(The photo associated with this POLREP is the Engineered Stockpile #2 with a view of Cell #2 and Cell #1 in the background.)
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.
Samantha Urquhart-Foster, RPM, provided oversight of removal activities during this reporting period (October 20 - 26, 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:
Excavation Activities:
* Continued excavation/transportation of material with PCB Aroclor 1268 concentrations greater than 50 mg/kg. On October 21, 2008, approximately 168 cubic yards of soil was transported from the pipe trench to Engineered Stockpile (ES) #2.
* Continued excavation/transportation of material with PCB Aroclor 1268 concentrations less than 50 mg/kg. During October 20-24, 2008, approximately 4,524 cubic yards of soil was transported from IP Cell #2 to IP's landfill. This material orginated from Grids G-6NE, H-4, I-4, I-6NW, I-6SW, O-14, Q-14, S-10, S-12, U-8, U-10, U-12.
* Identified 16-inch corrugated pipe (believed to be the original discharge pipe) during additional removal at the pipe trench location.
[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 11,580 cubic yards.]
Liner Installation Activities:
* EFI (liner subcontractor) completed installation work on Stockpile #1 (vents, bags) and completed covering ½ of Stockpile #2.
Dewatering Activities:
* Rain fell on the Site on two days during this reporting period, with amounts ranging from 0.16 to 0.92 inches per day.
* During October 19-25, 2008 approximately 114,800 gallons of water from Cell #2 was pumped, treated, and discharged to IP.
* The total volume of water treated since treatment operations began on June 18, 2008 is approximately 4,340,300 gallons.
Sampling Activities:
* Collected confirmation and water treatment samples.
* Began collecting cell-wide confirmation samples on grid nodes for lab analysis. Preliminary sampling results confirm <1 mg/kg results in several grids.
Analytical Data received during the reporting period:
* Confirmation sample data from numerous grids were received during this reporting period. Results ranged from undetected to 16 mg/kg. The following grids had confirmation results that exceed the cleanup goal of 11 mg/kg for Aroclor 1268 and will require additional excavation: the base of Grid G-6 NE quadrant (16 mg/kg) and the base of grid H-5 (15 mg/kg). The PRPs are attempting to achieve remediation levels of less than 1 mg/kg. The bases of two grids had concentrations between 4.3 and 7.6 mg/kg.
* Water treatment data from samples collected on 10/11 and 10/13 indicated effluent results as undetected and 0.84 ug/L respectively. (The treatment goal is <3 ug/L.)
Other activities:
* Contractor provided alternative decontamination procedures to the Team for review.
Samantha Urquhart-Foster will provide oversight from the office during the next reporting period, October 27 - November 2, 2008. Activities planned for the next reporting period include:
* Continue water treatment system operations and monitoring of pumping activities. Collection of samples will depend on water table in sump area.
* Complete excavation/transport of > 50 mg/kg material to engineered stockpile #2 – based on sample results from confirmation sampling of Cell #2 grids and pipe trenches.
* Continue excavation of soils from SE corner of Cell #2. Excavate soils to a workable bottom for future IP turnover (perform confirmation sampling when excavation is complete).
* Continue cell-wide confirmation sampling at grid nodes with off-site lab analysis.
* Complete over excavation of pipe trench and collect confirmation samples to determination further excavation actions.
* Complete covering of ES #2. Corner to remain open to place any additional >50 mg/kg material encountered.
* Demobilization activities will begin upon receipt of confirmation sample results indicating <1 mg/kg.
The schedule for the completion of the removal activities indicates demobilization on November 11, 2008. However, the demobilization date is highly dependent upon sample results from bottom scrapes as well as efforts required for decontaminating equipment. A pre-final walk through is tentatively scheduled for November 10, 2008. Representatives of EPA, NCDENR, and Honeywell will be present along with the removal contractors.
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