18050_Cenco_ FILE DOCKET 02041992-OCR

•
Mr. Lawrence Wellington
April 19, 1991
Page 2
•
2) Disposal of the decontamination rinsewater must be in
compliance with the CMUD Discharge Permit. All sampling
results from the analysis of rinsewater including field and
laboratory blanks must be submitted to this office for
approval.
3) If pumping to lower the water table is required as described in
Appendix F, Section 02200, Part 3.02 of the approved closure
plan, this office must be notified to ensure proper treatment
and disposal of ground water.
4) If CTI plans to use uncontaminated excavation material for
general fill as described in Appendix F, Section 02200, Part 3
of the approved closure plan, then a description of how
contaminated and uncontaminated materials are segregated must be
submitted within thirty (30) days of receipt of this letter.
CTI must show that the excavation material is clean by analyzing
for volatiles, semivolitiles, and TCLP constituents.
5) In Appendix F, Section 02001 of the approved closure plan, the
last line of the section states that samples will be analyzed
for TCLP metals. samples must be tested for all TCLP
constituents. In Section 02200, Part 3.04(A)(l), the backfill
must also be tested for all TCLP constituents.
6) Volume ratios of portland cement or cement kiln dust should be
established per the stabilization Pilot Test described in
Appendix F of the approved closure plan before stabilization of
the sludge in the field begins.
In addition to the inclusion of the above as part of the Closure
Plan, CTI must expand the discussion of soil quality in Section B by
addressing the source of voe contamination in the soil borings from
MW-1 and MW-3, and the contamination in the sludges in Pond 3. This
must be submitted within thirty (30) days of receipt of this letter.
The professional engineer certification of closure must acknowledge
this letter as part of the closure plan and state that the above
provisions were included in the review of the closure. Referencing
this letter will be considered adequate acknowledgement. Any
variation from the approved closure plan will result in enforcement
action.
•
Mr. Lawrence Wellington
April 19, 1991
Page 3
•
Please note that an approval decision on the post-closure plan will
be made at a later date. lf you have any questions please contact
Katherine O'Neal at [phone].
sincerely,
/~-/$, tfU'~~ I:'~
Jerome H. Rhodes, Chief
Hazardous Waste Section
JHR/KLO/mb/20-22
cc: James H. Scarbrough, EPA
Marc L. Fleischaker
John Doyle, Jr.
Gary L. Honbarrier
William F. Hamner
James A. Carter
Robert Glaser
Spring Allen
Katherine L. O'Neal
• •
Clean Closure Plan Comments
Central Transport, Inc.
NCD 060 295 417
Section/Page
B.11
c. 14
E.29
E.30
F-ll
F-13
Comment
The discussion of the soil contamination
beyond the areas of the lagoon concludes
that no consistent pattern of
contamination exists. This discussion
should address the 40 CFR 261 App. VIII
and 40 CFR 264 App. IX hazardous
constituents that were detected in Pond 3
such as napthalene and bisphthalate.
Also, an attempt to explain the presence
of voes at MW-1 and MW-3 should be made.
NC DEHNR should address in relation to the
state order the statements by central
Transport that the waste handled at the
facility is neither a listed nor
characteristic hazardous waste.
The statement suggesting that metals are
naturally occurring should include or
reference data that shows a comparison of
background levels to the highest levels of
App. IX metals detected downgradient for
contaminants of concern.
The absence of a groundwater plume is
contingent upon an explanation of the
non-metal constituents detected at MW-7
and background comparisons per the comment
for E.29.
As noted in the NC DEHNR 10-23-90
comments, the risk assessment to establish
clean up goals should be part of the
closure plan. It should not be submitted
at a later date.
Refer to the Engineering support Branch
Standard Operating Procedures and Quality
Assurance Manual, April l, 1986, App. B
for standard cleaning procedures.
F-19
Table 10
Table 10
App. D-4
General
• •
-2-
The statement that there has been no
release of hazardous constituents to
groundwater based on sampling is
contingent upon a background metals
comparison and an explanation of
pthalates, voes and phenol contamination
in MW-7. See colll!l1ents on E.29 and E.30.
The hazardous constituents listed in the
clean up criteria should clearly correlate
with the "waste characteristics"
discussions and tables containing the
sludge analysis. currently, App. VIII and
App. IX constituents such as
xylenes(total), napthalene, chrysene, etc.
have been detected in the sludge in Lagoon
l and omitted from the clean up criteria
list.
Note the attached table of soil cleanup
levels which are consistent with the risk
based approach used in the RCRA Facility
Investigation (RFIJ Guidance (May 1989),
Vol. I, Tables 8-6, 8-7. This table was
prepared by EPA Region IV Health
Assessment staff and considers oral
exposure only. Where appropriate, updated
lower levels should be used.
Volume ratios of Portland cement or cement
kiln dust should be established by
demonstration before stabilization of the
sludge in the field begins per the
Stabilization Pilot Test described in App.
F.
The railroad line should be considered as
a possible source of contamination from
polyaromatic hydrocarbons associated with
creosote treated railroad ties.
• /:;·$\Al''i'~·~ " .. ~~y;~t·;1~1 .. ,~~~. '~ ~-\ \:·~ ~,t.i··il -.L. '· ., '"""'·'" ..-· " ~~ ,,,;..,,, ... ·'
'""''""'"'"·'"''
State of North Carolina
•
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 ·Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary January a, 1991
Mr. James H. Scarbrough, P.E., Chief
RCRA and Federal Facilities Branch
Waste Management Division
US EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Attention: Ms. Camilla Warren
Dear Mr. Scarbrough:
William L. Meyer
Director
Enclosed are copies of Central Transport, Inc. 's original closure
plan, their response to our October 23, 1990 comments, and the
revisions to the closure plan for the hazardous waste surface
impoundments. They will be attempting clean closure.
We would appreciate if you would review and comment on these documents
within thirty (30) days. If you have any questions, please call
Katherine O'Neal at [phone].
sincereO U:t;, ~H. Rhodes, ~ ~~~ous Waste Section
JHR/KLO/mb/4
Enclosures
cc: William F. Hamner
James A. Carter
Katherine L. 0 1Neal
M Equal Opportunity Affirmative Action Employ•:<
• •
William F. Hamner, Head
Permitting Branch
January 4, 1991
Page 2
Three (3) Replacement covers, table of contents
spine label to replace those included in
July 1990 Closure Plan submittal
and
the
Three (3) Complete notebooks which have been updated to
include the replacement sections and figure
described above.
These sections have been updated to incorporate comments made in
the following correspondence:
October 23, 1990 letter from James A. Carter
November 20, 1990 response from OBG
December 11, 1990 acknowledgement from your office
As you are aware, OBG, on behalf of Central Transport, Inc. is
working with Mr. Robert Glaser, Hydrogeologist to complete a ground
water investigation designed to further assess ground water flow
direction and quality at the site. No changes have been made in
the closure plan to address Comment 12 in the October 23, 1990
letter, pending the outcome of this investigation. Revisions to
Section E Ground Water Monitoring will be necessary to
incorporate the results of the investigation.
The following summarizes where changes were made in the closure
plan to address specific comments as numbered in the October 23,
1990, letter:
#1 Representative raw data was provided with the November 20,
1990 response from OBG. The request to include 2-chloroethyl
vinyl ether was incorporated in paragraph F-lb{2)f(ii)
Sampling and Testing Program
#2 See paragraph F-lb(2)b(iv) on Site stabilization sampling and
Testing Program
#3 See paragraph F-lb(2)f(ii) Sampling and Testing Program and
Appendix F, Specification Section 02001
#4 See paragraph F-lb{2)f(i) Contaminated Soils Removal Criteria
#5 See paragraph F-lb(2)c Removal of Structures and F-lb(2)d Off-
Site Disposal
#6 See paragraph F-lb(2)e Backfilling Lagoon Areas and Appendix
F, Specification Section 02200
CHlRlrnl G CcHl
•
William F. Hamner, Head
Permitting Branch
January 4, 1991
Page 3
•
#7 See paragraph F-lc Closure of Disposal Units
#8 See paragraph F-lb(2)f(iii) contaminated
Decontamination Procedures
#9 see paragraph F-lb(2)f(iii) contaminated
Decontamination Procedure
#10 See paragraph F-1 Closure Plan
#ll Figure 7 has been included in this submittal
Equipment
Equipment
#12 See above regarding ongoing hydrogeologic investigation
#13 See paragraph F-2d Inspection Plan and revised Appendix G
#14 See paragraphs F-2 Post-Closure Plan, F-2b Post-closure
Security, F-2f Maintenance Plan, F-3 Notice to Local Land
Authority, and F-4, Notice in Deed.
#15 See paragraph F-2j Post Closure Certification
#16 see paragraph F-7 Post Closure Cost Estimate
Please advise
clarification.
if you require additional information or
Very truly yours,
O'BRIEN & GERE ENGINEERS, INC.
A -25< :5st; ~~B. Rest, P.E.
Vice President
GBR:TLN:
cc; T. L. Norman-OBG
S. P. Shach-OBG
M. A. Wittner-OBG
J. Doyle, Esquire-Weinstein & Sturges, P.A.
M. Fleischaker, Esquire-Arent, Fox Kintner, et al
K-Nam, Esquire-Arent, Fox, Kintner, et al
G. Simpson-Central Transport, Inc.
L. Wellington-Central Transport, Inc.
fYElflltN A GEHL
• • ,.<.~·s;;:i;·.~·~ ~)lt:'T ";.. :ill' ~ ~ilf <;: ~-~~-......... m .. <···
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 ·Raleigh, North Carolina 27611-7687
t~
'1-.~,~~·
James G. Martin, Governor
William W. Cobey, Jr., Secretary
William L. Meyer
Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Lawrence Wellington
~entra:T. Tra:n.sport',i !tic •... ~
600 Melynda Road
December 11, 1990
Charlotte, North Carolina 28208
Re: Lagoon.closure Plan
•NCD046i48540 . W
Dear Mr. Wellington:
This acknowledges receipt on November 21, 1990 of the response to
our comments on the closure plan submitted on your behalf by
O'Brien and Gere Engineers, Inc. These revisions must be
incorporated into the closure plan with the following provisions:
1) The sample of the sludge analysis does not include
2-chloroethyl vinyl ether. This constituent should be
included in future analysis.
2) Discrete samples of stabilized sludge from lagoons 1 and 2
must be taken and the TCLP analysis performed prior to
transport to a Subtitle c landfill.
3) As discussed in the November 2, 1990 conference call, CTI
may test samples for indicator parameters during soil
excavation. In order to verify removal of contaminants to
practical quantitation limits or health based levels as
applicable, CTI must take discrete samples of the remaining
soils and analyze for all volatiles, acid/base/neutral
extractables, and TCLP constituents. The proposed number and
location of samples is adequate.
4) The development of clean up criteria must be based on site
specific conditions, including all constituents remaining in
the soil at this site. This will be reviewed by a state
toxicologist as well as by the EPA, State that the laboratory
results for the soil analysis will be submitted to the
Hazardous Waste section for approval prior to backfilling.
.·
Lawrence Wellington
December 11, 1990
Page 2
•
6) As stated in our comments on the closure plan, CTI must not
use asphalt or materials larger than two inches in diameter as
backfill.
8) The closure plan must specify the decontamination
procedures to be used and the sampling methodology.
12) This item has been addressed in the December 3, 1990
letter from Robert Glaser to Marc Fleischaker, John Doyle, and
Gary llonbarrier.
The remaining items must be incorporated into the closure plan as
stated. The post closure plan will be reviewed when the closure is
nearing completion and will be revised as needed.
A public notice of closure will be placed in The Charlotte Observer
on December 11, 1990. A comment period will run for thirty (30)
days after the appearance of this notice. A public hearing will be
held, if requested. Should a public hearing be held, a public
notice will be made at least thirty (30) days in advance of such a
hearing.
six (6) copies of the revised closure plan must be submitted to
this office on or before January 7, 1990. If you have any question
please contact Katherine O'Neal at [phone].
Sincerely,
~111m{1:~
Permitting Branch
aazardous Waste Section
cc: James a. Scarbrough, EPA
Marc L. Fleischaker
George Rest
James A. carter
Robert Glaser
Spring Allen
Katherine L. O'Neal
• • e,@..lT!{A-L TflN.JSl'6/7. r
l'V CO 01./ i. JI./ 8 S'ID
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 ·Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary December 5, 1990
Legal Ad/Public Notice Section
The Charlotte Observer
PO Box 32188
Charlotte, NC 28232
Dear Sir/Madam:
Please print the enclosed public notice one time in your
newspaper as soon as possible upon receipt of this letter.
©GD
William L. Meyer
Director
You may bill Emil Breckling with the State's Solid Waste
Management Division, PO Box 27687, Raleigh, NC 27611. Also,
please send a copy of the ad and certification that it ran as
scheduled to Mr. Breckling and to Ms. Katherine O'Neal (same
address as Mr. Breckling). For record-keeping procedures, I would
also ask that you please telephone Ms. O'Neal at [phone]
and inform her as to when the ad will appear in The Observer.
If you have any questions, please call me at [phone].
Thank you for your help.
Sincerely,
Steve Reid
Public Information Officer
Solid Waste Management Division
An Equal Opportunity Afftrmative Action Employer
• • •
NOTICE OF CLOSURE
HAZARDOUS WASTE MANAGEMENT UNITS
Central Transport, Inc., located at 600 Melynda Road, Charlotte,
North Carolina, proposes to close two {2) surface impoundments used
to treat and store hazardous wastes. A closure plan is under
review by the North Carolina Department of Environment, Health, and
Natural Resources, Hazardous Waste Section. Within thirty (30)
days of the date of publication of this notice, any person may
submit written comments and request modification of the closure
plan or request a hearing.
A copy of the closure plan can be reviewed during office hours
(8:00 a.m. to 4:00 p.m.) Monday through Friday at the Hazardous
Waste Section, 401 Oberlin Road, Suite 150, Raleigh, North
Carolina 27605. Any persons with questions or comments regarding
the closure plan should contact Ms. Katherine O"Neal in Raleigh at
[phone].
12/5/90
KLO
• •
James A. Carter, Environmental Supervisor
November 20, 1990
Page 2
c. Soil sample results from September 1989. Attached are
copies of metals, pesticides, PCB's, acid extractables,
base/neutral extractables, and volatile analyses
performed by Martel Laboratory Services, Inc.
d. Ground water sample results from November 1989. Attached
are copies of metals, pesticides, PCB's, acid
extractables, base/neutral extractables, and volatile
analyses performed by Martel Laboratory Services, Inc.
e. Lagoon surface water sample results from October 1989.
Attached are copies of BOD, metals, Ph, total suspended
solids, volatiles, acid and base/neutral extractable
analytical results performed by IEA Laboratory in
connection with CMUD discharge permit compliance
monitoring.
The attached analytical results demonstrate that sufficient
chemical analyses have been performed on soils, ground water,
and sludge to assess the presence of hazardous constituents.
2. Attached are copies of the TCLP analyses that were performed
in October 1989 on six sludge samples. The samples were
composited from three different areas of Lagoon 1. TCLP
extracts followed by GC/MS analyses were performed on
composited samples. Of the 40 constituents which are
regulated by the TCLP, only four compounds were detected in
the sample above the detection limit of 0.05 milligrams per
liter. These four constituents were present in the samples at
concentrations which are less than 2% of the regulatory
threshold limit. Given these facts, it l.S clear that
individual samples would not have exceeded regulatory
threshold limits. Discrete samples of stabilized sludge will
be taken and TCLP analysis performed prior to transport to the
disposal facility.
3. Section Nine of the Environmental Protection Agency
publication SW-846, entitled Test Methods for Evaluating Solid
Waste, Third Edition describes a statistical method for
determining the number of samples of a solid waste required to
characterize the physical and chemical properties of the
waste. This section provides the equations for calculating
the sample mean, sample variance the appropriate number of
samples to collect. The variables in the formulae require
some previous knowledge of the characteristics of the waste to
determine the number of samples which are to be taken. One of
the formula variables is the regulatory threshold
concentration for the known contaminants. Analyses of the
waste that have been performed on the lagoon sludges together
O'BRIEN & C~cRc
•
James A. carter, Environmental Supervisor
November 20, 1990
Page 3
•
with the health based clean up criteria included in the RCRA
Facilities Investigation Manual were used to perform this
statistical analysis. Using the SW-846 formula, a minimum of
three samples per lagoon are recommended. Based on this, CTI
proposes to divide each lagoon into quadrants and take one
discrete sample from the bottom of each quadrant and one
discrete sample from the side of each quadrant for a total of
eight ( 8) samples per lagoon. Eight samples have been
proposed so that the volume of additional excavated soil can
be minimized. With your concurrence, the Closure plan will
be modified accordingly.
4. The clean up criteria presented in Table 10 of the Closure
Plan were derived from two sources: the December 1987 Draft
RCRA Facilities Investigation Manual, and the May 1989 RCRA
Facilities Investigation Manual. The revised Closure Plan
will incorporate information from the Corrective Action for
Solid Waste Management Units at Hazardous Waste Management
Facilities proposed rule as published in the July 27, 1990,
Federal Register. All three sources present health and
environmental clean up levels for hazardous constituents in
soil. The concentrations recommended in these sources for
each constituent are derived from EPA established chronic and
acute toxicity criteria for ingestion or inhalation exposure
routes. The recommended concentrations were calculated by EPA
using identical intake assumptions as the sample document
provided by your office. Inquiries to the USEPA in
Washington, D.C., specifically Mr. David Fagan, Office of
Solid Waste, Permits and State Programs section, confirmed
that clean closure is defined as "clean up to health based
levels." Based on o' Brien & Gere' s understanding of the
applicability of the three sources cited above, a review of
the methodology used in preparing the sample document provided
by your office, and information provided by Mr. Fagan, the
clean up criteria presented in Table lo should be adopted.
5. Contaminated soils, sludges and structures will be stockpiled
in manner that will prevent a release to the environment using
roll-off boxes or other suitable means. The selected
contractor will be required to submit his plans for
eliminating a release to O'Brien & Gere for review prior to
commencing the work.
6. In order to demonstrate that no contaminated materials will be
used as backfill, the contractor will be required to submit
his source for fill for approval to O'Brien & Gere prior to
beginning to backfill. If documentation confirming that clean
fill is being used is not provided, the Contractor will be
rl'BRIEN & c;CRf'
•
James A. Carter, Environmental Supervisor
November 20, 1990
Page 4
•
required to take one sample of fill per 50 cubic yards and
analyze for the clean up criteria constituents and submit the
results tor review by O'Brien & Gere prior to placement of the
fill.
7. The closure plan will be modified to include language that
describes what action will be taken in the event that clean
closure is not possible. This language will confirm that, if
clean closure is not possible, Central Transport intends to
comply with the requirements of 40 CFR 265.228(a) (2) including
such items as providing a RCRA cap.
a. The closure plan requires the contractor to decontaminate all
structures and equipment. A sample of the rinsewater will be
analyzed to verify that the decontamination has been completed
using the methodology outlined in your October 23 letter.
9. Concrete walls and structures of the lagoons will be
decontaminated as described in paragraph 8 above. Any
equipment that cannot be confirmed to be cleaned to the
standards described in your October 23 letter will be disposed
of as hazardous waste.
10. The closure plan will be modified to include language that
confirms that changes to the approved closure plan will be
submitted to the Hazardous Waste Section. No changes will be
executed without approval by that section.
11. Page 54 of the Closure Plan references Figure 7. A figure
similar to Figure 6 in the November 1990 Supplemental
Hydrogeologic Investigation Report will be included in the
revised closure plan.
12. The data reported in the June 1990 Report of Hydrogeologic
Investigation and the November 1990 Supplemental Report does
not provide conclusive evidence as to whether MW-7 is an
upgradient or downgradient well. Additional quarterly ground
water sampling and water level measurements which will
include MW-7, should provide sufficient data to clarify this
issue. Four background moni taring wells and three
downgradient monitoring wells will be sampled during the term
of post closure monitoring. A letter to Robert L. Glaser
dated November 19, 1990, prepared by Marc L. Fleischaker,
Esquire of Arent, Fox, Kintner, Plotkin and Kahn provides
additional information on the resolution of this comment.
Ci'nRIEN & GCRF
• •
James A. Carter, Environmental Supervisor
November 20, 1990
Page 5
13. The quarterly inspection log will be amended to include
inspection of the condition of ground water monitoring wells.
specifically, the following items will be checked:
a) protective metal casing
b) lock
c) well casing
d) well cap
e) cement pad
f) well identification number
g) well reference mark for measuring ground water
elevation
h) depth of well
i) turbidity of ground water samples
j) changes in ground water flow into well during well
purging
kl changes in static ground water elevation
In the event that repairs to the wells become necessary, these
repairs will be conducted in accordance with standard
protocols and with the approval of the state of North
Carolina. With your concurrence, the closure Plan will be
modified accordingly.
14. CTI understands that, if clean closure is not feasible, a
maintenance plan, post-closure security, survey plan and
notice to local land zoning authority and notice in deed to
the property will be provided. The Closure plan will be
modified to include such language.
15. CTI will provide post-closure certification in accordance with
40 CFR 265.120.
16. The post closure period of three years assumes that a clean
closure is being performed. If 1 after completion of the
quarterly groundwater sampling, and removal of soils and
confirmatory clean sampling it appears that a clean closure
can not be accomplished, CTI agrees to perform post-closure
care in accordance with 40 CFR 265.117.
The revisions outlined in this letter will be made and a revised
closure/post closure plan prepared upon receipt of your comments to
the proposed changes contained in this letter. The revised Plan
will be submitted promptly to the Department for your further
review and comment.
CJ"nRIEN & Gi::RE
•
James A. Carter, Environmental Supervisor
November 20, 1990
Page 6
•
Please advise if you require additional
clarification on the above responses.
Very truly yours,
O'BRIEN & GERE ENGINEERS, INC.
'l'LN:GBR:dmh
cc: M. Fleischaker, Esquire
J. Doyle, Esquire
K. Nam, Esquire
'!'. Norman
s. Shach
M. Wittner
Enclosures:
information or
U'FJRIEN & GERc
~
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•••REMARKS•••
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•"•REMARKS•••
. . • • • • •••
, ~ __ , ..
•A-AVERAGE VALUE •NA-NOT ANALYZED •NAl-INTERFERENCES •J-ESTJMATED VALUE •N-PRESUMPT!VE EVIDENCE OF PRESENCE Of r.IATERJAL •K-ACIUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN •L-ACTUAL VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN 0U-lilAIERJAL WAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER JS THE MINIMUM OUANTITATION LIMIT.
\l 3 / L/
---------------------------------·--------......... 1 ..... ........_,. .... ,
.. ,.,,~,,.-·•·• ... ,._.. .... x: sz::c~·~,,..,,.._ . ....,.....,.., P ................ .,...... cs e > ' .. .........,,
I
. .
•• C 0 N f l 0 E N T I A L •• SAMl'LE AND ANALYSIS MANAGEMfNT SVSTtM EPA-REGION IV ESD, ATHENS, GA.
••• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •• PROJECT NO. 88-264 SAMPLE NO. 24215 SAMPLE TVPE: LAGOCINWATE
DATA REPORT MISCELLANEOUS EXTRACTABLE COMPOUNDS -. . . . . . . . . . . . . . . . . . . . . . .. .. ... PROG ELEM: SSf COLLECTED BY: 80!<.EV/THQMAN/MU C !TY: CHARLOTTE ST: NC COLLECTION START: 03/22/88 oeso STOP: 00/00/00
fM./!:"Jil-;M
• • • ...
.. •• SOURCE: CENTRAL TRANSPORT •• STATlON 10: CTL-SW LAGOON 3
•••••••••••••••••••••••••••••••••••••••••••••
..................... ~·· ..
Rf SUL TS UN ITS COMPOUND
RESULTS UNITS 20J UG/L
COMPOUND UNIDENTIFIED COMPOUND •
•
•
, ~ .... •':..
•••FOOTNOTfS••• •A-AVERAGE VALUE •NA-NOT ANALYZED •NAl-!NTERfERENCES •J-ESTJMATEO VALUE •N-PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
•K-ACTUAL VALUE JS KNOWN TO Bf LESS THAN VALUE GIVEN •L-ACTUAL VALUE 15 KNOWN TO Bf GREATER THAN VALUE GIVEN
•U-MATERIAL WAS ANALYZED FOR BUT NOT DfTfCTEO. THE NUMBER IS THE MINIMUM QUANTITAT!ON L!M!T. •R-OC INDICATES !HAT DATA UNUSABLE. COMPOUND l/IAV OR MAY NOT BE PRESENT. RESAMPLING AND REANALYSIS JS NECESSARY FOR VERJFICATION.
, ~-----------~ '-1 /Lf
I • '
•
.
•• C 0 N f I 0 E N T I A L ••
PESTJC!OES/PCB'S OATA REPORT
SAMPlE ANO ANALYSIS MANAGEMENT SVSllM EPA-REGION JV ESO, ATHENS, GA.
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • PROJfCT NO. 88-264 SA.Ml'LE NO. 24215 SAMPLE TYPE: LAGOONWATE
. . . . . . .. . . .. . . . . . . .. . . . . .. . . ..
PROG ELEM: SSf COLLECTED BY: BOl<EV/Tl'IOIUoN/~U CITY: CHARLOTTE ST: NC COLLECTION START: 03/22/811 0850 STOP: 00/00/00 •••
0-lll•IM
• • •
•• •• •• •• •••
SOURCE: CENTRAL TRANSPORT STATION ID: CTL-SW LAGOON 3
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • UG/L ANALYTICAL RESULTS
. .. .. .. .. .. ...
<•GIL ANALYTICAL RESULTS
0.029U 0.027U o.021u o.021u 0.027U 0.027U 0.050U 0.027U 0.027U
0.071 u 0.044U 0. 071 u 0.029U
0.029U 0.07\U 0.22U 0,47U
0.47U 0.41U
ALDRIN HEPTACHLOR HEPTACHLOR EPOX!OE
ALPHA-BHC BETA-8HC GAMMA-BHC (LINDANE)
DELTA-BHC ENOOSULfAN 1 (ALPHA)
O!fLORlN 4,4•-oor <P.P•-ooT> 4,4'-0DE (P.P•-OOE)
4.4'-000 (P.P'-OODJ
ENDRIN ENOOSULFAN II !BETA) ENOOSULfAN SULFATE CHLORDANE (TECH. MJXTUREl PCB-1242 (AROCLOR 1242) PCB-1254 (AROCLOR 1254) PCB-1221 (AROCLOR 1221)
•••REMARKS•••
/1
0.47U 0.4/U 0.47U 0.47U
1. 7U
0. 13U 0.044U
PCB-1232 (AROCLOR 1232) PCB-1248 (AROCLOR 1248) PCD-1260 (AROCLOR 1250) PCB-1016 (AROCLOR 1016)
TOXAPHENE CHLORDENE /2 ALPHA-._CHLOROENE /2 BETA ~ttLOROENE /2 GAMMA-CHLOROENE /2 \-HVOROXVCHLORDENE /2 GAMMA-CHLORDANE /2 TRANS-NONACHLOR /2 ALPHA-CHLORDANE /2 CJS-NONACHLOR /2 OXYCHLOROANE COCTACHLOREPOXIOEl
METHOXYCHLOR
E NOR IN KETONE
•••AEMARK.S•••
{2
.... -. ..... _
•
•••FOOTNOTES••• •A-AV[RAGE VALUE •NA-NOT ANALYZED •NA!-!NTERFERENCES •J-ESTIMATED VALUE •N-PRESUMPT!VE EVIDENCE OF PRESENCE OF MATERIAL
•K-ACTUAL VALUE IS KNOWN TO DE LESS THAN VALUE GIVEN •L-ACTUAL VALUE !5 KNOWN TO Bf GREATER THAN VALUE GIVEN •u-MATERIAL WAS ANALYZED FOR BUT NOT OETfCTEO. THE NUMBER IS THE MINIMUM QUANTITATlON L!MIT. C-CONFJRMEO av CC/MS I. WHEN NO VALUE IS REPORTED, SEE CHLORDANE CONSTITUENTS. 2. CONSTITUENTS OR META60\.ITES Of TECHNICAL CHLORDANE.
• Hartel Laboratory Serv&s
DATA FILENAME:)FSS32::D6
SAHPLE_lD: 6249 HW-1
MISC DATA: 11-27-89
ANALYSIS TIHE:12/01/89
ANALYST: MANAGER
UNITS: PPB
AE
OBRIEN
2:34
SUPER GRP.
COMPOUND Std Detection
Phenol
2-Chlorophenol
2-Nitrophenol
2,4-Dimethylphenol
2,4-Dichlorophenol
4-Chloro-3-methylphenol
2,4,6-Trichlorophenol
2,4-Dinitrophenol
4-NITROPHENOL
4,6-Dinitro-2-methylphenol
PENTACHLOROPHENOL
urrogate Spike (\ recovery)
2-Fluorophenol
Limit
(1
(1
(2
(1
(1
<1
<1
(5
<1
<5
<1
CONC
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
3\5
230 (120\)
·M~RTEL • CertificatAt Laboratory Analysis
MARTEL LABORATORY SERVICES. INC 102~) Cromv;f-''! 8r1d9e ROf,C Rc.it1m01(· ~~' (il'·,.::; ::11 ~)(;.; • -' ' , e~; · i' i' ~·-·,
Page No. 7 5SJ;:'(! ND'.P; E;(,:'. $u1H· 1i~ H~·uf.l(1~ iE·,-;::' 7/3~J·:) c'';:·· .:.'.·.~ff•.'~
12/18/89 Cap!t8! A1:r~\:'. s~\(lr"19l1c:::: l~i~T\(>•S f.~1·-:-:1 • (~'i I)~!~::·''.'·'."''·
EPA Priority Pollutant Analysis
Analytical Parameter
•• Base/Neutral Extractables
' CTI-51, TCLP Extract
N-Nitrosodimethylamiri~
Pis (2-Chloroethyl) Ether
1,3-Dicbl0r0benzene
1,4-Dichlorobenzene
1,2-Dichlorobenzene
Bis (2-Chloroisopropyl) Ether
Eexachloroethane
N-N1troso-Di-n-Propylamine
N 1 tr obt.r,zene
l :.0pj·,coi c.r,e
Ei $ { 2-Ch~wl veLL<J;._J: 1·~etl·JF~l1~
1,2,,-Trichlor0benzene
NapLtJ-,f.le11e
~ex5ct~o~01:~uta6iene
HE·~~ ~.C"l".1 l or Ct:"~'i:': 7 I-'i?t t ,-, /!ii:-:.~
2-~~=~~~1 ~ar~t~=~e~~
Acer_'.°" I>~~"'; !'-1 y l E"-'. -
Dimethyl Ph!hel3te
2,6-Dinitrotoluene
F.-:-enaphthene
2,4-Dinitrotcluene
Fl uc,renE'
Diethyl Phth&late
4-Chloroih0 nyl PhePyl Ether
N-Nitrosodiphenylamine
1.~-Diphenylhydrazine
4-Bromophenyl Phenyl Ether
H£xachlorobeczene
Phena!ltrirer;e
Ar<:hracene
Di-n-Butyl Phthalate
Fl ucrantriene
Benzidine
?yren€·
Butyl Benzyl ?hthalate
Benzo {a) Anthracene
3,3-Dichlorcbe~zidin~
Chryserie
Bis {2-Ethylhexyl) Phthalate
Di-n-Octyl Phthalatt.
Ber,zo (a) ?yrene
Indeno (1,2,3-cd) Pyrene
Diber.zo {a,hj J,,nthracene
Benzo {g,h,ij ?ezylene
FAtJeilzcf?\b'.lFk) Fluoranth<0me
A GE-~EX (;(!l"i"l[\;i ·,,
Result
i::
ND
li Ii
I~ ::i
1rn
l~L
l~l;
ND
~Ij
I~ I.
I~ r:
Nt
;~j
ND
KD
t'D
l"l'
Nr:1
ND
Nf· rm
ND
ND
NI:
ND
ND
ND
ND
ND
ND
1
ND
ND
ND
4
ND
ND
ND
47
4
ND
ND
ND
ND
ND
D~tection Units
Limit
l
:::
" l
1
1
2
1
1
1
1
l
' 1
1
' 1
2
1
1
1
1
10
1
1
1
2
1
10
1
J.
2
2
2
2
ug/l
u9/J.
ug/l
ug/~
ug/~
ug/l
.,9/ l
' -U9/J
ug/1
ug/l
ug/l
i.;g/.i
ug/l
Ug/l
ugll
ug /'
1HJ/l
ug/2
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
ug/1
ug/l
ug/1
ug/l
ug/l
ug/;
ug/l
lig/ 1
" US/..:.
ug/l
ug/l
ug/l
Ug/l
ug/l
ug/l
Ug/l
ug/l
• •
CENTRAL TRANSPORT, INC.
COMMENTS ON CLOSURE PLAN
-1) Provide a list of all materials handled at the facility and all
materials hauled in trucks that were cleaned at the facility.
Analysis of sludge, groundwater, and soil samples must include all of
these constituents.
2) Identify the waste sludge as hazardous by the constituents
handled at the facility and found in the sludge. In addition, the
TCLP analysis must be performed on discrete independent samples.
Samples must not be composited. The sludges and contaminated soils
must be managed as hazardous waste in accordance with 40 CFR
265.228(a)(l).
3) Soil samples must not be composited as described in Appendix F.
Discrete independent samples must be collected from each quadrant
floor and wall. In addition, the sample testing must include all
volatiles, acid/base/neutral extractables, and the TCLP analysis.
4) CTI must remove all contaminated soil down to levels below
detection limits for all constituents (volatiles, acid/base/neutral
extractables, TCLP) or develop a risk assessment for any hazardous
constituent remaining in the soils. The risk assessment will be
reviewed by a state toxicologist. CTI must show that all
contamination is removed from lagoons 1 and 2 and that groundwater is
not contaminated in order to obtain a clean closure. Submit the
laboratory results to the Hazardous Waste Section for approval prior
to backfilling.
5) All contaminated sludges, structures, and soils must be
stockpiled in a manner that will prevent a release to the
environment. Explain how this will be accomplished during closure
activities.
6) Show that no contaminated materials will be used as backfill. In
addition, asphalt and materials larger than two inches should not be
used as backfill.
7) If CTI is unable to remove all contaminated soils and structures
the lagoon(s) must be closed as a landfill in accordance with 40 CFR
265.228(a)(2). CTI must then propose a cap that meets the
specifications in EPA/530-SW-89-047, Final Covers On Hazardous Waste
1.imt;'lfills And Su_rface ImpounQ.mentJ?., and perform. post-closure care.
8) All contaminated structures and equipment must be decontaminated
by steam cleaning or a high pressure detergent wash. The
decontamination pad must be designed in a manner that will prevent a
release to the environment. The rinsewater must be collected and
sampled in order to verify decontamination. The equipment and
structures will be considered decontaminated when the
• •
concentrations of all constituents are below the detection limits
recommended in SW-846 or below drinking water standards where these
exist.
9) The concrete walls and any other structures must be cleaned to
the above standards or disposed of as hazardous waste. Any equipment
used that is not decontaminated by the above standards must be
disposed of as hazardous waste.
10) State that any proposed changes from the approved closure plan
will be verified with the Hazardous Waste Section before the changes
are executed.
COMMENTS ON POST-CLOSURE PLAN
11) on page 54, Figure 7 is referenced but was not provided.
12) Post-closure monitoring must include well MW-7. Also, CTI must
analyze for all volatiles, acid/base/neutral extractables, and
metals.
13) Possible problems with the groundwater monitoring wells can
occur including, but not limited to, cracking of the cement collar,
clogging of the well screen, damage from equipment, etc. Provide for
the inspection for possible problems and discuss how they will be
repaired. Include problems to monitor for in the inspection
checklist.
14) The following will be required if CTI is unable to remove all
contaminated structures and soils and must close as a landfill with
waste in place:
a) a maintenance plan meeting the requirements in 40 CFR
265.117(a)(l), 265.118(c)(2), and 265.228(b).
b) post-closure security in accordance with 40 CFR 265.117(b)
c) a survey plat in accordance with 40 CFR 265.116.
d) notice to local land zoning authority and notice in deed to
property in accordance with 40 CFR 265.119.
15) CTI must provide post-closure certification in accordance with
40 CFR 265.120.
16) A post-closure care period of three years is assumed. If the
units are closed as landfills, CTI will be required to perform
post-closure care in accordance with 40 CFR 265.117 as referenced in
ISA NCAC 13A .0010 until such time as a post closure permit
application is called.
•.• ;r~·.
'\..
Arent, Fox, Kintner, Plotkin & Kahn
Mr. Jerry Rhodes
September 19, 1990
Page 2
•
with the closure plan. We look forward to hearing from you
soon.
MLF:kmm
Enclosure
cc: Mr. Glen Simpson
John J. Doyle, Jr., Esq.
George B. Rest, P.E.
Ms. Terry L. Caton
Katherine H. Nam, Esq.
Sincerely,
~(~·~
Marc L. fJ{f;.;baker
."!'· • - 1 -•
POST-CLOSURE PLAN CHECKLIST
I. WRITTEN PLAN
* 1. Is there a written POST-CLOSURE PLAN YES NO N/A
at the facility? (40 CFR 265.llB(a))
If answer is "N/A" skip to cost estiinate
checklists.
2. Does the post-closure plan cover the
MAXIMUM AREA EXPECTED TO CONTAIN
HAZARDOUS WASTE after closure, including:
a. landfills? YES NO N/A
b. disposal surface impoundments? YES NO N/A
c. land treatment faci.lities where YES NO N/A
hazardous waste will remain?
d. other remaining hazardous wastes? YES NO N/A
* 3. Does the post-closure plan provide for YES NO
30 years of post-closure care?
(40 CFR 265. ll7(a)) •. How many years of post-closure
C4re7
4. Does the post-closure plan cover all YES NO
areas where hazardous waste will remain.
that were active as of· ll/19/80?
II. SPECIFIC POST-CLOSURE PLAN REQUIREMENTS
* 1. Does the plan clearly identify the YES NO
ACTIVITIES required in post-closure care?
. (40 CFR 265 .118 (a))
* 2. Does the plan clearly identi£y the YES NO
FREQUENCIES for post-closure activit.ies.?
See also Question 5. (40 CFR 265.ll8(a))
* 3. Do the GROUNDWATER MONITORING plans (40
CFR 265.ll7(a)(l); 265.ll8(a)(l)) include:
a. number of wells? YES NO
h. sample collection activities? YES NO
c. sample collection frequencies? YES NO
d. sample test activities? YES NO
e. sample test frequencies? YES NO
f. replacement of failed wells? YES NO N/A
I
• - 4 • .
.. .
""
(5) Characteristics of the cover, including YES NO N/A
material, final. surface contour, thick-
ness, porosity, pe:i:meability, slope,
vegetation.
(6) Geological and soil p;:oriles and YES NO N/A
s=face and subsurlace hycb:ology.
(7) Unsict:=ated. .zone monitcti.ng. YES NO N/A
(8) TyPe, concentration, and depth of YES NO N/A
hazardous constituent migl:ation as
compared "to background concentrations.
III. OTHER REQUIREMENTS
* 1. Does the plan address the -requirement. YES NO
for notice to the local land aut:hotity?
(40 CFR 2.65 .119)
* 2. Does the 'plan address the requ:Lrement YES NO
~or notice in the deed? (40 CFR 265.120)
3. Does the plan address zhe proi:ect.ion and "YES NO N/A
maintenance of surveyed benchmarks?
IV. COMMENTS"
.··.f ...
Page 2
c.
1.
2.
3.
• •
Date all waste will be removed, treated, or disposed
of on-site. Note that this must be within 90 days
of the above.
Date when equipment will all be decontaminated.
Date when any remedial action
necessary (such as removal of
for example.)
will be finished, if
contaminated earth,
Dates of any interim inspections by professional
engineer, if needed.
Date of final certifications of closure, by a
company officer and by an indepe.ndent professional/
engineer ..
(Note that this must be within 180 days of start of
closure.)
Description of actual operations in closure.
Mode of ultimate disposal of each type of waste.
Name of proposed rec:eiver of each type of waste.
v"'
,I'
Name of proposed transporter to be used. ,/
4. Description of sampling techniques and analyses to
5.
6.
7.
8.
be performed, particularly as related to checking /
for contamination.
Procedures to be used in cleaning up any equipment ,/'
used.
Procedures that will be used in any remedial actions.
(For example if soil contamination is found). ;,,;'
Procedures to be used to clean up storage tanks and/
lines.
Other
Page 3
D.
1.
2.
3.
4.
5.
6,
7.
8.
• •
Cost estimate
Assumption of "worst possible case.
(a) Maximum amount of waste on site.
(b) so that it
(Involves
reasonable
Company not able to perform work,.
is done by an outside contractor.
labor charges for contractor, plus
supervisory charges,)
(Man-hours x rate per hour) ./
Transporter's charges. (Assume this will be done
by outsiders also.) (No. of loaded trucks x miles /
to disposer x charge per mile) "
Outside analyst's charges,
Disposer's or treater's charges, (Such as no. of
drums landfilled x charge per drum).
Charges, if any, for materials and equipment used
in decontamination.
Fees to professional engineer for final
certification, plus interim inspections, if any.
Total for all closure costs.
Allowance for inflation. (For 1983, use the
factor 1.09.)
.,,/
./
,/
The compliance date for filing a revised plan with our office is
hereby set at January 14, 1984. It should be sent to my attention at our
office on or before this date.
If you hsve any questions, please contact me at 919/733-2178.
KL:dws
DHS Form 3199 12/83
Solid & Haz. Waste Mgt. Branch
Very sincerely,
/'(~~
Keith Lawson
Chemical Consultant
Solid & Hazardous Waste Mgt. Branch
North Carolina De,tment of Human Resources • 4-7-83
yage"--2"-~~~~~~~~~~~~~~~~~~~-
Central Transport, Inc.
500 Melynda Road
Charlotte, NC 28208
EPA IDll NCD046148540
Closure Cost $25,000.00
Post-closure Cost $3,000.00
3. In states outside of North Carolina where EPA or some designated
authority is administering the financial requirements, this
fir.m; as owner or ope~ator or guarantor, is demonstrating
financial assurance for the closure or post~closure care of
the following facilities through the financial test and/or
corporate guarantee specified in Subpart H of 40 CFR Parts
264 and 265 or through a test equivalent or substantially
equivalent to it. The current closure and/or post-closur~
estimates covered by such a test or guarantee are sl1own for
each fac i 1 i ty:
None
4. This firm is the owner or operator of the following hazardous
waste management facilities for which financial test or any
other financial assurance mechanism specified in Subpart H
of 40 CFR Parts 264 and 265 or equivalent or substantially
equivalent State mechanisms. The current closure and/or
post-closure cost estimates not covered by such financial
assurance are shown for each facility:
None
This firm is not required to file a Form lOK with the Securities and
Exchange Commission (SEC) for the latest fiscal year.
This fiscal year of this firm ends on Dec.,mber 31. The figures for the
following items marked with an asterisk are derived from this firm's
independently audited 1 year-end finafl.cial statements and footnotes for
the latest completed fiscal year, ended December 31, 1982.
Very truly yours,
CENTRAL TRANSPORT, INC.
;:$-?/~/:2:.,,,,' ~
W. . Kivett
Comptroller
WKK:cg
• -4-•
RE UIRED WORDING FOR LETTER FROM CHIEF FINANCIAL OFFICER
40 CFR 2 4. 5 f , ADOPTED IN NORTH CAROLINA AS l ONCACl OF . 0032
ALTERNATIVE II
1. Sum of current closure and post-closure cost estimates
(total of all cost estimates shown in the four para-
graphs above)
$ __ ""'2"'"s.._o""o""o __
2. Current bond rating of most recent issuance of th'is
firm and name of rating service
3. Date of issuance of bond
4. Date of maturity of bond
*5. Tangible net worth (if any portion of the closure and
post-closure cost estimates is included in "total
liabilities" on your firm's financial statements, you
may add the amount of that portion to this line)
*6. Total assets in U.S. (required only if less than 90
percent of firm's assets are located in the U.S.)
7. Is line 5 at least $10 mill ion?
8. Is line 5 at least 6 times 1 ine l?
*9. Are at least 90 percent of firm's assets located
in the U. s.? If not, complete line 10.
10, Is line 6 at least 6 times line l?
N/A
N/A
N/A
$ 11 085 177
$ N/A
Yes No
--"---
NI A --
x --
N/A --
I hereby certify that the wording of this letter is identical to the
wording\t..specified in 40 CFR 264.15l(f), adopted in North Carolina as iONCAClOF
.0032~J~ as such regulations were constituted on the date shown immediately
below. d_,f'//~~ (Signature)?-V~~
(Name) w. K. Kivett
(Title) Comptroller
(Date) 4-7-83
•
Central Transportj Inc.
500 Melynda Road
Charlotte, NC 28208
Closure Plan for Waste Containment Pond
•
1. It is anticipated this waste pond will be closed during the
year 1983.
2. Prior to beginning closure; an approved above groLind mechanical
pre-treatment system will be installed to handle tank truck
washing waste for introduction into the Mecklenburg sanitary
sewer system.
3. After this is in place and operating, the liquid waste from the
containment pond will be processed through this system for disposal.
4. After completely draining containment pond, sludge residue left
in the bottom will be analyzed to determine characteristic of
E P Toxicity. If results indicate sludge to be non toxic, non
corrosive, non reative and non flammable by the standards and
parameters of the E P Toxicity analysis, it will be left in
place and the pond filled in with soil and compacted after
approval from the Department of Human Resources.
5. Three months after closure, monitoring wells will be sampled and
analy?.ed and compared to paramenters previously established.
6, The closure will be completed within the time allowance set forth
by the Department of Human Resources, Solid and Hazardous Waste
Branch,
l