Short termim workplan_20100602_part1

1080 Holcomb Bridge Road Building 100, Suite 190

Roswell, GA 30076

www.geotransinc.com 770-642-1000 FAX 770-642-8808

June 2, 2010 Mr. Scott Miller VIA EMAIL Remedial Project Manager U.S. Environmental Protection Agency Region IV, Superfund North Florida Section 61 Forsyth Street, SW Atlanta, GA 30303-3104 Subject: Short-Term Interim Measures Work Plan

Koppers Portion of the Cabot Carbon/Koppers Superfund Site, Gainesville, Florida USEPA/FDEP ID: FLD 004 057 535 Dear Mr. Miller:

On behalf of Beazer East, Inc. (Beazer), attached is a copy of the work plan entitled “Short-Term Interim Measures Work Plan: Koppers Portion of the Cabot Carbon/Koppers Superfund Site, Gainesville, Florida.” This work plan summarizes the short-term current and future Interim Measure (IM) activities resulting primarily from the acquisition of the Koppers property by Beazer East, Inc. (Beazer). The IM activities described herein are associated with:

• Site security, operations, and maintenance;

• Stormwater and dust management (Best Management Practices); and

• Decommissioning and demolition of remaining structures. Should you require additional information, please feel free to contact Mitchell Brourman or me.

Sincerely,

Gregory W. Council, P.E. Principal Engineer cc: Kelsey Helton, Florida DEP

Jeff Martin, Florida DEP Ashwin Patel, Florida DEP Fred Murray, City of Gainesville John Mousa, Alachua County EPD

Rick Hutton, Gainesville Regional Utilities Linda Paul, Koppers, Inc. Mitchell Brourman, Beazer Bob Fisher, Beazer Jim Erickson, GeoTrans

http://www.geotransinc.com/�

Short-Term Interim Measures Work Plan Koppers portion of the Cabot Carbon/Koppers Superfund Site Gainesville, Florida USEPA/FDEP ID: FLD 004 057 535 June 2, 2010 Prepared for Beazer East, Inc.

1080 Holcomb Bridge Road Building 100, Suite 190 Roswell, GA 30076 www.geotransinc.com 770-642-1000 FAX 770-642-8808

Short-Term IM Work Plan ii

TABLE OF CONTENTS 1 INTRODUCTION .......................................................................................................................... 1

1.1 Site Description ......................................................................................................................... 1 1.2 Previous Interim Measures ....................................................................................................... 2

2 INTERIM MEAURES OBJECTIVES AND APPROACH ........................................................... 3 2.1 Objectives ................................................................................................................................. 3 2.2 Approach ................................................................................................................................... 3

2.2.1 General Site Security, Operations, and Maintenance ......................................................... 3 2.2.2 Stormwater and Dust Management Improvements ............................................................. 3 2.2.3 Decommissioning and Demolition of Remaining Structures ............................................. 4

3 SCHEDULE .................................................................................................................................... 8

4 REPORTING .................................................................................................................................. 9

5 REFERENCES ............................................................................................................................. 10

LIST OF FIGURES Figure 1. Site Location Map Figure 2. Site Layout Figure 3. Previous Interim Measures Figure 4. Conceptual Interim Erosion Control and Drainage Measures LIST OF APPENDICES Appendix A. Stormwater Discharge Permit Application and Preliminary Stormwater Design Report Appendix B. Demolition Asbestos Survey and Assessment Appendix C. Demolition Permit Applications and Plans Appendix D. Waste Summary

Short-Term IM Work Plan 1

1 INTRODUCTION This work plan summarizes the short-term current and future Interim Measure (IM) activities resulting primarily from Beazer East, Inc.’s (Beazer) acquisition of the Koppers, Inc. (Koppers) property which is part of the Cabot Carbon/Koppers Superfund Site. Beazer assumed management of the former Koppers property (the Site) at the end of March 2010, and has chosen to proactively implement IM activities at the Site to:

• Act as good stewards of the property;

• Address community concerns; and

• Prepare the property for effective implementation of environmental remedies and subsequent reuse and redevelopment of the property.

The IMs described in this work plan are associated with:

• Site security, operations, and maintenance;

• Stormwater and dust management (Best Management Practices); and

• Decommissioning and demolition of remaining structures.

1.1 Site Description The Site is located in the City of Gainesville, in Alachua County, Florida (Figure 1). The Site encompasses approximately 86 acres and was used as a wood-treating facility beginning in 1916. Active Site operations ceased in January 2010. Former wood-treatment facilities are located within the southeastern portion of the Site (Figure 2). Site investigations (e.g., GeoTrans, 2004) have identified four main source areas related to former Site operations and facilities. The Former Process Area and the Former Drip Track were located east of the recently shut-down process area and drip tracks (Figure 2). The Former North Lagoon is located near the center of the Site and the Former South Lagoon in located in the south-central portion of the Site. Both former waste lagoons have been closed, covered, and graded.

Adjacent properties include the former Cabot Carbon portion of the Superfund Site and commercial facilities to the east, private residences to the west and northwest, and commercial facilities and private residences to the north and south.

As mentioned previously, the Site is a Superfund Site in the midst of the remedy selection process. A Feasibility Study of remedial alternatives was recently released and the proposed environmental remediation plan for the Site is anticipated to be released in the coming months.

From January 2010 through the sale of the property at the end of March 2010, Koppers performed activities associated with its closing of the Gainesville wood-treatment facility. These activities included relocating some equipment to other facilities, removal of product inventory (treated wood), and removal of chemical inventory. In addition, Koppers conducted compliance-related closure activities per Florida Department of Environmental Protection (FDEP) requirements. Specifically, Koppers cleaned and pressure washed the chromated copper arsenate (CCA) drip pad and secondary containment area. Koppers also sealed the majority of the CCA drip pad and secondary containment area with epoxy.


The Florida Department of Environmental Protection (FDEP) performed Hazardous Waste Site Inspections before and after management of the Site was transitioned to Beazer. The following items associated with Koppers’ closure operations were identified (May 18, 2010, Non-Compliance Letter NCL10-2552HW10NED from Ashwin Patel, FDEP):

• Oil and gasoline dispensing lines in the fuel/oil storage area may contain fluid that will need to be emptied and flushed.

• CCA residue was present on four rail-car trams, the rail track east of the treatment cylinder, the sump in the CCA tank area, the CCA secondary containment floor, pipes in the CCA tank/pad area, filter assemblies, and in the bottom of the two CCA storage tanks.

• Miscellaneous chemicals, including epoxy, paint thinner, gas cylinders, aerosol cans, oil containers, antifreeze containers, and fluorescent light bulbs, were present on-Site. The chemicals need to be managed as useable items or disposed.

The following violation associated with Koppers’ former operation was also identified:

• Oil-saturated and oil-stained soils were present within and near the oil-tank secondary containment in the bark removal area.

1.2 Previous Interim Measures Beazer has conducted or is in the process of executing other IMs at the Site. These IMs relate mostly to groundwater and are described in detail in other IM work plans. The following is a general description of those IMs.

A Surficial Aquifer groundwater extraction system has been in operation as an Interim Remedial Measure (IRM) on the Koppers, Inc. portion of the Site since 1995. The system initially consisted of fourteen extraction wells installed in the Surficial Aquifer along the northern and eastern property boundary. An on-Site water treatment facility was constructed to treat extracted groundwater. The system was expanded in 2009 to include horizontal groundwater collection drains in the Surficial Aquifer closer to the four potential source areas. The on-Site water treatment facility was also expanded to handle the increased flow.

Also in 2009, IRMs were implemented in the Upper Floridan Aquifer near the Former Drip Track (FW-21B) and the Former North Lagoon (FW-6). The IRMs consisted of removal of the existing Westbay System from well FW-21B and installation of a hydraulic plug between the second and third, and third and fourth screened intervals of this well. A conventional submersible pump was then installed in monitoring well FW-21B. A submersible pneumatic piston pump was installed in monitoring well FW-6. Both wells are being pumped at approximately 2 gallons per minute (gpm), with discharge to and treatment by the on-Site water treatment plant.

An Upper Floridan Aquifer extraction well (FW-31BE) was installed in March 2010 to provide capture of groundwater impacts detected in the northwestern area of the Site in monitoring well FW-22B. Aquifer testing is scheduled to be completed by June 2010. At the completion of the aquifer tests, extraction well FW-31BE will be restarted and placed in long-term operation. The water will be discharged to and treated by the on-Site water treatment plant.

The locations of the previously implemented IRMs are shown on Figure 3.


2 INTERIM MEAURES OBJECTIVES AND APPROACH

2.1 Objectives The objectives of the IMs are to:

• Secure the property and put in place a comprehensive property management plan;

• Address community concerns by employing best-management practices (BMPs) for stormwater and dust control; and

• Position the Site for effective implementation of environmental remedies and subsequent reuse and redevelopment.

The IMs will include removal and disposal of materials and supplies, cleaning and/or removal of structures and equipment, and improvement of Site surface features.

2.2 Approach The IMs described in this report were selected as immediate or short-term activities (i.e. the period from property acquisition through implementation of Site-wide remedial actions) consistent with the above objectives. The approach to each of the selected IMs is discussed separately below.

2.2.1 General Site Security, Operations, and Maintenance Prior to acquisition of the property, Beazer maintained Site personnel necessary to complete its required activities which were primarily related to operation of the groundwater pre-treatment plant. With the acquisition of the property, Beazer now assumes all activities associated with operations and maintenance of the entire property. This responsibility includes general Site maintenance, landscaping, lawn care, general good housekeeping, and security. Prior to transition of the property to Beazer, the Site property fence did not completely encircle the Site. A gap existed in the northeast portion of the property, primarily to allow rail cars to enter and exit the Site in this area. The fence has now been extended so it now completely encloses the property. A privacy cover was also added to the front gate, and signs were added to provide a contact for Beazer and a contact for on-Site operations.

Landscaping and debris removal were performed along the frontage of the property to improve the appearance of this area.

Debris and trash has been and will be collected from around the Site and containerized for disposed. General Site operation and maintenance, including good housekeeping practices, will be an ongoing effort.

In addition, and until the activities described in Section 2.2.2 are completed, Beazer maintains and operates a water truck at the Site to reduce dust generation.

2.2.2 Stormwater and Dust Management Improvements GeoTrans and Tetra Tech prepared an Individual Industrial National Pollution Discharge Elimination System (NPDES) permit application. The permit was submitted to FDEP on June 1, 2010, and a copy is provided in Appendix A. The application is accompanied by a Preliminary


Stormwater Design Report detailing planned stormwater/dust improvements and BMPs at the Site. The improvements are intended to reduce sediment erosion on Site, minimize dust generation, and intercept the “first flush” of sediments in swales and bermed impoundments prior to reaching the drainage ditch. Specific improvements included in the Preliminary Stormwater Design Report include:

• Root rake and disc approximately 36 acres to break up hardened limerock;

• Hydroseed and mulch root rake-disc the cleared areas (approximately 36 acres);

• Excavate and grade the interceptor swales;

• Place berms to impound stormwater prior to release to the Site ditch;

• Install approximately sod in bottom of swales and on berms;

• Install silt fence along the ditch and perimeter of the Site;

• Install riprap impoundment overflows; and

• Use existing mulch available on‐Site to cover access roads.

The primary stormwater improvements are shown on Figure 4. The Preliminary Design Report also includes inspection and maintenance procedures and quarterly discharge event sampling details. Collectively, these BMPs should provide effective short-term mitigation to operational concerns related to stormwater and dust generation. Additional stormwater and dust-control measures are anticipated as part of the Site-wide remedial actions.

2.2.3 Decommissioning and Demolition of Remaining Structures As mentioned previously, Koppers removed operational equipment that could be relocated to other facilities. With the exception of the plant office building, the remaining Koppers facilities and buildings are scheduled for decommissioning and subsequent demolition. The following subsections detail the steps in the decommissioning and demolition process.

2.2.3.1 Asbestos Assessment and Abatement

A pre-demolition asbestos survey and assessment was performed on April 12, 2010 by Avanco Environmental, Inc. in anticipation of demolition of the remaining Koppers structures. The assessment report is included as Appendix B. The assessment was performed to identify asbestos containing materials (ACM) in the maintenance shop, fuel storage area, brick oven, tank farm, pipe run, boiler house, silo, wash room, drip track, land and tank rook, steel oven, administrative office, administrative shed, log office, tool shop, and pole peeler buildings.

A total of 132 samples were collected and submitted to Steve Moody Micro Services, Inc. in Farmers Branch, Texas. Positive asbestos samples were identified in the maintenance shop, the brick oven, a drop pipe near the tank farm, the boiler, the drip track lab and tank room, and the log office. The positive samples contained between 5% and 65% Chrysotile, and consisted of five areas of friable thermal system insulation (TSI), two areas of non-friable TSI, one friable area of rope gasket, seven miscellaneous areas of non-friable materials consisting of flange gaskets, roof flashing, asbestos cement board, sheet flooring, and floor tiles.

The asbestos survey and assessment included recommendations for removal of the identified ACMs. Abatement activities were conducted from May 10, 2010 to May 21, 2010 by Simpson


Environmental Services, Inc. a licensed Florida asbestos abatement contractor. All ACM was disposed of at Keene Road Landfill in Apopka, Florida in accordance with local, State, and Federal regulations. A total of 50 gaskets, six rope gaskets, 10 linear feet of pipe insultation, 650 square feet (sf) of resilient flooring, 3,102 sf of cementitious material, and 3,102 sf of asphalt roofing was disposed of. Completed FDEP Notice of Demolition or Asbestos Renovation forms documenting the asbestos abatement are provided in Appendix C.

2.2.3.2 Disposal of Miscellaneous Materials

As previously described in Section 1.1, the following miscellaneous materials remained on-Site after the property transition:

• Various non-RCRA oils and greases: 4 drums

• Flammable liquids (paints, thinners, solvent wash): 4 drums

• Light ballasts for fluorescent bulbs: 2 drums

• Ammonium hydroxide lab packs: one 5-gallon pail

• Lead acid batteries: 1

• Alkaline batteries: one 5-gallon pail

• Non PCB transformers with oil: 6

• Mercury switches: one 5-gallon pail

• Calcium hydroxide solid: one 5-gallon pail

• NiCad batteries: one 5-gallon pail

• Florescent light bulbs: 4 light bulb tubes (approximately 40 per tube)

• HID light bulbs: 1 drum

• Epoxy resin: one 5-gallon pail

• Amine hardener: one 5-gallon pail

• Caustic boiler reagents: 1 drum An inventory of these wastes and a description of characterization and planned disposal methods were sent to FDEP in a Waste Summary prepared by Chemtron Corporation (Appendix D). The materials were containerized, classified, and labeled for shipment in accordance with State, Federal, and DOT guidelines. All waste has been (or will soon be) manifested and shipped to the Chemtron Corporation Transport Storage and Disposal Facility (TSDF) in Avon, Ohio for proper disposal. This activity responds to the FDEP’s May 18, 2010 Non-Compliance Letter (NCL10-2552HW10NED) and prepares the structures for subsequent dismantling.

2.2.3.3 Tank and Structure Decontamination

Tank and structure decontamination will be completed by Chemtron Corporation. Any remaining flake, sludge, and/or liquid at the bottom of the two CCA tanks and used oil tanks will be removed and placed in 55-gallon drums for characterization and disposal. After removal of the outer aluminum sheeting and insulation, the tanks will be moved with a crane to a decontamination containment area constructed of a 50 ft by 100 ft area of triple-layered 6 mil


poly sheeting with raised perimeter edges. The tanks will be placed on plastic wrapped 4x4 blocks to evenly distribute the tank weight and prevent sharp edges from coming in contact with the containment liner. The tanks will be cleaned with hand tools and pressure washers to remove residual materials. The decontamination water will be collected from the interior of the tanks and the containment area as it accumulates using a vacuum truck. The liquid will be managed as hazardous waste, containerized for shipment, and transported for disposal at Chemtron Corporation’s TSDF located in Avon, Ohio.

Following use of the decontamination containment area, the containment structure will be inspected for holes or signs of leakage, which will be marked for further inspection of the ground beneath. After removal of the containment structure, the ground will be inspected for saturation, discoloration, or other signs of leakage. Any locations with signs of leakage will be removed with an excavator and managed for disposal as hazardous waste. The decontamination containment structure materials will be managed and disposed as hazardous waste with EPA waste codes D004 and D007.

The CCA residue on specific items identified as potential areas of concern during the FDEP Hazardous Waste Inspection will also be removed by scraping and/or pressure washing. The items to be decontaminated include four rail-car trams near the mechanical building, a section of rail track east of the treatment cylinder, a sump in the CCA tank area, a section of the southwest corner of the secondary containment floor, pipes for the CCA tanks/pad, and filter assemblies. Other concrete building pads remaining after demolition (discussed in Section 2.2.3) will be also be pressure washed as necessary to remove residue from previous operations.

Following pressure washing to decontaminate, the secondary containment area, sumps, and concrete building pads will be inspected to determine if additional protection is needed. An industrial, waterproof concrete epoxy (the same epoxy previously used to seal the CCA drip pad) will be applied to seal these areas, where warranted.

An FDEP inspection will be arranged at the end of the tank and structure decontamination process to ensure the State is in agreement with the results of the process and the areas of concern and violation noted during the Hazardous Waste Inspections (as documented in the May 18, 2010, Non-Compliance Letter NCL10-2552HW10NED) have been addressed.

2.2.3.4 Demolition

Following asbestos abatement and tank and structure decontamination, eight above ground Site structures will be demolished by Chemtron Corporation in concert with local support from B&N Welding and Fabrication and Al’s Dozer Service of Plant City. The on-Site structures that will be left in place include the water treatment plant and associated trailer, sheds housing extraction wells/pumps, and the main office building. A City of Gainesville demolition permit was prepared by B&N Welding and Fabrication, Inc. and submitted on May 19, 2010. An FDEP Notice of Demolition or Asbestos Renovation form describing demolition methods was completed by Al’s Dozer Service of Plant City on May 18, 2010. The demolition permits are included in Appendix C. Dust management practices will be implemented during demolition, including spraying roads and equipment tracking areas with a water truck and wetting concrete and brick surfaces prior to breaking. Excavators with grapple attachments will be used to dismantle the buildings to minimize dust generation.


A demolition work plan summary and a health and safety plan were prepared by Chemtron Corporation, and are included in Appendix C. Demolition will include removing above ground structures, including eight buildings and two and above ground tanks. The tanks will be removed by first stripping the out aluminum jackets and insulation. This step will be completed prior to moving the tanks to the constructed containment area for decontamination. The aluminum will be recycled and the insulation will be sent to a landfill, and the insulation will be managed and disposed as hazardous waste with EPA waste codes D004 and D007. Following decontamination, the tanks will be sheared into manageable pieces and placed in a roll-off bin for recycling. Prior to demolition of the buildings, all utilities will be disconnected and plugged/capped, as appropriate. Steel components will be segregated and recycled, including cleaning and cutting piping to management lengths. Light fixtures, thermostats, switches, or other devices potentially containing mercury have been removed from the buildings and are containerized for recycling or proper disposal. Building components such as wood, brick, glass, and plaster/drywall will be hauled to a class III landfill or Construction and Demolition Debris (C&D) facility for disposal.

The concrete slabs associated with some of the smaller sheds and buildings may also be broken up and removed for disposal, but the concrete slabs associated with larger structures will be left in place.

As part of demolition, the existing rail lines that extend from the northeast corner of the Site to the brick kiln and pressure treating area will be removed. The rails will be cut into manageable pieces and recycled. The ties will removed and transported to a landfill for disposal.

2.2.3.5 CCA Pad Closure and Roof Structure Removal

The CCA drip pad is an epoxy-treated concrete pad. The proposed closure approach for the CCA pad was presented in a Beazer letter of April 16, 2010, that was sent to Ashwin Patel (FDEP) and Scott Miller (USEPA).

As described in that letter, Koppers cleaned one section of the CCA pad that had visible stains and recoated that section with the waterproof epoxy sealant prior to vacating the property. Beazer continues to inspect the CCA pad to determine if additional cleaning and epoxy protection is needed. The waterproof concrete epoxy will be applied to seal the pad if warranted.

As an additional interim step, Beazer will install a compacted soil cover (2-foot height at center of pad) over the CCA pad & containment area to keep stormwater from accumulating and to promote runoff. Grass will be planted on the cover to prevent erosion and reduce infiltration potential. The roof over the CCA pad will be removed.

Eventually, as described in the April 16, 2010, letter, the CCA pad and containment area will be within the area remediated as part of the Site-wide environmental remedy. As such, the CCA area will be within a larger area that has appropriate groundwater containment, surface covers, and stormwater management.


3 SCHEDULE Several of the IMs discusses above have been completed or are underway. Remaining tasks include:

• Miscellaneous chemical disposal;

• Debris and trash cleanup (ongoing);

• Tanks and structure decontamination;

• Demolition;

• CCA pad covering; and

• Storm water improvements. The schedule to complete these items depends partially on the time for review and approval of permits associated with some of the work. It is anticipated that with quick turn around on permit approval, the majority of the work will have commenced by July 2010 and will be completed in fall 2010.


4 REPORTING A report documenting the completion of IM activities described in this workplan will be submitted for Agency review. The report will include a description of IM activities, figures depicting key work areas, waste manifests, and photographic summaries of key activities. It is anticipated that the IM completion report will be submitted within 2 months of completing the IM activities discussed in this work plan.


5 REFERENCES GeoTrans 2004, Addendum 6: Groundwater Flow and Transport Model, Draft Report, Koppers, Inc. Site, Gainesville, Florida, October, 2004.

Short-Term IM Work Plan

FIGURES

Short termim workplan_20100602_part1

Technology

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