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HoltraChem

All POLREP's for this site HoltraChem
Riegelwood, NC - EPA Region IV
POLREP #31
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On-Scene Coordinator - Leo Francendese 1/15/2009
Time-Critical - Removal Action Pollution Report (POLREP) #31
Start Date: 5/19/2008
Pollution Report (POLREP) #31
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, January 4-10, 2009, included:
* On January 5th, 42,000 gallons of water was treated.  This is the last volume that will be treated under this removal action.  The total volume of water treated during the removal action is approximately 6,563,700 gallons.  The contractor turned over water pumping duties from sump in the southeast corner to IP.
* Completed removal of unsuitable material in the southeast corner of Cell #2.  On January 5th, approximately 204 cubic yards of this material was transported to IP's landfill.
* Removed the settling ponds and carbon from the water treatment equipment.  In accordance with the settling pond sediment sample results, approximately 696 cubic yards of the settling pond material was transported to Engineered Stockpile #2 during January 8-10.  On January 10th, approximately 192 cubic yards of carbon from the three water treatment vessels was transported to the IP Landfill.
* Continued completing the Pre-Final Inspection findings and preparing for site demobilization, including decontamination and wipe sampling of equipment. On January 6th, wipe samples were collected from the Godwin 4" high pressure pump and four bag filter champers.  The results were received on January 9th.  All results were undetected with a detection limit of 0.63 ug/wipe, which is well below the decontamination standard of <10 ug/wipe.  On January 7th and 9th, wipe samples were collected from a second Godwin 4" high pressure pump, two headers, three carbon vessels, treatment system hard pipe, and the vacuum truck. Results from these samples will be reported next week.


Planned Removal Actions
Activities planned for the next reporting period, January 11-17, 2009, include:
* Continue removal of material from the underlying area of settling ponds. This material will be transported to engineered stockpile #2. Once this material is removed, collect the remaining confirmation sample at the grid node.
* Continue completing the Pre-Final Inspection findings and prepare for site demobilization, including decontamination and wipe sampling of equipment.
* Final inspection of the site will be conducted on January 13, 2009. However, EPA and NCDENR will return on January 28th to conduct a final inspection of Engineered Stockpile #2, after it is sealed.  The liner crew is scheduled to be onsite during the week of January 19th to seal this stockpile.


Next Steps
The schedule for the completion of the removal activities indicates demobilization has been postponed until January 23, 2009.