Singer Furn_EPA Review of RFI Work Plan-OCR

I
I
6/15/93 NOV Explanatory/New
Collllnent Addressed Adequate Comment I
36 y N 68
37 y N 68 8 38 N/A N/A Reference to VOA
analysis removed.
39 y y
I 40 y N 65
41 y N 65
42 y y
43 y y I 44 Y. y
45 N/A N/A Referenced sentences
removed. I 46 N/A N/A Groundwater
monitoring to be
performed under
Phase I. I 47 y y
48 y N 76
49 y N 75 I 50 N/A N/A Phase II sampling
removed.
51 N/A N/A Pit excavation no I longer proposed.
52 y y
53 y y
54 y y I 55 N N 23
56 N N 61
57 y N 36 I 58 y y
59 N N 44
60 N N 43
61 y y I 62 y N 49, 52, 57, 63, 65,
70
63 y N 46, 53, 80, 82, 85, I 86, 88
64 y N 78
65 y y I 66 N N 49, 52, 57, 63, 65,
70
67 N/A N/A Paragraph referenced
removed. I 68 y N 91
69 y y
I.
I
·1
i ..
I
6/15/93 NOV Explanatory/New
I Comment Addressed Adequate Comment
70 y N 82
a 71 y Y.
72 N/A N/A Sentence referenced
removed.
I 73 N N/A Text modified.
74 N N 55
75 N N/A Text modified; Table
deleted.
76 N/A N/A Text deleted. I 77 y N 94 I. 78 y y
I 79 y N 82
80 N N 88
81 y '[
82 y y Info now contained
I in Appendix C.
83 y y Info now contained .
in Appendix c.
I 84 y y Info now contained
in Appendix c.
85 y y Info now contained
I
in Appendix c.
86 y y Info now contained
in Appendix c.
87 y y Rationale presented
I in Work Plan Section
5.
88 N N 49, 52, 57, 63, 65,
I 70
89 y y
90 N N 79
91 y y
I 92 y y
93 y y
94 y y
i 95 y y
96 y y
97 Y. y
98 y y
I 99 y y Organizational
structure discussed
in Project
I Management Plan
100 y 'l
101 y 'l
I
I
I
SINGER FURNITURE COMPANY
LENOIR, NORTH CAROLINA
EPA I.D. No. NCD000604322
GENERAL COMMENTS
1. The figures included in the October update did not directly
correspond with the current referenced figures in the
document. In addition, many of the figures (e.g., cross
sections, potentiometric maps) provided, including those
from the previ ous investigations of the landfill, are
illegible and should be replaced with the best available
copies of the maps. Figure 2 needs to be improved for
readability.
2. The entire Work Plan (especially the Sampling and Analysis
Plan in Appendix 0) is poorly written and contains many
typographical and grammatical errors. The text should be
revised accordingly. This was also a General Comment (on
page 3) in the previous NOV. In addition, several numbered
sections have been omitted from the text1 and it is not
clear if sections were edited out from the last revisi on .
3. The cover page of the June 15, 1993 NOV letter frorn EPA to
Singer Furniture states (in the fourth paragraph) that
"Singer Furniture must submit a revised RFI Work Plan
(visibly indicating revisions to Work Plan in the text using
)?old or italicized text) ... ". The revised Work Plan
contains neither bold nor italicized type. As a result, it
is not possible to determine where the revisions have been
incorporated. Any additional revisions should be visibly
indicated to clearly show any modifications which have been
made.
4. The lateral and vertical extent of ground-water
contamination at the Landfill (SWMU #1) is not adequately
assessed by ground-water monitoring plans proposed in the
Work Plan. The locations of shallow and deep wells are not
specified in the Work Plan, thus it is not possible to
determine whether the lateral extent of contamination is
going to be assessed. Additionally, geological/
hydrogeological information presented in the report
indicates that deeper aquifers (saprolite/bedrock) are
potentially hydraulically connected to the shallow,
contaminated aquifers. However, only one well is proposed
for installation in the bedrock, while no wells are proposed
for the saprolite. Furthermore, there are no
geophysical/hydrogeological studies (i.e., permeability
tests, slug tests, etc.) proposed to establish
1
u
I
I
I
I
I
I
I
I
I
I
I
I
I
·D
I
I
I
I
SINGER FURNITURE COMPANY
LENOIR, NORTH CAROLINA
EPA ID No. NCD000604322
SPEctFIC DEFICIENCIES
l~ :INTRODtTCTION
1. The Work Plan states in the third paragraph on page 1 that
wastes from off-site plants were transported by EPA-approved
hazardous waste transporters to the Singer Plant for
incineration. In accordance with the requirements of
Appendix B.II.B.2 of the Permit, revise the'text to indicate
the place of origin and contents of these wastes. If the
contents of these wastes differed from those routinely
managed by the Lenoir facility, identify the content of the
wastes, the origin of the wastes, and onwsite waste
management procedures. The proposed sampling and analysis
strategy should be reviewed and modified (if necessary) to
ensure that all potential waste constituents will be
detected during the RFI activities.
2. The SWMUs on Figure 2 are not labelled. For example, the
first paragraph ·on page 2 indicates that the Container
storage Area (SWMU #6) is shown on Figure 2. Although
Figure 2 contains a stippled pattern for the Storage Area,
the SWMU is not labeled. Revise the figure to cleal':ly
delineate the location of the unit. Also delineate Plant
No. 33 on the figure.
2 . ENVIRONMENTAL SETTING
3.
4.
Figure 2 in the Work Plan shows the Abandoned Drums Area At
Lower Creek (SWMU #2) at two locations: southeast of
monitoring well No. N-2, a~d near well No. NE-1.
Additionally, RFA Appendix No. 1 (Figure 1) in the RFA
Report (located in Attachment 3 of the Work Plan) shows the
drum area to the northwest of the monitoring well. In
accordance with the requirements of Appendix 8.I.B.1.b. of
the Permit, revise the text to indicate the correct location
of the well relative to the location of the abandoned drums,
and ensure that the proposed magnetometer survey (discussed
on page 80) will encompass all potential drum disposal
areas.
The facility has been instructed in the past NOTI and NOV to
add information concerning environmental setting, and to
provide an adequate map showing topography, drainage,
ground-water elevations, and general ground-water flow
directions. The maps provided, Figures 2 and 3, are
redundant. Ground-water flow directions, elevations, and
direction of surface water drainage ·features are not shown
3
I
I
I
I
I
1.
I
I
I
I
I
I
I
I
I
I
I
I
·I~
-···---------··· .. ------
locations, which are the concerns in the investigation.
Revise the map to show the figures more clearly.
a
I
10. The Work Plan states in the first paragraph in this section U
that a water-table map was constructed from water-level
measurements in the seven monitor wells and two water wells 1 located east of the site. Revise the text to indicate the
depth to which screens were set within these wells, and
indicate in which aquifer these screens are located, in
·accordance with the requirements of Appendix B.II.A.1.e. of u
the Permit.
11. The third bullet on page 11 states that ground water flowing Ill
through the Alluvial Aquifer disoharges to the Lower Creek Ii
floodplain. Although ground water flows in the general
direction of the alluvial floodplain, it has not been
demonstrated from the data presented in the Work Plan that I
deep ground water discharges to the creek. Flow nets have
not been presented which suggest that the ground water
gradients in the deeper intervals of the floodplain decrease ti
in the direction of the creek. Furthermore, Figure 4 shows II
that the Alluvial Aquifer extends approximately 25 feet
below the base of the creek. Since the creek does not
extend to the top of the saprolite, it is possible that If
ground water in the Upper Alluvium unit {Unit 1A) below the B
creek base, and in the Lower Alluvium unit {Unit lB) flows
beneath and beyond the creek in a downgradient and off-site 1·
direction. In accordance with Appendix B.II.A.1. and
II.c.1. of the Permit, revise the RFI Work Plan to
investigate the specific hydrologic flow regime in the area Ill
of floodplain and determine the potential for off-site Ii
migration of contaminants.
Section 2.2.1.4, vertical Groundwater Movement (p. 12)
12. The first paragraph on page 12 states that ground water
moves downward from the upper unit into the lower unit.
Provide hydrologic cross sections showing ·the vertical
gradients, and the vertical and horizontal components of
flow as required by Permit Appendix B.II.A.1.e.
13. The last paragraph on page 12 indicates that the saprolite
unit is believed to function as a confining bed which
restricts the downward vertical movement of ground water
from the Alluvial Aquifer into the Bedrock Aquifer. The
ability of the saprolite unit to func~ion as a confining
unit has not been qualitatively or quantitatively determined
since ground-water monitoring wells have not been installed
in the unit and the total thickness of the saprolite has not
been penetrated. Furthermore, the ·saprolite unit is
potentially used as an aquifer for the seven large-diameter
wells located east of Virginia Street (as discussed on page
5
I
I
I
I
I
I
I
accordance with the requirements of Appendix B.II-A-2 of the
Permit.
Section 2.4, surface Water and Sediment (p. 19)
19. Revise the Work Plan to provide surface water inforlllation
for Lower Creek and the Landfill marsh including water
elevation, flow velocity, depth, width, seasonal
fluctuations, flooding tendencies, drainage patterns,
evapotranspiration data, and a description of the surface
water chemistry as required by Appendix B.II.A.3.a. and b of
the HSWA Permit. In addition, surface water and sediment
samples must be collected from the marsh and analyzed for
the same analytical parameters as the ground-water samples.
See Comment #25 below for further discussion of this
sampling.
20. Revise the Work Plan to provide a description of the
sediment characteristics of Lower Creek and the Landfill
marsh including the thickness profile and physical/chemical
parameters as required by the HSWA Permit Appendix
B.II.A.3.c. If these data have not been collected, provide
detailed plans in the revised Work Plan for collecting these
data during RFI field activities.
21. As stated in the June 15, 1993 NOV, the facility must
provide detailed information concerning surf ace water bodies
surrounding the site, and provide a _detailed discussion of
seasonal fluctuations affecting these water bodies. Page 16
of the Work Plan indicates that no seasonal cycle of ground
water levels have been obtained, and proceeds to provide
theories on what might occur due to seasonal fluctuations in
ground ~ater. However, the effects of seasonal fluctuations
are not addressed in the RFI Work Plan. Since the
information is not currently available, in accordance with
the requirements of Appendix B.II.A.3.a.iii. of the Permit,
provide a plan in the Work Plan to obtain these data.
Additionally, page 19 of the Work Plan states that surface
water flow is perpendicular to landforms, and flows from
higher to lower elevations. Provide more site-specific
data, describing features onsite which direct surface water
flow. Provide a figure which clearly shows surface water
runoff, and include sufficient surrounding topography to
show likely runoff receptors. If this information is not
available, indicate how it will be obtained, in accordance
with the requirements of Appendix B-II.A.3. of the Permit-
Section 2.s, Climate (p. 20)
22-Revise the Work Plan to provide climate information
including monthly temperature averages and extremes, wind
.speed and direction, relative hUlllidity/dew point,
7
I
I
I
I
I
I
I
I
I
I
I
I
I
B
I
I
B.II.A.1.e. and II.C.1. of the Permit, the proposed RFI Work
Plan must be revised to investigate the specific hydrologic
flow regime in the floodplain· area and determine the
potential for offsite migration of contaminants.
26. The. last paragraph on page 31 states that the low
concentration of priority pollutant solvent and metals
detected in the downgradient Phase II wells suggests a small
chemical source in the area of the Landfill. Low chemical
concentrations in downgradient wells may also be caused by
other factors including improper stratigraphic well screen
placement, improper geographic well placement relative to
the advancing plume front, improper use of analytical
methods, and location of the contaminant source relative to
the saturated.zone. In addition, the Work Plan does not
consider the chemical characteristics (e.g., solubility,
affinity for sorption} of the wastes relative to the
detected concentrations. Revise the Work Plan to indicate
that the reasons for the observed contaminant distributions
will be investigated during the RFI activities.
27. Detection limits are not listed for several of the compounds
and analytes listed in Table l . Include the missing
detection limits in Table i, if available. Additionally,
clarify whether these results are from one event or whether
several sampling events are represented.
28. The first full paragraph on page 32 says chemical results
from 1982 to 1989 are available. · Provide the results in the
document.
section 3.1.s, Potential Receptors (p. 38)
29. Although the saprolite wells located along Virginia Street
east of the facility are upgradient and may not be impacted
by onsite contamination, wells located downgradient of the
area may be at risk. The potential for offsite ground-
water/leachate flow beneath Lower creek has not been
investigated (see Comment #11). As a result, the risk
potential of downgradient ground-water users should be
evaluated only after the proposed investigation has been
completed. Revise the Work Plan to include a provision that
the risk potential of downgradient ground-water users will
be evaluated only after the proposed RFI investigation is
completed.
30. Page 33 of the Work Plan states "additional data should be
collected to further assess potential toxic air emissions
via the integrity of the landfill cap.tr Provide a text
explanation of contaminants which are potentially expected
to contribute to air emissions, and either provide a
reference to another portion of the document or a
9
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Section 3.4.S, Container Storage Area Analytical Results (p. 47)
37. The Work Plan states at the bottom of page 47 that no
further investigation activities are planned for the
Container Storage Area. This unit can only be deleted from
further investigation if adequate documentation is provided
which shows that the parameters analyzed during the previous
soil sampling activities were sufficient to detect potential
releases £rom all wastes previously stored at the unit.
Since waste paints and paint scrapings (according to page 43
of the Work Plan) have been stored at this unit,
justification must be presented to indicate why metals
analyses a'nd a more complete list of voes are not required.
In addition, all of the requirements specified in specific
Deficiency #57 in the June 15, 1993 Notice of Violation must
be met. Revise the Work Plan accordingly.
4. PROJECT MANAGEMENT PLAN
38. All references (italicized type and bracketed numbers) to
previous Notice of Violation {NOV) comments should be
deleted from the Work Plan . The approach used to address
previous deficiencies must clearly indicate the actual text
which was changed by using bold or italicized type, or some
other method which delineates wording changes.
section 4.1, overall Technical Approach (p. 51)
39. Comment #7 of the previous NOT! indicates that air
monitoring information must be included in the RFI due to
the presence of formaldehyde, a volatile organic compound;
however, an air monitoring plan is neither discussed in the
text, nor included in the table on page 57A which discusses
the steps which will be taken in the assessment of all SWMUs
covered by the RFI. In accordance with Section I.A. in
Attachment B of the Permit. provide information on the
technical approach, scheduies, and personnel with respect to
the air assessment activities.
40.
41.
42 .
Specify that the RFI Report will summarize all information
acquired under the RFI and will define further corrective
actions which are required within the Technical Approach.
The last sentence on page 51 states that investigation-
deri ved data will be cornpa:red with health and environmental
criteria to determine whether a CMS or interim corrective
measures may be necessary. Re-V-J:.se-the--Wo·rk-~-an--tcr-spec±fy·. the--·cr-.i:te:l'--i-a--re:fer~to. /,}.,v .tlll£4 wi./f., -p4>..-hv& n.-1-::-i•f l'Ni!k·~·;,,,s,+" .... ~
'? {.'4'{lJ}-Afe{-I ,,.;e.,.. ,f.p ~ (/l't6 ...ff..v... ~1111)11Atd. -t-,j.J._,,_, t!A-lo.J A-1-t:-d. .k.f,,,.-c '<~<id<:>
-!-<> dei4 Ind/~ .If' /2bl '4·h/h I-;!> l'l?G~S ?C<-Vlf.: . The work Plan do s not inciuae a ~iscussion on the Data
Quality Objectives (DQOs) required for the proposed study.
Revise the Work Plan to include the site-specific Data
11
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
• ~
1• g
n
• ll
II ;3
!I 9
1. ,.
"
I
' ?J
,'l
Quality Objective levels (e.g., DQO Levell for field
screening activities, DQO Level IV for laboratory analyses)
required to achieve the RFI objectives.
Section 4.2, Schedule and Reportinq (p. 57)
43. If the RFI is to be performed in a phased approach, Phase
Reports must be submitted at the end of each phase. In
addition, Section 5 of the Work Plan must be revised to
outline which tasks will be performed as part of each phase,
and describe what criteria will be used to determine whether
subsequent tasks will be required. In accordance with
Section I.A. contained in Attachment B of the HSWA Permit,
also includes the planned phase activities within the
schedule shown on page 57A. This comment was previously
identified within Specific Deficiencies #17 and #60 in the
June 15, 1993 Notice of Violation.
44. The last paragraph on page 57 indicates that a report will
be submitted within 30 days of completion of the approved
interim measure. In addition, the second sentence on page
81 states that interim measures will be in strict accordance
with the Permit. Revise the text to indicate that all
interim measures will also be approved by EPA prior to
implementation. This comment was previously identified as
Specific Deficiency #59 in the June 15, 1993 Notice of
Violation.
Section 4.3, Personnel and Laboratory Quaiifications (p. 59)
45. The Work Plan states that with the exception of Singer
Furniture Company, ENSCX Engineering Group, P.A., Enseco
Incorporated, and AnalytiKEM personnel, no additional
subcontractors will be used for the RFI. This section fails
to identify the drilling subcontractor which will be used
for the drilling and installation of the soil borings and
monitoring wells. In addition, several other subcontractors
or personnel are mentioned throughout the document,
including a land surveyor registered in the State of North
Carolina and a biologist (page 61). Revise the Work Plan to
specify each subcontractor which will be used along with
their qualifications.
I 5. RFI WORR PLAN
I
ftl rl
I
46. The Work Plan states on page 59 that all sampling and
analyses will be conducted in strict accordance with the
Sampling and Analysis Plan (SAP, Appendix D) and in
accordance with ECBSOPQAM. However, Appendix D references
the 1986 EPA Region IV standard Operating Procedures, which
have been superseded by the us EPA Region IV Environmental
services Division (ESD) Envirorunental Compliance Branch
12
Standard Operating Procedures and Quality Assurance Manual
(ECBSOPQAM, February l, 1991). Revis~ the Work Plan and
appendix to reference the updated version of the SOPs.
47. The second paragraph on page 66 indicates that a soil
scientist will select the boring locations on the cap.
Provide the rationale the scientist will use, and indicate
how deep the borings will be advanced.
se~tion s.1.2.1, Landfill Delineation (p. 68)
48. Since the landfill has been regraded and sodded, indicate
how the margin of the landfill will be delineated.
49. Revise the Work Plan to provide a
piezometers used to delineate the
installed, including construction
the proposed well screen depths.
previously identified as Specific
15, 1993 Notice of Violation.
description of how the
landfill will be
methods, materials, and
This oomroent was
Deficiency #62 in the June
50. The second paragraph on page 69 states that only samples
which exhibit OVA readings significantly above background
level or evidencing visual impacts will be sent to a
laboratory for appropriate analysis. Under the proposed
approach, only soils which are visually stained or are
contaminated by volatile organic compounds will be sent to
the laboratory for analysis. The proposed approach does not
allow for the detection of soils contaminated by semi-
volatile or metal contaminants. Since there is no record of
the quantities or types of materials disposed in the
landfill (first sentence on page 68), it is not known
whether these contaminants are present. Furthermore, metals
have been detected in the ground water flowing from the
landfill in concentrations exceeding the Primary Drinking
Water Standards. As a result; the Work Plan must be revised
to submit a minimum of at least one soil sample (collected
.. f.o -~~ .. -~E.~ ~a-~~!:_.tal?~§: __ S..\l~Jac~) from each b<;>r7hole to. the ....... -·· laboratory for Appendix IX analyses. Addi. tional soil
.. •-: ~ ..... 1--salllples should be submitted to the laboratory contingent
:'-~.:.. ·· upon the previously proposed criteria. Revise the Work Plan
\rl.'\ · accordingly.
\ ,, ..
Section S.1.3.2, Groundwater (p. 72)
51. The first sent~nce on page 72 states that nine ground-water
monitoring wells are shown on Figure 7. However, Figure 7
shows only eight proposed wells. Correct the text or figure
accordingly. The second sentence goes on to state that the
"proposed monitoring well system is designed to assess both
the upper and lower alluvial aquifer units and the
underlying saprolite/bedrock aquifer ... (e.g.,
13
I
I
I
I
I
I
I
I
I
I
I
I
m
n
I
I
I
reqular schedule (e.g., quarterly). Revise the Work Plan to
describe the proposed sampling schedule. This comment was
previously identified as Specific Deficiency #74 in the June
15, 1993 Notice of Violation.
56. The second paragraph on page 73 additionally states that
analysis of the RFI Phase I landfill ground-~ater assessment
will determine what additional measures will be taken.
Provide specific criteria (i.e., constituent levels present
in the samples) which will trigger further corrective action
studies. As requested in previous NOT! #ZS, provide a
description of any further investigation which will be
performed if contamination is present at less than ~ater
quality standards to determine if contamination may result
from future releases from the source area. Provide a
description of further actions which will confirm that
further contamination is unlikely.
Section S.1.3.3, Surface Water and Sediment Contamination (p. 73)
57. The bullet at the bottom of page 73 states tnat one sediment
and one surface water sample will be collected from the
:marsh, while the second bullet on page 74 states that two
sediment samples and two surface water samples will be
collected from Lower Creek. Revise the Work Plan to show
the proposed locations of these samples. Additionally, it
does not appear that two samples can adequately assess
releases to surface water from the landfill. Indicate how
sampling will be performed to adequately characterize
drainage features between the landfill and the creek. This
comment is similar to those previously identified as
Specific Deficiencies #66 and #88 in the June 15, 1993
Notice of Violation.
58. The first sentence on page 75 states that additional samples
will be collected durina Phase I if contamination is
detected. Identify the-criteria that will be used for
determining the necessity for further work {e.g., what
contaminant concentration levels are required to justify
furthe.r sampling).
Section s. 1. 3 . 4 I Air Contamination ( p. 7 s·)
59. The Work Plan states in the description of the landfill that
the cap assessment will be used to assess potential air
releases. However, Se.ct ion 5. 1. 3. 4 indicates that air
monitoring/assessment will not be performed. Reconcile the
discrepancy.
15
u
I
I
I
I
I
I
I
I
I
I
I
E
I
I
I
I
84. The second bullet on page 12 states that the soil sample
with the highest headspace reading will be collected for
laboratory analysis at the end of each boring. This implies
that the sample will be transferred from the headspace
bottleware to the sample bottleware at the termination of
the boring. Revise the text t o indicate what measures will
be taken to prevent the volatilization of the salllple during
the transfer waiting period.
section 2.4, Monitoring Well Instaliation (p. 12)
85. The Work Plan indicates that selected soil bo~ings will be
completed as TYPe II monitoring wells. Revise the text to
specify what Type II monitoring wells are. Also, PVC is not an acceptable well construction material where the
analytical program includes volatile organic compounds
(ECBSOPQAM Appendix E.5.1). Furthermore, the selection of
well screen slot size and filter pack materials must be
determined by a sieve analysis of the formation materials,
as required by ECBSOPQAM Appendix E.5.3. This comment was
previously identified as Specific Deficiency #63 in the June
15, 1993 Notice of Violation. The first sentence on page 13
indicates that a schematic diagram of a tYPical monitoring
well is· included as Figure **· correct the Work Plan to
address each of the above-referenced concerns.
section 2.4.3, Installation Procedure (p. 14)
86. Item number 6 on page 14 states that well development will
continue until the water is observed to be clear of
suspended sediments. Revise the text to indicate that
development will continue until the water quality pararoeters
(conductivity, pH, temperature) have stabilized, as required
by ECBSOPQAM Appendix E.7. This comment was previously
identified as Specific Deficiency #63 in the June 15, 1993
Notice of Violation.
section 2.s.3, Procedure (p. 16)
I
I
u
I
I
I
I
I
I
I
I
.I
87. Item number 2 on page 16 indicates that a field data sheet l1
is included as Figu.re **· Correct the Work Plan accordingly Ii
to name and include the f igure .
. as. Item number 6 on page 16 does not indicate the method of I~
disposition of the purge water. Revise the text to provide fi
this information. This comment was previously identified as
Specific Deficiency #80 in the June 15, l993 Notice of ~
Violation. Ii
I
21 I
I