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HoltraChem

All POLREP's for this site HoltraChem
Riegelwood, NC - EPA Region IV
POLREP #25
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On-Scene Coordinator - Leo Francendese 12/5/2008
Time-Critical - Removal Action Pollution Report (POLREP) #25
Start Date: 5/19/2008
Pollution Report (POLREP) #25
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 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.


Current Activities
Activities conducted by the PRPs' contractors during this reporting period, November 24-30, 2008, included:
* Continued additional excavation of unsuitable material from the southeast corner of Cell No. 2 per IP’s request. On 11/26, IP visited the site and noted some additional removal required around the U-10 area.  Approximately 1,188 cubic yards was excavated from grids U-10, U-12, and U-14 and transported to IP's landfill.
* Water treatment only occurred on Tuesday of this reporting period.  59,800 gallons was treated on 11/25, bringing the total volume treated during this project to 5,006,700 gallons.  Analytical results for the samples collected on 11/20, were reported to the Team on 11/25. Effluent results were below the treatment standard.  On 11/25, water treatment system samples were collected for lab analysis.
* Received wipe sampling data from the Volvo Off Road Dump Truck. All results were below the decontamination goals.
* Continued completing items noted during the Pre-Final Inspection.
* THANKSGIVING HOLIDAY BREAK


Planned Removal Actions
Activities planned for the next reporting period include:
* Continue completing items noted during the Pre-Final Inspection.
* Continue pumping water from Cell No. 2 to IP and continue water sampling/analysis. Every other day sampling of influent to demonstrate < 3 ppb will begin on 12/1.
* Complete excavation of unsuitable material from the southeast corner of Cell No. 2 and staging wet material within Cell No. 2 for subsequent IP handling.
* Preparation of the final report is ongoing.
* Preparation for site demobilization.


Next Steps
The schedule for the completion of the removal activities indicates demobilization is still planned for December 17, 2008.