NCD003200383_19960710_Koppers Co. Inc._FBRCERCLA RD_Remedial Design 1991 - 1996-OCR

1/ v~~
RECE/V . · ED
MEMO JUL 15 1996
TO:
FROM:
Ms. Cindy Gurly
U.S. EPA -Region IV
Mr. Bruce Geno 1})·:;.,
Cummings/Riter Consultants, Inc.
SUPf,:,r1 ., .
Project No. 93-·145S£CTtON
July 10, I 996
RE: REMEDIAL ACTION REPORTING
KOPPERS COMPANY, INC. SUPERFUND SITE
MORRISVILLE, NORTH CAROLINA
In accordance with the Statement of Work, a Final Construction Inspection is to be held
upon completion of construction. In addition, the Unilateral Order requires that a
Precertification Inspection be held after Beazer East, Inc. (Beazer) determines that the site
remedial action has been fully performed. On June 6, 1996, Beazer conducted a
construction inspection for surface water, groundwater, and soil remediations. These
inspections were intended to be the Final Construction Inspection for soil and surface
water, and the Prefinal Inspection for groundwater remediation. The groundwater
treatment system w_as not operational because Beazer is in the process of installing
additional system monitoring capabilities beyond that required by the design. As a result
of the inspection for soil and surface water, the U.S. Environmental Protection Agency's
oversight contractor (Black and Veatch Waste Science, Inc., memorandum dated June 27,
1996) identified three tasks which needed to be addressed by Beazer:
• Vegetation should be established over the soil excavation areas;
c Th~ arcu leading to the former ~1edlin Pond should be graded to
promote positive drainage and to reduce the possibility of ponded
water; and
• The southern two-thirds of the Fire Pond should be graded to promote
positive drainage and increased surface stability.
The June 6, 1996 inspections for soil and surface water are therefore considered to. be
prefinal inspections,
mml/145 -1-
QJMMINGS
'f{ITER
• •
Beazer has addressed each of the above items. Consequently, the surface water and soil
portions of the work are ready for the Final Construction Inspection. The Final
Construction Inspection for groundwater has yet to be scheduled, but will follow the two-
week startup period for the groundwater treatment system. Beazer will schedule the Final
Construction Inspection for groundwater, surface water, and soil remediations for the
same time to conserve travel costs. It is anticipated that this inspection will take place in
mid-August. A letter will follow with the proposed inspection date.
In conjunction with the Final Construction Inspection, the site Precertification Inspection
could take place. Beazer will prepare and submit a site Final Ccnstn1ction Report wit.11.in
30 days of the Final Construction/Precertification Inspection, and a remedial action report
for soil, surface water, and groundwater remediations within 90 days of the Final
Construction/Precertification Inspection.
Operation and maintenance (O&M) plans for the soil and surface water remediations will
be submitted on or before August I, 1996. The O&M plan for groundwater remediation
will be completed after the two-week startup period for the groundwater treatment
system.
pc: Mr. Dave Lown -NCDEHNR
Mr. James Cook -Beazer
Mr. William Smith -Cummings/Riter
mml/145 -2-
(:pMMINGS
'R_ITER
•
Memorandum
Date: May 2, 1996
To:
From:
David Lown
Environmental Engineer
NC Superfund Section
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 200383
On April 30, 1996, 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 waler 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 I 5
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 iterris 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
1.1
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 I 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, I 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 corner 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 corner, (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 ( 10) 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
Watec will complete regrade and contractor will do the seeding, in probably 2-3 weeks.
2
• •
(I 0) Mr. Gunn said that Fire pond is too wet to do fine grade with heavy 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 concerns over
standing pockets of water on the fill surface at the Fire pond.
Other additional areas discussed include the stabilization of the Fire 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 McCrimmons 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 dam (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 storm pipe under
McCrimmons road. The basin willbe constructed in a flare-pattern that will hold a larger
volume of runoff and direct it to the headwall and through the pipe under McCrimmons
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 affect 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 are 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 downslope of
the last berm, (2) remove the Medlin pond perimeter fence and (3) remove and chip
remaining logs and limbs. Item (I) is currently under a separate contract from 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 information 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 sediments on
the east side and south end of the Medlin pond and (6) remove the plastic flex 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 exposed areas.
Watec proposed to add geotextile and rock to prevent further erosion. (6) Watec 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)
Watec will regrade and shape the overflow drainage ditch with a swale that slopes toward
3
• •
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.
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
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 coordinates.
Mr. Geno requested the priority in which the project would be completed by
Watec. Mr. Gunn indicated that Watec would be working on several of these projects
concurrently and that he expects to reseed/stabilize the Medlin pond dam and
construction of the headwall and retention basin to take priority. Mr. Gunn indicated that
some of the regrade projects at both ponds are weather dependent and that he 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 agreed 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 majority 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 corner 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 draining across the
perimeter road and runoff was pooling at the north end of the brick building. Mr. Gunn
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 standing 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 corner of the Fire pond. This area had been recently
graded to improve the drainage. However, there were numerous pools of standing water
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 observed 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 McCrimmons
road has been cleared from the dam. Some soil was apparently excavated from the dam
face and from the bottom of the ditch that runs parallel to McCrimmons road. A small
cut has been made into the face of the dam to allow runoff to pass through the dam. The
4
• •
dimensions of the cut are estimate to be IO feet wide at the top by 7 feet 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 runoff enters
an 18 inch concrete pipe that directs it underneath McCrimmons road. 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 rip-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 concrete 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.
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 small earthen
berms are constructed at 30-40 foot intervals in the drainage path over the surface 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 enough to cause
the soil behind each berm to become saturated. A silt fence has been placed along the
length of the Medlin pond dam to control erosion. The berms and dam are to ·be final
graded, stabilized and reseeded.
We walked back to the trailers and I departed the site at 13: 15 p.m.
5
; • •
PRELIMINARY PUNCI !LIST
Ct:acral Project
4/1 S/96
Provide fol!O\,ing contract submittals:
riprap gradation analysis for culven apron on Adams Products pioperty
chain-link fence shop ·dra\\ings
cenificates of materials for fence
As-built dwgs. including depth of fill with lift thickness checks and edge of geogrid/geote~1ile
seed cenification of mix, purity, germination. weed content
soil ammcndments cenificate of analysis
Fire Pond
• Regrade and seed disturbed Fire Pond perimeter road ditch near nonhwest come_r of Fire Pond .
Dispose of plastic tubs placed in tree-line to cast of Fire Pond.
Abandon monitoring well MW-9.
~ • Install underdrain. -
/4 • Remo,·e/dispose of culvert sections used to bridge di\'ersion ditches.
/ • Regrade diversion ditches to match c~isting grades, and seed/mulch.
C • Remo,·e/disposc of plastic sheeting and old tires used to secure sheeting.
...---i<-to-lfi 1'-<d •ow &b>,,.n-v..A'o.. ,.,._.,,k .
e, • Chip trees stockpiled bv others near nonhwest comer of Fire Pond. -~ ,, ,..,.., f-.
C. •
•
•
'-.
•
Remm·e limbs and root mancr from Fire Pond fill surface already seeded near nonhwest corner of
Fire Pond. -~1-..,-uJ,_ -n c.U. rd"'""~ .,.., 't{ t, n.-utl" ( ,.,_).
Remo\'e large rocks stockpiled near small pine tree in nonhwest Fire Pond area.
Grade area south of remaining concrete slab at nonh end of Fire Pond and adjacent to Proposed Soil
Excal'ation Arca 3 to drain. -~~ ). w..dt.s
Grade ruts created during disking/planting operations in Fire Pond area .
~'a ~ b-4.. ;i. -s ,,,.lu.
'-ft,v._ ,k,.,),'"'? 1 w=h~ µ
-;r«-', ~ ~ ~
Repair damaged fence east of Fire Pond. =chip trees felled on fence. -Q..,,._ s..,'.,( ~ ~
v-lU ~
Place topsoil over processed fill,at southeast corner 9fFire Pond before.seeding.~ ,.,...,..,,__J · .to-c-,_}-........_r-....,,.,.·~ 'J .,.,....., l"'4.4.( /, ~ ,-;1'/,( "'-' Vf'tvh;,,,,, /it1 ~ ~ ,.,. ~'11
Fine grade Fire Pond surface, espcciallv east side_. and southwest corner near Enwood office bulding ~ ~ •
where soil was mounded to cover sediments to provide positive drainage. Mounded area should drain
from both sides . .., ~..... ~i. ~ c.,il( ~.
Medlin Pond
Place topsoil O\'~r procesied fill at norp1 end of Medlin Pond. -J-~ _,......._ 1 ~••«, s-b-,-,...-.,.J.,. ~ /,UJ "'I>¼",, CAM,Si", h'/( h ·4,,_ ~
Seed Medlin Pond benns and disturbed area downslope of last berm. _ -.,,~ 1.,; ~ Qi~.
Remo\'c Medlin Pond perimeter fence.
(
•'•·
;
~
• "
r:;:,_.J '9-. ~ ,,,,rt{ Ix.~~,/
1 1n--d .__J 1'r< r W-'~
s-11' ,.,,..'ch ,.. (r,,k. 1-~· ~-~',I' ~d' Y"':.,t., (1)/,(_ ~ ¥ f., Rf( -J ~4/,;;,... ~ ~,e ~"o/lY ca, h~ ~-
""""f p,tc-,..U ~ ~-,,,..,6','.,.,J.-. ~ f .,i,.J-Hda/4~ -"o/-t-
{µJ,u,) . ------Fike-r-t~ ~ 't ~ 7 fh-,vc.L 6-....
tk ~ t,__~J _.,.,,, .• A-/,Jlk ,_.,{,..,u,/t,,,._,,,,.,e,J>I' i
v• 'k. (A,t a ( -"'iv>/ ,_.,.,r;
6-.o "Pf V,.,,,/c_( J"Y7 fl I o/ .,.f' P-/ u/2.
t. ,.a~.,., fs-6-tvt,·-ur ~..._ l)a...... ~. *,., w,.U eu,, ~--,,, ,;x ~™ . r-./4. /I( ?:;-, ...,, -,...,.,,, ~ -') .
-~/. ~ ~ ~-,-, JI.
3-.. Fi'tf~ ~-.
f.
...t~~ ,,_u ~ ;{A~~~ .. /~
k-, ~ /4a..,,1.
1/-ltf 4<:ca,,._.r-< .u.-cA;..... /u./t,,,..,, d--Cf-e-. da.... w# ,_.,,,c: -',, /./4ec./)_
,!'.°4~.:~~t':'· 4.f:,~o.a/lf-: .t,,,, f'4'-.,a,,~,,.~ a....l ~I~ ,..,,,...g
~ '.,.~6·"<,,;;:...;, .. ,iftt'&.1, ·~21-.~-·~;,-,,-_,,...., ~~ -~ ~
... ; ,~( z_;.;.;,•~~-.,-✓28"~. /.,. c.,,,1,-.,/ '1~:,_ -' ,.,J,.., r ~-
! .... ' .; ' • .".,1..\_,. • . : •., .......... J • ·:
. ' . ~ ' i • . " ,! w • • ' ... , ••••
X~a/·~~_?-
,,
,·
•
~~0'
rEL.34'1.5'
~I .
349.0' "'---"" ~ r---------.. 340.0' ----·
34 7 .0' --
0' 20'
,
'.
I =135' 1 IJIHEI-ISIUI-IS i;1 !U\11·1 ()Ill' Al'l'IHJXl1'1!YIE -------··--·----------------------
(NlJUS I 10 rn A( JI JAi. rir::ul COtlll!TIOHSl
----El __ 3., ;---EL.34'1.0'
/-Hlf' Dr OEflH -/ ---·-------··--------------------·---
J / --·-. ·---I t7 IJJ
34 ------. -.. v --
co .. ' L-,------" 3.-10 ,.._ -----··------· -------·-·---·--· ·-------l=--\
-----------------
40'
--
.. -.. . . ·-·-. ·----.. --------------· ·-----------.... ---· -·------------------------·· 3 Lj _) _
I. ---EL.347.5
I
G0' Br1'
/vllllllll~ lll:111'1
SECTIO!\J B-B
SC/\1.L• I" I' 11" VI l<IIC/\1
l'•-IW'·W llllill/lll/lAI
fl()! !OH
Cl OP ()I"'
I
100'
or OE! H
fl EMEi)! AL r I I. I. I
I I I
120' 140'
'
~1:::-r~-. ~-~~• -~,)·· -~--. ..,.1<";;./""'·{<;.1: .. ..!,'":, .i~ ::2}~·::~i~'
~-. : ,· .. ;. . . ·:. ' '; :·
.;;fiJtt=
--.. ,.-:.,
• J ,,, .,, .. J I'\ ,,... • s;J .. r ~ ' .k, ,
-. ,, , L. -~ -
,I ,
I J ·-, .,,_ ~-.
, I ., ✓ ✓.-l-1 -. J 1..-~ , .. P1. -. I
I
I .. ,_ J_.~ ,.
,I ' '--
I
A • .. , ,.. -· -_gl, ' , ,_ r, lcT4.
2-I .. : }' . / '
d.·11: f?,; 7
'I ~ ~ ;..._.
I
,&tC< ~ '-· -. ,.11 I -~ :I: ,_ ·-.,, , 'J_ . , I " 1[1.., I , {,,,.,, .. .,:.. , .. ,
, /, _I LI. r. ~..1.1, .
~ l, . V· ~ I{, .. , ' ..' .
1 .. ~ .,, 1 ~ ' . I , J ""-, .I .,_
~ ' I ~ ,/ 'L.. .I, ., , • s
I'< --~ I v ' I ,
r7L I'., , , ·-t.J 1>7 r u--'· t,; k..'
fi,.,, 0v,..1J .t., .-,,b I L _, !,.. I :e.c--,-ft.!, H" -.
I-• ]J c; :t. -I: -/ J £. , w ... --h, ~-, ,
all -f,f •. I,,.! I
,
I\ or, -" C. • . '" '
~-~!Jel~~ b(...; ,, . ~ ,
-
c.Jo t, _,_, , 1 , I _ I~ I ..,_ /" '-
~ I, tt ,. I I '_h ,.1 l,W; ·-· : A -p . I
tD I -~~---------------~ -------------/ --~ J--+-+-+---L~ ~ ,. I -~----------------------. --

-
~--~-
}
--------------------------~-
. I r~ ~
_P:,_ -f. ----t. -------
-k 31 I ,.._
' "' ..
k-------1-"--J;;>~'!'--k-+-1--f---• l-----l----l-----1-----"il-----ltC--J:
---'-&~-1.. -:l<--l"l----k---"'11.--1 ~, -_~t::~-1s;=--_ +---l------4------+--_:___i-~;~--!~_--t'li-----1_
f I
!
.. -. . ;,:, . ,.,.
--··.
2-or. e,c/. .
I .. ' • ' I , • I I V", i.,....... /......J.... -L-.,, ~ ',I,.... ,,... r.. J ,,._,
' ' .-.1. ~ I • Ill.,,
I
I' I .,· i ,
' ., I . I , ., . " .n .... 11'1.
f----+---ti--'--+--1 ~ff.-~• J.,J ,Le,, • •~o.J
.,.1,,-[ I IJ 1,J,< 1 J i...4.'1 1,,,J,
t.,j_ G'kf .,..,; rt.JJ \';' __ cu [I...,, .AS/ f SY ~UH'.
,1... . C-v ,....._ , : --!I t..-t $H c,...._, o le ~
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
MAY O 9 1996
4WD-NSRB
MAY 101996
SUPERFUND StGTION
David Lown
North Carolina Department of Environment
Health & Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
RE: Koppers Co., Inc.,' (Morrisville Plant) NPL Site, Morrisville, NC
Dear Mr.Lown:
This letter notifies you that Cindy Gurley has been assigned as the Remedial Project
Manager for the Koppers Co., Site during my absence on maternity leave. All correspondence
and further communications should be directed to her. No address or telephone changes will be
required. Please contact me or Cindy if you have any questions concerning this notification.
Craig Higgason will continue as the Regional attorney for this Site. ·
Sincerely,
(!;;,:t:1~
Regional Project Manager
North Superfund Remedial Branch
cc: Curt Fehn, NCS
Craig Higgason, ORC
Printed on Recycled Paper
•
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3i26
In Reply Refer To:
FWS/R4/AES/RANC
April 25, 1996
Ms. Beverly T. Hudson
North Superfund Remedial Branch
Waste Management Division
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Hudson:
The U.S. Fish and Wildlife Service (Service) offers the following
guidance regarding recent inquiries on habitat mitigation for the
Former Koppers Company, Incorporated Superfund Site in
Morrisville, Wake County, North Carolina. These comments respond
to your telephone calls and the fax you sent us on April 3, 1996.
Service comments and are intended to assist your investigations,
assessments, and planning pursuant to Section 104(a) of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (42 U.S.C. 9601 et seq.). Service
comments are provided on a technical assistance basis only and do
not represent any position that the U.S. Department of the
Interior (Department) may adopt concerning possible injury to
natural resources under the Department's trusteeship.
As we discussed via telephone, the Service's role in habitat
mitigation planning for the Former Koppers Company site is one of
technical assistance to the U.S. Environmental Protection Agency
(U.S. EPA) and contractors for the responsible party. The
December 1994 Remedial Design Habitat Mitigation Plan, 100%
Design Submittal (Mitigation Plan), prepared by Chester
Environmental, was submitted to us for review by U.S. EPA on
Janua·ry 6, 1995 (via the Department). The Mitigation Plan we
received for review included proposed restoration of wetlands on
the former Medlin Pond site in addition to the creation of
wetlands and open water habitat at the Seagondollar property.
Mitigation at the Seagondollar property was to consist of 1.6
acres of mixed herbaceous, scrub-shrub, and forested wetland and
0.6 acres of open water habitat while the Medlin Pond area will
contain about 1 acre of forested wetlands. Thus, the 1 acre
restoration proposed at the former Medlin Pond site comprises
approximately 38 percent of the total proposed wetland acreage to
be replaced.
, . . ..,,. • •
While the Service worked with the U.S. EPA and site contractors
to review and refine aspects of the proposed mitigation, the
Mitigation Plan was not designed by the Service. The Service
maintains that there are various mechanisms for the responsible
party to satisfy habitat mitigation requirements. The Mitigation
Plan is one approach which we have deemed acceptable (via our
February 2, 1995 response to your request for review of the
Mitigation Plan), but it is not a requirement of the Service that
this particular plan be implemented. If the U.S. EPA and/ or
the responsible party wish to modify the existing Mitigation
Plan, the Service stands ready to provide assistance in
evaluating any new proposals. We are not able to dismiss the
proposed mitigation at the Medlin Pond site without recommending
that the U.S. EPA and responsible party pursue alternative
mechanisms to compensate for this portion of the overall
Mitigation Plan which would not be implemented.
In a separate issue related to the Former Koppers Company site,
the Service remains concerned over the protectiveness of the
clean-up levels for polychlorinated dibenzo-p-dioxins (PCDDs),
and polychlorinated dibenzofurans (PCDFs). Upon receiving
Beazer's March 8, 1995 response to our February 2, 1995 comments
on the site, we recommended you seek a review of the disagreement
over clean-up levels from the U.S. EPA Ecological Technical
Assistance Group (ETAG). The Service recommended this avenue to
you because we believed Beazer had taken our comments out of
context and that an independent evaluation of the issue would be
beneficial in your decision making process relative to protection
of natural resources. We would be interested to discuss the
results of any ETAG review related to the PCDD/PCDF ecological
risk evaluation.
Thank you for coordinating with the Service; if you have any
questions, please contact me at [phone] (extension 21)
Sincerely,
To?Yl:tlu~r
Ecologist
FWS/R4:TAugspurger:ta:04-25-96:919-856-4520 ext.21:wp51\kopp.mit
cc: Lee -DOI/OEPC
O'Neal -AES/TS-EC
Lown -NCDSWM
Shannon Craig -Beazer
Medlin -Morrisville, NC
Wellman -EPA/ETAG
y •.' • •
BEAZER EAST. !NC .. +36 SEVENTH -\VENL'E. PITTSBURGn. P.-\ 15219
March I, 1996
Ms. Beverly Hudson
Remedial Project Manager
US. EPA-Region IV
North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: Material Characterization/Removal & Disposal
Remedial Action
. Pond De~atering Project . . ..
'KopperSSite-Morrisvill~, North Carolina ·
Dear Ms. __ Hudson:_ .
MAR O 7 1996
This letter provides notification of material characterization and the transportation/disposal
activities associated with approximately 165 cu. yds. of material generated during the fire pond
and medlin pond dewatering efforts. The various types and quantities of material requiring
containerization for transport and disposal are delineated as follows:
Material Est. Volume
Carbon Granuls 120 cu. yds.
Filtration Cloth Strainers 15 cu. yds.
PVC Pipe 30 cu. yds.
Container Size
20 yd. roll-offbox
20 yd. roll-off box
20 yd roll-off box
Est. Quantity
8 roll-offboxes
1 roll-offbox
2 roll-off boxes
Beazer has elected to protectively manage all of the above material as listed hazardous waste
(F032). However, by managing this material as such, Beazer in no way admits that the wood
preserving waste listings published at 55FR5040_ and stayed at 55FR27332 are applicable to the
point of ge!ler;i.bon (a non-operating wood preserving plant) or to the materials in question.
... • •
Page 2
March 1, 1996
Beazer has submitted the appropriate characterization documents to Laidlaw Environmental
Services of South Carolina, Inc. for disposal purposes. The material has subsequently been
approved for disposal at Laidlaw's RCRNCERCLA approved landfill located in Pinewood,
South Carolina. Transportation/shipment of all material will be accomplished with licensed
hazardous waste haulers.
Please call me at [phone] or James Cook at [phone] if you have any questions or
require additional clarification.
V ~ truly yours,
·1rc~
~-
Robert A. Fisher
Manager -Operations & Maintenance
RAF/Ilk
enclosures
cc: S. Craig -Beazer
T. Faye -Beazer
W. Smith -Cummings-Riter
D. Lown -NC Superfund
R. Lasater -NC Air Quality
J. Gunn - W ATEC
State of North Carolina
MICHAEL F. EASLEY
ATTOHNEY GENEHAL
Dcpartrnunt of Justice
F'. 0. l{OX (DD
H1\l.EIGl-l
--MEMORANDUM--
TO:
FROM:
RE:
DATE:
Dave Lown, Environmental Engineer
Remediation Branch, Superfund Section
Rob Gelblum, Asst. Atty. GeneralRl?
Environmental Division, A.G.'s Office
Koppers NPL Site
Morrisville, Wake County
December 22, 1994
•
Attached hereto is a copy of the NPDES permit that has been
prepared for Koppers in relation to the subject site. The DEM
Water Quality just faxed it to me, as promised.
Attachment
:\n Equcd Opportuni1y / 1\ffinn<-llivc 1\ctio11 Ernployer
Division of Environmental Management
Water Quality Section •
· P.O. Box ~535
Raleigh. N.C. 27626-0535
FAX:{919) 733-9919
P.01/25
... I F_AA_1_o_=_g_o_b __ 6_e_6_l_u_r'f' ______ ---1I FAX ~UMBER: 7 3, '3 -'1'.19 :7
FROM: je_~li\.d\-e. Po w2..ll
PHONE: [phone] , c.1et ,S'S t
I r-..io. OF PAGES INCLUDING THIS SHEET: IJ_S
An Equcl Opportuntty Affi1motive Action Employer
DEC-22-1994 _10:38 FROM 411 t..ATER GUl.lTY SECTICN TO • P.02/25
Permit No. NC0084366
STATE OF NOR1H CAROLINA DEPARTMENT OF ENVIRONMENT, HEAL1H, AND NA11JRAL RESOURCES
DNISION OF ENVIRONMENT AL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLIJJTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended,
Beazer East, Incorporated
is hereby authorized to discharge wastewater and stormwater from a facility located at
Koppers Company
Koppers Road
Morrisville, NC
Wake County
to receiving waters designated as an unnamed tributary to Crabtree Creek in the Neuse River Basill in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts I, ll, III, and fV hereof.
This permit shall become effective February 2, 1995.
This permit and the authorization to discharge shall expire at midnight on May 31, 1998.
Signed this day December 19, 1994.
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By the Authority of the Environmental Management Commission
Page I
I:EC-22-1994 HJ:38 FROM • WATER GII..H..JTY SECTJCN TO •
is hereby authorized to:
SUPPLEMENT TO PERMIT COVER SHEET
Beazer East, Incorporated
Koppers Company Superfund Site
97339909 P.03/25
Permit No. NC0084366
1. Continue to operate groundwater and surface water remediation system consisting of
equalization/storage, flow metering, bag filtration, and liquid phase carbon adsorption located
at Koppers Road northwest of Morrisville, NC, in Wake County
2. Discharge wastewater from said treatment works at the location specified on the attached
maps into an unnamed tributary to Crabtree Creek which is classified Class B NSW waters in
the Neuse River Basin.
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS-FINAL Permit No. NC0007749
During the period beginoing on the effective date of the pennit and lasting until expiration, the Pennittee is authorized to discharge from outfall(s)
serial number 003 (Medlin Pond dewatering treatment system discharge point). Such discharges shall be limited and monitored by the pennittee as
specified below:
Effluent Characteristics ~D~i~sch-a~r..,g ... e _ __,..l,wim=it~a..,tj .. own_s
Lbs / day Unit~
Pentachlorophenol
Phenol
Dioxin
Mon. Avg. Daily Max. Mon. Avg.
*Sample Locations: E -Effluent, I -fnfluent, U -Upstream, D -Downstream
(specify)
Dailb Max.
20. ug/l
Monitoring Requirements
Measurment Sample •Sample
Frequency Ill!'. Location
2/month Grab E
2/month Grab E
Quarterly Grab E
** Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, December; See Part ill, Condition E.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Design and construction of the waste treatement facility will emphasize the use of plastic pipes and fittings where practically possible.
cl
•
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -FINAL Permit No. NC0007749
During the period beginning on the effective date of the permit and lasting until expiration, the Pennittee is authorized to discharge from outfall(s)
serial number 002 (Fire Pond dewatering treatment system discharge point). Such discharges shall be limited and monitored by the pennittee as
specified below:
Effl ueot Characteristics
Pentachlorophenol
Phenol
Dioxin
Discharge
Lbs I day Moo. Avg. Dally Max.
Limitations
Units
Mon. Avg.
*Sample Locations: E -Effluent, I -Influent, U -Upstream, D -Downstream
{specify)
Dally Max.
20.0 ug/1
Monitoring BC11uirements
Measurment Sample •sample
Frequency ~ Location
2/month Grab E
2/month Grab E
Quarterly Grab E
** Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, December; See Part IU, Condition E.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Design and construction of the waste treatement facility will emphasize lhe use of plastic pipes and fittings where practically possible.
~
cl
•
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -ANAL Permit No. NC0007749
During the period beginning on the effective date of the pennit and lasting until expiration, the Pennittee is authorized to discharge from outfall(s)
serial numberOOl (groundwater remediation treatment system discharge point). Such discharges shall be limited and monitored by the pennittee as
specified below:
Effluent Characteristics
Flow
Pentachlorophenol
Phenol
Dioxin
Chronic Toxicity
Discharge Limitations
Lbs/ day Units
Mon. Avg. Daily Max. Mon. Avg.
"Sample Locations: E -Effiuent, I -[nfluent, U -Upstream, D -Downstream
M!mitoring Requirements
<specify) Measurment Sample •Sample
Daily Max. Frequency ~ Location
2/month Instantaneous E
20.0 ug/1 2/month Grab E
2/month Grab E
Quarterly Grab E
** ** "* E
""" Chronic Toxicity {Ceriodaphnia) P/F at 90%; March, June, September, December; See Part lll, Condition E.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Design and construction of the waste trealcment facility will emphasize the use of plastic pipes and fillings where practically possible.
•
"l)
DEC-22-1994 10:40 FRCl1 • !,,ATER Gl.H...ITY SECTICN TO • 9"7339909 P.08/25
PART!
Section B Schedule of Compliance
I. The pennittee shall comply with Final Effluent Limitations specified for discharges in accordance with the following schedule:
Permittee shall comply with Final Effluent Limitations by the effective date of the pemrit unless specified below.
2. Pennittee shall at all times provide the operation and maintenance necessary to operate the existing facilities at optimum efficiency.
3. No later than 14 calendar days following a dare identified in the above schedule of compliance, the pennitt.ee shall submit either a report of progress or, in the case of specific actions being required by identified dates, a written notice of compliance or noncompliance. In the latter case, the notice shall include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next schedule requirements.
DEC-22-1934 10:41 FRCl'l • ~TER GI..H..ITY SECTICN TO • 9'?339909 P.09/25
Part II
Page 1 of 14
PART II
STANDARD CONDffiONS FOR NPDES PER.\{!TS
SECTION A DEFINITIONS
I. Permit Issuin,~ Authority
The Director of the Division of Environmental Management.
2. DEM or Division
Means the Division of Environmental Management. Department of Environment, Health and
Natural Resources.
3. ~
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33
USC 1251, et. seq.
5. Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges
sampled and/or measured during a calendar month on which daily discharges are sampled
and measured, divided by the number of daily di.-,charges sampled and/or mea~ured during
such month. It is therefore, an arithmetic mean found by adding the weights of the
pollutant found each day of the month and then dividing this sum by the number of days
the tests were reported. The limitation is identified as "Monthly Average" in Part I of the
permit
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday • Saturday) on which daily discharges
are sampled and measured, divided by the number of daily discharges sampled and/or
measured during such week. It is, therefore, an arithmetic mean found by adding the
weights of pollutants found each day of the week and then dividing this sum by the
number of days the tests were reported. This limitation is identified as "Weekly Average"
in Part I of the permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant discharged during
a calendar day. If only one sample is taken during any calendar day the weight of pollutant
calculated from it is the "maximum daily discharge.• This limitation is identified as "Daily
Maximum," in Part I of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found
each day of the year and then dividing this sum by the number of days the tests were
reported. This linritation is defined as "'Annual Average" in Part I of the permit
DEC-22-1994 10:41 FRCl1 • l>.ATER QLRJTY 5ECTJa,i TO • 91339909 P.10/25
Part II
Page 2 of 14
6. Concentration Measurement
a. The "average monthly concentration," other than for fecal coliform bacteria, is the swn of
the concentrations of all daily discharges sampled and/or measured during a calendar month
on which daily discharges are sampled and measured, divided by the number of daily
discharges sampled and/or measured during such month (arithmetic mean of the daily
concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average monthly count for
fecal colifonn bacteria is the geometric mean of the counts for samples collected during a
calendar month. This limitation is identified as "Monthly Average" under 'Other Limits" in
Part I of the permit.
b. The "average weekly concentration," other than for fecal coliform bactetia, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar week
(Sunday/Saturday) on which daily discharges are sampled and measured divided by the
number of daily discharges sampled and/or measured during such week (arithmetic mean of
the daily concentration values). The daily concentration value is equal to the concentration
of a composite sample or in the case of grab samples is the arithmetic mean (weighted by
flow value) of all the samples collected during that calendar day. The average weekly count
for fecal coliform bacteria is the ~eometric mean of the counrs for samples collected during
a calendar week. This limitation IS identified as "Weekly Average" under "Other Limits" in
Part I of the permit
c. The "maximum daily concentration" is the concentration of a pollutant discharge during a
calendar day. If only one sample is taken during any calendar day the concentration of
pollutant calculated from it is the "Maximum Daily Concentration". It is identified as
"Daily Maximum" under "Other Limits" in Part I of the permit.
d. The "average annual concentration," other than for fecal coliform bacteria. is the swn of the
concentrations of all daily discharges sampled and/or measured during a calendar year on
which daily discharges are sampled and measured divided by the number of daily
discharges sampled and/or measured during such year (arithmetic mean of the daily
concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average yearly count for
fecal colifonn bacteria is the geometric mean of the counts for samples collected during a
calendar year. This limitation is identified as "Annual Average" under "Other Limits" in
Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable amount
of dissolved oxygen required to be available in the effluent prior to discharge averaged
over a calendar day. If only one dissolved oxygen sample is taken over a calendar day, the
sample is considered to be the "daily average concentration" for the discharge. It is
identified as "daily average" in the text of Part I.
f. The "quarterly average concentration" is the average of all samples taken over a calendar
quarter. It is identified as "Quanerly Average Limitation" in the text of Part I of the permit
g. A calendar quarter is defined as one of the following distinct periods: January through
March, April through June, July through September, and October through December.
DEC-22-1994 10:42 FROM .M WATER QLRLITY SECTICN TO • 97339909 P.11/25
Part II
Page 3 of 14
7. Other Measurements
a. Flow, (MGD): The flow limit expressed in thi~ permit is the 24 hours average flow,
averaged monthly. It is determined as the arithmetic mean of the total daily flows recorded
during the calendar month.
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling,
when both the sample and flow will be representative of the total discharge.
c. A "continuous flow measurement" is a measure of discharge flow from the facility which
occurs continually without interruption throughout the operating hours of the facility. Aow
shall be monitored continually except for the infrequent times when there may be no flow
or for infrequent maintenance activities on the flow device.
8. Types of Samples
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of
discharge and combined proportional to the rate of flow measured at the time of
individual sample collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the
sampling point Flow measurement between sample intervals shall be determined by
use of a flow recorder and totalizer, and the present gallon interval between sample
collection fixed at no greater than 1/24 of the expected total daily flow at the treatment
system, or
(3) a single, continuous sample collected over a 24 hour period proportional to the rate of
flow. ·
· In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having a detention time
of greater than 24 hours. In such cases, eftluent grab samples may be collected at time
intervals evenly spaced over the 24 hour period which are equal in number of hours to the
detention time of the system in number of days. However, in no case may the time interval
between effluent grab samples be greater than six (6) hours nor the number of samples less
than four (4) during a 24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9. Calculation of Means
a Arithmetic Mean: The arithmetic mean of any set of values is the summation of the
individual values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of
the individual values where N is equal to the number of individual values. The geometric
mean is equivalent to the anti tog of the arithmetic mean of the logarithms of the individual
values. For purposes of calculating the geometric mean, values of zero (0) shall be
considered to be: one (I).
DEC-22-1934 10:42 FR01 w lJ'ITER GU=l.JTY SECTJCN TO • 9'?333909 P.12/25
Part lI
Page 4 of 14
c. Weighted by Flow Value: Weighted by flow value means the summation of each
concentration times its respective flow divided by the summation of the respective flows.
10. Calendar Day
A calendar day is defined as the period from midnight of one day until midnight of the next
day. However, for purposes of this permit, any consecutive 24-hour period that reasonably
represents the calendar day may be used for sampling.
11. Hazardous Substance
A hazardous substance means any substance designated under 40 CFR Part 116 pursuant to
Section 311 of the Clean Water Act
12. Toxic Pol!utrui1
A toxic pollutant is any pollutant listed as to,cic under Section 307(a)(l) of the Clean Water Act
SECTION B. GENERAL CONDITTQNS
I. Duty to Com pl Y
The permittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enfol\'ement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit renewal
application.
a. The permittee shall comply with effluent standards or prohibitions established under
section 307 (a) of the Clean Water Act for toidc pollutants and with standards for sewage
sludge use or disposal established under section 405(d) of the Clean Water Act within the
time provided in the regulations that establish these standards or prohibitions or standard_~
for sewage sludge use or disposal, even if the permit has not yet been modified to
incorporate the requirement.
b. The Clc:an Water Act provides that any person who violates a eermitcondition is subject to
a civil penalty not to exceed $25,000 per day for each VJolation. Any person who
negligently violates any permit condition is subject to criminal penalties of $2,500 to
$25,000 per day of violation, or imprisonment for not more than 1 year, or both. Any
person who knowingly violates permit conditions is subject to criminal penalties of $5,000
to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. Also,
any person who violates a permit condition may be assessed an administrative penalty not
to exceed $10,000 per violation with the maximum amount not to exceed $125,000. [Ref:
Section 309 of the Federal Act 33 U.S.C.1319 and 40 CFR 122.41 (a)] ·
c. Under state law, a civil penalty of not more than ten thousand dollars ($10,000) per
violation may be assessed against any person who violates or fails to act in accordance with
the tenns, conditions, or requirements of a permit. [Ref: North Carolina General Statutes
§ 143-215.6AJ
d. Any person may be assessed an administrative penalty by the Administrator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or
limitation implementing any of such sections in a permit issued under section 402 of the
Act Administrative penalties for Class I violations are not to exceed $10,000 per violation.
with the maximum amount of any Class I penalty assessed not to exceed $25,000.
r:EC-22-1994 10= 43 FRa1 ttr !,.ATER Gl..A...ITY SECT!Di TO • 9'?339909 P.13/25
Part II
Page 5 of 14
Penalties for Class II violations are not to exceed $10,000 per day for eat:h day during
which the violation continues, with the maximum amount of any Class Il penalty not to
exceed $125,000.
2. Duty to Miti~ate
The pennittee shall take all reasonable steps to minimize or prevent any discharge or sludge use
or disposal in violation of this permit which has a reasonable likelihood of adversely affecting
hwnan health or the environment.
3. Civil and Criminal Liability
Except as provided in pennit conditions on "Bypassing" (Part II, C-4) and "Power Failures"
(Part II, C-7), nothing in this permit shall be construed to relieve the pennittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-
215.6 or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the pennittee is
responsible for consequential damages, such as fish kills, even though the responsibility for
effective compliance may be temporarily suspended.
4. Oil and Hazau1nTJS Substance Liability
Nothing in this permit shall be consttued to r,reclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthennore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
5. Property Riehts
The issuance of this pennit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authoriz.e any injury to private property or any
invasion of personal rights, nor any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Constmction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
7. Severabjjjty
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this pennit, shall not be affected
thereby.
8. Duty to Provide Infonnation
The pennittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to detennine whether cause exists
for modifying, revoking and reissuing, or tenninating this permit or to determine compliance
with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit
DEC-22-1994 10: 43 FRIJ'1 tlf W'ITER Gl.R..JTY SECTJ(),I TO • 97339909 P.14/25
Part II
Page 6 of 14
9. Duty to ReilJlpJy
lf the perrnittee wishes to continue an activity regulated by this permit after the expiration date
of this permit, the permittee must apply for and obtain a new permit.
10. Expiration of Pennit
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any penuittee that has not requested renewal at least
180 days prior to expiration, or any pcrmittee that does not have a permit after the expiration
and has not requested renewal at least 180 days prior to expiration, will subject the permittee to
enforcement procedures as provided in NCOS 143-215.6 and 33 USC 1251 et. seq.
1 l. Sii:natory Reqµjrements
All applications, reports, or infonnation submitted to the Permit Issuing Authority shall be
signed and certified.
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section,
a responsible corporate officer means: (a) a president, secretary, treasurer or vice
president of the corporation in charge of a principal business function, or any other
person who pe1fonns similar policy or decision making functions for the corporation,
or (b) the manager of one or more manufacturing production or operating facilities
employing more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter [980 dollars), if authority to sign documents
has been assigned or delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respecovel y; or
(3) For a municipality, State, Federal, or other pllblic agency: by either a principal
executive officer or ranking elected official.
b. All reports required by the permit and other infonnation requested by the Permit Issuing
Authority shall be signed by a person described above or by a duly authorized
representative of that person, A pen;on is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above; .
(2) The authorization specified either an individual or a position having responsibility for
the overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority.
DEC-22-19g4 10:44 FR01 • ~TER GU'IL.ITY SECTICN TO • 9'1339909 P.15/25
Part II
Page 7 of 14
c. Certification. Any person signing a document under paragraphs a. or b. of this section
shall make the following certification:
"I certify, under penalty of law, that this docwnent and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
pel'Sonnel properly gather and evaluate the infonnation submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowled~e and
belief, true, accurate, and complete. I am aware that there are significant penallles for
submitting false information, including the possibility of fines and imprisonment for
knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a
request by the permittee for a permit modification, revocation and reissuance, or tennination,
or a notification of planned changes or anticipated noncompliance does not stay any permit
condition.
13. Peonit Modification, Revocation and Rejs,,uance or IeOPioatipn
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed
by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts
122 and 123; Title 15A of the Nonh Carolina Administrative Code, Subchapter 2H .0100; and
North Carolina General Statute 143-215.1 et al.
14. Previous Pennits
All previous National Pollutant Discharge Elinlination System Permits issued to this facility,
whether for operation or discharge, arc hereby revoked by issuance of this permit. [The
exclusive authority to operate this facility arises under this permit The authority to operate the
facility under previously issued permits bearing this number is no longer effective. J The
conditions, requirements, terms, and provisions of this permit authorizing discharge under the
National Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C. OPERATION AND MAINTENANCE OF PPIJ,lmQN CONTROLS
1. Cenifiesi OJlerator
Pul'Suant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities.
Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the wastewater treatment facilities by the Certification Commission.
The permittee must also employ a certified back-up operator of the appropriate type and any
grade to comply with the conditions of Title 15A, Chapter SA .0202. The ORC of the facility
must visit each Class I facility at least weekly and each Class II, ill, and IV facility at least
daily, excluding weekends and holidays, and must properly manage and document daily
operation and maintenance of the facility and must comply with all other conditions of Title
lSA, Chapter 8A .0202. Once the facility is classified, the permittee shall submit a letter to the
Certification Commission which designates the operator in responsible charge within thirty
days after the wastewater treatment facilities are 50% complete.
OCC-22-1994 10:45 FROM • WATER GI..R_!TY SECT!CN TO • 9/339903 P.16/25
Part II
Page 8 of 14
2. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the pennittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also
includes adequate laboratory controls 3.l)d appropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary facilities or similar systems which are
installed by a pennittee only when the operation is necessary to achieve compliance with the
conditions of the permit.
3. Need 10 Halt or Reduce not a Defense
It shall not be a defense for a pennittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
condition of this pennit.
4. BY1Jassin& of Treatment Facj]jties
a. Definitions
(1) "Bypass" means the known diversion of waste streams from any portion of a treatment
facility including the collection system. which is not a designed or established or
operating mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to
the treatment facilities which causes them to become inoperable, or substantial and
permanent loss of natural resources which can reasonably be expected to occur in the
absence of a bypass. Severe property damage·does not mean economic loss caused by
delays in production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to
be exceeded, but only if it also is for essential maintenance to assure efficient operation.
These bypasses are not subject to the provisions of Paragraphs c. and d. of this section.
c. Notice
(I) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypa.o;s.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as
required in Part II, E. 6. of this pennit. (24 hour notice).
d. Prohibition of Bypass
(!) Bypass is prohibited and the Permit Issuing Authority may take enforcement action
against a permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes or maintenance during normal
DEC-22-1994 10: 45 FROM • l,JC\TER GI..R..ITY SECTICN TO • 97339909 P.17/25
Part II
Page 9 of 14
periods of equipment downtime. This condition is not satisfied if adequate backup
equipment should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance; and
(C) The pennittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph cl. (l) of this section.
5. Upsets
a. Definition.
"Upset " means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the pennittee. An upset does not include noncompliance
to the extent caused by operational error, improperly designed treatment facilities,
inadequate treatment facilities, lack of preventive maintenance, or careless or improper
operation.
b. Effect of an upset.
An upset constirutes an affirmative defense to an action brought for noncompliance with
such technology based permit effluent limitations if the requirements of paragraph c. of this
condition are met. No detennination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset.
A pennittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed, contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the pellilittee can identify the cause(s) of the upset;
(2) The pennittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part Il, E. 6. (b) (B) of this
permit ·
(4) The permittee complied with any remedial measures required under Part Il, B. 2. of this
pellilit
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence of an upset
has the burden of proof.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be utili:c:ed/disposed of in accordance with NCGS 143-215.1 and in
a manner such as to prevent any pollutant from such materials from entering waters of the State
or navigable waters of the United States. The pennittee shall comply with all existing federal
DEC-22-1994 10:45 FROM • W'lTER GII...AL!TY SECTION TO • 97339909 P.18/25
Partll
Page 10 of 14
regulations governing the disposal of sewage sludge. Upon promulgation of 40 CFR Part 503,
any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified. or revoked and reissued, to incorporate applicable requirements at 40
CFR Part 503. The permittee shall comply with applicable 40 CFR Part 503 Standards for the
Use and Disposal of Sewage Sludge (when promulgated) within the time provided in the
regulation, even if the permit is not modified to incorporate the requirement The permittee
shall notify the Permit Issuing Authority of any significant change in its sludge use or disposal
practices.
7. Power Failures
The permittee is responsible for maintaining adequate safeguards as required by DEM
Regulation, Title ISA, North Carolina Administrative Code, Subchapter 2H, .0124 Reliability,
to prevent the discharge uf untreated or inadequately treated wastes during electrical power
failures either by means of alternate power sources, standby generators or retention of
inadequately treated effluent
SECTION P MONITORING AND RECORDS
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents. All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Pennit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month
and reported on a monthly Discharge Monitoring Report (DMR) Form (DEM No. MR I, 1.1, 2,
3) or alternative forms approved by the Director, DEM, postmarked no later than the 30th day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the
case of a new facility, on the last day of the month following the commencement of discharge.
Duplicate signed copies of these, and all other reports required herein, shall be submitted to the
following address:
3. EJow Measurements
Division of Environmental Management
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of
tbe volume of monitored discharges. The devices 5hall be installed, calibrated and maintained
to ensure that the accuracy of the measurements are consistent with the accepted capability of
that type of device. Devices selected shall be capable of measuring flows with a maximum
deviation of less than + 10% from the true discharge rates throughout the range of expected
DEC-22-1994 10: 46 FR01 • i,,RTER GI..R..ITY SECT!ll'1 TO • 97339909 P.19/25
Part II
Page 11 ofl4
di,;charge volumes. Once-through condenser cooling water flow which is monitored by pump
logs, or pump hour meters as specified in Part I of this permit and based on the manufacturer's
pump curves shall not be subject to this requirement
4. Test Procedures
Test procedures for the analysis of pollutants shall confonn to the EMC regulations published
pursuant to NCGS 143-215.63 et seq, the Water and Air Quality Reporting Acts, and to
regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal Water
Pollution Control Act, as Amended, and Regulation 40 CPR 136; or in the case of sludge use or
disposal, approved under 40 CPR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and
all data generated must be reported down to the minimum detection or lower reporting level of
the procedure. If no approved methods are determined capable of achieving minimum
detection and reporting levels below permit dischar_lfe requirements, then the most sensitive
(method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
pennit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both. If a conviction of a
person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not
more than 4 years, or both.
6. Recorrls Retention
Except for records of monitoring information required by this permit related to the permittee • s
sewage sludge use and disposal activities. which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permittee shall retain records of all
monitoring information, including all calibration and maintenance records and all original strip
chart recordings for continuous monitoring instrumentation, copies of all repons required by
this permit, for a period of at least 3 years from the date of the sample, measurement, report
or application. This period may be extended by request of the Director at any time.
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the
perrnittee shall record the following information:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
DEC-22-1994 10:47 FRO'l • WATER Gl..l'LITY SECTICJ-1 TO 97339909 P.20/25
Part II
Page 12 of 14
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon the presentation of credentials and
other documents as may be required by law, to;
a. Enter upon the pennittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this pennit; and
d. Sample or monitor at rea.~onable times, for the purposes of a.~suring pennit compliance or
as otherwise authorized by the Clean Water Act, any substances or parameters at any
location.
SECTION E. REPORTING REOJJIREMENTS
I. Change io Discharge
All discharges authorized herein shall be consistent wi_th the terms and conditions of this
perrnit. The discharge of any pollutant identified in this permit more frequently than or at a
level in excess of that authorized shall constitute a violation of the perrnit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b ); or
b. The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the pennit, nor to notification requirements under 40 CFR Part 122.42
(a) (1).
c. The alteration or addition results in a significant change in the permittee's sludge use or
disposal practices, and such alternation, addition or change may justify the application of
permit conditions that are different from or absent in the existing peI101t, including
notification of additional use or disposal sites not reported during the permit application
process or not reported pursuant to an approved land application plan.
3. Anticipated Noncom p1iance
The permittee shall give advance notice to the Director of any planned changes in the permitted
facility or activity which may result in noncompliance with permit requirements.
DEC-22-1994 10:47 FRCl1 tlf1 l.J=\TER Gl.R..!TY SECT!°' TO • 9' ?339':0::I P.21/25
Part II
Page 13 of 14
4. Transfers
lbis pennit is not transferable to any person except after notice to the Director. The Director
may require modification or revocation and reissuance of the permittee and incorporate such
other requirements as may be necessary under the Clean Water Act.
5 . Monitortni: Reports
Monitoring resultS shall be reported at the intervals specified elsewhere in this permit
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.
D. 2 of this permit) or forms provided by the Director for reporting resultS of monitoring of
sludge use or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using
test procedures specified in Part II, D. 4. of this permit or in the case of sludge use or
disposal, approved under 40 CFR 503, or as specified in this pennit, the results of this
monitoring shall be included in the calculation and reporting of the data submitted in the
DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in rhe permit.
6. Iwentx-fonr Hour Renorting
a. The permlttee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
pertnittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including
exact dates and times, and if the noncompliance has no been corrected, the anticipated time
it is expected to continue: and steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours
under this paragraph:
(1) AIJ.y unanticipated bypass which exceeds any effluent limitation in the permit
(2) Any upset which exceeds any effluent limitation in the permit
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case-by-case basis for reports under
paragraph b. above of this condition if the oral report has been received within 24 hours.
7 . Oilier Noncompliance
The permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6.
of this permit at the time monitoring reporrs are submitted. The reports shall contain the
information listed in Part II. E. 6. of this permit.
LEC-22-1994 10:49 FRCM • t.l=ITER GLIAL.ITY SECTION TO • 97339909 P.22/25
Part II
Page 14 of 14
8 . Other Infonnation
Where the permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect infonnation in a pennit application or in any report to the
Director, it shall promptly submit such facts or info11Dation.
9. Noncompliance Notification
The permittee shall report by telephone to either the central office or the appropriate regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of the
following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnonnal in quantity or characteristic, such as the
dumping of the content~ of a sludge digester; the known passage of a slug of hazardous
substance through the facility; or any other unusual circumstances.
b. Any pmcess unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures of
pumps, aerators, compressors. etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receivmg waters without treatment of all or any portion of the influent to such
station or facility.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within 5 days following first knowledge of the occurrence.
10. AvaifabiHlY of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2)'or Section 308 of
the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be
available for public inspection at the offices of the Division of Environmental Management As
required by the Act, effluent data shall not be considered confidential. Knowingly malting any
false statement on any such report may result in the imposition of criminal penalties as provided
for in NCGS 143-215.l(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per
violation, or by imprisonment for not more than two years per violation, or by both.
DEC-22-1994 10:49 FRCl1 • WATER GI..IPLITY SECTICN TO
A. Pmunu;tion
PART ID
onmR REQUIREMENTS
• 97339909 P.23/25
No cons1r11cli.on of wastewater =aunent facilities or additions ro add to the plant's UU!mcnt
capacity or to change the ~ of process utilized at the treatment phult shall be begun until
Final Plans and Specificauons liavc been submitted ro the Division of Environmental
Management and written approval and Authorization IO C'.onstnlct 1w been issued.
B. Qmundwam MODitadnr
'Ibc permincc shall, upon written notice from the Director of the Di vision of Environmental
Mana~ement, conduct groundwater monitoring as may be required to determine the
compliance of this NPDES permitted facility with the eurrent groundwater Jtandards.
c. CbMri;s in Pisehar&es of Toxic; Subuanscs
The perminee shall notify the Permit Issuing Authority as soon as it knows or has reason ro
believe:
a.. That any activity has occurred or will OCClll' which would result in lhc discharge, on a
routine: or frequent basis, of any toxic pollutant whieh is not limited in lhc permit, If that
discharge will exceed the hlghest of the followin& "notification levels":
0) One hundred micrograms per liter 000 ug/1);
(2)Two hundred micrograms per liter (200 ug/1) for acrolein ana acrylonitrile; five
hundred micrograms per liter (500 ug/1) for 2.4-dinitrophenol and for 2-methyl-4.6-
dinia-ophenol; and one milligram per liter O mg/I) for antimony;
(3) Five (5) times the maximum conccnll'ation value reported for that pollutant in thi::
. pennit application. ·
b. That any aetivity has occurred or will occur which would result in any discharge, on a
non.routine or inf~uent basis, of a toidt pollutant whlch is not limited in the pcnnit, if
1hat discharge will exceed the highest of the following "notification levels";
(1) Five hundred microgams per liter (500 ui/1);
(2) One milligram per liter O mgll} for antimony;
(3) Ten 00) times the maximum concentration value reported for that pollutan; in the
pcnnit application.
D. Requir;ment IQ Continually Evaluate Alternatives IQ Wastewar;r Discbarn,
The J)CTT!llttce shall continually evaluate all wasti::watcr disposal alternatives and pursue the
most cnvironmenlAllr sound alternative of the reasonably cost effective alternatives. If the
facility is in substanual non-compliance with the terms and conditions of the NPDES permit
or governing rules, regulations or laws, the penninee shall submit a report in such fonn and
detail as required by the Division i::valuating these alternatives and a plan of action within
sixty (60) days of notification by the Division.
DEC-22-1994 10:49 FRCl1 • WATER QURLJTY SECTJCN TO • 97339909 P.24/25
Partlli Permit No. NC0084366
E. Toxicity Reopener Condition
This permit shall be modified, or revoked and reissued to incorporate toxicity limitations and
monitoring requirements in the event toxicity testing or other studies conducted on the effluent or
receiving stream indicate that detrimental effects may qe expected in the receiving stream as a result
of this discharge. '.
DEC-22-1994 10:49 FROM • WATER Gil..l'L!TY SECTION TO • 97339909
PARTN
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
P.25/25
A. The permiuee must pay the annual administering and compliance monitoring fee within
30 days after being billed by the Division. Failure to pay the fee in a timely manner in
accordance with lSA NCAC 2H .010S(b)(4) may cause this Division to initiate action
to revoke the pennit
TOTAL P.25
' • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365"
May 22,1995
4WD-NSRB
Mr. David Lown
North Carolina Department of Environment
Health, and Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
SUBJ: Review of an Explanation of Significant Difference (ESD)
Koppers Superfund Site
Dear Mr. Lown:
Enclosed is an· ESD for the Koppers Superfund Site in Morrisville,
North Carolina. Please review the ESD and let me know if you
concur. Thank you for your cooperation.
If you have any questions regarding this site, please contact
me at 404 347-7791 ext. 2080.
Sincerely,
Be~J:"~
Remedial Project Manager
Enclosure:
Printed on Recycled Paper
•
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
SUPERFUND PROGRAM EXPLANATION OF SIGNIFICANT DIFFERENCES
KOPPERS SUPERFUND SITE
MORRISVILLE, NORTH CAROLINA
Introduction
The purpose of this Explanation of Significant Difference
(ESD) is to provide information to the public on the changes to
the remedial activities for the Koppers Superfund Site in
Morrisville, North Carolina (the Site). The remedial action
selected by the U.S. Environmental Protection Agency, Region IV
(EPA), the lead agency for remedial activities at the Site, is
described in detail in the Record of Decision (ROD) signed on
December 23, 1992. The ROD provides for the remediation of soil,
surface and groundwater at the Site.
EPA has made one change to the implementation of the
recommended soil remediation for the Site. The ROD selected off-
Site incineration as the preferred alternative for treating
dioxin and pentachlorophenol. The ROD also stated that a
treatability study of the Based Catalyzed Decomposition (BCD)
innovative technology would be conducted to determine its
effectiveness on the contaminants of concern. Based on the
results of the treatability study a determination would be made
between utilizing incineration or the BCD technology at the Site.
The treatability study was conducted from August 23 -September
10, 1993, by EPA's Superfund Innovative Technology Evaluation
(SITE) Program. The results from the treatability study have
been finalized and based upon those results, EPA has selected the
BCD treatment technology to be utilized at the Koppers Site to
treat contaminated on-Site soil. This change represents a
significant difference from the original remedy for
pentachlorophenol and dioxin set out in the ROD. The public will
be notified of the change in the ROD through the publication of
the ESD. The ESD is being issued by EPA with the concurrence of
the North Carolina Department of Environmental Health and Natural
Resources (NCDEHNR).
This ESD is issued as part of EPA's public participation
responsibilities under Section 117(c) of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA),
42 U.S.C. § 9617(c), as amended by the Superfund Amendments and
Reauthorization Act of 1986, and Section 300.43S(c) (2) (i) of the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 C.F.R. Part 300. The ESD includes the information
which provides the basis for the change, the reasons why the
change is appropriate, and a discussion of the extent of the
change. The administrative record file for this Site contains
the information upon which the remedy selection was based,
•
including the ROD and Responsiveness
become part of that record, which is
locations:
Information Repository
Wake County Public Library
Cary Branch
310 South Academy Street
Cary, North Carolina 27511
[phone]
Site History
•
Summary. This ESD will
located at the following
EPA Region IV Office
U.S. EPA Records Center
Ground Floor
345 Courtland St. NE
Atlanta, Georgia 30365
[phone]
The Koppers Site 1s located in the community known as Shiloh,
several miles north of the town of Morrisville, at the
intersection of Highway 54 and Koppers Road. The Site consists
of approximately 52 acres, though ownership of the property is
divided. In 1959, the Site was sold by Cary Lumber Company to
Unit Structures Inc. and again sold in 1962 to the Koppers
Company. In September 1986, the majority of the Site was sold to
Unit Structures (a company unrelated to the previous owners);
Unit Structures currently operates a wood lamination facility at
the Site. Koppers Company retained approximately 10 acres of the
Site and has recently acquired additional portions of the
property. In June 1988, the Koppers Company was acquired by
Beazer, Inc. Therefore, both Beazer and Unit Structures now own
portions of the Site.
The CELLON process was used at the Site from 1968 until 1975.
The southeastern section of the Site was the location of the
CELLON processing area and the former lagoon area. The CELLON
treatment consisted of injection of PCP into the wood. PCP is a
main contaminant at the Site. Isopropyl ether (IPE) was used as
a cosolvent in the process to increase the solubility of PCP in a
butane carrier.
After treatment, residual PCP was removed by a steam process. The
rinsate was processed by a coagulant to remove excess PCP which
was filtered off. The final rinsate, presumed to be
predominately water, was pumped into two on-Site lagoons. It is
believed that these lagoons were not lined.
In 1976, Koppers voluntarily began to conduct environmental
studies at the site focusing on the CELLON process area and the
lagoon area. According to the history of the Site provided by
Beazer and based on those studies, it was recommended that the
two lagoons be reclaimed by land treatment. In 1977, the liquid
contents of the lagoons were pumped out and landfarmed, or
sprayed, in the northernmost portion of the Site. Fertilizer was
spread over the area and the area was plowed again. The lagoon
bottom sludges were mixed with surrounding soils and spread to
• •
dry over the former lagoon areas. The lagoon areas were also
fertilized and seeded. By definition, the lagoon contents
sprayed in the landfarmed area were considered F032 wastes;
likewise, the lagoon bottom sludges which were placed back in the
same area were characterized as K00l wastes.
In January 1980, Koppers conducted more studies on the Site.
Investigations of groundwater and soils were conducted. Results
of these investigations prompted the following soil removal
actions. During the spring of 1980, approximately 220 cubic
yards of contaminated soil were removed from the lagoon area.
Later that same year, 240 more cubic yards of contaminated soil
were removed from the area. In 1986, another soil removal was
conducted. Approximately 1100 cubic yards were taken from the
lagoon area, 50 cubic yards from the filter bed area and 100
cubic yards from the blowdown pit area. According to Beazer,
final disposal of these soils was to permitted facilities.
In 1980, the Environmental Services Division (ESD) of the
Environmental Protection Agency (EPA), conducted a site
inspection of the Fire Pond, the Medlin Pond and select private
wells. No further action was considered necessary at that time.
In 1986, Beazer began sampling off-Site private residential
wells.
The North Carolina Division of Health Services, Superfund Branch
also investigated the groundwater in the area to determine if any
of the contamination at the Site had migrated into private wells
in the immediate vicinity of the Site. Eventually, a cooperative
effort between the State of North Carolina and Beazer began, with
monitoring of private wells in the vicinity. This sampling was
conducted on a quarterly basis beginning in February 1989. Based
on the results of the private well sampling, Beazer provided
bottled water to all residents whose wells showed any detectable
amounts of IPE or PCP. The last round of sampling did not detect
any of the chemicals of concern in the resident's well water.
Therefore, the resident's bottled water supply was discontinued
in November 1993.
In June 1988, at the State's recommendation, the Site was
proposed for inclusion on EPA's National Priorities List (NPL),
and became final in March of 1989. On March 14, 1989, EPA issued
an Administrative Order on Consent, which allowed Beazer to
conduct the Remedial Investigation and Feasibility Study at the
Site.
In May of 1989, EPA and Beazer entered into an agreement for
Beazer to install public water supply lines to all residents
whose wells had been impacted. Approximately four miles of water
lines have been installed and approximately eighty residences
have been connected to the municipal water supply. The specific
terms of the water line construction were developed between
Beazer and the Town of Morrisville. Beazer tied into a pre-
• •
existing line installed along Koppers Road.
The Remedial Investigation (RI), completed in December of 1991,
confirmed the presence of Site contaminants in groundwater,
surface water, surface soils, subsurface soils and sediments.
The groundwater under the lagoon, process areas and off-Site was
found to be contaminated with PCP, PCDDs, PCDFs, and IPE.
Several additional phenolic compounds have been identified; 2,4-
dichlorophenol, 2,4,6-trichlorophenol, 2,3,5,6-tetrachlorophenol.
The RI also included an analysis of the potential dangers to
human health and the environment. Based on the results from the
RI, EPA determined that remediation of the soil, surface waters
and groundwater was necessary to protect human health and the
environment.
A Feasibility Study (FS) was conducted to analyze the remedial
alternatives. Each alternative was evaluated using the following
factors: effectiveness of soil and groundwater remediation, cost-
effectiveness, technical feasibility, institutional requirements,
and the degree of protectiveness to human health and the
environment.
On July 23, 1992, EPA held a public meeting at the Morrisville
Elementary School in Morrisville, North Carolina. At this
meeting, EPA discussed the remedial alternatives developed in the
FS and reviewed the preferred alternative. The ROD was signed
and issued on December 23, 1992.
Descriotion of the Remedy
A complete description of the selected remedy is contained in the
ROD, which is available at the information repository in the Wake
County Public Library and the U.S. EPA Records Center. In
summary, the Koppers Site remedy addressed the contaminated soil,
surface water, and groundwater present at the Site. The remedial
actions required by the ROD are briefly set forth below.
The selected remedy addresses the current and future unacceptable
risks posed by the Site to human health and the environment.
A primary remedy and a contingency remedy have been selected for
soils. The primary remedy for soils will permanently remove and
destroy contamination in the soil through treatment. This
alternative involves off-Site incineration of the soils at a
permanent permitted facility, to include:
e Excavation of contaminated soils from the lagoon, and
process area on-Site to meet cleanup standards
o Transportation of soils to an off-Site permitted
incineration facility
• •
o Backfilling of excavation area with clean fill and
o Final regrading and revegetation of the excavated
areas.
Dechlorination Treatability Studies were conducted on soils from
August 23 to September 10, 1993, by EPA's Superfund Innovative
Technology Evaluation (SITE) Program. Based upon the results of
those studies, EPA selected the Based Catalyzed Dehalogention
(BCD) treatment technology to be utilized at the Koppers Site.
The BCD technology will be required to permanently remove and
detoxify chlorinated organics in soils and will include:
o Excavation of contaminated soils from the lagoon and
process areas on-Site to meet cleanup standards
o Mobilization of soils to an on-Site dechlorination
treatment system
o Backfilling of excavation areas with clean, treated
soils and
o Final regrading and revegetation of the excavated
areas.
The remedy for groundwater will remove Site-related contaminants
in the groundwater through groundwater extraction and on-Site
treatment by carbon adsorption. The following activities are
involved in this remedy:
o Contaminated groundwater will be extracted from within
the plume via extraction well(s) and piped to an on-
Site, above-ground treatment unit.
o Treatment will consist of carbon adsorption through a
primary carbon adsorption unit and a secondary carbon
polishing unit.
Final discharge of the effluent will be to the surface
water, stipulated by the substantive requirements of
the National Pollutant Discharge Elimination System.
If no viable surface water discharge point exists on
the Site, the discharge may be off-Site, thereby
requiring a permit under the National Pollutant
Discharge Elimination System.
o Further delineation of the horizontal and vertical
extent of groundwater contamination will be conducted.
The remedy for surface water will remove Site-related
contaminants in the surface water by the dewatering of the ponds,
backfilling with clean fill, and regrading the areas for proper
•
drainage flow. Activities of the surface water component of the
remedy consist of:
o The on-Site Fire Pond and the Medlin Pond will be
dewatered
• The ponds will be backfilled with clean fill
o The surface water will be treated by carbon adsorption
o Final discharge of the effluent will be to the surface
water, stipulated by the substantive requirements of
the National Pollutant Discharge Elimination System.
If no viable surface water discharge point exists on
the Site, the discharge may be off-Site, thereby
requiring a permit under the National Pollution
Elimination System.
o Final regrading and drainage control of the pond areas
will be conducted and
o Wetlands will be destroyed under this portion of the
remedy. Therefore, wetlands mitigation will be
required under this remedy. Final location and
requirements of this mitigation will be decided during
Remedial Design. Evaluation of the associated habitats
will be conducted under a Habitat Restoration Plan.
Description of Significant Difference
EPA has made one change to the implementation of the
recommended soil remediation for the Site. The ROD selected off-
Site incineration as the preferred alternative for treating
dioxin and.pentachlorophenol. The ROD also stated that a
treatability study of the Based Catalyzed Decomposition (BCD)
innovative technology would be conducted to determine its
effectiveness on the contaminants of concern. Based on the
results of the treatability study a determination would be made
between utilizing incineration or the BCD technology at the Site.
The treatability study was conducted from August 23 -September
10, 1993, by EPA's Superfund Innovative Technology Evaluation
(SITE) Program. The results from the treatability study have
been finalized and based upon those results, EPA has selected the
BCD treatment technology to be utilized at the Koppers Site to
treat contaminated on-Site soil.
This change has been made to ensure that the remedy is
protective of human health and the environment, and to comply
with ·applicable State laws as provided under Section 121 of
CERCLA.
. ' . • •
Change in the Soil Remediation
The soil remedy selected in the ROD would still be
implemented. The health-based clean-up standards for PCP and
PCDDs/PCDFs will be 95ppm and/or 7ppb.
EPA expects to begin the soil remediation in accordance with
the change outlined in this ESD by June 1995.
Conclusion
The above-outlined change in soil remediation represents a
significant difference from the remedy outlined in the ROD.
Considering the new information that has been developed and the
change that has been made to the selected remedy, EPA and NCDEHNR
believe that the remedy remains protective of human health and
the environment, complies with Federal and State requirements
that are applicable or relevant and appropriate to this remedial
action, and is cost-effective. In addition, the revised remedy
utilizes permanent solutions and resource recovery technologies
to the maximum extent practicable for this Site.
John H. Hankinson, Jr.
Regional Administrator
B. Hudson/db:4WD:7791/4-5-94/BEVESD
Hudson Higgason LEAHY
GREEN FRANZMATHES
HARRIS FEHN JOURDAN
• RECEl\!~D
UMMING APR 31995 ITER
CONSULTANTS. l1 CsuPERfUMD SECTION
Ms. Beverly T. Hudson
USEPA-Region IV
Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: TRAN SM ITT AL
REVISED PAGES AND FIGURES
FINAL DESIGN REPORT
KOPPERS COMPANY INC., SUPERFUND SITE
MORRISVILLE, NORTH CAROLINA
Dear Ms. Hudson:
•
March 31, 1995
Project No. 93-145
Via Federal Express
On behalf of Beazer East lnc.(Beazer), enclosed are 5 sets of pages and figures from the
Final Design report which have been revised in accordance with Beazer's responses dated
March 3, 1995 to USEPA comments on the Final Design Report. Also included is a copy
of the US EPA Final Design Report comments and responses for insertion into
Appendix A.
If you have any questions, please call Mr. James Cook, Beazer at 412/227-2092.
Respectfully Submitted,
Cummings/Riter Consultants, Inc.
William C. Smith, P.E.
Project Manager
WCS:jgj
Enclosure
cc: LMr._[)<1vid Low.1_1, NS: S~perfuna (2 copies) J
Ms. Shannon Craig, Beazer · ·
Mr. James Cook, Beazer
Oxford Building. Suite 202 • University Office Plaza• Newark. DE 19702
93145\rcviscd.doc [phone] • FAX [phone]
•
BEAZER EAST, l:\'C., 436 SEVENTH A VENUE, PITTSBURGH. PA I j2 I 9
RECE\VF..O
M~R O 91995
Pi~R~f~U;:NO:;_;;.SE_C_T_IO_N..., 5U!_
Dear Ms. Hudson:
March 3, 1995
Ms. Beverly Hudson
USEPA -Region IV
Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: Responses to USEPA Comments dated
February 1, 1995
Koppers Company, Inc. Superfund Site
Morrisville, North Carolina
Enclosed are Beazer East, Inc. 's ("Beazer") responses to the United
States Environmental Protection Agency ( "USEPA") comments dated
February 1, 1995, and received by Beazer February 2, 1995, on the
Final Design Report for the Oil, Groundwater and surface Water
Remediation at the subject site. Draft responses to these comments
were provided to you on February 22, 1995, discussed during a
conference call on February 23, 1995, and finalized based on our
conference call.
Comments provided by the Department of Interior, received by Beazer
February 7, 1995, will be addressed in a separate response letter.
Once the USEPA conditionally approves the Final Design Report
subject to inclusion of these applicable responses, Beazer will
provide the revised pages and figures that changed as a result of
these comments and responses. If you have any questions, please
call me at [phone] or Jim Cook at [phone].
Sincerely,
&~Ck, r< l°:cf
~hannon K. Craig
Program Manager -Environmental Group
SKC:djw
Enclosure
//. cc: vDavid Lown -N.C. Superfund
James Cook -BEI
Terri Faye -BEI
William Smith -Cummings/Riter Consultants, Inc.
MAR 03 '95 03:39PM CU,NGS RITER DEL 1302 731 9509 •
USEPA REVIEW COMMENTS · FEBRUARY 1, 1995
FINAL DESIGN REPORT -KOPPERS COMP A."'IY, INC.
MORRISVILLE, NORTH CAROLINA
Comment 1: Page 18. Section 4.3 Excavation Plan. First Bullet. "Excavate an initial
soil volume based upon the soil excavation plan depicted on Construction Drav.ing No. 4
in Appendix B;"
Figure 4-9 shows that the area around borings X50 and X206 is
contaminated to a depth of 8 feet. Construction Drawing No. 4 shows
that the soil in this area v.ill be excavated to a depth of on! y 6 feet.
The excavation should continue to 8 fooi depth and the soil
surrounding X.50 and X206 should be treated.
Response: The soil surrounding X206 will be excavated to 8 feet. At the
XS0 location one sample was collected representing the depth interval
of 4 to 8 feet. In the X50 area, soil v.ill be removed to 6 feet and then
screened to assess the need for deeper excavation. This is why
Coristruction Drawing No. 4 indicates excavation to 6 feet at X50.
The Drawing will be revised to show excavation to 8 feet at X206.
Comment 2: Page 19. Last paragraph and re 4-10. "Excavated material -will be
temporarily staged in bermed areas lined with a 10 mil reinforced polyethylene liner. The
liner will be covered with a protective layer of soil to prevent damage to the liner. The
staged soil will also be covered ,,ith 6 mil reinforced polyethylene sheeting to protect the
soil from weather and to inhibit direct contract ,,..ith soils. See Figure 4-10 for staging
area schematic. It is not anticipated that the stage soil will be stored longer than 90 days."
EPA made the same 90 day argument at the Carolina Transformer site,
a fund-lead NPL site, to justify not having to meet the requirements
specified in 15A NCAC 13A Part 264, Subpart L; however, at the
Carolina Transformer site, EPA specified a waste pile design that is
closer to meeting the requirements than that being proposed for
Koppers. The EPA design includes, along with other improvements, a
leachate collection system a 20 mil membrane cover, and a 30 mil
·liner. The specifications of the EPA waste pile design are anached.
More information can be obtained from the Draft Performance
Specification for Soil Treannent (August 12, 1994) for the Carolina
Transformer site. The design for the Koppers site should meet these
minimum specifications.
93145\feblcomm.doc
MAR 03 '95 03:40PM C-NGS RITER DEL 1302 731 9509 •
Response: As discussed in our February 23, 1995 conference call, Beazer
is changing the contracting strategy for soil excavation and treatment
from that described in Section 4.2.2 of the Final Design Report.
Instead of contracting separately for excavation/staging and soil
treatment, one contractor will be used for both excavation and
treatment of soil. This will significantly reduce the schedule for this
portion of the work. Actual excavation and treatment of impacted soil
is expected to only last 30 to 45 days.
Based on this contracting change and our discussions on February 23,
the design of the temporary staging areas will remain as described in
the final design report and as depicted on Figure 4-10 of that report.
Section 4.2.2 will be revised to reflect this contracting change.
Comment 3: Page 20. Section 4.0 Soil Remediation. Subsection 4.5 Permits.
"Available information from the BCD soil treatment SITE demonstration will be
provided to the State of North Carolina, Air Quality Section for review of air monitoring
requirements."
The substantive requirements of an Air Quality permit are outlined in
the attached memorandum. The Air Quality Section wants ambient air
monitoring for dioxin during excavation and staging of contaminated
soils. Collectors used for monitoring should use a PUF sampler v.ith
subsequent GC/MS analysis (Method T09 from the Compendium of
Method5 for Toxic Compounds in Ambieni Air:, EPA 600/489-017).
The ambient monitoring system proposed must be evaluated by the
North Carolina Technical Services Branch for sening criteria and
sample handling. An Air Quality Plan must be approved also prior to
remediation. The system must be installed and approved prior to site
operations. Questions about these requirements should be directed to
Mr. Richard Lasater at the NC Air Quality Section (Phone: 919/73-3-
3340).
Response: Beazer is pursuing the air monitoring requirements of the
. North Carolina Technical Services Branch. As outlined the Statement
of Work anached to the Unilateral Administrative Order, the air
monitoring plan will be submined as part of the Remedial Action
Work Plan (RA WP).
Comment 4: Page 28. Section 5.0 Groundwater Remediation. Subsection 5.4
Permits. "Information required to meet the substantive requirements of the North
Carolina NPDES program has been submined to the State of North Carolina; however,
discharge limits have not yet been established by the state."
93145\feblcomm.doc 2
;
MAR 03 '95 03!40PM CU-NGS RITER DEL 1302 731 9609 •
The substantive requirements of the NPDES permit are contained in
the attached letter from Mr. David Goodrich to Ms. Beverly Hudson,
dated January 13, 1995. Questions about these requirements should be
directed to Ms. Jeanette Powell of the Water Quality Section at
919/733-5083, extension 537.
Response: Beazer acknowledges receipt of the substantive requirements
of the North Carolina ·NPDES and discharge limits. The form to be
used for reporting will be provided in the RA WP.
P.4/8
Comment 5: Page 29. Section·6.0 Surface Water Remediation. Paragraph 3. ''The
ROD further states that the surface water treatment and discharge standards will comply
'¾ith the substantive requirements of the NPDES permitting program."
TI1e substantive requirements of the NPDES permit are contained in
the attached letter from Mr. David Goodrich to Ms. Beverly Hudson,
dated January 13, 1995. Questions about these requirements should be
directed to Ms. Jeanette Powell of the Water Quality Section 919/733-
5083, extension 537.
Response: See response to Comment No. 4.
Comment 6: Page 44. Paragraph l. "If analysis indicates that penta levels are below
the 95 mg/kg, the material v.-ill be used as backfill for the excavation or reused elsewhere
on site."
Backfilling the excavation makes sense, however, the health risk-based
cleanup goals of 95 mg/kg penta and 7 ppb dioxin are based on a
commercial/industrial scenario. Moving soils that contain penta and
dioxin, but at levels below the cleanup goals, from the excavations in
the lagoon area, across the road to the Medlin Pond and into the
neighborhood of the residences in this area, docs not make sense and
should be avoided.
Response: Beazer's intent is to only use this material to backfill soil
excavations or as backfill at the Fire Pond. This material will not be
transported across the road to Medlin Pond.
Comment 7: Figure 3-1. Soil Sample Areas 1 & 2. Soil sample X227 is not shov,m to
contain contaminants above the remedial action level.
As shown on Figure 4-7, soil boring X227 contains contaminant (COI)
concentrations greater than remedial action goal and should be
indicated as such on Figure 3-1.
9314:S\fob 1 comm.doc 3
MAR 03 '95 03:41PM CUMMINGS RITER DEL 1302 731 9609 • •
Response: At the 2-4 foot depth, split sample results reported 35. l mg/kg
and 182 mg/kg for the same sample. The X227 location will be added
to Figure 3-1. ·This area is included on Construction Drawing No. 4.
Comment 8: Figure 4-4. Distribution of pentachlorophenol by depth of soil sample.
Number of samples which exceed remedial action goal as shown in
Figure 4-4 do not match the numbers shov.n in Figures 4-6 through
4-9:
0-2 FEET (7) (According to Figure 4-6 and not 6 as indicated in
Figure 4-4).
2-4 FEET (2) (According to Figured 4-7 and not 3 as indicated in
Figure 4-4).
6-S FEET (3) (According to Figure 4-9 and not 2 as indicated in
Figure 4-4).
Response: Figure 4-4 will be revised to match Figure 4-6, 4-7. and 4-9.
Comment 9: Figure 4-7. Appro:,:imate soil areas exceeding 95 mg/kg (2 to 4 feet
deep).
In Figure 4-7, soil sample X227 is sho"'n to contain greater than 95
mg/kg penta but the area surrounding the sample is not marked as
contaminated.
Response: Figure 4-7 will be revised to include X227 as an area
exceeding 95 mg/kg. This area was included in Construction Drawing
No.4.
General Comments:
Comment 10: There are references in the specifications to a Measurement & Payment
section but none is provided. If the engineer believes such a section is required, it should
be added and the specific comments shovm below addressed accordingly.
Response: The Measurement and Payment Specification is a contractual
issue and not technical. It .... ;n be provided to contractors with the bid
form, conmict, and general conditions as part of the construction bid
package.
Specific Comments:
Comment 11: Appendix C-1: Page 01400-2 was missing.
93145\feb I comm.doc 4
MAR 03 '95 03:41PM C.NGS RITER DEL 1302 731 9609 •
Response: Page 01400-2 is attached for your review.
Comment 12: Appendix C-1: Page 02055-1, Section 1.02; Item B refers to a Section
01150 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. 10.
Comment 13: Appendix C-1: Page 02100-1, Section 1.02; Item A refers to a Section
01150 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. I 0.
Comment 14: Appendix C-1: Page 02135-1, Section 1.02; Item D refers to a Section
01115 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. 10.
Comment 15: Appendix C-1: Page 02200-1, Section 1.02; Item B refers to Section
01 115 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. 10.
Comment 16: Appendix C-1: Page 02260-1, Section 1.02; Item C refers to a Section
01700 -Measurement & Payment, ·but this Section does not exist.
Response: See response to Comment No. 10.
Comment 17: Appendix C-1: Page 02300-1, Section 1.02; Item D refers to a Section
01700 -Measurement & Pa:ment, but this Section does not exist.
Response: See response to Comment No. 10.
Comment 18: Appendix C-1: Page 02400-1, Section 1.02; Item B refers to a Section
01150 -Measurement & Payment, but this S_ection does not exist.
Response: See response to Comment No. 10.
Comment 19: Appendix C-2: Page 01400-1, Section 1.02; Item B refers to a Section
01410 -Testing Laboratory Services, but this Section does not exist.
Response: Section 01410 -Testing Laboratory Service has been
eliminated. The reference v.ill be deleted.
Comment 20: Appendix C-2: Page 01650-1, Section 1.02; Item D refers to a Section
01700 -Construction Closeout, but this Section does not exist.
9314;\fcblcomm.doc 5
MAR 03 '95 03:41PM C-NGS RITER DEL 1302 731 9609 •
Response: Typographical error; Section 01700 • Construction Closeout
should read Section 01900 -Demobilization and Project Closeout.
Comment 21: Appendix C-2: Page 01730-1, Section 1.02; Item D refers to a Section
01700 -Construction Closeout, but this Section does not exist.
Response: Typographical error; Section 01700 • Construction Closeout
should read Section 01900 -Demobilization and Project Closeout.
Comment 22: General Comment• A
According to Section 5.1.4, Design Objectives, and the Unilateral Administrative Order,
the remedial action goal and MCL for pentachlorophenol in groundwater is 0.001 mg/L
or 1.0 ug/L. In Section 7.1.4, the use ofUSEPA Method 8270 modified v,ith "single
ionization monitoring" is proposed for the analysis of groundwater and surface water
samples collected at the subject site. The docwncnt claims that this modification lowers
the detection limit to "0.5 mg/1". Is this a typographic error? The unmodified version of
Method 8270 has a detection limit of 0.05 mg/] or 50 ug/L for pcntachlorophenol in watcr
samples.
Due to the chromatography demonstrated by pentachlorophenol in Method 82 70, it is
possible but unlikely that this modification will demonstrate sensitivity below the MCL
on a rou_tine basis. In order for this ''single ionization monitoring" version of Method
8270 to reach a detection limit lower than the MCL of 1.0 ug/L must be demonstrated on
a continuing basis. Therefore, in addition to the mid-level calibration standard,
calibration standard containing pentachlorophenol in an amount below the MCL should
be analyzed every twelve hours. Pentachlorophenol should meet the CCC criteria in both
standards.
Response: 0.5 mgll is a typographical error. The detection limit is
O.Sµgll. A calibration standard containing pentachlorophenol below
the MCL will be analyzed as pan of project specific protocol for this
site when analyzing groundwater samples.
General Comment -B :
All of the follov.ing comments were made on the Pre-Final Design Repon. A response to
these comments is contained in Appendix A of the Final Design repon but this response
merely states that the comments v,,ilJ be addressed in Appendix G. However, Appendix G
was apparently not included in the copy of the Final Design Repon. For reference, the
comments on Appendix G of the Pre-Finai Design Report are reprinted below.
Response: Beazer intended to have the NPDES monitoring requirements
prior to the final design subminal and planned to include the Sampling
and Analysis in Appendix A. However, when the NPDES limits were
not in place at the time of submission, Appendix G was deleted. The
93145\feb !comm.doc 6
MAR 03 '95 03:42PM CU,NGS RITER DEL 1302 731 9609 •
Sampling and Analysis Plan will be submined as pan of the RA \VP
and Construction Quality Assurance Plan as indicated in Section 7 .0 of
the final design report. Comments on Appendix G will be addressed
as appropriate in that submittal.
Comment 23: Appendix G (Remedial Design Sampling and Analysis Plan), Section 2.
Table 2-1, The holding times for Method 8290 listed in this table are incorrect. The
specifications of Section 6.4 of Method 8290 require the sample to be extracted within 30
days and completely analyzed within 45 days of collection.
Response: See response to General Comment B.
Appendix G, Section 3, Table 3-4 -as 7. above.
Response: See response to General Comment B.
Appendix G, Section 4, Table 4-2 • as 7. above.
Response: See response to General Comment B.
Appendix G, Section 5, Tables 5-1 and 5-2 -as 7. above.
Response: See response to General Comment B.
24. Appendix G, Section I 0.0 -The document proposes a detailed validation of only
five percent of the analytical data. Due to the complex nature of the PCDD/PCDF
analytical procedure and the critical nature of the PCDD/PCDF analytical data, a detailed
validation of 100% of the PCDD/PCDF analytical data is recommended.
Response: See response to General Comment B.
25. Appendix G, Section 13.2 -The equation presented in this section to calculate the
recovery of a compound spiked into a field sample does not take into account the
possibility of this compound being present in the sample prior to being spiked. An
example equation would read:
R = ~piked sam~e resu)t -~ample reimlt x 100
spi ed added
Response: See response to General Comment B.
93145\fcblcomm.doc i
•
CUMMINGS
1( {~~~LTANTS. INC
Ms. Beverly Hudson
USEPA -Region IV
Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
•
RE: USEPA REVIEW COMMENTS DATED FEBRUARY 1, 1995
FINAL DESIGN REPORT-KOPPERS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
Dear Ms. Hudson:
February 22, 1995
Project No. 93-145
RECEIVED
FEB 2 3 1995
!;jUPERFUND SECTION
Enclosed please find a draft copy of the responses to the USEPA Review Comments
dated February 1, 1995, of the Final Design Report for the Koppers Company, Inc.
needed for our February 23 conference call scheduled for 2:00 p.m.
If you have any questions, please call me.
Sincerelv, "
Cu,{'lmi~s/Riter/Cbnsu/tants, Inc.
' , . 1J t7 JI ·;l I I
-~ )vv{ ~/Y)/J"/!1 ./~ ~
William C. Smith, P.E. :f j
Project Manager
WCS:jgj
cc: \Mr. David J. Lown, DEl:!NR J
Mr. Jim Cook, Beazer East -·
Oxford Building, Suite 202 • University Office Plaza• Newark, DE 19702
931451fcb23cc.doc [phone] • FAX (302) 73 I -9609
• •
USEPA REVIEW COMMENTS-FEBRUARY I, 1995
FINAL DESIGN REPORT-KOPPERS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
Comment l: Page 18. Section 4.3 Excavation Plan. First Bullet. "Excavate an initial
soil volume based upon the soil excavation plan depicted on Construction Drawing No. 4
in Appendix B;"
Figure 4-9 shows that the area around borings XSO and X206 is
contaminated to a depth of 8 feet. Construction Drawing No. 4 shows
that the soil in this area will be excavated to a depth of only 6 feet.
The excavation should continue to 8 foot depth and the soil
surrounding XS0 and X206 should be treated. /f
Response: The soil surrounding X206 will be excavated to 8 feet. 1J the
XS0 location one sample was collected represe~tin the depth interval
of 4 to 8 feet. In the X50 area, soil will be rem d to 6 feet and then
screened to assess the need for deeper excavati . This is why
Construction Drawing No. 4 indicates excavati to 6 feet at X50.
The Drawing will be revised top excavation to 8 feet at X206.
Comment 2: Page 19. ~aragraph and re 4-10. "Excavated material will be
temporarily staged in be reas lined with a IO mil reinforced polyethylene liner. The
liner will be covered with protective layer of soil to prevent damage to the liner. The
staged soE·1 · I also be covered with 6 mil reinforced polyethylene sheeting to protect the
soil from e her and to inhibit direct contract with soils. See Figure 4-10 for staging
area sche 1c. It is not anticipated that the stage soil will be stored longer than 90 days."
EPA made the same 90 day argument at the Carolina Transformer site,
a fund-lead NPL site, to justify not having to meet the requirements
specified in 15A NCAC 13A Part 264, Subpart L; however, at the
Carolina Transformer site, EPA specified a waste pile design that is
closer to meeting the requirements than that being proposed for
Koppers. The EPA design includes, along with other improvements, a
leachate collection system a 20 mil membrane cover, and a 30 mil
liner. The specifications of the EPA waste pile design arc attached.
More information can be obtained from the Draft Performance
Specification for Soil Treatment (August 12, 1994) for the Carolina
Transformer site. The design for the Koppers site should meet these
minimum specifications.
93145\feb I comm.doc
• •
Response: This comment will be a topic of discussion during the
February 23 conference call.
Comment 3: Page 20. Section 4.0 Soil Remediation. Subsection 4.5 Permits.
"Available information from the BCD soil treatment SITE demonstration will be
provided to the State of North Carolina, Air Quality Section for review of air monitoring
requirements."
The substantive requirements of an Air Quality permit are outlined in
the attached memorandum. The Air Quality Section wants ambient air
monitoring for dioxin during excavation and staging of contaminated
soils. Collectors used for monitoring should use a PUF sampler with
subsequent GC/MS analysis (Method T09 from the Compendium of
Methods for Toxic Compounds in Ambient Air, EPA 600/489-017).
The ambient monitoring system proposed must be evaluated by4
North Carolina Technical Services Branch for setting criteria ancll
sample handling. An Air Quality Plan must be approved also prior to
remediation. The system must be installed anderovecl prior to site
operations. Questions about these requirement oulcl be directed to
Mr. Richard Lasater at the NC Air Quality Sect on (Phone: 919/733-
3340). f\
Response: Beazer is pursuing the ;::;,.onitoring requirements of the
North Carolinafinical Services Branch. As outlined the Statement
of Work attach the Unilateral Administrative Order, the air
monitoring pla will be submitted as part of the Remedial Action
Work Plan (RA WP).
CommenQ Page 28. Section 5.0 Groundwater Remediation. Subsection 5.4
Permits. "Information required to meet the substantive requirements of the North
Carolina NPDES program has been submitted to the State of North Carolina: however,
discharge limits have not yet been established by the state."
The substantive requirements of the NPDES permit are contained in
the attached letter from Mr. David Goodrich to Ms. Beverly Hudson,
elated January 13, 1995. Questions about these requirements should be
directed to Ms. Jeanette Powell of the Water Quality Section at
919/733-5083, extension 537.
Response: Beazer acknowledges receipt of the substantive requirements
of the North Carolina NPDES and discharge limits. The form to be
used for reporting will be provided in the RA WP.
93145\fob ! comm.doc 2
• •
Comment 5: Page 29. Section 6.0 Surface Water Remediation. Paragraph 3. "The
ROD further states that the surface water treatment and discharge standards will comply
with the substantive requirements of the NP DES permitting program."
The substantive requirements of the NPDES permit are contained in
the attached letter from Mr. David Goodrich to Ms. Beverly Hudson,
dated January 13, 1995. Questions about these requirements should be
directed to Ms. Jeanette Powell of the Water Quality Section 919/733-
5083, extension 537.
Response: See response to Comment No. 4.
Comment 6: Page 44. Paragraph I. "If analysis indicates that penta levels are below
the 95 mg/kg, the material will be used as backfill for the excavation or reused elsewhere
onsire. ~
Backfilling the excavation makes sense, however, the health risk-~ased
cleanup goals of 95 mg/kg pen ta and 7 ppb dioE. · re based on a
commercial/industrial scenario. Moving soils contain penta and
dioxin, but at levels below the cleanup goals, f m the excavations in
the lagoon area. across the road~he Medlin Pond and into the
neighborhood of the residences n 1s area, does not make sense and
should be avoided.
Response: Beazeatent is to only use this material to backfill soil
excavations orJ;;°s ~ackfill at the Fire Pond. This material will not be
transported across the road to Medlin Pond.
CommeQ Figure 3-1. Soil Sample Areas 1 & 2. Soil sample X227 is not shown to
contain contaminants above the remedial action level.
As shown on Figure 4-7, soil boring X227 contains contaminant (COi)
concentrations greater than remedial action goal and should be
indicated as such on Figure 3-1.
Response: At the 2-4 foot depth, split sample results reported 35.1 mg/kg
and 182 mg/kg for the same sample. The X227 location will be added
to Figure 3-1. This area is included on Construction Drawing No. 4.
Comment 8: Figure 4-4. Distribution of pentachlorophcnol by depth of soil sample.
Number of samples which exceed remedial action goal as shown in
Figure 4-4 do not match the numbers shown in Figures 4-6 through
4-9:
93 145\fob I comm.doc 3
• •
0-2 FEET (7) (According to Figure 4-6 and not 6 as indicated in
Figure 4-4).
2-4 FEET (2) (According to Figured 4-7 and not 3 as indicated in
Figure 4-4).
6-8 FEET (3) (According to Figure 4-9 and not 2 as indicated in
Figure 4-4).
Response: Figure 4-4 will be revised to match Figure 4-6. 4-7. and 4-9.
Comment 9: Figure 4-7. Approximate soil areas exceeding 95 mg/kg (2 to 4 feet
deep).
In Figure 4-7, soil sample X227 is shown to contain greater tha~
mg/kg penta but the area surrounding the sample is not marked a~
contaminated.
Response: Figure 4-7 will be revised to include X.C:::::as an area
exceeding 95 mg/kg. This area was included ink:~~struction Drawing
No. 4.
General Comments:
Comment 10: There are ranees in the specifications to a Measurement & Payment
section but none is provid f the engineer believes such a section is required, it should
be added and the specific omments shown below addressed accordingly. .
R(spi)nsc: The Measurement and Payment Specification is a contractual
l,jiue and not technical. It will be provided to contractors with the bid
form. contract. and general conditions as part of the construction bid
package.
Specific Comments:
Comment 11: Appendix C-1: Page 01400-2 was missing.
Response: Page 0 1400-2 is attached for your review.
Comment 12: Appendix C-1: Page 02055-1, Section 1.02; Item B refers to a Section
01150 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. I 0.
93145\fcb I comm.doc 4
• •
Comment 13: Appendix C-1: Page 02100-1, Section 1.02; Item A refers to a Section
0 I 150 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. I 0.
Comment 14: Appendix C-1: Page 02135-1, Section 1.02; Item D refers to a Section
01115 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. I 0.
Comment 15: Appendix C-1: Page 02200-1. Section 1.02; Item B refers to Section
01115 -Measurement & Payment, but this Section does not exist.
Response: See response to Comment No. 10. ~
Comment 16: Appendix C-1: Page 02260-1. Section 1.02; Item C refers to~ Section
0 I 700 -Measurement & Payment, but this Section does no~st.
Response: See response to Comment No. I 0. r
Comment 17: Appendix C-1: Page 02300~ection 1.02; Item D refers to a Section
01700 -Measurement & Payment, but this ~on does not exist.
Response: See res~e to Comment No. I 0.
Comment 18: Appendix l-I' Page 02400-1, Section 1.02; Item B refers to a Section
01150 -tv~rrement & Payment, but this Section does not exist.
RWonse: See response to Comment No. 10.
Comment 19: Appendix C-2: Page 01400-1, Section 1.02; Item B refers to a Section
01410 -Testing Laboratory Services, but this Section does not exist.
Response: Section 01410 -Testing Laboratory Service has been
eliminated. The reference will be deleted.
Comment 20: Appendix C-2: Page 01650-1, Section 1.02; Item D refers to a Section
01700 -Construction Closeout, but this Section does not exist.
Response: Typographical error; Section 01700 -Construction Closeout
should read Section 01900 -Demobilization and Project Closeout.
93145\feb I comm.doc 5
• •
Comment 21: Appendix C-2: Page O 1730-1. Section 1.02; Item D refers to a Section
01700 -Construction Closeout, but this Section does not exist.
Response: Typographical error; Section O 1700 -Construction Closeout
should read Section O 1900 -Demobilization and Project Closeout.
Comment 22: General Comment -A
According to Section 5.1.4, Design Objectives, and the Unilateral Administrative Order.
the remedial action goal and MCL for pentachlorophenol in groundwater is 0.00 I mg/L
or 1.0 ug/L. In Section 7.1.4, the use of US EPA Method 8270 modified with "single
ionization monitoring" is proposed for the analysis of groundwater and surface water
samples collected at the subject site. The document claims that this modification lowers
the detection limit to "0.5 mg/I". Is this a typographic error? The unmodified version of
Method 8270 has a detection limit of 0.05 mg/I or 50 ug/L for pentachlorophenol in water
s~les. ~
Due to the chromatography demonstrated by pentachlorophenol in Method 8~70, it is
possible but unlikely that this modification will demonstratra· nsitivity below the MCL
on a routine basis. In order for this "single ionization mon ing" version of Method
8270 to reach a detection limit lower than the MCL of 1.0 g/L must be demonstrated on
a continuing basis. Therefore, in additionio he mid-level calibration standard,
calibration standard containing pentachloro h ol in an amount below the MCL should
be analyzed every twelve hours. Pentachl ophenol should meet the CCC criteria in both
standards.
Response: 0.5 m~a typographical error. The detection limit is
0.5,tg/l. A calibration standard containing pentachlorophenol below
(th} MCL will be analyzed as part of project specific protocol for this
~e when analyzing groundwater samples.
General Comment - B :
All of the following comments were made on the Pre-Final Design Report. A response to
these comments is contained in Appendix A of the Final Design report but this response
merely states that the comments will be addressed in Appendix G. However, Appendix G
was apparently not included in the copy of the Final Design Report. For reference, the
comments on Appendix G of the Pre-Final Design Report are reprinted below.
Response: Beazer intended to have the NPDES monitoring requirements
prior to the final design submittal and planned to include the Sampling
and Analysis in Appendix A However, when the NPDES limits were
not in place at the time of submission, Appendix G was deleted. The
Sampling and Analysis Plan will be submitted as part of the RA WP
and Construction Quality Assurance Plan as indicated in Section 7.0 of
the final design report. Comments on Appendix G will be addressed
as appropriate in that submittal.
93145\fcb I comm.doc 6
• •
Comment 23: Appendix G (Remedial Design Sampling and Analysis Plan), Section 2,
Table 2-1, The holding times for Method 8290 listed in this table are incorrect. The
specifications of Section 6.4 of Method 8290 require the sample to be extracted within 30
days and completely analyzed within 45 days of collection.
Response: See response to General Comment B.
Appendix G, Section 3, Table 3-4 -as 7. above.
Response: See response to General Comment B.
Appendix G, Section 4, Table 4-2 -as 7. above.
Response: See response to General Comment B.
Appendix G, Section 5, Tables 5-1 and 5-2 -as 7. above.
Response: See response to General Comment B. r
24. Appendix G, Section 10.0 -The docint proposes a detailed validation of only
five percent of the analytical data. Due to omplex nature of the PCDD/PCDF
analytical procedure and the critical natur of the PCDD/PCDF analytical data, a detailed
validation of 100% of the P,DIPCDF analytical data is recommended.
Response: See reI;°o~se to General Comment B.
25. App(na}x G, Section 13.2 -The equation presented in this section to calculate the
recovery l,;i compound spiked into a field sample does not take into account the
possibility of this compound being present in the sample prior to being spiked. An
example equation would read:
R = spiked sample result -sample result x 100
spiked added
Response: See response to General Comment B.
93145\fob I comm.doc 7
• •
February 17, 1995
Memorandum
TO:
FROM
RE:
Jack Butler
David J. Lown
Dioxin produced and released during September 1993 BCD test
Koppers NPL Site
Morrisville, Wake County
This memo is being prepared to respond to your request for a concise description and
documentation of the dioxin that was produced and released during the BCD test at the Koppers
site in September 1993. The following documentation was given to me by Terry Lyons of the
SITE program during a presentation Mr. Lyons made to EPA Region IV personnel on
December I, 1994.
Seven soil tests were run during the demonstration and about 15 tons of soil were treated.
Testing parameters were varied during the demonstration. Table I shows the parameters that
were varied.
The most toxic dioxin is 2,3,7,8-TCDD. Before-and-after-treatment soil results for dioxin
are shown in Table 2. The amount of 2,3,7,8-TCDD increased in test runs I and 2. (For
example, input soils for test run I were below detection limits for 2,3,7,8-TCDD and output soils
averaged about 11 ug/kg.) The levels of2,3,7,8-TCDD for runs 4 through 7 were all below
detection and no conclusions about the creation or destruction of2,3,7,8-TCDD can be made.
Because of the way the data was collected, exactly how much dioxin was released to the
atmosphere during the demonstration is unknown. Mass-balance calculations suggest that a total
of0.3 grams of dioxin was released to the atmosphere during the demonstration (Table 3). How
much of this estimate is 2,3,7,8-TCDD, I do not know.
A high-volume filter air monitor device used during the demonstration detected l .59e-04
ng/dscm 2,3,7;8-TCDD and 8.39e-06 2,3,7,8-TCDF. These results are shown in Table 4.
Runs
1
2
3
4
5
6
BCD Test Parameters
Solid Reactor
Temp °F
•
1 800
800
650
650
800
800
Reagent
Bicarb (5%)
Non-Bicarb
Bicarb (5%)
Non-Bicarb
? •
? •
Retention
30 min
30 min
30 min
30 min
30 min
30 min
-l/1
l;S
" 0 0 rv
AA.:llytc
2,3,7,8-TCDD
Tolai TCDD
2,3,7,&-TCDF
Toul TCDF
Toul PeCDD
Total PcCDF
Total HxCDD
Tot,! HxCDF
Tot:,J HpCDD
Tool HpCDP
OCDD
OCDP
TABLE 2
ANALYTICAL RESULTS J'OR PCDD/F IN SOIL SA1"1PLES (µg/kg)
TB~r RUN 1
INPUT OlJTPITT
TRl-CNL-SU · TRI-CN 10-SU TR 1-£:N 1-SLJ TR I-CN2-SLJDUP TRI-CN2-SL3
038 u 1.5 u 7.4 20.6 8.7
6.5 J 7.0 u 87.3 298 99.3
2.0 u 1.4 u 0.74 u 0.66 u 1.0
31.4 I 25.9 J 2.6 lJ 4.7 J 2.3
2.3 u 2.5 u 141 439 169
134 J 123 J. 4.3 u 12.2 3.7
%.8 106 225 658 265
648 J 606 5.5 J 27.8 4.6
2,190 J 1,850 J 275 790 J 252
.
968 J 9-14 J 11.2 39.7 7.2
11,60 J 13.100 J 646 J 1.980 J 359
2,590 J 2,440 J 9.5 I 25.2 4 I
TR 1-CN3-SL3
J 8.7 J
86.1 • u 1.2 u
u 11.8 u
138
u 2.8 u
221
J 2.2 J
178
1.9 J
J 211
J 3.1 u •
-\Jl ,,,
Ana!yu:
2,3,7,8-TCDD
Tot>! TCDD
'1
<SJ 2,3,7,8-TCDF
TOb.l TCDF
Tm.al PcCDD
Total PcCDF
Total lbCDD
Total HxCDF
Tora! HpCDD
Tow HpCDF
OCDD
OCDF
I
TABLE Z..
(cont.iue<l)
ANALYrICAL RESULTS FOR PCDDffJN SOIL SAMPLES (J<glkg)
TEST RUN 2
INPUT OlffPUT
TR2-CN 1-S12 TR2--CNI-SL3 TR2-CN!-SL3D{JP TR2-CN2-SL3
L.6 u 2.4 J 8.0 J 3.9 J
3.2 u 267 3&3 466 J
L5 u 2.6 u 1.2 u 1.6 u
25_3 I 26.4 17.2 79.6
4.5 u 419 661 637
13& J 13_7 u 14_7 36.3
]07 7l!O J 1,300 J 1.090 J
561 J 17.7 24.9 49.4
1,750 J 951 J l,270 J 1, l 10 J
833 J 41.1 47.3 66.6
11,200 J l,250 I l,660 J U30 J
2,190 I 22.0 25.6 3&5
TR2-CN3-SL3
2.4 J • Y:YI
1.4 u
42
4()9
20_9
679
27_ l
632
37.0
759
.
17 .7 •
lJ
(SJ
'E'
Alulyle
2,3,7,&-TCDD
Tow TCDD
2 3 ) 8-TCDF
Total TCDF
Total PcCDD
Total P<.CDF
Toal HxCDD
Toul HxCDF
TOlal HpCDD
To<al HpOJP
OCDD
OCDF
TABLE 2..
(continued)
ANALYTICAL RESULTS FOR PCDD/F IN SOIL SAAIPLES (;iglkg)
TEST RUN 3
INPUT OITTPUT -CANCELLED
TR3-CN l -SL2
1.0 u
3.9 u
0.9 u
29.2 J
7.1 u
113 J .
102
550 J
1,T.J() J
1,040 J
8,460 J
1,510 J
•
•
OJ
~ ,-,.
Q L
Vl -J -J
h
0
isl
TABLE Z
(cootinucd)
ANAL\"fICAL RESULTS FOR PCDD/F IN SOIL SMIPLES (pg/kg)
TEST RUN 4
INPUT OUTPUT
Analylc BATI-CNI-SL2 TR4-CN I -SL3 'ffi4-CN2-SL3 TR4-CN3-SL3
2,3,7 ,8-TCDD 2.1 u 0.74 u l.4 u 1.6 u • Total TCDD 3.4 u 5.1 u 7.6 u 4.9 u
2,3,7,8-TCDF 1.2 u 1.4 u 1.0 u 0.96 U
TotiOI TCDF 22.0 J 2.1 u I. I u I.I u
Taul PeCDD 7.2 u 8.4 u 8.1 u 4.1 u
Taul PeCDF 122 J 3. 1 u J.2 u 1.5 u
Tot.al JlxCDD l l 7 15 .4 u 4.2 u 11.9 u
Tot.al HxCDF (/J7 J 2.1 u 1.8 •U 2.4 u
Toral HpCDD 2,000 J 23.1 u 12.2 u 13.9 u
Tola! HpCDF l,070 J 3.4 u 1.5 u 1.4 u
OCDD 15,000 J 42.◄ u 19.0 u 2l.7 u
OCDP 3,390 J 2,5 u 1.9 u 1.0 iJ •
~
Vl
ld
Ana!ytc
2,3,7.8-TCDD
Total TCDD
1 2,3.7 ,8-TCDF
Total TCDF
Tou.J Pt:CDD
Total PeCDF
Tatu HxCDD
Tot.! HxCDF
To<,! HpCDD
Total HpCDP
OCDD
.. OCDF
TABLE 2...
(continueil)
ANALYTICAL RESULTS FOR PCDD/~' IN SOIL SAl\1PLES (Jlg/kg)
TEST RUN 5
!NPUT OUTPUT
BATI-CNl-SU TR5-CN !-SU TR5-CN I-SL1DVP TR5-CN2-SL3
0.85 u 2.2 u l.4 u 2.2 u
2.2 u 4.2 V J.4 u 4.4 V
!I u J.3 V 2.2 u I. 9 lJ
36.J J 1.6 V I.] V 2.S u
6.4 V 4.1 V 3.6 u 7.2 lJ
93.9 J i.6 V 2.2 u 2.6 V
87.4 7.4 V 8.2 u 10.6 V
482 J J.5 u 2.2 u 3.0 V
1,520 J 8.1 u 11.6 u 12.6 V
793 J 1.9 u S.7 u 2.8 V
7,400 J 12.4 u 19.2 u . 17.0 V
1;420 J 1.9 u 0.71 i.J 6.4 V
TR5-CN3-SL3
2.0 u • 5.5 lJ
1.3 u
2.2 V
J.7 V
3.0 V
8.8 u
l.]4 u
9.4 V
1.8 u
12.4 V •• 0.48 u
Vl
(.J
"'
TABLE z.._
(coolinued)
ANALYTICAL RESULTS FOR PCDD/F IN SOIL SAl\.1PLES (µglkg)
TEST RUN 6
INPUT OUTPUT
Analyre BAT:J-CNl-SLl BA T3-CN I D-SLl TR6-CN 1-SLJ TR6-CN2-SL3 TR6-CN3-SL3
2,3,7,8-TCDD 0.17 u 0.60 u l. 7 u 3.1 u 0.92 u
To1>1 TCDD 6.6 3.4 u 1. 9 U. 1.7 u 2.2 u
2,3,7,8-TCDF I. 7 u 1.2 u 1.4 u 3.0 u 1.4 u
Toti! TCDF 55.1 J 24.3 J 1.2 u 0.70 u 1.4 u
Tot>l PeCDD 7.7 u 6.6 u 4.0 u 7.4 u 5.0 u
Total PeCDF 125 J 155 J 1.5 u 2.1 u 3.1 u
Total HxCDD ]35 141 6.7 u 7 .2 u 7.2 u
Total HxCOF 701 1 826 J 1.4 u 1.3 u 2.3 u
Tot.al HpCDD 1,930 J 2,660 J 8.1 u 8.8 u 9.0 u
Total HpCDF 1,260 J 1,540 J 1.9 u 3.7 u 1.3 V
OCDD 9050 J 11,200 J l l .7 V J 2.8 u 11.4 u
OCDF 1,840 J 2,550 J I.I V 1.9 u 2.3 u
•
•
::,: D ;o
I
~
(J)
I
~
~ h..
lJ
e;) ~
TABLE Z
(continued)
ANALYTICAL RESULTS FOR PCDD/F IN SOIL SAMPLES (pg/kg)
TEST RUN 7
lNPUT OUTI'UT
AnalyLe BAT4-CN1-SL2 TR7-CN I-SU TR7-CN2-SL3
2,3,7 .8-TCDD 0.94 u 1.2 u
Total TCDD 9.7 J 4.3 u
2.3,7.8-TCDF 1.0 u 2,4 u
Total TCDF 61.1 J 1.4 u
Total PtCDD 21.1 3.2 u
Total PoCDF 134 J 1.8 u
Total HxCDD 278 9.0 u
Total HxCDF 695 l 2.5 u
Total HpCDD 3,690 J 9.7 u
Total HpCDF 1. 150 J 6.1 u
OCDD 10,200 l 15.5 u
CX:DF 2,670 J 0,62 u
Not=
U -Not dcletc<l a< the kvel reported.
J -Estimated only. Below i.cu!nnneot a.libration range.
TCDD -TctrachJorinated dibemo-p-dioxin
TCDF -Tcirachlorinalcd dibcazofurao -
HpCDD -Hcptachlorinau:d dibenzo-p-dioxin
HpCDF -HcptachJorioa!Cd dibcnzofur.m
HxCDD -Hcuchlorioo1ed dibctu.o-p-dio;tin
HxCDP -Hcxachlorirulled dib<:nzofuran
PeCDD -Peotacblorinntcd dib=-p-<lioxin
PeCDF -Peotachlorinated dibeomfuran
OCDD -Ocladuorirurtcd dibenzo-p-<lioxio
OCDF -Oct;tdilorinated dibc.11Zofur..u
1.4 u
3.0 J
1.9 u
1.9 u
8.1 u
3.0 u
16.2
1.9 u
18.9 u
2.7 u
22.2 lJ
1.6 u
TR7-CN3-SL3
O.W u
6.5 u
3.4 u
3.4 u
8.2 u
4.4 u
20.1
2.9 u
21.6 u
3.5 u
28.5 u
4.3 u
•
•
• • TOTAL MASS OF PCDDs AND PCDFs EMITTED
TO THE ATMOSPHERE DURING OPERATION OF THE MTID
Run Number AYerage Sum of Tow Total Amount
and Sample Volumetric Duration of Total Gas PCDD and of PCDD and
Location Flow Rate Rw1 (min) Flow PCDF PCDF Emitted
(dscmm) (dscm) Concentrations to Atmosphere
(ng/dscm) (mg)
Run l, Outlet 2.06 720 . 1,483 31,214 46.3
Run 2, Outlet 1.86 690 1,283 65,602 84.2
Assume 1. 66 -Assume 38,583 -
Run 3, Outlet Average of 660 1,096 Average of 42.3
Other Runs Other Runs
(Outlet) (Outlet)
Run 4, Outlet >'l .36 510 693.6 737.7 0.51
Run 5, Outlet 1.88 570 1,071.6 96,112 103.0
Run 6, Outlet 1. 31 570 746.7 18,572.2 13.9
Run 7, Outlet 1.47 .--· 540. 793.8 19,260.1 15.3
TOTAL MASS OF PCDDs A1'fD PCDFs EMITTED TO
ATMOSPHERE DURING OPERATION OF ~ITID = 305.Slmg = 0.3g
BCD/047-l 127ff0TALDXN TBL
/'' \/"' ....
• •
Table 4
Summary of l'CDD/PCDF Results for AmbieJJt Hi-Yolnme filter Samples
llfllili&iiiilliii
2,3,7,8-TCDD __ -----~ _ 1.59c-04 ____ 1.19c,-06 J
2,3,7,8-TCDF 8.39e·D5 '---·-·-·-___ S._L'l_c_·0_7_~ ___ J ____ _
Surrogate Re<:over:,...:(_%.;..) __________ ~---
13C-2,3,7,8-TCOD 69 65
DC-?0 3,7,8-TCDF
Anal)'1C
74
Total TCDD l.73c-03
1,2,3,7,8-PcCDD 1.23c-03
Totnl PcCDD 8,03e-03
B
B
B
B
71
5,14e-05
4.63c-06
S.08e-05
3.63e'.06
B,Q
B,J,Q
B,Q
B,J 1,2,3,4,7,8-HxCDD 2.91e-03 -----l-------1------lf-------l----'---ll
l,?0 3,6,7,8-HxCDD 4.27c-03 B 3.50c-06 B,J
l,2,3,7,8,9-HxCDD 7.79e-03 B -7.81e-06 B,J
Total HxCDD 5,78i;.02 B 6.56e-05 B
1,2,3,4,6,7,8-HpCDD 5.78e-02 . B,E 233e-05 B
Total HpCDD l.18e-01 B,E 5.44e-05 B
OCDD l.23e-0l B,E,S 9,19e-05 B
Total TCDF 1.77e-04 I 5.S0e-06 J,Q
1,2,3,7,8-PcCDF · 4.82c-05 1.75c-06 u
2,3,4,7,8-PcCDF l.95e-05 J 1.06e-06 u
Tot~! PcCDF 6,76c-04 I,Q 3.9'.c-06 J,Q
I 1,2,3,4,7,8-H.x'CDF -----J--.::.1.;,;,64e~-04;;_-ih---~---1-.,.._;.::;c:..;_c, __ f.. ___ :..._.........jl 9-'lSe-07 u
1,2,3,6,7,8-HxCDF 8,94c-05 s · 1.19e-06 u
2,3,4,6,7,8-HxCDF _____ ,___9_.7_8_c_-Oc;:.5_-+---'-----+-------+----'---9.38e-07 B,J
1,2,3,7,8,9-HxCDF -----l---'--5_.89_e_-0:;_5_-l------f-----+-~-'----
Total HxCDF l.55e-03 B,l
8.75c,07 u
4.69e-06 J,Q
1,2,3,4;6,7,8-HpCDi.' l.58c-03 B -----l-----1,2,3,•1,7,8,9-HpCDt' 4.20c-04 B
1.56e-06 B,J. ·-----1.13e-06 u
Total H pCD P 7 ,85e-03 B 4,38c·06 B~
OCDF 5,75e-03 B,S 5.38e-06 B,J
Su rrog:, le Recorer,· (%)
J3C-2,3,7,8-TCDD _____ + _ _.:.68.::..__+-----l---
13C-1,2,3,7,8-PcCl,D 93
69
96
13C-1,2,3,6,7,8,l·W:oo 90 90
13C·l.2,3,4,6,7,8-l-! oCDD 113 91
13C-OCDD 113 68
l3C-2,3,7,8-TCDF 78 77
•
Table
(Continued)
l.JC-l ,?03,4,6, 7,8-1-l s,CDF 85 '----------------·~---· MM5 Surrog«to Rc~ery (%)
BC-1,2,3,4-TCDF NA
Qu.:ili{icf$:
8 -Anillyte found i:; es'"k;,,1,:.c laOOra!oty n',cthc,d bl.rnk. C • Co.-.=.!uti.nr, isome.r pre: .. ·.ot. E -E.nim.atc only; e:xcc.etl.$ intn.:rncnr ullbrJrion r:lnge. I • Pcx.~ibk p,.;!ychJorin.Hed_ Oiphenyl ether inter!enc~. J. E:.!inrn.ic on/;, 0¢Jo,..,. ir..v,n:;;:e;u c..'!!ibr:\!ion r.'lnge, ,'{.A -f\10! nna!y,,.ed.
Q -!'e.,'lk pre..s,:;nf O!.lt.sidc iO:<: ratlo JimiL.~. U -Not detci;:tcd ar the !e.< I rc;-o.:cd.
•
%
NA
-=
.,.
,-. •
United States Department of the Interior
Ms. Beverly T. Hudson
FISH AND WILDLIFE SERVICE
Ecological Services
Post Office Box 33726
Raleigh, North Carolina 27636-3726
February 2, 1995
North Superfund Remedial Branch
Waste Management· Division
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Hudson:
·-113 -Ill
RECEiV!ED
FEBO 81995
$UPERFUND SECTION
The U.S. Fish and Wildlife Service (Service) has reviewed the December 1994
Remedial Design Habitat Mitigation Plan (Mitigation Plan) and September 1994 Pre-
Final Design Report (Design Report) for the Former Koppers Company, Incorporated
Superfund Site in Morrisville, Wake County, North Carolina. These comments
respond to your September 20, 1994 letter on the Design Report and January 6,
1995 letter on the Mitiga~ion Plan_ and are intended to assist your
investigations, assessments, and the planning process being conducted pursuant
to Section 104(a) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended (42 u.s.c. 9601 et seq.). Service comments are
being provided on a technical assistance basis only and do not represent any
position that the U.S. Department of the Interior (Department) may adopt
concerning possible injury to natural resources under the Department's
trusteeship.
The Service is pleased that the Mitigation Plan and Design Report have addressed
many of the issues identified in our previous correspondence on this project.
The Mitigation Plan is very thorough and well written. Issues remaining to be
resolved includ9 the inclusion of a more binding performance guarantee in the
Mitigation Plan and our continuing.concern over the protectiveness of the clean-
up levels for polychlorinated dibenzo-p-dioxins (PCDDs), and polychlorinated
dibenzofurans (PCDFs). These concerns are discussed in this letter.
Mitigation Plan
The designed remedy at the Former Koppers Company site will, among other actions,
include dr.aining Fire Pond and Medlin Pond which are contaminated with
pentachlorophenol, PCDDs, and PCDFs. Consequently, the two ponds and two parcels
of adjacent wetlands will be impacted. The two wetland units have been
identified as FP-3 and FP-7. Unit FP-3, which surrounds approximately one-half
of the Fire Pond, consists of a palustrine, scrub-shrub, broad-leaved, deciduous,
intermittently exposed wetlands. Dominant vegetation in the wetland includes
black willow (Salix nigra), soft rush (Juncus effusus), wax myrtle (Myrica
cerifera), and groundsel tree (Baccharis halimfolia). The unit provides migratory
waterfowl habitat, small mammal habitat and habitat for wading and other bird
species. The wetland also provides functions such as water storage / flood
retention and water quality improvement by filtration and attenuation. Unit FP-7
fringes the drainage channel which connects the Fire Pond to Medlin Pond. It
consists of a palustrine, forested, broad-leaved deciduous, seasonally flooded
wetland. Dominant vegetation in this unit consists of sweetgum (Liquidambur
styraciflua), black gum (Nyssa sylvatica), red maple (Acer rubrum) and willow oak
(Quercus phellos). The unit provides storm water retention, water quality
• •
improvements by filtration and adsorption, and wildlife habitat.
Units FP-3 and FP-7 will be affected by the remediation activities at the site.
The area of each is about 0.75 and 0.55 acres, respectively, for a total of about
1.30 acres. The Mitigation Plan notes that although unit FP-7 may be affected
to some degree by the remediation, some of this unit may survive due to its
distance from the shores of Medlin Pond and its location in an existing drainage
channel which is to remain functioning after remediation. Therefore, the 1.30
acres may not be totally disturbed. The combined areas of Medlin and Fire Pond,
which are to be filled, is 5.7 acres.
In addition to attenuating existing chemical hazards from site habitat, the
proposed mitigation consists of the construction of approximately 2.6 acres of
wetland and 0.6 acres of open water habitat. Two areas are proposed for the
mitigation. The Seagondollar property will consist of 1.6 acres of mixed
herbaceous, scrub-shrub, and forested wetland and 0.6 acres of open water habitat
while the Medlin Pond area will contain about 1 acre of forested wetlands.
The proposed Seagondollar mitigation area currently consists of disturbed
woodlands. A field investigation of this parcel by site contractors indicates
no existing wetlands. The parcel is located in Wake County about 2.5 miles from
the Former Koppers Company Superfund Site. The entire Seagondollar mitigation
area property consists of about 4.5 acres.
The Medlin Pond area will be de-watered and filled during the site remediation.
The project area is considered a part of the Koppers Superfund Site and is
located on the south side of Koppers Road across from the Fire Pond.
We appreciate the level of detail the has been .. incorporated into the Mitigation
Plan, including descriptions of sites to be restored or created, discussions of
site preparation, vegetative stock, planting, and designation of persons
responsible for monitoring and maintenance. Although the concept of a
performance guarantee has been embraced, as is evident in the Operation,
Monitoring, and Maintenance Program (Attachment 4) and warranty (page 35 of
Attachment 1), the Mitigation Plan still lacks language to ensure the plan is
properly and successfully implemented. The statement that monitoring will be
conducted from two to three years needs to be amended to recognize that
monitoring and maintenance will continue until the success criteria (85 percent
coverage by desirable vegetation) have been met. Currently, the monitoring_
section describes what will occur if the success criteria are ultimately met
within three years, but there is no discussion of actions to be taken if
mitigation is not fully successful at the end of the third year of monitoring.
The Mitigation Plan should be amendeid to address this deficiency by stating the
procedures to be implemented if project monitoring indicates remedial actions are
still required after three years.
The Service commends the efforts of the consultants to include experimental areas
for rare insectivorous plants (page 4-4) and fish replacement (page 4-8 and page
40 of Attachment 1) in the habitat restoration. We wish to emphasize, however,
that these activities are not a requirement of the Service in satisfying the
mitigation requirements.
Design Report
In the Department's May 26, 1992 comments on the Revised Draft Feasibility Study,
it was cautioned that a more protective clean-up level for PCDDs and PCDFs in
site soils and sediments may be appropriate. Unless the soils and sediments at
7 parts per billion (ppb) TCDD-TEQs are capped to preclude exposure to wildlife,
the remedy may not be protective of ecological receptors. It is not known
whether the proposed 1-foot of fill over the contaminated sediments will
effectively isolate them from burrowing organisms. Because the U.S.
Environmental Protection Agency is proceeding with the 7 ppb TCDD-TEQ clean-up
goal, we recommend that a biotic component be added to the environmental
monitoring proposed in the remedial design. While.monitoring of surface water,
groundwater and soils is currently required under section 9. 5, "Compliance
• •
Monitoring," of the December 1992 Record of Decision, additional monitoring of
forage organisms, such as earthworms or small mammals, is advised. This is
particularly pertinent for the Medlin Pond area which is to be restored to a
functioning palustrine forested wetland hydrologically fed by run-off from the
remainder of the Former Koppers Company site, as well as effluent from the
treated groundwater of the site. We note that levels approaching or exceeding
1 ppb TCDD-TEQ have been documented from sediments in both ponds and the Fire
Pond outflow ditch.
We caution that the proposed PCDD / PCDF clean-up level for groundwater is about
1,000 times higher than the North Carolina surface water quality standard for
dioxin. This may inhibit the use of surface water discharge for treated
effluent. Page 8 of the Design Plan indicates that a practical quantitation
limit of SO parts per quadrillion (ppq) will be used as a performance criteria;
we note that quantitation limits as low as 0.03 ppq TCDD-TEQ were reported in
Appendix F, "Predesign Data Report," which is closer to the State standard of
0.014 ppq.
Thank you for the opportunity to review the documents. If you have any
questions, please contact me or Mr. Tom Augspurger of this office at (919) 856-
4520 (extension 21).
cc: Lee -REO -DOI/OEPC
Dawson -AES/TS-EC
Wellman -USEPA / ETAG
Lown -NCDSWM
~~u
L.K. Mike Gantt
Supervisor
•
February I, 19<}4 r;;.t
Memorandum
TO:
FROM:
RE:
File
David J. Lown~~
Air Permitting Requirements -Base Catalyzed Decomposition (BCD) Process
Remedial Design
Koppers Company, Inc. NPL Site
Morrisville, Wake County
I phoned Beverly Hudson today and asked her when the State would get to review the air
monitoring plan for the BCD process to be used at this site; Air Quality Section's substantive
requirements for a permit were forwarded to her as part of my comments on the Final Remedial
Design Report. She assured me that a requirement for the submittal of an air-monitoring plan is
contained in the Remedial Design Report and that the State would have an opportunity to review
and comment on the air-monitoring design before the final plan to use the BCD process is
approved.
cc: Bruce Nicholson
State of North calltna
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Ms. Beverly Hudson
January 17, 1995
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
RE: Comments on the Final Design Report (December 28, 1994)
Koppers Company, Inc. Site
Morrisville, Wake County
Dear Ms. Hudson:
COPY
The Superfund Section received and reviewed this document and offers the following
comments:
1) Page 18. Section 4.3 Excavation Plan. First Bullet. "Excavate an initial soil volume
based upon the soil excavation plan depicted on Construction Drawing No. 4 in
Appendix B;"
Comment. Figure 4-9 shows that the area around borings XS0 and X206 is
contaminated to a depth of 8 feet. Construction Drawing No. 4 shows that the soil in
this area will be excavated to a depth of only 6 feet. The excavation should continue
to 8 foot depth and the soil surrounding X50 and X206 should be treated.
2) Page 19. Last Paragraph and Figure 4-10. "Excavated material will be temporarily
staged in bermed areas lined with a 10 mil reinforced polyethylene liner. The liner will
be covered with a protective layer of soil to prevent damage to the liner. The staged
soil will also be covered with 6 mil reinforced polyethylene sheeting to protect the soil
from weather and to inhibit direct contact with soils. See Figure 4-10 for staging area
schematic. It is not anticipated that the stage soil will be stored longer than 90 days."
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone 9l9-733-A996 FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post•consumer paper
Ms. Beverly Hudson
January 17, 1995
Page 2
• •
Comment: EPA made the same 90 day argument at the Carolina.Transformer site, a
fund-lead NPL site, to justify not having to meet the requirements specified in I SA
NCAC 13A Part 264, Subpart L; however, at the Carolina Transformer siie, EPA
specified a waste pile design that is closer to meeting the requirements than that being
proposed for Koppers. The EPA design includes, along with other improvements, a
leachate collection system, a 20 mil membrane cover, and a 30 mil liner. The
specifications of the EPA waste pile design are attached. More information can
obtained from the Draft Performance Specification for Soil Treatment (August 12,
1994) for the Carolina Transformer site. The design for the Koppers site should meet
these minimum specifications.
3) Page 20. Section 4.0 Soil Remediation. Subsection 4.5 Permits. "Available
information from the BCD soil treatment SITE demonstration will be provided to the
State of North Carolina, Air Quality Section for review of air monitoring
requirements."
Comment. The substantive requirements of an Air Quality permit are outlined in the
attached memorandum. The Air Quality Section wants ambient air monitoring for
dioxin during excavation and staging of contaminated soils. Collectors used for
monitoring should use a PUF sampler with subsequent GC/MS analysis (Method T09
from the Compendium of Methods for Toxic Compounds in Ambient Air, EPA 600/4-
89-017). The ambient monitoring system proposed must be evaluated by the North
Carolina Technical Services Branch for siting criteria and sample handling. The
system must be installed and approved prior to site operations. Questions about these
requirements should be directed to Mr. Richard.Lasater at the NC Air Quality Section
(Phone [phone]).
4) Page 28. Section 5.0 Groundwater Remediation. Subsection 5.4 Permits.
"Information required to meet the substantive requirements of the North Carolina
NPDES program has been submitted to the State ofNorth Carolina; however,
discharge limits have not yet been established by the state."
Comment. The substantive requirements of the NPDES permit are contained in the
attached letter from Mr. David Goodrich to Ms. Beverly Hudson, dated January 13,
1995. Questions about these requirements should be directed to Ms. Jeanette Powell
of the Water Quality Section at [phone], extension 537.
5) Page 29. Section 6.0 Surface Water Remediation. Paragraph 3. "The ROD further
states that the surface water treatment and discharge standards will comply with the
substantive requirements of the NP DES permitting program.
Comment. • The substantive requirements of the NPDES permit are contained in the
attached letter from Mr. David Goodrich to Ms. Beverly Hudson, dated January 13,
Ms. Beverly Hudson
January 17, 1995
Page 3
•
1995. Questions about these requirements should be directed to Ms. Jeanette Powell
of the Water Quality Section at [phone], extension 537.
6) Page 44. Paragraph 1. "If analysis indicates that penta levels are below the 95 mg/kg,
the material will be used as backfill for the excavation or reused elsewhere on site."
Comment. Backfilling the excavation makes sense, however, the health risk-based
cleanup goals of 95 mg/kg penta and 7 ppb dioxin are based on a
commercial/industrial scenario. Moving soils that contain penta and dioxin, but at
levels below the cleanup goals, from the excavations in the lagoon area, across the
road to the Medlin Pond and into the neighborhood of the residences in this area, does
not make sense and should be avoided.
7) Figure 3-1. Soil Sample Areas 1 · & 2. Soil sample X227 is not shown to contain
contaminants above the remedial action level.
Comment. As shown on Figure 4-7, soil boring X227 contains contaminant (COI)
concentrations greater than remedial action goal and should be indicated as such on
Figure 3-1.
8) Figure 4-4. Distribution ofpentachlorophenol by depth of soil sample.
Comment. Number of samples which exceed remedial action goal as shown in Figure
4-4 do not match the numbers shown in Figures 4-6 through 4-9:
0-2 FEET (7) (According to Figure 4-6 and not 6 as indicated in Figure 4-4.)
2-4 FEET (2) (According to Figure 4-7 and not 3 as indicated in Figure 4-4.)
6-8 FEET (3) (According to Figure 4-9 and not 2 as indicated in Figure 4-4.)
9) Figure 4-7. Approximate soil areas exceeding 95 mg/kg (2 to 4 feet deep).
Comment. In Figure 4-7, soil sample X227 is shown to contain greater than 95 mg/kg
penta but the area surrounding the sample is not marked as contaminated.
Ms. Beverly Hudson
January 17, 1995
Page 4
• • ,.
We appreciate the opportunity to comment on this document and look forward to seeing
this site cleaned. If you have any questions, please call me at [phone].
Attachments
cc: Jack Butler
Bruce Nicholson
Sincerely,
~~
David J. Lown ·
Environmental Engineer
NC Superfund Section
• SECTION 02050 •
PART 1
STORAGE, DISPOSAL, DEMOLITION ANO DUST CONTROL
GENERAL
1.1 WORK INCLUDED The work includes the control of fugitive dust
emissions, demolition and disposal of the Main Building and adjacent
building ruins as indicated on drawings,· ,· removal and disposal of site
vegetation, debris, four USTs, six electrical transformers, and if
necessary, the temporary onsite storage of non-contaminated and
contaminated materials. The requirements of this section pertain to all
site activities, as outlined in Section 01015 and as required to
complete the excavation, stockpiling and removal activities.
1.2 REFERENCES. The publications listed below form a part of this
specification to the extent referenced. The publications are referred
to in the text by basic designation only.
CODE OF FEDERAL REGULATIONS (CFR)
40 CFR 761 POLYCHLORINATED BIPHENYLS (PCBs) MANUFACTURING,
PROCESSING, DISTRIBUTION IN COMMERCE, ANO USE
PROHIBITIONS.
NORTH CAROLINA ADMINISTRATIVE CODE
NORTH CAROLINA ADMINISTRATIVE CODE, TITLE !SA, Chapterl3 SOLID
WASTE MANAGEMENT.
1.3 SUBMITTALS. See Section 1300, SUBMITTALS.
1.4 DEFINITIONS.
Drainage Gravel. Gravel placed above the membrane liner along the
containment berm to facilitate drai~age and removal of leachate
and meets the requirements specified in Part 2 of this Section.
Geo Net. A polymeric material manufactured as a three dimensional
lattice to promote drainage within the plane of material
placement. Geo net is placed between the filter fabric and
membrane liner to allow space for leachate flow.
Filter.Fabric. A non-woven polypropylene fabric manufactured to
allow passage of water while retaining soil particles without
clogging. Filter fabric is placed above geo net and membrane
liner to facilitate leachate drainage.
Membrane Cover. Sheeting which is placed on top of the permanent
soil stockpile to prevent rainwater infiltration and meets the
requirements specified in Part 2 of this Section. ,
02050-1
DRAFT
August 12, 1994
I I
Membrane Liner~Sheeting which is placed abov.lect fill and
beneath the permanent soil stockpile to prevent stockpile leachate
from seeping into the surrounding soil and meets the requirements
specified in Part 2 of this Section.
Select Fill~ "Fill which is used to bring subgrade below the
membrane liner up to required elevation and grade and meets the
requirements specified in Part 2 of this Section.
Select Waste Soil. Select waste soil shall be that portion of
excavated contaminated soil which is able to pass a 3/4 inch U.S.
standard sieve and is free of rocks, debris, roots, deleterious
material and other sharp objects which may potentially damage the
Membrane Liner. ·
Silt Control Fence (Silt Fence). Slit-film woven polypropylene
fabric manufactured for the purpose of silt control application
and placed as a fence perpendicular to runoff flow in areas where
soil erosion is to be minimized or prevented.
Sump Cleanout Pipe. Slotted PVC pipe placed in the layer of
Drainage Gravel and against the stockpile berm to provide access
to remove drained liquids for disposal.
PART 2 PRODUCTS
2.1 Drainage Gravel.
quartzite gravel
Engineer.
Drainage gravel shall be uncontaminated
obtained from a local source and approved by the
2.2 Geo Net. The new Geonet shall consist of Gundle Gundnet® XL-14 or
equivalent as approved by the Engineer.
2.3 Filter Fabric. The new filter Fabric shall consist of Polyfelt
TS600® or equivalent as approved by the Engineer.
2 .. 4 Membrane Cover. The new membrane cover shall consist of PVC
material of not less than 20 mills nominal thickness placed
continuously and sealed over the stockpiled soil to prevent the
infiltration of rainwater. The Cover Liner shall be Huls America
Inc. PVC 0176® or equivalent as approved by the Engineer.
2.5 Membrane Liner. The new membrane liner shall consist of high
density polyethylene (HOPE) material of not less than 30 mils
nominal thickness placed above Select Fill and below the Drainage
net for the purpose of providing a continuous impermeable barrier
to liquids. The Drainage Liner shall be GUNDLE GUNDLINE® HD or
equivalent as approved by the Engineer.
2.6 Select Fill. Select fill shall be uncontaminated soil obtained
from a local source, classified as "SC" under the Unified, Soil
Classification System and shall contain gfeater than 12% clay by
02050-2
DRAFT
August 12, 1994
weight. Othe-uitable material may be substi.ed as approved by
the Engineer. The Select Fill material shall be fr;ee of rocks,
debris, roots, organic, deleterious or frozen material which may
potentially damage the membrane liner. 100% of the Select Fill
material shall pass a #4 U.S. Standard Sieve.
2.7 Silt Fence Fabric. The new geotextile shall meet the minimum
specifications as follows:
Fabric Properties
grab tensile strength(LB)
elongation at fail.(%)
Mullen burst strength (PSI)
puncture strength (lb)
equivalent opening size
ultraviolet stability(%)
Minimum
90
50
190
40
40
40 -80
test method
ASTM 01682
ASTM 01682
ASTM 03786
ASTM 0751
CW-02215 ·
ASTM 9-26
2.8 Sump Cleanout Pioe. The Sump Access pipe shall be new schedule 40
PVC pipe .. The portion of pipe to be installed at the bottom of
the sump shall be slotted .0.050 inch openings.
2.9 GENERAL MEMBRANE REQUIREMENTS.
A. The new membrane liner shall consist of HOPE material as
appropriate and manufactured of new, first-quality products
designed and manufactured specifically for the purpose of
liquid contaminant in hydraulic structures.
B. The new membrane cover shall consist of PVC material as
appropriate and manufactured of new, first-quality products
designed and manufactured for use in liquid containment.
C. The Contractor shall, at the time of bidding, submit a
certification from the manufacturer(s) of the sheeting,
stating that the sheeting meets physical property
requirements for the intended application.
0.. The liner or cover material shall be so produced as to be
free of holes, blisters, undispersed raw materials, or any
sign of contamination by foreign matter.
E. Labels on the roll shall identify the thickness, length, and
manufacturer's roll number. There shall be no factory seams.
F. The liner material shall meet the specification values
according to the specification sheet for HOPE or PVC
respectively.
G. All welding or adhesive material and equipment shall be of a
type supplied by the respective membrane manufacturer.
02050-3
DRAFT
August 12, 1994
//~-:_ •. ·,:,:·.\-}~:-.
i;Y,:•;~t)/~_·.\:/w,::_~•\/~:-
:i{/ti}>
·.>,,:._·::_::.')
''_· ;~;..~-.-
• •
,~ ;;):~:-:· '::?f<.
:,:,:."
~~--.-.-;JCT-05-' 9,1 l,IED 14: 0"3 ID: A IR QLJRLI TY I-IQ . • •
Division·of Environmental Management:
Air Quality Section
October 4, 1994
MEMORANDUM
'l'O :
FROM;
David J, Lown
Superfund Section
N.C. Division of Solid waste :Management
Richai::d Lasater /<, L.
Air Permite Branch
:1210 POl
SUBJECT! Ambient air moni tod.ng a.t Koppers Super fund si. te
The first phase of the cieanuJ? is the excavati.on and staging
of contaminated soil, including the pond bottoms. The cleanup
contract:or·s final version of this pa.rt of the i;-e111ediation plan
does not include ambient air moni to1·ing except that required on-
site by OSHA.
The Ai:r. Q1.lality Section feels that an ambient air monitoring
system should be operated co. track dioxin di.scharges from various
c\Ctivities during "i:he proposed cleo.nup, The monitoi:-ing system
should cont3in thr,:,e sampling sites, two of which must be on the
property. lines. The third site may be located on l~he property.
One of the monitors must be collocated. Instead of the TSP Metl1od
V "Hi-Vol" collectors used during the prior testing activities,
use of a PUF sampler with subsequent GC/I1S aualysis (Method
T09)is recommended. Sampling time chould i:-un fi:-om midnight to
midnight. Any ambient moni taring iiystem pi:-oposed must be
evaluated by the. Technical Services Branch for sit:ing c:rited.a
and sarnple handling, approved and installed prior to any site
operations.
JRN-13-1995 10:43 FROl'I DEM WATER QUALITY SECTiOI, TO
State of North!rolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
97334811 •
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A: Preston Howard, Jr., P.E., Director
January 13. 1995
Ms, Beverly Hudson
Superfund Br-anch, Waste Mgt. Div,
US EPA Region IV
345 Courtland Street
Atlanta. GA 30365
Dear Ms, Hudson:
Subject: Koppers Co., Inc. NPL Site
Morrisville, North Carolina
Wake County
P.02/04
Koppers Company, Incorporated (Koppers) submitted an application to the Division of
Environmental Management (Division) for a NPDES permit on June 13, 1994. After the
Division had completed the permit development aud public notice pwcesses, Koppers
informed the Division that it was not required to obtain u NPDES rcrmit under the
CERCLA regulations. It is the understanding.of the Division that Superfund activities
discharging on-site are !!ill subject to state NP DES permitting requirements, but~ subject
to substantive discharge requirements to assure compliance with instream water quality
stawhrds. ·
A summary of the substantive discharge requirement~ is attached, as well as a copy of the
draft NPDES permit. It is unclear how the substantive requirements are to be administered
under the CERCLA regulations and, the Division of Environmental Management Water
Quality Section is concerned that without a NPDBS permit there may be no mechanism to
ensure that the requirements are effectively implemented. As a National Priority List site
with contaminant:$ that have the potential to threaten the quality of waters of the state, this
discharge is of significant concern to the Division.
The Division would appredate any insights you can pwvide on available implementation
mechanisms for the dischargo requirements, · If you have any questions, please feel free to
contact Jeanette Powell of my staff at [phone], extension 537. .
jcp/JCP:DAG
cc: Dave Lown, DEM Superfund Section
NC0084366 Pennit File
sn119w~
David A. Goodrich, Supen-isor
NPDES Permits Group
Ken Schuster, Raleigh Regional Office
P.O. Box 29535, Raleigh, Nor1J1 Carolina 27626,0535
An Equal Opportunity Affim1atlve Ar.lion Employee Telephone 919-733·7015 FAX [phone]
50% recyclod/ 10% PQSt-oon~umer paper
JAN-13-1995 10: 43 FROM DEl'I WATER QURL !TY SECT! ON TO 97334811 • •
SUMMARYOFSUBSTANTIVEDISCHARGEREQUJREMENTS
FOR KOPPERS CO., INC
1 . Groundwater Remediation
Analytical Monitoring Requirements:
Effluent Discharge Measurement
Characteristic Limitation Freauencv SamoleTvoe
Flow nta 2/Month Instantaneous
Phenol n/a "2/N10nrn nrab.
Dioxin n/a Quanerlv Grab
Pentachloroohenol 2Q.Q UP/J 2/Monlh Grab
Chronic Toxicitv 1 n/a Quarterly Grab
All samples shall be collected from the final effluent discharge below all treatment
processes.
Footnot~:
P. 03/04
1 Cluoaic Toxicity: TI1e effluent discharge shall at no time exhibit chronic toxicity using
test procedures outlined in The North Carolina Ceriodaphnia chronic effluent bioassay
procedure (North Carolina Chronic Bioa~say Procedure• Revised *September 1989) or
subse'luent versions. The effluent concentration at which there may be no-observable
inhibit10n of reproduction or significant mortality is 90% ( defmed as treatment two in the
North Carolina procedure document).. A pass/fail test shall be perfonned on samples
collected quarterly during the months of March, June, September, and December ..
NOTE: Failure to achieve test conditions.as· specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate retesting( within 30 days of initial
monitorin.g event). Failure to subinit suitable test results will constitute noncompliance
with monitoring requirements.
2 • Pond Dewatering
Analytical. Monitoring Requirements:
Effluent Discharge Measurement
Characteristic Lirnitaliou Freauencv Sarnole Tvoe
Pe11tac11Jorophenol 20.0 uir/J ., Grab
Phenol II/a * Grab
Diox.iu ** ., urab
* Each pond shall be sampled and analytical results obtained prior to commencement of
-dewatering activities. Any result found to be in excess of specified limitations shall be
considered a violation of water quality standards if dewatering proceeds.
** Analytical nosults shall indicate non-detect for dio,cin.
Ji=N-13-1995 97334811 P.04/04
3.
•
Reporting
It is suggested that these reporting requirements apply to the above listed substantive .
· discharge requirements. Monitoring result~ obtained during the previous month(s)
shall be summarized for each month and reported on a monthly Discharge Monitoring
Report (DMR) Form or alternative forms approved by the Director and post.marked·uo
later than the 30th day following the completed reporting period. . . .
The first DMR is due on the last day of the month following the commencement of
discharge. Duplicate signed copies of these, and all other reports required herein, shall
be submitted to the following address:
Division of Environmental Management
Raleigh :Regional Office
Water Quality Section
Post Office Box 27687
Raleigh, North Carolina 27611
TOTAL P.04
' ' •-~ State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
January 13, 1995
Ms. Beverly Hudson
RECEIVED
JAN 1 91995 Superfund Branch, Waste Mgt. Div.
US EPA Region IV
345 Courtland Street
Atlanta, GA 30365
Dear Ms. Hudson:
sUPERFUND SECTION
Subject: Koppers Co., Inc. NPL Site
Morrisville, North Carolina
Wake County ·
Koppers Company, Incorporated (Koppers) submitted an application to the Division of
Environmental Management (Division) for a NPDES permit on June 13, 1994. After the
Division had completed the permit development and public notice processes, Koppers
informed the Division that it was not required to obtain a NPDES permit under the
CERCLA regulations. It is the understanding of the Division that Superfund activities
discharging on-site are not subject to state NPDES permitting requirements, but are subject
to substantive discharge requirements to assure compliance with instream water quality
standards. ·
A summary of the substantive discharge requirements is attached, as well as a copy of the
draft NPDES pem1it. It is unclear how the substantive requirements are to be administered
under the CERCLA regulations and,the Division of Environmental Management Water
Quality Section is concerned that without a NPDES permit there may be no mechanism to
ensure that the requirements are effectively implemented. As a National Priority List site
with contaminants that have the potential to threaten the quality of waters of the state, this
discharge is of significant concern to the Division.
The Division would appreciate any insights you can provide on available implementation
mechanisms for the discharge requirements. If you have any questions, please feel free to
contact Jeanette Powell of my staff at [phone], extension 537.
jcp/JCP:DAG
cc: Dave Lown, DEM Superfund Section
NC0084366 Permit File
S~cerely; /l . ~ ii-9,/.?f✓tvc,,l---~
David A. Goodrich, Supervisor
NPDES Permits Group
Ken Schuster, Raleigh Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone]
50% recycled/ 10% post·consumer paper
• •
SUMMARY OF SUBSTANTIVE DISCHARGE REQUIREMENTS
FOR KOPPERS CO., INC.
1. Groundwater Remediation
Analytical Monitoring Requirements:
Effluent Discharge Measurement
Characteristic Limitation Frequency Sample Type
Flow n/a 2/Month Instantaneous
Phenol n/a 2/Month Grab
Dioxin n/a Qumterlv Grab
Pentachlorophenol 20.0 µg/1 2/Month Grab
Chronic Toxicity I n/a Quarterly Grab
All samples shall be collected from the final effluent discharge below all treatment
processes.
Footnotes:
1 Chronic Toxicity: The effluent discharge shall at no time exhibit chronic toxicity using
test procedures outlined in The North Carolina Ceriodaphnia chronic effluent bioassay
procedure (North Carolina Chronic Bioassay Procedure -Revised *September 1989) or
subsequent versions. The effluent concentration at which there may be no observable
inhibition.of reproduction or significant mortality is 90% (defined as treatment two in the
North Carolina procedure document). A pass/fail test shall be performed on samples
collected quarterly during the months of March, June, September, and December.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate retesting(within 30 days of initial
monitoring event). Failure to submit suitable test results will constitute noncompliance
with monitoring requirements.
2. Pond Dcwatering
Analytical Monitoring Requirements:
Effluent Discharge Measurement
Characteristic Limitation Frequency Sample Type
Pentachlorophenol 20.0 IJ o/1 * Grab
Phenol n/a * Grab
Dioxin ** * Grab
* Each pond shall be sampled and analytical results obtained prior to commencement of
dewatering activities. Any result found to be in excess of specified limitations shall be
considered a violation of water quality standards if dewatering proceeds.
** Analytical results shall indicate non-detect for dioxin.
•
3 . Reporting
It is suggested that these reporting requirements apply to the above listed substantive
discharge requirements. Monitoring results obtained during the previous month(s)
shall be summarized for each month and reported on a monthly Discharge Monitoring
Report (DMR) Form or alternative forms approved by the Director and postmarked no
later than the 30th day following the completed reporting period.
The first DMR is due on the last day of the month following the commencement of
discharge. Duplicate signed copies of these, and all other reports required herein, shall
be submitted to the following address:
Division of Environmental Management
Raleigh Regional Office
Water Quality Section
Post Office Box 27687
Raleigh, North Carolina 27611
State of North .lino Department of Environment, Health and Natural Resources
Division of Solid Woste Management
James B. Hunt, Jr,, Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
~A
DEHNR
January 6, 1995
Ms. Beverly Hudson
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
RE: NPDES Permit
' Koppers Company, Inc. Site
Morrisville, Wake County
Dear Ms. Hudson:
Attached is the NPDES pennit that I told you about on the phone today. The Water Quality Section is preparing a summary of the substantive requirements and will fax them directly to you when they are available.
If you have any questions, please call me at [phone].
Attachment
cc: Jack Butler
Sincerely,
GvJ)-~.~
David J. Lown
Environmental Engineer
Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
State of North •lino
Department o~ ronment, Health and Natural Resources
Division of Solid Waste Management _X,A
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
DEHNR
Mr. Tom Augsburger
Fish and Wildlife Service
Department of the Interior
P.O. Box 33726
Raleigh, NC 27636-3726
January 5, I 995
RE: Final Habitat Mitigation Plan (December 1994)
Koppers Company, Inc. NPL Site
Morrisville, Wake County
Dear Mr. Augsberger:
Attached is the Final Habitat Mitigation Plan for the Koppers NPL site. I will be
submitting comments on the Final Remedial Design soon and would like to incorporate your
concerns if possible. If you have any questions or comments, please call me at 733-2801.
cc: Bruce Nicholson
Jack Butler
c5~~
David J. Lown
Environmental Engineer
Superfund Section
P.O. Box 27687. Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post~consumer paper
State of North c4ilhlina
Department o~ronment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
January 4, 1994
Memorandum
TO:
FROM:
Arthur Mouberry, Chief
Groundwater Section
Division of Environmental Management
David J. Lown Ope
Environmental Engineer
Superfund Section
Division of Solid Waste Management
RE: Final Remedial Design Report
Koppers Superfund Site
Morrisville, Wake County
•4~~ a·· -------·~ a a ,;-, ____ _
DEHNR
Please forward the attached Remedial Design report to Jeanette Powell in the
Water Quality Section and Richard Lasater in the Air Quality Section. Jeanette is in the
process of determining the substantive requirements of an NPDES Permit and Richard is
assessing the air permitting requirments. Beazer East, Inc., the PRP, is completing the Remedial Design for this National Priority List site. The NC Superfund Section is
reviewing the draft report and will be submitting comments to EPA soon. EPA is the
lead regulatory agency for the site and the report was prepared for the PRPs by
Cummings Riter Consultants. In addition to comments by the Air and Water Quality
Sections, we would also like the comments of the Groundwater Section.
If you or your staff have questions, please call me at [phone].
Attachment
cc: Bruce Nicholson
Jack Butler
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX 919-71$-3605
An Equal Opportunity Affirmative Action Employer 5m'., recycled/ l 0% post-consumer paper
State of North ~lino
Department o(~ironment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr .. Governor
Jonathan B. Howes. Secretary
William L. Meyer, Director
Ms. Beverly Hudson
November 15, I 994
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
,~--a a·· . ---1" ---dOi O O Fi iii BA
DEHNR
RE: North Carolina Division of Environmental Management (DEM) Comments on
Intermediate Remedial Design
Koppers Company, Inc. Site
Morrisville, Wake County
Dear Ms. Hudson:
Attached are comments made by the DEM on the Intermediate Remedial Design. If you
have any questions or comments, please call me at (919) 733-280.
cc: Bruce Nicholson
Jack Butler
~y
DavidJ. Lown
Environmental Engineer
Superfund Section
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North Cnrolina
Department of &iror,ment,
Health and Nat~I Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B Howes, Secretary
A Preston Howard, Jr., P.E., Director
October 25, 1994
MEMORANDUM
TO: David Lown
Superfund Section ~
FROM: ~ Preston Howard~-/. .
SUBJECT: Koppers Company
Intermediate Remedial
Wake County
Project No. 94-47
Design
The Division of Environmental Manage~ent has completed the
review of the subject document and offers the following comments
and recommendations.
Air Quality Section
Ambient air sampling for dioxin should be conducted at the
site during excavation and treatment of the soil.
Water Quality Section
Water Quality has numerous concerns about this discharge and
the limitations of monitoring dioxin to the water quality
limit. Attached please find the staff report dated August
11, 1994.
Groundwater Section
The groundwater should be remediated to the standards set
forth in 15A NCAC 2L.0200.
If there are any questions, please advise.
APHjr/sbp/SWM2.
cc: Alan Klimek
Steve Tedder
Rale.igh Regional Office
Central Files
Groundwater Section Files
P.O. Box 29535, flaleigh, North Carolina 27626-0535 Telephone [phone] FAX 'I 1 '1-715-0588
t ... n Equal Opportunity J\ffirrnotive Action Employer 50% recyclec!/ i [)o/,, post -con:;urT1e:r pciper
T f Yes, sue No. --------• To: Permits and EngineflLE copy
Water Quality Section fl
Attention: Jeanette Brig_g_,;_
Date August il, 199-1
NPDES STAFF REPORT AND RECOMMENDATION
County i-lake
Permit No. NC0084366
PART I GENERAL INFORMATION
1. Facility and Address:Beazer East, Inc.
Koppers Company Superfund Site
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
2. Date of Investigation: August 10, 1994
3. Re9ort Prepared by:Babette McKemie, P.E.
4. Persons Contacted and Telephone Number: Robert Fisher,
Beazer, 412-227-2955
5. Directions to Site:Hwy 54 to Morris~;ille, left on Koppers
Rd., right on Church St. site on left
6. Discharge Point(s), List
Outfall 001 (groundwater
Latitude: 35°50°48".
for all discharge points:
remediation)
Langi tude: 7 8°50' 18"
Outfall 002 (Medlin Pond)
Latitude: 35°50' 35" Longitude: 78°50' 19"
Outfall 003 (Fire Pond)
Latitude: 35°50'42" Langi tude: 7 8°50 · 2 o"
Attach a USGS map extract and indicate treatment facility
siLe and discharge point on map.
U.S.G.S. Quad No. D23SE U.S.G.S. Quad Name Cary
7. Site size and expansion area consistent with application?
_X __ Yes ___ No If No, explain:
8. Topography (relationship to flood plain included) :relatively
flat, not in flood plain
9. Location of nearest dwelling:more than 400 feet
10. Receiving
Cree}:
to Crabtree
a. Classificatio11:S NSW
b. River Basir1 and S1.1bbasin ~ro. :OJ 04 02
c. Describe ceceivi11g stream features and perti.r1011t
dow11strea1u tises:dry drainage ditcl1, differe11t
locatio11s on the same ditch Eor all three outfalls
PART II DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be pe·rmitted:
Outfall 001 (Groundwater Treatment) .0144MGD(Ultimate
Design Capacity)
Outfall 002 (2A) . 15 MGD
Outfall 003 ( 28) . 15 MGD
b. What is the current permitted capacity of the 1.-Jcste
Water Treatment facility?none
c. Actual treatment capacity of the current
(current design capacity)?N/A
facility
d. Date(s) and conscruction activities allowed by previous
Authorization to Construct issued in the previous two years:
N/A
e. Please provide a description of existing or
substantially constructed wastewater treatment facilities:
none
f. Please proviae a description of proposed wastewater
treatment facilities:The groundwater remediation system will
consist of one recovery well, a 1,500 gallon equalization
tank, flow meter, two pumps,.dual bag filters, and dual
carbon filters.
The surface water remed·iation system will be a portable
system. It will be used for one pond and then moved to the
next one. It will be designed for 105 GPM, however design is
not complete and will be submitted with A to C request.
g. Possible toxic impacts to surface waters: Dioxin, Fur an
h. Pretreatment Program (POTWs only):
in development __ _
should be required ___ _
approved~---
not needed X
2. Residuals handling and utilization/disposal scheme: N/A
3. Treatment plant classification (attach completed rating
sheet) :Class I
If Yes, SOC No. ---------• •
4. SICCode(s): 2439
'daste\•.iater Cocie(s) of: c~ctuc.l 1..-laste•,va.te.r, not pa.ct.i_cula.c
fac.i.lities i.e .. , non-contact cooling '.-i·ater d.ischc..rge from a
metal plating company would be 14, 11ot 56.
Primary 66~ Secondary _____ _
Main Treatment Unit Code: 002-0
PART III OTHER PERTINENT INFORMATION
1. Is this
Funds or are
facility being constructed with Construction Grant
any public monies involved. (municipals only)?N/A
2. Special monitoring
requests:toxicity, Dioxin,
or limitations (including
Furan and fish tissue
toxicity)
3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate)none
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non-discharge ootions available. Please provide
regional perspective for each option evaluated. Discharge is the
besc option for this facility
S. Other Special Items:
PART IV EVALUATION AND RECOMMENDATIONS
The RRO has reviewed the
a site visit. The project is
an EPA order to remediate
indicated.
information submitt~d and conducted
an EPA Superfund site and is under
the site, although no dates were
The remediation plan calls for the fire pond to be
remediated first, followed by the Medlin Pond. The site visit
revealed that this was not practical because the fire ·pond
outfall will drain right to the Medlin Pond. The Medlin Pond
should be remediated and filled prior to remediation of the fire
pond. The drainage through the Medlin Pond will have to be
recontoured and reinforced in order to then take the flow from
the draining and remediation of the larger fire pond.
Alternatively, the outfall and/ drainage way~ could be rerouted
_so that the flow does not go through the Medlin Pond or through
the newly backfilled area.
The applicant needs to address these issues more thoroughly in
the A to C application.
The NPDES permit should be issued with three effluent pages,
one for each outfall. Outfall 001 for the groundwater should be
from the completion of the Fire Pond Remediation until
expiration. Outfall 002 for the Medlin Pond should be from
receipt of the A to C until completion of Medlin Pond
Remediation. Outfall 003 for the Fire Pond should be from
completion of the Medlin Pond Remediation until completion of the
. .
If Yes, soc No. _______ _
Fire Pond Remedlj_on. In this way, only le remediation project
is underway at a time. It is estimated that the remediation of
both ponds will only take e month. The monitoring should be
identical for each system.
The stream standard for Dioxin is .000014 ng/1. The
concentrations for Dio:d.n in the various contaminated areas are
on the order of .03 to 5.7 ng/1. Even if the treatment system is
99% effective, the effluent will be as much as 4000 time greater
than the stream standard, The detection limit is 10 ng/1. 'l'he
effluent could be far below the detection limit but as much as
7 million times over the stream standard for human health. This
discharge is directly upstream of Lake Crabtree which is a
recreational lake. The other compound reported is Furan which is
closely related to Dioxin. The same discrepancy poses itself
with Furans.
This site is a superfund site under an EPA order to clean
up. However, if treating to safe levels cannot be achieved, is
discharging the solution? If this permit is issued, perhaps Dr.
Ken Rudo with Epidemiology should also provide recommendations.
In addition, fish tissue sampling should be required before and
during discharge in order to track bioaccumulation. The RRO has
reservations about t~e is uance of this permit.
# -1,0 . ~ , j' -~.1/7,=e
Water Quality Regional Supervisor
Date
J_ 1·
(._ ,• I -..:.:.:..
H:\NC84366.SR
I
,1[) Cv1 A) (ccC..(/ ~
/_!,_ l--_/:c--1...~~ I
/
l . State of North <iaolina
Department of~ironment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
October 25, 1994
MEMORANDUM
TO: David Lown
Superfund Section ~
FROM: ~ Preston Howard~-
SUBJECT: Koppers Company
Intermediate Remedial Design
Wake County
Project No. 94-47
~VA
DEHNR
NOV ,~ 1994
The Division of Environmental Management has completed the
review of the subject document and offers the following comments
and recommendations.
Air Quality Section
Ambient air sampling for dioxin should be conducted at the
site during excavation and treatment of the soil.
Water Quality Section
Water Quality has numerous concerns about this discharge and
the limitations of monitoring dioxin to the water quality
limit. Attached please find the staff report dated August
11, 1994.
Groundwater Section
The groundwater should be remediated to the standards set
forth in 15A NCAC 2L.0200.
If there are any questions, please advise.
APHjr/sbp/SWM2.
cc: Alan Klimek
Steve Tedder
Raleigh Regional Office
Central Files
Groundwater Section Files
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
. . --
SOC PRIORITY PROJECT: Yes __ No___LL
If Yes, i No .
To, '•=Hs and ,ng,ne1ltf copy
Water Quality Section ~
Attention: Jeanette Briggs
Date August 11, 1994
NPDES STAFF REPORT AND RECOMMENDATION
County Wake
Permit No. NC0084366
PART I GENERAL INFORMATION
1. Facility and Address:Beazer East, Inc.
Koppers Company Superfund Site
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
2. Date of Investigation: August 10, 1994
3. Report Prepared by:Babette McKemie, P.E.
4. Persons Contacted and Telephone Number: Robert Fisher,
Beazer, 412-227-2955
5. Directions to Site:Hwy 54 to Morrisville, left on Koppers
Rd., right on Church St. site on left
6 . Discharge Point(s), List
Outfall 001 (groundwater
Latitude: 35°50'48"
Outfall 002 (Medlin Pond)
for all discharge points:
remediation)
Langi tude: 7 8°50' 18"
Latitude: 35°50'35" Longitude: 78°50'19"
Outfall 003 (Fire Pond)
Latitude: 35°50'42" Longitude:78°50'20"
Attach a USGS map extract and indicate treatment facility
site and discharge point on map.
u.s.G.S. Quad No. D23SE u.s.G.S. Quad Name Cary
7. Site size and expansion area consistent with application?
_X __ Yes ___ No If No, explain:
8. Topography (relationship to flood plain included):relatively
flat, not in flood plain
9. Location of nearest dwelling:more than 400 feet
....,,__,,.,_ -·•-----•If Yes, SOC No. -------• • 10. Receiving stream or affected surface waters:U.T. to Crabtree
Creek
a. Classification:B NSW
b. River Basin and Subbasin No.:03 04 02
c. Describe receiving stream features and pertinent
downstream uses:dry drainage ditch, different
locations on the same ditch for all three outfalls
PART II DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted:.
Outfall 001 (Groundwater Treatment) .0144MGD(Ultimate
Design Capacity)
Outfall 002 (2A) .15 MGD
Outfall 003 (2B) .15 MGD
b. What is the current permitted capacity of the waste
Water Treatment facility?none
c. Actual treatment capacity of the current facility
(current design capacity)?N/A
d. Date(s) and construction activities allowed by previous
Authorization to Construct issued in the previous two years:
N/A
e. Please provide a description of existing or
substantially constructed wastewater treatment facilities:
none
f. Please provide a description of proposed wastewater
treatment facilities:The groundwater remediation system will
consist of one recovery well, a 1,500 gallon equalization
tank, flow meter, two pumps, dual bag filters, and dual
carbon filters. ·
The surface water remediation system will be a portable
system. It will be used for one pond and then moved to the
next one. It will be designed for 105 GPM, however design is
not complete and will be submitted with A to C request.
g. Possible toxic impacts to surface waters: Dioxin, Fur an
h. Pretreatment Program ( POTWs only) :
in development __ _ approved ___ _
should be required ---not needed X
2. Residuals handling and utilization/disposal scheme: N/A
3. Treatment plant classification (attach completed rating
sheet) :Class I
4 •
SOC PRIORITY PROJECT: yes __ No-----1,,/'
If Yes, -No._______ •
SIC Code ( s ) : 2 4 3 9
Wastewater Code(s) of actual wastewater,
facilities i.e .. , non-contact cooling water
metal plating company would be 14, not 56.
Primary 66_ Secondary _____ _
Main Treatment Unit Code: 002-0
PART III OTHER PERTINENT INFORMATION
not particular
discharge from a
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)?N/A
2. Special monitoring or limitations (including toxicity)
requests:toxicity, Dioxin, Furan and fish tissue
3. Important soc, JOC or Compliance Schedule dates: ( Please
indicate)none
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non-discharge options available. Please provide
regional perspective for each option evaluated. Discharge is the
best option for this facility
5. Other Special Items:
PART IV EVALUATION AND RECOMMENDATIONS
The RRO has reviewed the information submitted and conducted
a site visit. The project is an EPA Superfund site and is under
an EPA order to remediate the site, although no dates were
indicated.
The remediation plan calls for the rire pond to be
remediated first, followed by the Medlin Pond. The site visit
revealed that this was not practical because the fire pond
outfall will drain right to the Medlin Pond. The Medlin Pond
should be remediated and filled prior to remediation of the fire
pond. The drainage through the Medlin Pond will have to be
recontoured and reinforced in order to then take the flow from
the draining and remediation of the larger fire pond.
Alternatively, the outfall and/ drainage ways could be rerouted
so that the flow does not go through the Medlin Pond or through
the newly backfilled area.
The applicant needs to address these issues more thoroughly in
the A to C application.
The NPDES permit should be issued with three effluent pages,
one for each outfall. Outfall 001 for the groundwater should be
from the completion of the Fire Pond Remediation until
expiration. Outfall 002 for the Medlin Pond should be from
receipt of the A to C until completion of Medlin Pond
Remediation. Outfall 003 for the Fire Pond should be from
completion of the Medlin Pond Remediation until completion of the
,,., • SOC PRIORITY PROJECT:
If Yes, • No.
Yes No / -d-• Fire Pond Remediation. In this way, only one remediation project
is underway at a time. It is estimated that the remediation of
both ponds will only take a , month. The monitoring should be
identical for each system.
The stream standard for Dioxin is .000014 ng/1. The
concentrations for Dioxin in the various contaminated areas are
on the order of .03 to 5.7 ng/1. Even if the treatment system is
99% effective, the effluent will be as much as 4000 time greater
than the stream standard, The detection limit is 10 ng/1. The
effluent could be far below the detection limit but as much as
7 million times over the stream standard for human health. This
discharge is directly upstream of Lake Crabtree which is a
recreational lake. The other compound reported is Furan which is
closely related to Dioxin. The same discrepancy poses itself
with Furans.
This site is a superfund site under an EPA order to clean
up. However, if treating to safe· levels cannot be achieved, is
discharging the solution? If this permit is issued, perhaps Dr.
Ken Rudo with Epidemiology should also provide recommendations.
In addition, fish tissue sampling should be required before and
during discharge in order to track bioaccumulation. The RRO has
reservations about the is of this permit.
4
Water Quality Regional Supervisor
H:\NC84366.SR
' ...
,. •a't, ~ <''
P"o "i, .:<>0
~,:::;,==~-~-~li.a .. -Q .,_l'
'D • lr, • '•
' ,i°'t· JIil, q . -
p.;<>_'O°c,4,
0 o0 o ,• a. •Oo, o0"'~
0 ' ' 0
\ 0 ;_o'"~
0 9 ,·,1.
,· 0 ~: _"9.,g"' ~
,""<>, " ' -; o o a
.£' s O.. ,&,
P' ..;,A~ .. ~
'Of~ t, o
o::·.
'b j,', -:"' . .
-... ,,
11_,,~-,
~ ~"a .~-,;~-., o , ·g
~--·,.,, ·,t Q ~t~· ~ r'
& °'b'\O II
,, ~ ,;f II• • ~ "
,0 O' G .
WE ARE MOVING ....
RECEl\!ED
AUG 3 0 1994
suPERFUND SECTION
As of September 1, 1994, Cummings/Riter Consultants'
eastern regional office will be relocating to the following
address:
Oxford Building, Suite 20:?
University Office Plaza
Newark, Delaware 19702
Phone: [phone]
Fax: [phone]
Please make a note of our new address.
WE ARE ALSO PLEASED TO ANNOUNCE ...
The following individuals have recently joined our firm:
o Craig Marker, P.E. -Senior Project Engineer
o Judy Johnson -Administrative Assistant
o Dan Cusick -Geologist
0 Chris Tiani -Administrative Assistant
Craig and Judy will be working in our Newark office and
Dan and Chris will be working in our Pittsburgh office.
These individuals will enable Cummings/Riter to better
serve our clients and provide additional depth to our
overall capabilities.
Beazer.
BEAZER EAST, INC., 436 SEVENTH AVENUE. PITTSBURGH. P:\ 15219 USA
January 31, 1994
VIA: OVERNIGHT DELIVERY
Ms. Beverly Hudson
Remedial Project Manager
U.S. EPA Region IV
NC North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Re: Submittal of Habitat Mitigation
Preliminary Remedial Design
Koppers Superfund Site
Morrisville, NC
Dear Beverly:
Reference No. 179286-00
RECEIVED
FEB O 11994
SUPERFUND SECTION
In accordance with the Unilateral Order dated April 21, 1993 between U.S. EPA and
Beazer East, Inc., enclosed please find five (5) copies (one unbound) of the report
entitled "Remedial Design, Habitat Mitigation Plan, Former Koppers Superfund Site,
Morrisville, North Carolina, Preliminary Report, January 1994," prepared by Chester
Environmental, Inc. By copy of this letter, two (2) copies of the report are being sent
under separate cover to the State of North Carolina. Based on your discussions with
Beazer last week, it was agreed that this report can be sent to you via overnight
delivery today.
The report presents the preliminary design of habitats for a site known as the
Seagondollar property. The selection of this property for the mitigation resulted from
discussions with the local representative of the Wake County Soil Conservation Service
who had been working with Mr. Seagondollar to create a pond on his property. In
addition, a site reconnaissance of four properties including the Seagondollar site was
conducted by my consultants in November. At your recommendation, we met with
Tom Augspurger, U.S. Fish and Wildlife Service, Raleigh Field Office, to discuss the
approach to be used for the Habitat Mitigation. The result of the discussion and site
visits was the selection of the Seagondollar property for the development of the
preliminary design for the Habitat Mitigation.
We look forward to your review and U.S. EPA' s concurrence of the suitability of the
property for implementation of the Habitat Mitigation. Please direct your review
Ms. Beverly Hudson{D
Submittal of Habitat Mitigation •
comments to me. If you have any questions regarding this submittal, please do not
hesitate to call me at [phone].
Sincerely,
~ XJ;.:?4 ~
Shannon K. Craig
Program Manager
JCM/BB/DCC#R0601LET
Enclosures
cc: Mr. Bruce Nicholson -North Carolina Superfund (two copies)
Mt. Jim Cook -Beazer East, Inc.
Ms. Cindy Zuch -Beazer East, Inc.
Mr. John Mitsak -Chester Environmental
Mr. Tom Augspurger, USF&W (letter only)
. _:y:f~1 . ··-,• .
.. ·' ~ -;;--:-. -
' •, 4 ~ .,
( ~-·,•-
... ~:,2· •·:: ·. >: '·-,,.
UMMINGS
'/TER
CONSULTANTS, INC.
Ms. Beverly Hudson
Remedial Project Manager
North Superfund Remedial Branch
Waste Management Division
USEP A Region IV
January 28, I 994
Project No. 93-145
RECEIVED
JAN 3 1 1994
345 Courtland Street, NE
Atlanta, GA 30365
SUPERFUND SECTION
RE: TRANSMITTAL OF PRELIMINARY DESIGN REPORT
SOIL, GROUNDWATER AND SURF ACE WATER REMEDIATION
KOPPERS COMPANY, INC. SUPERFUND SITE
MORRISVILLE, NORTH CAROLINA
Dear Ms. Hudson:
On behalf of Beazer East, Inc., Cummings/Riter Consultants, Inc. is pleased to submit for
your review the Preliminary design Report for the soil, groundwater and surface water
remediation at the Koppers Company, Inc. Superfund Site. Enclosed are five copies of
the report and one full-size set of preliminary construction drawings, per your
instructions. Two copies of this report were sent directly to Mr. Bruce Nicholson at the
State of North Carolina. The Preliminary Design Report for habitat mitigation is being
submitted under separate cover.
Respectfully submitted,
Cu iter Consulta s, Inc.
William C. Smith FOR.
Project Manager
WCS/dmw
Enclosures
pc: Mr. Bruce Nicholson -NCDEHNR
Mr. James Cook -Beazer East, Inc.
Bellevue Building, Suite 106 • University Office Plaza • Newark, DE 19702
[phone] • FAX [phone]
1257/projects
,. • •
October 21, 1993
MEMORANDUM
TO:
FROM:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
RE: Koppers Company Inc. NPL Site
Morrisville, Wake County, N.C.
Overview of Pre-remedial Design Field Work
Overview of pre-remedial design field work was performed at
the Koppers Company, Inc. NPL Site on 19 through 21 October, 1993
by the NC Superfund Section. 2 shallow and 1 deep well had been
drilled and cased with the air rotary drill rig late last week and
during the week end. The shallow well installed to a depth of 65
feet in the area behind Crowders construction property has remained
dry for several days and a conference call with EPA was scheduled
for 4:00 o'clock wednesday afternoon to discuss whether installing
an additional shallow well is justified. While drilling a second
deep well the engine of the rig broke down. The next day and a
half, for the drill crew, was spent moving the broke down rig to
the road for towing and waiting on a replacement rig. Drilling of
the second deep well with the replacement rig began late wednesday
afternoon.
The Black and Veatch oversight person,· Mary McClain, was
replaced by Ed Meyer.
Sampling of some 55 gallon drum debris was performed Tuesday.
55 gallon drums and surrounding soils were excavated during
construction of the gravel roadway and are being stored in roll-off
containers on-site until a disposal location is determined.
A chain-link fence is being constructed around the fire pond
and adjacent contaminated former lagoon, cellon and sandfilter
areas in order to restrict access.
On Tuesday authorization was received by EPA to proceed with
the groundwater sampling of the existing monitoring wells located
on the adjacent Unit Structures property. Sampling of the wells
located on Unit Structures property is scheduled to begin on Monday
10-25-93 and should take approximately 2 weeks to complete. Gordon
Otool with Chester Environmental is in charge of this work and
Laura Morrison with Black and Veatch will provide EPA oversight.
The deep well was completed
93 and the 8 11 casing was set to
below ground surface. The total
170 feet below ground surface.
as planed wednesday evening 10-20-
a depth of approximately 120 feet
depth of the well is approximately
Well screen and casing was not
..
Ms. Hudson
10-21-93
Page 2
• •
installed in the deep well. Therefore approximately 50 feet of
very dense to extremely dense siltstone is open below the bottom of
the 8" casing. Concrete pads and locking protector covers were
being installed around all 3 wells in this area.
I arrived on site at 1:30 Pm 10-21-93. The installation of 1
additional shallow well in the area of the shallow ( 65') well
located behind the Crowders Construction Co. property was
authorized by EPA as noted above. Set-up and air rotary drilling
of the additional shallow well began around 2:30 Pm 10-21-93 and
was completed around 5:00 Pm. The primary soil and rock type noted
and sampled by Chester Env. while drilling the well was maroon
weathered to unweathered siltstone and siltstone conglomerate. The
Koppers site is located in the Triassic basin formation. Siltstone
and siltstone conglomerate is typical of this area. Stainless well
screen and casing was installed and the well constructed to the
surface. A concrete pad was being constructed around the well and
a locking protector cover was being installed.
Photographs of the work being performed during these overview
field trips will be included in this State Superfund file.
•
October 15, 1993
MEMORANDUM
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Koppers Company Inc. NPL site
Morrisville, Wake County, N.C.
Overview of Pre-remedial Design Field Work
Pre-remedial design field work was performed at the Koppers
Company, Inc. NPL Site on 12 & 13 October, 1993 by the NC Superfund
Section. The drillers were setting-up to perform soil sampling in
the former lagoon and cellon process and sandfilter area located
just northwest of the fire pond. Charlie Wingered and Jeff Root,
Chester Environmental, were setting-up to perform monitoring,
sampling, soil classification and logging of the samples. Layne
Environmental services was performing the drilling at the site.
Layne personnel consisted of a driller and 3 support personnel to
perform decontamination of the drilling and sampling equipment.
The drill crew is using a Mobil B-52 drill rig and hollow stem
augers. An air rotary drill rig will arrive later this week to
install additional shallow and deep aquifer wells to the east of
the site. Mary McClain, Black and Veatch Company, was performing
EPA oversight of the drilling activities. A Beazer employee was
on-site setting-up the contractor to establish perimeter fencing
for the fire pond and adjacent contamination areas.
Profiling of the fire pond was also underway at this time. A
raft was being used to perform this work. Tom Hilton and Tony,
Chester Environmental, were in charge of surveying and profiling
the ponds. 2 surveyors, Thom Avery and Jonathan Murphy with Murphy
Hobson Sacks were assisting Tom and Tony in establishing the grid
and sounding of the ponds. According to Mr. Avery they had been
surveying the ponds and well locations over the past 2 weeks prior
to Chester Env. arriving on-site.
On Tuesday the Chester Environmental personnel were not
monitoring the ambient air for drilling and sampling procedures.
This was brought to the attention of the B & V oversight person.
The following day air monitoring of the soil samples was being
performed with an HNu meter.
On Wednesday surface water and sediment sampling was
authorized by EPA and the work was started in the afternoon. Mr.
John Metsak with Chester Environmental and Cynthia Zuch with Beazer
Inc. were on-site also overviewing the work.
Photographs of the work being performed during these overview
field trips will be included in this State Superfund file.
• •
State of North Carolina
Department of Environnient, Health, and Natural Resources
512 North Salisbury Street• Raleigh, North.Carolina 27604
James B. Hunt, Jr., Governor Division of Solid Waste Management
· Telephone [phone]
October 1, 1993·
MEMORANDUM
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Koppers Company NPL Site
-Jonathan B. Howes, Secreta1y
Soil Delineation, Preliminary Remedial Design Field Work
In a telephone conversation with Beverly Hudson, EPA RPM for
the subject Site, it was determined that Chester Environmental will
be mobilizing to the Koppers Site on October li, 1993 as noted in
the letter from Chester Environmental to Beverly Hudson dated
September 17, 1993. Beverly stated _that a detailed schedule of
events would be faxed to the NC Superfund. Basically she stated
that Chester would mobilize:
-Monday October 11, 1993
-Establish a decon. area and verify site bench'mark data on
Tuesday
-Establish soil sampling grid
Perform soil sampling with drill rigs
-Install additional groundwater monitoring wells
and groundwater sampling during the last 2 weeks on site.
The work is scheduled to be performed during a 3 to 4 week
period using 2 drill rigs.
cc: Jack Butler, NC Superfund
Bruce Nicholson, NC Superfund
PO !~ox 27687, Raleigh, North Carolina 27611-7687 ·1t:lephorn: 919-733-4984 f:.1x # 919-733-0513
An Equ.11 Opportunity Affirrnativc Action En1ploycr
.,
Lf{j]DtfJ{;:!j@[]~' [}JLfJ[J]~
Htl;fttVt.U
OCT O G 1~::U
SUPERFUN~SECHON
CASE NARRATIVE
Analysis of Samples for the Presence of
2,3,7,8-Tetrachlo;-inated Dibenzo-p-Dioxin by
High-Resolution Gas Chrom:,tography / High-Resolution Mass Spectrometry
Date:
Client ID :
P.O. Number :
TLI Project Number
METHOD 1613A (10/90)
October 01, 1993 (REVISED OCTOBER 2,1993)
PRC ENVIRONMENTAL MANAGEMENT. INC.
25378
Rev. 09/02/93
Triangle Laboratories of RTP, Inc.
801 Capitola Drive P.O. Box 13485
Durham, NC 27713 Research Triangle Park, NC 27709
919-544-5729 Fax# [phone]
,•.
Triangle Laboratorie.RTP, Inc.
Case Narrative ~
Overview
October 01, 1993
25378
Two water samples were received (in duplicate) from PRC ENVIRONMENTAL
MANAGEMENT, INC. in good condition September 29, 1993 and stored in a refrigera-
tor at 4°C. The samples were extracted and analyzed according to procedures described in
EPA Method 1613A (October 1990) and in the Triangle Labs User's Manual. Any par-
ticular difficulties encountered during the sample handling by Triangle Labs will be
discussed in the QC Remarks section below.
Quality Control Samples
A laboratory method blank and an ongoing precision and recovery (OPR) sample are in-
cluded with each batch of samples. •
oc Remarks
This analytical data has been released after being subjected to a series of inspections.
General deviations from acceptable QC requirements are identified below. Comments on
the effect of these deviations upon the validity and reliability of the results can be ob-
tained from TL!' s Data User's Manual. Specific QC issues associated with this particular
project are:
Sample Receipt: None
Sample Preparatio11 Laboratory: This project shares a common blank and OPR with TL!
project# 25206.
Mass Spectrometry: None
Data Review: All samples of this project present a quantitative interference which co-
elutes with the labeled recovery standard. For the OPR, TL! blank and sample 047-1126-
001 the interference will only affect reported percent recoveries for labeled standards and
analyte quantitation should be unaffected. For sample 04771126-00lFB the interference
elutes with both the recovery and the internal standards. As a result, reported detection
limits, minimum levels and percent recoveries are compromised to some de~ree. Data for
this analysis should not be considered to be reliable. The results for the initial analysis of
sample 047-1126-00IFB were released at the request of the Client Services Manager,
Valerie Evans. However, the sample was processed through additional fractionation in
an attempt to remove or lessen the affect of the quantitative interference. The reanalysis
(after the additional fractionation) had no quantitative interferences. The results from the
reanalysis should be considered reliable and should be used instead of the previously .
reported results.
Ge11eral Comme11ts: No 2,3,7,8-TCDD was detected in the TL! Blank above the target
detection level.
2
Triangle Laboratoriea{-RTP, Inc.
Case Narrative •;
October 01, 1993
25378
The detection limits in some samples may be above the Target Detection Limit due to
Method 1613A reporting format which requires that GC peaks which do not meet QC cri-
teria for ion-abundance ratio be reported in the detection limit
By our interpretation, the analytical data in this project is valid based on the guidelines of
EPA Method 1613A and Triangle Laboratories' Method 1613 Data User Manual. Any
specific QC concerns or problems have been discussed in the QC REMARKS section
with emphasis on their affect on the data. Should PRC ENVIRONMENTAL MAN-
AGEMENT, INC. have any questions or comments regarding this data package, please
feel free to contact Valerie Evans, Water Quality Client Services Manager, at (919) 544-
8353.
For Triangle Laboratories of RTP, Inc.,
Data Prepared & Reviewed by:
Stuart JefferysNijay Chhabra
Report Preparation Chemist
3
Quality Control Performed by:
-' Report Preparation Chemist
Data File
Sample ID
Units
.ANGLE LABORATORIES OF RTP, IN.j
Sample Result Summary for Project 25378
1613A TCDD Analysis (DB-5)
T934663
OPR AQUEOUS
PG/L
T934664 T934665
TLI AQUEOUS ELA 047-1126-00lFB
NK
PG/L PG/L
Page 1
10/02/93
-=====================------------------==================-----=====================-
Analytes
2378-TCDD 164 < 5.0
Other Standards Percent Recovery Summary (% Rec)
37Cl-TCDD 79.4 81.5
Internal Standards Percent Recovery Summary (% Rec)
13C12-2378-TCDD 82.9 66.0
< 5.0
82.1
73.9
---==========-====-------------------------==--==-=====--------==========------------
(Concentration of GC peaks out of theoretical isotopic
abundance ratio range expressed as a detection limit).
Minimum levels are reported for non-detected GC peaks.
•••••=INTERFERENCE
Triangle Laboratories of RTP, Inc.
801 Capitola Drive• Durham, North Carolina 27713
Phone: [phone] • Fax: [phone]
Printed: 11 :54 10/02/93
C! ... -. l o·
··;1u / :') ll ;
::11 -~iJ l l tL1 :J'Jr,.1:.1 .I ,·i :: :·_1J'.:
. ;Ill..,..· Cit1 ,
· :.: :=J.1\,T.J':::-=11 -,
•. 1 !ll . :'. I! I
Vi:•_1·:1 ii.1 ·_!:·_ii·.P.,i!,:.:_::: __ 1:_;~:
1.(; ~C• : ·:w I! ~-'. '; .. '. -!1:i,',I\,.·
i:t/1.·.: I : J l,}-_:11 :";: ! ·-:_,\ "!-:-',):,<
~ t 1,h_i i-!U f ; :1Uti .! ·
-~~OJne·J~ .:(i~L~W
:.,•:~ ·t '?"f nu:-i: ·_:l.:
·; l "HY: ];J ~ ·1,_~w:7·~
·11u_/bu)
I_ ] IU ; ;""", 11 1
1-1 i ~jl,:: ,'.1 l i•! u ~)
ii : ~ :,'.'.}i
n1.-:
l .) 3 r· :),~,-J
iJJ!~O:., 1
TRIANGLE IABORATORIES OF RTP, INC.
Rev. AH • 9/93
DOCUMENT
CONTROL
\ -
'il CIIAIN OF CUSTODY SAMPLER'S SIGNATURE;
=·J
co, NAM.Iii.I CONTACT N"MG:1 NO,OF ANALY9 I B WANTEO
AODAE9Bf PROJECT NAME/)t\ CON-
PON I TAI NEAS r
\ \ ----
PHONE " : ,___,,
AEMf'f'lK~ -
9TA NO, DATE TIME COMP GRAB SAMPLE I, 0, H
I 1·.2 ~ -
1-:Zf-f ---
'f.-___ p~,1-q-
OL/7 -112c-.ci.ec)' -oe,J_ .2_
J 1-Z !-1~ 'I. o</7-1/Z 6' -oo_L r.C, z_ •
-
j
~QUlo/~1 SIC.N, □ATE /TI ME AE:CEIVEO SY I B 11GN, RELINQUISHED BYIBIGN, DATE .,,, TI MEi RECEIVE □ BY1 9 I ~ ,.. ,V/,;,""-----/u -4. _;;;;I-1-21-15 ' /
RELINQUISHED SY1 9 I GN, DATE /TIME RECEIVE BY: 9 I GN, RELINQUISHED BY1SIGN, DATE /TIME RECEIVED BY1 BI
C.NJ
RECEIVED FOR LABORATORY BYISIGNATUAE OATE/Tl"'1E SEND SAMPLES T01 TR I t='\NGLE LABORATORIES OF ATP, I NC, ] t5 /£_ I 7hC-;,.t~c::h 901 CAPITOLA DRIVE --~ -i L v .. ·, □UAHf'M. NORTH CAROLINA 27713
FT2/COC I :,✓21/92
. . PAGEIO'l
-------------------------------------------------------------------:·t----------~---------+------------------------------------+------+
Custody Seal ?resent/Intact ! Tl! Project Nu~ber : 25378 Book '
Chain of Custody Present +------. ---... ---. --+------------------------------------+
Sa~ple Tags Present ' Clfent: )RC01 ,. ·: PRC ENV!RONHESTAL HANAGEHENT, INC. : 71
sa~ple Tag Numbers : listed . :·.-.. :-: .. · ~------.,::, .. -· · ----+-.-----------------------------------+------+ ____ '.~~-:~'.~=------------~-~~=:~: ______________ . ___ _ ___ _ , _ .·.;_Date _ Rece-ived • .. __ ;_~:(~:'.:: __ l-~~~-~~ ]
Ice Chest Ice Te~p 10.0 F : Carrier and iumber : FRANK BRYANT I '
--------------------------------------+-----------+-----------+--. --------+-----------+---.. ------+-----------+-----------+-----------+
Tl! Number Hatrix : To LAB : To STORAGE: lo LAB . : lo STORAGE: lo LAB : To STORAGE: To LAB : To STORAGE:
. Client ID Location : Oate/lnit : Oate/Init: Date/Init ; Oate/lnit : Oate/Init : Date/lnit : Oate/lnit : Oate/Init :
: --· .. ----. -----------------------------+-----------+-----------+-----------+-----------+-----------+-----------+-----------+-----------+
'7141A" 'l'A"'ER' t I I l ! I 1 I ' --~ ; ,, 04i -1126-001 'I ;1l;rJJ~71_~Jj:J-1H..2_; ___________ ; ______ ~ ____ ; ___________ ; __________ ,; ___________ ; ___________ ;
-----------------------------=~~: =~, ~ _ ; ___ Tu_t ~l-~-__ S1s_; ___________ ; ___________ ; ____ . ______ ; ___________ ; ___________ ; ___________ :
7i-l-lB •11::, I I ' l t I I I I I I n '-" I I . I • I I I I I 1
_____________ :~~~::::~::: ____ =~~:::'.'._: ___ ~~ -:. -l--. -/------;---~~------!-----------:-----------!-----. ----\---------_!-----------1
71-~-2A WATER: I I ! I I I I 1
' 047-1126-00lFB COOLERJ2 ~----------~---i-------~-----------;-----------~-----------~-----------~-----------~-----------:
·-,i-4-18-----------------------~!TER-;----_-----;----------;-----------:-----------~-----------;-----------;----------;-----------;.
' 047-1125-00iFB COOLER'l ;---,!--~::--;--[;------;-----------;-----------;-~---------;-----------;-----------;~----------:
1'1•3/;;-·1y 1 I 1\ I I I !
·-----~-------------------------·----+-----------+-----------+-----------+-----------+--;---------+-----------+-----------+-----------+
.. I I I I I I \ I
t I I I \ I ! +---· -·· --. ---+-----------+-----------+-----------+-----------+-----------: -----------+-----------+
I I ··.!
' ' ' ~------------------------------. -----+-----------+-----------+-----------:-----------+-----------+-----------+-----------+-----------+ I / l ! ! I I .,.;-_! .· I I I I
I I I I
+-----------+-----------+-----------+-----------+--· --------+-----------+-----------+-----------+
I -1 ·
' ' ' ·-------------------------------------+-----------+-----------+-----------:-----------+-----------+-----------+-----------•-----------•
' ' +-----------+-----------+-----------+------------+-----------+-----------+-----------+-----------+
' ' I I I I I I I I
--------------------------------------+-----------+-----------+-----------+-----------+-----------+-----------:-----------+-----------+
' ' ' ' +-----------+-----------+-----------+-----------+------· ____ , ________ . --+-----------+-----------+
' ' --------------------------------------+-----------+-----------+-----------+----------,+-----------+-----------•-----------+-----------t ' ·, I ! I I
+-----------+-----------+-----------+---------· -+-----------+-----------•-----------:-----------·
' I
--------------------------------------+-----------+-----------+-----------+-----------+-----------+-----------+-----------.-----------· ' ·, l I •• t
+-----------+-----------+-----------+-----------+-----------+-----------•-----------+-----------+
' ' --------------------------------------+ ·----------+-----------+-----------+-----------+-----------+-----------+-----------+-----------:
Receiving Re~arks:
'
-----------------------------------------------·----------------------------------------•--------------------------------:
~.~:r,1-...-e P.er1an.s: . :
TRIANGLE LABORATORIES OF RTP, INC.
HIGH RESOLUTION SAMPLE TRACKING AND PROJECT MANAGEMENT FORM
-------------------------ADMINISTRATIVE
TLI PROJ.: 25378 SAMPLES: 2
PROD CODE: D28401 TYPE ... : C
INFORMATION-------------------------
TURNAROUND.: 2 DAY(S)
HOLD TIME .. : 0 DAY(S)
METHOD ... : 1613A:2378-TCDD ONLY
AQUEOUS
DRINKING H20
MATRIX ... :
DETECT LM: 5 PG/L
RPT REQ .... :
RPT FORMAT.:
Report Option II
1613A
CLIENT ....... : PRC ENVIRONMENTAL MANAGEMENT, INC. {PRCOl)
P.O. NO ...... :
CONTACT ...... :
CLIENT PROJ .. :
COLLECT DATE. :
ERIC HESS
NA
SeeCOC
PHONE ... : [phone]
PROD. MGR .. : Valerie Evans
ORIGINATOR.: DHW
-----------------------------PROJECT TIMETABLE------------------------------
UNIT IN DATE ACTUAL OUT DATE ACTUAL
RECIEVING 09/29/93
WET LAB 09/29/93
HRMS LAB 09/30/93
HR RPT PR 09/30/93
SHIPPING 09/30/93
09/29/93
09/30/93
09/30/93
09/30/93
~ 10/1/C,::,
'/[:J.'i/'/-0, ' '
----------------QUALITY ASSURANCE / QUALITY CONTROL SAMPLES-----------------
TLI BLANKS ... : 1
OPR Count .... : 1
SPIKE FILE ... : SP161F2S
DUPLICATES ... : 0
MATRIX SPIKES: 0
MS DUPLICATES: 0
WS:
MS:
RS:
CONC VOL
0.100
0.010
100.0
NG/UL
NG/uL
PG/uL
20 UL
20 UL
20 UL
-------------------SPECIAL INSTRUCTIONS/ QA REQUIREMENTS-------------------
JOINT PROJECT {LOW RES) ... :
JOINT PROJECT (INORGANICS): PRESPIKE STANDARD: NA
PREP PROJECT .............. : PRESPIKE AMOUNT .. : 0.0
WET LAB .... : Low Level EXTRACTION EXPIRATION DATE.: I I
I I TEF ........ :
CONFIRM
NO
% MOIST
NO
ANALYSIS EXPIRATION DATE ... :
PCT ORIG EXTRACT TO GC/MS .. :
ANALYTE CONCENTRATION UNITS:
I C,Ll 1/o
PG/L
% LIPID
NO
% SOLID
YES
DRY-WT
NO
I-FILES
NO
ICAL CCAL
NO NO
SPECIAL INSTRUCTIONS: \_;-j 12...-\-lo._.L:, SOP 1) Sf' d 3 S
SIGNATURE: ~) DATE: (PMGTH0893)
houR /)9
• •
Date
01.9..'1/q,
1('2,,J/4'1
1/7,/J/t/3
10IJ1.,__
I '
10/,/0:')
I
\QI I /93,
' I
I
TRIANGLE LABORATORIES RTP, INC. [PSTMF 2]
PROJECT COMMUNICATION TRACKING FORM
TLI Project Number: ldS-3 rrl ,·
Use this form to record all exchanges of information between production
units as we 11 as personnel handling this project. Decisions, corrective
actions and recommendations must also appear on this tracking document.
Name Comment I Decision I Resolution I Action I Obseservation
Qs, ~' ni+ 1-Q_e>,,,oc-v ~~-( i...,_; :J. L ~)
I -;r· I :i 'S;;, I) l() r~tc-~___., oZ,
)liy I -y,,,i;;,,_L. ,-,, ),_ '7 j,_a.. ,::.&, II ~ -. ~ A
J!JJ0.· II
10,Prn ,/4e)v"! -. /),,) f .. :ii, J -t-C, d,,,,,,.~v-,,,,.l,A ,,,,·-~ l.,_"' u I -.J IL.,,,::.J!.-
;,
tA~ 1ci.z -"'"'·"( () v..&..J, -, rJ/ . J i . c--e.-ul.
/ V / I
C:::.. t; a~.n 12, . .,./ r':) 7 --/;; I ---:.;. __,,.,-~ /1/ . . .,ti,.;{ l~-v,.....l.,-~ ·-. ,t."'v' ,--a ,,.,,~..,,..
'" , , I <..,--~i. • ; /'<h.f,s/ ",+.-. I /,1,,.1,I-,;} -. ' /h-(J-V ...... ~ .},Git /l-'1 't.1_
V 17 I j'
( o'/-1 -uzb -cq i::~ \/ ((t,•,·e+
,/ hrv N 'k~t MS Ol( Cl<le ';,( Lurfcc.l:..( '/iu.:C,
' --
A-sAP
tJf.;."'f?-1 !l ~-t\:--,..,, 1-1~ 0,.---/ -_, --.A--QLl, . 112L,-,):11 -I , ' I ;
/'\,,n ()I, )_ A 0 , D,-, I • _.t.,,( -(2_p -!, + r;Pif' -.
I' I
/) 6, -P,l..-r)c1-, -I I ') I. · 001 F/3 _g_ -0 .,.---..../ ., I .• ( (2_,
' 'I J~ -(,I '' T A --~ = ., . -·---...
u ()
1J ,'tu""'-"-Pl.<'-"'-"--:J.--,..._._.,? O'-/ -llL\... ~CH.:_;!f'8 ,k.~-,,-j. c-\.a..{r~. c~ l'\"-.CI
LJ
··:;kl_ o.fl,, ~c\ le,~ C' -.; ,__ Oc. A.,:,-C.-, cl,o..~J__ ·-, l·\..,U·. t (. ,\__ \.,u_,_
LU l)
. I cl{.., I\_,'-<.-, Jo (,\ -. Cc...v.i-L l)n...\.... ... <,._,~...;;_.. 7'h.'-""'-C"-'--'ll.L -'-4-\.-" ,._t 1,,1.• • t ( '--
LI,_ ~ SL\C..V ,;,...._
I (G':, r ,\.G .'-,\J--..,·' 1 r .l( CL\.--l-,, In<-< k, Cv..~-"._.<ll_ ~ I\., C'_C_> ~ ~, ~ "'--,_;,
I "
-c,&.11.-t,-,J. c~.c._,.__, .... L .• :;, / n.s.' ...... Ct---L1. .. \,L-\f4.:.,_; ' LLQJ la. \slv .v CC., r,l "-
' I 'A.)J.;\ 1.."-\...., ,,lt«-•J.(_ A-o\e. \.2.I ... 'h c0 alct..0. ()C't,>,''-C\.<, ~t:., ~v c....,'--1..._u_l;~-
~'{ .. ..\ c~~''"'°'J, ·c. .. \it.........__ , __ .., 112.i.:•,\...i-1,~c\ ~
I ~
Rev 105 1/21/91 I • •
ii II I!
!I ii
ii
II
!I
II
I TRIANGLE LABORATORIES RTP, INC. I [PSTMF 4]
SAMPLE COMPLIANCE AND EXTRACTION, CLEANUP TRACKING FORM
TLI PROJECT No.:
II P~c CHROMATOGRAPHIC CLEANUP
Wet Spike·
Lab before
No. fxtr. · y:_
Extr. Spike
after
1..xtr.
~.,.M'
f,1 SP---lt1.S
Acid Large Escal-AG4 Flor-Piggy
Base Acid ated 6 gm isil Back
Biosil
I
\. i
' I '-i'
L I
II
fl
Ii
II
:1
II
II
-,
Carbon Transfer ·
Column
,I
<
~ ..._ 1 /:J1 I ,7-~
'
;< ... ,J '""' _,,,· BEL 'p':)
Pl~se enter date and initials. Initial indicates SOP's was followed.
~*beside initials indicates deviation from SOP's documented on Project
Communication Tracking Form.
Comments
REV 104 5/23/9l_J
• •
/c:;/1('"1
l
l
QS I
Percent Moisture
PRO,JECT:
TRIANGLE LABORATORIES OF RTP. INC.
Init.i.al1:
:--------------------------------------------------------------------------------------------------------------------------------~
·s-1111ole~ TLI I Wt \/1al t Wet I Emotv Vi,:d I t..,.b"'11al ~ Orv '3amole 1 ~ Mn1stur~ : , ::,Gild 1
1 ~ crrll s:iMPLE ID I r.ut~T : So1mole : Wei ant 1 ~ ... 3o-q31 2 1 ) : 1 1
~✓j_S"::i. (:j (o (9; --------------------------------------
'.000 '. OPR WATER
OPR HPLC WATER :
;~~;---;-;;;-;;~;;----~i-si-;c:;-~--------------------------------------------------------------------------------,
TL I WATER 8LANK '.
+--------------------------:-----------------------------------------------------------------------------------------------------+
'002 '. )!+!A ~ lS:loiv j-n, o<I-( : : '. ' ' ' '
, , ,i,1-1w-001 ':J.5,0::,SCj :15,o').1.J.' /'!>.Ofi{'j ' : : : ------------------------------------------------------------------------------L._________________________________ -------
'00.J '. 71+2A
; ______ '. __________________ ~'. '.::: :~: '.'. :~". _ '. :7:~~'. ::!.~'_( ~-_ '. !~:-~!".?_~:Ji: 2 ~ 3.~-__________ '. ___________ : ________ ----_: ------_ --;
·--·········--------------------------·····················--------------------···················------·······-·--·--···········+
----------·---·---·-------------------------·-·············--·--···-····-t
.--------------------------------------------------------------------------------------------------------------------------------+
··-···-···············--····--·-···························-········--···--·····-···-········-·····-·-·····--··-····-'
······-··········-····-·-····-···-·····--···············---···········--·-·························-·······--·-·····-··-·-·-····-~
-·······--··············-···-------··~
• •
------:--------------------·-·-------+-------·-:---·--··-+-··--··•-:••-·---------+-----·-------:-------------+-----------·-+---·----;
·------+---·--·-------·-·---··--------+---------:---------+---------t-------·-----+---··--·--·-·•------·-·-·--•·-··--··---·-'.·--·--·-+
··--··-~-------·--···········--······-+·········+---·-··-·+--·-·····•----····-!···•·············+·-··-··-·-·•-;-... --.......•....... _t
----··:••--·--···-·········---······-+-··--·-·-•···---·--+-···--···+······---···-+-··--··--·---•--··--·-···-·+---------·-•-:--•-··--+
Gross wei9ht of samnle container t 5amole before/~fter alinuot removal Indicate below the TLI Identification Numher
1 of the S.:imnle Fortification Sol_1.1J.!ons:
IISF·AIS:_ ci,:l:,_-103 ··1 C. :?_·.-:, t 1--e ,7;:i-:;;7:-,-T--c.-1 "'.i 1, ... ../1 1_~80RATORY ID: LOW
lni t.i,l/D,te 1 LOT ~ !Solvents!:
for en.racr.ion:
lNITIALS OF 80TH THE SPIKER AND OBSERVER MUST BE ENTERED.
············································································································REV 07/1q/9! IPSTMF ll··t
• •
C.M;[ l :)F 1 ·····················-··············································································································· TRIANGLE LABORATORIES OF RT•. INC. Me!hod: _Jb.L!..}__ A°'lvsis: _? 319 ,e-c-,o HR GCIHRMS ANALYSIS Re1Juired Detection Limit.: _______ _ +···················+ I PROJECT: 25378 ············-··-·-················---····················-·············-·······-·--·--·-····-·-···-·------·--·-···-·······----. ' SAMPLE INFORMAT!ON RS i" J • ISTCOLIJMN 2t!OCOLIIMN ., CONC.Q•J~/,,,,_/;,, + · ................................................................................... £,ff· ·J_P.,;r;?. .. 3).L Y.Lq l .......... :. ::: ....... + ' ' Ill ! : GC/MS FILENAME: ANALYST :CONFIRM :cOIIFIRM FILENAME :ANALYST :usF·RS jJJ :11sF·RS/OO!ANALYSIS: :si.crct: SAMPLE ID I CLIENT : COLI/MIi: ------: !NIT. :YES/NO :cOLI/MII: _________ :rn11, :voLIIME21l/Y :111!1. !COMM[IIJS! ·' SAMPLE ID ' : OAT[ : ' :om :sOLN IO :oATE : : •••• ···•••••········••••••·••·••·••• • •••·•••·••••••••••·•• ·•·•···••••••••••·· .. •·• ••• • ··· •·••• ••••· ·1 • -11 :,: -·r /_;, · 1/s-·/ fJ .... · · ···: ' : OPR WATFR : : ,,}-:jse< ,~' · : 5l /-: : : :ooo : · OPR HPLC WATER'. /,/ ·"-: ':(e:,::,"" ~1~,;~,.J·1V"" : ; ,ts·:= : j : , ....................................... ,:.t'.-L .... ~•·······='·•p-r-"•·······························i·························, ' : ill BLANK : J ~°,.1 ~"!' D()Q_ -;-1'Z3'<~3 ' ' : ' : "'01 ' Ill '' TER 8LAN' ; ":, .,,,• L ; ' / ' ' ' ' ' ' ''· . ,A '· ' "(,,o" .__., T9 ?dC,u'-' ' . ' ' . . :·········································· ··oVR ··················································································, , 1 71·4·1~ 1 I I I 1 1 , : '7" 1 , '/1)) ' 047·!12A·001 ' -· H'." '.,, ' ' ' ' ' \ ' ' .'.. · ... ' ........................ · ......... / "'.:> :f.lo' ,._.... ........ · .......................................... i·········· ··········--·, , 1 71 _ J • 2A 1 1 1 i 1 1 : 1 1 .oo~ 1 on•u2t.-OOiFP. 1 •7c17;,~L1":S -rfwr..,~~ 1 1 V 1 \} i 1 ·---··--·--··---·······---········-----··-----···-·-------·---····················-··-·······----·-·--·-···---···-···--·--·--·····--·+ ·-·--··-···-··--········-·--··-············-··········--·-·---··-----·······--··-·--·-·-·····-················· ······--························-········-··········--··········--··-·----···-··········-··········--································+ ························-········-···············-·-···-····················-····-···················································+ ············-···-··-··---···-···············-··•······-··········-·····--·····-··-----···········-···-···········-·--······-····--···+ ·-······-······-···-··-·····--·················-·-·····--····-·-··························-············-···-····--······· . ' ············-··-····················-·····---······-·-··-···-·-····-·····-·····--·················-············-···········-· ' ., ············-····················-···································-············--·····-······················-····················, ·········-······-································-······--············--·-··-········-·-·····-····-·--····--·-·-·-·····-·············-SPfC!Al INSTRUCTIONS: ----------------------------------------------------------------------------REASON FOR REWORK: -----------------------------------------------; : DATA ARCHIVED/SHIPPED ·············································································································AEV OJIOJ/q3 IP$1Mf 61··1 • •
IRIANGLE LABORATORIES OF RIP. INC.
PCDDIPCDFIP8DDIP8Df SAMPLE TRACKING I HAN!GEMENi FORM
SAMPLE EXTRACT INFORMPTIOI
Extr~ct Chain of C11stodv
IPROJECT: 25376
'------+------------+--------------------:-----------+-------------------+---------+-------------------+-----------------------------+
:TLI :FROM WET LAB :rn MASS SPEC l.A8 :10 ARCHI'IE
:sn.crd:SAMPLE ID :DATE ANO TIME :rnl1IALS :DATE AND TIME :rnl1IALS :DATE AND TIME :coMMENTS
:SAMPLE RELEASED :SAMPLE ACCEPTED :SAMPLE ARCHIVED '.------'.--s~:gm~-z:,1--@-~-----------'. ___________________ '. _________ '. ___________________ '. _____________________________ '.
; 000 ___ ;QPR_ WATER ___ ; ___ )o '(j ),?i) ;_ I? (L, ; ___________________ ; _________ ; ___________________ : ________ · ____________________ ;
: : ~:J..s .),O(o (/') . : : : : . '
_IOQl !TLI 8LANK , 1-.! I ! ! I I
~------,------------+-------------------+----------t-----------------·-t··-------+-------------------+-----------------------------+
/ I I I I I I
'.•10_? ', 71-,-1, I ; ; i,1 ll,[ti? ; V l/ ; ; : ' • .. • · -I ,.., · · ·1" rci;., • , , ·
-----+-----------:---------7· v----;-------. ----I_-. -,, :------ ---:-------------------;-----------------------------:
:00.3 :7i+2A ': <..,,/ . : . : \ 1.-: ,I : : :
. ------. -·· -··· · ·· · -: ···· -----· · ··· ··· ·--+· ---·· · · -··: ------·l1 · -· -~~ --+·· 1 ...... · · · · +--· · -· --·-·-··-----: ---· -·---·-· -··--· ----·--· ---:
·--·---.··········-·:···--·--·---······-·:----·----••:•···············--·+----··-•·:•················································+
·····-·+············+······--·--·········+··-········+·-··············-··+··--·--··:-···········-·····•:••·········-···············-·+
·····--:••·····. ····:---··-······-·--···-+·-········-:--·-·········-·····+-·····-··t·····--·------·-···+-···-··-··--··--·············+
·······+···-·····-••:••·······-······-··•:••·······--+--···-·······-·····t-········+···-·····----···--·t····--······-·······--·······:
·······~·-·······---+·······---------····+····-······+·············-·····+--·-···--+···-···············+···-·········-················
·······~··--·-······+····-·····--·······-+·-···--··--+·--················~·········t--··············---•··········-···-···-··········t
·····-·~·········-··i····-···············r···········t-············-·····t·········~-·--···············+··-··························+
-------------------------------------------------------------------------------------------------------------P[V 07129193 IPSIMf 91--'
• •
II HS, COLI.JHJJ rrPf
f·;n1 ' i) !3_')
-
OAI[ l lHE F-ROJEC IM SAMPLE#
'/(>.1,~ /7 cl/:) tn-117--!P ~,...,_.--, A ,,-. l'74-l '-;_,;'-,';( 'c"~" -?i-1f<;: ') ,,?,½
½·,/~ I ✓ -• e /' ~
J6l4 h-::rzA ?'-)-I lS--s • 'tr( (0 );z-:rz /'\ -:P-/(, (; -1
717ft) }I'S f Jt;z_ S"l --:;v-15l-,/J
/(~ I i,. I'/ J . -, 1,:,(,,, ;:)0Z5 0 =Jo-/41'-I
I ,'r • i~ L-"',/ 1 -tzz-11 7-,v ,J -~ ul)o5 i u1;, :?,=;cc; o ]U-,YU-1/1
l%15 <bt/1 :).-5Z07--\l ; 1
f v A 1 rt: t"-)-S :?-C:,-:+ ---
cJ(,'.,'i J-u,,u,_·-3
,,i..;.;' -
~ ,j lL f~ -I
i 2 S l,,J\,, -__Q_'J_;__j_j_ 1--
I oc/: ,;l l,, 1;,--, " (...
) ,, t fr 1(1-ol, ~-1,0-1
I I ·, I II
No
-
')
~
q.-
":l
'.l
-
;2
COLUHN ii
1'fillillGLlLT J\ IIOJlA '1'011 T 1•:s TN!,;
RUN LOG
PLOT NAHE PKO AHOU!II lt:J
"$/) l-(:'l_3, [)~PL1 !)J f!lj) 2 -o j-· I
CLIENT SA.HPLE ID COMMENT 5 !332 1. . I
12.s-f.::io ~3
'?W>4A ·S4~J
1:se,¢9A jf"t-Z.
r;1os1,1 -A j:;o4
t -, C,------., ,< v-.,,_L,___, _.,/5 m-:;
J -75 -rp ") I 1 -(/) rf, I 560 I
ls I cJZ, Zf JC.
°13-¢4-e:, 0 i''¥6
ACOUISISTIOJ./ G/C
(01-/{ z.___ /-.,,_y{c {) 8 5-
OP 1111 I p Q SYR II f ILE #
VC--[/ v,_, f lJ,/t>D --(4 ;, "I '-; "FY
1~0 I/ l __,, rfi I'i { Tr-s'h,s,'
{J'(S /
0/Z"il
-, ..
v V n )Lf577
M ,./ v T7Z4 1 1 J:, -1-c. clb
~() / ,::, '/f'?Z 1( 71'5 "J·G o I
~6 J_A -T)-ZS { 173.Lr00L
~lfi " Iv k'. 'S?;tUu T'?".)4-<=.o 'J' v /L'-'L ~-~ -/7 )~·&cJ 4 J V T1Z'i I
f) ult Hp Le_ /.vc.._le,_,_ f,f4 -Jt " ✓ T1ZCj, 1 '? Yi & 6 ~
I -rt, ~c, l'-lO<,,<. (/<--vVL l t, 1, .,/ V TIZ4I Ten 1r (, O (,
' /
(l Tt-+i < ~ ~·/,,,.:, . B'; £A v V ;z..n.,n•--L ,.~,.__.. I , T'i3'1LCt--h Is SA-/ ./ IL 1_5 ., "} ;, ·I L e,, fJ (.:>,VL«L IV J .11ill. I" . ..,
.,,/ ~D !:, I J(Y v ✓ T9z'i I T1 3</ i,o'i -L-op, -,
I TL-L fft?4 .;;,,«.s l,1_, kli. lill Q ,<t-' -/ '1J i 'i I -r't~</.'-1"' -~
-v 6°&3~13 1 o/, I., ,'5.4-v / -r, L., I .,,, ' '-/-l-//
II HS, COLUMN JYPE
I I
l•f 'O 13 s
f,""
l lHE PROJECltt SAMPLE#
q6,11 ) ()~ :3~ 9 '>3?--B 71. 'I-/,;
0 :r: L-_"', 2.<37g rl •<{-z4
1-,,'{:arn ~ lzi-11t-,~ • bq 'Q;:).... I ls;).O'i< -:,o-,~~-,
\ J.s-~ 'g" D'.\' j i ~-1.,)· J!I:
i o ·. l "'1---JS;}.o~ ~o · IJ ►·'iA •
l I: I :I ~"5)0'15 ,0-1.}.} ~A
II·. ">i :ts1'1-'I -
,;:i.-5-. . ".':) ) 5" ~O'I: ~-l"H-~
I
I ) : <JO JS3al 'l-0 ·\'li·IA
I I'\·. ~5"' J..-s~o, 1=-\Qt,JA._
I-1<;'' I 9--l~ ).-Cj f.-I
' I]. '1~ 'f,u -,oJ • ~
I 5>'.2 ;, ...q'( -I J ,i· .,~ .. !
\ \\1,1\t, I ..---· __..,
COLUHJ.I #
···•······· ·--··-------------------------~•RTAllGT.lLLlJDO!lA'l'OHTES TUC
RUN LOG
PLOT NAHE PKO AHOUN J IN J ACOUISISTION G/C
3, S: Z..<> .,_ 3 1Jo PLT j.l-c, I' 1C. 0 7 .u yl C, r'F 2-/~:STp /3 ',-
Ho CLIENT SAHPLE ID COMMEIH S ! 332 · OP 11111 p Q SYR # f ILE # '-... -.
?-O </?-'fllC. -oo I j,.0J.s. 1--&--"v v,..,-
f 1 l1 I T~ .:i •f c.1 2... --
_±, n,J;,. -//7.I. -oo/h '1ffi.D <?A... / / 'J!t.l'J.) t. '.l '3 'f.J, L3 _,__
Is 1 = .Jo Q(, Ql,-\-j,,J ~~ SA--(\. s -o. I(.. -.., ✓ fl,-, oV -r"I ,'; 'fl I'-/ I C•A
l r yt.i iS >nt •ff,.,"-" r . -
)).fa ~oc JS r✓ ;).. ---IM"" V ij ;).'i I T1~"fu/'.:,-N~'i' C.o,<._;(_e--CT ,-.
3 J.:;t. &, ":¼-'t D ).:Pi 'l-30-9.3 -,~ 3"'1 lo lln C--i'15&b I~ I"-v' ✓ Tq~OI
q, :).. :>-l3 ~'<D b53l-LA-\ IV\ V v T'\ >O\
\ "I 34 (, l "":\-. ,, , .. tcp..; io 14-, ' . .,
5 :l;).l,'i(lf'I ) "'< <; • fl/\ V¼ '-/~ T°l~cl( f'\t"t'lo1&"
0,\1... J,)0 Q.t.. 41{,'--ID cl,..,.~t-..:' 1-., = :-f Q.C.
I 1"1.,1 ol""".K-n.,,I(. ~ I,
~~""' :~ ; h Ill~~·() j,, .. ,i.,~, ~)10 I\.\Vv\ _ ,_ T93<.:J I r 't )"f ti 1:1 __ I t""J.:..v,~ d., •."I\
& ,:;J )-e, <i "1-0 'uil.'.I. UA \M V ✓ r\3o1 T'i3~w;;i o
;:i, 0 ,· U .. t q:_ 1 ruJ..J "> . L 4::\'\ 1 MW\ ✓ ~ it, 'l JO I T'j3'J&,x.\
3 E 11 .. , eo \){_ , , ..,J-.-.wf ,,; L, %3 \¼\I,\ 1 ✓ ./ T~?ol 1 ct 3 t lo~
I(, 13 -J "2 I":. (°'-"' .4 I I I~ ,"\ }'1~3 r,,\y\,\ IU.u T~ ~ '\ 4';;t 3 ---c\~ I !s'½ Q_. ~"' \'-.. D~ \2..1-.c.n "-~ ">:,0,_I-,-~ L\
~1.l
I~ I';
Tq:?) '-I (o ?-\ -\u,(~ (Cf\u;.\ LO .o 130 10,V
-Ci,11wct L(v., VC---t"IJ '-/ l, 2-b
j
I
HS#
lo-r'
-
OAH IIHE
lo/,/,\ IL I-·)
il/", f
IT .... (I
1___.,1 ·;_ '.
/,j j,
'
i
.(;
PA.GE
'
-~ .. ...•..
I 'I C{J 'J
Jc.:,; '-j
,'I-, [ •· l
'
l '. !
) ', ' ,-
· 1. .·..J,
~
·-
t,·' < ·7
v/, ,-1.,.
c)l.'---.V
COLUMN JYPE
-1)i3<,
PROJECT# SAHPLE#.
..
I\XJ.·IC;·'.,
'p.>1 ,. 7 . -<-/L--
-·· ...... ·---· ·\_ i_J ·l 17 -1 !:
'!,,JJ-~l . I
:'.,''-,:' L/ ) ll-1 . .:.L•'t·-fZJ:rvt
~~)( --, ' ·.1 ' -,, ) .. c~,re_
,-)-
-c-J ? 'j)... \Lt
'"Ii:'\\'.-
·-· r, ,. ,,., . .,,
-----l_;,J .!/l -I
----vJ-½t-J..
-~ .:.) •!;.1.J .. L. A-2,11-1
.i.-S37'1 C.,(>(L
P)/c.n,.::..
' S-2 01:, -
-I..;) (,7 ·l ") ---l
l >) 1-~ }f-4· 4
I I 11
-------····-·· -~---'l'l!IANGLE TJ\BOllA'l'OllTES INC
RUN LOG
COLUHN # PLOT HAAE PKO AAOOHI I HJ
d ''>-2..(.., 2... 3 DoP,, -Po Pf.-.D z_,µ ,J.
Ho CLIENT SAMPLE 10 COHl<EHIS ! 332:
\? -\ ( \-, \<........ \C-o;, ··-· -~ f.
--O•-f:JI \ f''-1 r,,__ ~ C.· (\(.Ct\ ";".C,
-(2 ~-;/ t) C. ~l'N
-1(913 Cc; ,'\L.C. I //.J. i) Jil)
c'J co-· . . ·--/'_ ·---, ·-
I /. J 1; ',\L'i' , -, /cv1 (
. ·-.~----
() 1 ·,9 C2 h \ :, 11\ \( __ ,,·i;;5 ,1,
11.....T i''i.J..< ~,---s \:, luA\:... 5w2. ' (_ . \. L ,,C,,T\ "'"/;>-c j.1 i I I <.r i ·._: (, ,_.,..,,,.. L\..;_..-_,.,-J nl --)l'-·,\..~ i.·,c,:) ( .. ! •/,. ~-~ I I )!.1ott ·1< •j,-·,,2 -I I i,t J
\ ([ l",
\~--\-,.<L.
--· ·y1 l • -...·1 i.. -< Ll-1-n c )Co cl ;,-,19
··-1°.::.'·\ILL ( C\'\c(( I s .() cyooc:f ·,,]((:. ,,
[htJ l {: ~ , .. ,. 1 C: 0 '.'.> 1)()1 (L 1-1,,i/ 0-
C) oPIL ·-·-·-l i \ --~' ) \,,·/\ l/ ;·' J -
t{i o--r t?.. 1-h,D )H,~.,..
I 1 L-\ ~-JI.£ /,h,;<., l,<."u
2-7/t .5 o,j "" -;, , ' -Fl', . ·/ ·,.
ACOUISISTIOH G/C
0rJ F ;i__ 1cST D,3<;.-
OP !HIT p 0 SYR # fl LE #
Y~TS ✓ ✓ ·i. \chi'--cc, >,cj &.-'~ °'.)
t<'\rc v tt1 '.(_l,>(:._l.. \ IC(?;' /l,'j L/ cc;-.r,
r., {'-_;, tL--_.,,uO ·T,,·y1c,'5
80 I 1,,, I;,
IC( 'J '-( ~, ¼ l,.:f"lWI ,o-~
-131~---..... -,-=,-0 .:.). I·-177:,rcrc-: 'fr·
r=;::; / ,.,To c-1 ·/ L -\?1 )_{ ( !.: :;7 -(_
r):,,
/L -J
f3 b C /\.. '1' /0<'/ TC, ?:, L/ &sY
V( . Lv__--I L[ ·1, Lt(,,:-,'<, .
thiiv
i ·' --, e: ;.:.'-"I 1<i./ j l/l(c·(_) , ✓ :.,u 1(1.()
Cc-:-u, ( I. / V ✓ ,c; -5 'U: {c I •· 1 I "··1 -~·· (J -/
.. -~ ·0 ",'I(-{· :,J [_...' ,., / ✓ /10 t:/
,7 <7 1"~_''-~--r--t":;L/(,_/4'5 -.~.~ ",'d.·-:.;. -
VL ✓ ✓ T1001 1 C,J 41,63
\}{/ ✓ ✓ 11 uDI 1'1311 l Pl
, / -S',4-V "'T1c 0 J ',q 1c./ LbS:--
---·-• f&Wiliisii,11111r11111Hc!llt,J'1:1,:,,1,1:1,,:r>.:
TRIANGLE LABORATORIES OF RTP, INC.
Rev. AH -9/93
SAMPLE
DATA
TL-RTP Project: 25378
Client Sample: OPR AQUEOUS
Client Project:
Sample Matrix:
TLRTPID:
Sample Size:
Dry Weight:
GC Column:
2,3,7,8-TCDD
"C12-2,3, 7 ,8-TCDD
"Ct.-2,3,7 ,8-TCDD
n/a
AQUEOUS
OPR
1.000 L
n/a
DB-5
Date Received:
Date Extracted:
Date Analyzed:
Dilution Factor:
Blank File:
Analyst:
164
1660 82.9
159 79.4
1613A TCDDfTCDF Analysis (DB-5)
Analysis File: T934663
I I
09/29/93
10/02/93
n/a
T934664
vc
Spike File:
!CAL:
CONCAL:
% Moisture:
% Lipid:
% Solids:
0.74
0.79
0.79
SP161F2S
TF59033
T934660
n/a
n/a
n/a
29:12
29:11
29:12
28:59
Data Reviewer:_...,\,_/~, ..... c_..,,,~,.._,.,_,L.,,.A .... <q"--'-b-av"'---"~--10/02/93
Page 1 of I 161F_PSR v:1.06, LJJtS S.09.02
Triangle Laboratories of RTP, Inc.
801 Capitola Drive• Durham, North Carolina 27713
Phone: [phone] • Fax: [phone]
Printed: 03:45 10/02/93
f924BS3 ·· -~-OCT-93 01:09 70-250$ CEH 5i.ls:T£ST005
3R 1 o, 315.9419 [: 317,938S F: 31. G: 321.&'336 H: 327.SS47
Text : C\PR TL! I 25206
1001 F Sl,11,GI
•
1.00
2.8805
1.00
3.3368
. ·-,.
T934663 2·0CT·93 SL~-tage 70·2505 Sys: TEST085 • SaNple l Injechon 1 Gr 1 Mass 319.8965
Text:OPR !LIi 25206
100 Hor~: 308
0
24 40 25:20 26:00 26 40 2720 28:00 28:40 29 20 30 00 30:40
T934663 2·0CT·93 SLr Voltage 70·2505 Sys TEST085
Sample 1 InjectLon 1 Group 1 Mass 321.8936
Text OPR TL! I 25206
100 NorM' 400
0
24 40 25 20 26 00 26 40 2720 20,00 28:40 29 20 30:00 30 40
T934663 2·0CT·93 SLr'Voltage 70·250S Sys, TEST085
SaRple 1 Injechon 1 Group 1 Mass 327 .8847
Text:OPR TL!# 25206
100 Nor~: 696
0
24 40 25 20 26 00 26 40 2720 20,00 28 40 29,20 30,00 30 40
1834663 2·0CT·93 5Lr:Voltage 70·2505 Sys TEST085
Sample 1 In jechon 1 Group 1 Mass 331. 9368 .
Text:OPR TL!# 25206
100 Nor~: 3265
0 .
24: 40 25 20 26:00 26 40 2720 28 00 28 40 29 20 30 00 30 40
1934663 2·0CT·93 SLr'Voltage 70·250S Sys TEST085
Sample l In jectLon 1 Group 1 Mass 333.9338
Text:OPR TL!# 25206
!Gu Nor~: 4237
0
24:40 25 20 26 00 26 40 2720 28 00 28 40 29 20 30 00 30:40
1934663 2·0CT·93 SLr:Voltage 70·250S Sys: TEST085
Sample 1 Injechon 1 Group 1 Mass 292.9825
Text,□PR TLII 25206
100 Nor~: 2737
0
24 40 25:20 26 00 26 40 27 20 28 00 28 40 29 20 30 00 30:40
' • • Ref. mass 292,0025 Peak top
HeL!t( ,63 I/lits Span 200 ~
Systes flle naee TEST005
Dia fLle naee B:T934663
-...1,--...,l ResolLtLon 10000
~ ram I
IonLzat Lon IIOde EI•
SiJLtchlng YCl TAGE
Ref, aasses 292,9825, 380.9761
-~ A 292 .9825 J 331.9368 B 303 ,9016 K 333 ,9338
C 305,8987 L 375,8364
0 315.9419
E 317.9389
F 319.8965
_...1,-_ __.· G 321.8936
H 327,8847
I 330,9792
Channel I 330 ,9792 Lock mass
HeLght ,49 volts Span 200 ppm
:.
· TL-RTP Project: 25378
Client Sample: TLI AQUEOUS BLANK
Client Project: n/a
Sample Matrix: AQUEOUS Date Received:
TLRTP ID: TL! BLANK Date Extracted:
Date Analyzed:
Sample Size: 1.000 L Dilution Factor:
Dry Weight: n/a Blank File:
GC Column: DB-5 Analyst:
2,3, 7,8-TCDD ND 0.9
"C12-2,3.7 ,8-TCDD 1320 66.0
37CL,-2,3. 7 ,8-TCDD 163 81.5
"C,,-1,2,3,4-TCDD
1613A TCDD/TCDF Analysis (DB-5)
Analysis File: T934664
I I Spike File: SP161F2S
09/29/93 !CAL: TF59033
10/02/93 CONCAL: T934660
n/a % Moisture: n/a
T934664 % Lipid: n/a
vc % Solids: n/a
0.79 29: 11
29: 12
0.79 28:59
Data Reviewer: )<'. u~ Gr V c_ 10/02/93
Triangle Laboratories of RTP, Inc.
801 Capitola Drive• Durham, North Carolina 27713
Phone: [phone] • Fax: [phone]
Page I of I !61F_PSR \':l.06. LARS Hl'J.O~
Printed: 11 :50 10/02/93
• itial • B-File/Header Changes \( C __
'
Date
\O; o \,,f
-'---Calculated Noise Area:
Manual Integrations
Transcription
Dbase Corrections
Page No. 1
10/02/93
Listing of
Matched GC Peaks
M Z Omit
lQ4 JOG
304-306
316-
328
328
332-334
332-334
DC
Ratio RT.
0.79 28:27
*** Total ***
0.79 27:23
28:00
28:52
30:29
*** Total ***
o.oo 26:17
0.00 29:12
*** Total ***
Ji O. 73 27:55
0.79 28:59
0.79 29:11
pl.56 29:34
***Total***
*** End of Report***
Channel: µ.o ;;,o
In it i a 1 s : ~ /C v
T934664B.dbf
I Ratio I Ret. Time
Match Match
Area Rat RT REL RT
24.38 T T 1.002
24.38 # of Peaks: 1
T F 0.964
413.01 T F 0.986
44 860.13 T T 1.000
197. 1.016
68.81 T F
44,860.13 # of Peaks. I
31.13 T F 0.907
3,513.91 T_ T 1.007
3,513.91 # of Peaks: 1
81.07 T F 0.957
36,817.53 T~ T~ 0.993
26,669.67 T T 1.000
149.33 F F 1.013
63,717.60 # of Peaks: 4
Who/
Why
WL
WL
WH
WH
WL
1342:4 2-0CT-93 01:56 70·25£S (El•> Sus:T£STD85 •
. R l' 0 315;9419 [: 317,9339 f: 319. G: 321.8'936 H 327,8847
·ext TU ftffi+'. 1,!RTER TUI 25..:-es
I e-<--_....,...._......,. __ .,......._....,...._......,..~........,
10sLG Sl ,Il ,Gl
~·-
--""-'-WL2'....!'-'-"L!J'-".1.)".ll.---'·1-1'--'-"'-'-----"--'-"'--'--'·-~ -~
I
1.00 -----<
N = 2,6940 r-· 3 r-l ~. 0 'f
1.00
2,9970
v~
G..__1 ___ ...........,--.--,-_.......,...._..........., __ -,-.-_...,
T934G64 2-OCT-93 SL-ltage 70-250S Sys: TESTOB5 • Sa~ple 1 lnJectLon 1 . G 1 ~ass 319.B965
Text•TLI BLANK YATER Tlli 25206
1gn Nom: 5 '0·1 ""'i II '='=1 .,..,. ' ◄ ' ,..; ·~•·"; .~-........ ~ .. .,. ......
' 24:40 25 20 26 00 26 40 2720 28 00 28:40 29 20 30:00 30:40
T934664 2-OCT-93 SLr Voltage 70-250S Sys: TEST0B5
Sai1pl e 1 In jeclton l Group 1 Mass 321.8936
Text:TLI BLANK ~ATER TLllt 25206
100 Hom: 5
f: ~ ... ~ ,. . ___ ... -'-' . . ,. ~~ ~ ' ' ' ' ' I I I I ' 24 40 25 20 26 00 26 40 2720 28 00 28 40 29 20 30 00 30 40
T934664 2-OCT-93 Str Voltage 70-250S Sys: TESTOB5
Sa~ple l InjectLon 1 Group 1 Mass 327.8847
Text:TLI BLANK WATER TL!ff 25206
10G Nor~: 724
0
24 40 25 20 26 00 26 40 2720 28 00 28 40 29 20 30 00 30 40
T934664 2-OCT-93 Str:Voltage 70-258S Sys : TESTOBS
Sample 1 InjectLon 1 Group l Mass 331.9368
Text TL! BLANK WATER TL U 25206
!OB Nor~: 3513
0
24 40 25 20 26 00 26 40 2720 2B:00 28 40 29 20 30 00 30 40
T934664 2-OCT-93 Str': IJoL tage 70-250S Sys: TESTOB5
Sample 1 lnjechon 1 Group l Mass 333.9338
Text TL! 8LAHK WATER TUI 25206
100 Norm: 4451
0
24:40 25:20 26:00 26 40 2720 28 00 28:40 29 20 30:00 30 40
T934664 2-OCT -93 5Lr: Voltage 70-2505 Sys: TESTOB5
Sa~ple I In jechon 1 Group 1 Mass 292.9825
Text:TLI BLAHK WATER TL!# 25206
100 Norn: 2472
0
24:40 25 20 26 00 26 40 2720 28:00 28 40 29 20 30:00 30:40
• Ref, llaSS 2S2 ,9825 Peak top
HeLgtt ,69 vol.ts Span 200 i:llll
System flle naaie ITSTD85
Data fLLe na11e 8:T934664
..---+---, Resolt.hon 10000
Group ni.l!llb€r I
looLzat Lon 1ode El•
SIILtchl.nQ VOLTAGE
Ref, ma;ses 292.9825, 380.9761
-~ A 292.9825 J 331.9368
B 303.9816 K 333,933,g
C 305,8987 L 375,8364
0 315,9419
E 317 ,9389
F 319,8965
-+---, G 321,8936
H 327,8847
I 330.9792
Channel I 330 ,9792 Lock Mass
HeLght .46 volts Span 200 ppm
·' '
TL-RTP Project: 25378
Client Sample: 047-1126-00lFB
Client Project:
Sample Matrix:
1LRTPID:
Sample Size:
Dry Weight:
GC Column:
2,3,7,8-TCDD
"CI.-2,3, 7 ,8-TCDD
"Ci,-1,2,3,4-TCDD
n/a
AQUEOUS
71-4-2A
1.000 L
n/a
DB-5
Date Received:
Date Extracted:
Date Analyzed:
Dilution Factor:
Blank File:
Analyst:
ND 1.8
164 82.1
1613A TCDD/fCDF Analysis (DB-5)
Analysis File: T934665
09/29/93
09/29/93
10/02/93
n/a
T934664
SA
Spike File:
ICAL:
CONCAL:
% Moisture:
% Lipid:
% Solids:
0.81
SP161F2S
TF59033
T934660
100.0
n/a
0.0
29:09
28:56
Data Reviewer: __ 1\l-/_._f-c-ci-l,U11__,.~w._o4lccch"-.U..y:;-'-;:-,___ 10/02/93
Page I of I 161F.PSR v:J.06, LARS 5.09.02
Triangle Laboratories of RTP, Inc.
801 Capitola Drive • Durham, North Carolina 27713
Phone: [phone] • Fax: [phone]
Printed: 03:45 10/02/93
• itial Date • B-File/Header Changes
Manual Integrations
Transcription
Dbase Corrections
\f( <= _J_Q; 0 l--1 .-22.
~ .. ;t
Calculated Noise Area: ?---S )--
Channel : _3 2-2---
Initials: V C--
Date: / o/ i-,/ "i.J
Page No. 1
10/02/93
Listing of T934665B.dbf
Matched GC Peaks / Ratio I Ret. · Time
Match Match Who/
M z Omit Ratio RT. Area Rat RT REL RT Why
304-306 0.57 28:22 16.78 F T SN
304-306 ** o.oo # of
316-318 DC .81 T F 0.964 WL
DC 261. F 0.985 WL
29,545.41 T-T
DC 28:50 139.16 p p WH
3 J 6 318 29,545.41 # of Peaks:
328 o.oo 29:09 2,058.33 T -T-1.008
328 *** Total *** 2,058.33 # of Peaks: 1
332-334 0.81 28:56 21,406.29 T T 0.993
0.78 29:08 17,357.36 T T 1.000
j) 1.20 29:31 111.55 F F 1. 013
332-334 *** Total *** 38,875.20 # of Peaks: 3
*** End of Report ***
-3346"o5 t-OCT-93 02:42 70·2505 CE!·) &Js:TESTIB5
2 i Q: 3i5.9419 E 317.9389 F: 31. G 321.8336 H: 327.8847
~):t:047·1126-001F8 TLil25378
lOO•F Sl,11,Gl
0-c....-,_.....,......_......,.~_.,......_...,......~......,..-~
•
1 .00
3,0441
1.00 100 G S1 111 1Gl
N~ 2,1618 f · ~!.~'f-/o .=. ::f-S-?-
50
0.._.,_~,._,...~.......,.-~.,.......~ ........... -........ ~....__,
T934·665 2-OCT-93 5-Ltage 70-2505 Sys' TEST085 • Sa~ple I In Jechon I l Aass 319.8965
Text:047-1126-001FB TLil25378
1:,0L --~ Hor~' 5
' ""' A ~ ~ "' ~~ : . ~ ~ ;
l l l l l
24:40 25 20 26 00 26 40 2720 28:00 28 40 29 20 30 00 30 40
T934665 2-OCT-93 SLr Voltage 70-250S Sys TESTOBS
Sa~pl e I InjectLon 1 Group 1 Mass 321.8936
Text:047-1126-001FB TLil25378
1:0~
Horn: 4
l l l l l l l l l l
24:40 25:20 26 00 26 40 2720 28:00 28 40 29:20 30 00 30 40
T934665 2-OCT-93 SLr Voltage 70-2505 Sys: TE5T085
Sa~ple 1 Injechon I Group I Mass 327.8847
Text:047-1126-001FB TLIU25378
100 Nor~: 487
0
24 40 25:20 26 00 26 40 27 20 28 00 28 40 29 20 30 00 30 40
T934665 2-OCT -93 S Lr ~1ol tage 70-250S Sys: TESTOB5
Sa~ple l In jectLon l Group 1 Mass 33 l. 9368
Text:047-1126-001FB TLID25378
100 HorM' 2288
0
24 40 25:20 26:00 26 40 2720 28 00 28 40 29:20 30:00 30:40
T934665 2-OCT-93 SLr Voltage 70-250S Sys: TEST085
Sample I In jectLon l Group l Mass 333.9338
Text:047·1126-001FB TLID25378
100 A Nor~: 2924
0
24:40 25,20 26:00 26:40 27:20 20,00 28:40 29:20 30:00 30 40
T934665 2-OCT -93 SLr'V□ltage 70-2505 Sys: TESTOB5
Sa~ple I Injechon l Group 1 Mass 292.9825
Text:047-1126-001FB TLil25378
100 Hor~: 2211
0
24:40 25 20 26:00 26:40 27:20 28:00 28:40 29:20 30,00 30:40
.
•
;o L-----1----
5
• Ref, l\aSS 292 ,9825 Pe~ top
HeLgrt ,63 vcUs ~ 200 ppa
System fLle name TEST005
Dia fLle name B:TS346S!i
-----------Resolt.Uon 10000
Groi.ip ni..nber 1
IonLzat Lon IIOde EI•
~.LtchLng \JU. TOOE
Ref. mas% 232.9825, 380,9761
!ail~ A 232,9825 J 331.9368
B 303,9016 K 333,9338
C 305,8987 L 375,8364
D 315.9419
E 317.9389
F 319.8965 --1------------G 321.8936 H 327 ,8847
I 330,9792
Channel I 330,9792 Lock mass
HeLght .53 volts Span 200 P?lll
•
TRIANGLE LABORATORIES OF RTP, INC.
Rev. AH -9/93
CALIBRATION
DATA
TR.LE LABORATORIES, INC.
for T.33 I al Calibration
Analysis Date. 09/03/93
Instrument ....... : T
Analytes RF SD %RSD
23 7 8-TCDF 1.054 0.018 2%
TOTAL TCDF 1.054 0.018 2%
2378-TCDD 1.232 0.043 3%
TOTAL TCDD 1. 232 0.043 3%
Other Standards RF SD %RSD
3 7Cl-TCDD 1.067 0.047 4%
Internal Standards RF SD %RSD
13Cl2-2378-TCDF 1. 843 0. 175 9%
13Cl2-2378-TCDD 1.097 0 .130 12%
Recovery Standards RF SD %RSD
13Cl2-1234-TCDD 1.000 0.000 0%
... End of Report •••
Page
Triangle Laboratories of RTP, Inc,
801 Capitola Drive• Durham, North Carolina 27713
Phone: [phone] • Fax: [phone]
Summary
Method ...... :
GC Colwnn ... :
GC Colwnn ID:
RT RT/LO RT/HI
27:02 20:02 31:02
27:48 23: 4 7 31: 4 7
RT RT/LO RT/HI
27:48 25:34 29:34
RT RT/LO RT/HI
27:02 26:02 28:02
27:47 25:47 29:47
RT RT/LO RT/HI
27:34
1
Date: 09/03/93
161F
DB-5
3129411
Ratiol Ratio2 N
0.758 5
0.758 5
0.795 5
0.795 5
Ratiol Ratio2 N
5
Ratiol Ratio2 N
0.767 5
0.820 5
Ratiol Ratio2 N
0.819 5
Printed: 19:04 09/03193
Date: 10/01/93
Analysis Date .... :
Operator ......... :
Init Calibration.:
real Date ........ :
Analysis Time .... :
Analyte Summary
Name
2378-TCDF
TOTAL TCDF
2378-TCDD
TOTAL TCDD
• • TRIANGLE LABORATORIES, INC.
Continuing Calibration for T934660
10/01/93 Method ...... :
BB Instrument .. :
TF59033 Std.Cone .... :
09/03/93 GC Column ... :
2 2 :-5-2-s-3 Cl GC Column ID:
E:-~ 0 (G / v/ ~)
RF RT
real
Rel. RT RF
161F
T
10.00
DB-5
3152623
Delta
RF
0.960
Ratio
1&2
0.74
RT
Lo/High
25:29 28:26 1.0006 1.054 -0.094
30:41
%D
-8.9%
0.960 0.74
1.158 0.76
1.158 0.76
26:31
30:37
29:13 1.0006
1.054 -0.094 -8.9%
1.232 -0.074 -6.0%
1.232 -0.074 -6.0%
Other Standard Summary real Delta
Name RF Ratio
1&2
37Cl-TCDD
Internal Standard
Name
13Cl2-2378-TCDF
13Cl2-2378-TCDD
Recovery Standard
Name
13Cl2-1234-TCDD
1.011
Summary
RF Ratio
1&2
2.010 0.77
1.055 0.82
Summary
RF Ratio
1&2
1.000 0.81
RT
Lo/High
26:31
29:35
RT
Lo/High
28:16
28:36
27:12
31:12
RT
Lo/High
Page 1
RT Rel. RT
29:13 1.0075
RT Rel. RT
28:25 1.0000
29:12 1.0000
RT Rel. RT
29:00 0.9932
RF RF
1. 067 -0. 056
real Delta
RF RF
1.843 0.167
1.097 -0.042
real
RF
1.000
Delta
RF
0.000
%D
-5.3%
%D
9.1%
-3.8%
%D
0.0%
~ ~~fM!;r~
• : • I •
VIA: FEDERAL EXPRESS
September 22, J 993
Ms. Beverly Hudson
U.S. Environmental Pi'oketion Agency
345 Cou1ilfllld Street, N .E.
Atlanta, Georgia 30365.
Dear Ms. Hudson:
Ref. No. 179285-01
RE: . Schedule for Field Activities for Remedial D sign Phase
Former Koppers Company Site
Morrisville, NC
On behalf of Beazer East, Inci and in accordance wi h the Unilateral Order, we are writing to notify you of our plans for field work in 9oaj1111ction with the Remedial · Design Work Plan for the Koppers Supetfw1d Sitd, Moirisville, NC. The field . work i11dudes soil boring and· sampling, surface fater and sediment san1pling,
monitoring well installation, and groundwater san1~ling. · For your reference, the following summarizes om schedule. · i,
l
Chester plans to mobilize to the Monisville site ol). Monday, October I I, 1993. The drilling contractor will alJ'ive either on Octoberi 11th or 12th, and drilling will begin on October 12th. Most sampling ac,tivities wi\1 begin oi1 October 12th, with the exception of groundwater sampling. . Groundw~ter sampling is scheduled to start on October 18th. As you are aware, groundwater sampling is contingent · upon receiving access from Unit Strnctures, Inc. · '
torn-1ci·ly Keye.to a Envir-Cltlrncnt[)I Roaou1'C.b:1
13G00 L Salls n □1,(l, Guit:c [,02
Yor•l: Guflding.
lowaani r-,t1Ar-yl~1_id 21 eee ·
<'.110-02'!\2900; r-l"I,; t.110·821-~.918
•
Ms. 'Beverly B:udson i
· September 22, 1993
Page 2
The following is a chronological progression offielq activities.
WEEK#l
10/11/93
10/12/93
l 0/13/93 .
10/14/93
10/15/93
. . i
Arrive at site
Prepare decontamiiiation area ,
Confmn bcnc.lunark locations1d establish soil sampling grid Purchase local supplies · _
' '
. ' ..
Drillers prepare to drill · , · . .
Rig # 1 begins soil sampling program • Cellon process area
Rig #2 begins monitoring well i~stallation · C-33B&C
. Assemble sampling platfonn fo~ pond·sampling
Smvey previous samJJhng !ocatipns and perfo1m
cross-sections at Fire Pond i . ·
De gin srnnpling surface water at! Fire Pond
· Continue soil sampling program• Rig #1
Continue well installation at C-3B&C -Rig #2
Sample re;naining suiface water and s~dime_nts at Fire Pond
Continue soil sampling program in CeUon area and prepare in
Former Lagoon Area .: Rig # l
Co.ntinue well installation at C-33B&(] -Rig #2
Trimsfer sampling platfonn to 11~dlin ·Pond . · .·
Smvey previous sarnplinglocati?ns and perfoml
cross-sections at Medli1i Pond ' . ·
Begin smface water and sedime t sampling at Medlin Pond
Continue soil sampling program in Fo1:mer Lagoon Area -
Ri #I g . '
Continue well installation at C-3[3B&C -Rig #2
Complete sampling al '.Medlin Pdnd
Demobilize and <lccon sampling latfotm
Begin ditch sediment sampling i access is grnnted
•
. Ms. Beverly Hudson
September 22, 1993.
Page 3
10/16/93 . Complete soil sam. piing. program ib Fonner Lagoon Area •
Rig #1 . . . .
Continue well installation at C-33 &C ~ Rig #2
Finish ditch sediment sampling if ccess is granted
10/17/93
WEEK#2
· 10/18/93
10/19/93
tluu
10/23/93
WRRK #1.3 AND #4
10/24/93
t11ru
11/03/93
. .
Continue well installation at C-33 &C • Rig #2
Begin well installation at C-34B C
Begin groundwater sampli11g pro . am
Continue well installation at C-3~&C
Continue groundwater sampling A ogi•am
Well development at C-'33B&C
Well development at C~34B&C
Continue groundwater sampling Arogram
Chester anticipates that all field work will be compl
1
ted by November 4, 1993.
Please call me at [phone] or David J. Winger at [phone] with any
questions.
Sincerely, J-~~Q, fvtJ;;;Jl
John C. Mitsak, P.E.
Manager, Baltimore Operations
TCH12\ral9
cc: Shafil\on K. Craig -Beazer East
Cind~ Zuch -Beazer East
Jim C ok • Beazer East
C. Wi, 1gcrd -Chester Environ.
·~~· • ~; ~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONIIV
345 Courtland Street, N E.
Atlanta, Georgia 3036!
FACSIMILE TRANSMITTAL COViR SHEET
TO: r, "'" , c~v I ~
COMPANY/ORGA~ ZATION: I\} !'.
~
PHONE NUMBER: ~ FAXNUMI
NUMBER OF PAGES SENT (Including this cover sheet):
ER: &/q) J5J-· 1/f f/
.
Please contact th11 person s11ndlng this fax If It ts rs etved poorly or Incomplete.
FROM: /-fi.,n,t ~(I [)_ •
,.
( NORTH SUPERFUND REMEDIAL 3RANCH
WASTE MANAGEMENT DIVljlON •
Phone Numbers: [phone] or 800-435-9233
Fax Number; (404) 347-16• 5
COMMENTS:
-17u~ (J-it..A n A"' "'M . , ... ,;, -,
• ,~ ~ESTER ~ ENVIRONMENTAL
Federal Express
September 17, 1993
Ms. Beverly Hudson, Remedial Project Manager
USEP A Region IV
N. C. North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Dear Beverly:
Re: Selection of Laboratory
Forme(Koppers.Plant.Remedia[Desigril
Morrisville, North Carolina
Ref. No. 179285-01
HfCIE~Vtu
SEP 2 4 1993
SUPERF/INOSfCnoN
On behalf of Beazer East, Inc. and in accordance with the Unilateral Order, Chester
Environmental (Chester) is informing you that Chester LabNet has been chosen to
perform the analytical analyses for the Koppers site in Morrisville, North Carolina.
Negotiations are currently in progress for selection of a laboratory to conduct
dioxin/furan analyses. Chester expects that a laboratory will be selected early next
week at which time a dioxin/furan laboratory Quality Assurance Manual (QAM)
will be submitted.
Please find enclosed ten (10) copies of the revised pages of the Quality Assurance
Project Plan (QAPP) for the Remedial Design, and a copy of Chester LabNet
Monroeville's QAM.
As you have been informed Chester is planning to mobilize on October 11, 1993.
Soil sampling is scheduled to begin Tuesday, October 12, 1993.
Should you need additional information regarding the submittal, please contact
Shannon Craig at [phone] or me.
Very truly yours,
-:.,dn,, ,r,?J,~fu~ /2,1:'.1>1
J6hn Mitsak, P.E.
Manager, Baltimore Operations
Enclosures
cc: Ms, Shannon Craig -Beazer East, Inc.
Ms. Cindy Zuch -Beazer East, Inc.
Mr. Jim Cook -Beazer East, Inc.
Mr. Bruce Nicholson -NCDEHNR Superfund
3000 Tech Center Drive
Monroeville, Pennsylvania 15146
412-825-9600: Fax [phone]
• c...lEiTER-
ENv1R□NMENTAL
rtttGt\\BtU
SEP 16 1993
Via: Federal Express su~ERHIN[\ S£UION
September 3, 1993
Ms. Beverly Hudson, Remedial Project Manager
USEPA Region IV
NC North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Dear Beverly:
Re: Monthly Progress Report #4, Remedial Design
Koppers Site -Morrisville, NC _
Ref. No. 179285-01
On behalf of Beazer East, Inc. and in accordance with the Unilateral Order, please find: attached four (4) copies of the Mo1:1thly P~ogress Report #4 for the perjod
endin_g August 31, 1993 for the Remedial Design for Koppers Superfund Site,
Momsville NC. . .
Should you need additional information regarding this progress report, please let
Shannon Craig at [phone] or me know. .
Very truly yours,
~l.~~
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt4
Attachment
cc: Ms. Shannon K. Craig -Beazer East, Inc.
Ms. Cindy Zuch, Beazer East, Inc. /
Mr. Jim Cook, ael\Zer East, Inc. , · · .
Mr.'.Bruce Nicholso_n ~ NC Superfund (Two Copies)· .• ,,.
. ' .
: ' ; : .. '' --formerly Keystone Environmental Resources
8600 LaSalle Road, Suite 502
York Building
Towson, Ma')'lancl 21286
410-821-2900: Fa) 410-821-2919
• •
MONTHLY PROGRESS REPORT #4
REMEDIAL DESIGN
SITE NAME: Koppers Superfund Site
Beazer East, Inc.
Morrisville, NC
USEPA DOCKET NO: 93-09-C
PERIOD ENDING: August 31, 1993
1. PROGRESS MADE THIS MONTH
I. Remedial Design
Based on comments received from EPA on August 9th, Chester
Environmental, on behalf of Beazer, submitted revised replacement sections
and pages of the Remedial Design Work Plan (RDWP). A written response
to each comment raised by EPA on the RDWP was also prepared and
submitted for agency review. · ·
EPA conducted a field demonstration program of field screening tests of
pentachlorophenol in soil and groundwater at the site during August 9 -
16th. Data obtained from the demonstration program will be used in the
Remedial Design. Each sample location was surveyed by a registered
surveyor subcontracted by Chester Environmental.
EP A'S SITE Program for the demonstration of dechlorination technology
was also initiated in August. Following mobilization, soil was excavatea
and prepared for treatment using BCD technology. Soil was processed
during the period August 26 to September 3rd. A public demonstration was
held on August 31st for interested parties. Demobilization is expected to
begin the week of September 5th.
Access agreements to conduct the remedial design were obtained by Beazer
except for Unit Structures, Shilo Baptist Church, Norfolk Southern
Railroad, and Charles Zimerili. Agreements are currently being negotiated
and signed access agreements should be forthcoming.
n. Domestic Well Sampling
EPA invited the public, who had their domestic wells sampled during June
1993, to an availability session on August 31 to discuss the results of the
sampling. No one from the public attended the session.
2. PROBLEMS RESOLVED
Many issues regarding the SITE Program and the field demonstration
program at the site were discussed and resolved.
• •
MONTHLY PROGRESS REPORT #4
(Continued)
3. PROBLEMS ANTICIPATED
None.
4. UPCOMING EVENTS
On September 2nd, Beazer received EP A's letter regarding the revised
RDWP. EPA reviewed the revised sections and had no comment. Therefore, the
starting date for commencing the Preliminary Design will be either September 16
(14 days from September 2) or fourteen days from completion of the access road,
whichever occurs later. Beazer will mobilize to build the access road seven (7)
days following completion and demobilization of the SITE Demonstration
Program. Beazer asswnes that demobilization will be complete by September 10.
In anticipation of construction, Beazer is in the process of procuring a contractor
to build the road. We anticipate that construction will start on September 20,
1993. ·
5. PERSONNEL CHANGES
None.
6. SUBCONTRACTORS
Murphy Yelle of Chapel Hill, NC conducted surveying at the site.
7. ANALYTICAL DATA
None.
8. OTHER
None.
~l.~
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt4
• ,A, c.lsTER ~ ENVIRONMENTAL
-Kt.t;tl\ft.U
AUG 16 1993
SUPERF/IN11 SEf.TION
Ref. No. 179285-01
August 13, 1993
FEDERAL EXPRESS
Ms. Beverly Hudson
NC/SC Site Management Unit
Superfund Branch, Waste Management Division
-U.S. EPA Region IV _
345 Courtland Street, NE
Atlanta, GA 30308
Dear Ms. Hudson:
RE: Remedial Desi~n Work Plan
Kopper's Mornsville, North Carolina Superfund Site
Additional Replacement Pages ·
In reviewing the previously submitted changes to the Remedial Design (RD) Work _
Plan, it was discovered that the surface water. and sediment tables in Section 6.0 of
the RD Work Plan (Tables 6-5 and 6-6) and Section 4.0 of the Field Sampling Plan
(Tables 4-3 and 4-4) were inconsistent. Therefore the tables were revised to be
consistent. Ten copies of these tables are included for substitution into the Final ·
RD Work Plan.
I apologize for any inconvenience this may have· caused you. If you have any
questions on this submittal, please call John Mitsak of Chester at 410-821-2909 or
Shannon Craig of Beazer at 412-227-2684.
Very truly yours,
~-£:~
Jd.mes R. Miller, Sc.D.
Chester Project Coordinator
JRM:dac jm622
Enclosures
cc: B. Nicholson (2 copies)
S. Craig
J. Mitsak
3000 Tech Center Drive
Monroeville, Pennsylvania 15146
412-825-9600; Fax [phone]
• •
REMEDIAL DESIGN WORK PLAN
SECTION 6.0 REPLACEMENT PAGES
•
Proposed Number of Total
Sample Samples per Number
Sample Location Location of Samples
Fire Pond S-16A, S-16B, 2 6
Outflow S-17
Ditch
Western S-30, S-33, 2 6
Ditch S-34
Fire Pond S-5, S-8, 5
S-11, S-13,
S-15
$ Medlin S-18, S-20, 3
Pond S-22
~n
":I elm
2 CJ)
~-I '!im I'D
CB/DCCR0499 8/93
• TABLE 6-5
SEDIMENT SAMPLE ANALYSIS SUMMARY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Number
Analytical Detection of Field
Parameters Method Limit Duplicates
Phenolics EPA 3550 NA
EPA 8270 (1)
PCDD/PCDF EPA 8290 various
Phenolics EPA 3550 NA 0
EPA 8270 ( 1)
PCDD/PCDF EPA 8290 various 0
Phenolics EPA 3550 NA
EPA 8270 (1)
PCDD/PCDF EPA 8290 various
Phenolics EPA 3550 NA 0
EPA 8270 ( 1)
PCDD/PCDF EPA 8290 various 0
•
Number of Number
Equipment of Trip DQO • Blanks Blanks Level Comments
0 III At each location a sample will be
collected from the surface and sub-
0 III surface (1.0-1.5 feet). Three
samples will be composited from
an area which, due to slow-moving
water, exhibits deposition.
0 0 III At each location a sample will be
collected from the surface and sub-
0 0 III surface (1.0-1.5 feet). Three
samples will be composited from
an area which, due to slow-moving
water, exhibits deposition .
0 III Samples will be collected from the • 0 to I-foot core intervals.
0 III
0 III Samples will be collected from the
0 to 1-foot core intervals.
0 III
•
Notes:
(1) EPA Method 8270 Parameters/Detection Limits:
Parameter
Phenol
2-Chlorophenol
2-Nitrophcnol
2,4-Dimethylphenol
2,4-Dichlorophenol
4-Chloro-3-Methylphcnol
• TABLE 6--5 (Continued)
SEDIMENT SAMPLE ANALYSIS SUMMARY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Detection Limit
330 ug/Kg
330 ug/Kg
330 ug/Kg
330 ug/Kg
330 ug/Kg
330 ug/Kg
Parameter
2,4, 6-Trichlorophenol
2,4-Dinitrophenol
4-N itrophenol
2,3,5 ,6-Tetrachlorophenol
4,6-Dinitro-2-Methylphenol
Pentachlorophenol
{2) Detection limits are highly matrix-dependent. The Detection limits listed may not always be achievable.
(3) One round of sediment sampling will be performed for the above noted parmeters.
NA -Not Applicable
CB/DCCR0499 8/93
Detection Limit
330 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
•
•
•
•
Sample
Fire Pond
Medlin
Pond
Notes:
Proposed
S11Dlplc
Location
SW-205, SW-208,
SW-211, SW-213,
SW-215
SW-218, SW-220,
SW-222
Number of Total
Samples per Number
Location of Samples
2 IO
2 6
(I) EPA Method 8270 Parameters/Detection Limits:
Parameter
Phenol
2-Chlorophenol
2-Nitrophenol
2,4-Dimcthylphcnol
2,4-Dichlorophenol
4-Chloro-3-Methylphenol
•
TABLE 6-6
SURFACE WATER SAMPLE ANALYSIS SUMMARY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Analyticol
Parameters Method
Phenolics EPA 3520
EPA 8270
PCDD/PCDF EPA 8290
Phenolics EPA 3520
EPA 8270
PCDD/PCDF EPA 8290
Detection Limit
IO ug/L
IO ug/L
IO ug/L
IO ug/L
IO ug/L
IO ug/L
Detection
Limit
NA
(I)
various
NA
(I)
various
Number Number of
of Field Equipment
Duplicates Blanks
2
2
0 0
0 0
Parameter
2,4,6-Trichlorophenol
2,4-Dinitrophenol
4-Nitrophenol
Number
of Trip
Blanks
0
0
0
0
2, 3,5, 6-T ctrachlorophcnol
4,6-Dinitro-2-Mcthylphenol
Pentachlorophenol
(2) Detection limits are highly matrix-dependent. The Detection limits listed may not always be achievable.
(3) One round of sediment sampling will be performed for the above noted parmeters.
NA -Nol Applicable
CB/DCCR0499 8/93
DQO
Level
Ill
Ill
Ill
Ill
•
Comments
Samples will be collected
within five feet from the
RI sediment sampling locations
S-5, S-8, S-11, S-13, and S-15.
Samples within the five feet
from the RI sediment sample
locations, S-18, S-20, and S-22.
•
Detection Limit
IO ug/L
50 ug/L
50 ug/L
50 ug/L
50 ug/L
50 ug/L
•
Proposed Number of Total
Sample Samples per Number
Sample Location Location of Samples
Fire Pond S-16A, S-16B, 2 6
Outflow S-17
Ditch
Western S-30, S-33, 2 6
Ditch S-34
Fire Pond S-5, S-8, 5
S-11, S-13,
S-15
$ Medlin S-18, S-20, 3
Pond S-22
'.EO
5 J: Elm z rn ii --i ;, m I' Il
BB/DCCR0499 8/93
• TABLE4-3
SEDIMENT SAMPLE ANALYSIS SUMMARY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Number
Aru,Jytical Detection of Field
Parameters Method Limit Duplicates
Phenolics EPA 3550 NA
EPA 8270 (1)
PCDD/PCDF EPA 8290 various
Phenolics EPA 3550 NA 0
EPA 8270 (1)
PCDD/PCDF EPA 8290 various 0
Phenolics EPA 3550 NA
EPA 8270 (i)
PCDD/PCDF EPA 8290 various
Phenolics EPA 3550 NA 0
EPA 8270 (1)
PCDD/PCDF EPA 8290 various 0
•
Number of Number
Equipment of Trip DQO • Blanks Blanks Level Comments
0 III At each location a sample will be
collected from the surface and sub-
0 III surface (1.0-1.5 feet). Three
samples will be composited from
an area which, due to slow-moving
water, exhibits deposition.
0 0 llI At each location a sample will be
collected from the surface and sub-
0 0 III surface ( 1.0-1.5 feet). Three
samples will be composited from
an area which, due to slow-moving
water, exhibits deposition .
0 III Samples will be collected from the • 0 to I-foot core intervals.
0 III
0 llI Samples will be collected from the
0 to I-foot core intervals.
0 III
•
Notes:
(I) EPA Method 8270 Parameters/Detection Limits:
Parameter
Phenol
2-Chlorophenol
2-Nitrophenol
2,4-Dimcthylphenol
2,4-Dichlorophenol
4-Chloro-3-Methylphenol
• TABLE 4-3 (Continued)
SEDIMENT SAMPLE ANALYSIS SUMMARY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Detection Lim.it
330 ug/Kg
330 ug/Kg
330 ug/Kg
330 ug/Kg
330 ug/Kg
330 ug/Kg
Parameter
2,4,6-Trichlorophenol
2,4-Dinitrophenol
4-Nitrophenol
2,3,S,6-Tctrachlorophenol
4,6-Dinitro-2-Methylphenol
Pentachlorophenol
(2) Detection limits are highly matrix-dependent. The Detection limits listed may not always be achievable.
(3) One round of sediment sampling will be performed for the above noted parmeters.
NA -Not Applicable
BB/DCCR0499 8/93
Detection Limit
330 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
1,600 ug/Kg
•
•
•
Sample
Fire Pond
Medlin
Pond
Notes:
Proposed
Sample
Location
SW-205, SW-208,
SW-211, SW-213,
SW-215
SW-218, SW-220,
SW-222
Number of TolAI
Samples per Number
Location of Samples
2 10
2 6
(I) EPA Method 8270 Parameters/Detection Limits:
Parameter
Phenol
2-Chlorophenol
2-Nitrophenol
2,4-Dimethylphcnol
2,4-Dichlorophenol
4-Chloro-3-Methylphenol
• TABLE 4-4
SURFACE WATER SAMPLE ANALYSIS SUMMARY
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Analytical
Parameters Method
Phenolics EPA 3520
EPA 8270
PCDD/PCDF EPA 8290
Phenolics EPA 3520
EPA 8270
PCDD/PCDF EPA 8290
Detection Limit
10 ug/L
10 ug/L
10 ug/L
10 ug/L
10 ug/L
10 ug/L
Detection
Limit
NA
(I)
various
NA
(I)
various
Number Number of
of Field Equipment
Duplicates Blanks
2
2
0 0
0 0
Parameter
2 ,4, 6-Trichlorophenol
2,4-Dinitrophenol
4-Nitrophenol
Number
of Trip
Blanks
0
0
0
0
2, 3,5, 6-Tctrachlorophenol
4,6-Dinitro-2-Methylphenol
Pentachlorophcnol
(2) Detection limits are highly matrix-dependent. The Detection limits listed may not always be achievable.
(3) One round of sediment sampling will be performed for the above noted parmetcrs.
NA -Not Applicable
CB/DCCR0499 8/93
DQO
Level
III
III
III
III
•
• Comments
Samples will be collected
within five feet from the
RI sediment sampling locations
S-5, S-8, S-11, S-13, and S-15.
Samples within the five feet
from the RI sediment sample
locations, S-18, S-20, and S-22.
•
Detection Limit
IO ug/L
50 ug/L
50 ug/L
50 ug/L
50 ug/L
50 ug/L
• Ktl:tlVt.U
AUG O 9 1:J:JJ
SUPERF/INDSELT/ON
Via: Federal Express
August 4, 1993
C ... STER
ENVIRONMENTAL
Ref. No. 179285-01
Ms. Beverly Hudson, Remedial Project Manager
USEP A Region IV
NC North Superfund Remedial Branch
Waste Management Division .
345 Courtland Street, NE
Atlanta, GA 30365
Dear Beverly:
Re: Monthly Progress Report #3, Remedial Design
Koppers Site -Morrisville, NC
On behalf of Beazer East, Inc. and in accordance with the Unilateral Order, please
find attached four (4) copies of the Monthly Progress Report #3 for the period
ending July 31, 1993 for the Remedial Design for Koppers Superfund Site, Morrisville NC. · ·
Should you need additional information regarding this progress report, please let
Shannon Craig at [phone] or me know.
Vety truly yours,
~C-~
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt3
Attachment
cc: Ms. Shannon K. Craig -Beazer East, Inc.
Ms. Cindy Zuch, Beazer East, Inc.
Mr. Jim Cook, Beazer East, Inc.
Mr. Bruce Nicholson -NC Superfund (Two Copies)
former!•t Keystone Environmental Resources
8600 LaSalle ROad, Suite 502
York. Building
Towson. Maryland 21286
J 10-82 '!-2900. Fa( .110-82~ -29 ~ 9
• • MONTHLY PROGRESS REPORT #3
REMEDIAL DESIGN
SITE NAME: Koppers Superfund Site
Beazer East, Inc.
Morrisville, NC
USEPA DOCKET NO: 93-09-C
PERIOD ENDING: July 31, 1993
l. PROGRESS MADE THIS MONTH
I. Remedial Design
In accordance with the Order, on July 26, 1993, Beazer sent a Certificate of Insurance for Chester Environmental, Beazer's supervising contractor.
Unit Structures and PRC (EPA's subcontractor) signed an access agreement on August 3, 1993.
Revised access agreements were sent to Crowder Construction (July 30, 1993), Lichtin Properties, Inc. (July 28, 1993), and Unit Structures (July 28, 1993). Seven new access agreements were mailed to property owners during the month of July. An additional 30 days was requested to obtain the necessary site access in a letter to Beverly Hudson, U.S. EPA, dated July 2, 1993.
A letter was sent to the U.S. EPA on July 29, 1993 concerning delays in the remedial design schedule resulting from the SITE program demonstration, the due date of the Remedial Design Work Plan (August 11, 1993), and authorization from the U.S. EPA to utilize the SITE Screening Demonstration soil and groundwater test results to partially satisfy the requirements of the Pre-Design Investigation.
Comments on PRC's draft work plan for the SITE Field Screening Technologies Demonstration were submitted to Beverly Hudson and PRC on July 22, 1993. Eric Hess, PRC, has indicated that all of Beazer's comments were incorporated into the work plan. Beazer will receive a revised copy in August.
II. Domestic Well Sampling
By letter dated July 15th, Beazer submitted domestic well results to EPA and the State of North Carolina. On July 23, EPA sent Beazer's results, as well as results from EPA and North Carolina to the eight (8) residents currently receiving bottled water.
No positive results were found ..
• • MONTHLYPROGRESSREPORT#J
(Continued)
2. PROBLEMS RESOLVED
The placement of the decontamination/containment pad for the SITE
demonstration was decided after several telephone calls and site visits by
PRC and Beazer personnel. The pad will be of tem~rary construction ana
will be approximately 40 x 70 feet. The location (Option B) is shown on
the attaclied figure. ·
3. PROBLEMS ANTICIPATED
None.
4. UPCOMING EVENTS
Beazer will continue to obtain access agreements to conduct the Remedial Design. ·
5. PERSONNEL CHANGES
None.
6. SUBCONTRACTORS
None.
7. ANALYTICAL DATA
None.
8. OTHER
By letter dated July 3rd, the schedule for completion of the RD was revised
as follows:
Fourteen ( 14) days after approval by EPA of the. RD Work Plan or
completion of the access road, whichever event occurs later, the RD will be
implemented. Beazer will mobilize to build the access road seven (7) days
following completion and demobilization of the SITE Demonstration
Program.
~lUhlL
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt3
EXISTING
TRANSFORMER\
LEGEND
-MONITORING WELL LOCATION .. -FORMER SOIL BORING LOCATION
-0--UTILITY POLE ---BEAZER EAST, INC. PROPERTY BOUNDARY
APPA BY:
R,..
6/30/93
I
SCALE i-.,------50 0
SAMPLE AREA I
(FORMER LAGOON AREA)
APPROXIMATE
FORMER LOCATION OF SANO FILTER
F I R E
SAMPLE AREA 2
(FORMER CELLON PROCESS
AND SAND FILTER Af1EA)
p 0 D
APPROXIMATE FORMER LOCATION OF TREATING CYLINDER
(FEETI
50
Q)ljG tJO .
=
•
'
.,~A CHESTER ~ ENVIRONMENTAL
SITE PLAN SOIL TREATABJLJTY STUDY FORMER KOPPERS COMPANY, INC. SITE BEAZER EAST, ]NC. MORRJSVJLLE, NC.
C69621
• ct-AtsTER
ENVIRONMENTAL
Ref. No. 179285-01
Via: Federal Express
July 2, 1993
Ms. Beverly Hudson, Remedial Project Manager
USEP A Re_gion IV
NC North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Dear Beverly:
Re: Monthly Progress Report #2, Remedial Design
Koppers Site -Morrisville, NC
On behalf of Beazer East, Inc. and in accordance with the Unilateral Order, please
find attached four (4) copies of the Monthly Progress Report #2 for the period
ending June 30, 1993 fur the Remedial Design for Koppers Superfund Site,
Morrisville NC.
Should you need additional information regarding this progress report, please let
Shannon Craig at [phone] or me know.
Very truly yours,
~l/AJlJG
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt2
Attachment
cc: Ms. Shannon K. Craig -Beazer East, Inc.
Ms. Cindy Zuch, Beazer East, Inc.
Mr. Jim Cook, Beazer East, Inc.
Mr. Bruce Nicholson -NC Superfund (Two Copies)✓
formerly Keystone Environ_menta1 Resources
8600 LaSalle Road. Suite 502
York Building
Towson, Maryland 21286
410-821·2900: Fa;,:: 410-821-2919
• •
MONTHLY PROGRESS REPORT #2
REMEDIAL DESIGN
SITE NAME: Koppers Superfund Site
Beazer East, Inc.
Morrisville, NC
USEPA DOCKET NO: 93-09-C
PERIOD ENDING: June 30, 1993
l. PROGRESS MADE THIS MONTH
I. Remedial Design
Progress was made on obtaining site access with Unit Structures. Also,
Beazer East and Chester Environmental representatives met with Crowder
Construction on June 15th to discuss site access issues. Beazer is drafting
an access agreement for Crowder. Contact was made with representatives
of Norfolk Southern Railway to obtain access.
A meeting at the site was held on June 15th to discuss the scope of the RD
Work Plan. Attending for EPA was Beverly Hudson. Representing Beazer
East were Shannon Craig, Jim Cook and Cindy Zuch. Representing Chester
Environmental was Johri Mitsak. During the meeting, we visited EnSY.s for
a demonstration of their. ImmunoAssay field test kits which will be
proposed for field testing of pentachlorophenol during Remedial Design.
By letter dated June 18th, the Remedial Design Work Plan for the site was
submitted to EPA and the State of North Carolina.
On June 29th, Beazer obtained title to the property acquired from Unit
Structures. By letter dated December 17, 1992, Beazer East informed EPA
of their plans to construct a roadway for permanent access to the site. Now
that the property has been titled to Beazer, construction could start as early
as mid July.
A telephone conference between Beazer East, EPA Region IV and EP A's
Risk Reduction Engineering Laboratory was held to discuss the proposed
pilot treatability study to be conducted at the site. It was I · at a
Work Plan would be submitted b the SITE Pro am-· n Ju
9 . 0 · 1za on o eq · 1s en a veiy_ sc eduled for August 2n · 7 ·
Toconduct the pilot study iv to 15 cubic yards of soil will be required. A
week-long pilot study is envisioned. Issues discussed included location of a
40 foot by 100 foot decon pad, utility requirements, access, planned public
participallon and technical economic objectives of the study. A follow-up ...,,J '<-
telep~hone :nfircr~~~ R_ Ju~l f iiu,-/ f~i:t ... ;)
aO{ ~ 111 ~ ~s;~lt..
(e,aSt l . , 11
( 11 tlJ --::p cf'~"' r1,,..t /) ,,,.J (e 1,MAl-u' t,..i.,V . \ n D QI~ ~*
LVV ·i{;:'7 W<Yhlt 1k:, fo':6 1 bU--rev:~ 1+.
• •
MONTHLY PROGRESS REPORT #2
(Continued)
2. PROBLEMS RESOLVED
None.
3. PROBLEMS ANTICIPATED
None.
4. UPCOMING EVENTS
5.
Beazer will continue to obtain access agreements to conduct the Remedial
Design.
PERSONNEL CHANGES
None.
6. SUBCONTRACTORS
None.
7. ANALYTICAL DAT A
None.
8. OTHER
During the week of June 8th, Beazer East sampled thirty-six (36) domestic
wells m Morrisville. Split samples were taken by both EPA and Wake
County Health Department of the eight (8) domestic wells currently
receivmg bottled water. Analytical resuTts are anticipated the week of July
4th.
~c~
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt2
•
. ' • C~STER
ENVIRONMENTAL
Ref. No. 179285-01
Via: Federal Express
July 2, 1993
Ms. Beverly Hudson, Remedial Project Manager
USEP A Region IV
NC North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Dear Beverly:
Re: Monthly Progress Report #2, Remedial Design
Koppers Site -Morrisville, NC
tttt:tuv1:.o
JUL O 7 1993
SUP£RF11rvo SEC110N
On behalf of Beazer East, Inc. and in accordance with the Unilateral Order, please
find attached four (4) copies of the Monthly Progress Report #2 for the period
ending June 30, 1993 for the Remedial Design for Koppers Superfund Site,
Morrisville NC. .
Should you need additional infonnation regarding this progress report, please let
Shannon Craig at [phone] or me know.
Very truly yours,
~l/)JJJG
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt2
Attachment
cc: Ms. Shannon K. Craig -Beazer East, Inc.
Ms. Cindy Zuch, Beazer East, Inc.
Mr. Jim Cook, Beazer East, Inc. /
Mr. Bruce Nicholson -NC Superfund (Two Copies)
torrnerly Keystone Environmental Resources
8600 LaSalle Road, Suite 502
York Building
Towson, Maryland 21286
410·8~9□0: Fax [phone]
• •
MONTHLY PROGRESS REPORT #2
REMEDIAL DESIGN
SITE NAME: Koppers Superfund Site
Beazer East, Inc.
Morrisville, NC
USEPA DOCKET NO: 93-09-C
PERIOD ENDING: June 30, 1993
1. PROGRESS MADE THIS MONTH
I. Remedial Design
Progress was made on obtaining site access with Unit Structures. Also,
Beazer East and Chester Environmental representatives met with Crowder
Construction on June 15th to discuss site access issues. Beazer is drafting
an access agreement for Crowder. Contact was made with representatives
of Norfolk Southern Railway to obtain access.
A meeting at the site was held on June 15th to discuss the scope of the RD
Work Plan. Attending for EPA was Beverly Hudson. Representing Beazer
East were Shannon Craig, Jim Cook and Cindy Zuch. Representing Chester
Environmental was Johri Mitsak. During the meeting, we visited EnSY.s for
a demonstration of their ImmunoAssay field test kits which will be
proposed for field testing of pentachlorophenol during Remedial Design.
By letter dated June 18th, the Remedial Design Work Plan for the site was
submitted to EPA and the State of North Carolina.
On June 29th, Beazer obtained title to the property acquired from Unit
Structures. By letter dated December 17, 1992, Beazer East informed EPA
of their plans to construct a roadway for permanent access to the site. Now
that the property has been titled to Beazer, construction could start as early
as mid July.
A telephone conference between Beazer East, EPA Region IV and EP A's
Risk Reduction Engineering Laboratory was held to discuss the proposed
pilot treatability study to be conducted at the site. It was learned that a
Work Plan would be submitted by the SITE Program Contractor on July
9th. Mobilization of equipment 1s tentatively scheduled for August 2nd.
To conduct the pilot study 10 to 15 cubic yards of soil will be required. A
week-long pilot study is envisioned. Issues discussed included location of a
40 foot by 100 foot decon pad, utility requirements, access, planned public
participation and technical economic objectives of the study. A follow-up
telephone conference was held on July 1.
• •
MONTHLY PROGRESS REPORT #2
(Continued)
2. PROBLEMS RESOL YEO
None.
3. PROBLEMS ANTICIPATED
None.
4. UPCOMING EVENTS
Beazer will continue to obtain access agreements to conduct the Remedial
Design.
5. PERSONNEL CHANGES
None.
6. SUBCONTRACTORS
None.
7. ANALYTICAL DAT A
None.
8. OTHER
During the week of June 8th, Beazer East sampled thirty-six (36) domestic
wells m Morrisville. Split samples were taken by both EPA and Wake
County Health Department of the eiJUJt (8) domestic wells CUITently
receivmg bottled water. Analytical resuTts are anticipated the week of July
4th.
~cUhaL
John C. Mitsak, P.E.
Manager, Baltimore Operations
JCM:ralrpt2
.. TO: Remedial Project Manager
NC/SC Site-Management Unit
Superfund Branch, Waste
Management Division
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30308
Dear Ms. Hudson:
SUPERfllND SEtTION
DATE June 21, · 1993
JOB NO. 179285-01
. ATTENTION Ms. Beverly Hudson
RE Draft Remedial Design
Work Plan
We are sending 0 herewith D under separate cover the following items:
D Drawings D Plans □
Copies Drawing No.
12 Page 5-9 of Appendix A.l (FSP)
.
..
These are transmitted as checked below:
□ Approved □ Not Approved D For Review & Comment
□ Approved as Corrected □ Contractor Coordination Req'd □ For Approval
□ Revise and Resubmit □ Drawing Revision Forthcoming D
□ As requested 0 For your use ,
Rem.arks Ms. Hudson:
··This page was inadvertently omitted from Appendix A.l
(Field Sampling Plan) of the Draft Remedial Design Work Plan
submitted to you yesterday.
By
cc: B. Nicholson
Cover!
''
3000 Tech Center Drive ·
Monroeville, Pennsylvania 15148
. 412-825-9600: Fax [phone]
•
•
•
• •
5.4.2 Completing the Trip Report
The Field Team Leader is responsible for a brief summary of the sampling event,
prepared to serve as a cover page for all project-specific data, such as:
■ Signed Project Notes Sheets;
■ Field Data Sheets;
■ Chain-of-custody sheets; and,
■ Other pertinent information, as necessary .
Raleigh/FSP
179825--01 CB/DCC#R0499 6/93 5-9 CHESTER
ENVIRONMENTAL
•
•
•
•
5.4.2 Completing the Trip Report
The Field Team Leader is responsible for a brief summary of the sampling event,
prepared to serve as a cover page for all project-specific data, such as:
a Signed Project Notes Sheets;
■ Field Data Sheets;
■ Chain-of-custody sheets; and,
■ Other pertinent information, as necessary .
Ralcigh/FSP
179825-01 CB/DCC#R0499 6/93 5-9 CHESTER
ENVIRONMENTAL
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY~ Mi\R Q 1 \993 §)
REGION IV ,.~ //~f/ FEB 2,3 1003
4RC
345 COURTLAND STREET. N.E. ~ .:,."< ATLANTA, GEORGIA 30365 O,s, 'f"°'t''
NOTICE LETTER FOR REMEDIAL DESIGN/REMEDIAL ACTION (RD/nl NOTICE OF DECISION NOT TO USE SPECIAL NOTICE PROCEDURES URGENT LEGAL MATTER--PROMPT REPLY REQUESTED CERTIFIED MAIL--RETURN RECEIPT REQUESTED
Mr. Craig L. Sparks
General Counsel
Unit Structures, Inc.
Four Market Center
Jeffersonville; Indiana 47130
o~souo~r,.t/";
RE: The Koppers Co., Inc., (Morrisville Plant) Superfund Site Morrisville, Wake County, North Carolina
Dear Mr. Sparks:
The purpose of this letter is to notify you of the potential liability as defined by Section 107(a) of the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), 42 u.s.c. § 9607(a), as amended, that Unit Structures, Inc., ( "USI") may have incurred with respect to the Koppers Co., Inc., (Morrisville Plant) Superfund site (''Site").
As the enclosed Record of Decision ("ROD") details, the United States Environmental Protection Agency ("EPA") has documented the release or threatened release of hazardous substances, pollutants and contaminants at the above-referenced Site. EPA is considering spending public funds to abate the releases or threatened releases of hazardous substances, pollutants or contaminants by undertaking the response actions pursuant to Section 104 of CERCLA, 42 U.S.C. § 9604, unless the Agency determines that such action will be done properly by USI. By this letter, EPA is notifying USI of the opportunity to perform the response activities outlined below.
In addition, this letter serves three other purposes: first, to demand reimbursement of response costs that have been incurred at the Site, including interest thereon; second to notify USI that a 30-day period of formal negotiations with EPA automatically begins upon receipt of this notice, which EPA has deemed to be five calendar days from the date of this letter; and third, to provide general and site-specific documentation in order to assist USI in the negotiation process. Such documentation includes a draft Consent Decree, a copy of the ROD, and a draft Scope of Work. EPA reserves the right to make certain additional changes in the Consent Decree and Scope of Work prior to finalization of such documents.
Printed on Recycled Paper
• • 2
NOTICE OF POTENTIAL LIABILITY
Potentially Responsible Parties ("PRPs") under CERCLA include:
the current owners or operators of the Site; persons who at the
time of disposal of hazardous substances owned or operated the
facility; persons who by contract, agreement, or otherwise
arranged for disposal or treatment, or arranged with a
transporter for disposal or treatment of hazardous substances;
and persons who accept or accepted any hazardous substance for
transport to disposal facilities and selected such facilities.
Under CERCLA and other laws, PRPs may be liable for all funds
expended by the United States government to take necessary
corrective action at a site, including planning, investigation,
cleanup and enforcement activities associated with a site. In
addition, PRPs may be required to pay damages for injury to
natural resources or for their destruction or loss,. together with
the cost of assessing such damages.
Based on information received during the investigation of this
Site, EPA believes that USI is the current owner of part of the
Site and a responsible party under Section 107 of CERCLA, 42
U.S.C. § 9607(a). Before the government undertakes further
response actions, EPA requests that USI voluntarily performs the
work necessary to prevent any releases or threatened releases of
hazardous substances from the Site.
DECISION NOT TO USE SPECIAL NOTICE PROCEDURES
ABBREVIATED NEGOTIATION MORATORIUM
•
EPA is also sending a Notice Letter to Beazer East, Inc. EPA's
contact with Beazer East, Inc., is:
William F. Giarla
Law Department
Beazer East, Inc.
436 Seventh Avenue
Pittsburgh, PA 15219
EPA encourages good faith negotiations between EPA and USI and
between USI and Beazer East, Inc., regarding the response actions
required at the Site. EPA has determined that a period of
negotiation would facilitate settlement between the parties.
Under Section 122(e) of CERCLA, 42 U.S.C. § 9622(e), EPA has
discretionary authority to invoke special notice procedures to
formally negotiate the terms of an agreement between EPA and a
PRP or PRPs to conduct or finance response activities. Use of
these special notice procedures triggers a sixty day moratorium
on certain EPA activities at the Site while formal negotiations
between .EPA and the PRP or PRPs are conducted.
EPA has decided not to invoke the Section 122(e) special notice
procedures for this negotiation. EPA has determined that the
sixty day moratorium, which is triggered by the invocation of the
special notice procedures, is not appropriate for the negotiation
. ' '. • -3-
of this Consent Decree.· Beazer has performed the Remedial
Investigation and Feasibility Study for this Site. Additionally,
EPA is issuing Notice Letters to only two PRPs. For these
reasons, negotiations of a Consent Decree for this Site is
greatly simplified. In light of these conditions, use of the
full Section 122(e) negotiation moratorium is unnecessary.
EPA has determined that a thirty (30) day period of formal
negotiation is adequate to facilitate settlement between EPA and
USI. Therefore, in lieu of the Section 122(e) special notice
procedures and sixty day moratorium, EPA will adhere to a thirty
(30) day moratorium on certain EPA response activities at the
Site. EPA deems this moratorium to begin within five (5) days of
your receipt of this letter. During this thirty (30) day
moratorium, USI is invited to negotiate a settlement under which
USI will conduct or finance the RD/RA for this Site •. This thirty
(30) day negotiation period will be extended for an additional
thirty (30) days, if, within the initial thirty (30) day period,
USI provides EPA with a good faith offer to conduct or finance
the RD/RA. If a settlement is reached within that total sixty
(60) day period, that settlement will be embodied in a consent
decree for the RD/RA.
If a good faith offer is not received within the initial 30-day
notice period, EPA may take appropriate action at the Site.
Moreover, EPA reserves the right to take action at any time at
the Site in the event that a significant threat requiring EPA's
immediate response arises.
A good faith offer is a written proposal which demonstrates USI's
qualifications and willingness to conduct or finance the RD/RA.
A good faith offer to conduct or finance the RD/RA must include
the following elements:
l. A statement of willingness by USI to conduct or finance
the RD/RA which is consistent with the draft Consent
Decree provided as Enclosure A to this letter, the ROD
provided as Enclosure B to this letter, and the
Statement of Work provided as Enclosure C to this
letter, and which provides a sufficient basis for
further negotiations.
2. A response to the terms of the draft Consent Decree and
enclosed Scope of Work.
3. A demonstration of USI's technical capability to carry
out the RD/RA including the identification of the
firm(s) that would be used to conduct the work or a
description of the process that will be used to select
the firm(s).
• • -4-
4. A demonstration of USI's capability and willingness to
finance the RD/RA.
5. A statement of USI's willingness to reimburse EPA for
costs incurred in overseeing USI's conduct of the
RD/RA.
6. The name, address and telephone number of the person
who will represent USI in negotiations.
ADMINISTRATIVE RECORD
Pursuant to Section 113(k) of CERCLA, EPA has compiled the
administrative record which contains documents that form the
basis of EPA's decision on the selection of a response action for
the Site. This administrative record is open to the public for
inspection and comment at the EPA Region IV Library, 345
Courtland Street, N.E., Atlanta, Georgia, and at the Cary Branch
of the Wake County Public Library, 310 South Academy Street,
Cary, North Carolina.
DEMAND FOR PAYMENT
In accordance with CERCLA, EPA has already undertaken certain
actions and incurred costs in response to conditions at this
Site. Those response actions include the oversight of the
conduct of the Remedial Investigation/Feasibility Study (the
"RI/FS") and certain removal activities by Beazer. The cost to
date of the response actions performed at the Site prior to
October 31, 1992, through EPA funding, is approximately
$786,110.52. Pursuant to Section 107 of CERCLA, 42 U.S.C.
§ 9607, EPA hereby demands payment of the above-stat.ed amount,
together with any and all interest recoverable by law.
As stated above, EPA anticipates expending additional funds to
conduct the RD/RA at this Site. Whether EPA funds the entire
RD/RA or simply incurs costs in overseeing the parties conducting
these response activities, USI is potentially liable for these
expenditures plus interest.
PRP RESPONSE AND EPA CONTACT PERSON
Pursuant to this Notice Letter, USI has thirty (30) days to make
a good faith offer to EPA. However, USI is requested to contact
EPA in writing within fifteen (15) calendar days of the date of
this letter to indicate whether USI wishes to participate in
negotiations to undertake or finance the RD/RA at this Site. EPA
is.willing to meet with Beazer.on at 10:00 a.m. on March 3, 1993,
at EPA's offices in Atlanta, Georgia, to discuss the response
activities being-required and the potential settlement. USI's
response should include the appropriate person's name, address
and telephone number for further contact with USI.
• -5-•
If EPA does not receive a timely'response, EPA will assume that
USI does not wish to negotiate a resolution of its liabilities in
connection with the response, and that USI has declined any
involvement in performing these response activities. USI may be
held liable hereafter under Section 107 of CERCLA, 42 U.S.C.
§ 9607,. for the cost of the response actions which EPA performs
at the Site and for any damages to natural resources.
The response to this notice letter should be sent to:
Charles V. Mikalian
Assistant Regional Counsel
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
404/347-2641,_ ext. 2269
If you have any legal questions pertaining to this matter, please
direct them to Mr. Mikalian. Questions of a technical nature
only should be directed to Barbara Benoy, Remedial Project
Manager at 404/347-7791.
Due to the seriousness of the problem at the Site and the legal
ramifications of USI's failure to respond promptly, EPA strongly
encourages USI to give this matter immediate attention ·and that
USI representatives respond within the time specified above.
Thank you for your cooperation in this matter.
~e\,......._~1....._,:,-....;:,o.JT, I
Joseph R. Franzmathes, Director
Waste Management Division
Enclosures
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY.
FEB 2 :J 1993
4RC
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
NOTICE LETTER FOR REMEDIAL DESIGN/REMEDIAL ACTION (RD/RA)
NOTICE OF DECISION NOT TO USE SPECIAL NOTICE PROCEDURES
URGENT LEGAL MATTER--PROMPT REPLY REQUESTED
CERTIFIED MAIL--RETURN RECEIPT REQUESTED
Mr. William F. Giarla
Law Department
Beazer East, Inc.
436 Seventh Avenue
Pittsburgh, PA 15219
RE: The Koppers Co., Inc., (Morrisville Plant) Superfund Site
Morrisville, Wake County, North Carolina
Dear Mr. Giarla:
The purpose of this letter is to notify you of the potential
liability as defined by Section 107(a) of the Comprehensive
Environmental Response, Compensation, and Liability Act
( "CERCLA"), 42 U.S.C. § 9607 (a), as amended, that Beazer East,
Inc., ("Beazer") may have incurred with respect to the Koppers
Co., Inc., (Morrisville Plant) Superfund site ("Site").
As the enclosed Record of Decision ("ROD") details, the United
States Environmental Protection Agency ("EPA") has documented the
release or threatened release of hazardous substances, pollutants
and contaminants at the above-referenced Site. EPA is
considering spending public funds to abate the releases or
threatened releases of hazardous substances, pollutants or
contaminants by undertaking the response actions pursuant to
Section 104 of CERCLA, 42 u.s.c. § 9604, unless the Agency
determines that such action will be done properly by Beazer. By
this letter, EPA is notifying Beazer of the opportunity to
perform the response activities outlined below.
In addition, this letter serves three other purposes: first, to
demand reimbursement of response costs that have been incurred at
the Site, including interest thereon; second to notify Beazer
that a 30-day period of formal negotiations with EPA
automatically begins upon receipt of this·notice, which EPA has
deemed to be five calendar days from the date of this letter; and
third, to provide general and site-specific documentation in
order to assist·Beazer in the negotiation process. Such
documentation includes a draft Consent Decree, a copy of the ROD,
and a draft Scope of Work. EPA reserves the right to make
certain additional changes in the Consent Decree and Scope of
Work prior to finalization of such documents.
Printed on Recycled Paper
• 2
NOTICE OF POTENTIAL LIABILITY
Potentially Responsible Parties ("PRPs") under CERCLA include:
the current owners or operators of the Site; persons who at the,
time of disposal of hazardous substances owned or operated the
facility; persons who by contract, agreement, or otherwise
arranged for disposal or treatment, or arranged with a
transporter for disposal or treatment of hazardous substances;
and persons who accept or accepted any hazardous substance for
transport to disposal facilities and selected such facilities.
Under CERCLA and other laws, PRPs may be liable for all funds
expended by the United States government to take necessary
corrective action at a site, including planning, investigation,
cleanup and enforcement activities associated with a site. In
addition, PRPs may be required to pay damages for injury to
natural resources or for their destruction or loss, together with
the cost of assessing such damages.
Based on information received durin'g the investigation of this
Site, EPA believes that Beazer is the past and current owner and
operator of the Site and a responsible party under Section 107 of
CERCLA, 42 u.s.c. § 9607(a). Before the government undertakes
further response actions, EPA requests that Beazer voluntarily
performs the work necessary to prevent any releases or threatened
releases of hazardous substances from the Site.
DECISION NOT TO USE SPECIAL NOTICE PROCEDURES
ABBREVIATED NEGOTIATION MORATORIUM
EPA is also sending a Notice Letter to Unit Structures, Inc.
EPA's contact with Unit Structures, Inc., is:
Craig L. Sparks
General Counsel
Unit Structures, Inc.
Four Market Center
201 East Market Street
Jeffersonville, Indiana 47130
EPA encourages good faith negotiations between EPA and Beazer and
between Beazer and Unit Structures, Inc., regarding the response
actions required at the Site. EPA has determined that a period
of negotiation would facilitate settlement between the parties.
Under Section 122(e) of CERCLA, 42 u.s.c. § 9622(e), EPA has
discretionary authority to invoke special notice procedures to
formally negotiate the terms of an agreement between EPA and a
PRP or PRPs to conduct or finance response activities. Use of
these special notice procedures triggers a sixty day moratorium
on certain EPA activities at the Site while formal negotiations
between EPA and the PRP or PRPs are conducted.
EPA has decided not to invoke the Section 122(e) special notice
procedures for this negotiation. EPA has determined that the
sixty day moratorium, which is triggered by the invocation of the
• • -3-
special notice procedures, is not appropriate for the negotiation
of this Consent Decree. Beazer is the current owner and operator
of the portions of the Site requiring response actions and has
performed the Remedial Investigation and Feasibility Study for
this Site. Additionally, EPA is issuing Notice Letters to only
two PRPs. For these reasons, negotiations of a Consent Decree
for this Site is greatly simplified. In light of these
conditions, use of the full Section 122(e) negotiation moratorium
is unnecessary.
EPA has determined that a thirty (30) day period of formal
negotiation is adequate to facilitate settlement between EPA and
Beazer. Therefore, in.lieu of the Section 122(e) special notice
procedures and sixty day moratorium, EPA will adhere to a thirty
(30) day moratorium on certain EPA response activities at the
Site. EPA deems this moratorium to begin within five (5) days of
your receipt of this letter. During this thirty (30) day
moratorium, Beazer is invited to negotiate a settlement under
which Beazer will conduct or finance the RD/RA for this Site.
This thirty (30) day negotiation period will be extended for an
additional thirty (30) days, if, within the initial thirty (30)
day period, Beazer provides EPA with a good faith offer to
conduct or finance the RD/RA. If a settlement is reached within
that total sixty (60) day period, that settlement will be
embodied in a consent decree for the RD/RA.
If a good faith offer is not received within the initial 30-day
notice period, EPA may take appropriate action at the Site.
Moreover, EPA reserves the right to take action at any time at
the Site in the event that a significant threat requiring EPA's
immediate response arises.
A good faith offer is a written proposal which demonstrates
Beazer's qualifications and willingness to conduct or finance the
RD/RA. A good faith offer to conduct or finance the RD/RA must
include the following elements:
1. A statement of willingness by Beazer to conduct or
finance the RD/RA which is consistent with the draft
Consent Decree provided as Enclosure A to this letter,
the ROD provided as Enclosure B to this letter, and the
Statement of Work provided as Enclosure C to this
letter, and which provides a sufficient basis for
further negotiations.
2. A response to the terms of the draft Consent Decree and
enclosed Scope of Work.
3. A demonstration of Beazer's technical capability to
carry out the RD/RA including the identification of the
firm(s) that would be used to conduct the work or a
• • -4-
description of the process that will be used to select
the firm( s) •
4. A demonstration of Beazer's capability and willingness
to finance the RD/RA.
5. A statement of Beazer's willingness to reimburse EPA
for costs incurred in overseeing Beazer's conduct of
the RD/RA.
6. The name, address and telephone number of the person
who will represent Beazer in negotiations.
ADMINISTRATIVE RECORD
Pursuant to Section 113(k) of CERCLA, EPA has compiled the
administrative record which contains documents that form the
basis of EPA's decision on the selection of a response action for
the Site. This administrative record is open to the public for
inspection and comment at the EPA Region IV Library, 345
Courtland Street, N.E., Atlanta, Georgia, and at the Cary Branch
of the Wake County Public Library, 310 South Academy Street,
Cary, North Carolina.
DEMAND FOR PAYMENT
In accordance with CERCLA, EPA has already undertaken certain
actions and incurred costs in response to conditions at this
Site. Those response actions include the oversight of the
conduct of the Remedial Investigation/Feasibility Study (the
"RI/FS") and certain removal activities by Beazer. The cost to
date of the response actions performed at the Site prior to
October 31, 1992, through EPA funding, is approximately
$786,110.52. Pursuant to Section 107 of CERCLA, 42 U.S.C.
§ 9607, EPA hereby demands payment of the above-stated amount,
together with any and all interest recoverable by law.
As stated above, EPA anticipates expending additional funds to
conduct the RD/RA at this Site. Whether EPA funds the entire
RD/RA or simply incurs costs in overseeing the parties conducting
these response activities, Beazer is potentially liable for these
expenditures plus interest.
PRP RESPONSE AND EPA CONTACT PERSON
Pursuant to this Notice Letter, Beazer has thirty (30) days to
_make a good faith offer to EPA. However, Beazer is requested to
contact EPA in writing within fifteen (15) calendar days of the
date of this letter to indicate whether Beazer wishes to
participate in negotiations to undertake or finance the RD/RA at
this Site. EPA is willing to meet with Beazer on at 10:00 a.m.
on March 3, 1993, at EPA's offices in Atlanta, Georgia, to
• • -5-
discuss the response activities being required and the potential
settlement. Beazer's response should include the appropriate
person's name, address and telephone number for further contact
with Beazer.
If EPA does not receive a timely response, EPA will assume that
Beazer does not wish to negotiate a resolution of its liabilities
in connection with the response, and that Beazer has declined any
involvement in performing these response activities. Beazer may
be held liable hereafter under Section 107 of CERCLA, 42 U.S.C.
§ 9607, for the cost of the response actions which EPA performs
at the Site and for any damages to natural resources.
The response to this notice letter should be sent to:
Charles v. Mikalian
Assistant Regional Counsel
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
404/347-2641, ext. 2269
If you have any legal questions pertaining to this matter, please
direct them to Mr. Mikalian. Questions of a technical n.ature
only should be directed to Barbara Benoy, Remedial Project
Manager at 404/347-7791.
Due to the seriousness of the problem at the Site and the legal
ramifications of Beazer's failure to respond promptly, EPA
strongly encourages Beazer to give this matter immediate
attention and that Beazer representatives respond within the time
specified above.
Thank you for your cooperation in this matt.er.
' w;\,~~.\ \
Joseph R. Frans=thea, Directo~/W\
Waste Management Division
Enclosures
BEAZER EAST, INC., 436 SEVENTH A VENUE. PITTSBURGH, PA I 52 I 9 USA
Dear Mr. Tobin:
February 11, 1991
Patrick M; Tobin
Director
CERTIFIED MAIL
RETURN RECEIPT
REQUESTED
Waste Management Division
US Environmental Protection Agency
Region IV·
345 Courtland street, NE
Atlanta, GA 30365
Re: Administrative Order on Consent
U.S. EPA Docket No. 89-20-C
Pursuant to the subject Administrative Order on Consent ("AOC"),
·please find attached on behalf of Beazer East, Inc. (former by
named Beazer Materials and Services, Inc.) the final report and
description of work on the subject order.
Trusting the enclosed report meets with your approval, I
anticipate written notification from your office confirming that
Beazer has satisfied the terms and conditions of the AOC, and
that the AOC is therefore terminated.
If additional copies of this report are needed, please do not
hesitate to contact me at 412/227-2690.
Sincerely,
~:::::~~~
Program Manager-Environmental Services
/lpd
cc: M. Norman -EPA Region IV
P. DeRosa -NCDEHNR
B. Giarla w/o encl.
J. Mitsak w/o encl.
BNK w/o encl.
B. Fisher w/o encl.