NCD003162542_Badin Business Park_Corrective Action_20190626

Badin Business Park LLC

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

June 26, 2019

Robert C. McDaniel
Facility Management Branch
Hazardous Waste Section
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, North Carolina 27603

VIA ELECTRONIC MAIL

Re: Targeted Soil Sampling Confirmatory Sampling Report
Badin Business Park (f/k/a Alcoa - Badin Works)
Badin, North Carolina
EPA ID: NCD 003 162 542

Dear Mr. McDaniel:

This letter documents the results of confirmation soil sampling efforts performed at the Badin
Business Park facility on June 11, 2019. The sample was collected as a follow up action to the
detection of a single polychlorinated biphenyl (PCB) Aroclor, Aroclor 1232, as reported in the
January 28, 2019, Targeted Sampling Report (Report). A confirmation sample was collected from
a location adjacent to the location previously containing the detection; no constituents were
detected above laboratory detection limits.

The May 31, 2018 Targeted Sampling Work Plan (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. The Work Plan was prepared following receipt
of the North Carolina Department of Environmental Quality (NCDEQ) January 31, 2018
correspondence concerning the review and conditional approval of the Investigative Work Plan for
the Phase 4 and 5 Corrective Measures Study, Alcoa/Badin Landfill, and Former Ball Field, a
meeting with NCDEQ personnel on May 10, 2018, and a subsequent conference call with NCDEQ
personnel on May 24, 2018.

NCDEQ determined that previous environmental investigations have targeted known or suspected
areas of the facility where constituents of interest (COIs) were known to have been utilized. Other
areas of the facility were not evaluated because they were covered by plant buildings or other
obstructions, or not suspected to be impacted. The objective of the Work Plan was to provide
information to assess the presence or suspected presence of COIs in soils on the facility property
not previously investigated. To accomplish the objective, surface and subsurface soil samples were
collected to assess soil quality conditions and to screen for the presence of potential source areas
that have not been identified in previous investigations.
Robert C. McDaniel
Targeted Soil Sampling Confirmatory Sampling Report
June 26, 2019

As reported in the January 28, 2019 Report, a single PCB Aroclor, Aroclor 1232, was detected in
one shallow soil sample (ANO-SB002 (0’-1’)) at a concentration above the Protection of
Groundwater Preliminary Soil Remediation Goal (PSRG) but below the Industrial PSRG. PCB
Aroclors were not detected in the remaining soil samples at concentrations above either PSRG.
Aroclor 1232 has not been historically detected in soil or groundwater samples. Further, Aroclor
1232 is not common to past operations and as a result the detection of Aroclor 1232 was believed
to be anomalous.

During a March 19, 2019 follow-up meeting with the NCDEQ Hazardous Waste Section, it was
discussed that a confirmation sample should be collected from the location where the detection
occurred and the sample analyzed for Aroclor 1232. On June 11, 2019, ENVIRONEERING, Inc.
personnel collected a confirmation sample from a sample location (ANO-SB003 (0’-1’)) adjacent
to the location previously containing the detection. No constituents were detected above laboratory
detection limits. A map showing the location of the sample is provided as Figure 1. Soil sample
confirmation analytical results and equipment blank analytical results are summarized in Tables 1
and 2. The laboratory report and completed chain of custody form is provided in Appendix A.

Badin Business Park LLC appreciates the time and effort your office has spent on this project, and
we look forward to working with you in the future. 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

Attachments

cc: Jason Mibroda, Alcoa
Michael W. Worden, Environeering

Robert C. McDaniel
Targeted Soil Sampling Confirmatory Sampling Report
June 26, 2019

Figure

ENVIRONEERING, INC.
LEGEND:
PARCEL BOUNDARY
SOIL BORING
NOTE: BACKGROUND AERIAL PHOTOGRAPH DATED 2015
ANO-SB003ANO-SB002
Robert C. McDaniel
Targeted Soil Sampling Confirmatory Sampling Report
June 26, 2019

Tables

Sample ID Method CAS Units
PSRG
Prot. of
GW
PSRG
Ind/Comm
Surface Material
Thickness of Surface Material
Sample Depth Below Surface Material
Date
Time
Percent Moisture ASTM D2974-87 %
PCB-1232 (Aroclor 1232) EPA 8082 11141-16-5 mg/kg ND <0.0348 0.0059 0.73
Soil sample ANO-SB003 (0'-1') was collected adjacent to sample ANO-SB002 (0'-1') to confirm previous results.
ND - The analyte was not detected above laboratory detection limits. Subscript indicates compound-specific
MDL in mg/kg.
NCDEQ Preliminary Soil Remediation Goals (PSRG) - May 2019
13:30
6/11/2019
14.7
0'-1'
Crushed Concrete
6"
ANO-SB003
(0'-1')
Table 1
Soil Sample Analytical Results
Former Anode Plant Area
Badin Business Park Facility
Badin, North Carolina
Table 2
Field Blank Sample Analytical Results
Former Anode Plant Area
Badin Business Park Facility
Badin, North Carolina
Sample ID Method CAS Units ANO-EB001
Location
Date
Time
PCB-1232 (Aroclor 1232) EPA 8082 11141-16-5 mg/l ND <0.00021
ND - The analyte was not detected above laboratory detection limits. Subscript indicates
compound-specific MDL in mg/l.
6/11/2019
13:50
Equipment Blank
Robert C. McDaniel
Targeted Soil Sampling Confirmatory Sampling Report
June 26, 2019

Appendix A
Laboratory Report and Chain of Custody Form
#=CL#
June 19, 2019
LIMS USE: FR - MICHAEL WORDEN
LIMS OBJECT ID: 92432687
92432687
Project:
Pace Project No.:
RE:
Michael W. Worden
Environeering, Inc.
16100 Cairnway
Suite 320
Houston, TX 77084
137-267
Dear Michael Worden:
Enclosed are the analytical results for sample(s) received by the laboratory on June 12, 2019. The
results relate only to the samples included in this report. Results reported herein conform to the most
current, applicable TNI/NELAC standards and the laboratory's Quality Assurance Manual, where
applicable, unless otherwise noted in the body of the report.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Angela Baioni
[e-mail]
Project Manager
[phone]
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 1 of 14
#=CP#
CERTIFICATIONS
Pace Project No.:
Project:
92432687
137-267
Charlotte Certification IDs
9800 Kincey Ave. Ste 100, Huntersville, NC 28078
Louisiana/NELAP Certification # LA170028
North Carolina Drinking Water Certification #: 37706
North Carolina Field Services Certification #: 5342
North Carolina Wastewater Certification #: 12
South Carolina Certification #: 99006001
Florida/NELAP Certification #: E87627
Kentucky UST Certification #: 84
Virginia/VELAP Certification #: 460221
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 2 of 14
#=SS#
SAMPLE SUMMARY
Pace Project No.:
Project:
92432687
137-267
Lab ID Sample ID Matrix Date Collected Date Received
92432687001 ANO-SB003 (0'-1)Solid 06/11/19 13:30 06/12/19 09:41
92432687002 ANO-EB001 Water 06/11/19 13:50 06/12/19 09:41
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 3 of 14
#=SA#
SAMPLE ANALYTE COUNT
Pace Project No.:
Project:
92432687
137-267
Lab ID Sample ID Method
Analytes
Reported LaboratoryAnalysts
92432687001 ANO-SB003 (0'-1)EPA 8082A 2 PASI-CSEM
ASTM D2974-87 1 PASI-CKDF
92432687002 ANO-EB001 EPA 8082A 2 PASI-CSEM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 4 of 14
#=AR#
ANALYTICAL RESULTS
Pace Project No.:
Project:
92432687
137-267
Sample:ANO-SB003 (0'-1)Lab ID:92432687001 Collected:06/11/19 13:30 Received:06/12/19 09:41 Matrix:Solid
Results reported on a "dry weight" basis and are adjusted for percent moisture, sample size and any dilutions.
Parameters Results Units DF Prepared Analyzed CAS No.QualMDLLimit
Report
Analytical Method: EPA 8082A Preparation Method: EPA 35468082 GCS PCB
PCB-1232 (Aroclor 1232)ND ug/kg 06/17/19 10:19 11141-16-506/14/19 20:4776.6 34.8 2
Surrogates
Decachlorobiphenyl (S)183 %06/17/19 10:19 2051-24-3 D3,S306/14/19 20:4710-130 2
Analytical Method: ASTM D2974-87Percent Moisture
Percent Moisture 14.7 %06/13/19 17:080.10 0.10 1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 5 of 14
#=AR#
ANALYTICAL RESULTS
Pace Project No.:
Project:
92432687
137-267
Sample:ANO-EB001 Lab ID:92432687002 Collected:06/11/19 13:50 Received:06/12/19 09:41 Matrix:Water
Parameters Results Units DF Prepared Analyzed CAS No.QualMDLLimit
Report
Analytical Method: EPA 8082A Preparation Method: EPA 3510C8082 GCS PCB RVE
PCB-1232 (Aroclor 1232)ND ug/L 06/19/19 05:13 11141-16-506/13/19 21:050.50 0.21 1
Surrogates
Decachlorobiphenyl (S)69 %06/19/19 05:13 2051-24-306/13/19 21:0510-130 1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 6 of 14
#=QC#
QUALITY CONTROL DATA
Pace Project No.:
Project:
92432687
137-267
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
QC Batch:
QC Batch Method:
Analysis Method:
Analysis Description:
481089
EPA 3510C
EPA 8082A
8082 GCS PCB
Associated Lab Samples:92432687002
Parameter Units
Blank
Result
Reporting
Limit Qualifiers
METHOD BLANK:2602536
Associated Lab Samples:92432687002
Matrix:Water
AnalyzedMDL
PCB-1232 (Aroclor 1232)ug/L ND 0.50 06/19/19 05:510.21
Decachlorobiphenyl (S)%84 10-130 06/19/19 05:51
Parameter Units
LCS
Result
% Rec
Limits Qualifiers% RecConc.
2602537LABORATORY CONTROL SAMPLE:
LCSSpike
Decachlorobiphenyl (S)%79 10-130
Parameter Units
MS
Result
% Rec
Limits Qualifiers% RecConc.
2602538MATRIX SPIKE SAMPLE:
MSSpike
Result
92432868001
Decachlorobiphenyl (S)%94 10-130
Parameter Units
Dup
Result
Max
RPD QualifiersRPDResult
92432687002
2602539SAMPLE DUPLICATE:
PCB-1232 (Aroclor 1232)ug/L ND 30ND
Decachlorobiphenyl (S)%6069
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 7 of 14
#=QC#
QUALITY CONTROL DATA
Pace Project No.:
Project:
92432687
137-267
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
QC Batch:
QC Batch Method:
Analysis Method:
Analysis Description:
481275
EPA 3546
EPA 8082A
8082 GCS PCB
Associated Lab Samples:92432687001
Parameter Units
Blank
Result
Reporting
Limit Qualifiers
METHOD BLANK:2603337
Associated Lab Samples:92432687001
Matrix:Solid
AnalyzedMDL
PCB-1232 (Aroclor 1232)ug/kg ND 33.4 06/17/19 11:0315.2
Decachlorobiphenyl (S)%83 10-130 06/17/19 11:03
Parameter Units
LCS
Result
% Rec
Limits Qualifiers% RecConc.
2603338LABORATORY CONTROL SAMPLE:
LCSSpike
Decachlorobiphenyl (S)%84 10-130
Parameter Units
MS
Result
% Rec
Limits Qualifiers% RecConc.
2603339MATRIX SPIKE SAMPLE:
MSSpike
Result
92433182001
Decachlorobiphenyl (S)%83 10-130
Parameter Units
Dup
Result
Max
RPD QualifiersRPDResult
92433182002
2603340SAMPLE DUPLICATE:
PCB-1232 (Aroclor 1232)ug/kg ND 30ND
Decachlorobiphenyl (S)%8176
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 8 of 14
#=QC#
QUALITY CONTROL DATA
Pace Project No.:
Project:
92432687
137-267
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
QC Batch:
QC Batch Method:
Analysis Method:
Analysis Description:
481075
ASTM D2974-87
ASTM D2974-87
Dry Weight/Percent Moisture
Associated Lab Samples:92432687001
Parameter Units
Dup
Result
Max
RPD QualifiersRPDResult
92432870001
2602410SAMPLE DUPLICATE:
Percent Moisture %0.19 15 250.16
Parameter Units
Dup
Result
Max
RPD QualifiersRPDResult
92432823002
2602419SAMPLE DUPLICATE:
Percent Moisture %18.0 5 2519.0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 9 of 14
#=QL#
QUALIFIERS
Pace Project No.:
Project:
92432687
137-267
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
TNTC - Too Numerous To Count
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL - Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit.
RL - Reporting Limit - The lowest concentration value that meets project requirements for quantitative data with known precision and
bias for a specific analyte in a specific matrix.
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean-Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
LABORATORIES
Pace Analytical Services - CharlottePASI-C
ANALYTE QUALIFIERS
Sample was diluted due to the presence of high levels of non-target analytes or other matrix interference.D3
Surrogate recovery exceeded laboratory control limits. Analyte presence below reporting limits in associated sample.S3
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 10 of 14
#=CR#
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Pace Project No.:
Project:
92432687
137-267
Lab ID Sample ID QC Batch Method QC Batch Analytical Method
Analytical
Batch
92432687002 481089 481256ANO-EB001 EPA 3510C EPA 8082A
92432687001 481275 481429ANO-SB003 (0'-1)EPA 3546 EPA 8082A
92432687001 481075ANO-SB003 (0'-1)ASTM D2974-87
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.Date: 06/19/2019 02:54 PM
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
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