NCD000770487_20021025_Johnson Controls Battery Group_FRBCERCLA RA_RD RA Engineering Evaulation Cost Analysis 2000 - 2002-OCR

•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
October 25, 2002
RE: Field trip to discuss the proposed RCRA '.treatment/staging area issue and complete a
reconnaissance of the lead contaminated basin areas.
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Walkertown, Forsyth County, North Carolina
On 19 September 2002, a representative of the NC Superfund Section drove to the Johnson
Controls Battery Group Site with Doug Roberts of the Hazardous Waste Section in Raleigh to
discuss a treatment/staging area proposed for treatment of hazardous waste containing soil and
sediment at the Site. Doug Roberts with the Raleigh central office and Steve Phibbs with the RCRA
Winston-Salem regional office met with RCRA representatives for the JCBG Site to complete a
reconnaissance of the facility and observed the contaminant source areas and reviewed the proposed
treatment/staging area design. No conclusions were made about how this treatment/staging area
could be constructed.
cc: Dave Lown, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An EQual Opportunity Affirmative Action Employer' 50% Recycled/ 10% Post-Consumer Paper
•
MEMORANDUM
To: Randy McElveen
Division of Water Quality
-Aquatic Toxicology Unit
October 24, ,2001
Div. of Waste Management
From: Sandy Mort .:,l.lA
Environmental Biologist, Aquatic Toxicology Unit
Subject: Johnson Controls Battery Group, Kernersville, NC
Wetlands sediment toxicity study, August 2001
I ·--------
C'/f/1:F"'c-,,·.«-,-'-) · ·, ·1n _N
I have completed review of JO-day Chironomus tentans invertebrate whole-sediment toxicity
tests performed on 10 samples collected from a wetlands receiving storm water drainage on
the Johnson Controls Battery Group site, Kernersville NC.
The sediment toxicity data indicates no statistically significant acute toxicity in the 8 site
samples as compared to 2 site background sample'.s and the (laboratory) control sediment.
Detection of organism effects may have been impacted by reduced test sensitivity resulting
from control-sediment organisms just meeting method quality control survivability criteria
(70%) and elevated control variability.
The mean survival rate in the lab control sediment was 71.25%, and 66.25% and 47.50% in
the 2 site background samples (i.e., site-specific negative controls). Coefficients of variation
(CV) for control responses are routinely used in toxicity testing to quantify control response
variability and assess test sensitivity. As the CV increases test sensitivity decreases. The lab
control survival CV was 24.2%, and the growth CV was 45.0%. USEPA reported inter-
laboratory precision studies performed in 1993 for C. tentans resulted in mean control
survival of 93.0% and a CV of 5.7%. Diminished test sensitivity reduces the ability to detect
statistically significant toxicity differences between the test samples and controls.
Additionally, several deviations from standard protocols were noted in the execution of the
sediment toxicity tests that may have also contributed to reduced test sensitivity and reduced
representation of site sediment effects. Alkalinity was reported to have varied by more than
50% in the overlying water. This may be a result ,of water change-over procedures, which
were not clearly described in the study. Increased alkalinity may decrease bioavailability of
some metals. The impact of the alkalinity effects:in this instance is unknown. Deviation ·
from prescribed test organism acclimation protocols prior to initiation of the test may have
stressed test organisms and also contributed to elevated and variable mortalities in the
controls.
Site data indicates sediment total lead concentrations from 4 to >22 times USEPA Region 4
chronic ecological screening values (ESVs) for sediment in the 8 "lead impacted" samples.
Environmental Sciences Branch Water Quality Section
• Two site background samples were reported with lead concentrations of 0.78 and 1.2 times
Region 4 ESVs. The lack of observed sediment toxicity in light of the elevated lead levels is
puzzling. Because of this disagreement in components of the sediment triad assessment, and
the potentially reduced sensitivity in the IO-day sediment toxicity test, explanation and
additional lines-of-evidence are recommended to confirm the toxicity test data.
Additional lines of evidence routinely employed in risk assessment include tissue data and
population/community assessments to assess lead bioavailability and ecological impacts.
The wetland environment does complicate the collection and assessment of these data types .
. A simplified wetlands assessment including benthos appraisal by biologists familiar with
\ l.vetland ecosystems may be an appropriate alternative for this site. DWQ personnel may be
;a~~ilable for tqi,;, operation. Also, a more sensitive sediment toxicity test could be employed
using longer exposM'e1,;periods and an organism more sensitive to the contaminant of concern
on this site, such as 28-day Hya'lella azteca whole-sediment tests. USEPA data indicates H.
azteca to be more sensitive to some metals than C. tentans and toxicity data from USEPA's
AQUIRE database indicates H. azteca to be more sensitive to lead than C. tentans. Analysis
of sediment pore water could be used to determine the concentration of dissolved lead and
provide an estimate of the maximum bioavailable lead concentration in the water matrix.
A possible explanation for the lack of observed sediment toxicity in light of the elevated
sediment lead concentrations is metal-ligand complexation reducing lead bioavailability.
Study samples had TOC levels in the 50,000 to > 120,000 mg/kg range. Sulfide, produced in
anaerobic sediment environments, may also complex lead and reduce metal bioavailability
when sulfide to metal molar ratios exceed I. This relationship has been studied for a specific
group of metals, including lead. There is no sulfide or A VS data available for this study to
evaluate this impact.
Another possible explanation is IO-day sediment toxicity tests may not provide as sensitive
an endpoint as 28 to 42-day sediment toxicity tests, and Chironomus have reportedly less
sensitivity to some metals than other organisms (Hyalella azteca) specified in USEPA
freshwater whole-sediment toxicity methods. Most ESVs are provided as the more sensitive
chronic endpoints, which have the greatest relevance to long-term exposures and detection of
deleterious environmental effects. It is possible that the test organism and the 10-day
endpoints did not provide the sensitivity to detect effects due to lead in site sediments.
It was also observed that the I 0-day ammonia levels in 9 of the samples exceeded the mean
C. tentans 10-day LC50 obtained from USEPA's AQUIRE database (ammonia mean= 2.30
mg/L, median = 2.41 mg/L). The impact of this potential source of toxicity on the results is
unknown, but could have confounded results and test sensitivity.
In summary, based on the conflicting evidence provided by the lead analytical data which
significantly exceeds levels where chronic effects would be expected, the lack of detectable
effects observed in the IO-day C. tentans whole-sediment toxicity tests and the potential
toxicity test sensitivity problems, additional lines of evidence are recommended to confirm
no environmental effects due to sediment lead contamination on this site.
cc: Matt Matthews, A TU
Environmental Sciences Branch Water Quality Section
North Carolina •
Department of Environment and ral Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
September 27, 2002
RE: National Pollutant Discharge Elimination System (NPDES) Issues
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores:
Chris Preston with ENT ACT raised concerns about the NPDES permit at the JCBG Site in
recent telephone conversations. Based on telephone discussions and conference calls with Steve
Mauney of the Division of Water Quality (DWQ), it was determined that the existing NPDES
Permit, that JCBG has, does not have to be revised until after the mega-basin construction is
completed and the NPDES Permit is upgraded. Based on a voice mail from Corey Basinger with
the DWQ, Section "E" of the JCBG NPDES Permit only requires that DWQ be notified if the
facility plans to make changes to the permitted area or structures. The Walkertown JCBG facility
must however, maintain all the NPDES requirements during the construction of the Mega-basin and
Removal Action. As long as the existing NPDES discharge requirements are met CERCLA actions
should continue.
With appropriate settling ponds and other sediment and erosion control measures that are
required at the site, all NPDES discharge requirements should be met. If at any point in the work
discharge concerns arise appropriate measures should be taken to correct the problem.
The State looks forward to working with you on the project. If you have any questions or
comments, please call me, at [phone], extension 341 or email at
ranclv.mccl vcen@ncmai I .net.
Sincerely, \!~
~Al .ce.. )lV\~.~
Randy McEI veen
Environmental Engineer
NC S4perfund Section
cc: Dave Lown, N.C. Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: 9 I 9-715-3605 \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
•
J~HNSON
CONTRt1LS
Dear Mr. Flores:
Re: JCl's Winston-Salem Remediation
Luis Flores
U.S. EPA Region 4
Remedial Project Manager
North Site Management Branch
61 Forsyth Street. S.W.
Atlanta, GA 30303
September 12, 2002
Johnson Controls, Inc. (JCI) will conduct appropriate ground water sampling and
analysis to address U.S. EPA and North Carolina DENR concerns at the conclusion of
the soil removal and remediation phase of this project. JCI will submit a draft ground
water work plan to the agency for approval prior to the completion of the field work.
Very truly yours,
JOHNSON CONTROLS BATTERY GROUP, INC.
-~~
Debbie Hastings
Sr. Environmental Engineer
cc. Mr. Randy McElveen, NCDENR
Mr. Tim Lafond
September 6, 2002
Luis E. Flores
United States Environmental Protection Agency
Region 4, North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, GA 30303
1360 North Wood Dale Road
Suite A
Wood Dale, Illinois
60191
LTR-WNSA-10
1
. ~-;-;:,-·.. . n I rJ,; {; fi'. // \\,/ i/ -. ~~-I
/J'( SEP ·-9 ~~ . ,/i ])//
, : <cu!. , ... ' I ' ' ' I I ,. _,,,' J
RE: I .. .., ----i In the Matter of: Johnson Controls Battery Group, Inc.,: '· ·.-. -1 , · , ., ·· ·• ;
Walkertown, Forsyth County, NC; Administrative Order· on . '' '-'. '· 1
:. c·, '' ' ' I
Consent for Non-Time Critical Removal Action -.
Dear Mr. Flores:
Please find enclosed three (3) copies of the monthly progress report for the above
referenced site. This report is submitted pursuant to Section VIII, Paragraph 26(a) of
the Administrative Order on Consent for Non-nme Critical Action.
Please contact me if you have any questions regarding this submittal. I can be reached
at 630.616.2100.
''ll/J!-_"'°·
Christ pher D. Preston, P.E.
ENTACT
Enclosures
Cc: Randy McElveen -NCDENR (2 copies)
nmothy J. Lafond -JCBGI (1 copy)
Dennis P. Reis -Dennis Reis, LLC (1 copy)
n.fi30.ti!r5.1/()() • www cnrr1r·r r:nm ·r !'l 3 n r. , I'! o ? n ~
December 19, 2001
Mr. Luis Flores
Remedial Project Manager
U.S. EPA Region 4
North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, GA 30303
Re: Final EE/CA Report Changes
JCBGI Winston-Salem Site
Dear Luis:
•
I _L u
--A-ttz.cl\ .. &-r> rs £--.... s .vr't..,_cl ,',,,
Doc.'-'"""-"-.,ct-;,. .
Attached are 4 copies of revised pages 130 and 138 from text for the final Engineering
Evaluation/Cost Analysis (EE/CA) report for the Johnson Controls Battery Group, Inc.
(JCBGI) Winston-Salem Site, submitted on December 11, 2001. As with the previous
submittal, two copies of a red-lined copy of the pages are attached to facilitate the agency's
review. Copies of the revised pages will be distributed to other agencies as indicated
below.
Please replace pages 130 and 138 of the text with the attached pages. As discussed in our
telephone conversation on December 17, 2001, revisions to these pages were completed to
provide flexibility in the disposal of sediment from basins #2 and #3 during remedial
activities. JCBGI would like the option of placing this material on-site in general fill areas
if contaminant concentrations are less than the applicable cleanup levels (e.g., sediments
less than 100 mg/kg total lead would be placed on-site within basin #1).
Please call me with any comments or questions.
Sincerely,
MWH
Daniel W. Hall, PG
Project Manager
Enclosure: Revised EE/CA Report Pages 130 and 138 (4 copies and 2 redline copies)
cc: Mr. Randy McElveen, NCDENR (I copy and I redline copy)
Mr. Steve Mauney, NCDENR (1 copy)
Mr. Van Sullivan, Forsyth County (I copy)
Mr. Timothy J. Lafond, JCBGI (2 copies)
Ms. Jane Fowler, Quarles & Brady (2 copies)
DTUdtl/v!r/DWH
N :\Jobs\208\2326\0 l \wp\ltr\87 Flores.doc
2082326.01160101-MADJ -
One Science Court
P.O. Box 5385
Madison, Wisconsin
53705-0385
Tel:[phone]
Fnx: 608 7.31 11777
Delivering Innovative Projects a11d So/urio11s Worldwide
• •
• I . ENGINEERING EVALUATION/COST ANALYSIS (EE/CA) PROCESS
EPA has implemented the Ep/CA process at this Site. The diagram for the EE/CA process is
featured foljowing this section outlining the standard steps in the process. The following major
steps are normal for non-time critical removal actions:
• A "removal site evaluation" is conducted to identify the source and nature of the release
or threatened release of hazardous materials! and to assess the threat to public health, the
magnitude of the threat and the factors necessary to determine the need for a removal
action.
• An EE/CA (Engineering Evaluation/Cost Analysis) Approval Memorandum is
prepared by the Project Manager after the site evaluation has been completed. This
memorandum serves three functions:
I) se·cure EPA management approval and funding to conduct the EE/CA,
2) documents that the situation meets the National Contingency Plan crite1ia for
initiating a removal action and that the proposed action is non-time-
critical, and ·
3) it includes detailed information pertaining to actual or threatened releases of
hazardous substances or pollutants from the site that may present an
imminent and/or substantial endangerment; general_ information pertaining
to the site background; threat_s to public health, welfare, or the
environment posed by the site which inc!Ltdes expected changes in the
situation if no action is_ taken; enforcement activities related to the site;
and estimated project costs.
This is a preliminary document outlining the possibility/probability of contamination,
• Then an EE/CA ExecutiveSummary report is prepared identifying the objectives of the
removal action and an analysis of the various alternatives that may be used to meet the
objectives for cost, effectiveness, and implementability. The EE/CA should provide
definitive information on the locations of hazardous substances/contaminants; quantity,
volume, size or magnitude of the contamination; physical and chemical characteristics of
the contaminants; and risks presented by the site; and various alternatives available for
treating the contaminants.
• Conduct EE/CA Site Characterization based upon the Approval Memorandum, i.e., site
description; type of facility and operations; area of site and topography; geology of area;
land use and populations; ecosystems; rain/snow amounts; any previous removal actions
at the site; identify responsible parties; source, nature and extent of contamination;
identify applicable treatment technologies; etc.
• •
• An EE/CA Action Memorandum is prepared providing a concise, written record of the
decision for selecting the response action based upon technical data-. -This document
along with others developed du1ing the process are placed in the Administrative Record
in the information repository for public viewing. ·
• A public notice describing the EE/CA report and proposed action fact sheet for the site
are prepared and mailed to citizens on the site's mailing list and notice is published in
local newspapers, and a minimum 30-day public comment period is offered and noticed.
in a major local newspaper. A.public meeting will be held during the 30 day period to
· present the results of the EE/CA investigation to the public, and to respond to questions. ·
EPA will respond in writing to comments received during the public comment period
after the selection of the response act is made.
• A public notice of the Removal Action implementation will be provided prior to such
action being taken.
ENGINEERING EVALUATION/COST ANALYSIS (EE/CA)
PROCESS
EE/CA Approval ~►
Mermrandum
EE/CA
I Exocutive Surrrrary I
Site Oiaracterizatior
Identification of
Removal Action
O:>jectives
Identification of
Analysis of
Removal Action
Alternatives
uimparat1ve
Analysis of
Rermval Action
Alternatives
Reoonmended
Rermval Action
Alternative
Public Corm-en\ ---.
Response to Action
-► Period ~ Comments -► Mermrandum
(at least 30 days)
•
•
• (Ill) !Y1Yc!tttATSON HARZA
November 13, 2001
Mr. Randy McE!vccn
•
North Carolina Department of Environment and Natural Resources
Division of Waste Management
40 I Oberlin Road, Suite 150, 1646 Mail Service Center
Raleigh, North Carolina 27605
Re: Response to October 4, 200 I Comments
JCBGI Winston-Salem EE/CA Report
NCD 000 770 487
Dear Randy:
Attached arc responses to the comments from your review of the EE/CA for the Johnson
Controls Battery Group, Inc. site in Winston Salem, NC, as presented in your October 4,
2001 letter to Luis Flores ofUSEPA, Region 4. We arc pleased that the State concurs with
the preferred removal action alternative presented in the EE/CA.
We discussed USEPA's comments associated with ecological risk with Luis and Sharon
Toms on November 6. We discussed comments associated with human health risk with
Kevin Korporec on occasions the week prior. The discussions and agreements we reached
with US EPA support a remedy that is protective of human health and the environment, and
largely reflect the preferred removal action as described in the EE/CA. These agreements
are reflected in the response to the State's comments presented below.
I. The fourth paragraph 011 page 13 discusses surface water run-off from the lead oxide
unloading dock. The path of the majority of the 1w1-o[f from this area is unclear and
should be fi1rther evaluated during the Design. The paragraph indicates that the
majority of this run-off is channeled through underground piping to the splash pad at
the head of sedimentation basin #1. The State does not recall a catch basin in this
area. However, even if a catch basin does exist this area is not well graded and has
no definite flow pallern. Much of the swface runoff from the paved areas adjacent to
the lead oxide unloading dock flows into the grassed drainage swede locatedjust east
of and parallel to the paved areas.
This drainage swede 110 longer has a clear drainage path. During rainy days the
State has observed the rainwater collect in the swede and ove,jlow into the adjacent
grassed field. The drainage (,·om this area should be improved and properly
controlled as part of the improvements to contain the lead oxide that spills from the
unloading process. A containment system should be developed around the immediate
area of the 1111loadi11g dock and cleaned out 011 a regular basis. It is recom111ended
that persons who are assigned to clean 011/ this area wear a respirator or a
medical/dust 111ask.
One Science Court
P.O. Box 5385
Madison, Wisconsin
53705-0385
Tel [phone]
Fax: [phone]
Delivering Innovative Projects and Solutio11s Worldwide
• •
Response: This text within the EE/CA is the Conceptual Site Model excerpted
without change from the Work Plan; it was added to the EE/CA text, based on
USEPA's comment (General Comment #6) in their August 28, 2001 letter. Inclusion
of this text only intends to describe our basic understanding of the site conditions at
the time of the Work Plan preparation. The description of the drainage pattern from
the lead oxide unloading area on p. 13 of the EE/CA is inaccurate, and was updated in
later portions of the EE/CA, based on field observations during the EE/CA
investigation. We will annotate the text of this section to provide an explanation or
the whereabouts of the correct information within the EE/CA.
We concur that the surface water flows into the grass drainage swale just east of the
paved areas. Our evaluation of the drainage patterns at the site indicate that this
drainage swale flows toward the north and water can either continue flowing north to
a culvert beneath the building or to the east to the grassy field. Water flowing into
the grassy field is captured by a swale along the south and east edges of the field and
directed around the building to the north.
Drainage control in the vicinity of the lead oxide unloading area will be addressed in
the design plan for the site to control lead oxide releases from this area. However,
lead oxide is unloaded at the facility currently on an infrequent basis, because the
facility now manufactures most of its own oxide within the plant. Current practice
with unloading is sealed pnuematic transfer of the lead oxide from tanker trucks to
internal storage areas and is no longer considered a significant source of lead to the
environment. Any spillage from the lead oxide unloading will be addressed in best
management practices (BMPs) developed for the facility storm water management
plan (SWPPP) under State authorization. We envision that the BMP applied to this
area would be part of the general sweeping program, and in the case of a spill, the
procedure would call for immediate sweeping or containment (the methods used
would be weather dependent). Health & safety concerns would be addressed as part
of overall company policy and procedures.
2. The paragraph at the top of page 14 should be removed or revised to indicate the
actual depths of the groundwater in the area of the facility. These depths are now
known and should be communicated here. if anything. The depths of groundwater in
the area of the facility is 27 to 38 feet below top of casing elevations which in most
cases is near ground surfc,ce.
Response: This text within the EE/CA is the Conceptual Site Model excerpted
without change from the Work Plan, as is described in the first paragraph of Section
1.4. The Conceptual Site Model was added to the EE/CA text, based on USEPA's
comment (General Comment #6) in their August 28, 2001 letter. Inclusion of this
text only describes our basic understanding of the site conditions at the time of the
Work Plan preparation, so it was not intended to be modified from its use in the Work
Plan. We will annotate the text of this section to provide an explanation or the
whereabouts of the correct information within the EE/CA. The depths to
Mr. Randy McE\vccn November 13, 200 I NCDENR
Page 2
• •
groundwater, based on the EE/CA field investigation, are described in Section 2.2.4.1
in the report.
3. The Met_eorology Section on page 17 states that net annual precipitation averages JO
inches near the Site even though annual rainfall is approximately 48 inches. If this is
to adjust for the facility and paved structures it may be a reasonable estimate. In
unpaved areas however, much of the rainfall will infiltrate to groundwater before it
evaporates or transpires. Care should be taken as to how this number is used in the
future if at all.
Response: The second sentence addressing net precipitation will be removed from
the text.
4. The first paragraph on page 100 (Section 3) states that sediment in the wetland below
basin #1 are not carried forward in the analysis of removal action alternatives. This
statement is inconsistent with the information form Section 3.2.2 and the associated
Figure 14 that describe and show these areas being removed along with basin #1
area soil and sediment. The sentence on page 100 should be changed or removed to
be consistent with later Section's of the report. The sediment contamination in this
area exceeds all agreed cleanup goals and must be removed or treated during this
scope of work.
Response: We believe there is a misunderstanding of which sediments are being
addressed by the first paragraph in Section 3.0 and we will clarify the intent. It is
accurate that the wetland sediments below basin #1 do not require remediation, as
stated. The information presented in Section 3.2.2 and on Figure 14 address the
sediments immediately below basin # 1 which are still on JCBGI property. These
sediments are not considered within the wetland area. We will make sure this
distinction is made in the revisions.
5. The State recommends that sediment in the drainage swale to Basin #2 be cleaned up
to 100 mg/kg total lead. This would require a minimum of additional excavation
along the central portion of the drainage swale starting at SB-51E and ending at the
extent of contamination at SB-51 B. The contamination in the area around location
SB-51 B is primarily along the central portion of the drainage swede and the
excavation proposed in this area can be elongated to focus on these higher
concentration sediments and impacted soils. The Area around SB-5/E is right at the
head of the drainage swale and has concentrations up to 330 mg/kg. These higher
concentration sediment/soils could significantly impact future surface water quality.
The basin sediments are proposed for removal and disposal at a non-hazardous
landfill. This will significantly improve surface water quality. The lead
concentrations in sediments along the drainage swale leading into basin #3 were
generally lower and significantly lower than concentrations in the area of SB-51 B.
Future sediment transport from the upgradient area of basin #3 also have further to
travel and therefore will be more dilute. The highest concentration in the swale
Mr. Randy McElveen November 13, 2001 NCDENR
Page 3
• •
leading to basin 3 was 300 mg/kg at SB-33D. This node is located sway J,-om the
primary flow path and is probably as isolated occurrence. It may be desirable to take
a composite sample within a 25 feet area of his node to veri/51 the area co11ce11/ralio11.
SB-35 is located in the low area of the basin #3 drainage swede. If sediment buildup
is located in this area it may be desirable to remove these sediments also since they
are closer to the proposed mega basin along the central flow path and were noted at
concentrations of 210 to 240 mg/kg. These additional removal measures, discussed
above, are recommended in order to help minimize the future impact of lead 011
surface waler discharge from the proposed mega basin. This will also minimize
future exposure pathways to humans and animals in these areas closest to the facility.
Response: In discussions with USEPA, it was agreed that the remedy proposed for
the area behind basins #2 and #3 would be protective of human health and the
environment by:
• Removing soils above a concentration of 400 mg/kg lead (in the area near
SB5 l B behind basin #2) and
• Demonstrating that the average lead soil concentration behind basins #2 and
#3 is I 00 mg/kg or less.
US EPA was satisfied that the remedy would be protective of human health and the
environment, even with leaving small areas above I 00 mg/kg. Confirmation testing
will be conducted around the area of excavation near boring SB5 I B to determine that
excavation meets intended cleanup levels, and overall, is protective.
The megabasin will capture surface water flows from the entire plant facility and will
provide settling capacity of lead sediment in suspension, within in certain storm-size
and particle size limits, which is not afforded by the current storm water basins. The
particulate lead in suspension apparently contributes the bulk of the total lead
concentration in basins #2 and #3 surface water samples, so there should be some
expected reductions to total lead in the megabasin with greater settling capacity. We
certainly appreciate the State's concern for wanting to enhance the probability of
meeting surface water discharge standards at the discharge location. However, at this
time, we do not know that removing isolated soil concentrations above I 00 mg/kg
within the drainage areas will substantially lower the total lead concentration at the
discharge location for the megabasin. The overall average lead soil concentration
behind basins #2 and #3 is currently below I 00 mg/kg and the number of sample
locations exceeding 200 mg/kg is three. Further, there is no reliable correlation to
draw between soil/sediment concentrations and discharge water quality, so we intend
to rely on surface water discharge monitoring after megabasin construction to
detem1ine if additional measures are needed to reduce total lead content at the
discharge point. We propose that the performance of the megabasin be judged during
a shakedown period after construction, allowing for a sufficient time for the system to
reach some equilibrium (we expect that construction will increase the sediment load
to the basin on the short-term). If the water quality does not meet standards at the
Mr. Randy McElvccn November 13, 2001 NCDENR
Page 4
• •
conclusion of the shakedown period, additional measures will be evaluated and
implemented to improve the discharge water quality.
6. It is advisable to confirm all excavations with co111posite samples and to take
co111posite sa111ples in grid areas around for111er sa111ple nodes that exceed
background upgradient of basins 2 and 3 to show that the average exposure is less
than background. This would 111inimize the area required to be deed recorded. Most
of the sediments/soils exceeding background are located along the central flow path
to the basins (in basin 2 area SB-51D, SB-5/E, SB-5/JJ, SB-28B, SB-28). If these
areas are re111oved and confirmed with co111posite samples or included in the mega
basin construction, only areas SB-53B and SD-33 will require co111posite testing in
order for this area to meet background requirements.
Response: The soil quality at the perimeter and base of excavation will demonstrate
that residual lead soil concentrations are below the cleanup criteria that are protective
of human health and the environment. As agreed with USEPA, up to 400 mg/kg lead
in soil can be left in place behind basins #2 and #3 after soil excavation, so long as
the average lead soil concentration in the entire area is below I 00 mg/kg. The soil
excavation behind basins #2 and #3 is not intended to achieve lead soil background
levels, although we expect this will be achieved with depth as a practical matter, but
not laterally. The area of soil excavation has been defined in the EE/CA, based on
soil sampling and analysis, to be the area in the vicinity of boring SBSIB. Based on
the cleanup levels, USEPA has agreed that no additional excavations are necessary to
be protective of human health and the environment.
We believe that sufficient soil samples have been collected to adequately characterize
the degree and extent of lead soil behind basins #2 and #3, so no additional sampling
around node locations, where no excavations are planned, will be conducted.
However, confirmation sampling will be conducted at the perimeter and on the base
of the excavated soil area. In the design plan, we will prepare a sampling plan that
may utilize some aspect of composite sampling to evaluate whether we have achieved
cleanup goals.
7. The State agrees with Alternative #2 as the preferred alternative for remediation of
soil and sediment at the Site.
Response: Comment acknowledged.
We are prepared to complete the final EE/CA, based on our discussions with USEPA about
their comments. However, we want to be certain that NCDENR is satisfied with the
approach we have agreed to with USEPA. We would like to know soon whether there are
any other thoughts NCDENR may have on the remediation approach before we complete
the final changes to the EE/CA document.
Mr. Randy McElvccn November 13, 200 I NCDENR
Page 5
• •
1 will call you Friday, November 16, to discuss NCDENR's comments. lf this time is
inconvenient, please let me know what other arrangements can be made.
Sincerely,
MWH
Daniel W. Hall, PG
Project Manager
cc: Timothy J. Lafond, JCBGI
Jane Fowler, Quarles & Brady
Luis Flores, USEPA
Dale Lane, MWH
DWH/v!r/DWI I
N:Vobs\208\2326\0\ \wp\rpt\95 _McElvecn Resp to I 0-0 I Comments.doc
2082326.01160101-MADI
Mr. Randy McElveen November 13, 2001
Page 6
NCDENR
North Carolina •
Department of Environment a'nd Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
. 61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
October 4, 2001
RE: Comments on the Revised Engineering'Evaluation/Cost Analysis, all Media
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores:
The Revised Engineering Evaluation/ Cost Analysis (EE/CA) Report, dated
September 2001, for all media of concern at the Johnson Controls Battery Facility,
located in Winston-Salem, NC has been received and reviewed. The following comments
by the North Carolina Superfund Section are submitted for your consideration. When the
EE/CA is finalized please have JCBG mail the NC Superfund Section a signed/final copy
for our files.
General Comment
The State concurs with the preferred alternative for remediation of lead contaminated soil
and sediments at the Site and with the exceptions noted in our comments that follow we
expect that the work proposed will minimize future impacts to the fullest extent
practicable.
Specific Comments
I. The fourth paragraph on page 13 discusses surface water run-off from the lead oxide
unloading dock. The path of the majority of the run-off from this area is unclear and
should be further evaluated during the Design. The paragraph indicates that the
majority of this run-off is channeled through underground piping to the splash pad at
the head of sedimentation basin #1. The State does not recall a catch basin in this
area. However, even if a catch basin does exist this area is not well graded and has no
definite flow pattern. Much of the surface·runoff from the paved areas adjacent to the
lead oxide unloading dock flows into the grassed drainage swale located just east of
and parallel to the paved areas.
Mr. Luis Flores
8-21-2001
Page 2 of 3
•
This drainage swale no longer has a clear drainage path. During rainy days the State
has observed the rainwater collect in the swale and ovetflow into the adjacent grassed
field. The drainage from this area should be improved and properly controlled as part
of the improvements to contain the lead oxide that spills from the unloading process.
A containment system should be developed around the immediate area of the
unloading dock and cleaned out on a regul,ar basis. It is recommended that persons
who are assigned to clean out this area wear a respirator or a medical/dust mask.
2. The paragraph at the top of page 14 should be removed or revised to indicate the
actual depths of the groundwater in the area of the facility. These depths are now
known and should be communicated here, if anything. The depths of groundwater in
the area of the facility is 27 to 38 feet below top of casing elevations which in most
cases is near ground surface.
3. The Meteorology Section on page 17 states that net annual precipitation averages 10
inches near the Site even though annual rainfall is approximately 48 inches. If this is
to adjust for the facility and paved structures it may be a reasonable estimate. In
unpaved areas however, much of the rainfall will infiltrate to groundwater before it
evaporates or transpires. Care should be taken as to how this number is used in the
future if at all.
4. The first paragraph on page 100 (Section 3) states that sediment in the wetland below
basin #1 are not carried forward in the analysis of removal action alternatives. This
statement is inconsistent with the information from Section 3.2.2 and the associated
Figure 14 that describe and show these areas being removed along with basin #1 area
soil and sediment. The sentence on page 100 should be change or removed to be
consistent with later Sections of the report, The sediment contamination in this area
exceeds all agreed cleanup goals and must be removed or treated during this scope of
work.
5. The State recommends that sediment in the drainage swale to Basin #2 be cleaned up
to 100 mg/kg total lead. This would require a minimum of additional excavation
along the central portion of the drainage swale starting at SB-5 lE and ending at the
extent of contamination at SB-5 lB. The contamination in the area around location
SB-5 lB is primarily along the central portion of the drainage swale and the
excavation proposed in this area can be elongated to focus on these higher
concentration sediments and impacted soils. The Area around SB-51E is right at the
head of the drainage swale and has concentrations up to 330 mg/kg. These higher
concentration sediments/soils could significantly impact future surface water quality.
The basin sediments are proposed for rymoval and disposal at a non-hazardous
landfill. This will significantly improve surface water quality. The lead
concentrations in sediments along the drainage swale leading into basin #3 were
Mr. Luis Flores
8-21-2001
Page 3 of3
• •
generally lower and significantly lower than concentrations in the area of SB-5 lB.
Future sediment transport from the upgradient area of basin #3 also have further to
travel and therefore will be more dilute. The highest concentration in the swale
leading to basin 3 was 300 mg/kg at SB-33D. This node is located away from the
primary flow path and is probably an isolated occurrence. It may be desirable to take
a composite sample within a 25 feet area of this node to verify the area concentration.
SB-35 is located in the low area of the basin #3 drainage swale. If sediment buildup
is located in this area it may be desirable to remove these sediments also since they
are closer to the proposed mega basin along the central flow path and were noted at
concentrations of 210 to 240 mg/kg. These additional removal measures, discussed
above, are recommended in order to help minimize the future impact of lead on
surface water discharge from the proposed mega basin. This will also minimized
future exposure pathways to humans and animals in these areas closest to the facility.
6. It is advisable to confirm all excavations with composite samples and to take
composite samples in grid areas around former sample nodes that exceed background
upgradient of basins 2 and 3 to show. that the average exposure is less than
background. This would minimize the area required to be deed recorded. Most of the
sediments/soils exceeding background are located along the central flow path to the
basins (in basin 2 area SB-51D, SB-5 lE, SB-5 lB, SB-28B, SB-28). If these areas are
removed and confirmed with composite samples or included in the mega basin
construction, only areas SB-53B and SD-33 will require composite testing in order for
this area to meet background requirements.
7. The State agrees with Alternative# 2 as the preferred alternative for remediation of
soil and sediment at the Site.
The State appreciates the opportunity to comment on this document and we look forward
to working with you on the project. If you have any questions or comments, please call
me, at [phone], extension 341.
Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
September 14, 200 I •
RE: Conference Call on the Draft Engineering Evaluation/Cost Analysis Report Comments
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 4 September 2001, a representative of the NC Superfund Section participated in a
conference call with representatives of the NC DENR Water Quality Section and the Consultants
and other representatives for the Johnson Controls Battery Group, Inc. Those in attendance at the
meeting included Steve Mauney, NC DENR Water Quality Section, and Johnson Controls Battery
Group representatives Dan Hall, Jane Cloaky, Dan Gustonson, and Michael Kierski, with
Montgomery Watson Hazer. The purpose of the call was to discuss the Agencies comments and the
Responsible Parties (RPs) responses to comments on the Draft Engineering Evaluation/Cost Analysis
Report for all Media at the Johnson Controls Batte~y Group (JCBG) Facility.
cc: Grover Nicholson, N .C. Superfund Section·
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
Ao Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
North Carolina . a,
Department of Environment ai9<atural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Interim Director
Mr. Luis Flores/Sharon Thoms
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
~ .
November 14, 2001
RE: Toxic Metals Review of Wetlands Contamination
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores/Sharon:
•
As you know Sandy Mort with the Division of Water Quality (DWQ) of the DENR had
some concerns about the Toxicity study corripleted by JCBG Consultants. I recently
discussed the work further with her and she recommended this Toxic Metals Review in
reference to the low toxicity results obtained in the lab. She seems to think that this
study/ Review may give an explanation for why this may be occurring in the wetlands at
the JCBG Site. Luis please copy the Review for Sharon. I think she may have a greater
appreciation for it than we do.
The State appreciates the opportunity to work with you on the project. If you have any
questions or comments, please call me, at [phone], extension 341.
Si~cerely, \1 /)
~. 12 fl1cL~ Randy McE!veen
En,vironmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
October 18, 200 I •
RE: Conference Call on the Need for a New AOC and the Removal Design Schedule
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 17 October 2001, representatives of the NC Superfund Section participated in a
conference call with representatives of the EPA Region IV and the Consultants and Attorneys for
the Johnson Controls Battery Group, Inc. Those .in attendance at the meeting included JCBG
Attorneys Jane Fowler and Tim Lafonte, Quarles & Brady, Dan Hall with Montgomery Watson
Hazer, Luis Flores, EPAs RPM and Jennifer Lewis, EPAs Attorney, Region JV, and Rob Gel bl um,
NC Attorney Generals Office and Myself. The purpose of the call was to discuss the Agencies
schedule for the AOC and the timing of the Public comment period and Removal Design schedule
and other issues.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
September 14, 2001 •
RE: Overview of Sediment Sample Collection for Laboratory Toxicity Testing
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
EE/cA
On 6 and 7 August 2001, a representative of the NC Superfund Section provided overview
and assistance with locating and collection of Wetland #1 sediment samples and similar condition
sediment samples at the Johnson Controls Battery Group, Inc. Site located in Winston-Salem, NC.
Bobby Sauer and John Frank with Montgomery Watson Hazer completed the sediment sample
collection and shipment. On August the 6th sediment samples were collected from the wetland #1
area in former locations SD-29, SD-29A, SD-26, SD-26A, SD-28D, SD-30 and 4 locations within
25 feet north, east, south and west of former sample location SD-30. The following day background
samples were collected at SD-BG-03, SD-BG-09, and SD-BG-301 (near former sampling location
SD-BG-10) in the morning and returned to collect sediment samples SD-30A and 1 extra sample at
SD-26Z from wetland 1.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
July 19, 200 I •
RE: Conference Call on Streamlining the Ecological Risk Assessment in Wetland area.
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On June 26, 2001, a representative of the NC Superfund Section participated in a conference
call with representatives for EPA Region IV and representatives for the Johnson Controls Battery
Group, Inc. The conference call included the EP As RPM and their Risk Assessment representatives
for both human health and ecological areas. The JCBG representatives included Michael Kierski,
Ph.D, with Montgomery Watson, and Jane Fowler, Quarles and Brady LLP. The focus of the
meeting was on the specifics of the Eco Risk Assessment in the wetland area downgradient of facility
Basin #1 and how to proceed with the overall assessment in light of the proposed remedy.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affinnative Action Employer 50% Recycled/ 10% Post-Consumer Paper
Land Use Restriction Guidance for the JCBG Site
I ol' I
• • Subject: Land Use Restriction Guidance for the JCBG Site
Date: Tue, 26 Jun 2001 13:02:27 -0400
From: Randy McElveen <[e-mail]>
To: Daniel Hall <[e-mail]> ·
--....1 Cl ~ V\ ;; 0 V\. u Vll ~ ( ':,
t ~ire.HJ G--y-C) vp .
CC: Luis Flores <[e-mail]>,
GROVER NICHOLSON <[e-mail]>
Dan,
In our conference call today with Michael Kierski and Jane Fowler, we discussed the North Carolina DENI
Land Use Restriction (LUR) laws that are required anytime a site is not cleaned up tounrestricted use. All
sites in NC that are cleaned up to Industrial Risk levels require LURs be placed on the property deed.
Therefore, the Johnson Controls Battery Group Site in Winston-Salem, NC will require LURs. The
Inactive Hazardous Waste Branch of the NC Superfund Section has a simple guidance to help the JCBG
representatives think through how to write up these LURs. The Agencies will require a review of the
restrictions language to assure that all exposure scenarios are covered for both present and future land use.
If JCBG would like the NC Superfund Section ofDENR in consultation with the US EPA will provide the
language for inclusion in the property deed.
The State LURs guidance is included on the Superfund web page on the world wide web at
www.cnr.statc.nc. us/Ii !cs/cl i vision. htm
Click on Division of Waste Management
Click on Superfuncl
Click on Inactive Hazardous Sites Branch
Click on Guidance
Click on Inactive Hazardous Sites Guidelines for Assessment & Cleanup
The LURs are located at the back of this guidance as Appendix "D".
The NC Superfund Section & EPA attorneys are in the process of updating this guidance in order to
cooperate with the EPA at Superfund Sites. We should be able to easily include any changes made by the
State/EPA discussions at a later date. The State Attorney involved in this process is Mr. Rob Gelblum
[phone] and the EPA attorney is Ralando Bascombe. If you would like to discuss the LURs process
further please give me a call or contact Mr. Gelblum directly. This language should probably be included
on the next AOC.
Randy McElveen
NC Superfund Section
61261200 I I :06 l'M
I
J • MONTGOMERY WATSON
June 8, 200 I
Mr. Luis Flores
Remedial Project Manager
U.S. EPA Region 4
North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, GA 30303
Re: June 1, 200 I Discussion
• '"o!..,,,,_ ow•-\ D ~ '"
JUN 1 1 2001
SUPERfUND SECTION
Expedited Remediation and Risk Assessment Issues
JCBGI Winston-Salem EE/CA
Dear Luis:
This letter is a follow up to our discussion on June 1 regarding the expedited remediation
and the risk assessment issues for the JCBGI Winston-Salem EE/CA. Both of these issues
are key to the near-term scope and schedule of activities performed on the project.
You indicated EPA is willing to work with JCGBI on an expedited remediation approach
for the plant and basins areas, and is willing to categorize both as industrial areas, not
ecological areas. EPA is willing to recognize the expedited concept for the remedial
construction of the plant area and the wetlands in writing. We discussed that the plant and
basins areas remedies would likely not be driven by the risk assessment, but comparison to
appropriate site-screening levels (Region IX Industrial PRGs) for these industrial areas
would suffice for making cleanup decisions' in these industrial areas. In contrast, we
discussed it is more likely that the wetlands areas would be driven by the risk assessment,
which probably puts the wetlands on a longer term schedule for any needed remediation.
To make the expedited schedule move forward, you would like to review the results of the
investigation as soon as possible, so discussions with us can be meaningful. We talked
about the close communication it will take to expedite the plant area and basin area
remediation, but EPA is willing to do it.
With regard to the hybrid risk assessment, you indicated that EPA' s initial reaction is that
food chain models, such as proposed in the hybrid approach, may not be applicable to the
wetlands, because the area of highest risk (lead-sediment in the wetlands) is so small.
However, you suggested that EPA would probably be satisfied with taking sediment
samples from the 500-600 mg/kg area in wetland # 1, to see if this lead sediment
concentration passes toxicity testing. (A protocol would need to be established for EPA's
approval, but we would propose analyzing several samples in the 200 -600 mg/kg lead in
sediment range, with a comparable number of background/control sediment samples, using
an indicator species such as chironomus ten/ans). You also suggested that we 'combine
these toxicity testing results with the literature research on lead cleanup values to support a
cleanup number.
One Science Court
P.O. Box 5385
Madison, Wisconsin
53705-0385
Tel:[phone]
Fax: [phone]
Delivering Innovative Projects and Solutions Worldwide
' , , • •
We are moving ahead with completing the investigation portion of the report together for
EPA by early July. The risk assessment and engineering evaluation will not be included in
this investigation report. In the meantime, JCBGI is evaluating the merits of moving ahead
with the expedited remediation and should have a decision by mid-June. We will have to
re-evaluate the schedules for other deliverables with EPA under whatever approach JCBGI
takes.
We appreciate the agency's willingness to work with JCBGI on these important issues. We
look forward to discussing these issues with you further.
Sincerely,
MONTGOMERY WATSON
~w-~
Daniel W. Hall, PG
Project Manager
cc: Timothy J. Lafond -JCBGI
Debbie H. Hastings -JCBGI
Jane Fowler -Quarles & Brady
Mark Koczela -JCBGI
Glen Ponczak -JCI
Randy McElveen -NCDENR
DWH/vlr/DWH
N:\Jobs\208\2326\0 I \wp\ltr\96 Flores.doc
2082326.01160101 MAD-I -
Mr. Luis Flores June 8. 2001
Page 2
U.S. EPA Region 4
I of3
EE/CA.
file:///Untitled
Good morning Tom,
As Luis said we have not yet seen the data. We were given a presentation and told the maximum
concentrations in a particular area of concern and the general trend or potential average concentrations.
They did not have the data in an acceptable format at the time of the meeting or so they say. You may
contact Dan Hall at [phone] in Wisconsin. Michael Kierski is also at that location if you wish to
discuss the Site Screening Risk Assessment. I think the primary area of concern to Sharon Thoms, EPA
ECO person is the "one hit oflead at 650 ppm and other 200 + ppm concentrations in the wetlands down
at Lowrey Mill Creek. As you see below Sharon is recommending a clean up goal of 128 ppm for the
ECO areas including the Wetlands. That seems reasonable to me and to our toxicologist as long as there
are no species that are adversely affected by this concentration.
If we do accept this 128 ppm concentration or any concentration less than the 650 ppm level detected in
the wetlands will it be more ecologically impacting to the area to remove the contaminated sediments
than to leave them in place? If so then we would only need to document this fact and we can move on to
the Removal Action. Based on my personal observation of the color coded maps of concentration data,
the estimated wetlands area that exceeds 200 ppm is quiet large ( approximately . 5 to I. 5 acres) Kierski
can probably mail or email you a copy of the color coded drawings in the Wetlands area.
If you would like we could meet at the site in the near future and observe the areas of concern in a
morning or afternoon.
Randy McElveen
----------------------
Hi Randy-
Thanks for keeping me in the loop. I'd like to get a copy of the
analytical data and its summary I presentation (i.e., its context in
relation to the habitats on-site). Is Kierski still the best one to
contact to get this information?
Thanks,
Tom Augspurger
[e-mail] wrote:
Randy/Tom
JC has not submitted any analytical data yet. That was one of the problems
we faced in the meeting. We have not really seen the results yet. The
only information they provided in the meeting was color-coded maps, but no
analytical data.
Please see message below regarding ecological risk assessment.
Thanks,
Luis
5/15/2001 1:05 PM
2 of3
• •
-----Forwarded by Luis Flores/R4/USEP A/US on 05/15/0 I 11 :22 AM -----
Dan,
Luis Flores
04/25/01
09:03 AM
To: [e-mail]
cc: Sharon Thoms/R4/USEPA/US@EPA, Luis
Flores/R4/USEP A/US@EPA
Subject: Ecological Risk assessment
Based on the information I am receiving from Sharon (see below). A
literature review is not necessary.
EPA suggests that you either use the published benchmark of 128 mg/kg as a
protective level for ecological risk in sediments or collect site-specific
data to calculate site specific numbers in order to support the risk
assessment.
Please call me if you have any questions.
Thanks,
Luis
-----Forwarded by Luis Flores/R4/USEPA/US on 04/25/01 08:20 AM-----
Luis,
Sharon Thoms
To: Luis Flores/R4/USEP A/US@EPA
04/23/01
04:34PM
cc: Kevin Koporec/R4/USEPA/US@EPA
Subject: JCI proposal to review lead
literature
I have the Ross Metals site risk assessment. It has lots of other metals
besides lead, but lead levels are very high. They have some toxicity data
but maybe only three data points.
1 had received a report from Chris Ingersoll and Don MacDonald with
freshwater consensus value for lead developed for GLNPO ( Great Lakes
National Program Office in Chicago). Don MacDonald is using data from our
Region 4 sites. I sent him data for Sapp Battery. The report for GLNPO
includes a consensus based probably effect concentration (PEC) based on
over 20 different samples and with greater than 75 percent correct
classification as toxic. The PEC number was 128 mg/kg for lead. The
report also tabulates other sources of benchmarks for lead, which are all
in the same ball park as the 128.
file:///Untitled
5/15/200 I 1:05 PM
3 of3
• • Given the existence of EPA-funded studies to compile and evaluate toxicity
testing for lead and to develop benchmarks, I do not believe it is
profitable to have JC's consultant spend time compiling and reviewing
literature. I think they either need to take a published benchmark like
128 mg/kg as a protective level for ecological risk in sediments or they
need to do the site-specific data collection to support the risk
assessment.
Sharon
file:///Untitled
5/15/2001 1:05 PM
• • MONTGOMERY WATSON
May 14, 2001
Mr. Luis Flores
Remedial Project Manager
U.S. EPA Region 4
North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, GA 30303
Re: Hybrid Risk Assessment Approach
Dear Luis:
•
SUPERFUND SECTION
In our meeting held on April 23, 200 I, we discussed our desire to implement what
Dr. Michael Kierski called a hybrid risk assessment approach. This hybrid approach would
in essence be a middle ground between a Baseline Risk Assessment (BIRA) conducted
during a CERCLA Remedial Investigation and a Streamlined Risk Evaluation (SRE)
normally conducted as part of an Engineering Evaluation/Cost Analysis (EE/CA).
We are confident that this hybrid risk assessment will provide your agency with the level of
detail needed to make informed remedial action decisions as part of the EE/CA process.
And, as we pointed out at the meeting, by avoiding the need for additional field work this
year, it allows Johnson Controls Battery Group, Inc. (JCBGI) to immediately begin
implementing steps to address the existing contamination, preventing any recurrence of the
problem. Because budgets and resources are limited, however, JCBGI cannot
simultaneously undertake additional field work and initiate engineered solutions for the
Site. The company strongly believes it has documented the nature and extent of the
contamination. The alternatives to solve the problem are limited and fairly obvious.
Reliance upon well documented studies of similar sites is entirely appropriate in guiding
our assessment of ecologic risk at this Site and represents a much more productive
investment of time, money and resources.
The remainder of this letter details the intended scope of the hybrid risk assessment. In
addition, we have provided a revised schedule for developing the EE/CA and data tables
that will be used in the ecological risk assessment. Please note that these data tables are a
work in progress, which are being prepared for presentation in the EE/CA. We hope these
data tables will help your staff understand the nature and extent of the contamination prior
to the EE/CA submittal.
One Science Court
P.O. Box 5385
Madison, Wisconsin
53705-0385
Tel: [phone]
Fax: [phone]
Delivering Innovative Projects and Solutions Worldwide
• •
HYBRID RISK ASSESSMENT APPROACH AND SCOPE
Why conduct a hybrid risk assessment? A BlRA is not needed to identify the appropriate
corrective action at the Site. However, a SRE does not necessarily provide enough
documentation in itself to document that lead is the primary concern.
What would the hybrid risk assessment include?
I. Human Health Evaluation
⇒ Provide a qualitative exposure pathway analysis to identify potential exposure
pathways for humans (e.g., employees, recreational users, etc.).
⇒ Comparison to Region IX PRGs and background to identify chemicals of potential
concern for each complete exposure pathway
=> Comparisons to the PRGs by area ( and sub-area) and medium
⇒ This information will be used to provide a qualitative risk characterization to support
· the need for action in particular areas of site (i.e., Lead oxide unloading area, Basin
No. I) or no action (other areas of Site)
⇒ The data base will be used to show that most other contaminants above PRGs are co-
located with lead. This information will be used to justify using lead as the primary
indicator contaminant for evaluating remedial alternatives.
II. Ecological Risk Assessment -Conducted for areas affording ecological habitat on Site.
=> Provide Screening Level Ecological Risk Assessment (SLERA) to identify potential
problem areas. This SLERA would follow the approved Work Plan and include:
• Documentation from Site habitat assessment
• Initial problem formulation
, Evaluation of T &E species
, Development of hazard quotient calculations by area and medium
• Comparison of inorganic analyte concentrations to background concentrations.
Those analytes detected below background will be excluded as contaminants of
concern.
Mr. Luis Flores May 14. 2001 U.S. EPA Region 4
Page 2
• •
The SLERA will be used to identify areas on Site, which may pose a potential ecological
concern. The SLERA will demonstrate that lead is the primary contaminant of concern at
the Site. JCI is committed to eliminating Basin 1, and cleaning Basins 2 and 3, so no
further ecological evaluation of these potential habitats are proposed. A further evaluation
of the ecologic risk posed by lead in the off-Site wetland areas will be conducted via the
methods described below to determine the extent of remedial action needed in those areas.
No additional field work is contemplated:
⇒ Proposed Additional Analysis beyond the SLERA for wetland habitats.
• Select a range of applicable receptors that may utilize the wetland habitat and
have a relatively small home range. Receptors with small home ranges would be
considered most sensitive to the lead contamination, because of their duration of
exposure.
• Qualitative discussion of the appropriateness of each receptor for the wetland
areas. Certain receptors may be more appropriate then others because of their
habits.
• Use published NOAEL and LOAEL for lead from well-recognized studies and
sources such as Oak Ridge National Labs and other EPA regions, to estimate
toxicity to lead for each receptor (use body-weight scaling as necessary).
• Estimate the lead concentration that would be health protective for each receptor
based on NOAEL and LOAEL using simple models.
• Evaluate areas of lead contamination in the wetland above the receptor specific
remedial action objectives.
• Provide a recommendation for a lead concentration that 1s protective m the
wetland environment.
We have provided a conceptual approach in this letter. Once we have an agreement on the
approach, Dr. Kierski would be happy to travel to Atlanta to talk further about the details of
the hybrid risk assessment. Alternatively a teleconference may suffice.
SCHEDULE
As we stated during the meeting at your offices, our schedule is constrained by two sets of
factors. First, since JCBGI is committed to begin remedial work as soon as practical, we
have a need for expedited review of our proposed approach. We would like to get approval
of the hybrid risk assessment approach by May 25, 2001. Preparation of the hybrid risk
assessment proposed in this letter, and completion of the other portions of the EE/CA, will
take place in parallel as much as possible to expedite the preparation of the EE/CA.
However, some of the analysis required in the EE/CA hinges on the results of the hybrid
Mr. Luis Flores May 14, 2001 U.S. EPA Region 4
Page 3
• •
risk assessment. Taking into account all that needs to happen before a draft EE/CA can be
provided to your agency, we are requesting permission to submit the draft EE/CA on or
before July 30, 2001.
We look forward to your staffs comments on this approach. If you have any questions on
the approach you or your staff may contact Dr. Kierski directly at 608-231-4755 ext. 203.
Sincerely,
MONTGOMERY WATSON
1PIJJd;£.
Michael W. Kierski, Ph.D.
Supervising Environmental Toxicologist
Daniel W. Hall, PG
Project Manager
Enclosures: Table I -Wetland Area Sediment, Hazard Quotients Based on USEPA
Region IV Ecological SSLs
Table 2 -Wetland Area Soil, Hazard Quotients Based on USEPA Region IV
Ecological SSLs
Table 3 -Basin Area Sediment, Hazard Quotients Based on USEP A Region
IV Ecological SSLs
Table 4 -Basin Area Soil, Hazard Quotients Based on USEPA Region IV
Ecological SSLs
Table 5 -Wetland Area Surface Water, Hazard Quotients Based on USEPA
Region IV Ecological SSLs
Table 6 -Basin Area Surface Water, Hazard Quotients Based on USEPA
Region IV Ecological SSLs
cc: Timothy J. Lafond-JCBGI (with tables)
Debbie H. Hastings -JCBGI (with tables)
Jane Fowler -Quarles & Brady (with tables)
Mark Koczela -JCBGI (no attachments)
Glen Ponczak -JC! (no attachments)
Randy McE!veen -NCDENR (with tables)
MWK/mwk/ndj/DWH
N:Vobs\208\2326\0 l\wp\ltr\97 _fl ores Risk Letter.doc
2082326.01160101 MAD·\
Mr. Luis Flores May 14.2001 U.S. EPA Region 4
Page 4
• • Table 1. Wetland Area Sediment
Hazard Quotients Based on USEPA Region IV Ecological SSLs
WETLAND AREA
Sediment Overall Background Overall Wetland Max
Units ECO SSL Eco SSL Criterion
METALS
Fixed Lab
Aluminum mg/kg B NA 34397.1 54000.0
Arsenic mg/kg X 7.2 3.8 8.3
Barium mg/kg B NA 229.7 275.0
Beryllium mg/kg B NA 2.4 2.4
Cadmium mg/kg X 1.0 0.2 1.2
Calcium mg/kg B NA 1598.6 2090.0
Chromium, Total mg/kg X 52.3 67.2 72.2
Cobalt mg/kg B NA 15.4 19.7
Copper mg/kg X 18.7 57.7 68.3
Iron mg/kg B NA 36214.3 67800.0
Lead mg/kg X 30.2 38.7 650.0
Magnesium mg/kg B NA 4634.9 5070.0
Manganese mg/kg B NA 449.3 3240.0
Mercury mg/kg X 0.1 0.03 0.14
Nickel mg/kg X 15.9 22.5 25.6
Potassium mg/kg B NA 3330.6 4560.0
Selenium mg/kg B NA 1.8 3.0
Silver mg/kg ~ iE .. ;_. 2.0 0.2 1 .1
Sodium mg/kg ' B,Z NA 93.9 76.9
Thallium mg/kg ~z ~,.-~ , .,'/j_ _ _:, ~~ <-',;!-~1~ NA 1.4 1.2
Vanadium mg/kg B NA 107.3 NA
Zinc mg/kg ,., ,:;;,. ., .. , 124.0 94.9 115.0 . , .... -
PESTICIDES
ODE ug/kg X 3.3 NA 5.2
voes
Acetone ug/kg A NA NA 46 .
Carbon disulfide ug/kg A NA NA 120
·Methyl ethyl ketone (2-Butanc ug/kg A NA NA 7.0
svocs
X = Detected above the Eco SSL. Would be carried into a Baseline ERA.
B = Detected above the background criterion, but does not have an Eco SSL. Would be carried into a Baseline ERA.
A = Detected and has no Eco SSL. Would be carried into a Baseline ERA.
B = Nutrient metal. Would not be carried into a Baseline ERA.
tY:~:Q.e\li}::_t~9:~$9'felba_cJ5gr9iijc:!~tjQt"n9Httiia;E;i:9'.,§9_t,'{:,\/j_£Lllgfr:,°e;t~beC§_lli.e'.BJi6!oia@13~~j3lii11(sRA~:':o<C·"~2;c:zzJ'•~,•\1•';-,,~
rz;mN6~~Wa156ve)tfs1'c1<grcitffi'd['-'cW<fLlli1frioti~fc'a/riecl,ifito'ia1 Ba°i:l';line'ERA'?Si. . .,.;:.= ·-'"'
NA = Not available
HQ = Hazard quotient (i.e., Sediment concentration / Eco SSL)
Eco SSL= USEPA Region IV Ecological Sediment Screening Value
Overall Wetland HQ Wetland 1 Max
NA 54000.0
1.15 8.3
NA 275
NA 2.4
1.20 1.2
NA 2090
1.38 72.2
NA 19.7
3.65 68.3
NA 67800.0
21.52 650.0
NA 5070.0
NA 1550.0
1.08 0.14
1.61 25.6
NA 4560
NA 3.0
0.55 1 .1
NA NA
NA NA
NA 127
0.93 115.0
1.58 5.2
NA 46
NA 120
NA 7
Wetland 1 HQ Wetland 213 Max
NA 38300.0
1.15 7.6
NA 238
NA 2
1.20 0.8
NA 1840
1.38 45.2
NA 13.8
3.65 54.8
NA 53600.0
21.52 130.0
NA 3920.0
NA 3240.0
1.08 0.11
1.61 16.5
NA 3010
NA 2.6
0.55 1
NA 76.9
NA 1.2
NA 94.5
0.93 115.0
1.58 NA
NA 18
NA 100
NA NA
Background criterion = 2 times the average concentration in the background samples. For analytes not detected in background samples, the criterion represents the average of the reporting limits.
DRAFT
JCF/MWKINEC
N:\208\2326\01\statsOutput\ECOHQsByArea.xls <Wetland Area Eco -Sed>
Wetland 213 HQ No. Exceedances
Backgr. EcoSSL
NA 6 NA
1.05 3 2
NA 2 NA
NA 1 NA
0.80 7 1
NA 2 NA
0.86 1 2
NA 1 NA
2.93 1 11
NA 8 NA
4.30 51 53
NA 1 NA
NA 7 NA
0.85 9 1
1.04 2 7
NA 1 NA
NA 2 NA
0.50 2 0
NA 0 NA
NA 0 NA
NA 1 NA
0.93 4 0
NA ~IA 1
NA NA NA
NA NA NA
NA NA NA
• • Table 2. Wetland Area Soil
Hazard Quotients Based on USEPA Region IV Ecological SSLs
WETLAND AREA
Soil Overall Eco SSL Background Overall Wetland Max
Units ECO SSL Criterion
METALS
Fixed Lab
Aluminum mg/kg ~~~{.\}\!,'"~~ . -· -· . --~ --~ 50 38360.0 30300
Arsenic mg/kg [:~-~.f~WG~1~.P:ii:~~ 10 3.8 NA
Barium mg/kg ~B~~~z_G~J"S:-f:.:;~jf~ 165 243.9 NA
Beryllium mg/kg 1 .1 2.7 NA
Cadmium mg/kg -~;:,~_=f.."f}_';;j}1:l:Ii__1YJ?.-;~~y:)i•~~~ 1.6 0.08 0.52
Chromium, Total mg/kg 1s=-"'· ~q -;;F'1tC·,o~;;,;~·.,_ •-~ 0.4 78.8 NA
Cobalt mg/kg
~~ ... ~2t-., ·'"
20 24.6 NA
Copper mg/kg ~x~ 40 80.6 40.3
Iron mg/kg ~~~lifi!lmf'X'~~ : .. -.~~""' ~--::~~ .· :~ 200 48400.0 26600
Lead mg/kg X 50 66.7 68
Manganese mg/kg -x~ •-"" . . 100 1065.2 460
Mercury mg/kg .:.' -·-.-:,. ---~~ 0.1 0.03 0.1
Nickel mg/kg :~~~2Z.~~k~¾i~ 30 26.6 16.9
Selenium mg/kg •;n;.;...~ .Ji~~C~"~~ ~ ."?'::. . ~--;.;;;;;,,, .,.:A = A 0.81 1.8 NA
Silver mg/kg 2 0.13 NA
Vanadium mg/kg ~:?£:~~-"~C~~-,;~?7i 2 119.9 NA
Zinc mg/kg ~x~~ ---~ 50 79.1 61.8
PESTICIDES
DDE ug/kg ~~¥~-:i.c·:;:~M? ~-:~_:3 2.5 NA NA
voes .
Acetone ug/kg ~ff;.S_~:iflfC~~:~X~ NA NA NA
Carbon disulfide ug/kg ~~1:~?·~~C~i?-:"-~~ NA NA NA
Methyl ethyl ketone (2-Butanc 1 ug/kg -----. NA NA NA
svocs
X = Detected above the Eco SSL. Would be carried into a Baseline ERA.
B = Detected above the background criterion, but does not have an Eco SSL. Would be carried into a Baseline ERA.
A= Detected and has no Eco SSL. Would be carried into a Baseline ERA.
[X@..;0~te}t\RJ[/j_bpY2\tn~]Eg>iS!,it'\15'.ytjnj5tfaoql(i1ti§,§far]:fu'i5drC:rit~-rionji.y9'.ut1llnotlo_e@fii~p!ifj!J5IijjB*'eiir:@Ef,½c~
B = Nutrient metal. Would not be carried into a Baseline ERA.
fc:!gjNot'"iieteded,'JiWould•not115e'!&frnediinto/a!Baselirie;ERA§s;,>~,~c:,14-lA ~ ~E~-~,r,,--··~..,~-4"' ~.,,-;:.;:.,---...,.."""' --~,t,' "'.r..:'_.r,:-~ lli'.;"i;,D~-~~~teg;A~a,,§cl<groynd;'j5Ui:r\"ot,_t.6e E.9.9J9~L.'},_Wsti1Lg,_~of;b";,P_~tr=l~~-t6;cJlBa_seline1ERA'~ ar';jl:-/;•r,<c.;'b;'°STi'"'"-~'%•:tj
tz(;e)Not;aetecte"a1ab"ov~1backgrom@'i~W&ilii;not1tj:e!~ni~1Tfito]ll!B~irmr~
NA = Not available
HQ = Hazard quotient (i.e., Soil concentration / Eco SSL)
Eco SSL= USEPA Region IV Ecological Soil Screening Value
Overall Wetland HQ Wetland 1
606.00 12900
NA NA
NA NA
NA NA
0.33 NA
NA NA
NA NA
1.01 9.8
133.00 14100
1.36 51
4.60 439
1.00 0.05
0.56 7.1
NA NA
NA NA
NA NA
1.24 33.1
NA NA
NA NA
NA NA
NA NA
Max Wetland 1 HQ Wetland 2/3 Max
258.00 30300
NA NA
NA NA
NA NA
NA 0.52
NA NA
NA NA
0.25 40.3
70.50 26600
1.02 68
4.39 460
0.50 0.1
0.24 _,16.9
NA NA
NA NA
NA NA
0.66 61.8
NA NA
NA NA
NA "NA
NA NA
Background criterion = 2 times the average concentration in the background samples. For analytes not detected in background samples, the criterion represents the average of the reporting-limits.
DRAFT
JCF/MWK/NEC
N:\208\2326\0 I \statsOutput\ECOHQsByArea.xls <Wetland Area Eco -Soil>
Wetland 2/3 HQ No. Exceedances
Backgr. EcoSSL
606.00 0 2
NA 0 0
NA 0 0
NA 0 0
0.33 1 0
NA 0 0
NA 0 0
1.01 0 1
133.00 0 2
1.36 1 2
4.60 0 2
1.00 2 0
0.56 0 0
NA 0 0
NA 0 0
NA 0 0
1.24 0 1
NA NA 0
NA NA NA
NA NA NA
NA NA NA
DSAIT
JCFIMWKiNEC
• Table 3. Basin Area Sediment • Hazard Quotients Based on USEPA Region IV Ecological SSLs
BASIN AREA
Sediments Overall Eco SSL Background Overall Basin Max
Units ECO SSL Criterion
METALS-Fixed lab
Aluminum mglkg ,~}-_,-;::.!~Zi 7'>C•').'-;'_i-,:, NA 34397.1 24900.0
Antimonv mglkg t".i?, ;;..~&"fiii~'ZL:?~.;;:;.~ 12.0 0.9 0.7
Arsenic mglkg ~~~:1!&41:'JZ-.;;.~ft~:"'1 7.24 3.8 2.8
Barium mg/kg f .. :,"?s--'§Zffi?~ZS-t:;.~~ NA 229.7 133.0
Beryllium mglkg ".';: &,.'1-.ffu'v:;;{•Z~,T'±.,?kK NA 2.4 1.2
Cadmium mglkg X 1.0 0.17 1.3
Galcium mglkg B NA 1598.6 2110.0
Chromium, Total mglkg c..w..::~x~~~"l.'§ 52.3 67.2 59.7
Cobalt mglkc >77~~.':d;-l{tzjZ ~~·.::-~:> NA 15.4 14.0
Copper mg/kg Z''1$],:,.:;.,.~'.X~"':'~ 18,7 57.7 38.3
Iron mgikg B NA 36214.3 37600.0
Lead mglkg X 30.2 38.7 1600.0
Magnesium mglkg $:;..:_. -~~z~:.--t:R:r..,.:r. NA 4634.9 2770.0
Mantlanese mglkg B NA 449.3 828.0
Mercurv mg/ko C ~-~i._,;'::;i-:.Z,Y,£ ·-k::.::;.;,:)¥, 0.13 0.03 0.07
Nickel mg/kg ~¥~!:t'X~4ili: 15.9 22.5 21.6
Potassium mglkg '-i;.";,i'.!!"~5:...JjZ~ .;.'i'~::1 NA 3330.6 2660.0
Selenium mglkg B NA 1.8 1.8
Silver mglkg :~ .. : :;---:..;-:··;:,,y·-.-. ,..~,ic.:.: 20 0.24 12
Sodium mglkg .,::.z_,;;.";ffi._ifili:'Z~ t~,4--:.u-r;t';. NA 93.9 5,\ 2
Vanadium mg/kg L~-::£:5"1¥8?rZZ:!.Y1fo9:'-¾.Fi NA 107.3 99.5
Zinc mglkg X 124.0 94.9 158.0
PESTICIDES
Aldrin ,glkg A NA NA 1.6
alpha Chlordane ,glkg ~crcn•-&1;;.:; 1.7 NA 1.6
alpha BHC ug/kg A NA NA 1.7
alpha Endosulfan ,glkg A NA NA 5.6
beta Endosu!fan ,glkg A NA NA , ..
DOE ,glkg ON:"· ::.~dC~·./i\.li:::5 3.3 NA 2.2
DDT ,glkg ::r:~c~~ 3.3 NA 12
Oieldrin ,glkg ~-~::~C'ti¢~~~,.Z.3L4 3.3 NA 2.3
Endosulfan sulfate ug/kg A NA NA 11.0
Endrin aldehvde ,glkg A NA NA 2.9
Endrin ketone ,glkg A NA NA 8.6
gamma-Chlordane ,glkg X 1.7 NA 2.6
Heptachlor epo)(ide ,glk, A NA NA 2.0
MethO)(VChlor ug/kg A NA NA 23.0
e
SVOCS
Anthracene ,glkg ·.·"t: :,..,.._..,,__'wc,..,.:;,;--_u-~ 330.0 NA 90.0
Benznl a )anthracene ,glkg X 330.0 NA 380.0
Benzo(a)l)Vrene ,glkg X 330.0 NA 660.0
Benzo(b )Huoranthene ,glkg A NA NA 990.0
Benzo( n,h,i)perylene ,glkg A NA NA 1000.0
BenZoik)fluoranthene ,glkg A NA NA 1200.0
bis(2-ethvlhe)(yl) Phthatate ,glkg X 182.0 NA 2200
Gartlazole ,glkg A NA NA 140.0
Ch""'ene ,gikg X 330.0 NA 990.0
Dibenz(a ,h )anthracene ,glkg :,.;;r,>-:,:~C¾'\ll'~ 330.0 NA 210
Fluoranthene ,glkg :..,~~-~*C~ ":!~ 330.0 NA 1400.0
lndeno( 1.2,3-c,d)Pyrene ,glkg A NA NA 1100.0
Phenanthrene ,glkg X 330.0 NA 390.0
Pyrene ,glko f".:?.U~C~~~ ,1,-:,."'i;).½",;: 330.0 NA 990.0
voes
Acetone ,glkg A NA NA '5
carbon disulfide ,glkg A NA NA 26
Methvl ethvl ketone (2-Butan ,glkg A NA NA 3.0
X = Detected above the Eco SSL. Would be carried into a Baseline ERA.
B = Detected above the background criterion, but does not have an Eco SSL. Would be carried into a Baseline ERA.
A= Detected and has no Eco SSL. Would be carried into a Baseline ERA.
)_( = Detected above the Eco $$~but not above ba~nd Qiteriori!'iWould not be carried Into a ~ERA.9
B = Nutrient metal. Would not be carried in_to a Baseline ERA.
1c~ No..t,~e~.;.~.the -~~~-~ .. 1~_ould -~ be 9l11~J!i-~ a~'.~~~~--_ ==•·=-== ,Y -, Detected above background~ but ll9t the E':(' SSL, ,Would not be earned mto a Baseline E~::t;::. 0 ~¢•'fi-:-:!
Z::. Not detected'amcicground:1,woorai'iot be iarried rnto"a Baselil1fiE~
NA = Not available
HQ= Hazard quotient (i.e .. Sediment concentration I Eco SSL)
Eco SSL= USEPA Region IV Ecological Sediment Screening Value
Overall Basin HQ Basin 1 Max
NA 24100
0.06 NA
0.39 1.4
NA 83.8
NA 0.88
1.30 0.7
NA 198
1.14 59.7
NA 9.3
2.05 38.3
NA 37600
52.98 1600
NA 2190
NA 293
0,54 0.06
1.36 21.6
NA 2520
NA 1.1
0.60 0.82
NA NA
NA 65.9
1.27 158
NA NA
0.94 NA
NA NA
NA 5.6
NA NA
0.67 NA
3.64 12
0.70 NA
NA 3.4
NA NA
NA NA
1.53 2.5
NA NA
NA NA
0.27 NA
1.15 150
2.00 NA
NA 260
NA 160
NA NA
12.09 2200
NA 100
3.00 300
0.64 NA
4,24 520
NA NA
1.18 220
3.00 '90
NA ,5
NA 19
NA 3
Basin 1 HQ Basin 2/3 Max Basin 213 HQ
NA 24900.00 NA
NA 0.70 0.06
0.19 2.80 0.39
NA 133.00 NA
NA 1.20 NA
0.70 1.30 1.30
NA 2110.00 NA
1.14 37.80 0.72
NA 14.00 NA
2.05 38.20 2.04
NA 35500.00 NA
52.98 184.00 6.09
NA 2770.00 NA
NA 828.00 NA
0.46 0.07 0,5,\
1.36 12.90 0.81
NA 2660.00 NA
NA 1.80 NA
0.41 120 0.60
NA 54.20 NA
NA 99.50 NA
1.27 152.00 1,23
NA 1.60 NA
NA 1.60 0.94
NA 1.70 NA
NA 4.40 NA
NA 4.40 NA
NA 2.20 0.67
3.64 NA NA
NA 2.30 0,70
NA 11.00 NA
NA 2.90 NA
NA 8.60 NA
1.47 260 1.53
NA 2.00 NA
NA 23.00 NA
NA 90.00 0.27
0.45 380.00 1.15
NA 660.00 2.00
NA 990.00 NA
NA 1000.00 NA
NA 1200.00 NA
12.09 910.00 5.00
NA 140.00 NA
0.91 990.00 3.00
NA 210.00 0.64
1.58 1400.00 4.24
NA 1100.00 NA
0.67 390.00 1.18
1.48 990.00 3.00
NA 6.00 NA
NA 26.00 NA
NA NA NA
Background criterion= 2 times the average concentration in the background samples. For analytes not detected in background samples, the criterion represents the average of the reporting limits.
No. Exceedances
Backgr. EcoSSL
0 NA
0 0
0 0
0 NA
0 NA
' 1
1 NA
0 1
0 NA
0 ' 1 NA
21 24
0 NA
1 NA
' 0
0 1
0 NA
1 NA
' 0
0 NA
0 NA
' 2
NA NA
NA 0
NA NA
NA NA
NA NA
NA 0
NA 0
NA 0
NA NA
NA NA
NA NA
NA 2
NA NA
NA NA
NA 0
NA 1
NA 2
NA NA
NA NA
NA NA
NA 3
NA NA
NA 2
NA 0
NA 0
NA NA
NA 2
NA 0
NA NA
NA NA
NA NA
DRAFT
JCFlM\VK·-:,/EC
•
N:1208'2J26\01\s1J.tsOwpu1IECOHQsByArea~ts <Basin Arc.:'! Eco. Soil>
• Table 4. Basin Area Soil
Hazard Quotients Based on USEPA Region IV Ecological SSLs
BASIN AREA
Soil Background Overall Basin Max I Overall Basin HQ I Basin 1 Max
Units ECO SSL Eco SSL Criterion
METALS-Fixed Lab
Aluminum mg/kg er~'.!!'--Xl!ii!!ll!l,El:!I<'.,. 50 38360.D 35000
Antimony mg/kg lS~~Zllt-S:WP-~"-~"!t 3.5 0.70 NA
Cadmium mn,og _:~:::_ ':":J.2.: ._:.',-_\tYr:f.;t .:': :t:.T":J 1.6 0.08 1
Chromium, Total mg/kg ~,;~~l~X~~~ 0.4 78.8 34
Cobalt mg/kg ·if~~.r~.32~'£:'}.2!~':J 20 24.6 NA
Copper mg/kg ~~!~~x~,.;;~;:~ 40 80.64 76.5
Iron mg/kg X 200 48400.0 50000
Lead mg/kg X 50 66.7 2800
Manganese mg/kg -.,,_x 1Jc~S?tl'ifi 100 1065.2 911
Mercury mg/kg ~y;~-"-,"J_f"·t;· ;.-;;JEW;".;;1';;?,;i'·'-1 '.:t: c'...J 0.1 0.03 0.07
Nickel mg/kg ~f~~~Z~~k):: 30 26.6 17.1
Selenium mg/kg ::~:.~'.f ,;.;,:-vz~~·:ftx:::• 0.81 1.8 NA
Silver mg/kg f:" ....... ~~~~-~~zp.:;,,~:~:.::i 2 0.13 NA
Zinc mg/kn X 50 79.1 188
PESTICIDES
Aldrin ug/kQ ;:;:.::;.,:Z.;-E-:W.".::.CTI;.,;'1:.-,:'::~:"'J::~ 2.5000 NA NA
alpha Chlordane ug/kg ~~..T.l:.£Q77i;C:~~~;r,,:c-~ NA NA NA
alpha Endosu!fan ug/kg r:-:c~~":u;;c--:.:ffA0;.:;:et.itYi"J. NA NA NA
beta Endosulfan ug/ko •:J&..~~C'l'H~ .. '"ffeJ:;,,; NA NA NA
ODE ug/kg ??'~'t?!:%C~~wi'tt:'~:,P3 2.5000 NA NA
DDT ug/kg ~,;?,~~Cm?M<~5 2.5000 NA NA
Die!drin un~n ::i "'7;;i;,.,r~.c~~~"'-~ 0.5000 NA NA
Endosulfan sulfate ug/kg r;::::i:::'1·:;;t;;®'C~"",,;:~"'.:"'~,;,.➔ NA NA NA
gamma-Chlordane ug/kg ,._ ,.;~..:.~·rn;,QC~'~ .. =-~~ NA NA NA
Methoxychlor ug/kg ,..,. :.__"'.'<::a::,-; ,~·~C~~~~ NA NA NA
svocs
Anthracene ug/kg X 100.0 NA 150
Benzo(a)anth_racene ug/kg A NA NA 1300
Benzo(a)pyrene ug/kg X 100.0 NA 2300
Benzo(b)fluoranthene ug/kg A NA NA 3700
Benzo(g, h, i)perylene ug/kg A NA NA 2000
Benzo(k)fluoranthene ug/kg A NA NA -3500
bis(2-ethylhexyl) Phlhalate ug/kg A NA NA 7100
Carbazole ug/kg A NA NA 610
Chrysene ug/kg A NA NA 3300
Dibenz(a,h)anthracene ug/ko A NA NA 850
Fluoranthene ug/kg D 100.0 NA 5300
Fluorene uQ/ko A NA NA 55
lndeno(1,2,3-c,d)Pyrene ug/kg A NA NA 2200
Phenanthrene un/kn X 100.0 NA 1900
Phenol ug/kg X 50.0 NA 180
Pvrene ug/kg X 100.0 NA 4000
voes
Acetone unlkn ~~.1i~ii?f"3C~~~tP!~ NA NA NA
Carbon disulfide ug/kg =:...::: ... ~-;,-:,-~~c·i-~--~ NA NA NA
Methvl ethvl ketone (2~Butano ug/kg ~-~-~.;~:i:c~-:;,_,~r.'::-; NA NA NA
X = Detected above the Eco SSL. Would be carried into a Baseline ERA.
B = Detected above the background criterion, but does not have an Eco SSL. Would be carried into a Baseline ERA.
A= Detected and has no Eco SSL. Would be carried into a Baseline ERA.
•X.=:Detectecl aoove the:Eco·SSL~t>utnot'above ~nd criterioo!{Would·not l5e carried·into a.Baseline ERA:fzj
B = Nutrient metal. Would not be carried into a Baseline ERA
~C~=:=:Not cletectectiWook:1.not be_tarrieCfin1o a Baseline ERks~.~: .. f;-,/
D =· ot detectea ·aoo"\fe!Eoo I.: .Would'n·ot oo·canietMrito a Ba · ine ERA]
j'V:.;..~~DElteciedra_bove backgrotiOcl.'but not the ECO SSL:-::-.1/,/□-Uld-nOt tie C8rriEia int□-.a~Baselin8·ERA.,,. ~'":.. -~; : n;:.. -::.) ·'•G::J
:~tdetoct~~~na::.twould!nofoe ~'ffil~.f~ineERA~~zj.!. · -;>
NA= Nol available
HQ= Hazard quotient (i.e .. Soil concentration/ Eco SSL)
Eco SSL= USEPA Region IV Ecological Soil Screening Value
700.00 22800
NA NA
0.63 0.83
85.00 32.9
NA NA
1.91 39
250.00 50000
56.00 2800
9.11 911
0.70 0.07
0.57 17.1
NA NA
NA NA
3.76 121
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
1.50 150.0
NA 1300.0
23.00 2300.0
NA 3700
NA 2000.0
NA 3500
NA NA
NA 610
NA 3300.0
NA 850.0
53.00 5300.0
NA 55.0
NA 2200
19.00 1900.0
3.60 NA
40.00 4000.0
NA NA
NA NA
NA NA
Basin 1 HQ Basin 2/3 Max I Basin 2/3 HQ
456.00 35000 700.00
NA NA NA
0.52 1 0.63
82.25 34 85.00
NA NA NA
0.98 76.5 1.91
250.00 37800 189.00
56.00 2200 44.00
9.11 781 7.81
0.70 0.07 0.70
0.57 15.2 0.51
NA NA NA
NA NA NA
2.42 188 3.76
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
1.50 NA NA
NA 460.0 NA
23.00 860.0 8.60
NA 1500 NA
NA 910 NA
NA 1500 NA
NA 7100 NA
NA 190 NA
NA 1300.0 NA
NA 340.0 NA
53.00 1700 17.00
NA NA NA
NA 980 NA
19.00 550.0 5.50
NA 180.0 3.60
40.00 1300 13.00
NA NA NA
NA NA NA
NA NA NA
Background criterion = 2 times the average concentration in the background samples. For analytes not detected in background samples. the criterion represents the average of the reporting limits.
No. Exceedances
Backgr. EcoSSL
0 20
0 0
14 0
0 14
0 0
0 2
1 20
40 63
0 20
5 0
0 0
0 0
0 0
7 8
NA 0
NA NA
NA NA
NA NA
NA 0
NA 0
NA 0
NA NA
NA NA
NA NA
NA 1
NA NA
NA 3
NA" NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA 1
NA NA
NA NA
NA 3
NA 1
NA 3
NA NA
NA NA
NA NA
• • Table 5. Wetland Area Surface Water
Hazard Quotients Based on USEPA Region IV Ecological SSLs
SURFACE WATER
Total Metals Background Wetland 1 Max Wetland 1 Max HQ Wetland 213 Max Wetland 2/3 Max HQ No. Exceedances Dissolved Metals
Metals Units REG IV ECO SSL Eco SSL Criterion Backgr. EcoSSL REG IV ECO SSL
Aluminum ,g!L ~~-m~z~rn NA 261.3 NA NA 171 NA 0 0 ~$~2[£i~l]
Cadmium ,g/L T;t"'?;~Z~~•-:.r;:1 0.6600 0.6 NA NA NA NA 0 0 ~~~•-z,Yr:Z:~-:
Chromium, Total uglL ~~i'£Z~Z:,l;.:;.3; 11.0000 5.0 NA NA NA NA 0 0 ~~~:tZ.9-~?f~
Copper ,g!L 2:~~Z~\t£.il 6.5400 4.4 NA NA NA NA 0 0 l~~.:::,;:z~...:..r~}::;
lro, ,g/L ~~X~i':£~ 1000 2492.9 1880.0 1.88 2200.0 2.20 0 2 -;~;x~:J~V:
Lead uglL ~X~::]"~ 1.3200 2.4 2.0 1.52 NA NA 0 1 :ta,:~z-~~~~
)sfanganese ,g/L '[r~Z~~~ NA 563.5 94.0 NA 138.0 NA 0 0 ~j;"..,?~Z~~~~
Mercury sg/L ;~~1f.Z~:~JU 0.0120 0.1 0.00027 0.02 0.00061 0.05 0 0 ~~Z-~~~
:-.'ickel ,g/L iultfWt~S'Z~t~irl 87.7100 1.3 NA NA NA NA 0 0 F~Z~E"~~
Zinc ,g/L ~~ffl!Z~~~~ 58.9100 9.2 NA NA NA NA 0 0 ~-sitfJi>~X-~~~~-
tz,..,;:N6tdetecteo aoove·tia~uld:ri6t'be;"caniecirfnto~a:"sa~nTERA1'{t~-:
NA = Not available
HQ= Hazard quotient (i.e., Surface water concentration/ Eco SSL)
Eco SSL= USEPA Region 1V Ecological Freshwater Surface Water Screening Value
Background criterion = 2 times the average concentration in the background samples. For analytes not detected in background samples, the criterion represents the average of the reporting limits.
DR.-\FT
JCFl~WK.:":-.'EC
N:\ZOSIZJZ6\0l\statsOutpu11ECOHQsByArea.xl~ <Wetland Area Eco Surface Wati:T :>
Background Wetland 1 Max Wetland 1 Max HQ Wetland 2/3 Max Wetland 2/3 HQ No. Exceedances
Criterion Backgr. EcoSSL
56.8 NA NA NA NA 0 0
0.6 NA NA NA NA 0 0
0.5 NA NA NA NA 0 0
1.4 NA NA NA NA 0 0
1735.8 1470.0000 1.4 7 1710.0000 1.71 0 2
1.7 NA NA 0.7000 0.53 0 0
565.7 93.4000 NA 139.0000 NA 0 0
0.1 NA NA 0.0007 0.06 0 0
1.3 NA NA NA NA 0 0
31.5 NA NA 42.8000 0.73 1 0
• Table 6. Basin Area Surface Water • Hazard Quotients Based on USEPA Region IV Ecological SSLs
SURFACE WATER
Total Metals Background Basin 1 Max Basin 1 Max HQ Basin 2/3 Max Basin 213 Max HQ
Metals Units REG IV ECO SSL Eco SSL Criterion
Aluminum "'' 8 NA 261.3 480.0000 NA 2070 NA
Cadmium ug/L ~~z:~-~~ 0.6600 0.6 NA NA NA NA
Chromium. Total "'' ~;~~~z -'X~5.&: 11.0000 5.0 NA NA 3.9 0.35
c.,,,,o "'' ~~:::z~:.r,qy_,~ 6.5400 4.4 NA NA NA NA
,roo "'' :~x== 1000 2492.9 1710.0 1.71 1790.0 1.79
Cud ug!L X 1.3200 2.4 460.0 348.48 79.9 60.53
Manganese "'" .:~~ZL--''"l,~~ NA 563.5 527.0 NA 39.0 NA
~!ercwy "'' ~x~~ 0.0120 0.1 0.0048 0.40 0.00691 0.58
:-.'iclel ug•L >-<:,-~:.,r.;; ·ve-_:;,.,,_,:_-_;: 87.7100 1.3 NA NA 1.4 0.02
Zinc ug-'L X 58.9100 9.2 61.0000 1.04 125 2.12
X = Detected above the Eco SSL. Would be carried into a Baseline ERA.
B = Detected above the background criterion, but does not have an Eco SSL. Wou!d be carried into a Baseline ERA
1X1= Detected above the.Eco ss~~~but nofabove back.grotind'criterion:-';.WOUkfoot becanioo•into a Baseline ERA:${{-J}@/&f.·-"""i'·~-;.tyt§:AfP\--...; :.;:'1£M;wm! ~eo 8bo~,backgro~:.b~~SSC/, W~}:L~~-~..Jrlt_?~a ~s~liniiERA:i½5I_;· ;_· ..:.~ · .. q Z = Not detected'above backgrourii::l'.";Would not be carried into a Baseline ERA::.1ft} • ..: ,,;;J
NA = Not available
HQ = Hazard quotient (i.e., Surtace water concentration I Eco SSL}
Eco SSL= USEPA Region IV Ecological Freshwater Surface Water Screening Value
No. Exceedances Dissolved Metals
Backgr. EcoSSL REG IV ECO SSL
4 NA ;.-,~~zr:;r.:3-.:;ir.:•~
0 0 ;~~~_f Z~~
0 0 ;:.:T4-~kZ'i1,'2_~~:i
0 0 ~'.;.,;_;.z7_,.z~:;--~-a·j
0 3 ~:-;,-~~Z-";;,.=3r;~J
4 4 X
0 NA i%!'.:Jit'.4Y~Z~~).,,r,
0 4 ~~~z~~~~
1 0 I·· · :.'it:C:Y;'-"£::i,"".'-''~
2 2 X
Background criterion= 2 times the average concentration in the background samples. For analytes not detected in background samples, the criterion represents the average of the reporting limits.
DRAFT
JCFIMWK/NEC
N:\2081.2326\01\statsOutput\ECOHQsByArea.xls <Basin Area Eco. Surface Water>
Background
Criterion
56.8
0.6
0.5
1.4
1735.8
1.7
565.7
0.1
1.3
31.5
Basin 1 Max Basin 1 Max HQ Basin 2/3 Max Basin 2/3 HQ No. Exceedances
Backgr. EcoSSL
NA NA NA NA 0 NA
NA NA NA NA 0 0
NA NA NA NA 0 0
NA NA NA NA 0 0
236.0000 0.24 1710.0000 1.71 0 0
410.0000 310.61 14.6000 11.06 3 3
532.0000 NA 24.0000 NA 0 NA
0.0012 0.10 0.0016 0.13 0 0
1.8000 0.02 NA NA 1 0
61.2000 1.04 118.0000 2.00 2 2
• • MONTGOMERY WATSON
April 18, 2001
Mr. Luis Flores £
Remedial Project Manager
U.S. EPA Region 4
' [/,
North Site Management Branch
61 Forsyth Street, S. W.
APR I 9 200/
Atlanta, GA 30303
Re: Meeting of April 23, 2001
Dear Luis:
TIO
Enclosed are preliminary project maps for the Winston-Salem project and data tables for
your review prior to the meeting on April 23. I also have included a suggested agenda for
the meeting, below.
The three maps enclosed include:
• Drawing FI -Lead Concentrations in Soils
• Drawing F2 -Lead Concentrations in Soils
• Drawing F3 -Lead Concentrations in Site-wide Sediments
• Drawing F9 -South Wetlands Arca
The enclosed maps plot the soil and sediment sampling locations and concentrations for
lead only, including the mobile and fixed laboratory results. We are in the process of
evaluating the need for compiling maps depicting the results for other constituents, but
these will not be available before our meeting next week.
The maps are color coded to aid in your review. A red result indicates an exceedance of the
lead screening level at a sampling location. A green result indicates the sample result is
less than the screening level. The distribution of cxcecdances/non-exceedances of
screening levels around the plant, in the basins area, and in the few wetland area soil
samples appear to confirm the validity of our conceptual site model: most soil excecdances
are on the plant property. As we suspected, lead is the primary chemical of concern at this
Site and future actions at the Site will be based primarily on that conclusion.
The difference between Drawings F 1 and F2 is reflected in the designations "IND" and
"ECO" in specified areas on the maps. In our review of the data values in the area
surrounding the stonnwater basins, we have found it useful to compare the data to
ecological screening levels as well as industrial values. The labels "IND" and "ECO"
reflect these designations. ·-Thus, for instance, Drawing F 1 compares the lead
concentrations in soil in the plant area to an industrial screening level of 750 mg/kg, but
compares the lead found in soils in the basins and wetland areas to an ecological screening
level of 50 mg/kg. In contrast, Drawing F2 applies the indL1strial screening level for lead in
One Science Court
P.O. Box 5385
Madison, \/1.fisconsin
53705-0385
Tel: [phone]
Fax: [phone]
Serving·the World's Environmental Needs --
•
soil (750 mg/kg) to the basins area. The boundaries between the three areas are the fence
line (between the plant and basins areas) and the property line (between the basins and
wet land areas).
We believe that both sets of standards are potentially applicable to the basins area.
Specifically, while ecological screening levels have potential applicability during any risk
assessment phase of work, any remediation or upgrade work will, of necessity, treat the
basins as part of an operating industrial facility. This is among the topics we would like to
discuss with your staff on Monday.
Because there is no industrial screening value for sediment, Drawing F3 compares the
concentrations of lead found in sediment to the ecological screening value of 30.2 mg/kg.
This screening level was applied wherever sediment samples were collected, including the
unnamed creeks, wetlands areas and the basins.
Drawing F9 illustrates the contours of the lead concentrations in sediment in the south
wetlands area, downgradient of sedimentation basin #1. The map depicts isocontours of
200, 400, and 600 mg/kg for lead. In contrast, in the northern weilands below
sedimentation basins #2 and #3, all lead concentrations in sediment were below 100 mg/kg,
with exception of one location, SB22B, which was 130 mg/kg.
The drawings do not include a comparison to background values which, for lead in soil and
sediment, are above their respective ecologic screening levels of 50 mg/kg and 30.2 mg/kg.
Applying background will reduce the total number of locations that exceed either a
screening level or background.
The attached tables provide information about the number of exceedances of constituents in
specific areas of the Site. Tables I through 4 list the number of samples in each area of the
Site that exceed their respective SSLs and/or calculated background concentraiions for soil
and sediment. Tables 5 and 6 depict the same information on a site-wide basis for surface
water and groundwater. The tables also address (in the notes; "Obser,ations from
Database Output") the extent of co-location of other chemicals with lead. We will bring to
the meeting a summary of the maximum concentration of each constituent in each media.
As noted above, lead appears to predominate in all areas and all media.
Given these results, Johnson Controls Battery Group, Inc. would like to begin discussions
with you and your staff on the best approach to effectively address the source of
contamination, clean up contamination to the extent reasonable and approp1iate, and
prevent any recurrence of the conditions. We thought it would be valuable to have a face-
to-face meeting to discuss our ideas before finalizing the EE/CA.
With those thoughts in mind, we suggest the following as a possible agenda for the April
23 meeting:
A. Overview of Investigation Results
Mr. Luis Flores .. April 18,200 I U.S. EPA Region 4
Page 2
• •
I. Hydrogeology and Site Conceptual Model
2. Lead in Site Media
a. Soil Results
b. Sediment Results
c. Surface Water Results
d. Groundwater Results
e. SSL Exceedances and Background Results
3. Other Metals, SVOCs, VOCs, Pesticides/PCBs in Site Media
B. Proposed Future Actions
I. Proposed Remedial Actions, interim and/or final
2. Proposed enhancements to on-site stormwater management
C. Risk Assessment Scoping
D. Schedule
We look forward to a productive meeting with you.
Sincerely,
MONTGOMERY WATSON
Daniel W. Hall, PG
Project Manager
Enclosures: Table I -Plant Arca, Comparison of Soil Data to USEPA Region IX Human
Health Based Industrial PRGs
Mr. Luis Flores
Table 2 -Wetland Area, Comparison of Soil and Sediment Data to USEPA
Region IV Ecological SSLs
Table 3 -Basin Area, Comparison of Soil and Sediment Data to USEPA
Region IV Ecological SSLs
Table 4 -Basin Area, Comparison of Soil Data to USEPA Region IX Human
Health Based Industrial PRGs
Table 5 -Site Wide Surface Water Metals Data, Comparison of Surface
Water Data to USEPA Region IV Ecological SSLs
Table 6 -Site Wide Groundwater Metals Data, Comparison of Groundwater
Data to North Carolina Groundwater Standards (Including Interim
Values)
April 18. '001 U.S. EPA Region 4
Page 3
• •
Drawing Fl Lead Concentrations in Soils, Plant Area -IND SSLs, Onsitc
Sedimentation Basins Area -IND SSLs, Offsitc Wetlands and
Unnamed Tributaries Area ECO SSLs
Drawing F2 Lead Concentrations in Soils, Plant Area -IND SSLs, Onsitc
Sedimentation Basins Area -ECO SSLs, Offsite Wetlands and
Unnamed Tributaries Arca ECO SSLs
Drawing F3 Lead Concentrations in Sitcwidc Sediments
Drawing F9 South Wetlands Area
cc: Timothy J. Lafond -JCBGI (with maps and tables)
Debbie H. Hastings -JCBGI (with maps and tables)
Jane Fowler -Quarles & Brady (tables only)
Mark Koczela -JCBGI (no attachments)
Glen Ponczak -JC! (no attachments)
Randy McElveen -NCDENR (with maps and tables)
N :\Jobs\208\2326\0 I \Vlfl\ltr\99 _ Ltr.doc
2082326.01160101 MAD-I
Mr. Luis Flores April I 8,200 I
Page 4
U.S, EPA Region 4
DRAFT
• •
TABLE l
Plant Area
Comparison of Soil Data to USEPA Region IX
Human Health Based Industrial PRGs
Soil
REGIXINDUSPRG
METALS
Lead -Field Lab X
Lead -Fixed Lab X
PESTICIDES Not above SSLs
SVOCs
Dibenz( a,h)anthraccne X
lndeno( 1,2,3-c,d)Pyrenc X
Benzo( a)pyrene X
Benzo(b )fluoranthcne X
Benzo( a)anthracenc X
voes Not above SSLs
X = Indicates those analytes detected above Industrial PRG.
N:\208\2326\0 I \wp\1bl\99 _BackgroundSummaryByArcaEco.xls <Plant Area I lllE>
DRAFT
TABLE 2
Wetland Arca
Com1rnrison or Soil and Scdimrnt Data to USE PA Region IV Ecological SSLs
Sediment ,,·o. Exceedances Soil No. Exceedanl'l'S
f:l'A REG I\' ECO SSL Hackgr. EcoSSL El'A REG I\' ECO SSL llackgr. EcoSSL
MET,\LS
Field Lah
Lead X X 2
Fixed Lab
Aluminum B 6 NA xx 0
Arsenic X 3 2 0
Barium II 2 NA 0
Be~ Ilium II I NA 0
Cadmium X 7 I 2
Chromium, Total X I 2 0
Cobalt II I NA 0
Conner X I II xx 0
Iron II 8 NA xx 0
Le.id X 36 37 0
Manl!ancse II 7 NA xx 0
Mercurv X II I 2
Nickel X 2 7 0
Selenium 8 2 NA 0
Silver 2 0 0
Van:idium II I NA 0
ZinC II 4 0 xx 0
l'ESTICIDES Not above Eco SSL Not Analyzed
voes Not above Eco SSL Not Analvzed
I
S\'OCS Not above Eco SSL Not Analyzed
X = Detected above its Eco SSL. Would be carried into a Baseline ERA.
ll = Those analytes added because they were detected above the badground criterion, but did not have an Eco SSL. Would be carried into a Baseline ERA.
XX= Detected above the Eco SSL, but not above background criterion. These compound would not be carried into the Baseline ERA.
NA = Not available
01.J)en·:uions from Darnl.Jasc Ou1ru1:
2
2
0
I
2
2
2
0
I
1. There ,are no sediment sample locations where other analytes exceed their background criterion in the wetland, but the lead bad:ground criterion is not exceeded.
2. There fre no sediment sample locations where other analytes e11eeed their Eco SSL in the wetl,rnd, but where the lead Eco SSL i§ not C,\cccded.
3. There is one soil sample location (S13-45) where other analytcs (cadmium and mercury) c11cccd their background criterion in the wetland, but the lead background criterion is not e.,cccded.
4. There is one soil sample location (SB-45) where other analytes (aluminum, iron. manganese) exceed their Eco SSL in the wetland, but the lead Eco SSL is not exceeded.
5. Considering 3 and.; above, it apc:irs in soil there arc no samples in the wct];rnds where there arc ;111;1lytc.q that c,,eeed backgm11nd and their Ecn SSL where lciid i, 110( i11 nrcedal'lle ul' it~ Em SSL.
N:'20812.\26\0llwpltbl\99 _!hc~groundSummary13yAreuEco ~Is <Weiland Area Eco>
•
•
• • TABLE3
Basin Area
Comparison of Soil and Sediment Data to USEPA Region IV Ecological SSLs
Sediments No. Exceedances Soil No. Exceedances
EPA REG IV ECO SSL Backgr. EcoSSL EPA REG IV ECO SSL Back~r. EcoSSL
METALS-Field Lah
Lead X X
METALS-Fixed Lab
Aluminum 0 NA xx 0 20
Cadmium 3 0 14 0
Chromium, Total xx 0 I xx 0 14
Copper xx 0 3 xx 0 2
Iron B I NA X 1 20
Lead X 14 15 X 30 45
Manganese 0 xx 0 20
Mercury 3 0 14 0
Nickel xx 0 1 0 0
Silver 3 0 0 0
Zinc X 3 1 X 7 8
PESTICIDES
gamma-Chlordane X NA 2
svocs
Anthracenc NA 0 X NA 1
Bcnzo( a )pyrene X NA I X NA 3
Bcnzo(b )fl uoranthcnc NA 0 NA 0
bis(2-cthylhexyl) Phthalatc X NA 2 NA 0
Chrysene X NA 1 NA 0
Dibcnz( a,h)anthraccnc NA 0 NA 0
lndcno( 1,2,3-c,d)Pyrcnc NA 0 NA 0
Phcnanthrcne X NA 1 X NA 3
Phenol NA 0 X NA 1
Pyrcnc NA 0 X NA 3
voes Nol Detected above SSL Not Detected above SSL
X = Detected above its Eco SSL. Would be carried into a Baseline ERA.
B = Those analytcs added because they were detected above the background criterion, but did not have an Eco SSL. Would be carried into a Baseline ERA.
XX= Dctcc1ed above the Eco SSL, but not above background criterion. These compound would not be carried into the Baseline ERA
NA= Not available
Observations from Database OutPul:
1. There arc no sediment sample locations where other analytcs exceed their background criterion in the wetland, but the lead background
criterion is not exceeded.
2. There is one sediment sample location (SD-12) where other analytes (bis2ethylhexylphthalate) exceed their Eco SSL in the basin, but where
the lead Eco SSL is not exceeded.
3. There arc 6 soil sample locations (SB-238, 29, 31, 34, SOE, and 5 IA) where other analytes (cadmium and mercury primarily, iron once al
SB23B) exceed their·bad-grm.md-critcrioff•i-n-thc basin;-but the lead·background criterion is not exceeded.
4. There arc 5 soil sample locations (SB-24, 29, 31, 36, and SOE) where other analytes (aluminum, chromium. managancsc, and iron) exceed their
Eco SSl in the basin, but the lead Eco SSL is not exceeded.
5. Considering 3 and 4 above, it apcars in soil there arc no samples in the basins where there are analytes that exceed background and their
Eco SSL, where lead is not in cxcccdance of its Eco SSL.
DRAFT
N:\208\2326\01\wpltbl\99 _BackgrouudSumm:iryl3yAreaEco.,1s <Basin Arca Eco>
• • •
TAllLE4
Basin Arca
Comparison of Soil Data to USEPA Region IX Human Health Based Industrial PRGs
REGIXINDUSPRG
J\IETALS-Fidd Lah
Lead X
METALS-Fixed Lab
Aluminum
Cadmium
Chromium. Tot:i.1
Copper
Iron
Lead X
Manganese
Mercury
Nickel
Silver
Zinc
PESTICIDES
gamma-Chlordane
svocs
Anthraccnc
Bcnzo(a)pyrene X
Bcnzo(b )fl uoramhcne X
bis(2-cthylhcxyl) Phthala1e
Chryscne
Dibenz( a,h)anthracene X
lndcno( 1,2,3-c.d)Pyrenc X
Phcnanthrene
Phenol
Pyrenc
voes
X = lndica1cs those analytcs detected above Industrial PRG.
DRAFT
N:\20812326\01\wp\!bl\99 _BackgroundSummaryllyAreaEco.,ds <Basin Arca IIIIE>
TABLE 5
Sile Wide Surface Water Mebils Data
Comparison of Surface Water Data to Region IV Ecological SSLs
Total 1\-lctals No. Excccdances Dissolved Metals No. Excccdanccs
Metals REG IV ECO SSL Backgr. EcoSSL REG IV ECO SSL Backgr. EcoSSL
Aluminum B 4 NA B I NA
Antimony
Arsenic
Barium
Ucryllium
Cadmium
C.ilcium
Chromium, Total
Cobalt
Copper I 0
Iron xx 0 5 xx 0 2
Lead X 4 5 X 2 I
Magnesium
Mang,mcsc
Nickel I 0 I 0
Potassium
Selenium
Slln:r '
Sodium
Thallium
Vanadium
Zinc ' X 5 2 X 3 I
Mercury
X = Detected above its Eco SSL. Would be carried into a Baseline ERA.
B = Those analytcs added because they were detected above the background criterion, but did not have an Eco SSL. Would be carried into a Baseline ERA.
XX= Detected above the Eco SSL, but not above background criterion. These compound would not be carried into the Baseline ERA.
NA= Not available:
Observations from Database OutPut:
' . . I. There is one surface water sample (SW-04) location where other anlaytcs (zinc) exceed their background criterion, but the lead background criterion is not exceeded.
2. Only iron exceeded its Eco SSL in dissolved surface water samples where lead did not exceeded its Eco SSL. However, iron concentrations were below background
at these locations.
3. Lead exceeds its Eco SSL only within the Basin Area; not in the Wetland Arca.
DRAFT
N:\208\2326\0 I \wp\tbl\99 _ B:ickgroundSummaryByArcaEco.xls <Surface W:itcr Eco>
•
•
• TABLE 6 •
Site Wide Groundwater Metals Data
Comparison of Groundwater Data to North Carolina Groundater Standards
(Including Interim Values)
Total Metals Dissolved Metals
Metals NC GW Stds No. Exceed NC GW Stds No. Exceed
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium, Total X? I'?
Cobalt
Copper
Iron X 3 X? , .
Lead
Magnesium
Manganese X 5 X
Nickel xo I?
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Mercury
X = Analyte was detected above NC Groundwater standard.
X? = Analyte was detected in field duplicate (MW-03 DUP) above NC Groundwater standard, but
not normal sample.
DRAFT
N:\208\2326\0 l\wp\tbl\99 _BackgroundSumm:nyByArcaEco.xls <Ground Water fl! IE>
I?
5
. -.. ' .. ,_,,..,. .. ,._,,_.,,., ...
DEPARTMENT OF ENVIRONMEIH Al"D NATURAL RESOURCES'
DIVISION OF WASTE MAN.~ENT
MICHAEL F. EASLEY, GOVERNOR ,.
WILLIAM G. Ross JR., SECRETARY
WILLIAM L. MEYER, DIRECTOR
Nooo-TH Cuoo,,..,..,. ~-..,. or c.,,..,.,°"" .. i!:..,. ...,.o ,,...,.,.,......._ Rc.OU11tec.s
FAX TRANSMITTAL RECORD
DATE:
TO:
FAX#:
_.[<_,_,.CJ.,='\;\~~~--"'1--+M~c_,~,="-~( v-=-e.=e~Y\,_,__· --, Superfund Section
tso b K1 ?otc:1s IY\&YY)ls VJe. I! ~ 86-
Number of Pages (Including Co\;er): --"'-b-~----------
FROM:
RE:
Comments:
I . Cl> wo._· G--Y-lk-M\ &\.,U.ll<r 0c; w I v\c ili-vi-sJ ,Q WJ 12:_-¥~-~ G_f+~c~
TLS-Lr e , h--&'Y:-<._ L J M:o:~-('::\--J411s ; 11, --t1-'-'(
~j :, 0 , , .ct f", rlJ ~,I \JJ/len \ )J -t s-f (,,~
, t r~ :\!-J:it-eA: t,\,, « s 1.j-e_ ,.,...-y slcg_l{(j-{.(J
/ s_l b _p (: <!d O 4 --e t '-l :::cb; A \._
&\.--t:V...v Ul-!',,t:'¼::, /'i/( p-eYte.i) w--e. vi X2 10-1 2 / De-e?, D1\N"J':;? ( NC Sup,-,'...Ar-F-~~.,,& b-ai YU)~ -f""-e........e_\ \ ~t~ vJ.l'c; "-~{, \ .,_ ~ J......;-f ~ ~-t\ i-7 d , -r ~-~ ~ ti.. .... L{ G.,\..JJ , Confirm receipt of documem(s): Cr_ ____________ , Superfund Section
(9l9) 733-280], e)..1. __ _
1646 MAIL SERVICE GENER, RALEIGH, NORTH CAROLINA 27699-1646 401 OBERLIN ROAD. SUIE 150, RALEIGH, NC 27605
PHONE: [phone] \ FAX: [phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACT!O~ EMPLOYER -50% RE.CYCLED/10% POST-CONSUMER PAP:;:R
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 20, 200 I •
RE: Overview of Groundwater Sampling for Engineering Evaluation ofLead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 30 January 2001, a representative of the NC Superfund Section provided overview of the
groundwater-sampling event at monitoring wells MW-3 and MW-6 as identified and described in the
Engineering Evaluation/Cost Analysis Work Plan for the Johnson Controls Battery facility. I observed groundwater chemical parameters taken on water from both wells. The submersible
grundfos pump was overheating during pumping operations causing the groundwater temperature
to be around 30°C which is extremely high for groundwater. If volatile organic compounds are detected in this area well MW-6 will require re-sampling. Dave Beverly and Bobby Saver with Montgomery Watson completed the groundwater sampling from each well. Yesterday they sampled monitoring wells MW-I, MW-2, and MW-4.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone] An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
• February 20, 2001
RE: Overview of Monitoring Well Installations for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 10 January 2001, a representative of the NC Superfund Section continued to provide
overview of Rotosonic drilling operations and well installations as identified and described in the
Engineering Evaluation/Cost Analysis Work Plan for the Johnson Controls Battery facility. Terra
Hermonn and Dave Beverly with Montgomery Watson logged and consulted the driller in determining
geology for well installation. They were in the process of installing monitoring well MW-I, which
was drilled to a depth of 3 7 feet, and the well was installed at a depth of 3 5 feet below ground surface
with a IO feet screened interval. The Soil profile/ classification was similar to all site soils, which is
clayey to fine sandy silt with mica (saprolite).
Bobby Saver with Montgomery Watson was also present and was logging and collecting soil
samples to a depth of 4 feet below ground surface at the back of the facility. Ecological Services, Inc.
was recovering the samples using GeoProbe technology. Bobby was completing the second round
of soil sampling to further delineate the contaminant source areas. At 9:30 Am I departed from the
site and assisted the Division of Water Quality in sampling the adjacent property private well at the
property of Bob Kigers mother located east-northeast of the Facility property.
The Rotosonic drill crew set-up and drilled MW-4. The monitoring well was set and constructed at
a depth of 35 feet below ground surface with IO feet of screen intercepting the water table. The three
wells that are already set were bailed and water levels were taken at several times throughout the day
to evaluate the well's recovery rate. After completing construction ofMW-4 the drill crew set-up,
drilled, and constructed monitoring well MW-6 in the former Drum Storage area. Monitoring MW-6
was constructed from 35 feet below ground surface with 10 feet of screen, sand, bentonite, and
grouted to the surface.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affinnative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 19, 2001
RE: Overview of Surface Water /Sediment Sampling for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCO 000 770 487
Winston Salem, Forsyth County, North Carolina
On 9 January 2001, a representative of the NC Superfund Section provided overview of
Rotosonic drilling operations done by ProSonic Environmental Services as identified and described
in the Engineering Evaluation/Cost Analysis Work Plan for the Johnson Controls Battery facility.
Monitoring well location MW-2 was re-drilled to a depth of76 feet and backed up to set the well at
a depth of72 feet below ground surface. MW-2 had 10 feet of Screen in the groundwater with 12
feet of sand and several feet of holeplug and then grouted to the surface. They proceeded to drill
MW-3 located adjacent to the maintenance facility. Some moisture was detected at 20 to 27.5 feet
below ground surface and competent crystalline rock was encountered at 29 feet below ground
surface. Monitoring well MW-3 was constructed at a depth of 47.5 feet below ground surface and
included 15 feet of screen, 17 feet of sand and 3 feet of bentonite and was then grouted to the surface.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 16, 2001
RE: Overview of Soil/Sediment Pile Sampling for Evaluation of Lead Concentrations
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 7 February 2001, a representative of the NC Superfund Section arrived on-site and
provided overview of Soil/Sediment sampling of the soil piles around Sediment Basin# 1. Dave
Beverly and Bobby Saver with Montgomery Watson had received authorization from their client to
proceed with the sampling as proposed by the EPA and the State. Nine (9) soil pile samples were
collected from 5 soil piles located around Sediment Basin # I. Each of the 9 soil samples were
composite samples collected vertically through the soil piles. 2 composite samples were collected
from each of 4 large soil piles and only I composite sample was collected from a single smaller soil
pile. The composite samples were carefully collected from varying depths and/or soil variations to
the full depth at each sample location. This work was not documented in the original EE/CA Work
Plan but was added as a result of overview of the area during field investigations. Two (2) soil
samples were also collected from a former unloading area at the railroad spur outside the fence line
of the facility.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 16, 2001
RE: Overview of Surface Water /Sediment Sampling for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 31 January 2001, a representative of the NC Superfund Section provided overview of
Surface Water and sediment sampling from Basins and Background locations as identified and
described in the Engineering Evaluation/Cost Analysis Work Plan for the Johnson Controls Battery
facility. I observed Surface Water samples being collected from Sediment Basins 1,2 &3 and form
background location SWBG-06. They then proceeded to resample surface water and sediment from
location SWBG-05 due to the previous detection of high lead levels in samples from this area.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
E£jCA
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
February 16, 2001
RE: Overview of Surface Water /Sediment Sampling for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 6 February 2001, a representative of the NC Superfund Section arrived on-site to
provided overview of Soil/Sediment samples from the soil piles around Sediment Basin# 1. After
discussing the sampling procedure proposed in a teleconference call with the EPA and Montgomery
Watson it was determined that the number of samples to be collected and the sampling procedure
needed to be renegotiated and authorized by the Johnson Controls Battery Group representatives.
The options were discussed in a telephone conference with Luis Flores, EPA Region IV and he
discussed the issue with Dan Hall of Montgomery Watson who then made the proposal to the JCBG
representatives. The soil pile sampling was postponed until a later date.
Instead of sampling the soil piles we proceeded to collect samples from background sediment
and soil locations SBBG-06, SBBG-07, SBBG-08 and SDBG-08. Later that afternoon I observed
while Dave Beverly and Bobby Saver collected Sediment and Soil samples from background locations
SDBG-09, SDBG-10, SBBG-09 and SBBG-10 at locations in or adjacent to Salem Lake. Additional
deep Soil/Sediment samples were also collected from upgradient locations at Sediment Basin #2. I
also observed data logging for rising head permeability test at various wells including MW-I.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
• • MONTGOMERY WATSON
LETTER OF TRANSMITTAL
To: Mr. Randy McElveen Date:
North Carolina Department of Job No:
Environment and Natural Resources
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Re: QAPP Signature Page
WE ARE SENDING YOU [X] Attached [ ] Under separate cover
COPIES
] Shop Drawings
] Samples
] Copy of letter
] Lab Results
] Prints
] Specifications
DESCRIPTION
February 13, 2001
2081404.1 G 120 IO I
[ J Plans
[X] Completed QAPP Signature Page
DATE
November 2000 Completed QAPP Signature Page
THESE ARE TRANSMITTED as checked below:
[ ] For approval
[X] For your use
] As requested
] Approval as submitted
] A pprovcd as noted
] Returned for corrections
J Resubmit __ copies of approval
] Submit copies for distribution
J Return __ correct prints
] For review & comment [ ] _______ _ J Prints returned after loan to us
] For Bl DS Due ________ _
REMARKS
Please replace the existing signature page with the final QAPP completed signature page.
COPY TO:
NAl\'1E Steven G. Wiskcs
If enclosures are not as noted, kindly notify us at once.
M:~obs\1242\l 79\\ 6\wp\rpt\%_Trans.doc
One Science Court
P.O. Box 5385
Madison, Wisconsin
53705-0385
Tel:[phone]
Fax: [phone]
Delivering Innovative Projects and Solutions Worldwide
NCDENR WSRO Fax:[phone]
North Carolina • Department of Environment and Natural Resources
Mlcbael F. Easley, Governor
· William G. Ross Jr., Secretary
FAX
TO:
Feb 8 '01 15 :03 P. 0l/05
# of pages including coversheet: __ 5 ___ Fa~# (91crj 73~ -'f8 I I
From:
Note:
Geoffrey Kegley
f.~y.
f/ere Mt! the r,e.s., lh I~ fk ~~
~£. ml wt · Be.!:> --~r ·5 wel/.
I Sf,'tl /2u-,c. . "'" f . ~ ~ C 1,,,,,,, ' e. i-,
··-~ vv,.y It,;,, else i3 ,701'n_J we!(_
Winston-Salem Regional Office, 585 Waugh town Street, Winston-Salem, North Carolina 27107-2241
Phone: 336 -m-4600 \ FAX: :,36 -771-4632 \ Internet www.enr.state.nc.us/ENR/
AN EQUAL OPPOR11JN1TY \ AFFIRMATIVE AcnON EMPWYER ~ 50% RECYCLED/ 10% POST CONSUMER PAPER
U)
0 " 0,
c-~ ~-ry
0._ D NO·
JRT TO c"c'e•:,co'--_________ Regioml Offiu:.
U:Cn)R(S} : !K~L<~-~•l~.H~Yc_ __ _.: ____ _ t5 1: IJJ(l/1001
•• E.:. en
• ----1 POSE:
.D
(lj LL
BORAT0RY ANAi YSIS ,
BOD JI0
COD Hitli ~
CODl...,._,B~
CnLifonn. M.Ff'ec.ll 316Jt,/
Cotifom1" MFTotal lljDt
roe
Tw~
~, Sc!-ru.b:I S:30
Total S<.<!i,....,<in:l lil'JLid.s
< ,H
,o.llaliaity tn nH 4 5
A.fl...1licrity co pHS.3
C.t1boMJC
B~ate
llll"""' ' Clmlroiu.m.:: He1 103:'.
Co]c,r./roe 80
Cya.o;<i;:720
MMl.."JTS:
rn,iL
m•n. --HOQr-dl
llOOml
-"
tmJ -~
--"'
llnit$
,,-,JL
-11.
111_~/L
rnY,IL
rn,:IL
moll-
lJ.,.,,_
c•
m<IL
Owr..:.·:
Lo.:~ticm 01 S1t1:
Ix~ci_pcion a.f Hmplfr1g po-inJ
~1Ulg ),,fohcd: ·-"'
Di~. SoliJs-70300
Avc,ride9'.il
tu:rdn<S'!:LOt:l.1900
l:h1dix,,;;.; (r•-.ln·'-"a.<~, 902
Fiirnols JJ?:J,0
.'-ffi,,ciJ".c O>od. '.l)
SuJf.>k: .
Si.Jfilk 745
MBAS
Oilllll<iGi=
s.iuc~
&,oo
f'l)n:J'Wdd:,yd:
t-n{J as N 6L0
T¥Na.sN62.'i
~02 +N03 as.n 6i0
P: TotJL a1 P 665
P04
DIVISION OF WATEII QUALITY
S,\MPL[ PRfORrTY
~ROUllr,..'E
~ CHAJN OF CUSIODY
[~ SAMPLE TYP£
BO-B TYCHR RES: .
--· --• -· -·· ___ ,._..
"'"""s/crn2
""1L
-·" --· --•
JT"'/t,
--([,
o,g/L.
mglL
mpL -· -"
□HtERGENC\'
G
A:!-S:ilVfr,6.566
.'\J-Atuminum -46551
-"-'•Anien..ic46½1
Ba-B.irium465~S
Ca.-Cal.ciw-n ◄IS.552
X C-...d-:Cadlum 46:559
X Cr-Oi.ri:-nium 4M e,o
Ct1.-C:.,__,r JOH
X 1·,. kor1. J0-1-5
Hg-Men:ur,-7 L 9(X)
K-?<J t.'<\ -Juro 4fil5 5
X M.g• :',,l;u,-nesiUtlJ92}
X Mn-Mani=e 1~5
f'oa.-SodilJl"D '):>'}
tfi-Nicld -'1' X f't:-.-U".ad-16564
So:.-Sda,ium
Zn_7,.inc4656l
'
-(
~
Lab NtJJCl.>,:r IG-0039
DJJc Rccci,nl. : 1/11n.oo1
Til'TltC-Rcc,:,Lw,J. •.oo
Re,:x:5...-ffi B,-Th5
Rel~ By DS
Dile reported: 2Il/?{JOI
, .. r1,,e1rwxhk>o11L-Pc!.Lici.k!.
""" OrtllD<li::f!Ollolioru-s-P<'.1tici.d.,,i ·-· ~itro~ ~
•<IL
m•• Add H.i:!ticidd
<2.0 ,~
<2.5 , .. X s.cmi-ro~1b
-.. 11<>!1_ Tl"'H-[fu,;u-l Ran...-:
2,400 ,,.,,
ur/L. \'oLrti.le.0.!8rtiC~{VOA t,,,uk)
m,JL
3.4 r!lfJL" TPH-Ga.!oline.RlnPe.
40 ,,ft-TPH.-BTEX Ca.wime R,n~c --.,n --;
23 11g/l_ I
"'" ,~
•g/L
o--------------------------------------------------~---------------------85--------------------------------------------------------~~-------------3-------------------------------------------------------------------IY------------------------------------------------------------------------z '--'' □ u z
l,;OlY:l
ENR/DWQ LABORATORY LAB NO. 1G0039
SEMI-VOLATILE ANALYTICAL REPORT
Lf) REPORTED BY PC SUPERVISOR ·REK
0 CHECKED BY PTO OAT L 1/29/2001
" r0 RE'/lEWE.D BY PTO 0 ENTERED BY CL
SAMPLE IYP~: WATER ANALYSIS RESULTS OA1E
C<) ; sEral'vol'Jlfirts ·~ti1~1~f:8illJt,:• 0 c:::':\;tj?,/t::r
Lf) ,-, 5z.5-3.3 ANll.lNf_ u 606-20-2 2,6-DIN I TROTOLUENE 10 u
108·95-2 PHENOL 10 u 99 09 2 3 NITROANILINE 50 u
0 ·•44-4 BIS(2-CHLOROETHYL} ET ti ER 10 u 83-32-9 A.C[NAPHTHE.NE 10 u
57 8 2-CHLOROPHE.NOL 10 u 51-28-5 2,4-0INITRO PHENOL 50 u
00 541-73-1 l,3-0ICHLOROBE_NZENE 10 u 100-02-7 4-NITRO PHENOL 50 u
.D 106-46-7 l ,4-0ICHLOROBE.NZENE 10 u 132-64-9 DIBE.NZOFURAN 10 u
UJ 100-51-6 B rnzyL ALCOHOL 20 u 121-14-2 2A-01NI TROTOLUENE 10 u
LL
95-50-1 1,2-rnCHLOROBENZENE LO u 84-66-2 DILTHYL PHTHALATE 10 u
95-48-7 2-MLTHYL PHENOL 10 u · 7005-72-3 4-CtiLOROPHE.NYL P~t[.NYL ElHER 10 u
f 108-60-l 8iS(2-CH LO ROI SOPROPYL~ DH ER 10 {U 86-}3-1 FLUORLNE 10 u
.106-44-5 4-METHYL PHENOL 10 u l 00 01-6 -4-NITROANILINE 50 u
62164-7_-N-NI TROSO-D1-N-PROPYLAMINE. 10 . u 534-52-1 4,6:DIN!TR0-2-METHYL PHENOL 50 u
"" 67-72-1· .HEXACHLOROETHANE 10 u 86-30-6 N -NITRO SO DI PHE N-YL.AM I NE. 10 u
t0
'° • 98-95 3 N!TROBENZE.NL 10 ' u lOl-55-3 . 4-SROMOPHENYL PHENYL-E:THER \0 u
"" I 78-59 I ISOPHORONE LO u 118-74-1 HEXACHLOROBEN~ENE 10 u
~ ,..._ 88-75-5 2-NITRO PHENOL 10 u 87-86-5 PENTACHLORO PfffNOL 50 u ,..._
I 105-67-9 2,4-0IMETHYL PHENOL 10 u 85-01-8 PHENANTl'lRENE 10 u
<.D t0 65-85-0 BENZOIC A.CID 50 u 120-}2:7 ANl"HRA.CENE 10 U·
r0
X 111-91-1 RIS(2-CHLOBOl.THOXY) MDtiANE 10 u 84-74-2 D1-N-BUTYL PHTHALATE 10 u
co .83-2 2,4-DICHLORO PHE.NOL 10 u 206-44-0 FLUORANTHENE 10 u
LL
82-l 1,2,4-TRICHLOROBENZENE 10 u 129-00-0 PYRENE LO u
91-20-3 NAPHTHALENE 10 u 85-68-7 6U1YLBENZYL PHTHALATE JO u
. L0647-8 4-CHLOROANILIN[ 20 u 9 i-94-L J,3'-DICHLOROBUJZIOI NE 20 u
87-68-3 HEXACHLOROBUTADLENE 10 u 56-55-3-BENZO(A)AN THRACENE 10 u
59-50-7 4-CHLOR0-3-ME THYL PHENOL 20 u 2_18 OL-9 CHRYSENE 10 lJ
91-57-6 2·MF..H1YL NAPtfTHAL[NE 10 u 117-81•7 81$(2-EfHYLHEXYL) PHTl1ALATE 10 u
D 77-47.4 HEXACHLOROCYCLOPf_NT ADIE NE 10 u 117-840 01-N·OCTYt PtHHHlATE 10 u
°' (f) 88-06-2 2,4,6-TRICHLORO PHENOL LO u 205-99-2 BE.NZO{B)FLUORAN Tll EN£ 10 u
3 95-95-4 2,4,5-TRLCHLORO PHENOL 10 u 207-0..'3-9 BENZO(K)f"LUORANTHENE 10 u
"' 91-58-"/ 2-CHLORO NAPHH-lAU'..N[ 10 u 50-32-8 BENZO(A)PYRcN!: 10 u z w S.'3-74-4-2-Nll"ROANILIN[ 50 u L93-39-5 INO[NO(l ,2_,3-CO)PYRENE 10 u
<=l LJ 131-l l 3 DIMETHYL PHlHALATE 10 u 53 70-3 D18ENZO(A,H }ANT HRAC[NE LO -U
z 208-96 8 ACE.NAPHHlYl.ENf. 10 u 191-24-2 GENZO(G, I i,l)PERSLENE 10 u
tf)
0 ' " 0
Q_
t0
0
tf) -~
-· 0
00
.D
"' u.
"' t0 "' " I -r--r--
I
"' t0 ,0
X "' u.
D
"' (/)
::3
e;, z Id 0 LJ z
•
•
SEMLVOLATILE ORGANICS REPORT -DWQ LAB PAGE 2
; NO BASf_ / NEUTRAL OR ACID EXTRACTABLE ORGANIC
COMPOUNDS DET[ClED BY GC/MS.
LAB NO. __ 1=-G=-00=-=-3~9_
TQL· fa,rgd Quantilation Limit-Subject to
change due I? instrument" sensiti..,ily
r. Tentdtively Identified, estimated concentration
[. Es.ti mated Value
U· Samples._analyz_cd for this compound but notd.etecte-0
N-Sample not analyzed foi-this. compound
D· Detected below QUantitation limit
H· Holding lime ex::~ee<ied
NCDENR ws,m Fax:[phone] Feb 8 'Ol 15:04 P.05105
Divisi ♦f Environmental Managem.
GROUNDWATER SECTION R Ee:. ~~.!\I E:f)
CHAIN· OF CUSTODY RECORD r--1. I~. C,:e =~;·;,. i'j·[ E i··f f'\ F~
2,1 ---,; ,_ .
f Or In Ve St i g at i On Of _ _.,.C)C<'e-.<t-~l-'Jr-..y'<-L<-~fi~'~'~1 "91~· ~'~f------
V -~-'·I~ : .-:: , ,._,,,; ·, -...._,:,.,~~.'f.c, . .:a ,\ ....
Samples collected and GW-54 forms completed by: ;'"\.,, •,•: , .. , '" ,,•.: ,. t.;f' ·J~·, ;. ~ ... ,-:-~;./, ,._,• 'i ,,.•,:; C,1, :.,..
Lab Only Ouad
... --NO,• of
Lab No. No. Location Date Time Conta_\ners
I 1. r;J J7f1 33:i. ,·J:d -<·' r-1"""'":.-(,o ;...., ;£ 1_l✓
J(,/,,.,,.,,L.~ ;,IJ,. 1/0/0-1 /t?.ou ;£ '. ., ,,
?"
--~-.
.. .
\
,.
><
. "· .. . ,
Rel~shed ,,by(Signature)i ·
.., ~-·/.-·/""),'/ ~ ,R',.,J,,&1---Y
-iie~ei~_ed by(Sign~ei,,-,M 1 \ . . -, . . ---. . r, f.. '[Jfv,,,.. ", ,,.,,y, .,)IJ,~.1/
,/4t?':/Tlrr,e
/r { l'J C7 , ' Rec: ' ·. • ,.!_ ·-+:··
Rel. by I
'
' .,
Rel. Rec. by ·-. I ·--~-·-. \ ..
Rel. Re_c. ·by I
"
Method ot S_hip me nt: (r,.,v -
i(v-' (':
Seal by: rc;v 'Bio ken by :'f',J!!,l.:/'c',..P..jl:,
Security Type and Condition: Lock by: ,; Open by: --c:: ,..-:,,,;J/(V/IJ/J/J ~-.. -LAB USE nNI Y . . ~' ',
Lab No. ,'JO. :; r·.:
From Throunh Co ntffi n er s Analysis fielin'i'iulshed by·: Received by Date I Time
/' .',/1/)7>6; I /,;;__~J f }Jul{,, {;/.,/r/hl, ~,--~. '/,, 1~' I 9·,,,
f,/() ;, C .,, ,0 ll I :f..; ''J/ l /_:)~ /} •• I~ ,/t v\ ,, 1//,')/ (}, fth . c:.• :»..' Ji' ./1,,.,..~ lr,11{ uf11/u I Oro,r
I
. "
·-.. I
I
I .
-I -
. -~ I ·-1, I
White copy -GW Headquarters, Canary copy • Lab , Pink copy -Region
9/C'?
.
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
January 26, 200 I
RE: Overview of Sediment and Soil Sampling for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 20 December 2000, a representative of the NC Superfund Section provided overview of
sediment sampling as identified and described in the Engineering Evaluation/Cost Analysis Work Plan
for the Johnson Controls Battery facility. Sediment samples were collected from background wetland
areas across Lowery Mill Creek downgradient and upgradient of the tributaries discharging from the
facility property. Dave Beverly, Terry March and Bobby Saver collected samples SD-BG-01 through
05 for CLP laboratory testing. Two samples were also collected in Salem Lake downgradient of the
Site for background evaluation. Dave Beverly and I proceeded to the back of the facility northeast
of the Site to observe sediment locations previously collected in this tributary without agency
overview. It is believed that this tributary never drained the property and is considered background.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
January 25, 2001
RE: Overview of Sediment and Soil Sampling for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
ff/cA
On 19 December 2000, a representative of the NC Superfund Section provided overview of
soil and sediment sampling as identified and described in the Engineering Evaluation/Cost Analysis
Work Plan for the Johnson Controls Battery facility. Soil/Sediment samples were collected from
sediment basin #2 to the natural/residual soil depth. Dave Beverly, Terry March and Bobby Saver
collected the samples for laboratory testing. Dave Beverly and I proceeded to the wetland sample
locations collected on Monday when I was not present to observe the work. Monday's sample
locations were appeared to be representative of wetland sediments.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
January 25, 200 I
RE: Overview of Geoprobe Soil Sampling for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
On 11 & 12 December 2000, a representative of the NC Superfund Section provided
overview of soil sampling as identified and described in the Engineering Evaluation/Cost Analysis
Work Plan for the Johnson Controls Battery facility. Soil samples were recovered to a depth of 4 feet
below ground or asphalt surfaces around the immediate facility property. Tommy Cargle with Real
Probe, Inc. collected the samples using a geoprobe and Dave Beverly, Terry March and Bobby Saver
with Montgomery Watson logged and jarred the samples. I observed sampling of soils at locations
JC-SB02, JC-SB04, JC-SB0S, JC-SB06 through JC-SB!S and JC-SB! 7. The soil profile generally
included 2 to 12 inches of re-worked fill material and tan to brown with white and black mottled fine
sandy micacious silt (saprolite) with weathered quartz lenses
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone· 919-733-4996
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
• January 25, 200 I
RE: Overview of Sediment and Soil Sampling for Engineering Evaluation of Lead Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Caroli11a
On 14 December 2000, a representative of the NC Superfund Section provided overview of soil and sediment sampling as identified and described in the Engineering Evaluation/Cost Analysis Work Plan for the Johnson Controls Battery facility. Soil/Sediment samples were collected to the natural/residual soil upgradient of sediment basin 3. Dave Beverly and Bobby Saver collected the samples for laboratory testing. Dave Beverly showed me the sample locations and holes for sediment/soil previously collected upgradient of sediment basin #2.
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone 919·733-4996 An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
•
Memorandum
TO: FILE
From: Randy McElveen
Environmental Engineer
NC Superfund Section
January 25, 2001
RE: Overview of Site Screening Risk Assessment for Engineering Evaluation of Lead
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
f::E/ctA.
On 6 November 2000, a representative of the NC Superfund Section participated in a Site
Screening Ecological Risk Assessment of the Johnson Controls Battery facility, sediment basins and
adjoining tributaries and downgradient wetland areas. Those who participated in the screening
process included Michael Kierski and Dave Beverly with Montgomery Watson and Rick Erby with
JCBG and myself Tom Augsburger with U.S. Fish & Wild Life was also encouraged to participate
in the screening process. He was not able to participate but indicated that he would review the
findings. This ecological screening process was completed as a part of the Engineering
Evaluation/Cost Analysis (EE/CA).
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
MONTGOMERY WATSON Montgomery Watson
Date: October 27, 2000 RECEIVED
OCT 30 2000
SUPERFUMO SECTION
3400 Peachtree Road NE, Suite 535
Atlanta, GA 30326
Tel: [phone]
Fax: [phone]
To: Mr. Randy McElveen
NCDENR -Superfund Section
The following items are:
D Requested
D Report
. D Test Result
No. of Description
Copies
I Cover Letter
D Enclosed
D Specification
D Prints
3 Figure 3, Proposed Sample Locations
From: David Beverly
Montgomery Watson
D Sent Separately via ______ _
D Cost Estimate
D Test Sample
[Kl Drawings
D Other
3 Figure 5, Proposed Backgrounnd Sample Locations
This data is submitted:
[Kl At your request
D For your approval
D For your review
D For your action
D For your files
D For your information
Q
CJ < u
0 u
0 m
0
7
Old Greer,sooco .::icod
•
9 0 SBBG-2
\\
SWBG-2
SWBG-·3 (COLLECT FROM WEILAND,\
AREA UPGRADENT OF t.
SWBG-1 SITE) . •~
~\
MONTGOIEIY' WATSON
Atla.nta., Georgia.
,,
\
\~
.>,
JOHNSON CONTROLS BATTERY GROUP, INC.
1llNSTON-SALEM, NORTH CAROLINA
LEGEND
' ---'°, ,(IALJ-c;,..._,:('.); ~✓,;:] ~".I ---SURF.~CE Wi'-.E":
BACKGROUND SOIL
SM~PLE Q S88G-•
0 SWBG-1 BfaCKGROUND SURF fa.CE
WATER ANO SEDIMENT
SAMPLES
SUE 11-1
PROPOSED BACKGROUND
SAMPLE LOCATIONS
i600
FIGURE
5
(Ill) MONTGOMERY WATSON ~ Montgomery Watson
3400 Peachtree Road NE, Suite 535
Atlanta, GA 30326
Date: October 4, 2000 OCT O 5 2000
SUPERfUl~U ::itCTiON
Tel: [phone]
Fax: [phone]
To: Mr. Randy McElveen
NCDENR -Superfund Section
The following items are:
D Requested
D Report
D Test Result
No. of Description
Copies
1 Cover Letter
D Enclosed
D Specification
D Prints
From: David Beverly
Montgomery Watson
D Sent Separately via ______ _
D Cost Estimate
D Test Sample
[Kl Drawings
D Other
5 Figure 2, Previous Investigation Sample Locations with Lead Concentrations
5 Figure 3; Proposed Sample Locations
5 Figure 5, Proposed Backgrounnd Sample Locations
This data is submitted:
[Kl At your request
D For your approval
D For your review
D For your action
D For your files
D For your information
l
a:J ...
a,
0
0 0 0 N
I e-u 0 I n
0
iu 0 Cl
3'
-0
0 n r---r---r---r---
I "' "' 0 .0
"' ·c
3'
2 0
0 <C u
"' e c
8
C
0 "' C _c
0 --,
•
ither Rood
~ 0
~ •• Donna Ave
a
Old Greensboro Rood
SWBG-3 {COLLECT FROM WETlAN
AREA UPGRADENT OF
SITE)
. .1..,.. I
MONniiOIVlll!RY WATSON JOHNSON CONTROLS BATIERY GROUP, INC.
WINSTON-SALEM, NORTH CAROLINA \, :~"' Atlo.nto., Georglo.
I <0, US,
LEGEND
0 SBBG-4
0 SWBG-1
ROAD
SURFACE WATER
BACKGROUND SOIL
SAMPLE
BACKGROUND SURFACE
WATER AND SEDIMENT
SAMPLES
, FIGURE
PROPOSED BACKGROUND SAMPLE LOCATIONS .-:,
• MONTGOMERY WATSON
October 3, 2000
Mr. Luis E. Flores
Remedial Project Manager
US EPA-Region 4
North Site Management Branch
6 I Forsyth Street, S.W.
Atlanta, Georgia 30303
Re: Figures Associated With Response Comments
Johnson Controls Battery Group, Inc.
Winston-Salem EE/CA
Dear Mr. Flores:
As per our telephone conversation, !'have enclosed five copies of the Figures 2, 3, and 5 of
the EE/CA Workplan at the JCBGI Winston-Salem, NC facility. Three copies of the
figures have been forwarded to NCDENR directly. The figures have been modified with
respect to our written response comments that you received on October 3, 2000. Please
note previous investigation sample locations JC-012-SL has been relocated approximately
350 feet to the northeast of its location presented in the EE/CA Workplan. The sample
location was moved to the present correct location based on a more detailed review of the
North Carolina ESI field notes and observations made during site visits.
If you have any questions, please call me at 404-814-3070, Dan Hall at 803-231-4747, or
Debbie Hastings of JCBGI at 414-228-2459.
Sincerely,
MONTGOMERY WATSON
5)~~
David S. Beverly, PG
Project Hydrogeologist
cc: Ms. Debbie Hastings, JCBGI
Mr. Randy McElveen, NCDENR
Ms. Jane Clokey, Quarles and Brady
Mr. Dan Gustafson, Quarles and Brady, Milwaukee
Mr. Dan Hall, MW, Madison
3400 Peachtree Road NE
Suite 535
Atlanta, Georgia
30326
Tel:[phone]
Fax: [phone]
Delivering Innovative Proiecrs and Solutions Worldwide
({I}) MONTGOMERY WATso!'
October 2, 2000
Mr. Luis E. Flores
Remedial Project Manager
US EPA -Region 4
North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, Georgia 30303
Re: Response to Comments on Final Work Plans
Johnson Controls Battery Group, Inc.
Winston-Salem EE/CA
Dear Mr. Flores:
RECEIVED
OCT 08 20DO
SUPERFUNO SECTION
Enclosed are five copies of the Response to Comments on the final Work Plan Set for the
EE/CA at the JCBGI Winston-Salem, NC facility. This document responds to comments
issued by EPA on September 12, 2000. EPA granted an extension request until October 3,
2000 for the submittal of these comment responses. Three copies of the comment
responses have been forwarded to NCDENR directly.
We have included within the comment responses the direct quotes that will appear in the
final Work Plan documents, and have referenced the page number, section and/or
paragraphs. As we discussed, a couple of EPA's comments could result in fairly large
changes to text, tables, drawings, and appendices. In these cases, we have provided in our
comments some rationale and description to our approach including specific sampling
locations, but we want to have EPA's input before making the final plan changes. We
anticipate discussing these issues with EPA at the upcoming meeting in Atlanta. We will
forward an updated map with all proposed sampling locations in the next few days.
Please let us know as soon as possible a list of possible meeting dates from EPA team
members. October 23 still looks good, but earlier dates are filling up fast with other
commitments by various team members.
In the meantime, if you have any questions, please call me at 608-231-4747 or Debbie
Hastings of JCBGI at 414-524-2459.
Sincerely,
MONTGOMERY WATSON
~lv-//41£
Daniel W. Hall, PG
Project Manager
Enclosure: Response to Comments on Final Work Plan
cc: Ms. Debbie Hastings, JCBGI (I copy)
Mr. Timothy J. Lafond, JCBGI (I copy)
Mr. Randy McElveen, NCDENR (3 copies)
Mr. Rick Irby, JCBGI, Winston-Salem (I copy)
Mr. Mark Koczela, JCBGI (I copy)
Ms. Jane Clokey, Quarles and Brady (I copy)
Mr. Dan Gustafson, Quarles and Brady, Milwaukee (I copy)
Mr. Dave Beverly, MW, Atlanta (I copy)
DWH/vlr/MCB
M:\jobs\1242\179\16\\vp\ltr\94 Flores.doc
1242179.16120101-MAD-l -
EE/4A
One Science Court
P.O. Box 5385
Madison, Wisconsin
53705-0385
Tel: [phone]
Fax: [phone]
Servinp :ne World's Environmental Neer!~
I
• • RESPONSE TO COMMENTS ON FINAL WORKPL~ECEIVED
JOHNSON CONTROLS BATTERY GROUP, INC. SitE
WINSTON-SALEM, NORTH CAROLINA OCT 0 3 2000
SUPERFUND SECTIOt-J
Where appropriate, we have integrated the quotes that will appear in the Final Workplan
into these comment responses. The quotes provide the actual proposed language and are in
some cases presented along with additional comment, for clarification. Some of the agency
comments, or our responses, may cause extensive changes in the text and tables, and we
have deferred making these changes until we have agreement with the agency on the
approach to be used. We propose the upcoming meeting will be used to reach final
agreement on the approach and in some cases, the methods to be used in the investigation.
The comment responses provided below reflect our basic approach to this project, which
include the following elements:
, The primary chemical of potential concern for this Site is lead, based on JCBGI's
manufacturing process at the Site and previous environmental sampling results,
although other chemicals of potential concern are included in the proposed
sampling and analysis.
, JCBGI is proposing a phased approach to this project, such that the scope of work
can be expanded to investigate other chemicals of concern and/or areas, based on
previous and future environmental sampling results.
Lead is the most widely detected constituent at concentrations above site screening levels
(SSLs) and background concentrations in media samples (soil, surface water, and
sediment) collected at the Site. In general, other constituents detected in media samples are
within the horizontal extent of lead detections or at a concentration within the same order
of magnitude of their respective background concentration. Elevated detections of lead are
one to two orders of magnitude above background concentrations. Lead therefore is the
primary constituent of concern, although a limited number of other constituents have been
detected above Ecological Risk SSLs.
We have added other chemicals of potential concern for Site media based on their
relevance to the manufacturing process and operations, or where there is an exceedance of
ecological risk site screening levels (SSLs). We have not included chemicals on the list
that are known to be naturally occurring at concentrations in media typically higher than
SSLs.
We propose flexibility in the approach to the work scope, to use previous and future
investigation results to provide meaningful direction to implementing the investigation.
We understand that additional investigation may be needed, based on the results of the
proposed work.
•
EPA COMMENTS
PART 1: EPA Comments by William N. O'Steen
EE/CA Workplan
•
l. A comment on the drafi EE/CA Workplan stated that the following wording from
Section 1. 1.4 needed to be changed: "Lead was not detected above the SSL in soil
samples collected in the vicinity of the acid storage tank area, and therefore. this
area is not considered a source area." 771e comment also stated that similar wording
in the fourth paragraph of Section 1.5 needed correction. The latter comment
mistakenly identified the problem as being in the fourth paragraph; actually, the third
paragraph of Section 1.5 required correction. The wording in Section 1.4.1 was
changed, but the wording in Section 1.5 has not been changed and thus still needs
correction.
Response: The last sentence of the third paragraph of Section 1.5 will be revised as
follows: "Lead was not detected above the SSL in soil samples collected in the
vicinity of the acid storage tank area and, therefore, this area does not indicate an
unacceptable level of impact with respect to a direct exposure to soil."
2. A comment on Section 2.1 of the drafi EE/CA Workplan stated that some delineation
of lead contamination in the subsurface to corcentrations below the 400 mg/Kg soil
screening level should be done. This investigation is needed to evaluate potential
subsurface lead (or other contaminant) transport mechanisms or attenuation
processes. Discussion on page 16 of the revised EE/CA (last paragraph under the
heading "Lead'') indicates that this additional work effort will be done. However, the
first "bullet" on page 14 implies that the delineation of lead contamination in soil to a
400 mg/Kg concentration minimum is still the intent of the field investigation. If this
language is to be lefi in the EE/CA Workplan. it should be qualified as being
designed to evaluate soil lead contamination for risk assessment purposes only.
AlternativeZv, the language could be changed, or another sentence added. to indicate
that the deeper subswface soil investigation will not terminate on the basis of a 400
mg/Kg lead criterion.
Response: The following text will be added after the last sentence of. the last
paragraph under the heading of Lead in Section 2.1.1.1 on Page 16: "The 5-foot
interval soil samples will be analyzed with depth until the lead concentration is equal
to or below the background concentration for lead."
2
•
3. Related to the comment in the previous paragraph, the proposal in Section 2.1.1.1 to
limit the depth of the subswface lead investigations at the two proposed potential
source area monitoring wells to 15 feet should be qualified to indicate that if soils at
that depth exhibit above-background lead contamination indicative of potentially
deeper contamination of significance, then deeper sampling for lead will occur.
Response: See response for EPA Comment # 2.
4. Consistent with a comment I had made in a review of the draft EE/CA Workplan. the
revised Workplan needs to indicate at least a potential that deeper monitoring wells
may be necessary in order to fully define the vertical extent of ground-waler
contamination. Such wells will be indicated if any of the proposed shallow
monitoring wells show that lead (or other contaminants) are present near the water
table above relevant and appropriate regulato1y standards or any risk-based
concentrations of concern. As noted in the referenced June 29, 2000 memorandum,
EPA Region 4 has experience at several other sites in hydrogeologic terrains similar
to the Johnson Controls site where the principal zone of ground-water contaminant
trallsport is in a transition zone between the saprolite and the bedrock. Thus,
monitoring of shallow wells placed downgradient from the potential source areas will
not be considered sufficient to define the extent of contamination if samples form the
two proposed source area wells show unacceptable contaminant concentrations.
Section 2.1.4 of the Workplan should specifically state that deeper monitoring wells
will be completed downgradient of the potential source areas, if significant ground-
water contamination is found near the waler table in the potential source areas.
Response: The following text will be added after the last sentence of last paragraph
of Section 2.1.4 on Page 21: "If analytical results indicate that a groundwater impact
has been detected at concentrations above ARARs or risk-based concentrations,
deeper monitoring wells may be installed downgradient of the potential source areas
to delineate the vertical extent of the impact."
5. My comments on the draft EE/CA Workplan included two recommended changes lo
the last paragraph in Section 2.1. The first of those changes has been made in the
revised Workplan; the seco!ld change has not been made. The second recommended
change was that the last paragraph of Section 2.1 needs to reference later sections of
the Workplan that provide more definition to the proposed PAH investiga1ions.
Response: The following text will be added after the last sentence of the paral,'Taph
under the heading of Semi-Volatile Organic Compounds in Section 2.1 on Page 15:
"The proposed P AH investigation is further discussed in Sections 2.1.1.1 and 2.1.3.1
under the heading Semi-Volatile Organic Compounds."
3
• 6. In the discussion on page 16 under the heading Semi-Volatile Organic Compounds,
the test in the next to last sentence has been corrected to address my concerns with
the draft Workplan. However, the additional language that has been added needs
some minor clarifying text. Specifically, the text should state (if intended) that further
soil sampling in any subsequent investigations will follow the same sample spacing
procedures as for the initial investigation.
Response: The following text will be inserted before the last sentence of the
paragraph under the heading of Semi-Volatile Organic Compounds in Section 2.1.1.1
on Page I 6: "Future P AH investigation activities will be conducted in accordance
with sample location rationale and procedures of the initial investigation described in
this EE/CA Workplan."
7. A comment on the draft Workplan concerned the Section 2.1.3.1 proposed TCLP lead
testing of sediments. The revised Workplan addresses that concern, but needs to
include a statement about the number of samples that would be tested. As I infer f,wn
this discussion, the proposed number of samples to be tested would be up to a
maximum of ten samples. The plan will be sufficient if the lead contamination is
found at a variety of concentrations that range as high as 3,000 mg/Kg. However, it
is possible there will be no sediments found within some of the specific concentration
ranges proposed for testing. For that condition, the number of samples tested could
conceivably be much fewer than ten. Some lower cutoff point for the number of
sediment samples to be TCLP tested should be presented, such that there will be a
meaningful number ofTCLP analyses of the sediments.
Response: The following text will be inserted after the last sentence of the second
paragraph under the headings of Sediment and Lead in Section 2.1.3. I on Page 19:
"If the range of lead concentrations detected in the sediment samples is not as high as
3000 mg/kg, a minimum of 6 sediment samples will be collected and analyzed for
TCLP lead."
PART 2: EPA Comments by Sharon Thoms
General Response
To address EPA's ecological risk comments, one step in the screening level ecological risk
assessment (i.e., comparison to Region 4 ecological SSLs) was performed for inorganic
analytes utilizing the existing soil, sediment, and surface water data for the Site. This
comparison to ecological SSLs was used to select a tailored list of TAL metals that would
be carried through in the Baseline Ecological Assessment for the Site. It should be noted
that other aspects of the screening level ecological assessment will be conducted during the
first phase of the investigation, such as the walk over of the Site to define ecological
habitats. This information will be used to complete the screening level ecological
assessment, which will be used as a point of discussion during the risk investigation
4
l r '
•
assessment scoping meeting, which is scheduled to be held after the first phase of the RI is
complete. At this meeting, the scope of the Baseline Risk Assessment will be discussed,
which includes both the human health evaluation and the ecological assessment. The scope
of the Baseline Ecological Assessment will be summarized in the Baseline Risk
Assessment Technical Memorandum, that will be issued after the scoping meeting has been
held.
Aside from the comparison to ecological SSLs, a. comparison to background inorganic
analyte concentrations was conducted to further focus the list of analytes to be carried
forward for analysis during the investigation. It is recognized that such a background
screen is usually conducted after the investigation, but it was considered that sufficient site-
specific and regional data existed to make this assessment now to focus the investigation on
the key inorganic analytes at the Site. The following is a summary of the results of the
ecological screening process, and comparison to background inorganic concentrations.
Lead is the most widely detected constituent at concentrations above site screening levels
(SSLs) and background concentrations in media samples (soil, surface water, and
sediment) collected at the Site. In general, other constituents detected in media samples are
within the horizontal extent of lead detections or at a concentration within the same order
of magnitude of their respective background concentration. Elevated detections of lead are
one to two orders of magnitude above ecological SSL and/or background concentrations.
Although lead is the primary constituent of potential concern, other constituents have been
detected above Ecological Risk SSLs or background during past investigations. As
presented on Table I of the EE/CA Workplan, the following constituents other than lead
were detected above their respective Ecological Risk SSL.
MEDIA Parameter Detected Above SSL
Soil Aluminum, cadmium, chromium, iron, manganese, thallium, vanadium, and zinc
Sediment Chromium, total mercury, nickel, and zinc
Surface \Vater Aluminum, iron. and total mercury
Of the parameters detected above their respective Ecological Risk SSL, the following
parameters have a calculated background concentration that is higher than the highest
detected concentrations within the area subjected to Ecological Risk Assessment (See
Table I of the EE/CA Workplan): aluminum (soil), chromium (soil), iron (soil), thallium
(soil), and vanadium (soil). It should be noted that aluminum and iron concentrations in
surface water were above site-specific background, but since they were not detected above
background in soil and sediment concentrations the exceedances of background in surface
water were not considered site-related.
The United States Department of the Interior Geologic Survey (USGS) conducted a study
titled the Chemical Analyses of Soils and Other Surficial Materials of the Conterminous
Uni1ed States that evaluated the naturally occurring elements concentration of soils through
out the conterminous United States. The soil samples from this study were collected at a
depth of approximately 8 inches representing surface soil and at locations approximately
· 50 miles apart. Although no soil samples were collected in Forsyth County as part of this
Study, three soil samples were collected from locations in other counties (Davies,
5
Randolph and Surry) in the vicinity of Winston-Salem. The analytical results of the three
samples are presented below:
Reported Values for Inorganic Elements for Soils in Central North Carolina
Parameter Sample Location
Davie Co. Randolph Co. Surry Co. (080350) Calculated Background
( 197750) (197650) mg/kg Johnson Controls SiteA
mg/kg mg/kg (mg/kg)
Soil Description Red Clay Yellow Clay with Stoney Residual on Sandy Loam and Red
quartz phyllite Clay
Aluminum 70,000 50,000 > 100,000 24,450
Chromium 70 15 100 58.25
Iron 50,000 30,000 I 00,000 32,450
Lead 20 NA 20 45.85
Manganese 1,000 200 700 602
Nickel 20 7 70 19
Thallium NA NA 10.67 5.3
Vanadium 150 70 150 77.17
Zinc 25 25 124 56.55
A -Background Concentrations were calculated as two times the mean of the background concentrations
:\'A -'.'iot Analyzed
The naturally occurring concentrations of elements in soil of the USGS study are consistent
with the background soil concentrations for the JCBGI Site. The USGS study indicates that
naturally occurring background concentrations of aluminum and iron in surface soils in the
general region can be much higher than the background concentrations found for the site.
Based on the background concentrations at the Site and the naturally occurring element
concentrations in the Winston-Salem Area from the USGS study, the following list of
parameters above Ecological Risk SSLs and background has been generated:
Proposed Analytical List
MEDIA Parameter Detected Above SSL and Background
Soil Cadmium, lead, manganese, and zinc
Sediment Chromium, lead, total mercury, nickel, and zinc
Surface Vlater Lead and total mercury
In response to EPA's comments for additional T AL metals analyses, JCBGI proposes to
analyze samples associated with ecological risk at the Site for the above mentioned
parameters (i.e., each sample will be analyzed for cadmium, chromium, lead, total mercury,
manganese, nickel, and zinc).
The EE/CA Workplan proposed to analyze soil and sediment for lead in the field using
XRF. In the light of the additional metals and P AH analyses requested by EPA, JCBGI
proposes to use an on-site laboratory capable of performing ICP metals, furnace metals,
6
•
and P AHs analyses. The benefit of on-site laboratory is rapid tum around time for sample
results for the expanded parameter list. The rapid tum around will enable an expedited
field evaluation of the potentially impacted soil and sediment, allowing additional sample
collection for delineation in limited mobilizations. Once the on-site laboratory field
measurements have defined the extent of impacted media, selected samples will be
submitted to a fixed analytical laboratory for validation of (and correlation to) the field
results. Approximately 15% of the soil, sediment, and surface water samples analyzed by
the on-site laboratory will be split for fixed laboratory validation, representing the range of
concentrations measured by in the field. The correlation of on-site and fixed analytical
laboratory results will be evaluated to assess that an acceptable relationship exists and if
additional laboratory confirmation analysis is required.
General Comments
I. A Screening-level Ecological Risk Assessment (SLERA) was conducted on the 199 7
data by NCDENR but not on the RMT data. The. SLERA results in Appendix A
indicate that several constituents detected in swface water. soil and sediment exceed
ecological screening values and should be characterized for the EE/CA. Swface
water is to be analyzed for lead only. Aluminum and iron have historically exceeded
their respective screening values in surface water. Aluminum and iron were widely
dispersed in environmental media in the vicinity of the site at levels above
background concentrations. The fact that surface water is elevated above ecological
screening levels indicates that Florida State standards may be exceeded for these
metals. The aluminum and iron present in soils and sediments may be in a form
available to cause toxicity to ecological receptors, given the solubility being great
enough to elevate the concentrations in swface water. All environmental media.
including swface water, should be sampled for TAL metals to resolve this issue.
Response: As discussed above in Montgomery Watson's General Response to Part 2
General Comments, a tailored list of T AL metals has been proposed for analysis at all
surficial soil sample locations in response to this comment. The tailored T AL list was
based on a comparison to Region 4 ecological screening values and comparison to
background concentrations. It should be noted that the data collected in areas which
are potential ecological habitat (not adjacent to the Facility) were used to perform this
screen. Based on this analysis, aluminum and iron are not present above background
concentrations in soil and sediment samples collected in areas that are potential
ecological habitats, and so these analytes will not be carried through during the
investigation.
It is assumed that the Florida State standards are referred to mistakenly in this
comment. Region 4 guidance provides that the Region 4 Waste Management
Division, Water Quality Standards Unit's Screening List, should be used as SSLs for
surface water. This screening list was developed by Region IV based on the
information provided in the USEPA's Water Quality Criteria documents, and
represent where available the ambient water quality standards (A WQC). Where an
7
• A WQC is not available for an analyte, information provided in the Water Quality
Criteria documents is used with a safety factor to derive a screening value for the
particular analyte.
In terms of solubility of iron and aluminum, the normal reducing conditions found in
wetlands can cause increased solubility of these metals in surface water. The
increased solubility of these metals in a reducing environment is a natural
phenomena, and is unlikely due to some other unnatural form of aluminum or iron
being present that creates the condition. As noted above, in areas of the Site that are
potential ecological habitat, the concentrations of aluminum and iron are within
background concentrations.
2. There was one mercwy hit in swface water for Sample JC-009-SW (August 11-13,
I 997). The detection limits for the non-detect samples were also elevated with
respect to the ecological screening value. Mercwy should be analyzed in the swface
water samples using a more sensitive detection limit.
Response: If the USEPA "Clean Hands/Dirty Hands" sampling method 1669 and
EPA analytical method 1631 are utilized, the reporting limit for mercury in surface
water should be attained (at least 12 ppt).
3. The data included in Appendix A show that a ve,y limited number of full scans were
conducted for the site. For example, it appears as if the only location apart from the
"source areas" where semi-volatile organic compounds were analyzed was at
JC-014-SL. While concentrations of lead are highest at JC-014-SL, other metal
constituents were detected at their highest concentrations in the soils of the other
basins, e.g., cadmium at JC-OJ 3-SL and aluminum and iron at JC-OJ 2-SL. It has
already been stated that the contaminant release mechanism for the semi-volatile
organic compounds is not expected to necessari(v be the same as for lead. Since
there is only one sample for semi-volariles in soils around one basin, additional
sampling should be undertaken. This sampling for PAHs should take place, not just
in the vicinity of JC-014-SD but also around the edges of the other two basins.
Response: We concur with the comment. The following text will be inserted after
the last sentence of the paragraph under the heading of Semi-Volatile Organic
Compounds in Section 2.1.3.l on Page 18: "Surface soil samples will be collected at
the previous investigation soil sample locations JC-012-SL and JC-013-SL and
analyzed for P AHs. If analytical results indicate that PAHs are detected at these
locations, additional P AH investigation activities will be conducted in accordance
with sample location rationale (i.e., 50-foot grid) and procedures as described
Section 2.1.l.l in the EE/CA Workplan."
8
• •
4. The data in Appendix A do not show any analysis for pesticides and PCBs. A limited
number of full scan samples are needed to rule this class of chemicals out as
chemicals of potential concern at Johnson Controls Site.
Response: JCBGI began operations at the property in 1978. Prior to that time the
property was undeveloped. Pesticides and PCBs were not historically used at the
facility. Therefore, these chemicals should not be considered potential concerns at
the Site and not sampled/analyzed as part of this EE/CA. However, PCB and
pesticides analyses have been included in the TCL organics analyses on the sediment
sample (JC-SD-33) to be collected in the vicinity of the trailer maintenance building.
5. Some of the background locations shown on 'Figures 3 and 5 are potentially impacted
by the'site and should be re-located. Background stations SBBG-02, SBBG-03, and
SBBG-04 are located in the flood plain of Lowery Mill Creek downstream from the
tributaries to the creek leading from the basins. These sample locations should be re-
located farther upstream into the tributaries, which are located on the opposite side
of the creek fiwn the site. The expected flow path from the unnamed tributm)'
leading from Basins 2 and 3 is to the outside bend in the creek, directly into the areas
chosen as background locations. Positioning on the opposite bank of Lowery Mill
Creek is insufficient to ensure that locations have not been impacted. Thus, it cannot
be concluded that the proposed backgrounds stations are unimpacted by the site.
Background sampling locations should be located outside the 100-year flood plain of
Lowery Mill Creek. There should be background surface water and sediment
samples to represent the main channel of a creek similar to Lowery Mill Creek and
there should be other background surface water and sediment samples to represent
the flood plain wetlands. The text should be re-written to indicate which background
stations will represent the wetlands, which background stations will represent the
main stream channel, and which background stations will represent the swface water
and sediment of the basins. Appropriate background stations should be chosen to
serve as a referencefor each type of water body.
Response: We concur with the comment. The proposed background sample
locations will be moved upgradient on the tributaries to ensure that they are outside of
the 100-year flood plan. The text in the second bullet in Section 2.1.6 on Page 22
will be revised as follows: "Seven surface water and sediment samples will be
collected from locations (JC-SWSB-01 through JC-SWBG-07) that have not been
impacted by Facility operations. One background sediment and surface water sample
will be collected from a location (JC-SWSB-01) on Lowery Mill Creek up gradient of
the Site and will represent the background sediment and surface water of the main
stream channel. One background .sediment and surface water samples will be
collected from location (SWBG-3) in the first wetland area on Lowery Mill Creek
upgradient of the wetland area below sedimentation basins #2 and #3 and will
represent background of the flood plain wetlands. Background sediment and surface
water samples will be collected from locations (JC-SWSB-02, JC-SWBG-04 through
JC-SWBG-06) on tributaries located on the opposite bank of Lowery Mill Creek from
9
• the Site and up gradient of the I 00-year flood plain. These samples will represent
background of the unnamed tributaries. The final background surface water sample
(JC-SWSB-07) will be collected from the above mentioned western branch of Salem
Lake. The background surface water samples will be analyzed for T AL inorganics,
dissolved lead, and hardness. Because there will be no background sample collected
for the sedimentation basins, the background sediment and surface water for the
basins will be calculated from all the other background samples (flood plain wetlands,
unnamed tributaries, and main channel). The text and figures will be revised
accordingly."
Note that the sample location SWBG-3 (Figure 5 in the EE/CA Workplan) will be
moved from the tributary to Lowery Mill Creek to the first wetland area on Lowery
Mill Creek upgradient of the wetland area below sedimentation basins #2 and #3.
Figure 5 will be changed accordingly.
In addition, the text in the third sentence of the first bullet of Section 2.1.6 on Page 22
will be revised as follows: "The proposed sample locations JC-SBBG-02 through
JC-SBBG-04 are located on the opposite side of Lowery Mill Creek from the Site and
up gradient of the I 00-year flood plain. Therefore, these locations are not likely
impacted by Facility operations.
6. Additional XRF samples are needed to ensure that depositional zones are targeted. A
sediment/soil sampled should be taken in a flood plain depositional zone downstream
of the delta from the unnamed tributary leadingfiwn Basin 1. Any sediments that do
not deposit in the wetlands receiving direct inputs from the unnamed tributary may be
carried downstream to the next wetland depositional area. Sampling is needed to
characterize the downstream wetlands as well as the main channel of the creek.
Sediments from the contaminated wetlands may have eroded and been transported
downstream to other wetlands, which have not been sampled.
Response: The initial phase of investigation activities are focused on evaluation of
lead-impacted media from the potential source areas to the two wetland areas below
the sedimentation basins.
The following sentence will be added after to the end of the last paragraph in Section
1.5 on Page I 3: "If the initial phase investigation results indicate that Lowery Mill
Creek is potentially impacted, additional assessment (including assessment of Lowery
Mill Creek) will be addressed in subsequent investigations."
7. Screening values fiwn sources other than Region 4 are proposed for use in the
SLERA. Alternative values may be used in the Step 3, Problem Formulation,
refinement of chemicals of potential concern. The actual screening-level assessment
(Steps 1 and 2) should be pe1formed using the Region 4 screening values alone.
Screening values for total PAHs should not be used as a surrogate for PAH
10
r
•
compounds lacking Region 4 screening values. The total PAH screening value
_ should be used lo screen the sum of PAH concentrations in each sample. Background
screening should occur in the Step 3, Problem Formulation, Refinement of COPCs
step. As alternative screening values are proposed for use, these values should be
provided to EPA/or review and approval in the EE/CA Workplan.
Response: In regard to the use of alternate screening values, the third paragraph in
Section 3.4 will be changed to read as follows:
"For the screening level ERA, the ecological screening values obtained from the
summary tables on the Region 4 website (i.e.,
http://www.epa.gov/region04/waste/oftecser/ecolbul.htm) were used to perfonn the
screening assessment conducted as part of this Work Plan development.
In regard to the P AH screening values, total P AH screening values were applied to
individual P AHs in the SLERA. The total P AH screening value was only used to
screen total P AH concentrations.
Background screening has been performed during the development of this Workplan
to focus the RI investigation on those chemicals that are clearly above background
concentrations at the site. Additional background screening will occur as part of the
problem formulation step of the baseline ERA.
Specific Comments:
I. Section 1.4, Previous Investigations. Page 8. fourth bullet. Text should be revised. It
is possible that the opposite side of the creekji-o,n the facility could be impacted. See
General Comment 5.
Response: The third and fourth bullets of Section 1.4 on Page 8 will be replaced
with the following text:
, "The North Carolina ES! stated that sample locations JC-010, JC-011, .JC-013,
JC-014, JC-015, JC-016, and JC-017 were control sample locations to evaluate
whether any alternate sources that may be discharging to Lowery Mill Creek.
These control samples were considered background locations. A review of the
ES! sample trip notes does not give a clear indication of the exact location of
control sample collection relative to the wetland and floodplain of Lower Mill
Creek. In addition, figures from the ES! do not show the location of samples JC-
010, .JC-011, JC-013, and JC-014 and figures from the Response to NCDENR ES!
(by Gradient Corp.) only show the control sample locations based on descriptions
provided in the ES!. From the Gradient Corp Figure (See Appendix A of the
EE/CA Workplan), it appears sample locations JC-010, JC-011, and JC-017 are
outside of the 100-year flood plain and, therefore, they will be used for the
determination of background sediment and surface water concentrations. In
contrast, since is not clear if the remaining san1ple locations (JC-013, JC-014,
11
• • JC-015, and JC-016) are within or outside of the floodplain, these locations will
not be used for either the determination of background concentrations or
evaluation of constituents of concern."
Table 2 "Background Concentrations" will be revised to incorporate the above
mentioned changes. In tum, Table 1 "Summary of Constituents Detected Above
SSLs" will be revised to add corrected background concentrations.
2. Figure 5, Proposed Background Sample Locations. The figure should be revised to
show sample location SBBG-07. If it cannot be shown on this figure, another figure
should be added.
Response: The reference to sample location SBBG-5 located on an unnamed
tributary of Lowery Mill Creek (Figure 5 of the EE/CA Workplan) is incorrect. The
correct reference should be SWBG-5. There is no sample location SBBG-07. The
figure will be corrected accordingly.
3. Table 2, Background Concentrations. Some of the concentrations listed are not
appropriate as background because they are from stations downstream of the site.
See General Comment 5.
Response: See response to Specific Comment # l. Previous investigation samples
JC-013, JC-014, JC-015, JC-016 and JC-017 are located down gradient of the Site.
Sample location JC-017 is located on the opposite side of Lowery Mill Creek outside
of the 100-year flood plain and, therefore, will be used for the determination of
_ background sediment and surface water concentrations. In contrast, since _it _is not
clear if sample locations (JC-013, JC-014, JC-015, imd JC-016) are within cir outside
of the floodplain, these locations will not be used for either the determination of
background concentrations or evaluation of constituents of concern. The table will be
revised to reflect changes.
4. Section 2.1.3, Further Delineation of Migration Pathways, Page 18. The section
indicates that soil samples adjacent to the basins will be delineated for lead to the
SSL of 50 mg/kg. A limited number of TAL scans are proposed, however, they are
only proposed for one 6-inch interval with the highest XRF reading would be
analyzed for the full metal scans. The proposed subswface soil samples are valuable
to characterize the vertical extent of contamination. For the ecological risk
assessment, horizontal delineation for TAL metals above ecological screening values
is also needed. (The top 6 inches of soil can provide a swface soil sample.) 17,e
utility of the proposed approach is questioned as the 1997 data already ·includes TAL
metal scans by both the state and RMT at the previous sampling locations. If the
highest concentrations are in the swface interval, then the study will simply repeat
the 1997 data. Since, the 1997 results clearly indicate that constituents other than
lead exceed the ecological screening values at these locations, all the samples around
12
0 • JC-013-SL (SB-28 through SB-31) and all the samples around JC-014-SL (SB-23
through SB-26) should be analyzed for TAL metals in swface soils. The current
proposal is that only one 6-inch interval of a soil core form SB-22 and SB-27 will be
evaluated for TAL metals.
Response: The following text will replace the two paragraph under the headings Soil
and Lead in Section_2.J.3.l on Page 18: "Surface soil samples will be collected at
locations on a 50-foot grid centered on previous investigation soil sample locations
JC-012-SL (SB-33 through SB-36), JC-013-SL (SB-28 through SB-31), and JC-014-
SL (SB-23 through SB-26) for horizontal delineation. The soil samples will be
analyzed for the proposed Ecological Risk Parameter List (i.e., each sample will be
analyzed for cadmium, chromium, lead, total mercury, manganese, nickel, and zinc)
using an on-site laboratory. In addition, soil samples at depth will be analyzed at
each of the previous investigation soil sample locations (JC-012-SL, JC-013-SL, and
JC-014-SL) for vertical delineation. If the on-site laboratory results indicate that a
parameter is above an SSL, additional investigation activities will be conducted in
accordance with sample location rationale (i.e., 50-foot grid) and procedures as
described Section 2.1.1.1 in the EE/CA Workplan."
Surface soil sample locations SB-33 through SB-36 will be added to Figure 3.
The proposed Ecological Parameter List is presented in the General Response to EPA
Comment by Sharon Thomas.
5. Section 2.1.3. Further Delineation-of Migration Pathways, Page 18. Since PAHs in
soils are only analyzed in 1997 at JC-014-SL, there is no reason to think that the
other two basins do not have elevated PAHs in their soils. The analysis of soil PAHs
should be for soils around all three basins.·--Currently no sampling"-of soils ·is
proposed for the area around Basin 3, although JC-012-SL had the highest
concentrations of 15 metals (aluminum, arsenic, barium, beryllium, calcium,
chromium, cobalt copper, iron. magnesium, manganese, nickel, potassium. thallium,
an vanadium) relative to the soils adjacent to the other two basins_ Although all 15
metals are not elevated with respect to soil screening levels, this finding indicates
that the area around Basin 3 has been effected by activities at the site. Since soils
near Basin 3 have not been analyzed for PAHs, PAH analysis CJ( soils around Basin 3
should be added to the work effort. TAL metals should also be analyzed at the basins.
Response: P AHS are addressed in General in Comment #3 and T AL metals are
addressed in Specific Comment #4.
6. Section 2.1.3, Further Delineation of Migration Pathways, Unnamed Tributa,y,
Page 20. For the ecological risk assessment the characterization should provide
information on the areal extent of contamination in su,face sediments of constituents
with concentrations exceeding screening values. Subswface sediment samples can
delineate the vertical extent of contamination for TAL metals, however, the current
13
• • plan fails to delineate the horizontal extent of contamination for constituents other
than lead. Samples in the vicinity of the 1997 samples JC-004-SD, JC-006-SD, and
JC-007-SD should be analyzed for TAL metals to complete the horizontal delineation
for the risk assessment. This would include samples SD-13 through SD-15 and
SD-21 through SD-30.
Response: The second to last paragraph under the headings Sediment in Section
2.1.3.2 on Page 20 will be revised as follows: "Surface sediment samples will be
collected at locations on a 50-foot grid centered on previous investigation sediment
sample locations JC-006-SD (SD-27 through SD-30), and JC-07-SD (SD-22 through
SD-25) for horizontal delineation. Two sediment samples (SD-13 and SD-14) will be
collected within 50 feet of previous investigation sediment sample (.JC-004-SD); one
sample upstream and one sample downstream. The soil samples will be analyzed for
the proposed parameter list (i.e., each sample will be analyzed for cadmium,
chromium, lead, total mercury, manganese, nickel, and zinc) using an on-site
laboratory. In addition, soil samples (SD-21 and SD-26) at depth will be analyzed at
each of the previous investigation soil sample locations (JC-006-SD and JC-007-SD)
for vertical delineation. If the on-site laboratory results indicate that a parameter is
above an SSL, additional investigation activities will be conducted in accordance
with sample location rational (i.e., 50-foot grid) and procedures as described
Section 2.1.3.2 in the EE/CA Workplan."
The proposed Ecological Parameter List is presented in the General Comment
7. Section 2.1.3, Further Delineation of Migration Pathways, Unnamed Tributmy.
Page 20. The basin sediments should be analyzed for TAL metals and PAHs at all
locations .. This includes SD-OJ through SD-04, SD-05 through SD-08, and SD-09
.through· SD-Fi: Historical"daia is not available to· assess potential risk for these
basins. This data gap should be addressed by sampling.
Response: The following paragraph will replace the first paragraph under the
headings Sediment and Lead in Section_ 2.1.3.1 on Page 18: "Sediment samples
collected at locations SD-0 I through SD-12 will be analyzed for the proposed
parameter list (i.e., each sample will be analyzed for cadmium, chromium, lead, total
mercury, manganese, nickel, and zinc). The sedimentation basins will be divided into
quadrants and sediment samples will be collected from each quadrant at 6-inch
intervals until the basin bottom is reached. If on-site laboratory analytical results
indicate that a parameter impact is above an SSL in a sediment sample, the successive
6-inch intervals will be analyzed until the parameter concentrations fall below the
SSL or the bottom of the basin is reached. Proposed sediment sample locations are
shown on Figure 3.
The proposed Ecological Parameter List is presented in the General Comment.
Sediment samples will be collected and analyzed with depth until P AH
concentrations fall below their respective SSLs at one location in sedimentation basin
14
8.
• • # I (See Section 2.1.3.1 under heading Sediment). As discussed in the response to
General Comment # 3, soil samplJs above sedimentation basins # 2 and # 3 will be
collected and analyzed for P AHs.
The following paragraph will be inserted after the paragraph under the headings
Sediment and Semi-Volatile Organic Compounds in Section_2.l.3.l on Page 18: "If
on-site laboratory analytical results indicate that P AHs are present in a soil sample,
sediment samples will be collected from the corresponding sedimentation basin using
the sampling rationale and procedures (same as sedimentation basin #I) discussed in
Section 2.1.3. l of the EE/CA Workplan."
Table I.I, Summa,y of Sampling Locations and Analysis, Field Sampling Plan. The
table indicates that only XRF samples will be collected for swface soil and swface
sediment. A certain percentage of laboratory samples are necessa,y to confirm the
XRF analysis. XRF is a field screening technique to detect areas of relative lead
enrichment. As the response of XRF may differ depending on the type of lead at the
site, confirmato1y sampling is necessary to define the XRF results. Also. the
background stations to be analyzed for TAL metals and not XRF. The current
sampling design will provide an inconsistent data set, which will not permit a
comparison of site samples with background. Not TAL analyses are proposed for
swface soils and sediments (only subsurface). This deficiency should be corrected.
Response: See General Response Comment. The EE/CA Workplan proposed to
analyze soil and sediment for lead in the field using XRF. In the light of the
additional metals and P AH analyses requested by EPA, JCBGI proposes to use a on-
site laboratory capable of performing ICP metals, furnace metals, and P AHs analyses.
M:'~obs\1242\179\ 16\wp\rpt\91 EPA Comments.doc
15
• NC DENR COMMENTS
PART3
General Comments
I. Analyses of Volatile Organic Compound (VOC) and Target Analyte Compounds
(Including RCRA Metals) should be comprehensive for soil and groundwater
samples.
Response: As stated in the SOW (Task 2, Site Characterization), the overall objective
of Site Characterization is to use existing data and collect additional data to describe
areas of the Site that may pose a threat to human health or the environment. Previous
investigations, including the 1997 Expanded Site Inspection (ESI) by NCDENR have
extensively evaluated Site conditions. To achieve a comprehensive understanding of
the nature and extent of the contamination at the Site, this EE/CA Workplan
employed the existing data from the previous investigations to outline a more
focused, expedient, and effective investigation.
The ES! concludes that lead is a concern at the Site. VOCs were not identified by the
State as a concern. Given that JCBGI manufactures batteries at the Site and the
primary raw material is pig lead, we are focusing primarily on the effects of lead in
the environment. Our analysis of the data indicates that P AHs and other metals were
also present from the ES! analysis, but generally not VOCs. These results are also
reflected in our approach to the investigation, as we are including P AHs and other
metals. We do not have an identified source of P AHs at the Site, but it is known that
other metals occur in the raw pig lead, and so their fate and migration will be similar
. _to that .of the lead at the Site ... Occurrences. o.f 9th er metals were generally.in the ---·-- -. --.. . --
presence of lead.
To address NCDENR concerns, the following additional investigation activities were
added to the Workplan:
• The previous investigations did not assess the potential for environmental impact
associated with operations at the trailer maintenance Building. Therefore, one
sediment sample (.JC-SD-33) will be collected downgradient of the trailer
maintenance building in an apparent storm water runoff pathway to assess
potential environmental impact and analyzed for target compound list (TCL)
organics and target analyte list (T AL) inorganics scans. In addition, a
groundwater sample will be collected in the vicinity of the building and analyzed
forVOCs.
• Although no VOCs were detected during the previous investigations, four soil
samples will be collected at the 4-foot interval at locations JC-SB-01, JC-SB-05,
JC-SB-11, and JC-SB-14 and will be analyzed for VOCs to evaluate potential
environmental impact at depth in the source areas.
16
•
2. The State Project Manager (PM) for the NC Supe1fund Section would like to meet
with JCBGI representatives at the Facility to develop a better understanding of where
specific releases took place. Where was the 3,000 gallons of sulfuric acid spilled,
lead oxide dust released to 1 acre, and 1,000 gallons of lead oxide and lead sulfate
wastewater spilled?
Response: After conferring with JCBGI, there apparently are no employees left at
the plant with specific knowledge of the release incidents. JCBGI will attempt to
contact previous employees who may have knowledge of these release incidents.
3. If new or additional information leads to a better understanding of lead deposition or
where the releases took place additional soils borings may be requested by the
agencies.
Response: Comment acknowledged.
Specific Comments
I. The NC DENR acronym in the 3rd and 4th paragraphs on page 11 and on page 1-10 of
the QAPP is not correct. Please make corrections.
Response: We have corrected the spelling for State agency.
2. The first paragraph on page 17 indicates that VOCs will be coUected at the 4-foot
interval in --4 pi-oposed borings adjace1it · ici the facility: · As discussed in our
co11ference call on August 16 all a11alyses completed to date have bee11 on swface
soils at depths less than 1 foot. For the EE/CA work to be reaso11ably representative
and comprehensive subswface soils in the four borings 11oted 011 page 17 and in
JC-SB-08 would be required. If soil transitions from fill to residual soil it is
requested that this transition soil be sampled and analyzed for VOCs also. All soil
boring samples should also be screened usi11g an OVA. If OVA readings above
background are noted additional samples should be collected and sampled for VOCs
and SVOCs.
Response: The text in the paragraph under the heading Volarile Organic Compounds
on page 17 will be revised as follows: "Although no VOCs were detected during the
previous investigations, five soil borings JC-SB-01, JC-SB-05, Je-SB-08, .JC-SB-11,
and Je-SB-14 will be sampled to 4-foot to evaluate potential environmental impact at
depth in the source areas. Soils will be segregated into 6-inch intervals and screened
in the field using an OVA: If OVA reading are above background· for a 6-inch
interval, the interval will be collected for laboratory analyses of voes. If a soil
transition from fill to residual soil is observed, a sample will be collected from the
transition zone and analyzed for voes. If neither OVA readings are detected or a
17
• soil transition is encountered, the soil sample from the 4-foot interval will be
collected and analyzed for voes."
3. The 3'd paragraph on page 21 indicates that groundwater samples will only be
analyzed for SVOCs and RCRA metals. As we previously discussed with the JCBGI
contractor all groundwater samples should be tested for TAL Metals as well as TCL
Volatile Organic Compounds (VOCs) and SVOCs. If the groundwater data is
consistent with the facility histo1y/chemical usage then Contaminants of Concern
(COCs) can be estimated to specify the groundwater contaminant analysis.
Response: Historical soil and sediment data, along with knowledge of Facility
manufacturing processes, were used to evaluate appropriate groundwater analytical
parameters. As indicated from historical data, voes were not detected above the
method detection limit in soil, surface water or sediment samples collected at the Site,
with the exception of methyl ethyl ketone (MEK). MEK was detected in one
sediment sample (JC-006-SD) collected near Lowery Mill Creek. Because MEK was
not detected in other environmental samples collected at the Site and is not
historically used at the Facility, it is not believed to be associated with Facility
operations. Toluene was detected at an estimated concentration (below method
detection limits) in one soil sample and several sediment samples collected at the
Site. The NCDENR ES! states that toluene was reported in the soil trip blank at a
concentration below the contract required detection limit (CRDL) and is a possible
lab artifact. Because of the toluene detection in the trip blank, toluene was not used
in evaluating a release in any of the soil or sediment. Because VOCs were generally
not detected in soils and sediments that are associated with Facility operations, VOCs
are not proposed for analyses of groundwater samples.
SVOCs are included in the groundwater analyses, because as th~ historicaf data
indicate, several SVOCs were found in sediment and soils at the Site that exceeded
the standards to which the results were compared.
RCRA metals were chosen, in part, because the RCRA metals suite generally
represents the metals of concern at the Site. Based on previous sampling and
NCDENR ES! results, lead is the main metal of concern at the Site, which reflects its
use in the battery manufacturing process. Other metals are trace constituents (totaling
less than ½ %) in the pig lead, which is used in the battery making process. Given
that these other metals are minor inclusions in the pig lead, their distributions in the
environment will generally mimic the lead distribution in much smaller proportions.
As previously discussed as part of the August I 6 conference call between NCDENR,
EPA, and JCBGI, NCDEJ\TR requested VOC analyses on the groundwater sample to
be collected· in. the vic"in11y of the· trailer maintenance facility and agreed that this,
along with the additional VOC soil sampling and analyses discussed in the response
to Specific Comment #1, would address NCDENR concerns associated with VOCs at
the Site.
18
•
4. The second paragraph on page 21 states that "Groundwater samples will be collected
using slow purge sampling techniques". Slow purge methods may be used consistent
with EPA guidance but must maintain a rate sufficiently fast enough to assure that
the groundwater within the screened interval of the well is such that the entire
column of water is purged not just the area around the pump or inlet pipe. The pump
or extraction tubing must also be placed near the bottom of the well. If micro
purging is desired groundwater samples must be collected at 18 to 24 inch intervals
throughout the water column.
Response; A sufficiently fast enough pumping rate will be maintained to assure that
the groundwater within the screened interval of the well is such that the entire column
of water is purged not just the area around the pump or inlet pipe.
Sampling and Analysis Plan
1. The distribution list at the front of the SAP provides 2 copies of documents to NC
DENR. Please provide 3 copies since the County Environmental Affairs Department
has requested to receive copies of the work documents.
Response: The text in the front of the SAP will be revised to provide 2 copies of the
document to NCDENR and 3 copies to the County Environmental Affairs
Department.
2. The 3rd paragraph on page 7 indicates that "surging" will be done during pumping and
deveLoping the wells. This is not a standard procedure. during development of wells.
What will be used to surge wells and how is the surging process done?
Response; Surging is a common technique used to develop monitoring wells by
forcing water to flow into and out of a screen versus pumping or bailing which pulls
water through a well screen in only one direction. Surging increases the removal of
silt and clay size particles from the sand pack. Surging can be performed by using a
mechanical plunger up and down the well casing, similar to a piston in a cylinder.
Another way to surge a well is using compressed air to lift the water in the well to the
surface (i.e. development) and shut off the air to cause the water column to fall and
surge through the well screen. For the development of the wells, one of the above
mentioned surging methods likely will be employed.
19
• Quality Assurance Project Plan
1. All State ARARs should be listed on page 1-6 as noted in the comments on the Draft
EE/CA. State ARARs should include as a minimum:
NC Groundwater standards, NCA C Title 15A, Chapter 2, Subchapter 2L
NC Water Pollution Control Regulations, NCAC Title 15A, Chapter 2,
Subchapter 2H.
NC Water Quality Standards. NCAC Title 15A, Chapter 2, Subchapter 2B.
NC Air Pollution Control Requirements, NCAC Title 15A, Chapter 2.
Subchapter D and 2H NC Solid Waste Management Rules, NCA C Title 15A,
Subchapter 3B.
NC Hazardous Waste Management Rules, NCAC Title 15A, Subchapter 13A.
NC Sedimentation Control Rules, NCA C Title 15A, Chapter 4.
Many of the Site ARARs in this list can be screened out during the remedy design
process or in the comparative analysis process.
Response: Table 1-1 of the QAPP lists ARARS for media sampled during the
EE/CA and compares those ARARs with reporting limits. All applicable state
standards were reviewed and compared with Region 4 EPA criteria. The more
stringent standard is reflected in Table 1-1. State ARARs are not listed for media
which are not included in the EE/CA, because there are no sample results to compare
to those ARARs.
2. Groundwater sampling of monitoring wells on page 1-11 should be changed to be
consistent with comment #6 above.
Response: Comment# 6 (now Sampling and Analysis Comment #1) is not relevant
to monitoring wells.
3. The Reporting limits noted on page 7-1 and listed in Table 1-1 of the QAPP need to
be updated. Lower levels can now be achieved. VOCs in the aqueous phase samples
can now achieve 1 ug/1.
Response: If a 25 ml sample volume is used, VOCs can be reported to 1 ug/L. The
laboratory will be asked to provide the best reporting limits available for the methods
requested.
4. Table 1-1 lis1s .reporting limits and ARARs for all chemicals. This Table is ve1y
.. confusing and should.be separated into 4 different tables (soil, sediment, swface
water, and groundwate1).
Response: Table 1-1 was assembled as a comprehensive resource that provides
information at a glance about all potentially applicable standards. We believe that
20
i f
I t.
5.
• separating Table 1-1 into component media tables would not be any more effective
than the current presentation.
General and specific comments noted above should be corrected in all associated
Table and Figures and in all the related text of the EE/CA, SAP, and QAPP as
appropriate.
Response: Comment responses will be incorporated in appropriate sections of each
document.
DWH/vlr/DSI3/SGW/MWK/DWH
M:\jobs\1242\1 79\16\wp\rpt\9\ EPA Comments.doc
1242179.16 J 20101-MAD-1
21
• • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4WD-NSRB
Mr. Grover Nicholson
ChicC Superfund Section
NCDEHNR. Suite 150
40 I Oberlin Road
Raleigh, NC 27605
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
June 13. 2000
SUBJ: Johnson Controls Superfund Site
Winston-Salem, North Carolina
Engineering Evaluation/Cost Analysis (EE/CA)
Dear Grover:
R£c£1v1::o
JUN l 4 zooo
SUPERFUNo SECTtoN
?!ease find enclosed a copy of the Draft EE/CA \Vork Plan, Sampling and Analysis
Plan and Health and Safety Plan for the above-mentioned site. The scope of the EE/CA
includes:
Dete1mine if groundwater is a media of concern; ,.
* Detennine the extent of soil. sediment and groundwater (if applicable) contamination; and
* Prepare a human and ecological risk assessment.
Please review and send any comments by July 3, 2000. If you have any questions or if you
anticipate any problems meeting this deadline, please contact me at 404/562-8807.
SincP•1 'L>W--
\~~
roJect Manager
Enclosures
Internet Address (URL) • http://www.epa.gov
RecyCled/Aecyclable • Printed with Vegetable OIi Based Inks on Recycled Paper (Minimum 30% Postconsumer)
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
6 I Forsyth Street, 11th Floor
Atlanta, Georgia 30303
NORTH IROLJNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
September 13, 2000 01v1s10N oF WAsTE MANAGEMENT
RE: Comments on the Revised Final Engineering Evaluation/Cost Analysis Work Plan,
all Media
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000.770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Flores:
The Revised Final Engineering Evaluation/ Cost Analysis (EE/CA) Work Plan,
Sampling and Analysis Plan and Health and Safety Plan, dated June 2000, for all media
of concern at the Johnson Controls Battery Facility, located in Winston-Salem, NC has
been received and reviewed. The following comments by the North Carolina Superfund
Section are submitted for your consideration. If additional discussion is required for the
following comments please schedule a meeting or conference call with J CBG
representatives and the NC Superfund Section. ·
Engineering Evaluation /Cost Analysis Work Plan
General Comments
Analyses of Volatile Organic Compound (VOC) and Target Analyte Compounds
(including RCRA Metals) should be comprehensive for soil and groundwater
samples.
The State Project Manager (PM) for the NC Superfund Section would like to meet
with JCBG representatives at the Facility to develop a better understanding of
where specific releases took place. Where was the 3000 gallons of sulfuric acid
spilled; lead oxide dust released to I acre,. and 1000 gallons oflead oxide and lead
sulfate wastewater spilled?
If new or additional information leads to a better understanding of lead deposition
or where the releases took place additional soil borings may be requested by the
agencies.
Specific Comments
4. The NC DENR acronym in the 3'd and 4lh para!!raohs on oage 11 and on oa!!e 1-10
-a'o1 'oeERL.IN "RoAo, surTE 1 so, RAlE1b'k NC 27605
PHONE 919-733•4996 FAX 919•715•3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· SO% RECYCLED/10% POST-CONSUMER PAPER
· Mr. Luis Flores
9-13-2000
Page 2 of3
•
5. of the QAPP is not correct. Please make corrections.
•
6. The first paragraph on page 17 indicates that VOCs will be collected at the 4-foot interval in 4
proposed borings adjacent to the facility. As discussed in our conference call on August 16 all
analyses completed to date have been on surface soils at depths less than 1 foot. For the
EE/CA work to be reasonably representative and comprehensive subsurface soils in the four
borings noted on page 17 and in JC-SB-08 would be required. If soil transitions from fill to
residual soil it is requested that this transition soil be sampled and analyzed for VOCs also.
All soil boring samples should also be screened using an OVA. If OVA readings above
background are noted additional samples should be collected and sampled for VOCs and
SVOCs.
7. The 3'd paragraph on page 21 indicates that groundwater samples will only be analyzed for
SVOCs and RCRA metals. As we previously discussed with the JCBG contractor all
groundwater samples should be tested for T AL Metals as well as TCL Volatile Organic
Compounds (VOCs) and SVOCs. If the groundwater data is consistent with the facility
history/chemical usage then Contaminants of Concern (COCs) can be established to specify
the groundwater contaminant analysis.
8. The second paragraph on page 21 states that "Groundwater samples will be collected using
slow purge sampling techniques". Slow purge methods may be used consistent with EPA
guidance but must maintain a rate sufficiently fast enough to assure that the groundwater
within the screened interval of the well is such that the entire column of water is purged not
just the area around the pump or inlet pipe. The pump or extraction tubing must also be
placed near the bottom of the well. If micro purging is desired groundwater samples must be
collected at 18 to 24 inch intervals throughout the water column.
9. The first paragraph on page 31 indicates that the EPA will review and comment on any
needed Treatability Studies. The NC DENR representative should also review and comment
on these and any other site related documents. Please make appropriate changes.
Sampling and Analysis Plan
10. The distribution list at the front of the SAP provides 2 copies of documents to NC DENR.
Please provide 3 copies since the County Environmental Affairs Department has requested to
receive copies of the work documents.
11. The 3'd paragraph on page 7 indicates that "surging" will be done during pumping and
developing the wells. This is not a standard procedure during development of wells. What
will be used to surge wells and how is the surging process done?
12. Quality Assurance Project Plan
P.O. Box 29603. Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
-
· Mr. Luis Flores
9-13-2000
Page 3 of3
• •
. l3. All State ARARs should be listed on page 1-6 as noted in the comments on the Draft EE/CA.
State ARARs should include as a minimum:
NC Groundwater standards, NCAC Title 15A, Chapter 2, Subchapter 2L;
NC Water Pollut.ion Control Regulations, NCAC Title 15A, Chapter 2, Subchapter 2H
NC Water Quality Standards, NCAC Title 15 A, Chapter 2, Subchapter 2B
NC Air Pollution Control Requirements, NCAC Title 15A, Chapter 2, Subchapter 2D and 2H
NC Solid Waste Management Rules, NCAC Title 15A, Subchapter 13B
NC.Hazardous Waste Management Rules, NCAC Title 15A Subchapter 13A.
NC Sedimentation Control Rules, NCAC Title I SA Chapter 4
Many of the State ARARs in this list can be screened out during the remedy design process or
in the comparative analysis process.
14. Groundwater sampling of monitoring wells on page 1-11 should be changed to be consistent
with comment #6 above.
15. The Reporting limits noted on page 7-1 and listed in Table 1-1 of the QAPP need to be
updated. Lower levels can now be achieved. VOCs in the aqueous phase samples can now
achieve I ug/L
16. Table 1-1 lists reporting limits and ARARs for all chemicals. This Table is very confusing and
should be separated into 4 different tables (soil, sediment, surface water, and Groundwater).
17. General and specific comments noted above should be corrected in all associated Tables and
Figures and in all the related text of the EE/CA, SAP, and QAPP as appropriate.
The State appreciates the opportunity to comment on this document and we look forward to working
with you on the project. If you have any questions or comments, please call me, at [phone],
extension 341.
Sincerely, (n
~~-.¼1~~i~
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equil.l Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
• • Ef/CA
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
September 6, 2000 oivis10N oF WASTE MANAGEMENT
· llli.!1R,I'"·-: Memorandum ~~--.. , ·" i/(s:· TO: Van Sullivan . :,
\,~.~.AMEs_e:•Hu~;-}
NOR
}\ ;,· ·-
. 'i· < "J•\
From:
Co Environmental Affairs Department
537 North Spruce Street
Winston-Salem, NC 27101
Randy McElveen
Environmental Engineer
NC Superfund Section
RE: Final Engineering Evaluation/Cost Analysis (EE/CA) Work Plan and Associated
Work Plans
Johnson Controls Battery Group, Inc. (JCBG) Site
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina
Dear Mr. Sullivan:
The US EPA Region IV 1s m the Process of completing the Engineering
Evaluation/Cost Analysis (EE/CA) Work Plan, Sampling and Analysis Plan, and Health
and Safety Plan for all media of concern at the Johnson Controls Battery Facility, located
in Winston-Salem, NC. Comments on the Draft EE/CA were submitted to JCBG's
Contractor and conference calls to discuss comments/responses with the JCBG
representatives, the EPA Region, and NC DENR were completed on August 14 and 16.
The Superfund Section is in the process of reviewing and commenting on the Revised Final
EE/CA and associated documents. Figure 1-1 of the QAPP document is included as part
of the Sampling and Analysis Plan (SAP) and includes an updated rough estimate of the
work schedule.
The Superfund Section is providing these work plans for your review and
comment. If changes are warranted an additional submission with changes will be
completed even though this is called a Final Document. These documents are under
review by the Superfund Section at this time. If you have comments please forward them
to us as soon as you can or just give me a call and we can discuss them. As the work
progresses aqditional documents will be provided to your office to keep you informed
about the work. Documents to follow will include Public Relations Plan, Public Meeting
Notification/Fact Sheet, the EE/CA Report of findings at the sight, additional investigation.
work recomm_endations based on the original EE/CA work, Decision Documents, Design
Documents, and Remedy Progress Reports.
A public meeting is scheduled for tomorrow, Thursday September 7, 2000 at 7:00
PM at the Walkertown Public Library. I am including a copy of the Fact Sheet for you
information just in case you are unable to attend.
. 401 OBERLIN ROAD, SUITE 1 50, RALEIGH, NC 27605
PHONE 919•733-4996 , FAX 91,9·716-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER·-50% RECYCLED/10% POST-CONSUMER PAPER -.-~· .• . ' •.~ ...
If you .our staff have any questions, please-ll me at [phone],
extension 341.
Attachment
cc: Grover Nicholson, NC Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
' t
. .. E.f/CA
~PERFUND KICK-OF~ACT SHEET
~ JOHNSON CONTROLS, INC.
GLOBE BATTERY DIVISION
WALKERTOWN, FORSYTH COUNTY, NORTH CAROLINA
September 2000
INTRODUCTION
This .fact .shee.t. DD .the .Joh.nson . .Contr.a\s, .Im;, .Globe .&.ttery. DiYision.s.ite .!ocate.d in .Walker:t.D~VR,. Forsyth
County, North Carolina, has been prepared by the Environmental Protection Agency (EPA), Region 4
office in Atlanta, Georgia. The purpose of this fact sheet is to inform interested citizens and local officials
about the Site and provide advanced notice of upcoming activities. This fact sheet also provides the
following information: (1) a brief description and history of the Site; (2) a brief introduction to the
Superfund EE/CA process; (3) a brief description of proposed upcoming sampling activities and what to
expect in the coming months; and ( 4) a list of contacts.
BRIEF SITE DESCRIPTION/HISTORY
The Johnson Controls' property is approximately
75 acres in size. The coordinates for the Site are
36°07'09" North Latitude and 80°09'40" West
Longitude. The manufacturing facility is located
near the top of a smal! hill that slopes northwest
toward Lowery Mill Creek which flows into Salem
Lake. The remainder of the acreage is wooded and
undeveloped. It is bounded by private property on
all four sides and on the southeast by residential
properties facing West Mountain Street. The
property is located in Forsyth County in the
Walkertown jurisdiction.
The Johnson Controls facility was constructed in
1978 to manufacture, assemble and charge lead-
acid automotive batteries. The facility consists of
a large manufacturing plant, a trailer maintenance
building, a battery storage facility, a concentrated
acid storage and acid mixing building, a waste-
water pretreatment system, asphalt parking lots
and offices. A chain link fence enclose\the
facility with access controlled by a security guard.
The original facility was enlarged in 1984 and
again in 1992 to handle increased battery
production. Since operations began at this facility
there have been a number of accidental releases of
varying quantities of hazardous substances to soil
around the facility's main buildings or sedimenta-
tion basins which were reported to the State.
Three sedimentation basins are located down
gradient from the facility to catch surface run-off
which travels through underground pipes from the
manufacturing and parking areas. These basins in
turn discharge into unnamed tributaries which
flow into Lowery Mill Creek Currently, only one
of these basins is filled with water, the other two
are virtually dry. A Site map is featured on the
next page indicating the location of the facility and
basin areas.
Water used in the manufacturing process is pre-
treated. The treated wastewater is either recycled
back through the operation or discharged to the
City of Winston-Salem publicly owned treatment
works (POTW).
PUBLIC MEETING -THURSDAY, SEPTEMBER 7, 2000
7:00 PM at the
Walkertown Public Library
2969 Main Street
Walkertown, N.C.
•
JQ uospaqoij
"
@
I: ~ 0 . I ~ • ~ ~-~ ..
,3. ~ • z
Ii ~~ ;~
.. ~ ~a f =I
~i t
•
Hazardous wastes generated during the operation
are stored at the plant in 55-gallon drums and 10
mil polyethylene bags prior to shipment to a
smelter. Residue and sludge in wastewater as a
result from plant operations is also containerized
and shipped to a smelter for disposal.
In August 1997, the State conducted an Expanded
Site Inspection which included sampling soil on
.. Si.tr., ,s1,1r.fa.ce .wa.t.er.,and.,sl".i:limr.nt,samplr.,5,aff'.Site
and drinking water well samples. Based upon
data from these sampling events, EPA has
proceeded to investigate the Site because it
appears there is a release of lead to surface water
at concentrations that could pose a significant
threat to a nearby wetland. Data to date does not
seem to indicate that contamination has impacted
any other surrounding properties.
EPA and Johnson Controls are working together
to investigate the reported contamination at the
Site. The investigation will provide us with more
definite information of whether contamination has
spread, what contaminants are present. and what
action, if any, is required to treat or clean up any
contamination.
EPA EE/CA SUPERFUND PROCESS
The EPA and Johnson Controls signed an
Administrative Order on April 23, 2000 to
conduct an Engineering Evaluation/Cost Analysis
(EE/CA) at this facility. This Order requires
Johnson Controls to collect the necessary data to
evaluate the nature and extent of contamination.
• The EE/CA will identify the objectives of
the removal action and an analysis of the
various alternatives that may be used to meet
the objectives for cost, effectiveness, and
Implementability. The EE/CA should
provide definitive information on the
locations of hazardous substances/
contaminants; quantity, volume, size or
magnitude of the contamination; physical and
chemical characteristics of the contaminants;
and risks presented by the site; and various
alternatives available for cleaning up the Site.
•
• A public notice describing the EE/CA and its
availability to the public, and a 30-day public
comment period will be published in a major
local newspaper. EPA will respond to all
comments received.
• An Action Memorandum is then prepared
providing a concise, written record of the
decision for selecting the response action.
.Tbis.document.a!ong .wiLli.others,developed
during the process will be placed in the
Information Repository for public viewing. A
notice announcing the selected response
action will be placed in the local newspaper as
well as being mailed to citizens on the Site
mailing list.
A flow chart of the EE/CA process is featured on
the next page.
Community participation is encouraged through
out the process. Be sure to call us at 1-800-435-
9233 any time you have a questions or concerns.
INFORMATION REPOSITORY
Copies of documents developed during the
Superfimd process will be placed and made
available to the public in the information
repository located in the:
Walkertown Branch Library
2969 Main Street
Walkertown, N.C.
Phone: [phone]
EPA CONTACTS
If you want more information or have questions,
please contact either of the following:
Luis E. Flores, EPA Project Manager
Diane Barrett, Community Relations Coordinator
. U.S.E.P.A., Region 4
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303
Phone: [phone] ext. 28807 or 28489
• EE/CA Development· Process
EE/CA
., "
ldoatltlcAllan of
llarnml Al:llan
Objoc:flvu
fd111ffllcallon arul
l'ubllcCommaat
Alllllplsof
Pt!1o41(1t1Nat llaapoualll Action ---RomoVII Acffoa ~ .. Cammanls ,... IIDIIUIIDlldum
Altomatlvu 3D dayg)
Clllnjll ratlva
Allllplsof
bnlovllllcllon
Abrllllv'III
, .
.
bcoallllendad
RIIIIIQ'llf A.clllln
lllonlaU-
.
" .. i(
'n . _ .Uk.Z-.l-:$~~
MAILING LIST ,. .. ' ,., '~
If you have a change of ~pai'ess or want your name removed from this mailingJist or know of someone
that would like to have their name added to the Johnson Controls, Inc. Site,rnailing list, please have them
complete the following infonnation and return to Diane Barrett at the EPA address in Atlanta. Thank yCJu.
NAME------------------------------
ADDRESS ---------------------------
CITY, STATE, ZIP CODE
PHONE NUMBER (Optional) ----------------------
ft
~
Region 4
Change of Address __ Delete Name Addition
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
. ,.._ ' '\ (<er "9 \ North Site Management Branch !
Diane Barrett, Community Involvement Coofd. t,:_;33 l'JO I
Luis Flores, Remedial Project Manager \. /
'
Official Business
Penalty for Private Use $300
S/F
MR. RANDY MC EL VEEN, PROJECT MGR
SUPERFUND FEDERAL REMEDIATION BR
DIVISION OF WASTE MANAGEMENT ·
NC DEPT OF ENVR & NATURAL RESOURCES
401 OBERLIN ROAD, SUITE 150
RALEIGH NC 27605-1305
JOHN 28
RECEIVED
SEP 05 2000
SUPERFUND SECTION
. r,, I, II,,, 1;11,, II,'" I ,I, .. ,II,, II II I, 1,11, ,,, , 1,1, l,J,,1,,11
' •
• (II}) MONTGOMERY WATSON
August 4, 2000
Mr. Luis E. Flores
Remedial Project Manager
Region 4 U.S. Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta. Georgia 30303-S960
Re: Response to EPA.1NCDENR Comments
Draft EE/CA Work Plans
JCBGI Winston-Salem Facility
Dear Luis:
--....... , ... ,. . .. -.. ··-·-~ ..... ~ ............... . •
RECEIVED
AUG 07 2000
SUPERFUND SECTION
Enclosed is one copy of the response to comments on the draft Work Plans for the subject
project. We assume that we will resolve any questions on the comments in the August 14,
2000 teleconference. Final copies of the Work Plans will be prepared for delivery to you
on August 25, 2000.
We look forward to completing this phase of the project with you.
Sincerely,
MON'TGOMERY WATSON
Daniel W. Hall, PG
Project Coordinator
Enclosures: Responses to EPA Comments
Responses to Comments -NCDENR
cc: Ms. Debbie Hastings, JCBGJ (2)
Ms. Jane Clokey, Quarles & Brady (I)
Mr. David Beverly, MW, Atlanta(!)
!v1r. Randy McElveen, NCDENR (1)
:\fr. Rick Irby, JCBGI (1)
O\\'H:dwh'ndj/i\.JWK
M:\jobs·.; ::..;:!\ 179\l 6\wp\lrr\9S_Flores.doc
\I 242! 79161:!01 OJ-MAD-\
One Scien~e Court
P.O. Sox 5385
Madison, Wisconsin
53705-0385
Tel:608231 t.747
Fax: soe 231 t.777
Sen-in;; :he V.1orld's Environmen:al t. £'eds
• •
RESPONSES TO COMMENTS ff ORT~ CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL . ·VEO RESOURCES COMMENTS
AUG O 7 2000JOHNSON CONTROLS BATTERY GROUP, INC.
S .. , 'XINSTON SALEM, FORSYTH COUNTY, NORTH CAROLINA
UPEi,, ... ,. ~ECTION .
DRAFT ENGINEERING EVALUATION/COST ANALYSIS WORK PLAN
General Comments
I. The Administrative Order on Consent (AOC) and Statement of Work (SOW) requires
that site characterization "will provide for a comprehensive understanding of the
nature and extent of the contamination at the site." This EE/CA Work Plan (WP) is
not comprehensive in nature and extent. Volatile Organic Compound (VOC) and
Target Analyte Compounds (TAL) (other than RCRA Metals) are not included in the
Sampling and Analysis Plan (SAP) as required. There is a major tributary to the
northeast of the JCBGI Facility that has no proposed sediment or surface water
sampling proposed. The maintenance facility and other areas of the facility are not
being investigated under this EE/CA.
The AOC also includes areas of the facility where 3,000 gallons of sulfuric acid was
spilled, where lead oxide dust was released to a I-acre area, and 1,000 gallons of lead
oxide and lead sulfate wastewater was spilled. The point of release of each of these
incidences should be provided on a Figure and details of facility actions taken
provided in the site history section of the EE/CA. It is recommended that the EE/CA
initially be "comprehensive in nature and extent" then source areas and contaminants
of concern can be refined during this EE/CA.
Response: As stated in the SOW (Task 2, Site Characterization), the overall
objective of Site Characterization is to use existing data and collect additional data to
describe areas of the Site that may pose a threat to human health or the environment.
Previous investigations, including the 1997 Expanded Site Inspection (ES!) by
NCDENR have extensively evaluated Site conditions. To achieve a comprehensive
understanding of the nature and extent of the contamination at the Site, this EE/CA
Work Plan employed the existing data from the previous investigations to outline a
more focused, expedient, and effective investigation.
The ESI summarizes that the Site has a concern for lead. Given that JCBGI
manufactures batteries at the Site and the primary raw material is pig lead, we are
focusing primarily on the effects of lead in the environment. Our analysis of the data
indicates that PAHs and other metals were also present from the ES! analysis, but
generally not VOCs (see specific comment #5 response regarding MEK). These
results are also reflected in our approach to the investigation, as we arc including
PAHs and other metals. We do not have an identified source of PAHs at the Site, but
Response to NCDENR Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page I
•
it is known that other metals occur in the raw pig lead, and so their fate and migration
will be similar to that of the lead at the Site. Occurrences of other metals were
generally in the presence of lead. Further, in the source area samples collected, no
soil samples exceeded the SCDM human health-based screening benchmarks or the
NC RGs in the acid unloading area or the drum storage area, and only lead and
arsenic exceeded these standards in the lead oxide unloading areas. These same
results were compared against the SSL for lead near the Facility (400 mg/kg), with
the same conclusions emerging with regard to lead as the chemical of concern.
Most other metals at the Site of potential concern (e.g., arsenic, barium, mercury) are
adequately covered by the RCRA metals list. For purposes of the SLERA (see EPA
Ecological Assessment comment #2), we are adding a limited number of full T AL
metal scans to confirn1 lead as the main metal of concern.
Engineering controls (i.e., a drainage ditch) have been in place at the Facility that
have not allowed surface water runoff to the above mentioned tributary to the
northeast of the Facility, thus eliminating potential environmental impact to this
tributary.
The investigation act1V1t1es proposed in this EE/CA Work Plan arc considered a
continuation of the comprehensive investigation of Site conditions, and address the
potential threats to human health and the environment. The previous results were
used to shape the approach to this EE/CA investigation.
Each of the "spills" has already been reported to NCDENR under separate
documentation. To the extent that the documentation exists, the locations of the spills
will be identified and plotted on Figure 2 of the Work Plan.
2. The NCP and the AOC for this work requires both Federal and State Applicable
Relevant and Appropriate Requirements (ARARs). State ARARs are not mentioned
in the text of this EE/CA or listed in Table 1-1. All State ARARs must be included in
this EE/CA and if State ARARs are more stringent than the Federal ARARs they will
become the perfornrnnce standard for the various contaminated media. State ARARs
should include as a minimum the NC Groundwater standards, NCAC Title 15A,
Chapter 2, Subchaptcr 2L; NC Water Pollution Control Regulations, NCAC Title
15A, Chapter 2, Subchapter 2H; NC Water Quality Standards, NCAC Title 15A,
Chapter 2, Subchapter 2B; NC Air Pollution Control Requirements, NCAC Title
15A, Chapter 2, Subchapter 2D and 2H; NC Solid Waste Management Rules, NCAC
Title 15A, Subchapter 13B; and the NC Hazardous Waste Management Rules, Title
15A NCAC 13A.
Response: An analysis of State and Federal ARARs will be conducted and included
in or referenced to a table in the Work Plan. The most stringent ARAR will be
identified. We assume that State ARARs are cleanup standards, not Site Screening
Levels (SSLs).
Response to NCDENR Comments August 2000 Johnson Controls Battery Group• Winston Salem
Page 2
•
3. The exclusion of these details causes some concern as to the intent of the JCBG[
representatives and is not a good way to start on a major project such as this. lt is
better to start out conservatively and relax analysis and source investigation as
contaminants and source areas are eliminated by proper testing and evaluation.
Response: Comment noted. Refer to NCDENR General Comment No. I Response.
4. As noted in the above comments and with the following exceptions this Work Plan
seems to be adequate for an initial follow-up investigation phase to further delineate
the source areas and determine the impact to groundwater.
Response: Comment noted.
Specific Comments
I. The first paragraph at the top of page 7 and Figure 2 state or show that lead
contamination is present in soils of the "Lead Oxide Unloading Dock (LOUD) Area"
at concentrations exceeding the EPA's Soil Screening Levels (SSLs). Figure I shows
two additions to the northeast of the facility at some time in the past. Before these
additions runoff from the LOUD Area and the Acid Storage Tank (AST) Area may
have deposited sediment into the drainage swale northeast of the Facility. Please
provide at least 2 screening sediment and surface water samples in this drainage
swale and the downgradient stream. Specific sediment and surface water sample
locations can be detern1ined in the field.
Response: Prior to the warehouse addition, surface water drainage at the eastern
portion of the Facility (including the Lead Oxide Unloading and the Acid Storage
Tank Areas) was controlled by a drainage ditch that ran parallel to the building
(Figure 2 will be revised to reflect the location of the former drainage ditch). Runoff
collected in the drainage ditch flowed to the north and discharged to a manhole
located in the northeastern portion of the Acid Storage Tank Area (see Figure 2).
This manhole also drains the Acid Storage Tank Area. From the manhole, runoff is
directed via underground piping below the building to a drainage swale that runs
parallel to the northern portion of the building and eventually discharges to
sedimentation basin # 3. Because runoff did not discharge to the drainage swalc
located northeast of the Facility addition, collection of sediment samples in this area
is not proposed.
2. The second paragraph on page 12 indicates that the potential for suspended solids
causing unrealistically high lead concentration will be addressed by sampling and
analyzing both total and dissolved lead samples. The State and EPA do not recognize
filtered samples for surface water and groundwater samples. Confinnation of
performance standards cannot be made using filtered samples but for infonnational
Response to NCDENR Comments August 2000 Johnson Controls Battery Group• Winston Salem
Page 3
• •
purposes filtered samples may be collected and reported along with unfiltered
samples. Care should be taken that surface water samples are collected with as little
suspended solids as possible. This procedure may include recovery of surface water
samples that allows suspended particulate to settle. Then decant the more pure water
from the top of the sample. This procedure is accepted for inorganic contaminants
only.
Response: Comment noted.
3. The second paragraph on page 13 states that soil samples at 6-inch intervals will be
sent to the laboratory for Poly-Aromatic Hydrocarbons (PAH) analysis. It is
recommended that an organic vapor analyzer (OYA) be used to screen the soils for
PAHs. This infomiation could be useful during remediation of the soils and sediment.
Response: As standard practice, soil samples will be screened in the field using an
OYA. Although, due to the high ionization potential of PAHs, the relative response
of the instrument with respect to PAHs will be negligible.
4. Section 2.1.1.2 indicates that contaminated soil samples were detected in composite
samples that are now located under building additions. These conditions may also
exist under the building additions at the north end of the Facility. Land Use
Restrictions (LURs) may be required in these areas to assure that future land use and
development considers Human Health Risk during future construction and renovation
at the Facility. This is especially critical when soils or groundwater are disposed off-
site.
Response: Comment noted.
5. Section 2.1.4 discusses the groundwater investigation and states that "each
monitoring well will be sampled and analyzed for SYOCs, hardness, and total and
dissolved RCRA Metals." It is general practice to sample and analyze groundwater,
during the first sampling event, for YOCs, SYOCs, and target compound list
inorganics (all metals). If the groundwater data is consistent with the facility
history/chemical usage then Contaminants of Concern (COCs) can be established to
specify the groundwater contaminant analysis.
Response: Tabulated historical data will be provided in an Appendix to the Work
Plan. Historical data (NCDENR ES!, 1997) were used to shape the monitoring plan;
groundwater samples collected from the Site included two private well samples
(likely not downgradient from the Facility) and a groundwater spring sample (1200 ft
west and downgradient from the Facility). Water quality at the private wells was not
attributed to the Site. Water from the spring was only analyzed for basic indicator
parameters. As a result, historical soil and sediment data, along with knowledge of
Response to NCDENR Comments August 2000 Johnson Controls Battery Group -Winston Salem
P:.igc 4
•
Facility manufacturing processes, were used to evaluate appropriate groundwater
analytical parameters.
As indicated from historical data, VOCs were not detected above the method
detection limit in soil, surface water or sediment samples collected at the Site, with
the exception of methyl ethyl ketone (MEK). MEK was detected in one sediment
sample (JC-006-SD) collected near Lowery Mill Creek. Because MEK was not
detected in other environmental samples collected at the Site and is not historically
used at the Facility, it is not believed to be associated with Facility operations.
Toluene was detected at an estimated concentration (below method detection limits)
in one soil sample and several sediment samples collected at the Site. The NCDENR
ES! states that toluene was reported in the soil trip blank at a concentration below the
contract required detection limit (CRDL) and is a possible lab artifact. Because of the
toluene detection in the trip blank, toluene was not used in evaluating a release in any
of the soil or sediment. Because VOCs were generally not detected in soils and
sediments that are associated with Facility operations, VOCs are not proposed for
analyses of groundwater samples.
SVOCs are included in the groundwater analyses, because as the historical data
indicate, several SVOCs were found in sediment and soils at the Site that exceeded
the standards to which the results were compared.
RCRA metals were chosen in part, because the RCRA metals suite generally
represents the metals of concern at the Site. Based on previous sampling and
NCDENR ES! results, lead is the main metal of concern at the Site, which reflects its
use in the battery manufacturing process. Other metals arc trace constituents (less
than ½ %) in the pig lead, which is used in the battery making process. Given that
these other metals are minor inclusions in the pig lead, their distributions in the
environment will generally mimic the lead distribution in much smaller proportions.
6. Section 2. I .4 on page 16 references Figure 3 for proposed monitoring well locations.
The general locations for the four wells shown on Figure 3 are good. However, to
assure that the aquifer characteristics do not change downgradient of the facility it is
recommended that 3 additional monitoring wells be installed at a good distance
downgradient of the facility to the west. Perhaps these additional monitoring wells
could be placed in the area of proposed staff gauge SG-03 and in the area of Sediment
sample SD-16 and one well to the north of the facility.
Response: A phased groundwater investigation approach is proposed for this EE/CA
Work Plan (see response to EPA Comment No. 8). A shallow monitoring well will
be installed within each area of high soil lead concentrations (Lead Oxide Unloading
Area and Fornier Dmm Storage Area). Water level measurements and analytical
samples will be collected from the two additional monitoring wells and the four
previously proposed monitoring wells (MW-I through MW-4). Based on the
Response to NCDENR Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 5
•
observed groundwater flow direction and analytical results from the monitoring wells,
additional monitoring wells will be proposed accordingly, if necessary.
7. The third bullet at the bottom of page 17 states that a background groundwater
sample will be collected from one of the wells shown in this report that is considered
upgradient of the site based on the calculated groundwater flow direction. The
background well should be well upgradient of the general source area and must
be non-detect or at background concentrations for all Contaminants of Concern
(COCs). Private well concentrations or other off-site wells may be used to establish
background.
Response: The current scope of work will be used to detcrrnine the direction and
quality of groundwater near the manufacturing Facility. The proposed upgradient
well is not known to be in an area of historical contamination, and so our current
belief is that it is a reasonable location to begin our assessment. If groundwater flow
direction and analytical results indicate thatpt none of the newly installed wells do
not represent a background location, a background well will be installed in a
subsequent phase of the groundwater investigation.
8. The second paragraph on page 19 misspells the word "completed" twice m this
paragraph.
Response: Comment noted. The text will be revised accordingly.
9. The third sentence in the fourth paragraph on page 19 1s either not complete or
unclear. Please make appropriate clarification.
Response: Comment noted. The text will be revised to clarify its intent.
Sampling and Analysis Plan
10. Section 2.9 on page 7 discusses locating the samples by using a survey. It is
recommended that the locations of all wells, soil and sediment samples also be
located on a Geographic Infomrntion System (GIS) including private wells of
residents around the area. By using the GIS, sample locations can be easily located in
the field regardless of future development.
Response: Comment noted. We are currently considering the positive attributes of a
GIS approach and will address this in the Work Plan, as appropriate.
Response to NCDENR Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 6
•
11. The word "Analyses" as used in the Sample Rationale/Comment column of Table 1-1
should be changed to Analyzed.
Response: The word "Analyses" should be used in the Sample Rationale/Comment
column of Table 1-1, because the column represents the future analyses that are to be
perfom1ed as part of the EE/CA Work Plan. The word "Analyzed" implies that the
analyses has been performed in the past.
12. Sample depth is not complete on Table 1-1 for sediment sample JC-SD-26 through
30. Sample Depth for Sediment is generally listed as "6-inch intervals to basin
bottom" and soil sample depth is listed as "6-inch intervals to 4 feet". Please change
the sample depth of JC-SD-21 through JC-SD-30 to be consistent with other sediment
sample depths.
Response: Comment noted. The text will be revised accordingly and the comment
will be incorporated on Table 1-1. Because the sediment samples JC-SD-21 through
JC-SD-30 are located in a wetlands area, the sample depth will be listed as "6-inch
intervals to sediment/native soil interface.
13. The Decision Rule listed as number 5 on page 1-1 states that "groundwater sample
results will be compared to US EPA MCLs." Groundwater samples should be
compared to ARARs, which include the EPAs MCLs and the States NCAC 2L
Groundwater Standards. The ARARs list should only include the most stringent of
these standards.
Response: Comment noted. The text will be revised accordingly. As indicated in
NCDENR General Comment# 2, a list of ARARs will be assembled in a table for the
Work Plan. We assume that State ARARs are cleanup standards, not Site Screening
Levels (SSLs ).
14. It would probably be appropriate to list my name as the NC DENR representative in
the Project Organization and Responsibility Section on Page 2-1 and include the
Superfund Representative under or along-site the U.S. EPA Region IV, RPM in
Figure 2-1.
Response: The NCDENR representative, Randy McElveen, will be presented in the
referenced section and on Figure 2-1.
15. Details for Section 4.0, Sampling Procedures, are not provided m the SAP. All
appropriate details should be given for each Section of the SAP.
Response to NCDENR Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 7
•
Response: Details of the sampling procedures are provided for in the Field Sampling
Plan. The QAPP only presents the outline; there is no need to duplicate the procedure
descriptions, because they are in the same document (SAP).
I 6. The Reporting Limits (RLs) listed in Table 1-1 should reflect the best analytical
methods and include peaks on the graphs that are below the detection limit. The
Laboratory generally lists concentrations that are noted below the detection limits as
"J values".
Response: A footnote will be added to Table 1-1 indicating the laboratory will report
an estimated value (J) for analyte concentrations detected between the method
detection limit and method reporting limit.
17. State ARARs should be included in Table 1-1 or in a separate Table or in a similar
table that includes the most stringent ARARs per the NCP. We assume that State
ARARs are cleanup standards, not Site Screening Levels (SSLs).
Response: State ARARs will be included on Table 1-1.
18. The Acronyms and Abbreviations Table provided at the front of the Quality
Assurance Project Plan (QAPP) is an excellent reference. However, many of the
abbreviation/acronyms in some Tables of the Report are not defined in the Table or in
the text of the Plan or included in the Table at the front of the QAPP. Examples are
SPCC, CCC, RSD, GFAA/CV AA, and R in Tables 3-2A and 3-2B and 3-2C. Please
re-check all abbreviation and acronyms to assure that they are defined appropriate.
Response: The Acronyms and Abbreviations table will be corrected.
19. Abbreviations and acronyms are defined in Table 3-2B but not in Table 3-2A. Please
include these abbreviations in both Tables since they are not a continuation of each
other.
Response: The comment has been incorporated on Table 3-2A and 3-2B.
20. General and specific comments noted above should be corrected in all associated
Tables and Figures and in all the related text of the EE/CA Work Plan.
Response: The comment has been noted and corrections will be made 111 all
appropriate sections of the EE/CA Work Plan.
SG\V /vlr/nJj/DSB/DWI I
\\MA DI-SERVER I \Main\johs\1242\ 179\ 1 (i\wp\rpt\92 _ NCDNR Comments.doc
1242179. I 6 I 20 IO 1-M,\ [). I
Response to NCDENR Comments August 2000
Page 8
Johnson Controls Battery Group -Winston Salem
•
RECEIVED RESPONSES TO EPA COMMENTS
JOHNSON CONTROLS BATTERY GROUP, INC.
AUG O 7 200Q: WINSTON SALEM, FORSYTH COUNTY, NORTH CAROLINA
SUPERFllND SECT~FT ENGINEERING EV ALUA Tl ON/COST ANALYSIS WORK PLAN
GENERAL COMMENTS
EE/CA \York Plan
I. Page I, the effective date of the AOC is April 23, 2000.
Response: The text will be revised accordingly.
2. At the top of page 4, the clean up goals for the Site will be detem1ined as part of the
risk assessment. Delete last sentence of the top paragraph.
Response: The text will be revised accordingly.
3. At the top of page 7, the EE/CA Work Plan states that because soil lead
concentrations around the acid storage tank area were below the lead screening level
for soils (400 mg/kg), this area is not considered a source area. There may be soil
lead contamination at levels below the 400 mg/kg value that, through mass transfer
processes, results in surface water, sediment, or groundwater contamination above
action levels or screening levels for these other environmental media. Therefore, it
would be correct to state that the soil contamination around the acid storage tank area
is of relatively minor concern with respect to being a source of contamination for
these other environmental media. It could be stated that the soil lead data from this
area does not indicate an unacceptable level of contamination with respect to a direct
exposure to the soil. This comment should also be considered in the wording of the
fourth paragraph of Section 1.5.
Response: The text will be revised with the above comment in mind.
4. Page 7, at the end of the second paragraph of section 1.4.2, delete the sentence that
reads "The survey was conducted in an expedient manner and may not accurately
define the extent of the wetland areas".
Response: The text will be revised accordingly.
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page I
•
5. Some alternate wording 1s recommended for the second sentence of the sixth
paragraph of Section 1.5. The clay-rich saprolite may influence drainage patterns or
the general topography of the area but the geology of the area is not "dominated" by
the saprolite. Since the saprolite has fonned from weathering of the parent rock, and
would not be present without the parent rock, one could as easily state that the
saprolite (and thus the geology) is "dominated" by the bedrock.
Response: The text will be revised to reflect this comment. Our comments were
directed at the prevalence of the saprolite as a soil type.
6. In order to support the premise that only lead as an inorganic contaminant of concern
needs to be evaluated in this investigation, presentation of the existing data for other
inorganic contaminants (principally metals and sulfate) must be included in the
EE/CA Work Plan. This comment docs not reflect potential concerns with respect to
the omission of data that may be relevant to a human health or ecological risk
assessment.
Response: The text will be revised in Sections 1.4 (Previous Investigation) and 1.5
(Conceptual Site Model), to reflect how the historical data has been used to focus the
scope of the proposed EE/CA field investigation. Tabulated existing data will be
provided in an Appendix and presented on site maps, where appropriate. This will
include data from previous analysis for VOCs, SVOCs, and other metals. We have
commented elsewhere in this document (see Ecological Risk Assessment comment#
2) regarding our intent to include additional metal parameters for the purpose of risk
assessment.
7. One element of the investigation needs to be an evaluation of potential subsurface
lead (or other contaminant) transport mechanisms or attenuation processes. In this
regard, some delineation of lead contamination in the subsurface to concentrations
below the 400 mg/kg soil screening level should be done. This could be a focussed
investigation that considers lead vertical contaminant distribution in soils at a handful
of locations in the areas of the most highly contaminated surface lead contamination.
These areas can be defined by previously collected data.· Section 2.1 of the work plan
should be revised to make this fate and transport element of investigation a part of the
work plan.
Response: The text will be revised to reflect additional investigation to evaluate the
vertical extent of lead soil impact. It will be noted in the objectives as well as
described in Section 2.1.1 (Further Delineation of Source Areas). Locations will be
selected based on previous (historical) soil sample locations or proposed new
locations. Since XRF analysis is proposed, sample results will be determined in the
field with regard to vertical extent. Experience shows that lead migration in soil is
usually limited to within 2 feet of ground surface. Our 4-ft soil sampling should be
more than adequate to assess lead concentrations with depth to background
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 2
•
concentration, but we will have real-time field data to determine if we need to go
deeper. We may take the opportunity to sample soils at greater depths for lead soil
analyses, since we are committing to conducting the two additional well borings in
the high lead source area (see General Comment# 8).
8. Concerning the proposed monitoring well locations, there should be one well placed
very close to (if not within) each of the two areas of high soil contaminant (lead)
concentrations around the building. These areas are defined by the cluster of soil
borings shown on Figure 3 on the eastern side of the building and the cluster of soil
borings around the southeast corner of the building. The reason this near-source
monitoring well placement is important is primarily the potential for contamination to
be present in these areas that either has not yet or will not migrate further
downgradient to the locations of proposed wells MW-02, MW-03, and MW-04
(reference Figure 3). Also, depending on the relative degree of hydraulic
conductivity in the various subsurface materials and the position of the monitoring
wells relative to groundwater discharge areas, there is a potential that significant
groundwater contamination present near the water table around the source areas may
only be present at greater depths than those proposed for monitoring well MW-02,
MW-03, and MW-04. At several other sites in the Piedmont region of North and
South Carolina, it has been observed that a relatively high hydraulic conductivity
characterizes the transition zone between the saprolite and bedrock. In such settings,
it is possible that shallow wells positioned downgradient of a contaminant source area
will miss detecting the contamination that is localized in the deeper saprolite-bedrock
transition zone. Should there be any significant contaminant concentrations found in
the shallow saturated part of the saprolite closer to the potential source areas, then a
more comprehensive downgradient investigation that considers both shallow saprolite
and deeper groundwater quality will be indicated. Since the conceptual site model is
that groundwater has not been impacted by the site operations, the best place to test
the validity of that model is clearly in the areas of the most significant soil
contamination.
Response: Comment noted. The text will be revised accordingly. A shallow
monitoring well will be installed within each area of high soil lead concentrations
(Lead Oxide Unloading Area and Former Drum Storage Area). Water level
measurements and analytical samples will be collected from the two additional
monitoring wells and the four previously proposed monitoring wells (MW-I through
MW-4).
Our approach to the groundwater investigation is to evaluate groundwater flow and
groundwater quality relatively near the Site. The addition of the two additional
source area wells is consistent with our approach. Once interpretations are made of
groundwater flow direction with respect to the monitoring wells that are installed,
then the need for and placement of additional monitoring well can be assessed. In
this regard, this investigation will assess whether groundwater contamination is a
problem closest to the Facility building, where the potential for detecting
Response to EPA Comments August 2000
Page 3
Johnson Controls Battery Group -Winston Salem
0 •
groundwater contamination should be highest. The groundwater investigation will be
more effective by assessing potential impact near the source areas or just
downgradient of the Facility, before committing to the time and expense of drilling in
difficult terrain, further downgradient or deeper beneath the Site.
9. With regard to the discussion on pages 11 and 12, the proposal for laboratory analysis
of only a subset (proposed 15%) of the total of soil and sediment samples subject to
field XRF analysis is acceptable, with the understanding that a poor correlation
between laboratory and field results may warrant additional confinnatory sampling or
confinnatory sample analysis. This point is especially true for areas with a potential
for critical levels of contamination that have not been confim1ed through the
laboratory analysis.
Response: We concur with the comment. We will evaluate the correlation of the
XRF and analytical laboratory dates to assess whether an acceptable relationship
exists and to assess if additional laboratory confirmatory analysis is required.
I 0. The last paragraph of Section 2.1 is too vague with respect to the analysis of PAH
compounds in environmental samples. This concern can be addressed by making two
changes or additions to the work plan. First, a full description of the observed soil
PAH detections from previous site investigations is needed in an earlier section of the
work plan. Second, the last paragraph of Section 2.1 needs to reference the later
sections of the work plan that provide more definition to the proposed PAH
investigations.
Response: The text will be revised accordingly in Section 1.4 to reflect a full
description of the historical PAH data. The work plan currently comments only on
the locations where PAHs exceed a specific SSL. Also, Section 2.1 will reference
later work plan sections where PAH investigations are proposed.
11. At the top of page 13, a sampling procedure is proposed that is very difficult to
follow. It would be useful for the work plan to include an illustration to show how
the sampling would proceed in cases where the XRF measurements indicate that lead
concentrations are either above or below the 400 mg/kg concentration.
Response: The text will be referenced to a figure that will illustrate the sampling
concepts.
12. In the discussion on page 13 under the heading Semi-Volatile Organic Compounds,
the text in the next to last sentence of the first paragraph needs revision. Since the
maximum proposed depth for the soil sampling is 4 feet, analytical results could not
" ... indicate that PAH concentrations are detected above SSLs in soils .. at depths
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 4
• •
below 4 feet." The analytical results could, however, indicate the potential for P AH
concentrations above SSLs in soils deeper than 4 feet.
Response: EPA's interpretation of our intention is correct. The text will be revised
accordingly.
13. Section 2.1.2 proposes to evaluate soils for TCLP extract lead concentrations. Some
statement about the number of samples that will be subjected to this testing should be
presented. It is EPA's experience that TCLP lead (or metals in general)
concentrations are often highly variable between samples with approximately equal
total lead concentrations. Thus, a sufficient number of samples are needed if
reasonably defensible conclusions are to be drawn about the soil lead concentration
that defines a hazardous waste.
Response: The text will be revised accordingly to indicate that six to eight soil
samples will be analyzed for TCLP lead. The soil samples for TCLP lead analyses
will be selected from specific locations with total lead concentrations from 500 mg/kg
to 3,000 mg/kg in approximate 500 mg/kg increments. Experience suggests that the
TCLP threshold for lead will be met within this range of lead concentrations. Table 1-
2 of the QAPP provides the number of samples to be analyzed.
14. Section 2.1.3.1 proposes that no additional soil samples for lead analysis will be
collected around the sedimentation basins because lead in previously collected soil
samples did not exceed the screening level of 400 mg/kg. However, less highly
contaminated soil represents a potential source of surface-water or sediment
contamination and may need to be addressed to limit potential cross-media impacts.
It would be useful to have some limited additional soil sampling and TCLP testing of
the lead in soils near the locations of above-background lead concentrations at the
upstream margins of the sedimentation basins (e.g., around sample joint JC-013-SL,
with a reported lead concentration of 13 7 mg/kg; reference Figure 2). This additional
sampling would determine if there is a potential for cross-media impacts from such
soil contamination that may need to be addressed in a site remedial action, and would
indicate the possible volume of contaminated soils that would contribute to any such
cross-media impacts.
Response: The test will be revised to reflect additional soil sampling. Additional
soil samples will be collected at the upstream margins of the sedimentation basins and
analyzed for total lead. If total lead is detected at concentrations above 500 mg/kg in
the soil samples, the soil sample will be submitted for TCLP lead analyses.
15. At the bottom of page 14, it is unclear from the discussion whether the sample with
the highest soil lead concentration of the samples collected from each quadrant will
be TCLP tested, or whether the sediment sample with the highest lead concentration
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 5
•
of all the sediment samples is proposed for that testing. In order to have a reasonable
understanding of the potential for mass transfer of lead from sediment to water, more
than one sample would have to be tested. Additionally, some range of sediment lead
concentrations should be tested in order to evaluate the sediment concentration at
which contaminant mass transfer to water becomes a potential concern.
Hypothetically, if there was a relatively uniforn1 lead concentration in the sample
with the highest lead concentration from each quadrant, and there was a relatively
uniforn1 TCLP extract concentration associated with the set of highest lead sediment
samples, then one might not be able to detern1ine the sediment concentration
associated with an unacceptable degree of potential contaminant mass transfer from
sediment to water. This possibility suggests that the proposal should assure that a
range of sediment lead concentrations will be evaluated using the TCLP.
Response: A total of six sediment samples will be collected and analyzed for TCLP
lead from the three sedimentation basins. These will be identified through XRF
screening in the field. The sediment samples for TCLP lead analyses will be selected
from speci fie locations with total lead concentrations ranging from 500 mg/kg to
3,000 mg/kg in approximate 500 mg/kg increments, if conditions allow.
With regard to evaluating mass transfer of contaminants, our current plan is to
conduct a qualitative assessment of potential transfer; we are not anticipating a need
for a quantitative assessment or modeling. The SSLs, ARARs and risk assessment
process will provide the basis for addressing contaminants in specific media. The
need for cleanup will be media-specific, based on the regulatory process. Therefore,
we are less concerned about a detailed analysis of cross media transfers, of
contaminants, unless the results will serve to practically alter the approach to the
remedy, or will lessen costs.
16. Section 2.1.4 should either state the field filtration procedure that will be used for the
filtered groundwater samples or should reference the section of the Field Sampling
and Analysis Plan that describes the procedure.
Response: The Section 2.1.4 text will identify one of the filtration procedures and
will refer to the Field Sampling Plan for its detailed description.
17. Because the proposed monitoring well construction is such that the well screen
brackets the water table (per Section 2.1.4), the slug testing of the proposed
monitoring wells should be a rising-head test (references Bouwer, 1989, Ground
Water, Vol. 27, No. 3, p. 307).
Response: The Section 2.1.4 text will be revised to indicate the preference for the
rising head test. The text in the Field Sampling Plan will describe the test procedures.
Response to EPA Comments August 2000 Johnson Controls Battery Group~ Winston Salem
Page 6
•
I 8. For the sake of completeness, the EE/CA Work Plan should include a figure or show
on existing figures the proposed approximate locations of all of the background
samples proposed in Section 2.1.6. The background samples should be identified as
such on the figures.
Response: The text will reference Figure 3, which shows the locations of proposed
sample collection points. The majority of proposed background sample locations for
various media will also be presented on Figure 3. An additional figure (Figure 4) will
show the background sample locations that are not on Figure 3, further from the
Facility.
Field Sampling and Analysis Plan
19. In section 1.0, page I, the last "bullet" needs to add a word or words after the word
"impacted".
Response: The text will be revised to say "Evaluate groundwater quality at the Site
to confirm the conceptual site model." This correction also modifies the last bullet on
p. 11 of the work plan document.
20. There appears to be a need for a revision to the last sentence in the first paragraph of
Section 2.1.
Response: The text will be revised to say "Subsurface soil samples will be collected
using direct push technology, or hollow stem augers with split-spoon samples."
21. The last paragraph of Section 2.4 proposes to use a 0.45-micron filter to field filter
samples for dissolved metals analysis. This procedure will not only result in
detem1ination of the dissolved metals concentrations, but may also partially reflect
the concentration of metals in the suspended colloidal particle fraction of the sample.
That colloidal material may or may not be mobile under the ambient hydraulic
gradient. Section 7.3.5 of the "EISOPQAM" (this EPA guidance document is
referenced at the bottom of page 11 of the EE/CA Work Plan) specifies the
recommended filter sizes to determine either truly dissolved or the dissolved plus
potential mobile colloidal particles in the groundwater. This guidance should be
followed when proposing a filter size for this sampling. The proposal should also
explain the reasons for selection of the filter size.
Response: We will check the EPA guidance for selection of an appropriate filter
size. Our intent is to select a filter size that eliminates particles that could be
entrained into the water sample during collection procedures that might potentially
contain metals concentrations. Low-flow sampling techniques should eliminate most
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 7
•
of the concern for particulates in samples, but it is the concern for particulates that we
are proposing dissolved and total metals analyses.
22. At the bottom of page 6, the specified hydration time for the bentonite seal should be
modified to conform with Section 6.5. l of the aforementioned "ElSOPQAM". The
type of grout to be used in the annular space of the monitoring wells needs to be
specified. lfpure bentonite grout (such as Volclay Pure Gold Grout) is used, then the
one hour hydration time for the bentonite pellets is adequate. l f cement grout (neat
cement) is used for the annular grout, then the one hour hydration time for the
bentonite pellets is not adequate. Instead, the bentonite pellets should hydrate at least
7-8 hours before the cement grout is placed into the annular space.
Response: The text will be revised to reflect the above mentioned EPA guidance
regarding well installation grouting and bentonite hydration time. The annular grout
will consist of a neat cement and bentonite slurry and therefore, the hydration time for
the bentonite pellets will be a minimum of eight hours or the manufacturer's
recommended hydration time, whichever is longer.
23. Similar to the previous comment, installation of the protective casing around the top
of the well (reference FSAP pages 6 and 7) should be specified as per Section 6.5. l of
the "EISOPQAM".
Response: The text will be revised to reflect the EPA guidance regarding the
protective casings and surface pads for well installation. The protective casing will
be of steel construction with a hinged, lockable cap. Once the annular grout has
cured at least 24 hours, cement will be added to the borehole and the protective
casing will be pushed into the wet cement a minimum of 2 feet. The protective
casing will extend above the surface a minimum of 2.5 feet. Two weep holes will be
drilled into the casing for drainage. A surface pad will be constructed around the
protective casing. The surface pad will consist of 3 feet x 3 feet x 6-inches and will
be sloped so that drainage will flow away from the protective casing off the pad.
24. A comprehensive and complete schedule needs to be prepared. Start and completion
dates for each task should be included from the approval date of the work plan until
submission of the final EE/CA report.
Response: A draft bar chart type schedule will be prepared, so that each task will
have a proposed start and completion date, and duration. The actual dates will
depend on authorization to proceed by EPA.
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 8 ·
• •
ECOLOGICAL ASSESSMENT COMMENTS
l. Usually in a work plan present existing data is presented to demonstrate that the field
work can focus on a subset of analytes. The Ecological Risk Assessment Guidance of
Superfund (USEPA, l 997) recommends that the Screening-level Ecological Risk
Assessment be conducted prior to the work plan. A work plan addendum can be
prepared to present the assumptions that will be used in the Baseline Ecological Risk
Assessment. Alternate screening values, with assumptions for any calculations, can
be provided in this submittal. The work plan addendum would begin with the
Problem Fonnulation.
Response: Although Ecological Risk Assessment Guidance of Superfund (US EPA,
l 997) recommends that the Screening-level Ecological Risk Assessment be
conducted prior to the work plan, this assumes that there is adequate data to perform a
screening level assessment. In developing the work plan, we took into account the
existing data from previous investigations, but believe that additional data is
necessary before completing the Screening Level ERA. For this reason, the
Screening Level ERA will be completed after the first phase of data is collected and
the nature and extent of any potential contamination is better defined. Once this data
is available and the Screening Level Ecological Risk Assessment is perforn1ed, an
evaluation will be made with USEPA input concerning whether a Baseline Ecological
Risk Assessment is appropriate for the Site.
2. The Operational and Regulatory History indicated that pig lead, lead oxide, barium
sulfate, carbon black, and sulfuric acid were associated with manufacture of batteries
at this site. Other metals commonly associated with automobile batteries are
antimony, arsenic, cadmium, copper, nickel, and zinc. Lead is the only metal
proposed for analysis. Lead may capture the bulk of the human health risk, there is
no assurance that this is the case for ecological risk. At least a limited number of full
TAL metal scans are needed to conduct a Screening-level Ecological Risk
Assessment (SLERA) to confirm lead as the main chemical of concern for this site.
If existing data are available to make this determination, a SLERA should be
provided in the work plan, or in a work plan addendum.
Response: The selections of lead as the indicator parameter for the risk assessment
process is based on the relative amount of lead used in the battery making process,
it's potential for human health and ecological impacts, and previous sampling results
from the site. Other metals are present as trace metal constituents in the pig lead, but
combined, they account for less than ½ % of the pig lead.
For the purposes of the SL ERA, we will conduct a limited number of full T AL scans
to confirm lead as the main chemical of concern at the Site. Existing data and the
additional data yet to be collected will be used in the SLERA to evaluate whether lead
is the sole metal of potential ecological concern. The sampling locations and
procedures will be described in Section 2.0, Site Characterization, of the Work Plan,
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 9
with appropriate description in the FSP and QAPP. The sampling will also be
addressed in Section 3.0 Baseline Risk Assessments.
3. No background locations are shown on Figure 3. A map is needed for background
locations. A description of the rationale for choosing the background stations is also
needed.
Response: Similar to the response to EPA Comment# 18, Figure 3 and new Figure 4
will show background sample locations, and a rationale will be provided for their
selection.
4. The soils are proposed to be delineated to 400 mg/kg for lead. The soils screening
value for ecological risk is 50 mg/kg. I recommend to delineate to a lower
concentration (50 mg/kg). Otherwise, the delineation assumes that the cleanup goal
will be approximately 400 mg/kg, or greater. The "hot-spot" delineation will not
provide an estimate of the average exposure concentration or what the concentration
will be after the removal. It does not indicate how rapidly the concentrations fall off
from the hot spots. Delineation to 400 mg/kg would make it impossible to justify an
assumption that the average concentration at the site was anything less. Default
exposure assumptions, necessary in absence of site-specific biological data for the
ecological risk assessment, will predict unacceptable ecological risk for lead
concentrations of 400 mg/kg. Proceeding to the Baseline Ecological Risk
Assessment (BERA) is a foregone conclusion for a site delineated to a level greater
than the ecological soils screening value. Delineation to a value closer to background
is recommended.
Response: Soils within the developed, open space around the JCI Facility will be
considered in the human health risk assessment, because practically, human
exposures to media are generally restricted to this area, and this is not anticipated to
present ecological habitat. In this respect, the SSL of 400 mg/kg for lead seems
appropriate for these areas.
In contrast, soils within the forested area of the Site, including the areas around the
sedimentation basins, will be compared to an SSL of 50 mg/kg lead. Further, soil
samples collected within the forested areas and sediment samples collected within the
sedimentation basins and along the intem1ittent creeks to the wetland areas will be
considered in the ecological risk assessment, because these areas afford potential
ecological habitat. This area is generally inhabited only by wildlife, with limited
human occupation, such as for hunting or cropping. In this area, sediment sample
results will be compared to the sediment SSL of 30.2 mg/kg, since all samples
collected below the basins are considered sediment samples. We believe this strategy
is a practical approach to the human health and ecological risk assessment process.
Response to EPA Comments Aueust 2000 Johnson Controls Battery Group M Winston Salem
Page I 0
•
5. The sampling technique of using the highest lead XRF to choose where to sample for
PAHs assumes that lead and semi-volatiles are co-located. This may be true for
sediment deposition zones. In the Former Lead Oxide Unloading Arca, however, it is
conceivable that a separate contaminant release process took place for each class of
contaminants. Separate delineation for metals and PAHs is recommended.
Response: We agree that lead and semi-volati Jes could have separate release
processes from each other in the vicinity of the plant. Since we do not have an
identified source area for SVOCs, in the lead oxide unloading area, or anywhere else
on the Site, we choose a systematic method of collecting and analyzing samples for
SVOCs. The alternative is to sample pre-determined locations around the Site, but
we do not believe this will add to a greater understanding of the occurrence of these
contaminants at the Site. Therefore, we propose to sample for SVOCs, as planned,
with the understanding that the results may help focus future sampling efforts as to
the source of SVOCs at the Site.
6. No detection limits arc provided for the analytical methods. A table should be
prepared of the number of confirmatory samples, the method number, and detection
limits. Detection limits for surface water may not be low enough to achieve the
sensitive ecological effects levels.
Response: Tables 1-1 and 1-2 of the QAPP contain the requested information.
Reporting limits, (if any) that do not attain ecological ARARs will be noted. This
table will be included in or cross-referenced in the Work Plan.
7. The work plan should specify the numbers of confinnatory samples being sent to the
laboratory for sediments and soils.
Response: Sec response to EPA Ecological Assessment Comment #6 above.
8. The work plan should indicate that the SLERA will tabulate names of species
potentially present with those species actually observed indicated.
Response: Within the SLERA a site walkthrough will be conducted to detem1ine
the ecological habitats on site and make observations of dominant plant species, and
animals present in the habitats at the time of the site visit. This will be documented in
the SLERA. Detailed biological surveys are beyond the scope of the SLERA so a
comparison as requested would have little practical meaning. However, the potential
types of receptors that may be present in each ecological habitats identified on-site
will be identified and discussed. A full list of all potential flora and fauna on-site will
not be developed as part of the SLERA.
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 11
•
9. Recommended are ten XRF samples in the unnamed tributary draining Basin #1, with
at least three sent to laboratory. The extent of concentrations elevated over
background should be delineated instead of just the sediment screening level (SSL).
Response: Based on the historical data, background sediment lead values are lower
than the sediment SSL of 30.2 mg/kg. For this reason, it seems appropriate to
delineate to the sediment SSL. In the future, the SSL values can be compared to
historical and proposed background sampling data for comparison. If the background
values from the proposed investigation are higher than the SSL, the sediment values
will also be compared to background for purposes of describing Site conditions.
10. As the site will, in all likelihood, require a BERA, the work plan (or a work plan
addendum) should include all alternate screening values that will be used and all
assumptions for food chain models. These assumptions should be submitted for
review and approval before preparation of the BERA. The work plan for the
ecological risk assessment should follow the 8-step process in the ERAGS guidance
(USEPA, 1997), which requires Problem Fonnulation and selection of Assessment
Endpoints prior to specific choices of receptor species or food-chain models.
Response: We plan on taking a step-wise approach to the ecological risk assessment
process, and as discussed in the Comment I response, the SLERA will be conducted
once additional data will be collected to better define the nature and extent of analyte
concentrations on site. Once the SLERA is conducted, it will be decided with USEPA
input whether it makes sense to perforn1 a BERA. Simply because a given sample
location is above a SSL does not necessitate that a BERA has to be conducted at a
site. Other factors will also determine whether a BERA is warranted, such as extent
of the contamination and location in relation to sensitive ecological resources.
EPA HUMAN HEALTH RISK ASSESSMENT
I. Throughout the report, statements are made that "Lead was the most widely detected
constituent" and that "lead will be the primary constituent of concern for assessment
of potential impact". In the discussion of proposed sampling to characterize the site,
it is stated that only lead and/or PAHs will be analyzed for in soil, sediment, and
surface water, while groundwater samples will also be analyzed for the "RCRA
metals". This proposed approach is not acceptable based on the information
presented. Ordinarily all samples in an initial RI or EE/CA sampling event are
analyzed for the full TCL/T AL (Target Compound List/Target Analyte List).
Selection of Chemicals of Potential Concern (COPCs) for further evaluation in the
risk assessment must be done according to EPA guidance (EPA, I 989, I 995).
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 12
• •
Response: We agreed with EPA that existing data could be used to the extent
possible to shape the scope of work for this EC/CA. The existing data was reviewed
during Work Plan development with an eye toward focusing on the problems
associated with the Site, as presented. The ES! (NCDENR) results were convincing
as to the nature of the contaminant types worthy of further investigation. It served as
a screening tool to evaluate the chemicals of concern at the Site. Additional
information will be presented in the Work Plan, in association with EPA Comment
#6, that demonstrates that the selected contaminants of concern in the various media,
are appropriate for this Site. We have added chemicals to the parameter lists, where
needed to support the SLERA (see response to EPA Ecological Risk Assessment
Comment #2).
2. Section 1.3, pgs 3, 4; Figures 2, 3 -future exposure scenarios. The statement is made
on page 4 that the site is "an industrial operation and, therefore, the clean up goals for
the Site will be established to represent an industrial setting." Figures 3 and 4,
however, show that site sampling extends beyond the facility property boundaries.
While this land may be undeveloped at present, future exposure scenarios should be
evaluated in the risk assessment which consider all plausible land uses (including, as
appropriate -residential, trespassing, recreational).
Response: The text in Section 1.3 will be revised, per EPA General Comment #2 on
the Work Plan. Offsite areas will be evaluated in the human health risk assessment,
but JCBGI does not control access or ownership to parcels of land beyond its
boundaries that may be potentially affected. In offsite areas other plausible scenarios
will be evaluated consistent with the site setting and land use.
3. Section 1.3, pg 4, Table of Site Screening Levels. Screening values should be
presented on separate tables for human health and ecological concerns. The EPA
Region 4 Supplemental Ecological Risk guidance bulletins should be consulted for
the ecological screening value for lead in soil. The acute and chronic ecological
screening values for lead in surface water are reversed.
Response: Comment noted. The tables will be separated in Section 1.3 to reflect
SSLs for human health and ecological concerns. The acute and chronic values for
lead SSLs in surface water will be correctly stated.
4. Section 1.4.2.4, pg 8 -groundwater assessment. The last two sentences appear to be
contradictory. How is it known that "Neither of the private wells are believed to be
downgradient of the Site", if "Previous investigations have not assessed groundwater
flow direction"?
Response: We will further clarify this apparent contradiction by editing in the text
describing the topography. It is a reasonable interpretation, based on what we know
about topography and surface waters at the Site, that groundwater flow from the Site
is not toward the private wells, but rather, towards Lowry Mill Creek.
Response to EPA Comments August 2000 Johnson Controls Battery Group -Winston Salem
Page 13
•
5. Section 1.5, 4th paragraph on pg 9, 5th line on Page 10. The statements that "lead is
not readily soluble in water" (pg 9) and "Lead is typically relatively insoluble"
(pg 10) are inappropriate generalizations. What is "typical"? "Relative" to what?
The solubility and mobility of lead are highly dependent on the form of lead, the pH,
and the hardness of the water (STSDR 1999). Under certain circumstances, lead can
be very mobile, soluble, and bioavailable. More explanation and discussion are
needed on this topic. References must be provided.
Response: We thought the discussion presented in the Site Conceptual Model
regarding lead was appropriate, and generalized, based on what we currently know
about Site conditions and the fate and migration of lead in the environment. We
understand the relationships between solubility and mobility of lead, and its
bioavailability. However, we are not anticipating extreme conditions, and so do not
expect extreme results. The conceptual site model summarizes known and expected
conditions. However, it provides a basis for launching a scope of work, the results of
which will be gauged against the conceptual model. The discussion is meant to be
general and additional references will not change the model. However, we will do a
factual review of what we have written in our effort to reduce EPA's concerns, in the
referenced areas, and provide additional explanation and qualification.
6. Section 3.4, 3.5, pgs 21, 22 -toxicity assessment, risk characterization. The
assessment of lead for human health risk, notably different from assessment of other
chemicals, should be discussed.
Response: The toxicity assessment will include a discussion of the different methods
used to estimate health risks to lead in the human health evaluation component of the
risk assessment. In general unless soil lead concentrations are above 400 mg/kg on
average at the site these alternate methods, such as the Integrated Uptake Biokinetic
Model (IEUBK), are not used because it generally believes that soil concentrations
below this level do not pose a health concern even in residential areas.
7. Section 3.5, pg 23 -remedial goals. "Preliminary remediation goals (PRGs)" is an
inappropriate term here. PR Gs are to be used at the beginning of the investigation,
before any risk assessment is performed. At the end of the risk assessment process,
Remedial Goal Options (RGOs) should be developed for evaluation of remedial
alternatives. For an in depth discussion of RGOs, see human health bulletin 5 of the
EPA Region 4 supplemental risk guidance (EPA I 995).
Response: The language will be revised as suggested to conform to the EPA Region
4 supplemental risk guidance. It should be noted though that the end of the risk
assessment process is somewhat nebulous and in many USEPA regions the term PRG
is used until final modifications and evaluation of the PRGs are complete during the
FS stage of the project.
SGW /vlr/ndj/DSB/DWI I
\\MAD I-SERVER I \Main\jobs\1242\ \ 79\l 6\wp\rpt\93_EPA Comments.doc
\242179.16120101-MAD-l
Response to EPA Comments August 2000
Page 14
Johnson Controls Battery Group -Winston Salem
'' '. ~::·:;f
JA.MES B, HUNT JR.,., 1\:;.
GoVCRNOR
WAYNE MCDEVITT
~::[J1;::;~i~l~rii,
t·/\,;::•'lc:,,,,:,1.:;t(1~@~· If~ rt-/1-1.~'J;i];:.:i.'l'~:. -· ~{w:
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
NORTH .ROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 7, 2000 01v1s10N oF WAsTE MANAGEMENT
RE: Comments on the Draft Engineering Evaluation/Cost Analysis Work Plan, all
Media
Johnson Controls Battery Group, Inc. (JCBG)
NCD 000 770 487
Winston Salem, Forsyth County, North Carolina p--'.,..._,~,).l;';t:._.1:'-;i~~-"114 f!...(f'.;-.--.. . .; /~,.l~.:tf?-.-.,;,1,i.:,.:· ..u!;'~i~~ • ":, ,WIL:,L~ J.:.-_~EYEi!,'\k~ ~;~·omE~,l~~r~W:f~ ~&J,t;i;c;;;:~\,:,-,~::~ Dear Mr. Flores: ~~-(~;j~tlft~i~~i~: ~~':s-tt!~;t~~ · The Draft Engineering Evaluation/ Cost Analysis (EE/CA) Work Pl~n, Sampling (<:,: ;:~~;3/,:•' ... ,,,:,,i../'/'~i't and Analysis Plan and Health and Safety Plan, dated June 2000, for all media of concern ~\f .t~ff·iF ::~\if at the J~hnson Controls Ba~tery Facility, located in Winston-Salem, NC has been received L·,,>,.J~""·~.,.-'.1'~'Ji and r~v1ewed. The fol!owm_g comments by the North Car?lma Superfund Sect1on_are fl·-: /-,~' '1~".'i· sublilltted for your consideration. When the EE/CA and associated work plans are finaltzed t .,J J ]-· /~ please have JCBG ".1ail the _NC Sup_erfund Section a signed/final _copy for our files. The t:"' "i "/"1i ; ~ NC Superfimd Section part1c1pates m the cleanup of Superfund sites under a cooperative ft \ ! J ,.;: ~ /; a~eement wit~ the US E: A and therefor~ should. receive_ copies of all do~uments and it. . i / \ [, M given opporturuty to part1c1pate m the Scoping Meetmg and m all future technical and legal '.[ / / <1, f" 'i ~eetings associat_ed with this work. It is recommended that a meeting be scheduled to l: ~/,. f~ .. L~ discuss the agencies comments and JCBG's responses.
~Jf~~!!.!.!J Engineering Analysis/Cost Evaluation Work Plan
General Comments
I. The Administrative Order on Consent (AOC) and Statement of Work (SOW)
requires that site characterization "will provide for a comprehensive understanding
of the nature and extent of the contamination at the site." This EE/CA Work Plan
(WP) is not comprehensive in nature and extent. Volatile Organic Compound
(VOC) and Target Analyte Compounds (TAL) (other than RCRA Metals) are not
included in the Sampling and Analysis Plan (SAP) as required. There is a major
tributary to the northeast of the JCBG Facility that has no proposed sediment or
surface water sampling proposed. The maintenance facility and other areas of the
facility are not being investigated under this EE/CA.
The AOC also includes areas of the facility where 3000 Gallons of sulfuric acid was
spilled, where lead oxide dust was released to a I acre area, and 1000 gallons of
lead oxide and lead sulfate wastewater was spilled. The ooint of release of each of 401 ODERLlf., ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919-715•3605
AN EQUAL OPPORTUNITY/ AF"FIRMATIVE ACTION EMPLOYER -so% RECYCLED/1 0% POST-CONSUMER PAPER
Mr. Luis Flores
7-7-2000
Page 2 of5 •
these incidences should be provided on a Figure and details of facility actions taken provided
in the site history section of the EE/CA. It is recommended that the EE/CA initially be
"comprehensive in nature and extent" then source areas and contaminants of concern can be
refined during this EE/CA.
2. The NCP and the AOC for this work requires both Federal and State Applicable Relevant and
Appropriate Requirements (ARARs). State ARARs are not mentioned in the text of this
EE/CA or listed in Table 1-1. All State ARARs must be included in this EE/CA and if State
ARARs are more stringent than the Federal ARARs they will become the performance
standard for the various contaminated media. State ARARs should include as a minimum the
NC Groundwater standards, NCAC Title ISA, Chapter 2, Subchapter 2L; NC Water
Pollution Control Regulations, NCAC Title 15A, Chapter 2, Subchapter 2H; NC Water
Quality Standards, NCAC Title 15 A, Chapter 2, Subchapter 2B; NC Air Pollution Control
Requirements, NCAC Title 15A, Chapter 2, Subchapter 2D and 2H; NC Solid Waste
Management Rules, NCAC Title I SA, Subchapter 13B; and the NC Hazardous Waste
Management Rules, Title I SA NCAC 13A.
3. The exclusion of these details causes some concern as to the intent of the J CBG
representatives and is not a good way to start on a major project such as this. It is better to
start out conservatively and relax analysis and source investigation as contaminants and source
areas are eliminated by proper testing and evaluation.
4. As noted in the above comments and with the following exceptions this Work Plan seems to be
adequate for an initial follow-up investigation phase to further delineate the source areas and
determine the impact to groundwater.
Specific Comments
I. The first paragraph at the top of page 7 and Figure 2 state or show that lead contamination is
present in soils of the "Lead Oxide Unloading Dock (LOUD) Area" at concentrations exceeding
the EPA's Soil Screening Levels (SSLs). Figure I shows two additions to the northeast of the
facility at some time in the past. Before these additions runoff from the LOUD Area and the Acid
Storage Tank (AST) Area may have deposited sediment into the drainage swale northeast of the
Facility. Please provide at least 2 screening sediment and surface water samples in this drainage
swale and in the downgradient stream. Specific sediment and surface water sample locations can
be determined in the field.
2. The second paragraph on page 12 indicates that the potential for suspended solids causing
unrealistically high lead concentration will be addressed by sampling and analyzing both total and
dissolved lead samples. The State and the EPA do not recognize filtered samples for surface
water and groundwater samples. Confirmation of performance standards cannot be made using
filtered samples but for informational purposes filtered samples may be collected and reported along with unfiltered samples. Care should be taken that surface water samples are collected with
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affinnative Action Employer 50% Recycled/ 10% Posl•Consumer Paper
Mr. Luis Flores
7-7-2000
Page 3 of5 •
as little suspended solids as possible. This procedure may include recovery of surface water samples that allows suspended particulate to settle. Then decant the more pure water from the
top of the sample. This procedure is accepted for inorganic contaminants only.
3. The Second paragraph on page 13 states that soil samples at 6 inch intervals will be sent to the
laboratory for Poly-Aromatic Hydrocarbons (P AH) Analysis. It is recommended that an organic vapor analyzer (OVA) be used to screen the soils for PAHs. This information could be useful
during remediation of the soils and sediment.
4. Section 2.1.1.2 indicates that contaminated soil samples were detected in composite samples that
are now located under building additions. These conditions may also exist under the building
additions at the north end of the Facility. Land Use Restrictions (LURs) may be required in these areas to assure that future land use and development considers Human Health Risk during future
construction and renovation at the Facility. This is especially critical when soils or groundwater
are disposed off-site.
5. Section 2.1. 4 discusses the groundwater investigation and states that 'each monitoring well will be sampled and analyzed for SVOCs, hardness, and total and dissolved RCRA Metals.' It is
general practice to sample and analyze groundwater, during the first sampling event, for VOCs,
SVOCs, and target compound list inorganics (all metals). If the groundwater data is consistent
with the facility history/chemical usage then Contaminants of Concern (COCs) can be established
to specify the groundwater contaminant analysis.
6. Section 2.1.4 on page 16 references Figure 3 for proposed monitoring well locations. The general locations for the four wells shown on Figure 3 are good. However, to assure that the aquifer
characteristics do not change downgradient of the facility it is recommended that 3 additional
monitoring wells be installed at a good distance downgradient of the facility to the west. Perhaps
these additional monitoring wells could be placed in the area of proposed staff gauge SG-03 and in the area of Sediment sample SD-16 and one well to the north of the facility.
7. The third bullet at the bottom of page 17 states that a background groundwater sample will be
collected from one of the wells shown in this report that is considered up-gradient of the Site based on the calculated groundwater flow direction. The background well should be well up-
gradient of the general source area and must be non-detect or at background
concentrations for all Contaminants of Concern (COCs). Private well concentrations or other
off-site wells may be used to establish background.
8. The second paragraph on page 19 misspells the word 'completed' twice in this paragraph.
9. The third sentence in the fourth paragraph on page 19 is either not complete or unclear. Please
make appropriate clarification.
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An EQual Opportunity Affimiative Action Employer 50% Recycled/ 10% Post-Consumer Paper
Mr. Luis Flores
7-7-2000
Page 4 of 5 • •
Sampling and Analysis Plan
10. Section 2.9 on page 7 discusses locating the samples by using a survey. It is recommended that
the locations of all wells, soil and sediment samples also be located on a Geographic Information
System (GIS) including private wells of residents around the area. By using the GIS, sample
locations can be easily located in the field regardless of future development.
11. The word "Analyses" as used in the Sample Rationale/Comment column of Table 1-1 should be
changed to Analyzed.
12. Sample depth is not complete on Table 1-1 for sediment sample JC-SD-26 through 30. Sample
Depth for Sediment is generally listed as "6-inch intervals to basin bottom" and soil sample depth
is listed as "6-inch intervals to 4 feet". Please change the sample depth for JC-SD-21 through JC-
SD-30 to be consistent with other sediment sample depths.
13. The Decision Rule listed as number 5 on page 1-10 states that "groundwater sample results will
be compared to US EPA MCLs." Groundwater samples should be compared to ARARs, which
include the EP As MCLs and the States NCAC 2L Groundwater Standards. The ARARs list
should only include the most stringent of these standards.
14. It would probably be appropriate to list my name as the NC DENR representative in the Project
Organization and Responsibility Section on Page 2-1 and include the Superfund Representative
under or along-side the U.S. EPA Region IV, RPM in Figure 2-1.
15. Details for Section 4. 0, Sampling Procedures, are not provided in the SAP. All appropriate
details should be given for each Section of the SAP.
16. The Reporting Limits (RLs) listed in Table 1-1 should reflect the best analytical methods and
include peaks on the graphs that are below the detection limit. The Laboratory generally lists
concentrations that are noted below the detection limits as "J values".
17. State ARARs should be included in Table 1-1 or in a separate Table or in a similar table that
includes the most stringent ARARs per the NCP.
18. The Acronyms and Abbreviations Table provided at the front of the Quality Assurance Project
Plan (QAPP) is an excellent reference. However, many of the abbreviation/acronyms in the some
Tables of the Report are not defined in the Table or in the text of the Plan or included in the Table
at the front of the QAPP. Examples are SPCC, CCC, RSD, GFAA/CV AA, and R in Tables 3-2A
and 3-2B & 3-2C. Please re-check all abbreviation and acronyms to assure that they are defined
appropriately.
19. Abbreviations and acronyms are defined in Table 3-2B but not in Table 3-2A. Please include
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An EQual Opportunity Affirmative Action Employer 50% Recycled/ 10% Post-Consumer Paper
Mr. Luis Flores
7-7-2000
Page 5 of5 • • '
these abbreviations in both Tables since they are not a continuation of each other.
20. General and specific comments noted above should be corrected in all associated Tables and
Figures and in all the related text of the EE/CA Work Plan.
The State appreciates the opportunity to comment on this document and we look forward to working
with you on the project. If you have any questions or comments, please call me, at [phone],
extension 341.
Sincerely, (7 i ~ • ~. ~{1cL,,·~V\
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirm.ative Action Employer 50% Recycled/ 10% Post-Consumer Paper
lJl 'dOr "' UMOJO
;
' . . _ ,. ,--•"' .. ' /
' •
\
\
1 N 0
u '
\
\
•
\
. ~""' "!A9tl ~licW>ft
\
" {
,J·
'
\
\
\
\
' ' '
•lO(J
"; '' --------· -~
\ \
_/
I
~-------
10WNOO
>.1fM10
SUOISl/\9~•; · · o e::monssi
c·;
:~,'.:.;.,> !
/
_..,.
·-_, "-/{?
' ' .'\·,
'
,
/
t
J
, ,
'
/
----------
' '
•
•
tJOll:J:IS QNO:llft · ~
~ 1,1.): r:::1
, \t'N 17 O<:J\t'JlUI ' ·
dnO<:J'.:J ,l,Jl3il\f~tlON 'V<J37\t'S SlOtllNO'.)
.fi01SNIM
NOSNHOr
S.LN3r4103S 301M3.LIS NI SNOI.LW.LN30N 00 0\131
I •
--
•
•
•
•
•
•
•
I
• I I
/
0
Iii ~
ii!:
/.--
_,<. , _-:;:· .
/
I
/
----.. -------
~ 7 f:°'
0 " .. :,
·1
I
I
•
I
I
\C
' 0
0 • .,
C " •
" •
•
•
•
•
6•p·r.:1\a av:>\IOI\I0\9iri\eo7\ ~ sqor\:N
!
\
1::i1 'dar ""
' '
\
\
\,
\
UMDJQ
. \
\
-
\. •'
-V' :?\~ ~\-~t "' ' -' en
. '_.f:f;"IS \ .. •· .. ·.
<cJJ'J ,. \
u)
0 rj)
/
~,.,
Ill~ ~UIHJ.»liDUDe,
\
\
\
\
\
\
\
\,-
;,\';'
. ' :.-..
00DU01'1 JOOfcud
~ fDO!U(I09l
--
\
r:J)_
'° 0 rj)
)'..
""
j
/
3JDQ
/
.;
/
/
' --·-
~
!DU~J<Ud pori l~
li?JllpllDIS ~lfdn!D illl\'nO
·u0510M Nat.Uo51u~ JO JOAO.Kldo UilJl!J~
94l lOOlfl!I"' pasn ~ lOU AOw puo UO!lO:>!fddo
:l!J-!::.ads o JOJ ~laMip uaaq soq :µ.iawn::iop &!"IJ.
, ' .'I ;. < ,. \.' , ' • , • • ' _, • , •
~
VNllO~\fJ Hl~ON
_J
'~37\fS-NOlSNIM
'JNI 'dno~o }._~]il\f8 SlO~lNOJ NOSNHOr
(87SS 003 -1l9JV seinqnqµJ. pewvwn pu11 spu11p11ft\ e11suo 87SS 003 -118.l'f su1sve UO!IIIPIWIP8S ~suo 87SS CNI -118.l'f JU111d
----------
~
' ~ •
"'<•• A-,_ '
' v'
~
•
--
'f',-'lli»-~
---
0 0 ITT
' rn v, •
-----
-
'
S110S NI SNOIJ.WJ.N30NOO CJV31
~ v
' rn v, •
I
I I
,/
ill N I ill •
I
I
I
I
I
I
I
I
I
--
/
/
/
•
-
]
C ·c
Q.
I
---
..•
-
l..,.
(
I
/
/ -
l'.ll
.,O(]
'dor "" UMOJQ
--\
\
\
\
\
\
\
Vi>I
\
\
'Ot!:J
\
\
.-6aullft l=»f~
~ ID:J!U40lll
'HMO
SlUDJlnsuo::,
a::>ucuaJa~
~ paAOJdcfV
.<a podo1ar.oo ·p1udd'f'
' '
/
~Jl)Jd l'091 1mllNro
•PJ0PUCllS '!',Id~ AJ.f1'WnO
"" aqoa
\
,
' . , .
SUO!S!Aa~/a::>uonss1
' r'.,.'!.' .\~---~ '•
\
, ,
. I .
r I
I
I
·-----------D'!.
,.,-
·u~DM. .<.tewo~oi, JO 1D,\0Jdd0 uenµM
a41 1no1rn111 pain aq lDU .(ow puo UO[lDO!fddo
:>!J!~S O JO! padOl9MP u~ SDlj lUlilwn:x>p S!4J.
OT ,•-·· '. i ,. ' i ·, '
'
sasoa1•~
'
i
I
~ NOIJ.33S ONn~lJ 7 ' .-\'.
'
liS i
D
•I
I
'•-· i -' ~--2]' ' .
'rf37VS~OlSNIM VNllO~ 0-Hl~ON
'JNI 'dno~~ )-~311\18 SlOtllNOJ NOSNHOr
81SS 003 -89JV 881,18¥1<1!,IJ. pewewn puv 8pu&p8M e.-uo 81SS ONI -89JY 8U!888 UO!lvPWIP9S 9118UQ 81SS QNI -89JV IU81d
,
,
'
I
----
"<,.,,.,
' v'
~
--
1,~i;,..___
•
----
0
0 ,o
' rn "' •
----
S110S NI SNOLLWJ.N30NOO <JV31
•
/
I
I ,
----
I
I
I
I
I
I
I
I
I
"' -~
"'
------
/
•
(
~ • -C ·c
~
4'l', 1 ✓' ' • I/
\
L • ~
E a z -• • L "'
\
\
LL.
0
~
---
J, /, X Jc.j ' ' (_ / J .
1i: ~z Ii
L s~e • ~ -E <D 0 a N-5i1 z no g' N f.O ·i ro ......
~ a .....
□NO
0
0 :I
m
z
I
/
/ --._ ----
6MP" 1.:l\CJCJVO\ 10 I \I0\9l:£l:\&m:\vqor\:N
alDG lJl 'dOP .<a UMDJQ --... ----
'
'
V'l>I --
L,_
0 n
I
0
l/l
·0~3 ...
"' st
I ••
[!J ;:='
Ul ;:r, • [_ ·,
I.' ,1 •
.-t,ou°" lN!"Wcl I
-~ ,UO!U~Oll_i
'HMO _, , ' . Sluo11nsuo:;i a:>uaJa4a~ ,(g pa.11.rudd,/ .(s pado1a,,,aa "PAJddv .<a ... ----I '•--~ .,',, •·I ' QjOQ suo!S!A8~/a:>uonss1 ----
fl')
-()ti)
;~.•
•
...
/
'
·umqoM, ollawa6p.10t, ,10 1DAO.lddo uanµ...
al(l 1no1n!'I'-pesn aq \OU A"DW puo UO!lO:>!lddo
:>!J!:>ads o JOj ped01a11ap uaaq soq 1uewnoop S!4.L
--
• '
'
•
'·0 --1
I ",• -, ' ,._.
'-.
•
•
•
' 7 ' I ' ' sasoa1a~ --
,
:.f n
I
0
Ul, ••
<(
I
• I
I
/
u
C'-
N
I
0
l/l •
/
i '
OJ • ..
I I
'. ."' . . ~-;
c,
co
"'
u
C' ; •
•
r--
st
I
[D
l/l •
----
I •
I
I
I
I
I '.::
I
D
l/l •
O'
tj-; "' .
I• D I.I'. •
•
•
u st n
I
0
Ul
.JNI .. --.,,.
i
• • •
v J L(~'/1.J;,.,:1 1rlf, -, -' ·-'" I -r-I ·~ , I I ' I~ ; ~~-/}/J/1 v'NllOtl\iJ HltlO~~~S"r 8~SNIM 'dnOtJ:l J-tl311\i8 SlOtllNOJ~NHOr V3W SCNVll.3M H.LnOS C z § • . ~ ~ • -C ·c a. • " .8 E , z -• • ~ V> 0:: :::, i 0 0 C\I LL 0 ~ / iz 0) LL l:o " g~-• ~ -E <Do ~ N .---5J t') 0 g' N (D "i co .---11 ~ 0 .---o NO m z 0
6Mp·NVld-6.:!\00V:>\LO I \10\si:1:i:\eoc:\sqor\:N
O' ' -0 IS ~ .,.--0 Cl < 0 / 0 / 0 / C) ::'·l n OJ / "° 0 Cl / " D ;) 7 / ~ ,_ m • ·! " i ' g' ~· ~ 1 s o . -• • ·,c ::;, . -"'-$' -a , ,! -;; C C a -C' C· . -C 0 ~ " ~ ~ 1 -~ -" Lr 2 ·" c.. i..,, ~ ii () _J ca -• S'z =, 0 o,, C • • On ,_ 0" C Q C -2~ f. ,-u 0 •u> 0 • ~~c -. o. ., E <no ~ c: ·I 0.' C: 0 n ,, ,, C ,_ .2 E _: _, 0 ~ g e ' 0 • 0 O r~ 0 .,_, 2 ~ -~ ~~ 0 , ,' I ! I ' ' I I I I .so--.SD-288 --.,S8-48 I so-11• I ,// / ,/ '/ ,/ ....... --,' 51,;.o. \ i, / -= I SD-MA•'--,. • S0.228 / ,/ 80-Me '>, 8;..~_:._/-- • I / ,-I ---// // 80-23. / I / .SD-238 ,/ /' / .~.,:;.., I ' / //// /" . i / / / / /// J I // / // --/ / / / -('~ y, //'/... 0\)-.J'.,) / I • / / I / I I I ,-( -) I i I I I I I I \ I \ I \ ' ' I ' ' I ' I ' ' ' ' \\\\ \ \ \ ' ' I ' I \ \ \ '\ I I I I \ -I I I \ \_ \\ \ ' \ \ \ \ \ ', \\ I ' ~ ' ' \ ~ \ ,/// ••' (/ ,------' ' ' I ,--./ i I ' ! ,:._ I I A \ ~. /--~< '-z; .-' / -~\,'--' / C .-• SB-45 ,,_ ' \J -\"' •so-aoe '-l\ I 'C' ' . ' ! I I , I • . I ......... / 1~i ~y 1--,1 /1....J: /"11' .80-30E I / I I I I I • I / ' -' i i I ' ' _,, ,/ e8D-30A .--; ' Sfl-4G I ' ..... ~.e-: BD-2QA •"'"" .so-.. .80-290 SfJ-~8~29 e8D-Zl' 80-28. \ \ \ \ \ ~ ' ' i\ / / / / / 8D-21f\.. 38-•Um SB-491;-..., SB-49.'. 9S0-21"A .-.80-290 . -... S8-47 ' ----------........ .80-348 -----::::--. -•.,_-............... .80-27F ·-.. .-\, ',,-I ,-. -. \ I I 1)\-\-->''' \_, ' c-· \' I ,, ' h \,✓\ ,-\_) 'd\".\\·,\r•-1 ,\..--.0041C ---.S0-278 "'·\,_---....._\ ..,_ .... \"._ ~-\'-. ______ _ ...... \ \,"\ \,,_ ,, ~ 1,11) nC, i----'-~ r, .·· ,,,-\ f;.., ~\ u --__ ,-[':/\?' c~ ' I I \ \ ' --\ I -' ' ,)\\--· ,°' ! \.'·'.· , i ,,,;-2,\ I I y,, \ 'i. '. 1.-_, --------·80·270 ---.:80--17-•so-11 .... .,. I I \ -\ --,. , ,-',-6003 -, \ --........ '\ I • ! I \ I \ \, ' \ -'\ ' ' ,.__ ', \ \ \ -\ '::::.----~ ..,_,. n -----\ \ \ \ \ \ \ \ --\,, ·c~:. ~~--. ------... -------~ ~"i-, j \ ~---~... ao-oa -.. \•' \ .Sl>-04 \ :.,.... __ '-\ --------------, I \' :, . :' (C-~ ---... --------... .I I ' ' ' ... ----,") '-. __ ' , I'-' /·: ::' -,-,_ ., ·-:•, ':C-r "-., "' ~ -' ~SB-3¥! ") •, I SB-::16 SB-3:J'A _, " ., .. ~ 'I-.,_ -' ••-d• -~ 's 3 · · S8-528 SB-32 -., -3~ : . ,, ·•-"-._ ,', _.~ -; SB-33Eli'-l• -. SB-32A •#' -'\, .,_ _, --_)S -• SB<l-6 58-35B "II' ·,..,SB-"3F _; '\, SB•:J4A y• •, ,• 1 SB-3◄C ~ ~-' i 1' SB-34E SB-348 .... __ \' • :' i ,:0.,. SB-34~ i,:_:' l ,'1 -.. '1 ' ' " ' A ---, ,•"C'-e, II ' ' . 'SB-34F -1·' ~ I • j, _ SB-34C ··:. · ; ~--"; -.~ -;;--.-~ -~ ·" --'~-"""'" \. /'f .SI -' --/ ~ ...... ,, /_/ -' ' -J _, \ ' \ 1,, i --, ,, ''-' ' \ __ ,,,G1''·-' // --~-~f'"''-:,,r / \ \: ' --' -\ 0 ,.-,,N-1'-'-"c\-,, __ ,,,--. ,-I I 'I \\ \' ' ' --) __ .--'-,,11 ....-----J--'-' ' "''" ',--11',\ \'-\\_) .. '0}-~•'-----,\1 ~ v' :::-' ',-,,~, " \ -, -:'---... .,,,. ..,,. --~ -',;,'--' r \ \ \ .... SB-53A ·-\jl,1)..\1 i I:.' ' \ \ ' "{ \\ t p,_(,\'--"-' \ :f;;.'il. .. \ IAW03 ,.,,. SB-538 _ ' 1-SB-S~ _ ,....) ~B-53F ',, $a.s:1o~ ~•-,,o· , B-28A , ,_,fl ,,1,; _.,,---• "" " , s "" '"" ., / . ..,,..... "' ".'tr--., , ""'°"• ~ '"; ~ SB-2'A "'SB-28-~SB-53F '/ --~SB-SI~ __ _ :_\ss-s~ 1 ' -...~ "~-/, se 3oe ",. _.,, ss-628 ~ ,-a~,,~ -, -1·-r-, I , :1• h 'i ,\ ,, I,., ' \ \ \ •so-01~ so-oo -; 0 SB-27 .__ _,. . ,, -,. • SB-3 -o;-' --, _ • 80-<JI ~ SB-27B ('.;" -•se-Joc ...__ _ -·-'\ ) -:. ••-1• \\\, ' . ·"\---\---,'.J~,:,1_,._::: \ \ \ ------+ I I I --'--<, \\""l\'-1 I ~-,;-•N' I\, I J,~ I· ' ~ I I \ r' \ _, -' ',, '-\ .-. -' ·.\ . '' ,.~ . <,• ' ' , . .', _ .. ,::' . ..-_-~ r '.;:r: C• ~-._.-' • ,_ --~\ ', -. \ ' ~,, d-_,..,-"_, ... \ . · .. ·, \; ' i_ \ \ -\ \ \ \ ' -\ ". ',-, ' ~ '.'' ,~--;., . -'::. -;; .,_ \ ,-· -,,_J, -;,. I ~' ' <, \.' \ \ \ --fa.~ ---~ ~ ~\ ' --M~~-' :.j,;.:., \-' ' ' \ ., \,,' ---._.... _,,. ~--' -\., '' _, ' <" -, ' ' -,,.--,; --~-,cu-:-:-'" I-"\ 'I'' p,\-<. ...-· .,-, 01·-l ' ~ ,-..\-,1 \ \ I ~\_)'-'\ ,.\ =t, \ 'se-40 ~--'s , ·"•8~2 ' --_ -__ \D,. ,_,, \\' -~~ _j _ _),_ -4 ' ·. ~1 · \ -,'SB-38 ·~ ' ' ' / · C-i \\",il_J C'i-,.\J · ,~r, I-', \\ \)\1 l'-0.,\._;,V ,. '., ,'\ \t\ 1----,\'\ \ ( 1_,...,. ~\iJ: \ i-/'s( -~·::· <• '-\---~-'-,~· \ .. ~\,.,_ \ j '.~..ir.,_,_,_.-,;-\_-..._ ~ -,~ \:' I\ /AK _r' \\1 V "sli-4JC Hl. :, 1,1,\ ---' '. ,., ¾;' ·-, -.'-':\ ~-.,, ~ ", ~ ' ~~ot-,\ ' ' \ I<> \. ·,\', \\\ \ 'i~ M~' ·Q;, .!.,.SB-43B ,6 '' ' ,.. -oi ·" ' ~ss'.q2 ~ ,"".,ss-o~\ ~ 'i \ ~l"-1' ~\-, \,~ V\ \ ·,\B-10 ~-,._,', _ SB-43f ,.:;, "Ji.". ~ -S8-4 I,~ t·;,.,,_. "rSB-07 1 -~·cje -••-o . \.\ <tA oq# '•.~ le~~-08 ' {.\ "I ' I \\\ \\._\,~ ..,, ' ·.\ SB,.~-. SB-,-4,_D\ ,\}; -1,-~~8 •-.. ' le' ,"J'.'., "A___ .,, , . . 1'$B-4411 ~ I -~ . I ·:~i\ \._ ',. ' ' -~ '· ', ) ' _, .i:,i$1S044C ,-·~s--o9l)-· l"" , \ -~:Si>-15 I , \'• ,\ , \ -, . ._ \ ' ' \ \ \ ' ' . ' ~MW01 ·---; ' \ \ \ \ \ .-~r ' -, ,, ~Y.,. '/, ,, -, .. ,J -, 1/, 'n --;"/, ·7, \ \ -\ -:; ' --··--\ \ \ \ \ \ '':'],, /1_ 1/ -,·, "' C -. ~-'< ~.; ·_;' -l -.·. ---~ , . \' \ \ '" ,"'' ; ; / -.. '/ / '' , , I"· -; \ /; .,:, \; ' . , ' ' ,-,.-, "<1 ,, ' .' .:.., -I ' <_: -4 •-·-,,' /:, ', " 0 ' ., ', ~-""' '<;'' -*' ' I ·"'· ·-· '<.' --~ ' _,, ' \ ' ·-"' o· "'' " ,\\ • ' '• ':-/ ./ ._-...\ ,", '<;' !'.-,, t\ ,, ,---, ~--..;',, '..___ . 0"' I ;,-, ~-0· *' ' ' ' / \ (_-\ f'1 \ ,,}1 ':"" . , ' r·• __ -"r' \ V 'I'' ------0 1 ' _) <¥ , •0J \ ,) i-, ",clN ,,, _ -., -\ ,--' ----., c,' ''--~ ~ ...... .............. __ \ \ \j f-""...) \ \ \ ~--,, \ \ \ .-.... \ \ ~: --P-.,.,-\1\~1 .,--I ' I I\ ) ' ' ---,'\~I--~\ \ \ ._., c\-\_ '-✓\1..--', C, . ..,-1 ,......-.J' ,...-,-p\ ' 1 \ \ \ (" • -· ,J>I-''' ,---,"'c ('-1i-Ze-r; l\'---,,1~J \ \ \ \ \ I--, -'_,, ' \ \.-•'' \' --\ \ \ \ -\' -" ., . ' '.--. ,' 'i•'. . \ ' ---·>-· '\ • S I \' --' ' \ \ i ·, I\' I i I i \ iJ ' ·, .. ,, '/,-,; __ , ' ! i' I ' I /';' / •-...__ ,,, ,.,_ ----~--,.,., \ ./ I "..-MWO~ '-...,_ --I -·.a-~ ,: --. --.-!1 s~lso ,.; "-.. 1, _. -·-..... ' . S850C ~., Sf!'l?A .. '.:>B-5\lll -; ,......_ -",Sfl·~2~ SB<~E se:,::rn t ,.,, SH·£6B SB-5,0 ', ,B-asc., >I, SB '" SB-SOE SB-bQ, -'\,, • . S8-25S ", " S6-~',f,6, SB-23B ~ JI\; SB-23A -~ ·, . '\'SB~23 ,-' •.; ,---.....-' --' _/ --~-/ I /, /"1,_ r·' ,, ·-": ·,., . r:/ .~-' \ ·,;' \ \ 't',~~,~-I -\ ' ' ' ,._,,2 ·-,_ ----,, --i:~--.......... , 80-16 -. \ \ \ __ ,\ ,.,· / ~\ \ \ _,/ \ ·-_____ />GIJ-13 -----~,;-------• t)'' \ r'i"\-\,t .... \ \,_ \·"' ,-,·,,.,/.--1'1' .. , ,:" \ 1 I\ \"s \ 1-'\ _,--, \_ \.._. ·'' ~-.. ,('\ _, ~-1\"-.I \•_\·,_,.• ,.--, t\'---1\'-l. ' t> r'• •--' I ' ~ l ·=-· ---:-' A0-10 ,, -•so-12 / \,>· I I /.' --_J...-' 1---; -I-/-. ·, ---' ' ' I I ' '·-... ,':: ;,. "-:') ,_ ,; ,, '' ·-' ' I I '/ ' I' ·.._, -, I ·--c,· " ~-.... ~-., ., ,, ,t-' / .. ,, ,,. S::,-0 ' I ~ c,· .:i.-· '-l:-"1' ,., -• .. -, )_~ I • ' "" !It _, ~MW06 l--\ i ;,1.He ... Sf:1:.! . ~ r: """ ' : j SB.•2'1\-i I i f :.i ... SR-<'D ""' ' --'\,, ~ ·:81:H!l Sij-17 ~~ ·-· -4~lJ--,~ ., '' /.; I '.'-, ~]--; ,,{' , .. , ,_ ;· '! ,, h'-, _. .... ,,,~-, .__,•/--s :-,•,/ -'-: . ' ;...., .. ifi.i ,<, ---•_';L, '\ ... ,_. i .• ,'--i -1\. ,·, : •"':°' ,,; -0. ~ ':'--.; ,--._,. = _f.,' < ' C, -" ~ I / -{ ,· ' i -~ j / I "" C, \Jc;' c:, -, '--,, ' ·, , '-/ )i.) '-/:! :·, -., ,; I i, // -/ ., er, ---< " _,-:::; -. ,-:; ~ --"'·· ¼j ~-I.EGEND ... ~W04 ...;crn ",,-SB-2:'!A .80-12 NOTE Mm\-::,=:'-~::; ·,'/EL_ l•. )\ ) I.._I U lvl 8 EFi LCCA: ON SIA~~ GAJGE A~D NUMBl~ _JCA-101'-I SJRFAC.: WAl~R SAMPLE ANC NUMBfR LO:'.:ATIO~ SOIL ANI) BORie.•3 ~~UMBER ~:JCA-ON SEDIME',n ShHPL[ Ar'-JD l,JV::3=..R LOCA-101'-J SCIL AND 01L.l LCCAT1::;N \j'JMBER BAS: I/Ar D~VELOCEO f~C)M SURBOQ51dwh.cwg, FR(l\ill!f ) ::ff TH:: J::::H~ R. t/c.ACA\,1S COMP.t•I\ 11·-JC.. =2:::SEARCf--RIA\J'.;I F P.ilJi•K, [\JC,'.T-1 Y""""'" 0 = ~~~ (\Ot'-'' 100 l.J7..r_ SCALE IN FEET 200 DRAFT ~-------I u _J Q_ 0 7 > m ' ' 0 ?; 0 c£ ~ " ~ 0 " > " n ' t ~ ~ < &;· s 0 0 t-'" C Q , s , a ----0 v ' a ' C a " " a 0 0 f cJ • 0 0 II) z 0 5 g C, z :J D.. ! i' ' " > 2 ~ ~ < w !::: II) P·i-ikd ,_, :., ~ _, 0 :, 2 0 " C a oc 0 u u z r, 7 CJ <£ CY (_') 7 ~ __J Ci CL --r ( ., >--Cc' LJ f---~ ['.] _, ,L f---CL -, '.__./';, '.,_) ___J z ~ ~-CY ~ f---2 ~ L 0 u z 0 IJ) z I _u __J <( C1 I 7 CJ f---,n z C) 7 3; ----.u• 5 2COJ S·1eel \Ju·'7~•e" 1) OF ---------------j =:rav1n; f"Jrrbs·,· LOB-2.326 01150-01 F12 MONTGOMERY WATSON <D I s-f/!'.!r\ 0 '~ ,, .. ,--·~· · ::-: ~ ·--. ' ::-I, L~ ~ ~; ,-,_ ,-.. ,_ L:-: ~ ~ ·-~ "-~ ('--:-;--x l "._J '. (' >~l
i I
,. '1
.. 'I
,. '1 /
.. '1
,, '1
•,' I
,, '1
,, • 1
,, '1
,, 'I
'•' 1
,, '1
' •. ' 1
\
N
'<1 5l
\
SNOllV::JOl 3ldrfVS 03S0dO~d
-
\
"-~--~~-
\
' I
/ ! . I
/
i i I
\
\
I ---_;_____
\
c{)_
~) .o
(/J
:I-
"
VNllO~VJ Hl~ON 'ri37VS-NO!SNIM
'JNI 'dnO~~ >J:1311V8 SlO~lNOJ NOSNHOr
-
I I
I I
!
/,
I !
.
l
i
\
' !
I I
I '
\
NOS.LYM AIBII09.LNOII
,
/
·, ., '
)'-
-----
, -
-----
i
\
i
------
:_· \
!
·----.::.-
I
i
J1v'O
\ \
-
/
' !
I
/
'·
I
.. ·-o3NOIS30
mu1r-ians
/ -·----------···-' ···--., .
\
'/ i !
\
\
i
/
i I I
\
\
/
----
0 ,,.,
' 5l
o>.<1
I
I
' ' '
\
/
/
!
I
/
/
/
/ -
t
' 0 ~
I '
ro N
' 5l
___________ N_o_11_d_1a_J_s_,0 __________ ~1-'_::8+=]lv'O A3tl
I
)
$0<1 □1>
' ' '/
I
I
I
I
I
I
I
'
\ ·.
I
I
I
\
' .
' ' I
·,·-..._,
____ :>--::
\
\
;0• ,,.,
ro
I,'
\
!
I
I
I
\
/ ·'
0 .,
ro
. \
I
I
i '
. I
/
i
I
' ----.i
-I
I 1-----
\,
' I
I
\
' I
I '
0
!2
I
.
\
\
i
' '
' '
I
f
I
' \
! I ' /
~ -
z 0
GJ ~
I • i
\ '
I
0 c-ro
I
I
/
-/
I !
\
\
/
I :
\
\
8
-
\
I I
/
\
)
I
I
0 aj
/
" .. . 8
/
I
/
I
j
!
i
I
/
\
!
\
/
I •
-
;1,1,,,, . ',.
.) -------------------·----------------------------------------------------------------.----, __ . I ~' "'' ··I :;, 0 0 s:, I I ~, u, o, I I ~, o, ,s 0 0 C n: "' "' o, -'1 o, o, U: ~ c.., _';;, ., g, •ii ~ 0 0 ~ I I ., c.., C Q ~ g ~ ) \. ' ! ,. _______ / \_ ·, . ( I ' ,-·" --.-----·---,• '/ / / / ·/ / . /' / "/ / / ' , /· / /, ./ . / ' / ,/ /, ,, / . ,/ / / / / -· I / / , ./,/ // ·>/ . ·,// , , \ '·\._ /C-00.8-'iW(StPb <0.002mg/l; <0.0028m· .. ;71) . , C-008-:50(8/9 Pb 15m1kg; 9.9mg/kg) \ . 06,\ . \ 'o ✓ • , 0 ', , JC-007.-SW(B/97) (Pb <0,002m_g/l; _<O.Ol)2~m9/I) ?• ' \ \ ' \ ' \ ' \ / ::, ... ,,._ -. ,, \C' / , , / ,/ ,' / .. / ·./"/_,/ \~. I / • ,,_ ·----,• .• ' ·, \ "·--.... \ -.... , _____ 0 / ,/· _,...) I I / / . / / ' / . I .. ,·/ / ,..---· --, ,..--, --, (\ / ----';,,< ·-, .• I , > I • ~-· ,_, -I ,LJC-.009-SW / -0c.coo9~so, -. ·, .'....: .. ,· .' . ) . ' , Q ("• ,-..., \_) .l <J · . / I , / , // / . / ..... ) -~ C, -.< y. \ -• I__; , , , , /' / ~ / ; -' ' ' / .· ,' / .Pb. <0.002m9/1;/<.0.0028mglJJ' Pb 22mg/kg; ;s.21119/kg) /' / , / / I / ,-, ' ) / ~-/ ,re,.,, . '".._;. / / ·-/ ,-1"·-~i. -~bl/. / / / ,/· .. / // ' /·~ t;~! 't~1~ ' ·-,,,, ' • ·,. ··,, \, __ ·,~. '· ·•,,, ' -----...)) / / ·c-~) , •. ' Q"1 ,j \ '· \ \ I ! ;\-----! ·,-;, "j ,~i ' ' : . i --J ! / -~ C-v I / / i \ I J-r ' t \ I \ \ ~ :. , ' ,,,.,-! I I / I / / /_/' / //// ;"-r I • •: C -\ \ \ ,:) . -., d\ \. -' ~ \ ' ' ' \ \ ~ -' \ ' \ \ --\' •. -~-:-U· -\. -' ' . __;.K-. . '" .. --. ' '-. -·,, ' \ . -,_ '•. '\'\_ . ', . "';': ~" '· ·-. ·<·:... . \/'1 ' \ \ '\ j_, ' ' -/ I ! \, \ \ . \ ' -----r ... -"l \, ~.,\,< ,j \, ', \, ·/' ... ;~ ~ 0 --~~'<',;;,_ 'Z'p. ✓. /. c ' ', \~ ~ ,~,. ~6-';z,90' \ ', \ \ \, ' ' \ ,\. \. ·-... \ \ ,_ \ ___,-:_ \ __--< --I ... '3/ .... ~ .,/ I ;'. -! ·-< glls\ \, ' -,,:, . \ . ' \ \ '. ' \ \ \ . \ ' ' ' \ ' " ' ' '\ " \ \ \ ' \ \ :'.-v! '-\ ,· \ ' ' . '11. \ ',.' \ , 'I> I ,. -, \ •~, I •,)/ '(~, -r' i \ ' \d . ; • , , / • "J / I ,-, I / "-· / ,, I • ,' : / : ·! I ; -/ ',,__1,.;_;· ... ·/•' .. ,:_/ . ; '( ; ...,_,1 /.·.'J .. /1 1' _. ; . -I '· ~ ,. '/ /11_,_/ -\ ' ' \ --' \. \ .. ··, ..... ~--.,, ;--· \ \ ~\·r-• •,, \ '·. ''°'\ ·. ', . ',, r-0 ' • ' \ ' ~,"" ;;. \v, '·._ \1 ' ...... , •. ', ' \ 1 \_ ·, ,"ih ' '•, , \ \' '-., ...... l \ . · eC \ "l'.-Q . \ ' ·'i'l • , ... I -o.;,,-i~ I \ <, ¾,.ov '-._ __ --.. --.. ____ ·-' -,_/ --i' •;<• ' ·--.,_, '/. ><::-(~ I . -..:'-. ·,. ' . ·>,' . ' ·,., \ '· t,.,·t, I, \ • ,,_ • \ \ \, \ \ \ . 1 /·,-;~1 .. :-., \,e, 'o, · \>Y"'"·,. ' . '·-'{, "i, ·, .... \ ·, . . ... \', ... '-\ _,-\\ \ ----' \ ~--'\ \ '\. ·, ','._ '•,.. I / ', \ \,__ / \ \ / .\, ✓ . ··-..... ·-..... ~_ " -·,...,. JC-010-SW(B/117.) (Pb.. <{),0028.mg/1) JC-010-SD(B/fl}., (Pli 5.2mg/kg) , \ I , ,, , i'o()'J,'o / ./ ()· · 1,.,1 ' / Cr, ··' _.-·-·---. \ / -. ''-. '---. ··1 .,,.--------1. ----\. -~. ' -' "' u Q I ' ,,• b·, \ I , I ! , / ', ' 'ri-('J .<!. -:-:;:. C, ClJlu~ . Si-,75 ··f ,/:~::// .~ :./: ,. ' ' . /1·•,' I /1../,./ i V /1 l-,. ''<•:"."-~ \ \ ... . ...___ \ •,. '\ ·.,_ ' ._ . ·-....... ___ .. _ ''·-·· .. ,__ -'~\ \\ '''·,,., \. \ .... ' ', \ ·•·-. ·---·----...... .,_ ··,. '·\, . . \ . ,, ··~o ·--,'&% ··--. ··,_ \ \ i' \ ,1 / , /, f i' . / ,/ / , ,, I I i I I / I I I / I I ! C,, ,,. "' ·, \ '· ! . / \ ! / •• so•' j_ JC-011-SW(S/97) /Pb <0.0028mg/1) JC-011-$0(8/97) Pb 6.4mg/kg) \ I '-/. I ~oo-·, 'f 501,,·\.. j_ eoI" I 'I 'i:,1 I l> '. ./ 8 \ 0 sO' b j_ BO\ 2 Y.., ,,.-; (/, , , • , I , ' , I , / , , . I ~. I , I I ,/ .•· I I I ;y_•o,2 soi'Y-/ / I I I I ,' / I I , I I I j_ 600' . , , , j_ sD\ B ·, I ·· .. I I i , / , // , I ,,/ j_ BO\.':> : JC~006-SW(8/97l (Pb1 ()~05~~/I; <0.6o2:~9/I)··.•, .. JC-006-SD(S/97 (~g/kg~:;m~/kg) I .. ~--,__ ' . ' •, ··~ \ .. ·~ j_ --1 , c· ---... /· I ,.,--', I , ~ ~ .,--., /--/-/ I '·-.... ~· ,//' . .-.. ~ / l JC-012-SW(8/9Z).~Pb 0.003.Jmg/l; <0.028mg/l) _/",, I •. ' I I I I B4B·'/ I I I I !' \ ',, Bt..g,3 j_ ', \ \\, . -. ' i \ i \~·.' .. · . ' ' . \ ' . ' ' . ' ' ' \ . . . . \' \ ' ' \ ' ,, / \ ·, ' ' ' \\ ' \ \ \ \ ,, \ . \ ', \\ \,_ ·., \ ' ' \ \ o·, '. -'" \.V rt)' '9,9'· '!; ·--.~en ~ ,, ,. '' \ •u->O \~ ·,, \ -/ ., '~---~ '•·-,.\:"-.-..:~ -c... --:-,:_'...;__ / o \"'-. JC,-0!)2-SW/8/97) (Pb «:0.002mg/l; <0.0Q28tng/l) \ ·----..;~· •• -z_ .'.!C-c002-'SO 8/':J?) {Pb 25rli9/kg;-16.2mg7kg) ----··--~ ' -.. ' ""· ' --·. . ' \ \ '\" ' .\ '-._ .\ -~ UNNAMED TRIBUTARY \:~ =~ ' ~ "'. os• ' . -, : '\ .. ,.. \_ f-•cl•'· :r B'='' .0 J:001 -SL(8Jg7) (Pb 23.1 m~/kg; JB-001-SL(B/97) (Pb 27'1lg/kg) / ' I ·, ,.,a 'b '·-'.' ' " ··' i-' 0 ~., \ 870 • -\ '\. ·\i \~ .. • \ ·.·· .... · .. J f ' • -• ''• .. " --" SEDIMENTATION BASIN NO. 3 \ .. , • .. \ ' . '\ \,,, J~-003-SD(B/97) (Pb 5~g/kg; 54mg/kg) '•. -... ', __,:, ,_ 0 sT1.v ' ... '>--. ) . ---:/;/ .• · .... ·e·o?-3:-~, /• ·· · T·. ss ;,--~-. ½-. , • \ ,. ·--, 4 :?' /; / i I -.. ' ' " .. /> ·-7 . I ( f ->~-~-/ '1 \ •. r L '• ,\ ,, . •:,, \~~ '~· ·-.. ·\. \ -<'.'-~~ ·. . \ __ ___ _ ___ oee.",'..~ , , •.. · ., .. ,,. · • >. · I (, \ '"<-.... -· ' ---:::-\ \ c,'0 ' ' \ s,· · .:"-,, .. I . . . ' . "\' • . "6 ,,_, · .. \ ·, • .. · ... -~ ,·. . • ~/~~~!it;Jl).1i;f//g?:,z~~-01 l"Sl::97))P~;;::~J9l_~:~"°0 '~-',i : i ., r . __ / .. ----• ·:.· ,/" 9 "· ~ . · . ..--.· . ·' -'. '\ JC-012-SL(B/97) (f.b ~-2tng/kg) •• '• -, · ·>-/ _\ _ .'cp,0 Oas ' ; I 0~ ' ,,.:/ ' ,.,--7, I ;. : t '. . I, i i , --':'-'-' .--/ -----i= . / _,. a--go \ JC-005-SL(8/97l (Pb 23.8mg/kg) \ JB-005-SL(B/97 (Pb 23mg/kg) ---,;-.._ ACID STORAGE TANK AREA JC-004-SL(S/97) (Pb 130mg/kgl . JB-004-SL(B/97) (Pb 130mg/kg \ ' e JCSS02(6/91l (Pb 18mg/kgl ....--i JCSB02(6/91 (Pb 19mg/kg \\\. )~\ l~\, I ' f_ \ I -,\ . ,\ '•" I ' .. ~ ~~f.\\01.lsY, ~\)\)\'\'.\01' OLE/ ORPJN . ' • I ;; " ,, '\ ''I ,, ,\ ' ~\ ·, . ··-.,, ',, ·...._,,\ 0 ~~ ' t -7' 069. 0~6 ,--. " \ . ' \ \ \ \ \ ' \ \ ..,,,. i ---,,.,, __ _ --JC-010-SL(8/97l (Pb 33.?mg/kg) JB-010-SL(S/97 (Pb 32mg/kg) /4 0 \ w '&· .. -\ c.z.: ... \ i / 'I 1,\1'\'-''\'.f.'-'~'-'cY, \O.~~"' t /':' " it ·' ~ ~==. ~~----~-~-----~ ~~ JC-003-SL(B/97) (Pb 9.9mg/k~) JB-003-SL(B/97) (Pb 13mg/kg) -'£,'iJs'\'.l~ G u\J\Llll~G ,. -'' ·,.' \ ' 1.;., ___ .., ' ·. \ ----------' . \ . ' --------\----\ ·-. , ' JC-0\16-SL(B/97) (Pb 2,750mg/kgl JB-OOl)-SL(B/97) (Pb 3,300mg/k9 I, .• , --· -\ \ -\ "' \ ,,, ~ \ ·:=/~o \ ·-;,,\ \ --;.tr> UJ ; r-l .,~_ "'-'< \"' $. Si "· _fj, ·,.,_ \ '\ //. ' JC-'007-SL(SX,Bif~ (Pb 1,370mg/kgl JB-007-SL(B/8~ (Pb I ,800mg/kg / /· <\ ,: \lll -~ 0 C\, '· ,r ', .::._~ \ I \ \---·.\ '\ \ \ \ \ -----/ I /-·/ ',.-· ·-. ____ .,;.-' _ _;..,---\ ._/ ·,. ·,. -.. \v/ \ . \ ___ :::..---./" ,,,,.,,,.,,,, / -------/ / / // /./· . . 01'~ · ... .-· . . _/.'"· ·~ .~ ... ... /, ~~. ......... ............ '"( .. .. .~ , ... .~ 7-!' BS c~ ' · .· ·· f · i, . . I ) / . . . . . JC-013,,SL(~/.97), (Pb 137mg/kg) -C --.;, >' •' • _ .. -'\. .._ _____ _,, '---"=--....,., •I '. \\ , l; .~. \\ "\"" ":in ',r-(i1 t,:.· 'ov -~-. lO .._ <ot,._ /'r0 \ c-i ;,[!_\0v ,· , ,' p') \ < Q_'! I/ -\ C ~ •'-' ~· --..::., ~ : ' ··-' ...... ........ . . -~-. i:_i. ,::'. __ · ' 810 -e,'20 8)() ✓ ·, 0 r---Bl'· ' '\ j_ \ B1o6•-· \ . ·. ------SEDIMENTATION , BASIN NO. 2 , i ··1 ~:--. / , I \ ; \ I ' ' ~--·· -> .. ~ ' ,_.--' ,. / ,. 'V ·,, ORPJ~GE "", ._ I ,DfTCH / .·.·• ·.·-·,~l / \ . '!,,. •)-·" '\ i e JC-D68-SL(8/97f(f'b. -. 64~;/!11} , -~ 0 ' ~C-001-PW ........ . , '-o, ~ \ -i~~0~-5-L(B/97) (P.~ ~4:P~. \' , --\ I , _(' ~ ' ... _ : \\A . ~-',. JCf00\l-'SL(8/9, (P·b···. 6'2,5. m9/kg) JB-fll09-SLllli. , (e~80mg/kg) ·, STORAGE' .\' 1f l .fl ~"~, ' :;?Sf )> ~• I I\ .O)' ,.. ,I ,:/ ~ { l ~:,' •, AREA ·-;/ • I ',,, '•, ._ ._ -~ '""'~~'--., ~v· -~ ' <'~ .. / _,._,_.,.; ,,., -::;, ,. ·-· ~>·' /-_,' .;:-_ ,, ,. , . ~ SS-03(6/91) (Pl:! 920mg/kg) _,__ j. ( l i ' ; ,._,__ '-._ t ..... , ._ "'-...,_ 8"() '· ·-. __ --·--..... ·,. ·,. ··--...., . ._ 'o':P 50B9 y.., ... .-.. y_s<o29 ·, ,, . ' ' \ --\ \ \,, -4 ---. ...--' ~ 0 :o ' ',! 0 () ' ' ' ✓ > · .. ---'--. ' // ., i . ; r-•, ,' '·,;;;~ ..... .,..0 .., . ~ ;-._ 1~ :\ :--__ ---:.~------,. ' \ -----., ' ' ' ',) \ \ '',, \g \ I \ ; ~,.< "' '., ,( ')-,, .t ,, ·, \ ·,. I ·; J. '.,.,_ . ,.· c,;~, cO :i: :;-'7 . ./ ~1"'-,z.-·"···'t .-..... -",!_. ;;,'. ,li°i ... / ___ _-: :;-, · II ., · · ;_ c, •-·~ J,i£!.:-,.c. ,ri,.,, ' ,.__ --·pf". --~, ' ' .. ''\'j, i-· ·~ -,.--~, i -.;.'l, /~-•~-. I • • '. •'o .· . ·l.-, " / ,~ _,., . D -... ,:"-......._ , ,, •'. '1, Q ,<.P< , ' / /----,, I ', ,~,• -~.U ; / t -__,.,. I • -.,_ -, ' • I --, . \-•~ \ , >" r-;-~, ···./,~·· ,; \ ' i '' . \ . ~ ' \ \ .. --··-_ .. ,. . ' "ii'._ '--( . ''-... ' ~'< . -... _\.: / ' 1 · '. . \ \, ..... _,.,./ ,· 'I--·1 '-, ,.· .. , ' /, • I • "-., . • • , /" .J.l '<> , ·, ', -},· ••. ' '. • • ' ......... __ ~----/./ \ . \ \ \ ··.,. '\\ '\._ . / ~~ /' 'l,-t . \ -. -.:.. -<)·c::.:_, ·.; -·-J· ---...........___ . ·-.... ____ -------\ \ , • \ ·-., ',s. . . \. '·-..,_ ,,,-/ /' ~ ,. \ ~ ..... ,_.. -I:----<'\~, ·, ·-.. •. \ \ . "-"·\ '--, ------.. --____ ____..,--,' , -\ ' \ . ' ~-------. ~-✓-:'c:.\ \ ··• -. --·-\ ' ' "--~-...,_ ._ . . -~-_ .\ ', 069 /I . , \ , , ., ):·<.',,'. . -------~--'-------::.:..,· .... _ '-...._. ---., ' '· , 1· ' ". ·,· ·\•"/\' ,_ •. ---· --___ .. -.. . . \ . '--, . \ \ .. .. / •, . . ·.. \ ·.. . . · .. ·. ~'. '·· ' ·, _ _ _ -.·, _ ·. '• .. • 4 ·· · '• .· . ......__ · · ... · \ . ·. ·. '.. ',, _,.-...-'!. r 'JC'--014~SL 8~7 P~ 17Smg/~~ \ " \t,, ---·-·------------UNNAMED TRIBUTARY .. ---.--'1,7..a .-·-...._ :-.. :\JC~ooS"-SW(Bml JP~. <0 ... Q02mg/l .• ; <0.0028"'1!/I) \ '· . dg· .. , ---__ /✓ ·,-, • ..---~ 7 _ -J.,JC. dl1,4-'SL)a;s.7l ~.~. m.!li .. _1/ • · \. ,\; .· JG-005~SD(8/97),(Pb 7tng/kg; 7.2'('g. /kg) -., , . ~ ,, -.. . , -,' ·. , ~· ... ~· · '\ :. ~ ,,. ,--,_;,.,,1-1 1.( . .-~: • .• ·. . \ . '.... ' ( / ) ( .,; /) --' 0 ... • . .,,,, . ' ' . . · "---. · · .:<. . . •. \, . · · · \ ',. JC-SW02 6 91 Pb Hlo!iin<l I -■,4 ',_ ,, ;,,.. ..(I .f · /,.•.1,, : --8.30 -'-· .. ., . , , , ', ' \ . >, ·... JC--sEIJ02(6(9~) (~b :;Jlbtng/kg)/ °"'~ _.· ; ; , , / / ,.f.(,,..~;j, ·.• r· --.. ,_ "-....;;;;:;, ,_ , •• .... ~ ---.,.,, / / r ··-I ; ,. :;:, t¢ c •. .~ \ '·-.., \, ._ o,:;,· · ·---· ----~~"' -.. . "' -:· / $EDIMENTATION. ( Y ";? f: ', \ 840 . .· \, ' ' .'-7 • '·f , ,, (. /?;"/· j_~/' ;_,,,· : 'y ,: .. ) / / .; i .C I , <'.< / .. :)•/. ' ' .. , :///:: .. ,. , --,·; •,'; . . !. ._, • I ' .. '-.' \ \\ --... ... "'· '-.. ._ ......... \ \ ·-._ \ -......., ._ \ \ \\\ \ \ ·\' \ \ / \ I ~ ' ._ ' .¾/-'' :,'.: r-...1°< -·-<'1 -,., A,lo 'I: ' ....... f"·.'. .,, / ':Jf::,. ... .', / ' . : ,cf;/-"')/'' '·.'/ \, . ,, . JCSSP1. ~·;ig. I} (Pb \~~g/l((tt... SB,ll1( f.91) (Pb I ~"'1!7kgJ ·, " -' ' ' ~ I ' I-~/ ' ; ',:9 }~-. l . i::& /.,' . , '· b •. I ' 1--... . '·. ,,, / I _,.._,___ , !/-I /---.........' ' ,?~ , ---........:.. ~p ... '' \---.. . ._ ._ \ ...... ... / • • .............. ', ' ' \ \-' / ', ~~-,-.. '"' "' « -<JI ' I/ I .. i \ ",,\ NOTES: 1. • ~ • J JN 0 ,' ' .~' ,~ ,;' . .\ ' . . ,} LEGEND SOIL SAMPI.£ WITH LEAD CONCENTRATION SEOIWENT SAMPI.£ WITH LENl CONCENTRATION SURFACE WATER SAMPLE WITH LEAD CONCENTRATION ESTIMATED V/>LIJE ANALYTE PRESENT TENTATMLY IDENTIFIED RESIDENJ\\L WEil Jc-012~5-p~~(sn·(Pb 16mg/kg: l2.5mg;~~) / I ---·-, .. ...._ \ ---~··/ //.· --·· ·-.. •,. '\ ·,. •.. • •, .. -. ~~ ~~ ,' /BASIN NO 1 1 • -I .· I· .,, "--.<~---,, ...... -, ......... .,_...-----'., ____ :._ __ 'ii=' ' .. -_ .· . ..:;-· _.· '. _ .. ) \ . "' • ~ ..,, \ · •. · ~. • ·,__ __ ,/ 1 /" . /. ..(NORMAL POOL . ,, , , ,, \ ~ -=:::-. i ORIGINAL PROPERTY SURVEY FURNISHED BY THE JOHN R. McADAMS COMPANY, INC., RESEARCH TRIANGLE PARK, NORTH CAROLINA. -, ,/ _,,-•' -.. / , / iooO ", \ . , .... ....,,_ ·,, \ i // ,. .. --·· 850 -/ / ,/ -·-------......... 560 -. ... ·. '",. . ', . .. ' ' ·. . . " ..-·. •.·. 'El..§Y-85300) .• · · ' , .' . , ,_ ... 1 •• ••. . \< -,. .. __ . · . J~-io4~swca;9n~:;;.oh~~/J( <;~02~,;,~;1) ,.)yJ / ✓<// ·~-+ , ·~ .. ,_' · ·. ·.• ",,, ·. -, ---,~C-004-50{8/97f(Pb 340nig/-i<g; J58mg/kgJ . / .· ·.' -~.' , 1 .;;-., ---......_. ________ ;.>-:.::~ ··. -,.,.../ _-_ ---... --/ ,. ··<Ai:? -___ .,. '·._ \ / /.-:;.· ,;..--/ / Ir(O·o --·-, '--.... ' -..._ , I ,, ., ' • / ,, ·----_ .. ----,,,, · 1· · -· --, ·----, · ·1 / / _, 1~·R ·, ,, .. I ,_.. i.•:.> '' ' I // ·•,\ \ /,./" ·-...... / / ' ,' I/ ; ','"1,--', / ,, ." _, ✓' / --,..,, ·~·· I ' ' ,, ~ , .,, ... . \ \ ;· ' ' '· ( , / '-.... i •~.. L / ;,j,' ··--~ .. ~ -~! ... ,..,. ·, ' . '· . ' . \. I ------·-·-·-. ,, I . •, ' ··---870 ... .,_ , i' , ,, .:::·--· ---......_ I ·; \ ! ' --.. -' ··.. ., , .~· ' ,r ) . ',,'>!-... ! . ,, .-, C-, "i ,.,~ _, --: o· -¾. .<::> '° ',, \\ 2. 3. 4. THIS TOPO EXHIBIT IS A COMPllATION OF FIELD LOCATION, CITY OF WINSTON SALEM TOPOGRAPHIC SURVEYS AND CONSTRUCTION PLANS. ALL SAMPLE LOCATIONS ARE APPROXIMATE BASED ON PREVIOUS INVESTIGATION FIGURES. WHERE 1WO VALUES ARE REPORTED FOR LEAD CONCENTRATION, VALUES REPRESENT SPLIT SAMPLING. FIRST VALUE IS NCDENR SAMPLE RESULT, SECOND VALUE IS RMT SAMPLE RESULT. w O' -=, N "' G: 0 w I= Si m ::, V, ".l cS V, ~ a.. ~Q ZliSu, ....J z 0 0 ~~j:::: (!) §: ~ -1-ln u, z LLJ z LLJ >ou Z-z -~o u, u u =>o 0....J ~ a::: a.. . u z _<( a.:z ~ :::::i 00 0::: c:: (.') () ~ :::c 1..1..J l:i: ~o CIJZ -(/) :::::!! ...J 1..1..J 0....J 0::: <C I-(/) ZJ Oz Uo zl:n oz (1)-z:3: :::c 0 -:, z a le I I w ~ 0 z w c.. d 0) L 0 Qi c;I ' d +' C d ~ +' <[ w ~ 0 z ~ i 0 w z z 2 s u, "" w O' 0 0 0 w "' u w I u z 0 ,__ Q_ O' u en w 0 j ', \ .. -.. --·. \ ) ! ) / ' 7", ~, -. '" \ \ \ / ~ /_ . "-.:::, /: ~, ---' \ '• ( ' / /G '<.) .,. 1....:. ,..___..._ I..!.. -.' t .... i -, .---· .. ·--·, • I , / ' ~. ,•: I ' I , : .,, ~I B"o -----:...~ i -·· ----\ \ ·w_ .._. 1 / ,' ..... ,),;,;,. ,[·, ,;;;,"/'·-,'\ ,J .. v:-1,/ '1 NI ~ ' , , 50 .. ', , · _,._ -,'o ' ,• I •· foC >c I ., i j , -1 ·. \ 3 -----·· ------~-----\, ---, • .k I / I ',·_,10_1§ i ......_, ,, ',., .... _! /,-£ / • • .,:\ \.,. .-'·· \ \ . \ \ JC-001-S 97) (Pb <IJio;mg/1; ~.00281T)!lfi) / ,;:,~ · ,-.."'.· .··,. .< -•. /~~ ,"'-":·c::/ GRAPHIC SCALE I I I I I i£ ~ -• ,✓ \ • • . r.JC-=OOle,Sll 8 ), (Pb 24m kg; 12dfmg/k91\ ..,,./ . '"'! ~>-:..:./ .( ait/ ~ o so 100 200 o , ·. 1 . -D ,. , r ·· , -.-· ~ •· , ~ ;;;;;J I :::J w ""j '-... i i / B90 ---------··-·--..... _ ··,. \ l , : .. --ii~,_:, ., I/ :\~---/ ~ .... _r.· :Q?. ----....... / ·..,_0r-'' •·="'7 ~iiiiaaiiiiiiiiiiii ~ , , I\ . ,r· u.-•, • ' I ~ ~•' .._ , " I '-!:. Q I / ·' / .{....; , ... ·-._ -~ ' 1 inch = 100 ft. 0 c;:, O' i'~--';-, . .,, ·-·' I '.~) .,-,--. \ ~