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HoltraChem

All POLREP's for this site HoltraChem
Riegelwood, NC - EPA Region IV
POLREP #4
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On-Scene Coordinator - Leo Francendese 6/18/2008
Time-Critical - Removal Action Pollution Report (POLREP) #4
Start Date: 5/19/2008
Pollution Report (POLREP) #4
Site Description
The HoltraChem Site (also known as Acme Alkali) is comprised of approximately 24 acres and is located at 636 John L. Riegel Road in Riegelwood, Columbus County, North Carolina.  It is surrounded on three sides by International Paper (IP), which is comprised of approximately 1,500 acres. Both HoltraChem and IP border the Cape Fear River.  The surrounding area is a mixture of industrial, residential and commercial uses.

The area subject to this removal action includes neighboring IP’s North Bay treatment pond, also known as Cell #2.  IP formerly accepted process water generated during chlorine production from the Holtra Chem facility.  HoltraChem operated as a chlor-alkali facility using the mercury cell process from 1963 to 1999, when facility operations ceased.  HoltraChem was originally constructed to provide chlorine gas, caustic soda, and bleach to the IP facility. Process water from the former HoltraChem facility was reportedly discharged to the northwest corner of Cell #2 via a 16-inch diameter, corrugated galvanized steel pipe from approximately 1963 to the late 1970s or early 1980s.

A time-critical removal action was conducted at the HoltraChem Site during 2003 – 2004, during which containerized hazardous waste and the former cell building were removed.  In 2004, an Engineering Evaluation / Cost Analysis (EE/CA) investigation began at the Site.  During the EE/CA, the primary contaminants of concern were identified as mercury and PCB Aroclor 1268.  Sampling conducted by IP identified PCB Aroclor 1268 at concentrations up to 5,100 mg/kg in Cell #2.  PCB contamination extends to a depth of approximately 12 feet below the ground surface.  PCB contamination has been found in the adjacent Cape Fear River sediments.  IP needs to utilize Cell #2 for the expansion of their landfill sooner than the EE/CA will be completed.  Therefore, a Time-Critical Removal Action is being taken to excavate the contaminated Wastewater Treatment Solids (WWTS) from Cell #2 and place the WWTS with concentrations exceeding 50 mg/kg in temporary storage on the HoltraChem Site until the final cleanup plan is selected for HoltraChem.  The estimated volume of this material is 6,500 cubic yards.  The cleanup goal for this removal action is 11 mg/kg based on the Human Health Risk Assessment for the Holtra Chem Site.  WWTS with concentrations between 11 mg/kg and 50 mg/kg will also be excavated, but will be placed in IP’s landfill Cell #1.  The estimated volume WWTS with PCB concentrations between 1 mg/kg and 49 mg/kg is 93,500 cubic yards.

The Enforcement Action Memorandum for this time-critical removal action was signed on May 13, 2008.  The Effective Date of the Administrative Order on Consent for this removal action was May 20, 2008.


Current Activities
RPM Samantha Urquhart-Foster provided oversight of removal activities during this reporting period (June 9-15, 2008).  IP's Cell #2 was divided into 100'x100' and 50'x50' grids during the investigation phase.  Grids are labeled with a letter and a number.  Grid locations can be found in a Figure in the Action Memo.  Activities conducted by the PRPs' contractors during this reporting period included:

• On June 11, 2008, the first truckload of material with PCB concentrations exceeding 50 mg/kg was transported from IP to the engineered stockpile on the HoltraChem facility.  Two trucks are being used in the transportation of the materials.  Each truck goes through decontamination (pressure washing) upon entry and exit of the HoltraChem property.

• The volume of material excavated is estimated at 2,884 cubic yards for this reporting period.  The destination of excavated material for the week ending 06/15/08 is provided below.  Each load is estimated at 14 cubic yards; actual quantity of material removed will be surveyed using the Trimble system to determine in-place cubic yards removed.  The load destination is abbreviated in parenthesis (ES = Engineered Stockpile, IPL = IP Landfill Cell #1).
     Grid H-5 =  17 loads (ES)
     Grid I-5 =  9 loads (IPL)
     Grid I-6W = 83 loads (IPL)
     Grid M-6 =  67 loads (ES)

• On 6/13/08, IP representatives completed inspection of the water treatment system. Modifications to the system will be made by 6/16/08.

• On 6/14/08, CH2M Hill collected the initial sample from the engineered stockpile.

• Excavation of Grid M-6 has been deeper than anticipated in the NE quadrant and appears to migrate into nearby grids.


Planned Removal Actions
RPM Samantha Urquhart-Foster will provide oversight during the next reporting period, June 16-22, 2008.  Activities planned for the next reporting period include:

• Continue excavation of the > 50 mg/kg PCB material, transportation and placement of the materials into the engineered stockpile.

• Confirmation sampling of the grids (post excavation).

• Begin pumping/treating/sampling/analysis of water from Cell #2.


Next Steps
Removal activities remain on schedule and are planned through July 30, 2008, with demobilization scheduled for the first week of August 2008.