(The photo associated with this POLREP is of the a section of the completed Engineered Stockpile #1. It has poly sand bags connected by ropes draped across the top and down the sides. In the middle of the photograph is a seam where two pieces of 40-mil HDPE were sealed together.)
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 was 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 was 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.
David Mattison of NCDENR provided oversight of removal activities during this reporting period (September 22 - 28, 2008).
* Note: 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:
* Prepared site for severe weather conditions (heavy rain/tropical storm winds). No damage to site occurred during the storm.
Excavation Activities:
* Re-started excavation/transportation of material with PCB Aroclor 1268 concentrations greater than 50 mg/kg. During September 22-24 and 27, 2008, approximately 1,548 cubic yards of soil was transported from IP Cell #2 to Engineered Stockpile (ES) #2. This material orginated from Grids I-8N and K-8. Excavation and transportation was limited this week due to two days impacted by heavy rains (9/25 and 9/26).
[Note: ES #1 is at capacity with approximately 8,000 cubic yards of material. The top and bottom liners have been seamed together. As of the end of this reporting period, ES #2 is estimated to contain 10,600 cubic yards.]
Dewatering Activities:
* Approximately 4.56 inches of rain fell on the Site over three days during this reporting period with volumes ranging from 0.18 to 4.16 inches per day. The heaviest rain fell on Thursday, September 25, 2008.
* During September 26-27, approximately 105,100 gallons of water from Cell #2 was pumped, treated, and discharged to IP. Water was not pumped earlier in the week due to low water level in the pond area of Cell #2.
* The total volume of water treated since treatment operations began on 6/18/08 is approximately 3,680,700 gallons.
Sampling Activities:
* Collected a waste characterization sample from ES #2.
Analytical Data received during the reporting period:
* Water treatment data from samples collected on 9/15 were undetected for Aroclor 1268 with a maximum detection limit of 0.63 ug/L. (The treatment goal is <3 ug/L.)
* Material management data from samples collected on 9/15 were received during this reporting period. The results are as follows: MM-06E (9.8 mg/kg), MM-06W (5.7 mg/kg), MM-08E (5.5 mg/kg), MM-08W (14 mg/kg).
* Waste Characterization data from samples ESP-06 through ESP-15 were received during this reporting period, minus dioxin/furan results. The data indicates a variety of volatile organic compounds, semi-volatile organic compounds, pesticides and metals are present within the stockpile.
RPM Samantha Urquhart-Foster will provide oversight during the next reporting period, September 29 - October 5, 2008. Activities planned for the next reporting period include:
* Continue water treatment system operations.
* Collect water treatment system samples.
* Collect samples from concrete material found in Cell #2.
* Continue excavation/transportation of >50 mg/kg material to the expanded ES#2.
* Collect material management samples from excavated material in ES#2.
The schedule for the completion of the removal activities has been extended again. The revised schedule indicates the demobilization date shifted from October 21st to October 23, 2008 because of two days lost due to rain during this reporting period. The schedule may be extended further if there are numerous rain delays or more contaminated material is discovered than is currently anticipated.
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