20070812 Ver 2_More Info Received_20101109

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NCDENR f : y
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Beverly Eaves Perdue Dexter R. Matthews Dee Freeman
Governor Director Secretary
November 5, 2010
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Robert A. Prezbindowski
Alcoa Remediation
2300 North Wright Road
Alcoa, Tennessee 37701
t'O V 10' 2010
WETIANDS AMO ST ? 8
Reference: Phase 3 - Engineering Data Collection Work Plan for the CMS
Alcoa, Inc.
Badin, North Carolina
NCD 003 162 542
Dear Mr. Prezbindowski:
The Hazardous Waste Section has completed the review of Alcoa Inc.'s Phase 3 --
Engineering Data Collection Work Plan for the Corrective Measures Study for the Badin
facility.
The attached comments identify specific issues that must be addressed prior to the
approval the Phase 3 Work Plan. Alcoa must submit revisions to the work plan
addressing these comments within 45 days of the receipt of this letter.
If you have questions concerning this matter please contact me at [phone].
Sincerely,
YA
Robert C. McDaniel
Facility Management Branch
Hazardous Waste Section
cc: John E. Johnston, US EPA, Region 4
Sean Morris
Tom Belnick, NC DWQ
Mprney, NC DWQ
Andrew Lucas, Stanly County Manager
rc: Elizabeth Cannon
Harold A. McCarty
Vance Jackson
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] Internet: wvvw.wastenotnc.org
An Equal Opportunily 1 Affirmalwe Action Eri?ployer
C:Ame1\rem\phase 3
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Phase 3 - Engineering Data Collection Work Plan
2.1.1 Task 1 - Fill Assessment
Alcoa Badin Landfill
Figure 2 - 1 is the figure of the Old Waste Oil Storage Area and Figure 2 - 2 is the figure
of the Alcoa Badin Landfill.
Are the proposed monitoring wells to be installed through the cap of the Alcoa Badin
Landfill permanent wells or temporary wells?
If it is determined that ground water is in contact with the waste in the Alcoa Badin
Landfill Alcoa proposes to collect and analyze ground-water samples for only cyanide
and fluoride. Since the landfill also contained municipal waste, samples should be
analyzed for indicator parameters that would indicate if contaminants from municipal
waste have been released.
Old Waste Oil Storage Area (SWMU No. 35)
Alcoa must include the polycyclic aromatic hydrocarbons (PAHs), as well as, total
cyanide, fluoride, and polychlorinated biphenyls (PCBs) in the soil sampling program for
the Old Waste Oil Storage Area. The RFI Report identified three constituents above the
Region 3 residential RBCs (fluoride, benzo(a)anthracene, indeno(1,2,3-cd)pyrene) and
the constituents arsenic, PCB Aroclors 1248, 1254, and 1260, and three PAHs (benzo(a)
pyrene, benzo(b)fluoranthracene and dibenzo (a,h)anthracene) were above the Region 3
industrial and residential RBCs in soil samples collected at the Old Waste Oil Storage
Area.
Alcoa proposes to install ten soil borings within the perimeter of the Old Waste Oil
Storage Area. The proposed soil samples will be collected and sampled in each boring at
the following locations:
1 - gravel cover soil interface;
2 - two feet below gravel/soil interface;
3 - four feet below gravel/soil interface; and
4 - immediately above the fill material/native soil interface.
The total soil samples collected in the ten borings would be 40 instead of the 30 samples
as indicated.
Alcoa states that 15 to 20 shallow borings to approximately 3 feet below grade will be
advanced at locations as indicated on the Old Waste Oil Storage Area figure (Figure 2 -
1), however, the shallow boring locations are not indicated on the figure.
In addition, the targeted area to be investigated is in the area of the RFI borings "TP - 01,
02, 06, and 10." Should the borings designated "TB" instead of "TP"?
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Pine Tree Grove Area and West SPL Area
After the collection and evaluation of the geophysical data at the Pine Tree Grove Area
and West SPL Area, Alcoa propose to employ an approach similar to the one with the
Alcoa Badin Landfill. With this procedure, where will the monitoring wells and borings
be located in the Pine Tree Grove and West SPL Areas?
If it is determined that ground water is in contact with the waste in the Pine Tree Grove
and West SPL Areas, what constituents will the ground-water samples be analyzed to
determined if water is migrating through the material in the units?
2.1.2 Task 2 - Water Quality Assessment
Alcoa Badin Works Plant Area Ground-Water Sampling
Alcoa proposes to evaluate ground-water data in the Alcoa Badin Works Plant Area to
evaluate the potential use of various remediation technologies. In the determination of
the potential use of monitored natural attenuation, Alcoa should use the HWS Guidance
on Developing a Monitored Natural Attenuation Remedial Proposal for Chlorinated
Organics in Ground Water. The guidance document can be found on the DWM website:
http://portal.ncdenr.org/web/wni/hw/technical/guidance
The presence of organic and inorganic contaminants currently in the ground water in the
Alcoa Badin Works Plant Area must be determined in the evaluation of the potential
remedial technologies. The remedial technologies must be able to remediate the
hazardous constituents present in the ground-water to the North Carolina 15A NCAC 2L
Standards or the background concentration for the constituent. Due to the length of time
since the last ground-water Appendix IX analysis in the Alcoa Badin Works Plant Area,
Alcoa must collect ground-water samples from the two most contaminated monitoring
wells downgradient of the SWMUs and conduct an Appendix IX analysis on the samples.
Ground-water monitoring well MW - 6 was initially selected to be sampled during the
RFI process because of the concentration of cyanide and fluoride present in the well.
Organic contaminants should also be considered in the determination of the monitoring
wells to be sampled for Appendix IX analysis.
The Alcoa/Badin Landfill and Old Brick Landfill Ground-Water Sampling
In addition to total cyanide, fluoride, and standard field parameters, the Post Interim
Measures ground-water sampling for the Alcoa/Badin Landfill should include indicator
parameters that would also indicate if contaminants from municipal waste have been
released.
Due to the length of time since the previous ground-water Appendix IX analysis at the
Alcoa/Badin Landfill, Alcoa must collect a ground-water sample from the most
contaminated monitoring well downgradient of the Alcoa/Badin Landfill and conduct an
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Appendix IX analysis. The previous Appendix IX analysis was conducted on ground-
water monitoring well ABL - MW - 5 in the RFI process due to the concentration of
cyanide and fluoride in the well. Organic contaminants should also be considered in the
determination of the monitoring well to be sampled for Appendix IX analysis.
Badin Lake Surface Water Sampling
Surface water samples collected along the shore of Badin Lake adjacent to the
northeastern edge of the plant and the Old Brick Landfill should be analyzed for PCBs &
PAHs, as well as, total cyanide, fluoride, TCE, and standard field parameters.
Alcoa should also collect surface water samples from Little Mountain Creek to determine
if contaminants have been released from the Alcoa/Badin Landfill to Little Mountain
Creek. The surface water samples should be analyzed for, at a minimum, the same
constituents as the ground-water samples for the Alcoa/Badin Landfill.
Conducting Aquifer Tests
Alcoa believes that the aquifer in the North End of the Plant will "exhibit the
characteristics of a confined aquifer with no leakage" and the pumping tests will run for
at least 2 hours.
Alcoa proposes to characterize the hydraulic properties of the aquifer by conducting very
low flow rate pumping tests at eight ground-water monitoring wells in the north end of
the plant. The hydraulic properties will used in ground-water models to evaluate
corrective action alternatives at the site. Conducting a low flow rate pumping test for at
least 2 hours would have little impact on the aquifer's response to the stress and thus the
information would be of limited value.
The preferred method to determine aquifer hydraulic properties (transmissivity,
storativity, hydraulic conductivity, and ground water velocity, etc.) is a pumping test with
observation wells of sufficient duration and rate to stress the aquifer. The aquifer
response from observation wells would provide much more valuable data to determine
the representative hydraulic properties of an aquifer than that of a limited time, low flow
rate pumping test.
Provide detail why the low flow rate aquifer pumping test method is preferred or
equivalent to a pumping test to determine aquifer characteristics for the evaluation of
corrective action alternatives at the site.
4.0 Schedule
Alcoa should submit the Phase 3 report to the Hazardous Waste Section within ninety
days of completion of field activities. The schedule to complete field activities in Phase 3
needs to be revised and condensed. Task 2 - Water Quality Assessment to determine
effects of interim measures and cover system installation at the Alco/Badin Landfill and
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Old Brick Landfill can be reduced from two years to one year by collecting quarterly
samples instead of semi-annual samples.
By reducing the completion schedule for all field activities to one year and the submittal
of the report to DENR within ninety days of completion of field activities, the schedule
for submittal of the Phase 3 Report can be greatly reduced from 2.5 years.
Alcoa must submit quarterly status reports to the Hazardous Waste Section of the
progress of Phase 3. The status reports shall include the following information:
1. A description of the portion of the Phase 3 - CMS completed;
2. Summary of the findings;
3. Activities conducted;
4. Summary of any problems or issues encountered;
5. Summary of work to be conducted in the following quarter; and
6. Activities for the next reporting period.
5.0 Waste Consolidation
The Hazardous Waste Section will address the issue of waste consolidation in a
corrective action management unit under a separate cover.
In addition based on the March 29, 2010 letter to Alcoa, Alcoa should contact Karen
Knight of EPA Region 4 RUST Branch concerning PCB from the Alcoa facility.
"Based on its review of the PCB-related information provided to date, the EPA
RUST Branch has determined that Alcoa will need to provide additional
information concerning the PCB contamination in the sediment at Bad in Lake.
EPA requests that Alcoa pursue a risk-based disposal approval in accordance with
40 CFR 761.61(c), which requires submission of information to EPA pursuant to
40 CFR 761.61(a)(3). The purpose of the risk-based disposal approval is to ensure
that the final cleanup poses no unreasonable risk to health and the environment. It
is suggested that Alcoa use the Superfund Risk Assessment Guidance and the
PRGs for total PCBs and individual aroclors as initial screening levels. If Alcoa
thinks that there is sufficient information available to determine that no
unreasonable risk currently exists that should be stated in the submittal as well as
the reasoning and data supporting the
determination."
Also, Alcoa Badin is a facility on EPA's 2020 Baseline. Alcoa should be aware that EPA
has a goal that all facilities on the EPA 2020 Baseline have a remedy constructed and
operational by 2020. In order to meet that goal the North Carolina Hazardous Waste
Section expects Alcoa to have a remedy decision by January 2015 and the remedy
constructed and operational by 2017.