NCD003162542_Badin Business Park_Corrective Action_20180403

Badin Business Park LLC
c/o Alcoa Corporation 201 Isabella Street Suite 500 Pittsburgh, PA 15212-5858 USA Tel: [phone]

April 3, 2018 Mr. Robert C. McDaniel Facility Management Branch Hazardous Waste Section
North Carolina Department of Environmental Quality 1646 Mail Service Center Raleigh, NC 27699-1646 Re: Revised Investigative Work Plan for the Phase 4 And 5 Corrective Measures Study, Alcoa/Badin Landfill, and Former Ball Field Badin Business Park LLC, Badin, North Carolina; EPA ID: NCD 003 162 542 Dear Mr. McDaniel:
Badin Business Park LLC, in care of Alcoa Corporation, respectfully submits the attached revised Investigative Work Plan for the above referenced site for your review and approval. The Work Plan has been revised considering conditions of the January 31, 2018 conditional approval letter and the instream
monitoring study requirements of the September 29, 2017 Final NPDES Permit, Condition A. (8.)
Should you have any questions or comments, please contact Jason Mibroda of Alcoa at [phone] at your convenience.
Sincerely,
Ronald M. Morosky Director, Corporate Remediation Attachment

cc: Teresa Rodriguez, NCDEQ (email) Robyn Gross, Alcoa (email) Jason Mibroda, Alcoa (email) Michael W. Worden, Environeering (email)

ENVIRONEERING, INC.

Investigative Work Plan

For The

Phase 4 And 5 Corrective Measures Study,
Alcoa/Badin Landfill, And Former Ball Field
Badin Business Park LLC
f/k/a Alcoa Badin Works Facility
Badin, North Carolina

Original: April 28, 2017
Revised: April 2, 2018

Prepared for:

Badin Business Park LLC
201 Isabella Street,
Pittsburgh, PA 15212

Prepared by:

ENVIRONEERING, INC.
16100 Cairnway, Suite 320
Houston, Texas 77084
832-674-8800
ENVIRONEERING, INC.

137-262 CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2018 i
TABLE OF CONTENTS

1.0 INTRODUCTION .......................................................................................................................1
1.1 Site Overview ...................................................................................................................1
1.2 Project Objectives ...........................................................................................................2
2.0 SCOPE OF WORK .....................................................................................................................3
2.1 Task 1 – Alcoa/Badin Landfill Area ..............................................................................3
2.1.1 Subtask 1 – Surface Water Assessment ................................................................3
2.1.2 Subtask 2 – Hydrological Conditions Evaluation .................................................4
2.1.3 Subtask 3 – Geophysical Baseline Establishment .................................................6
2.1.4 Subtask 4 – Jurisdictional Determination .............................................................6
2.2 Task 2 – Main Plant Groundwater ................................................................................7
2.3 Task 3 – Additional Former Ball Field Assessment .....................................................7
2.3.1 Subtask 1 – Geophysical Survey ...........................................................................7
2.3.2 Subtask 2 – Surface Soil Assessment....................................................................8
2.3.3 Subtask 3 – Sediment Sample ...............................................................................8
3.0 FIELD PROCEDURES ..............................................................................................................15
3.1 Pressure Datalogger Deployment ..................................................................................15
3.2 Sample Collection Procedures .......................................................................................15
3.2.1 Sample Collection and Decontamination ..............................................................15
3.2.2 Sample Analysis ....................................................................................................18
3.2.3 Field Quality Control ............................................................................................19
3.2.4 Sample Shipment ..................................................................................................19
3.2.5 Chain-Of-Custody .................................................................................................20
3.2.6 Laboratory Quality Control ...................................................................................20
3.3 Geophysical Survey Procedures ....................................................................................20
3.3.1 EM Field Procedures .............................................................................................20
3.3.2 GPR Field Procedures ...........................................................................................21
4.0 SCHEDULE AND REPORTING ..............................................................................................22
4.1 Reporting and Notifications ...........................................................................................22
4.1.1 Quarterly Update Reports .....................................................................................22
4.1.2 Comprehensive Report ..........................................................................................22

LIST OF TABLES

Table 2-1 Task 1-Subtask 2 Selected Wells ............................................................................... 5
Table 3-1 Bottling and Preservative Parameters ...................................................................... 17
Table 3-2 Analytical Parameters .............................................................................................. 18

ENVIRONEERING, INC.

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137-262 CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2018

LIST OF FIGURES

Figure 2-1 Alcoa/Badin Landfill Surface Water & Sediment Sampling Locations .................... 9
Figure 2-2 Alcoa/Badin Landfill Gauging & Well Sampling Locations ................................... 10
Figure 2-3 Alcoa/Badin Landfill Geophysical Survey Area...................................................... 11
Figure 2-4 Main Plant Groundwater Sampling Locations ......................................................... 12
Figure 2-5 Former Ball Field Geophysical Survey Area ........................................................... 13
Figure 2-6 Former Ball Field Sampling Locations .................................................................... 14

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1.0 INTRODUCTION

This work plan is provided as a guidance document in support of sampling and investigative activities at
the Badin Business Park LLC, formerly known as the Alcoa Badin Works facility. The work plan has
been prepared following receipt of the North Carolina Department of Environmental Quality (NCDEQ)
January 23, 2017 correspondence concerning the review of Phase 4 and 5 of the Corrective Measures
Study (CMS), the Expanded Pre-CERCLIS Screening Assessment (EPSA) for the Former Ball Field, and
the Site Inspection Report (SIR) for the Alcoa/Badin Landfill. NCDEQ determined that further evaluation
was warranted and requested that Alcoa demonstrate that identified items had been evaluated or prepare a
work plan to evaluate those items. Select items were addressed in a March 3, 2017 written response from
Alcoa and in a meeting with NCDEQ on March 28, 2017. The remaining items are the subject of this
work plan which focus primarily on the Alcoa/Badin Landfill, the Main Plant area groundwater, and the
Former Ball Field area.

The approach for the sampling and investigative activities has been developed based on information
obtained from site reconnaissance, previous investigations, and remedial activities conducted at the
facility. This work plan is intended to provide an update to the current conditions information and
establish a baseline to support recommendations towards additional remedial activity and monitoring. The
work plan is organized by the following sections:

 Section 1 – Introduction
 Section 2 – Scope of Work
 Section 3 – Field Procedures
 Section 4 – Schedule and Reporting

1.1 Site Overview

The facility is located on State Highway 740 within the Town of Badin, North Carolina, and occupies
approximately 123 acres of land. Production at the Badin Works facility began in 1916 and continued
through 2002. Principal products once manufactured at the facility included carbon cathodes and anodes,
continuous cast sheets, and specialty metals. The facility was permanently closed in 2010 and several
buildings were razed in 2012. In 2016, the legal owner and operator of the facility transferred from Alcoa
Inc. to the Badin Business Park LLC, a subsidiary Alcoa Corporation (Alcoa).

The facility is currently subject to Resource Conservation and Recovery Act (RCRA) Corrective Action
as a condition of an existing RCRA Permit (EPA ID: NCD 003 162 542). As a condition of the permit,
the facility is required to identify Solid Waste Management Units (SWMUs) and Areas of Concern
(AOCs), assess the units for potential/confirmed releases, and provide remedies for those units where
releases are identified and in need of corrective measures. To date, multiple investigations and interim
measures have been completed across the facility. The RCRA Facility Investigation report identified
groundwater in three areas of the facility as needing further actions. These areas were: groundwater at the
Alcoa/Badin Landfill (SWMU No. 2); groundwater at the Old Brick Landfill (SWMU No. 3); and
groundwater at the Main Plant. More recently, the EPSA for the Former Ball Field, and the SIR for the
Alcoa/Badin Landfill identified questions warranting further investigation and constituted a majority of
the comments provided in the NCDEQ correspondence dated January 23, 2017.
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1.2 Project Objectives

This Work Plan provides guidance to address the items identified in the March 3, 2017 response to the
January 23, 2017 NCDEQ letter and are summarized under the primary objectives to follow. Two
additional objectives were identified during the March 28, 2016 NCDEQ meeting to address items
identified by the NCDEQ Division of Water Resources and are annotated as such.

 Determine the contribution of cyanide and fluoride compounds from the eastern drainage ditch to
Little Mountain Creek and examine the potential source of the PCBs and PAHs in and adjacent to
the eastern drainage ditch.

 Assess the variation on constituent levels in Little Mountain Creek as intended by the instream
monitoring study requirements of the September 29, 2017 Final NPDES Permit Renewal,
Condition A. (8.) (NCDEQ Division of Water Resources Objective)

 Assess the contribution of groundwater discharge to the eastern drainage ditch.

 Evaluate the effects of the new trench collection system on the site-wide flow system and the
constituent concentrations observed within the landfill interstitial pore water, the shallow
groundwater unit, and the groundwater south of the landfill.

 Delineate the linear extent of elevated constituent levels in the wetland area downgradient of the
Alcoa/Badin Landfill and monitor the effectiveness of the new trench collection system over an
extended period of time.

 Determine the current jurisdictional status of the three drainage ditches upgradient of Little
Mountain Creek (i.e., eastern, middle, and western) and the adjacent areas. (NCDEQ Division of
Water Resources Objective)

 Determine if trichloroethylene (TCE) is present in monitoring well (MW-110) and update the
delineation of TCE in groundwater at the Main Plant area.

 Assess subsurface conditions at the Former Ball Field area to determine if a disposal area is
present.

The results of this study, as appropriate, will be used in support of recommending additional remedial
activity and monitoring. In addition, the results will be used to develop a subsequent work plan regarding
an evaluation of the long-term effectiveness of recent upgrade activities completed at the Alcoa/Badin
Landfill.
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2.0 SCOPE OF WORK

To satisfy the objectives of this work plan, the scope of work has been organized into three primary tasks;
the Alcoa/Badin Landfill, the Main Plant area groundwater, and the Former Ball Field area. The
Alcoa/Badin Landfill task is the only task that is further divided into individual subtasks. The scope of
work for each of the tasks is summarized in this section with additional details on field procedures
provided in Section 3.

2.1 Task 1 – Alcoa/Badin Landfill Area

In order to satisfy the objectives concerning the Alcoa/Badin Landfill and surrounding area, the scope of
work for this task has been divided into four subtasks.

2.1.1 Subtask 1 – Surface Water Assessment

Subtask 1 is intended to address the first two objectives, specifically:

(1) Determine the contribution of cyanide and fluoride compounds from the eastern drainage ditch to
Little Mountain Creek and examine the potential source of the PCBs and PAHs in and adjacent to
the eastern drainage ditch; and,
(2) Assess the variation on constituent levels in Little Mountain Creek as intended by the instream
monitoring study requirements of the September 29, 2017 Final NPDES Permit Renewal,
Condition A. (8.).

The scope of Subtask 1 includes collecting the following samples:

 Once per quarter for a period of four quarters, five surface water samples will be collected from
instream monitoring at five locations within Little Mountain Creek as shown on Figure 2-1.
 During one of the four quarterly sampling events, two sediment samples will be collected from
two of the Little Mountain Creek sample locations, the furthest upstream sample location and the
sample location immediately downstream of the eastern drainage ditch.
 During one of the four quarterly sampling events, three surface water and sediment samples will
be collected from upper, middle, and lower reaches of the eastern drainage ditch as shown on
Figure 2-1.

For the first quarterly Little Mountain Creek sampling event, the surface water samples will be analyzed
for the following constituents:

Little Mountain Creek
 pH,
 Total Cyanide,
 Total Fluoride,
 PCBs (Aroclors and Congeners),
 Priority Pollutant List (upstream and downstream locations only)
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 Total Hardness (upstream location only),
 Total Lead, and
 Total Arsenic.

Subsequent quarters will include pH, total cyanide, total fluoride, total hardness, total lead, and total
arsenic.

The surface water samples from the Eastern Drainage Ditch will be analyzed for the following
constituents:

Eastern Drainage Ditch
 Total Cyanide,
 Available Cyanide,
 Total Fluoride,
 PCBs (Aroclors and Congeners), and
 PAHs (via SVOCs).

The sediment samples will be analyzed for the following constituents:

 PCBs (Aroclors and Congeners), and
 PAHs (via SVOCs).

The Subtask 1 sampling results and recommendations for future activities, including the potential need to
examine for additional potential source(s) of PCBs and PAHs, will be provided in a quarterly progress
report.

2.1.2 Subtask 2 – Hydrological Conditions Evaluation

Subtask 2 is intended to address the second two objectives, specifically:

(1) Assess the contribution of groundwater discharge to the eastern drainage ditch; and,
(2) Evaluate the effects of the new trench collection system on the site-wide flow system and the
constituent concentrations observed within the landfill interstitial pore water, the shallow
groundwater unit, and the groundwater south of the landfill.

An analysis of current hydrological conditions will be accomplished through monitoring the water levels
and constituent concentrations in several groundwater monitoring wells and piezometers associated with
the landfill’s existing monitoring well network, as shown on Figure 2-2 and summarized in Table 2-1.
Additionally, surface water elevation data will be collected from Little Mountain Creek and the eastern
drainage ditch.

For the purposes of assessing flow at the site, water level data will be collected from the landfill’s shallow
and deep flow systems. The investigation strategy for the assessment will consist of the following:

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 Pressure dataloggers will be installed in wells strategically placed throughout the Alcoa/Badin
Landfill site. The pressure dataloggers will be used to determine water levels in wells by
recording a hydraulic head above the placement of the pressure sensor. Each datalogger will be set
up to collect pressure data on thirty minute intervals. The pressure data will be converted to water
level data, and adjusted, as necessary, to compensate for barometric pressure fluctuations. A
Diver® datalogger by Schlumberger Water Services (Diver) or equivalent will be deployed in the
following wells:

Table 2-1 Task 1-Subtask 2 Selected Wells
MW-1 PZ-1S PZ-3S PZ-16
MW-2 PZ-1I PZ-3I PZ-17
MW-3 PZ-1D PZ-3D PZ-19
MW-4 PZ-2S PZ-13
MW-5 PZ-2I PZ-14
MW-6 PZ-2D PZ-15

The collected data will be compiled and used to determine the maximum, minimum, and median
potentiometric levels observed in each well over the period of one year. Potentiometric surface
maps will be generated using this data and quarterly water elevations will be manually obtained to
confirm the comprehensive datalogger data collection. Data will be used to determine the
groundwater gradient and flow direction and to provide a better understanding of the interaction of
the interstitial pore water within the landfill, the shallow groundwater unit, and the groundwater
south of the landfill.

 Stage monitoring points will be installed in Little Mountain Creek and the eastern drainage ditch.
Pressure dataloggers will be installed at monitoring points for the collection of water level data.
All data will be used to develop stream flow hydrographs to separate base flow from surface run
off components in determining the contribution of groundwater to Little Mountain Creek and the
Eastern Drainage Ditch.

For the purpose of assessing the groundwater constituent concentrations, water samples will be collected
once per quarter for four (4) quarters from the monitoring wells (MW-1 through MW-6) listed in Table 2-
1. The water samples will be analyzed for the following constituents:

 Total Cyanide,
 Available Cyanide, and
 Total Fluoride.

Analytical sample results and water levels will be provided in quarterly updates and may include a
reduction in frequency based on quarterly analytical results.

After completion of four quarters of monitoring, a comprehensive report will be prepared describing the
scope of services performed including results of any sampling performed as well as recommendations for
future activities.
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2.1.3 Subtask 3 – Geophysical Baseline Establishment

Subtask 3 is intended to address the objective to delineate the linear extent of elevated constituent levels
in the wetland area downgradient of the Alcoa/Badin Landfill and monitor the effectiveness of the new
trench collection system over an extended period of time.

The task will be accomplished through the use of electromagnetics (EM), a geophysical method, to
evaluate the electrical conductance in soil pore water downgradient of the Alcoa/Badin Landfill. This
methodology was supported by Benson et al1 as a means to correlate between inorganic water chemistry
data and data from electrical-based geophysical methods. These methods can also be used for time-series
measurements to obtain data on concentration dynamics2. The location of the targeted geophysical survey
area is provided on Figure 2-3.

Due to a potential for seasonal variability, the baseline geophysical survey will be conducted quarterly for
a period of one year. The quarterly surveys will be used to establish a reference baseline condition. A
longer-term assessment of the area will be assessed through a subsequent work plan following the
establishment of the baseline conditions.

A summary of Subtask 3 accomplishments will be included in the quarterly update letter. A more
complete assessment will be included in the comprehensive report following completion of four quarters
of monitoring.

2.1.4 Subtask 4 – Jurisdictional Determination

Subtask 4 scope of work is intended to address the objective to determine the current jurisdictional status
of the three drainage ditches (eastern, middle, and western) and adjacent areas.

The scope will be accomplished by conducting a stream and wetland delineation to classify conditions at
the base of the Alcoa/Badin Landfill. The location of each wetland and non-wetland boundary will be
flagged in the field and located with a sub-meter GPS unit. Stream channels will be flagged and GPS
locations acquired at representative intervals. Wetland delineation will be performed in accordance with
the 1987 US Army Corps of Engineers (USACE) Wetland Delineation Manual and subsequent regional
supplements. Stream delineation will be performed using indicators of ordinary high-water mark and
current North Carolina stream identification methodology.

A Request for Preliminary Jurisdictional Determination summarizing the findings of the delineation will
be prepared for submission to the USACE. The Request will include the following:

1 Benson, R.C., M.S. Turner, W.D. Vogelsong and P.P. Turner, Correlation between field geophysical measurements and
laboratory water sample analysis, Proceedings of the Conference on Surface and Borehole Geophysical Methods in Ground
Water Investigations, National Water Well Association, Worthington, OH, pp. 178–197, 1985.
2 Benson, R.C., M.S. Turner, P.P. Turner and W.D. Vogelsong, In situ, time-series measurements for long-term ground-water
monitoring, in Ground Water Contamination: Field Methods, ASTM STP 963, Collins, A.G. and Johnson, A.I. Eds., American
Society for Testing and Materials, Philadelphia, PA, 1988, pp. 58–72.
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• Jurisdictional Request Form
• Table of potential jurisdictional resources including estimates of area/size and classification
• Vicinity Map
• USGS and Soil Survey maps
• Aerial photography map of the site depicting the location of potential Clean Water Act
jurisdictional and non-jurisdictional resources
• USACE wetland data forms documenting the characteristics of the wetland and upland areas
investigated including vegetation, soils, and hydrology
• NC Division of Water Resources Stream Identification forms for each of the drainage ditches
including benthic assessment.
• NC Stream Assessment Method and NC Wetland Assessment Method forms for each drainage and
type of adjacent wetland.
• Relevant background information including historical mapping, site plans (if available)
• Site photographs

If necessary, a site visit will be scheduled with the USACE to verify the delineation results. Upon
conclusion of the visit, any required revisions will be made to the mapping as well as a memo
summarizing the changes.

2.2 Task 2 – Main Plant Groundwater

To address the objective of determining if TCE is present in monitoring well (MW-110) and to update the
delineation of TCE in groundwater at the Main Plant area, groundwater samples will be collected from
monitoring wells (MW-4, MW-9, MW-16, and MW-110). The locations of the wells to be sampled are
provided on Figure 2-4. The groundwater samples will be analyzed for volatile organic compounds
(VOCs).

After completion of the Main Plant Groundwater task, an interim report will be prepared providing a
summary of the services performed including results of any sampling as well as recommendations for
future activities.

2.3 Task 3 – Additional Former Ball Field Assessment

In order to satisfy the objectives concerning the Former Ball Field and surrounding area, the scope of
work for this task has been divided into three subtasks.

2.3.1 Subtask 1 – Geophysical Survey

To address the objective of determining if a disposal area is present at the Former Ball Field, geophysical
methods such as EM and ground penetrating radar (GPR) will be employed. The location of the
geophysical survey area is provided on Figure 2-5.

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For the Former Ball Field, the EM technology will be useful in characterizing buried material (either
metal bearing or conductive). Buried carbon material typically exhibits very high quadrature (apparent
conductivity) values when compared with a non-carbon bearing host material. The high conductivity
values are generally exhibited across all EM frequencies. Metal bearing materials (such as steel) tend to
have lower conductivity responses and higher in-phase responses. As a result, a comparison of apparent
conductivity values with the in-phase (metal detection mode) values provides insight as to the
composition and extent of buried material with anomalous high in-phase and apparent conductivity
values.

The GPR technology allows for high resolution, continuous profiling of the subsurface. Changes in
conductivity and in dielectric properties are associated with natural hydrogeologic conditions such as
bedding, cementation, moisture, clay content, voids, and fractures. Therefore, an interface between two
soil or rock layers that have a sufficient contrast in electric properties or a large ditch, backfilled with
suspected plant waste materials, will show up in the radar profile.

Contingency Plan: If the results of the geophysical survey(s) indicate the presence of buried materials,
borings will be installed and soil samples will be collected from the area(s) of interest and analyzed for
the following constituents:

 Total Cyanide,
 Total Fluoride,
 RCRA Metals, and
 PAHs (via SVOCs).

2.3.2 Subtask 2 – Surface Soil Assessment

The objective of Subtask 2 is to assess the drainage swales for constituents in excess of screening levels
found in the sediment in the catch basin. The scope of work will include collecting six surface soil
samples from drainage swales as shown on Figure 2-6.

The soil samples will be analyzed for the following constituents:

 PCBs (Aroclors and Congeners),
 PAHs (via SVOCs).

2.3.3 Subtask 3 – Sediment Sample

The objective of Subtask 3 is to corroborate that concentrations of constituents in Badin Lake sediments
near the concrete culvert discharge are consistent with historical Lake studies and assessments. The scope
of work will include collecting one sediment sample from Badin Lake between the concrete culvert and
the barrier as shown on Figure 2-6.

The sediment samples will be analyzed for PAHs (via SVOCs).

An interim report will be prepared to provide a summary of the investigation to include results of the
geophysical survey and any sampling preformed as well as recommendations for future activities
following the completion of the Former Ball Field Assessment subtasks 1 through 3.
ENVIRONEERING, INC.
MW-32
MW-30
MW-33
MW-34 MW-35
MW-36
MW-37
MW-39
MW-45
MW-47
MW-48
MW-43
MW-44
MW-42
MW-41
MW-40
MW-49
MW-46
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ENVIRONEERING, INC.
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3.0 FIELD PROCEDURES

3.1 Pressure Datalogger Deployment

Pressure dataloggers have the capacity to determine water levels in wells by recording a hydraulic head
above the placement of the pressure sensor. For the Site, the Diver® datalogger by Schlumberger Water
Services or equivalent will be deployed. Diver units will be decontaminated prior to deployment utilizing
the procedures outlined in Section 3.2.1 and will be installed in the locations identified in Table 2-1. Each
Diver unit will be installed suspended from the top of the well using a non-stretch suspension cable on the
basis of the lowest potential water level.

The Diver-Office desktop application will be used to calibrate, read, and program all Diver units. Pressure
data will be downloaded from the Diver onto a PC. The Diver-Office application performs barometric
compensation using the Baro-Diver as well as calculations of absolute water levels based on top of casing
elevations measured in relation to the vertical reference datum. This calculation is performed using either
a known cable length and confirmed with a manual measurement of the water level in the well.

3.2 Sample Collection Procedures

3.2.1 Sample Collection and Decontamination

Surface water and sediment samples will be collected starting with the farthest downstream sampling
location. Surface water samples will be collected using a device constructed of non-reactive material (i.e.
glass, stainless steel or Teflon) and transferred to the laboratory provided sample containers. Water
samples will be collected from the wells utilizing a peristaltic pump and disposable tubing. Sediment
samples will be collected using a stainless-steel hand corer, scoop, trowel, spoon or ladle. Soil samples
will be collected using either a stainless-steel hand trowel or hand auger, or using a small portable
Geoprobe®-like system. All equipment used will be decontaminated between each sample.

Decontamination of Equipment

Decontamination of sampling equipment will be per EPA Region IV Standard Operating Procedures. For
sample collection equipment contaminated with environmental media, one or more of the following
options will be used for field cleaning based on the condition of the sampling equipment:

1. Clean with tap water and Liquinox® or Luminox® detergent using a brush, if necessary, to
remove particulate matter and surface films. Equipment may be steam cleaned (detergent and
high pressure hot water) as an alternative to brushing. Sampling equipment that is steam
cleaned should be placed on racks or saw horses at least two feet above the floor of the
decontamination pad. PVC or plastic items should not be steam cleaned.
2. Rinse thoroughly with tap or distilled water.
3. Rinse thoroughly with distilled water and place on a clean foil-wrapped surface to air-dry.
4. All equipment must be wrapped with foil. If the equipment is to be stored overnight before it is
wrapped in foil, it should be covered and secured with clean, unused plastic sheeting.

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For well sounders (water level indicators) and tapes, the following procedures will be followed:

1. Wash with detergent and tap water.
2. Rinse with tap water.
3. Rinse with distilled water.

Unless conditions warrant, it is only necessary to decontaminate the wetted portion of the sounder or tape.

For downhole drilling equipment (augers, drill stems, rods, tools, and associated equipment) used for
drilling activities involving the collection of soil samples for trace organic and inorganic constituent
analyses and for the construction of monitoring wells to be used for the collection of groundwater, the
following procedures will be followed:

1. Cleaning and decontamination of all equipment should occur at a designated area
(decontamination pad) on the site. Tap water brought on the site for drilling and cleaning
purposes should be contained in a pre-cleaned tank. A steam cleaner and/or high pressure hot
water washer capable of generating a pressure of at least 2500 PSI and producing hot water
and/or steam (200° F plus), with a detergent compartment, should be obtained.
2. Prior to arrival, drilling equipment should be clean of any contaminants that may have been
transported from off-site to minimize the potential for cross-contamination.
3. Equipment will be washed with tap water and detergent, using a brush if necessary, to remove
particulate matter and surface films. Steam cleaning (high pressure hot water with detergent)
may be necessary to remove matter that is difficult to remove with the brush. Drilling
equipment that is steam cleaned should be placed on racks or saw horses at least two feet
above the floor of the decontamination pad. Hollow-stem augers, drill rods, etc., that are
hollow or have holes that transmit water or drilling fluids, should be cleaned on the inside with
vigorous brushing.
4. Rinse thoroughly with tap water.
5. Remove from the decontamination pad and cover with clean, unused plastic. If stored
overnight, the plastic should be secured to ensure that it stays in place.

For downhole drilling equipment that contacts the sample media (piston sampler points and shoes, screen
point sampler screens and sheaths, and the drive rods when used for groundwater sampling), the following
procedures will be followed:

1. Clean with tap water and Alconox® detergent using a brush, if necessary, to remove
particulate matter and surface films. Equipment may be steam cleaned (detergent and high
pressure hot water) as an alternative to brushing. Sampling equipment that is steam cleaned
should be placed on racks or saw horses at least two feet above the floor of the
decontamination pad. PVC or plastic items should not be steam cleaned.
2. Rinse thoroughly with tap or distilled water.
3. Rinse thoroughly with distilled water and place on a clean foil-wrapped surface to air-dry.
4. All equipment must be wrapped with foil. If the equipment is to be stored overnight before it is
wrapped in foil, it should be covered and secured with clean, unused plastic sheeting.

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After decontamination, sampling equipment will be handled only by personnel wearing clean gloves to
prevent re-contamination. In addition, the equipment should be moved away (preferably upwind) from the
decontamination area to prevent re-contamination. If the equipment is not to be immediately re-used it
should be covered with plastic sheeting to prevent re-contamination. The area where the equipment is kept
prior to re-use must be free of contaminants.

Sample Collection

Precautions will be taken so that sampling materials do not contact the ground or other potentially
impacted surfaces. Each soil, sediment, surface water, and water sample will be retrieved from the
sampling location and placed into a clean sample container. Upon completion of the field measurements,
samples will be collected from the sample location for laboratory analyses, and placed in
laboratory-prepared containers appropriate for the analyses to be performed. Each sample container will
be labeled with the sample number; the identity of the sampler; the time and date of collection; the
preservatives (if any); and the required analyses. All samples collected will be placed into
laboratory-prepared containers and preserved as noted on Table 3-1.

Table 3-1 Bottling and Preservative Parameters
Analyte Bottle Preservative Holding Time
Sediment
SVOCs (for PAHs) 4 oz. Glass 0-4ºC 14 days
PCBs (Aroclors) 4 oz. Glass 0-4ºC 1 year
PCBs (Congeners) 4 oz. Amber Glass None 1 year
Soil
Total Cyanide 4 oz. Glass 0-4ºC 14 days
Fluoride 4 oz. Glass 0-4ºC 28 days
RCRA Metals 4 oz. Glass 0-4ºC 28 days
PAHs 4 oz. Glass 0-4ºC 14 days
Surface Water
Total Cyanide 250 ml Plastic NaOH, 0-4ºC 14 days
Available Cyanide 250 ml Amber Plastic Lead Carbonate/
Filtration, NaOH, 0-4ºC 14 days
Fluoride 250 ml Plastic 0-4ºC 28 days
PCBs (Aroclors) Two x 1-liter Amber Glass 0-4ºC None
PCBs (Congeners) Two x 1-liter Amber Glass None 1 year
PAHs Two x 1-liter Amber Glass 0-4ºC 7 days
PPL - VOCs Three x 40mL amber vials HCl, 0-4°C 14 days
PPL - SVOCs Two x 1-liter Amber Glass 0-4ºC 7 days
PPL – Metals 250 ml Plastic HNO3, 0-4ºC 28 days
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Analyte Bottle Preservative Holding Time
PPL – Cyanide 250 ml Plastic NaOH, 0-4ºC 14 days
PPL – Phenols 250 mL Amber Glass H2SO4, 0-4°C 28 days
PPL – Asbestos 1-liter Plastic 0-4°C 48 hours
PPL – Dioxins Two x 1-liter Amber Glass 0-4°C 1 year
PPL – Pesticides/PCBs Two x 1-liter Amber Glass 0-4ºC None
Total Hardness 250 ml Plastic HNO3, 0-4ºC 180 days
Total Lead/Arsenic 250 ml Plastic HNO3, 0-4ºC 180 days
pH Field Procedure None None
Water (Via Wells)
Total Cyanide 250 ml Plastic NaOH, 0-4ºC 14 days
Available Cyanide 250 ml Amber Plastic Lead Carbonate/
Filtration, NaOH, 0-4ºC 14 days
Fluoride 250 ml Plastic 0-4ºC 28 days
VOCs 3 x 40ml V-TSL HCl, 0-4ºC 14 days
ml – milliliters
V-TSL – Glass Vial Teflon-lined Septum
PPL – Priority Pollutant List

Sample collection points will be geolocated and placed on an aerial photograph base map and
incorporated into a georeferenced database for the site. The ArcView® visualization program will be used
to integrate the database and geo-referenced aerial photographs and topographic map set.

3.2.2 Sample Analysis

Samples will be analyzed in accordance with the EPA methods, listed in Table 3-2 or an equivalent
procedure, by a North Carolina-certified laboratory:

Table 3-2 Analytical Parameters
Analyte Method
Number
Laboratory Reportable
Detection Limit
Sediment
SVOCs (with PAHs) 8270 0.33-1.7 mg/kg
PCBs (Aroclors) 8082 0.033 mg/kg
PCBs (Congeners) 1668 2.5x10-5 - 3x10-4 mg/kg
Soil
Total Cyanide 9012 0.25 mg/kg
Fluoride 9056 5 mg/kg
RCRA Metals (with Hg) 6020/7471 0.006 - 5 mg/kg
PAHs 8270 0.33-1.7 mg/kg
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Analyte Method
Number
Laboratory Reportable
Detection Limit
Surface Water
Total Cyanide 4500 CN-E 0.01 mg/l
Available Cyanide OIA-1677-09 0.002 mg/l
Fluoride 300 0.5 mg/l
PCBs (Aroclors) 608 0.0005 mg/l
PCBs (Congeners) 1668 2.5x10-7 - 3x10-6 mg/l
PAHs 625 0.010-0.060 mg/l
PPL - VOCs 624 0.002 - 0.05 mg/l
PPL - SVOCs 625 0.010-0.060 mg/l
PPL – Metals 200.7/245.1 0.0002 - 0.050 mg/l
PPL – Cyanide 4500 CN-E 0.01 mg/l
PPL – Phenols 420.4 0.01mg/l
PPL – Asbestos 100.2 <10 micron
PPL – Dioxins 1613 10 pg/l
PPL – Pesticides/PCBs 608 0.00005 - 0.0005mg/L
Total Hardness 200.7 0.7 mg/l
Total Lead/Arsenic 200.7 0.0001 - 0.050 mg/l
pH Field procedure
Water (Via Wells)
Total Cyanide 9012 0.01 mg/l
Available Cyanide OIA-1677-09 0.002 mg/l
Fluoride 4500FL-C 0.5 mg/l
VOCs 8260 0.001-0.025 mg/l

3.2.3 Field Quality Control

The quality of data for the collection of samples will be ensured by the use of trip blanks, and equipment
blanks (not required if dedicated materials are used), and replicate samples. Trip blanks measure any
cross-contamination of the samples during transport, handling, and storage. Equipment blanks
demonstrate that the sample equipment is free of contamination and that adequate decontamination was
performed after the use of the sample equipment. Replicate samples indicate the precision of the sampling
process by calculating the relative percent difference in the results for a sample and its replicate. Each
sampling event will include at least one trip blank, and one equipment blank (if required), and one
replicate sample. Trip blanks will be analyzed for VOCs in the same manner as the accompanying
samples. Equipment blanks and replicate samples will be analyzed for the same analytes and in the same
manner as the accompanying samples.

3.2.4 Sample Shipment

All samples will be packaged securely and placed on ice to cool (reduce the sample temperature to below
4° C), and transported to the analytical laboratory following strict chain-of-custody protocol.
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3.2.5 Chain-Of-Custody

Each sample container will be individually identified as to sample number, date and time collected, and
source of sample. A chain-of-custody record will be prepared which will include:

 The name of the person collecting the samples;
 The identity of each sample;
 Analytical requirements; and
 Name of person accepting sample.

Custody transfers of samples will be recorded on the chain-of-custody form by signatures of the transferor
(relinquisher) and the transferee (receiver). This procedure will be repeated, as necessary, until final
delivery is made to the analytical laboratory.

3.2.6 Laboratory Quality Control

The quality of data from the laboratory will be ensured by the use of instrument tuning, initial calibration,
continuing calibration, internal standards, method blanks, surrogate recoveries, and matrix spike/spike
duplicate analyses.

3.3 Geophysical Survey Procedures

3.3.1 EM Field Procedures

The EM in-phase and conductivity data are typically collected simultaneously at five varying frequencies
(1530 Hz, 5010 Hz, 9990 Hz, 20010 Hz, and 47010 Hz). By varying the collection frequencies, the
geophysicist is able to better characterize the makeup of buried debris (i.e., distinguish between highly
conductive carbon and other metal bearing material), if present.

The GEM-2 may be operated in remote control configuration while evaluating the landfill area (using a
sled) and wetlands (carried by hand). In this mode, the GEM-2 unit is mounted on PVC tubular sled
positioned approximately 0.75 meters from the ground surface, or is held by hand while the land is
traversed on foot. The receiving coil (detector coil) is situated directly above the exposed ground surface.

Data is typically collected at the rate of approximately six samples per second. The position of each
sample point is measured utilizing a CSI Wireless SERES global positioning system (GPS) with a data
update rate of 6 Hz. This data can be transferred from the GEM-2 unit to a portable laptop computer that
was carried on board a 4WD vehicle (Polaris Ranger with covered cab area). The sample spacing is thus a
function of rate of travel of the sled or pace rate of the person carrying the GEM-2 and rate of data
sampling.

The EM data will be transferred from the field data collection unit to a laptop computer using the
WinGEM software provided by the manufacturer. During the transfer process, the WinGEM software
assigns UTM metric coordinates to each data collection station, and calculates the apparent conductivity,
sum of conductivity, and magnetic susceptibility for each frequency collected using the system software.
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These data will be transferred to a Microsoft Excel Spread Sheet and reviewed for data anomalies such as
poor GPS confidence levels that would likely result in poor coordinate assignments. All data with GPS
confidence levels of less than 1 are typically rejected. The UTM Coordinates are transformed into the
North Carolina State Plane System (in survey feet) using the Corpscon software, and then used to compile
a series of maps illustrating various responses using a simple 3D mapping program (such as Golden
Software’s Surfer software).

3.3.2 GPR Field Procedures

The GPR data will be collected on the SIR 3000 data collection unit using a 400 and 200 MHz antennas,
and reviewed in the field for completeness and reliability. The SIR 3000 unit uses a digital survey wheel
to determine the distance between each vertical survey GPR sounding. This data is collected with the time
domain records of the GPR, and post-processed using GSSI Radar Radan software.
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4.0 SCHEDULE AND REPORTING

All activities shall be implemented according to a schedule agreed upon by Alcoa and NCDEQ. Within 90
days of the NCDEQ’s approval of the WP, Alcoa will begin implementation of the plan. Field activities
will be completed within the following estimated timeframe:

 Task 1 – Alcoa/Badin Landfill Sampling consisting of:
o Subtask 1 – Surface Water Assessment completed in six weeks;
o Subtask 2 – Hydrological Conditions Evaluation completed in fifty-six weeks;
o Subtask 3 – Geophysical Baseline Establishment completed in fifty-six weeks;
o Subtask 4 – Jurisdictional Determination completed in thirty-six weeks;
 Task 2 – Main Plant Groundwater Sampling completed in four weeks; and
 Task 3 – Additional Ball Field Assessment completed in eight weeks.

4.1 Reporting and Notifications

NCDEQ will be notified no earlier than seven (7) days prior to commencing field activities. The best
available effort will be made to submit results and findings of the work plan to the Division of Waste
Management within six weeks of completion of field activities. Should unforeseen delays occur, Alcoa
Division of Waste Management will be notified and presented with a revised schedule.

4.1.1 Quarterly Update Reports

Progress Reports will be submitted quarterly to provide a summary of work completed, document
findings, and provide recommendations for future activities. The interim reports for the main plant
groundwater and ball field investigations may be provided as an attachment to a quarterly progress report
or under separate cover.

4.1.2 Comprehensive Report

After completion of the Alcoa/Badin Landfill tasks, a comprehensive report will be prepared describing
the scope of services performed including results of any sampling performed. A screening level ecological
risk assessment and recommendations for future activities will be provided to DWM at the completion of
the investigative activities and if warranted, may include a recommendation for a site-specific baseline
ecological risk assessment. The site-specific baseline ecological risk assessment work plan would follow
the comprehensive report under a separate cover.