Corrective Action

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Corrective Action At Koppers, Inc. North Little
Rock Facility
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Koppers, Inc. NLR Facility Description

• Location
• 2201 Edmonds Street
• North Little Rock, Pulaski County, AR
• Size 155 acres
• Activities
• Active wood treatment plant producing railroad
  ties pressure-treated with creosote.
• Previously produced treated lumber, utility
  poles, bridge piling materials using
  pentachlorophenol, chromated copper arsenate, and
  creosote.

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Koppers, Inc. NLR Aerial Photgraph
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Koppers, Inc. NLR Zoning
N
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Koppers, Inc. NLR Operational History

• 1907 present
• Pressure-treated various wood products using
  creosote / oil mixtures
• Early 1950s 1964
• Chromated copper arsenate (CCA)
• also used as a preservative
• Early 1960s 1982
• Pentachlorophenol (PCP)
• also used as a preservative

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Past Waste Treatment Description / History

• Pre-1970
• Waste preservative mixture and water (waste)
  collected in sump
• Waste pumped to unlined lagoons
• Early 1970s
• Tank and API oil/water separator added
• PCP effluent treatment system added
• 1975
• Two unlined SIs (SI1 and SI2) put into service
  in place of unlined lagoons
• Sprayfield Area put into service received
  wastewater from SI2

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Past Waste Treatment Description / History
lagoons
lagoons
SW corner of site - December 1949
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Past Waste Treatment Description / History
lagoons
lagoons
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Past Waste Treatment Description / History
lagoons
lagoons
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Past Waste Treatment Description / History
lagoons
New SIs
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Past Waste Treatment Description / History
A series of impoundments were used from
plant construction until approximately 1975. By
that time the series of individual impoundments
had essentially become one large impoundment. -
RFI / CMS Work Plan, October 1988, Sec. 2.3.2.1,
page 2-6
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Past Waste Treatment Description / History

• 1975
• Surface Impoundments put into service
• SI1 used as a surge basin
• SI2 biological treatment with aeration
• Sprayfield water from SI2 surface discharged
  (NPDES permit)

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Past Waste Treatment Description / History

• Part of SI2 w/aeration and Sprayfield

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Start of Groundwater Detection Monitoring

• November 1980
• Koppers NLR submits RCRA Part A Application to
  the U.S. Environmental Protection Agency
• Interim Status granted
• November 1981
• Installation of Groundwater Monitoring System -
• 4 wells (R-1 R-4) installed

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1st 3008(h) Administrative Order

• May 1, 1984
• Due to inadequate groundwater monitoring and
  assessment, USEPA issues a 3008(h) Administrative
  Order against Koppers NLR.
• As part of the order, 3 new monitoring wells are
  installed
• R-5 (up-gradient)
• R-6 and R-7 (down-gradient)
• Accelerated monitoring program initiated
• (monthly sampling vs. quarterly)

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Discovery of Off-site Contamination

• July 5, 1984
• North Little Rock Health Department detects 11
  components of creosote in a private well ½ mile
  down-gradient of the Koppers NLR facility

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3013 Administrative Order

• February 1985
• USEPA issues 3013 Administrative Order (requires
  investigation to determine how significant a
  threat the contamination poses) against Koppers
  NLR
• Groundwater monitoring program changed from
  detection monitoring to assessment monitoring
  assessment plan prepared
• Data collected in the first quarter of the
  accelerated detection monitoring shows a
  significant increase of contamination in
  down-gradient wells

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Assessment Plan Implementation

• May 1985
• Beginning of assessment plan implementation
• Requirements
• Installation and monitoring of 35 wells, both
  on-site and off-site
• Surface soil samples
• Soil borings

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USEPA Compliance Monitoring Evaluation

• July 22-31, 1986
• USEPA Hazardous Waste Ground Water Task Force
• conducts a Compliance Monitoring Evaluation at
• Koppers NLR
• Findings
• Uppermost aquifer characteristics not yet
  identified
• GW flow direction and flowrate not determined
• Alluvial sediments underlying the site not
  characterized

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USEPA Compliance Monitoring Evaluation

• Extent of confining clay zone underlying the
  sediments not characterized
• Rate and extent of migration of hazardous waste
  in groundwater not determined (required by
  regulations and further stipulated in 3013 Order)

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USEPA Compliance Monitoring Evaluation

• Improper monitoring well construction
• Sampling deficiencies
• No provision for detection or sampling of LNAPL
  or DNAPL that might be in wells
• QA/QC sampling problems
• Numerous laboratory deficiencies

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USEPA Compliance Monitoring Evaluation

• Only 17 of the required 35 wells were installed
• (all on-site)
• 17 SWMUs and 6 AOCs identifed, many with obvious
  contamination
• SIs found to have high levels of creosote
  component contamination
• 7 wells sampled by USEPA found to be contaminated
  with creosote components

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SWMUs AOCs
Due to the number of SWMUs, and the similar
waste constituents present in each, it is not, as
yet, possible to assess the source(s) of site
constituents found in the groundwater - from
DOCC, February 1991 (various places) Because
of the close proximity of the various potential
source areas, and the similar constituents
present in each, it is both difficult and
impractical to differentiate many of the SWMUs
and AOCs into separate potential source areas. -
RFI Report, 1995 Sec. 4.2, page
4-2 Translation The place is a mess.
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SWMUs AOCs
1
3
1 Past Landfarm 1 2 Past Landfarm 2 3 Past
Landfarm 3 4 Waste Containment Storage
Facility 21 Stained Soil (AOC)
4
21
2
N
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SWMUs AOCs
5 Former Sprayfield Area 6 Drip Track Area 7
Former Lagoon Area 8 Former Container Storage
Facility 9 Former SI 1 10 Former SI 2 11
Primary API Separator 12 Former Secondary API
Separator 13 Dehydrator Secondary
Containment 14 Basement Beneath Treatment
Cylinders
5
10
9
12
6
8
7
13
14
11
N
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SWMUs AOCs
15 Septic Tank 16 Former PCP Effluent
System 17 Effluent Surge Tank Areas of
Concern 18 Tank Farm Area 19 Rail Car Unloading
Area 20 Truck Unloading Area 21 Stained Soil
(previously shown) 22 Treatment Cylinders 23
Visual Off-site Contamination (not shown)
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19
18
20
22
16
17
N
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Past Waste Treatment Description / History
Landfarms in NE corner of site These units
received material from the clean-up of the Former
Lagoon Area around 1980. The material contained
creosote, carbon black oil, and possibly CCA.
The quantity of material deposited in this unit
is unknown. - description of 3 landfarms from
DOCC, February 1991 3.2.1, 3.2.2, 3.2.3
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SWMU 6 Drip Track Area
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SWMU 6 Drip Track Area

• Area where freshly treated wood is allowed to
  drip and dry after being removed from treatment
  cylinders.
• From 1907 to 1987 the area consisted of railroad
  tracks on top of bare soil.
• Soil borings showed visibly stained soil to
  depths of up to 3 feet.

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SWMU 6 Drip Track Area

• 1987
• Visibly stained soil was removed
• stored in SWMU 4 prior to disposal
• Liquid collection system installed
• Continuous concrete pad poured beneath railroad
  tracks

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Permit Application Issues

• February 1987
• Koppers NLR submits revised Closure Plans for
  Surface Impoundments and Container Storage
  Facility in response to Part B Application NODs
• July 1987
• ADPCE issues Notice of Intent to Deny RCRA
  Permit due to failure to submit a Technically
  Complete Application (Closure Plan issues)
• September 1987
• ADPCE issues Final Decision to Deny RCRA Permit

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Permit Application Issues

• October 1987
• Koppers NLR petitions for, and receives, delay
  of effective date of denial to September 1, 1988
  so units may be closed.
• January 1988
• Container Storage Facility certified closed
• June 1988
• ADPCE approves modified closure/post closure
  plans for SIs.
• July 1988
• SIs receive last wastewater

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SI Closure

• August 8, 1988
• Completion of removal and disposal of bottom
  sludge and visibly contaminated soil from SIs
• August 16, 1988
• Sub-grade soil sampling of SIs
• Contaminated with
• Arsenic
• Chromium
• Phenolics
• PAHs

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SI Closure

• October 1988
• RFI/CMS Work Plan approved
• April 4, 1989
• Koppers NLR receives temp. authorization to
  discharge accumulated rainfall from SIs to NPDES
  outfall

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SI Closure
April 17, 1989 accumulated rainwater in SIs
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SI Closure
April 17-21, 1989 rainwater pumped from SIs
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SI Closure
April 27 May 12, 1989 backfill of SIs with
clean soil
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SI Closure
June 5, 1989 Application submitted for RCRA Post
Closure Permit for SIs May 13 July 10,
1989 Beginning of closure of SIs with placement
of geotextile layers and clay cap
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SI Closure
Geotextile anchor trench
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SI Closure
Geotextile anchor trench
Placement of 1st geotextile layer
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SI Closure
Placement of clay cap material
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SI Closure
Compaction of clay cap material
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SI Closure
Sampling of clay cap for permeability testing
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SI Closure
Placement of gravel conducting zone
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SI Closure
Placement of 2nd geotextile layer
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SI Closure
July 5 August 1, 1989 Placement of soil cover
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SI Closure
July 20-26, 1989 Installation of drainage pipe
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SI Closure
August 2, 1989 Hydroseeding of soil cover
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2nd 3008(h) Administrative Order

• December 27, 1990
• USEPA issues 3008(h) Administrative Order
  requiring
• Interim Measures
• RCRA Facility Investigation
• Corrective Measures Study

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2nd 3008(h) Administrative Order

• February 11, 1991
• Interim Measures implemented
• Deep GW vertical delineation monitoring wells
  installed
• (DNAPL encountered during drilling)
• GW Pump Treat system installed
• Two GW recovery wells installed
• One monitoring well converted to DNAPL recovery
  well
• One monitoring well R-6 plugged and abandonded
• (due to anomalous water level readings)
• New monitoring well cluster installed (3 wells)

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Groundwater Pump Treat System
Site Preparation
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Groundwater Pump Treat System
GW Recovery Well Schematic
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Groundwater Pump Treat System
Groundwater Recovery Wellhead Components
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Groundwater Pump Treat System
GW Treatment Plant
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Groundwater Pump Treat System
Settling/surge backwash tanks
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Groundwater Pump Treat System
pH adjust feed pumps multi-media filter
activated carbon unit
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ADPCE Comprehensive Monitoring Evaluation

• April 22-26, 1991
• Findings similar to EPA GWTF CME in 1986
• Additional findings
• Inadequate number of monitoring wells
• Some wells improperly placed to get
  representative
• samples of in-situ water quality
• No procedures for DNAPL sampling/measuring
• No updated map showing monitoring and recovery
• well locations
• Sampling Analysis Plan too generic
• Wells not maintained or repaired in a timely
  fashion

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RCRA Facility Investigation

• Sept. 1992 March 1993 and Sept. 1993 Nov.
  1993
• 53 soil borings
• 61 monitoring wells installed
• 33 on-site
• 28 off-site
• Lithologic sampling of confining clay layer
• Characterization of the hydraulic properties of
  aquifer
• Domestic and industrial well inventory
• Geophysical logging
• Sampling of surface water and sediments
• at plant exit locations

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RCRA Facility Investigation
Soil Borings
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RCRA Facility Investigation Supplemental Studies

• April - July 1995
• Subsurface Investigation
• 3 deep test soil borings through confining clay
  layer
• lithologic sampling
• geophysical logging
• 3 monitoring wells installed in deep portion of
  aquifer
• 6 new monitoring wells installed near closed SIs
• Recovery well (RW-3) installed
• Aquifer tests conducted at well RW-3
• Limited DNAPL recovery test at well RW-3
• Elevation and location survey of all wells

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RCRA Facility Investigation Supplemental Studies

• April - July 1995
• GW Sampling and Analysis
• First ever site- wide, all-well sampling event
• 97 on-site monitoring wells
• 2 off-site residential wells
• To provide a site-wide snapshot of GW
  conditions
• Sampling and analysis of off-site sediments

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RCRA Facility Investigation Supplemental Studies

• Results
• Subsurface Investigation
• Areas with DNAPL characterized
• several small areas perched on clay lenses
• one small pond on confining clay layer
  (on-site)
• one large pond in depression in confining clay
  layer both
• on- and off-site (up to 200 feet south of
  property boundary)

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RCRA Facility Investigation Supplemental Studies
Confining clay layer contours DNAPL ponds
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RCRA Facility Investigation Supplemental Studies

• Results (continued)
• GW Sampling and Analysis
• Plumes of VOCs, PAHs, and Phenols mapped

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RCRA Facility Investigation Supplemental Studies
Plume contours - VOCs in Zone D
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RCRA Facility Investigation Supplemental Studies
Plume contours - Phenols in Zone D
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RCRA Facility Investigation Supplemental Studies
Plume contours - PAHs in Zone D
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RCRA Facility Investigation Supplemental Studies

• Results (continued)
• Sampling and analysis of off-site sediments
• All sediments found to contaminated with
• PAHs
• Oil and grease
• dioxin/furans
• metals (in ditches only)

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Post Closure Permit 24H
July 28, 1995 ADPCE issues Post Closure
Permit to Koppers NLR. Recovery wells for DNAPL
extraction required.
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Interim Measures RCRA Permit 24H

• May 1996 to March 1997
• Test borings to further delineate the DNAPL
  pond
• Analysis of boring data to determine optimum
• location for DNAPL recovery well
• DNAPL recovery well RW-4 installed
• Between 1998 and 2002
• three more DNAPL recovery wells installed

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Corrective Action Authority

• 2000
• Oversight of CA process transferred to ADEQ
• 3008(h) Order closed out
• Permit 24H becomes CA document

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Corrective Action Strategy

• February 15, 2001
• Koppers submits Notice of Intent to enter into
  Corrective Action Strategy (CAS) Program
• February 22, 2001
• CAS Scoping meeting held
• March 13, 2001
• Risk Assessment Report filed by Koppers
• January 2002
• Two new DNAPL recovery wells installed (RW-6
  RW-7) and one old well refurbished (RW-4)

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Original DNAPL Recovery System

• Converted monitoring well
• Submersible pulse pump (pneumatic)
• Equipment shed

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Original DNAPL Recovery System

• Compressor
• Pressure regulator
• Air Filter
• Air dryer
• Pneumatic controller
• DNAPL storage drum
• Flow meter w/ chart recorder (not shown)

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Original DNAPL Recovery System

• Operation of System
• Pneumatic controller cycles pulse pump
• Pump is off to allow DNAPL to collect and fill
  bottom
• of recovery well
• Pump is turned on to pump collected DNAPL to
• storage drum
• Cycle repeats
• Level control in storage drum shuts off system
  when
• near full

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Current DNAPL Recovery System
Enhanced System Through pumping and
re-circulation of groundwater, DNAPL elevations
increase near the well (effect was discovered
during RFI-SS testing at RW-3 recovery
well). This causes increased flow into the
recovery well, thus shorter pump cycle times, and
an increased DNAPL recovery rate.
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Current DNAPL Recovery System

• Recovery well
• DNAPL recovery pump
• GW extraction pump
• GW re-circulation pump
• GW re-circulation well

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Current DNAPL Recovery System
Current DNAPL Recovery System
DNAPLStoragetank
RW-6well head
DNAPL recovery system Well RW-6
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Corrective Action Strategy

• March 12, 2002
• Soil and Sediment Sampling and Analysis Work
  Plan (to supplement Risk Assessment Report) filed
  by Koppers
• April 30, 2002
• Koppers submits Corrective Action Strategy
• Proposed Performance Standards
• Soil and Sediment Sampling and Analysis Work
  Plan
• (SSSAWP) implemented
• December 3, 2002
• Koppers submits results of SSSAWP

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Corrective Action Strategy

• August 18, 2003
• Koppers submits Human Health Environmental Risk
  Assessment
• October 24, 2004
• Koppers submits CAS Proposed Performance
  Standards Supplement
• October 6, 2005
• Koppers submits letter concerning proposed
  Ground Water Institutional Controls

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Corrective Action Strategy

• February 1, 2006
• Human Health Environmental Risk Assessment
  approved
• On-site workers at risk (from surface soils)
• Institutional Controls needed to prevent access
  to
• contaminated groundwater
• March 27, 2006
• Meeting with Koppers to discuss proposed GWICs

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Corrective Action Strategy

• March 6, 2007
• Koppers submits Draft Risk Management Plan
• cover soils to prevent worker contact
• North Little Rock city ordinance concerning
  wells in
• Activity Use Limitations GWIC area
• Active monitoring of buffer zone around GWIC
  area for
• land use changes
• Continued recovery of DNAPL from subsurface
• Monitored natural attenuation of GW
  contamination plume

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RCRA Post Closure Permit 24H

• March 8, 2007
• Draft Permit Renewal into Public Notice
• April 23, 2007
• Close of Public Comment period on
• Draft Permit Renewal
• Permit Module XII(b)
• Standard Corrective Action procedure is
  contained in Module XII(b) of Draft Permit
  Renewal
• Corrective Action will revert to standard
  procedure if CAS process does produce
  satisfactory results

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Corrective Action at Koppers NLR
Questions