NCD981927502_19931105_Geigy Chemical Corporation_FRBCERCLA RD_Remedial Design Work Plan-OCR

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REMEDIAL DESIGN WORK PLAN
GEIGY CHEMICAL CORPORATION SITE
·• ABERDEEN, NORTH CAROLINA
:t
NOVEMBER 1993
PREPARED BY:
RUST ENVIRONMENT & INFRASTRUCTURE .
RUST E&I PROJECT NO. 86619.200
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D[C O :J 1993
SUPERFtJNn StCllON
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GEIGY CHEMICAL CORPORATION SITE
REMEDIAL DESIGN WORK PLAN
TABLE OF CONTENTS
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
1.1 SITE BACKGROUND ................................... 1-1
1.1.1 Site History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3
1.1.2 Existing Analytical Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4
1.2 RD/RA REQUIREMENTS ............................... 1-5
1.3 OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-7
1.4 DOCUMENT ORGANIZATION ........................... 1-7
1.5 ADJUNCT DOCUMENTS ................................ 1-8
1.5.1 Sampling and Analysis Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8
1.5.2 Health and Safety Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-9
2.0 GROUNDWATER EXTRACTION AND TREATMENT. . . . . . . . . . . . . . . . . 2-1
2.1 PRELIMINARY DESIGN BASIS ........................... 2-1
2.1.1 Extraction Rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.1.1.1
2.1.1.2
Uppermost Aquifer . . . . . . . . . . . . . . . . . . . . . . 2-2
Second Uppermost Aquifer . . . . . . . . . . . . . . . . 2-2
2.1.2 Chemical Composition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3
2.1.2.1
2.1.2.2
2.1.2.3
Pesticides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3
TCE .................................. 2-4
General Parameters . . . . . . . . . . . . . . . . . . . . . . 2-4
2.2 EXTRACTION WELLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4
2.3 PRETREATMENT .................................... ; . 2-7
2.4 ACTIVATED CARBON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8
2.5 PERFORMANCE MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8
2.6 LONG-TERM EVALUATION ............................. 2-9
2.7 TCE EVALUATION .................................... 2-10
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3.0 SOIL EXCAVATION AND DISPOSAL ............................ 3-1
3.1 PRELIMINARY DESIGN BASIS ........................... 3-1
3.2 EXCAVATION ........................................ 3-2
3.3 TRANSPORTATION .................................... 3-3
3.4 DISPOSAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
3.5 DEMOLITION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5
3.6 REVEGETATION/FENCING ............................. 3-5
4.0 POTENTIAL REGULATORY REQUIREMENTS ..................... 4-1
4.1 GROUNDWATER DISCHARGE .......................... 4-1
4.1.1 Moore County POTW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
4.1.2 Infiltration Gallery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2
4.2 GROUNDWATER TREATMENT RESIDUALS ............... 4-3
4.3 SOIL DISPOSAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4
4.3.1 Excavation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4
4.3.2 Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4
4.3.3 Landfilling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
4.3.4 Incineration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
4.4 LOCAL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
4.4.1 Rights-of-Way . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6
4.4.2 Access Agreements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6
5.0 PRE-DESIGN FIELD ACTMTIES ............................... 5-1
5.1 GROUNDWATER CHARACTERIZATION .................. 5-1
Geigy RDWP
5.1.1 Water Level Measurements . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1
5.1.2 Groundwater Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2
5.1.3
5.1.4
5.1.5
5.1.2.1
5.1.2.2
Wells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2
Direct Push . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3
Additional Monitoring Wells . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4
Aquifer Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5
Well Abandonment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5
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5.2 DELINEATION OF TCE ................................. 5-6
5.3 GROUNDWATER TREATABILITY TESTING ............... 5-7
5.4 LITHOLOGIC LOGGING AND SUBSURFACE SOIL
SAMPLING ........ , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-8
5.5 INFILTRATION TESTING ............................... 5-9
5.6 SOIL CHARACTERIZATION ............................. 5-11
5.7 SURVEYING .......................................... 5-12
6.0 REMEDIAL DESIGN SUBMITIALS......... . . . . . . . . . . . . . . . . . . . . . 6-1
6.1 PRELIMINARY DESIGN REPORT ........................ 6-1
6.2 COMBINED INTERMEDIATE/PRE-FINAL DESIGN REPORT .. 6-3
6.2.1 Intermediate Design Requirements . . . . . . . . . . . . . . . . . . . . . 6-3
6.2.2 Performance Standards Verification Plan . . . . . . . . . . . . . . . . . 6-4
6.2.3 Pre-Final Design Requirements . . . . . . . . . . . . . . . . . . . . . . . . 6-5
7.0 PROJECT MANAGEMENT ..................................... 7-1
7.1 PROJECT ORGANIZATION .............................. 7-1
7.2 QUALITY CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2
7.3 DATA MANAGEMENT PLAN ...................... : ..... 7-3
7.3.1 Minimum Data Requirements/Formatting . . . . . . . . . . . . . . . . 7-3
7.3.2 Data Tracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3
7.3.3 Sorting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4
7.3.4 Validating . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4
7.3.5 Retnevmg . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-5
7.3.6 Backup Data Management . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-5
7.3.7 Project Procedure Manual . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-5
7.4 DESIGN CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-7
7.5 PROGRESS REPORTS .................................. 7-7
7.6 SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-8
7.7 COMMUNITY RELATIONS .............................. 7-9
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I FIGURES
I Figure No. Description
I 1-1 Location Map
1-2 Site Plan
1-3 Hydrogeologic Profile
I 1-4 Existing Well Locations
1-5 Uppermost Aquifer Contour Map
1-6 Second Uppermost Aquifer Contour Map
I 5-1 Proposed Direct Push Locations
5-2 Existing and Proposed Well Locations
5-3 Proposed Infiltration Gallery Test Locations
I 5-4 Proposed Surficial Soil Sampling Locations
7-1 Project Organization
7-2 Remedial Design Schedule
I TABLES
I Table No. Description
1.1 Performance Standards
I 1.2 Summary of Groundwater Quality Analyses
1.3 Monitor Well Construction Details
5.1 Proposed Well Construction Details
I 7.1 Project File Index
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I Geigy RDWP IV November 5, 1993
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1.0 INTRODUCTION
This Remedial Design Work Plan (RDWP) has been prepared for the Geigy Chemical
Corporation Superfund Site ("Site") located in Aberdeen, North Carolina. The purpose of
the RDWP is to provide a detailed scope of work and technical approach for the design of
the remedy as set forth in the August 27, 1992 Record of Decision (ROD) for the Site. This
work plan has been prepared in accordance with Section VJ, Paragraph 10 of the Consent
Decree and relevant United States Environmental Protection Agency (EPA) guidance. The
RDWP has been prepared for Olin Corporation, Ciba-Geigy Corporation, and Kaiser
Aluminum & Chemical Corporation ("the Companies").
The nature and extent of contamination at the Site has been characterized through a
two-phase Remedial Investigation (ERM; March 1992). This information was used to
develop a baseline risk assessment to determine possible public health risks and potential
impacts to environmental receptors (Clement International Corporation, March 13, 1992).
Potential remedial alternatives were developed and evaluated in the Feasibility Study
(Sirrine Environmental Consultants, March 1992).
1.1 SITE BACKGROUND
The Site is located one-half mile east of Aberdeen on State Highway 211 in Moore County,
North Carolina (Figure 1-1). The former area of active use at the Site comprised
approximately one acre. This area, referred to herein as the facility property, is vacant and
bounded by Highway 211 to the north, the Aberdeen & Rockfish Railroad to the south, and
the Allred property to the east. The property contains partial concrete foundations from
two former warehouses, a small office building, a concrete tank pad, storage tanks for purge
water, and a decontamination pad (Figure 1-2). Manmade features depicted on Figure 1-2
are approximate and will be revised following completion of the Site survey.
The Site is in the Sandhills physiographic province, characterized by rolling hills underlain
by well-drained, unconsolidated sands. Site soils are of the Candor series and are deep,
excessively drained sandy soils (e.g., sand, silty sand, loamy sand, sandy loam). The Site is
essentially flat.
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Three aquifers underlie the Site: the surficial (uppermost), Black Creek (second uppermost),
and Upper Cape Fear (third uppermost) aquifers. A cross-section of the Site hydrogeology
is presented in Figure 1-3. Monitoring well locations are presented in Figure 1-4.
Approximate depth to groundwater in the uppermost aquifer at the Site is 35 to 45 feet.
The average saturated thickness and hydraulic conductivity in the uppermost aquifer at the
Site are 12 feet and 2.8 feet/day, respectively. Groundwater in the uppermost aquifer flows
from the eastern and western portions of the Site and meets in an elongated zone of
convergence. East of the convergence zone, groundwater flows west and northwest with a
hydraulic gradient of 0.026 ft/ft. West of the convergence zone, groundwater flow is
predominantly to the east-southeast with a hydraulic gradient o'f 0.017 ft/ft. Groundwater
gradients in the uppermost aquifer are presented in Figure 1-5.
The Black Creek confining unit is interpreted, through boring logs developed during Site
drilling, to be continuous beneath the facility property. However, south of the parcel the
lateral continuity of the layer is uncertain. Boring logs indicated that the thickness of the
confining unit underlying the facility property ranges from 6 to 20 feet. Average thickness
and hydraulic conductivity for the second uppermost aquifer at the Site are 40 feet and 28
feet/ day, respectively. Groundwater flow is generally to the northwest, with an average
gradient of 0.004 ft/ft. Groundwater gradients in the second uppermost aquifer are
presented in Figure 1-6.
The Upper Cape Fear confining unit (approximately 60 feet thick) exists between the Black
Creek and Upper Cape Fear aquifers at the Site. The third uppermost aquifer ranges from
10 to 20 feet thick and overlies crystalline· bedrock. The estimated hydraulic conductivity
is 30 feet/ day. Groundwater flow is generally to the northwest.
There is no surface water at the Site. Drainage ditches are located along the railroad tracks
and across Highway 211 on the western side of the Site. Drainage ditches at the Site are
dry except during storm events. Surface water runoff during storms is absorbed into the
well-drained soils.
Approximately 2,700 people live in Aberdeen and 59,000 in Moore County.
1,200 people live within a one-mile radius of the Site (ERM, March
employment is in manufacturing, lumbering, retail trade and tourism.
Geigy RDWP 1-2
Approximately
1992). Major
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There are no endangered species or habitats on the Site. The Site is located between a
state highway and an active rail line, with a maximum width of 150 feet (Figure 1-2).
Accordingly, the Site is not an attractive or large area for wildlife.
More complete descriptions of the Site physiographic, hydrologic, geologic, demographic,
ecological, and natural resource features are presented in the RI/FS.
1. 1. 1 Site History
The Site was operated as a pesticide blending and formulation facility by various operators
from approximately 1947 to 1967 and by retail distributors of agricultural chemicals from
1968 to 1989. The pesticides DDT, toxaphene, and BHC were received in bulk at the Site,
blended with clay and other inert materials, repackaged, and sold. Pesticides were not
manufactured at the Site but were formulated by dry mixing into a product suitable for local
consumer use. During normal formulation activities, there were occasional incidental losses
to the Site soils.
Soil removal actions were conducted in 1989 and 1991. A two-phase soil removal action,
approved by the EPA, was conducted at the Site in 1989 to remove areas of visually
contaminated soils and debris. The areas for removal were generally located at former
areas of active use, such as near the access doors to the warehouses. The initial removal
was conducted in February 1989 by GSX Services, Inc. Visual areas of pesticide
contamination were removed and the wastes placed at the GSX Landfill in Pinewood, South
Carolina. A total of 462 tons of material were removed and disposed. The removal of
visually contaminated soils was completed in October 1989. Soils from the October 1989
removal action were incinerated at the Therma!Kem fac(lity in Rock Hill, South Carolina
or transported as hazardous waste to the Laidlaw Environmental Services Landfill (formerly
GSX Services) in Pinewood, South Carolina.
A second removal action was conducted in 1991 using EPA-approved interim removal levels
such that site soil would be less than 100 mg/kg for gamma-BHC and less than 500 mg/kg
for toxaphene. The warehouse superstructures, a portion of the eastern end of the
warehouse A foundation, the pump house, and contaminated soils were removed from the
Site during March through April of 1991. The remaining concrete foundations beneath the
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former warehouses appeared to be structurally sound ( e.g., no significant cracking) and were
steam cleaned. Approximately 2841 tons of soil and debris were removed. Of this, 505 tons
of soil were transported to the Rollins Facility in Deer Park, Texas for incineration. The
remainder was disposed at the Chemical Waste Management landfill in Carlyss, Louisiana.
Confirmation sampling determined that the interim removal levels were achieved.
Approximately 3071 tons of contaminated soil and 460 tons of debris have been removed
from the Site and properly treated or disposed. All on-site facilities (except for the office
building) have been demolished. A portion of the concrete pads under the former
warehouses remain at the Site. Currently, the Site is unoccupied, posted and fenced.
1.1.2 Existing Analytical Data
Analytical parameters for soil and groundwater samples collected during the Remedial
Investigation (RI) included volatile and semi-volatile organic compounds, metals,
polychlorinated biphenyls (PCBs ), and pesticides. Copper, lead, and zinc were within
background concentrations. BHC isomers and toxaphene were the most prevalent
pesticides. Trichloroethene (TCE) was detected in the second uppermost aquifer but no
other media, as discussed below. Air was found to be not impacted by the Site.
Pesticides are the only compounds exceeding Performance Standards (Table 1. 1) in surficial
soils (0 - 1 foot depth). Concentrations exceed the Performance Standards in 72 of the 167
surface soil sampling locations. Toxaphene is the most prevalent pesticide, with current
concentrations ranging from below detection to 130 mg/kg. Toxaphene governs the removal
of soils for all but two of the 71 locations that exceed the Performance Standards. DOE and
DDT exceed Performance Standards at the remaining locations. Pesticide concentrations
for surficial soils are presented in Appendix A. This data forms the basis for preliminary
estimates of excavation volumes and for selecting any additional sampling locations.
Maximum groundwater concentrations for pesticides were found in the uppermost
monitoring wells. The BHC isomers (alpha, beta, gamma, and delta) were the most
prevalent pesticides, with maximum concentrations around 30 ug/1. Groundwater data is
summarized in Table 1.2. Monitoring well construction information is summarized in Table
1.3. Pesticides in the uppermost aquifer are migrating towards the center of the Site, due
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to the convergence of groundwater flow from the east and west. No pesticides were
detected in the USGS well screened in the uppermost aquifer (USGS-02-3), located adjacent
to City Well #4, or in the uppermost monitoring wells north of the Site. These results are
consistent with the hydraulic control exerted by the convergence zone, which prevents
migration to the east and west, and to areas located directly north of the former warehouse.
Sample collection from the uppermost confining unit indicated a laboratory permeability of
10·8 cm/sec. For the area represented by the facility property, no connection between the
uppermost and second uppermost aquifer was indicated. South of the property, however,
the hydraulic relationship and the continuity of the layer is uncertain. Characterization of
the uppermost confining layer is described in Section 5.1.
No pesticides were detected in the second or third uppermost aquifers beneath the facility
property, which is the former source area. Pesticides were detected in the second
uppermost aquifer only at MW-llD, located about 375 feet south of the facility property
(Figure 1-4). The groundwater gradient at MW-llD is from the southeast.
Trichloroethene (TCE) was detected in the second uppermost aquifer in two on-site
monitoring wells (MW-6D at 160 ug/1 and MW-4D at 47 ug/1). TCE was also detected
upgradient (southeast) of the Site in two off-site private domestic wells (Allred at 72 ug/1
and PMP at 360 ug/1; Figure 1-4). TCE was not detected in soils or the uppermost aquifer.
Monitoring well PZ-1 was sampled twice during the RI. TCE was not detected the first
time and was below the quantitation limit (SJ) in the second sampling event. Also during
the RI, the onsite water supply well was sampled, but TCE was not detected.
Air sampling for pesticides adsorbed to particulate matter was conducted in February 1989,
prior to the initial soil removal. Airborne pesticide concentrations were found to be below
action levels. Two removal actions (1989 and 1991) have since occurred. Therefore, current
airborne pesticide concentrations would be even less than prior to the removal actions.
1.2 RD/RA REQUIREMENTS
Remedial Action requirements for the Site are specified in the Record of Decision (ROD;
August 27, 1992). Components of the remedy are summarized below:
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Groundwater Remedy
• extraction of groundwater across the Site in the upper and second uppermost aquifers
that exceed Performance Standards
•
•
on-site treatment of extracted groundwater using carbon adsorption
discharge of treated groundwater to the Moore County publicly owned treatment
works (POTW) or an infiltration gallery, as determined during Remedial Design
• continued groundwater monitoring.
Soils Remedy
• demolition of the former warehouse foundation and disposal at a municipal or secure
landfill
•
•
excavation of the top one foot of soils exceeding the Performance Standards
Stockpiled soils will be analyzed according to the TCLP. Soils that fail the TCLP
will be incinerated at an approved off-site facility. Soils that pass the TCLP will sent
to an approved hazardous waste landfill.
• backfilling, regrading and revegetation of excavated areas.
Additional Sampling and Monitoring
Additional sampling and analyses of the second uppermost aquifer to determine the extent
of pesticide contamination, and to determine if trichloroethylene (TCE) found in two wells
is Site-related.
Performance Standards for Site media are summarized in Table 1. 1.
Remedial Design requirements are defined in the Statement of Work (SOW) for the
RD/RA Consent Decree. This Remedial Design Work Plan addresses preparation of the
following documents described in the SOW:
• Preliminary Design (30%) Report
• Intermediate Design ( 60%) Report
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•
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1.3
Performance Standards Verification Plan
Prefinal (90%)/Final (100%) Design Report.
OBJECTIVES
The purpose of the Remedial Design Work Plan (RDWP) is to provide a detailed scope of
work and technical approach for the design of the remedy as set forth in the ROD. The
RDWP provides a description of the tasks to be completed, outlines the deliverables to be
submitted during the RD phase, and presents a schedule for completing the tasks and
submitting the deliverables.
The primary objective of Remedial Design is to establish the detailed engmeenng,
procedural and institutional requirements for the selected site remedy components. The
overall goal is to present an implementable design that is consistent with the requirements
of the ROD and the Consent Decree. Specific objectives during Remedial Design include:
• determination of data necessary for design through engineering pre-design field
activities
•
•
•
•
1.4
definition of the Site design basis
preparation of a conceptual (30%) design of the remedy components
preparation of an intermediate ( 60%) design, including a Performance Standards
Verification Plan
preparation of a pre-final (90%) and final (100%) design, including complete
. drawings and detailed specifications, a draft construction schedule, and a construction
cost estimate.
DOCUMENT ORGANIZATION
I The remainder of this report is organized into the following major sections:
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2.0 GROUND WATER EXTRACTION AND TREATMENT
3.0 SOIL EXCAVATION AND DISPOSAL
4.0 POTENTIAL REGULATORY REQUIREMENTS
5.0 PRE-DESIGN FIELD ACTIVITIES
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6.0
7.0
REMEDIAL DESIGN SUBMITTALS
PROJECT MANAGEMENT
Section 2 describes the information necessary for design of ground water extraction and
treatment systems for the uppermost and second uppermost aquifers. Section 3 describes
plans for design of the soil disposal, demolition and Site restoration activities. These two
sections address the primary components of the remedy.
Section 4 presents a plan for addressing potential permitting issues and requirements,
including determination of treatment requirements for groundwater prior to discharge.
Transportation and disposal considerations for Site soils are addressed as well as any local
limitations on use of the Site. Field activities necessary to define the basis for Remedial
Design are described in Section 5. · Implementation of the field activities is described in the
Sampling and Analysis Plan. As required by the SOW, Section 6 defines the content of the
required design submittals. Procedures for managing the design efforts and providing a
quality product are presented in Section 7. This section also includes a schedule for
Remedial Design through completion of the Remedial Action Work Plan and addresses
potential community relations support activities.
1.5 ADJUNCT DOCUMENTS
The RDWP describes the rationale and approach for development of the Remedial Design.
Specific methods and procedures for implementing field activities are contained in the
Sampling and Analysis Plan (SAP). Worker safety is governed by the Site-specific Health
and Safety Plan (HASP). These three documents (RDWP, SAP and HASP) are being
submitted to EPA as separate submittals. However, the three docurnents are interconnected
and must be employed together for implementation of Remedial Design. Descriptions of
the two adjunct documents (SAP and HASP) are provided below.
1.5.1 Sampling and Analysis Plan
The SOW requires the RDWP to include a SAP. The draft SAP is presented in a separate
document (RUST Environment & Infrastructure, August 1993) submitted to EPA
concurrently with the RDWP. The SAP includes a Field Sampling Plan (FSP) that describes
Geigy RDWP 1-8 November 5, 1993
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sampling locations, procedures and handling. The SAP also includes a Quality Assurance
Project Plan ( QAPP) that describes sample analysis, management, custody and data
validation. The SAP has been prepared in accordance with EPA Region IV Standard
Operating Procedures and Quality Assurance Manual (SOPQAM; February 1, 1991) and
Section IX of the Consent Decree (Quality Assurance, Sampling, and Data Analysis).
1.5.2 Health and Safety Plan
The SOW requires the RDWP to include a HASP. The draft HASP is presented in a
separate document (RUST Environment & Infrastructure, August 1993) submitted to EPA
concurrently with the RDWP. The HASP was prepared in accordance with the
requirements of OSHA.
Geigy RDWP 1-9 November 5, 1993
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~ • ,.v'r"''"'-----
·( ~~
l -N-
I
QUAORANGL( lOCAT1QN
1000 0 1000 2000 3000 40XI 5000 6000 7000 f[(T ======================= 5
CONTOUR l_NTERV_Al 10 FEET
RI lflllENVIRONMENT & l~IDI INFRASTRUCTURE
FIGURE 1-1
LOCATION MAP
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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' l !
' )
,)' / ................... .,.¼ ...
.• ~·
WOODS
.·•·-.... ~ · ....... 4-JS •• ,.,.,
NOTES,
0
TOPO MAPPING BY WOOLPERT CONSULTANTS BASED ON
AERIAL PHOTOGRAPt-N FLOWN MARCH 26, 1989 WITH
GROUND CONTROL TIED TO THE STATE PlANE COORDINATE
SYSTEM.
PLANIMETRIC FEATURES WERE flELD IDENTIFIED
ON MAY 18, 1989 BY WOOLPERT CONSULTANTS.
150' 300' 450'
N,\86619\6619GH01.DWG
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l~U>I liNFRASfRUCTURE
,_ .. ~--~~-----~·~-~-~
-= 4 70 _.. ... ~ •. -=--,
\
(
LEGEND
PAVED ROAD
DIRT ROAD = RAILROAD
FENCE
PROPERTY LINE
INDEX CONTOUR
PREVIOUS EXCAVATION
FIGURE 1-2
SITE PLAN
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAAOLINA
,_
o,._,,.. .., ;z :::;
~ "' ..,
I', ALLRED
"' PROPERTY a.
CAR PORT
AREA
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490
480
470
460
450
440
430
420
410
~ ii5 400
::;
t;: 390
~
z
Q 380
';i
Gi GJ 370
360
350
340
330
320
310
290
N:\86619\6619HG07.0WG
WEST
CITY OF ABERDEEN
MUNICIPAL WELL 64 USGS WELL
CLUSTER
(GS-02-02)
········~.-
~. 373
-~-
ROAD MW-13S
430.0.·
. ·,z
N"
·················:.·~-··············.·_;..,;·
_._. .. _._._._ ... _ ....... -~. 4J6.1·
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.426C.1 .
lZ
395.7 -· MEDIUM COMPACT TO COMPACT
SILTY AND ~ID rlNE TO C'8A.RSE SANO~ lZ
_-__ - _ -_ -_lU,._Bl!., _-_ -_ -_VERYSJ•FL-_ -_ -_ -_ -_ -_-_ -_ -
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480
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380
370
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-------------------------------------------------------------
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- - - - - - - - - - - - - --_-- - - ---~-..::_-~-=-:-=-=-=+=-=-=-=-=-~---=---=--=-=-,.=-;_.=-,.=--=--=-=--=-:-=-c,=--=-~~+=-----:--~~~ ----... --... . . ~ 360
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• •
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t28
STATIC WATER LfVEL 2 SCREENED W.TERlAL WITH ELEVATIONS
18
T0•157' WELL TOTAL DEPTH
0 1 60' .320' 480' ~-----~'-'------',-'-------
HORIZONTAL SCALE IN FEET
... 3S2.2 . ; .. ,. ~
.. •
APPROX ..
TD-140'·
COMPACT G1¥.VELL Y MEOl!fM ·
TO COARS£ 5'ND -
•
lfllll ... ENV][RONMENT&
1'-U>I INFRASTRUCTlUllIB
350
340
330
320
• • 310
300
290
FIGURE 1-3
HYDROGEOLOGIC PROFILE
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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CllY WELL #4
WOODS
LEGEND
~cs-02-2 GEOLOGICAL SURVEY WELL
~MW-75 MONITORING WELL
PRODUCTION ZONE WELL
GS-02-2
GS-02-1
GS-02-3
~MW-13S
APPROXIMATE LOCATION OF ALLRED WELL
0 200' 400' 600'
N,\86619\6619HG12.DWG
WOODS
PZ-1
WOODS
MW-
...
L MW-6S
-~ MW SS EXISTING
/MW-11D
PRODUCTION WELL
~MW-10S
MW-4S
MW-4D
WOODS
MW-1~
W(>ODS f
1/N..LRED 1 PROPERTY
METAL SHtD
NORTH
I'll .... ENVJ[RONMENT &
l~U:> I OORAS'fRUCTURJE
FIGURE 1-4
EXISTING WELL LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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CITY WELL #4
434
432
WOODS
430
LEGEND
432
434
02-~ \ s-02-3\
34.53
i-02-4'
"'«:::::~---GS-02-5
426
~GS-02-2 GEOLOGICAL SURVEY WELL
~MW-7S MONITORING WELL
~PZ-1 PRODUCTION ZONE WELL
~ SURFICIAL AQUIFER CONTOUR
(DASHED WHERE INFERRED)
150' 300' 450'
430
\
\
426
428
1Ds
\
MW 7S
~42 9 05
)
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\
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;i, MW-12S 427.77
MW-BS
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WOODS ---._____ ., MW-1 S
/.........._____ 432.5 ~
428 /A I I
/43~ / ~
W-4S
436.53
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/ 432 / 434
436
ftll .. ENVIRONMENT & l~U>I JINJFRASfRUCTURE
NORTH
434
/
wooj
438
_,,.,..---436
I
ALLRED PROPERlY
FIGURE 1-5
UPPERMOST AQUIFER
CONTOUR MAP
JULY 1991
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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D
-
CITY WELL #4
~GS-02-2
~MW-7S
~PZ-1
0
N:\86619\6619HG13.DWG
GS-02-2
GS-02-1 GS-02-3
GS-02-4
WOODS
LEGEND
GEOLOGICAL SURVEY WELL
MONITORING WELL
S -UPPERMOST AQUIFER
D -SECOND UPPERMOST AQUIFER
PRODUCTION ZONE WELL
SECOND UPPERMOST AQUIFER CONTOUR
150' 300' 450'
WOODS
MW-7S
~
~ MW-12S
WOODS
MW-9S
MW-8S
MW-2S
0
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0,
0,
fv)
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W-4D\
; 398.9
,,.
o,·
0, fv)
WOODS
I'll ...-ENVIRONMENT &
l~U>■ OORASTRUCTURE
NORTH
ALLRED
PROPERTY
FIGURE 1-6
SECOND UPPERMOST
AQUIFER CONTOUR MAP
SEPTEMBER 1991
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN. NORTH CAROLINA
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TABLE 1.1
PERFORMANCE STANDARDS
GEIGY CHEMICAL CORPORATION SITE
Compound
Aldrin
alpha-BHC
beta-BHC
delta-BHC
garnrna-BHC
Dieldrin
Endrin ketone
Toxaphene
DDD
DDE
DDT
alpha-Chlordane
gamma-Chlordane
Trichloroethene
Notes
NA -Not applicable
NC -Not calculated
Groundwater
(ugi'l)
0.05
0.05
0.05
0.05
0.05
0.1
0.1
1.0
NA
NA
NA
NA
NA
2.8
Ref.: Record of Decision (August 27, 1992)
Geigy RDWP
Soils
(mgi'.kg)
0.113
0.28
1.15
NC
1.5
0.13
NC
2.0
7.6
5.5
4.75
1.4
1.43
NA
November 5, 1993
-------------------
Aquifer
Uppermost
Aquifer
Second
Uppermost
Aquifer
TABLE 1.2
Summary of Groundwater Quality Analyses
Geigy Chemical Corporation Site
Compound Frequency of Average
Detection' Concentration (ug/1)
Alpha-BHC 6/12 4.0
Beta-BHC 6/12 4.8
Delta-BHC 6/12 4.5
Gamma-BHC 6/12 3.3
Aldrin 2/12 0.10
Heptachlor Epoxide 1/12 0.10
Dieldrin 3/12 0.29
4,4'-DDE 1/12 0.14
Endrin Ketone 5/12 0.53
Toxaphene 3/12 3.1
Alpha-BHC 1/6 2.7
Beta-BHC 1/6 1.2
Delta-BHC 1/6 0.71
Gamrna-BHC 1/6 1.9
Dieldrin 1/6 0.09
Endrin Ketone 1/6 0.11
Trichloroethylene 2/6 38
Note: Concentrations from the most current sample data available.
Number of detections/number of wells that were sampled.
Geigy RDWP
Maximum
Concentration (ug/1)
36
25
29
30
0.4
0.2
2
0.2
4
10
16
7
4
11
0.3
0.4
160
November 5, 1993
·I!!!!!!!! !!!!! --== liiiila: iiiii liiiii --· -· -.. - ----..
MW-1S 8-2-90 481.4
MW-10 10-8-90 482.0
MW-2S 8-10-90 472.7
MW-3S 8-7-90 459.7
MW-4S 8-22-90 470.8
MW-4D 9-25-90 470.8
MW-5S 8-17-90 468.2
MW-6S 8-14-90 462.1
MW-6D 9-18-90 462.6
PZ-1 10-4-90 462.7
MW-7S 5-31-91 449.6
MW-8S 6-3-91 460.7
MW-9S 6-4-91 469.6
MW-10S 5-29-91 459.1
MW-12S 5-30-91 444.7
MW-13S 6-5-91 447.2
MW-110 5-28-91 461.0
MW-14D 6-26-91 484.6
MW-15D 6-25-91 · 489.6
NOTES:
msl = mean sea level
bgl = below ground level
TABLE 1.3
MONITOR WELL CONSTRUCTION DETAILS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
484.04 63.4 0-10
484.83 109.3 0-7,0-65
475.52 55.5 0-10
462.26 42.0 0-10
473.47 39.3 0-10
473.99 95.2 0-9,0-52
471.34 44.3 0-10
464.71 44.4 0-10
465.49 89.1 0-9,0-48
465.65 132.7 0-10,0-50,0-99
451.89 26.6 0-9.8
462.72 40.5 0-9.5
471.71 48 0-9.5
461.48 39 0-9.7
447.33 20 0-10.1
449.74 24 0-9.5
463.41 73 0-8.5
486.87 102 0-9.8,0-67.8
491.03 104.3 0-9.5,0-71.8
51.3-61.3 430.1-420.1
87.1-107.1 394.9-374.9
43.3-53.3 429.4-419.4
29.8-39.8 429.9-419.9
27.2-37.2 443.6-433.6
73.0-93.0 397.8-377.8
32.1-42.1 436.1-426.1
32.2-42.2 429.9-419.9
66.9-86.9 395.7-375.7
110.5-130.5 352.2-332.2
16.2-26.2 433.4-423.4
27-37.1 433.7-423.6
34.6-44.5 435-425.1
26.8-36.5 432.3-422.6
9.6-19.6 435.1-425.1
13.6-23.8 433.6-423.4
59.4-69.6 401.6-391.4
88.4-98.3 396.2-386.3
90.9-100.7 356.3-388.9
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2.0 GROUNDWATER EXTRACTION AND TREATMENT
The ROD specifies groundwater extraction in the uppermost and second uppermost aquifers
with treatment using activated carbon. Treated groundwater will be discharged to the
POTW or an on-site infiltration gallery. The following sections relate the approach towards
design of the groundwater extraction and treatment systems. Groundwater discharge options
are described in Section 4.1. Design data will be collected during the pre-design field
activities, as discussed in Section 5. Results of the pre-design activities and a basis for
design of the groundwater remediation system will be presented in the Preliminary Design
Report (Section 6.1 ).
2.1 PRELIMINARY DESIGN BASIS
The design of the groundwater extraction system is initially based on the findings of the RI
and the evaluations conducted in the FS. Activities discussed in the pre-design section will
further define the objectives and limitations of the extraction system.
The two uppermost aquifers are included in the remedial design. Groundwater containing
Site-related pesticides will be extracted from both aquifers, while groundwater containing
TCE may be removed from the second uppermost aquifer.
2.1.1 Extraction Rates
Based on the preliminary modeling in the FS, there will be seven extraction wells in the
uppermost aquifer and two in the second uppermost for a combined flow of around 15-25
gpm. The uppermost aquifer is expected to yield about 2 gpm per well while the second
uppermost aquifer is expected to yield around 5-10 gpm per well. The aquifer tests to be
performed during the pre-design phase will provide a basis for defining well yields and the
number of extraction wells. The actual number of extraction wells and extraction rates will
be determined during Remedial Design.
Geigy RDWP 2-1 November 5, 1993
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2.1.1.1 Uppermost Aquifer
The low yields expected in the uppermost aquifer suggest that an electric centrifugal type
pump will be unacceptable for maintaining continuous drawdown. Due to the low flow rate,
cooling an electric motor would be difficult.
A pneumatic system will therefore most likely be used for the uppermost extraction wells
since pneumatic pumps generate no heat. Pneumatic systems are commonly used m
groundwater extraction systems and almost exclusively used in low flow situations. A
pneumatic system will require an air compressor on site which would be capable m
supplying all extraction wells with compressed air.
Jet pumps are also an option for groundwater extraction from wells are shallow and/or low
flow. For shallow well (less than 25 feet to groundwater) applications, jet pumps use suction
to lift groundwater. For intermediate depth wells (25 to 100 feet to groundwater), jet pumps
circulate water through a jet nozzle in the well to create a vacuum which removes the
groundwater. The jet pump, in the intermediate well application, must use most of its
energy .to create the jet in the nozzle which requires a larger pump motor and increases
energy usage. Since most of the extraction wells at the Site are anticipated to require lifting
groundwater more than 25 feet, jet pumps will most likely not be used. The final decision
of which type of pump to use will be made following the pre-design phase.
2.1.1.2 Second Uppermost Aquifer
The yields from the second uppermost aquifer are expected to be significantly higher than
that of the uppermost aquifer. This would allow the installation of either pneumatic or
electric type pumps. The most advantageous type will depend on the findings of the pre-
design activities as well as the design of the treatment system and will not be decided upon
until the design phase.
Geigy RDWP 2-2 November 5, 1993
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2.1.2 Chemical Composition
The design of an effective groundwater extraction system reqmres a knowledge of the
chemical composition of the groundwater. This includes knowledge of the chemical
compatibilities of the pump and associated hardware materials with the constituents of
concern as well as an understanding of the natural parameters of the groundwater.
The majority of the extracted groundwater (approximately 85%) may be from the second
uppermost aquifer, which means that TCE will most likely have the highest individual
concentration in the combined waste stream. Actual composition will depend on the final
design parameters and whether TCE must be extracted.
2.1.2.1 Pesticides
Pesticides are the pnmary constituent of concern in the groundwater. The blended
concentrations estimated in the FS based on concentrations in surrounding wells for the
individual pesticides in the groundwater extracted from the uppermost aquifer are:
Pesticide Concentration (ug/1)
alpha-BHC 27
beta-BHC 19
gamma-BHC 22
delta-BHC 22.5
toxaphene 7.5
dieldrin 1.5
endrin ketone 3
aldrin 0.1
These concentrations are most likely high since they represent equilibrium conditions which
will be disrupted upon start-up of the groundwater extraction system. Upon start-up,
groundwater velocity through the soil will increase allowing less of the pesticides to dissolve
in each unit of groundwater that flows past. Pesticide concentrations in the final combined
waste stream prior to treatment should also diminish due to the dilution provided by the
flow from the second uppermost extraction wells, depending on the extent of extraction in
Gei1,,y RDWP 2-3 November 5, 1993
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the second uppermost aquifer. Chemical compatibility difficulties with the extraction
equipment are not anticipated with the pesticides.
2.1.2.2 TCE
Chlorinated solvents can at high concentrations raise a concern of chemical compatibility
with piping and pump seals. TCE concentrations at the Site, however, have been less than
200 ppb and should pose no concerns, if TCE must be extracted.
2.1.2.3 General Parameters
General parameters of the groundwater are concerns mostly in operation and maintenance
of the extraction and/ or treatment system. Parameters that will be examined include:
• total organic carbon (TOC)
• hardness
• iron
• manganese
• alkalinity
• total suspended solids
• pH
Total organic carbon will help predict carbon usage at the site. Hardness is a measure of
the total divalent cations ( calcium, magnesium) in solution which can indicate the potential
for scale to form within treatment equipment. Total suspended solids will indicate the need
for filtration prior to carbon adsorption. The pH may effect the removal efficiency of the
carbon.
2.2 EXTRACTION WELLS
Extraction wells will be placed in the uppermost and second uppermost aquifers for the
removal of pesticides, based upon the results of the pre-design investigation. Extraction
wells may be placed in the second uppermost aquifer for the recovery of TCE, depending
on the results of the TCE delineation efforts (Section 5.2). The objectives of groundwater
Geigy RDWP 2-4 November 5, 1993
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extraction are to control the migration of pesticides and attain the Performance Standards.
It may become apparent, during the implementation or operation of the groundwater
extraction system and its modifications, that contaminant levels have ceased to decline and
are remaining constant at levels higher than the remediation levels over some portions of
the contaminated plume. In such a case, the system performance standards and/or the
remedy may be reevaluated as described in Section X.A of the ROD.
Placement of the extraction wells and required flow rates will be determined through results
of the pre-design field activities and groundwater modeling. Pre-design activities that affect
the placement of extraction wells include:
•
•
•
•
•
water level measurements (Section 5.1.1)
resampling of select wells (Section 5.1.2.1)
aquifer sampling using direct push methods (Sections 5.1.2.2 and 5.4)
aquifer testing (Section 5.1.4)
sampling of additional monitoring wells (Section 5.1.3)
Water level measurements will be used to confirm the aquifer flow patterns. Resampling of
existing wells coupled with direct push sampling will define the extent of the aquifer that
exceeds Performance Standards. Aquifer testing will define the hydraulic properties
necessary to design an interactive extraction system (e.g., transmissivity, storativity).
Groundwater characterization activities are described in Section 5.1. Results of the
pre-design activities will be presented in the Preliminary Design Report, as required by the
sow.
The uppermost and second uppermost aquifers have distinctly different properties (Section
1. 1 ), which will affect design of the extraction system. The shallow saturated thickness and
low hydraulic conductivity of the uppermost aquifer indicate that water yields will be low.
Sustained yields are estimated to be approximately 2 gpm per well. The second uppermost
aquifer has a greater saturated thickness and hydraulic conductivity. Accordingly, the yield
will be higher than for the uppermost aquifer. Sustained yields for the second uppermost
aquifer are estimated to be approximately 5 to 10 gpm per well. Actual well yields will be
established in the Preliminary Design Report.
Geigy RDWP 2-5 November 5, 1993
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Design of the extraction system will consist of the following elements:
• extraction well locations and flow rates
• well screen and filter pack specifications
• pump and piping system
• well head equipment and monitoring capability.
Based on the anticipated hydraulic properties and aquifer flow regime, analytical modeling
( e.g., Wellhead Protection Area (WHPA), USEPA Office of Groundwater, April 1992) will
be used to evaluate groundwater flow and extraction well capture zones for each aquifer.
The specific groundwater model(s) will be determined following review of the aquifer test
results and determination of aquifer properties. The name(s) of the groundwater models
used to design the extraction system will be provided to EPA once identified. Locations and
flow rates of extraction wells will be presented in the Preliminary Design Report.
Design of a groundwater extraction system will be more straightforward if discharge is to
the POTW. An infiltration gallery will serve as a point of recharge to the aquifer(s) that
will be addressed in the modeling. A higher extraction rate could be required to control the
additional groundwater flow generated by an infiltration gallery.
Design of the well screen and filter pack will be based on the required flow rates, chemical
compatibility, anticipated duration of extraction activities, and the aquifer geological
materials. Flow rates will be defined by the modeling. Contaminant and hardness
concentrations are relatively low. Chemical compatibility is not expected to be a concern
but this will be confirmed following review of the resampling results. The ROD estimates
extraction to continue for a period of at least 30 years during which time the system's
performance will be carefully monitored on a regular basis (Section 2.5) and adjusted as
warranted by the performance data collected during operation (Section 2.6). Grain size
analyses of the saturated soils will be conducted during the pre-design efforts for selection
of the optimal screen slot size and filter pack materials.
The piping system will be designed for the maximum anticipated flow rates, anticipated
loads, and frost protection. Design of the pumping system will consider the maximum
anticipated flow rates, head losses, network losses, and cycling requirements. The low flow
Geigy RDWP 2-6 November 5, 1993
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rates of the uppermost aquifer will likely require a pneumatic pump or jet pump system.
Extraction from the second uppermost aquifer will likely use a jet pump or standard electric
submersible pump system. Actual pumping systems and the rationale for their selection will
be presented in the design documents.
Well heads are placed at the surface of the extraction well to allow for monitoring of
operating parameters and periodic equipment inspection. Parameters to be monitored
typically include instantaneous flow rate, total flow rate, outlet pressure, and water level.
Operating parameters can be read manually or automatically at a remote location using a
data acquisition system, Design of the well heads and the degree of automation will be
presented in the design documents.
2.3 PRETREATMENT.
The primary treatment for the extracted groundwater is carbon adsorption. Any
pretreatment would be to assist the carbon in its treatment task whether through the
removal of some carbon limiting compound or by adjusting one of the general water
parameters such as pH, hardness, or suspended solids.
The first stage of the treatment process is the combining of the groundwater extraction well
flows into one stream in an equalization tank. This serves many purposes. Flow is combined
so that the carbon feed pumps see more of a uniform flow from the extraction system.
Suspended solids are allowed to settle out. This also provides a convenient location where
pH may be adjusted to increase the effectiveness of subsequent treatment. Any direct
removal of hardness would occur following equalization. The need for hardness removal
and associated treatment will be specified in the Preliminary Design Report.
Filtration for suspended solids will also most likely be required immediately prior to carbon
adsorption. Filtering down to 5 to 10 microns is commonly recommended by carbon
suppliers. This usually indicates the use of bag type filters placed in parallel to allow
cleaning of one without interrupting system operation.
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2.4 ACTIVATED CARBON
Granular activated carbon ( GAC) adsorption is the best available technology for treatment
and removal of pesticides. This technology was identified in the ROD as the selected
remedy for treatment of extracted groundwater. A majority of design parameters for a full
scale activated carbon system will be developed during the pre-design phase. Parameters
to be evaluated include:
• standard pretreatment (filtration, pH adjustment) requirements
• adsorbent type
• empty bed contact time (EBCT)
• breakthrough characteristics
• column configuration and flow pattern
• contact vessel pressure requirements
• pressure drop across the vessels
• effluent requirements
• saturation capacity or carbon exhaustion rates
• regeneration requirements
• handling/ storage of regenerated and spent carbon
• utility requirements
Pretreatment requirements will be evaluated following review of the general groundwater
chemistry parameters and resolution of whether TCE is site-related. Activated carbon
treatment parameters will be presented in the Design Criteria Report portion of the
Preliminary Design Report.
2.5 PERFORMANCE MONITORING
The ROD requires long-term monitoring of groundwater during remediation. Monitoring
of groundwater extraction systems consists of periodic hydraulic evaluations and chemical
analyses. Hydraulic control is necessary to ensure that the required capture zones have
been achieved. Water level measurements are used to generate potentiometric surfaces,
which indicate the capture zone effectiveness.
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Chemical analyses are used to compare groundwater concentrations to Performance
Standards. Attainment of Performance Standards in groundwater systems is typically a
protracted process. Site pesticides have Performance Standards that are 1 ug/l or less and
tend to adsorb to particulate matter in aquifers. These factors suggest a lengthy restoration
period for Site groundwater. The ROD estimates a period of at least 30 years. For such
a duration, the frequency of chemical analyses can be reduced so long as hydraulic control
is maintained.
Groundwater monitoring is to continue for an unspecified period following discontinuation
of extraction, either after the Performance Standards are attained or if it is determined that
attainment of the Performance Standards is technically impractical. The period of continued
monitoring will be based on statistic'ally-based trends derived from historical data.
Performance monitoring for the treatment system will be based on the conditions set in the
POTW pretreatment agreement or the infiltration permit equivalency. Monitoring will
consist of periodic sampling of the effluent for specified treatment parameters ( e.g.,
pesticides), which may vary depending on the method of discharge.
Performance monitoring for the groundwater extraction system will be presented in the
Performance Standards Verification Plan (PSVP). Performance monitoring for the
treatment system will be specified in the Operation and Maintenance Plan (O&M Plan).
In accordance with the SOW, the O&M Plan will be prepared at the 30 percent construction
stage.
2.6 LONG-TERM EVALUATION
The ROD allows for re-evaluation of the groundwater remedy if contaminant levels show
no significant decrease at levels exceeding the Performance Standards. Modifications to the
extraction system may include:
• alternating pumping wells to remove stagnation points
• pulsing of the extraction at individual wells to allow
contaminants into solution
• installation of additional extraction wells .
Geigy RDWP 2-9
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Design of the extraction system will consider these potential modifications. For example,
heavy duty starters may be specified for pump motors to allow for the cycling that would be
required during pulsing. Extraction wells will be located to minimize the potential for
stagnation effects.
The system will be evaluated through statistical review of chemical monitoring data. A
monitoring program to assess the attainment of groundwater Performance Standards will be
presented in the PSVP. The program will evaluate the latest analyses with respect to
historical trends to determine whether statistically significant decreases in contaminant
concentrations are occurring. The decision to invoke the provisions of Section X of the
ROD may be made during a periodic review of the remedial action, which occur at intervals
of at least every five years. The provisions in Section X of the ROD allow:
• additional gradient controls, such as low flow pumping at the perimeter of
contamination
•
•
•
•
waiver of chemical-specific ARARs
institutional controls to limit potential future uses of the aquifer(s)
continued monitoring of select wells
periodic re-evaluation of alternate technologies .
Any modifications to the Performance Standards will be established in an Explanation of
Significant Difference or an Amendment to the ROD.
2.7 TCE EVALUATION
The ROD states that TCE is considered to be Site-related until proven otherwise. TCE was
not found in the soils or the uppermost aquifer at the Site. TCE was only found in the
second uppermost aquifer, at wells MW-4D and MW-6D. The Black Creek confining unit
exists between the Site and these wells and no pesticides were detected in these wells. TCE
was found in the Allred well, which is located immediately east of the Site and upgradient
of wells MW-4D and MW-6D. TCE was not detected in wells MW-14D and MW-15D,
which are located between the Allred well and the wells MW-4D and MW-6D. The
concentration of TCE detected in well MW-6D (160 ug/1) is higher than that in the Allred
well (72 ug/1). TCE was also detected in the upgradient Powder Metal Products (PMP)
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production well (located approximately 1/2 mile east of the Site). The PMP well has the
highest level of TCE (360 ug/1) found in the Site area.
Because of the possibility of an upgradient source, upgradient monitoring wells such as
MW-14D, MW-15D, MW-16D (proposed well), and·MW-17D (proposed well) will be
sampled periodically for TCE. Sampling of the upgradient wells would be part of the
long-term monitoring program. Upgradient sampling requirements will be presented in the
O&M Plan. Monitoring results from the upgradient wells will be evaluated with respect to
any modifications to the extraction system. Proposed modifications to the extraction system
would be presented to EPA.
TCE and pesticides are not found in the same locations in the second uppermost aquifer.
As an alternate approach, separate extraction and treatment systems may be designed for
TCE and for pesticides. The determination of whether separate remediation systems will
be designed will be presented in the Preliminary Design Report.
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3.0 SOIL EXCAVATION AND DISPOSAL
Soil remediation requirements are given by the ROD. The warehouse foundations will be
demolished and confirmation testing will be conducted on the debris as required by the
receiving facility. If testing results are acceptable, the debris will be landfilled at a
municipal landfill. Actual disposal requirements will be determined during Remedial
Design. After the warehouse foundations are demolished, the top foot of soil exceeding the
Performance Standards (Table 1.2) will be excavated and stockpiled at the Site. Stockpiled
soils will be analyzed for pesticides using the toxicity characteristic leaching procedure
(TCLP). Soils failing the TCLP test will be considered hazardous by characteristic and
incinerated at an off-site facility to satisfy land disposal restrictions (LDR). Soils passing
the TCLP will be sent to a RCRA-approved landfill.
Attainment of the remediation levels will be established through implementation of the
Performance Standards Verification Plan. Excavated areas will then be covered with clean
fill and revegetated with a perennial grass. The Site will be fenced and have adequate
warning signs to control unauthorized access.
Design requirements for soil excavation and disposal are described in the following sections.
Following excavation, confirmation sampling will be conducted in accordance with the
Performance Standards Verification Plan (Section 6.3) to ensure that remedial levels are
attained.
3.1 PRELIMINARY DESIGN BASIS
A total of 167 soil samples have been analyzed at the Site (Appendix A). Of these, 72
locations currently exceed the Performance Standards set for the upper foot of soils. The
total volume of soils to be excavated based on existing data and arithmetic calculations is
approximately 1,600 cubic yards (CY). This volume may change depending on additional
soil analyses (Section 5.5) and implementation of the Performance Standards Verification
Plan (PSVP; Section 6.3).
The TCLP will be used to determine whether stockpiled soils will be incinerated or
landfilled. The only compounds in Site soils to be excavated that are included under the
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TCLP are lindane (gamma-BHC) and toxaphene. TCLP leachate limits for these
compounds are 0.4 mg/I and 0.5 mg/I, respectively. Approximately 1,600 cubic yards of soil
are to be excavated at the Site. Actual disposal requirements will be based on TCLP
measurements of stockpiled soils.
3.2 EXCAVATION
The primary design requirement will be to determine the areal extent of excavation at the
Site. The depth of excavation is set by the ROD as one foot. The extent of excavation will
be based on existing data collected during the RI and previous removal actions and
additional data to be collected during the pre-design field efforts (Section 5.5). Excavation
requirements will also consider implementation of the PSVP. The PSVP will specify the
sampling frequency, methodology, and data interpretation used to determine whether the
Performance Standards have been attained. Since the PSVP will be submitted with the
Intermediate Design, excavation plans will be submitted with the Prefinal Design.
Excavation to a depth of one foot presents no technical concerns. Additional geotechnical
information is not necessary. Special access and construction procedures may be required
when excavating near the highway and on off-Site property. For example, the State
right-of-way extends into the area of excavation along the highway. Any additional
requirements for this work in rights-of-way or on off-Site areas is discussed in Section 4.4.
Excavation along the railroad tracks must consider the following:
• scheduling around train traffic
• use of flagmen
•
•
•
•
•
railroad permit requirements
notification procedures
stability of the tracks during and after excavation
replacement of ballast
maintaining drainage away from the tracks .
Track construction and maintenance requirements are set by the Federal Railway
Administration (FRA). FRA regulations govern the tracks, ballast, crossings and the
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drainage ditches on either side of the tracks. The Interstate Commerce Commission. (ICC)
governs railroad service and schedules. The Aberdeen & Rockfish railroad runs two trains
a day, five days a week past the Site. Excavation within the drainage ditches will conform
with FRA requirements.
Soils will be stockpiled at the Site following excavation. Stockpiled soils will be analyzed
using the TCLP. Stockpiles will be maintained during the analytical turnaround time to
minimize any air dispersion or run-off. Stockpiles will be located in areas that facilitate
loading and transportation. Analytical and stockpiling procedures will be specified in the
Remedial Design.
3.3 TRANSPORTATION
Transportation to the off-site facilities will be by truck and/ or rail. The Site allows for easy
access for trucks off of State Highway 211 and for rail cars off of the Aberdeen & Rockfish
(A&R) rail line. Transportation would have to comply with EPA's "off-site policy" (OSWER
Dir. 9834.11) and Paragraph 14 of the Consent Decree.
Transportation by truck would likely involve 20 CY roll-off containers. For the estimated
volume of 1,600 in-place CY, a minimum of 80 truck loads would be required.
Transportation by truck must consider the following:
• driver training and vehicle inspection requirements
• U.S. and North Carolina Department of Transportation regulations
• RCRA manifesting, placarding and packaging requirements, for characteristically
hazardous wastes
• notification of the Fayetteville (NC) Hazmat unit
• on-site weigh station (existing scales or temporary unit)
• Federal and North Carolina highway weight limitations
• turning radii and grades must accommodate haul vehicles
• dust control measures
• travel routes must have appropriate lane widths, bridge weight limits, sight distances,
and turning radii
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• travel routes should avoid congested areas, residential areas and school zones to the
extent practicable
• provide loading areas outside of contaminated areas to minimize or eliminate the
need to decontaminate vehicles leaving the site
• scheduling and approvals from the receiving facility .
The on-site weigh station was calibrated and used for the 1991 removal action.
Acceptability of the on-site weigh station for truck transportation will be determined during
Remedial Design.
Transportation by rail would likely involve fixed-bottom gondola cars. These cars are
approximately 50 feet long by 8 feet wide by 6 feet high and can carry approximately 80 CY.
For the estimated volume of 1,600 in-place CY, a minimum of 20 rail cars would be
required. Transportation by rail must consider the following:
• coordination with other rail traffic
• FRA and ICC requirements
• RCRA manifesting, placarding and packaging requirements, for characteristically
hazardous wastes
• scheduling and approvals from the receiving facility
• real-time tracking.
The most appropriate method of transportation will depend on the volume of soils, the
location and access restrictions for the receiving facility, carrier availability, and cost.
Transportation options will be evaluated during Remedial Design.
3.4 DISPOSAL
Excavated soils will either be incinerated or landfilled at an off-Site facility. Which soils are
to be incinerated and which are to be landfilled will be determined following TCLP analysis
of the stockpiled soils. Receiving facilities will be selected during Remedial Action,
following review of contractor bids.
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Landfilling of soils would occur at a RCRA Subtitle C facility. The ROD states that debris
from demolition of the foundation will be landfilled at a municipal or secure landfill,
following confirmation testing. Debris will be sampled for toxaphene and gamma-BBC
using the TCLP. Debris passing the TCLP will be sent to a Subtitle D landfill ( e.g.,
Kernersville, NC landfill). Debris failing the TCLP will be sent to a Subtitle C facility (e.g.,
Grassy Mountain Facility, Clyde, Utah landfill) with the soils.
3.5 DEMOLITION
The remaining building foundations will be demolished prior to sampling and landfilling.
Demolition of the eastern foundation did not encounter any rebar. The absence of rebar
will make demolition of the remaining foundation less complicated. Demolition will be a
lead item, to limit any contamination of the foundation from other construction activities.
The specifications for demolition will consider the following:
• OSHA requirements
•
•
•
•
•
3.6
sealing and abandonment of any existing utilities
protection of utilities to remain in service
maximum allowable size of debris
stockpiling and sampling of debris
decontamination .
REVEGETATION/FENCING
Clean fill will be placed at the Site following confirmation that the soil Performance
Standards have been attained. Requirements for backfill, including chemical screening for
pesticides, will be presented in the specifications. A borrow survey will be conducted prior
to Remedial Action to identify sufficient quantities of suitable clean fill. The Site will be
revegetated with perennial grasses adapted to the area. The local Soil Conservation Service
office will be contacted for recommended low maintenance grasses. Erosion control
measures will be evaluated during Remedial Design for maintenance of the vegetated fill.
A method of controlling or diverting storm water run-on from the east will be included in
these erosion control measures.
Geigy RDWP 3-5 November 5, 1993
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Following removal of the soils exceeding Performance Standards, the Site will be protective
of human health. A fence will still be placed around the property, however, to protect the
groundwater remediation system and to deter unauthorized access. The adequacy of the
existing fence will be evaluated during Remedial Design'. Requirements for fencing and
warning signs will be presented in the specifications.
Geii,,y RDWP 3-6 November 5, 1993
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4.0 POTENTIAL REGULATORY REQUIREMENTS
On-site CERCLA actions are exempt from the administrative requirements of permits
(SARA 121(e)(l)). Substantive requirements would still have to be met. The majority of
Site remedial activities will involve off-site elements, however. Off-site actions must meet
all administrative and substantive requirements. Local use restrictions may also apply to
remedial activities at the Site. Potential regulatory requirements for the identified remedial
activities and their impact on design are discussed below.
4.1 GROUNDWATER DISCHARGE
The ROD states that discharge of treated groundwater will be either to the Moore County
Sanitary Sewer Authority (MCSSA) or an infiltration gallery. The discharge method will be
determined during Remedial Design. Anticipated regulatory and design requirements for
discharging to the MCSSA and to an infiltration gallery are described below.
4.1.1 Moore County POTW
Discharge of treated groundwater to the Aberdeen sewer system and subsequent by the
Moore County POTW is the first of two discharge options that will be explored. This option
was first examined during the FS in late 1991 and appears to be a viable option. Current
information has recently been requested by RUST E&I but has not yet been received.
Under this option, the treated groundwater would be metered and then piped to the closest
manhole via a PVC conduit. The meter is usually selected from an approved list provided
by the sewer authority. The PVC line with provisions for sample collection would have to
be constructed from the treatment facility to the manhole.
Potential areas that may impact the design are:
• discharge limits (both flow and constituent concentrations)
• BOD level
•
•
hydraulic capacity in the sewer line and at the receiving facility
flow metering requirements
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•
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discharge sampling methods and schedules
manhole tie-in specifications
required parameters to monitor
construction and long-term operating costs
crossing the railroad tracks
crossing Highway 211
4.1.2 Infiltration Gallery
The State of North Carolina has regulations in place governing the design and construction
of infiltration galleries. These criteria will be fully examined prior to the selection of a
treated groundwater discharge option. The primary issues are described below.
Under this option, all treated water would be evenly distributed through a gallery and
allowed to infiltrate down through the soils back to the aquifer. The infiltration system
would be located up-gradient of the extraction system to form a "closed-loop", as currently
required by the state of North Carolina. North Carolina additionally requires that treated
groundwater distributed to areas within the contaminant plume show 95% removal of
contaminants or if discharged to areas outside the plume, the attainment of groundwater
quality standards.
Parameters affecting selection of infiltration galleries as the discharge option are:
• hydraulic capacity of the soils (especially important due to small areal size of this
site)
• total flow from treatment system
• chemistry of the soils recharge effect upon the extraction system
• construction and long-term operating costs
• any quality and quantity impacts to potential groundwater users.
Infiltration tests will be conducted during the pre-design phase (Section 5.5).
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4.2 GROUNDWATER TREATMENT RESIDUALS
Groundwater treatment will produce spent activated carbon. Activated carbon will contain
pesticides and may contain TCE. Based on anticipated flow rates and chemical
concentrations, a standard 200 pound carbon canister should last approximately two years
before it has to be replaced. Carbon that failed the TCLP would be regenerated or
incinerated. Specific options will be evaluated at the time of disposal based on analyses of
the carbon and available disposal/regeneration capacity.
Shipment of spent carbon off-site would have to comply with the following:
• U.S. and North Carolina Department of Transportation requirements
• RCRA land disposal restrictions
• EPA's off-site policy (OSWER Dir. 9834.11)
• profile analysis and acceptance by a permitted TSD facility .
Shipment of spent carbon would not have to comply with Paragraph 14 of the Consent
Decree since the volume would be less than 10 cubic yards.
Particulate matter may be collected in the equalization tank or a bag filter upstream of the
carbon system. Particulates would consist of sands and other aquifer materials generated
from the extraction wells. The well screen and filter pack will be designed to minimize the
production of particulates. Any particulates that are produced. would be representative of
groundwater concentrations and have low ( < 1 mg/kg) contaminant levels. The initial
accumulation of any particulate matter would be analyzed for pesticides. Particulate matter
that met the soil removal Performance Standards would be replaced at the Site. Matter
· exceeding the Performance Standards would be sent to an appropriate off-site disposal
facility based on TCLP testing.
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4.3 SOIL DISPOSAL
Disposal involves the excavation, transportation, landfilling and potentially incineration of
surficial soils exceeding the Performance Standards. Potential regulatory requirements
pertaining to these activities are described below.
4.3.1 Excavation
North Carolina requires submittal of an erosion control plan when there will be disturbance
of more than one continuous acre. The entire Geigy. property is approximately 0.95 acres
and the area of excavation is even less. An erosion control plan will therefore not have to
be submitted to the State. The specifications will still specify erosion control measures that
minimize run_-on and run-off during construction activities.
Stockpiles of excavated soil will be analyzed for toxaphene using the TCLP. The location(s),
design and management of the stockpiles will be presented in the Remedial Design. Factors
to be considered include:
•
•
•
•
placement of the stockpiles with respect to excavation of the underlying soils
control of windblown particulate emissions
control of run-on, run-off, and leachate from the stockpiles
access to truck and/ or rail traffic for transportation .
4.3.2 Transportation
Transportation of excavated soils will be by truck and/ or rail. Truck traffic will be governed
by U.S. ( 49 CFR 171-173) and North Carolina Department of Transportation requirements.
Rail traffic will be regulated by the Federal Railway Administration and Interstate
Commerce Commission requirements. Soils that are characteristically hazardous will have
to comply with RCRA manifesting requirements.
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4.3.3 Landfilling
Soils that pass the TCLP will be landfilled a RCRA Subtitle C facility. Debris from
demolition of the concrete foundation will be sent to a RCRA Subtitle D facility, following
confirmation testing. Debris failing the TCLP will be sent to a Subtitle C facility with the
soils. Disposal of soils and debris would have to comply with EPA's "off-site policy"
(OSWER Dir. 9834.11) or any modifications, Section 300.440 of the National Contingency
Plan, and Paragraph 14 of the Consent Decree. The design specifications will set standards
that a receiving facility must meet to be considered acceptable. At a minimum, a Subtitle
C facility must meet the following requirements:
• permitted to accept waste type
• no relevant violations at the receiving unit
• no current releases and previous releases must have been addressed
• releases at other units must have been addressed.
Disposal requirements for local Subtitle D landfills will be established during Remedial
Design. The Companies may impose additional requirements on the receiving facilities
based on their corporate standards.
4.3.4 Incineration
Soils that fail the TCLP will be sent to an off-site RCRA incinerator. Incineration of soils
would have to comply with EPA's "off-site policy" (OSWER Dir. 9834.11), Section 300.440
of the National Contingency Plan, and Paragraph 14 of the Consent Decree. The
Companies may impose additional requirements on the receiving facilities based on their
corporate standards.
4.4 LOCAL REQUIREMENTS
Since the Geigy property is less than one acre, much of the remedial activities will require
activity close to and across current property boundaries to fully remediate the Site. This will
result in the encroachment onto private property and into existing right-of-ways.
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4.4.1 Rights-of-Way
Several existing right-of-ways could restrict activities on the Site. Any activity within these
limits will require prior notification of the appropriate party and possibly permitting. The
right-of-ways are defined from each side of the center line as follows:
Highway 211: 50 feet
Railroad: 80 feet
Power line: 20 feet
The existing right-of-ways will be confirmed as part of the pre-design activities. Any
discrepancies will be noted in the Preliminary Design Report.
4.4.2 Access Agreements
The pre-design activities scheduled for groundwater characterization and the TCE
delineation will require access to properties surrounding the Geigy site. Continued
monitoring of site groundwater will also require access. to surrounding properties on a
regular basis. Access agreements will therefore have to be established for immediate and
long-term future use.
Access agreements for the Johnson and Upchurch properties have been in place for previous
site investigative activities, however, it does not appear that these agreements allow for
"continuing" use. Therefore, new agreements will most likely have to be obtained. The
existence of the previous agreements should simplify the process.
The need for access agreements will be established following EPA approval of the Remedial
Design Work Plan. In accordance with Paragraph 27 .of the Consent Decree, the Companies
will define the type and extent of access that is required to implement the Remedial Design
Work Plan and initiate access negotiations. The Companies shall notify EPA if access
cannot be obtained and provide a summary of the measures taken to obtain access.
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5.0 PRE-DESIGN FIELD ACTIVITIES
Additional data must be collected for design of the soil and_ groundwater remediation
systems. Pre-design field activities necessary to satisfy data needs and provide the basis for
Remedial Design are described in the following sections. Results of the pre-design activities
will be presented in the Preliminary Design Report.
The Sampling and Analysis Plan addresses procedures and methodologies for
implementation of pre-design activities. The Health and Safety Plan addresses potential
health effects and worker safety requirements during implementation of the pre-design field
activities.
5.1 GROUNDWATER CHARACTERIZATION
Pre-design groundwater characterization efforts will include obtaining an additional round
of water level measurements and groundwater samples from select wells and/or sample
locations. This information will be used to further define the portions of the uppermost and
second uppermost aquifers requiring remediation. Groundwater characterization efforts will
also include the performance of aquifer tests in the uppermost and second uppermost
aquifers to determine hydraulic parameters needed for design of the extraction system(s).
A discussion of the objectives of these characterization efforts is presented below
5.1.1 Water Level Measurements
Initial groundwater characterization efforts will include obtaining a complete round of water
level measurements from all Site monitoring wells and USGS well cluster GS-02. Data from
the water level measurements will be used to produce potentiometric maps for the
uppermost and second uppermost aquifers, confirm groundwater flow directions previously
determined during the RI, and adjust the locations of additional monitoring wells and/ or
groundwater sampling locations. An additional round of water-level measurements will be
collected following the installation of additional monitoring wells and well point
piezometers.
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5.1.2 Groundwater Sampling
Pre-design field activities will include the collection and analysis of additional groundwater
samples to confirm the distribution and concentration of pesticides previously determined
during the RI, to further delineate the extent of pesticides in the uppermost and second
uppermost aquifers, and to determine if the presence of TCE in the second uppermost
aquifer is Site-related. Groundwater samples will also be collected to study the effect of any
upgradient pesticides on the extraction system in the second uppermost aquifer. This effort
will be accomplished through the collection of samples from existing wells, through the
collection of in-situ groundwater samples using direct push methods, and through the
installation of additional monitoring wells.
Results of previous sampling activities indicate that the extent of pesticides in the uppermost
aquifer to the east, west and north has been defined and is largely limited to the area of
former site activity. The southern extent of pesticides in the uppermost aquifer is not
completely delineated and will be addressed through the groundwater sampling activities
outlined below. Results of previous sampling activities indicate that pesticides are present
in the second uppermost aquifer in the vicinity of well MW-11D; however, the extent of this
contamination is not completely delineated. Groundwater sampling activities will therefore
also be conducted to assess the extent of pesticide contamination in the second uppermost
aquifer. In addition, groundwater sampling will be conducted to determine if the presence
of TCE and pesticides in the second uppermost aquifer are due to an off-site source.
5.1.2.1 Wells
Groundwater samples will be collected from selected existing Site monitoring wells and off-
site private wells to confirm the concentration of pesticides and TCE previously detected
at the Site and to determine the need for additional monitoring wells and/ or groundwater
sample locations. Field activities will include:
• resampling of wells MW-2S, MW-3S, MW-4S, MW-5S, MW-6S, and MW-lOS for
TCL pesticides;
• resampling of wells MW-11D, MW-14D and MW-15D for TCL pesticides;
• resampling of wells MW-4D, MW-6D, MW-14D and MW-15D for TCE; and
Geigy RDWP 5-2 N.ovember 5, 1993
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• resampling of upgradient off-site wells at the Allred and PMP properties for TCE.
Groundwater samples will be collected immediately following completion of water level
measurements and will be obtained following the procedures described in the SAP.
Collection of groundwater samples from the Allred and PMP properties will be contingent
upon the establishment of access agreements. Groundwater samples will not be collected
from monitoring wells MW-lS, MW-10, MW-7S, MW-SS, MW-9S and MW-13S as these
sampling locations were previously shown to be unimpacted by former Site activities.
Sample analyses for the uppermost aquifer will be conducted using US EPA Level III data
quality objectives and corresponding analytical methodologies. Sample analyses for the
second uppermost aquifer will be conducted using US EPA Level IV data quality objectives
and corresponding analytical methodologies.
5.1.2.2 Direct Push Methods
Results of groundwater samples obtained during the RI indicate that pesticides are present
in the uppermost and second uppermost aquifers at wells MW-lOS and MW-110,
respectively. The extent of pesticide contamination at this portion of the site (i.e., south of
the Aberdeen and Rockfish Railroad) is presently undefined. Additional information on the
extent of pesticide contamination at this portion of the Site will be obtained using direct
push methods whereby groundwater samples are obtained by hydraulically advancing a
sealed sampling device into the formation, opening the sampling device and allowing the
sample chamber to fill under static conditions, and retrieving the device to surface to collect
the sample. The primary benefit of this approach is that, relative to monitoring well
installations, it allows multiple locations within an aquifer (both laterally and vertically
segregated) to be sampled in a timely and cost effective manner. Results of the
groundwater sample analyses will be used to site locations for additional monitoring wells
in the second uppermost aquifer as needed to define the extent of pesticides.
If direct push technology methods are unable to penetrate the uppermost confining unit,
conventional rotary drilling methods will be used to install a surface casing within the
uppermost confining unit. The direct push borings will then be installed through the surface
casing and into the second uppermost aquifer. Upon receipt and validation of analytical
data, and following determination that a monitoring or extraction well will not need to be
Geigy RDWP 5-3 November 5, 1993
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installed in a surface casing, surface casings will be tremie grouted to surface. In the event
the uppermost confining unit is penetrated by the direct push technology tools, the direct
push borings will be abandoned using grout tremied from the bottom of the boring to the
surface immediately upon removal of the direct push tools.
Proposed direct push groundwater sample locations for both the additional pesticide and
TCE characterization efforts are shown on Figure 5-1. Procedures for obtaining direct push
groundwater samples are presented in the SAP. Chemical analyses for the direct push
groundwater samples are presented in Table 2.1 of the SAP.
5. 1.3 Additional Monitoring Wells
Following re-sampling of the existing site monitoring wells and completion of direct push
groundwater sampling efforts, analytical results will be reviewed and used to determine the
number and locations of additional monitoring wells, if any, to be installed in the second
uppermost aquifer. At present, one additional monitoring well (MW-18D) is anticipated to
be installed in the second uppermost aquifer to provide further hydrogeologic data. Based
on available site potentiometric data, this well is anticipated to be installed approximately
midway between existing wells MW-11D and MW-13S. The proposed well location is shown
on Figure 5-2.
In addition to the above, two wells (MW-16D and MW-17D) are anticipated to be installed
in the second uppermost aquifer at locations hydraulically upgradient of the Site for the
purpose of monitoring the potential on-site migration of pesticides and TCE from an off-site
source. Based on available site potentiometric data, these wells are anticipated to be
installed immediately south of the Aberdeen and Rockfish Railroad and east of the gravel
road which transects the Site. Proposed well locations are shown on Figure 5-2.
Table 5.1 provides the rationale for the proposed monitoring well locations as well as the
rationale for the proposed aquifer test wells. Actual locations for the additional monitoring
wells will be submitted to US EPA for approval prior to installation. Well construction
methods and sampling will in conducted in accordance with the procedures presented in the
SAP.
Geigy RDWP 5-4 November 5, 1993
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5.1.4 Aquifer Testing
A constant rate pump test, preceded by a step drawdown test, will be conducted to obtain
estimates of the hydraulic properties of the uppermost and second uppermost aquifers.
Information obtained will then be used to design the groundwater extraction systems.
Performance of a constant rate pump test in the uppermost and second uppermost aquifers
will provide global estimates of transmissivity, storativity, and specific yield for a large area
of the aquifer. Additionally, the pump test also yields information on the response of an
aquifer to pumping. For the characterization of the uppermost aquifer, a constant rate
pump test will be conducted in the vicinity of well MW-5S since this well would be available
to serve as an observation point during the test and since a pumping well installed in this
portion of the aquifer may be able to serve as a future extraction well. For the
characterization of the second uppermost aquifer, a constant rate pump test will be
conducted in the vicinity of well MW-11D. Again, installation of a pump test well at this
location would have the benefit of potentially serving as a future extraction well. The
anticipated duration of each constant-rate test is 72 hours. A pumping well and two
temporary observation wells will be installed for each aquifer test. Proposed locations and
construction details of these wells are presented in Figure 5-2 and Table 5-1.
Both constant-rate pump tests will be preceded by a step drawdown test. Information from
the step drawdown tests will be used to position the pumps properly and will yield
information on specific capacity of the aquifers and well loss coefficients. Pretests will be
conducted for approximately 6 hours. The total volume of water extracted during the
pretests and constant-rate tests is estimated to be approximately 36,000 gallons. Drawdown
levels in the pumped well and surrounding observation wells will be measured and used to
determine the aquifer characteristics using graphical techniques. Procedures for conducting
the pump tests and the methods by which data will be reduced and analyzed are presented
in the SAP .
5.1.5 Well Abandonment
Existing monitoring well PZ-1 and the former on-site production well, which were completed
in the third uppermost aquifer, will be abandoned following the completion of pump tests
Geigy RDWP 5-5 November 5, 1993
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m the uppermost and second uppermost aquifers. Both wells will be abandoned in
accordance with North Carolina Administrative Code Title ISA, Subchapter 2C, Section
.0100, which governs well construction and abandonment standards. Procedures for the
abandonment of the wells are presented in the SAP.
5.2 DELINEATION OF TCE
TCE characterization efforts will be limited to the second uppermost aquifer.
Comprehensive groundwater characterization efforts for the Site were described in the
previous section. Efforts to determine if TCE is site-related will be as follows:
•
•
•
•
updating the groundwater contours based on water level measurements, to define
flow patterns onto the Site
resampling of Site wells MW-4D, MW-6D, MW-14D and MW-15D for TCE
resampling of upgradient off-site wells at the Allred and PMP properties for TCE
collecting groundwater samples from the second uppermost aquifer using direct push
sampling methods
placement of up to two additional upgradient wells in the second uppermost aquifer
based on flow patterns and results of the in-situ samples.
Results of the TCE characterization will be presented in the Preliminary Design Report
along with an evaluation of whether TCE is Site-related. The extent of any groundwater
extraction for TCE in the second uppermost aquifer will be based on results of the pre-
design activities.
Geigy RDWP 5-6 November 5, 1993
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5.3 GROUNDWATER TREATABILITY TESTING
Treatability tests will be conducted to establish design and operating parameters for a full
scale carbon adsorption system. Treatability testing will determine carbon usage rates and
determine whether any naturally occurring compounds in the groundwater ( e.g., humic acids,
iron) will affect carbon adsorption of the Site pesticides.
Since pesticides are known to be readily adsorbable on carbon, and adequate isotherm data
is available in literature for the compounds of concern, only bench scale column tests will
be conducted to establish site-specific breakthrough characteristics, preliminary equipment
sizes, carbon exhaustion rates and pretreatment requirements. The column tests will be
performed at the RUST E&I laboratory in Greenville, South Carolina using representative
Site groundwater. Three 1-inch diameter columns, charged with a degassed activated carbon
slurry, will be used to conduct the tests. The columns will be operated in series to simulate
a typical full scale dual reactor skid. It is .anticipated that the tests will be conducted at an
empty bed contact time (EBCT) of 30 minutes.
The flow-through tests will require approximately 20-25 gallons of groundwater per week
over a 2-4 week period. The groundwater samples will be shipped to the RUST E&I
laboratory without any preservative or pretreatment. Pretreatment will be provided atthe
laboratory, if necessary, to ensure that the influent concentrations to the bench scale
columns are representative of those that will be encountered in the field. For example, air
stripping for TCE may be necessary to allow better estimation of actual carbon requirements
for adsorption of the pesticides.
Samples of influent and effluent will be subjected to analysis for total organic carbon
(TOC), pH, alkalinity, hardness, TCE, and pesticides. The effluent concentrations will be
monitored until breakthrough is recorded in both carbon columns. Data collected during
this flow through study will be used to select and optimize full scale design criteria such as:
• groundwater pretreatment requirements
• empty bed contact time
• adsorber sizes and skid configuration
• saturation capacity
Geigy ROWP 5-7 November 5, 1993
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• carbon regeneration frequencies .
The samples will be cooled to the extent possible during transportation and storage. The
volumes of groundwater necessary for treatability testing may limit the level of cooling.
However, since the primary contaminants of concern (pesticides) are non-volatile and not
rapidly biodegradable, no significant losses are anticipated during shipment and storage.
Site groundwater is not a listed or characteristic waste under RCRA. However, RCRA
handling requirements for treatability studies are considered appropriate for the Site. Even
if hazardous, the groundwater samples to be used in the treatability study are conditionally
exempt from regulation under Subtitle C of RCRA based on the amendments 261.4(e) and
261.4(f) in the Federal Register, that became effective on July 19, 1988. RUST E&I will
comply with specific requirements under these amendments for handling, shipment, storage
and treatment of the untreated groundwater samples and any residuals generated during the
study.
RUST E&I will consult technology vendors in developing column test procedures and
operating conditions, interpretation of test results, selection of full scale equipment sizes and
configuration, estimation of regeneration frequencies, selection of a suitable regeneration
system, and definition of optimum full scale operating conditions.
On-site pilot scale tests are typically recommended when a significant variability is
anticipated in influent characteristics, or when the carbon consumption/ exhaustion rates are
expected to be high ( > 10,000 lb/month). Pilot scale tests will not be conducted at the Site
since loadings (flow, pesticide concentrations) to the full scale system are expected to be
relatively uniform and fairly low.
5.4 LITHOLOGIC LOGGING AND SUBSURFACE SOIL SAMPLING
As part of the groundwater and subsurface soil sampling effort, a specially equipped direct
tool (i.e. piezocone) will be advanced through the subsurface using direct push methods to
log the formation differences at selected locations at the site. Lithologic data generated
from the piezocone will be used to correlate soil descriptions already collected for the site,
Geigy RDWP 5-8 November 5, 1993
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and to develop an understanding about the lateral continuity of the uppermost confining
unit.
Undisturbed soil samples will be obtained duri~g completion of the direct push installations
to determine the grain size distributions of representative portions of both the uppermost
and second uppermost aquifer. This information will be used to properly design the slot size
of the screens to be installed in the proposed monitoring, pumping, and observation wells.
The soil samples will be obtained by hydraulically advancing a specially equipped direct
push tool (ie., geocone) into the aquifer, retracting the drive point to expose the sample
tube, and filling the tube with soil by hydraulically advancing the sampler an additional 1.5
to 2 feet into the aquifer. The device is then retrieved to the surface to obtain the sample.
Four of the direct push locations are proposed for the collection of subsurface soil samples
using direct push methods.
Following completion of the lithologic (ie., piezocone) logs at each location, the target depth
for sample collection will be determined to obtain a representative sample of each aquifer
at each location. One soil sample will be then collected at depths ranging from
approximately 35 to 50 ft in the uppermost aquifer, and 70 to 100 ft in the second
uppermost aquifer.
5.5 INFILTRATION TESTING
Site-specific soil characterization and hydraulic data must be collected to design and permit
subsurface (e.g. infiltration gallery) systems for the discharge of treated groundwater.
Information required for satisfaction of NCDEHNR and USEPA permitting and design
criteria includes detailed soil profile descriptions and soil hydraulic conductivity
determinations based on an approved in situ technique. These data are also required as a
design basis for sizing of the system, selection of hydraulic loading rates, evaluation of
potential ground water mounding concerns, and assessment of potential ground water quality
impacts, in keeping with standard engineering practices.
Portions of the Site proper and an area of approximately four acres adjacent and south of
the site that are outside the extent of excavation will be evaluated for suitability of these
Geigy RDWP 5-9 November 5, 1993
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discharge options. The evaluation will consist of (1) conducting a cursory preliminary
model of the hydraulic impact on the water table aquifer from the infiltration of the
estimated design load of 40,000 gpd to assure viability of the concept, (2) detailed evaluation
of site soil conditions via direct observation from test pits, and (3) measurement of in situ
hydraulic conductivity using the Compact Constant-Head Permeameter (CCHP) method.
The purpose of the preliminary modeling is to evaluate potential water balance issues that
may derive from extracting ground water from the water table aquifer in combination with
the second uppermost aquifer yet infiltrating the total quantity back to the water table
aquifer. While this condition may have some advantages for management of the extraction
system, such as gradient manipulation and management, it is important to assure that
excessive mounding does not occur that could potentially interfere with the effectiveness of
the extraction system. We anticipate using the FLOWPATH™ model to make this
evaluation.
The extensive soil boring data for the Site will be reviewed prior to any additional soils
investigations. In this review we will assess the presence of any potential hydraulically
restrictive horizons or layers that may control recharge rates. We will also identify "clean"
zones appropriate to any further investigation. We do anticipate the need for some
additional test pits on the Site proper to verify conditions observed via borings and to
confirm the absence of contiguous hydraulically restrictive zones. We anticipate no more
than 3-4 test pits on the Site proper. In the case of the off-site area to be investigated, we
will also need to provide supplemental soil characterization data with regard to soil physical
characteristics, horizonation, and hydraulically restrictive conditions. Approximately 12 test
pits will be required in this area depending on the heterogeneity of soil conditions. All test
pits will be excavated to approximately 12 feet. Proposed test pit locations are presented
in Figure 5-3. Actual locations will be confirmed in the field based on soil conditions and
accessibility.
The determinations of saturated hydraulic conductivity (K,) of the soils will be made in situ
using the CCHP device. This instrument provides a fast, accurate means of measuring K,
in the 2-10 m depth range of the vadose zone. K, is estimated using the data from the field
measurements in combination with the Glover Solution and the method of Amoozegar
(1989) (see Appendix B of the SAP). Detailed descriptions of the equipment, methods, and
Geigy RDWP 5-10 November 5, 1993
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data interpretation are presented in the SAP. This instrument was developed by soil
physicists at N.C. State University and has been used extensively by the engineering/science
community in North Carolina for soil property and site suitability determinations. We
anticipate conducting the test at approximately 20 locations on the combined on-site and off-
site areas, and at two soil depth zones. The actual depth zones tested will be determined
based on the results of the soil test pit observations.
The decision to proceed with a recharge system design will be based on the CCHP test
results in conjunction with existing data from previous borings, standard engineering
practices for these systems, design safety factors and allowances, a comparison of the area
available versus the area required, and examination of potential interactions with the ground
water extraction system. Determination of the preferred discharge method will be presented
in the Preliminary Design Report.
Design of either a surface spray irrigation or a subsurface infiltration gallery would have to
satisfy State of North Carolina Non-Discharge Permit requirements (15A NCAC ZH.0200).
The permit itself would not be required so long as the discharge was conducted entirely at
the Site.
5.6 SOIL CHARACTERIZATION
The ROD requires excavation of the top one-foot of soil where pesticide concentrations
exceed the Performance Standards. Soils at the Site have been well characterized and the
existing data (Appendix A) provides a strong basis for excavation requirements. This data
was evaluated to determine if there were any areas of the Site where the extent of
excavation was uncertain. Sampling locations are placed outside areas to be excavated that
are not bounded by areas that satisfy the Performance Standards. Topographical features,
surface drainage patterns, and chemical transport potential were considered when selecting
the proposed sampling locations. Proposed surficial soil sampling locations are presented
in Figure 5-4. Sampling locations were placed along the existing grid system to the extent
practical. Locations in the figure are approximate and will be confirmed in the field based
on Site conditions. Surficial soil samples will be analyzed for pesticides.
Geigy RDWP 5-11 November 5, 1993
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Excavation to a depth of one foot presents no significant geotechnical concerns. No
geotechnical parameters are necessary for design. The density of Site soils must be. known
for the construction cost estimate, since disposal costs wiB be based on weight. In situ
density will be determined using either the sand cone method or a calibrated nuclear density
gauge. Density measurements will be conducted on surficial soils from clean portions of the
Site if the sand cone method is used. The nuclear density gauge is a non-destructive testing
method and can be used anywhere at the Site.
The groundwater treatment system will be constructed at the Site following excavation of
soils and removal of the foundation debris. · Site soils must have sufficient strength to
support the load of the treatment system. Compressive strength requirements for Site soils
will be set in the design specifications once the load is determined.
5.7 SURVEYING
The most recent survey of the Site was conducted between March 26 and May 18, 1989.
However, since this survey, the Site has been altered by soil removal activities conducted
in 1989 and 1991. A ground survey will be conducted to update the disturbed areas of the
Site as part of the pre-design activities. This will provide an accurate representation of the
ground surface so that excavation and drainage drawings may be produced. This will also
provide an original surface against which excavated volumes may be calculated and checked.
A revised Site plan will be presented in the Preliminary Design Report.
A permanent benchmark with horizontal and vertical coordinates is believed to be located
on or near the site. If this is so, the construction of a temporary benchmark would not be
necessary since coordinates could be taken directly from the existing benchmark. However,
if the existing benchmark is located a significant distance from the Site and would require
a traverse to be run to the Site each time coordinates are needed, then an additional
benchmark would be beneficial. The need for a temporary benchmark will be presented in
the Preliminary Design Report.
Geigy RDWP 5-12 November 5, 1993
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CllY WELL #4
WOODS
GS-02-2
GS-02-1
GS-02-3
~MW-13S
WOODS
~MW-7S
PZ-1 + MW-18D
• P-11 WOODS
LEGEND
~GS-O2-2 GEOLOGICAL SURVEY WELL
~MW-7S MONITORING WELL
~PZ-1 PRODUCTION ZONE WELL
~LLRED APPROXIMATE LOCATION OF ALLRED WELL
PIEZOCONE
PIEZOCONE, SHALLOW HYDROCONE
PIEZOCONE, DEEP HYDROCONE
6
P-14
6P-6
fr.P-10
AP-1
&P-5
■ P-16
00 P-12
PIEZOCONE, SHALLOW AND DEEP HYDROCONE, SHALLOW GEOCONE
PIEZOCONE, SHALLOW GEOCONE
PIEZOCONE, DEEP GEOCONE
+ WP-1 S SHALLOW WELL POINT PIEZOMETER
♦ WP-1 D DEEP WELL POINT PIEZOMETER
CAL-1 PIEZOCONE CALIBRATION
+ MW-16D PROPOSED MONITORING WELL
N,\86619\6619HG03.0WG
00
P-12
._♦WP-1D
P-13
MW-
fr.
P-10
6
P-6
6
P-8
• P-7
/
MW-10
MW-4S
&
P-5
(CAL-2)
WOODS
MW-
W-14D\WOODS I/
ALLRED ,f PROPERTY
+ MW-16D
• P-2
• P-3
CAR PORT
~AU.RED
...... ENVIRONMENT& l~U~ I OORASTRUCTlURlE
0
NORTH
POWDER METAL PRODUCTS
WELL 2300 FT.
200' 400'
FIGURE 5-1
PROPOSED DIRECT PUSH
LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
600'
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GS-02-2
GS-02-1
D
CITY WELL #4
WOODS
LEGEND
~GS-02-2
~MW-7S
~PZ-1
-$MW-16D
• PW-1S
□ OW-1S
® PW-1D
-$-OW-1D
0
GEOLOGICAL SURVEY WELL
MONITORING WELL
PRODUCTION ZONE WELL
PROPOSED MONITORING WELL
PROPOSED UPPERMOST AQUIFER
PUMPING WELL
PROPOSED UPPERMOST AQUIFER
OBSERVATION WELL
PROPOSED SECOND AQUIFER
PUMPING WELL
PROPOSED SECOND AQUIFER
OBSERVATION WELL
150' 300'
GS-02-3
450'
MW-13S
~
WOODS
MW-7S
~
-$ MW-18D
MW-BS
W-6D MW-6S
~ MW-12S
WOODS
. /MW-11D
OW-1D-$-
MW-9S
MW-2S
MW-
OW-1tif OW-L PW-1S
0
MW-10S j\ ~ MW-4S_/ ',,\
MW-,4D\
NORTH
ALLRED PROPERTY
PW-1D _/-$-OW-2D WOODS
I'll ..-ENVIRONMENT & l~U>I OORASfRUCTURJE
MW-17D
(APPROXIMATELY 150 FT. SOUTH)
FIGURE 5-2
EXISTING AND PROPOSED
WELL LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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Piil
0
=
r-,
L_ ' \
f
' I
j
LEGEND
TEST PIT (TP-X)
COMPACT CONSTANT-HEAD PERMEAMETER (CCHP) (CH-X)
PAVED ROAD
DIRT ROAD
RAJLROAO
FENCE
PROPERTY LINE
INDEX CONTOUR
PREVIOUS EXCAVATION AREA
N,\86619\6619GH14.DWG
,. .-,,,, .. ....,_,.,-··
·<,5:.~s':.
TP-4
~CH-4
TP-1·1,.,. ...
~CH-1,~
0 150'
-~~-;,-:---==-~-::.:---=--:::~~--:::_~-~-~;-
~ ---
APPRoXIMA TE CONCRETE
FOUNDATION wooos
TP-3
Piil
OEMOLET
AUTOMOTIVE
~ANING SERVICE
\
CH-Jt
t:
/;i
8; ALLRED f PROPERTY
0 \@ \~ • I= ,ti
CAR
PORT
0
) ETAL SHED
"•--c.., \
NOTES:
300' 450'
.. _..ENVJrRONMENT &
l~U>I JINJFRASJRUCTURE
TOPO MAPPING BY WOOL PERT CONSULTANTS BASED ON
AERIAL PHOTOGRAPHY FLOWN MARCH 26, 1989 WITH
GROUND CONTROL TIED TO THE STATE PLANE COORDINATE
SYSTEM.
PLANIMETRIC FEATURES WERE FIELD IDENTIFIED
ON MAY 18, 1989 BY WOOLPERT CONSULTANTS.
FIGURE 5-3
PROPOSED INFILTRATION GALLERY
TEST LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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N: 86619\6619HG05.0WG
SD-25
~
SS-61
0
SSR-8
till
WOODS
WOODS
LEGEND
SEDIMENT SAMPLE LOCATION
SOIL SAMPLE LOCATION
PROPOSED SOIL SAMPLE LOCATION
0 120' 240' 360'
c======~i========r========
-
□
Q ,;";~~'\::~~~~~~~:,,_:,~, -~
WOODS
.. ..-ENVIRONMENT & l~U>I OORASfRUCTURE
WOODS
NORTH
FIGURE 5-4
PROPOSED SURFICIAL SOIL
SAMPLING LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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Well
PW-1S
TW-1S
TW-2S
PW-1D
TW-1D
TW-2D
TABLE S.l
PROPOSED WELL CONSTRUCTION DETAILS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
Aquifer Test Wells
Casing Estimated
Diameter Estimated Depth Screen Length
(in) (ft bgl) (ft)
4 50 15
1 50 10
1 50 10
6 100 35
1 80 10
1 80 10
Monitor Wells
Estimated
I
Well Casing Estimated Screen
Diameter Depth ' Length Rationale
(in) (ft bgl) (ft)
MW-16D 2 100 10 Monitor potential migration of
TCE onto site
MW-17D 2 100 10 Monitor potential migration of
TCE onto site
MW-18D 2 100 10 Monitor downgradient pesticide
concentrations
Notes:
bgl = below ground level
I
Gcib'Y RDWP November 5, 1993
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6.0 REMEDIAL DESIGN SUBMITIALS
In accordance with the SOW, the remedial design will be developed sequentially at
Preliminary (30%), Intermediate (60%)/Pre-Final (90%), and Final (100%) stages.
Conceptual requirements ( e.g., discharge options) will be examined in the Preliminary
Design submittal. After the scope is defined following the Preliminary Design submittal,
details of the design (e.g., treatment equipment arrangements) will be developed in the
subsequent stages. EPA comments on each submittal will be formally responded to and
then incorporated into the next submittal as appropriate so that the design may proceed in
a timely manner. The Intermediate and Pre-Final Design stages will be submitted as one
design report because of the straight forward remediation requirements of the Geigy Site
and to advance the schedule.
Further details of each design submittal are discussed below along with the list of specific
documents that will constitute each submittal.
6.1 PRELIMINARY DESIGN REPORT
The objective~ of this submittal are to summarize the results of the pre-design activities and
to define the basis for design. At the conclusion of this phase, the remedial design will be
approximately 30% complete. A primary purpose of this submittal is to determine whether
TCE should be treated as a site-related constituent in groundwater and therefore be actively
addressed in the site design. The primary soils issue is delineation of those soils that could
exceed Performance Standards and require excavation.
This submittal will address the following design considerations for soils and groundwater:
• locations of any additional monitoring wells
• locations of extraction wells
• extraction rates and constituent concentrations
• discharge limits for treated groundwater
• groundwater treatment requirements
• groundwater pretreatment requirements
• demolition of the foundation
Geigy RDWP 6-1 November 5, 1993
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•
•
approximate volumes of soil and concrete requiring excavation
whether TCE in the second uppermost aquifer is site-related
• effect of any upgradient pesticides on the extraction system in the second uppermost
aquifer.
The Preliminary Design will therefore establish the conceptual design requirements for
remediation. Resolution of the monitoring and extraction well issues will have a major
impact on the overall cost of site remediation. Groundwater modeling will be conducted
using the aquifer test results to determine extraction well locations and recovery rates.
Based on site geology and flow patterns, it is anticipate that analytical modeling (e.g.,
WHPA) is sufficient for predicting groundwater transport.
Large scale process drawings (Process Flow Diagram, Piping & Instrumentation Diagram,
General Arrangement, etc.) will be provided in this submittal along with an outline of the
specifications. Initial detail drawings will be provided with the Intermediate Design
submittal. A written narrative (Design Criteria Report) describing the design would be
included in this submittal. The Preliminary Design Report will include the following:
• summary of pre-design activities and conclusions
•
•
•
•
design criteria
permitting requirements
project delivery strategy
results of additional groundwater modeling
• preliminary drawings and outline of the specifications.
Groundwater modeling will be used to design the extraction system for the Site. Based on
results of the pre-design activities, the model of the groundwater extraction system will
simulate the flow systems of the two aquifers as dependent (i.e., leakage rate and
contaminant transport from the uppermost aquifer to the second uppermost aquifer will be
considered). Based on the pre-design field results and discussions with regulatory
authorities, the most promising discharge option, either POTW or infiltration gallery, will
be indicated.
Geigy RDWP 6-2 November 5, 1993
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The Preliminary Design Report will be submitted to EPA for review and approval in
accordance with the SOW. Following submittal of responses to agency comments, a
Preliminary Design Review Meeting involving EPA and the Companies will be held in
Atlanta, Georgia to resolve any pending design issues. Following EPA approval of the
Preliminary Design Report, work will begin on the remainder of design.
6.2 COMBINED I.NTERMEDIATE/PRE-FINAL DESIGN REPORT
Elements of the Intermediate Design Report and the Pre-Final Design Report as described
in the SOW will be combined into a single design submittal. This combined document will
be called the Intermediate/Pre-Final Design Report (IPDR) and include:
• Intermediate Design requirements
• DraftPerformance Standards Verification Plan
• Pre-Final Design requirements .
Design requirements for the IPDR are described in the following sections.
6.2.1 Intermediate Design Requirements
The Intermediate Design will advance the design details to the 60% completion level and
incorporate any agency comments on the Preliminary Design. The Intermediate Design will
include draft design analyses, plans and specifications.
Any value engineering recommendations will be presented at this stage. Value engineering
involves identifying options which, without compromising the quality of the product, can
improve the cost effectiveness either through reduction in capital costs or in long-term
operation and maintenance costs.
Design for soils removal would involve the preparation of grading plans and specifications,
demolition of the concrete foundation, and restoration of the site. Grading plans will be
based on the extensive amount of existing analytical data along with select confirmation
sampling collected as part of the pre-design activities.
Geigy RDWP 6-3 November 5, 1993
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Detailed engineering drawings (structural, electrical, mechanical, instrumentation) will be
developed at this stage. Division 1 through 17 specifications, based on the outline submitted
in the Preliminary Design Report, will also be developed. Division O specifications
(Contract and Bid Documents) will be prepared by the Companies for bidding purposes
alone and will not be part of the design submittals.
The Intermediate Design may include design details such as:
• treatment facilities housed in a Butler-type building with slab floor
• HV AC consisting of heating and simple fan/louver system for cooling m the
treatment building
• single-wall PVC piping or equivalent
• electrical utilities conforming to standard NEC requirements .
6.2.2 Performance Standards Verification Plan
The Performance Standards Verification Plan (PSVP) provides a mechanism by which the
achievement of the remediation goals, both for soils or groundwater, will be verified. The
PSVP will discuss:
• remediation goals
•
•
•
•
•
sampling grids and locations
sampling frequency and schedule
sampling techniques
analytical methods
field information and parameters to be collected
Included in the PSVP will be the:
•
•
Performance Standards Verification Field Sampling and Analysis Plan
Performance Standards Verification Quality Assurance/Quality Control Plan
Geigy RDWP 6-4 November 5, 1993
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Sufficient detail will be provided within these plans so as to allow persons not familiar with
the site to collect quality information and samples. The Draft PSVP will be submitted with
the IPDR.
6.2.3 Pre-Final Design Requirements
The Pre-Final Design will present a complete set of design drawings and complete
specifications. In addition, the Pre-Final Design Report will include the following:
• construction schedule
• construction cost estimate.
6.3 FINAL DESIGN REPORT
The Final Design Report will incorporate the agreed upon responses to EPA's comments
on the Intermediate/Pre-Final Design Report and associated reports. A final PSVP will
also be submitted at this time.
Geigy RDWP 6-5 November 5, 1993
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7.0 PROJECT MANAGEMENT
The following sections describe the project organization, progress reporting requirements,
and document quality control. Also presented are a project schedule and proposed support
of community relations efforts.
7.1 PROJECT ORGANIZATION
The organization chart for the remedial design activities is presented in Figure 7-1. The
focal point of the project team will be the Project Coordinator, Ms. Lorraine Miller of Olin
Corporation. Pursuant to Section XIII, Paragraph 41 of the Consent Decree,.Ms. Miller will
act as the duly authorized representative of the Companies. She will provide technical
review of submittals and will act as the liaison between the Project Manager and the
EPA-RPM. The Alternate Project Coordinator will be Mr. Dave Cummings of Olin
Corporation.
Pursuant to Section VI, Paragraph 9 of the Consent Decree, the Supervising Contractor will
be RUST Environment & Infrastructure (RUST E&I). The Project Manager for RUST
E&I will be Mr. Jim Cloonan, P.E. The Project Manager will be responsible for all day to
day aspects of the project, both administrative and technical, including adherence to the
schedule outlined in Section 7.6. He will direct the Remedial Design Coordinator and the
Pre-Design Field Activities Coordinator.
The Remedial Design Coordinator will be Mr. John Murphree, P.E. The Remedial Design
Coordinator will be responsible for coordination of all design aspects and disciplines: civil,
mechanical, electrical, instrumentation and environmental. He will . coordinate the
submission of all design submittals and ensure that the design is consistent with the Consent
Decree and the ROD.
The Pre-Design Field Activities Coordinator will be Mr. Michael Sheehan. The Pre-Design
Field Activities Coordinator will be responsible for designing and managing the various field
activities associated with the RDWP. These responsibilities include supervising the
collection of data, assuring data collection procedures are performed in accordance with the
FSP and QAPjP, and reporting to the Project Manager as to the status of the project. The
Geigy RDWP 7-1 November 5, 1993
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Pre-Design Field Activities Coordinator will be the key team member to provide technical
direction to the field staff and ensure compliance with contractual, technical, and financial
requirements of the sampling and analysis tasks.
7.2 QUALITY CONTROL
I Quality control throughout the remedial design process is essential to the development of
an effective and implementable remedial action. Standards will be followed in the
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preparation of design calculations and drawings to ensure their accuracy and ease of review.
All calculations will adhere to the following format requirements:
•
•
•
•
•
Make calculations neat and legible
List all design assumptions
List all formulae and define symbols
Group calculations for various portions of project
Number all pages in proper order
• Provide index for quick reference
• File for future reference when complete
All drawings will adhere to the following requirements:
• Convey precise information in a concise manner
• Use standard format and presentation for all disciplines
• Explain all symbols and abbreviations clearly
• Provide index of drawings on cover sheet
• Revision numbers will be clearly noted
• Provide drawings for each discipline
• Coordinate carefully all references to drawings of other disciplines
• Check and coordinate all drawings individually and between disciplines
All documents will be reviewed by RUST E&I and then the Companies before submittal
to EPA. All design work will be performed under the supervision of an engineer registered
in the State of North Carolina. No drawings shall be certified with an engineer's seal before
Geigy RDWP 7-2 November 5, 1993
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receiving final review. Specifications shall follow the CSI Masterworks format.
will be prepared using the AutoCAD platform (v. 11 or higher).
7.3 DATA MANAGEMENT PLAN
Drawings
Data management will involve the maintenance and control of field data, laboratory
analytical data, and any other information relevant to remedial design activities. Effective
data management requires that information be available in a concise, comprehensive, timely,
and reliable manner. To achieve these goals, remedial design data will be stored in an
environmental information management system (EIMS) which is administered and
maintained by RUST E&I. The system consists of several computer hosted database
applications and is designed to minimize the need for data entry (i.e., electronic transfer of
laboratory data), provide data validation checks and relational query capabilities, protect
information via user access restrictions, and provide reporting capabilities.
I 7.3.1 Minimum Data Requirements/Formatting
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To ensure efficient use of EIMS, the selected analytical laboratory will be capable of
producing an electronic deliverables of the analytical data in a compatible file format ( e.g.
ASCII comma delimited). The analytical reports required for this project will be Level III
deliverables, which include complete documentation of extractions, dilutions, and standard
curves. In addition, a complete sampling and laboratory chain of custody, a library search
for tentatively identified compounds, matrix spike and duplicate sample analyses, and the
associated chromatograms, if applicable, will be includea.
7.3.2 Data Tracking
Sample designations are essential to the data management process. The sample
identification procedures presented in the SAP have been be designed to provide a
consistent and logical method of ensuring data integrity. The sample identification format
contains specific information about the sample, including sample matrix and location. In
addition, suffixes will be used to track ~ssociated quality control samples submitted blindly
to the laboratory as follows:
Gcigy.RDWP 7-3 November 5, 1993
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-a
-b
-c
-d
-e
Field duplicate of the primary sample
Field split to a quality assurance laboratory
Trip blank
Rinsate or equipment blank
Field blank.
Analytical _requests will be managed using the Sample and Analysis Laboratory Tracking
(SALT) system developed by RUST E&I using File Maker Pro, a commercially available
flat-file database program. SALT is a tracking and validation system that includes project,
laboratory, and cost information along with comprehensive reporting capabilities. All
information available from the chain of custody forms completed in the field will be logged
into the SALT database. When a sample is received by the laboratory, a Laboratory
Confirmation Report will be submitted to RUST E&I. This report will summarize the
samples received by the laboratory, report any breakage or inconsistencies in the chain of
custody, and reiterate the laboratory's understanding of analyses to be conducted. From this
report the database manager will input the sample specific information and verify analytical
methods.
7.3.3 Sorting
Upon receipt of the analytical data hardcopy and electronic file, record of receipt will be
entered into SALT to develop a comprehensive profile of each sample collected. Sample
tracking reports will be generated from this information to anticipate deliverable due dates,
confirm receipt of data, and identify projects overdue from the lab. The status of a
particular sample, a group of samples, or the entire job will be available through the SALT
system.
7.3.4 Validating
An additional capability of SALT is management of the data validation process by ensuring
consistency in validation methods and by documenting all data checks. Validation of
analytical data will include the evaluation of method blanks and laboratory control samples.
Common laboratory artifacts that are detected in associated blanks will be evaluated with
respect to EPA criteria. Additionally, surrogate recovery and matrix spike information will
Geigy RDWP 7-4 November 5, 1993
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be reviewed to allow a subjective rating of the sample matrix effects. Chain of custody
information, cooler temperature, headspace in volatile organic analyses vials, and any
instances of remiss technical holding times will be noted in the validation process. This
evaluation serves to alert the data manager of any problems or trends which may affect the
validity of the data, resulting in qualification of the data with data flags.
7.3.5 Retrieving
Data received on electronic file from the laboratory will be downloaded from the analytical
instrument onto floppy disk, which will be loaded into the EIMS using Paradox, a
commercially available relational database program. Paradox serves as a storage and data
retrieval system. From Paradox, information on any sample location, sample date, or
specific compound can be retrieved.
Analytical summary tables for report presentation will be generated in Excel through a cross
tabulation program developed at RUST E&I. Excel allows data manipulation and
reformatting of the data into tables without re-inputting the data, which eliminates problems I with transcription errors.
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7.3.6 Backup Data Management
Field and laboratory data will be stored in hard copy and floppy disk format (when
applicable) as part of the project file. Additional backup copies of this information will be
stored in the Project Manager's, data analysts', and principal author's files for working
purposes. This information will be retained in the project file until completion and close-
out. Upon project close-out, all records will be archived for permanent storage.
7.3.7 Project Procedure Manual
RUST E&I has prepared a Project Procedure Manual (PPM) for the Geigy Site Remedial
Design. The PPM is an internal document that presents the following information:
• project description and scope
• project team organization, including phone and fax numbers
Geigy RDWP 7-5 November 5, 1993
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•
•
•
•
•
•
format for letters, histories, communication reports, memoranda, progress reports and
design subrnittals
names, addresses and number of copies for document distribution
document retention requirements
project charge numbers
project file index
drawing and specification standards .
The project file index is presented in Table 7.1. The project file is maintained at the RUST
E&I office in Greenville, South Carolina. Anyone removing the working copy from the
project file must note the file name and number, their name and the date on the master
sign-out list.
RUST E&I will take the following approach to promote clear and effective communication
within our technical team, with the Companies, and with EPA:
•
•
•
•
•
all correspondence will address the project name ("Geigy Site Remedial Design") and
the project number (86619.xxx)
letters will be used for all correspondence other than within RUST E&I
the "RE:" heading on all letters will refer to the project subject area
memoranda will be used only for internal RUST E&I correspondence
telephone and office conversations involving decisions and/ or information pertinent
to this project will be confirmed in writing by RUST E&l.
I The number of copies of each deliverable to be submitted to EPA are defined in the
Statement of Work. Copies will be submitted to:
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Mr. Luis Flores
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
[phone]; fax [phone]
Geigy RDWP 7-6 November 5, 1993
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7.4 DESIGN CHANGES
The Remedial Design will be performed in a manner consistent with the ROD and the
Consent Decree. If it appears that major design changes may be required that may alter
the selected remedy, the Project Coordinator will notify the EPA-RPM of the situation in
accordance with Section VII (Additional Response Actions) of the Consent Decree. The
EPA-RPM will then determine if the design changes warrant an ESD or an amendment to
the ROD. Minor design changes that are consistent with the approved remedy may be
approved by the EPA-RPM.
Technical scope changes and/or cost changes in the project could constitute a major design
change. Examples of changes which may require an ESD or an amendment to the ROD
include:
•
•
Proposed remedy cannot attain remediation or discharge levels due to Site conditions
Change from one treatment process to another
Examples of changes which would not require an ESD or an amendment to the ROD
include but are not limited to:
•
•
•
7.5
If EPA determines that TCE in the second uppermost aquifer is not Site-related
Pretreatment options for groundwater and soils
Cost savings or technical modifications achieved through value engineering review .
PROGRESS REPORTS
The Project Coordinator will provide written reports to the EPA-RPM by the tenth day of
every month pursuant to Section XI, Paragraph 29 of the Consent Decree. These progress
reports shall include the following information:
• actions which have been taken toward achieving compliance with the Consent Decree
during the previous month
• results of sampling and tests and all other data received or generated in the previous
month
Geigy RDWP 7-7 November 5, 1993
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•
•
•
•
•
7.6
identification of all work plans, plans and other deliverables required by the Consent
Decree which were completed and submitted during the previous month
all actions, including, but not limited to, data collection and implementation of work
plans, which are scheduled for the next six weeks
' information regarding percentage of completion, unresolved delays encountered or
anticipated that may affect the future schedule for implementation of the Work, and
a description of efforts to mitigate those delays or anticipated delays
any modifications to the work plans or other schedules proposed to EPA or that have
been approved by EPA
all activities undertaken in support of the Community Relations Plan during the
previous month and those to be taken in the next six weeks.
SCHEDULE
The estimated schedule for completion of Remedial Design is given m Figure 7-2.
Implementation of the major work tasks has been divided into discrete, definable tasks to
indicate the coordination of parallel and consecutive elements through completion of the
remedial design.
The schedule presumes that the work to be accomplished is that identified in this Work Plan
without changes or modification. The schedule is based on the field activities described in
Section 5. Additional activities, adverse field conditions, and laboratory delays will impact
the schedule. Major design changes may also significantly impact tjle schedule. Any
changes or modifications which are deemed appropriate based on the data collected and/ or
interim results of the design effort, and their effect on the estimated schedule, will be
reviewed with EPA at the earliest opportunity.
The SOW requires the schedule to indicate timing, initiation and completion of all critical
path milestones. The critical path is a series of tasks, each of which must be completed on
time to meet fixed task dates and the end of the overall project. Schedule dates are
contingent on the receipt of EPA comments and approvals, where required. Delays in
EP A's approval of submittals will impact the schedule. The schedule assumes prompt
obtaining of access, where required. Delays in obtaining access will affect the schedule.
Geigy RDWP 7-8 November 5, 1993
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The Consent Decree requires a schedule for completion of the Remedial Action Work Plan.
The Remedial Action Work Plan is to be developed in conjunction with the following
documents:
• Construction Management Plan
• Construction Quality Assurance Plan
• Construction Health and Safety Plan/Contingency Plan.
The draft Remedial Action Work Plan will be submitted to EPA 60 days following receipt
of written approval of the Remedial Design. Responses to any comments will be provided
to EPA within 30 days of receipt. A final Remedial Action Work Plan will be submitted
to EPA within 30 days of acceptance of the responses and/ or draft plan.
7.7 COMMUNITY RELATIONS
The Consent Decree states that EPA will prepare a Community Relations Plan for the Site.
The Companies believe that the dissemination of relevant and reviewed project information
to the public is an important element of Remedial Design. Information should come from
one source and be verified prior to release, to minimize errors and misinformation. The
Companies will provide reasonable assistance to EPA and the State upon sufficient notice
with public relations activities.
Geigy RDWP 7-9 November 5, 1993
lr--------------------r----_-_-_-_ ---~------------------------,
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Scoping/Wark Plans
Task Coordinator
M.Sheehan
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• Work Plan
• Q,APP
• SAP
. Project Management
J. Cloonan, P.E.
• Planning
• Cost Control
• Document Control
• Technical Review
• Cost Estimating
• Scheduling .
EPA RPM
Luis Flores
Project Coordinator
Lorraine Miller
Olin Corporation
Health & Safety
H.Moore
• HASP
• Oversight
Pre-Design Remedial Design
Field Activities
Coordinator
M. Sheehan
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Site Characterization
Task Coordinator
S. Bohannon
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• Well Installation
-RUST
-Subcontractors
• Sampling/Analysis
-RUST
-Contract Labs
• Aquifer Testing
• Repon
-RUST
Technical Review Team
• L. Miller (Olin) • J. Bums (Olin)
• H. Moats (CIBA)
• B. Vinzant (Kaiser)
• J. Cloonan (RUST)
• D. ·Hargett (RUST)
Coordinator
J. Murphree, P .E.
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Pre-Design Evaluation
Task Coordinator
J. Cloonan, P .E.
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• RDWorkP/an
• Modeling
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Process Engineering
Task Coordinator
J, Murphree, P .E.
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• Preliminary Design
• Intermediate Design
Technical Review Team
• L. Miller (Olin) • J. Bums (Olin)
• H. Moats (CIBA) • R. Delap (RUST)
• B. Vinzant (Kaiser) • J. Cloonan (RUST)
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Detail Engineering
RUST Engineering
G. Ewoldsen, P .E.
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• Instrumentation
• Electrical
• Design Basis • PrefinaVFinal Design • Structural
• Permitting • PSVP
• TCE Delineation
• Treatability Testing
...... ENVIRONMENT & l~U~I INFRASTRUCTURE
Rev. I: 10-4-93
• Mechanical
Figure 701
Geigy Chemical Corporation Site
Project Organization
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Row
FIGURE 7-2
GEIGY CHEMICAL CORPORATION SITE
REMEDIAL DESIGN SCHEDULE
1993 1994
# Task Name End Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug
1 Remedial Design Work Plan ~ 2 Submit Work Plan to EPA Aug/30/93
3 EPA Review
4 Response to Comments r::
5 Document Revision I
6 EPA Aooroval Nov/15/93 6
7 All Access Requirements Complete Dec/01/93 ' ~
8 Pre-Design Field Activities ~ 9 Receipt of All Analvtical Data Mar/31/94
10 Preliminary Desion Report
11 Results of Data AGauisition II I 12 Desian Criteria Report
~ $ 13 Preliminary Plans & Specifications
~
Plan for Satisfying Permitting Requirments 14
15 Submit Preliminary Desiqn Report Jun/06/94 ~ .
16 EPA Review & Comments ~
17 Response to Comments ~
18 Preliminary Design Review Meeting Aug/02/94 [
-
19 EPA APoroval Aug/09/94 ~ 20 lntermediate/Prefinal Design Report
21 Complete Design Analyses
22 Final Plans & Specifications
23 Preformance Standards Verification Plan
24 Draft Construction Schedule
25 Construction Cost Estimate
26 Submit lntermediate/Prefinal Design Report Nov/25/94
27 EPA Review & Comments
28 Response to Comments
29 Final Design Report Jan/30/95
Printed: Nov/05/93 NOTES: DATES ARE CONTINGENT ON THE RECEIPT OF EPA COMMENTS AND/OR (DIS)APPROVALS, WHERE REQUIRED.
Page 1 ARROWS BETWEEN TASKS DENOTE DEPENDENCIES.
Project No.: 86619.200
1995
Sep Oct Nov Dec Jan Feb Mar Apr May Jur
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Milestone 6 Summary .a
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1.0
2.0
3.0
3.0.1
TABLE 7.1
PROJECT FILE INDEX
GEIGY SITE REMEDIAL DESIGN
INDEX
PROPOSAL CONTRACTS
2.1
2.2
2.3
2.4
2.5
2.6
RFP from Client
Proposal to Client
2.2.1 Revision No. 1
2.2.2 Revision No. 2, Etc.
Contract with Client
2.3.1 Revision No. 1
2.3.2 Revision No. 2, Etc.
Contract with General Contractor
2.4.1 Revision No. 1
2.4.2 Revision No. 2, Etc.
Contract with Subconsultants
2.5.1 Breakdown as Required
Contract with Vendors
2.6.1 Breakdown as Required
2.7 Change Orders
2.8 Engineering Cost Estimates and Backup
CORRESPONDENCE (Except 2.0 and 4.0)
Master Correspondence File
3.1 Correspondence from Client
3.1.1 To Client
3.2 Interoffice Correspondence
Geigy RDWP November 5, 1993
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4.0
5.0
Table 7-1 (Continued)
3.3 Correspondence With General Contractor
3.4 Correspondence With Subcontractors
3.4.1 As Required
3.5 Correspondence With Vendors
3.5.1 As Required
3.6 Correspondence With Regulatory Authorities
3.6.1 EPA
3.6.2 NCDEHNR
3.6.3 MCSSA
3.7 Correspondence With Property Owners
3.7.1 As Required
3.8
3.9
Correspondence With Legal Counsel
Correspondence With Insurers
INVOICE INFORMATION
4.1
4.2
4.3
4.4
Invoices to Client
Invoices from Contractor
Invoices from Subcontractors
4.3.1 As Required
Invoices from Vendors
4.4.1 As Required
PROJECT CONTROL
5.1 Project Procedure Manual
5.2 Project Work Orders
5.3 Accounting Data Sheets
5.4 Accounting Project Reports
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Table 7-1 (Continued)
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5.5 Work Plan/Schedule
5.6 Drawing Control
5.7 Design Progress Report
5.8 Progress Reports from Contractor
5.9 Quality Control -Design
5.10 Quality Control -Vendor
5.11 Quality Control -Construction
6.0 MEETING NOTES AND HISTORIES
7.0
6.1 Telephone Memoranda
6.2 Histories
6.3 Field Memoranda
6.4 Field Orders (Not Involving Changes)
6.5 Trip Reports
6.6 Workshops, Presentation, Public Hearings, Conference Notes
6.7 Project Photos
6.8 Project Videos
DESIGN FILES
7.1
7.2
7.3
7.4
Client Supplied Design Criteria/Data
Design Analysis
7.2.1 Disciplines as Required
Design N ates
7.3.1 Disciplines as Required
EPA Submittals
7.4.1 Monthly Progress Reports
7.4.2 Remedial Design Work Plan
7.4.3 Sampling and Analysis Plan
7.4.4 Health and Safety Plan
7.4.5 Preliminary Design Submittal
7.4.6 Intermediate Design Submittal
7.4.7 Prefinal/Final Design Submittal
7.4.8 Performance Standards Verification Plan
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8.0
9.0
Table 7-1 (Continued)
7.5 Property Survey Data
7.5.1 Site Maps
7.6 Field Activities Reports
7.7 Soil Data
7.7.1 Chemical Data
7.7.2 Geotechnical Data
7.8 Technical Literature
7.8.1 Carbon Absorption
7.8.2 Pesticides
(Note: More detailed breakdown of technical literature will be made as
appropriate)
7.9 Air Photos
7.10 Erosion Control
7.11 Vendor Documents
7.11.1 Structural, Mechanical, Electrical, Controls, Vessels, HVAC, Etc., As
Required
7.12 CADD Files/Documents
7.13 Others Numbered Sequentially As Required
SPECIFICATIONS
8.1 As Required
PERMITS
9.1 Permits (Specific Items, e.g., Air, Archaeological, etc., as required.
Recommended to maintain separate file for each permit).
10.0 SAFETY
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11.0 UTILITIES
11.1 As Required
12.0 INSURANCE
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Table 7-1 (Continued)
November 5, 1993