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HomeMy WebLinkAboutNC0000311_Authorizaion to Construct_200102211 a lb'AI'FIZS FDGF ENAIROVMENTAL, LLC O4901 WATERS EDGE DRIVE, .SUITE 100 • RALEIGH, NC 27606 • PHONE 919.859.9987 • FAx 919.859.9930 February 21, 2001 Ms. Jackie Nowell North Carolina Department of Environment and Natural Resources Division of Water Quality- NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699 -1617 Reference: Authorization to Construct Plan Mitchell - Bissell Industries, Incident # 13005 Rosman, North Carolina Waters Edge Environmental Job No. R 1 -17 Dear Ms. Nowell: The subject M -B Industries, Inc. (M -B) owns and operates a metal working /fabrication facility located along US Highway 64 west of Rosman, Transylvania County, North Carolina. Typical processes at the facility include; chrome plating, zinc plating, cyanide brine heat treating (ceased in December 1980), and various machining activities. Presently, wastewater is treated by a permitted wastewater treatment system that discharges to the West Fork of the French Broad River. M -B is currently classified as a small quantity generator of hazardous waste under the Resource Conservation and Recovery Act (RCRA). The primary hazardous materials shipped off site are F006 wastes associated with electroplating operations. M -B also generated solvents from cleaning activities (17001 wastes) in the past. M -B presently uses a Safety -Kleen application for cleaning activities at the facility. On August 16, 1995, the North Carolina Department of Environment and Natural Resources (NCDENR), Hazardous Waste Section (HWS) conducted a RCRA inspection of the M -B facility. Laboratory analytical results from four water supply well (WSW) samples obtained on September 29, 1994, by the HWS indicated that WSW #1 and WSW #2 demonstrated elevated levels of trichloroethene (TCE) and tetrachloroethene (PCE). However, samples obtained on August 16, 1995, by the HWS indicated that WSW #2 and WSW #3 had elevated levels of TCE and PCE, similar to the September 1994 laboratory results. Based on the RCRA inspection and WSW analytical results, a Notice of Violation (NOV), dated February 22, 1996, was issued. As a result of the NOV, Aquaterra Engineering, Inc. ( Aquaterra) commenced site analysis activities in March of 1996. LJ M -B Authorization to Construct February 21, 2001 01 -031 o Page 3 of 5 partially weathered rock interface (estimated at a depth of 40' below ground surface (bgs)); and EW -11, a new deep extraction well (approximately 100' bgs) with a 30 to 50 foot - screened interval located near monitoring well MW -11. Two of the existing water supply wells will also be incorporated into the pump and treat system; WSW #2 and #3 (see Figure 3). Waters Edge feels that this will both target the source area and limit the downgradient migration of the COC. Based on Waters Edge's knowledge of this site, along with the pump tests and experience with chlorinated solvents, each extraction point is estimated to have an effective radius of influence (ROI) of approximately 100 -150 feet; however, this will be verified by a limited drawdown test conducted during system startup. The ground water with elevated VOCs will be sufficiently encompassed by the ROI. It is anticipated that this initial action will reduce the PCE concentrations in the downgradient wells sufficient to eventually allow natural attenuation supplemented with carbon filtration systems attached to several of the existing private supply wells to reduce VOC concentrations to below North Carolina Groundwater Standards (NCGS). The pump and treat system will utilize a shallow tray aeration treatment system, with an initial throughput of approximately 60 gpm, with a maximum capacity of 160 gpm, should adjustments be deemed necessary from subsequent sampling events (Appendix B). Waters Edge has proposed this reduction from Aquaterra's original 250 -gpm capacity system to more reasonably reflect field experience with pumping capacity for multiple wells located within the same aquifer. The system is being designed to provide for the efficient removal of PCE, thereby eliminating the need for secondary carbon treatment to meet the current NPDES discharge limits (Appendix Q. Treatment system upgrades such as bag filtering to remove some isolated incidents of elevated chromium and lead concentrations may be added at a later date pending evaluation of additional ground water sampling data. To supplement the active removal of the COC in the source area, Waters Edge will install a Soil Vapor Extraction (SVE) system in the delineated source area in the southeastern portion of the original building (see Appendix D). The SVE system will initially consist of two SVE wells installed approximately 25 feet apart (see Figure 2). The wells will be 2 inches in diameter, drilled to approximately 2 -feet above the water table (approximately 8 -feet bgs), and screened a minimum of two feet above the water table. Based on data from the boring logs included in Aquaterra's Corrective Action Plan and Addendum (contained in proposed NPDES permit modification in Appendix D), it is assumed that a 25 -foot ROI can be achieved by these SVE wells. The SVE system will consist of a Roots 36 URAI 10 HP blower (or equivalent), moisture separator, vacuum relief valve, Warrick level switches, and inline filter /silencer, and transfer pump from moisture separator to air stripper (see Figure 4 and 4A). The blower and motor has been sized to produce 200 ACFM airflow at 12" of Hg. The SVE system O is oversized to allow for additional SVE wells to be installed if warranted. Based on worst -case soil data and air emissions calculations from the system, the SVE system will M -B Authorization to Construct February 21, 2001 01 -031 • Page 4of5 not require an air permit. From 15A NCAC 2D.0518, total volatile organic carbons must be less than 40 lbs. /day. Air emissions presented in Aquaterra's Corrective Action Plan Addendum were calculated to be less than 15- lbs. /day total VOCs. All liquid produced by the SVE system will be discharged to the air stripper for treatment. The piping from the wells to the SVE will be Schedule 80 PVC and will either be trenched under the concrete slab or piped along walls and /or overhead pipe racks. Each SVE effluent pipeline will be constructed with a ball valve and vacuum gauge, located at the system manifold connection. This will serve as a throttling device for the vapor recovered from the SVE points, to allow for precise adjustment of the flow rates. The proposed NPDES permit application is contained in Appendix D and additional information requested by DENR (Ms. Natalie Sierra) is contained in Appendix E. Based upon the Authorization to Construct Guidance Document, we have supplied the following information: 1. Letter designating consultant as the authorized representative- Appendix F 2. Three Sets of Detailed Plans and Specifications- These plans and specifications were contained in the NPDES permit modification contained in • Appendix D. We have included three copies of the drawings, which are shown in Figures 2 to 5A, which are sealed by a licensed NC Professional Engineer. These drawings are also stamped "Final Plans- Not for Construction. " Manufacturer's specifications are included in the CAP, NPDES permit, and attached to the Addendum to the Corrective Action Plan. We have included these specifications in Appendix B. 3. Two sets of design calculations and hydraulic profiles are included in the CAP and CAP Addendum (contained in the proposed NPDES permit modification in Appendix D). 4. Three copies of the Flow Schematic are included as Figure 4A and 5A. 5. Since this is not a modification to an existing facility, no Construction Sequence Plan for continuous operation is required. 6. Since the shallow tray stripper has been demonstrated as an effective treatment for volatile organic compounds, it is felt that the facility will be able to meet the permit requirements. Manufacturer's specifications and performance data are included in Appendix B. Some of the initial activities for the well installation have been initiated since the CAP has been accepted. We would like to begin construction of the treatment system as soon as we get authorization from you. A tentative schedule is as follows: • • C *B. DOBBINS WELL 0 100 200 400 Scale in Feet D. DOBBINS VELL LEGEND ® Deep Well (Tap of Bedrock) Water Supply Well Shallow Well Property Line ii ii r"4," � 1 IJ 1 WMA WN vil M INN lug SITE VICINITY MAP PMI*d M -B INDUSTRIES Transylvanla County, North Carolina Author Dmuping Law— Date mbb R1 -17 1 -17 -99 Job No, Revteien JNB%— S0411e R1 -17 02 -06 -01 1 1' = 200' J r I N CHROME SECONDARY DEPT 3277 SF I o a 4 -SLIDE DEPT 950 SF a c 2753 SF TOOL ROOM I 2197 SF N Y QC, DEPT, SHIPPING L = - Al V INVENTORY 2471 SF F-1 Z H 1810 SF r 4 aH I RAW MATERAL BLACKING raw 1833 SF 1833 SF I N PRESS DEPT 1833 SF NOTE, FINAL PLANS - NOT FOR CONSTRUCTION TOOL ROOM OFFICE 1200 SF IIFFICr G BENDING AREA ( I VIDE 2841 SF I (CUTTING 748 SF I I ZINC PLATING COOLIND DEPT. 2275 SF 2470 SF PRESS ROOM 2073 SF AYP STORAGE 2530 SF SCREW MACHIES L MACHINING 1711 SF AYP DEPT, �`•''�uaruN�rh 4002 SF SHIPPING L �`�� CARoti % RECEIVING 2091 SF �.OEE SSl j. � � • ,�;•. 'I 4� SEA( • • e ' 17 ' SHIPPING 6 i ` • RECEIVING G ,.•�J LEGEND Extraction Well .SVE Proposed SVE Point Location Iidhor Dmwow Layers Dale Mile mhb RI -17 11 -6 -00 Interior SVE Points & Ground Water Extraction Well Location Map WATERS EDGE ErffMONMENTA14 LLC Job NO. Revision l+iyum Soak JPrv* l s INDUSTRIES R1 -17 02 -06-01 2 NTS Transylvania County, North Carolina N CHROME Y YJ PLATING o a N 950 SF a c a m N Y l7 ? = NEEDING L HUFFIN Z H 1810 SF a 4 aH wm raw N N TOOL ROOM OFFICE 1200 SF IIFFICr G BENDING AREA ( I VIDE 2841 SF I (CUTTING 748 SF I I ZINC PLATING COOLIND DEPT. 2275 SF 2470 SF PRESS ROOM 2073 SF AYP STORAGE 2530 SF SCREW MACHIES L MACHINING 1711 SF AYP DEPT, �`•''�uaruN�rh 4002 SF SHIPPING L �`�� CARoti % RECEIVING 2091 SF �.OEE SSl j. � � • ,�;•. 'I 4� SEA( • • e ' 17 ' SHIPPING 6 i ` • RECEIVING G ,.•�J LEGEND Extraction Well .SVE Proposed SVE Point Location Iidhor Dmwow Layers Dale Mile mhb RI -17 11 -6 -00 Interior SVE Points & Ground Water Extraction Well Location Map WATERS EDGE ErffMONMENTA14 LLC Job NO. Revision l+iyum Soak JPrv* l s INDUSTRIES R1 -17 02 -06-01 2 NTS Transylvania County, North Carolina NOTEi FINAL PLANS - NOT FOR CONSTRUCTION o e e ZVI SHIPPING L RECEIVING J F I SECONDARY DEPT 3277 SF 4 -SLIDE DEPTI CHROME 2753 SF TOOL ROOM r� I 2197 SF W PLATING G.C. DEPT, <� SHIPPING L EV -19 - +. INVENTORY 2471 SF _ w N RAW MATERAL BLACKING 1833 SF I 1833 SF ZVI SHIPPING L RECEIVING TOOL ROOM OFFICE 1200 SF NtEAX AREA i BENDING AREA I I VIDE 2841 SF i i 748TSF I I ZINC PLATING COOLIND DEPT. 2275 SF 2470 SF PRESS ROOM 2073 SF AYP STORAGE 2530 SF AYP DEPT. 4002 SF SHIPPING L RECEIVING 2091 SF SCREW MACHIES L MACHINING 1711 SF LEGEND Extraction Vell .SVE Proposed SVE Paint Location Author Dmwing Layers Date Title mbb Rt -t7 11-6-00 Interior SVE Points & Ground WATEBS EDGE ENV�ONMENI'AL, LLC Water Extraction Well Location Map Job Na A.viaion Figure scat. Preli of RI-17 02 -06 -01 Z MS N-11 INDUSTRIES Trnnsylvnnla County, North Carollnn N C Lj CHROME r� W PLATING `� <� 950 SF = -w _ w N z NEEDING L HUFFING ZV�1 1810 SF fA y TOOL ROOM OFFICE 1200 SF NtEAX AREA i BENDING AREA I I VIDE 2841 SF i i 748TSF I I ZINC PLATING COOLIND DEPT. 2275 SF 2470 SF PRESS ROOM 2073 SF AYP STORAGE 2530 SF AYP DEPT. 4002 SF SHIPPING L RECEIVING 2091 SF SCREW MACHIES L MACHINING 1711 SF LEGEND Extraction Vell .SVE Proposed SVE Paint Location Author Dmwing Layers Date Title mbb Rt -t7 11-6-00 Interior SVE Points & Ground WATEBS EDGE ENV�ONMENI'AL, LLC Water Extraction Well Location Map Job Na A.viaion Figure scat. Preli of RI-17 02 -06 -01 Z MS N-11 INDUSTRIES Trnnsylvnnla County, North Carollnn 0 ® MW -9 WSW -3 / Q- MW-10 rive MW -12 38i 17669 e • F � V-S J. � • / sW�. ti F..t r Q. LEGEND .SVE Proposed SVE Point Location gg waste ater �Trnt Pt t / 4 Sall Boring Locatlon 03996) / S •SB -9 Solt Baring Location (2000) Deep Well (Top of Bedrock) 'Autfall / WSW er V"-N g � d � � a YtE a Pe•1 — Varlea s — bbvm won NOTE, FINAL PLANS - NOT FOR CONSTRUCTION Water Supply Y10I j8! Shallow Well IN of Trwph ao tmve s�. vi.. M Proposed Recovery Well m.0 .......... . Property Line Mier I — — — River Bad Er 36 — — — Former River Bed NOTEo Discharge from the e0.lroundconnected to Treatment PIPEN(H DETAIL existing discharge from the Waste Water Treatment Plant (WVTP) Author Dr2010010 Layer+ Date r lie n,bb RI-17 11-6 -00 DPE Distribution Lines Location Map A-NAM 00"Q4PE7� A EDGE ENVIRONMENTAL, LLC .rob Ho. per talon Figure soot. Pojbot R1 -17 OZ -06-01 J 1' - 100' s INDUSTRIES Transylvania County, North Carolina ® Discharge from the e0.lroundconnected to Treatment PIPEN(H DETAIL existing discharge from the Waste Water Treatment Plant (WVTP) Author Dr2010010 Layer+ Date r lie n,bb RI-17 11-6 -00 DPE Distribution Lines Location Map A-NAM 00"Q4PE7� A EDGE ENVIRONMENTAL, LLC .rob Ho. per talon Figure soot. Pojbot R1 -17 OZ -06-01 J 1' - 100' s INDUSTRIES Transylvania County, North Carolina t I r F600 fr• vau t�::: to T.i T. Trt J Carlrf►al h" Piping Detail Outside Building .•�LH CAROt" Pvc Q '9lt • S L SW Lay"d S • i y'NEMP . • NOTE too@#����n�Naa FINAL PLANS - NOT FOR CONSTRUCTION r- . r AbnO Plan vim IJ 1rA M bg/E*-4 3 ierlr rlr O TT r nmw n>a lrit L r rvc Ldi ■ a d Author mbb 'WATERS EDGE ENVIRONMENTAI., IM Job No. R1 -17 SVE Blower Detail Piping Detail Inside Building / C;o=cte Slab 2" PVC tv[ t.,vrt Dmwing Layers Date R1 -17 11 -6-00 Bevieion Fi9wv Some 02 -0e -01 4 NTS Title R1pht SW View WE SVE BLOWER SCHEMATIC Projist N -B INDUSTRIES Transylvania County, North Carolina FILTER w QPARTICULATE w FILTER DISCHARGE N SILENCER SILENCER go KNOCK- OUT I li TAN K SVE BLOWER o� cr6 0� GALLON �a HOLDING CENTRIFICAL TANK PUMP G1 it7 m .•'`H CAR O •. D o��,,.....,, ��,y�•; q = LEGEND SEAL r z 17 669 ; f ?• Q PRESSURE INDICATOR �'••�, REM BALL VALVE - 2���n�N� BLEEDER VALVE FLOW METER SAMPLE PORT WATER TABLE Author Drawing Layers Dale Title mbb R1 -17 02 -08 -01 SVE Piping Diagram A His EDGE ENVl�O1�IMEN iAL, LW Jo6 No. PAmision Figure scab PFD*W M — R1 -17 02-14-01 �4A NTM-11 INDUSTRIES Troneyhanla County, North Carolina L-1 TI Gl C M CJ1 D Q SUBMERGED 0 w o! L) 3 w w RECOVERY WELL (TYPICAL) 1K GALLON EQUALIZATION TANK 0 SHALLOW TRAY TRANSFER AIR PUMP STRIPPER ZN CARo OEE SSI0,y,q a� : .. Ileg N• ��a l Author Dmu"y Lay-a mbb RI-17 Job No. Rw{+1on PVWW R1 -17 02 -14-01 8A AIR BLOWER �7— A VOCs TO ATMOSPHERE DISCHARGE TO SURFACE WATERS LEGEND Data ritle 02 -08 -01 Ground Water System Piping Diagram Soalf Pro" M —B INDUSTRIES NTS Tronsyhwnia County, North Carolina TH ROTTLE VALVE FLOW METER SAMPLE PORT V WATER LEVEL Data ritle 02 -08 -01 Ground Water System Piping Diagram Soalf Pro" M —B INDUSTRIES NTS Tronsyhwnia County, North Carolina e C � I 00,�- 1000 Gallon Equalization Tank Air Transfer 16.0 Blower pump 60700"► rAnw 04 3 SHALLOW TRAY STRIPPER No: 3631 •; �Q •b �'� Control Panel i SE AI 10.0 's 17 669 • o �? Effluent to West Fork of French Broad R'nrsr NOTE: FINAL ,Pr NOT FOR CONSTRUCTION .0 Author lbawbW layers !late ritie AT=1l lm6i 1fLC mbb R1 -17 0 9 -3 -97 Treatment System Schematic Job Xn Jbwwon rwure Sawn pMiMt Y -B INDUSTRIES RI-17 02 -06 -01 5 nto Transylvania County. North Carolina a 0 Table 1. Soil Laboratory Analytical Results - M -B Industries, Rosman, North Carolina May 22, 1996 Soil Boring ID (Sample Depth) Parameter SB -1 SB -1 SB-2 SB-2 SB -3 SB -3 SB4 SB -4 SB-5 SB -5 (0 -1 ft) (4-5 ft) (0 -1 ft) (1 -2 ft) (0 -1 ft) (1 -2 ft) (0 -1 ft) (4-5 ft) (0 -1 ft) (3 -4 ft) Inorganics (mg/kg) Aluminum 8,600 7,600 9,490 5,700 6,800 5,600 9,800 8,200 8,700 10,000 Total Cyanide 0.66 <0.10 0.43 0.31 0.39 1.02 0.05 0.23 0.47 0.12 Zinc 66 39 35 32 110 480 23 24 26 26 Arsenic <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 Barium 37 27 32 20 28 21 29 39 27 42 Cadmium <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1 Chromium 40 6.6 53 34 20 31 7.4 8.2 7.8 8.4 Lead 16 3.9 8.5 9.3 6 4.8 5.1 4.3 4.3 4.4 Mercury <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 Selenium <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 Silver <1.0 <1.0 <1.0 1.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 SVOCs (pg/kg) No Compounds Detected Above Method Detection Limits VOCs (pog) Tetrachloroethene <7 <7 19 11 8 <6 <l 36 <7 <6 Oil & Crease (mg /kg) 34 27 29 <10 70 <10 <10 <10 <10 41 SB soil boring mg /kg milligrams per kilogram or parts per million pg /kg micrograms per kilogram or parts per billion SVOCs semivolatile organic compounds according to SW -846 Method 8270 VOCs volatile organic compounds according to SW -846 Method 8260 ft feel below ground surface e e o Table 1 (cont.) Soil Laboratory Analytical Results - M -B Industries, Rosman, North Carolina May 22, 1996 Soil Boring ID (Sample Depth) Parameter SB -6 SB-6 SB -7 SB -8 SB -9 SB -10 (0 -1 ft) (2 -3 ft) (1.5 -2 ft) (34 ft) (34 ft) (34 ft) Inorganics (mg /kg) Aluminum 10,000 11,000 4,300 10,000 Total Cyanide 0.27 0.14 0.15 0.16 Zinc 29 36 24 48 Arsenic <0.5 <0.5 <0.5 <0.5 Barium 28 29 27 34 Cadmium <1.0 <1.0 <1.0 <1.0 Chromium 41 24 3.4 8.8 Lead 5.6 5.6 2.2 7.9 Mercury <0.10 <0.10 <0.10 <0.10 Selenium <0.50 <0.50 <0.50 <0.50 Silver <1.0 <1.0 <1.0 <1.0 SVOC.s (µg /kg) X330 <330 <330 NA Di- n -octyl phthalate <330 <330 -330 X330 VOCs (µg /kg) 17 <6 <6 NA Tetrachloroethene <7 <6 <6 <8 Toluene </ <6 <6 <8 Oil & Grease (mg/kg) 68 52 <10 <10 SB soil boring mg /kg milligrams per kilogram or parts per million p g /kg micrograms per kilogram or parts per billion SVOCs semivolatile organic compounds according to SW -846 Method 8270 VOCs volatile organic compounds according to SW -846 Method 8260 ft feet below ground surface NA not analyzed SB -12 Duplicate SB -1I of SB -11 BG -1 (7 ft) (7 ft) (1.5 -2 ft) 8,300 12,000 10,000 11,000 14,000 ND 0.72 ND 0.29 0.22 52 53 86 100 55 <0.5 <0.5 <0.5 <0.5 <0.5 29 40 36 35 35 <1.0 <1.0 <1.0 <1.0 <1.0 17 63 8.3 10 8.1 5.6 12 4.9 4.8 16 <0.10 <0.10 <0.10 <0.10 <0.10 <0.50 <0.50 <0.50 <0.50 <0.50 <1.0 <1.0 <1.0 <1.0 <1.0 460 X330 <330 <330 NA <7 <6 <6 <6 NA II 17 <6 <6 NA <10 <10 16 302 0 0 Table 1 (cunt.) Soil Laboratory Analytical Results - M -B Industries, Rosman, North Carolina October 10, 2000. Soil Boring ID (Sample Depth) Parameter Inorganics Chromium Lead 11Y)Cs Tetrachloroethene 1,2,4- Trimethylbenzene Total Xylenes P -1 P -5 Soil Water (8 -9 ft) (mg/k8) (A-2/L) 120 5.4 24 0.88 (µg/kg) (µ-'•n ) <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 P -2 P -5 Soil Water (5-6 ft) (mgfk8) (µg/L) 250 31 7.5 0.72 (µg/kg) (µg/L) <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 P = Probe Designation mg /kg (L) = milligrams per kilogram (liter) or parts per million ftg /kg (L) = micrograms per kilogram (liter) or parts per billion VOCs = volatile organic compounds according to SW -846 Method 8260 ft =feet below ground surface P -3 P -5 Soil Water (5 -8 ft) (mg/kg) (µgn-) 87 12 8.8 0.41 (µg/kg) (49/L) <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 P-4 P -5 Soft Water (4 -5 ft) (mg/kg) (µg�L) 20 0.38 9.3 0.25 (µg/kg) (µgn-) 6000 4700 100 <5.0 200 10 11 P -5 Soil Water (6 -7 ft) (mg/kg) (n/L) 17 0.24 10 0.16 (µg/kg) (µ9f-) 740 500 <54 <5.0 <54 <5.0 11 0 0 0 Table 2. Ground Water Laboratory Analytical Results - M -B Industries, Rosman, North Carolina. WSW water supply well mg /L milligrams per liter or parts per million fig /L micrograms per liter or parts per billion SVOCs semivolatile organic compounds according to SW -846 Method 8270 VOCs volatile organic compounds according to SW -846 Method 8260 NA not applicable ND non detect Numbers in bold indicate concentrations over the NC Ground Water Quality Standards Inorganics ftlL) VOC's (frg/L) SVOC's Sample ID Sample Date Alwniman Total Zinc Arsenic Banwn Cadmium Hexavalent Chromiwn Lead Selenium Silver cis -1,2 Trichloroethene Tettachloroeame (pg /L) Cyarude Chromiwn dichloroethene WSW -] 3/3/98 <0.05 0.002 0.032 <0.005 <0.010 <0.010 NA <0.010 <0.005 <0.005 <0.010 <5 <5 <5 ND 8/9/99 <0.25 <0.002 0.022 <0.01 <0.005 <0.001 <0.05 <0.005 <0.01 <0.02 <0.002 Q Q Q NA 2/24/00 <0.20 NA 0.25 <0.005 <0.01 <0.001 NA <0.005 <0.003 <0.005 <0.005 Q Q Q NA 10/13/00 <0.10 <0.005 <0.005 <5.0 <5.0 <5.0 WSW -2 3/3/98 <0.05 <0.002 <0.01 <0.005 <0.010 <0.010 NA 0.2 <0.005 <0.005 <0.010 <5 <5 53 ND 8/9/99 <0.25 <0.002 <0.01 <0.01 <0.005 <0.001 0.13 0.12 <0.01 <0.02 <0.002 Q Q 33 NA 2/24/00 <0.20 NA 0.022 <0.005 <0.01 <0.001 NA 0.125 <0.003 <0.005 <0.005 Q Q 26.2 NA 10/13/00 <0.10 0.13 0.07 <5.0 <5.0 41 WSW -3 313/98 0.08 0.002 3.6 0.008 <0.010 <0.010 NA 0.011 0.21 <0.005 <0.010 <5 5 150 ND 8/9/99 <0.05 0.003 <0.01 <0.01 <0.005 <0.001 <0.05 <0.005 <0.01 <0.02 <0.002 Q 14 700 NA 2/24/00 <0.20 NA <0.02 <0.005 <0.01 <0.001 NA 0.03 <0.003 <0.005 <0.005 Q 6.9 309 NA 10 /13/00 <0.10 0.012 <0.005 <5.0 18 510 WSW4 3/3/98 <0.05 <0.002 0.08 <0.005 <0.010 <0.010 NA <0.010 0.043 <0.005 <0.010 0 <5 <5 NA 8/9/99 <0.25 <0.002 0.016 <0.005 <0.01 <0.001 <0.05 <0.005 <0.01 <0.02 <0.002 Q Q Q NA 2/25/00 <0.20 NA 0.089 <0.005 <0.005 <0.001 NA <0.005 <0.003 <0.005 <0.005 Q Q Q NA 10/13/00 Not Sampled WSW -5 3/3/98 <0.05 <0.002 0.043 <0.005 <0.010 <0.010 NA <0.010 0.018 <0.005 <0.010 NA NA NA ND (Duplicate 819/99 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA of WSW -4) NC Ground Water Quality Standard NA 0.154 2.1 0.05 2 0.005 0.05 0.05 0.015 0.05 0.018 7 2.8 0.7 NA WSW water supply well mg /L milligrams per liter or parts per million fig /L micrograms per liter or parts per billion SVOCs semivolatile organic compounds according to SW -846 Method 8270 VOCs volatile organic compounds according to SW -846 Method 8260 NA not applicable ND non detect Numbers in bold indicate concentrations over the NC Ground Water Quality Standards 0 0 Table 2 (cont.) Ground Water Laboratory Analytical Results - M -B Industries, Rosman, North Carolina. WSW water supply well mg,L milligrams per liter or parts per million pg /L micrograms per liter or parts per billion SVOCs semrvolanle organic compounds according to SW -846 Method x270 VOCs volatile organic compounds according to SW -846 Method 8260 NA not applicable ND non detect Numbers to bold indicate concentrations over the NC Ground Water Quality Standards VOC's (pg/L) SVOC's cis -1,2 Tnchloroethene Tettachloroethene Inorganics (mg/L) <2 Sample ID Sample Date Aluminum Total Zinc Arsenic Barium Cadmium Hexavalent Chromium Lead Selenium Silver <2 <2 NA Cyanide <2 <2 NA <5.0 Chromium <5.0 <2 <2 MW -5 8/18/99 0.225 <0.010 <0.020 <0.005 0.141 <0.001 <0.01 <0.005 <0.003 <0.005 <0.005 NA 2123/00 5.6 NA 0.025 <0.005 0.095 <0.001 NA 0.007 0.007 <0.005 <0.005 <2 10 /13 /00 <2 NA 0.17 <5.0 <5.0 4 0.041 0.056 NA <2 MW-6 8/18/99 0.196 <0.010 <0.020 <0.005 0.016 <0.001 <0.01 <0.005 <0.003 <0.005 <0.005 142 2123/00 49.3 NA 0.132 0.007 0.0821 <0.00I NA 0.027 0.074 <0.005 <0.005 NA 10 /13 /00 <5.0 8 0.19 0.05 0.13 MW -7 8/18/99 0.269 <0.010 <0.020 <0.005 0.028 <0.001 2.00 2.18 <0.003 <0.005 <0.005 224/00 7.35 NA <0.02 <0.005 0.054 <0.001 NA 0.199 0.003 <0.005 <0.005 10/12/00 <0.10 1.3 <0.005 MW -8 8/18/99 <0.05 <0.010 <0.020 <0.005 0.018 <0.001 <0.01 <0.005 <0.003 <0.005 <0.005 223/00 90.8 NA 0.325 0.012 1.84 0.002 NA 0.048 0.08 <0.005 <0.005 10 /13 /00 0.60 0.14 0.19 MW -9 9/17/99 0.326 <0.010 6.31 <0.005 0.123 <0.001 <0.01 <0.005 0.022 <0.005 <0.005 225/00 0.096 NA 1.21 <0.005 <0.01 <0.001 NA <0.005 <0.003 <0.005 <0.005 10/13/00 4.9 <0.005 0.008 MW -10 9/17/99 0.553 <0.010 0.18 <0.005 0.028 <0.001 <0.01 0.006 0.006 <0.005 <0.005 2/23/00 0.085 NA 0.138 <0.005 <0.01 0.005 NA <0.005 <0.003 <0.005 <0.005 10/12/00 <0.10 <0.005 <0.005 MW -I1 9/17/99 6.27 <0.010 0.043 <0.005 0.035 <0.001 <0.01 <0.005 0.003 <0.005 <0.005 2/24/00 16.40 NA 0.034 <0.005 0.075 <0.001 NA 0.012 0.01 <0.005 <0.005 10/12/00 0.15 0.030 0.046 MW -12 9/17/99 1.57 <0.010 <0.020 <0.005 0.04 <0.001 3.7 2.74 <0.003 <0.005 <0.005 2/24/00 51.2 NA 0.077 <0.005 0.167 <0.001 NA 2.26 0.028 <0.005 <0.005 10/12/00 <0.10 1.9 0.046 WSW water supply well mg,L milligrams per liter or parts per million pg /L micrograms per liter or parts per billion SVOCs semrvolanle organic compounds according to SW -846 Method x270 VOCs volatile organic compounds according to SW -846 Method 8260 NA not applicable ND non detect Numbers to bold indicate concentrations over the NC Ground Water Quality Standards 0 VOC's (pg/L) SVOC's cis -1,2 Tnchloroethene Tettachloroethene (p91L) dtchloroethem <2 <2 <2 NA <2 <2 <2 NA <5.0 <5.0 <5.0 <2 <2 <2 NA <2 <2 <2 NA <5.0 <5.0 <5.0 <2 <2 3.9 NA <2 <2 <2 NA <5.0 <5.0 <5.0 <2 <2 58.3 NA <2 <2 <2 NA <5,0 <5.0 30 <2 <2 <2 NA <2 <2 <2 NA <5.0 <5.0 <5.0 4 48 515 NA <2 <2 9.7 NA <5.0 <5.0 19 <2 <2 12.7 NA <2 <2 142 NA <5.0 <5.0 250 7.7 8.2 20.8 NA <2 <2 <2 NA <5.0 <5.0 8 0 e o 0 Table 2 (cons.) Ground Water Laboratory Analytical Results - M -B Industries, Rosman, North Carolina. WSW water supply well mg1L milligrams per liter or parts per million fig /L micrograms per liter or parts per billion SVOCs semivolarile organic compounds according to SW -846 Method 8270 VOCs volatile organic compounds according ro SW -846 Method 6260 NA not applicable ND non detect Numbers to bold indicate concentrations over the NC Ground Water Quality Standards Inorganics (mg /L) VOC's (Eeg/L) SVOC's Sample ID Sample Date Almnutum Total Znle Arseruc Barium Cadmtmn Hexavalent Chromiwn Lead Seletuum Silver cis -1,2 Tnchloroethene Tetrachloroethene (pg/L) Cyanide Ctuornum dichloroethene MW -13 11/17/99 4.75 <0.010 0.04 <0.005 0.051 <0.001 <0.01 0.005 0.005 <0.005 <0.005 <2 6.9 83.7 NA 2/24100 0.15 NA 0.125 <0.005 <0.01 <0.001 NA <0.005 <0.003 <0.005 <0.005 <2 5.8 61 NA 10/12/00 <0.10 <0.005 <0.005 <5.0 8 100 MW -14 11/17/99 15.8 <0,010 0.075 <0,005 0.082 <0.001 <0.01 0.018 0.014 <0.005 <0.005 <2 <2 46.6 NA 2124/00 64.0 NA 0.356 0.009 0.38 0.004 NA 0.069 0.053 <0.005 <0.005 <2 <2 57.5 NA 10/12/00 0.16 0.038 0.038 <5 <5 130 MW -15 11/17/99 6.4 <0.010 0.045 <0.005 0.08 <0.001 <0.01 0.007 0.004 <0.005 <0.005 <2 <2 <2 NA 2/24/00 11.5 NA 0.123 <0.005 0.098 <0.001 NA 0.014 0.009 <0.005 <0.005 <2 <2 <2 NA 10/13/00 <0.10 0,009 0.008 <5.0 <5,0 <5.0 MW -16 11/17/99 1.42 <0.010 0.025 <0.005 0.018 <0.001 <0.01 <0.005 <0.003 <0.005 <0.005 <2 <2 <2 NA 2123/00 11.1 NA 0.44 <0.005 0.117 <0.001 NA 0.009 0.01 <0.005 <0.005 <2 <2 <2 NA 10/13/00 0.27 0.052 0.094 <5.0 <5,0 <5.0 MW -17 2/25/00 0.95 ND <0.02 <0.005 0.01 <0.001 ND <0.005 <0.003 <0.005 <0.005 <2 <2 6.4 NA 10/12/00 <0.10 <0.005 <0.005 <5.0 <5.0 12 MW -18 2/25/00 2.42 ND <0.02 <0.005 0.019 <0.001 ND <0.005 <0.003 <0.005 <0.005 <2 <2 <2 NA 10/12/00 0.17 0.032 0.024 <5.0 <5.0 <5.0 NC Ground Water Quality Standard NA 0.154 2.1 0.05 2 0.005 0.05 0.05 0.015 0.05 0.018 7 2.8 0.7 NA WSW water supply well mg1L milligrams per liter or parts per million fig /L micrograms per liter or parts per billion SVOCs semivolarile organic compounds according to SW -846 Method 8270 VOCs volatile organic compounds according ro SW -846 Method 6260 NA not applicable ND non detect Numbers to bold indicate concentrations over the NC Ground Water Quality Standards 0 Corrective Action Plan Addendum Mitchell - Bissell Industries Rosman, Transylvania County, North Carolina Incident # 13005 November 8, 2000 1.1 Prepared For Mitchell- Bissell Industries Rosman, North Carolina Prepared By Aquaterra Engineering, Inc Charlotte, North Carolina E. C•. Corrective Action Plan Addendum Mitchell - Bissell Industries Rosman, Transylvania County, North Carolina November 8, 2000 I. Additional Soil and Ground Water Assessment Activities On October 10, 2000 Aquaterra advanced five direct push borings (P -1 through P -5) inside the M -B facility. Soil borings P -1, P -2 and P -3 were installed in the area of the former cess pool and previous hand auger sampling locations S13-9 and SB -10 as described in the CAP. Soil borings P4 and P -5 were installed in the southeastern portion of the building (see Figure 1 for locations). The borings were advanced to the water table to evaluate if soils and ground water had been impacted. The soil samples were split in the field, with one portion placed into a zip -lock bag for screening utilizing an organic vapor analyzer (OVA), and the remaining portion placed into laboratory supplied jars for possible laboratory analyses. Soil borings P -1 through P -5 were advanced to depths ranging from 11.0 feet to 13.0 feet. Soil samples for laboratory analyses were obtained generally from one -foot intervals exhibiting the highest OVA reading or based on subsurface conditions encountered. Soil samples were obtained at intervals ranging from 4 -5 feet in boring P4 to 8 -9 feet in boring P -1. Boring logs describing Odetails of subsurface conditions and OVA measurements are included in Appendix A. Water samples were also collected from the shallow ground water at the termination depth of each borehole. A screen -type, ground -water sampling device was driven to the desired depth and then deployed to expose an approximate 4 -foot screen interval. New tubing and a bottom check valve was inserted into each borehole screen interval where the sample was collected. Each water sample was collected directly from the tubing and into each container without purging. The samples selected for laboratory analysis were placed in a cooler chilled to approximately 4 °C and shipped to Prism Laboratories, Inc. in Charlotte, North Carolina, following chain -of- custody procedures. The soil and ground water samples were analyzed for volatile organic compounds (VOC's) by EPA Method 8260B and the metals chromium and lead according to EPA Method 6010. The laboratory reports.of the soil -and ground water samples are summarized in Table 1 and a copy of the laboratory report is included as Appendix B. Results VOC's were not detected in the soil and ground water samples obtained from borings P -1, P -2 and P -3 below the former cess pool. Chromium was detected at levels ranging from 87 to 250 mg/kg in the soil and 5.4 to 31 ug/L in the ground water. Lead was detected at levels ranging from 7.5 to 24 mg/kg in the soil and 0.41 to 0.88 ug/L in the ground water. VOC's were detected in the soil and ground water samples from the area of borings P-4 and P -5 at levels up to 6000 ug/kg of PCE in soil and 4700 ug/L in ground water at boring P-4. Chromium was detected up to 20 mg/kg in the soil and up to 0.38 ug/L in the ground water. Lead Owas detected at levels up to 10 mg/kg in the soil and up to 0.25 ug/L in the ground water. •f CAP Addendum M -B Industries, Inc. November 8, 2000 Conclusions Based on results of the recent soil and ground water assessment in conjunction with historical ground water sampling activities, the highest PCE concentrations exist in the soil and shallow ground water near the southeastern portion of the original building. As presented in the CAP, potential sources of the release were thought to be the east leach field and the former cesspool located under an addition to the facility. The depth of the former cesspool was reportedly less than 4 feet below the former ground surface under the existing building. Results of the recent investigation below the bottom depth of the former cess pool indicates that soil and shallow ground water in this area does not appear to be impacted by VOC's. Investigation results in the area of borings P-4 and P -5 indicate soil and shallow ground water are impacted from VOC's (mainly PCE). This area in the southeastern portion of the original building may be indicative of a potential source of the current ground water contaminant plume based on historical concentration levels in nearby monitoring wells and direction of ground water flow (i.e., elevated impact in downgradient shallow ground water well MW -11). H. Remediation Plan Addendum The location of the originally proposed ground water treatment system configuration in relation to the recently suspected source area would appear to remain effective with additional extraction points. In addition, treatment of impacted soil encountered at the suspected source area is proposed with a soil vapor extraction system. Aquaterra believes that the recommended remediation technology - Ground Water Extraction(Treatment with Natural Attenuation - O presented in Section 3.4 of the CAP remains the most feasible option to meet remediation objectives with the following changes/additions: Ground Water Extraction/Treatment Svstem Revisions The system will consist of the existing down -hole pumps situated in water supply wells WSW -2 and WSW -3 which continue to exhibit elevated contaminant concentrations. The proposed shallow extraction well at MW -11 will instead be a deep extraction well with a 30 to 50 foot screen interval installed at the top of bedrock. In addition, a shallow extraction well will be installed at the location of suspected source in the southeastern portion of the original building to recover impacted ground water. See Figure 1 for proposed and existing well locations and distribution lines. The shallow tray aeration treatment system originally proposed has been upgraded to a model that will handle higher influent concentrations. Appendix C gives manufacturer's specifications for a treatment system that will result in efficient removal of PCE, which will eliminate the initial need for secondary carbon treatment to meet the NPDES discharge limits. Treatment system upgrades such as bag filtering to remove elevated chromium and lead concentrations may be added pending evaluation of additional ground water sampling data. Soil Vapor Extraction Svstem Addition The recommended Soil Vapor Extraction System (SVE) specifications to treat impacted soils in the southeastern portion of the original building are presented below. Figure 2 shows conceptual drawings of the SVE system. CAP Addendum M -B Industries, Inc. November 8, 2000 e • The system will initially consist of two SVE wells approximately 25 feet apart. The wells will be 2 inches in diameter and drilled to the .water table (approximately 10- feet Below floor slab) and screened a minimum of five feet above the water table. The wells will be located near the area of soil borings P4 and P -5. Based on the boring logs, it is assumed that a 25 -foot radius of influence can be achieved by these SVE wells. The blower, motor and controller for the SVE system will be installed at the same location as the pump and treat system (see Figure 1) where a licensed electrician will establish the electrical service. The control panel will be U.L. Listed and constructed to NEMA 4 requirements. The SVE system will be skid mounted and anchored to the ground. All liquid produced by the SVE system will be discharged to the air stripper for treatment. The SVE system will consist of a Rotron moisture separator, Rotron vacuum relief valve, Warrick level switches, Midco Flow Control Valve, Stoddard inline filter /silencer, Appollo dilution valve, Wika vacuum gauge, Roots 36 URAI blower, Leeson TEFC 10 hp 230v 3.ph motor, and transfer pump from moisture separator to air stripper. The blower and motor has been sized to produce 200 ACFM airflow at 12" of Hg. The SVE system is oversized to allow for additional SVE wells to be installed if warranted. Valves are designed into the system to allow for manual adjustment of the airflow and vacuum through the wells. eThe piping from the wells to the SVE system will be Schedule 80 PVC and will either be trenched under the concrete slab or piped along walls and/or overhead pipe racks. Once the SVE piping reaches outside the building, the piping will be installed in common trenches with the pump and treat piping. Based on worst -case soil data and air emissions calculations from the system described above, the SVE system will not require an air permit. From 15A NCAC 2D.0518, total volatile organic carbons must be less than 40 lbs. /day. Air emissions were calculated to be less than 15- lbs. /day total VOCs (See Appendix D for calculations). III. Ground Water Remediation System Status In response to your comment "the work related to the groundwater remediation system proposed in the original CAP should be initiated as soon as possible", the NPDES permit modification/application is in progress and will be modified as a result of the recent assessment activities. Detailed information on system design and process is being adjusted to effectively meet remediation goals and discharge limits. An Engineering Alternatives Analysis and site specific engineering design and specifications are required that will be included in the NPDES permit. e