20070812 Ver 2_More Info Received_20110123

Beverly Eaves Perdue
Gcvernor
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North Caroiir7a Ce~artment of Environment and iV'atural Resources
Division of Waste Management
Dexter R. Matthews
Director
January 18, 2011
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Robert A. Prezbindowski
Alcoa Remediation
2300 North Wright Road
Alcoa, Tennessee 37701

Reference: Phase 3 -Engineering Data Collection Work Plan for the CMS
Alcoa, Inc.
Badin, North Carolina
NCD 003 162 542
Dear Mr. Prezbindowski:
Dee ree((~an
Secretary
The Hazardous Waste Section has completed the review of Alcoa's December 21, 20101etter in
response to the Hazardous Waste Section's comments on Alcoa's Phase 3 -Engineering Data
Collection Work Plan for the Corrective Measures Study for the Badin facility.
The attached comments identify specific issues which must be addressed prior to the approval
the Phase 3 Worl< Plan. Alcoa must submit revisions to the work plan addressing these
comments within 30 days of the receipt of this letter.
If you have questions concerning this matter please contact me at [phone].
Sincerely,
Robert C. McDaniel
Facility Management Branch
Hazardous Waste Section
cc: John E. Johnston, US EPA, Region 4
Sean Morris
Tom Belnick, NC DWQ
,John Dorney, NC DWQ
Andrew Lucas, Stanly County Manager
1646 Mail Service Center, Raleigh, l~lorth Carolina 21699-1646
Phone: [phone] FAX: [phone] `.Internet: www.was±enoinc.org
An Equal Gpportunity'~. Affinnati•ie Alien Bnpbeyer
rc: Elizabeth Cannon
Harold A. McCarty
Vance Jackson
Otte
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Phase 3 -Engineering Data Collection Work Plan Comments
Alcoa, Inc.
Badin, North Carolina
NCD 003 162 542
Old Waste Oil Storage Area (SW1V1U No. 35)
Alcoa proposes to test for total cyanide, fluoride, and polychlorinated biphenyls (PCBs) in the
soil sampling program for the Old Waste Oil Storage Area, but not for polycyclic aromatic
hydrocarbons (PAHs). Alcoa acknowledges the presence of PAH contaminants in the soil, but
contends that the PAH data corresponds to the PCB data, thus it is not necessary to sample for
PAHs when the soil samples will be analyzed for PCBs.
It is the Hazardous Waste Section's position that Alcoa must sample for all hazardous
constituents found to be present in the environmental media during the CMS process to
determine the presence, concentration, and extent of the contaminants during the C1~1S and
remediation process. Alcoa will need to determine the contaminants present prior to excavation.
Therefore Alcoa must also include PAHs in the soil sampling program for the Old Waste Oil
Storage Area (SWMU 35).
Alcoa should also respond to the remaining points in the comments in the Hazardous Waste
Section's November 5, 2010 letter concerning Old Waste Oil Storage Area (SWMU No. 35). In
addition, as stated in the November 30, 20101etter regarding waste consolidation, soils at the Old
Waste Oil Storage Area contain high concentrations of PCBs. Alcoa must have EPA Region 4
RUST Branch approval prior to moving waste from SWMU 35.
2.1.2 Task 2 -Water Quality Assessment
Alcoa Badin Works Plant Area Ground-Water Sampling
When evaluating the potential for the use of monitored natural attenuation as a remedial strategy
for ground-water contamination, along with the EPA guidance document Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water, Alcoa should use the
HWS document Guidance on Develonin~ a Monitored Natural Attenuation Remedial Proposal
for Chlorinated Organics in Ground Water as well. The guidance document can be found on the
DWM website:
http://portal.ncdenr.org/web/wm/hw/technical/guidance
The AlcoaBadin Landfill and Old Brick Landfill Ground-Water Sampling
In addition to the indicator parameters list proposed by Alcoa (pH, specific conductivity,
dissolved oxygen, and temperature), Alcoa should include total organic carbon, chemical oxygen
demand, biological oxygen demand, and turbidity in the indicator parameter list for ground-water
monitoring wells sampled at site.

Waste Consolidation
The Hazardous Waste Section provided comments to Alcoa on November 30, 2010 concerning
Section 5.0 Waste Consolidation of the Phase 3 -Engineering Data Collection Work Plan for the
CMS. Alcoa may include any concerns regarding waste consolidation in the response to this
letter.
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