Document ZBYeg876k9q5n6735vBKMnbqJ

Applied Chemistry, Creative Solutions Solutia Inc. 702 Clydesdale Avenue Anniston, Alabama 36201-5328 Tel 256-231-8400 June 29, 2000 Mr. Wm. Gerald Hardy, Chief Hazardous Waste Branch Land Division Alabama Department of Environmental Management 1400 Coliseum Blvd. Montgomery, AL 36130-1463 Re: Responses to Comments on Revised Interim Measures Plan and Corrective Measures Study Highway 21 Bridge at Choccolocco Creek Alabama Department of Transportation Project No. STPAA-62(15) Dear Mr. Hardy: This letter provides Solutia's responses to the comments contained in a letter from the Alabama Department of Environmental Management (ADEM) dated May 22, 2000. Those comments relate to the revised Interim Measures Plan (IMP) and the Corrective Measures Study (CMS) which describe the corrective measures proposed for the site of a new bridge to be constructed on State Route 21 (S.R. 21) over Choccolocco Creek in Calhoun and Talladega Counties. Each of the comments is reproduced below in italicized text, immediately followed by our response. 1. CMS. Page 2, Second Bullet: Please clarify the planned depth of the pipe jacking pit excavation. What is the anticipated total depth required by the utility companies for pipe jacking and how will this anticipated depth impact the corrective measures activities? Response: The jacking pits will be a maximum of 16 feet deep. As noted in the referenced bullet, excavation for the corrective measures will continue until confirmation sampling indicates that PCB concentrations are equal to, or less than, 1 mg/kg, or to a depth of one foot below the planned base of the excavation (i.e., to a maximum depth of 16 feet), whichever comes first. The planned depth will not impact the corrective measures activities since these activities allow for that depth. The text of referenced section of the CMS has been revised to provide the requested clarification. OSW 148050 STLCOPCB4039660 Mr. Wm. Gerald Hardy Alabama Department of Environmental Protection -2- June 29, 2000 2. CMS. Paee 11, Section 3.2.4: Solutia states that periodic maintenance will be required to maintain cover integrity for Alternative No. 2. The Department believes that project needs and site conditions dictate additional, specific monitoring provisions. For the short term (perhaps the first 6 months after the completion of construction), inspection provisions should be more rigorous and frequent (perhaps weekly). Because Solutia's intent is to leave PCB-impacted materials covered in place indefinitely, it will be necessary to establish a long-term monitoring plan to adequately protect the waterway from potential release of PCBs. The plan should also address potential intervention in the future, shouldfuture road work or utility crossings potentially disturb covered materials. Please submit a Highway 21 Bridge Inspection and Monitoring Plan addressing both long and short-term inspection and monitoring (including erosion control) provisions. The plan should be submitted to A DEM along with the revised CMS. Response: The requested plan is attached to this letter. .3. Revised IM Plan Paee 5: Solutia states that it will measure upstream and downstream turbidity on a daily basis during construction. If turbidity levels show a significant increase in downstream levels ( defined as one order of magnitude above upstream levels ), additional water samples shall be collected andfiltered. In such cases, Solutia has proposed to analyze the filtered solidsfor PCBs and to analyze the filtratefor total suspended solids. ADEM has determined that additional sampling is necessary if downstream turbidity levels exceed one order of magnitude above upstream levels. In such cases, Solutia should also analyze the bulk water quality (to determine potential downstream PCB levels) in the surface water. Response: The procedure outlined in this section of the IMP is the same procedure that was approved by ADEM for use in the off-site portion of the RCRA Facility Investigation (RFI). It includes analysis of the whole water sample (not the filtrate as noted above) for total suspended solids (TSS) and analysis of the filtered solids for PCBs. This procedure is based on the fact that the PCBs will be adsorbed to the solids and will not be present in the aqueous phase because of the very low solubility of these compounds. Measurement of the TSS in the water and the PCB concentration on the solids allows the determination of any increase in downstream transport of PCBs as a result of runoff from the construction site. In order to remain consistent with the approved practice for determination of PCB transport in surface water, therefore, we propose to use the procedure currently outlined in the IMP. Accordingly, we have not revised the plan as requested. In addition to the revision to the CMS identified in the response to Comment No. 1, other minor revisions have been made to the document. These include the following: DSW 1A8Q5I STLCOPCB4039661 Mr. Wm. Gerald Hardy Alabama Department of Environmental Protection -3- June 29, 2000 Sheet numbers have been changed throughout the document to reflect the fact that one sheet has been added to the CMS drawing package. This new sheet (Sheet 6 of 17) was previously submitted to ADEM as part of the responses to comments on the IMP. It includes the test results for samples obtained along the Colonial Pipeline corridor which crosses the highway right-of-way south of Choccolocco Creek. Other minor changes which were made to the drawings accompanying the revised IMP have been included in the CMS drawing package. For example, Sheet 12 (previously Sheet 11) was revised to set the utility trench excavation limits to be coincident with the jacking pits in the vicinity of Choccolocco Creek and to define the limits of excavation for soils to be sent to an off-site disposal facility. Sheets 4 and 5 were revised to include the results of PCB testing performed on samples taken along the western side of the existing roadway. Once the new bridge and northbound roadway are complete, the existing road embankment will be raised and the existing bridge will be demolished and replaced. Raising the embankment will result in the toe of the embankment slope being extended westward of its present position. Sheets 16 and 17 (previously Sheets 15 and 16)were revised to extend the limits of the soil cover on the western side of the existing roadway. This cover extension is necessitated by the fact that the existing roadway grade will be raised in the future and worker access will be required along the western side of the right-of-way. Three copies of the revised CMS and the accompanying drawings are attached to this letter. Since we have not made any changes to the IMP, for reasons stated in our response to Comment No. 3 above, that document is not attached to this letter as you requested. Please review the attached material and call me if you have any questions or additional comments. Finally, in your letter of May 22, 2000 you make several statements which imply Solutia has not worked aggressively to allow the Highway 21 construction project to proceed on schedule. These statements are not supported by the factual record, as the review below clearly demonstrates. On October 14, 1999, after working extensively with the Alabama Department of Transportation (ALDOT), Solutia prepared and submitted a Pre-Construction Activities Work Plan to ALDOT. The work proposed in this plan included clearing of trees and vegetation from the work zone, excavation of a utility corridor, transport of soils with greater than 50 mg/kg PCBs to an approved landfill, and stockpiling of soils with PCB concentrations between one and fifty mg/kg on site pending review and approval of a Corrective Measures Study by ADEM. Because these activities were to be completed in compliance with TSCA, all excavated non-TSCA material was to be kept within the site QSW 148052 STLCOPCB4039662 Mr. Wm. Gerald Hardy Alabama Department of Environmental Protection -4- June 29, 2000 boundaries, and no corrective measures were included in that plan, no Interim Measures Plan should have been required. Solutia was prepared to begin our portion of the work at this time pending resolution of manageable comments from ALDOT. A meeting was held on November 16, 1999 to resolve these comments. A member of your staff was invited to this meeting to be made aware of the activities that were to take place. It was at this meeting that ADEM imposed the requirement that an Interim Measures Work Plan be submitted. You then state that Solutia took in excess of three months to submit an Interim Measures Work Plan to ADEM. This is also incorrect. In fact, Solutia submitted the Interim Measures Work Plan to ADEM approximately six weeks later on January 4, 2000. We did not receive comments from ADEM on this document until March 3, 2000. These comments were addressed by Solutia in a letter to you dated March 29, 2000. Additional comments were received from EPA on April 24, 2000 and were addressed by Solutia in a letter to you dated May 5, 2000. During this time several members of your staff made commitments to Solutia and ALDOT to have comments on these reports within two weeks of our submissions. As you can see from the above timeframe, none of these commitments were met. We are troubled that ADEM would imply that Solutia was not acting in good faith in a document that received such wide distribution. Solutia has and continues to demonstrate it's commitment to working closely with all agencies and the public to resolve our obligations in the Anniston area in a quick and productive manner. We remain prepared to move forward with an extensive amount of remedial work in Anniston, including the On-Site RFI report, the North Side Cover extension, the 11th Street Ditch, and other activities, some of which were proposed to ADEM over one year ago, as soon as we receive your approval. We repeat our offer, which has to date not been accepted by ADEM, to meet with you and members of your staff to facilitate this effort. Sincerely, Solutia Inc. Craig R. Branchfield Manager, Remedial Projects Attachments cc: Mr. Craig Brown, United States Environmental Protection Agency (USEPA) Mr. Russ McLean, USEPA Mr. Wesley Hardegree, USEPA Ms. Karen Knight, USEPA, Anniston Office Mr. B. E. Cox, ALDOT (w/ 3 copies of attachments) DSW 148053 STLCOPCB4039663