NCD003200383_20030423_Koppers Co. Inc._FRBCERCLA C_Groundwater correspondence 1991 - 2003-OCR

April 23, 2003
Ms. Beverly Hudson
Remedial Project Manager
USEPA-Region IV
North Superfund Remedial Branch
Waste Management Division
100 Alabama Street
Atlanta, Georgia 30303
The RETEC Group, Inc.
1822 E. NC Highway 54, Suite 100
Durham, NC 27713
.RETEC
[phone] Phone
[phone] Fax
www.retec.com
RE: Request for Modifications to the Groundwater Sampling Program at the
Former Koppers Company Site, Morrisville, North Carolina
RETEC Project No.: BEAZ7-03624-103
Dear Ms. Hudson:
RETEC North Carolina, Inc. (RETEC), on behalf of Beazer East, Inc. (Beazer), is submitting this request
to modify the groundwater monitoring frequency and the type of groundwater sampling equipment used at
the former Koppers Company Site in Morrisville, North Carolina (Site). Beazer herein requests that in the
second half of 2003, the quarterly monitoring schedule be changed to semiannual, and the use of stainless-
steel hailers be changed to dedicated-Teflon® hailers.
RETEC has discussed these modifications with Mr. David Mattison of the North Carolina Department of
Environment and Natural Resources during a telephone conversation in February 2002. Mr. Mattison
recommended that we have sufficient data (at least 3 years of data) to support our requests. This data has now
been compiled, and as shown on the enclosed summary table, the number of constituents detected in the
groundwater sampled from this Site (as well as the concentrations of those constituents) appear to have
stabilized; warranting a reduced sampling frequency. In addition, the non-reactive nature of Teflon® hailers
makes them a suitable and more cost effective alternative to the labor-intensive stainless-steel hailers currently
used.
As stated above, RETEC hopes to implement these modifications during the second half of2003; therefore, we
request that you provide us with a letter approving these modifications on or before June 30, 2003.
RETEC thanks you for your time and consideration of this request. Please do not hesitate to contact Michael
Helbling, Beazer Environmental Manager at ( 412) 208-8858 or Rita Bauer at [phone] should you have
questions or comments regarding this letter, or the Site in general.
Sincerely,
RETEC North Carolina, Inc.
~C-:.~-~ -
Stefanie D. Young <_____J 0 ~IU-~~
Rita M. Bauer
Environmental Scientist Groundwater Sampling Program Manager
Enclosure
cc: D. Mattison-North Carolina Department of Environment and Natural Resources
M. Helbling-Beazer East, Inc. ·
The RETEC Group, Inc.
1822 East NC Highway 54
Suite 100
Durham, NC 27713
Letter of Transmittal . ,~r~ (c; IF: ~ VJ ~ [R\
ViAY I 2 21m \Y G,RETEC
919.484. 2200 Phone
919.484. 8100 Fax
www.retec.com
TO: Jay Zimmerman DATE: ----'--'5/-'-'9/-"0-'--3 _________ _
RE:
Request for Modifications to the
Groundwater Sampling Program Letter,
Ralei h PROJECT NO: BEAZ7-03624-103
PLEASE FIND: [8] Attached D Under separate cover via:
1
Cooies
D Copy of Letter
D Samples
Date
4/23/03
D Change Order
D Other:
No.
D For Approval D Approved as Submitted
[8] For Your Use D Approved as Noted
D As Requested D Returned for Corrections
D For Review & Comment
Remarks:
D Drawings/Figures D Plans/Specs
Descriotion
Request for Modifications to the Groundwater
Samoling Program Letter, Raleigh
D Resubmit
D Submit
D Return
D Other:
,,
Copies for Approval
Copies for Distribution
Corrected Prints
As per D. Mattison's request, a copy of this letter and corresponding data table has been sent to you. Any
questions or concerns, please feel free to call Rita Bauer at 978-371-1422.
Sincerely,
The RETEC Group, Inc.
Stefanie Young
cc:
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard•
2,4-DICHLOROPHENOL o,n/L
PENTACHLOROPHENOL o,n/L
1,2,3,4,6,7,8-HpCDD oo/L
1,2,3,4,6,7,8-HoCDF nn/L
1,2,3,4,7,8,9-HpCDF nn/L
1,2,3,4, 7,8-HxCDD oo/L
1,2,3,4, 7,8-HxCDF nn/L
1,2,3,6, 7,8-HxCDD nn/L
1,2,3,6,7,8-HxCDF nn/L
1,2,3,7,8,9-HxCDD nn/L
1,2,3,7,8,9-HxCDF oo/L
1,2,3,7,8-PeCDD nn/L
1,2,3,7,8-PeCDF nn/L
2,3,4,6, 7 ,8-HxCDF nn/L
2,3,4,7,8-PeCDF nn/L
2,3, 7 ,8-TCDD oo/L
2,3, 7 ,8-TCDF nn/L
OCDD nn/L
OCDF oa/L
TOTAL HPCDD nn/L
TOTAL HPCDF nn/L
TOTAL HXCDD oa/L
TOTAL HXCDF nn/L
TOTAL PECDD nn/L
TOTAL PECDF nn/L
TOTAL TCDD nn/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg/L -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
*ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled tor dioxins/furans in May 2002.
Mar-00
0.2 u
1 u
...
...
...
...
...
...
...
...
...
...
...
...
...
...
...
...
...
...
...
...
-··
...
...
-··
...
C-01B
Mar-01 May-02 Feb-03 Mar-00
0.2 u 0.22 u 0.2 u 0.2 u
1 u 1.1 u 0.98 u 1 u ... 20 u ... . ..
... 1.6 u . .. ...
... 1.7 u ... ...
. .. 2 u ... ...
. .. 1.6 u ... ...
... 2.2 u ... ··-
. .. 1.6 u ... ...
... 2 u ·-· ...
--· 1.7 u ... ...
... 3.4 u ... ...
... 1.8 u ... . ..
. .. 1.7 u ... ...
... 1.8 u ... ...
... 1.6 u ... . ..
... 1.2 u . .. ...
... 360 ... . ..
... 7.9 u . .. ...
. .. 29 ... ...
... 3.7 u . .. -··
... 2.2 u ... ...
·-· 1.7 u ... ...
... 3.4 u . .. ...
. .. 1.9 u ... ...
... 1.6 u ... ...
... 1.2 u . .. ...
.
C-09B C-10A C-10A DUP C-10A C-10B
Mar-01 Mar-02 Feb-03 Mar-00 Mar-01 Mar-02 Feb-03 Mar-00 Jun-00
0.2 u 0.2 u 0.19 u 0.2 u 0.2 u 0.2 u 0.2 u 0.19 u 0.2 u 0.2 u
1 u 1 u 0.96 u 1 u 1 u 1 u 1 u 0.96 u 1 u 1 u
. .. ... . .. ... . .. . .. . .. . .. ... . ..
... . .. . .. ... . .. . .. ... . .. . .. ...
. .. . .. . .. . .. . .. . .. . .. . .. ·-· ...
. .. ... . .. . .. ... . .. . .. . .. ... ...
. .. . .. . .. . .. ... . .. . .. . .. . .. ...
. .. ... . .. ... ... . .. . .. . .. ... ...
. .. ··-. .. ... . .. . .. . .. . .. ·-· ...
... ... ... . .. ... . .. . .. . .. ... ...
. .. ··-. .. ... . .. ... . .. . .. --· ...
. .. ... . .. ... . .. . .. . .. . .. . .. ...
··-... . .. ... ... . .. . .. . .. ... . ..
. .. . .. . .. ... . .. . .. . .. . .. ·-· ...
. .. . .. ... -·· ... . .. ..• . .. . .. ...
... . .. . .. . .. . .. ... . .. . .. --· ...
... . .. . .. ... . .. . .. ... . .. . .. --·
... -·· . .. . .. . .. ... . .. . .. . .. ...
... . .. ·-· ... ... •.. ... . .. . .. ...
··-. .. . .. . .. . .. ... . .. . .. . .. ...
. .. . .. . .. ... ... . .. ·-· ... ... . ..
. .. . .. --· ... . .. -·· ... ··-. .. ...
··-... . .. ... . .. . .. . .. . .. ... ...
... . .. . .. ... . .. -·· ... ... . .. ...
. .. . .. . .. . .. . .. ... . .. . .. . .. ...
. .. ... . .. . .. ... . .. ·-· ... ... . ..
. .. -·· ... ... ... -·· ... ··-. .. ...
1 of 8
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard*
2,4-DICHLOROPHENOL "n'L
PENTACHLOROPHENOL "n'L
1,2,3,4,6,7,8-HoCDD nn/L
1,2,3,4,6,7,8-HpCDF nn/L
1,2,3,4,7,8,9-HoCDF nn/L
1,2,3,4, 7 ,8-HxCDD nn/L
1,2,3,4,7,8-HxCDF nn/L
1,2,3,6,7,8-HxCDD nn/L
1,2,3,6,7,8-HxCDF nn/L
1,2,3, 7 ,8,9-HxCDD oa/L
1,2,3, 7 ,8,9-HxCDF nn/L
1,2,3, 7 ,8-PeCDD nn/L
1,2,3,7,8-PeCDF nn/L
2,3,4,6, 7,8-HxCDF nn/L
2,3,4,7,8-PeCDF oa/L
2,3,7,8-TCDD nn/L
2,3,7,8-TCDF nn/L
OCDD nn/L
OCDF nn/L
TOTAL HPCDD nn/L
TOTAL HPCDF nn/L
TOTALHXCDD nn/L
TOTAL HXCDF oa/L
TOTAL PECDD nn/L
TOTAL PECDF nn/L
TOTAL TCDD oa/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
8 indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg/L -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
*ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
C-10B
0.2 u
1 u ...
---
--·
---...
---
--·
---
...
---
---
---
---...
---
...
---
·--
...
---
...
---
---
...
---
C-10B DUP C-10B
Sep-00 Mar-01 Jun-01 Mar-02 Feb-03
0.2 u 0.2 u 0.2 u 0.2 u 0.2 u
1 u 1 u 1 u 1 u 1 u
... ... ... ---·--
------------...
------ ---
... ---
... ... ------. ..
---------... ---... ... --- ------
---------... ---
... ------ --- ---
-----· ... ------
... ------ ---...
---... ... ------
------ ---... ---
... ... ---------
--------· ... ---
--· ... ---------
------ ---... ...
---... ... ------
... ------... ...
------... ------
... . .. ---... . ..
... -----· ... ---
---... ... ------
--· ... ---... ...
... ---... ------
---... ---... ---
2 of 8
C-11 B C-12A C-13B
Jun-00 Mar-01 Mar-02 Feb-03 Mar-00 Jun-01 Mar-02 Feb-03 Mar-00 Mar-01
0.2 u 0.38 0.2 u 0.33 0.2 u 0.2 u 0.2 u 0.2 u 0.2 u 0.2 u
1 u 1 u 1 u 0.95 u 1 u 1 u 1 u 0.98 u 1 u 1 u
--· ------... ------... . .. --· ---
------ ------... ---------------
---... ... --- ---. .. ---. .. ---...
... ------... . .. ---... ---... ---
---... ... --- -----· ---------...
... ------... ... . .. ... ---... ---
---... ... --- --- ------ ------...
... ------... . .. ---... ---... ---
---. .. ------ ---------... ------
------. .. ---------... ---------
... ------... ... ---... -----· ---
----·-... --- ---
... --- ------...
... ------... . .. ---... ---... ---
---... ------ ---
. .. ---. .. ---...
. .. ------... ... ---... ---... ---
---... ... --- ---
. .. ---. .. ---...
. .. --- ---
... ... ---... ---... ---
---... ... --- ---
. .. ---. .. ---...
... ------... ... ---... . .. ... ...
--- ---
... ---------------... ---
--· ... -----· ---... ---. .. ---...
. .. --- ---
... ... ---... ---... ---
---... ... ------. .. --- ---------.,
... . .. ---... ... ---... . .. -·----
' . .. ... ... ---------------. .. ---
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard*
2,4-DICHLOROPHENOL 11n/L
PENTACHLOROPHENOL 11n/L
1,2,3,4,6, 7 ,8-HoCDD nn/L
1,2,3,4,6,7,8-HoCDF nn/L
1,2,3,4,7,8,9-HpCDF pq/L
1,2,3,4,7,8-HxCDD nn/L
1,2,3,4,7,8-HxCDF nn1L
1,2,3,6,7,8-HxCDD pq/L
1,2,3,6,7,8-HxCDF nn/L
1,2,3, 7 ,8,9-HxCDD nn/L
1,2,3, 7 ,8,9-HxCDF nn/L
1,2,3,7,8-PeCDD nn/L
1,2,3,7,8-PeCDF pq/L
2,3,4,6, 7,8-HxCDF nn/L
2,3,4,7,8-PeCDF nn/L
2,3,7,8-TCDD nn/L
2,3,7,8-TCDF nn/L
OCDD nn/L
OCDF nn/L
TOTALHPCDD nn/L
TOTALHPCDF oa/L
TOTALHXCDD nn/L
TOTAL HXCDF nn/L
TOTALPECDD oa/L
TOTAL PECDF nn/L
TOTAL TCDD nn/L
TOTAL TCDF oa/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg/L -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
·ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
C-13B
Mar-02 Feb-03 Mar-00 Sep-00 Dec-00
0.2 u 0.19 U 0.2 u 0.53 U 0.71 u
1 u 0.95 U 16 21 3.6 u
... ... ... 2530 . ..
... ... ... 537 . ..
... ... ... 36.1 . ..
... ... ... 22.4 J ...
... ... ... 17.4 J . ..
... ... . .. 138 ...
... ... ... 25.9 J . ..
... ... . .. 70.2 ...
... . .. ... 7.64 U . ..
... ... . .. 11.1 J ...
... ... ... 2.46 U . ..
... ... -·· 20.4 J . ..
... ... . .. 2.41 u . ..
... ... ... 2.13 u . ..
--· ... ... 1.64 u ...
... ... ---23200 B . ..
... ... . .. 1930 ...
... ... . .. 3990 . ..
... ... ... 1850 . ..
... ... ... 481 ...
... ... . .. 555 . ..
... ... ... 11.1 . ..
... ... ... 90.1 . ..
... . .. --· 2.13 u . ..
... ... ... 1.64 u ...
C-14A C-14B
Mar-01 Jun-01 Aua-01 Dec-01 Mar-02 May-02 Aug-02 Dec-02 Feb-03 Mar-00 Jun-00
0.2 U 0.23 U 0.2 u DRY DRY DRY DRY DRY DRY 0.2 u 0.2 u
4.4 1.4 180 D DRY DRY DRY DRY DRY DRY 5.9 1 u
1100 . .. 55 . .. DRY . .. DRY ... DRY . .. 150
97 . .. 7.8 u . .. DRY . .. DRY ... DRY . .. 34
15 U . .. 0.98 u . .. DRY . .. DRY ... DRY . .. 2.1 u
12 U . .. 1.7 u ... DRY . .. DRY . .. DRY . .. 4.8 u
7.3 U . .. 1.5 u . .. DRY . .. DRY ... DRY . .. 3.2 u
43 J . .. 2.7 u ... DRY . .. DRY ... DRY . .. 6.8 u
7.3 U . .. 1.4 U . .. DRY . .. DRY ... DRY . .. 2.4 u
77 . .. 1.6 U . .. DRY . .. DRY ... DRY . .. 4.2 u
8.6 UJ . .. 1.6 u . .. DRY . .. DRY ... DRY . .. 3.3 u
9.2 U . .. 2.1 u . .. DRY . .. DRY ... DRY . .. 9.8 u
7.2 U . .. 1.4 u . .. DRY . .. DRY ... DRY . .. 5 U
8.1 UJ . .. 1.6 U . .. DRY ... DRY ... DRY . .. 3.3 u
7.1 u . .. 1.3 U -·· DRY . .. DRY ... DRY . .. 5.1 u
3.2 U . .. 1.3 U . .. DRY . .. DRY ... DRY . .. 4.1 u
3 U . .. 0.94 U --· DRY ... DRY ... DRY . .. 2.8 u
3900 . .. 660 . .. DRY ... DRY ... DRY . .. 1000
260 . .. 56 J ... DRY . .. DRY ... DRY . .. 24 u
1400 . .. 92 . .. DRY ... DRY ... DRY . .. 220
240 . .. 16 U . .. DRY . .. DRY ... DRY . .. 34
180 . .. 3 U . .. DRY ---DRY ... DRY . .. 11 u
26 U ·-· 2.1 u . .. DRY ... DRY ... DRY . .. 4.8 U
9.2 u . .. 2.1 u ... DRY . .. DRY ... DRY . .. 9.8 U
7.2 U . .. 1.5 U . .. DRY ... DRY . .. DRY . .. 5.1 u
3.2 U ·-· 1.3 U . .. DRY ... DRY ... DRY . .. 4.1 u
3 U . .. 0.94 U . .. DRY . .. DRY ... DRY . .. 2.8 u
3 af 8
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard•
2,4-DICHLOROPHENOL un/L
PENTACHLOROPHENOL un/L
1,2,3,4,6,7,8-HoCDD nn/L
1,2,3,4,6,7,8-HpCDF nn/L
1,2,3,4,7,8,9-HpCDF on/L
1,2,3,4, 7,8-HxCDD M/L
1,2,3,4,7,8-HxCDF nn/L
1,2,3,6,7,8-HxCDD oa/L
1,2,3,6,7,8-HxCDF nn/L
1,2,3,7,8,9-HxCDD nn/L
1,2,3,7,8,9-HxCDF nn/L
1,2,3,7,8-PeCDD nn/L
1,2,3,7,8-PeCDF oa/L
2,3,4,6,7,8-HxCDF nn/L
2,3,4,7,8-PeCDF nn/L
2,3,7,8-TCDD nn/L
2,3,7,8-TCDF nn/L
OCDD oa/L
OCDF nn/L
TOTAL HPCDD nn/L
TOTAL HPCDF oa/L
TOTALHXCDD nn/L
TOTAL HXCDF nn/L
TOTAL PECDD oa/L
TOTAL PECDF nn/L
TOTAL TCDD nn/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg/L -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
·ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
Sep-00 Dec-00
0.4 u 0.2 u
15 8.9 D
... ...
... ...
... ...
... ...
... ...
... ...
... ...
... ...
--- ---
... ...
... ...
... ...
... ...
... ··-
... ...
... ...
... ...
... ...
... ...
... ---
------
... ...
... ...
... ...
... ---
. C-14B
Mar-01 Jun-01 Aua-01
0.2 u 0.2 u 0.2 u
12 1.4 1 u
10 u ... 6.2 u
4.4 u ·-· 2 u
4.7 u ---0.97 u
5.1 u ---1.5 u
5.7 u ... 1.1 u
6 u ··-1.6 u
5.6 u ... 1.1 u
5.3 u ... 1.4 u
6.7 UJ ... 1.2 u
10 u -·· 2.9 u
2.3 u ---1.6 u
6.3 UJ ... 1.2 u
2.3 u ---1.6 u
5.7 u ... 1.2 u
3.2 u ---1 u
82 J ... 55 J
9 u ---6.6 u
10 u ... 6.2 u
4.7 u ... 2 u
6 u ---1.6 u
6.7 u ... 1.2 u
10 u ··-2.9 u
2.3 u ... 1.6 u
5.7 u ... 1.2 u
3.2 u ··-1 u
C-15B C-27A
Dec-01 Mar-02 May-02 Feb-03 Mar-00 Mar-01 Mar-02 Feb-03 Mar-00 Mar-01 Mar-02 Feb-03
0.2 u 0.23 u 0.22 u 0.19 u 0.2 u 0.2 u 0.2 u 0.21 u 0.2 u 0.2 u 0.2 u 0.2 u
1 u 1.2 u 1.1 u 0.96 u 1 u 1 u 1 u 1 u 1 u 1 u 1 u 1 u
... . .. . .. ... ... . .. ··-. .. ... ... . .. ...
. .. ... . .. ··----... . .. ... ... . .. . .. . ..
. .. ... . .. ... ... . .. ··-... ... ... . .. ...
. .. ... ... ... ... . .. . .. . .. ---. .. ---...
. .. ... ... ... . .. ... . .. . .. . .. --· ... ...
... ... ... ... . .. ... . .. . .. . .. . .. . .. ...
. .. ... ... ... . .. ... . .. . .. . .. --· ... ...
---... . .. ... ··-... . .. . .. . .. . .. . .. ...
... •.. . .. ... ... . .. ---. .. ... ... . .. ...
... ... . .. . .. ... ... . .. ... . .. . .. --· ...
---... . .. ... ... ... ---. .. . .. ... . .. ...
. .. ... ... ... ··-... . .. . .. . .. --· ... . ..
. .. ... ... ... ... ... . .. ··-. .. ... ---...
. .. --- ---
... ... ... . .. . .. . .. --· ... ...
. .. ... ... ---... ... . .. ··-... ... ---...
. .. ---. .. ... ... ... ---. .. ... ---. .. ...
. .. ... . .. ---... ... . .. ··-. .. ... ---...
. .. ... ---... ... . .. ---. .. ... --· ... ··-
... ... . .. ... . .. ----·· ... . .. ... ---...
... ... . .. ... ··-... . .. ... . .. . .. ... . ..
... ---. .. ... ... ... ---. .. . .. ... . .. ...
... ... . .. ---... ... . .. . .. ---. .. ··-...
... . .. ---... ... ... ---... ... . .. . .. ---
... ... . .. .•. . .. --· . .. ... . .. ... ---...
... ... . .. ... ... ... . .. ---... ... ... . ..
4 of 8
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard•
2,4-DICHLOROPHENOL ua/L
PENTACHLOROPHENOL ua/L
1,2,3,4,6, 7,8-HoCDD nn/L
1,2,3,4,6,7,8-HoCDF nn/L
1,2,3,4,7,8,9-HpCDF oa/L
1,2,3,4,7,8-HxCDD nn/L
1,2,3,4, 7,8-HxCDF nn/L
1,2,3,6,7,8-HxCDD nn/L
1,2,3,6,7,8-HxCDF nn/L
1,2,3,7,8,9-HxCDD oa/L
1,2,3, 7,8,9-HxCDF nn/L
1,2,3, 7,8-PeCDD nn/L
1,2,3, 7 ,8-PeCDF nn/L
2,3,4,6,7,8-HxCDF nn/L
2,3,4,7,8-PeCDF pq/L
2,3, 7 ,8-TCDD nn/L
2,3,7,8-TCDF nn/L
OCDD oa/L
OCDF nn/L
TOTALHPCDD nn/L
TOTAL HPCDF nn/L
TOTALHXCDD nn/L
TOTAL HXCDF nn/L
TOTAL PECDD nn/L
TOTAL PECDF nn/L
TOTAL TCDD na/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg/L -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
*ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
Jun-00
0.2 u
1 u
---
---
---
---
---
---
---
---
---
---------
---
---
---
---
---
---
---------
---
---
------
C-27B C-28A
Mar-01 Mar-02 Feb-03 Mar-00 Mar-01 Mar-02
0.2 u 0.2 u 0.19 u 0.2 u 0.2 u 0.2 u
1 u 1 u 0.96 u 1 u 1 u 1 u
------------------
--------- ---------
------------------
------------------
------------------
------------------
------------------
--------------------- ------ ---------
--- ---------------
------------ ------------ ------ ---
---
------ ---
------ ---
--------------- ---
------------ ------------ ------------
------ --------- ---
------------------
--- --------- ------
------ --- --- ------
--- ---
------ ------
------------------
------------------
--------- --- --------------------- ---
5 of 8
C-28B C-29B C-29B REA C-29B
Feb-03 Jun-00 Mar-00 Jun-00 Sep-00 Dec-00 Mar-01 Jun-01
0.19 u 0.2 u 0.2 u 0.22 0.2 u 4 u 0.6 1 u 0.21
0.97 u 1 u 9.3 110 D 51 D 80 51 D 58 56 D
------------9.8 u 344 ---19 u ---
------------3.4 u 55.1 ---6.4 u ---
------------3.1 u 6.68 u ---1.9 u ---
------------4.8 u 14.5 J ---4 u ---
------------3 u 2.25 u ---4.1 u ---
------------4.6 u 15 J ---4.6 u ---
------------2.2 u 2.39 u ---4.1 u ---
------ ------4.2 u 4.23 u ---4 u ---
------ ------3.1 u 3.68 u ---4.8 UJ ---
------ ------7.4 u 2.18 u ---4.8 u ---
------ ------4.1 u 2.24 u ---5 u ---
------ ------3.1 u 2.56 u ---4.5 UJ ---
------ ------4.2 u 2.19 u ---5 u ---
------------3.2 u 1.21 u ---1.8 u ---
------------2.2 u 0.819 u ---2 u ---
------------88 3650 B ---200 ---
------------6.5 u 249 ---21 u ---
------ ------9.8 u 606 ---19 u ---
------ ------3.4 u 245 ---8.9 u ---
------ ------4.8 u 54.4 ---4.6 u ---
------------3.1 u 62.4 ---4.8 u ---
------------16 u 2.18 u ---4.8 u ---
------ ------4.2 u 6.23 ---5 u ---
------ ------3.2 u 1.21 u ---1.8 u ---
------ ------2.2 u 0.819 u ---2 u ---I. j
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard•
2,4-DICHLOROPHENOL ,1n/L
PENTACHLOROPHENOL ,,ntL
1,2,3,4,6, 7,8-HpCDD nn/L
1,2,3,4,6, 7,8-HpCDF oa/L
1,2,3,4,7,8,9-HoCDF nn/L
1,2,3,4, 7,8-HxCDD nn/L
1,2,3,4, 7,8-HxCDF nn/L
1,2,3,6, 7,8-HxCDD nn/L
1,2,3,6,7,8-HxCDF pq/L
1,2,3,7,8,9-HxCDD nn/L
1,2,3, 7,8,9-HxCDF oa/L
1,2,3, 7,8-PeCDD aa/L
1,2,3, 7,8-PeCDF nn/L
2,3,4,6, 7 ,8-HxCDF pq/L
2,3,4,7,8-PeCDF nn/L
2,3,7,8-TCDD nn/L
2,3,7,8-TCDF oa/L
OCDD nn/L
OCDF nn/L
TOTAL HPCDD nn/L
TOTAL HPCDF nn/L
TOTAL HXCDD nn/L
TOTAL HXCDF nn/L
TOTAL PECDD nn1L
TOTAL PECDF nn/L
TOTAL TCDD nn/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA,
NA
NA
NA
NA
NA-
NA
NA
NA-
NA
NA
NA
NA
NA
NA
NA,
NA•
NA
NA
NA
NA
NA"
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg.IL -picograms per titer
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
•ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
Aug-01
0.45
17 D
4.2 u
2.6 u
2.8 u
9.8 u
3 u
11 u
2.9 u
9.3 u
3.7 u
3.8 u
1.9 u
3.4 u
1.9 u
1.8 u
1.7 u
7.3 u
5.7 u
4.2 u
2.8 u
11 u
3.7 u
4.3 u
3.1 u
1.8 u
1.7 u
C-29B
Dec-01 Mar-02 May-02
0.2 u 2 u 0.2 u
41 D 27 41 D
14 u ---12 u
2.7 u ---2.7 u
1.5 u ---1.5 u
1.2 u ---1.8 u
0.88 u ---1.1 u
1.6 u ---1.9 u
0.47 u ---1.1 u
1.1 u ---1.7 u
0.57 u ---1.2 u
2 u ---2.7 u
0.64 u ---1.6 u
0.52 u ---1.2 u
0.62 u ---1.6 u
0.82 u ---1.4 u
0.97 u ---1.1 u
64 J ---99 u
6.9 u ---6.1 u
14 u ---12 u
4.6 u ---3.7 u
1.6 u ---2.2 u
1.3 u ---1.2 u
3.3 u ---2.7 u
1 u ---1.8 u
0.82 u ---1.4 u
0.97 u ---1.1 u
C-29B I C-29B DUP M-04
Aug-02 Dec-02 Feb-03 Mar-00 Sep-00 Mar-01 Mar-02 May-02 Aua-02 Dec-02 Feb-03
0.2 u 1 u 0.97 u 0.95 u 0.2 u 0.22 u 0.22 u DRY DRY DRY DRY DRY
39 D 45 28 32 1 u 1.1 u 1.1 u DRY DRY DRY DRY DRY
---9.4 u ------------------------------
---3.6 u --------------- ---------------
---1.2 u ------------------------------
---0.51 u ------------ ------------------
---0.79 u --------- --- ---
---------------
---0.6 u --------------------------- ---
---1.1 u ------------ --- ---------------
---0.62 u ------------------------------
---0.48 u --------------- ---------------
---1.6 u --------------- ---
------------
---1.1 u --------------- ---------------
---1.1 u ------------ ------ ------------
---1.1 u --------- ---
--------------- ---
---0.81 UJ ------------------------------
---1.1 UJ ------------ ------------------
---140 ------------ ------------------
---19 u ------------------------ ------
---22 u ------------------------ ---
---
---7.8 u ------------------------ ------
---1 u --------------------- ---------
---1.1 u ------------------------------
---1.6 u ------------------------ ------
---1.1 u --------------- --------- ------
---0.81 UJ ------------------------------
---1.1 UJ ------------ --------- ---------
6 at 8
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard•
2,4-DICHLOROPHENOL "n/L
PENTACHLOROPHENOL "nil
1,2,3,4,6,7,8-HpCDD pq/L
1,2,3,4,6, 7 ,8-HoCDF nn/L
1,2,3,4, 7,8,9-HpCDF nn/L
1,2,3,4, 7,8-HxCDD oa/L
1,2,3,4, 7,8-HxCDF nn/L
1,2,3,6, 7,8-HxCDD nn/L
1,2,3,6, 7,8-HxCDF nn/L
1,2,3, 7,8,9-HxCDD nn/L
1,2,3, 7 ,8,9-HxCDF oo/L
1,2,3, 7 ,8-PeCDD nn/L
1,2,3, 7 ,8-PeCDF nn/L
2,3,4,6,7,8-HxCDF nn/L
2,3,4,7,8-PeCDF nn/L
2,3,7,8-TCDD oo/L
2,3,7,8-TCDF nn/L
OCDD nn/L
OCDF oa/L
TOTALHPCDD nn/L
TOTAL HPCDF nn/L
TOTALHXCDD oa/L
TOTAL HXCDF nn/L
TOTAL PECDD nn/L
TOTAL PECDF oa/L
TOTAL TCDD nn/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA-
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg.IL -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
*ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
PW-01 PW-01 -DUP PW-01 PW-01 -DUP
Mar-00 Jun-00
0.2 u 0.2 u 0.2 u 0.2 u
36 DJ 50 D 20 DJ 22 DJ
------5.8 u 4.4 u
------2.6 u 1.9 u
------2.8 u 2.1 u
---... 4.2 u 4.1 u
------2.9 u 2.5 u
------4.1 u 3.9 u
------2.1 u 1.8 u
------3.7 U 3.6 U
------3 U 2.6 U
------7.2 U 7.4 u
------3.6 U 3.7 u
------3 u 2.6 u
------3.7 u 3.7 u
------3.3 U 3.8 U
------2 U 2.4 u
------8.9 U 7.3 U
------5.4 u 5.7 u
------5.8 u 4.4 u
------2.8 u 2.1 u
------4.2 u 4.1 u
------3 U 2.6 U
------12 u 15 U
------4.1 u 3.7 u
------3.3 u 3.8 u
------2 U 2.4 u
PW-01 PW-01 PW-01 -DUP PW-01 PW-01 -DUP PW-01 I PW-01 -DUP PW-01
Sep-00 Dec-00 Mar-01 Jun-01 Aug-01
1 u 0.2 u 0.2 u 0.2 u 0.2 u 0.2 U 0.2 u 0.2 U
30 16 DJ 14 D 33 DJ 34 D 24 DJ 30 D 35 D
13.9 U ------4.2 u 4.8 u ------2.1 u
2.88 U ------3.8 u 12 u ------1.3 U
4.39 U ------4.1 u 7.6 u ··----1.3 U
5.1 u ---... 5.9 u 16 u ... -·· 1.7 u
2 u ------4.3 UJ 12 u -·----1.6 U
5.78 U ------6.7 u 18 u ------1.8 u
2.34 u ------4.3 u 12 u ------1.5 u
5.11 u ------5.9 u 16 u ... ---1.6 u
3.31 u ------5.1 UJ 14 UJ ------1.7 u
2.48 U ------11 u 7.7 u ------2.6 u
1.72 u ------5 u 5.9 u ------1.3 u
2.09 U ------4.8 UJ 13 UJ ------1.6 u
1.9 u ------5 UJ 5.9 u ------1.3 u
1.24 u ------5.6 U 5.3 u ------1.3 u
1.67 U ------5.8 u 4.3 u ------0.96 U
69.2 u ------9.7 UJ 13 u ------17 u
7.7 u ------11 u 9.4 u ------3.6 u
13.9 U ------4.2 u 4.8 u ------2.1 u
3.54 U ------4.1 u 12 u ' ---1.3 u
5.33 U ------6.7 u 18 u ------1.8 u
2.4 u ------5.1 u 14 u ------1.7 u
2.48 u ------11 u 7.7 u ------2.6 U
1.81 u ------5.6 U 9.7 u ... ---1.3 U
1.24 u ------5.6 U 5.3 u ------1.3 U
1.67 U ------5.8 U 4.3 u ... ---0.96 U
7 of 8
Historical Groundwater Sampling Analytical Results
Beazer -Morrisville, NC
ROD Analyte Name Units Groundwater Standard•
2,4-DICHLOROPHENOL 11n/L
PENTACHLOROPHENOL uo/L
1,2,3,4,6, 7,8-HoCDD nn/L
1,2,3,4,6,7,8-HoCDF nn/L
1,2,3,4, 7,8,9-HpCDF nn/L
1,2,3,4,7,8-HxCDD ~tL
1,2,3,4,7,8-HxCDF nn/L
1,2,3,6, 7,8-HxCDD oa/L
1,2,3,6, 7 ,8-HxCDF nn/L
1,2,3, 7,8,9-HxCDD nn/L
1,2,3,7,8,9-HxCDF nn/L
1,2,3,7,8-PeCDD nn/L
1,2,3,7,8-PeCDF oa/L
2,3,4,6,7,8-HxCDF nn/L
2,3,4,7,8-PeCDF nn/L
2,3,7,8-TCDD nn/L
2,3,7,8-TCDF nn/L
OCDD oa/L
OCDF nn/L
TOTAL HPCDD nn/L
TOTAL HPCDF oa/L
TOTALHXCDD nn/L
TOTAL HXCDF nn/L
TOTAL PECDD oa/L
TOTAL PECDF nn/L
TOTAL TCDD nn/L
TOTAL TCDF nn/L
Notes:
---indicates not analyzed
B indicates compound was also detected in the blank.
Bold Font indicates detection.
D indicates compound was diluted.
20
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
DRY indicates insufficient groundwater volume in well to produce sample.
J indicates estimated result.
NA indicates not applicable.
pg.IL -picograms per liter
REA indicates sample was reanalyzed.
Red Font indicates exceedance.
*ROD -Record of Decision Groundwater Cleanup Standard
U indicates compound was analyzed for, but not detected.
µg/L -micrograms per liter
Sampling Note:
Well C-01 B was inadvertanly sampled for dioxins/furans in May 2002.
PW-01 -DUP
Aug-01
0.2 u
29 D
2.1 u
0.76 U
0,8 u
1.4 u
1.3 u
1.5 u
1.3 u
1.4 u
1.4 u
2.2 U
1.2 U
1.4 u
1.1 u
1.5 U
0.89 u
7.6 u
1.8 u
2.1 u
0,8 u
1.5 u
1.4 u
2.2 u
1.5 u
1.5 u
0.89 U
PW-01 PW-01 -DUP PW-01 PW-01 -DUP
Dec-01 Mar-02
0.2 u 0.2 u 0.2 u 0.2 u
27 DJ 25 D 4.2 D 7.6
9.9 U 4.2 u ---...
1.8 u 2.1 u ... ---
2.2 u 2.5 u ------
0.67 u 3.5 u ------
0.85 U 3.1 u ------
0,9 u 3,9 u ------
0.54 u 2.9 u ------
0.62 u 3.5 u ------
0.65 U 3.5 u ------
1.7 u 5.5 U ------
0.85 U 3.2 U ------
0,6 u 3.2 u ------
0.85 U 3.2 u ------
0.61 u 2.3 u ------
1 u 1.8 U ------
32 u 15 U ------
5.2 u 4.8 u ------
9,9 U 4.2 u ------
3.7 u 2.5 u ------
1.1 u 3.9 u ------
0.85 U 3.5 u ------
2.5 U 5.5 u ------
0.97 u 3.7 u ------
1.4 u 2.3 u ------
1 u 1.8 u ------
8of 8
n" r.
PW-01 I PW-01 -DUP PW-01 PW-01 -DUP PW-01 PW-01 -DUP PW-01 I PW-01"-DUP
May-02 Aug-02 Dec-02 Feb-03 /•'""Cc::_--..=
0.2 u 0.22 u 0.2 u 0.22 U 0.39 u 0.39 u 0.6 u 0.59 U· '~·
18 D 20 D 21 D 16 D 22 D 22 D 21 19
3.3 u 3.2 u ... ---1.9 u 2.6 u ---...
2.8 u 2 u ... .. . 2.1 u 2 U ------
3.2 u 2.4 u ------0.79 U 0.81 u ------
3.4 u 2.8 U ------0.89 U 0.57 U ------
2.5 u 2 U ------1.8 U 1.7 u ------
3,7 u 3.1 u ------0.94 u 1.1 u ------
2.5 U 2 U ------1.1 u 0.74 u ------
3,3 U 2.7 u ------1.1 u 0.39 U ------
2.7 u 2.2 u ------1 u 0.63 u ------
7.2 u 4.6 u ------1.6 U 1.4 u ------
4.3 u 2.8 U ------1 u 0.97 U ------
2.7 u 2.2 u ------0.95 U 0.87 u ------
4.4 u 2.8 U ------0.94.U 0.93 U ------
5.2 u 3 u ------0.69 UJ 0.93 UJ ------
2.9 u 1.7 u ------1 UJ 1 u ------
14 u 21 u ------8.7 u 7.8 u ------
4.4 u 3.5 U ------2.8 u 3.2 u ------
3,3 u 3.2 u ------1.9 u 2.6 u ------
3.2 u 2.4 U ------2.1 u 2 u ------
3.7 u 3.1 u ------1.1 u 1.1 u ------
2.7 u 2.2 u ------1.8 U 1.7 u ------
7.2 u 6.4 u ------2.4 u 1.4 u ------
5 u 2.8 U ------1 u 0.97 u ------
5.2 u 3 u ------0.69 UJ 0.93 UJ ------
2.9 u 1.7 u ------1 UJ 1 u ------
• . ~ ft I'-\ I C: .•.Ur.'/ ('ij u I!'( :nrni-:, \., JJ\i'\ u l!.,;J NA
. Department•of.E:rjilironriierf~ndlllatural.•Resources
·• -~--~ "· iiRaleigh]Regional:Qffica':~ . · ~---. . .. 3aoo earreit cinve,\s~lie'i16.1iifialeisfi:c:Nc21sos · ·· .. ··•· -· ·_· -.· /ti'tfs1s,~td~?:<ici~r-:\ .•·. · ·. · .. -·•F;1eiAccesslRecord-~ -----
.. 'SECTfoN==========~~~c;;-i;::, . ; . . . . . \ --~..;::;.._,..I---------------------. TIME/DATE .-·\ 09:.30~~~1?-z r-o /
NAME.
REPRESENTING:
· Guidelines for·Access:·The staff of the\Raleigh Regional Office is dedicated to making public r~~rci?J..f!__our ____ __ ·' custody·readily available·to·the·public·torreview ana·copying.-We also have the responsibility to the public to safeguard these records and-lo carry out our day-to-day program obligations. Please read carefullv the following auidelines ·before signina the form:
1. We prefer that you call at least a day in advance to schedule an appointment to review the files. Aooointments will be scheduled between 9:00 a.m. and 3:00 p.m. -Viewing time ends at 5:00 · -p.m." Anyone arriving without an appointment may view the files to the extent that time and staff supervision is available.
2. You must specify files you want to review by facility name. The number of files that you may review at one time will be limited to five.
3. You may make copies of a file when the copier is not in use by the staff and if time permiis. Cost per copy is 10 cents for ALL copies if you make more than 25 copies -there is no charge for
less than 25 copies; payment may be made by check,. money order, or cash at the. reception desk. You can also be invoiced.
4. FILES MUST EE KEPT IN THE ORDER YOU FOUND THEM. Files may not be taken from the office. To remove, alter, deface, mutilate, or destroy material in one of these files is a misdemeanor for which you can be fined up to $500.00.
5. . In accordance with GeneralStatute 25-3-512, a $20.00 processing fee will be charged and
1.
2.
3.
4.
0.
collected for checks on which payment has been refused.
FACILITY NAME
-=-:---4(. ___ ,.,..,::::t,..,....½_~_V--C_. ·_c.._· _,1"'. 11c:.:c..w=/(-'o-"-'i.'-'--,.'-1 __,I {I?~&
Signature.and :Name:of Finn!Business Date
I f'leasollft»ch1Jbuslrl8SSc'1fdtolh/sform
COUNTY
Time In nme Out
STATE OF NORTH CAROLINA
Department of Environment and Natural Resources
Raleigh Regional Office
3800 Barrett Drive, Suite 101, Raleigh, NC 27609
919/571-4700
File Access Record
SECTION
TIME/DATE
NAME
REPRESENTING
UST/GW
Thursday, September 2, 1999
Sean K. Patrick
NFE Technologies, Inc. [phone]
Guidelines for Access: The staff of the!Raleigh Regional Office is dedicated to making public records in our
custody readily available to the public for review and copying. We also have the responsibility to the public to
safeguard these records and to carry out our day-to-day program obligations. Please read carefully the following
guidelines before signing the form:
1.
2.
3.
4.
5.
1.
2.
3.
4.
5.
We prefer that you call at least a day in advance to schedule an appointment to review the files.
Appointments will be scheduled between 9:00 a.m. and 3:00 p.m. Viewing time ends at 5:00
p.m. Anyone arriving without an appointment may view the files to the extent that time and
staff supervision is available.
You must specify files you want to review by facility name. The number of files that you may
review at one time will be limited to five.
You may make copies of a file when the copier is not in use by the staff and if time permits. Cost
per copy is 10 cents for ALL copies if you make more than 25 copies -there is no charge for
less than 25 copies: payment may be made by check. money order. or cash at the reception
desk. You can also be invoiced.
FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may not be taken from the
office. To remove, alter, deface, mutilate, or destroy material in one of these files is a misdemeanor
for which you can be fined up to $500.00.
In accordance with General Statute 25-3-512, a $20.00 processing fee will be charged and
c_ollected for ch._E!c::~~.<J.f.1.~ic::h p.:1yl_!.l_E'l_11J_b~~J?.ei,en _reflJS_E'ld.
FACILITY NAME
Koppers Co., Inc .. -ID #6754
COUNTY
Wake
Signature and Name of. Firm/Business
Please attach a business card to this form Date
O"t 3 9
Time In Time Out
: '
December I 0, 2002
Ms, Beverly Hudson
Remcd ial Project Manager
U,S. EPA -Region IV, 11th Floor
North Site !'Vlanagement Branch
6 I Forsyth Street, SW
Atlanta. GA 30303
RE: Monthly Progress Report #I 15
Remedial Action
Koppers Site -Morrisville, North Carolina
Dear Ms. 1-luclson:
i \
\ ' \
The RETEC Group, Inc,
300 Baker Avenue, Suite 302
Concord, MA01742
RETEC
-,
-• I \,' fr'. i97s)'371.1422 Phone
'·' (978j 371-1448 Fax
o1:c , 6 2002
': \ ww,w.re,t~c.com
, ', _) I \
1,L-' \
----~
In accordance with the Unilateral Order, and on behalf of Beazer East, Inc. (Beazer), please find attached
four (4) copies of the November Monthly Progress Report for Remedial Action at the Koppers Superfund
Site in Morrisville, North Carolina. No exceedenees occurred during this event However, since the
October chronic toxicity test failed, we are colleting on a monthly (rather than quarterly schedule) until
we have passing results for two consecutive months. Because the November chronic toxicity sample
passed, a second monthly chronic toxicity sample will be collected in December.
Should you need additional information regarding this progress report, please call Mike 1-Ielbling at
[phone] or me at [phone].
Sincerely,
The RETEC Group, Inc.
Rita Bauer
Project Geologist
CK:th
Enclosure
cc: D. Mattison -NC Superfund (2 copies)
L. l'aulconer-Wake County
G. Caskey -Enwood Structures
M. Helbling -Beazer
F:\l' ROJ ECl'S\U3624\Rcports\Mni1thly\2002\ ! I M-02.doc
D. Hails -Ecological Restoration, Inc.
J. Garrett-NC Division of Water Quality
D. Matthews -NC Div. of Waste Management
P. Kilchenstein -RETEC
MONTHLY PROGRESS REPORT #115
RI~MEDIAL ACTION
SITE NAME: Koppers Superfund Site
Beazer East, [nc.
Morrisville, NC
US EPA DOCKET NUMBERS: 93-09-C
PERIOD ENDING: November 30, 2002
I. PROGRESS MADE THIS MONTH
2.
3.
4.
5.
6.
7.
Remedial Action (RA) -HABITAT !Vl/TIGATION. No activities were conducted this
month.
Remedial Action (RA) -GROUNDWATER TREATMENT. The treatment system
operated throughout the month without upset. System performance was monitored on a
biweekly basis. Approximately 34,560 gallons of groundwater were extracted, treated in
the treatment plant, and discharged between November I, 2002 and November 30, 2002.
System water samples were collected on November 5, 2002 and November 22, 2002 in
accordance with the sampling schedule in the O&M manual. Samples were submitted to
Severn Trent Laboratories, Inc. and Tritest, Inc. for laboratory analysis. The operations
and sampling programs are summarized on the attached Table 1.
Remedial Action (RA) -EFFECTIVENESS MONITORING PROGRAM. No activities
were conducted this month.
Remedial Action (RA) -CORRESPONDENCE. None.
PROBLEMS RESOLVED None.
PROBLEMS ANTICIPATED None.
UPCOMING EVENTS Continue System O&M.
PERSONNEL CHANGES None.
SUBCONTRACTORS None.
ANALYTICAL DATA Analytical data from system influent and effluent
sampling received during this period are enclosed and are summarized on Table 2.
r::\l'R OJ ECTS\03(12,l\Ri..:ports\M rn1th ly\2002\ I l M-02 .doc
Date Systems Cummulallve SV-101 SV-101
Check Effluent Flow Sample Sample
(yes/no! (Gallons! (yeslnol Parameters
01/10/02 ves 3,251 280 no
01/23/02 ves 3 264 850 ves Penta 2 4-Dichloro Phenol
02/07/02 ves 3 283 240 no
02/19/02 ves 3,300,140 no
03/06/02 ves 3,318,630 no
03/21/02 ves 3,338,440 no
04/02/02 ves 3 356 200 ves Penta 2 4-Dichloro Phenol
04/17/02 ves 3 378,150 no
05/01/02 ves 3 397 920 no
05/13/02 ves 3414970 no
6/12/2002 ves 3 455 530 no
6/24/2002 ves 3467110 no
7/10/2002 ves 3 484 130 ves Penta 2 4-Dichloro Phenol
7/26/2002 ves 3,503 441 no
8/6/2002 ves 3 515 200 no
8/23/2002 ves 3 536 650 no
9/4/2002 ves 3 547 340 no
9/19/2002 ves 3,564 680 no
10/9/2002 ves 3 587,350 ves Penta 2 4-Dichloro Phenol
10/22/2002 ves 3 603 120 no
11/5/2002 ves 3,619 248 no
11/22/2002 ves 3 638 832 no
Notes:
Sampling point SV-101 is located before the Carbon Units (pretreatment)
Sampling point SV-304 is located between the Carbon Units
Sampling point SV-305 is lactated after the Carbons Units (post-treatment)
NR -Not recorded
F:\Pruj«tsl0l624\Repofts\Monlhlyl 11 M-02 Table L-"II
Table 1
Groundwater Treatment Operations and Sampling Program Summary
Koppers Superfund Site
Dioxin
Morrisville, North Carolina
November 2002
Associated SV-304 SV-304 Associated
Group Sample Sample Group
fyes/nol Parameters
no
1 2 ves Penta 2 4-Dichloro Phenol 1
no
no
no
no
1 ves Penta 2.4-Dichloro. Phenol 1
no
no
no
no
no
1 ves Penta 2 4-Dichloro Phenol 1
no
no
no
no
no
1 ves Penta 2 4-Dichloro Phenol 1
no
no
no
Associated Groups:
SV-101 -Group 1 is penta and 2,4-dichlorophenot; Group 2 is dioxin
SV-304 -Group 1 is penta and 2,4-dichlorophenol
SV-305 SV-305
Sample Sample
(veslno) Parameters
ves Penta 2 4-Dichloro Phenol
Penta, 2,4-Dichloro, Phenol, Dioxin, Chronic
ves Tox
ves Penta 2 4-Dichloro Phenol
ves Penta 2 4-Dichloro Phenol
ves Penta 2 4-Dichloro Phenol
ves Penta, 2 4-Dichloro, Phenol
Penta, 2,4-Dichloro, Phenol, Dioxin, Chronic
ves Tox
ves Penta 2 4-Dichloro Phenol
ves Penta 2 4-Dichloro Phenol Chronic Tax
ves Penta 2 4-Dichloro, Phenol
ves Penta. 2 4-Dichloro, Phenol Chronic Tax
ves Penta 2 4-Dichloro Phenol
Penta, 2,4-Dichloro, Phenol, Dioxin, Chronic
ves Tox
ves Penta. 2 4-Dichloro, Phenol
ves Penta 2 4-Dichloro Phenol Chronic Tax
ves Penta 2 4-Dichloro Phenol
ves Penta 2,4-Dichloro Phenol, Chronic Tax
ves Penta 2 4-Dichloro. Phenol
Penta, 2,4-Dichloro, Phenol, Dioxin, Chronic
ves Tox
ves Penta 2 4-Dichloro. Phenol
ves Penta. 2,4-Dichloro. Phenol Chronic Tax
ves Penta 2,4-Dichloro Phenol
SV-305 -Group 1 is penta, phenol, and 2,4-dichlorophenol; Group 2 is dioxin and Group 3 is chronic toxicity
Associated
Group
1
1 2 3
1
1
1
1
1 2 3
1
1 3
1
1 3
1
1 2,3
1
1 3
1
1 3
1
1,2 3
1
1 3
1
Table 2
Groundwater Treatment Analytlcal Data Summary
Koppers Superfund Sito -Morrlsv!lto, North Carollna
November 2002 ·
Analytical
Parameter Date Sample Sample
Sample Location Location
Collected SV-101 SV-304"
Pentachloroohenol 01/10/02
01123102 6.2 <1.0
02/07102
02/19102
03/0B,02
03/21102
04102!02 24 <1,0
04117102
05101/02
05113102
06112102
06/24/02
07110102 33 <1.1
07126/02
oaroe,o2
08/23102
09!04102
09/19102
10/09/02 " <0,96
10/22102
11105102
11122/02
2. 4-0ichloroohenol 01/10/02
01/23/02 <0.20 <0,20
02!07/02
02/19/02
03/06/02
03121/02
04/02/02 <0.20 <0.20
04117/02
05101102
05113/02
06112/02
06/24/02
07/10/02 <0.21 <0.22
07/26/02
08/06/02
08123/02
09/04/02
09119/02
10I09/02 <0.20 <0.19
10122/02
11/05/02
11122/02
Phenol 01110/02
01123/02 <0.20 <0.20
02107/02
02/19/02
03106102
03/21/02
04102/02 <0.20 <0.20
04117102
05101/02
05113102
06/12/02
06J24102
07110/02 <0.21 <0.22
07126102
08/00102
08123102
09/04102
09119102
10/09102 <0.20 <0.19
10/22/02
11/05/02
11/22/02
Chronic Toxicitv 01/23102
04/02102
05/01102
06/12/02
07110/02
08/14102
09/04102
10I09/02
11/05102
Dio;,in C2 3.7 8-TCDDl 01/23102 <2.6
04/02102
07110/02
10/09102
Nolu: AJI resu~• ••• In mictograms pu ~Ol!t'L) e•c•PI d•mn. Oio•,n ~Ila ,s'" pocograms per Iller (pgll.)
SV-101 • B•lore Carbon Un~•
'SV-304 -8-•11 Car1><>n Un~
""SV-305 -Allor Carbon Un1t1
F.\PrOJKIS\03624\Repor!s\Mont~ly\l lM.cl Table 2 xis
Sample
Location
SV-305 ..
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<0.96
<1.0
<0.98
<1.0
<1,0
<1.0
<1.0
<0.99
<0.99
<1,0
<1,0
<0,97
<1.0
<0.20
<0.20
<0.20
<O 20
<0.20
<0.20
<0.20
<0.20
<0.20
<0.19
<0,20
<0.20
<0.21
<0,20
<0.21
<0.20
<0.20
<0.20
<0.20
<0.21
<0.19
<0.20
<0.21
<0.20
<0.20
<0.20
<0,20
<0.20
<0,20
<0.20
<0.20
<0.20
<0.19
<0.20
<0.21
<0.20
<O 21
<0.20
<0,20
<0.20
<O 20
<0.21
<0.19
<0.20
Pass
Fail
Fail
Pass
Fail
Pass
Pass
Fail
Pass
<1.5
<O 62
<2,4
<3.1
•
A Da1 d Severn Trtnl pie
STL
ANALYTICAL REPORT
Ral.eigh, Biweekly NPDES
Lot II: C2K060332
Rita Bauer
The RETEC Group Inc
SEVERN TRENT LABORATORIES, INC.
Manager
November l.5, 2002
S~vem Trent Laboi'atorles, Inc.
STL !'lttsburgh • 450 William Pitt Way, Pittsburgh, PA 15238 Tel [phone] Fax [phone] • www,stl-inc,com
Sample Receiving:
CASE NARRATNE
THE RETEC GROUP
Raleigh, Biweekly NPDES
STL Lot# C2K060332
STL Pittsburgh, PA received one sample on November 6, 2002 in good condition. The
cooler was within the proper temperature range
GC/MS Semivolatiles SIM:
The reporting limits for the sample were adjusted to reflect the amount of sample used in
the extraction procedure.
Since insufficient sample volume was received to perform a matrix spike and matrix
spike duplicate, a Laboratory Control Sample (LCS) and Laboratory Control Duplicate
(LCD) were performed. All recoveries were within QC limits.
METHODS SUMMARY
C2K060332
ANALYTICAL PREPARATION
_P_ARAI-IE_=~T~E~R~--------------------METHOD . ~ME=TH=O~D ____ _
8270C (SIM) SW846 8270C SIM SW846 3520C
References:
SW846 "Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods", Third Edition, November 1986 and its updates.
SAMPLE SUMMARY
C2K060332
WO# SAMPLE# CLIENT SAMPLE ID
FCJHG 001 EFF/SV-305
NOTE CS):
-The analytical results of the samples listed above are prescmed on the following pages.
-All calrulatiom are performed before rounding to .avoid round-<>ff erron in calculated resulu,
-Results noted as "ND" Wttc not detecto:1 at or above the stated limit.
-This repon must not be reproduc.cd,. except in full, withoot lhe written approval of the laboratOJy.
-Results for !be following panmeten arc never~ on a dry weight basis: color, corrosivity, density, flasbpoim, ignitability, layers, odor, paint filter test, pH, porosity pressure, reaaivi~, redox pou:ntial, specific ~vity, spot tests, solids, solubility, temperature, viscosity, ari::I wcigbt.
SAMPLED SAMP
=Dcc,Ae:T=E'-~ TIME
11/05/02 08:20
'STL
Chain-of Custody Record & Analytical Request
Client: {2.J,<.c.., 1~-z.u-~½>rojectlD: _____ _ Address: JvD 'B J,t.; fi.-.i'!, Contact: f?:.rte-J\<'i'-"':Y'" Address:Ce<.o,J ffit'+ 1 0\'1'/~ Phone~ C\:H-1::78'-I j;)..;)._
Date: _l_l \~:r~(~o_:l __ _
Turnaround: _s_T() _____ _
nDlr.!IUAI
COC# 30365
Page { of~-
Report To: ________ _
SEE REVERSE FOR TERMS AND CONDITIONS
THE RETEC GROUP INC
Client sample ID: EFF/fN-305
GC/MS Semivolatiles
Lot-Sample# ... : C2K060332-001 Work Order # ••• : FCJHGlAA
Date Received .. : 11/06/02
Allalysis Date .. : 11/14/02
Matrix .•.•..••• : WATER
MS Run. # ••••••• : Date Sampled ... : 11/05/02
Prep Date ...•.. : 11/os/02
Prep Batch# ... : 2315091
Dilution Factor: 0.97
PARAMETER
2,4-Dichlorophenol
PentachlOrophenol
Phenol
SURROGATE
Nitrobenzene-d5
Terphenyl-dl4
2-Fluorobiphenyl
2-Fluorophenol
Phenol-d5
2,4,6-Tribromophenol
Method ..•....•• : SW846 8270C SIM
REPORTING
RESULT LIMIT UNITS
ND 0.19 ug/L
ND 0:97 ug/L
ND 0.19 ug/L
PERCENT RECOVERY
RECOVERY LIMITS
74 (30 -121)
61 (11 -119)
77 (39 -115)
72 (37 " 115)
70 (41 -115)
86 (40 -115)
METHOD BLANK REPORT
GC/MS Semivolatiles
Client Lot # .•. : C2K060332 Work Order # •.• _: FCTHClAA
MB Lot-Sample#: C2K110000-091
Analysis Date .. : 11/14/02
Dilution Factor: 1
PARAMETER
Pentachlorophenol
Phenol
2,4-Dichlorophenol
SURROGATE
Nitroben2ene-ds
Terphenyl-d14
2-Fluorobiphenyl
2 -Fl uorOphenol
Phenol-d5
2,4,6-TribromoPhenol
NOTE(S):
Prep Date •..•.. : 11/08/02
Prep Batch# .•. : 2315091
REPORTING
RESULT. LIMIT UNITS
ND 1.0 ug/L
ND 0,20 ug/L
ND 0.20 ug/L
PERCENT RECOVERY
RECOVERY LIMITS
74 (30 -121)
60 (11 -119)
77 (39 • 115)
74 (37 -115)
74 (41 -115)
87 (40 -115)
Calculations are pcrfonned before roundiIJ& to avoid romid-off errol"S in calai.1.atcd re.suits.
Matrix ......... : WATER
METHOD
SW846 8270C SIM·
SW846 8270C SIM
SW846 8270C SIM
LABORATORY CONTROL SAMPLE EVALUATION REPORT
GC/MS Semivolatiles
Client Lot# •.. : C2K060332 Work order # ••• : FCTHClAC-LCS
FCTHClAD-LCSD
Analysis Date .. : 11/14/02
Matrix ..•.....• : WATER LCS Lot-Sample#:
Prep Date .•..•. :
Prep Batch # ••• :
Dilution Factor:
PARAMETER
Phenol
Pentachlorophenol
C2K110000-091
11/08/02
2315091
l
PERCENT
RECOVERY
68
70
.95
98
2,4-Dichlorophenol Bl
85
SURROGATE
Nitrobenzene-d5
Terphenyl-dl4
2-Fluorobiphenyl
2-Fluorophenol
Phenol-d5
2,4,6-Tribromophenol
NOTB(S):
Cak:ulation:s arc perfonncd before rowmng to avoid round-off erron in calculated results.
RECOVERY
LIMITS
(10 -131)
(10 -131)
(10 -140)
(10 -140)
(42 -115)
(42 -115)
PERCENT
RECOVERY
72
77
SB
61
74
76
70
71
69
68
Bl
83
RPD
RPD LIMITS METHOD
SW846 B270C SIM
2.8 ( 0-43) SWB46 8270C SIM
SWB46 B270C SIM
3.4 (0-56) SW846 8270C SIM
SW846 8270C SIM
4.6 (0-44) SW846 B270C SIM
RECOVERY
LIMITS
(30 -121)
(30 -121)
(ll -119)
(ll -119)
(39 -115)
(39 -115)
(37 -115)
(37 -115)
(41 -ll5)
(41 -115)
(40 -115)
(40 -115)
i \' ' '
A pert of SovemTIUII pie
I
I
~
STL
ANALYTICAL REPORT
Ral.eigh, Biweekly NPDES
Lot JI': C2K230134
Rita Bauer
The RETRC GroUp Inc
SEVERN TRENT LABORA:I'ORIES, INC;
·~
Veronica Bortot
Project Manager
December 4, 2002
Severn Trent Laboratories, Inc,
STL Pittsburgh• 450 William Pitt Way, Pittsburgh, PA 15238 Tel [phone] Fax [phone] • www.stUnc.com
Sample Receiving:
CASE NARRATIVE
THE RETEC GROUP
Raleigh, Biweekly NPDES
STL Lot# C2K230134
STL Pittsburgh, PA received one sample on Nov=ber 23, 2002 in good conclition. The cooler was within the proper temperature range
G:C/MS Semiyolatil~ SIM:
The reporting limits for the sample were adjusted to reflect the amount of sample tised iil the extraction procedure.
Since insufficient sample volume was received to perform a matrix spike and matrix
spike duplicate, a Laboratory Cciritrol Sample (LCS) and Laboratory Control Duplicate (LCD) were performed. All recoveries were within QC limits.
;
\ I:
I
I
METHODS SUMMARY
C2K230134
ANALYTICAL PREPARATION
~p~===~T=E~R'---'--'-'--------------"--'-'-----METHOD ~METH==O=D ____ _
8270C (SIM) SW846 8270C SIM SW846 3520C
References:
SWB46 "Test Methods for Evaluating solid· waste, Pliysica:1/Chemica1
MethodS", Third Edition, November 1986 and its updates.
WO # SAMl?LE# CLIENT SAMPLE ID
FDRKS
NOTB(S):
001 STSEFF/SV-305
SAMPLE SUMMARY
C2K230134
-The analytical results of dle SUDples listed abon: arc prcxDtCd o.n the rollowini: pages.
-A,11 calndation, 'Ire pcrl'omaed bdotc rmmdmg to aYDid rouod~tf errors in calc:ulated results.
-Remilis I!Oiid U •ND~ were not detected a:1 Of Abci~e the aited iimii.
-This repon must not be rq,roduc:ed, except in full. without the wntte:n ~roval. of the hb~ratory.
• Rew!B for the following parunetm are never reported on a city weight basis: color, corrosivity. demity, flashpoint. ignitability, layers, odor,
paint tilter test, pH, porosi.ly pressure, reactivity, redax potmtial, spcclfic ID,vlty, spot tests, solids, solubility, tmipcnture, ¥uc:osity1 and weight.
SAMPLED SAMP
DATE TIME
ll/22/02 ll:20
I
I
I
I
I
I
I
' I
I
I
I
I
I
Chaihot
Custody Record
·◄1 4 STL 2 I 0901)
Cl/en/~·.
Address
Ea..\6.., Lf ')OD
City~
(_..,..,-lsmt l21
PCod• · · ot1<l:i. Project N~ and L
"iJ/G\.7•• pae:s,~e) ,m" Contracl/Purchase rder/Quote Nol , ~ P.:/1,,c. -'t -fl~ wJ .f ._ o'i<-
Sample 1.0. No. and Description
Date (Containers for each sample may be COfTlbined on one foe) ~ i ~ (F-P (,;;;)/-l ,,':{' 11\.:i,dn ..
Possible Hazard ldenUllcatJon
0 Non-Hazard 0 Flammable 0 Skin /rrfltJnl 0 'Polson. B
ProjscDa;ar_ ~~ Tefephone Number (Area Code)!Fax Number C\,18'-111-14);).
Sil9 Cofltact 1 ~~.Cootact
Calrier/WaybHI Number
'.
Containers & ~ Matrix· ... Preservatives "' l J • i ~· -~ ~ Time l ~ 8 <l C ~ ,;, ~ ~~ ·~ ~ .~ 11 ao ~ ~ ~
..
I
~, I Sample Disposal .£v nlmown O Return To Client DiSposBi By Lab D Archive Frir
Tum Around Time Required · D 24 Hours . DC Rsqu,remenls (Specify) 14 Days O 21 Days
2. Reffnquishad 8 .
3. Relinquished By
Comments.
DISTRJBUTTON: WHITE-. Returned lo Cllsnt wtlh Report; CANARY: Slays with the Sample: PINK -Fleld Copy
Severn Trent Laboratories, Inc.
O~ts. ~Jd~ Cha'1 °1 ci'447'4 4 II
Lab l'jlJ l!ll8f
) l Paga of Analysis [Attach list if more s ace Is needed
' ..
Special lnstf1Jct/ons/
Conditions of Receipt
.
'
(A toe may be assessed If samplr1s aro ralained Months IMgor than 1 month)
nme
Dato nme
Date Time ltrl-J · o"! ~-
THE RETEC GROUP INC
Client sample ID: STSEFF/SV-305
GC/MS Semivolatiles·
Lot-Sample# .. ,: C2K230l34-00l
Date Sampled •.. : 11/22/02
Work order # ••• : FDR.KBlAA
Date Received .. : 11/23/02
Analysis Date .• : 12/03/02
Matrix ..•..•••• , WATER
MS Run # •.•.••• , ~ Date ..•••. : 11i25/02
~Batch# ... : 2329317
Dilution Factor: 1.01 Method •.....•.. : SW846 8270C SIM
PARAMETER
2,4-Dichlorophenol
Pentachlorophenol
Phenol
SURROGATE,
Nitrobenzene-dS
Terphenyl-dl4
2-Fluorobiphenyl
2-Fluorophenol
Phenol-d5
2,4,6-Tril>roiriophenol
. RESULT
ND
ND
ND
PERCENT
RECOVERY
67
74
67
58
66
64
REPORTING
Lil'ITT UNITS
0.20 ug/L
l.O ug/L
0 .20 ug/L
RECOVERY
LIMITS
(30 -121)
(il -119)
(39 -115)
(37 -115)
(41 -115)
(40 115)
,,1
I
MllTHOD BLANK REPORT
GC/MS Semivolatiles
Client LOt # ••. : C2K230l.34 Work Order # ••• : FDT3Hl.AA
MB Lot-sample#: C2K250000·3l.7
AnaJ.ysis Date .. : l.2/03/02
Dilution Factor: l
Pentachlorophenol
2,4"Dichlorophenol
Phenol
SURROGATE
Nitrobenzene·dS
Terphenyl"dl4
2-Fluorobiphenyl
2-Fluorophenol
Phenol-d5
2,4,6-TribromOphenol
NOTE (S) ,·
Prep Date ..•••• : l.l/25/02
Prep Batch# ••• : 23293l.7
REPORTING
RESULT LIMIT UNITS
ND 1.0 ug/L
ND 0.20 ug/L
ND 0.20 ug/L
PERCENT RECOVERY
RECOVERY LIMITS
70 (30 -l2l.)
76 ( l.l . l.l9)
66 (39 . l.l5)
62 (3 7 . l.l5)
69 (4l. . l.l.5)
65 (40 . ll.5)
Calculations are perfonned before rounding to Jl,void IOUlld-Qff ermn in alc:ohted results.
Matrix .•.•.•••. : WATER
METHOD.
SW846 8270C SIM
SWB46 B270C SIM
SWB46 8270C SIM
LABORATORY CONTROL S1IMPLB EVALllATION REPORT
GC/MS Semi.volatiles
Client Lot# ••. : C2K230134 work Order# .•• : FDT3HlAC-LCS Matrix .•.....•. : WATER LCS I.qt-sample#: C2K25000D-317 FDT3H1AD-LCSD Prep Date ..•.•. : 11/25/02 Analysis Date .• : 12/03/02
Prep Batcil # .•. : 2329317
Dilution Factor: 1
PE;RCENT RECOVERY RPI> PARAMETER RECOVERY LIMITS ~ LIMITS METHOD Phenol 70 (io -131) SWB46 B270C SIM
73 (10 -131) ,4.4 (0-43) SWB46 B270C SIM Pentachlorophenol 77 (10 -140) SWB46 B270C SIM
83 ( J. 0 -140) 7.7 (0-56) SW846 8270C SIM' 2;4-Dichlorophenol 6J. (42 -J.15) SW846 8270C SIM
65 (42 -J.15) 5.7 (0-44) SW846 8270C SIM
PERCENT RECOVERY SURROGATE RECOVERY LIMITS Nitrobenzene-d5 65 (30 -121)
69 (30 -121) Terphenyl-dl4 61 (11 -119)
61' (11 -119) 2-Fiuorobiphenyl 63 (39 -115)
65 (39 -115) 2-Fluorophenol · 57 (37 -115)
60 (37 -115) Phenol-dS 51 (41 -115)
55 (41 -115) 2,4,6-Tribromophenol 66 (40 -1i5J
70 (40 -115)
NOTE(S):
Ca1rulations are perfotmed before rounding to avoid muru:1-otr errors in calculated results.
Effluent Toxicity Report Form -Chronic Pass/Fail and Acute LCSO Date: 11/22/02
Facility: BEAZER NPDES#: NC
Laboratory Performing Test: TRITEST, INC.
0211-00123
MAIL ORIGINAL TO:
Pipe#: County: WAKE
Comments:
* PASSED: 15.72% Reduction*
Environmental Sciences Branch
Div. of Water Quality
N.C. DENR
1621 Mail Service Center
North Carolina Ceriodaphnia Raleigh, North Carolina 27699-1621
Chronic Pass/Fail Reproduction Toxicity Test
CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 30 33 28 29 26 32 30 0 29 27 25 29
Adult (L)ive (D)ead L L L L L L L D L L L L
Effluent % : 90%
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
Chronic Test Results
Calculated t =
Tabular t =
% Reduction= 15.72
% Mortality
8.33
Control
8.33
Treatment 2
Control CV
Avg.Reprod.
26.50
Control
22.33
Treatment 2
32.641% PASS FAIL
# Young Produced 23 25 27 27 28 1 24 25 22 15 25 26 % control ergs
producing 3rd
brood
0C
Adult (L)ive (D)ead L L L L L D L L L L L L Check One
pH
Control
Treatment 2
1st sample
t8IB
1st sample
~
s s t e t e a n a n r d r d
t t
D.O. 1st sample 1st sample
2nd sample
~
s
t e
a n
r d
t
2nd sample
92%
Complete This For Either Test
Test Start Date: 11/05/02
Collection (Start) Date
Sample 1: 11/04/02 Sample 2: 11/07/02
Sample Type/Duration
Grab Comp. Duration
Sample 1
f---t----+------,
X 24 hrs
Sample 2 X 24 hrs
1st
D
I S L A
U M
T p
Hardness (mg/1) 44 ......... .
2nd
P/F
s
A
M p
Control ffi [83B3 [ffiB3 f----+----+----
Spec. Cond. (µmhos) 200 924 891 Treatment 2 f----+---+----i Chlorine(mg/1) <0.1 <0.1
LC50/Acute Toxicity Test Sample temp. at receipt(°C) f---+--t---j
(Mortality expressed as%, combining replicates)
LC50 = % 95% Co-n~f-1-d~e-n_c_e--Limits
% --%
Concentration
Mortality
start/end
Method of Determination
Moving Average Probit
Spearman Karber Other
pH
Organism Tested: Ceriodaphnia dubia Duration(hrs):
Copied from DWQ form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.41)
1.1
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Note: Please
Complete This
Section Also
start/end
D.O.
0.7
. ,
TRITEST, INC. ·
Bioassay Chain 'of Custody Form
Bioassays.a,.re to ·be sampled a,.fter . -'_Tue-sday &. Friday.
B:30a.m. on
Faalli'ly Name: 'f?<,g 1&C { .e..Ja;,'J b . ,
Ad<hss: R~ . P.O.#: ________ _ 300 R ... \s+c Av.e. ~,c97K )311-1¥~~ ~cocJ h'.)14 oi,1./;). ·eomact: @~ 8'9-Y-LC· Co~'ly: 'w..h . Ou1!all/Pipe:ll: ___ · _·NPDESPe:mit\11: ·tf/11,vb t;:;ttiJ/ %EffillO!lt0
D!Jutlon : _..,,<J/""-"----
. SB!llple Site Description: --=~'--"-Y ... s ___ /£'---~ ... f------------
Semple Coll::::t_>:::a ... f~·:.::i:::"-.s;"-ex---. :::Jt:..,1,-'-.:L~,_;\:\:·::::::::~::~--
Sample 'fype:: Composite :
Dile Stazted : _ _._, ·._j +-/ __.if!--'/ O'-~:..,.... _______ • Tlme · .. _ .:0,:..::6:..::~;.;:;'D'-. __ (y;i} or Pll!°
Date Ended: / cl S.-/ojl Tim~: · CfiJ,j _· f/ip or PM
San,plc, p:r Hour:---~-----·11 ,;om: ,i>f ·
~
!>ate'-----=--=--------rune: _.--. AM or PM Sampl~ Volume: ___ ,._~..____£-=-_____ Chllled durlng Collectlon? _ _,f __
Method ofTnsnsponlliion to Lab : ;;;J . a;
. . • • • • • • • • • • • • • • • • • • • • • • • • • • · . Chain cf Cµstod:y R:uease .............................
For Laborator,y USt O:nly I I ,a, · Rcce!ving Te:mp=n: _! .... , __________ By; 1-· Qo ,.SD/'fu.l::
. . ..
l\e:sidwChlorlne: __ ._,.;_r;:i, _______ Numbe:rofBot!los:_· ....,:2-'-----
Acfdr=: 39O9·Beeyl li-lWeigb, NC 27607 Ph011e(919) 834-4984 Fmc (91!?) 834-64!11-oJ-// -.(}0( ;)..3 _-~tJ ( (
TRITEST, INC.
Bioassay Chain •of Custody Form
Bioassays . are to ·be samoled q,fter B:30a.m. on
P.O.#: ___________ _
Pb.on~# ( C/7 J ) 57(-/f d "J.
Contact : l<ij--,,._ fl:,..µ or .
County : __ "'uJ.,.· '-'J=~--=· '-----Outfalll Pipe# : _OJ=-·=-,..(_· __ . NP~ES Permit i: . ~ 1.... l.urJ;_
%Effiuent Dilution: _ _,_ff-'-._____ T,;.iMethod :· ~' cJ'w· .
· Sample Site Description: __ 5_,.;...· -.:,=-'~-_C.c...F~_ '-F _____________ _
Sa.-nple Collector: _Print> --,/'-~1--_A~. '-"v\-',_·'--~',,=-'-,no/1'"" • .,_·u.fh.,_r-/d ________ _
Sigru,rure> _ _,,,f_,.,,~ae...::......:.=~.;..~~""'J/"-----~-------
Sample Type: Comnosite:
Date Started : __ ...,· i.:,.14--(-.!..i·, f:-.:o:.::"-:......:--~---TUlle : / J i Y
Date Ended: ---'-(f..:..J{ai,.,_~-"-0<.:,,,· _______ Tim~: · /.J ;;)f!J
Samples per Houz: ---+--------# ~ou;..: JP
Grab:
_D_ate_: __ · ____ ___,,~--------T=: / . AM or PM
Sample Vol=: ___ ;;Jc;c_.:.._f,.;;_:.1-v....;;_:;.._ ___ ~-Chilled du.-ing Colle::tion; f .
Method of Transportation to Lab: _,_W.=;=..><d@""'-~""-'-'l,v_.· ___ __, ______ _
; • • • • "• ..... • • • • • • • • • • • • • ♦ • • •· • Cha.inofCµStodyR.cl-....ase •••••••• ♦ •• •. ♦ • ♦ • • • + •·. ~ • ♦ ♦ ♦ •
Relinqui..-.ed Bv .• A Date, Tim~. Rec::ived Bv "Date T~ /✓-~ IL<¥ n/f/t!'?-,u.'Z,b 7. r.iOVLA---z.· ..... ,J (LL'>A .'
..
For Laboratory Use Ollly
· Receiving Tel!lpera!ur::: _ __,.O'-'-• -47 _______ By: ..J..· ~
Residual Chlorine: · ~ Number ofBottics: --'g=----
A&lress: 39D9·Bery! Rd.· R8loigh. NC 27607 Phone{9J9) _834 -4984 Fax (91~) 834-6491 01-./ (-()()/ 2 _11'7>~ (
:
JAMES B. HUNT JR ... '
GOVERNOR Ms. Beverly Hudson
Remedial Project Manager
Superfund Branch
Waste Management Division
NORTH ·CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
United States Environmental Protection Agency
Region IV
61 Forsyth Street, I Ith Floor
Atlanta, GA 30303
Re: Proposed Remedial Action Groundwater Monitoring Program
Koppers Company NPL Site
Morrisville, Wake County
Dear Ms. Hudson:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received the Proposed Remedial Action
Groundwater Monitoring Program for the Koppers Company National Priorities
List (NPL) Site. The Superfund Section has reviewed this document and offers
the attached comments.
We appreciate the opportunity to comment on this document.. If you have any
questions, please feel free to call me at [phone], extension 349.
Attachment
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
cc: Mike Slenska, Beazer East, Inc.
Jay Zimmerman, NC DENR Div. of Water Quality
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE 919·733-4996 FAX 919•715-3605
AN EQUAL OPPORTUNITY/ AF'F'IRMATIVE ACTION EM Pl.OYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
Ms. Beverly Hudson
September 10, 1998
Page I
PROPOSED REMEDIAL ACTION GROUNDWATER MONITORING PROGRAM
Section 2 Previous Analytical Findings
I. The second paragraph of this section indicates that fifteen groundwater monitoring
wells were sampled for pentachlorophenol and 2,4-dichlorophenol analysis. This
section also states that three groundwater monitoring wells were sampled for dioxin and
furan analysis. Please revise either this section or the referenced Figure 2-3 in order to
accurately describe which groundwater monitoring wells were sampled for laboratory
analyses.
2. The paragraph included as page 2-3 of this section is a duplicate of the last paragraph
on page 2-2 of this section. Please delete page 2-3.
Section 3 Groundwater Monitoring Program
3. The proposed groundwater monitoring program is unacceptable per current NC DENR
Division of Water Quality policy. Quarterly sampling of all fifteen groundwater
monitoring wells shall continue until four consecutive quarterly groundwater sampling
events indicate that the concentrations of pentachlorophenol, 2,4-dichlorophenol,
phenol and dioxin meet the specified cleanup levels. If an individual groundwater
monitoring well achieves the specified cleanup goal prior to the other groundwater
monitoring wells, annual sampling of the groundwater monitoring well shall commence
until such time as all fifteen groundwater monitoring wells achieve the specified
cleanup goals for four consecutive quarterly groundwater sampling events. Upon
achieving the specified cleanup goals at all fifteen groundwater monitoring wells,
Beazer East, Inc. shall seek written approval from the NC DENR and the United States
Environmental Protection Agency (US EPA) to discontinue the groundwater extraction
system. Once written approval has been received from the NC DENR and the US
EPA, Beazer may discontinue the groundwater extraction system. At this point,
quarterly groundwater sampling shall resume at all fifteen groundwater monitoring
wells until Beazer can demonstrate that the specified cleanup goals have been
maintained for four consecutive quarterly groundwater sampling events. If Beazer
cannot make this demonstration to the satisfaction of the NC DENR or the US EPA,
Beazer shall evaluate additional groundwater treatment options in order to meet the
specified cleanup goals.
Ms. Beverly Hudson
September 10, 1998
Page 2
4. The second sentence of the third paragraph of this section states that "concentrations of
the constituents of interest in wells C-l0B, C-14B, and M-04 during the next sampling
event at or below the specified cleanup goal would indicate that these wells also have
been demonstrated to meet the specified cleanup goals and sampling for these wells
would be discontinued." However, the laboratory documentation included in Appendix
B of the One-Year Groundwater Monitoring Report indicates that the groundwater
sample obtained from groundwater monitoring well C-14B contained 20 micrograms
per liter (µg/1) pentachlorophenol (in excess of the groundwater cleanup goal for
pentachlorophenol). Therefore, groundwater monitoring well C-14B must be sampled
for a minimum of four additional quarterly sampling events until it has been
demonstrated that groundwater monitoring well C-14B has achieved the specified
cleanup goal. Please revise this paragraph accordingly.
5. The third sentence of the fourth paragraph of this section states that "if the findings for
all wells meet the specified cleanup goals, the extraction system will be discontinued
and .a semi-annual boundary well monitoring system will be established to monitor
long-term groundwater quality at the boundary of the site." Please note that any
extraction system shutdown and boundary well monitoring system will require written
approval from the NC DENR Superfund Section and the US EPA prior to
implementation. Please revise this section accordingly.
Table 2-1 Summary of Historical Groundwater Quality Data for Constituents of
Interest
6. Table 2-1 indicates that the groundwater sample obtained from groundwater monitoring
well C-14B in January 1998 contained no detectable concentrations of
pentachlorophenol at a laboratory quantitation limit of 1 µg/1. However, the laboratory
documentation included in Appendix B of the One-Year Groundwater Monitoring
Report indicates that the groundwater sample obtained from groundwater monitoring
well C-14B in January 1998 contained 20 µgll pentachlorophenol. Please clarify this
discrepancy.
Figure 2-1 Groundwater Elevation Contours, Shallow Wells -January 21, 1998
7. Figure 2-1 indicates that the groundwater elevation for groundwater monitoring well C-
SA is 348.92 feet (ft), mean sea level (ms!). However, Table 2 of the One-Year
Groundwater Monitoring Report indicates that the groundwater elevation for C-8A is
348.52 ft, ms!. Please clarify this discrepancy.
Ms. Beverly Hudson
September 10, 1998
Page 3
8. Figure 2-1 does not indicate the location or groundwater elevation of groundwater
monitoring well C-30A. Please revise Figure 3 to depict the location of groundwater
monitoring well C-30A.
Figure 2-2 Groundwater Elevation Contours, Intennediateffieep Wells -October 21,
1997
9. Please provide justification for including this figure that depicts the October 1997
groundwater elevation contours of the intermediate/deep wells rather than the January
1998 groundwater elevation contours of the intermediate/deep wells.
10. Figure 2-2 does not indicate the location or groundwater elevation of groundwater
monitoring wells C-lB, C-9C, C-12C, C-17C, C-19C, C-20C, C-22C, C-33C or C-
34C. Please revise Figure 2-2 or include an additional figure to depict this data.
Additionally, please provide justification for the inclusion of groundwater elevation
data for one groundwater monitoring well over another in those instances in which
groundwater monitoring well clusters have been installed.
11. Groundwater monitoring well C-30A was inadvertently included in Figure 2-2. Please
remove C-30A from Figure 2-2 and place in Figure 2-1.
Figure 2-3 On-Site and Near Off-Site Monitoring Well Locations
12. Figure 2-3 does not indicate the location of groundwater monitoring wells C-16C, C-
17C, C-18C, C-19C, C-20C, C-21C, C-22C, C-23C, C-24C, and C-32C. Please
revise Figure 2-3 or include an additional figure to depict the locations of all
groundwater monitoring wells.
&mer
BEAZER EAST, INC .. ONE OXFORD CENTRE, SUITE 3000, PITTSBURGH, PA 15219-6401
July 20, 1998
Ms. Beverly Hudson
Remeidal Project Manager
US Environmental Protection Agency -Region IV
Atlanta Federal Center ·
61 Forsyth Street, SW
Atlanta, Georgia 30303-8909
RE: Proposed Remedial Action Groundwater Monitoring Program
Former Koopers Company, Inc.
Site Morrisville, North Carolina
Dear Ms. Hudson:
Please find four (4) copies of the Proposed Remedial Action Groundwater Monitoring
Program for the Former Koppers Company, Inc. site located in Morrisville, North
Carolina. The report is being submitted by Beazer as referenced in the June 4, 1998
correspondence to USEPAtransmitting the One-Year Groundwater Monitoring Report.
Please feel free to call with any comments or questions or if any additional information
is needed.
Sincerely,
Michael Slenska, P.E.
Environmental Manger
Enclosures
cc: Dave Mattison, NCDEH (2 copies)
. Ben Genes, RETEC (w/o enclosure)
q .
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Proposed Remedial Action
Groundwater Monitoring Program
Former Koppers Company, Inc. Superfund
Site, Morrisville, North Carolina
Prepared by:
Remediation Technologies, Inc.
9 Pond Lane, Suite 3A
Concord, MA 01742
RETEC Project No.: 4-3624
Prepared for:
Beazer East, Inc.
One Oxford Centre, Suite 3000
Pittsburgh, PA 15219
July 20, 1998
F:IPROJECTS\4-3624\GW_MON\GW_MON.WPD
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Table of Contents
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
2 Previous Analytical Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
3 Groundwater Monitoring Program ................................... 3-1
List of Tables
Table 2-1 Summary of Historical Groundwater Quality Data for Constituent of
Interest, First Quarter 1990 through First Quarter 1998
Table 2-2 Summary of PCDD/PCDF analytical Results and Toxicity Equivalence
Concentrations, January 1998
List of Figures
Figure 2-1
Figure 2-2
Figure 2-3
Figure 3-1
Groundwater Elevation Contours Shallow Wells, January 21, 1998
Groundwater Elevation Contours Intermediate/Deep Wells, October 21,
1998
On Site and near Off Site Monitoring Well Locations
Monitoring and Operations Evaluation Process
1 Introduction
Beazer East, Inc. (Beazer) has been operating a groundwater extraction and
treatment system at this former wood treating facility since February l 997. The
site, located approximately one mile north of Morrisville, North Carolina, was
.purchased by Koppers Company, Inc. in 1962 and ceased operations in
September 1986. The Koppers Company was acquired by Beazer in 1988.
During plant operation, two types of wood treatment activities were conducted,
a lamination process and a wood preserving process called CELLON. The
CELLON process used from approximately 1968 to 1975 consisted of press-
injecting pentachlorophenol in a liquified butane isopropyl ether solution into the
wood. Excess pentachlorophenol salt was removed by steaming the wood. The
wash solution from the steaming process was filtered to recover
pentachlorophenol, then the solution was discharged into a fire pond on the site.
The.site was placed on the National Priorities List (NPL) by the Environmental
Protection Agency (EPA) in March of 1989. Remedial Action activities
conducted at the site include: soil removal and off-site incineration; surface water
treatment and discharge; and groundwater extraction, treatment, and discharge
under authorization by the State of North Carolina. As noted i.n the Record of
Decision (ROD), the groundwater treatment system is to continue to operate
until the following cleanup standards are achieved: 30 pg/L for dioxins/Eu.rans, l
µg!L for pentachlorophenol and 20 µg!L for 2,4-dichlorophenoL
During the first year of full-scale groundwater-extraction and treatment
operations, groundwater was monitored on a quarterly basis in accordance with
the Baseline Groundwater Data Summary Report (Fluor Daniel GTI, September
1996). The results of these monitoring activities were reported in the Six-Month
Groundwater Remedial Actiori Monitoring Report (Fluor Daniel GTI, November
1997 and One-Year Groundwater Remedial Action Monitoring Report (Fluor
Daniel GTI, June 1998). The Proposed Groundwater Monitoring Program
presents a summary of the analytical findings reported in these two documents
and a proposed groundwater monitoring plan to evaluate the continuing
performance of the groundwater remediation system at the site.
Introduction 1-1
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2Previous Analytical Findings
As reported in the Six-Month and One-Year Groundwater Remedial Action
Monitoring Reports (Fluor Daniel GTI, November, 1997 and June 1998),
groundwater elevation data were collected during all four quarter's monitoring
activities from on-site and near off-site monitoring wells. This information was
used to develop potentiometric maps to assess the hydraulic influence of
groundwater pumping at well PW-1 for the shallow and bedrock monitoring
intervals. Figures 2-1 and 2-2 present the results for the most recent monitoring
event for the shallow and intermediate/deep monitoring wells. Figure 2-1 for the
shallow monitoring interval indicates the continued presence of a potentiometric
high in the north central-area of the site and an elongated area of depression
originating from this potentiometric high area to the west of pumping well PW-1
that extends to the northwest.
Groundwater samples were .collected from fifteen monitoring wells (shown in
Figure 2-3) during the January 1998 monitoring event and were analyzed for
pentachlorophenol and 2,4-dichlorophenol by EPA Method 8270B, using ion trap
technology. This analytical method provides a detection limit of 1 µg!L for
pentachlorophenol and 0.2 µg!L for 2,4-dichloropheno!. Three of the fifteen
samples were also analyzed for dioxins and furans (PCDD/PCDF) using EPA
Method 8290. These samples for dioxins and furans were collected from the three
wells where pentachlorophenol concentrations exceeded the cleanup standard of
1 µg!L during both the Baseline and Six-Month monitoring events.
A summary of historical pentachlorophenol and 2,4-dichlorophenol groundwater
data collected from the site since 1990 is presented in Table 2-1. This data
includes the results from the July 1997 and January 1998 sampling events
conducted after the initiation of full-scale groundwater extraction operations. As
shown in Table 2-1, the following wells were found to have concentrations of
pentachlorophenol and 2-4-dichlorophenol which meet the specified cleanup
standards during the last two sampling events (at a minimum):
• C-0lB
• C-09B
• C-l0A
• C-12A
• C-I 3B
• C-14A
• C-15B
• C-27A
Previous Analytical Findings 2-1
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Proposed Remedial Action Groundwater Monitoring Program
• C-27B
• C-28A
Additionally, monitoring, well C-14B has reported 2,4-dichlorophenol
concentrations which meet the required cleanup standards for the last two
sampling events.
Analytical results for the dioxin/furan analyses are reported in Table 2-2. The
laboratory results for each PCDD/PCDF congener are multiplied by the Toxicity
Equivalent Factor (TEP) relative to 2,3,7,8-TCDD. The TEC values are summed
and compared to the cleanup standard of 30 pg/L for 2,3,7,8-TCDD. All samples
were less than this cleanup standard. See the One-Year Groundwater Remedial
Action Monitoring Report (Fluor Daniel GTI, June 1998) for a full discussion of
the sampling and analytical results for the January 1998 sampling event.
Previous Ana!Jtical Findings 2-2
Proposed Remedial Action Groundwater Monitoring Program
Analytical results for the dioxins and furan analyses are reported in Table 2-2.
The laboratory results for each PCDD/PCDF congener are multiplied y the
Toxicity Equivalent Factor (TEF) for each congener to obtain a toxicity equivalent
concentration (TEC) relative to 2,3,7,8-TCDD. The TEC values are summed and
compared to the required cleanup standard of 30 pg!L for 2,3,7,8-TCDD. All
samples were less than this cleanup standard. See the One-Year Groundwater
Remedial Acton Monitoring Report (Fluor Daniel GT!, June 1998) for a full
discussion of the sampling and analytical results.
Previous Ana!Jltical Findings · 2-3
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3 Groundwater Monitoring Program
The first year performance verification program demonstrated that concentrations
of PCDD/PCDF are below the groundwater cleanup standards specified in the
ROD in all wells. With the exception of wells C-l0B, C-1 lB, C-l 4B, C-29B, and
M-04 (where insufficient water was present to sample during the January 1998
sampling event), the groundwater cleanup standards for pentachlorophenol and
2,4-dichlorophenol have been achieved also. Therefore, the next step of the
groundwater monitoring program will focus on demonstrating that the cleanup
standards have been met in the remaining wells through a program of continued
sampling and analysis.
The overall operations and monitoring program is outlined in Figure 3-1. The
proposed groundwater monitoring program consists of quarterly groundwater
sampling and analysis for pentachlorophenol and 2,4-dichlorophenol in the
following wells:
• C-l0B
• C-1 lB
• C-l 4B
• C-29B
• M-04
fl.I -01. ·~
Quarterly sampling of these wells will continue until two consecutive sampling
events indicate that the concentrations of pentachlorophenol and 2,4-
dichlorophenol meet the specified cleanup levels. Concentrations of the
constituents of interest in wells C-1 OB, C-l 4B, . and M-04 during the next
sampling event at or below the specified cleanup goal would indicate that these
wells also have been demonstrated to meet the specified cleanup goals and
sampling for these wells would be discontinued. Wells M-1 lB and C-29B will be
sampled for a minimum of two additional sampling events since they had
detectable concentrations of pentachlorophenol during the January 1998 sampling
event.
As noted, quarterly groundwater monitoring will be conducted on those wells
listed above. As the cleanup goals are demonstrated in a well by the two
consecutive analytical findings at or below the specified cleanup .goals, that well
will be dropped from the monitoring program. If the findings for all wells meet
the specified cleanup goals, the e.xtraction system will be dis.continued and a semi-
annual boundary well monitoring system will be established to monitor long-term
Groundwater Monitoring Program 3-1
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Proposed Remedial Action Groundwater Monitoring Program
groundwater quality at the boundary of the site. This boundary monitoring
system will continue until the next five year review period.
Those wells found to have at least one site constituent above the cleanup goal will
continue to be sampled quarterly, until such a time as the concentrations reach
an asymptotic level. At that time, the extraction system would be temporarily
shut-down to evaluate potential modifications to the groundwater program
including: constituent rebound, changes in pumping rates or periods; · the
possibility of natural or enhanced biodegradation processes to attenuate or
degrade the remaining site constituents; and optimization of the extraction and
treatment system to increase removal efficiencies. A short-term monitoring
program of selected site and boundary wells would be enacted to ensure
compliance with groundwater quality requirements during this evaluation period.
The exact treatment system shut-down period and·evaluation scope of work would
be discussed with USEPA and NCDENR prior to implementation.
Using the findings from this evaluation, the groundwater program would then be
modified and either quarterly sampling of the remaining wells or boundary well
monitoring would be conducted, depending on the modifications that are selected
for the system. This modified program and monitoring would also continue to the
next five year review period and then be evaluated.
During the quarterly sampling events, water level elevations will be taken at all
wells at the site during each sampling event to continue to observe hydraulic
conditions. All sampling activities will be conducted according to the Field
Sampling and Analysis Plan developed in June 1993 as part of the Remedial
Design.
Groundwater Monitoring Program 3-2
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Table 2-1
Summary of Historical Groundwater Quality Data for Constituents of Interest
First Quarter 1990 through First Quarter 1998
Former Koppers Superfund Site
Morrisville, North Carolina
Well Sampling Event Pentachlorophenol 2,4-0ichlorophenol
(µg/L) (µg/L)
C-01B Jul-90 4U 35.8
C-01B Oci-90 7.77 J 9.24 J
C-01B Oci-93 10.0 U 10.0 U
C-01B Mar-96 1 U 0.2 U
"-01 R .l~n.QR 1 U 0?U
C-09B Jul-90 1 U 0.731 U
C-09B Oci-90 1 U 0.5 U
C-09B Nov-93 10.0 U 10.0 U
C-09B Mar-96 1 U 0.2 U
r..nac IM.QR 1 11 0? 11
C-10A Jun-90 3.82 0.5 U
C-10A Od-90 1 U 0.5 U
C-10A Nov-93 10.0 U 10.0 U
C-10A Mar-96 1 U 0.2 U
C-10A Jan.a" 1 U O?LJ
C-10B Oci-90 113 21.8
C-10B Jan-92 23.9 312
C-10B Nov-93 10.0 U 10.0 U
C-10B Mar-96 2J 0.2 U
C-10B Jul-97 11 1
C-10B Jan-98 1 U 0.2 U
C-11B Jul-90 9.8 0.5 U
C-11B Oct-90 12.6 0.5
C-11B Nov-93 10.0 U 10.0 U
C-11B Mar-96 29 0.2 U
C-11 B Dup. Mar-96 26 0.2 U
C-11B Jul-97 1 U 1
C-11B Jan-98 2 0.2 U
C-11 B Duo. Jan-98 1 0.2 U
0 • Reproduced from Fluor Daniel GT! (June 1998) ,.
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Table 2-1
Summary of Historical Groundwater Quality Data for Constituents of Interest
First Quarter 1990 through First Quarter 1998
Former Koppers Superfund Site
Morrisville, North Carolina
Well Sampling Event Pentachlorophenol 2,4-0ichlorophenol
(µg/L) (µg/L)
C-12A Jun-90 1 U 0.5 U
C-12A Oct-90 1 U 0.5 U
C-12A Oct-93 10.0 UJ 10.0 UJ
C-12A Mar-96 1 U 0.2 U
C-1 "" lon-98 1 U 0.2 U
C-13B Jun-90 1 U 0.5 U
C-13B Oct-90 1 U 0.5 U
C-13B Jan-92 1 U 0.2 U
C-13B Nov-93 10.0 U 10.0 U
C-13B Mar-96 1 U 0.2 U
C-13B Jan-98 1 lJ 0.? U
C-14A Jun-90 889 0.5 U
C-14A Oct-90 2010 0.5 U
C-14A Nov-93 1600 10.0 U
C-14A Mar-96 3500 0.2 J
C-14A Jul-97 0.08 U 0.2 U
C-14A lon-98 1 U 02U
C-14B Jun-90 499 0.5 U
C-14B Oct-90 124 0.5 U
C-14B Nov-93 10.0 U 10.0 U
C-14B Mar-96 19 0.2 U
C-14B Jul-97 14 0.2 U
C-14B Jan-98
r;-.1 U 0.2 U
C-15B Jul-90 1.60 0.5 U
C-15B Oct-90 1 U 0.5 U
C-15B Jan-92 0.5 U 0.5 U
C-15B Nov-93 10.0 U 10.0 U
C-15B Mar-96 1 U 0.2 U
C-15B Jan-98 1 U 0.? U
' Reproduced from Fluor Daniel GT! (June 1998)
11
i
Table 2-1
Summary of Historical Groundwater Quality Data for Constituents of Interest
First Qj arter 1990 through First Quarter 1998
Fornier Koppers Superfund Site
Morrisville, North Carolina
I
Well Sampling Event Pentachlorophenol 2,4-0ichlorophenol
I . (µg/l) (µg/L)
C-27A May-90 1 UJ 0.5 UJ
C-27A Oct-90 1 U 0.5 U
C-27A Jan-92 48.4 J 0.5 U
C-27A Nov-93 10.0 U 10.0 U
C-27A Mar-96 1 U 0.2 U
C-27A lon.98 1 U □.? u
C-278 Jun-90 4.23 0.5 U
C-278 Oct-90 4.18 U 0.5 U
C-278 Nov-93 10.0 U 10.0 U
C-278 Mar-96 2J 0.2 UJ
C-278 Jul-97 1 U 0.2 U
C-278 Dup. Jul-97 1 U 0.2 U
C-?7R .l~n-98 1 U 0.? u
C-28A May-90 1 U 0.5 U
C-28A Oct-90 26 0.5 U
C-28A Nov-93 10.0 U 10.0 U
C-28A Mar-96 1 U 0.2 U
c.?RA Ian.OR 1 U /l? u
C-298 Jul-90 591 0.5 U
C-298 Oct-90 968 0.5 U
C-29B Nov-93 17 10.0 U
C-29B Mar-96 1 U 0.3
C-?9B lan-98 17n n_? u -
M-04 Jul-90 99.2 0.5 U
M-04 Oct-90 69.1 0.5 U
M-04 Mar-96 10 0.2 U
M-04 Jul-97 0.08 U 0.2 U
M-04 J~n-98 "" NS
• Reproduced from Fluor Darnll GT! Oune 1998)
Table 2-1
Summary of Historical Groundwater Quality Data for Constituents of Interest
First 1Quarter 1990 through First Quarter 1998
Fonner Koppers Superfund Site
Morrisville, North Carolina
Well Sampling Event Pentachlorophenol
(µg/L)
PW-01 Oct-93 120
PW-01 Dup. Oct-93 159
PW-01 Mar-96 29
PW-01 Jul-97 91
PW-01 Jan-98 6
Notes:
1 NS indicates that the wel was not sam led. p
2 U indicates that the comP,ound was analyzed for by not detected.
3 J indicates an estimated v ue.
• Reproduced from Fluor Danr GT! (June 1998)
F,\PROJECTS\4-3624\GW._MOt-<\T ABI .. ---.
2,4-0ichlorophenol
(µg/L)
10.0 U
10.0 U
0.4
0.2 U
0.2 U
Table 2-2
Summary of PCDD/P •DF Analytical Results and Toxicity Equivalence Concentrations
January 1998
Former Koppers Superfund Site
Morrisville, North Carolina
SITE: C10B C-11B C11B Oup. PW01
DATE: 02/11198 02/11/98 02/11/98 02/11198
(pg/I.) (pg/I.I (pg/LI (pg/I.I
Compound TEI' Ruutt TEC -· TEC ResUtt TEC Result TEC
OIOXJN
2,3,7,8-TCDD 1 1.3 U ND 0.88 U ND 12 U ND 12U ND
12,3,7,8-PeCDD 0.5 1.4'U ND 0.5< U ND 0.47 U ND 0.S4U ND I 12,3,4,7,8-HxCDD 0.1 2.6 026 1.3 U NO 1.7 U ND 0.77U ND I 12,3,6, 7,8-HxCDD 0.1 7.6 0.76 12U ND 1.6 U ND 0.70U ND I 1,2,3, 7 ,8,9-HxCDO 0.1 4.1 0.-41 1.1 U ND 1.5 U ND 0.66 U ND I 12,3,4,6,7,8-HpCDD 0.01 190 1.9 8.9 0.0089 12 0.12 1.9 0.019 I OCDD 0.001 2500 2.5. 78 0.078 120 0.12 uu 0.014
Total TCOOa 1.<4U -0.88 U 12U -12U -
Total PECDDs 1.◄ U -0.5< U -0.47 U -0.5< U -
Total HxCODa 42 -1.3 U 1.7 U -o.nu -
T~al HpCOOa 330 -,. 19 -1.9 -
FURANS
2,3,7,8-TCDF 0. 0.60U ND 0.38 U NO 0.34 U ND 0.39U ND
1,2,3,7,8-PeCDF o.r 12 U ND 0.55 U ND 0.51 U ND 1.0U ND
2,3,4,7,8-PeCDF 0.5 1.1 U ND 0.◄7U ND 0.39 U ND 0.83U ND
1,2,3,4,7,8-HxCDF 0.1 1.6 U ND 0.79 U ND 0.62 U ND 0.27U ND
1,2,3,6, 7 ,8-HxCDF 0.1 1.4 U ND 0.89 U ND 0.69 U ND 0.30 U ND
2,3,4,6,7,8-HxCOF 0.1 1.6 U ND 26 2.6 0.67 U ND 0.29U ND
1,2,3,7,8,9-HxCOF 0.1 1.1 U ND 0.88 U ND 0.69 U ND 029U ND
1 ,2,3,4,6,7,8-HpCDF 0.0 57 0.57 3.5 0,035 4.5 0.045 0.53 U ND
1,2,3,4, 7 ,8,9-HpCDF 0.0 2.4 0.024 025 U ND 0.62 U ND a.sou ND
OCDF 0.0< 1 150· 0.15 9.0 0.009 14 0.014 2.0 0.002
Total TC□Fs 0.65 U -0.38U 0.34 U · -0.39U
Total PeCOFs 4.7 0.55 U -0.51 U -1.1 U -
Total HxCOFs 37 -26 1.1 -0.03U -
Total HpCDFs 150 -82 11 -0.53 U
' Reproduced from Fluor Daniel G ll Uune 1998)
. -------·---
1
Table 2-2
Summary of PCDD/PCDF Analytical Results and Toxici_ty Equivalence Concentrations
SITE:
CATE:
Compound TEF
To<al TEC (pg/I.)
Notes:
. January 1998
Fonner Koppers Superfund Site
Morrisville, North Carolina
C108 C-11B
'
02/11198 02/11198
(pg/I.) (pg/I.)
Re:sutt TEC Resuft TEC
••• 2.6
-Toxicity equivance factor (I TEF/89 EPA, March 1989)
C11B Cup.
02/11198
(pg/I.)
Resuft
1 TEF
2 TEC
3
-Toxicity equivalence·concentration (relative to 2,3,7,8-TCDD
indicates Not Calculated
4 ND indicates Not Detected
5 PCDD/PCDF groundwater data from resampling event on February 11, 1998
6 U indicates that the compound was analY2ed for by not detected.
• Reproduced from Fluor Daniel GT! Gune 1998)
F,\PROJECTS\4-3624\GW_MON\TAB2·2. WFD
PW01
02/11198
(pg/L)
TEC Resuft TEC
0.3 0.035
~ ~
a
D a
a D
"di [I
•
·Oo
C09A
360.30
0
D
0
c::=J
c:J
c::::J ~
()
Q
~
361.39
....___,,---c 50
, ,
~
C2
347.
CoME:iERY BA .
, ,,' 348.92 , , , , , ,/ , ., ,,,,a I / ' vJ• '/"' I ('y .I
r,..,'O l.?),o ~ 0 ~--~ ..., %J
Groundwater Elevation Contours Shallow
January 21, 1998
t
[£GENO
♦ /JON/TOR/NC ;i£!. LOCAT70N
{J-19. 19) CR()UNOWAici? =L:'Ml/ON (f""i MSL)
3&4ER EAST. INC.
PROPERTY 80UN!J4RY
------UNIT Si'RUCTURES INC.
PROP:ii'TY 30UN!J4RY
------INF£i?.f£0 GROUNOWATci?
CONTOUR
CONTOUR INTERVAL = 2.0 FC::7
•F:eproduced from Fluor Daniel GT!, June 1998
Figure
2-1
...
□
•
□
00
C098 ,i,. 352.18 V
Cl
c·,5c
011c11 LJ 351.
J C29
-
c=i
CJ
c::=i ,:::;,
D
()
, , ---:;62 ,.. "' , 'n, -3o0
c-:,::i.
J•i.7.57
,e-1-~S
•O . 0 , . .
tJ'I \ '--.. ~ --.> \ ... --.. .,,."' ,' C25o
.35 i.01
Groundwater Elevation Contours Intermediate/Deep-~t:;_As~~: .. ,7 .•.
October 21. I 997
!.IONITORING W£li LOCATION
(34'9.!9} GRO/JNOWAIFR ELEVATION
(FEET /JSL)
--
• !NO/CA TES THAT GRO/JNOWA TER
EUVATION WAS NOT /1S£7) TD OEVEl.OP GRO/JNOWATER CONTO/JRS
---8£4Z£i? DST, INC.
PROPD?TY 80/JNOARY
-------/JNIT S;i?/JCT1/RE:S INC.
PROP£RTY 80/JNOARY
-----!NFEIRE:D GRO/JNOWA TER
CONTD/JR
CONTOUR INTERVAL = 2.0 FEt:.1
• ,..
· •Reproduced from Fluor Daniel GTI, June 1998
Figure
2-2
0
C
0 0
,G [J C
C ='.J -00 u
, __ .
'
0
i ; . ! -
I
I
c:::
··" , .. :.:-/ t-,.,"¥=:;;-• -:_,.. -·~·.,,-·:t :;;Usl~~·:<Yt~i'(~~-:.T_,,;..: ·~ , .:..__ On Site and near Off Site Monitoring Well.z~St1tioris:
. ·.,' ":/\:_?:t:?:··~. .
<? .
L£GEND
1,-. /,ION/TOR/NG WELL !OCA;;ON
BO.ZE7? £4ST, /NC.
PROPERTY BOUNDARY
---------iwrr STRUCTURES /NC.
PROPE.'ITY BOUNDARY
SCALE (FE:. 1)
0 200 A.00 600
•
1/
*jleproduced from Fluor Daniel GT!, June 1998
Figure
2-3
la :~ =a ~
Treatment Operations and
Quarterly Monitoring One or more constituents
above specified cleanup
goals in any well
Continue quarterly
sampling for wells with
concentrations above
Two consecutive results cleanup goals
at or below specified
cleanup goals in all wells Concentration asymptote
' demonstrated
Shut down extraction
system to evaluate
groundwater program:
-Constituent rebound,
-GW modeling of modified
extraction i-ates, periods,
Discontinue Extraction configuration
System -Natural and enhanced
biodegradation studies
-System optimization
-Establish short-term
GW monitoring program
Specific Scope of Work to be determined
Conduct long-term Modify groundwater
.. boundary well monitoring pror,ram If necessary
Conduct Five Year
Review
-Figure
Monitoring and Operations Evaluation Process 3-1
STATE OF NORTH CAROLINA
DEPARTMENTOFENVIRONMEN~
HEALTH, AND NATURAL RESOURCES
RALEIGH REGIONAL OFFICE
3800 Barrett Drive, Suite 101
Raleigh, North Carolina 27609
[phone]
FILE ACCESS RECORD
SECTION
TIME/DATE
NAME
REPRESENTING
GROUNDWATER
A ril 28, 1997
Ben Powell
TRIGON ENGINEERING
[phone]
GUIDELINES FOR ACCESS: The staff of the Raleigh Regional Office is dedicated to making public
records in our custody readily available to the public for review and copying. We also have the responsibility to
the public to safeguard these records and to carry out our day-to-day program obligations. Please read carefully
the following guidelines before signing this form.
(l) We prefer that you call at least a day in advance to schedule an appointment to review the
files. Aimointments will be scheduled between 9:00 a.m. and 3:00 p.m. Viewing time ends
at 5:00 p.m. Anyone arriving without an appointment may view the files to the extent
that time and staff supervision is available.
(2)
(3)
(4)
You must specify files you want to review by facility name. The number of files that you
may review at one time will be limited to five.
You may make copies of a file when the copier is not in use by the staff and if time permits.
Cost per copy is 10 cents: payment may be made by check. money order. or cash at the
reception desk.
FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may not be
taken from the office. To remove, alter, deface, mutilate, or destroy material in one of these
files is a misdemeanor for which you can be fined up to $500.00.
♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦♦
FACILITY NAME COUNTY
1. Koppers Co., Inc. Wake
Incident #6754
b,_d,~ /-r,;j,,, E~ il~/q1 2,:10 J;..oo
Signature & Name of Firm/Business Date Time In Time Out
(Please attach a business card)
I
I
'1~ TRIGON
fNGiNffRING CONSULTANTS, INC.
Ben L. Powell
Air Quality Analyst
Mum-Media Technician
{919) 755-5011
Fa.x [phone]
700 Blue Ridge Road, Suite 101 Raleigh, NC 27606 -
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
October 25, 1994
MEMORANDUM
TO: David Lown
Superfund Section ~
FROM: ~ Preston Howard~-
SUBJECT: Koppers Company
Intermediate Remedial Design
Wake County
Project No. 94-47
.MA
a'S '11-llGl'.J 41 &@ i ·O
DEHNR
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
I.f Yes, soc No. -------
To: Permits and Enginefl&,E 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)
Longitude:78°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 11 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 proviae 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
in development ---
should be required ___ _
only) :
approved ----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~·
If Yes, SOC No. _______ _
SIC Code(s): 2439
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 fire pond to be
remediated first, followed by the M~dlin 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: Yes No . / ---,::,-If Yes, SOC No. _______ _
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.
//
Water Quality Regional Supervisor
H:\NC84366.SR
_,-7 ..i. · 1· I i.:... _/I.,\.~ I'-" /' l t.. ( a. _,,-c_
SECTION
TIME/DATE
NAME
REPRESENTING
STATE OF NORTH CAROLINA
DEPARTMENTOFENVIRONMEN~
HEALTH, AND NATURAL RESOURCES
. RALEIGH REGIONAL OFFICE
3800 Barrett Drive, Suite 101
Raleigh, Norrh Carolin.a 27609
[phone]
FILE ACCESS RECORD
GUIDELINES FOR ACCESS: nie statt of the Raleigh Regional Office is dedicated to making
public records •in our custody readily available to the public !pr review and copying. We also have the
responsibility to the public to safeguard these records and to carry out our day-to-day program
obligations. Please read carefully the following guidelines before signing this form.
(·1) We prefer that you call at least a day in advance to schedule an appointment to review the
fiies. Apoointmenls will be scheduled between 9:00 a.m. and 3:00 p.m. Viewing time ends
at 5:00 p.m. Anyone srrivino without an ap·oointment mav view the files to the e:rtent that
time and statf supervision is available.
(2) You must specify files you want to review by facility name. The number of files that you may
review at one time will be limited to five.
(3) You may make copies of a fiie when the copier is not in use by the statt and ff time permits.
Cost per copy is 10 cents: payment mav be made by check. money order. or cash at the
reception desk.
,(4) FlLES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may not be taken from the
ottice. To remove, alter, deface, mutilate, or destroy material in one of these files is a
misdemeanor for which you can be fined up to $500.00. ·
1.
'2.
3.
4.
'5.
FACILITY NAME
zfb f'MS
Signature & Nam o Firm/Business
(Please attach a business card)
COUNTY
;;-/4/21,, 9-"fo
Date Time In Time Out
·•.:\~:::<:};:::::.: .... •:::
\(:'i:,f.};.:JL
. :
SECTION
TIME/DATE
NAME
R EPA ESENTING
STATE OF NORTH CAROLINA
DEPARTMENTOFENVIRONMEN~
HEALTH, AND NATURAL RESOURCES
RALEIGH REGIONAL OFFICE
3800 Barrett Drive, Suite IOI
Raleigh, Norrh Carolina 27609
[phone]
FILE ACCESS RECORD
GUIDELINES FOR ACCESS: The staff of the Raleigh Regional Office is dedicated to making
public records ·in our custody readily available to the public for review and copying. We also have the
responsibility to the public to safeguard these records and to carry out our day-to-day program ·
obligations. Please read carefully the following guidelines before signing this form.
(1) We prefer that you call at least a day in advance to schedule an appointment to review the
fiies. Appointments will be scheduled between 9:00 a.m. and 3:00 p.m. Viewing time ends
at 5:00 p.m. Anyone arriving without an appointment may view the files to the extent that
time and staff supervision is available.
(2) You must specify files you want to review by facility name. The number of files that you may
review at one time will be limrted to five.
(3) You may make copies of a file when the copier is not in use by the staff and if time permrts.
Cost per copy is 10 cents: payment may be made by check. money order, or cash at the
reception desk.
(4) FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may not be taken from the
office. To remove, alter, deface, mutilate, or destroy material in one of these files is a
misdemeanor for which you can be fined up to $500.00.
1.
2.
3.
4.
5.
FACILITY NAME
Signature & Name ol Firm/Business
(Please attach a business card)
COUNTY
1/1,1/ft: 11:rr~ ~ Timeln
/;l,/J]J
~
Carol M. Schiller ;<i.
Attorney at Law
UCB Plaza
3605 Glenwood Avenue, Suite 220
Raleigh, North Carolina 27612
TEL [phone]
FAX [phone]
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
RALEIGH REGIONAL OFFICE
3800 Barrett Drive, Suite 101
Raleigh, North Carolina 27609
[phone]
FILE ACCESS RECORD
SECTION L)E /4-? -6--<%/
TIME/DATE __ .L<?....,/1~-fl"'"--'-. ,---------:c-:---r----------
NAME ,I( M It te.-V !. · e R ,1-i.Jy,{
REPRESENTING ,I( ,'v ,:,IL_ 8e of.?eff ,:;;s-,..:zjvc r
GUIDELINES FOR ACCESS: The staff of the Raleigh Regional Office is dedicated to making
public records in our custody readily available to the public for review and copying. We also have the
responsibility to the public to safeguard these records and to carry out our day-to-day program
obligations. Please read carefully the following guidelines before signing this form.
(1) We prefer that you call at least a day in advance to schedule an appointment to review the
files. Appointments will be scheduled between 9:00 a.m. and 3:00 p.m. Viewing time ends
at 5:00 p.m. Anyone arriving without an appointment may view the files to the extent that
time and staff supervision is available.
(2) You must specify files you want to review by facility name. The number of files that you may
review at one time will be limtted to five. ·
(3) You may make copies of a file when the copier is not in use by the staff and if time permits.
Cost per copy Is 10 cents: payment may be made by check, money order, or cash at the
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MARY ERAZ!M, CRP . ·-;
Vice Presidt::nt/COTporatC LlsLini Oirfccm' ·
Resickrtcid Division , ' · ' · ·
' "i .
919/821'7177 Offic; •:.
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MEMO
TD, __ C_o..._ro_l ----'_5'"'---'h---'-'---,' I'-"-'/ f !..-=---
1 & 7 • -, t.,~( '--1
DATE, ____ _
SUBJECT, ____ _
From: _______ _
North Carolina Department of Environment, .
Health, and Natural Resources @ P,lotodooRecycl,dPapo,
RECEIVED
NOV 6 1992
State or North Carolina DEHNR-RAL RO
Department or Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street• Raleig~, North Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., Secretary October 27, 1992 A. Preston Howard, Jr., P.E.
Acting Director
Regional Offices
Asheville
704/251-6208
Fayetteville
9]9/486-1541
~v1oorcsvillc
704/663-1699
R:tleigh
919/571-4700
Washington
919/946-6481
\Vilmington
919/395-3900
\Vinston-Salcm
9 l 9/896-7007
MEMORANDUM
TO: Bruce Nicholson, Chemical Engineer
Superfund Section
FROM:
I , .~ ~.t\.
,~ Preston Howard ~ (~
RE: Koppers Co., Inc. -NPL Site
Morrisville, NC -Wake County
Review of Draft Record of Decision
Proj. #92-46
As requested, the Division of Environmental
Management has reviewed the subject document. The
comments from our Water Quality, Air Quality and
Groundwater Section are provided below:
WATER QUALITY SECTION
The majority of the contamination
groundwater and contaminated soils.
additional comments to offer.
AIR QUALITY SECTION
is relevant
We have
to
no
The remediation project at the Koppers Company site
in Morrisville will either need to be permitted or
registered with the Air Quality Section. Some of the
questions of concern that determine whether permitting
is required are:
Will the soil be agitated in the incineration
process?
If not, what is the method used?
What are the Air Quality control devices used
in the processes?
Where is the "offsite" location?
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
. --·'
Once these questions are answered,
Section can either determine whether
permit or registration.with the section
GROUNDWATER SECTION
the Air Quality
an Air Quality
is required.
Groundwater Section has no additional comments
other than those stated previously.
Thank you for the opportunity to review the subject
document. Should you have questions or wish additional
discussion on this matter, please contact, Mr. Arthur
Mouberry at [phone].
cc: Perry Nelson
Steve Tedder
Alan Klimek
Arthur Mouberry
Nargis Toma
NT/pkh:Koppers.NPL
RALEIGH REGIONAL .OFFICE
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MEMO
DATE: ____ _
·TO, ______ _ SUBJECT, ____ _
From: _______ _
,,,. STATf ,,...,
· f~~~) North Carolina Department of Environment,
\~~-~Yf})!I Health, and Natural Resources @ '''""""""°"'"""'"
!t Q</A ... "°' ... ,. -.... _. ..
STATE OF NORTH CAROLINA
Department of Environment and Natural Resources
Raleigh Regional Office
3800 Barrett Drive, Suite 101, Raleigh, NC 27609
. 919/571-4700
File Access Record
SECTION
TIME/DATE
NAME
REPRESENTING
UST
Friday, January 8, 1999
Mike Malone
Pulley, Watson, King & Liner [phone]
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FACILITY NAME
Koppers Co., Inc. -ID #6754
COUNTY
Wake
Signature and Name of Firm/Business
Please attach a business card to this form Date Time In Time Out
~
To: ~I O>-j 7 /07/Jt~r 11-i_f~
From : -f-/,-f-/.:....;:ri1'-+1.,.:-/-f+f)----'-'-'-"--=~;;.__-~-'-,c-
1 l f / ' □ FOR YOUR INFORMATION
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□ PLEASE PREPARE RESPONSE FOR
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□ PLEASE REVIEW
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□ DISCUSS WITH ME
,,;l2sr FILE ,_, □'---OTHER
_____ DUE DATE
COMMENTS
RECEIVED
. JAN O 1 1992
State of North Carolina
Department of Environment, Health and Natural Resources Division of Environmental Management
512 Nonh Salisbury Street• Raleigh, Nonh Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., SccrcL1l)'
October 27, 1992 A. Preston Howard, Jr., P.E.
Acting Dim:tor
Regional Offices
Asheville
704/251-6208
Fayetteville
9 I 9/486-! 541
Mooresville
704/663-I 699
Raleigh
919/571-4700
Washington
919/9.j6-648 I ·
\Vil ming.ton·
919/395-3900
\Vins:on-Salcm
919/896-7007
MEMORANDUM
TO: Bruce Nicholson, Chemical Engineer Superfund Section
FROM: -r Presto.n Howard ~ /.~
RE: Koppers Co., Inc. -NPL Site Morrisville, NC -Wake County Review of Draft Record of Decision Proj. #92-46
As requested, the Division of Environmental Management has reviewed the subject document. The comments from our Water Quality, Air Quality and Groundwater Section are provided below:
WATER QUALITY SECTION
The majority of the contamination groundwater and contaminated soils., additional comments to offer.
AIR QUALITY SECTION
is relevant
We have
to
no
The remediation project at the Koppers Company site in Morrisville will either need to be permitted or registered with the Air Quality Section. Some of the questions of concern that determine whether permitting is required are:
Will the soil be agitated in the incineration process?
If not, what is the method used?
What are the Air Quality control devices used in the processes? ·
Where is the "offsite" location?
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone][5
An Equal Opportunity Affirmative Action Emnlnver
Once these questions are answered,
Section can either determine whether
permit or registration with the section
GROUNDWATER SECTION
the Air Quality
an Air Quality
is required.
Groundwater Section has no additional comments
other than those stated previously.
Thank you for the opportunity to review the subject
d9cument. Should you have questions or wish additional
discussion on this matter, please contact, Mr. Arthur
Mouberry at [phone].
cc: Perry Nelson
Steve Tedder
Alan Klimek
Arthur Mouberry
Nargis Toma
NT/pkh:Koppers.NPL
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Koppers Company Site
Morrisville, North Carolina
STATEMENT OF BASIS AND PURPOSE
f{E.CEi\!ED
SEP 4. \992
. DEHNf'<-f:AL RO
This decision document presents the selected remedial action for
the Koppers Company Superfund Site in Morrisville, North Carolina
chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the
extent practicable, the National Contingency Plan. This decision
is based on the administrative record file for this site.
The State of North Carolina has given tentative concurrence on the
selected remedy. Final concurrence is expected prior to signature.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
endangerment to public. health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy addresses the current and future unacceptable
risks posed by the Site to human health and the environment.
Alternative S-9 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.
0
0
0
Excavate contaminated soils from the lagoon and process
areas onsite to meet cleanup standards.
Transport soils to an offsite permitted incineration
facility.
Backfill excavation areas with clean fill.
Alternative GW-4 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 alternative:
0
0
0
Contaminated groundwater will be extracted from within
the plume via extraction well(s) and piped to an onsite,
above-ground treatment unit.
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 Pollution Discharge Elimination System. If no
viable surface water discharge point exists on the site,
the discharge may be offsite, thereby requiring a permit
under the National Pollution Elimination System.
Alternative SW-3 for surface water will remove all 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:
0
0
0
0
0
0
The onsite Fire Pond and the offsite Medlin Pond will be
dewatered.
The ponds will be backfilled with clean fill.
The surface water will be treated by carbon adsorption.
Final discharge of the effluent will be to the surface
water, stipulated by the substantive requirements of the
National Pollution Discharge Elimination System. If no
viable surface water discharge point exists on the site,
the discharge may be offsite, thereby requiring a permit
under the National Pollution Elimination System.
Final regrading and drainage control of the pond areas
will be conducted.
A small area of wetlands will be destroyed under this
portion of the remedy. Therefore some wetlands
mitigation will be required under this remedy. Final
location and requirements of this mitigation will be
decided during Remedial Design.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
·solutions and alterative treatment and resource recovery
technologies, to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Since this remedy may result in hazardous substances remaining on-
site above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
Greer C. Tidwell
Regional Administrator
Date
THE DECISION SUMMARY
FOR THE RECORD OF DECISION
KOPPERS COMPANY SITE
MORRISVILLE, WAKE COUNTY NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
ATLANTA, GEORGIA
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
KOPPERS COMPANY SITE
MORRISVILLE, WAKE COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
TABLE OF CONTENTS
SECTION PAGE No.
1.0 SITE NAME, LOCATION, AND DESCRIPTION .•••••••.•••••.••••• l
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES ..•••••..•••.••.• 1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION ••..•....••••..••.. 5
4.0 SCOPE AND ROLE OF THE RESPONSE ACTION WITHIN SITE
STRATEGY ••••••••••••••••••••••••••••••••••••••.••••••••• 7
5.0 SUMMARY OF SITE CHARACTERISTICS .•••••.•••.•••.•..••...•. 7
6. 0 SUMMARY OF SITE RISKS ...••••.•••••.••••.•••..•••.••••.. 2 0 6.1 Contaminants of Concern ..................................................... 20 6.2 Exposure Assessment ..•...••••••..••••.••••••••••• ,23 6. 3 Toxicity Assessment ............................... 26 6.4 Risk Characterization .......................................................... 31 6. 5 Risk Uncertainty .................................. 33 6. 6 Ecological Risk ................................... 33 6.6.1 Fire Pond .................................................................... 33 6. 6. 2 Medlin Pond ................................ 33 6.6.3 Summary of Ecological Risk •••.•••.•••••.... 34
7.0 DESCRIPTION OF ALTERNATIVES .•••..•••.•••..•••..•••..••• 34 7.1 Remedial Alternatives to Address Soil
Contamination ..................................... 34 7. 1. 1
7. 1.2
7. 1.3
7. 1.4
Alternative S-1:
Alternative S-3:
Alternative S-4:
Alternative S-5:
No Action ................ 3 6
Surface Cover ....• : ..•••• 36
Surface Capping ••••.••••• 36
Excavation and On-site
Landfill ................................... 37 7.1.5 Alternative S-6: Excavation and Off-site
Landfill .................. · ................. 37 7.1.6 Alternative S-7: Excavation and On-site
Treatment by Dechlorination Process and
Replacement of Treated Soils •••..••••..•... 38 7.1.7 Alternative S-8: Excavation and On-site
Incineration ............................... 38 7,1.8 Alternative S-9: Excavation and Off-site
Incineration ............................... 39 7.1.9 Alternative S-10: Excavation and On-site
Storage .................................... 3 9 7.2 Remedial Alternatives to Address Groundwater
Contamination ..................................... 4 0 7.2.1 Alternative GW-1: No Action ••••.•••.••••.. 42 7.2.2 Alternative GW-3: Extraction, Above-ground
Bioremediation, Surface Water Discharge •••• 43 7.2.3 Alternative GW-4: Extraction, Above-ground
Pretreatment and Carbon Adsorption, Surface
Water Discharge ............................ 43
TABLE OF CONTENTS (cont. )
SECTION PAGE No.
8.0
9.0
7.3
7.2.4 Alternative GW-5: Extraction, Above-ground
Pretreatment and UV/Chemical Treatment,
Surface Water Discharge .•••.••.•.••••....• 44
Remedial Alternatives to Address Surface Water
Contamination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5
7.3.l Alternative SW-1: No Action ••.....••...• 45
7.3.2 Alternative SW-3: Pond Dewatering, Surface
Water Treatment, Surface Water Discharge,
Backfilling in Pond ... ~ .................... 45
7.3.3 Alternative SW-4: Pond Dewatering, Surface
Water Treatment, Pond Lining and Refilling.47
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. .48
.48 8. l
8.2
8.3
Threshold Criteria .................... .
8.1.l Protection of Public Health and
Environment ................................. 4 8
8. 1.2 Compliance with Applicable or Relevant and
Appropriate Requirements. ••••• . ••• 51
8.1.2.1 Soils.......... . .. 70
8 • l. 2 • 2 Groundwater. . • . • • 7 0
8.1.2.3 Surface Water.. .70
8.1.2.4 Summary. •• .71
Evaluating Criteria..... .71
8.2.1 Cost............. .71
8.2.2 .73 Implementability.
8.2.2.l Soils •.•
8.2.3
8.2.4
8.2.5
8.2.2.2 Groundwater ••
8.2.2.3 Surface Water.
Short-Term Effectiveness ••••.•
8.2.3.l Soils ........ .
8.2.3.2 Groundwater ••••
8.2.3.3 Surface Water ••
Long-Term Effectiveness.
8.2.4.1 Soils ........ .
8.2.4.2 Groundwater ••••
8.2.4.3 Surface Water ..••...
Reduction of Mobility, Toxicity,
Volume .••.•••••••••••
8.2.5.l
8.2.5.2
Soils ............ .
Groundwater •••
8.2.5.3 Surface Water. ......
Modifying Criteria •••••••••••.
8.3.l State Acceptance ••••••••••
8.3.2 Cominunity Acceptance.
and
..
.73
.73
.73
.73
.• 73
.73
.73
.74
.74
.74
.74
.74
.74
.75
.75
.75
.75
.76
SELECTED REMEDY ••••••••••••••..••
9.1 Source Control .•••.••••...•.
9.1.l Excavation Standards.
9.2 Groundwater Remediation ••..•
9.2.l Performance Standards.
•••
...
.76
.76
.77
.78
• •• 7 8
TABLE OF CONTENTS (cont. )
SECTION PAGE No.
9.2.1.1 Extraction Standards ••••••••.••••. 78
9.2.1.2 Treatment Standards •••••••••••••.. 78
9.2.1.3 Discharge Standards ••.•••.•.•••.•. 79
9.2.1.4 Design Standards .................. 79
9.3 Surface Water Remediation •......••..•••••.......•• 79
9.3.1 Discharge Standards ........................ 80
9.4 Compliance Monitoring ............................. 80
10.0 STATUTORY DETERMINATION ................................ 80
10.1 Protection of Human Health and the Environment .••• 80
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements ......•.•••.•..•••...•.... 81
10.3 Preference for Treatment .......................... 81
10.4 Cost Effectiveness ................................ 81
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES ....•••••••••.••.•• 81
LIST OF FIGURES
FIGURE PAGE No.
1. 1 Site Features Map ....... · .................................. 2
2. 1 Location of Lagoon Area .................................. 4
5. 1 Soil Sample Locations .................................... 9
5.2 Major Contaminant Concentrations: Process and Lagoon
Areas .................................................... 15
5.3 Onsite and Near Off-site Monitoring Well Locations •.••... 16
5.4 Offsite Monitoring Well Locations ..............•••••••••• 17
5.5 Private Well Sampling Locations .......................... 18
5.6 Pentachlorophenol Groundwater Plume (>MCL) ..••..•••••••.• 19
5.7 Dioxin Detections in Groundwater ......................... 20
5.8 Surface Water Sampling Locations ......................... 22
5. 9 Sediment Sample Locations •••••...•...........••.....•.••• 2 3
7.1 Pentachlorophenol Groundwater Plume (>MCL) ......••••••••• 41
7 • 2 PCDD / PCDF Detections .•.•.•••..••••••••••••••••••••••••••• 4 2
7. 3 Pond Locations ........................................... 4 9
TABLE
5. 1
5.2a
5.2b
5.2c
5.2d
5.3
5.4
5.5
5.6
6.1
6.2
6.3
6.4
8.1
8.2
8.3
8.4
8.5
8.6
8.7
9.1
9.2
LIST OF TABLES
PAGE No.
Contaminant Concentration Ranges in Soils ••••••••••••. 10
Contaminant Concentration Ranges in Groundwater:
Eastern Area .......................................... 11
Contaminant Concentration Ranges in Groundwater:
Western Area .......................................... 12
Contaminant Concentration Ranges in Groundwater:
Offsite ............................................... 13
Contaminant Concentration Ranges in Groundwater:
Lagoon and P roe es s Area ............................... 14
Contaminant Concentration Ranges in Surface Water:
Fire Pond ............................................. 24
Contaminant Concentration Ranges in Surface Water:
Medlin Pond ........................................... 2 5
Contaminant Concentration Ranges in Sediment: Fire
Pond .................................................................. 26
Contaminant Concentration Ranges in Sediment: Medlin
Pond ................................................................................................... 27
Cancer Slope Factors .................................. 31
Reference Doses ••.•.•••••.•.....••••••.••••••••••••••• 31
Current Quantitative Risk ............................. 33
Future Quantitative Risk .............................. 33
Potential Action-Specific ARARs •.......••.•••••••..••• 53
Potential Location-Specific ARARs ..................... 61
Potential Chemical-Specific ARARs ..•....••.•••••.•••.. 62
Potential Action-Specific ARARs (North Carolina) •.•••• 64
Potential Location-Specific ARARs (North Carolina) ••.• 70
Potential Chemical-Specific ARARs (North Carolina) •..• 71
Estimated Costs of Alternatives ....................... 74
Groundwater Cleanup Goals: Major Contaminants ••••••••• 80
Groundwater Cleanup Goals: Minor Contaminants ••••.•.•• 80
Record of Decision
Summary of Alternative Selection
Koppers Company site
Morrisville, North Carolina
1.0 Site Name, Location and Description
The Koppers Company Site is
which is in Wake County.
intersection of Highway 54
located in Morrisville,
The 52 acre site is
and Koppers Road.
North Carolina
located at the
The property of the site is owned by two companies: Beazer East,
Inc. and Unit Structures. Beazer East bought the Koppers Company
in 1962. The Koppers Company had conducted wood treatment
operations at the site. Unit Structures, Inc. purchased the site
property in 1986 and currently operates a wood laminating facility
on approximately 80% of the original site property. The portion of
the site currently owned by Beazer is considered inactive.
Figure 1.1 is a facility map which indicates the site features;
The process area and the lagoon area are both located near the
onsite Fire Pond in the southeastern section of the site. The
landfarrn area is the northernmost section of the site proper. The
surface drainage ditches on the eastern and western boundaries of
the site are shown. The western ditch flows downstream in a
southerly direction and merges with the outflow ditch of the Medlin
Pond. The onsite Fire Pond outflow ditch flows into the Medlin
Pond. The confluence of these surface water features flows
downstream and drains into Crabtree Creek and subsequently into
Crabtree Lake.
2.0 Site History and Enforcement Activities
History of the property ownership dates back to 1896. Cary Lumber
Company occupied the site and sold the property to a company known
as Unit Structures, Inc., in 1961. That the original Unit
Structures company is not the same company as the Unit Structures
company at the site today. Only the name is the same. The
following year, in 1962, Unit Structures sold the property to
Koppers Company, Inc.
At that time, the Koppers Company began treating wood using a
process known as CELLON. CELLON treatment consisted of injection
of pentachlorophenol into the wood. Pentachlorophenol is a main
contaminant at the site. Acronyms for pentachlorophenol are PCP
and penta. These acronyms are used interchangeably throughout the
Administrative Record.
After treatment, residual pentachlorophenol was removed by a steam
process. The rinsate was processed by a coagulate to remove excess
pentachlorophenol which was then filtered off. The final rinsate,
Kopper• Draft ROD
Auguet 1992
Page 1
--+
ED=· 0,. c~~ ','~-
0" ~::::--IL.EEBENll INC.
ll ~ -~-£AZER EAST. \I ----~ ,...,.,,,nrHrr Olt'NEO BY 8 '\.-_:::::::_-::::.---/.// mvr-<:.,
-1 ---///, IT STRUCTURES.
~--'NW BY UN ·cc:_:''::;:-□ PROPERTY O~
Figure I.I
:--~=~~~2:;;00~~300 ~ O 100 100
SCALE (FEEl)
INC.
STRUCTURES
UNITPERTY LINE PAO
Figure I.I
Features Map Site
I I
presumed to be predominantly water, was pumped into two
lagoons. It is believed that these lagoons were not lined.
2.1 presents the locations of the lagoons.
onsite
Figure
The CELLON process was used at the site from 1962 until 1975,
approximately 13 years. Beazer has stated that after the CELLON
process was discontinued, the facility began receiving pretreated
wood to continue operations.
In 1976, the Koppers Company 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
contents of the lagoons were pumped out and landfarmed, or sprayed,
in the northernmost portion of the site. This area is identified
in the record as the landfarm area. This area was plowed and two
applications of the liquid from the lagoons were sprayed onto the
ground. Fertilizer was spread over the area and the area wa·s.
plowed again. Landfarming was an accepted technology at the time.
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.
Beginning in 1980, the Koppers Company conducted more studies on
the site. Investigations of groundwater and soils were conducted.
Beazer' s records · indicate 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 site 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. North
Carolina Division of Health Services, Superfund Branch also began
investigating 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
monitoring private wells in the vicinity. This sampling, which has
been conducted on a quarterly basis since February 1989, continues
to be a part of the program at the site. This effort remains a
cooperative effort between Beazer and the State. Based on the
lopper• Draft ROD
Auguot 1n2
Pago 3
c::=J
C=:J
c:::::J
Figure 2.1
IICJJ..E IFE£Tl
100 0 100 200 300
Cl
, Figure 2 • I
Location of Lagoon,
Area
results of the private well sampling, Beazer provided bottled water
to all residents whose wells showed any detectable amounts of
isopropyl ether or pentachlorophenol. This action was elected
during the· re-evaluation of the carcinogenicity of
pentachlorophenol.
In 1989, EPA and Beazer entered into an agreement for Beazer to
install a public _water line to the affected area. 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.
Very few of the private wells had concentrations of
pentachlorophenol which exceeded the current maximum contaminant
level (MCL) of 1 ppb identified by the Safe Drinking Water Act. No
MCL exists for isopropyl ether.
In 1986, the North Carolina Superfund Branch of the North Carolina
Department of Environment, Health and Natural Resources, conducted
a site inspection at the site which was utilized in the development
of the Hazard Ranking System package. The site was proposed to the
National Priority List (NPL) on June 24, 1988 principally due to
the groundwater contamination. Final rule and inclusion on the NPL
occurred on March 31, 1989.
In March of 1989, the Environmental Protection Agency signed an
Administrative Order on Consent which allowed Beazer to conduct the
work at the site. In November of 1989, the Work Plan for this work
was approved. During 1990, extensive field work was conducted 0n
soils, groundwater, drainage pathways and the ponds. In June of
1991, it was determined by the Agency, that additional work needed
to be done, specifically on surface soils in the lagoon and CELLON
process areas. Additional groundwater sampling has also been
conducted.
All field work under the scope of the Remedial Investigation has
been completed. Additional field work will be required by this
Record of Decision.
3.0 HIGHLIGHTS OP COMMUNITY PARTICIPATION
The EPA has encouraged public participation since NPL inclusion.
The community has an active coalition, the Shiloh Coalition for
Community Control and Improvement, that has been established since
before the site was finalized on the NPL. More recently a subgroup
has been formed out of the coalition which identifies itself as the
Clean Water and Environment Project. Other citizens and groups
have participated, but the Coalition respresents the most vocal and
active sector in the community.
The community has been quite organized in their participation of
site activites and have held their own public meetings of which EPA
Koppera oratt ROD
Allquat 1992
Pa<je 5
was sometimes invited to attend. A total of four public meetings
have been held by the Agency. Periodic fact sheets have been
distributed to update the community during the Remedial
Invetigation and Feasibility Study.
EPA has solicited comments, both formally and informally, from the
community since the work plan stage. Documents were placed in the
Wake County library for review. Input received from the public has
influenced EPA's level of oversight of the investigation as well as
the substance of the project. EPA increased its oversight presence
during field activities in response to community concerns. Site
areas were further investigated as a result of specific input from
the community.
The community has had concerns with the Potentially Responsible
Party performing the work and has suggested frequently that EPA
should be doing the investigative work instead of the PRP. This
concern was heightened while the Potentially Responsible Party
developed of the Baseline Risk Assessment.
A major concern of the community has been with the contamination
impact on groundwater in an area where most people have
traditionally used wells for domestic water supply. An alternative
water supply was provided to all residents whose wells showed any
detectable amounts of pentachlorophenol or isopropyl ether.
Bottled water was originally provided; permanent water lines were
installed later. The City of Morrisville required that annexation
petitions be submitted prior to hookup. The resulting increase in
taxation has been. a primary source of anger and frustration for
many of the residents. EPA's Regional Administrator sent a letter
by personal courier to a Town Council meeting to waive or
reconsider this requirement. The annexation requirement was
maintained.
The local community was awarded a Technical Assistance Grant in the
fall of 1991. The EPA approved the utilization of the small
purchase procurement method to allow the hiring of a technical
advisor quickly.
A public meeting was held on April 8, 1992 to discuss the findings
of the Remedial Investigation. Potential remedial technologies
were discussed. The public comment period for the selected remedy
was (is being) held from July 17, 1992 to September 16, 1992. An
extension was requested and is incorporated into this public
comment period. Public notice was provided in the Raleigh News and
Observer and on ads on two cablevision advertisement stations. The
formal public meeting announcing the proposed plan was held on July
2 3, 19 9 2 in accordance with CERCLA Section 11 7 (a) ( 2 ) . The
transcript of this meeting is enclosed as part of the
Responsiveness Summary. The Responsiveness Summary also includes
responses to community concerns which have been expressed during
the public comment period. All requirements of CERCLA Sections
Koppers Draft ROD
August 1992
Page 6
113(k)(2)(B)(i-v) and 117 have been met.
4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The response action defined in this Record of Decision (ROD) is
anticipated to be the final action and subsequently the final ROD
for this site. No separate Operable Units are anticipated as this
remedy should address all aspects of the site which currently pose
a threat to human health or the environment. Remediation of the
groundwater will be to levels that will allow the aquifer to be
returned to safe drinking water levels. Remediation of the soil
contamination will both eliminate direct exposure risks to onsite
workers as well as eliminate future adverse impacts to the
groundwater. Remediation of the surface water· will eliminate
exposure pathways of site related contaminants to ecological
populations.
5.0 SUMMARY OF SITE CHARACTERISTICS
The Koppers Company Site has been subjected to the requirements of
CERCLA which mandate that a Remedial Investigation be conducted;
This section of site characteristics is based on that Remedial
Investigation, and attempts to summarize the results. Further
detail can be obtained from the Remedial Investigation report.
The Remedial Investigation included the sampling and analysis of
groundwater, soils, surface water and associated sediments and
fish. The results of this sampling and analysis indicate that the
contamination generated by the use of the CELLON wood preserving
process has adversly impacted groundwaters, soils and surface
waters at and in the vicinity of the site. Samples were analyzed
predomiantly for extractable organic compounds, also known as semi-
volatile compounds, since pentachlorophenol was the main chemical
component of the wood treatment. Further refinement categorized
the majority of the site related contaminants as phenolics.
Approximately 15 % of all environmental samples, with the exception
of fish samples, were analyzed for metals, volatiles, semi-
volatiles, pesticides and PCBs, known as full-scan or TCL/TAL to
ensure that the historical information available for the site was
accurate and that additional unknown contaminants were not
adversely affecting the Site. Analysis for PCDD/PCDF was also
required of a percentage, (approxiamtely 15%), of the environmental
samples collected during the RI. PCDD/PCDF is known to be a
contaminant of pentachlorophenol. Pentachlorophenol and PCDD/PCDF
are considered the major contaminants at the Site. Other phenolic
compounds and isopropyl ether, a volatile organic compound, have
been identified at the site, but are considered minor site
contaminants due to frequency of detection and concentration.
The investigation of soil focused on the former process and lagoon
areas, the former landfarm area, the tepee area and the remaining
site proper. Figure 5.1 provides the locations of the soil samples
~Opper• Draft ROD
Auguet 1992
P&qe 7
collected during t~e RI. Surface and varying depths of subsurface
soils were used in the characterization of the soils. The
analytical results demonstrate that contamination in the former
process and lagoon areas pose a significant threat for human
exposure from direct contact as well as a potential source of
contamination to the groundwater. Table 5 .1 identifies site
contaminants and the concentration ranges. Figure 5. 2 provides the
contaminant concentrations of the major contaminants
pentachlorophenol and TCDD toxic equivalents in the former process
. and lagoon areas. A concentration range for total phenolics is
also shown. ·
The former lagoon and process areas are the only areas of the site
targeted for soil excavation. The volume of contaminated soil
originally calculated in the .Remedial Investigation Report was
approximately 1000 yds3 • Due to historical underestimates at
Superfund Sites, EPA conducted modeling to calculate a potential
high volume. An upperbound maximum of 10,000 yds3 was calculated.
Groundwater contamination was known prior to the initiation of the
Remedial Investigation and was the primary reason the site was
placed on the National Priority List. Figure 5.3 provides onsite
and near site monitoring well locations. Figure 5. 4 presents
offsite monitoring well locations. Though not officially part of
the scope of the RI, extensive groundwater sampling of private
wells in the vicinity of the site has been conducted and was
utilized in the decision making process for remedy selection. The
Domestic Well Sampling Program can be found as Appendix I of the RI
Report. Figure 5.5 shows the private well sampling locations. The
MCL for pentachlorophenol was exceeded in wells 0S-8 and 14K during
the private wells sampling program.
Tables 5.2.A, 5.2.B and 5.2.C provide the major contaminants and
the concentration ranges for the groundwater in the eastern area of
the site, the western area of the site and offsite, respectively.
Table 5.2.D focuses of groundwater contamination is the lagoon and
process areas. Figure 5. 6 demonstrates the pentachlorophenol
groundwater plume defined as any concentration exceeding the MCL of
1.0 ppb. Figure 5.7 shows locations where dioxin has been detected
in groundwater. Additional groundwater sampling of all monitoring
wells and select private wells will be conducted during Remedial
Design to better define the lateral and vertical extent of
groundwater contamination.
The surface water investigation.included the onsite Fire Pond, the
Medlin Pond, the outflow ditches from both ponds and drainage
features termed the eastern and western ditches. The Fire Pond
outflow ditch progre;;ses into the Medlin Pond; the western ditch
converges with the Medlin Pond outflow ditch and the confluence
continues downstream joining Crabtree Creek 2-3 stream miles south
of the site.
Koppers Draft ROD
Auguat 1992
Paqa 8
= CJ
0
0 ()
Q
Ll,. C3A
lb
Figure 5.1
LEGEND
D SURFACE SOIL SAMPLING LOCA HON
A_ SOIL BORING LOCAlION
A BACKGHOUNO SOIL BORING tOCATION
•---BEAZER EASl. INC. PRUPERH BOUNDARY
----Utlll STRUClURES me. PROPF.RrY BOUNDARY
NOTE:
UNDISTURBED SOIL SAMPLES COLLECTED VIA SHELBY TUBES AT THE FOLLOWING LOCATIONS:
X-5. X-25, X-30 (3), X-37. and X-59 13!
SCALE (FEET!
0 100 200
0
Cl
Figure 5.1
Soil Sample Locations
Table 5.1
:-··:,: :·'.•._: ... ,_·.:,· ..
.. ·•·.: •···············.·•··•·•····· ii/)•· .. ·•·•··
....... /> ·r .·
SURFACE SOILS .;. \ ...... { .· .
,Process & Lagoon. Afe~~ .. / · ... -.-.:_· . } ./ ••
Contamiri~rit .· .·.·• ··•·•·• 1( l .. · .. •·.
"1i 11 i.rii~in . ~-,J ·:f . .. \: Fi~queri~; •· i .
>·
I·· '-1ffl ··
. _.-:.:._.,::::··-·::._ .. _:.: ·. ·::, ··ri!h~bhibi. i . . · .. •· . •.. . ...
tt········••. • 1 > ). .·. . . i . fr. ·•. .. . .... ·. ··•·· . . . ···•··· ... ..
phenol ND ND 0:19
2-chlorophenol ND 477.0 4:19
2-nitrophenol ND ND 0:19
2,4-dimethylphenol ND 646.0 1:19
2,4-dichlorophenol ND 383.0 3:19
4-chloro-3-methylphenol ND 568 2:19
I I
2,4,6-trichlorophenol ND 190.0 1:19
2,4-dinitrophenol ND 8740.0 1:19
4-nitrophenol ND ND 0:19
2,3,5,6-tetrachlorophenol ND 3390.0 5:19
2-methyl-4,6-dinitrophenol ND 580.0 2:19
isopropyl ether ND ND 0:1
pentachlorophenol ND 3,220,000.00 16:19
TCDD-TE 0.480 270.00 5:5
ND -Contaminant was not detected
·.· TABI.B5-2~A!<>··
Groundwatei:/ ···.·: .:
>'ifustern··: Area.•·· ' • ·-:..-I . ··' ' .· .... .,;:_:::/.://:•,•I·:''" . : ,_,_
···. > ..
.Contaminant :Minimum
. •. ·. \. · (ug/1)
phenol ND
2-chlorophenol ND
2-nitrophenol ND
2,4-dimethylphenol ND
2,4-dichlorophenol ND
4-chloro-3-methylphenol ND
2,4,6-trichlorophenol ND
2,4-dinitrophenol ND
4-nitrophenol ND
2,3,5,6-tetrachlorophenol ND
2-methyl-4,6-dinitrophenol ND
isopropyl ether ND
pentachlorophenol ND
TCDD-TE 4.00E-07
ND -Contaminant was not detected
~oppera Draft ROD
August 1992
Page 11
.. :. ·•:•. I .
I . .. ·•.· ). · . . . ..
Maxi.mum : .. :
,·I < I Frequency
(ug/1) .. .. • of Detection
1.7 3:12
1.22 2:11
ND 0:12
ND 0:11
307.5 1:11
7.91 2:11
3.45 1:11
ND 0:17
1.66 1:17
16.3 4:17
12.7 3:22
2800 14:22
1490 22:27
l.96E-05 5:5
.• TABLE· s4iti r ... ·
I . i Groundwater . ·.. : : .
. Western Area · · I• .
-\:._/·.·:·<>' :.,:: .. -.. ..... :-: ·:::·· .. I ' . i• ..
. .
Contaminant Minimum
(ug/1)
phenol ND
2-chlorophenol ND
2-nitrophenol ND
2,4-dimethylphenol ND
2,4-dichlorophenol ND
4-chloro-3-methylphenol ND
2,4,6-trichlorophenol ND
2,4-dinitrophenol ND
4-nitrophenol ND
2,3,5,6-tetrachlorophenol ND
2-methyl-4,6-dinitrophenol ND
isopropyl ether ND
pentachlorophenol ND
TCDD-TE NA
ND -Contaminant was not detected
Xoppera Draft ROD
August lH2
Page 12
<. _··,\: ,} .
i I.· . ': ... :. : ' . '. .. · ..
. Maximum ... ' ·Frequency
(ug/1) :,::: .of Detection
155 2:13
ND 0:13
0.98 2:13
ND 0:13
ND 0:13
9.8 3:13
ND 0:13
ND 0:13
10.7 3:13
ND 0:13
57.5 1:16
2.84 2:16
0.18 9:19
NA 0:0
.Contaminant ·
phenol
2-chlorophenol
2-nitrophenol
2,4-dimethylphenol
2,4-dichlorophenol
4-chloro-3-methylphenol
2,4,6-trichlorophenol
2,4-dinitrophenol
4-nitrophenol
2,3,5,6-tetrachlorophenol
2-methyl-4,6-dinitrophenol
isopropyl ether
pentachlorophenol
TCDD-TE
I • ....
.. ·: !:"---
..... :•··
I •.-.·
:-. _::·. ..-·: .. :·1,: ..
Mi,.· . ··• •M. • . nl.lllllm ,aXJ mn10 . ·
(ug/1 ). i i (ug/1} i
ND 32.4
ND 11.5 J
ND 134
ND 2.8
ND 35.8
ND 278
ND ND
ND 13.5
ND 36.2
ND 16.9 J
ND 98
ND 5.37
ND 0.23
1.00E-08 1.50E-07
ND -Contaminant was not detected
J -Estimated Value
Koppera Draft ROD
Auquat 1992
Page 13
Frequency
of Detection ..
4:23
1:23
2:23
1:23
3:23
3:23
0:23
1:23
5:23
2:23 ,
3:27
3:28
14:32
3:3
TABLE .5~2{bY
.. .. . ...
Ground~a1:er Former .·· · .. .'::'·-,·::-· ::·_. _,. . . ·' -: -.
Lagoon and . : le
i> .Process Area . < . ..
:-:"./·:· .. -· . -. ,-:
.. . .
·contaminant </.••· ·.: .•Minimum •Maximum
.. ..
.. · Frequency
(ug/1) (ug/1) :.of Detection
phenol ND 2.67 4:17
2-chlorophenol ND ND 0:17
2-nitrophenol ND ND 0:17
2,4-dimethylphenol ND ND 0:17
2,4-dichlorophenol ND ND 0:17
4-chloro-3-methylphenol ND 9.2 3:17
2,4,6-trichlorophenol ND 9.81 3:17
2,4-dinitrophenol ND ND 0:17
4-nitrophenol ND 1.66 1:17
2,3,5,6-tetrachlorophenol ND 16.3 4:17
2-methyl-4,6-dinitrophenol ND 12.7 3:22
isopropyl ether ND 2800 14:22
pentachlorophenol ND 1490 22:27
TCDD-TE 4.00E-07 1.96E-05 5:5
ND -Contaminant was not detected
Figure
points.
5. 8 shows the locations of the surface water sampling
Figure 5.9 presents the locations of sediment samples.
Koppera Draft ROD
August 1992
Page 14
= L]
0
A C3A
lb
Figure 5.1
LEGEtJO
/j,. SURFACE SOIL SAMPLING LOCAllON
,A SOIL BORING LOCATION
A BACKGHOUNO SOIL BORING l OCAT ION
•---BEAZER EAST. INC. PHUPERTV BOUNUARY
.;.... ___ UNIT STRUCTURES INC. PROPfRry BOUNDARY
NOTE:
UtmlSTURBED SOIL SAMPLES COLLECTED VU
SHELBY TUBES AT THE FOLLOWING LOCATIONS:
X-5. X-25, X-30 {3), X-37. and x_-59 (31
SCALE (FEE~)
0 100 200
0
Cl
Figure 5.1
Soil Sample Locations
= -<..J
\
LEGE.t,J
Figure 5.2
... • r-------.;: " .... <.........J ,'
~-~ tc,:c;'c,+':._c•:,•~·1 .~, ·--* * .,.. .. , .,.
'"'
·-
H ,-,o
,.., "·' u ,u ..,
'"
......... --....................
9CAI..E -
0 30 ..
F R E p 0 N 0
_,,,--·-
/
Af'f'FIOXJ~?CATION OF .,..,,,,.," Pll
no 11 ,., ., I
• ""
...................
---
-:: )
0
.,
"' u ... .. -,n ,o, u ~· .,.
\
\
\
\
\
\
\
\ y
Figure 5.2
Major Contami C nant
oncentratio Pr ns ocess and L
A
agoon
rea
\
)
=
LEGEND
□
HON/ TOR!NG 1'EU [_OCAT ION
BEAZER EAST, INC. PROPERTY BOUMJARY
UNI I STRUCTURES INC. f'f?OPERTY BOUNOARY
NOT£. lrELL /'l(f lt'AS UTIL l ZED AS
A PUMPING TEST lt'Ell .
•
0
L] •
Figure 5. 3
I
I
I
I
I CUA
CUB
I
0
SCALE (FEET)
1~0 300
0
! !
I I
CBA
Figure 5.3
Onsite and Near Off-
4!50 Site Monitoring Well
Locations ,!)It
-* ___,cc:::,=
Ell)
:) orr Sllf 0fff' M0NII ORING Ifft L LOO I ION
-8f.AlfA f.1.SI, INC. Pll OP[RH l:lOUII0.1.AY
•-l/tlll SIRUCIURfS INC. PA OPE RT y BOUt,0.1,RY
,,,.
</~' 51pf
,.., ,,pc"v·
~~,-~/
J / .. ._: ,,,,/~ ,.,,
, ./✓-,
0
l'igute 'J.4
+ C21C
□ • a
·~ a
0
C19C
+ C23C
..
0
+ C18C
\_.:;;\ f-~"' . ()q,~
' CHlRCH STREET
BA/BEE ROAD • C20C
SCALE (FEET)
300 600 900
Figure 5.4
Offsite M Well L onitoring
ocations
I I
1
----.....'
I I I I I I I
Fig'-!.re 5,5
3 4 . .........___
-~.
-------
~.!'-... ----/--
-~~..C.
-,? , , .. , -, ..
_.,
'--------
+ PROPOSED SHALL Oli INTERHEDIA TE AND DEEP ilELL CUJSTEH
-+ PROPDSEO DEEP >IEL L
5' 6
I
I
0
7
1
~
I
SC.ALE (FEET)
JOOO
I
2000
G
:-1
I
J
L
M
N
C
Figure 5.5
Private Well Sampling
Locations
---------------------------....L.------------·--"
=
LEGEND
D
HON[TORING lt'El.l LOCATION
BEALER EAST, INC. PROPERTY BOUVJARY
UNIT STRUCTURES INC. PROPERTY BOUNOARY
NOTE: WELL PN I lt'AS UTIL l ?ED AS
A PUHPJNG TEST lt'ELL .
•
• • D
"o
) p'
1/ -~C9B
C9A CBC
• LJ
Figure 5.6
I
I
I
I
I
I
SCALE (FEET)
o 160 300 ~eo
d o
0
Figure 5.6
Pentachlorophenol
Groundwater Plume
( > MCL)
Table 5.3 identifies concentration ranges and frequencies of
detection for surface water samples in the Fire Pond. Table 5.4
provides that information for the offsite Medlin Pond. Tables 5.5
and 5.6 provide the concentration ranges for sediment samples in
the Fire Pond and Medlin Pond respectively.
6.0 SUMMARY OF SITE RISKS
A primary directive under CERCLA is to protect human health and the
environment from both current and future potential exposures to
hazardous substances at Superfund sites. ' The Baseline Risk
Assessment provides the basis for taking action and indicates the
exposure pathways that need to be addressed by remedial action. It
serves as the baseline indicating what risks could exist if no
action were taken at the site. This section of the ROD reports the
results of the Baseline Risk Assessment prepared using the
analytical data generated during the Remedial Investigation and
summarizes the current and future risks associated with the
contamination which presently exists at the site. The Baseline
Risk Assessment was developed by the potentially responsible party;
the Administrative Order by Consent signed in March of 1989 allowed
potentially responsible partY to conduct the Risk Assessment
concurrently with Remedial Investigation work.
6.1 Contaminants of Concern
Historical records and sampling of environmental media at the site
were used in the original selection of contaminants of concern at
the Koppers site. Pentachlorophenol, isopropyl ether, and the
congeners of the dioxin/furan family were known to be contaminants
at the site. To ensure that no additional major contaminants
existed, approximately 15 % of the samples collected during the
Remedial Investigation . were required to be "full scan" · which
included volatile organic compound, semi-volatile organic
compounds, pesticides and PCBs, (known as the Target Compound List)
and metals and cyanide, (referred to as the Target Analyte List).
The list of contaminants below were selected for inclusion in the
quantitative risk assessment conducted in the Baseline Risk
Assessment.
Major Contaminants
pentachlorophenol
PCDDs/PCDFs'
1 PCDDs/PCDFs refer to polychlorinated dibenzo-p-dioxins and
polychlorinated dibenzofurans, which are also more commonly
referred to as dioxins. TCDDs/TCDFs are the tetrachlorinated
congeners substituted in the 2,3,7,8-configuration, specifically
2,3,7,8-tetrachlorodibenzo-p-dioxin and 2,3,7,8-
tetrachlorodibenzofuran. Due to the greater toxicity associated
with this 2,3,7,8-configuration, Toxic Equivalents (TEs) are
calculated for all congeners. The toxicity assessment for the
PCDDs/PCDFs are evaluated as TCDD-TEs.
Koppora Draft ROD
August 1992
Page 21
=
LEGEND
D
HONllO/iJNG lt'Ell l.OCAIION
BEAZlll EAST. JNC. l'IIUPl.lll I' BOllNOAIIJ'
UNIT SIRUCIIJllES INC. PROPERTY BOUNOARY
NOTE: NEU f'Jt'f WAS UT fl [?ED AS A PUHPJNG /EST NHL .
•
• • D D
"o
)
Fi ure 5.7
d o
SCALE IFEETI
0 160 300 4!50
Figure 5.7
Dioxin Detections
in Groundwater
' !
I \
SN28
t'
L]
•
D
0
Figure 5.8
SCALE (FEET)
l"liil"I-o 120 I 240 360 .
Cl
Figure 5.8
Surface W Sampli ater ng Locations
I I
Figure 5.9
•
0
SCALE (FEET)
0 120 240 360
Cl
Figure 5.9
Sediment S ample
Locations
I I
Contaminant . Minimum
•·. (ug/1)
phenol ND
2-chlorophenol ND
2-nitrophenol ND
2,4-dirnethylphenol ND
2,4-dichlorophenol ND
4-chloro-3-rnethylphenol ND
2,4,6-trichlorophenol ND
2,4-dinitrophenol ND
4-nitrophenol ND
2,3,5,6-tetrachlorophenol ND
2-rnethyl-4,6-dinitrophenol ND
isopropyl ether ND
pentachlorophenol 0.043
TCDD-TE 1. 20E-04
ND -Contaminant was not detected
Koppera Draft ROD
Auquat 1992
Page 24
.
· Maximum . ,. ·. Frequency <· (ug/1). .. ·_·· I of Detection
1.02 2:12
0.609 1:12
ND 0: 12
3.84 2:12
3.69 6:12
ND 0:12
ND 0:12
ND 0: 12
4.13 (avg) 1:12
1.92 5:12
ND 0: 12
ND 0:6
0.1665 12: 14 2
2.SSE-04 6:6
TABLE 5~4 / i .ii•· .. . :· .
·. · SURFACE/WATER ...,
MEDLiiFPOND
. : ..
~ ~--Contaminant · ·Minimum•·. . .. ·.,. · .... (ug/1). ·
phenol ND
2-chlorophenol ND
2-nitrophenol ND
2,4-dimethylphenol ND
2,4-dichlorophenol ND
4-chloro-3-methylphenol ND
2,4,6-trichlorophenol ND
2,4-dinitrophenol ND
4-nitrophenol ND
2,3,5,6-tetrachlorophenol ND
2-methyl-4,6-dinitrophenol ND
isopropyl ether ND
pentachlorophenol ND
TCDD-TE 4.60E-06
ND -Contaminant was not detected
Koppers Draft ROD
Auguat 1992
Pa,ge 25
.: ..
i: •·
. · ..... ( . > I/ . . . : .
. .. : .
Maximum •• ,Frequency
(ug/1). · . of Detection
2.85 3:11
ND 0:11
1.3 3:11
0.743 1:11
0.551 2:11
ND 0:11
1.49 1:11
2.11 1:11
ND 0:11
4.89 5:11
1.13 1: 11
ND 0:6
0 .145 6:11
1. 99E-05 2:2
TABLE'•· .sis t··< i\• .. ·. ·,. [:'" ..
. --·
SEDIMENT SAMPLES./ . ·•· ) :. · ..
Fire P<>nd.. . I
. . }' Contaminant Minimum '
.. (ug/kg)
phenol ND
2-chlorophenol ND
2-nitrophenol ND
2,4-dimethylphenol ND
2,4-dichlorophenol ND
4-chloro-3-methylphenol ND
2,4,6-trichlorophenol ND
2,4-dinitrophenol ND
4-nitrophenol ND
2,3,5,6-tetrachlorophenol ND
2-methyl-4,6-dinitrophenol ND
isopropyl ether ND
pentachlorophenol ND
TCDD-TE 0.04
ND -Contaminant was not detected
Koppers Draft ROD
Auguat 1992
Pago 215
< .. ·. I i _.., ,',, .
·. >·.·•·····
''' ·:. :-...
( i .,.·
.: ·'·. . . ··.·-.•
.
,I. . . : •, . . . . : · Maximum •· / Frequency
•. (ug/kg) > of Detection
197 5:16
802 3:16
94.4 1:16
184 1: 16
ND 0:16
ND 0: 16
ND 0:16
ND 0:16
361.5 2:16
ND 0:16
233 1:16
ND 0:4
5040 5:16
0.49 5:5
••·TABLE .. ··s.·6 L . . ·•. .
SBDIMER'l'\SAMPLBS
·} . ·· .. •. MBDLIIN POND ...
·contaminant Minimum ... (ug/kg)
phenol ND
2-chlorophenol ND
2-nitrophenol ND
2,4-dimethylphenol ND
2,4-dichlorophenol ND
4-chloro-3-methylphenol ND
2,4,6-trichlorophenol ND
2,4-dinitrophenol ND
4-nitrophenol ND
2,3,5,6-tetrachlorophenol ND
2-methyl-4,6-dinitrophenol ND
isopropyl ether ND
pentachlorophenol ND
TCDD-TE 0.54
ND -Contaminant was not detected
loppers Draft ROD
Augu■t 1992
Page 27
· . .· .
.
. . ·._':.,' ... _ _. . .
:_· .. ·.
Maximum•·•··· · .. •• .Frequency
·• · ... • .••• (ug/kg) .of Detection
134 2:5
ND 0:5
ND 0:5
1590 4:5
ND 0:5
ND 0:5
ND 0:5
ND 0:5
ND 0:5
ND 0:5
233 0:5
ND 0: 1
5040 0:5
1.01 2:2
Minor Contaminants
isopropyl ether
phenol
2,4-dichlorophenol
2,4-dinitrophenol
2,4,6-trichlorophenol
2,3,5,6-tetrachlorophenol
2,3,4,6-tetrachlorophenol
2-chlorophenol
2,4-dimethylphenol
2-nitrophenol
4,6-dinitro-o-cresol
4-nitrophenol
4-chloro-3-methylphenol
The tables in Section 5.0, Summary of Site Characteristics,
identify the concentrations of the contaminants of concern in each
medium of exposure.
The contaminants identified above can be related to the wood
treatment process historically used at the site. The land use of
the immediate site continues to be of an industrial nature, with an
active wood laminating facility on the western portion of the site.
Surrounding land use is a mixture of light industrial, commercial
and rural residential. Current land use and zoning maps are
included in the Baseline Risk Assessment. The likelihood of the
site reverting to residential is extremely remote. The entire area
known as the Raleigh, Durham, Research Triangle Park area is
developing for industrial and commercial use.
Drinking water was obtained almost exclusively in the immediate
area from groundwater prior to 1989, when Beazer signed the
Administrative Order by Consent to install water lines. Many area
residents outside the immediate vicinity continue to be served by
groundwater for all domestic water uses. The groundwater is
federally classified as IIB, a drinking water source aquifer.
6.2 Exposure Assessment
The exposure assessment evaluates and identifies complete pathways
of exposure to human populations on or near the site. Land use and
human activity are utilized in this assessment.
The current principal human receptors (potentially exposed
populations) include local offsite residents, onsite workers, and
potential onsite trespassers. Onsite workers and trespassers may
be exposed to site-related contaminants in surface water,
sediments, and surface soil. Onsite truck washing using
groundwater may also create an exposure pathway to site
contaminants.
The primary future human receptors at the site may be onsite
~oppera Draft ROD
Augu11t 1992
Page 28
workers and potential trespassers, construction worker and offsite
residents. Potential future exposures would include surface soils,
sediments, and groundwater.' The Baseline Risk Assessment did
evaluate the potential future human receptors considering land use
under the residential scenario, though the site is not considered
residential for current or future use by this decision document.
That information may be referred to in the Baseline Risk
Assessment.
The current and future potential exposure pathways considered
included both direct exposure pathways in which the receptor comes
into contact with a contaminated medium and indirect exposures
through which exposure to site contaminants would be from food-
chain uptake. The exposure pathways listed below were evaluated
quantitatively:
Inhalation of soil as dust (surface and subsurface)
Dermal contact with and inadvertent Ingestion of soil
(surface and subsurface)
Dermal contact with and inadvertent Ingestion of sediment
Dermal contact with and inadvertent Ingestion of surface
water
Consilmption of Groundwater
Inhalation of Volatile constituents from groundwater
while showering
Consumption of vegetables
Consumption of Fish
The exposure scenarios evaluated took various assumptions into
account to develop estimates which represent risks quantitatively.
A local off-site resident is assumed to live near the site property
for the first 30 years of his/her life. Further categorization
into age groups of young child (YC) ages Oto 5, older child (OC)
ages 6 -17, and adult (A) 18 to 29. In addition, a local off-site
teenage mutant ninja trespasser is also evaluated and assumed to
2 The Baseline Risk Assessment indicates that ingestion of
groundwater for current or future residents would not be a pathway
selected for evaluation since city water has been extended to the
immediate surrounding area and therefore residents would not have
access to groundwater as a drinking water source. This would be
true for the immediate area only where the existing water lines are
available for hookup. A Wake County representative indicated that
a well permit would probably not be issued where the water lines
exist. Those areas where no public water is available cannot
consider groundwater inaccessible. Since risk assessment must
consider the site from a no action perspective, the groundwater
exposure scenario must be maintained here. This also takes into
consideration that the aquifer is a Class IIB aquifer, a resource
which requires remediation to a drinking water quality.
Koppers Draft ROD
August 1992
Page 29
trespass for 8 years during ages 10 to 17. A worker onsite is assumed to be a 70 kg adult who works at the site 5 days a week for 47 weeks per year for 20 years. Further detail and mathematical calculations can be reviewed in the Baseline Risk Assessment Report.
6.3 Toxicity Assessment
Toxicity assessment, as part of the Superfund baseline; risk assessment process, considers ( 1) the types of adv,~rse heal th or environmental effects associated with individual and· multiple chemical exposures, ( 2) the relationship between magnitude of exposures and adverse effects, and (3) related uncertainties such as the weight of evidence for a chemical's potential carcinogenicity in humans.
Cancer slope factors (CSFs) have been developed by EPA's Carcinogenic Assessment Group for estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic chemicals. CSFs, which are expressed in units of (mg/kg/day)-1 , are multiplied by the estimated intake of a potential carcinogen, in (mg/kg/day), to provide an upper-bound estimate of the excess lifetime cancer risk associated with exposure at that intake level. The term "upper-bound" reflects the conservative estimate of the risks calculated from the CSF. Use of this approach makes underestimation of the actual cancer risk highly unlikely. CSFs are derived from the results of human epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health effects from exposure to chemicals exhibiting noncarcinogenic (systemic) effects. RfDs, which are expressed in units of mg/kg/day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals, which will result in no adverse health effects. Estimated intakes of chemicals from environmental media (i.e., the amount of chemical ingested from contaminated drinking water) can be compared to the RfD. RfDs are derived from human epidemiological studies or animal studies to which uncertainty factors have been applied (i.e., to account for the use of animal data to predict effects on humans). These uncertainty factors help ensure that the RfDs will not underestimate the potential for adverse noncarcinogenic effects to occur.
The Baseline Risk Assessment identified CSFs and RfDs for the contaminants of concern for the Koppers site. Table 6.1 provides the Cancer Slope Factors (CSFs); Table 6.2 provides the Reference
Kopper■ Ora.ft ROD
Auguat lH2
Page 30
TABLE 6~f(i ... '\ .
. .. EPA
Const~r:~~t :'.' .
· .. Carcinogen .
Class EPA CSF Source . .
2,4,6-trichlorphen9l B2 O:l.lE-2 IRIS, 4/91 . I:l.lE-2 IRIS, 4/91
pentachlorophenol B2 O:l.2E-l BEAST, 9/90 I:ND
PCDD/PCDF . t B2 O:1.SE+S BEAST, 9/90 I: l.5E+5 BEAST, 9/90
.. TABLE 6.2 . •. OralRfD. > • .. Source
:,.. · (mg/kg/dayJ\
' ':': . •. Contaminant . . · ... .. .. . .• . ·:·:·:::· phenol 6E-l IRIS, 4/91
.·· .. 2-chlorophenol SE-3 IRIS, 4/91
.· 2-nitrophenol BE-3 3 EPA, 1990
' 2, 4-dimethylphenol• 2E-2 BEAST, 9/90 ·., 2, 4,'-dichlorophenol · .. . :<i' ....... ',, 3E-3 IRIS, 4/91 ,. >.< 4-chloro-3-methylphenol 2E-2 ENSR,4/91
2, 4-dinitropheno( ,;J ,; '·: /(. 2E-3 IRIS, 4/91
4-nitrophenol •.· ....• \? / . . . .. . ·. ·:,:•,:>:. .·· BE-3 EPA, 1990 . . .. ·· ', .,., ... _ .. ,• ,', ·_·,.: ... 2 , 3 , 5 , 6-tetrachlorophenol· •' ,,,: lE-2 ENSR,4/91 ., 2-methyl-4; 6-dinitr~phenoi :•:• 2E-3 IRIS, 4/91
isopropyl ether .. ·': . '.} ' .. ,,:_:, ·:···· ·,,,· . 2E-1 IRIS, 4/91 t hl' <.·.h•· ,'J\•.,/ . .i:Yi:. pen ac · orop eno ·:·· · ·· .·.·.-· :_:: 3E-2' IRIS, 4/91
Dose (RfDs) values. Those site-related contaminants for which EPA-derived RfDs or CSFs are not available, RfDs were derived using standard EPA methods from toxicity studies identified in the
3
•
RfD.
Value 4-nitrophenol used due to structural similarity •
CSF is identified for this contaminant in addition to the
Kopper• Draft ROD Auguat 1992
Page J l
scientific literature, or from EPA toxicity criteria for structurally related compounds. The contaminants of concern that can be associated with the majority of the risk associated with the site are PCDD/PCDFs, and to a lesser extent, pentachlorophenol.
6.4 RISK CHARACTERIZATION
The risk characterization step of the site risk assessment process integrates the toxicity and exposure assessments into quantitative and qualitative expressions of risk. The output of this process is a characterization of the site-related potential noncarcinogenic and carcinogenic health effects.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed as the hazard quotient (HQ), or the ratio of the estimated intake derived from the contaminant concentration in a given medium to the contaminant's reference dose. By adding the HQs for all contaminants within a medium or across all media to which a given population may be reasonably exposed, the Hazard Index (HI) can be generated. The HI provides a useful reference point for gauging the potential significance of multiple contaminant exposures within a single medium or across media·. The HI is equal to the estimated potential exposure dose divided by the RfD. When this ratio exceeds unity, the estimated potential exposure is greater than the allowable exposure and the potential for adverse health effects may exist. None of the hazard indices for the site exceed unity considering the current and future land use scenario as industrial.
Excess lifetime cancer risks are determined by multi plying the intake level with the cancer potency factor. These risks are probabilities that are generally expressed in scientific notation (i.e., 1x10-• or lE-6) . An excess lifetime cancer risk of lE-6 indicates that, as a plausible upper-bound, an individual has a one in one million chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions at a site.
EPA has set an acceptable carcinogenic risk range of lE-4 to lE-6. The current quantitative carcinogenic risks which are either within or outside this risk range are presented in Table 6.3. Table 6.4 provides the future quantitative carcinogenic risks for the offsite resident; onsite worker values do not change. This evaluation assumes the current land use will not change to residential. The current and future land use of the site is considered industrial; the cleanup standards developed for the soils removal are 95 ppm for pentachlorophenol and 7 ppb for PCOD/PCDF. The risks associated with dermal exposure to the soils after aquiring these cleanup standards are 3. 2E-06 and 1. 2E-04 respectively for the onsite worker.
Koppera Draft ROD
Auguat 1992
Page 32
... ·.• .. ·. / > . /. i • ... · ... ·.
. ··· ... / Table6~3 :-'t:\:)?.,-·:·::::.: •, ·-:-··· -,"_' -:::_·' .-·\·•:._:/·'•-?::_,:/,_·:·;:,. . . . •.•· <,·
. ..· ... , Local Reaid.tint (trespasser· scenario) ·.
Surface Area Soils -Lagoon & Process Area 7.7E-04
Fire Pond Surface Water (Oral & Dermal) 6.6E-06
Fire Pond Fish 1.9E-05
Western Ditch Surface Water (Dermal) 1.2E-06
Fire Pond Discharge stream sediments 7.lE-6
(oral, dermal)
I TOTAL II 8. lE:-04
. ..... , ...•........ . •····•· . ..·\•<•:. ·onsite Worker ..... · .. ._ .... _ .. , .. _·:· .
Surface Area Soils -Lagoon & Process Area 3.SE-03
Surface Area Soils -Area north of lagoon
& process area excluding the landfarm area 2.2E-3
I TOTAL II 3.SE-03
· Offsite
Trespasser -
Surface soil (lagoon & process 7.8E-04
area)
Trespasser -Fire Pond Surface Water 6.6E-06
Trespasser -Fire Pond Fish 1.9E-05
Trespasser -Medlin Pond Fish 1.4E-06
Western Ditch -surface water 1.2E-06
Fire Pond Discharge Sediment 7.lE-06
TOTAL II 8.2E-'-04
Koppora Draft ROD
Augunt U92
Page 3l
: _:, I
I
6.5 Risk Uncertainty
There is a generally recognized uncertainty in human risk values
developed from experimental data. This is primarily due to the
uncertainty of extrapolation in the areas of (1) high to low dose
exposure and (2) animal data to values that are protective of human
health. The Site specific uncertainty is mainly in the degree of
accuracy of the exposure assumptions.
Most of the exposure assumptions used in a risk assessment have not
been fully verified. For example, the degree of chemical
absorption from the gut or through the skin or the amount of soil
contact that may occur is not known with certainty. Generally EPA
standard methods were used in developing values when EPA derived
values were not available. In the presence of such uncertainty,
the Agency and the risk assessor have the obligation to make
conservative assumptions such that the chance is very small,
approaching zero, for the actual health risk to be greater than
that determined through the risk assessment process. On the other
hand, the process is not intended to yield absurdly conservative
risks values that have no basis in reality. That balance was kept
in mind in the development of exposure assumptions and pathways and
in the interpretation of data and guidance for this Baseline Risk
Assessment.
6.6 Ecological Risk
A qualitative ecological risk assessment using benchmark values was
conducted as part of the Baseline Risk Assessment for the Site.
The surface water and associated sediments of the Fire Pond and the
Medlin Pond appear to pose to greatest potential risk to ecologicQl
populations at the site.
6.6.1 Fire Pond
The Ecological Risk Assessment showed Chronic Toxicity Quotients
for 2, 3, 7, 8-TCDD of 16. 5 using the EPA Region IV Surface Water
Screening Values protective of aquatic life as a benchmark value.
The riparian assessment showed a toxicity quotient of 0.11 for the
mammalian receptor, the muskrat, and 0.60 for the avian receptor,
the belted kingfisher.
6.6.2 Medlin Pond
The Ecological Risk Assessment showed Chronic Toxicity Quotients
for the following chemicals:
~oppere Draft ROD
August 1992
Page 34
Contaminant
2,4,6-trichlorphenol
2,4-dinitrophenol
2,3,5,6-tetrachlorophenol
2-methyl-4,6-dinitrophenol
2,3,7,8-TCDD
Chronic Toxicity
Quotients
0.184
0.105
0.146
2.3
1.22
These benchmarks are also based on EPA Region IV Surface Water
Screening Values protective of aquatic life as benchmark values,
with the exception of 2,3,5,6-tetrachlorophenol which used a LOEL
for bluegill divided by a safety factor of 10 which is considered
protective of more sensitive species.
6.6.3 Summary of Ecological Risk
While EPA Region IV Surface water Screening Values are not designed
to serve as remedial action levels, they should serve as an
indication of potential ecological threats. Other benchmark values
may be used, both proposed criteria and values reported in the
literature, which would produce larger values for the toxicity
quotients, some by three to five orders of magnitude. Based on the
chronic toxicity quotients provided, remediation of the surface
water in both the Fire and Medlin ponds is deemed appropriate.
7.0 DESCRIPTION OF ALTERNATIVES
The media requiring remediation at the Koppers Company Site include
soils, groundwater and surface water. The description of
alternatives will address the separate components of the remedy by
media.
7.1 REMEDIAL ALTERNATIVES TO ADDRESS SOIL CONTAMINATION
The former wood treating process area and the former lagoon area
are targeted for remediation of contaminated surface and subsurface
soils. The estimation of 1000 yds' will be the soil volume
utilized in identifying costs for this draft decision document
only. Recalculations are being developed based on 5000 yds3 due to
in-house modeling. Costs have been roughly estimated for on-site
and offsite incineration and are included. The major soil
contaminants are pentachlorophenol and PCDDs/PCDFs.
The current risk associated with the contaminated surface soils for
an onsite worker are calculated to be 3.Sx10-'. Soil remediation
will be conducted in the former lagoon and process areas and will
be conducted until concentrations in the soil of PCDD/PCDF are at
Koppers Draft ROD
Augu ■t 1992
Page 35
or below 7 ppb and concentrations of pentachlorophenol are at or
below 95 ppm. Upon completion of the soil excavation, the risk
associated with direct contact for an onsite worker at the site
becomes 3. 2x10-• for pentachlorophenol and 1. 2x10-• for PCDDs/PCDFs.
7.1.1 ALTERNATIVE S-1: SOILS
No Action
Capital Costs:
PW O&M Costs:
Total PW Costs
Time to Implement:
$ 0
$ 0
$ 0
None
CERCLA requires that the "No Action" alternative be evaluated at
every Superfund Site to establish a baselin~ for comparison. No
further activities would be conducted with Site soils under this
alternative (i.e., the Site is left "as is") • CERCLA also requires
that the selected. remedy be protective of human health and the
environment and because the Site poses a future risk to human
health and the environment, the No Action alternative will not be
selected. There are no operation or maintenance costs associated
with this alternative.
7.1.2 ALTERNATIVE S-3: SOILS5
Surface Cover
Capital Costs
PW O&M Costs:
Total PW Costs
Time to Implement:
$ .19,000
$1,307,000
$1,326,000
1 month
This alternative provides for surface capping over the contaminated
soils and includes surface drainage controls. Final soil
compaction, seeding and mulching would be done to provide long term
erosion control. Use of a surface cover would be designed to
eliminate or substantially reduce potential ingestion, dermal
contact, and inhalation exposure pathways. Drainage control and
long term maintenance would be required.
7.1.3 ALTERNATIVE S-4:
Surface Capping
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
SOILS
$ 109,000
$1,368,000
$1,477,000
5 months
5 This Record of Decision does not identify an alternative
titled S-2. The soil alternative S-2 was eliminated in the
screening process of the Feasibility Study due to the lack of
protectiveness; descriptive codes, e.g., S-5, S-9, etc., were kept
for easy reference back to the Feasibility Study Report.
Koppere Draft ROD
August 1992
Page 36
This alternative would be used to isolate the contaminated soils in
the process/lagoon area. This alternative would specify the
construction of a Resource Conservation & Recovery Act (RCRA) cap
over the contaminated soils. This alternative also includes
surface drainage controls. This alternative involves the
implementation of institutional controls to prevent direct contact
and incidental ingestion of contaminated soils by the general
public. A RCRA multi-layer cap consists of the following layers in
ascending order: a densely compacted 2 foot-thick clay layer placed
over the contaminated soils, a synthetic polyethylene liner of at
least 30 mils in thickness on top of the clay layer, a synthetic
drainage layer over the synthetic liner along with a geotextile
fabric to prevent clogging of the drainage layer, and finally, 18
inches of native soils and 6 inches of top-soil on top of the
geotextile fabric. A vegetative cover would be completed and
fencing would be installed to provide a barrier to trespassing.
Long-term maintenance would be required.
7.1.4 ALTERNATIVE S-5: SOILS
Excavation and On-site Landfill
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
$ 663,375
s1. 506,625
$2,170,000
7 months
This alternative involves excavating the contaminated soils and
landfilling the soils on-site. Major components of this on-site
alternative would include capping and lining the landfill area to
meet RCRA regulations. A leak detection system would be installed
to ensure the liners do not fail. A leachate collection and
removal system would be installed. The cap would be identical to
the RCRA cap as identified in Alternative S-4 for soils.
Maintenance of the landfill would require periodic mowing and
control of vegetative cover. Long term groundwater monitoring
would be required to implement this alternative. The excavated
areas would be backfilled with clean soils, graded, and
revegetated. Long term maintenance would be required for this
alternative.
7.1.5 ALTERNATIVE S-6: SOILS
.Excavation and Off-site Landfill
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement
$816,000
S 0
$816,000
approx. 12 months
This alternative involves excavating the contaminated soils in the
same manner as identified in Alternative S-5. The contaminated
soils would be transported to a RCRA-permitted off-site landfill.
The excavated areas would be backfilled with clean soils, graded,
Kopper■ Draft ROD
Augu11t 1992
Page 37
and revegetated. This alternative for soils would be complete upon
final transport of soils and analytical confirmation of cleanup
standards. No long term maintenance would be required.
7.1.6 ALTERNATIVE S-7: SOILS
Excavation and On-site Treatment by Dechlorination
Process and Replacement of Treated Soils
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
$1,838,000
$1,162,000
$3,000,000
Unknown
This alternative involves excavating the contaminated soils and
then chemically treating the contaminated soils on-site. A mobile
treatment unit would be placed on-site. The chemical process
attempts to detoxify and chemically decompose the contamination in
the soils by removing the chlorine atoms from the pentachlorophenol
and the PCDDs/PCDFs. Upon final treatment of the soils, the soils
would be washed and replaced back onto the site. A treatability
study was conducted using the APEG-PLUS™ process. Uncertainties
are associated with the effectiveness of the dechlorination of
PCDDs/PCDFs. The treatability study using the APEG-PLUS™ process
was not successful in demonstrating effective dechlorination of
PCDDs/PCDFs. There are other dechlorination processes available,
such as K-PEG, and BCD. An additional problem associated with
dechlorination is the disposal of residual waste. Due to the use
of solvents in the process, waste is generated which must also be
properly disposed.
7.1.7 ALTERNATIVE S-8: SOILS
Excavation and On-site Incineration
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
$3,432,000
$ 0
$3,432,000 [$ 15,000,000 5000 yds3 ]
6 months
This alternative involves excavation and incineration of the
contaminated soils in an On-site mobile incinerator. The
incinerator destroys the organic contaminants in the soils.
Excavation is expected to be done using conventional equipment and
earthmoving techniques. Following excavation, the excavated soils
would be transposrted to an on-site soil incineration unit. Soils
would be stockpiled prior to treatment. For purposes of destroying
PCDDs/PCDFs, the incinerator is assumed to be a mobile rotary kiln
incinerator with appropriate air cleaning equipment. Site
contaminants · would be burned in the rotary kiln by heating the
solids to a temperature of approoximately 1400°C. Waste solids are
discharged directly from the kiln, while the off-gases are
discharged to a secondary combustion unit where complete oxidation
is insured. Off-gases from the secondary combustion unit are
Koppera Draft ROD
Auguat 1992
Page 38
treated in a multi-stage scrubbing unit for removal of particulates and neutralization o acidic gasses formed during combustion. The treated soils (also considered ash) would either be replaced onto the site or disposed of in a RCRA-permitted landfill. The costs identified above are developed for final off-site disposal. Costs will be developed to consider on-site disposal also, which would be the preference under SARA. These costs will be included in the Final Record of Decision. Onsite disposal of the residual ash would require delisting and land disposal onsite as a solid waste potentially in a land disposal unit designed in accordance with RCRA Subtitle D.
7.1.8 ALTERNATIVE S-9: SOILS Excavation and Off-site Incineration
Capital Costs:
PW O&M Costs:.
Total PW Costs:
Time to Implement:
$2,141,000
S 0
$2,141,000 [$11,000,000 5000yds3 ] approx. 6 months
This alternative involves excavating the contaminated soils and transporting the contaminated soils to a RCRA permitted off-site incineration facility. The contaminated soils would be incinerated which would result in the elimination of the potential risk of ingestion, dermal contact, or inhalation associated with the soils in the process and lagoon areas. It is anticipated that excavation would be accomplished using conventional equipment and earthmoving techniques. Following excavation and removal of contaminated soils, clean fill would be placed in the excavated area(s). Each area would be graded to achieve desirable surface drainage.
For the destruction of site contaminants, use of a rotary kiln incinerator is assumed. Temperatures reaching approximately 1400°C are used in conjunction with all appropriate air cleaning equipment. Waste solids are discharged directly from the kiln, while off-gases are discharged to a secondary combustion unit where complete oxidation is insured. Off gases from the secondary combustion unit are treated in a multi-stage scrubbing unit for removal of particulates and neutralization of acidic gases formed during combustion. The ash which would result from the incineration would be disposed of at a secure chemical landfill and would be the responsibility of the operator of the incinerator facility. The excavated areas would be backfilled with clean soil, graded and revegetated.
7.1.9 ALTERNATIVE
Excavation and
Capital Costs:
PW O&M Costs:
Koppera Draft ROD
Augu11t 19512
Page 39
S-10: SOILS
On-site Storage
$125,000
$534,000
Total PW Costs:
Time to Implement:
$659,000
approx. 3 months
This alternative involves excavating the contaminated soils and
moving them to an on-site storage facility that would be
constructed for the soils storage. A synthetic liner, leachate
detection and collection system, concrete foundation with curbs,
and a cover manufactured of synthetic liner material would be used.
Excavation would be conducted as described in previous
alternatives. The excavated areas would be backfilled with clean
soil, graded and revegetated. This alternative would be a
temporary measure utilized only until acceptable technology for
treating the soils becomes available. This alternative would
eliminate the exposure routes for ingestion, dermal contact, and
inhalation as well as the mobility of the contamination in the
soils.
7.2 REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION
The area of groundwater contamination which exceeds the cleanup
standard in monitoring wells for pentachlorophenol is depicted on
Figure 7 .1. The monitoring wells which have PCDD/PCDF levels
exceeding the cleanup standard for PCDD/PCDF are shown on Figure
7.2.The groundwater at the Koppers Site is classified as Class GA
by North Carolina and Class IIB by the EPA. Since this groundwater
is a potential source of drinking water, remediation is required to
be protective of public health and the environment; cleanup
standards will be met throughout the plume.
The Safe Drinking Water Act and North Carolina Administrative Code,
Title 15, Subchapter 2L (NCAC Tl5:02L.0202) establish maximum
concentration levels (MCLs) and non-zero maximum contaminant level
goals (MCLGs) for numerous organic and inorganic constituents. For
contaminants that do not have either a Federal or State cleanup
goal, risk based remediation goal were calculated. The cleanup
standards are:
Pentachlorophenol' 1.0 ppb
Dioxins/ fur ans 7 • 0•10-5 ppb
Federal Maximum Contaminant Level (MCL).
7 Proposed Federal MCL, equivalent
Quantitation Limit (PQL) of the analytical
promulgated cleanup standard for the State of
2x10-', is below method detection capability.
Koppera Draft ROD
Auguat 1992
Page 40
to the Practical
methodology. The
North Carolina,
=
LEGEtm
1-fDNllORJN{; Jt'[LI. /_OCAFION
BFA?Efl CASI. INC. PROPERlY BOUNDARY
UNI I SlRUCIURE:! ._IN~': .. PROPERTY BOUNDARY
NOTE Liz·~o 4S h'[U PJt'f h'.4S UT I _ c::, A PU.¥PJNG JESf KtLL .
•
D •
• □
SCALE (FEET)
0 150 300 450
Figure 7.1
Pentachlorophenol
Contaminant Plume
( > MCL)
I I
=
LEGEND
·-
D
NONITORING lt'ELL LOCATION
BEAZER EAST. INC. PROPERTY B01.N7ARY
UNIT STRUCTURES INC. PROPERTY BOUNOARY
NOTE: lt'ELL PIO ltlAS UTILIZED AS
A PUMPING TEST lt'ELL .
•
• • D
)
Figure 7.2
• CJ
SCALE (FEET)
0 150 300 ◄!5()
d o
Figure 7.2
PCDD/PCDF
Detections
I I
I ··· Minot i±tec~ntaminants· II·· I
phenol' 4200 ppb
2,4-dichlorophenol' 20 ppb
2,4-dinitrophenol' 14 ppb
2,4,6-trichlorophenol' 3.0 ppb
2,3,5,6-tetrachlorophenol' 10.0 ppb
2,3,4,6-tetrachlorophenol' 210.0 ppb
2-chlorophenol 9 0.1 ppb
The cleanup standards for health based numbers are associated with
a human health risk in the 10-• range.
The groundwater extraction and treatment alternatives were
developed to run for a period of approximately 30 years;
Groundwater remediation is anticipated to be less than the thirty
year period.
7.2.1 ALTERNATIVE GW-1:
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
NO ACTION
$ 0
LQ
$ 0
None
This alternative for groundwater contamination would require no
further activities to be conducted for on-site groundwater. The No
Action alternative is required to be established for comparative
basis under CERCLA. Groundwater contamination would be expected to
continue to migrate with groundwater flow.
' Health-based standards calculated in the absence of state
of federal standards and are based on 10-• risk level .
• North Carolina promulgated maximum contaminant level.
Koppera Draft ROD
August 1992
Page 43
7.2.2 ALTERNATIVE GW-3:
SURFACE WATER DISCHARGE10
Capital Costs:
EXTRACTION, ABOVE-GROUND BIOREMEDIATION,
$ 869,000
PW O&M Costs: S 4,231,000
Total PW Costs: $ 5,100,000
Period of Operation: 30 years
This alternative involves installing extraction well{s) in the
contaminant plume to actively extract groundwater for treatment.
The steps in the treatment include equalization, filtration of
suspended solids, pH adjustment, removal of organic contaminants
and a carbon polishing step. The primary organic treatment
consists of a submerged fixed film bioreactor to permanently remove
and destroy the organic contaminants. Effluent will be discharged
to the surface water and monitored to insure compliance with
National Pollution Discharge Elimination System {NPDES) discharge
requirements.
7.2.3 ALTERNATIVE GW-4: EXTRACTION, ABOVE-GROUND PRETREATMENT &
CARBON ADSORPTION, SURFACE WATER DISCHARGE
Capital Costs:
PW O&M Costs:
Total PW Costs:
Period of Operation:
$ 419,000
S 3,612,000
$ 4,031,000
30 years
This alternative involves the installation of extraction well{s) in
the contaminant plume on-site to actively extract groundwater for
treatment. The steps in the treatment system would consist of
equalization, filtration for removal of suspended solids, and
carbon adsorption of dissolved organics. Groundwater would be
pumped from extraction well{s) into an equalization tank designed
to provide a 24 hour residence time for a predetermined flow rate.
Groundwater would then be pumped into a sand filter for removal of
suspended solids and other matter which could inhibit subsequent
treatment units and hinder treatment capabilities. The filtration
system would include a sand filter, backwash tank, and backwash
pump. Soils would be removed periodically from the backwash tank
and disposed of. Final disposition of the backwash soils would be
determined during Remedial Design. If possible, onsite disposal is
preferable. The filtered groundwater would be pumped from the sand
filter into the activated carbon units; at present a minimum of two
units of 500 pounds of activated carbon each, have been used in the
conceptual design. A series arrangement would be used with the
first unit serving as the primary adsorption unit and the second
unit serving as a polisher. Disposal of spent carbon would be
10 The Alternative GW-2 was eliminated due to the
adequate protectiveness during the screening process
Feasibility Study. The original codes are retained.
~oppera Draft ROD
Auguet 1992
Page 44
lack of
in the
necessary. Final disposal options of spent carbon would be
determined during Remedial Design Stage. The difference of
treatment between GW-3 and GW-4 alternatives is the elimination of
the fluidized bed biological reactor system. The pH adjustment
would not be necessary since this step is taken to optimize
conditions for the biological treatment. Effluent would be
discharged to surface water and monitored to insure compliance with
NPDES discharge requirements.
A treatability study was conducted to evaluated the performance of
activated carbon adsorption for the contaminated groundwater from
the site. The spent carbon and backwash soils would be the
residual waste associated with the groundwater component of the
remedy and would be treated in accordance with all applicable or
relative and appropriate requirements. Due to the PCDDs/PCDFs,
incineration may be the choice for the disposal of the carbon
units.
7.2.4 ALTERNATIVE GW-5: EXTRACTION, ABOVE-GROUND PRETREATMENT AND
UV/CHEMICAL TREATMENT, SURFACE WATER DISCHARGE
Capital Costs:
PW O&M Costs:
Total PW Costs:
Period of Operation:
$ 419,000
$4,714,000
$5,133,000
30 years
This alternative involves installing extraction well(s) in the
contaminant plume on-site to actively extract groundwater for
treatment. The steps in this treatment alternative consist uf
equalization, filtration for removal of suspended solids, treatmer.t
in a UV/chemical oxidation reactor, including addition of peroxide
for oxidizing/converting dissolved organic compounds to chemical
species which meet required discharge levels and a carbon polishing
for adsorption of residual organics. Extracted groundwater would
be pumped to an equalization tank designed to provide a 24 hour
residence time, followed by sand filtration. The filtered
groundwater would then flow by gravity into a reaction tank
equipped with ultraviolet (UV) lights. Hydrogen peroxide ( H202 )
would be used as an oxidizing agent which, in the presence of UV
light, will chemically oxidize the contaminants at the site. Site
contaminants would be converted to chemical species which are
detoxified. The reaction vessel would be designed to provide
intimate contact between the extracted groundwater and the oxidant.
The degree to which UV/chemical oxidation breads down organic
compounds is dependent upon: ( 1) the oxidant dosage, ( 2) the
initial concentration of chemicals in solution, and ( 3) their
molecular structure. Effluent from the reaction vessel would be
pumped through two activated carbon units, a primary desorption
unit and a secondary polisher unit. Effluent would be discharged
to surface water and monitored to insure compliance with NPDES
discharge requirements.
Roppera Draft ROD
Augu11t 1992
Page 45
7. 3. 0 REMEDIAL ALTERNATIVES TO ADDRESS SURFACE: WATER CONTAMINATION
There are two main surface water ponds that will be addressed under this component of the remedy. These are the onsite Fire Pond and the offsite Medlin Pond. Figure 7.3 shows the locations of the ponds. The remediation of the surface waters and the associated sediments is based on protection of the environment. No unacceptable human health risks are present. The Baseline Risk Assessment identifies the quantitative human health risks associated with the surface water and sediments.
7.3.1 ALTERNATIVE SW-1: NO ACTION Fire Pond
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
Medlin Pond
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
$ 0
.LQ
$ 0
None
$ 0
.LQ
$ 0
None
This alternative for surface water contamination would require no further activities to be conducted for on-site groundwater. This alternative is required to be developed under CERCLA, No protection of environmental concerns would be afforded under this alternative.
7.3.2 ALTERNATIVE SW-3: POND DEWATERING, SURFACE WATER TREATMENT, SURFACE WATER DISCHARGE, BACKFILLING IN POND11
Fire Pond
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
$1,300,000
$ 0
$1,300,000
3 months
11 Alternative SW-2 was eliminated during the original screening process in the Feasibility Study due to lack of adequate protection to human health and/or the environment. The original codes are retained for ease of reference to the Feasibility Study.
Koppera Draft ROD Auguat 1992
Page 46
Medlin Pond
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
$ 695,500
$ 0
$ 695,500
3 months
This alternative would require the draining of the on-site Fire
Pond and the Medlin Pond, with surface water storage followed by
treatment with activated carbon. The storage tanks would provide
the necessary equalization capacity and would reduce suspended
solids. Surface water from the ponds would be treated by mobile,
truck-mounted carbon adsorption units •. Dewatering of ponds would
be assisted by the construction of diversion channels and berms to
route stormwater run-on away from the existing pond waters. A
mobile pumping unit would be used to pump the surface water to
temporary storage tanks. The dewatering process would be staged to
allow for the concurrent backfilling of the pond. Temporary
cofferdams, consisting of portable dams would be used to
segmentally dewater and backfill the pond. After dewatering and
backfilling are completed, final grading of the Fire Pond area to
control surface drainage would be conducted. Once final grading is
completed, the disturbed land would be seeded and mulched to
provide long term sediment and erosion control. Temporary storage
tanks would function to equalize dewatering flows and to reduce
suspended solids in the surface water prior to pumping the water
through the treatment facility. Equalization storage required
would be based on the difference between the dewatering rate and
the treatment rate, over a one-day period. Two carbon units,
configured in a series for desorption and polishing would be used.
Final effluent would be discharged to surface water and monitored
to insure compliance with NPDES discharge requirements. The pond
would be filled in with clean soil. The area would be graded to
control surface drainage and a vegetative cover would be planted.
Wetlands construction would also be conducted under this
alternative to restore the wetlands which would be eliminated by
this alternative.
7.3.3 ALTERNATIVE SW-4: POND DEWATERING, SURFACE WATER TREATMENT,
POND LINING AND REFILLING
Fire Pond
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
Medlin Pond
Capital Costs:
PW O&M Costs:
Total PW Costs:
Time to Implement:
~Opper ■ Draft ROD
Auguat 1992'
Page 47
$ 952,000
$ 0
$ 952,000
3 months
$ 710,000
$ 0
$ 710,000
approx. 6 months
This alternative is identical to Alternative SW-3 except that the Fire Pond and Medlin Pond would be lined with a multi-layer synthetic liner which would be anchored into the banks of the ponds by an anchor trench. The ponds would be allowed to refill by storm water within the respective drainage areas. Disturbed soil areas would be revegetated for sediment and erosion control. Wetlands construction would also be conducted on-site under this alternative to restore the wetlands associated with the Fire Pond which would be eliminated by this alternative. Long-term maintenance may be necessary to ensure the integrity of the liners.
No specific treatability study was performed on surface water due to the successful results of the groundwater treatability study. Site contaminants are the same for the surface water and effectiveness is anticipated to be similar to that demonstrated during the groundwater treatability study using activated carbon. The spent carbon would be the only residual waste associated with the groundwater component of the remedy and would be treated in accordance with all applicable or relative and appropriate requirements. Due to the PCDDs/PCDFs, incineration may be the choice for the disposal of the carbon units.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The various remedy alternatives for all components were evaluated using the selection criteria presented in EPA Directive 9355.3-02. These criteria relate directly to factors mandated by CERCLA in Section 121 and considerations which measure the overall feasibility and acceptability of the remedy. '
8.1 THRESHOLD CRITERIA
8.1.1 Protection of Public Health and Environment:
Protection of human heal th and the environment is the central mandate of CERCLA, as amended by SARA. Protection is achieved by reducing risks to acceptable levels and taking action to ensure that there will be no future unacceptable risks to human health and the environment through any exposure pathway. Different remedial alternatives will have varying long-term and short-term impacts on the protection of human health and the environment.
All alternatives evaluated in this document, with the exception of the No Action alternatives, provide some degree of protection of public health and the environment. The degree of protection and the permanence of that protection vary between the alternatives. Alternatives involving excavation of contaminated soils from the
Rappers Draft ROO Auguat 19112
Page 48
•
Figure 7.3
SW2B
T
ITII[[I] -IHf-AC.TEL• '5'1f.FAC.E WATEfi
-
0
-□
I
C)
. ft •• \~ •••
.1/" ,,~ \ \ \\ ~~
( ' )<v'\ .
\..-·· \...,.,/ ~ 0
I .
I ,,/\ \l v" a\ -\
Q'l ~
CJ
o ___ . _mmi___...
----=·
SHJO
SCALE (FEET)
!'!'.~--------·-,
0 120 2◄0 360
FlnE PONO
6 OUTFLOW OITCII 0,PPAOKIH.t.lE\
SH17
-..._______ .
SH31 ~
-~-~
s
••-llfJ.lfll fASf. IMC. PAOJ'EJITY IIOo.t.iHH
---u-1n nRJCnna tHC. PAOP£Rn' e•:uouw
SH36
J.PPROX.
000'60UTll€AST-~
HEOI.. tN PQt,IIJ /
OUTfLOM DITCH /
IAPPROJ(JHA TEI / SH3S
~-✓ 'i) .r-6H2◄ /SW33
/
/ ""'"" "'"'"'°' v>~· / Ol TCtl IA.PPflOllMA.TEI
o Cl
00
Figure 7.3
Pond Locations
I I
uncontrolled area would provide a higher long-term degree of protection for human health and would minimize the need for ongoing operation and maintenance (O&M) activities and land use restrictions. Alternatives involving long-term management of the soil in-place or in a disposal unit would require more extensive monitoring and maintenance and reliance upon land use and access restrictions to adequately protect human health and to assure the continued effectiveness of the remedy. ·
Removal of soils exceeding the cleanup standard for designated non-residential land usage represents a substantially reduced risk to human heal th and the environment. A minimum one-foot vegetated soil cover would further reduce risk by providing both a barrier against potential exposure and dilution of subsurface soils in the event of soil disturbance.
Both treatment and disposal were considered for final management of contaminated soils. Land disposal results in some risk of future release from the disposal facility as long as the dioxin remains in the environment. Thermal treatment of contaminated soil destroys dioxin to undetectable levels, permanently removing the contamination from the environment and eliminating the need for continuing maintenance or monitoring of the treated material.
8.1.1.1 Protection of the Environment:
The primary environmental concern at the Site is in the surface water of the onsite Fire Pond and the offsite Medlin Pond. These surface water bodies are not in violation of the Federal Ambient Water Quality Criteria (AWQC, EPA, 1986), however, EPA screening values were used in the development of acute and chronic toxicity quotients for qualitative risk evaluation with respect to the ecological receptors. The chronic toxicity quotient for dioxin in the Fire Pond indicates an area of high concern and an area of possible concern for dioxin in the Medlin Pond.
The placement of clean fill into the pond areas will reduce or eliminate the existing potential for further environmental impairment. The fill will eliminate future ponding and the potential of future surface water to become contaminated. The fill also renders the residual dioxin contamination in the sediments biologically unavailable by creating anaerobic conditions. The continued integrity of the soil cover would not be critical for maintaining the effectiveness of the remedy. Future contamination degradation and mixing of soils through natural processes is expected to further reduce residual contaminant concentrations and the potential for environmental impairment.
8.1.1.2 Protection of Human Health:
In this document, EPA establishes a cleanup level for soils contaminated with pentachlorophenol and PCDDs/PCDFs at the Koppers
Koppers Draft ROD
August 1992
Page 50
Company Site. A cleanup level of 95 ppm for pentachlorophenol and 7 ppb for PCDDs/PCDFs has been recommended for the protection of public health based upon the non-residential land usage of the site. These levels were established for the protection of groundwater, but are protective levels for dermal contact as well. The Agency believes that the continued non-residential usage of the site is assured based upon the current land development trend, the price of real estate in the immediate vicinity and the current zoning restrictions on adjacent properties. This is a practical consideration of the existing conditions of the area known as Research Triangle Park, in North Carolina.
In-place containment of the contaminated soils would attain the objective of reducing surface concentrations to an acceptable level. Moni taring and maintenance requirements would be more extensive than for alternatives involving the removal of contaminated soils. Eventual replacement of the cover or cap may become necessary. Land use restriction would also be necessary to protect the soil cover and prevent possible human exposure in the event of cover failure. In the event of cap failure, there would be potential for offsite migration and human exposure.
Land disposal of the contaminated soils in a permanent facility meeting RCRA design criteria would provide a higher degree of protection to public health and the environment than in-place containment alternatives. There would be some risk of release due to failure of the disposal facility. This risk should be minimal if the disposal facility is properly designed, constructed and maintained. Regular monitoring and maintenance would be required to assure the continued integrity of the land disposal facilit1 . Access restrictions would also be required to protect the disposal facility and prevent possible human exposure in the event of a facility failure.
An increased short-term risk associated with soil-disturbing activities is associated with all of the alternatives involving excavation and handling of dioxin-contaminated soil. This short-term risk is due to potentially contaminated dust which could be created during excavation activities. Mitigative measures, such as dust suppression, are available to control this potential risk.
Thermal treatment alternatives represent technologies which have achieved destruction of dioxin in soils to undetectable levels. These alternatives provide the greatest level of long-term protection of human health and the environment of the soil alternatives evaluated in the feasibility study because the toxicity, mobility, and volume of contaminated materials would be substantially reduced in comparison to the containment alternatives. -
Ongoing monitoring and maintenance requirements are less for alternatives involving removal of contaminated soils than for in-
Koppers Draft ROD
August 1992
Page Sl
place containment alternatives. The removal of soils exceeding the cleanup standards are protective of human health for the industrial scenario. Since soils exceeding cleanup standards are removed, the continued integrity of any subsequent cap or soil cover is not essential to maintain the effectiveness of the remedy. Inplace containment alternatives require critical maintenance for effectiveness.
The protection afforded by the dechlorination alternative for soils, which involves onsite treatment is questionable. This is due to the unknown effectiveness regarding the dechlorination of PCDDs/PCDFs. The use of solvent material also generates a new waste which would require a residuals disposal plan. The toxicity, the volume, and the potential RCRA classification of these residuals cannot be adequately defined at this time.
All alternatives involving transportation of contaminated soils to an offsite location for treatment or disposal would require special considerations to assure the short-term protection of human health and the environment during transport. These considerations include the method of containment and transport of contaminated soil, transportation routes and scheduling of hauls.
All alternatives, with the exception of "No Action", involving the treatment of groundwater are considered protective of human health. This is primarily due to the intent to conduct mass removal of the contaminants from the aquifer, thereby ultimately restoring the groundwater to drinking water quality.
8.1.2 Compliance with Applicable or Relevant and Appropri~te Requirements
Section 121 ( d) of CERCLA, as amended by SARA, requires that remedial actions comply with applicable or relevant and appropriate requirements or standards (ARARs) under Federal and State environmental laws. Such a standard or requirement must be attained if it is determined to be either directly applicable or both relevant and appropriate. Some of the requirements discussed in this section are directly applicable to a particular aspect or component of a remedial alternative. Other requirements are identified as being both relevant and appropriate to a remedial alternative. Both of these categories of requirements constitute ARARs and must be attained by the remedial alternative.
Three basic types or ARARs exist, Action-Specific ARARs, Location-Specific ARARs, and Chemical-Specific ARARs. Table 8.1 identifies potential federal action-specific ARARs for this site. Tables 8.2 and 8.3 list the potential federal location-specific and chemical-specific ARARs for the site. Potential State ARARs are identified
Koppera Draft ROD
August 1992
Page 52
CONSOLIDATION
WITHIN a UNIT
CONTAINER STORAGE
Table 8.1
POTENTIAL ACTION-SPECIFIC ARAlu
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRJSVILUl, NORTH CAROLINA
P JI h
Coataincn of RCRA hazardou1 wuaca
mull be:
-Mai.nlainod in good condition;
-Compatible with bazardoua waAtc lo
be .. .,, ... , and
-Cloecd during Uoragc: (e1cc:pt lo add
or remove waatc).
When RCRA hazardou• wuta arc
moved into or ow of an area of
contamUWion,RCRAdiapou.l
rcquitc:mcot1 arc applicable lo
lhc w .. c: being managed and
certain lrc:almcnl, lloragc, or
diapol,al requirement.a arc
applicable: lo the area receiving
the wutc. (Ea. Cloaurc:)
Storage of RCRA wutc, (lilted or
charactc:ri■ic) not mccting •mall
q11Anlitiy generator criteria held
for • temporary period greater
thu 90 ct.ya before lreatmc:ol.
dispoul or lloragc: dacwhcrc:
(40 CFR 264.10) in a container.
A gcnc:rator wbo accumulalca or
llloree haurdoua Walle on-ailc
for 90 daya or leu in c.omp.lWlcc
with 40 CFR 262.34(a)(I~) i, no1
aubjcct to foll RCRA 110,agc:
requirement,. Small quanliry
gcncracon arc noc aubjoct lo
lhc 90 day limil (40 CFR 262.34
(c), (d). and (e)).
Citatioa
40 CFR 264. 171
40 CFR 264.172
40 CFR 264 173
Table 8.1 (cont.)
POTENTIAL ACTION-SPECIFIC ARA!u
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORJIISVILLE, NORTH CAROLINA
Rapd
lupoct COlllaiAa IIWragc area wcclly
r .. -.
Pla0o eoatalDora oo a alopcd, crack-free
but, Md protoct from COOlacl with any
KCumulatcd llquida. Provide conllinmcnt
aytlem wllh a capacity of 10'1 of the
volume of wotaincn of free hquid1.
Keep coat&iocr1 of ignitable or reactive
waetc ct lcut SO fed Crom the
facililica property line.
Keep incompaliblc malcriala ac:p,iratc.
Sc:puatc iocomplliblc material■ atorcd
near ~b other by a dike or b.arricr.
IV da.u.rc, remove all haz.ardoua wutc
and raiduc:. from the containmenl ayatcm
wl docoateminatc or remove all
container■, linera.
Storage of banned wutca muat be in
accordance with 40 CFR 268. Whc.n auch
atora1c occun bcyood one year,
the owner/operator beau the burden of
proving thal auch lloregc ia aolcly for
the purpoae of accumulating aufficicnt
quanliha lo allow for proper recovery,
lrcatmcnt, and diaPowJ.
Pnn,quwu,o Ciblioo.
40 CFR 264.174
40 CFR 264.175
I I
40 CFR 264.176
40 CFR 264.177
40 CFR 264.178
40 CFR 268.50
..,....._..
Table 8.1 (cont.)
POTENTIAL ACTION-SPECIFIC ARAa.
FORMER KOPPERS COMPANY. INC. SITE
BEAZER EAST. INC.
MORJUSVILLE, NORTH CAROLINA_
DISCHARGE of TREATMENT BEST AVAILABLE TECHNOLOOY
SYSTEM EFFLUENT Uoo of-available locboology (BAT)
cnwxnk:elly acbkv.hlc LI required to
COlllrol &ollC ud QOGCOGYCOl.ional
pollutaab. Uao or belll coovcnhoaal
pollUlolll .-ml 1ocboology (BCT) ;.
required to c:oalrol coa.vmtioaal
poll ....... T ocboology bual limiuliom
may be dderminod OG e cue-by-cue
buia.
WATER QUALITY STANDARDS
Applicable Federally approved, State
waler qllalily llaodardt mu• be complied
wilh. Thcac llandar<t. may be in
-.ddilii?D,Jo or more llringcnl than other
Federal IW>dardo under lhe CWA.
BEST MANAGEMENT PRACTICES
Dcvdop and implemcal • Beat Managcmc:nt
Practice Prosram to prcvcnl the rdcue
or toxic corutilutmu of concc:rn to
surface waten.
The 8e,t Managcmenl Practice Program
m~:
-Ealabliah apccific pniccdurca for lhc
control of toUC and bu.ardou1
pollutanl 11piJl1.
Poinl IOUrce diachargca lo walcrs
of the United Slates.
(Any water body or wdJand.
CERCLA on-1ilc eclivit.C. arc
c,;cmpe from pcrmining
rcqullcmc:nt1. but mull med the
lelcbniul rcquircmcn11 of
applicable rcgula1ioo1.)
Oitchargc lo walcn; of lhc U.S.
(CERCLA on-1itc aclivilica arc
c1cmp1 from permitting
rcquircmcnb, bul mull meet the
lochnical rcquircmeot1 of
applicable rcgulatioo1.)
Citatioa.
40 CFR 122.44 (a)
40 CFR 122.44
and St.ate reg•
approved under
40 CFR 131
40 CFR 125.100
40 CFR 125 104
I I
Table 8.1 (cont.)
POTENTIAL ACflON-SPECIFIC ARAlu
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
,..,.. 2J
-ladudo a prodictioa of I.be dircctioo,
-of Dow, ud Idol quantity of
&oUC pollutaata where capcricGcc
mdka&m ■ roeeooehlci potcolial for
.,..._ falluro.
-AMurapropc, ...... 1cmm1orao1id...i
bazantoua wutc la accordance with
rcaulatioou promulpod uadcr RCRA.
MONITORING REQUIREMENTS
Oiacbargc mml be IDOllitorcd to uaurc
compliance. DiKbarac wW monilor:
-Tbc mau of each poUutan1;
-Tbc volume of efflumt;
-T~ f(Oqucncy of diKhllrgc and other
mc:auromcatl u appropriate.
Approved tcial mcthoda for ~ilueol
to be moaltorcd mull be followed.
Detailed roqui:rcmcnta for analytical
procodurm ud quality control■ arc
provided.
Sample prcacrvation procedure,.
container material■, and maximum
allowable holding lime, arc: prcacribcd.
Comply wilh addilionaJ 1uh11tanli\'c:
condi1iona auch u:
P,-aoquuiloo
I I
40 CFR 122.41 (i)
40CFR IJ6.I-IJ6.4
40CfR 122.41 (i)
DISCHAROE IO PUBLICLY
p I I •=
Table 8.1 (cont.)
POTENTIAL ACTK>N-SPECIFIC ARARa
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTII CAROLINA
Pracquiailm
-Duty lo mitipac any lldvenc cffccu
al uy dlocwgc; and
-Propor opandoo ud m11Ncoencc of
troaballlml .., ....
Diacbugc of poll...,... lllal puo
OWNED TREATMENT WORKS through lhc POTW wilhoul trcatmcat,
Indirect diachargc of pollutant.
1o POTW.
(POTW) inl«fcrc with POTW opcr110oo,
(Off 1itc activity) coalaminate the POlW IIYdgc, or endanger
bealth/ufd)' of POTW work.en ia
prohibited.
Specific prohibihoo1 preclude the
diachargc of pollulaPI• lo POTW1 that:
-Craatc • fire or explosion hu.ard in
lhc POJW;
-Will c.uac corro1ivc ltruclural change
loPOTW;
-Ob•ruct Oow rcaulting in
interference;
-Arc diKhargcd al • Oow rate and/or
COOCCllllatioo I.hat will rcaulf in
interference; and
Citation
40 CFR 403.5
PLACEMENT of WASTE
in LAND DISPOSAL UNIT
Table 8.1 (cont.)
POTENTIAL ACTION-SP6CIFIC ARAR.
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
...........
-~ the temperature of wutewatcr
-.ta11hotralmallplaatlhal
would rNUlt in inlcrfcrcoce, but in
DO c&N niac tbc POTW influcal
.._... .. abovo 104 F (40 C).
Dlaollarp ,... comply with local POTW
.,...._..... prolfll.m, iAcludiog
POTW-,pocific poll ...... , ,pill
prcvadioa proaram requirement.a, and
report.lag and mooiloring roqullcmcnta.
RCRA permit-by-rule roquircmcoll
(including corrective achoo where the
NPDES permil •u iuuc:d after
N<Wcmbcr I, 19M) muat be complied
with. f'!r diacbarga of RCRA hazardous
WutCI to POTW■.
LAND DISPOSAL RESTRICTIONS
Altaio lond di"P<-! • .,_....,.
llaaduda-before putting wutc into
landfdl 10 wmply wilh land ban
ralrk:tiom. A trcatmc:nl llandard cu
be; • conccntrllioo lcvd lo be achieved
(performance buod), or a apccif&ed
lcchnology that mum: be uacd (technology
bated.) If the llandard is performance
baaed, any technology can be uKd 10
achieve the llAndarda. (Sec Trcalmcnl
when WHlc will be land Di!>pos«.I.)
Transport of RCRA ha.r.ardou1 wUlc
to POTW, by truck.. rail, or
dodicalcd pipe (40 CFR 264) which
diacbargc:a from within the
CERCLA ■ilc to within lhc
boundartcl of the POTW.
Placcmcn1 of RCRA haz.ardoua wutc
in a landfill, aurf.ce
impoundmcnl, WUIC pi.Jc,
injection wdl. land 1rca1mcn1
faciliry, •all bed or MIi dome
formalioa, or underground mine or ~Ye
for which LOR• have bcco promulglllc.J.
Citation
40 CFR 403.5
I I
40 CFR 270.60
40 CFR 268 (D)
TANK STORAOE (On-SIio)
TREATMENT in a UNIT
Table 8.1 (cont.)
POTENTIAL ACTION-SPECIFIC ARAlu
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
a.,,, :,
TUlU au bavc auffacic:at alrength lo
emurc tbat dloy do DOt rupture or ---
Tub muat bavc IOCODduy coalolinmcnt
and wffic-h-ooi,oard IO p,cvCld
ov«Row by wave action.
-Repair of cnck, or lcab.
-AJ clOM1rc, .U bazardoua wutc and
wuac reaidlie mLl.11 be clcaood from tank.
(Additional rcquirc:mcou •ill be included
if tbia bocomc:a an altcmativc.)
Ocaign and opcraling ltud.rd• for unil
in•~ bua.rdou, waac ia lrc.atcd.
(Sec citaiom for dcaiga and opera.ling
roquiremcob for apccific unit,.)
Pnn,quiua
Storage of RCRA hazardou, wa&ac
not mocting 1mall quanhty
generator cr&leri.l.
Trcalmc:nl o( ha.tardoua walk:
in• unil.
Citatioa
40 CFR 264. 190
40 CFR 264. 191
40 CFR 264. 10
40 CFR 264. 193-194
40 CFR 264. 196
40 CFR 264.197
40 CFR 264. 190
-264.192 (Tanu)
40 CFR 264.273
(I~ Trcalmcnl Unila)
40 CFR 264.001
....................... (Miac. Trca1mcnt Unila)
I I
TREATMENT
(Wloal•-•Wbc
IMd di.po.cl.)
I I I
Table 8.1 (cont.)
POTENTIAL ACTION-SPECIFIC ARAlu
FORMEII KOPP£11S COMPANY, INC. SITE
BEAZER EAST, INC.
MOIUUSVILUi, NORTII CAROLINA .
..............
T--of -,ui,_loct to boa oa
IMd d._i -llltUD lovd,
--by BOAT fo, -=h bourclouo
Diapoeal of IIOIDC lmpactod aoil
and dcbria n»lllling from CERCLA
~ action, or RCRA
corn:ctivc action, it DOf aubjcct ....... bl w.11 IUIGd wuto.
to land diapoeal prohibilioaa
UDlil May I, 1992. No LOR,
have bcal aubliabc:d for
F032todau:.
Cllalioo
40 CFR 268. 10
40 CFR 268.11
40 CFR 268.12
40 CFR 268.41
I I
I oc,bcm
Table 8.2
POTENTIAL LOCATION-SPECIFIC ARARs
l'ORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORJlJSVILLE, NORTH CAROLINA
Pren,qui1ilca
Action to prohibit diacbarge or dredged
or fill material into wotlanda without
Wetlands 1& defined in US Army
Corps of Engineers regulations.
• perm.ii.
Fcdenl
Citation
Clean Water Act
section 404;
40CFR 230
33 CFR 320-330
Action to avoid adverse effects, minimize
potential harm, and preaerve and enhance
wetland&: to the extent possible.
Action involves construclion of 40 CFR Part 6,
facilities or management of Appendix A
property in wcll1nds, as defined
by 40 CFR 6, Appcndi• A, section 4(j).
(Note: 40 CFR 6, 1ubpart A aeu forlh EPA policy for carrying out lhc provisiOD1 or E<cculivc Orders I 1988 (Floodplain M1n1gcmcnl)
1od 11990 (Protection or Wotlanda). E~O!,Outivc Order■ are binding oo lhc level (e.g., redcral, sute) of govcrnmcnl for which Ibey
arc iasued.)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Area affecting aueam Action IO protect fiab or wildlifo.
or river.
Diversion, channeling or other
aclivity that modifies a stream
or river, aod affects fish or
wildlire.
16 use 661 er seq.
(fish & Wildlife
Coordination Acl);
40 CFR 6.302
I I
RCRA M■1im11m
Cane. Limila
Cm.Ii-of Coacem (MCL&)
PbeDol•
Phenol (Total)
2-Chloropbenol
2-Nitropbenol
2,4-Dimcthylphcnol
2,4-Dichloropbenol
4-Chloro-3-Methylpbenol
2,4,6-Tricbloropbenol
2, 4-Dinitropbenol
4-Nitropbenol
2,J,5,6-Tetr1chloropbenol
2-Methyl-4,6-Dinitropbenol ·
Penlachloropbenol
Dio}(u,s aod Furans
2,3,7,8-TCDD
Table 8.3
POTENTIAL CHEMICAL-SPECIFIC ARARs
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
SDWA SDWA SDWA NPDWR
NPDWR Muimum NPDWR Muimum Socrolary Muimum
Coolaminant Contaminant Level Contaminant Level
Levola (MCL&) Goela (MCLGs) Levels (SMCLs)
0.001 mg/L (1)
5.00E-08 mg/L (1)
(a) SDWA, NPDWR, MCLs (Effective 1-27-92); 55 FR 30445, 7-25-90; to be codified at 40 CFR 141.61.
SDWA-S.fe Drinking Water Act
NPDWR-National Primary Drinking Water Regulations
CW A-Freshwater Water Qualiry Criteria, from EPA Integrated Risk lnformati~ System
CWA
Frubw1ter WQC
Acute I Chronic
ug/L ug/L
10,200 2,560
None None
None None I I
2,020 365
None 970
None None
in Tables 8.4, 8.5, and 8.6.
Action Specific ARARs
Action-specific requirements are technology-based and establish
performance, design, or other controls related to the management of
the wastes associated with the Site.
Location-Specific ARARs
Location-specific ARARs are standards or criteria which may affect
the types of remedial alternatives or technologies used to
remediate a site due to the location of the site. These ARARs
consider any restrictions which may be present at the site and the
area surrounding the site, which may require special consideration
during the remediation. Types of locations-specific ARARs include
regulations protective of wetlands, scenic rivers, and endangered
species.
Chemical-Specific ARARs
Chemical-specific ARARs are usually risk-based standards or
criteria which may affect the types of remedial alternatives used
to remediate a site. Maximum contaminant levels as identified
under the Safe Drinking Water Act are examples of chemical-specific
ARARs.
The following summaries are provided with respect to media.
8.1.2.1 Soils
There are no federal or state chemical-specific ARARs for the
contaminants detected in the soils. There are no action-specific
ARARs for Alternative S-1. RCRA requirements for Alternative S-4
(capping) may be relevant and appropriate. Alternatives S-5, S-7
and S-8 would be required to comply with Land Disposal Requirements
(LDRS) through a Treatability Variance for the contaminated
soil/debris. S-9 may also be required to comply with LDRs. The
Treatability Variance does not remove the requirement to treat
restricted soil/debris wastes, they allow the establishment of LDR
standards on actual data collected form the Site. LDR treatment
levels would be met for the soils/debris and for any sludge or used
activated carbon generated by the treatment or processes.
8.1.2.2 Groundwater
MCLs and North Carolina standards are ARARs for Site groundwater.
Alternative GW-1 would not comply with ARARs.. Alternatives GW-3,
GW-4 and GW-5 woul~ attain ARARs throughout the contaminant plume.
Construction of the groundwater recovery, treatment, and discharge
system for each of these alternatives would satisfy action-specific
Table 8.4 -potential State-action specific ARARs for the site
Kopper11 Draft ROD
Augu11t 1992
Page 63
I,
Crilmria. OI' I leM:edoe
North CarollDO Solid OAd
Haunloua Wuic Mano-Ad
North Carolina Solid WUlc
Maaagcmcna Rcaulaliou
North Carolina Hazardoua Wutc
Managcmcftl Com.miuioo Ace
North Carolina Oil Pollutioa
and Hu.ardoua Subll&Dcc
Con1rol A.ct
North Carolina Water
Pollution Control Regulation•
Table 8.4
POTENTIAL ACTION-SPECIFIC ARAlu (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
DmcripdoD
Eaablilhca regulatiom for band.ling
and dltpoMI of con•ructioa dcbriJ,
lrub, dudgc, and haz.ardouA wa•e.
Alao rcgulatca recycling and
proceuina of thcac mal.crial,.
Rulca governing the managcmcol or IOlid
wutc. Jocludca llorage, collcclion,
lranaport&lioo, and diapoeal of
IOlid wut.c.
Eatabli&hu regulation• for ailing,
coa.llruction and opcralioo of TSDF5.
Eaablimca rcgulatioa1 proccciing the
land and watcn Oli'cr which the St.ate
ha, jurisdiction rcgardUlg oil
product& Md other hazardoua
aubatancc.a.
Eatabliahea NPDES pcrmil roquiremcnu
and fees, fur discharges 10 waler,
of 1hc ltlatc.
Cillll.ioo
G.S. 130A, Article 9
15A NCAC 138
I I
G.S. 1308
G.S. 143, Article 21 A
15A NCAC 211
--~-Crilcril, cw I leketioe
N .C. Waler Quality Slandard1
Efflucnl Guiddinca and
Standard• Appl icablc
lo Surface Wetcn
Table 8.4 (cont.)
POTENTIAL ACTION-SPECIFIC ARAR. (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Dcacrlj,doa
WASTEWATER DISCHARGES TO SURFACE WATERS
ltoquirce permil for the diact..rgc
of pollUIUltl into wlllcn of the
UallodS..U..
WASTE NOT DISCHAROED TO SURFACE WATER
Rcqulsa permit for .y.aema whicb
do noC diacbarac to .urfacc water
of the ltatc, inclLMlca acwcr ■yatem1,
trcalmcnt work.a, and dudgc diapoaaJ
ayllCm, wb.ich di.ecbargc wutc oalo or
bdow laod wrfa.ce.
WATER QUALITY CERTIFICATION
Rcquisca diM:h.ugcn 10 obtain ■
Ccniftcatc of Coverage, prior to
iuuancc of a diachargc permit.
STANDARDS FOR PRETREATMENT FACILITIES
Require.a permit for prdrcalmcnl
fecihlic, ditcharging WUIC lo.
Trcatmad Worka.
CLASSIFICATIONS AND WATER QUALITY STANDARDS
APPLICABLE TO SURFACE WATERS OF N.C.
Rcquirca apccifoc cfllucnl i;haraclcridlic5
for diachargc under NPDES pcrmill.
Citatioo
ISA NCAC 211.0100
ISA NCAC 211.0200
I I
ISA NCAC 2H.0SOO
ISA NCAC 211.0900
15A NCAC 1H 0100
Stoadanl. 11a .. ...,...,, __ ._
Crtkria, or I leltedcw
North Carolina Hazardoue
Wutc Mana1cmon1 Rcgulalioaa
Table 8.4 (cont.)
POTENTIAL ACTION-SPECIFIC ARARa (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CARO UN A
Doocnpioa
EFFLUENT LIMITATIONS
Roquira technology bued cffluc:nl
limiletiooe for pol.lutanta.
STORMWATER RUNOFF DISPOSAL
Eatabliahea rulce governing (he
managcmcml. of haz.rdou, w .. c wit.bin
I.he State.
IDENTIFICATION AND LISTING OF HAZARDOUS
WASTE
Ealablilhca criteria for iden1ifacacioa
of bau.rdou• w.utc.
STANDARDS APPLICABLE TO GENERATORS OF
HAZARDOUS WASTE
Eatabliabca llandardt for generator■
of haz.ardou1 WHlCI.
STANDARDS APPLICABLE TO TRANSPORTERS
OF HAZARDOUS WASTE
E.aablilhc:.a 11and1•rd1 applicahlc 10
lraruporten of haurdoua wucc within
the U.S.
Citauon
!SA NCAC 28.0400
!SA NCAC 211.1000
!SA NCAC llA
(40 CFR 262)
ISANCAC llA0006
(40 CFR 261)
ISA NCAC tlA0007
(40CFR 262.10-12)
ISANCAC IJA.0008
(40 CFR 20JJ
Table 8.4 (cont.)
POTENTIAL ACTION-SPECIFIC AllAlu (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRJSVU.U, NORTH CAROLINA
0-:rlj,<b
ST AN DAROS FOR OWNERS AND OPERATORS OF
HAZARDOUS WASTE TREATMENT, STORAGE.
AND DISPOSAL FACILITIES
Eaubliaboa minimum ale lllaodarda
for tbCI acceptable manage.meat of
bu.ardotal •uaea. for owncra and
opuuon of facihhc1 whk:h lrmt,
IWre or dllp()K of hazardous wutc.
INTERIM STATUS STANDARDS FOR HAZARDOUS
WASTE TREATMENT, STORAGE, AND
DISPOSAL FACILITIES
Eatabliaba IUilc llandarda for the
ID.I.UICmcol of hazardou.a wUlc during
the period of interim ... u• &Dd until
ccrtuw::11doo of final cla.urc or if
tbo facilily ~ tubja.1: to
po11-cla.urc rcquircment.1, uotil
poaa-cla.urc rcaponaibilitice arc
fulfdlcd.
LAND DISPOSAL RESTRICTIONS
Ettabliahca timetable for rcatrk::tion
of burial of wutc, and other hazardous
material■.
15A NCAC llA.0009
(40 CFR 2"4)
15A NCAC llA.OOIO
(40 CFR 265)
15A NCAC IJA.0012
(40 CFR 268)
Slwlud, R ; L ,.
Crtlcria, °" I 1,11...,_
North Carolina Drilwng Water
and Orouadwlltu SlaAdanb
North Carolina Scdimcntalion
Pollution Control Acl
North Carolina lnadivc:
Huardou1 Subllancca and
Waste Di&p0u.J Si1ea
Regulation,
Table 8.4 (cont.)
POTENTIAL ACTION-SPECIFIC ARAlu (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRJSYILLE, NORTH CAROLINA
HAZARDOUS WASTE PERMIT PROGRAM
Eatabllabca proviaiou covering baaic
EPA permitting requirement action,.
CRITERIA AND STANDARDS APPLICABLE TO WATER
SUPPLY AND CERTAIN OTHER TYPE WELLS
Ellablisbca rcgulatioru defaning
injcchoo wdla, and lhc conalruaiOO
and moniloring rcquircmcnla a .. ocialcJ
with lhcm.
Etlablidacd rc:gule1ion1 and conalruclion
crilc:ria for wdla, and rcgia1ra1ion
rcquirc:mcn11 for driller■.
Citatioa
ISA NCAC IJA.0013
(40 CFR 270)
ISA NCAC 2, 2C
0.200
ISA NCAC 2, 2C
(N.C. Wdl
Conatruc1ion Al.-t)
.0100
N.C. GROUNDWATER CLASSIFICATIONS AND STANDARDS ISA NCAC 2L .0100
Clauifw:alion• and water quality 0.200
lllandarda apphcablc: to groundwater 0. JOO
o( North Carolina.
Rcquirca the dcvdopmc:01 of c:ro1ion
and .cdimcnl conlrol plan, for land
dilturbing activitiea.
Requires rcaponaiblc: p,artica to
provide: nocificalion, lo NCDEII
and public, of propu -.oJ
remedial aclionJa. Al•) c:Jal.ahli!ihc~
a. bile ranlling i;yi.lc:m
G.S. I IJA, Artidc: 4
15A NCAC IJC
(G.S. IJOA290 OIOI.
Artidc: 9)
I I
:,
Criteria. or I leftlCkw
Rocyclablo -.i. Uoal
la • Manw ron,ttr,111n1
Dilf><-I
NC Air PoUulioa Coatrol
RoquilcmmU
Table 8.4 (cont.)
POTENTIAL ACTION-SPECIFIC ARAlu (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
Eubliabcd rcguJatiotu which
apply to recyclable material•
thal uc applied to or placed
oo the land.
Eatabliabca ltatc air pol.1Lllion
wauol policy.
Citation
15A NCAC I JA 0011
(40 CFT 266.20)
15A NCAC 20.0200
I I
SbuJdanl ~
Criltril, a, I imUPtioo
North CarolUIII laacdvo
Huardoua Silao ""'
North CaroU..u Land Policy Act
Table 8.5
POTENTIAL LOCATION -SPECIFIC ARAlu (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORRISVILLE, NORTH CAROLINA
0-riptioa
Roquirca rcaporuiblc partaca 10
provide notiflC&lioa to NCDEH
and public of propoecd remedial
Ktionl. AJIO catabliahca •
1ilo ranking 1y1tem.
E.atabliahca • Slaae policy 10 give
local govcrnmcnu guidance and
Ulillance in the catablilhmcnl and
implcmcntalioa of local land
planning.
GS. 130A, Article 9
G.S. IIJA, Article 9
I I
•
Table 8.6
POTENTIAL CHEMICAL-SPECIFIC ARARs (NORTH CAROLINA)
FORMER KOPPERS COMPANY. INC. sm
BEAZER EAST, INC.
MORRISVIl.LE. NORTH CAROLIN A
CluaWS ,CluaC
Groundwater Surf..:c Water Surf..:c Water
Maximum Mu.imum Mu.imum
CxttemiMot Coat■min■DI: Comamin,m
Coaltituc:at1 of Coocern 1..evci. (MCt..) Levela (MCu) Levela (MCu)
Pbeaols
2-Chlorophcnol 0.0001 mg/L (a)
Pcntachlorophc.nol 0.22 mg/L (a)
T ota.l phenol 1.0 ug/L (b) (d)
Dioxins
2,3,7,8-TCDD 2.20E-10 mg/L (a) 0.000013 ng/L (b)' (d)
(a) 15A NCAC 2L.0202 {Water Quality Standard.).
(b) 15A NCAC 28.0211 (Sland&rdo for Toxic Sub......, &nd Tcmpenture io WS clua wu,n) .
. (c) 15A NCAC 28. pp. 24, 25. (W-Quality Standard, for Frcahwatcr Cluaca).
(d) Unapecificcl.lcvela. lluod oa tdq,hoac conversation, with North c.roliaa DiVilioa
of Envin>ameulal aw,agemcm. lite 1Urfacc .,...,. dilchargc to Crabtroc Creek (acar
iate.....:tioo of Route 54 &nd Cow,ty Rood 1002). Crabtroc Creek at thi, location, ;.
Identified u Clua C-NSW watcn. R.gulatloa 15A NCAC 2B.021 I. pongraph (b)
doca not apccify qll&lltitatlvc llaw fOT pba,oiic c:<>mpound, or dioxim (OT Clua C .,...,._
• Meuund u PQL.
Standarda for all Frcahwatcr
Aq.-Life Human Health
0.000014 ng/L (c)•
ARARs. The . disposal of any sludge or spent activated carbon
generated by the groundwater system would also comply with ARARS.
Final discharge of the treated water would comply with the
substantive requirements of the National Pollution Discharge
Elimination System.
8.1.2.3 Surface Water
The No Action Alternative SW-1, would not comply with any of the
known ARARs associated with the surface water contamination.
Alternatives SW-3 and SW-4 would comply with location-specific and
action-specific ARARS. Treatment of the surface water of
Alternatives SW-3 and SW-4 would result in compliance with the
State of North Carolina chemical-specific ARARS. Final discharge
of the treated water would comply with the substantive requirements
of the National Pollution Discharge Elimination System.
8. 1. 2. 4 Summary
The following potential ARARs have been identified and evaluated
for remedial alternatives in this Record of Decision:
o Resource Conservation and Recovery Act
o Clean Water Acts
o Federal and State Clean Water Acts
o Federal and State Transportation Laws and Regulations
o Clean Air Act
o National Pollution Discharge Elimination System
These ARARs would have the most impact on the selected remedy.
More complete discussions of the potential ARARs are presented in
the feasibility study for the site.
Onsite actions, such as the disposal of structures and debris, are
exempt from the need to actually obtain a State, (administrative
requirement). Nonetheless, all onsite actions would be required to
meet all substantive requirements of any and all identified ARARs.
8.2 Evaluating Criteria
8.2.1 Cost:
The benefits of implementing a particular remedial alternative are
weighed against the cost of implementation. Costs include the
capital up-front costs of implementing an alternative over the long
term, and the net present worth of both capital and operation and
Koppers Draft ROD
August 1992
Page 72
maintenance costs. Again, the components of the remedy are broken out by media·and are presented in Table 8.7:
8.2.2 Implementability:
EPA considers the technical feasibility (e.g., how difficult the alternative is to construct and operate) and administrative ease (e.g., the amount of coordination with other government agencies that is needed) of a remedy, including the availability of materials and services.
8.2.2.1 Soils
No implementation is needed for the No Action alternative. Construction of the cover or cap (Alternatives S-3 and S-4) would pose no significant difficulties. Alternative S-7 would require an additional treatability study to assure achievement of Site-specific remedial goals and ARA.RS. Treatment units are available and site conditions are suitable for on-site treatment. Review of literature for this treatment technology suggests that it may not be effective on PCDDs and PCDFs. Alternative S-8 would require test burns.
8.2.2.2 Groundwater
None of the alternatives pose significant concerns regarding implementation. Final design of the treatment systems for Alternatives GW-3 through GW-5 can not be completed until discharge requirements are defined.
8.2.2.3 Surface Water
None of the alternatives pose significant concerns regarding implementation. Final design of the treatment systems for Alternatives SW-3 and SW-4 can not be completed until discharge requirements are defined.
8.2.3 Short-Term Effectiveness: The length of time needed to
implement each alternative is considered and EPA assesses the risks posed to workers and nearby residents during construction and implementation.
8.2.3.1 Soils
Alternatives S-1, S-3, and S-4 could be implemented without significant risks to on-site workers or the community and without adverse environmental impacts. The principal short term impacts of implementing Alternatives S-5 through S-10 is the potential exposure of workers during excavation and the handling of contaminated soils.
Koppera Oraf~ ROD
Auguat 1992
Pago 73
8.2.3.2 Groundwater
All of the alternatives can be implemented without significant risk
' .\\ i i Table 8 .7 > ..
.. . Soil Alternatives.·
Sl -No Action
S3 -Surface Cover
S4 -RCRA Cap
SS -On-site Landfill
S6 -Off-site Landfill
S7 -On-site Dechlorination
SB -On-site Incineration
S9 -Off-site Incineration
Sl0-On-site Storage
I
.. Grouhdwater•Arterriatives >I
GW-1: -No Action
GW-3: -Extraction,
Bioremediation, Surface
Water Discharge
GW-4: -Extraction, Carbon
Adsorption, Surface Water
Discharge
GW-5: -Extraction, UV/OX,
Surface Water Discharge
I ·••surface·· w~ter• ri £~i-ri11.tivel
SW-1: -No Action
SW-3: -Pond Destruction,
Carbon Adsorption, Surface
Water Discharge
SW-4: -Pond Lining, Carbon
Adsorption, Surface Water
Discharge
Roppera Draft ROD
Auguat 1992
Page 74
$ 0
$ 1,326,000
$ 1,477,000
$ 2,170,000
$ 816,000
$ 3,000,000
$ 3,432,000
$ 2,141,000
$ 659,000
$ 0
$ 5,100,000
$ 4,031,000
$ 5,133,000
II Fir~ Pond i•·•• ·· i IIMedliJ:J. Pond I
$ 0 $ 0
$ 1,300,000 $ 695,000
Total $ 1,995,000
$ 952,000 $ 710,000
$ 1,662,000
to the community or on-site workers and without adverse environmental impacts.
8.2.3.3 Surface Water
All of the Remedial Alternatives could be implemented without significant risks to the community or on-site workers. The potential impacts on the environment from implementation of Alternative SW-3 includes the removal of wetlands and the natural habitat for fish and wildlife by the destruction of the Fire Pond. This impact will be countered by a wetland mitigation plan which will restore wetlands in a portion of the area.
8. 2. 4 Long-Term Effectiveness: The alternatives are evaluated based on the alternatives' ability to maintain reliable protection of public health and the environment over time once the cleanup goals have been met.
8.2.4.1 Soils
Alternative Sl would not be effective in reducing contaminant levels in the groundwater. Alternatives S-3 and S-4 could be effective in the long term through regular maintenance of the cover or cap, but. a review of the remedy would be required every five years since a cap or cover is not considered to be a permanent remedy and leaves wastes in place that are above health protective levels. Alternatives S-7 through S-9 call for treatment of the contaminated soil and therefore, result in the highest degree of long-term effectiveness by permanently reducing the Site risks. Alternative S-7 has not been shown to be effective for PCDDs and PCDFs. Alternative S-10 does not provide long-term effectiveness or permanence since on-site storage would be on a temporary basis until better technology is developed.
8.2.4.2 Groundwater
Under Alternative GW-1, groundwater contamination would continue to migrate off-site, therefore the No Action Alternative would not be considered a permanent or effective remedial solution. The contaminant concentrations in the groundwater will be permanently reduced through groundwater extraction and treatment specified in Alternatives GW-3 through GW-5.
8.2.4.3 Surface Water
Under the No Action Alternative, surface water contamination would remain in the surface water, therefore, this is not considered a permanent or effective remedial solution. Contaminant concentrations in the surface water would be eliminated by either Alternative SW-3 or SW-4. These alternatives are considered to be effective on a long-term basis and permanent.
8.2.5 Reduction of Mobility, Toxicity, and Volume: EPA evaluates
Itoppero Draft ROD
Auguet 1992
Page 75
each alternative based on how it reduces (1) harrnfu1 nature of the contaminants; (2) their ability to move throughout the environment, and (3) the volume or amount of contamination at the site.
8.2.5.1 Soils
Contaminant levels would remain unchanged for Alternatives S-1, S-3, S-4, S-5, S-6, S-7 and S-10. Alternatives S-3 and S-4 would not reduce the toxicity or the volume of the contamination, but would reduce the mobility and therefore the effective toxicity may be reduced. Alternative S-5 may reduce the mobility of the contamination. Alternative S-6 would permanently reduce the mobility of contamination in soils at the site; volumes and toxicity remain unchanged. If effective, Alternative S-7 would reduce the toxicity and mobility of the contaminants in the soils. Since the effectiveness of this treatment has not been demonstrated for PCDDs/PCDFs, the reduction of overall toxicity, mobility and volume for Alternative S-7 is unknown. Alternatives S-8 and S-9 would effectively reduce the toxicity, mobility and volume of site contaminants in the soils. Alternative S-10 would reduce only the mobility of the contaminants in the soils.
8.2.5.2 Groundwater
Alternative GW-1 would not significantly reduce the toxicity, mobility or volume of contaminants in groundwater. Alternative GW-3 through GW-5 would reduce the volume of contaminants in the aquifer through recovery. The groundwater treatment systems will comply with the statutory preference for alternatives that reduce toxicity of contaminants.
8.2.5.3 Surface Water
The implementation of Alternative SW-1, No Action, would not reduce the toxicity, mobility or volume of contaminants in the surface water. Alternatives SW-3 and SW-4 eliminate the contamination in the surface water.
8.3 MODIFYING CRITERIA
8.3.1 State Acceptance:
EPA requests State comments on the Remedial Investigation and Feasibility Study reports as well as the Proposed Plan, and must take into consideration whether the state concurs with, opposes, or has no comment on EPA's preferred alternative. The NCDEHNR has reviewed and provided comments on the reports and data from the RI, the FS and the Baseline Risk Assessment. The NC-DEHNR has also reviewed the Proposed Plan and EPA's preferred alternative and presently tentatively concurs with EPA's selection. Final evaluation of State acceptance will be conducted at the conclusion of the public comment period. EPA anticipates State concurrence
Koppers Draft ROD
Auguat 1992
Page 76
with the selected alternative.
8.3.2 Cnmmnn,ity Acceptance:
To ensure that the public has an adequate opportunity to provide input, EPA holds a public comment period and considers and responds to all comments received from the community prior to the final selection of a remedial action. Some of the concerns that have been raised by the community to date regarding the Proposed Plan are quite altruistic in nature. The community has stated emphatically that they would not want to just ship their problem off and create the same problem for another community. The members of the Clean Water and Environment Project have requested demographic information, copies of permit application(s), as well as available information on the concerns that have been expressed by the local community regarding the Coffeyville, Kansas facility. Another main comment has been a desire to use the dechlorination treatment technology for the contaminated soils at the site. Fianl evaluation of the community acceptance of the preferred alternative will be conducted after the public comment period ends. A response to each comment is (will be) included in a Responsiveness Summary which is (will be) a part of the Record of Decision (ROD) for the Site.
9.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the National Contingency Plan, the detailed analysis of alternatives and public and state comments, EPA has selected a multi-component remedy for this site to include source control for contaminated soils, groundwater and surface water remediation. At the completion of this remedy, the risk associated with this site has been calculated to be within the accepted risk range which is determined to be protective of human health and the environment. The total present worth cost of the selected remedy is estimated at $17,000,000.12
The selected remedy is protective of human health and the environment, is cost-effective, attains ARARs, and utilizes permanent solutions and resource recovery technologies to the maximum extent practicable. Additionally, because this remedy employs thermal destruction to eliminate the principal threat at the site, this option also satisfies SARA's preference for remedies which utilize treatment as their principal element . to reduce toxicity, mobility and volume.
12 The cost figure currently represents estimations based on a greater volume of soils. This amount was identified in the comparison of alternatives. The final version of the ROD will represent revised cost estimates.
Kopper• Draft ROD
Auguat 1992
Page 77
9.1 Source Control
Source control remediation will address the contaminated soils at the Site. Contaminated soils located in the former process and lagoon areas will be excavated and transported to a permitted offsite incineration facility. Excavation will be conducted on all soils contaminated with greater than 95 ppm of pentachlorophenol and/or 7 ppb of dioxins/furans. Costs associated with this component of the remedy are approximately$ 11 milllion. This cost is based on a volume of 5000 yds3 • EPA believes the volume could be greater, however modeling indicates that the volume should not exceed 10,000 yds3 •
Additional soil characterization may be required, either before excavation begins or as part of 'the excavation process, to more accurately define the lateral and vertical extent of soil to be excavated. It is anticipated that excavation would be accomplished using conventional excavation equipment and earthmoving techniques.
Following excavation and removal of the soils, clean fill would be placed in all excavated areas. A minimum of 1 foot of clean fill will be required. Areas will be graded and revegetated to achieve desirable surface drainage patterns.
The contaminated soils will be transported to an offsite permitted facility and incinerated. The facility permit must allow the treatment of KOOl and FO32 wastes. Compliance history of the facility will be reviewed prior to · transporting the material. Hazardous waste manifests will be required for the transport of the materials.
Upon completion of incineration, the residual ash would be disposed of at a secure landfill and would be the responsibility of the operator of the incineration facility.
9.1.1 Excavation Standards
Excavation shall continue until the remaining soil and material achieve the following maximum contaminant levels. All excavation shall comply with ARARs, including, but not limited to OSHA and North Carolina standards. Testing methods approved by EPA shall be used to determine if the maximum contaminant levels have been achieved.
Pentachlorophenol
Dioxins/furans
95 ppm
7 ppb
During the Remedial Design phase, additional maximum contaminant levels may be developed for minor contaminants at the site.
Koppers Dratt ROD
August 1992
9.2 Groundwater Remediation
Groundwater remediation will address the contaminated groundwater at the Site. Groundwater remediation will include extraction of contaminated groundwater, treatment and final discharge to surface water. The treatment technology will be carbon adsorption. Discharge of treated water will be to the nearest viable surface water body. All applicable regulations associated with the National Pollution Discharge Elimination System will be complied with.
It is believed that groundwater at the Koppers Site occurs in the weathered bedrock unit (10 to 30 feet bls) underlying the surficial sediment deposits and in the lower fractured bedrock aquifer. Recharge is supplied to the fractured aquifer by leakage from the overlying semi-confining bed in the residual soil. Water producing fractures decrease in size, frequency, and interconnectedness with increasing depth. Water-bearing fractures in the bedrock were generally encountered at depths ranging from 30 to 55 feet below ground surface.
The current design of the pumping strategy consists of one main groundwater extraction well which is located in the onsite plume. Extracted groundwater is expected to contain pentachlorophenol, dioxins/furans, and phenolic compounds. During the Remedial Design and/or the Remedial Action, assessment of the effectiveness of the existing extraction well will be made. Additional extraction wells will be added if necessary.
The treatment of the groundwater would consist of equalization·, filtration for removal of suspended solids, and carbon adsorptivn of dissolved organics to required discharge levels. A more detailed description is provided in Section 7.0 of this decision document.
9.2.1 Performance Standards
9.2.1.1 Extraction Standards
Groundwater will be extracted from the plume using the existing extraction well PW-1. This well is located adjacent to the former lagoon area. The groundwater flowrate to treatment is not expected to exceed 10 gallons per minute. To accommodate the need for potential future additional groundwater pumping, treatment system components will be designed to treat 50 gallons per minute of groundwater.
9.2.1.2 Treatment Standards
Groundwater shall
concentration levels
compliance points.
~cppera Draft ROD
Auguat lH2
be treated until the following maximum are attained at the wells designated by EPA as
,,-< } i ;TABLE-• 9.1.••--· i"•\ . --~j6i \site contaminants:
Pentachlorophenol
Dioxins/furans
I::._. . TABLE 9.2
Minor Site Contaminants
phenol
2,4-dichlorophenol
2,4-dinitrophenol
2,4,6-trichlorophenol
2,3,5,6-tetrachlorophenol
2,3,4,6-tetrachlorophenol
9.2.1.3 Discharge Standards
1.0 ppb
5 • 0 x 10 -5 ppb
_i
4200 ppb
20 ppb
14 ppb
3.0 ppb
210.0 ppb
210.0 ppb ..
Discharges from the groundwater treatment system shall comply with
all ARARs, including, but not limited to, substantive requirements
of the NPDES permitting program under the Clean Water Act, 33
U.S.C., 1251 et seq., and all effluent limits established by EPA.
9.2.1.4 Design Standards
The design, construction and operation of the groundwater treatment
system shall be conducted in accordance with all ARARs, including
the RCRA requirements set forth in C.F.R. Part 264 (Subpart F).
9.3 SURFACE WATER REMEDIATION
The surface water contained in the onsite Fire Pond and the offsite
Medlin Pond will be removed by pumping and treated by carbon
adsorption and discharged to the nearest viable surface water body.
All applicable regulations associated with the National Pollution
Discharge Elimination System will be complied with.
The surface water would be treated by mobile, truck-mounted carbon
adsorption units. Diversion channels and berms will be constructed
to minimize the amount of rainfall draining to the ponds during
dewatering. Clean soil will be used to backfill the ponds. After
dewatering and backfilling are completed, final grading of the pond
areas to control surface drainage will be conducted. Final
revegetation will be maintained to provide long term sediment and
erosion control.
Approximately one acre of wetlands would be eliminated in the Fire
loppora Draft ROD
Auguat 1992
Pond area with this component of the remedy. In accordance with applicable North Carolina and Federal ARARs, a mitigation plan would be developed and implemented. This work may involve the creation of new wetlands or the expansion of existing wetlands at a nearby location.
9.3.1 Discharge Standards
Discharges from the groundwater treatment system shall comply with all ARARs, including, but not limited to, substantive requirements of the NPDES permitting program under the Clean Water Act, 33 U.S.C., 1251 et seq., and all effluent limits established by EPA.
9.4 COMPLIANCE MONITORING
Groundwater, treated soils and surface water monitoring shall be conducted at this site. After demonstration of compliance with Performance Standards, the Site including soil and groundwater shall be monitored for five years. If monitoring indicates that the Performance Standards set forth in this Record of Decision are being exceeded at any time after pumping has been discontinued; extraction and treatment of the groundwater will recommence until the Performance Standards are once again achieved. If monitoring of soils indicates that Performance standards are exceeded, the effectiveness of the source control component will be re-evaluated.
10.0 STATUTORY DETERMINATION
Based upon available information, the selected remedy satisfies the remedy selection requirements under CERCLA, as amended by SARA, and the National Contingency Plan. The remedy provides protection uf public health and the environment, is cost-effective, utilitzes permanent solutions to the maximum extent practicable, and satisfies the statutory preference for remedies involving treatment technologies.
10.1 Protection of Human Health and the Environment
The selected remedy for the Site will provide a high degree of protection of human heal th and the environment. For soils, no other alternative, with the possible exception of onsite incineration, offers an equivalent degree of overall long-term protection. The soils remedy selection will eliminate all onsite potential exposure pathways associated with soils. The groundwater component of the remedy will significantly reduce contaminant levels within the aquifer. An alternative drinking water supply has been made available to the immediate area to include approximately 4 miles of water lines. This action was taken under an Administrative Order on Consent in 1989. The potential for a private drinking water well to contain levels of contaminants which exceed the maximum contaminant levels has been substantially reduced; this potential will be further reduced upon implementation of the groundwater extraction system by disallowing the plume to
Kopper• Draft ROD Auguat 1992
migrate further.
10.2 Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will be designed to meet all Federal or State
ARARs. No waivers of State or Federal requirements are anticipated
for this site. The Federal and State Maximum Contaminant Levels
will be achieved throughout the plume. Incineration of the soils
will be required to meet the six-nines rule, as defined in 40 CFR
266.104(a)(3),(e). Final disposal of the ash will be required to
meet all land disposal restrictions.
10.3 Preference for Treatment
The selected remedy satisfies the statutory preference (established
by SARA) for remedies involving treatment which result in the
permanent reduction of the volume, toxicity, or mobility of
hazardous substances. Thermal treatment destroys the dioxin and
pentachlorophenol contamination, therely eliminating the toxicity
associated with the contamination in the soil. Mass reduction of
contaminants in the groundwater by extraction and treatment will
also satisfy this statutory preference.
10.4 Cost Effectiveness
The selected remedy provides a greater level of protection and
permanence for the soils at the site within the same relative cost
of the other alternatives evaluated. This greater level of
protection and permanence causes the soil remedy selection to'be
cost effective.
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
CERCLA Section 117(b) requires an explanation of any significant
changes from the preferred alternative presented in the Proposed
Plan. The EPA has selected a multi-component remedy consisting of
excavation and treatment of contaminated soils, groundwater and
surface water remediation. The major components of the remedy
identified in the Proposed Plan are identical to the description in
this Record of Decision. Minor components were discussed at the
July 23, 1992 Public Meeting, but were not explicitly identified in
the Proposed Plan Fact Sheet. These minor components consist of
the following items:
Groundwater Confirmation Sampling -sampling of the monitoring
wells will be conducted. Select private wells will be included
in the sampling. Methodology will be clearly selected and
approved by EPA prior to sampling commencement, and will be
required to meet all appropriate detection limits and data
quality objectives defined by the EPA. Re-evaluation of the
plume may be necessary under Remedial Design.
Kopper• Draft ROD
Auguat 1992
Soil Excavation Confirmation Sampling -sampling of the soils must be conducted to ensure that all soils which exceed the cleanup standards identified for pentachlorophenol and PCDD/PCDF, 95 ppm and 7 ppb, respectively. Confirmation sampling will also be required of the sediments of both ponds prior to covering with clean fill to ensure that the soil cleanup standards are not exceeded.
A perimeter fence to enclose that area of the site property which will require remediation will be installed. Signs noticing the public of a Superfund Site will be posted on at least two places on the fence, one along Koppers Road side and one along Highway 54 side.
Additional changes may be incorporated into this Decision Document based on any potential changes EPA deems necessary in response to significant community or state comments.
lopper• Draft ROD August 1992
DIVISION OF ENVIRONMENTAL MANAGEMENT
July 23, 1991
M E M O R A N D U M
To: Perry Nelson
Through: Arthur Mouberry, P.E(?
From: S.Jay Zimmerman '7~
Subject: Kopper's Co., Inc. -NPL Site
Morrisville, NC, Wake County
Review of Remedial Investigation
Project #91-44
The Raleigh Regional Office Groundwater Section has reviewed
the subject document and has the following comments at this time:
1. Proposed cleanup standards for the subject site should
not exceed those allowed at 15A NCAC 2L .0202 prior to
receiving a written variance from the Director of the
Division of Environmental Management.
2. Detection limits for the detected compounds should not
exceed the Standards established at 15A NCAC 2L .0202.
For any compound where a Standard has not been
established, the detection limit shall be the lowest
available limit.
3. All monitor wells installed at the facility shall be
permitted by the Division of Environmental Management
in accordance with 15A NCAC 2C.
Should you have any questions, please contact me at your
convenience.
AM:SJZ
KOPPERS
' '
July 15, 1991
TO: Arthur Mouberry, P.E.
Regional Supervisor
THROU~Donnelly, P.E.
/~gional Water Quality Supervisor
FROM: Car~Stephens
Envi~bnrnental Technician
SUBJECT: Review of the Koppers Company, Inc. NPL Site
Morrisville, Wake County
Remedial Investigation Report
Project ij91-44
The Water Quality staff of the Raleigh Regional Office has
reviewed the subject project. The need for proper permits and
requirements leading to the attainment of such permits must be
reiterated.
As long as the proper channels are followed during the
remediation project, at this time, no water quality problems are
foreseen.
DIVISION OF ENVIRONMENTAL MANAGEMENT
AIR QUALITY SECTION
RALEIGH REGIONAL OFFICE
July 24, 1991
MEMORANDUM
TO: Arthur Mouberry
Regional Supervisor
THROUGH: Ken Schuster;Jl_ __ ,,,.,
Regional Air Quality Supervisor
FROM: Mark Feltner/fl'{-
Environmental Technician V
SUBJECT: Koppers Company, Inc. NPL Site
Morrisville, Wake County
Project #91-44
I have reviewed the subject document and it does not directly state any
air quality concerns nor does the document state any sources of air emissions
and/or express any significant air quality impacts to warrant ,further review.
Possible air quality concerns include particulate, volatile organic compound,
and air toxic emissions, both fugitive and point source from site clean-up
activities. All air pollution control devices employed at the site would
require permittingJand soil venting, or groundwater stripping projects would
require State registration as per 15A NCAC 2D .0202.
MF/jf
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
July 1, 1991
MEMORANDUM
TO:
FROM:
Arthur Mouberry, Regional Supervisor
Raleigh Regional Office
Perry Nelson, Chief ORIGINAL SIGNED BY
Groundwater Section PERRY r: .NELSON
SUBJECT: Request for Review and Comments on the Koppers
Company, Inc. NPL Site
Moorisville, Wake County
Remedial Investigation Report
Project #91-44
Attached is the documentation on the referenced project
submitted to this Division, for review and comment, by the
Division of Solid Waste Management.
You are requested to have someone from each of the Air
Quality, Groundwater and Water Quality staffs in your office
review the project and provide comments. The Central Office
Section staff will also have an opportunity to review the
addendum.
The Groundwater Section has been assigned
responsibility for coordination of Di vision comments, so
your regional comments and the application package should be
sent to my attention no later than August 1, 1991. If
additional time is needed to complete the regional office
review, please contact Jack Floyd.
Attachments 4:r L .1iJ!:-' fcrf? I PN/sbp/KOPPERS. L ~ ') cc: Jack Floyd c~I w~ L~) G!W toM 1--
---
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
July1,1991
MEMORANDUM
TO:
FROM:
Arthur Mouberry, Regional Supervisor
Raleigh Regional Office
Perry Nelson, Chief ORIGINAL SIGNED BY
Groundwater Section PERRY F. NELSON
SUBJECT: Request for Review and Comments on the Koppers
Company, Inc. NPL Site
Moorisville, Wake County
Remedial Investigation Report
Project 1/91-44
Attached is the documentation on the referenced project
submitted to this Division, for review and comment, by the
Division of Solid Waste Management.
You are requested to have someone from each of the Air
Quality, Groundwater and Water Quality staffs in your office
review the project and provide comments. The Central Office
Section staff will also have an opportunity to review the
addendum.
The Groundwater Section has been assigned
responsibility for coordination of Division comments, so
your regional comments and the application package should be
sent to my attention no later than August 1, 1991. If
additional time is needed to complete the regional office
review, please contact Jack Floyd.
Attachments
PN/sbp/KOPPERS.
cc: Jack Floyd
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MEMO.
TO€£~<
DATE:
SUBJECT• ____ _
RALEIGH REGIONAL OFFICE
. 1 . • North Carolina Deportment of Natural
Resources &Community Development
MEMORANDUM
TO:
FROM:
RE:
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
March 20, 1987
Lee Crosby
CERCLA Unit, Division of Health Services
Perry Nelson ~
Groundwater Section, Division of Environmental
Management
Groundwater Contamination At Koppers Co., Inc., Wake
County
In reference to the meeting held on March 19, 1987, please
keep me informed of all matters pertaining to the occurrence
and investigation of groundwater contamination in the vicinity _____ _ --of· Koppers cc,i:--I1ic~--------------·---· ·· ···-· · ·· ·--· ·---------··· ---..... ---
-Our file to date consists of monitoring well logs for MW-1
through MW-12; boring logs for B-1 through B-15; analytical
results of soil samples RN67-RN96 collected on 9/26/86; and
analytical results of groundwater samples collected during the
period 9/9/86-9/11/86 ... Please provide us with any ad_ditional
information which will enable us to assess the existing and
potential environmental impacts associated with groundwater
contamination at the above referenced facility.
If you should have any questions regarding this request,
please let me know. Thank you for your assistance.
PFN/bjg
cc: _Incident Files
I .it>.';/"'"' . . . .,., .... srM'""' ~~-i~'•,.•:•-,,·.• , _-.;1;~ ,..., ,... [ C, ~ ~1,1 • , •• ·,' ....... _ "'' -~Jtf. . ' ,_c!~_ /,ii r ' ~ ,.,,,\ r:.wJ> •·· · · -.. -·--: !•.lj ,, ~!r;l'.'r,:~' is--· ···r, 'l~}ji~ . APR 1 7 1987 ![,/
.,,;::::,;:.:/ GROUND \'l'AiEr< ::iECTIDN
. North Carolina Department of Human Resources RALEIGH, N. C.
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
Bhillipr,l~,y Ronald H. Levine, M.D., M.P.H.
State Health Director
David T. Flaherty
Secretary
MEMORANDUM
TO:
From:
SUBJECT:
April 15, 1987
Pat DeRosa
Solid and Hazardous Waste Branch
CERCLA Unit
Ted Taylor, Ph.D., Toxicologist<
Environmental Epidemiology Branc~
Koppers Company -Off-site Groundwater Investigation
I have reviewed the OHS laboratory results taken from 13 wells surrounding the
Koppers Company at the Morristown site. Two chemicals used in the Koppers
wood-treating process, isopropyl ether (IPE) and pentachlorophenol (PCP),were
found at variable, but very low, concentrations in a number of the wells.
Five samples were completely negative; the Crowe, John Medlin, Roy Medlin,
Louis Barbee residences and the Deli Box. IPE was found in the wells of
Wilkinson Construction (trace), William Barbee (1.4 ug/1), L. A. Lyons (16
ug/1), and the Shiloh Baptist Church (28 ug/1); the minimum detection limit
✓' reported by EPA is 10 ug/1. The minimum detection limit for PCP by the EPA
derivatization method is reported to be 0.5 ug/1; however, the OHS laboratory
used a larger sample volume and was able to detect even lower concentrations;
The highest level of PCP detected was 0.02 ug/1 at the Shiloh Baptist Church.
Trace levels of PCP (less than 0.02 ug/1) were also found at the residences of
Baker, Harding, William Barbee, and at TMI, Wilkinson Construction and Watson
Burroughs. Thus, the water at the Shiloh Baptist Church represents the "worst
case" for the purpose of evaluation of any health risks associated with
drinking water that is contaminated with IPE and/or PCP._
In the case of IPE, no relevant toxicological.data are available on this
chemical as such; however, based on its structural similarity to diethyl ether
and to other ethers, the predicted toxicity of IPE would be expected to be very
DeRosa Memorandum
Page 2
April 15, 1987
low. Thus, based on the present information, our best judgment suggests that
the concentrations of IPE found in the four wells do not represent a
significant health risk to people who consume this water.
In the case of PCP, many relevant studies have been published which indicate
that the levels found in the 7 wells do not represent a significant health
risk. However, a very recent unpublished toxicity study suggests that PCP may
cause cancer in laboratory mice; PCP did not cause cancer in rats. Thus, if
the mouse study is found to be valid, some caution would be warranted when PCP
is detected in drinking water at elevated concentrations, i.e. in the parts per
billion range.
RECOMMENDATIONS
1. Although PCP apparently produced tumors in mice, the dose given to the
animals was hundreds of thousands times higher than the dose that would be
received from drinking well water in this area. Thus, at this time, based
on the available information, the water from the wells surrounding the
Koppers site does not represent a significant health risk; normal usage of
water for drinking, cooking, bathing, may continue.
2. Since IPE and PCP were admittedly used in the Koppers process and since
off-site contamination has been demonstrated, further monitoring of private
wells should take place (probably at least at six-month intervals for the
near future). This will assure that citizens are not exposed to
unacceptable levels of chemicals should the levels be found to be
increasing in the future.
If you have any questions, please feel free to contact me at 3410.
TT:lp
c: Bill Meyer, Head, Solid and Hazardous Waste Branch
).,'l'erry Nelson, Chief, Groundwater Section
Wally Venrick, Head, Public Water Supply Branch
Greg Smith, M.D., M.P.H., Environmental Epidemiology Branch
DIVISION OF ENVIRONMENTAL MANAGEMENT
April 10, 1992
MEMORANDUM
To: Perry Nelson
P.E. (/3 Through: Arthur Mouberry,
From: S.Jay Zimmerman SfY
Subject: Kopper's Co., Inc. -NPL Site
Morrisville, NC, Wake County
Review of Draft Remedial Action Plan Revision
Project #92-18
The Raleigh Regional Office Groundwater Section has reviewed
the subject document as requested and has no additional comments
other than those stated previously.
Should you have any questions, please contact me at your
convenience.
'AM:SJZ
KOPPERS4.doc
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MEMORANDUM
Division of Environmental Management
Raleigh Regional Office
March 31, 1992
TO: Arthur Mouberry, Regional Supervisor
THROUGH: Ken Schust~ AQS Regional Supervisor
FROM: Mark Feltner~QS Env. Tech. V
SUBJECT: Koppers, Inc., Wake County
Project #92-18
With respect to the subject document, there appears to
be no significant Air Quality concerns observed. Hence, no
further Air Quality review is deemed necessary at this time.
., ,,...-
APRIL 24, 1992
MEMORANDUM
TO: Arthur Mouberry
THROUGH,¢)Tim Donnelly J
FROM: Daniel Rowe'
Subject: Koppers, Inc.
Remedial Investigation Report
Wake County
Project# 92-18
I have received the investigatory report concerning the
former Koppers Company, Inc. My primary focus was on the
concentrations of various parameters in surface waters and
the possible ecological impacts.
Surface water concentrations for various parameters
were determined on-site and off-site. The levels of various
parameters were most concentrated in Fire Pond and generally
decreased away from the pond.
The mammalian exposure evaluation concentrated on the
muskrat due to the fact that it is a constant resident of
Fire Pond. ·Deer were eliminated from the study due to land
disturbance by man, yet observations of deer were made
during the course of the study. The report outlines that
on-site use of the land and pond by deer is likely to be
low. The statement seems to be more assumption than fact,
and deer may possibly roam on-site with increasing frequency
and numbers during the night. If this is the case, concern
should be for the mammal at the top of the food chain,
"man".
Avian Studies were limited to the Kingfisher due to
it's trophic level and semi-migratory status. The study
pointed out that migratory birds such as ducks and geese are
at a lower trophic level and are not subject to as much
biomagnification of the two main hydrophobic parameters,
(dioxin and pentachlorophenol), as the fish eating
Kingfisher. The study fails to point out that the act of
feeding may stir up chemically impacted sediment that would
·be ingested by these migratory fowl, and once again possibly
transferred to the highest trophic level, "man", through
hunting and subsequent consumption. . --------
The study also fails to point out the possibility of
chemical pockets that may open up in time and leach to
surrounding surface waters. This would be of greatest
concern if adjacent land is developed further.
Exposure to the Koppers, Inc. site should be kept to a
minimum, .and remediation of the chemically impacted areas
should be considered for the future.
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 16, 1992
M E M O R A N D U M
To: Perry Nelson
Through: Arthur Mouberry, P.E. ~
From: S.Jay Zimmerman 7~
Subject: Kopper's Co., Inc. -NPL Site
Morrisville, NC, Wake County
Draft Remedial Action Plan Review
Project #92-10
The Raleigh Regional Office Groundwater Section has reviewed
the subject document as requested and has the following
comments:
1. System design should allow for the restoration of the
groundwater to the levels at 15A NCAC 2L .0202.
Cleanup of contaminated groundwater to a level
greater than that permitted at 15A NCAC 2L .0202
would be considered a violation, subject to the
enforcement provision's at North Carolina General
Statute 143-215.GA.
2. Although the document discusses at length the
cleanup of affected soils and groundwater to
levels established by ARAR's and RTBCL's, the
Groundwater Standard's should apply with respect
to contaminated groundwater. At the least,
application of the more restrictive standard or
cleanup level would provide the greatest
protection.
Should you have any questions, please contact me at your
convenience.
AM:SJZ
KOPPERS3
MEMORANDUM
Division of Environmental Management
Raleigh Regional Office
March 6, 1992
TO: Arthur Mouberry, R'J1ional Supervisor
THROUGH: Ken Schuster( AQS Regional Supervisor
FROM: Mark Feltner~'t.Qs Env. Tech. V
SUBJECT: Koppers, Inc., Wake County
Project #92-10
With respect to the subject document, there appears to
be no significant Air Quality concerns observed. Hence, no
further Air Quality review is deemed necessary at this time.
To:
From:
Subject:
March 19, 1992
MEMORANDUM
Arthur Mouberry
Steve Mitchell
Koppers, Inc.
Draft Remedial Action Plan
Project #92-10
Morrisville, N.C.
Wake, County
.The review of the information contained in Kopper's Draft
Remedial Action Plan, Project #92-10 has been completed.
The proposal to for remediation of the site contains nothing
applicable to the surface waters of the State. There are
some charts and lists of chemical contained in the Fire Pond
(on site) and the fish within the pond, but this would only
require remediation if the area was to be converted from
industrial to residential.
I have no negative comments or additions to offer after my
review.
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DIVISION OF ENVIRONMENTAL MANAGEMENT
October 2, 1991
M E M O R A N D U M
To: Perry Nelson
P.E. ~ Through: Arthur Mouberry,
From: S .Jay Zimmerman c;rc--
Subject: Kopper's Co., Inc. -NPL Site
Morrisville, NC, Wake County
Review Feasibility Study Report
Project #91-62
The Raleigh Regional Office Groundwater Section has reviewed
the first five sections of the subject document as requested and
has the following comments:
1. System design should allow for the restoration of the
groundwater to the levels at 15A NCAC 2L .0202.
2. All recovery wells installed at the facility shall be
permitted by the Division of Environmental Management
in accordance with 15A NCAC 2C.
3. Additional information will be necessary to determine
the effectiveness of the corrective action system and
to prove that the location of any recovery wells will
cleanup the groundwater and prevent furthur migration
of the contaminant plume.
Should you have any questions, please contact me at your
convenience.
AM:SJZ
KOPPERS2
DIVISION OF ENVIRONMENTAL MANAGEMENT
Air Quality Section
October 2, 1991
KKKORANDUK
TO:
THRU:
FROM:
Arthur Mouberry, P._E., Regional Supervisor
Ken Schuster, Regional Air Quality Engineer
Mark Feltner, Environmental Tech. V, Air Quality
SUBJECT: Koppers Co., NPL Site
Feasibility Site
Wake County
Project //91-62
I have reviewed the subject document and it appears to contain no
significant air quality concerns. Other than possible on site groundwater
remediation, i.e. air stripping, which would require source registration as
per lSA NCAC 2d section .0202. Otherwise, no further Air Quality review is
warranted at this time.
AM/KS/MF/gb
To:
From:
Subject:
October 3, 1991
MEMORANDUM
Arthur Mouberry
Steve MitchellS/Y\
Feasibility Study Report
Former Koppers company, Inc.
Superfund Site
Morrisville, North Carolina
Wake County
Project No. 91-62
The review of the information contained in Keystone
Environmental Resources, Inc. Feasibility Study, has been
completed. The draft proposal to implement remedial action
for the former Koppers Company glue-laminated wood products
plant appears to be entire and complete and I have no
negative comments or additions to offer after my review.
The three alternatives offered, 1) groundwater
collection, pretreatment and fluidized bed biological
reactor treatment with carbon polishing and surface water
discharge, 2) groundwater collection, pretreatment and
carbon polishing with surface water discharge, and 3)
groundwater collection, pretreatment and UV/chemical
oxidation treatment with carbon polishing with surface water
discharge would all provide permanent reduction of toxicity
and protect the environment and human health due to the
elimination of the constituents of interest.
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James C. lv1artin, Governor
William W. Cobey, Jr., Secretary
George T. Everett, Ph.D.
.Director
Regiun~I Of::~..:,
Ashcv.ille
704/151-6208
Fayenevil!e
919/486-1541
Mooresvilli:
7041663-1699
Raleigh
919/733-2314
Wa~hington
919/946-6481
\'v'ilmingion
919/395-39(X)
Winston.Salem
919/896-7007
October 18, 1991 RECEIVED
MEMORANDUM ocr 2 :i 19~1
Raleigh Regional Office
TO: Bill Meyer, Director
Division of Solid Waste Management
FROM: George T. Everett 6~
SUBJECT: National Institute of Environmental Health Studies
NCD2750890004
Class 3 Modification Addendum
Durham County
Project #91-57
The Division of Environmental Management has completed
the review of the subject document and offers no comments at
this time.
If there are any question·, please advise.
GTE/sbp/NIEHS.SWM
cc: Lee Daniel
Steve Tedder
[R_al~igh Reg_ioria_l Office
Central Files
Groundwater Files
State of North Carolina
Department of Environment, Health, and Natural Resources
< 'Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., Secretary
August 20, 1991 George T Everett, Ph.D.
Director
M E M O R A N D U M
TO:
FROM:
Lee Crosby, Head {:)
Superfund Section _/
George T. Everett, Director -~_,,_,c.-<,f-£.~---
Division of Environmental Mana,(emenj:)
SUBJECT: Kopper's Co. Inc. NPL Site
Morrisville, NC
Wake County
Review of Remedial Investigation
Project No. 179280-08
GW # 91-44
The Division of Environmental Management has reviewed the subject
addendum. The comments from our Water Quality, Air Quality and
Groundwater Sections are provided below:
Air Quality Section:
The subject document does not directly state any air quality
concerns, any sources of air emissions, nor does it express any
significant air quality impacts to warrant further review.
Possible air quality concerns include particulate volatile organic
compounds, and air toxic emissions which are fugitive and point
source from the site clean-up activities. All air pollution
control devices employed at the site would require permitting.
Soil venting, or groundwater stripping projects, require state
registration as per 15A NCAC 2D.0202.
Asheville
7041251-6208
Fayetteville
919/486-1541
Mooresville
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
919,946-6481
Pollution Prevention Pays
Wilmingtori
919/395-3900
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affinnative Action Employer
Winston-Salem
919/761-2351
RECEIVED
Water Quality Section: SEP 4 -1991
The need for proper permits and the requirements for attaining
such permit must be reiterated. n_a_;_[KiH Rf:'.f;!(,p,:~:. C;'·:-,C:,'.
As long as the proper channels are followed during the present
remediation project no water quality problems are foreseen.
Groundwater Section:
The proposed concentration levels for the targeted parameters
should not exceed the maximum allowable concentrations specified
in Rule .0202 of 15A NCAC 2L. The Division of Environmental
Management may require the clean-up to continue for groundwater
restoration to Class GA standards, a petition for a variance, or a
petition for a reclassification of groundwater.
All monitoring wells at the facility will be permitted in
accordance with North Carolina Well Construction Standards
15A NCAC 2C.
Should you need any additional information, please contact
Mr. Arthur Mouberry, Raleigh Regional Office at [phone].
021.RGE
cc: Perry Nelson
Steve Tedder
Lee Daniel
Arthur Mouberry
Nargis Toma
File
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