAWS OF THE CWBPS Committee be absent without good cause from three eonsecutive meatings of the Steering Committee, that seat may be declared vocant, the Yacancy filled as provided ~y c:.hese Bylaws. officers: Section l, Titles. The officers of CWEFS shall be Director and Treasurer. Seetion 2. Appointment and Terms, All of the officers of CWEPS shall serve through appointment by the Members of the St:eering committee for one year, The officers shall serve until the expiration 0£ his/her term, resignation or removal from office. ' Section 3. vacan•cies and Removals; · vacancies among the officers may be filled by appointment. Any officer may be removed when the Steering Committee deems it to be in the best interest of CWEPS, sect:ion 4, Director. The Director shall be the chief · Member of ·the Steering Cornniitte9 of CWEPS and shall be subj9ct to the control of the Steering Committee and shall manage this organization in accordance to these Bylaw8, The Director shall preside at all meeti~gs o: the Steering Committee. The Director shall sign, with any proper member, instruments which may be lawfully executed on behalf of CWEPS, except where required or permitted by law to be otherwise signed and executed, and except where the signing and execution thereof shall be delegated by the Members of the Steering Committee to some ·other officer or agent. ~n general, the Directer shall perform all duties as may be prescribed by t:1e Steering Committee from time to t1111e. Section 5. Treasurer. The Treasurer shall have custody of all funds belonging to the organization end sh,,ll receive, deposit or disburse the same under the direction of the Members of the Steering Committee; provided that the Members of the Steering Committee may appoint .. custodian or depository for any such funds and deaigna"e whose signature or authority ~uch fund8 may be disbursed or tran.sferred, ·.•·· Section 6. Absence·or Disability of Officer8. In the event of the absence or disability if any officer, the J.len,J:>Grs of the S_teering Comn1i ttee may ctelegate his /her power.s and duties for the time being to any other 4 05/29/94 13:36 ARTICLE VI ARTICLE VII WASTE MANAGMENT PRCERAM 1SccT__;FL-=R::.--➔,9-1;:.9_7_3_3_48_1_1 _____ N_□_-... s_33 __ i._13_5_ • ~ .. ·~~ ~,, {·'[ BYLAWS OF THE CWEPS officer, Section 7. Employe9s or Agents. The .Members of the StGiering Committee may employ or authorize the employment of advisors or agents as shall be considered necessary o:r advisable for the conduct of the affairs of the organization and shall assign their duties aqd fix or approve their compensation. Cgmmittees, Section l, committees. Other committees not having and exercising the authority of the Members of the Steering Committee in the management of CWEPS may be designated by a resolution adopted by a majority of the members present at a meeting at which a quorum is present. Except ae otherwise provided in such resolution, the Members of the . Steering Cammi ttee of CWEPS a hall appoint the merullers and chairman thereof. section 2. Term of Office. Each membor of a committee shall serve as such until all duties of that committee are mQt or until a euccessor is appointed following a written resignation. Section 3. Chairman. Except as otherwise provided in these Bylaws, one membor of each committee shall be appointed chairman by the person or persons authorized to appoint the members thereof. ' Section 4, Vacancies. Vacancies in the membership of any committaa may be filled in the same manner as the incumbent member was appointed, Section 5. Quorum and Action of Cornmi ttees. Unless otherwise provided in the resolution designating a committei:i, a majority of the members on the committee shall constitute a quorum, and the act of a majority of the members present at a meeting at which a quorum is present shall be the act of th<:> committee. funds: 5 05/29/94 13:36 ARTICLE VII I .ASTE MA~GMENT PRIERAM 1ST FLR, __ ➔ i 733 481_1_ A $ • \~.I N0.533 GJ0E, BYLAWS OF THE CWEPS Sect i an 1. Checks. All checks, draft a or ordere for the payment of money or notes or other evidences of indebtedness issued in the name of CWEPS shall be signed by such officer or officers or other individuals as the Members of the Steering Committee may designate, Section 2. Bond. The Members of the Steering ~ommittee may by resolution require any and all officers, agents and employees of CWEPS to give bond to the CWEPS, at the expense of CWEPS, with sufficient sureties, conditioned on the faithful performance of the duties of their respective offices or positions, and to comply with such other conditions as may be required by the Members of tha Steering Committee from time to time. Section 3. Deposits. All · funds of CWEPS shall be ·-deposited from time to ·time to· the .credit ·of CWEPS in. such banks or other depositories as the Mambere of the Steering Committee may select. Section 4. Gifts. The Members of the· Steering Committee may accept on the behalf of CWEPS any contribution, gift, bequest, or devise of personal property for the general purposes or for any epecial purpose of CWEPS. Section 5. Fiscal Year. The fiscal year of the organization shall be the period ending on Dacember 31 of each year. Section 6. Audit of BOoks. The books and records of the organization shall be audited at the discr~t~on of the Members of the Steering Committee or as required by law. All books and records of the organization may be inspected by any member for any proper purpose at any reasonable time. General Provisions: Section 1. Waiver of Notice. Whenever any notice is required to be given to any Members of the Steering Committee under the provisions of these Bylaws, a Waiver thereof in writing signed by the person or persons entitled to such notice, whether before or after the time stated therein, or attendance at the meeting referred to in such notice, shall be the equivalent to the waiving of such notice, 13:37 WASTE MANAGMENT PRffiRAM 1ST FLR. •• NO. 533. _ _ccGl.;..07 __ BYLAWS OF THE CWEPS section 2. Use of Fllnds. Any and all received by CWEPS will be used to gather onvironmental and health information and"for educational purposes, section 3. Taxability. Notwithstanding any othG1r provision of these articles, CWEPS shall not carry on ,my activities not permitted to be carried on by (a) a corporation exempt from Federal income tax under section 501 (c) (3) of the Internal Revenue Code of 1954 or the corresponding provision of any future United States Internal Revenue Law or (b) a corporation contribution5 to which are deductible under Section 170 (C) (2) of the Internal Revenue Code of 1954 or any other corresponding provision of any future United $tates Internal RevG1nua Law. -Section 4. · 1unendnients ... · These I)ylaws · may be amended or repe<'lled and riew .Bylaws niay be adopted by the affirmative vote of two-thirds of the Members of the Steering Committee present at any regula~ or special meeting at which a quorum ie· present, provided ·that notice of the proposed action shall have been included in the notice of the meeting as shall have been waived as provided in these Bylaws. · 7 • • UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 4WD-NSRB Vanessa M. Berge Wyatt, Tarrant & Combs McClure Building P. O. Box 495 Frankfort, Kentucky 40602 Re: 4-RIN-1026-90 Dear Ms. Berge: 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 ttt.Ct.lVE.O JUN 8 l::!90 SUPERFUND SECTION This letter is in response to your Freedom of Information Act (FOIA) request for reports from Region IV files on the Koppers Superfund Site, Morrisville, North Carolina. Please find the materials enclosed. Fees are waived as di minimus. The maps and photographs referenced in the Site Inspection Report should be obtained from the North Carolina Department of Environmental Health and Natural Resources. The contact is Pat DeRosa, Superfund Branch. She can be reached at 919/733-2801. Should you have any questions, please call Barbara Benoy of my staff at (404) 347-7791. Si~c.erely, I , 'I/ , l n 11 Co.!Jluvt: "t)s-t:vvtlC"------ Robert Jourdan,-Chief North Superfund Remedial Branch Enclosure Pat DeRosa, NCDEHNR • :,; • • U~JITED 3TATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 345 COURTLAND STREET. N.E. ATLANTA. GEORGIA 30365 AFR 1 D 1G20 -Kt.GtJVEO A? R :~ :l tl90 4WD-SFB CERTIFIED MAIL SUPERfUNO SEC110N RETURN RECEIPT REQUESTED Shannon Craig Beazer Materials and Services, Inc. 436 Seventh Avenue Pittsburgh, PA 15219 RE: Koppers Site Morrisville, North Carolina Dear Ms. Craig: During a site visit on March 28, 1990, I observed that the CELLON lagoon area had recently been filled in with soil and regraded. This disturbance of soils in an area scheduled for investigation is of primary concern to the Agency. The integrity of the investigation of this area has been compromised. EPA views this action as an improper and inappropriate action conducted under the RI/FS. Please provide the following information so that the Agency may evaluate this situation appropriately: 1. Who authorized this activity of digging and filling the lagoon area and why was this activity authorized? 2. What was the objective of filling this area? 3 What type of fill was used and where was it obtained? 4. Please submit an Addendum to the Work Plan which presents the current conditions of this area. This information should be submitted to the Agency no later than May 3, 1990. EMS is responsible for rectifying any and all problems that occur as a result of this digging and filling of the lagoon area. Please note that field operations such as the stablization of contaminated marshy areas on an NPL Site must be proposed to and approved by the Agency prior to being conducted. The February 1990 monthly report did not include notification of this work. • • Page 2 Please contact me if you have any questions concerning this letter. I can.be reached at 404/347-7791. Sincerely, Barbara H. Benoy Remedial Project Manager cc: Jane Penny, Dynarnac / Jack E. Williams, Dynarnac Pat DeRosa, NC superfund Branch 'l'o: From: Date: RE; • Lee Crosby Pat DeRosa ~ February 9, 1989 Koppers Co. , Inc Morrisville, NC • On February 9, 1989, I spoke by telephone with Shannon Craig, Beazer Materials and Services, Inc., (412) 227-2679, regarding letters to residents about the tentative dioxin results. Shannon said that she will write the letters and hand deliver them to residents on February 13, 1989. cc: Grover Nicholson Charlotte Varlashkin PD/db/pat.2/p.2 ,. ------• • UNII&D STATIS IN'VlllOIIKIPl'rAL PIDTIC'UOII AGUC't, 345 Covrtlalld Str .. t, ».B. ATI..Ul'fA, GA :!OIS08 l'ACSUO:Lt! 'rUHBKISSlOlf SUIT 1011 IV DAT!: _ ... $Ji ... ' ...... '_· 1-r_<?_q ___ HUKIP Ol" PAGBSI __ , ..... I ___ (lzac\luded. Cover lbHt) non1 ____ qI_g _____ 1.3~1----...:.:W__,_~I_ P.U NUKBll: -·---·----- 4 f I ' lf the tollowina •••••ae 1• receivad pc,orly, Pl•••• call ___ ...,. ____ _ in 011r office at rrs 257-,;:13/ or cowrd.al (404) 31,7~£@,/( SPECIAL tNSTRUCTIONS: __ ~------· U:ClON/11. OFFICE PA:J. NUMlll:R: 3M, J:KT 916) PANAFAX · . • TELEPliCl~ N'J~!:RS FTS 257-4486 (Al1t0) COMM, (404) 347-448& rrs 257-4702 COl'frl, (404) 347-4702 • • A copy of the trans,:1.ltu,l letu,r sh0\1.1.d be sent to tlie On-scene O:::ordj_na tor. EPJ\ res1::t·vcs th<2 r.i9ht to lxing nn action again!lt any resp:msilile p·srty p:.n.-suar:t to s,~,;tion J.WI CERCLA for rer.:overy of all response and ovc-rsiqht c:osl:s i:1cun:e.d by the' Unit,,(] SU:t<>s relatr.,,:l to this O:>nsem: 01."l-Jer. ~u1d not rc~iJ,11:,ursi;:.;1 b_y th(:! Resp:)1'1<]l?~1t, as well as any other pcs,sl ,,,r,1 futi ire costs .i.ncurr-<.>d by tJ-1e Urii.ted Stat.cs tran the Fund in connP.ction v,·,l t.!i ~~QSJ-1::inse ~1ctivities ctJndtictcd pur.f3uar:.t. to CERCIA/SARA at t.his sit.1-~. XII. 01ilER (1 .. /·.IMS NoU1i.n9 hE>rd.n is inte,"l,xl to relec1,;,, any claims, caus,;s of act4ion or dcn..:sn,fo .in law o,· <'qui ty by f.i'll 01· the Resp:mdent ag21_i_nst any person, finn, p,u-u·,ership, or rx,qxirat.i.on, not a siqnatory to relating in any "''~Y to the g,•neratio:-1, stora3c, u:ec<tment, h;;ndling tr,nwportatiion, rel 0,:ise or disr>::>sal of -~ny hazcJ.rdous sut>sta.nces, hazardous wastes, l'-'llut.,mt.s, or cont:imin~,nts found at, tal;en to, or tW;en fro-n the Si.t.e. rrnis Consnnt Orde:: Uoes not cor:;,titutE• any decision on pn:;1uU-1or.i.,.aLion u!' fun'ls cm:l•~r S,,ction lll(a) (2) of CERCLA. XIV. Jt;,i)~•f;--1 FICA'rIC:N O!·' 7HC: Ll!lI1£l) STA'l'F.S GOVERNMWI' ri~!X: Ri-::s~_)ndc1-,t. ;-1~_11·0es t.n i!·~Ue::c··ii.:y and :-~ave and holC:i the United St.;·t1J:.':~ L'.nviron;n-.::nt·...::1l P:..·•-">t.eci:j.0:1 A<_~~ncy, its agencies, dep,.'._"\:rtmer~to, .-;~~•::nt.:;, arn.l ernp 1 oy~~t)S, 'tv111nl E!SS frcxn any and all claims or cctu~ea of ;:Jr:L:..i on uri~_:;.i_ntJ fran or on ~v-_X,'-)U.r1t of ar.ts or. anissio:1s of the · R0sJ.;:·):xk:;nt, the.ix a~1t~nts or a~>siqns, in carrying out the o.ctivlties pursu,:ml. to this Order. ):;PA .i..c, nol a p:.u:ty in uny contract in'X)lving th,:,! }{(!:·:1x)l1d1:nt~ at'. Lhi.:! Sit.e. BY: Gl't:.!(~l~ C'. TL~·v.t!.L.t RegionaJ. t:.:.'t:U ni;:~t.rato.r.· l.lA'l'E: u.s. tnv.\cc~:unent<1l pr,)toction AqrnK:y Rf!c_::1iu:1 1 V 34S 0)1lrt. l.'..lrid !]t.reet, NE: Atlantc-i, Gt-.. 3V)~~65 o::NSEl\'T '!'11<., 1'<:sporicJcnt .i.denti.fie,d hc,J.o,.r hereby <..-onsents to the issuanci! of this O:>nslml Order and to .i.ts len~c;. FurLhenrore, the eignatoty of this Or1ler eer·b.fies that he or slle is fully authori.zed to ent~ int.o the, t<cnns anrl cor:di.ti.ons of' tJ1i.,J Cons,~nt Order and to legally "t,ina t.1,c Rcsponrlent to the COnsc,nl Ordr;r, · fOR KOPPEHS O:"J..'.Pll!1Y, INC. l!Y: DATE: 14:54 Pel,,y that r,"s,11 Ls h-on circ=tance~ wyon<'1 the c.:ont.rol of the Resr:ondent u1.:: .. t. c:nrmot. lr..: overcc1rte by due di 1 igence 0n the H(~sp-:_111rJ0nU; p,7.rt shall not be ci~cm.~ to be n violut.ion of this 0.>JJS>?llt. Qnle1:, SllOU).d !:PA r]etern,ine a delay is 01\lf;ed hy ci.rcllln:.,1-.:mces rx:yond t.he control of the Respcodcnt, the schedule a ffecten t,y the d,21.ay shall l,e extondecl tor a period equal to the <l".lay r.,,;u.Lr.ir1.:; ti:<.1n suc\1 <.:jxcumst:.anc,es. Fc1.l l urc of ttic Hrosp:m,lent to c.urply with the notice requirement.43 of t.lii.s; s,.,c:t.i.011 r,h.cll constitute a waiver of the Respcmdent 's right to invoke U-10 h<>nc~it.s of this Ssccticin with respect to that event. Xl. F.l:SEi'<VJl:cXOt: OF RlGlff'S NoLw.i t.hstJ.:1d.i.n13 -:;"f:~1~pJ..\;:U1cc 1,,ri.th the terTTIEI of this Co!"'!~t!;-lt Or<l{!r I the R,:--sp.mf1or1t :i.e noL r,.::].f~c:.se,j from liabiLLt.y, if any, for ~.ny actions lx,yon<.l n,c t8rn1', of tl1is 0:Jnsent On:1,;r taken by EPA respecting tile /.iil(•. El'!\ rP.SCl:ves tJ,e righL· to take any enforcement 1:1ction pursuant 1·.o CI::RCJ A/:;Al'A an,1/01: an; r..vai.labl e leqa.l <1uthority, including the r.i.ghl t.c, s"'''°'' injuncL.ive relief, nonei:ary penalties, and punitive dii,r.ig8s for any v.iolalion of J.aw or t.l-1.is Consent Orner. 'J'h,:s f(csp:,n,lcnt '''"i EPA cexpressly r8serve u.11. rights and defense$ that l.'!1,:•y m,y h:ivte, .i.n(·l ucl ii1,3 i:r;,' u r ic;ht l::otJ1 to disnppnwe of work r>',r Lonn,,d by tl1,., Hc>Gr-0:,dents ,:md to request that the Respondent$ p::r foi·rn tttr,l<.s in zid(l1 tion t() tho-,"'ie det..-~ i led j n this CoMent Order In L]·,c, ,:vent. r.hc1t th,, Resron:len+: dc,cl ine,1 to perform any additional t11d/or 11i,_: .... li,fje~1 t .. ~sl.:"3, EPA will have the ri9ht to undE'rtak'::l any sucl1 \•.~.>r\.. J n <id:-Jitioi-,; EPA r-.:.:s~r.,.,c:r.; t.he right to underta'ke. reroval ,·.1cLion~; ont1/or .r .. t~;a'='.".li;1.l <1l~ion.s, ot~her tli~u1 those req,:dn ... :..1 by this C,·)n~it..'.nt Ordi:.:r., CJt. ;in.'/ t.irrl'3', In e.itl"le.r event, EPA reserves the right t.t.> sce1'. r:-cirnbu!·1;,::::"i1C'~~t:. frcn the RP.SfXmdent. thereafter for such costs ir1CUtTerJ by t.hc· lJrd .1,.-ei<: St.dL•~.S. Rc•s:1x.>ri,.l,?llt. r,,.scc::ves c,11 i;j.ghts and deferu;es that it ·has or may liave t.:.n d!:,:.;i:_.rt cl<;iJns ;.1~,:\i.u~.)t perE;Onti or entities for m:ttt.ers arising out of ll ,,, Si le or i. ts 0F'"rc1 lion and ownership, including, bc1t not Jj 11ri tcd to, c.l.,i1ns for breach of conti:act, indemnity, contribution, n1list1,ic:o and clairn!-".i 'tlndP!:'.' f(:.""?JeraJ., stat~ arrl loca.1 laws. XlJ , REJ1t,fJUl';SEME1,n· OF O)Sl'S Fc.i l 1 u•,.;.i.nJ (,.'<"_.rnp /.(" t.i::wi of tJle re:m.Jvu.l n.ctions, the ~sp::lr:.dents shall, wi tlii.n u,·Lrty ( 30) calcmlc1r days of receipt of an acoounting, remit a chec,, for tlic, .:i:.,:llmt of ovors.i.9l1t costs m'.lde payable t.o t..>ie EPA Hil'/,rn-U:>\.H:; su~JEit".::tnce Sup:Jrful'Y1. Checks should s,PaCif.i.cally reference the i (3cnt i Ly of t.!·1,:~ r.d.t.c and be addre8se--i to: li, s. E:nvhornnentill Protect.ion Agency Super fui,:l Acoount i ng I-'. O. Box 10~142 Atlanta, GA 30384 A'l'I'N: Collection Officer for superfun<'l ··8- RCSJ.x)n(lt!ritr~ thr:1t pru1;;1.l tit2>.s have l.X:!en ussess~. PaymentR shall also lx, m,de by cc,n:t.i.fie,J or cashiers check, mo.de payilhle to "EPA H;:,zardous SL1bsta,1cc,s f,upcrfund". '!'he• ch<-<::k must. reference the n.ime of the Si Le il.nd SI 1'.i l l b<, sent. to: U.~_;. EIJA 1 RE.·;Jion IV /\'IT!:;: Sur-~r.ftl.ni"l Arx .. '-:,unting 11 • C,. l'-C>>: lOi-J14:~ Ad ,rnu,, (",J1 J<J:m,; A cxJJ,Y of thu lrcc,n.srnic.t.,l letter should be se:;t Slmult-0:ii,-Ously to the Et>/\ On··-Scent--! C..l.rrcd inator, J nt.can:,;t sh«J.1 bc3j_n to ilccrue on the unpilid l:>i'\lance ot a stipulated p.,n.·1lt.y at tJ10 end of ti-.,~ f.i.fteent.h duy upon wh:i.ch payment is due. F'urUu~nrore, not1ii.ti9 her~in shr1}J. prevent the simultane--<:>us accrual of sep.,n,t.e pc:vl.l.ties for se,x,rc1te viol.at.ions of th.is Consent Oi:c1er, n,e ,·,t i.pulated pcnalt.ies set fc":U1 in this Section do not preclude 1·:l'T1 -fn.n cJ.ecl" . .i.nq to r•irsue any otllet· rcme<lies or uunct ions, which may be ava:i J.c1))J c' to r-:!'A by r~·,1son of U1e Respondents' fo.ilnrc to con;.>1 y wi.th ,my ot tJ1>! requin,T,c"rtts of this Consent. On1er. Such 1~•-~mo,:liOf.:i i:tnd Ha.nc:tions fitc.~ly i.ncludt~ a st1it. for 1:3t.f.1t.uto1-y penalties up to the .:-ur..-)unL autb:>r·i~.ed by L.t\•l I Ct fe!JHrct.l ly-fw¥.led resp.Jnse action, .:md <·1 t;11 it f<Jl~ r~~J.!rbu1-~t.:~ner1L of c:)s~:s incur.red by the Un l tee St.at.es. HG.r;p::,nJer it.' s nct.i.v i.t i.t:.!s under this Co:;~(:ml Order shall be perforrfte(l wit.11·i n the time lj_11ii L-; r_;(~t forth in t.his C'onsent Onler, unless per forHonc:f~ i ~;; d,.~ l ~ye•~ by e\'i~n~.s ·.-.·hi.c:1 constitl~te a ~9E~~jcura. For purp::>~:;c:; of thts C.(1('..~1ent Ord<:.:r·, a f.orce maJeure Is defined as any ev,.,nt. ,,ri.si.n<J fro:~ Cil'.1s<:is bey,~nd Vie .roesona.ble control of Hcq:x:mdent wh.i.ci·1 could r!l>t: have, h?en prevented by the exerci sc of due dili<Jenc:2. lnci:easc,ci L\),its incurred by Rcsp::,ndent J.n coruluct.i.ng ·the 1:teJT<Wal acLi.on or clvmged econocn·ic circrnnstances of Respondents ahall not 1x~ conf-;L:i~rod ,:is conGtitllting a fo~~j!_L:_~~• 'J'l1" R•,s;x,ndem. r-sh:sl l 1,otify EP!, · i; os·:'. orally ,d.Uu.n tv.,mt.y-four (24) hours u.nd ."i.n 1./ff i ~.i:--19 no later than tlffe-r.=: t 3) busJness days fron the inc:,~pt.i.on of tl.n:/ e:vc:.:~·1t which P.e$pJndt~rit: contencls con.stit1ites u force majc•un, as definred ilb~,v"'. 1he wri:.ten nolice shall de,;,,ribe fully···-· U1e n,1t:11rc of tile ,Jelay, ",tiy the cJ,.il.ay i.s l>eyond the control of the Hc,;pond,:,nt., tlie: i\ctione ta};en and/or-that will be takc>n to mit.i.gat.e, prevent. and/or mini.mLze furU-1er del.c1y, the unticipatcci length of .th€ clel.-1y and t11e timetable by wl,icch t.he actions to mitigat...,, prevent ,md/o, m:Lniinizc r.hc delay ,,1i l.l he t'lken. Should the date of d.i.,;cnv,c,ry c1it.for fran tJw dcite of the .incept.ion of a force•majeure cvenl., ne,;p:>ndenU; s;hflll include .in the required wr:i.tten not.ice tfie r;,;,,;om; for the ti.Jne w,ri,mce. 1'hc, Respondent shall adopt all l r<·!<•H:;orv,hlc 1r10a~1..n-e~;, t.o a.voi(l or. min.imize a.r1y s11ch delay. • --7 . • VIII. DISPUTE RESOJJJTION If thr, R<~sr,onJ,,,11. objects to any EPI, notic,:, of disappruvnl or decision mJ.de 1x~rm1~nt lo tJ1is O"'Jnscnt Onler, the Respoli(1ent shall w,t-_i fy JcPA in wri.ti.ng of its objeclions withi.n fourteen (14) calendar cl;.sy,; of: r.eo:,ipt of tli<J dccisj_on. !-:PA and the Resr..onnent shall then h,w," · m, a,ld i tional. four.teen ( 14) calendar days fran tl1c receipt by 1-:1>11 of t!w n:)t.i fi.c,.-,tion of obj,ection to reach agreement. If "'Jre~m.-,nt t:,J1111ol l>e rei'.lchr:.-d on ,rny issue within this fourteen (14) c:, J.<;11,J;;r d;Iy p2ricd, E:P.', sh,,ll provide a writ.ten statement of ita decision t.o u·1e! Re::-:-:_rx.)f)(l.cnt. IX. !JFl.l\'{ _IN PERrvH,,_"1,CE/STIPIJ!ATCTl PENALTIES J f ,my ,:-vent occ,1r,-,. ,-:hie.::-, cc1nses delay j_n the ac.hievernent of the n:qu i.rcmc\nls of. tl1is Cn:1st:nt Or::1,::r, the Resp:)r.:~cnt shall have the bi.1nh2n of pro'-'; m; U·,<>t. thoe del;sy was Cil'.lSlhl by circ=tunces beyond t..h<2 l"C'i-"1f'iOr1.:11) l.(: (..\JllLnj L o[ t1·1e Hesp..JnJen~ which could not have ooen uvc,rV.l!11C by due di Lig;.,nce. 'I':-ice Respondent shall praiiptly notify 1-:1.'A'r; osc oi:c1lly ,11U1i.n no rrnre than twenty four (24) hours and dliil I, wi.t.l,in tJ1re,2 (3) ccilcnclor <'ldys of oral notification to EPA, r1t)t i.fy EPA. in 1,o,•rit.itirJ of tJ1e <'-Jitir.j_!.Xlted .length and cause of the d<.~lay, tl1c: mc;i"!.sun.Js t.u.k1Y1 an;J/or. to b(: t.ikLn t.n pr.·evc~nl OL mini1nizi?. tJ1•:-! delay, and the t.irnetable by vlt i ch tho r.:~--!sp:--in<.1E:nt 'i.nt.cnJ.s t0 j.11iple:.:1t.!nt these measu:res. If the rn1~t.il::; ct:1n agrQc t.h<.1t tt":e (ktay or untj.cipated de.lay has 'been or \,,:i .11. 1·x} Ci1u:=:;ed l)y <;ir,;ii.r::f:.~t::.1.ncr~s lll'-.;yond tl1u reasonable control of the F.c::.p::K1ClQ:1t, the t .. in-1,:> to:: p2rfo1.~.r;:mcc hereunder shaJ 1 be extended for a p~)·cic){:l t:!1.~u.:-1 l to tile ,:ll:-:J.::iy nisu l ting fi:-om t:,;\.lch cir~t.anc-eg. J f t.hc r:i.:.n•t..i;_·~r; sKJ r;rY:. •"'-~;ce.:.:, cs to whc-U·,i::r or not tho c..:..t"cumst.ances w"t.:rc l.,..:..!yon(J t.h•::: 1~1.·;:::·.,0:-1.: .. d:-l.e-O)nt.ro l 0: tJ-,c R~s_r:::ond.ent, the dispute i;:1:1].J ht.·: r1-:.,~;::)!\"fr,:l 1.:·, ;.-1cco)~d.:.u·1c0. ,..-iti': th1:.• provisions of the "Dispute r-:r.•sol.uL.i():-J 11 Secti.o:·: lf-.e,:..-U,r.:)n VIII} of this C.onsent Order. U:1 lcf;:-.-; L~:-:c.:w_;ed l~nc":!1:1r t.h1: pt"O\'isions of Section, x, the Reapoilelent sl1;.1lJ p~·iy into Ll1£> Hr1,!,'.i1.'dous Suh::;tanc•.: Superfund, administered by EPA, t.he st.1rrn; net fort.h belc,11 <1s stipulated penalties. l"or U,e 1st U1rnu9h Lh<e 7th day of fo.ilure to comply with the texms arid cun,l.i.tions or t.he C::irrnccnL Onlc\'., t.herc 1,-:i.ll be a $1,000 penalty p..cr:-v.iolc1t:ion J:":>r c!~y and S?.,(000 per day thereafter. St.i.p,.1L,tc<l p:,nal~i..,,,; t-.c,si11 to a;ccruc on Uw day t.hat a violation <x:cur,_; or c,n t,10 d,aiy foll.01vic,9 Rcsp,,ndents' failure to canply with any schedulet; c...-,r· (11:.:J;JJ.ines, or the tenns conditions or requ.i.remeo.t.a conlzli n,-,1 in t.his VH1b•:nt Onlet· an,1 shall continue to accrue until H0sp-:,n,knts' v.i.o1 ,rt: ion ends or until Respondents <.'Ollpl y with the · part.·ic:u1,~r.· sdicduJ.c, deadl.irw'., t€nn, condition or require.rnent. I 1',1yn>et1t. of >'ti.pul.fltrod pen2lt.i.-,s shall be due and o.<lng within fifteen ( l ':,} d::iys fr-cxn the ,lc,t,~ of 11 writtc:1 notice fran EPA notify.ing 8. • -·(, .. • Nothing hcr.ein shall constitutH or be construed as a satir;faction or reloase from lia,,ility for any conditions or cl,,ims ari.r,in•J as a result of past operations or ownership of t.hc ,,i Le b,' 1·.he Resp:x..-ients, \:.heir agents, contractors, 1(:.>SDeGS, 6UL'C8SSors or ctf-JGigns • 9. ReilponJent shall 1-ctke actions t11at are necessary to protect the public ricc1 l.t.h, ,.-el.fi'lre, and U1e e:wironrnent. The Respondents ,;hall rep.,:-·t to U,e EP.z.. On·-Scen,; ox,rdinator (OSC) prior to t.uking any s~1ch a1:-t i.1::in. 10. Nutw.i t-J1~;ta:1tli..nq c-:-1:npl.i..ance 'v.'ith thA terms of this Consent. Order, the R•.;si-0n:.lent moy be required to take further actions an necx~E;s.:.u~y t_o at:ia t.e any endar1gerl':1t-':!nt JX)SOO by cond1.tiona a.t the sit_e. l l, Jn the evtent thc1t the OSC detenn.ines that activities impl.crw,,ntcd are not in canpliance with this Consent Order, or any olJ1<''r ci.rcurll.'3ti'lnces o:-act..i.vH.i.es are creating an i.mninent nnd ,aubst.<mti.1'1 «nd,u19cment to t11e public health or welfare or u, envir01111,.cnt, lhe Rc-gion;:il l\.'.mti.nistrator of EPA, Region IV, TTBy onler th,s Rc:sp::,ndent to cease actions at the si le and tPA will carry out the activiti,;,s pursuant to this C.7nscnt Order. 12. Develop ar,,:; ,;ubn.i t f:or app>.:()l"al a work plan canplete with ,lesi.gn dn",i::g,:; for El',". app<'O'Jct: ¼-ithin thirty ( 30) days after the cffc2t .i..v1::i clat.e o.f tlti.s Cor~::.;..~nl: Or-de-r. l :J. P,.,g'ir, i.nirl.rn,:.,nt<iU.cn of th« ,_.c,:·kpL-s;1 "·.Lthin thirty ( 30) days of its opproval, Resp.:indi:~nt must no~·ify tho O.SC five (5) dayt prior to the in.~ tr.i.:lt.ioi-• of any on-site activity. 1'1. o·.:rnplete a1 l con,;tx11ction within ninety (90) days of initiation of construct:i.on. l:'>. 'l'hj_s 0-msent <.)r.der ire, ef~cct:Lvc U}X):1 EPA signFtture~, l 1otwithstmir.i i.r~~J un_y c'-.,n.ferences regLiested by the Resp::mderit. All t.ime.s for p,,r forn\dl1ce of response activities shall be c;.1J.culc..1tt.=:!-d f.l:\)111 tht1.t rla.t.n. VII. RE:OJis FRESf.R'.'ATlON 'J11c R1.isp::"Jnd13n L 09li2cr. to preservt..,, during the pcndency of this 0:Jnscn\. On:ler aTJ,J fer a rni.n.imu:n of. six ( 6) years after its t.ennirlht.ion, one, c,opy of all reo:Jrds and documents in the.i.r . p: . .>sscsn:i.on or in t.hf::' posses~•ion of the.ir divisions, etuployee~i, a<3ent.s, account..anu:,, cont.ructor-s, or atton1ey8 which relate to the work lX!r for=d pun:,lant·. to this consent Order, despi.te any document r..,t.ent ion pol.icy to the <..'Ontrdr'_;. After this six ( 6) year peri<Xl, t:11e Rr:-.s1x,rKlent. slv,11 nnkc avai.lable to EPA such records or copies of !'.lUCll rec,or.dB except, those which am c1tton1ey work-product or subject t.o the c1ttornf>y-cli.e11t privik,ge. • • ···'>·· 1, 'fn<..: rE-'h ... ~:,!'.'t: ctn(l t.:,:.re;:.1t of relHdtC' ':'lf hazan1ous substd.nCt!'O fro-n Ll1<..~ fncility n°ay pre5eE'..:. an 1.".nni.nent and sul:>stani.:..i.i:il ()ndr11 i~Jc•rnf~:r:~ to th•.-~ public hea lt.h cind/or wel.(are and/or the nnv.i.1:-c..Yu,-~.:·i"lt: /.. lll or\lt.~1· to prot8ct p11blic healt..'-1 and/or welfare and/or the e:1v:i.ro1nni:?1·:t., it is ne .. x~~~jrl.L)., thtit uction be taken to mitigate U11::" reJc.~H:;1~ into tlv= envirunrnen(.; c1.nd 3. 'J'h<' ,,cti.o:b rNJuirc,1 in this 0-.)nB<,nt Onler ,:i.1:-e cons,ist.ent witJ1 u·"'' N,,t.i.on.:,l cont.inqency Plan, 40 C.F.R. Part 300, ~~- VT • WORK TO BE Pi':Rf'ORMED ·rhr:-: p::-:rt i•:::i_; 11.:1·.rir;q r:t ... ~1c:J·10-:'. ?. r2s".)J.1..:~ :i.on of tlle issues involved iri tl1.i t;; proc·-~·c/fj 1i~, ~L .i.:;; t.:n0reforc ACHEE]) ona ORDEl{J•:D tli<it rzespond~nt.s sh·1.Ll \J:d(:rta}:c t':1c~ ro:~.io-,,.:inq u.cLiviti.(jS purslltJ.nt to CE.RCJA Sections HJ.·; ( ;·,) ,mrl 1:/2, -17 l '.. S. C. S<e.::U.ons 96[1'1 l Fi) and 9G:i~: 1. Provide ;.; JX·rm:L'1cnL drinking "'c1t.r,r supply (r.,y the ins-.:.allation of ;i v;c:iL"."~l' line C(..'fltplet..e \•tlt.';1 all tiG-i!l5 iron the water line to tl,.-! rc~,.i.d€,i1ce,s) to any ,md all n,,,idents a ffecte.'\.l or 1-..-)t:.<::nt .i .:-:1. ·! :l y .:, f fcx:LeJ l?/ gro:.infr.•:~-1.:.~:r contatnin,-"ltion frQj'i\ the f.~1ci1·i l.y. l\11y rx)rt.ior:. o.f: t~-:t:.• W~>r-1:. whi.ch rey,.lfre~~ perfoimmce 1.iy lo::-:.: l (n.1tl 1or.Lt-. .-Lt:~f:.i ~::h·i] .l be~ acccirnplizhed at. t.he expense of t.\p~· J·:t:'.'.:;J :c:":d•~ni .. ~-!. ·1~·v: w/ilt21.· 1.~Llir~ s~":::iJ 1 be:i ciosiqnt:~:1 in acco:n1anc~1 \..,ith all i:!i'"f)i.ic.~,,,blc-: f..: .... :hn-al., r,t..;-1..:.e, ~ind l.o::,'li. l.-cquirencnto, J\ll 11<:.•,::t:;:::'.S~tl·y r1r,;,!·-1n:.ivi1ls of ;,J.an~1 s:·1:.lll b(:: r:1Cql1ired by tJ1e P(~~;r...-:n-:lc~·1t. 3. l\c:.;p-:)1 KJ>::nt ~;1·1:;111. be n:.·s;::cinsj_ble f o:-obt,1J.11ing ~r1y easenerit~ or riqhls-of-\-::iy 1h-:cr•::;~~.'.:·n:y to al lo-, .. · instt.1llHti.on of t.he line. Any ..:1ss(x.~ia1·J!:·; fe,~:-~ ~~11<.i.ll be tho re:3r:.:mGibility ot tht'? Respondent. -'1. .r-.1.l nc;tions car.r)c-~d out. by the Res.pondont pu-ront.t.nt to this 0:,:·1,;cnt Onl,.,1: shal.1 b<, per.fornl0(J in accordanc.-e with all r1ppl.icahl.c fc,:,,·lc1~n.1, sl<Jtc, nn<l local laws. ':°l. H(•:~.p-)rY1r~nt r.J17il l -::1sr11..n:e ~"'H ... ~ce~1s to the site by ~PA, its <lL\thor.i.✓-~tjd r,~preS<~ntat.ivcG, conttF\ctot:'G und consul t.antf3 f<n- p111·rx.x,e~; of i1npJ.c...,;-.::r1t.ci+:.i.on of thi.s consent Or.df:.r. C. All r1iSf.<):1Ee h'o1~J:. _r)erfonr,?.cl pursuant to this Cbnoent. Order i.:fr,1.l l h"' uti,Jr,r 1-h,, c1in,ct.i.on ctnd supervision of a qualified eny.i.nGc1~ or·'" C:X)ll-~tJ'.'uc.Li.on m.3.na9e~. Res;:ondent Bhall notif.-y J:o:PA iii; to t.1'H_.! ic'JF:'nl i t.y of such e11~rLn1.:e:r:, <-'Ontractor:-s, or sulx.·ontr:.H.::tor:-s i:o oo used ).ti currting out the tc~ of tli.i.s <kdC!l" in ~<'lvancc of tl1eir work ~t the site. 7. R<',P.JX>lldf,n I_ ,,h;c1l1 pr-ovide a q1.wl i.ty control report to EPA "!hich cc1·tific,s t.h,1t all activities have been perfonred as approved l)y EI'A. \ 14:Sd • • ·-4- in June, l'J8~. !Is a i:ces,ilt, a:1 ,1c1clitional 1250 cubic yards of ~;oil ,mJ c'-x.,nta.minated 1Mteric1 ls were n•rovE.>d fran ilie lagoon <1rect i.n ,Tilly l 986. Post-clcil11'.lp sc1mples collected in this area J.iefcn:e h.,ckfi. lling incti.c:nte that 1-'CP is still present .in t11e so:i . .l.. W. J n C>clobe,: .i. 'JS/l, th·~ u. S. T,nv.i.ro:1mental Protection Agency, n1:::9.i.O!'> IV, r:.nvirorr:ientbl-Scc,;.icc!i Division aamp.i.i:--.J private w(,ll ,;, rr,::,:1ihiring "<ells, .:,n,J on-;iite soil and sed:i.ms>r1t. PC.'P was (leh~ct.E~d in a p.r:ivrite w,.~l.L us f1igh <1s 40 u3/l. IPE was d~l:.1,.1ct.o:J :in t..i·1.=~ same pri vat.e wel 1. at 48 Uj/l. PCP \•~S ulso de,tqcted .in ,in on-site rronitorinJ well i11 concenlrc1li.cn,; up to l '.i0 ug/J . U. ln /\1HJ11;;1~ l 9U2, Y.on:,crs bega.n supplying oottlc-d water to r,,,,id,c,nt s vi\10se w,~J.ls hc1d do;umentecl evidence of growidwater C..Y..>nl·.r1min._'--1 t.i.on. l'\t pres(:nt, t.her.c are six resid~Jces, incluc:ling the !;J1.iJoh llapLi.st ci111rch, bceing supplied bottled water by Koptx~rs. l2. p,,,nliJc:hl.oror-,hc'.1101 is ct l i.:oLed }i;,zarclous substance as clefin0d in S«Gtion l G.1. ( 13) of CllR2.IA <1:·,cJ a list.:e<l h,,:,.ardO'Jf' \·caste i.n 40 <.:l·'R Pcirt 261 .:n (auly 1987). It .i.s: al.60 ctn EPA pr.i.ority rnlJ utant. 2~, l.lstF.-;J in SE'Cti,:>;t Ji'.'7 o.f the Cle.an li-J;~"':~r .Z:ic.t. l.]. f1(:nlcichlo.ro1hc:nu.l hns OOc~:1 n~c·12si~ifl.ed by the EPM's Q1ncor Rit>J.-. l\~~~.,essr:).c.::-!JL \'crif:i.cat.io'.: EndE,qvor (C...1V\\l£) \-.lorkgrou1) fr~ a cl?1s~; 11D" tc..J Q cli1SS "B2" cti..r-::inc:x:-,e·.n. l, -n,,, sH.e ;,~, a fac:ilH:y ;.,·ithtn the muaning of. Section 101(9) of: 0:1~_,,,, 42 u.s.c. s,,ct.ion 960.L(CJ). "!., J"'\opp<.~n-, O~x11;_.:.:L'"1y, Jnc. is an ov.'ncr wit}1in th0 tn0:t.ning of Sect.ion l(Jl(20) oC o:;;,_,:!/•., •P. u.s.c. Sw:t.ion 9601 (20). ) • Kr.>!JJ:1C"".r.:::; (:Z.lr(--.:1:iy, Inc.:. is t}1e pa.f:t; 0pcrat.or and con·tro.1.led and nuna9ed t11e t:tc:tj_v i.ties ;i.t tl-11-1 f-:tc.i lily within Uie niC!a.ning of f;c,c Lion Hl l ( 20) of C"'::m:::rA, 42 u. S. C. section 9G01 ( 20) . 4. J.\.~ntac:!1.l.oro;·)h•:.!no.l is J listed hw.:-~.ard.oua waste in 40 C.F'.R. 261,33 (July 1987) . .5, J.ienl.i.tt.::h l.01~opheno1 i!'I ~ h1.1znJ .. 1.-1u~1s substance within the meaning of ,,,;ct.ion lOl(l4) of CERCiA, 42 U,S,C, Section 9601(14), 1 :,'.:._ _ _])l::)'.(cRl·1[!"''\TlONS DY REGIONAL A!filNJSTAATOR llaf;,xl on th" For.e9oi.ng Findings of Fc1ct and Q:%1clusions of Law, arid UH, ,,ntire i·cc.~>1:d of lhi,; procecd.ing, t11e Regional Atlministrator has ,ktt>nni.rn:.,l U111t: • -3-• no cllv .. ~r.:-,in:·1 syi~tcrn \,.:-1d no leac1vrte collect.ion system. In 19Tl, th1=' l,-t1Jcon:J \o.10re: clof_;,yJ. wc:1tc~r frcnt the la9t.l:)l1S Wt-ts f_;p1.·ayed ovc:t' ct ficJd <)n i:;ilc <ind !:tludqe was mixetl \,,.•ith soil and ~:prc,:1d over t.lh:: .U.1qcxx: flt'(' .. a. 5. IXx;11:ncntr.~] s::°:.rrpl..in~t act.i.vit'Lt~~ i10.ve been concluct .. e-:i since May 19'70, by Kop[t:.::r~., th~ St;;.to o:: ~~or.th C-volino, and US EPA. PCP hc.1~; b:·:~n clct.cct~xi in the soil. concentrations as hi1._1h as 230,000 11r,1/"<f ( Kopp2rs, :-l,u.cl, l 9>30), in growxh,c1ler rron.i.toring woll!f up lo r,. ~ ny/ J ( l<.opp,,r:; S,,;-:itEli11:-,.Jr 1980) , and in pri w,te drinking "'"b"' ,.,.._,it,; tcJ -;1,:, u;;/l (Koppers, N:>vernber .1987). lsoproptl e\..h,,r ( lPJ-;) lF,~; b<:m1 ckl·.e,cted in private residcriti,iJ. wells s.i 11cc: JA?cc•:nhe.:· 1986, f!n 1:l h;j!=', been consJst:ently present in eacl1 J_:1.F:r·i ,xl i c 1,,.1c l l san11:iJ.in:J action !.'ii.t)Ce that t.ime. (1. r. f.i t,~~ 1i·1~:,1:x::ct . .ic)11 rcp:n:l wt.1s _pi-ep,.u:i:.:d for the site by the NC ~-~_-,J.i.d wx1 lia1,::irdous lvcest.c, M,,n,,g,_,.~,:,t Rr.anch on Mi,y 27; 1987. ·rnc r1::'fJ1'J1-~1. d:"'}::Llrn(~r!t.t:~d the r:i•.1e1~.;J.gc.• dt:."'pth to g1·otl.T"1d\•r-:tt.:..:r in the •,1·j,:h1it.y ot ti'l•:~ slte at. lf~i-20 feel. Within a thnt~ mile radius uf ·t·.hc :;,j_ ti:;,_, 2~ l w;-, :.~r:·-lJr:'.,:\r.j :19 zones are hydro lo.Ji cal 1 y C'("JJ mcct:c·t.1 H111i .ti.u 1ct.inn a.s .:, !=", i:1Jlo c1gulfet". Grounclvli3.ler. is tile pr:iHr1ry ~;(:i:.1cco of tlrinJt.i.r.~~ \o.t;:_~tc1~ for 21!39 r<?!.d/l~nt.r:.1 \•:ithin a 1..hr•1f:~ rni.1c~ rndi.u!{ ot th<.::· sit•~. ·;. J..:ur1t)ff fn)11: tl1r! nor.L/1~..rJst co1:"1H:~r of th~ silt~ drainn erwtward to li11 .intcrrni.t.t·,.:,nt. cl:ec~l.. 1't1is cceek flo,.;s sot1thcaat c:1pp1cn:i.11tr:\t·.,:·!·1y 2-~~'.) mile~:. to C1'.·a~)tr~0 (.'-reek. Rw-ioff frat, thO :-:( )' 1t.h1•),:1:;t. o:)n 10 t· of tJ·1,: rd i:.f..! G.1:-d i.:1s to Kopr".11:.:rs P:.:>n.d which is 1E~c~.1 i"ur .l .. L n=.: p.1·ch.:.-i.·:t: ion. PCP hc1.s lx~en detected in wa.ter and f_;cJ i n1c'.1l t. fl"l),;-, t..!'1t: p.,:-i<.:-l. T.11t.:.r!r:::1"L ti-en t:. overfJO\..-, frc~n KOf'!~rs , I 'o: 1d cl, .. ;.; j n;; ~01:(tll ,:..ir,1.:,::.~o,:i:r .. '-iLel~r l, 000 feet t.o thL'. f-,C,€':(:nin Pond. 'f11i.G p:>r;d j . ..:; \i!;! . .-~(j for fj_shit1~·1 u.nil j1,-.rigat.ion of 9e1.rden crop~. h. :1 ri 197'/, t~w C-Y~l..l.'..):.r ~.ffl~1ent. v;a.st.c treatment l<.1go..;11s \o.·c:ffe cl0i-_;c,d. r .iq·.]i.d fri..xn L11c la(F>-)IIS was cptayed over· 2 f).elds on I t-.11r,) :;i t 12. 1l'i·1-2 fi.r.~;t J ~.:>,::~r.rt.:i.on w,-1.s l-x~hind the ste•~l shop and the :_;i·:o:>nd J (Y:h·,-. ion w..:is l>.2t.·.}(~(~r1 tl;e st.c-c~.l shop and tJ1.e rt~ ilrood tr.~<:ks. SJ.udq•~ .fn:.Jrn the: b::iltoTI of; tl1e lagoons w.::,.s rer!"IOved, 1:·d.xc11, t:11H1 ~_;p::·c•:1.d uvc-,r U--1e .1 a~..:JO.)n arett and ndjacer.it soil to tlry. 9. Tn ~~,,.::li 1.ci,:ic, I<opp:ers be3an to study PCP c.'0ntaminc1ti.on of ~:oi . .L, 9rourl,.i•.,:dt•.;r., h.nd p:md sc..Jiin•.~nt on s.i.te. As a 1:-csult, i1ppnJx i.1-n::tt0ly '.22(·1 cW)i.c yar(]r;; of crmtaminat.ed soil were z:eoc,vcd fn>n thG si.t<.~ in Apri.l ar1'i r--1,i;:iy of 1980. l'rld.ltio:1al 8ampling w-:,s cx·,IYJ<K,t.c,.i on site, bet..,~en June and September of 19Ell, n,:::.11 t.i 119 .i.n t.J"t;:, n'!Tn-ial of tv.O··J-,uridre,, and forty cubic yarcls of conl.i:l:ni!t',t.•.xl so:LL t.o a penni.t.tP.d J.an:lfill in November 1980. In ,l Llt1! •. ' .1 ~11_.:1, a m:'lre det.a i led f:ollc.Y...,'-•up soil invr:st.igat.ion was cu:i1:,leL,,t'I i 11 tlv, ,n:c,i o.f th,, forn,ei-eff.lucnt waste treatrnent L:t~Jn'.)nH <.111d 80:i.1 irri9at:i.on fj_cld~1 n8ur the steel shop. PCP cor1t· . .-rn1in;:-lLi.on w(·1~; $till pres1.-;nt. in both areas. C.ontamination w~"' cn·1fi n1ecl l)y Kopper" in onot.her round of: sampling =nduqted 1~:53 C'.onuc,JJt Onler and shall not chc!llenge the applicabil.i.ty of thi" ri:,11,;t,:1L 0n]c1r to Hesp::irni<ent. TI,e l-'int1i.ngs of Fact and Conclusions of I;:,v: an, cffe,,:tivc, only for the puq:o.,es of this Consent Order and are riot !ii ndiric1 in :ci,cy other proceedin9. Resrx,ndent reserves all right.a t.hcy nny ·riwe t.o object to or c'Ontest any allegations of violation of L.hi,; C't:m:;cnt On]d·. Nothing in the finclirigs of fact or conclusions or 1,,,w ex de,tc.,rmi.n,,U.ons rn..,dc hc,cin constitute an ac'lm.i.ssion of fact of l.L.tl')i J.it.y by Hcsj_:-•:>rJ.Jc:~1t; l10M...~ver, Resi::o!lt'.lent agree a not to cl i:.tlJ t•.rh)'2 tht.•cc fi.ri·Jir:ig~ or concJ.usionr. for pur.r,os:es of enfo,:cerrent of t.hiH ()·..)rtf;t:!ri1: Or··~1i::-r., 11,i.;; Consent Ordc,,: sl:a lJ ,,pply to '111<1 bE' lJi.ncllng L1pon tl,e folloo.nci rli-:U'.'t..irc!~i: .l. rn-10 lk~spond~?nt., .i.ts fH3erit.u, officers, directors, emr;loyees and suc:ccssors, assif:JtlS I and r1.ll per.sons, including, but. not l.i.1ni.t-<x1 to f.-irrn.s, c:orp)r,J.tions, contr,i:\ctors and con9uJ.tai,t.s, ,.H:t-.l rl!J tu1der or foJ.-lht! Resi:.on<Junt.: nnd 2. The Unit.()] St.ates Cnvirorunental Protection Agency (EPl\) and its acJ~!nts, employr::-es and OJnt.ractors acting under or for EPA. L H:~·sp:--,nck,~1t. :is t."/"1e c·,~n-~~2nt. 0\.VrK:ir of .J. ten (J0) ucre JA.'Jrtion. of .ltirH1 lr.:»:~CTt,::c~ i.r: U~•~: BOiltht:~lst c-;)n1er of t.lu: fifty-b,-,-o (52) acre s.1 li:!. R<-:!~_.;r:.01·u:l1.·:!:t G:) lrJ the reircd rd.n9 property to Unit St:.r·1 lL'.LtH.'(~is, lE,::. ·j n S82te1-r~'Jer .l. :-J86, for product.io! 1 of 9 l 1.1<:.'·-l,:i.;11.i 1v! t.J.:'• 1 -....~:.v:)..:i proJucts. 'l"hc"! r(::sr--ondcnt' s t.er.. ( 10) ;1cro ti:-ac:t i,a h,,re:ir:z,H.ur· referred to c1s "the facility". ·rt1t:' t.• i. ti::.• YiiJS u0cd a:c:; 2 sa~~r,J.1..l by the ca~.)' Lumber Co. until l'J'.">9. Unit Structures then plln::l1,1sccl the properly and beg,m pn.x'Juc: i.n\J g LVi'-1,,;ni.r ~,t.F,-c1 w0:Y:l prooucts. In l '>62, Koppers c·o,~xirry p,n:ci-.,.,,:;,,d the: site and co:1U.n,1ed the glue-J.ami.nating prxx;,,:,,~. Frun 196f.l to 197'.i, Kq,pe.::-s used the southeP1st poL·tion of ti 1f, ,;ite (u,,, f:::1c.i.J..i ty) for v,'0'.,"1 tre;,,tment wi. t:h J"-'nLacJ·,10,·uphe,,ol. (PCP). lrr 19HG, the EJj,te, with t!re exception of thf: tffr (l,1) ,,cr-e p:,n.i.on re1:<1inecl by Koppers, was sold back to lJr1it Sti:.-1.;,::t-.ut·•_:,s. 3. v.:.1st,,,wat(:1· oi,;,.os;e.:l of 11t tJ1e fac'ilit.y wa!el generC1t"d by tl1e "CJ::U/,~" v.n.xl ln,atment process. This treabnont consisted of, pn,,•,cure injc,ctin(J r,:p in a .l.i.quidfiw butane isopropyl ether ,;o l u Li cm into tJ,2 ,,:x:d. /\ft.er j1npregnation was caupletcd, the lnlt.iuH: ct-1rr.ic:r cvztfX)rated, ler.1vi.ng tJ1e PCP as a dry1 i c,ysb,lli.ne ,;,,J.t, Exc,,ss PCP salt w;is renrJVea from the w:xxl by nLC':un:i ng. 'J11c \o.',H:ih solution waf.:; treuted to recover PO? anr.1 diGch;:1.r9<..\cl on site. ' '1-l•/;,s;LC, .... Jt.e'.,: fr<.rr, the, PCP prcx:,,ss W-ds ,hscharged to the fire pond at t.h,,• 1'.-ad.J ity f:01; ,,ppi;oxi.rnately r, rronths and then t.o 2 · l:•10u.,ns on sit,,. 1110 Jagams we,o not lined and had no di.king, • UN.l'l'J:JJ SW,TES ENVIRJNM!fill\l, l'ROTFlCrION /\GENcY Rte IO:•; l V 11< Till·: Ml1'/'l'LR Uc'; ) ) hOPl11::P:~ CU··Wl..J.'-:'l ~; r.·11: ) r1:J1~r.i ~,v i.1 ·1 (~, J."J(:ct.h (_';._t ruJ. i.r 1c-..i ) ) ) ) -· ... --· ------·••',·--·------·-· -------) KOl'Pl<R',: C( Nl'lJv\', IIJC:, ) ) H1.;~::,~")::1nd1.:~nt ) ) l: • S . Ef> A JXX::Kf::1' NC> • Proc,;(:ding under Sections 104 and 122 o!: t.he Canprehensive Enviror1TTiental ){e,sp.-,nse, Crn,pcnsat.i on and Lial:u 1.i ty /\.ct of 1980, 42 u.s.c. Section f;l604 allcl :'!6~J., as amended hy the Superfund Am,,ndinents and Reauthori.;,,.ation l\ct of l 9Go, P .J,. 99-499, Octol">er l 7, l 986. i\U·ll NIS1'RATJ.'vT, ORDU-\ BY 0:)NSENT 'tlic [r., l lo.,,1:i rv:9 Td17;l_n:i ::)ltd t i.·...,e O.r.U•:.::r by C')nsent. (hcreinq,f ~er call 1:)d "Corn;cnt. (Jrrl0L·11 ) i~~ t~nt.i:).rer-:! int.o 'ny t,he United St.c-,tes J~v.i.ronmentul PI.'ot<.·ct: i <;11 /\gc,nc,' (1 i,srein0f t•:t" Cd U.e.i ",J,r,") wit.½ the c1Ut.ho1:i t.y v,.,s,.,-,,1 i.n the J>,:c:-;jd,_•nt of; the U:,i.te:J Slates by Sect.i.on,; 104(a) and .!?.?. of. l·J1,.:i 0);1f1t~c}i,:~n.s.lvt· E .. ri·,·Jr.on:n•~~n!.:ii.l Pt::sponsu, Can_p,2ns,~tion a.nil T;i;;:,.ili1·y /,ct_ of ·19n3 (l:c,::,0 in;;if1:<•.t· c,illod "Cl:'.RCVI") 42 U.5,C. ~:i-:c'.·.io11-=_: 9C;n4(~) li.i'id 9622, ~s nmi.111di:-Y1 by the Super.funll A:nend:oonto and T.:,,:,11rlu!l"i ;,,,Lion N:t. (:1,c,,·r.,j_:li';ft,_•r ccellro::i "S/\RA."), Pub. J,. No. 99--499, 'J'h:ir; 1::1!:"ti(H'ity \\\ts r.1~~1,.:::-f1t.1...:d to t.he A.r.Ud.n)sLt·n.tor c,f EPA by Executivu ()tdrar U' .. ,rn 1li1t1,.-.I .J:.w,.,,ll:y :!J, J91.i7, 52 J-b:.lcral Reg.i.oter 2923 (l 987) ,.ili'1 11,.'.:; l,i1;(":rl furLl'H..~!:" d0l<.YJi\b.:.;.:: \.() thr.l Rc-gionc1l A.c);ninist. rater of · H1.=1;:1i.o:·1 .lV, /·'.Pl-.. PiJCSUdnt l".() ,s(~C'tio:-i 1c1~ of CERCLA, '1/.. u.s.c. Secti.on 9(lVi I t!1f! ;31:~11:.~-~ nf i'·Jo1:Lh Cd.ro.1 i,1,:1 lit1.H J->';-t~n uot:i. f.icd of thj s Consent Cln.1,,t·. 'l'1K\ p:ir:_1,::!.; ~;t..ip:,11.d:-_.'.'. ":!1.:-it r:p;·~ ]1i..lS rn<J-:-1e. t.!112 rieccs~aJ~Y d.1...:-d:.e.rmi.nati.oos re,_.ji-tJ~dlnq {:ht-! :rel e:.:,:-:.:,.:.-cu1d thre,:.:i.L of 1:ele,\$E' of lMz.:.1.:rdous substance! ,-,,_; d<•finc.J ir: Gcc-:.ic:1 WJ(l,i) of Ct::EC[J\, 42 \J.S,C, Se<:U.on 9601(14) [,~·o:n th•~· f1_;l.Jov,dt1':! J.c•~~◄-1t.i:x::: KOJJix,r·s (.:On])'_any SJ te KOJ_)iJ1.:':l.-r; J<.o.·1( ·i Vi·J1T.i~ville, NC /.75GV Rt:t;p:,:Yl•.~11t. c.1c;1re:•i:~s fl 1,_=:1t. f.Pl\ has the~ right t(> en force this Consent ()r11l•c t11l(l0r (1~HC.LJ\ .in ci cottcl of e,'(..t11pet.ent jur.isdi<..'tion. In any -1cUnn hy th" uni.t.s,d su,t.es to enforce, this Cbnsent Order, Respoodarit f;J1,-,l1. rnt chtl..len,w the h.,sis for the Conr;e:1t Orrfor, shall not · cl1c1l.l ,.,n'.J"' the :)uri~•:ii.cU.o:, of EP,'I in iln action to enfocce this John C. Brooks Commissioner \) r J • \~ r J I) ,v.,-.. -.-"~ L,.,:., _ •• k-,=-..,._,____Department of Labor \),.... ~ ....... c.,0 _ State of North Carolina c~ C., • ,\,) 214 West Jones Street \? . ,\ 'l<-'t 1 • ✓ Raleigh 27603 January 20, 1989 rlr. Ronald H. Levine, M.D., M.P.H. State Health Director North Carolina Dept. of Human Resources Division of Health Services P.O.Box 2091 Raleigh, NC 27602-2091 • RE: Your letter dated Nov. 9, 1988 concerning health hazards to employees of Koppur Company Dear Dr. Levine: Thank you for bringing the above referenced matter to my attention. A review of our Occupational Safety and Health division records indicates we have never inspected the Koppur Company facilities in Morrisville, nor have we had any safety and health complaints against their operations. We appreciate your referral. Should you become aware that the facilities return to operation, please inform Dr. J. A. Oppold, Director of the division, or me so we may follow up with an inspection. /ssc • North Carolina Department of Human Resources Division of Health Services P.O. Box 2091 • Raleigh, North Carolina 27602-2091 James G. Martin, Governor David T. Flaherty, Secretary Ronald H. Levine, M.D., M.P.H. State Health Director MEMORANDUM TO: FROM: SUBJECT: (919) 733-3410 November 10, 1988 Bill Meyer, Chief Solid Waste Management Section C. Gregory Smith Medical Epidemiologist Environmental Epidemiology Branch Background and Chronology Summary Koppers' PCP Contamin.ation \ of Groundwater / Attached is a copy of the document related to CSI which I mentioned this week. I believe that it would be very helpful to have a similar summary prepared on· Koppers. We can prepare the "Public Helath Issues" section. Please have your staff prepare and forward a draft copy of the other sections to us as soon as possible sq·that -we can add our part, CGS:lp Attachment • • North Carolina Department of Human Resources Division of Health Services P.O. Box 2091 • Raleigh, North Carolina 27602-2091 James G. Martin, Governor David T. Flaherty, Secretary Ronald H. Levine, M.D., M.P.H. 22 September 1988 Mr-Richard Stonebreaker, Chief Superfund Branch EPA Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 Dear Mr. Stonebreaker: State Health Director The Division of Health Services has ITBde a recommendation to the Shiloh Baptist Church in response to a level of 31 ppb pentachlorophenol in the church drinking water ·well. Dr. Ted Taylor of the CHS Environmental Epidemiology Branch has recommended that the church discontinue use of the water for drinking and washing purposes. Koppers Company, Inc. was proposed for the National Priority List in June, 1988, ':ie. und:~rstand that during the ren,xlial ir_ve.stigatior/ .. feasibility study process, groundwater remediation will eventually be evaluated-However, we request that you evaluate the data currently available and consider an immediate removal action. We support the installation of a municipal water supply line to the Shiloh Baptist Church and to residents located between Koppers Company, Inc. and the church. Based on the complex geology of the triassic basin where the church is located, a water supply line is a reasonable perITBnent drinking water source alternative. Background inforITBtion has been provided to Barbara Benoy and to VJ.ke NorITBn. We appreciate your staff attending the =nrnunity meeting on Wednesday, September 21 and listening to community concerns_ I would appreciate hearing from you as soon as possible. I ITBY be reached at (919) 733-2178. ~iJJJ.~ William L. Meyer, iief Solid Waste Management section WL'-1,/acr/shiloh.doc The pioneer in laminated wood since I 9J4 • UNIT STRUCTURE,inc. P.O. Box A Morrisville, NC 27560 (919) 467-6151 FAX (919) 469-2536 September 21, 1988 Formerly l(OPPEnS En1tinccred Wood Sy.~tcms In September of 1986 Unit Structures, Inc •• purchased the business and certain assets of the Engineered Wood Systems Division of the Koppers Company, Inc. Included in the purchase was a portion of the Koppers property located in Morrisville, North Carolina; excluded from the purchase and retained by Koppers was a parcel of land which included a pond known to be contaminated. Because of the current news as to environmental problems in Morrisville, Unit Structures, Inc. wishes to · clarify certain points. 1. Unit Structures, Inc. 's property is neither the.· source of pentachlorophenol nor any other hazardous chemical or petroleum substance. 2. Koppers Company. Inc., not Unit Structures, ·owns the property at the northwest corner of Koppers · Road and Highway 54 in Morrisville. This property is the area being reported as the source of pentachlorophenol •. 3. Unit Structures, Inc •• is not a source of hazardous chemical pollutants and is in full compliance with all state and federal environmental rules, regulations, and laws. Plants at Morrisville, NC and Magnolia, AR TO: FROM: RE: • Lee Crosby Pat DeRosa~ Koppers Co., Inc. Morrisville, NC • September 19, 1988 I spoke by telephone today with Barbara Benoy, EPA RPM for Koppers' site (404) 347-7791, regarding her coming up this week and also about the Wednesday 7:30 pm meeting. She said that Mike Norman will attend the Wednesday night meeting and she is planning to arrive Thursday AM. She would also like to know who will be the State contact person for the following site: Koppers (I assume I will continue this one) Jadco-Hughes Potters Pits Sodyeco Please let me know about this so I can relay the information to her on Thursday. cc: Grover Nicholson PD/ds/ibm.4 . /-6-J7 u.Jak~ ~ Jkd.Att... ~ ~'ju o--/--cm-,r,;:u m~,e..,t,~ (,)..)i.-/f.-~ . /--=,--J"71 t!)/J -~ m-et'M1r-, r -lour 1) l<.~s f~11 3-1 9 -J' 7 me e,;t-UH If,..__, ~ ..s fo ✓cAe 411. e..L us-n CL.f. rre A--t' ~~~ 3-o-0 , tt 7 <D ll -,Jvt:i. l,t.l-LL( chtmrf!-'⇒ l,U1 21-L ~~ , ~¥r-e--~ 41-1~-&'1 ~ ~,n rn-e~ i1h /4,n T~ T°"1/or #'D r/? f ~ fi 0/ U r1Ji--I C-fll -h~ ht.rYt;t.L/~ 7c/.N Lu:> ~o~cl ~ JJ-/2f-tl) .. .. -~~o/-.. . ,-u-, ~,µ,~ l ~ ru(3/~ ~ ~ ~;;;T d' d' -b 15'-l;'.' (b-v.~w~ ?Yn<~) rY?~ tv(>,~it"vf/W~ ·h_,,Pv'.~ ~c/ . _./ 0 J /2-v_l . ?7-...L ';l i:Y?/ n? w ~ ~ oY' fl'7'????J 4, 1rv. h,{/. V??-J'c/ .PJ'-o ~-1 . (?'7?:VT;).J -(JC _...,..;J)~· ~. CJ;l ~/~ rP) ~J> woy' f'~ £~~')?Jc/ tJ-J'l-t'/ . . . s-~y ~WY? ~~J 77? l/ 0'7 4;,yi}J w "12-F rJ?-rrl ?:;(if-cf/ (5l tP.../'l-1/ t,?-i:.l-11 . . t_-,P /✓ / /// -t:. I I// . . . · ~no,_/iyr;,-zf?wl?/ -1~v & ~ ~TP?/1 ~Y.c?AI rJ' -['/-// d-~d . ,S"?,t-f-/ ~ HY? ITd.3 o/ ~I, Y?? w -A ~I d1w_p-;;, · -I J' 8 -t t> -.S >P~.~ of -~~ Lu0-JL parr~ kr>,cr->_1r,l.H'A1 tR-f6-fr • • "f-a. <i' -i8 F, ·r----o---1. re--<-o m rr-e.-~ et. ti · ,.,...,..__, frO rYl 7 e_d' I~ Io r J~ 'lo L -d-u U:,/\J"/ 1'--U-1<., firv-&,i'l'-l.'1 ,.._ <-0 o~· 1 D'-f&.e..r s -;1..--0 r ~ <.....L--LJt... c~ I\.LJ..,L,~v-: ,.__,) !--: '-{ -g~ J-€./\--& !,· ~ ~ M ~ ~·.sr-,., ~ h -eo.-l 1\., ~. ~.5- fr)e-e__;(:,·r--c, UJ-t.1L ~" 1 t/~-/lu -~ T~ t~ { o,-:I=, d..,{J' U-b24 r-e-<--0 M~·.:n--i. (J_ A-{J_ r, &-::()·-J,·~ 'cm . ~ r-e..-vi ~r\..k 5 . . J -I z, -p P Bo 't-/t ~ ~ ff N-t. &L& h cA.L,_,,1,_ .. l, by ~.5. . . ~.s fo ~·~d.s ,fi-r>m Jl~-n..., ~ m 0-,(_ l-e_d2. I-/ V -J' J ..LI) fo,m d m e-e..:t, 7 ~ U-u..trc.,k_, -fo ~ s ~ ~✓ r-h~r-.vi-tr-cQ 1nfn,-clY) ~s f<e v. ~ f::. CL I) I\.A5Ul1 C eo ~. I <f' rn '€ e_n ~ · °!-d -J> F-v.JD, /.,,.../ f c..o rn n-u.· -1-k..-e. rn e en~ N...l d . ~ d.-,1:S-~ J?QC'+ r <fUl'---e/l.. 1 .:h1.m1i,u'r-r -r-~ , ,.,, v-eFL/J "'1 - Ive; v;v-iv_1 on-n-1-,. L:rd}u..1""12.-P Pv.1 ~ >~ 88-'2.J-b • ~ Ol-v¥1~_1 ~-,.. L_rrl)w~ ~ -~v ~. s pryp_~ s ~ o-7 r-~'91 8 ,3 --l:. -!? • •