20070812 Ver 2_More Info Received_20101201

NCDENR
North Carolina Department of Environment and Natural
Beverly Eaves Perdue
Governor
Mr. Robert A. Prezbindowski
Alcoa Remediation
2300 North Wright Road
Alcoa, Tennessee 37701
Division of Waste Management
Dexter R. Matthews
Director
November 30, 2010
Sce z
Resources -
Dee Freeman
o ecrelary
8,1) ?/;: N @ 0 l
DEC 0 1 2010
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Reference: Section 5.0 - Waste Consolidation
Phase 3 - Engineering Data Collection Work Plan for the CMS
Alcoa, Inc.
Badin, North Carolina
NCD 003 162 542
Dear Mr. Prezbindowski:
The following are additional comments on the August 2010 Phase 3 - Engineering Data
Collection Work Plan for the Corrective Measures Study, concerning Section 5.0 - Waste
Consolidation.
Spent potlining from primary aluminum reduction is a listed waste from a specific source (40
CPR 26132 (K088)) with cyanide and fluoride being the primary constituents of concern. North
Carolina agrees that Alcoa has made a good faith effort to determine if a material is a listed
hazardous waste. Alcoa has already determined that spent potliner (SPL) has been disposed of in
the "Northwest Valley". Specifically the SPL was disposed of in SWMU 1, the On-Site
Landfill, SWMU 44, the Pine Tree Grove Area, and SWMU 46, the West SPL Area. This is
documented in the RCRA Facility Assessment, RCRA Facility Investigation Work Plan and
Report, in the Conclusion section of the Pine Tree Grove Area SWMUAssessment report dated
November 19, 1996, in the Notification of Newly Identified SWMU report dated September 22,
1999 and in this document. Because of this any material removed from SWMU 1, SWMU 44, or
SWMU 46 will be deemed a listed hazardous waste and must be handled as such.
In addition, Alcoa is aware that SWMU 35, the Old Waste Oil Storage Area has high
concentrations of PCBs in the soil. Alcoa must have EPA Region 4 RUST Branch approval
prior to moving waste from SWMU 35.
10uh Mai! S? iic e. Centel Rdeigh, North C cu ina 27699-1646
Phone [phone]', FA K 919-715-4061 i Internet: www wastenotnc.org
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Mr. Prezbindowski
Page 2
November 30, 2010
Prior to proceeding with plans to move or consolidate SWMU material Alcoa should meet with
the Hazardous Waste Section to discuss specifics concerning what materials can be moved, how
the material should be handled and the type of unit to which it can be moved.
If you have any questions concerning this information you should contact Bud McCarty at 919-
508-8552 bud. mccartyCOncdenr.gov or Rob McDaniel at 919-508-8553
rcabert.mcdan cl(a),nck r.r,oV .
Sincerely,
Robert C. McDaniel
Facility Management Branch
Hazardous Waste Section
cc: John E. Johnston, US EPA, Region 4
Sean Morris
Tom Belnick, NC DWQ
kTohn Dorney, NC DWQ
Andrew Lucas, Stanly County Manager
rc: Elizabeth Cannon
Harold A. McCarty
Vance Jackson
C:AmeI\rcm\wastcconsIidation