NCD980840409_20031117_Charles Macon Lagoon Drum_FRBCERCLA RD_Remedial Design Remedial Action 1990 - 2003-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
4WD
Ms. Jill C. Lemacks
Project Geologist
Applied Earth Sciences, Inc
434 Copperfield Blvd, NE
Suite B
Concord, NC 28025
SUBJ: Macon/Dockery NPL Site
Cordova, NC
Dear Ms. Lemacks:
November 17, 2003
The US EPA, along with the. NC DENR, has reviewed the July 15, 2003 letter in
which a request for modification to the analytical requirements of the remedial action
was made. The request was for the elimination of certain parameters in ten (10) of the
wells-currently in the monitoring network.
The following requests have been granted: the request for elimination of the
purgeble aromatics in wells MW-11, MW-13, MW-16, MW-21, MW-23, MW-24, and
MW-25; the request for elimination of the metals cadmium and lead in wells MW-2A,
MW-19, MW-21, MW-23 and MW-24; and the request for elimination of cadmium in
wells MW-13 and MW-22. However, the analysis of lead in MW-13 and MW-22 and the
analysis of purgeable halocarbons in Wells MW-24 and MW-25 must be continued and
therefore, the request for elimination of these parameters is denied for these wells.
If you have any questions, or would like to discuss this matter further, please
give me a call at 404-562-8824.
cc: David Mattison, NC DENR
Sin ly,~
iezelle S. Bennett
emedial Project Manager
Internet Address (UAL)• http://www.epa.gov
R0cycled/Recyclable a Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30"/., Posti:onsumer)
• ••
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4WD-NSMB
Technical Committee
c/o David L. Jones
Ingersoll-Rand Company
114 Spencer Road
Cassopolis, Ml 49031
REGION 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
January 12, 2000
SUBJ: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Jones:
This letter is written to notify you that the Macon/Dockery NPL Site will be the subject of a
'1ive-year review" this fiscal year. The. purpose of a five'year review is to determine whether the
remedy at a site is protective of human health and the environment. EPA conducts five-year
reviews as a matter of policy for sites where_ a remedial action will allow for unlimited use and
unrestricted exposure upon completion, but where attainment of cleanup goals will take longer
than five years. This policy is consistent witti'both CERCLA Section 121(c) and the NCP.
The remedial action at Macon/Dockery was formally initiated in May 1995 when the RA
contract for construction of the soil vapor extraction (SVE) and groundwater remediation systems•
was awarded. Therefore, the five-year review is due May 2000. EPA is hereby requesting a
sampling and analysis plan, complete with schedule, for sampling the soils in Lagoon 7, which
were the subject of the SVE treatment. Please submit this plan to the Agency no later than
February 14, 2000.
Based on the results of this sampling investigation, the Agency will determine if the SVE
treatment should continue. The Record of Decision contemplated that the SVE system would
operate for only three years.
Please give me a call at 404-562-8824 if you have any questions.
cc: David Mattison, NC DENR
Steve lrminger, AES
1ezelle S. Bennett· .
·Remedial Project Manager
I•'• '
05/27/1995 17:37 4044097893 i.--AES -ATLANTA •
FAX TRANSMISSION
To:
Fax#:
Distribution
see below
From: Ronald J. Wallace
Subject: Macon /Dockery
Dave Jones
219-282-3961/
Giezelle Bennett
404-347-1695 ✓
Richard Ogle
713-981-8821
APPLIED EA.RTH SCIENCES, INC.
13525 )HE CORN~RS PAR1\W.A.Y :!iu1TE -400
NORCROC-e. GEOAGl.l 30092
<770)-448-491 I
FAX; (7701•409-7693
Date: JW1e 27, 1996
Page.: 2, including this cover sheet.
Kenny Gulledge Toro Effinger John Chidley
803-537-4382 v 803-748-3568...--804-383-2216 ✓
Nonna Eichlin David Lown Paul Furtick
770-951-8910.,,, 919-733-4811 615-883-5793
J~ri 4 269
COMMENTS: Proposed O & M Schedule Change
PAGE 01
06/27/1996 17:37 4044097893 •
June 27, 1996
Ms. Giezelle Bennett
Remedial Project Manager
US EPA, Region IV
345 Courtland Street
Atlanta, Georgia 30365
AES -ATLANTA.
Re: Moron/Dockery Site. Cordova, North Carolina
Proposed O & M St?hedule Change
Dear Ms. Bennett:
PAGE 02
The four groundwater treatment systems and the soil vapor extraction (SVE) system have operated
since February 1996. An autodialer has been installed at the SVE system, thereby all systems now
have autodialers. The Operation and Maintenance Plan prepared by RMT recommended weekly
monitoring activities at the different treatment systems. Presently, technicians respond to all alarms
identified by the remote telemetry should a treatment system fail to operate. When the technicians
are on site all systems are checked to make sure they are operational in addition to checking the
gauges in the compounds. The Macon/Dockery Site Group requests that weekly site visits for O &
M be amended to monthly visits which will be attached to the monthly progress report for your
review. The Group feels that the necessity of filling out O & M forms once a week is not needed
at this time and that a fonnal check of the systems should be completed on a monthly basis.
Respectfully Submitted,
Kenny Gulledge
Project Coordinator
cc: Macon/Dockery Site Group Members
Paul Furtick, RMT, Inc.
Ms. Norma Eichlin, CDM Federal Programs
David Lown, NC Super Fund Section
6525 The Cowers Parkway, Suite '100 •Norcross.Georgia 30092 • Tel: [phone] • Fax: [phone]
STATE PROG. SECTION ID:404-347-5094 • JUL 17'96 • 11 :03 No.006 P.01
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
1-U COURTLAND Snt.EET. N.E.
A TI.ANt A. GCOI\GIA 30365
July 17, 1996
4WD-N$RB
Mr. Kenny Gulledge
Project Coordinator
Crown, Cork, and Seal Co.
100 Evans Row
Cheraw, SC 29520
SUBJ, Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Gulledge:
This letter is written in respon!Sle to your June 26, 1996
letter in which you requested a reduction in laboratory sampling•,
and your June 27, 1996 letter in which you requested a change to
the O & M Schedule.
The first request to discontinue sampling for isophorone,
mercury, and cyanide in the influent and effluent systems is
approved. The request to discontinue sampling for isophorone and
cyanide in the monitoring wells is also approved. However, as your
letter states, four wells will still be analyzed Car mercury.
Please be mindful that at the end of the remediation, all wells
will be gampled for all· contaminant,;t of concern and all must be
below the performance standards before remediation can be
considered complete.
The second request to reduce the influent sampling from
monthly to quarterly l.9 approved, however, the effluent will still
be sampled monthly.
The third request to eliminate the air stack sampling ot the
various groundwater treatment systemB iB denied. Though rural, the
Site is still located in a residential neighborhood, and as such,
human health is a concern. Therefore, sampling of all air stacks
should occur on a quarterly basis. The SVE: inlet can be
eliminated, but the exhaust and the property line samples should be
collected on a quar.t.erly w:.is. Sampling of the SVB wells can be
reduced to twice a year.
STATE PROG. SECTION ID:404-347-5094 • JUL 17'96 • 11:04 No.006 P.02
The request to reduce the o & M site visits from weekly to
monthly is denied and seems a bit premature. The June O & M report
states that the groundwater systems were only operational between
st and 33i. In addition, no mention is made in the report about
the success or failure of adding the Clorox to the infiltration
galleries. Therefore, until the "bugs" are worked out, it would
seem prudent that the o & M visits continue on a weekly basis.
If you have any questions, or would 1 H;e to discuss this
matter further, please give me a call at 404/347-779i, ext 20G5.
cc: David Lown, NC DEHNR
Norma Eichlin, CDM
Ronald Wallace, AES
c~i lle S. Bennett
Remedial Project Manager
07/16/1996 16:33 4044097893 AES -ATLANTA • •
FAX TRANSMISSION
APPLIED EARTH SCIENCES, INC.
65Z:5 THE CORNERS PARKwAY SUITE 400
NoRCRO:,:=i, Gr::o ... GIA .'.30092
(770)•448-4Q I I
FAX: (770)-409•7893
Date: July 16, 1996
PAGE 01
To:
l'ax#;
Mr David Lown
919-733-4811 Pages: 12, including this cover sheet.
From: Rona.Id J. Wallace
Subject: Macon/Dockery
COMMENTS: North Carolina permit for groundwater remediation facility.
07/16/1996 16:33 4044097893
VI' ,1.0• ~Q .LV; Jll,I -g-. OJ7 iJ5Z
'State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water auaffty
James B. Hunt, Jr., <3ovemor
Jonathan B. Howes, Secretary
A. Pres1on Howard, Jr .. P.E., Director
Mr-. Thomas W. Daggett,
~ecutivc: COIJlll.li.ttec Chllhman,
Macon/ Docbry Site Group
CARE OF:
Wildroai., lwwld, Allen &; Di.lion 22SW. WaclcerDrive
Suitc3000
· Chicago, D... 60606-1229
Dl-Ju-Mr. Daggett'
AES -ATLANTA
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July 2, 1996
Subjea: Permit No. WQOOll 944 Macon/ I)c(;uty Site Group
Co.cdova, North CalUllna Sli" Groundwater Remediation Fodlitiea
Richmond Counry
In acco!dlWce with your appllcadonr=ivcd January 16, 1996, we are forwarding herewith Pemlit No. WQOOl I 944 dated July 2, 1996, to the Macon / Dockery Sit& Oiv11p for tho construction and ope,ation of the subject groundwater remediation facility.
lbispcrmlt shaU be effective tiom t!JQ date of isSIIIUlte unl:i.1 May 31, 2001, and shall be subject to tbe eonditions lllld limitations ao spe~ therein. Pl~c: pay partlculllr attention to the mon ltorlng ~quircments in this permit Failure to establish :!In adequate system for collecting and maintaining the required opetallonal information will leSlllt in future compliance problems.
If BIIY parts, reqlliR>1110nts. or limitations eontam,;:d in this permit~ unacceptllble, you have the riipn lo i:equest an adjudicatory hearing upon written request within thirty {30) da)'S following l'Cl."10tpt of this penuit This requ~iil musl be in the form of a written petition conforming to Chapter I.SOB of the Nonh Carolina Gell.era.I Statutes, and filed with the Office of Admillistmtive Hearings, P.O. Drawer 27447, Raleigh, NC 27611•7447. Unless such demands are made this pellllit shall be finid 1111d binding.
P.O. Box 2"35. ~lgh, NQrtt, (:aroma 27&!8-0"35
All EQu&I OOPOffiJ~lly Alllnnativ,. Aet\M Etnol"for
rolc,phono (g19) 7M-5083 FAX (919) r=19
5()1%. rooyoled/ 10%, post-ecnaum(!I'" l)a?Or
07/16/1996 16:33 4044097893 V ,J7 4352
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~0031012
One set of approved plillls and specifications is being forwarded ro you. If you have any qu.;stions concemlng the Groundwater Conditions or groundwater monitoring requirements. please conu,c1 Mt. David Goodri~h in the Groundwater Section at 9!9/715-6162 If you ncc:d any additioaal lnfo11nation concerning this matter, pleue cont.Bct Mr. John Seymour at [phone] e,itension 546.
cc:
Sincerely,
~~~
Plch.Jnood County ~th Dcpattn1ent RMT. lllc .. Mr. David S. Shaw Fayetteville Regional ~ Wm Qgali!y Section Fayetteville Region.al Office, GroundW11tcr Section Bob Oieek, Oroll!ldwetu Sccti.on, ~uer.\l Office Trainini and Ccrtitication Unit Fwlies Al>6CISsmcnt Unit
07/16/1996 16:33 4044097893
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ilJ004/012
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENV[R.ONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
GROUNDWATER REMEDIATION PERMIT
In accrndmi<:e with~ provisions of ~le 21 of Chapter 143, General Statutes of Nonb Carolina as amen~ and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY O1:lANTBD TO
Macon / Dockery Site Group
Richmond County
fORTHfi
constructlort and operation of a 337,000 GPD groundwater remedilllion facility consist:iog of three separate groundwater recovery, treatm=ot and infiltration gallery systmru:
1.) 1hc Upper Doc:kccy Sites with six (6) recovery wells, wi ~on feed tiwk, a 51wluw tray air diffusion air stripping system, dual km e.xehaflga eol UfflQll for metal£ removal, BIJd a 624 square foot infillI8tion gallery;
2.) the Lower Dooke:y Site with four (4) rccoYc:ry wells, a ~i.rculation water feed Ulllk, a shallow llay air diffuaion air striJ)plng system. dual ion exchange columns for metal. =oval, and a 6,000 S(!uaRI foot illfiln-ation pllery;
' 3.) the Upper And ~r Macon S*s with r;eovcu (7) recovery well$ for the Upper Macon Site and four (4) recovery wells for the Lower Macon site, a ~011 wate.l' feet tank foe e11eh site, a shallow txay air diffusion air stripping system shaRd by both s~. followed by dual ion cxchan,e col1llllllS for metals removal, and a 6, 7SO total square foot intiltntion gallczy;
a soil vapor extraction system (SVE) in the lagoon area with air corapteSSOl' and atmosphmic vents; 411d all associated piping. valvllS, controls, ltl8tets, transre-pumps, and.appwwnanoes to serve the groundwater remediation systems of the Macon / Doclcexy Remediation Site with no diicharge of wastes to the ~'Urfacc watcro., pursuant to the applicar.i<,n rccc.ived lanUBI)' 16, 1996, and ln confonnity Wilh tll8 proje~t plan, specifications, 811d other supporting data s11l>S11qu1111.tly filed Wld approved by the Dcptutmcnt of Environment, Health and Natural Resources and C()nsidered a part of this pennit.
· This pmnlt shall be effective from the dale of lssuBllce until may 31, 2001, Blld shall be sul~cct to the following 1~ conditions and limillltions:
I, CERFOR.\fANCE STAN))ARDS
I. Upon eompletion of constroction and prior to operation of this permitted facility, a ceniliClltion must be rcmved from a professional englnur certifyine that the peimitted facility has been h1stalled in accordance with this perm.it, the approved plans and spociJi.Clllions, Wld other supporting materials. Mail lhc Ce:nilication to tlic War.,r Quality Pcrmiu and Hnginwing Unit. P.O. Box 29S35, Raleigh, NC 27626-0535.
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07/lU/96 lQ:38 V. 537 4382
2.
3.
4.
5.
6.
7.
The Fayeneville Regional Office, telephone number 911Y 486-1541 s.hall be notified at least fony.elght (48) holll'S in advance of operation of lhe Installed facilities so that aii in-plaee i~peetion ean be made. Such llot.ification to the iegional supcrviwr shall be made dwing the normal office honl'5 from 8:00 a.m. until S:00 p.tn. OI! Monday through 1-'riday, excluding Stlltc Holidays.
Thia permit shall become voidable if tho s11ili fail to adequatoly assimilate the was\ <:S and mar he rescinded uruess the faeilitieG am il'l&lalled, maintwned, Md opcn,ted in a nl8Jlncr which will protect the assigned w11tu quality standards of the surface waters and ground waters.
In the event that the facillt.iC3 fail to perform !llltisfactorily, includuig the crea1ion 11f B~r;e conditiom, the Pcrmi111,e shall llllc:e inunediate coxrecti\/8 aetion, including th01C ~ons that may be requiied by this Division, such as the construction of addilillnal or ri,placemcm lleatJllCllt or CliSpoSal fac.l.U.ties. ·
The isswmcc of this pcncit shall not relieve the Perrnitt=ofthe resporuibility for cbmag"" ID surface or gro1111dwatem resulting from the opetlllion of this Cacility.
Aay mi~ ~crated from lhc~e treatmcmt l'a.cilities must be disposed in accordance with Cleneral Statute l43-21S.1 and in a manner approved by the North Carolina Di..-ision of Water Quality.
Di-.emon or byp=ing of the W1treated groundwater from the treatment facilities is prohibited.
II. QfRRATYoN AND MAINTENANCE REQUIREMENTS
1 The faciHtit11 shall be properly roamtained and opemed at all times.
z. Upon Classific:atlon of lhe facility by the Certification Commission, the Pernutte<! shall employ a oerti.ftt.d wastDwamr treatmont plant operator 10 be 1.11 respo11$ible cbarge (ORC) Of the wastewater trea!mellt facilities. Tho opemor mllllt hold a C<>rtificate of~ Q'J>C: lll1(f &™le llt least ~Valent lo or greater than the classification assi~ to the wastcwatu lfflltlOOlt fac:ilities by the Certification Commission. The Pcrmittee must also employ a ccrtific:d back-up operator of the appropriate rype Md grade to comply with the conditiOIJS of Tide l SA, Cbapttt 8A, .0202. Tho ORC of tho facilil)' must visit -=li Class I facility at least wee.k.ly and each Class II, Ill, and IV facility at leaat daily, excluding weekends and holidays, and musl properly Illilllljl'C and documc:llt daily o~o and IIlamffllUUlce of the fa,;ility and must C11111ply with all other condition, of Title J°5A, Cllap!er 8A, .0'202. Once the tilCilicy ~ cluoified, the Permittce must submit a lc:ttct' to the ~mtication C11nuni .. i911 which designates the o~rator in responsible charge within thirty da)'ll after the wwuwlkler ttealnlmlt filcilities me 50% ~omplete. .
3. The facllltles shall bo cffoetivcly maintained lllld operated a.s a non-discharge system to J)l'eVCllt the discharge of any wastewater n:,sulting from the operation of this facility.
nr. MONITORING AND REPORTING REQIDRRMENTS
I . Any monltoring deemed neoeuary by the Divilri011 of Water Quality to ins~ $..d'ace and grolllld water protection will be established and an acceptable sampling rePOrtini schedule shall be followe<l
2. NoncomplianCQ Nolificatio11:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone numbor 910/ 466-1541 as soon as possible, but in no case mor= than 24 holl!S or on the 11w working day following the oocuucncc 11r first knowledge of the occumnce of any of the following:
2
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a. Any occumnce at the wastewater treatment facility which n:sulrs in !he treatment of significant amounts of wastes which an: abnormal in quantity or chuacteristic. such as -the dumping of the: cont~nts of a basin or tank, the known passage of a slug of hazardous substance through the facility, or any other unusual circiunsllll!ce&;
b. Any process unit failure, due to known or llllknown reasons, that n:ndm the facility incapable: of adequale: waRewater treaunmi, sueh as mechanical or electrical failures of pumps. aeraton:, compreasors, etc.;
c. AIJy failure of a pumping station, ~wet line, or ~t facililY resullillB in a by-pass diiecdy tQ receMog warers WiUlout tmmnent of all or any portion of the influent to s..ch station or facility; or
d. AIJy time tlw self-lll()Ditoring illfonna!lon indicates that the facility is not ili compliance wtrh Us pennil limitatioos.
Persons ~ort!nt such occurrence$ by telephone shall also file n written rcoport in letter fonu within five (S) days following first knowledge of tru: occurrence. This report must outline tile actions taken or proposed to be taken to r.nsu.re that the problem does not recur.
IV. GROJJNDWADB BEQJ11REM£NTS
I.
2.
3.
The groundwater treatment system shall i;;onsistently achieve Cass GA Oroondwater Stuidards in the treated effl~t. as outlined under Title 15A, SUbchapt,,r 2L. s~ctioo .020'2(g), prior to discharge to the infiltration galleries. The tn:ated wale. discbarJ~d into the iDfil1nitio11 galleries must not violate the class OA Orollll!lwater Qulllity Stllndard~ for any constituent beyond· the Compliance Boundary, nor cause the migration of contmuinalion into ua.dfected =as. If the treatment system fails to consistently adlieve th&se ~-additional t.eatment unit5 or chungc:s in opmitional methods may be: xeqwed.
Prior w begiwJ.inii wllBtc disposal operat!OIJ8, three monitor wells.one at the lJ ppcr Doci;ery Site. one at the Lower Dockery Site, Qnd one at the Lower Mw;oa Site, sh~ be installed to monitor xroW1dwater quality. The well(s) shall-be eon,tructcd such that the Wa!llt Jovel in the well is 118VBr above or below the scteened (open) portion of the well at any limo dudn\: year. The gene.al location and name for eai;h well Is maned on Attachment A. monitoring well ,ha.II be loaw:d at the a.view bolllldary, COllstnicted In aa:ordarice with this_ ~nnil. and uppmved by the Fayeittvllle ResJonal ot&e.
'J1iqe tlu\le DBW monltor wells MW-I, MW-2, and MW-3 shdl be sampl&d hutially after CO!l9ft'l1etian (;\lid pri01' to waste disposal opewions) and themafter eveiy Februacy, J1111e, aJJd October for the following parameters:
~~I Chlorido
Benzene
Xylenes
Cadmium
Water~!
Cyalli&
Toluene
Barium
The analy•es for hy,:kocarbon compounds .u-e to be performed by EPA M..ihods 602 and 610. .
Th,, measurerrumt of watci-levels must be made prior to 8t\lnpling for tlJQ remaining parameters. The depth to wa11,r in e:>eh well thall be measured from the: surveyed point on the top of the cuing_
The _mea.sunng poial3 (u,p of well c115ing) of all mo11ltortng w~lls shall be sw:ve)•ed to provide !he relative elovation of the measuring point for ""-Ch monitorini w~ll-
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4.
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6.
7.
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The results of the samplin& and analysis shall be 5eni to the Groundwater Section, Permits and Complinncc Unit, P.O. Box 29578 Ralc:igh, N.C. 27626-0578 on Form CJW-59 [CoJ:t1>liance Monitoring Report Form] eveiy March, July, and November
The influent and effluent from the ueatment system shall be Wllplcd 011cc every l\1/'0 (2) weeks for the first three (3) months and monthly thereafter for the panmeters sp~ed below,
BenzeM Toluene Xylenes Barium cadmium
The analyses for hyclrocaxbon compounds are to be penormed by EPA Methods 602 and 610.
The i:esulte of the oompling and analysis shall be sent to th; Grollndwater Section, Pennits Md Compliance Unit. P.O. Bo:,; 2!l578 Raleigh, N.C. 27626-0578 within 30 days of sampfo collection.
All wc:lls that ~ wnstru=d for purposca of groundwllter monitorillg shall be constructed in e,;:corclanoe with 15A NCAC 2C .0108 (Standards of Cons!(\lction for Wells Olh~r than Water Supply) and any other state and local laws and regulations pertaining to well construction.
The Pa~ell.ep,nal Office, telephone, number 910/,486-1541 $hall bo notifi;d at least forty-eight ( 48) holltli prior to the construction of any molliroring well so that an .insl"'Clion can "be made of the monitoring well location. Such notification to the regioual groundwa= supc:rvisor shall~ made dnrtng the nonnal ottlce holll'S from 8:00 a.m. UDlil 5:00 11.m. on Monday through Friday. excluding ~ holidays.
Within lhirty (30) days of all well constcuction activities, a certification must be received frl>m a profeulonal eugiueer certifying that !he monitorlns wells are Joc11tcd and ct1ftll!ructed in accordance with tho Well Conawction Srandan;b (lSA NCAC 29 and this ~-This certifiealion should be submitted with. copies of the Well Completio11 Form (OW•l) for each well. Mail thiq certification and the associaled GW•l forms to the I'emlits aad Compli11nce Unit, Grounawamr Section, P.O. Bo,i: 29578, Ral=igh, NC, 27626-0578.
for the initial sampling of the well as s~ed elsewhei., in the pennit, the pMllitteo shaU submit a copy of the OW-I Form (Well Completion Form) with the Co~lianoe Mimltormg f'Ollll (GW-~ll) for that well. COmplillllOI: Monltoring Forms that do not 111dude copies of the GW-1 fonn will be zetllmed to the pennitteo without being .rrocessed. Fai.lUR: to submit tlwse fonns as reqllired by !hi$ pe,:mit may result in the Initiation of enf~~e111Dnt activities pursuaut to NC General Statutes 143,215.6.
Within sixty (60) days of completion of all mcmlrorlilg wells, !hf: pomlittee Sball subn lit two origina! co pills of a Acaled topographic map (ncm no g,:emer tbim I '', I 00? •ign<:d ant,l sealed by a professional e11gineer or a stare licensed land swvcyor that indiC3tes all of tho following information:
a. the location and identity of -,h monitonna well, b. the location of the waste disposal sys!Ml, c. !he location of an property boundllrics, d. tho latitu~ and lonftutk of the established horizontal control mo11Wfle11t. e. the relative elevation of the top of the well cuing (which shill be .known as the "measuring point"), and
f. Che depth of water below the mcuuring point at the time the measuring P<>int is Ulablished.
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PAGE 08
iaioos..-ou
~ s\llVey shiul be conducted using apJ)l'Oved practices outlined in North Carolina G~11eml Statuws Chllpkr 89C and the Nonh Ciuolina Adminis11111.1ve Code Title 21, Chapier ~-Tiie surveyor i,hall establish a hQtbontal contn>l monummt QD the property of the waste disposal system aml determine the lalitude and lonaitude of thu horizontal conrml 1110111,mcnt to a horizontal l)06itional accuracy of+/. 10 feet, All other features listed in a through e, above shall be surveyed relallve to thl8 horiZQDlal control monument. The positionrd accuraoy of features listed in a. lhmugh c. abo..., shall have a .-atio of precision not to exceed an error of closure of I foot pet 10.000 feet of perimeter of the survey. Any features located by the radial method will be located from a minimum of two points. Horizontal control monument shall be installed In sueh a manner 1111d !Dllde of su~h materials that the monument will not be destroyed due to activities that llllly take place on the property. The map lhall abo be •=yed oai!lg the North Allleri.can Datuin of l !18l coordmate system and llball iudicate the datum 011 the map, All bearings oz azimuth~ shall be basea on either the true or NAD 83 grid meridian. If a Global Positioning System (OPS) b ueccl to detetmine the lati!Ude and longitudcofthchori.wullll conuol monu11reui, a GPS receiver that has the capability to perl'<lrm diffetentllli OPS shall be used GIid nU data coll~ed by the GPS zca:iver will be dilf=Dtiallr coaected,
The map~ md any supporting documenta1io11 shall be li8Dt to Ille Groll!ldwatcr Section. N.C. Division of Water Qmility P.O. Box 2!>573 Rllieigh. N.C. :27626-0578,
1 o. All eomponems of the groundwater 1'6COvery, treatment. and disposal system shall be p.ropcrly wcatba-proofed to prevent~ and falbw of the system,
11. The groundwater recovery, treatment and qisposa! system shall be inspected weekly. If it is detennincd that the system is malfunctioning, all reprirs sbould be made as s,)()D as puiSiblc lll!d iq,om:d to the f'ayeaeville Re&lonal Offire Within 4S hours.
12. lsoeoncentral!Oll (Hoes C01111eeting poiDts of equal conCClltnltion) maps in both the \l<lffleal and horizontal directions shall be developed using the gro1111dwatcr monitorinJ d: ibl for Febnnuy, June, 1111d October. A walel' level cootour map must al80 be devclopea on a Tri• Aw,,ual buis. 'These ma~ lhall be submi!18<1 along wit& all otiu,i-monitoring data forthat period.
13. The permittee shall retain copies of rccoi:ds of all nionitoling lnfonnation, including all calibration and lllaintenance records, all original strip chart recordings for Conti uuous. monilorilla instrumenurtion and copies of all l'l!(JOrt!l iequired by this permit, for a pe,iod of at least 3 yean· from the date of the sample, meuUR:lDCllt, report or application. Rt.'COrds of this monitcting lnromlation shall include. but not be limited to, the following:
a. the date. exact place, and tlm8 of sampling or measnrertJents, b. the individi.lal who performed Ibo sampling or meiasuremsnts, c. the date tl!c, analyses Wm; performed,
d. !he analytical 1DchnlquC11 or~ used, and · e. the results of any such sampling, ineasut'811lenl$, and analyses.
14. The permittee shall n,port any mouitoring or other infom111tion which indicateS that any e0ntanwu111t may oau$C au endaugcrment to an underground source of drinking water and any noncompliance with a pennit condition of malfunction of the injection system "'hi~h may cause ffuld migration outside the injection ione or area. The infoml3tion ihall be providecl to the Fayetteville Regional Office ol'lllly within 8 bOUIS of tho occum:nce a, 1d 1111 a written •ubmission within five da)lli of the occurren<:e. The written submission shall co11tain a description of the noneonipliance and its caui:e, the period of noncornpl i1111ce. including exact dates and times, and if the 0011oompliance has not been correcttd. the anticipatl!d time it is expected to ~ontinue, and any steps taken or piano~ to n:duce, eliminate and prevent teoC<l=nce of the noncompliance:.
s
07/16/1996 16:33
1.11•J.1;t,·ijt;, lV:41.
4044097893 'g. 537
AES -ATLANTA
CROWN CHERAW #2.
PAGE 09
1lioo9.•012
v.
IS.
16.
Arly additional groundwatefquality monitoring. as deemed necessary by tl1e Divisioi,, shall be provided.
The COMPLrANCE BOUNDARY for the disposal system is specified by re$111at,on• in I SA NCAC 2L. Groundwater Classifications and Standards. The Compliance Boundary is for the disposal system constructed afb:r December 31, 1983 is esr.ablished at either ( I) 250 feet from tho waste disposal area, Qr (2) SO feet within the pmpcl'I)' boundary, wllich<:vcr is closest to the waste disposal area. An exceedanee of Groundwater Quality Standards at or beyond the Complianr.e Boundary is subject to immediate remediation action in addirion to the penally provisions applicable under Geuerul Slatute 143-215.6A(a)(I)_
In accordance with ISA NCAC 2L. a lU\VIE)&'. BOUNDARY is established around the disposal systems midway between the Compliance Boundary &11d the -perimeter of the waste disponJ area. AtJy cxceedallce of standams at the Review Boundary shall niquiri: remedlalion ac:tio11 on Ibo part of tile permittoc.
INSPECTIONS
I.
2.
3.
A<k:Qullk i.n.spc:won, llllliD!lmilll<;e and clearuog shall be provided by the Plmnittee to in~ proper openition of tho &ubj10et facilities. .
The Permittee or his designee ~hall inspect the groundwater recovery and trei,tment fllcilicics to piovcnt malfunctions and det8rloration, ope.ntor ellOrs and dischurg~ which may cause or lead to the release of wastes to tho onvironmont, "threat to human hool1 h. or a n~. The Pemuttee shall m!!.intain an inspection log or summary including at least the date and time of inspection, obsi:rvations made, and any llJlliDti:nance, repllirll. or con-ective actiollli taken by the Permlttee. This log of in~ shall be maintained by the Permittee for a period or thMe yelllll from the dnte of tho inspection end shall be made available to the Division of Water Quality or other pennitting amhnrity, upon reqnest.
Any duly auth~ officer, employee, or repiescnta1i.ve of the Division of Water Quality may, upon preaonWion of credentials, enter and inspccl iWY property, premises or place 011 or related to the disPOSal site or facility at any reasonable time for the pu,po$& of determining compliance with this pmnit, may inspect or copy any reeords that must be maintained unda the r:enns ana conditions of th.is pennit, and may obtain samples of groundwater. surface water, or leachate.
VI. GENERAL CONDITIONS
I.
2.
3.
4.
5.
Issuanoe of this permit docs not constitute approval for reimbwsement from tlJe L<· aking Petroleum UndergroUll.d Storage Tank Cleanup Fuod; (lSA NCAC 2P).
This pennil shall become voidable unless the facilities are constructed in aecordanci: with the cood.ilions of this pc:mut. the, approved plans arid specifications, and other supporting data.
This pennit is effective only with respect to the ruiture and volume of wastes described in the application and otbc:r supporting data. ·
This ~t Is not lr!UISfei:able. In the event there. is a dMite for the faeilitie, to < hangc ownenhip, <lr there 1s a name change of the Pemuttee, a foanal pennit request m,1st be iubmittc:d ~o the Division ~f Wate.r Quality accompanied by an applicatio11 foe, documentation from the parties involved, and other suppo11ins materials as mav be appropriate. The approval of this request will be considered on its merits and may c-r 'may nor be approved.
A set of apProvedf.la.n• and specification$ for th& subj°"t proj~ct must be retamed 1,y the Pennittee for the li o ofthis project.
6
07/16/1996 16:33 4044097893
,,.,,.a.v•<>u .a.v, .. a. AES -ATLANTA
CROWN CHERAW •2· PAGE 10
Ill 0101012
6. Failure ro abide by the conditions and limitations contained in this permit may subje.ct the Permittec to an enforcement action by the Division of Ware.r Quality in accordanc~ with North Carolina G~nernl Statute 143-215.6(a) to 143-215.6(c).
7. Th~ annual administe.dllg ancl compliance fee must be paid by the Penninee within thirty 00) days after lx:ini: billed by lb,:, Division. Failure to pay the fee accordingly may cause the Division to initiate actio, to ..-evoke this pen-nit as specified by lSA NCAC 2H .0205 (c)(4).
8, The issllilllce oftbis pemlil does not preclude the Pennittee from complying with any and all statutes, rules, rcgulationa, or ordllUU!oos which may b<: impolil'd by other govcmmenr •~cies (local state, and federal) which ha.ve jurisdictio1t.
9. TIie Pennlnee, Ill least six (6) wonths prior to the ~iration of this pennit, shall reqi,est its extension. Upon receipt of th~ requ~t, the Commbslon will revtew the ade<juacy of the facilities described therein. llltd if warrartted, will ~d the pemlit for sucli period of time and 1111dcr such conditions aud limitations IIS it may deem appropriate.
10. Upon Resi,onal Office appI()val \lie, Permittce may mno~ ~ ion exchange colwnn~ from the treatment systems, without pem,it modilkt1tio<1, when it is dc:tonnincd they ,,re; no lonaer needed. The Permittce IIl\lst n:ccive Resional Office written approval by adequately llcnionstrating, to the Divisioo's Fayetteville Regional Office's Groundwater ond Water Quality Se<:tion.s, tho Ion exchange columns an: no loqger necessary.
Pennit i~ued this the 2nd day of July, 1996
NORTII CAROLINA ENVIRONMENTAL MANAOEMBNT COMMISSION
r., P.E., Director
nral Manasci,nent ll y Authority of the Bn~tal MBDagemcnt Commbslon
PermU Number WQ0011944
7
07/16/1996 16:33 4044097893 ___ v,,~Q/VO JV:4a "Cl'. 537 4J82
Pfrniit No. WQOOl 1944 Suly 2, 1996
ENGINEER'S CEB1'1FICATIQN
AES -ATLl'NTA
CROllN CllllRAI! •:•
PAGE 11
ilJ0ll/012
• l, ,--------,--.--, u a duly rel!isterod Plofessional Engineer in rhe State cf North
Carolina, ha.villa beco BU!horlzed to obsel'Ve (periooically, wt:eJdy, full~) the CODStruction O(tht projQct. ______________
-----=---.----~forthc Project Name
Location Pennittee hen.,by siato that, to tlic !>,;st of my abilities, due care ll!ld diligence was used in the observation
of the oonsltuetion such that the c011ttractio11 w~ observed to bo built wilbiu substantial C(lmplian.:e and
irltent of th.is permit, the approved plans and specifications. and othe.t supporting waterials. SigD~ture _________________
Registlation No. ____ _ Date ______ _
8
---
07/16/1996 16:33 4044097893 -. ""'
AES -ATL/l}\TA. CROWN CHERAW •2
PAGE 12
ll}0l2/0l2
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lIQURB 1 MACON/DOClCERY RBM!m:IATJ:ON lU::CRMOND COUltT? WQ00ll?tf/G!lfg6O16
lll:l'E Dl'l'AIL HAP
.. 05/17/1996 14:49
May 17, 1996
Ms. Oiezelle Bennett
Remedial Project Manager
US EPA, Region IV
345 Counland S~
Atlanta, Georgia 30365
AES -ATLANTA
Re: Macon/Dockery Site -Cordova, North Carolina
Request to Treat Upper Dockery Gallery with Bleach
Deor Ms. Bennett;
PAGE 02 •
The Upper Dockery has had two recovery wells shut off the last few months due to the galleries not talcing additional water. Several factors could cause the low infiltration rates including lower
penneability, biological fouling, or precipitation of iron or magnesium oxides formed in the air stripper. The Macon Dockery Site Group (MDSO) recommends that the smaller of the two galleries
be treated with a commercial bleach such as Cloroll by pouring approximately 8 gallons directly into
the distribution pipe inlets on the gallery side of the weir. This will help eliminate biological fouling
or precipitation of iron and manganese. If this is successful, the other gallery will also be treated.
If the infiltration rate does not increase, it will be recommended to drill three soil boreholes
approximately 20 feet deep and infiltration testing each. At this dme the MDSG asks permission
from the US EPA to treat the gallery with a commercial bleach.
We appreciate your consideration in this matter.
Respectfully Submitted,
Kenny Gulledge
Project Coordinator
cc: Macon/Dockery Site Group Members
Paul Furtick, RMT. Inc.
Ms. Norma Eichlin, CDM Federal Programs
David Lown, NC Super Fund Section
4§515 Tb,e. Cornere ParkwQy, Sulte 400 • Norcro::;::;, Ceor9h1 3009Z • T~I: (770) •48-"i:91 l • Fax: {770) 409•7693
B5/17/1996 14:49 AE.S -ATLANTA •
FAX TRANSMISSION
To:
Fax II:
Mr David Lown
919-733-4811
From: Ronald J. Wallace
Subject: Macon/Dockery
Al'f'LIED EARTH SCJENCES, INC,
esas Tl-iE CoRNCl'IG PARKWAY SUITE 400
NORCA0$S, GEORGIA. 30092.
<770>•448·49 I I
FAX.: <770l·40S·7eaa
Date: May 17, 1996
Pages: 2, including this cover sheet.
COMMENTS: Request to Treat Upper Dockery Gallery with Bleach
PAGE Bl
April 9, 1996
Memorandum
TO:
FROM:
RE:
File (iJ'V
David J. Lown ~
Applied Earth Sciences Project Manager
Charlie Macon Lagoon (Macon/Dockery) Site
Cordova, Richmond County
•
Today I was telephoned by Ron Wallace of Applied Earth Sciences. Effective
immediately, Mr. Wallace is replacing Dan Amer as the construction manager for this site.
Mr. Amer left AES to join Westinghouse in Miami, Florida. Mr. Wallace asked what
information he should submit to this office. I told him that we would like to be copied on
anything that goes to EPA. He said that he would do that.
cc: Grover Nicholson
01/18/1994 08:32 4044097893 AES -ATLANTA -. •
FAX TRANSMISSION
To:
Fax#:
Mr David Lown
919-733-4811
From: Daniel M_ Arner
Subject: Start up
COMMENTS: FYI
APPLIED EARTH SCIENCES, INC.
6525 Tl-IE CORNERS PARKWAY SUITE 400
NoROROC:.!:, 0EOROIA 30002
<770)-446-49 I I
FAX: 1770>-409-7693
Date: February 8, 1996
Pages: 3, including this cover sheet.
PAGE 01
01/18/1994 08:32 4044097893 AES -ATLANTA PAGE 02 • •
MEMO
Jo: ·Giezelle Bennen, USEPA,-Norma Eichlin COM-Federal Programs Corp., Tom
Effinger SCE&G, -Keooy Gulledge Crown Cork and Seal, Dave Jones Ingersoll
Rand, -Clifford Lee Dupont Chemical, Paul Fwtick RMT, Fred Banker RMI, -Joh11
Canzeri Handex, Rich Ogle AES, David Lown NC Superfund
•·rom: Daniel M. Amer j). rn . C---
Subjeet: Macon Dockery System Start Up Schedule
Date: February 8, I 996
On January 26, 1996 the final inspection was held for the Macon Dockery site. With the
exception of contractor punch list the final inspection was completed. An attendance list is attached.
At the meeting a start up date of February 5, 1996 was scheduled. Due to weather constraints
the start up date has been rescheduled for February 12, 1996.
Sampling of monitor wells outlined in the RMT report Performance Standards Verification
Plan will be conducted during the week of February 12, 1996.
If you have any questions please feel free to contact me at 770-448-4911 this week, or 910-
895-2340 onsite the week of February 12, I 996.
6525 The Corners Parkway, Suite 400 • Norcross, Georgia 30092 • Tel: [phone] • Fax: (770) 409,7893
01/18/1994 08: 32 4044097893, AES -ATLANTA PAGE 03 • •
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January 18, 1996
Ms. Giczcllc Bennett
Remedial Project Manager
US EPA, Region IV
345 Courtland Street
Atlanta, Georgia 30365
• \tD
Vl il1c . . (_j
(), . ~
~i\lcES~
Re: Macon/Docke11· Site -Cordova, North Carolina
l'rcfinal Inspection Report
Dear Ms. Bennett:
• 'R4
RECEIVED
JI\N 2 6 1996
SUPERFUND SECTION
On behalf of the Macon/Dockery Site Group ("Group"), the Pre final Inspection Report is herewith
submitted in accordance with the SOW (Task Ill c) and per the RA Workplan. This report describes
activities associated with the prefinal inspection.
The following items are included and/or attached in the Final Inspection Report
• Outstanding or discrepant RA construction items and incomplete equipment testing and
demonstration deficiencies. This is delineated on the attached punchlist.
• Actions required for the resolution of outstanding or discrepant RA construction items and
incomplete equipment testing and demonstration deficiencies. This is delineated on the
attached punchlist. A review of punchlist corrections will be conducted by the RA
construction manager and the QA oversight, RMT, on January 24,25, 1996.
• Scheduled completion dates for each of the items identified above. This is included on the
attached punchlist.
• The anticipated date for the Final Construction Inspection. The anticipated and scheduled
date is January 26, 1996 at 09:30am.
Respcctl"ully Submitted,
Daniel M. Arner
Construction Manager
6525 TIH: Curner.s l'mkwny, Suite 400 • Norcross, Geor9io :~0092 • Tel: [phone] • Fux: [phone]
NO.
M-E1
M-E2
M-E3
M-E4
M-E5
M-E6
M-E7
M-ES
M-E9
M-E10
M-E11
M-E12
M-E13
MACON/DOCKERY SITE
PREFINAL SITE TNSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Ground fence and gate.
Provide case gTOUnding for all equipment.
Install gTound well.
Complete electrical wiring.
Provide "typed" circuit directory's.
Provide ID labels for electric and control
enclosure.
Complete control panel and instrument wiring
and calibrate instruments.
Instrument tags to be installed. Check number
to match numbering on drawings.
Install heat tracing system as per drawings.
Air stripper heater and heater controller to be
installed.
Install missing screws on 480 volt panel face.
Relocate tubing on bag filter so filter bag may
be changed without removing tubing.
Flexible metal conduit shall not exceed 6' in
length.
SITE CODES:
G -General Item for all sites
LO -Lower Dockery Site
REFERENCE
SITE DOCUMENT
M Spec. 16170
M Spec. 16170
M Spec. 16170
M
M Spec. 16470
M Spec. 16195
M
M
M
M
M
M
M NEC 430-123
M • Macon Site
UD -Upper Dockery Site
l:\WP\700\7001nJa.DOC/CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DA TE
1 /15/96
1/15/96
1 /15/96
1/15/96
1/15/96
1/15/96
1/5/96
1/15/96
1/13/96
1/7/96
1/6/96
1/7/96
1/15/96
MS -Macon Source Area
SVE -SVE System
f Paue 1 o 17
CM(AES)
SIGN•OFF
INITIAIJDATE
~
NO.
M-E14
M-E15
M-E16
M-Ml
M-M2
M-M3
M-M4
M-M5
M-M6
M-M7
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Provide motor test and motor test data sheet
Provide ground test reports
Area lighting to be installed on pole
BF-1001 and BF-1002 now are parallel pair of
filters with a 2" inlet each. Effect on hydraulics
is unknown.
There have been no sample taps provided on
either side of the bag filters.
Touch up paint required on all tanks, bag
filters, pumps and ladders.
Finish installation of pipe supports, including
bolt down to slab as well as bolt around pipe.
Pumps are also not anchored. Provide touch up
of painting.
Inlet piping to AS 1001 was designed to be steel
but is PVC.
Install anchor bolts on all pumps and
equipment.
On effluent line after MR units missing 3" ball
valve to be located after the sample tee.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
M Spec. 16011.1
M Spec. 16170
M
M
M
M
M
M
M
M
M -Macon Site
UD -Upper Dockery Site
!;\ WP\700\7001727 a.DOC/CD F96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INmAL/DATE
1110196
1115196
1115196
( )
NIA
1 l15l96
1115196
NIA
1115196
1 l15l96
MS -Macon Source Area
SVE -SVE System
aee 0 P 2 f17
CM(AES)
SIGN-OFF
INmAUDATE
:·c.c.,,.
. 1-/ ::::/'--·{_,.__._~
NO.
M-M8
M-M9
M-M10
M-M11
M-M12
M-M13
M-M14·
M-M15
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Piping at BF-10032 not as designed. This results
in moving the location of FE 1308. Equipment
substituted.
Height of discharge out of P-1001 & P-1003 is
8' -10". Concern about stability of 2" PVC
discharge pipe.
Total height of stack for AS 2001 is 5' -8" from
top of trays to outlet. The sample collection
point is located 3" from the outlet. Contractor
reports that the sample collection pipe that is
inside the stack has not been installed. One SS
strap is missing on connection boot.
All steel to PVC flanges are not per general
connection detail-gaskets.
PVC piping on 1-inch sample tap is missing on
Tl001 and T1002.
Piping and connection locations and sizes to
the MR units not as shown.
Air heater to stripper not installed.
Install air relief valves on above ground piping
as discussed with D. Amer-AES and D. Shaw-
RMT.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
M
M
M
M
M
M
M
M
M -Maron Site
UD -Upper Dockery Site
I:\ 'NP\700\7001727 a.DOC/ CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAIJDA TE
( )
( )
12/22/95
1/7/96
12/21/95
( )
1/10/96
1/15/96
MS -Macon Source Area
SVE -5VE System
f Page3 o 17
CM(AES)
SIGN-OFF
INITIAIJDA TE
cZ.._.
y
~-~
(..-;.-,,~r'
I
NO.
M-M16
M-M17
M-C1
M-C2
M-C3
M-C4
M-C5
M-C6
M-C7
M-C8
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM REFERENCE
DESCRIPTION SITE DOCUMENT
Insulate all above ground piping following heat M
tracing installation.
Well UM-7 jet pump assembly blew out during
testing, rework required.
Finish gravel road
Install variable weir in infiltration gallery
manhole as faxed to Dan Amer on
1-September 26, 1995.
Concrete pad must be resurfaced, previous
treatment did not bond coJTectly. Anchor bolts
that are not used on slab need to be cut flush.
Meters for the following wells did not read "O"
with no flow. LM-4 and UM-6.
Provide standard lock for splitter manholes to
infiltration galleries.
Drains on covers to all valve vaults should
discharge free and on the down hill side of
vaults.
LM-3 vault has water in it. Regrade and
remove soil from on top of vault.
Remove tape covering name plates on wells.
SITE CODES:
G -General Item for all sites
LD -Lower Dockery Site
M
M
M
M '
M
M
M
M
M
M -Macon Site
UD -Upper Dockery Site
I:\ ½'P\700\7001 727.a..OCX: /CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DATE
1/15/96
12/21/95
12/31/95
N/A
1/12/96
12/21/95
12/21/95
12/21/95
1/10/96
12/20/95
MS -Macon Source Area
SVE -SVE System
age 0 P 4 f 17
CM(AES)
SIGN-OFF
INITIAL/DATE
J 'l. .... ----/
(., :::.,--., _ _, ,
NO.
M-C9
M-C10
M-C11
M-C12
M-C13
M-Cl4
M-C15
MS-Cl
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Check for steel removal tee to be provided for
the removal of each jet pump. Tee ties into
pitless adapter. Also provide protective plugs
for wells.
Establish grass and vegetative cover.
Grade out and revegetate excess soil excavated
during the installation of the new infiltration
gallery at the south end of the site.
Provide ID label for MW 23.
Well LMWP05 was hit and knocked over
during the installation of MW 23, straighten
and replace concrete pad.
Well casing on LM-5 is so high that the steel
protective cover will not close with the plug in
place.
Hold down lugs (3) need to be installed and
supported on all tanks.
Finish gravel road.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
M
M
M
M
M
M
M
MS
M -Macon Site
UO -Upper Dockery Site
I:\ WP\700\7CXJl n7 a.OOC/ CD F96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAUDATE
( )
( )
1/15/96
1 /15/96
12/21/95
12/20/95
( )
12/31/95
MS -Macon Source Area
SVE -SVE System
f Page 5 o 17
CM(AES)
SIGN-OFF
INITIAUDA TE
-~"r-. (.,;;" .. -: ,
NO.
MS-C2
MS-C3
MS-C4
MS-CS
MS-C6
MS-C7
MS-E1
MS-M1
MS-M2
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Drains on covers to all valve vaults should
discharge free and on the down hill side of
vaults. In general grading around the vaults
and wells I too steep and will lead to erosion
and ponding of storm water.
Remove tape covering name plates on wells.
UMS-4 vault has water in it.
Check for steel removal fee to be provided for
the removal of each submersible pump. Tee ties
into pitless adapter. Also provide protective
plugs for wells.
Establish grass and vegetative cover.
Grade and revegetate excess soil excavated
during the installation of the new infiltration
trench at the south end of the site.
Complete electrical and instrumentation
installation
BF-4001 different than specified. Piping
modified.
There have been no sample taps provided on
either side of the bag filter.
SITE CODES:
G -General Item for all sites
LO -Lower Dockery Site
REFERENCE
SITE DOCUMENT
MS
MS
MS
MS
MS
MS
MS
MS
MS
M -Macon Site
UD -Upper Dockery Site
!:\ WP\700\70017J.7a.DOC/COF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DA TE
1/15/96
12/20/955
1 /15/96
( )
( )
1/15/96
1 /10/96
( )
( )
MS -Macon Source Area
SVE -SVE System
p f age 6 o 17
CM(AES)
SIGN-OFF
INITIAL/DA TE
•
•
NO.
MS-M3
MS-M4
MS-MS
MS-M6
MS-M7
UD-C1
UD-C2
UD-C3
UD-C4
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Finish installation of pipe supports, including
bolt down to slab as well as bolt around pipe.
Provide touch up of painting.
Inlet to AS 4001 has been piped to discharge
into the top tray only. The second inlet that
discharges directly to the next lower tray has
been plugged.
Stack not installed on AS 4001. Heater not
installed.
All steel to PVC flanges are not per general
connection detail.
Complete mechanical and piping installations.
Install variable weir in infiltration gallery
manhole as faxed to Dan Arner on
September 26, 1995.
Concrete pad must be resurfaced, previous
treatment did not bond correctly.
Meters for the following wells did not read "0"
with no flow. UD-3, 4, 6, 7, and 8.
Provide standard lock for air release manhole.
SITE CODES,
G -General Item for all sites
LO -Lower Dockery Site
REFERENCE
SITE DOCUMENT
MS
MS
MS
MS
MS
UD
UD
UD
UD
M -Macon Site
UD -Upper Dockery Site
I:\ WP\700\7001 727 a.IXX/ CDF"96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAUDA TE
12/22/95
( )
1/15/96
1 /15/96
1/10/96
( )
1 /15/96
1/10/96
12/20/95
MS -Macon Source Area
SVE -SVE System
a2e 0 P 7 f 17
CM(AES)
SIGN-OFF
INITIAL/DATE
•
c.c~ I
NO.
UD-C5
UD-C6
UD-C7
UD-CS
UD-C9
UD-Cl0
UD-Cll
UD-C12
UD-El
UD-E2
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
UD-5 vault has 5 inches of water in it and
cannot read meter.
Drains on covers to all valve vaults should
discharge free and on the down hill side of
vaults. In general grading around the vaults
and wells is too steep and will lead to erosion
and ponding of storm water.
Rip rap is partially covering the inlet and outlet
·of the 12" concrete culvert under access road.
Remove tape covering name plates on wells.
Check for steel removal tee to be provided for
the removal of each jet pump. Tee ties into
pitless adapter. Also provide protective plugs
for wells.
Repair erosion on back side of treatment plant.
Establish grass and vegetative cover.
Install at least three hold-down lugs on the CS
tank and anchor.
Ground fence and gate
Provide case grounding for all equipment
SITE CODES,
G -Gen~ral Item for all sites
LO -Lower Dockery Site
REFERENCE
SITE DOCUMENT
UD
UD
UD
UD
UD
UD
UD
UD
UD Spec. 16170
UD Spec. 16170
M -Macon Site
UD -Upper Dockery Site
I:\ WP\700\7001727 a. DOC/CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAUDA TE
12/20/95
12/20/95
12/20/95
12/20/95
( )
12/20/95
( )
( )
1/16/96
1/15/96
MS -Macon Source Area
SVE -SVE System
f Pa~e 8 o 17
CMIAES)
SIGN-OFF
INITIAUDA TE
-
NO.
UD-E3
UD-E4
UD-E5
UD-E6
UD-E7
UD-ES
UD-E9
UD-El0
UD-E11
UD-E12
UD-E13
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Install ground well
Complete electrical wiring
Provided "typed" circuit directory
Provide ID labels for electrical and control
enclosure
Complete control panel and instrument wiring
and calibrate instruments.
Instrument tags to be installed. Check number
to match numbering on drawings.
Install heat tracing system as per drawings.
Air stripper heater and heater controller to be
installed
Install missing screws on 480 volt panel face
Relocate tubing on bag filter so filter bag may
be changed without removing tubing.
Flexible metal conduit shall not exceed 6' in
length. Replace flex from flow transmitter to
flow element and ]-box with rigid steel conduit.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
UD Spec. 16170
UD
UD Spec. 16470
UD Spec. 16195
UD
UD
UD
UD
UD
UD
UD NEC. 430-123
M -Macon Site
UD -Upper Dockery Site
1:\ \VP\700\7001 'TZJ a.DOC/CD F96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DATE
1/15/96
1 /15/96
1 /15/96
1/15/96
1 /15/96
1/15/96
1 /15/96
1/10/96
1 /10/96
1/10/96
( )
MS -Macon Source Area
SVE -SVE System
a2e 0 P 9 f 17
CM(AES)
SIGN-OFF
INITIAL/DATE
,i.--
. '"
.,
\ .....
,_
·.-
-~
.,...
\ .....
, __
c., -,} /
I
•
NO.
UD-E14
UD-E15
UD-E16
UD-E17
UD-E18
UD-E19
UD-M1
UD-M2
UD-M3
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
PUNCHLIST ITEM
DESCRIPTION
Relocate J-box in front of
transformer /panelboard to insure 36" work
clearances.
Label remote well panels to match drawings
Provide motor test and motor tea_t data sheet.
Provide ground test reports
Area lighting to be installed on pole
In panel SP-1, remove the 40 amp breaker at
Circuit No. 10 and replace with 50 amp
breaker. Replace the 30 amp disconnect switch
with a 60 amp disconnect switch. Fuses shall
be rated for 50 amps. Check motor overloads.
There have been no sample taps provided on
either side of the bag filter.
Inlet location on As-3001 is different than
shown on plans. Only inlet to upper tray has
been piped, the inlet to the lower tray has been
plugged.
Finish installation of pipe supports, including
bolt down to slab as well as bolt around pipe.
Provide touch up of all painting.
SITE CODES,
G • General Item for all sites
LO-Lower Dockery Site
January 3, 1996
REFERENCE
SITE DOCUMENT
UD
UD
UD Spec. 16011.1
UD Spec. 16170
UD
UD
UD
UD
UD
M -Macon Site
VD -Upper Dockery Site
l:\ WP\700 \7001 727 a.DOC/ CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DATE
( )
1/10/96
1/15/96
1 /15/96
1 /15/96
( )
( )
( )
12/20/95
MS -Macon Source Area
SVE -SVE System
f Paue 10 o 17
CM(AES)
SIGN-OFF
INITIAL/DATE
.v
_ _.... • •
.
'"
~
I C.
NO.
UD-M4
UD-M5
UD-M6
UD-M7
UD-MS
UD-M9
UD-M10
UD-M11
UD-M12
SVE-E1
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Tighten all bolts on flow meter FE3308
Suction line to P-3002 also has two elbows right
at the inlet to the pump. _This will make the
inlet flow very turbulent.
Touch up paint required on all tanks, bag
filters, pumps and ladders.
Provide and install sample taps on each side of
BF-3002.
On effluent line after MR units missing 3" ball
valve to be located after the sample tee on all
sites.
All steel to PVC flanges are not per general
connection detail.
Taps for differential pressure switches have not
been provided on the metals removal units.
.Install a minimum of three lugs on tank and
anchor bolts.
Insulate above ground piping.
Ground fence and gate
SITE CODES,
G -General Item for all sites
LD-Lower Dockery Site
REFERENCE
SITE DOCUMENT
UD
UD
UD
UD
UD
UD
UD
UD
UD
SVE NEC 250-155
M -Macon Site
UD -Upper Dockery Site
!:\ WP\700\7001727 a.DOC/ CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITJAIJDATE
12/21/95
( )
1 /15/96
( )
1/15/96
1/15/96
12/20/95
1/15/96
l /15/96
1/15/96
MS -Macon Source Area
SVE -svt System
f Paoe 11 o 17
CM(AES)
SIGN-OFF
INITIAL/DA TE
'l-
"'
'-........
\ VJ • '
·"
"'
NO.
SVE-E2
SVE-E3
SVE-E4
SVE-E5
SVE-E6
SVE-E7
SVE-E8
SVE-E9
LO-Cl
LD-C2
LD-0
LD-C4
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Provide case grounding for all equipment
Provide "typed" circuit directory
Provide ID labels for electrical and control
enclosure
Flexible metal conduit shall not exceed 6' in
length.
Provide motor test and motor test data sheet.
Provide ground test reports.
Area lighting to be installed on pole.
Install auto dialer for SVE system.
Patch grout on top of manhole to infiltration
gallery.
Concrete pad must be resurfaced, previous
treatment did not bond correctly.
Clean up (regrade) around MW 16 to remove
excess dirt.
Dispose of staged contaminated soil piles.
Maintain covers on piles.
SITE CODES,
G -General Item for all sites
LO -Lower Dockery Site
REFERENCE
SITE DOCUMENT
SVE NEC 250-155
NEC250-45c
SVE Spec. 16470
SVE Spec. 16195
SVE NEC 430-123
SVE Spec. 16011.1
SVE
SVE
SVE
LO
LO
LO
LO
M -Macon Site
UD -Upper Dockery Site
I:\ WP\700\7001 727 a.DOC/ CD F96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INffiAL/DA TE
1 /15/96
1/15/96
1 /15/96
1/15/96
1/15/96
1/15/96
1/15/96
( )
1 /16/96
1/10/96
1/10/96
1/16/96
MS -Macon Source Area
SVE -SVE System
f Page 12 o 17
CM(AES)
SIGN-OFF
INITIAL/DA TE
'-~ t
::.:--
=-cl
I:)
' ,-1
"'
,1
Ir_
h C ~
~➔··'t--c.:
c.
C
·-,_
'-/
NO.
LO-CS
LO-C6
LO-C7
LO-CS
LO-C9
LO-C10
LO-C11
LO-E1
LO-E2
LO-E3
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Air release vault at LO-5 is too low to drain
covers properly.
There is severe erosion around the concrete
base at LO-3.
Protective steel covers on wells are painted
shut. Must be accessible. Check for protective
covers to be in place.
Check for steel removal tee to be provided for
the removal of each jet pump. Tee ties into
pitless adapter.
In vault to LO-2 the steel pipe supports are
loose and do not support the pipe on the high
pressure line.
Establish grass and vegetative cover.
Install tank lugs (minimum of 3) and anchor
bolts.
Ground fence and gate.
Provide case grounding for all equipment.
Provide "typed" circuit directory.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
LO
LO
LO
LO
LD
LD
LD
LO Spec. 16170
LD Spec. 16170
LO Spec. 16470
M -Macon Site
UD -Upper Dockery Site
I:\ wP\700\700t727a.DOC/CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DA TE
1 /10/96
1/5/96
12/20/95
( )
12/20/95
( )
( )
1/15/96
1 /15/96
1/15/96
MS -Macon Source Area
SVE -SVE System
f Pa•e 13 o 17
CM(AES)
SIGN-OFF
INITIAL/DA TE
I \· , ·c-t-...,.',.
I
'f
1,.--I-•
\ ,__
\ L.--
-r
;
}--
'
,v-
,'-
;,-
NO.
LD-E4
LD-E5
LD-E6
LD-E7
LD-E8
LD-E9
LD-E10
LD-E11
LD-E12
LD-E13
LD-E14
LD-M1
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Provide ID labels for electrical and control
enclosure.
Complete control panel and instrument wiring
and calibrate instruments.
Instrument tags to be installed. Check number
to match numbering on drawings.
Install heat tracing system as per drawing.
Air stripper heater and heater controller to be
installed.
Install missing screws on 480 volt panel face.
Relocate tubing on bag filter so filter bag may
be changed without removing tubing.
Flexible metal conduit shall not exceed 6' in
length.
Provide motor test and motor test data sheet.
Provide ground test reports.
Area lighting to be installed on pole.
BF-2001 is now a parallel pair of filters with a
2" inlet each. Effect on hydraulics is unknown.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
LD Spec. 16195
LD
LD
LD
LD
LD
LD
LD NEC 430-123
LD Spec. 16011.1
LD Spec. 16170
LD
LD
M -Macon Site
UD -Upper Dockery Site
I:\ WP\700\7001727 a.[X)C /CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN•Off
DATE INITIAIJDATE
1 /15/96
1/15/96
1/15/96
1/15/96
1/15/96
1/10/96
1 /15/96
1 /15/96
1 /15/96
1/15/96
1/15/96
( )
MS -Macon Source Area
SVE-SVE System
Pa2e 14 of 17
CM(AES)
SIGN-OFF
INITIAIJDA TE
,,-
\l/
\ 1.,--
\ I,--
,L--
\v
' ' f\ C::r·-f
. ,-
,-. c-.::: .. :'
I
.
!\.'
NO.
LO-M2
LO-M3
LO-M4
LO-MS
LO-M6
LO-M7
LO-MS
LO-M9
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
There have been no sample taps provided on
either side of the bag filters.
Suction line to P-2001 is 4" not 6". Multiple
elbows will make inlet to pump have severe
turbulence.
Suction line to P-2002 also has two elbows right
at the inlet to the pump. This will make the
inlet flow very turbulent.
Finish installation of pipe supports, including
bolt down to slab as well as bolt around pipe.
Provide touch up of painting.
Inlet to AS 2001 has been piped to discharge
into the top tray only. The second inlet that
discharges directly to the next lower tray has
been plugged. Heater not installed.
Bolt missing on the butterfly valve on the P-
2001 discharge line.
Install anchor bolts on P-2001 (motor end of
base).
Touch up paint required on all tanks, bag
filters, pumps and ladders.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
LO
LO
LO
LO
LO
LO
LO
LO
M -Macon Site
UD -Upper Dockery Site
I:\ WP\ 700\7001 i27 a.DOC/ CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DA TE
( )
( )
( )
12/22/95
( )
12/20/95
12/20/95
1/15/96
MS -Macon Source Area
SVE -SVE System
Paee 15 of 17
CM(AES)
SIGN-OFF
INITIAL/DA TE
iJ I
V
V
fv,-----
V •
\/
~
I-
NO.
G-3
G-4
G-5
G-6
G-7
G-8
G-9
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Complete equipment operational testing and
demonstration at all sites.
Submit all Operations and Maintenance
Data/Manuals/Testing Reports for all
equipment/instrumentation.
Contractor training of O&M personnel on each
equipment/instrument item.
Install standard locks for all gates, vaults,
manholes, and wells.
Anchor bolts not installed on all but one air
stripper.
All above ground pipe flanges need to be
tightened and gasket installations competed as
designed.
Several anchor bolts at all sites are cocked at
unacceptable angles.
SITE CODES,
G -General Item for all sites
LO -Lower Dockery Site
REFERENCE
SITE DOCUMENT
G
G Spec. 01730
G Spec. 01730
G
G
G
G
M -Macon Site
UD -Upper Dockery Site
I:\ WP\700\7001727 a.OOC/CDF96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAIJDATE
1/17/96
1 /17 /96
3/1/96
12/20/95
12/20/95
12/22/95
12/22/95
MS -Macon Source Area
SVE -SVE System
Paoe 17 of 17
CM(AES)
SIGN-OFF
INITIAIJDA TE
,r.
t /1 (
(,Cr-.
I
NO.
LD-MlO
LD-Mll
LD-M12
LD-M13
LD-M14
LD-M15
LD-M16
G-1
G-2
MACON/DOCKERY SITE
PREFINAL SITE INSPECTION
CONSTRUCTION PUNCHLIST
January 3, 1996
PUNCHLIST ITEM
DESCRIPTION
Centerline of discharge at P-2002 is at 3' -8"
instead of 3' -6".
On effluent line after MR units missing 3" ball
valve to be located after the sample tee.
PVC piping on 1" sample tap is missing on
T3001.
Tee at change to gTavity flow is a 4X4X4 with a
bushing now 4X4X3.
Total height of stack for AS2001 is 5'8" from
top of trays to outlet. The sample collection
point is located 3" from the outlet. Contractor
reports that the sample collection pipe that is
inside the stack has not been installed.
All steel to PVC flanges are not per general
connection detail.
Support bolts missing from AS2001.
Restore and revegetate all disturbed areas.
Submit as-built "Red-Line" drawings for final
grades; include all field modifications to
original design.
SITE CODES,
G -General Item for all sites
LD -Lower Dockery Site
REFERENCE
SITE DOCUMENT
LD
LD
LD
LD
LD
LD
LD
G
G
M -Macon Site
UD -Upper Dockery Site
I:\ WP\700\7001721 a.DOC/ CO F96
SCHEDULED CONTRACTOR
COMPLETION SIGN-OFF
DATE INITIAL/DATE
NIA
( )
12120195
NIA
12120195
12l3ll95
12120195
1 l15l96
2110196
MS -Macon Source Area
SVE-sVE System
Pa2e 16 of 17
CM(AES)
SIGN-OFF
INITIAL/DA TE
,,-
I I ----• ,I/
' 1,,,---'"
l-L----
,_ v
' 1,,---• Ii! (
; ii
To:
Fax#:
From:
Subject:
• •
FAX TRANSMISSION
APPLIED EARTII SCIENCES, INC.
6525 THE CORNERS PARKWAY SUITE 400
NORCROSS, GEORGIA 30092
<770>-448-49 I I
Ms Giezelle Bennett
404-347-1695
Daniel M. Arner
Macon Dockery Site
FAX: [phone]
Date:
Pages:
January 18, 1996
19, including this cover sheet.
COMtvlENTS: Prelinal Inspection Report
•
October 27, 1995
• REC~PVED
NOV 14 1995
SUPERFUND SECTION
VIA AIRBORNE
Ms. Giezelle S. Bennett
Remedial Project Manager
United States Environmental Protection Agency
345 Courtland Street NE
Atlanta, Georgia 30365
Subject: Modification of the Infiltration Gallery Design
for the Upper Macon Source Area
Macon/Dockery Site -Cordova, North Carolina
Dear Ms. Bennett:
As we have discussed, infiltration rates measured by the Macon/Dockery Site Group's contractor, Handex,
were much lower than anticipated for the Upper Macon Source Area. Consequently, AMT has modified
the infiltration gallery design for this area of the site to take advantage of more permeable soils beneath
the silts and clays found from ground surface to approximately 15 to 25 feet below grade. This letter
summarizes the reasons for the design modification and the details of the modified design.
RMT's remedial design for the Upper Macon Source Area ground water extraction/treatment system
included disposal of treated water through horizontal infiltration galleries. The galleries were sized to
provide sufficient infiltration capacity at an anticipated rate of 0. 7 inches/hour, based on previous
infiltrometer test results (November 1993) in this area. Handex conducted infiltrometer tests last month
as required to confirm infiltration rates prior to gallery construction. The infiltrometer test results obtained
by Handex showed that the expected infiltration rate at the gallery locations was only 0.2 inches/hour,
which is unsuitable for the type of infiltration gallery planned for this site.
AMT evaluated alternative disposal options for treated ground water and conducted additional field studies
to support alternatives analysis. The alternatives were limited to those that would allow disposal of treated
ground water upgradient of the Upper Macon Source Area extraction wells, since the US EPA had
approved of _the deletion of treatment for dissolved manganese if the disposal method met this condition.
AMT conducted standard tests for seepage pits using an improved falling head test procedure (Kaplan,
Benjamin 0., Septic Systems Handbook, Lewis Publishers, 1978, p. 253). Four test borings were installed
to approximately 30 feet below grade in the vicinity of the planned infiltration galleries, and data was
collected on seepage rates. Attached to this letter are boring logs for the four test borings, a sketch of
the boring locations, and seepage test results. Test borings encountered saprolite beneath the silts and
clays of the overlying Middendorf formation at depths ranging from 15 to 25 feet below grade. The tests
showed that seepage rates in the saprolite were sufficient to dispose of treated ground water from the
Upper Macon Source Area extraction/treatment system.
INC.
RMT, INC. -NASHVILLE, TN
53 (ENJURY BOULEVARD -Sum 150 • 37214-3693
615/883-5767 , 615/883-5793 FAX
. -(ZJ
p\70\017\70017 .27benncttltr/lld95
•
Ms. Giezelle S. Bennett
US Environmental Protection Agency
October 27, 1995
Page Two
•
Using this data, RMT has assumed a design basis of 2.9 gallons per day per square foot of trench wall
and designed a vertical infiltration trench for disposal of the treated ground water. The trench is to be
approximately 28 feet deep, 1 00 feet long, and approximately 3 to 4 feet wide. The trench is to be
backfilled with 3/8-inch washed gravel up to approximately 4 feet below grade. An inlet pipe from the
treatment system is to be installed in the north end of the trench at a depth of approximately 6 feet below
grade (2 feet below the top of the gravel) and extended approximately 5 feet horizontally into the gravel.
The pipe is to be fitted with a 90° elbow facing downward to keep gravel out of the inlet pipe. The gravel
is to be overlain with Mirafi 600X stabilization fabric extending 1 foot upwards along the sides and ends
of the trench. The trench is to be backfilled and compacted in accordance with the methods, procedures,
and requirements specified for trench backfill and compaction in Section 02220 of the project
specifications.
Please contact me at [phone] if you have any questions concerning the modifications to the
infiltration gallery design for the Upper Macon Source Area ground water extraction/treatment system.
Thank you for your continued assistance on this project.
Sincerely,
RMT, Inc.
) , /' . ,;). / . (
.-/-'t-vv .... l le .. dt..<--'!--rt-cl<--
Paul A. Furtick
Project Manager
PAF:cw
Attachments
cc: MDSG Technical Committee Members
Dan Arner -AES, Inc.
Cl
p\70\017\70017 .27bennettltr/lld95
• DEelGN SHEET
_______________________ SHEET _______ OF ___ _
100 Verdae Boulevard P.O. BoK 16778 Greenville, SC 29606 Phone: [phone] FAX: [phone]
PROJECT/PROPOSAL NAME PREPARED CHECKED PROJECT/PROPOSAL NO.
By: Date: By: :b 5 1oi1 q5
Date: 70017.27
Stabilization Fabric (Mirafi 600X)
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PROJECT/PROPOSAL NAME
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Greenville SC 29606
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Citizens, .
ANNOUNCEMENT FROM EPA
· Atlanta, Georgia
July7, 1995 •
.. ----.... , ..
. This is to notify you that the Environmental Protection Agency has begun the Remedial Action phase of the
.. Supertund program at the Macon/Dockery Supertund Site. The cOntractor, Handex, began this week clearing
an area of the property to set up the.ir Site operations office and other operation areas. They wiil be installing
. extraction wells and constructing two groundwater treatment facilities. It is anticipated that the work required
for construction activities will be complete in approximately four months.
You can .review the April .1995 "Remedial Action Fact Sheet" page 6 for more information about the design
of the groundwater recovery system, or review the Rem~ial Design documents located in the repository
located in the Leath Memorial Public Library, 412 East Fr:!AKlin Street, Rockingham, N.C.
If you have any questioras\.please feel free to contact either Giezelle Bennett or me at 1-800-435-9233.
Thank you.
Diane Barrett
N.C. Community Relations Specialist
• Macon/Dockery Site
Richmond County, North Carolina
June 15, 1995
RECEIVED
JUL 03 1995
SUPEHHJND SEC1\0N
Ms. Giezelle S. Bennett
Remedial Project Manager
US EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
•
Reply to: MDSG Technical Committee
c/o Kenny B. Gulledge
Crown Cork & Seal Company, Inc.
P.O. Box 887
Cheraw, S.C. 29520
Phone: [phone]
Fax: [phone]
Re: Final Design Submittal -Upper Macon Source Area Groundwater Extraction and
Treatment System
Dear Ms. Bennett:
Transmitted herewith are four (4) copies each of replacement pages and drawings providing the
design information for the Upper Macon Source Area Groundwater Extraction and Treatment
System. As previously discussed, the Upper Macon Source Area extraction/treatment system
design information is being incorporated into the Final Remedial Design documents submitted and
approved in February 1995. Attached is a document indicating revisions made to the text due to
US EPA's May 18, 1995, comments on the 90% design submittal for the Upper Macon Source
Area Groundwater Extraction and Treatment System.
If you have any questions concerning these deliverables, please contact me at [phone] or
Paul Furtick at [phone]. Thank you for your continued assistance on this project.
Sincerely,
?~2-.~
Kenny B. Gulledge
Project Coordinator
cc: Macon Dockery Technical Committee
Paul Furtick, RMT, Inc.
• •
Note: As requested, the Macon/Dockery Site Group is providing a description showing how
and where changes were made to the Final Design text to incorporate US EPA's
comments. Each original comment (in standard type) is followed by the MDSG's
response (in italicized type), followed by a note explaining how the comment was
incorporated (in bold type).
MDSG RESPONSES TO US EPA COMMENTS ON THE
PREFINAL DESIGN FOR THE UPPER MACON SOURCE AREA
GROUND WATER EXTRACTION AND TREATMENT SYSTEM
June 5, 1995
GENERAL COMMENTS
COMMENT 1: The Final Design documents/drawings are to be stamped and signed by a PE
registered in the State of North Carolina.
RESPONSE: Each appropriate document and drawing will be stamped and signed by a PE
registered in the State of Nonh Carolina.
The enclosed submlttals have been stamped and signed as needed.
COMMENT 2: This submittal only included revisions to the RD. Appropriate changes to the RA
Workplan, the Pertormance Standards Verification Plan, and the O&M Plan should also
be submitted.
RESPONSE: Each of these documents are being revised to include the founh ground water
extraction and treatment system. Replacement pages for each document will be
provided with the Final Design submittal for the Upper Macon Source Area extraction
and treatment system on June 16, 1995.
The referenced documents have been revised to Include the Upper Macon Source
Area extraction and treatment system. The attached table llsts the revisions made
to each document and the reason for the revision.
COMMENT 3: The additional wells added to the other systems (Upper and Lower Dockery and Lower
Macon) have not been included. For example, neither the revised Dwg. 7001721-C01
nor any of the other drawings reflect the additional wells that are to be added to the
other source area systems. These revisions should be made. In addition, the
drawings are in conflict with Drawing 7001721-C10 submitted e_arlier.
RESPONSE: The Macon/Dockery Site Group previously requested and received US EPA approval on
March 10, 1995, to show the locations of the four wells without providing design
details. The design text and contract documents instruct the contractor to add the
designated wells to the existing design in the locations shown on Drawing 7001721-
C1 o and require the contractor to use the equipment, materials, and construction
details already specified for the associated wells. For example, the contractor will use
1 G:\OAT A\PAUL \WP\MACONDOC\BENNTT22.L TR/94
• •
the design information provided for the four extraction wells on the Lower Macon
extraction system to construct the Lower Macon source area well. As previously
agreed, the four wells will not be added to the design in any location other than on
Drawing 7001721-C10.
Drawing 7001721-C/0 will be revised to make the representation of the Upper Macon
Source Area extraction and treatment system consistent with the current design.
No addltlonal changes were made to the text to address this comment. Drawing
C-10 has been revised to reflect the final design of the UMS treatment system.
SPECIFIC COMMENTS
COMMENT 1: Page 3-4, Para 1 -What is the rationale for not providing a specific design of the
additional wells? What guidance will be provided?
RESPONSE: As discussed in the previous response, the MDSG and US EPA agreed that there is
sufficient design information available for the contractor without providing a specific
design for each of the four additional source area wells. The guidance provided for
the contractor is the design drawings and specifications provided for the extraction
wells on each of the associated systems.
No additional changes were made to the text to address this comment.
COMMENT 2: Page 3-12, Para 1 -The submersible pumps will actually pump the groundwater to a
prefilter prior to the air stripper and not directly to the air stripper as stated here.
Please correct the text. Also, verify that the filter will be capable of handling sharp
variations in flows/pressure without prior equalization in an upstream tank.
RESPONSE: The prefilters specified for the extraction and treatment systems will only be necessary
during stanup, based on well development data from the Remedial Investigation and
from the aquifer pump test conducted in 1992. The purpose of the prefilter is to
remove suspended solids during the first few hours of system stanup. When the
system is fully operational, the submersible pump wells will pump directly to the air
stripper.
The bag filter vendor has verified that the filters do not require prior equalization in an
upstream tank to handle sharp variations in flows and pressures as long as the stated
design parameters are not exceeded.
No additional changes were made to the text to address this comment.
2 C3 :\DAT A\PAUl\WP\MACONOOC\BENNTT22.L TR/94
• •
SPECIFICATIONS
COMMENT 1: The instrumentation data sheets are not directly referenced wtthin the body of any
specijications or included in the Specmcation List (Page 3-31 and Appendix S).
Include in the Table of Contents similar to the Liquid Bag Filters and reference directly
in Section 1601 0, Article 1.2E or a separate section.
RESPONSE: The instrumentation data sheets will be referenced on Page 3-32 and Appendix Sand
referenced directly in Section 16010 in the final document to be submitted on June 16,
1995.
The Instrument data sheets are now referenced on Pages 3-32 and 3-33 and In the
Table of Contents In Appendix S. Section 1601 o has been revised to direct the
reader to the Instrument Index for the Instrument specifications.
3 G:\DATA\PAUL\WP\MACONDOC\BENNTT22.LTA/94
• •
REVISIONS TO THE FINAL DESIGN AND SUPPORTING DOCUMENTS
June 15, 1995
INSTRUCTIONS PURPOSE
Final Remedial Design Report -Volume 1 -
Text
/ Replace Preface with revised Preface Note to readers that the design has been
revised to include the Upper Macon Source
Area (UMS) extraction/treatment system
v Replace TOC p. ii with revised TOC p. ii Section 3 page numbers changed
/ Replace Section 3 (pp. 3-1 through 3-Incorporate references and design descriptions
· 30) entirely with revised Section 3 (pp. for UMS system as shown in the 90% design
3-1 through 3-34) submittal (4-14-95).
Add Upper Macon Source Area Provides estimated construction costs for UMS
Submersible Pump System cost table to system
end of Section 5
Final Remedial Design Report -Volume 2 -
Drawings
c,/Replace Drawing 7001721-X01 (Rev.0) Revised Drawing List
with Drawing 7001721-X01 (Rev.1)
/ (/Add Drawing 7001726-K04 (Rev.0) after P&ID for UMS system
7001721-K03 (Rev.0)
vReplace Drawing 7001721-C01 (Rev.0)
· with Drawing 7001721-C01 (Rev.1)
Adds UMS system to GA
/
[,/Replace Drawing 7001721-C03 (Rev.0) Adds UMS system to Macon grading plan
with Drawing 7001721-C03 (Rev.1)
o/ Replace Drawing 7001721-C0S (Rev.0) Adds UMS system to Macon underground
with Drawing 7001721-C0S (Rev.1) piping plan
V Replace Drawing 7001721-C06 (Rev.0) Adds note to Detail C for Drawing 70017211-
with Drawing 7001721-C06 (Rev.1) COS for UMS system needs
VReplace Drawing 7001721-C0B (Rev.0) Adds notes to submersible pump details for the
with Drawing 7001721-C0B (Rev.1) UMS system
vReplace Drawing 7001721-C10 (Rev.0) Revised layout of UMS system to agree with
with Drawing 7001721-C10 (Rev.1) Final Design
Vr~dd Drawing 7001726-C11 (Rev.0) after Provides UMS treatment system pad design
Drawing 7001721-C10 (Rev.1) and details
I . Provides UMS treatment system equipment )' ~dd Drawing 7001726-M02 (Rev.0) after
/1.?rawing 7001721-M01 (Rev.0) general arrangement
G :\DATA\PAUL \WP\7001726A. APL/94 1
• •
REVISIONS TO THE FINAL DESIGN AND SUPPORTING DOCUMENTS (CONTINUED)
June 15, 1995
--/Md Drawing 7001726-P04 (Rev.a) after Provides UMS treatment system above ground 1-Drawing 7001721-P03 (Rev.0) piping plan
( Add Drawings 7001726-E31 through Provides UMS treatment system electrical and
7001726-E37 (all Rev.a) after Drawing instrumentation design and details
7001721-E27 (Rev.a)
Final Remedial Design Report • Volume 3 • No revisions
Appendices A through E
Final Remedial Design Report • Volume 4 •
Appendices F through Q
Add UMS Design Calculations (4 Provides design calculations for UMS system
l_./pages) to end of Appendix L head loss and design pressures
Replace Appendix O -Process Controls Adds process description for UMS system
vNarrative (pp. 01 through 012) with elements
revised Appendix O -Process Controls
Narrative (pp. 01 through 013)
Final Remedial Design Report • Volume 5 •
Appendices R through S
./Add May 18, 1995, US EPA comments Updates correspondence record for design
and June 5, 1995 MDSG responses to comments/responses
the end of Appendix R
Replace Appendix S Table of Contents Adds references for new instrument
V(pp. i through v) with revised Table of specifications
Contents (pp. i through v)
VReplace Section No. 11512 (2 pages) Adds specttications for UMS system
with revised Section No. 11512 (2 submersible pumps
pages) (Appendix S)
✓~eplace Section No. 13235 (7 pages) Adds specttications for UMS system air stripper
with revised Section No. 13235 (1 o
pages) (Appendix S)
Insert data sheet for Liquid Bag Filter Adds specttications for UMS system bag filter
BF-4001 after data sheet for Liquid Bag
Filters BF-3001 and BF-3002 (Appendix
S)
ti Replace Section No. 1601 o (5 pages) Adds specttications for UMS system electrical
with revised Section No. 1601 o (5 requirements
pages) (Appendix S)
G:\DATA\PAUL\WP\700172BA.RPl./94 2
• •
REVISIONS TO THE FINAL DESIGN AND SUPPORTING DOCUMENTS (CONTINUED)
June 15, 1995
Insert TraceCalc Linelist -Upper Macon Adds electrical circuit load estimates for UMS
Source Area Site 4-Apr-94 after system heat tracing
TraceCalc Linelist -Upper Dockery Site
20-Dec-94 (Appendix S)
Insert data sheet for Pressure Gage Pl-Adds data sheet for UMS system instrument
4101 after data sheet for Pressure Gage
Pl-3101. (Appendix S)
Insert data sheets for Rotameters Fl-Adds data sheet for UMS system instrument
4101 and Fl-4105 after data sheet for
Rotameter Fl-3105 (Appendix S)
Insert data sheet for Differential Adds data sheet for UMS system instrument
Pressure Switch dPISH-4202 after data
sheet for Differential Pressure Switch
dPISH-3503 (Appendix S)
Insert data sheet for Flow Indicating Adds data sheet for UMS system instrument
Totalizer FOl-4308 after data sheet for
Flow Indicating Totalizer FOl-3308
(Appendix S)
Insert data sheet for Magnetic Adds data sheet for UMS system instrument
Flowmeter FIT -4308 after data sheet for
Magnetic Flowmeter FIT-3308
(Appendix S)
Remedial Action Workplan
Replace the first page of the Table of Page numbers in Section 2 changed
Contents (Section 1 through Section
3.2.5) with the revised first page of the
Table of Contents (Section 1 through
Section 3.2.5)
Replace Section 2 (pp. 2-1 through 2-Adds new Section 2.2.5 describing UMS
1 O) entirely with revised Section 2 (pp. system installation
2-1 through 2-11)
Performance Standards Verification Plan
Replace page 3-1 of the Field Sampling Adds description of UMS system to effluent
and Analysis Plan with revised page 3-1 monitoring requirements.
Operations and Maintenance Plan f Replace Preface with revised Preface Note to readers that the design and O&M
requirements have been revised to include the
Upper Macon Source Area (UMS) extraction
and treatment system
CJ:\DATA\PAUL\WP\7001728A.RPLJ94 3
• •
REVISIONS TO THE FINAL DESIGN AND SUPPORTING DOCUMENTS (CONTINUED)
June 15, 1995
/
/
(Replace Table of Contents (pp. i Page numbers in Section 1 changed and a
through iv) with revised Table of new Section 2.5 was added
Contents (pp. i through iv)
Replace p. 1-3 with revised p. 1-3 Added UMS treatment system description at
// bottom of page
V Replace p. 1-5 with revised p. 1-5 Added UMS system description at top of page
/ vReplace pp. 1-8 and 1-9 with revised Added UMS system text to Sections 1.5.1 and
pp._)'8 and 1-9 1.5.2
/ [,,Replace pp. 1-23 through 1-29 (Figure Added Table 1-4 for UMS site air stripping
1-8) with revised pp. 1-23 through 1-30 system
Replace pp. 2-32 through 2-35 with Revised Operational Description to include V revised pp. 2-32 through 2-35 explanation of electronic timer/overload device
added Section 2.5 to describe O&M system
/ requirements
1V Replace p. 2-38 with revised p. 2-38 Corrected title of Table 2-7
Replace p. 2-41 with revised p. 2-41 Corrected title of Table 2-8
Replace p. 2-49 with revised pp. 2-49 Added Section 2.5 to describe O&M system
through 2-58 requirements
Replace p. 3-2 with revised p. 3-2 Added UMS reference to electric submersible
pumps text
Replace p. 5-4 with revised p. 5-4 Added UMS air stripper to Table 5-3
Replace Appendix B (Process Controls PCN was revised to include the UMS system
Narrative) with the revised PCN (pp. 01
through Q-13
Add data sheet for Bag Filter BF-4001 Adds data sheet for UMS system instrument
at the end of Appendix D
Add vendor cut sheet for submersible Adds vendor information for UMS system
pump to end of Appendix F pumps
G:\DATA\PAUL\WP\7001726A.RPL/84 4
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
May 18, 1995
4WD-NSRB
Mr. Kenny Gulledge
Crown, Cork and Seal Co.
100 Evans Row
Cheraw, SC 29520
SUBJ: Macon/Dockery NPL Site
Cordova, NC
Dear Mr. Gulledge:
Rece,veo
MAY 2 21995
SUPERFUNO sec,;o,v i
The Agency
the Upper Macon
April 14, 1995.
has reviewed the Prefinal Design Submittal for
Source Area Groundwater Treatment System dated
Comments are attached.
Since the comments are not extensive, please go ahead and
finalize the replacement pages. Include with this submittal, the
usual letter response that shows how and where the comments were
addressed.
If you have any questions, please give me a call. The final
pages will be due to the Agency no later than June 5, 1995.
Sincerely,
01!.0...@:4
Remedial Project Manager
cc: Paul Furtick, RMT
Printed on Recycled P.1per
• •
COMMENTS
General
1. The Final Design documents/drawings are to be stamped and
signed by a PE registered in the State of North Carolina.
2. This submittal only included revisions to the RD.
Appropriate changes to the RA Workplan, the Performance
Standards Verification Plan, and the O&M Plan should also be
submitted.
3. The additional wells added to the other systems (Upper and
Lower Dockery and Lower Macon) have not been included. For
example, neither the revised Dwg. 7001721-COl nor any of the
other drawings reflect the additional wells that are to be
added to the other source area systems. These revisions
should be made. In addition, the drawings are in conflict
with Drawing 7001721-Cl0 submitted earlier.
Specific Comments
1. Page 3-4, Para 1 -What is the rationale for not providing a
specific design of the additional wells? What guidance will
be provided?
2. Page 3-12, Para 1 -The submersible pumps will actually pump
the groundwater to a prefilter prior to the air stripper and
not directly to the air stripper as stated here. Please
correct the text. Also, verify that the filter will be
capable of handling sharp variations in flows/pressure
without prior equalization in an upstream tank.
Specifications
1. The instrumentation data sheets are not directly referenced
within the body of any specifications or included in the
Specification List (Page 3-31 and Appendix S). Include in
the Table of Contents similar to the Liquid Bag Filters and
reference directly in Section 16010, Article l.2E or a
separate section.
0
State of North aolina 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
April 21, 1995
Memorandum
TO: Arthur Moubeny, Chief
Groundwater Section
COPY • ~VA
DEHNR.
Division of Environmental Management (DEM)
FROM:
RE:
David J. Lown ~
Environmental Engineer
Superfund Section
Prefinal Remedial Design -Upper Macon Source Area
Groundwater Treatment System
Charlie Macon Lagoon and Drum Storage (Macon Dockery) NPL Site
Cordova, Richmond County
EPA is completing a Remedial Design Report for this National Priorities List site. The NC Superfund Section is reviewing the draft reports and will be submitting comments to EPA by May 10; 1995.
The documents being reviewed are attached. The remediation plan calls for pumping and treating the groundwater plume for VOCs and discharging the treated water to infiltration galleries. The substantive requirements for a non-point source discharge permit will have to be met; however, because the discharge is on-site, a permit is not required. Source areas will be treated with soil vapor extraction technology.
Please forward this document to the appropriate sections of DEM and submit any comments to the NC Superfund Section. We would like to have the views and permitting requirements of Air Quality, Groundwater, and Water Quality Sections of DEM. If you or your staff have questions, please call me at [phone].
Attachment
cc: Jack Butler
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX 919-71&-3605
An Equal Opportunity Affirmative Action Employer 50% recycled/ l O't post•consumer paper
• • r-;;:=------"\
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RECEIVED I
REGION IV
345 COURTLAND STREET. N.E.
4WD-NSRB
Technical Committee
c/o Kenny Gulledge
Crown, Cork, and Seal Co.
100 Evans Row
Cheraw, SC 29520
ATLANTA. GEORGIA 30365
March 28, 1995
SUBJ: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Gulledge:
APR 41995
SUPERFUND SECTION
In response to your February 28, 1995 letter, EPA and NC DEHNR
have considered your request to discharge treated water from the
air stripper system directly to the onsite infiltration gallery
WITHOUT treating for manganese.
The NC DEHNR considers this a request to waive the substantive
requirements for an infiltration gallery with respect to manganese.
This request is granted WITH THE FOLLOWING CONDITIONS:
1) Design the groundwater extraction system so that the
system is closed-loop with respect to the infiltration
gallery and the injection wells;
2) The system will continue to operate until the cleanup
level for all the contaminants of concern, including
manganese, are achieved. The performance standard for
manganese will not change; and
3) Infiltration galleries are located onsite more than 50
feet from the site boundaries.
If you have any questions, please give me a call.
Sincerely,
v::f !If.A !!!E
Remedial Project Manager
Printed on Recycled Paper
....
State of North clolina
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
COPY
March 27, 1995
Ms. Giezelle Bennett
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
RE: Comments on Letter Concerning Source Area and
Treatment System Design (February 28, 1995)
Macon/Dockery Site
Cordova, Richmond County
Dear Ms. Bennett:
• NA
DEHNR
The Superfund Section has received and reviewed this document. It is our understanding that
the Macon/Dockery Site Group (MDSG) wants the State to waive the substantive requirements for
an infiltration gallery pennit with respect to manganese. As a condition of this waiver the MDSG will
do the following:
1) Design the groundwater extraction system so that the system is closed-loop with respect
to the infiltration gallery and the injection wells.
2) The system will continue to operate until the cleanup level for all the contaminants of
concern, including manganese, are achieved.
3) Infiltration galleries are located on-site more than 50 feet from the site boundaries.
The State agrees to this waiver as long as these conditions are maintained.
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
Ms. Giezelle Bennett
March 27, 1995
Page2
• •
The Superfund Section appreciates the opportunity to comment on this document and looks
forward to continuing to work with you to clean up this site. If you have any questions or comments,
please do not hesitate to contact us at [phone].
cc: Jack Butler
Coleen Sullins, Water Quality, DEM
Environmental Engineer
NC Superfund Section
Macon/Dockfry Site
Richmond County, North Carolina •
Reply to: Technical Committee
c/o David L. Jones
Clark Equipment Company
P. o. Box 7008
South Bend, IN 46634
February 17, 1995 Phone, 219-239-0195
Fax: [phone]
Ms. Giezelle Bennett
Remedial Project Manager · RECEIVED
U.S. EPA, Region IV
345 Courtland Street MAR O 11995
Atlanta, GA 30365
RE: Final Design Deliverables sUPERFUND SECTION
Macon/Dockery Site -Cordova, North Carolina
Dear Ms. Bennett:
Transmitted herewith are seven (7) copies each of the following documents, which are
required for submittal with the Final Design:
• Final Remedial Design Report for Ground Water;
• Final Remedial Design Drawings; and
• Operation and Maintenance Plan
The Remedial Action Work Plan, the Performance Standards Verification Plan for Ground
Water, and the Construction Health and Safety Plan were previously submitted in a finalized
form. The Macon/ Dockery Site Group (MDSG) has incorporated into each document the
approved revisions contained in our December 19, 7 994 response letter. Revised text is
contained in the enclosed replacement pages for each of the seven copies of these plans. The
Prefinal Remedial Design Report for Ground Water and the Operation and Maintenance Plan
were submitted as working copies. The MDSG has incorporated U. S. EPA comments into
these latter two do..:umeilts and is resubmitting both in finaii.>:ed form. Attached is a list
indicating revisions made in the enclosed documents-due to. U. S. EPA's commei,ts on the
Prefinal Design submittal. The attached documeni lists U.S. f'i'/>.,'s comments in bold type,
the MDSG's respo;1ses in standard type, and an italicized nc,tr: following each response
indicating where ar:d/or how the text was _revised to ine<:>rporate eoach comment. _
The Final Design submittal does not contain any information from N.C DEHNR re,;arding the
permitting status for effluent discharges from the three ground water treatment system5, :;ince
N. C. DEHNR does not review draft permit applicaticn:packages. As previously discussed,
the MDSG is submitting a permit application based 011 the Final Di!sign submitt,.I, stamped
and sealed as appropriate by registered Professional -Engir,ee_rs.\ , ·
r
Ms. Giezelle Bennett • Page 2 • February 17, 1995
Please contact me at [phone] or Wayne Barto of de maximis, inc. At [phone]
if you have any questions concerning this letter or the transmitted deliverables. Thank you
for your continued assistance on this project.
Very truly yours,
CLARK EQUIPMENT COMPANY
ff~..;;'~
David L. Jones
Project Coordinator
Macon/Dockery Technical Committee Chairman
lb
cc: Macon/Dockery Technical Committee
Wayne F. Barto, de maximis, inc.
•
PREFINAL REPORT COMMENTS
1. Page 1-1, Para 3. The source control paragraph needs to be updated.
RESPONSE: The referenced paragraph states the requirements of the Order for Lagoon 7 and
Lagoon 10 wastes. The second and third full paragraphs on page 1-2 provide the
requested update.
[No changes were made in the text for this comment.]
2. The groundwater recovery system was designed using a two-dimension numerical model assuming
an isotropic porous media. In viaw of the change to the hydrogeologic model for the site, the
numerical model is only of limited value and should be reevaluated. Alter mapping permeability
trends in the transition zone and bedrock, the data should be examined using a three-dimension
numerical model.
RESPONSE: The Flowpath model was used to predict likely flows and capture zones using the
available data. The MDSG' consultants reviewed the recent findings and revised the
design with sufficient capacity to handle much higher flows than predicted, thereby
eliminating the need for a change in hydrogeology models. We believe that conducting a
three-dimensional modelling effort at this point would not cause a revision of the system
design but would greatly increase the cost and duration of the design phase.
[No changes were made in the text for this comment.]
3. Page 3-16. The text states that extraction well installation may include using a bentonite slurry
powder, tremied into the well, in place of using bentonlte pellets as an annular seal above the sand
pack. This procedure is inconsistent with the specifications in Appendix S, Section 4.2. It is also
not recommended as a well construction procedure, for the following reasons:
•
•
•
Bentonlte pellets will hydrate In the well bore, which should form a tighter, more solid seal
than the bentonite slurry. A slurry may not prevent grout migration Into the sand pack,
because of grout Jetting through the bentonlte slurry seal as the grout exits from the
tremie pipe at a high velocity.
A bentonite slurry seal might be more difficult to "tag" than a bentonite pellet seal,
potentially resulting in grout emplacement beginning below the top of the bentonite seal,
rather than at the top of the seal.
The EPA Region IV ESD Standard Operating Procedures and Quality Assurance Manual,
1991, specifies that a bentonite pellet seal should be used. However, ii there is some
condition unique to this site that makes use of a bentonlte slurry preferable to the ESD-
recommended bentonite pellet seal, then It would be permissible to use the bentonite
slurry. There Is no Information presented in the design report to Indicate this is the case.
RESPONSE: The text has been revised as follows:
l~WP\7017001721B COM'c~
"The annular space around the well screens will be packed with clean washed silica
sand having a grain size appropriate to the screen slot size. The sand pack will be
emplaced by tremie pipe and will extend approximately two feet above the top of the
screen. A bentonite seal having a minimum thickness of approximately two feet will be
placed above the sand pack. If the top of the sand is less than 50 feet below land
surface, bentonite pellets will be dropped down the annular space. The bentonite pellets
will be added a few at a time to minimize the chance of bridging. If the top of the sand
Page 1
• •
PREFINAL REPORT COMMENTS
1. Page 1-1, Para 3. The source control paragraph needs to be updated.
RESPONSE: The referenced paragraph states the requirements of the Order for Lagoon 7 and
Lagoon 10 wastes. The second and third full paragraphs on page 1 -2 provide the
requested update.
[No changes were made in the text for this comment.]
2. The groundwater recovery system was designed using a two-dimension numerical model assuming
an isotropic porous media. In view of the change to the hydrogeologic model for the site, the
numerical model is only of limited value and should be reevaluated. After mapping permeability
trends in the transition zone and bedrock, the data should be examined using a three-dimension
numerical model.
RESPONSE: The Flowpath model was used to predict likely flows and capture zones using the
available data. The MDSG' consult.ants reviewed the recent findings and revised the
design with sufficient capacrty to handle much higher flows than predicted, thereby
eliminating the need for a change in hydrogeology models. We believe that conducting a
three-dimensional modelling effort at this point would not cause a revision of the system
design but would greatly increase the cost and duration of the design phase.
[No changes were made in the text for this comment.]
3. Page 3-16. The text states that extraction well installation may include using a bentonite slurry
powder, tremied into the well, in place of using bentonite pellets as an annular seal above the sand
pack. This procedure is inconsistent with the specifications in Appendix S, Section 4.2. It is also
not recommended as a well construction procedure, for the following reasons:
•
•
•
Bentonite pellets will hydrate in the well bore, which should form a tighter, more solid seal
than the bentonite slurry. A slurry may not prevent grout migration into the sand pack,
because of grout jetting through the bentonite slurry seal as the grout exits from the
tremie pipe at a high velocity.
A bentonite slurry seal might be more difficuH to "tag" than a bentonite pellet seal,
potentially resulting in grout emplacement beginning below the top of the bentonite seal,
rather than at the top of the seal.
The EPA Region IV ESD Standard Operating Procedures and Quality Assurance Manual,
1991, specifies that a bentonite pellet seal should be used. However, if there is some
condition unique to this site that makes use of a bentonite slurry preferable to the ESD-
recommended bentonite pellet seal, then It would be permissible to use the bentonlte
slurry. There Is no Information presented In the design report to indicate this Is the case.
RESPONSE: The text has been revised as follows:
I :\wP\7O170O1721 B.COM/cd!IM
"The annular space around the well screens will be packed wrth clean washed silica
sand having a grain size appropriate to the screen slot size. The sand pack will be
emplaced by tremie pipe and will extend approximately two feet above the top of the
screen. A bentonite seal having a minimum thickness of approximately two feet will be
placed above the sand pack. If the top of the sand is less than 50 feet below land
surface, bentonrte pellets will be dropped down the annular space. The bentonite pellets
will be added a few at a time to minimize the chance of bridging. If the top of the sand
Page 1
• •
pack is greater than 50 feet below land surface, the bentonite pellets may be placed via
!ramie pipe. A bentonite slurry made of potable water and bentonite powder may be
used ~ unusual conditions prevent the use of bentonite pellets to create the seal. If a
bentonite slurry is employed as a seal, this slurry will be placed via a tremie pipe set
near the top of the filter pack."
[The revised paragraph can be found at the bottom of p. 3-16.J
4. Page 3-19, Last Bullet. Change reference for "Appendix G" to "Appendix Q".
RESPONSE: The text has been corrected.
[The revised text is in the last sentence at the bottom of p. 3-19.J
5. Page 3-19, Last Bullet. The statement is incorrect; the pump Is controlled by levels In the air
stripper reservoir. The pump operation will not necessarily be continuous. Revise paragraph
accordingly.
RESPONSE: This paragraph describes the operation of the centrifugal pumps (also known as "prime
movers") used in the jet pump system, and not the air stripper effluent pumps. The
following text will be added at the bottom of page 3-14:
. The air stripper effluent pumps are controlled by level switches located in the air stripper
sump and by differential pressure switches located across the discharge bag filter and
metals removal columns. The pump will start if the water level in the air stripper sump
reaches the high level swkh, and the pump will stop when the water reaches the low
level switch or if the metal removal columns or the bag filter are unable to operate due to
high differential pressure. A control narrative is included in Appendix Q to detail pump
operations. n
[The new paragraph was added at the top of p. 3-20.J
6. Page 3-20. Delete the last sentence.
RESPONSE: The last sentence has been deleted.
[The change was made as indicated.]
7. Page 3-20, Bullet 6. Recommend including cover for the equipment with at least an open-sided
"ramada" sun/rain roof. This will help in easing maintenance repairs during rain showers.
RESPONSE: The system has been designed without a roof to facilitate column exchange operations
and to accommodate future equipment additions ~ necessary. The MDSG does not
consider a roof to cover the treatment pads warranted for relatively infrequent
maintenance work in inclement weather in light of the need for column access and
system flexibility.
[No changes were made in the text for this comment.]
8. Page 3-21, Bullet 2. Verify that this statement applies to the Upper and Lower Dockery systems as
well as the Macon system ..
RESPONSE: The statement applies to all three systems. Each system can continue to operate if one
column is removed for servicing.
[No changes were made in the text for this comment.]
l:\'NP\7017001721B.COMle~ Page 2
• •
9. Page 3-22, Bullets 7-9. Add a reference in this section to the process control narrative given in
Appendix Q.
RESPONSE: The following sentence has been added to the last bullet on page 3-22:
"A control narrative is included in Appendix Q that describes equipment interlocks."
{The added sentence was included in the top paragraph of p. 3-23.]
10. Page 3-26, Paragraph 3. Include here the air stripper air emission tables attached to the Response
to Intermediate Design Report Comments or refer to Appendix Land include the tables there.
RESPONSE: The paragraph has been revised by referring the reader to Appendix L, where the tables
have been added.
{The referenced sentence has been added to the last paragraph on p. 3-26.J
11. Figure 4-1. The schedule does not include O&M contractor selection. The completion reports for
vessel removal and Lagoon 10 removal have been deleted. When_ will these reports be submitted?
RESPONSE: O&M contractor selection will be conducted throughout 1995 through identification of.
and interviews wrth, qualified individuals and companies. The schedule requires that a
contractor be selected by 11-13-95, which is the beginning date for O&M Training. The
Lagoon 10 waste and vessel removal tasks were completed in November. The
completion report for both activities will be submitted in January 1995.
[No changes were made to the text for this comment. The completion report was submitted to
US EPA on January 30, 1995.J
12. Appendix L. Include material balances for the groundwater constituents and air calculations.
RESPONSE: Material balances and air emission calculations for the three air strippers and the SVE
unrt will be included in Appendix L. The attached summary air emission tables will also
be included in Appendix L.
{The referenced calculations and summary tables now appear in Appendix L.J
13. Appendix Q, Page 4, Paragraph 6. Discuss how damage to the effluent pump will be prevented in
the occurrence that the filter becomes blocked.
RESPONSE: The referenced paragraph has been revised as follows:
"If the filter becomes too full, Differential Pressure Switch dPISH-1307 will issue alarm
dPAH-1307, located on the Macon Control Panel, and shut down P-1001, P-1002, P-
1qo3, and Blower B-1001."
The other bag filter descriptions have been similarly revised to state that the differential
pressure alarm will cause the related pumps and blowers to shut down.
{Each description of bag filter operations in the Process Narrative now describes the system
safeguards for clogged filters.]
14. Appendix a, Page 7, Paragraph 4. Add that Pump P-2002 will run without any interlocks when the
H-0-A switch is on HAND.
RESPONSE: The following sentence has been inserted after Paragraph 3:
I ;\WPI 70\7001721 B. COM/cd!IM Page 3
•
"In HAND, P-2002 will run without any interlocks."
[The change has been made as indicated.}
•
15. Appendix a, Page 8, Paragraph 1. Explain why the well pumps will STOP at high level.
Should this not be the level at which they START? Explain why the well pumps are
being controlled from the air stripper sump at low-level In addition to the control coming
from the feed tank at high-level.
RESPONSE: The text references the Upper Dockery system, which is a submersible pump
system. A high level alarm in the feed tank indicates that flow to the treatment
system has slowed or stopped, so the wells should stop pumping. The low flow
swttch referenced at the end of the first paragraph measures air flow from the
blower. If no air is blowing into the air stripper, the system shuts down to
prevent the discharge of untreated water.
[No changes were made to the text for this comment.]
16. Appendix S, Section 02673, part 3.1. This section states that the well drilling contractor
should be certified by the state of South carollna. Since the site Is In North Carolina,
the contractor should be certified to drill wells In North Carolina.
RESPONSE: All references to "South Carolina" in paragraph 3.1.3 have been revised to
"North Carolina."
[The changes were made as indicated.]
17. The state has these fundamental questions about the groundwater:
a. What Is the vertical extent of contamination? Is there contamination In the
bedrock aquifer?
RESPONSE: Although there is no specttic analytical data concerning the bedrock aqutter, the
concentrations of contaminants in bedrock, tt present, are expected to be
signtticantly less than those in the saprolite aqutter, since there is no indication
of a separate solvent phase. We do expect that higher horizontal flows
exhibited in the partially weathered rock transttion zone above bedrock are
likely to intercept the contaminant plume. The recovery wells will be installed
and screened through the transttion zone to the top of competent bedrock,
which will also aid in preventing migration into the bedrock aqutter and will
intercept the greatest mass of contaminants.
[No changes were made to the text for this comment.]
b. Plezocones were completed In order to locate conductive zones? Were
conductive zones located?
RESPONSE: Due to limttations of the direct-push technology, piezocones completed in the
spring of 1993 were not successful in locating conductive zones wtthin the
water table, though shallower zones were identttied (i.e., cobble layers).
Tradttional auger methods used in the fall of 1994 located the conductive zones
within the area of the anaerobic microbial dechlorination study area.
l:\'NP\70\70017218.COM/cd!Q4 Page 4
TABLE 3-2 WORST CASE AIR EMISSION RATES
MACON AIR STRIPPER INFLUENT
POUNDS PEA 15 MINUTE POUNDS PER DAY POUNDS PER YEAR
Com0ound Flowtopm) Cone. tuam Actual Threshold Actual Threshold Actual Threshold
Benzene 48 0.52 3.26e-06 NV 3.13e-04 NV 1.14e-01 8.1
T etrachloroethene 48 1.90 1.19e-05 NV 1.14e-03 NV 4.17e-01 13000
Trichloroethane 48 6.30 3.95e-05 NV 3.79e-03 NV 1.38e+OO 4000
Toluene 48 2.70 1.69e-05 3.60 1.62e-03 98 5.93e-01 NV
Vinyl chloride 48 0.00 0.00 NV 0.00 NV 0.00 26
Xylenes 48 5.90 3.70e-05 4.10 3.55e-03 57 1.29e+OO NV • TABLE 3-3 WORST CASE AIR EMISSION RATES
UPPER DOCKERY AIR STRIPPER INFLUENT
POUNDS PER 15 MINUTE POUNDS PER DAY POUNDS PER YEAR
Compound Flow lnnm) Cone. (uq,1) Actual Threshold Actual Threshold Actual Threshold
Benzene 6 0.00 0.00 NV 0.00 NV 0.00 8.1
T etrachloroethene 6 1.70 1.33e-06 NV 1.28e-04 NV 4.66e-02 13000
Trichloroethane 6 2.50 1.96e-06 NV 1.88e-04 NV 6.86e-02 4000
Toluene 6 2.00 1.57e-06 3.60 1.50e-04 98 5.49e-02 NV
Vinyl chloride 6 0.00 0.00 NV 0.00 NV 0.00 26
Xylenes 6 25.00 1.96e-05 4.10 1.88e-03 57 6.860-01 NV
TABLE 3-1 WORST CASE AIR EMISSION RATES
LOWER DOCKERY AIR STRIPPER INFLUENT
POUNDS PER 15 MINUTE POUNDS PER DAY POUNDS PER YEAR • Compound Flow (gpm) Cone. (ug/1) Actual Threshold Actual Threshold Actual Threshold
Benzene 28 0.25 9.14e-07 NV 8.77e-05 NV 3.20e-02 8.1
Tetrachloroethene 28 0.00 0.00 NV 0.00 NV 0.00 13000
Trichloroethane 28 1.25 4.57e-06 NV 4.38e-04 NV 1.60e-01 4000
Toluene 28 0.00 0.00 3.60 0.00 98 0.00 NV
Vinvl Chloride 28 0.00 0.00 NV 0.00 NV 0.00 26
Xylenes 28 0.25 9.14e-07 4.10 8.77e-05 57 3.20e-02 NV
NV = No Value Given
l:\WP\7r:Jl.7001n1B.C0Mtc:df94 Page 5
• •
TABLE 3-5 COMBINED AIR STRIPPER WORST CASE AIR EMISSION RATES
Pounds per 15 minutes Pounds per day Pounds per vear
Comnound Actual Threshold Actual Threshold Actual Threshold
Benzene 4.17E-6 NV 4.01 e-04 NV 1.46e-01 8.1
T etrachloroethene 1.32E-5 NV 1.27e-03 NV 4.64e-01 13000
T richloroethene 4.60E-5 NV 4.42e-03 NV 1.61 4000
Toluene 1.85E-5 3.60 1.77e-03 98 6.46e-01 NV
Vinvl chloride 0.00 NV 0.00 NV 0.00 26
Xylenes 5.75E-5 4.10 5.52e-03 57 2.01 NV
TABLE 3-6 SVE UNIT WORST CASE AIR EMISSION RATES
Pounds per 15 minutes Pounds per day Pounds per year
Comnound Actual Threshold Actual Threshold Actual Threshold
Benzene 2.8E-7 NV 2.7E-5 NV 9.9E-3 8.1
T etrachloroethene 4.3E-3 NV 0.42 NV 153 13000
Trichloroethane 6.9E-6 NV 6.63E-4 NV 2.4E-1 4000
Toluene 2.4E-5 3.60 2.3E-3 98 8.4E-1 NV
Vinvl chloride 0.00 NV 0.00 NV 0.00 26
Xvlenes 2.1 E-3 4.10 0.20 57 73 NV
TABLE 3-7 MACON/DOCKERY SITE WORST CASE AIR EMISSION RATES
Pounds per 15 minutes Pounds per day Pounds per year
COffl"'OUnd Actual Threshold Actual Threshold Actual Threshold
Benzene 4.3E-6 NV 4.1 E-4 NV 1.6E-1 8.1
T etrachloroethene 4.4E-3 NV 4.21 E-1 NV 153.4 13000
Trichloroethane 5.3E-5 NV 5.1 E-1 NV 1.85 4000
Toluene · 4.2E-5 3.60 4.2E-3 98 1.50 NV
Vinvl chloride 0.00 NV 0.00 NV 0.00 26
Xylenes 2.1 E-3 4.10 2.1 E-1 57 75 NV
NV ~ No Value Given
l:\WP\70\ 70017218. COM/cdf94 Page 6
• •
[No changes were made to the text for this comment.]
c. The Student I-test was used to compare hydraulic conductivities (k) values for different
regions. Were the k values from the monitoring wells included In this determination? Based on
the Student's I-test, It was concluded "At a 90 percent confidence level, no significant differences
were found between the mean k values for the four areas of the site." In the groundwater flow
model, It was necessary to vary the k values over 3 orders of magnitude to calibrate the models.
This contradicts the conclusion based on the statistics. Are additional pump tests necessary?
Please explain.
RESPONSE: The k values from monitoring wells were not included in the determination. The k values
used to calibrate the model were varied to account for discrete areas of higher or lower
conductivities. The student t-test indicated that the pump test was indicative of average
conditions. No additional pump tests are necessary for system design. Results of the
single pump test were used to develop a design basis for average conditions, but
subsequent findings from the latest field studies led to a design revision to achieve
containment goals under much higher flow conditions. The system will be optimized
after installation. Additional extraction wells can be added to each system tt necessary
to achieve capture of each plume.
[No changes were made to the text for this comment.]
d. The transition zone between the saprollte zone and the bedrock zone seems to be a
permeable zone that is conductive to groundwater flow and the movement of contaminants. What
information has been collected to describe this zone? What is the permeability distribution for this
zone? What is Its thickness and map distribution? Please provide cross-sections showing the
transition zone, structure contour maps showing the top of bedrock surface, and isopach maps
showing the thickness of the transition zone and the saprolite zone.
RESPONSE: We do not have sufficient data to provide realistic cross-section maps of the transitio11
zone. The only available detail of the transition zone is in the vicinity of well MW-9. The
recovery wells will be installed to the top of bedrock at each site, intersecting the
transition zone. The current design already accommodates the higher flow rates
expected to be encountered in the transition zone. Therefore, the MDSG does not
believe that the requested maps will alter the design or expedite the remedy.
[No changes were made to the text for this comment.}
e. The results of analyses of groundwater from MW21 show that the western boundary of the
Upper Macon plume has not been adequately defined. What additional work is being planned to
define the extent of this plume?
RESPONSE: Analytical results at MW-21 indicate that the plume boundary has been defined. The
locations of extraction wells for the Upper Macon site will be adequate to contain the
plume while source area remediation is achieved. An intensive investigation to
determine the exact line along which constituents are no longer detected is not
warranted based on the analytical results at MW-21.
[No changes were made to the text for this comment.]
18. A survey must be made of all off-property wells within 2,000 feet, and a daily pumping rate
ascertained for each well. Such data should be utilized when designing the monitoring program
for the site.
RESPONSE:
I ~WP\70\7001721 B. COM/cdt!M
A survey of private wells located within a one-mile radius of the site was conducted
during the RI (please reference the RI Report, p. 3-25)/ It is very unlikely that residential
Page 7
• •
wells several hundred feet away from the property boundary and upgradient of the
source areas can have any effect on the operations or progress of the remedy.
Therefore, we disagree that the referenced information could cause a revision of the
monitoring program.
[No changes were made to the text for this comment.]
19. Comments that were not addressed satisfactorily:
a. General Comment No. 2. This comment needs to be addressed in terms of source area
extraction wells also.
RESPONSE: As stated in the previous response to the referenced comment, operation of the SVE
system is not expected to produce upswelling of any significance that will intertere with
system operations.
[No changes were made to the text for this comment.]
b. Specific Comment No. 1. As expressed by EPA on numerous occasions, this document
should be a stand alone document, and as such, the PRP information should be included.
RESPONSE: This document is not a stand-alone document. Once approved, the Final Design is
incorporated into the Order, which already lists the Responsible parties. The MDSG
disagrees with US EPA's request to provide this information in the design submittal.
{The document was later revised to include the list of PRPs on pp. 1-8 and 1-9.J
c. SC No. 4. This needs to be updated. The paragraph is outdated as of the ESD.
RESPONSE: The text was updated in the Prefinal Design submittal. The revised paragraph can be
found at the top of Page 2-15.
{The change was made as indicated.]
d. SC No. 5. The footnotes are still not complete. What is B, C, DL?
RESPONSE: The DL and C designations are already explained in the footnotes. The following text
will be added to the last footnote of Table 2-1:
"The following suffixes were added to the end of the sample labels: "A" designates that
the sample is the shallower of two ground water samples or the only ground water
sample collected at that location; "B" designates that the sample is the deeper of two
ground water samples collected at that location.
[The additional text was added at the end of Tables 2-1 through 2-5.J
e. SC No. 13. This sentence needs to be included in the text?
RESPONSE: We do not believe that the definition of compliance monitoring point is necessary in this
context.
{The text was later revised. The description was added to the first paragraph on p. 2-85.J
I :\WP.7017001721 B. COM1edl94 Page 8
• •
SPECIFICATIONS COMMENTS
1. Division O sections should be included.
RESPONSE: Division O sections will be included in the bid package, but not in the Remedial Design
submittal.
[No changes were made to the text tor this comment.]
2. Bid comparison sheets should have been included in this submittal.
RESPONSE: Bid comparison sheets will not be submitted to US EPA. The name of the successful
bidder will be submitted to US EPA for approval.
[No changes were made to the text for this comment.]
3. A specification section for construction scheduling is needed.
RESPONSE: A specification for construction scheduling has been added.
[Specifications for construction scheduling are included on p. 1300· 1.J .
4. Explain why Section 01410 -Testing Laboratory Services was not included In this submittal.
RESPONSE: A specification for Testing Laboratory Services has been added.
[The referenced specification is shown on p. 1400-1.J
5. The Division 1 specifications (especially Submittals and Quality Control) give the contractor
insufficient direction. Many generalities are stated using vague, catch-all language that has no
enforceable meaning. As an example, Section 13235 and 13236 refer to Section 01300 for submittal
procedures; however, Section 01300 gives no direction on when to make submittals, quantity of
submittals, and distribution of submittals.
RESPONSE: The bid package will have the necessary direction to contractors for submittais. These
will not be revised in the current design.
[No changes were made to the text for this comment.]
6. Does the Committee have a preference on how they want the main control panel physically laid
out? If so, then some direction in the form of specifications or drawings should be included In the
design package.
RESPONSE: The drawings and specifications provide the contractor with description of the panel
inputs and Items to be included in the enclosure. The contractor has the discretion to lay
out the arrangement of the panel. The Remedial Engineer will review the contractor's
shop drawings to determine if the layout is appropriate.
[No changes were made to the text for this comment.]
7. Include specifications on instrumentation (i.e., pressure indicators, flow meters, level indicators,
transmitters, etc.).
l~WP\7017001n1B.CQMI~ Page 9
• •
RESPONSE: Instrumentation specifications have been added.
{Instrument specifications are included at the end of Appendix S.J
I ~WP\70\7001721 B.COMle~ Page 10
• •
DRAWINGS COMMENTS
1. Drawings K-01, K-02, and K-03. For completeness, include a legend for symbols used on the
P&IDs.
RESPONSE: A separate drawing, K-00, has been added as a legend for symbols used on the P&IDs.
{The referenced drawing has been included in the drawings package.]
2. Drawings K-01, K-02, and K-03. Indicate that the metals treatment system(s) is a package system.
If this is not the case, then Include mechanical drawings and/or data sheets (in the Specifications).
RESPONSE: The drawings have been revised to indicate that the metals treatment columns are
package systems.
{The changes have been made as indicated.]
3. Drawing K-01. Denote that the box around the air stripper indicates "Package System".
RESPONSE: The drawing has been revised as requested.
{The change has been made as indicated.]
4. Drawing K-01, K-02, and K-03. Explain why the pressure indicator associated with the air stripper
is measuring the water head as opposed to the air pressure in the blower line.
RESPONSE: The drawings have been revised to show the pressure indicators above the sumps and
above the water level switches. These pressure indicators are measuring operating
pressures inside the air strippers.
{The changes have been made as indicated.]
5. Drawing P-01. One set of feed/return lines should indicate Lower Macon. Currently both indicate
Upper Macon.
RESPONSE: The drawing has been revised to indicate the Lower Macon line.
{The change has been made as indicated.]
6. Drawing C-02. Physically .lie in the well locations.
RESPONSE: The well location coordinates are now shown for the Dockery Site on Drawing C-04 and
for the Macon Site on Drawing C-05.
{The changes have been made as indicated.]
I :\WP\70\7001721 S. CQMlcdfQ,4 Page 11
• •
OPERATIONS AND MAINTENANCE PLAN COMMENTS
1. Pages 1:2 and 1-3. These pages discuss a consent decree. This work is under a UAO, please
change these paragraphs.
RESPONSE: Page 1-2, fourth paragraph, first sentence will be changed to:
"The O&M Plan is a major project deliverable and milestone called for in the Remedial
Design Schedule, Unilateral Administrative Order and Statement of Work (SOW)."
Page 1-3, third paragraph, first sentence will be changed to:
"The Macon/Dockery Unilateral Administrative Order requires that the
Prefinal/Final Design Report include, at a minimum, the following: .... "
{The changes were made as indicated.]
2. Page 1-27, Section 1.7. This section does not provide any Information on Process Instrumentation
and Control. Suggest referencing Appendix A here.
RESPONSE: The following sentence will be added to the end of Section 1.7:
"The process instrumentation and control approach for each system is provided
in Appendix A.''
(The sentence was added to Section 1.7, though ff now references Appendix B.J
3. Page 1-29, Section 1.9. It is recommended that the contractor(s) and equipment vendors give
operator training beyond that given by the RD engineers. Ideally, the operators would be selected
and in the field prior to final completion of construction, thereby giving the operators the chance
to witness the installation and to interface with the constructors.
RESPONSE: The first sentence of Section 1.9 will be revised as follows:
"System Operator(s) will be trained by the remedial contractor, equipment
vendors and the remedial design engineer."
[The change was made as indicated.]
4. Section 1.0. Include a Table of Contents for the O&M Manual that outlines a description of what is
to be included In the O&M Manual. Recommend that the O&M Manual include (in addition to the
contents of the O&M Plan):
a. Section for as-built drawings, approved shop drawings, and construction photos
b. Listing of manufacturers wtth telephone numbers
c. Spare parts inventory and suppliers wtth phone numbers
d. List of special tools required for O&M activtties
e. Complete nameplate data for all O&M activities
I. Sources for services and parts
l:\WPl70\7001721B.COM/cd!Q4 Page 12
• •
g. Procedures for obtaining technical support and warranty service along with telephone
numbers
h. Utility requirements
i. Permits
RESPONSE: A Table of Contents for the O&M Manual is presented below. The recommended
contents can be found in the following sections:
Section
A. List of Drawings
B. Section 8.4.1
C. Section 8.3
D. Section 8.3
E. Sections 7.1.2; 7.2.2; 7.3.2; and 7.4.2
F. Section 8.3
G. Section 8.4
H. Section 7.1.1; 7.2.1: 7.3.1; and 7.4.1
I. Appendix K
OPERATION AND MAINTENANCE MANUAL
TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS
DOCUMENT CONTROL SHEET
1. INTRODUCTION
1.1 Background
1.2 Purpose of Manual
1.3 Scope of Work
1.4 Regulatory Requirements
2. TREATMENT SYSTEM DESCRIPTIONS
2.1 Ground Water Recovery
2.2 Ground Water Treatment
2.3 Soil Vapor Extraction System
3. DESIGN CONDITIONS AND PRESCRIBED TREATMENT
3.1 Macon Ground Water Extraction Wells and Process Equipment
3.2 Upper Dockery Ground Water Extraction Wells and Process Equipment
· 3.3 Lower Dockery Ground Water Extraction Wells and Process Equipment
3.4 Macon Soil Vapor Extraction Wells and Process Equipment
l:\WP\7O\7OO17210.COM/c~ Page 13
• •
OPERATION AND MAINTENANCE MANUAL
TABLE OF CONTENTS (Continued)
4. PROCESS INSTRUMENTATION AND CONTROL APPROACH
4.1 Organization of Operations Management
4.2 Upper Dockery Ground Water Remediation System
4.3 L_ower Dockery Ground Water Remediation System
4.4 Macon SVE Remediation System
5. ORGANIZATION OF OPERATIONS MANAGEMENT
6. TRAINING OF PERSONNEL
7. OPERATION OF SYSTEMS
7 .1 Macon Ground Water Remediation System Description
7.1.1 System Description and Equipment
7.1.2 Equipment Name Plate Data
7.1.3 System Start-Up for Ground Water Recovery and Treatment System
7.1.4 Normal Operation
7.1.5 Normal Shutdown
7.1.6 Emergency Shutdown
7.1.7 Troubleshooting and Alternate Operation
7.2 Upper Dockery Ground Water Remediation System Description
7.2.1 System Description and Equipment
7.2.2 Equipment Name Plate Data
7.2.3 System Start-Up for Ground Water Recovery and Treatment System
7.1.4 Normal Operation
7.2.5 Normal Shutdown
7.2.6 Emergency Shutdown
7.2.7 Troubleshooting and Alternate Operation
7 .3 Lower Dockery Ground Water Remediation System Description
7.3.1 System Description and Equipment
7.3.2 Equipment Name Plate Data
7.3.3 System Start-Up for Ground Water Recovery and Treatment System
7.3.4 Normal Operation
7 .3.5 Normal Shutdown
7.3.6 Emergency Shutdown
7 .3. 7 Troubles hooting and Alternate Operation
7.4 Macon Soil Remediation System Description
7.4.1 System Description and Equipment
7.4.2 Equipment Name Plate Data
7.4.3 System Start-Up
7.4.4 Normal Operation
7.4.5 Normal Shutdown
7.4.6 Emergency Shutdown
7.4.7 Troubleshooting and Alternate Operation
7 .5 Description and Operation -Auto Dialer
I ~WP\7017001721 B.COM/cdf94 Page 14
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OPERATION AND MAINTENANCE MANUAL
TABLE OF CONTENTS (Continued)
8. MAINTENANCE OF SYSTEMS
8.1 Ground Water Remediation System Maintenance Tasks
8.1.1 Mechanical Equipment
8.1.2 Instrumentation and Controls
8.2 Soil Vapor Extraction System
8.2.1 Mechanical Equipment
8.2.2 Instrumentation and Controls
8.3 Maintenance Supplies and Equipment
8.3.1 Tools and Parts Inventory
8.3.2 Suppliers
8.4 Technical Support and Other Services
8.4.1 Manufacturer Warranty Services
8:4.2 Engineering Support
8.4.3 Local Contractor Services
9. HEAL TH AND SAFETY
9.1 Health and Safety Plan
9.2 Standard Operating Procedures and Controls
9.3 System Failure Activities
9.3.1 Medical Emergencies
9.3.2 General Emergency Procedures
9.3.3 Personal Injury
9.3.4 Chemical Exposure
9.3.5 Fire or Explosion
9.3.6 Emergency Contacts
10. ROUTINE MONITORING, RECORDKEEPING, AND LABORATORY TESTING
10.1 Monitoring Activities and Schedule
10.1.1 Ground Water Remediation System
10.1.2 Macon Soil Vapor Extraction System
10.2 Laboratory Testing
10.3 Personnel and Maintenance Records
10.3.1 Medical Surveillance
10.3.2 Training
10.3.3 Work Logs
10.3.4 Accident Reporting
10.3.5 Maintenance Records
10.4 Systems Reporting
List of Figures
List of Tables
List of Drawings
[Na changes were made to the text far this comment. The tftle of Section 7.2 was changed to
reference Upper Dockery rather than Lawer Dockery due ta a subsequent comment from US
EPA.]
tW#Pl71l17001721B.COMtedt94 Page 15
• •
5. Page 5-1, Paragraph 1. Include instructions for the autodialer, especially for alarm
conditions.
RESPONSE: The following description of the autodialer function has been added to Section
1. 7.
The systems are designed to operate continuously unless certain monnoring
devices indicate a problem. Each of the three ground water treatment systems
will be equipped wnh an autodialer device to nottty designated personnel if a
system shuts down automatically, or if power (but not telephone service) is
interrupted to the systems. The autodialer will automatically dial a preset list of
telephone numbers in series until someone acknowledges with a preset code.
The acknowledging party will hear a pre-recorded message describing which
treatment system has shut down. The autodialer will repeat the list of
notifications after a prescribed time period unless someone manually resets the
autodialer at the sne.
[The revised paragraph is shown on the bottom of p. 1-27.]
6. Page 5-2, Section 5.2. Reference Performance Standards Verification Plan for sampling
frequency and methodology or include those sections of the plan.
RESPONSE: The following text will be inserted after the first sentence of Section 5.2:
Sampling frequency and methodology will follow the sampling
schedule and procedures as found in the Performance Standards
Verttication Plan."
[The added sentence is shown on p. 5-2.J
7. Page 5-2, Last Paragraph. Also submit the report forms to EPA.
RESPONSE: The first sentence of the last paragraph will be revised as follows:
Results of the sampling analysis will be provided on a monthly routine
to NC DEHNR and the US EPA using Discharge Monnoring Report
Forms (EPA Form 3320-1)."
[The sentence was inserted at the top of p. 5-3.J
l:\WP\7017001721B.CQMI~ Page 16
• •
PERFORMANCE STANDARDS VERIFICATION PLAN COMMENTS
1. Page 3-1. A nondischarge permtt is discussed In Section 3.1.2. If a permtt is needed, then
NC recommends:
-An application for a non-discharge permit, for groundwater remediation systems, and a
fee of $400.00 should be submitted to Permtts and Engineering, Water Qualtty Section,
Division of Environmental Management, Department of Environment, Health and Natural
Resources, P. 0. Box 29535, Raleigh, NC 27626-0535.
-Please include wtth the application:
1) the final design report
2) a soil evaluation of the disposal site conducted by a soils scientist (The soils al each
specific infiHration gallery should be described. Provide a minimum of 3 borings at each
of these locations or the equivalent information to a minimum 7 loot depth), and
3) the manufacturer's performance specification for the diffused aeration system which
demonstrates that the system performance will in fact reduce the influent volatile
constituents to the performance effluent requirements.
RESPONSE: The permit application will be submitted lo NC DEHNR with the Final Design
Report and the other requested information and fee.
{No changes were made to the text for this comment.]
2. Page 3-2, Section 3.1.4. ResuHs should be sent to EPA with the monthly progress reports,
not upon wrttten request. (As stated In the response to comment no 3).
RESPONSE: The last sentence of Section 3.1.4 has been revised as follows: "US EPA will
be provided copies of all such data with the monthly progress reports."
[The revised sentence is shown on Replacement Page 3-2.J
3. Proposed monitoring wells MW24 and MW25 do not appear to be in locations that can
possibly intercept the migrating contaminant plume as displayed. Please explain.
RESPONSE: Well MW-24 might not intercept the migrating contaminant plume. The MDSG.
therefore, proposes to eliminate MW-24 altogether. MW-25, however, does lie
in the path of the Lower Dockery plume, and we expect that the well will
eventually be impacted if the remedy is not implemented. The MDSG,
therefore, requests to leave MW-25 as shown.
[Well MW-24 will not be installed. The figure has not been changed.]
I ~WP\7017001721 B.COM/ClfflM Page 17
• •
CONSTRUCTION HEALTH AND SAFETY PLAN/CONTINGENCY PLAN COMMENTS
1. Table 7-1. It is unclear to the reader why respirators with HEPA/organic vapor cartridges
are to be used. According to the information on pages 4-6 to 4-19, cartridges should not
be used for 57% of the volatile organics found on the site. Even ii detector tube readings
for the chemicals listed in this table are all below the "maximum range value" and vinyl
chloride is less than 1 ppm, air purifying respirators are still not appropriate to protect
against 36% of the chemicals of concern. Please explain.
RESPONSE: The protection requirements were set at levels that will not exceed Threshold
Lim rt Values (or the Permissible Exposure Lim rt for benzene) for the
contaminants known to be present. While respirators are not required at these
levels, the Health & Safety Plan specmes the use of respirators as a safety
measure until some action is taken to identify and quantify the constrtuents in
an organic vapor.
[No changes ware made to the text for this comment.]
2. Table 7-1. Will a gas chromatograph be used wHh the PID/FID? If not, chemicals cannot
be Identified with the proposed instrumentation, therefore, a concentration expressed as a
volume to volume ratio such as ppm is meaningless. The recommended term is "meter
units."
RESPONSE: The table has been revised by substrtuting "meter units" or mu for "ppm".
[The revision is shown on Replacement Page 7-2.}
I :\\NP\ 70\7001721 B. COM1c:d!Q4 Page 18
• •
RA WORKPLAN COMMENTS
1. Previous Comment No. 4. Confirmation sampling still is needed for the SVE Lagoon 7
cleanup. Why Is this no longer applicable? Is it included in the SVE final design report?
RESPONSE The SVE design was broken out as a completely separate design. The SVE
design does include confirmation sampling for Lagoon 7 soils.
{No changes were made to the text for this comment.]
2. Previous Comment No. 12. This is still not in line with the UAO that was issued. THE
IQAT TEAM MUST REPORT ITS FINDINGS AND CONCLUSIONS DIRECTLY TO EPA, AND
NOT THROUGH THE PAPS.
RESPONSE: The text in the third sentence of the IQAT description has been revised to
reflect that US EPA will receive all reports simultaneously w~h the Remedial
Action Coordinator.
{The revised sentence is shown in the /OAT description on Replacement Page 4-5.J
3. There Is a typo In the schedule both here and in the prefinal report. The schedule states
that the contractor selection process begins on 1/1/94, instead of 1/1/95.
RESPONSE: The text in both locations has been corrected.
[The text has been revised as indicated.]
I :\WP'\70\7001721 B.COM/cdHM Page 19
EPA REGION IV WASTE MGT PROGRf'NS 001 •
Macon/Dockery Site
Riobmond County, North ca~oliQ•
. OPTIOIJAL rom.4 9~ (1-90) ! . -,.~ l .' '
RANSMITT
Via Facsimile
FebnJary 26, 1995
G&:N1:R1U. s kv1oes ~DM!NU~TRr.T10N
Ms. Glezem, S. Bennett
· Remedial Project M111m19er
United States Environrmmtal Protection Agency
345 Courtland Street, NE . .
Atlanta, GA 30366
Reference: · Maoon/Docikery Site -Cordova, NC
Souro-, Areft E.drautlon ,md Treatment Syetem 0eelgn
Oear Ms. Bennett:
The Macon/Dockery Site Group (MDSG) Is proceeding with the design of source area
extraction end treatment systema ·as conceptualli!!d In the Final Design Report submlttad
on Fl'!bruary 17, 1995.
The conoeptual design for the Lower Macon and Lower Dockery source areas consists of
the addlllon of one (1) extraction well to the piping loop for each location. The Upper
Dockery f?Ource area conceptual design consists of the addition of two (2) extraction wells
to the piping loop. These changes are slmple additions Of extraction wells'lilalil:> the existing
design, since the addiflonat treatment cepaolty required by adding these wells has already
been incorporated into the hydraulic design of the current treatment system&. Therefore,
the MDSG Is proposing to add these wells into the current bidding documents as additional
bid items for in11tallatlon under the forthcoming perimeter containment and SVE system
competitive bidding proce(lure. This will be the mo&t timaly and efficient way to Insure that
these wells are installed coincident with, end that the piping and material& of construction
are consistent with and of the same quality ath the other extraction wells.
The conceptual desI9n for the Upper Macon source area system Will be designed as a
stand alone system. It Includes the Installation of five (OJ extraction wens, a treatment
ziy11tem, und 1m lnflltratlon gallery (See Drawing 7001721-C10 In the .final Dei;lgn
Drawings). In ~valuating the options for the treatment systam fOr the Uppr:,r Macon, thi,
Group's Project engineer, RMT, Inc., has determined that th@re ar@ currently no promising
technologies for addressing the removal of naturally occuring manganese from
groundwater In thle vicinity which oxhiblte oonoentralions above Performance .Stendeird&,
This finding, coupled with the bellaf that under continuous pumping conditions (whioh
would b~ axperlenced with lhe "pump & treat" technclogy) the Influent manganes& -
SIWIXljW 3G WdEv1S0 S6, SE: 63.:!
Ms. Giezelle Bennett
February 28, 1995
Page2 of3 ·
EPA REGION IU WASTE MGT PROGRAMS • -
002
concentration to the treatment system is expected to drvp-off to h,1vels below the
Perfonnance Standards. This Issue appears to be well founded based upon the dramatic
reduction (i.e. 382 ppb to 123 ppb) in manganese concentrations delivered from the pump
test well during the pre-design aquifer test. Tnls significant reduction occurred within lhB
approximate 50 hOure duration of the pump test and, In fact, at the termination of the pump
test the manganese conC1:1ntratlon we& still dropping and had not yet leveled off. fl ls also
noted that manganese concantrstlons only exeaed the 50 ppb Performance Standard In
2 out of 6 of the proposed extraction well looa\io0$ shown in .the conceptual de&i9n. lo the
other 3 locations the manganese concentrations were less then the detactlon limits of
16 ppb. The need to remove mangimo11e to mlilet the performenoi, standards haa not
been confirmed, and even if it were needed at start.up, we believe that it Will not be
needed as part of Iha long term remedy. This Is a major design Issue r~nlzed by tha ·
MDSG; wn1cn 1s concerned that a complex system to Clesign, install and operate woulCI De
found to b& unneoo&Bary shortly after startup (I.e. weeks, months)-,
RMT, Inc. has determined that treatment of low concentrations of manganese requires the
uau gf '-li!talytlc or Ion exchan9e media, both of which are v1:1ry complicated to Install and
operate. For long•term treatment, a cetalytic precipitation process. such as the Burgess
Iron Removal Medium (131RM), may be the only option that will com1l11tently achieve the
maneanese Performance Standeird. Using thle proceS8 wlll take manganese from one .
medium, the ground water, and put it in another, as a solid to be buried in a landfill. The
manganese that would be removed Is a natural part of the aquifer matrix and Will return to
ite original form es the. organic contaminant& are removed from the aquifer. Once
extracted, manganese sludge will have to be thlcKened with polymer additives, partially
dried via filter or belt press, and shipped to a Subtitle D landfill. The concept of removing
man9arn1se from a very localized area or tile site iiJroundWatttr and transporting thtt
dewatered manganese sludge to an off-site landfill conflicts with the stated pr&fl'lrene&tl
found In the National Contingency Plan (NCP) for on-site treatment and/or destruction of
contaminants over off-site transport and disposal.
AS noted In u.s. EPA comments on the Intermediate Remedial Design, it i~ry likely that
concentrations of naturally o~rring mangunese are a re11ult of localized geochemlcal
conc1111ons located In the Upper Macon area. Manganese concentrations appear to be
lnver11ely proportional to dissolved oxy9en concentrations in 9round water where VOC
concentrations are greatest Extraction of ground water In 1tll11 area eventually le expected
to have a beneficial effect on manganese concentration, as the VOC concentrations
decreaae and as the _oxygen levels increase. Therefore, manganese concanlralloruJ aro
expected to decrease es en Indirect result of ground water extraction.
Manganese ooncentralion& are also expeuted to decrease through the treatment of
extracted ground water a1 II is aerated In the air stripper. Dissolved manganeBG Is
S!WI><l'.lW 30 WdEt, ;S0 ~. 82 El3,l
Ms. Giez;elle Bennett
February 28, 1995
Page 3 of3
09: 14 EPA REGION IV IJ'1STE MGT PROGRAMS 003 •
expected to react to some extant to form Insoluble manganese dioxide dur,.,,.U,ls process.
A bag. filter located In the dischar(ile llne from the air stripper Will capture soma Of the
particulate manganese. More will eventually pn1eipitate out over time as the aerated water
percolmtes back throufilh the aquifer from the Infiltration gedlery.
For all of the above-noted reasons, thEl MDSG Is requesting U.S. EPA to reconsider the
manganese treatmetnt requirement for the upper Macon area. Approval is requested to
allow the discharge of water (extracted from the Upper Macon source area) tc an
infiltration 9alhny al'ter treatment via the currently proposed air stripper system. Thia
Infiltration gallery wlll be stratagieally located upgradlent of the Upper Macon extraclion
well 11y3tem. In thi• way, water will be extracted from the Upper Macon source area,
treated through the air strlpper/bai;i filter system end discharged (at lowar mangenese
oonoenlretlons) to an inflltration gallery which will t>e located In an appropriate manm,r to
Insure that the reintroduced groundwater-will be recaptured by the proposed exlrectlon
system. We anticipate !hat the location of the infiltration gallery may require some
adjustment from lhal shown in the conCj!ptual design drawings to aocompllSh this objective.
'l"hls also may require 11ome groundwater modeling efforts to aocomplish thia objective.
The net ('El8UII of this change In the design will be a gradual low&ring of meriganose
concentrations in the Upper Macon source area groundwater and the pllientlon Of any
potential migration awa.y from Un, current Upplilr Macon source area looalions. These
r&11utta wlll be obtained through a greally slmpllfled ano ea11lly maintainable air stripping
system which wlll not be encumbered with great difficulty to operate due to unrellable
oetelytlc or Ion exchange el;Jl.lipmcmt.
We would sincer'$ly appreolate your serous oonsideretion of thla. Group proposal and look
forward to your response !ill your earnest convenience. PIE11:u1e conlsct me at
[phone] or Wayne Barto/Bruce ThompEion at [phone] If you have any
que&lion&. Thank you for your continued assistance on the project.
Sincerely,
/Pz_~-
(-'.,a. Kemy Gulledge
Project Coordinator
WB~a ,
cc: Maoon/Dockery Group Members
Wayne Barto, do maximla, Irie.
Paul Furtick, RMT, Inc.
l>,'7 • d
-
Fllafl!Ollltllll3088b\Soum.lr
SIWI)(tjW :;ra Wdl>'7 :S0 se;, 8Z 83.:1
• P. 0. llox 18778
Oreen\lllle, S. C. 295()6
Phone: [phone]
FAX: [phone]
Name(a) of Recipient(•)
Ma. Glezetle Bennett
Recipient'• Company Name:
US EPA -Region IV
Recipient Fex #:
[phone]
• RECEIVED
NOV 7 1994
I
FAX TRANSMITTAL
~VER SHEET
Name of S~nder: Paul Furtick
Date: Septe1Rlla, 14, 1114 ('l.111Mbw 3, (4'14-
Project Name: Macon/Dockery Site RO/RA
Project No.: 70017.22-2/
Number of Pagea (Including this page):
37
Sorry for the delay. Attached are the Macon/Dockery Site Group's original reponses 10 US EPA comments
on the Intermediate Design submittal, with italicized notes after each response indicating where and/or
how the text was revised to incorporate the comment/response. Please call Wayn~o (615/691-5052)
or me (803/281-0030) if you have any questions.
• •
INTERMEDIATE REMEDIAL DESIGN AEPORT COMMENTS
GENERAL COMME'NTS
1. ThroughoUI the report there are references to Appendices and material found In the
Prellmlnary Design Repon, as well as references to the response letter to EPA's
comments. The Flnal AD Report should be Inclusive of the all previous reports.
Therefore, any material referenced In that report should be physically Included In the
final report. Likewise, the final RD documents should also be "stand alo~ lncludlng
actual Information and not Just references to the previous RD dOCtJments.
The Macon/Dockery Site Group's (MDSG's) Final Design report and other required submitlals
will be inclusive of all previous reports and will be "stand alone." However. as discussed at our
February 16, 1994 meeting, we would prefer to submit the Prefinal Design report with the
appropriate references to appendices but without including the actual appendices in the
document. MY appendix material not previously submitted will be Included with the Prefinal
Design report review. The previously submitted appendices will then be inserted and
resubmitted with the Final Design report. It is our understanding that US EPA is in agreement
with this approach. ·
[As indicated, only new appendix material was submitted with the Prefina/ Design.}
2. WIii the pumping of Macon wells coincide with the use of SVE' treatment? Do these
wells have a large enough Influence on the water table near lhe SVE wells to benellclally
reduce upswelllng of the water table for a vacuum In the vadose zone?
Ground water recovery wells as proposed in the Intermediate Design are sufficiently distant
from the SVE wells so that there will be no influence on the water table at the SVE location.
The projected radius of influence of the Upper Macon area extraction wells is anticipated to be
only 20 to 50 feet. The SVE system will be located approximately 500 feet upgradient from the
proposed line Of extraction wells. The operation of the SVE extraction wells is not e~pected to
produce upswelling of any signtticance that will intertere with system operatio~
(No changes were made to the text for this comment.]
3. For the sake of continuity there should be a discussion In these RD documents on who
will operate and maintain the treatment syatems and the acqulsttlon of that O & M
contractor.
The Prefinal Design rePort will include a discussion regarding the method and schedule for
selection of the O&M contractor.
[The fourth full paragraph on p. 3-24 was added to address this comment.}
4. It should be confirmed that the design documents wlll be "stamped" and signed by an
appropriately qualified Professional Engineer that Is registered In the State of North
Carolina.
The Final Design report and other required documents will be stamped and signed a_s required.
{No changes were made to the text for this comment.}
1.,WP\7fJl.7001 71 /,RES/«lkM
• •
SPECIFIC COMMENTS
1.
2.
3.
4.
Page 1-11 sectlQn 1.1 <Background): For completeness, 11 discussion of who the RPs are
should be Included.
Information describing the potentially responsible parties is included in numerous other public
record documents, including the Unilateral Administrative Order (UAO). Since tt has no bearing
on the engineering design, MDSG disagrees with the need to Include this information In the
design reports.
{No changes were made to the text for this comment.]
Page 1-1 1 Paragraph 4 -The performance standard for lagoon 10 should also be given.
The following text will be added to the end of the referenced paragraph:
"In addition to the required vessel removal activities, the Statement of Work requires removal
and treatment of Lagoon 10 wastes and affected soil lo achieve a 2 ppm Performance
Standard for total carcinogenic polynuclear aromatic hydrocarbons (cPAHs). ~ecord of
Decision anticipated that ex-situ bioremediatlon of Lagoon 10 wastes could achieve the
Pertormance Standard. and the Statement of Work required a Treatabiltty Study to demonstrate
the feasibility of bioremediatiOn."
[The performance standard for Lagoon 1 O was added to the last para.graph on p. 1-1.J
Page 1-21 Pan1gr11ph 2 -As stated previously, the only documen1 that wlll be approved Is
the flnal RD repon.
The comment is noted.
{No changes were made to the text for this comment.]
Page 2-5, Paragraph 3 -As stated In previous comments, estimating the extent of
contamination using a quanthatlon llmlt above tho performance standards Is ridiculous.
This paragraph should be rewritten to Include a discussion of the OBVIOUS llmllatlons
of using this field screening data. In the response to comments, please Include the new
language.
The following will be inserted after the first sentence of paragraph 3 on page 2•5:
[Note: The reporting limits for both field screening and laboratory confirmation analyses are
greater than the Pertormanca Standards for several of the volatile organic an .. s. Analytical
methods capable of measuring some of the concentrations set forth in the Performance
Standards do not exist. The extent of impacted ground water cannot be determined to the level
of Performance Standards for all analytes. Therefore, the extent of impacted ground water
above tho Performance Standards must be estimated.]
[The proposed t11Jtt was inserted at the top of p. 2-I 5.J
Page 2~, Tables -Thaso tablas clearly do not contain a summary of all data that was
collected. Aa stated above, the llnal RD must be complete, and contain all RD field work
results. Also, pleaso Indicate which samples are field screening samples, and which
1-'WP-.70\7001717. RES1~ 2
6.
7.
e.
9.
•
were sent to the laboratory.
The title of Table 2-1 will be changed to:
SUMMARY OF ANALYTICAL RESULTS OF MACON/DOCKERY
COMPARISON OF GROUND WATER FIELD SCREENING AND CO~MATION
SAMPLES (1993) · .
The complete summary table of field screening results was submitted as Appendix G In the
Preliminary Remedial Design Report. This table was not included In the Intermediate Remedial
Design Report, but will be included in the Final Remedial Design Report.
A footnote will be added to the table to distinguish field and laboratory analyses. This footnote
will be _consistent with Paragraph 1, page 2-3.
(The title of Table 2-1 was r11vised as indicated. The complete summary table of field screening
results will be Included as Appendix Fin the Final Design report. A footnote was added to
Tables 2-1 through 2-5 describing how th& sample nomenclature distinguishes between field
and laboratory samples.)
Page 2-26. and Plates 3 and 4 . The monitoring well data should also be Included on
these maps to show extent of ground water contamination.
Constituent concentrations at monitoring wells have been added to the plates for submtttal wtth
the Prefinal Design Aeport.
{Monitoring well data is now shown on Plates 3 and 4.J
Page 2-40. Paragraph 5 -As stated In previous comments, remediation "'l,l,lbl}ot be
complete .until the levels of TOTAL tnorganlcs Is b9low the per1ormance levels. This
needs to be Indicated.
The following sentence will be added at the end of the paragraph:
"The designed treatment system, however, will have sufficient capacity and capability to
address suspended solids as well as dissolVed Inorganic constituents."
[The revised text now appears at the bottom of p. 2-46.J
Section 2.4.2. Paragraph 3 • Include a sentenc9 explalnlng why PCE was selected as the
organic contaminant for soll vapor analysts.
The following sentence will be added:
"PCE was selected as the organic conslijuent of concern because PCE was the only organic
compound identttied in subsurface soils at Lagoon 7 during the RI/FS and in the selActed
remedy in the ROD which requires remediation to a specttied Performance Standard."
[Addressed in the SVE Final Design Report, June 1994.J
Page 2-61. Section 2.4.3 (SVE Test Results -Air Emissions) & Page 3-30. Section 3.4.2
(Air Discharge): Despite the fllCt that the overall air emissions apparentt,,:rppoar to be
l:\WP\70\7001717.AESl<d104 3
• •
within regulation standards for "gross" numbers, wlll there be any cancer causing
compounds (besides tha PCE and vinyl chloride noted) among those emissions that
exceed Individual requirements? This should be discussed.
North Carolina Air pollution rules (15A NeAe 2D.1104) require permitting for thA emission of
toxic VOCs for any facillty whose actual emissions from all sources are greater than any one of
the emission rates listed in 15A NeAe 2H.0600 (h). For tacillties emitting toxic voes in
quamltles less than the 2H.0600 regulation, the facility must register wtth the Slate.
The compounds listed In 2H.0600 were compared with estimated ground water compositions at
the Macon/Dockery Site, and projected worst case air emission rates for each of the three air
strippers were calculated. Tables 1, 2, and 3 summarize air stripper air emission rates for the
Macon, Upper Dockery and Lower Dockery air strippers, respectively. Table 4 shows the
combined projected worst case air stripper air emission rates. and Table 5 presems projected
worst case air emission rates from the Soil Vacuum Extraction Unit. '-'>
Table 6 shows the projected worst case air emission rates from all emission sources at the
Macon/Dockery Site. All of these are below the thresholds for individual air toxics .regulated by
the State, and, therefore, no pennlt for discharge Is required. The largest actual e•mission rates
were calculated at 60.2 pounds per year of tetrachloroethene (PCE), 2.56 pounds per year of
trichloroethene (TCE), 0.0853 pounds per day of xylenes, and 0.00268 pounds per day ot
toluene. These values were derived by exirapolating start-up conditions over the entire year.
The predominant source of these air emissions is the SVE untt. The highest emissions from
the SVE unit will occur at start-up and then taper off to low asymptotic levels. The other voes
are several orders of magnitude less than the threshold values and will not approach the
threshold values during the l~e of the project.
I.\Wf'\7°'7001717.f'ICSladfa4 4
TABLE 1 WORST CA&EAIR -RATES MACON AIR STRIPPER NFLUENT
POUNDS PER 15 IIINUTE POUNDS PER DAY POUNDS PER YEAR
eom-d Flow ••ftml Ccnc. 1uon1 A<:lual Threshold Acillal T1119lllold Ac1ual Threshold
Benzene 48 0.52 3.26e-06 NV 3.138-04 NV 1.14e-01 8.1
T etrachloroethen e 48 I .90 1.19e-05 NV 1.14e-03 NV 4.17e-01 13000
Trichloroethane 48 6.30 3.95e-05 NV 3.798-00 NV 1.38e+OO 4000
Toluene 48 2.70 1.698-0:; 3.60 1.628-03 98 5.939--01 NV
Vinyl chloriie 48 0.00 0.00 NV 0.00 NV 0.00 26
Xylenes 48 5.90 3.70e-05 4.10 3.559-03 57 1.29e+OO NV •
TABLE 2 WORST CASE AIR EMISSION RATES
UPPER DOCKERY AIR STRIPPER INFLUENT
POUNDS PER 15 IIINUTE POUNDS PER l>A'I POUNDS PER YEAR
Compound F-(90"") Ccnc, lug.l) AclUal Thre.,hokl -"""•1 ThrNh~d .Ac!ual TllrNhold
Benzene 6 0.00 0.00 NV 0.00 NV 0,00 8.1
Tetrachloroethene 6 1.70 1.33e-06 NV 1.28e-04 NV 4.66e-02 13000
T rich loroet hene 6 2.50 1.96e-06 NV 1 .see-04 NV 6.869-02 4000
Taluene 6 2.00 1.57e-06 3.60 1 .50e-04 98 5.49e-02 NV
Vinyl c!,loricle 6 0.00 0.00 NV 0.00 NV 0.00 26
Xylenes 6 25.00 1.96e-05 4.10 t.BBe-03 57 6.868-01 NV
TABLE 3 WORST CASE AIR EUISSION RAT Es
LOWER DOCKER'I AIR STRIPPER INFLUENT
POUNDS PER 15 IINUTE POUNDS PER DAY POUNDS PER YEAR
Compound Flow (gpm) ecnc. (ugn! Aclual Tlvwshold Aclual Thruhold AclWll Thr-
Benzene 28 · 0.25 9.14e-07 NV 8.77e-05 NV 3.20e-02 s.1
T etrachloroefjten e 28 0.00 0.00 NV J 0.00 NV 0.00 13000
T richloroeth.D.e 28 1.25 4,579--06 NV b 4.38e-04 NV 1.60e-01 4000
Toluene 28 0.00 0.00 3,60 0,00 96 0.00 NV
Vinyl Chloride 28 0.00 0.00 NV □.DO NV 0,00 26
Xylenas 28 0.25 9.14e-07 4,10 8.778-05 57 3.20e-02 NV
NV -No Value Given
wpwin\projec:ts)7001721.33/Q'n94 5
•
-
TABLE4 COMBINtiD AIR STRIPPER WORSl·CAsE AJA EMISS.ON RATES
Pouncla per 15 mlnU1ea Pound• P• d,v Pound!I per year
comnound AC1ual · ThrMhold Ac111,t Threshold Actual Throohold
Benzene 4, 17E-6 NV 4,01 e-04 NV 1.46e-01 8.1
Tetrach/oroethene 1.32E-5 NV 1.27e-03 NV 4.64e-01 13000 ....
Trichloroethene 4.60E-5 NV 4.42e-03 NV 1.61 4000 .. ---
Toluene' 1 .B5E-5 3.60 1.77e-03 98 6.48e-01 NV
Vinvl chloride 0.00 NV 0.00 NV
.. f,I)
0.00 26 ·-
Xylene& 5.75E-5 4.10 5.52e-03 57 2.01 NV
•. . .. ---. -
TABLE s 6VE UNIT WORST CASE AIR EMISSION RAT"8
Pound• Der 1$ mlnutas Pounda per day Pounds pw year
com-und Actual ThnInold Aotual Th....,hokl AC1uol ·Thruhold
Benzene 1.10E-7 NV 1.0SE-5 NV 3.B7E•3 8.1
T etre.chloroethene 1.7E-3 NV 1.SSE-1 NV 60.2 13000
Triehloroe1hene 2.71E-6 NV 2.6E-4 NV 9.49E-1 4000
Tolueno 9.42E-6 3.60 9.04E-4 98 3.30E-1 NV
V/nv/ chloride 0.00 NV 0.00 NV 0.00 26
XvlenGS 8.313E-4 4.10 7.98E-2 57 29.12 NV
TABLE 6 MACON/DOCKl'i!.RY SITl'i!. WOA9T CAS& AIR &MISSION AATES
Pound• Der 15 minute& Pound• uu-cf.av ~ound• p.,. yMr
Comoound AcU.1,al Thrnhotd AeW•I ThrMhold Actuol Thr .. nold
Benzene 4.28E-6 NV 4.1 E-4 NV 1.50E-1
.....,
8.1
T e1rach/oroethen& 1.71E-3 NV 1.85E·1 NV 60.6 1300
Trichloroethene 4.87E·5 NV t.75E-2 NV 2.56 4000
Toluene 2.79E-5 3.60 2.68E-3 98 9.78E-1 NV
Vi=/ chloride 0.00 NV 0.00 NV 0.00 26
Xylenes 8.89E-4 4.10 8.53E-2 57 31.14 NV
NV -No Value Given
{These t.ab/Gs were not incorporated in the r~P._Ot1, but this information will be available to future reviewers. This document
(Agency comments and Group responses) w1// be included in Appendix R of the Final Design Report./
wpwin\projeclRJ?OO 1721.3-3/dm;,4 6
•
10. Page 2-68, Blodegradatlon Section. In all probablllty, the ROO wlll be amended to
change the remediation ol the Lagoon 10 materials from blodegradatlon to off-she
disposal. However, the RD should discuss the treatablllty study, why It felled In hs goal
to reach the performance l&vels, and why bloremedlatlon wlll not work here atthls she.
However, the comments made In the pre11m1nary design should be Incorporated Into this
discussion. Therefore, If this document Is read later, and some of the same questions
_and comments arise, the discussion here wm address those. For questions such as
stirring or addhlon of various substences at various times, simply state that these
questions have arisen. Please do not try to fix It up or Justify what was done. EPA
clearly could have required the test to be redone.
11.
12.
13.
14.
The RO will be amended to incorporate the comments made about the treatabillty study during
the preliminary design phase, In addition, the RD will be amended to discuss the resampling
effort, results, and evaluation ol why bioremediation will not worl< at this site.
{Section 2.5 of the Intermediate Design report was replaced with Section 2.5 of the Preliminary
Design report, and the Agency's ccmmonts on the Preliminary Design report we/'9 incorporated.
The following paragraphs in Section 2.5 (renamed Section 2.4 In the Prefinal Design reporl)
were revised: Phrase regarding degrees of variability added to last sentence before Section
2.4. 1 (p.2-55). Sentence added to end of 3rd paragraph of Section 2.4. 1 (p. w;. Revised
last sentence before Section 2.4.3 (p. 2-58). Paragraph added at end of Nutr/anal Analysis in
Section 2.4.4 (p.2-61). Last paragraph on p. 2-62 was revised to address comments on SOS
addition. First paragraph on p. 2-64 rBvised to address commr,nts on air flow in reactors.
Three sentences added at end of 1st paragraph on p. 2-67. Sentenc9 added at end of 2nd
paragraph on p. 2-67, Paragraph describing pH ccntrol added alter 1st paragraph on p. 2-70.
Section•2.4.5, 151 paragraph (p. 2-71) revised to describe potential questions arising from study
conditions.]
Page 2-79, First line -A word Is missing In this sentence.
The text will be corrected by inserting '1hat" after "maintained conditions.·
{No longer applicable.]
Page 2-81, Paragraph 2 -Delete the last Une.
The referenced sentence will be deleted.
(The referenced sentence made it through our edits. It will be deleted in the final design
report.]
Page 2-92, Paragraph 2.8.4 -Please explain the use ol the term "compliance monitoring
point," _,
The term "compliance mon~oring point" describes a monitoring well location at which the
success of ground water containment and/or remediation will be evaluated.
{No changes were made to the text for this commtmt.]
On page 2-961 Section 2.9.2 of that repol1, there ls the statement "II Is anticipated that
manganese concentrations In extracted ground waler wlll already be below the
wpwin\pr<>jects)7001721,33/dm94 7
15.
16.
• •
Performance Standard, all Indicated by.the MW21 sample results." Tha position ot
MW21 relative to Identified contaminant source areas (comparison of Plate 1 to Figure 1.
21, as well a, the analytical results tor the sample from MW21 In Table 2·36, Indicate that
this well ls located well downgradlent of the most hlghly contaminated ground water.
While the statement about manganese concentrations In extracted ground water, relallve
to the Per1onnance Standard, may be correct, consideration of the MW21 sample Is not
appropriate for making such an argument. Therefore, this statement sho\'dl!>elther be
removed or r11wort1ed. This concern Is discussed In greater detail below.
Manganese concentrations in ground water immediately beyond the source areas have been
shown to be below the Performance Standard. These concentrations are though! to be
representative of typical manganese levels anticipated in ground water extracted at the
periphery of the plumes. The sample collected at MW21 confirms that manganese levels
beyond the source area are likely to meet the Performance Standard without treatment. The
referenced sen1ence will be revised as follows:
"It Is anticipated that manganese concentrations In extracted ground water will be be!Qw the
Performance Standard, as indicated by sample results for wells outside of the source areas and
oonfirmed by the MW21 sample resutts." ·
[Revised first full sentence on p. 2-88.)
Page 2-108 -Delete the last four semences of this paragraph. EPA will make the final
decision on the remediation of theu wastes.
The last four sentences will be deleted.
{Sentences were deleted from fast paragraph on p.2· 100, and new text added on following
page to discuss ROD amendment and waste removal activities.} -Section 3 (lntennedlate Design) & Drawings C04 & C05 overall!: The dOcument author
should confirm thet the following will be addressed In the next level of the RD:
Since they form the basis of the system design and operation methods, a
discussion of the systems' control philosophy and lnfonnatlon on alarms,
controls, and panel, automation, automatic analysis and system feedback,
Interconnections, etc. should be Included. This Information Is not avallable on
the Process Flow Diagrams, although at this stage of the RD these drawings
should be all but tlnalb:ed, as Is normal Industry standards, and represent a true
Process and Instrumentation Diagram (P&ID).
Normal Industry practice Is to provide an overall "!allure type" analysls Indicating
the need (or lack of need) for backup units and the consequences of
failure/shutdown of the system.
In the Prefinal Design submittal, Drawing C04 will be replaced with separate P&IDs tor thA
Macon and the Dockery systems, A control narrative and a "failure analysis" will also be
included.
[Separate P&/Ds shown on drawings K01, K02, and K03. The O&M Plan and the Prefinal
Design report contain a Process Controls Narrative in th9 appendices. The O&M Plan contains
a fa/lure analysis.] _,
wpwinlp,ojeet>)7001721,S31dm94 8
17.
18.
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Page 3-4. Section 3.1.1, (Ground Water Recovery and Treatment systems), focusing on
Metals Removal:
The next design submtttal should make the detennlnatlon of whether to
regenerate (on-site or off-site) or to replace the resin.
The ion exchange resin will be regenerated off-site by a subcontractor. The
subcontractor will either rem:ive the exhausted resin from the vessel and replace the
resin on-site or replace the entire vessel and Its contents.
[The seccnd paragraph on p. 3-5 was revised to address resin regeneration.]
There should be a discussion on why such a comparatlvely shon (3,5 days)
capacity was provided for the metals removal units. This discussion should
Include the 11111ount of time required to have theso units regenerated off-or on.
site. _,
The relatively short service life capacity provided for the metals removal unijs is
determined by the projected short-term service requlremenls during start-Lip. Standard
36-inch diameter vessels with a resin capacity of 30 cubic feet each were used. The
3,5-day service IHe was calculated using a nominal flow rate of 50 gpm for the Macon
Site treatment system and a dissolved metals removal ol 60 mg/L (mostly hardness)
across the ion exchange system. The length ol calculated service IHe will increase at
the lower flow rates anticipated for Upper Dockery and Lower Dockery. Larger columns
are available at considerably greater expense. However, it is anlicipated that
elimination of the metals removal units soon after start-up will be indicated, as it is
projected that manganese concentrations will meet the Pertormance Standards without
treatment. If extracted ground water exceeds Performance Standard for manganese
afler startup, the alternative metals removal system. which utilizes a different medium,
will be i0'4)Iemented to achieve longer service lives tor the columns.
{This paragraph was inserted at the end of Section 3.1.1 (p, 3-5).J
Page 3-4. Section 3.1.2. Soll Vapor E><tractlon System: Within this section, reference
appropriate drawings and discuss the wells' radius of Influence.
The following teX1 will be added to page 3-4, Sections 3.1.2.
"Using the 0.4 isobar line as the extent of the maximum practical radius of infl~e. the pilot
test results indicate that the SVE wells' radii of influence are variable, with the greatest radii cl
influence being 50 feet and extending to the northeast and southwest. The shortest radii of
influence are 20 feet and extend to the east. Figure 2-6 shows the radius of influence tor VE-
1."
[Addressed in the SVEi Final Design Report, June 1994.J
19. Page 3-9. under Section 3.2.1 /Volume of Ground Water Requiring Treatment)~ Since It
appears that the actual number 01 pore volumes of ground water needing pumping and
treatment will exceed the theoretlcal volume ol contaminated water, there should be a
discussion on how these volumee were calculated.
The text will be revised as follows:
wpwin\prc;ijvets)7001721.33Jdm94 9
20.
•
"The volume ot ground water requiring treatment is defined by the horizontal and vertical extent
of lhe affecied ground water plumes. A single pore volume ot ground water exceeding
Performance Standards is calculated to be 108 million gallons. This volume ~iculated
assuming a saturated thickness of 45 feet and a porosity o1 0.25 for the aqutter, and measuring
the areal extent of ground water exceeding the Performance Standard on all four areas of the
Site. The area of the affected ground water plume at each portion ol the site is as follows:
Upper Macon, 790,000 square teat; Lower Macon. 255,000 square feet; Upper Dockery.
161,000 square feet; Lower Dockery, 80,000 square feet.
Because ot sorptlon and re1ardation of the constituents present In the ground water.
remediation of the ground waler will require the removal ot multiple pore volumes of water from
the aqutter. Thus, the actual volume of water lo be pumped is expected to be greater than one
calculated pore volume of ground water."
[These two paragraphs were substituted for the original paragraph under Volume of Ground
Wator R«tUlrlng Trsatm9nt (p. 3•8).]
Page 3-9 et al, under Section 3.2.1 {Treatment SCheme) and Drawing COS:
Elevated manganese concentrations 9!!l have an adverse effect on treatment
equipment, such as air strippers. The document (and the 10/15/93 MDSG
responHS) Indicated that manganuso truatment wlll not be lne1alled prior to the
air stripper. Please discuss the potential for adverse effects on the air stripper
by manganese In the stripper Influent and why the treatment Is not Indicated
prior to the stripper. Also Include In thts discussion: what are t~ndor
Influent requirements for the use of the shallow-try air strippers; what provisions
have been Included In the process for periodic cleaning of the stripper? (These
hsd also been commented on In EPA's 9123/93 letter, comment #27).
The air strippers chosen for the Macon/Dockery s~e are low profile tray air strippers. Somo of
the advantages of low profile tray air strippers over random packed tower air strippers include:
Tray air strippers are shon. With a maximum height of 6 feet. tt is feasible to provide a
gravity flow feed lo the unit.
As tho name implies, tray air strippers are constructed ot several trays. These trays
are stacked one on top of the other and can be easily disassembled tor inspection and
maintenance.
The bottom of each tray is perforated and is called a sieve plate. Air flows upward
through each sieve plate and through the water on top of each plate. The size of the
holes in the sieve tray are relatively large (318-inch) but the upward air movement
keeps the water from weeping through the holes . short lengths of pipe, called
downcomers, are provided to allow the water to cascade downward from tray to tray.
This Internal arrangement encourages sediment and precipitants to be washed through
the unit, as opposed to tho random packed tower air stripper which tends to colleci
sediment and precipttants over time. The vendor recommends pretrea1ment of the air
stripper's Influent tt: _,
total hardness exceeds 250 mg/I
dissolved iron exceeds 25 mg/I
wpwinlptojecml7001721.93/dm04 10
----------------------·· • •
dissolved manganese exceeds 25 mg/I
For Influent conditions less than the value stated above, any potential fouling Is best
addressed through system maintenance. The plume containment system currently
incorporated in the Remedial Design is not expected to exceed the criteria described
above for pretreatment. However, It the results of the Anaerobic Bioremediation PIiot
Study indicate that enhanced bioremediation of source-area ground water is not
feasible, Installation of extraction wells in these areas will be proposed. In this case.
pretreatmem of either the isolated source area Influent stream(s) or the entire Influent
stroam to each treatment unit will be evaluated and, ~ needed, incorporated in the
Prellnal Design.
Tho internal arrangement of the tray air stripper allows for variable inti~ fl~w from 0
gallons per minute to the unit's rated maximum capacity. At lower flow rates the
retention time of the water on the sieve plate actually increases. so that removal
efficiencies will increase.
At the Macon Site, the tray air stripper's influent stream is provided by gravity overflow from the
two feed tanks T1 and T2. Treatment is not indicated prior to the air stripper, since anticipated
influent hardness, manganese and iron levels are below the maximum acceptable levels given
by the vendor. The following table summarizes the results of ground water sampling from MW-
09 (worse case) and vendor requirements.
INORGANIC ANALYSIS
Total hardness 42 250
b1ssolv8d Iron 25
Dissolved manganese 1.1 25
At the Upper and Lower Dockery sttes, electric submersible pumps in each r~ry well will
pump ground water to the air stripper. Manganese removal is not considered a necessary pre•
treatment step for the air strippers, since anticipated influent condttions are less than the
maximum acceptable levels.
Adverse effects of air stripper fouling, tt it should occur, are minimized by the tray design.
Severe affects may include an increase in pressure drop throughout the system, which could
reduce the maximum rated capactty of the system and increase the load on the air stripper's
fan motor.
Drawing Number 7001714-C0S shows a pressure indicator at each air stripper sump for
measuring pressure drop In the untt. Provisions for periodic Inspection and, tt required,
cleaning of the air strippers will be included in the Operation and Maintenance Manual and will
include detailed instructions for disassembly, cleaning and reassembly.
[These paragraphs were ac/ded to the text, beginning on p. 3-10.)
wpwin'4)rojocto)7001721.33/dm9-4 11
21.
• •
To provide equallzatlon (steady state air atrfpper Influent flow, process control
and sufficient head tor moving the Influent to the air stripper) were feed tanks
(with appropriate discharge pumping) evaluated for tho two Dockery systems?
There should be lnclUded a discussion on why these tanks were only Included at
the Macon Site.
As discussed previously, the tray air strippers do not require a constant flow rate. The
submersible well pumps at the Upper Dockery and Lower Dockery Sttes have been sized to
provide the required head to deliver the ground water from the recovery wells to the inlet of the
air stripper. Equalization tanks are therefore not required at the Dockery sites.
At the Macon Site, a jet pump system is used to recover ground water. This system requires
feed tanks T1 and T2 as a source of water for pumps P-100 and P-200. It is the gravtty
over1Iow of ground water from T1 and T2 that is directed to the inlet of the air stripper.
A~hough the feed tanks are primarily included as water sources tor the recirculation pumps,
they will also provide an "equaliiation effect" and a more-or-less steady-state flow to the air
stripper.
{Tanks havs been added to the treatment scheme at each site.}
Page 3-10, Paragraph 2 -The emissions from both the air stripper and the SVE wlll have
to be monitored. EPA cannot exclusively rely on modelling lnformatlon.we.;iddltlon, air
monitoring should be dona at the perimeter of the site to ensure that the public Is not
being advensely affected.
Sampling ports consisting ol copper tubing, a needle valve, and brass compression ftttings will
be added to the air strippers and SVE discharge stacks. The copper tubing will enter the stack
through the sidewall and will have a 90 degree tum facing downward so that air flowing through
the stack :'{Ill enter the copper tube.
Al startup, the air strippers and the SVE unit will be monitored by sampling the discharge
stacks.
For the air strippers, the analytical resutts will be compared with the results of ground water
analysis and mass balance calculations, and will be used to verify modeling assumptions.
During the first month of operation, if the weekly analytical results verily the mass balance
calculations based on influent and effluent water quality data, then mass balance calculations
will be used thereafter to monitor air stripper emissions.
Direct sampling using adsorbing charcoal tubes and laboratory analysis of lhe SVE unit
emissions will continue on a quarterly basis after start up. Sampling from SVE well heads will
occur at 6-month Intervals.
Air-monitoring using adsorbing charcoal tubes and laboratory analysis will be conducted at the
Macon property line during the first week of start up, since this is when the hi~
concentrations are potentially recovered. Based on preliminary modeling results, ii is not
expected that any constituents will be detected at the property line. The resutts of the initial
property line monitoring will be correlated with air stripper and SVE emission monitoring data.
If fulure emission monitoring events for the air stripper and SVE systems indicate a substantial
increase in emissions, then the necessity for additional property line monitoring will be
evaluated.
wpwin\proj<>et,)700, 721 .33/dm94 12
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[This text was added after the 1st paragraph on p. 3-12.)
22. Pago 3-131 under Section 3.2.1 (Roeovery Well 0$slgn): What criteria will be used for
slot-size selectlon, In comparison to grain size distribution, and how wlll that be related
to required well flow? Why Is PVC being proposed for the recovery wells?
Grain size distributions of the aqutter lormation materials will be used as a guide for selecting
appropriate filter pack and well screen slot sizes for use in the recovery wells. Generally, a
tilter pack is selected to retain most of the formation material, and the well scr~openlng is
selected to retain about 90 percent of the filter pack after development. For recovery well
UMRW01, a screen slot opening of 0.010 inches was used successfully, and~ is anticipated
that the proposed recovery wells will be constructed with similar screen openings. The fitter
pack and screen slot sizes will be selected so as not to inhibit the yield at each well.
PVC Is proposed for the recovery wells since these wells are not proposed for compliance
and/or ground water qualijy monitoring. PVC Is as reliable and effective a material and is also
more cost-effective than stainless steel. The concentrations ol chlorinated organic compounds
previously detected on-s~e do not require the use of special materials, even for so1,1rce area
wells.
[This /11xt was inse,ted as the 1st and 2nd paragraphs on p. 3-16.)
23. Page 3-161 under Section a.2.1 (Centrllugal Pumps}, also epec 1151 o: There should be a
discussion on how the pump discharge flow will be varied based on system
requirements, Le. wlll the pump be throttled back or wm It come on/off In response lo
levels In either upstream or downstream tanks, etc?
24.
25.
Centr~ugal pump discharge flow rate will not be throttled. The pump will come on/off in
response )0 levels in the feed tank; however, the system is designed so that the level in the
feei;I tank is static, and the pump should therefore operate continuously at a constant discharge
rate. A control narrative will be Included in the Prefinal Design submlt1al to dW'Jl'Tll
operations.
[Text added as last item on p. 3-19. A Process Comro/s Narrative was added as Appendix Q.J
Page 3-16. under Section 3.2.1 (Tanks}, also Orawlng C12: Please Indicate llthese are
"backwash" tanks or tankage to allow regeneration of the magnesium metal removal Ion
material.
Backwash tanks and facilities associated with a backwash system have not been included in
previous submlt1als because they are not required for the Ion exchange system. In the Prefinal
Design. a backwash system and a different treatment medium will be included as an alternative
installation tt the anaerobic bioremediation of source area ground water contaminants proves to
be infeasible and extraction of ground water in this area becomes necessary.
{Text added to 4th bullet under Tanks.]
Page 3-17. under Section 3.2,1 (Metals Removal Columns): Previous response #31 In the
MDSG 10/15/93 letter lndlca1ed that the text would be revised to Indicate that each
column wlll be valved to allow operation when one column ls removed. This test
rev1a1on shou1<1 be made.
wpwinlprojects)7001721.33/dm04 13 -
• •
The following statement will be added to page 3-17, under Section 3.2.1 (Metals Removal
Columns)
• The columns will be provided with isolation valves and associated piping to allow
continuous system operation when one column is removed for servicing.
[Text added as 2nd bullet on p. 3-21.J
26. Page 3-18, under Section 3-2.1 (Shallow Tray Air Stripping Until:
• As discussed elsewhere, provisions should be provided to allow cieanlng of the stripper.
Provisions for cleaning the air stripper include:
Specttications for a tray air stripper that can be readily disassembled and
reassembled. """"
Two cleaning ports per tray
A wash wand to Insert through the cleaning ports to wash the trays
A pressure indicator to mon~or internal pressure
Detailed instructions for disassembly, cleaning, and reassembly in the O&M
Manual.
{Text added as 6th bullet on p. 3·22./
• Provisions for varying blower outlet air flow rates (soch as belt drive or
adjustable dampers) to allow for optimizing the system should be Included.
There is no need to vary blower outlet air flow rates. The blowerand blower motor have been sized to provide the amount ot air required to strip the maximum projected VOC concentrations
from the water.
{No changes wer9 mad9 to the text for this comment./
27. Page 3-28 Section 3.4 (Plan for Satisfying Permitting Ragulraments): How wlll permits be addressed for stonn water and erosion control, especially during constnk9lln? Also, how will parmlts be handled for drllllng of any wells, building permits, Ille.?
Compliance with the substantive permitting requirements for storm water, erosion control, and
system installation will be perfomied by the construction contractor. The design drawings will include design features addressing these needs for use in obtaining these permits. However,
since this site is a CERCLA response action, actual permits are not required. The construction
contractor will supply the necessary information to permitting agencies to meet the substantive requirements for permits and will consutt with these agencies as necessary,
{Text add9d as 3rd lull paragraph on p. 3-25.J
wpwin~rojecta)1oo1721.S31dm84 14
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28. Page 3-29 -There IS no discussion In this report on the Int11tratlon pits; rationale tor their
respective elzes and placements; exactly how they work, etc. Other questions arise on
the· specHlc uses of the well pits and diversion trenches. This needs to ~lear In the
report.
Discussions on the design of the infiltration galleries will be included in the Pretinal Design.
[T6xl addi,d as t st full paragraph on p. 3-25.J
29. EPA has previously commented on the proposal In the Prellmlnary Design Report to
locate extraction wells near the down gradient margin of the area of ground water
comamlnallon. Those comments probably did not sufficiently express the range and
depth of coneorns about this type of remedial design. Therefore, these comme,:,ts
provide an expanded discussion of these concerns, as the Intermediate Work Plan
continues with the "lead Ing edge" design, and the response to EPA ·s comment number
26 on the Preliminary Design Report does not fully address this Issue.
By making the recovery well system entirely a plume comalnment design, the Inherent
system efficiency, expressed In terms of contaminant mass removed per votume of
water extracted, Is minimized. Thus, II the volume of water removed by the pump and
treat operation per unit time Is fixed, regardle!ls of the location of the extraction wells,
the ground water remedial time frame should be longer (potentlally much longer) tor this
type of a design, compared to a design Incorporating ground water extraction closer to
the plume source, or center of mass of the plume.
After operation of such an Inefficient ground water remedial system tor 11.QWIOd of time,
It could appear that the ground water can elmply not be remedlated In a reasonable time
frame. This observation would probably result In a petition to EPA to consider the
ground water performance standards unattainable. Such a scenario le contemplated In
the Performance Standards Verification Plan, Section 3.3. A request for EPA Region IV
to make an "lmpractlcablllty determination" for this type of remedial design would be
denied. This dental would ensue because EPA Region IV would hav11 al1'8ady determined
that the remedial design would be Inefficient lot attaining remedial goals. Legitimate
"lmpractlcablllty" must be based on uncontrollable site conditions, rather than
controllable racovary wall daslgn. Thus, In order to evaluate or demonstrate technical
lmpractlcablllty of attaining ground water remediation goals, an efficient recovery well
design Is required.
As a secondary concern, locatlon ol recovery welle at the down gradient margin ol the
plume potentially has e component of contaminant dllutlon as a significant aspect of th8
system. This can most readlly be shown through a lalrty d9talled modeling analysis.
Such an analysts would be a substantial, unnecessary effort In the context of the
secondary degree of concern we have about this situation. However, the dllutlon or
spreading of contaminants Into less contaminated areas should be avoided II possible In
a ground water remedial action.
Another related concern Is that the propoS&d 1'8medlal design wlll not effecllvely (or
perhaps even lneffectlvely) remedlate or otherwise affect the ground water manganese
problem over the areas where It Is most crltlcal. For example, ground w1lltCtl manganese
concentrations clearly exceed, by a factor of approximately 20 or more, the Pertonnance
Standards In samplas from several wells clo"" to the upper Macon organic contaminant
source areas (Table 2-7, analytical results !or MW05, MW09, and MW19). It Is very llkely
that the excessive concontratlons of this naturally occurring contaminant are a result ol
wpwinlp,oj""'t,,J700172I .M/dm94 15
• •
locallzGd gaochemlcal condlllons prevalllng near some of the old lagoons. Manganese
Is also Inherently less mobile In the subsurface environment, relative to the volatlle
organic compounds. Given these prevalllng conditions, the proposed recovery well
system wlll not deal with the most serious ground water manganese problems
effectlvely. It may have no measurable Influence on the manganese .concentrations.
Clearly, this situation Is Incompatible with the ground water remediation levels specified
In the Record of Decision for this site.
Arguments such as that In the section titled "Ground Water Treatment" on page 3-3 that
manganese le natu111lly occurring In ground water at such observed high levels are not
supported by available data. A comparison of dissolved manganese concentrations to
total volatile organic concentrations and dissolved oxygen concentrations (report Tables
2-7 through 211) Indicates a correlation between dlssolvGd manganese aWWJ'lese two
water quallty varlabl88 (Spaarman's rank colT8Iatlon coefficient Indicates statlatlcal
slgnHlcance at a __ of less than 0.02). The attached figure g111phlcslly shows the
relationship between dissolved manganese and total VOCs/dlssolved oxygen. This
figure essentially defines dissolved manganese (point values on the figure) by the other
two variables. This figure clearly shows that at low dissolved oxygen levels,-dlssolved
mangan888 concentrations Increase over background values. While the relationship
between dissolved manganese and total voes Is less obvious from 1he figure, most al
the samples with appreclabkl concentrations of total voes have obviously higher than
background concentrations al manganese. The correlations between these three
variables may Indicate that In the most highly contaminated ground water, some aerobic
blodegradatlon of organic compounds Is or has been occurring. Und8r these conditions,
the dissolved oxygen normally present In the ground water would be depleted. As a
consaquenco ot the lower ground water oxygen concentration, the equlllbrlum
concentration of manganese dlssolved In the ground water would be altered. The design
report st11189 on page 3-3 that " •.. It Is theorized that naturally occurring manganese may
be solublllzed by naturally occurring blologlcal aetlvtly In the source areas." The
Intended meaning at this statement may be the same as this manganese data
Interpretation presented In this paragraph. However, this statement Implies that the
dissolved manganese concentrations result from entirely naturally occurring processes.
EPA's conclusion Is that they do not.
To·summarlze, the proposed recovery well networl< wlll be less than optimally efficient
for ground water remediation. Some ground water contaminants may ~ captured by
the recovery wells at the down gradient plume margin. Other contaminants may require
long time periods before they are recovered. EPA strongly r&commends that this design
be modHled, to assure compliance with the ground water requirements specified In the
ROD, to Improve the efficiency ot the recovery well system, and to assure approval of
the llnal RD. The redesign should be done to supplement the containment action at the
down gradient margin ol the plume with additional recovery weI1s: located closer to
source areas and ground water "hot spots". This redesign wlll Improve efficiency and
reduce the time frame fOr ground water restoration, If It Is possible to attain that goal.
EPA's primary basis tor these statements made in Comment #29 is apparently a perception of
the Group's remedial design as entirely a plume containment design. In fact. the Group's
remedial strategy already combines source reduction with th11 containment aspects of the
remedy, and dc,es so by employing an Innovative, in-situ technology which promises to
slgnttlcantly outperform adding recovery wells close to the sources. The Group is currently
funding a study of this innovative technology with EPA approval: ii resuns are negative. the
Group intends to redesign with placement of extraction wells near the source areas.
wpwin\projecta)7001721.33/dm94 16
• • _,
It Is our understanding from the Group's meeting with EPA on February 16, 1994, that the
serious ooncems expressed by EPA, above, were Intended to address a design as sat out in
the Intermediate Design Document without considering the proposed source control by the
proposed ln--s/tu technology, or alternatively, source-recovery wells.
A more detailed response to issues raised In Comment #29 follows. In this response, each of
these concerns will be broken out of the original US EPA comment and addressed separately.
The reoovery well system is entirely a plume containment design and will thus
inefficiently remove contaminants of concern from source areas.
Contaminants will be spread into less contaminated areas down gradient of the
hotspots without the use ot source area recovery wells.
High manganese concentrations in ground water are not the resutt of naturally-
occurring subsurface conditions.
The proposed ground water recovery system will not affect areas showing high
dissolved manganese concentrations.
Each of these issues Is discussed below.
1. The recovery wen system Is entlrely a plume containment design end wlll thus
lnefftclently remove contaminants of concern from source areas.
The Record ot Decision for the Site spectties the ground water rem!ldy lo be ~raciion and
treatment. Like US EPA, the Group understands the inherent limitations of ground water pump
and treat technologies and has sought to e•plore all avenues by which the specHied remedy
can be most elleciively implemented. Design scenarios have indeed included consideration ot
source-area extraction wells to enhance mass removal of contaminants at the Site. However,
the Group has selected to explore, with lull ooncurrence by US EPA Region IV. the use of an
Innovative.in-situ technology recently developed by the E.I. duPont de Nemours & Co. Inc. -
microbial reductive dehalogenation -as a means Of rapidly remedlating halogenated source
area contaminants, This technology has shown considerable promise al other sijes with similar
constituents of concern. The Group believes that It otters all concerned parties the best
opportunity to rapidly and effectively remediate ground water contamination at the Site. In
addition, as will be discussed later in this response, this technology is also e•pecied to
concurrently reduce manganese concentrations which also exist in the source areas. This
innovative technology will be thoroughly evaluated in a field pilot study to be conducted in 1994
in the Upper Macon area of the Site. A workplan has been submitted to US EPA by DuPont
Environmental Remediation Services and is expected to gain final approval in the near future.
Please reference this worl<plan for more detailed information. The Group would like to note
here that, during the above-reterenced pilot study, It will be important to maintain the existing
hydrogeological conditions to tully evaluate the technology. This implies that source-area
extraction cannot be installed and/or operated during the duration of the study.
Should this technology be implemented at the Site. and all preliminary indications are that It will
be.the Group fully expects to meet ground water performance standards In th~urce areas in
a traction of the time It would take using a pump and treat technology. As such, the Group
believes it is fully complying with the letter and intent ot the Record of Decision as well as
advancing the sophistication of ground water remediation technologies for potential use at other
sites of concern throughout Region IV and the US.
Should this technclogy not be applicable at the Site, the Group agrees with US EPA regarding
the need lo construct and operate source-area extraction wells and would incorporate source
wpwinlprojects)7001721.33/dm04 17
• •
area extraction wells into the design upon reaching a negative conclusion on the innovative
technology. The potential negative impact of not having source-area extraction wells operating
during the several months of pilot study Is expected to be negligible, as average ground water
velocities in the area do not exceed 60 ft/year.
2. Contamlname wlll be spread Into less-contaminated areas down gradlenl of the
hot-spots without the use of eourca area recov11ry wells.
The last section provided a discussion of the strategy the Group has outlined 1""'4all ground
water remedi11tion at the Site. This includes an evaluation of an innovative technology in a field
pilot study to be conducted over several months In 1994. The Group fully understands and
agrees w~h us EPA's concerns over the potential migration of contaminants into less-
contaminated down gradient locations. 11 is for this reason that. should the previously
discussed innovative in-situ technology prove ineffective during Its pilot evaluation, source-area
extraction wells will be Installed and operated upon gaining US EPA review and approval of any
necessary design modifications to the existing proposed pump and treat design.
3. High manganese concentrations In ground water are .!!21 the result of .naturally-
occ:urrlng subsurtece conditions.
The Group fvlly agrees with US EPA on this point. The Group strongly believes that the
solubilization of manganese in source areas almost exclusively results from microbial
degradation of chlorinated organic compounds In source areas. As discussed In detail in the
Group·s Preliminary Design submittal (RMT, 1993). solubilized manganese, iron. and other
transition elements have been commonly observed at other sttes wtth similar contaminants and
microbial activity. This occurs primarily because of low redox potentials (primarily <·100 eV)
created by anaerobic condttions resulting from microbial respiration. These elements can be
used by microbes during respiration as an electron acceptor, much like oxygen is used by
aerobic microbes. Transttion elemen1s will be readily reduced and made more soluble under
these inttial conditions. As will be discussed in the next section, these types of subsurface
conditions can be favorably used to rapidly remediate both organic and inorganic problems.
' \oQ,
4. The proposed ground water recovery system will not affect ereas showing high
dissolved manganese concentrations.
The Group does not disagree wtth this statement, but also believes that consideration should
be given to the Innovative technology to be evaluated. as previous experience has Indicated
that both organics and inorganics are re mediated by enhancing microbial activtty. Considerable
research is currently being pertormed on bioremadiation ot metals-contaminated ground water.
Attached to this response is a recent and represP.ntative article on this subject which reviews
the mechanisms by which this technology can be made successful. It has been lhe experience
of the DuPont company that implementation of in-situ bioremediation systems can effectively
reduce concentrations of inorganics in addnlon to the organics for Which these systems were
originally Intended. Such Inorganic reductions can occur in both aerobic and anaerobic
cond~ions. The most likely mechanism for manganese remediation, discussed In the attached
article and taken advantage of by the proposed microbial reductive deha!ogenation pilot study.
Is through manganese precipitation. In this mechanism, suHate-reducing bacteria. such as
those suspected to exist in source areas at the site. produce sulfides which react with
inorganics to produce permanently insoluble compounds.
Interpolating from the above discussion. it can be reasonably hypothesized that existing
manganese concentrations in the impacted areas can be attributed to sulfate-reducing microbes
wpwin'9rojocool7001721.33/dm04 18
• •
oxhausting available suttates in soils over time .(low suttate concentrations have indeed been
observed In these areas). Having no biologically produced suHides to react and precipitate
with, manganese concentrations have slowly built to the levels observed today. The proposed
pilot study, It should be noted, has. as a key element of Its design, the injection of sunates to
these areas to replenish currently depleted suttate levels.
The Group believes that two likely outcomes will result from a successful Implementation of the
innovative bioremediation technology: 1) solublllzed manganese will be permanently bound by
suttldes during the enhancement of microbial activtty, thereby reducing manganese
concentrations, and 2) the permanent reduction of organic concentrations will ensure that the
aquner will rapidly return to higher redox conditions in the source areas. thereby eliminating the
potential for tuture solublllzation of manganese.
As stated previously, should this technology not be applicable at the Site, the Group fully
agrees with US EPA regarding the need to construct and operate source-area extraction wells
and would immediately do so upon reaching a negative conclusion on the innovative
tectmology. Again, the potential negative illllact ot not having source-area extraction wells
operating during the several months of the bioremediation pilot study is expe~to be
negligible, as average ground water velocities in the area do not exceed 60 It/year.
{The MDSG is proceeding with a field demonstration of the DERS anaerobic microbial
dechlorination technology. A schedule of field and design activities has bean added to the
Remedial Action Consfruction Schedvle shown in Section 4.)
30. Appendix B (Calculatlons}: This should also Include, at a minimum: material balances
(especlally tor the ground water constituents); air calculations; llquld and son vapor
piping; treatment equipment/system sizing calculatlons and vendor Information.
The indiciited calculations will be included in the appendices of the Prefinal Design.
(Air calcu/atlons were included in the $VE Fit1al Design report. Piping and sizing calculations
are included in Appet1dix L. Vendor information is included in Appendix L and Appendix S.]
31. Appendix H ISpeclllcatlonsl & Page 3-31 & 32, Section 3.5.2 {Draft Specification List):
General:
Since these specifications can be consldorlld "Rough Drafts" at best. the
tollowlng comments represent a cursory review, awaiting further
lntonnatlon.
'"-A statement should be added that these specifications are at an early
prellmlnary stage and wlll be greatly e11panded upon (and edltorlally
corrected) In the next submittal, similar to the note on the drawing
referring to the same subject.
In the Summary of Work article Included In each section, provide a
paragraph Indicating which sections are "performance-based".
The specHications will be expanded to some degree. but the major~y of the sections
conform to "normal industry standards" in 1heir present form. In addition, 1he body of
each specnicatlon ln(licates whether or not the section is "performance-based."
wpwin\projec:!8)700 t 721.J3/dm04 19
• •
[Revised specifications are contained in Appendix S.]
As commented on previously, Division 1 normally Includes, at a minimum, the following addltlonal specification sections: Measurement and Payment; Safety, Health, and Emergency Response; Chenflt'a) Data Acqu1s1t1on and Management; Construction Administration {Including Project Mootlngs): Comractor Quality Control; Operatton and Malmenance; and Air Monltor1ng (may be In Division 2 or 13). It should be confirmed how these Items wlll be handlad.
The MOSG will Include the requirements for these items In the Prefinal Design submittal.
{These items are addressed in the following documents: Constniction Health and Safety Plan, Operations and Maintenance Plan, and Remedial Action Work Plan. Measurement and Payment has been incorporated into this design.]
section 01010 should Include Lagoon 10 work.
Lagoon 1 0 work will not be a part of this design, but will be accomplished under a separate work plan.
/No longer applicable.]
Division 2 (or 13) needs specifications tor ercavatlon, handling, transport, and disposal of contamln91ed solls, lnllltratlon gallarles, Lagoon 10 work, and demolltlon (tank removal).
Specifications for infiltration gallery installation will ba included in the Pretinal Design as a part of the earthwork specKications. Lagoon 10 work and vessel removal will not be a part of this design, but will be accomplished under a separate work plan.
[The infiltration gallery design is shown on Drawing C·06. The other items are no longer applieable.J
Section 13235, as an example • Important parameters should be added to the specfflcatlon such as Influent conditions, expected performance crtterla, design flow rate, sizing, etc.
Section 13235 Is not a performance based specification. The desired unk has been selected as part of the system design, based on engineering calculations predicting influent quallty. In the Prefinal Design submittal, specific flow rates will be added for each unit.
[Flow rates have been added to each unit.]
It should be Indicated where, at a minimum, the followlng specification sections wlll be Included: Instrumentation.and Control Panels; well materials; metals removal; pipe other than PVC (since there seems to be a queetlon of PVC sultablllty); bforemlldlallon; and fitters. ""-
wpwin\projeo1•J7001721.33/dm~ 20
• •
Instrumentation and Control Panel specdications (Section 16) and well material
specttlcations (Section 02030) are currently detailed in the technical specttications.
There will be no bioremediation to specify because the scope of Lagoon 10 work has
been altered. Specttications for the metals removal system. including prefillers, will be
submttted wtth the Prefinal Design. The suttabiltty of PVC material for"11!0 was
discussed In our response on Comment #22.
{Tha specifications for everything except bioremediatlon are now included in Appendix 5.J
wpwin\proiocls ]7001721.33/dmll4 21
-----. ------------------------··---------• •
INTERMEDIATE RD REPORT (VOLUME 2. PLATES AND DRAWINGS)
GENERAL COMMENTS
1, It Is assumed that as these drawings are developed to complete bidding documents,
they wlll have addltlonal notes, existing and new utllltles, llmlts of construction,
contractor staging areas, security fencing, electrlcal/lnstrumematlon drawings (If used)
and other Information added, especlally completion of exact dimensions or coordinates
to ''tie down" facilities.
This information will be part of the pre-final design submittal.
[The Information has been added to the drawings.} ..._
2, Where wlll drawings be Included for the air stripper and other ground water treatment
lntercon nectlons?
Drawing C12 will show all equipment interconnections.
{Interconnections are shown on Drawings P-01, P-02, and P-03.)
3. WIii burled piping be profiled? How and where wlll air release valves be located?
Buried pipes will not be profiled. Air/vacuum release valves will be placed at projected high
points in the system, based on the topographic map of the stte. H will bA the contractor's
responsibility to verify that !he release valves have been appropriately located, using spot
elevation measurements.
{Undergro.und piping plans are shown on Drawings C-04, C-05, and C-06, and miscellaneous
details are shown on Drawing C-09.J
4. Where wtll Lagoon 10 work be lndlcatad?
Lagoon 10 wor1< will not be a part of this design, but will be accomplished under a separate
work plan.
{No longer applicable.] """"
5. Also, please refer to comments relating 10 drawings that are Included under Volume 1
above.
These comments have been noted.
SPECIFIC COMMENTS
1. Orawtng C04, SVE Process Flow Diagram
Pressure Indicators should be added along lines off of the SVE wells to allow
observations of flows.
wpwin\proj<><l•l700 t n t .33/dm94 22
2.
• •
Dedicated pressure indicators are not required for each SVE well. A normally 'l:i&.led. quick
connect pneumatic fttting will be installed on the SVE vauij piping. This fitting will allow the
rapid connection of a vacuum gauge for measuring well head vacuum.
(Addressed in the SVE Final Design Report. June 1994.J
There Is a discrepancy betwMn the ball valve Indicated on tile elevation drawing
and the globe valve Indicated on the process !low diagram.
Ball valves will be used in SVE piping,
[Addressed in the SVE Final Design Report. June 1994.J
The riser piping should be sloped either back towards the well or towards liquid
traps and the manifold piping should be sloped to liquid traps or sumps et
various Intervals.
Piping will be sloped back towards the SVE wells. A condensate trap Is provided at the
vacuum unit.
[Addressed in the $VE Final Design Report, June 1994.J
Drawing C05, Ground Watar Procoss Flow Diagram:
lnltlal fitters, flow elements, tank level controls, and Interlock logic and teed tanks
(for the Dockery Site systems) should be Indicated. Also, why aren·t feed tank
effluent pumps used? Gravity discharge from these tanks to the air strippers
may be difficult to arrange.
This drawing Is not intended to function as a P&IO, but to convey the intent of the overall
system. A P&ID will be developed for each system in the Prefinal Design. Gravity discharge to
the low-profile shallow tray system is a simple connection and therefore, feed tank effluent
pulll)s are not required.
{Addressed in Drawings K-02 and K-03.J
sampnng tape should be Indicated.
Sampling taps will be shown in the Pretinal Design.
(Taps added to pipelines on P&/Ds.}
Pressure ewltches or other moans to monitor possible blower fellure and slmllar
means to Indicate metals removal !allure and automate system shutdown should
be Included. _,,
A control narrative will be included and the P&ID will indicate the Instrumentation.
{The Process Controls Narrative is included as Appendix Q and the P&/Ds include
instrumentation.}
wpwinlprojocis)7001721.:l9/dm94 23
• •
• · Check valves are missing on the reeycle pumps.
Check valves are not required on the recycle pumps. Doubl8 check valves are alr11ady included at eaOh well. to prevent backflow into the well H the pump fails or shutfwJQwn.
{No revisions to drawings for this comm,mt.j
3. Drawing C12. Pump.Pad Plan and Sections: These pads should be revlsea to reflect comments elsewhere concerning backwash tanks and the need for feed tanks on the DOCl<ery system.
This drawing will be modHied for the pre-final design submittal.
[Feed tanks were added to the Dockery sites. The metal~ removal treatment scheme does not currently inc/ud9 a backwash system.]
wpwinlprojoct,J7001721.1.'l/dm!M
24
1.
2.
3.
4.
5,
• •
RA WORKPLAN COMMENTS
Page 1-2, Section 1.1 (Background): For completanass, there should be a reference
Included In the text to the RD, by name, and the RD documents to be used, especlalty
the Drawings and Specifications.
The FIA text wm be modnied to Include a reference to the Flemedlal Design (FID), the drawings,
and spectticatlons to be used.
[An introductory paragraph was added at the top of p. 1-1.J
Page 2-2, Section 2, 1,2 (Phasing Alternatlvesl: To present a complete discussion of the
contracting altematlves that may be used, Information should be added to the text on
what criteria would be used by the MDSG In deciding to "employ specla~ntractors
.• :· In place of "s General Contractor will be competltlvely procured , .. "
The following information will be added to the text discussing what criteria would be used by
the MDSG In procuring specialty contractors.
"The M DSG may contract directly with speciatty contractors to perlorm specialized tasks such
as instrumentation, electrical controls, and well construction. Specialty contractor(s) selection
will be based upon experience, abilities, and pricing compar9d to normal industry standards."
[The text was added to the first full paragraph of p. 2-2.J
Page 2-21 Section 2.1.2 & 2.1.3 (COntractor and Equipment Avallabllltyl: Page 3-4, Section
3. 1 .3 (Regulatory Interface and Deliverables); and Page 3-8, Section 3,2.4 (Review and
Evaluation ot Bid Proposals): In accordance with Industry standards and the above-
reference!I EPA OSWER Directive, the text should be revised to Indicate that there wlll
be a submlttlll to EPA for review on the selection Information ot th& RA Construction
contractor.
The text will be revised to state that "EPA will have the opportunity to review the selection
Information for the FIA Construction Contractor."
[A sentence was added to the last paragraph of Section 2. 1.2 (p. 2-2) to address this
comment.] _,
Page 2-61 Paragraph 1 -The confirmation sampling plan should be Included In the RO.
A reference to the confirmation sal1"1='1ing plan will be included in the Prefinal Design submittal.
[No longer applicable.]
Page 2-61 Paragraph 4 -Please give an example for esch of the four categories, and
discuss the method of disposal. Thl11 needs to be approved ahead ot time and WIii not
be done on an ad hoc basis.
Methods of disposal will be approved ahead of time. Four categories, w~h examples, and
method of disposal identttled in the RA Worf< Plan are:
wpwin\projects ]7001721.93/dmo.t 25
6,
7.
8.
9.
1)
2)
3)
4)
• •
~ Nonhazardous construction and landscaping debris, such as cleared trees or clean fill,
as well as other wastes, that are acceptable for disposal at a local Sublltle D or
municipal landfill.
Special wastes that, while not hazardous by regulatory detlnttion, are not acceptable for
disposal in a Subtttle D or municipal landfill. These wastes may oonslst of portions
excavated waste from Lagoon 1 o and/or wastes In the vessels.
Characterized hazardous wastes that do not require treatment, which may include
Lagoon 10 waste, disposed of at RCRA storage facility.
Characterized hazardous wastes that do require treatment may be disposed of at an
EPA-approved TSO facility.
{No longer applicable.]
Page 3-31 Section 3.1.2 (Quallflcatlons [for the RA PM Team]) end Page 4-6, Section 4,2,4
(Quallflcatlons and Experience (for the IOATil: In accordanca with the Scope of Work,
referenced EPA OSWER Directive and normal Industry standards, the docum·ent should
be revised to Include the actual names and actual quallflcatlons/resumes of the
lndlvlduals to fill the noted positions. This will allow proper review of the proposed
person's credentials.
~
The identtties, qualilications, and experience of the individuals and organizations selected tor
the RA management team will be submitted with the Prefinal Design.
[Figure 3· 1 has been revised to include the names of proposes members of the RA
Management Team. The proposed Team Members are the current Remedial Design
Management Team. The MDSG will submit the names, qualifications. and experience of any
individuals and organizations that differ from the current team ii changes are made.}
Page 3-4, Paragraph 3. 2nd bullet • Written notifications of changes Is not sufficient. The
PRPs can REQUEST a change before the event happens, not notify EPA of a change
after It has taken place.
The MDSG site representatives will contact the EPA to request a construction change, when
needed. It is requested that the evaluation of the request by the EPA be done in an expedient
manner, such that the review process will not have the effect ot delaying the RA construction
schedule.
[The 3rd bullet item from the bottom on p. 3-4 has been revised to incorporate this comment.]
Page 3-71 Section 3.2.3 {Pre-Bid Conlerenco}: The text should be revised to Indicate that
EPA will have the opportunity to attend this conference, as Is normally done In the
regulated RD/RA fleld.
The text will be revised to state that EPA will be invtted to attend the Pre-Bid Conference.
[The first paragraph ol Section 3.2.3 (p. 3-7) has b8An revised to incorporate this comment.}
Page 3-11 1 ~Ion 3.3.6 (Administration and Approval of Construction Changes\, third
paragraph: To presem 1my misunderstanding and minimize "surprises," EPA should be
wpwinlprcjocbj7001721.331dm04 26
10.
12.
• •
notified of !!J. Impending changes, so that the E;PA, not the Responsible Parties (RP),
may determine which changes are "substantial." EPA would then determine which
changes they would want to review and notify the RA Construction Manager. The text
should be revised accordingly to reflect this comment.
The text will be revised to state that the EPA will be notHied of all impending changes.
[The last paragraph on p. 3-11 has been revised to address this comment.)
Page 3-12. Section 3.4.1 (Monthly Progress Reports!: To provide II com~plcture In
the monthly report, the fotlowlng element should be added to this report: "Change
Orders. Proposed, Approved, and Completed."
The monthly report will be amended to include a section tor "Change Orders· which will consist
of proposed, approved, and completed change orders.
[The 3rd bullet item of Section 3. 4. 1 was added to incorporate this comment.)
Page 4-2. Paragraph 4.2.1 • How wlll the members of the IQAT be chosen?
Members of the IQAT team will be selected by the MOSG. The MOSG is currently reviewing
resumes of potential IQAT members. The members selection will be based on the experience
and certttication in the appropriate disciplines for the Macon/Dockery site work.
{Section 4.2. 1 was rovised to incorporate this comment.}
Page 4-51 IQAT -The 10AT wlll report to the RA Coordinator and EPA. See pages 18 and
19 or the UAO sow.
Communications, findings, and conclusions from the IQAT team will be provided to the RA
Coordinator and/or the RA Construction Manager. These individuals will report all resutts to
EPA. As a representative of the MDSG, the IQAT team will report to the RA Coordinator
and/or RA Construction Manager, not directly to EPA. -
[The description of the /OAT (p. 4-5) was revised to Include this text./
13. Pagos 4-9 & 4-101 "Process and Mechanical COA": To present a complete picture of the
required work ror this project component, the text should be revised to Include a
paragraph slmllar to "all documentation or testing and test results will be submitted to
the RA Coordinator ... for use In completion of reports"' (as used with other project
components).
9.
The text will be revised to Include a paragraph stating that "all documentation of testing and test
resutts will be submttted to the RA Coordinator and/or Construction Manager:·
{The paragraph was added at the end of Process and Mechanical CQA on p. 4-10}
Section 5 (RA Construction Schedule}:
ovamll comments:
wpwin\pmjao1&)7001721.3'3/dm9<1 27 -
•
For explanation and review purposes, ;ind In accordance with normal RA
procedures, discussion should be added to the test which Includes: very brief
note on task breakdown, Justification, milestones, constralms, and opportunities
for shortening the schedule. The specific schedule comment below should also
be addraS88d In this discussion.
The overall schedule of approximately 1 1/2 years from the beginning of the
bidding process untll actual start up appears rather excessive and should be
reinvestigated. Certain tasks could be performed slmuI1aneousIy, such as the
wells could be started earner In the contract.
The RA Work Plan will be revised to include text which provides a breakdown, justttication,
milestones, constraints, and opportuntties for shortening the schedule.
Currently the duration of the construction schedule is being reviewed to identify opportuntties for
shortening the schedule duration. One area under consideration is reducing thfl duration of the
bidding process. The MOSG may request that the contractor(s) include proposed ways of
shortening the schedule in their proposal to conduct the Remedial Action.
[The schedule contained in Section 5 has been shortened by seve;at months. ~I has been
added to Section 5 to incorporate the comments.]
Bidding Documents Development:
This should be done during the RD phase and le therefore contusing as being discussed
horo. Ploaso revise Ihle accordingly.
The ma]or~y ot the bidding documents will be created during the RD phase. Final bidding
documents will be based on approval of the RO. Therefore bidding documflnts may require
preparation and/or modttication tallowing the approval of the Final Design submittal to
Incorporate any EPA comments or modifications.
Contractor Selection Process:
Five months for this task appears rather long, especially In light of using bidder
prequallflcatlon. This should be discussed and revised.
The construction schedule is being reviewed in an effort to reduce the duration. One area
under investigation is the bidding process. The final construction schedule will be modrtied to
minimize durations such that the qualijy and overall operation will not be impactAd.
[The ccnstructicn schedu/6 has been reduCfld.J -
PERFORMANCE STANDARDS VERIFICATION PLAN {PSVP) COMMENTS
GENERAL COMMENTS
1. A discussion should be added on the monitoring of Lagoon 1 o cleanup (such as son
sampling or SVE).
wpwl<,\pr$<t•J7oo t 721.3Jlurn94 28
• •
The Macon/Dockery Stte Group will submtt a wor1<plan 1or the excavation and disposal of
Lagoon 10 waste. The workplan will include field sampling and analytical procedures for waste
characterization and soil cleanup confirmation sampling. This inlormatlon will not be included in
the PSVP.
(No longer applicable.)
2. There Is mention ·on page 3-4, Section 3.2.4 (Vacuum Vapor Analysis) ot affluent PCE
measurements at the discharge stack and Influent PCE measurements at the piping
manifold Inlet. However, the t=leld Sampling and Analysis Plan (FSAP) and Quallty
Assurance/Quality Control (QA/QC) Plan do not have sampling and analysis procedures
for these air measurements.
The soil vapor In the $VE discharge and in well head piping will be sampled using adsorbing
charcoal rubes.
The soil vapor in the SVE discharge stack, well head piping and piping mannold Inlet will be
sampled using a vacuum pulTl) to draw soil vapor through an adsorbing charcoal tube. The
charcoal tuba will be sent to a laboratory for quantttative analysis. Sampling and analysis
procedures for these measurements have been added to the FSAP and the QA/QC Plan. which
will be resubmiHed wtth the Preflnal Oeslgn.
[Addressed in the SVE Final Design Report, June 1994.J
3. WIii "Frac" type tanks be used to hold the effluent untll discharge requirements can be
verified?
"Frl!C" type tanks will not be used for effluent retention. The ground water treatment systems
have beer) conservatively designed to provide sufficient treatment to meet pe-ance
standards under Influent conditions that are al least double the actual concentrations
anticipated. The metals removal systems are being installed solely to avoid storage of ettluent
during startup, since the influent concentrations are projected to be below performance
standards. For added protection, the infiltration galleries will be located wtthin the capture
zones of the extraction systems, and, therefore. any unexpected discharge of effluent
exceeding Performance Standards will be contained and eventually remedied.
{The second paragraph on p. 3-1 was added to address this comment. J
wpwin\prcject9)7001721.:33/dm<M 29
• •
SPl=CIFIC COMMl=NTS
1.
2.
3.
4.
Page 2•1. Section 2 (Sampllng Obk>ctlves): A referenco should ha added to the Ground
Water Treatment System.
The firsl objective will be reslated as follows;
Evaluate the effectiveness of the ground water extraction and treatment systems In
meeting the Performance Standards specnied in the Statement of Work.
[The change was made as indicated.}
Page 3-1. Section 3.1.1 (Flow Monitoring): The following should be dlscusseo:
How the metera are Integrated Into the equipment.
"-Were flow meters considered to be located downstream of the treatment system
and between each unit operation to provide optimum process monitoring and
control?
Normally, flow Is monitored off each extraction well. Was this evaluc1ted?
Water meters will be located at the inlet of each shallow tray air stripper. Measurement of the
flow downstream of this point or between unrts of operation is not necessary. If a backwash
system is required, a meter will be added to the discharge of the system. Flow meters will bA
included on each extraction well.
[Section 3. 1. 1 {p. 3-1) was revised to incorporate this text.)
Page 3-2,' Section 3.1.3 (Sample Location and Frequency): To present a complete
explanation and to allow tor proper review, there should be a discussion added on the
frequency of sampling during stanup. Tllls section Is very Incomplete. The frequency of
the tests should be presented here, and when results are obtained, they shall be 88nt to
EPA with the monthly progress repons, not upon written request. Please read the UAO.
The last sentence In Section 3.1.1 will be replaced wtth the following.
"During system startup, each ground water treatment system effluent will be sampled according
to the following schedule: 'bO>
Each 12 hours for the first 48 hours of discharge by grab sample,
Daily for the next 5 days, and
As prescribed in the NC DEHNA Non-Discharge Permit."
Analytical results will be sent to the US EPA wtth the monthly progress reports.
[The text was added at the end of Section 3.1.3 (p. 3-2).J
Paga 3-2. Section 3.2 • During the FIA, EPA will need ACTUAL emission rates, not
calculated ones. In addition, the schedule of performance checks on tha SVE system
should Ile given.
wpwin\projecta)7001721.33/dm04 30
5.
6.
7.
• •
Emission rates, expressed as pounds per day or milligrams per minute, are a function of
concentration and !low rate. Concentration can be derived either by direct sampling and
analysis or by mass balance calculations. Flow rate may also be directly me~ or may be
obtained from equipment operating curves.
As part of $VE system monitoring, the soil vapor discharged will be sampled and analyzed on a
weekly basis for the first month, and quarterly thereafter. Flow rate will be determined by field
measurements that are cross-checked with equipment operating curves.
{Addressed in the SVE Final Design Repon, June 1994.J
Page 3-4, Section 3.2.4 • Again, this Information Is given without the frequency of
sampllng events,
The following paragraph will be added at the end of Section 3.2.4.
"The SVE system's discharge stack will be sampled and analyzed on a weekly basis for the first
month, and quarterly thereafter. A portable vacuum pump will draw the sample from the
sample port and through an adsorbing charcoal sample tube. The charcoal tube will be sent to
a laboratory for quantitative analysis."
{Addressed in the SVE Final Design Repon, June 1994.)
Page 3-5, section a.2.5 (System Pertormanca Analyses): Please clartfy that the weekly
per'tormance 11nalyels wlll be st11rted only after the lnltlal equipment "sta~• dllflcullles
have been corrected.
The second sentence in Section 3.2.5 (System Performance Analyses) will be revised as
follows:
"System performance analyses will be conducted weekly during the first month of steady-slate
operation, after correcting any initial startup difficulties, to establish an appropriate bench-mart<
for system per1ormance."
{Addressed in the SVE Final Design Repon, Jun& 1994.J
Page 3-6, Section 3.2.8 • The conflnnatlon sampling.plan should be presented here for
EPA approval. Describe how the confirmation son samplas wlll be collected.
Toe following will be inserted on page 3-6, after the existing first paragraph ol Section 3.2.8 to
become a new second paragraph.
"Soil samples will be collected from two depths from each of two borings to be located within
the lagoon. Anticipated depths are approximately between 15 to 20 feet and 25 to 30 h:•et
below surface.
"Subsurface soil samples will be collected using a spilt barrel sampler. When mobilized,
downhole sampling equipment will be free of rust and paint. This equipment ~e
decontaminated before use at each boring according to the procedures outlined in the
MacorVDockery FSAP and EPA Region IV's ECBSOPQAM. Decontamination procedures will
be performed between borings in the designated decontamination area. After decontamination,
the downhole sampling equipment will not be allowed to contact potentially contaminated
wpwin\projgcte)7001721.33/dmg4 31
8.
9.
• •
materials until it Is advanced to colleci the sample. Boreholes will be advanced using hollow
stem augers to the desired sampling depth. A standard two-inch O.D. split barrel sampler will
be used for sample collection. Once a split barrel sampler is removed from the boreholA, the
sampler will be opened. and the sall1)Ie will be split lengthwise. A representative subsample of
the soil will be removed and placed into a laboratory-supplied clean glass container in a
manner lo minimize headspace. The collected samples will be stored and cooled in coolers
until and during shipment to the laboratory. Sample chain-of-custody forms will be maintained
for all samples. Following drilling, boreholes will be grouted from the bottom up using neat
cement grout. Cuttings will be contained in DOT-approved, 55-gallon drums. The appro~imate
locations of the borings will be marked on a site map, and field locations will be staked for
-subsequent surveying. The soil samples will be analyzed for tetrachloroethene using SW-846
Method 8021." 'bQ>
The confirmation soil sampling plan will be incorporated in the revised PSVP which will be
submitted with the Prefinal Design for the SVE system.
/Addressed In the SVE Final Design Report, June 1994.J
Section 3.3 does not state the planned frequency of ground water monitoring during the
first year of recovery well system operation. In addition, the section should state that
the compllance monitor wells wlll be Installed as specified In the US EPA, Region IV,
Envlronment11I Services Division, Environmental Compliance Branch St11nd11rd Oparatlng
Procedures and gualhy Assurance Manual, ~ebruary 1, 1991.
The following sentence will be added to Section 3.3.1 (Compliance Monttoring Well Installation).
Compliance monitoring wells will be installed as specified In the US EPA, Region IV,
Environmental Services Division, Environmental Compliance Branch Standard Operating
Procedures and Qualtty Assurance Manual, issued February 1, 1991.
{The sentence was added at the end of Section 3.2. 1 (p. 3-3).J
The first sentence in the third paragraph in Section 3.3.2 (Sample Location and Frequency) will
be revised as follows:
"Before startup of the ground water recovery systems and quarterly thereafter through the
conclusion of the first year of active ground water remediation, selected on-site monitoring wells
(Including the proposed compliance monitoring wells) will be sampled and analyzed for the
compounds listed in Table 3-2. The data will be reviewed at the end of the first year of
monitoring, and the frequency of sampling and list of constituents analyzed for subsequent
monitoring will be determined in conjunction with US EPA."
[The text was revised as indicated (top of p. 3-6).J
Section 3.3 should Include a plan for monitoring wells closer to contaminant source
areas, for determination of ground water quality changes over time In those sreas. This
plan should be developed In concert with the redesign of the recovery well network to
Incorporate addltlonal ground water recovery wells In the areas of the most highly
contaminated ground water. The text states In Hvoral places that selected monitoring
wells Installed during the RI wlll be sampled during the Remedial Action. The report
should clearly Identify those wells. The report should also provide some Justification for
selection of each wen proposed for the Remedial Action sampling.
wpwinlprojocts)700172 I .3:lldm94 32 -
· 10.
• •
We propose to develop the monttoring plan In conjunction with !he Prefinal Design Submittal.
Compliance monttoring wells closer to the contaminant source area will be included in the
monitoring plan. The well locations will be dependent on the selected source area ground
water remedy.
[Monitoring wells within each plume are now shown on Figure 3-1, Proposed Monitoring Well
and Extraction Well Locations.]
Page 3-91 Paragraphs 2 and 3 -Contaminants of concern wlll not be delatad from the
analytical program. In addition, three sampling periods Is not long enough to request
any type of waivers.
Page 3-7, Paragraph 5: The existing second sentence (beginning with "Following review or the
results from the first year ... ") will be deleted. The last sentence Of this paragraph will be
modified to read: ·
"Water qualtty data will be reviewed to determine whether the analytical program (e.g., analyle
list, Performance Standard, sampling frequency) should be rnod~ied.·
[The referenced sentence was deleted (see 1st paragraph of p. 3-6). The last sentence was
revised as Indicated.]
The following sentence will be added to the end of this paragraph:
"If there is evidence to support a modtticatlon In the analylical program, EPA may be petitioned
for such mod~lcatlons."
{The sentence was added as indicated.}
Page 3-8, Paragraph 1: This paragraph will be deleted.
{The paragraph was deleted.]
11. Section 5,4 states that dedicated ballers may be used to purge monitoring wells prior 10
sampling. The EPA Roben s. Rear laboratory has performed several Investigations
which considered tha affects of dltterent sampling and purging devices on observed
concentrations of metals In ground water samples. The use of dedicated ballers to
collect samples has been shown to commonly produce unrepresentative unfiltered
ground water quality samples with respect to metals (R.W. Puls et al,
EPA/600/MIM-91/040, July, 1990). Research on this topic of the problems with sampling
and purging using ballars IS discussed In Ground Water Volume 32, Number 1, January.
F'ebruary 1994 article by Barcelona et al. The Macon Dockery slt111 has a history of high
me_tals concentrations In ground water samples. Based on the comparison of ftllered
and unfiltered samples In the Remedial Design Work Plan, these high m~
concentrations are probably largely related to sampling technique or possIBiy sampling
detlgn. Therefore, our program cannot agree with the use of dedicated ballers for
purging wells at the Macon Dockery site. Such devices may also not be appropriate tor
sampling monnortng wells at the Macon Dockery site. The Performance Standards
Verification Plan should propose an alternate type ol purging sampling device end a
sampling technique which wlll minimize the potentlal for suspended solids In ground
water samples.
wpwin\projecml7001721.33/dmll-4 33
12.
• •
The comment is noted. Peristaltic or submersible pumps are preferable to bailers to purge
wells and collect ground water samples for metals analysis in wells where suspended solids are
significant. The MDSG reserves the right to use bailers to purge wells and collect ground water
samples for metals analyses in wells that exhibtt minimal suspended solids.
[No changes were made to the text for this comm1mt.]
Section 5.4. page 5-6 -VOA samples may not be collected using a subm-te pump.
They should be collected using a baller or directly from the tellon tubing.
Page 5-6, third paragraph, second and third sentences will be modified as follows:
'Samples for volatiles analysis will be collected using etther a bailer or directly from Teflon
tubing in order to minimize volatilization of constttuents during sampling. If the wells are purged
by pump, then the volatiles will be collected last, after volumes for metals and other required
analyses have been obtained. If the wells are purged using a bailer, th0n the sample for voe
analysis will be collected first."
[The text was added to the 2nd full paragraph on p. 5-8.]
SPECIFIC COMMENTS -PSVP QA/QC PLAN
1. Page 2-1 1 section 2 (Protect ResponslbllHy): The followlng should be provided to
prosent a complete discussion:
2.
Organization chart and actual names and resumes of proposed staff.
An _organization cha11 will be provided in the Final Remedial Design Repol1.
[The MDSG w/11 obtain a quality assurance sampling contractor cturing the Re":::'Jia1 Action
phase. The names and resumes of the appropriate personnel will be submittec! to US EPA for
reviuw at that time.]
WIii thero bo a separate QA officer for field activities?
Field activtties will be audtted by members of the project Independent OualHy Assurance Team
(IOAT). (See the response to PSVP QA/QC Plan, Comment 5.]
[No changes were made to the text for this comment,]
Page 7-1. Section 7 (Sampllng Site Location and Sampling Identification): This requires
additional text and Information to form a complete "picture" of what wlll be done. At a
minimum this ahould Include: the type of Information Items expected In the field log
books. corrections, signatures, dating, attention to blank pages, etc.
The requested information will be provided in the Preflnal Remedial Design Report.
[Section 7 has been revised to address these comments.}
wpwin\projocl0]700 tnt .331dm94 34
• • """""
3. Pago 8-1 1 Soctlon e (C8llbratlon Procedures and Frequency): Discussion on the
4.
5.
callbrallon of SVE equipment should be Included.
Except for an OVA for field monitoring, there is no equipment associated wtth SVE
operations that require calibration. Soil vapor recovery from individual SVE wells will be
adjusted during operation based on the results of vapor monitoring.
{AddrBss9d in th9 SVE Final Design Report, Jufl6 t 994.J
Page 11-11 Section 11 /Internal Quallty Control Checks}: For ease of review and
Implementation, text and a table should be Included that Indicates the frequency of
taking QC blanks.
We believe that the supplied text is sufficiently clear on the required frequency of blanks.
The Laboratol)' Coordinator Is available to field staff to answer questions related to QC
samples, should they arise.
""""" [No changes to the text were made for this comment.}
Page 12-1 1 Section 12 (Performance and System Audits\: The audits should not be
conducted by the Project Manager but by someone Independent of the project who
reports directly to upper management and who can notify upper management to stop
work, If necessary. This should be discussed In this $$ctlon.
Page 12·1, second sentence would be modified as follows:
"The audits would be conducted by the appropriate member(s) of the Independent aual~y
Assurancl! Team (IOAT). The IOAT will be composed of experienced personnel capable of
evaluating field pertonnance and compliance with QC procedures. IQAT personnel will notffy
the RA Coordinator and/or RA Construction Manager whether to stop work. if necessary, to
correct errors and/or omissions In the construction tasks."
[The 1st paragraph on p. 12-1 was revised to incorporate this text.)
CONSIBUCTION HEAL TH ANO SAFl".TV PLAN CONTINGENCY PLAN
These comments are only related to general statutory requirements for the RA Contingency Plan
as set ounn the above-referenced EPA OSWER Directive.
""""" 1. tt Is reall.zed that the actual lncluslon of names for the contingency Plan may be dlfflcult
thla fer In advance of construction, however a place for these names should be Indicated
In the document, with a notation as to when the actual names and resumes wlll be
available tor EPA review.
The comment Is noted.
{The Emergency Contacts chart on p. 13-4 has been revised to address this comment.)
2. The tollowlng ,.hould to be added to Ihle documem:
wpwin\projoe11)7001721.33/dm94 35
• •
Cleal1y dellneate (preferably In a form that may be prominently hung at the Job
site) the actual names and phone numbers of the persons responsible for
responding In the event of an emergency.
Name of the 11ctual person who wlll give the on-site training.
Place and date for meeting with the local community. lncludlng agencies Involved
with the cleanup as well as local emergency squads and hoapltals.
Names of personnel trained In first aid.
Plan for protection of public and visitors to the Job site.
Specific discussion and plan aC1<fresslng the protection ot the local affected
populallon In the event of an accident or emergency, not just the workers.
These comments will be addressed in the revised Health and Safety Plan.
[The Emergency Contacts chart on p. 13-4 has been revised to address this comment. The
remaining comment items will be addressed by the Remedial Contractor in their Health and
Safety Plan.]
3. A copy of the map to the hospital and written directions should be placed lri each
vehicle used on-aHe.
The comment Is noted.
""""' [The chart on p. 13-4 contains written directions to the nearest hospital. Appendix D contains a
map of the route to the nflarest hospital.]
4. The plan should specify the locatlon of tha n93rest telephone.
The comment is noted.
{The Remedial Contractor will be required to maintain a telephone on-site during construction
activities. J
5. EPA l'GCOmmends that when personnel who have not received the 40-hour personal
protection training (e.g., plumbers, electrlclans) are working on-site, that they be
accompanied by trained personnel.
Personnel who have not received the 40-hour personal protection training will be accompanied
by trained personnel to the extent practicable and necessary as determined by the General
Contractor's Health and Safety officer. However, some stte activities, such as roadbulldlng,
may be conducted wtthout trained personnel present. Untrained individuals will not be allowed
to work in designated exclusion zones unless accompanied by trained personnel.
{The second par39raph on p. 14-1 has been revised to incorporate this teKI.} -
wpwln'9ro)octsl7001721.33/dm94 36
r •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
December 7, 1994
4WD-NSRB
Technical Committee
c/o David L. Jones
Clark Equipment Co.
P.O. Box 7008.
South Bend, IN 46634
SUBJ: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Jones:
. ~o
D£c 12 7994
SUPERFUN
'.\)::,,.,.IL~
Attached are the Agency's comments on the Prefinal Report documents. Please send a response to these comments no later than December 17, 1994.
The design, as submitted, is not complete. There still is the question of the design of the source area extraction well system, including metal treatment, VOC treatment, and infiltration galleries. As commented by EPA in the November 16, 1994 comments on the bioremediation report, this system must be ready to go if and when it is determined that the bio system will not be used at this site. The Agency does not want the delay of submitting, reviewing, and approving additional design documents. Therefore, this needs to be included in the final design document.
If you have any questions, please give me a call at 404/347-7791, ext. 4105.
Gie S. Bennett
Remedial Project Manager
•
Comments
1. Page 1-1, Para 3. The source control paragraph needs to be
updated.
2. The groundwater recovery system was designed using a two-
dimension numerical model assuming an isotropic porous media.
In view of the change to the hydrogeologic model for the
site, the numerical model is only of limited value and should
be reevaluated. After mapping permeability trends in the
transition zone and bedrock, the data should be examined
using a three-dimension numerical model.
3. Page 3-16. The text states that extraction well installation
may include using a bentonite slurry powder, tremied into the
well, in place of using bentonite pellets as an annular seal
above the sand pack. This procedure is inconsistent with the
specifications in Appendix S, Section 4.2. It is also not
recommended as a well construction procedure, for the
following reasons:
* Bentonite pellets will hydrate in the well bore, which
should form a tighter, more solid seal than the bentonite
slurry. A slurry may not prevent grout migration into the
sand pack, because of grout jetting through the bentonite
slurry seal as the grout exits from the tremie pipe at a
high velocity.
* A bentonite slurry seal might be more difficult to "tag"
than a bentonite pellet seal, potentially resulting in
grout emplacement beginning below the top of the bentonite
seal, rather than at the top of the seal.
* The EPA Region IV ESD Standard Operating Procedures and
Quality Assurance Manual, 1991, specifies that a bentonite
pellet seal should be used. However, if there is some
condition unique to this site that makes use of a bentonite
slurry preferable to the ESD-recommended bentonite pellet
seal, then it would be permissible to use the bentonite
slurry. There is no information presented in the design
report to indicate this is the case.
4. Page 3-19, Last Bullet. Change reference for "Appendix G" to
"Appendix Q".
S. Page 3-19, Last Bullet. The statement is incorrect; the pump
is controlled by levels in the air stripper reservoir. The
pump operation will not necessarily be continuous. Revise
paragraph accordingly.
6. Page 3-20. Delete the last sentence.
1
• •
7. Page 3-20, Bullet 6. Recommend including cover for the equipment with at least an open-sided "ramada" sun/rain roof. This will help in easing maintenance repairs during rain showers.
8. Page 3-21, Bullet 2. Verify that this statement applies to the Upper and Lower Dockery systems as well as the Macon system.
9. Page 3-22, Bullets 7-9. Add a reference in this section to the process control narrative given in Appendix Q.
10. Page 3-26, Paragraph 3. Include here the air stripper air emission tables attached to the Response to Intermediate Design Report Comments or refer to Appendix Land include the tables there.
11. Figure 4-1. The schedule does not selection. The completion reports Lagoon 10 removal have been deleted.
be submitted?
include O&M contractor
for vessel removal and
When will these reports
12. Appendix L. Include material balances for the groundwater constituents and air calculations.
13. Appendix Q, Page 4, Paragraph 6.
effluent pump will be prevented
filter becomes blocked.
Discuss how damage to the
in the occurrence that the
14. Appendix Q, Page 7, Paragraph 4. Add that Pump P-2002 will run without any interlocks when the H-0-A switch is on HAND.
15. Appendix Q, Page 8, Paragraph 1. Explain why the well pumps will STOP at high level. Should this not be the level at which they START? Explain why the well pumps are being controlled from the air stripper sump at low-level in addition to the control coming from the feed tank at high-level.
16. Appendix S, Section 02673, part 3.1. This section states that the well drilling contractor should be certified by the state of South Carolina. Since the site is in North Carolina, the contractor should be certified to drill wells in North Carolina.
17. The state has these fundamental questions about the groundwater:
a. What is the vertical extent of contamination? Is there contamination in the bedrock aquifer?
2
• •
b. Piezocones were completed in order to locate conductive zones? Were conductive zones located?
c. The Student t-test was used to compare hydraulic conductivities (k) values for different regions. Were the k value from the monitoring wells included in this determination? Based on the Student's t-test, it was concluded "At a 90 percent confidence level, no significant differences were found between the mean k values for the four areas of the site." In the groundwater flow model, it was necessary to vary the k values over 3 orders of magnitude to calibrate the models. This contradicts the conclusion based on the statistics. Are additional pump tests necessary? Please explain.
d. The transition zone between the saprolite zone and the bedrock zone seems to be a permeable zone that is conductive to groundwater flow and the movement of contaminants. What information has been collected to describe this zone? What is the permeability distribution for this zone? What is its thickness and map distribution? Please provide cross-sections showing the transition zone, structure contour maps showing the top of bedrock surface, and isopach maps showing the thickness of the transition zone and the saprolite zone.
e. The results of analyses of groundwater from MW2 l show that the western boundary of the Upper Macon plume has not been. adequately defined. What additional work .is being planned to define the extent of this plume?
18. A survey must be made of all off-property wells within 2,000 feet, and a daily pumping rate ascertained for each well. Such data should .be utilized when designing the monitoring program for the site.
19. Comments that were not addressed satisfactorily:
a. General Comment No. 2 • This comment needs to be addressed in terms of source area extraction wells also.
b. Specific Comment No. 1. As expressed by EPA on numerous occasions, this document should be a stand alone document, and as such, the PRP information should be included.
c. SC No. 4. This needs to be updated. The paragraph is outdated as of the ESD.
d. SC No. 5. The footnotes are still not complete. What is B, C, DL?
e. SC No. 13.
text?
This sentence needs to be included in the
3
•
Specifications Comments
1. Division O sections should be included.
2. Bid comparison sheets should have been included in this submittal.
3. A specification section for construction scheduling is needed.
4. Explain why Section 01410 -Testing Laboratory Services was not included in this submittal.
5. The Division 1 specifications (especially Submittals and Quality Control) give the contractor insufficient direction. Many generalities are stated using vague, catch-all language that has no enforceable meaning. As an example, Section 13235 and 13236 refer to Section 01300 for submittal procedures; however, Section 01300 gives no direction on when to make submittals, quantity of submittals, and distribution of submittals.
6. Does the Committee have a preference on how they want the main control panel physically laid out? If so, then some direction in the form of specifications or drawings should be included in the design package.
7 • Include specifications on indicators, flow meters,
etc.) .
instrumentation (i.e. , pressure
level indicators, transmitters,
Drawings Comments
1. Drawings K-01, K-02, and K-03. For completeness, include a legend for symbols used on the P&IDs.
2. Drawings K-01, K-02, and K-03. Indicate that the metals treatment system(s) is a package system. If this is not the case, then include mechanical drawings and/or data sheets (in the Specifications).
3. Drawing K-01. Denote that the box around the air stripper indicates "Package System''.
4. Drawing K-01, K-02, and K-03. Explain why the pressure indicator associated with the air stripper is measuring the water head as opposed to the air pressure in the blower line.
5.
6.
Drawing P-01.
Lower Macon.
Drawing C-02.
One set of feed/return lines should indicate Currently both indicate Upper Macon.
Physically tie in the well locations.
4
• •
Operations and Maintenance Plan Comments
1. Pages 1-2 and 1-3. These pages discuss a consent decree. This work is under a UAO, please change these paragraphs.
2. Page 1-27, Section 1.7. This section does not provide any information on Process Instrumentation and Control. Suggest referencing Appendix A here.
3. Page 1-29, Section 1.9. It is recommended that the contractor(s) and equipment vendors give operator training beyond that given by the RD engineers. Ideally, the operators would be selected and in the field prior to final completion of construction, thereby giving the operators the chance to witness the installation and to interface with the constructors.
4. Section 1.0. Include a Table of Contents for the O&M Manual that outlines a description of what is to be included in the O&M Manual. Recommend that the O&M Manual include ( in addition to the contents of the O&M Plan):
a. Section for as-built drawings, approved shop drawings, and construction photos
b. Listing of manufacturers with telephone numbers
c. Spare parts inventory and suppliers with phone numbers
d. List of special tools required for O&M activities
e. Complete nameplate data for all O&M activities
f. Sources for services and parts
g. Procedures for obtaining technical support and warranty service along with telephone numbers
h. Utility requirements
i. Permits
5. Page 5-1, Paragraph 1. Include instructions for the autodialer, especially for alarm conditions.
6. Page 5-2, Section 5. 2. Reference Performance Standards Verification Plan for sampling frequency and methodology or include those sections of the plan.
7. Page 5-2, Last Paragraph. Also submit the report forms to EPA.
5
•
Performance Standards Verification Plan Comments
1. Page 3-1. A nondischarge permit is discussed in Section 3.1.2. If a permit is needed, then NC recommends:
2.
-An application for a non-discharge permit, for groundwater remediation systems·, and a fee of $400.00 should be submitted to Permits and Engineering, Water Quality Section, Division of Environmental Management, Department of Environment, Health and Natural Resources, P.O. Box 29535, Raleigh, NC 27626-0535.
Please include with the application:
1) the final design report
2) a soil evaluation of the disposal site conducted by a soils scientist (The soils at each specific infiltration gallery should be described. Provide a minimum of 3 borings at each of these locations or the equivalent information to a minimum 7 foot depth), and
3) the manufacturer's performance specification for the diffused aeration system which demonstrates that the system performance will in fact reduce the influent volatile constituents to the performance effluent requirements.
Page 3-2, Section 3.1.4. Results should be sent to EPA the monthly progress reports, not upon written request. stated in the response to comment no 3).
with
(As
3. Proposed monitoring wells MW24 and MW25 do not appear to be in locations that can possibly intercept the migrating contaminant plume as displayed. Please explain.
Construction Health and Safety Plan/Contingency Plan Comments
1. Table 7-1. It is unclear to the reader why respirators with HEPA/organic vapor cartridges are to be used. According to the information on pages 4-6 to 4-19, cartridges should not be used for 57% of the volatile organics found on the site. ·Even if detector tube readings for the chemicals listed in this table are all below the "maximum range value" and vinyl chloride is less than 1 ppm, air purifying respirators are still not appropriate to protect against 36% of the chemicals of concern. Please explain.
2. Table 7-1. Will a gas chromatograph be used with the PID/FID? If not, chemicals cannot be identified with the proposed instrumentation, therefore, a concentration expressed as a volume to volume ratio such as ppm is meaningless. The recommended term is "meter units."
6
•
RA Workplan Comments
1. Previous Comment No 4. Confirmation sampling still is needed
for the SVE Lagoon 7 cleanup. Why is this no longer
applicable? Is it included in the SVE final design report?
2. Previous Comment No. 12. This is still not in line with the
UAO that was issued. THE IQAT TEAM MUST REPORT ITS FINDINGS
AND CONCLUSIONS DIRECTLY TO EPA, AND NOT THROUGH THE PRPS.
3. There is a typo in the schedule both here and in the prefinal
report. The schedule states that the. contractor selection
process begins on 1/1/94, instead of 1/1/95.
7
State of North c&1ina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr.:Governor
Jonathan 8. Howes, Secretary
William L. Meyer, Director
November 15, 1994
Memorandum
TO: Arthur Mouberry, Chief
Groundwater Section
,>:;A
DEHNR
Division of Environmental Management (DEM)
FROM:
RE:
David j_ Lown ~,f
Environmental Engineer
Superfund Section
Prefinal/Final Remedial Design and Remedial Action Reports
Charlie Macon Lagoon and Drum Storage (Macon Dockery) NPL Site
Cordova, Richmond County
EPA is completing a Remedial Design Report and a Remedial Action Workplan for this
National Priority List site. The NC Superfund Section is-reviewing the draft reports and will be
submitting comments to EPA by December 1, 1994.
The documents being reviewed are attached. Brian Wagner is presently reviewing the
plans for a pilot study of bioremediation for this site. The original plan was to pump-and-treat the
entire contaminated ,groundwater plume. Now, depending on the results of the bioremediation
study, the perimeter of the plume will be pump-and-treat and the most contaminated water in the
source areas will be treated with bioremediation.
Please forward this document to the appropriate sections of DEM and submit any
comments to the NC Superfund Section. We would like to have the views and permitting
requirements of Air Quality, Groundwater, and Water Quality Sections ofDEM. If you or your
staff have questions, please call me at [phone].
Attachment
cc: Jack Butler
P:O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% mcyded/ 10% post-consumer paper .
i
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
4WD-NSRB
MEMORANDUM
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
DATE: November 3, 1994
SUBJECT: Macon/Dockery NPL Site
Cordova, North Carolin
FROM: Giezelle
TO:
Remedial
Macon Team Re · wers
Dave Hill/Bill O'steen, Water
Norma Eichlin, CDM
David Lown, NCDEHNR
Rr-.-.-·--~o
NOV O 4 1994
SUPERFL1Nt1 ''.-iECTION
Attached are
referenced site.
comments that you
Remedial Design related documents for the above Please review these documents and provide any may have to me no later than December 1, 1994.
Please give me a call if you have any questions. Thank you again for your continued support on this project.
• • Macon/Dockery Site
Richmond County, North Carolina
October 31, 1994
Ms. Giezelle Bennett
Remedial Project Manager
U. S. EPA, Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Preflnal Design Deliverables
Reply to: Technical Committee
c/o David L. Jone•
Clark Bquipment Company
P.O. Box 7008
South Bend, IN 46634
Phone: [phone]
Fax: [phone]
IRF"' ... ~~ •~10
NOV O 4 1994
Macorv'Dackery Site -Cordova, North Carolina
Dear Ms. Bennett:
Transmitted herewith are seven (7) copies each of the following documents which are required
for submittal with the Prefinal Design:
• Remedial Action Work Plan (revised to incorporate U. S. EPA comments);
• Performance Standards Verification Plan for Ground Water (revised to
incorporate U.S. EPA comments);
• Construction Health and Safety Plan (revised to Incorporate U. S. EPA
comments);
• Prefinal Remedial Design Report for Ground Water;
• Preflnal Remedial Design Drawings; and
• Operation and Maintenance Plan.
The Remedial Action Work Plan, the Performance Standards Verification Plan for Ground
Water, and the Construction Health and Safety Plan were previously submitted for review.
These documents are being submitted In a finalized form. If further revisions are necessary,
the Group will prepare and submit replacement pages to U. S. EPA for each of the seven
• • Ms. Glezelle Bennett Page 2 October 31, 1994
cople5 of these plans. The Preflnal Remedial Design Report for Ground Water and the
Operation and Maintenance Plan are being submitted as working copies. The Group will
Incorporate U. S. EPA comments Into these latter two documents and resubmit both In
flnallzed form on December 22, 1994.
By prior agreement with U. S. EPA, the Preflnal Remedial Design Report Is being submitted
without several of the appendices. These appendices were submitted and reviewed with the
Preliminary and/or Intermediate Design submlttals. The only appendices submitted with the
Prefinal Design submittal are those with updated Information, such ·as the design
specifications. The entire set of appendices wlll be included In the Final Design submittal.
Also by prior agreement with U. S. EPA, the Prefinal Design drawings are submitted at half-
slze, with the intent of submitting full-size drawings with the Final Design submittal.
As previously documented, the Preflnal Design submittal does not contain any information
from NC DEHNR regarding the permitting status for effluent discharges from the three ground
water treatment systems since NC DEHNR does not review draft permit application packages.
The Macon/Dockery Site Group will submit a permit application based on the Final Design
submittal, stamped and sealed as appropriate by registered Professional Engineers.
You will note In the Prefinal Design Report and Drawings that 5E!Veral general changes were
made from the Intermediate Design submittal. First, references to the Soil Vapor Extraction
(SVEJ fieldwork and remedial design were deleted from this submittal, since the Group
submitted a complete Final Design for SVE In June 1994 which has subsequently been
approved by U.S. EPA. Second, the Remedial Action Work Plan and Performance Standards
Verification Plan were revised to exclude requirements for Lagoon 10 and vessels removal
activities, which were recently undertaken and accomplished by the Group well ahead of the
construction schedule previously submitted. Finally, the Performance Standards Verification
Plan in this submittal is now focused on ground water remediation activities only since the
SVE Final Design submittal Included a Verification Plan for lagoon 7 remediation activities.
Several specific design changes should also be noted. The ground water extraction system
design for Lower Dockery was modified to include a Jet pump system rather than a series of
submersible pumps. Design analyi;is during the Prefinal Design phase Indicated that
submer.;ible pumps operating at the Lower Dodtery area would be subject to an unacceptable
rate of on and off cycling, leading to potential pump failure and increased maintenance costs.
Design changes for the Macon site resulted from observations during fieldwork conducted
recently by DuPont Environmental Remediation Services (DERS). DERS Identified a highly
conductive transition zone at depth. RMT modified the design basis to Increase the rate of
extraction capabilltles to reflect higher now conditions and to Increase overall treatment
capacities. Modeling refln_ements based on the DERS findings also Indicated that fewer
extraction wells along the Upper Macon plume perimeter would be sufficient to contain the
plume under these revised conditions. The system has been designed with flexibility to allow
• •
Ms, Glezelle Bennett Page 3 October 31, 1994
the addition of several extraction wells If pumping rates are found to be lower than indicated
by recent observations.
Please contact me at [phone] or Wayne Barto of de max/mis, Inc. at [phone]
If you have any questions cooc:emlng this letter or the transmitted deliverables. Thank you
for your continued assistance on this project,
Very truly yours,
L)~,;:, J,lb,1v 1
David L. Jones
Project Coordinator
Macon/Dockery Group Technical Committee Chairman
/b
atts.
c:c: Macon/Dockery Technical Committee
Wayne F. Barto, de max/mis, Inc.
Paul Furtick-RMT, Inc:.
'.
State of North ctfolina
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
October 27, 1994
Memorandum
TO:
FROM:
Brian Wagner
Groundwater Section
Division of Environmental Management
David J. Lown r;s}:J?
Environmental Engineer
Superfund Sect.i0r.
RE: Bioremediation Pilot Study Interim Report
Macon/Dockery Superfund Site
Cordova, Richmond County
Enclosed is the report on bioremediation for the cleanup of contaminated groundwater at the
Charlie Macon Lagoon and Drum Storage Site (Macon/Dockery), a National Priority List site. The
original ROD required treating the groundwater with a pump-and-treat system. The PRPs want to
incorporate bioremediation into the groundwater remediation program. DuPont Environmental
Remediation Services is the contractor for this work and they state that" ... materials to be injected
at this site are identical to those permitted for the Kinston fadlity." (See enclosed letter.)
EPA wants to know if we have any major objections to the proposed pilot project by
November 4. Of course, we can submit specific comments after this date.
If you have questions or comments, please call me at [phone].
Enclosures
cc: Jack Butler
P.O. Box 27687. Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Empioyer 50% recycled/ l 0% post-consumer paper
Macon/Do~ery Site • Richmond County, North Carolina
May 20, 1994
) Reply to: Technical Committee
c/o David L. Jones
Clark Equipment Company
P. 0. Box 7008
Ms. Giezelle Bennett, Remedial Project Manager
U. 5. EPA, Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Response to U. S. EPA Comments
South Bend, IN 46634
Phone: [phone]
Fax: [phone]
Work Plan for the Removal of Wastes from Lagoon 10, Vessels, and Drums
Macon/Dockery Site -Cordova, North Carolina
Dear Ms. Bennett:
Transmitted herewith are the Macon/Dockery Site Group's "(MDSG") response to U. 5. EPA
comments on the subject Work Plan. U. 5. EPA's comment has been repeated in the text of
the response followed by the Group's response in italics.
The project is currently out for competitive bid. The following companies were pre-qualified
by the Group and invited to bid on the project: Nu-Way Environmental, Inc., Lexington,
South Carolina; Waste Abatement Technology, Inc., Marietta, Georgia; OBG Technical
Services, Inc., East Syracuse, New York; Sevenson Environmental Services, Inc., Niagara Falls,
New York; Heritage Environmental Services, Inc., Charlotte, North Carolina; Fenn-Vac, Inc.,
North Charleston, South Carolina; and Bierlein Environmental Services, Inc., Saginaw,
Michigan. The bids will be due on May 31, 1994. The MDSG would like to award the
project as soon as possible thereafter with the intention of beginning site work by mid-June
1994. Towards that end the Group would like to request your assistance by indicating if any
of the potential contractors are unacceptable to U. 5. EPA. U. 5. EPA's expedited approval of
the Work Plan is also requested. A complete Work Plan incorporating all U. 5. EPA-approved
revisions will be forwarded to your attention at that time.
Please do not hesitate to contact me at [phone] or Wayne Barto at [phone], if
any further clarifications are needed. Thank you for your continued assistance on this project.
Very truly yours,
#~~~-· "'.
David L. Jones ~
Project Coordinator
Macon/Dockery Group.·Technical Committee Chairman
WB/b
cc: Macon/Dockery Site Group Members
Wayne F. Barto, de maximis, inc.
Paul Furtick -RMT, Inc.
• •
WORKPLAN COMMENTS
1. Page 1-3, 3rd Para -Use polyaromatic hydrocarbons for PAHs instead of polynuclear.
The change will be made as requested throughout the document.
2. Page 1-3, 3rd Para -Delete the sentence, "Subsequently, the Macon ... Lagoon 10 materials."
The referenced sentence will be deleted.
3. Page 2-6 -The title of this table needs to be changed. The tttle is different than from the one on page 2-5, and this table does not contain any volatile or semi-volatile information. Table 2-2 needs to be divided.
The name of Table 2-2 will be changed to "Analytical Results tor the November 9, 1993, Sample of Lagoon 1 0 Waste." Subtitles will be included within the table.
4. Page 3-1 -The equation needs some sort of explanation/legend.
The following text will be added at the end of the second paragraph of Section 3.2. 1:
"The estimated volume was recalculated with the following assumptions:
depth of waste is assumed to be 1 0 feet, minus the cap thickness of 3 feet. plus 1 foot for potentially affected soil beneath the _waste;
lagoon width is assumed to be 40 feet, plus an additional foot on each side for potentially affected soil requiring removal;
lagoon length is assumed to be 100 feet, plus an additional foot on each end tor potentially affected soil requiring removal; and
total.yards will be multiplied by a factor of 1.2 to account for an assumed 20% expansion of materials after excavation."
5. Page 3-2, Para 3 -The sentence "The lateral boundaries ... sidewall stability." should be deleted. Boundaries of excavation are determined by remediation levels, not machine operation.
The referenced sentence will be deleted.
6. Page 3-2, Para 4 -This paragraph is confusing. All excavated material must be placed on lining in a protected staging area and all excavated material must be sampled prior to using it as backfill. This needs to be stated here.
The overburden referenced in the beginning part of this paragraph refers to the clay cap material placed on the lagoon by EPA during a previous removal action. The clay materials were placed in the lagoon on top of a plastic liner. The clay cap will be removed without mixing with waste. Therefore, there will be no need to sample the clay, a'nd it will be suitable without sampling to use as final cover over the backfill in the lagoon.
l:\WP\70\7001721.COM/alf94
• •
The last sentence will be deleted and replaced with the following: "Soils excavated to maintain
sidewall stability will be placed on a liner in the staging area and sampled prior to use as
backfill to confirm that waste constituents are not present above the 2 ppm cPAH level."
7. Page 3-3, Para 2 - A 12-foot excavation limit is not specified in the ROD. What is specified is a
remediation level that all soils in Lagoon 1 O must meet before the cleanup is complete. The 2
ppm limit was based on direct contact threat, but an excavation limtt was not established,
therefore, all soils must meet the remediation level. This report should be changed accordingly.
The referenced paragraph will be revised as follows, 'The volume of soil to be excavated will
initially be limited to quantities that are visibly affected by waste materials. Immunoassay will
be used as a field screening method to guide removal of affected soil exceeding 5 ppm total
PAH's. Laboratory analysis will be performed to verify that remaining soils meet the 2 ppm
total carcinogenic PAH performance standard. Further excavation, if needed, will be conducted
until verification sampling demonstrates that remaining soils meet the 2 ppm cPAH standard.
Upon completion of waste and soil removal, dimensions of' the excavation will be estimated,
photographed, and recorded for record documents.
8. Page 3-3, Para 1 -The discussion on storm water and erosion control should be more detailed.
The referenced paragraph will be revised as follows:
"During excavation activities, storm water run-on, run-off, and accumulation will be minimized by
use of berms around the excavation. In addition, silt fence will be installed on slopes downhill
from the excavation. If necessary, rainfall that accumulates in the open lagoon excavation
during the project will be absorbed by cement kiin dust or other appropriate absorbent
materials. The cement kiln dust will then be handled as overburden."
9. Page 3-3, Para 3 -This discussion should be in more detail. "Sufficiently compacted" should
be defined. The site restoration requirements should also be described, i.e., final grading,
surface water controls, surface replanting, etc.
The referenced paragraph will be revised as follows:
"Backfill from an on-site borrow source will be compacted to 90 percent of the maximum dry
density as determined by Standard Proctor. The clay material removed as overburden will be
returned to the lagoon as cover material and graded to attain ·positive drainage from the
disturbed area. After final grading, the disturbed areas. wi/1,be revegetated with common grass
seed (e.g., fescue) conforming to NC DOT Section 1060-3. Surface ruri-off from disturbed
areas will be managed using silt fences installed on downhill slopes, until a uniform stand of
established grass is achieved."
10. Page 3-3, Para 4 -Since remediation is limited to the Lagoon 10 area, any liquid wastes
encountered should be immediately contained, wtth subsequent solidification.
The second sentence of Paragraph 4 will be revised as follows, "However, in the event that
they are encountered, immediate action will be taken to absorb liquid waste in the lagoon using
surrounding soils or a solidification media such as cement kiln dust or other appropriate
absorbents. The absorbed waste will be removed and staged for characterization and
disposal."
I :\WP\70\ 7001721. COM/cdl94
• •
11. Page 3-4, Vessels -The removal of liquid wastes in the existing tanks is questionable, because the integrity of the tanks is unknown. Using portable "frac" type tanks would seem to be a more reliable alternative.
.,
The following sentence will be inserted after the third sentence of the first paragraph in Section
3.2.2: "Tank integrity will be verified using a low-pressure air test to confirm that the tank does not leak. If the tank integrity is suspect, another tank will be selected and tested, or a portable
tank (e.g., frac tank) will be utilized." ·
12. Page 3-4, Last Para -All soils in the proximtty of the tanks should be sampled io confirm that contaminants of concern are not present. Visibility is not an acceptable measure of the amount or degree of contamination present.
The second sentence of the last paragraph will be deleted and replaced with the following text: "Remaining soils will be screened using a hand-held vapor meter. If vapor concentrations exceed 1 O ppm above background, confirmation samples will be collected as described in Section 3.3.2." ·
13. Page 3-4 -The report needs a discussion on how any piping connected to the vessels will be sampled, emptied, removed, and disposed.
A sentence will be added after the first sentence of the first paragraph of Section 3.2.2, which
will read, "Piping connected to vessels will be dismantled and allowed to drain into the vessels."
Other text will be modified to show that wherever empty vessels are being cleaned or removed, the associated piping will also be cleaned and removed. Text will also be modified to show that visibly affected soils will be removed under any vessels orpiping which may have leaked, and remaining soils will be screened as previously describi!d using a ha.nd-held vapor meter (see response to Comment 12).
14. Page 3-7 -The soil around the drums_ should also be sampled.
The following text will be added after the first sentence on Page 3-7, "Drums that have been
punctured or otherwise appear to be leaking will be noted. If the contents of a leaking or
punctured drum originated from source area investigations or decontamination activities, or if the origin is unknown, soil beneath the drum will be sampled to determine whether soil removal is warranted." The text on Page 3-11 for drums will also be modified. The following text will be added at the end of Page 3-11, "If the drum has been punctured or appears to have leaked, then the contractor will attempt to identify the origin of the drum contents. The soil beneath the drum will be sampled if the drum contents cannot be properly identified or if the contents originated from source area investigations or decontamination activities. Drill cuttings and
purge water from locations outside the source areas are not likely to contain concentrations of waste-related constituents that warrant soil cleanup if spilled.
Soils that are sampled will be analyzed for parameters listed in Tables 9-5 and 9-6 (attached) of the Quality Assurance/Quality Control Plan (Appendix 8). Analytical results will be evaluated by comparison with risk-based cleanup targets, such as action levels distributed by US EPA
Region 3 Technical Support Section (memorandum dated October 15, 1993, from Roy L. Smith, Ph.D., Senior Toxicologist to the Risk-Based Concentration Table mailing list)."
I :\WP\ 70\ 7001721.COM1cdl94
• •
15. Page 3-12, Last para -Notification should also be provided to NC DEHNR.
The third sentence of the last paragraph will be modified as follows, "The MDSG Project Coordinator will notify US EPA and NC DEHNR prior to shipment of any waste materials to an off-site facility for disposal."
16. FSAP Section 5 -References to collecting soil samples indicate that the soil samples do not have to be mixed tt sufficient material can be collected in a single scoop or hand auger: Except when volatile organic analyses are to be conducted, soil samples should always be mixed. ESD recommends that when samples are to be shipped, some type of sorbent material should be used to pack the samples.
Section 5.4. 1 will be modified as follows:
" ... The sample containers will be filled after thoroughly mixing each soil sample, as per the ECBSOPQAM, in a decontaminated stainless steel or glass holding vessel."
17. The Field Sampling and Analysis Plan should only discuss details of this removal. For example, Section 7.2 discusses the surveying of wells, and Section 5.5 discusses subsurface sampling.
A ground elevation survey will be required to determine payment for the Lagoon 10 waste removal contractor. The text in Section 7.2 will be changed by deleting the first two sentences
and adding the following at the beginning of the paragraph: "A ground elevation survey at Lagoon 1 O will be necessary to determine the volume of the excavation prior to backfilling."
Section 5.5 (Subsurface Sampling) will be deleted and replaced with the attached Sections 5. 5 (Bulk Liquid Sampling) and 5.6 (Waste Pile and Roll-Off Container Sampling) . •
l:\WP\70\7001721.COM/odl94
• •
5.5 Bulk Liquid Sampling
Bulk liquid samples will be collected from existing tanks or frac tanks used to contain effluent
from the water treatment system. Samples will be analyzed for the site's ground water
constituents of concern. The samples will be collected using Teflon bailers if possible. If
sampling via bailer is not possible because of tank construction. samples will be collected from
draining valves located on the tank, after allowing water to briefly flow from the valve. Sample
containers will be filled directly from the bailer or valve. Sampling times will be recorded in field
notebooks. The required sample containers, preservatives, records, labels, handling, and
chain-of-custody procedures are described in this FSAP and the associated QA/QC Plan.
5.6 Waste Pile and Roll-off Container Sampling
One sample will be collected per approximately 30 cubic yards of waste material. Samples will
be collected from a depth greater than one foot below the surface of the waste pile, where
possible, to reduce the potential for false negatives of volatile analytes. Samples will be
collected from varying depths within the waste pile as directed by the Construction Manager.
Samples will be collected using decontaminated stainless steel hand augers and/or scoops.
Samples for analysis of volatile organic compounds (VOCs) will be collected at each sampling
location (i.e., a minimum of one voe sample will be collected per approximately 30 cubic yards
of waste) and placed directly into the sample container. Samples for TCLP metals, TCLP
semivolatile organic compounds, corrosivity, reactivity, ignitability, and free liquid (paint filter
test) analyses will be composited where possible and appropriate. Samples to be composited
must come from adjacent locations of a single waste pile. A maximum of five adjacent sample
locations will be composited (i.e., a minimum of one sample composite for non-volatile organic
analytes will be collected per approximately 150 cubic yards of waste). Sample volumes will be
composited in a decontaminated stainless steel bowl using a decontaminated stainless steel
scoop or spatula per EPA's ECBSOPQAlf Sufficient sample volume must be collected from
the five locations to accommodate the required analyses. The composited sample will be
placed into sample containers using the scoop or spatula.
Roll-off containers will be sampled in three locations using decontaminated stainless steel hand
augers to collect the sample. The depth of the sample should be between one-quarter and
three-quarters of the depth of waste material at the sampling location within the roll-off
container. A sample for analysis of voes will be collected at each· of the three locations within
a roll-off container for compositing by the laboratory. Sample volumes from each of the three
locations within a roll-off container will be placed into a decontaminated stainless steel bowl and
composited using a decontaminated stainless steel scoop or spatula per EPA ·s ECBSOPQAM.
Sufficient sample volume must be collected from the three locations to accommodate the
required analyses. The composited sample will be placed into sample containers using the
scoop or spatula. Homogenized sample will be analyzed for TCLP metals, TCLP semivolatile
organic compounds, corrosivity, reactivity, ignitability, and free liquid (paint filter test).
Upon arrival at the laboratory, individual voe samples will be composited under controlled
conditions. Each VOC composite created in the laboratory will be composited from the same
sampling locations as used in the field to create the non-VOC composite. Instructions for
compositing the VOC grab samples will be included with laboratory work orders or on chain-of-
custody forms.
This FSAP and the associated QA/QC Plan describe sample volume, container, preservative,
record keeping, handling, and chain-of-custody requirements."
l:\WP\70\7001721. COM/cdl94
AMT PERFORMANCE STANDA-VERIFICATION
QUALITY ASSURANCE/QUALITY CONTROL PLAN
MACON/DOCKERY SITE •
TABLE 9-5
ORGANIC GROUND WATER CONSTITUENTS OF CONCERN
Volatile Organic Compounds
Vinyl chloride
Methylene chloride
Acetone
1, 1-Dichloroethene
1, 1-Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1,2-Dichloroethane
1, 1, 1-Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Xylenes (total)
Semlvolatlle Organic Compounds
lsophorone
TABLE 9-6
1
10
1
1
1
1
1
1
1
1
3
10
INORGANIC GROUND WATER CONSTITUENTS OF CONCERN
Antimony
Barium
Beryllium
Cadmium
Chromium
Lead
Manganese
Mercury
Nickel
Vanadium
Zinc
Cyanide
10
50
5'
0.3
10
3
5
0.2
40
50
20
10
APRIL 1994
SECTION 9
• Quantitation limit is greater than the Performance Standard required by the Unilateral Administrative
Order/Statement o·f Work.
L\WP\70170017L 1 0.OAP/ccU94 9-9
State of NorthArolina
Department ofTnvironment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes. Secretary
William L. Meyer, Director
·•4~~-.a·· .------·~ a a ,; ~------. DEHNR
May 17, 1994
Ms. Giezelle Bennett
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland street
Atlanta, Georgia 30365
RE: Comments of Prefinal Remedial Design Report for Soil Vapor Extraction
Macon/Dockery site
Cordova, Richmond county
Dear Ms. Bennett:
COPY
The Superfund Section has received and reviewed this document and would like to make the following comments:
Page 3-5. Section 3 .1. 6 Sample Location and Frequency. Paragraph 2, "Confirmatory soil samples will be collected at the 22-to 24-foot depth interval and the 29-to 31-foot depth interval from two soil borings."
Comments: Two samples from each confirmatory boring is not adequate to determine if the soil beneath Lagoon 7 is clean, The confirmatory borings should be sampled on 2-foot intervals from the ground surface to the top of the water table. Enough data should be collected from these borings to allow for the modeling of the residual contamination to determine if the levels are protective of groundwater.
According to the RI, the subsurface soils under Lagoon 7 were characterized by one soil boring and two soil samples. The soil samples tested the intervals from 25 to 29 feet and 15 to 17 feet. Both samples contain a number of contaminants, at levels high enough to be concerned about the possible impact on groundwater. The actual distribution and concentrations of these contaminants cannot be determined based on two samples. Likewise, four samples taken from roughly the same interval, will not provide adequate data to determine if the soils under the lagoon are clean.
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
Ms. Giezelle B.ett
May 17, 1994
Page 2 •
In .addition to a full scan for all contaminants previously
detected, other information that should be collected during
the confirmatory drilling should include sample descriptions
and determination of geologic units. For each geologic unit,
information on permeability, mineralogy and soil-water
partitioning coefficients should be provided. This data along
with the general site characteristics should be modeled to
determine if the groundwater is protected to the degree
stipulated in the ROD.
The Superfund Section appreciates the opportunity to comment
on this document and looks forward to continuing to work with you
to clean up this site. If you have any questions or comments,
please do not hesitate to contact us at [phone].
cc: Jack Butler
(J"]J9_e_
David J. Lown
Environmental Engineer
NC Superfund Section
.....
9 •··
State of North calina
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
April 29, 1994
RECE!\fED
M E M O R A N D U M
! David Lown ,_ _ /
MAY -9 1994
TO:
NC Superfund Section Jf~f~~N~
FROM: tA. Preston Howard, Jr., P.E~~-
SUBJECT. Charlie Macon Lagoon & Drum Storage
Intermediate Remedial Design Report
Richmond County
DEM Project #93-50
The Division of Environmental Management has completed the
review of the subject document and offers the following comments
and recommendations.
Air Quality Comments:
The Air Quality Section is in agreement with the report's
conclusion that no control devices are required provided no
more than 75 SVE wells are operated at one time.
Water Quality Comments:
Water Quality prefers that the proposed non-discharge
alternative for the disposal of remediated groundwater be
utilized if soil conditions are adequate.
An application for a non-discharge permit, for groundwater
remediation systems, and a fee of $400.00 should be
submitted to Permits and Engineering, Water Quality Section,
Division of Environmental Management, Department of
Environment, Health and Natural Resources, P.O. Box 29535,
Raleigh, NC 27626-0535.
Please include with the application:
1) the Final Design Report,
2) a soil evaluation of the disposal site conducted by a
soils scientist {The soils at each specific
infiltration gallery should be described. Provide a
minimum of 3 borings at each of these locations or the
equivalent information to a minimum 7 foot depth), and
3) the manufacturer's performance specification for the
diffused aeration system which demonstrates that the
P.O. Box 29535. Raleigh. North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
•
system performance will in
volatile constituents to
requirements.
Groundwater Section Comments:
•
fact reduce the
the performance
influent
effluent
A survey must be made of all off-property well within 2,000
feet, and a daily pumping rate ascertained for each well.
Such data should be utilized when designing the monitoring
program for the site.
If there are any questions, please advise.
APHjr/sbp/MACONLAG.SWM
cc: Alan Klimek
Steve Tedder
Fayetteville Regional Office
Central Files
Groundwater Section Files
• •
April 12, 1994
Memorandum
TO:
FROM:
RE:
File
David J. Lown
Anaerobic Bioremediation Study (Remedial Design)
Charlie Macon Lagoon (Macon/Dockery) NPL Site
Cordova, Richmond County
Bruce Thompson with de maximus phoned today to tell me that they
have met the NC requirements for an injection permit and that he
sent a memo to me describing this. Piezometers for a tracer test
have been installed at the site and are in the process of being
slug-tested. The tracer test is scheduled to begin on Monday.
cc: Jack Butler
•
Macon/Dockery Site
Richmond County, North Carolina
August 25, 1993
Ms. Giezelle Bennett
Remedial Project Manager
U.S. EPA, Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Preliminary Design Report
Reply to: Technical Committee
c/o David L. Jones
Clark Equipment Company
P. 0. Box 7008
South Bend, IN 46634
Phone: [phone]
Fax: [phone]
Macon/Dockery Site -Cordova, North Carolina
Dear Ms. Bennett:
Transmitted herewith are seven (7) copies of the Preliminary Design Report for the
subject project. The report is submitted as a four volume set, organized as follows:
Volume 1 -Text
Volume 2 -Drawings and Plates
Volume 3 -Appendices (A through D)
Volume 4 -Apnl:'nrlir:,i,c, (E !h~ou3h 0) • 1
• •
Ms. Giezelle Bennett Page 2 August 25, 1993
• The inability of the PAH degrading organisms to affect a significant reduction in the
concentration of higher-numbered ring PAHs within a time period of less than four
months of treatment. The performance standard stated in the Record of Decision
and Statement of Work for the higher-numbered ring PAHs is a total of 2 ppm for
all constituents. The study also suggests that the reduction in concentration of
these PAH constituents may not reach an asymptotic value less than 2 ppm.
• The requirement for extensive soil amendment and handling procedures to prepare
the materials for bioremediation in a greenhouse treatment cell. The study
indicates that properly amended soil volumes may be three to five limes greater
than the anticipated 1000 cubic yards presented in the Feasibility Study and
Record of Decision. The added volume of amended material could not be
replaced and then capped in the original Lagoon 10 area. It would be necessary
to transport and dispose of large volumes of excess material.
As an alternative to the use of bioremediation for remediating Lagoon 10 materials, the
Group proposes to excavate and dispose Lagoon 10 materials off-site. This alternative
was evaluated in the Feasibility Study and discussed in detail in the Record of Decision.
The advantages of this alternative include:
• The ability to implement the remedy rapidly (3-5 weeks including testing) and
thereby minimizing potential exposure to on-site receptors (hunting club, dogs,
etc.).
• Removal of all residual contamination in the Lagoon 10 area of the site provides
the maximum protectiveness.
• In the likely event that the material will require off-site treatment prior to disposal,
the treatment would be performed at a facility selected by the Group and approved
by U.S. EPA. The off-site disposal would be performed in accordance with the
facility's permit.
• Treatment at the off-site facility will substantially reduce or eliminate the materials'
mobility and may also reduce or eliminate its toxicity.
Due to the nature of the most important issues for discussion outlined above for the
forthcoming meeting, it would be extremely advantageous to have U. S. EPA
bioremediation experts and personnel in attendance. I will be in touch with you in the
next few days to work out the details and other arrangements for the meeting.
• •
Ms. Giezelle Bennett Page 3 August 25, 1993
Please do not hesitate to contact me at [phone] if you have any questions. Thank
you for your continued cooperation on the project.
Sincerely,
Af}~~
David L. Jones
Project Coordinator
Macon/Dockery Technical Committee Chairman
/b
cc: Macon/Dockery Site Group Members Wayne Barto, de maximis, inc. Paul Furtick, RMT, Inc.
State of North cftolina
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
February 21, 1994
MEMORANDUM
TO:
FROM:
Jerome Rhodes
~ A. Preston Howard, Jr.~
SUBJECT: Charlie Macon Lagoon & Drum Site
Richmond County
Project #93-so·
The Division of Environmental Management has completed the
review of the subject document.
The comments for this site are attached to this letter. It
should be noted that this project was received on November 1,
1993 by DEM. Since that time we have received two more revisions
to this project. These comments are submitted for your review,
however they may be out-of-date.
If there are any questions, please advise.
APHjr/sbp/MACON.SWM
Attachments
cc: Allen Klimek
Steve Tedder
Fayetteville Regional Office
Central Files
Groundwater Section Files
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post•consumer paper
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
January 25, 1994
4WD-NSRB
Technical Committee
REGE:tVE ·
JA_N 2 7 1994
SUPERFUND SECTION
c/o David L. Jones
Clark Equipment Company
P.O. Box 7008
South Bend, IN 46634
SUBJ: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Jones:
• .
Enclosed are the Agency's comments on the Intermediate
Remedial Design Report, Plans and Specifications, Construction
Health and Safety Plan, Performance Verification Plan, and the
Remedial Action Work Plan. Please send a response letter to these
comments in sufficient time to allow the Agency to review the
responses, and to allow their incorporation into the next
submittal.
If you have any questions, please give me a call at 404/347-
7791.
Sine
B,lj
Gi e es. Bennett
Remedial Project Manager
• •
INTERMEDIATE REMEDIAL DESIGN REPORT COMMENTS
GENERAL COMMENTS
1. Throughout the report there are references to Appendices and
material found in the Preliminary Design Report, as well as
references to the response letter to EPA's comments. The
Final RD Report should be inclusive of the all previous
reports. Therefore, any material referenced in that report
should be physically included in the final report. Likewise,
the final RD documents should also be "stand alone", includi_ng
actual information and not just references to the previous RI>
documents.
2. Will the pumping of Macon wells coincide with the use ~f SVE
treatment? Do these wells have a large enough influence on
the water table near the SVE wells to beneficially reduce
upswelling of the water table for a vacuum in the vadose zone?
3. For the sake of continuity there should be a discus~ion in
these RD documents on who will operate and maintain the
treatment systems and the acquisition of that
0 & M contractor.
4. It should be confirmed that the design documents will be
"stamped' and signed by an appropriately qualified
Professional Engineer that is registered in the State of North
Carolina.
SPECIFIC COMMENTS
l . Page 1-1, Section l . l ( Background l : · F_or _c_ompletenes s, a
discussion of who the RPs are should be included.
2. Page 1-1, Paragraph 4 -The performance standard for lagoon 10
should also be given.
3. Page 1-2, Paragraph 2 -As stated previously, the only
document that will be approved is the final RD report.
4. Page 2-5, Paragraph 3 -As stated in previous comments,
estimating the extent of contamination using a quantitation
limit above the performance standards is ridiculous. This
paragraph should be rewritten to include a discussion of the
OBVIOUS limitations of using this field screening data. In
the response to comments, please include the new language.
5. Page 2-6. Tables -These tables clearly do not contain a
summary of all data that was collected. As stated above, the
final RD must be complete, and contain all RD field work
results. Also, please indicate which samples are field
screening samples, and which were sent to the laboratory.
6 •
7 •
8.
• •
2
Page 2-26 and Plates 3 and 4 -The monitoring well data should
also be included on these maps to show extent of groundwater
contamination.
Page 2-40, Paragraph 5 -As stated in previous comments,
remediation will not be complete until the levels of TOTAL
inorganics is below the performance levels. This needs to be
indicated.
Section 2.4.2, Paragraph 3 -Include a sentence explaining why
PCE was selected as the organic contaminant for soil vapor
analysis.
9. Page 2-61, Section 2.4.3 (SVE Test Results -Air Emissions) &
Page 3-30, Section 3.4.2 (Air Discharge): Despite the fact
that the overall air emissions apparently appear to be within
regulation standards for "gross" numbers, will there be any
cancer causing compounds (besides the PCE and vinyl chloride
noted) among those emissions that exceed individual
requirements? This should be discussed.
10. Page 2-68, Biodegradation Section -In all probability, the
ROD will be amended to change the remediation of the Lagoon 10·
materials from biodegradation to off-site disposal. However,
the RD should discuss the treatability study, why it failed in
its goal to reach the performance levels, and why
bioremediation will not work here at this site. However, the
comments made in the preliminary design should be incorporated
into this discussion. Therefore, if this document is read
later, and some of the same questions and comments arise, the
discussion here will address those. For questions such as
stirring or addition of various substances at various times,·
simply state that these questions have arisen. Please do not
~ry to fix it up or justify what was done. EPA clearly c~uld
have required the test to be redone.
11. Page 2-79, First line - A word is missing in this sentence.
12. Page 2-81, Paragraph 2 -Delete the last line.
13. Page 2-92, Paragraph 2.8.4 -Please explain the use of the
term "compliance monitoring point."
14. On page 2-95, Section 2.9.2 of the report, there is the
statement "It is anticipated that manganese concentrations in
extracted ground water will already be. below the Performance
Standard, as indicated by the MW21 sample results." The
position of MW21 relative to identified contaminant source
areas (comparison of Plate 1 to Figure 1-2), as well as the
analytical results for the sample from MW21 in Table 2-36,
indicate that this well is located well downgradient of the
most highly contaminated ground water. While the statement
• •
3
about manganese concentrations in extracted ground water,
relative to the Performance Standard, may be correct,
consideration of the MW21 sample is not appropriate for making
such an argument. Therefore, this statement should either be
removed or reworded. This concern is discussed in greater
detail below.
15. Page 2-108 -Delete the last four sentences of this paragraph.
EPA will make the final decision on the remediation of these
wastes.
16. Section 3 (Intermediate Design} & Drawings C04 & COS
/Overall): The document authors should confirm that the
following will be addressed in the next level of the RD:
• Since they form the basis of the system design and
operation methods, a discussion of the systems' control
philosophy and information on alarms, controls and panel,
automation, automatic analysis and system feed back,
interconnections, etc. should be included. This
information is not available on the Process Flow
Diagrams, although at this stage of the RD these drawings
should be all but finalized, as is normal industry
standards, and represent a true Process and
Instrumentation Diagram (P & ID).
• Normal industry practice is to provide an overall
"failure type" analysis indicating the need (or lack of
need) for backup units and the consequences of
failure/shutdown of the system.
17. Page 3-4, Section 3.1.1, (Ground Water Recovery and Treatment
Systems), focusing on Metals Removal:
• The next design submittal should make the determination
of whether to regenerate (on-site or off-site) or to
replace the resin.
• There should be a discussion on why such a comparatively
short (3.5 days) capacity was provided for the metals
removal units. This discussion.should include the amount
of time required to have these units regenerated off-or
on-site.
18. Page 3-4, Section 3.1.2, Soil Vapor Extraction System: Within·
this section, reference appropriate drawings and discuss the
wells' radius of influence
19. Page 3-9, under Section 3.2.1 (Volume of Ground Water
Requiring Treatment): Since it appears that the actual
number of pore volumes of ground water needing pumping and
treatment will exceed the theoretical volume of contaminated
• •
4
' water, there should be a discussion on how these volumes were
calculated.
20. Page 3-9 et al, under Section 3.2.1 (Treatment Scheme) and
Drawing COS:
• Elevated manganese concentrations £f!!! have an adverse
effect on treatment equipment, such as air strippers.
The document (and the 10/15/93 MDSG responses) indicated
that manganese treatment will not be installed priot to
the air stripper. Please discuss the potential for
adverse affects on the air stripper by manganese in the
stripper influent and why the treatment is not indicated
prior to the stripper. Also include in this discussion:
what are the vendor influent requirements for the use of
the shallow-tray air strippers; what provisions have been
included in the process for periodic cleaning of the
stripper? (These had also been commented on in EPA's
9/23/93 letter, comment i/27.)
• To provide equalization (steady state air stripper
influent flow, process ·control and sufficient head for
moving the influent to the air stripper) were feed tanks
(with appropriate discharge pumping) evaluated for the
two Dockery systems? There should be included a
discussion on why these tanks were only included at the
Macon Site.
21. Page 3-10, Paragraph 2 -The emissions from both the air
stripper and the SVE will have to be monitored. EPA cannot
exclusively rely· on modelling information.. In. addition, air
monitoring should be done at the perimeter of the site to
insure that the public is not being adversely affected.
22. ·page 3-13, under Section 3.2.1 (Recovery Well Design): What
criteria will be used for slot-size selection, in comparison
to grain size distribution, and how will that be related to
required well flow? Why is PVC being proposed for the
recovery wells?
23. Paae 3-16, under Section 3.2.1 (Centrifugal Pumps),also spec
11510: There should be a discussion on how the pump discharge
flow will be varied based on system requirements, i.e. will
the pump be throttled back or will it come on/off in response
to levels in either upstream or downstream tanks, etc?
24. Page 3-16, under Section 3.2.1 (Tanks}, also drawing C12·:
Please indicate if these are "backwash" tanks or tankage to
allow regeneration of the magnesium metal removal ion
material.
• •
5
25. Page 3-17. under Section 3.2.1 (Metals Removal Columns):
Previous response #31 in the MDSG 10/15/93 letter indicated
that the text would be revised to indicate that each column
will be valved to allow operation when one column is removed.
This text revision should be made.
26. Page 3-18, under Section 3.2.1 (Shallow Tray Air Stripping
Unit):
•
•
As discussed elsewhere, provisions should be provided, .to
allow cleaning of the stripper. ,
Provisions for varying blower outlet air flow rates ('such
as belt drive or adjustable dampers) to allow for
optimizing the system should be included.
27. Page 3-28 Section 3.4 (Plan for Satisfying Permitting
Requirements): How will permits be addressed for storm water
and erosion control, especially during construction? Also,
how will permits be handled for drilling of any wells,.
building permits, etc.?
28. Page 3-29 -There is no discussion in this report on the
infiltration pits; rationale for their respective sizes and
placements; exactly how they work, etc. Other questions arise
on the specific uses of the well pits and diversion trenches.
This needs to be clear in the report.
29. EPA has previously commented on the proposal in the
Preliminary Design Report to locate extraction wells near the
downgradient margin of the area of_ground water contamination.
Those comments probably did not sufficiently express the range
and depth of concerns about this type of remedial design.
Therefore, these comments provide an expanded discussion of
these concerns, as the Intermediate Work Plan continues with
the "leading edge" design, and the response to EPA's comment
number 26 on the Preliminary Design Report does not fully
address this issue.
By making the recovery well system entirely a plume
containment design, the inherent system efficiency, expressed
in terms of contaminant mass removed per volume of water
extracted, is minimized. Thus, if the volume of water removed
by the pump and treat operation per unit time is fixed,
regardless of the location of the extraction wells, the ground
water remedial time frame should be longer (potentially much
longer) for this type of a design, compared to a design
incorporating ground water extraction closer to the plume
source, or center of mass of the plume.
After operation of such an inefficient ground water remedial
system for a period of time, it could appear that the ground
• •
6
water can simply not be remediated in a reasonable time frame.
This observation would probably result in a petition to EPA to
consider the ground water performance standards unattainable.
Such a scenario is contemplated in the Performance Standards
Verification Plan, Section 3.3. A request for EPA Region IV
to make an "impracticability determination" for this type of
remedial design would be denied. This denial would ensue
because EPA Region IV would have already determined that the
remedial design would be inefficient for attaining remedial
goals. Legitimate "impracticability" must be based on
uncontrollable site conditions, rather than controllable
recovery well design. Thus, in order to evaluate or
demonstrate technical impracticability of attaining ground
water remediation goals, an efficient recovery well design is
required.
As a secondary concern, location of recovery wells at the
downgradient margin of the plume potentially has a component
of contaminant dilution as a significant aspect of the system.
This can most readily be shown through a fairly detailed
modeling analysis. Such an analysis would be a substan~ial,
unnecessary effort in the context of the secondary degree of
concern we have about this situation. However, the dilutiqn
or spreading of contaminants into less contaminated areas
should be avoided if possible in a ground water remedial
action.
Another related concern is that the proposed remedial design
will not effectively (or perhaps even ineffectively) remediate
or otherwise affect the ground water manganese problem over
the areas where ·'it is most critical. · For .example, ground
water manganese concentrations clearly exceed, by a factor of
approximately 20 or more, the Performance Standards in samples
from several wells close to the upper Macon organic
contaminant source areas (Table 2-7, analytical results for
MWOS, MW09, and MW19). It is very likely that the excessive
concentrations of this naturally occurring contaminant are a
result of localized geochemical conditions prevailing near
some of the old lagoons. Manganese is also inherently less
mobile in the subsurface environment, relative to the volatile
organic compounds. Given.these prevailing conditions, the
proposed recovery well system will not deal with the most
serious ground water manganese problems effectively. It may
have no measurable influence on the manganese concentrations.
Clearly, this situation is incompatible with the ground water
remediation levels specified in the Record of Decision for
this site.
Arguments such as that in the section titled "Ground Water
Treatment" on page 3-3 that manganese is naturally occurring
in ground water at such observed high levels are not supported
by available data. A comparison of dissolved manganese
• •
7
concentrations to total volatile organic concentrations and
dissolved oxygen concentrations (report Tables 2-7 through 2-
11) indicates a correlation between dissolved manganese and
these two water quality variables (Spearrnan's rank correlation
coefficient indicates statistical significance at a of less
than 0.02). The attached figure graphically shows the
relationship between dissolved manganese and total
voes/dissolved oxygen. This figure essentially defines
dissolved manganese (point values on the figure) by the other
two variables. This figure clearly shows that at low
dissolved oxygen levels, dissolved manganese concentrations
increase over background values. While the relationship
between dissolved manganese and total voes is less obvious
from the figure, most of the samples with appreciable
concentrations of total voes have obviously higher than
background concentrations of manganese. The correlations
between these three variables may indicate that in the most
highly contaminated ground water, some aerobic biodegradation
of organic compounds is or has been occurring. Under these
conditions, the dissolved oxygen normally present in the .
ground water would be depleted. As a consequence of the lower,
ground water oxygen concentration, the equilibrium .
concentratio·n of manganese dissolved in the ground water would ,
be altered. The design report states on page 3-3 that " ... it
is theorized that naturally occurring manganese may be
solubilized by naturally occurring biological activity in the
source areas." The intended meaning of this statement may be
the same as this manganese data inte~pretation presented in
this paragraph. However, this statement implies that the
dissolved manganese concentrations result from entirely
naturally occurring processes. EPA' s c_on_c_l_us_i_on is that they
do not.
To summarize, the proposed recovery well network will be less
·than optimally efficient for ground water remediation. Some
ground water contaminants may not be captured by the recovery
wells at the downgradient plume margin. Other contaminants
may require long time periods before they are recovered. EPA
strongly recommends that this design be modified, to assure
compliance with the ground water requirements specified in the
ROD, to improve the efficiency of the recovery well system,
and to assure approval of the final RD. The redesign should
be done to supplement the containment action at the
downgradient margin of the plume with additional recovery
wells, located closer to source areas and ground water "hot
spots". This redesign will improve efficiency and reduce the
time frame for ground water restoration, if it is possible to
attain that goal.
30. Appendix B (Calculations): This should also include, at a
minimum: material balances (especially for the ground water.
constituents); air calculations; liquid and soil vapor piping;
• •
8
treatment equipment/system sizing calculations and vendor
information.
31. Appendix H (Specifications) & Page 3-31 & 32, Section 3.5.2
(Draft Specification List):
• General:
• Since these specifications can be considered "Rough
Drafts" at best, the following comments represent a
cursory review, awaiting further information.
• A statement should be added that these
specifications are at an early preliminary stage and
will be greatly expanded upon (and editorially
corrected) in the next submittal, similar to the
note on the drawing referring to the same subject.
• In the Summary of Work article included in eac'h
section, provide a paragraph indicating which
sections are "performance-based".
• As commented on previously, Division 1 normally includes,
at a minimum, the following additional specification
sections: Measurement and Payment; Safety, Health, and
Emergency Response; Chemical Data Acquisition and
Management; Construction Administration (including
Project Meetings); Contractor Quality Control; Operation
and Maintenance; and Air Monitoring (may be in Division 2
or 13). It should be confirmed how these items will be
handled.
• Section 01010 should include Lagoon 10 work.
· • Division 2 (or 13) needs specifications for excavation,
handling, transport, and disposal of contaminated soils,
infiltration galleries, Lagoon 10 work, and demolition
( tank removal) .
• Section 13235, as an example -important parameters
should be added to the specification such as influent
conditions, expected performance criteria, design flow
rate, sizing, etc.
• It should be indicated where, at a minimum, the following
specification sections will be included: Instrumentation
and Control Panels; well materials; metals removal; pipe
other than PVC (since there seems to be a question of PVC
suitability); bioremediation; and filters.
• •
9
INTERMEDIATE RD REPORT (VOLUME 2 -PLATES AND DRAWINGS) COMMENTS
GENERAL COMMENTS
1. It is assumed that as these drawings are developed to complete
bidding documents, they will have additional notes, existing
and new utilities, limits of construction, contractor staging
areas, security fencing, electrical/instrumentation drawings
(if used) and other information added, especially completion
of exact dimensions or coordinates to "tie down" facilities;
2. Where will drawings be included for the air stripper and other
ground water treatment interconnections?
3. Will buried piping be profiled? How and where will air
release valves be located? ·
4. Where will Lagoon 10 work be indicated?
5. Also, please refer to comments relating to drawings that are
included under Volume 1 above.
SPECIFIC COMMENTS
1. Drawing C04, SVE Process Flow Diagram:
2.
• Pressure indicators should be added along lines off of
the SVE wells to allow-observations of flows. ·
• There is a discrepancy between the ball valve indicated
on the elevation drawing and the globe valve indicated on
the process flow diagram.
• The riser piping should be sloped either back towards the
well or towards liquid traps and the manifold piping
should be sloped to liquid traps or sumps at various
intervals.
Drawing COS, Ground Water Process Flow Diagram:
• Initial filters, flow elements, tank level controls, and
interlock logic and feed tanks (for the Dockery Site
systems) should be indicated. Also, why aren't feed tank
effluent pumps used? Gravity discharge from these tanks
to the air strippers may be difficult to arrange.
• Sampling taps should be indicated.
• Pressure switches or other means to monitor possible
blower failure and similar means to indicate metals
removal failure and automate system shutdown should be
included.
• Check valves are missing on the recycle pumps.
• •
10
3. Drawing C12, Pump Pad Plan and Sections: These pads should be
revised to reflect comments elsewhere concerning backwash
tanks and the need for feed tanks on the Dockery System.
RA WORK PLAN COMMENTS
1. Page 1-2, Section 1.1 (Background): For completeness, there
should be a reference included in the text to the RD, by name,
and the RD documents to be used, especially the Drawings and
Specifications.
2. Page 2-2, Section 2.1.2 (Phasing Alternatives): To present a
complete discussion of the contracting alternatives that may
be used, information should be added to the text on what
criteria would be used by the MDSG in deciding to "employ
specialty contractors ... " in place of "a General Contractor
will be competitively procured .. ".
3. Page 2-2. Section 2.1.2 & 2.1.3 (Contractor and Equipment
Availability): Page 3-4, Section 3.1.3 (Regulatory Interface
and Deliverables): and Page 3-8. Section 3.2.4 (Review and
Evaluation of Bid Proposals): In accordance with industry
standards and the above-referenced EPA OSWER Directive, the
text should be revised to indicate that there will be a
submittal to EPA for review on the selection information of
the RA Construction Contractor.
4. Page 2-6, Paragraph 1 -The confirmation sampling plan should
be included in the RD.
5. Page 2-6, Paragraph 4 -Please give an example for each of the
four categories, and discuss the method of disposal. This
peeds to be approved ahead of time and will not be done on an
· ad hoc basis.
6. Page 3-3, Section 3.1.2 (Qualifications (for the RA PM Team))
and Page 4-6, Section 4.2.4 (Qualifications and Experience
[for the IQATJ): In accordance with the Scope of Work,
referenced EPA OSWER Directive and normal industry standards,
the document should be revised to include the actual names and
actual qualifications/resumes of the individuals to fill the
noted positions. This will allow proper review of the
proposed persons' credentials.
7. Page 3-4. Paragraph 3, 2nd bullet -Written notifications of
changes is not sufficient. The PRPs can REQUEST a change
before the event happens, not notify EPA of a change after it
has taken place.
8. Page 3-7, Section 3.2.3 (Pre-Bid Conference): The text should
be revised to indicate that EPA will have the opportunity to
9 •
• •
11
attend this conference, as is normally done in the regulated
RD/RA field.
Page 3-11, Section 3.3.6 (Administration and Approval of
Construction Changes), third paragraph: To prevent any
misunderstanding and minimize "surprises", EPA should be
notified of all impending changes, so that the EPA, not the
Responsible Parties (RP), may determine which changes are
"substantial". EPA would then determine which changes they
would want to review and notify the RA Construction Manager.
The text should be revised accordingly to reflect this
comment.
10. Page 3-12. Section 3.4.1 (Monthly Progress Reports): To
provide a complete picture in the monthly report, the
following element should be added to this report: "Change
Orders -Proposed, Approved and Completed."
11. Page 4-2. Paragraph 4.2.1 -How will the members of the IQAT
be chosen?
12. Page 4-5. IOAT -The IQAT will report to the RA Coordinator
AND EPA. See pages 18 and 19 of the UAO SOW.
13. Page 4-9 & 4-10. "Process and Mechanical COA": To present a
complete picture of the required work for this project
component, the text should be revised to include a paragraph
similar to "all documentation of testing and,test results will
be submitted to the RA Coordinator ... for use in completion of
reports" (as used with other project components).
9. Section 5 /RA Construction Schedule):
Overall comments:
• For explanation and review purposes, and in accordance
with normal RA procedures, discussion should be added to
the text which includes: very brief note on task
breakdown, justification, milestones, constraints, and
opportunities for shortening the schedule. The specific
schedule comment below should also be addressed in this
discussion.
• The overall schedule of approximately 1 1/2 years from
the beginning of the bidding process until actual start
up appears rather excessive and should be reinvestigated.
Certain tasks could be performed simultaneously, such as
the wells could be started earlier in the contract.
Bidding Documents Development:
This should be done during the RD phase and is therefore
• •
12
confusing as being discussed here. Please revise this
accordingly.
Contractor Selection Process:
Five months for this task appears rather
light of using bidder prequalification.
discussed and revised.
long, especially in
This should be
PERFORMANCE STANDARDS VERIFICATION PLAN (PSVP) COMMENTS
GENERAL COMMENTS
1. A discussion should be added on the monitoring of Lagoon 10
cleanup (such as soil sampling or SVE).
2. There is mention on Page 3-4, Section 3.2.4 (Vacuum Vapor
Analysis) of effluent PCE measurements at the discharge stack
and influent PCE measurements at the piping manifold inlet.
However, the Field Sampling and Analysis Plan (FSAP) and
Quality Assurance/Quality Control (QA/QC) Plan do not have
sampling and analysis procedures for these air measurements.
3. Will "frac" type tanks be used to hold the effluent until
discharge requirements can be verified?
SPECIFIC COMMENTS.
-. 1. Page 2-1. Section 2 (Sampling Objectives): A reference should
be added to the Ground Water Treatment System.
2. Page 3-1, Section 3.1.1 (Flow Monitoring): The following
should be discussed:
3.
• How the meters are integrated into the equipment.
• Were flow meters considered to be located downstream of
the treatment system and between each unit operation to
provide optimum process monitoring and control?
• Normally, flow is monitored off each extraction well.
Was this evaluated?
Page 3-2. Section 3.1.3 (Sample Location and Frequency): To
present a complete explanation and to allow for proper review,
there should be a discussion added on the frequency of
sampling during startup. This section is very incomplete.
The frequency of the tests should be presented here, and when
results are obtained, they shall be-sent to EPA with the
4.
• •
13
monthly progress reports, not upon written request. Please
read the UAO.
Page 3-2, Section 3.2 -During the RA, EPA will need ACTUAL
emission rates, not calculated ones. In addition, the
schedule of performance checks on the SVE system should be
given.
..
5. Page 3-4, Section 3.2.4 -Again, this information is given
without the frequency of sampling events.
6. Page 3-5, Section 3.2.5 (System Performance Analyses): Please
clarify that the weekly performance analysis will be started
only after the initial equipment "startup" difficulties have
been corrected.
7. Page 3-6, Section 3.2.8 -The confirmation sampling plan
should be presented here for EPA approval. Describe how the
confirmation soil samples will be collected.
8. Section 3.3 does not state the planned frequency of ground
water monitoring during the first year of recovery well system
operation. In addition, the section should state that the
compliance monitor wells will be installed as specified in the
US EPA, Region IV, Environmental Services Division,
Environmental Compliance Branch Standard Operating Procedures
and Quality Assurance Manual, February 1, 1991.
9. Section 3.3 should include a plan for monitoring wells closer
to contaminant source areas, for determination of ground water
quality changes over time in those areas. __ This plan should be
developed in concert with the redesign of the recovery well
network to incorporate additional ground water recovery wells
in the areas of the most highly contaminated ground water.
·The text states in several places that selected monitoring
wells installed during the RI will be sampled during the ·
Remedial Action. The report should clearly identify those
wells. The report should also provide some justification for
selection of each well proposed for the Remedial Action
sampling.
10. Page 3-9, Paragraphs 2 and 3 -Contaminants of concern will
not be deleted from the analytical program. In addition,
three sampling periods is not long enough to request any type
of waivers.
11. Section 5.4 states that dedicated hailers may be used to purge
monitoring wells prior to sampling. The EPA Robert S. Kerr
laboratory has performed several investigations which
considered the effects of different sampling and purging
devices on observed concentrations of metals in ground water
•
14
samples. The use of dedicated hailers to collect samples has
been shown to commonly produce unrepresentative unfiltered
ground water quality samples with respect to metals (R.W. Puls
et al, EPA/600/M/M-91/040, July, 1990). Research on this
topic of the problems with sampling and purging using hailers
is discussed in Ground Water Volume 32, Number 1, Janu~ry-
February 1994 article by Barcelona et al. The Macon Dockery
site has a history of high metals concentrations in ground
water samples. Based on the comparison of filtered and
unfiltered samples in the Remedial Design Work Plan, these
high metals concentrations are probably largely related to
sampling technique or possibly sampling design. Therefore,
our program cannot agree with the use of dedicated hailers for
purging wells at the Macon Dockery site. Such devices may
also not be appropriate for sampling monitoring wells at the
Macon Dockery site. The Performance Standards Verification
Plan should propose an alternate type of purging/sampling
device and a sampling technique which will minimize the
potential for suspended solids in ground water samples.
12. Section 5.4, page 5-6 -VOA samples may not be collected using
a submersible pump. They should be collected using a bailer
or directly from the teflon tubing.
SPECIFIC COMMENTS -PSVP QA/QC PLAN
1. Page 2-1. Section 2 /Project Responsibility): The following
should be provided to present a complete discussion:
• Organization chart and actual.names and resumes of
proposed staff.
• Will there be a separate QA officer for field activities?
2. Page 7-1, Section 7 (Sampling Site Location and Sampling
Identification): This requires additional text and
information to form a complete "picture" of what will be done.
At a minimum this should include: the type of
information/items expected in the field log books,
corrections, signatures, dating, attention to blank pages,
etc.
3.
4 .
Page 8-1, Section 8 (Calibration Procedures and Frequency):
Discussion on the calibration of SVE equipment should be
included.
Page 11-1, Section 11 (Internal Quality Control Checks): For
ease of review and implementation, text and a table should be
included that indicates the frequency of taking QC blanks.
5 .
• •
15 . ..
Page 12-1. Section 12 (Performance and System Audits): The
audits should not be conducted by the Project Manager but by
someone independent of the project who reports directly to
upper management and who can notify upper management to stop
work, if necessary. This should be discussed in this section.
CONSTRUCTION HEALTH AND SAFETY PLAN/CONTINGENCY PLAN
These comments are only related to general statutory requirements
for the RA Contingency Plan as set out in the above-referenced EPA
OSWER Directive.
1. It is realized that the actual inclusion of names for the
Contingency Plan may be.difficult this far in advance of
construction, however a place for these names should be
indicated in the document, with a notation as to when the
actual names and resumes will be available for EPA review.
2. The following should to be added to this document:
• Clearly delineate (preferably in a form that may be
prominently hung at the job site) the actual names and
phone numbers of the persons responsible for responding
in the event of an emergency.
• Name of the actual person who will give the on-site
training.
• Place and date for meeting with the local community,
including agencies involved with .the cleanup as well as
local emergency squads and hospitals.
• Names of personnel trained in first aid.
• Plan for protection of public and visitors to the job
site.
• Specific discussion and plan addressing the protection of
the local affected population in the event of an accident
or emergency, not just the workers.
3. A copy of the map to the hospital and written directions
should be placed in each vehicle used on-site.
4. The plan should specify the location.of the nearest telephone.
5. EPA recommends that when personnel who have not received the
40-hour personal protection training (e.g., plumbers,
electricians) are working on-site, that they be accompanied by
trained personnel.
TO:
FROM:
SUBJECT:
• •
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 13, 1993
Arthur Mouberry
Groundwater Chief_-,, t ;',,
Kerr T. StevenS"f~Regional Supervisor
Fayetteville Regional Office
Fayetteville ?..egional Office Comments
Charlie Macon Lagoon and Drum Site
Richmond County
Project #93-50
The Fayetteville Regional Office has reviewed the subject project and our
comments are presented below.
Air Qualitv
An Air Quality review of the preliminary remedial design report prepared
by RMT for the Macon/Dockery Remediation Site indicates approximately 1.6
lab/day of volatile organic compounds (VOC) will be emitted when three SVE
wells are operated concurrently (Page 2-72 of the report). This VOC emission
value is significantly lower than level which would require emission controls.
voe emissions in the report are derived from a pilot-scale study. Air
Quality is concerned that the voe emission value would be considerably higher
during full-scale remediation. voe emissions of greater than 40 lbS/day may
adversely effect the General Air Quality in the area and may contribute to an
ozone exceedance for Richmond county, especially :..n the warmer months of the
year. If voe emissions at the site are in fact greater than 40 lbs/day, the
Air Quality Section requests every effort be made to loweR voe emissions {not
excluding the use of control equipment).
Water Qualit•,
A Water Quality review has been conducted of the preliminary remedial
design report prepared by RMT for the Macon/Dockery Remediation Site.
Water Quality prefers that the non-discharge alternative for the disposal
of remediated groundwater be utilized if soil conditions are adequate for such
flow. If the discharge option should be the most feasible, then an
alternative discharge to the Pee Dee River as opposed to Solomon's Creek
should be examined to obtain greater dilution of discharge to stream flow.
Both streams are classified as Class C.
The preliminary design
diffusion appears adequate.
required in accordance with
concept of metals removal followed by air
Upon final design the following items will
the North Carolina Administrative Code:
1) For Subsurface ground absorption systems including infiltration
galleries:
be
• •
(A) soil evaluation of the disposal site conducted by a soils scientist
to adequately evaluate the soils to be utilized for treatment and
disposal down to a depth of seven feet to include, but is not
limited to, field descriptions of texture; color; structure, the
depth thickness and type of restrictive horizons; pH; the presence
or absence and depth of evidence of any seasonal high water table;
recommendations concerning application rated of liquids, solids,
and other wastewater constituents; field estimates of saturated
hydraulic conductivity in the most restrictive horizon; and cation
exchange capacity. Applicants may be required to dig pits when
necessary for proper evaluation of the soils at the site;
(B) design data;
(C) plans of complete system including plan and profile and cross
section views for all relevant systems components;
(D) a map of the site, with topographic contour intervals not exceeding
two feet and showing all facility-related structures and fences
within the treatment, storage and disposal areas, all test auger
borings or inspection pits and the location of all wells, springs,
lakes, ponds, or other surface drainage features within 500 feet of
the principal waste treatment/disposal site(s);
(E) For systems treating industrial waste and any system with a design
flow of over 25,000 gpd, a hydrogeologic and soils description of
the subsurface to a depth of 20 feet or bedrock, whichever is less.
The number of borings shall be sufficient to define the following
( i)
(ii)
( iii)
significant changes in 'lithology underlying the site;
the vertical permeability of the unsaturated zone and the
hydraulic conductivity of the saturated zone, and
depth to the mean seasonal high water table (if definable
from soil morphology or from evaluation of other applicable
available data).
(F) For all projects with a design flow of greater than 25,000 gpd, a
determination of transmissivity and specific yield of the
unconfined aquifer based on withdrawal or recharge test;
(G) Information on the location, construction details, and primary
usage (drinking water, process water, monitoring, etc.) of all
wells within 500 feet of the waste treatment/disposal area;
(H) Degree of treatment (primary, secondary, tertiary);
(I) For industrial waste a complete chemical analysis of the typical
wastewater to be discharged, may include but not limited to Total
Organic Carbon, BOD, COD, Chlorides, Phosphorus, Ammonia, Nitrates,
Total Nitrogen, Calcium, Sodium, Magnesium, Sodium Adsorption Ratio
(SAR) Calculations, Phenol, Total Trihalomethanes, Toxicity test
parameters, Total Volatile Organics, Total Coliforms and Total
Dissolved Solids;
(J) proposed location and construction details of a monitoring well
network;
(K) Any additional information required by the Director in order to
adequately evaluate the disposal facility.
• •
(L) An infiltration gallery shall be designed such that its largest
surface dimension is greater than its depth and no vertical piping
shall be installed within the trench.
(M) An infiltration gallery shall be designed such that disCharges from
the infiltration gallery which reach the water table must be within
the zone of influence of any on-site groundwater recovery system,
and must not cause or contribute to the migration of contaminants
into previously uncontaminated areas. Predictive modeling shall be
used to estimate the zone of influence, infiltration rate,
groundwater movement and flow direction.
(2) Applicants for new NPDES permits requiring construction of water
pollution control facilities shall, in addition to applications required
in Paragraph (1) above, file, in triplicate, an engineering proposal
setting forth the following information:
{A) a description of the origin, type and flow of water which is
proposed to be discharged. Justification and a demonstration of
need shall be provided for expected flow volumes. Flow shall be
determined in accordance with 15A NCAC 2h .0219(1);
{B) a summary of waste treatment and disposal options that were
considered and why the proposed system and point of discharge were
selected; the summary should have sufficient detail to assure that
the most environmentally sound alternative was selected from the
reasonable cost effective options;
{C) a narrative description of the proposed treatment works including
type and arrangement of major components, in sufficient detail to
assure that the proposed facility has the capability to comply with
the permit limits; for commonly used treatment system or components
with well established treatment capabilities, detailed plans and
specifications need not be submitted until the application for the
authorization to construct; however, detailed plans and
specifications shall be required with the permit application for
any system or component without well established treatment
capabilities for the nature of waste or degree of treatment needed
to meet the permit limits;
(D) a general location map, showing orientation of the facility with
reference to at least two geographic re~erences {numbered =□ads,
named streams/rivers, etc.);
(E) a scale location plan of the site showing location of the proposed
treatment works and the proposed point of discharge;
(F) special studies or modelling may be required in cases where the
impacts of the discharge cannot be readily determined by the
Division;
{G) a statement to demonstrate financial qualification and substantial
previous compliance with federal and state laws, regulations, and
rules for the protection of the environment as required by G.S.
143-215.1 (b) (4) (b).
{3) After an NPDES permit has been issued by the Division of Environmental
Management in accordance with this Section, construction of wastewater
treatment facilities or additions thereto shall not begin until final
plans and specifications have been submitted to and an Authorization to
Construct has been issued to the permittee by the Division of
• •
Environmental Management. If an Authorization to Construct has not been
applied for in accordance with the requirements of the NPDES permit
during the term of the permit, the permit will be considered void upon
expiration and future actions will be considered as new application.
Many of the above items are present in this preliminary remedial design
report.
Groundwater
The groundwater recovery and treatment plans are acceptable. The
disposal of treatment groundwater by either of the proposed methods (discharge
or infiltration gallery) is also acceptable. However, infiltration will
probably be difficult in saprolite. Additional aquifer characterization
should be conducted to determine the groundwater flow characteristics within
the bedrock zone. This aquifer characterization should include a survey of
all wells located within 2,000 feet of the sites. The location and an average
daily pumping rate should be determined for each well found in the survey
area, if. any wells exist. Utilizing the above data, a monitoring program
should be designed to effectively track the movement of the contamination
plume for the project life.
KTS/zlc:p~-i,7 ! .
State of North .olina
Department of t:nvironment.
Health and Natural Resources
Division of Solid Waste Management
Jomes B. Hunt. Jr .. Governor
Jonathon B. Howes, Secretory
William L. Meyer. Director
•A~•,~ .a·· ______ .,.
n a _, ____ _
DEHNR
January 25, 1994
Ms. Giezelle Bennett
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365 .. . . -l-13.=~ 51'\ e..irn ecr1a:1-1:>e:s: 131=:i;-tie1 ; CJl}J
RE: Comments on the 60%.RD_Report and the Performance-Standards Verification Plan
Macon/Dockery NPL Site
Cordova, Richmond County
Dear Ms. Bennett:
Below are my comments on the most recent RD report and an associated document.
A copy of the RD Report will be forwarded to the North Carolina Division of
Environmental Management (DEM) for their review. Comments from DEM will be
forwarded when they are received by our office.
With the time available, I have not had an opportunity to review all of the most
recent documents or all the materials available in the files. Some of the questions that I am
asking may have already been answered. I will continue to review the files and may have
additional comments in the future.
In order to adequately design a groundwater remediation system for this site, it is
essential that we continue to refine our understanding of the site hydrology. Between the
30% Remedial Design and the 60% Remedial Design Reports, there appears to be little
done to improve the understanding of the site hydrology. Most of my comments are
intended to make certain that work on the site characterization continues.
1. What is the vertical extent of contamination? Is there contamination in the
bedrock aquifer?
2. Page 2-2, paragraph 3. Piezocones "were completed in order to locate
conductive zones ... " Were conductive zones located?
3. Page 2-3, paragraph 4. The Student's t-test was used to compare hydraulic
conductivities (k) values for different regions. Were the k value from the
monitoring wells included in this determination?
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX 919-71&-3605
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 O't post-consumer paper
•
Ms. Giezelle Bennett
January 25, 1994
Page 2
•
Based on the Student's t-test, it was concluded "At a 90 percent confidence
level, no significant differences were found between the mean k values for the
four areas of the site." In the groundwater-flow model (Appendix G) it was
necessary to vary the k values over 3 orders of magnitude to calibrate the
models. This contradicts the conclusion based on the statistics. Are
additional pump tests necessary? Please explain.
4. The transition zone between the saprolite zone and the bedrock zone seems
to be a permeable zone that is conductive to groundwater flow and the
movement of contaminants. What information has been collected to describe
this zone? What is the permeability distribution for this zone? What is its
thickness and map distribution? Please provide cross-sections showing the
transition zone, structure contour maps showing the top of bedrock surface,
and isopach maps showing the thickness of the transition zone and the
saprolite zone.
5. Page 2-90, Paragraph 4. The results of analyses of groundwater from MW21
shows that the western boundary of the Upper Macon plume has not been
adequately defined. What additional work is being planned to define the
extent of this plume?
6. Performance Standards-Verification Plan. Proposed monitoring wells-MW-24
and MW-25 do not appear to be in locations that can possibly intercept the
migrating contaminant plume as displayed on Plate 5 (Configuration of the
Water Table, May 1993) of the RD Report. Please explain.
Thank you for the opportunity to review these documents. If you have any questions
please contact me at [phone].
GJ:r;J9~
David J. Lown
Environmental Engineer
Superfund Section
State of North Aolina
Department of~vironment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
~~ _____ ti~
,.... a ,,;,;~ .mlll!l11m-ll!llll11.
DEHNR
January 24, 1994
TO:
FROM:
RE:
Arthur Mouberry, Chief
Groundwater Section
Div~sion of Ef'i5~n'7ntal
David J. Lown ~ J:::
Environmental En ineer
NC Superfund Section
Management
Intermediate Remedial Design Report
Charlie Macon Lagoon and Drum Storage (Macon/Dockery)
Cordova, Richmond County, North Carolina
EPA is in the process of completing a Remedial Design for the
. Charlie Macon Lagoon and Dru.m Storage (Macon/Dockery) Superfund
site, a National Priority List site.
Attached is one copy of the Intermediate Remedial Design
Report for the site. This report was prepared by RMT, Inc. -
Greenville, SC for the US EPA, Region IV. Please forward these
documents to the appropriate sections of DEM and submit your
comments to the NC Superfund Section as soon as possible. Due to
EPA timing constraints, the NC Superfund Section has already
reviewed and submitted preliminary comments to EPA Region IV. We
would like to have the views and permitting requirements of the Air
Quality, Groundwater, and Water Quality Sections of DEM.
If you or your staff have any questions, please do not
hesitate to call us at [phone].
Attachment
cc: Jack Butler
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
•
Macon/Dockery Site
RECEIVED
JAN 2 0 1994
SUPERFUND SECTION ,
Richmond County, North Carolina
Reply to: Technical Committee
c/o David L. Jones
Clark Equipment ·company
January 7, 1994 P. o. Box 7008
South Bend, IN 46634
Phone: [phone]
Fax: [phone]
Ms. Giezelle Bennett
Remedial Project Manager
US EPA; Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Macon/Dockery Site -RD/RA
Monthly Progress Report -December 1993
Dear Ms. Bennett:
On behalf of the Macon/Dockery Site Group ("Group") the December 1993 Monthly Progress
Report is being submitted in accordance with Section XV -PROGRESS REPORTS of the
Unilateral Administrative Order (effective date -June 30, 1992) for the Macon/Dockery Site.
This report describes those activities which occurred during the month of December as part
of the Remedial Design Phase of this project.
PROIECT TASKS INITIATED OR COMPLETED THROUGH DECEMBER 1993:
Results of Sampling and Testing and Other Data Received
Results of additional sampling and testing obtained from activities conducted
under the Supplemental Fieldwork Workplan were submitted to U.S. EPA with
the Intermediate Design deliverables on December 20, 1993.
Plans. Reports. Deliverables and Procedures Completed
• Prepared and submitted correspondence to U.S. EPA dated December 7, 1993
which provided responses to comments contained 1n U.S. EPA's
correspondence of November 18, 1993 regarding the "Anaerobic
Bioremediation Pilot Study Work Plan".
• •
Ms. Giezelle Bennett
US EPA, Region IV
January 7, 1994
Page 2
Received analytical results for the Lagoon 10 waste sample collected on
November 9, 1993. The analytical results were tabulated and a thorough
discussion of the results was prepared and submitted to U.S. EPA through
Group correspondence dated December 10, 1993. The discussion of waste
sample analytical results concluded that bioremediation of the Lagoon 1 O
creosote materials is not feasible, and that, excavation and off-site disposal of
the materials is a more appropriate remedial alternative.
Completed preparation and submitted to U.S. EPA on December 20, 1993 the
following deliverables associated with the Intermediate Design:
► Remedial Action Work Plan;
► Performance Standards Verification Plan;
• Construction Health and Safety Plan;
► Intermediate Remedial Design Report; and
• Intermediate Design Plans and Specifications.
TASKS PLANNED FOR IANUARY 1994:
• Receive U.S. EPA approval of the "Anaerobic Bioremediation Pilot Study Work
Plan" and begin work in accordance with the Work Plan project schedule.
Obtain U.S. EPA comments on the Group's December 10, 1993 letter report
discussing the technical feasibility of bioremediating Lagoon 10 creosote
wastes.
Obtain U.S. EPA comments on all deliverables submitted on December 20,
1993 associated with the Intermediate Design package.
PROBLEMS AND DELAY:
No problems and/or delays are foreseen at this time.
Ms. Giezelle Bennett
US EPA, Region IV
January 7, 1994
Page 3
• •
If there are any other questions, please do not hesitate to contact me at 219-239-0195.
Very truly yours,
g ~ -7/~
David L. Jones
Project Coordinator
Macon/Dockery Technical Committee Chairman
DLJ:ns
alt.
cc: Macon/Dockery Site Group Members
Wayne F. Barto, de maximis, inc.
Paul Furtick, RMT, Inc.
• •
Macon/Dockery Site
Richmond County, North Carolina
January 10, 1994
Ms. Giezelle Bennett
Remedial Project Manager
US EPA, Region IV
345 Courtland Street
Atlanta, GA 30365
Reply to: Technical Committee
c/o David L. Jones
Clark Equipment Company
P. 0. Box 7008
South Bend, IN 46634
Phone: [phone]
Fax: [phone]
RE: Macon/Dockery Site -Cordova, North Carolina
Request for Well-Point Abandonment
Dear Ms. Bennett:
During the performance of work for the Supplemental Field Activities in November, 1993, the
owners of the Thompson property expressed their displeasure with the location of several
well-points that were installed during the Pre-Design Investigation in March and April, 1993.
As you may recall, the Thompson property lies between the Macon and the Dockery
properties. The reason for their dissatisfaction was that the well-point locations interfered with
normal farm use of their property for hay production (cutting operations). These well-points
were constructed as temporary installations and served to provide a one-time look at site-wide
groundwater elevations. These well-points were not installed for groundwater sampling
activities. The Group is proposing to remove the well-points to facilitate good public relations
with the Thompson parties.
Accordingly, the Group has requested RMT, Inc. to prepare an out I ine of the field procedures
to be utilized for removing the well points for U.S. EPA's review and approval. The attached
letter from RMT, Inc. outlines the procedures. The work should take between 1 to 2 days to
complete. In order to finish the work prior to the requested February 1, 1994 date given by
the Thompson's, RMT has tentatively scheduled contractors for the week of January 17, 1994.
Ms. Giezelle Bennett
US EPA, Region IV
January 10, 1994
Page 2
• •
Please advise at your earliest convenience if the proposed work and procedures are acceptable
to U.S. EPA. If you have any questions, please contact me at 219-239-0195 or Wayne Barto
of de maxim is, inc. at 615-691-5052. Thank you for your continued assistance on this project.
Very truly yours,
/5/~;;;:'~
David L. Jones
Project Coordinator
Macon/Dockery Technical Committee Chairman
DLJ:ns
alt.
cc: Macon/Dockery Site Group Members
Wayne F. Barto, de maximis, inc.
Paul Furtick, RMT, Inc.
; .
!
• •
r· . '···January 10, 1994 .
' '
Mr. David L: Jones, Manager
Environmental Technology
Clark Equipment Comp'any ·
100 North Michigan Street
P. 0. Box 7008
South Bend, Indiana 46634
Subject: Macon/Dockery Site . ..
Proposed Wellpoint Abandonment
Dear Mr. Jones:
r
During the Macon/Dockery Remedial Design/Remedial·Action field screening program, temporary well
points were installed at several upper and lower Macon/Dockery site locations. These temporary well
points were installed in March and April 1993 to obtain water level data to better describe ground
water flow. Direct Push Technology (i.e., the analogue of the Dutch Cone Penetrometer) was
employed for temporary well point installation. Well points were constructed from 1-inch I.D. schedule
40 PVC well screen and riser and were completed inside approximately 2-inch diameter boreholes.
Native materials were used to backfill the well points, which were finished at the surface with 4-inch
square, 5-foot long locking steel security covers set in 1 foot by 1 foot well pads. The temporary well
point grout column extended approximately 1 foot below surface grade.
The Direct Push work was performed according to the Macon/Dockery Field Sampling and Analysis
Plan (FSAP) with minor modifications that were approved by US EPA field overslte personnel. A
complete description of Direct Push Technology and field results, including well points, is presented in
the Macon/Dockery Remedial Design Report.
Several of the temporary well points are located on property owned by Thompson Enterprises of
Rockingham, North Carolina, which lies between the Macon and Dockery properties. In November
1993, Thompson Enterprises requested that the temporary well points (UMWP11, UMWP12, UMWP13,
and UMWP14, Figure 1) located on their property be removed before February 1, 1994. The
Thompson property has an agricultural land use (hay field), and the well points are hindering farming
operations, including a proposed field expansion and routine cutting operations. RMT, Inc. has no
objection to this request from a technical standpoint, since the wellpoints were meant to be temporary
to provide information on site-wide ground water elevations during the pre-design investigation.
Therefore, RMT proposes to mobilize to abandon well points UMWP11, UMWP12, UMWP13, and
UMWP12 during the week of January 17, 1994. Well abandonment procedures will conform to the
procedures contained in the North Carolina Administrative Code, Title 15A, Subchapter 2C, Section
.0100, Well Construction Standards, and US EPA Region IV's ECBSOPOAM.
INC.
g:\data\sheny\macon\7001716.ltr
RMT, INC. -GREENVILLE, SC
100 VEROAE BOULEVARD • 29607 -3825
P.O. Box 16778 • 29606-6778
803/281-0030 • 803/281-0288 FAX
i ' I
• •
Mr. David L. Jones, Manager
January 10, 1994
Page 2
TEMPORARY WELL POINT ABANDONMENT PROCEDURE
The four temporary well point locations illustrated on Figure 1 will be abandoned by overdrilling and
tremie-grouting the borehole. All boring abandonment operations and procedures will be recorded
and documented in a hard bound field notebook. Samples of soil, ground water, or potable water will
not be _collected for laboratory analysis during this field effort. The abandonment procedure will be as
follows.
• Before starting the abandonment procedures, RMT will measure the depth of each
temporary well to confirm well construction. Well construction diagrams show the
depth of UMWP11, UMWP12, UMWP13, and UMWP14 to be 25 feet, 25 feet, 23 feet,
and 13 feet below surface grade, respectively.
• The concrete pad and above-grade protector will be removed. If possible, the well
point screen and riser will be removed at this time.
• The hollow stem auger drilling method (minimum 2-1/4-inch I.D. augers) will be used
to overdrill the well point borehole and any screen or riser remaining in place. Each
borehole will be overdrilled a minimum of 1 foot of the tagged depth or the depth
given on the well construction diagram, whichever is greater. The cut1ings generated
through the borehole overdrilling will be containerized in DOT-approved 55-gallon
drums.
• After the well point borehole is overdrilled, the open borehole will be grouted with a
cement bentonite grout slurry. This slurry will be emplaced through a tremie pipe set
within 3 feet of the bottom of the open borehole. The cement bentonite grout slurry
will be mixed using approximately 94 pounds of Portland cement, 7 gallons of water,
and 1 to 2 pounds of bentonite. The water used to mix the slurry will be obtained
from an on-site potable water source. The cement bentonite grout column will be
brought to within 3 feet of surface grade. This will keep the grout column at sufficient
depth so as not to cause damage to farming equipment. The remaining open
borehole will be filled with a cut1ings, sand, and bentonite mixture to the land surface.
• The drill rig, drill rods, and augers will be decontaminated prior to performing well
abandonment drilling operations. This equipment will be decontaminated through
high-pressure steam cleaning, using water from the on-site potable water source.
Equipment decontamination will take place on the decontamination pad.
Decontamination wash fluids will be containerized in DOT-approved 55-gallon steel
drums. All 55-gallon drums will be relocated to the centralized storage location at the
Macon site.
g:\data.\shcmy\macon\ 7001716. ltr
rs:71
•
Mr. David L Jones, Manager
January 1 o, 1994
Page 3
•
It is our understanding that you will forward this information and request to US EPA for approval.
Time is of the essence in order to perform and complete the work prior to February 1, 1994, as
requested by the Thompson parties. Please advise ff you have any questions or comments.
Sincerely,
RMT, Inc.
~J(l.~/d
Paul A. Furtick
Project Manager
Attachment
cc: Project File
Charles Rowan
Wayne Barto, de maximis, inc.
g:\data\sherry\macon\7001716. ltr
r:31
•
,'
Macon/Dockery Site
Richmond County, North Carolina
December 20, 1993
Ms. Giezelle Bennett
Remedial Project Manager
U. S. EPA, Region IV
345. Courtland Street
Atlanta, GA 30365
RE: Intermediate Design Deliverables
Macon/Dockery Site, Cordova, North Carolina -
Dear Ms. Bennett:
• RECEIVED
DEC 3 0 1993
SUPERFUN0 SECTION
Reply to: Technical Committee
c/o David L. Jones
Clark Equipment Company
P. 0. Box 7008
South Bend, IN 46634
Phone: [phone]
Fax: [phone]
Transmitted herewith are seven (7) copies each of the following documents which are required
for submittal with the Intermediate Design:
• Remedial Action Work Plan;
• Performance Standards Verification Plan;
• Construction Health and Safety Plan;
• Intermediate Remedial Design Report; and
• Intermediate Design Plans and Specifications.
Within the documents listed above are many references to the projected remedial work for the
Lagoon 10 area of the site. As you are aware, the Group prepared a technical letter report
regarding the Lagoon 10 creosote wastes and submitted it to you on December 13, 1993. The
letter report presents the results of resampling of Lagoon 10 materials and analyzes the data
to draw conclusions which support the Group's previous position stated in the Bioremediation
Treatability Study Report submitted with the Preliminary Design. In summary, the letter report
concludes that bioremediation is not the appropriate technology for the Lagoon 10 creosote
wastes and recommends that the remedy be modified to provide for excavation and off-site
disposal. Excavation and off-site disposal permanently removes the Lagoon 10 source area
and satisfies the nine (9) CERLCA evaluation criteria to a greater degree than the other
remediation scenarios evaluated in the Feasibility Study.
Due to the fact that U.S. EPA received the letter report document only one (1) week ago and
that you have indicated to de maximis, inc. that agency review comments may not be received
until January 21, 1993, the Group instructed RMT to prepare the Intermediate Design
deliverables with the appropriate language to indicate that the Lagoon 10 materials would only
• •
Ms. Giezelle Be_nnett· Page 2 December 1 7, 1993
be excavated and disposed of off-site if U. 5. EPA's approval of the Group's recommendation
is obtained.
During preparation of the letter report regarding Lagoon 10 remediation, discussions were
held with two (2) separate off-site disposal facilities regarding acceptance of the materials.
These discussions were based upon each disposal facility's review of the analytical data for
the Lagoon 10 waste. The facilities indicated that the material could currently be accepted for
disposal. Should U. 5. EPA accept the Group's recommendation to change this portion of the
remedy, the Group would propose to expedite the Lagoon 10 remedial action. This portion
of the remedial action involves site work which does not require a detailed engineering
design, but will require a clear and logical sequence of procedures which would be
adequately described in a task specific work plan prepared for U. 5. EPA review. Once
U. 5. EPA approves the work plan, it would be incorporated into an RFP package for the
Group's selection of a contractor. Implementation would only proceed after U. 5. EPA's
completion of the public notice and comment procedures for the ROD amendment. Should
U. 5. EPA approve the Group's recommendation for Lagoon 10 contained in the letter report,
the details and extent of work that could be potentially expedited can be mutually discussed
and worked out between the Group and the U. 5. EPA. We have pointed out these issues in
this letter merely to advise U. 5. EPA of potential scheduling options and scenarios.
You will note in the design plans accomp,111ying the Intermediate Design Report that the
number and location of extraction wells req,11rpd to recover and contain the four (4) distinct
plume areas have been modified since tlw Pn•l1111i11,1rv Design submittal. These refinements
are based upon the numerical modC'l1111! th,it w,is performed to enable projections of
withdrawal rate and cone of depression I" ,u:1d,ir11·, with a greater degree of precision. Minor
modifications to the Upper Macon ,.,,-,.,. 1,1111 ""II layout have also been made to
accommodate recent requests by the 1 h, "'" '" "' 1 >,irl 11•s to exclude the "open-field" portions
of their property from consideration for 11,,,.,11.,,,."' 111 ,lily future permanent well structures.
The realignment of extraction wells to.,,,,'""'" .1.,1,· this request is submitted herewith and
we believe the re-design effectively co,11.,11,, ""' pltun,• boundary sufficient to eliminate any
further downgradient movement of affpc1,•d l!'""""",iter above performance standards.
The Intermediate Design submittal also d.,,., not, or11,1111 any information from NC DEHNR
regarding permitting status for effluent dis, h.irg<', '"'"' ,1ir stripping systems. RMT's contacts
to date with NC DEHNR have indicated 1il .. 1 th .. ,· do not routinely review "draft" permit
application packages (which we would haw 10 ,uhrllll ,it this point). It was also indicated that
if review of a draft permit was provided, thP Croup would be required to pay $1,200 for
review of the draft application and another $1.200 tor review of the final application package.
At the time that NC DEHNR was contacted coric,•rn111g this, RMT had not yet performed the
site infiltration tests and therefore, the viability oi using infiltration galleries as a means of
effluent disposal was still in question. Now th,it the infiltration tests liave been successfully
completed, and it is obvious that this will be the preierred method of effluent disposal, the
Group would like to proceed with submittal of c1 draft Non-Discharge Permit Application to
NC DEHNR in order to determine the permit limits thc1t will be required for effluent disposal.
• •
Ms. Giezella Be.nnett· Page 3 December 17, 1993
Since NC DEHNR indicated to RMT that they would cooperate with U. 5. EPA in this matter,
the Group would like to request your assistance in obtaining NC DEHNR's agreement to
review a draft permit application and to waive the initial review fee. We would be pleased
to arrange a conference call with all parties if you feel that_ would be the appropriate
procedure:
Please contact me at [phone] or Wayne Barto of de maximis, inc. at [phone]
if you have any questions concerning this letter, the transmitted deliverables, or to arrange the
above-mentioned conference call. Thank you for your continued assistance on this project.
Very truly yours,
.,--,
f, . ' .-,, .. ;,,,_,,: ) /' /2,·u:,·/ /,:. ,,.,,. ~ ✓ A_/.-.. ✓
David L. Jones
Project Coordinator
Macon/Dockery Technical Committee Chairman
/b
encs.
cc: Macon/Dockery Technical Committee
Wayne F. Barto, de maximis, inc.
Paul Furtick, RMT, Inc.
State of North c&nna
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
COPY
October 29, 1993
TO: Arthur Mouberry, Chief
Groundwater Section
•A,a,_,~-~'1
cG A «i:,,, ,~i&IIEI ii Q ii ►
DEHNR
Division of Environmental Management
FROM:
RE:
David J. Lown 'ii).f
Environmental Engineer
NC Superfund Section
Preliminary Remedial Design Report
Charlie Macon Lagoon and Drum Storage (Macon/Dockery)
Cordova, Richmond county, North Carolina
EPA is in the process of completing a Remedial Design for the
Charlie Macon Lagoon and Drum Storage (Macon/Dockery) Superfund
site, a National Priority List site.
Attached is one copy of the Preliminary Remedial Design Report
for the site. This report was prepared by RMT, Inc. -Greenville,
SC for the US EPA, Region IV. Please forward these documents to
the appropriate sections of DEM and submit your comments to the NC
Superfund Section as soon as possible. Due to EPA timing
constraints, the NC Superfund Section has already reviewed and
submitted preliminary comments to EPA Region IV. We would like to
have the views and permitting requirements of the Air Quality,
Groundwater, and Water Quality Sections of DEM.
If you or your staff have any questions, please do not
hesitate to call us at [phone].
Attachment
cc: Jack Butler
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
• State of North Carolina
Deportment of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
·~·~~~-. ;,,; '
•• 0
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&R ft 0: ,1:. • sea-
DEHN R
October 26, 1993
Ms. Giezelle S. Bennett
Remedial Project.Manager
United States Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Comments on Supplemental ·Fieldwork for the Intermediate Design
Macon/Dockery Site
Cordova, Richmond County
Dear Ms. Bennett:
As I indicated to you in our phone conversation this morning,
the workplan for additional RD fieldwork for the Macon/Dockery
Site, in Cordova, North Carolina was received and reviewed. We do
not have any comments on the proposed work at this time.
I am looking forward to working with you on this and the other
projects that we share.
If you have any questions or comments, please do not hesitate
to contact us at [phone].
~Q
Da;id J. Lown
Environmental Engineer
NC Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Eauo\ Opportunity Affirmative Action Emp\cyer 50% recycled/ l 0% post-consumer paper
• • UNITED STATES ENVIRONMENTAL PROTECTION f.GENCY
REGION IV
SEP 2 s 1991'
4WD-NSRB
Technical Committee
c/o David L. Jones
Clark Equipment Co.
P.O. Box 7008
South Bend, IN 46634
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
RE: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Jones:
ttt.G[tJ"ltU
SEP 2 7 1993
SUPERFUNllSECflON
Attached are EPA' s comments on the Preliminary Design Report submitted on August 26,.1993. Please note that this report is not required to be "finalized", ·nor will this report be "approved". The attached comments will be incorporated into the 60%' RD Submittal which is due on December 21, 1993.
If you have any questions, please give me a call at 404-347-7791.
Sine
i elle S. Bennett
Remedial Project Manager
\
Printed on Recycled Paper
• •
COMMENTS
1. Page 1-1. Line 2 -Change "finalized" to "reissued".
Paragraph 2 -Throughout the report, the term "constituents of
concern" is used. This needs to be changed to "contaminants
of concern" •
Background Section -This section needs to include a brief
summary of the site history and a description of the site.
First time reviewers were also thrown by the terms "upper" and
"lower". This report should be able to stand alone without
having to refer back to the RI/FS.
2. Page .1-2. Delete the last sentence of Section 1. 2. The
report will not be approved.
3. Page 2-2. Delete the words "field oversight personnel". If
modifications are made, EPA is the approving agency.
4. Page 2-7. Paragraph 2 -This discussion needs to include some
analytical comparison to support the conclusion that the field
screening data are generally comparable to the laboratory
data.
Paragraph 3 -The discussion regarding methylene chloride
needs to include at least one hypothesis as to the occurrence
of the false positive. This discussion also requires
analytical comparison.
5. Page 2-8. Why is groundwater presented in ppm? Groundwater,
especially for organics, is usually presented in ppb.
6. Page 2-16. Paragraph 1 -There is an unstated assumption that
laboratory data are more reliable, which contradicts the
assumption that field and lab data · are comparable. This
should be commented on and addressed as noted above.
Paragraph 2 -"J" values from DQO Level 4 data are used by EPA
for all aspects of a project. Therefore, all such data must
be used for gw as well as soil evaluation.
Paragraph 3 -The quantitation limit of 0.005 ppm
performance standard for a number of contaminants.
the extent of the gw plume still may not
established.
is above the
Therefore,
have been
7. Page 2-17. Paragraph 4 Please check the maximum
concentrations given for these compounds. For example, the
1
• •
highest value for vinyl chloride appears
well UMA03A, not 0.391 as indicated here.
0.015, not 0.014.
to be 0.538 ppm in
Benzene should be
8. Page. 2-19. Paragraph 1 To properly indicate this
information, a figure should be provided in this report
showing the information discussed in this paragraph, as well
as giving a general delineation of the plumes determined
( summarizing and simplifying the information presented in full
size drawing Plates 3 & 4).
9. Page 2-20. Top of page -Further justification should be
provided concerning the statement: "Based on observations
during the pumping test, extracted water is ... start-up
activities." What time frame is anticipated for this and how
will suspended solids be dealt with until they are "naturally"
reduced, if that does indeed occur?
10. Page 2-38. Section 2.1.3 of the report discusses an aquifer
test which was conducted to support the recovery well remedial
design. This· section presents the pumping well and
observation well/piezometer layouts, the test conditions such
as pumping rate and duration, and the ultimate results of the
aquifer test. However, the report does not present the actual
test data (time-drawdown tables and time-drawdown plots for
the wells and. piezometers) . This information should be
included, so that an independent evaluation of the data may be
performed.
11. Page 2-50. Paragraph 1 -Please note: Before the treated
water is discharged, it must meet performance standards, and
remediation will continue until all wells meet performance
standards for organics as well as inorganics.
12. Page 2-52. Table 2-16 of the report doesn't correspond to the
surface soil sampling location data presented in Figure 2-3.
The text states that the sample data of Table 2-16 represent
a composite of samples, but it is unclear exactly which
samples shown on Figure 2-3 were combined to yield the
composite samples described in the table.
13. Page 2-53. Paragraph 1 -The last sentence is unclear, and
must contain either a typo or too many words.
Section 2.3.1 -If the species of choice was not used in the
evaluation, then the evaluation is incomplete and conclusions
such as those on 2-56 cannot be· drawn.
14. Page 2-55. Paragraph 1 -"Significantly" is a subjective
word. Either the contaminants have or have not affected the
organisms. Please reword.
2
• •
15. Page 2-70. Air Emissions -OVA measurements do not give
accurate quantitative data; support findings with material
balances. Aside from the 40 lbs/day voe limitations, are
there criteria for lbs/day of hazardous/carcinogenic
compounds? Do the emissions comply with NIOSH requirements
for compounds such as PCE and vinyl chloride? Additionally,
the air strippers from the water treatment plant may bring the
overall site emissions to levels above 40 lbs/day. Recommend
using at least vapor-phase GAC if emissions are in fact low.
16. Page 2~12. Conclusions_ -There should be a discussion here on
how the flow from the different size wells will be "balanced"
to achieve reasonably equal flows from all of the extraction
vapor wells, since they are of different diameter and distance
from the suction unit.
17. Page 2-73. Include a listing and discussion of the "inherent
limitations" for the bench-scale testing, and the potential
influence of these limitations on scale up factors to be used
for design.
The discussion on the material encountered seemed to be new
information beyond what had been presented before, especially
concerning the material beneath the liner. Due to the nature
of this material, and its potential leaching effects on the
groundwater pollution, there should be a separate discussion
on this material below the liner and how it will be dealt
with.
How were the actual samples made up: i.e .. , did they contain a
mixture of all of the material encountered in all of the
layers? Due to the dramatically different nature of the
different layers, why weren't these sampled, analyzed, and
tested differently, in addition to a composite sample?
18. Page 2-76 ~ How was it determined that the ratio of 100:4:4
was acceptable?
19. Why wasn't the SDS solution used from the beginning? There
should be a discussion, and backup justification, on what
effect not adding this solution from the beginning had on the
outcome of the tests.
Was gas flow from the reactors only checked on the 29th day,
and then seals tightened and the pressure increased? If this
was only done on the 29th day, then there should be a
discussion, and backup justification, on how the lack of the
proper amount of air flow, up until that time, affected the
test. If airflow up to day 29 was not adequate, why wasn't
the test restarted, since adequate air is one of the primary
factors in any biological aerobic testing?
3
• •
Why was stirring only started on the 30th day of the test?
There should be a discussion, and backup justification, on how
the lack of stirring affected.the test. What would have been
the effect if the stirring had taken place at more frequent
intervals? How would the stirring have been done in full-
. scale tilling ( if ex-situ) or use of patented soil mixing
equipment (if in-situ)?
20. Page 2-82. Paragraph 2 -There should be further discussion
and explanation on what initial concentrations were assumed
( since Day O values were below the detection limit of the
equipment used) when evaluating the rate of biodegradation of
the PAH compounds.
21. The measure of success used to determine the feasibility of
bioremediation, a reduction of total carcinogenic PAHs ( cPAHs)
to 2ppm in 100 days, is not flexible enough for an innovative
technology like bioremediation. A more useful approach would
have been to look at the rates of degradation of the cPAHs
with time to estimate the time required to reach any endpoint.
However·, the data generated in this study cannot be used to
calculate rates accurately because many of the cPAH analyses
are reported as less than a certain number, and only 2 or 5
replicates were analyzed. It is very likely that 2 or 5
replicates is not a large enough number of samples to generate
a reasonable standard deviation. In other words, the error in
the average concentrations reported for cPAHs is very likely
relatively large. Unfortunately, the standard deviations for
these results were not presented.
Because the evaluation criteria of attaining an endpoint by a
specific time was used, the sampling should have been
concentrated on day O and day 100 (per workplan comments) to
generate the most significant results possible given a fixed
number of· samples. Instead, the cPAH numbers tell almost
nothing.
The qualitative nutrition analysis turbidity test was
conducted even though comments on the workplan suggested that
the test was of que.stionable value. RMT concluded from this
test that phosphorus was the only nutrient additive needed.
However, it was later determined from soil sampling during the
treatability test that (1) pre-amendment soil levels of
phosphorus were in excess of generally accepted requirements
(pg 2-88), and (2) for the first 30 of the 100 day test, the
soils were nitrogen limited. Additional nitrogen was finally
added at the 30 day. Thus, (1) the turbidity test gave
incorrect results as to what nutrient additions were needed,
and (2) the bioremediation process, as evaluated by attempting
to achieve a specific endpoint in a specific time period (2ppm
cPAHs by day 100) was seriously hampered by the low nitrogen
levels during the first 30 days.
4
• •
The evaluation of bioremediation was also hampered by improper
control of soil pH. The report describes a drop in pH with
time during the treatability test in the bioreactors.
Although the pH of the soil could have been adjusted at t=0 to
the optimal pH of 7, the study began at a suboptimal level of
pH 5. 8. It is generally accepted that pH for biological
systems must remain between 6 and 8 to avoid significant loss
of rate of biological activity. The pH remained unadjusted
until it dropped to as low as 4. 6 by day 50. Adjustment of pH
at day 50 raised only 3 of the 7 bioreactors to pH>6. Thus,
suboptimal pH levels existed in all bioreactors to a lesser or
greater time period making it very likely that suboptimal
biodegradation rates were measured. Again, the treatability
test was not a fair evaluation of bioremediation.
It is not clear that an adequate amount.of oxygen was supplied
to the bioreactors. Because the exit gas composition was not
analyzed, there is no guarantee that at any time during the
study the oxygen concentration did not drop to rate-limiting
levels in the soil bed. In addition, the report states that
the pressure of the feed air line was increased on day 29 due
to the lack of air flow from the reactor gas effluent line.
Thus, it is not clear how many days of the first 29 had any
air flow. Inadequate oxygen levels would halt the aerobic
biological activity. Again, this problem, as well as others
noted above, must bring into question the validity of using
this experiment to determine the (lack) of effectiveness of
bioremediation.
The design report states, "Overall, the experimental
configuration was specifically designed for optimum PAH
degradation, which included maintaining optimum soil moisture
and nutrient availability for PAR-degrading microorganisms."
However, as described above, optimum conditions were . not
maintained. Low nitrogen levels and low pH values, ·tor
significant portions of the study, and uncertainty as to
whether sufficient oxygen was available during all or portions
of the study, occurred. The study's results should not be
considered useful in determining the feasibility of
bioremediation at this site.
22. Page 2-89. Last line -Delete the sentence "This would ...
Lagoon 10 excavation."
23. Page 2-90. In the last line· of the first full paragraph,
replace "Statement of Work" with "ROD".
24. Page 2-91. If easements or access agreements are needed, they-
should be obtained as soon as possible. Check the language in
the UAO for more specific information.
25. Page 3-1. This section states that· "two Dockery sites will
5
• •
have independent recovery and treatment systems" and Page 3-2
discusses a "sump of the centrally located air stripper. "
Drawing COS shows 3 strippers each labelled "AS-1". Please
clarify the number of air strippers and coordinate drawings
and text.
26. Page 3-2. A comparison of Drawing CO7 to Plate 4 indicates
that the groundwater recovery system which has been considered
for the Upper Dockery area relies on pulling contaminated
groundwater through the aquifer to near th_e downgradient
margin of the area of contamination. This type of recovery
system will move groundwater from the more highly contaminated
areas to areas of lower contaminant concentrations.· This
recovery scheme will probably be less efficient than a system
where recovery wells are located in the areas of the highest
contaminant concentrations. The same general comment applies
to the Macon site recovery well locations shown on Drawing
COB. While the recovery well locations would be effective
from a plume containment perspective, a more efficient removal
of contaminant mass per unit time (i.e. a more efficient
groundwater restoration system) should be achieved by locating
recovery wells near the downgradient plume margin and in the
areas of higher groundwater contaminant concentrations.
Refinements of the recovery well placement during subsequent
Remedial Design phases should consider optimization of the
contaminant mass removal.
The projected inorganic contaminant concentrations in the
proposed recovery well areas are potentially less than what
may be anticipated for areas closer to the center of the
observed VOC contaminant plumes. Thus, projected requirements
for metals treatment may need to be reconsidered or upgraded
for groundwater recovered from areas of higher organic
contaminant concentrations.
27. Page 3-3. Is the sole purpose of the manganese removal to
meet performance standards of is it also a pretreatment unit
to protect the packed-bed air stripper from the plating
effects of manganese?
Provide discussion on backwash and/or regeneration of the
metals removal system.
Provide discussion on cleaning of the air stripper packing.
Air stripper emissions are not discussed here or shown on
Drawing COS.
If obtaining an NPDES permit is strongly being considered, the
PRPs should begin the permitting process early so that the
schedule will not be impacted.
6
• •
28. Page 3-5. Capping has not been chosen as an option at this
site. Therefore, all discussion of caps as well as
comparisons of caps to offsite disposal should be deleted.
29. Page 3-7. How will the temporary bag filters be handled in
the design specs and drawings?
30. Page 3-8. The preliminary process flow diagram is shown on
Drawing COS, not CO4.
For the treatment of metals, please refer to the UAO, SOW, and
ROD. This treatment should be done in accordance with these
.documents.
31. Page 3-14. If the metals removal columns are sent offsite for
regeneration, will .the treatment system have to shut down, and
if so, for how long?
32. Page 3-20. How will this SVE mass balance be affected by more
or less thari 3 wells on line? Also, since the wells will be
different sizes, how will that affect this mass balance.
33. Page 3-21. Was consideration given to the use of a flame trap
in the piping upstream of the vacuum pump? Was a Rotron type
blower considered in place of a vacuum pump?
34. Page 3-25.
document?
Why wasn't vessel removal included in this
35. Page 3-28. Will these specifications be prescriptive
( specifying exact equipment) or of the performance type
( specifying only overall goals and general requirements -
requiring the construction contractor to complete the final
details of design? Please indicate which will be used and the
rationalization for the method chosen.
Division 1: Sections also usually include: Health and
Safety, Emergency Response, Measurement and Payment, Security,
Sampling and Chemical Data Acquisition, and Contractor Quality
Control. Normally, the majority of these sections include
requirements for the Contractor's submittal of the appropriate
plans defined by the specification section.
Specification should be included for: bioremediation; any
additional treatment unit operations required (such as
suspended solids or metals removal); and instrumentation.
36. Page 4-1. At the bottom of the page, the text states that
additional information is needed to determine if infiltration
is suitable for the discharge of treated groundwater. The
additional field work is proposed during the intermediate
design phase of the RD. It is not clear from this discussion
7
• •
exactly what type of test is proposed, the number of the
proposed tests, or the location of the tests. In addition,
this additional, work should not delay the overall RD schedule.
37. Page 4-2. A proposed plan for conducting a passive anaerobic
bioremediation pilot study is proposed. The proposed study.
will " ... evaluate the efficacy of using new technology ... for
enhancing reductive microbial dehalogenation of PCE and TCE."
Unspecified nutrients and substrate will be injected into the
groundwater in a particular part of the Upper Macon area in
order to determine how this process may work at the site.
While EPA supports the use of innovative technologies for
groundwater remediation, this report provides far too little
information on the proposed process and the projected outcome
of the process for us to concur with this proposal. Specific
concerns are as follows:
• The materials which would be injected into the groundwater
are unspecified. At a minimum, the proposed pilot study would
have to meet the substantive requirements of state laws
governing the construction and operation of Class V injection
wells, unless there is some provision for a waiver of these
ARARs. State Class V well permitting regulations require an
analysis of the chemical, physical, biological and
radiological characteristics of the injected fluid (North
Carolina Administrative Code Title 15, Chapter 2, Subchapter
2C, Section .0211 (c)(l)(M)(iii)). There are also specific
State Class V regulations which apply to "Wells Used in
Experimental Technologies (NCAC Title 15, Chapter 2,
Subchapter 2C Section .0213 (c)(2)).
• The byproducts resulting from the interaction of the
injected fluid(s) with the groundwater and aquifer material
should be predictable, with a high degree of certainty, before
the _process is allowed to proceed in an open system. If the
process results in the formation of hazardous substances, or
increases the mobility of hazardous substances in the
environment, then it is unacceptable for use in a groundwater
remedial action at this site. The procedure has the potential
to enhance the mobility and toxicity of groundwater
contaminants, if it does not result in complete dehalogenation
of the chlorinated compounds. Aside from this concern, the
potential for enhanced mobility of other substances such as
naturally occurring metals should be fully evaluated before a
field test of this procedure begins at the site.
• A complete discussion of any previous tests of this process
(preferably with the referenced studies reproduced and
submitted) should be provided. Specific concerns are the
applicability of any such .studies to the hydrogeologic
8
• •
conditions at this site and the degree to which the process
has been documented.
• While the end products of dehalogen~tion may be relatively
non toxic dechlorinated compounds, the kinetics of the
successive dehalogenation steps should be quantified, both
before the field test (i.e. described in previous test results
which may or may not be applicable to the Macon site) and
should be quantified during the actual field test, if
approved. If the process results in production of vinyl
chloride at one rate and production of the dehalogenated end
product at a slower rate, there may be expansion of the vinyl
chloride plume in uncontaminated portions of the water table
aquifer.
• The potential maximum total injection rate and conditions
which would result in the most significant cone of impression
on the water table must be considered in modeling the
potential direction and rate of movement of the treated
groundwater and reacting injectate/groundwater during and
.after the pilot study. Movement of contaminated groundwater
into currently uncontaminated areas is unacceptable. The
report states on page 4-5 that no extraction of groundwater is
planned. Extraction of groundwater may be necessary in order
to avoid movement of groundwater contamination into previously
uncontaminated areas.
38. Drawing C04-:-Where is the condensate going?
39. Drawing COS -Include flow elements on each well and a flow
totalizer. Include level switch elements on tanks and flow
elements prior to each unit operation and prior to discharge.
May need to measure pressure differential across the metals
removal operation and across the stripper.
The drawing does not indicate the "shared water source ... drawn
from the sump of the centrally located air stripper" discussed
on page 3-2.
• 40. NOAA comments. The constituents of concern to NOAA and those
most likely to be potential harmful contaminants to NOAA trust
resources are inorganics. Most of the analytical results
presented for groundwater samples are below NOAA screening
levels for these contaminants. One exception is mercury on
the Upper Dockery site where mercury levels reach 1.8 ppm for
MW15. These levels are not repeated in the other wells for
the portion of the site, however, the detection limits for
mercury are above chronic effects levels for aquatic
organisms.
9
• •
Even though some constituents were above screening levels, the
site· does not seem to be grossly contaminated with
contaminants that are of concern to NOAA. Given the treatment
plan that is proposed, further contamination downgradient of
the site should be reduced so that the possibility of future
contamination from onsite sources will hopefully be reduced.
In this respect, the proposed remedial design will most likely
reduce any potential risk that the site poses to NOAA trust
resources.
Contamination within Soloman's Creek is still an issue that
has not been sufficiently addressed. NOAA resource use in the
creek is unknown at this time, but it is very likely that it
is used as a nursery area for some NOAA trust resources. A
limited investigation into the resource use and possible
contamination of the creek would be necessary to properly do
an ecological risk assessment for offsite habitat that may
have been affected by the site. In order for NOAA to grant a
covenant-not-to-sue ( CNTS) to the PRPs, NOAA would need
information regarding the absence or presence of contamination
within Soloman's Creek and any potential risk that it might
pose.
10
--, .
State of North (a)lina
Department of •ironment,
Health and Natural Resources
Division of Solid Waste Management
Jomes B. Hunt, Jr., Governor
Jonathon B. Howes, Secretory
September 24, 1993
Ms. Giezelle Bennett
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
SUBJECT: Review of Preliminary Remedial Design Report, Volumes 1-4
Charlie Macon Lagoon and Drum Storage NPL Site
Cordova, Richmond County, North Carolina
Dear Ms. Bennett:
The referenced documents have been received and reviewed by
this office. The following comments are offered by. the North
Carolina Superfund Section.
1.
2 •
3 •
Page 2-17. Section 2.1.1
This section indicates that the southern boundary of affected
groundwater could not be determined due to the inability to
take groundwater samples.· No other mention was found as to
whether or not this information was needed or what affect this
would have on the final design of the groundwater remediation·
system. Additional information to address this should be
included in the design documents.
Page 2-19. Section 2.1.1
A statement is made that a water table divide is located in
the upper portion of the Upper Macon area. Upon review of the
water table map (Plate 5), this divide appears to start
directly east of the Upper Macon area and not at all in the
upper portion of that area. Please clarify.
Pages 3-4 through 3-5. Section 3.1.3
While it is .noted that the bioremediation study did not appear
to be effective, selection of an alternate remedy will need to
be conducted either by an Explanation of Significant
Difference (ESD) to the original ROD, or by an amended ROD.
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone 919-733-~996 FAX 919-733-~810
An Equal Opportunity Affirmative Action Emp!oyer EiJ% recycled/ l 0% post•consumer paper
• Ms. Giezelle Bennett
September 24, 1993
Page 2
4. Pages 3-4 through 3-5, Section 3.1.3
•
Concerning the proposed off-site disposal of the Lagoon 10 materials, the State of North Carolina has specific preferences regarding disposal. The first preference is to use on-site disposal technologies followed by off-site options. We, therefore, would like to see some investigation of potential on-site options before settling for the off-site disposal method.
5. Page 3-25, Section 3.3
Issuance of an ESD or ROD amendment to address the ineffectiveness of the bioremediation treatability study may impact the schedule noted in this section.
6. Page 4-1, Section 4
The same comment as# 3 regarding the potential need for and ESD or a ROD Amendment for selection of the off-site disposal alternative.
7. Pages 4-2 through 4-5, Section 4 The proposal to use the Microbial Reductive Dehalogenation for the chlorinated solvents involves the use of. nutrient injection wells which requires a specific permit from the Di vision of Environmental Management. Typical information needed for this permit includes:
Identifying the chemical nutrients
Injection procedures (rates, volumes, pressures, temperatures, etc.)
Well construction details
Geographical location
Hydrogeologic information
Topographic maps, cross-sections, etc. The Groundwater Section within the Division of Environmental Management should be contacted directly to obtain the specific permit application requirements.
Also regarding this proposal, it would seem that appropriate ROD modifications (i.e. ESD or Amendment) would be necessary before this remedy could be allowed.
The North Carolina Superfund opportunity to review these documents. about this, please contact me at (919)
Section appreciates the
If you have any questions
733-2801.
Sincerely,
Patrick Watters
Environmental Engineer
superfund section
•
UNITED STATES ENVIRONMENTA.L PROTEC.TION AGENCY
REGION I.V
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
MEMORANDUM
DATE: August 26, 1993
SUBJECT: Macon/Dockery NPL Site
Cordova, North Carolina
FROM: Giezelle
Remedial
TO: RD Review Team
Dave Hill/Bill O'Steen, Water
yf"atrick Watters, r:c DEHNR
Waynon Johnson, NOAA
James Lee, DOI
Joan Mattox, Cincinnati ORD
Norma Eichlin, COM
Nt«;tu ~ff.OJ
AUG27 1993
SUPEflflJPJ!)Sft,roM
Attached is the 30% Remedial Design Report for the above referenced
site. Please review it and.give me any comments that you may have
no later than September 17, 1993. If you have any questions,
please give me a call at 404-347-7791. My fax number is 404-347-
1695.
Thank you for your continued support.
Printed on Recycled Paper
•
Macon/Dockery Site
Richmond County, North Carolina
July 30, 1992
Ms. Giezelle Bennett
Remedlal Project Manager
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365 .
Reference: Macon/Dockery Site RD/RA
Reply to: Techn\i:.C.~lt..lfctiiiii\i!~~ee
c/o.')ID£via." L. Jones
Clark Equipment;. Company
P. o. Box 7008
South Bend, IN 46634
Phone: [phone]
Fax, 219-239-0238
Annual Summary Report• June 30, 1992 through June 30, 1993
Dear Ms. Bennett:
Transmitted herewith is the Annual Summary Report which has been prepared by RMT,
Inc. in accordance with Section XV -"Progress Reports" of the Unilateral Administrative
Order (UAO). This report covers the time period of June 30, 1992 (UAO effective date)
through June 30, 1993.
The Remedial Design (RD) Project Schedule contained in the U.S. EPA-approved RD
Work Plan has been revised to incorporate the 30-day extension for submittal of the
Preliminary Design Report. The revised project schedule is attached herewith. Please
note that submission of the Final Remedial Design package remains scheduled for June
15, 1994, as originally specified in the U.S. EPA approved RD Work Plan. If you have
any questions concerning the contents of this report, please do not hesitate to contact
me at [phone].
Sincerely,
~i. (L __ .
0~
David L. Jones
Project Coordinator
Macon/Dockery Technical Committee Chairman
/mdm
Attachment
cc: Macon/Dockery Site Group Members
Wayne Barto, de maximis, inc.
Paul Furtick, AMT, Inc.
File:ASP.03\projocts\3068
88Z0 18Z £08Q.
1111
I
July 30, 1993
Mr. David L Jones
Project Coo,dlnator
Macon/Dockery Technical Committee Chairman
c/o Clark Equipment Company
P.O. Box 7008
South Bend, lndlana 46634
SUBJECT: Macon/Dockery Site RD/RA
•
Annual Summary Report -June 30, 1992, through June 30, 1993
Dear Mr. Jones:
RMT has prepared this Annual Summary Report on behatt ol the Macon/Dockery Site Group (Group)
for the June 1992 -June 1993 period, In accordance with Section XV -PROGRESS REPORTS of the
Unilateral AdmlnlstratlVe Order (effactlve date -June 30, 1992), Issued by the United States
Environmental Protection Agency (US EPA) for the Macon/Dockery Site. This report describ$5 those
activities which occurred during the twelve months since June 30, 1992. as part ot the Remedial
Design phase of this project.
PROJECT TASKS INITIATED OR COMPLETED THROUGH JUNE 1993
The followlng tasks were Initiated or completed as part of the Remedial Design phase of the
Macon/Oockery Site during the twelVe-month period since June 30, 1992:
• On July 15, 1992. a Statement of Qualnicatlons was submitted to US EPA Identifying
AMT. Inc., to serve as the Supervising Contractor on behalf of the Macon/Dockery Site Group.
Mr. Thomas Devine of RMT was designated as the Project Coordinator on behalf of the Group.
• Representatives for the property owned by the Macon and Dockery parties were notified that a
preliminary site visit was planned by RMT. Authorization for the site visit was obtained and
scheduled for July 20, 1992. Mr. Kenny Gulledge of Crown, Cork and Seal Company, Inc.
accompanied RMT representatives to the Macon/Dockery Site during the July 20, 1993 site
vislt.
• Mr. Thomas Devine, Project Coordinator, visited US EPA's office In Atlanta and reviewed the
file for this project. From Mr. Davine's review, ii was determined that the Information presented
was not the complete Removal Action file. Mr. Devine was unable to review the OSC's log of
the removal activities. as US EPA had decided the log had not been properly cleared by the
former OSC or counsel.
h:\data\common\gtorla\annual1.rw
RMT, INC. -GREENVILLE
100 VEROAf Bu1111vARn GmNVILlf, SC 29601-3825
INC. P.O. Box 16778 GmHYlllE. SC 29606-6778
80J/281-00J0 803/281-0288 FAX
·::is ·1Ao ·1 ·w -~ 88Z0 18Z l:08Q.
•
Mr. David L Jones
Macon/Dockery Site Group
July 30, 1993
Page2
Subsequently. a Freedom ol lnformatloo Act Request was submitted by Mr. Jim Marter of AMT
on July 21, 1992. This request was for documentation of any and all removal activities at lhe
sites and also documentation of any and all on-she relocation/containment of wastes into
Lagoon 10, Including details of any treatment actions taken prior to backfilling and capping lhe
lagoon.
• On July 30, 1992, the Macon/Dockery Stte Group provided evidence of their llnanclal ability to
complete tha work and pay all clalms.
• On September 9, 1992, US EPA no1Hled Mr. Thomas Daggett, Esq., Group Chairman, that
AMT had baen approved as the Group's Supervising Contractor.
• Correspondence dated September 25, 1992 was received, which outlined EPA's decision not
to allow modifications to the SOW as previously requested by the Group's Supervising
Contractor. However, In this correspondence, us EPA stated they were receptive to
considering RMTs approach to the SOW In the RD Workplan to be submitted.
• On October 8, 1992, the following deliverables were submitted to the US EPA for review and
approvaVcomment.
Remedial Design Workplan
Sampllng and Analysis Plan
Field Sampling and Analysis Plan
Quality Assurance Project Plan
Bloremedlatlon Traatability Study Workplan
Health and Safety Plan
A Technical Memorandum dOcumenting the need for additional data was submitted to the US
EPA with the RO Workplan.
• On November 17, 18, and 23, 1992, comments on the Remedial Design Workplan and
associated documentation were received from us EPA.
• On December 4, 1992, responses to us EPA comments on the Remedial Design Wolkplan,
the Sampling and Analysis Plan, the Health and Safety Plan, and the Bioremediation
Treatability Study Workplan were submitted to us EPA.
• On December 16, 1992. a conference call was conducted involving Ms. Glezelie Bennett, US
EPA RPM, representatives lor each ot the Group members, end representatives for RMT.
During the call, explanations were provided to a number of questions asked by Ms. Bennett
regarding responses submhted on December 4, 1992.
h:\d•t•\common\glorl•\ar'U'lual1.rtN
gaze rnz 1:0as
Mr. David L Jones
Macon/Dockery Site Group
July 30, 1993
Page3
•
• On December 22, 1992, a complete revised set of responses was submitted to US EPA.
• On December 30, 1992, Ms. Bennett advised that the revised responses were acceptable, but
requested AMT to revise the response to US EPA's Comment No. 8 for the Sampling and
Analysis Plan.
• On January 15, 1993, revised responses to US EPA comments on the Sampling and Analysis
Plan were submitted.
• On January 21. 1993, rePf9sentatl11es of the Group, AMT, and s911eral subcontractors visited
Iha site. During this site visit, the scope of work for the ground water field screening activities
was reviewed with In Situ Technology -the intended subcontractor for this work. Mr. Jack
Butler, Environmental Engineering Supervisor of the Superfund Section for the State of North
Carolina. along with two associates, also participated In the site visit.
• On January 25, 1993, the Group and RMT were advised by Ms. Glezelte Bennett that the
Remedial Design Workplan and associated documents had been approved.
• On February 8, 1993, RMT's proposed schedule for field screening actlllltles was submitted to
US EPA. A revised schedule was submitted on February 10, 1993 to US EPA postpooing the
start of site activities by one week.
• On February 15, 1993, correspondence was submitted notifying US E;:PA that the Group had
retained de max/mis, Inc., a project management firm, to provide a limited oversight role on an
as needed basis of the Group's Supervising Contractor. RMT. Inc. With the same
correspondence, the Group notified US EPA that Mr. Dave Jones, Chairman of the Group's
Technical Committee, would serv11 as the Group's Project Coordinator in place of
Mr. Tom Devine of RMT.
• On F11bruary 17, 1993, ground water field screening activities were begun. In addition to
Group and RMT representatives, Ms. Giazelle Bannan and Mr. 518118 Hall with us EPA wer&
present.
• On February 18, 1993, test pits wem dug Into Lagoon No. 1 O and samples obtained for the
purposa of eonductlng the bloremediatlon treatability study for the materials in the lagoon.
• On Febn.iary 24, 1993, US EPA was notified of two proposed changes to the approved Field
Sampling and Analysis Plan. The first change Involved revising the sample locrulon
designations to more precisely identify the sample location with respect to the speciflc area of
the site. The second change Involved the decontamination procedure for In-Situ Technology's
h:\data\common\glort.\annual1.rwY
•
Mr. David L Jones
Macoo/Dock81"y Site Group
July 30, 1993
Page4
sampling and 'drilfing• equipment. Toe specifics for both of these changes were preaented In
Mr. Dave Jonas· letter to Ms. Giezelle Sennett dated February 24, 1993.
• On February 26, 1993, US EPA was notified that RMT Intended to sample the existing walls at
the site beginning on March 15, 1993. This notHicatlon letter also stated that sampling for the
ecological SSS9!1Smenl would begin on Monday, March 1, 1993.
• 0 n March 1, 1993, RMT personnel visited the site to collect samples required for the
ecological ass8S9ment. This activity wa,i completed on March 2, 1993.
• On March 15, 1993, sampling of the existing ground wat8f wells began. The sampling
methods and procedures were discussed several times between Group representatives,
US EPA and their oversight personnel, and AMT and, as a resun, were modnied from those
outlined In the US EPA approved Sampling and Analysis Plan. This work was completed by
March 25, 1993. The procedural modifications for the ground water sampling were submitted
to the Agency In the Group's correspondence to US EPA dated March 22, 1993.
In addition to the required samples, RMT also collected a round of filtered ground water
samples for dlssotved metals analysis. Samples from six of the wells were also coll8¢1ed for
ferrous Iron analysis. The ferf()(Js Iron samples were collected from monitoring wells MW-5,
MW.f',, MW-9, MW-13, MW-16 end MW-18. The ferrous iron analysis will be used In the design
Of the treatment system.
• In accordance with the approved Remedial Design Workplan, field screening activities to
evaluate the ground water conditions at the site were continued In March. Sample results
obtained In March were provided to US EPA with the Monthly Progress Report for March.
Field screening activities W8fe completed on Wednesday, March 31, 1993.
• Preliminary results were received In April for bioassay tests, inorganic surface soil, surface
water, sediment, and vegetation samples, and organic surface soil and vegetation samples.
Preliminary laboratory r9Sulta were obtained for the semlvolatile organic compound11,
lsophorone, total metals, and volatile organic compounds for selected monitoring wells.
• For the purposes of performing the svr;: pilot test, the Installation of one (1) soil vapor
extraction (SVE) well and five (5} observation wells in and near Lagoon 7 was Initiated during
the week of April 5, 1993, and was completed on April 12, 1993. The SVE pilot test was
subseqL1011tly conducted and completed on April 15, 1993.
• A r9Vlsed project ,ichedule for the remaining Remedial 0estgn field activities was prepared end
submitted to US EPA on April 22, 1993.
h:\data\oommon\glorlalannual1.ttN
88?:0 18?; t08Q.
11. Ill
Mr. David L Jones
Macon/Dockery Site Group
July 30, 1993
Pages
•
• Examination of preliminary data lrom the field screening activities end groundwater sampling
event was performed In order to develop a proposed aquifer pump test procedure. Based on
the new field data examined, a procedure !or aquifer pump test well Installation end a
methodology for performance ol the aquifer test was prepared and submitted to us EPA on
June 3, 1993.
• A letter prepared by AMT. Inc. dated April 28, 1993, wae submitted to US EPA documenting
the Group's proposal for pump test well materials of con8tructlon. A subsequent
teleconrerence call was held on April 30, 1993, with representatives rrom US EPA -
Environmental Services Division, North CBJ'Olina Department of Envlronmental Management,
COM -Federal Programs Corporation, RMT, Inc., end de max/mis, inc. participating. A
common consensus was obtained to allow RMT to proceed with well Installation procedures
the following week using the materials of construction outlined In the April 211. 1993
correspondence.
• Analytical results from sampling the existing monitoring wells were provided 10 !he Agency
with the Monthly Progress Repon for May 1993 submitted on June 9, 1993. The progress
report also included preliminary results from the ecological assessment for bolh the
compositional analysis of vegetation and the bioassay results.
• On May 10, 1993, the Group received US EPA and NC DE;:HNR comments on the Aquifer Test
Procedure submitted on April 29, 1993. The Group submitted responses to these comments
In a letter to tho Agency dated May 13, 1993.
• Additional Agency comments were received during a phone call on May 17, 1993, and were
responded to by the Group's correspondence of May 18, 1993. US EPA subsequently
approved the Group's Aquifer Test Procedure through their letter of May 19, 1993.
• Installation of one reC0Very well and two plezometers for the aqultBt pump lest was completed
on May 13, 1993. Followlng US EPA approval, the test was initiated on May 19, 1993 and
completed on May 22, 1993. The pumping test was conducted for a total of 64 hours,
consisting of 52 hours_ of pumping and 12 hours of recovery.
• All of the pump test water generated from the aquifer pumping test was containerized on site
in a frac tank. Arrangements for disposal of this water have been made with the City of
Rockingham,
• The folfowlng analytical results were submitted to the Agency with the Monthly Progress
Report ror June, 1993 submitted on July 9, 1993:
t\:\data\comman\glorl•\.rw1ual1.tw
aazo rnz 1:0aQ.
•
Mr. David L Jones
Macon/Dockery Site <3roup
July 30, 1993
Page 6
• Field screening (hydrooone) laboratory confirmation;
• US EPA blanks and spikes:
• CLP data fot the field, rlnsate, and trip blanks;
• Recovery well (aquifer pumping test) samples:
• Wat.er supply samples; and
• Frac tank composite sample of treated pump test water.
• On June 3, 1993, the complete text of the revised Aquffer Test Procedure was submitted to
US EPA as requested. Tois revision incorporated the Agency's comments.
• On June 7, 19!13, RMT's survey team returned to the site and surveyed the data points
established during the field actlvttles.
• On June 21, 1993, the complete CLP data packages for the spikes and blanks provided by
US EPA, and the split samples from the monitoring well sampling were provided to US EPA.
• On June 23, 1993, a Pump and Haul Permit Appllcatlon was submitted to Mr. KerrT. Stevens,
Of NC DEHNR's FayettB\lllle Office, requesting approval to dispose of containerized pump test
wlllllr at the Rockingham, N.C. POTW. Through negotiations wtth Mr. Larry Cobler,
Rockingham Plant Operations Director for the POTW, the city agreed to accept this water.
This acceptance was based on Mr. Cobler being provided with laboratory analysis of the
treated water. A copy of Mr. Cobler's letter ol acceptance was provided with the June 1993
Monthly Progress Report
• On June 29, 19!13, RMT collected live ground water samples from existing monitoring wells.
These samples were collected for the use or Group member, DuPont, to evaluate the feasibility
of bioremediation for VOCs in groundwater at the site. This sampling procedure was
Independent of other sampling activities for the site outlined In the US EPA approved RO
Workplan. The field sampling pro~dures utilized by AMT did, however, conform with those
approved by US EPA In the RD Workplan. US !:PA was verbally Informed of this sampling
activity prior to RMT's stte visit.
• During June 1993, RMT began to incorporate all of the field information into the development
of preliminary design plans lor the site.
h:\do1a\common\glorlal,onnualt .,..,
•
Mr. David L Jones
Macon/Dockery Site Group
July 30, 1993
Page7
TASKS REMAINING TO BE ACCOMPLISHED
• Dispose of the pumping test watel'8 being temporarily stored on site. (Note: NC 0EHNR
Pump and Haul Permit Issued on July 7, 1993, and pump test water disposed at Rockingham
POlW on July 28, 1993),
• Complete preparation of the prellmlnary design dellverables as required by The Unilateral
Administrative Ordsr (UAO)-Statement or Work.
This submittal, Including tables, figures, plates, drawings, and appendices will be made to
US EPA on August 26. 1993. This date Incorporates a 30-day extension into the original
schedule which has been requested from and approved by US EPA. The extension request
was documented In the Group's correspondence dated July 22, 1993.
• Prepare and submit the Intermediate Design package, which Includes the elements described
In the UAO-Statement of Work,
The Intermediate Design defiverebles, Including tables, figures, plates, drawings, and
eppendicas Is JJl'Ojected to be submitted to US EPA on December 21, 1993.
• Prepare and submit the Prefinal/Finel Design package, which Includes the elements described
In the LIAO-Statement of Work.
This submittal, Including tables, figures, plates, drawings, and appendices as required to
complete the Prefinal/Flnal Design package, Is PfOJected to be made to US EPA on
April 13, 1994, !or the Prefinal Design package and on June 15, 1994, for the Final Design
Package.
• Implementation ol the Remedial Action will occur In accordance with the schedule approved
by US EPA In the Final Design package.
SCHEDULE FOR IMPLEMENTATION OF THE REMAINING WORK
The Remedial Design Projllct Schedule approved by US EPA has been revised to incorporate the 30-
day extllnslon granted by Ms. Glezelle Bennett on July 20, 1993, for submittal of the Preliminary
Mr. David L. Jones
Macon/Cookery Site Group
July 30, 1993
Page 8
•
Design Report. The revised schedule Is attached. Please note that the revised project schedule
provides tor submission of the Final Remedial Design package by June 15, 1994, as originally
specified In the US EPA approved Remedial Design Workplan.
If there are any questions or commems, please com act me at 803-281-0030.
Sincerely,
AMT, Inc.
Pt1. ~.1.J..
Paul A. Funlct<
Project Manager
h:\dato\oom.,,.,n\glo~•ltnnuall .rw
U,ED ST ATES ENVIRONMENTAL. PRO-TION AGENCY
REGION IV
345 COURTLAND STREET. N.E
ATLANTA. GEORGIA 30365
HtCE\VtU
OCT 1 :i 199t
MEMORANDUM SiPlBfUNDUL9N
DATE:
SUBJECT:
FROM:
TO:
October 13, 1992
Macon/Dockery RD/RA Documents
Cordova, North Carolina
Giezelle S. Benn~tt. ~ Remedial Project n
Macpn Review Te
\/Jack Butler, NC DEHNR
Dave Hill/Bill O'Steen, water
Steve Hall, ESD
Wade Knight, ESD
Waynon Johnson, NOAA
James Lee, DOI
Attached is the Remedial Design Workplan, the Sampling and Analysis
Plan, the Health and Safety Plan, and the Bioremediation
Treatability Study Workplan. The PRPs are proposing an approach to
the design that is slightly different than what is proposed in the
ROD. Please review and send any comments that you may have to me
no later than November 3, 1992.
If you have any questions, please give me a call at 404/347-7791.
Thank you for your continued support.
Printed on Recycled Paper
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•
State of North Carolina
Department o_f Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
.l:imcs G. Martin, Governor
William W, Cobey, Jr., Secretary
FAX TRANSMITI'AL RECORD
William L Meyer
Director
From: ____________ , Solid Waste Management Division
, Solid Waste Section ------------
, Hazardous Waste Section ------------
c lvurh /le. :;; s l)C! C Ir ' Superfund Section
Date:
To:
Re:
No. of Pages (Including Cover)
Division of Solid Waste Management
Hazardous Waste Section
Superfund Section
Solid Waste Section
Confirm receipt of document(s)
[phone]
[phone]
[phone]
[phone]
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