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HomeMy WebLinkAboutNCD122263825_20020502_JFD Electronics - Channel Master_FRBCERCLA RA_Interim Remedial Action Report-OCR•,··.-. l•··· .... , , , UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 4WD-NSMB Mr. Dexter Matthews, Director Division of Waste Management NC DENR 401 Oberlin Road, Suite 150 Raleigh, NC 27605 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 May 2, 2002 SUBJECT: Interim Remedial Action Report JFD Electronics/Channel Master Site, Oxford, North Carolina Dear Mr. Matthews: EPA is pleased to announce the completion of the Remedial Action phase and the initiation of the Long-Term Response phase at the JFD Electronics/Channel Master NPL Site, which is located in Oxford, Granville County, North Carolina. The EPA North Site Management Branch Chief signed the enclosed Interim Remedial Action Report for this site on May 2, 2002. The construction was completed as documented in the Preliminary Close Out Report, dated September 29, 2000, and the groundwater pump and treat system is considered operational and functional. The Long-Term Response phase will continue until clean-up goals are achieved for the groundwater remediation system. If you have any questions, I can be reached at (404) 562-8789. ~~ Philip Vorsatz, Chief North Carolina Site Management Section Enclosure Internet Address (URL) • http://www.epa.gov Recycled/Recyclable• Prlnled with Vegetable Oil Based Inks on Recyded Paper (Minimum 30¾ Postconsume~ • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 May 2, 2002 4WD-NSMB Mr. William H. Doucette, Jr., Ph.D., L.G. Senior Program Manager ENSR International 7041 Old Wake Forest Road Raleigh, NC 27616-3013 SUBJECT: Interim Remedial Action Report JFD Electronics/Channel Master Site Dear Mr. Doucette: Enclosed is a copy of the approved Interim Remedial Action Report for the JFD Electronics/Channel Master Superfund Site. The guidance document·, Close Out Procedures for National Priorities List Sites (EPA 540-R-98-016, OSWER Directive 9320.2-09A-P, PB98- 963223, January 2000) states that a Remedial Action Completion is achieved once the designated EPA regional official (in this case, the Branch Chief), approves the Interim or Final Remedial Action Report. Interim Remedial Action Reports are utilized when there are groundwater or surface water treatments that will require a long period of time between the construction completion and the achievement of clean-up goals. The approval of the Interim Remedial Action Report indicates the completion of the Remedial Action phase and the beginning of the Long- Term Response phase (PRP LR). The PRP LR will be considered complete when cleanup goals are achieved and is documented in the Final Remedial Action Report. If you have any questions, please call me at (404) 562-8760. Enclosure· cc: David Mattison, NC DENR Brian Kempner, The Unimax Corporation S. Alan Lazar, Avnet, Inc. Sincerely, 2~rfel- Samantha Urquhart-Foster Remedial Project Manager North Site Management Branch Internet Address (URL) • http://www.epa.gov Recycled/Recyclable• Prlnlod wrth Vegetable OH Based Inks on Recycled Paper (Mtnimum 30% Postconsumer) • • INTERIM REMEDIAL ACTION REPORT JFD ELECTRONICS/CHANNEL MASTER SUPERFUND SITE Oxford, Granville County, North Carolina Prepared by United States Environmental Protection Agency May 2002 • • Interim Remedial Action Report JFD Electronics / Channel Master Superfund Site Record of Preparation, Review, and Approval . Groundwater Pump and Treat Excavation and Off-site Treatment/Disposal of Contaminated Soils and Sludge This report has been prepared in accordance with EPA OSWER Directive 9320.2-09A and will be used as the basis for development of the site Final Close Out Report. Prepared By: Reviewed By: Approved By: Samantha Urquhart-Foster Remedial Project Manager US EPA Region 4 Date: /tp(!Jt-2Cf,.2a2,... ' 11 ip orsatz Chief, NC Site Management Section US EPA Region 4 · Date: · '!:J-· '2.D:,7..--- Chief, North Site Management Branch USEPARk/4 Date: 5 ~ (JZ,- • JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report TABLE OF CONTENTS • Page i I. INTRODUCTION ....................................................... l A. Location, Size, Environmental Setting, and Operational History ............. l B. Operations and Waste Management Practices that Contributed to Contamination ................................................................ 1 C. Regulatory and Enforcement History ................................... l D. Major Finding and Results of Site Investigation Activities .................. J I. North Carolina Department of Human Resources Site Inspection ...... J 2. ATSDR and EPA Site Visits ................................... 2 3. Remedial Investigation ....................................... 2 4. Risk Asses.s_ment ......................................... : .. J E. Prior Removal and Remedial Activities ................................ J F. Operable Units .................................................... J II. OPERABLE UNIT BACKGROUND ........................................ J A. Groundwater ..................................................... :!: I. Cleanup Goals .............................................. :!: 2. Remedy Selected in the ROD ................................... :!: 3. Remedial Design .......................................... , . .2_ 4. Explanation of Significant Differences ........................... -2, B. Soil/Sludge ........................................................ Q I. Cleanup Goals .............................................. Q 2. Remedy Selected in the ROD .................................. Q 3. ROD Amendment ........................................... Q 4. Remedial Design ............................................ Q 5. Explanation of Significant Differences ........................... 1 ill. CONSTRUCTION ACTIVITIES ........................................... 1 A. Groundwater ..................................................... 1 I. Pre-construction Activities ..................................... 1 2. Remedial Construction ..... , .................................. li 3. System Startup .............................................. 2. 4. Treatment System Modification ................................ l.Q 5. System Restart ............................................. l.Q B. Soil/Sludge ...................................................... IO I. Pre-construction Activities .................................... l.Q a. Contractor Procurement and Access Agreement ............. l.Q b. Pre-excavation Confirmation Sampling .................... ll c. Pre-construction Conference ............................ ll 2. Remedial Construction ....................................... ll a. Mobilization/Site Setup ................................ ll b. Site Health and Safety Controls .......................... 12 c. Material Removal ..................................... .Ll. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page ii d. Materials Handling ..................................... 1'4 e. Post-excavation Confirmation Sampling ................... 14 f. Suspect Soils ....................................... ; .11 g. Transportation, Treatment and Disposal ................... .11 · h. Decontamination ..................................... 12 1. Backfill ............................................. ]2 J. Site Restoration ...................................... lfi N. CHRONOLOGY OF EVENTS ............................................ .1.fi V. PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL .. l} A. Groundwater .................................................... 11 I. Performance Standards ..................................... -11 2. Construction Quality Control .................................. .IB B. Soil/Sludge ...................................................... _IB 1. · Performance Standards ... : .................................. .IB 2. Construction Quality Control ................ · ................. -12 VI. FINAL INSPECTION AND CERTIFICATIONS ............................. -12 A. Groundwater .................................................. ,. -12 B. Soil/Sludge ..................................................... -12 VII. OPERATION & MAINTENANCE ACTIVITIES ............................. 20 A. Groundwater .................................................... 20 I. System Maintenance ........................................ 20 2. Sampling and Monitoring Plan ................................ 20 3. Operation, Maintenance and Monitoring Activities ................ ;D_ 4. System Interruptions ........................................ ;u_ B. Soil/Sludge ...................................................... 22 VIII. SUMMARY OF PROJECT COSTS ........................................ 22 A: Groundwater ........................................ : ........... 22 B. Soil/Sludge ............................................... : ...... 23 IX. OBSERVATIONS AND LESSONS LEARNED .............................. 23 X. CONTACT INFORMATION .............................................. 23 A. EPA ........................................................... 23 B. North Carolina Department of Environment and Natural Resources · ......... 24 C. PRPs ........................................................... 24 D. PRPs' Contractors ................................................ 24 I. RD, Construction Project Management, Oversight, Quality Assurance . 24 2. Groundwater Remediation System ............................. 25 3. Soil/Sludge Remediation ..................................... 25 • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page iii APPENDIX A -REFERENCES ................................................. 26 LIST OFT ABLES Table I -Groundwater Remediation Levels ......................................... ± Table 2 -Soil Remediation Levels ................................................. § Table 3 -Well Construction Details ............................................... ll_ Table 4 -Excavation Details ..................................... : .............. .Ll. Table 5 -Groundwater Remedy Chronology of Events ................................ l§ Table 6 -Soil/Sludge Chronology of Events ......................... _ .............. -11 Table 7 -Groundwater Monitoring Plan ........................................... 20 • • JFD Electronics/ Channel Master Superfund Site Page I of 26 Interim Remedial Action Report INTERIM REMEDIAL ACTION REPORT JFD ELECTRONICS/CHANNEL MASTER SUPERFUND SITE OXFORD, GRANVILLE COUNTY, NORTH CAROLINA EPA CERCLIS ID NUMBER NCD122263825 I. INTRODUCTION A. Location, Size, Environmental Setting, and Operational History The'JFD Electronics/Channel Master Superfund Site(the Site) is approximately 13 acres in size and is lqcated at the corner of Industrial Drive and Pine Tree Road, approximately 2 miles southwest of Oxford, in Granville County, North Carolina. The main building at the Site is currently being utilized by Avnet as a warehouse distribution center. The smaller building on-site is currently being used by the Bandag Corporation as a distribution warehouse. B. Operations and Waste Management Practices that Contributed to Contamination JFD Electronics (a subsidiary of Unimax Corporation) manufactured television antennas from 1961 to 1979 at the Site. An unlined lagoon was built during 1964-1965 to dispose of wastewater and sludges generated from a chromate conversion process and a copper/nickel electroplating process. The lagoon reportedly held from 800,000 to 1,000,000 gallons of sludge during its operation. Wastes generated from the processes contained a number of metals, including chromium,· lead, and cyanide. Waste\vater was treated in an on-site.treatment plant. Sludge was disposed of in the lagoon and in eleven sludge drying beds (SDBs) along the southern property boundary. In October 1979, Channel Master Satellite Systems, Inc. (a subsidiary of Avnet Inc.) began leasing the Site. Channel Master purchased the property in 1980 and used it until 1984 to produce satellite antennas, amplifiers and boosters. Organic solvents "'.ere reportedly used on-site for cleaning tools and antenna elements prior to sending them off- site for· electroplating. C. Regulatory and Enforcement History The United States Environmental Protection Agency (EPA) proposed the Site to the National Priorities List (NPL) on June 24, 1988 (53 FR 23988), and added it to the final list on October 4, 1989 (54 FR 41000). On April 25, 1989, EPA sent special notice letters to: (]) Unimax Corporation, (2) Channel Master, and (3) GranviBe Industrial Developers. The letters requested that these potentially responsible parties (PRPs) conduct a Remedial Investigation and Feasibility Study (Rl/FS) at the Site. The notice letters also informed the PRPs of their liability for past costs. The PRPs declined to perform the Rl/FS. On November 9, 1989, EPA sent a letter to the PRPs informing them of EPA's decision to conduct a fund-lead Rl/FS at the Site. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 2 of 26 Following the RI/FS, a Consent Decree was negotiated between EPA, JFD Electronics Corporation, and Channel Master Satellite Systems, Inc. to perform the Remedial Design and Remedial Action. It was signed by a United States District Judge on December 23, 1993. D. Major Finding and Results of Site Investigation Activities 1. North Carolina Department of Human Resources Site Inspection The North Carolina Department of Human Resources -CERCLA unit (NCDHR-CERCLA) (now called North Carolina Department of Environment and Natural Resources (NC DENR)) conducted a Site Inspection in 1987. Analysis of the lagoon sludge and adjacent soils revealed the presence of chromium, lead, arsenic, cyanide and volatile organic compounds (VOCs). Analysis of the groundwater revealed the presence of dichloroethane, trichloroethene, tetrachloroethene and xylene . . 2. ATSDR and EPA Site Visits Site visits were conducted by representatives of the Agency for Toxic Substances and Disease Registry (ATSDR) in March 1989 and by EPA in September 1989. Based on these inspections and other information, both EPA and ATSDR concluded that contamination still existed at the Site which warranted further investigation. Site contamination included soils and groundwater contaminated with VOCs, and metal-contaminated soil/sludge associated with the SDBs. 3. Remedial Investigation Bechtel Environmental, Inc. (Bechtel), EPA's contractor, submitted the Final RI/FS in April 1992. The RI stated that industrial activities resulted in two potential contamination source areas. The first was the release of VOCs iii the south parking lot area, which extended to the subsurface. The second was the placement of metal sludges in SDBs and the settlement lagoon. The RI determined that the shallow and deep groundwater tables were contaminated with VOCs (maximum total VOC concentration of 364,410 micrograms per Liter (µg/L)) and the surficial and sub-surficial soils and sludges were contaminated with heavy metals at the following maximum concentrations ( chromium (100,000 milligrams per kilogram (mg/kg)), nickel (36,000 mg/kg), zinc (2,000 mg/kg), copper (1,600 mg/kg)) and cyanide (estimated at 230 mg/kg). • • JFD Electronics/ Channel Master Superfund Site Page 3 of 26 Interim Remedial Action Report 4. Risk Assessment The Risk Assessment indicated that under the current land-use scenario, the greatest concern is of adverse noncarcinogenic effects due to ingestion exposure of onsite facility workers to chromium in the SOB area. The high concentrations of metals in the SDBs were also of potential concern with respect to migration to groundwater. Under future land-use scenarios, the use of groundwater was of concern. Although exposure was hypothesized for a future resident, the continued migration of these mobile chemicals to existing downgradient residential wells was of great concern. The contaminants of concern identified in the Risk Assessment for groundwater included: Benzene, 1,2-Dichloroethane, 1, 1-Dichloroethene, 1,2- Dichloroethene, Tetrachloroethene, 1, I, I-Trichloroethane, Trichloroethene, Vinyl chloride, Barium, Chromium, Copper, Lead, Nickel, Zinc and Cyanide. The contaminants of concern identified in the Risk Assessment for soil/sludge included: . Antimony, Cadmium, Chromium, Copper, Nickel, Zinc and Cyanide. E. Prior Removal and Remedial Activities ·Asa-result of the Site Investigation, Channel Master initiated cleanup activities in June 1987 under the supervision of NCDHR-CERCLA. These activities included excavating approximately 17,000 cubic yards ( cy) of contaminated soil/sludge and disposing of it in a permitted waste disposal facility. Approximately 2,000 cy of VOC- contaminated soil were also excavated and thermally treated. In July 1988, Channel Master excavated and disposed of two fuel oil tanks and one concrete waste oil tank. F. Operable Units There is only one Operable Unit (OU) for this Site. The Remedial Action for which this Report discusses will be broken down into two components: (I) Groundwater, and (2) Soil/Sludge. II. OPERABLE UNIT BACKGROUND As just stated, there is only one OU for this Site. The Record of Decision (ROD) was signed on September 10, 1992. Although there is only one OU, the Site can be broken into two components: Groundwater and Soil/Sludge. For both components, the remedy selected in the ROD was modified through an Explanation of Significant Differences (ESD) and/or a ROD Amendment. This section is organized according to the components. The Cleanup Goals are discussed first, followed by the original remedy selected in the ROD, the revised remedies according to the Explanation of Significant Differences and/or ROD Amendments, and a summary of the Remedial Design·. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report A. Groundwater 1. Cleanup Goals Page 4 of 26 The Groundwater Remediation Levels (RLs) established in the ROD were the Safe Drinking Water Act Maximum Contaminant Levels (MCLs) or North Carolina groundwater quality standards, whichever were more protective. The groundwater RLs selected for the Site are listed in Table 1. Table 1 -Groundwater Remediation Levels , >'c-Cicintarrii'haht:'of.ci,i:: .l •_:R_Eftn.~_gi'alt;on•·L~.ve,l;f; :_i:-•,: ·(t.:~~r~,:~;f~Qr:i.~~g'f D2~-J£l!;~;f3: ':.i.:f_:;~'--"G;;;Ju_gf'_t;:)N:t··::u:.~:;;:.,~- Benzene 5 1,2-Dichloroethane 0.38 1,1-Dichloroethene 7 , 1,2-Dichloroethene 70 Tetrachloroethene 0.7 1,1,1-Trichloroethane 200 Trichloroethene 2.8 Vinyl chloride 0.015 Barium 1,000 Chromium 50 copper 1,000 Lead 20 Nickel 100 Zinc 500 cyanide 154 2. Remedy Selected in the ROD The groundwater remedy selected in the ROD was Alternative 4: Groundwater Extraction, Treatment with Alkaline Chlorination, Precipitation/Filtration, Air Stripping, and Carbon Adsorption. The ROD called for the extraction of groundwater contaminated above.the RLs from the affected area. The contaminated aquifer would be remediated until the RLs·are achieved. Discharge of the treated groundwater would be either to the local, publicly owned treatment works (POTW), or as surface water discharge to an unnamed branch of Fishing Creek. Discharges would comply with Applicable or Relevant and Appropriate Requirements (ARARs) listed in the ROD. I> JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report 3. Remedial Design • Page 5 of 26 ARCADIS Geraghty & Miller (ARCADIS), consultants for the PRPs, submitted a Remedial Design Work Plan in November 1993. They submitted a Preliminary Design Report in July 1995 and a Pre-Final Design Report on February 6, 1996. The Final Design Report for the Groundwater Remediation (FDR-GW) was submitted to EPA in July 1996 and was approved by EPA on September 11, 1996. During the Remedial Design (RD) process, pre-design data collection activities occurred between July 1994 and March 1995. The results were utilized in preparation of the Final Design, which varied from what was prescribed in the ROD. A significant finding of this data collection was that the RLs for dissolved metals were not exceeded based on analyses of groundwater samples collected using revised'sampling techniques. Previously detected metals in the groundwater were likely the result of turbid samples. The Final Design called for seven recovery wells pumping groundwater contaminated with VOCs into a low-profile air stripper. The treated groundwater from the air stripper would be discharged to a nearby intermittent stream. 4. Explanation of Significant Differences During the RD, ARCADIS collected additional groundwater data which_ indicated that several changes could be made to make the remedy more efficient and cost effective. On January 24, 1996, an ESD was signed which changed the groundwater remedy. The Alkaline Chlorination, Precipitation/Filtration and Carbon Adsorption treatment methods were conditionally eliminated. These steps would be added back to the system if monitoring after system start-up showed exceedance of POTW or surface water standards ( depending on where the effluent would be discharged) for cyanide, metals or VOCs. Therefore, the revised remedy included: • Six or more extraction wells placed along the plume; • Extraction of groundwater that is contaminated above the RLs; • Passage of extracted groundwater through an equalization tank for pH and temperature adjustment and flow equalization; • Removal of VOCs from the groundwater via Air Stripping; • Discharge of treated groundwater to surface water or POTW; and • Continued analytical monitoring for contaminants in groundwater. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report B. Soil/Sludge I. Cleanup Goals • Page 6 of 26 At the time the ROD was written, there were no promulgated Federal or State standards applicable to the contaminants in the soil/sludge at the Site. RLs were calculated based on direct exposure residential assumptions for contamination identified in the soil/sludge. These levels reflect a protective risk on the order of 10-' and are included in Table 2. Table 2 -Soil Remediation Levels ,'c1CI611tamfna:nt'fof,Y,,s :';Remedi a:t;ion,:1L:elleJ's~ ,,.:~,;~~\¥1~0 nc.e r:n::;~t1;:~~~:t.;~\i 0~:1';::~~;;}, ?::-(~9/Kg:>~1{4t:\·;%{~(d Chromium (Cr '6) 310 Ni eke l 1,100 Antimony 25 Cyanide (total) 590 cyanide (amenable) 30 2. Remedy Selected in the ROD The soil and sludge remedy selected in the ROD was Alternative 4: Excavation, Treatment with Oxidation-Reduction, Stabilization, On-site Disposal, and Capping. A Treatability Study was required during the RD. The remedy that was select_ed in the ROD was modified through a ROD Amendment and an ESD. 3. ROD Amendment Treatability studies conducted in 1994 and 1995 f_ound that soils and sludges contaminated with cyanide could not feasibly be treated on-site to meet treatment standards. Therefore, in May 1999, the ROD was amended_ The ROD Amendment divided the soil and sludge into two categories: (I) cyanide-and metals-contaminated soil/sludge, and (2) metals-contaminated soils. Both categories would be excavated. The cyanide-contaminated soil/sludge would be transported off-site for treatment and disposal. The metals-contaminated soil would be stabilized on-site with Portland Cement, then placed back on-site and covered with a vegetative cover. 4. Remedial Design _A Remedial Design Work Plan was prepared and submitted to the US EPA and NC DENR in November 1993. A Design Criteria Memorandum was developed in June 1999. Following that memorandum, a Preliminary Design Report was submitted in September 1999. The Pre-Final Design Report was JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 7 of 26 submitted in February 2000. The Final Design Report Soil/Sludge Remediation (FDR-SS) was submitted in March 2000. The Final Revisions were submitted on May 23, 2000. These revisions were reviewed by EPA and NC DENR and the FDR-SS was approved by EPA on June I, 2000. 5. Explanation of Significant Differences After the FDR was finalized, and just prior to the Remedial Action, surficial soil sampling showed that the extent of surficial soil metals-contamination was much less than previously estimated. The drastic decrease in soil volume made on-site treatment and disposal not very efficient or cost effective. Therefore, an ESD was signed by Richard D. Green, EPA Region 4 Waste Division Director, on July 19, 2000, changing the soil/sludge remedy. The revised remedy included: • Excavate approximately 2,300 cy of cyanide-impacted sludge and 650 cy of metals-impacted soils; • Transport the wastes to an appropriate treatment and disposal facility; • Treat the sludge with alkaline chlorination to reduce levels of cyanide; • Reduce hexavalent chromium in the sludge to trivalent chromium; • Stabilize the sludge and soils for metals to reach the disposal requirements established by the disposal facility; • Dispose of the treated and stabilized wastes in the off-site facility; and • Backfill, grade, cover and seed the excavated areas. III. CONSTRUCTION ACTIVITIES A. Groundwater A detailed description of the remedial action can be found in the Final Construction Report, Groundwater Remediation, Revision 1 prepared by ARCADIS in December 2000. The following is a brief summary taken from the document. I. Pre-construction Activities Upon approval of the FDR-GW, ARCADIS prepared and distributed bid documents. A pre-bid meeting was held on December 5, 1996, and bids were received later that month. Waste Abatement Technologies, Inc. (W ATEC) was . selected to construct the groundwater remediation system. Construction did not begin immediately due to a delay in obtaining access agreements from off-site property owners. The final access agreement was obtained in February 1998. ARCA DIS executed the contract with WA TEC in March 1998. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 8 of 26 AR CAD IS purchased major equipment for the ·treatment system from several vt,ndors during March and April 1998. The equipment was delivered during the system construction. A pre-construction conference was held on April 12, 1998 and was attended by representatives of ARCADIS, Avnet, EPA, NC DENR and WATEC. A conference summary report was submitted to EPA in June 1998. 2. Remedial Construction WA TEC mobilized to the site and began the treatment system construction on May 6, 1998. A field construction trailer and utilities were installed. An offsite access road was built for installation and maintenance of the off site wells. Richard Simmons Drilling Company, Inc. installed six new recovery wells: PW-2, PW-3, PW-4, PW-5A, PW-5B and PW-5C. (Well PW-I was installed in December 1994 during design activities.) Well installation and development occurred between May 18, 1998 and June 5, 1998. All wells were constructed of 6-inch diameter stainless steel piping. Additional information regarding the specific well construction is found in the following table: Table 3 -Well Construction Details ,WEL:L'..,t-JAME. :.RATE J>RitbEI:>" .DEPT.H · PW-2 06/04/1998 37 feet PW-3 06/02/1998 24 feet PW-4 06/03/1998 58 feet PW-SA 05/28/1998 25 feet PW-5B 05/27/1998 25 feet PW-SC 05/27/1998 25 feet Drill cuttings were placed into roll-off containers, sampled and analyzed. The results indicated that they were not hazardous. They were transported and disposed of at Piedmont Landfill and Recycling Center in Kernersville, NC.. W ATEC began trenching and installing pipes in May 1998. CT &L Engineering performed compaction testing for the soil backfilled over piping trenches. All underground pipes were made of high-density polyethylene (HDPE), and aboveground pipes were made of Schedule. 40 chlorinated polyvinyl chloride (CPVC). To protect from freezing temperatures, the CPVC pipes at the treatment pad were heat traced and insulated. An electric submersible pump was installed in each recovery well. • JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report • Page 9 of 26 In June 1998, after installation of the recovery wells, step-drawdown tests were performed on wells PW-2, PW-3 an_d PW-4. Groundwater flow rates were estimated to be 3 gallons per minute (gpm), 2 gpm, and 8 gpm, respectively. At the end of the test, a groundwater sample was collected for VOC analysis. A 9-_inch-thick reinforced concrete pad was constructed. The low-profile air stripper, motor control center and control panel were then anchored on the concrete pad. A canopy was constructed over the treatment system. All recovery well pipes were connected to the air stripper through a common header pipe equipped with a flow meter/totalizer, a-control valve, and a sample port. The air stripper is ShaHew Tray ~ode! 2341 equipped with a 7.5 horsepower air blower. Exhaust from the air stripper is connected to a 26-foot- high discharge stack using a 7-inch-diameter fiberglass flexible pipe and a 6-inch- diameter Schedule 40 PVC rigid pipe. The air discharge stack is supported by a timber pole. The groundwater treatment system is controlled by a central control panel. The control panel also houses a programmable logic control and an auto dialer to notify remote personnel of alarm conditions. The control panel displays run lights and on/off switches for each recovery well pump, the air stripper, and the blower. The wells are equipped with switches to operate or shut down the pumps based on water levels. The air stripper blower is equipped with a low air-flow switch, and the air stripper sump is equipped with a high water-level switch to shut down the entire system and prevent discharge of untreated water. The effluent line consists of 4-inch-diameter HDPE pipe. This pipe gravity drained to the unnamed tributary of Fishing Creek. The top 18-inches of excavated soils above the effluent line were stockpiled, sampled and analyzed. The results were below the soil RLs, so the soils were used for backfilling trenches. The well development water and decontamination water was containerized in 55-gallon drums and two polyethylene tanks. This water was pumped through the treatment system in December 2000 and January 2001 (see section VII.A.3). 3. System Startup The system startup/trouble shooting was initiated soon after the final inspection. A few minor adjustments and modifications were made during August 10-28, 1998. . On August 13, 1998, well CMMW04 was pumped for 12 hours as a temporary measure to reduce cyanide concentrations. The water was transferred into a steel tanker, sampled and analyzed. Because of the elevated cyanide • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 10 of 26 concentrations (0.18 mg/L), the water was treated as Hazardous with a waste code of F009. On February 3, 1999, the 3,854 gallons of water was transported to Heritage Environmental Services, Inc. in Charlotte, NC for treatment/disposal. The system began operation during the last week of August 1998. The first samples from the treatment system effluent were collected on September 2, 2000. The analytical results indicated that total cyanide concentration in the effluent was 22 µg/L, which exceeded the discharge limit of 5 µg/L. Upon receipt of the analytical results, the system was shut down on September 8, I 998. 4. Treatment System Modification The City of Oxford issued the PRPs a General Sewer User Permit, which became effective on September I, 1999, and current! y has an expiration date of December 31, 2002. In March 2000, a new effluent pipe was installed and connected to the_ city's sanitary sewer located southeast of the treatment pad. The new piping included a ball valve, a check valve, and two clean-outs. A ball valve was installed on the original discharge line to prevent discharge to the creek. PVC piping and fittings were used for the new discharge line. GARCO, Inc. completed the effluent line installation to the property fence line. The City of Oxford completed the sewer tap and final connection. 5. System Restart After the effluent discharge lines were modified, the system was returned to operation on April 12, 2000. Recovery wells PW-I, PW-2, PW-3 and PW-4 were put into operation on that date. However, the PW-5 well cluster was not put into operation until November 17, 2000, because of the Enhanced Reductive Dechlorination pilot test ongoing in that area. B. Soil/Sludge A detailed description of the remedial action can be found in the Final Construction Report, Soil/Sludge Remedial Action (Volume I) prepared by ARCADIS in February 2002. The following is a brief summary taken from that document. I. Pre0 construction Activities a. Contractor Procurement and Access Agreement Separate bids were obtained for the on-site remediation activities and off-site transportation, treatment and disposal (T&D). Bid documents were distributed on April 17, 2000. A pre-bid meeting was held four days later and bids were received on May 11, 2000. Notices to Proceed were • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 11 of 26 provided on June 2, 2000 to Earth Tech to perform the soil/sludge removal and backfilling operations, and to Safety Kleen for T&D of contaminated soils/sludge. However, due to Safety Kleen's inability to obtain the required bond, their contract was terminated and The Environmental Quality Company (EQ) was given a Notice to Proceed on July 19; 2000. The access agreement was executed by Norfolk Southern Corporation (NSC) on June 14, 2000. NSC issued a letter dated June 30, 2000 approving collection of soil samples on their property. b. Pre-excavation Confirmation Sampling As proposed in the FDR-SS, ARCADIS collected soil samples to further delineate areas with surficial soil contamination. The on-site soils were sampled on May 24-25, 2000, and the soils on the NSC easement were sampled on July 6, 2000. The samples were collected at three depth intervals: 0-0.5 feet below the land surface (ft bls), 0.5-1 ft bis and 1-1.5 ft bis. They were analyzed using Level II data quality objectives, with 25 percent also analyzed using the Contract Laboratory Program (CLP)/CLP- equivalent methods. Based on this sampling event, only six surface grids required remediation with an estimated volume of 600 -700 cy. c. Pre-construction Conference On June 12, 2000, a preconstruction conference was held with representatives of ARCADIS, Avnet, EPA, NC DENR, Earth Tech and Safety Kleen. In addition to discussing roles and responsibilities, health and safety, etc., the results of the soil sampling performed on May 24-25, 2000 were presented. 2. Remedial Construction a. Mobilization/Site Setup Earth Tech mobilized to the site on July 24, 2000. Prior to excavation, the area was cleared of vegetation. Sections of the chain-link fence were removed and safely fencing was tied into existing fencing to secure the. area. Storm water management controls were utilized, which included siltfencing, diversion ditches, temporary berms and a temporary retention pond. Plastic sheeting was placed in the gravel parking lot east of the Bandag building to stockpile excavated soils for T&D. On August I, 2000, the temporary piezometer was abandoned. Carolina Power and Light (CP&L) temporarily disconnected the existing r • JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report • Page 12 of 26 overhead ,power lines, removed two power poles in the excavation area and rerouted power to the groundwater treatment system. b. Site Health and Safety Controls The site was divided into the following three health and safety . zones: an exclusion zone, contamination-reduction zone, and a support zone. The exclusion zone included the excavation areas and impacted-soil stockpile areas. Caution tape was placed around the excavation areas and Personal Protective Equipment (PPE) was reguired in this zone. The contamination-reduction zone was located between the exclusion zone and the support zone. Equipment and personnel decontamination aciivities were performed in this zone and PPE and first-aid equipment were staged here. A rectangular decontamination pad with bermed sides was constructed with asphalt in this area. The support zone was for site management and deliveries. Site access was restricted to individuals participating.in the remediation activities. Earth Tech performed on-site air monitoring using Minirams, at upwind and downwind locations of the active work-area. Water was sprayed often in excavation areas for dust suppression. Earth Tech performed periodic air monitoring in the breath_ing zone during excavation activities. The personal air sampler filters were shipped to Test America, Inc. for analysis of metals and cyanide. The analytical results were below method detection limits. c. Material Removal Excavation occurred during August 2-25, 2000. Soils were excavated to specified depths and were transported via dump truck to the stockpile area. Where soil sampling indicated metals and cyanide levels. were below RLs, the top I-foot of soil was excavated, stockpiled separately, and later used for backfilling. While excavating surficial soil over the SDBs,_ sludge was discovered in thin seams ( I to 4 inches thick). The depths of the sludge seams varied depending on the location. The sludge was typically bluish- green to black in color and easy to visually distinguish. A sludge seam was sampled and shipped to STL Savannah Laboratories in Savannah, GA. The analytical results indicated nickel concentration greater than the RL. Sludge seams were found in 16 grids. The sludge seams and surrounding soils were excavated and stockpiled for off-site T&D. • • JFD Electronics/ Channel Master Superfund Site Page 13 of 26 Interim Remedial Action Report · While removing sludge seams in Grid 6, a small sludge bed was discovered. This SOB was not previously identified and was labeled as SOB-0. This SOB was discovered at approximately I-ft bis. The sludge and immediately adjacent soil was excavated for off-site T &O. The remaining 11 SOBs were located close to the areas identified in the RI. After the excavation of the surficial soils over a sludge bed, soils were removed at 6-inch depth intervals and stockpiled as suspect soils. Sludge and surrounding soils were excavated to approximately 6 inches below visible contamination and stockpiled for T &O. Typically, the SOBs were located I-ft bis to 3-ft bis and extended to depths of approximately 5.5-ft to 7-ft bis. After excavation, confirmation samples were collected. Table 4 presents each grid and SOB excavation details~ Table 4 . Excavation Details · Su rf,i.ci al· ; ./:,.: ,Excavafi'.on;.·,;,,, ... · · --:~,~'.l~t1,~~}} ·~•' T>ime'nsions<>ler\ 'th x'' : wi.dtn ·~. ,a~'iin · Ci:1:X>i <,:<:, >.,.?-~att;/::~t\;.:J ':-;i.Complet, o.n.1,, ·' ,. bates .c2000):: 2 50x50x3 8/8-11 5 50x50x2 8/8 6 40x20xl 8/7 8 50x50xl 8/7-15 9 50x50xl 8/16-17 11 50x50xl 8/9-17 13 50x25xl 8/18 14 50x40xl 8/3-8 18 50x40xl. 5 8/22-23 21 45x45x0.5 8/24 22 50x50x0.5 8/21-25 , . ·,i';;Sllldge .,or.yi,ng ·Beds ~>1:,; .: : .. -_i:':_ T .:·~ ""':--i4} _::.:~ -.. ,.., 0 20x12x4 8/7 1 25x15x7 8/15-.23 2 20x20x6 8/15-16 3 25x20x6 8/16 4 25x30x6.5 8/16-17 5 22x2 5x5. 5 8/17 6 22x20x7 8/18 7 25x20x6 8/18-21 8 27x20x6 8/21-22 9 27x20x6.5 8/22 10 30x25x6.5 8/22 11 25x25x6.5 8/23 • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report d. Materials Handling • Page 14 of 26 The excavated sludges and soils were segregated into three stockpiles within the staging area: (I) soils that contained metals concentrations above RLs; (2) sludges and soils that contained cyanide concentrations above RLs, or the visual presence of sludge; (3) soils pending characterization. Soils containing concentrations of metals and cyanide below RLs, based on pre-construction sampling results and the absence of sludge, were stockpiled for use as backfill. e. Post-excavation Confirmation Sampling After excavation was completed in a grid or SOB, ARCADIS collected post excavation samples. In general, for each grid or SOB sampled, a five-point composite sample was collected from the bottom of the excavation area and from each of the excavation sidewalls. Each composite sample was analyzed for hcxavalent chromium, antimony, nickel, and total and amenable cyanide. The laboratory performed Level II analysis of all samples collected and CLP/CLP-equivalent analysis for 25 percent of the samples. The analytical results indicated concentrations below the RLs for all samples. Based on these data, the EPA authorized backfill of the excavations through letters dated August 23 and 31, 2000. f. Suspect Soils On August 22 and 25, 2000, Earth Tech obtained composite samples from the suspect soil piles. Both samples were analyzed for metals and total and amenable cyanide by Test America, Inc. Analytical results were below RLs and therefore, these soils were used as backfill. g. Transportation, Treatment and Disposal EQ provided T&D for the contaminated sludges and soils. The trucks were backed into the stockpile area and Earth Tech utilized an excavator to load each truck with approximately 20 tons of waste material. The undercarriage and tires were decontaminated and the truck containers were covered for transport. A total of 147 trucks were loaded from August 8, 2000 through September 11, 2000. All loads were shipped for treatment at Michigan Disposal Waste Treatment Plant (MDWTP) (USEPA ID No. MID00072483 l) and disposal at Wayne Disposal, Inc. (WDI), Site #2 Landfill (USEPA ID# MID048090633). Both EQ facilities are located at 49350 North 194 Service Drive, Belleville, Michigan 48111. • • JFD Electronics/ Channel Master Superfund Site Page 15 of 26 Interim Remedial Action Report · Approximately 283 tons of metals-impacted soils (RQ, Environmental Hazardous Substance, Solid, N.O.S., UN3077, PGIII (F006)) were stabilized at MDWTP with a pozzolanic agent, and disposed in a subtitle C landfill at WO!. Approximately 3,282 tons of cyanide- impacted wastes (RQ, Environmental Hazardous Substance, Solid, N.O.S., 9, UN3077, PGIII (F006, F0l9)) were treated at MDWTP by alkaline chlorination, followed by reduction of hexavalent chromiu_m to trivalent chromium with ferrous sulfate. The resultant slurry was stabilized with a pozzolanic agent to bind the metals and solidify liquids. The treated material was then disposed at WDI. -h. Decontamination All equipment that came into contact with contaminated materials were decontaminated. Sediment collected in the sump was removed and included in the cyanide-impacted soils/sludge for T&D. Decontamination water was pumped from the decontamination'pad sump into storage tanks. On August 18, 2000, Earth Tech obtained samples which were analyzed by Test America, Inc. for full TCLP arid total and amenable cyanide. Analytical results indicated that only total and amenable cyanide concentrations were detected, and these concentrations were below TCLP limits. Earth Tech contracted Industrial Marine Services, Inc. (IMS) to transport this water as non-hazardous waste for off-site disposal. A total of 2,900 gallons was disposed of at IMS' s facility located in Norfolk, Virginia on September 5 and 18, 2000, After transporting the decontamination water, one storage tank was found to be impacted by solids that had settled. Therefore, the tank was shipped with the cyanide-impacted soils for disposal. The other tank and transfer pump were decontaminated and demobilized. 1. Backfill A total of 733 cy of offsite structural fill (red clayey soils and aggregate base course (ABC) stone), 140 cy of former suspect soils, and 357 cy of clean soils stockpiled within the excavation areas were used as backfill material. Backfilling and compaction occurred between August 30, 2000 and October 6, 2000. Difficulties were_ encountered due to heavy rain events, which left the soils too moist for proper compaction. These soils were disked to reduce moisture prior to backfilling. In addition, ABC was used as an alternative to soils in some areas for backfilling. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 16 of 26 The top 12 inches of backfill was a vegetative soil, totaling 1,048 cy. The surface was graded to promote drainage ·and was hydroseeded. J Site Restoration On October 3, 2000, CP&L replaced the two power poles and restored power. After remediation activities, the chain-link fence sections were reinstalled. A minimum of 3 inches of gravel under the stockpiles were removed and transported with the contaminated soils for T&D. The asphalt decontamination pad was demolished, and the asphalt and other site debris (trees, concrete, construction materials, etc.) was transported for -off-site disposal. Earth Tech demobilized all equipment and personnel. · IV. CHRONOLOGY OF EVENTS ·· With a few exceptions, most of the events are disc"retely related to either the Groundwater Remedy or the Soil/Sludge Remedy. Because of this and the fact that the Groundwater Remedy will be continuing for many years, while the Soil/Sludge Remediation has been completed, presented below are two separate tables for the Chronology of Events. Table 5 -Groundwater Remedy Chronology of Events ;fven:t: .·:-, ·.: 1-~-', C , v,,, '.':;-. •·if,,·::0,:-,. -, ',.,~,,., J' ... :' '' ,;, :, :D_ate_,,,:_,,._-,, ,;,,/,,.·;,, ., "·? '.:':,;;:;:•.;,,,;,~_-,;: Record of Decision septembe~ 10, 1992 Remedial Design work Pl an submitted November 1993 Explanation of Significant Differences January 24, 1996 Remedial Design submitted July 1996 Remedial Design Approved September 11, 1996 Mobilize/begin construction May 6, 1998 Final Inspection August 11, ,1998 Start-up #1 August 1998 shut Down September 8, 1998 Effluent Re-routed March 2000 Start-up #2 April 12, 2000 Preliminary close-out Report September 29, 2000 Downtime #1 February 26th -March gt\ 2001 Downtime #2 April 25-26, 2001 Downtime #3 August 14-17, 2001 Downtime #4 January 11-14, 2002 Downtime #5 April 17-,2002 Interim Remedial Action Report May 2002 5-Year Review September 30, 2005 JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report 'Evei1t;·~~--':·.~~ r::.:; ~ ~ -~ ~ .. ;I';-1-:::t L/: ''_:.::·;":.-""/' ,-.-:.,·-v, 1-, ... ~¥-_ .. , • ,i. -ii,·., v_ •• o.-.. r'.'•-"-;-. ~ 5-Year Review 5-Year Review 5-Year Review 5-Year Review Estimated Date of Remediation Completion Final close-out Report Deletion from the NPL Page 17 of 26 'D,a tf;!:: ;~~[1i_:t.:5'•-~ :_1·!:·. :::, "";· .. '.:1!.:'i:,~~tf:1_: .. ..:1~?t\,i September 30, 2010 September 30, 2015 September 30, 2020 September 30, 2025 April 2030 sept ember 30, 2030 March 31, 2031 ' Table 6 • Soil/Sludge Chronology of Events . ~verr1;:-·-,.,. {2-i '::.. _;;' ... ti. ~-.',_t':-,:._ :-~~,;::· ;\_ .:·,,_.-:! ·:r / _:,-.:.' .-<10:•:;;,t•1'l -~ Q~ t ~ {l~•i·,,. ~!·~:i~ ./1·-:~:,':;~f ,;r/ , ·.;•; :f_ -,i~:; Record of Decision September 10, 1992 Remedial Design Work Pl an submitted November 1993 supplemental Feasibility Study submitted 1996 ROD Amendment May 1999 Design criteria Memorandum submitted June 1999 Preliminary Design Report submitted September 13, 1999 Pre-fi na 1 Design Report submitted February 19, 2000 Final Design Report Submitted April 2000 Final Design'Report submitted Final Revisions May 23, 2000 Remedial Design Approved June 1, 2000 Pre-excavation Soil Sampling May 24-25, 2000 and July 6, 2000 Explanation of Significant Differences July 19, 2000 Mobilization/Begin Remedial Action July 24, 2000 Pre-Final Inspection September 28, 2000 Preliminary close-out Report September 29, 2000 Punch List Items completed October 2000 Final Inspection October 23, 2000 Regrading August 27, 2001 Interim Remedial Action Report May 2002 V. PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL A. Groundwater I. Performance Standards As of October, 2001, no paranieters have ever exceeded the maximum allowed in the City of Oxford Industrial Users Permit (IUP) for the treatment • JFD Electronks / Channel Master Superfund Site Interim Remedial Action Report • Page 18 of 26 effluent. With one exception, all of the VOCs have been below the laboratory's detection limit of I µg/L. In a sample obtained on January 5, 2001, Tetrachloroethylene was detected at a concentration of 1.2 µg/L. The cyanide concentrations have ranged from <0.005 to 0.019 mg/L. The higher cyanide concentrations were found during the first few months of operation. With the exception of February, March and April 200 l, the cyanide concentrations were <0.005 mg/L from November 2000 through October 2001. These values are· well below the POTW maximum concentration of0.050 mg/L. The average flow for the period of April 18, 2000 through October 200 I, was 21,250 gallons per day. The range varied between 14,000 and 26,000 gallons per day (calculated). These values are well below the POTW maximum volume of 40,000 gallons per day. As of October 2, 200 I, the total volume of water that has flown through the influent meter for treatment was l l ,681,888 gallons. As expected, VOCs concentrations were above RLs in some of the wells during the quarterly sampling of the Groundwater Monitoring Wells, the Perimeter Monitoring Wells and the Recovery Wells, during the first year of operation. Two in organics exceeded the RLs established in the ROD for one of the wells (CMMW 17) during the Annual Sampling for chromium, copper and nickel which occurred on July 26, 2000. The results showed elevated concentrations of chromium ( l 60 µg/L) and nickel ( l 20 µg/L), above the respective RLs of 50 and 100 µg/L. This particular well did not have corresponding turbidity data. Turbidity has been found in the past to upwardly affect the inorganic results. This well was resampled on July 25, 2001. The turbidity was recorded as 6.51 NTU at the time of sampling. The results were below the laboratory's detection limits of 0.010 mg/L, 0.020 mg/L and 0.040 mg/L for chromium, copper and nickel respectively, which are below the RLs established in the ROD. 2. Construction Quality Control . A Construction Quality Assurance (CQA) Plan was prepared and implemented by the consultants for the PRPs. CQA-related activities occurred throughout the construction. These activities consisted of periodic meetings and inspections; CQA testing, sampling and observations; and CQA documentation. B. Soil/Sludge l. Performance Standards The Soil/Sludge remediation successfully achieved the remediation goals. As stated previously, approximately 3,565 tons of metals-and/or cyanide-impacted wastes were removed from the Site, treated at MDWTP, and then disposed at JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report • Page 19 of 26 WDI. The excavated areas were sampled and analyzed before being backfilled. The material utilized for backfill was sampled and analyzed prior to placement. 2. Construction Quality Control A CQA Plan was prepared and implemented by the consultants for the PRPs. The CQA was generally followed with the exception of minor deviations which can be found in Section 4 of the Final Construction Report Soil/Sludge Remedial Action (Volume I), February 2002. In addition to the CQA activities performed by the PRPs consultants, representatives of NC DENR and EPA visited the Site on seventeen separate days during construction activities. The dates and times of the visits ·were not known to the PRPs' representatives or contractors, prior to arrival. In addition to randqm, unannounced Site visits, NC DENR and EPA personnel reviewed subcontractor submittals and laboratory results prior to providing approval. VI. FINAL INSPECTION AND CERTIFICATIONS A. Groundwater On August 11, 1998, representatives of EPA, NC DENR, ARCADIS and WATEC compleied a combined Pre-final/Final Inspection of the groundwater treatment system. No major construction deficiencies were identified; therefore, EPA issued a verbal authorization to proceed with the system startup once the punch list items were completed. In August 1998, the punch list items were completed. Due to cyanide concentrations exceeding surface water standards (see Section IU.A.3), the groundwater treatment system did not begin effective operation until April 2000. The groundwater treatment system is now considered operational and functional. B. Soil/Sludge On September 28, 2000, representatives of EPA, NC DENR, ARCADIS, Earth Tech, and Avnet performed a Pre-final Inspection. No major remediation deficiencies were identified; therefore, EPA issued a verbal acceptance, provided the punch-list items were completed. The 14 punch list items were completed by October 10, 2000. On October 23, 2000, representatives of EPA, NC DENR, ARCADIS and Earth Tech performed a Final Inspection. All of the punch list items were confirmed to be complete. It was noted that grass cover had not been established over the site, most likely as a-result of lack of recent precipitation. Vegetation has now been established and the remediation is considered complete. • • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report Page 20 of 26 VII. OPERATION & MAINTENANCE ACTIVITIES li:1 ~; '"" A. Groundwater The Operations and Maintenance Plan was prepared by ARCADIS and submitted as an appendix to the FDR-GW. This plan includes system startup and shutdown procedures, system maintenance, sampling and monitoring and reporting requirements. I. System Maintenance System maintenance includes visual inspection and specific maintenance tasks such as lubrication and cleaning. The maintenance frequency suggested in· the plan varies from weekly to semi-annually depending on the maintenance task. 2. Sampling and Monitoring Plan To ensure the treatment system performs as designed, and to evaluate influent and effluent water quality, a sampling and monitoring plan was implemented. As required by the permit issued by the City of Oxford, the system effluent was sampled on a weekly basis during the first three months of operation, after which a less stringent sampling schedule was negotiated. The weekly sampling of the treatment system influent and effluent began on April I 8, 2000. Since August 16, 2000, effluent sampling has been performed monthly. The sampling schedule was incorporated into the Revised Monitoring Program. Table 7 -Groundwater Monitoring Plan '":::\J~'\'.;_' '?{J' ::'• :!~,i ~'.t~ONUifo\-'?-?N~R? lPERIMETERC ;/; RECOVER'(,:;:"' ,-. ;TREATMENT~!'.?ii -1:0·1:·_TR_E.A:rME.N.T;:Wrq MONi-ToRiNG ({~;;t~ix~~~~-,',~:INFLUENT(··: >f·>:EFFl.!.UENT ~ ~, .<::/.:; "'· .. . . ··.:·;e ·.~-· "-::_~~L!i_s ~. ~ :·, :; ·.'. "'!'t~~~tS~?') ',;, ::.,,.r1:,,~:;?;_ .. ·,:J{ f;!E ,:,:.1 s1•~i~ii -----}1.i\" .. , . "'~\-.~tL 1 f~f ;-1.ST. 2~ >'-ieAR ~ ::~~ir:.,3 ·:\~--' ,,_1sT·: .", •2-~D•:: ,' ·\JSTF{\, ;;···•nt\,: ,;t~:1 ~i'_;J:~ '•~· NO" t i/1i~::.~~trf . · ,:'' '1• .YEA~' ·oNWARo·~ .\,i,YEARSY,;1' ~YEAR·, ,vyEAR :.i ;.y·EAitt t YEARi:·-' ,:hYEAR\J:1 t\il,tl ,.:: ,• i'I ,,..;{ nt:':· , . :'.l i't't·t( j ,·•--:: .:, --·r1 1aNWAR□·,: ").~'./;::} ONWARD'; _;:< -~· '.'.'; ,~\; ONWARD t'i .. .,-,, pH, Temperature, conductivity· Q s Q s A ---- Tri chl oroethene Q s Q s A W-1/Q s W-1/TM M Tetrachloroethene Q s Q s A w-1/Q s W-1/TM M 1,2-Dichloroethene (total) Q s Q s A W-1/Q s W-1/TM M 1,1-Dichloroethene Q s Q s A W-1/Q s W-1/TM M 1,2-Dichloroethane Q s Q s A w-1/Q s W-1/TM M Vinyl chloride Q s Q s A W-1/Q s W-1/TM M Copper, Nickel, chromium A -------------- Cyanide (total) --------------W-1/TM M Cyanide (amenable/total) Q' Q' ----s ------- water Table Elevation M s --M s -------- Flow -----------C C W Weekly samphng W-lffM Weekly sampling dunng first three months, Monthly sampling thereafter A Annual Sampling M Momhly sampling W-1/Q Weekly sampling during the firsl three months and quarterly thereafter Q QuarterlySampling C Continuous now monitoringS Semiannual sampling -Not applicable Monitoring well CMMW04 will be the only well sampled for total and amenable cyanide on a quarterly basis for the first 3 years of operation. • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report 3. Operation, Maintenance and Monitoring Activities Page 21 of 26 Baseline groundwater samples were collected during the week of April 3, 2000. Other sampling has occurred according to the Monitoring Plan. In July 2000, well CMMW22 was replaced with well CMMW22A. The original well was found to be missing during a regularly scheduled sampling event. In late 200 I, the CMMW22 well remains were found and the well was properly abandoned on October 5, 200 I. On October 13, 2000, a sample was collected from the two storage tanks and several 55-gallon drums which contained 'decontamination-water and we_!! development water. The results indicated that the water could be treated using the on-site treatment system. Approximately 2,719 gallons of the water was purnped through the system on December 12, 13, and I 8, 2000. The remaining nine 55- gallon drums of water was pumped through the system on January 5, 200 I. During November 2000, the control wires to recovery well cluster PW-5 were installed and connected to the control panel by Avnet personnel with the assistance of Nelms Electric. On November 17, 2000, recovery wells PW-SA, PW-SB and PW-SC were put into operation. On January 18, 200 I, routine maintenance was performed on the treatment system. The air stripper was inspected and the trays were pressure washed to remove scaling. On November 8, 200 I, City of Oxford performed their annual inspection. 4. System Interruptions On February 26, 200 I, AR CAD IS found that the system was shutdown. Based on the flow data, it was estimated that the system probably shut down on February 20 or 21, 2001. On February 28, 200 I, it was determined that the controls were damaged by a power surge. · On March 8, 200 I, a new processor was installed in the control panel, a new modem was added to the teledialer, and a surge protector was installed on .the telephone line. The system was returned to operation that same day. On July 25, 2001, recovery well PW-I was found to be shutdown due to a. tripped _electrical breaker for the pump motor. The breaker was reset and the pump was returned to operation on July 26, 2001. On August 13, 2001, the system autodialer informed AR CAD IS that _the system was shut down. On August 17, 200 I, the cause was determined to be from • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 22 of 26 a dead bird blocking the intake of the air stripper blower. The blockage was cleared and the system was restarted. On January 11, 2002, Avnet personnel discovered that a recovery well pipe was leaking and they shutdown the system. On January I 4, 2002, a cracked check valve on.the combined influent line for the PW-5 well cluster at the treatment pad was found, the valve was replaced, and the treatment system was restarted. On April 18, 2002, Avnet personnel discovered that a pipe had burst from the PW-5 well cluster, probably the day prior. The treatment system shut down that well cluster pump and Avnet personnel manually turned it off also. The PRPs' consultants are in the process of procuring a local contractor·te-replace the damaged piping. B. Soil/Sludge Because all of the soil/sludge contamination was removed from the Site, long-term operation and maintenance will not be required. Inspections and maintenance activities occurred during the first year after the remedial action was complete. These activities included inspections and maintenance of the vegetative soil cover. During April 2001, Avnet informed ARCADIS that the Bandag building had flooded during storm events. Water was entering from the southwest corner of the building. Earth Tech returned to the site on August 27, 2001 to re-grade this area and improve the drainage swale on the south side of the building. Additionally, the riprap check dams were removed and all exposed areas were re-seeded. VIII. SUMMARY OF PROJECT COSTS A. Groundwater The original present worth total cost estimate to implement the remedial action for groundwater described in the ROD was $5,181,000 (Total Capitol Costs: $2,498,000 + Total O&M Costs $2,683,00_0). The ESD did not include a revised cost estimate for the groundwater remedial action. · The·FDR-GW included the following cost estimation, assuming a 30-year operation period: Total Capital Costs Total I" Year O&M Costs Total Annual O&M Costs after year 1 TOTAL Costs $ 400,900 $ I 19,900 $ 111,700 $2,206,400 J JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 23 of 26 After the construction was completed, the PRPs estimated that the construction cost was $540,000 and estimated probable O&M costs of $150,000 per year. The reason for the major difference between the ROD Total Costs and the PRPs' estimated costs is because of the elimination of several treatment units from the ROD as documented in the ESD. This remedy alteration produced significant cost savings. B. Soil/Sludge The original present worth total cost estimate to implement the remedial action for soil and sludge described in the ROD was $1,211,000 (Total Capitol Costs: $1,090,000 + Total O&M Costs $121,000). The ROD Amendment revised the soil/sludge remedial action present worth total cost estimate to $2,582,385 (there was no breakdown of capitol and O&M costs). The ESD revised the soil/sludge remedial action present worth total cost estimate to $2,585,000 (there was no breakdown of capitol and O&M costs). The following cost information was provided by the PRPs' representative on April 5, 2002: ARCADIS and Earth Tech Oversight & Construction Activities EQ Transportation and Disposal Total Costs $ 406,522 $ 628,078 $1,034,600 The major difference between the ESD cost estimate and the PRPs' estimated total cost is primarily due to the actual volume of soil/sludge requiring excavation, costly treatment, and disposal being less than what was estimated. IX. OBSERVATIONS AND LESSONS LEARNED As is the case with the majority of hazardous waste remediation projects, what was found during the remediation varied slightly from what was projected in the RI and RD. Previously unidentified sludge seams, greater than average rainfalls, and other minor events caused the remediation to take longer than hoped. But, all parties were motivated to complete the remedial action by the end of the government fiscal year. This common goal ensured teamwork to complete the remediation on schedule. Each entity worked diligently to make this goal a reality. / . X. CONTACT INFORMATION A. EPA There were two RPMs involved with this Site. Mr. McKenzie Mallary served as the RPM through December 1999. Ms. Samantha Urquhart-Foster served as the RPM from January 2000 until present. • JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report Ms. Samantha Urquhart-Foster • Page 24 of 26 (404) 562-8760, e-mail: urguhart-foster.samantha@epamail.epa.gov Mr. McKenzie Mallary ( 404) 562-8802, 4WD-NSMB e-mail: mallary.ken@epamail.epa.gov US Environmental Protection Agency 61 Forsyth Street, SW Atlanta, GA 30303 B. North Carolina Department of Environment and.Natural Resources Mr. David B. Mattison, CHMM Environmental Engineer NC Department of Environment and Natural Resources -Superfund Section 401 Oberlin Road, Suite 150 Raleigh, NC 27605 (919) 733-2801 ext. 349, e-mail: david.mattison@ncmail.net C. PRPs Mr. Brian Kempner Vice President & General Counsel The Shepaug Corporation 54 East 64th Street New York, NY 10021 e-m~il: bkempner@observer.com D. PRPs' Contractors Mr. S. Alan Lazar Avnet, Inc. 2211 South 47th Street Phoenix, AZ 85034 e-mail: sandy.lazar@avnet.com l. RD, Construction Project Management, Oversight, Quality Assurance a. ENSR International According to the Consent Decree, the primary contact for the PRPs is William Doucette. During the RD and RA, Dr. Doucette was employed by ARCADIS. During O&M, he transferred to ENSR International. William H. Doucette, Jr., Ph.D., L.G. Senior Program Manager ENSR International 7041 Old Wake Forest Road Raleigh, NC 27616-3013 (919) 892-6600 ext. 249, e-mail: Bdoucctte@ENSR.com • JFD Electronics/ Channel Master Superfund Site Interim Remedial Action Report • Page 25 of 26 The secondary contact for this project has been Nanjun Shelly. He was also employed by ARCADIS but is now employed by ENSR. Mr. Nanjun V. Shelly, PE Senior Program Manager ENSR International 7041 Old Wake Forest Road Raleigh, NC 27616-3013 (919) 892-6600 ext. 249, e-mail: Nshetty@ENSR.com b. ARCADIS Geraghty & Miller of North Carolina, Inc. As stated above, during the RD, RA and Operational and Functional (O&F) determination period, the primary and secondary contacts for this Site were William Doucette and Nanjun Shelly, who were at that time employed by ARCADIS. Numerous other ARCADIS personnel were involved with this project. ARCADIS Geraghty & Miller of North Carolina, Inc. 2301 Rexwoods Drive, Suite 102 Raleigh, NC 27607 2. Groundwater Remediation System Waste Abatement Technology, Inc. -North Carolina 3. Soil/Sludge Remediation Earth Tech performed the construction activities for the soil/sludge excavation. The primary on-site contact was: Mr. Michael Gleasman Earth Tech, Inc. 7870 Villa Park Drive, Suite 400 Richmond, Virginia 23228 EQ was responsible for transportation, treatment and disposal of the soil/sludge waste. They utilized two facilities for this endeavor: Michigan Disposal Waste Treatment Plant and Wayne Disposal, Inc. Both are located at the following address: The Environmental Quality Company 49350 N. 1-94 Service Drive Belleville, Michigan 48111 • JFD Electronics / Channel Master Superfund Site Interim Remedial Action Report APPENDIX A -REFERENCES • Page 26 of 26 I. , ARCADIS Geraghty & Miller, 2002. Final Construction Report, Soil/Sludge Remedial Action, JFD Electronics/Channel Master Site, Oxford, North Carolina. February 2002. 2. ARCADIS Geraghty & Miller, 2000. Final Construction Report, Groundwater Remediation, Revision I, JFD Electronics/Channel Master Site, Oxford, North Carolina. December 2000. 3. Geraghty & Miller, Inc. 1996. Final Design Report, Groundwater Remediation, JFD Electronics/Channel Master NPL Site, Oxford, North Carolina. July 1996. 4. United States District Court, 1993. In the United States District Court for the Eastern District of North Carolina, Raleigh Division. United States of America, Plaintiffs, v. JFD Electronics Corporation and Channel Master Satellite Systems, Inc., Defendants. Civil Action #93-650-CIV-5-B. Consent Decree. December 23, 1993. 5. United States Environmental Protection Agency, 2000. Preliminary Close Out Report, JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. September 29, 2000. 6. United States Environmental Protection Agency, 2000, Explanation of Significant Difference to the Remedial Action for the JFD Electronics/Channel Master Site, Oxford, Granville Co_unty, North Carolina. July 19, 2000. 7. United States Environmental Protection Agency, 2000. Close Out Procedures for National Priorities List Sites. EPA 540-R-98-016, OSWER Directive 9320.2-09A-P, PB98-963223. January 2000. 8. United States Environmental Protection Agency, 1999. Amendment to the 1992 Record of Decision, Remedial Alternatives Selection, JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. May 4, 1999. 9. United States Environmental Protection Agency, 1996. Explanation of Significant Difference to the Remedial Action for the JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. January 24, 1996. 10. United States Environmental Protection Agency, 1992. ,Record of Decision, Summary of Remedial Alternative Selection, JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. September 10, 1992. • ~ • , r: :-------- uN1TEo STATES ENVIRO~~G~~~ ~L PROTECTION AGE1~?:tJ r1E-~:/j-) · \Vi· ff 4WD-NSMB Mr. David Mattison NC DENR Superfund Section 40 I Oberlin Road, Suite 150 Raleigh, NC 27605 ATLANTA FEDERAL CENTER f" / !f . 61 FORSYTH STREET I'., , . APR ATLANTA, GEORGIA 30303-8960 I ' -4 2002 ' / .. , L:· April 3, 2002 SUBJECT: (I) DRAFT Interim Remedial Action Report, JFD Electronics/Channel Master Site (2) Constructed Wetlands Presentation Package Dear Mr. Mattison: As we discussed briefly a few weeks ago, I'm requesting that you review the enclosed DRAFT Interim Remedial Action Report for the JFD Electronics/Channel Master Site. I am still waiting on final costs from ENSR, but expect them within the next week. Also, as you requested, 1 am including a copy of the package WESTON representatives handed out at the Constructed Wetlands presentation on March 28, 2002. This process will be included in the Feasibility Study for the Reasor Chemical Co. Site for the groundwater/surface water media. If you have any questions, I can be reached at (404) 562-8760 or by e-mail at urquhart- foster.samantha@epamail.epa.gov. Enclosures (2) Sincerely, il~k Samantha Urquhart-Foster Remedial Project Manager North Site Management Branch Internet Address (URL) • http://www.epa.gov Recycled/Recyclable •Printed with Vegetable OH Based Inks on Recyded Paper (Minimum 30% Poslconsumer) • • Draft INTERIM REMEDIAL ACTION REPORT JFD ELECTRONICS/CHANNEL MASTER SUPERFUND SITE Oxford, Granville County, North Carolina Prepared by United States Environmental Protection Agency April 2002 • • r;Interim Remedial ActionReport JFD Elettroilics"'/;'efiaiufel\Mliiter·Supe~und Site 11 II II ,-c:;::I II I' Record of/PreP,aration-;-RevieM', and Approval l.::::::1/ u ~ t'...I '8 Groundwater Pump and Treat Excavation and Off-site Treatment/Disposal of Contaminated Soils and Sludge This report has been prepared in accordance with EPA OSWER Directive 9320.2-09A and will be used as the basis for development of the site Final Close Out Report. Signature Samantha Urquhart·Foster Prepared Remedial Project Manager By: US EPA Region 4 . Date Signature Reviewed Philip Vorsatz By: Chief, NC Site Management Section US EPA Region 4 Date Signature Approved Franklin Hill By: Chief,· North Site Management Branch US EPA Region 4 Date • • JFD Electronics / Channel Master Superfund Site Page i ,m .. ,m R,rn«fa>Act<oo R,pob ~ --_j L t Dmk,p,;,;,oou "'"'"' I. INTRODUCTION ..... •. ~fUB.CE-~~N-TIT.TS ..... -..................... -l A. Location, Size, Environmental Setting, and Operational History ............. l B. Operations and Waste Management Practices ............................ l · C. Regulatory and Enforcement History ................................... l D. Major Finding and Results of Site Investigation Activities .................. ;?_ I. North Carolina Department of Human Resources Site Inspection ...... ;?_ 2. ATSDR and EPA Site Visits ................................... ;?_ 3. Remedial Investigation ....................................... ;?_ 4. Risk Assessment ............................................ } E. Prior Removal and Remedial Activities ................................ } F. Operable Units .................................................... }" Il. OPERABLE UNIT BACKGROUND ...... : ................................. } A. Groundwater ..................................................... ± l. Cleanup Goals .............................................. ± 2. Remedy Selected in the ROD .................................. ± 3. Remedial Design ............................................ 2_ 4. Explanation of Significant Differences ........................... 2_ B. Soil/Sludge ....................................................... §_ I. Cleanup Goals ............................................... §_ 2. Remedy Selected in the ROD .................................. §_ 3. ROD Amendment ........................................... §_ 4. Remedial Design ............................................ §_ 5. Explanation of Significant Differences ..................... : ..... Z . Ill CONSTRUCTION ACTIVITIES ........................................... 2 A. Groundwater ..................................................... Z l. Pre-construction Activities ..................................... Z 2. Remedial Construction ............................. : .......... .8. 3. System Startup .............................................. 2 4. Treatment System Modification ................................ l.Q 5. System Restart ............................................. l.Q B. Soil/Sludge ...................................................... l.Q I. Pre-construction Activities ..................... • ............... l.Q a. Contractor Procurement and Access Agreement ............. l.Q b. Pre-excavation Confirmation Sampling .................... ll c. Pre-construction Conference ............................ ll 2. Remedial Construction ....................................... ll a. Mobilization/Site Setup ................................ ll b. Site Health and Safety Controls .......................... U c. Material Removal ..................................... U d. Materials Handling .................................... l± • • JFD Electronics/ Channel Master Superfund Site Page ii Interim Remedial Action Report ~ Draft April 3, 2002 ( 12:36PM) nr:::-i ~c-1·· ..J.L:--s ~1-· 14 e. st1excavat1on_ on 1rmat1on amp mg .................. . f. !peel Soils .6. ! ... ! ! ..... ! ! ...................... 14 ...., ., 11 · 1_,4,_..,,,, 1-1 d D' L."-1i -14 g. -,-ransp0rtat1on, •,.1eatment an 1sp0sa ................... _ h. Decontamination ..................................... 12 1. Backfill .......................... : .................. 12 J. Site Restoration ..................................... -12 IV. CHRONOLOGY OF EVENTS ............................................ 16 V. PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL .. .LZ A. Groundwater ................................................... -lZ I. Performance Standards ...................................... lZ 2. Construction Quality Control .................................. .IB B. Soil/Sludge ...................................................... _IB I. Performance Standards ...................................... .IB 2. Construction Quality Control ............................. · ..... .IB VI. FINAL INSPECTION AND CERTIFICATIONS ............................. -.12 A. Groundwater ......................................... , ......... : .12 B. Soil/Sludge ...................................................... .12 Vli. OPERATION & MAINTENANCE ACTIVITIES ............................. .12 A. Groundwater ..................................................... .12 I. System Maintenance ........................................ 20 2. Sampling and Monitoring Plan ................................ 20 3. Operation, Maintenance and Monitoring Activities ................ ;u 4. System Interruptions .................................... · .... 21 B. Soil/Sludge ...................................................... 22 VIII. SUMMARY OF PROJECT COSTS ........................................ 22 A. Groundwater .................................................... 22 B. Soil/Sludge ...................................................... 23 IX. OBSERVATIONS AND LESSONS LEARNED .............................. 23 X. CONTACT INFORMATION ............................................. 23 A. EPA ........................................................... 23 B. North Carolina Department of Environment and Natural Resources ......... 24 C. PPRs ........................................................... 24 D. PRPs' Contractors ................................................ 24 I. RD, Construction Project Management, Oversight, Quality Assurance . 24 2. Groundwater Remediation System ............................. 25 3. Soil/Sludge Remediation .................. • ................... 25 • • JFD Electronics/ Channel Master Superfund Site Page iii Interim Remedial Action Report ,,........,., Draft April 3, 2002 (12:36PM) APPENDIX A. REFERFD r@t t ................... 26 LIST OFT ABLES Table 1 -Groundwater Remediation Levels ......................................... ± Table 2 -Soil Remediation Levels ................................................. Q Table 3 -Well Construction Details ............................................... Ji Table 4 -Excavation Details .................................................... U Table 5 -Groundwater Remedy Chronology of Events ................................ J.§ Table 6 -Soil/Sludge Chronology of Events ........................................ 11 Table 7 -Groundwater Monitoring Plan ........................................... 20 r • • JFD Electronics/ Channel Master Supcrfund Site Page I of 26 Interim Remedial Action Report ,.--,, Draft April 3, 2002 ( 12:36PM) ~ ,..,,,....., ~ ..JL ,JL.., .. INTERIM1RENIEDIAli, ACT!ION-REPORT · II 11 II ...-= l'I II JFD ELECTROl',I.C§/C~AN~jzM~uSTER~~PERFUND SITE. OXFORD, GRANVILLE COUNTY, NORTH CAROLINA EPA CERCLIS ID NUMBER NCD122263825 I. INTRODUCTION A. Location, Size, Environmental Setting, and Operational History The JFD Electronics/Channel Master Superfund Site (the Site) is approximately 13 acres in size and is located at the corner of Industrial Drive and Pine Tree Road, approximately 2 ll)iles southwest of Oxford, in Granville County, North Carolina. The main building at the Site is currently being utilized by Avnet as a warehouse distribution center. The smaller building on-site is currently being used by the Bandag Corporation as a distribution warehouse. B. Operations and Waste Management Practices that Contributed to Contamination JFD Electronics (a subsidiary of Unimax Corporation) manufactured television antennas from 1961 to 1979 at the Sit_e. An unlined lagoon was built during 1964-1965 to dispose of wastewater and sludges generated from a chromate conversion process and a copper/nickel electroplating process. The lagoon reportedly held from 800,000 to 1,000,000 gallons of sludge during its operation. Wastes generated from the processes contained a number of metals, including chromium, lead, and cyanide. Wastewater was treated in an on-site treatment plant. Sludge was disposed of in the lagoon and in eleven sludge drying beds (SDBs) along the southern property boundary. In October 1979, Channel Master Satellite Systems, Inc. (a subsidiary of Avnet Inc.) began leasing the Site. Channel Master purchased the property in 1980 and used it until 1984 to produce satellite antennas, amplifiers and boosters. Organic solvents were reportedly used on-site for cleaning tools and antenna elements prior io sending them off- site for electroplating. C. · Regulatory and Enforcement History The United States Environmental Protection Agency (EPA) proposed the Site to the National Priorities List (NPL) on June 24, 1988 (53 FR 23988), and added it to the final list on October 4, 1989 (54 FR 41000). On April 25, 1989, EPA sent special notice letters to: (I) Unimax Corporation, (2) Channel Master, and (3) Granville Industrial Developers. The letters requested that these potentially responsible parties (PRPs) conduct a Remedial Investigation and Feasibility Study (Rl/FS) at the Site. The notice letters also informed the PRPs of their liability for past costs. The PRPs declined to perform the Rl/FS. On November 9, 1989, EPA sent a letter to the PRPs informing them of EPA' s decision to conduct a fund-lead Rl/FS at the Site: • • JFD Electronics I Channel Master Superfund Site Page 2 or 26 Interim Remedial Action Report ,,--, Draft April 3, 2002 (12:36PM) Following t~S, f'<26hlen'rii?reerd1a~"n-e1g~between EPA, JFD . I ! I· I 11 ..--' I 1 . I ·I Electromcs Corporation, and C::hannel(Master Satellite Systems, Inc. to perform the R d' ID . 1d1·R// d'111A. \.....-'\ !I db 111:J. dS D' . J d eme ia es1gn an -eme ia ct1on-irwas s1gne y a, • ri1te tates 1stnct u ge on December 23, 1993. D. Major Finding and Results of Site Investigation Activities I. North Carolina Department of Human Resources Site Inspection The North Carolina Department of Human Resources -CERCLA unit (NCDHR-CERCLA) (now called North Carolina Department of Environment and Natural Resources (NC DENR)) conducted a Site Inspection in 1987. Analysis of the lagoon sludge and adjacent soils revealed the presence of chromium, lead, arsenic, cyanide and volatile organic compounds (VOCs). Analysis of the groundwater revealed the presence of dichloroethane, trichloroethene, tetrachloroethene and xylene. 2. ATSDR and EPA Site Visits Site visits were conducted by representatives of the Agency for Toxic Substances and Disease Registry (A TSDR) in March 1989 and by EPA in September 1989. Based on these inspections and other information, both EPA and ATSDR concluded that contamination still existed at the Site which warranted further investigation. Site contamination included soils and groundwater contaminated with VOCs, and metal-contaminated soil/sludge associated with the SDBs. 3. Remedial Investigation Bechtel Environmental, Inc. (Bechtel), EPA's contractor, submitted the Final Rl/FS in April 1992. The RI stated that industrial activities resulted in two potential contamination source areas. The first was the release of VOCs in the south parking lot area, which extended to the subsurface. The second was the placement of metal sludges in SDBs and the settlement lagoon. The RI determined that the shallow and deep groundwater tables were contaminated with VOCs (maximum total VOC concentration of 364,410 micrograms per Liter (µg/L)) and the surficial and sub-surficial soils and sludges are contaminated with heavy metals at the following maximum concentrations (chromium ( I 00,000 milligrams per kilogram (mg/kg)), nickel (36,000 mg/kg), zinc (2,000 mg/kg), copper (1,600 mg/kg)) and cyanide (estimated at 230 mg/kg). • • JFD Electronics/ Channel Master Superfund Site Page 3 of 26 Interim Remedial Action Report ,,..---., Draft April 3, 2002 ( 12:36PM) Ris,r,m~tA c31 7 r ir The RisJsseUment inQted that under the:current land-use scenario, 4. the greatest concern is of adverse noncarcinogenic effects due to ingestion . exposure of onsite facility workers to chromium in the SDB area. The high concentrations of metals in the SDBs were also of potential concern with respect to migration to groundwater. Under future land-use scenarios, the use of groundwater was of concern. Although exposure was hypothesized for a future resident, the continued migration of these mobile chemicals to existing downgradient residential wells was of great concern. The contaminants of concern identified in the Risk Assessment for groundwater included: Benzene, 1,2-Dichloroethane, I, 1-Dichloroethene, 1,2- Dichloroethene, Tetrachloroethene, I, 1, I-Trichloroethane, Trichloroethene, Vinyl chloride, Barium, Chromium, Copper, Lead, Nickel, Zinc and Cyanide. The contaminants of concern identified in the Risk Assessment for soil/sludge included: Antimony, Cadmium, Chromium, Copper, Nickel, Zinc and Cyanide. E. Prior Removal and Remedial Activities As a result of the Site Investigation, Channel_ Master initiated cleanup activities in June 1987 under the supervision of NCDHR-CERCLA. These activities included excavating approximately 17,000 cubic yards (cy) of contaminated soil/sludge and disposing of it in a permitted waste disposal facility. Approximately 2,000 cy of VOC- contaminated soil were also excavated and thermally treated. In July 1988, Channel Master excavated and disposed of two fuel oil tanks and one concrete waste oil tank. F. Operable Units There is only one Operable Unit (OU) for this Site. The Remedial Action for which this Report discusses will be broken down into two components: ( 1) Groundwater, and (2) Soil/Sludge. II. OPERABLE UNIT BACKGROUND As just stated, there is only one OU for this Site. The Record of Decision (ROD) was signed on September 10, 1992. Although there is only one OU, the Site can be broken into two components: Groundwater and Soil/Sludge. For both components, the remedy selected in the ROD was modified through an Explanation of Significant Differences (ESD) and/or a ROD Amendment. This section is organized according to the components. The Cleanup Goals are discussed first, followed by the original remedy selected in the ROD, the revised remedies according to the Explanation of Significant Differences and/or ROD Amendments, and a summary of the Remedial Design. • • JFD Electronics / Channel Master Superfund Site Page 4 of 26 '"'""" :em«•~::::::::ib r 5') t.,. .. , t··. Draft April 3, 2002 ( 12:36PM) 1. Clealrnp-6oals (QJ:, · The Groundwater Remediation Levels (RLs) established in the ROD were the Safe Drinking Water Act Maximum Contaminant Levels (MCLs) or North Carolina water quality standards, whichever were more protective. The groundwater RLs selected for the Site are listed in Table 1. Table 1 • Groundwater Remediation Levels Contaminant of Remediation Levels concern (µg/L) Benzene 5 1,2-Dichloroethane 0.38 1,1-Dichloroethene 7 1,2-Dichloroethene 70 Tetrachloroethene 0.7 1,1,1-Trichloroethane 200 Trichloroethene 2.8 Vinyl chloride 0.015 Barium 1,000 chromium 50 Copper 1,000 Lead 20 Nickel 100 Zinc 500 Cyanide 154 2. Remedy Selected in the ROD The groundwater remedy selected in the ROD was alternative 4: Groundwater Extraction, Treatment with Alkaline Chlorination, . Precipitation/Filtration, Air Stripping, and Carbon Adsorption. The ROD called for the extraction of groundwater contaminated above the RLs from the affected area. The contaminated aquifer would be remediated until the RLs are achieved. Discharge of the· treated groundwater would be either to the local, publicly owned treatment works (POTW), or as surface water discharge to an unnamed branch of Fishing Creek. Discharges would comply with ARARs listed in the ROD. • • JFD Electronics / Channel Master Supcrfund Site Page 5 of 26 '"'"°" R,m-,;•:Act•• :::r&,in?J ~ 7 f • f[= Dm' "riU,OOU,dO,M ARGADlS Gernghty &,Miller-(ARCADIS);-cotisultants for the PRPs, submitted a Remedial Design Work Plan in November 1993. They submitted a Preliminary Design Report in July I 995 and a Pre-Final Design Report on February 6, 1996. The Final Design Report for the Groundwater Remediation (FDR-GW) was submitted to EPA in July 1996 and was approved by EPA on September 11, 1996. During the Remedial Design (RD) process, pre-design data collection activities occurred between July I 994 and March I 995. The results were utilized in preparation of the Final Design, which varied from what was prescribed in the ROD. A significant finding of this data collection was that the RLs for dissolved metals were not exceeded based on analyses of groundwater samples collected using revised sampling techniques. Previously detected metals in the groundwater were likely the result of turbid samples. The Final Design called for seven recovery wells pumping groundwater contaminated with VOCs into a low-profile air stripper. The treated groundwater from the air stripper would be discharged to a nearby intermittent stream. 4. Explanation of Significant Differences During the RD, ARCADIS collected additional groundwater data which indicated that several changes could be made to make the remedy more efficient and cost effective. On January 24, 1996, an ESD was signed which changed the groundwater remedy. The Alkaline Chlorination, Precipitation/Filtration and Carbon Adsorption treatment methods were conditionally eliminated. These steps would be added back to the system if monitoring after system start-up showed exceedance of POTW or surface water standards (depending on where the effluent would be discharged) for cyanide, metals or VOCs. Therefore, the revised remedy included: • Six or more extraction wells placed along the plume; • Extraction of groundwater that is contaminated above the RLs; • Passage of extracted groundwater through an equalization tank for pH and temperature adjustment and flow equalization; • Removal of VOCs from the groundwater via Air Stripping; • Discharge of treated groundwater to surface water or POTW; and • Continued analytical monitoring for contaminants in groundwater. • • JFD Electronics/ Channel Master Superfund Site Page 6 of 26 ::.:In.:..:t.::;er:::im:::....:R::.:e:::m::.:e;.;:d::::ia::.l::.:A:.:c::::tio::.:n::...:..:RCJepccoccr.:..t __________ Af"7"'''='""'"'' ___ ..:D:.;r.;.a.;.ft.;.;A:..p;..;ri:.;! 3:..:,..:2.:..0::.:02:.......c( 1.::2:..:::3;.;:6.:...P:.;;M.:..! B. Soil/Sludge I. At the time the ROD was written, there were no promulgated Federal or State standards applicable to the contaminants in the soil/sludge at the Site. RLs were calculated based on direct exposure residential assumptions for contamination identified in the soil/sludge. These levels are at the I o-6 end of the protective risk range and are included in Table 2. Table 2 -Soil Remediation Levels contaminant of. cC • ,Remedi at.ion, Leve,l s:' ,c,oncern, ' ,-' (mg/kg),•,,,:, '.:',, i''' ii',, °'c,,,, _' ,,, ,, ? L: ci,;' chromium (Cr '') 310 Nickel 1,100 Antimony 25 Cyanide (total) 590 cyanide (amenable) 30 2. Remedy Selected in the ROD The soil and sludge remedy selected in the ROD was Alternative 4: Excavation, Treatment with Oxidation-Reduction, Stabilization, On-site Disposal, and Capping. A Treatability Study was required during the RD. The remedy that was selected in the ROD was modified through a ROD Amendment and an ESD. 3. ROD Amendment Treatability Studies conducted in 1994 and 1995 found that soils and sludges contaminated with cyanide could not feasiblely be treated on-site to meet treatment standards. Therefore, in May 1999, the ROD was amended. The ROD Amendment divided the soil and sludge into two categories: (I) cyanide-and metals-contaminated soil/sludge, and (2) metals-contaminated soils. Both categories would be excavated. The cyanide-contaminated soil/sludge would be transported off-site for treatment and disposal. The metals-contaminated soil would be stabilized on-site with Portland Cement, then placed back on-site and covered with a vegetative cover. 4. Remedial Design A Remedial Design Work Plan was prepared and submitted to the US EPA and NC DENR in November 1993. A Design Criteria Memorandum was developed in June 1999. Following that memorandum, a Preliminary Design • • JFD Electronics/ Channel Master Superfund Site Page 7 of 26 Interim Remedial Action Report ~ Draft April 3, 2002 ( 12:36PM) Report was ~ed ir\~tel~) 9§9{ [th~ $al Design Report was submitted irl FebrUryi2000. 'P~inal D~sign Re~ort Soil/Sludge Remediation (FDR-SS) Ja's:<ul5mit!dd in M·a?cn·2000. Lthe Fin~kRevisions were submitted on May 23, 2000. These revisions were reviewed by EPA and NC DENR and the FDR-SS was approved by EPA on June I, 2000. 5. Explanation of Significant Differences After the FDR was finalized, and just prior to the Remedial Action, surficial soil sampling showed that the extent of surficial soil metals-contamination was much less than previously estimated. The drastic decrease in soil volume made on-site treatment and disposal not very efficient or cost effective. Therefore, an ESD was signed by Richard D. Green on July I 9, 2000, changing the soil/sludge remedy. The revised remedy included: • Excavate approximately 2,300 cy of cyanide-impacted sludge and 650 cy of metals-impacted soils; • Transport the wastes to an appropriate treatment and disposal facility; • Treat the sludge with alkaline chlorination to reduce levels of cyanide; • Reduce hexavalent chromium in the sludge to trivalent chromium; • Stabilize the sludge and soils for metals to reach the disposal requirements established by the disposal facility; • Dispose of the treated and stabilized wastes in the off-site facility; and • Backfill, grade, cover and seed the excavated areas. III. CONSTRUCTION ACTIVITIES A. Groundwater A detailed description of the remedial action can be found in the Final Construction Report, Groundwater Remediation, Revision I prepared by ARCADIS in December 2000. The following is a brief summary taken from the document. 1. Pre-construction Activities Upon approval of the FDR-GW, ARCADTS prepared and distributed bid documents. A pre-bid meeting was held on December 5, 1996, and bids were received later that month. Waste Abatement Technologies, Inc. (WATEC) was selected to construct the groundwater remediation system. Construction did not begin immediately due to a delay in obtaining access agreements from off-site property owners. The final access agreement was obtained in February 1998.' ARCADIS executed the contract with W ATEC in March 1998. • JFD Electronics/ Channel Master Superfund Site Page 8 of 26 Interim Remedial Action Report ,.-,-, Draft April 3, 2002 (12:36PM) AR,.,~A'""'DI. S ri_,/('Q~ ~ ..J •l,,,.., "~h" f "I purcuaseu maJor equ1r1ment ,orl t e treatment system rom several vendors dJring March ~pril t'98. Th~equ. ipment was delivered d . h IL__,,/ ii . lL.,)t unng t e system construct10n~ - A pre-construction conference was held on April 12, 1998 and was attended by representatives of ARCADIS, Avnet, EPA, NC DENR and WATEC. A conference summary report was submitted to EPA in June 1998. 2. Remedial Construction WA TEC mobilized to the site and began the treatment system construction on May 6, 1998. A field construction trailer and utilities were installed. An offsite access road was built for installation and maintenance of the offsite wells. Richard Simmons Drilling Company, Inc. installed six new recovery wells: PW-2, PW-3, PW-4, PW-SA, PW-SB and PW-SC. (Well PW-I was installed in December 1994 during design activities.) Well installation and development occurred between May 18, 1998 and June 5, 1998. All wells were constructed of 6-inch diameter stainless steel piping. Additional information regarding the specific well construction is found in the following table: Table'3 -Well Construction Details WELL NAME DATE DRILLED DEPTH PW-2 06/04/1998 37 feet PW-3 06/02/1998 24 feet PW-4 06/03/1998 58 feet PW-SA 05/28/1998 25 feet PW-5B 05/27/1998 25 feet PW-SC 05/27/1998 25 feet Drill cuttings were placed into roll-off containers, sampled and analyzed. The results indicated that they were not hazardous. They were transported and disposed of at Piedmont Landfill and Recycling Center in Kernersville, NC. , WA TEC began trenching and installing pipes in May 1998. CT &L Engineering performed compaction testing for the soil backfilled over piping trenches. All underground pipes were made of high-density polyethylene (HOPE), · and aboveground pipes were made of Schedule 40 chlorinated polyvinyl chloride (CPVC). To protect from freezing temperatures, the CPVC pipes ·at the treatment pad were heat traced an.d insulated. An electrical submersible pump was installed in each recovery well. • • JFD Electronics/ Channel Master Superfund Site Page 9 of 26 Interim Remedial Action Report ,,.....,......, Draft April 3, 2002 ( 12:36PM) In Ju~8, Ii'tfnristfion dtt1~e-r~cs{L-,~ery·wells, step-drawdown tests II 'I II ~· 'I I were performed on wells PW-2rP_)'l3 anti PW-4. Groundwater flow rates were estimated to1.ik.1ialldds per n\i'iiute.(gp1ri), 2 gpm, ~nd 8 gpm, respectively. At the end of the test, a groundwater sample was collected for VOC analysis. A 9-inch-thick reinforced concrete pad was constructed. The low-profile air stripper, motor control center and control panel were then anchored on the concrete pad. A canopy was constructed over the treatment system. All recovery well pipes were connected to the air stripper through a common header pipe equipped with a flow meter/totalizer, a control valve, and a sample port. The air stripper is Shallow Tray Model 2341 equipped with a 7 .5 horsepower air blower. Exhaust from the air stripper is connected to a 26-foot- high discharge stack using a 7-inch-diameter fiberglass flexible pipe and a 6-inch- diameter Schedule 40 PVC rigid pipe. The air discharge stack is supported by a timber pole. The groundwater treatment system is controlled by a central control panel. The control panel also houses a prografrunable logic control and an auto dialer to notify remote personnel of alarm conditions. The control panel displays run lights and on/off switches for each recovery well pump, the air stripper, and the blower. The wells are equipped with switches lo operate or shut down the pumps based on water levels. The air stripper blower is equipped with a low air-flow switch, and the air stripper sump is equipped with a high water-level switch to shut down the entire system and prevent discharge of untreated water. The effluent line consists of 4-inch-diameter HOPE pipe. This pipe gravity drained to the unnamed tributary of Fishing Creek. The top 18-inches of excavated soils above the effluent line were stockpiled, sampled and analyzed. The results were below the soil RLs, so the soils were used for backfilling trenches. The well development water and decontamination water was containerized in 55-gallon drums and two polyethylene tanks. This water was pumped through the treatment system in December 2000 and January 200 I (see section VllA.3). 3. System Startup The system startup/trouble shooting was initiated soon after the final inspection. A few minor adjustments and modifications were made during August 10-28, 1998. On August 13, 1998, well CMMW04 was pumped for 12 hours as a temporary measure to reduce cyanide concentrations. The water was transferred into a steel tanker, sampled and analyzed. Because of the e,ievated cyanide • • JFD Electronics/ Channel Master Superfund Site Page IO of 26 Interim Remedial Action Report ,,....-, Draft April 3, 2002 ( 12:36PM) concentratio~118 m~)\]th[-wa. th ~Jreate~zardous with a waste code 11.-. I 1 · ,1..,-, I 11 I I of F009. On tebrnary ~. l 999t' [_heJ3,854 ,g,allons otlwater was transported to Heritage En~iron'~ental Services;;rnb. in Qharlotte~N6 for treatment/disposal. The system began operation during the last week of August I 998. The first samples from the treatment system effluent were collected on September 2, 2000. The analytical results indicated that total cyanide concentration in the effluent was 22 µg/L, which exceeded the discharge limit of 5 µg/L. Upon receipt of the analytical results, the system was shut down on September 8, 1998. 4. Treatment System Modification The City of Oxford issued the PRPs a General Sewer User Permit, which became effective on September I, 1999, and currently has an expiration date of December 31, 2002. In March 2000, a new effluent pipe was installed and connected to the city's sanitary sewer located southeast of the treatment pad. The new piping included a ball valve, a check valve, and two clean-outs. A ball valve was installed on the original discharge line to disallow flow to the creek. PVC piping and fittings were used for the new discharge line. GARCO, Inc. completed the effluent line installation to the property fence line. The City of Oxford completed the sewer tap and final connection. 5. System Restart After the effluent discharge lines were modified, the system was returned to operation on April 12, 2000. Recovery wells PW-I, PW-2, PW-3 and PW-4 were put into operation on that date. However, the PW-5 well cluster was not put into operation until November 17, 2000, because of the Enhanced Reductive Dechlorination pilot test ongoing in that area. B. Soil/Sludge A detailed description of the remedial action can be found in the Final Constrnction Report, Soil/Sludge Remedial Action (Volume I) prepared by ARCADIS in February 2002. The following is a brief summary taken from that document. I. Pre-construction Activities a. Contractor Procurement and Access Agreement Separate bids were obtained for the on-site remediation activities and off-site transportation, treatment and disposal (T&D). Bid documents were distributed on April 17, 2000. A pre-bid meeting was held four days later and bids were received on May Ii, 2000. Notices to Proceed were • JFD Electronics/ Channel Master Superfund Site Page 11 of 26 Interim Remedial Action Report ,........, Draft April 3, 2002 ( 12:36PM) prov~ J~~2000ToEard]+etK t~rm the soil/sludge removal 1 1 " II ..--:='I I ·I and backfillin~ operations--;-and to Safety ~een for T&D of contaminated ·1 1111--,(/ H 1 '-1d..,; 1 S J I Kl It . b·1· b . h so, s,s uuge. owever, ue'to aiety eencs:nia 1 1ty too tam t e required bond, their contract was terminated and The Environmental Quality Company (EQ) was given a Notice to Proceed on July 19, 2000. The access agreement was executed by Norfolk Southern Corporation (NSC) on June 14, 2000. NSC issued a letter dated June 30, 2000 approving collection of soil samples on their property. b. Pre-excavation Confirmation Sampling As proposed in the FDR-SS, ARCADIS collected soil samples to further delineate areas with surficial soil contamination. The on-site soils were sampled on May 24-25, 2000, and the soils on the NSC easement were sampled on July 6, 2000. The samples were collected at three depth intervals: 0-0.5 feet below the land surface (ft bis), 0.5-1 ft bis and 1-1.5 ft bis. They were analyzed using Level II data quality objectives, with 25 percent also analyzed using the Contract Laboratory Program (CLP)/CLP- equivalent methods. Based on this sampling event, only six surface grids required remediation with an estimated volume of 600 -700 cy. c. Pre-construction Conference On June 12, 2000, a preconstruction conference was held with representatives of ARCADIS, Avnet, EPA, NC DENR, Earth Tech and Safety Kleen. In addition to discussing roles and responsibilities, health and safety, etc., the results of the soil sampling performed on May 24-25, 2000 were presented. 2. Remedial Construction a. Mobilization/Site Setup Earth Tech mobilized to the site on July 24, 2000. Prior to excavation, the area was cleared of vegetation. Sections of the chain-link fence were removed and safety fencing was tied into existing fencing to secure the area. Stormwater management controls were utilized, which included silt fencing, diversion ditches, temporary berms and a temporary retention pond. Plastic sheeting was placed in the gravel parking lot east of the Bandag building to stockpile excavated soils for T&D. On August I, 2000, the temporary piezometer was abandoned. Carolina Power and Light (CP&L) temporarily disconnected the existing • • JFD Electronics/ Channel Master Superfund Site Page 12 of 26 Interim Remedial Action Report ,,.........., Draft April 3, 2002 ( 12:36PM) ~hr;-,-.d. o.(ci .-=---d ,._f L, ·~1 . h . d over ea P,0Wer mes, rem. o:,ve two-power!R·o es m t e excavat10n area an II II I -----=' Ii I rero~\ed f'Jweq \0 the grou.ndwater treatment system. ~ u ~ Li \S. b. Site Health and Safety Controls The site was.divided into the following three health and safety zones: an exclusion zone, contamination-reduction zone, and a support zone. The exclusion zone included the excavation areas and impacted-soil stockpile areas. Caution tape was placed around the excavation areas and Personal Protective Equipment (PPE) was required in this zone. The contamination-reduction zone was located between the exclusion zone and the support zone. Equipment and personnel decontamination activities were performed in this zone and PPE and first-aid equipment were staged here. A rectangular decontamination pad with bermed sides was constructed with asphalt in this area. The support zone was for site management and deliveries. Site access was restricted to individuals participating in the remediation activities. Earth Tech performed on-site air monitoring using Minirams, at upwind and downwin? locations of the active work-area. Water was sprayed often in excavation areas for dust suppression. Earth Tech performed periodic air monitoring in the breathing zone during excavatio~ activities. The personal air sampler filters were shipped to Test America, Inc. for analysis of metals and cyanide. The analytical results were below method detection limits. c. Material Removal Excavation occurred during August 2-25, 2000. Soils were excavated to specified depths and were transported via dump truck to the stockpile area. Where soil sampling indicated metals and cyanide levels were below RLs, the top I-foot of soil was excavated, stockpiled separately, and later used for backfilling. While excavating surficial soil over the SDBs, sludge was discovered in thin seams ( 1 to 4 inches thick). The depths of the sludge seams varied depending on the location. The sludge was typically bluish- green to black in color and easy to visually distinguish. A sludge seam was sampled and shipped to STL Savannah Laboratories in Savannah, GA. The analytical results indicated nickel concentration greater than the RL. Sludge seams were found in 16 grids. The sludge seams and surrounding soils were excavated and stockpiled for off-site T&D. • JFD Electronics/ Channel Master Superfund Site Page 13 of 26 Interim Remedial Action Report ,,..,-,-, Draft April 3. 2002 (12:36PM) ~le r'i~in{-i;Jud.ge r.dm.f s•ih cii=.ct-6; a small sludge bed was discbte:J) 1 T~i~ SDB1w'a1rn'ot pr6iiously i3entified and was labeled as ti/, II }._I,,,,)\ 'I \\. SDB-0;::.Th1s SIDB was discovered-at approx11nately I-ft bis. The sludge and immediately adjacent soil was excavated for off-site T&D. The remaining 11 SDBs were located close to the areas identified in the RI. After the excavation of the surficial soils over a sludge bed, soils were removed at 6-inch depth intervals and stockpiled as suspect soils. Sludge and surrounding soils were excavated to approximately 6 inches below visible contamination and stockpiled for T&D. Typically, the SDBs were located I-ft bis to 3-ft bis and extended to depths of approximately 5.5-ft to 7-ft bls. After excavation, confirmation samples were collected. Table 4 presents each grid and SOB excavation det~ils. Table 4 -Excavation Details Su rfi ci al· ... .Excavation , 1. Start-Grid Dimensions, l en(th x completion width x depth ft) Dates (2000) 2 50x50x3 8/8-11 5 50x50x2 8/8 6 40x20xl 8/7 8 50x50xl 8/7-15 9 50x50xl 8/16-17 11 50x50xl 8/9-17 13 50x25xl 8/18 14 50x40xl 8/3-8 18 50x40xl. 5 8/22-23 21 45x45x0.5 8/24 22 50x50x0.5 8/21-25 . sludge oryi ng Beds · .· 0 20x12x4 8/7 1 25x15x7 8/15-23 2 20x20x6 8/15-16 3 25x20x6 8/16 4 25x30x6.5 8/16-17 5 22x25x5.5 8/17 6 22x20x7 8/18 7 · 2 5x20x6 8/18-21 8 27x20x6 8/21-22 9 27x20x6.5 8/22 10 30x25x6.5 8/22 11 25x25x6.5 8/23 • JFD Electronics/ Channel Master Superfund Site Page 14 of 26 '""'"" R,m,a"" Actffio ,:•p~ri,~s'iiihct~ it' it Droff ,pnu. ,oo,u,c,,cMJ llT-lf exlLated s!Qes1and-soils were-se·gregated into three stockpiles within the staging area: (I) soils that contained metals concentrations above RLs; (2) sludges and soils that contained cyanide concentrations above RLs, or the visual presence of sludge; (3) soils pending characterization. Soils containing concentrations of metals and cyanide below RLs, based on pre-construction sampling results and the absence of sludge, were stockpiled for use as backfill. e. Post-excavation Confirmation Sampling After excavation was completed in a grid or SOB, ARCADIS collected post excavation samples. In general, for each grid or SOB sampled, a five-point composite sample was collected from the bottom of the excavation area and from each of the excavation sidewalls. Each composite sample was analyzed for hexavalent chromium, antimony, nickel, and total and amenable cyanide. The laboratory performed Level TI analysis of all samples collected and CLP/CLP-equivalent analysis for 25 percent of the samples. The analytical results indicated concentrations below the RLs for all samples: Based on these data, the EPA authorized backfill of the excavations through letters dated August 23 and 31, 2000. f. Suspect Soils On August 22 and 25, 2000, Earth Tech obtained composite samples from th~ suspect soil piles. Both samples were analyzed for metals and total and amenable cyanide by Test America, Inc. Analytical results were below RLs and therefore, these soils were used as backfill. g. Transportation, Treatment and Disposal EQ provided T&D for the contaminated sludges and soils. The trucks were backed into the stockpile area and Earth Tech utilized an excavator to load each truck with approximateJy·20 tons of waste material. The undercarriage and tires were decontaminated and the truck containers were covered for transport. A total of !47 trucks were loaded from August 8, 2000 through September l l, 2000. All loads were shipped for treatment at Michigan Disposal Waste Treatment Plant (MDWTP) (USEPA ID No. MID00072483 l) and disposal at Wayne Disposal, Inc. (WDI), Site #2 Landfill (USEPA ID# MID048090633). Both EQ facilities are located at 49350 North 194 Service Drive, Belleville, Michigan 48 l l l. · • • JFD Electronics/ Channel Master Superfund Site Page 15 of 26 Interim Remedial Action Report ,----, Draft April 3, 2002 ( 12:36PM) ~roI'ilfuitily ~nsc;1 ~ethl~cted soils (RQ, .11 App I I ' ..-::-::! I I I . I I Environmental &lazardous-Substarice, Solid, N.O.S., UN3077, PGill I l _,/ / I . . I \. • /'I I 1 . \ I_ . • . (F006))-were stab1hzed•at-MDW11F with a pozzolanic agent, and disposed in a subtitle C landfill at WDI. Approximately 3,282 tons of cyanide- impacted wastes (RQ, Environmental Hazardous Substance, Solid, N.O.S., 9, UN3077, PGlII (F006, F0l9)) were treated at MDWTP by alkaline chlorination, followed by reduction of hexavalent chromium to trivalent chromium with ferrous sulfate. The resultant slurry was stabilized with a pozzolanic agent to bind the metals and solidify liquids. The treated material was then disposed at WDI. h. Decontamination All equipment that came into contact with contaminated materials were decontaminated. Sediment collected in the sump was removed and included in the cyanide-impacted soils/sludge for T&D. Decontamination water was pumped from the decontamination-pad sump into storage tanks. On August I 8, 2000, Earth Tech obtained samples which were analyzed by Test America, Inc. for full TCLP and total and amenable cyanide. Analytical results indicated that only total and amenable cyanide concentrations were detected; and these concentrations we.re below TCLP limits. Earth Tech contracted Industrial Marine Services, Inc. (IMS) to transport this water as non-hazardous waste for off-site qisposal. A total of 2,900 gallons was disposed of at IMS' s facility-located in Norfolk, Virginia on September 5 and 18, 2000. After transporting the decontamination water, one storage tank was found to be impacted by solids that had settled. Therefore, the tank was shipped with the cyanide-impacted soils for disposal. The other tank and transfer pump were washed and demobilized. 1. Backfill A total of 733 cy of offsite structural fill (red clayey soils and· aggregate base course (ABC) stone), 140 cy of former suspect soils, and 357 cy of clean soils stockpiled within the excavation areas were used as backfill material. Backfilling and compaction occurred between August 30, 2000 and October 6, 2000. Difficulties were encountered due to heavy rain events, which left the soils too moist for proper compaction. These soils were disked to reduce moisture prior to backfilling. In addition, ABC was used as an alternative to soils in some areas for backfilling. • • JFD Electronics/ Channel Master Superfund Site Page 16 of 26 Interim Remedial Action Report = Draft April 3, 2002 ( 12:36PM) ~ ltoift~e ~ ortlakill ~JAsi~ied of a vegetative soil layer, totalmg Uf048 cyf(T. he .. ·•~surdc~ was g~hded to promote drainage and I, .I 1 .. 1 , ,,,2, r.l U, hydroseedmg was perfonne·d, I.:!! "= J. Site Restoration On October 3, 2000, CP&L replaced the two power poles and restored power. After remediation activities, the chain-link fence sections were reinstalled. A minimum of 3 inches of gravel under the stockpiles were removed and transported with the contaminated soils for T&D. The asphalt decontamination pad was demolished, and the asphalt and other site debris (trees, concrete, construction materials, etc.) was transported for off-site disposal. Earth Tech demobilized all equipment and personnel. IV. CHRONOLOGY OF EVENTS With the exception of the ROD, the Remedial Design Workplan and the Preliminary Close-Out Report (PCOR), the remainder of the events are discretely related to either the Groundwater Remedy or the Soil/Sludge Remedy. Because of this and the fact that the Groundwater Remedy will be continuing for many years, while the Soil/Sludge Remediation has been completed, presented below are two separate tables for the Chronology of Events. Table 5 -Groundwater Remedy Chronology of Events Event . Date ;., ,, ; . .•. '\;·" . . ; .. Record of Decision September 10, 1992 Remedial Design Work Plan submitted November 1993 Explanation of Significant Differences January 24, 1996 Remedial Design submitted July 1996 Remedial Design Approved September 11, 1996 Mobilize/begin Construction May 6, 1998 Final Inspection August 11, 1998 Start-up #1 'August 1998 shut Down September 8, 1998 Effluent Re-routed March 2000 Start-up #2 April 12, 2000 PC0R September 29, 2000 Downtime #1 February 26th -March gt\ 2001 Downtime #2 April 25-26, 2001 Downtime #3 August 14-17, 2001 Downtime #4 January 11-14, 2002 Estimated Date of Remediation completion April 2030 • • JFD Electronics/ Channel Master Superfund Site Page 17 of 26 Interim Remedial Action Report ,,.---, Draft April 3, 2002 ( 12:36PM) 'TI~-Shll!Sllidgn]firofciU~gy'o~ . ' Event Date Record of Decision L.:::::::,/ u ~ septembe r '-to? 1992 Remedial Design work Plan submitted November 1993 supplemental Feasibility Study submitted 1996 ROD Amendment May 1999 Design criteria Memorandum submitted June 1999 Preliminary Design Report submitted September 13, 1999 Pre-fi na 1 Design Report Submitted February 19, 2000 Fina 1 Design Report submitted Apri 1 2000 Final Design Report Final submitted Revisions May 23, 2000 Remedial Design Approved June 1, 2000 Pre-excavation soil Sampling May 24-25, 2000 and July 6, 2000 Explanation of Significant Differences July 19, 2000 Mobilization/Begin Remedial Action July 24, 2000 Pre-Final Inspection September 28, 2000 PCOR September 29, 2000 Punch List Items completed October 2000 Final Inspection October 23, 2000 Regrading August 27, 2001 V. PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL A. Groundwater I . Performance Standards As of October, 200 I, no parameters have ever exceeded the maximum allowed in the City of Oxford Industrial Users Permit (!UP) for the treatment effluent. With one exception, all of the VOCs have been below the laboratory's detection limit of I µg/L. In a sample obtained on January 5, 2001, Tetrachlciroethylene was detected at a concentration of 1.2 µg/L. The !UP did not specify a maximum concentration for this chemical. The cyanide concentrations have ranged from <0.005 to 0.019 mg/L. The higher cyanide concentrations were found during the first few months of operation. With the exception of February, March and April 2001, the cyanide concentrations were <0.005 mg/L from November 2000 through October 200 I. These values are well below the POTW maximum concentration of 0.050 mg/L. • • JFD Electronics I Channel Master Superfund Site Page 18 of 26 Interim Remedial Action Report ,,....---, Draft April 3, 2002 ( 12:36PM) The ~ fl£°1w'fbJ th'qe?iod d krri1 ~O through October 200 I, was 21,250 khllon'slpe} tlay. T.1iieTaJge vJ/ied bettccn 14,000 and 26,000 gallons ,l_// •! · \.,.ll 11 1.1-_ . per day (calculatei:I). T-hese values'are welt below tlie:P.OTW maximum volume of 40,000 gallons per day. As of October 2, 200 I, the total volume of water that has flown through the influent meter for treatment was 11,681,888 gallons. As expected, VOCs concentrations were above RLs in some of the wells during the quarterly sampling of the Groundwater Monitoring Wells, the Perimeter Monitoring Wells and the Recovery Wells, during the first year of operation. Two inorganics exceeded the RLs established in the ROD for one of the wells (CMMW 17) during the Annual Sampling for chromium, copper and nickel which occurred on July 26, 2000. The results showed elevated concentrations of chromium ( 160 µg/L) and nickel ( 120 µg/L), above the respective RLs of 50 and 100 µg/L. This particular well did not have corresponding turbidity data. Turbidity has been found in the past to upwardly affect the inorganic results. This well was resampled on July 25, 200 I. The turbidity was recorded as 6.51 NTU at the time of sampling. The results were below the laboratory's detection limits of 0.0 IO mg/L, 0.020 mg/Land 0.040 mg/L for chromium, copper and nickel respectively, which are below the RLs established in the ROD. 2. Construction Quality Control A Construction Quality Assurance (CQA) Plan was prepared and implemented by the consultants for the PRPs. CQA-related·activities occurred throughout the construction. These activities consisted of periodic meetings and inspections; CQA testing, sampling and observations; and CQA documentation. B. Soil/Sludge I. Performance Standards The Soil/Sludge remediation successfully achieved the remediation goals. As stated previously, approximately 3,565 tons of metals-and/or cyanide-impacted wastes were removed from the Site, treated at MDWTP, and then disposed at WDI. The excavated areas were sampled and analyzed before being backfilled. The material utilized for backfill was sampled and analyzed prior to placement. 2. Construction Quality Control A CQA Plan was prepared and implemented by the consultants for the PRPs. The CQA was generally followed with the exception of minor deviations which can be found in Section 4 of the Final Construction Report Soil/Sludge Remedial Action (Volume I), February 2002. • • JFD Electronics/ Channel Master Superfund Site Page 19 of 26 Interim Remedial Action Report ,,..........., Draft April 3, 2002 ( 12:36PM) In ad~to t~A 'acti~itie~e~foim~lby·the PRPs consultants, II .I' ,, ..-==!1 11 I representatives oyl)lC DENR and·EPiA visited the Site on seventeen separate days d . , L .. _/ , ., . . \+n..,,_ 1. , , d. . 1 ~. h . . k · unng construcl1on act1-v111es. •,. e·c ates an tunes•o,;t e visits were not nown to the PRPs' representatives or contractors, prior to arrival. In addition to random, unannounced Site visits, NC DENR and EPA personnel reviewed subcontractor submittals and laboratory results prior to providing approval. VI. FINAL INSPECTION AND CERTU'ICATIONS A. Groundwater On August 11, 1998, representatives of EPA, NC DENR, ARCADIS and W ATEC completed a combined Pre-final/Final Inspection of the groundwater treatment system. No major construction deficiencies were identified; therefore, EPA issued a verbal authorization to proceed with the system startup once the punch list items were completed. In August 1998, the punch list items were completed. Due to cyanide concentrations exceeding surface water standards (see Section ill.A.3), the groundwater treatment system did not begin effective operation until April 2000. The groundwater treatment system is now considered operational and functional. B. Soil/Sludge On September 28, 2000, representatives of EPA, NC DENR, ARCADIS, Earth Tech, and Avnet performed a Pre-final Inspection. No major remediation deficiencies were identified; therefore, EPA issued a verbal acceptance, provided the punch-list items were completed. The 14 punch list items were completed by October 10, 2000. On October 23, 2000, representatives of EPA, NC DENR, ARCADIS and Earth Tech performed a Final Inspection. All of the punch list items were confirmed to be complete. It was noted that grass cover had not been established over the site, most likely as a result of lack of recent precipitation. Vegetation has now been established and the remediation is considered complete. VII. OPERATION & MAINTENANCE ACTIVITIES A. Groundwater The Operations and Maintenance Plan was prepared by ARCADIS and submitted as an appendix to the FDR-GW. This plan includes system startup and shutdown procedures, system maintenance, sampling and monitoring and reporting requirements. • • JFD Electronics/ Channel Master Supcrfund Site Page 20 of 26 fo«rirn """''~ Actfo,o :::~mctlr.i'l'51 c{~ T Dmf"r""· ,,,,w, WMJ S l·UJ II .«J1·0,l. ''1· ll ~ d "f" . ystem-mamtenance me uues:v1sua 111spect1on.an spec1 1c mamtenance tasks such as lubrication and cleaning. The maintenance frequency suggested in the plan varies from weekly to semi-annually depending on the maintenance task. 2. Sampling and Monitoring Plan To ensure the treatment system performs as designed, and to evaluate influent and effluent water quality, a sampling and monitoring plan was implemented. As required by the permit issued by the City of Oxford, the system effluent was sampled on a weekly basis during the first three months of operation, after which a less stringent sampling schedule was negotiated. The weekly sampling of the treatment system influent and effluent began on April 18, 2000. Since August 16, 2000, effluent sampling has been performed monthly. The sampling schedule was incorporated into the Revised Monitoring Program. Table 7 • Groundwater Monitoring Plan PARAMETER GROUNDWATER PERIMETER RECOVERY TREATMENT TREATMENT ---------------------------- pH Temperature Specifi C conductivity Trichloroethene Tetrachloroethene 1,2-Dichloroethene (total) 1,1-Dichloroethene 1,2-Dichloroethane Vinyl chloride copper Nickel chromium cyanide (total) cyanide (amenable/total) water Table Elevation Flow w M Q A Weekly sampling Monthly sampling Quarterly Sampling Annual Sampling Not sampled/Not applicable MONITORING MONITORING WELLS INFLUENT EFFLUENT WELLS WELLS ----------------~---------------------------------------------------· --------l" 2ND YEAR YEAR ONWARD Q s Q s Q s Q s Q s Q s Q s Q s Q s A ·- A .. A -- ---- Q' Q' M s --- l" Q Q Q Q Q Q Q Q Q -- -- -- -- -- -- - W-1/TM W-1/Q s C 3 YEARS l" 2" l" 2"0 l IT YEA~--YEAR YEAR , YEAR YEAR ONWARD ONWARD s A - -- s A -- - s A - -- s A W-1/Q s W-1/TM s A W·l/Q s W-1/TM s A w-1/Q s W-1/TM s A w-1/Q s W-1/TM s A W-1/Q s W-1/TM s A W-1/Q s W-1/TM -------- ---------- -----· ---- --------W-1/TM --s -- ---- M s ------ ----- --C Weekly sampling durmg hrst three months, Monthly sampling thereafter Weekly sampling during the first lhree mon1hs and quarterly thereafter Semiannual sampling Continuous flow monitoring 2" YEAR ONWARD' - - - M M M M M M -- -- -- M - -- C Monitoring well CMMW04 will be the only monitoring well sampled for total and amenable cyanide on a quarterly basis for !he first 3 years of operation. • • JFD Electronics/ Channel Master Superfund Site Page 21 or 26 Interim Remedial Action Report ,............., Draft April 3, 2002 ( 12:36PM) 3 0 ~M ,., r:::-, ,;::;::::-,-ti M ~ L_, ~. . peration) amtenance-anm omtonng n:ct1v1t1es BaJ1lnd1cmJdLater (Qlt weU colleJe~~during the week of April 3, 2000. Other sampling has occurred according to the Monitoring Plan. In July 2000, well CMMW22 was replaced with well CMMW22A. The original well was found to be missing during a regularly scheduled sampling event. In late 200 I, the CMMW22 well remains were found and the well was properly abandoned on October 5, 200 I. On October 13, 2000, a sample was collected from the two storage tanks and several 55-gallOn drums which contained decontamination water and well development water. The results indicated that the water could be treated using the on-site treatment system. Approximately 2,719 gallons of the water was pumped through the system on December 12, 13, and 18, 2000. The remaining nine 55- gallon drums of water was pumped through the system on January 5, 2001. During November 2000, the control wires to recovery well cluster PW-5 were installed and connected to the control panel by Avnet personnel with the assistance of Nelms Electric. On November 17, 2000, recovery wells PW-SA, PW-SB and PW-SC were put into operation. On January 18, 2001, routine maintenance was performed on the treatment system. The ai_r stripper was inspected and the trays were pressure washed to remove scaling. On November 8, 200 I, City of Oxford performed their annual inspection. 4. System Interruptions On Febru<)ry 26, 2001, ARCADIS found that the system was shutdown. Based on the flow data, it was estimated that the system probably shut down on February 20 or 21, 2001. On Fe)?ruary 28, 2001, it was determined that the controls were damaged by a power surge. On March 8, 200 I, a new processor was installed in the control panel, a new modem was added to the teledialer, and a surge protector was installed on the telephone line. The system was returned to operation that same day. On July 25, 2001, recovery well PW-I was found to be shutdown due to a tripped electrical breaker for the pump motor. The breaker was reset and the pump was returned to operation on July 26, 200 I. On August 13, 2001, the system autodialer informed ARCADIS that the system was shut down. On August 17, 200 I, the cause was determined to be from • • JFD Electronics/ Channel Master Superfund Site Page 22 of 26 Interim Remedial Action Report ,.--, Draft April 3, 2002 (12:36PM) a dead bird ~g th~inirlke'6nti'e a;;:{t[·ippe1~r. The blockage was cleared and h\e sY,kteni ias restarted! LI 11 L'=::1/LJ ~ ~ ' On January 11, 2002, Avnet personnel discovered that a recovery well pipe was leaking and they shutdown the system. On January I 4, 2002, a cracked check valve on the combined influent line for the PW-5 well cluster at the treatment pad was found, the valve was replaced, and the treatment system was restarted. B. Soil/Sludge Because all of the soil/sludge contamination was removed from the Site, long-term operation and maintenance will not be required. Inspections and maintenance activities occurred during the first year after the remedial action was complete. These activities included inspections and maintenance of the vegetative soil cover. During April 2001, Avnet informed ARCADIS that the Bandag building had flooded during storm events. Water was entering from the southwest corner of the building. Earth Tech returned to the site on August 27, 200 I to re-grade this area and improve the drainage swale on the south side of the building. Additionally, the riprap check dams were removed and all exposed areas were re-seeded. VIII. SUMMARY OF PROJECT COSTS A. Groundwater The original present worth total cost estimate to implement the remedial action for groundwater described in the ROD was $5,181,000 (Total Capitol Costs: $2,498,000 + Total O&M Costs $2,683,000). The ESD did not include a revised cost estimate for the groundwater remedial action. The FDR-GW included the following cost estimation, assuming a 30-year operation period: Total Capital Costs Total I" Year O&M Costs Total Annual O&M Costs after year I TOTAL Costs $ 400,900 $ 119,900 $ 111,700 $2,206,400 After the construction was completed, the PRPs estimated that the construction cost was $540,000 and estimated probable O&M costs of $150,000 per year. The reason for the major difference between the ROD Total Costs and the PRPs' estimated costs is because of the elimination of several treatment units from the ROD as documented in the ESD. This remedy alteration produced significant cost savings. • • • JFD Electronics/ Channel Master Superfund Site Page 23 of 26 Interim Remedial Action Report ,..--:-:-, Draft April 3, 2002 ( 12:36PM) 8 ::~::::::,□, w[mal,,.;JL ,~ Jt,em ,oc remedial aclioa fm soil and sludge described in the ROD was $1,211,000 (Total Capitol Costs: $1,090,000 + Total O&M Costs $121,000). The ROD Amendment revised the soil/sludge remedial action present worth total cost estimate to $2,582,385 (there was no breakdown of capitol and O&M costs). The ESD revised the soil/sludge remedial action present worth total cost estimate to $2,585,000 (there was no breakdown of capitol and O&M costs). The PRPs estimate the soil/sludge remediation total cost will be $1,025,000 lreplace with update frm ENSR expected 4/8/02). The major difference between the ESD cost estimate and the PRPs' estimated total cost is primarily due to the actual volume of soil/sludge requiring excavation, costly treatment, and disposal being less than what was estimated. IX. OBS ERV A TIO NS AND LESSONS LEARNED As is the case with the majority of hazardous waste remediation projects, what was found during the remediation varied slightly from what was projected in the RI and RD. Previously unidentified sludge seams, greater than average rainfalls, and other minor events caused the remediation to take longer than hoped. But, all parties were motivated to complete the remedial action by the end of the government fiscal year. This common goal ensured teamwork to complete the remediation on schedule. Each entity worked diligently to make this goal a reality. X. CONTACT INFORMATION A. EPA There were two RPMs involved with this Site. Mr. McKenzie Mallary served as the RPM through December 1999. Ms. Samantha Urquhart-Foster served as the RPM from January 2000 until present. Ms. Samantha Urquhart-Foster ( 404) 562-8760, e-mail: urquhart ,foster.samantha@cpamail.epa.gov Mr. McKenzie Mallary ( 404) 562-8802, e-mail: mallary.ken@epamail.epa.gov 4WD-NSMB US Environmental Protection Agency 61 Forsyth Street, SW Atlanta, GA 30303 • JFD Electronics/ Channel Master Superfund Site Page 24 of 26 Interim Remedial Action Report ,,-----, Draft April 3, 2002 ( 12:36PM) B N h C l~D n,-,:::, f E:::= ,.J ~dd7:--iN I R . ort aro ma eRartment.o nv1ronmencan atura esources Mr. David J1MdZsol,JCHM©l u lL Environmental Engineer NC Department of Environment and Natural Resources -Superfund Section 40 I Oberlin Road, Suite 150 Raleigh, NC 27605 (919) 733-2801 ext. 349, e-mail: david.mattison@ncmail.net C. PPRs Mr. Brian Kempner Mr. S. Alan Lazar Vice President & General Counsel The Shepaug Corporation 54 East 64th Street New York, NY I 0021 e-mail: bkempner@observer.com D. PRPs' Contractors Avnet, Inc. 2211 South 47th Street Phoenix, AZ 85034 e-mail: sandy.lazar@avnet.com I. RD, Construction Project Management, Oversight, Quality Assurance a. ENSR International According to the Consent Decree, the primary contact for the PRPs is William Doucette. During the RD and RA, Dr. Doucette was employed by ARCADIS. During O&M, he transferred to ENSR International. William H. Doucette, Jr., Ph.D., L.G. Senior Program Manager ENSR International 7041 Old Wake Forest Road Raleigh, NC 27616-30 I 3 (919) 892-6600 ext. 249, e-mail: Bdoucette@ENSR.com The secondary contact for this project has been Nanjun Shetty. He was also employed by ARCADIS but is now employed by ENSR. Mr. Nanjun V. Shetty, PE Senior Program Manager ENSR International 7041 Old Wake Forest Road Raleigh, NC 276I6-3013 (9 l 9) 892-6600 ext. 249, e-mail: Nshetty@ENSR.com • • JFD Electronics/ Channel Master Superfund Site Page 25 of 26 Interim Remedial Action Report ,,..-,..., Draft April 3, 2002 (12:36PM) b. rr,,Allf©er~r ,1f ec6ftarolina, Inc. [1=.d~tated abov~ng the-~D, RA~and• Operational and Functional (O&F) determination period, the primary and secondary contacts for this Site were William Doucette and Nanjun Shetty, who were at that time employed by ARCADIS. Numerous other ARCADIS personnel were involved with this project. ARCADIS Geraghty & Miller of North Carolina, Inc. 230 I Rex woods Drive, Suite 102 Raleigh, NC 27607 (919) 782-5511 2. Groundwater Remediation System Waste Abatement Technology, Inc. North Carolina 3. Soil/Sludge Remediation Earth Tech performed the construction activities for the soil/sludge excavation. The primary on-site contact was: Mr. Michael Gleasman Earth Tech, Inc. 7870 Villa Park Drive, Suite 400 Richmond, Virginia 23228 EQ was responsible for transportation, treatment and disposal of the soil/sludge waste. They utilized two facilities for this endeavor: Michigan Disposal Waste Treatment Plant and Wayne Disposal, Inc. Both are located at the following address: The Environmental Quality Company 49350 N. 1-94 Service Drive Belleville, Michigan 481 i I (800) 592-5489 • • JFD Electronics/ Channel Master Superfund Site Page 26 of 26 Interim Remedial A.ction Repo[Jrn ~,,,..,,., ----.. _j L EP Draft April 3, 2002 ( 12:36PM) L-<A,PENDIX K-"REFERENCEll . . . I. ARCADIS Geraght -&~illeJ.,1002. ~l_10:oJJuction kepdrt, Soil/Sludge Remedial Action, JFD Electronics/Channel Master Site, Oxford, North Carolina. February 2002. 2. ARCADIS Geraghty & Miller, 2000. Final Construction Report, Groundwater Remediation, Revision I, JFD Electronics/Channel Master Site, Oxford, North Carolina. December 2000. 3. Geraghty & Miller, Inc. I 996. Final Design Report, Groundwater Remediation, JFD Electronics/Channel Master NPL Site, Oxford, North Carolina. July 1996. 4. United States District Court, 1993. In the United States District Court for the Eastern. District of North Carolina, Raleigh Division. United States of America, Plaintiffs, v. JFD Electronics Corporation and Channel Master Satellite Systems, Inc., Defendants. Civil Action #93-650-CJV-5-B. Consent Decree. December 23, 1993. 5. United States Environmental Protection Agency, 2000. Preliminary Close Out Report, JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. September 29, 2000. 6. United States Environmental Protection Agency, 2000. Explanation of Significant Difference to the Remedial Action for the JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. July 19, 2000. 7. United States Environmental Protection Agency, 2000. Close Out Procedures for National Priorities List Sites. EPA 540-R-98-016, OSWER Directive 9320.2-09A-P, PB98-96322.3. January 2000. 8. United States Environmental Protection Agency, I 999. Amendment to the 1992 Record of Decision, Remedial Alternatives Selection, JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. May 4, 1999. 9. United States Environmental Protection Agency, 1996. Explanation of Significant Difference to the Remedial Action for the JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. January 24, 1996. 10. .United States Environmental Protection Agency, 1992. Record of Decision, Summary of Remedial Alternative Selection, JFD Electronics/Channel Master Site, Oxford, Granville County, North Carolina. September 10, I 992.