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HomeMy WebLinkAboutNCD122263825_19960528_JFD Electronics - Channel Master_FRBCERCLA RD_Response to Comments Pre-Final Design Report-OCRState of North Carola . 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 MEMORANDUM TO: David J. Lown Superfund Section FROM: Preston Howard--il r,b )))"' . May 8, 1996 SUBJECT: JFD Electronics/Channel Master Site Pre-Final Remedial Design Report Granville County Project #96-10 ..;:1~~ ~-----~~ DEHNR RECEIVED MAY 1 0 1996 SUPERFUND SECTION The Division of Environmental Management has completed the review of the subject document and offers the following comments and recommendations: Air Quality Section No comments at this time. Water Quality Section No comments at this time. Groundwater Section Monitoring well CMMW20 should be included in any monitoring plan. At least four (4) consecutive sampling events at/or below I SA NCAC 2L Standards should be conducted before closing the recovery wells. APHjr/baw/96-1 Ofin.doc cc: Alan Klimek Steve Tedder Raleigh Regional Office Groundwater Section Files I Groundwater Section, -W.: ~ Nike P.O. Box 29578, Raleigh, North Carolina 27626-0578 •~ 2728 Capital Blvd .. Raleigh, North Carolina 27604 Voice 919-733-3221 FAX 919-715-0588 An Equal Opportunity/ Affirmative Action Employer 50"/4, recycled/10"/o post-consumer paper ~8"GERAGHTY • AV& MJLLER, INC. JJil!Jf E11viro11me11tal Services Mr. McKenzie Mallary U.S. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, GA 30365 • a heidemij company April 10, 1996 RECEIVED APR 16 1996 SUPERFUND SECTION Re: Response to comments on the Pre-Final Design Report, JFD Electronics/Channel Master NPL Site Dear Mr. Mallary: Attached are our responses to USEP A,Bechtel and State of North Carolina comments to the Pre-Final Design Report (PFDR). These comments have been helpful in completing the final design. Nearly all of the commentors suggestions will be incorporated into the Final Design Report (FDR). The remaining key issues to finalizing the design addressed in our responses are summarized below: • Monitor Well Sampling Frequency -The state of North Carolina Department of Environmental Health and Natural Resources (NCDEHNR) commentor prefers quarterly sampling for an indeterminate time frame. Geraghty & Miller believes that after the first year of operations annual or semi-annual sampling should suffice until such time that a more frequent evaluation is justified such as the attainment of performance standards at the leading edge of the plume. In the PFDR we proposed annual sampling but will accept a revision to semi-annual sampling. • Water Level Measurement Frequency -The NCDEHNR commentor also prefers quarterly water level measurements throughout the entire life of the remedial system. A USEP A commentor also preferred more frequent water level measurements as well as continuous water level measurements· in unspecified wells until the water levels stabilize. Geraghty & Miller believes that the capture zones will stabilize in a relatively short time (months) which should be captured with a monthly water level measurement the first year. After the first year, water level measurements should not be needed more than semi-annually, unless the pumping rates in the recovery wells change significantly, at that time a more frequent measurement of water levels would be appropriate. Continuous water level measurements are not believed to provide significant additional information in the evaluation of capture zones. We agree to increase the water level measuring frequency to semi-annually after the first year. srd g:\aprojcct\jfdchann\nc0202.1 \0\commentsltesp-1tr,doc\l l-Apr-96 CrossPointe U, 2840 Plaza Place, Suite 350 • Raleigh, North Carolina 27612 • (919) 571-1662 • FAX (919) 571-7994 U GERAGHTY & MILLER. IN. • Mr. McKenzie Mallary April JO, 1996 Page2 • Air Monitoring During System Startup -The Explanation of Significant Difference (ESD) allows for measuring air emission levels at the air stripper and calculating the fence line concentrations. Given the fact that the calculated emissions are well below the permitting thresholds, we believe a tiered approach to determine ambient air conditions is appropriate. At startup grab samples will be collected at the stack and the fence line calculations performed. If calculated concentrations exceed the standards then fence line ambient measurement will be taken. We believe this approach allows for fine tuning the system in a cost effective manner that is also consistent with the suggestions of the ESD. With your concurrence, Geraghty & Miller and GMCE, Inc. will proceed with the Final Design. A revised PFDR not be submitted reflecting the changes noted in our responses. /smp Our responses to comment are provided in the following appendices: A. Response to Comments from Mr. R. Bernie Hayes, Region IV, USEP A B. Response to Comments from Mr. Donald Hunter, Hazardous Waste Section, Region IV, USEPA C. Response to Comments from L.E. Young, Bechtel D. Response to Comments from Wayne Underhill, Bechtel D. Response to DEHNR's Comments Respectfully yours, GERAGHTY & MILLER, INC. William H. Doucette, Jr., Ph.D., P.G. Associate and Project Coordinator for the Responsible Parties cc: Brian Kempner, The Unimax Corporation Lisa Palumbo, Avnet, Inc. David Lown, Superfund Section, NC DEHNR Greg Rorech, P.E., GMCE, Inc. Nanjun Shetty, P.E., G&M, Raleigh Arthur Anchors, P.E., POH srd g:\aprojcct~fdchann\nc0202.110\commcnts\tesp.ltr.doc\ I 2-Apr-96 • • APPENDIX A Response to Comments from R Bernie Hayes USEP A, Region IV on the Pre-Final Design Report ud g:\aprojectljfdchann\m:0202.110\i:ommef!'-'\resp-\.doc\l J-Apr-96 GERAGHTY & MILLER, INC. 0 • APPENDIX A • Response to Comments From Bernie Hayes USEP A Region IV GENERAL COMMENTS: Response: On behalf of JFD Electronics Corporation and Channel Master Satellite, Inc., Geraghty & Miller, Inc. (Geraghty & Miller) acknowledges that the proposed deep bedrock recovery well contributes approximately 2 percent of the flow. As recommended by United States Environmental Protection Agency's (USEPA), Geraghty & Miller proposes to monitor the bedrock aquifer to see if removal of the volatile organic compounds (VOCs) from the overlying strata have a beneficial effect on groundwater quality in the deep bedrock aquifer. Data from monitoring well CMMW14 will be used for this purpose. The bedrock recovery well DPW-1 will not be installed but will be included in the design as an optional component to be decided at a later date. However, piping for the recovery well DPW-1 will be installed for future use. SPECIFIC COMMENTS: 1. See page 3-2. While it may have been possible to obtain groundwater samples meeting performance standards for metals by careful sampling techniques designed to minimize turbidity in the samples, it is not the same thing as showing that dissolved metals are not present at concentrations above the standards. Unless filtered samples were obtained and analyzed, this statement should be revised to simply state that recent sampling events using revised sampling techniques have demonstrated that the performance standards are not exceeded. Response: The Final Design Report (FDR) will be revised to indicate that performance standards are not exceeded. 2. See page 4-2. My understanding is that the acronym PQL represents practical quantification limit, not permissible quantification limit. Response: We acknowledge the typographical error that PQL represents practical quantitation limit and not permissible quantification limit. This error will be corrected in the Final Design Report. 3. See page 4-3. While metals may not be present in groundwater exceeding performance standards, this does not insure that the discharge criteria for metals will be met without some type of treatment. If the metals concentrations previously observed are the result of turbidity, a simple, low-tech. approach to insuring that metals discharge criteria are met would be an in-line cartridge filter to remove excess suspended solids from the extracted srd g:l.aprojcct\jfdch.umw:0202.1 I 0"4:.ommcnts\resp-I .doc\l I •Apr•% 2 GERAGHTY & tvTILLER. INC • APPENDIX A • Response to Comments From Bernie Hayes USEPA Region IV groundwater. While it may not be necessary to include this in the design at this time, I would recommend including it as a contingency should it prove difficult to meet discharge criteria for metals. Response: While we do not anticipate the metals to exceed the discharge criteria the use of a cartridge filter would be an option if the metals were in particulate form. If the metals criteria is exceeded testing will be performed to evaluate and implement appropriate corrective measures; of which the use of a cartridge facility may be an option. 4. See page 5-9. Cyanide/iron complexes in the ground waters at this (or any) Site are not immobile, in the sense that they won't migrate in groundwater. In fact, ferrocyanide complexes are likely to be quite mobile in the groundwater system. The point here, however, is well taken, in that the ferrocyanide complexes will not volatilize from the air stripper and are not, therefore, a concern in the design of the air stripper treatment system. Response: No response required. 5. See page 7-1. First, in Section 7. I, I would recommend specifying that not only should EPA be notified of any changes in the groundwater monitoring program, EPA should approve those changes before they are implemented. Second, I would recommend that the water levels in the wells used to monitor potentiometric surfaces in the aquifer be monitored more frequently. In fact, I would put recorders in those wells to develop continuous water level records until such time as water levels stabilize in response to remedial extraction. In this manner, any short-term, anomalous changes in water levels that may occur in response to rainfall or other events will not be misinterpreted. Once the water levels have stabilized, the proposed sampling schedule could begin, i.e., quarterly sampling for one year and yearly sampling thereafter. Third, I recommend that the monitoring of water quality in the influent headers should be at the same time and at the same frequency as the influent to the air stripper. In that manner, the data from these two locations can be correlated to identify the source of any changes or trends in influent water quality. Response: Approval of modifications to the groundwater monitoring program will be solicited prior to implementation. Since the groundwater flow model, utilized to demonstrate capture, is a steady state model the frequency of water level collections is only necessary to evaluate the hydraulic response of the aquifer and to compare those results with that predicted by the model. Therefore, we do not think it is necessary to install continuous water level recorders on the monitor wells. It is correct that rainfall events will have an effect on the water levels and possibly interpretation of the data if it is not accounted for. When possible, collection of water levels will Sld g:\aproject\jfdctwmw:0202.l !Ch:omments\resp-\.doc\l l-Apr-96 3 GERAGHTY & MILLER. INC 6. • APPENDIX A • Response to Comments From Bernie Hayes USEP A Region IV be coordinated to minimize impacts from rainfall events. Regardless, in order to collect additional data for evaluation of hydraulic capture we would propose that water levels be collected monthly from the proposed monitor wells for the first quarter of operation, quarterly the remainder of the first year and semi-annually thereafter. Sampling of the influent to the air stripper is to evaluate system performance and not to determine where the contaminant mass loading is originating. We do agree that evaluations to determine where the mass loading is originating may help us operate the system more effectively. Therefore, we are proposing that samples be collected from the header of recovery wells PW-5A through 5C, and each of the other recovery wells initially at start-up, semi-annually the first year and annually thereafter. Depending upon the results more frequent sampling may occur. See page 7-3. The first sentence on this page seems to be too broad in its potential application. Recovery wells that meet remediation levels may be shut down, but it may also be necessary to continue to monitor them, and restore them to operation if contaminant concentrations increase. Additionally, situations may arise where even though groundwater quality in certain recovery wells may meet remediation goals, it may be desirable to continue pumping those wells to insure containment of the plume. In any case, the simple statement to the effect that recovery wells will be shut down once remediation levels are achieved may be too general. • Response: As indicated in the PFDR, Section 7.0 (page 7-3), recovery wells PW-3 and PW-4 are anticipated achieve performance standards sooner than other recovery wells. The recovery wells will not be shutdown based on one analytical set of results indicating contaminant concentrations to be. below the performance standard, but will be based on evaluating contaminant concentrations in monitoring wells (including upgradient and downgradient, if available) surrounding the recovery wells. A justification will be submitted to USEP A for approval prior to discontinuing operation of the recovery wells. 7. The PFDR should include figures that show the locations of monitoring wells to be used for performance standards verification in relationship to the extent of groundwater contamination and to the anticipated capture zones of the recovery wells. A figure showing wells used to monitor water quality, and a figure showing wells to be used in monitoring water levels, should both be included. Response: A figure was prepared (Figure 3-1, Approximate Plume(s) Delineation) but was found to be missing in the PFDR. This figure is enclosed for insertion in the PFDR report. ~ g:\aproject\jfdchann\nc0202. I IC71commcnblrcsp-l .doc\l l•Apr•96 4 GERAGHTY & MILLER. INC 0 • • APPENDIX A Response to Comments From Bernie Hayes USEPA Region IV 8. Please review my hand-written notes regarding design calculations in Appendix B. These comments are generally minor, but may be of some interest to you in assessing the overall design document. Response: No handwritten notes were provided. 9. As above, please review my hand-written notes regarding technical specifications in Sections 02672, 15101, and 15300 in Appendix D. These comments are likewise minor ones. Response: No handwritten notes were provided. I 0. See page 2-5 of the PSVP, Appendix H. It is not clear to me that amenable cyanide is the appropriate parameter for groundwater monitoring. To some extent, this may depend on the language of the ROD and other documents upon which the decisions regarding . remedial action are based. In general, however, drinking water standards and state ambient groundwater standards are based on total cyanide. While it may be true that amenable cyanide is a better measure of mobile cyanide (in terms of contaminant transport), it is not necessarily true that it is the best measure of potential exposure and health effects. Barring some pre-existing understanding on this issue, I would recommend monitoring for total cyanide. Response: Geraghty & Miller will correct the Performance Standard Verification Plan (PSVP) to reflect the measurement of total cyanide in the Final Design Report. The Federal drinking water MCL is based on free cyanide which is best measured by amenable cyanide. 11. See page 2-10 of the PSVP, Appendix H. Analysis for total metals should be the basis for determining compliance with performance standards. This section does not state whether both filtered and un-filtered samples will be analyzed, and if filtered samples are to be used, this filtering procedure is appropriate. Total metals should also be run, however, and should be the basis for determining compliance with remedial goals. Response: Experience with site sampling is that low flow rate sampling techniques should achieve a turbidity of <IO NTU' s. Filtering should not be necessary. The final design document will state that in the event a filtered sample is taken, an unfiltered aliquot will also be submitted for the same analysis as the filtered sample. ard g:lapmject\jfdchann\nc0201.110\oommcnts\selir I .doc\! I •Apr-96 5 GERAGHTY & MILLER, INC • • APPENDIXB Response to Comments from Donald Hunter Hazardous Waste Section USEP A, Region IV on the Pre-Final Design Report srd g:\aprojcct\jfikhann\nc0202.1 l~ts\r=p-2.doc\l l-Apr-96 GERAGHTY & MJLLER, INC. 0 • APPENDIXB • Response to Comments From Donald Hunter Hazardous Waste Section USEP A Region IV SPECIFIC COMMENTS: 1. Sec. 2.3.3/P.2-8 -ESD now recommends that turbidity also be measured during well purging to determine purge adequacy. We have found that when wells are purged using the lowest flow technique appropriate for the conditions, samples with low turbidity can usually be obtained. Many times the turbidities achieved are so low that sample filtering is not needed, and therefore, is not an issue. Response: Turbidity will be measured during well purging and sampling. 2. Sec. 2.3.3.1/P. 2-9 -ESD strongly recommends against using hailers for purging. The surging action of the bailer inevitably creates turbidity problems in the water column. We recommend sticking with low flow, steady rate pumps for purging monitoring wells prior to sampling. Response: The sampling procedures will be rewritten to exclude hailers as either a purging or sampling device. 3. Sec. 2.3.3.1/P. 2-10 -This section of the report does not contain specific procedures for actual sampling. It seems to move directly from purging to sample containerization. I would like to see specific sampling procedures in this section, i.e., bailing after pumping, peristaltic pump/vacuum jug assembly collection, etc. This needs to be included, with detail, in this document. Response: Specific procedures similar to those in the RD work plan will be added to section 2.3.3.1. 4. Sec. 2.3.3.1/P. 2-10 -This section appears to indicate that only filtered metals samples will be collected. We recommend that if filtered metals samples are collected, that unfiltered samples also be collected for evaluation purposes. As indicated earlier in these comments, if acceptably low turbidity is achieved, filtering may not be an issue. Response: If a filtered sample is taken an aliquot of unfiltered water will be submitted for identical analysis. This statement will be added to 2.3.3.1. s:cd g:\aproject\jfdch.annlnc0202.1 I ~bl.resp-2.docl 11-Apr•!ki 2 GERAGHTY fl MILLER. INC 0 • • APPENDIXC Response to Comments from L. E. Young, Bechtel, on the Pre-Final Design Report std g:'.aprojed\jfdchann\nc0202.I IC1lcommenb\rcsp-3.doe\l l•Apr•96 GERAGHTY & MILLER. INC 0 • APPENDIXC • Response to Comments From L. E. Young, Bechtel SPECIFIC COMMENTS: 1. Missing Figure 3-1, which is referenced on page 3-2. Response: Figure 3-1 entitled Approximate Plume(s) Delineation is enclosed. 2. Section 5.2.2, Page 5-6 (Bottom of first full paragraph): Do the calculations in Appendix B-4 also take into account the revised location of recovery well PW-3 (as indicated in Section 5. I. I)? Response: Yes, the revised location of recovery well PW-3 was also used in estimating influent contaminant concentrations to the treatment system (Refer to Figure I in Appendix B-4 in the PFDR). 3. Table 5-3: Process Stream No. 9 erroneously indicates a 300 gpm water flow. It is assumed that this is intended to be a 300 cfin air flow. Response: Process stream No. 9 (air flow) in Table 5-3 of the PFDR erroneous indicated as 300 gpm instead of 300 cfin. This error will be corrected in the Final Design Report. 4. Section 5.2.5, Page 5-10. The respondent needs to provide additional discussion, either here or in Appendix B-7, regarding the hydraulic design of the effluent discharge structure. Specific areas to be addressed include sizing of the rip-rap and the potential for erosion in the intermittent stream channel. Response: Attachment C-1 includes calculations demonstrating that the effluent discharge structure is larger than necessary to minimize erosion to the intermittent stream. These calculations will also be included in the Final Design Report. 5. Remedial Action Work Plan/Appendix E and Construction Quality Assurance Plan/ Appendix F. The respondent needs to incorporate a mechanism to solicit EP NNCDEHNR review and approval of significant design changes, for example, by the use of a field change request, and a mechanism for notification of EP NNCDEHNR when minor design changes occur, for example, by the use of a field change notice. Response: USEP A will be notified of any significant design change and obtain their approval prior to implementation. However, during construction of a remedial system, it is typical that field conditions change and require some modifications. As long as this modification will not affect the design or srd g:\aprojcct\jfdclwut¼IC0202. l l0\commc:ntsltesp-J.doc\l l-Apr-96 2 GERAGHTY & MILLER. INC • APPENDIXC • Response to Comments From L. E. Young, Bechtel operation of the remedial system, it is not practical to prepare field change notices for approval prior to implementation, which can delay construction and further increase the project cost. As built drawings with relevant changes will be provided in the construction completion report. 6. Performance Standard Verification Plan/Appendix H: Section 2.3.3.1. The respondent needs to provide the sampling protocol for the domestic well owned by Dr. C.B. Finch at 503 Lewis Road. Response: Specific procedures will be developed for sampling of the domestic wells owned by Dr. C. B. Finch at 503 Lewis Road. These procedures will be included in the FDR. 7. Performance Standard Verification Plan/Appendix H: Sections 2.3.3.1 and 2.3.3.2. Because of the historical indication of suspended sediment interferences with metals sampling, consideration should be given to measurement of turbidity during purging. Response: Turbidity will be measured and both sections revised to this end. 8. Section 2.3.3.2. A dissolved oxygen meter is called out in the equipment list, but is not mentioned in Section 2.3 .3 .1. The respondent should clarify if dissolved oxygen is to be measured, or the item should be removed form the equipment list if it is not to be measured. Response: Currently, no dissolved oxygen monitoring is planned. The dissolved oxygen meter will be deleted from the equipment list in the Final Design Report. 9. Section 2.3.3.3. The respondent should provide a decontamination procedure for reusable sampling equipment (e.g. hailers, purge pumps, etc.). Response: A decontamination procedure will be added to the FDR. I 0. Performance Verification Plan/ Appendix H and Operation and Maintenance Plan/Appendix I, Section 6.0. The respondent needs to expand upon the reporting items in these two plans, specific areas which need to be addressed are: • Comparison of modeled heads to observed heads • Hydrographs from water level monitoring wells • Concentration versus time graphs for monitoring wells and the extraction system • Comparison of predicted versus actual contaminant mass extraction • Graph of extraction rates over time srd g:l.tprojcct\jfdchann\nc0202. I l~ttlresp-J.dlx:\l l•Apr-96 3 GERAGHTY 6' MILLER. INC 0 • APPENDIXC • Response to Comments From L. E. Young, Bechtel These items represent key components for evaluation of system performance and should be presented in a format that is amenable to visualization of data trends. Response: Typically, the items listed in the comment are part of the routine system performance evaluation reports to be specified in the performance verification plan. These reports will be incorporated in the FDR to be prepared annually. 11. Operation and Maintenance Plan. The respondent needs to include a Sampling and Analysis plan and Quality Assurance Plan for sampling and analysis during system operation. Response: A sampling and analysis plan (SAP) and quality assurance plan (QAP) will be incorporated in the Operation and Maintenance Manual. The SAP and QAP are also components of the performance verification monitoring plan. srd g:\aproject\jfdchann\nd)202. I IO\commcntsfflp-3 doc\l l-Apr-96 4 GERAGHTY 6i' MILLER. INC. 0 • • APPENDIXD Response to Comments from Wayne Underhill, Bechtel, on the Pre-Final Design Report srd g:1.Aprojcct\jfdchann\rn:0202, l \O\commcnt.s\resp-4.doc\\ l-Apr•96 GERAGHTY & MILLER. INC • APPENDIXD • Response to Comments From Wayne Underhill, Bechtel SPECIFIC COMMENTS: I. P&ID symbology doesn't clearly represent the VO scheme. Example: As developed on the P&ID the panel lights are controlled by the handswitch but actually are turned on/off by the PLC digital output. Response: The intent of the design is to have the motor status lights operated by a report back contact and not from the control switch. The motor run indicating lights "YL" are operated from the associated motor starter auxiliary contacts. This signal is inputted to the PLC to operate the run status indicating light and to generate a low flow alarm to conjunction with the flow switch. 2. The PLC control logic will use the flow switches to shut down the associated pumps when a low flow condition occurs. Response: Upon system startup, the recovery well pumps will be adjusted to pump at a flow rate to minimize the cycling frequency. In addition, The PLC control logic will use the flow switches to shut down the associated pumps when a low flow condition occurs. 3. Drawings E-2 and E-3 indicate different service voltages 240 vs. 480. Response: The actual service voltage will be 120/240 volts 3 phase, 4 wire. Drawing E-3 will be corrected. 4. The MCC is rated 120/240V, 3 PH with Neutral bus but Dwg E-2 indicates 120/230V. Response: Drawing E-2 will be corrected to reflect 120/240 volts. 5. LP! is shown rated for 120/280V shouldn't this be 120/240V? Response: Panelboard LP I schedule will be corrected to show 120/240 volts, single phase. 6. LP I is shown as with "main lugs only" and "with main breaker"? Response: Panelboard LP I will be inside the motor control center. The panelboard will have a main breaker and the schedule will be corrected. srd g:\aprojcct\jfdclwm\nc0202.1 IO\commcnb\rcsp-tdoc\l l•Apr•96 2 GERAGHTY 6? MILLER. INC. 0 • APPENDIXD • Response to Comments From Wayne Underhill, Bechtel 7. GAC not shown on P&ID. Response: GAC is interpreted as granular activated carbon. GAC is not part of the treatment process and therefore, it is not shown on P&ID. 8. Why is pres-vac relief required on a vented stripper system? Response: It is a safety measure recommended by the vendor. 9. Electrical Cale. Section doesn't contain a load study, was this considered the utility's action? Response: An electrical load study will be included in the electrical calculation section of the FDR. 10. How did a 200A, 3 PH service get defined? Response: A 200 Amp service was defined in order to accommodate possible future expansion. 11. Spec 16155, para 2.01,B indicates starter enclosures to be Nema 4 stainless steel. Aren't the starter enclosures the MCC itself which is 3R? Response: The specification section referred to was for stand-alone combination motor starters. This section will be changed to allow NEMA 3R enclosures for these starters. 12. Spec 16155, para 2.01,F indicates that requirements for a 120V control transformer in each starter, isn't the I 20V fed from LP 1? Response: The control voltage for each starter shall be feed from a fused circuit feed from the motor starter breaker. · At 120/240 volts, control power transformers are not required. The specification will be revised. 13. Spec 16155, para 2.02,A-1 states that the MC wiring is to be Class I. What type A/B? Response: The specification will be revised to clarify in the FDR. 14. Major Equipment List, Table 1 doesn't agree with catalog cuts or pump specification page for pump models. Response: The major equipment list (Table 1) will be revised to match the catalog cut sheets in the FDR. srd g:\aproject\jfdcMM\nc0202, l 10\commenU'ltesp-4.doc\1 l-Apr-96 J GERAGHTY & MILLER. INC. 0 • APPENDIXD Response to Comments From Wayne Underhill, Bechtel 15. A wiring diagram should be provided to show a single Phase 3 wire motor connected to a three phase MCC starter. Response: The pump motors are 2 wire single phase. A note will be added to the motor control center clarifying that the associated well pumps are single phase. 16. Dwgs E-2 and E-3 disagree on indicated motor horsepowers. Response: Disagreements in motor horsepower were not found. However, a conduit schedule error found which will be corrected in the FDR. srd g:\aproject~fdchann\nc0202. I \~ommcnt.slrcsp-4 doc\! l-Apr-96 4 GERAGHTY & i'vTTLLER. lNC • • APPENDIXE Response to Comments from DEHNR on the Pre-Final Design Report srd g:\aproject\jfdchann\nc0202. l 10\commenl5\re,p--5.doc\l l•Apr-96 GERAGHTY & MILLER. INC ft \.J • APPENDIXE • Response to Comments From DEHNR USEP A Region IV SPECIFIC COMMENTS: I. Page 2.3, paragraph 4 and page 2 of Table 2-3. NCAC ISA: 2D. I 104 states that a facility shall not emit any of the toxic air pollutants listed in the rule in such quantities that may cause or contribute beyond the premises to any significant ambient air concentration that may adversely affect human health. The report states that based on modeling results using SCREEN2, the estimated ambient air concentrations for trichloroethylene, ( etrachloroethylene, and vinyl chloride are less than the acceptable ambient levels. Modeling results must be confirmed with air monitoring after the facility is in operation. Response: As indicated in the Explanation of Significance Difference (ESD), dated January 29, 1996, the fence line concentrations can be estimated using air emission levels at the air stripper. Therefore, Geraghty & Miller proposes to collect a grab sample from the air stripper exhaust stack once the remedial system is in operation. Based on the sampling results, air emissions will be modeled to estimate the fence line concentrations. 2. Page 3 .2, paragraph I. The first sentence of this paragraph is in error. the level of cyanide in the groundwater is above the remedial action level. On page 4 .1 of the Pre- Final Design Report, it states that cyanide ( total) was detected in well CMMW04 at 3 54 µg/1. NCAC ISA: 2L.0202(g) states, "the standard refers to the total concentration ... of any constituent in a dissolved, colloidal or particulate form which is mobile in groundwater." The standard for cyanide is 154 µg/1. Response: Geraghty & Miller understands that according to NCAC ISA: 2L.0202(g) the groundwater standard is based on total cyanide concentration and not amenable. Therefore, the first sentence of paragraph I on page 3-2 of the PFDR will be revised to reflect the total cyanide in the FDR. 3. Page 3.2, paragraph 5. This paragraph discusses an off-site plume. The presence of an off-site plume has not been proved. references to an off-site plume should be removed from the report. Response: It is Geraghty & Miller's opinion based on field data that the buried drum area on the Cristey property is a likely source of groundwater contamination. Bechtel made similar statements in the RI Report. srd g:l.aproject~fdchann\ru:0202. l \O\commcnts\rcsp-S,doc\l l-Apr•96 2 GERAGHTY 8 MILLER. INC 0 • APPENDIXE • Response to Comments From DEHNR USEP A Region IV 4. Page 3.3, paragraph I. The remedial action level for cyanide is 154 µg/1 total cyanide. This level is exceeded in the groundwater at the site. Response: This comment is acknowledged. The FDR will reflect the change. 5. Page 3.2, paragraph 5. the presence of a plume emanating from the abandoned drum area has not been confirmed. The relationship of the ratio to plumes has not been established. While we acknowledge the possibility of a plume source in this area, the existence of a second plume has not been proved. References to an off-site plume should be removed from the report. Response: See response to comment 3 above. 6. Page 5-6 Section 5.2.3 Groundwater Treatment System. Paragraph I and Table 5-2. Proposed groundwater eflluent VOCs concentrations are listed. The levels permissible in the eflluent will be determined by Water Quality Section under the NPDES requirements. Response: This comment is acknowledged .. 7. Page 5-6 Section 5.2.3 Groundwater Treatment System. Paragraph 2. in addition to influent concentrations, ambient air concentrations must be monitored to determine if off- gas treatment must be re-evaluated. Response: As proposed in response to Comment 1, a grab sample will be collected from the air stripper exhaust stack and fence line concentrations will be estimated. If these concentrations are unacceptable, then a further evaluation will be made regarding the necessity of treating the vapor emissions from the air stripper. 8. Page 5-7, Paragraph 3. The last sentence contains a typographical error. Response: This is a typographical error. The last sentence of third paragraph on page 5-7 of the PFDR should read "At a minimum, the air stripper will need to be cleaned using a pressure washer approximately every time the blower discharge pressure exceeds 18 inches of water column." These changes will be incorporated in the FDR. 9. Page 5-9, paragraph I. Estimated ambient air concentrations for trichloroethylene, tetrachloroethylene, and vinyl chloride must be confirmed by air monitoring after the process is in operation. Response: See response to Comment 1 above. srd g:\,project\jfdchann\nc0202.110\commcnu\rcsp..S.doc\l l-Apr-96 3 GERAGHTY & MILLER. INC • APPENDIXE • Response to Comments From DEHNR USEP A Region IV 10. Page 5-9, paragraph 3 .. It is stated in this paragraph that even if all the estimated cyanide (12 ug/1) is in the form of hydrogen cyanide and volatilized in the air stripper, the resulting ambient air concentrations will be insignificant. Provide assumptions and calculations supporting this statement. Response: Attachment E-1 provides assumptions and calculations supporting the modeling result for potential hydrogen cyanide emission. 1 I. Page 7.1, Section 7.1. Groundwater Quality Monitoring Program. Report states that wells will be sampled quarterly the first year and annually thereafter. The wells should continue to be monitored quarterly after the first year. Annual sampling may not be frequent enough to monitor changes in groundwater quality. After a few years of data have been collected and analyzed, the frequency may be reduced. Response: Sampling groundwater from monitoring wells on a quarterly basis is not cost effective and will not provide for more useful results. Instead of annual sampling after the first year sampling will be semi-annual. Groundwater monitoring wells will be sampled quarterly during the first year and semi-annually thereafter for volatile organic compounds as proposed in the PFDR. This monitoring may be modified as the dissolved contaminants at the site's groundwater begins approaching the groundwater performance standards. Additionally, metals are not a problem at the site. Therefore, groundwater samples will not be analyzed for metals. These corrections will be incorporated in the FDR. 12. Page 7.1, Section 7.2. Groundwater Recovery and Treatment System. Water levels in monitoring and recovery wells should be measured quarterly after the first year instead of annually as proposed. Recovery wells should be sampled quarterly after the first year not annually as proposed. combined influent to the air stripper should be sampled quarterly after the first year and not semi-annually as proposed. The frequency of sampling and measuring may be re-evaluated in the future. Response: The commentor provides no rationale for more frequent measurement. Our experience with other recovery systems is that capture zones once established do not change significantly unless groundwater withdrawals change significantly. To evaluate hydraulic capture we propose that water levels be collected monthly from the proposed monitor wells for the first quarter of operation, quarterly the remainder of the first year and semi- annually thereafter. Sampling of the influent to the air stripper is to evaluate system performance and not to determine where the contaminant mass loading is originating. We do agree that evaluations to determine where the mass loading is originating may help us operate the system more srd g:\aproject~fdchann\nc0202.110\commcnts\rC$p-5.doc\l l-Apr-96 4 GERAGHTY & MILLER. INC • APPENDIXE • Response to Comments From DEHNR USEPA Region IV effectively. Therefore, we are proposing that samples be collected from the header of recovery wells PW-5A through 5C, and each of the other recovery wells initially at start-up, semi-annually the first year and annually thereafter. Depending upon the results more frequent sampling may occur. APPENDIX H DRAFf PERFORMANCE STANDARD VERIFICATION PLAN 13. Page 2.3, last paragraph. Water-level measurements should include monitoring well CMMW-26. Response: measurement. Monitoring well CMMW26 will be included m the water level 14. Page 2.4, third bulleted item. Water-level measurements should be done quarterly after the first year of operation. Response: Please refer to response to comment 12 above. 15. Page 2.5, last paragraph. Cyanide analyses should be for total not amenable cyanide. Response: Analyses for cyanide will be modified to include total cyanide as well as amenable cyanide. 16. Page 2.7, paragraph 2. Reference to an off-site plume should be removed from the text. Response: Please refer to response to comment 3 above. 17. Page 2.8, paragraph 2. Field parameters measured should include turbidity. Response: Field parameter will include turbidity, and will be included in the FDR 18. Page 2.10 item 7. Field filtering of groundwater samples are not acceptable unless the results of unfiltered samples are also determined and presented with the filtered result. Laboratory filtering using method 3030C as specified in the NC groundwater guidance document is allowable. Response: In the event of field filtering an aliquot of unfiltered water will also be analyzed for the same constituents. 19. Page 2.7, third bulleted item. Groundwater quality sampling should be done quarterly. Response: Please refer to response to comment 11. srd g:\aproject\jfdchann'1K0202.110~omments\rcsp-5.doc\l l-Apr-96 5 GERAGHTY & MILLER. INC 0 OWG DA TE: IOJUL95 CO~ICRITE P,O REF(RENCE: BECHTEL nGURE t -J PRJCT NO.: NC0202.080 f°ILE NO.: CHANNEL OXFOR PR!NHNG cu CtJt.lW28 rs R[PORT. APRIL 1992. j.,,. GERAGHTY Al.,, & MILLER, INC. .Alllll,f Environmental Services 0 300 FEET ORA'MNG: SI TE2A CHECKED: -APPROVED: 8; DOUCETTE CMUW24 0 =run •£Y TO PUMf5 E=-=-=i UMU,C,IIN l'\IM: k~~:c.:~ C(WNQ.(J) PU.WC -x-x-x-x- ~ PW-1 A OW-I~ F(NCE CULV[RT DRAlNAC[ CR[[I< PROPERTY UN[ TR[[ UN[ RAILROAD PUIJPING WELL OBSERVATION W[LL APPROXIIVIA TE PLUIVIEISI DELINEATION SPRING 1995 JFD ELECTRONICS/CHANNEL MASTER OXFORD, NORTH CAROLINA ,.. 0 0 181 • Q ■ CP-1 DRAFTER: A. WAr<~EN • • SHALLOW W(ll INITRt.lEOV..T[ WCll SHALLOW BEOROCI< W[ll HYOROPUNCH O[[P B£0ROCI< wnt TOP Of ROCK WHL C[OPROBC SA.MPL[ FIGURE 3-1 • • ATTACHMENT C-1 Effiuent Discharge Structure Design g:'-Projeci\jfdchann\nc0202. l l ~ommenb\rcsp-6.doc\ l I •Apr•96 GERAGHTY 8 MILLER. INC. 0 .. D 3 : l 4 PM TAMPA FL 1-' U 1 All,·GERAGHTY AJfti'MlLLER. (\IC. ,., r.'11,•l,1,nmt111al ,i;r,\•i,:r.1 ,l M•ldttmij Cortour . ., '---··---•--.u--• .......... ---•••••111••-•-...-01111,,...,._.,. ______ ___,,,.,_,. __ ,., _________________ _ Dec 11;.1EJ1•,si;,. •~:, \J...f'F I C ~lG:J,.\'rtt..:1 ~ j:~";.:,t Ci~--~ 0 ;::.. ., . • ,. 0 lJ11:=-.... ,L •• a ...... ~ i \JSt.t,~:... ... ,---J or~ 'To ;-;1<:e/ 1::. r-,J"i"" D-o ._.j ~-S,~E.l'\,v\ f.2.-!~ .f u-( ID. l...-t N f:.. , C.. AL. c. <->-t.-""Tl c:::::, /.J D ,.,.\ff'lt.-'ft,"--. ONH. •-••-■••-•-•-•'"-olll""'"'""'' ■11•-••u-------•-•••""1111•••••• fii·;-,--------1,,,-,-, ----- .. ·---------.....L------ D 3 : 1 4 PM TAMPA FL P02 -·---... -·--... -, .. ,-..J ~~)\,\ -· \J.~I ,}., ::· L-.:;.. .. ·- - .. , ... l.d 1~1\"\ ("=> 10 ,:::·.:..o\J \C>E. .,.._ ~~E.. c'...OrJ"';,T~c.'.\AE,1..,: 'i;:, 1c.~~ \ <'.s-•r-J • •-••--•,.--•-•-,.l-1•••""'"■1101•,.-•■---ra----•-"'•·•·u1o0•,,., ........ ~,.-• .. ,,_•------------------■-• o.&.1,,1 .l't,m :10 f-1[1 1r. D 3 : 1 4 PM TANIPA FL ..--••••-••••1-•-11•-~••••m111a ...,__ __ .. ______ , __ .... , .... , ..... ............ ~-·-·-··"··••111 ..... , ... _,... ... _,_ SU•J!e'I! 0~!,J;_.Q._Q:::_1,,1!:,';J~'.'5.r~<.i-1,~-'.TU P~o~eC'f! Ct\ A Nt,;:t_f;;, \.., d~\A ce., T c · ~ CLIIINTIPPClllcr. NO: j\'IL. ('.,~~,f.i:s~><. -·-----•11 ■•-···---;;;;::=;;;;;;:;/ p u j REV: ,---••-•••••-u-... ,,11.11,..., .. ,_, ____ •----•-• ............ ,._,_,,..,,_ ______________________ ~ L,, ,_1,.1 ... \, 5 10 5(• I<)'.) 10()0 llhr.h.1110, tr1/w: +---l---t--H-t-·f-r+1-·-·------•l--1-+++++>--+--+--+-- ·' ,:l .3 .4 .s ,6,"f.11.91 J 3 _. 5 6 7 8 10 15 20 25 .;lK:~nrg11, ,r.1/111-C E'i;..i. '7.46 Dui,:n of rip rap outlet r.1 (lt,~<:Uor. frm11 a rou11d pip~ flowing ruU; m.u.lmum Llilw;1ter condillc,ns. (8, 14) "t;:) 0 \· C), ~r· L-e,.. C • ~!:, ,, ' ~-(JJ) -s.5 Ff.E_.:r -\-- •-••---••11-•-•-,u-,,,,,. ............... _, _______ .. ___ ·•··••·•• .. ••••• .. ••-·" .. _' ........... _______________ _ ,., o IJ '"""' YI n~.:i _,,,.,I, ---·· DJ : 1 4 PM -·-·•-•1••·--•-•11-j1■,111111t1•1 ' . -'lil'GERAGHTY Al"8MILLER. ll~C. ~ t:111·ironm~11,o/ Sn .•/,:,r1 ,-, l·leldumiJ Cnnip1:,y _._..·--·--·-·-··--·-~ TAMPA FL P04 -•-■•-••■••--11•-•-•lllllll ■-••------•---p----------------•----.. 1::i2~~ IJ,,,:;~ \ (\) (,-- C> " A.ND A I ' I 1.-••-■1■••-•-•n-11,,,,,.,,,.,,.,,~,...-•&■u-•---•-••·•"••ll11m,~-••••••-•"""••-~"'·---•-------------•--• : ,..._u ••-• 'Wl _..,111 a~• Seu\ ,~rl~\ 9!••1: 04. 03. 913 D 3 1 4 PM TAMPA FL P05 . , _ _.. ....... , . ..-... -----·--- I~rosi()n and Sediment (~oirt.r 1ol jflandbook 1Jt1--•.t111tadllllllllllll9:a■--- .. ~ ~,,,~ ... , 'i 1ii11 <.D 3/c~ ·,;,. <· · Sr.eve.n J. Goldman / Calif,,rni,i ~"i::hm~ Cof'l.f~ri:·a~1cy Ke.fknrine Jacks,on Cun1.u!in11t •rara~: A. B·llrSztynsky, P.E. A.:~odaliu11 r.J B1JJ Aret? Gvvernmertu ~lc-Gr.,w-H!U Publl-!hlng Company New Yol"k S:. Louis San Francisco Auckbnd Bogot:i Ca:-J<:a:: H;unburg Lisbon London M:rdrid Mexico Milan M1):m:-:1I N~w Dc:lhi Okhhoma City P:rrls San Juan Sfo l'auio Sing:iporc S)'dncy Tokyo Toronto ' . .,..--JlA , I] ;:) -..) . g 13 - ;r th11 receiving chmnne1 ia ne,.rh' tiveraally li!H thun culvert i:,u·J1111; genorally lur11er than the c~11\ """ . rapidly adjunt to • pattern c l11,. ·rated, high-•i,,lo:ity flow ar,,d b)' .o nnw In a larger i!hnnnel. Fig .m1 ct or scour at .i pipn outll-t. l( 11 ,bjectianable, i~ 1na)' b• de,,irahl,, 1!1 an tnl!!'8Y dln,ipator. Hoi.'li·«w~t·, 1dermininE: throu1:h the m1ia cf Ii --------------------·-- i;li,a\ bttd ,,1 · a 11cour hale: 1m1 lite rtr- 1·1 rj 1 4 Pt.f ~· • t G 1,M TAMPA FL P06 ' • . ., --------------------------· .. GD _w_,_.1_._r_C_o_n_v_•..;Y:..•_n_e_,,_._._d_E_n_,_,._;g:,:y_n_1._._1.:.p_a_,1_0_• _____________ 7_._&_s ~E cut.off w:..11. The p:•opc? depth for ·the wall can he determined from Buch re!er- anceo ao :8ohon (,1 •~d FH WA (18), 7.13b Riprap Aprono Propel' upl°i;n dr::dgn dr.per1d, on wh1:ther minimum t.allwahr, maxlmun1 tnll- WJ le:, or both c•:-nditions e:dst. T4ilwn.t~r condition ii, the rel~tion betwet·n the el~iv11Lioni. r.-l wattr surruces in an outlet conduit Qnd a reeolvlng ch11nnel. Pi,1J:-c 7.--\,4 llluitrnte~ minimum and maximum tollw.o.ter conditions (or a round pipe flowing [·,ill. tJndP.r minimum t.$.llwater conditions, the water depth or Lhti recclvlng chnn• nrl, es c1lk\.ll11it:d hy Manning's cguatlon, li:1 loss than one-half the discharg,, pipe dlitrne:u. 'I'h~ e~1ui;:,-ur the wator d~schargfng: from the pipe will be-diR!lipeted by spr~Lulini; on thd .npron r.nd by tu~bulence from impact with tha .ripr.11p -of the aprcm. Un-clt-:· mll.xinium lai!wnter condltlons, the wn.ter depth of the receivini; ch11:\- nel io iireat,,, than one-half the pipe diometer. Energy will ha dl••ip•tod by tu,, bden.;e duiJ to lmpoct of the di,charge stream with both the receiving lailwahr arid tho mclu nf ih111 ripr11p apron. Pre<io.Ju,•i, for Dufg11 ,,( Rlprap Apron ( 14) The-fojlcwing-p1·~i:-eclure Is for the deoign of a level .opron of length end tiaM !!ouch t!iat th,: ~:.i:pe;nd!:-.g flo'N (fr<.1m pipe or conduit to channel) lose, ,ufficienl ve·lnd ty ar.d ene-rgy that it will not erode the downstream channel reach. The dealr,n curvi!~ 1Jn b~1!!eC: :m round pipes flowing full. The curve:, provide the apron sht! 111:d th1:i mHlinn diamet.er dM for tho riprap. There are two curv~s, one f,:,r the rr,inimur~, taibn:iter conditi(ln (Fig. 7.45) and the other for the maximum Wil· wuter co~1dition (Fig. 7.46). The ~1r~11. :;tep in using this procedlire is to determine the tailwster condition. Uae Mar.nir1;fs ,iquntion, Qp,t-,l in the receiving: channel, snd the channel dimen- sinm: t,:1 s;)lvc rm cros.!Hi.edional are-a and t.hen depth or flow In the receiving chJ1.11nf'l. ('.ornpn~~ <l•?pth oJ' flow to pipe diameter to <lettrmlne tallwater 1:onC.i- tior.. Tt:i~J: 1inte1· Lhe appropriate chart with the dl5charge ond the pipe diameter Maximum 1.ailw,111, LJ,L IIJ. '::llj l 4 r' fvl T1~1\'lr'A FL r' u ( .. • • lllllllllll!lllllllUl~i■IU-----·-■-ltlllllll.llllAl:811tlall11Dllldl 11111■11 , . ·--,. .I, For chonn ourfac:! wi bend fact< determine tbsll 1,1 t chan11el n f,,r th,, be: uctiun ar dist.i1r.ce , 11. Enwr Fi1 iaurfac:e. \00 L'.l!l ao ,o ao ,o ,o !~ 30 " :JO ·>/A. :z:~ -10 - ~-'"· 7.3•) Q,, _, •' 7.e~ ------···-·--·--·-~C-,' EMtlon and Sediment Control Handb<Jo~~ 1/ 'J,, I,, 10 C .___.____l o• •,1 J s ..Ll' 10 :: n4--H'+i'HI -i1 " ,4--,,..,4-,,.,,y;w"""2·a .... 200 ~ -~ .. "-1"' . "" . " " 500 ' 0 1000 -1-----f--+-i-++-+i-!+--+--+-+-+H-++-!--+-++ ◊. I U 0.3 0,4 0.8 0.8 I 2 3 ◄ 5 8 7 8 10 I& 20 2& 01,c:ha,gl!, ml/111c; u 1.4 ,. J 1.2 1.1 1.0 e 0.1 S o.a ~ 0.7 ·l C),6 ~ o.s ~~ o., O.J 0.2 0.1 J:'ig. 7.4.S Deaign of riprap outlet protection rrom A ro,.u,d r,lpt ftowins; full; rnil'\ircaum t11ilwater t:tinditiont, (8, 1'} t,, find the ripr:tp !li:te ur,d apron hmgth. The apron width at the pipe end slinul& he 3 t.{~e~ thti pipe dl11meter. Where there ii, 11 well-defined chtmncl immerHl'!tely do•i'l't'lfltrc.111'\ ft•'.'IJ'U tha npl'on, the width or the dC'lwnstrenm end or tht-npror; ~~'lou!d b'.! ,:quol to the _wid•.h or the channel. Wherl? there ie no well-defined chnn- nel im::led{nt,;!l_y d1)WMtrca.rn from the npron, minimum tn.ilwnter eondltlcm!. apply and the width of thi! downstream end or the apron should be aqua.I to tha pirc 2.i.~lni!l+~1 ph.:I\ th~ 11:)r.r;th o( the apron. E;XAi\l r•r.J!: ?"A R.iprup· Outlet Protection De,tsn Ct1leu1Atlon for Mhln111n1 Tarl-wi,1er Cc·d.,1!tle-r:i G(v.e!'I: A 1tciw ,;f;; ~t:/~ec 10.li m1/sec:) dlsrhs.rges from a l:?.in (:JO-cm) pipe cnto !l 2 percent ,;r11.!11y .sb:n1 ,,,hh no deflnc-d ch11nnel. P\nd: "l'ht· rr:q11i1':'d len;~th, width, and inedien etono 5iu d:,., fore riprop apron. , .. 0 4 . i:1 :: . Si 13 ~~~----■•--•-· J. 4 • -----------···.,··--····---·· I I I I Ht--+-1-t-"' s e , s ,c ,is 20 2s ·\around pipe Howing full; ml11irr.u m pron width .,.1 t.h1~ pipe er:cl ,h,1uld well-defl1H:d ch1rnne! irnmei la1,r!;.y 1e downntunm und of t:-,e uprc n here ther13 i1s, 110 '"'etl-<lcfi11Hd drn1:- '• minimu~11 t.1ilwater c1).1i it.ic,n:1 .• the apron should be eq1Jal hl th8 11 rrom a l'.2-in (:lo-cm} ;:1lp11 o·Jt.J n :2 •n11 1iie a',tAl for 11 frprap lp1'1Jn, Ti:J,.MP A FL • W.aiv:r C1)fl'lrt!YL1tLOd Llnd Enitn·r; Diuloatlon +·-·--+--i-t-t-i+t-1-f---+--t-t-+-H--H+--+-+-+- , l .1 .J A .5.6.7.8.gl ' J ~ 5 ll 7a 10 15 20 25 011ehar;.,, ml/we 1.0 0.9 o.s e 0.7 ii 0.8 " • C.6 .~ 0.4 ~ C.3 .':- 0.2 a: 0.1 Fi1~. 7.48 D-e~ign nf riprap outlet protection Crum a round pipe ftowing r1..1ll; rnulmum t.nllw:11;,~~ ,:mdi-:ian!. (fl, 1{1 Soluri',,n: Sin,:.! the plf,1! diad1arge& ontn t!I Aat area with nl'.'I deRned channel, a mini• mun1 1_,i!l\rnt,:r ,;;mditic,n i:rin b~ a113umed. Uy ~•i~. i.4!, !ht t1p1•Qn length L~ und meclian 11t(Jne ~i:w d!t'\ are 10 rt (:1 ml .rnd (),;] ft {U 1;:m), ,.a.!poct:vcly. 1'be 1JJJ!Jlrt>(lm apron width W11 equals 3 timeR the pipe? di1unet1)r D~: Ww •• 3 A D, ·• 3(1 fl) • 3 fl 13(0.J m) ~ 0.9 ml Th,· d,1\;,-r.•1fr1!am np((•n wld:.h W,;1 t!quHl.!1 the apron Ieng-th plu:, tha pipe dlatT,Ctl!r: -1 rt + 10 t't -11 ft (0.3 m + !lO r., • 3.~ m) .V,:H.· "\'flier, 11 cnrn:rnlr,1ted flow b di.'lcharg,e,d onto" ,lope (aa in thla euniple), rut. lyi n l ,: rn 1>-:C'...tl d,.Jwnhilt fftlm lhe outl~t protPct ion. The spreading o( conccnlnstNl tl.,Jw • • • A TI ACHMENT E-1 Air Emissions Calculations g:lapt0jcct\jfdchann\nc0202. l I Olcommentslresp-6 doc\! I-Apr-96 GERAGHTY & MILLER. INC 0 Project Number: Project Name: Calculation By: Subject: Checked By: PURPOSE; • NC0202.100 JFD Electronics/Channel Master Site N.V.Shetty Hydrogen Cyanide Emission Modeling (JJ)r • Sheet: Date: Date: of 5- .f//l /16 0 Y/tt/1£ To model the hydrogen cyanide emission from the air stripper stack using SCREEN2 air modeling program. METI-IODOWGY; The "SCREEN2" is an air dispersion model developed by the U.S. Environmental Protection Agency based on Screening Procedures to Estimate the Air Quality Impact of Stationary Sources. This model can perform all of the single source, short-term calculations in the screening procedures document, including estimating maximum ground-level concentrations and distance to the maximum, incorporating the effects of building downwash on the maximum concentrations for both the near wake and fare wake regions, estimating concentrations in the cavity recirculation zone, estimating concentrations due to inversions break-up and shoreline fumigation, and determine plume rise for flare releases (USEP A 1988). This model takes into account various parameters including the gas exit velocity from the stack, the gas temperature, and several different atmospheric conditions. The model calculates the 1-hour maximum concentration of the compound (example: trichloroethene) and indicates at what distance from the stack this concentration is expected to occur. The modeling assumes flat to gently rolling terrain. No building downwash or cavity effects, since the nearest building is greater than five times the lesser of the height or width of the building (5*16 = 80 feet). The 1-hour maximum concentration is then converted to 24-hour average by multiplying by a factor of 0.4 (USEPA, 1988). The results can then be compared to acceptable ambient concentration under NCAC Title 15A Chapter 2D.1104. ASSUMPTIONS; For the purposes of modeling, it is assumed .that hydrogen cyanide gas is released into atmosphere from the air stripper exhaust stack. The following data are used to model the emission of potential hydrogen cyanide in the air stripper stack. Air Flow Rate Exhaust Stack Height above the base Exhaust Stack Diameter h: \nan jun \channelm\air-issuscm-hcn. txt = = = 300 scfm 26 feet (8.1 meters) 6 inches (0.152 meters) • • Exhaust Temperature (assumed) Air Velocity in the Exhaust Stack = = • 68° F (293 kelvin) 7.762 meter/sec Estimated hydrogen cyanide emission rate = 0.000022 grams/second (Based on 12 ug/1 dissolved concentration in groundwater and 29 .5 gpm) RESULTS: A printout of the SCREEN2 model run is given on the following page. Based on the modeling results, if hydrogen cyanide is emiited from the air stripper exhaust stack at an emission rate of 0.000022 g/s, the maximum one-hour concentration of contaminants expected is 0.08377 ug/M3 at a distance of 49 meters from the source. The one-hour concentration is then multiplied by 0.4 to yield the 24-hour average concentration as 0.0335 ug/M3• The resulting 24-hour concentration is less than the acceptable ambient concentration listed in NCAC 15A, 2D.1104 for hydrogen cyanide (0.14 mg/M3 or 140 ug/M3 ). REFERENCES: GUIDELINES FOR EVALUATING THE AIR QUALITY IMPACTS OF TOXIC POLLUTANTS IN NORTH CAROLINA, July 1990, North Carolina Department of Environment, Health and Natural Resources, Division of Environmental Management, Air Quality Section, Raleigh, North Carolina. USEPA, 1988, "Screening Procedures for Estimating the Air Quality Impact of Stations Sources". EPA-450/4-88--010, Office of Air Quality Planning and Standards, Research Triangle Park, NC, August 1988. h:lnanjun\channelmlair-issuscm-hcn.txt :i. ; " J ~ 0: t s ~ " .J I .. i'i e Ii 6 z i ' i'i a z ~ ;: 8 fl 0 N 8 z a z ~ f ., -~ z ~ t! < ., i ., CO!O'OI: "" ~ a: Q ~ :, Q ;; ~ OXl'ORO PRIMll/lG • t LfGENO -··-··-··------- ~ l l l l CUI.VERT IWJW,G( CR£EX PROPERIY LINE TR£E ll!IE: RAll.R(W) 5 L. £23 ,--e.E"nf M €rvT p lt1, Chi '1._ 6TTl-•t>pS<.) J8f GERAGHTY Alf & MIJJ,ER, INC. ,., Jnt,{ronfflffltGl SffV\CU 0 200 rm Al~ ~-,tl.,,~]2. pA-2:> LJryDl.l"f • STEU.YOUT Jft> D.ECTRONICS/C!WINEl. MASTER OXFORD, NORni C>ROUW. . ' FlGURE 1 • • *** SCREEN2 MODEL RUN *** *** VERSION DATED 92245 *** • 04/11/96 11:44:37 MODELING POTENTIAL HYDROGEN CYANIDE EMISSIONS FROM THE AIR STRIPPER; JFD ELECTR SIMPLE TERRAIN INPUTS: SOURCE TYPE = EMISSION RATE (G/S) = STACK HEIGHT (M) = STK INSIDE DIAM (M) = STK EXIT VELOCITY {M/S)= STK GAS EXIT TEMP (K) = AMBIENT AIR TEMP (K) = RECEPTOR HEIGHT (M) = URBAN/RURAL OPTION = BUILDING HEIGHT (M) = MIN HORIZ BLDG DIM (M) = MAX HORIZ BLDG DIM (M) = POINT .223310E-04 8.1000 .1520 7.7620 293.0000 293.0000 .0000 RURAL 4.8800 61.0000 244.0000 BUOY. FLUX= • 000 M**4/S**3; MOM. FLUX= .348 M**4/S**2 . *** FULL METEOROLOGY*** ********************************** *** SCREEN AUTOMATED DISTANCES*** ********************************** *** TERRAIN HEIGHT OF o. M ABOVE STACK BASE USED FOR DIST CONC UlOM USTK MIX HT PLUME (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) --------------------------------------- 1. .0000 0 .o . 0 . 0 .00 100. .5974E-Ol 6 1.0 1.0 10000.0 11. 35 200. .4179E-Ol 6 1.0 1.0 10000.0 11. 35 300. .3222E-Ol 6 1.0 1.0 10000.0 11. 35 MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 49. .8377E-Ol 6 1.0 1.0 10000.0 11.35 DWASH= DWASH=NO DWASH=HS DWASH=SS DWASH=NA MEANS MEANS MEANS MEANS MEANS NO CALC MADE (CONC = 0.0) NO BUILDING DOWNWASH USED HUBER-SNYDER DOWNWASH USED SCHULMAN-SCIRE DOWNWASH USED DOWNWASH NOT APPLICABLE, X<3*LB ******************************************** * SUMMARY OF TERRAIN HEIGHTS ENTERED FOR * * SIMPLE ELEVATED TERRAIN PROCEDURE * ******************************************** TERRAIN HT (M) o. DISTANCE RANGE (M) MINIMUM MAXIMUM 1. 300. FOLLOWING SIGMA y {M) ------ .00 4.17 7.78 11.27 2.33 DISTANCES *** SIGMA z (M) DWASH ----------- .00 NA 6.65 HS 8.01 HS 9.31 HS 5.95 HS ' . ~ • • *** CAVITY CALCULATION -'1 *** *** CAVITY CALCULATION - 2 *** CONC (UG/M**3) = .0000 CONC (UG/M**3) = .0000 CRIT WS @lOM (M/S) = 99.99 CRIT WS @lOM (M/S) = 99.99 CRIT WS@ HS (M/S) = 99.99 CRIT WS@ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 4.88 CAVITY HT (M) = 4.88 CAVITY LENGTH (M) = 31.63 CAVITY LENGTH (M) = 25.88 ALONGWIND DIM (M) = 61.00 ALONGWIND DIM (M) = 244.00 CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET= 0.0 *************************************** *** SUMMARY OF SCREEN MODEL RESULTS*** *************************************** CALCULATION PROCEDURE MAX CONC (UG/M**3) DIST TO MAX (M) TERRAIN HT (M) SIMPLE TERRAIN .8377E-Ol 49. o. *************************************************** ** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS** *************************************************** c;-~ --~