19034_IRC_Initial Abatement Plan_20121003

lnitial Abatement Plan
lnternational Resistive Company, lnc.
Boone, llVatauga County, North Carolina
IHSB lnventory No. NONCD000{907
October 3,2012
Tenacon Project No. 86127103
Prepared for:
lnternational Resistive Company, lnc.
736 Greenway Road
Boone, Watauga County, NC
'*lsl,.Prepared by:
Teracon Consultants, lnc.
Taylors, South Carolina
TABLE OF CONTENTS
INITIAL ABATEMENT PLAN
INTERNATIONAL RESISTIVE COMPANY, INC.
736 GREENWAY ROAD
BOONE, WATAUGA COUNTY, NORTH CAROLINA
TERRACON PROJECT NO. 86127 103
1.0 BACKGROUND......... .........1
2.0 INITIAL ABATEMENT PLAN.... ..,.......1
2.1 Excavation and Trenching............ .........................1
2.1.1 Former Transformer Area. ...................2
2.1.2 Hazardous Materials Storage Area......... ..............2
2.2 Temporary Storage of Material ............3
2.3 Performance Verification Sampling............ ..........3
2.4 Backfilling .........4
2,5 Waste Characterization and Disposa1............... ......................4
2.5.'l Waste Gharacterization ....................4
2.5.2 Waste Disposal ...............4
2.5.2.1 PGB lmpacted Soi!(Zones I and 2).............. ....................4
2.5.2.2 VOG lmpacted Soil(Zone 3).............. ..............5
3.0 woRKER HEALTH AND 5AFETy............ ..........5
4.0 FIELD DOCUMENTATION AND REPORTING ....,... ,.........,,5
5.0 LIMITATiONS ............. ........6
F!GURES
Figure 1 - Site Location Map
Figure 2 - Planned Extent of Soil Excavation
Figure 3 - Planned Extent of Soil Excavation
- Former Transformer Area
- Hazardous Materials Storage Area
INITIAL ABATEMENT PLAN
INTERNATIONAL RESISTIVE COMPANY, INC.
736 GREENWAY ROAD
BOONE, WATAUGA COUNTY, NORTH CAROLINA
IHSB INVENTORY NO. NONCDOOO19OT
TERRACON PROJECT NO. 86127 103
ocroBER 3,2012
1.0 BACKGROUND
Soils in the Former Transformer Area and the Hazardous Materials Storage Area of the subject
facility are impacted by polychlorinated biphenyls (PCBs) and volatile organic compounds
(VOCs), respectively. Limited assessment of these areas was performed in April 2012 by
S&ME, lnc. (S&ME) and the results of those assessments were provided to the North Carolina
Department of Environment and Natural Resources (NC DENR)-Division of Waste Management
(DWU1. Following its review of the referenced assessment reports, the DWM issued a Notice
of Regulatory Requircments (NORR) for Contaminant Assessment and Cleanup on August 17,
2012 (Day to Dunnigan). ln the NORR, IRC is directed to perform initial abatement actions in
these two areas; the intent of the initial abatement actions is to remove grossly impacted soil in
these areas, thereby reducing the risk to human health and the environment.
ln response to the above NORR, Tenacon has prepared this lnitial Abatement Plan (lAP) to
describe the methods and procedures to be used during: the removal of impacted soil in the
areas of concern; verification sampling; waste characterization; and, soil bacKill procedures.
These components are discussed below.
The general site location is presented in Figure 1. Figures 2 and 3 depict the approximate
planned extent of soil excavation in the Former Transformer Area and the Hazardous Materials
Storage Area, respectively.
2.0 INITIAL ABATEMENT PLAN
2.1 Excavation and Trenching
Excavation will be performed in three Zones that are located in the two Areas of Concern at the
site. The Zones are numbered sequentially and are described below and are depicted on the
accompanying Figures 2 and 3. All excavation activities within the three Zones shall be
conducted in accordance with the guidelines provided in this lAP.
1 - Remedial lnvestigation Report, Hazardous Materials Storage Area..S&ME, lnc. June 2012
Soil and Groundwater Assesment Report, Former Transformer Area. S&ME, lnc. June 2012
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lnitial Abatement Plan
lnternationa! Resistive Company, lnc. a Boone, Watauga Co., NC
October 3,2012 m Terracon Proiect No.86127103
T[erratron
2.1.1 Former Transformer Area
Based on the soil borings drilled at the site, it is estimated that there are two distinct zones of
soil impact (Zones 1 and 2) inside the Former Transformer Area that have PCB concentrations
in excess of the Protection of Groundwater Preliminary Soil Remediation Goal (PSRG) for PCBs
(i.e., 140 micrograms per kilogram or "pg/kg") established by the NC DENR-DWM, lnactive
Hazardous Sites Branch (IHSB). Soils within these two zones are planned for removal as
indicated on Figure 2, Planned Extent of Soil Excavation - Former Transformer Area. All soils
within these zones will be considered impacted by PCBs and will, therefore, be managed as
such.
Excavation from these zones will be performed using a backhoe or trackhoe to remove soils to
depths of approximately four to five feet, depending on the zone. Zone 1 is approximately 10
feet x 14 feet in area and will be excavated to an approximate depth of five feet below ground
surface (bgs). Zone 2 is approximately 4 feet x 7 feet in area and will be excavated to an
approximate depth of four feet bgs. There are a number of buried underground utilities in this
area so it will likely be necessary to remove some of the impacted soils manually. The
excavations will not exceed the prescribed limits unless discussed with and approved by
Tenacon. At the conclusion of excavation activities, Terracon will record the aerial extents of
each excavation using a handheld global positioning system (GPS) unit that is capable of sub-
meter accuracy.
2.1.2 Hazardous Materials Storage Area
Based on the soil borings drilled at the site, it is estimated that there is one distinct zone (Zone
3) of grossly impacted soil inside the Hazardous Materials Storage Area that has concentrations
of chlorinated organics (principally perchloroethylene or PCE) that are in excess of the
respective Protection of Groundwater Preliminary Soil Remediation Goal (PSRG) for those
compounds (e.g., 5 pg/kg for PCE) established by the NC DENR-DWM, IHSB. Soilwithin this
zone is planned for removal as indicated on Figure 3, Planned Ertent of Soil Excavation -
Hazardous Materials Sforage Area. All soil within this zone will be considered to be impacted
by volatile organics and will, therefore, be managed as such.
Excavation flom this zone will be performed using a backhoe or trackhoe to remove soils. Zone
3 is approximately 35 feet x 17 feet in area and will be excavated to an approximate depth of 12
feet bgs. There are buried underground utilities in this area so it will likely be necessary to
remove some of the impacted soils manually. The excavation will not exceed the prescribed
extents unless discussed with and approved by Tenacon. Terracon will memorialize the extent
of the excavation using GPS equipment, as described above.
2Responsive r Resourceful r Reliable
lnitial Abatement Plan
lnternational Resistive Company, lnc. ':: Boone, Watauga Co., NC
October 3,2012 e Terracon Project No.86127103
Tferracon
2.2 Temporary Storage of Material
Excavated soils from each Area will be temporarily stored onsite in open topped, roll-off
containers that are equipped with a sealed door, disposable polyethylene liner, and
weatherproof tarp covering. Soils from each Area will be stored in separate containers and will
not be mixed with soils from the other Area. Roll-off containers will be staged in approved
locations, near the rear of the facility, and will be tarped and secured when not actively being
loaded. Rolloff containers will labeled as to contents and date of waste generation during the
time they are'onsite and loaded; labeling will be weatherproof and all writing and/or makings
will be with a weatherproof marker.
lf it becomes necessary to temporarily store impacted soil on the ground, it will be stockpiled in
a manner so as not to spread contaminants to other soils or to surface water thrcugh run-
on/runoff. Specifically, stockpiled soil will be protected by placement into a containment cell
which shall be constructed of a double layer of 10-mil polyethylene sheeting sunounded by a
perimeter earthen berm. Contaminated soil shall be placed in the containment cell and covered
with a single layer of 1O-mil polyethylene sheeting that extends over the perimeter berm and is
secured with clean soil or other material. A containment cell will not be constructed on top of or
adjacent to a drainage swale, drop inlet, or other stormwater conveyance structure. Stockpiling
impacted soil in this manner is not prefened and must be discussed with and approved by
Tenacon priorto being performed.
2.3 PerformanceVerification Sampling
At the conclusion of excavation activities, Tenacon will collect samples from the base and
sidewalls of each excavated Zone. Samples collected from Zones 1 and 2 will be submitted to a
NC-certified labor:atory for PCB analysis using EPA Method 80824. Samples collected from
Zone 3 will be analyzed for volatile organic compounds (VOCs) using EPA Method 82608. A
minimum of one base sample and four sidewall samples will be collected from each Zone. The
excavations will be bacKilled immediately following performance verification sampling,
irrespective of laboratory results.
As a qualig control measure, one duplicate sample will be collected from each Zone and willbe
submifted along with the primary samples to be analyzed using the appropriate test method. A
trip blank, prepared by the laboratory, will accompany the samples collected for VOG analysis
and will also be analyzed for VOCs.
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lnitia! Abatement Plan
lnternational Resistive Company, lnc. :: Boone, Watauga Co., NC
October 3,2012 s Terracon Project No. 86127103
Tferratron
2.4 Backfilling
Offsite bonow materialwill be utilized to backfill excavations. This material will be substantially
free of rocks, roots, and other miscellaneous debris and will be prequalified for use at the site by
collecting a representative sample of the material and submitting it for laboratory analysis for the
full Priority Pollutants list established by the US Environmental Protection Agency (EPA).
Results from this testing will be evaluated by Terracon to assess the suitability of the material
for use on the site.
At the completion of excavation and immediately following performance verification sampling,
each excavation will be bacKilled with fill material imported from the prequalified offsite location.
BacKill will be placed in the excavations in approximate one-foot lifts and compacted to the
proposed grade. Compaction will be performed using a vibratory roller, tamp, or other device
sufficient to achieve compaction that is equal to 95 percent of the Standard Proctor maximum
dry density
2.5 Waste Characterization and Disposa!
2.5.1 Waste Gharacterization
Samples will be collected from each roll-off container and submifted to a NC-certified laboratory
for analysis. Samples collected from rolloffs containing soil from Zones 1 and 2 will be
analyzed for PCBs using EPA Method 8082A. Samples collec{ed from roll-offs containing soil
from Zone 3 will be analyzed for VOCs (EPA Method 82608) using the toxicity characteristic
leaching procedure (TCLP).
2.5.2 Waste Disposal
The laboratory results will be compared to the regulatory levels appropriate for the contaminant
when determining the appropriate destination for the waste.
2.5.2.1 PCB lmpacted Soil (Zones 1 and 2)
Soilcontaining PCBs at concentrations less than 50 parts per million (ppm) may be disposed at
a municipalsolid waste (i.e., RCRA Subtitle D) landfill. Soilcontaining PGBs at concentrations
equal to or greater than 50 ppm must be disposed of in a Toxic Substances Control Act (TSCA)
incinenator or chemical waste landfill.
4Responsive r Resourceful r Reliable
lnitial Abatement Plan
lnternational Resistive Company, lnc. n Boone, Watauga Co., NC
October 3,2012 s Terracon Project No.86127103
Tferratron
2.5.2.2 VOC lmpacted Soil (Zone 3)
Soil containing VOCs at concentrations less than the applicable Maximum Concentration of
Contaminants for the Toxicity Characteristic or "TC" (as listed in 40 CFR Paft261-ldentification
and Listing of Hazardous Waste, Secfion 261.24(b) Table 1, 11re0 and as determined by TCLP
testing) may be disposed of at a RCRA Subtitle D landfill that is permitted to accept such
material. lf the soil contains VOGs in excess of the applicable TCs ffor example, the TC limit for
PCE is 0.700 milligrams per liter (mg/L)l then it will be declared a characteristic hazardous
waste and will be managed accordingly.
3.0 WORKER HEALTH AND SAFETY
Worker health and safety will be the responsibility of the remedial oontr:actor selected to perform
the work. The contractor shall be solely responsible for the development of and compliance
with its own health and safety plan (HASP), as required under 29 CFR 1910.120, for the work
performed.
The primary hazards are those associated with energized electrical equipment and lines,
pressurized piping, and general construction activities including open excavations and working
with heavy equipment. Additional hazards may arise if excavation activities encounter
significantly contaminated media, unknown tanks or buried containers, or other unknown
structures. The contractor's HASP should address these potential hazards in addition to
construction-related haza rds.
All onsite Terracon personnel will follow the requirements of a site-specific Tenacon HASP
which will be developed with specific application to this project.
4.4 FIELD DOCUMENTATION AND REPORTING
Site activities will be documented by Tenacon field personnel in a permanently-bound,
dedicated field logbook. The field log will consist of notes and drawings describing the location,
field conditions, method of sample collection, and sample identification. All field operations and
sample custody records will be recorded in the field logbook. Terracon personnel will also
photodocument site activities and recod the general content of each photo in the logbook.
At the beginning of each entry, the date, time, perconne! present, and identification of the
activity to be described will be noted. All measurements made and samples collected will be
recorded in the field logbook. Personnelwill also note any activities performed at variance with
the procedures described herein and will provide an explanation of why those variances
occurred.
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lnitial Abatement Plan
lnternational Resistive Company, lnc. e Boone, Watauga Co., NC
October 3,2012 n Terracon Proiect No.86127103
Tfenracon
Upon completion of the initial abatement measures, a summary report will be prepared to
document site activities. This report will include a site map depicting the areas of excavation,
location of samples collected, a summary of sampling results, documentation of waste
charatdenzation and disposal, and recommendations for additional action, if appropriate.
Copies of disposal manifests, disposal facility weight tickets, and laboratory data reports will be
appended to the report.
5.0 LIMITATIONS
This report has been prepared for the exclusive use of lnternational Resistive Company, lnc.
(lRC) and any use or reliance by another party (except a governmental entity having jurisdiction
over the site) is prohibited without the express written authorization of IRC and Terracon. Any
unauthorized distribution or reuse is at IRC's sole risk. Notwithstanding the foregoing, reliance
by authorized parties will be subject to the terms, conditions, and limitations stated in the
proposal and Terracon's Agreement for Services. The limitation of liability defined in the terms
and conditions is the aggregate limit of Tenacon's liability to IRC and all relying parties unless
otherwise agreed in writing.
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llbnacon
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