NCD003162542_Badin Business Park_Corrective Action_20190417

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

April 17, 2019 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: Addendum to Investigative Work Plan for the Phase 4 And 5 Corrective Measures Study Badin Business Park LLC, Badin, North Carolina; EPA ID: NCD 003 162 542 Dear Mr. McDaniel:

Badin Business Park LLC respectfully submits the attached Addendum to the April 2018 Investigative Work Plan for your review and approval. The Addendum addresses additional investigation activity near the Alcoa/Badin Landfill.
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: Qais Banihani, NCDEQ Julie Grzyb, NCDEQ Robyn Gross, Alcoa
Jason Mibroda, Alcoa
Michael W. Worden, Environeering
ENVIRONEERING, INC.

ADDENDUM

to

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

April 15, 2019

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.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 ii
TABLE OF CONTENTS

1.0 INTRODUCTION .......................................................................................................................1
2.0 SCOPE OF WORK .....................................................................................................................2
2.1 Task 1, Subtask 1 – Alcoa/Badin Landfill Area ...........................................................2
2.1.1 Step 1: Site History and Records Search ..............................................................2
2.1.2 Step 2: Site Reconnaissance ..................................................................................3
2.1.3 Step 3: Surface Soil and Sediment Sampling ........................................................3
3.0 FIELD PROCEDURES ..............................................................................................................7
3.1 Sample Collection Procedures .......................................................................................7
3.1.1 Sample Collection and Decontamination ..............................................................7
3.1.2 Sample Analysis ....................................................................................................8
3.1.3 Field Quality Control ............................................................................................8
3.1.4 Sample Shipment ..................................................................................................8
3.1.5 Chain-Of-Custody .................................................................................................8
3.1.6 Laboratory Quality Control ...................................................................................9
4.0 SCHEDULE AND REPORTING ..............................................................................................10

LIST OF TABLES

Table 3-1 Bottling and Preservative Parameters ................................................................... 7
Table 3-2 Analytical Parameters ............................................................................................. 8

LIST OF FIGURES

Figure 2-1 Alcoa/Badin Landfill Area Features ...................................................................... 4
Figure 2-2 Alcoa/Badin Landfill Area Topography ................................................................ 5
Figure 2-3 Alcoa/Badin Landfill Targeted Soil Sampling Areas ............................................ 6

ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 1
1.0 INTRODUCTION

On April 2, 2018, a revised Investigative Work Plan for the Phase 4 And 5 Corrective Measures Study,
Alcoa/Badin Landfill, and Former Ball Field (Work Plan) was developed 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. In order to satisfy the objectives concerning the Alcoa/Badin Landfill and
surrounding area, the scope of work was divided into four subtasks. Alcoa/Badin Landfill Subtask 1
targeted the potential source of the polychlorinated biphenyls (PCBs) and polycyclic aromatic
hydrocarbons (PAHs) in and adjacent to the Eastern Drainage Ditch.

In support of the Subtask 1 objectives, sediment and surface water samples were collected from the
Eastern Drainage Ditch in July 2018. Concentrations of PAHs above regulatory levels were detected in
one sediment sample collected from the middle section of the Eastern Drainage Ditch. Sediment samples
from the upper (or northernmost) and lower (or southernmost) sections of the Eastern Drainage Ditch did
not contain concentrations of PAHs above regulatory levels, indicating the extent of PAHs in sediments is
limited. No surface water sample from the Eastern Drainage Ditch contained a detection of PAHs above
laboratory detection limits.

The sum of PCB congener concentrations in sediment samples collected from the middle and lower
sections of the Eastern Drainage Ditch were greater than the respective screening level. The sediment
sample collected from the upper section contained a sum of PCB congener concentrations lower than
screening level suggesting the extent of elevated PCB congeners in sediments is limited to the middle and
lower sections of the Eastern Drainage Ditch. Similarly, the total PCB congeners in surface water was
observed to increase in concentration between the Alcoa/Badin Landfill and Little Mountain Creek.
Results from the sampling event are summarized in the December 5, 2018, the Investigative Report for the
Little Mountain Creek Area (Report) submitted to the North Carolina Department of Environmental
Quality (NCDEQ).

During a March 19, 2019 follow-up meeting with the NCDEQ Hazardous Waste Section, it was discussed
that the sample locations containing the detections have the potential to be influenced from offsite sources
including two operating electrical substations. NCDEQ requested that an Investigative Work Plan (IWP)
Addendum be submitted to NCDEQ outlining the investigation of the areas surrounding the electrical
substations east of the Alcoa/Badin Landfill.

ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 2
2.0 SCOPE OF WORK

To satisfy the objectives of this IWP Addendum, the scope of work has been organized into follow-up
actions for Subtask 1 for the Alcoa/Badin Landfill. The steps for this follow-up action are summarized in
this section with additional details on field procedures provided in Section 3.

2.1 Task 1, Subtask 1 – Alcoa/Badin Landfill Area

In order to identify the potential source of the PCBs and PAHs in and adjacent to the Eastern Drainage
Ditch, the scope of work has been established to follow a track down approach similar to that outlined in
the Handbook for Determining the Sources of PCB Contamination in Sediments1. Two strategies for track
down field sampling can be employed:

1. Top-down sampling that begins with a potential source that is being confirmed; or
2. Bottom-up sampling that begins with very little knowledge and engages in a systematic hunt.

For the IWP Addendum, the top down approach was selected to identify elevated concentrations above
background levels to confirm a potential source(s). The top down approach will follow steps outlined
below.

2.1.1 Step 1: Site History and Records Search

The first step in the top down approach is determining a relationship between historical activities at or
near the site and the constituent detected in the sediments. As discussed during the March 19, 2019
follow-up meeting with the NCDEQ, sample locations containing the detections have the potential to be
influenced from offsite sources including two operating electrical substations. Figure 2-1 shows the two
operating electrical substations with respect to the sample locations containing the detections. A review of
aerial photograph and area drawings shows that the substations were constructed in the mid-1970s. With
the exception of access roads to the Alcoa/Badin Landfill, the substation areas were largely undeveloped
prior to the mid-1970s.

A preliminary review of available U.S. Environmental Protection Agency, NCDEQ, and National
Response Center environmental records indicated that on August 11, 1997, one substation had a bushing
failure that resulted in the release of a tar-like substance. Analytical results indicated that the tar-like
substance contained a concentration of 24,000 mg/kg PCB-1260. Approximately 150 tons of gravel and
soil were removed from the spill area. Post-cleanup verification sampling and analysis identified
detectable concentrations of PCBs in two of the thirty samples, however both concentrations (0.11 mg/kg
and 0.11 mg/kg) were significantly below the 40 Code of Federal Regulations Part 761.125 cleanup
requirement of 50 parts per million.

1 Battelle (Battelle Memorial Institute). 2012. A Handbook for Determining the Sources of PCB Contamination in Sediments.
Technical Report TR-NAVFAC EXWC-EV-1302. Arlington, VA.
ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 3
2.1.2 Step 2: Site Reconnaissance

Preliminary site reconnaissance was conducted to better understand how constituents may move from
potential sources to where constituents were detected in the Eastern Drainage Ditch. These include
drainage, runoff, and discharge pathways from potential source locations to the movement of waters and
sediment in the receiving environment where the detections occurred.

A topographic map of area showing the drainage, runoff, and discharge pathways from the electrical
substations is presented as Figure 2-2. The Eastern Drainage Ditch is shown to have the potential to
receive discharges from the topographically higher electrical substations. Subsequent erosion from these
elevated areas can bring soil particles into surface water bodies where they can deposit out as the sample
locations containing constituent detections. During the preliminary site reconnaissance, multiple erosional
features including both rills and depositional fans were observed in the areas surrounding the electrical
substations.

2.1.3 Step 3: Surface Soil and Sediment Sampling

To confirm the information gathered in Steps 1 and 2, up to twenty (20) surface soil and sediment samples
will be collected from locations surrounding the electrical substations. Sample locations will be
determined in the field and will target depositional feature locations and/or locations where spilled
material could gather. Figure 2-3 shows the targeted areas with respect to the two operating electrical
substations and the sample locations containing the detections.

The soil samples will be analyzed for the following constituents:

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

An interim report will be prepared to provide a summary of the investigation to include results of the
sampling preformed as well as recommendations for future activities.
ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 7
3.0 FIELD PROCEDURES

3.1 Sample Collection Procedures

3.1.1 Sample Collection and Decontamination

Sediment and soil samples will be collected using a stainless-steel hand corer, scoop, trowel, spoon, or
hand auger. 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.
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.

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 or sediment sample will be retrieved from the sampling location and placed
into 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 and Soil
SVOCs (for PAHs) 4 oz. Glass 0-4ºC 14 days
PCBs (Aroclors) 4 oz. Glass 0-4ºC 1 year
oz – ounces
ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 8
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.

3.1.2 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 and Soil
SVOCs (with PAHs) 8270 0.33-1.7 mg/kg
PCBs (Aroclors) 8082 0.033 mg/kg
mg/kg – milligrams per kilogram

3.1.3 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 (if required), 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.

3.1.4 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.

3.1.5 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.
ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 9

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.

3.1.6 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.
ENVIRONEERING, INC.

137-267 ADDENDUM CMS-ABL-FBF Investigative Work Plan – Badin Business Park LLC - Badin, NC; April 2019 10
4.0 SCHEDULE AND REPORTING

All activities shall be implemented according to the schedule previously agreed upon by Badin Business
Park and NCDEQ. The best available effort will be made to submit results and findings to the NCDEQ
within six weeks of completion of field activities. Should unforeseen delays occur, NCDEQ will be
notified and presented with a revised schedule.