NCD980840409_20070314_Charles Macon Lagoon Drum_FRBCERCLA RA_Remedial Action Reports 2006 - 2007-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
March 14, 2007
4WD-SRSEB
Macon Dockery Site Group Technical Committee
c/o Ken Gulledge
Crown, Cork and Seal
P.O. Box 759
Cheraw, SC 29520
SUBJ: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Gulledge:
The Interim Remedial Action Report -Charles Macon Lagoon and Drum Storage
Site dated December 2006 is hereby approved.
Please give me a call at 404-562-8824 if you have any questions.
R.emedial Project Manager
cc: David Mattison, NC DENR
Steve lrminger, lrminger Consulting
Internet AddreSs {URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% PostconsumerJ
• i~C~flnc~
Chemistry and Engineering Solutions in the Environmental Industry
December 8, 2006
Giezelle Bennett
U.S. EPA Region IV
61 Forsyth Road SW
Atlanta, Georgia 30303
Re: Transmittal oflnterim Remedial Action Report;
Macon Dockery Superfund Site;
Cordova, Richmond County, North Carolina
Dear Ms. Bennett:
•
Please find attached one copy of the Interim Remedial Action Report, dated December 8, 2006, for the Charles Macon Lagoon and Drum Storage Site located in Richmond County, North
Carolina. A second original has been submitted to Mr. David Mattison North Carolina
Department of Environment and Natural Resources (DENR). This final version of the Interim Remedial Action Report reflects the changes and comments received from the Environmental
Protection Agency in a letter dated November 13, 2006. As such, the attached report replaces
the report submitted to you dated October 2006.
Should you have any questions, please do not hesitate to contact me.
Sincerely,
I GERC
/ --------Steven . Irminger, P.E.
President
cc:-David.Mattison~-
MDSG Members
Inninger Consulting, Inc. 7015 Erin brook Drive, Concord, North Carolina 28025
[phone] voice, [phone] fax, [phone] cell [e-mail]
• 8f'?'A .=;::;;-~"-~-~ •
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director
Ms. Giezelle Bennett
Remedial Project Manager
Division of Waste Management
October 18, 2006
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, Region 4
Sam Nunn -Atlanta Federal Center
6 I Forsyth Street
Atlanta, GA 30303
RE: Interim Remedial Action Report -Groundwater Remediation
Charles Macon Lagoon and Drum Storage NPL Site
Cordova, Richmond County, NC
Dear Ms. Bennett:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the Interim Remedial Action Report -
Groundwater Remediation for the Charles Macon Lagoon and Drum Storage National
Priority List (NPL) Site. The Superfund Section offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919)
508-8466.
Sincerely, 72;g~i~n;tl:s
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] \ FAX [phone]\ Internet http://wastenotnc.org
An Equal Opportunity/ Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
f Ms. Giezelle Bennett
October 18, 2006
Page 1 • •
Interim Remedial Action Report -Groundwater Remediation
Charles Macon Lagoon and Drum Storage NPL Site
Table of Contents
1. Please correct the Table of Contents to indicate that the title of Appendix A is
"Site Characteristics and Operational Data".
Section 1.0 Introduction
2. Please delete the phrase "EPA ID" from the title block on the first page of the
Introduction.
Section 2.2 Remedial Design
3. Please correct the last sentence of the fourth paragraph of Section 2.2 to state "For
this reason, bioremediation was not pursued further as a remediation technology."
Section 3.2 Installation of Groundwater Remediation Systems
4. Please correct the seventh sentence of Section 3.2 to state "Aboveground piping is
protected from freezing with the use of thermostatically actuated heat trace
wiring and fiberglass wrap insulation."
Section 10.0 Contact Information
5. Please revise the contact information for David Mattison to indicate that his
telephone number is [phone].
Appendix A
6. Please revise Appendix A to indicate that the title is "Site Characteristics and
Operation Data".
• □~~!IOJDtQ
Chemistry and Engineering Solutions in the Environmental Industry
•
October 4, 2006
Giezelle Bennett
U.S. EPA Region IV
61 Forsyth Road SW
Atlanta, Georgia 30303
t ' /-2 ,-
'( :;: 1 ', zo,; ; .. ·,
1 '-
.1
...,_ f'ft ------~....._~. . ; Re: Transmittal of Interim Remedial Action Report;
Macon Dockery Superfund Site;
Cordova, Richmond County, North Carolina
Dear Ms. Bennett:
-
Please find attached one copy of the Interim Remedial Action Report for the Charles Macon
Lagoon and Drum Storage Site located in Richmond County, North Carolina. A second original
has been submitted to Mr. David Mattison North Carolina Department of Environment and
Natural Resources (DENR).
Should you have any questions, please do not hesitate to contact me.
ING, INC.
. ._ ...
Steven E. Irminger, P.E;-_-...--... ___ _
President
cc: David Mattison
MDSG Members
.•
lrminger Consulting, Inc. 7015 Erinbrook Drive, Concord, North Carolina 28025
[phone] voice, [phone] fax, [phone] cell [e-mail]
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
September 29, 2006
4WD-SRSEB
Macon Dockery Site Group-Technical Committee,,··" ,., . ., __ .. , .... ,_,
c/o Ken Gulledge
Crown, Cork and Seal
P.O. Box 759
Cheraw, SC 29520
SUBJ: Macon/Dockery NPL Site
Cordova, North Carolina
Dear Mr. Gulledge:
The Remedial Action Report -Charles Macon. Lagoon and Drum Storage Site
dated September 2006 is hereby approved.
Please give me a call at 404-562-8824 if you have any questions.
cc: David Mattison, NC DENR
Steve lrminger, lrminger Consulting
. . --· ......
Internet Address (URL)• http://www.epa.gov
. ' . -'~ . ' .. ~~: .
"
Rocycled/Aecyclabte • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Poslconsumer)
. '
• •
4WD-SRSEB
MEMORANDUM
UNITED.STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA. GEORGIA 30303-8960
DATE: September 26, 2006
SUBJE'ct:' ,, 'R~rris8i~('l,:ciidfi"co~'pleiio'ii ~'Soil''", .. ,::,,, ,-
FROM:
TO:
Charles Macon Lagoon and Drum Storage Site
Cordova, Richmond County, North Carolina
. --Gi~~;1·1~ s:-Bennett~;J
Remedial Project fi(a~~J:'.v
Don Rigger, Chief .
Superiund Remedial & Site Evaluation Branch
The purpose of this memorandum is to request your approval and concurrence
on the Remedial Action Report for the Charles Macon Lagoon and Drum Storage Site
in Cordova, Richmond County, North Carolina. To the extent possible, this report has
been prepared in general accordance with the Close out. Procedures for National •
Priorities List Sites, Office of Solid Waste and Emergency Response (OSWER)
Directive 9320.2-09A-P, January 2000.
Approval and concurrence on this_Remedial.ft,.9tion Rep.or! by .tb_~ EPA's Chief of,
the Superiund Remedial & Site Evaluation Branch documents the completion of the
remediation of soil at this Site.--..
i
,.,-,
/ I I
/1 I ' --{~/;,~-,
Concurrence -Don Rig er, Chief SRSEB
,I
Non-Concurrence -Don Rigger, Chief SRSEB
lnteme! Address (URL)• http://www.epa.gov
Date
Date
Recycled/Recyclable. Printed with vegelahlc Oil BasecJ Inks on Recycler! Paper (Minimum 30':-;. Poslconsurner)
• &-'!~A .=;;::;;-~"-~-~ .NCDENR
•
North Carolina Department of Environment and Natural Resources
Dexter R Matthews, Director
Ms. Giezelle Bennett
Remedial Project Manager
Division of Waste Management
September 14, 2006
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, Region 4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
RE: Revised Remedial Action Report
Charles Macon Lagoon and Drum Storage NPL Site
Cordova, Richmond County, NC
Dear Ms. Bennett:
Michael F. Easley, Governor
William G. Ross Jr, Secretary
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the Revised Remedial Action Report
for the Charles Macon Lagoon and Drum Storage National Priority List (NPL) Site. The
Superfund Section offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919)
508-8466.
Sincerely,
D a,u-i_p__ h . ~ /J ,.._ / d
David B. Mattison f
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone] I Internet http://wastenotnc.org
An Equal Opportunity I Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
Ms. Giezelle Bennett
September 14, 2006
Pagel •
Revised Remedial Action Report
Charles Macon Lagoon and Drum Storage NPL Site
Record of Preparation, Review, and Approval
•
1. Please correct the signature block for David Mattison to indicate that he is not a Professional Engineer (PE) and that his title is Environmental Engineer.
Table of Contents
2. Please correct the Table of Contents to indicate that the title of Table 1 is "Air Quality Summary".
3. Please correct the Table of Contents to indicate that the title of Appendix A is "Site Characteristics and Operational Data".
Section 1.0 Introduction
4. Please delete the phrase "EPA ID" from the title block on the first page of the Introduction. ·
Section 7.0 Operation and Maintenance
5. Please correct the fourth paragraph of Section 7 .0 to state "A summary of the · laboratory analytical results of vapor samples collected from the offgas stack and the vapor extraction wells is attached as Table 1."
Section 8.0 Summary of Project Costs
6. Please delete the last paragraph ofSection 8.0 on page 24 of the document.
Section 10.0 Contact Information
7. Please revise the contact information for David Mattison to indicate that his telephone number is [phone].
Figure 2 Macon Layout Map
8. Please revise Figure 2 as the figure contained in the document is illegible.
Figure 3 Dockery Layout Map·
9. Please revise Figure 3 as the figure contained in the document is illegible.
Ms. Giezelle Bennett
September 14, 2006
Page 2
Table 1
•
Air Quality Summary
I 0. Please correct Table I to indicate that it is Table 1.
Appendix A
•
11. Please revise Appendix A to indicate that the title is "Site Characteristics and
Operation Data".
,, ·-... • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
September 14, 2006
4WD-SRSEB
Mr. Steve lrminger, P.E., P.G.
' President ' ~-""" ' .. . . .
lrminger Consulting Inc
7015 Erinbrook Dr
. C.onc9rd, NC: g8Q?5 ....
SUBJ: Macon/Dockery NPL Site
Cordova, NC
Dear Mr. lrminger:
Enclosed are comments on the Remedial Action Report, Charles Macon Lagoon
and Drum Storage Site dated August 28, 2006. Please incorporate the comments and
submit the revised report no later than September 22, 2006.
If you have any questions, please give me a call at 404-562-8824.
cc: David Mattison, NC DENA
Sincerely,
G' zelle S. Bennett
Remedial Project Manager
Ken Gulledge, Macon Technical Committee
., .. ,_
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable • Printed with Vegelable Oil Based Inks on Recycled Paper (Minimum 30% Poslconsumer)
• •
COMMENTS
REVISED REMEDIAL ACTION REPORT
CHARLES MACON LAGOON AND DRUM STORAGE NPL SITE
Record of Preparation, Review, and Approval
1. Please correct the signature block for David Mattison to indicate that he is not a
Professional Engineer (PE) and that his title is Environmental Engineer .
. Table of Contents,,;;·-;. • V O • + • • -.. ,t,_,,,,.,.~-1t ,l •'•• ~· •• •• ,1 ... -..,
2. Please correct the Table of Contents to indicate that the title of Table 1 is "SVE
Air Analy~_is Summary".
• r:,·· ,_.,_ ~ :-.ii .... •.'.l~~n,J,'., ,,. .,. ~· ,,.
3. Please correct the Table of Contents to indicate that the title of Appendix A is
"Site Characteristics and Operational Data".
Section 1.0 Introduction
. 4. Please delete the phrase "EPA ID" from the title block on the first page of the
Introduction.
Section 2.0 Operable Unit Background
5. On page 6, first paragraph, please change "Authorization to decommisioning ... "
to "Authorization to decommision ... "
6. Page 7, the original ROD addressed the vessel remediation, not the amended
ROD. Please correct.
Section 7.0 Operation and Maintenance
7. Please correct the fourth paragraph of Section 7.0 to state "A summary of the
laboratory analytical results of vapor samples collected from the offgas stack and
the vapor extraction wells is attached as Table 1."
Section 8.0 Summary of Project Costs
8. Please change the last sentence on page 22 from "We believe it likely ... " to "It is
likely ... "
9. Please delete the last paragraph of Section 8.0 on page 24 of the document.
•
,, . · .. ',, . ·-..
• •
Section 10.0 Contact Information
10. Please revise the contact information for David Mattison to indicate that his
telephone number is [phone].
11. The telephones numbers for Ken Gulledge and_ Giezelle·Bennet are reversed. ·
Figure 2 Macon Layout Map
12. Please revise Figure 2 as the figure contained in the document is illegible.
,, .Figur,e,3 , ... Dockery Layout Map
13. Please revise Figure 3 as the figure contained in the document is illegible.
Table 1 -· · · Air Quality Summary
14. Please correct Table 1 to indicate that it is Table 1.
Appendix A
.
15. Please revise Appendix A to indicate that the title is "Site Characteristics and
Operation Data."
Chemistry and Engineering Solutions in the Environmental Industry
August 28, 2006
Giezelle Bennett
Remedial Project Manager
U.S. EPA Region IV
61 Forsyth Road, S.W.
Atlanta, Georgia 30303
Re: Transmittal of Revised Remedial Action Report;
Macon Dockery Superfund Site;
Cordova, Richmond County, North Carolina
Dear Ms. Bennett:
•
Please find attached the Revised Remedial Action Report for the Charles Macon Lagoon and
Drum Storage Site located in Richmond County, North Carolina. An original copy has been
submitted to Mr. David Mattison of the North Carolina Department of Environment and Natural
Resources, under separate cover.
The Revised Remedial Action Report addresses the comments from the EPA and NCDENR in a
letter to lrminger Consulting, Inc. dated July 25, 2006.
Should you have any questions, please do not hesitate to contact me.
ING, INC.
· Steven E. Irminger, P.E.
President
cc: David Mattison -NCDENR
MDSG -Members
lrminger Consulting, Inc. 7015 Erinbrook Drive, Concord, North Carolina 28025
[phone] voice;[phone] fax, [phone] cell [e-mail]
I ... • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
4WD-SRSEB
Mr. Steve lrminger, P.E., P.G.
President
lrminger Consulting Inc
7015 Erinbrook Dr
Concord, NC 28025
SUBJ: Macon/Dockery NPL Site
Cordova, NC
Dear Mr. lrminger:
July 25, 2006
Enclosed are comments on the Remedial Action Report, Charles Macon Lagoon
and Drum Storage Site dated June 30, 2006. Please incorporate the comments and
submit the revised report no later than August 18, 2006.
If you have any questions, please give me a call at 404-562-8824.
cc: David Mattison, NC DENR ·
ezelle S. Bennett
Remedial Project Manager
Ken Gulledge, Macon Technical Committee
Internet Address (URL) • http://www.epa.gov
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GENERAL
• •
CHARLES MACON SITE
REMEDIAL ACTION REPORT COMMENTS
1. The purpose of the RA report is to document the cleanup activities that took
place. The RA report could not be prepared until after the cleanup goals were
achieved in the soil vapor extraction system. A previous report submitted to the
Agency entitled "Completion Report for the Removal of Wastes from Lagoon 10,
Vessels and Drums" dated January 30, 1995 may provide useful information. In
addition, included is a copy of the oversight report for the remediation.
Although the RA Report provides a general overview of site activities, the RA
Report lacks the detail as the official record of remedial action activities. Much
greater detail is required of this report, including all of the supporting
documentation required to substantiate the information presented in the text of
the report. The report follows the set-up in the guidance, but is repetitive and ·
confusing. In addition, please remember that this is the RA report for soils only.
The report states this on page 3, but discusses the groundwater remediation
throughout.
2. On the sign-off sheet, please change "Site Manager" to "Remedial Project
Manager".
INTRODUCTION
3. In the title on page 1, change "Source Control" to "Source Remediation".
Indicate the contents of Lagoon 10 (Soils, Debris?) and Lagoon 7 (soils).
4. The figures referenced on page 1 (figures 2-5) show the groundwater situation
which is not the subject of this report and figure 1 does not show lagoons 1 O and
11 .
5. After discussing the EPA cleanup on page 2, include a discussion on the NPL
listing and the subsequent PRP lead RI/FS.
6. In the third paragraph on page 2, delete the first sentence, "In November ... Site."
The second sentence should state that the record of decision (ROD) was 'issued'
by EPA in September 1991.
7. Paragraphs 1 and 2 on page 3 should be moved to the next section.
8. In the last paragraph of this section, delete the references to "OU1 ". This site
was not subdivided into operable units.
• •
OPERABLE UNIT BACKGROUND
9. On page 4, Section 2.1, the remediation level for PCE is 1 ppb. Even though the
state's ARAR is 0.7 ppb, the default value is the contract required quantitation
limit (CRQL).
CONSTRUCTION ACTIVITIES
10. Section 3.1.1 should be moved to the Introduction.
11. Section 3.1.2 -All discussions about the ROD and ROD amendment should be
in the Operable Unit Background Section.
12. The Construction Activities Section should start with Section 3.1.3, discussing
the actual remediation activities.
CHRONOLOGY OF EVENTS
13. The events should begin with the 1991 ROD and the entries concerning the
groundwater should be deleted.
FINAL INSPECTION AND CERTIFICATION
14. In Section 6.1, please include the dates of the inspections.
15. In Section 6.2, EPA does not approve HASPs. Please delete the 2nd sentence.
OPERATION AND MAINTENANCE
16. Add "SVE" to the title of Table 2. PCE is missing from the table.
SUMMARY OF PROJECT COSTS
17. Change the third sentence of this section to "In the table on the next page are
the costs estimated in the 1991 ROD and a comparison to actual costs."
18. Delete the groundwater components in the table. If SVE costs are lumped into
the capital cost for gw, then a good estimate will suffice.
CONTACT INFORMATION
19. Add David Mattison as the NC DENR contact.
NOT TO SCALE IONS EXISTING AND PROPOSED MONITORING WELL LOCAT CHARLES MACON SITE
ROCKINGHAM COUNTY, NORTH CAROLINA
VERNON
WARNER
RESIDENTIAL
\
EXISTING
G RESIDENTIAL
WELL ♦----------
FIGURE 2-1
ctj~@
0 A Halliburton Company
•
•
COM FEDERAL PROGRAMS.
a subsidiary of Camp Dresser &·McKee Inc.·
September 9, 1994
· Ms; Giezelle Bennett
U.S. Envir_oninental Protection Agency . ·
.· 345 Courtland Street
Atlanta, Georgia· 30365
PROJECT: EPA Contract No. 68-W9-.0056
DOCUMENT NO: 7740,036-LR-BMBV
SUBJECT: Work Assignment 36-4XA1
•
CORPORATION
Macon/Dockery, Richmond County, North Carolina
Oversight Report of Remedial Action Field Activities
Reporting Period: 6/20/94 through 8/25/94
Dear Ms. Bennett: ·
COM Federal Programs Corporation (COM F~deral) is pleased io submit the_ above subject ·
oversight report. for the Macon/Dockery Site Remedial Actio~ (RA) ()versight: This report
summarizes the removal of wastes from Lagoon 10, vessels, and drums performed by the ..
Responsible Parties (RPs) and their subcontractors over the period of June 20 through August
25, 1994, and· presents to. EPA any significant problems, issues, or items of note observed by
COM Federal during the oversight of field activiiies. · · · . . . .
The •details of the removal° activities performed are presented in. the EPA-approved RMT
Workplan for the Removal of Wastes frorri Lagoon 10, Vessels, andDrums dated June 1994: .
•' . . . . . .. .
COM Federal followed all prosedures specified in th~ COM FederalQuality.Assurance
. Project Plan for the Macon/Dockery Site in .conducting oversight. Attachntei:J.ts'to this .• ... __ . .
oversight report include Field Notes (Attachment A) and PhotographicLog'(AttachmeritB). ' . . ' . ' -~ ... ·:. ·,, .-' . ·_. .. '· .,,-._. .f.'-'" · .. _ : ...
The·scope of work for this phase. of the RA included removal and disposal;f;Lag;oonl.O·_·: !,.
waste materials and soils which exce~ded the Performance Standard o(i ppni'totali . . . . ...
carcinogenic polynuclear aromatic hydrocarbons (cPAHs). In addition, all vessels:(tanks;: . • ,,
tankers, vats, and boiler) and existing onsite drums contai.ning drill cutting;s;·liqiiids; and othe{
investigation-related wastes were to be removed.and disposed. . . . .. .s·. ; ·,.•·::,::-r, ,,
P~nt~ on Recycled Paper
, 2030 Po,;ers Ferry Road, Suite 490 Atlanta, GA 30339 404 952-7393
Ms. Bennett
Field Oversight Report
Page 2·
· CDM FEDERAL PROGRAMS CORPORATION
a·-sub~idiary·oi'Camp Dresser·~ McKee Inc.'
···•The following personnel were present for all or part. of the oversight period covering 6/20/94
through 7 /1/94: · · · · · · · · · -· · . ·
Personner
Eric Tschudi
Fred Banker
Paul Furtick
Derek Hughes
Chris Driver
Bill Dunigan
J.W. Hall .
Larry Minchew
. Karen Moore
Greg Paxton
Chris Rabley
Jonathan Rabley
Justin Ricard
Organization
CD!v1 Federal
RMT
RMT
RMT
NU-WAY Environmental Inc.
· NU-WAY Environmental Inc.
NU0 WA Y Environmental. Inc.
. NU-WAY Environmental Inc.
NU-WAY Envirolllilental Inc .
NU-WAY Environmental Inc.
NU0WAY Environmental Inc. ·
• NU-WAY Environrhental Inc.
NU-WAY Environmental Inc.
Removal activities at Lagoon 10 required the use of heavY mo~ing equipment, which included
a: trackhoe, backhoe, front-end loader, and dump truck. . Excavation included all overburden, ·
waste and visibly-affected adjacent soil. · The Lagoon IO excavation began with the removal
of.a 3~foot clay cap, which was determined as clean, and was staged outside the exclusion ·
zone for future use during backfilling operations. Waste imd visibly-affected soil was .
excavated by trackhoe and deposited by dump truck to a' staging area approximaiely 20 feet
wide.and !0O'feet long. The staging area consisted of a 12-inch high bermed perimeter with
either· a 20 or 60. mm. very low density polyethylene (VLDPE) bottom liner. A total o(4 .
. staging areas were constructed during the oversight period, each one made in a similar fashion
with no significant differences between them. 9isqueen covers were used to cover all staging
areas and the lagoon itself at the end of each day iii order to protect them from the: elements. ·
Rand9m composite sampling of the. staging areas was ongoing throughout the excavation
activities. Each area was. divided into 150-yard piles, each pile into equidistant sections. The .
· sections were then numbered and sampled randomly at various depths within each pile.
Immunoassay was used as a field screening method to guide removal of affected soil -
exceeding 5 ppm total PAHs. C~mfirrriaiory samples-were sent to an offsite laboratory to
· Ms. Bennett .
Fi~ld Oversight Repini
Page 3
• COM' FEDERAL. PROGRAMS CORPORATION
a.subsidiary ot·CB.mp Dr8sser & McK8e Inc . . . . ' . : ' . .
verify that the remaining soils in the lagoon niet the 2 ppm total ~p AI:Is pe~formance
.· standard. Further excavation, if necessary, was conducted based on these results .
. Excavation activities ce~sed te~porarily once all visibly-affected soil ~as rt:moved from. the.
lagoon. To facilitate access and handling, NU-WAY Environmental personnel then began ...
transporting drums .from their current locations around the site to.a single staging ai-ea at .the-.
Upper Macori Site. Headspace readings were'taken froni each drurii and noted .. Liquids were.
then removed. from the drnrns · and bulked for characterization and disposal, .. The empty drt1Il1s
were to be crushed after removing the contents. Any drums found deteriorated and leaking
were_ overpacked prior to the removal of the contents. . . .
· During this time period, Tanks 2 though 9 were sampled for oil content to determine the
appropriate means for. disposal. · Tank 6 was not sampled since there was not e~ough ciil. in
the tank to collect a sample. · ·
This oversightperiod didnot include the transfer of any material frohi the d~ums.or the .
vessels, nor did it include confirmatory sampling of the Lagoon IO bottom and sidewalls:
The following personnel were present for all or part of the oversight period covering 7/12/94
through 7 /14/94:
Personnel
Jim _Cole
Derek Hughes
Chris Driver.·
Pete Duncan
. Larry Minchew
Chris Rabley .
· Bernard Wright
Organization
COM Federal.
RMT
, NU-WAY Environmental Inc.
)'IU-WAY Environmental Inc.
NU-WAY Environmental Inc ... ·
NUc WA y Enviio'ninental Inc.
NU-WAY. Environmental Inc.
· During this phase of oversight, CDM Federal observed work related to Vats !through 8: • The
contents.of Vats I through 7 were pumped out info a tanker truck, and from there; info frac
tanks onsite: Vat 8 was pumped once and a hole' in the· bottom of the vat w_as discovered
.which allowed groundwater to fill up-the vat after pumping. Once the liquid was removed,
solids found in any of the vats were. removed, drummed, and staged ini-oll-off containers for
· subsequent disposal. The. vats were then .. cleaned out. by using a pressure washer. . At the end
· Ms. ·Bennett: ·
Field Oversight Report .
. Page 4.
. COM FEDERAL PROGRAMS CORPORATION .
a s~bsidia.ry Of_ Camp o:e~ser .& }'1~K~e Inc:·
of the oversight period, disn1antling of the vats was initiated .. After discovering the hcile .in
Vat8; itwas decided to leave it alone for the tinie. •.. . . . .
Drum consolidation and contents renio;al continued thrjmghout this oversight period.
The following personnel were. present.for all or part -of til~ oversight period covering 8/22/94.
through 8/25/94: · · · · · ·· · ·
· Personnel
Terry Chuhay
Fred Banker
Paul Furtick
Derek Hughes
Earl Armstrong
Mike Dillan
Pete Duncan .
· Larry Minchew
Kenneth PattersQn
Greg Paxton · ·
Chris Rabley · .
Bernard Wright
John Marston
Organization
CDM Federal
RMT
RMT
RMT
NU-.\V A Y Environmenial. Inc ..
NU-WAY Env_ironmental Inc.
NU-WAY Enviro!lll1ental Inc, .
NU-WAY Environmental Inc.
NU-WAY Environmental Inc.
NU0 WAY Environmental Inc.
. NU-WAY Environmental Inc.
NU-WAY Environmental Inc.
BF! County Landfill
During this last phase .of oversight, CDMF ederal observed· the loading of hazardous mat~rial
. from Lagoon 10 for offsite disposal at a hazardous waste 'facility. Prior to loading, ..
precautionary meaiures ~ere implemented by covering the. ground around the tiuck/tiailer,
.and.the tires themselves, with visqueen. This was to catch any spilled material while loading.
The trailer bed also was lined with visqueen prior to loading the hazardous material. Before
. the truck left the· site, the' tires and underside were pressure-washed to remove any .excess .
. material and a tarp was used to cover the load. . .
It was determined, through analysis, that the frac t~ holding water from vessels; drums; .
·. etc. would be .pumped out with the liquids' going 'into a vac;truck, for transportation to the
local POTW. ·, Liquids were passed. through carbon filters and then analyzed for contaminants
of concern .. Results indicated that manganes~ was still above the cleanup level and there~o.re
. . ' ' . ' -
Ms. Bennett
Field Oversight Report
Page-5 ·
• ..
CDM FEDERAL•. PROGRAMS CORPORATION
, a subsidi~"ry of Camp Dres~er & M~K~e l_nc.
· . could riot. be disposed of in the . orchard area. Therefore, the water w~s transportedto the · .
POTW for treatinent arid disposal'.· -.
. During this period, IlCJn-liazardous material disposal to BFI Landfill in Charlotte, NC and
scrap metal removal to Nationwide, also in. Charlotte, took place. The steel shed which
housed .the horizontal tanks was dismantled.
· CDM Federal is pleased to assist EP.A with this work assignment: If yciu have any questions
or comments Concerning this submittal, .please do not hesitate to calL .
Sincerely,
CDM FEDERAL PROGRAMS CORPORATION·
-t(ovn,~ J ~--
Norma L. Eichlin
Project Manager
cc: . Rob Stern, EPA ARCS IV Project Officer (w/o attachments)
. Gary Clemons, CDM Federal Program Manager (wio attachments)
Document Control ·
Macon
1 of 2
• Subject: Macon
From: Bennett. [e-mail]
Date: Fri, 21 Jul 2006 09:06:33 -0400
To: [e-mail]
•
David, here is my attempt at sanity. Please feel free to chime in
wherever you see fit. I know you work in Word, which I don 1 t care for,
so I am including the comments both within this e-mail and in
Wordperfect, just in case you can open it.
Giezelle
CHARLES MACON SITE
REMEDIAL ACTION REPORT COMMENTS
GENERAL
1. The purpose of the RA report is to document the cleanup activities
that took place. The RA report could not be prepared until after the
cleanup goals were achieved in the soil vapor extraction system. A
previous report submitted to the Agency entitled "Completion Report for
the Removal of Wastes from Lagoon 10, Vessels and Drums" dated January
30, 1995 may provide useful information. In addition, included is a
copy of the oversight report for the remediation.
The report needs a lot more detail about the remediation that
occurred. The report follows the set-up in the guidance, but is
repetitive and confusing. In addition, please remember that this
is the RA report for soils only. The report states this on page
3, but discusses the groundwater remediation throughout.
2. On the sign-off sheet, please change "Site Manager" to "Remedial
Project Manager".
INTRODUCTION
3. In the title on page 1, change "Source Control" to "Source
Remediation". Indicate the contents of Lagoon 10 (Soils, Debris?) and
Lagoon 7 (soils}.
4. The figures referenced on page 1 (figures 2-5) show the
groundwater situation which is not the subject of this report and figure
1 does not show lagoons 10 and 11.
s. After discussing the EPA cleanup on page 2, include a discussion
on the NPL listing and the subsequent PRP lead RI/FS.
6. In the third paragraph on page 2, delete the first sentence, "In
November ... Site." The second sentence should state that the record of
decision (ROD} was 'issued' by EPA in September 1991.
7. Paragraphs 1 and 2 on page 3 should be moved to the next section.
8. In the last paragraph of this section, delete the references to
"OUl". This site was not subdivided into operable units.
OPERABLE UNIT BACKGROUND
9. On page 4, Section 2.1, the remediation level for PCE is 1 ppb.
Even though the state's ARAR is 0.7 ppb, the default value is the
contract required quantitation limit (CRQL).
7/24/2006 8:39 AM
Macon
2 of 2
• • CONSTRUCTION ACTIVITIES
10. Section 3.1.1 should be moved to the Introduction.
11. Section 3.1.2 -All discussions about the ROD and ROD amendment
should be in the Operable Unit Background Section.
12. The Construction Activities Section should start with Section
3.1.3, discussing the actual remediation activities.
CHRONOLOGY OF EVENTS
13. The events should begin with the 1991 ROD and the entries
concerning the groundwater should be deleted.
FINAL INSPECTION AND CERTIFICATION
14. In Section 6.1, please include the dates of the inspections.
15. In Section 6.2, EPA does not approve HASPs. Please delete the 2nd
sentence.
OPERATION AND MAINTENANCE
16. Add "SVE" to the title of Table 2. PCE is missing from the table.
SUMMARY OF PROJECT COSTS
17. Change the third sentence of this section to "In the table on the
next page are the costs estimated in the 1991 ROD and a comparison to
actual costs."
18. Delete the groundwater components in the table. If SVE costs are
lumped into the capital cost for gw, then a good estimate will suffice.
CONTACT INFORMATION
19. Add David Mattison as the NC DENR contact.
(See attached file: rareport-soil-comments.wpd)
. Content-Type: application/octet-stream
, rareport-s01!-commen ts, wpd, Content-Encoding: base64
7/24/2006 8:39 AM
•
5.6.5 Managing Claims
Constructor claims are generally made for the
purpose of requesting more financial remuneration
or to deviate from the schedule. In the claim, the
constructor alleges that the contracting party's action,
inaction, or misrepresentation In the contract
documents has caused an involuntary change in the
cost or time of performing the contract. The
contracting party can use the following techniques
to minimize the occurrence and effects of claims:
Before advertising for bids or offers, ensure
that the drawings and specifications are
biddable, all conflicting language has been
removed, and ambiguities have been clarified.
Make a complete investigation of the
subsurface conditions before soliciting bids
for and starting the RA and include the results
in the bidding documents.
Closely monitor the construction to anticipate
problems and be prepared to resolve thein as
soon as possible.
Because EPA does not have privity of contract with
the constructor for either USACE-or ARCS/RAC-
managed RAs, EPA will become involved in
constructor claims only under certain ciicwnstances
such as when the ARCS/RAC contractor pursues the
claim in the name of the constructor (see FAR Part
33 and the Contract Disputes Act of 1978), If the
ARCS/RAC contractor pursues a claim, it must be
submitted to an EPA CO. Usually, however, the CM
attempts to address any claim issues before the claim
goes to the CO. If the CO denies the claim, it may
be appealed in the Department of the Interior Board
of Contract Appeals or in U.S. District Court.
For USACB-managed RAs, the constructor that
directly contracts with USACE will submit a claim
to USACE for consideration. USACE and the RPM
should communicate so that the RPM is aware of
any conslrllctor claim that might affect the schedule
or achievement of the remedy. If the USACE CO
rejects the claim, it may be appealed in the
Department of Defense Board of Contract Appeals
or in U.S. District Court.
If a claim is filed, the CM or RE should address the
issues raised and control future claim costs by having
the technical and legal staff analyze each issue.
81
•
Chapter 5 • Federal-lead Remedial Actlon
5.6.6 Value Engineering During Conslniction
Value engineering (VE) is to be included in federal
construction contracts worth $100,000 or more with
few el\ceptions (see FAR 52.248-1). The VE clause
for construction is an incentive clause that provides
the opportunity to the constructor to use the latter's
unique knowledge and constructi~n experience as a
basis for submitting a value engineering change
proposal (VECP) (see FAR 52.248-3). Developed
with its own resources (i.e., non-reimbursable), the
VECP is the constructor's proposal to make changes
to the RA project that, if incorporated, will save
money without compromising quality or
performance. The savings resulting from the
incorporation of a VECP are normally shared ( 45-
55 percent split for fixed-price contracts and a 75-
2S percent split for cost-reimbursement contracts)
between the federal government and the contractor
that submits the VECP. However, this arrangement
may vary according to contract type with the sharing
arrangement being determined by the type of VE
and the source of savings (see FAR 52.248-1 (fl).
Payment of any share due the constructor for use of
a VECP shall be authorized by a modification 10 the
construction contract.
After EPA receives a VECP from the contracting
party, it must notify the contracting party os to the
status of the VECP within 45 days or, if additional
time is needed, explain the delay and provide an
expected date for its decision. The RPM/Work
Assignment Manager prepares a letter on the starus
of the VECP review for the CO 's signature. VECPs
should be processed expeditiously; however, EPA
is not liable for any delay in acting upon a VBCP.
If a VECP is not accepted, the CO notifies the
contracting pany in writing, which in twn notifies
the constructor, explaining the reasons for rejection.
Any VECP may be accepted, in whole or in part, by
the CO's approval of a modification to the
construction contract. The CO may accept the VECP,
even though an agreement on price reduction has
not been reached, by issuing a notice to proceed with
the change. Until such a notice is issued or the CO
approves a contract modification, the constructor
must perform according to the existing contract
For USACE-managed RAs, USACE follows its own
VE procedures, but should notify the RPM of any
•
RO/RA Handbook
accepled VECPs Iha! wouldaffcct ROD requirements
or the RA schedule or budget
OSWER Directive 9355.5.()3/FS, "Valtu
Engineering," May 1990, prov/M& addidonal
lnformalion on VB dluing con.,tn,ctiqn.
5. 7 Contractor Completion Activities
As a project nears completion, all parties must
understand their roles and responsibilities to ensure
proper project completion and closeout. Pinal
inspection and closeout activities arc discussed
below.
6. 7.1 Achieving an Operational and Functional
Remedy
Immediately following construction of the remedy,
the remedy enters a "shakedown" phase referred to
as the operational and functional period. This
shalcedown enables the constructor to make minor
modifications as necessa:ry to en.sure the remedy is
operating as designed.
Under 40 CFR Section 300.435, a remedy becomes
operational and functional either one year after
construction is complete or when the remedy is
detcnnined concurrently by EPA and the state to be
functioning properly and is performing as designed,
whichever occurs first
The operational and functional detcnnination by both
EPA and the state is a critical milestone because it
marks the stan of the O&M phase of a project.
Subsequently, disagreements may arise as to whether
the remedy is operational and functional. To
minimize disruption to the project, the RPM should
do the following:
Ensure the designer incorporates into the
design documents (CQAP) the tests thal are
necessary to demonstrate that the remedy is
operational and functional. This requirement
should be included in the RD SOW.
• Obtain agreement with the state tltrough the
SSC on which tests will be used by both
parties to demonstrate that the remedy is
operational and functional.
82
•
5.7.2 Preflnal Construction Conference
A pref anal construction conference is required just
before completing the conatniction work. The
conference will be scheduled by the contracting party
and attended by the RPM, s(l1te, and constructor. The
objective of the conference is to discuss procedures
and requirements for project completion and
closeout. Suggested conference topics include:
• Final O&M plan submission
• Construction clc;anup reaponsibilitiea
• Demobilization activities
• Security requirements for project transfer
• Prefmal inspection schedule
• EPA/slate joint inspection ~hedu)e (NCP
requirement)
• Facility startup and training
• Operator training
5.7.3 Preflnal and Final Inspections
The prefmal and fmal inspections are standard
construction pl"&Ctices for closing oµt a.contract The
purpose of these inspections is to determine whether
the construction was completed in accordance with
the contract They are generally held between the
contracting party and the constructor. These
inspections are often confused with the mandaiory
EPA/slate joint inspection requirement under the
NCP, 40 CFR Section 300.SlS(g), Tho EPA/state
joint inspection is a separate inspection held at the
completion of physical consttliction to obtain
agreement between EPA and the state that the
operational and functional period is ready to
commence. The contracting party and the
constructor, however, may ~ to invite both the
RPM and the state to the preflnal or final
inspection(s) to avoid having to schedule separate
inspections.
Preflnal Inspection
The ARCS/RAC contractor's CM or USACE's RE
and the constructor's construction superintendent
will inspect the site and look at each element of work
to see if it is complete and ready to be accepted. In
some instances, the prefmal inspections can be
performed as each major element of the job is
completed instead of at the end of the project.
•
Generally, there will be a few elements of work still
in progress at this time and some minor defects that
will come to light as the inspection proceeds. A
prefinal inspection report must be prepared that
includes the punch list developed by the CM,
completion dates for outstanding items, and a date
for a final inspection (if one is to be beld).Acopy of
this report should be sent to the RPM.
Fina! lnspecl!on
Work is considered complete when the rernedy is
operational and functional, all punch list taslc8 have
been performed, and terms of the contract have been
met. Thus, completion of construction activities does
not mean that the WA is complete.All parties should
attend the final inspection. The CM or RE determines
the level of work completeness. There may be a few
minor work elements not yet complete, but they may
not affect acceptance of the work. A portion of the
constructor's final payment is retained until these
outstanding elements are completed.
Toe RPM must focus EPA's portion of the inspection
on determining whether the remedy has been
implemented in full compliance with the ROD. In
addition, where anARCS/RAC contractor serves as
the contracting party, the RPM needs to determine
if the work has been completed as described in the
ARCS/RACs work plan. Toe RPM should perform
a thorough work plan review so he or she will be
fully prepared to participate in the inspection. Toe
RPM should have his or her TIO' assist in this
inspection.
Demobilization
Site demobilization occurs after the majority of
construction work is completed. This phase of the
remediation is generally comprised of the followlng
tasks:
•
Removing all equipment, machinery, or
materials that are no longer necessary to
complete site activities
Removing temporary buildings and structurea
Completing all necessary restoration or
replacement of public or private property
affected by the remediation activities
Removing site debris, disconnecting
temporary utilities, and cleaning roadways or
other public access or service areas
83
•
Chaptar 5 • Federal-lead Remedial Action
Transferring all finalized documentation
associated with the construction {e.g., log
books, records, etc.)
Items removed from the site ®ring demobilization
may require decontamination before removal. Fmal
inventories of remaining materials and utilities
should also be completed. Axiy additional or site-
specific requirements contained in· contract
requirements and specifications prepared during the
RD should be addressed.
5.7.4 Contraclual Acceptance of the Project and
Warranty
Accepting the work is an important juncture in the
project because it al= the rights and responsibilities
of the parties involved in the construction projecL
The government takes over full possession of the
facilities from the constructcir upon acceptance of
the work. Final acceptance occurs after final
inspection and correction of the punch list items.The
risk of loss due to damage or theft shift& from the
constructor to the government. By accepting the
work, the government limits its rights to require the
constructor to make adjuslmeDts to or correct defects
in the work.
The government's acceptance doeg not relieve the
constructor from assuming respomibility for the
quality of work performed. If any of the three
exceptions to the finality of acceptaoc-latent
defects, fraud, or gross mist~ found to exist.
the constructor generally must correct the work.
In conditions not described above, a wQTTanty clause
must be in the original contract to en.sure that the
conslrUCtorcorrects any defects, The warranty period
ia usually one year against defects in equipment and
materials or quality of work and design.
Final Payment
Final payment to the constructor cannot occur until
the following itelll& are completed:
• All final drawings, log books, records, and
other docwnentation are received by the
contracting party.
Toe contracting party receives a letter from
the constructOl stating that all work has been
performed in accordance with the contract and
is complete in every reapecL
•
RO/RA Handbook
• 1be contracting party receives a letter from
lhe constructor stating that all wages, debls,
and payments incurred by the constructor
during work perfonnance have been settled or
paid in full.
The contracting party receives .a letter from
the bonding company stating that it has
reviewed the constructor's final request for
payment and agrees that payment will release
the constructor from any and all claims that
the constructor may have against the
regulatory agency(ies) in performance of this
contract
• 1be contracting party receives satisfactory
evidence of the release of any outstanding
liens.
5.7.5 Remedial Action Report
Within 60 days after the final inspection, the
contracting party prepares and submits an RA report
to the RPM for each construction project The report,
the official record of RA activities, is a required
submiual. This is not to be confused with the EPA
contractor or USACE contractual obligations with
the constructor. This is an EPA administrative
requirement only and does not have to be done to
fulfill contractual agreements. The RA report
contains the following information:
• Introduction
• Chronology of events
Performance standards and cleanup goals met
• Description of the QA/quality control (QC)
procedures followed
• Description of construction activities
• Final inspection documentation
• Certification that the remedy is operational
and functional
• Discussion of O&M requirements
• Swnmary of project costs
Review of the RA Report
The RPM reviews the RA report to ensure that the
remedy has been completed and meets EPA's goals
as established in lhc ROD. After reviewing and
accepting the report, the RPM prepares a letter to be
84
•
signed by an EPA branch chief, notifying the
contracting party of the acceptance.
OSWER Directive 9355.0-39FS, "Remedial
Action Reporl-Docunumtation/or Operubu
UniJCompktio11," June 1992,prol'idu mart
i,iformation on RA rtporu.
5.8 State Operation and Maintenance
This section provides a brief overview of O&M
activities. State-performed O&M activities are
necessary to protect the integrity of lhe remedy.
(Additional guidance lhat EPA Headquarters is
developing on O&M should be inserted into the
handbook when available.)
O&M commences on the date that EJ>A and the state
agree that the remedy is openuional and functional.
The exception is active ground water restoration,
where EPA will operate a pump and ti'eat system for
up to ten years, after which time the system is
declared operational and functional
The SSC establishes the rules for transferring the
site and its facilities from EPA to state control. Once
the facility is transferred, it becomes state propeny.
The RPM must ensure that the O&M package
(drafted by the designer) has been complctw by the
constructor and includes all record drawings and
manufacturer equipment manuals. The state and its
contractors should conduct a tour of the site and
obtain any special training necessary to carry out
O&M before the transfer. ·
The RPM should be awlll'C that site access is often
overlooked as part of the transfer pro<:css. The RPM
and state should detenninc what. if any, state site
access is needed to implement O&M. These issues
must be worked out before the state assumes control.
O&M commences on the date in the RA report that
certifies the project is complete and the remedy is
operational and functional (with the exception of
groWld water restoration).
The SSC is also lhe mechanism through which EPA
establishes the state's reporting requirements for
O&M, including the frequency for report
submission. The RPM must continue to review lhese
reports and ensure that they arc submitted on
schedule after the state assumes responsibility for
the site.
•
5.9 Site Closeout Process
The site closeoul process consists of documenting
that all Superfund response action is complete and
the site can be deleted from the National Priorities
List (NPL). Site completion requirements provide a
definitive endpoint to Supcrfund cleanup activities
and satisfy the NCP requirements for site deletion.
Figure S-8 illustrates the site closeout process,
highlighting the following three phases:
• Construction completion activities
• Site completion activities
• Site deletion activities
OBRRJHSCD "Cwseout Procedun1/or NaJional
Priorlde, Lisi Silas," (Dnifl), April 1995,
provuus information on 1h11 siu cloi•oul ~eu.
5.9.1 Construction Completlon Actlvltles
In 1991, the EPAAdministratorestablisbcd national
targets for the number of sites to be deleted from the
NPL through the year 2000. The concept of
construction completion, EPA's primary measure of
accomplishment toward that goal, was created lo
simplify the syslem of site categori""tion and to
beuer communicate the successful completion of site
cleanup activities. Construction completion means
thaL physical consuuction of the remedy is complete
or that no substantial' physical construction is
necessary 10 implement the remedy. It marks
completion of a phase in the Superfund remedial
process buL does not affect the separate milestones
of site completion or deletion. Characteristics of sites
satisfying construction completion criteria include:
Sites where all necessary physical
construction is complete, whether or 001 final
cleanup levels or other requirements have
been achieved
Sites where EPA has determined that the
response action should be limiled to measures
not involving construction (e.g., institutional
controls)
• Sites that qualify for deletion from the NPL
Preliminary Closeout Report (PCOR)
The PCOR f&rrns the basis for the final closeout
report (FCOR) and focuses on site construction and
85
•
Chapter 5 • Federal-Lead Remedial Action
completion. The PCOR includes information on the
release of contaminants at the site, site conditions,
response action, steps remaining for site completion,
and a schedule for their completion. The PCOR
should contain the information shown in Figure 5-11.
The RPM often prepares the PCOR before the RA
report for the final operable unit (OU) becsuse the
RA report can be submitted up to 60 days after
detenniniog that the remedy is operational and
functional. The PCOR gencrally should be three to
five pages long. A draft of the PCOR must be sent to
EPA Headquarters for review. The purpose of the
review is to ensllttl national consistency in reporting
completions. Comtructioo completion is considered
final when the Regional Division Director approves
and signs the PCOR.
NPI. Sita, Involving COn,trucl/on
Completion of physical consuuction means Iha! the
final remedy, 1111 determined by the ROD, bas been
conalnleted at the site and a prcfinal inspection has
identified only minor unfinished activities on Lhe
punch list. When determining eligibilily for
construction completion, the RPM must anticipll!O
likely site progress as well as consider current site
status. A site with a significant number of
outstanding work clements to be completed should
not be categorized as achieving construction
rompletion.Achievingcoostruction completion doea
not imply final~ by EPA.
After a site achieves construction completion status,
some minor tasks will remain before a site can move
towards site completion status (i.e., completing
remaining punch list items, conducting the final
inspection, achieving operational and functional
statua, and signing the final RA report). lo mosl
cases, the RPM should prepare a PCOR to docwnent
ronstructioo completion. However, sometimes the
need for a PCOR is eliminated ~aiuc rffl!edial
activities at the site have progressed to the point
where construction and site-completion
determinatioru occur simultaneously. In these cases,
the RPM can rely on the FCOR to satisfy the
documentation requirements for both events.
Additional information on preparing an FCOR is
presented later in this section.
• •
RD/RA Handbook
Site Completion and Deletion Proceu
Oblak, &la!e CXll'lC00'5)0t
P~ ~ of lnllnd lo dolate (NOID); ob1aJrl EPA HQ commeri11
and Regional Administrator approwl; ~ dele6on docket maleri81
Place deletion dockel in Regional publlo docMI and local n,po&ltory
C PubUsh NOIDln F-~'== local NOIDm~•) of
Pnwide30-day publ~ comment~r1od; ll"'pall ~
WIMIII)', il neceswy, and plaoe In ~ docket and local rapoeitory
Prepate nocice ol dolltlon; pt.t,lloh In FR
NOTE: Sl>lded po,tion iden1ifies lho &leps associated wlh ~ oonstruction and site completion.
88
,,f;•&·1itij'.~J;.i::~
ermlnatlon cl r rallonal and
PAHQ
: oblaln
lilalepee,
{;~-;~~.:tt~~~-~=
kilo FCOA
•
Contents of the Prellmlnmy Closeout Report
• Background ol site conditions
• Remedial construction acllvltles
• Discussion of QNQC trom cle&nup actMlles
• Final Inspection
• RA report and EPA approval
• EPNslate Joi11 Inspection (may COVlClde with Iha
flnal ilspec1lon)
• Operational and funcUooal pelloda
• O&Mperlod
• Discussion ot five-year reviews .........
HPI. Sltaa Not Involving Construction
At some NPL sites, EPA detennines through .the
remedial investigation/feasibility study (RI/PS) that
no remedial construction is necessary to protect
human health and the environment If certain criteria
are met, construction and site completion can be
documented by completing one of the following:
no-action ROD
• no-further-action ROD
• limited-action ROD requiring no physical
construction (i.e., a ROD with only
institutional controls)
A site with a ROD that does not require construction
is considered to be a construction and site completion
site when the Regional Administrator approves and
signs the ROD. If the site is a no-action site where
EPA has never implemented an RA, the RPM does
not prepare a PCOR (or FCOR) and should instead
place the following certification in the declaration
section of the no-action ROD:
"EPA has detennined that its response at this site is
completed and no action/no further action is
necessary at this site. Therefore, the site now
qualifies for inclusion on the construction
completion list."
For sites with no-further-action RODs where EPA
has previously conducted RAs (triggering statutory
documentation requirements), the RPM may choose
either to prepare an FCOR or to document
compliance with statutory requirements in theRODs,
•
Chaptar 5 • Federal-lead Remedial Action
incoiporating information normally included in the
FCOR and the certification mentioned above.
Sites with limited-action RODs not requiring
physical construction may achieve construction
completion when the Regional Administrator
approves and signs the ROD. The RPM docs not
prepare a PCOR, but should instead place ,the
following certification in the declaration section of
the limited-action ROD:
"EPA has determined that its future response at this
site does not require physical construction.
Therefore, the site now qualifies for inclusion on
the construction completion list."
The RPM may not declare site completion at this
time since the site will include some future activities
such as implementing the institutional control
requirements. An FCOR will thus be required (see
section 5.9.2).
5.9.2 Site Completion Actlvltles
Site completion marks the end of r.mledial activity
at a site. A site must meet all for,r criteria below to
be eligible for site completion status:
• Cleanup levels specified in all RODs are met
and cleanup actions and other measures
identified in all RODs are s~fully
implemented.
• The constructed remedy is operational,
functional, and perfonning according to
engineering design specifications.
The site protects human health and tho
environment.
The only remaining site activity to be
completed, if any, is O&M.
A site may meet the site completion criteria
following any one of a number of activities at a site.
For example, a site is eligible for site completion
following completion of the final OU of the RA, a
no-action ROD, or .completion of a long-term
response action. In order to satisfy these
requirements, an FCOR generally will be prepared.
However, in certain cases a final OU limited-action
ROD for a ·site that does not require remedial
construction may be sufficient documentation to
satisfy site completion requirements .(see section
5.9.1).
•
RD/RA Handbook
TheFCOR
The FCOR is a detailed summacy of site history,
emphasizing the RD and RA. In general, the RPM
prepares the FCOR but also may allow other parties
to prepare it. The FCOR is usually 12 to 15 pages
long and should summarize the information
necessary to describe the activities performed and
the results achieved. Figure 5-10 lists the types of
information in an FCOR.
The information neooed to prepare the FCOR should
be readily available from previous documentation
of site activities such as the RA report, Rl/FS, and
ROD.
•
Since it is the final record of site remedial activities, .
the FCOR must be complete and able to stand alone.
The PCOR provides the overall technical
justification for site completion, and so must clearly
demonstrate how the remedial activities conducted
satisfy site completion requirements.After the FCOR
is prepared, the RPM submits a draft to EPA for
review. The state also must be given the opportunity
lo review the FCOR and provide comment However,
the state does not formally offer a signed concurrence
on the report itself. Site completion is considered
fmal when the RegionalAdrninistrator approves and
signs the FCOR.
Final Clo&e0\11 Report Summa,y
Chapter Conlama
I. lntroductlon • General statement i1dlcatr,g successful 8XDCU1icn of RA
II. SWMla,y of Site • SIie llackgiolJnd
CQlldi!ions • Early eciions perlonned
• RVFS. resulls
. ROOllndilgs
• Design crill)ria
• Cleanup activities pe,fOIOled
• Community lnwlvemenl ec1t-i!tles perlonnad
Ill. O>JQC of Cleanup • O>JQC protocol followed
Activlly • 5anllllng and analysis protocol followed
• Results ol on-site nrpectior1s
N. Monitoring Results • Sufficient da1a avallsble to demonstrate cleanup lsvels r;peclfiad in the ROD or action
mamolllnda ha"" been adllevad end Implemented end remedlae ere parformlng to design
specifications
• Brief documentatlon at monltorilg ruqulred at no-action sites aft8r the ROD ls signed
(shollld also be lrdudad In the alinnlslra!lve record)
V. SUIIYnary of O&M • Assurance thal O&M plans are In place end sufficient to malntail irtegrlly of remedy
AciMty • Assurance that all necessaiy Institutional controls ere In place .
• Assurance that O&M eclivitiea specified for the site will be pe,formed by the state 01 PRP(s)
VI. Protectiveness • Assurance that the inplementad remecfy (or ilo-ec1kln decislOll) echleves lhfi degree of
cleanup or protection specified In Iha ROD(s) for all palhwaya of exposure end that no fullher
Supe,fund response ls needed to protecl human health end the enviroom...i
• Assurance that BIi areas of concam de&a1bed In the NPl. li6tlng haw been adequa!Bly
addreSSad
Vil. Flv&-Yeer Review • Statement explaining whe1her a five.year review is appropriate. end H so, the type of review
(statutory or polky) end review schedule
• Brief description of Iha resulls of any five-year review& peiforrnad
• Assurance that the remedy ls protective
VIII. Bibliography • Complete citations of all relevant repolfS
88
•
5.9.3 Site Deletion Activttles
The site is eligible for deletion from the NPL when
all of the site completion activities discussed in
section 5.9.2 are complete. At this point, issues
surrounding placement of the site on the NPL have
been addressed, the threat to human health and the
environment has been addressed, and the Superfund
process has completed its course. Site deletion
requirements ensure that documentation and
verification of activities and decision-making at the
site are complete and the public has an opportunity
to comment before the site is formally deleted from
the NPL.
Section 300.425(e) of theNCP states that a site may
be deleted from or recategorized on the NPL when
no response/no further response is appropriate. The
RPM consulls with !he slate in making this
determination. To delete a site from the NPL, EPA
must determine, and the state must concur, that one
of the following criteria has been rne1:
• Potentially responsible parties (PRPs) or other
persons have implemented all required
response actions.
•
All appropriate Fund-financed response under
CERCLA has been implemented, and no
further response action by PRPs is
appropriate.
The RI has shown that the release poses no
significant threat to public health or the
environment, and lherefore, taking of remedial
measures is not appropriate.
Deletion of a site fi:om the NPL does not preclude
eligibility for subsequent Fund-financed or PRP
actions. If future actions warrant, the NCP provides
that Fund-financed RAs may be performed at sites
deleted from the NPL. When there is a significant
release at a site deleted from the NPL, the site may
be restored to the NPL after resc9ring the site on the
Hazard Ranking System.Additionally, enforcement
actions also may be taken, depending on liability
releases in the consent decree or administrative order.
89
•
ChaplBr 6 • Federal-lead Remedial AcUon
The RPM should initiate the deletion process by
consulting with the state and requesting its
concurrence with EPA's intent to delete the site from
!he NPL. No site may be deltted from the NPL
wirhout state concwrence. Once state concurrence
is ob~ed, the RPM prepares a deletion docket
contai!Jing all pertinent information supporting,the
deletion recommendation. The RPM works with lhe
Superfund community involvement slaff to ensure
that complete copies of !he docket are placed in the
appropriate Regional and local repositories.
Notice of Intent to Dele18 (NOID)
The NOID informs the public of EPA's intention to
delete a site from the NPL. The delctimi docket mus1
be co~plcte before the Region publishes the NOID
in the Fttkral Rtgl.rw (FR) or local newspaper(s).
Site-s~ecific information needed to prepare the
NOID ~hould be available from the FCOR. Figure
5-U lists the contents of a NOID.
The public has !he opportunity to comment on the
intended NPL deletion during the 30-day comment
period that follows publication of the NOID. The
RPM ~ responsible for preparing a responsivtness
s11mmary for all local and national comments
received. The responsiveness summary should
present: all comments received during the public
comment period, paired with detailed responses to
' the ~nts. The RPM must Include a copy of the
responsiveness summary, approved by the Regional
Administrator, in the Regional docket and local . ' repos1t~ry. .
I
Notice o1 Deletion
The RP;M then publishes the notice of deletion in
the FR. mus notice states that all appropriate Fund-
financed responses under CERCLA have been
implert!ented and that no further response is
appropriate. The notice of deletion includes an
' effective date, a Regional contact, and supplemental
site infOfilllltion. All NPL rulernakings subsequent
to the publication of this notice will reflcct !his
deletion,
• •
RD/RA Handbook
Content& of Ille Nolloe of Intent to Delete
ChaplN Conl8nl9
I. Summary Announcement of lnlenl to delete
II. Dates Oates of a 30-4ay pericld for submls$l0n of public comments
Ill. Addresses Name, addresa, and phone number of a Regional IXlllfact to whom commenl8 6houkf be sem;
address ot Reglonaf docket and local repository
IV. Regional Contact Name, address, and phone number of a Regional IXlllfact for fullher llfonnallon or (lllestions
fnfonnation
V. Supplemenlaly lnlormallon: ldenllficalfon of slte(s) kl be deleted and a summary of information In 1he NOID
lnloonallon
NPL Delellon Crltw: List of lhe appllcable NCP allar1a and statement lndlcallng that EPA·
relalns lhe ablf!y fD use Slipelfund aulhorlly Ill a deleted Bila ff Mure <X>OOl!lon8 warrant such
ect1on (40 CFR §30CJ..125(e)(3))
Deklllon Procedurte: brief ~ of procedures followed to delefs sites Iran the NPI.
Buel far lnllnded Slte De1911on(a): bllef de8CI ipllons of fhe tollowi1g ltam8:
• Site hlllory (location, former use, 1)1)8 of COliamlnants, FR citations of propoeed and final
NI'\. llstlng. and aft8 condltions resulli1g In IIM,j)
• All resporme llciklfls taken, Including scope of RI (tt applicable), general reGUIIB, end
COl1cluslons regarding Mure pe,10111l8/lC8 of these actions
-Speci1k: claanup ilandarda and Cltteria and resulta of all c:oofumatory sampli~
• O&M procedures and Bila ~ program
• Reasons for needing ftw-yaar reviaws, li1len approprialll, and plans for 1helr execution, In
8CCllidanc:e wtlh EPA'& plans for their execution, In accordance with EPA's requlremenfs for
plotecttvenesa at fhe ~ of each future mlew
-Major commwity lnYOlvarnent actllffles
• How site meals delellon cri!Bria
• Evlclence Of 8talll concurrence with decl.loo kl delala sita
II-O<U418
Chemistry and Engineering Solutions in the Environmental I
June 30, 2006
David Mattison, P.E.
NCDENR-Superfund Division
40 I Oberlin Road -Suite 150
Raleigh, North Carolina 27605
Re: Transmittal of Remedial Action Report;
Macon Dockery Superfund Site;
Cordova, Richmond County, North Carolina
Dear Mr. Mattison:
•
15 ~ ~ .ffi'. aw~~
jl JUL O 5 2006 lLlJ
SUPERFUNO SECTION
Please find attached one copy of the Remedial Action Report for the Charles Macon Lagoon and
Drum Storage Site located in Richmond County, North Carolina. An original copy has been
submitted to Ms. Giezelle Bennett of the USEPA Region 4 office, under separate cover.
Should you have any questions, please do not hesitate to contact me.
Sincerely,
.
liC~R CONSUL TING, INC.
. 7
ven . rminger, P ..
President
lrminger Consulting, Inc. 7015 Erin brook Drive, Concord, North Carolina 28025
[phone] voice, [phone] fax, [phone] cell [e-mail]