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.
Activities conducted by the PRPs' contractors during this reporting period, December 1-7, 2008, included:
* Continued additional excavation of unsuitable material from the southeast corner of Cell No. 2 per IP’s request.
* Performed rough grading of Cell No. 2. Additional grading needed to allow drainage from the northwest corner of cell to the southeast corner.
* Mixed six loads of fly ash with Settling Pond #1 (SP-1) sludges. SP-1 was cleaned out to allow adequate retention time to floc solids.
* Treated surface water on three days: 12/01, 12/02 and 12/05. The amount treated this week was approximately 249,100 gallons. The total amount treated since June 2008 is approximately 5,255,800 gallons.
* Analytical results for the water samples collected on 11/25/08 were reported to the Team on 12/02. Aroclor 1268 results were below the 3 ppb treatment goal.
* Every other day sampling of influent to demonstrate Aroclor 1268 in concentrations less than 3 ppb began on 12/1/08. On 12/03, water was not present in the southeast corner to collect samples. On 12/01 and 12/04, water samples were collected. Those samples were analyzed for Aroclor 1268 by an offsite laboratory and were analyzed for TSS by IP. Aroclor 1268 results were below the 3 ppb treatment goal.
* Continued completing the Pre-Final Inspection findings.
* No material was transported to IP Landfill or Stockpile #2.
Activities planned for the next reporting period include:
* Continue completing the Pre-Final Inspection findings.
* Haul Settling Pond #1 material to the engineered stockpile.
* Continue pumping water from Cell No. 2 to IP and continue water sampling/analysis.
* 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.
The schedule for the completion of the removal activities indicates demobilization is still planned for December 17, 2008. This date is dependent on influent water sample results of Aroclor 1268 remaining below 3 ppb.
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