NCD003162542_Badin Business Park_Corrective Action_20240131

Badin Business Park LLC

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

January 31, 2023

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

Re: Baseline Ecological Risk Assessment Progress Report – Alcoa Badin Landfill
Badin Business Park (f/k/a Alcoa - Badin Works)
Badin, North Carolina
EPA ID: NCD 003 162 542

Dear Mr. McDaniel:
Badin Business Park LLC (BBP) provides this update on the Alcoa Badin Landfill Baseline
Ecological Risk Assessment (BERA) as requested in your December 11, 2023 letter which
summarized the review conducted by Toeroek Associates, Inc, an environmental contractor for
US Environmental Protection Agency (EPA) Region 4.
BBP appreciated the assessment of both the “Scientific Management Decision Point Revisions -
Former Ball Field Area Screening Level Ecological Risk Assessment” and the “Response to
Comments on the Alcoa/Badin Landfill Baseline Ecological Risk Assessment Work Plan” and
understands no additional ecological analysis is required at the Former Ball Field Area.
The following is an update regarding the activities conducted in support of the development of the
Alcoa Badin Landfill BERA but, in synopsis the investigation activity identified in the January 31,
2023 Work Plan (Work Plan) are complete. However, the laboratory has not yet provided final
reports to all the requested analysis. BBP is proposing to meet virtually with DEQ and EPA Region
4 to review the information and path forward to complete the BERA in 2023.
In 2023, BBP and its consultants carried out four independent field mobilizations; focusing
primarily on porewater, surface water, sediment and soil in the May mobilization, groundwater in
June and December, and porewater and surface water revisited again in December. Each of the
mobilizations were carried out to address the specific objectives outlined in Table 4-1 of the Work
Plan. No further field work is required related to the objectives identified in the Work Plan.
The most recent field sampling events were completed in December 2023 with the collection of
surface water and pore water from Little Mountain Creek and groundwater from the landfill. The
December mobilization had been pending for many weeks while awaiting a sufficient storm event
to satisfy the evaluation through a range of hydraulic conditions. With the field work complete, a
subset of the analytical data is yet to be received from the laboratory. Upon receipt a
comprehensive dataset of soil, groundwater, sediment, pore water and surface water media will be

available for review. BBP proposes to meet with NCDEQ and US EPA Region 4 to facilitate an
efficient review of the collected information, primary findings, and proposed path forward. We are
tentatively looking to schedule during the week of February 19, 2024, pending receipt of the
remaining data and stakeholders’ availabilities.
Should you have any questions or comments, please contact Jason Mibroda of Alcoa at (412) 315-
2783 at your convenience.
Sincerely,

Robyn L. Gross
Director, Asset Management
Badin Business Park LLC

cc: Adam Ulishney
Heather Goldman
Kim T. Caulk,
Brian Bastek
Leah H. Davis
Maria Arevalo Gonzalez
Sarah Cook
Rose Pruitt
Jason Mibroda