NCD003200383_19980811_Koppers Co. Inc._FRBCERCLA RA_Work Plan for a Toxicity Reduction Evaluation-OCR

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· Work-.Plan ·tor a Toxicity Reduction
Evaluation _ (TRE) .· at the. -Former
Koppers Company, Inc~ Superfurid
Site, Morrisville, NC.
Prepared by: ·
. Remediation Technologies, Inc.
3040 William Pitt Way
Pitt_sburgh, PA 15238.
. RETEC Project No.: -3-3815-000
Prepared for:
Beazer East, Inc:
One Oxford Centre .
301 Grant Street, Suite 3000 ·
Pittsburgh,PA 15219.
.August 11, 1998
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AUG 13 7998
SUh .. ,1ru,,u bt:CTION
Work Plan for a Toxicity Reduction
Evaluation (TRE) at the Former
Koppers Company, Inc. Superfund
Site, Morrisville, NC
Prepared by:
Remediation Technologies, Inc.
3040 William Pitt Way
Pittsburgh, PA 15238
RETEC Project No.: 3-3815-000
Prepared for:
Beazer East, Inc.
One Oxford Centre
301 Grant Street, Suite 3000
Pittsburgh, PA 15219
Prepared by:
Author's Name, Titl-7
Technically Reviewed by:
eviewer's Name, Title
August 11, 1998 F:IPROJECTS\3-3815\RALEIGH.WPD
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Table of Contents
l Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
2 Site Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
3 Scope of Work .................................................. 3-1
3.1 Task I -Data Compilation/Information Gathering . . . . . . . . . . . . . . . . 3-1
3.2 Task 2-Toxic Identification/Evaluation (TIE) .................... 3-1
3.3 Task 3 -Data Evaluation/Reponing ........................... 3-2
4 Proposed Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
Appendix A: DEHNR -Whole Effluent Toxicity Reduction Guidance
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List of Figures
2-1 Process Flow Diagram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2
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1 Introduction
This work plan presents the scope of work to perform a Toxicity Reduction
Evaluation (TRE) at the Beazer East, Inc. (Beazer) site located in Morrisville,
North Carolina. This work plan has been prepared by Remediation Technologies,
Inc. (RETEC) on behalf of Beazer.
A groundwater corrective action is currently in place at the Raleigh site which
includes a groundwater pump and treat system. The treated groundwater
(effluent) from this system is discharged through a NPDES outfall governed by
the North Carolina Department of Environmental, Health, and Natural Resources
(DEHNR). As part of the NPDES permit, periodic chronic toxicity tests (i.e.,
North Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Bioassay) are to be
performed on the treated effluent. As a result of recent ( 1997/1998) toxicity
tests, several "failed" results were indicated. As a result of these "failed" tests,
Beazer has been directed by the DEHNR to conduct a TRE with the goal of
reducing observed chronic toxicity in the treated effluent.
The remainder of this work plan includes:
Introductio,z
2 Site Description -brief description of the site and groundwater
treatment svstem. ;
3 Scope of 'Nork -presents the tasks to be completed for the TRE.
4 Proposed Schedule -presents the anticipated schedule to complete
the TRE.
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2Site Description
The Raleigh site is a former laminating plant that has produced glue-laminated
wood products since 1962. The site is located in the town of Morrisville, North
Carolina. A wood treating plant, consisting of a single treatment cylinder, was
operated in the southeast section of the property from 1968 to 1975. Treatment
was completed using the Cellon process which consisted of pressure injection of
pentachlorophenol ( PCP) in a liquified butane carrier. The Cell on process was
discontinued and dismantled in 1975. In 1989, the site was placed on the
National Priorities List and in 1992 a ROD was issued for site remedies. Prior to
1989, several remedial activities were performed at the site. These included land
treatment of lagoon sludges and impacted soils along with subsequent off-site
disposal of these soils.
Currently there is a groundwater pump and treat system being operated at the
site. This system was installed in late 1996. Figure 2-1 shows the process flow
diagram for the system. This system consists of a single groundwater extraction
well, a 1500 gallon equalization tank, two cartridge filters, and carbon adsorbers
prior to a NPDES outfall. The average treatment flowrate is approximately 7
gpm. The extraction well pump is activated by water level sensors.
Site Description 2-1
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3 Scope of Work
In order to conduct the TRE, the following tasks will be completed:
• Task 1 -Data Compilation/Information Gathering
• Task 2 -Toxic Identification/Evaluation (TIE)
• Task 3 -Data Evaluation/Reponing
A copy of the North Carolina DEHNR Whole Effluent Toxicity Guidance
Document, which was referenced for this work plan, is present in Appendix A.
3.1 Task 1 -· Data Compilation/Information Gathering
The first step of the TRE is to assemble and evaluate all applicable information
regarding the inf1uent/effluent characteristics and treatment system. Information
such as treatment system design criteria, process f1ow diagrams, descriptions of
treatment system components, influent and effluent flow data, influent and
effluent chemical characteristics and removal efficiencies, previous toxicity results,
sampling procedures, and housekeeping will be collected. This task will also
include a visit to the site by RETEC personnel.
During Task 1, it is proposed to obtain groundwater samples from two upgradient
wells for toxicity testing. The results of this testing would be used to determine
whether there may be some naturally occurring or offsite conditions that are
causing the treated groundwater to fail the toxicity test, rather than any site-
related conditions. The two upgradient wells will be selected based upon a review
of ~he site data. These samples will be collected at the same time as the next
scheduled eff1uent toxicity test sampling to look for any connection between the
results. The data collected during Task I will be evaluated to assist in the
identification of potential sources of toxicity. The need for funher testing will be
determined based upon the results of Task I.
3.2 Task 2-Toxic Identification/Evaluation (TIE)
If the results of Task l does not readily reveal the source of effluent toxicity, the
next step would be to perform a Toxic Identification/Evaluation (TIE). The TIE
consists of a series of chemical analvsis/toxicitv tests to identifv or rule out • ✓ ✓
possible toxicants. As pan of the TIE, the follmving streams will be sampled:
Scope of Work 3-1
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Stream
Work Plan for a Toxicity Reduction Evaluation (TR£) at
Beazer East, Inc., Raleigh, NC Site
Analysis
Influent/Effluent Acid Extractable Organics (GC!MS EPA Method
625/SIM)
Volatile Organics (GC/MS EPA Method 624)
pH
Conductivitv ,
TAL metals (Method 200.7/245.1)
Toxicity Tests (N.C. Ceriodaphnia Chronic
Pass/Fail Reproduction Bioassy)
3.3 Task 3 -Data Evaluation/Reporting
Following Task 2, all of the data will be evaluated in order to identify the source
of the toxicity. Depending upon the toxicity source, recommendations will be
presented to address effluent toxicity. This recommendation will be presented in
a report to the North Carolina DEHNR for their review. This report will also
include the results of Tasks l and 2 along with a rationale for selecting the
recommendation.
Scope of Work 3-2
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4Proposed Schedule
Following approval of this work plan by the DEHNR, RETEC will begin Task I.
Task I (which includes information gathering, site visit, and toxicity testing of
two upgradient wells) will be completed within 4 weeks. Task 2 (TIE) will then
be initiated and will be completed within 6 weeks (allowing for 4 weeks for
receipt of analytical results). The report will be generated (Task 3) within 3
weeks following Task 3.
Proposed Schedule 4-1
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Appendix A
DEHNR -Whole Effluent Toxicity Reduction Guidance
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
NA
D E N R
WHOLE EFFLUENT TOXICITY REDUCTION GUIDANCE Rev. 12/97
This document has been prepared by the N.C. Water Quality Section ·s Aquatic Toxicology Uni I to aid
NPDES permittccs, their consultants. and state regulatory staff with the development of whole eflluent toxicity
identification and reduction plans. As has been the operating strategy of the Water Quality Section in the past. this
document will not attempt to present a strictly defined procedure to accomplish toxicity reduction, as such defined
processes limit the ability to design programs custom fitted to the situation of each discharge. Rather. this
document will attempt to present a series of logical steps that can be initiated to help track cffiucnt toxicity sources.
trends, and investigate possible avenues of to:-.:icity reduction. Nearly all steps presented herein have originally
been described by documents published by the U.S. Environmental Protection Agency including:
Mount. D.I. and L. Anderson-Carnahau. 1988. Methods for Aquatic Toxicity Idenlificalion Evaluations:
Phase I. Toxicity Characterization Procedures. EPN600/3-88/034. Sept 1988. Environmental Research
Laboratory, Duluth. Minn.
United States Environmental Protection Agency. Toxicity Identification Evaluation: Characterization of
Chronically Toxic Eilluents, Phase I. EP N601l/6-9 l/005F. May 1992. EPA Office of Research and
Development. Washington. D.C.
United Stales Environmental Protection Agency. 1989. Methods for Aquatic Toxicity Identification
Evaluations-Phase Ill Toxicity Confirmation Procedures. EP N600/3-88/036. Environmental Research
Laboratory, Duluth. Minn.
United States Environmental Protection Agency. 1993. Methods for Aquatic Toxicity Identification
Evaluations-Phase III Toxicity Confirmation Procedures for Samples Exhibiting Acute and Chronic
Toxicity. EPN600/R-92/08 l
United Slates Environmental Protection Agency. 1993. Methods for Aquatic Toxicity Identification
Evaluations-Phase III Toxicity Confirmation Procedures for Samples Exhibiting Acute and Chronic
Toxicity. EPNG00/R-92/081. Office of Research and Development, Washington. D.C. September
1993.
United Slates Environmental Protection Agency. 1989. Methods for Aquatic Toxicity Identification
Evaluations-Phase !I Toxicity Identification Procedures. EPN600/3-88/035. Environmental Research
Laboratory, Duluth. Minn.
United States Environmental Protection Agency. 1993. Methods for Aquatic Toxicity Identification
Evaluations-Phase II Toxicity Identification Procedures for Samples Exhibiting Acute and Chronic
Toxicity. EPN600/R-92/080. Office of Research and Development. Washington, D.C. September
1993.
United States Environmental Protection Agency. Toxicity Reduction Evaluation Protocol For Municipal
Wastewater Trea1men1 Plants. EPN600/2-88/062. April 1989. EPA Risk Reduction Engineering
Laboratory. Cincinnati. Ohio.
United States Environmental Protection Agency. 1989. Generalized Methodology for Conducting Industrial
Toxicity Reduction Evaluations (TREs). EPNG00/2-88/070. EPA Risk Reduction Eugineering
Laboratory. Cincinnati, Ohio.
These documents should he avai/nhle from the:
National Technical Information Service
5285 Port Royal Rd.
Springfield Va. 22161
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(703) 487-l650
Anyone developing a toxicity reduction plan should obtain copies of one or more or these documents as
appropriate in order to better understand the strengths and weaknesses of each step and be better able to plan
further actions. Included in this b'ltidance arc outlines of general toxicity reduction evaluations for both industrial
and municipal wastewater treatment facilities. These outlines demonstrate decision paths that may be encountered
in performing a TRE, as described in detail by the EPA documents.
A logical starting place for investigations of toxicity sources and reduction is a thorough infonnation
gathering phase. At this stage. several preliminary issues should be investigated and infonnation evaluated for
potential causes/sources of toxicity, effiuent variability, treatment system efficiency, etc.
For municipal waste water treatment plants(WWTP) this infonnation may include:
•The NPDES pennit
•Treatment system design criteria. flow diagrams. descriptions of treatment elements
•Influent and effiuent flow data
•Influent and effiucnt conventional pollutant data and removal efficiencies
•Eilluent toxicity data and trends
•Process control and operational data and histories
•In-plant chemical usage (polymers. coagulants. chlorine)
•Treatment upset histories and reports
•Pretreatment infon1iation
•Industrial waste surveys
•Industrial user self-monitoring reports
•Industrial user operational schedules and flow patterns
•Waste hauler monitoring and manifests
•Hazardous waste inventories
For industrial waste water treatment plants(WWTP) this infonnation may include:
•Process and wastewater generating process diagrams and descriptions
•Production records
•Diagrams and descriptions of non-process wastewater sources( cooling towers. boilers. floor
drains)
•In-plant flow records and water usage
•Chemical inventories and usage records
•Chemical labels. MSDS. and toxicity information
•Operating schedules with emphasis on how these schedules affect wastewater flow/composition
•WWTP operational data and histories
•Wastewater monitoring records(chemical and toxicity)
The overall importance of this initial information gathering phase to the success of a toxicity reduction
evaluation cannot be overestimated both in terms of eventual outcome as well as the efficiency with which that
outcome is achieved. In many instances, it is likely that sources or toxicity can be escalated or de-escalated as
targets for investigation by simple calculation rather than further testing, greatly reducing the cost of the
investigation. This informntion gathering phase will often be accomplished by the permittee prior to contact with
any paid consultants and before any actual testing takes place. By carefully reviewing the infonnation gathered
and comparing trends in flow patterns. treatment efficiency. wastewater loading and eilluent constituents with
toxicity patterns observed over time, the permittcc may be able to narrow the scope of farther investigations and
possibly even identify problem constituents.
Following infonnation gathering, emphasis should next be placed on ma"Ximizing in-house treatment
efficiency and assuring that housekeeping practices are not contributing unnecessarily to final effluent toxicity
practices. Waste treatment efficiency must be maximized during this process in order that it does not present a
moving target in itself. Industrial facilities should identify and regulate all possible contributions to the wastewater
system, including even floor drain discharges where unwanted materials may be disposed without the knowledge of
wastewater treatment staff. In addition to the obvious industrial process waste streams. side streams such as
cooling tower discharge. boiler blowdown. or airwash discharges should be reviewed for the presence of sometimes
very toxic chemicals. Toxicity information is now readily available for many of the more commonly used biocidal
compounds used in these treatments. Municipal systems should investigate the toxicity of any added treatment
chemicals and review effiuent toxicity vs. use records of such chemicals. Effiuent chlorination and ammonia
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frequently prove to be two of the most commonly encountered causes of effiuent toxicity. Over-chlorination and
excess variation in chlorination should be high on the list as potential toxicity problems.
At this point a good i1tfonnational base should have been developed and wastewater treatment efficiency
should be at peak sustainable levels. If still necessary, a Toxicity Identification Evaluation (TIE) could now be
initiated to help characterize the chemical/physical nature of the problem constituents. This series of tests,
described by EPN600/3-88/034, EPN600/3-88/035, and EPN600/3-88/036, referenced on the first page consists
of a series of chemical/physical manipulations of the wastewater followed by subsequent toxicity tests \vhich can
identify or rnlc out possible toxicants. A TIE will most likely require the expertise of a group of biologists,
chemists. and possibly wastewater engineers experienced with these protocols due to the case by case decisions that
must be made in development and interpretation of results. Some of the complex analytical procedures required by
TIE protocols may not be available in most wastewater laboratories. As such. consultants specializing in toxicity
reduction may need to be sought. A TIE series should be carefully planned and monitored through its duration
with interim findings translated back to the collection and treatment system managers for immediate investigation.
Where these interim findings point to a possible source of toxicity, modifications in chcmicals.,being used or
disposal/use patterns may be modified so as to efficiently solve toxicity problems.
Once problem constituents have been characterized and/or identified, in either an individual industrial
discharge or in a municipal system, the sources of these constituents can be tracked to the source and addressed
through product substitution. wnste reduction. or recycle/reuse systems. With few exceptions. removal of these
problem constituents will be more cost effective by these means than by trentment. If treatment is necessary, the
TRE can shift to bench or pilot scale trcatabilily studies.
In municipal treatment systems where the sources of problem constituents arc not known, a procedure
referred to as Refractory Toxicity Assessment (RTA) can be accomplished, as described by EPN600/2-88/062.
This approach utilizes bench scale treatment of various influent sources to determine which wastestrcams pass
through the treatment system without effective detoxification.
For either industrial or municipal discharges. custom designed toxicity tests to answer specific questions
can be beneficial. If ,veil organized. these tests can be significantly reduced in both complexity and cost from those
required for NPDES compliance testing. Such tests could address the toxicity of individual streams contributing to
the whole effluent or tests of process or treatment chemicals to address relative toxicity. Consultants experienced
with performing toxicity reduction work should be able to design such tests and significantly reduce costs by doing
so. As stnted earlier, the position of the N.C. Water Quality Section is that the gonl of this process is 10 reduce
observed toxicity in the effiucnt. Finding the most efficient means of reaching this goal is encouraged so that
unnecessary testing and costs arc not incurred.
Most toxicity reduction plans are reviewed by technical staff of the Water Quality Section. Reviewers of
these plans will judge adequacy based on information provided and the technical ability of the plans to address the
problems encountered in each specific application. Geucrally, those plans that follow the logic of the EPA
described toxicity reduction evaluation guidance will meet the intent of most TRE requirements. The EPA
document " Technical Support Document for Water Quality-based Toxics Control ( EPN505/2-90-00 I, PB9 l-
l27-115, March l99l)" includes a list of evaluation criteria for TRE plans which could be helpful in designing or
evaluating a plan submitted by a consultant. The ideas presented by this list include important concepts that we
evaluate when reviewing the effectiveness ofTRE proposals. That list is as follows:
• Are the objectives or targets of the TRE stated clearly and accurately?
•Arc the schedule milestones for accomplishing the tasks described in the study plan?
•Arc the final TRE report, progress reports, and meetings with the regulatory authority included as part of the
schedule?
•Arc the approaches or methods to be used described to the extent possible prior to beginning the TRE'I
•Has available EPA guidance been used in designing the TRE and developing the TRE plan (or if other methods
are proposed. arc these sufficiently documented)?
•Docs the TRE plan specify what results and data arc lo be included in ihe interim and final reports'/
•Does the TRE plan provide for arrangements for any inspections or visits to the facility or laboratory that are
determined to be necessary by the regulatory authority'/
•Are the toxicity test methods and endpoints to be used described or referenced?
•Does the approach described build on previous results and proceed by narrowing down the possibilities in a logical
progression?
•Docs the plan provide for all test results Lo be analyzed and used to focus on the most effective approach for any
subsequent source investigations, treatability studies. and control evaluations?
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• Are optimization of existing plant/treatment operations and spill control programs part of the initial steps of the
TRE?
•Does Uie TRE plan allow a sufficient amount of time and appropriate level of elTon for each of the components of
the study plan?
•Does the TIE use broad characterization steps and consider quantitative and qualitative cffiuent variability?
•Is toxicity tracked with aquatic orgrmism toxicity tests throughout the analyses?
•ls the choice of tests for U1e TRE logical and will correlations be conducted if the species used are dilTerent from
those used for routine biomonitoring?
• Is the laboratory analytical capability and the expertise of the investigator broad enough to conduct the various
components of the evaluation?
A question which will undoubtedly arise is, "What will be the State's role in the TlEffRE process?" DWQ's
regional office stalT should be the first point of contact in these issues. Most often. they will have the best
knowledge of specific facilities and will be the hub of compliance activities. StalT of the Aquatic To,icolOb'Y Unit
in Raleigh can provide information and technical guidance on toxicity and toxicity reduction issues. One of the
responsibilities of U1is Unit is review of submitted TRE plans addressing the proposed logic and direction
undertaken to reduce toxicity. The comments provided by this Unit incorporate the technical expertise of
individuals whom, over U1e years, have evaluated TJEffRE plans and provided recommendations related to those
plans. Additional information on waste reduction and reuse strategies may be availnble from the N.C. Division of
Pollution Prevention and Environmental Assistance at 9I9/715-6500. The latter is a non-regulatory program
designed to provide the industrial/commercial sector with information in this area.
Successful toxicity reduction can rely to a great extent on selection of a competent and qualified contractor
to conduct toxicity reduction activities should the services of a qualified contractor be needed to resolve toxicity
noncompliance. A simple question which should be addressed to a toxicity consultant prior to retaining services
should be. ·'What has been your success and experience with conducting toxicity reduction evaluations?"
Should there be any questions related to this guidance document or to toxicity reduction strategies, we
would encourage you to contact Matt Matthews or Kevin Bowden of the Aquatic Toxicology Unit at (919) 733-
2136.