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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.
Gregory W. Council, P.E.
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
Short-Term Interim Measures Work Plan
Koppers portion of the Cabot Carbon/Koppers Superfund Site
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
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 ii
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.
Short-Term IM Work Plan 1
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
• 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
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.
Short-Term IM Work Plan 2
2 INTERIM MEAURES OBJECTIVES AND APPROACH
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.
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
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
Short-Term IM Work Plan 3
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.
18.104.22.168 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
Short-Term IM Work Plan 4
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.
22.214.171.124 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.
126.96.36.199 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
Short-Term IM Work Plan 5
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.
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.
Short-Term IM Work Plan 6
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
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.
188.8.131.52 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.
Short-Term IM Work Plan 7
Several of the IMs discusses above have been completed or are underway. Remaining tasks
• Miscellaneous chemical disposal;
• Debris and trash cleanup (ongoing);
• Tanks and structure decontamination;
• 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
Short-Term IM Work Plan 8
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.
Short-Term IM Work Plan 9
GeoTrans 2004, Addendum 6: Groundwater Flow and Transport Model, Draft Report, Koppers,
Inc. Site, Gainesville, Florida, October, 2004.
Short-Term IM Work Plan 10
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