NCD980840409_20060918_Charles Macon Lagoon Drum_FRBCERCLA RA_Interim Remedial Action Report-OCR

I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report If , , 8 1006
I,
i Charles Macon Lagoon and Drum Storage ~iteSEP
Cordova, Richmond County, North Ca~olina-
EPA ID: NCO 980840409 i . _. ~~...:,.-~·-1"-
Prepared for
US EPA Region 4
September 18, 2006
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
REMEDIAL ACTION REPORT
CHARLES MACON LAGOON AND DRUM STORAGE SITE
EPA ID: NCO 980840409
Prepared for the
US Environmental Protection Agency
Region 4
and the
State of North Carolina
Department of Environment & Natural Resources
&~~a
NCDENR
_,H C,,,RQLl~A ~·•·•f>T .... ,N~ 0~
ENVHm•o-«:>rr ,.,.., NAl"lJ ....... REe>O<.mcu
September 2006
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
REMEDIAL ACTION REPORT
RECORD OF PREPARATION, REVIEW, AND APPROVAL
CHARLES MACON LAGOON AND DRUM STORAGE SUPERFUND SITE
SOURCE REMEDIATION BY OFF-SITE DISPOSAL OF VESSEL CONTENTS AND
LAGOON 10 SOILS AND DEBRIS AND
SOIL VAPOR EXTRACTION OF LAGOON 7 SOILS
This report has been prepared in accordance with EPA OSWER Directive 9320.2-09A and will
be used as the basis for development of the site Final Close Out Report once groundwater
cleanup is complete
' lj , 1 -0~ RA Report I ~
Prepared
By: PRP Consultant: Steven lrminger, P.E. / President I I.C., Inc.
September 18, 2006
,.-, -
RA Report ~~ ~~~<lv2 (.1-:
Submitted '
By: PRP Agent: Ken B. Gulledge/ Technical Lead/ MDSG
Septembet 18, 2006
Approved
By: EPA Region4
Approving Official: Giezelle Bennett/ Remedial Project Manager/
USEPA Region 4
Date:
Approved
By:
NCDENR
Approving Official: David Mattison/ Environmental Engineer/
NCDENR
Date:
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE OF CONTENTS
1.0 INTRODUCTION .............................................................................................................. I
2.0 OPERABLE UNIT BACKGROUND ................................................................................ 5
2.1 Performance Standards ............................................................................................... 5
2.2 Remedial Design ......................................................................................................... 5
3.0 CONSTRUCTION ACTIVITIES ....................................................................................... 8
3.1 PRP Initiated Waste Removal.. ................................................................................... 8
3.2 Construction of Treatment Systems .......................................................................... 13
4.0 CHRONOLOGY OF EVENTS ........................................................................................ 15
5.0 PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL. ... 16
5.1 SVE System Performance ......................................................................................... 16
5.2 Quality Assurance and Quality Control .................................................................... 17
6.0 FINAL INSPECTION AND CERTIFICATION .............................................................. 19
6.1 Inspections ................................................................................................................ 19
6.2 Health and Safety ...................................................................................................... 20
6.3 Institutional Controls ................................................................................................ 20
7.0 OPERATION AND MAINTENANCE ............................................................................ 21
8.0 SUMMARY OF PROJECT COSTS ................................................................................ 22
9.0 OBSERVATIONS AND LESSONS LEARNED ............................................................ 24
10.0 CONTACT INFORMATION ........................................................................................... 25
11.0 REFERENCES ................................................................................................................. 27
Figure 1
Figure 2
Figure 3
Table 1
Appendix A
LIST OF FIGURES
Topographic Location Map
Macon Layout Map
Dockery Layout Map
LIST OF TABLES
SVE Air Analysis Summary
LIST OF APPENDICES
Site Characteristics and Operational Data
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Ac/ion Reporl
Charles Macon l.agoon and Drum Storage
Cordova, Hichmond Co11111y, NC
REMEDIAL ACTION REPORT
CHARLES MACON LAGOON AND DRUM STORAGE SUPERFUND SITE,
CORDOVA, NORTH CAROLINA
EPA CERCLIS ID NUMBER: NCD980840409
SOURCE REMEDIATION BY OFF-SITE DISPOSAL OF VESSEL CONTENTS AND
LAGOON 10 SOILS AND DEBRIS AND
SOIL VAPOR EXTRACTION OF LAGOON 7 SOILS
1.0 INTRODUCTION
The Charles Macon Lagoon and Drum Storage Site covers 17 acres on State Road 1103 in
Richmond County, approximately 1.5 miles southwest of Cordova, North Carolina. The site is
composed of the 16-acre Charles Macon Lagoon & Drum Storage site and the 1-acre Dockery
site, which is located 2,600 feet north of the Macon site. A portion ofa United States Geological
Survey Topographical map showing the site location is attached as Figure I.
Land use in the area is agricultural, and woodlands cover over half of the site. The site overlies
an unconfined aquifer, and surface runoff discharges to the Pee Dee River, which is
approximately one mile west of the site. Between the site and the Pee Dee River are two ponds,
two streams, and a swamp.
From the late 1970s to 1981, Charles Macon trucked in waste oil and recycled it at both the
Macon and the Dockery sites using a large boiler on the Macon site to separate the waste oil
from other wastes including spent solvents, acids, and bases. Charles Macon leased five acres of
the Macon site, including the waste oil boiler, to another operator, C&M Oil Company of
Chesapeake, Virginia, in May 1981. Starting at that time, C&M Oil Company arranged for trucks
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Co1111tv. NC
from an affiliated company, B. W. Mitchum Trucking, also of Chesapeake, Virginia, to haul
waste oil from other affiliated corporations in neighboring states to the Macon site and recycled
it there, continuing after Charles Macon died in October 1981. Then, in March 1982, when the
State of North Carolina sued C&M Oil Company and Charles Macon's widow and estate to
compel cleanup of waste oil residues, C&M Oil abandoned the site.
During a site inspection in 1980, the North Carolina Solid and Hazardous Waste Management
Branch (SHWMB) found 12 lagoons containing waste oil and sludge and 2,173 55-gallon drums
containing various chemical wastes. Eight of the lagoons were unlined and overflowing. The
State's analyses of the oil and sludge wastes in the lagoons found lead, chromium, and barium at
concentrations considered hazardous under the Resource Conservation and Recovery Act
(RCRA). The drums contained hazardous substances, which included acetone, methanol,
toluene, vinyl thinners, epoxy, enamels, lacquers, ethyl acetate, methylene chloride, and sodium
hydroxide. Site maps showing the locations of the 11 lagoons at the Macon site is provided as
Figure 2, and the twelfth lagoon at the Dockery site as Figure 3.
In November 1982, the owner's estate started to clean up the site under a State court order
obtained by SHWMB in August 1982. After removal of 300 55-gallon drums and installation of
two on-site monitoring wells, the estate's resources were expended. In November 1983, using
CERCLA emergency funds, EPA began to remove all remaining drums. During 1983, EPA
removed 3,123 tons of waste and 137,000 gallons of oil at the Macon site. In 1984, EPA
conducted similar removal activities at the Dockery site, removing 709 tons of waste. After
removal activities for both properties had been completed in 1984, all but one lagoon, referred to
as Lagoon 10, had been excavated and filled in. Because of the size of Lagoon 10, EPA decided
2
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Nichmond County. NC
to backfill and cap the lagoon without excavating the contents. Lagoon I 0, contained solidified
creosote waste, solidified sludge, 43 crushed empty drums, and contaminated soil from the
cleanup operations at the other lagoons. Lagoon IO was then filled in and capped with 3 feet of
clay. In 1987, the MDSG members and six other potentially responsible parties (PRPs) entered a
consent decree with EPA reimbursing its response costs.
The Macon/Dockery site scored 47.10 out of a total of 100 on the Hazard Ranking System
(HRS). Any site with a HRS score greater than 28.5 is proposed for the National Priorities List
(NPL). This site was proposed for addition to the Superfund NPL in January 1987 because of
actual and threatened releases of hazardous substances. This site was placed on the NPL in July
1987 making it eligible to receive Federal funding for long-term action.
In 1987, EPA sent notice letters to identified potentially responsible parties (PRPs). These letters
invited the PRPs to enter formal negotiations with EPA to conduct a Remedial Investigation and
Feasibility Study (RI/FS) at the Macon/Dockery site. On April 14, 1988, two of the MDSG
members entered into an Administrative Order on Consent with EPA agreeing to perform the
RI/FS. The RI involved the installation of 34 borings and 19 monitoring wells and the collection
of more than I 00 surface soil, sediment, surface water, groundwater, and waste samples.
These MDSG members completed the Rl/FS in 1991, and a final cleanup option was selected in
a formal Record of Decision (ROD) document for the Site agreed to between EPA and the State
in September 1991. In June, 1992, EPA issued an Unilateral Administrative Order to eight of the
PRPs to conduct the design and construction of the remedy for groundwater at both the Macon
and Dockery sites and for soil at Lagoon 7 and soil and debris at Lagoon IO on the Macon site.
3
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond County. NC
Four of the eight PRPs that were named as respondents to the UAO formed the MDSG, and
collectively agreed to implement the Remedial Design and the Remedial Action (RD/RA) The
MDSG's Remedial Design was completed and approved by EPA in 1994, and its construction of
the Remedial Action was completed and approved by EPA in 1996.
This Remedial Acton Report has been prepared for the soil and vessel remediation at the site.
The groundwater continues to be actively remediated and hydraulically controlled by
groundwater extraction and ex-situ aeration treatment technology. An Interim Remedial Action
Report will be submitted for groundwater at a later date.
4
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Reporl
Charles Macon Lagoon and Drum Slorage
Cordova, Richmond Co11111y, NC
2.0 OPERABLE UNIT BACKGROUND
This section details development of cleanup standards and the remedial design for treatment of
soil.
2.1 Performance Standards
The soil remedy described in the ROD was designed to achieve performance standards
based on a risk assessment. The dominating risk assessment exposure scenario was
protection of groundwater. Performance standards or goals for the soil in the area of
Lagoon 7 is a tetrachloroethene (PCE) concentration of 3.0 mg/kg and at Lagoon IO a
total carcinogenic PAH concentration of2.0 mg/kg.
2.2 Remedial Design
The following sections describe the design for the selected remedies at Lagoon IO and
Lagoon 7.
2.2.1 Lagoon 7 Remedy
The soil remedy for Lagoon 7 was selected as vapor extraction. The selected
remedial action for YOC-contaminated soil in the area of Lagoon 7 was in-situ
vapor extraction and a carbon adsorption system to remove off-gas organic
contaminants. The vapor extraction system was designed to operate with four
vapor extraction wells.
Construction of the soil vapor extraction (SVE) system was completed in January
5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond County. NC
1996. The SVE remediation system was operational in February 1996. A Five-
Year Review was completed in 2000. The review authorized sampling to
demonstrate that soils were successfully remediated. Authorization to
decommission the SYE system was provided by EPA after their review of the
confirmation soil sample analytical data. The SVE system was terminated m
200 I and all associated SYE equipment was subsequently removed.
2.2.2 Lagoon /() Remedy
Subsequent risk assessment activities identified the concentrations remaining in
Lagoon IO to be a threat to groundwater and would require remediation. The
Unilateral Administrative Order -Statement of Work for the Macon Dockery Site
required that the feasibility of biological treatment of the organic materials from
Lagoon IO be investigated. The remedy for Lagoon IO was proposed by the ROD
to be in-situ bioremediation. If feasible, the materials would be treated in a lined
waste treatment cell to reach performance standards for specified compounds.
PAH contaminated soil from Lagoon IO was to be excavated and treated in an
onsite, biological waste treatment cell equipped with a carbon adsorption system
to control emissions. After treatment in the biological waste treatment cell the
soil was to be returned to Lagoon IO and covered with a low permeability cap. A
treatabil ity study was performed to evaluate whether bioremediation could
achieve the Performance Standard of2.0 ppm total carcinogenic PAH's within a
reasonable treatment cycle timeframe of I 00 days. The treatability study
indicated that a decrease of total carcinogenic P AH' s to performance Standard
6
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond County. NC
concentrations would not occur within 100 days and would be difficult (if
possible at all) to achieve in any reasonable time period.
Based on Treatability Study findings that bioremediation was not capable of
meeting the performance standards for Lagoon IO within the constraints stated in
the Record of Decision, and based on a subsequent waste characterization study
that indicated a thirty-fold increase in waste volume was likely to result from
bioremediation, the Record of Decision was amended to require source
remediation through excavation of the Lagoon 10 materials that exceeded the
Performance Standard and transport of the materials offsite for disposal.
The ROD called for transferring all vessel (tanks, tankers, vats, boilers, and box
trailers) contents into secure transportation vehicles and dismantling the vessels.
The excavated materials were required to be stockpiled, sampled, characterized,
and transported for offsite disposal at a permitted disposal facility. Hazardous
vessel contents were to be transported to a RCRA-approved facility for disposal
and non-hazardous vessel contents and the vessel pieces were proposed to be
recycled or sent to an industrial landfill for disposal. Excavation and offsite
disposal of the material in Lagoon 10 was completed by October 1994.
7
I
I
I
Remedial Action Reporl
Charles Macon Lagoon and Drum .~·rorage
. Cordova, Richmond Coullly. NC
I 3.0 CONSTRUCTION ACTIVITIES
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
This section describes the tasks conducted during construction of the selected remedy.
3.1 PRP Initiated Waste Removal
The Macon Dockery Site Group initiated waste removal activities 1n June 1994 for
Lagoon IO waste, the vessel contents, and the vessel pieces as required in the Statement
of Work and described in the Workplan for the Removal of Wastes From Lagoon I 0,
Vessels and Drums report dated April I 994. Three remedial activities were undertaken
between June 15, 1994 and October 7, 1994. The creosote waste previously contained in
Lagoon IO was excavated and disposed. Twenty-five vessels had their contents
characterized and removed for disposal. The vessels were then decontaminated and
disposed. The soils beneath the vessels were evaluated and, where necessary, were also
excavated and disposed. Drums containing well cuttings, development water, and
decontamination fluids were disposed. The three remedial activities identified in the
work plan, which are Lagoon IO closure, drum disposal, and vessel disposal, are
summarized below.
Lagoon IO Closure
The Lagoon IO remedial activities resulted in the removal of approximately 200 cubic
8
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond County, NC
yards of clean overburden and a total of 2,704 21 tons of waste and affected soil. The
overburden material was subsequently used as backfill. Analytical testing conducted of
the excavated material reported that seven of 17 representative waste samples exceeded
the Toxicity characteristic Leachate Procedure criteria for benzene resulting in the
transport and disposal of 1,261.47 tons of DO 18 hazardous waste at the Laidlaw
Environmental Services Subtitle C Landfill in Pinewood, South Carolina. The remaining
1,442.74 tons of Lagoon 10 material were shipped to the BF! Nonhazardous Waste
Landfill in Harrisburg, North Carolina.
Confirmation soil sampling of the excavation floor and sidewalls was conducted to
document that the excavation remedy had reached the required action limits. A total of
16 samples were collected and analyzed for carcinogenic PAH's. One sample analytical
result was reported at concentrations greater than the required action limits.
Subsequently, an additional one foot of soil was removed from the area represented by
the sample. Retesting of the area confirmed that the required action limits had been
achieved.
Lagoon IO was backfilled in I -foot lifts with each lift compacted to 90 percent modified
proctor density. A quantity of 1,607 cubic yards of clean fill taken from an adjacent
borrow area was used to backfill the lagoon excavation. Topsoil was not used as backfill
Both Lagoon 10 and the borrow area were covered with topsoil and seeded.
9
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Drums
Remedial Ac/ion Reporl
Charles Macon Lagoon and Drum Slorage
Cordova, Richmond Co11111y. NC
The remedial action for drums resulted in the removal of 561 drums, which included 524
drums from the Macon Site and 37 drums from the Dockery Site. The drums contained
drill cuttings, well development water, decontamination rinsate, and debris generated
during previous onsite investigation activities. The head space of each drum was tested
with an HNu organic vapor meter. Based on the headspace testing, one drum was
separately sampled and analyzed and disposed by Heritage Environmental Services, Inc.
(Heritage).
Solids in the remaining 560 drums were placed into bulk rolloff boxes, sampled and
analyzed. The empty drums were crushed and bulked with the solids in the rolloffboxes
Based on the analytical results, a total of 85 tons of soil and crushed drums were sent to
the BFI Landfill in Harrisburg, North Carolina.
Drummed liquids were bulked in a frac tank with liquids from vessels and treated through
an activated carbon system. The treated water was then analyzed for the performance
standards parameters. Based on the analytical results, one frac tank containing 20,840
gallons of treated water was transported to the Rockingham Publicly Owned Treatment
Works for disposal. A second frac tank containing 18,020 gallons of treated water was
discharged to the ground surface in the vicinity of well MW-19.
10
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Vessels
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova. Richmond County. NC
Analytical characterization of liquids in eight tanks identified them as containing
halogenated oils. The contents of the eight tanks (totaling I 0, 780 gallons) were placed
into a frac tank and transported to Heritage for disposal.
The contents of two tanks were determined to contain lead contaminated oil.
Approximately 400 gallons of oil and sludge were combined with 50 gallons of a similar
waste identified in one drum. In addition, Heritage rinsed the tanker with approximately
1,000 gallons of water to clean the tanker truck of heavy solids. Subsequently, a total of
1,550 gallons of oil, sludge and rinse water were received and disposed by Heritage.
Oil sludge from six tanks and eight vessels were stabilized with quicklime. A total of
32.14 tons of stabilized sludges were sampled, analyzed, and sent to the Laidlaw facility
in Pinewood, South Carolina as a nonhazardous waste.
Water from five tanks and the drums was transferred to two frac tanks, filtered through
activated carbon, and analyzed for the performance standards list of parameters. Based
on the analytical results, one frac tank containing 20,840 gallons of treated water was
transported to the Rockingham Publicly Owned Treatment Works for disposal. A second
frac tank containing 18,020 gallons of treated water was discharged to the ground surface
in the vicinity of well MW-19.
I I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Co1111ty, NC
One tanker containing tar was emptied and the contents mixed with soil for stabilization.
The tar and soil mixture was placed in two roll-offs, sampled and analyzed, combined
with other vessel soils and transported to Laidlaw's Pinewood, South Carolina facility as
nonhazardous waste.
Solids from a second tanker were removed and bulked with other vessel soils and
transported to Laidlaw's facility in Pinewood, South Carolina as nonhazardous waste.
The boiler that was housed in the Vat Building was determined to be constructed with
asbestos containing gaskets. A certified asbestos abatement subcontractor removed the
gaskets which were then sent to the BFI Landfill in Harrisburg, North Carolina.
The vessels were constructed of carbon steel and were recycled (after cleaning) at
Nationwide Tank in Matthews, North Carolina. A total of 14 tanks, eight vats, two
tankers, and one boiler were recycled by Nationwide Tank.
Soil beneath the vessels were evaluated in accordance with the work plan. Based on field
screening and analytical results, two feet of soil was removed beneath three tanks. In
addition, an area of stained soil near the area of wells MW-10 and MW-9 was excavated
to a depth of2-feet below grade. The excavated soil was sampled and analyzed for waste
characterization parameters. Based on the analytical results all of the soil (1,433.88 tons)
was transported to and disposed at the Laidlaw facility in Pinewood, South Carolina as
nonhazardous waste.
12
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
3.2
Remedial Action Report
Charles Macon Lagoon and Drum Slorage
Cordova, Hichmond Co11111y, NC
Construction of Treatment Systems
The PRP' s consultants designed a soil vapor extraction (S VE) system to treat PCE
contaminated soil in-situ at Lagoon 7. The construction of the SVE system occurred
simultaneously with construction of four groundwater treatment systems. The major
tasks and sub-tasks for construction activities (in approximate chronological order) were:
Contractor Selection Process
Bidder pre-qualification
Issue bid documents
Pre-bid conference
Review and Evaluate bids
Construction contract negotiations
Construction contract award and notice to proceed
Initial Sitework Construction
Contractor preparation and mobilization
Pre-construction conference
Site preparation -clearing, grading, access road construction
Well Installation
Installation of S VE wells
Equipment Procurement
Vapor extraction blower moisture knock-out tank
Instrumentation and controls
Treatment System
Form and pour concrete slab
Placement of equipment on slab
Trenching and installation of underground piping
Testing of piping and backfilling of trenches
Complete piping connections to wellheads
Complete piping to treatment equipment
Installation of electrical/instrumentation/controls
Electrical Inspection and Activation
Equipment operational testing
Final Inspection
System Start up and balancing
Site restoration and demobilization
13
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Dmm Storage
Cordova, Richmond County, NC
Site conditions and operating parameters for the SVE system are detailed in Appendix A.
The first day of the start-up week was February 22, 1996. During each day of the start-up
week the SVE system was monitored for pressure applied, air flow, and offgas
concentration. Start-up activities continued after the first week with monitoring and
sampling occurring each week for the first month of operation. Subsequent operation and
maintenance visits occurred weekly with monthly sampling of the offgas for the first six
months followed by quarterly sampling of the offgas stack.
14
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova. Richmond Co11111y. NC
4.0 CHRONOLOGY OF EVENTS
The following table summarizes the major event and milestones.
DATE EVENT
9/30/199 I ROD comoleted and signed
6/22/1992 US EPA issues an Unilateral Administrative Order (UAO)
06/01/1994 ROD Amendment signed
6/28/1994 Remedial Design completed
6/28/1994 PRP RA Begins
1/18/1996 Prefinal Inspection Report
02/1996 Superfund Preliminary Close-out Report (PCOR) complete
2/22/1996 S VE svstem at Lagoon 7 bel!ins operation.
11/06/1996 Preliminary Close-out Report Prepared
5/12/2000 Lagoon 7 Sample and Analysis Plan Submitted to EPA
5/19/2000 USEPA aooroves Lal!oon 7 Samole and Analvsis Plan
6/13/2000 Confirmation soil samples collected at Lagoon 7.
9/26/2000 Five Year Review complete
12/27/2001 SVE system at Lagoon 7 discontinued and wells abandoned
11/8/2002 Soil Vapor Extraction Abandonment Report Submitted to EPA
15
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Co11111y, NC
5.0 PERFORMANCE STANDARDS AND CONSTRUCTION
QUALITY CONTROL
This section describes the performance of the prescribed remedy and data quality control
procedures for the SVE system at Lagoon 7.
5.1 SVE System Performance
The SVE system was installed in the area of former Lagoon 7 to remediate vadose zone
soil beneath the former lagoon. The SVE system consisted of a series of SVE wells used
for vacuum extraction and soil venting. Remediation at the former Lagoon 7 was
initiated on February 22, 1996. From system start-up, the system consisted of a large
blower operating in vacuum mode which was attached to the wellheads of SVE wells
VE-I, OW-I, OW-3, and OW-5 to recover vapors in soil and volatilize adsorbed
contaminants. Vapors captured by the SVE system were discharged to the atmosphere
through a vertical discharge stack. Ambient air was allowed to enter the ground surface
through two vent wells designated OW-2 and OW-4. The EPA and NC DENR approved
decommisioning the SVE system, as well as abandoning the observation and extraction
wells associated with this system in October 2000. The SVE system was turned off on
December 27, 2001.
Based on the results of offgas samples collected frequently from the discharge stack of
the SVE system and the results of confirmation soil samples collected June 13, 2000, the
16
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Ac/ion Heporl
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Countv. NC
SVE system performed in accordance with its design and was effective at reducing
concentrations of adsorbed PCE to the prescribed performance standard.
The volume of soil remediated at the former Lagoon 7 was approximately I ,300 cubic
yards. Laboratory analytical results of the June 13, 2000 final soil sampling event did not
report the presence of PCE above the detection limit. Analysis of soil samples collected
during the final sampling event did not report any parameters at concentrations greater
than the performance standard.
5.2 Quality Assurance and Quality Control
A Field Sampling and Analysis Plan (SAP) was developed in June 1994 and approved by
the EPA regarding sample control, field records, and chain of custody procedures to be
followed at the SVE system.
Each vapor sampling point was provided a unique identification number and soil vapor
samples were identified by the location sampled. Sample identification numbers were
included on both the chain-of-custody forms and sample containers. Sets of containers
shipped together to the laboratory were assigned a chain-of-custody form which traveled
with sample containers. A copy of the chain-of-custody was kept by the sampler and the
laboratory.
The Field SAP included decontamination procedures for vapor sampling equipment and
detailed procedures for collection of soil vapor samples from the SVE offgas stack and
17
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Ac/ion Reporl
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Co11111y, NC
from the well heads of the SVE extraction wells.
At least 14 days prior to sampling, the EPA's oversight contractor was contacted in order
to document the sampling event or split samples.
18
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Uichmond Co1111/y, NC
6.0 FINAL INSPECTION AND CERTIFICATION
These sections describe inspections by the EPA contractor, Health and Safety issues and
certification of soil remediation completion at Lagoon 10 and the Lagoon 7 SVE system.
6.1 Inspections
Representatives from EPA's oversight contractor, CDM Federal Programs Corporation
(CDM Federal), were on site during the removal of Lagoon IO materials drums and
vessels. Also present were representatives of the Remedial Design consulting firm,
RMT, Inc. and a representative from the BFI Landfill in Harrisburg, North Carolina. The
personnel from these organizations are identified below:
Personnel Organization Oversight Period
Eric Tschudi CDM Federal 6/20/94 -7 /1 /94
Jim Cole CDM Federal 7/12/94-7/14/94
Terry Chuhay CDM Federal 8/24/94 -8/25/94
Fred Banker RMT, Inc. 6/20/94-7/1/94
8/24/94 -8/25/94
Paul Furtick RMT, Inc. 6/20/94 -7 /I /94
8/24/94 -8/25/94
Derek Hughes RMT, Inc. 6/20/94 -7 /1 /94
7 /I 2/94 -7 /14/94
8/24/94 -8/25/94
John Marston BFI, Inc. 8/24/94 -8/25/94
19
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Ueport
Charles Macon Lagoon and Drum Storage
Cordova. Nichmo11d Co1111tv. NC
No deficiencies were noted by the onsite oversight personnel.
CDM Federal was the EPA contract inspector for the SVE system operation at Lagoon 7.
The COM inspector, Ms. Norma Eichlin, was contacted 14 days prior to each sampling
event. The COM inspector documented that the SVE vapor samples were collected in
accordance with the procedures contained in the SAP. No deficiencies were noted.
6.2 Health and Safety
A Health and Safety Plan (HASP) was assembled in preparation of the Lagoon I 0
excavation and Vessel disposal activities. No substantial problems or deviations from
the HASP were noted.
A Heath and Safety Plan (HASP) dated June 1995 was prepared for remedial operations
at the Macon and Dockery sites. The HASP covered Operation and Maintenance
activities at groundwater systems and the soil remediation system. Work in the vicinity
of the SYE system was allowed with Level D personal protective gear. No substantial
problems or deviations from the HASP were noted.
6.3 Institutional Controls
Institutional controls were not required by EPA as part of the source control remediation
activities.
20
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond County. NC
7 .0 OPERATION AND MAINTENANCE
The SVE system was started on February 22, 1996. During start-up, vapor samples were
collected from the SVE offgas stack daily for the first week, weekly for the first month and
monthly for the first six months. After that time, vapor samples were collected quarterly. Vapor
samples were collected from the wellheads of each vapor extraction well on a semi-annual basis.
The vapor samples were collected into a I-liter Tedlar bag and then pushed through a carbon
tube. The tubes were then shipped to an EPA approved laboratory for analysis of PCE and
PAH's.
System maintenance included regular replacement of the drive belt connecting the electric motor
to the positive displacement blower, and routine lubrication as recommended by the
manufacturer. In addition, the moisture knock-out tank periodically would fill and turn off the
system after heavy rain events. The moisture knock-out tank would then be emptied and the
system restarted.
In mid-1996, the MDSG and the EPA received complaints from neighbors of the SVE system
regarding noise. The noise was coming from operation of the positive displacement blower at
the SVE system. As a result, the SVE system was operated on a timer so that from late evening
to early morning, the system was off No more complaints regarding noise were received.
A summary of the laboratory analytical results of vapor samples collected from the off gas stack
and the vapor extraction wells is attached as Table 1.
21
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova. Richmond County. NC
8.0 SUMMARY OF PROJECT COSTS
Following the 1991 ROD, and the I 992 UAO, the MDSG set up a Fund to implement the
project All group costs for the RD and RA since April 1993 have been paid through this Fund.
In the table on the next page, are the costs estimated in the 199 I ROD, and a comparison to
actual costs.
The cost for the SVE and land treatment system was less than expected in the ROD by
approximately -40%. The majority of this savings is from the change that was made to the
remedy for Lagoon IO soils. The 1991 ROD selected a remedy for these soils that called for the
development and construction of a biological treatment system on-site to treat those soils. The
MDSG engaged RMT, Inc. to conduct a pilot project, and it showed that the selected biological
treatment alternative would not work as intended. EPA changed the remedy for the
contaminated soils in this lagoon to excavation and off-site disposal, at a significant savings,
even with the costs of the pilot incorporated into the final capital costs.
Further, the MDSG's accounting for its costs has not tracked the same categories as used in the
ROD cost projections, which made it difficult to do a direct comparison. It is likely, for
example, that some of the costs for the Lagoon 7 SYE system are included in costs incurred with
the groundwater remedy.
22
-------------------
Cost Item ROD Inflation
Estimate1 Adjusted Rod
Estimate2
Construction Cost for $1,300,000 $1,420,510
Lagoons 7 and I 0
Drum and Vessel Removal $300,000 $327,818
Total Capital Cost $1,600,000 $1,748,328
Operation and Maintenance $200,000 $311,600
Costs for Lagoon 7
Operation and Maintenance $0 $0
Costs for Disposal of
Vessels
Actual % Difference
Cost3
$811,457 -42.88%
$309,574 -5.56%
$1,121,031 -35.88%
$217,250 -30.28%
$0 NA
Remedial Action Report
Charles !vfacon Lagoon and Drum Storage
Cordova, Richmond Co11111y, NC
Estimated C.Y. Estimated unit
of Treated Soil cost per cubic
yard
1,994.80* $406 79
NA NA
NA NA
192 $1,131.51
NA NA
*2,704.21 tons removed at average density of 1.5 tons per cubic yard plus 192 cubic yards in Lagoon 7
Note: CY.= Cubic Yard
NA= Not applicable
1ROD Costs are estimates, with present value calculated as of 1991.
2 Inflation Adjusted and Actual Capital costs are in 1994 dollars. Inflation Adjusted and Actual Operation and Maintenance Costs are in
2006 dollars. Inflation rate was assumed to be 3%.
3 Actual Capital Cost does not include RD or RIFS; Actual O&M Costs are for the first 10 years of the 30 years estimated in ROD expressed
in 2006 dollars.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Co1111ty, NC
9.0 OBSERVATIONS AND LESSONS LEARNED
• Selection. of vapor extraction equipment could have accounted for the noise generated by
a positive displacement blower. Similar performance characteristics could have been
realized with regenerative blowers working in series. In addition, the maintenance issues
associated with a separate drive blower would not have been experienced with more
reliable direct-drive blowers.
• The treatability study for Lagoon IO proved invaluable in preventing implementation of a
remedy which would have ultimately been uneconomical. While removal with offsite
disposal was not the initial preferred remedy, the absence of a treatability study would
have added to these costs the price of an attempt at full scale bioremediation.
24
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
10.0 CONTACT INFORMATION
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond Coullly, NC
The Executive Committee Chairman for the MDSG was:
Thomas W. Daggett
Daggett Law Firm
Suite 4950 -Chicago Title Tower
161 North Clark Street
Chicago, Illinois 6060 I
The MDSG used the following consultant for design of the RA:
Paul Furtick
RMT, Inc.
I 00 Verdae Boulevard
Greenville, SC 29607
[phone]
The MDSG used the following contractor for implementation of the RA:
John Canzeri
Principal Hydrogeologist
Handex, Inc.
3600-G Woodpark Boulevard
Charlotte, NC 28206
[phone]
The MDSG used the following contractor for engineering oversight of the RA:
Dan Arner
Applied Earth Sciences, Inc.
434 Copperfield Blvd.
Concord, NC 28025
(704) 795-I 585
The EPA used the following contractor for oversight of the RA:
Mike Profit
CDM Federal
2030 Powers Ferry Road
Atlanta, Georgia 30339
The following company analyzed samples for the MDSG:
Savannah Environmental Laboratories, Inc.
5 I 02 LaRoche A venue
Savannah, Georgia 3 1404
(9 I 2) 354-7858
25
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
The Project Manager for the MDSG was:
Ken Gulledge
Crown, Cork, and Seal, lnc.
100 Evans Row
Cheraw, South Carolina 29520
[phone]
The Project Manager for the EPA was:
Giezelle Bennett
US EPA Region 4
61 Forsyth Road SW
Atlanta, Georgia 30303
( 404) 562-8824
The Project Manager for the NCDENR was:
David Mattison
40 I Oberlin Road -Suite 150
Raleigh, North Carolina 27605
[phone]
26
Remedial Action Report
Charles Macon Lagoon and Drum Storage
Cordova, Richmond County, NC
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
; I
I
I
11.0 REFERENCES
Remedial Action Report
Charles Macon Lagoon and Dmm Storage
Cordova, Richmond Co1111ty, NC
List of Documents Reviewed
Charles Macon Lagoon and Drum Storage Site
Remedial Action Report Source Control
Sirrine Environmental Consultants, Inc., February 1991. Remedial Investigation Report,
Charles Macon Lagoon and Drum Site, Cordova, North Carolina
Sirrine Environmental Consultants, Inc., July 1991. Final Feasibility Study,
Macon/Dockery Site, Richmond County, North Carolina
U.S. Environmental Protection Agency, Region IV. July 25, 1991. Proposed Plan
Superfund Fact Sheet. Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
U.S. Environmental Protection Agency, Region IV. September 30, 1991. Record Of
Decision, Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
U S. Environmental Protection Agency, Region IV. June 1, 1994. ROD Amendment,
Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
RMT, Inc., June 1994. Workplan for the Removal of Wastes from Lagoon 10,
Vessels, and Drums, Macon/Dockery Site, Cordova, North Carolina
RMT, Inc., June 1994. Field Sampling abd Analysis Plan, Macon/Dockery Site,
Cordova, North Carolina
RMT, Inc., January 30, 1995. Removal Action Completion Report, Charles Macon
Lagoon and Drum Site, Cordova, North Carolina
RMT, Inc., February, 1995. Final Remedial Design Report, Charles Macon Lagoon
and Drum Site, Cordova, North Carolina
Handex of the Carolinas, June 1995. Site Health and Safety Plan, Charles Macon
Lagoon and Drum Site, Cordova, North Carolina
U.S. Environmental Protection Agency, Region IV. January 2000. Close Out
Procedures for National Priorities List Sites
Applied Earth Sciences, Inc., May 12, 2000. Revised Sampling and Analysis Plan;
Lagoon 7, Charles Macon Lagoon and Drum Site, Cordova, North Carolina
U. S. Environmental Protection Agency, Region IV. September 26, 2000. Five-Year
Review Report, Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
27
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Remedial Action Report
Charles Macon Lagoon and Dmm Storage
Cordova, Richmond County, NC
Applied Earth Sciences, Inc., October 3, 2000. Soil Assessment Report-Former
Lagoon 7. Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
Applied Earth Sciences, Inc., September 12, 2002, Soil Vapor Extraction Abandonment
Report, Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
U. S. Environmental Protection Agency, Region IV. September 2005. Five-Year
Review Report, Charles Macon Lagoon and Drum Site, Cordova, North Carolina.
28
I
I
I
I
I
I
I
I FIGURES
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
0
FIGURE 1
Topographic Location Map
Macon Dockery Site -Cordova, North Carolina
0.2 0.4 0.6 0.8 1 roi
Map center is UTM 17 606 I 88E 3862309N (WGS84/NAD83)
Rockingham quadrangle -TopoZone Pro elevation display
Projection is UTM Zone 17 NAD83 Datum
M=-7.681
G=0.665
.. ----- -- ---------r-------------------------·-...
, ............... ...
N
lRMINGER CONSULTING, INC.
0004 _001 Jlad1 8r, SEI Oai,,: 01-20-2005
Chkd By: SEJ fildnomo: 0004001
M W-02 (LAGOON
\ LAGOON LAGOON .¥/ I
" ' ~· 0. £ll19TJNO · =.-
MOHITOfflNG ~A GOON
W~LL J#' D ~ (2 PVCJ ___,.. {._/"
t'-:/i" MW~♦'----. V \_
l/1000:1 a .#c5" ....
. ./'l EA II
&.AGoo\..{AG #7
l;:O~N ~
FllfflW
• '
MACON DOCKERY SITE CRODP
., .
VfltNON
WAffHf~ . RESIDENTIAL
b EXISTING
~SIDEHTIAL WELL ♦ _______,.
~o ◊~ENTIAL
MACON LAYOUT MAP
--
2
-.
I
I
I
I
I
I
I
I
I
I
I
I
11
I
I
,_ ..
"" Q
,i!
!
® MW-21
,ii
li~~~==,=====r===n IRMINGER CONSULTING, INC. I -/If: SEI IJrrla: 01-20-1999 0004-001 Chbl /If: SEI ,-FILENAME
MACON DOCKERY SITE
GROUP
I
DOCKERY LAYOUT
MAP 3
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLES
I
I
Sample
Lot·atiun I VE-01
I
I
OW-1
I
I
I (J\\'-3
I
I
I OW-5
I
I
SVE Exh,mst
I
I
I
I
I
I
TABLE 1
SVE Air Analysis Summary
Macon/Dockery Site -Richmond County, North Carolina
Page 1
Date II C~1-~form I ,2-Dichlorocthcnc ·rctrachlorocthcnt>
'=' mo/m3 lllP/mJ
2/22/1996 <10 <JO <IO
6/5/1996 <JO <JO <]()
7/1/1996 <10 <10 <10
11/811996 <10 <JO <JO
6/D/1997 <JO <JO <J(l
11/13/1997 <2.0 2.3 <2.0
6/19/1998 <2.0 <2.0 <2.0
I \/4/1998 <2.0 <2.0 <2.0
5/B/1999 <2.0 <2.0 <2.0
IW/1999 <2.0 <2.0 <2.0
5/812000 <:1.0 <1.0 <I.()
7J27J\996 <10 <IO <10
6/5/1996 <JO <10 <10
7/1/1996 <10 <10 <JO
11/8/1996 <10 <JO <JO
6/23/1997 <10 <10 <J(l
11/13/1997 -.."2.0 <2.0 <2.0
6119/1998 <2.0 <2.0 <2.0
I 1/4/1998 <2.0 <2.0 <2.0
5/13/1999 <2.0 <2.0 <2.0
11/3/191'.)9 <2.0 <2.0 <2.0
5/8/2000 <1.0 <J.O <LO
212'l11996 <10 80 <JO
6/5/1996 <10 <JO <10
7/1/1996 230 <JO <10
11/8/1996 <10 <\() <IO
6/2~/1997 <10 <10 <10
I J/13/1997 <2.0 <2.0 <2.0
6/19/J(J(J8 <2.0 <2.0 <2.0
11/4/1998 <2.0 <2.0 <2.0
5/13/1999 <2.0 <2.0 <2.0
11/3/1999 <2.0 <2.0 <2.0
5!8'2000 <1.0 <1.0 <t.n
2/22119% <Ill 380 <10
6/5/1996 <10 <IO <JO
11/8/1996 <JO <IO <JO
6'23/1997 <JO <10 <JO
11/13/1997 <2.0 <2.0 <2.0
6/19/1998 <2.0 <2.0 <2.0
11/4/1998 <2.0 <2.0 <.."2.0
5/13/1999 <2.0 <2.0 <2.0
ll/3/1999 <2.0 <2.0 <2.0
5/8'2000 <1.0 <I.() <1.0
'})14/1996 <IO <10 <10
2/15/1996 <JO <10 <JO
2/\6/J(J(J6 <10 <JO <10
4/3/19% <10 <It) <10
(,15/1996 <JO <I{) <JO
7/1/1996 <10 <10 <JO
8/l/l(J(J6 <10 <10 <JO
"1J5/1997 <10 <10 <JO
6'23/1997 <10 <IO <JO
8/7/1997 <2.0 <2.0 <2.0
11/13/1997 <2.0 <2.0 <2.0
2.16/1998 <2.0 <2.0 <2.0
511119'-}8 <2.0 <2.0 <2.0
8/7/IY.:J8 <2.0 <2.0 <2.0
11/4/1998 <2.0 <2.0 <2.0
Vl l/1Y.:.J9 <2.0 <2.0 <2.0
5/13/1999 <2.0 <2.0 <2.0
815/19']9 <2.0 <2.0 <2.0
I l/3/J(J(J9 <2.0 <2.0 <2.0
518'2000 <1.0 <1.0 <1.0
813/2000 <\.() <!.() <1.0
TrichlnrtK'lhene T
mP/mJ
<IO <to
<10 <10
<10 <\()
<10 <10
<10 <10
<2.0 <2.0
<2.0 <2.ll
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<1.0 <1.0
<10 <\()
<10 <10
<JO <JO
<JO <JO
<10 <JO
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<LO <I.()
<10 <10
<JO <10
<10 <10
<10 <10
<10 <JO
<2.0 <2.il
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<1.0 <1.0
<]O <10
<10 <\()
<10 <JO
<JO <10
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<1.0 <1.0
<10 45
<10 43
<10 73
<10 <JO
<JO <10
<10 <10
<JO <10
<10 <10
<I() <10
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <20
<2.tl <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<1.0 1.2
<1.0 <1.0
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
APPENDIX A
SITE CHARACTERISTICS AND OPERATION DAT A
Parameter Site Conditions Measurement
Procedure/
Comment
Em•ironmental Setting
Air Temperature Average July Average = 80° F Rockingham Weather
January Average = 40° F Underground
Range of Average August Morning Average= Rockingham Weather
Humidity 90% Underground
April Afternoon Average=
48%
Range of Average Monthly July average= 6 inches Rockingham Weather
Rainfall (inches) Apri I average= 3 inches Underground
Soil Types
Soil Classification Cecil and Iredell Soils of the USDA
Piedmont Province and
Norfolk, Orangeburg, and
Greenville soils of the Coastal
Plain Province
Geology Saprolite consisting of silts and
clays overlying a granitic
bedrock separated by a thin
transition zone.
Depth to groundwater 20 to 35 feet below grade
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
APPENDIX A Continued ...
Parameter
Suction Aoolied
Maximum Suction
Observed
Minimum Suction
Observed
Air flow (average at stack)
Temperature ( at stack)
Operating Parameters
Site Conditions Measurement
Procedure/Comment
120-inches w.g Vacuum Gauge
1.2-inches w.g. Magnehelic
0.2-inches w.g. Magnehelic
18 to 43 cfm Pitot tube
140 degrees F Mercury Thermometer
USEPJ\ Region 4