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Industrial Metal Alloy

All POLREP's for this site Industrial Metal Alloy
Winston-Salem, NC - EPA Region IV
POLREP #6 - Backfill begins; excavation continues
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On-Scene Coordinator - Matthew Huyser 12/1/2007
Time-Critical - Removal Action Pollution Report (POLREP) #6
Start Date: 11/6/2006 Completion Date: 6/1/2008
Pollution Report (POLREP) #6
Site Description
Site background and enforcement information can be found on Pollution Reports #1, #2, and #3.

Current Activities
Backfill and topsoil has been fully applied in the areas surrounding the West, South, and East sides of 8/10 Acadia Avenue.  Backfill and some topsoil has been applied to the easement path on the West side of the IMACO lot; topsoil will continue to be applied to meet the original  surface level and rooting areas of nearby trees.  Backfill and topsoil has also been fully applied to the grid location in the backyard of 2117 South Main Street, and backfill has been applied to grid locations south of this lot while topsoil is still needed for these locations.

The south fence of 2117 South Main Street was torn down in order to access the property with equipment for excavation.  The fence has temporarily been replaced and a fencing contractor will arrive near the completion of site activities to permanently replace the damaged areas.

On November 21, 2007, a total of 29 trucks were loaded with treated soil from the first stockpile and transported to BFI Landfill in Concord, NC.  The estimated total tonnage of disposed soil is between 464 and 522 tons.

Crews secured the Site and temporarily demobilized on November 21 for Thanksgiving holiday, and mobilized back to the Site on November 26 to resume operations.

Analytical results arrived for arriving loads of topsoil and fill dirt on November 20, 2007.  Lead levels in these soils were reported as 19.5ppm and 18.6ppm respectively; also, no other metals were reported at elevated levels in the results.

BFI CMS Landfill of the Allied Waste Company issued a letter of acceptance for the second treated stockpile as nonhazardous soil.  Also, analytical results for the second treated stockpile returned TCLP levels of 0.28mg/L; these results confirm that the treatment ratio, mixing procedure, and sampling procedure have all been successful and will not be altered as excavation continues.

On November 26, START reported findings of investigating the slag near the SW corner of the GMAC building at 2100 Sunnyside Avenue.  Surface and subsurface soils were scanned with XRF and returned readings below screening levels of approximately 100-300ppm for lead.  Slag pieces were scanned with XRF and returned readings of more than 800ppm for lead.  The slag and soil is in a mound approximately 3 feet wide 2 feet high, and 20 feet long bordering the SW corner of the GMAC building.

On November 27, HEPACO uncovered piping and a concrete slab at approximately 6” below ground surface in grids G24 and G25.  Solvent smells were emitting from the grid locations, though no soil staining and no free product was observed.  It did not appear that excavation activities caused the breakage of any piping.  HEPACO secured the area until the correct air monitoring equipment could be mobilized to the site.  START mobilized a PID/FID unit to the site on November 28.  The solvent odor could be detected at all locations on the site as far as 150 yards away, but PID and FID readings indicated that there were no volatile organic compounds present above Recommended Exposure Limits. The solvent odor was absent from the site on November 29 and did not return. Soil samples were collected by Brown & Caldwell and sent for analysis of VOCs, SVOCs, PCBs, Metals, Organics, Oils, and Greases.  Excavated soils were stockpiled and segregated from soils of other grids.

EPA OSC Huyser conducted a site walkthrough on November 28 and discussed the following issues with START, BC, and HEPACO:
- A clay drain tile in grid K14 was cracked during excavation and will be replaced prior to backfilling
- Fencing at the south end of 2117 South Main Street will be replaced by a professional fencing contractor; the fencing was torn down and replaced temporarily during excavation of grid L5
- Excavated surfaces of grids P3 and P4 appear to be at or below the water level in the creek and are at risk of washing out during a rain event; these grids will be backfilled a soon as possible
- A recycler for the kettle bottoms and large slag pieces has not been located; these pieces may have to be crushed and treated for disposal
- Slag pieces located at the SW corner of the GMAC building will have to be removed manually, if slag is mixed throughout small soil pile, then the pile will have to be removed entirely and replaced with new soil
- Colter Electric business owner, who leases the lot where piping and solvent odors were discovered on November 27, reports that a furniture store once occupied the site but burned down several decades ago.  Afterwards, a used car lot occupied the site approximately 16 years ago.  The used car lot contained a small work area where oils, fuels, and other liquids may have been spilled.
- The piping in grids G24 and G25 appear to be a shallow water line (possibly drainage) and a metal sign post.  The pipe appearing to be a water line is 3” in diameter, 6” below grade, and has a 2’ crack down one side likely created by freezing water.  The pipe appearing to be a sign post is made of galvanized steel and is positioned vertically.

After reviewing the data sets from BC and split samples from START, OSC Huyser met with BC and HEPACO to propose reducing the screening level for Type III analysis to 300ppm.  The current data set, including split samples, concludes that samples with XRF readings between 300ppm and 400ppm reported laboratory results above 400ppm about 50% of the time, and also report split samples that disagree 50% of the time.  Conversely, samples with XRF readings below 300ppm report laboratory results below 400ppm 100% of the time.  The PRP, BC and HEPACO agreed to this change in the field sampling procedure.
On December 3, HEPACO uncovered a buried drum in the waste pile near the SE corner of the IMACO property.  A second drum was discovered on December 5.


Planned Removal Actions
- Sampling to determine the aerial and vertical extent of contamination on-site and on adjacent properties (COMPLETE)

- All soils and sediments on-site and on adjacent properties which are contaminated above RALs shall be excavated (ONGOING)
Column 1: 1 cleared (row N); 0 uncleared
Column 2: 0 uncleared
Column 3: 0 uncleared
Column 4: 1 cleared (row N ); 0 uncleared
Column 5: 4 cleared (rows L, M, N, O); 0 uncleared
Column 6: 4 cleared (rows B, C, D, N); 0 uncleared
Column 7: 2 cleared (rows C, N); 0 uncleared
Column 8: 3 cleared (rows B, C, N); 0 uncleared
Column 9: 13 cleared (rows A, C, D, E, F, G, H, I, J, K, L, M, N); 0 uncleared
Column 10: 11 cleared (rows A, B, C, D, H, I, J, K, L, M, N); 0 uncleared
Column 11: 7 cleared (rows H, I, J, K, L, M, N); 0 uncleared
Column 12: 6 cleared (rows H, I, J, K, L, M); 0 uncleared
Column 13: 6 cleared (rows H, I, J, K, L, M); 0 uncleared
Column 14: 6 cleared (rows H, I, J, K, L, M); 0 uncleared
Column 15: 5 cleared (rows H, I, J, K, L); 1 uncleared (row M)
Column 16: 0 cleared; 5 uncleared (rows H, I, J, K, L)
Column 17: 0 cleared; 8 uncleared (rows D, F, G, H, I, J, K, L)
Column 18: 0 cleared; 9 uncleared (rows D, E, F, G, H, I, J, K, L)
Column 19: 0 cleared; 9 uncleared (rows D, E, F, G, H, I, J, K, L)
Column 20: 2 cleared (rows A, B); 9 uncleared (rows C, D, E, F, G, H, I, J, K)
Column 21: 1 cleared (row B); 9 uncleared (rows A, C, D, E, F, G, H, I, J)
Column 22: 5 cleared (rows A, B, C, L, M); 7 uncleared (D, E, F, G, H, I, J, K)
Column 23: 0 cleared; 8 uncleared (rows A, B, C, D, E, F, G, H)
Column 24: 6 cleared (rows B, C, D, E, F, G); 2 uncleared (A, H)
Column 25: 8 cleared (rows A, B, C, D, E, F, G, H)

- All waste streams shall be disposed of by appropriate measures as determined by the disposal profile (ONGOING)

- Restore areas which are disturbed by the removal action to their pre-removal state to the maximum extent practicable


Next Steps
- Loading and transport off-site for disposal of the second stockpile.
- Sampling and analysis of soils in grids G24 and G25 for VOCs, SVOCs, PCBs, Metals, Organics, Oils, and Greases
- Remove slag and possibly soils from mound near corner of GMAC building
- Locate recycler that will accept slag
- Begin excavation of waste pile at SE corner of IMACO property
- Continue excavation, backfill and restoration activities


Key Issues
Soils in the Colter Electric yard may be contaminated with hazardous substances other than lead. If this is the case, HEPACO will not backfill the excavated grids where these substances are found until the contamination can be addressed.  EPA and BC are trying to contact the property owner to discuss the current situation and all findings.