NCD991278540_20100922_Weyerhaeuser Company_FRBCERCLA RA_Remedial Design Remedial Action 2000 - 2010-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
4SD-SRSEB
Marcel Sylvestre
Domtar, Inc.
395 de Maisonncuvc Blvd. West
Montreal, QC H3A I LG Canada
Re: Approval of Final Remedial Design
Operable Unit Four (Welch Creek)
September 22, 20 I 0
Domtar (fonnerly Weyerhaeuser), Plymouth, NC
Dear Mr. Sylvestre,
EPA approves of the Final Remedial Design Report dated August 2010 for the
project noted above. There arc certain topics, such as turbidity monitoring, that are
repeated in both this report and the draft remedial action work plans. Comments
regarding some of these repeated topics may be best addressed during the review of the
remedial action work plans. If you have any questions, please contact me at 404/562-
8794 or [e-mail].
Cc:
Nile Tcstcnnan, NCDENR DWM
Stephen Rynas, NCDENR DCM
~;~
Randy BryanF
Remedial Project Manager
Supcrfund Remedial/Site Evaluation Branch
Internet Address {URL) • http://www.epa.gov
Rocycled/Aecyclablo • Prinlo(/ with V1;1gntallle 011 BasecJ Inks on Recycied Paper (Minimum 30"/• Poslconsum1:1r)
March 8, 2010
Mr. Randy Bryant
Remedial Project Manager
•ENVIRONMENT• ENERGY• ENGINEERING
United States Environmental Protection Agency, Region 4
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, GA 30303-3104
Subject: Domtar Paper Company, LLC (Domtar), Plymouth, North Carolina
Operable Unit No. 1 (OU-1; Former Landfill No. 1 Area) First Quarter 2010 Leaf Litter Report
Dear Mr. Bryant:
RMT North Carolina, Inc. (RMT) on behalf of Domtar is submitting this letter and attachments to
describe site-related activities conducted during the first quarter of 2010 reporting year for the OU-1
at the Domtar Plymouth, North Carolina facility. Per the Field Sampling and Analysis Plan (FSAP: RMT
2004), leaf litter samples are collected during both the fourth quarter and first quarter annually. This
letter documents the results of the leaf litter sampling that occurred in January 2010. The
groundwater, wetland soils, and fall 2009 leaf litter sampling results were reported in the Annual
Monitoring Report Operable Unit 1 -Former No. 1 landfill Area (RMT, 2010). Attached to this letter are
the following:
11 Photographs of leaf litter sample containers (Attachment 1)
■ Summary tabl_e of leaf litter analytical results for samples collected in January 2010
(Attachment 2)
,. ■ Case narrative for mercury leaf litter samples collected in January 2010 (Attachment 3)
Leaf Litter Analyses
Leaf litter samples were collected from OU-1 sample collection containers in January 2010.
Photographs from the sampling event are included in Attachment 1. Table 1 includes the January
2010 data along with data from previous leaf litter sampling events. Mercury concentrations
observed in the January 2010 leaf litter samples ranged from 0.0245 to 0.0575 mg/kg of dry leaf weight
with an average concentration of 0.0398 mg/kg. The concentration in leaves remains below the
mercury soil ecological clean-up goal of 0.4 mg/kg dry soil. The results from the January 2010
I:\ WPGVL \PJT\00-05170\03\ L000517003-002.DOCX
30 Patewood Drive, Suite 100 • Greenville, SC 29615-353S • [phone] • [phone] FAX• www.rmtinc.com
C R_ E A T I·~ G .B A L :A N C 'Et"
Mr. Randy Bryant
United States Environmental Protection Agency, Region 4
March 8, 2010
Page 2
sampling event are consistent with the results from the December 2009 sampling event and have
shown a slight decline compared to previous first quarter sample results (since January 2006).
Mercury Deposition
As indicated in the Annual Monitoring Report for OU-1 (RMT, 2010) mercury deposition for the
monitoring period beginning on March 25, 2008 and ending on March 24, 2009 (which represents the
most recent data reported for this monitoring station), the mercury deposition rate for the Pettigrew
State Park NADP/MDN station was 9.4~tg/m2/year. Utilizing this deposition rate, the total mercury
deposition for the 87 acre (350,000 m2) No. 1 landfill is calculated to be 3.29 grams with some
percentage loss to the wetlands. In addition, there will be a small component of local precipitation
that falls directly to the ground surface that adds additional sources of mercury to the soils. The
specific mass of mercury deposited from precipitation does not need to be calculated given that
mercury concentrations in adjacent wetlands remain well below the ecological clean-up criteria of
0.4 mg/kg. Partitioning of mercury between the storm water runoff into the river, and deposition into
wetland soils is beyond the scope of this analysis.
Scheduled Events
Leaf litter samples will be discontinued consistent with recent discussions regarding the five year
review and the next five year monitoring cycle. Wetland soil sampling will be conducted once
towards the end of the next five-year period and groundwater sampling will be conducted on the
shallow wells at FL-01, FL-02, FL-03, FL-05, FL-07, FL-09 every two years within the next five-year
review period. The intermediate depth wells at these locations will be sampled once during the next
five-year review cycle.
Please contact me or Bill Morris of Domtar if you have questions or need additional information
regarding the information contained in this letter.
Sincerely,
RMT North Carolina, Inc.
B~iar&-
Senior Client Service Manager
Attachments
I:\ WPGVL \ PJT\00-05170\ 03 \ LOCKlS 17003-002. DOCX
C R .E A T I N G B I!, '. L A N C E'"
I:\ WPGVL \PJT\00.05170\03 \Lll0051700J..002.00CX
Attachment 1
Photographs
Client Name:
Domtar Paper Company, LLC
Photo No.
1
Description
Date
01/21/10
Leaf Litter Sample Collection
Container
Photo No.
2
Description
Landfill No. 1
Date
01/21/10
I:\ Wl'CVL \PJT\00-05170\03 \L000517003--0J2.00CX
Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.03
Client Name:
Domtar Paper Company, LLC
Photo No.
3
Description
Landfill No. 1
Date
01/21/10
I:\ WPGVL \Pff\00-05170\03\ L000517003-002.00CX
Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.03
Historical Leaf Litter Analytical Results
Domtar Paper Company, LLC, Plymouth, North Carolina
~~"'~ ~ r·.,.,~•--::r,.,-• r·_~ -~~ .. ,,:: .. -:._·· .. · ~:: ~·:~~,. :::·~~£0~!~N1'.~~1~,:~ ~~ ... :~.,,~~·~ .. ~·~'..~-._~.t.~./'t;.':E~·1 MEi-"E-Rl1() i [ SAMP.t:~;6JirE'.l.; _-;_;'SJ -~~---::_--.~.~•·--~ r:1itlfifo1) ,. t:~ifce,oJ\ .. :; [ Fllilli,if4):;~ f:;·~Tiifi2•[~f1 [1 EEL!°W~f'•J :.., -~~ ... ·-·" ,_...L.r---➔ '1 -~ ---~ __,:__. ... -'.) o:.:t;;; .................... .'= -...,,~
Mercury Nov-2005 0.0536 0.0491 0.0427 0.0398 0.0471
Mercury Jan-2006 0.0633 0.0788 0.107 0.0566 0.0489
Mercury Nov-2006 0.0504 0.0443 0.0358 0.0365 0.0488
Mercury Feb-2007 0.0628 0.0591 0.0479 0.057 0.0544
Mercury Nov-2007 NA 0.0189 0.0403 0.0364 0.0377
Mercury Feb-2008 0.0544 0.0486 0.0506 0.0628 0.0622
Mercury Dec-2008 0.0452 0.0343 0.0397 0.0467 0.0478
Mercury Feb-2009 0.0486 0.0375 0.0394 0.0492 0.0541
Mercury Dec-2009 0.0633 0.0268 0.0299 0.0278 0.0407
Mercury Jan-2010 0.0541 0.0307 0.0245 0.0323 0.0575
<1l Analytical results are reported in milligrams per kilogram (mg/kg) unless otherwise noted.
NA Not analyzed.
I: \ WPGVL \ PJT \00-05170 \ 03 \ UJOOS 17003-0)2. DOCX
Attachment 3
Laboratory Case Narrative
I:\ WPGVL \PJT\0(}.05170\03 \ L000517003-002. DOCX
&,.( Columbia
C:';;) Analytical ServicesM 9143 Philips Highvvay, Suite 200 I Jacksonville, FL 322561 904-739-2277I904-739-2011 fax I www.castab.com
February 19. 2010 Service Request No: JI000390
Heather Smith
RMTinc.
30 Patewood Drive
Suite 100 Patewood Plaza One
Greenville, SC 29615-3535
Laboratory Results for: Domtar, Plymouth/5171.04
Dear Heather:
Enclosed are the results of the sample(s) submitted to our laboratory on January 27, 2010. For
your reference, these analyses have been assigned our service request number Jl000390.
All analyses were performed according to our laboratory's quality assurance program. The test
results meet requirements of the NELAP standards except as noted in the case narrative report.
All results are intended to be considered in their entirety, and Columbia Analytical Services, Inc.
(CAS) is not responsible for use of less than the complete report. Results apply only to the items
submitted to the laboratory for analysis and individual items (samples) analyzed, as listed in the
report.
Please contact me if you have any questions. My extension is 4408. You may also contact me via
email at [e-mail].
Respectfully submitted.
Columbia Analytical Services, Inc.
~~ Ii~~
Tom Kissinger
Project Manager
Page I of -1,
CAS Jacksonville is NELAC-accredited by the State of florida, #E82502. Other state accreditations
include:, Georgia, #958; Kentucky, #63; Louisiana, #02086; North Carolina, #527; South Carolina,
#96021001; Texas, #Tl04704197-09-TX
1
Client: RMT Inc. Service Request: Jl000390
Project: Domtar, Plymouth/5171.04
SAMPLE CROSS-REFERENCE
SAMPLE# CLIENT SAMPLE ID DATE TIME
Jl000390-001 FLLL-01 1/21/10 00:00
Jl000390-002 FLLL-03 1/21/10 00:00
Jl000390-003 FLLL-04 1/21/10 00:00
Jl000390-004 FLLL-05 1/21/10 00:00
Jl000390-005 FLLL-06 1/21/10 00:00
2
Printed 2119110 15:52 Sample Summary Page 1 of I
commma Ana1ynca1 ~erv1ces, tnc.
, . Cooler Receipt Form ~--··-Q f\r\\ I \ )/'",(V\_ -\-a...A_ Service Request #: Client: 7"Slo~J9o
Project: s,,~·.o~ ~ Cooler received on \·d-7•\.D and opened on ~ -.:\.1 · I l)y
COURIER: CAS UPS ~DE~ Client Other Airbill # 1$ 7 \ ~ lDOY \ 9. o '-1.9
I Were custody seals on outside ofcooler? (Yes l No
If yes, how many and where? Q-;:, on lid) other
-2 Were seals intact and signature and date correct? (Yes 1 No NIA
~
3 Were custody papers properly filled out? / Yes "\ No NIA
4 Temperature ofcooler(s) upon receipt (Should be 4 +I-2 degrees C) _._\_ . ' ------------
5 Thermometer ID _Tl ( 0 --------
6 Temperature Blank Present? Yes cEO
7 Were lee or lee Packs present ( · 1ce "\ lee Packs No
8 Did all bottles arrive in good condition (unbroken, etc .... )? -,.,..es ·) No NIA
9 Type of packing material present -n ' -10 Were all bottle labels complete (sample ID, preservation, etc .... )? r--·res, No NIA
· I I Did all bottle labels and tags agree with custody p_apers? ( Ycs1 No NIA
12 Were the correct bottles used for the tests indicated? • ( Yes') No NIA
13 Were all of the preserved bottles received with the appropriate preservative? Yes No ~
HN03 pH<2 H2S04 pH<2 ZnAc2/NaOH pH>9 NaOHpH>l2 HCl pH<2
Preservative additions noted bel0:w
14 Were all samples received within analysis holding times? ~ No NIA
-15 \Vere VOA vials checked for absence of air bubbles? If present, note below Yes No rf<IA )
16 Where did the bottles originate? CAS (Client~
Sample ID Reagent Lot# ml added Initials Date/Time
Additional comments and/or explanation of all discrepancies noted above:
3
Client approval to run samples if discrepancies noted: Date:
SR.' J /vOuJ'io Dale\·d:\·\D lnlllalscoo
Jacksonville Laboratory
Condition Upon Receipt -Sample pH
Note that pH Is check and meets the required pH criterion ltsted in the column heading unless otherwise noted on the oooler receipt fonn.
2 3-I 4 I 5
40ml 40ml 40ml 1125m1112sm
Container G G
~p HCI Ha2S203 HCI
<2 !i.N/. <2
Sample# . .
-001
-002
-003
-004
-005
-OOG
-007
-008
-009
-010
-011
-012
-013
-014
-015
-016
-017
-018
-019
-020
-021
-022
-023
--024
-025
-026
-027
-028
-029
-030
-031
-032
-033
-034
-035
..J:ll:,5
-037
-038
-039
-040
6 7
125ml 125m
p p
H2S04 HNO
<2 <2
Bottle Code
8 9 10 11 12 13 14 15 16 17 18 I 19 I 20 I 21 22 I 23 24 1 25 I 26 I 27 28 29 l 30 I 31
50m 250ml 250ml 250ml 250ml 50ml 50m =Om KQOm 500ml OOmU500mU 1l t 1L 1L I 1L 1l I 2oz I 4oz I 6oz 16oz 100ml 1._._~1Mlsc. ~ p p Z~2 p t,-~-G l~I P P P~P P G I G G ... G G. ~. ~-p ~lsc.
H2S04 HNO3 NaOH NaOH ~j~ [~U HCI H2S"' HNO , HNO ,... .. HCt H2S04 . Thlosulfa
4 _<.:;2--;_<.:;2-l-->-'-9--l-_>_1'-'2'-!'•:::N,:t:,N'I, _<.:;2-l'r,.,N:::ll<.::;....;<2'-i_<.:2;,...i_<.:;2_: / <2 Alll,i-"<C:24'=<2~ I , ia~t, IC . -
I .
' . .
NOTE: VOA pH checks are perfonned by the anatytlcal area, not safllP1o control
-001
-002
-003
-004
-005
-006
-007
-008
-009
-010
-011
-012
-013
-014
015
-016
-017
-013
-019
-020
-021
022
-023
-024
025
-026
-027
-028
. 029
-030
-031
-032
-033
-034
-035
036
-037 . 038
039
.0,0
RMT CHAIN OF CUSTODY RECORD
30 Patewood Drive, Suite 100, Patewood Plaza One, Greenville, SC 29615-3535
Phone [phone] • Fax [phone]
Proj09-N.97{ If. 7 I t , 67 Project/Client DO Mt/fR \ Pl'( /11, 00, TT-{
Project Manager/Contact Person:
/V111,E ~ .~/<E;R--/f€ft THe-fe. ~M l-r!-{
Lab No. y;;p/Q
Date Time Sample Station ID
FLLL-01
P LU--b.3
FL-LL,,. OJ./-
FlLl.-05""
L/..L--ob
~ ~ .. ~ Jl .. E .5 ~ ~ 0 Zc "' -

0

i J;!V
t-2 0
LJ?l}F
"
I'
a " :;;.. 11
77368
B-HN03
C-H,SO,
D-NaOH
E-HCI
f-METHANOL
G-
SPECIAL INSTRUCTIONS ·'-
e, / IPc41 qo¥f
Dote/Time Received by (Signature) Date/Time
r '2d £"'" I ·2.<..o-10 :,f;
Relinquished by (Signature) Date/Time Received by (Signature) Date/Time -\ -7-\0 0
RelulAuished by (Signature) Date/Time Received by (Signature) Date/Time
Custody Seal
F-268 (10/08)
HAZARDS ASSOCIATED
WITl-1 SAMPLES
D Flammable
D Corrosive
l i3-r-i,ghly loxic
D Other {list)
WHTTE-IABORATORY COPY
Tum Around (circle one) Normal lush
'· Report Due ---------;---
(For Lab Use Only) \
Receipt Temp: \ • \
Temp Blank Y ~
YEllOW--llEPORT APPENDIX
\
Rec~t pH
(Wet~etals)
\
~NK-SAMPl£\,;UIMfTTER
\
fA< Columbia 1"'~ Analytical Services-
Columbia Analytical Services
9143 Philips Highway, Suite 200
Jacksonville, FL 32256
Tel [phone]
Fax [phone]
Appendix A
Subcontracted Analytical Results
6
£{ Columbia e'.l Analytical Services~
Febrnary 18, 2010
Tom Kissinger
Columbia Analy1ical Services
9143 Philips Highway
Suite 200
Jacksonville, FL 32256-1365
RE: Domtar, Plymouth/5171.04
Dear Tom:
360.577.7222 36G.6~6.1068 '.fn:-:l www.caslab.com
Analytical Report for Service Request No: JI 000390
Enclosed are the results of the samples submitted to our laboratory on January 27, 2010. For your
reference, these analyses have been assigned our service request number Jl000390.
Analyses were performed according to our laboratory's NELAP-approved quality assurance program.
The test results meet requirements of the current NELAP standards, where applicable, and except as
noted in the laboratory case narrative provided. For a specific list ofNELAP-accredited analytes, refer
to the certifications section at www.caslab.com. All results are intended to be considered in their
entirety, and Columbia Analytical Services, Inc. (CAS) is not responsible for use of less than the
complete report. Results apply only to the items submitted to the laboratory for analysis and individual
items (samples) analyzed, as listed in the report.
Please call if you have any questions. My extension is 3291. You may also contact me via Email at
E [e-mail].
Respectfully submitted,
Columbia Analytical Services, Inc.
-~ W~a ca_
~fwallace
Proj eel Chemist
EW/afs Pagelof /(
ASTM
A2LA
CARB
CAS Number
CFC
CFU
DEC
DEQ
OHS
DOE
DOH
EPA
ELAP
GC
GC/MS
LUFT
M
MCL
MDL
MPN
MRL
NA
NC
NCASI
ND
NIOSH
PQL
RCRA
SIM
TPH
tr
Acronyms
American Society for Testing and Materials
American Association for Laboratory Accreditation
California Air Resources Board
Chemical Abstract Service registry Number
Chlorofluorocarbon
Colony-Forming Unit
Department of Environmental Conservation
Department of Environmental Quality
Department of Health Services
Department of Ecology
Department of Health
U.S. Environmental Protection Agency
Environmental Laboratory Accreditation Program
Gas Chromatography
Gas Chromatography/Mass Spectrometry
Leaking Underground Fuel Tanlc
Modified
Maximum Contaminant Level is the highest permissible concentration of a
substance allowed in drinking water as established by the US EPA.
Method Detection Limit
Most Probable Number
Method Reporting Limit
Not Applicable
Not Calculated
National Council of the Paper Industry for Air and Stream Improvement
Not Detected
National Institute for Occupational Safety and Health
Practical Quantitation Limit
Resource Conservation and Recovery Act
Selected Ion Monitoring
Total Petroleum Hydrocarbons
Trace level is the concentration of an analyte thatjs less than the PQL but greater
than or equal to the MDL.
2 8
Inorganic Data Qualifiers
fhe result is an outlier, Si:e case narrative.
# The control limit criteria is not applicable. See case narrative.
8 The analyte was found in the associated method blank at a level that is significant relative 10 the sample result
E The remit is an estimate amount because the value exceeded the instrument calibration range.
The result is an estimated concentration that is less than the MRL or LOQ but p-eatcr than or equal to the MDL or LOO.
The compound was analyzed for, but was not detected ("Non-detecr) at or above the MRUMDL. DOD-QSM 4.1 definition:
U Analyte was not detected and is reported as less than the LOD or a.s defined by the project The LOO has been adjusted for
dilution.
The MRUMDL or LOQ/LOD has been elevated due to a matrix interference.
X See case narrative.
Q See case namtive. One or more quality control criteria was outside the limits.
•
J
E
M
N
s
u
w
Metals Data Qualifiers
The control limit criteria is not applicable. Sec case narrative .
The result is nn estimated concentration that is less than the MRL or LOQ but RJealer than or equal to the MDL or LOO.
The percent diffCT"Cnce for the serial dilution was greater than 109/G, indicating a possible matrix interference in the sample.
Th: duplicate injection precision W1lS n01 met.
The Matrix Spike sample recovery is not within control limits. See case narrative.
The reported \-alue was determined by the Method of Standard Additions (MSA).
The compound was analyzed for, but was not detected ("Non-detecq at or above the MRL/MDL. DOD-QSM -1.1 definition:
Analyte was not detected and is reported as less than the LOO or as defined by the project. The LOO has been adjusted for any
dilution or
ll1e post-digestion spike for furnace AA analysis is out of control limit., while sample absorbanee is less than 50¾ of spike
absorbance.
The MRL/MDLor LOQ/LOD has been elevated due to a maoix interference.
X Seo "'' aan-a,;,o.
+ The correlation coefficient for the MSA is Jess th:m 0.995.
Q See case narrntive. One or more q~lity control criteria was out..ide the limits.
Organic Datn Qualifiers
The ~ult is an outlier. See ea.~e narntive.
# The control limit criteria is not applicable. See case narrative.
A A cenlativcly identified compound, a suspected aldol-condensation product
B The an:ilyte was found in the associated method blank at a level that is significant relative to th~ sample result.
C The analyte was qualitatively con.fumed using GC/MS techniques. pattern recognition, or ~y comparing to historical data.
D The reported result is from a dilution.
E The result is an estimate amount because the value exceeded the insoument calibration range.
N
p
u
The result is an estimated concentralion that is less than the MRL but greater than or equal to the MDL.
The result is presumptive. l11e analyte was tentatively identified, but a confinnation analysis was not performed.
The GC or HPLC confirmation critaia was exceeded. The relative percent difference is greater th.n 40% between tbe two
analytical results.
The compound was analyzed for, but was not detected ("Non-detect~) at or above the MRL/MDL DOD-QSM 4.1 definition:
Analyte was not detected and is reported as less than the LOO or as defined by the project. The LOO has been adjusted for any
dilution or
The MRIJMDL or LOQ.'LOD has been elevated due to a chromatographic interference.
X See case narrative.
Q See ca~ narrative. One or more quality control criteria was outside the limits.
F
L
H
0
y
z
Additional Petroleum Hydrocarbon Specific Qualifiers
The chromatographic fingerprint of the sample matches the elution pattern of the calibration standard.
The chromatographic fingerprint of the sample resembles a petroleum product, but the elution pattern indicates the presence ofa
greater amount ofligh~-r molecular weight constituents than the calibration standard.
The chromatogr.ipluc fingerprint of the sample resembles a petroleum product. but the elution panem indicates the presence of a
&-rre:ner amount of heavier molecular weight constituents than the _calibration standanl
The chromatographic fmgerprint ofthe sample resembles an oil, but does not match the calibration standard.
The chromatographic fmgerµrint of the sample resembles a petroleum product eluting in approximately the correct carbon
rangt:. but the elution p:ittt:m does not match the calibration stand.a.rd.
The chromatographic fingerprint does not resemble a petroleum product.
3 9
Columbia Analytical Services, Inc.
Kelso, WA
State Certifications, Accreditations, and Licenses
Pro2ram Number
Alaska DEC UST UST-040
Arizona OHS AZ0339
Arkansas - D EO 88-0637
California OHS 2286
Colorado DPHE -
Florida DOH E87412
Hawaii DOH -
Idaho DHW -
Indiana DOH C-WA-01
Louisiana DEO 3016
Louisiana DHH LAOSOOIO
Maine OHS WA0035
Michigan DEO 9949
Minnesota DOH 053-999-368
Montana DPHHS CERT0047
Nevada DEP WA35
New Jersey DEP WA005
New Mexico ED -
North Carolina DWO 605
Oklahoma DEO 9801
Ore_gon -OHS WA200001
South Carolina DHEC 61002
Utah DOH COLU
Washinmon DOE Cl203
Wisconsin DNR 998386840
Wyoming (EPA Re<!ion 8) -
.:.}-;;.\-.:.
.. _.(.__.;_. ,, ..
4
1meim1
10
COLUMBIA ANALYTICAL SERVICES, INC.
Analytical Report
Client: Domtar Industries Service Request: JI000390
Project: Domtar, Plymouth/5171.04 Date Collected: 01121/10
Sarn11lc Matrix: Solid Date Received: 01127/10
Mercury, Total
Prep Method: ME1110D Units: ng/g
Analysis Method: 1631E Basis: Dry
Test Notes:
Dilution Date Date Result
Sample Name Lab Code MRL MDL Factor Extracted Analyzed Result Notes
FLLL-01 ' JI000390-00I 0,9 0,2 40 02/10/10 02/12/10 54,I
FLLL-03 JI000390-002 0,9 0,2 40 02/10/10 02/12/10 30,7
FLLL-04 J1000390-003 0,9 0,2 40 02/10/10 02/12/10 24,5
FLLL-05 Jl000390-004 1.0 0,2 40 02/10/10 02/12/10 32,3
FLLL-06 JI000390-005 LO 0,2 40 02/10/10 02/12/10 57,5
Method Blank I JI000390-MBI 1.0 0,2 40 02/10/10 02/12/10 ND
Method Blnnk 2 JI000390-MB2 LO 0,2 40 02/10/10 02/12/10 ND
Method Blank 3 JI000390-MB3 1.0 0,2 40 02/10/10 02/12/10 0,3
J!00039C1cp <1jl • Sunple 02/WI0
5 11
Client:
Project:
Sample Matrix:
Sample Name:
Lab Code:
Test Notes:
Analytc
Mercury
Domtar Industries
Domtar, Plymouth/5171.04
Solid
FLLL-06
J 1000390-005,
Prep Analysis
Method Method
METHOD 1631E
Jl000390icp.djl. OMS 02116110
COLUMBIA ANAL YflCAL SERVICES, INC.
QNQC Report
Matrix Spike/Duplicate Matrix Spike Summary
Total Metals
JI000390-005
Spikc Level Sample Spike Result
MRL MS OMS Result MS OMS
1.0 105 104 57.5 152 166
6
Senice Requ~st: J 1000390
Uatc Collected: 0 l/21/10
Date Received: 01/27/10
Date Extracted: 02il0/10
Date Amllyzed: 02/12/10
Units: ng/g
Basis: Dry
Percent Recovery
CAS Relative
Acceptance Percent
MS DMS Limit., Difference
90 104 70-130 15
12
Re~uJt
Notes
Client:
Project:
LCS Matrix:
COLUMBIA ANALYTICAL SERVICES, INC.
QNQCReport
Domtar Industries Service Request: JI 000390
Domtar, Plymouth/517\.04 Date Collected: NA
Date RcceiYCd: NA
Date Extracted: NA
Date Analyzed: 02112/10
Water
Ongoing Precision and Recovery (QPR) Sample Summary
Total Metals
Sample Name: Ongoing Precision snd Recovery (Initial) Units: ng/L
Basis:. NA
Test Notes:
CAS
Percent
Recovery
Prep Analysis True Percent Acceptance Result
Analytc Method Method Value Result Recovery Limits Notes
Mercury METIIOD 1631E 5.00 5.62 112 70-130
J IOOOJ90icp dj! • OPR (lc1w) 0'.!116/10 Page No.:
7 13
COLUMBIA ANALYTICAL SERVICES, INC.
Client:
Project:
LCS Matrix:
Domtar Industries
Domtar, Plymouth/5171.04
Water
QA/QC Report
Service Request: !1000390
Date Collected: NA
Date Received: NA
Date Extracted: NA
Date Analyzed: 02112/10
Ongoing Precision and Recovery (OPR) Sample Summary
Total Metals
Sample Name: Ongoing Precision and Recovery (Final)
Test Notes:
Prep Analysis True
Analyte Method Method Value Result
Mercury METIIOD 1631E 5.00 5.54
Jl000390ocp.rljl · OPR (lm,}(2) 0l/16/10
8
Percent
Recovery
111
Units: ng/L
Basis: NA
CAS
Percent
Recovery
Acceptance
Limits
70-130
Result
Notes
P~No:
14
COLUMBIA ANALYTICAL SERVICES, INC.
Client:
Project:
LCS Motrix:
Domtar Industries
Domtar. Plymouth/5I71.04
Water
Sample Name: Quality Control Sample
Test Notes:
Prep
Analytc Method
Mercuiy MEIBOD
J IOOOJ90icp djl . QCS {IC\/} 02/JNIO
QNQCReport
Quality Control Sample (QCS) Summary
Total Metals
Analysis True Percent
Method Value Result Recovery
163IE 5.00 5.77 115
9
Service Request: JJ000390
Date Collected: NA
Date Received: NA
Date Extracted: 02/I0/10
Date Analyzed: 02112/10
Units: ng/L
Basis: NA
CAS
Percent
Recovery
Acceptance Result
Limits Notes
70-130
P-g,:No.:
15
Intra-Network Chain of Custody
9143 Philips Highway• Jacksonville, FL32256 • 904·739-2277 • FAX [phone]
Project N1mr: Domtar, Plymouth
Projrrt N'umbrr: 5171.04
Projecl Mana~er: Diane Hardison
Company: Domtar Pnper Company, LLC ~~ .... ~
C C _, la-
;§ ;§ _, -
.. M :: ::e
CAS Contact: Tom Kissinger I
;!JiL
'° ......
Sample Date
Lab Code Client Sample ID II or Cont. Matrix Date Time Received Send To
JI000J90-001 FLLl,01 j Solid 1/21/10 0000 1/27/10 KELSO II n
JI 000390-002 FLLL-03 Solid 1/21/10 0000 1/27/10 KELSO II II
JI 000390-003 FLLL-04 Solid 1/21/10 0000 1/27/10 KELSO II II
JI 000390-004 FLLL-05 I Solid 1/21/10 0000 1/27/10 KELSO II II
' JI 000390-005 FLLL-06 I i Solid . 1/21/10 0000 1/27/10 KELSO II II
0
Special lnslruclions/Comments Turntround Rt'quitrmrnls Rrpart Rrqulrrmrnb Invoice Information
__ RUSH (Surchnrges Apply) __ I.Results Only
L,_ II. Results+ QC Summaries
PLEASE PLEASE CIRCLE WORKDAYS PO#
SEND I 2 3 4 5 __ Ill Result~+ QC and C:dibr:ilion Summa,ies )1000390
RESULTS TO ✓sTA1'DARD __ IV. Dola Vnlidation Report with Raw Data
MANDY SULLIVAN Requested FA...X Date: PQUMDUJ ..L Dill to
Requested Report Dmc:
EDD .1L 02/16/IO
Relinquished Il)~ Airbill Number:
l':iv.e !
Columbia Analytical Services, Inc. PC [u.J
Cooler Receipt and Preservation Form
Client I Project:_----""C;"'✓'"'>c.-· ~ • .L-'h"';J""-'~'-'-"'-' =-."-.::' &,,,¼,,:__ _______ Service Request Kl O _ __:Jc..:...l"-O-"CJ"'<l_,<.....:.q.-"''i) _____ _
Received: );,~}o Opened: /r~tp By: /pf;<,./
I. Samples were received via? Mail FedEx (!ffii;> DHL PDX Courier Hand Delivered
2. Samples were received in: (circle) ~ Box Envelope Other NA
3. Were custody seals on coolers? NA <iy:) N If yes, how many and where? l .,c,.,-.J-
If present, were custody seals intact? G N If presen~ were they signed and dated? d) N
·-O,'-o., l"Il:L/ ,-..~,,..tv",.,,,,..nJ~j•--:;o"u
7. · Packing material used. Inserts ~<f!Fblife ~ Gel Packs ~)~:,.,"'4/4""''"''~•-'6?"'l=l''-------
8. Were custody papers properly filled out (ink, signed, etc.)? NA &) N
9. Did all bottles arrive in good condition (unbroken)? Indicate in the table below. NA & N
IO. Were all sample labels complete (i.e analysis, preservation, etc.)? NA Q? N
11. Did all sample labels and tags agree with custody papers? Indicate major discrepancies In the table on page 2. NA {!) N
12. Were appropriate bottles/containers and volumes received for the tests indicated? NA ·(y) N
13. Were the pH-preserved bottles (see SMO GEN SOP) received at the appropriate pH? Indicate in the table below ~ Y N
14, Were VOA vials received without headspace? Indicate in the table below. {i)J. Y N
15. Was C!2/Res negative? @ Y N
Notes, Discrepancies, & Resolutions .. ·_-----------------------------------
11 Page_:ff---of. __
BA
NCDENR
1\iorth Carolina Department of Environr.ient and i\iaturai Flesources
8e\1erly Eaves PerdL:e
G<l'Jf)fnO(
Marcel Sylvestre
Director, Soil Remediation
Domtar, Inc.
395 de Maisonneuve Blvd. West
Montreal, QC H3A I L6 Canada
SUPERFUND SECTION
Oe1~ Fie1~rnan
SecretarJ
SUBJECT: Submission Status for Proposed Site Remediation at Welch Creek, Martin County,
North Carolina (DCM#20100026)
Dear Mr. Sylvestre:
We received your submissiim on February 25, 20 IO for proposed site remediation at Welch Creek
in Martfo County,' North ·carolina·. Your submission has been distributed to State agencies that
woulct'bave regulatory interest for review and comment. Furthermore, this letter notifies the US
Environmenial Protection Agency that an informal consistency review of this project by the North
Carolina Division of Coastal Management has been initiated. Please be aware that as we continue
to review this submission that we may develop questions on the proposed project that will require
that Domtar respond through the submission of additional information. The comment period will
close on March 26, 20 I 0. We intend to provide you with a response concerning conformance of
the proposed action with the State's coastal management program as soon as practicable following
the close of the comment period. Thank you for your consideration of the North Carolina Coastal
Management Program.
Sincerely,
,7 . ~~/~,,w--:c;--
Stephen Rynas, AICP
Federal Consistency Coordinator
Cc: Doug Huggett, Division of Coastal Management
, DaVid Moye, Division of Co.istal M·au~gemcnt ·
· Nile Testennan, NC Division of.,Wastc Management.
· -Rilb(I}' Bryant, US Ellvironmcntill ProtL-Ction Agency .
· t James L HutCliCns, R..\1T Noltii cafO!inii, Inc. ·
' 400 Commerce Ave., Morehead City, NC 28557-3421
Phone: 252-808·2808 \ FAX: 252·247-3330 Internet: www.nccoastalmanagement.net
An Equal Opportunity\ Affirmative Aclion Employer
N~rth Carolina ;Naturally
')\
'-=-' Domtar
Domtar Inc.
395, boul. de Maisonneuve Quest
Montreal QC HJA 1L6 Canada
T 514-848-5555
www.domtar.com
February 25, 2010
Domtar Inc.
395 de Maisonneuve Blvd. West
Montreal, QC H3A ll6 Canada
T 514-848-5555
www.domtar.com
Mr. Randy Bryant, Remedial Project Manager
Superfund Remedial/Site Evaluation Branch
United States Environmental Protection Agency, Region 4
41 Forsyth Street
Atlanta, GA 30303-8960
Subject: Response to November 15, 2009, USEPA Comment Letter Addressing
Conceptual Design Report (Welch Creek -Operable Unit 4)
Domtar Paper Company, LLC (Domtar), Formerly Weyerhaeuser Company
Plymouth, North Carolina
Dear Mr. Bryant:
Enclosed please find a summary of Domtar' s responses to the review comments provided in
your above referenced letter dated November 25, 2009. These responses have also been
incorporated into the Pre-final/Final Remedial Design Report being submitted concurrently
with this response letter. For ease of review, the original comments are presented in italics
typeface with the accompanying responses following in normal typeface.
If you have questions regarding the enclosed information, please don't hesitate to contact me.
Sincerely,
r'\_..--..---
Marcel Sylvestre
Director, Soil Remediation
Office: 514-848-5555 ext. 85324
Cell: 514-894-0083
Fax: [phone]
Email: [e-mail]
cmk/attachments
cc: Kathy Huibregtse, RMT North Carolina, Inc.
Jim Hutchens, RMT North Carolina, Inc.
Nathan Weber, RMT North Carolina, Inc.
,
Review Comments -November 25, 2009
Conceptual Design Report
Domtar Paper Company, LLC
Welch Creek -Operable Unit 4
Plymouth, Martin County, North Carolina
1. The term cover should be used in place of cap when referring to the planned 5 to 10 cm of sand to be placed
over contaminated sediment.
Response: As appropriate, references to cap will be replaced by cover when referring to the
planned 5 to 10 cm of sand as a component of the eMNR™ remedy.
2. Controlling the bioavailability of dioxin or limiting the biological uptake of COCs is mentioned several
times in the document as one of the goals for the remedy. The design of the cover and monitoring program
should demonstrate how that goal will be met.
Response: Additional information pertaining to limiting bioavailability of dioxin is included in
Section 2.3 and Table 2-2 of the Pre-final/Final Remedial Design Report. Specifically, the benthic
macroinvertebrate community in Welch Creek was evaluated with respect to the depth in which
benthics are actively feeding and burrowing. In addition, the preliminary performance
monitoring components are linked to the remedial action objectives developed for Welch Creek
eMNR™.
3. Section 1.6.1, Page 4: The upstream reach is noted with an approximate length of 5,300 feet. It is noted as
7,900 feet on Page 23.
Response: Section 3 of the Pre-final/Final Remedial Design Report (RMT, 2010) correctly defines
the upstream reach as approximately 5,300 feet in length with an average width along this length
of approximately 125 feet bank to bank. The reference on Page 23 has been changed.
4. Section 2.2.2, Page 14: It looks like there was only one core taken in the eMNR™ area. The core is not well
described. The picture shows great variability in the sand layer, ranging from about 0.8 to 2.3 cm across a
5 cm section. This does not suggest that the sand can be placed uniformly. What was the TOC of the sand
layer? A statistical meaningful number of cores (at least five) would be much more informative, and these
should be analyzed in sections based on visual characterization so that one can understand its performance.
What were the dioxin concentrations as a function of depth in the core? If other cores have been collected
from the pilot test areas, then such information should be summarized in the design documents to support
the planned configuration and placement of the sand cover.
Response: Attachment B has been added to the Pre-final/Final Remedial Design Report. It
provides a summary of the pilot program and describes the sediment dioxin data collected in
January 2005 from the eMNR™ pilot study area which demonstrates an average of 80% reduction
in dioxin concentrations for a 1 to 2 cm layer of sand (based on six core samples). In addition, the
eMNR™ pilot study fine layer Total Organic Carbon (TOC) and Total Volatile Solids (TVS) data
from August 2009 that indicates that the cap material can be placed uniformly using RMT' s
placement approach and is readily discernible. Finally, Attachment B includes a forecast of
expected dioxin concentrations and percent reduction for a 5 to 10 cm thick eMNR™ layer, as was
Page 1 i: \ wpmlw\pjt \00-05174 \03\conceptua! design report\zOJOSJ 7403-001.docx
required for implementation in the site Record of Decision (ROD). Pictures and pilot study core
samples from January 2005, October 2005, and August 2009 show limited surficial mixing, on-
going integrity of the 1 to 2 cm eMNR™ layer, and limited placement variability.
5. Section 2.2.2, Pages 14 and 15: Sa. Gas is probably being generated from the wastewater solids and leaf
litter, and not particularly a function of the cap. The hogged fuel probably adds structure that limits the
ability of the cap to pass the gas. Sb. The description of the comparison of eMNR™ and the sand cap with
hogged fuel suggests that significant mixing occurred in the eMNR™ area, suggesting that a greater
thickness of sand is needed to provide the desired reduction in bioavailability.
Responses:
Sa. We agree that gas is expected from the highly organic solids and will vent easily through the
5 to 10 cm sand cover. The hogged fuel combined cap was not the selected remedy for the
site.
Sb. The response to Comment 4 addresses the amount of observed mixing in the eMNR™
covered area. There was very limited mixing even with the 2.5 cm thickness placed during
the pilot study. The targeted thickness of the eMNR™ cover to be placed over exposed
sediment in the final remedy is specified in the ROD to be 5 to 10 cm. This eMNR™ cover
thickness is based upon defined site-specific bioactive zone thickness of 5 cm and was then
confirmed with an evaluation of published information on the behaviors of tubiforous
benthic macroinvertebrates (Appendix B). The actual thickness of the placed cover material
will vary somewhat depending upon the physical characteristics of the cover material being
placed, roughness and magnitude of debris extruding from the sediment, the slope of the
near shore submerged creek banks, and slope of the creek bottom.
6. Section 3.2, Page 21: Targeted thickness is usually increased by the variability and uncertainty of
placement methods and the quantihJ of mixing with or penetration in the sediment layer. Therefore, the
actual placement thickness is generally 5 to 10 cm greater than the target thickness.
Response: Cover placement techniques and thickness are further described in Sections 3 and 4 of
the Pre-final/Final Remedial Design Report as well as the Construction Specifications included as
part of the Pre-final/Final Remedial Design Report. Due to the very soft nature of the deposited
wastewater solids in the creek, additional cover thickness is not desirable and could compromise
the overall integrity of the cover if placed too rapidly. Targeted placement thickness is presented
in the bid specifications and will be closely monitored during construction.
7. Section 3.2, Page 22: There are a number of erosion control and slope stability products available on the
market that may be able to aid stability on steep side slopes. However, the use of such products would have
to consider the risk reduction that would be achieved in those particular areas and also any limitations that
may arise from installing such products from the shore in wetland areas.
Response: The percentage of side slope that may not be able to maintain a 5 to 10 cm sand cover is
estimated to be approximately 6% of the total 5,300 foot upstream reach. Based upon the small
(6%) of the area which may not support a 10 cm cover, the large quantity of debris present along
the banks and the variability in side slopes which complicate consistent coverage, supplemental
Page2 i: \ wpmlw\pjt\00-05174 \03\i:onceptu.il design report\zOOOSI 7403--001.docx
,
side slope stabilization products were not evaluated further in this part of the design. The risk
reduction from additional slope coverage is therefore considered minor when considered in the
context of the entire creek system.
8. Section 3.3.3, Page 24: Ba. Bioturbation is often greater where the benthic community is more diverse, so is
5 cm adequate on the side slopes? Bb. 10 cm of sand on the bottom does not provide much of a buttress.
Consolidation of the bottom could induce sloughing on the side slopes. The material should be placed across
the entire area working from the middle to the sides. Be. Why should the target thickness include naturally
accumulated sediment or debris? Sd. If these areas have clean sediment or debris on top of the wastewater
solids, then is it necessary to cover these areas? Is there sufficient data to know if they are clean? Be. The
thickness should be visually verifiable.
Responses: These issues are addressed in Section 2.4, Table 2-2, and Attachment A. Summarized
responses are also included below.
Sa. Based upon the dominant benthic communities which are epi-faunal and, as such have limited
contact with sediment the 5cm thickness should be adequate. Furthermore, the presence of
leaves and debris above any infauna! organisms along the sides, limit the transport of dioxin
into the water column.
Sb. The cover material placement will be applied from the middle of the creek to the edges.· In
addition, the cover material along the sides will have a different particle size distribution to
limit sloughing.
Sc. The cover thickness will not include measurement of the leaf pack.
Sd. Cover will be placed from bank to bank.
Se. Core samples and other observations will be used to confirm the thickness of the cover after
placement.
9. Section 3.3.3, Pages 25 and 26: 9a. Has there been an attempt to estimate the deposition rate in the
eMNR™ areas? What is the deposition of organics in kg/sq meters? 9b. Sand provides very little reduction
in bioavailability. A mixed substrate of top soil with sands, fines, and organics would provide better
reduction in bioavailabiliti;. Mixed media would reduce the loadings or stresses on the sediment because its
deposit would be less dense. 9c. Accuraci; is usually limited to an inch or two in well controlled placement
operations. A planned placement of 7.25 to 12.5 cm would provide better assurance of coverage given the
expected variability along the surface of the creek bottom and the placement thickness of the cover. 9d. The
presence of woody debris will add to the variability of the placement, but should add stability to the side
slopes.
Responses:
9a. The natural deposition rate is low given the size of the drainage area and the local
topography. Although a deposition rate was not calculated, the time for natural recovery
was estimated. After inputting site specific data, especially the low measured upstream
base load TSS, into the USA COE RECOVERY model, it was estimated that the natural burial
Page 3 !:\ wpmlw\pjt\00-05174 \03\conceptual design report\z00:1517403-001.doo
u ,
would take about 50 years for the surficial concentrations to reach the clean-up level of 1 ppb
dioxin (I-TEQ) (see Table 2-2).
9b. The recovery of the benthic community after pilot tests was rapid over both the 2.5 cm eMNR
0153 cover and the 24 cm of hogged fuel/sand cap. Furthermore, visible organic deposits
were observed over the covers within months of sand placement. Thus, an amended cover is
not being considered.
9c. The placement method is quite precise. The stated cover thickness in the ROD provides 5 cm
of safety factor for the placement.
9d. Comment noted.
10. Section 3.3.3, Page 26: Recolonization is best when the cap material is similar to the existing sediment
substrate. Bioturbation depths are not likely affected by thickness used in eMNR™ since many organisms
will go that deep to find food, particularly if the surface material is aerobic as sand is likely to be due to its
low oxygen demand.
Response: For Welch Creek, the selected remedial action for the upstream reach of a thin layer
sand cover is consistent with the identified manageable properties and updated Conceptual Site
Model. Isolation of contaminated sediment below a cover layer that limits bioturbaction (the
bioactive layer) will reduce dioxin release and the associated transfer of contaminants from
sediment to benthic infauna. Although the sand layer will be aerobic initially, the oxygen will be
rapidly depleted in this blackwater environment.
Specific published information that defined feeding depths is limited for many of the benthic
organisms identified in Welch Creek. However, review of the existing literature and enumerated
species suggests that the typical feeding depths range from 2 to 8 cm, with majority within the 2 to
5 cm in the soft bottom sediments of Welch Creek. Application of a sand cover will reduce these
burrowing depths since these organisms prefer borrowing in soft sediments. Appendix A of the
Pre-final/Final Remedial Design Report provides additional details on Welch Creek benthic
community and the corresponding feeding depths associated with the benthic community
inhabiting the creek. A fairly rapid recovery of the benthic community was observed in the
eMNR™ test area. The pilot studies along with literature information indicates that
recolonization will occur within a year or less, with benthic recovery occurring in the first few
years after the creek reaches a steady state. Recolonization will be assessed as part of the long-
term performance monitoring program.
11. Section 3.3.3, Page 23: Is data sufficient to distinguish where contaminated materials are present in the
main channel of the creek as opposed to the shallows (less than 2 to 3 feet below water surface)? If so, will
that have a bearing on the extent of the cover relative to distance from the creek banks?
Response: The eMNR™ cover will be placed from bank to bank following procedures described
in Sections 3 and 4 of the Pre-final/Final Remedial Design Report. With respect to the shallow
sides, the dominant benthic organisms in the near shore areas of Welch Creek consist of a different
Page4 i: \ wpmlw\pjt\00-05174 \03\oonceptual design report \z00)5J7403-00Ldocx
class of epi-faunal benthic species living on debris and leaf packs. These organisms have only
limited contact with the underlying sediment in contrast to benthics inhabiting the bottom portion
of the creekbed which provides habitat for low oxygen tolerant tubiforous organisms that can
transfer the soft sediments into the water column. Any infauna! benthic species that are present in
the limited areas of sediment deposits on the near bank surfaces under leaf pack have less direct
interface with the water column so their potential to recontaminate the cover surface is further
reduced with the sand cover. Thus, the targeted cover thickness across the entire creek is 5 to
10 cm with the expectation that some areas will be more suitable for placement such as the
thalweg as opposed to steeper side slopes.
12. Section 3.3.4: What will be measured for mobility monitoring -bed load, TSS, dioxin? Will sediment traps
be used? How will monitoring be activated? What events will be used for monitoring?
Response: Short-term surface water mobility monitoring will include TSS and dioxin monitoring.
In addition, surface water sampling will be utilized to determine if dioxin impacted sediment
mobilize and remain in the water column during high flow events (5-to 10-year flow event
range). Additional information on the performance monitoring program will be included in the
Performance Standards Verification Plan. Performance monitoring forms the basis for on-going
remedy evaluation and detailed remedy review at 5-year intervals. The results of the short-term
mobility monitoring will be assessed as a component of the 5-year review process.
13. Section 3.4.5 on Institutional Controls: A deed notice is part of the NCDENR institutional controls.
NCDENR requires two additional items: a declaration of Perpetual Land Use Restrictions Document
(DPLURD) and a plat map. These items should be prepared for the operable unit that requires institutional
controls.
Response: As described in Section 6 of the Pre-final/Final Remedial Design Report, a declaration
of DPLURD along with a plat map will be prepared consistent with NCDENR requirements and
submitted as a component of the remedial action documentation.
14. Section 3.3.5, Pages 28 and 29: This section should note the collection and use of fish tissue data as
contemplated for the long term monitoring. We have recently discussed other techniques such as SPMDs or
SPMEs as another performance measure. The SPMD or SPME will measure dissolved concentrations of
contaminants in pore water or surface water (which is not considered the predominant exposure pathway).
However, pore water concentrations are expected to be in equilibrium with the sediment concentrations so
the results could be considered a surrogate for the potential bioavailability of dioxin in sediment. I
understand that RMT is reviewing other possible testing methods that could be used as another line of
evidence for performance monitoring.
Response: Section 5 of the Pre-final/Final Remedial Design Report presents a framework for the
multiple lines of evidence approach needed to assess the Welch Creek remedy. Additional tools
or techniques for evaluating pre-and post-construction monitoring of dioxin concentrations will
be evaluated as part of the baseline performance monitoring sampling activities to be performed
in March 2010. The information from these data collection activities will be assessed for use as
part of the long-term remedy performance evaluation. The results of this evaluation will be
Page5 i: \ wpmlw\pjt\()().{l5174 \03 \conceptual design report\z000517403--001.docx
incorporated into the Performance Standards Verification Plan required to be submitted during
the remedial action.
15. a. SW A Cs are not generally appropriate criteria if the cover materials are dissimilar from the sediments.
Normalized concentrations should be used to more accurately address bioavailability.
b. Won't the benthic organisms preferentially seek to feed on organic matter, ignoring the mineral material
of the sand?
Responses:
15a. SWAC for Welch Creek corresponds to mass of dioxin per mass of sediment within the top
5 cm (the defined bioactive layer) over a specific area. The purpose for using SWAC as a
measure of remedial success is motivated from the notion that risk to resources within the
Welch Creek aquatic system is proportional to exposure to dioxin. Further, the agreed upon
conceptual model indicates exposure is proportional to the concentrations within the
biologically active layer of sediment. The facilitated meeting agreements indicated that
utilizing SWAC for assessing conditions at Welch Creek was appropriate. SWAC has been
used for identifying the preliminary upstream reach area by comparing SW AC to the
preliminary remedial goals. Thus, SW AC will be used for comparison to the ROD based
clean-up criteria of 1 ug/kg. SWAC updates will be used to evaluate site recovery and
remedy effectiveness in the eMNR™ cover area.
15b. As indicated in Attachment A of the Pre-final/Final Remedial Design Report, multiple
benthic studies conducted in Welch Creek as part of the RI/FS, and during a supplemental
review of the Welch Creek benthic data that synthesized available life history information in
the literature and identified Welch Creek taxa. This review determined that most of the
dominant taxa are shallow burrowers, not expected to impact the 5 or 10 cm eMNR™ cover
proposed for Welch Creek.
16. Table 3-1, Upstream Reach, Sediment: Pore water dioxin concentrations using SPME or other device
should be measured as well as TOC. Performance monitoring needs discussion.
Response: Additional tools or techniques for monitoring of dioxin concentrations will be
evaluated during baseline performance monitoring sample collections to determine which
methodology is applicable to Welch Creek. The Performance Standards Verification Plan will
outline additional information to be included in the performance monitoring program.
17. Table 3-1, Upstream Reach, Surface Water: TOC and DOC should be measured. Performance monitoring
needs discussion.
Response: Surface water monitoring during construction activities are described in Section 4 of
the Pre-final/Final Remedial Design Report. As noted, TOC and DOC have been included to the
sampling program. Long-term monitoring will be further refined as a component of the
performance monitoring plan. The Performance Standards Verification Plan will outline
additional information to be included in the performance monitoring program.
Page6 i: \ wpmlw\pjt\00--05174 \03\conceptual design report\z000517403-0)J.dm:x
18. Table 3-1, Midstream Reach, Surface Water: Grain size, TOC, and DOC would also be useful.
Response: Surface water monitoring will be further refined as a component of the performance
monitoring program. These parameters will be included as well as other applicable lines of
evidence. The Performance Standards Verification Plan will also outline how the additional
information will be used to more fully evaluate remedy success.
19. Table 3-3: This table is not discussed in the text. These sample numbers are very low. Will future
iterations include enough samples to be statistically meaningful?
Response: This table has been replaced with Figure 5-1 to provide a preliminary program for the
monitoring activities during implementation, short-term (0 to 5 years) and long-term (5 to
10 years). The Performance Standards Verification Plan will outline additional information (e.g.,
sample numbers) to be included in the performance monitoring program.
20. Figure A-0: What is transect SUP-13?
Response: This transect is located upstream of the project area and reference to it has been
removed from the document.
21. Appendix C, Table C-1: These TOC values appear atypical. Expected TOC values for wetland materials
would be about 50,000 mg/kg while the median of these samples is about 100 mg/kg. How can hogged fuel
have a carbon content of only 4,200 mg/kg? Wood should be mostly carbon and has a TOC approaching
500,000 mg/kg. How can the moisture of most of the samples be 0.1%? These are saturated samples.
Similarly, the TVS are too low. Hogged fuel should be mostly volatile and the TVS should be comparable to
the TOC. .
Response: Appendix C, Table C-1 was referencing incorrect information with regard to the TOC,
Moisture, and TVS from samples collected during from the pre-design activities. The table has
been corrected and a revised version of the table has been included.
Page 7 i: \ wpmlw \ pjt \00-05174 \ 03 \ conceptual design report\ zOOOS 17403.001.docx
Letter of Transmittal ,~((;
RMT, Inc.
150 N. Patrick Boulevard, Suite 180
Brookfield, WI 53045-5854
Tel. [phone] • Fax [phone]
To: Nile Testerman, NC DWM
Tom Augspurger, US FWS
Michel Geilazyn, NOAA
Kyle Barnes, NC DWQ
Lynn Henry, Division of Marine Fisheries
Chad Thomas, NC Wildlife Resources
Raleigh Bland, USAOE
Prepared By: Kathy Huibregtse
Date: 10/7/09
Project No.: 00-05174.03
' ocr 092009
SUPER FUND SECT/ON
Subject: Conceptual Design Report
At the request of Randy Bryant from the USE!' A, RMT is pleased to send an electronic copy of the
Welch Creek Conceptual Design Report prepared under the direction of Domtar Paper Company, LLC.
This report is for your review and comment back to USEPA.
Please let us know if you need a paper copy as well as the enclosed electronic version. Thanks for your
continued attention to this project.
cc (w/o attachments): Randy Bryant, USEPA
Marcel Sylvestre, Domtar
Bill Morris, Domtar
Kathy Huibregtse, RMT
l;\l'Jl'00-0517,1\UJ\CONCEl'TUAI, DESIGN REJ'ORT\l.ll0!1517,I0.1-002.I )OCX 10/7/ll'i 'l'Ht\,\JSl.'rl,/.1.JOC l'Ol<~1 FX\•! (ll-1/2-1/01)
,~(i}~#fy RA (_l<,jl ~~ NCDENR suPr:,::;;,, s ?o,o I/;;
Beverly Eaves Perdue
Governor
North Carolina Department of Environment and Natural Resources ~.11110 S£c
Division of Coastal Management 1/0fi;
James H. Gregson Dee an
Director Secretary
TO: Nile Testerman
Superfund Section
MEMORANDUM
March 3, 2010
Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
FROM: Stephen Rynas, AICP; Federal Consistency Coordinator
SUBJECT: Proposed Site Remediation at Welch Creek (DCM#20100026)
LOCATION: Welch Creek, Plymouth Mill Site, Martin County, North Carolina
This document is being circulated for an informal consistency review and comment by March 26, 2010.
Domtar (formerly Weyerhaeuser) is proposing site remediation at the Plymouth Mill Site in Martin County.
While Martin County is not a coastal county, the proposed project has the potential to affect coastal
resources within Washington County, which is a coastal county. Site remediation is being proposed due to
the presence of dioxin and furan contaminati~associated with wastewater treatment solids located in
portions of the sediments located in Welch Creek. Welch Creek flows into the Roanoke River. Your
responses will assist us in determining whether the proposed project would be consistent with the State's
Coastal Management Program. If the proposed project does not conform to your requirements, please
identify the measures that would be necessary to bring the proposed project into conformance. If you have
any additional questions regarding the proposed project you may contact me at 252-808-2808 or email me
at [e-mail].
REPLY: No Comment.
This office supports the project as proposed.
Comments to this project are attached.
This office objects to the project as proposed.
Signed:___________________ Date: _______ _
CORRECTIONS: Please identify any corrections, additions, or deletions that should be made in terms
of contact information.
RETURN COMPLETED FORM TO:
Stephen Rynas, Federal Consistency Coordinator
NC Division of Coastal Management
400 Commerce A venue
Morehead City, NC 28557-3421
400 Commerce Ave., Morehead City, NC 28557-3421
Phone. [phone] \ FAX: [phone] Internet: www.nccoastalmanaqement.net
An Equal Opportunity\ Affirmative Action Employer
NirthCarolina )Vaturallu
p--RECEIVED
MA MAR 2 4 2010
HCDEHR Morehead City DCM
North Carolina Department of Environment and Natural Resources
Division of Coastal Management
Beverly Eaves Perdue
Governor
TO:
James H. Gregson
Director
MEMORANDUM
March 3, 2010
Maria Dunn
Division of Inland Fisheries, Habitat Conservation Program
NC Wildlife Resources Commission
943 Washington Square Mall
Washington, NC 27889-1638
FROM: Stephen Rynas, AICP; Federal Consistency Coordinator
SUBJECT: Proposed Site Remediation at Welch Creek (DCM#20100026)
LOCATION: Welch Creek, Plymouth Mill Site, Martin County, North Carolina
Dee Freeman
Secretary
This document is being circulated for an informal consistency review and comment by March 26, 2010.
Domtar (formerly Weyerhaeuser) is proposing site remediation at the Plymouth Mill Site in Martin County.
While Martin County is not a coastal county, the proposed project has the potential to affect coastal
resources within Washington County, which is a coastal county. Site remediation is being proposed due to
the presence of dioxin and furan contamination associated with wastewater treatment solids located in
portions of the sediments located in Welch Creek. Welch Creek flows into the Roanoke River. Your
responses will assist us in dctennining whether the proposed project would be consistent with the State's
Coastal Management Program. If the proposed project does not conform to your requirements, please
identify the measures that would be necessary to bring the proposed project into conformance. If you have
any additional questions regarding the proposed project you may contact me at 252-808-2808 or email me
at [e-mail].
REPLY: No Comment.
'This office supports the project as proposed.
Comments to this project are attached.
This office objects to the project as proposed.
Signed: __ .LM-".j.1,£;,,"1 . .Lll '--'4-J -'-' u....,,"c::"::"-'----------\
Date:
CORRECTIONS: Please identify any corrections, additions, or deletions that should be made in terms
of contact information.
RETURN COMPLETED FORMTO:
Stephen Rynas, Federal c;:onsistency Coordinator
NC Division of Coastal Management
400 Commerce A venue
Morehead City, NC 28557-3421
400 Commerce Ave., Morehead City, NC 28557-3421
Phone: [phone] \ FAX: [phone] Internet: www.nccoastalmanagement.net
An Equal Opportunity\ AHirmati~e Action Employer
0~\.,c 1· No1u1 aroma Naturally
§ North Carolina Wildlife Resources Commission§
Gordon S. Myers, Executive Director
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
Stephen Rynas, Federal Consistency Coordinator
Division of Coastal Management
North Carolina Department of Environment and Natural Resources
Maria T. Dunn, Northeast Coastal Region Coordinator
Habitat Conservation Program
March 23, 2010
' ---,·'.,').:,J::~:
Consistency Submission for Welch Creek, Plymouth Mill Site, Martin County,
North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
consistency determination with regard to impacts on fish and wildlife resources. Our comments are
provided in accordance with provisions of the Coastal Area Management Act (G.S. l l 3A-l 00 through
l 13A-128), as amended, and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C.
661 et seq.).
Domtar (formerly Weyerhaeuser) is proposing site remediation in Operable Unit 4 at the
Plymouth Mill Site in Martin County. The "Pre-final/ Final Remedial Design Report, Welch Creek
Operable Unit 04" presents actions as defined by the Record of Decision dated September 2007. State
and federal resource and regulato,y agencies, including the NCWRC, participated and contributed to
ideas and concerns regarding the report and remedial measures. Within the report, Domtar proposes to
selectively remediate Operable Unit 4 in Welch Creek by conducting Enhanced Monitored Natural
Recove,y ( eMNR) and debris removal within the project area. Details of these procedures as well as
maintenance and monitoring are found within the report. Additional measures to protect the public from
contaminants within Welch Creek include fish consumption advisories, signage stating consumption
advisories, fencing to prevent access to the Welch Creek area, and deed notification for future land
owners of Domtar property regarding the remediation easement and land / water use restrictions.
The NCWRC has reviewed the report and believes actions within the document should be
considered consistent with NC Division of Coastal Management regulations. However, we request an in-
water moratorium be enforced to protect valuable aquatic resources. A moratorium ofFebrua,y 15 -
September 30 of any year should be enforced for all in-water activities including snagging and clearing,
in-water debris removal, and the eMNR. Conducting these activities during the time period scheduled in
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
la, REcEn,Eo
WclchCrcekOU4RcmcdialDcsignReport Page2 / ~ iA°R°z ,f ZO/Qj
Figure 7-2 would directly impact spawning anadromous fish by covering and/ or suffoca~~l\w!W.
and juveniles. Resident species would also be impacted by the proposed actions during this timeframe. lrrAt
addition to the above statement, the NCWRC would like to state support for the concerns and
recommendations of the NC Division of Marine Fisheries regarding this project.
We appreciate the opportunity to review and comment on this consistency determination. If you
need further assistance or additional information, please contact me at [phone].
1
BA
MCDEMR
North Carolina Department of Environment and Natural Resources
Division of Coastal Management
Beverly Eaves Perdue
Governor
TO:
James H. Gregson
Director
MEMORANDUM
March 3, 2010
Brian Strong
NCDENR -Division of Parks and Recreation
512 North Salisbury Street, Seventh Floor
Raleigh, NC 27604-1170
· FROM: Stephen Rynas, AICP; Federal Consistency Coordinator
SUBJECT: Proposed Site Remediation at Welch Creek (DCM#20100026)
RECF.fll':D
MAR 2 9 2010"
Morehead City DCM
LOCATION: Welch Creek, Plymouth Mill Site, Martin County, North Carolina
Dee Freeman
Secretary
This document is being circulated for an informal consistency review and comment by March 26, 2010.
Domtar (formerly Weyerhaeuser) is proposing site remediation at the Plymouth Mill Site in Martin County.
While Martin County is not a coastal county, the proposed project has the potential to affect coastal
resources within Washington County, which is a coastal county. Site remediation is being proposed due to
the presence of dioxin and furan contamination associated with wastewater treatment solids located in
portions of the sediments located in Welch Creek. Welch Creek flows into the Roanoke River. Your
responses will assist us in determining whether the proposed project would be consistent with the State's
Coastal Management Program. If the proposed project does not conform to your requirements, please
identify the measures that would be necessary to bring the proposed project into conformance. If you have
any additional questions regarding the proposed project you may contact me at 252-808-2808 or email me
at [e-mail].
REPLY: No Comment.
This office supports the project as proposed.
Comments to this project are attached.
This office objects to the project as proposed.
Signed: JAMf1 el{~ Date:
CORRECTIONS: Please identify any corrections, additions, or deletions that should be made in terms
of contact information.
RETURN COMPLETED FORM TO:
Stephen Rynas,-Federal Consistency Coordinator .
NC Division of Coastal Management
400 Commerce Avenue
Morehead City, NC 28557-342 l
400 Commerce Ave., Morehead City, NC 28557-3421
Phone. [phone] I FAX: [phone] Internet: www.nccoastalmanagement.net
An Equal Opportunity\ AffirmaUve Action Employer
Ni~carolina
;Nat11rall!f
Jl;A r RECEIVED
MCDEMR MAR 2 9 2010
Morehead City North Carolina Department of Environment and Natural Resources DCM
Beverly Eaves Perdue
Governor
Division of Natural Resources Planning and Conservation
Linda Pearsall
Director
March 25, 2010
Stephen Rynas
NC Division of Coastal Management
400 Commerce A venue
Morehead City, NC 28557-3421
RE: Proposed Site Remediation at Welch Creek
DCM#20 I 00026
Dear Mr. Rynas:
Dee Freeman
Secretary
The NC Natural Heritage Program has records of rare species and Significant Natural Heritage Areas (SNHAs)
within one mile of the project area described in the request for consistency review.
The proposed remediation at the Domtar Site is within one mile of the Lower Roanoke River Aquatic Habitat
Significant Natural Heritage Area. Aquatic components of this site include an assemblage of rare stream insects
and freshwater mussels in addition to the importance of the Lower Roanoke River for the anadramous Striped
Bass. Four locations for the Watch List mayfly Ephemerel/a argo are located along the lower river as well as a
record for the rare caddisfly Ceraclea cancel/ala near Plymouth.
Rare species records reported from within one mile of the Domtar Site are listed below:
Plants:
Multiflowered Mud-plantain (Heteranthera multiflora)-NC: Significantly Rare
Animals:
Tidewater Muckel (Leptodea ochracea) -NC: Threatened
Eastern Pondmussel (Ligumia nasuta)-NC: Threatened
In addition to the species listed above, Red Wolf (Canis rufus) is known to occur in at least the eastern half of
Washington county, if not the whole county. This species is listed as NC Significantly Rare, and US
Endangered, with the population in NC considered a Nonessential Experimental Population.
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] \ FAX: [phone] Internet: www.ncnhp.org
An Equal Opportunity\ Affirmative Action Employer
0~i.c 1· No1 u1 aro 1na
)Vat11rall!f
Noturol Resources Planning and Conse1VOtion
Special planning may be needed to protect the rare aquatic species during the remediation project. The presence
of the species listed above indicates an increased potential for occurring within the project areas if suitable
habitat exists there. Please contact the NC Wildlife Resources Commission, US Fish and Wildlife Service,
and/or the NC Natural Heritage Program if these or other rare species are found within the project area. If rare
species are found, we request that you design the project to minimize impacts to the populations and their
habitat.
The use of Natural Heritage Program data should not be substituted for actual field surveys, particularly if the
project area contains suitable habitat for rare species, significant natural communities, or priority natural areas.
You may check the Natural Heritage Program database we.bsite at www.ncnhp.org for a listing of rare plants
and animals and significant natural communities in the county and on the quad map. Our Program also has a
new website that allows users to obtain information on element occurrences and significant natural heritage
areas within two miles ofa given location: http://nhpweb.enr.state.nc.us/nhis/public/gmap75_main.phtml. The
user name is "public" and the password is "heritage". You may want to click "Help" for more information.
Please do not hesitate to contact me at 919-715-8700 if you have questions or need further information.
Sincerely,
/~ B~
Misty Buchanan, Botanist
Natural Heritage Program
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] I FAX: [phone] Internet: www.ncnhp.org
An Equal Opportunity\ Affirmative Action Employer
Nirth Carolina Jvnturnl/11
Natural Rcsourm Plonning and ConseMJlion
NA RECEIVED
NCDENR MAR 2 5 2010
North Carolina Department of Environment and Natural Resources
Division of Coastal Management Morehead City DCM
Dee Freeman
Secretary
Beverly Eaves Perdue
Governor
TO:
James H. Gregson
Director
MEMORANDUM
March 3, 2010
Vivian Christy (401 Water Quality)
DWQ -401 Water Quality Certification (Washington)
NCDENR -Division of Water Quality
943 Washington Square Mall
Washington, NC 27889-1638
FROM: Stephen Rynas, AICP; Federal Consistency Coordinator
SUBJECT: Proposed Site Remediation at Welch Creek (DCM#20 I 00026)
LOCATION: Welch Creek, Plymouth Mill Site, Martin County, North Carolina
liA~ G 4 2010
This document is being circulated for an informal consistency review and comment by March 26, 2010.
Domtar (formerly Weyerhaeuser) is proposing site remediation at the Plymouth Mill Site in Martin County.
While Martin County is not a coastal county, the proposed project has the potential to affect coastal
resources within Washington County, which is a coastal county. Site remediation is being proposed due to
the presence of dioxin and furan contamination associated with wastewater treatment solids located in
portions of the sediments located in Welch Creek. Welch Creek flows into the Roanoke River. Your
responses will assist us in detennining whether the proposed project would be consistent with the State's
Coastal Management Program. If the proposed project does not conform to your requirements, please
identify the measures that would be necessary to bring the proposed project into conformance. If you have
any additional questions regarding the proposed project you may contact me at 252-808-2808 or email me
at [e-mail].
REPLY: No Comment.
This office supports the project as proposed.
~ Comments to this project are attached. D ,J ~ _ This office objects to the project as proposed.
Signed:-~ >?::::-----Date: ~
CORRECTIONS: Please identify any corrections, additions, or deletions that should be made in terms
of contact information.
RETURN COMPLETED FORM TO:
Stephen Rynas, Federal Consistency Coordinator
NC Division of Coastal Management
400 Commerce A venue
Morehead City, NC 28557-3421
400 Commerce Ave., Morehead City, NC 28557-3421
Phone. 252-808·2808 \ FAX: [phone] Internet: www.nccoastalmanagement.net
An Equal Opportunity\ AffirmaUve ActiOll Employer
Ni~carolina Jvaturally
6.A
MCDEMR IIECEIVEO
Beverly Eaves Perdue
Governor
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullies
Director
MAR 2 5 2010
MlilfellJif§~?n
Secie!~~,.,
MEMO
To:
Through:
Stephen Ryan's, Federal Consistency Coordinator, NC Division of Coastal Management
Al Hodge, Supervisor, Surface Water Protection Ll\&f
From: Roberto L. Scheller, Senior Environmental Specialist~
Subject: Comments on Consistency Review for Proposed Site Remediation of Welch Creek
Date: March 18,2010
The following comments are in response to a consistency review for the proposed remediation of dioxins and
furan in sediments of Welch Creek. The remediation site is at the former Weyerhaeuser (presently Domtar)
Mill site located in Martin County off Highway 64. It was noted during review of the proposed project that
there was insufficient information given in relation to the proposed treatment process. The following items
were noted as being exiguous:
• In Attachment A, it is proposed to use Bio-films Extracellular Polymeric Substances (EPS) to stabilize
sediment. Additional information will be required on proposed EPS to be used at the subject.
• Attachment B: Reduction of Dioxins from Capping Site, a 1-2 cm layer of sand is proposed to be
applied instream to reduce dioxin concentrations. Further information on the proposed process is
necessary to evaluate the treatment process.
• Attachment C: Welch Creek cross sections and percent slope range information was given. It will be
necessary to provide this Office with information on how the proposed sand layer will affect stream.
dimensions, pattern, profile, and how sand layer will affect sediment transport within the stream.
• It is the recommendation of this Office that RTM schedule a scoping meeting to review the proposed
treatment process and answer any unaddressed questions before moving onto the permitting phase for
the subject project.
If you should have any questions or require additional information you may e-mail me at
rc•lx:rtn.schcllcl'ri/ncdcnr.eov or contact me by pho·ne at 252-948-3940.
North Carolina Division of Water Quality
943 Washington Square Mall
Washington; NC 27889
Phone: [phone] I FAX: [phone]
Internet: www.ncwaterqualitv.om
An Equal Opporlunity I Affirmative Action Employer
OnehC 1· Nort aroma
)vaturall!f
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
National Ocean Service
Office of Response and Restoration
Assessment and Restoration Division
263 13th Avenue South
St. Petersburg. FL 33701
MEMORANDUM
TO: Randy Bryant, EPA RPM
FROM: Michel Gielazyn, Ph.D., NOAA RRC
SUBJECT: NOAA Comments on Pre-final/Final Remedial Design Report, Welch Creek
DATE: April 2, 2010
CC: Tom Augspurger, FWS
Nile Testerman, NCDENR
The U.S. Department of Commerce, National Oceanic and Atmospheric Administration
(NOAA) appreciates the opportunity to comment on Pre-final/Final Remedial Design Report,
Welch Creek Operable Unit 04, Plymouth, Martin County, North Carolina, Prepared by RMT
North Carolina, Inc for Domtar Corporation, February 2010. If you have any questions,
please contact Michel Gielazyn, Ph.D., NOAA RRC, al 727-551-5771 or
[e-mail].
I) Using a surface weighted average concentration (SWAC) to compare to the dioxin
sediment remedial goal for Welch Creek (OU4) is not appropriate, especially in light of
new EPA dioxin guidance (EPA 2009).
Use the dioxin sediment remedial goal for Welch Creek as a "not to exceed"
concentration. The Welch Creek Record of Decision (ROD) states that based on
ecological risks the remedial cleanup goal for sediment should be 0.41 ppb (EPA
2007). This is the goal determined by the facilitated meeting process undertaken by
representatives from Weyerhaeuser (now Domtar), RMT (Weyerhaeuser's
consultants), EPA, the State of North Carolina, FWS, and NOAA. However, in the
Record of Decision (ROD), EPA decided to use a I ppb cleanup goal for dioxin in
sediment based on OSWER directive 9200.4-26 (EPA 1998), which directed a
residential dioxin soil cleanup goal of I ppb. The ROD also states that "given the
distribution of contaminants in sediment, achieving a cleanup goal of I ppb for dioxin
(1-TEQ) will likely result in a surface area weighed average concentration in the
upstream reach approaching 0.4 I ppb." This shows that the I ppb was intended as a
"not to exceed" value, which will minimize any residual ecological risks.
Note that in 2009, EPA released new draft guidance, OSWER directive 9200.3-56,
which lowers the human health-based soil cleanup goals and states: "Based on
consideration of oral and dermal exposures to dioxin and other dioxin-like
compounds in soil, EPA recommends the interim PRGs for dioxin in soil calculated
based on non-cancer effects: 72 ppt dioxin TEQ in residential soil and 950 ppl dioxin
TEQ in commercial/industrial soil (EPA 2009)." This revised lower number is again
based on a human health endpoint, however, this new draft guidance also slates:
"Regions should continue to develop PR Gs on a site-speci fie basis for other media,
like sediments, that involve biotransfer and bioaccumulation up the aquatic food
chain to fish consumed by humans and for ecological assessments where the receptors
are terrestrial biota, such as plants and animals, not humans."
2) A statement in Section l.4 mischaracterizes the conclusions of the North Carolina
Coastal Region Evaluation of Wetland Significance (NC-CREWS) study; we
recommended that the phrase "overall healthy conditions" be deleted.
The statement, in Section 1.4, that "The Welch Creek wetlands were rated as a
mixture of Substantial Significance or Exceptional Significance based on the NC-
CREWS reflecting their exceptional value and overall healthy condition (emphasis
added)" is inaccurate. The NC-CREWS did not rate wetlands on their "overall
healthy condition." Sediment contamination was not considered when wetlands were
ranked by NC-CREWS. In fact, "The primary objective of the NC-CREWS wetland
functional assessment is to provide users with information about the relative
ecological importance of wetlands for use in planning and the overall management of
wetlands. It is useful in determining where development should not be planned, or
where certain types of development are best suited to and compatible with the
habitat. Where wetland impacts are unavoidable, NC-CREWS can significantly
improve avoidance and minimization of significant and irreversible adverse impacts
to the most valuable wetland ecosystems (Sutter et al., 1999)." The only way in which
contaminants were considered was in water-borne runoff from non-point sources.
Wetlands were ranked based on their estimated ability to remove non-point source
pollution from water. And, "the Overall Wetland Rating (OWR) for wetlands is based
on each wet land's ability and opportunity to provide (I) Water Quality, (2)
1-lydrologic, and (3) Wildlife Habitat functions (Sutter et al., 1999)." To achieve an
exceptional functional significance a wetland only had to rank exceptional in two of
these three ti.mctions, which did not consider the contaminant concentrations in
sediment or benthos.
3) Delete or clarify the last bullet in Text Box 1-1 regard mercury sources.
The last bullet in Text Box 1-1 states that "Mercury presence in creek and river basin
attributed to upwind utility emissions." This statement should be deleted or clarified.
Exactly what areas and which media (water, sediment, biota, soil?) are being referred
Page 2
to? For example, the Welch Creek FS does not attribute all of the mercury in Welch
Creek sediments to utility emissions.
4) Please include a full list of references for the subject document and attachments.
5) References
EPA (1998) Approach for Addressing Dioxin in Soil at CERCLA and RCRA Sites.
Memo from Timothy Fields, EPA Acting Administrator, to Regional Directors. U.S.
Environmental Protection Agency, Office of Solid Waste and Emergency Response.
OSWER Directive 9200.4-26.
EPA (2007) Record of Decision for Welch Creek Area -Operable Unit 4 of the Domtar
Corporation (formerly Weyerhaeuser) Site, Martin County, NC.
EPA (2009) Drall Recommended Interim Preliminary Remediation Goals for Dioxin in Soil
at CERCLA and RCRA Sites. Public Review Draft, OSWER 9200.3-56.
RMT North Carolina, Inc. (2007) Final Welch Creek Feasibility Study. Prepared for Domtar
Paper Co., LLC (formerly Weyerhaeuser Company), Plymouth, Martin County, North
Carolina.
Sutter, L. A. ct al. ( 1999) NC-CREWS: North Carolina Coastal Region Evaluation of
Wetland Significance. A Report of the Strategic Plan for Improving Coastal Management in
North Carolina. Published by Division of Coastal Management North Carolina Department
of Environment and Natural Resources.
Page 3
.&i:A
NCDEMR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue, Governor Division of Marine Fisheries Dr. Louis B. Daniel Ill, Director
Dee Freeman, Secretary
April 1, 201 D
Mr. Randy Bryant, Remedial Project Manager
Superfund Remedial/Site Evaluation Branch
US Environmental Protection Agency -Region 4
41 ForsY1h Street
Atlanta, GA 30303-8960
SUBJECT: Pre-final/Final Remedial Design Report (February 2010) prepared by RMT, Inc.,
Welch Creek Operable Unit 04 Superfund Site of the Domtar Paper Company
(formerly Weyerhaeuser);
Plymouth, Martin County, North Carolina
Dear Mr. Bryant,
The following comments by the North Carolina Division of Marine Fisheries (NCDMF) on the subject
report and proposed project are offered pursuant to NC General Statute 113-131. These comments
are pursuant to NCDMF's objectives to: (1) reduce pollution and improve water quality conditions, and
(2) enhance fish habitat functions in North Carolina's estuarine waters. These comments are being
sent to Mr. Randy Bryant with USEPA as requested by RMT, Inc.
The text portion of the report has no reference to the time period of when the sand cover (eMNR) will
be deployed. The only reference to the sand cover construction period is found in "Figure 7.2, I.D. #28,
eMNR Placement" and spans the time period from 3/2/2011 to 5/31/2011 (90 Days). This proposed
construction period is within the normal Feb. 15-Sept. 30 anadromous fish moratorium for in-water
construction established by the NCDMF and other agencies. The proposed work area is located in an
Anadromous Fish Spawning Area (NCDMF 2008) and. is used as an Anadromous Fish Nursery Area;
consequently, the proposed work would have significant adverse impacts on spawning and juvenile
anadromous fish. Elevated turbidity levels and in-water work is known to negatively affect anadromous
fish. The NC Wildlife Resources Commission samples the Roanoke River immediately adjacent to the
proposed area and has found juvenile alosid fish (i.e., shad and river herring) into early November.
Previous agreements on in-water construction, during meetings in 2004 with Weyerhaeuser and RMT
/consultant) to discuss the eMNR Pilot Study, established an expanded in-water construction
moratorium (Feb. 15-Oct. 31) to protect anadromous fish resources [see attached 2004 meeting
minutes: (1) top of page 5 and page 7 (Table 1) of 2004-5-12&25 MeetingMinutes Welch Cr May12-25-
m00511907-002a, and (2) top of page 6 in 2004-6-16 MeetingMinutes Welch Crmemom000511907-
003bj. Therefore, the NCDMF would recommend an expanded anadromous fish in-water construction
moratorium (Feb. 15-Oct. 31) for consistency with previous agreements and work in Welch Creek.
3441 Arendell Street, P.O. Box 769, Morehead City, North Carolina 28557
Phone: [phone] \ FAX: [phone] \ Internet: www.ncdmf.net
An Equal Opportunity/ Affirmative Action Employer -50 % Recycled I 10% post Consumer Paper
One . NotthCarolma ;Nntt,rnl/y
Pre-final/Final Remedial Design Report (February 2010)
Welch Creek Operable Unit 04 of the Domtar Paper Company
Page 2 of 3
April 1, 2010
Section 3.2.2 Mobility Monitoring (p 30; last paragraph; 1st sentence) notes the collection of "base flow
and event based surface water quality data" in the Midstream Reach, only. However, both, "Table 5-1
Upstream Reach Preliminary Remedy Performance Monitoring" (pages 49-50) and "Table 5-2
Conceptual Approach for Midstream Reach Performance Monitoring" (page 51) indicate that surface
water will be sampled for dioxin and TSS. These inconsistencies should be clarified in the text for the
Upstream Reach. Further, the text and tables should elaborate on the sampling methodology and
specifically outline where sampling will occur in the water column (e.g., depth from surface, mid water,
bottom). Sampling near the sediment and water interface would appear to be the most ideal location.
Section 4.6 Mobility Monitoring Equipment and Installation (page 43; 1st paragraph) states that "a multi-
cell Doppler Current Profiler" will be installed at three stations in Welch Creek. Previously, in the
October 2009 Conceptual Design Report, it was stated that event based surface water sampling would
be triggered by events recorded at the lower Roanoke River stage gauge. Using the lower Roanoke
River stage gauge to trigger sampling was not discussed in this report. So, are we to assume that real-
time events recorded by the multi-cell Doppler current profiler will be utilized to trigger "event based
surface water quality sampling"?. The addition of several rain gauges in the Welch Creek basin would
assist in documenting and potentially triggering sampling during high inflow events that may impact
sediment movement and suspension.
"Table 5-2 Conceptual Approach for Midstream Reach Performance Monitoring" (page 51) notes the
collection .and analysis for "Mercury Fish Tissue Concentrations". Table 5-2 should also include fish
tissue sampling and analysis for dioxin as is noted in "Table 5-1 Upstream Reach ... , Note #8" which
mentions sampling for dioxin "within the Midstream Reach (MT-7 to GT-15)".
Section 3.2.4 Institutional Controls (page 32), Section 4.5 (pages 42-43), Section 4.7.4 (page 45), and
Section 6.6 (pages 55-56) state that signs will be maintained in Welch Creek noting fish advisories and
the presence of the sand cover. In order to protect the sand cover and the public, NCDMF
recommends that the signage contain the following precautions for the Upstream Reach.
❖ Bottom sediments contain wastewater solids that may contain dioxin. These wastewater solids
are covered with a thin layer of sand.
• Do not disturb bottom sediments with motors, propellers, or propeller wash.
• No bottom fishing with heavy sinkers.
• No anchoring.
Also, wastewater solids are not restricted to the Upstream Reach of Welch Creek. Therefore, similar
signage containing this precautionary language, with the omission of the sand cover statement (only,
where applicable), should be placed throughout the creek from US Hwy 64 downstream to the mouth.
Pre-final/Final Remedial Design Report (February 2010)
Welch Creek Operable Unit 04 of the Domtar Paper Company
Page 3 of 3
April 1, 2010
Throughout the process of evaluating options for the Welch Creek Superfund Site, the NCDMF has
raised concerns relative to the efficiency of the 5-10 cm sand cover remedy to isolate the dioxin laden
wastewater solids from benthic organisms (bioavailability) and surface waters. Removal of the
contaminated wastewater solid sediment deposits from the entire creek, not the sand cover, was our
preferred option for remediation as was noted in our comments (Sept. 4, 2007) on the Proposed
Superfund Plan. As previously noted in our comments (Feb. 14, 2007) on the FS and (Sept. 4, 2007)
on the Proposed Superfund Plan, NCDMF, has concerns about the ability to maintain the integrity of the
thin 5-10 cm sand cover due to:
1) disturbance or mobility of wastewater solids sediments due to sediment decomposition
underneath the sand cover and the subsequent eruption of gas from these sediments,
2) recolonization and potential bioturbation by benthic organisms,
3) unintentional damage by human activities, and
4) scouring and erosion of the cover by high stream flow events.
Thus, NCDMF would recommend consideration and further evaluation of a substantially greater
(approximately 30 cm) sand cover for the Upstream Reach.
Thank you for the opportunity to review this report for the Welch Creek Superfund Site. We look
forward to continued cooperative work to reduce water quality problems and protect aquatic resources
in North Carolina. If you have questions or need further clarification on any of these comments, please
contact me at [phone] or via e-mail at [e-mail].
Sincerely,
,J.} -----(/.) I rJ;r--I . ½J=v:;v-
Lynn T. Henry, Biologist
NC Division of Marine Fisheries
LITERATURE CITED
NCDMF (NC Division of Marine Fisheries). 2008. Habitat Alteration Permit Review Guidelines. DMF.
Morehead City, NC 29pp.
cc: Dr. Louis B. Daniel Ill, NC Division of Marine Fisheries, Director
Anne Deaton, NC Division of Marine Fisheries, Chief Habitat Protection Section
Sara E. Winslow, NC Division of Marine Fisheries, Northern District Manager
Kevin Hart, NC Division of Marine Fisheries, Habitat Protection Section
,'/
ly
~
Domtar
April 30, 2007
Mr. Randy Bryant, Remedial Project Manager
United States Environmental Protection Agency, Region 4
Atlanta Federal Center
6l Forsyth Street, S. W.
Atlanta, GA 30303-3104
Domtar Paper Company, LLC
Plymouth Mill
PO Box 747
Highway 149 North
Plymouth, NC 27962
Tel.: (252) 793·8111
15)~@~□\Yl~ln)
Ull MAY -9 2007 ~
SUPERFUNO SECTION
Subject: Domtar Paper Company, LLC (Domtar), Plymouth, North Carolina
Operable Unit No. 1 (OU-1; Former Landfill No. 1 Area) Quarterly Report
Dear Mr. Bryant:
RMT North Carolina, lnc. (RMT) is submitting this letter and attachments to describe site-related
activities conducted during the fourth and first quarters of the 2006-2007 reporting year for the Ou-·1
at the Domtar (formerly Weyerhaeuser Company [Weyerhaeuser]) Plymouth, North Carolina facility.
On March 7, 2007, Domtar acquired certain assets from Weyerhaeuser, including the Plymouth Mill.
This letter documents activities at OU-1 that have occurred since submittal of the report entitled
A111111nl Mo11itori11g Report Operable Unit I -Former No. 1 landfill Area (RMT, 2007). Attached to this
letter are the following:
11 Photographs and Well Construction Logs for groundwater monitoring well replacement and
repairs (Attachment 1)
ra Tables of groundwater and leaf litter analysis of samples collected in February 2007 and mercury
deposition records recorded at Pettigrew State Park (Attachment 2)
ra Case narrative for dioxin analyses of groundwater and leaf litter samples collected in February
2007 (Attachment 3)
Groundwater Monitoring Well Repairs
As indicated in the An1111al Mo11itoring Report (RMT February 2007), observations during the past two
groundwater sampling events indicated that the well conditions of select wells had deteriorated and
were in need of repair or replacement. It was recommended that new groundwater wells be installed
at FL-04-1 and FL-06-1.
Groundwater samples collected on November 6, 2006 from these two wells had detectable
concentrations of 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD). This was the first time that
www.domtar.com
' ' /ffi
•
Mr. Randy Bryant, Remedial Project Manager
United States Environmental Protection Agency, Region 4
April 30, 2007
Page 2
•
2,3,7,8-TCDD was detected from well FL-04-1 and the second time that 2,3,7,8-TCDD was detected
from well FL-06-1.
Due to the deteriorating condition of the monitoring well pads and protective covers, Weyerhaeuser
decided to undertake well repairs. RMT, along with a specialty subcontractor Parratt-Wolff Inc.,
mobilized to the Weyerhaeuser Mill in Plymouth, North Carolina on February 19, 2007 to reconstruct
·is monitoring well casings and foundations, abandon two existing monitoring wells, and install two
new monitoring wells on the Former Landfill No. 1.
Replacement monitoring wells, FL-04-lR and FL-06-lR were installed. The photographic
documentation and well construction records are included in Attachment 1. Wells were bored using
a Diedrich D-50 truck mounted drill rig with a 4 ¼ inch inner diameter (ID) and 8 inch outer diameter
(OD) auger. Each well screen was set at a depth of 13 feet below ground surface (bgs), and backfilled
with No. 1 filter sand to a depth of 1.5 foot bgs. A bentonite seal was placed in the remaining 1.5 feet.
Wells were developed using a surge block and a submersible pump. Approximately 50 gallons of
purge water was pumped from each well. Circular shaped concrete pads were poured around the
well casings using pre-cast templates.
Upon completion of the well installation, FL-04-lR and FL-06-lR were sampled using low-flow
sampling method with a peristaltic pump and vacuum jug. At each well, an unfiltered sample and a
sample passed through a .45 micron filter were collected for total and dissolved dioxin/furans,
respectively. Samples were packed securely on ice and shipped overnight to Weyerhaeuser
Analytical and Testing (WATS) in Federal Way, Washington for analysis.
Eighteen well casings and concrete pads were then removed and replaced on the remaining Fonner
Landfill No. 1 wells. The metal casings were in various states of disrepair. New metal casings were
installed on all wells and a circular pad containing approximately 1 cubic foot of concrete were
installed around each casing.
All soil cuttings, well casings, and associated concrete removed were disposed of in Dom tar's on-site
Landfill No. 3. Purge water from the· development and sampling of FL-04-lR and FL-06-lR was
disposed in Dom tar's on-site wastewater treatment system. New locks were installed on all 20
monitoring wells. Wor~ was completed on February 22, 2007.
•
Mr. Randy Bryant, Remedial Project Manager
United States Environmental Protection Agency, Region 4
April 30, 2007
Page 3
Results of the Groundwater Sampling
for FL-04-lR and FL-06-lR
•
As reported in the Annual Monitoring Report for OU-1 (RMT 2007), 2,3,7,8-TCDD was reported above
the detection limit for the November 2006 groundwater sample collected from monitoring wells
FL-04-1 and FL-06-1. These wells were replaced and the new wells were sampled in February 2007.
Both filtered and unfiltered samples were collected at from monitoring wells FL-04-0lR and
FL-06-01 R for dissolved and total dioxin/furans. Table 1 (see Attachment 2) shows 2,3,7,8-TCDD was
not detected in any of the samples collected from monitoring wells FL-04-lR and FL-06-1 R. Table 2
(Attachment 2) summarizes the physical parameters for the samples collected from FL-04-lR and
FL-06-1 R. The laboratory case narrative for these analyses is included as Attachment 3.
The 2,3,7,8-TCDD Toxicity Equivalent Concentrations (TEQs) calculated for both the filtered
(dissolved) and unfiltered (total) samples for FL-04-lR are 4.40 X 10·11 and 2.00 X 10·10, respectively,
following the United States Environmental Protection Agency (USEPA) International Toxicity
Equivalence Factor (1-TEF) method. The 2,3,7,8-TCDD TEQs for filtered and unfiltered samples for
FL-06-1 Rare calculated as 8.0 X 10-11 and 2.70 X "I0·9, respectively. Currently, the North Carolina
drinking water standard is 2.2 X 10·10 mg/L for 2,3,7,8-TCDD (15 NCAC 02L.0202, revised April 2005).
In 2001, the state of North Carolina proposed a modification of its drinking water standard for dioxin,
by changing the application of the standard to dioxin 1-TEQ rather than 2,3,7,8-TCDD. Therefore, the
Record of Decision (ROD) for OU-1 classified the then proposed North Carolina Administrative Code
(NCAC) 2L standard of 2.3 x 10·10 mg/Las a "to be considered" (TBC) criterion for consideration in the
evaluation of applicable or relevant and appropriate requirements (ARARs) compliance. The status
of the dioxin standard proposal has not changed since 2001, so the comparison to 1-TEQ remains a
TBC. The TEQ concentrations for both filtered and unfiltered samples collected from FL-04-1 R arc
below North Carolina's proposed dioxin I-TEQ standard. The TEQ concentrations calculated for the
unfiltered (total) sample from FL-06-1 R exceed the North Carolina's proposed dioxin 1-TEQ standard
because of the calculation method that includes concentrations of the various dioxin congeners that
arc also present in background groundwater samples.
Five dioxin congeners (1,2,3,4,6, 7,8, 9-octachlorod ibenzo-p-d ioxin, 1,2,3,4,6, 7,8-heptachlorod iobenzo-
p-d ioxin, 1,2,3,6,7,8-hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9-hexachlorodibenzo-p-dioxin, and
1,2,3,4,6,7,8-heptachlorodiobenzo-p-furan) were detected in both the filtered and unfiltered sample
collected from FL-06-lR. Only 1,2,3,4,6,7,8-heptachlorodiobcnzo-p-dioxin was detected in the filtered
sample from FL-06-lR, with the higher concentration observed in the unfiltered sample. For filtered
and unfiltered samples collected from FL-04-1 R, the dioxin congeners 1,2,3,4,6,7,8,9-
octachlorodibenzo-p-dioxin and 1,2,3,4,6,7,8-heptachlorodiobenzo-p-dioxin were detected. The octa-
•
Mr. Randy Bryant, Remedial Project Manager
United States Environmental Protection Agency, Region 4
April 30, 2007
Page 4
•
and hepta-congener concentrations were higher in the unfiltered sample. Table 2 (Attachment 1)
compares the samples collected from FL-04-1 and FL-06-1 in November 2005, March 2006 and
November 2006 to the sample collected from the replacement wells in February 2007. All of these
detected congeners exhibited lower concentrations in the March 2007 samples collected fro1n the new
wells (FL-04-lR and Fl-06-lR) compared to previous samples collected from FL-04-1 and FL-06-1.
Leaf Litter Analyses
Table 3 (see Attachment 2) presents results of low-level mercury analyses of leaf litter samples
collected on February 22, 2007. The five sampling locations are the same as presented in the Annunl
Mo11itori11g Report for OU-1 (RMT, 2007). Sample location designations are referenced to existing soil
and groundwater sampling locations. For your convenience, we have included data from prior leaf
litter sampling events on Table 3. As can be seen from Table 3 (see Attachment 2), leaf litter samples
collected during the two winter sampling events (January 2006 and February 2007) exhibit somewhat
higher mercury concentrations when compared to leaf litter samples collected in late fall (November
2005 and November 2006). The observable trends in mercury concentration will be evaluated at the
completion of the five-year OU-1 monitoring period.
Mercury Deposition
In the Ann uni Monitori11g Report for OU-1 (RMT, 2007) mercury deposition for the fifty-two week
period March 21, 2006 was estimated. The estimated deposition rate of 11.68 µg/m2 was based on
data collected from the National Air Deposition Program/Mercury Deposition Network
(NADP/MDN) station l_ocated at Pettigrew State Park (MON Station NC42). Since the annual report
was prepared, the NADP/MDN station has reported mercury deposition rates through June 20, 2006.
Table 4 (Attachment 2) presents weekly mercury deposition results recorded from the Pettigrew State
Park Station for the period beginning March 28, 2006 and ending June 20, 2006. For this reporting
period, the total mercury deposited at the Pettigrew State Park station was 4.47 pg/m2• Assuming a
similar deposition rate at Plymouth, this equates to a total mercury deposition of 1.6 grams of
mercury on OU-1, which encompasses 87 acres (350,000 m2).
Scheduled Events
Leaf litter samples will continue to be obtained in the fourth and first quarters annually. For the
2007-2008 reporting year, Weyerhaeuser will conduct annual groundwater, wetland soil and leaf
litter sampling during the fourth quarter. As with the prior sampling events, wetland soil and leaf
litter samples collected for the 2007 annual sampling event will be collected and analyzed using low-
•
Mr. Randy Bryant, Remedial Project Manager
United States Environmental Protection Agency, Region 4
April 30, 2007
Page 5
•
level mercury sampling and analysis methods. This approach will be used to ascertain if soil mercury
concentrations exhibit a discernable trend over the time frame that Weyerhaeuser is required to
monitor the effectiveness of the OU-1 remedy.
Please contact me if you have questions or need additional information regarding the information
contained in this letter.
Sincerely,
Bill Morris, Environmental Engineer
Domtar Paper Company, LLC
Attachments
xc:
Marcel Sylvestre
Mike Parker
Kathy Huibregtse
Nile Testerman '
Diane Hardison
• •
Attachment 1
Photographic Log and
Well Construction Records
•
Client Name:
Domtar Paper Company, LLC
Photo No.
Description
Date
02/20/07
FL-06-1 and FL-06-2 before
replacement well and before
reh;:ib work.
Photo No. Date
2 02/20/07
Description
Drilling FL-06-IR.
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
I • r, , , ~ l ,
j
' 1 ; -_ , ..
I '-\,'( \.,'~~_";'.;1.._~~i . '.,\
•
Client Name:
Domtar !'aper Company, LLC
Photo No. Date
Description
Setting FL-06-1 R.
Photo No.
4 .
Description
Date
02/20/07
FL-06-1 Rafter well set, sand
p~ck, zmd bcntonile seal.
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
.~•r.;gJ ;f:; ii \'.:~~t~ ..
'( ,,
'•
•
Client Name:
Domtar Paper Company, LLC
Photo No.
5
Description
Date
02/20/07
FL-04-1, FL-04-2, and FL-04-3
before rehab.
Photo No.
6
Description
FL-04-1 R.
Date
02/20/07
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
•
Client Name:
Dom.tar Paper Company, LLC
Photo No. Date
7 2/21/07
Description
FL-07-1 and FL-07-2 before
rehab.
Photo No. Date
8 02/21/07
Description
FL-05-1 and FL-05-2 before
rehab; FL-05-1 under bucket;
FL-05-2 protective casing and
pad removed.
• Photographic Log
Site Location: Project No.:
Plymouth, North Carolina 00-05170.0 I
•
Client Name:
Domtar !'aper Company, LLC
Photo No.
9
Description
Date
02/21/07
FL-05-2 bucket removed, before
rehab.
Photo No. Date
• Photographic Log
Site Location:
Plymouth, North Carolina
Prnject No.:
00-05170.0l
•
Client Name:
Domtar Paper Company, LLC
Photo No.
l1
Photo No.
12
Description
Date
02/21 /07
Date
02/21/07
FL-08-1, FL-08-2, and FL-08-3
before rehab.
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
•
Client Name:
Domtar Paper Company, LLC
Photo No.
13
Description
Date
02/21/07
FL-09-1 and FL-09-2 before
rehab.
Photo No.
14
Date
0212·1 /07
i\ ~-~~-;; ~!;vi~ "',<1•,...t~ '"\tt.~ f.."!?J,i:,, .:r-csc ~~"f'!• t~f~ ~;;~ !;!'t ..
;; : .. i•,.Y!!t,
• Photographic Log
Site Location: Project No.:
Plymouth, North Carolina 00-05170.01
•
Client Name:
Domtar Paper Company, LLC
Photo No.
15
Description
Date
02/21/07
FL-07-1 and Fl"-07-2 during
rehab.
Photo No.
16
Description
Date
02/22/07
FL-01-1 and FL-01-2 before
rchzib.
• Photographic Log
Site Location: Project No.:
Plymouth, North Carolina 00-05170.01
llfi'H •
Client Name:
Domtar Paper Company, LLC
Photo No.
17
Description
Date
02/22/07
Fl,-06-·1 R sample set-up.
Photo No.
18
Description
Date
02/22/07
FL-06-1 R sample set-up for
dissolved dioxin, notice
0.45 micron filter in-line.
• Photographic Log
Site Location: Project No.:
Plymouth, North Carolina 00-05170.01
•
Client Name:
Domtar Paper Company, LLC
Photo No.
19
Description
Date
02/22/07
FL-10-1 and FL-10-2 after rehab.
Photo No.
20
Description
Date
02/22/07
Fl"-09-1 and FL-09-2 after rehab.
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
•
Client Name:
Domtar Paper Company, LLC
Photo No.
21
Description
Date
02/22/07
Fl..-08-1, Fl..-08-2, and FL-08-3
after rehab.
Photo No.
22
Description
Date
02/22/07
FL-07-1 and FL-07-2 after rehab.
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
•
Client Name:
Domtar Paper Company, 1.,LC
Photo No.
23
Description
Date
02/22/07
FL-06-lR and FL-06-2 after
rehab.
Photo No.
24
Description
Date
02/22/07
FL-05-1 and FL-05-2 after rehab.
• Photographic Log
Site Location: Project No.:
Plymouth, North Carolina 00-05170.0I
•
Client Name:
Domtar Paper Company, LLC
Photo No.
25
Description
Date
02/22/07
FL-04-1 R, FL-04-2, and FL-04-3
~fter rehc1b.
Photo No.
26
Description
Date
02/22/07
FL-03-'I and FL-03-2 after rehab.
• Photographic Log
Site Location: Proj eel No.:
Plymouth, North Carolina 00-05170.01
•
Client Name:
Domtar Paper Company, LLC
Photo No.
27
Description
Date
02/22/07
Fl.,-02-1 and FL-02-2 after rehab.
Photo No.
28
Description
Date
02/22/07
FL-01-1 and FL-0"1-2 after rehab.
• Photographic Log
Site Location:
Plymouth, North Carolina
Project No.:
00-05170.01
Table 4
Weekly Mercury Deposition Results
Domtar Paper Company, LLC (formerly Weyerhaeuser Company), Plymouth, North Carolina
NC42 03/28/2006 11 :30 04/04/2006 12:00 20.32 242.00 20.32 11.25 228.60 w A 200603
NC42 04/04/2006 12:00 04/11/2006 11 :30 50.80 410.50 50.80 8.11 412.24 w A 200604
NC42 04/11/2006 11 :30 04/18/2006 12:30 2.54 13.90 2.54 13.70 34.81 w A 200604 •
NC42 04/18/2006 12:30 04/25/2006 12:00 17.02 150.70 17.02 8.21 139.83 w A 200604
NC42 04/25/2006 12:00 05/02/2006 11 :30 25.15 279.80 25.15 15.49 389.58 w A 200604
NC42 05/02/200611:30 05/09/200612:00 130.81 1341.20 130.81 4.14 542.60 w B dh 200605
NC42 05/09/200612:00 05/16/200612:00 75.44 767.00 75.44 8.11 612.02 w B d 200605
NC42 05/16/200612:00 05/23/200616:25 19.05 182.80 19.05 9.76 186.00 w B h 200605
NC42 05/23/2006 16:30 05/30/2006 12:00 24.13 206.40 24.13 11.62 280.56 w B mh 200605
NC42 05/30/200612:00 06/06/200616:00 15.24 196.10 15.24 9.69 147.72 w B d 200606
NC42 06/06/200616:00 06/13/200612:00 38.10 422.00 38.10 9.70 369.87 w B d 200606 • NC42 06/13/2006 12:00 06/20/2006 11 :30 30.48 286.60 30.48 4.10 125.24 w A 200606
NC42 06/20/2006 11 :30 06/27/2006 11 :30 107.44 1063.50 107.44 9.29 998.67 w A 200606
D: \ DOCUMENTS AND SETIINGS\MCCRADA\LOCAL SETIINGS\TEMl'OHARY 11'.'TERNET FILF.5\O1.K~SIL000517001-001.DOC Draft
I
•
Attachment 3
Laboratory Case Narrative
• •
CERTIFICATE OF ANALYSIS
DIOXIN/FURAN REPORT
Service Request Number: 07-0508
Service Request Name: Plymouth -Groundwater/Leaf Litter
This is the Certificate of Analysis for the following Samples:
Client Contact: Heather Smith
Date Received by Lab: 2/26/07
Number of Samples: 4
Sample Type(s): 4 Groundwater samples
I. Introduction/Case Narrative
Four samples were received February 26, 2007 for the analysis of 2,3,7,8-TCDD and 2,3,7,8-
TCDF. The samples and a blank for each extraction batch were spiked prior to extraction with an
internal standard solution containing 2.0 ng of 13C1r2,3,7,8-TCDD and 2.0 ng 13C 12-2,3,7,8-
TCDF. They were extracted and cleaned-up using the methods described in NCASI Technical
Bulletin No. 551, "NCASI Procedures for the Preparation and Isomer Specific Analysis of Pulp
and Paper Industry Samples for 2,3,7,8-TCDD and 2,3;7,8-TCDF",(1989). Extracts were
analyzed by EPA 16138 "Tetra-through Octa-Chlorinated Dioxins and Furans by Isotope
Dilution I-IRGC/HRMS" using High Resolution GC/MS operating in the selected ion monitoring
mode for enhanced sensitivity.
Reviewed and Approved:
Randy Eatherton, PhD
Organic Analysis Technical Specialist
'.I
• •
Page 2
Date: 3/09/07
Service Request Number: 07-0508
II. Analytical Results and Methodology
SAMPLE PREPARATION
The water samples were spiked with the internal standard solution described above, filtered and
extracted using liquid/liquid extraction techniques involving multiple extractions with methylene
chloride. The solids from the sample were soxhlet extracted with 68:32 ethanol/toluene. The two
extracts (water and solids from the water) were combined prior to cleanup. Immediately
following extraction and prior to any cleanup procedures, the extracts were spiked with a
cleanup recovery surrogate standard (37CJ 4-2,3,7,8-TCDD) to monitor losses through· the
cleanup.
SAMPLE CLEANUP
Following a solvent exchange step, the residues were cleaned up with two. or more column
chromatographic procedures. Just prior to 1-IRGC/HRMS analysis, a recovery standard (13C1r
1,2,3,4-TCDD and 13C 1rl,2,3,7,8,9-I-IxCDD) was added to all final extracts.
GC/MS ANALYSIS
Two ul of the concentrated extract was injected into the HRGC/HRMS system capable of
performing selected ion monitoring at resolving powers of at least I 0,000. The identification of
the 2,3,7,8-TCDD and 2,3,7,8-TCDF was based on the elution at the exact retention time (-1 to
+3 seconds from the respective internal standard signal), the simultaneous detection of the M+
and M+2 ions, on a comparison of the ratio of the integrated ion abundance of these ions to the
theoretical abundance ratio, and peak signal to noise ratio of>2.5: I for both ions. The column
used for this analysis was a 60111 Restek rtx-5 fused silica capillary column. A five point
calibration plot was analyzed prior to the analysis of any samples. Shift standards were run every
twelve hours to determine if the instrument was still calibrated. The mean response from the
multipoint was used to calculate the concentration of analyte in the samples.
GC/MS RESULTS
The results of the analysis, shown in Table I, are reported in ppt (pg/rnL, water; pg/gm OD,
solids). A detection limit wa's calculated from 2.5 times the signal in the area of the elution of
13C 1r2,3,7,8-TCDD (TCDF) whenever a sample contains no detectable TCDD (TCDF). This
value is reported in parenthesis.
• •
Page 3
Date: 3/09/07
Service Request Number: 07-0508
lll. Case Narrative
Method Variations. Different lock masses for the first and second MID descriptor ranges
were required for acceptable HRMS lock function. EPA 1613 lists a PFK ion near mass 355 amu
for this purpose. In practice, this mass is very close to a GC column stationary phase bleed
response which risks the occurrence of an inappropriate lock. We have used a PFK masses near
331 and 343 amu for a number of years successfully for this range. This descriptor has been used
to run all standards and samples, hence no effect on quantitation is expected.
Mass Spec. Resolution Check. For primary analysis, resolution of at least I 0,000 was
demonstrated at amu 331, 343, 393, 431 and 443 prior to analysis of samples. For multiple shifts,
the end run resolution check may have been the beginning of the next day's shift.
Initial Calibration. Levels described in EPA 1613 for the 5 calibration standards were used.
Cambridge Isotope Laboratories provided the standards in premixed aliquots. Certification
documents are available in the laboratory.
Calibration Verification. Levels described in EPA 1613 for the VER standard were used. Our
current practice for retention time verification requires a retention time windows mixture be
injected each shift and instrument data acquisition windows adjusted (if needed) to insure
detection of all first and last eluting isomers. We report these absolute retention times for each
shift on separate Form 5s. Since we use a guard column whose length varies as maintenance is
performed, the absolute retention times will change over time.
Precision and Recovery. Levels and criteria described in EPA I 613B for the PAR standard
were used. The recoveries of all native and labeled compounds were acceptable for PAR
2/27/07.
Sample Analysis. The method blanks contained no responses greater than the 1613 low
calibration standard. In general, all labeled compound recoveries for the blank and samples were
within the acceptable range of'25 lo 150 % for 1613A. They also met the requirements of 1613B.
Several samples (FL-06-IR, for example) produced curious results in which the first and last
eluting isomers for TCDD, PCDD, HxCDD, and 1-lpCDD were found. Usually they were found
absent some or all the 2,3,7,8-containing isomers within their respective degrees of chlorination.
Weyerhaeuser Analytical & Testi.rvices
32901 Weyerhaeuser Way South
Federal Way, WA 98003
Report
Plymouth -Groundwater/Leaf Litter
Blank
2/27/2007
Com ound Name ( t)
TCDD ND(0.002)
2,3,7,8-TCDD ND(0.002)
PCDD ND(0.002)
1,2,3,7,8-PCDD ND(0.002)
HxCDD ND(0.002)
1,2,3,4,7 ,8-HxCDD ND(0.002)
1,2,3,6,7,8-HxCDD ND(0.002)
1,2,3,7,8,9-HxCDD ND(0.002)
HpCDD ND(0.004)
1,2,3,4,6,7,8-HpCDD ND(0.004)
OCDD ND(0.007)
TCDF ND(0.001)
2,3,7,8-TCDF ND(0.001)
PCDF ND(0.001)
1,2,3,7,8-PCDF ND(0.001)
2,3,4,7,8-PCDF ND(0.001)
HxCDF ND(0.002)
1,2,3,4,7,8-HxCDF ND(0.002)
1,2,3,6,7,8-HxCDF ND(0.002)
2,3,4,6,7,8-HxCDF ND(0.002)
1,2,3,7 ,8,9-HxCDF ND(0.002)
HpCDF ND(0.003)
1,2,3,4,6,7,8-HpCDF ND(0.003)
1,2,3,4,7,8,9-HpCDF ND(0.003)
OCDF ND(0.003)
EPATEQ (1.000
Approved: Randy Eatherton
Telephone: [phone]
FL-06-IR tot.
2/27/07 1030
07-0508-00 I
( t)
0.032
ND(0.007)
0.012
ND(0.003)
0.060
ND(0.002)
0.002
0.012
0.094
0.041
0.876
ND(0.003)
ND(0.003)
ND(0.002)
ND(0.002)
ND(0.002)
ND(0.001)
ND(0.001)
ND(0.001)
ND(0.001)
ND(0.001)
0.001
0.001
ND(l.000)
ND(0.003)
0.003
~e Request: 07-0508
tale Cert.#: C1219
FL-06-IR diss. FL-04-IR tot. FL-04-IR diss.
02/27/07 1030 02/27 /07 1405 02/27 /07 1405
07-0508-002 07-0508-003 07-0508-004
( Jt) ( t) ( t)
ND(0.003) 0.013 ND(0.003)
ND(0.003) ND(0.008) ND(0.003)
ND(0.002) ND(0.003) ND(0.003)
ND(0.002) ND(0.003) ND(0.003)
0.019 ND(0.004) 0.003
ND(0.003) ND(0.004) ND(0.003)
ND(0.003) ND(0.004) ND(0.003)
ND(0.003) ND(0.004) ND(0.003)
0.019 0.014 0.007
0.008 0.007 0.003
ND(0.003) 0.130 0.014
ND(0.002) ND(0.002) ND(0.002)
ND(0.002) ND(0.002) ND(0.002)
ND(0.002) ND(0.001) ND(0.002)
ND(0.002) ND(0.001) ND(0.002)
ND(0.002) ND(0.001) ND(0.002)
ND(0.002) ND(0.002) ND(0.001)
ND(0.002) ND(0.002) ND(0.001)
ND(0.002) ND(0.002) ND(0.001)
ND(0.002) ND(0.002) ND(0.001)
ND(0.002) ND(0.002) ND(0.001)
ND(0.002) ND(0.001) · ND(0.002)
ND(0.002) ND(0.001) ND(0.002)
ND(0.002) ND(0.001) ND(0.002)
ND(0.004) ND(0.002) ND(0.002)
0.000 0.000 0.000
Date: 3/8/07 EPA: 1613
io §, ____________________________________ :__ __
~ TOP OF OPEN •-----~ • LJ CASING POINT ~ LOCKING STEEL PROTECTIVE COVER
g
~ :a
----<(
i5 ,.:,
~
----
WEEP HOLE~
' DEPTH (FT) o.O
1.5
3.0
1 .0
13.0
// VENTED CAP ,r r CONCRETEPAD
r LANDSURFACE
/ ELEV. 1r1-~.-----'-'------., /
~ BOREHOLE
~
r%:a-----GROUT
Portland Cement
--WELL CASING
2-inch SCH 40 PVC
--BENTONITE SEAL
"----BentoniteSlurry
··· .. ···1· ______ SAND PACK
. ....... Silica Sand
b--l..;".:+------WELL SCREEN
2-inch SCI-I 40 PVC .010
machine slot
WELL CONSTRUCTION DIAGRAM
Not To Scale
PROJECT ______ ____,_W,_,1:..,iYcsE,.cR,.._H,.cA.>.cE"-'U'-"S~E"'R _______ _
PRO) ECT NO. --------""-51.,_1"'5"'.1'-"0 ___________ _
WELL NO. ______ Fc,·L"°-0"'6c:,-lc,:,R~ _________ _
DATE INSTALLED ___ _,,2L20L~0~7 __________ _
DRILLING CONTRACTOR _.,_P,,,arcer,"'at,:t-c.cv\,_,1o""l'-'-ff'-'i"-'n"-'c. ________ _
RMT GEOLOGIST _________________ _
"' g,----------------------------------------
TOI' OF OPEN •------CASING POINT
~ :;:
----~ ~ ,,_
----<(
iS .:,
~
----
WEEP HOLE~
' DEPTH (FT.)
0.0
1.
3.0
13.0
• ~ LOCKING STEEL PROTECTIVE COVER
'l VENTED CAP / r CONCRETE PAD
r LA~DSURFACE ~b-~~'~ ELbV. " , " " . ' ~
~ BOREHOLE
~
--------WELL CAS!NC
--------2-inch SCH 40 PVC
BENTONITE SEAL
Bcntonitc Slurry
IJ------SAND PACK
Silica Sand
G .... c'-4------WELL SCREEN
2-inch SCI-[ 40 PVC .010
machine slot
WELL CONSTRUCTION DIAGRAM
Not To Scale
PROJECT _______ .,_½,.,'E,..,YceEe.cRs.cl-I-'-'A"'E"',U"'S"-'E"'R'---------
PROJ ECT NO. _____ _,5'-"1_.,_,15"'-.lo,0'-------------
WELI, NO. ----------'-F2cLc,-0c,4::..,-1c.eR,__ __________ _
DATE INSTALLED ___ ____,,2"-/2=0L_,,07,_ __________ _
DR! LU NC CONTRACTOR _.,_l'."'a1-"-ra"-'t-'=t-.,_Wc;o,._,lf"'f--'i1.,,1e=. _______ _
RMTCEOLOC!ST __________________ _
, ON RESIDENTIAL WELL CONS!CTION RECORD
North Carolina Department of Environment and Nawrnl Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION# _3_35_9 ________ _
1. WELL CONTRACTOR:
NATHAN SWEETING
Wei! Contractor (Individual) Name
PARRA TT-WOLFF, INC.
Well Contractor Company Name
STREET ADDRESS 501 MILLSTONE DRIVE
HILLSBOROUGH, NC 27278
City or Town State Zip Co<Je
< 919 )-644-2814 -
Area cede-Phone number
2. WELL INFORMATION:
SITE WELL ID #(ii applicable)_F_L_-0_6_-_IR __________ _
STATE WELL PERMIT#{if applicable) __________ _
DWQ or OTHER PERMIT #{if applicable) ________ _
WELL USE (Check Applicable Box) Monitoring Kl Municipal/Public O
Industrial/Commercial D Agricultural D Recovery D Injection □
Irrigation□ Other □ {list use) ___________ _
DATE DRILLED 2120I07 --------
TIME COMPLETED AMO PMO
3. WELL LOCATION:
CITY: PLYMOUTH COUNTY WASHINGTON
NC ROUTE 149
{Street Name, Numbers., Community. Subdivision. Lot No., Parcel, Zip Code)
TOPOGRAPHIC/ LAND SETTING:
□Slope □Valley OFlal □Ridge O Other ______ _
(check appropriate box}
LATITUDE ..l,_ ~ 51.700'
LONGITUDE 7 6 _46_._69_2_' -~
May be in degrees,
minutes, seconds or
in a decimal rormat
Latitude/longitude source: oGPS ![)Topographic map
(locsrion of well must be shown on a USGS topo map and attached to this form if not using GPS)
4, FAC/UTY. ,s u,e namo or I.he business whoro 1116 well is locatoi:t.
FACILITY ID #{if applicable) __________ _
NAME OF FACILITY_W_E_Y_ER_H_A_E_U_S_E_R _______ _
STREET ADDRESS NC ROUTE 149 -------------PLYMOUTH NC 27962
City or Town State Zip Co<Je
CONTACT PERSON ____________ _
MAILING ADDRESS ____________ _
City or Town State Zip Code
Area code -Phone number
6. WELL DETAILS:
a. TOTAL DEPTH:_1_3_.0_' ____ _
b. DOES WELL REPLACE EXISTING WELL? YES D NO (lJ
c, WATER LEVEL Below Top of Casing: 3.0 FT.
(Use"+" if Above Top of Casing)
d, TOP OF CASING IS O FT. Above Land Surface'
•rop of casing terminated aVor below land surface may require a variance in accordance with 15A NCAC 2C .0118.
o. YIELD (gpm): NIA METHOD OF TEST_N_I_A ___ _
f. DISINFECTION: Type NIA Amount_N_IA ___ _
g. WATER ZONES {depth):
From ___ To __ _ From ___ To __ _
From ___ To __ _ From ___ To __ _
From ___ To __ _ From ___ To __ _
6. CASING: Thickness/
Depth Diameter From_O __ To~ FL_2_" __ ~(t.£14h0t ~crial
From ___ To ___ FL. __ _
From ___ To ___ Ft.. __ _
7. GROUT: Depth Material
From O To .5 Fl PORTLAND
From .5 To 1-5 Fl: BENTONITE
From ___ To ___ FL _____ _
8. SCREEN: Deplh Diameter Slot Size
From~ To~ 2" Fl. __ In. .010 in.
From To ___ Ft in. in. ------From ---To ___ Fl ---in. in.
9. SAND/GRAVEL PACK:
Method
TREMIE
TREMIE
Material
PVC
Depth Size Ma!erial
From 1.5 ToE.:2.,_ FL #1 SAND
From To ___ Fl.
From To ___ FL
10. DRILLING LOG
From To Formation Description
0 4.0' light gray. wet, very fine SAND
4.0 12.0 Tan wel coarse GRAVEL & SAND
11. REMARKS:
I DO HEREBY CERTIFY THAT rnIs WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15A NCAC 2C. WELL CONST UCTION STANO , AND TKAT A COPY OF THIS RECORD HAS BEEN PR W NER.
SIG
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt., 1617 Mail Service Center-Raleigh, NC 27699•1617 Phone No. (919) 733•7015 ext 568. Form GW-ib
Rev. 7/05
; --l
I I I --, ----1---,-
! I I I I , I
o::•mv,L NOU:R
· ;~~:n,:.."'..!'~t ...... -·· ·--"·" ..,._,
,. ~~~=-·~~'.~.~5 .. •:~i,t r,.;.--r..:.:..~
LEOEHO
'"·'~--c-<oo-c .... , -,~ .. ___ , __ -"'-"-
A Weyerhaeuser
,...,, .. ,,,, ,.,.,.•ou,,..,.r LOCU'°""' ,:,-, --,oo-, .,...u&
'ON RESIDENTIAL WELL CONS!CTION RECORD
North Carolina Department of Environment and Natural Resources-Division of Water Quality
WELL CONTRACTOR CERTIFICATION 11 _3_35_9 ________ _
1. WELL CONTRACTOR:
NATHAN SWEETING
Well Contractor ()ndividual) Name
PARRA TT-WOLFF, INC.
Well Contractor Company Narne
STREET ADDRESS 501 MILLSTONE DRIVE
HILLSBOROUGH, NC 27278
City or Town
1919 l· 644-2814
Area cede-Phone number
2. WELL INFORMATION:
State Zip Code
SITE WELL ID #(If applicable)_F_L_·0_4_·_IR __________ _
STATE WELL PERMJT#(if applicable), __________ _
DWQ or OTHER PERMIT #llf applicable! ________ _
WELL USE (Check Applicable Box) Monitoring © Municipal/Public O
lndustriaVCommercial □ Agricultural □ Recovery □ Injection □
Irrigation□ Other □ {!isl use) __________ _
DATE DRILLED_21_20_10_7 _____ _
TIME COMPLETED _______ AMO PM 0
3. WELL LOCATION:
CITY: PLYMOUTH
NC ROUTE 149
COUNTY WASHINGTON
(Street Name, Numbers, Community, Subdivision, Lot No,. Parcel, Zip Codo)
TOPOGRAPHIC I LAND SETTING:
□Slope □Valley □Flat □Ridge O Other ______ _
(check appropriate box)
LATITUDE ..1_ ~ 51.700'
LONGITUDE _7 ~ _46_.6_9_2_' __
May be in degrees,
minules, seconds or
in a decimal format
Latitude/longitude source: oGPS KJTopographic map
(location of well mvs1 be shOwn on a USG$ topo map and attached to this form if no/ using GPSJ
4. FACILITY-is thlt namo of lho ouslnoss whore tho well is located.
FACILITY to #(if applicable) ___________ _
NAME OF FACILITY WEYERHAEUSER
STREET ADDRESS NC ROUTE 149
PLYMOUTH NC 27962
City or Town State Zip Code
CONT ACT PERSON
MAILING ADDRESS
City or Town State Zip Code
Area code. Phone number
5. WELL DETAILS:
a. TOTAL DEPTH:_1_3_.o_· -----
b. DOES WELL REPLACE EXISTING WELL? YES O NO [ll
c. WATER LEVEL Below Top of Casing: 3.0 FT. (Use"-+" if Above Top of Casing)
d, TOP OF CASING IS 0 FT. Above Land Surface• 'Top of casing terminated avor be!O'N land surface may require
a variance in acc~rdance with 15A NCAC 2C .0118.
e. YIELD 1gpm}: _N_/A ___ METHOD OF TEST_N_I_A ___ _
f. DISINFECTION: Typo NIA Amount _N_IA ___ _
g. WATER ZONES (depth):
From ___ To ___ From ___ To __ _
From ___ To___ From ___ To __ _
From ___ To___ From ___ To __ _
6, CASING: Thickness/
Depth Diameter From_0 __ To~Ft_2_" __ ~ejrol
From ___ To ___ Ft. __ _
From ___ To ___ Ft. __ _
7. GROUT: Depth Material Method
TREMIE From O To .5 Ft. PORTLAND
From .5 To 1.5 Ft. BENTONITE TREMIE
From ___ To ___ Ft. _____ _
8. SCREEN: Depth Diameter Slot Size Material
From~ To~ 2" Ft. __ in. .010 in, PVC
From ---To ___ Ft. --in. in.
From ___ To ---Ft. --in. in.
9. SAND/GRAVEL PACK:
Depth Size Material
From 1.5 To.21£_ Ft. #1 SAND
From To ___ Ft.
From To Ft. ---
10. DRILLING LOG
From To Formation Description
0 6.0' Light grny, wol. modium fine/fine, SAND
9.0 13.0 Brown, wet, medium fine/fine SAND
11. REMARKS:
I 00 HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH \ 5A NCAC 2C, W ARDS, AND THAT A COPY OF THIS RECORD HA l'lJl~Ji~ "-"'o/"'f'l OWNER.
SI CONTRACTOR l1,rfiJ[
CONSTRUCTING THE WELL
Submit the original to the Division of Water Quality within 30 days. Attn: Information Mgt., 1617 Mail Service Center-Raleigh, NC 27699-1617 Phone No. [phone] ext 568. Form GW-1b
Rev. 7105
l I
---+-L---·-·-···.
I\
I
-·-i---_J
-~~Tl LOCAr,Q,/d,n.,_no,,
""--"IIIIV.1-II OF ·--= --
• ly
~
Domtar
. April 22, 2008
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection agency, Region 4
Atlanta Federal Center
61 Forsyth Street, S. W.
Atlanta, GA 30303-3104
•
Subject: Domtar Paper Company, LLC, Plymouth, North Carolina
Domtar Paper Company, LL(
Plymouth Mill
PO Box 747
Highway l <19 North
Plymouth, NC 27962
Tel.: [phone]
Operable Unit No. I (OU-1; Fonner Landfill No. 1 Area) First Quarter Leaf Litter Report
Mr. Bryant,
Enclosed please find 2 copies of the letler report documenting the results of the leaf litler
sampling which occurred at Landfill No. I in February 2008. Copies of the lctler report
have also been provided to North Carolina departn1ent of Environment and Natural
Resources (NC DENR). The next round of groundwater, wetland soil, and leaf litter
sampling activities arc currently scheduled for November 2008. Please feel fr~e to
contact me or Mike Parker at RMT with questions.
Bill Morris
~!YldJS
"iinvironmental Engineer
Domtar Plymouth Mill
Cc: Nile.Testerman
Marcel Sylvestre
Diane Hardison
www.domtar.com
(21\-
• •
•ENVIRONMENT• ENERGY• ENGINEERING
April 14, 2008
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region 4
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, GA 30303-3104
Subject: Domtar Paper Company, LLC (Domtar), Plymouth, North Carolina
Operable Unit No. 1 (OU-1; Former Landfill No. 1 Area) First Quarter Leaf Litter Report
Dear Mr. Bryant:
· RMT North Carolina, Inc. (RMT) on behalf of Domtar is submitting this letter and attachments to
describe site-related activities conducted during the first quarter of 2008 reporting year for the OU-1
at the Domtar (formerly Weyerhaeuser Company [Weyerhaeuser]) Plymouth, North Carolina facility.
Per the Field Sampling and Analysis Plan (FSAP: RMT 2004), leaf litter samples are collected during
both the fourth quarter and first quarter annually. This letter documents the results of the leaf litter
sampling that occurred in February 2008. The groundwater, wetland soils, and fall 2007 leaf litter
sampling results were reported in the Annual Monitoring Report Operable Unit 1 -Former No. I landfill
Area (RMT, 2008). Attached to this letter are the following:
■ Photographs of leaf litter sample containers (Attachment 1)
■ Summary table of leaf litter analytical results for samples collected in February 2008
(Attachment 2)
■ Case narrative for mercury leaf litter samples collected in February 2008 (Attachment 3)
Leaf Litter Analyses
Leaf litter samples were collected from OU-1 sample collection containers on February 6, 2008. The
leaf litter containers show some disturbance from local wildlife as indicated in the photographs in
Attachment 1. Samples were not compromised by the container disturbance. The five sampling
locations are the same as presented in the Annual Monitoring Report for OU-1 (RMT, 2008). Sample
location designations are referenced to existing soil and groundwater sampling locations. For your
convenience, we have included data from prior leaf litter sampling events on Table 1. Mercury
concentrations observed in the November 2007 leaf litter samples ranged from 0.0486 to 0.0628 mg/kg
I:\ Wl'GVL \Pff\00-05170\02\ l..000517002-001.DOC
30 Patewood Drive, Suite 100 • Greenville, SC 29615-3535 • [phone] • [phone] FAX• www.rmtinc.com
C R E A T I N G B A L A N C E'"
•
Mr. Randy Bryant
United States Environm.ental Protection Agency, Region 4
April 14, 2008
Page2
•
of dry leaf weight with an average concentration of 0.0557 mg/kg. The concentration in leaves
remains below the mercury soil ecological clean-up goal of 0.4 mg/kg dry soil. The results from the
February 2008 sampling event are slightly higher than results from the November 2007 sampling
event and consistent with the February 2007 sample results. Leaf litter samples will be collected again
in November 2008. As shown in Table 1 (see Attachment 2), leaf litter samples collected during the
winter sampling events Qanuary 2006, February 2007 and February 2008) exhibit somewhat higher
mercury concentrations when compared to leaf litter samples collected in late fall (November 2005,
November 2006 and November 2007). The observable trends in mercury concentrations will be
evaluated at the completion of the five-year OU-1 monitoring period.
Mercury Deposition
As indicated in the Annual Monitoring Report for OU-1 (RMT, 2008) mercury deposition for the
52 week period ending April 17, 2007 (which represents the most recent data reported for this
monitoring station), the mercury deposition rate for the Pettigrew State Park NADP/MDN station was
12.6 µg/m 2/year. Utilizing this deposition rate, the total mercury deposition for the 87 acre
(350,000 m2) No. 1 landfill is calculated to be 4.4 grams with some percentage loss to the wetlands.
Since the annual report was prepared, the NADP/MDN station has not reported additional mercury
deposition rates. The mercury deposition data for Pettigrew State Park NADP/MDN station will be
reviewed and presented in the next annual monitoring report for OU-1.
Scheduled Events
Leaf litter samples will continue to be obtained in the fourth and first quarters annually. For the
2008-2009 reporting year, Domtar will conduct annual groundwater, wetland soil and leaf litter
sampling during the fourth quarter 2008. Leaf litter samples will be collected during the first quarter
2009. As with the prior sampling events, wetland soil and leaf litter samples collected for the 2008
annual sampling event will be collected and analyzed using low-level mercury sampling and analysis
methods. This approach will be used to ascertain if soil mercury concentrations exhibit a discernable
trend over the time frame that Domtar is required to monitor the effectiveness of the OU-1 remedy.
Leaf litter sample containers and monitoring wells will be inspected and repaired as necessary during
field activities.
I:\ WPGVJ, \ Pff\()(J.Q5l70\02\IJJ00517002-lXJl.DOC
C R E A T I N G B A L A N C E'"
•
Mr. Randy Bryant
United States Environmental Protection Agency, Region 4
April 14, 2008
Page3
•
Please contact me or Bill Morris of Domtar if you have questions or need additional information
regarding the information contained in this letter.
Sincerely,
RMT North Carolina, Inc.
~g-~
Michael B. Parker, P.E.
Senior Client Service Manager
Attachments
I:\ WPGVL \ l'ff\00--05170\02\ L000517002-001.DOC
C R E A T I N G B A L A N C E'"
I:\ WPCVL\ l'ff\00-05170\02\ LOOOS17002·001.[X)C
Attachment 1
Photographs
•
•
Client Name:
Domtar Paper Company, LLC
Photo No.
1
Description
Date
02/06/08
Photograph of leaf litter
collection container. Container
has "teeth" marks, possible
from local wildlife.
Photo No.
2
Description
Date
02/06/08
Photograph of leaf litter
collection container. Container
has "teeth" marks, possible
from local wildlife.
I:\ WPGVL \ l'JT\00-()5170\02\Lll005l7002-001.DOC
•
Site Location: Project No.:
Plymouth, North Carolina 00-05170.02
•
Mercury Nov-2005 0.0536 0.0491 0.0427 0.0398 0.0471
Mercury Jan-2006 0.0633 0.0788 0.107 0.0566 0.0489
Mercury Nov-2006 0.0504 0.0443 0.0358 0.0365 0.0488
Mercury Feb-2007 0.0628 0.0591 0.0479 0.057 0.0544
Mercury Nov-2007 NA 0.0189 0.0403 0.0364 0.0377
Mercury Feb-2008 0.0544 0.0486 0.0506 0.0628 0.0622 ,,, Analytical results are reported in milligrams per kilogram (mg/kg) unless otherwise noled.
NA Not analyzed.
I:\ WPGVL \ Pff\ 00-05170 \ 02 \ L.000517002-001. OCX:
• •
Attachment 3
Laboratory Case Narrative
I:\ WPGVL \ Pff\ 00-05170 \ 02 \ LOOOS 17002-001.DOC
9143 Philips Highway, Suile 200
March 07, 2008
Heather Smith
RMTinc.
30 Patewood Drive
• Jacksonville, FL 32256
Suite I 00 Patewood Plaza One
Greenville, SC 29615-3535
RE: Domtar Analytical Support/5170.02
Dear Heather:
[phone] [phone] fax
An Employee -Owned Company
Service Request No: 10800784
Enclosed are the results of the sample(s) submitted to our laboratory on February 15, 2008. For
your reference, these analyses have been assigned our service request number J0800784.
All analyses were performed according to our laboratory's quality assurance program. The test
results meet requirements of the NELAP standards except as noted in the case narrative report.
All results are intended to be considered in their entirety, and Columbia Analytical Services, Inc.
(CAS) is not responsible for use ofless than the complete report. Results apply only to the items
submitted to the laboratory for analysis and individual items (samples) analyzed, as listed in the
report. In accordance to the NELAC 2003 Standard, a statement on the estimated uncertainty of
measurement of any quantitative analysis will be supplied upon request
Please call if you have any questions. My extension is . ·You may also contact me via email at
[e-mail].
Respectfully submitted,
Columbia Analytical Services, Inc.
Tom Kissinger
Project Chemist
Labora/ory Manager: Greg Jordan
Quality Assurance Officer: Kathy Brungard
Page I of / 7
CAS Jacksonville is NELAC-accredited by the State of Florida, #£82502 valid through 6/30/08.
Other slate accreditations include: Arkansas, #88-0600 valid through 1/12/06; Georgia, #958 valid
through 6/30/08; Louisiana, #02086 valid through 6/30/08; Texas, #Tl 04704197-06-TX valid
through 5/31/08; North Carolina, #527 valid through 12/31107; South Carolina, #96021001 valid
through 6/30/07. I • NELAP Accredited ACIL Seal of Excellence Award
Client: RMT!nc. • • Service Request: 10800784
Project: Domtar Analytical Support/5170.02
SAMPLE CROSS-RJ<:FERENCE
SAMPLE# CLIENT SAMPLE ID DATE TIME
10800784-00 I FLLL-01 02/06/08 09:00
10800784-002 FLLL-06 02/06/08 09:10
10800784-003 FLLL-03 02/06/08 09:15
10800784-004 FLLL-04 02/06/08 09:20
10800784-005 FLLL-05 02/06/08 09:30
2
Printed 03/07/2008 14:51 Sample Surrimary Page I of I
'
• Columbia Analytical Services,A.
Cooler Receipt and Preservation F:lllllll'r
Client: ___ R.!'r,r __ t; u,~-,iL Service Request# ~Qi<{lli_Y.,_~~
Project: _j)o,,,,v '-y
Cooler received on ] -lf·v& and opened on ...£Ii· .::,J by S<.
COURIER CAS UPS ~ DHL CLJENT Tracking# 'X/2cJ/ D!;6l 4N{ -
1 Were custody seals on outside of cooler? 'Yes G_g) NIA
2 Were seals intact, signed and dated? \{ es No ;;{'c)
3 Were custody papers properly fillecl ou!'! /fey No NIA
4 Temperature of cooler(s) upon receipt (Shot.Id bL•, 4 ·ii-2 dcg1 tes C) _,JJ// .
·5_ Correct Temperature'' _\e, No \I.A
6 Were lee or Ice Packs present ycy No NIA
7 Did all bottles arrive in good condition (unbroken, etc .... )? ~ No N/A
8 Wei"e aU bottle labels complete (sample ID, preservation, etc .. . )? ~s No NIA
'-' (J Did all bottle labels and tags_agree with custody papers? /Ye} No NIA
] I) Were the correct bottles used for the tests indicated'' i), No NJ.A,
11 \Vere :ill of the preserved bottles received with the. appropriate preservative? Yes No ~
HN03 pl-1<2 H2S04 pf-1<2 ZnAc21NaOH pf-1>9 NaOH pH>\2 I-IC\ pl-1<2
!'rc:servativc additions noted below
12 Were all saniples received within analysis holding times? i'e0 No NIA
13 Were VOA vials checked for _absence of air bubbles'? If present, notf! below Yes No Q!tt,
I 4 Vihere did the bottles originate'' Ci\S <Uie,~
M anuf. Lot# or CAS
Sample ID Reagen! Chem ID 111\ added lnilitials -
.
. _ .Aclclitional comments and/or explanation of all discrepancies noted above:
C! ient appioval lo run smnplcs if.discrcpnncies noted: n,..,1n•1, .L.'>-<cv.
Cu,,1...,i,,c,
Somp[e #
-001
002
-003
.oo,
-005
-006
-007
-ooe
' ·-5--15 7 8 9 ---➔Oml ~Qn,l <:OmL 40ml 125,n l 125m 125ml 125ml 25-JmL
G G G G e e e ,, p
NIA
Bottle Code
"' 11 12 13 " ~ 5(11nl ::'50111 250ml 250,111 250ml. 250,nl
e p p
lni!ials: __ 5_L ______ _
16 17 18
50vml 500ml 500m
p e
; .,'. H2SO
.;NiA" <2
e
19
IL
p
20
IL
e
21
IL
G
22
G
23
IL
24 2s 25 21 2a 29 ~o
2oz 4oz Boz 16o? Sn 100ml I-~-
J.· .;
WA NIA
1--+---l--~l--+--+--+--t----+--+-+---i--+-+--+·-C-+---l--+-+--~_!.......
I,
r---~-f--t--t----11---+---+--+--+---+--+--+-+--t--4--+--+--+-+-t-+--+--+-il--+---+--t---l--+--I
-009 . 1---1----l,----+--+---+--+----+---ll--+----+--l---+---+--+---l--+---+---l-+--+-+--1---+-+--+-+----ll---1-----ll---l
.010
-011
-012
·022
-023
-024
·025
--+-----lC--+--+-+---l------+---+---l----ll--+--+--f--t----+--+-t---i--+-+---+-11--+-l---+---l----+---t
-~-1-------+---+---+--+--+--+--l--l--l--l-+---l-l--+--+--+-l-+-il---+--+--I
c---+--1---+----1-------·--~-} __ , . .J-.---1---.J-.-'--.J-.--+--+--+---+----+-l--l-.J-.--l--1-+--1---1----l---1--+-I
e---+-+---+---+-~1---+--+-+-·-L..:. ... c... .... -1---+--+--•l---l--l---+--+--+-+-+--
_j __ -+--+---+--+---+~-+---+--+----I-+-+--+--+---+-f--+-f--+-+--+---+
---1--+--+---+---!--+-+-+---+---l-+--------+--+--l-.J-.---+--+--+--1--1--
1----+--+---+--+--1----+-----'---L-1--1--1--+-+-~1---1----+--+-+-+-1-1--~-·--1--1-+---+--+---+--
i:=_--1~-1-==!"=~=~=~=_::!-=--1~--~-f---+--+---+--+---lf----if----+---+--1-t---ll-+---l-1-+--+-l---1---+-+--
-----··-·-· -·-·---4-~+----+--+---l--+--+--+--l--l-+-+--l---+--f--+--l-+--l---1--
1-----+---l---l----11--l--il--il--l--l----+---+---+--+--+---+---+---+--+-+----+---+-1--!---+--+--il----+--
+----+--l--1---+--+-------l--+--+--+---l--+-+-+--+--l-+--l-+--l--l--l--+-+---l---l----1-........j
~-+-+--f---1----1---i----!--+-+---l---l----+---l--l-.-Jl--l---!--+--I--+-l----l--f--!---+--1----l---+--+-
:--_ .. __ :.-____ L-_-_1---J..---l-----·-·1---_-_··+-+--+---l--ll----+--l--f--l--+--+--+--l--+.-l-+---+-J_ !--+----+-·----
--------' ---____ L_-J. __ .L_--l ___ .L__-l-.L---l_.L--J--l-_-J._--J ___ L_
•
•
CHAIN OF CUSTODY RECORD
30 Patewood Drive, Suite 100, Patewood Plaza One, Greenville, SC 29615-3535
Phone [phone] • Fax [phone]
Lab No. Yr.QC
Date Time
SPECIAL INSTRUCTIONS
Sample Station ID
F=°LLL-0 I
FLLL-ol
SAMPLER Relinquished by (Signature) Date/Time Received by (Signature) Date/Time
o~//4-/03
i :
re) Date/Time
Custody Seal: Present/ Absent
F-268 (6/04)
Preserved (Code)
HAZARDS ASSOCIATED
WITT-I SAMPLES
D Flommoble
0 Corrosive
□ Highly Toxic
O Otlm (list)
WHITE-tABORATORY COPY
A-NONE
B-HN03
C-H2S0i
D-NoOH
E-HCI
F -:-METHANOL
G-
Turn Around {circle one) Normal Rush
Report Due ___________ _
(For Lab Use Only)
Receipt Temp:
Temp Blank Y N
YEllOW-REPORT APPENDIX
Receipt pH
(Wet/Metals)
~NK-SAMPLER/SUBMITTER
a~l~~~\~al •
Services'"'
An Employee-Owned Company
• Columbia Analytical Services
8540 Baycenter Road
Jacksonville, FL 32256
Tel [phone]
Fax [phone] l
Appendix A
Subcontracted Analytical Results
6
• •
131iSoulh 131h Avenue P.O. Box 479 Kelso, Wa,;;hing1011 98626 [phone] [phone] fax
March 6, 2008 Analytical Report for Service Request No: J0800784
Mandy Sullivan
Columbia Analytical Services
8540 Baycenter Rd.
Jacksonville, FL 32256-7460
RE: Domtar Analytical Support/5170.02
Dear Mandy:
+ ...
Ail~~~i~al
Services"'
An Employee -Owned Com1nmy
Enclosed are the results of the samples submitted to our laboratory on February 15, 2008. For your
reference, these analyses have been assigned our service request number ]0800784.
All analyses were performed according to our laboratory's quality assurance program. Where
applicable, the methods cited conform to the Methods Update Rule (effective 4/11/2007), which relates
to the use of analytical methods for the drinking water and waste water programs. The test results meet
requirements of the NELAC standards. Exceptions are noted in the case narrative report where
applicable. All results are intended to be considered in their entirety, and Columbia Analytical
Services, Inc. (CAS) is not responsible for use ofless than the complete report. Results apply only to
the items submitted to the laboratory for analysis and individual items (samples) analyzed, as listed in
the report.
Please call if you have any questions. My extension is 3291. You may also contact me via Email at
[e-mail].
Respectfully submitted,
Columbia Analytical Services, Inc.
~p~
Project Chemist
EW/lb Page I of i f
• NELAP Accredited ACIL Seal of Excellence Award 7
ASTM
A2LA
CARB
CAS Number
CFC
CFU
DEC
DEQ
DHS
DOE
DOH
EPA
ELAP
GC
GC/MS
LUFT
M
MCL
MDL
MPN
MRL
NA
NC
NCASJ
ND
N!OSH
PQL
RCRA
SIM
TPH
tr
• • Acronyms
American Society for Testing and Materials
American Association for Laboratory Accreditation
California Air Resources Board
Chemical Abstract Service registry Number
. Chlorofluorocarbon
Colony-Forming Unit
Department of Environmental Conservation
Depaiiment of Environmental Quality
Department of Health Services
Department of Ecology
Department of Health
U.S. Environmental Protection Agency
Environmental Laboratory Accreditation Program
Gas Chromatography
Gas Chromatography/Mass Spectrometry
Leaking Underground Fuel Tank
Modified
Maximum Contaminant Level is the highest pennissible concentration of a
substance allowed in drinking water as established by the US EPA.
Method Detection Limit
Most Probable Number
Method Repo11ing Limit
Not Applicable
Not Calculated
National Council of the Paper Industry for Air and Streain Improvement
Not Detected
National Institute for Occupational Safety and Health
Practical Quantitation Limit
Resource Conservation and Recovery Act
Selected Ion Monitoring
Total Petroleum Hydrocarbons
Trace level is the concentration of an analyte that is less than the PQL but greater
than or equal to the MDL.
8
• •
Inorganic Data Qualifiers
"' The rt:Su!t is an outlier. See case narrative.
# 111c control limit cri1eria is no1 applicable. See case ntllTative.
B 1l1e analyte was found in the nssociaied method blank at a level that is significant relative to the sample result.
E 1l1e resull is an estimate amount because the value exceeded the instrument cu!ibrntion range.
The result is an estimated concentration that is less than the MRL but greater than or equal to the M Dl.
U The compound was analyzed for, but was not detected ("Non-detecn at or ahove the MRUMDL.
The MRUMDL has been elevated due lo a matrix interference.
• X See case narrative.
B
E
M
N
s
u
w
X
•
Metals Data Qualifiers
The control limi1 criteria is not Hpplicahle. See case narrative.
The result is nn estimated concentration that is less than the MRL but greater th1m or equal to the MDL.
Tiie percent difference for the serial dilution was greater than 10%, indicating a possible matrix inierferem:e in the sample.
The duplicate injection precision was n()t met.
Tin: Matrix Spike sample re-:avery is not within control limits. See case narrative.
The repon~ value wns detenninc<l by the Method of Swntlard Additions (MSA).
Tiie compound was analyzed for. but was nol detected ("Non-detect") at or above the MR.UMDL.
The post~digestion spike for furnace AA analysis is out of control limits, while sample absorbance is less than 50% of spike
absorbnnce.
The MRIJMDL has been elevated due to a matrix interference.
See c11se nmTative .
The duplicate analysis not within control limiL'i See case narrative
The correlation coe.fficient for the MSA is less than O.995.
Organic Data Qualifiers
The result is an outlier. Sec case nam\tive.
# The control limit criteria is TIO! applicable. See case narrative
A A tentatively identified ~mpound, 11 suspected aldol-condens111ion product.
B TI1e onnlyte wos found in the associated method blank at a !eve! that is significam relative to the sample result.
C The analyte was qualitatively confinned using GC!MS techniques, panem recognition. or by comparing to historical data.
D The reported n:sult is from a dilutiun.
E The result is an estimate amount because lhe value exceeded the instrument calihration nmge.
N
p
u
The result is an estimated concentration that is less than the MRL but greater than or equal to the MDL
The result is presumptive. The analyte was tentatively identified, but a confirmation analysis was not performed.
The GC or HPLC confinnation criteria was exceeded. The relative percent difference is greawr thnn 40% between th·e two
analytical results (25% for CLP Pesticides).
The compound was analyzed for, but was n0! det1..>cted ("Non-detect") nt or above the MRl.JMDL.
TI1e MRUMDL has been eleva!ed due 10 a chromatographic interference.
X See case narrative.
F
L
H
0
y
z
Additional Pe.troleum Hydrocarbon Specific Qualifiers
Tht chrommogrnphic lingtrprinl of the sample mutt:he~ the dutiun pattern of the calibrntiun o:tand~rd.
The chromatographic fingerprint of1ht sample resembles a petroleum product, but the elution pattern indicatts the presence of
a greater amount of lighter molecular weight cons1ituents than the calibration standard.
The chromatographic fingerprin1 of the sample resembles a petroleum product, but the elution pattern indicates the presence of
a gremer amoum of heavier molecular weight constituents than the calibration standard.
The chromatographic fingerprint oftbe sample resembles an oil, but does not match the calibration standard.
The chromatographic fingerprint of the sample resembles a petroleum product eluting in approximately the correct carbon
range, but the elution panem does noi match the calibration standard.
The chromatographic fingerprint does not resemble a petroleum product. -000 3
9
• •
Columbia Analytical Services, Inc.
Kelso, WA
State Certifications, Accreditations, and Licenses
Pro2:ram Number
Alaska DEC UST UST-040
Arizona OHS AZ0339
Arkansas - D EQ 88-0637 .
California OHS 2286
Colorado DPHE -
Florida DOH E87412
Hawaii DOH -
Idaho DHW -
Indiana DOH C-WA-01
Louisiana DEQ 3016
Louisiana DHH LA050010
Maine OHS WA0035
Michigan DEQ 9949
Minnesota DOH 053-999-368
Montana DPHHS CERT0047
NevadaDEP WA35
New Jersey DEP WA005
New Mexico ED -
North Carolina DWQ 605
Oklahoma DEO 9801
Oregon -DHS WA200001
South Carolina DHEC 61002
Utah DOH COLU
Washington DOE C1203
Wisconsin DNR 998386840
Wyoming (EPA Region 8) -
l.liMIE~ i/=¼·:.
Will ·'¥'.'
10
• • COLUMBIA ANALYTICAL SERVICES, INC.
Client: Domtar Industries
Project: Domtar Analytical Support/5170.02
Sample Matrix: Solid
Prep Method: METHOD
Analysis Method: I 631 E
Test Notes:
Sample Name
FLLL-01
FLLL-06
FLLL-03
FLLL-04
FLLL-05
Method Blank I
Method Blank 2
Method Blank 3
J08007&4icp.dj I • S.mplc 0)/06108
Lab Code
J0800784-00 I
)0800784-002
)0800784-00)
)0800784-004
J0800784-005
10800784-MB I
J0800784-MB2
J0800784-MB3
Analytical Report
Mercury, Total
Dilution Date
MRL MDL Factor Extracted
1.0 0.2 40 03/05/08
1.0 0.2 40 03105/08
1.0 0.2 40 03105/08
1.0 0.2 40 03/05108
1.0 0.2 40 03/05/08
1.0 0.2 40 03/05/08
1.0 0.2 40 03/05/08
1.0 0.2 40 03/05/08
Service Request: J0800784
Date Collected: 02/06/08
Date Received: 02/15/08
Date
. Analyzed
03/06/08
03/06/08
03/06108
03/06/08
03/06108
03/06/08
03106108
03/06/08
Units: nf;1g
Basis: Ory
Result
54.4
62.2
48.6
50.6
62.8
0.3
ND
ND
11
Result
Notes
B
• •
Client:
Project:
Sample Matrix:
Sample Name:
Ulb Code:
Test Notes:
Analyte
Mercury
COLUMBIA ANALYTICAL SERVICES, INC.
QNQC Report
Domtar Industries
Domtar Analytical Support/5170.02
Solid
Batch QC
K0801014-001S,
Prep
Method
METHOD
Analysis
Method
1631E
Matrix Spike/Duplicate Matrix Spike Summary
Total Metals
K0801014-00ISD
Spike Level Sample Spike Result
MRL MS OMS Result MS OMS
1.0 95.9 92.4 31.6· 129 121
J0800784icp.djl -OMS 3/6/2008
Service Request: J0800784
Date Collected: NA
Date Received: NA
Date Extracted: 03/05/08
Date Analyzed: 03106/08
Units: ng/g
Basis: Dry
Percent Recovery
CAS Relative
Acceptance Percent
MS OMS Limits DIITerence
102 97 70-130 .5
Result
Notes
ooo 6
P~~ No.
12
Client:
Project:
LCS Matrix:
• • COLUMBIA ANALYTICAL SERVICES, INC.
QNQCReport
Domtar Industries Service Request: 10800784
Domtar Analytical Support/5170.02 Date Collected: NA
Date Received: NA
Date Extracted: NA
Date Analyzed: 03/06/08
Water
Ongoing Precision and Recovery (OPR) Sample Summary
Total Metals
Sample Name: Ongoing Precision and Recovery (Initial) Units: ng/g
Basis: NA
Test Notes:
CAS
Percent
Recovery
Prep Analysis True Percent Acceptance Result
Analyte Method Method Value Result Rccove'ry Limits Notes
Merc.ury METHOD 16JIE 5.00 5.86 117 70-130
J0S007&4icp.dj I • OPR {lc1w) 316/2008
13
Client:
Project:
LCS Matrix:
• • COLUMBIA ANAL YT.I CAL SERVICES, INC.
QNQC Report
Domtar Industries Service Request: /0800784
Domtar Analytical Support/5 I 70.02 Date Collected: NA
Date Received: NA
Date Extracted: NA
Date Analyzed: 03/06108
Water
Ongoing Precision and Recovery (OPR) Sample Summary
Total Metals
Sample Name: Ongoing Precision and Recovery (Final) Units: ng/g
Basis: NA
Test Notes:
Analyte
Mercury
J08007114icp.dj l -QPR (ksw) (2) 3/CJ/2008
Prep
Method
METHOD
Analysis
Method
1631E
True
Value
5.00
Percent
Result Recovery
5.59 112
CAS
Percent
Recovery
Acceptance
Limits
70-130
Result
Notes
000'. L,
Page No.;
14
• • COLUMBIA ANALYTICAL SERVICES, INC.
QA/QC Report
Client: Domtar Industries
Project:
LCS Matrix:
Domtar Analytical Support/5170.02
Water
Sample Name: Quality Control Sample
Test Notes:
Prep
Analyte Method
Mercury METHOD
J08007S4iep.djl -QCS (!CV) JJ6/l008
Quality Control Sample (QCS) Summary
Total Metals
Analysis True Percent
Method Value Result Recovery
163IE 5.00 5.25 105
Service Request:
Date Collected:
Date Received:
Date Extracted:
Date Analyzed:
Units:
Basis:
CAS
Percent
Recovery
Acceptance
Limits
70-130
10800784
NA
NA
03/05/08
03/06/08
ng/g
NA
Result
Notes
15
l'rojt-rl 1'\'amc: Amir:11~·;d Suppurt
l'rojl'rl Number:
l'rojrct 1\lanagcr: Diane I !.irdi:-.1111
Company: Domtar 1"';1pt,>1 l\m1p.:1ny. LLC
Lab Code Client S11111pll' ID
J08007S4-001 I FLLL-01
·-----------'
. J0S007&4-002 I FLLL-06
'
IOS;0:;;4-~03 -_ _/}:LLl.-03
J0800784-004 I FLLL-04
I -

-
. .I0S007S4-005 1 FLLL-05
# ofC0111.
I
\
l
I
I
Special lmtructio11s/Co1111n'kb:.£ AS£ .. S £-ND
R ,. ~ '! ! r '" r :1 ._ ., .1 ,_.. I ~ I ;.:
MANDY
Rdi1H-1uishc<l Hy:
Intra-Network Chain of Custody CAS ContJtT
:,:)c11~ !l:i~ ..:~·111,:r Rel_ • .!w.:k~um·ilk. l'I. .>225t, • QQ.J. 7J9-n.77 • F1\X 90--1-7JY-2r_, I I
Solid
S:unph' 0:itc
Date Tinn· lkccivl'tl Send To
I 02106;0~
: =+~:~~::::
1 02/06/08 •
I 02106,os
O',!Oil
09! 5
0920
09]0
02/ 15/08 K EL.SO
02/l5/0S KELSO
02/15/0S KELSO
02115/08 KELSO
02/15/08 KELSO
II
JI
II
II
II
-----; __ -----·
Turn,trounJ Hc11uircmen1s
__ HUSH (Surcharges Apply)
PLEASE CIRCLE WORK D_.\ YS
I 2 3 •1 5
ST..\ND:\RI)
Reqm:sted FAX Date: ____ _
Rcqrn:,;t,:J Ro.:port Oat~ 02/29tUS
Rqiurt Requirements
Results Only
It. Results+ QC Sumn1:11 ii:s
Ill. lksullS t QC and C.ilibratio11 Suu11naries
___ JV. Dnia V:1lidatio11 Report with R.iw Oat.i
Pt)UMOUJ
EDD
_y_
_li_
Airbill Numh..:r.
.:., .....
C>
0
0
)11\"oicc l11form:,1iu11
PO#
!0800784
13ill 10
\D ,.....,
•
•
• Columbia Analytical Services, Inc. • PC ,JoM)l)_,.
Cooler Receipt and Preservation Form
. Client I Project: (!4c;/u/Jy
Received: J~ N~o g i
Service Re uestffl_._ue.__::_O__:i...::.0-=.D__.1:__.8,_t/,__ __
I.
2.
3.
Samples were received via? US Mui/ Fed~ DHL GH GS PDX Courier Hand Delivered
Samples were received in: (circle) ~ Box Envelope Other __________ +--
Were custody seals on coolers? NA (5) N If yes, how many and where? / ~ '
NA
4.
If present, were custody seals intact? CJ) N If present, w:rf they,signed and dated?
Is shipper's air-bill filed? Ifnot, record air-bill number: It Y6W oqs I gi/()(l{JJ.£1 s I NA y
5. Temperature of cooler(s) upon receipt ('C): -().
Temperature Blank ("C):
6. If applicable, list Chain of Custody Numbers:
7. Were custody papers properly filled out (ink, signed, etc.)? NA u)
N
N
N
8. Packing material used. Inserts Bubble Wrap Ge/Packs ~ Sleeves Other ___________ _
9. Did all bottles arrive in good condition (unbroken)? Indicate in the table below.
· I 0. Were all sample labels complete (i.e analysis, preservation, etc.)?
1 I. Did all sample labels and tags agree with custody papers? lndica/e in the table below
12. Were the correct types of bottles used for the tests indicated?
13. Were all of the preserved bottles received at lhe lab with the appropriate pH? Indicate in the table below
14. Were VOA vials and 163 l Mercury bottles checked for absence of air bubbles? Indicate in the table below.
15. Are CWA Microbiology samples received with >1/2 the 24hr. hold time remaining from collection?
I 6. Was Cl 2/Res negative?
NA
y
y
y
y
N
N
N
N
N
N
N
N
_,_._-,,, ,'
'.:irii~~-1}."::
Additional Notes, Discrepancies, & Reso/utfons: ______________________________ _
0
Par:e I of: 1 2
17
RWI'®
September 27, 2006
Mr. Randy Bryant
Remedial Project Manager
•
United States Environmental Protection Agency. Region IV
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3104
• 744 HcartlanJ Trail 53717-1934
P.O. Box 8923 53708-8923
,\ ladison, \X'I
Telephone: [phone]
b" 608-831-3334
www.rmtinc.com
Subject: Weyerhaeuser Company Site• State Road 1565, Martin County, North Carolina
Final Interim Remedial Action Report
Dear Mr: Bryant:
RMT, Inc. (RMT), on behalf of Weyerhaeuser Company (Weyerhaeuser), is submitting two copies of the Final
Interim Remedial Action Report for the Former Chlorine Plant. This report documents the remediation
construction activities that were completed at the site.
Note that one copy of the report has been submitted directly to Mr. Nile Testerman of the North Carolina
Department of Environment and Natural Resources (NC DENR).
If you have any questions regarding this report. please call me.
Sincerely.
RMT NoM Carolina. Inc.
;~
se
roJect anager
cc: Melody Sydow -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
Jim Bragg-Weyerhaeuser Company
John Gross -Weyerhaeuser Company
\ Nile Testerman -NC DENR ,
Kathy Huibregtse -RMT
I: I WJ'MSN \ l')T\00·05100\ 76 \ !.000510076-002.DOC
rar
September 8, 2006
Mr. Randy Bryant
Remedial Project Manager
•
United States Environmental Protection Agency, Region IV
North Site Management Branch
6 I Forsyth Street, SW
Atlanta, GA 30303-3104
Subject: Prcfinal Construction Inspection Report
Site Inspection/Punch List Items
Weyerhaeuser Company, Plymouth, North Carolina
Former Chlorine Plant Remedial Construction
Dear Mr. Bryant:
• 744 Heartland Trail 53717-1934
P.O. Box 8923 53708-8923
Madison, WI
Telephone: [phone]
Fox, 608-831-3334
www.rmtinc.com
On August 23, 2006, representatives from the United States Environmental Protection Agency (USEPA); the
North Carolina Department of Environment and Natural Resources (NC DENR); Weyerhaeuser Company;
EnSafe, lnc./Ops Contracting Services, L.L.C.; and RMT, Inc., met for a Pre-final Construction Inspection at the
Weyerhaeuser Company, Plymouth, North Carolina, Former Chlorine Plant (FCP) area. The panicipants in the
meeting concluded that the remedial actions were completed in substantial conformance with the design '
specifications and the Remedial Action Work Plan. During this inspection, three items were identified that
needed to be addressed before the remedial actions could be determined complete at the site. These "punch list''
items are as follows:
I. Installation of replacement monitoring well protective surface casings at select wells
2. Lining of the existing storm sewer trench within the barrier wall boundary
3. Minor pavement repair and grade change at the southern end of the existing storm sewer trench within the
barrier wall boundary
On August 24, the existing stom1 sewer trench was cleaned and coated with an epoxy sealant. On August 31,
2006, the monitoring wells were inspected and monitoring well protective casings were installed. On
August 31, 2006, the minor pavement repair at the southern end of the storm sewer trench was completed.
Photographs of each of these efforts are included in the attachment to this letter.
As this completes the remedial construction at the FCP, the working copy Interim Remedial Action Report will
be forwarded to you today. On behalf of Weyerhaeuser, if you have any questions, please call me.
Sincerely,
opher D. Krause
Senior Project Manager
cc: i Nile Testennan -_NCDENR -/'
Melody Sydow -Weyerhaeuser Company
Jim Bragg -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
John Gross -Weyerhaeuser Company
Joe Jackowski -Weyerhaeuser Company
Kathy Huibregtsc -RMT, Inc.
1:1 WPMSN\PJTI00-05 l 0017 5\00002\1.0005 l 0075-015.DOC
Storm Sewer Trench Coating, View I looking NE; Completed
on 8/24/06
View of two Monitoring Well Surface Casings and Pads;
Completed on 8/30/06
Storm Sewer Trench Coating, View 2 looking SW; Completed
on 8/24/06
View of Monitoring Well Surface Casings and Pads Installed
along Bulkhead, View looking W; Completed on 8/30/06
•
•
~_g-K~ .,r,s.,u ~~~~t:~~ - . ,,: / ~--, _._ -~ ~~.ir·~·-_-p ·. . ,-2-~m~
.. ~-,,.
Southern End of Storm Sewer Trench Pavement; Repair
Completed on 8/31/06
~~~~~~;. ·-'~ <~-
~
Southern End of Storm Sewer Trench Pavement; Repair
Completed on 8/31/06
•
•
:;;,,.""<' ... (lA ,_,,. • 744 Heartland Trail 53717-1934
P.O. Box 8923 53708-8923
Madison, WI
July 20, 2006
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region IV
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Subject: Weyerhaeuser Company, Plymouth North Carolina
Former Chlorine Plant Remedial Construction
Dear Mr. Bryant:
Telephone: [phone]
Faxo 608-831-3334
www.rmtinc.com
The purpose of this letter is to summarize our July 12, 2006, telephone discussion regarding the type of
pavement that will be installed for the final surface grading at the Weyerhaeuser Company (Weyerhaeuser)
Former Chlorine Plant (FCP) site in Plymouth, North Carolina. Because of the extensive area that will require
paving due to settling caused by the barrier wall installation, and the related costs, Weyerhaeuser proposes to
install an asphalt pavement cap at the FCP site. The USEPA-approved remedial design in the Remedial Action
Work Plan specified that concrete would be placed in areas where pavement was removed to accommodate the
installation of the barrier wall.
As we discussed, asphalt was originally considered and targeted for the surface cap, but since the design called
for a relatively narrow pavement cut and replacement along the barrier wall route, concrete would be more
conducive to doweling into the existing neighboring pavement. Because of the extent of pavement now
requiring replacement as a result of surface damage during the remedy implementation, this advantage is no
longer as relevant. Additionally, asphalt is more conducive to contrnlling sloping and obtaining the targeted
grades, which would allow for more effective sUJface drainage and the elimination of two of the three barrier
wall penetrations for subsurface storm water lines.
Although concrete pavement is typically considered better for bearing traffic loads and having lower associated
maintenance requirements, the asphalt surface will be constructed consistent with North Carolina Department of
Transpo1tation standards, and will be adequate for the specific traffic loading realized in the FCP area. Also,
as part of the operation and maintenance of the installed remedial action, the pavement cap will be regularly
inspected as presented in the October 2005 Performance Standards Verification and Operation and Maintenance
(PSV/OM) Plan.
As presented in the PSV/OM Plan, any significant surface cracks, holes, depressions, or other signs of
degradation of surface integrity that could decrease the ability of the cap to effectively protect the groundwater
quality will be documented, and surface repair activities will be evaluated. Cracks and/or holes in asphalt
surfaces can be remedied using conventional repair techniques, such as filling with sealant and/or removing
damaged portions and replacing with new.
I:\ Wf'MSN \ PJT\00-05)00\75\00002 \ LCXJ0510075{)12.DOC
•
Mr. Randy Bryant
United States Environmental Protection Agency, Region fY
July 20, 2006
Page 2
•
Please approve asphalt for use in the final surface grading at the FCP area. As you are aware, the contractor is
currently preparing the site for paving, so your decision regarding this proposed change is needed as soon as
possible to avoid construction delays. Sub-base grading and pavement preparation activities are scheduled to be
completed during the week of July 24, 2006.
If you have any questions, please call me.
Sincerely,
RMT North Carolina, Inc.
Kristopher D. Krause
Senior Project Manager
cc: Melody Sydow -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
John Gross -Weyerhaeuser Company
Nile Testerman -NCDENR
Kathy Hui bregtse -RMT, Inc.
J, \ Wl'MSN\ PJT\00-05100\ 75\00002 \ L000510075-0l2. DOC
Approval By.
Mr. Randy Bryant Date
•
Letter of Transmittal
RMT, Inc.
30 Patewood Drive, Suite 100
Greenville, SC 29615-3535
Tel. [phone] • Fax [phone]
To: Mr. Randy Bryant
Remedial Project Manager
Waste Management Division
United States EPA, Region 4
61 Forsyth Street, SW, 11th Floor
Atlanta, GA 30303-3104
Prepared By: Mike Parker
Date:
Project No.:
Subject:
•
6/19/06
00-05119.09
Replacement Pages
Please find enclosed 3 sets of replacement pages (entire text) for the Interim Remedial Action report for
Operable Unit #1 (Former Landfill No. 1 Area), Weyerhaeuser Company, Plymouth, North Carolina.
The document has been revised in response to United States Environmental Protection Agency (USEPA)
comments contained in your e-mail of March 27, 2006.
As you are aware, Weyerhaeuser Company and US EPA are working with North Carolina Department
of Environment, and Natural Resources (NC DENR) to resolve the issues related to the deed restriction
requirements. This information and related drawings, if needed, etc. will be forwarded to US EPA when
completed.
Please call Bill Morris at 252-793-8494, or me at 864-234-9462, if you have any questions or comments.
I:\ Wl'C.VJ .\ l'n'\0{H)51 t.5\ll9\M00051 L509-00'1.1:XX: 6/19/!)6 l'llANSLTIU)OC FORM 1;334 (04n4ftJI)
May 31, 2006
lntegmtA
Envirrin-ta I
Solutions
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region IV
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Subject: Weyerhaeuser Company, Plymouth North Carolina
Former Chlorine Plant Remedial Construction
Dear Mr. Bryant:
744 Heartland Trnil 53717-1934
I'.O. Box 8~23 53708-8923
Madison, WI
Telephone: [phone]
Fax: [phone]
www.rmtinc.com
Please recall that during your May 1, 2006 site visit to Weyerhaeuser's Former Chlorine Plant in Plymouth, NC,
you approved a realignment of the south barrier wall to a position approximately 4 feet north of the location
presented in the Remedial Design. As requested, this letter presents a summary of the mercury mass
calculations used to estimate the mass of mercury in the soil that will be left in place (22 pounds) as a result of
this wall realignment.
South Barrier Wall Alignment
As presented in the May 15, 2006 letter to the USEPA, the Remedial Design specified that the south barrier wall
of the containment system be installed just north of the existing fire line. Prior to commencing construction,
RMT marked the barrier wall location. The southwestern corner of the fire line was marked approximately 4
feet from the fire line, and the southeastern corner of the barrier wall was marked approximately 6.5 feet from
the (ire line. As communicated in our May 15, 2006, letter, we had concerns that settlement of soil during the
barrier wall installation could breach the integrity of the fire line.· RMT had calculated that, by moving the
barrier line approximately 4 feet to the north, approximately 22 pounds of mercury would remain outside the
barrier wall. For perspective, approximately 7,200 pounds of mercury are estimated to be contained by the
barrier wall. After discussion, it was determined that moving the south barrier wall approximately 4 feet to the
north was acceptable to the EPA.
Mercurv Mass Estimation
The USEPA requested the submittal of the calculations suppo1ting the conclusion that approximately 22 pounds
of mercury will now be outside the barrier wall by moving the south wall approximately 4 feet to the noith.
The estimate was calculated using data, assumptions, and methodology consistent with previous mass estimate
calculations, namely calculating soil volumes within mercury concentration contour "zones" and applying
assumed average mercury qmcentrations to determine mercury mass estimates for each "zone." Analytical data
(mercury concentration contour map) used for the mercury mass calculati_on were taken from "Map A," which
was presented originally as part of Figure 5-1, A-C in the June 2000 Final Remedial Investigation Report. The
approximately 4-foot wide area between the RD wall alignment and the revised wall alignment was subdivided
into nine of these concentration zones, as presented on the attached figure. Assumed average depths (10 feet)
and average concentrations (assumed average 2 mg/kg concentration within the 0 -10 mg/kg zones, 20 mg/kg
concentration within the 10-100 mg/kg zones, and 200 mg/kg within the 100 + mg/kg zone) associated with
the zones arc also presented in the calculation table on this figure, along with the respective calculated volumes
and mercury mass estimation for each zone. As the attached (igure shows, the highest percentage (73 percent of
the tqtal mass estimate) of the estimated mercury mass is associated with the higher concentration Zone A.
l: \ Wl'MSN\ PJT\00-05100\ 75\00002 \ L000510075-006.DOC
PA
. , •
Mr. Randy Bryant
United States Environmental Protection Agency, Region TV
May 31, 2006
Page 2
•
If you have any questions, please do not hesitate to call me at 608-662-5 l 78.
Sincerely,
~l rt
. rause
Ject Manager
Attachments: Figure l (Mercury Mass Estimation Drawing and Calculation Table)
cc: Melody Sydow -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
John Gross -Weyerhaeuser Company
'Nile Testerman -NCDENR
'Kathy Huibregtse -RMT
I:\ W!'MSN \l'JT\00-05100\75 \00002 \ L000510075-006.DOC
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1.
NO. BY DATE REVISION
PROJECT: WEYERHAEUSER CO.
FINAL REMEDIATION INVESTIGATION
MARTIN COUNTY, NORTH CAROLINA
SHEET TITLE: MERCURY CONCENTRATIONS
IN SURFACE AND SUBSURFACE SOIL
APP'□.
DRAWN BY: MEYERHOC SCALE:
CHECKED BY; . 1" - 1 O'
PROJ. NO. 05100.23
FILE NO. 5100231 OODWG.DWG
APPROVED BY; DATE PRINTED:
DATE: NOVEMBER 2004 FIGURE 1
744 Heartland r,-oil
Madison, WJ 53717-1934
P.O. Box 8923 53108-8923
Phone: [phone]
Fax: [phone]
,. RMT. lntegri.
Enviro ,ntal
Solutions
May 15, 2006
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency. Region IV
North Site Management Branch
6 I Forsyth Street, SW
Atlanta. GA 30303-3104
Subject: Weyerhaeuser Company, Plymouth NC
Former Chlorine Plant Remedial Construction
Dear Mr. Bryant:
• ~
744 !·leanlandiail 53717-1934
P.O. Box 8923 53708-8923
ivtadison, WI
Telephone: [phone]
Fax: [phone]
www.rmtinc.com
The purpose of this letter is to summarize the discussions we had during our Former Chlorine Plant construction
meeting at the Weyerhaeuser Plymouth site on May I, 2006. Attendees at the meeting included yourself, Bill
Manis of Weyerhaeuser Company (Weyerhaeuser); Nile Testcrmann of the North Carolina Department of
Environment and Natural Resources (NC DENR); and Travis Tarbet and Kris Krause of RMT North Carolina.
Inc. (RMT). A summary of the items discussed follows below.
Target Area 2a
\Vhile removing surface concrete to prepare for excavating soil from Target Area 2a, significant concrete was
found in this area. The concrete removal began on the western side of the excavation area. Concrete was
removed until over 3 feet of concrete were observed. As a result of this finding, the concrete was dri lied across
the entire excavation area to evaluate its thickness and determine if the planned 4-foot excavation depth for this
area could be achieved. Attached is Figure I, which summarizes the findings. In general, approximately two
thirds of the area (one third on each end) contains over 16 inches of concrete. The middle third of the area
contains approximately 12 inches. Upon discussing our findings with you, it was determined that removal of the
significant mass of concrete was not necessary. We would attempt to remove the middle third of the target
excavation area in which only 12 inches of concrete were found.
Target Area 2b
During our construction meeting, the contractor began excavating Target Area 2b. While excavating, a concrete
foundation was discovered that appeared to have formerly heen a foundation for an aboveground storage tank.
After uncovering the extent of the foundation, and reviewing its location relative to the planned Target Area 2b
area, it was determined that it would be appropriate to remove only the soil that was contained within the concrete
foundation. Attached is a sketch of the foundation. While excavating the soil from inside the foundation, one of
the tiebacks for the bulkhead was found to be anchored to this foundation. RMT will include these findings and
modifications to the excavation area in the remediation documentation report.
South Barrier Wall Alignment
The remedial design specified that the south barrier wall of the containment system be installed just north of the
existing fire line. Prior to commencing construction, RMT marked the barrier wall locations. The southwestern
corner of the fire line is approximately 4 feet from the fire line, and the southeastern corner of the barrier wall is
approximately 6.5 feet from the fire line. While installing the banier wall along the northern boundary, we
observed significant settlement within approximately 8 to JO feet of the installed baJTier wall. We have
concerns that, should similar settlement occur along the southern wall during wall installation, the underground
firewater line could potentially be damaged. Therefore. during our site visit, we reviewed the areas of
settlement and proposed that the south barrier wall be moved approximately 50 inches to the north. This would
I:\ Wl'MSN \PJT\00-05100\ 75\00002 \ L000510075-004.DOC
•
Mr. Randy Bryant
United States Environmental Protection Agency, Region TV
May 15, 2006
Page 2
•
create a minimum separation of 8 feet from the south barrier wall to the fire line and minimize the potential of
impacting the fire line. RMT calculated that approximately 22 pounds of mercury in the 50-inch-wide volume
of soil would now be outside the ba1Tier wall. For perspective, approximately 7,200 pounds of mercury are
estimated to be contained by the barrier wall. After discussion, it was determined that moving the south barrier
wall 50 inches to the north was acceptable.
Target Area lb
On March 24, 2006, RMT submitted a leller to the USEPA that summarized the findings of excavating to install
the structural sheetpile to perform target excavation I. ln that letter, RMT requested, and the USEPA
subsequently approved, modifying the limits of target excavation 1. The modified excavation was renamed
Target Area la. The excavation area located where the former U-drain discharged to the river was named
Target Area I b. In our March 24, 2006 letter, we committed to further evaluating this area.
During your May 1 site visit, we reviewed the area in which the former U-drain was located. This area is
covered with concrete, and it is difficult to ascertain whether the former U-drain pipe can be removed without
significant difficulties. In addition, it is unknown how the pipe and concrete interface with the bulkhead, so
removal of the pipe and concrete could damage the bulkhead. II was concluded that we would excavate on the
western and southern sides of the concrete with the miniexcavator. This work would be conducted after Target
Area 2b was completed, at which time the feasibility of removing the pipe and underlying soil would be
evaluated. We further concluded that, if concrete around the pipe were significant enough lo preclude the
removal of soil, no further soil excavation would be performed.
The contractor has performed this excavation, and RMT has viewed the area. Al this lime, it appears that the
concrete on lop of the pipe can be removed. However, we cannot determine the extent of the concrete beneath
and around the pipe until the concrete on top of the pipe has been removed. The contractor will remove the
concrete above the pipe after the Target Area la excavation has been completed, at which time we will further
evaluate the feasibility of removing the pipe and any soil in the immediate vicinity of the pipe. We will contact
you to discuss this further after the concrete has been removed and the evaluation has been completed.
Please review the information contained in this Jeuer and, confirm that we are in agreement on the future
direction for lhe various areas. ln the meantime, if you have any questions, please call me.
Sincerely,
RMT .North ,arzli · Inc. , ,-4~ / z::,---~
K,J;nftopher D:Krause ---
Senior Project Manager
Attachments: Figure 1
Sketch of Foundation
cc: Melody Sydow -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
John Gross -Weyerl,aeuser Company
, Nile Testerman -NCDENR
'Kathy Huibregtse -RMT
1: \ Wl'MSN \l')T\00·05Hl0\75\00J02 \ L000510075--004.DOC
COOLING TOWER
NOTES
/ PIPE RACK FOOTING
□ ffi CP-08-1 8 DP-11
CP-08-2
ffi
END OF REMOVED
CONCRETE
0 (16+) 0 (16+)
TARGET AREA 2a EXCAVATION LIMITS
1. DIMENSIONS OF TARGET AREA 2a EXCAVATION 10'X55'
2. DIMENSION OF CORE LOCATION DISTANCE IS FROM EAST
WALL OF TARGET AREA 2a
8 (16+)
STORM DRAIN
SYSTEM
It (12)
ALLEY
e DP-10
0 (12)
9 (12) $ (12)
• (12)
OLD CONCRETE
MOTOR CONTROL CENTER
rrPIPE RACK FOOTING
0 DP-12 d PIPE RACK FOOTING /
/
0 (10)
0 (12)
/
/
/
r16•l 0 (16+)
I
9 (16+)
I
I
I
J
PROJECT:
SHEET TITLE:
0
L J
SCALE: 1 "= 5'
WEYERHAEUSER COMPANY
FORMER CHLORINE PLANT
PLYMOUTH, NORTH CAROLINA
AREA 2a CORE LOCATIONS
DRAWN BY: FIEBRANT SCALE: PROJ. NO.
CHECKED BY: BJ 1"=5" FILE NO.
10
j
05100.74
51007404.DWG
APPROVED BY: KK DATE PRINTED:
DATE: MAY 2006 MA y 1 FIGURE 1
• ~ 3. (12) IS MEASURED THICKNESS OF CONCRETE
;
§ ~ 7-U Heartland Trail z Madison, WI 53717-1934
.!r.;
0
~ P.O. Box 8923 53708-8923
!I:: ... _ 411!!!,!.. Phon~: 608-831-,f.,#..f.,f 5~~._ _______________________________________________________________ .J_ ____ • ________ F~~--·608..:..-=~~1-~~=~...., __ _J
• •
lilWl: C:rcc-nvil!e • :1n hti:wood l)t•i;~., Snitt: 100 • (..'r;.onl'ilk, SC 29615·•:tt).5 5HY,,:r __ /_ 0r __j_
-------,--,-,---=
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~~J'·':" li.ev\,ecd Te.c5-u Ace• '2. B --~-
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RM(
March I 6, 2006
Mr. Randy Bryant
lnteg,A
Envin-ntal
Solutions
Remedial Project Manager
Waste Management Division
USEPA Region IV
61 Forsyth Street, SW
Atlanta, GA 30303-3 I 04
Subject: Weyerhaeuser Company, Former Chlorine Plant
Analytical Testing Laboratory Approval Request
Dear Mr. Bryant:
• 74'1 Hcnrtl::md Trail 53717-1934
P.O. Box 8923 53708-8923
Madison, WI
Telephone: 608-83"1-4444
Fax: [phone]
www.rmtinc.com
As you are aware, Weyerhaeuser Analytical and Testing Services (WATS) is the approved analytical testing
laboratory for testing associated with the Remedial Action for the Fonner Chlorine Plant (FCP) area at the
Weyerhaeuser Company, Plymouth, No1th Carolina, facility. The majority of the analytical services for the
aforementioned project will be completed by WATS; however, RMT, Inc. (RMT), on behalf of Weyerhaeuser
Company (Weyerhaeuser) would like to request USEPA's approval of Environment I, Inc., located in
Greenville, North Carolina, as an alternate analytical testing laboratory. We are requesting this approval for
circumstances when quick-turn (next-day) services are necessary. This will allow Weyerhaeuser to keep the
project moving forward and will limit the potential for construction delays.
lf this request is acceptable, please sign in the space provided below and return a copy of this letter to us. We
appreciate the USEPA's evaluation and approval of Environment I, Inc., as an alternate analytical testing
laboratory for the FCP Remedial Action.
If you have any questions, please contact me, at [phone].
Sincerely,
RMT North Carolina, Inc.
Kri topher D. Krause
Senior Project Manager
cc: Melody Sydow -Weyerhaeuser Company
Jim Bragg -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
John Gross -Weyerhaeuser Company
Nile Testerman_: NC DENR, Raleigh
--- -·-I -Kathryn Huibregtse, RMT, Inc
J, \ WPMSN\l'JT\00-05100\74 \ LOOOS10074-0D4.DOC
Approval By
Mr. Randy Bryant
Remedial Project Manager
Date
• •
Letter of Transmittal
RMT North Carolina, Inc.
30 Patewood Drive, Suite 100
Greenville, SC 29615-3535
Tel. [phone] • Fax [phone]
To: Randy Bryant
Remedial Project Manager
United States Environmental Protection
Agency, Region 4
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
Prepared By: Mike Parker, P.E.
Randy:
Date: 3/14/06
Project No.: 00-05115.09 .
Subject: Final Construction--"As Built"
Drawing for the Interim RA Report
(Weyerhaeuser Paper Company,
Plymouth, NC)
The Interim Remedial Action (RA) Report for Weyerhaeuser Paper Company, Plymouth, North Carolina
was sent to you and others on the distribution list on February 10, 2006 to fulfill the requirements for the
OU-1 Remedial Design/Remedial Action (RD/RA) Consent Decree, Civil Action No. 4:03-CV-90-H(3).
lodged on June 6, 2003. The final surveyed elevations or "as-built" drawing-Figure 5-Landfill Cover
Thickness, was not included in the report as problems were encountered getting the survey data in a
usable electronic format.
Per this transmittal, please find enclosed three copies of the above referenced drawing for insertion into·
the Interim RA Report. We apologize for any inconvenience this may have caused. If you have any
questions or comments, please contact Bill Morris of Weyerhaeuser Company at 252-793-8494 or me at
864-234-9462.
Best regards,
RMT, Inc.
~£.~
Michael B. Parker, P.E.
Senior Project Manager
Cc: (Mr.:Nile-Testerfifah;:NCDENR,
Mr. John Gross, Weyerhaeuser Company
Mr. Bill Morris, Weyerhaeuser Company
Ms Kathy Huibregtse, RMT, Inc
Heather Smith, RMT, Inc.
Central Files
I:\ WPGVL \PJT\00-05115\09\MCXXJ511509-0'.18.DOC 3/14/06 TRANSLTROOC FORM F334 (04/24/01)
RM'1. Integ. ,
Envin ental
Solutions
March 8, 2006
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency
North Site Management Branch
Atlanta, GA 30303-3104
Suhject: Weyerhaeuser Company, Former Chlorine Plant
Hazardous Waste Disposal Facility Options
Dear Mr. Bryant:
• 744 Heartland Trail 53717-1934
P.O. Box 8923 53708-8923
Madison, WI
Telephone: [phone]
Fax: [phone]
www.rmtinc.com
Weyerhaeuser has identified off-site hazardous waste disposal facilities for the potential generation of RCRA
hazardous waste during the Former Chlorine Plant remedial action implementation activities. As discussed at
the February 8, 2006, Preconstruction Meeting, and as presented in the May 2005 Remedial Action Workplan,
should the characterization of excavated soil indicate hazardous levels of mercury, this soil will be transported
to and disposed at an EPA-approved RCRA hazardous waste TSDF facility.
Although hazardous levels of mercury arc not expected to be found in the excavated material, two disposal
facilities have been identified for RCRA hazardous waste disposal: Waste Management in Emelle, Alabama,
and the Environmental Quality Company's Wayne Disposal Facility in Belleville, Michigan.
If you have any questions or concerns regarding these facilities, please contact me at [phone].
Sincerely,
RMT North Carolina, Inc. ~*for
Kristopher Krause
Senior Project Manager
cc: Melody Sydow -Weyerhaeuser Company
Jim Bragg -Weyerhaeuser Company
Bill Morris, Weyerhaeuser Company-Plymouth, North Carolina
John Gross, Weyerhaeuser Company-Federal Way, Washington
Nile Testerman -NC DENR, Raleigh, North Carolina
Kathryn Huibregtse, RMT, Inc. -Milwaukee, Wisconsin
!: \ WPMSN \ PJT\00-05100\ 74 \ l.000510074-003.DOC
,,
• Integrated
March 8, 2006
Environmental
Solutions
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency
North Site Management Branch
Atlanta, GA 30303-3104
Subject: Weyerhaeuser Company, Former Chlorine Plant
•
!'reconstruction Investigation Results -Target Excavation Area 2a
Dear Mr. Bryant:
7,14 1-lc:irtlnnd Trail 53717-!934
P.O. Box 8923 53708-8923
Mndison, \\IJ
Telephone: [phone]
Fax: [phone]
www.rnninc.oim
On January 26, and February 8, 2006, the !'reconstruction Investigation was completed at the Weyerhaeuser
Former Chlorine Plant (FCP) area located in Plymouth, North Carolina in substantial conformance with the
USEPA-approved !'reconstruction Investigation Work plan, dated November 3, 2005. The objectives of this
investigation were to determine soil mercury concentrations north of the Target Excavation Area 2a extent
presented in the May 2005 Remedial Action (RA) Workplan and to determine the practicable extent of soil
excavation for Target Excavation Arca 2a.
Five samples in two separate locations were collected between the cooling towers and the motor control center
as shown on Figure l. Weyerhaeuser prepared these sampling locations by coring through 8 inches of concrete
prior to the soil sampling event. A hand auger was used to collect the soil samples at these locations. Sampling
depths in both borings were located generally between 2-4 feet and 4-6 feet below the ground surface.
Stainless-steel sco_ops and bowls were used to composite soil samples from these discrete depth intervals. Field
observations were noted regarding the physical characteristics of the soil that were consistent with previous field
observations.
On January 26, 2006, soil samples from boring SB-01 were collected between 2-4 feet and 4-5.5 feet below the
ground surface. Soil boring SB-01 was terminated at 5.5 feet due to refusal. Auger refusal at approximately I
foot below the ground surface was encountered at SB-02, therefore, soil samples could not be obtained from the
original boring SB-02 location. This boring location was moved approximately 4 feet no11h and 0.5 foot west of
the original location. On February 8, soil samples from relocated boring SB-02 were collected between 2-4 feet
and 4-5.25 feet below the ground surface. Again, the desired sample depth of 6 feet below the ground surface
could not be reached due to refusal. In addition, a duplicate sample was taken from boring SB-02.
Soil samples were appropriately labeled, packaged, and sent to Weyerhaeuser Analytical and Testing Services
(WATS) for total mercury analysis. Analytical results, along with Chain-of-Custody Records, are contained in
Attachment I. A summary of the analytical results is provided in Table l. Analytical results indicate that the
composite samples analyzed were either below or just slightly above (in one instance) the Remedial Goal
Objective (RGO) indicated in the ROD of 20 mg/kg. Analytic~( results indicate that the total mercury
concentration of the composite sample taken at the interval 2 to 4 feet below the ground surface at boring SB-0 I
was 20.8 mg/kg.
I:\ Wl'MSN \ l'JT\00--05100\ 74 \ UXXJ510074.002.00C
•
Mr. Randy Bryant
United States Environmental Protection Agency
March 8, 2006
Page 2
•
As indicated in the Preconstruction Workplan, many site constraints, including proximity to the cooling towers,
motor control center, subsurface foundations, and underlying/overhead utilities, exist in the vicinity of Target
Excavation Area 2a. Based on the numerous site constraints and the results of the analytical data confirming
results below or just slightly above 20 mg/kg between the cooling tower and motor control center, the previously
defined extent of the Target Excavation Area 2a is appropriate.
We appreciate your review of this information, and Weyerhaeuser requests your approval of the excavation
limits as provided in the May 2005 RA Workplan.
If you have any questions, please contact me at (608) 662-5 I 78.
Sincerely,
RMT North Carolina, Inc.
p.:_~~o<
Kristopher Krause
Senior Project Manager
Attachments
cc: Melody Sydow -Weyerhaeuser Company
Jim Bragg -Weyerhaeuser Company
Bill Morris, Weyerhaeuser Company-Plymouth, NC
John Gross, Weyerhaeuser Company-Federal Way, WA
, .. Nile Testerman-:... NC DENR, Raleigh, NC
' -KathrynHuibregtse, RMT, Inc. -Milwaukee, WI
!: \ Wl'MSN \ PJT\ ll0-05100 \ 74 \ 1.000510074-002. DOC
•
Table 1
Total Mercury Summary
Weyerhaeuser Company
•
Former Chlorine Plant -Plymouth, North Carolina
SB-01 2-4
4-5.5
SB-02 2-4
4-4.25
SB -02 Duplicate 2-4
l:\ WJ'MSN\ l'JT\00-05100\74 \ Tl)()()5JOIJ74--00\.DOC 03/06/06
20.8
9.4
8.1
4.6
12.1
I ' LEGEND
I/ /I
COOLING TOWER
MOTOR CONTROL CENTER
e S8-01
WATER PIPES
SCPSB-15
8 SB-02
[121 mg/Kg. 2'-41
® CP-011-1
@ SB-11C
S DP-12
(49.8 mg/Kg. 41
S DP-7
\
0
LIMITS OF TARGET EXCAVATION
AREA 2A AS PRESENTED IN
THE MAY 2005 RA WORKPLAN
OVERHEAD PROCESS PIPING
PIPE CHASE SUPPORT FOOTER
PRECONSTRUCTION SOIL BORING
LOCATION
SHALLOW SOIL BORING
LOCATION
GROUNDWATER MONITORING
WELL LOCATION
PREDESIGN GEOTECHNICAL
BORINGS
PREDESIGN DIRECT PUSH
LOCATION
MAXIMUM MERCURY
CONCENTRATION DETECTED IN
TOP 10 FEET, AND DEPTH
DETECTED
10 20
SCALE: 1"=10'
51007403.DWG
FIGURE 1
•
I:\ WPMSN \PJT\00-05100\ 74 \ LOO'JS10074-002.0CX:
•
Attachment I
Analytical Laboratory Results
•
Analysis & Testing Services
A Weyerhaeuser
The future is growing"'
March I, 2006
RMT
c/o Heather Smith
Patewood Plaza One, Suite 100
30 Patewood Drive
Greenville, SC 29615-3535 ·
Dear Heather:
•
P.O. Box 9777, WTC 2F25
Federal Way, WA 98063
3290! Weyerhaeuser Way South
Federal Way, WA 98001
Tel 253 924~6872
Fax [phone]
Enclosed are the test results for the samples that you requested we analyze for you. This work has
been performed under our Service Request No. 06-0329.
If you have technical questions regarding these result_s, please contact me at 253 924-6242. This
work is being charged to Weyerhaeuser internally and will result in no billing to RMT.
Thank you for the opportunity to be of service to your organization. I hope we can be of assistance
in the future.
Sincerely,
0~
Dennis _Catalano, Operations.Manager
Analytical Chemistry Laboratories
Weyerhaeuser Analytical & Testing Services
Enclosure
cc: Mike Parker RMT
H :\ADMIN\ADMI NICV RL TR\rml-smilh .doc
• •
A Research and Development -Analysis and Testing
Service Request
Weyerhaeuser 06-0329
I Title: Plymouth Soil/Ground Water/Leaf Litter
Samples: 46 Tests: 5 Last Samp: 046 Project Number: 708-8771 PO:
Date Received: 01130106 Date Desired: 02115106 Date Completed:
Submitter: Smith, Heather Location: Greenville, SC Phone: [phone]
Reviewer: Catalano, Dennis Location: WTC 2F25 Phone: [phone]
Copy To: Mike Parker
Record Book: Ref Request: 05-3265 Disposal:
Comments: See Dennis with questions. Sent samples 040-046 to CAS on 1/31/06.
Revisions:1130 -removed 3-IF-S3050 on samples 038 and 039 perDMC (cng).
Group Analysis Test Description Comp List Component List Description
ADMIN 0-OUTSIDE
METALS 3-HG-S
METALS 3-HG-W
METALS HG
METALS SL-OD-3
Test Schedules being used:
Sample ID -Date Sampled
Customer Sample Description/ ID
06-0329-001 -01/24/06 1020 -
CP-12-2
06-0329-002 -01/24/06 1055 -
CP-12-1
06-0329-003 -01124/06 1130
CP-11-2
06-0329-004 -
DU-06101
Form AT100
VERSION 25April2002
-
-
Charge for Outside Testing
AM1-245.5 Mercury Prep -Solid/Soil
AM1-245.1 Mercury Prep -Water
Mercury
AM1-TS-CLP Solids -105C in Solid
Matrix
-
3-HG-S
3-HG-W
Status
Completed
Completed
Completed
Completed
;;
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w w C, ·a; in z. I-m ::,
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Printed on: 03/01/06 1528
Data Retrieved: 03/01 /06 1528
M o o· -' "'
1
SOLID
WATER
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Total Mercury in a Solid
Total Mercury in Water
Entered by: Downs, Kelly
Entered on: 01130106 1041
A
• •
Research and Development -Analysis and Testing
Service Request
Weyerhaeuser 06-0329
I Title: Plymouth Soil/Ground Water/Leaf Litter
06-0329-005 . .
TBLK-06101
06-0329-006 -01/24/06 1220 .
CP-11-1
06-0329-007 . 01/24/061350 .
CP-3-1
06-0329-008 . 01/24/06 1225 -
FBLK-06101
06-0329-009 . 01 /24/06 1440 -
CP-3-3
06-0329-010 . 01/24/06 1510 -
cp.3,2
06-0329-011 . 01/24/06 1540
CP-01-3
06-0329-012 -01/24/061610
CP-01-2
06-0329-013 . 01 /24/06 1700
MW-18 ·
06-0329-014 .
DU-06102
06-0329-015 . 01/24/061710
FBLK-06102
06-0329-016 . 01/24/06 1730
CP-9-1
06-0329-017 . 01/24/06 1800
CP-9-2
06-0329-018 . 01/24/06 1820
CP-10-1
Form AT100
VERSION 25April2002
.
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Printed on: 03/01/06 1528
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Entered by: Downs, Kelly
Entered on: 01 /30/06 1041
.
• •
A Research and Development -Analysis and Testing
· Service Request
Weyerhaeuser
I Title: Plymouth Soil/Ground Water/Leaf Litter
06-0329-019 -01 /24/06 1840 -
CP-10-2
06-0329-020 -01/25/06 0915 -
CP-08-2
06-0329-021 -01/25/06 0940 -
CP-08-1
06-0329-022 -01/25/06 1020
CP-07-2
06-0329-023 -01/25/06 1040
CP-07-1
06-0329-024 -01 /25/06 1100
MW-2-2
06-0329-025 -01/25/061145
MW-2
06-0329-026 -01/25/06 0000
DU-06103
06-0329-027 -01/25/06 1155
FBLK-06103
06-0329-028 -01 /25/06 1420
CP-02-1
06-0329-029 -01/25/06 1445
CP-02-2
06-0329-030 -01/25/061500
CP-04-3
06-0329-031 -01 /25/06 1520
CP-04-2
06-0329-032 -01 /25/06 1540
CP-04-1
Form AT100
VERSION 25April2002
-
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Printed on: 03/01/06 1528
Data Retrieved: 03/01 /06 1528
0 ::,
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06-0329
Entered by: Downs, Kelly
Entered on: 01/30/06 1041
• •
A
Weyerhaeuser
Research and Development -Analysis and Testing
Service Request
06-0329
I Title: Plymouth Soil/Ground Water/Leaf Litter
06-0329-033 -01 /25/06 1600
CP-05-1
06-0329-034 -01/25/06 1620
CP-05-2
06-0329-035 -01 /25/06 1645
CP-13-1
06-0329-036 -01/25/06 1715
CP-15-1
06-0329-037 -01 /25/06 17 40
CP-14-1
06-0329-038 -01 /26/06 0900
SB-01 (2-4')
06-0329-039 -01 /26/06 0915
SB-01 (4-5.5')
06-0329-040 -01/26/06 0745
FLLL-1
06-0329-041 -01/26/06 0800
F~LL-2
06-0329-042 -01 /26/06 0810
FLLL-3
06-0329-043 -01 /26/06 0815
FLLL-4
06-0329-044 -01 /26/06 0825
FLLL-5
06-0329-045 -01/26/06 0755
RBLK-06101
06-0329-046 -01/26/06 0750
RBLK-06102
Form AT100
VERSION 25Apri12002
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Printed on: 03/01/06 1528
Data Retrieved: 03/01/06 1528
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Entered by: Downs, Kelly
Entered on: 01/30/06 1041
•
Weyerhaeuser Analytical & Testing Services
32901 Weyerhaeuser Way South
Federal Way, WA 98001
•
Report
Date
Client ID Sampled
SB-01 (2-4') 01/26/06
SB-01 (4-5.5') 01/26/06
Approvf:!d: Dorothy Kerlin
Telephone: [phone]
Plymouth Soil/Ground Water/Leaf Litter
Time Lab Total Metals
Sampled ID Hg
mg/kg O.D. basis
0900 038 20.8
0915 039 9.4
QL: 0.1
Method Number: E-245
Date of Analysis : 02/15/06
Analyst: DJK
Date: 02/17/06
Service Request 06~0329
D.D. Solids
¾ @ 105°C, as-received basis
82.4
81.3
0.1
S-2540G
02/07/06
OJK
Weyerhaeuser Analytical Chemistry
c/o SLM 216
32901 Weyerhaeuser Way South
F d I W WA 98001 e era av,
Date Project ntle /3 a; :5 e,, ;; ,., e, I-Zt,-01, Pc.P
CHent'sRJ.iT / lt/e,~,
0 P I 11 rnowr~
Client's Address ' .
fpaoe L/ of I/ Account Number/Project Number
5'100,73
Client's Phone Number Client's FAX Number
Client's e-mail address
Project manager (print)
Kr~s kra-,1e.,
Sampler Name (print) , ); 'Trav'i's \,.,r e,<J/ Rec?~tu~
Sample Descriotion Matrix Preservation u Field Sample ID Date Time 'O 0 0
0 C
.c (15 character Max) (mm/dd/yy) (hh:mm) .!! sg 0 r5 0: w w u "!, ~ N :::; /Reauired) (Required) ~ ·a i5 z rn e U) :z: :z: :z: z u_ G rP n<: ? ,-i! 5'-6/, !6ZO X y X ,-, c_p_ . ...,. I I-Z,-6C. /J.,{J,;-X )( ;,( ,., rP ,,,._, /-2:t;'"~N I 7u---)< ,,,. X ,., rP-/1.J_ I I -., ,-_ ,-,/ 17'1" V V >< D <;R.-nl ('Z.-u1 ) 1-zt. of ll'?M -y V X fl cR-,_, fu-r ,;-• 1 l-?L6/'., I'> 'I I, . .)l, y ,x
' .____. "G"rab 'D"epth composite, or "T"ime composite
tuinaround time required Results to: ~art type ~ 24 hours -Electronic Report -48 hours Disk Deliverables --7 days cc: Other: "5! -NPDES/Requlatorv 2-3 weeks -due: I
return unused samples
'
'O .j
~ • ~ u
~ • .
I
I
I
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2
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Percent
ppm
ppb
ppt
f i
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Chain of Custody Record!
I ' Anal sis Requested write/t ne in parameter) Notes
~
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" ~
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X
V
y
)( x
)(
Estimated Concentration Range Report Basis
As Red.
OD
Volume
Wt.
IRS qualified R&D? Sample Chain of Custodv and ShlooinQ Method Record Remarks/Detection Limit Requirements Relinquished by Sampler (signature) Date Time Received by (Signature) /-~~ /-Zif 7l; 164::) ~~ /I Relinquished by (stgnature) Date Time Received by ~aboratory (SignaturR__
:\ \) 0 ~ .-+,,___ 1-21-ac 13:cn /ly~ffe t.'L Airbill Number CoolerT mp TJai ~"'J' ct Ti~,a~ed 65-"17 140~ 377-::, L Form 15307 (R 9/0JJ
'
i
! i
i ; • ' '
•
•
Analysis & Testing Services
A. Weyerhaeuser
The future is growing"'
February 17, 2006
RMT
c/o Heather Smith
Patewood Plaza One, Suite 100
30 Pate wood Ori vc
Greenville, SC 29615-3535'
Dear Heather:
•
P.O. Box 9777, WTC 2F25
Federal Way, WA 9B063
32901 Weyerhaeuser Way South
Federal Way, WA 98001
Tel [phone]
Fax [phone]
Enclosed are the test results for the samples that you requested we analyze for you. This work has
been performed under our Service Request No. 06-0473.
If you have technical questions regarding these results, please contact me at 253 924-6242. This
work is being charged to Weyerhaeuser internally and will result in no billing to RMT.
Thank you for the opportunity to be of service to your organization. I hope we can be of assistance
in the future.
Sincerely,
~-
Dennis Catalano, Operations Manager
Analytical Chemistry Laboratories
Weyerhaeuser Analytical & Testing Services
Enclosure
cc: Mike Parker RMT
H:\AOMIN\ADMlN\CVRL TRl•mH1mfth.doc
.
•• •
Research and Development -Analysis and Testing
Service Request
Weyerhaeuser
I Title: Plymouth Soil
Samples:2 Tests: 3 Last Samp: 002 Project Number: 708-8771
· Date Received: 02/10/06 Date Desired: 02/17/06
Submitter: Smith, Heather Location: Greenville, SC
Reviewer: Catalano, Dennis Location: WTC 2F25
Copy To: Mike Parker
Record Book: Ref Request:
Comments:
Group Analysis Test Description
METALS 3-HG-S AM1-245.5 Mercury Prep -
Solid/Soil
METALS HG Mercury
METALS SL-OD-3 AM1-TS-CLP Solids· 105C in
Solid Matrix
Test Schedules being used: 3-HG-5
• ::l
E • C 0 ~ □ E ~ 8 "'
w M ·a "' >-6 "' "' C/ ~ + ~ " '" "' :I:
Sample ID . Date Sampled Status
Customer Sample Description/ ID 1 1 1
06-0473-001 02108/06 1110 -Authorized 'A 'A' A
SB-02 (2-4')
06-0473-002 02108/06 1120
SB-02 (4-5.25')
Form AT100
VERSION 25Aprll2002
;.;!::. ~ :'.;-J tt'.': :.:t:.
Authorized Ji/ ~ w ~iI ~ t~•-:s:
Printed on: 02/17/06 1420
Data Retrieved: 02/17/06 1420
06-0473
PO:
Date Completed:
Phone: [phone]
Phone: [phone]
Dispose/:
Comp List Component List Description
SOLID Total Mercury in a Solid
Entered by: Downs, Kelly
Entered on: 02/10/06 1152
Weyertl11.euser Company, Corporale Research and Developmen\, Analysis & Testing --Intranet: http://www.weyer.com/at/
•
Weyerhaeuser Analytical & Testing Services
32901 Weyerhaeuser Way South
Federal Way, WA 98001
•
Report
Plymouth Soll
Date
Client ID Sam led
SB-02 (2·4") 02/08/06
Duplicate
SB-02 (4-5.25') 02/08/06
Approved: Dorothy Kerlin
Telephone: [phone]
Time Lab
Sampled ID
1110 001
001D
1120 002
QL:
Method Number:
Date of Analysis :
Analyst:
Date: 02/17/06
Total Metals
Hg
m /k O.D. basis
8. 1
12.1
4.6
0.1
E-245
02/15/06
DJK
Service Request 06-0473
O.D. Solids
% @ 105°C, as-received basis
83,2
82.8
81.6
0.1
S-2540G
02/13/06
DJK
CHAIN OF CUSTODY RECORD
76502
30 Patewood Drive, Suite 100, Patewood Plaza One, Greenville, SC 29615-3535 F;ltered (Ye,/No} ,N / / / / / / / /
Phone [phone] • fax [phone]
Preserved (Code] / .a. / / / / /" / / /
PrciectNo. I Projoct/dient: P 1., ,..,,, .. ,.l ,J>/
C:IOD.13 W~vc~
PRESERVID CODES
Proiect Monoger/Con,oct Pen.on: . ,J" A-NONE
-~ q,.iPi .. B-HN01
\<r ~5 Kr~use ( Kr ;5. kr~"se 6> f/'f\+~ ,-,c,c.o ,.-, 'I . -,., ,. C-H,SO•
JJ • E .S
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D-NoOH
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Date lime Sample Station ID
Commenh: G
•
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l-9. 1f7n
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SPEOAL INSTRUCTIONS
•
SAMPlfR Reli"'l"i~;re) Date/Time Received by (Sir;tvn,) Date/Time HAZARDS ASSOCIATED Tum Around (circle one) Normal~
~-, ?-fJ.nL / z l1"b.., 11 ;o< WITHSAMPlfS
J,'\(j I I -Z,,A • ;._ □ flommoble Report Due
R~linqui,hed by (Signci;;re) Dote/Time Rece~ by (Signatvre) Date/Time 0 C.Orrosivu (Far lnb U,e Only)
□ H;ghly To,uc
Relinqui,hed by (S;gnature) Dote/Time Recei....d by (SignatvreJ Dcte/Time □ Olh.r(l;,1}
Receipt Temp: Receipt pH
Temp 81,ank y N (Wet/ Motel,)
Cu,lody Seal: Present/ Absent lntad/Nol lntad Seal #,
F-268 (6/0A)
\M1nf-lABOAATORY COf'Y YEUOW--REf"ORT APPENDIX PINK-'SAMP1B/S!A,Y,ITT!R
II
February 10, 2006
lnteg,.
En uironmen ta I
Solutions
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region 4
61 Forsyth Street, SW
Atlanta, CA 30303-3104
Subject: Submittal of the Interim Remedial Action Report
Operable Unit #1 (Former Landfill No. ·1 Area)
Weyerhaeuser Company, Plymouth, North Carolina
Dear tvlr. Bryant:
• 30 Patewood Dri\·e, Suite 100
Patewood Plaza One
Greemillc, SC 29615-3535
Telephone: [phone]
Fax: [phone]
\\'WW. rmtinc .Cl )Ill
On behalf of Weyerhaeuser Co111pany (Weyerhaeuser), R.l'vlT North Carolina, Inc. (RMT), is
submitting the enclosed Interim Remedial Action Report for the Former Landfill No. 1 Arca.
This document has been completed in fulfillment of the re(juire111ents for the Ou-·1 Remedial
Design/Re111edial Action (RD/RA) Consent Decree, Civil Action No. 4:03-C\l-90-H(3) lodged on
June 6, 2003.
The Interim Remedial Action Report documents completion of the Remedial Action for the OU-I
Former Landfill No. 1 Arca.
As specified in the SOW, three copies have been enclosed for your review and approval. One copy of
each document has been submitted directly to Mr. Nile Testerman at the North Carolina Department
of Environment and Natural Resources (NC DENR). Upon approval by USEPA, Weyerhaeuser will
begin implementation of the remedial action activities outlined in the RA Workplan.
Construction Inspection was conducted on December 14, 2005. Figure 5 of the report will be
forwarded to your attention within the next couple of weeks. OCS/EnSafe has encountered difficulty
getting the final "as-built", survey finalized for the site.
/;\ \\'l'GVL \ P/T\ll0-05115 \09\UXMJ5J 1509-019.IJOC
•
Mr. Randy Bryant
United States Environmental Protection Agency, Region 4
February H), 2006
Page 2
•
Please contact Ms. Kathy 1-luibregtse, RMT Principal in Charge, at [phone] or Mr. John Gross,
Weyerhaeuser Project Manager, at [phone], or me al [phone] for any questions you mav
have. We look forward to receiving your approval of this document.
Sincerely,
RMT North Carolina, Inc.
~R\L_
Michael 13. Parker. P.E.
Senior Project Manager
Attachments:
cc: Mr. Nile Testerman, NC DENR
Mr. John Gross, Weyerhaeuser
Mr. Bill Morris, Weyerhaeuser
Ms. Kathy 1-luibregtse, RMT
Central Files
J: \ \\'PCVL \ l'JT\00--05115\09\ LOOJ51 l509-019.DOC
RMI® Integrate.
Environn al
Solutions
January 9, 2006
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region 4
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3104
•
Subject: Operable Unit I (OU-I)-Remedial Action (RA) Implementation
Quarterly Pro6>rcss Report (October 2005 though December 2005)
Weyerhaeuser Company (Weyerhaeuser)-Former Landfill No. I Area
State Road 1565, Martin County, North Carolina
Dear Mr. Bryant:
30 Patcwood Drive, Suite 100
Patewood i'bza One
On behalf of Weyerhaeuser, RMT North Carolina, Inc. (RMT), is submitting this quarterly progress report for
the period of October 2005 through December 2005 for the OU-I RA activities at the above-referenced site.
This pro6>ress report describes the tasks initiated and completed during this period.
Construction Activities
Borrow Areas
Soil excavation in the borrow areas for transportation, placement, and compaction on the Former
Landfill No. I Area was completed in October. Shaping of the borrow areas was completed in
November and seeding of the Hardison property was completed in December. Trees will be planted
around the perimeter of the pond constructed on the Hardison property in accordance with the
Engineering Drawings in January. Additional seeding activities planned for the Hayes property will
also be completed in January. All erosion and sediment control features are being inspected and
maintained in accordance with the North Carolina Department of Environment, and Natural Resources
(NC DENR) approved Erosion and Sediment Control Plan (ESCP). No pumping of groundwater from
the excavation occurred during the period from October through December.
Former Landfill No. I Area
Concrete curbing was installed around the perimeter of the remaining buildings in October. Existing
concrete pads were also raised to meet the final grade elevations in accordance with the Engineering
Drawings.
Soil cover placement and compaction on the Former Landfill No. I Arca was completed in early
October. Soil was placed 14 to 16 inches in depth over the gcotextile and compacted to meet
95 percent of Standard Proctor. The soil cover was placed in a single lift due to constrnctability
issues. The thicker lift better distributes the wheel loads over the soft subgrade and avoids subgrade
rutting. The thicker lift is also more protective of the underlying geotextile. However, adequate
l:\\VPGVLIP JT\OQ.QS 115\0'll[.OOOS l 1509-018.DOC
(LA
• •
Mr. Randy Bryant
United States Environmental Protection Agency, Region 4
January 9, 2006
Page 2
compaction (95 percent of Standard Proctor) and optimum moisture content (±3 percent) was still
achieved in accordance with the Construction Quality Assurance Plan (CQAP) and Specifications.
Field density testing was performed for every 500 cubic yards of fill placed. Soil cover density testing
results were provided in the monthly progress reports submitted to United States Environmental
Protection Agency (USEPA) during this period.
Fertilizer and lime was disked into the soil in accordance with the Specifications prior to seeding. An
approved seeding mixture and seeding method was used.
A water truck was used continuously around the borrow areas and where the trucks were traveling on
the Former Landfill No. I Area to minimize dust at the site.
Approximately 15 acres of the soil cover was damaged by a significant rainfall event associated with
tropical stom1 Tammy on October 7 and 8, 2005. Additional fill material from the borrow area was
used to fill and reshape the eroded areas. These areas were compacted and reseeded with the specified
seeding mixture. Silt fencing that was damaged by this event was repaired or replaced and staked hay
bales added in some areas. Repairs of the eroded areas and silt fencing were completed by
November 10, 2005.
USEPA and NC DENR performed the pre-final construction inspection of the Fonner Landfill No. I
Arca on October 19, 2005. RMT, on behalf of Weyerhaeuser, submitted a Pre-final Construction
Inspection Report to USEPA on October 31, 2005, documenting the inspection and follow-up actions
to be taken prior to the final construction inspection. All of the action items were related to the eroded
areas discussed above and were completed by November IO, 2005.
USEPA and NC DENR conducted the Final Construction Inspection of.the RA for the Former Landfill
No. 1 Area on December 14, 2005. Eroded areas from the tropical stonn event that were observed by
USEPA and NC DENR during the Pre-final Construction Inspection on October 19, 2005, had been
repaired. No follow-up actions were necessary following the Final Construction Inspection.
Weyerhaeuser will continue to inspect the cover system and all erosion and sediment control measures
on a weekly basis and following significant rainfall events in accordance with the approved ESCP.
Repairs will be made to the cover system and the erosion control measures as needed.
During the week of November 14, 2005, the initial sampling event for the Former Landfill No. I Area
long-term monitoring program was completed consistent with the Performance Standards Verification
Plan (PSVP). Groundwater, wetlands soil, and leaf litter samples were collected for chemical analysis.
A summary of the analytical data will be provided to USEPA and NC DENR in January 2006.
l:\WPGVLIP Jl\00-05 l 15109\J..000511509-013.00C
•
Mr. Randy Bryant
United States Environmental Protection Agency, Region 4
January 9, 2006
Page 3
Daily Reports
Mr. Travis Tarbet of RMT filled the role of resident construction quality assurance (CQA) representative
throughout the RA implementation. As the CQA representative, Mr. Tarbet completed the daily summary
reports as required by the RA Workplanning documents. With the RA work completed, Mr. Tarbet left the site
as the CQA representative on November 8, 2005.
Project Schedule
RMT, on the behalf of Weyerhaeuser, will submit the Interim RA Report lo US EPA and NC DENR by the end
of January.
If you have any questions regarding this letter, please contact Bill Morris of Weyerhaeuser at 252/793-8494 or
Mike Parker of RMT at 864/234-9462.
Sincerely,
RMT North Carolina, Inc.
~1?-~~
Michael B. Parker, P.E.
Senior Project Manager
cc: Nile Testerman, NC DENR
Bill Morris, Weyerhaeuser Plymouth
!:\WPGVLIPJTI00-05115\09\L000S11 S09.Ql 8.DOC
•
Memorandum
To: Nile Testerman
Environmental Engineer
Federal Remediation Branch
From: Hanna Assefa ~
Environmental Toxicologist
Inactive Hazardous Sites Branch
December 27, 2005
Re: Site Conceptual Model Memorandum
Lower Roanoke River
Martin County, North Carolina
•
The following comment on the subject document is based both on my review and discussions with Tom
Auxpuerger of the US Fish and Wildlife Services.
I. Assessment Endpoint 2: Protection of Worm Eating Birds. The argument against the
application of 1 OX uncertainty factor to the dioxin toxicity value is based on an interpretation
ofa series of US Fish and Wildlife Services studies on the relationship of the concentration of
dioxin in wood duck eggs and reproductive performance. Wood ducks are not the most
sensitive birds in the area therefore the observations may not apply to all birds. Also there still
remains the issue of using a toxicological value for dioxin from a study that is not considered
to be of chronic exposure duration.
2. For most of the other assessment endpoints the justification used to change the risk conclusion
is a wildlife survey and other short term observations of the different invertebrates and
wildlife. These types ofobservations cannot give conclusive evidence of the health of the
subject populations. In order to gather conclusive evidence one must conduct long term
studies of the subject populations relative to the expected health effects of the contaminants of
concern. These types of studies generally take years.
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
November 23, 2005
Melody Sydow
Environmental Manager/ Audit, Assessment and Remediation
Weyerhaeuser
Mail Stop EC2 2Cl
PO Box 9777
Federal Way WA 98063-9777
Re: Performance Standards Verification and O&M Plan
Operable Unit Three (former chlorine plant)
Weyerhaeuser, Plymouth, NC
Dear Melody,
rwrn@~awrnfR)
lJl] NOV 2 8 2005 ~
SUPEAFUND SECTION
The document noted above, dated October 2005, is approved. If you have any
questions, please contact me at 404/562-8794 or [e-mail].
cc: Nile Testerman, NCDENR
Sincere.~ly tO /;;:::{) ff~ . -
Randy Bry~ntJ
Remedial Project Manager
Superfund Remedial/Site Evaluation Branch
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable• Printed with Vegetable OB Based Inks on Recycled Paper (Minimum 30o/~ Postconsumer)
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October 31, 2005
lnteg.A
Envi;Sental
Solutions
Mr_ Randy Bryant
Remedial Project Manager
United State Environmental Protection Agency, Region 4
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Subject: Prefinal Construction Inspection Report
Operable Unit 1 (OU-1) RD/RA
Weyerhaeuser Company---Former Landfill No. 1 Area
State Road 1565, Martin County, North Carolina
Dear Mr. Bryant:
• pA
30 Patcwoo<l Drive, Suite 100
Patewood Plaza One
Greenville, SC 29615-3535
Telephone: [phone]
Fax, 864-281-0288
www.rmtinc.com
The Statement of Work for Remedial Design/Remedial Action (RD/RA), Former Landfill No. 1 Area,
Weyerhaeuser Company, Plymouth Wood Treating Plant Site, North Carolina requires that a Prefinal
Construction Inspection be conducted upon preliminary completion of the RA activities. The purpose
of the inspection is to determine whether the construction is complete and consistent with the
Consent Decree. The inspection is required to consist of a walk-through of the OU-1 project site. For
the Former Landfill No. 1 Area (OU-1), the Prefinal Construction Inspection was held on October 19,
2005. This letter report documents the outstanding construction items that must be completed to
deem the RA complete. The Prefinal Inspection is to be documented to outline the outstanding
construction items, actions required to resolve the items, completion date for the items, and set an
anticipated date for the Final Construction Inspection.
Those in attendance at the Prefinal Inspection included Randy Bryant, United States Environmental
Protection Agency (USEPA), Nile Testerman, North Carolina Department of Environment, and
Natural Resources (NC DENR), Jim Bragg and Bill Morris of Weyerhaeuser Company
(Weyerhaeuser), David Moore and Bradley White of Ops Contracting Services LLC (OCS), and Kent
Nilsson, Mike Parker and Travis Tarbet of RMT, Inc. (RMT). The above group met in the construction
trailer at the Plymouth Mill to discuss tl1e overall construction activities and status of OU-1. The
following summarizes the meeting discussions:
• RA construction activities were essentially complete over the entire Former Landfill No. 1
Area with the exception of seeding in one small area on October 6, 2005.
• Over most of the landfill, the rye grass had already come up and on the day of the inspection
in many areas the slower germinating fescue grass was coming up.
I:\ WPGVJ.\PJT\00-05115\09\ 1..000511509-015.DOC
• • •
•
Mr. Randy Bryant
United State Environmental Protection Agency, Region 4
October 31, 2005
Page 2
•
• Over the next 30 to 36 hours (October 7 and 8, 2005), the area received 7.98 inches of rainfall
from the remnants of tropical storm "Tammy".
• This significant precipitation event (1 in 25 year storm) came at a time when the cover on the
landfill was most vulnerable to erosion. As a result, there were several areas along the edges
of the landfill that suffered severe erosion (see attached photographs).
• In general the silt fencing/hay bales did an excellent job in preventing cover soil from going
into the wetlands.
• Nile Testerman, NC DENR, asked if a Sediment and Erosion Control Plan had been prepared
for the RA activities. Weyerhaeuser and RMT both assured Niles that it had been prepared
and followed for both the RA activities at the Former No. 1 Landfill Area and the Borrow
Areas. Weyerhaeuser and RMT also stated that a Mining Permit and National Pollutant
Discharge Elimination System (NPDES) permit for the Borrow Area had been obtained as
well.
• OCS and Weyerhaeuser stated that the repairs to the eroded areas, silt fences, and associated
reseeding would be complete by November 18, 2005 pending dry weather.
• Weyerhaeuser and RMT reported that the first monitoring event of the groundwater, wetland
soils and leaf liter collection will take place during the week of November 14, 2005. Also, the
rusted metal debris located in the wetlands along the northern portion of OU-1 will also be
removed during this same period.
Following the discussions, the entire OU-1 area was toured to look at the eroded areas and discuss
how the repairs would be made. The plan is to haul additional borrow in to fill and reshape the areas
that eroded. These areas will be re-compacted and seeded again with the specified seed mixture. For
most of OU-1 the silt fences will have to be taken down and reinstalled. The soil that was held by the
fencing will be reshaped, compacted and reseeded as well.
US EPA commented that overall the site looked good. The anticipation is that once the
aforementioned repairs are completed and the vegetation is established, that this will protect the
cover system for OU-1. US EPA commented that another visit to the site will be likely (possibly the
week of November 14) and will be considered the Final Construction Inspection. Once the Final
Construction Inspection is completed, Weyerhaeuser will have 60 days to prepare and submit an
Interim RA Report. This report will be consistent with US EPA guidance for preparing the report
(Close Out Procedures for National Priorities List Sites, US EPA, OSWER Directive 9320.2-09A-P).
I:\ WPGVL \ l'ff\00-05115\09\ I..O()J511509-015.DOC
•
Mr. Randy Bryant
United State Environmental Protection Agency, Region 4
October 31, 2005
Page3
•
Weyerhaeuser agreed to periodically communicate the status of the repairs to the cover system to US
EPA so that the Final Construction Conference can be scheduled. If you have any questions or
comments, please contact Bill Morris at 252-793-8494 or Mike Parker at 864-234-9462.
Sincerely,
RMT North Carolina, Inc.
M~B-~ Michael B. Parker, P.E.
Senior Project Manager
Attachments: Photographs
cc: Bill Morris, Weyerhaeuser Company-Plymouth, NC
John Gross, Weyerhaeuser Company-Federal Way, WA
Kathyrn Huibregtse, RMT, lnc.-Milwaukee, WI
Nile Testerman-NC DENR, Raleigh, NC
Central Files
I:\ WPGVL \ l'JT\00--05115\09\ t000511509-015.DOC
•
lf'!ll.
Client Name:
Weyerhaeuser Company
Photo No.
001
Description
Date
10/19/05
Erosion on soil cover east of
salvage yard area, looking
north.
Photo No.
002
Description
Date
10/19/05
Erosion on aggregate cover in
salvage yard area, looking
north.
/;\ WPGVI. I l'/T\ 00-05115\ 09\ Z0005115V9·002.DOC
•
Photographic Log
Site Location:
Plymouth, North Carolina
1
Project No.:
5115.09
PhotoLog form F·\05 (06n9f[J.l}
•
Client Name:
Weyerhaeuser Company
Photo No.
003
Description
Date
10/19/05
View of erosion on landfill
surface looking west. Grass has
emerged.
Photo No.
004
Description
Dale
10/19/05
Erosion on soil cover west of
proposed salvage yard, looking
north.
/; I Wl'GVL \ l'{/'\00·05115\09\Z000511509-001.DOC
•
Photographic Log
Site Location: Project No.:
Plymouth, North Carolina 5115.09
2 ' l'hutulug Form F-\05 {06/29/04)
•
Client Name:
Weyerhaeuser Company
Photo No.
005
Description
Date
10/19/05
View of erosion in same area as
photo number 004, picture
taken further south, looking
north.
Photo No.
006
Description
Date
10/19/05
Closer view of erosion near rock
check dam show in photo
number 004, looking north.
/: \ WPGVI. \ P{T\ 00-05115 \ 09 \ 200051 1509•002. DOC
•
Photographic Log
Site Location:
Plymouth, North Carolina
3
Project No.:
5115.09
PhotoLog Form F-l05 (06/29/().1)
October 26. 2005
lnfl•iratA
E,1 ui ron-ta I
Sulutions
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency
North Si,te Management Branch
61 Forsyth Street. SW
Atlanta, GA 30303-3104
Subject: Weyerhaeuser Company
Former Chlorine Plant, OU-3
Plymouth, North Carolina
• 744 Heanbnd Trail 53717-1934
P.O. Box 8923 53708-8923
Madison, \\11
Telephone: [phone]
Fax: [phone]
www.rmtinc.com
Performance Standards Verification and 01,eration and Maintenance Plan
Dear Mr. Bryant:
In accordance with Section YI, paragraphs 11 and 12, of the Consent Decree for the Remedial Design/Remedial
Action (RD/RA) for OU-3, enclosed for your approval are three copies of the final Performance Standards
Verification and Operation and Maintenance Plan for the Former Chlorine Plant area. A copy of this Plan has
also been submitted directly to Mr. Nile Testerman of the North Carolina Department of Environment and
Natural Resources (NCDENR).
If you have any questions, please contact Melody Sydow. at 253-924-6650. or Kris Krause, at 608-662-5178.
Sincerely,
RMT North Carolina, Inc.
~~~ 6. kra-~
Kristopher D. Krause
Senior Project Manager
cc: Nile Testerman -NCDENR
Melody Sydow -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
Jim Bragg -Weyerhaeuser Company
Glen Wyatt -Weyerhaeuser Company
Kathy Huibregtse -RMT. Inc.
Dan Madison -RMT, Inc.
• I:\ Wl'r-.1St\' \ l'JT\00-05 l(JO\ 70 \00002 \ L000510070•009.DOC
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
September 27, 2005
Melody Sydow
Environmental Manager/ Audit, Assessment and Remediation
Weyerhaeuser
Mail Stop EC2 2C l
PO Box 9777
Federal Way WA 98063-9777
~c:;t~ ,'.1~s'J~
SUPIErfL,•\.~ · ,£10f\Gll\'l
Re: Comments on Performance Standards Verification and O&M Plan
Operable Unit Three (former chlorine plant)
Weyerhaeuser, Plymouth, NC
Dear Melody,
I have a few comments regarding the document noted above:
Section 3.4: Performance Standards: As written, the text should refer to long
term performance standards. Also, add a reference to short term performance
standards such as excavation standards and sheet pile installation requirements,
and indicate that the construction quality assurance plan addresses those short
term performance standards. Note here how the planned excavations satisfy the
language in the ROD that states that excavations will extend to the " ... practicable
horizon and vertical limits .... "
Section 4.1.4: Initial sampling should include a groundwater well sampling event
shortly before the start of wall installation. Such sampling would serve as a
baseline to evaluate the long term performance of the barrier wall.
Section 4. I .5: Turbidity may be a useful parameter to measure during the
monitoring well purging.
Please revise the document accordingly. If you have any questions, pl~ase contact me at
404/562-8794.
Sincerel'l k_') _
fa:~~~
Remedial-Project Manager
Superfund Remedial/Site Evaluation Branch
Cc: Nile Testerman. NCDENR
,, Internal Address {URL)• ht1p://www.epa.gov
Recycled/Re;;:yclablE' • Printed with Vc1Jelablo Oil Basod Inks on Recyclod Paper (Minimum 30% Poslconsumer)
Integral.
Environ, al
Solutions
July 28, 2005
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Subject: Weyerhaeuser Company
Former Chlorine Plant, OU-3
Plymouth, North Carolina
• 744 l·karclnnd Trail 537 I 7~ 1934
P.O. Box 8923 53708-8923
J\.bdison, \\11
Tckphonc: 608-83 J-4444
Fax: [phone]
rru ~ @ IB ,rw"rn'fn) ['ill A;;~~~
SUPERFUND SECTION
Performance Standards Verification and Operation and Maintenance Plan
Dear Mr. Bryant:
In accordance with Section VI, paragraphs 11 and 12, of the Consent Decree for the Remedial Design/Remedial
Action (RD/RA) for OU-3, enclosed for your review and comment are two copies of the draft Performance
Standards Verification and Operation and Maintenance Plan for the Former Chlorine Plant area. A copy of this
Plan has also been submitted directly to Mr. Nile Testerman of the North Carolina Department of Environment
and Natural Resources. Upon receipt of review comments on the draft documents, a final Performance
Standards Verification and Operation and Maintenance Plan will be prepared for the site.
If you have any questions, please contact Melody Sydow, at 253-924-6650, or Kris Krause, at 608-662-5178.
Sincerely,
RMT North Carolina, Inc.
~£)~_
Kris.topher D. Krause
Senior Project Manager
cc: Nile Testerman -NCDENR
Melody Sydow -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
Jim Bragg -Weyerhaeuser Company
Glen Wyatt -Weyerhaeuser Company
Michael Clea -Delta Environmental Consultants, Inc.
Kathy Huibregtse -RMT, Inc.
Dan Madison -RMT, Inc.
I:\ WJ'MSN \ l'JT\00-05100\70\00002 \L0005J0070-008.DOC
\,\~,'~ Q·I\ J"\'
Integral.
Environ, al
Solutions
September 1, 2004
Mr. Willie Hardison
• 744 Heartland Trail 53717-1934, '
P.O. Box 8923 53708-8923
Madison, WI
Telephone: [phone]
F,x, 608-831-3334
www.rmtinc.com
North Carolina Department of Environment and Natural Resources
Water Quality Division, Groundwater Section
943 Washington Square Mall
Washington, NC 27889
Subject: Well Abandonment Record
Dear Mr. Hardison:
RMT, Inc., on behalf of Weyerhaeuser Company, is submitting this Well Abandonment Record
(GW-30) in accordance with 15A NCAC 2C for the eight geotechnical borings drilled and abandoned
at the Weyerhaeuser Plymouth Mill Former Chlorine Plant area (Figure 1). The eight geotechnical
borings were drilled from August 2, to August 5, 2004, to determine soil properties and shallow
stratigraphy to support the Remedial Design of the USEPA-selected remedy for the Former Chlorine
Plant area. Communications with the North Carolina Department of Environment and Natural
Resources (NCDENR) indicated that only one Well Abandonment Form (GW-30) would be needed to
document the abandonment of all eight borings.
Parratt Wolff, Inc., under subcontract with RMT, Inc., drilled and abandoned eight geotechnical
borings in the vicinity of the Former Chlorine Plant at the locations shown on Figure 2. Table 1
summarizes the total depths and diameters of the borings. The eight geotechnical borings were
abandoned by placing cement/bentonite grout via tremmie pipe and filling from the bottom up to
approximately 1 foot below the existing ground surface. The grout mixture consisted of 1 bag of
Portland cement (approximately 100 pounds) and 5 to 15 pounds of bentonite for every 6 to 7 gallons
of water. The borings were then brought to grade with a 3,000 pound per square inch concrete mix
and finished to match the surrounding grades.
The attached GW-30 Form and supporting information provide further details of the abandonment
procedures. Please contact me if you have any questions regarding this information.
Sincerely,
KrL pher D. Krause
Senior Project Manager
cc: Melody Sydow -Weyerhaeuser Company
John Cross -Weyerhaeuser Company
Randy Bryant -US EPA
Lynn France -COM Federal
I:\ Wl'r-1Sr\' \ 1')1'\Q0.05101)\68 \ Ul005 I 0068·007. DOC
Nile Testerman -NCDENR
Paul Randall -ORD Cincinnati
Robert Stevens -Parratt Wolff, Inc
•
Mr. Willie Hardison
Water Quality Division, Groundwater Section
September 1, 2004
Page 2
List of Attachments:
Table 1
Figure 1
Figure 2
GW-30 Form
I:\ \Vl'MSN\l'JT\00·0~700\68\ I.D00510068·007 DOC
Soil Boring Summary
Site Locator Map
Geotechnical Boring Locations
•
Table 1
Soil Boring Summary
Weyerhaeuser Company
•
Former Chlorine Plant -Plymouth, North Carolina
SB-1 47 6
SB-2 42 6
SB-3 42 6
SB-4 42 6
SB-5 42 6
SB-6 67 8
SB-8 52 8
SB-11C 22 6
I:\ Wl'MSN \ PJT\OO·0S!U0\68\ Ul00510068--007.DOC
LANDRLL
N0.1
STATE LOCATION
SOURCE:
BASE MAP PRODUCED BY PHOTOGRAMMETRIC DATA
SERVICES, INC., CHARLOTTE, NORTH CAROLINA. DATE
OF PHOTOGRAPHY: DECEMBER 20, 1994.
-----APPROXIMATE LIMIT OF THE 10-YEAR
FLOOD PLAIN
------APPROXIMATE PROPERTY LINE
0 1500' 3000'
SCALE: 1 "= 1500'
PROJECT: FEASIBILllY STUDY
WEYERHAEUSER CO.
MARTIN COUNTY, NORTH CAROLINA
SHEET TITLE:
SITE LOCATOR MAP
DRAWN BY: SYLVESTM SCAl.£:
CHECKED BY: 8SJ 1 • "" 1 soo·
APPROVED BY: KOK DATE PRINTED:
DATE: SEPTEMBER 20D4 EP 0 1 2004
PROJ. NO. 05100.68
Fll£ NO. 51006803.DWG
RGURE 1
744 Heartland T roil Madison, WI 53717-1934
P.O. Box 8923 53708-8923
Phone: 608-831-,f.4,l.4
Fox: 608-831-.J3J4
NOTES
1. BASE MAP PRODUCED BY PHOTOGRAMMETRIC. DATA SERVICES,
INC.
2. ESTIMATED MERCURY ISOCONCENTRATIONS IN SUBSURFACE SOIL
DETERMINED FROM FIGURE 5-1 A OF THE REMEDIAL
INVESTIGATION REPORT (RMT 2000).
TARGET
AREA2
0 40'
, .. _ -D
LEGEND
r 1
!.._ ____ J APPROXIMATE LOCATION OF FORMER EQUIPMENT
AND SUBSURFACE UTILITIES
EXISTING EQUIPMENT
c::::J APPROXIMATE EXTENT OF 4-FOOT DEEP SOIL
EXCAVATION (HLA, 1992)
BURIED CONCRETE SLABS
--10-ESTIMATED EXTENT OF TOTAL MERCURY,
ISOCONCENTRATION _ IN SOIL (mg/kg)
PROPOSED TARGET AREA EXCAVATION LIMITS
OU) PUMP
STATION SUMP
FENCE LINE
PROPOSED BARRIER WALL ALIGNMENT
APPROXIMATE GEOTECHNICAL BORINGS
LOCATIONS
EXISTING SUBSURFACE STORM SEWER SYSTEM
OVERHEAD PROCESS PIPING
FIRE HYDRANT
FIRE LINE
□ ca STORMWATER CATCH BASIN
-FLOW DIRECTION OF STORMWATER
~ PIPE RACK SUPPORT
LEGEND (CONT.)
80'
TOTAL MERCURY CONCENTRATIONS IN SOIL
;, 1 OOOmg/kg
TOTAL MERCURY CONCENTRATIONS IN SOIL
;,100mg/kg
TOTAL MERCURY CONCENTRATIONS IN SOIL
;,1 Omg/kg
PROJECT: FEASIBILITY STUDY
WEYERHAEUSER CO.
MARTIN COUNlY, NORTtt CAROLINA
SHEET TITLE:
GEOTECHNICAL BORING LOCATIONS
DRAWN BY: SYLVESH.4 SCALE: PROJ. NO. 05100.68
CHECKED BY: 8SJ 1 ~ e:40' FlLE NO. 51006804.DWG
APPROVED BY: KOK
DATE: SEPTEMBER 2004 FIGURE 2
.. iii "E ~ 0 3. SUBSURFACE SOIL MERCURY CONCENTRATIONS PRESENTED FOR
;
z z .. 7« Heartland Trail
c,,~ -~ 8 TO O FT. NGV029. (0-8 FT BGS) Madison, WI 53717-1934
.£ C iii(/) SCALE: 1 "= 40' P.O. Box 8923 53708-8923 ~ K] • 4. GROUND SURFACE ELEVATION APPROXIMATELY 8 FEET NGVD29. Phonec 608-831-#14 OQ(l)0.._ __________________________________________________________________________ J. ____ _: ________ ~F,==:c~6:00:-:BJ:7:-:~:J:4 ___ ..J
. .
•
• • North Carolina -Department of Environment and Natural Resources -Division of Water Quality-Groundwater Section -1636 Mail
Service Center• Raleigh, NC 27699-1639 -Phone No. [phone]
WELL ABANDONMENT RECORD WELLCONTRACTOR....cP..:•:.:.;rr•::.:;«c.;.W:..:o:.:.;lff'-'' lnc;:cc:...· _______ _
WELL CONTRACTOR CERTIFICATION # _2_4_87 ______ _
1. WELL USE (Chock Applicable Box): Residential □ Municipal □ Industrial □ Agricultural □ Monitoring □
Recovery □ Heal Pump Waler Injection D Other 11D If Other, Lisi Uso:_Gc.e:..:o:::l•:.:ch:::n:::ica:.:c:I B:.:o:::rinc.,g,::s _______ _
2. WELL LOCATION: (Show a sketch oflhe location on back of fonn.)
Nearest Town: Plymouth County :::M:::a:::rt:..:in~-----------
State Road 1565
(Road Name and Number, Community, Subdivision, Lot No.)
3. OWNER: Weyerhaeuser Company
4. ADDRESS: NC Highway 149 North, Plymouth, NC, 27962
. □·□ □ □ m 5. TOPOGRAPHY: draw, slope, hi!ftop, valley, flat
(circle one)
6. TOT AL DEPTH: Table 1 DIAMETER Table 1 ------
7. CASING REMOVED:
fret
NIA
diameter
NIA
8. DISINFECTION: -'-N""IA'-------------
(Amounl of 70% hypochlorite used:)
9. SEALING MATERIAL:
Neat Cement Sand Cement
bags of cement _, __ _ bags of cement. __ _
gallons ofwater_6_-_7 __ gallons of water __
Qlb.cr
Type material...:B:.:•:.cnt:c:on.;:;il:::e __________ _
Amount 5 -15 pounds
10. EXPLAIN METHOD EMPLACEMENT OF MATERIAL.
Tremmie tube from bottom to the top.
11. DA TE WELL ABANDONED --'s""/3/"'o'-'4--:::.Bl:::.510"'4'------
35076
Quadrangle No.
WELL DIAGRAM: Draw a detailed sketch of tho
well showing total depth, depth and diameter of
screens remaining in the well, gravel interval,
intervals of casing perforations, and depths and
typos of fill materials used.
~6 G,,u,JIJ 5:.,r-.£
o4--3Q'.:0~~£rE , -1 -
M-"-~ /&./n:,,,Jt'fE
61<0t,1-,
• I f!,f',6 Cl!J,,IE>lr
•5n,1€~QS
/So.Jrr:w!TE.
• 6 Tr> 16/>UA'JS
I</~
I do hereby certify that this well was abandoned in accordance with 15A NCAC 2C, well construction
standards, and that a copy of the record has been provided t the well owner.
Signature of person abandoning the well ·2 l........:.-# "!. · t;
WELL LOCATION: Draw a location sketch on the reverse of this sheet, showing the _direction and distance
of the well to at least two (2) nearby reference points such as roads, intersections and
streams. Idenlify roads with State Highway road identification numbers.
Submit original to the Division of Water Quality. Groundwater Section, one copy to the owner within 30 days
from completion of abandonment.
GW-30 Revised I 2/99
• •-----~~:-=, Letter of Transmittal lo)~@l~l]W~ij
RMT North Carolina, Inc.
30 Patewood Drive, Suite 100 (29615-3535)
PO Box 25000 (29616-2500)
Greenville, SC
Tel. [phone] • Fax [phone]
To: Randy Bryant
Remedial Project Manager
USEP A Region IV
Waste Management Division
61 Forsyth Street, S.W. 11th Floor
Atlanta, GA 30303-3104
Prepared By: Mike Parker, P.E.
tn1 JUL 2 8 2004 ~
SUPERFUND SECTION
Date: 7/22/04
Project No.: 5115.06
Subject: Communication Record of July 8"'
Phone Conversation--Landfill No. 1
Area, Weyerhaeuser Company,
Plymouth, NC
Attached is a Communication Record of the call between you, Bill Morris-Weyerhaeuser Company,
and I on July 8, 2004. The purpose of the call was to discuss a design issue for the Landfill No. 1 Area
and submittal requirements associated with the Prefinal Design.
Please call me at 864-234-9462 if you have any comment or questions.
Best Regards,
RMT, Inc.
Michael B. Parker, P.E.
Senior Project Manager
Cc: John Gross-Weyerhaeuser Company
Kathryn Huibregtse-RMT, Inc.
Joseph Jackowski-Weyerhaeuser Company
Bill Morris-Weyerhaeuser Company
-.• Nile Testerman-North Carolina Department of Environmental and Natural Resources
I:\ WPGVL \ PJT\00--05115\06\2000511506--002.DOC 7/22/04 TRANSL TR.DOC FORM F334 (04/24/01)
• • Communication Record
RMT North Carolina, Inc.
100 Verdae Boulevard (29607-3825)
PO Box 16778 (29606-6778)
Greenville, South Carolina
Tel. [phone] • Fax [phone]
Participant
Randy Bryant
Bill Morris
Prepared By:
Signature:
Mike Parker
Company Name
US EPA, Region IV, Atlanta, GA
Weyerhaeuser Company,
Plymouth, NC
Telephone No.
404-562-8794
252-793-8494
Title Senior Project Manager
Project Name: Weyerhaeuser Company, Landfill No. 1 Area, Prefinal/Final Design,
Proj eel No.:
Date:
Plymouth, NC
5115.06
7/8/04
Meeting At: Conference Call
Time: 4:45 PM Telephone Conversation: Yes
Subject/Purpose: To discuss Prefinal/Final Design items and submittals required with the
Prefinal Desi
Bill Morris and I called Randy Bryant of USEPA, Region IV, Atlanta, GA to discuss questions
concerning the Prefinal/Final Design for the Weyerhaeuser Company Landfill No. 1 Area in
Plymouth, NC. The following items were discussed and resolved as summarized below:
• Landfill Cover/Wetlands Edge---As a follow-up to my July 1, 2004 phone conversation with
Randy Bryant, Randy had left me a message to be sure that we put a discussion in the
Prefinal/Final Design document about leaving a 5' buffer area from the edge of the wetlands to
where the geotextile will start and how this will or will not impact the wetlands. We reviewed
the previous discussion and agreed with Randy's request.
Resolution: Bill and I agreed that we would address the impact of the buffer area on the
wetlands in the document.
• Prefinal/Final Design Submittal: As work efforts on the prefinal/final design report progressed,
a discrepancy between the Consent Decree and the Statement of Work for the Landfill No. 1 Area
was found. In Section VI of the Consent Decree-Performance of Work by Settling Defendant,
paragraph 11, part (f), it states that the Prefinal/Final Design document will include, (1) Final
plans and specifications; (2) an O&M Plan; (3) Construction Quality Assurance Project Plan; ( 4)
Field Sampling Plan ( directed at measuring progress towards meeting Performance Standards;
and (5) a Contingency Plan. In contrast, the Statement of Work-Task II, paragraph D outlines
what is required in the Prefinal/Final Design. In addition, Tasks IV and V of the Statement of
Work describe other items that are to be submitted concurrent with the Prefinal/Final Design
document. Task IV requires the O&M plan and manual which will outline how the cover will be
I:\ WPGVL \Pf[\00~5115\06\Z.000511506-001.00C 7/22/04 COMMREC.DOC FORM F59 (04/24/01)
• Communication Record •
maintained in the future-frequency of inspections, repairs, monitoring well maintenance, grass
cutting, etc. The manual provides Weyerhaeuser staff with the procedures for completing the
maintenance. Task V requires that a Performance Standards Verification Plan (PSVP) be
submitted. The Statement of Work outlines that a Field Sampling and Analysis Plan (FSAP) and
Quality Assurance Project Plan (QAPP) are required components of the PSVP. These will
address the procedures for the wetlands and groundwater monitoring required in the ROD as
well as in the approved Conceptual Design. Task III of the Statement of Work is the Remedial
Action (RA)task. Components of the RA Workplan include the Construction Management Plan,
Construction Quality Assurance Plan, Construction Health & Safety Plan/Contingency Plan along
with other items that will become a part of the RA Workplan Implementation.
Resolution: Randy agreed with our understanding of the Statement of Work items and that this
should be our direction for completing the Prefinal/Final Design, the RA Workplan and
subsequent RA Implementation.
This communication record serves as documentation of agreement between Weyerhaeuser Company,
RMT, Inc. and USEPA for proceeding with the remaining RD/RA activities for the Landfill No. 1 Area.
I:\ WPGVL \ Pff\00-05115\06\2000511506.001.DOC 7(11/04 2 COMMREC.DOC FORM F59 (04/24/01)
laW(
July 12, 2004
Mr. Randy Bryant
Project Manager
USEPA Region IV
Integral.
Environ 'tl!
Solutions
Waste Management Division
61 Forsythe Street, S.W., I Ith Floor
Atlama, GA 30303-3104
Subject: Weyerhaeuser Company
Former Chlorine Plant, OU-3
Plymouth, North Carolina
Pre-design Investigation Workplan
Dear Mr. Bryant:
• 744 Heartland Trail 53717-1934
P.O. Box 8923 53708-8923
Madison, WI
Telephone: [phone]
Faxc 608-831-3334
www.rmtinc.com
'/wt @ @'. n w 1s ~ lfll, JUI_ I 5~/YJ,
SUPERFUND SECT/ON
RMT, Inc. (RMT), on behalf of Weyerhaeuser Company, is submitting this Pre-design Subsurface Investigation
Workplan which details the field activities that will be conducted to support the Remedial Design of the
USEPA-selectcd remedy for the Former Chlorine Plant area. The on-site activities are described in the attached
workplan and will consist of investigative geotechnical drilling, groundwater monitoring well abandonmem and
replacement, and groundwater elevation measurement. The information obtained by the pre-design
investigation will provide geotechnical and subsurface information to facilitate the design for the containment
barrier.
The enclosed workplan contains a brief introduction describing site information and background, and the
purpose and scope of the pre-design activities. Following the introductory information, the on-site field work is
described, followed by a section detailing how the field work will be documented and how the data will be used.
The workplan concludes with the anticipated schedule of events.
The specific activities presented in this workplan arc similar to work either previously conducted or being
performed on the Weyerhaeuser Plymouth site during Remedial Investigation/Feasibility Study (Rl/FS)
activities or on-going RD/RA activities at Landfill No. I. As such, the pre-design workplan for the Former
Chlorine Plant references the USEPA-approved Quality Assurance Project Plan (QAPP), Field Sampling and
Analysis Plan (FSAP), and USEPA-rcviewed Health and Safety Plan (HSP) developed for the site RI/FS
activities.
!:IWP~1SN\l'JT\00·05 100\68\L0OOS I 0068.()02.DOC
i
Mr. Randy Bryant
USEPA Region IV
July 12, 2004
Page 2
• •
Weyerhaeuser is prepared to execute the pre-design investigation immediately upon your approval of the
Workplan. Please contact me (608-662-5178) if you have any questions regarding this information.
Sincerely,
RMT, Inc.
~
Krist 1cr D. Krause
Senior Project Manager
Attachments: Pre-Design Investigation Workplan
Figure I -Proposed Geotcchnical Boring Locations
cc: John Gross -Weyerhaeuser Company
Melody Sydow -Weyerhaeuser Company
Lynn France -CDM Federal
Nile Testerman -NCDENR
Jeff Welti -NCDENR
Paul Randall -ORD Cincinnati
! :\ WPM S N\I' IT\()().QS I 0016H\U)IJ05 I 00(,8 .002.noc
• •
Pre-design Investigation Workplan
1.0 Introduction
1.1 Workplan and Site Status under CERCLA
This workplan presents the anticipated pre-design investigation activities for the Former Chlorine
Plant (FCP) Area of the Weyerhaeuser Company Plymouth Wood Treating Plant Site (Site) in
Plymouth, North Carolina. The Site is comprised of four areas of concern, which are being
investigated or remediated under the Superfund Alternative Sites program of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). The four areas are
Landfill No. I, the FCP, Welch Creek and the Roanoke River. The FCP is considered Operable
Unit-3 (OU-3) of the Site.
A Remedial Investigation (RI) report was issued for the FCP in June of 2000, and the Feasibility
Study (FS) in June 2003. Both documents were approved and entered into the administrative
record. In September 2003, the Record of Decision (ROD) was issued for the site and the
Consent Decree was lodged on May 24, 2004 to perform Remedial Design/Remedial Action
(RD/RA) activities. As part of the USEPA-selccted remedy for the FCP presented in the ROD, a
subsurface containment barrier and two limited soil excavations are to be conducted at the FCP.
The notice of authorization to proceed was given by the USEPA on June 9, 2004. This workplan
is the first formal activity under the RD/RA Consent Decree for the FCP area.
1.2 Site Information and Background
The Site, as defined by United States Environmental Protection Agency (USEPA), is an active
wood and paper products manufacturing facility located on State Road 1565 in Martin County,
North Carolina. The FCP operated on site from approximately 1952 to 1968. Operations
involved the production of chlorine and sodium hydroxide from salt brine (sodium chloride).
Mercury cells, containing metallic mercury, were used in the production process. Process
equipment was removed between 1968 and 1978, and the building was then used for storage and
equipment maintenance from the late 1970s to 1984. The aboveground portion of the FCP
structure was demolished and removed in ·1986 and 1987, with the floor slab and subgrade
structures being left in place. The 1987 demolition material was found to contain mercury, and
approximately 1,300 tons of debris were disposed as a hazardous waste (D009) at the GSX
Landfill in Pinewood, South Carolina. In 1992, subsurface investigations and additional soil and
foundation removal activities were conducted and a report was submitted to the State of North
Carolina. In November, 1997, a Special Notice letter was sent by US EPA to Weyerhaeuser that
included the FCP as an area of concern. The resulting Administrative Order by Consent (AOC)
I US EPA Docket No. 98-I 0-C] for conducting Remedial Investigation (RI) /Feasibility Study (FS)
activities included the FCP area.
The RI confirmed the presence of mercury-contaminated soil in the footprint area of the former
manufacturing building. Impacted soils in an area approximately 120 by 200 feet and to depths
I:\ WP~tS :-J\P J1'CXJ.Cl5 l mV,H\UXl05 I lX}611·lXl2.DOC
• • •
of up to 44 feet below the shallow groundwater surface or 48 feet below ground surface were
identified in the RI report. Shallow soils near adjacent U drains that were not removed previously
were also found lo contain some mercury. The adsorbed mercury present in the soil has limited
solubility in the local groundwater but does exceed the North Carolina mercury groundwater
standard of 1.1 ug/L in six of the twenty-nine monitoring wells installed in the area.
Concentrations of mercury in both groundwater and soil decrease with depth and distance from
the former building footprint area. Groundwater flow patterns in the FCP area were found to be
complex in part due to leakage from the cooling tower system which was repaired in January
2004 as part of routine maintenance. The general flow of the groundwater in the FCP area is
expected to be north toward the Roanoke River.
Seven alternatives were presented in the Feasibility Study for the FCP area. The options
considered in the FS ranged from No Action to excavation of remaining mercury-contaminated
soils. In September 2003, USEPA issued the ROD for the Former Chlorine Plant area that
selected as the remedy Alternative 4 -Containment with Groundwater Compliance and Trend
Monitoring. The primary components of this alternative include:
Installation of a 45 foot deep barrier wall around 23,000 sq feet of the former FCP building
footprint area
Target area soil excavation of approximately 900 cubic yards of mercury impacted soils near
the former hypochlorile tank and the eastern U drain areas.
Groundwater compliance monitoring outside of the containment area
Surface cover over existing grassy areas north of the FCP footprint and over areas disturbed
by the remedial activities.
Land use restrictions to limit potential consumption of the groundwater.
1.3 Overall Goal and Schedule of the Pre-design Activities
The overall goal of this pre-design work plan is to obtain information needed to complete the
design of the remedy. Specifically, geotechnical information will be obtained that will allow
completion of the detailed evaluation and the subsequent design of an appropriate containment
structure (i.e., subsurface barrier wall) for installation around the former FCP building footprint
area. Additionally, the current groundwater flow pattern will be documented now that the leaking
cooling tower sump has been repaired.
The proposed schedule for implementation of the pre-design activities is being expedited to
accommodate the schedule set forth in the Consent Decree. Based upon the June 9, 2004 notice
of the authorization to proceed, the Final Design and Remedial Action Work plan documents are
due to USEPA on December 6. 2004. As such. the field investigation activities described in this
workplan should begin in late July 2004.
I:\ WPMSN\Pfl\00-1 )51 (K)lfill\L(Kl05 J (Klti~-CM 12. [){X:: 2
, • •
2.0 Pre-Design Investigation Activities
2.1 Objectives of the Pre-Design Investigation Activities
The objective of the pre-design investigation field activities is to obtain site-specific information
to facilitate the RD. The specific objectives for the pre-design investigation activities are to:
Determine soil geotechnical properties along the proposed containment barrier footprint and
within the Target Excavation Area 2 to support detailed evaluation of barrier wall options
and to aid in the final design of the barrier wall and excavation area support systems
Establish the depth to the clay that the barrier wall will be tied into along the perimeter of the
barrier wall planed. ·
In addition, two existing groundwater monitoring wells will be removed and replaced. This
activity is discussed in detail in Subsection 2.3 of this Workplan. The tasks to be performed
during the field activities include advancing soil borings to collect the geotechnical data; well
abandonment, replacement, and development; water level measurement; and investigative-
derived waste management. These activities are discussed further in the following subsections.
2.2 Field Investigation
The gcotechnical drilling program is anticipated to consist of up to 11 soil borings, IO of which
would be advanced around the estimated footprint of the barrier wall to an estimated depth of
40 feet below ground surface (bgs) (anticipated clay aquitard depth). Approximate soil boring
locations are presented in Figure I. The soil borings will be conducted via a truck-mounted
drilling rig, using 3 ¼-inch inside diameter hollow stem augers. Soil will be sampled via split-
spoon sampler/standard penetration testing (SPT) in accordance with ASTM D 1586 at 2.5-foot
intervals from the ground surface to a depth of 15 feet. The soil samples, collected at 5-foot
intervals, will be containerized and sent to and retained by RMT for verification of field soil
classification. If cohesive soil is encountered, hand penetrometer readings will be taken. One
soil boring will be advanced to a depth of approximately 20 bgs within the planned Target Area 2
excavation.
Should consistent subsurface conditions be encountered along the barrier wall footprint,
(including both soil type and top-of-clay aquitard elevation) a field decision may be made to
reduce the total number of borings. Soil borings will be field-logged to include Unified Soil
Classification System (USCS) soil descriptions and relative densities. Corresponding depths and
geotcchnical parameters, such as drilling conditions encountered and SPT values, will be
documented during the boring installations. In addition, the presence of potential bulk fill, such
as concrete debris and/or old foundations that could create complications during construction of
the barrier wall, will.be documented. Each borehole will be grouted from the bonom of the
deepest sample depth to the land surface with a bentonite slurry grout. Asphaltic concrete to
match pavement materials will be placed in the remaining borehole depth.
I:\ WP:\1SN\P J1'(~J.U5 I I Kl\6R\Ul005 I Ck 16H·OOZ. DOC 3
, • •
2.3 Well Abandonment, Replacement, Development, and Survey Documentation
Monitoring wells CP-08-1 and CP-08-2 are located in a low-lying area within the site.
Consequently, these monitoring wells are not accessible when standing water is present.
Weyerhaeuser will abandon these wells and replace them approximately 15 feet west of their
existing location. The existing wells will be abandoned in accordance with 15A NCAC
02C.O I I 3(b)( I). The replacement wells (CP-08-1 R and CP-08-2R) will consist of ¾-inch outer
diameter PVC with a stainless steal wire-wrapped screens. The total depth of the CP-08-1 R will
be approximately 13 feet with a 9-foot screened length. The total depth of the CP-08-2R will be
approximately 31 feet with a 3-foot screened length. The wells will be installed and developed in
accordance with I SA NCAC 02C.O I 08. The development water will be collected in containers
for analytical testing and future disposal. The newly installed wells will be located vertically (top
of casing and ground-surface) and horizontally in accordance with subsections 8.1.1 and 8.8.2 of
the FSAP.
2.4 Decontamination of Drilling and Sampling Equipment
The drilling equipment used for soil sampling and monitoring well installation will be cleaned
with high-pressure/hot water washing prior to initiation of the field investigation. The same
procedure will be applied to the down-hole drilling tools between each boring location and to all
drilling equipment as it leaves a contaminate reduction zone. Water used for steam cleaning will
be obtained from a potable water source.
2.5 Water Level Monitoring
Groundwater levels (49 total) in the vicinity of the FCP will be recorded as described in
Subsection 8.3 of the FSAP. All groundwater monitoring wellheads will be inspected for damage
and repaired as necessary.
2.6 Investigative-Derived Waste Management
Development and decontamination water, soil, and other solid waste decontamination material
generated from the investigative activities will be containerized on-site by media. The waste will
be sampled, analyzed and profiled as necessary, prior to disposal. Waste materials will be
handled in accordance with the Field Sampling and Analysis Plan and the Health and Safety Plan.
The soil cuttings will be disposed of in accordance with applicable state and federal regulations
based on the results of the characterization testing analytical results. ·
3.0 Documentation and Data Evaluation
A pre-design technical memorandum will be prepared documenting soil borings, soil borehole
abandonment forms, and groundwater monitoring well construction diagrams. This pre-design technical
memorandum will be included in the Remedial Design portion of the Remedial Action Workplan. The
soil information will be used to determine and refine the proper containment technology as well as to
develop an appropriate construction approach. The data will be used in the development of the remedial
design and will also be refiected in the construction plans and specifications. The well abandonment
I :I WPMS N\P Jnl K)·OS 11 K)\6~\U K~ l5 I ( Kl(,8 -1 K)2.DOC 4
• •
forms and groundwater monitoring well construction diagrams will be prepared and submitted to the
North Carolina Department of Environment and Natural Resources(NCDENR).
Water levels measured in the existing monitoring wells and the two replacement monitoring wells will be
used to prepare an updated water table map. This information will be used to evaluate groundwater flow
panerns at the site since repair of the cooling tower sump has been completed.
4.0 Schedule
The field activities are expected to take up to eight working days and are anticipated to commence in late
July, pending USEPA approval of this pre-design workplan and driller availability. The gcotechnical
information obtained during this investigation is expected to be immediately incorporated into the
remedial design efforts. Well abandonment documentation will be provided to the NCDENR within
30 days of the completion of the well abandonment.
I:\ WPMS N\P JTll)().IJ51 ()(l\fil!\U KKJ5 I !K )(,l!.(Kl2. DOC 5
NOTES
1. BASE MAP PRODUCED BY PHOTOGRAMMETRIC DATA SERVICES,
INC.
2. ESTIMATED MERCURY ISOCONCENTRATIONS IN SUBSURFACE SOIL
DETERMINED FROM FIGURE 5-lA OF THE REMEDIAL
INVESTIGATION REPORT (RMT 2000).
TARGET
AREA 1
TARGET
AREA2
-
LEGEND
r 1
L_ ____ J
I
c::::J
IO ' : '. ,-1
-10-
~
"
-~
APPROXIMATE LOCATION OF FORMER
EQUIPMENT AND SUBSURFACE UTILITIES
EXISTING EQUIPMENT
APPROXIMATE EXTENT OF 4-FOOT DEEP SOIL
EXCAVATION (HLA, 1992)
BURIED CONCRETE SLABS
ESTIMATED EXTENT OF TOTAL MERCURY,
ISOCONCENTRA TION IN SOIL (mg/kg)
PROPOSED TARGET AREA EXCAVATION LIMITS
FENCE LINE
PROPOSED BARRIER WALL ALIGNMENT
PROPOSED GEOTECHNICAL BORINGS
(ADVANCED TO ~5 FEET INTO CLAY AOUITARD)
EXISTING SUBSURFACE STORM SEWER SYSTEM
OVERHEAD PROCESS PIPING
FIRE HYDRANT
FIRE LINE
STORM WATER CATCH BASIN
FLOW DIRECTION OF STORM WATER
PIPE RACK SUPPORT
LEGEND (CONT.) -TOTAL MERCURY CONCENTRATIONS IN SOIL
;,7 OOOmg/kg
TOTAL MERCURY CONCENTRATIONS IN SOIL
:C100mg/kg
TOTAL MERCURY CONCENTRATIONS IN SOIL
:ClOmg/kg
PROJECT: FEASIBILITY STIJDY
WEYERHAEUSER CO.
MARTIN COUNTY, NORTH CAROLINA
SHEET TITLE:
PROPOSED GEOTECHNICAL BORING LOCATIONS
DRAWN BY: SIEV£RID SCALE: ROJ. NO. 05100.66
CHECKED BY: BSJ 1~=40' IL.£ NO. 51006801.D'Mi
APPROVED BY: BS FIGURE 1
v ~ o 40' so·
;
~ Ji 3. SUBSURFACE SOIL MERCURY CONCENTRATIONS PRESENTED FOR 744 Hoorlland Tran
DA TE: .AJL Y 2004
z" • 8 TO O FT. NGVD29. (0-8 FT BGS) Mad;san, 111 53111-1934 .£ ~ a:i (ii SCALE: 1 "= 40' P.a. Box 8923 53708-8923 ~ i jj , 4. GROUND SURF ACE ELEVATION APPROXIMATELY 8 FEET NGVD29. Phan"' 608-831-4444 ao~a---------------------------------------------------------------------------.l.-------------~~===·~6=08=-=BJ=/--=~=3~4----'
May 18, 2004
Integrated •
Environ me,
Solutions ·
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency
North Site Management Branch
Atlanta, Georgia 30303-3104
Subject: Response to USEPA Technical Review Comments
Conceptual Design Report
•
Weyerhaeuser Company (Weyerhaeuser) Site, OU-I (Landfill No. I)
Plymouth; North Carolina
Dear Mr. Bryant:
100 Verdae Boulevard
Greenville, SC 29607-3825
Telephone, 864-281-0030
Fax, 864-281-0288
www.rmtinc.com
r{B) rn@ @lWf~ ml[]
lnl MAY I 9 2004 11=!)
SUPERFUNO SECTIOf~
Attal:hed for your review are technical responses to review comments presented in your letter dated April 26,
2004.
Responses to review comments are presented in Attachment 1. For ease of review, the original comment is
presented in bold italic typeface with the accompanying response following in normal typeface. As noted in the
comment responses, where appropriate, requested revisions will be incorporated into the Prefinal/Final Design
Workplan to be prepared for OU-I; therefore, submittal of a revised Conceptual Design Report is not anticipated.
In addition, we have included in Attachment 2, a replacement Appendix C, containing revised Boring Logs along
with replacement document covers and spines.
If you have.questions regarding the enclosed information, please contact me.
Sincerely,
RMT North Carolina, Inc.
t ::l:"!::JJL fl'C
Principal-In-Charge
Attachment I
Attachment 2
Response to Comments on the Conceptual Design Report
Revised Appendix C
cc: Nik Testerman -NC DENR
John Gross -Weyerhaeuser Company
Bill Morris -Weyerhaeuser Company
Mike Parker -RMT
Project File 00-05 I I 5.03
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Attachment 1
Response to Comments
•
• •
USEP A Technical Review Comments
Conceptual Design Report
OU-1 Landfill
1. Pages 4-4 and 4-5: Additional comments regarding performance monitoring will likely be
generated as part of subsequent review of the RA workplan and performance standards verification
plan. However, I would initially suggest that FJ,WS-04 be added to the wetland soil monitoring
program. I would also suggest that we maintain monitoring wells MWJ-2, 3-2, 5-2, 7-2, ·and 9-2.
These wells should be sampled as part of the baseline and again between 2 or 3 years after the
baseline.
As requested, FLWS-04 will be added to the wetland soil monitoring program. In addition,
monitoring wells MWl-2, MW3-2, MWS-2, MW7-2 and MW9-2 will be maintained and sampled as
part of the baseline monitoring and again in two to three years after the baseline monitoring. These
changes to the proposed monitoring programs will be reflected in the Prefinal/Final Design Report.
2. Page 4-5: NCDENR notes that the correct groundwater standard for 2,3,7,8-dioxin is 0.00022ng/l.,
not 0.00023.
' The correct groundwater standard of0.00022 ng/L for 2,3,7,8-TCDD will be reflected in subsequent
submittals for OU-I.
3. 1\ppendix C: The borings logs should more clearly note the soil interval that was collected for
analysis of COCs.
A replacement Appendix C, containing boring logs which have been revised as requested, along with
replacement document covers and spines are included in Attachment 2.
4. Please indicate how and when you will document completion of the land use restrictions and
associated easements noted in Section IX of the Consent Decree.
Section IX, Paragraph 24 c of the Consent Decree indicates that an easement form will be provided to
Weyerhaeuser by US EPA. Within 60 days of USEPA's request, Weyerhaeuser will submit a draft
casement and evidence of title. A conceptual schedule for completion of the land use restrictions and
casements described in Paragraph 24 will be prepared and documented in the Remedial Action
Workplan. Completion of the land use restrictions and associated easements will be documented in
the Remedial Action report.
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•
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Attachment 2
Revised Boring Logs
•
• • RM•~ Letter of Transmittal
RMT, Inc.
100 Verdae Boulevard (29607-3825)
PO Box 16778 (29606-6778)
Greenville, South Carolina
Tel. [phone] • Fax [phone]
To: Mr. Nile Testerman
NC Division of Water Quality
Environmental Sciences Branch
NCDENR
1621 Mail Service Center
Raleigh, NC 27699-1621
Prepared By:
Enclosed Conceptual Design Report.
l>OCUMENT'J 3/22/04
Date: 3/23/04
Project No.: 05115.04
Subject: Report
TRANSLTRDOC FORM F334 {04/24/01)
RM•~ Integral.
Environ al
Solutions
March 23, 2004
Mr. Randy Bryant
Remedial Project Manager
United States Environmental Protection Agency, Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-3104
•• 100 Veraae Boulevard
Greenville, SC 29607-3825
Telephone, 864-281-0030
Fax, 864-281-0288
www.rmtinc.com
'
Subject: Submittal of Conceptual Design (CD) Report for Operable Unit 1 (OU-1) (Landfill No. l)
Weyerhaeuser Company (Weyerhaeuser), Martin County, North Carolina
Dear Mr. Bryant:
On behalf of Weyerhaeuser, RMT North Carolina, Inc. (RMT), is submitting the enclosed OU-1 CD
Report. This document has been completed in fulfillment of the requirements for the OU-1 Remedial
Design/Remedial Action (RD/RA) Consent Decree, Civil .Action No. 4:03-CV-90-H(3) lodged on
June 6, 2003.
The CD report provides preliminary details for design of the remedy set forth in the Record of
Decision (ROD), in accordance with the Statement of Work (SOW).
As specified in the SOW, three copies have been enclosed for your review and approval. One copy of
each of the documents has been submitted directly to Mr. Nile Testerman at the North Carolina
Department of Environment and Natural Resources (NC DENR). Upon approval by the United States
Environmental Protection Agency (USEPA), Weyerhaeuser will begin preparing the final design
workplan for OU-1.
Please contact Ms_ Kathy Huibregtse, RMT Principal in Charge, at 262/879-1212 or Mr. Bill Morris,
Weyerhaeuser Project Manager, at 252/793-8494 for any questions you may have. We lookforward to
receiving your approval.
Sincerely,
RMT North Carolina, Inc. ,-
~~)~
Senior Project Engineer
Attachments:
cc: Mr. Nile Testerman, NC DENR
Mr. John Gross, Weyerhaeuser
Mr. Bill Morris, Weyerhaeuser
M_s. Kathy Huibregtse, RMT
Central Files
I:\ WPGVL \ P/T\00-051 15 \ 04 \ WOOS I 1504-008.DOC
A Weyerhaeuser
The !Uturc is yrowing·~
January 22, 2004
Mr. Randy Bryant
US EPA Region IV
Waste Management Divi'sion
61 Forsyth Street, S.W. 11 th Floor
Atlanta, GA 30303-3104
PO Box787
Plymouth NC 17962
Tel [phone]
!.!cC~e:~ti~fie..!.d~M!:.!a~il~J.111!!~~~:!!.d F:B ~: z:, ~ ~
./
SUPERFUl~D SECTION
Subject: Landfill Area No. 1, Operable Unit I, Weyerhaeuser Site, Martin County, NC
Dear Mr. Bryant:
Enclosed is a certified copy of the deed notice that was recorded with the Martin County Register
of Deeds. The notice was filed as stated in Section V., paragraph 9a. of the Consent Decree for
RD/RA for OU_!.
Please advise us if there are any additional items that may be necessary to fulfill this
requirement.
Sincerely,
Bill Mortis, Project Manager
Weyerhaeuser
Plymouth, NC
WM:dmc
Enclosure
xc: Joe Jackowski
John Gross
Enclosure
xc: Repott File
0U-19
0341 •
• •
BOOK Cl --1 9 PAGl 3 41
STATE OF NORTH CAROLINA
COUNTY. OF MARTIN NOTICE
Prepared By: Joseph P. Jackowski, Attorney, Law Department
Weyerhaeuser Company-CH 1J28
Post Office Box 9777, Federal Way, WA 98063-9777
Weyerhaeuser Company by this instrument dated the / 1./t/,... day of
January, 2004, hereby gives Notice with regard to thefollowing
case:
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
EASTERN DIVISION
NO. 4: 03-CV-90 (H) (3)
UNITED STATES OF AMERICA
Plaintiff,
vs.
WEYERHAEUSER COMPANY
Defendant,
Notice is hereby given that a Consent Decree was entered in
the above referenced case on August 18, 2003. Further,
Weyerhaeuser Company is the owner of the property referred to in
the Consent Decree as "Operable Unit 1" hereinafter referred to as
(OUl) and in accordance with Paragraph 9 of the Consent Decree
entitled "Notice to Successors-in-Title" Weyerhaeuser Company
(
; '
OU-19
0342 •
•
BOOK U., -1 9 PllGE 3 4 2
hereby gives Notice (quoting from paragraph 9 of the Consent
Decree) "Tel all Successors-in-Title that OUl is part of the
property, that EPA selected a remedy for OUl on June 19, 2002, and
that the potentially responsible party has entered into a Consent
Decree requiring implementation of the remedy". The property owned
by Weyerhaeuser Company that is the subject of the Consent Decree
is described as follows:
Lying and being in Jamesville Township, Martin County, State
of North Carolina, and. being further described as follows:
By that deed dated the 18th day of May, 1962, and recorded
in Book E-7, Page 609, Martin County Registry, West India
Fruit and Steamship Company, Incorporated, conveyed to
Weyerhaeuser Company a tract or parcel of land containing
1223. 80 acres, more or less. The property that is the
subject of this Notice is located on a portion of this tract
or parcel of land and contains 100 acres, more or less, and
it is on this portion that Weyerhaeuser Company had a
Landfill. Any potential purchaser of this property or any
portion thereof is encouraged to do the following:
(1) Examine the file of the case heretofore referred to in which
the Consent Decree was entered,
(2) Have the public records relating to this property examined,
(3) Have a survey made of the property by a professional land
surveyor.
IN TESTIMONY WHEREOF, Weyerhaeuser Company has caused this
instrument to be signed in its name by its Vice President, its
0U-19
0343 •
• •
" BOOK ll -19 PAGE 3 4 3
corporate seal hereunto affixed, all by authority duly given the
day and·year first above written.
WEYERHAEUSER COMPANY
BY:
. (CORPORATE SEAL)
0U-19
0344 •
COUNTY OF
I,
•
BOOK ll-1 9 PAGE 3 4 4
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_'9_.,.__,2-.;>tc,;.:O,>i,.-'-l<-<..,,..,.,,,.___\>:,,...,_5__,__..,u..:,,,_;x,_,,2,;,,,;,_'--'L.JI~----' Notary Put
certify that Jack R. Bray, personally came before me this da}
acknowledged that he is Vice President of Weyerhaeuser Compar
corporation, and that by authority duly given and as the act oi
corporation, the foregoing instrument was signed by himself ai
Vice President, and sealed with its corporate seal.
My commission expires
Witness my hand and official seal, this Lhe
~~-;, n :{;) ~,s;'r,-',S
Notary Public
NORTH CAROLINA, MARTIN COUNTY
! hereby ccr;:tirt that the foregoing or attached instrument to be a true copy of a rt"Cord
\~t:p1' <t_~\nJ::"_. Book lL-\9 Page 3l\\ intheofficeofRC}!isterofD,
Martin County, Willirumton, NC.
Witness my hand and official seal thi!s --'t'.:.·A,S·lC,:).s~>s\&"'-'i\'-i("~--''.)."--'~::,__~, 2004.
Tina P. Manning
Martin County Register or Deed!!
By: _...:.\-'c..:.:\:"'-\,:cco.~'-'oc\£L-c=--...c(\..:.\se\ ___ ~_-..,j._,_,\--_'L,----'----I _O.QJYl.
UNITE,TATES ENVIRONM.ENT~l:PROTECTII AGENCY
REGION 4
March 27, 2000
Rodney Proctor
Director, Environmental Affairs
Weyerhaeuser Company
Mail Stop CH IL28
33663 Weyerhaeuser Way South
Federal Way, WA 98003
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960 RECEIVED
APR 012000
SUPERFUND SECTION
Re: Review of the Preliminary Site Characterization Summary Report, Welch Creek Source Area,
Weyerhaeuser Site, Martin-County, North Carolina ·
-:··,:; .. :-:•~:·:.·:,. ";'.t .',"L!;:t··:.· :.:i_ __ •~··=~: •1 :--~;-~_>•: j ., ;_? ::•·
Dear Mr. :PrOCtOr: -~,-,-~, .. -1 , >:J,-,-"( ~ :;:~~~·.;:_:1 ·.~( · ;.;-,-~ ;··· -:/·: -/: :,r Hf'. c: ... ;~·_; -f? ·. y .. ·: -::,"; 'l. :r;·· ;,;r:,•:
The United States·Environmental Protection Agency (EPA) has completed it's review of the
above referenced document.· The document is very,well written' and the data.is welf presented:"•
For the most part, the analysis of the data appears to be reasonable. The following comments are
provided as a record of the EPA review of the document, and to guide the future preparation of
the Remedial Investigation (RI) Report for this area. The Preliminary Site Characterization
Summary need not be revised and resubmitted.
General Comment
It is not readily clear that the RI report for Welch Creek will rely on the 1995 Welch
Creek Study as well as the 1998 field investigation.
l. Page 4-2, Section 4. l. l. Second paragraph, last sentence. MT-I is included as a
background location in this sentence, however, the previous section states that it is not a
background location. If MT-I is not considered as background, then is this location
considered to be within the impacted area? How will the data from .MT-I be interpreted
in the Welch Creek.RI?. "Please 'expand on the issue ·of appropriate liackgrourid ·samples in
.I.P:. c::.:rhi·s secti'On-ofthe Rh•: .. ~ .. : }Jt'~t,.-:-·◄::..,1 .. i-,.~_,: :/,. :· __ :;_ ... _,,; ;-_._ -·,;~_:j ~!~-. ·-!;, :., :.:r.·· ... · •.
,2,~,;~,, Figure··61-l. Preliminarv Conceptual Site Model. Not all of the discharges of wastewater
solids to Welch Creek were permitted under NPDES. Please eliminate this language from
, .. ' .. the chart,iri the first-two·b·oxes,' ',: .:.
Internet Address (URL)• http://www.epa.gov
Recycled/f!ecyclable • Printl_:!d with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% PostconsumerJ
: .. ;.
-·?.t .. · .. =,,/~:
• •
3. The alternating use of PCDD/PCDF and TCDD/TCDF is a little hard to follow
sometimes. Please consider adding clarification to the sections of the RI which include the
presentation of"poly" chlorinated dioxins and furans and the subsequent conversion to
TCDD etc. For example, several sections are entitled "PCDD/PCDF" , yet the first
sentence presents levels of these compounds as "TCDD ... ".
In accordance with the Administrative Order on Consent (AOC), the RI report for the Welch
Creek Area should be submitted to EPA within 30 days of receipt of this letter. If you have any
questions, or need clarification on this letter, please feel free to call me at (404)-562-8799.
cc: Nile Testerman, NCDENR
Tom Augspurger, USFWS
Terry Chuhay, COM Federal
Kathy Huibregtse, RMT
Since ly,
t-J!_jJ
erL. Wendel
emedial Project Manager