NCD981927502_19961023_Geigy Chemical Corporation_FRBCERLA FS_Remedial Investigation Feasibility Study-OCR

October 23, 1996
MEMORANDUM
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Meeting with EPA and Duracell Representatives Phase II RI/FS Work Plan
Duracell-Lexington Site
NCD 000 648 402
Lexington, Davidson County, North Carolina
On 11 October 1996, representatives of the NC Superfund Section participated in meetings with the
EPA, EPA oversight personnel, Bechtel Corporation, and Duracell representatives to review and
discuss the proposed Phase II Remedial Investigation Work Plan. The State participated through a
conference call to EPA Region IV in Atlanta, Georgia. The primary issue to be worked out with the
Duracell representatives is the extent of additional groundwater investigation. Specifically the
number and location of additional shallow and deep wells to be placed around the Site. The State
encouraged additional deep wells to the northeast of the property to evaluate the extent of Volatile
Organic Compound contamination in groundwater.
cc: Grover Nicholson, NC Superfund Section
• Ciba-Geig_y Corporation
May JJ, 1996
Ms. Julie Keller
US. Environmental Protection Agency
Region IV
345 Courtland Street NE
Atlanta, GA 30365
Dear Julie:
RECE1vPo
MAY 14 1996
SlJPmRUIND:SECTION
Ciba-Geigy Corporation
P.O. Box 18300
Greensboro, NC 27 419-8300
Telephone [phone]
Attached for your review are samples of the letters we plan to send to the neighbors
involved in the Rt. 211 Downgradient Study. The first letter is to Lester Davis. The
second is a sample of the letter to the well owners who represent the six other minor
detection points. We reference the agencies in these seven letters.
The third sample letter is to the 17 well owners who had non-detects, and the fourth letter
is correspondence we plan to send to the two well owners whose wells were too shallow
to sample. Finally, the fifth letter is to Southern States Galvanizing, in which we make a
continued offer to sample their well.
If you have any edits to propose to these letters, I would appreciate hearing from you by
May 16, 1996. Otherwise, we will assume you are satisfied with the correspondence and
will proceed accordingly.
Thank you for your review.
Sincerely,
~~
Harold Moats
Project Coordinator
Attachments
cc: Bernie Hayes, E;P A
'Raiidy-1v[cE1~NG-'DEHNR:;;,
·•
May 13, 1996
Mr. and Mrs. Lester Davis
P.O. Box 222
Aberdeen, NC 28315
Dear Mr. and Mrs. Davis:
•
Route 211 Area
APDS Committee Correspondence
As you may recall, a sampling team from Rust Environment & Infrastructure, on behalf of
Ciba-Geigy Corporation and Olin Corporation, collected a groundwater sample from your
well on April 10, 1996. The sample was analyzed for a standard list of pesticides.
The analysis of your water sample detected trace amounts of a chemical compound,
gamma BHC, at 0.047 parts per billion (ppb). This level is within the acceptable drinking
water standard of 0.2 ppb established by the North Carolina Department of Environment,
Health, and Natural Resources (NC DEHNR). Trace amounts of other chemical
compounds, for which there are no state or federal standards, were also detected in the
water.sample. These levels are within the acceptable risk range for consumption as
determined by the NC DEHNR and the U.S. Environmental Protection Agency. A
summary of the laboratory results for your well is attached to this letter.
Thank you for your cooperation in this matter. Should you have any questions or
concerns, please do not hesitate to contact Mary Ann Gillis with Ciba-Geigy Corporation
located in Greensboro, North Carolina at [phone], Randy McElveen with the NC
DEHNR in Raleigh at [phone], ext. 341, or Julie Keller of the Environmental
Protection Agency in Atlanta at [phone], ext. 2029.
Sincerely,
Harold Moats
Project Coordinator
Attachment
• • SL SAVANNAH LABORATORIES
& ENVIRONMENTAL SERVICES. INC.
2846 Industrial Plaza Drive (32301) • P.O. Box 13056 • Tallahassee, FL 32317-3056 • [phone] • Fax [phone]
LOG NO: T6-11026
Received: 11 APR 96
Reported: 16 APR 96 Ms. Evelyn Rogers
RUST Env. & Infrastructure, Inc.
15 Brendan Way
Greenville SC 29616
CC: Ms. Diana Baldi Project: RTE 211 Downgradient Receptor Study Area
Sampled By: Client
REPORT OF RESULTS
DATE/ LOG NO SAMPLE DESCRIPTION, LIQUID SAMPLES TIME SAMPLED
11026-3 PRW23 04-10-96/0955
PARAMETER
)rganochlorine Pesticides (508)
Aldrin, ug/1
alpha-BHC, ug/1
beta-BHC, ug/1
delta-BHC, ug/1
gamrna-BHC, ug/1
alpha-Chlordane, ug/1
gamma-Chlordane, ug/1
4,4' -DDD, ug/1
4,4' -DDE, ug/1
4,4' -DDT, ug/1
Dieldrin, ug/1
Endosulfan I, ug/1
Endosulfan II, ug/1
Endosulfan Sulfate, ug/1
Endrin, ug/1
Endrin Aldehyde, ug/1
Endrin ketone, ug/1
Heptachlor, ug/1
Heptachlor Epoxide, ug/1
Methoxychlor, ug/1
Toxaphene, ug/1
Surrogate Tetrachloro-m-xylene
Surrogate -Decachlorobiphenyl
Surrogate -Dibutyl Chlorendate
Date Extracted
Date Analyzed
Batch ID
11026-3
<0.0050
0.023
0.018
0.020
0.047
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<1.0
26 %-
118 %-
98 %
04 .11.96
04.12.96
0411B
Page 1
1boratories in Savannah, GA • Tallahassee, ·FL • Tampa, FL • Deerfield Beach, FL • Mobile, AL • New Orleans, LA
•
May 13, 1996
Mr. and Mrs. Lynn Baker
495 Carolina Road
Aberdeen, NC 283 I 5
Dear Mr. and Mrs. Baker:
•
Route 211 Area
APDS Committee Correspondence
As you may recall, a sampling team from Rust Environment & Infrastructure, on behalf of
Ciba-Geigy and Olin Corporation, collected a ground water sample from your well on
April 11, 1996. The sample was analyzed for a standard list of pesticides.
The analysis of your water sample detected trace amounts of a chemical compound,
gamma-BHC, at 0.13 parts per billion (ppb ). This level is within the acceptable drinking
water standard of0.2 ppb established by the North Carolina Department of Environment,
Health, and Natural Resources. Trace amounts of other chemical compounds, for which
there are no state or federal standards, were also detected in the water sample. A
summary of the laboratory results for your well is attached to this letter.
It is our understanding that your drinking water is currently being supplied by the Town of
Aberdeen and that you do not use your groundwater well for drinking water. We would
recommend that you continue to use the Town water for all your needs.
Thank you for your cooperation in this matter. Should you have any questions or
concerns, please do not hesitate to contact Mary Ann Gillis with Ciba-Geigy Corporation
located in Greensboro, North Carolina at [phone], Randy McElveen with the
North Carolina Department of Environment, Health, and Natural Resources in Raleigh at
(9 I 9) 733-280 I, ext. 341, or Julie Keller of the Environmental Protection Agency in
Atlanta at [phone], ext. 2029.
Sincerely,
Harold Moats
Project Coordinator
Attachment
SL SAVANNAH • LABORATORIES •
& ENVIRONMENTAL SERVICES. INC.
2846 Industrial Plaza Drive (32301) • P.O. Box 13056 • Tallahassee, FL.32317-3056 • [phone] • Fax [phone]
LOG NO: T6-11046
Received: ·12 APR 96
Reported: 17 APR 96
Ms. Evelyn Rogers
RUST Env. & Infrastructure, Inc.
15 Brendan Way
Greenville SC 29616
CC: Ms. Diana Baldi Project: 89550.202/Rt. 211 Downgradient Receptor Area
Sampled By: Client
LOG NO
11046-2
PARAMETER
REPORT OF RESULTS
SAMPLE DESCRIPTION, LIQUID SAMPLES
PRW50
11046-2
Page 1
DATE/
TIME SAMPLED
04-11-96/1250
-------------------------------------------------------------------------------
Organochlorine Pesticides (508)
Aldrin, ug/1
alpha-BHC, ug/1
beta-BHC, ug/1
delta-BHC, ug/1
gamma-BHC, ug/1
alpha-Chlordane, ug/1
gamma-Chlordane, ug/1
4,4' -DDD, ug/1
4,4' -DDE, ug/1
4,4' -DDT, ug/1
Dieldrin, ug/1
Endosulfan I, ug/1
Endosulfan II, ug/1
Endosulfan Sulfate, ug/1
Endrin, ug/1
Endrin Aldehyde, ug/1
Endrin ketone, ug/1
Heptachlor, ug/1
Heptachlor Epoxide, ug/1
Methoxychlor, ug/1
Toxaphene, ug/1
Surrogate Tetrachloro-m-xylene
Surrogate -Decachlorobiphenyl
Surrogate -Dibutyl Chlorendate
Date Extracted
Date Analyzed
Batch ID
<0.0050
0.18
0.16
0.14
0 .13
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<l.O
54 %
119 %-
59 %-
04.12.96
04.15.96
0412E
Laboratories in Savannah, GA • Taffahassee, FL • Tampa, FL • Deerfield Beach, FL • Mobile, AL • New Orleans, LA
•
Route 211 Area
APDS Committee Correspondence
May 13, 1996
Mr. and Mrs. Cleveland McNeill
265 Lena Circle
Aberdeen, NC 28315
Dear Mr. & Mrs. McNeill:
•
As you may recall, a sampling team from Rust Environment & Infrastructure, on behalf of
Ciba-Geigy Corporation and Olin Corporation, collected a ground water sample from your
well on April 8, 1996. The sample was analyzed for a standard list of pesticides. The
analysis of your water sample detected no pesticides. A summary of the laboratory results
for your well water is attached to this letter.
Thank you for your cooperation in this matter. Should you have any questions concerning
the results of your well sample, please do no hesitate to contact Mary Ann Gillis with
Ciba-Geigy Corporation located in Greensboro, North Carolina at (910) (?32-7819.
Sincerely,
Harold Moats
Project Coordinator
Attachment
• • SL SAVANNAH LABORATORIES
& ENVIRONMENTAL SERVICES. INC.
2846 Industrial Plaza Drive (32301) • P.O. Box 13056 • Tallahassee, FL 32317-3056 • [phone] • Fax [phone]
LOG NO: T6-10995
Received: 09 APR 96
Reported: 12 APR 96
Ms. Evelyn Rogers
RUST Env. & Infrastructure, Inc.
15 Brendan Way
Greenville SC 29616
CC: Ms. Diana Baldi Project: Route 211 Downgradient RJceptor Area
Sampled By: Client
LOG NO
10995-1
PARAMETER
REPORT OF RESULTS
SAMPLE DESCRIPTION, LIQUID SAMPLES
PRW26
Organochlorine Pesticides {508)
Aldrin, ug/1
alpha-BHC, ug/1
beta-BHC, ug/1
delta-BHC, ug/1
gamrna-BHC, ug/1
alpha-Chlordane, ug/1
gamma-Chlordane, ug/1
4,4'-DDD, ug/1
4,4'-DDE, ug/1
4,4'-DDT, ug/1
Dieldrin, ug/1
Endosulfan I, ug/1
Endosulfan II, ug/1
Endosulfan Sulfate, ug/1
Endrin, ug/1
Endrin Aldehyde, ug/1
Endrin ketone, ug/1
Heptachlor, ug/1
Heptachlor Epoxide, ug/1
Methoxychlor, ug/1
Toxaphene, ug/1
Surrogate Tetrachloro-m-xylene
Surrogate -Decachlorobiphenyl
Surrogate -Dibutyl Chlorendate
Date Extracted
Date Analyzed
Batch ID
? ~ct. ~< izath ~Schneider
10995-1
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<_0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0. 0050
<0.0050
<0.0050
<l. a
47 %-
111 %
101 %-
04 .11.96
04.12.96
0411D
Page 1
DATE/
TIME SAMPLED
04-08-96/1040
Laboratories in Savannah, GA • Tallahassee, FL • Tampa, FL • Deerfield Beach, FL • Mobile, AL • New Orleans, LA
May 13, 1996
Mr. Elden McNeill
200 Lena Circle
Aberdeen, NC 28315
Dear Mr. McNeill:
• •
Route 211 Area
APDS Committee Correspondence
As you may recall, a sampling team from Rust Environment & Infrastructure, on behalf of
Ciba-Geigy Corporation and Olin Corporation, measured your well on April 8, 1996, to
determine whether to collect a sample for analysis. A measurement of your well (3 9 .25
feet) determined its depth to be too shallow to draw from the aquifers of concern in our
study area. Therefore, it was not necessary to collect a water sample from your well.
Thank you for your cooperation in this matter. Should you have any questions concerning
our study, please do not hesitate to contact Mary Ann Gillis with Ciba-Geigy Corporation
located in Greensboro, North Carolina at [phone].
Sincerely,
Harold Moats
Project Coordinator
•
Route 211 Area
APDS Committee Co"espondence
May 13, 1996
Mr. Cary Peterson
Southern States Galvanizing Company
RR I, Box 60
Aberdeen, NC 28315
RE: Request for Sampling of Southern States Galvanizing Company's Well
Dear Mr. Peterson:
As you may know, Ciba-Geigy Corporation and Olin Corporation (the "Companies") have
been conducting a groundwater study in the area south of Rt. 211 and to the east of
Aberdeen. As part of that effort, the Companies' representatives have attempted to meet
with you to schedule a sampling of your well. It is our understanding that Southern States
Galvanizing has declined to allow the Companies to sample its well.
Should Southern States Galvanizing change its position on the sampling of its well, we
would appreciate your letting us know in order to add this information to the Companies'
database. If you have any questions, or wish to schedule well sampling, please phone
Mary Ann Gillis of Ciba-Geigy Corporation in Greensboro, North Carolina at
[phone].
Sincerely,
Harold Moats
Project Coordinator
' • ·• ~.-" ID CHEMICALS
P.O. BOX 248, LOWER RIVER ROAD, CHARLESTON. TN 37310
PHONE: (615) 3:l6-4000
December 2, 1991
Giezelle Bennett
Remedial Project Manager
Waste Management Division
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
via Federal Express
Re: Draft Responses to EPA Comments on the RI/RNFS for the Geigy Chemical
Corporation Site, Aberdeen, North Carolina
Dear Ms. Bennett:
Introduction
On behalf of the PRPs, enclosed are draft responses to EPA comments of November 6, 13 and
14, 1991 on the Remedial Investigation/Risk Assessment/Feasibility Study (RI/RNFS) for the
Geigy Site. Per our conversation of November 20, 1991, we have responded as completely
as possible given the short time frame. Because of the complexity of the subject, responses
to several comments could not be completely addressed in the enclosed responses. These
key issues require further discussion among the PRPs and technical consultants. Additional
information about these key issues will be provided to you at the December 1 oth meeting in
the form of a more complete response to EPA comments. In addition, complete responses to
several RNFS comments depend on the outcome of the RI.
Remedial Investigation
The PRPs do not agree with the comments expressed in EPA's RI cover letter of November 6,
1991. There is insufficient evidence to conclude that pesticides in MW-11 D originate at the site.
In addition, as discussed in RI response 20, there are sufficient soils data to demonstrate that
the Geigy Site is not a source of TCE in groundwater. While we are confident that the data in
the RI report support our conclusions, the PRPs are prepared to collect additional field data
which will clarify these issues.
OLIN CORPORATION
• Ms. Giezelle Bennett
December 2, 1991
Page 2
Feasibility Study
•
We believe we have addressed each of the Agency's comments appropriately. We believe
incorporation of the attached response will not require a complete rewrite of the FS. Please
clarify your comment in your cover letter of November 13, 1991 that "the basic assumptions
of the document are incorrect." As noted above, incorporation of these responses will not
involve significant changes in the basic assumptions. The FS will be revised per the attached
FS responses and the discussions to be held December 10, 1991 ..
Key Issues
For your convenience, RI/RNFS key issues are listed below. Since the three Geigy documents
(RI/RNFS) are scheduled to be discussed during the December 1 0, 1991 meeting at your
office, judicious use of meeting time is imperative. Therefore, we suggest that the following list
of key issues also serve as the meeting agenda:
(1) The source of TCE in groundwater
(2) Groundwater flow direction in the southern and eastern vicinity of the Site
(3) Lateral extent of contamination in the groundwater
(4) EPA and North Carolina groundwater classifications
(5) Remediation of former concrete foundation/floor
(6) Soil remediation levels
(7) Future residential risk assessment scenario
(8) Risk assessment exposure assumptions
(9) Air emissions and dispersion modeling/monitoring.
Responses to comments on the Draft Risk Assessment will be sent to you today from Clement
under separate cover. Please call me at 615-336-4381 if you have any questions or comments.
Sincerely,
r,f,~,
for
Olin Corporation
CIBA-GEIGY Corporation
Kaiser Aluminum & Chemical Corporation
'
Ms. Giezelle Benne,
December 2, 1991
Page 3
CC: Jim Cloonan, Sirrine
Dave Cummings, Olin
Steve Goldfarb, Ciba-Geigy
Howard Grubbs, Womble & Carmichael
Elaine Harmon, ERM
Keith Harold, Ciba-Geigy
Rob Lannan, Robinson & McElwee
Don Paulson, Ciba-Geigy
Lorraine Pearsall, Clement
Lester Rapp, Kaiser
Deborah Winthrop, Olin
Catherine Winokur, EPA
•
\. • •
RESPONSE TO U.S. EPA COMMENTS
TO THE
GEIGY CHEMICAL CORPORATION SITE DRAFT RI/FS REPORTS
Response to Cover Letter Transmitting RI Comments Dated November 6. 1991
As noted in the Agency's November 6, 1991 cover letter, EPA does not agree with our
conclusions that both the pesticides detected in the intermediate aquifer, and the trichloroethene
detected in the intermediate and deep aquifers, are due to off-site sources. While we are
confident that the data in the RI Report support our conclusions, we propose that additional
limited field investigations be conducted in order to reconcile our conflicting positions on these
issues.
During our December 10, 1991 meeting, we wish to discuss the need to collect an additional
round of ground water samples from monitoring wells MW-4D, MW-6D, MW-14D, MW-15D, and
PZ-1 for the analysis of trichloroethene. The PRPs propose that analytical and potentiometric
data from this and previous sampling efforts would be evaluated with EPA in order to determine
if the presence of TCE in the intermediate and deep aquifers is site related. Resampling and
analytical efforts would be conducted on an as soon as possible basis.
Response to RI Comments Dated November 6. 1991
Comment No.
1 .
2.
3.
4.
5.
Response
The figures and tables will be incorporated into the report as requested.
The error will be corrected.
An executive summary will be prepared.
There are no surface water bodies on-site. The ditch that traverses the
Site collected stormwater and is generally dry (except after storm events).
This point will be clarified in the report.
There is no knowledge of past enforcement actions; DEM or DNR
inspections or violation citings at the site. The NUS investigation was the
only sampling conducted. The NUS investigation was preliminary in nature
and was not intended to take precedence over the Remedial Investigation.
Since the sampling points and data collected during the NUS study cannot
be reproduced, the data are not suitable for inclusion in the RI report.
Extensive sampling in accordance with the RI/FS work plan was conducted
and these results are presented in the Draft RI report.
Draft Geigy RI Responses Page 1 December 2, 1991
Comment No.
6.
7.
• • Response
The soils data presented in the Draft RI Report represent existing site soil
concentrations. The data were intentionally presented in this manner to
avoid confusion over pre-removal conditions versus current conditions. In
order to make the Draft RI Report more complete, the Field Activities
Report for Building Demolition and Soil Removal (October 4, 1991) will be
included as an Appendix. Pre-removal conditions may be referenced in
that report.
In early February 1989, the governor of South Carolina issued an executive
order which precluded any hazardous waste from the state of North
Carolina to be disposed in South Carolina after March 1, 1989.
Consequently, the PRPs decided that an accelerated action should be
pursued to execute the removal prior to March 1, 1989. This action was
a major effort involving several parties. A critical approval involved the
State of South Carolina. A standard time allotment of 14 calendar days is
required for State approval both for land disposal and incineration. Since
the bulk of the soils were intended for land disposal, attention focused on
approval for that aspect of the plan. It was expected that the contractor,
GSX, could store the containerized soils intended for incineration at the
ThermalKem facility in Rock Hill, SC. However, ThermalKem had a
substantial backlog of materials for incineration and storage periods would
be significant. Incineration of the soils prior to the South Carolina disposal
ban deadline was, therefore, impossible. The only solution was to
accumulate and store several containers at the site until appropriate
approvals could be obtained.
EPA representatives expressed their extreme concern about any storage
of excavated materials in containers on-site. EPA would agree to allow the
PRPs to store these containers on-site for a matter of days, but any term
beyond two to three days would be totally unacceptable. The PRPs
contacted other incinerators and found that on-site storage for four to eight
weeks would also be required due to their backlog. On February 23,
1989, the PRPs submitted a letter to EPA which stated that all excavated
soils would be mixed for land disposal at GSX's Pinewood, SC facility.
EPA representatives expressed a further concern regarding the regulatory
controls on land disposal of the wastes in question. After several
conference calls with the EPA project manager and EPA council, it was
finally agreed that there were no regulatory restraints or concentration
limitations and the initial soil removal could proceed. However, the delays
resulted in completion of only a portion of the planned removal prior to the
March 1, 1989 disposal ban. Once legal issues with respect to the ban of
North Carolina wastes were resolved, the remaining wastes were removed.
Draft Geigy RI Responses Page 2 December 2, 1991
Comment No.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
• • Response
The AOC limits of 500 mg/kg toxaphene and 1 00 ppm gamma-BHC will be
included in the report. In some cases the areas excavated in the initial
removal were widened and the maps show some overlap. The maps do
show the approximate limits of excavations. The maps will be refined, as
appropriate, to more clearly indicate the excavation limits.
It is felt that the word "document" is more appropriate since support seems
to imply a pre-_conceived conclusion about the HRS evaluation.
The section will be updated to include a discussion about demography
and land use within a one-mile radius of the site.
The change will be made.
The 1990 census data will be included.
The change will be made.
A discussion of the residential areas near the site will be included.
The PRPs acknowledge that th_e low elevation of the water table in
monitoring well MW-6S, along with the thinning of the uppermost clay
aquitard, could be interpreted to suggest that ground water is flowing from
the uppermost aquifer to the intermediate aquifer at this location. As
recognized in the Agency's comment, however, analy1ical ·data from
monitor wells MW-6S and MW-6D demonstrate that leakage of
contaminants has not occurred at this location. The PRPs therefore
believe that a hydraulic connection between the shallow and intermediate
aquifers at this location is highly unlikely and that the water table
depression at well MW-6S can be more properly explained by the ground
water flow map presented in Figure 3-5 of the RI report.
A discussion of the quality assurance sample results as presented in
Appendix 3-D will be included in this section.
At this point in time, the owners have not been provided with the results
of the ground water analyses. The data can be made available to the
owners.
The discrepancies will be corrected.
Rounding according to the criteria presented in the CLP Statement of Work
was utilized resulting in a discrepancy between the results indicated for
MW-4S. The figures and the text in the revised report will use consistent
language. The result indicated on the Figure for MW-2S is a typographical
error and will be corrected.
Draft Geigy RI Responses Page 3 December 2, 1991
Comment No.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
• • Response
Remedial investigations conducted at the Geigy Chemical Corporation Site
have produced a large body of data on site environmental and hydraulic
conditions. Collectively, this information demonstrates that trichloroethene
(TCE) is not present above detection levels in site surface soils, subsurface
soils, ditch sediments, or ground water in the uppermost aquifer.
Analytical and potentiometric data also demonstrate that TCE is present
in the intermediate aquifer at locations hydraulically upgradient of the site.
Given the above, the PRPs disagree with the Agency's conclusion that the
presence of TCE in the intermediate aquifer is due to spillage from railroad
cars or, as stated in Ms. Giezelle Bennett's November 6, 1991 letter to Ms.
Lorraine Miller, is site related.
Because TCE was detected in groundwater collected from well PZ-1 at an
estimated value of 8 ug/I, reference to this information was omitted from
the Draft RI Report. The estimated TCE concentration for this well will be
noted in the revised RI report.
The figures will be revised as appropriate.
The March 1990 Statement of Work refers to the Contract Laboratory
Program (CLP) Statement of Work which became effective in July 1991.
The change will be made.
These sample locations were removed during 1991 removal action. The
figure represents existing site conditions. Pre-removal conditions and
results will be provided in an Appendix to the report.
The figure will be revised to include soil concentrations greater than 1 0
mg/kg.
SS-83 will be included on the revised map. SS-103 is located in close
proximity to highway. The clarification will be made.
Rounding according to the criteria presented in the CLP Statement of Work
was utilized. The figures and the text in the revised report will use
consistent language.
The PRPs concur that the lateral extent of contamination to the south and
east of the site appears to have not been completely defined.
The referenced paragraph will be reworded to eliminate confusion
regarding the vertical extent of pesticide contamination.
Draft Geigy RI Responses Page 4 December 2, 1991
' "
Comment No.
30.
31.
32.
33,
34.
• •
Response
Available hydraulic and geologic data does not support a relationship to
the site. The PRPs therefore disagree with removal of the referenced
paragraph and wish to discuss this issue further during our December 1 0,
1991 meeting.
See response to comment number 20, above.
No clean up goals are stated orimplied in the RI. Phase 3 soil sampling
was conducted on the basis of Phase 2 soil sampling results. Phase 2
sampling grid locations exhibiting total BHC, DDT and toxaphene
concentrations between 1 0 ppm and 100 ppm were resampled at two-foot
and five-foot depth intervals. Likewise, sample grid locations with
concentrations greater than 100 ppm were sampled at two, five and ten-
foot depth intervals. The reference to pesticide concentrations of 1 00 ppm
in the second paragraph of Section 6.2 on page 6-5 is in context with the
EPA approved Phase 3 soil sampling rationale discussed above and in
Section 4.3.3. The second paragraph of Section 6.2 will be revised to
more clearly summarize the extent of pesticide concentration in site soils
and to alleviate any misunderstanding.
The last sentence in Section 7.2.3.1 on page 7-5 will be modified to read,
"The maximum delta-and gamma-BHC concentrations in groundwater are
29 µg/I and 30 µg/I, respectively, in monitor well MW-6S while the
maximum beta-BHC concentration in groundwater is 25 µg/I in monitor well
MW-10S."
Conclusion #4:
Conclusion #6:
Conclusion #7:
This conclusion is in accordance with professional
opinions expressed by Mr. Ron Coble, USGS, and
Mr. Benford Graham, Graham and Currie Well
Drilling, regarding the suitability of the uppermost
aquifer as a water source. Therefore, this statement
is applicable to the site.
This statement will be reworded to emphasize that
it applies to the area immediately underlying the Site
property only.
The PRPs see no relation between this conclusion
and the Agency's comments. Therefore, this
statement is applicable to the site.
Draft Geigy RI Responses Page 5 December 2, 1991
•
· Conclusion #12:
Conclusion #13:
Conclusion #15:
Conclusion #16:
Conclusion #17:
Conclusion #18:
Conclusion #21:
Conclusion #22:
Conclusion #23:
Conclusion #24:
Draft Geigy RI Responses
• This statement will be reworded to emphasize that
ground water flow patterns in the shallow aquifer
preclude the possibility of pesticide contamination
migrating to the municipal well via the shallow
aquifer.
The PRPs see no relation between this conclusion
and the Agency's comments. Therefore, this
statement is applicable to the site.
This statement will be reworded to emphasize that
it applies to the area immediately underlying the Site
property only.
This statement will be revised as appropriate to
reflect the findings of the proposed additional
investigations to be conducted as a separate phase
of the RI.
This statement will be revised as appropriate to
reflect the findings of the proposed additional
investigations to be conducted as a separate phase
of the RI.
See response to comment number 20, above.
See response to comment number 32. This
statement is merely reiterating findings of the RI
from which a general conclusion is made. The
PRPs are in agreement that this general conclusion
reflects site conditions.
See. response to comment number 32. This
statement accurately reiterates findings of the RI.
The PRPs have no records indicating that copper,
lead, or zinc were used in formulating the pesticides
handled at the Site. Moreover, these metals are
within the range of background levels at the site.
Therefore, this statement is applicable to the site.
This statement accurately reiterates findings of the
RI. Therefore, this statement is applicable to the
site.
Page 6 December 2, 1991
•
Response to Department of Interior Comments
The RI report will be modified to include the Federally listed endangered species included in the
Department's comments. While the Department is correct that Section 2.7 is very general, it
should be noted that the areal extent of the Site is very small (approximately 1 to 2 acres),
contains relatively few trees, borders an active railway, a high traffic road (Highway 211), and
presents very limited habitats for plants or animals. Accordingly, we believe that expansion of
this section would mislead the reader into believing that the site represents a significant habitat
for wildlife.
Draft Geigy RI Responses Page 7 December 2, 1991
• • Responses to November.13 & 14. 1991 EPA comments about the Geigy FS:
General FS Comments (Dated November 13, 1991)
1. Soil Cleanup Remedial Alternatives
Soil cleanup levels are site-specific. Therefore, it is not appropriate ·to compare soil
remediation levels at the Geigy Site to other sites as stated in the EPA comment. Every
site should be evaluated separately, as was done in the Geigy Risk Assessment (RA) and
FS. This concept of site-specific remediation levels is obviously supported by the EPA.
Furthermore, it is inappropriate to use health-based, direct contact risk assumptions to
calculate subsurface remediation levels.
In summary, both the suriace and subsurface soil conditions at the Geigy Site were
considered in the Geigy RA and FS. Based on the reasons presented in these site-specific
documents, additional soil remediation at the Geigy Site is not necessary.
2. Concentrations of BHC isomers and toxaphene beneath the concrete flooring are
approximately the same level as soils in the remainder of the Site. For example, average
concentrations of total BHC isomers and toxaphene in soil at former areas of active use .
are 0.365 and 9.662 mg/kg, respectively. Under the concrete floor, average concentrations
of total BHC isomers and toxaphene are 1.733 and 1.525 mg/kg, respectively.
If necessary, the concrete flooring would be removed to provide access to those soils.
Otherwise, the concrete· has been steam cleaned and would only be removed for aesthetic
purposes.
3. Contamination of the uppermost aquifer has been attributed to the Site and corresponding
remedial alternatives were presented in the draft FS. The source of groundwater
contamination in the second uppermost aquifer has not been determined at this time and
is a subject for discussion during review of the RI comments. To require remediation of
the second uppermost aquifer at this time, without sufficient characterization and outside
the purview of public comment, is inappropriate. Presumed contamination of the third
uppermost aquifer is based on one qualified (J-flagged) value below the quantitation limits
and should first be evaluated through resampling.
Specific FS Comments
1 . The ranking was given as documentation of the site's determination as a CERCLA site and
to note the site's relative stature within the NPL. The date was given to mark the ranking
at a point in time, with the realization that the ranking may change. However, the
statement will be deleted if desired.
2. It is important to state the goals of the FS clearly and early in the document. Please
explain the rationale for deletion of the sentence.
Draft Geigy FS Responses Page 1 December 2, 1991
• •
3. Section 2 (Summary of Remedial Investigation) will be revised to reflect changes with the
RI.
4. Section 3 (Summary of Risk Assessment) will be revised to reflect changes in the RA.
5. As stated, the uppermost aquifer is correctly classified as Class Ill since it would not
consistently provide an adequate quantity of drinking water. The second uppermost
aquifer is IIA (currently used} according to EPA guidance (Guidance on Remedial Actions
for Contaminated Groundwater at Superfund Sites, EPN540/G-88/003, December 1988).
It is not correct to classify the second uppermost aquifer as Class I, as suggested by the
EPA, since it does not meet the definition of a Class I aquifer, as defined below:
"Special ground water (Class I) is (1) highly vulnerable to contamination because of the
hydrological characteristics of the areas in which it occurs, and (2) characterized by either
of the following factors:
•
•
The ground water is irreplaceable; no reasonable alternative source of drinking water
is available to substantial populations.
The ground water is ecologically vital; the aquifer provides the base flow for a
particularly sensitive ecological system that, if polluted, would destroy a unique
habitat." (EPA, December 1988)
The second uppermost aquifer is neither highly vulnerable to contamination from the Site
nor are either of the other characteristics outlined above applicable. That is, the third
uppermost aquifer could be used as a potential drinking water source (first bullet) and the
second uppermost aquifer is not ecologically vital (second bullet). Therefore, the second
uppermost aquifer is not Class I but is Class IIA.
6. The text will be revised as requested.
7. The text will be revised as requested.
8. The second sentence of the first paragraph in Section 2.1.1 on page 2-1 will be modified
to read "The property boundaries of the vacant Site, bounded by Highway 211 and the
Aberdeen and Rockfish Railroad, comprise approximately one acre.
9. The second sentence of the third paragraph in Section 2.4.1 on page 2-9 will be modified
to read: "Concentrated surface materials were visually identified in each area, excavated,
and packed in six 30 gallon fiber pack containers (approximately one ton of soil total)."
Additionally, the first sentence of Section 2.4.3 on page 2-1 0 will be modified to read:
"Approximately 3071 tons of. contaminated soil and 460 tons of debris have been removed
from the Site and properly disposed."
Draft Geigy FS Responses Page 2 December 2, 1991
• • \
I 10. The North Carolina groundwater classification system will be described in the revised FS.
11 . The following will be added to the legend of Figure 5-2:
SURFICIAL AQUIFER CONTOUR
(DASHED WHERE INFERRED)
12. The text will be revised as requested.
13. The text will be revised as requested.
14. EPA guidance specifies the use of a five percent interest rate (Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, EPA/540/G-
89/004, October 1988, p. 6-12).
15. Preliminary discussions with the North Carolina Department of Transportation -Division of
Highways Records Department (Mr. Ted McDuffie; November 14, 1991) indicate that buried
utilities including water, sewer and/or television cable may be located in the Highway 211
right-of-way. A utility location check would be required to locate and identify buried
utilities. Additionally, three wooden utility poles are within the confines of the proposed
slurry wall and cap. It would not be acceptable for any utilities to be located within the
confines of the proposed cap and slurry wall. as their presence would breech the
containment provided by the cap and their maintenance would require excavation of the
cap. Consequently, these utilities would be rerouted if Alternative 2 were selected.
Rerouting is considered extensive as the utilities would be rerouted either north of Highway
211 , south of the slurry wall and cap, or above the slurry wall and cap.
The proposed relocation of the Aberdeen and Rockfish Railroad indicated in Figure 5.3 is
conceptual and is provided for the purpose of illustrating the spatial relationship of the
proposed slurry wall and cap, and the Aberdeen and Rockfish railroad tracks. The porous
railroad bed would form a preferential conduit for infiltration and defeat the purpose of the
cap, which is to prevent excessive water accumulation within the slurry wall. To maintain
the integrity' of the cap, the railroad track must be relocated, presumably to the south. The
exact location of the relocated section of track can only be determined after appropriate
railroad engineering studies and design are completed.
16. Retained alternatives for the discharge of treated groundwater are discharge to the POTW
and an on-site infiltration gallery. The cost of remedial alternatives involving the discharge
of treated groundwater were conservatively estimated using the POTW discharge option,
which has both higher construction and operating costs than discharge to an infiltration
gallery.
Groundwater treatment alternatives that potentially involve disposal of treated groundwater
will be revised to include the cost of both discharge options. Preliminary and detailed cost
estimates for remedial alternatives are presented in Appendices E and F, respectively, and
are in accordance with EPA guidance.
Draft Geigy FS Responses Page 3 December 2, 1991
• •
17. EPA guidance specifies the use of a five percent interest rate (Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, EPN540/G-
89/004, October 1988 p. 6-12) and an inflation rate of zero percent (Remedial Action
Costing Procedures Manual, OSWER Dir. 9355.0-10, September 1985, p 3-21 ).
18.. The second sentence of the first paragraph in Section 7.2.1 on page 7-5 will be modified
to read "Approximately 3071 tons of contaminated soil have been disposed of or treated
at RCRA TSO facilities".
19. Deed restrictions will be included in the discussion of alternatives. Institutional controls
would be implemented until the remedial goals were achieved.
20. Alternatives 2 and 3 would control the flow of pesticides at MW-1 OS. Remediation would
attempt to contain or remediate groundwater to the remediation goals listed in Table 4.2
(e.g., MCLs).
21. The 180-foot source area used in the VIP modeling (Appendix C, Table C.2) corresponds
to area of active operations at the facility. This approach minimizes the area for infiltration
and is therefore conservative in the determination of potential pesticide concentrations in
groundwater. The justification will be provided in the revised FS.
22. This comment will be addressed in the RA and summarized in Section 3 of the FS.
Additional Draft FS Comments (Dated November 14, 1991)
• Page 4-3
As discussed in Specific Response No. 5 (above), the uppermost aquifer is correctly identified
as a Class Ill aquifer. Because of the low potential yield of the uppermost aquifer, it is not used
by local well drillers in the vicinity of the Site (personal communication with Benford Graham of
Graham and Currie Well Drilling Company, West End, North Carolina, September 1991 ). In
addition, Mr. Ron Coble (USGS, Raleigh, November 21, 1991) states that the uppermost aquifer
may not be a major or significant source of water since more productive aquifers exist (i.e.,
second and third uppermost aquifers). Therefore, water supply wells are likely to be drilled into
the lower units.
Furthermore, Mr. Ron Coble (personal communication, November 1991) stated that the nearest
homeowner wells in the uppermost aquifer are one to two miles north of the Site. The aquifer
characteristics that distance from the Site are apparently more conducive to homeowner wells
than near the Site.
In summary, the uppermost aquifer is Class Ill while the second uppermost aquifer is Class IIA.
Despite the unproductive nature of the uppermost aquifer, remedial alternatives were presented
in the FS that would attain groundwater levels that were protective of other aquifers and off-site
groundwater (e.g., MCLs).
Draft Geigy FS Responses Page 4 December 2, 1991
• •
• Section 4.2.1
Current evidence indicates that there is no hydraulic communication between the uppermost and
second uppermost aquifers at the Site. However, additional borings would be required to confirm
this.
• Section 5.3.1
The reference will be changed as requested. The Phase IV wells (MW-7S through 13S, MW-11 D,
MW-14D and MW-15D) were installed in August 1991 and seasonal water level measurements
are not available at this time.
• VIP Model
As discussed in the Geigy FS, the vadose zone interactive processes (VIP) model is the most
applicable model available for predicting the fate of pesticides in the vadose zone. The VIP
model was developed from the RITZ model by the Civil and Environmental Engineering
Department of Utah State University (Logan, Utah) and EPA's Kerr Environmental Laboratory
(Ada, Oklahoma). The VIP model and assumptions used for the Geigy Site are described in
Appendix C of the FS.
In summary, the VIP model:
• was developed with input from the EPA
• is an enhancement of the RITZ model
• based on field data, has accurately predicted the fate of PNAs in the vadose zone
• has been accepted by EPA Region IV for the Macon/Dockery Site, 25 miles from the Geigy
Site
• is applicable for modeling the fate of pesticides in vadose zone soil
• uses site-specific input parameters to more accurately predict the fate of contaminants
• was diligently and appropriately applied at the Geigy Site at considerable expense
• is applicable for use at the Geigy Site.
Draft Geigy FS Responses Page 5 December 2, 1991
• •
North Carolina DEHNR Comments
North Carolina Groundwater Quality Standards (NCGQS) were considered in the FS (e.g., Table
4.2}. The only NCGQS was 0.0265 ug/1 for gamma-BHC. However, the CERCLA contract
required quantitation limit is 0.05 ug/1. Therefore, according to the NCGQS, the detection limit
would be the allowable groundwater limit.
However, the NCGQS states that "The goal of actions taken to restore groundwater quality shall
be restoration to the level of the standards, or as close thereto as is economically and
technologically feasible." Remediation goals were therefore set at the more reasonable MCL for
gamma-BHC of 0.2 ug/1 (Table 4.2).
The comment about lead, copper, and zinc was appropriate for the scoping phase of the RI Work
Plan but is no longer appropriate since site-specific data were collected during the RI. The RI
data do not indicate any significantly elevated levels of these metals at the Site and metals were
not used for facility blending operations. Metals were determined to be at background levels
during the RI and thus no further evaluation is necessary.
Draft Geigy FS Responses Page 6 December 2, 1991
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:
31 October 1991
Perry Nelson, Chief
Groundwater Section
Division of Environmental Management
Lee Crosby. Chief p C/
Superfund Sectionf, :
Draft Remedial Investigation and Feasibility Study
Geigy Chemical Corporation N Pl Site.
NCD981927502
William L. Meyer
Director
EPA is in the process of completing a Remedial Investigation (RI) and Feasibility
Study (FS) for the Geigy Chemical Corporation Superfund Site, a National Priority List site.
Attached is one copy of the Draft RI and FS Reports for the subject site. It is
requested that these documents be forwarded to the appropriate sections of DEM and
comments be submitted to the North Carolina Superfund Section. The North Carolina
Superfund Section will be reviewing these documents and submitting comments to EPA
Region IV in the near future. It is our desire to include the comments and views of the
Division of Environmental Management.
If you or your staff have any questions, please call Jack Butler or me at (919) 733-
2801.
LC/JB/dk/4
Attachment
M Equal Opportunity Affinnatlve Acdon Employer
•
3 May 1990
'IO: File
FRCT-1: Jack Butler
SUBJECT: Geigy C11emical, NCD981927502
Fact Sheet
•
A Superfurrl Renroial Iiwestigation,IFeasibility Study (RI/FS)
Fact Sheet was received by FAX frcan Kay Crane on this date. 'Ihis
d=ument was reviewed and the following two editorial camments
were transferred to Kay Crane by telephone.
1. 'lhe sentence in lines 5, 6, 7 of the right column on page
2 should be changed to read "'lhe Sandhills Aquifer is
potentially threatened due to the high penneability of
the unsaturated zone."
2. '!he sentence in lines 29 and 30 of the right column on
page 3; "An evaluation of the no-action is necessary"
should be deleted and the sentence that follows this
sentence should be modified to read "An evaluation of
the no-action alternative is required and will assess
the risk ..• "
JB/ds/geigy.chmj3 ,·• ,