NCD991278953_19930707_National Starch & Chemical Corp._FRBCERCLA RI_Remedial Investigation OU-3 1991 - 1992-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
JUL O 7 1993
4WD-NCRS
Mr. Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
RE: Condi ticnal Approval of the June 2,
Investigation Report for Operable Unit 3 for
National Starch & Chemical Company Superfund
Dear Mr. Samson:
1993
the
Site
Remedial
The Agency and North Carolina Department of Environment, Health,
and Natural Resources (NCDEHNR) have reviewed the above referenced
document which was submitted to the Agency on June 3, 1993. This
correspondence conditionally approves the June 2, 1993 Remedial
Investigation (RI) Report. Enclosed you will find some additional
comments generated from the review of this revised RI document.
These comments are both from the Agency and NCDEHNR. The Agency is
not requesting or directing National .Starch & Chemical Company to
prepare a response to these comments. The Agency is sharing these
comments with you as they will be incorporated into the
Administrative Record.
If you have any questions, please call me at [phone].
Sincerely yours,
_,,;b; k./ 6~ c.------
lf;n K. Bornholm
Remedial Project Manager
enclosures
cc: Jim Cole, CDM/FPC
Bruce Nicholson, NCDEHNR
Ray Paradowski, NSCC
Kittybelle Rivera, EPA
Winston Smith, EPA
Michael Sturdevant, IT
Printed on Recycled Paper
-•
Comments on June 2, 1993
Remedial Investigation Report
for Operable Unit t3 for
NSCC Superfund Site
General Comments:
l. There is no "Executive Summary".
2. A number of the figures and tables in the text of the report and in the
appendices still have "DRAFT" printed on them.
3. Extensive detail on the method used and the tests that were performed to
confirm the piping was adequately grouted shut needs to be discussed in a
future document (Remedial Design Work Plan).
Page Specific Comments:
4. Page 1-2, Section 1.1.2: Additional detail on the piping history
(location, products/wastes carried, etc.) needs to be developed.
5.
6.
Page 1-3, Section 1.1.2, third paragraph, first sentence:
phrase "and were unlined" is not necessary.
Page 1-4, Section 1.1. 3, second paragraph, first sentence:
phrase '' in 1984" appears twice.
Typo, the
Typo, the
7. Figure 1-4 does not show all sampling points as implied under Section 1.2.
8. Page 2-1, Section 2 .1, first sentence:
provided for the "Supplemental RI".
A reference should had been
9. Page 2-6, Section 2.2.1, third paragraph: The actual depth below land
surface should had been incorporated into this paragraph.
10. Page 2-10, Section 2.2.6, first paragraph: The well construction diagrams
from Phase II are not in Appendix D.
11. Figures 3-3 and 3-4 don't match. The cross section uses points that
aren't in Figure 3-3. Also how can a cross section be drawn from A -A'
when at least one of the points is 750 ft. north of the cross section line
(point P-04). Also when comparing Table 3-2, Figure 3-3, and Figure 3-4,
the cross section depths to the top of bedrock don't match the table or
the bedrock map.
12. Page 3-4, Section 3.5, third paragraph, second to last sentence: It is
not clear what is meant by the phrase "not as well constrained".
13. Page 3-5, Section 3.5: .There is no-discussion with respec~ to the flow in
the bedrock.
14. Page 4-2, section 4.3.1: There is no MCL for acetone as stated.
15. ' Page 4-3, Section 4. 3. 1, first paragraph,
referring to USGS data as background data is
Site specific background data is collected.
last sentence:
not acceptable.
Typically,
Generally,
16. Page 4-3, section 4.3.1, second paragraph: The Agency questions whether
or not sufficient data has been collected to show beyond a reasonable
doubt that groundwater in the bedrock is discharging into the Northeast
Tributary.
-1-
-•
Comments on June 2, 1993
Remedial Investigation Report
for Operable Unit #3 for
NSCC Superfund Site
17. Page 4-4 Section 4.3.2.1, third paragraph: A more accurate interpretation
of the data could be made if recent weather conditions prior to the
collection of the sample were also discussed.
18. Table 4-5: GW-0lA results for 1,2-DCA should read 59 UJ: for GW7 it
should read 200; for 1,2-DCE it should read 10. GW-06 should not read
120.
19. Table 4-6: The results for
The readings for Chloroform
36 and NS-39 respectively.
bromodichloromethane should read 400 UJ.
should be corrected to read 5 U, 15 U for NS-
The results for NS-41 could not be located.
20. Figure 4-2: The figure does not show the codes next to the sample
location •
. 21. Figure 4-4: The unit of measurem':!nt (ppb) was not shown~
22. Page 4-8, Section 4.3.3.1, third paragraph, third sentence: Why use the
term "coincident"? The presence of similar concentrations of 1, 2-DCA
would be expected since 1,2-DCA is a DNAPL.
23. Page 4-10, Section 4.3.3.1, Acetone: Acetone in GW-06RE should read 120
J.
24. Page 4-11, Section 4.3.3.3, first line at top of page: Suggest that this
sentence be changed to read " ••• their presence has no ~ adverse health
effects ... ".
25. Table 4-8: Concentrations for Chromium (NS-14 -59.6), for lead (NS-36 -
3.9), for nickel (NS-14 -23.4) are in error.
26. Table 4-9: Sample SBA2-06-18-19 should read SBA2-06-20-22.
27. Pages 4-12, at top of page: Appendix G doesn't include all the samples
stated shown in Appendix H.
28. Page 4-13, .Section 4.3.4. 1, third paragraph, fourth sentence: What is "a
pattern that would be expected from leaking pipes" as is stated. The text
would be more convincing if the schematic of the underground piping were
overlaid on the figures using this "pattern" rationale as a reference.
29. Page 4-14, Section 4.3.4.1, Acetone: The units should be ppb not ppm.
The highest concentration of acetone is actually 4,000 ug/kg in SBA2-11-4-
6. The text of the report does not use this n~~er but Figure 4-13 does.
30. Page 4-15, Section 4.4 second sentence: This sentence implies that the
only contaminant "impacting" the environment is 1,2-DCA. 1,2-DCA is not
the only contaminant detected on site.
31. Page 4-15, Section 4.4: The horizontal and vertical extent of
contamination have not been completely defined in soil, or groundwater as
is shown by Figures 4-10, 4-11, and 4-12 and others. The source of
contamination was not adequately defined.
The horizontal extent of groundwater contamination to the east of the
plant is subject to scrutiny. Using the sample GW-15 (16,000 ug/1) as the
-2-
32.
--
Comments on June 2, 1993
Remedial Investigation Report
for Operable Unit t3 for
NSCC Superfund Site
eastern boundary of the plume is incorrect. The other samples GW-14, and
GW-16A cannot be used to extrapolate the 16000 ug/1 line because there are
no sample points showing non detects to the east. A well 49 feet bls (NS-
43) cannot be compared to a sample collected with the "geoprobe" rig
(which collected samples from shallow depths) when attempting to determine
horizontal extent of contamination.
Page 5-1, Section 5.1, first sentence:
to read " ... and the ji1,~);.9)f[$~J1:iil extent
Suggest this sentence be changed
of contamination ••• ".
33. Page 5-1, Section 5.1, fourth bullet: No where in this chapter is the
actual organic carbon content of the soil stated.
34. Page 5-2, Section 5.1, first paragraph, last sentence: There a number on
more important parameters than those listed here that will control the
rate of microbial activity. A few are the nature and. availability of
electron acceptors, water content, pH, etc.
35. Page 5-10, Section 5.3.1: It is peculiar about this discussion is that
the Site's major contaminant, 1,2-DCA, is not included in this discussion.
36. Page 6-2, Section 6.2, last paragraph, last sentence:
referring to USGS data as background data is not acceptable.
Site specific background data is collected.
Typically,
Generally,
37. Page 6-3, Section 6.2.1.2: The last two sentences are confusing.
38. Pages 6-12 through 6-18, section 6.3.4.2: As stated in previous comments
(4/20/93), some of the input parameters being used in the Summer's model
are not appropriate. Our comments specifically suggested an estimation of
the mixing zone below the contaminated site, rather than assuming the
entire aquifer thickness is contaminated. In addition, the volume of
recharge to be input into the model should be the ,fraction of rainfall
actually infiltrating the aquifer, rather than the total annual rainfall
less evapotranspiration. This is obvious when one realizes that none of
the rainfall has been accounted for as surface runoff.
39. Page 6-24, Section 6.5.4: An actual example of a calculation should had
been included in this section.
40. Page 7-1, Section 7.1.1, second paragraph, last sentence: This sentence
is only true for when the sample was collected. This one sample is but a
snap ·shot in time and cannot be used to make a categorically statement
such as "confirming that the stream is not carrying contamination off
site". Data over a long period of time would be needed to support the
statement in quotation marks.
41. Page 7-2, Section 7.1.2.1: There is no discussion in this section with
respect to the lateral and vertical extent of groundwater contamination.
42. Page 7-3, Section 7.1.2.2: There is no discussion in this section with
respect to the lateral and vertical extent of groundwater contamination.
43. Page 7-3, Section 7.1.2.3: A source of contamination is not specified in
this discussion.
44. Page 7-4, Section 7.1.2.4: A source of contamination is not specified in
this discussion.
-3-
-
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James 8. Hunt, Jr., Governor Division of Solid Waste Management
[phone]
Mr. Jonathan Bornholm
Remedial Project Manager
U.S. EPA Region IV
Waste Management Division
345 Courtland Street, N.R
Atlanta, GA 30365
June 16, 1993
Subj: Comments on Draft Final Remedial Investigation Report
National Starch and Chemical Company Site
Salisbury, Rowan Count, NC
Jonathan 8. Howes, Secretary
Ref: Comments on Draft Remedial Investigation, Letter from Bruce Nicholson,
NC Superfund Section to Barbara Benoy, U.S. EPA Region IV of 7 April 1993.
Dear Mr. Bornholm:
The NC Superfund Section has reviewed the Draft Final Remedial Investigation Report
of June 2, 1993. We offer the following comments.
1. The response to State Comment Number 1 (see referenced letter) concerning waste
generating and handling practices at the facility is inadequate. I am aware that EPA
also requested this information be included (as per EPA Comment 54, 28 April
1993). The State supports EPA's request for this information and reiterates the
, importance of including this information in the RI. This is particularly important
given the fact that it has now been demonstrated that waste handling pipes have
leaked into the subsurface, apparently as late as February 1993 when new stainless
pipes were installed. The current and past waste generation and handling practices
should be discussed in full in the Final version of the RI. The State suggests that this
issue may best be resolved via conference call between EPA, the State, and National
Starch rather than go through another iteration of comments and revisions on this
issue.
P.O. Box 27687, Raleigh, N0:-th Carolina 27611-7687 Telephone [phone] Fax# [phone]
An Equal Opportunity Affirmative .Action Employer
Mr. Bornholm
June 16, 1993
Page 2
• -
2. In its response to State Comment Number 6 on the Draft RI (see referenced letter),
National Starch has indicated that "Based on the soil contamination, the groundwater
isopleths have been adjusted, ... " However, upon further review, Figure 4-4 does not
appear to have been adjusted at all. The State continues to assert as it did in
Comment 6 on the Draft RI that, although the isopleths on the figure represent
"available" data there are serious data gaps at the northwest comer of the operations
building that are not reflected on the figure. As a result the figure is misleading.
Based on the current conceptual model of the site, the source for the western lobe
of contamination at Area 2 is the northwest comer of the operations building.
However, there is no groundwater data from this area. Isopleths alone do not fairly
represent this concept, and in fact, they imply that there is no source at the northwest
comer of the operations building. At a minimum, the text should so state and
explain that the northwest comer of the operations building is a potential source that
has not been examined and is an area of uncertainty in the representation of the
plume.
3. The State notes that Figure 4-7 (previously Figure 4-3 in the Draft RI) has been
corrected as per State Comment No. 8 (see referenced letter). The State further
notes that Comment No. 8 may have been confusing because of the incorrect
reference to 'Table 4-3" instead of "Figure 4-3". The comment did not refer to Table
4-8, as had been assumed in the response to comments, but to Figure 4-3 which has
evidently now been corrected.
4. Page 4-5, Section 4.3.2.2 Typo -"sliphizleinnards". The State knows for a fact that
there are no "sliphizleinnards" in the Salisbury area. They've been prohibited for
quite a while. You have to go way out of State before you encounter any.
As you know, we have not yet received comments from the Division of Environmental
Management on this remedial investigation. We will forward these comments to you when
we receive them. If you have any questions concerning these comments, please contact me
at [phone].
bin\let\nsccou3f
Sincerely,
~ ?fJk;£--.
Bruce Nicholson
Environmental Engineer
Superfund Section
..
State of North~ .
Department of Environment, 1M .
Health and Natural Resources u u"f:.(,,bi!::. -_ •
Division of Environmental Management JU, l.!,,,,J
James B. Hunt, Jr., Governor SUp, f o 1 I!
Jonathan B. Howes, Secretary . 1ENFurvo ~J:r EHN R
A. Preston Howard, Jr., P.E., Director "t.r,l!ON
June 1 8 , 1 9 9 3
M E M O R A N D U M
TO:
FROM:
RE:
Jack Butler, PE, Head
Special Project Br~
'.)1' Preston Howard -<lJ,( .
National Starch and Chemical
Draft investigation Unit 3
NCD 991 278 953
Rowan County
Proj. #93-18
As requested, the Division of Environmental ·Management has
reviewed the subject document. The comments from our Groundwater,
Water Quality and Air Quality Sections are provided below.
Groundwater Section Comments:
The Groundwater Section has two comments to offer:
1. The soil boring illustrated in Figure 4-3 (distribution
of 1,2 DCA in soil samples, Area 2)" shows that there are
not enough soil borings on the west side of area 2
to conclude that 1,2 DCA contamination in soil decreases
as indicated by the isoconcentration lines.
2. Table 4-5 indicates that GW 1 measures 660,000 ppb 1,2
dichloroethene while figure -4-2 shows 660,000 ppb 1 , 2
dichloroethane.
The two items above should be addressed and corrected.
Water Quality Section Comments:
Water Quality Section has no comments to offer at this time.
P.O. Box 29535, Raleigh, North Caroline 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
.. -
Air Quality Section Comments:
Air Quality Section has no comments to offer at this time.
Thank you for the opportunity to review the subject document.
Should you have any comments or wish additional discussion on this
matter please contact Brenda Smith at [phone].
NT/nt/RCR-MR.18
CC: Arthur Mouberry
Steve Tedder
Alan Klimek
Brenda Smith
Nargis Toma
i. " .. -STAT[,_, "~ __ .. ~,,.., ~
(cl!./ ; ~ ~-
-:t.1'Jf (?1;§)
lJi.~_pj ....... , .. ,,./,,. ~
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Division of Solid Waste Management
(919) 73'.;-2801
Mr. Jonathan Bornholm
Remedial Project Manager
U.S. EPA Region IV
Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
June 16, 1993
Subj: Comments on Draft Final Remedial Investigation Report
National Starch and Chemical Company Site
Salisbury, Rowan Count, NC
Jonathan B. Howes, Secretary
Ref: Comments on Draft Remedial Investigation, Letter from Bruce Nicholson,
NC Superfund Section to Barbara Benoy, U.S. EPA Region IV of 7 April 1993.
Dear Mr. Bornholm:
The NC Superfund Section.has reviewed the Draft Final Remedial Investigation Report of June 2, 1993. We offer the following comments.
1. The response to State Comment Number 1 (see referenced letter) concerning waste generating and handling practices at the facility is inadequate. I am aware that EPA also requested this information be included ( as per EPA Comment 54, 28 April
1993 ). The State supports EP A's request for this information and reiterates the importance of including this information in the RI. This is particularly important
given the fact that it has now been demonstrated that waste handling pipes have leaked into the subsurface, apparently as late as February 1993 when new stainless pipes were installed. The current and past waste generation and handling practices should be discussed in full in the Final version of the RI. The State suggests that this issue may best be resolved via conference call between EPA, the State, and National Starch rather than go through another iteration of comments and revisions on this issue.
P.O. Box 27687, Raleigh, NC':-trl Carolina 27611-7687 Telephone [phone] Fax# [phone]
An Equal Oppon:uniry Affirmative Action Employer
••
Mr. Bornholm
June 16, 1993
Page 2
-
2. In its response to State Comment Number 6 on the Draft RI (see referenced letter),
National Starch has indicated that "Based on the soil contamination, the groundwater
isopleths have been adjusted, ... " However, upon further review, Figure 4-4 does not
appear to have been adjusted at all. The State continues to assert as it did in
Comment 6 on the Draft RI that, although the isopleths on the figure represent
"available" data there are serious data gaps at the northwest corner of the operations
building that are not reflected on the figure. As a result the figure is misleading.
Based on the current ·conceptual model of the site, the source for the western lobe
of contamination at Area 2 is the northwest corner of the operations building.
However, there is no groundwater data from this area. Isopleths alone do not fairly
represent this concept, and in fact, they imply that there is no source at the northwest
corner of the operations building. At a minimum, the text should so state and
explain that the northwest corner of the operations building is a potential source that
has not been examined and is an area of uncertainty in the representation of the
plume.
3. The State notes that Figure 4-7 (previously Figure 4-3 in the Draft RI) has been
corrected as per State Comment No. 8 (see referenced letter). The State further
notes that Comment No. 8 may have been confusing because of the incorrect
reference to "Table 4-3" instead of "Figure 4-3". The comment did not refer to Table
4-8, as had been assumed in the response to comments, but to Figure 4-3 which has
evidently now been corrected.
4. Page 4-5, Section 4.3.2.2 Typo -"sliphizleinnards". The State knows for a fact that
there are no "sliphizleinnards" in the Salisbury area. They've been prohibited for
quite a while. You have to go way out of State before you encounter any.
As you know, we have not yet received comments from the Division of Environmental
Management on this remedial investigation. We will forward these comments to you when
we receive them. If you have any questions concerning these comments, please contact me
at [phone].
bin\let\nsccou3f
Sincerely,
~ ;(Jk;( __
Bruce Nicholson
Environmental Engineer
Superfund Section
•• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
JUN 4 1993
4WD-NCRS
Mr. Bruce Nicholson
North Carolina Department of Environment,
Health and Natural Resources
401 Oberlin Road
Raleigh, NC 27605
RE: Request to Review Revised Draft Remedial Investigation Report for Operable
Unit #3 for the National Starch & Chemical Company Superfund Site
Dear Mr. Nicholson:
The Potentially Responsible Party's (PRP's) Contractor, IT Corporation, sent the
State two one copies of the above referenced document for review. The NSCC site
is located in Salisbury, Rowan County, North Carolina and is a Super fund
enforcement undertaking. Phase I of OU-3 field work, which was based on the work
plan approved by the Agency on May 8, 1992, was conducted in May and June 1992.
OU-3 Phase II field work was conducted from November 1992 to March 1993. The
field work conducted during this phase was based on an addendum to the work plan.
The addendum was approved by the Agency on November 30, 1992.
The revised OU-3 RI Report (June 2, 1993) was reportedly modified in accordance
to the comments the Agency conveyed to the PRPs on the March 18, 1993 draft RI
report. A copy of the PRP's response to EPA's comments (which included the
State's comments) is included in the document. Please review the revised draft
RI to insure your comments have been adequately addressed. As I am still in the
process of getting up to speed on this Site and do not know all the nuances and
peculiarities of the Site, I ask that you look closely at the PRP's responses and
the modified text in the revised RI. If you have any additional comments, please
submit them to me by Wednesday, June 16, 1993 as this OU-3 is slated to have the
Record of Decision completed in this fiscal year. If you do not have any
additional comments and you concur with the revised RI, please inform me of your
concurrence via a memo or telephone call. Thank you for your efforts and time.
If you have any questions, I can be reached at 347-7791,
Sincerely yours, t:. !c::::m<--
Remedial Project Manager
cc: Michael Kelly, NCDEHNR
Printed on Recycled Paper
•
June 16, 1993
To: National Starch and Chemical Company NPL Site File
From: Bruce Nicholsoni,A~
Subj: Telecon with Arthur Mouberry, Chief, DEM Groundwater Section,
733-3221.
I spoke with Mr. Mouberry via telephone and told him that we
had received two copies of the Final Remedial Investigation for the
National Starch and Chemical Company (NSCC) NPL Site. I told him
that DEM is currently reviewing the Draft version and we have not
yet received comment. I hesitate to send the Final version while
review of the draft may be nearing completion.
He concurred that because the review has been .well underway
that DEM should complete its review of the draft before sending him
the Final version. It would probably cause more confusion to
review the Final from scratch. If there are significant comments
on the Draft we can compare it to the Final to see if they already
been addressed.
bin\tel\nsccmou
[i] INTERNATIONAL
TECHNOLOGY • CORPORATION
TO
312 DIRECTORS DRIVE
KNOXVILLE. TENNESSEE 37923
[phone]
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8e_g1DY'.,.IfC EfA
LE OF TRANSMITTAL
OATE 6-JOB
ATTENTION
SUBJECT
WE=-ENDJNG YOU□ Under separate cover via ________ the following items:
0 Flow sheets
□ Shop drawings
0 Copy at letter
COPIES DATE
.3
OP&ID
□ Prints
O Change order
NO.
THESE ARE TRANSMITTED as cnecked below:
0 For approval
~your use
□ As requested
O Approved as submitted
C Approved as noted
C Returned for corrections
0 For review & comment C
□
□ Plans
□
0 Samples 0 Spec1tications
C Resubmit __ copies for approval
0 Submit __ copies tor distribution
C Return __ corrected prints
□ FOR BIDS DUE---~-----...;_ ___ 19 □ PRINTS RETURNED AFTER LOAN TO US
REMARKS Eb,. re..5 foaJue,cia .,,+Jr left <211 t l)f D(\a / £r-de./2rgc1Pe,
file o/',;:, ½Jlz..., :fie any ?aco t11fE't1lenc&
SIGNED:
3 ,a-9-ee
• .. • SUPERFUND FACT SHEET
FINDINGS OF OPERABLE UNIT #3
REMEDIAL INVESTIGATION
NATIONAL STARCH & CHEMICAL COMPANY
Salisbury, Rowan County, North Carolina
June 1993
INTRODUCTION
The information presented in this Fact Sheet is based on activities that have transpired since the dissemination of the Agency's
last Fact Sheet (June 1991) and more importantly, the findings/conclusions highlighted in the revised June 1992 Remedial
Investigation Report for Operable Unit #3 at the NaUonal Starch & Chemical Company (NSCC) SUperfund Site. The goals of
a remedial investigation are to determine the nature and extent of contamination at a Supertund site; establish criteria for cleaning
up the Site as well as the clean up criteria themselves; identify preliminary remedial action alternatives; and support the technical
and cost analyses and evaluations of the potential remediation alternatives in the Feasibility Study. An updated schedule of major
milestones is also included in this fact sheet. The next Fact Sheet (the Proposed Plan for Operable Unit #3).will summarize the
findings/conclusions of the Feasibility Study and present the Agency's preferred remedial alternative for the contamination
associated with Operable Unit #3. The Proposed Plan fact sheet should be mailed to the public in the earty part of next month.
SITE DESCRIPTION
The NSCC site was proposed for inclusion on the National
Priorities List (NPL) in April 1985 and finalized on the list in
October 1989. The Site had a Hazardous Ranking System
(HRS) score of 46.51. This score is based on the following
exposure route scores: exposure via groundwater pathway -
80.46, exposure via surface water pathway -0.00, and
exposure via air pathway -0.00. The Site currently is
cataloged as numbered 257 of the 1,249 Superfund sites
across the country on the National Priorities List Only Sites
· with a Hazardous Ranking System score of 28.5 or higher
are eligible to be placed on the National Priorities List.
The NSCC facility occupies 465 acres on Cedar Springs
Road on the outskirts of Salisbury, North Carolina.
Presently, land use immediately adjacent to the Site is a
mixture of residential and industrial developments. East and
south of the Site are industrial parks consisting primarily of
light industrial operations. The west and north sides of the
NSCC property are bordered by ,esidential developments.
Refer to the Rgure 1 for Site location.
A surtace stream, referred to as the Northeast Tributary,
crosses the NSCC property parallel to Cedar Spring Road
and passes within 50 yards of the manufacturing area of the
facility (refer to Rgure 2). Surtace water runoff from the
eastern side of the facility discharges into this tributary. The
focus of the Operable Unit #3 Remedial Investigation was to
determine the source, nature, and extent of the
contamination entering this stream.
SITE HISTORY
In September 1968, Proctor Chemical Company purchased
the 465-acre tract of land on Cedar Springs Road. Within
the next year, Proctor Chemical was acquired by NSCC
which operated the facility as a separate subsidiary.
Construction of the plant on Cedar Springs Road began in
1970. On January 1, 1983, Proctor Chemical Company was
dissolved and its operations merged with NSCC.
Primarily, this facility marufactures textile-finishing chemicals
and custom specialty chemicals. Volatile and semi-volatile
organic chemicals are used in the production process along
with acidic and alkaline solutions. Acidic and alkaline
solutions are also used in the cleaning processes. The
waste stream from the manufacturing process include
reactor and feed line wash and rinse solutions. This
wastewater may include a combination of the following
chemicals: acrylimide, 1,2--0ichloroethane (1,2-DCA), methyl
isobutyl ketone, methanol, styrene, maleic anhydride, vinyl
toluene, sulphonated polystyrene, epichlorohydrin, octyl
alcohol, ethyl alcohol, allyl alcohol, allyl chloride, sodium
hydroxide, and sulfuric acid.
+
+
AIRPORT
ROAD
SL; I
FIGURB 1
500 0 500 1000 i,;;......,.._....,..,_.,,.-=...,~---,.....,, SITE LOCATION MAP OF THE NATIONAL STARCH
& CHEMICAL COMPANY SUPERFUND SITE 250 750
GRAPHIC SCALE: !'=50(}'
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g I ~ I ~ j I I !
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The following discussion center-JS of the NSCC
plant that are adversely impacti ortheast Tributary.
tnfonnation on the other areas of the plant that are adversely
impacting the environment are contained in documents that
pertain to Operable Unit #1 and Operable Unit #2. Copies
of these documents are located in the infonnation repository
in the Rowan Public Library in Salisbury.
Operable Unit #3 Remedial Investigation efforts focused on
the areas of the facility referred to as Plea 2 and · the
wastewater treatment lagoons (refer to Figure 2). Area 2
consists of the foUowing operations: Plea 2 Reactor Room,
the Tank Room, i,aw Material Bulk Storage, and the
Warehouse. The lagoon area includes three lagoons.
These lagoons were constructed between 1969-1970 and
were unlined. From 1970 to 1978, wastewater was pumped
· to Lagoon 2 for treatment prior to being discharged into the
City of Salisbury sewer system. In 1978, Lagoon 1 was put
into service and Lagoon 3 was lined with concrete. In 1984,
Lagoons 1 and 2 were excavated and also lined with
concrete. Contaminated soil excavated from beneath the
lagoons was removed and disposed of in an area west of
the plant area. The saturated soil was landfanned and then
used as fill material for expanding the facility's parking lot
A fourth lagoon was installed in 1992 for pretreatment of
contaminated groundwater as part of the Operable Unit #1
Remedial Action (RA).
As the result of finding contaminants in groundwater and in
the surface water/sediment of the Northeast Tributary, the
original scope of work specified in the initial Remedial
Investigation/Feasibility Study Work Plan has been
expanded twice. The first Remedial Investigation and
Feasibility Study resulted in the first Record of Decision
(ROD) to be issued by the Agency on September 30, 1988
for the NSCC Superfund site. This Record of Decision
divided the Site into two operable units. The first Operable
Unit incorporated the installation of the groundwater
interception, extraction, and treatment systems in the
western portion· of the facility. The contaminants in the
groundwater found in the western portion of the facility are
emanating from the trench area. The second Operable Unit
required further investigation of the contaminated soils in the
trench area and additional monitoring of the surrounding
tributaries. The groundwater interception, extraction, and
treatment system is called Operable Unit #1 (OU-1) and the
trench soil and surface water and sediment investigation is
called Operable Unit #2 (OU-2) ..
The findings of the OU-2 Remedial lrrvestigation/Feasibility
Study resulted in the necessity of broadening the scope of
the investigation a second time at the NSCC facility. This
was documented in the second Record of Decision issued
tiy the Agency for the NSCC Superfund site on September
30, 1990. The second Record of Decision required NSCC
to investigate the contamination consistently detected in the
Northeast Tributary. This effort is designated as Operable
Unit #3 (OU-3). As in OU-1 and OU-2, the work performed
in OU-3 is tenned enforcement, which acknowledges that
the work is being performed by NSCC, the Potentially
Responsible P-,e engineering contractor hired
by the PRP to U-3 work is TT Corporation.
OU-3 SPECIFIC REIIEDIAL INVESTIGATION
OBJECTIVES _;0
The following is a synopsis of the work conducted as part of
OU-3. The work was pertonned in two phases. Phase I
was based on the Work P1an approved by the Agency on
May 8, 1992 and the field work perfonned in May and June
1992. The objectives of Phase I were:
o detennine if contamination is migrating to Northeast
Tributary via the groundwater;
o detennine points along the Northeast Tributary
where potential contamination migration is
occurring;
o detennine tt soil in the parking area is a source of
contamination to the groundwater; and
o conduct an ecological screening assessment of the
Northeast Tributary.
To accomplish the objectives listed above, the following field
activities were perfonned:
seven surface water and seven sediment samples
were collected from the Northeast Tributary and
analyzed;
thirteen groundwater samples were collected and
analyzed using temporary groundwater wellpoints;
groundwater levels were measured to detennine
groundwater flow direction;
collected and analyzed two st.allow soil samples
from the parking lot area (a potential source area);
surveyed the horizontal and vertical locations of all
sample locations; and
perfonned an ecological screening investigation.
The findings of Phase I were presented in a document
entitled "Draft Remedial Investigation Report for Operable
Unit 3" submitted to the Agency in August 1992. Based on
the Agency's review of this draft report, the Agency required
NSCC to initiate a second phase of the investigation (Phase
11).
The scope of work to be conducted under Phase II was
approved by the Agency on November 30, 1992. The
objectives of Phase II included:
o define the extent of groundwater contamination;
"'
-15,0 -
• NS-37
(1J)
ABANDONED ----~ RAILROAD SPUA
NS-12
(NO)
-= _.,
I I\\ / I ,1
I I \I
J,'
;'/
" LEGEND
1.2.0C...CONCE:NTRATION
CONTOUR IN PPB
• 1.2.DCA. CONCENTRATION
NS-13 IN Pf>9. GAC>IJNDWA TEA
( 1 700) SAMPLES
PIGtlRB 3
DISTRIBUTION OF
1,2-DICHLOROETHANE
IN THE SAPRDLITE
ZONE OF THE AQUIFER
OPERABLE UNIT t3 NATIONAL STARCH &
CHEMICAL COMPANY
SUPERFUNO SITE
"' -
"'
-150 -
-150 I ...,
• NS-24
• NS-38
(1J)
(Not Sampled)
ABANDONED ____ _
RA!LROAO SPUR
_.,
----s
• NS-44
{ND)
NS-34
• (NO) ' ' "" ""
_1,·
/LEGEND
+ I
• NS-36
1.2-DCA. CONCENTRA
CONTOUR IN PP8
(11000)
\.2-0CA CO'ICe<l"RATION
IN F'PB. OAOl.N:IWATER
'-""LES
0 <(
0 a:
(/)
t') z a: a. (/)
a: <( 0 UJ u
~x»AATESCALE (IQ
.§{
FiGIJRJ! 4
DIST~IfurrION OF 1, 2-·01CBLOROETHAHE
IN THE}:BEDROCK
ZONE OF~ AQUIFER
OPERABLE UNIT #3 NATIONAL STARCH &
CHEMICAL COMPANY
SUPERFUND SITE
o identify the ~ources of -contamination;
o determine if soils are, or have been impacted by
leaking wastewater pipes; . I
o characterize the contamination and the
contamination source (i.e., identify the type and
concentration of contaminants present); and
o determine ~ ecological receptors of the Northeast
Tributary have been adversely impacted.
To fulfill Phase II objectives, the following field activities were
performed:
thirty-six groundwater samples were collected using
push-point water sampler, temporary well screen,
and screened water sampler, and analyzed;
ninety-six soil samples were collected and
analytically screened;
seven soil samples were collected and analyzed to
characterize-the contamination found in the soils;
surface water and sediment samples were collected
from two locations in the Northeast Tributary for
chemical analysis and chronic toxicity testing;
six saprolite and six bedrock monitoring wells were
installed and groundwater samples were collected
for chemical analyses;
surveyed horizontal and vertical locations of all
sam pie locations; and
confirmed locations of underground piping related to
the wastewater effluent and treatment system.
Phase II field work was performed from November 1992 to
March 1993.
ANDINGS BASED ON OU-3 REMEDIAL
INVESTIGATION
This section summarizes the conclusions specified in the
June 1993 document entitled "Final Remedial Investigation
Report for Operable Unit Three·. The Agency does not
concur with all the conclusions incorporated into this
document. Only those expressed below have the Agency's
full concurrence. The other cor~lusions expressed in the
"Final Remedial Investigation Report for Operable Unit
Three· are suppositions made by the PRP and are not
supported by the data generated to date.
Three environmental media have been adversely impacted
by contamination from the NSCC plant which include surface
water/sediment, groundwater, and soils. The contamination
detected in the trench area and groundwater in the western
porti~n of the·fa-:essed in the first two Records
of Decision. T 1nation in the Northeast Tributary,
in the groundwater beneath the lagoons and Area 2, and the
contaminated soils in the lagoon area and Area 2 will be
addressed in the third Record of Decision. It is the Agency's
desire to issue the third Record of Decision by the end of
September 1993.
The nature and extent of contamination in the Northeast
Tributary has been well defined. The prtmary contaminant
in the surface water and sediment of this stream is 1,2·
dichloroethane (1,2-DCA). This contaminant is known as a
chlortnated organic compound that volatilizes readily and is
classified as a probable human carcinogen. Acetone was
also detected in the surface water and sediment but at lower
concentrations than 1,2-DCA. Acetone is a volatile organic
compound which volatilizes quickly. The highest
concentrations of contamination were detected in the stream
just east of the plant. The levels of contamination decrease
downstream as these volaWe organics volatilize into the
atmosphere. Two samples, one surface water and one
sediment, were collected from the Northeast Tributary prtor
to the stream leaving the NSCC property and flowing under
Airport Road. These samples revealed no contamination
which indicates that no contamination is leaving the Site via
surface water/sediment. The apparent source of the
contamination . in .. this stream is the discharge of .. _
contaminated groundwater from the saprolite zone of the
underlying aquifer. An aquifer is defined as an underground
geological formation or group of formations, containing
usable amounts of groundwater that can supply water wells
and springs.
The nature and extent of contamination in the aquifer
underlying the NSCC facility is not as well defined. The
aquifer has been divided into two zones that are
interconnected. Typically, the shallow zone of the aquiler is
recharged through precipitation (rain and snow fall).
Through the force of gravity, water typically moves through
the unsaturated soil zone into the saturated soil zone (the
shallow zone of the aquifer) and finally into underlying
bedrock. As the water infiltrates and migrates through the
soil, it can pick-up chemicals, whether naturally occurrtng or
man-made, and transport these chemicals as the water
moves. This is the general mechanism of how
contamination found . in surface soils can eventually
adversely impact the quality of the groundwater deep under
the ground surface.
Both the shallow and bedrock zones of the underlying
aquifer have been adversely impacted by activities at the
NSCC plant. Sixteen different volatile organic compounds
and four semi-volatile organic compounds were detected in
the groundwater. Of these contaminants, the most
widespread contaminant and the one found in the highest
concentrations is 1,2-DCA (1,2-dichloroethane). The highest
concentrations of 1,2-DCA were found in the shallow
groundwater. The concentration decreases with depth in the
aquifer. The highest concentration detected in the shallow
zone is 660,000 parts per billion and the highest
5
N 850 -
N 250 -
CHAIN LINK FENCE---~
E 250
ND ,sND
6
6 ND
NO · aAOUN~ATEA.~REENING PONT.
e:. SHOWING 1,2-0CA C0NCENTRA TlON
10000-
1,2-DCA CONCENTRATION
-. CONTOUR
NOTE. Con!1r~at1on data __ _
supplemented by _groundwater
screening data
0 .,
0 a:
(/)
~ a: o._
(/)
a:
c!i w (.)
APPROXIMATE SCALE (ft)
100 200
FIGURE 5
PLUMES OF
CONTAMINATION IN
THE AQUIFER BASED ON
THE DISTRIBUTION OF
1,2-DICHLOROETHANE ----------OPERABLE UNIT #3
NATIONAL STARCH &
CHEMICAL COMPANY
SUPERFUND. SITE
concentration of 1,2-DCA in :ha 18 of the aqutter
is 99,000 parts per billion'. ~le Drinking Water
standard for 1,2-DCA is 5 parts per billion; the level which
must be met during treatmenVcleanup. Figure 3 shows the
distribution of 1,2-DCA in the shallow zone and Figure 4
displays the distribution of 1,2-DCA in the bedrock zone.
There appears to be three plumes of contaminated
groundwater identified in OU-3. One emanating from the
lagoon area and two from Area 2 {refer to Figure S,. The
plumes outlined in Figure 5 are based on data for 1,2-DCA.
OU-3 did a good job in defining the nature of groundwater
contamination {the-contaminants present and their
concentrations) but additional work is needed to completely
define the extent of groundwater contamination in the
shallow zone and especially In the bedrock zone of the
aquifer. Groundwater in the shallow zone in the vicinity of
the lagoons is flowing at an approximate speed of 80 feet
per year. This rate appears to slow to approximately 27 feet
per year just east of the lagoon area.
Groundwater in the shallow zone moves both horizontally
and vertically. The horizontal movement results in some of
the groundwater discharging into the Northeast Tributary.
The groundwater moving vertically recharges the
groundwater in the bedrock zone of the aquifer. The
percentage of flow that occurs horiizontally and vertically in
the shallow zone was not detennined.
No flow rate or flow direction has been established for the
groundwater in the bedrock. Flow in the bedrock is
governed by the fractures in the rock. Typically, major
geologic features {such as rivers, mountain ranges, etc.)
control the overall flow direction of groundwater in the
bedrock. The clQ.S8st geologic feature that may be
controlling the flow of groundwater in the bedrock is Grants
Creek. The depth that the bedrock is fractured and hence
the depth contaminated groundwater may have reached at
the Stte was not well delineated.
Even though the exact extent of groundwater contamination
has not been completely delineated, there is sufficient
infonnation available to allow an evaluation of potential
groundwater remedial alternatives and for the Agency to
select a. preferred remedial alternative to present to the
public in the Proposed Plan fact sheet
The soil investigation generated ample infonnation to
effectively define areas contaminated in the vadose soil
zone. The vadose zone is comprised of subsurtace soil that
is not saturated with water. The top of the saturated zone
is commonly referred to as the water table. Fourteen
different volatile organic compounds, one semi-volatile
organic compound, and one pesticide were detected in the
vadose soils. As in the other environmental media
discussed above, 1,2-DCA and acetone are the primary
contaminants in the soil. The extent of soil contamination in
Area 2 shown in Figure 6 and Figure 7 depicts the extent of
soil contamination in the lagoon area. Both of these figures
are based on 1,2-DCA data. The highest concentration of
1,2-DCA dete-Jils was 1,600,000 parts per
billion.
Although OU-3 RI defined the nature and extent of soil
contamination in the OU-3 area of the NSCC facility, the
Remedial Investigation did not clearly identify the sources for
the contamination found in the soils. The report did identify
several possibili1ies. The potential sources for the
contamination found in the soil and groundwater include: the
underground terra-cotta piping, soils used to construct the
parking lot, and the original unlined lagoons {all lagoons are
now lined).
Even though the source or sources of the soil contamination
have not been fully identified, there is sufficient information
available to allow an evaluation of potential remedial
alternatives for source remediation {cleanup of contaminated
soiQ and for the Agency to select a preferred remedial
alternative to present to the public in the Proposed Plan fact
sheet.
BASELINE RISK ASSESSIIENT
A Baseline Risk Assessment evaluates the potential risks to
human health and the environment due to releases of
contaminants from a Superfund Site. The specific objectives
of the baseline rlsk assessment are to:
o identify and provide analysis of baseline risks
(defined as risks that might exist if no remediation or·
institutional controls were applied at the Stte) and
help detennine what action is needed at the Site;
o provide a basis for determining the levels of
chemicals that can remain on site and still not
adversely impact public health; and
o provide a basis for comparing potential health
impacts or various remedial alternatives.
In order for there to be a risk, two prerequisites must be
mel First, there must be a route or pathway leading to an
exposure and secondly. the chemicals a person or
population are exposed to must have some degree of
toxicity associated with them. If neither of these criteria are
presen~ then no risk to human health or the environment
can occur.
At the NSCC site, a number of chemicals were detected
each.exhibiting its own degree of toxicity. The chemicals
are listed alphabetically: acetone, bis (2-chloroethyl) ether,
bis (2-ethylhexyl) phthalate, 2-butanone, carbon disulfide,
chlorofonn, chloroethane, delta-BHC, 1,2-dichloroethane
(1,2-DCA), 1,2-dichloroethene, ci-n-butyl phthalate, di-n-octy1
phthalate, ethyl benzene, methylene chloride, styrene,
tetrachloroethene, toluene, 1, 1,2-trichloroethane,
tnchloroethene. vinyl chloride and total xylene. In addition
to evaluating the toxicity of each chemical detected at the
Site, the Baseline Risk Assessment also evaluated all
' --------------
.. :-
I ...
APPROXIMATE SCALE (ti)
0 100 200· 400
DRIVEWAY
LAGOON 1
APPROXIMATE SCALE (ft)
0 100 200 300 400
,oo
•'PARKi~·~
LOT
500
[[---+---~
' --,~,
w.-an.w.o.T(IICCIU..l:CTION f'1T PARKING
AREA
SBl.A-18
19000(7.5)
LAGOON2 :' saLA-03 :. ■ ?3(7.5)
500
SBLA-08 ■
3J(1.5)
0
• SBLA-09
2J(3.5)
LEGEND
■ SOIL SORING lOCAOON SH()','IING MA.XIMUM
I 2 DCA CONCENTRATION (ppO) ANO
!DEPTH (n)I OF MA,;,;kMtJM CONCENTAA110N
IOJ 1 2 DCA CONCENTRATION CONT~
WASTE-WA. TEA l"'1::. A..RA0W INDICATES
~RECTION OF FlOW
NOTE Conl,rm&l>Orl da!a svppl<,me,iled t,v
'IO,I sc,....,,,r,g d.11&
FIGURB 6
DISTRIBUTION DF 1,2-DIClll,QROETHANE IN
SOIL AROUND AREA 2
THE
OPERABLE UNIT #3 AT THE NATIONAL STARCH & CHEMICAL
COMPANY SUPERFUND SITE
LEGEND
SOL BORNO SHOWING 1.2-0CA CClNCEHTAAllON ■ (ppt,) ANO (DEPTH fl!)) CF 1.tAXM..M
CONCENTRAIION
WA.STE-W-' TEA LINE. W<PON INDICATES
DIRECTION OF FLOW
ABANDONED UNE
1 2-DCA CDNCENTAA 110N CONTOUR 10000-'
NOTE: Conl,rm,ot,on data ~led by soot sc,...,rnni;i dat•
FIGURE 7
DISTRIBUTION OF 1,2-DICHLOROBTHANE IN THE
SOIL AROUND THE LAGOON AREA
OPERABLE UNIT t 3 AT THE
NATIONAL STARCH & CHEMICAL
COMPANY SUPERFUND SITE
potential exposure pathways .•
pathways evaluated:
the exposure
incidental ingestion of creek sediment (current and
future)
incidental ingestion of surtace water (current and future)
dermal contact ajth creek sediment (current and future)
dermal contact with surface water (current and future)
inhalation of volatile chemicals partitioning to air from
surface water ( current and future)
incidental ingestion of groundwater at springs (current)
dermal contact with groundwater at springs (current)
ingestion of groundwater as drinking water (future)
inhalation of volatile chemicals partitioning to air from
groundwater during domestic water use (future)
incidental ingestion of soil (current and/or future)
dermal contact with soil (current and/or future)
As can be seen from the list above, the Agency is not only
required to protect current human health but must also
protect the health of future populations.
A goal of.the Agency is to reduce the risk posed by a
Supertund site to below one person out of 10,000 being at
risk. This is the minimum risk the Agency will allow, typically
the Agency aspires to be even more protective and strives
to lower the risk so that at a minimum, only one person out
of one million may be adversely impacted by the
contamination found at the Site. This is the goal the Agency
has set for OU-3 at the NSCC site.
EPA has concluded that there are no major current risks to
human health at tine Site. However, under certain future risk
scenarios the ccntaminants at the present concentrations
would pose unacceptable future risks. The ccntaminated
groundwater poses the greatest future risk under the
scenario that ccnsiders residents living in homes built on the
Site using private, potable wells.
Data generated by tine ecclogical assessment of the
Northeast Tributary found adverse ecclogical impacts in
areas of tine stream where elevated levels of 1,2-DCA were
detected. However, the assessment cculd not ccncluded
that the contaminants originating from the Site, primarily 1,2-
DCA, are the scle cause of this impact There is a strong
indication that the naturally-limiting factors of the stream
itself has contributed to the diminished numbers of benthic
(bottom-dwelling) organisms in this reach of the Northeast
Tributary. Since ccncentrations of 1,2-DCA in this stream
have exceeded EPA Region IV water quality criteria,
additional monitoring of the Northeast Tributary is warranted.
RECENT MILESTONES [Z1
May 1992 --Agency approves Work Plan for OU-3
August 1992 --PRP submitted dratt OU-3 Remedial
Investigation Report
September ·;99-informs PRP to expand OU-3
emedial Investigation
November 1992 --EPA approves addendum to OU-3
Work Plan
March 1993 --PRP · resubmits draft OU-3
Remedial Investigation Report
April 1993 --RP submits dratt OU-3 Feasibility
Study Report
June 1993 --PRP submits revised OU-3
Remedial Investigation Report
FUTURE ACTIVmES
Currently, lhe PRP is revising the dratt Feasibility Study
document in acccrdance to comments the Agency
transmitted. The ccmments were formulated by the Agency,
the Agency's oversight contractor, and the State of North
Carolina Department of Environment, Health & Natural
Rescurces. The revised Feasibility Study document is to be
submitted to the Agency by June 21, 1993. Following the
review of this revised document and its acceptability, the
Agency will prepare and distribute the Proposed Plan fact
sheet. The Proposed Plan fact sheet will summarize the
Feasibility Study, designate applicable or relevant and
appropriate requirements, list the remedial action
pertormance standards (cleanup goals), identify the
Agency's preferred remedial alternative for addressing the
contamination associated with OU-3, inform the public of the
30-day public ccmment period, initiate the 30-day public
ccmment period, and announce the time and location of the
Proposed Plan public meeting.
INFORMATION REPOSITORY
Documents that have been developed over the past few
years describing findings from investigations and various
studies as well as Supertund activities that have been
occurring at the Site are available for public review and
ccmment in the repository located at:
9
Rowan Public Library
201 West Fisher Street
Salisbury, N.C.
Phone: [phone]
Hours: Monday -Friday -9:00 am -9:00 pm
Saturday 9:00 am -5:00 pm
Rtglon 4
. MORE INFORMATIO-inforinati"17 al:lout the Site, -ontact:
, Jon Born ho Im, Remedial Project Manager .. ,,. · .
. • , '" t''i;•,0~'.(o' :Diane ,Barrett;,_Community;R~!ati.ons,:~~~j11at~r,,:ei',\ire1,'<:1:-:• •<f,<if.l½'.!\'~<ii/f ,•cse,1,:"c:,il'l ,,.,
North Superfund Remedial Branch · ;.,,. · · · · · · . . . , I' ~ , . U.S.E.P.A., Region 4 · /.; ' ···
345 Courtland Street, NE ·
Atlanta, GA 30365
Phone: 1-800-43S:923:f
r--------------------------------------------------------------------------------------------, I I I i MAILING LIST ADDITIONS
I I
If you are not already on our mailing list or know someone that would like to be placed on the list to receive
future information on the National Starch & Chemical Company Superfund Sit~. please compl~te this form
and return to Diane Barrett, Community Relations Coordinator at the addr~,ilidicated on this page.
NAME-------------------------
ADDRESS ------'------'------------JEE
CITY, STATE, ZIP CODE -------------------=~~
PHONE NUMBER----------------------
L-----------------
U.S. Envlronmental Protection Agency
345 Courtland Street, N.E.
Adanta, Georgia 30365
North SUperfund Remedial Branch
Diane Barrett, Community Reladons Coord.
Jon Bornholm, Remedial Project Manager
. -r .. .,. -· . '. . \· ' .. · .. .
I .J',1!• , ". ,, ).< ;.,. · .. ,· c. [ _
I\ ~u-• " --
Offlclal Business JUN 18 lj'.:Jj Penalty for Private Use $300
SiJPERf-llND SECTION
S/F· l~SCCOOl l
MR. bRUC~ NlCHULSON
ENVIRONMENTAL ~NGR., SUPERFUNO SECTlON
N. C. DEPT. Of ENV!R □NMlNT, HEALTH
~ NATURAL ~~SOURCES
P. □• 60X 27687
RALEIGH NC 27bll-7687
1111 !Ill I'' I, I I I I' I' I I I I'', I\ I'' I I\ I''\' 11, I\''\ I\' I I\ i I'\ I\'' I 11 \" '\
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
/jru. c e_
MIW 2 6 1993
HtGt.U~tftJ
JUNO 1 1993
4WD-NCRS
SUPERfllND SEtllON
Mr. Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
RE: Notification of Change in the Remedial Project Manager
Dear Mr. Samson:
This letter notifies the Potentially Responsible Party for the National Starch
& Chemical Company (NSCC) Superfund site located in Salisbury, North Carolina
that with Ms. Barbara Benoy going on an IPA to the State of Nevada, the remedial
project responsibilities have been reassigned to me. This notification fulfills
the following requirements of the ensuing enforcement documents the Agency has
initiated with regard to the NSCC site:
• In accordance to Section VII. DESIGNATED PROJECT COORDINATORS of the
December 1, 1986 Administrative Order on Consent, the Agency is
notifying the Respondent in the change of EPA's Project Coordinator;
• In accordance to paragraph 38 under section XIII. PROJECT
COORDINATORS of the Consent Decree governing the implementation of
Operable Unit #2 Record of Decision, the Agency is notifying the
Settling Defendant in the change of EPA's Project Coordinator; and
• In accordance to Section VII. Project Coordinator of the July 27,
1989, Unilateral Administrative Order, the Agency is notifying the
Respondent in the change of EPA's Project Coordinator.
If you have questions, please feel free to call me at [phone].
Sincerely yours,
A11\ /( ~ ~-----
J-bn K. Bornholm
Remedial Project Manager
cc: Elmer Akin, EPA
Jim Cole, CDM/FPC
Bruce Nicholson, NCDEHNR
Ray Paradowski, NSCC
Kittybelle Rivera, EPA
Winston Smith, EPA
Robert Stern, EPA
Michael Sturdevant, IT
Printed on Recycled Paper
• UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
APR 2 8 1993
4WD NSRB
Alex Samson
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site
Salisbury, North Carolina
Operable Unit 3
Remedial Investigation Report
Dear Mr. Samson:
RECEIVED
MA't-4 1993
SUPERfllNO SECTION
This letter provides EPA's comments on the Operable Unit 3 Remedial
Investigation Report. The attached comments include several sets
of comments. Written responses to all comments are due to EPA on
May 12, 1993. The final report will be due no later than May 28,
1993.
The Feasibility Study was submitted late as have multiple documents
been in the past year, including both major and minor submittals.
This is not indicative of a cooperative spirit as is necessary
under an Administrative Order on Consent. Failure to correct this
problem may result in the Agency issuing a Unilateral Order for the
remaining work under this Operable Unit.
Please do not hesitate
concerning this letter.
nUmber 404/347-1695.
to contact me if you have any questions
I can be contacted at 404/347-7791 or fax
~4~
Barbara H. Benoy
Remedial Project Manager
Waste Management Division
cc: K. Rivera, ORC J. Dupont, WD
W. Smith, WD H. Graulich, NSCC
R. Paradowski, NSCC ,./ M. Sturdevant, IT
B. Nicholson, NCDEHNR J. Cole, CDM
Printed on Recycled Paper
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National Starch & Chemical Company NPL Site
Salisbury, North Carolina
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EPA Review Comments
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1.
2.
General Comments
Tables
In the tables presenting the concentrations of analytes in
samples collected at the subject site, the tables do not
include the detection limit for an analyte or analytes that
were not detected and list either ND or U. All of the tables
presenting either ND or U for an analyte or analytes that were
not detected shall be revised to include the appropriate
detection limit. It is not sufficient to indicate that the
detection limits are listed in the raw data included in the
appendices. Suggest footnotes.
Figures
Additional figures shall be provided in RI and will include:
1) The original blueprint(s) of the plant which show clearly
the locations of all drainage pipes and construction details.
The blueprints were shown to Barbara Benoy during a site visit
with Ray Paradowski; Mr. Paradowski agreed to submit copies to
EPA. As of the writing of these comments, EPA has not
received these copies. 2) The large scale map which has been
developed for the site, (l" = 200'), showing all historical
installations, residential areas, pretreatment locations, etc.
3) An updated figure, (l" = 200'), showing all installations,
activities, etc. for Operable Unit 3. 4) The updated figure,
possible redused, that presents sampling locations and
concentrations of major contaminants.
General Comments
3. Section 1.1.1. 3rd paragraph
Sentence indicates that all runoff from the plant is directed
into sumps and pumped through the treatment system. Physical
observation of the site clearly shows that this is a false
statement. Text shall be corrected to indicate that a portion
of the runoff may be directed into the treatment system, but
the majority of the plant runoff is not directed.
4. Provide further information to substantiate that the
headwaters of the northeast tributary receive industrial
runoff from the east. A more clear definition/description of
these headwaters shall may be included.
5. Qualify the discharge from the W .A. Brown plant by identifying
whether the discharge is upstream or downstream from the NSCC
plant. Historical maps indicate that this is a downstream
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discharge.
6. Section 1.1.1. page 1 2. 1st full paragraph
The subdivision shall be shown and clearly identified on the
above required site figure.
7. Section 2.2.2
8.
9 •
Information regarding the concentrations of the 3 standards
used to prepare the calibration curve should be included in
the document. The upper and lower limits of the calibration
curve are determined by the concentration of the standards.
Section 2.2.4. pg. 2 8 1 second paragraph.
do not correspond and shall be corrected
SBA2-02 and/or SBA2-20.
Section 2.2.6
Text and Figure 2-5
for sample location
Substantiate why many wells were not included in the
collection of water level measurements.
10. Section 2. 2. 6, page 2-9 states that an IT geologist supervised
activities at every borehole. Telephone correspondence with
an IT employee on 1/22/93 indicated, however, that correlation
of drill cuttings from one of the monitoring wells was being
hampered because no geologist was onsite. Correct text.
11. Figures 3 1 and 3 2
Some of the ground water contours in Figures 3-1 and 3-2 do
not appear properly placed in relationship to observed water
elevations. If some of the ground water measurement data is
weighted, it must be documented.
12. After study of the potentiometric maps (Figures 3-1 and 3-2),
it appears that the bedrock and saprolite are functioning as
a single hydrologic unit. EPA expects that the bedrock and
saprolite are separate lithologic zones of orie aquifer. This
is further documented by statements on pages 1-2 and 3-4,
indicating that the two zones "are interconnected", there
"appears to be no confining layer" between them, and that
"there is little or no impedance between these two hydraulic
systems" .. Further guidance can be found in 40 CFR Part 260,
Subpart B, Section 260.10. Text shall be modified throughout
report to accurately reflect this.
13. Section 3.0 and 4.0
Presentation of and distinction between Phase I and Phase II
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data shall be included in the RI.
14. Section 4.0 and Table 4-4
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This table presents the results of the groundwater samples
that were split and analyzed by both the field screening GC
and a fixed laboratory. Though there is reasonable agreeement
between the two analyses, it shall be noted in text that the
field screening GC consistenly reported lower amounts of the
target compound, 1,2-dichlorethane, than the fixed laboratory.
15. Section 4.0 and Table 4-8
This table presents the results of the soil samples that were
split and analyzed by both the field screening GC and the
fixed laboratory. Though there is reasonable agreement
between the two anaylses, it should be noted that the field
screening GC often reported lower amounts of the target
compound, 1,2-dichloroethane, than the fixed laboratory.
Moreover, it should also be noted that the field screening GC
reported a number of false negatives; that is, the field
screened GC reported the taget compound as undetected but the
fixed lab laboratory reported that the compound was present.
16. Section 4.1, page 4-1, 2nd bullet
Text shall be modified to read: Identify the sources of
groundwater, surface water, soils, sediment contamination.
17. Page 4-2
Text shall identify the acetone source in NS-34.
18. Section 4.2
The document does not reference or specify the source of the
procedures used in validation of the fixed lab analytical
data. This omission shall be corrected.
19. Section 4.2
Provide substantiation as to why NS-33/NS34 are considered
background.
20. Section 4.3
Section shall include figures with groundwater well locations
identified or supply adequate reference to appropriate
figures.
21. Sec. 4.0. Reiteration from previous RI comments
While the average concentrations of 1,2-dichloroethane (1,2-
DCA) in surface water at the four sampling locations in the
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EPA Review Comments
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22.
tributary have apparently been steady, the concentrations at
SW-13 have increased (from 880 to 1800 to 3200 ug/1) and
concentrations at SW-14 have decreased (from 1700 to 1200 to
590) from 1990 to 1992. Text shall state this.
Section
Further
metals.
4.3.1, page 4-3
justification is required on the elimination of
23. Sec. 4.3.1. p. 4 3
This section states that data for metals will not be discussed
in the subsequent sections because "all metals were detected
at concentrations within one order of magnitude of their
background concentration". All data shall be discussed in the
appropriate sections. If contaminants are present at
concentrations that are at least two times· the background
concentration (not just an order of magnitude greater), they
are evaluated in choosing the contaminants of concern. Also,
a discussion of metals (inorganics) is included in the
sections following this one (e.g. , Section 4. 3. 2. 2, page 4-4) ,
so the original statement does not make sense. Clarify this
point.
24 .. Sec. 4.3.2. p. 4 3
This section indicates that the Phase I and Phase II surface
water and sediment data would be used in conjunction with the
previously collected data for evaluating surface water and
sediment contamination in the Northeast Tributary. However,
surface water and sediment data obtained prior to Phase I (as
shown in Table 1-1) are not discussed in Sections 4.3.2.1 and
4.'3.2.2, pages 4-3 to 4-4. These sections should compare the
Phase I and Phase II data with the earlier data for surface
water and sediment, especially with respect to trends in
concentrations over time and downstream distance. ( For
example, see previous EPA comments on the Draft Ecological
Assessment of the Third Operable Unit: Aquatic Toxicity
Testing.)
25. Also, state that Phase II surface water and sediment samples
were analyzed for inorganic contaminants shall be included.
26. Table 4-1
To help clarify this table, change the title
"Concentrations of Inorganic Analytes in Background
Surface Water, and Ground Water Samples from OU3".
to read
Sediment,
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27. Table 4-2
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Since this table includes both Phase I and Phase II data,
include Phase II in the title.
28. Sec. 4.3.2.1.-p. 4 3
State that Table 4-2 also includes Phase II data for organic
compounds in surface water and sediment, and discuss the Phase
II results.
29. It is stated that both surface water and sediment results for
Phase I are shown in Figure 4-1, but the figure shows only the
water samples. Therefore, clarify the sentence.
30. Since both surface water and ground water data from Phase I
are shown in Figure 4-1, but only the surface water data are
discussed in this section, state that a comparison of surface
water and ground water concentrations is given in Section
4. 3. 3, page 4.-4.
·31. Under the subheading Review of Data for 1, 2-DCA in Surface
Water and Sediment, include the pre-Phase I data, as well as
the Phase I and Phase II data. Then, discuss any trends in
concentration with respect to downstream distance and time.
32. Figure 4-1
This figure is very difficult to follow, especially without
sampling location numbers. A different format shall be used
to present both the sampling location numbers and
concentrations. See earlier Figures comment.
33. Sec. 4.3.2.2, p. 4-4
According to Appendix H, some inorganic chemicals were present
in Phase II surface water and sediment at Station 13 at levels
greater than twice those at background Station 12. Therefore,
include a table showing the detected concentrations of
inorganics in the Phase II samples, and clarify what is meant
by "no significant differences between the samples".
34. Section 4.3.3. page 4-4
Figures are required for this section.
35. Section 4.3.3.1, page 4-5, second paragraph
Text states that 1,2-DCA was reported from only one sample.
This sentence is incorrect; text shall be corrected.
36. Section 4.3.3.1. third paragraph
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The data must be submitted immediately, with all appropriate
text, tables and figures that apply for EPA review.
37. Contrary to the statement on page 4-6, 1,2-DCA contamination
was found in ground water north of the plant fence in TWP-13.
Although this contamination was found in an earlier round of
sampling, it should have been verified or refuted through
additional investigation in the area. This doesn't appear to
have been done in the RI, and in fact, appears to have been
ignored. Text shall be modified to present this. RD work
will be required to finalize the extent of groundwater
contamination.
38. Section 4.3.4.1, page 4-10 incorrectly states that soils at
the Northeast corner of Lagoon 2 are not contributing 1,2-DCA
to ground water in the lagoon area. While these soils may not
be the source of ground water contamination, they may very
well be contributing to it. Text shall be corrected to
acknowledge this.
39. Section 4.3.3.1
Better substantiation for the interpretation of the chloroform
data_is required.
40. Table 4-5
1,2-Dichloroethene is listed twice. Table appears to have
omitted 1,2-dichloroethane in error. Table must be
resubmitted immediately with all data results.
41. Figure 4-5
An additional figure shall be provided showing acetone soil
concentration isopleths, so that direct comparisons can be
made to soil concentration isopleths of 1,2-DCA.
42. Section 4.3.3.3, page 4-8
43.
Provide more detailed information and rationale on why
"natural mineral constituents of groundwater" shall not be
addressed.
Section 4 • 3. 4. 1,
sentence shall be
of acetone (3,500
pg. 4-11, first paragraph. The fourth
changed to read "The highest concentrations
ppm) in soils ... "
44. Section 4.3.4
This is improper use_of the language "CLP" lab. Requirements
are that the lab must have the capability to conduct at least
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as well as the.CLP. EPA does not require that a Contract Lab
be used. Text shall be corrected. As written, text implies
that IT can utilize the CLP, which would be a conflict of
interest at this site.
45. Section 4.3.4.1, page 4-9. first paragraph
First paragraph: Thought by whom?
46. Second Paragraph: Be specific; identify numbers and location
of borings.
47. Define the site-specific "Soil vadose zone". Text shall be
modified to state that the extent of vertical contamination
was estimated and the Remedial Design will include field work
to substantiate the source of contamination in the onsite
areas.
48. Table 4-9
The blank areas in the table shall be defined,. e.g.,
nondetect, non-analyzed?
49. Figures 4-3, 4-4
Figures shall be supplemented with figure( s) which show
vertical distributions in a cross-sectional format.
SO. Section 4.3.4.1. page 4-10
Text incorrectly states that soils at the Northeast corner of
Lagoon 2 are not contributing 1,2-DCA to ground water in the
lagoon area. While these soils may not be the main source of
ground water contamination, they may very well be contributing
to it.
51. Section 4.0
This section requires a table(s) that identifies all sample
locations, types, depth, analyses, etc.
52. Table 4-5 Inconsistent use of distribution methods. Soil
contour map shall be provided for all areas of contamination.
53. Table 4.4 Data indicates lagoons may be leaking. Test shall
.state that the Remedial Design will be required to determine
the integrity of the liners in the lagoons.
54. EPA reiterates the position that the RI shall present specific
and detailed data concerning the plant operations, waste
generation, and waste handling.
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55. Section 4.4. page 4-12
The old piping referred to in Section 4.4, page 4-12 shall be
shown in a diagram, along with surrounding contaminant
concentrations in order to attempt a correlation between the
two. See earlier Figures comment.
56. Section 4.4, p.4-12
How do ground water contaminant concentrations compare to
concentrations of contaminants carried in the old piping?
Provide a narrative discussion. This information will be
helpful in determining the contaminant source in the area.
57. Section 5.11 bottom of page
This discussion seems to leave off many important factors in
the potential of migration. Volatilization plays a role
depending on the media; solubility is a much greater factor in
migration in groundwater than either adsorption or
biodegradation. This discussion shall provide a more indepth
and accurate discussion of all factors that are considered in
migration of a contaminants. Text may need to present the
information on a media-specific basis. Biodegradation is not
considered except in the uncertainty section of the Baseline
Risk Assessment if no site-specific data is generated to
support it.
58. Section 5.1. page 5-2
Text shall be modified to state that this may reduce the mass.
59. Biotrasformation of what will go to water, CO2, & HCl?
60. Identify which (are) ionic species.
61. Top of page 5-3
62.
The discussion of hydrophobia is overly simplistic and not
entirely accurate; Text requires modification.
Organic
Discuss
water?
Compounds, page 5-4
surface water use. Is surface water used for drinking
How far downstream?
63. First full paragraph. page 5-5
What is the point of these discussions?
64. These half-lives are not documented in a site-specific manner
and therefore is speculation from information provided from a
bench-scale level and not. an accurate description of site
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conditions.
65. Page 5-6
Define a "natural sink".
66. 1,2-DCA
Give full chemical names in decriptions.
commonly used acronyms.
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Also provide any
67. Page 5-8
sequence.
Inorganic ionic species: This text is out of
68. Page 5-8 Provide a mobility table.
69. Section 6.2. page 6-2
Last paragraph, What is SAS? This acronym is used in the
Superfund program to represent special analytical services.
Therefore, the acronym presents confusion. Report shall write
out the meaning and not use the acronym.
70. Section 6.2.1. page 6-2
This section need a figure here.
71. Table 6-1
What analyses were conducted?
72. What does footnote b mean? Sample size< 2? What does this
distribution really mean?
73. Section 6.2 and Tables 6-1 through 6-11
The five percent detection frequency discussed in the Risk
Assessment Guidance for Superfund (RAGS) is not intended to be
an absolute chemical selection criterion. Substances detected
at a frequency less than five percent may be appropriately
selected as a chemical of potential concern if, for example,
the "hit(s)" was at a high concentration, the substance is
extremely toxic, or the substance was detected in other media.
Report shall be corrected.
74. This section of the baseline risk assessment (BRA) should
contain initial tables which summarize the potential chemicals
of concern. The data summary tables should contain the
frequency of detection, range of detects, average
concentration, and background concentration. The non-detects
should not be incorporated into the average concentration at
this point in the BRA and the mean concentration should always
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represent the arithmetic mean. It is inappropriate to
evaluate the distribution of the data and calculate the 95
percent upper confidence limit (UCL) at this stage in the BRA.
The distribution and 95% UCL columns in Tables 6-1 through 6-
11 should be moved to the exposure assessment section of the
document. The equations used to calculate the 95% UCLs
(normal and lognormal) should also be presented in the
exposure assessment.
75. Table 6-2
Show background concentration.
76. · Table 6-3. page 2 of 2
A figure is ded to clearly show inside versus
plant as presented by IT.
77. Table 6-4
outside of
This table appears only to present Phase 2 samples and data.
Phase I data shall be presented.
78. Table 6-5
These are not adequate reasons for exclusion: No toxicity
data, essential nutrient. Better substantiation shall be
provided.
79. This table clearly shows that Area 2 was under sampled. Text
shall state that Remedial Deisgn work will include soil
sampling to adequately identify and define source areas.
80. Table 6-10
Provide information substantiating 30 subsurface soil samples.
Differentiate between the screening and the actual fixed lab
samples.
81. Section 6.2.1. page 6-3
Clearly identify and substantiate why the background samples
are appropriate, especially for ecological sampling.
82. Section 6.2.1.1
This language contradicts Tables in Section 6.
83. Section 6.2.1.2
How many samples were analyzed for what analytes? Provide a
table or narrative discussion.
84. Section 6.2.2
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Where is screening data? Groundwater? Temporary wells used
in Phase I?
85. Section 6.2.3
Define depth of surface soil. Report shall include a cross
sectional for reference to how deep the contamination exists.
86. Page 6-7 Text and tables appear to assume that a child is
equivalent to an adult. Report shall be corrected.
87. Future Land Use Provide the assumptions of people,
weight/rate of ingestion, etc.
88. Table 6-13 Affects of a child do not equal the effects of an
adult.. Children are evaluated as if effects are potentially
much greater due to development rates, weights, etc.
89. Section 6.3.4.2, page 6-13. second paragraph
Specify which model.
90. The Summers Model, as referenced in Section 6.3.4.2, page 6-13
and 6-14 is not entirely correct. The volumetric flow rate
calculation involves the estimation of the mixing zone
thickness (H) when calculating ground water flow available for
dilution (Q.). Instead of an estimation of a mixing zone
thickness below the contaminated soil, the entire aquifer
thickness is being used here, increasing the dilution rate and
effectively being less protective of ground water. We suggest
an estimation of the mixing zone thickness based on equation
5.49 of the EPA MULTIMED model:
H = ( 2*cx.*L) 112 + B* ( 1-e-[<L • Qfl/cva•e••>J)
Where: ex. = vertical dispersivity of soil (L)
L = dimension of facility parallel to flow
direction ( L)
B = thickness of saturated zone ( L)
Q, = percolation rate (L/T)
v. = seepage velocity (L/T)
9 = effective porosity (dimensionless) .
91. Page 6-15, last sentence, second paragraph
This sentence does not make sense. Please reword.
92. Section 6.4.2
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Cite the studies that are referenced in the text.
93. · Section 6.8.1
Identification of risk range isn't done correctly or is very
misleading at·least. Don't lump in the outside of risk range
with unacceptable risks.
94. Tables 6-5, 6-9. and 6-11. Chemicals should not be eliminated
from the list of chemicals of potential concern on the basis
that there are no toxicity values available. These chemicals
should be retained as chemicals of potential concern and
qualitatively discussed in the toxicity assessment.
95. Sections 6.2.1.1 and 6.2.1.2, pg. 6-3. The text states that
acetone, methylene chloride, and toluene were not considered
chemicals of potential concern because they were detected at
similar concentrations in the blanks. In accordance with
RAGS, these chemicals should be deleted from Tables 6-1 and 6-
2 since they were not detected at concentrations which are
significantly higher than in blank samples.
96. Section 6.3.2. pgs. 6-6 and 6-7. Current Land Use. When a
trespassing scenario (or in this case, a scenario where a
child plays on or near the . site) is evaluated in the BRA,
Region IV uses default values of a 7 to 16 year old child with
a body weight of 45 kilograms (kg). These exposure parameters
should be incorporated into the BRA.
97. Section 6.3.4.2, pg. 6-11. Interim Region IV (as of February
11, 1992) states that the following absorption factors (ABS)
should be used in determining the risks associated with dermal
exposure to contaminated soils: 1.0% for organics and 0.1%
for inorganics. In addition, although the soil to skin
adherence factors (AF) given in RAGS are 1.45 mg/cm2 to 2.77
mg/cm2• new data in this area indicate that this range should
be changed to 0.2 to 1.0 mg/cm2 • These new ABS and AF values
should be incorporated into the BRA.
98. Table 6-16. As previously discussed, the age of the child
should be changed to 7 to 16 years and the body weight should
be increased to 45 kg (otherwise the ingestion rate of 100
mg/day would need to be increased to account for the two-year
overlap, ages five and six, at the higher IR of 200 mg/day for
children 1-6 years old).
99. As discussed in Comment_, the ABS and AF values should be
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changed in accordance with Region IV guidance.
100. Page 8 of Table 6-16
The average exposed surface area (SA) for an adult is listed
as 5,300 cm2 /event. · This SA value is based on the average
surface area of the arms, hands, legs, and feet of a person
aged 0-30 years. On the other hand, a SA value of 6,500
cm2 /event ( same exposed surface areas) was used for a 5-12
year old child.. If .the same exposed surface areas (i.e.,
arms, hands, legs, and feet) are going to be evaluated for the
adult and the child, the SA term for the adult must be higher
than the SA term for the child.
101. · Page 9
The age of the resident being exposed via ingestion. of
contaminated groundwater should be changed to 0-30 years.
The SA term of 18,200 cm' shown on page 10 appears to be based
on exposure of the entire adult body not just the arms, hands,
legs, and feet. The reference for the this SA term should
reflect this fact.
102. Table 6-18.
The table lists IRIS (1992) and the WERL Treatability Database
as the sources of the toxicity values listed in the table.
IRIS (1993) should be the primary source of toxicity values
and the Health Effects Assessment Summary Tables should be the
secondary source of toxicity values. The inhalation slope
factor for 1,1-dichloroethene is 1.75E-01 (mg/kg-day)-1 • The
provisional inhalation slope factor for trichloroethene
(obtained from the Superfund Technical Support Center) is 6E-3
(mg/kg-day)-1 • The oral slope factor for bromodichloromethane
is 6.2E-2 (mg/kg-day)-1 • The source of the slope factors for
styrene should be identified.
103. Table 6-19.
The RfC values for 1,2-dichloropropane and styrene should be
changed to lE-3 and 2E-1 mg/kg-day, respectively. The oral
RfDs for manganese and zinc should also be changed. Manganese
has an RfD of 5E-03 mg/kg-day for water and 1.4E-1 mg/kg-day
for food (soil) . Zinc has an RfD of 3E-1 mg/kg-day. A
provisional RfD of 6E-3 mg/kg-day has been established for
trichloroethene (obtained from the Superfund Technical Support
Center).
104. Section 6.5.
The reviewer could not duplicate several of the incremental
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lifetime cancer risks and hazard quotients shown in this
section. In order to expedite verification of the cancer
risks and hazard indices, the chemical intakes (both
noncarcinogenic and carcinogenic) for each exposure scenario
should be presented on Table 6-16. Also, cancer risks and
hazard indices should be expressed using one significant
figure only.
105. The BRA sums the risks and hazard indices from exposure to
each pathway within a given medium (i.e., groundwater);
however, it does not calculate the total risk from exposure to
the different media. If an individual may potentially be
exposed to contaminants via several pathways and media, a
total risk for each exposure pathway (and medium) contributing
to that individual's exposure should be calculated. A
lifetime cancer risk should also be calculated by summing the
child and adult resident carcinogenic risks. ·
106. Sec. 6.6, p. 6-19
With respect to the chronic toxicity testing, explain what is
meant by "clarify the source for ecological impairments noted
during the ecological investigation". It might help to check
my memorandum of March 25, 1993 (mentioned above) concerning
the basis for EPA's request for conducting toxicity tests.
107. Sec. 6.6.1, pp. 6-21 to 6-22
In the first full paragraph on page 6-21, clarify that the
given concentrations are from sampling events prior to Phase
I.
108. Many of the subsequent paragraphs are redundant. Therefore,
the following reorganization is recommended: Combine the
first sentence of the second paragraph with the first three
sentences of the third paragraph. The resulting paragraph
would thus focus on results of the ecological investigation.
The remaining sentences of the second paragraph should be
combine with the last sentence of the third paragraph, the
entire fourth paragraph, and the first entire paragraph on
page 6-22. This last combined paragraph would focus on
factors (both 1,2-DCA and naturally-occurring) that could be
causing impairment of the macrobenthic community.
109. It is recommended that last two sentences of the first full
paragraph on page 6-22 be reworded as follows: This
ecological impact was found in areas of the Northeast
Tributary exhibiting elevated levels of 1,2-DCA (1,2-
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dichloroethane). However, it could not be concluded that 1,2-
DCA was the sole cause of this impact, in view of the
naturally-limiting factors associated with the headwater-
stream nature of this tributary.
110. Sec. 6.6.2, p. 6-22
While the first paragraph is good, it should include the
rationale behind EPA' s request for the toxicity tests, as
given in my memorandum of March 25, 1993 (mentioned above).
This summary section, as well as Appendix F, should also
address the comments contained in that memo. (This draft RI
Report from March 18 predates the memorandum.)
111. Sec. 6.6.2, p. 6-23
Discuss the toxicity test results in relation to the surface
water and sediment sample concentrations found during Phase II
(Table 4-2). While the sediment concentration of 1,2-DCA at
Station 13 increased from Phase I to Phase II (i.e., from 290
ug/kg to 1200 ug/kg), the surface water concentration of 1,2-
DCA at Station 13 decreased during the same period (i.e., 3200
ug/1 to 200J ug/1). The Phase II surface water concentration
is below the chronic screening value of 2,000 ug/1 used by the
USEPA Region IV Waste Management Division; thus, no toxic
effects would be expected at the Phase II surface water
concentration. Therefore, in extrapolating from the
laboratory test results to effects in the field, the last
paragraph on page 6-23 must indicate that the toxicity test
results for surface water are inconclusive with respect to
effects of 1, 2-DCA on field populations at concentrations
comparable to historic levels. The Phase II 1,2-DCA surface
water concentration had decreased to a level that was shown to
have no adverse effect on the aquatic biota, but this does not
indicate that surface water concentrations of 1,2-DCA
exceeding the screening value ( such as those found in Phase I)
pose no threat to the aquatic biota.
112. With respect· to the sediment toxicity test results, the
extrapolation from laboratory testing to field effects is
appropriate if it is shown that aeration of the test chamber
has little effect on concentrations of volatile organic
compounds (i.e., 1,2-DCA) in the test medium. (See
previous EPA comments.)
113. Sec. 6.6.3, p. 6-24
Again, the USEPA Region IV 1,2-DCA screening value of 2,000
ug/1, and the basis for this number (i.e., only one species
•
National Starch & Chemical Company NPL Site
Salisbury, North Carolina
Remedial Investigation -Operable Unit 1
EPA Review Comments
Page 16
•
tested for determining the AWQC value; a factor of 10 used to
allow for effects on more sensitive species) must be included
in this section. (Again, see my March 25, 1993 memorandum.)
(The screening value is mentioned farther down in this
section, under Potential Groundwater Effects.)
114. Table 6-26
The Region IV Chronic Screening Value for 1,2-Dichloroethane,
shown as "NA" in this table, must be changed to 2,000 ug/1 (as
mentioned in Section 6.6.3, page 6-25).
115. Also, the North Carolina surface water quality standards
should be obtained (through the North Carolina Department of
Environment, Health,-and Natural Resources, Raleigh, NC) and
included in this table.
116. Sec. 6.6.3, p. 6-25
It is recommended that the subsection under Water Quality
Standards titled Potential Groundwater Effects be made a
separate section.
117. The use of Daphnia magna to represent a sensitive aquatic
receptor is acceptable, as long as any available toxicity test
results showing adverse effects on other organisms at lower
concentrations are also included. (For example, paragraphs on
pages 6-25 and 6-26 do include other species.)
118. The surface water screening value for 1,2-DCA is the
concentration at which chronic effects on the more sensitive
species might be expected. Therefore, although a 1,2-DCA
concentration of 99,000 ug/1 (maximum ground water
concentration) might pose a high risk to the aquatic biota if
discharged to the tributary, concentrations closer to the
screening value might be expected to pose a more limited risk.
Therefore, the last sentence of the first paragraph on this
page should be modified.
119. Since this section includes literature information on the
effects of other contaminants, it is recommended that Section
6.6.4, page 6-27 to 6-28 (on effects of 1,2-DCA) be
incorporated in this section, rather than included as a
separate section.
120. Sec. 6.6.4, p. 6-27
As mentioned previously (e.g., my attached memorandum of
October 5, 1992, on the Draft Remedial Investigation Report -
•
National Starch & Chemical Company NPL Site
Salisbury, North Carolina
Remedial Investigation -Operable Unit 1
EPA Review Comments
Page 17
•
Operable Unit 3), other information available in the
literature has shown that toxic effects on salamander and
leopard frog embryos can occur at 1,2-DCA concentrations at
the same order of magnitude as those historically found in the
Northeast Tributary. Include this information in this
section.
121. Sec. 6.6.5. p. 6-28
The conclusions given in this section must be changed, based
upon the comments given above (e.g., 1,2-DCA has been found in
the Northeast Tributary surface water at concentrations that
pose a possible chronic risk to sensitive ecological
receptors; ground water concentrations of 1,2-DCA and other
contaminants pose a potential risk to aquatic ecological
receptors if they are discharged into the tributary).
122. Sec. 6.7. p. 6-28
Add any uncertainties associated with the ecological risk
assessment.
123. Sec. 6.8.2. pp. 6 30 to 6-31
Modify the first paragraph, based upon the comments given
above.
124. General Comment. The BRA should contain a remedial goal
options (RGO) section. The RGO section should contain an
appropriate narrative and a table with media clean-up levels
for chemicals that contribute to pathways that exceed a lE-4
risk or hazard index of 1. Individual chemicals contributing
risk to these pathways need not have RGOs developed if their
contribution is less than lE-6 risk for carcinogens or yield
a hazard quotient less than O. 1 for noncarcinogens. The table
should show the E-4,-5,-6 risk levels and the hazard quotient
0.1, 1.0, and 10 levels for each applicable chemical in each
medium and each scenario evaluated in the BRA, as well as any
ARAR values (state and federal).
125. Sec. 7.1.1, p. 7 1
Modify the third paragraph, based upon the comments given
above.
126. Sec. 7.4.1.2, p. 7-4
Modify this section, based upon the comments given above.
12 7. Sec. 7. 2, p. 7 6
Modify the last sentence, based upon the comments given above.
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James ll. Hunt, Jr., Governor Division of Solid Waste Management
Telephone [phone]
Ms. Barbara Benoy
Remedial Project Manager
U.S. EPA Region IV
Atlanta, GA 30365
April 7, 1993
Jonathan B. Howes, Secretary
Subj: Comments on Draft Remedial Investigation for Operable Unit 3
National Starch and Chemical Company NPL Site
Salisbriry, Rowan County, NC
Dear Ms. Benoy:
As per your letter of 22 March_1993 requesting comment, the NC
superfund Section is pleased to offer the following comments on the
March 1993 Draft of the Remedial Investigation (RI) for Operable
Unit 3 (OU3).
1. Page 1-2, Section 1.1.2. This section presents data
concerning plant operations, waste generation, and waste
handling in a general manner. Because it is now apparent that
current (or very recent) waste handling practices are the
source of groundwater contamination for OU3, the State would
like a more detailed discussion of the waste handling
practices including, but not limited to, information on the
use and fate of 1,2-Dichloroethane (1,2-DCA) in the process,
the quantities of waste generated, the concentrations of 1,2-
DCA in the waste and the frequency with which it is sent from
the reactor rooms to the treatment lagoons. This information
is imperative given the fact that waste handling practices
seemed to have changed as of 15 February 1993, when stainless
wastewater lines were completed. Current and prior waste
handling practices should be defined in detail for the record
and so that the State as a regulatory agency has a clearer
conceptual picture of the source.
As an editorial comment, the 2 Reactor Room, the Tank Room,
the Raw Material Bulk Storage, and the Warehouse are not
identified on Figure 1-3 as stated at the bottom of Page 1-2.
P.O. flux 27687, Raleigh, North Carolina 27611-7687 ·1t:lcphont.: 9!9-7:E--;9S4 F;ix /: '.W/./33-0513
~\n Equ.11 Oppommity Aifirn1:11iw: . .'\::1io11 Empkr.-:.."f
• •
Ms. Benoy
4-7-93
Page 2
2. Page 1-3, section 1.1.2. The RI provides a list of chemicals
that may have been handled through the unlined lagoons. Is
this list complete? How does it compare to the groundwater
contaminants found in either OU3 or OUl?
3.
4 •
5.
6.
The RI also states that saturated soil beneath the lagoons was
landfarmed and used as fill for the parking lot expansion.
More information on this should be provided. Are there before
and after lab analyses for _the landfarmed soils?
The RI states that among the
_one· sample-included. 1,2-DCA. I
in error as this_ is the most
Page 4-5, Section 4. 3. 3 .1.
compounds reported in . only
believe this statement is
~idespread site contaminant.
Page 4-6, paragraph 4. The RI states that there are two
distinct plumes and says that the Area 2·plume "may comprise
two coalesced plumes". I think this refers to the fact that
groundwater samples could not be obtained beneath the most
contaminated soil at the northwest corner of the reactor
building and that there is speculation that the area 2 plume
has two sources: one at the northwest corner of the reactor
building and the other near the loading dock. This needs to
be discussed in greater detail here, not just in the
conclusions section.
Page 4-6, paragraph 5. This paragraph is the only mention of
deep well results. The deep results are extremely important.
Indeed it is true that the bedrock aquifer is contaminated,
and the vertical extent of the plume has not yet been
established. A figure such as that for shallow results
(Figure 4-2) should be presented for the bedrock aquifer. As
the report states the results for .some of the deep wells (NS-
37, NS-38, NS-43, and NS-44) are not back from the laboratory
yet; however, the results for wells NS-33 and NS-34 are
apparently back from the lab but have not been reported in. the
text. 'I'he state feeis that the bedrock aquifer will need
further investigation although we agree it should not delay
the current deliverable schedule.
Figure 4-2. The plume map represents the data as gathered,
but the data is incomplete. It seems to indicate isopleths
that surround sampling Point 7A. This is simply not an
accurate portrayal of the suspected groundwater plume. There
simply is no groundwater data from the area near the northwest
of the reactor building. Based on the results of the soil
sampling near SBA2-20 there is a significant source that is
not reflected by this plume map. The text should explain this
fact, and the figure should be modified to reflect data
incompleteness in the area northwest of the reactor building.
Ms. Benoy
4-7-93
Page_3
• •
7. Figure 4-3. This figure does not reflect the complete soil
contamination picture and should be supplemented by additional
information and figures. The figure presents the depth where
the maximum contamination was found but ignores important
information about the extent of soil contamination. For
example, at SBA2-04 the table reports that the maximum
contamination level of 15,700 ppb is found at 1. 5 feet.
However, the.boring logs in Appendix D indicate that at SBA2-
04 soil is similarly contaminated down to 18 feet. This is
important information. Using the boring logs from Appendix D,
the OVA readings support the fact that many of the soils are
probably contaminated at depth near the water table. At the
very least, a figure should be added that shows all of the
analytical results and the depths at which they were found,
not just the highest result per sampling location. There
should also be some kind of notation at each sampling point
whether the OVA indicates soil is contaminated at depth. The
borehole logs for SBA2-20 itself shows the unsaturated zone is
contaminated right down to the aquifer. This supports the
notion that a pipeline leak near this location has
contaminated the aquifer. This type of support for the
pipeline hypothesis should be presented in the main body of
the RI report.
8. Figure 4-3. Spot comparisons of data reported on Table 4-3
with data sheets presented in Appendices G and H leads me to
seriously doubt the accuracy of Table 4-3. Some of the
apparent errors we found are shown in the table below:
Sampling Point
SBA2-20
SBA2-07
SBA2-04
SBA2-0l
Table 4-3
Reported Value
150,000
ND
15,700
8,700
"True" Value From
Appendices G and H
1,600,000
740
17,000
34,000
Of the errors above, note that the error for SBA2-07 is
particularly significant as it had been reported on Table 4-3
as a "ND" where the lab data show it as 740 ug/Kg. This
sampling site was at the periphery of Area 2. Thus, looking
at the table leads one to believe that the lateral extent of.
soil contamination has been determined, when it actually has
not. Please note that in the interest of a timely response,
the state has not compared all of the reported results with
the lab data so there may be additional errors on Figure 4-3
or other figures. The state recommends that all of these
figures and tables be thoroughly reviewed for accuracy before
making any decisions on the site.
• •
General Comments
1. Page numbers should be provided for all tables and figures and numbered
consecutively within the document.
2. Figures should depict all features referenced in the text (i.e., Airport Rd., railroad
spur, Area 2, etc.). Symbols for sample locations should not be so large that they
merge together into an indistinguishable mass. All symbols should be included in the
legend (i.e., dotted lines which depict curbing, speckled boxes which depict buildings,
isocontour lines, etc.) The scale of figures should be small enough to allow easy
interpretation and·should be the same for figures used to depict similar information
in the same area (i.e., soil results and groundwater results). Figures introduced in
introductory sections which show sample locations should be reintroduced with a new
number when they are referenced again to show results.
3. The data presented in the tables and figures has numerous errors (when compared
against the summary tables in Appendix H) and should be carefully checked against
the validated data sheets. This also applies to the data used in the risk assessment
which was not reviewed. Nondetects should be represented by the sample
quantitation limit, not "u" or "ND".
4. The measure of significance used in Region IV is 2 times the average background
level, not an order of magnitude. Discussions which refer to this should be adjusted
accordingly.
5. It is difficult to verify that previous EPA comments have been incorporated without
specifics regarding the page number, paragraph, etc., where the change was made.
Provide this information for these and previous comments.
6. When discussing results, refer to the appropriate sample codes, table, and/or figure
in the text. ·
7. According to the scope of work for the OU3 Phase II RI, primary objectives were to
identify the sources of groundwater contamination and to determine if soils are or
have been impacted by leaking wastewater pipes. The document is unconvincing in
its presentation of the sources of contamination, especially in its attempt to attribute
contamination to leaking pipes.
8. A QA/QC section should be included. This section should discuss controlling
documents used to guide the field effort, adherence to (and deviations from)
controlling documents, achievement of data quality objectives, data validation process ·
and results, field quality control results, comparison of on-site laboratory and
confirmation laboratory results, data evaluation discussion, and summary of any audit
findings.
1
• •
9. The Introduction Section ( 1.0) does not include information on climate, demography
and land use. It may be beneficial to include this information or reference previous
reports or other sections if it is available elsewhere.
10. An Executive Summary at the beginning of the report would be useful.
Specific Comments
1. Page 1-1. third paragraph. A figure is needed showing the locations of site features
referred to in Sect. 1.1.1 (i.e., lagoons, Area 2, roads, Northeast Tributary, W.A.
Brown· Plant NPDES discharge point, Southmark Industrial Park, etc.)
2. Page 1-2. first paragraph. Provide a figure with land use referred to (i.e., industrial
parks, mobile home park, other residential areas.)
3. Page 1-2. fourth and fifth paragraphs. Clarify the disposition of the waste streams.
4.
Since these paragraphs use both present and past tenses, it is difficult to determine
which practices were conducted and which still are.
Page 1-3. Fig. 1-3. Figure 1-3 is of poor quality; features referred to are not
discemable.
5. Page 1-5. Table 1-1. Use of the footnote "NS" for "not sampled" in Table 1-1 is
confusing because it is also part of the sample code descriptions. Appendix C
includes several results for each of the "50" series samples. Table 1-1 should specify
which are reported, or report them all.
6. Page 1-5, second paragraph. Figures of small enough scale are needed to follow the
discussion in Sect. 1-2. Figure 1-3 is unacceptable. Show asphalt area, catch basins,
dikes, surface water discharge lines, etc.
7. Page 1-6. last paragraph. Surface water and sediment were collected from seven,
not six, locations.
8. Page 1-7. first paragraph. Appendix Fis the Ecological Assessment, not the data
evaluation as stated. Sample S0-07C was nondetect per Table 1-1, not 1,200 ppb as
stated. According to Table 5, included in Appendix C, the 1,200 ppb is the analytical
result of the duplicate of S0-07C (3-3.5 feet). The SQ-07C (3-3.5 feet) sample result
is 1,700 ppb.
9. Page 1-7. second paragraph. No PRE was found in Appendix B. A Baseline Risk
Assessment is in Appendix C.
2
• •
10. Page 1-8, first paragraph. No PRE was found in Appendix B. A Baseline Risk
Assessment is in Appendix C.
11. Page 1-8, second paragraph. There are several inconsistencies in the interoffice
memorandum cited which may affect the conclusions drawn. For example, the
calculations cited in the Quattro tables are different from those presented in
summary Table 8 (i.e., the.ILCR for inhalation of 1,2-DCA is 3.89E-6 not 9.0E-7
reported in Table 8; the ILCR for ingestion of 1,2-DCA in water is 2.61E-6 not 1.3E-
6 reported in Table 8). Other inaccuracies exist but are less significant. The total
ILCR should be 6.0E-6 not the 2.2E-6 reported. It could be argued that a three fold
difference is significant.
12. Page 2-2, first paragraph. Capitalize the "I" in Rls. Insert "contamination" after soil.
13. Page 2-2, Fig. 2-1. A symbol for surface water and sediment is located between
TWP-5 and TWP-6 although no samples were collected at this location.
14. Page 2-2. Table 2-1. Identify the meaning of"-" in the Table. This can be done in
a footnote.
15. Page 2-2, second paragraph. Insufficient detail is proviclecl on surface water and
sediment sampling procedures to determine if they were conducted as specified in
the work plan. Provide details comparable to those provided for groundwater sample
collection in Sect. 2.1.2.
16. Page 2-2. last paragraph. Mention the parameters the groundwater was analyzed
for in this section.
17. Page 2-3, fourth paragraph. Justify the use of a peristaltic pump for sample
collection instead of a bailer as specified in the work plan. The sampling discussion
is a little confusing. Diel groundwater samples come in contact with the silicon
tubing? Should the teflon tubing have received a field decontamination prior to
sampling? Discuss the usability of VOC results obtained from wells which were slow
(24-hr or 1 week, it is not clear) to recharge. AJso discuss the results of the samples
collected through the use of a peristaltic pump. Provide a table with field
measurements for groundwater similar to Table 2-1 produced for surface water.
18. Page 2-4. second paragraph. A cross section was not found in Appendix C as stated.
19. Page 2-5, second paragraph. The Ecological Assessment is in Appendix E, not B,
as stated. Explain how the results of the groundwater screening influenced the soil
sampling locations as specified in the work plan.
3
• • •
20. Page 2-5. fifth paragraph. The final step of the equipment decontamination
procedure described here does not agree with the procedure given in the work plan. Indicate if the final deionized rinse was considered an organic-free water rinse as
stated in the work plan.
21. Page 2-8, last paragraph. The work plan specifies that surface water samples for
toxicity testing would be collected in a beaker then transferred to sample bottles.
Actual collection was directly into pre-preserved containers. Discuss how the
possible loss of preservative while collecting the sample may have affected the results
of the bioassay. Provide a table with the results of the field measurements referred
to in this paragraph.
22. Page 2-9. third paragraph. Reference the appropriate appendix if the boring logs
mentioned here are included.
23. Page 2-10. Table 2-2. Explain why the screen length for NS-38 is footnoted as not
applicable.
24. Page 2-10, fifth paragraph. Was the protective pad installed immediately after
grouting?
25. Page 3-1. second paragraph. Clarify the distance to Grants Creek. Two miles is
cited here while p. 1-1 reports the distance as 6,000 ft.
26. Page 3-1. third paragraph. SW /SE 11 is not shown in Fig. 2-2.
27. Page 3-1. last paragraph. Wellpoint locations described in this paragraph are shown in Fig. 2-1, not Fig. 2-2 as stated.
28. Page 3-4. last paragraph. Transport rates of 0.08 to 0.2 ft/day translate to 29 to 73
ft/yr not 27 to 80 ft/yr as stated.
29. Page 4-2, Section 4.2 -Data Validation. Additional explanation is needed here. A
validation effort independent of the laboratory's effort is required for CLP data.
This section should indicate who conducted the validation, and if EPA functional
guidelines were followed. A brief summary of validation results would also be beneficial.
In addition, validation efforts and results for on-site laboratory data and non-CLP · data should be included in this section.
A subsection covering data evaluation -specifically field QC samples should be
added to Section 4.0, or covered in a QA/QC section.
4
• •
30. Page 4-2, fourth paragranl!, Accorcling to Appenclix I-I, acetone was also cletected
in backgrouncl sample SW-12A at 20 ug/L on June 12, 1992. This conflicts with
Table 4-2.
31. Page 4-3. first paragraph. Surface water and sediment locations are in Fig. 2-1 not
2-2.
32. Page 4-3, second paragraph. According to Appendix H, methylene chloride in SW-
13 at 2 ug/L and carbon disulfide in SW-16 at 1 ug/L were also detected in surface
water, contrary to the second sentence of this paragraph. Acetone was detected at
20 ug/L in background sample SW-12A on June 12, 1992 contrary to the statement
. regarding voes in this paragraph.
33. Page 4-3, Table 4-2~ There are several errors in Table 4-2. According to Appendix
H, acetone was detected in SW-12A at 20 ug/L not ND; 1,2-DeA was detected in
SW-13 at 2,SOOE not 3,200D and in SW-14 at ?JOE not 5900; and methylene
chloride was detected in SE-11 at 8 ug/kg, and SE-14 at 7J ug/kg. ·
34. Page 4-3, Fig. 4-1. Sample codes should accompany the results in this figure. A
similar figure should be provided for sediment results.
35. Page 4-4, paragnrnh 1. Results of the inorganic analyses of surface water and
sediment should be presented in a table.
36. Page 4-4, Table 4-3. There are several errors in Table 4-3. According to Appendix
H, toluene was detected in TWP-3 and TWP-11 at 1 ug/L; TeE was detected in
TWP-13 at 1 ug/L; methylene chloride was detected in TWP-3 at 47 ug/L; acetone
was detected in TWP-5 at 430 not 439 ug/L, in NS-13 at 9 ug/L and in TWP-8-FD
at 240 ug/L; chloroethane was detected in TWP-9 at 5 ug/L.
37. Page 4-4, last paragraph. A discussion of how well the screening and confirmation
results compare should be included or referenced here.
38. Page 4-6, Table 4-5. 1,2-DeA is misspelled ("ene" instead of "ane") in page 1 of 4.
Location GW-14 appears twice.
39. Page 4-6, Table 4-6. There are several errors in Table 4-6. According to Appendix
H, delta BHe, detected in NS-42 at 0.16 ug/L, is not listed; bromodichloromethane
reported in NS-42 should be nondetect ( 400UJ); chloroform detected in NS-36, NS-
39, and NS-40 should be nondetects (SU, 15U and 6U); and TeE was detected in
NS-36 at 1 ug/L. The title is inaccurate since more than just voes are reported.
Locations NS-37, -38, -43, and -44 are tabulated (implying nondetects) although the
validated results have not been received as yet. The results for NS-41 could not be
located in Appendix H.
s
. .
• • •
40. Page 4-6, Figure 4-2. See General Comment Nos. 2 and 3. Also, include sample
codes next to the results to make the discussion easier to follow. Enlarge figure if
possible (use a foldout page).
41. Page 4-6, first and second paragraphs .. See General Comment No. 2. Also,
reference is made to sample locations and other features (i.e., railroad spur, Area 2)
in Fig. 4-2; however, these features are not included in the figure. Since
contamination was detected in GW-8 and GW-19 (the most down gradient wells) at
3 and 4 ug/L (the results for GW-19 are reported incorrectly in Fig. 4-2), the last
sentence regarding extent of contamination is in error.
42. Page 4-6, last paragraph. See General Comment No. 6. Units should be used
consistently throughout the discussion rather than changing from ppm to ppb as was
done in this paragraph.
43. Page 4-7, first paragraph. Sample NS-35 had 72,000 ug/L 1,2-DCA, which is not
"close" to 10,000 ug/L as stated in the text. NS-35 had the higher concentration, not
NS-36 as stated.
44. Page 4-7. second paragraph. See General Comment No. 6. Also, what is the
relevance of ethylene dichlorides discussion, especially since neither 1, 1,1-TCA nor
1, 1-DCA were detected in any sample? Explain. Avoid use of the term "low" unless
it is properly qualified. It is true that concentrations of 1,1,2-TCA are low compared
to concentrations of 1,2-DCA; however, 1,1,2-TCA was present in NS-40 and NS-41
above its MCL of 5 ug/L.
45. Page 4-7. fourth paragraph. What is the significance of the fact that methylene
chloride and chloroform are impurities in and degradation products of carbon
tetrachloride, bromodichloromethane and chlorodibromomethane, especially since
neither carbon tetrachloride nor chlorodibromomethane were detected at the site?
Is bromodichloromethane the presumed source of methylene chloride and chloroform
contamination?
46. Page 4-7. last paragraph. Acetone was detected in sample GW-6RE at 120J ug/L
also.
47. Page 4-8, second paragraph. Delta-BHC is not an isomer of lindane; delta-BHC and
lindane are both isomers of BHC. This compound is not listed in any summary table.
48. Page 4-8, third paragraph. See General Comment No. 4. Also, several
inconsistencies were noted between the results reported in the text and those
reported in Table 4-7. See results for chromium, lead, nickel, mercury, and cyanide.
A discussion of the significance or lack thereof of the results is needed rather than
a simple recitation of the results from the table.
6
•
49.
•
Pages 4-9, first pat1ial paragraph.
Appendix B as stated.
•
Summary tables are in Appendix I-I, not
50. Page 4-9. second paragraph. FID is flame not field ionization detector.
51. Page 4-9. Table 4-8. Several errors were noted in Table 4-8. See Appendix H for
results for locations SBLA-09-2-4, SBA2-05-20-22, SBA2-07-8-10, ·sBA2-06-18-19
(should be SBA2-06-20-22), and SBAZ-12-10-12.
52. Page 4-9, Table 4-9. Several errors were noted in Table 4-9. See results for
locations SBA2-06-20-22, SBA2-06-4-6, SBA-08-18-20, and SBA2-08-2-4.
53. Page 4-9, Figures 4-3 and 4-4. See General Comment No. 2. Also, sample codes
should accompany the results in both figures so that the results can be verified. At
least one error was noted in Fig. 4-4 where the results for SBLA-24 are reported as
ND whereas Table 4-9 indicates 1,2-DCA was found at 3J. Other errors may exist;
however, the results cannot be easily verified for the reasons stated. Figures 4-3 and
4-4 show the same scale; however, they are not as can be seen by overlaying one on
top of the other. It may be beneficial to take the data presented in Figure 4-3, and
present it in several figures, with a selected depth represented on each figure.
54. Page 4-10, second paragraph. Provide details on the attempts to collect groundwater
in locations with high concentrations of VOCs in the soil. Per the work plan, soil
sampling was to follow the groundwater screening program to characterize the soil
contamination profile and to locate the source of the soil contamination.
55. Page 4-10, last paragraph, last sentence. Change " ... 1,2-DCA was collected ... " to
"1,2-DCA was found ... ". The sentence is not supportable. Clarify how the
contamination detected in the soil is not contributing to 1,2-DCA contamination in
groundwater.
56. Page 4-11, Figure 4-5. See General Comment No. 2 and comments on Figs. 4-3 and
4-4 regarding sample codes, scale and symbols.
57. Page 4-11, first paragraph. The fourth sentence refers to DCA; presumable acetone
is intended. The units should be ppb not ppm. The highest concentration of acetone
is actually 4,000 ug/kg in SBA2-11-4-6. This result doesn't appear in Fig. 4-5.
58. Page 4-11, second paragraph. Reference to 2-butanone is in error. Per Appendix
H, the result for SBA2-08-18-20 should have been recorded as 1,2-DCA not 2-
butanone.
59. Page 4-11, fom1h paragraph. Delta-BI-IC is an isomer of BHC, not lindane.
7
60.
61.
• •
Page 4-1 I. fifth paragraph. See General Comment No. 4 regarding measure of
significance. The second sentence is superfluous as apparently all mineral
constituents are naturally occurring.
Page 4-12, second paragraph. Where is the discussion that the piping is apparently
the source of contamination in Area 2 as stated? Piping is not shown in Figs. 4-1,
4-2 or 4-3 which show the distribution of contaminants in groundwat-er and soil nor
is it discussed. The conclusion is not the place to introduce this concept.
The extent of groundwater contamination has not been adequately defined to the
north (where 1,2°DCA was detected in GW-8 and GW-19, the most down gradient
wells) or to the east where no wells exist east of GW-15 which had 15,000 ug/L.
Contrary to the conclusion drawn, the present lagoons could be contributing to
groundwater contamination given (1) the high concentrations (2,000 ug/L) of 1,2-
DCA detected in the lagoon water and (2) the porous nature of concrete which
serves as a liner.
The discussion ori sources of contamination should be expanded. This section should
present an evaluation of contaminant sources. Use the analytical results to delineate
source areas.
62. Page 5-2, first pai1ial paragraph. Biotransformation of what (presumably
chlorinated compounds) will result in water, carbon dioxide and hydrochloric acid?
63. Page 5-2, Table 5-1. The reported parameters, frequencies and ranges of
concentrations should be checked based on the errors noted in previous tables.
64. Page 5-6, third paragraph. Discuss the fact that several of the contaminants of
concern (including 1,2-DCA) are denser than water and will therefore sink in the
fractured bedrock aquifer beneath the site. What is the likely fate of such
compounds in this aquifer system?
65. Page 7-1, second paragraph. It is not clear how volatilization is the reason that 1,2-
DCA concentrations have decreased over time in a dynamic body of water sampled
over time. Samples SW /SE-09, the most down stream location, showed 1501 ug/L
in surface water and 91 ug/kg in sediment (Table 4-2). It is not clear what samples
were collected down stream of Airport Rd. to substantiate this claim.
66. Page 7-2, first paragraph. See previous comments regarding the nature and extent
of the contaminant plume. Discuss the reliability of this conclusion in fractured
bedrock with contaminants such as 1,2-DCA which are denser than water and
therefore sink.
67. Page 7-2, fom1h paragraph. This is the first mention of a third plume. Discuss in
8
,. . ' • •
the appropriate sections.
68. Page 7-2, fifth paragraph. This sentence is not clear. Please clarify.
69. Page 7-3. second paragraph. See comment #61 regarding piping.
70. Page 7-3, fifth paragraph. Discuss the fate and transport of dens-er than water
compounds in fractured bedrock aquifers (i.e. 1,2-DCA).
71. Page 7-6, 'Data Limitations and Recommendations' This discussion should be
expanded and incorporated into a QA/QC discussion section. See General
Comment #8.
9
• •
Stare of North Carolina
Department of Environmem, Health, and Natural Resources
512 North Sali,bwy Smee, • fbleigh, Nonh Carolina J76(J.;
James 8. hunt, Jr., Coverr.or Division of Solid \Vastc Managcmcn!
Ms. Barbara Benoy
Remedial Project Manager
U.S. EPA Region IV
Atlanta, GA 30365
Telephone [phone]
April 7, 1993
Jonathan B. Howes, Secreta,y
subj: Comments on Draft Remedial Investigation for Operable Unit 3 National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC
Dear Ms. Benoy:
As per your letter of 22 March 1993 requesting comment, the NC Superfund Section is pleased to offer the following comments on the March 1993 Draft of the Remedial Investigation (RI) for Operable Unit 3 (OU3). .
Page _1-2, Section 1.1.2. This section presents data .. concerning plant _operat_ions, waste generation, and waste handling, in a-general manner. Because. if is now apparent that · current ( or very· rece.nt) .· wa·ste . handling· 'practices are the source of groundwater. contamination for OU3, the State would like a .. more detailed discussion of the waste handling practices including, but not l{mited to, information on the use .and fate of 1,2-Dichloroethane (1,2-DCA) in the process, the quantities of waste generated, the concentrations.of 1,2-DCA in the waste and the frequency with which it is sent from the reactor rooms.to the treatment lagoons. This information is imperative given the fact that waste· handling practices· seemed to have changed as of 15 February 1993, when stainless wastewater lines were completed. current and prior waste handling practices should be defined in detail for the.record and so that the state as a: regulatory agency has a clearer conceptual picture of the source.
As an editorial comment, the 2 Reactor Room, the Tank Room'; the Raw Material Bulk Storage, and the Wareh·ouse ar.e not identified on Figure 1-3 as stated at the bottom of-··Page 1-2. P.O. Rox·276S7, Raleigh, North Carolina 27611-7667 1Ck-phon<: 9!9-7.B-498-4 f=ax l 9!9-733-0513
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• '\ •
• • Ms. Benoy
4-7-93
Page 2
2. Page 1-3, Section 1.1.2. The RI provides a list of chemicals that may have been handled through the unlined lagoons. Is this list complete? How does it compare to the groundwater contaminants found in either OU3 or OUl?
3 •
The RI also states that saturated soil beneath the lagoons was landfarmed and used as fill for the parking lot expansion. More information on this should be provided. Are there before and after lab analyses for the landfarmed soils?
Page 4-5, Section 4.3.3.1. compounds reported in only believe this statement is widespread site contaminant.
The RI states that among the one sample included 1, 2-DCA. I in error as this is the most
4. Page 4-6, paragraph 4. The RI states that there are two distinct plumes and says that the Area 2 plume "may comprise two coalesced plumes". I think this refers to the fact that groundwater samples could not be obtained beneath the most contaminated soil at the northwest corner of the reactor building and that there is speculation that the area 2 plume has two sources: one at the northwest corner of the reactor building and the other near the loading dock. This needs to be discussed in greater detail here, not just in the conclusions section.
5 .. Page 4-6, paragraph'~. This paragraph is the only mention of deep well results .. The deep results are extremely important. Indeed it is •~rue that _the bedrock aqu,~:fer is ,cc;m1::aminated; and ·the vertical extent of the plume .has .not. yet ,been·. established. A figure such as that for ·shallow ,r.1=s.ufts (Figure 4-2) should be,presented for th,e becl.rock 'aquifer ... A's the report states the res_ults for ·sonie of the deep welJ,:s .(NS-37, NS-38, NS-43, and NS-44) are not back froni the:laboratory yet; however, the results for wells :.NS-33 and NS·,:34 are apparently back from· the lab but have .n,ot been repor:ted· -:in the text. The State feels that the . ,bedrock aquifer will .,rieed further investigation althou_gh .i-?e·. agree it sho,uld not ct·elay .the current. deliverable schedule. · ··· ··
6. Figure 4-2. The plume map_ represents the da;ta ,as. gathered, but the .. data is incc,mpl~te; I_t seems to , iridi_cate · isopleths that surround sall)pl.i11g · Point 7A. . This is simply not an accurate portrayal of t;he suspe,ct<fd groundwat,e.r plµme ·: . There simply: is. no' groundwater.,data from·. the area near the northwest of the reactor builcJ,iiig: _ _..,··Based. on ):he results ,of ·tlJ,e-soil sampling near SBA2720:1::here is a sighificant.,source.that is not reflected by· this plume map. The text should explain -this fact, and the figure should be modified :to reflect · data incompleteness in the area. northwest of the reactor building. . . . -.. ,. ,, ..
• •
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Ms. Benoy
4-7-93
Page 3
·, I
• •
7. Figure 4-3. This figure does not reflect the complete soil contamination picture and should be supplemented by additional information and figures. The figure presents the depth where the maximum contamination was found but ignores important information about the extent of soil contamination. For example, at SBA2-04 the table reports that the maximum contamination level of 15,700 ppb is found at 1.5 feet. However, the boring logs in Appendix D indicate that at SBA2-04 soil is similarly contaminated down to 18 feet. This is important information. Using the boring logs from Appendix D, the OVA readings support the fact that many of the soils are probably contaminated at depth near the water table. At the very least, a figure should be added that shows all of the analytical results and the depths at which they were found, not just the highest result per sampling location. There should also be some kind of notation at each sampling point whether the OVA indicates soil is contaminated at depth. The borehole logs for SBA2-20 itself shows the unsaturated zone is contaminated right down to the aquifer. This supports the notion that a pipeline leak near this location has contaminated the aquifer. This type of support for the pipeline hypothesis should be presented in the main body of the RI report.
8. Figure 4-3. Spot comparisons of data reported on Table 4-3 with data sheets presented in Appendices G and H leads me to seriqusly do.ubt ,the accuracy of Table 4-3. Some of the apparent_ errors w·~ found are shown in the table below:
sampling• Point
SBA2--,20
.SBA2-:-07
·, SBA2:c04
· SBA2.:.01
Table 4-3
Reported.Value
. 150 000 · ' I . ND
_15,700
?,700
"True" Value From Appendices G and H . ,l;,6~q,9.qq
,.::-_· :·:_'. 7 4 o,
_17,g(?o,
-34 ,oo·oo
.-Of. the. errors above, note that the er-ror for SBA2-,-of is .particular_1y.: significant 'as it had been reported _on. Tab:le 4;;.3 as a,l."ND'' ii,l1~ri{ the lab data· show it -as· 740 lig/Kg.'.,a .; T\lis .sampiing, .site. was at the peripl1¢ry of Area 2. Thus; lciOking ·at-,.the ,tabl'e" 'leads' one to believe that the lateral e:Xtent: of ·soil contamihati.ori' has been determined, when it act_tiaFl.y has not. -Please h'ote,:t1tat in the interest of a timely,,rei;p°"hse, the stat'e ha·s. not"compared all of the reported .restllts, with the iab_.,data so th~'i'~ may );,e additional• errors _ori Figtirk ·4-3 or. other.,·.:figures;·•_•--The Sta·te recommends.•that•·all·:'of<_.these fig1,1res and ta)?Jes' be thoroughly revieweq:'for accuracy :bef.ore ·making. any decisions on the site. -•.:: .' .. -c.:":,: ... ·.·'.:; •., :·:: .:•-· .. --~ .. ··.~ .. . ;',~: c-~-. . . . ,.
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• •
Ms. Benoy
4-7-93
Page 4
• •
9. Page 4-10 and Figure 4-4. The pattern of contamination seems to indicate the potential for a pipeline leak at the elbow nearest Lagoon 2. This is not accounted for in the report. Based on the data, is it likely that this pipeline is currently leaking?
10. Page 7-2, Section 7. L 2. 2. Along with the plume near the northeast tributary, the RI states that a "relatively small plume exists directly north of Area 2 and appears to be somewhat isolated from the plume along the tributary". This plume probably originates from the northwest corner of the reactor building, however there are no groundwater samples at this location. This requires further investigation and should be so stated in the report (see related Comment 6 above).
11. Page 7-6. The RI states that the data meet the objectives of establishing the lateral and vertical extent of soil and groundwater contamination. Although several important objectives were met with this RI, it did not establish the lateral and vertical extent of contamination. What is taking place in the bedrock aquifer? The RI does not report the complete results to answer this question. Also, in many cases, the soil results reported in Figure 4-3 do not appear to match the analytical data sheets. Without a thorough review of the accuracy of all the figures, the State is doubtful as to the lateral extent as well.
The NC Superfund Section appreciates this opportunity to provide these comments. The Draft RI has also been submitted to the NC Division of Environmental Management (DEM) for :r;(!!View. As I had indicated to you via telephone, the short period allowed for co:mment does, not · provide enough time for DEM to c6mpJ.ete its review. DEM will be forwarding comments to this offic:·e as s00n as possible, and I will likewise f6r"iiard them to you. If you have ariy questions concerning these comments please contact me at (919)' 7j3-2so1.
bin\let\nsri2ou3
cc: Jack Butler
Bruce Nicholson
Chemical Engineer
NC Superfund Section
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor
Di,ision of Solid Waste Management
Telephone [phone] Jonathan B. Howes, Secretary
MEMORANDUM
To:
From:
Through:
Subj:
March 26, 1993
Arthur Mouberry, Chief
Groundwater Section ·
Bruce Nicholson, Environme.ntal Engineer~
superfund Section
Jack Butler, PE, Head#
Special Projects Branch
National starch and Chemical Company NPL Site
Draft Remedial Investigation For Operable Unit No. 3
Salisbury, Rowan County
I have attached a copy of the Draft Remedial Investigation
Report for Operable Unit No. 3 at the National Starch and Chemical
Company NPL Site. Please distribute for DEM review and comment.
The U.S. EPA has requested state comments by April 7, 1992. The
DSWM intends to send comment by this date. However, I have already
informed EPA that this schedule is unrealistic for obtaining DEM
comment. Please let me know an approximate date that is reasonable
so that I can inform EPA of when to expect all State comments.
If you or any reviewers have questions, please contact me at
733-2801.
bin/mem/nscc3ri
PO Box 27687, Raleigh, North Carolina 27611-7687 Tdt:r,hone 919-733-4984 F.ix # 919-733-05!3
An Equal Opportunity Affirmative Action Employer
e e Hi:GtBYto
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY MAR 21 JlJ:;i.;J
REGION IV SUPERFIJNDSfertoN
345 COURTLAND STREET. NE
ATLANTA, GEORGIA 30365
MAR 2 2 1993
4WD-NSRB
Bruce Nicholson
North Carolina Division of Environment, Health, &
Natural Resources
401 Oberlin Road
Raleigh, North Carolina 27605
Re: National Starch & Chemical Company
Salisbury, North Carolina
Draft Remedial Investigation (RI) Report
Operable Unit 1
Dear Mr. Nicholson:
The Draft Remedial Investigation (RI) Report has been submitted to
you directly by IT Corporation in Knoxville, Tennessee. This
letter requests your review of the RI. Please review and submit
comments to me no later than April 7, 1993. The RI contains the
Base.line Risk Assessment as a section in the report. Please
contact me no later than April 2, 1993 if you are unable to make
this schedule. I can be reached at 404/347-7791. Thank you for
your attention to this document.
Barbara H. Benoy
Remedial Proj~ct Manager
North Superfund Remedial Branch
North Carolina.Remedial Section
Enclosure
Printed on Recycled Paper
•
• rn INTERNATIONAL TECHNOLOGY
CORPORATION
Ms. Barbara Benoy
Remedial Project Manager
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
•
March 18, 1993
Draft Remedial Investigation Report for
Operahle Unit Three
Dear Barbara:
National Starch and Chemical Company Site
Salishury. North Carolina 28144
REGtlVtU
MAR 2 G l::J~~
SUPERRINDSEatON
IT Project No. 408668.60
Enclosed are 3 bound and I unbound copies of the Draft RI report. Two copies will be sent to Bruce
Nicholson of NCDEHNR and I copy will be sent to Jim Cole of CDM Federal Programs.
• If you have any questions, please call me at [phone].
Sincerely,
IT CORPORATION
Michael N. Sturdevant. P. E.
Project Manager
MNS/vlh
Enclosures
cc: Hank Graulich, NSCC
Alex Samson, NSCC
Ray Paradowski, NSCC
Bruce Nicholson, NCDEHNR
Jim Cole, CDM Federal Programs
KN/KP·J/03-18·9'3
Regional Oflice
3 I 2 Directors Drive • Knoxville. Tennessee 3 7923 • 615-690-3211
lT Corporation 1s a wholly owned subsidiary of International Technology Corporation
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
4WD-NSRB ATLANTA. GEORGIA 30365
Alex Samson
National Starch & Chemical Company 10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site Salisbury, North Carolina Operable Unit 3
Dear Mr. Samson:
This letter provides EPA comments .from · a variety of sources generated during and after the review of draft Remedial Investigation (RI) Report which you submitted in August of 1992. Additional field work was required; a revised and comprehensive RI and Baseline Risk Assessment are due on March 15, 1993. This information is provided as an enclousre to ensure that the report meets EPA's requirements for completion of an RI. The enclosure includes:
o EPA's formal comments, October 1, 1992, on the draft RI -OU3 Report;
o October 7, 1992 EPA/NSCC Meeting Outline; o Superfund Supplemental Guidance to RAGS; o Supplemental Region IV Risk Assessment Guidance.
EPA also expects a thorough evaluation of the drain lines coming from the plant which NSCC/IT have identified as the probable source of contamination from the plant. The blue prints on these lines, of which an excerpt was shown to me by Ray Paradowski, must accompany the RI report.
Items which NSCC/IT have agreed to supply include risk-based soil cleanup standards, and accurate potentiometric maps with supporting documentation.
Please do not hesitate to contact me if you have any questions concerning this letter. I can be contacted at 404/347-7791 or fax number 404/347-1695.
Barbara H. Benoy
Remedial Project Manager
Waste Management Division
Enclosures
Printed on Recycled Paper
cc: C. Fehn, NCS
W. Smith, WD
•
R. Leahy, ORC
H. Graulich, NSCC
R. Paradowski, NSCC
B. Nicholson, NCDEHNR/ J.
M. Sturdevant, IT
Cole, CDM
NSCC.OUl,2.10592.ASAM
•
• • ,
UNITE;D STATES ENVIRONMENTAL PROTECTION AGEN~\EtlQ~~UJ)
REGION IV SEP 2 2 1992
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site
Salisbury, North Carolina
Remedial Investigation
Operable Unit 3 -Surface Water
Dear Mr. Samson:
SUPERfU~D~ION
The First Draft of the Remedial Investigation Ior the Northeast
Tributary has been conducted. The Remedial Investigation (RI)
Report does not fulfill the objectives of the Draft Work Plan for
the Third Operable Unit which was to determine the source, nature
and extent of contamination entering the Northeast Tributary. The
conclusion reached in Section 7. 2 of this RI is that "contamination
appears to be migrating to the Northeast Tributary via the
groundwater pathway." Therefore, additional work is necessary to
adequately and accurately define the source of contamination. A
work plan for additional field work is due to the Agency no later
than October 19, 1992. Please note that a Record of Decision for
this site is scheduled for early 1992; all field work and analysis
must be completed in a timely manner to ensure that this schedule
is not further delayed.
Please do not hesitate to contact me if you have any questions
concerning this letter. I can be contacted at 404/347-7791 or fax
number 404/347-1695.
Sincerely, / /
,,6a,1!tz1tx (J~y
Barbara H. Benoy U
Remedial Project Manager
Waste Management Division
cc: C. Fehn, NCS
R. Leahy, ORC
J. DuPont, WD
H. Graulich, NSCC
R. Paradowski, NSCC
M. Sturdevant, IT /
B. Nicholson, NCDEHNR
R. HarG!y, CDM
NSCC.91692.0UJADD Printed on Recycled Paper
• •
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
Ms. Barbara Benoy
Remedial Project Manager
U.S. EPA Region IV
Atlanta, GA 30365
September 8, 1992
Subj: Comments on Draft Remedial Investigation for Operable Unit 3 National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC
Dear Ms. Benoy:
William L. Meyer
Director
The Superfund Section is pleased to offer the following comments on the Draft Remedial Investigation (RI) for Operable Unit 3 (OU3).
Remedial Investigation Report:
1. Figure 2-1. We would like for the exact area of soil placement under the parking lot to be delineated on Figure 2-1. My impression from my previous site visit is that the soils were placed further north than the sampling locations PLS-1 and PLS-2. As a general comment, these subsurface soils may be a source (both PLS-1 and PLS-2 contained at least some 1,2-DCA). Therefore, these soils need further investigation. Samples should not only be taken "adjacent" to the parking lot, but "through" the parking lot as well. It would be worthwhile to sample the subsurface soils nearer to sampling point SW/SE-14 at the north end of the parking lot.
2. Page 4-3. The report states that "The process of Identifying chemicals of concern was not performed for the groundwater data because the Baseline Risk Assessment only addresses surface water and sediment data. Groundwater contamination was addressed in a baseline risk assessment under OU-1 RI." The report is correct that significant work was done for the OUl RI which applies to this RI. However, this is no reason to neglect identifying contaminants of concern (COC's) in the groundwater for OU3. It is important to compare the new data for OU3 with the old data for OUl. Is the newfound plume an extension of the same contaminant profile found at OUl, or are there new contaminants?
3. Page 4-4 through 4-5, Section 4.6. It is evident from the conclusions in this section that it is time to expand the investigation. Phase I has determined that groundwater is the source of contamination in the surface water. However, a phased approach to the RI for OU3 is no longer appropriate. A comprehensive approach should now be taken.
4. Page 4-5. I am confused as to the meaning of the "Areas of surface water runoff that discharge to the upper reaches of the tributary" as described in this paragraph.
Ms. Benoy
9-8-92
Page 2
• Ct
5. Page 6-17, Section 6.6.1.5. The RI States that "The physical
characteristics of the Northeast Tributary adjacent to the plant
operations limit the diversity and richness of this stretch of the creek.
In essence, no biological impairment attributable to poor water quality
was detected using this screening protocol." My question is whether any
protocol would ever be able to attribute biological impairment to poor
water quality, given the physical characteristics of the tributary?
6. Table 6-16. Should 2-butanone be deleted from this table. From the data
presented in Section 4, 2-butanone was not detected in surface water.
7. Page 7-1. In the first line "consistently" has been misspelled.
RI Supplement: Draft Identification and Screening of Technologies:
1. The docUrne~t outlines the possible remedial technologies, but much of the
discussion in this document is just a little premature. I don't think its
worth the time making revisions until the groundwater has been
investigated.
2. Page 5-13. Although rule changes may be forthcoming, re injection of
wastewaters, treated or untreated, is not permitted in North Carolina.
Aleo, note that the Table of Contents incorrectly states that this Section
begins on Page 5-11.
The Superfund Section appreciates the opportunity to provide these
comments. If you have any questions, please contact me at [phone].
BIN/let/nsriou3
cc: Jack Butler
Bruce Nicholson
Chemical Engineer
Superfund Section
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
Alex Samson
National Starch &' Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site
Salisbury, North Carolina
Operable Unit 3 -Surface Water
Dear Mr. Samson:
Wl:CfE~Wi~OJ
AUG O 4 1992
SilPERfolVDSECnoru
The CLP data packages for the split samples collected during the
Remedial Investigation for the time periods May 19 and May 28, 1992
should be submitted to the Agency no later than August 7, 1992.
This request has been made verbally to Mike Sturdevant and a copy
of this letter will be faxed to him.
Please also note that I have never received your correspondence
from July 17, 1992 resulting from our conversation concerning the
drilling delay. Mike Sturdevant has agreed to fax me a copy in the
interim, but I would appreciate an original copy for the site file.
Please do not hesitate
concerning this letter.
number 404/347-1695.
to contact me if you have any questions
I can be contacted at 404/347-7791 or fax
J;;~tJ /
Barbara H. Benoy ~~
Remedial Project Manager
Waste Management Division
cc: C. Fehn, NCS
R. Leahy, ORC
H. Graulich, NSCC
R. Paradowski, NSCC
M. Sturdevant, IT
B. Nicholson, NCDEHNR ,/
R. Hardy, CDM
NSOU3.73192.AS
Printed on Recycled Paper
• • •
June 3, 1992
To: National starch and Chemical Corp. NPL Site File
From: Bruce Nicholson, Chemical Engineer ~
Subj: Data for Third Operable Unit
For the Remedial Investigation of Operable Unit 3, temporary
well points were placed to investigate groundwater discharging to
creek contaminated with 1,2 dichloroethane (1,2-DCE). Recently
they were sampled and no 1,2-DCE was found. The data was
invalidated by EPA because a peristaltic pump had been used for
sampling, which is against EPA's voe sampling protocol. Barbara
Benoy faxed the second set of well point sampling data (attached)
to me today. The EPA ordered that a second set of samples be
taken. The second set of data (taken with the correct sampling
protocol) shows that TWP? had 430 ug/1 and 470 ug/1 in duplicate
samples, and that TWP6 had 4200 ug/1 and 4500 ug/1 acetone in
duplicate samples.
Barbara indicated that because of this result, National starch
will place 2 boreholes in the parking lot area to determine if it
is a source of the voe contamination. Because of the positive voe
results, I recommended to Barbara that semivolatiles be included in
analysis of the parking lot samples. She told me that EPA will be
on site to split samples with National Starch and that, even if
National Starch did not conduct semivolatile analysis, that EPA
will analyze its splits for semivolatiles.
BIN\mem\nsccou3
,
UNITED STATES ENVIBONI\fENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
AU . .ANTA, GEORGIA. 30365
FACSIMILE TRANSM.ITTAL COYER SHEET
Date: \p · ?1 • 9 !) Time: ....,\"-I·_., \_.~,__ ___ 1)0 a.m. D p.m.
To, 1?:>:rv.c~. N \ c ~10) Boo
Company/Organizarion: --------------------------
Phone Number: ___________ fax Number: q I q -r] 3 ()· L.\ 2i 11
Number of Pages Sent (Including T/.?fs Cove,· S/Jee1): -~S-:~---
P/ease contact Barbam Benoy if 1/Jis fax is receil!ed poorly or i11comple1e.
FROM: Barbara Benoy, Remedial Project Manager
North Carolina Section
North Superfund Remedial Branch
\X'aste Management Division
Phone Number: (iJ04) Yi7-7791
FTS: 257-7791
rax Number: [phone]
FTS: 257-1695
NOTES: ____________________________ _
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. ·~~-~·
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
Ms. Barbara Benoy
Remedial Project Manager
U.S. EPA Region IV
February 10, 1992
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: National Starch and Chemical Corporation NPL Site
William L. Meyer
Director
Comments on the Draft Work Plan for the Third Operable Unit
Dear Ms. Benoy:
As you know the NC Superfund Section supports the
investigation of Operable Unit No. 3, and we are pleased that
National Starch has drafted this Work Plan in a timely way. As
requested, the NC Superfund Section has reviewed the Work Plan and
offers the following comments:
1. Page 4-2, Section 4.3. The Work Plan states that one of the
reasons the soils in the parking lot area are not considered
to be the source is because they were not in place at the time
of the Remedial Investigation for Operable Units 1 and 2.
This is a very important point that is well taken. Because no
samples are planned for the parking lot area, we request some
additional clarification on this matter. Please provide a
more detailed and specific timeline for the critical events.
What were the creek sampling dates and results versus the
parking lot expansion approval and construction?
2. Page A-1. The Work Plan states that temporary well points
will be used to collect groundwater samples. The NC Superfund
Section supports this approach as a cost effective method of
gathering numerous groundwater samples. In Section Site
Investigations the Division of Environmental Management (DEM)
has requested that we notify them when well points are being
used. Therefore, the NC Superfund Section requests that
National Starch notify the Mooresville Regional Office of DEM
about the planned use of well points at the National Starch
Site.
An Equal Opportu~ity Affirrn.1rive Action Employer
Benoy Letter
2-10-92
Page 2
• •
If you have any questions concerning these comments, please
contact me at [phone].
BIN/let/nsou3wp
~Y,1{,tL_
Bruce Nicholson
Chemical Engineer
NC Superfund Section
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
OCT 2 8 1991 ATLANTA, GEORGIA 30365
4WD-NSRB
Lee Crosby
North Carolina Department of Environment, Health and
Natural Resource
401 Oberlin Road
Raleigh, North Carolina 27605
Re: National starch & chemical company
Salisbury, North Carolina
Operable Unit 3 -·NE Tributary
Dear Lee:
Recently, I spoke to Bruce Nicholson concerning the need to have
someone from the state join me in a site visit to the National Starch
& chemical company (NSCC) site. we are currently developing an
outline for the investigation of the NE tributary. State input at
this stage is critical. I would like to schedule a site visit for
mid-November. Please let me know something on this as soon as
possible so that I may coordinate with the PRPs. I look forward to
your response.
Do not hesitate to contact me at 404/347-7791 if you have-any
questions concerning this letter.
sincerely, / /l J7,, /w_,,c;i; 'Ji ~,,,,t;-c;r
/ Barb~;:v / Beno~ ' /;
Remedial Project Manager v
North Superfund Remedial Branch
cc: Bill Meyer, NC-DEHNR
Richard Leahy, EPA-ORC
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'c::'-' ' ( ----~ ! ~--f ," ---•" __ -:~~ -"--.( ~~ I 0 LEGEND: 0 ~g(3 ~ D. I NO ,DATE ~----TAPn'INCi / •✓ INITIAT0/11 K.PACK I I I ! ( I llt:V!SIONS ~---0-11;~ i _•ESIGNI I PROJ IY I CMKO IENGII [NGR [NGII IAPPR DIIIAWN C.K.ROBERTSON PIIOJECT TANK 0 v 7:5•0. 5 ---------OUA:::j 0~_J '-.._~Sa.a ~_/ 0 \\ \ \ ) ) I 0 I ~ ---, --!__4<. cJ ·----.--~---------,..._ 731.5 r, 7 I ~\;\ '-,] ------~ -/ I I '\ I~ ----o· ---------~-----::::::-------..... ----------===-----~ \ I 0 ---------~ --------;::-~ vi I / • 7 78.5 // () (J l I :1----e-----/ ---r /-ii ~~~ ~ -I \!: I ---r,:;' --::--.I-._.\ t i 7 O •,,\ ,,_____ --.1, ' 115 0 ~ (j ----PROPERTY l!NE @ EXISTING PIEZOMETER • EXISTING BEDROCK MONITOR WELL ■ EXISTING SAPROUTE MONITOR WELL [j) EXISTING BEDROCK EXTRACTION WELL ♦ PROPOSED BEDROCK MONITOR WELL @ SOIL BORING 0 ·TEMPORARY WELLPOINTS (TWP) [!] SOIL SAMPLES (PARKING LOT) @ PROPOSED EXTRACTION WELLS NOTE: PROPERTY LINES APPROXIMATE ONLY, \( I . 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