NCD980729602_19960405_Jadco-Hughes_FRBCERCLA RA_Remedial - Design Remedial Action Work Plan 1991 - 1996-OCR

,
State of North Carofaii.t
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
MEMORANDUM
TO:
FROM:
SUBJECT
Randy McElveen
Superfund Section
Preston Howard ~J--
Jadco-Huges NPL Site
Remedial Action Work Plan
Gaston County
Project #96-03
April 5, 1996
j,l\
DEHNR
RF(;Fl\/f::0
APR 04 1996
SUPERFUNO SECTION
The Division of Environmental Management has completed the review of the subject document and
offers the following comments and recommendations:
Air Quality Section
No comments at this time.
Water Quality Section
No comments at this time.
Groundwater Section
No comments at this time.
APHjr/baw/96-03fin.doc
cc: Alan Klimek
Steve Tedder
Mooresville Regional Office
Groundwater Section Files
Groundwater Section. ...-: ~ N, ... C
P.O. Box 29578, Raleigh. North Carolina 27626-0578 ,_.,
2728 Capital Blvd .. Raleigh. North Carolina 27604
Voice 919-733-3221 FAX [phone]
An Equal Opportunity/ Affirmative Action Employer
50% recycled/lO"k post-consumer paper
State of North calina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr .. Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director Decemb 14 1995 er ,
Mr. Michael Townsend
Remedial Project Manager
US EPA Region IV
345 Courtland street, NE
Atlanta, GA 30365
,. .NA
DEHNR
COP-Y
RE: Comments on Remedial Action Work Plan -Addendum
Jadco-Hughes·
NCD 980 729 602
Belmont, Gaston County, NC
Dear Mr. Townsend:
The Remedial Action Work Plan -Addendum for the Jadco Hughes
NPL Site, located in Belmont, North Carolina has been received and
reviewed by the North Carolina Superfund Section. we· look forward.
to receiving the Revised Remedial Goal Verification Plan or
Addendum when it is submitted by the Jadco-Hughes PRP group. This
document has also been forwarded to the NC DEM for concurrent
review. Their comments will be forwarded when available. This
Addendum addresses the negotiated issues outlined in the letter
dated September 18, 1995. The following comment is offered by the
North Carolina Superfund Section.
1. Section 02018 of the Specifications addresses Monitoring
Wells. Item 3 of subsection 1.4 States that: "Grout
Seal" is required to a depth of 2 feet. It is unclear
what the phrase "Grout Seal" means. If this is referring
to the bentonite seal which is placed above the sand pack
as discussed on page 6 of this Section, item "O", please
use this same word throughout the text.
If you have any questions or comments, please do not hesitate to
contact me, at [phone], extension 341.
Sincerely,
~~it~~}~~
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
Bruce Nicholson, N.C. Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post~consumer paper
State of North <iannna
Department of°'ffl'vironment,
Health and Natural Resources
Division of Solid Waste Management
Jomes B. Hunt, Jr., Governor
Jonathon B. Howes, Secretory
William L. Meyer, Director
March 7, 1995
Mr. Michael Townsend
Remedial Project Manager
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Comments on Final Remedial Design Report
Jadco-Hughes
NCD 980 729 602
Belmont, Gaston County, NC
Dear Mr, Townsend:
The Final Remedial Design Report for the Jadco Hughes NPL
Sita, located in Belmont, North Carolina has been received and
reviewed by the North Carolina Superfund Section. This document
has also been forwarded to the NC DEM for concurrent review. Their
comments will be forwarded when available. The following comments
are offered by the North Carolina Superfund Section.
1. The Performance Monitoring Section on page 52 does not
discuss performance verification monitoring of the soils
in the landfill area. The State strongly maintains its
position that subsurface sampling must be conducted
before and after the Soil Vapor Extraction (SVE) and Soil
Flushing to monitor the performance of the remedy.
The State has held this position since groundwater
monitoring was first recommended in the Feasibility Study
as the primary verification strategy. The State conceded
that soil leachability tests are not necessary (because
of the placement of monitoring wells) but has always
stated it was necessary to monitor soil total contaminant
levels as a performance check. One cannot use
groundwater data alone to monitor performance of the
soils remedy.
In a conference call with Michael Townsend in January of
1994 it was concluded that soil verification would be
included along with groundwater monitoring. In a letter
from Michael Townsend to the NC Superfund Section dated
January 21, 1994 the last paragraphs states that: ''The
PRPs must still provide verification that the soils are
well within health based standards, ·and propose a method
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-<1996 FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
.• • •
Mr. Townsend
3-7-95
Page 2
to accurately monitor .and evaluate the influent of the
groundwater treatment system."
Therefore, we request that EPA require the inclusion of
landfill soils sampling for the performance monitoring
requirements in the Design.
2. In conceding that soil leachability testing was not
necessary, the State outlined monitoring well
requirements in the 29 March 1994 conference call with
EPA and in a letter summarizing such call. Heretofore,
these requirements have not been addressed. We
understand additional monitoring wells would be placed
within the landfill and at the down-gradient perimeter of
the landfill. We recommended at the time that these well
placements be developed in the Explanation of Significant
Difference (ESD). They were not, and subsequent RD
documents have still not addressed this question.
Obviously, we now need this to be addressed before the
Final Design is approved.
3. Similar to comment #2, the State has maintained that a
monitoring well be installed to the north-east of the
sump-manhole (in the fork of tributary A and tributary
B). Again, this has not been addressed in this Design
document. The monitoring well proposed in the area of
the sump-manhole should be installed to a minimum of 10
feet below the extraction trench and sump-manhole.
4. What analytical method(s) will be used by the potentially
responsible party (PRP) contractor to determine the
metals concentrations in groundwater? As we stated in
our previous comments Standard Method 3030C, "Preliminary
Treatment for Acid-Extractable Metals" or an EPA
equivalent, will be the only accepted method for metals
analyses at· NC Super fund Sites. Based on the PRPs
response to comment #3 of the Pre-Final Remedial Design,
the EPA and the State should discuss this issue in
detail.
5. Two-inch diameter perforated piping is not shown on
drawing No. G7 (Soil Vapor Extraction System) as noted on
page 44.
6. In response to the PRPs response on comment #11 for the
Pre-Final Remedial Design, in addition to visual and OVA
meter screening of the soils to be place over the
landfill surface, a representative number of samples
should be recovered from the proposed fill materials to
determine the range of contaminant concentrations.
. . . .
Mr. Townsend
3-7-95
Page 3
• •
If you have any questions or comments, please do not hesitate to
contact us, at [phone].
Sincerely,
C/11. A?. lM 1,('0 )
Randt JcE~~YfDVI
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
Bruce Nicholson, N.C. Superfund Section
•
Consulting Engineers
February 24, 1995
Mr. Randy McElveen
North Carolina Department of Environment,
Health and Natural Resources (NCDEHNR)
401 Oberlin Road
Suite 150
Raleigh, North Carolina
27605
Dear Mr. McElveen
• CONESTOGA-ROVERS & ASSOCIATES LIMITED
651 Colby Drive
Waterloo, Ontario, Canada N2V 1 C2
[phone] Colby Office Fax: [phone]
[phone] Bathurst Office [phone]
Reference No. 3669
RECEI\JED
MAR O 11995
suPERFUND secnoN /
Re: Final Design (CRA September 1994) -Full Size Drawings
Tadeo Hughes Site. Gaston County. NC
As discussed with Michael Townsend of the United States Environmental
Protection Agency (USEPA), please find enclosed a set of full size drawings for the
above-mentioned document. USEPA requested that this set of drawings be
provided by CRA to NCDEHNR for your review.
If you have any further questions please do not hesitate to contact our office.
Yours truly,
C NEST~A-ROVERS & ASSOCIATES ---.-c~ pzr.
anne Chew, P. Eng.
JC/as
encl.
c.c. Jadco-Hughes Technical Committee (w / o encl.)
Jimmy Kirkland (w /o encl.)
Steve Quigley (w /o encl.)
Rb
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I I
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
MAR 1 1993
4WD-NSRB
Jimmy Kirkland
King & Spalding
191 Peachtree Street
Atlanta, Georgia 28203
Dear Mr. Kirkland:
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
RECEIVED
Mlit< t1 199 3
SUPERRJND SECTION
EPA Comments on the Remedial Design Work Plan appear to be
adequately addressed. Approval is provided for the Remedial Design
Work Plan by this letter. The request for further extension of
final discharge is also approved providing that discharge
requirements and/or standards for both onsite stream discharge
(NPDES) and POTW discharge be submitted to EPA no later than May
31, 1993, the Steering Committee's proposed deadline for obtaining
a wastewater discharge permit.
Final comments on the Treatability Study and the Sampling and
Analysis Plan are enclosed. Written responses to these comments
shall be submitted to EPA no later than March 10, 1993.
All field work will be conducted in accordance with the
Environmental Compliance Branch Standard Operating Procedures and
Quality Assurance Manual, (Region IV SOP), February 1, 1991. In
the event of conflict between the work plan and the Region IV SOP
occur, the Region IV SOP shall control . •
Please contact me if you have any questions concerning this letter.
I can be reached at 404-347-7791.
Sincerely,
Barbara H. Benoy
Remedial Project Manager
Waste Management Division
Enclosure
cc: C. Fehn, NSRB
R. Bussey, ORC /
B, Nicholson, NCDEHNR
S. Quigley, CRA
Printed on Recycled Paper
, .. • •
_TREATABILITY STUDIES
General Comments
The Treatability Study must define the DQOs and the technical
rationale for establishing those objectives. The Study Plan lacks
necessary information concerning the number and types of sampels,
the rationale behind sample selection, etc.
Regulatory requirements may include air permiting by the State of
North Carolina. The State of North Carolina must be contacted to
make a determination on the necessity of an air permit. The pilot
scale may require governing under Clean Air Act; the quantity of
voes emitted may require tracking for the air permit and could
impact the total allowable amounts. A potential state contact is
Laura Butler at 919-733-3340.
Section 2.0, Purpose
Final discharge cleanup standards are necessary to adequately
design the treatability study at a pilot scale. Since the Steering
Committee has proposed that an extension be provided to arrange for
final discharge of treated water, some assumptions for cleanup
standards must be made.
The work plan clearly states that the purpose of the
Treatability Study is to "anticipate construction and
operational constraints of the SVE system and the off-gas
treatment system", to, determine operational parameters of the
groundwater treatment system, and to perform calculations to
determine the groundwater treatment system. The performance
standards for the groundwater treatment system will be based
on final discharge point. Without clear standards,
effectiveness cannot be adequately measured •
Table 3.1 • •
95th UCL must also be added. The Steering Committee agreed to
this for the RD Work Plan, but the required example
calculation has not been provided.
Table 3.1
Why was Benzo(a)anthracene not included?
Section 3.3.4, page 10 I Substantiate or explain the 30 % void space factor.
Section 3.3.5, page 11
Specify in detail the data that will be collected, identifying
number and type of samples, units of measurements,
frequencies, DQO level, and objective of measurement.
Flowrates must be identified; point measurement must be
defined; reporting format must be provided which clearly
states precisely what will be reported. The information must
be in the Treatability Study Work Plan as well as in the
Sampling and Analysis Plan.
2
, • •
Section 3.4. page 12
Sample collection and analysis must be conducted on all
residuals, including the wastewater collected during the SVE
pilot study.
Figure 4.1 -Out of place.
Groundwater Treatability Study -The objective of the evaluation
pilot study is to evaluate the aeration remedy in reducing the
groundwater to acceptable discharge levels. Since no "acceptable
discharge levels" have been established, effectiveness must be
measured directly with samples before and after treatment of all
site contaminants of concern. Table 4.1 provides MW-2D results
from RI; this information must be presented for PWl since it is
also a well selected for the treatability study.
Table 4 .1 Iron · and magnesium are the selected inorganics
identified on this table. Provide the rationale for selecting iron
and magnesium and the rationale for eliminating other site metals.
There is no technical justification for this elimination. Identify
the specific sampling event that generated the MW-2D data. This
table appears to be an excerpt of Table 8.10 of the RI; however,
there are several inconsistencies between the two tables, e.g. ,
there are no J values identified on Table 8 .10 (RI);
tetrachloroethene, vinyl chloride, chlorobenzene, and
trichloroethene are not included in Table 4.1. These contaminants
are found in high concentrations in the groundwater and must be
included in the evaluation.
Table 4.2 -Justify the selection of indicator contaminants, the
EPA method and the quantitation limit (if different from the method
or practical quan\~tation limit). Identify the DQO level
associated with these methods and quantitation limits. As
previously stated, EPA does not recognize the Ketone determination
as valid for this analysis.
First full paragraph -"After each run of the pilot study, ••••• ",
How many runs are planned? Counting of runs identified in Section
4.4 indicates a. total 6 runs. This must be confirmed. Provide
full explanation on the.use of different methods for same analysis.
The use of different methods causes serious problems in data
interpretation and may result in resampling to provide comparable
\results.
:Provide rationale for not collecting a sample of treated water for
fOCs and BNAs analysis. Provide rationale for not collecting
metals at beginning of study. These are obiviously necessary
parameters and samples for the groundwater treatment treatability
study.
I
~ection 4. 4. 3 -Why is temperature controled during the pilot ·
study?
3
' • •
Section 4. 6 . -How will efficiency be measured? Specify all
measurements and data to be reported and format. EPA will require
split samples for oversight requirements. Planning is necessary
for oversight analytical requirements and can cause schec,Iule delays
if information is not provided to EPA on a timely basis. ·
Section 4.9 -The treatability study evaluation reports will be
submitted in draft form at the conclusion of the treatability
studies and at 30% Design Stage.
I
4
l • •
Sampling & Analysis Plan
All field work will be conducted in accordance with the
Environmental Compliance Branch Standard Operating Procedures and
Quality Assurance Manual, (Region IV SOP), February 1, 1991. In
the event of conflict between the work plan and the Region IV SOP
occur, the Region IV SOP shall control.
Section 2.2.1, p 4 -EPA has clearly stated in the previous review
that the pesticides/PCBs analyses must be included for RD and Pre-
RD work.
Section 2.2.1, p 5 -
Specify which wells will be
installation of new monitoring
Section 2.2.2, paragraph 1
sampled
wells.
upon
Second sentence contains repeated phrase.·
completion of
Third sentence, the word "construction" seems inappropriate.
Fourth sentence, the word "ci:mstruction" is· used for depths
and screening intervals and is certainly not "construction
details".
Section 2.2.3
Bedrock monitoring wells: CRA says still not needed. Change
language stating that a "statistically significant increase in
contaminant concentrations has occurred" by providing
proposed methodolgy for this determination.
Section 3.0
Language must include clear statement that all sampling and
analysis activi~ies will be in accordance to Regiona IV SOP.
Decontamination procedures must clearly state that protocol
and guidelines of Region IV SOP will be adhered to.
Sampling instruments and equipment must clearly state that
protocol and guidelines of Region IV SOP will be adhered to.
Section 3.2.1
First sentence, first paragraph, advanced is mispel1ed.
Soil samples will be collected continuously during augering to
identify and classify soil materials. These are corings, not
soil samples. Table 3. 6 clearly shows the necessary fixed lab
analyses, but the text is very unclear and appears to be
screening only. Text requires clarification of the 12 samples
identified and the explanation of what those twelve represent.
Level IV DQO analysis must be conducted on soil borings.
5
• •
Section 3.2.2
Delete the word "unlikely" from top of page 12.
Water used by a drilling contractor should include full scan
analysis.
Section 3.4.1
If development to silt-free conditions is not possible, then
EPA will be consulted prior to deciding whether additional
development is necessary.
Well development will be conducted in accordance with the
procedures outlined in Appendix E, Section E.7 in the SOP.
The identification of a maximum 10 well volume amount is not
consistent with the SOP. Pumping dry for 3 consecutive days
is also not consistent. Refer to SOP for detail.
Section 3.4.3
Monitoring
sampling.
Section 3.4.4
wells should not be purged to dryness prior to
Refer to SOP Section 4.9.3 for details.
Provide rationale for not performing pesticides/PCBs.
QA/QC will be conducted in accordance with SOP.
Calibrations shall be undertaken at the beginning of each
field activity day; text shall specify this.
Table 3.6
Define difference between TAL and total dissolved metals.
Data Reporting requirements
During Field ;:,ark, the monthly reports will specify the
samples (by sample code) collected during the month being
reported, the analyses requested, the specific samples which
were split with EPA or a representative of EPA (to include
contractors), the anticipated date of preliminary data, the
expected date of verified data.
CLP data packages will be submitted to EPA within 2 months
after collection of samples, or explanation and anticipated
date of availablity of CLP data package.
Section 4.0
The water level measuring equipment should be rinsed after
each use to include the length of the devise that came into
contact with water in the well. Prior to use in each well,
the cleaning should include use of organic-free water and not
deionzied water.
Section B.2.0
Provide rationale for DQO level III; Level IV DQO is required,
6
•
especially for groundwater sampling.
sampling, Level IV is always required.
Analytical Capabilities
•
For private well
Analyses of contaminants must be adequate to detect at or
below detection limit.
ft
7
I .•
•
•
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV "~ ~,.?l~I~
J'u~f) ,? (/. ~b
~42).J} 1..9~,
MAR 2 O JQQ? 345 COURTLAND STREET. N.E.
Jimmy KirltUnd ATLANTA. GEORGIA 30365
King & Spalding
2500 Trust COmpany Tower
Atlanta, Georgia 30303
Re: Jadco-Hughes Superfund Site
North Belmont, North Carolina
Dear Mr. Kirkland:
~.?0,11
Enclosed are the EPA's comments to the Jadco-Hughes Remedial Design (RD) Work
Plan, to include Submittal A. The revised RD Work Plan is due on March 30,
1992. Please note the schedule requirements as outlined below:
30\ Design
60\ Design
90\ Design
Draft Final Design
RA Work Plan
O&M Plan
EPA review time will be
Due -120 days after RD Work Plan Approval
Due -30 days after receipt of EPA
comments on 30\ Design
Due -30 days after receipt of EPA
comments on 60\ Design
Due -30 days after receipt of EPA
comments on 90\ Design
Due -30 days after receipt of EPA
comments on 30\ Design
Due -30 days after receipt of EPA
comments on 60\ Design
30 days for each RD/RA·submittal.
EPA has been notified that the City Council of North Belmont remains opposed
to accepting the effluent of the pretreated water from the JADCO-Hughes
site. Development of an alternative discharge point ie critical to
pretreatment design, EPA requests that the current monthly reports include
statue reports of current progress toward a final effluent discharge point.
EPA ie pursuing the development of partition coefficients for the calculation
of soil cleanup numbers as specified in the ROD. Please do not hesitate to
contact me if you have any questions. I can be reached at 404/347-7791 or
fax number 404/347-1695.
~~ •.
:·,u•u••·-,, ~
Remedial Project Manager
waste Management Division
Enclosure
cc:_ R. Bussey, ORC
S. Botts, EPA
c. Fehn, NSRB
J. Lofton, DOJ
S. Quigley, CRA
L. Crosby, NC-DEHNR
[B: Nicholson, NC-DEHNR
)
Printed on Recycled Paper
•
•
• Jadco-Hughes superfund Site
North Belmont, North Carolina
RD work Plan comments
March 19, 1992
Page 2
•
Please note that the format and numbering system· used in CRA's
December 1991 Response to Agency Comments will be used for
simplicity.
REMEDIAL DESIGN WORK PLAN
( 1) Acceptable.
( 2 ) Acceptable.
(3) Provide the calculations that substantiate the volumes with all
assumptions provided.
(4) Acceptable. Table 2.1 will be clarified by labeling 2.lA and 2.1B for
landfill area & former operations area, respectively.
(5) Acceptable.
(6) Acceptable •
(7) EPA is currently developing partition coefficients for the calculation
of soil cleanup goals. The development of soil cleanup goals is a
requirement in the ROD. No agreement was reached between EPA and the
JADCO-Hughes Steering Committee regarding soil column testing. The
Agency is considering what options are available for the development of
soil cleanup goals.
(8) For purposes of this document, CRA's comment will be acceptable. It is
noted, however, that the State of North Carolina has not accepted CRA's
approach for the establishment of background. This issue must be
resolved no later than the submittal of the 301 Design.
(9) Page 19, first paragraph -The excepts from the ROD are not verbatim, as
directed in EPA'e first set of comments. Delete text beginning at the
secoad paragraph of Section 3.3 and continuing through the first
par••ph on page 19. (This consists of the elimination of two
par891:'aphs). The numbered items, 1 through 4, on page 19 will be
presented in the same order as written in the ROD, or verbatim. Delete
the last paragraph on page 21.
(10) Acceptable. The EPA and the Steering Committee should begin the
development of an adequate monitoring program immediately.
(ll) Acceptable.
(12) Acceptable.
•
•
•
• Jadco-Bughes Superfund Site
North Belmont, North Carolina
RD work Plan Comments
March 19, 1992
Page 3
(13) The incorporation is acceptable.
(14) Acceptable.
(15) See comment (9).
(16) Acceptable.
•
(17) Thie limit of three samples for the sampling of private wells is
inadequate. The number of samples in the immediate vicinity is
limited. Addition of more samples would not impact the schedule. If
necessary, EPA will conduct the sampling if the Steering Committee is
not willing to conduct the sampling.
( 1B) The City of Belmont has notified EPA that the city is "Not in favc·r" of
accepting the treated effluent from the site. Remaining options are:
Mt. Holly POTW and NPDES discharge oneite.
(19) Acceptable with the addition of an abstract for the system to be
included in the Work Plan. Greater description is required within the
30\ design •
(20) Acceptable.
SAMPLING AND ANALYSIS PLAN
(1) Acceptable.
DEHNR COMMENTS -REMEDIAL DESIGN WORK PLAN
(l) Acceptable to EPA.
(2) Acceptable to EPA.
(3) Acceptable to EPA.
(4) The response will be forwarded to the State.
'SAMPLING MP lll\LYSIS PLAN
·(l) Acceptable to EPA.
(2) Acceptable to EPA. Modifications may become necessary as the
development of the RD progresses.
General Connnents
(1) Acceptable to EPA. Labeling of individual containers should be done •
•
•
Jadco-Hughes sltrfund Site
North Belmont, North Carolina
RD work Plan Comments
•
March 19, 1992
Page 4
Comments by L. K. Williams, DEHNR
( l) Acceptable to EPA.
( 2) Acceptable to EPA.
( 3) Acceptable to EPA.
( 4) Acceptable to EPA.
Part C -USEPA Comments -11L2BL91
(l) Page 54 of the JADCO-Hughee ROD, Tha Selected Remedy, paragraph 4, states, "Further delineation of the plume will be necessary to determine the exact location of extraction wells." The text of the ROD further states, "The installation of bedrock wells may also be necessary.• The vertical extent of the contamination has not been defined in some areas on the site.
(2) This comment is reiterated. Ths sentence in the work plan states "The final remedy selected by USEPA in the ROD requires the following
actions: .••• • of which item 9 is identified and is insufficient.
Additional monitoring is required •
( 3)
( 4)
( 5)
(6)
(7)
(8)
Delete the first sentence after item 9 on page 4.
Acceptable.
The format of the table is acceptable, but only includes 12 of the site contaminants. Present a comprehensive table.
Acceptable.
Acceptable.
Thie comment is reiterate. As specifically stated in the comment, "additional discussion is needed in the WORK PLAN for further intcm?tion and to provide background and rationale for each of these pra-djiu,p activities".
HEALTH AND SAll'BTY PLAN COMMENTS
No additional comments on the Health and Safety Plan are provided.
EPA MONTHLY PROGRESS REPORTS
Mont~ly Progress Reports will be submitted in the following format:
l) Progress Made During the Month Reported;
I. Remedial Design,
II. Remedial Action.
•
•
•
• Jadco-Hughes Superfund Site
North Belmont, North Carolina
RD Work Plan COmments
March 19, 1992
Page 5
2) Problems Resolved;
3) Problems Anticipated;
4) Upcoming Events;
S) Personnel Changes;
6) Subcontractors;
7) Analytical Data;
8) Schedule;
9) other.
Appendix B -DATA MANAGEMENT PLAN
•
All aspects of the data management and document control for the JADCO-Hughes
Site w.ill be conducted in accordance to the Unilateral Administrative Order
(UAO), U.S. EPA Docket No. 91-31-C, Sections XX, XXI. Change Appendix B to
comply with the UAO.
EPA is continuing review of Submittal Band c. comments will be forthcoming •
• •
UNITED STATES ENVIRO~JMENTAL PROTECTION AGENCY
REGION IV
NOV 2 5 1991
4WD-NSRB
345 COURTLAND STREET. N.E.
Jimmy Kirkland
King & Spalding
2500 Trust Company Tower
Atlanta, Georgia 30303
ATLANTA. GEORGIA 30365
Re: Jadco-Hughes Superfund Site
North Belmont, North Carolina
Dear Mr. Kirkland:
Enclosed are additional EPA comments to the Jadco-Hughes Remedial
Design Work Plan. These comments supplement comments submitted by
the Agency, November 14, 1991 correspondence. Please incorporate and
resubmit the work Plan no later than December 26, 1991. The Sampling
& Analysis Plan (SAP) is being reviewed by the Regional Quality
Assurance officer for compliance with EPA policy and regulation. EPA
will notify you no later than December 11, 1991 if there are further
comments on the SAP.
Please do not hesitate to contact me if You have any questions. I
can be reached at 404/347-7791 or fax number 404/347-1695.
Si~9erely,
'· /, .,.--!;< ✓·' ;/,_// / //
/L , ( / '.-'~--~ '---
Barbara H. Benoy
Remedial Project
/j
-.~i I/ .--,<-
Manager
waste Management Division
Enclosure
cc: R. Bussey, ORC
c. Fehn, NSRB
s. Quigley, CRA
~B; -Nicholson, -NC-DEHNRJ
•
Jadco-Hughes Superfund Site
North Belmont, North Carolina
Remedial Design work Plan
EPA Comments
November 25, 1991
Page 1
WORK PLAN
SPECIFIC COMMENTS
•
Page 3. section 1. Item 3 -The work Plan states that four extraction
wells will be required by the ROD. The ROD simply states that:
"Extraction wells would be located in the areas of highest
contamination and would. be utilized for 'hot spot' pumping." The
number of wells, as.well as their locations and completion, should be
determined by the results of further sampling and monitoring to
delineate the contaminant plume.
Pages 3 and 4 1 Section 1 -The ROD requires: "Quarterly monitoring of
the Site, to include groundwater, surface water, sediments, and soils
.... "The work Plan only indicates in item 9, page 4, that periodic
monitoring of the groundwater will be performed. RD Work Plan must
include more specific information on the development of a monitoring
program.
Page 4, Section 1, First Paragraph (after item 9) -T~e Work Plan
states that: "Remediation required by the ROD are limited to remedial
activities within the Site boundaries." The ROD does not
specifically state that remedial activities are limited to locations
within site boundaries. Because the dimensions of the groundwater
contamination plume will be further defined as a required objective
for groundwater remediation, off-site extraction wells could be
required. [This comment was identified in the 11/14/91 comments.]
Pages 8 to 13, Section 2 -The sow specifically states that a
Background Summary will be included in the Work Plan that contains:
"A brief description of the site including the geographic location,
and a description of the physiographic, hydrologic, geologic,
demographic, ecological, cultural and natural resource features of
the site." Descriptions of demographic, ecological, cultural, and
natural resource features are missing.
Pages 8 to 13, Section 2 -The sow states that the Work Plan should
contain the physical and chemical characteristics of the site
contaminants. The Work Plan does not provide this information.
Page 14, section 3.0 -The ROD includes as a component of the
selected remedy Institutional Controls and/or other Land Use
Restrictions. No mention is made of using access and deed
restrictions except for page 19, section 3.3, item 3, where it is
apparently referred to as an option.
•
Jadco-Hughes superfund Site
North Belmont, North Carolina
Remedial Design work Plan
EPA comments
November 25, 1991
Page 2
•
Table 3.1, Following Page 15 -The soil remediation goals for lead
and polychlorinated.biphenyls (PCBs) are given in Table 3.1 as 3.2
and 25 mg/kg, respectively. The ROD and the sow indicate the soil
remediation goals for lead and PCBs are 1.3 and 10 mg/kg,
respectively. EPA has not approved revised goals for these
contaminants.
Page 27, section 6.1, Paragraph 4 -Reference is made to a number of
predesign activities and the reader is referred to the Sampling and
Analysis Plan.for further information. Additional discussion is
needed in the Work Plan to provide the background and rationale for
each of the pre-design activities. Also,· only the construction of
new monitoring wells is mentioned. The sampling and Analysis Plan
/
indicates that five monitoring Wells as well as six piezometers will
be installed. The piezometers are not mentioned in the work plan.
HEALTH AND SAFETY PLAN COMMENTS
GENERAL COMMENTS
1. The sow states the requirement that the Health and safety
Plan shall include a health and safety risk analysis. The
Health. and Safety Plan does not include a risk analysis. It
is suggested that a short section be added that summarizes
the hazards by type or class of contaminants found on site.
Health effects and symptoms should be noted so that site
workers will be aware of signs of exposure. A table should
be included showing a list of major contaminants,
permissible exposure limits, and Immediately Dangerous to
Life and Health (IDLH) levels where available. Material
safety Data sheets (MSDS) sheets for some of the chemicals
are included in the appendix, but the information is not
readily available.
2. The Health and safety Plan appears to be missing an overall
hazard evaluation and fire/explosion potential assessment.
These items should be included.
3. The Health and Safety Plan should include a list of field
tasks. Note for each task the type of work, the primary and
c.ontingency levels of personnel protection, and the schedule
for each activity.
•
Jadco-Hughes Superfund site
North Belmont, North Carolina
Remedial Design Work Plan
EPA comments
November 25, 1991
Page 3
•
4. A list of personnel and responsibilities including
subcontractors should be ·included,·and this list should
include the clearance/training levels of each person.
SPECIFIC COMMENTS
Pages 14 and 15, section 9 -This section should also address
supervisor training requirements and the ratio of supervisory to
regular trained employees allowable.
Page 21, section 12, second Paragraph -The statement is made
that the respiratory protection requirements may be relaxed with
the approval of EPA. The contractor is solely responsible for
this decision concerning his personnel and subcontractors. The
EPA will not assume an approval role as indicated.
Page 30, section 18.2. Items 2 and 4 -Provide further
clarification for the On-site contingency Plan. In item 4, is
the defined medical facility the Gaston Memorial Hospital
identified in Item 2? If so, then the predefined route is shown
on Figure 5. Also suggest adding the distance to {in miles) and
approximate time of travel to the hospital. In addition, it
would be helpful to describe the route in words to back up the
figure because it is not possible to read the street names.
Page 34. section 19.2, Item 7 -suggest adding "wind direction"
tO the list of observations recorded under field notes.
Page 41. Section 24.0 -Suggest including a statement concerning
availability of community relations personnel and/or information
to deal with the press and/or public if necessary.
\
' •
Jadco-Hughes superfund Site
North Belmont, North Carolina
Remedial Design work Plan
EPA comments
November 25, 1991
Page 4
TREATABILITY STUDY WORK PLAN COMMENTS
GENERAL COMMENTS
•
1. None of the activities described in the Treatability Study Work
Plan are covered· in the Health and Safety Plan. Treatability
study activities should be covered in the Health and safety
Plan.
SPECIFIC COMMENTS
Tables 3.1 -No information is provided as to how the "representative
concentration" was calculated. The 95 % Upper confidence Limit
concentration, (RAGS, 1989), may be used as a representative
concentration.
Page 4, section 3.2 -The text states that subsurface conditions that may
affect the design and performance of the SVE system are the variable
thicknesses and properties of the fill materials in the former landfill.
The text also states that the treatability study plan would describe the
use of three techniques to evaluate subsurface conditions: Developing
structure contour and isopach maps, performing drive-point air
permeability tests in c·on_junction with soil gas measurements, and
' analyzing the pressure response measured during the SVE pilot study.
However, only efforts involved in measuring and analyzing the pressure
response during the SVE test are really discussed. More details need to
be provided about how the referenced techniques will be used to ensure a
successful SVE treatability study.
Page•S, section 3.3, first paragraph after item 4, second sentence -
Something seems missing in this sentence. check this sentence for
accuracy and completeness.
Pages, section 3.3r Second Paragraph -Reference is made to the
installation of piezometers and soil gas sampling probes around the SVE
trench. Figure 3.3 shows what is identified as a piezometer/soil gas
probe installation. Piezometers are generally installed to measure
groundwater levels and the construction shown in Figure 3.3 is not typical
for a piezometer. clarification is required.
Page 6, Section 3.3.2 -No details are provide about the size or capacity
of the vacuum extraction blower unit, the air/water separator tank, and
other equipment. Fully evaluating the proposed SVE test system without
this information is not possible.
•
Jadco-Hughes superfund Site
North Belmont, North Carolina
Remedial Design Work Plan
EPA comments
November 25., 1991
Page 5
•
Page 6, Section 3.3.1, second and Third Paragraphs -statements in the
second and third paragraphs-appear inconsistent. The second paragraph
states: "The drummed soils (removed during excavation) will be addressed
during the final remediation for the Site." The third paragraph states
that: "The remaining portion of the trench will be backfilled with
excavated soils from the former landfill. clarification is r~quired.
Page 7, section 3.3.2, Last Paragraph -The proposed test will use two
1,200-pound activated carbon canisters in series, with two additional
1,200-pound canisters as replacements, should breakthrough occur. It
would be helpful as part of the study plan to estimate the anticipated
pounds (or an expected range) of extracted volatile and semivolatile
organic compounds to be extracted.
Pages 7 and 8, Section 3.3.3 -

A

general description of the soil gas probe
construction is covered. A procedure for the installation of the soil gas
probes is not provided in the Sampling and Analysis Plan or in the
Treatability study Work Plan. This information is required to complete
the review.
Pages 7 and 8, section 3.3.3 -The statement is made that the permanent
piezometers/soil gas probes will be installed to monitor the SVE pilot
study at distances of 25 and 50 feet from the SVE trench in directions to
be determined as appropriate by the project manager'. Information should
be provided about how this decision will be made, including the criteria
that will be used to determine the number and location of the probes.
Complete details of the test monitoring system should be evaluated by EPA
before the start of the test.
<>
Page 9, Section 3.3.4, First Paragraph and Page 9, section 3.3.5 -The
last sentence in section 3.3.4 states that: "The frequency and type of
monitoring of the SVE pilot study is presented in the sampling and
Analysis Plan.·• However, section 3. 3. 5 states that: "The frequency of
monitoring and sampling of the SVE system during the 30-day pilot study
will be at startup and every seven days thereafter." section 3.3.5 also
indicates that wellhead flow rates and subsurface vacuum measurements will
be taken as well as soil gas samples from each soil gas probe location, a
well head gas sample, and an offgas sample. However, on page 26 of the
SAP in section 3.5.2 Soil Gas Monitoring,· the statement is made that
samples of soil gas will be collected after the SVE system has been shut
off at least 48 hours. The information is in conflict and insufficient to
properly evaluate the adequacy of the proposed work plan. A table should
be provided to indicate the sample types or measurements to be made and a
proposed sampling schedule.
) •
Jadco-Hughes Superfund site
North Belmont, North Carolina
Remedial Design work Plan
EPA Comments
November. 25,. 1991
Page 6
•
Figure 3.3 -The rationale for the vertical placement of the soil gas
probe is not provided.
Page 8, section 3.3.4, First Paragraph -The sow indicates that the
measurements of performance shall be described in the Treatability study
Work Plan. This paragraph states that: "The system will be started up by
monitoring flowrates and subsurface. vacuum levels until an optimum level
of flow and vacuum is achieved." The optimum conditions are never defined
and the specific objectives and criteria to be used are not presented.
Page 9, section 3.3.5 -Methods for taking samples during the SVE'pilot
study are described in the SAP (Submittal B) but methods of analysis of
the samples are not provided. In addition, data qualitr objectives for
the SVE pilot study are not specifically discussed.
Page 10 1 section 3.3, last paragraph, last sentence -sentence needs to be
checked for grammatical error.
Figure 4.1 -The text describes the use of diffusers to provide the mixing
of air and water. Figure 4.1 shows what appears to be a paddle in the
aeration tank but it is not identified as a diffuser. Also, "exhaust air"
is shown but no air entering the tank.
Table 4.3, voe and BNA Compounds -The Quantitation limits (also referred
to detection limits in text) include many quantitation limits equal to or
greater than the cleanup goals defined in the ROD. Analytical methods
should be selected such that the detection limits will be lower than
cleanup goals. Those cleanup goals established by the federal government
are above detection limits. Treatability study Plan should identify and
explain those compounds which have detection limits greater than the
cleanup goals.
Page 12, Section 4.0 -The groundwater treatment treatability study is
technically a bench-scale or laboratory.-scale study, not a pilot-scale
study as indicated in the text.
Page 14, Section 4.3 -The design of the bench-scale testing system should
be generally proportional in capacity and configuration to the planned
full-scale system.
•
Jadco-Hughes superfund site
North Belmont, North Carolina
Remedial Design Work Plan
EPA_Comments
November 25, 1991
Page 7
Page 16, Section 4.4.3 -From the discussion in the text, one of the most
important design considerations for the aeration system is the
"diffuser". It is not just the air-to-water ratio that is important but
how the two phases come into contact. No information is provided on the
design of the diffuser to be used for the pilot study and how this design
will be used to develop a full-scale system ..
SAMPLING AND ANALYSIS PLAN COMMENTS
GENERAL COMMENTS
1. The Sampling and Analysis Plan (SAP) and Quality Assurance
Project Plan (QAPP) are primarily intended to be documents for
the field sampling team and project team to use as guidelines
during sample planning, collection, shipment, data evaluation,
and reporting. The Scope of Work specifically states that: "The
Field sampling and Analysis Plan shall be written so that a
field sampling team unfamiliar with the site would be able to
gather the samples and field information required." The SAP
provided presents information in a general-manner and does not
meet this objective.
2. The QAPP is typically prepared to address the entire project and
reference is made to the appropriate sections of the laboratory
Quality Assurance Plan, which can then be attached. This QAPP
is written heavily toward laboratory Quality Assurance/Quality
control (QA/QC) and fails•to properly address the field data
collection and measurement activities in detail. If the
required detail were found in the Field s~pling Plan, it would
be acceptable. However, in many cases the information is
·missing completely, in particular a description of the complete
project organization and responsibilitied.
3. No background information on sampling objectives and rationale
are presented in the SAP. It is questionable whether the SAP is
writt.en in adequate detail for a field sampling team that is
unfamiliar with the site to be able to collect the samples and
information required as described in the Unilateral
Administrative order.
4. The SAP should include sampling and analysis of investigation
derived wastes. If not covered at this t~rne, another SAP and
QAPP will have to be prepared later for this activity.
•
Jadco-Hughes superfund site
North Belmont, North Carolina
Remedial Design work Plan
EPA Comments
November 25, 1991
Page 8
•
5. The SAP fails to state the total number of samples from each
matrix to be collected.
6. Neither the SAP or the QAPP provides a detailed description of
the use and maintenance of field logbooks. The use of
photographic documentation is also not mentioned.
SPECIFIC COMMENTS
Page 1, Section 1.0 -The soil vapor Extraction (SVE) Pilot study as a
pre-design activity is not identified as a separate item, or as part of
the installation of the SVE system.
Page 1, Section 1.0, First Paragraph -The sampling an<;l Analysis Plan
includes the Quality Assurance Project Plan (QAPP). The terminology in
the document is not consistent with EPA terminology.
Page 1, Section 1.0, Item 6 -sampling of residential wells is an optional
activity however, a protocol for the activity is not provided. The
protocol for sampling monitoring wells is not appropriate for sampling
residential wells.
Page 2, section 1.0, Last Paragraph -The statement is made that: '"This
report presents protocols that will be followed during the RD activities
which are described in the RD work Plan." Pre-RD activities are
identified as separate from RD. All pre-RD protocols need to be presented
in the Sampling and Analysis Plan if not presented in the Treatability
study Work Plan. Protocols for installation of the soil' gas probes are
not provided in either submittal.
Page 4, Section 2.2.1 -The text indicates that filtered samples for
metals analyses will be collected from selected monitoring wells to
determine if there is a difference between filtered and unfiltered
samples. Unfiltered samples should also be collected at the same time for
the comparison instead of using previously collected data. EPA procedure
dictates the collection of unfiltered samples. Filtered samples are not
accepted as the data of record.
Page 6, Section 2.2.3, First Paragraph -The statement is made that: " ...
positive vertical hydraulic gradients in the areas of elevated contaminant
·concentration would not support the downward movement of contaminants."
The only data concerning hydraulic gradients are summarized in Figure 2.2
of the Work Plan. These data indicate that a slight vertical upward
gradient may exist. However, in areas of saprolite, groundwater flow
generally occurs in fractures or along.remnant structures. The vertical
•
Jadco-Hughes Superfund site
North Belmont, North Carolina
Remedial Design work Plan
EPA comments
November 25, 1991
Page 9
•
gradient may not be _a controlling factor. In addition, several of the
contaminants identitied are dense non-aqueous phase liquids. If present
in sufficient volume, these compounds will migrate downward based on a
density greater thari water and will not be affected by the hydraulic
gradient. The most likely location to monitor for these compounds would
be at the top of the bedrock.
Pages 11 to 15, Sections 3.2.2.1 and 3.2.2.2 -Both sections discuss
drilling fluids, bentonite seals, and grout mixtures. No mention is made
of analytical.testing for QC purposes. For example, in making up the
drilling .fluids or grout mixture, what is the source of water and what
provisions are there to assure it is not a source of-contamination?
Page 14, section 3.2.3 -This section fails to mention that all well
screen and casing must be decontaminated before installation.
Page 17, section 3.2.3 -No mention is made of surveying
elevations of the new monitoring wells and piezometers.
done,• by whom, and to what tolerance limits?
the locations and
Will this be
Page 18, section 3.4.l, Well D -It would be desirable to specify a single
method with a contingency method if necessary, rather than a laundry list
of possible methods. Given the amount of work conducted at the site to
date, a· viable method should be known and identified in the Field sampling
Plan.
Page·20, section 3.4.2 -sufficient detail on the protocols needs to be
provided to support an evaluation of the adequacy of the selected
procedure to provide required information._ The general statement in this
section that hydraulic conductivity will be determined by any one of the
available slug test methods is insufficient information. Also, the use of
a slug ·test in saprolite is questionable because only the near well
environment is investigated. The information obtained is probably
unreliable if it will be used to design a groundwater recovery system. An
aquifer test appears to be required but has not been proposed.
Page 21, Section 3.4.3, Item 2 -Need to specify a single method for well
purging with a contingency method if necess_ary. The field crew cannot
implement a plan with so many choices to make and all equipment for all
options will have to be on site. This is not practical.
Pages 25 to 27, Section 3.5 -The section does not indicate what the gas
samples will be analyzed for.
', •
Jadco-Hughes superfund Site
North Belmont, North Carolina
Remedial Design Work Plan
EPA comments
November 25, 1991
Page 10
•
Page 27, Section 3.5.2, Item 7 -The item references information that is
not found in the QAPP.
Page 29, section 3.6.2, First Paragraph -The statement is made that water
and soil samples will be delivered to the laboratory within 48 hours of
sample collection. In seCtion 3.5 the statement is made that gas samples
will be shipped to the laboratory within 24 hours of collection. Table
3.2 indicates that all samples will be shipped by Federal Express Priority
1. suggest simplifying the discussion to one term and describe shipments
in terms of same day or next day after sampling.
Table 3.2 -The table needs'to be expanded to include the requirements for
the necessary QA samples. In particular no eguip_ment rinseate samples
from soil sampling are shown. Equipment rinseate should be collected at
least once from each piece/type of sampling equipment used, an~ more
frequently if an extended field investigation occurs or if site
conditions, personnel, supplies, or equipment change in a manner that may
affect the decontamination procedure. See EPA SOP.
Table 3.2 -The holding time for Target Compound List (TCL) volatile
organic compounds (VOCs) is 14 days, not 60 days.
Page 30, Section 3.7.1 -Reference to analysis Of dissolved metals should
be added.
Page 33, Section 4.0 -Why is there not a rinse with potable water after
the wash with detergent to remove the detergent before the rinse wit~
deionized water?
Page 33, section 4.0 -Assuming potable water will be used for the steam
wash, what is the source of the potable water? How often will it be
sampled for QC purposes?
· Page 33, section 4.0, 2nd Paragraph -The equipment referred to inc~udes
trowels. The use of trowels was not mentioned in the sampling
procedures. Neither section appears to con·tain adequate details.
Pages 33 and 34, Section 4.0 -This section needs to be more explicit in
explaining the physical configuration and pieces of equipment to be used.
Also need to establish where clean equipment will :>e store for _drying, how
this area will be protected from dust, etc., and how clean equipment will
be wrapped (foil or plastic).
•
Jadco-Hughes superfund site
North Belmont, North Carolina
Remedial Design work Plan
EPA comments
November 25, 1991
Page 11·
•
Pages B-1 to B-2, Section B.1 -Although the introduction to the section
indicates that the procedures within the QAPP shall be used for sample
collection and laboratory analysis, the description of project personnel
and their qualifications and responsibilities are limited to the
laboratory personnel.
Page B-3, Section B.2, Third Paragraph -Reference is made to surface
water and sediment samples that do not appear to be collected as part of
this study.
Page B-4, Section B.2.1, Second Paragraph -The EPA specifies that one
duplicate be collected for every ten samples. The proposed requirement
for a minimum of one duplicate per day is unnecessary. The same comment
applies to the rinseate blanks.
Page B-5, section B.2.1, First Paragraph -samples for voe analysis will
be preserved by the addition of HCl to a pH<2. It is assumed that the
sampling bottles for volatiles will be pre-preserved.
Page B-8, section B.2.5 -This section discusses g~otechnical testing of
samples whose collection was not mentioned or described in detail in the
SAP.
Page B-10, Section B.3.0 -This section should provide detailed
step-by-step procedures for each type of sample collection effort.
Detailed lists of equipment needed for each event should also be
included. Although this information could be provided in the SAP instead
of the QAPP, the level of detail provided in the SAP does not meet this
requirement.
Page B-16, section B.5.3 -This section needs to include calibration of
the gas monitoring equipment.
Page B-20, Section B.6.1 -surface water and sediment samples are
mentioned but do not appear to be collected as part of this investigation.
Page B-23, Section B.7.0 -This section needs to include a detailed
discussion on the archiving of all field and laboratory data. The
discussion is also focused primarily on laboratory data; the field data
needs to be discussed in more detail.
Page B-27, section B.8.2.3, Top of Page -Mention is made of pesticide/PCB
analyses for the first time. Pesticide/PCB cleanup goals are included in
the site ROD and should be included in this study.
•
Jadco-Hughes superfund site
North Belmont, North Carolina
Remedial Design Work Plan
EPA Comments
November 25, 1991
Page. 12
•
Page B-28, section B.9.0. -This section only addresses the laboratory
performance and needs to include the fieldwork.
Page B-30, Section B.10.0 -This section only discusses preventive
maintenance of laboratory equipment and needs to include field equipment
including gas monitoring equipment.
Page B-32, Section B.11.0 -This section would normally include a
discussion of representativeness and comparability. These factors are
evaluated during data collection to assess the reliability of the data
collection effort. This section focuses on laboratory related issues and
such a discussion is not provided.
Page ·s-32. Section B.11.1.1, Precision -

·

How will precision be reported?
Page B-32, section B.11.1.2, Accuracy -How will accuracy be reported?
Page B-33, Section 12.0 -This section needs to address the field
activities as well as the laboratory analyses.
Page B-34, section 13.0 -ThiS section should include the results of
performance audits. In addition, this section should address field
measurement activities reported and specify a frequency of reporting for
all activities.
.. • • UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
4WD-NSRB
Jimmy Kirkland
King & Spalding
2500 Trust Company Tower
Atlanta, Georgia 30303
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
Re: Jadco-Hugh~s Superfund Site
North Belmont, North Carolina
Dear Mr. Kirkland:
Enclosed are the EPA's comments to the Jadco-Hughes Remedial Design
Work Plan. Please incorporate and resubmit the Work Plan no later
than December 16, 1991. Additional comments on submittals A, B, and
c, which accompanied the work Plan will be forthcoming.
Please do not hesitate to contact me if you have any questions. I
can be reached at 404/347-7791 or fax number 404/347-1695.
sincerely,
/
Barbara H. Benoy
Remedial Project Manager
waste Management Division
Enclosure
cc: R. Bussey, ORC
c. Fehn, NSRB
s. Quigley, CRA
B. Nicholson, NC-DEHNR
Printed on Recycled Papor
•
Page 2 Intro.
section 2.0
section 2.2
section 2.2
•
Tables 2.1-2.2
section 2.3 Pagel3
Section 3.2 Page 15
Section 3.3 Page 16
Section 3.3
section 3.3 Page 18
•
Jadco-Hughes superfund Site
North Belmont, North Carolina
Remedial Design work Plan
EPA comments
November 14,. 1991
Text failed to identify metals contamination and
should be corrected.
Total concentrations of volati.le organic compounds
(VOCs), extractable organic compounds (BNAs) do not
correlate to the objectives of the remedy. These
total voe and BNA concentrations are misleading and
should not be used the description of the
contamination. specific compounds and corresponding'
concentrations are needed.
The derivation of volume estimations must be
explained.
Provide a contamination profile for the former
operations area .
No information is provided ·as to how the
"representative concentration" was calculated. The
95 % Upper confidence Limit concentration, (RAGS,
,1989), may be used as a representative concentration.
Last sentence should read as follows: ""The "selected
remedy will attempt to mitigate transport of site
contaminants thereby minimizing the potential risk to
human health and the environment.""
The third paragraph states that soil column testing
will not be conducted. The scope of work, as required
by the Unilat,eral Administrative Order, and as
specified in the ROD, requires the collection of
additional data to include soil sampling for the
development of site specific soil partition
coefficients to ensure the development of a complete
and comprehensive· list of soil cleanup goals. This
Remedial Design work Plan is deficient in meeting
these requirements of the sow.
The language stating that background concentrations
will be used for metals should be deleted. Cleanup
goals are established for groundwater.
This section includes excerpts from the ROD. If this
language is used in the RD work Plan, it must be
verbatim.
The last sentence, first paragraph, must be deleted.
Duration has not been established.
•
Section 3.3 Page 18
Page 19
Page 19
Section 4.0 Page 20
Section 6.1 Page 28
Section 6.2.2
Section 6.2.3
section 6.2.3
Submittal B
•
Delete "'(the Site)"' in the second paragraph.
change third paragraph to read as follows: "Where
such a contingency situation arises, groundwater
extraction and treatment would typically continue as
necessary to achieve mass reduction and remediation
goals throughout· the rest of the area of attainment."
Last sentence should read as follows: "engineering
controls such as physical barriers, or long-term
gradient control provided ...... "
Add ·• 5) periodic reevaluation of remedial
technologies for groundwater restoration."'
Delete the last paragraph.
change "approved" to "overseen" in the last sentence
of this page.
Item 7; no limit will be set on the number of samples
to be collected from private wells.
The permit from the Belmont POTW may be required prior
to final RD approval.
The design of the soil flushing system must be
included in the Remedial Design and appropriate
information must also be included in this document.
Modifications may be made in the future, if
necessary. EPA must be provided information on this
portion of the remedy at all phases of the RD. North
Carolina's input at this stage of the RD development
is critical. This RD work Plan is deficient in this
area.
The conceptual design information for the groundwater
extraction system·must be included in this document.
This RD Work Plan is deficient in this area.
Section 4.0 Equipment cleaning protocols specifies the
use of a deionized water rinse following a solvent
rinse. The US-EPA Region IV·, ESD, Environmental
Compliance Branch, standard operating Procedures and
Quality Assurance Manual, February 1, 1991 9ECBSOPQAM)
Appendix B, Section B.8, paragraph B.8.3, specifies
the use of an organic-free water rinse. The paragraph
further states in item 6, that water which has only
been deionized or distilled is not to be used for this
final rinse. In the absence of organic-free water,
equipmnet should be allowed to air dry for as long as
possible.
[
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• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Marlin, Governor
William W. Cobey, Jr., Secretary 30 October 1991 William L. Meyer
Director
MEMORANDUM
TO:
FROM:
RE:
Bruce Nicholson
Environmental Engineer
Luanne K, Williams, Pharm.D.~l,J
Environmental Toxicologist
Jadco-Hughes Site Remediation Objectives
NCD980729602
Belmont, Gaston County, North Carolina
After reviewing the Jadco-Hughes Site Remediation Objectives, I
have the following comments:
1.
2.
3.
Justification should be provided regarding the deletion of
several soil and groundwater contaminants from the remediation
objectives.
As a · conservative approach, a risk assessment should be
determined assuming worker exposure to surface soil and
groundwater. Surface soil exposure should be assumed in the
risk assessment because the subsurface soil could potentially
be disturbed. Consequently, direct contact could .occur.
Additivity among the carcinogens and additivity among the
noncarcinogens were not considered in the determination of the
cleanup levels. According to the Environmental Protection
Agency December 1989 Risk Assessment Guidance For Superfund.
Volume I: Human Health Evaluation Manual p. 8-12, and p. 8-
13, carcinogenic effects should be treated as additive and
noncarcinogenic effects should be treated as additive. Dose
additivity is most appropriately applied to compounds that
produce the same effect by the same mechanism of action.
Therefore, chemicals producing similar health effects or
critical effects should be grouped together to take into
account additivity of the effect. These assumptions are made
to help prevent an underestimation of carcinogenic risk (risk
of cancer) or noncarcinogenic risk (risk of harmful effects
other than ·cancer).
An E.qual Oppom,nlry A/1\rmative Acl!on Emp~
•
Bruce Nicholson
30 October 1991
Page 2
•
4. Additive carcinogenic and noncarcinogenic effects for soil and groundwater exposure should also be considered in the determination of the cleanup levels. Additivity among exposure media is considered to prevent an underestimation of carcinogenic risk or noncarcinogenic risk.
00:00 00, 00 rni: 90d ,si:
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•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor ·
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
Remedial Project· Manager
North Remedial Branch
U.S. EPA Region IV
November 3, 1991
345 Courtland Street, N.E.
Atlanta, GA 30365
subj: Jadoo-Hughes Remedial Design work Plan Comments
Dear Ms. Benoy:
William L Meyer
Director
The NC Superfund Section appreciates this opportunity to comment on the Remedial Design Work Plan for the Jadoo-Hughes NPL ·site. We offer the following comments:
REMEDIAL DESIGN WORK PLAN
1. Page 3, paragraph 3. we suggest-that the groundwater collection sump for the annulus of the slip-lined culvert.be added to the list of items for the groundwater extraction system.
2. Page 15A, Table 3. 1. This list of soil cleanup goals is wholly inadequate. We note that there are 42 organic and 22 inorganic contaminants listed on Table 2.1 as being in site soils, but the vast majority of these compounds have been left off of Table J.l. Furthermore, Table 3.1 includes remedial goals for chloroform and carbon tetrachloride which, according to Table 2.1, are not found in site soils. This remedial goal list needs serious revision.
Also, the cleanup goal presented for PCB's is 25 mg/Kg: This is not consistent · with removal actions which have been conducted previously on the site. In these removal actions, PCB's were removed to less than 10 mg/Kg followed by backfilling with clean cover. Note, this was a removal action,·
Ari Equal Opporrunlty Alllrma!I--, Acdon ~
20d 1£1 00:00 00, 00 10T
Ms. Benoy
11-3-91
Page 2
• •
not a remedial action. For that reason it was correct to use the EPA Spill cleanup policy. However, for a long term remediation, it is important to generate a health-based remedial level rather than an arbitrary level from the EPA spill cleanup policy. A remediation level for the PCB's in the landfill area should be health based.
3. Page 16A, Table 3.2. It is noted that 6 compounds which are found in the groundwater, according to Table 2.2, are not on this remedial goal list. They include carbon disulfide, 1,1,2,2-trichloroethane, di-n-octylphthalate, 2-methylphenol, ,4-methylphenol, and naphthalene. These compounds need to be addressed or justifications for their absence from the remedial goals should be presented.
4. Tables 3.1 and 3.2. concerning the general approach taken to development of cleanup levels, the state of North Carolina supports using the current U.S. EPA risk assessment guidance, which states that additivity must be assumed for sites with multiple contaminants. This is particularly important for a site such as Jadco-Hughes where there are dozens of contaminants. For the complete State position on this subject please .refer to the attached memorandum from Luanne K. Williams, Pharm. D.
SAMPLING AND ANALYSIS PLAN
1. Page 4A, Figure 2.1. Please present well depths for existing and proposed wells on this figure.
2. Page 6, paragraph 1. Why are piezometers 8 through 10 proposed for the property line instead of-monitoring wells? The proposed locations appear to be excellent for sentry wells, not just piezometers.
GENERAL COMMENTS
1. General Co111I11ent. We noted in Section 5.0 of the Sampling and Analysis Plan that all investigation-derived wastes (IDW) will be containerized on site until final remediation. The state supports this action. However, the state strongly suggests that complete access restrictions and warning signs placed prior to generating any IDW that will remain on site. This should be stated in the RO Work Plan. This action will reduce the chance of the public coming in direct contact with these wastes.
£0d 1S1
Ms. Benoy
11-3-91
Page J
• •
If you have any questions concerning these comments please contact me at [phone].
BIN/let/jhrdcom
cc: Jack Butler
Luanne K. Williams
Attachment
sincerely,
bhols:n
Chemical Engineer
superfund Section
• .. -</:.:".~.r.:,•~~-
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tl0 1~l
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State of North Carolina
•
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
J;ime.s G. Martin, Governor
William W. Cobey, Jr., Secretary
FAX TRANSMITTAL RECORD
William. L. Meyer
Director
From: , Solid Waste Management Division ------------
, Solid Waste Section ------------
, Hazardous Waste Section ------------
i,3.1' t ,t e . l\l 1 ,... he, l -t:f'l:"l. , Superfund Section .
Date:
J
To:
Re:
No. of Pages (Including Cover) C.
Confirm receipt of document(s)
Division of Solid Waste Management
Hazardous Waste Section
Superfund Section
Solid Waste Section
[phone]
[phone]
[phone] ·
[phone]
. .......... ..... ...,..-;_,. STATL ,, '-.'-.. ;:·~",_~·;"' "~ ~;\.
:~ -·: ' ",..,. ... ~ is ;p.·m~.("' c:\ ,~ ,}, I<'-. ~/ ~v ,1,, 1· \;, '8111 .,.,,.., 1 • .;) •. 1 ?/ \,ii -. • ., .... -• ~.: ::~/::;/
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
Remedial Project Manager
North Remedial Branch
U.S. EPA Region IV
November 3, 1991
345 Courtland Street, N.E.
Atlanta, GA 30365
Subj: Jadco-Hughes Remedial Design Work Plan Comments
Dear Ms. Benoy:
William L. Meyer
Director
The NC Super fund Section appreciates this opportunity to comment on the Remedial Design Work Plan for the Jadco-Hughes NPL Site. We offer the following comments:
REMEDIAL DESIGN WORK PLAN
1. Page. 3, paragraph 3. We suggest that the groundwater collection sump for the annulus of the slip-lined culvert be added to the list of items for the groundwater extraction system.
2. Page 15A, Table 3 .1. This list of soil cleanup goals is wholly inadequate. We note that there are 42 organic and 22 inorganic contaminants listed on Table 2.1 as being in site soils, but the vast majority of these compounds have been left off of Table 3.1. Furthermore, Table 3.1 includes remedial goals for chloroform and carbon tetrachloride which, according to Table -2.1, are not found in site soils. This remedial goal list needs serious revision.
Also, the cleanup goal presented for PCB's is 25 mg/Kg. This is not consistent with removal actions which have been conducted previously on the site. In these removal actions, PCB's were removed to less than 10 mg/Kg followed by backfilling with clean cover. Note, this was a removal action,
An Equal Opporrunity Affirmative Action Employer
....
Ms. Benoy
11-3-91
Page 2
• •
not a remedial action. For that reason it was correct to use the EPA Spill cleanup policy. However, for a long term remediation, it is important to generate a health-based remedial level rather than an arbitrary level from the EPA spill cleanup policy. A remediation level for the PCB's in the landfill area should be health based.
3. Page 16A, Table 3.2. It is noted that 6 compounds which are found in the groundwater, according to Table 2.2, are not on this remedial goal list. They include carbon disulfide, 1,1,2,2-trichloroethane, di-n-octylphthalate, 2-methylphenol, 4-methylphenol, and naphthalene. These compounds need to be addressed or justifications for their absence from the remedial goals should be presented.
4. Tables 3.1 and 3.2. Concerning the general approach taken to development of cleanup levels, the State of North Carolina supports using the current U.S. EPA risk assessment guidance, which states that additivity must be assumed for sites with multiple contaminants. This is particularly important for a site such as Jadco-Hughes where there are dozens of contaminants. For the complete State position on this subject please refer to the attached memorandum from Luanne K. Williams, Pharm. D.
SAMPLING AND ANALYSIS PLAN
1. Page 4A, Figure 2.1. Please present well depths for existing and proposed wells on this figure.
2. Page 6, paragraph 1. Why are piezometers 8 through 10 proposed for the property line instead of monitoring wells? The proposed locations appear to be excellent for sentry wells, not just piezometers.
GENERAL COMMENTS
1. General Comment. We noted in Section 5.0 of the Sampling and Analysis Plan that all investigation-derived wastes (IDW) will be containerized on site until final remediation. The state supports this action. However, the State strongly suggests that complete access restrictions and warning signs placed prior to generating any IDW that will remain on site. This should be stated in the RD Work Plan. This action will reduce the chance of the public coming in direct contact with these wastes.
Ms. Benoy
11-3-91
Page 3
• •
If you have any questions concerning these comments please
contact me at [phone].
BIN/let/jhrdcom
cc: Jack Butler
Luanne K. Williams
Attachment
sincerely 'itJl-
bholson
Chemical Engineer
Superfund Section
..-<:.Sv,rt::•, ..
;-~~ftf~J)::;~ (~~~~) • •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary 30 October 1991
MEMORANDUM
TO:
FROM:
RE:
Bruce Nicholson
Environmental Engineer
Luanne K. Williams, Pharm.D.~W
Environmental Toxicologist
Jadco-Hughes Site Remediation Objectives
NCD980729602
Belmont, Gaston County, North Carolina
William L. Meyer
Direclor
After reviewing the Jadco-Hughes Site Remediation Objectives, I
have the following comments:
1. Justification should be provided regarding the deletion of
several soil and groundwater contaminants from the remediation
objectives.
2. As a · conservative approach, a risk assessment should be
determined assuming worker exposure to surface soil and
groundwater. Surface soil exposure should be assumed in the
risk assessment because the subsurface soil could potentially
be disturbed. Consequently, direct contact could occur.
3. Additivity among the carcinogens and additivity among the
noncarcinogens were not considered in the determination of the
cleanup levels. According to the Environmental Protection
Agency December 1989 Risk Assessment Guidance For Superfund,
Volume I: Human Health Evaluation Manual p. 8-12, and p. 8-
13, carcinogenic effects should be treated as additive and
noncarcinogenic effects should be treated as additive. Dose
additivity is most appropriately applied to compounds that
produce the same effect by the same mechanism of action.
Therefore, chemicals producing similar health effects or
critical effects should be grouped together to take into
account additivity of the effect. These assumptions are made
to help prevent an underestimation of carcinogenic risk (risk
of cancer) . or noncarcinogenic risk (risk of harmful effects
other than cancer).
An Equal Opportunity Affirmative Action Employer
Bruce Nicholson
30 October 1991
Page 2
• •
4. Additive carcinogenic and noncarcinogenic effects for soil and groundwater exposure should also be considered in the determination of the cleanup levels. Additivity among exposure media is considered to prevent an underestimation of carcinogenic risk or noncarcinogenic risk.
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
4WD-NSRB
OCT O 3 1991
Bruce Nicholson
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
N.C. Department of Environment,
Health & Natural Resources
401 Oberlin Road
Raleigh, NC 27605
Re: Remedial Design Work Plan
Jadco-Hughes Superfund Site
North Belmont, N.C.
Dear Mr. Bruce:
Enclosed is the Remedial Design Work Plan for the Jadco-Hughes
Superfund Site. This report was received by the Agency on Sept. 30,
1991. All review comments should be submitted no later than October
24, 1991. If you cannot comment by this date, please call me
immediately.
A RD/RA scoping meeting was held in August between the Steering
Committee/CRA and EPA. It was decided that a Site visit would be
beneficial to better define the objectives of the RD/RA. The Site
visit has been scheduled for October 29, 1991. A public meeting will
be held in the evening on the 29th._. The meeting was determined
necessary in order to clear up some confusion the public seems to
have between the Jadco-Hughes Site and\the North Belmont Site.
If you have any questions regarding thi\ Site, please do not hesitate
to call me at 404/347-7791. '··--
'Jjely, ~
Darcy~
cc: Curt Fehn, EPA ..
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