NCD981023260_19940517_Potters Septic Tank Service Pits_FRBCERCLA RD_Remedial Design 1992 - 1994-OCR

Ms. Beverly Hudson
US EPA Region IV
May 17, 1994
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
.. .·.•· . ,
RE: Comments on Draft Final Performance Based Design
Source and Groundwater Remediation
Potter's Septic Tank Service Pits Superfund Site
Sandy Creek, Brunswick County, NC
NCO 981 023 260
Dear, Ms. Hudson:
The Draft Final Performance Based Design for the Potter's
Septic Tank Service Pits Site for Source and Groundwater
Remediation, located in Sandy Creek, North Carolina has been
received and reviewed by the North Carolina Superfund Section.
This document has also been forwarded to the NC DEM for concurrent
review. Their comments will be forwarded when available. The
following comments are offered by the North Carolina Superfund
Section.
1. As we discussed the Groundwater clean-up goal for Benzene
is 1 ppb rather than the 5 ppb noted in Table 1-1 on page
2 and throughout the report. It is our understanding
that this will be changed in the revised Final Report and
that an Explanation of Significant Difference (ESD) is in
the process of completion that will document this change
in the Record of Decision (ROD).
2. NCAC Title 15A Chapter :2, Subchapter 2H should be
included under the North Carolina Water· and Air Resources
Act listed in Section 2.2 on 'page 12. This NC Regulation
establishes treatability study or demonstration phase
requirements and toxic air pollutant limits for sources. . . , . r ~ . . • -
3 •
The "A" is missincf in "Title 15A" of the NC Water and Air
Resources Act Standards.
Their· are contradictory Figure numbers · in the title
blocks throughout Section 3. ·. Please remove the Figure
numbers froin the title blocks or make the appropriate
corrections.
Ms. Hudson
5-17-94
Page 2
• •
The last paragraph on page 18 states that 11 soil borings
were drilled and sampled for chemical analysis and 6
wells were drilled and constructed for aquifer testing.
However, the lab data sheets for the various soil and
groundwater analysis performed and well construction data
are not provided in the report. ~eas.e_P.rovide lab dq:ta1
and well construction information for !:~.yi~w _by the State
as soon as possiole and include this information in the
revised Final report. --
Please provide the temperature scale for the low
temperature thermal desorption as noted in Section 3. 9 .1.
( 6. Perimeter monitoring systems are required by 15A NCAC 2D
.0600, 15A NCAC 2D .0500 and 15A NCAC 2H .0600.
0 herefore, the second sentence of the first paragraph
hould be deleted. "If required" should also be deleted
rom the last paragraph. Please clarify the type of c/.,,'1l monitoring equipment which will be used for perimeter
· (Y'-v>"monitoring and state clearly that perimeter air
iVII-' ~ t,,~ /4· monitoring will be in-place and operational prior to
0 ~«'..tr significant site traffic or operations of thermal systems
l
r,...,,-c-of any kind including those used for the demonstration ~.< -V" phase. The State Division of Environmental Management
(DEM) would prefer and may require that high volume
( 10.
11.
perimeter monitoring devices be used for this purpose.
Details of the perimeter monitoring system must be worked
out with the DEM during the Remedial Design.
Clarification as noted above would minimize untimely
delays.
TCLP testing of one grab sample per 500 yd3 of stabilized
product is not a suitable representative sample. The
State recommends that a composite sample for each
stockpile be taken proportionally from alternating
batches of stabilized product to represent each
stockpile.
Well 10 SPT 1 is not depicted or properly labeled on
drawing number 022-c-001. Please make this correction.
Ms. Hudson
5-17-94
Page 3
• •
The State of North Carolina appreciates the opportunity to
comment on the Draft Final Performance Based Design for the subject
site, and we look forward to working with EPA on the project. If
you have any questions or comments, please do not hesitate to
contact us at [phone]
Sincerely,
Randy McElveen
Environmental Engineering
Superfund Section
cc: Jack Butler, NC Superfund Section
• •
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\',i,~;,,i.-:;;",,, (~·":,;;~"3,;;.; SUPERFUNif""PROGRAM: EXPLANATION OF· SIGNIFICANT' DIFFERENCES·~'::: . -:::•;,i?•1;1..:".~,-'.;,',\ ~r~•.:.-:..l'.,c __ :_,. -:-------- - - ----_-- - -·••,. ,•,tu·"''"''··· ,, .. ,,., ..... , .. · · •. ,, ,. ·,,, .. ,..,.POTTER'S' SEPTIC· TANK SERVICE PITS-SITE, ........ ·•··---· ·,., ... ,, :·. DJ~i~,;"i~f jf :~:r;.,r:"-~~:,~;~:,::~~]'~t;'::"-~
'' ·.,'::~•·•: , . The··:purpoee of this Explanation of Significant Difference
(ESD) is· to' provide· information to the public on· the •changes to.
the remedial activities for the Potter's Septic TanJc Service Pits
Site in Sandy Creek, Brunswick County, North Carolina (the Site).
The remedial action selected by the U.S. Environmental Protection
Agency, Region IV (EPA), the lead agency for remedial activities
at the Site,ie deecr.lbed in detail in.the Record.of Decision
(ROD)eigned on August 5, 1992. The ROD provides for the
remediation of soil and groundwater at the Site.
'· "{'.""·~-~:,t:~:i.':·._;:~:: , .. : ... : . ~ , .. -. · ...... ~-. ..···:·,-".: ;. -.~.0-.,,:-..
;,-,;;,c:.;3: EPAc'hai(ina<ie one,'; change· to. the. implementation•of,:the .
·· recommended"•groundwater: remediation for .. the: Site/>l·: EPA, has
, ; determinEldf that:Tthe. :remediation: goaL for, benzene: should be', l ppb
.. :·);rathe:c'Xthar(thei"Maximwil Contaminant Level~:(MCL), of, 5 ppb as· noted
,•:;.;;Tin':thei',ROD·,'.i;rtThis'Ichange represents a significant; difference from
· the, original(:remediation''goal· for benzene set out in the ROD.
The public will• be notified of .the change in the ROD-through the
publication ·of the ESD; The ESD is being issued by EPA with the
concuirenCe of the North Carolina Department of Environmental
Health>and·Natural Resources (NCDEHNR) .
. .... : "'.f~':_;.:":.::... ····~
. . '; Thie'-ESD: is issued as part of EPA' e · public participation
· . responsibilities under Section 117 ( c) of the Comprehensive·
• / •Environmental-Response, Compensation and. Liability Act (CERCLA),
42,U.s.c:.S·9617(c)/ as amended by the Superfund Amendments and
Reauthorization Act of 1986, and Section 300.435(c)(2)(i)of the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 C.F.R. Part 300. Thie notice includes the information
which provide the basis for the change, the reasons why the
change is appropriate, and a discussion of the extent of the
change ... The administrative record file for this Site contains
the information upon which the remedy selection was based,
including the ROD and Responsiveness Summary. Thie ESD will
become part of that record which is located at the following
locations:
Information Repository
Columbus County Library
East Columbus Branch
P.O. Box 27, Highway 87
Reigelwood, North Carolina 28456
[phone]
' .EPA Region IV Office
U.S. EPA Records Center
Ground Floor
345 Courtland St. NE
Atlanta, Georgia 30365
[phone]
• • Site History
The Potter's Pits ·site is located in a rural section of Brunswick County, North Carolina, in a residential co111111unity known as the Town of Sandy Creek. Sandy Creek is subdivided into one to two acre lots, each with a private domestic water well. There are approximately 150 residential lots of which 70 are currently:occupied:
Between 1969 and 1976, before the land was developed for residential use, the Skipper family operated sludge hauling and oil spill cleanup·companies in this area. Waste disposal pits were operated in and around the Sandy Creek area. Disposal practices consisted of placing waste petroleum products and septic tank sludge in shallow unlined pits or directly on the land surface.
The Potter's Pits Site was divided by EPA into three study areas; Areas land 3 are located in residential lots within Sandy Creek, and Area 2 was located approximately 1,5 miles north across U.S. Highway 74/76. Area 1 comprises the actual Potter's Pits Site. Area 3 was included in the investigation because historical aerial photographs suggested that this,area might have been used as a disposal site. Area 2 was selected based on preliminary information which indicated that wastes may have been disposed of in this area. However, subsequent investigations did not produce any additional information or evidence of such disposal, and Area 2 was removed from further consideration .
. In August 1976, an unlined pit in Area 1 failed and allowed approximately 20,000 gallons of oil to escape. The oil flowed into two streams: Chinnis Branch and then into Rattlesnake Branch. The United States Coast Guard, acting pursuant to Section 311 of the Clean Water.Act, removed the spilled oil from Rattlesnake Branch. Also in August 1976, Mr. Otto Skipper (brother of Ward Skipper) began pumping out the oil remaining in the breached disposal pit (Area 1). Approximately 20,000 gallons of oil were removed from this pit and transported to Port Bragg Military Reservation in Fayetteville, North Carolina.
The oil stored in three other pits at the Site, as well as the oil recovered from the receiving stream, was also taken to Fort Bragg. In addition, approximately 150 dump truck loads of oil sludge and oil stained dirt were excavated and hauled to Brunswick County Landfill in Leland, North Carolina, for final disposal. The thick oil sludge that could not be pumped was mixed with sand and buried on site.
The Skipper Estate changed ownership in 1980. Wachovia State Bank, through foreclosure,.took possession of the property in January 1980. Investment.· Management Corporation later purchased the property and subdivided it for residential development. This development became known as Sandy Creek Acres and later as the Town.of Sandy Creek. In July 1983, owners of
• • the property found waste 'materials buried in their yard, . . . (formerly Pit,Area::l) •. : The State of North Carolina sampl84 th1a ·soil.and, groundwater~;"rAnalysis of. these samples'._confirmed;,the.,; ., ,·.,.,.:. presenciF.of· contamination.·).; The·· Site' e>wner' s ·: watliu:', ·well .,...as-','.::,:;:: :\:;,if\ ··/·~~~~:3r:.f~:It.~}t~,j]ftt7-::t~~~:=~;1 •. ~.~~:}i•:;.0~t-.J~r;·t:.t~t:i::t;rt.:;~tt,li;:}\':···.,_.,,\1,. ;:. . , .InSeptember/1983/iEPA·and.:the· Region IV __ E'.ield ·_Investigatio_n iC '-//" Team (!!'_IT):• ~:i;.f.o~~fan:elect;rom.a(Jlletic . sur:vey _of;:the ;site,,,.,,;,;;., \;,i.',k'i"t?\. moni tored,,_tlle} air ,t. 9<>llected·: soi~; surfac13 ,wat:er ,' .'!l:lld: gro~<h,f,a1:er.:;,;.'<>:: J'.f,!· samples : f or>laboratory. analysis ~,,.er: In· February • 19 84 ;-EPA-Region': IV• ·.• · used ground'penetrating radar (GPR) to further define• .. the' Site boundaries•~:\)\·':',~ ,\/;co,,; _; ,' o;,;,:. ·.· :::;·:.:: .. :i~··:•:.· ·. ·,·_::0::·>.'.\"',\·\i'
In March 1984, an illlmediate Removal Action at the.Potter's Pits Site (Area 1) was requested by the EPA Office of Emergency and Remedial Response. On March 21, 1984, a removal was begun centering around Area 1. A total of 1,770 tons of oily sludge and contaminated soils were excavated and transported to a hazardous waste landfill in Pinewood, s.c. Soil removal activities were completed on April 2, 1984.
In May 1984, EPA-Region IV proposed a groundwater monitoring plan to determine if the Potter's Pits Site (Area 1) presented a . :<:-::>':::':. threat .. t_o .. surrounding,. groundwater sources;• Contamination of the · . shallow, aquifer had been documented at the' Site (during: the , < · . September.,,1983,. FIT; investigation)' in groundwater samples taken .. : ·· :· from·_ootll;a}residentiaL and a monitoring well' on' Site~: . However, "in' orderLt~icharacterize: the nature and extent of the' groundwater ._. contamination'· in. this area, additional wells· were proposed. Nine ,; monitoring wells were subsequently installed and sampled by EPA. ·The locations of these wells were based on the assumption that the groundwater flow was in a northeasterly direction. The sampleii;:were analyzed for volatile organic compounds. Relatively high concentrations of benzene, ethylbenzene, toluene, and · xylenes (BETX).were detected in some of the groundwater samples. . ·._. .. ·. _: ·;.,:, . ·.. ' . · ... ,: EPA conducted a Preliminary Assessment (PA)·· of the Site in September 1987. The PA revealed soil and water contamination at the Site. Subsequently, EPA added Potter's Septic TanJc Service Pits Site on the National Priorities List and assumed lead responsibility for the Site.
The wells were re-sampled in 1988 by the State of North Carolina. These samples were analyzed for volatile organics, phenols, priority pollutant metals, and several nutrients. BETX and phenols were the predominant contaminants detected. In addition, the 1988 data indicated the possibility of low level benzene, ethylbenzene, and xylenes in a "deep• well which would indicate that the "deep• aquifer had now been affected.
The Remedial Investigation (RI) Report, completed in December of 1991, consisted of a two-phase investigation. The investigation consisted of analysis of the sediments, surface water, groundwater, surface soil, and subsurface soil at the
• •
Site. The RI also included an analysis of the potential dangers
to human health and the environment. Based on·the results from
the RI, EPA determined that remediation of the soil and
groundwater was necessary to protect human health and the
environment.
A Feasibility Study (FS) was conducted to analyze the
remedial alternatives. Each alternative was evaluated using the
following factors: effectiveness of soil and groundwater
remediation, cost effectiveness, technical feasibility,
institutional requirements, and the degree of protectiveness to
human health and the environment.
On May 12, 1992, EPA held a public meeting at the Hood Creek
Community Center, in Sandy Creek, North Carolina. At this
meeting, EPA discussed the remedial alternatives developed in the
FS and reviewed the preferred alternative. The ROD was signed
and issued on August 5, 1992. EPA began the remediation at the
Site in 1993, using Superfund monies.
Description of the Remedy
A complete description of the selected remedy is contained
in the ROD which is available at the information repository in
the Columbus County Library and the U.S. EPA Records Center. In
summary, the Potter's Pits remedy addressed the contaminated soil
and groundwater present at the Site. The remedy includes:
• MIGRATION CONTROL (remediation of contaminated
groundwater). Groundwater will be extracted using
extraction wells located within and near the periphery
of the plume. Extracted groundwater will be treated
on-site using an above-ground treatment process which
will include precipitation, flocculation, and
filtration to remove metals; and air stripping to
remove volatile organic compounds (VOCs). After
treatment to meet the National Pollutant Discharge
Elimination System (NPDES) permit requirements, the
extracted groundwater will be discharged to Chinnis
Branch.
• SOURCE CONTROL (remediation of contaminated soil).
On-site soil with contaminant concentration levels
above cleanup standards will be excavated and treated.
Contaminated soil will be treated on-site by a low-
temperature thermal desorption (LTTD) unit. Each batch
will be tested to determine whether concentrations of
heavy metals exceed cleanup standards; if so, the soil
will be stabilized using ex-situ soil treatment.
• •
Description of Significant Difference
EPA has made one change to the implementation of the recommended gr~undwater remediation for the Site. EPA has determined that the remediation goal for benzene should be 1 ppb rather than the Maximum Contaminant Level (MCL) of 5 ppb as noted in the ROD, This change has been made to ensure that the remedy is protective of human health and the environment, and to comply with applicable State laws as provided under Sections ·121 of CERCLA.
Change in the Groundwater Remediation
The groundwater pump and treat remedy selected in the ROD would still be implemented. However, there could be an increase in the length of time the system is operated in order to reach the more stringent North Carolina Groundwater Quality Standard for benzene.
EPA expects to begin the groundwater remediation in accordance with the change outlined in this ESD ~y March 30 1995.
Conclusion
The above-outlined change in the benzene remediation level, represent a significant difference from the remedy outlined in the ROD, Considering the new information that has been developed and the change that has been made to the selected remedy, EPA and NCDEHNR believe that the remedy remain• protective of human health and the environment, complia• with Federal and State requirements that are applicable or relevant and appropriate to this remedial action, and is cost affective. In addition, the revised remedy utilizes permanent ■olutions and resource recovery technologies to the maximum extent practicable for this Site.
John H. Hankinson, JJ:f. Regional Administrator
MEMORANDUM
TO:
From:
RE:
•
January 20, 1995
File
Randy McElveen
Environmental Engineer
NC Superfund Section
•
Remedial Design/Remedial Action Public Meeting
Community Center on Highway 87, Brunswick County
Potter's Septic Tank Service Pits
NCD 981 023 260
Sandy Creek, Brunswick County, North Carolina
On 19 January . 1995, representatives of the NC Superfund
Section attended a public meeting in Brunswick County, North
Carolina to represent the State of NC during the meeting. The
public meeting was held in order to discuss the Remedial
Design/Remedial Action for soil remediation at the Potters Pits
Septic Tank Service NPL Site located in Sandy Creek, Brunswick
County, North Carolina.
The proposed remedial action work is scheduled to start in
January of 1995 and should be completed in August of 1995. The
contractor chosen to performing the soil remediation is McLaren-
Hart Corporation using a IRV-100 low temperature thermal desorption
unit. The IRV-100 unit operates using an infrared heating carriage
with a va·cuum chamber loaded with soils to a depth of 18 inches.
3,000 cfm of air is then drawn through the soil, crating a
stripping effect and a vacuum gradient. The temperature range
during the operation of the unit is 200° to 600°F.
Paul Huff with Bechtel Environmental, Inc. will provide
oversight for the work being performed by McLaren-Hart. Steve
Cotton is the project engineer for McLaren-Hart who will be
responsible for the remedial work at the site. Paul Huff and Steve
Cotton were present at the public meeting and gave computer and
video presentations of the work to be performed and answered
general questions asked by the public. The first 2 weeks of work
at the site will include A demonstration phase with air monitoring
and testing of the soils to verify that the performance standards
are being met. Full scale operations will follow after a successful
demonstration.
Ambient and perimeter air monitoring will be performed on a
continuous basis. The IRV-100 thermal desorption unit should has
a 99.6 % efficiency rating on emissions. Off-gas flow will be
reduced and the vacuum increased to reduce the general flow rate
• •
and increase carbon treatment time. Ambient air
conditions will be established for various wind
(especially for the direction of Regalwood Industries.
has a automatic shut-down of the thermal unit in
emergency.
cc: Jack Butler, NC Superfund Section
background
directions
The system
case of an
POTTER'S SEPTIC TANK SERVICE PITS SITE
Sandy Creek, North Carolina
PUBLIC MEETING
AGENDA
January 19, 1995
Hood Creek Community Center
Highway 87
Sandy Creek, North Carolina
AGENDA:.··
Welcome, Introduction and
Community Relations
(Approx. 5 minutes)
Brief Site History
Overview of Remedial Design/
Remedial Action Process
(Approx, 10 minutes)
Remedial Design/Remedial
Action Activities
(Approx. 30 minutes)
Diane Barrett
Community Relations Specialist
Beverly Hudson
Remedial Project Manager
Paul Huff
Bechtel Environmental, Inc.
EPA's Contractor
Steve Cotton w/
McLaren/Hart the Remedial
Action Subcontractor
Question and Answer Period
Closing Remarks/ Adjournment
• •
NOTES
• • REMEDIAL DESIGN FACT SHEET
~.; , · , • . ..., ,';, I •· '•• ."1-'/fJi}f:
PHASE 1 · SOIL REMEDIATION:
Potter's Septic Tank Service. Pits-:Site
Sandy,Creek, Brunswick County, North _C_arolina
January 1995
This tact sheet is not intended to be a technical document but has been prepared in an effort to provide the general public with a better
understanding of the technology to be used to treat contamination at this Site.
INTRODUCTION
The Remedial Design (RD) of the selected remedies outlined in the Record of Decision signed on August 5, 1992,
has been completed by Bechtel Environmental, Inc., EPA's contractor. The Remedial Design provides the groundwork
for implementing the remedies specified in the Record of Decision which are Low Temperature Thermal Desorption
and Stabilization treating contaminated soil, and Chemical and Physical Treatment and Air Stripping using an
above-ground system treating contamination in ·groundwater .. However, based upon the data generated during the
sampling activities concerning the groundwater in the lower aquifer in the area, the Agency has decided to split the
cleanup activities into two phases. Phase 1 will be conducted first and consist of treating the contaminated soils.
Phase 2 will cover treatment of contaminated groundwater. The Agency has determined that more sampling and
analysis of the groundwater in the lower aquifer. is needed in order to better characterize the ·contents in the water
to make sure the selected groundwater treatment system will be effective on all contaminants found.
EPA has placed a copy of the Remedial Design for public review or copying in the Information Repository located in
the East Columbus Branch of the Columbus County Library, Highway 87, Reigelwood, North Carolina, phone
[phone].
*******************.*****************************************
REMEDIAL DESIGN
The components of the Remedial Design consist of
performance specifications, drawings and schedule
requirements for getting tasks accomplished, health ·
and safety requirements, and operation and
maintenance procedures. The design also documents
specific performance requirements for meeting all
State and Federal regulatory requirements.
The contract to implement the Design for the Thermal
Desorption and Stabilization treatments was awarded
to McLaren/Hart, Philadelphia, Pennsylvania.
' .
REMEDIAL DESIGN PUBLIC MEETING
January 19, 1995
. Location: Hood Creek Community Center
Highway 87
Sandy Creek, North Carolina
• The following is a br_ief summary of remedial work
ac\ivities that will be performed by the contractor at'the
Site: '
Site preparation includes complete removal and
disposal of vegetation (trees, brush, rubbish and
debris) from the work area as well as the removal
of _any_ s_tructures. All removed iterr~ yiill be
properly disposed of off Site' in an approved
landfill or disposal area.
Earthwork includes excavation of . materials,
trenching for utilities, and backfilling and grading
of areas to set up the treatment units. All earth
moving· equipment must meet applicable codes
and standards. A plan for controlling debris, dust
and sediments during excavation will be
implemented.
Set up and furnish temporary office trailers,
sanitary· facilities and parking area on site for
workers. A telephone line will be connected to the
· office facilities as well as electricity.
Contractor will arrange for-water s~rvice from
existing outlets to the pciint of use for duration of
treatment operation. Contractor will remove all
materials and equipment used to extending water
service connection to the work areas after the
remedial work has been completed.
Surface water will be directed away from work
areas via diversion ditches, dikes and grading.
Excavation and backfill areas will be protected by
sediment barriers to prevent erosion. A
stormwater control system will be implemented to
prevent run-on and run-off of rainwater at the Site.
Contractor to furnish and install 8-foot fencing
around work areas and the water treatment
system to restrict entry of unauthorized personnel.
Hauling roads will be established as required to
transport soil, solidified materials; debris, etc .. Any
vehicles utilized to transport materials off Site will
be either single or tandem axle dump trucks
operating according to DOT and State regulations.
' .
• A tarp will be placed over the truck bed to prevent
contaminated material from being blown,:□tspifie~ ·
·• from the truck. The contractor wilJ op~ra\!f!.iiQ~{r: :, .
an approved spill prevention and'contr,stgl_cin)§·· • · '" ·
address any accidental spills. · '. • • :~ ,.{' . ··-' ,,,.:.;':
i ! .. t .. Excavate contaminated soils to 1 foot below . -'
.,. , •.. exi_st_i~g grade as required by the Record of
· '· ·· Decislon_-Soil below excavated soil areas will be
sampled to determine if contamination has been
removed. If contamination is still present in the
soil, excavation will continue in one foot.intervals
·. until contamination is no longer fou~d bas~.d upon
. sampling and analysis at each one•.foot level. .
· Establish a decontamination pad area on Site;
ensure proper decontamination of all equipment,
· tools, and supplies brougDt t~ the Site before and
after use;. proper 'disposal of, any wastewater
-generated du0ring the decontamination process.-
. . , ,
Develop·a,:Health & Safety Plan'which will be
-:, protective of workers on-site and the public during
all field activities.
Contractor will set up air monitoring devices to
determine worker and public exposure to dust or
vapors during soil excavation and operation of
treatment system. The contractor will implement
dust control procedures to prevent the spread of
contamination and the generation of dust during
Site operations. This will be a part of the Health
and Safety Plan for remedial operations.
• The contractor shall provide sound barriers or
baffles around the thermal desorption unit to
minimize noise level from equipment while in
operation.
Restore the property to the original setting by
backfilling, grading, seeding and fertilizing.
Existing turf areas, pavements, and facilities that
are damaged during Site operation activities shall
be restored to their original condition by the
contractor.
2
• Remove .. all . materials and supplies, .after
completion ·01. the· re
1
m_edial work.
Before i~itiati°ng the tre~t~ent operations for soil il~d
g(~Hndwaier, the COD.tractor shall perform ., a_.·
demonstration phase test of the full-scale treatll)ent
systems which consists of designing and providing tne.
treatment unit, installing, starting-up and conducting
the performance testing. The first p~ase will be
treatment of contaminated soil. Contaminated soil will
be excavated and put into the low-temperature thermal
desorption (L TTD) unit. The unit will operate
continuously for 2 weeks during the demonstration
test. Any off-gases from the treatment process will be
treated and must comply with State and Federal
requirements. The treated soil exiting the treatment
unit will be analyzed to make sure that the cleanup
goals specified in the Record of Decision are met. · If
the levels of inorganics are higher than the cleanup
goals, the soils will be stabilized/solidified and either , •. I , • . • -' '"' • , • ' . ' ~ buried on site or transported off site· for disposal in a
RCRA approved waste landfill. Full,scale operation·
and maintenance cannot begin until the demonstration
phase has· been approved. on·ce operation of the
thermal desorption unit has been approved the
contractor can begin the full-scale treatment of
contaminated soils. Soil will be excavated and placed
in a stockpile on site to enable soil to be continuously
fed into the treatment system. The goal i_s to treat 1 O
tons of soil per hour. The treated soils will be
analyzed to ensure that they meet the soil cleanup
standards and if clean, the soil will be used to backfill
excavated areas at the Site. Those areas will be
graded and seeded with native vegetation.
Any soils containing levels of chromium, lead and zinc
above clean-up standards will be stabilized/solidified.
This method consists of mixing these soils with an
agent such as portland cement to prevent
contaminants from moving or being transported via
rain or melting snow or ice. This mixture confines any
contaminants solidifying them within the cement. The
solidified materials may be taken off site and properly
disposed of in an approved landfill or designated area
or buried on site.
• Groundwater remediation will be conducted·'in' the
s~cond phase of Site ,cleanup activitie'si'Th~ second
phase will consist of taking additional groundwater
samples of the lower aquifer and analyzing those
s,~l)lPJ~S.:,·.The lower aquifer i~ going to require more
study and chamcter)fation, Le., locatior ·and thigkness
of aquifer, boundaries of plume, calculatio.n of pumping
rate, installation of additional wells if required, etc. The
contractor will develop and submit to EPA q_qetailed
design for an extraction system for the· lower aquifer
based upon the field investigation. ·
As with 'the soil treatment system, the contractor will
conduct all field activities as described in the work
plan. Some of the tasks to be conducted are:
Design, furnish, install, start-up and conduct
performance testing of a groundwater treatment
· system to treat groundwater and surface water
contaminated with volatil~ organic compounds and
m·eials. Materials to be used for well installation
'must have a 30-year life span. · '
The treatment system will be automated for
continuous operation and maintenance. The
system will have a autoniatic shut down alarm in
the event of a malfunction, and all groundwater
pumping and treatment operations will stop.
The treatment system will be located within a
boundary fence.
• The treatment system will discharge into the
Chinnis Branch and discharged water must meet
all State and Federal standards.
The extraction system will have a minimum
extraction rate of 1,800 gallons per day, and be
installed in optimum locations in order to provide
the maximum rate of extraction of the contaminant
plume.
• • The contractor will develop and implement a plan
to monitor the performance of the extraction
system on a continuous basis.
3
• The c_ontractor will provide and implement a spill..
control aild 'air moniioring plan relating to' the
installation. and operation of the water treatment
. · ·system. ·
. ,. •• • I .• • The contractor will operate up-and-running·
treatment system under an approved "Ope_ration
· & Maintenance" plan: · · · ·
: • I' •
A Site restoration plan will be· developed and
implemented in order to restore the property to its
original lines and grades. This will include
backfilling, grading for drainage, seeding,
mulching and fertilizing. .,.·
• • Contractor will be responsible for obtaining all_
perm its concerning consiiucii'on and opi:fration of
the extraction and tre'atni'ilfrit'systems. ·· ' · ··
Please refer to the Record of Decision and Record of
Decision Fact Sheet of AJ'gust 1992: for· more
description of the se_lected rein~di~s-. Thes.e and cit~er
documents are housed in-th'lfinfor'niation repository. . _, -:· •',·. ' _I',' -located at:
'. '1·• .,· .
East Columbus Branch of
Columbus County_ Library
Highway 87
Reigelwood, NC 28456 ·
Phone: [phone]'
. . ; . .
OPPORTUNITIES:FOR COMMUNITY INVOL?EM
0
~NT ..
EPA will be conducting a public meeting on Jan~ary 19, 1995, beginning at 7:00 P.M. at the Hood.Creek Community
Center .. We 'will be there to provide the public with more detailed information concerning remedial design activities
at the Site and to answer questions. Please com·e and join us. · · -· · · ·
EPA will continue the community relations program at the Potter's Site to ensure that local officials and residents near
the Site are kepi informed. on activities of the cleanup to be undertaken. This program is designed to respond to
citizens' concerns and to ensure that those concerns are addressed. Future community relations activities will include
telephone contacts, correspondences, distribution of fact sheets, and notification via the Site mailing list, local radio
and news media. We encourage citizens to visit the information repository to review documents concerning the Site.
For more information about the Site, please ~ontact either:
Beverly Hudson, Remedial Project Manager (1-800-435-9233 ext. 4116)
or Diane Barrett, Community Relations Specialist (1-800-435-9233 ext. 4111)
U.S. Environmental Protection Agency, Region 4
345 Courtland Street, N.E.
Atlanta, Georgia 30365
4
• •
MAILING LIST
If you know of someone that would like to be added to the Potter's Pits Superfund Site mailing list or need to
change your address or would like to be deleted from the Site's mailing list, please complete the following information
and return to Diane Barrett at the address indicated above. Thank you.
NAME ___________________________ _
0
ADDRESS--------~-----------------
CITY, STATE, ZIP CODE ______________________ _
Region 4
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Official Business
Penalty for Private Use $300
ADDITION CHANGE
North Superlund Remedial Branch
Diane Barrett, Community Relations Coard.
Beverly Hudson, Remedial Project Manager
DELETION
5
?o~~;~~-~ PA Facts About
\${)_., Polycyclic Aromatic Hydrocarbon
~( PRCJ1'oc:;\
What are polycyclic aromatic
hydrocarbons'!
Polycyclic aromatic hydrocarbons (PAHs) arc a
group of chemicals formed during the incomplete
burning of coal, ciil, gas, refuse,.or other organic
substances. They arc a widespread product of
combustion from common sources such as motor
vehicles and other gas burning engines, wood
burning stoves, cigarette smoke, industrial soot,
and charcoal-broiled foods. Wood which has
been treated with creosote also contains PAHs.
Natural sources include volcanoes, forest fires,
and shale oil.
As pure chemicals, PAHs generally exist as
colorless, white, or pale yellow-green sqlids. Most
PAHs do not occur alone in the environment;
they arc found as mixtures, or compounds, of two
or more PAHs. They can occur in the air
attached to dust particles, or in soil or sediment
as solids. Except for research purposes, no
known uses exist for most of these chemicals;
there are over 100 different PAH compounds.
Most do not dissolve easily in water; some readily
evaporate into the air. They generally do not
burn easily and will persist in the environment for
months to years. P AHs have been detected at
over 1,975 of the 2,783 hazardous waste sites
analyzed.
How might exposure to polycyclic aromatic
hydrocarbons occur'!
Exposure to these chemicals may result from contact
with I' AH vapors or PAHs attached to dust and other
particles in the air. Other sources include vehicle
exhausts, wild fires, agricultural burning, and hazarcJous
waste sites. Exposure to PAHs in soil may occur near
areas where coal, wood, gasoline, or other products have
been burned. Exposure to PAHs in the soil may also
occur on or near hazardous waste sites, former
manufactured-gas sites,_ and wood-preserving facilities.
PAHs havs been found.in some drinking water supplies
in the United States.
June 1992
PAHs arc present in tobacco smoke, smoke from wood-
burning stoves and furnaces, creosote-treated wood
products, cereals, grains, flour, bread, vegetables, fruits,
meat, processed or pickled foods, and beverages. Food
grown in contaminated soil or air may also .contain
PAHs. Cooking meat or other food at high
temperatures, which happens during grilling or charring,
increases the amount of PAHs in the food.
How can P AHs enter and leave the body'!
PAHs can enter the body through the lungs when air
that contains them is inhaled. This is one of the most
significant routes of exposure for people living near
hazardous waste sites. Drinking water or swallowing
food, soil, or dust particles that contain P AHs are other
exposure routes. Under normal conditions of
environmental exposure, PAHs can enter the body if
skin comes into contact with soil that contains high
levels of P AHs. This type of exposure could occur near
a hazardous waste site, or from contact with products
that contain P AHs.
PAHs .enter the hody quickly by all routes· of exposure.
This rate is increased when PAHs arc present in oily
mixtures. PAHs travel to all tissues of the body. that
contain fat, and tend to be stored in the kidneys, liver,
and fat, with smaller amounts in the spleen, adrenal
glands, and ovaries. Most PAHs that enter the body
leave within a few days, primarily in wastes.
Is there a medical test to identify
polyc,-yclic aromatic hydrocarbons?
Once in the hody, PAHs arc changed into
chemicals I hat can attach to substances within the
body. The presence of P AHs attached to these
substances can then he measured in body tissues
or blood following exposure to PAHs. However,
this test is still in the developmental stage. PAHs
or their hrcakdown products can also he measured
in urine. Although these tests can reveal
exposure to PAHs, they cannot predict the
severity of any health effects that might occur or
,dctcrm!nc the extent of exposure.
How can P AHs affect human health?
Several of the PAHs, including hcnz(a)anthracenc,
bcnzo(a)pyrenc, benzo(b)fluoranthene, chrysene,
bcnzo(k)Ouoranthcne, dibcnz(a,h)anthracene, and
indeno(l ,2,3-cd)pyrcne, have caused tumors in
laboratory animals when fed to them, applied to their
skin, or when they breathed them in the air for long
periods of time. Mice fed high levels of benzo(a)pyrene
during pregnancy had difficulty reproducing and so did
their offspring. The offspring from pregnant mice fed
benzo(a)pyrene also showed other harmful effects, such
as birth defects and decreased body weight. Similar
effects could occur in humans, however, no information
is available to document these effects.
Studies in animals have also shown that P AHs can
cause harmful effects on skin, blood, and the immune
system following both short and long-term exposures.
These effects have not been reported in humans.
What levels of exposure have resulted in·
harmful health effects?
No information is available. from human studies to
determine health effects resulting from exposure to
specific levels of the individual PAHs. However, long-
term inhalation and skin exposure to mixtures
containing PAHs have been associated with cancer in
humans.
What are the methods of treatment and
disposal of PAI-ls?
Approximately one-third of PAHs in solution bind to
particles and can be removed by sedimentation,
flocculation, and filtration processes. Remaining
dissolved PAI-ls usually require oxidation (comhining
with oxygen) for partial removal or transformation.
Specific P AHs can he destroyed hy rotary kiln
incineration at temperatures ranging between l,50(l°F
and 3,00CY'F. Others can be oxidized using such agents
as concentrated sulfuric acid. Anthracene, one form of
PAH which may contaminate water, can be destroyed by
sorption with powdered activated charcoal, filtration
through a granular 1ctivatcd carbon bed, and chemical
oxidation.
•
What recommendations has the federal
government made to protect human health?
Based on data on benzo(a)pyrene, the federal
government has developed regulatory standards and
guidelin_es to protect individuals from the potential
health effects of P AHs in drinking water. The U.S.
Environmental Protection Agency (EPA) has provided
estimates of levels of total cancer-causing PAHs in lakes
and streams associated with various risks of developing
cancer. EPA has also concluded that any release of
P AHs of more than I pound should be reported.
For more information about PAf-is, · please
contact EPA at the following address:
U.S. Environmenrn! Prorection AgcnLy
Superfwul Program
Community Relations Coordinator
345 Courtland Street, N.E.
Atlanta, GA 30365
The infonnation contained in this focl sheet was compiled from the Toxicological Profile for l'AHs, Agency for Toxic Substances and Disease Registry,
U.S. Public Health Sc1vicc, in co!lahoration with the U.S. Environmental l'rntection Agency, December, 19<.JO. '/his [net sheet focuses ma the impact
of hazardous wa.\'tes 011 human health; however, EPA docs cvalut1te lh,;sc impacL1· on the crwironmrnt, including plants and ariimab:.
PA Facts About
Lead
What is lead?
Lead is a bluish-gray metal which occurs naturally
throughout the environment. Lead and its
compounds are found in plants and animals used
for food, and in air, drinking water, surface waters,
and soil.
Lead is mined from ore deposits or salvaged from
recycled scrap metal. It is used in a wide range of
products; the main use is in the manufacture of
storage batteries. Other uses are the production of
chemicals, including paint, gasoline additives,
ammunition and various metal products (for
example, sheet lead, solder, and pipe).
How can lead and its compounds affect human
health?
Lead exposure is especially dangerous for unborn children
because their bodies can be harmed while they arc being
formed. Exposure of the mother during pregnancy can cause
premature birth, low birth weight, or even miscarriage.
Young children arc also at an increased risk because more of
the lead ingested into their bodies is absorbed and they arc
more sensitive than adults to its effects. Lead exposure in
infants and young children has been shown to decrease IQ
scores, retard physical growth, and cause hearing problems.
These health effects can occur at exposure levels once
thought to be safe.
A link between lead exposure and cancer in humans has not
been demonstrated. However, because laboratory animals fed
lead throughout their lives have developed tumors, lead
should be considered a possible cancer-causing substance in
humans. ·
Exposure to high levels of lead can cause severe brain and
kidney damage. Lead exposure may increase blood pressure
in middle-aged men; high levels may also affect the male
reproductive system.
June 1992
Is there a medical test to identify lead exposure?
Lead exposure can be identified by measuring the amount of
a substance called erythrocyte protoporphyrin (EP) present
in red blood cells. The amount of EP is high when the
amount of lead in the blood is high. However, there arc
problems associated with this technique. Unless the lead
levels arc extremely high, EP levels may be within what arc
considered normal limits. In addition, other diseases which
affect the red blood cells, such as some types of anemia, can
cause high EP levels. Exposure can also be identified by
using x-ray techniques to measure the amount of lead present
m bone and teeth. However, this test is not commonly used.
How does lead enter the body?
Lead exposure stems primarily from contact with
contaminated dust or water. Lead present in the air
attaches to dust. Dust. contaminated with lead is
removed from the air by rain. Lead can remain in the
soils where it is deposited for many years, however,
heavy rainfall can cause lead contaminated soil to
move into both groundwater and surface waters. Lead
and lead compounds have been found at 853 of
approximately 1,300 sites on the National Priorities
List of hazardous waste sites in the U.S.
Lead can enter the body through inhalation of air
contaminated with lead particles or dust which
contains lead. Nearly all lead entering the lungs moves
to the blood and then to other parts of the body. In
adults, very little of the amount of lead ingested in
food, beverages, water, and dust enters the blood from
the inte-stinal tract. However, when children swallow
food or soil containing lead, much more of the lead
enters their blood and moves to other parLs of the
body. Relatively small amounts of lead enter the body
through the skin.
Regardless of the route by which lead enters the body,
most is stored in hone. Since additional lead is stored
with each new exposure, the level in bone-, and teeth
incre,1ses with age. Lead that is not stored in the body
is removed in bodily wastes.
•
What recommendations has the federal
government made to protect human health?
The Centers for Disease Control (CDC) recommends
that screening for lead poisoning be included in health
care programs for children, especially those between
the ages of 6 months and 9·ycars.
The CDC recommends immediate medical treatment
for children found to have blood lead levels of 250
parts_ per billion (ppb) or greater. The term "parts per
billion" is a way of expressing the concentration of a
contaminant in a liquid or air. One part per billion is
equal to one inch in a distance of about sixteen
thousand miles (or a penny in ten million dollars), a
very small amount. There is now concern that levels
as low as 100 to 150 ppb might be harmful to children,
and because of this, the CDC is reviewing current
screening criteria.
The Consumer Product Safety Commission (CPSC)
docs not permit lead content in most paints to be
above 0.06%. _The CPSC suggests that all painted
surfaces in homes be tested for lead. Paint which is
found to contain high levels of lead should be
removed.
Tiie Environmental Protection Agency (EPA) prohibits
lead levels in drinking water above 15 ppb of lead in
water. EPA suggests that public water systems treat
their water to decrease contamination from plumbing
(pipes, solder, etc.) if the level of lead in tap water that
has been standing overnight exceeds 15 ppb. Drinking
water in schools must he tested for lead and provision
made for its removal if lead levels exceed allowable
limits.
How might exposure to lead occur'?
Lead exposure can result from inhaling air, drinking water,
or ingesting foods or soil thal contain lead. Inhaling air
containing lead-contaminated dust or ingesting lead-
contaminated soil, both of which may be found at ha?ltrdous
waste sites or near areas with heavy automobile traffic, arc
also exposure sources. Children may be exposed to lead by
swallowing such non-food items as chips of paint which
contain lead.
•
Until recently, the largest single source of lead in air was
vehicle exhaust. Other sources of release to the air include
emissions from iron and steel production, smelting .
operations, municipal waste incinerators, and lead-acid
battery manufacturers. Cigarette smoke is also a source of
lead.
The major sources of lead released to water arc lead
plumbing and solder in houses, schools, and public buildings;
lead-contaminated dust and soil carried into water by rain .
and wind; and wastewater from industries that use lead.
Lead can be released to lhe soil from lead-contaminated
wastes in municipal and hazardous waste landfills, and from
fertilizers that contain sewerage sludge. Plants can absorb
lead from contaminated soil, and as a result, food and .
beverages may contain lead.
What is the method of treatment and disposal of
lead?
The primary method of disposing of lead is recycling; an
estimated 70-75 percent of the lead produced in the U.S. is
considered recyclable. Certain uses of lead preclude
recycling, for example, lead used in gasoline. Over 90
percent of the lead used in manufacturing lead-acid storage
batteries is recycled; 50 percent of the lead requirements arc
met by recycled lead, mostly from lead batteries.
A substantial amount of lead is disposed of in municipal and
hazardous waste landfills. Lead is commonly disposed of as
lead-containing waste products such as storage batteries,
ammunition waste, sheet lead, solder, pipes, lead-based
paints, and solid waste from lead mining and mineral ore
processing.
For more information about Lead, please contact EPA
at the following address:
U.S. Environmental Protecrion Agency
Superfund Program
Community Rdations Coordinator
345 Courtland Street, N.E.
Atlanta, GA 30365
The information contained in this fact sheet was compiled from th<.: Toxicological Profile for Lead, Agency for Toxic Substances and Disease Registry, U.S.
Public Hc:-tlih Service, in collaboration with the U.S. Environmental Protection Agency, June, I 990. This fact sha:t focuses on the impact of hazardous wartc.r
on human health; however, El'A does '-'valut11c these impacts rm the environment, including plants and animal\-. impacts m1 the environment, i11cludi11,: plams and
anitn.ak
THE IRV-1 00: ACLlt:..Lt:-t-<,..., ~~,
.IL REMEDIATION
A patented remedial option now avail-
able through McLaren/Hart is the IRV-
1001 a portable, mobile contaminant
removal system used to treat volatile
and semi-volatile hydrocarbons in cont-
aminated soil. This innovative treat-
ment was invented by Terra Chem, a
member of McLaren/Hart's remedial
services group. The principles of the
TerraChem soil treatment method
include conduction and convection
heating and vacuum extraction through
reduced pressure volatilization of the
material.
A PR □VEN □N·SITE · ,
REMEDIAL PR □CESS ' ·
This exciting new on-site remedial
process features the IRV-100, a low
temperature thermal desorption unit,
which remediates contaminated soil by
utilizing an infrared heating carriage.
The innovative design of the system
consists of a 16-foot 1ong steel contain-
er with a base vacuum extraction
chamber and a cover containing an
infrared heat source. The base of the
unit contains a series of well screens
and steel tracks. The tracks allow the
• direct loading and unloading of soils,
thus simplifying the batch treatment
process.
The unit is designed to treat
volatile and semi-~olatile organics,
including:
► Hydrocarbons,
► Pesticides,
► Mercury,
► Se\eniumi
► Chlorinated Solvents,
► PCBs, and
► Arsenic.
The contaminated soil is loaded into
the vacuum chamber to a depth of 18
inches, and then 3,000 cfm of air is
drawn through the soil, creating a strip-
ping effect and a vacuum gradient.
Next, the infrared carriage is roHed into
position over the container and pro-
duces hot air and radiant heat which
raises the temperature of the soil to
200° to 600° F. The infrared heat ele-
vates the temperature of the top few
inches of soil, which then becomes a
convection emitter of heat. An extrac-
tion fan pulls air downward through
the soil increasing the temperatures of
the lower layers of soil. The downward
air flow a;cl temperature differential
between the soil surfaces determines
On-site remediation of contami1wted soil utilizing the IR V-100
--, .n,;: 1..11 cic11~111t energy transfer and crc;ites reduced pressure in the extrac. tion chamber.
REGULATORY
AGENCY , 'ApPROVED
, '
The innovative design of the IRV-100 allows the system in many states ta be considered an enhanced vacuum extraction system. As a result, air moni-toring controls are usually not required. This allows McLaren/Hart to speed up the remediation process and save our clients money because the project is not delayed by having to obtain air per-mits. The IRV-JOO has an optional emission control system which can be added when operating in states which ·equire air emissions monitoring. This ·mission control system consists of a ooling loop followed by a carbon fil-·ation system,
EMEOIAL TECHNOLOGY I n·1-;1 REAL WORLD ', '. , □VANTAGES
-. .•,
'
, . -e unique design of the !RV-JOO unit ·;:rs many cost and time saving ~H1tages. The compact unit does not ize a rotary kiln, which makes the ·-IOO portable and very easy to 1ilize. As a result of this design, the .-I 00 can be transported in a stan-flat-bed truck, elirninating any ional transportation and permit~ osts. The compact design also , the unit adaptable to any site tions, including those sites where weas may be very limited or con-In addition, our unit c:111 be ·led and set up at most project ithin 24 hours. The IRV-100 , been designed to offer cost-
effective on-site soil remediation through flexibility and simplicity.
FROMl DEVELOPMENT
To' .□N·S1tTE APPLICATION
The !RV-JOO.unit has treated hundreds of thousands of cubic yards of contami-nated soil nationwide. Our project experience includes remcdhting conta-minated soil for clients such as: ► US Army Corps of Engineers, ► US Navy,
► Fortune 500 companies, and ► Industrial companies.
The systems flexibility allows for the addition or rcmov,1! of uni ls to meet the needs of individual project sites. Modifications can also be made to cus~ tomize the technology to Jchieve the most cost-effective ::md _timely results.
Additionally, a condensed JRV-100 unit is also available to perform a pilot-scale demonstration at potential project sites.
'
' SYSTEM SPECIF"ICATIONS
Operation Temperature: 1200° F Operational Heat:
Work Space Needed:
Power Rt:quircrnent.s:
Heater Pressure:
Air Turnover
Equipment:
Requirements:
1.5 million BTU/HR
20' s 30'
230 volt 3 ph.lse power
! 3 inches waler column
3000 CFM
Ford 555 C Backhoe
or comparable model ----------1~
Soi! Temperature:
Fuel Requitcments:
200 -GOO' F
1000 gallon tank LP or natural gas All specifiCCl!ions are subject to variance depe1ufo1g on the clwracterisiics mu! maisttire co11tw1 of tlw m<lferir1! tu be ireuted mul type, mixture, or levels of contami,wtion.
··Agency for.Toxic Substances and Disease Registry . , · .. · . :·' · : . .· · . . . ' , . . . April 1993' . • . I' . -,
This fact sheet answers the most frequently asked health questions about benzene. For more
information, you may call 404-639-6000. This fact sheet is one in a series ol' summaries about
hazardous substances and their health effects. This information is important because this substance
may harm you. The effects of exposure to any hazardous substance depend on the dose, the
duration, how you arc exposed, personal traits and habits; and whether other chemicals are present.
What is benzene'!
(Pronounced hen' zcn)
Benzene is a colorless liquid with a sweet odor. It is
(\\so called bcnzo!.
·Benzene gets into the environment from human and
natural ac1ivi1ics. Natural sources like volcanoes and
forest fires release small amounts of benzene to the
environment. Benzene is also found in crude oil ,:rnd
gasoline. The main release of benzene to the environment
comes from the use of oil and gasoline, and its use as a
1najor industrial chemical.
Industry uses benzene to make chemicals for
styrofoam, plastics, resins, nylon, and synthetic fibers. It
is also used to make some types of ruhber, lubricants,
dyes, detergents, drugs. and pesticides.
Whal happens to benzene when it enters the
environment·?
0 As a vapor. benzene mixes with air very quickly.
0 ll reacts with other chemicals in the air. and breaks
clown within a few days.
0 In liquid form, benzene mixes easily in water.
0 Benzene in water changes quickly into a vapor, and
got.:s into the air.
0 It breaks down more slowly in water than in air.
0 It can move from soil to groundwater.
0 Plants·and animals do not store high levels of it.
How might I he exposed to henzenc?
0 The most common exposure is from brea1hing
benzene in air.
0 Tobacco smoke is 1hc source of about 50 percent of
most people's total exposure.
fJ Auto exhaust and industrial emissions arc the source
of about 20 percent of most people's total exposure.
0 Highest levels in air may be found in the.workplace
(rubber industry, oil refineries, chemical plants, shoe
manufacturing, gasoline storage, shipment and retail).
0 Glues, paints, furniture wax; and detergents arc
common sources.
0 Breathing vapors from contaminated water or soil.
How Gill benzene affect my health?
Benzene is harmful, especially to the tissues that form
blood cells.
Brief exposures 9f 5-10 minutes to benzene in air at
very high levels (500.000 times the average levels) can
cause clcath.
High levels (50,000 times the average !CVcls) can
cause drowsiness, dizziness, rapid heart rate, ·headaches,
tremors, q)llfusion, and unconsciousness. In most cases,
Page 2 • • BENZENE
. Agency for Toxic Substances and Disease Registry. :·· · · ·._ · · ·· ::-· · · ' · April 1993 · ., •• • , • r , ' • , ..
these effects will stop once exposure ends and you begin
to breathe fresh air.
Breathing lower levels for long periods may damage
blood cells and bone marrow. This can cause anemia or
excessive bleeding or cancer of the white blood cells
(leukemia). Benzene may also harm the immune system
and increase the chance for infection.
Eating or drinking high levels of benzene can cause:
0 Vomiting or irritation of the stomach
0 Dizziness, sleepiness, or convulsions
0 Rapid heart rate, coma, and death.
The health effects from eating or drinking foods with
low levels of benzene are not known.
Direct contact with the skin may cause redness and
sores. Benzene may irritate and damage your eyes.
Animal studies indicatC that benzene may damage
genes and may affect the ability to have healthy children.
How likely is benzene to cause cancer?
The Department of Health and Human Services
(DHHS) has determined that benzene is a known human
carcinogen. Benzene is associated with leukemia, a
cancer of the blood•forming tissues.
ls there a medical test to show whether I've
heen exposed to benzene?
Tests can measure the amount of benzene in breath and
blood. Most tests must be done soon aflcr the exposure
because benzene docs not stay in the body for a long time.
The blood test is accurate only for recent exposures. The
b;cath test is not useful for very low levels of exposure.
Your body converts benzene to other c9mpounds,
including phenol, which can also be measured in urine.
These tests can't tell how much benzene you were
exposed to or the possible health effects.
These tc.s1s may be available at your doctor's office.
' \Vhcrc can I get more information'/
Has the federal government made
recommendations to protect human health?
The Environmental Protection Agency (EPA) sets a
maximum permissible level of benzene in drinking water
at 5 parts of benzene per billion parts of water (5 ppb) per
day for a lifetime of exposure. EPA sets a goal of 0 ppb
benzene in drinking water and in rivers and lakes. The
maximum permissible level of benzene in water for short-
tenn exposures (IO days) for children is 235 ppb.
EPA requires that the National Response Center be
notified of a discharge or spill into the environment of
1,000 pounds or more of benzene.
The Occupational Safety and Health
Administration (OSHA) sets an occupational exposure
limit of I part per million (ppm) in air for an 8-hour
workday, 40-hour workweek.
Glossary
Carcinogen: Substance that can cause cancer.
Leukemia: A cancer of the blood-forming tissues.
PPB: Pans per billion.
PPM: Parts per million.
References
Agency for Toxic Substances and Disease Registry
(ATSDR). 1993. Toxicological profile for benzene.
Atlanta: U.S. Department of Health and Human Services,
Public Health Service.
Agency for Toxic Substances and Disease Registry
(ATSDR). 1993. Case· studies in environmental medicine:
Benzene toxicity. Atlanta: U.S. Department of Health and
Human Ser\'ices, Public Health Service.
ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your commur~ity or state health or environmental quality department if you have any morC questions or concerns. For more infr!nnation, contact: Agency for Toxic Substances and Disease Registry, Division of Toxicology, 1600 Clifton Road NE, Mailitop E-29. Atlanta, GA 30333, Phone: [phone].
l ' . ' ' . . I \ . ' . I "\ /, ~;. . t J' ) ' , , ' • '. ) · '.\· '., 1\, · ', Fcd~ral Recycilng Program.·. • ) · Prinicd on·Recycleci"Piper. \. ·, . . /, // , .., " • ' l ," j I I j, H • ' • \' .,.. ! / .._,\ -~ I ' 'l ' ' ' • C •• ' '• ' ' • •/ • ' \ <
• •
SUPERFUND PROCESS.
ENFORCEMENT ACTIVITIES ·----------i
1
llflE
DISCOVERY
1
LONG-T~M
CLEANUP
COMMUNITY RELATIONS
IN 1980, CONGRESS ENACTED THE COMPREHENSIVE
ENVIRONMENTAL REPONSE, COMPENSATION, mo LIABILITY ACT
(CERCLA), THIS ACT CREATED A TRUST FUND, KNOWN AS
-SUPERFUND", TO INVESTIGATE AND CLEm UP ABmDONED OR
UNCONTROLLED HAZARDOUS WASTE SITES, MODIFIED IN 1986
BY THE SUPERFUND AMENDMENTS AND REAUTHORIZATION
ACT(SARA), THE ACT AUTHORIZES EPA TO RESPOND TO
RELEASES OR THREATENED RELEASES OF HAZARDOUS
SUBSTANCES THAT MAY ENDANGER PUBLIC HEALTH OR
WELFARE, OR THE ENVIRONMENT.
THE 1982 SUPERFUND NATIONAL OIL AND HAZARDOUS
SUBSTANCES CONTINGENCY PLAN (NCP), REVISED IN 1988,
DESCRIBES HOW EPA WILL RESPOND TO MEET THESE
MANDATES. THIS EXHIBIT PROVIDES A SIMPLIFIED EXPLANATION
OF HOW A LONG-TERM SUPERFUND RESPONSE WORKS,
1. AFTER A SITE IS DISCOVERED, IT IS INVEST.IGATED, USUALLY BY
THE STATE.
2. THE EPA OR ITS REPRESENTATIVE THEN RANKS THE SITE
USING THE HAZARD RANKING SYSTEM (HRS), WHICH TAKES INTO
ACCOUNT:
-POSSIBLE HEAL TH RISKS TO THE HUMAN POPULATION
-POTENTIAL HAZARDS (E.G .. FROM DIRECT CONTACT,
INHALATION, FIRE, OR EXPLOSION) OF SUBSTANCES AT
THE SITE
-POTENTIAL FOR THE SUBSTANCES AT THE SITE TO
CONTAMINATE DRINKING WATER SUPPLIES
-POTENTIAL FOR THE SUBSTANCES AT THE SITE TO POLLUTE
OR OTHERWISE HARM THE ENVIRONMENT.
IF THE PROBLEMS AT A SITE ARE DEEMED SERIOUS BY THE
ST ATE ANO THE EPA, THE SITE WILL BE LISTED ON THE NATIONAL .
PRIORITIES LIST (NPL), A ROSTER OF THE NATION'S HAZARDOUS
WASTE SITES WHICH AR£ ELIGIBLE FOR FEDERAL SUPERFUNO
MONEY.
IF A SITE OR ANY PORTION THEREOF POSES AN IMMINENT THREAT
TO PUBLIC HEAL TH OR THE ENVIRONMENIT AT ANY TIME, EPA MAY
CONDUCT AN EMERGENCY RESPONSE REFERRED TO AS AN
IMMEDIATE REMOVAL ACTION, .
3. NEXT. EPA USUALLY CONDUCTS A REMEDIAL INVESTIGATION
(Al). THE RI AS.SESSES HOW SERIOUS THE CONTAMINATION IS,
WHAT KIND OF CONTAMINANTS ARE PRESENT, ANO
, \ CHARACTERIZES POTENITIAL RISKS TO THE COMMUNITY. AS
. PART OF THE RI, EPA TYPICALLY CONDUCTS m ENDmGERMENT
ASSESSMENT THAT DESCRIBES THE PROBLEMS AT THE SITE
AND THE POTENTIAL HEALTH AND ENVIRONMENTAL ..
CONSEQUENCES IF NC FURTHER ACTION IS TAKEN AT THE SITE.
4. FOLLOWING COMPLETION OF THE RI, EPA PERFORMS A
FEASIBILITY STUDY (FS) WHICH EXAMINES VARIOUS CLEANUP
ALTERNATIVES AND EVALUATES THEM ON THE BASIS OF
TECHNICAL FEASIBILITY, PUBLIC HEALTH EFFECTS,
ENVIRONMENTAL IMPACTS, INSTITUTIONAL CONCERNS
(INCLUDING COMPLIANCE WITH STATE AND LOCAL LAWS),
IMPACT ON THE COMMUNITY, mo COST. THE FINDINGS ARE
PRESENTED IN A DRAFT FS REPORT. .
5. FOLLOWING COMPLETION OF THE DRAFT FS REPORT, EPA
HOLDS A PUBLIC COMMENT PERIOD TO RECEIVE CITIZEN INPUT
CONCERNING THE RECOMMENDED ALTERNATIVES. CITIZENS
MAY PROVIDE COMMENTS EITHER ORALLY AT THE PUBLIC
MEETING OR THROUGH WRITTEN CORRESPONDENCE TO EPA.
6. AFTER PUBLIC COMMENTS HAVE BEEN RECEIVED, EPA
RESPONDS TO THE COMMENTS IN THE RESPONSIVENESS
SUMMARY PART OF THE RECORD OF DECISION (ROD) WHICH.
· IDENTIFIES THE SPECIFIC CLEANUP PLAN.
7, ONCE THE DESIGN IS FINISHED, THE ACTUAL REMEDIAL
ACTIVITIES OR CLEANUP OF THE SITE CAN BEGIN.
THE TIME NECESSARY TO COMPLETE EACH OF THESE STEPS
VARIES WITH EVERY SITE. IN GENERAL, m RVFS TAKES FROM
ONE TO TWO YEARS. DESIGNING THE CLEANUP PLAN MAY TAKE
SIX MONTHS mo IMPLEMENTING THE REMEDY -THE ACTUAL
CONTAINMENT CR REMOVAL OF THE WASTE· MAY TAKE FROM
ONE TO THREE YEARS. IF GROUNDWATER IS INVOLVED, THE
FINAL CLEANUP MAY TA.KE MANY MORE YEARS.
COMMUNITY RELATIONS ACTIVITIES DURING A CLEANUP
INCLUDE PUBLIC MEETINGS AND OTHER ACTIVITIES INTENDED
TO KEEP CITIZENS AND OFFICIALS INFORMED AND TO
ENCOURAGE PUBLIC INPUT. THESE ACTIVITIES ARE
SCHEDULED THROUGHOUT THE SUPERFUNO PROCESS.
SPECIFIC ACTIVITIES VARY FROM SITE TO SITE DEPENDING ON
THE LEVEL OF INTEREST mo NATURE OF CONCERN. THE
RmGE OF COMMUNITY RELATIONS ACTIVITIES THAT CAN
OCCUR IS DESCRIBED IN THE EPA'S COMMUNITY RELATIONS
PLAN FOR THE SITE.
ALL DOCUMENTS RELATING TO THE SITE ARE AVAILABLE FOR
PUBLIC REVIEW ANO COPYING IN THE DESIGNATED
INFORMATION REPOSITORIES.
•
December 7, 1994
To: File
From: Jack Butler
Subject: Potter's Septic Tanlc Service Pitts, NCD98 I 023260
Old Mt. Holly Road PCE Site, NCD986 ! 725 l 8
•
Ms. Diane Barrett, EPA Region IV contacted our office on this date to update us on the
subject sites. Ms. Barrett reported that a contract has been awarded to McLauren and Hart from
Philadelphia to perform the remedial design for the thermal desorption process. Ms. Barrett also
reported that the Self Directed Work Group had made a decision to do no action at the Old Mt.
Holly Road PCE Site (Paw Creek Site) due to the petroleum exclusion under Superfund. Ms.
Barrett also requested a copy of the Paw Creek Pact Report that she said N.C. DEHNR,
Mecklenburg County, and eleven petroleum companies had agreed to prepare.
State of Nort&rolina Department of Environment, Health and Natural Resources
Division of Solid Waste Management :qA
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director September
Ms. Beverly Hudson
US EPA Region IV
North Superfund Remedial Branch 345 Courtland Street, NE
Atlanta, Georgia 30365
DEHNA.
16, 1994
RE: NC DEM Comments on Draft Final Performance Based Design Source and Groundwater Remediation
Potter's Septic Tank Service Pits superfund Site Sandy Creek, Brunswick County, NC NCO 981 023 260
Dear Ms. Hudson:
The Draft Final Performance Based Design for the Potter's Septic Tank Service Pits Site for source and Groundwater Remediation, located in Sandy Creek, North Carolina has been received and reviewed by the North Carolina Division of Environmental Management. The NC Sup~rfund Section received their comments on September 15, 1994. These comments are being forwarded as an attachment to this letter for your review. Please respond to the NC Superfund Section in reference to these comments.
If you have any questions or comments, please do not hesitate to contact us at [phone].
Sincerely,
0{}.~_{r1tL\
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone] An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
• Branch at the following address-
Ms. Laura S. Butler, P.E.
Assistant Chief
Air Quality Section
N.C. Division of Environmental Management
P. 0. Box 29535
Raleigh, NC 27626-0535
Water Quality Section
•
On page 42 of the subject document, the 1989 Wetland Delineation Manual was referenced as the document used in delineate wetlands. The North Carolina Corps of Engineers offices and NC DEM use the 1987 Wetland Delineation Manual for wetland delineation. The 1989 Manual should be replaced by the 1987 Manual where it is referenced in the subject document.
Groundwater Section
The Groundwater Section agrees that additional data should be collected pertammg to lower aquifer characteristics so that effective remedial design can include the lower aquifer.
The goals for soil and groundwater remediation were stated in the subject report. It was noted that the remediation goals for some qfthe groundwater constituents were in excess of 15A NCAC 2L standards. Specifically, the remediation goals fqr benzene and naphthalene were lisied as 5.0 ppb and 30.0 ppb respectively. The 15A NCAC 2L standard for benzene is currently 1.0 ppb and the interim standard for naphthalene has been set at 21.0 ppb. Remediation goals for groundwater contaminants at the site should be no greater than 15A NCAC 2L standards allow.
In summary, groundwater should have contamination concentrations remediated to state acceptable levels where those levels are more stringent" than contamination action levels required by the Federal government.
If there are any questions, please advise.
APHjr/sbp/94-28.doc
cc: Alan Klimek
Steve Tedder
Wilmington Regional Office
Central Files
Groundwater Section Files
• State of North ~olina Department otWvironment, Health and Natural Resources
Division of Environmental Management
James 8. Hunt, Jr., Governor
Jonathan 8. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
August 23, 1994
MEMORANDUM
TO: · Randy McE!veen
Superfund Section
FROM: ;Jn Preston Howard~°'--t::--b-:;i}j-
SUBJECT: Potter's Septic Tank Service
Draft Final Performance Design
Brunswick County
Project No. 94-28
SEP l 5 1994
I
. suPEf~:·;uND -SECY1,0?1.1 / ··--------··-·-·~~]
The Division of Environmental Management has completed the review of the subject · document and offers the following comments and recommendations.
Air Quality Section
The volatilized contaminants are treated through a carbon adsorption system before the air is released into the atmosphere, therefore, an AIR PERMlT IS REQUIRED. Carbon adsorption systems are air-control devices which must be permitted in accordance with NCGS 143-215.108., "Control of sources of air pollution; permits required".
North Carolina Administrative Code, Title 15A, Subchapter 2Q. 15A NCAC 2Q .0I0l(a)(3) reads, in part, that no owner or operator shall.. (without first applying for and · obtaining an air quality permit) .. Enter into an irrevocable contract for the construction, operation or modification of an air-cleaning device. Section 4.0 WORK PLAN, 4.1 PROJECT SCHEDULE and 4.2.11 Regulatory Compliance Plan indicate a schedule for procurement of equipment and subcontracts for services (page 51 of REPORT) and states that "the contractor shall be responsible for obtaining all necessary permits, approvals, licenses, and consents related to excavation, construction, and operation and maintenance of the treatment systems." (page 55 of the REPORT). This seems to provide at least the opportunity for the contractor to obtain an AIR PERMIT prior to entering into an irrevocable contract for the construction, operation or modification of an air-cleaning device.
Please contact the AIR PERMITS BRANCH in Raleigh if there are questions concerning the need to obtain an air permit for this project (919-733-3340) or write to the Permits
P.O. Box 29535. Raleigh. North Carolina 2762&-0535 Telephone [phone] FAX [phone] An Equal Opportunity Affirmative Action Employer 50% recycled/ l ITT:. post-consumer paper
• •
Ms. Beverly Hudson
US EPA Region IV
September 16, 1994
North Superfund Remedial Branch
345 Courtland street, NE
Atlanta, Georgia 30365
•
RE: NC DEM Comments on Draft Final Performance Based Design
Source and Groundwater Remediation
Potter's Septic Tank Service Pits Superfund site
Sandy Creek, Brunswick County, NC
NCD 981 023 260
Dear Ms. Hudson:
The Draft Final Performance Based Design for the Potter's
Septic Tank Service Pits site for Source and Groundwater
Remediation, located in Sandy Creek, North Carolina has been
received and reviewed by the North Carolina Division of
Environmental Management. The NC Superfund Section received
their comments on September 15, 1994. These comments are being
forwarded as an attachment to this letter for your review.
Please respond to the NC Superfund Section in reference to these
c.omments.
If you have any questions or comments, please do not
hesitate to contact us at [phone].
Sincerely,
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
,, ' · · ..,~-State of North ~lino
Department of Environment,
Health and Natural Resources
Division of Environmental Management NA James B, Hunt, Jr., Governor DEHNR Jonathan B, Howes, Secretary
A Preston Howard, Jr., P,E., Director
August 23, 1994
RECE~VED
SEP I 5 1994
MEMORANDUM SUPERFUND SECTION
TO: Randy McElveen
Superfund Section
FROM: <f&,
SUBJECT:
Preston Howard ~ "'----
Potter's Septic Tank Service
Draft Final Performance Design
Brunswick County
Project No. 94-28
The Division of Environmental Management has completed the review of the subject
document and offers the following comments and recommendations.
Air Quality Section
The volatilized contaminants are treated through a carbon adsorption system before the air
is released into the atmosphere, therefore, an AIR PERMIT IS REQUIRED. Carbon
adsorption systems are air-control devices which must be permitted in accordance with
NCGS 143-215.108., "Control of sources of air pollution; permits required".
North Carolina Administrative Code, Title 15A, Subchapter 2Q. 15A NCAC 2Q
.0I0l(a)(3) reads, in part, that no owner or operator shall .. (without first applying for and
obtaining an air quality permit) .. Enter into an irrevocable contract for the construction,
operation or modification of an air-cleaning device. Section 4.0 WORK PLAN, 4.1
PROJECT SCHEDULE and 4.2.11 Regulatory Compliance Plan indicate a schedule
for procurement ·of equipment and subcontracts for services (page 51 of REPORT) and
states that "the contractor shall be responsible for obtaining all necessary permits,
approvals, licenses, and consents related to excavation, construction, and operation and
maintenance of the treatment systems." (page 5 5 of the REPORT). This seems to provide
at least the opportunity for the contractor to obtain an AIR PERMIT prior to entering into
an irrevocable contract for the construction, operation or modification of an air-cleaning
device.
Please contact the AIR PERMITS BRANCH in Raleigh if there are questions concerning
the need to obtain an air permit for this project (919-733-3340) or write to the Permits
P.O. Box 29535, Raleigh. North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
•
Branch at the following address-
Ms. Laura S. Butler, P.E.
Assistant Chief
Air Quality Section
N.C. Division of Environmental Management
P. 0. Box 29535
Raleigh, NC 27626-0535
Water Quality Section
•
On page 42 of the subject document, the 1989 Wetland Delineation Manual was referenced
as the document used in delineate wetlands. The North Carolina Corps of Engineers
offices and NC DEM use the 1987 Wetland Delineation Manual for wetland delineation.
The 1989 Manual should be replaced by the 1987 Manual where it is referenced in the
subject document.
Groundwater Section
The Groundwater Section agrees that additional data should be collected pertaining to
lower aquifer characteristics so that effective remedial design can include the lower aquifer.
The goals for soil and groundwater remediation were stated in the subject report. It was
noted that the remediation goals for some of the groundwater constituents were in excess of
15A NCAC 2L standards. Specifically, the remediation goals for benzene and naphthalene
were listed as 5.0 ppb and 30.0 ppb respectively. The 15A NCAC 2L standard for benzene
is currently 1.0 ppb and the interim standard for naphthalene has been set at 21.0 ppb.
Remediation goals for groundwater contaminants at the site should be no greater than 15A
NCAC 2L standards allow.
In summary, groundwater should have contamination concentrations remediated to state
acceptable levels where those levels are more stringent than contamination action levels
required by the Federal government.
If there are any questions, please advise.
APHjr/sbp/94-28.doc
cc: Alan Klimek
Steve Tedder
Wilmington Regional Office
Central Files
Groundwater Section Files
State of North Arollna
Department o~vironment,
Health and Natural Resources
Division of Environmental Management
.!, J; ;
Jam.es B. Hunt,•Jr .. Governor
Jonathan B. Howes, Se<::retary
A Preston Howard, Jr., P.E.: Director
Gordon D. McDonald
Director of Business Development
Sevenson Environmental Services
4 Lakeview Drive
P.O. Box 1308
Chadds Ford, PA 19317
Dear Mr. McDonald,
September 8, 1994
Air Quality Section
... ' • : j
Rf_'Fc"t ,-7)''
SEP 1 4 1994
SUPERFUND secnoN
.,.
This letter is in response to concerns raised during our September 9th meeting regarding North Carolina air quality permitting requirements and · ihe soil remediation :project at the ,Potters"Pitt sul'!effuncl]ite,in Sandy Creek, North Carolina. Based on your comments, the "Record of Decision" (ROD) established for this site specific equipment to be used for the remediation process. The specified equipment consisted of a thermal desorption unit (with a maximum allowable temperature of 800°F) followed by a bagfilter, condensor, and finally two-bed carbon adsorption unit. As we discussed, this Section can issue an air permit for this system provided the unit can meet the applicable requirements under the North Carolina air quality regulations.
If a permit is issued for this soil remediation process utilizing the above mentioned control devices, the permit will contain reporting, monitoring, and recordkeeping necessary t.o demonstrate compliance. The stringency of these permit conditions would be based the State's engineering review and the expected level of performance for these control devices under the specific conditions at Potter's Pitt.
Another potential option for control of emissions from the remediation process consists of a thermal desorption unit, followed by a high temperature baghouse, and finally a thermal oxidizer. This control system can also be permitted provided all North Carolina air quality regulations are met. However, based on a cursory discussion of these technologies, the second option (with thermal oxidizer) would appear to be more reliable and efficient over a long term period.
,
P.O. Box 29535. Raleigh. North Ccrolina 2762&-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post~consumer paper
•
The choice of which technology to employ is left to the applicant and both options can be
permitted provided they show compliance with the North Carolina air quality regulations. If
you have any further questions regarding this matter please call me or John C. Evans of my
staff in Raleigh at [phone].
.,,~i~~ ~/--
ona{d R. van derVaart, Ph.D., P.E.
Supervisor
. '
• '
c: Randy McElveen -Superfund (401 Oberlin)/
I
Kirk Shellum
Advanced Soil Technologies
4 7 50 Churchill Street
S11ite 3000 : · . .
., St. Paul, Minnesota 55qfj-2222,-t ,.
.' i .
,,
'• j~ I
' ' ' '
r
.J: '·
....
' .. ,JII . .
.. ,.
' .
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'I
'.
.... • ' . d
.,
MEMORANDUM
TO:
From:
RE:
•
September 7, 1994
File
Randy McElveen
Environmental Engineer
NC Superfund Section
RD •
Meeting with Bid Contractor to Evaluate Air Permitting
Archdale Building, DEM/Air Quality Section
Potter's Septic Tank Service Pits
NCD 981 023 260
On 7 September 1994, a representative of the NC Superfund
Section participated in a meeting with bid contractors to discuss
the Air Permitting requirements for off-gases from thermal
desorption of soils at the Potter's Pits NPL Site located in
Sandy Creek, Brunswick County, North Carolina. The meeting was
held in the conference room of the DEM/Air Quality Section in
Raleigh, NC. Attendance included Donald van der Vaart, and John
Evans with DEM/Air Quality Section, Gordon McDonald with Sevenson
Environmental Services, Inc. and Kirk Shellum with Advance Soil
Technologies and Randy McElveen, NC Superfund Section.
The primary purpose of the meeting was to determine what the
Air Quality Permitting requirements, for the off-gases of the
thermal desorption system, are for North Carolina given the
contaminants of concern at the Potter's Pits NPL Site. Inter-
department notification for Air Quality Permitting of NPL sites
has not been established at this time. Therefore it is the
Superfund Sections objective to begin establishing this procedure
especially where only the requirements of the permit must be met.
DEM/Air Quality agrees with the contractor that the Record
of Decision (ROD) off-gas treatment process (Carbon adsorption)
is not financially appropriate for the thermal desorption remedy
and may not achieve the clean-up standards for the soils. There
is also agreement that thermal oxidation of off-gases is more
appropriate for the thermal desorption system and will be more
effective and economical and can be permitted by NC with some
stipulations. A letter to this effect, for the contractor's use,
will be copied to the Superfund Section by DEM/Air Quality
Section.
cc: Jack Butler, NC Superfund Section
State of North.rolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
Jomes B. Hunt, Jr., Governor
Jonathon B. Howes. Secretory
William L. Meyer, Director
May 17, 1994
Ms. Beverly Hudson
US EPA Region IV
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Comments on Draft Final Performance Based Design
Source and Groundwater Remediation
Potter's Septic Tank Service Pits Superfund Site
Sandy Creek, Brunswick County, NC
NCD 981 023 260
Dear Ms. Hudson:
The Draft Final Performance Based Design for the Potter's
Septic Tank Service Pits Site for Source and Groundwater
Remediation, located in Sandy Creek, North Carolina has been
received and reviewed by the North Carolina Superfund Section.
This document has also been forwarded to the NC DEM for concurrent
review. Their comments will be forwarded when available. The
following comments are offered by the North Carolina Superfund
Section.
1. As we discussed the Groundwater clean-up goal for Benzene
is 1 ppb rather than the 5 ppb noted in Table 1-1 on page
2 and throughout the report. It is our understanding
that this will be changed in the revised Final Report and
that an Explanation of Significant Difference (ESD) is in
the process of completion that will document this change
in the Record of Decision (ROD).
2. NCAC Title 15A Chapter 2, Subchapter 2H should be
included under the North Carolina Water and Air Resources
Act listed in Section 2.2 on page 12. This NC Regulation
establishes treatability study or demonstration phase
requirements and toxic air pollutant limits for sources.
3.
The ''A" is missing in ''Title 15A" of the NC Water and Air
Resources Act Standards.
Their are contradictory Figure numbers in the title
blocks throughout Section 3. Please remove the Figure
numbers from the title blocks or make the appropriate
corrections.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX 919-71 S-3605
An l:qual Opportunity Affirmotiv8 Action Employer 50% recycled/ l 0% posl-consumor paper
Ms. Hudson
5-17-94
Page 2
• •
4. The last paragraph on page 18 states that 11 soil borings
were drilled and sampled for chemical analysis and 6
wells were drilled and constructed for aquifer testing.
However, the lab data sheets ·for the various soil and
groundwater analysis performed and well construction data
are not provided in the report. Please provide lab data
and well construction information for review by the State
as soon as possible and include this information in the
revised Final report.
5. Please provide the temperature scale for the low
temperature the:r;mal desorption as noted in Section 3. 9. 1.
6. Perimeter monitoring systems are required by 15A NCAC 2D
.0600, 15A NCAC 2D .0500 and 15A NCAC 2H .0600.
Therefore, the second sentence of the first paragraph
should be deleted. "If required" should also be deleted
from the last paragraph. Please clarify the type of
monitoring equipment which will be used for perimeter
monitoring and state clearly that perimeter air
monitoring will be in-place and operational prior to
significant site traffic or operations of thermal systems
of any kind including those used for the demonstration
phase. The State Division of Environmental Management
(DEM) would prefer and may require that high volume
perimeter monitoring devices be used for this purpose.
Details of the perimeter monitoring system must be worked
out with the DEM during the Remedial Design.
Clarification as noted above would minimize untimely
delays.
7. TCLP testing of one grab sample per 500 yd3 of stabilized
product is not a suitable representative sample. The
State recommends that a composite sample for each
stockpile be taken proportionally from alternating
batches of stabilized product to represent each
stockpile.
8. Well 10 SPT 1 is not depicted or properly labeled on
drawing number 022-C-001. Please make this correction.
Ms. Hudson
5-17-94
Page 3
• •
The State of North Carolina appreciates the opportunity to_
comment on the Draft Final Performance Based Design for the subject
site, and we look forward to working with EPA on the project. If
you have any questions or comments, please do not hesitate to
contact us at [phone]
Sincerely,n~
'IA \ ; I
\_ /V' \' l'l ' ' ,j~
Ran£ UcE'i een
Environmental Engineering
Superfund Section
cc: Jack Butler, NC Superfund Section
TO:
FROM:
RE:
April 10, 1994
Arthur Mouberry, Chief
Groundwater Section
•
Division of Environmental Management (DEM}
Randy McElveen
Environmental Engineer
NC Superfund Section
Draft Final Performance Based Design
Potter's Septic Tank Service Pits NPL Site
NCD 981 023 260
Sandy Creek, Brunswick County, North Carolina
EPA is in the process of completing a Final Performance Based
Design for the Potter's Septic Tank Service Pits Superfund site, a
National Priority List site.
Attached is one copy of the Draft Final Performance Based
tDEis·i:gn-Reffor;t for the subject site. This report was prepared by
Bechtel Environmental, Inc. for the us EPA, Region IV. It is
requested that these documents be forwarded· to the appropriate
sections of DEM and comments be submitted to the NC Superfund
Section. The NC Superfund Section will be reviewing this document
and submitting comments to EPA Region IV on or before May 13, 1994.
It is our desire·to include the views and permitting requirements
of the Air Quality, Groundwater, and Water Quality Sections of DEM.
If you or your staff have any questions, please do not
hesitate to call us at [phone].
Attachment
cc/ Jack Butler, NC Superfund Section
)
• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
April 4, 1994
4WD-NSRB
Mr. Randy McElveen
North Carolina Department of Environment Health, and Natural Resources 401 Oberlin Road
Raleigh, North Carolina 27605
~ ';.\PR 7 1994 /;
SUBJ: Review of Fin~l Performance Based Design Potter's Septic Tank Service Pits Superfund Site
Dear Mr. McElveen:
Enclosed is·~~erformance bas d design fr the Source and Groundwater ~n at the Potte Septi Tank Service Pits Superfund Site located in Wilmington, Nort Carolina. Please review the report and provide comments to me by April 20, 1994. If you are unable to meet this timeframe, please inform me as to when you will be able to get your comments to me. Thank you for your cooperation.
If you have any questions regarding this site, please contact me at [phone].
Enclosure
Sincerely,
§,t•,·'{/~J ~½~
Beverlt}T. Hudson
Remedial Project Manager
Waste Management Division
cc: William Meyers, NCDEHNR (w/o enclosure) Micheal A. Kelly, NCDEHNR (w/o enclosure)
• COPY
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Covemor
Ms. Beverly Hudson
· Division of Solid Waste M anagcment
. Telephone 919 • 733-2801
October 19, 1993
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Comments on Preliminary (30%) Design
for Source and Groundwater Remediation
at the Potter's Septic Tank Service Pits
Located in Sandy Creek, Brunswick County, NC
NCD 981 023 260.
Dear Ms. Hudson:
Jonathan B. Howes, Secreta1y
The Preliminary (30%) Remedial Design. for Source and
Groundwater at the Potter's Septic Tank Service Pits located in
Sandy Creek, North Carolina has been received and reviewed by the
North Carolina Superfund Section. This document has also been
forwarded to the North Carolina Division of Environmental
Management (NC DEM) for concurrent review. Their comments will be
forwarded when available. The following comments are offered by
the North Carolina Superfund Section.
1. ·The Groundwater Remediation Goal for Benzene should be 1
PPB (UG/L) rather than 5 PPB (UG/L) as noted in Table 1-
1. The NCAC Groundwater Quality Standard for Benzene has
been 1 PPB since before December of 1989 and should be
the ARAR for Benzene.
2. The dimensions of the scale noted on Figure 1 are not
indicated.
3. Volatile and Semi-volatile are misspelled in the last
paragraph on page 18.
4. The soil boring numbers and legends on Figures 6 through
11 are not legible.
5. Section 4.4 Source Remediation, states that air sampling
and analysis shall be conducted daily. Air monitoring
must also include a perimeter monitoring system in place
P.O. _?ox 27687, R.al~igh, North C1roli11a 27611-7687 · lCkphone 919-733-~98-; Fax I! 9!9-733-0513
An Equal Opportunity Affirmative Actiun l:mployl.'r
Ms. Hudson
10-19-93
Page 2
• \ •
prior to start-up of source remediation and operated
continuously during all site activities. This monitoring
requirement is in accordance with:
-15A NCAC 2H. 0610 which establishes toxic air
pollutant limits for sources
15A. NCAC 2D.0500 this section (specifically
.0515) establishes particulate emission limits. ·
-15A NCAC 2D.1100 this section establishes the
· ambient (beyond property boundary) toxic air
pollutant limits for various compounds.
6. A sentence structure problem exists under the Fermi t
Requirements heading on page 5.0.
7. The sixth bullet on page 58 and the seventh bullet on
page 65 indicates that the groundwater remediation goals
are located in Sec:tion 3. 7. Groundwater remediation
goals are not listed in Section 3.7.
8. The automatic process ·control s·oftware testing performed
by comparing software monitoring results with laboratory
analytical results should be overviewed by EPA and the
State. The automatic process control is included as
bullet 5 on page 66.
If you have any questions or comments, please do not hesitate
to contact us at [phone].
Sincerely,
,)J. ~ .Arif\ \11 .
Randy Mc~~
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
• •
State of North Carolina
Department of Environment/ Health, .and Natural Resources ' . '• . . '.
· ., 512'North Salisbury Street • Raleigh, North Carolina77604
James B. Hunt, Jr., Governor · •Division of Solid Waste Management:
· · . TelePhone [phone] · · " :, Jonathan. B H·owes, ~cretary . . . . •. ·. .. .
TO:
FROM:
RE:
October 19, 1993
·Arthur Mouberry, Chief
Groundwater Section
Division of Environmental Management (DEM)
Randy McElveen
Environmental Engineer
NC Superfund Section
Preliminary (30%) Design
for Source and Groundwater Remediation
at the Potter's Septic Tank Service Pits
Located in Sandy Creek, Brunswick County, NC
EPA is in the process of completing a Preliminary (30%)
Remedial Design for the Potter's Septic Tank Service Pits Superfund
Site, a National Priority List site.
Attached is one copy of the Preliminary ( 3 0%') Remedial Design
Report for the subject site. This report was prepared by Bechtel
Corporation for the US EPA, Region IV. It is requested that these
documents be forwarded to the appropriate sections of DEM and
comments be submitted to the NC Superfund Section. The NC
Superfund Section will be reviewing this document and submitting
comments to EPA Region IV on October 19, 1993. It is our desire to
include the views and permitting requirements of the Air Quality,
Groundwater, and Water Quality Sections of DEM during the design
period. We apologize for the timing. EPA has been notified that
the State requires two copies of all bound reports in the future.
If you or your staff have any questions, please do not
hesitate to call us at [phone].
Attachment
cc/ Jack Butler, NC Superfund Section
PO _l}ox 27687, Raleigh, North Carolina 2761!-7687 "!i:kphom: 919-733-4984 F;ix # 919-733-0513
An EqLkll Opponurii(y /\(firrnativc l\ctiun f:111ployci
_, . , , ,_.,, "", , ,_, ,,,H~ 1 ::c 1•11., I PF:OGRRl'IS 002 ..,__-,.---"""J..-:"1.c::-.' "3 .. J_t-j:J 10: 331'1 ! D: l:i:cCH1 EL NAT 101,AL 1 NC TEL NO: 1s-220-2rn0 112~0 Pll •
Oak RlttgB Corpo,wi. C,mr•i
161 Lofa~ffll Drlw,
P.O. l1~K3$0
Ook RI~. Tltrlntl-37831-0360
• I .
I
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D tobcr 7, 1993 · • F«lt/mll~: (61!SJ 220-2 rOO I.
I
· Bc:Ycrly Hu<bon
· • U.S. Environmental Protection Agency Roalon 1v· ·
345 Courtlilnd Streot, N .E., 4th Floor AUanUI, GA 30365
,.
i
i
'
, . ..:-~.,,j,:sJJW:BC:r: -----•1, cimtr•ct No. ' --~ o .• •· · -, . ~'fs~Jf.$ig~ ~~~a~hNPWATER coL~TED DURING T~:-·, AUGUST 1993 POTTER'S PITS RJ!:MEbl~L OESJGN JNVESTIG~TION
REFERENCES: l) Flel~--Operatlons Plan for the Potter's S*ptic Tank Service Pits Supjirful\d. Site, Brunswick County, North Carolina, Bet11nel E~\•.lronmental, lnc., /}pril 1993 2) Facsimile from Hudson to Mcconnel, quifer;Test Pesiin, May 17, 1993
Subject Code: ~
Dear Ms. Hudson:·
There ts approximately 1,10Ogallon5 of wale~. 3c:,ner11ted duri i the aquifer pump test In AUiUSt, 1993, 6t0red ln a container at the Job site. Disposal o this water ls required to allow completion of the subcontract with Oraham and Currie and reltase their storage container; The analytical results of this waier have been received and reviewe~ against the around water tjlean up aoals lined in Table 1-1 of Reference 1 (summarized In the auf ched table). Tile rcsu.11 from the lead analysis is 100 ppbO) which ls above the groundwater cleanup goats.· '.
We request that you define the dis.posal option that you and th state of North Carolina wish to pursue for th" stored water. Several possible options we have ,lelemlfled are: •
·.:}____untrooted--dl~Mio-to-Ghlnn~ I • Off site disposal i r---o Untmate<J, merered L\lscharge 10 Chhwls Dra11ch I •
! · •:· Untreated dlscharte to a POTW that you identify
1 -if< (~) On site treatment with discharge to Chinnis Branch or f POTW tluu you ldemlfy ~ 'Yt".~
I · PleBBe note that Che work asslgnmem budget wa~ based on the iflrst option of umreateel release to Chinnis Branch and rhat other options will result in a chaniie o''( scope. '
!
---'--'-<JCT-0?-,'~3 THU 1;;:33r·1 JD:BECHTEL NRT!ONAL INC TEL t;Q:6•5-220-2100 I • • Ms. Beverly Hudson
Ociobor 7, 1993
PB11e 2
• I
To allow us to provide a timely respon5e to the drilling subcon acror ,,your response ls requested by October 23, 1993. If you bave any questions, plewie conuict Jo cox at (61S) 220-Z:;23,,or me at [phone].
Enclosure
<:<:: Doug ThompJon
USS
Ooto~tt 7, IPPl (9.◄hln)
rely yours,
_L!,,,,l,W,/,lr__f2.___
B.~. Mc<;onnel
_Pro ect Manager
!
• Agulrer Test Water Review su.lary
I i :
Conc,c,~tratio-,., J?J?b '
eo,namlnant Analytical Result Cleanup Goal►
Benz.ene 2(J) ' Toluene < lO(U) 1,000
... ···-
Ethylbcn:zcne < lO(U) 29 .
Xylenos I--•-·--· < lO(U) 400
Naphihalene < lO(U) 30 ... ....... • ••• "• _,d_
_Chromtum .. ,, . <6(U) 50
.• ,.J. 'Lead . -.. ............. , lOO(J) lS ..
(U) undetected
(1) ostlmatOd v aluc
I '
I
:
'
' '
\
' i
L6SS
o.lO\>o17, 1991 (9:◄hm)
.. . • ~i •..
UNITED STATES ENVIRONMENTAL PRO[ECTION AGENCY
REGION IV
345 Courtland Street, N •. E.
Atlanta, Georgia 30365
. . I
FACSIMILE TRANSMITTAL COVrR S•HEET
COMPANY/ORGA
PHONE NUMBER: g / vf 133 -,} fo J FAX NUMBER: q/ o/ 7J J -f &JI/
NUMBER OF PAGES SENT (Including this cover sheet): i---. -t----
Please contact the person sending this fax If It Is re . lved poorly or Incomplete.
I :
__,I
FROM: --<...:..<:..----"-''""--'--+f---l-...;,,,....~:::,J!_7'::.__v ___ -+----------
RTH SUPERFUND REMEDIAL ~RAN'.CH
WASTE MANAGEMENT DIVISION :
I . Phone Numbers: (404) 347•TT91 or 800-435-9233
Fax Number: (404) 347-16 5
COMMENTS:
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
4WD-NSRB
September 23, 1993
Mr. Jack Butler
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
North Carolina Department of Environment
Health, and Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
RE: Review of Final Performance Based Design for Source and
Groundwater Remediation at the Potter's Septic Tank Service Pits
Superfund Site.
Dear Mr. Butler:
Enclosed is a preliminary (30%) design for Potter's Septic Tank
Service Pits Superfund Site located in Wilmington, North Carolina.
Please review the work plan submi:tted-on-September 22, 1993, and
provide comments to me by Octobe£"'7, 1993_,__, If you are unable to meet
this timeframe, please infbrm_n{e_as-towhen you will be able to get
your comment to me. Thank you 'for your cooperation.
If you have any questions regard/ng this site, please contact me at
[phone].
Bever! T. Hudson
Remedial Project Manager
Enclosure
cc: Randy Mcelveen
Printed on Recycled Paper
MEMORANDUM
TO:
FROM:
RE:
•
August 27, 1993
File
Randy McElveen
Environmental Engineer
NC Superfund
•
Potter's Pits Septic Tank Service NPL Site
Sandy Creek, Brunswick County, N.C.
Overview for Pre-Remedial Design Field Work
Arrived on site at 4:30 Pm and contacted Bechtel contractors
John Schoolfield and John Cox and reviewed the work that had been
completed. Went to the Newlon residence with Bechtel personnel to
request site access again for additional borings required at this
property. 4 additional borings were laid out to further evaluate
potential contamination in this area.
John Cox notified me that the property owner, Mr. Ronnie Gore,
of Pit area #la, across Joe Baldwin Dr. from Pit area# 1, had
contacted him and wanted to know when he could build a residence on
this property. We walked over the property and observed a 2 11 PVC
well and a concrete septic tank located on the property. Photos of
these areas were taken and will be included in the files.
The following day, I drove to the county seat, Bolivia, N.C.
during the morning and purchased a Tax map of the Potter's Pits
property and to review the property deed for recordation of
contamination or. any deed restrictions. The Potter's Pits property
has no deed recordation or restrictions relating to the Site
contamination or human health.
Arrived back on Site at 1:00 Am, the drillers arrived shortly
there after and decontaminated the augers and sampling equipment.
The drill rig was set-up to drill boring PP SS-34 at the Newlon
residence. 4 additional soil borings, PP SS-31A, PP SS-32, PP SS-
33, and PP SS-34, ·were performed at this property to a depth of 12
feet below ground surface. John Schoolfield with Bechtel performed
sample preparation, air monitoring and other QA/QC operation and
John ____ , a geologist also with Bechtel Corp., performed soil
classification and logging. Graham & Currie personnel performed
all the drilling operations and delivered the samples to the
Bechtel QA/QC person.
A pump test, with a data logger and pressure transducers at
the bottom of the 4" pump well and 6 other monitoring wells, had
been operating for approximately 24 hours. The data logger would
electronically log the head and change in head from each monitoring
•
Memo, Potter's Pit
8-26-93
Page 2
•
well at preprogrammed intervals. The small electric submersible
pump maintained a flow rate display which was manually recorded at
the same intervals as the data logger readings. Readings were also
taken from an in line water meter and the flow rate manually
calculated at the predetermined intervals. Groundwater was pumped
into a roll-off box lined with 2 layers of 10 mil plastic during
the test. Mr. John Cox the project manager for Bechtel stated that
the groundwater would be stored on site in the lined container and
tested for contamination prior to disposal. He also stated that,
if the water is not contaminated it would be pumped out onto the
ground of the Site. Photos of all work activities were taken at
this time and will be included in the files.
I departed from the site around 6:00 Pm to return to Raleigh.
MEMORANDUM
TO:
FROM.:
RE:
•
August 13, 1993
File
Randy McElveen
Environmental Engineer
NC Superfund
•
Potter's Pits Septic Tank Service NPL Site
Sandy Creek, Brunswick County, N.C.
Overview for Pre-Remedial Design Field Work
Arrived at the Potter's Pits Site around 11:30 Am August 11,
1993 and performed site and adjacent property reconnaissance of the
area in vehicle. Stopped at Pit area# 1 where Bechtel had set up
their office trailer and materials storage area and met 2 of the
Bechtel personnel, (EPA Contractor) John Cox and Bob Cook and 2
Graham and Currie drillers. We discussed their proposed schedule
which had been affected by heavy rainfall.
The Newlon residence (101 Hickory Drive) was located and Mrs.
Newlon was initially contacted by a State official to request
access to the property for drilling purposes, as previously
discussed with the EPA RPM Beverly Hudson. Performed a Site
walkover with Bechtel personnel. While at the office area Mr.
Granger, a local residence contacted John Cox and took John and I
to see stained soils in a recently excavated ditch in front of his
property. For details see the Memo to this file dated August 11,
1993. No drilling was performed on Wednesday due to heavy rain.
On the following day, August 12, 1993, the drillers prepared
their equipment and mobilized to the Newlon property to perform
drilling operations for soil sampling purposes. This site was
alleged to have been used as a sludge pit by local residence. The
drill rig was set-up to drill approximately 4 to 5 feet southeast
of existing well # 104. Drilling with continuous sampling was
performed from approximately 8:30 to 11:30 Am. The boring was
labeled PP SS-31 and was extended to a depth of 12 feet below
ground surface. Sample intervals were 2 1 and were performed with
a 3" O.D. split-barrel sampler. Blow counts were taken at 6"
intervals. Soil sample collection, labeling and storage was
performed by John Cox of Bechtel and logging and classification was
performed by Bob Cook also of Bechtel. 2 samples were taken at
each depth, 1 for VOC's and 1 for Metals analysis.
QA/QC for sampling and analysis was in accordance with EPA
protocol. All sampling equipment was decontaminated before
reusing. The borehole was grouted to the surface by pouring a bag
of dry cement into the open borehole and then pouring approximately
5 gallons of cement-bentonite grout to the surface of the borehole.
•
Memo Potter's Pits
8-13-93
Page 2
•
The drill rig was then set up to drill monitoring wells, and
a 411 pump well, located just down gradient of Pit area #1 in the
area of existing well MW-204. The first well was located 40 1 west
of existing well MW-204. QA/QC was again performed by Bechtel
personnel as noted above. The boring was extended to a depth of
7.5 feet and threaded PVC well casing and screen were installed as
directed by the project Geologist Bob Cook. Photographs of the
existing site conditions and all drilling operations were taken and
will be included in this file.
After the 4 11 Pump well and the.5 additional monitoring wells
are installed and developed, a 3 to 6 day pump test will be
performed to evaluate the aquifer. I departed from the Site at 4:30
Pm and returned to Raleigh.
• • ;..-.STAT£.,
!:~ ....... .-·"/'"'> ,.~ "r,,_ci:
l3 ~•r,£1t ~)
r.:~\tu lYwJi'c~' .. --..... -.. ~,
"'"' .. .,,,c',./ . -~
State of North Carolina
•
Department of Environment, Health, and Natural Resources
· 512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Division of Solid Waste Management
Telephone [phone] . -
Jonathan B. Howes, Secretary
April 1, 1993 ··
Ms. Beverly T. Hudson, Remedial Project Manager
Superfund Branch, Waste Management Division
US EPA Region IV
345 Courtland Street, NE .
Atlanta, Georgia 30365
Subject: Draft Field Operations Plan
Potter's Septic Tank Service Pits Superfund Site
Maco, Brunswick County, North Carolina
Dear Ms. Hudson:
The referenced Field Operations Plan (FOP) and associated documents have been
received and reviewed by this office. The following comments are offered by the North
Carolina Superfund Section.
Field Operations Plan
1.
2.
3.
General
Section 9.1 of the ROD indicates that treatability tests will be needed because the
chromium species is unknown. The FOP makes no reference to any treatability tests.
General
Section 9.2.1 of the ROD describes a periodic groundwater monitoring and sampling
program that is to be developed before and during remedial action. It is not clear
how much of this is covered in the FOP.
Table 1-2
There is no explanation why the maximum concentrations detected for PAHs, Cr, Pb,
and Zn are not indicated in this table. Values for Cr, Pb and Zn are included on
page 6 of Attachment A of the Record of Decision (ROD).
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 9\9-733-4984 Fax# 9\9-733-0513
An Equal Opportunity Affirmativt: Accion Employer
• •
Ms. Beverly T. Hudson
April 1, 1993
Page 2
4.
5.
Page 7, Section 2.4
This section indicates that (for Area 1) soil samples will be collected to allow for
better-delineation of areas requiring soil remediation. Section 9.3 of the ROD states
that a sampling program be developed to determine the actual volume of soils
requiring remedial action. It is not clear whether the commitment noted in the FOP
fully meets the requirement in the ROD. Also, since this ROD requirement does not
differentiate between Areas 1 and 3, it is appropriate to conclude that this applies
to both areas.
Page 11-12. Table 4-2
This table is difficult to follow and at times appears to be vague and contradictory.
The FOP should be a stand alone document that clearly describes the proposed
operation and contaminants of interest without relying on references to various
sections of the ROD. Also, describing this sampling process in tabular form may not
be an appropriate format to convey• the level of detail necessary for the reader to
fully understand the process. Using a more explicit narrative format would make the
sampling description much easier to follow. Other specific comments on this table
are as follows:
The first box under Area 1 indicates that there is No Commitment for soil
sampling in the ROD. Comment 4 above cites a reference to the contrary.
Using the indicated ROD references in the second box under Area 1 do not
make it clear which contaminants are included or excluded.
The third box indicating that no VOCs would be sampled appears to
contradict that noted in the second box referring again to the Table in the
ROD.
The metals sampling paragraph is confusing. It indicates that the extent maps
for chromium and zinc have not been found but will be checked to ensure the
lead cleanup area encompasses their respective cleanup levels.
The fourth box under Area 1 indicates that -1/10 of the number of
boreholes used in the RI will be used. Figure 8 (page 19) of the ROD shows
80 boreholes. H the number 15 in the next sentence represents the number
of samples then the total number of samples is closer to 20% than 10%.
Also, Figure 4-1 shows only 13 sample locations for Areas lA and 1B. It
would be helpful to identify ( using the ID numbers from Figure 8 of the
ROD) which borehole locations are to be used. Chromium and zinc are
indicated as "maybe". It should be clarified as to what factors control when
a "maybe" becomes a yes or no.
For Area 3, there are no contingencies noted if 5 borings are not enough to
characterize this area.
• •
Ms. Beverly T. Hudson
April 1, 1993
Page 3
Page 12. Table 4.2
The ROD reference in the first box under Deep Aquifer is incorrect. It
would be easier to follow if what is referenced is explicitly written out. (see
previous comment)
The second box under Deep Aquifer has question marks following Semi-
volatiles and metals. It is unclear how this is to be interpreted and what
factors would make this a definite yes or no.
The fourth box under Deep Aquifer appears to contradict what is noted in the
second box regarding sampling for semi-volatiles and metals.
Sampling for deep aquifer contaminants is listed in the Shallow Aquifer
column. Also, the deep aquifer sample taken at EP A-08 is not noted in the
deep aquifer column.
Appendix C -Health & Safety Plan
1. Page 12, Hazard Assessment section, third paragraph: It is recommended original
sources, such as 29 CFR 1910.1000 or the American Conference of Governmental
Industrial Hygienist Threshold Limit Values (AGCIH TLV) Booklet be used to find
exposure limits. Compilation booklets, such as the one cited, almost always contain
mistakes. ·
2. Page 22, Table IV-12: 1,4-Dichloroethane does not exist.
3. Page 22, Table IV-12: The TLV claimed for 2,4-Dimethyphenol is not present in the
' ACGIH TLV Booklet.
4. Page 22, Table IV-12: The PEL for cadmium is 0.2 mg/m3•
5. Page 22, Table IV-12: It is unclear to the reader what information is given as the
exposure limit for copper.
6. Page 22, Table IV-12: The following abbreviations need to be spelled out: PEL,
IDHL, AL, TLV, NA.
7. Page 22, Table IV-12: How sure are you of these being the only chemical
contaminants present on-site? If the site has been extensively sampled and you are
very sure these are the only contaminants present, level C protection may be
appropriate. If not, level C will not be appropriate.
• •
Ms. Beverly T. Hudson
April 1, 1993
Page 4
8. Page 28, Section VII: It is recommended hearing protection be based on the Noise
Reduction Rating (NRR), not by manufacturer. The EAR Company offers ear plugs
in different NRRs.
9. Page 30, Section IX: Decontamination procedures need to be outlined in this safety
plan.
10. Page 35, Section XIII: It is recommended this safety plan also include a map to the
nearest hospital and the location of the nearest phone.
Appendix D.1 -Chemical Boreholes and Appendix D.2 -Well Installation
1. General
The Department of Environment, Health and Natural Resources, Division of
Environmental Management has specific regulations (North Carolina Administrative
Code) that apply to the permitting, construction and abandonment of wells. Specific
regulatory references are:
NCAC Title 15; Subchapter 2C; Sections:
.0105 -Permits
.0108 -Standards of Construction; Wells Other Than Water Supply
.0113 -Abandonment of Wells
A copy of these sections are supplied for your information.
The North Carolina Superfund Section appreciates the opportunity to review
this document. If you have any questions or would like to discuss the subject
document, please contact me at [phone].
Sincerely,
~0~
Patrick Watters
Environmental Engineer
Superfund Section
Attachment
I /).·I: /J:C ./1/l//1
(3J Lpon receipt olropcrly completed applicJtion fonn, the licant will be issued a ccnificJtc
of registration.
(b) Pump ln,tallcr Registration:
(I) 1\ll persons, firms, or corporations engaged in the husincss of installing or-repairing pumps or
. other equipment in wells shall register bi-annually with the dcpanmcnt.
(2) Registration shall be accomplished. during the period from April I to April JO of C\'Cl'}' odd-
numbered year. by completing and submilling lo the department a registration fonn pro,·ided
by the dcpanmcnt for this purpose.
(J) Lpon receipt of a properly completed application fonn; the applicant will be issued a ccnificate
of rcgjstration.
1/isto,y Sate: StatutO!)' ,luthority G.S. 87-87;
FI/ Febma,y !, !976;
Amended Eff July /, !98S; April 20, 1978 .
. Oto~ PL'\IP I.'\ST..\l.1 .. -\TIO.'\ RE(;ISTR..\TIO.'\
Ilis101y ,\'ate: SrarutmT Authnritr G.S. 87-87;
Flf Fd,;,,ary I, 1976:
Rcpc,1/cd FI/ .lu(F I. /9SS .
. 0105 l'ER\IITS
(::q It is the finding of the Commis~ion that the entire gcof!faphical area of the state is n.Jlncrabk 10
groundw.:itcr pollution from improperly loc.:itcd. constructed. operated, altered: or ab3.ndoncd non·\\·a-
tcr supply wells and ,,·atcr supply wells not constructed in accordance with the st:rndards set for1h ·in
Ruic .0107 of this Section. Therefore. in order to insure reasonable protection of ihe ground\\'ater re-
sources. prior pcmlission from the Di\"ision must be obtained for the construction of the types of wells
enumerated in Paragraph (b) of this Ruic.
(b) ~o per:=.on shall loc.:i.tc or constrt.lct ai1y of the following weUs until a pcnnit has been issued hy
the Director:
( I) any watcr-\\'cll or well S\'Stcm with a design capacity of 100,000 gallons per day (gpdJ or greater:
(2) any well added to an existing system where the total design capacity of such existing well system
and added \\'CII will equal or exceed 100,000 gpd:
(J) any test \\'ell if the design capacity of the production well or \\'CII system "·ill be I 00,000 gpd
or gre.1tcr;
· (4) any monitoring well;
(5) · any rccorcry well;
(fr) anv well intended for the rccO\"Cf\' of minerals or ores;
(7) an)' geophysical cxplorJtion well;
(~) .1ny 0il 0r g:is cxplor:iti011 or recn,-rry well:
(9) any \\Tll for recharge or injection purposes;
( IOJ any cathodic protection well;
( 11) any well \\'ith a design dc\'iation frnm the standards specified under the rules of this Subchaptcr.
(c) \1onitoring wells associ:ned with a wastew:1ter treatment .:i.nd disposal facility for which a pem1it
must he ohlained from the dcpar1ment m:iy he permitted as part of that facility; pro\"idcd, however, that
the pcm1it applicant comply ,,·ith all pro,·isions of this Sl:lbchaptcr including construction standards and
reporting requirements.
(d) The Commission m.:i.y delegate. through a \fcmorandum of Agreement, to another state agency
the authority to pennit \\"Clls thJt arc an integ.i'Jl pan of a facility requiring a permit from the agency.
In the absence of such JgrCemcnt, all wells require a wcU construction permit in Jd<lition to any other
permits.
(c) J\n application for a pcnnit shall be submillcd by the owner or his agent in duplicate to the dc-
panmcnt on fonns furnished hy the dcpanmcnt, and sh:dl include the follo"·ing:
(I) f'or all wells:
(,\) the owner's name (facility name):
(ll) the owner's mailing aJJress (facility aJJrcss):
(C) Jcscription of the well type aoJ acti\'ity re4uiring a pcm1it;
(D) facility location (map I:
.\DR TIT CIROU.\A ,ln.\ll\"!STR.1 T!l"l: COD/:. !]j I.//S9 I'ngc 3
ut.\R. t:.\Tll/os.,hsr .. ,,_ .,1,i.,.-,r;u11,., 'r ,15_.1: !i.'C .ti/1I11 • • (f) site plan showing location of all sources or potential sources of groundwater contamination
and locations of proposed wells:
(f.) location and description of existing wells on the same site or within the same well system;
(G) locatioo of any test borings:
(II) construction diagram of proposed wells including specifications describing all materials to be
used, methods of construction and means for assuring the integrity and quality of the finished
wcll(s).
(2) For water supply \\'ells, in addition to (c)( I) of this Ruic, the application shall include:
(,\) the number, yield and location of existing wells in the system;
(ll) the design capacity of the proposed wcll(s);
(C) any other information that the department may reasonably deem necessary.
(3) f'or monitoring and rcco,·cry \\'Clls; in addition to the information required in (c)(l) of this Ruic:
(A) A description of the subsurface conditions sufficient to C\'aluatc the site. Data from test
borings, wells pumping tests. etc., may be required as necessary;
(ll) a description of the quantity, character and origin of the contamination:
(C) any other infom1ation that the department m:iy reasonably deem necessary.
(I) In the event of an cmcn:cnc,·. monitorin!! wells and ·or rcco\'cr; wells mav he constructcJ after
,-crbal appro,·al is pro,·iJcd hy0 the -Director. After the fact application·, shall be s~bmitted hy the driller
or owner within ten days after construction hegins. The arf'lication shall include construction details
of the monito,in~ \\'Cll(s) :rnd 'or rcco,-crY well(s).
(g) It shall he ·,he re.'.'ponsihility of thC well owner or his Jgcnt to sec· that a pcnnit is secured prior
to the constn1ction of any \\'ell for \\'hich .1 pennit is requircJ under the rnles of the Suhchaptcr.
Iii.rim)' .\'01c: S1a1111my .-l111hnri1_r G.S. 87-S.7;
FJJ F,·bru,uy I. 1976;
!lisrnry .\'me:
,lm,·ndcd Eff .\lurch I. /985; Scplcmbcr I, /98./; April 20, 1978.
S1,1111101T .-l111hnri1r G.S. /./3-2/5./4; 1./3-2/5.15;
FjJ. Tch,:11,ll)' I. !9°(,:
R,•pca/cd t:/): .-lpril 20, /978 .
. 01117 ST.-\'.\'0.-\ROS OF CO'.\'STR!'CTIO'.\': \\'.-\TER-SCPPLY \\TLLS
(a) Location
(I) The well shall be located:
(A) In :m area not generally subject to flooding. Areas \\·hich ha\·e a propensity for flooding in-
clude tho.,e \\'ith conc;i,·e slope, .:i\lu\'ial or collu,·ial soils: gullies, depressions~ anJ drainage \\·ays:
(n) at a minimum horizontal dist:mce of 50 feet from any water-tight se\\'age and liquid-waste
collection facili1y (such as c:1st iron pipe) except in the ca::-e of \\'ells _intended for a single family
d,\·cl\ing where it ·is not ka:,.ihle to oht:iin 50 fci:t separation het\\'ecn a \\'ell anJ a water-tight
liquid-,,·aste collection forility hccausc of lot size or other fixed conditions, the horizontal sera•
ration distance shall he the maximum feasible distance, but in no case less than 25 feet; rro\'ided
the sewer line is constructed of lcak·rroof pipe, such as cast iron pipe, \\'ith leaded or mechanical
joints;
(C) at a minim.um horizontal distance of ,I 00 feet from any other sewage or liquid-waste collection
any disposal facility (such as a septic tank and drain fields) and any other source of existing or
potential pollution or contamination. c:.:ccp! in the case nf wells intended for a sin!.!.lc fomih·
d\\'clling where it is not feasible to ohtain I no feet horizontal separation between a ,;ell and a
source because of lot size or other fixed cnn<litions, the separation distance shall be maximum
fca5,iblc distance, hut in no case less than 50 feet.
(~) 1\ctual separation distances must conform \\'ith the more stringent of applicahlc federal, state and
local requirements.
(3) \\'ells drilk<l for public "·atcr supply s)·stcms rcguhtcd hy the Department of I luman Resources
sh:i.U meet the siting anJ aU uthLT rl'4uirc1m:nts of that Ucpartmcnt.
(h) Drilling Fluius an<l ,\J<liti,·es. Drilling Flui<l, and ,\Jditi\'CS shall he materials specified for u,c
in \\'atcr \\"l'll con~truction anJ :irrro\-cJ hy the Di,·ision. ·
( c/ Casing
.\'OIi Tl/ C..11/0U.\A .-W.l!l.\'JST!/A TIU: COD[ 12/ !J/R9 !'age 4
ll.H: 11:C .1111111
Such pon sh-c installed and maintained in such mannl, to prcYcnt entrance of water or
forcii:m material.
(2) \\'cll-ldcnti11cation Plate
(A) An idcnti11cation plate showing the drilling contractor and registration number shall be in-
stalled on the wcU within 2-1 hours after completion of the drilling.
(13) The identi11cation plate shall be constructed of a durable weatherproof, rustproof metal or
cquiYalcnt material.
(C) The identi11cation plate shall he securely attached to the well casing or enclosure floor around
the casing where it is readily visible.
(D) The idcnti11cation pbtc shalf not he rcmo,-cd from the well by any person.·
(E) The identification tag shall he stamped with a permanent marking within 30 days of com-
pletion of drilling to show the:
(i) total depth of well;
(ii) casing depth (ft.) and inside diameter (in.);
(iii) screened intcr;als of screened wcUs;
(i,·) graYcl intcrYal of gra,·cl-packcd wells;
(v) yield. in gallons per minute (gpm), or specific cap.1city in gallons per minute per foot of
drawdmrn (gpm ft.-dd):
(\·i) static water k,·cl and d.:i.lc measured:
(\'ii) drilling contr;1ctor and rcgiqr:ition number:
(,·iii) date well completed.
(.1J fnTy ancsian \\'CII th.:11 tln\\'S under n.'.ltur:i! ancsi:in pressure shall be equipped with a ,·ah·c sn
that the llo\\' c;:in _be completely s1nppcd. \\'ell owners shall he responsible for the opcr:itinn and
m:iintcnancc of the \':i.h·c.
(-lJ Pit less ad:iptcr uni1s 5hall be allo,\'cd as a mc1!10d of well head compktion under the follm\·ing.
condition~:
(,\) the pit less _adapter unit be of standard design and manufactured spcci11cally for the purp0sc
of well const1uction: -
{f3) the unit shall meet industry st:rndards for strength and water tightness;
(C) the unit be c0mpatible with the well casing;
(D) the unit he joined to the well casing be either a threaded coupling or \\Tided joint:
(E) the top of the unit shall be at least S inches abo,·e land surface;
(I') the unit shall haYe an access pan. .
(5) All piping. \\'iring. and \·ents shall enter the well at least eight inches abo\·e land surfocc, except
· where pitlcss adapter units arc used.
1/isrory .Yntc: StalU(O/y Awliorit_r C.S. 87<\7; s;.ss:
[(( Fcb111a11· I. /9.76;
,i;11,·11dcd !)/ J/arrh I, /985; Scrt,·111/xr I, 198✓; Arri/ 20. /9-:'S .
. 0108 ST..\,D..\RDS OF co,sTRl°CTJo,: 111-:u.s OTHER TII..\' .\\'ATER s1·pp1.y
(al :--;o well shall he loc.:itcd, constructed. opcr.11cd. or repaired in any manner that may ad\'crse\~·
impact the quality of groundw:11cr. An~· test holes :ind borings shall be pem1.::incntly ahandoncJ by the
driller in accordance "·ith Ruic .0 I 13 0f this Section within two days after drilling or two days after
testing is complete, whichc\Tr is k.::ist restricti\'c; except in the case that a test well is heing con\'cr1cd
to a production well. in \\·hich ca:--c com·~rsion shall he completed within JO days.
(b) Injection wells ,hall conform to the st:utd;irJs set fonh in Section .0200 of this Subchaptcr.
(c) \ lonitoring \\'l'i]s :.inJ rcco\-cry \\\:tis :-h:.ill h:.: loc:itcJ. Jc:--ig:ncd. constructed. opcr:.itcJ anJ ahan-
doncd \\'ith m:itcri~ds anJ hy mcthoJs \\'hich :ire comp:itihit: \\·ith the chcmic:il and physical propcrtic:s
of the contaminants involved, specific .site conditions and specific subsurface conditions. Specific
construction standarJs \\·ill be itcmizeJ in the construction f'cnnit, but the follo\\'ing gcn·cral require•
mcnb will apply:
(I) The hnrcholc shall not penetrate to :i depth ~realer than the depth to be monitored or the depth
from which cont3min:mts 3rc 10 he rccon·rcd.
(2) The well shall not hy<lrauLic:illy connect scraratc aquifers.
(.1) Constructirin matciials :--hall he comp:.itihlc ,,·ith the contaminants to be monitored or rccon:red.
(-l) The \\·ell .shall be con.structcJ in :--ui.:h a m:rnncr that \\'atcr from the land surf:.icc cannot mi:!.r;1tc
into gr.:1\·cl pack or well screen :H"ca. -
SORT// C..IROUS.-t AD.1/1.\"!STR.-IT/1'/: COD[ !]/f✓/S9 !'age S
)
!:/1.\"I/ • f,.\T/1/0.\J I/:.\" TA I .. \/.-1\A (;f:.\I /:.\ T r,5_.1: n:c .1111,0 • • (5) \\.hen a grawl rack is rlaecd around the screen. a seal shall he installed ahm-c the 1cra,·cl.
(6) Grout shall he rlaccd in the annular sracc between the casing and the borehole wall from land
surface to a depth within two feet ahoYc the top of the well screen or to the bottom of the casing
for open end wells.
(7J /\II wells shall be. secured to reasonably insure against unauthorized access and use.
(8) ,\II wells shall he afforded icasonahlc protection against damage during construction and use.
(9) Any wells \1-hich arc Dowing artesian wells shall be vah·cd so that the Dow can be regulated.
(IO) Each well shall ha,·c pcnnancntly affixed an identification plate constructed of a durable ma-
terial and shall contain the followinc infonnation:
(i\) drilling contractor name and rcgi;tration number:
(fl) date well completed;
(C) total depth of well;
(D) a waming that the well is not the water surrly and that the groundwater may contain ha,.-
ardous materials; and
(E) dcpth(s) to scrccn(s).
(d) Obscrntion \Velis.
(!) shall he cased as srecified in .0J07(e) of this Suheharter unless otherwise arrroved by the de-
p.:irtmcnt.
(~) shall be grouted to "·ithin t,rn feet of the well screens or, for open end wells, to the bottom of
the casing unless otherwise appro\·cd by the dcpanmcnt.
Staf/l!OIT :1111/inritr r,,s. 87•.!r:: 87·88,· r:rr r,,1,;11,11,-1. !976:
.ii11t11dtd r),: S,•prrmb,·r !, /9S./: .-lpril JO, /978 .
. 11109 l'C\IrS A:\D PC\11'1\°C EQUl'\IE\°T
(a) The pumring caracity of the.rump shall be consistent "·ith the intended use and yield charac-
teristics of the well. · ·
(h) The pump and rcl:ltcd equipment for the well sh;:ill be corn-cnicntly located to pcnriit c.1sy access
;ind rcmcn·a\ for repair :rnd maintenance.
(c) The base plate of a rumr placed directly over the well shall he designed to fonn a "·ateni~ht seal
with the ,,·ell casing or pump foundation.
(d) In installations ,,·here the pump is no_t located directly oYcr the well: the annular $race between
the casing and pump int.:1ke or discharge-piping shall be closed with a watcnight seal prefcr.:ihly designed
specifically for this purpose.
(c) The \\Tll shall be properly ,-cnted at the well head to allow for the pressure changes within the
well except ,,·hen a suction lift type pump is u:--ed.
(f) A hose hibh shall he-inst:llll'd at the well-head hy the person in$talling the rump for ohtaininf!
,,·::iter $:1mplcs. In the ca$e of ofl\et "jct pump installations the hose hihb shall he installed on the return
(pressure) side of the jei pump piping.
(g) J\ priming tee shall be instalkJ at the well head in conjunction with CJffset jct pump installations.
(h) Any suction line installed underground between the \\Tll and pump shall be surrounded by six
inches of cement, or encased in a larger pipe that is scaled at each end.
(i) The drop piping and electrical wiring U$Cd in connection with the pump shall meet underwriters
spccifica1iom: acceptahlc to the dcpartmen).
(j) Cont:imi_n:-itc-d ,,·atcr shall not he used for"priming the pump.
l!i.<IDI)' Xnrc: Sl,l/11/n!J A whnri1.1· r,.s. 87-87: S7-8S:
/:JT Fcb111,11r !, /976:
Amended Eff ,l11ril 20, /978 .
. 0110 \\Tl.I. TESTS FOR YIELD
(a) [,-cry water supply well shall be tested for capacity by a meth?d and for a period of time ac-
ceptable to the department.
(b) The pcm1it1ec may be n:quircJ as :t pcnnit condition to test any \\"ell for cap:1ci1y hy a mcthoJ
stipubtcd in the pcnnit.
(c) Standard mt:lhod~ for testing cJomcstic ,,-ell capacities include:
(II Pump \lcthod
.YOR71! C..11/0US.•I ,ID.1ll.\"IS71/ATl1E CODE n/1.//li? !'age 9
. '' . Ul.\R -T..\T/RO.\JI !:.\TA I .. 11.-t.\A GT..111,.\T T/5.-t: {!JC .1111//1 • • (d_l. \ational Science roundation (\Sr) apprm-cd P\'C pipe rated at 160 PSI may he used for liner
ca~mg. The annular space around the liner casing slwll be at least fj\·c-cighths inches anJ shall be
completely filled with neat-cement grout.
llis101J' .\'n1e: S1a1U1n1y .1wharily G.S. 87-87; 87-SS;
£ff Februmy I, /976;
Amended 1/f Sep/ember/, 198✓ .
. 0113 ABA\DO\\IE\T or \\"ELLS
(a) i\ny well which has been abandoned. either temporarily or pcnnancntly, shall be abandoned in
accordance \\·ith one of the following procedures:
(I) Procedures for temporary abandonment of wells:
(;\) Lpon temporary removal from scf\·ice or prior to being put into scf\'ice, the well shall be
scaled with a water-tight cap or seal compatible with casing and installed so that it cannot be
rcmm-cd easily by hand.
(B) _The well shall be maintained whereby it is not a source or channel or contamin.:i.tion during.
tcmpor:.uy ab:rnJonmi.:nt.
(C) l.-:\'l:ry temporarily :.ih~rndnncJ well shall be protected with a casing.
( ~) Pmccdurcs for pcnn.:i.ncnt .:i.handonmcnt of wells:
(_.\) AJI casink'. anJ screen materials m3y be remo\'eJ prior to initiation of ahandonmcnl procc-
Uurcs if such n:mo\·a\ will not c:.iusl' or contrihute to contamination of the ground\\·:.11i.::rs. ,\ny
casing not grouteJ in accordance \\·ith Rull! .0107 Par:.igraph (cJ) of this Section shall be rl'mo"n·J
or properly grouted.
( 13) The entire Jcpth of the well shall be sounJcJ before it is scaled to ensure freedom from ob-
structions tha_t·may interf1:rc with scaling operations.
(C) The well shall be thornughly disinfected prior to scaling.
(D) In the case of gr3\·el-packed wells in \\·hich the casing and screens ha\·c not been rcmon..·d.
neat-cement shall be injected into the well completely filling it from the bottom of the casing to
the top.
([) "Bored" "·ells shall be completel)· filled with cement grout, dry clay or material excavated
during drilling of the well and then compacted in place.
(F/ Wells constructed in unconsolidated formations other than "bored" \\Tlls shall be complctcl)·
dilled with cement grout by introducing it through a pipe extending to the bottom of the well
which can be raiseU as the well is filled.
(G) Wells constructed in consolidated rock formations or that penetrate zones of consolidated
rock ma)· be fillcJ with cement, sand, gra\·cl or drill cuttings opposite the zones of consolidated
rock. The top of the sand. gra,·cl or cutting 1111 shall he at least five feet below the top of the
rnns<>lid;itcd roes. The remainder of the well shall be filled with cement grout nnly.
(11) Test wells less than 20 feet in depth which do not penetrate the water table shall he ahancloncd
in such nunncr as to prcn:nt the well from being a channel allowi.n·g the \'ertical mo\'C.'ml'nt of
water or a source of contamination to the grou11Jwatcr supply. Test wells or borings th:.it pen-
etrate the water table shall he alx,ndnned by completely filling with cement h'fOUI.
(b) ;\ny well which acts as a source or channel of contamination shall be repaired or pcnnancntly
abandorn:J wi1hin JO days or receipt of notice from the department.
(c) The.: drilling contr.:.iclor s!ia!J pen11~111i.:ntly :.ib:.inJon .:.iny \\"Cl! in which the casing has not hccn in•
stalltd or from ,,·hich the.: c:.ising h:.1s been rcmo\·ed, prior to remo\·ing. his equipml!nl from the site.
(d) The O\\·ncr shall be responsible for pcm1:.1nc:ll abandonment of a wd] t·xccpt:
( I) As othcrn·isc spccific·J in these Regulations; or
(2) If well ah:1mhmmcnt is required because the Urillcr improperly locates, constructs, or completes
the 11·cll.
l/i.<ln1J' .\'me: S1a1u1n1y ,IU1hori1_1· G.S. 87-87; 87-8S;
llf. Februmy /, /9.76:
,I mended !:ff Sepwnh,,r I, /98-1; :lpril :o, /978 .
. lll 14 DAL\ .Y\'D HECOHDS REQURED
(a) \\'ell Cuttings
.\'()fl Tl/ C.t fl()/_/.\".-t .·tD.111.\"ISTR.1 T/1 E CODE 12/ l-1/li9 I'ngc 12
)
• •
March 31, 1993
TO: Patrick Watters
FROM: David Lilley
RE: Comments prepared on the Draft Field Operations Plan for the
Potter's Septic •rank Service Pits Site, Brunswick County, NC
llfter reviewing the above mentioned document, I offer the
following comments:
1. Page 12, Hazard Assessment section, third paragraph: It is
recommended original sources, such as 29 CFR 1910.1000 or the
American Conference of Governmental Industrial Hygienist
Threshold Limit Values (AGCIH 'fLV} Booklet be used to find
exposure limits. Compilation booklets, such as the one cited,
almost always contain mistakes.
2. Page 22: 1,4-Dichloroethane does not exist.
3. Page 22: The TLV claimed for 2,4-Dimethylphenol is not present
in the ACGIH TLV Booklet.
4. Page 22: 3 The PEL for cadmium is 0.2 mg/m.
5. Page 22: It is unclear to the reader what information is given
as the exposure limit for copper.
6. Page 22: The following abbreviations need to be spelled out:
PEL, IDLH, AL, TLV, NA.
7. Page 22: How sure are you of these being the only chemical
contaminants present on-site? If the site has been extensively
sampled and you are very sure these are the only contaminants
present, level C protection may be appropriate. If not, level C
will not be appropriate.
8. Page 28: It is recommended hearing protection be based on the
Noise Reduction Rating (NRR}, not by manufacturer. The EAR
company offers ear plugs in different NRRs.
9. Page 30: Decontamination procedures need to be outlined in this
safety plan.
10. Page 35: It is recommended this safety plan also include a map
to the nearest hospital and the location of the nearest phone.
dl/DL/comments.doc/27
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
Mr. Jack Butler
North Carolina Department of Environment
Health, and Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
RtGEIVtU
MAR 24 1993
SU~ERfUND sroroN
RE:1 Review Draft Remedial Design Field Operations Plan (FOP) for the
P·otter's Septic Tank Service Pits Superfund Site
Dear Mr. Butler:
Enclosed is a draft Remedial Design FOP for the Potter's Septic Tank
Service Pits Superfund Site located in Wilmington, North Carolina.
Please review the work plan submitted on March 22, 1993, and provide
comments to me by April 1, 1993. If you are unable to meet this
timeframe, please inform me as to when you will be able to get your
comment to me. Thank you for your cooperation.
If you have any questions regarding this site, please contact me at
[phone].
cerely,-~
Beverl T. Hudson
Remedial Project Manager
Enclosure
cc: William Meyers, NCDEHNR (w/o encl.)
cc: Micheal A. Kelly, NCDEHNR (w/o encl.)
Printed on Recycled Paper
•
State of North Carolina Oepan:ment of Environment, Health, and Natural Resources
Division of Coastal Management
225 North McDowell Street • Raleigh, North Carolina 27602
James G. Martin, Governor
\'(/JJliam W Cobey, Jr., Secretary
Mr, Greer T. Tidwell
Regional Administ"rator
EPA
345 Courtland Street, N.E. A !Jania;' GA 30365
November 9, 1992 Rog-er N. Schecter
Director
REFERENCE: SCH93-0220 Remedial Design/Remedial Action Project • Potter's Septic Tank Service Superfund Site, Sandy Oeel, Brunswick. County
Dear Mr. Tidwell:
The Division of Coastal Management has reviewed the subjt'ct project for.consistency with the North Carolina Coasllll Management Program (NC0"1P) according to 15 CFR 930. We have found the project to be consistent wiU, il,e Program, providing the following conditions arc met,
1. Contaminated soils, gTOundwater decontamination byproducts, sludge, and spent activated carbon are treated and disposed ofin accordance with EPA stand~rds and requirement:s, and no material will be depu5ited or disposf>C! of in l\ny area where it could have potential adverse impacts on any land or water resource of the coas11tl zone.
2. The monitoring program shall include regular testing of treated waters being di&:harged into Chinnis Branch.
3. A sedimentation and erosior, control plan must be submitted to and approved by the NC Division ot Land Resources prior to beginning any land disturbing activity if more than one acre will be disturbed. 11 any portion of the project is located in~ High Quality Water Zone {HQW), as classified by the Division of Environmental Management, increased design standards for sedimentation and erosion will apply.
4. The project must comply with all air pollution regulations and emissions standards contained within Title 15A; North Carolina Admin.ist;ativc Qidc (NCAC); ChaptGr 2.
I ·, •
5. All other state pennits and authodzatlons are obtained prior to initiation of the project.
Thanl< you for the opportunity to comment on this project. If you have any questions, please call Steve Benton or Caroline Bellis, Division of Coastal Management, at [phone].
Sincen.ily,
. £,g:_/~
fl,,-Roger N. Schecter .
cc: Bob Stroud, Di vision ·of CoastaJ Management, Wilmington Cluys Baggett, NC Slllte Gearing House
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
· · Division of Coastal Management_
2~5 North McDov.oell Street • Raleigh, North C.rdina 27602
James G. Martin, Governor
William W Cobey, Jr., Secret.1ry Roger N. Schecter
Director
TO:
FAX#:
FROM:
PAGES: -
SUBJECT:
FAX TRANSMITTAL
DATE: ____ _
733 -1-f<t I I
_.,,3'--___ (including this cover sheet)
Pcnnx'.,; xpnc 1r.i10i::.. ·v,:rr:s -t=:rA
;
Si:" l f, 1992
• • UNl"fED STATES ENVIRONMENTAL PROTECTION AGEtlCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGiA 30365 RECEIVED
Mrs. Chrys Baggett i .
Director, State Clearinghouse
Department of Administration
116 West Jones Str~et
SEP 2G 1992
SUPERFUND SECTION
Raleigh, North Carolina 27611
RE: Intergovernmental Review for a Remedial Design/Remedial Action
Project at the Potter's Septic Tank Service Pits Superfund
Site
Dear Mrs. Baggett:
This letter notifies you of an approaching Superfund project to be
funded by Superfund money. The last intergo~ernmental review for
the Potter's Pits site was conducted prior to the Remedial
Investigation and Feasibility Study (RI/FS) which was initiated in
January 1990 .. This requested State Intergovernmental Review will
help ensure that the Agency is knowledgeable of all State laws and
regulations that may have been.revised or added since the January
1990 timeframe. The 60-day comment period will commence five days
after the date on this letter. Please address any comments on the
proposed action to Darcy Duin, the EPA Remedial project Manager.
The Remedial Design/Remedial Action (RD/RA) activities are
described below:
1. Site Name:
Priorities
Potter's Septic Tank
List Superfund Site •
Service Pits National
2. ·Location of Site: This Site is located approximately 17
miles west of Wilmington, North Carolina in a rural
community known as the Town of Sandy Creek.
3. Site Rank: This Site was ·proposed in June 1988 for
inclusion on the National Priorities List (NPL) (40 CFR
Part 300, Appendix B) established by EPA pursuant to the
Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA) (P.L. 96-510), as amended
by the Superfund Amendments and Reauthorization Act of
1986 (SARA) (P.L. 99-499). The Site was finalized on the
NPL in March 1989.
4. Nature of the Problem: The RI/FS defined and characteri-
zed the contamination at the Site. Contamination at-the
·Site resulted from former disposal practices .which
consisted of placing waste petroleum products and septic
tank sludges in shallow unlined pits or directly on the
land surface. The contaminants at the Site include
Printed on Recyclea PJper
l
• •
benzene, ethylbenzene, toluene; xylene, lead, chromium,
zinc, and carcinogenic PAHs. These contaminants were
found in on-site soils and in the groundwater beneath the
Site.
5. Description of Proposed Activities: This RD/RA project
consists of meeting the requirements specified in the
August 1992 Record of Decision and Section 300.435 of the
National Oil and Hazardous Substances Pollution
Contingency Plan (40 CPR Part 300), as amended.
Following approval of the RD, the RA will be implemented.
Briefly the remedy includes the following activities:
1. If needed sa.~ple soils to better define the areas
which will be excavated.
2. Excavate and treat by Low Temperature Thermal
Desorption approximately 10,000 cubic yards of
contaminated soil.
3. Replace the treated soil, following confirmation
sampling, in the excavated areas.
4. Install and sample monitoring wells placed in the
deep aquifer to determine the extent, if any, of
contamination in this aquifer.
5.
6.
7.
Contaminated groundwater will
within and, at the periphery
extraction wells and piped to
ground treatmen_t process.
be extracted from
of the plume via
an on-site, above-
Install and develop
and possibly more
clusters.
groundwater extraction wells
groundwater monitoring well
Treatment process includes precipitation,
flocculation, and filtration for removal of the
heavy metals, and treatm_ent by air stripping for
removing the Volatile Organic Compounds.
8. Discharge of the treated groundwater will be to
Chinnis Branch which is a creek that runs across
the Site. The substantive requirements of a
National Pollution Discharge Elimination System
(NPDES) will be met before discharge will occur.
9. Any sludge or spent activated carbon which may have
to be used on the Low Temperature Thermal
Desorption Unit will be dealt with in the most cost
efficient manner.
- 2 -
• •
6. Community Relations Activities: Community relations
activities will be conducted as part of this project to
inform and receive input from the public officials and
the affected community. These activities may include
conducting public meetings and workshops, distributing
press releases, speaking to concerned citizens' groups,
preparing fact sheets, and maintaining and updating an
information repository in the vicinity of the Site.
7. Estimated Cost: The estimated costs for the RD and RA
are $250,000 and $11,800,000, respectively. The State
will need to contribute matching funds, 10 percent of the
RA costs or approximately $1,180,000.
8. Projected Start Date: The RD will be initiated
immediately. The RA will commence upon the approval of
the RD by the Agency. It is anticipated that the RD will
require one year to complete.
9. Projected Completion Date: Upon commencement, it is
estimated to take 360 days to complete the RD and 270
days to implement and complete remedial activities at the
Site except for groundwater remediation. Groundwater
remediation is anticipated to take 50 years and involves
a groundwater extraction and treatment system with the
treated water being discharged into Chinnis Branch.
10. State Project Officer:
11.
' Ms. Charlotte Jesneck ,
North Carolina Department of Environment,
Health & Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
[phone]
EPA Superfund Project Manager:
Ms. Darcy Duin
EPA
345 Courtland Street, N.E.
Atlanta, Georgia 30365
[phone]
Please address any questions you may have to Darcy Duin, the
Remedial Project Manager for this Site.
Sincerely yours,
~/)1~
-f"'Greer C. Tidwell
Regional Administrator
- 3 -
• •
cc: Curt Fehn, EPA
Charlotte Jesneck, NCDEHNR
)