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HoltraChem

All POLREP's for this site HoltraChem
Riegelwood, NC - EPA Region IV
POLREP #30
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On-Scene Coordinator - Leo Francendese 1/7/2009
Time-Critical - Removal Action Pollution Report (POLREP) #30
Start Date: 5/19/2008
Pollution Report (POLREP) #30
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, December 28, 2008 - January 3, 2009, included:
* On 12/29, the fifth round of water samples were collected for offsite lab analysis and TSS (TSS analysis by IP).
* Sample results from 12/22 and 12/29 were reported to the Team during the week. The influent results were 1.2 ug/L and 0.32 ug/L respectively.  Based on these results, the intent of the IP/Honeywell Agreement (Item 11) has been met.  Therefore, water treatment will no longer be required and the treatment system may be dismantled.
* A total of 375,700 gallons of water was treated during this reporting period.  This brings the total volume treated since June 2008 to 6,521,700 gallons.
* Continued excavation of unsuitable material from the southeast corner of Cell #2. This task was completed on 1/3/2009.
* No site work was performed on January 1 due to the holiday.


Planned Removal Actions
Activities planned for the next reporting period, January 4-10, 2009, include:
* Remove the settling ponds/water treatment equipment - in accordance with the settling pond sediment sample results, the settling pond material will be transported to engineered stockpile #2, and the carbon from the three vessels will be transported to the IP Landfill. Once the ponds/equipment are removed, collect the remaining confirmation sample at the grid node underlying the area.
* Complete sealing of Engineered Stockpile #2 liner following placement of settling pond materials into the stockpile.
* Continue completing the Pre-Final Inspection findings and prepare for site demobilization, including decontamination/wipe sampling of equipment.


Next Steps
The schedule for the completion of the removal activities indicates demobilization is still scheduled for January 14, 2009.  This date is dependent on confirmation samples beneath the water treatment sedimentation ponds indicating excavation goals were achieved.  The final walk-through is scheduled for January 13, 2009.