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Home My WebLink AboutNCD991278953_20021001_National Starch & Chemical Corp._FRBCERCLA FYR_Five-Year Review Reports for the Entire Site (All Operable Units)-OCRa· .. ···.•·· • • • • • • • ' I • • • ' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDE,RAL CENTER 61 Forsyth Street, S.W. Atlanta, Georgia 30303-::1104 October I, 2002 4WD-NSMB Ms. Angela J. Doh! National Starch & Chemical Company 10 Findeme Avenue Bridgewater, New Jersey 08807 f ./ / SUBJ: Transmittal of Five-Year Review Report for Entire National Starch & Chemical Company Superfund Site Dear Ms. Doh!: Enclosed for your information is a copy of the above referenced document, signed and approved by the Agency on September 27, 2002. One of the most integral components of this report is Table 17 -Summary of Recommendations and Follow-Up Actions. The Agency requests that National Starch & Chemical Company (NSCC) review this table and provide feedback within three weeks of receipt of this letter. The feedback should include whether or not NSCC is willing to take on the "Issue" and if the associated "Milestone" is an acceptable time frame. The Agency realizes NSCC is currently working on some of these issues. In these situations, please confirm that the "Milestone" date provides NSCC sufficient time to complete the work necessary to address the issue. If you have any questions, I can be reached at 404-562-8820. Enclosure (I) Sincerely, Jon K. Bomholm Remedial Project Manager I. September 2002 Five-Year Review Repo1t for Entire National Starch & Chemical Company Superfund Site cc: David Mattison, NCDENR • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 4WD-NSMB Librarian Rowan County Public Library 20 I West Fi sher Street Salisbury, North Carolina 28144 ATLANTA FEDERAL CENTl,R 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3:104 October I, 2002 SUBJ: Transmittal of Final Five-Year Review Report for the Entire National Starch & Chemical Company Superfund Site Dear Librarian: Enclosed for the National Starch & Chemical Company Superfund Site Information Repository at Rowan County Public Library is a copy of the above referenced document. The Agency prepared this report with the assistance of both North Carolina Department of Environment & Natural Resources and National Starch & Chemical Company (i.e., the Potentially Responsible Party). The Agency approved this report on September 27, 2002. Please place this copy of the Final Five-Year Review Report for the National Starch & Chemical Company Site in the Information Repository housed at the Rowan County Public Library. If you have any questions, please feel free to call me at 404-562-8820. Enclosure (I) Sincerely, Jon K. Bomhol m Remedial Project Manager 1. Final Five-Year Review Report for the National Starch & Chemical Company Superfund Site in Salisbury, North Carolina cc: David Mattison, NCDENR • • UNITED STATES ENVIRONMENTAL PFIOTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3104 October I, 2002 4WD-NSMB Mr. David Mattison No11h Carolina Department of Environment & Natural Resources/Superfund Section Suite 150 401 Oberlin Road Raleigh, NC 27605 i~0 j; I I /I' j , ,< > . I l · 1J L j OCT - 3 2C02 ----·----·-·····--c• ! Ir·· r r r I I~ ! r.--t ' ; -,-, ·1 . \., •.. \! Ul~ .. -'--' l -·--·---------·--· -· .. SUBJ: Transmittal of Five-Year Review Report for the Entire the National Starch & Chemical Company Superfund Site Dear Mr. Mattison: Enclosed for the State's file is a copy of the above referenced document, signed on September 27, 2002. Thanks for your assistance. If you have any questions, I can be reached at 404-562-8820. Enclosure (I) Sincerely, J,mKiS~~ ~r: K. Bornholm Remedial Project Manager 1. September 2002 Five-Year Review Report for Entire National Starch & Chemical Company Superfund Site I' ' I NOlffll (\:AROLl,\A DEPARTMENT OF ENVIRO .• 'iT Al'ill NATURAL RESOURCES Dl\'ISIOl'i OF WASTE MAl'iAG,..ENT MICHAEi. F. EASLEY, GOVERl'OH WJLJ,IAM G. Ross, .JR., SECRl:TAR\' DEXTrn R. MATl'IIEWS, DIRECJ'()ll Mr .. lon K. Bornholm Remedial Project Manager Superfund Branch Waste Management Division US EPA Region JV 61 Forsyth Street, 11 •h Floor Atlanta, Georgia 30303 RE: Five-Year Review Report September 25, 2002 National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC Dear Mr. Bornholm: ,: . IL£ Copy The State of North Carolina has reviewed the attached First Five-Year Review Report for the Entire National Starch & Chemical Company National Priority List (NPL) Site ("Site"). The State of North Carolina concurs with the First Five-Year Review Report for the Entire National Starch & Chemical Company (NSCC) NPL Site, subject to the following conditions. I. State concurrence on the First Five-Year Review Report and the selected remedy for the Site is based solely on the information contained in the subject First Five- Year Review Report. Should the State receive new or additional information that significantly affects the conclusions or remedy selection contained in the First Five-Year Review Report. it may modify or withdraw this concurrence with written notice to the United States Environmental Protection Agency (US EPA) Region IV. 2. State concurrence on this First Five-Year Review Report in no way binds the State to concur in future decisions or commits the State to participate, financially or otherwise, in the clean up of the Site. The State reserves the right to review, overview, comment, and make independent assessment of all future work relating to this Site. 3. lf, after remediation is complete, the total residual risk level exceeds IO·', the State may require deed recordation/restriction tdocument the presence of residual contamination and possibly limit future use of the property as specified in NCGS l 30A-3 l 0.8. 1646 MAIL SER\'ICE CE1'TER. RALEIGH, NORTH C\ROLl1'.-\ 27699-1646 401 Onrnu, ROAD. S1;1n; 150. R.\LEIGII. NC 27605 P1101'E: 919-733-49961 FAX: 919-71 ;;,3605 _.\~· EQtiAI. OPP0R1·1:~1n"/AFflR.\IA Tl\"[ ,\(Ti{)\ E\IPL0Yf.R -50% Rl:CYCU:D!t0% POST-CO:'\Sl;~n:R PAP[H. Mr. Jon K. Bomholm September 25. 2002 Page 2 • • The State of North Carolina appreciates the opportunity to comment on the First Five- Year Review Report for the Entire NSCC Site and we look forward to working with the US EPA on the final remedy. If you have any questions or comments, please feel free to contact me at (919) 733-2801, extension 278. Attachment (\ce\c/7E7r' ~~Jl4'>l David J. Lown, LG. PE Acting Head Federal Remediation Branch Superfund Section cc: Phil Vorsatz, NC Remedial Section Chief Jack Butler, Chief NC Superfund Section • • FIVE-YEAR REVIE~W REPORT FIRST FIVE-YEAR REV][EW REPORT· FOR THE ENT][RE NATIONAL STARCH & CHE1\1ICAL COMPANY SUPERFUND SITE SALISBURY, ROWAN COUNTY NORTH CAROL][NA SEPTEMBER 2002 Prepared by: U.S. ENVIRONMENT AL PROTECTION AGENCY REGION 4 Atlanta, Georgia • • Five-Year Review Report Record of Preparation, Review, and Approval National Starch & Chemical Company Superfund Site EPA CERCLIS ID Number NCD003188828 Spill ID Number 04G2 Salisbury, Rowan County, North Carolina This report has been prepared in accordance with OSWER Guidance 9355.7-03B-P to document the five year review process at the National Starch & Chemic:al Company Superfund Site. Another five year review process will be initiated within five years of the signature of this document. Five-Year Review Report EPA, Region 4, Remedial Project Manager Prepared By Reviewed By Jon Bomholm, EPA, Region 4, Remedial Project Manager (Signature) (Dare) Phil Vorsatz, EPA, Region 4, Section Chief (Signature) (Date) David Mattison, North Carolina Department of Environment & Natural Resources Project Manager (Sig11ature) (Dare) Approved By (Sig11ature) (Date) Richard D. Green, Director Waste Management Division U.S. EPA, Region 4 • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL C01\11PANY SUPERFUND SITE TABLE OF CONTENTS SECTION PAGE No. EXECUTIVE SUMMARY ................................................. v111 1.0 INTRODUCTION ................................................... I 2.0 SITE CHRONOLOGY ............................................... 2 3.0 BACKGROUND .................................................... 2 3.1 PHYSICAL CHARACTERJSTICS ..................................... 2 3.2 LAND AND RESOURCES USE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.3 HISTORY OF CONTAMINATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3 .4 INITIAL RESPONSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3.5 BASIS FOR TAKING ACTION ..................................... 11 4.0 REMEDIAL ACTION ............................................... 12 4.1 REMEDY SELECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4.1.1 OPERABLEUNIT#I REMEDIAL ACTION OBJECTIVES ............ 13 4.1.1.1 OPERABLE UNIT#] REMEDIAL ACTION COMPONENTS ... 13 4 .1.2 OPERABLE UNIT #2 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . I 5 4.1.2.1 OPERABLE UNIT#2 REMEDIAL ACTION COMPONENTS ... 15 4.1.3 OPERABLE UNIT #3 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . I 5 4.1.3.1 OPERABLE UNIT #3 REMEDIAL ACTION COMPONENTS . . . 16 4.1.4 OPERABLE UNIT #4 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . 16 4.1.4.1 OPERABLE UNIT #4 REMEDIAL ACTION COMPONENTS . . . 17 4.2 REMEDY IMPLEMENTATION ..................................... 18 4.3 SYSTEM OPERATIONS/OPERATION AND MAINTENANCE ............... 21 5.0 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW .................... 21 6.0 FIVE-YEAR REVIEW PROCESS ..................................... 25 6.1 ADMINISTRATIVE COMPONENTS ................................. 25 6.2 COMMUNITY INVOLVEMENT/COMMUNITY INTERVIEWS ............... 25 ~-3 DOCUMENT REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 6.4 ARAR REVIEW ............................................... 25 6.5 DATA REVIEW ............................................... 27 6.6 SITE INSPECTION ........................................... ~ .. 28 II • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONALSTARCH & CHEMICAL COMPANY SUPERFUND SITE TABLE OF CONTENTS SECTION PAGE No. 7.0 TECHNICAL ASSESSMENT ........................................ 28 7. I QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENT? .................................. 29 7.2 QUESTIONS B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES USED ATTHET!MEOFTHEREMEDY STILL VALID? ................... 53 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? ... 53 8.0 ISSUES .......................................................... 54 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ................... 54 10.0 PROTECTIVENESS ST A TEMENT .................................... 54 I 1.0 NEXT REVIEW ................................................... 56 APPENDICES APPENDIX A --FlvE-YEAR REVIEW QUESTIONNAIRES APPENDIX B --LIST OF DOCUMENTS REVIEWED 111 • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE TABLES TABLE PAGE No. TABLE l CHRONOLOGY OF SITE EVENTS ......................................... 4 TABLE 2 MAJORiTY OF CONT AMIN ANTS DETECTED AT THE SITE ..................... 14 TABLE3 PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS ...................................... 30 TABLE 4 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU#! ....... 33 TABLE 5 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ....... 34 TABLE 6 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR METHYLENE CHLORIDE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OFOU #I ....... 35 TABLE 7 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR BIS(2-CHLOROETHYL)ETHER FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU# I ................................ 36 TABLE 8 HISTORICAL ANALYTICAL GROUNDWATER DAT A FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OFOU#J ................. 37 TABLE 9 HISTORICAL ANALYTICAL GROUNDWATER DAT A FOR 1,2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU# I ................. 38 TABLE JO HISTORICAL ANALYTICAL GROUNDWATER DATA FOR TOLUENE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OFOU #I .................... 39 TABLE 11 HISTORICAL ANALYTICAL GROUNDWATER DAT A FOR BIS(2-CHLOROETHYL)ETHER FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #I ......................................... 40 TABLE 12 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR I ,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 .................................. 41 TABLE 13 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANEFOR WELLS ASSOCIATED WITH OU #3 ................ 41 TABLE 14 HISTORICAL ANALYTICAL SURFACE WATER/SEDIMENT DATA FOR THE UNNAMED TRIBUTARY ....................................... 42 TABLE 15 HISTORICAL ANALYTICAL DATA FOR 1,2-DICHLOROETHANE IN SURFACE WATER/SEDIMENT FOR THE NORTHEAST TRIBUTARY ............... 43 TABLE 16 LIST OF SIGNIFICANT ISSUES .......................................... 54 TABLE 17 SUMMARY OF RECOMMENDATIONS AND FOLLOW-UP ACTIONS ............... 55 JV • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE FIGURES FIGURE PAGE No. FIGURE I SITELoCATION .................................................... 7 FIGURE 2 FEATURES AROUND THE NATIONAL STARCH & CHEMICAL COMPANY FACILITY . . 8 F'IGURE3 LAYOUT OF NATIONAL STARCH &CHEMICAL COMPANY FACILITY ............. 9 FIGURE 4 COMPONENTS OF OU #I GROUNDWATER REMEDIATION SYSTEMS ............. 22 FIGURE 5 COMPONENTS OF OU #3 GROUNDWATER REMEDIATION SYSTEMS ............. 23 FIGURE 6 NATURAL DEGRADATION TREAT ABILITY STUDY PHASE 2 SAMPLING LoCATIONS . 24 FIGURE 7 GROUNDWATER ELEVATION CONTOUR MAP FOR OU # I/OU #2 TRANSITION ZONE WELLS FOURTH QUARTER 1999 .................................. 44 FIGURE 8 GROUNDWATER ELEVATION CONTOUR MAP FOR OU #I/OU #2 BEDROCK WELLS -FOURTH QUARTER 1999 ...................................... 45 FIGURE 9 GROUNDWATER ELEVATION CONTOUR MAP FOR OU #3 SAPROLITE/ TRANSITION ZONE WELLS -THIRD QUARTER 2000 ......................... 46 FIGURE IO GROUNDWATER ELEV A TION CONTOUR MAP FOR OU #3 BEDROCK WELLS -THIRD QUARTER 2000 ....................................... 47 FIGURE 11 SURFACE WASTE SAMPLING LoCATIONS FOR MARCH 1987 ................. 48 FIGURE 12 SEDIMENT SAMPLING LoCATIONS FOR MARCH 1987 ...................... 49 FIGURE 13 JUNE 2000 SURFACE WATER/SEDIMENT SAMPLING LoCATIONS ON UNNAMEDTRlBUTARY .............................................. 50 FIGURE 14 JUNE 1987 SURFACE WATER/SEDIMENT SAMPLING LoCATIONS ON NORTHEAST TRIBUTARY ............................................ 51 FIGURE 15 CURRENT SURFACE WATER/SEDIMENT SAMPLING LoCATIONS ON NORTHEAST TRIBUTARY ............................................ 52 V • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE AC! AOC ARARs CAA CD CERCLA CFR coc COD CT CWA DNAPL 1,2-DCA EPA ESA ESD FS ft/day ft/yr GCIMS gpm HRS MCL ISA NCAC 2B ISA NCAC 2L NCDEM NCDENR NCP NPL NSCC O&M OU LIST OF ACRONYMS Acceptable Chronic Intake concentrations Administrative Order on Consent Applicable or Relevant and Appropriate Requirements Clean Air Act Consent Decree Comprehensive Environmental Response, Compensation, and Liability Act of 1980 Code of Federal Regulations Chemical of Concern Chemical Oxygen Demand Collection Trench Clean Water Act Dense Non-Aqueous Phase Liquid 1,2-Dichloroethane U.S. Environmental Protection Agency Endangered Species Act Explanation of Significant Difference Feasibility Study feet per day feet per year Gas Chromatograph/Mass Spectrograph gallons per minute Hazardous Ranking System Maximum Contaminant Level North Carolina Administrative Code Title ISA Subchapter 2B (NCAC 1SA-2B), Classification and Water Quality Standards Applicable to the Surface Waters and Wetlands of North Carolina North Carolina Administrative Code Title ISA Subchapter 2L (NCAC l SA-2L), Groundwater Classification and Standards North Carolina Department of Environmental Management North Carolina Department of Environment and Natural Resources National Contingency Plan National Priority List National Starch & Chemical Company Operation and Maintenance Operable Unit • • VI FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE ppb PPES ppm POTW PRP PVC RA RAOs RD RD/RA R,D RI RI/FS ROD RPM SDWA SARA OU SVOCs TCLP UAO µglkg µgll voes LIST OF ACRONYMS pans per billion Plume Periphery Extraction System Pans per Million Publically Owned Treatment Works (local sewer system) Potentially Responsible Pany Polyvinyl Chloride Remedial Action Remedial Action Contracts Remedial Design Remedial Design/Remedial Action Reference Doses Remedial Investigation Remedial Investigation/Feasibility Study Record of Decision Remedial Project Manager Safe Drinking Water Act Superfund Amendments and Reauthorization Act of I 986 Operable Unit Semi-Volatile Organic Compounds Toxicity Characteristic Leaching Procedure Unilateral Administrative Order microgram per kilogram microgram per liter Volatile Organic Compounds Vil • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE EXECUTIVE SUMMARY The remedies for Operable Unit #I and Operable Unit #3 at the National Starch & Chemical Company Superfund site in Salisbury, North Carolina include groundwater extraction and on-site treatment of contaminated groundwater. The treated groundwater is discharged to the City of Salisbury sewer system. The Record of Decision for Operable Unit #2 specified "No Action" for the contaminated soils in the Trench Area since the contaminants that migrate into the aquifer via natural flushing by precipitation percolating through the contaminated soils are anticipated to be captured by the Operable Unit #I groundwater extraction system. A natural degradation treatability study is currently being conducted for the contaminated soil associated with Operable Unit #4. The Operable Unit #4 Record of Decision is a contingent Record of Decision. If National Starch & Chemical Company cannot demonstrate that natural degradation of contaminants in the soil is occurring, then a soil-vapor extraction system is to be installed. The first Five-Year Review Report for Operable Unit #I was issued on June 18, 1996 and the first Five-Year Review Report for OU #2 was issued in August 1998. This Five-Year Review Report covers all four Operable Units. The trigger for conducting this five-year review was the start date for the construction of the plume periphery extraction system for Operable Unit #I on August 14, 1990. The assessment of this Five-Year Review found that the remedies for Operable Unit #I and Operable Unit #3 were constructed in accordance with the requirements of the September 30, 1988 Record of Decision for Operable Unit# I and the October 7, 1993 Record of Decision for Operable Unit #3. The Record of Decision for Operable Unit #2, dated September 28, 1990, was a no action Record of Decision and therefore, no remedial action was implemented with regard to Operable Unit #2. National Starch & Chemical Company is currently conducting a natural degradation treatability study in accordance with the October 6, 1994 Record of Decision for Operable Unit #4. Two Explanation of Significant Differences, dated June 10, 1997 and September 28, 1990, were prepared for Operable Unit #3. The first Explanation of Significant Difference was issued to sp(,Cify the type of treatment to be used on the contaminated soils generated during the installation of the components of the Operable Unit #3 remedial action. The second Explanation of Significant Difference substituted an interception trench for a number of extraction wells. Part of the Operable Unit #I remedy (the Trench Area extraction wells) and the entire Operable Unit #3 remedies are functioning as designed. National Starch & Chemical Company is currently evaluating the effectiveness of the plume periphery extraction wells of the Operable Unit# I remedy which requires these wells to be temporarily shut-down. The immediate threats associated with the four Operable Units have been addressed and these remedies are expected to be protective until groundwater cleanup goals are achieved through groundwater extraction and monitored natural attenuation. The clean-up of the Site is expected to require more than 120 years. • First Five-Year Review Report for the Entire • National Starch & Chemical Company Superfund Site Salisbury, North Carolina 1.0 INTRODUCTION The purpose of a five-year review is to determine whether the remedy(ies) at a Superfund Site is(are) protective of human health and the environment. The methods, findings, and conclusions of this review are documented in a Five-Year Review Report. In addition, Five-Year Review Reports identify issues found during the review, if any, and identify recommendations to address them. The Agency has prepared this Five-Year Review Report for the entire National Starch & Chemical Company (NSCC) Superfund Site pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund) and the National Continge11cy Plan (NCP). CERCLA § 121 states: If the Presidem selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemellled. In addition, if upon such review it is the judgemell! of the President acrion is appropriare at such site in accordance with section 104, the Presidem shall take or require such action. The Preside111 shall repon to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews. The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states: If a remedial action is selecred that results in hazardous substances, pollutants, or co111amina111s remaining ar the site above levels rhat allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often then every five years after the initiation of the selected remedial action. The United States Environmental Protection Agency (EPA or Agency), Region 4, conducted the five-year review of the remedies implemented at the NSCC Superfund Site in Salisbury, North Carolina. This review was conducted by the Remedial Project Manager (RPM) in conjunction with North Carolina Depanment of Environment and Natural Resources (NCDENR) with the assistance of NSCC for the entire Site from July 2001 through August 2002. This repon documents the results of the review. • 2 Five-Year Review Rcpon National S~ Chemical Company Superfund Sile ~ SepLcmbcr 2002 The first Five-Year Review Report, dated June 18, 1996, covered Operable Unit #I (OU #I) and the second Five-Year Review Report, dated August 1998, covered OU #2. This five-year review is for the entire NSCC Site (i.e., all four OUs). The triggering action for the June 18, 1996 Five-Year Report was the initiation of the OU #I remedial action on August 14, 1990. The June 1996 Five-Year Review Report specified it was a statutory review as hazardous substances, pollutants, or contaminants remain on Site that would not allow unlimited use of the Site. 2.0 SITE CHRONOLOGY Table I lists the major milestones for CERCLA related work at the Site. 3.0 BACKGROUND 3.1 PHYSICAL CHARACTERISTICS The NSCC site is located on Cedar Springs Road, approximately 5 miles south of the City of Salisbury, in Rowan County, North Carolina. Figure 1 shows the location of the Site with respect to the City of Salisbury and Figure 2 identifies the features around the NSCC facility. As can be seen, commercial, industrial, and residential developments surround the Site. Grants Creek forms the western boundary. Two separate tributaries of Grants Creek, the Unnamed Tributary (Southwest Tributary) and the Northeast Tributary, are located in the southwest and northeast portions of the Site, respectively. Figure 3 highlights the locations of the structures/facilities on the NSCC property and the general locations of the four OUs. OU #I focuses on contaminated groundwater in the western portion of the NSCC property and the surface water/sediment in the Unnamed Tributary (refer to Figure 3); OU #2 concentrates on the Trench Area soils in the western portion of the NSCC property (refer to Figure 3); OU #3 deals with the contaminated groundwater under Area 2, the parking lot, and the wastewater treatment lagoons and the surface water/sediments in the Northeast Tributary (refer to Figure 3); and OU #4 centers on the contaminated soils in and around Area 2 and the wastewater treatment lagoons (refer to Figure 3). Area 2 includes the following features: Area 2 reactor room, the tank room, raw material bulk storage, the warehouse, and an abandoned underground terra-cotta pipe line that ran from the Area 2 reactor room to the wastewater treatment lagoons. The lagoon area includes three lagoons which were originally constructed as unlined lagoons between 1969-1970. Underlying the ground surface at the Site is saprolite; a clay-rich, unconsolidated material derived from in-situ weathering of the underlying bedrock. A transition zone between the saprolite and competent bedrock consists of saprolite, partially weathered rock, and competent rock fragments to boulders. The transition zone represents a zone of greater weathering than the competent bedrock, but lesser weathering than the saprolite. The transition zone averages between five and 122 feet in thickness and appears to underlie the entire facility. The depth of bedrock ranges from JO to 125 feet below ground surface. • 3 Five-Year Review Repon National S~ Chemical Company Superfund Site '9J September 2002 The saprolite and transition zones collectively act as the storage zone for groundwater. The bedrock generally has low primary porosity and therefore does not act as an important storage zone. More groundwater flow occurs in the transition zone than in the saprolite, this is mainly due to differences in conductivity and effective porosity. Groundwater flow in the fractured bedrock is through secondary porosity, which is primarily in the form of vertical or high angle fractures. These three lithological units are hydraulically interconnected with little impedance between them. Water level measurements from the water table/saprolite zone of the aquifer indicate that hydraulic heads decrease from both the east and west toward either the Unnamed Tributary or the Northeast Tributary. This indicates that these tributaries act as groundwater divides for the underlying aquifer. The hydraulic conductivity of the saprolite materials and the bedrock ranges from 0,72 to 3.35 feet per day (ft/day) and 0.01 to 1.13 ft/day, respectively. Based on the above information, the horizontal flow of groundwater in the saprolite was estimated to have a velocity of 80 feet/year .(ft/yr) in the lagoon area and 27 ft/yr in Area 2. 3.2 LAND AND RESOURCES USE The groundwater beneath the NSCC property is designated as Class GA in accordance with North Carolina's water classification system and Class IlA under USEPA Groundwater Classification Guidelines (December I 986). The Class GA classifications means that the groundwater is an existing or potential source of drinking water supply for humans as specified under North Carolina Administrative Code, Title 15, Subchapter 2L (NCAC 15-2L.02). EPA classifies the groundwater as Class IlA since the aquifer is currently being used as a source of drinking water in the vicinity of the NSCC facility. Neither the Unnamed Tributary nor the Northeast Tributary are specifically classified due to the low flow conditions within these streams. However, these streams are considered Class "C" under North Carolina Administrative Code, Title ISA, Subchapter 2B (NCAC 15A-2B.02) because the receiving stream, Grants Creek, isdassified as a Class C stream. A Class C stream is defined as being suitable for secondary recreation and the "propagation of natural trout and maintenance of trout." Land use of the areas immediately adjacent to the NSCC property is a mixture of residential and industrial developments (refer to Figure 2). An industrial park is located on the east and south sides of the NSCC facility. Another industrial park is located along the southern property line. A mobile home park adjoins the extreme southwestern corner of the property. Two housing developments lay to the north, one of which is adjacent to the facility property. The location of the nearest private, potable wells is approximately 2,700 feet north of Area #2. • 4 TABLE I --CHRONOLOGY OF SITE EVENTS EVENT Proctor Chemical Company purchased the 465-acre tract Construction of facility Proctor Chemical Company dissolved and merged with NSCC Site proposed for National Priorities List Special notice letter to conduct Remedial Investigation/Feasibility Study Administrative Order on Consent signed Remedial Investigation/Feasibility Study (Rl/FS) Work Plan Amended Rl/FS Work Plan Site re-proposed for National Priorities List First Remedial Investigation (RI) Report [for Operable Unit (OU) #1] First Feasibility Study (FS) Document (OU #I) Proposed Plan Fact Sheet Proposed Plan Public Meeting (OU #I) Proposed Plan public comment period (OU #I) OU #I Record of Decision (ROD) Signed, divided Site into two OUs, created OU #2 Issued Special Notice Letter to Conduct Remedial Design/Remedial Action for OU# I Unilateral Administrat_ive Order issued to perform OU #I Remedial Design/Remedial Action (RD/RA) Site finalized on National Priorities List Supplemental Remedial Investigation Report for OU #2 Initiation of OU #I construction -building access roads to bedrock plume periphery extraction well locations Installation of four bedrock plume periphery extraction wells Proposed Plan for OU #2 Proposed Plan public comment period Five-Year Review Report • al Starch & Chemical Company Supcrfund Si1c September 2002 DATE September 1968 1970 January I, 1983 April 1985 May 30, 1986 December I, J 986 December 1986 July 1987 June 1988 June 21, I 988 September 8, 1988 September I 988 September J 4, I 988 September 3 -24, 1988 September 30, 1988 March 27, 1989 July 27, 1989 October 1989 May 1990 August 14, 1990 August 301-November 14, 1990 July 1990 July 30 -August 29, 1990 • 5 TABLE 1 ·· CHRONOLOGY OF SITE EVENTS EVENT Supplemental Feasibility Study Document for OU #2 ROD for OU #2 signed, divided Site into three OUs, created OU #3 Consent Decree for OU #2 OU #3 Remedial Investigation Report OU #3 Feasibility Study Document Proposed Plan Fact Sheet for OU #3 Construction of trench area extraction wells + pretreatment system OU #3 Proposed Plan Public Meeting Proposed Plan public comment period Record of Decision for OU #3 signed, divided Site into 4 OUs, created OU#4 OU #4 RJ Report (used June 1993 OU #3 Remedial Investigation) OU #4 Feasibility Study Document Proposed Plan Fact Sheet for OU #4 OU #4 Proposed Plan public comment period OU #4 Proposed Plan Public Meeting Record of Decision for OU #4 Unilateral Administrative Order for OU #3 and OU #4 RD/RA Initiated OU #3 and OU #4 Remedial Design Construction Completion for OU #I Remedial Action First Five-Year Review Report (for OU #I) Initiated OU #4 Natural Degradation Treatability Study -Phase I First Explanation of Significant Difference Completed OU #4 Natural Degradation Treatability Study -Phase I OU #3 Remedial Design Completed Five-Year Review Rcpon • al Starch & Chemical Company Supcrfund Sile September 2002 DATE September 1990 September 28, 1990 CD signed August 199 I, entered in Federal Court on July 20, 1992 June 2, 1993 June 21, 1993 July 15, 1993 July 1993 -February 1996 August 3, I 993 July 19 -August 17, 1993 October 7, 1993 June 1993 June 20, I 994 July 8, 1994 July 12 -August 11, 1994 July 26, 1994 October 6, 1994 September 29, 1995 October 1995 March 1996 June I 8, I 996 December 1996 June 10, I 997 March 26, 1998 June 1998 • 6 TABLE I --CHRONOLOGY OF SITE EVENTS EVENT Second Explanation of Significant Difference Initiation of OU #3 Remedial Action Initiation of OU# 1 + OU #3 Combined Pretreatment System Completion of OU #I + OU #3 Combined Pretreatment System Construction Completion for OU #3 Initiated OU #4 Natural Degradation Treatability Study -Phase II First Site-Wide Five-Year Review Report Complete OU #4 Natural Degradation Treatability Study -Phase II Accept Findings of Soil Degradation Treatability Study or Implement Contingent Remedy Complete OU #I Plume Periphery Evaluation Implement Recommendations of OU #I Plume Periphery Evaluation Second Site-Wide Five-Year Review Report Third Site-Wide Five-Year Review Report ..... --... ·-. - Five-Year Review Rcporl • I Starch & Chemical Company Superfund Site September 2002 DATE November 4, 1998 June 15, 1999 September 23, 1999 February 18, 2000 February 18, 2000 November 5, 2001 July 2002 Anticipated December 2002 February 2003 July 2003 September 2003 September 2007 September 20 I 2 MIU. ~ IWIIW'I..OIS • 7 Five-Year Review Report National S1a.hcmical Company Superfund Site September 2002 N DAWlSON COUNTY -- \ COUNTY ----7 ~RUS COUNTY I ·-· --. ~ -··------a e 16 Llll.£S SITE LOCATION FIGURE I SOURCES: ROWAN MILLS, CHINA GROVE NORTH CAROLINA . 7.5 MINUTE QUADRANGLE CONTOUR INTERVAL = 10 FEET ■NC. ~ -~· OUADRAl<CLE LOCATION • 8 UTW GAIO ANO 19117 MAGNETIC HORTM O{CllNATI0N AT C(NT[R Of SH[[T Five• Year ke.,,.ic,. r'..cpon • National St;m.:h & Chemical Company Supc:rfund Site Sep1embcr 2002 2000' 0 2000' Approximate Scale: 1"' = 2000' FEATURES AROUND THE NSCC FACILITY FIGVRE2 • • 1'. -5C.-'U .. m, • 3.3 HISTORY OF CONTAMINATION 10 Five-Year kcvicw Rcpon National St.Chemical Company Superfund Sik September 2002 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 I, 1983, Proctor Chemical Company was dissolved and its operations merged with NSCC. The primary products of this facility are 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 liquid waste stream from the manufacturing processes include reactor and feed line wash and rinse solutions. This wastewater may include a combination of the following chemicals: acrylimide, 1,2-dichloroethane (1,2-DCA), methyl isobutyl ketone, methanol, styrene, maleic anhydride, vinyl toluene, sulphonated polystyrene, epichlorohydrin, octyl alcohol, ethyl alcohol, ally! alcohol, ally! chloride, sodium hydroxide, and sulfuric acid. In general, the greatest concentrations of organic contaminants in the soil were found in four areas: in and around the Trench Area, underneath Area 2, in and around the terra-cotta pipeline, and north-northeast of the lagoon area. Based on a 1984 CERCLA !03(c) notification report filed by NSCC, from 1971 to 1978, NSCC disposed of approximately 350,000 gallons of DO02 waste (corrosive waste with pH ,; 2.0) reaction vessel wash waters in trenches constructed in a 5-acre tract of land (Trench Area). Liquid effluent from the plant production area flowed into Lagoon I, which was unlined, and then was pumped to the Trench Area. Each trench was used until liquid no longer readily percolated into the ground. Afterwards the trench was backfilled and seeded, and a new trench was excavated. Since I 978, production plant process waters were directed to NSCC's pretreatment system and then discharged to the City of Salisbury publicly owned treatment works (POTW) (sewer system). In Area 2, two sources of contamination were identified: an underground terra-cotta pipeline and a solvent recovery system (distillation unit). The underground terra-cotta pipeline transported wastewater from the production area to the wastewater treatment lagoons. Terra-cotta piping was also used to control and direct surface water run-off from the plant area to the embankments of the Northeast Tributary. In February 1994, NSCC sealed the ends of the terra-cotta pipelines and replaced them with overhead pipelines. The solvent recovery system now sits on a concrete platform surrounded by a concrete berm so that any spills associated with the operation of this system are controlled and not released into the environment. In the lagoon area, the source of contamination was eliminated in I 984 when NSCC lined the lagoons with concrete. The contamination currently being detected in the soils and groundwater in these areas is the result of past practices and the residual contamination in the soil. 3.4 INITIAL RESPONSE The first environmental investigative work occurred in I 976 which included drilling 14 soil borings and the installation of eight polyvinyl chloride (PVC) monitoring wells within and around the Trench Area. Surface water/sediment samples were also collected during this time- 11 Five-Year Review Repon National S~ Chemical Company Superfund Site ,. September 2002 frame but the locations of the sampling points were not recorded consequently, this data has little value. NSCC first sampled these wells in January 1977 and again in November 1977. North Carolina Department of Environmental Management (NCDEM) sampled three of these wells in June 1977 and resampled two of the same wells and a different well in January 1983. All of the samples discussed above were analyzed for only metals and general water chemistry parameters. As pan of the 1977 assessment effort, NCDEM also sampled Grant Creek. In 1978, NCDEM augured 31 soil borings around the Site as well as collected groundwater samples. In June 1984, NCDEM resampled the same wells sampled in January 1983. These samples were analyzed using a gas chromatograph/mass spectrograph (GC/MS), but contaminant specific data was not generated. As a result of this sampling effort, NCDEM directed NSCC to run full sweeps on these wells. Consequently, NSCC collected groundwater samples from these wells in September and October 1984. The results showed the presence of toluene, xylene, 1,2-DCA, 1,2-dichloropropane, and several other organics. NCDEM also sampled the Southwest Tributary as part of this effort. In I 984 and I 985, North Carolina Department of Health Services, NSCC, and Rowan County Health Department sampled and resampled a number of nearby residential potable wells. None of the analyzes showed any detection of organic contaminants. NSCC also sample Grant Creek and the Unnamed Tributary in 1985. NSCC also sampled surface water conditions during three (3) different weather conditions: (I) after a 5-week dry period, (2) after a rainstorm, and (3) after a heavy rainstorm. However, the usefulness of the data generated from these efforts was very limited since these samples were only analyzed for chemical oxygen demand (COD) and pH. The NSCC Site was proposed for inclusion on the National Priorities List (NPL) in April I 985, re-proposed in June 1988, and finalized on the list in October 1989 with a Hazardous Ranking System (HRS) score of 46.51. The HRS score was 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. 3.5 BASIS FOR TAK.ING ACTION A number of contaminants have been detected in the soils, groundwater, and surface water/sediment at the NSCC Superfund site. Table 2 lists the majority of contaminants that have been detected in these environmental media. Under EPA's risk management criteria, exposure to Site soil, groundwater, or surface water/sediment could result in unacceptable human health risks. The carcinogenic risks were highest for exposures to groundwater and soil due to the high concentrations of carcinogenic chlorinated volatile organic compounds (VOCs). Non-carcinogenic risks were highest for exposures to groundwater due to the elevated concentrations of metals in the groundwater. Potential risks associated with exposure to groundwater are attributed to the presence of a variety of VOCs that exist at concentrations that exceed State and Federal applicable or relevant and appropriate requirements (ARARs). • 4.0 REMEDIAL ACTION 4. I REMEDY SELECTION 12 Five•Ycar Review Repon National Su. Chemical Company Supcrfund Site September 2002 Since there has only been one owner/operator of this property after being developed into an industrial complex, no "Responsib]eParty Search" was performed. NSCC has been and remains the sole owner/operator of the facility and therefore the only Potentially Responsible Party (PRP). A special notice letter was sent on May 30, 1986 to provide NSCC an opportunity to conduct the Remedial Investigation/Feasibility Study (RI/FS). A good faith offer was submitted and negotiations were concluded with NSCC signing an Administrative Order on Consent (AOC) on December I, I 986. The first RI/FS was completed on June 21, 1988 and September 8, 1988, respectively. Following the signing of OU #I Record of Decision (ROD) on September 30, 1988, the Agency sent a special notice letter to NSCC to initiate negotiations on a Consent Decree (CD) for implementing the OU #I Remedial Design/Remedial Action (RD/RA). However, negotiations on the CD were not successful. The Agency issued NSCC an Unilateral Administrative Order (UAO) directing NSCC to design and implement the Remedial Action (RA) specified in the OU #I ROD. The effective date of the UAO was July 27, 1989. To date, NSCC is in compliance with the requirements of the July 1989 UAO. The OU #1 ROD split the Site into two operable units. Working under the December 1986 AOC, NSCC generated a Supplemental Remedial Investigation (RI) Report and Feasibility Study (FS) document for OU #2. These reports were completed in May I 990 and September 1990, respectively. The Supplemental RI reported continued detections of contaminants in the Northeast Tributary but did not identify the source of this contamination. The OU #2 ROD, signed on September 28, I 990, was a no action alternative with regard to the soils in the Trench Area, however, this ROD did divide the Site into a third operable unit. Following the signing of the OU #2 ROD, the Agency sent NSCC another special notice letter in March 1991 to initiate negotiations on a CD. This CD governed the implementation of the OU #2 RA. The CD was signed in August 1991 and was entered by the Federal Court on July 20, 1992. To date, NSCC is in compliance with the requirements of the July I 992 CD. On December 4, 1991, EPA issued written notification to NSCC to conduct a third RI/FS to determine the source, nature, and extent of contamination entering the Northeast Tributary as required by the OU #2 ROD. As with the previous RI/FS efforts, the OU #3 RI/FS was conducted in accordance to the December 1986 AOC. The OU #3 RI and FS reports were completed on June 2, 1993 and June 21, 1993, respectively. Due to an inadequate evaluation of source control remediation alternatives in the OU #3 FS document, the Agency decided to split the groundwater and source control efforts into OU #3 and OU #4, respectively. The OU #3 ROD was signed on October 7, 1993 and required a fourth operable unit. On October 12, 1993, EPA requested NSCC to initiate OU #4 in accordance to the December 1986 AOC. Since only the evaluation of the source control remediation alternatives was in question, the June 1993 OU #3 RI sufficed as the OU #4 RI report. The June 20, 1994 OU #4 FS was conditionally approved by the Agency on July 8, 1994 and EPA issued the OU #4 ROD on October 6, 1994. In an effort • 13 · Five-Year ReView Rcpon National St;:. Chemical Company Su_perfund Sitt September 2002 to conserve resources, the Agency decided to negotiate the OU #3 and OU #4 RD/RAs together. Negotiations on a CD were unsuccessful. Consequently, EPA issued a second UAO to NSCC to implement the OU #3 and OU #4 remedies. The effective date of the UAO is September 29, 1995. To date, NSCC is in compliance with the requirements of the September 1995 UAO. Below are the remedial action objectives (RAOs) and the major components of each operable unit: 4.1.1 OU #I RAOs • Extract contaminated groundwater from the transition and bedrock zones.throughout the plume; • Pump extracted groundwater to treatment system for treatment; • Monitor the groundwater extraction and treatment systems; • Reduce mobility, toxicity, and volume of the contaminants in the aquifer; • Prevent further migration of groundwater contamination beyond its current extent; • Restore aquifer to Federal and State ARARs, including drinking water standards, and a level that is protective of human health and the environment within a reasonable period of time; and • Eliminate/minimize the threat posed to human health and the environment by preventing exposure to groundwater contaminants. 4.1.1.1 OU #I RA Components • Install groundwater extraction system to capture the leading edge of the plume, plume periphery extraction system (PPES), and the heart of the plume (i.e., immediately down gradient of the Trench Area). • Treat the extracted groundwater through a train of treatment technologies that may include: air stripping, activated carbon filtration, and metal removal to achieve a quality of water that can be discharged to the City of Salisbury POTW. • Establish a monitoring program for groundwater and surface water/sediment; and • Conduct a supplemental RI (OU #2) to determine the source of contamination continually being detected in the surface waters. The ROD for OU# I did not specify a duration for the RA. • 14 Five-Year Review Rt·port • al Starch & Chemical Company Superfund Siti: September 2002 TABLE 2 --MAJORITY OF CONTAMINANTS DETECTED AT THE SITE SOIL GROUNDWATER SURFACE WATER/SEDIMENT VOLATILE ORGANIC COMPOUNDS VOLATILE ORGANIC COMPOUNI>S VOLATILE ORGANIC COMPOUNDS Acetone Acetone 1,2-Dichloroethane Bromodichloromethane B is(2-ch I oroethy I )ether 2-Butanone Benzene Chloroform Bromodichloromethane Dibromochloromethane Carbon Disulfide 1.2-Dichloroethane Chloroethane Tetrachloroethene Chloroform Toluene 1,2-Dichloroethane Trichloroethene 1.1-Dichloroethene Total Xylenes 1,2-Dichloroethene (cis/trans) Vinyl Chloride 1,2-Dichloropropane Ethylbenzene PESTICIDE Methylene Chloride Delta-Hexachlorocyclohexane Tetrachloroethene Toluene INORGANICS 1.1,2-Trichloroethane Antimony Trichloroethene Arsenic Total Xylenes Barium Vinyl Chloride Beryllium Cadmium SEMI-VOLATILE ORGANIC Chromium COMPOUNDS Manganese B is(2-ethyl hex y I )phthalate Nickel Di-n-butyl Phthalate Selenium Di-n-octyl Phthalate Thallium 4-Nitrophenol Zinc INORGAl\1CS Antimony Arsenic Barium Beryllium Cadmium Chromium Manganese Nickel Selenium Thallium Zinc • 4.1.2 OU #2 RAOs 15 Five-Year Review Kepon National st:4111_ Chemical Company Supcrfund Site ,. September 2002 • Capture contaminants leaching from the soils in the Trench Area as precipitation naturally infiltrates and flushes the contaminants from the soils into the groundwater (accomplished by OU #1); • Minimize the migration of contaminants into surface water; and • Reduce mobility, toxicity, and volume of the contaminants in the soils in Trench Area to a point where the contaminants will no longer adversely impact the quality of the underlying aquifer. 4.1.2.1 OU #2 RA Components • No action remedy; • Monitored natural attenuation; • Monitor soils in the Trench Area on a quarterly basis; • Deed restriction to I) identify the area(s) of contamination, 2) prevent transfer of property to an uninformed purchaser, and 3) limit future utilization of the property; and • Conduct an RI (OU #3) to determine the source of contamination continually being detected in the surface waters in the Northeast Tributary. The ROD for OU #2 estimated 20 -30 years for the levels of contaminants in the soils to be reduced to a concentration where the contaminants will not adversely impact the quality of the underlying aquifer above the specified ARARs. 4.1.3 OU #3 RAOs • Operate groundwater extraction in the impacted areas; • Pump groundwater to the treatment system for treatment; • Treat the groundwater in the combined OU #I and OU #3 pretreatment facility through equalization, hydrolysis, and air stripping; • Monitor groundwater and surface water/sediment in the Northeast Tributary; • Reduce mobility, toxicity, and volume of contaminants in the aquifer; • Prevent further migration of groundwater contamination (including a potential dense non- aqueous phase liquid (DNAPL)) beyond its current extent; • 16 Five-Year Review Report National S. Chemical Company Supcrfund Sik · September 2002 • Restore contaminated groundwater to Federal and State ARARs, including drinking water standards, and a level that is protective of human health and the environment within a reasonable period. of time; and • Eliminate/minimize the threat posed to human health and the environment by pre:venting exposure to groundwater contaminants; 4.1.3.1 OU #3 RA Components • Install a groundwater extraction system in Area 2 (interception trench) and the lagoon area (extraction wells); • Treat the extracted groundwater using air stripping and/or activated carbon filtration (metal removal is not warranted at this time due to their low concentrations) to achieve a quality of water that it can be discharged to the City of Salisbury POTW; • Vapor emissions from the air stripping unit are to be controlled through catalytic oxidizing and scrubbing; • Establish a monitoring program for groundwater and surface water/sediment; and • Conduct FS (OU #4) to re-examine remediation options for the soils in this area of the NSCC facility. Two Explanation of Significant Differences (ESDs), dated June 10, 1997 and November 4, 1998, were prepared for OU #3. The first ESD was issued to specify that the contaminated soils generated during the installation of the OU #3 extraction wells were to be treated thermally to remove the VOCs from the soil. The vapor was treated prior to being released to the atmosphere. The second ESD substituted an interception trench for a number of extraction wells. All costs in the OU #3 ROD are based on running the groundwater extraction system for 30-years. 4.1.4 OU #4 RAOs • Implement a biodegradative study to substantiate the occurrence of natural degradation of contaminants in the soils at the Site and determine where and at .what rate degradation is occurring; • Develop a long-term monitoring program to ensure natural degradation continues to be effective until the ROD soil Performance Standard for 1,2-DCA is achieved and maintained; • Reduce mobility, toxicity, and volume of the contaminants; • 17 Five•Year Review Rcpon National S. Chemical Company Superfund Site September 2002 • Eliminate or minimize the threat posed to human health and the environment by preventing exposure to groundwater contaminants; • For human health, prevent release of contaminants from soil that could result in contaminant levels in excess of groundwater cleanup objectives specified in the OU #3 ROD; and • For environmental protection, continue containment of contamination. 4.1.4.1 OU #4 RA Components OU #4 ROD contains a contingency. The components of the primary alternative (monitored natural attenuation) include: • Perform a "Biodegradati ve Study" to (I) substantiate that natural degradation of contaminants of concern in the soil is occuning in the OU #4 area, (2) identify where in the subsurface soils degradation is occuning, and (3) determine the rate of degradation; • Develop and implement a for long term monitoring plan to monitor the biodegradative process until the performance standards are achieved; • Implement institutional controls. Institutional controls include deed restrictions and maintenance of both the existing fence around the plant operations area and the paved areas around Area 2; • Develop a plan to protect workers in the event that the contaminated soils are to be excavated prior to the levels of 1,2-DCA reaching the appropriate direct contact health based risk concentration; • Conduct a five-year review in accordance with CERCLA Section 121(c); In the event that the "Biodegradative Study" cannot substantiate the occurrence of significant natural degradation of I ,2-DCA and other contaminants of concern in the soil, or the study shows that degradation products increase the Site risks, the contingent remedy will be implemented. "Significant biodegradation" is defined as a statistically significant decrease in levels of contaminants of concern (particularly 1,2-DCA) that is coupled with multiple indicators of biological activity, which includes the appearance of degradation products such as, but not limited to, chloroethane, ethane, vinyl chloride, ethene, carbon dioxide, hydrogen sulfide, methane, and soluble iron(Il)) and the depletion of electron acceptors (including oxygen, nitrate, iron, sulfates, or others). The components of the contingent remedy include: • Install a soil-vapor extraction system above the water table to remove the volatile organic contaminants from the unsaturated zone and • 18 Five-Year Review Repon National S. Chemical Company Superfund Site September 2002 • Treat the extracted contaminated air from Area 2 using fume incineration to destroy the volatile organics prior to the air stream being released into the atmosphere. After concentrations of contaminants decrease in the extracted air, this contaminated vapor may be treated via vapor-phase activated carbon adsorption filters. The extracted contaminated air from the lagoon area will be treated using vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air stream being released into the atmosphere. The OU #4 ROD estimates it will take up to approximately 35-years to obtain the performance standard of 169 microgram per kilogram (µglkg) or parts per billion (ppb) forl,2- DCA in soil through monitored natural attenuation. At this concentration, 1,2-DCA should not adversely impact the groundwater in the underlying aquifer above the ARAR for 1,2-DCA which is 1 microgram per liter (µg/1) or ppb. The OU #4 ROD also estimated the time-frame to achieve the ARAR for 1,2-DCA in groundwater to be 130 years. 4.2 REMEDY IMPLEMENTATION The OU #1 RD/RA was implemented under the July 27, 1989 UAO. The OU #1 Remedial Design (RD) was approved by the Agency in 1990 and RA construction activities began on August 14, 1990. OU #1 RA took place in three phases. The first phase of construction focused on the plume periphery extraction wells and associated piping and electrical connections, the second phase focused on the pretreatment system for the extracted groundwater, and the third phase centered on the installation of the Trench Area extraction wells and associated piping and electrical connections. Construction of OU #1 was completed in March 1996. Figure 4 shows the location of the OU# I RA components. Originally, the four PPES extraction wells were pumping at a combined average of 86 gallons per minute (gpm). In the second quarter of 1998, the average combined flow was reduced to 3 I gpm. The average combined pumping rate of the six Trench Area extraction wells is approximately 12 gpm. In January/February 2000, the PPES was shutdown to allow NSCC to conduct a hydrogeologic evaluation of this area. Currently, the PPES remains off!ine as the hydrogeologic evaluation continues. This evaluation is scheduled to be completed by April 2003. OU #2 was a no action ROD. The Agency sent NSCC a special notice letter in March 199 I to initiate negotiations on a CD. This CD governed the implementation of the OU #2 RA. The CD was signed in August 1991 and was entered by the Federal Court on July 20, 1992. OU #2 ROD required the monitoring of the Trench Area, placement of a deed restriction, and initiation of OU #3. OU #3 and OU #4 RA are being conducted under the same UAO, dated September 29, 1995. The OU #3 RA commenced on June 15, 1999 and was conducted in numerous phases. The first phase involved convening two existing deep bedrock monitoring wells (NS-49 and NS- 51) into extraction wells and installing the necessary piping and electrical connections. The • 19 Five.Year Review Repon Nalional S~ Chemical Company Supcrfund Site ~ September 2002 second phase involved the construction of a groundwater interception trench on the top of bedrock and the installation of the necessary piping and electrical connections. This trench is referred to as the "Collection Trench". The next phase, although not required by the ROD, involved the construction of a berrn around Area 2 and re-grading some areas in order that all surface water runoff following a storrn event can be collected. The collected runoff is now being piped to the facility's wastewater pretreatment system instead of being discharged into the Northeast Tributary. All of these discharge lines were strung above ground. NSCC then capped and grouted the terracotta discharge line running from Area 2 to wastewater pretreatment system. The last phase involved modifying the groundwater pretreatment system. Construction of OU #3 RA was completed on February 18, 2000. On average, the combined flow from the two bedrock extraction wells is 20 gpm and the extraction rate for the Collection Trench is 6 gpm. Figure 5 shows the location of the OU #3 components. OU #4 ROD includes a contingency. The preferred alternative involves conducting a "Biodegradati ve Study" to (I) substantiate that natural degradation of contaminants of concern in the soil is occuning in the OU #4 area, (2) identify where in the subsurface soils degradation is occuning, (3) deterrnine the rate of degradation, and ( 4) develop and implement a long-terrn monitoring plan to monitor the biodegradative process until the perforrnance standards have been achieved. In the event that the "Biodegradative Study" cannot substantiate the occurrence of significant natural degradation of 1,2-DCA and other contaminants of concern, or the study shows that degradation products increase the Site risk, the contingent remedy shall be implemented. The contingency remedy involves the construction and operation of a soil-vapor extraction system installed in the unsaturated zone. The extracted contaminated air from Area 2 will initially be treated using fume incineration to destroy the volatile organics prior to the air stream being released into the atmosphere. After concentrations of contaminants in the extracted air decreases, this contaminated vapor can be treated via vapor-phase activated carbon adsorption filters. The extracted contaminated air from the lagoon area will be treated using vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air stream being released into the atmosphere. The contaminants captured by the vapor-phase carbon filters will be destroyed through the therrnal regeneration of the used activated carbon at an off-site, commercial regeneration facility. Also included in OU #4 ROD is the implementation of two institutional controls: the placement of deed restrictions on this portion of the NSCC facility and maintenance of both the existing fence around the plant operations area and the paved areas around Area 2. Phase I of the OU #4 Natural Degradation Treatability Study was initiated in December 1996 and was completed in March 1998. The objectives of Phase I were to: • deterrnine if natural degradation of Site contaminants was occuning in the saprolite; • deterrnine if natural degradation can be enhanced through the addition of nutrients to the soils, and; • deterrnine where in the subsurface degradation is occuning.· • 20 Five-Year Review Repon National S. Chemical Company Superfund Site September 2002 The following were conclusions highlighted in the Phase I Natural Degradation Treatability Study for OU #4 Report, dated March 26, 1998: • Results of the. laboratory biotreatability study indicated: • relatively high numbers of viable indigenous microorganisms exist in Site soil samples where there are sufficient nutrients (nitrogen and phosphorous); • these indigenous soil microorganisms are able to degrade 1,2-DCA under both aerobic and anaerobic conditions with the addition of nitrate to the soil; and • little or no loss of 1,2-DCA occurred under either aerobic and anaerobic conditions in the absence of microorganisms. • Results of the field biotreatability study provided three observations and three lines of evidence of natural degradation of 1,2-DCA in unsaturated soils: • Observations: • Concentrations 1,2-DCA in soil varied over a large range both spatially and with depth; • Moisture content in the soil samples ranged from 20 to 30 percent; • pH of soil samples generally ranged between 5.79 to 8.73 and is suitable for microbial activity. • Evidence: • Mass reduction of 1,2-DCA occurred in the soils during this time-frame; • Presence of 1,2-DCA biodegradation daughter products; and • Favorable geochemical environmental conditions. Phase II was started in November 2001 and is anticipated to be completed in February 2007. This work is being conducted in accordance to the January 2000 Phase II Natural Degradation Treatability Study Work Plan. The primary objective of Phase II is substantiate biodegradation, collect sufficient data to establish a defensible degradation rate, and develop a long-term monitoring program. Figure 6 shows the distribution of the sampling points of the natural degradation treatability study. In response to the institutional control (i.e., deed restrictions) requirements included in both the OU #2 and OU #4 RODs, a plot map was prepared and the restrictions were filed with the Rowan County Register of Deeds Office on June 12, 1997. The description can be found in Book 9989, page 179. • 21 4.3 SYSTEM OPERATIONS/OPERATION AND MAINTENANCE Five-Year Review Repon Nalional s·· Chemical Company Supcrfund Sit.e Sept<mber 2002 NSCC and its consultant is conducting long-term monitoring and operation and maintenance (O&M) activities according to the current O&M manual, the "Combined OU #I & #3 Pretreatment System Operation & Maintenance Manual", dated April 2000. The primary activities associated with O&M include the following: • Inspection of the condition of groundwater monitoring wells; • Periodic environmental monitoring which includes the following activities: collecting samples from selected monitoring wells, extraction wells, the Collection Trench, the pretreatment system influent, the pretreatment system effluent, surface water/sediment from the Unnamed and Northeast Tributaries, soils, and measuring and recording groundwater levels and flow rates. The focus of the RAs implemented at the NSCC Superfund Site is to remediate groundwater and use a combination of natural flushing to wash the contaminants out of the soils and monitored natural attenuation to address the contamination in the soils. Those contaminants that migrate from the soil into the groundwater will be removed from the environment through the groundwater extractions systems. The yearly O&M cost for all four OUs is approximately $320,000. Currently, NSCC is re-evaluating the hydraulic control of the OU #I plume periphery extraction system. This was in response to detecting contaminants in a monitoring well, NS-31, on the opposite of the Unnamed Tributary. According to the conceptual groundwater model for the Site, this stream should be acting as a hydraulic barrier. This evaluation should be completed by April 2003. 5.0 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW This is the first Five-Year Review Report for the entire Site. A Five-Year Report for OU #1, prepared by the Agency, was completed on June 18, 1996. A Five-Year Review Report for OU #2, prepared by NSCC, was completed in August 1998. The 1996 Five-Year Review Report for OU #I concluded that insufficient data had been collected with regard to the OU #I RA to make a determination on the protectiveness of the remedy due to the recent completion of the construction activities. However, the report assumed that the installed remediation systems would be protective of human health and the environment. This· report recommended that the Site not be deleted from the NPL. The 1998 Five-Year Review Report for OU #2 made the following recommendations: reduce groundwater monitoring from quarterly to an annual basis, eliminate selected monitoring parameters for designated wells, and change the analytical method for VOCs. The Agency concurred with these recommendations. This report concluded that the OU #2 RA was protective of human health and the environment. •· LEGEND • M ONl TORING 'llr£1.L LOCATION ♦ EXTRACTION WEll. LOCATION • & SURF ACE WATER/SEDIMENT SAMPLE LOCATION • SCALE IN FEET " \ \ \ I I \ \ ' \ 22 COMPO!\'ENTS OF OPERABLE UNIT# I Five• Year Review Rcpor: • ionJl Starch & Chemical Company Supcrfund Sne September 2002 J I ( I \ I FIGURE 4 • 23 I COMPONEJ'ffS OF OPERABLE lJNIT #3 / \ \ I Five-Year Review Report • tional S1arch & Chemical Company Superfund Site Sep1embcr 2002 I I LEGEND • MONITORJNG WELL LOCATION ♦ EXTRACTION WEU. LOCATION .A SURFACE WATER/SEDIMENT SAMPL.£ LOCATION 0 SCALE IN FUT \ \ I I I ~ ~~-~ _;-----c--\ 7, FIGURES. • 24 I I Fi YC· Year Review k:por.. • tiona! Starch & Chemical Company Superfund Site September 2002 l I ... I \ I I \ .a. Sl.'lf•Cl ••n~,'SltJwf'"T S.-,[ ~ CRIO co,,, ""0.. _..,(.,: ~'. SO'. BCllbJoG ("'°"'-"'C" :tOJ ~ 5-7. ec-,.c fv-O,.wt•:t:iJ €) "°"'TOll""C. IIICl'. ' NATURAL DEGRADATION TREAT ABILITY STUDY PHASE 2 SAMPLrNG LOCATIONS FIGURE6 0 • 6.0 FIVE-YEAR REVIEW PROCESS 6.1 ADMINISTRATIVE COMPONENTS 25 Five-Year Review Rcpon National S~ Chemical Company Superfund Site '91" Sept.cmbcr 2002 NSCC was notified of the initiation of the five-year review on May 17, 200 I. The basis of this Five-Year Report was provided by NSCC in a document entitled, "Draft Final Five Year Review", dated August 200 I and the revised version dated March 2002. NCDENR assisted in the review of both of these NSCC documents as well as this document. Since NSCC's revised repo11 did not fulfill the requirements of EPA OSWER's Directive 9355.7-03B-P entitled, Comprehensive Five-Year Review Guidance, June 200 I, the Agency elected to finalize this Five- Year Review Report. 6.2 COMMUNITY INVOLVEMENT/COMMUNITY INTERVIEWS During the week of December 17, 2001, EPA contacted a number of citizens who live around the Site. Copies of the review questionnaires (with the names of the interviewees redacted) are included in Appendix A. All of the residents contacted have lived near the Site for at least 12 years. In general, none of the individuals contacted identified any problems/concerns with regard to the Superfund cleanup. A few of the residents voiced that they attributed an occasional odor from the NSCC facility. NSCC holds Community Advisory Panel group meetings on a bimonthly basis. Attendees at these meetings have included NSCC personnel, City of Salisbury Firemen, City of Salisbury Utilities, Rowan County Emergency Response members, residents of adjoining or nearby neighborhoods, Rescue Squad members, and others. Plant activities, including those undertaken to advance the remedial activities at the Site, are discussed during these meetings and questions or concerns that attendees raise at the meetings are addressed by the Community Advisory Panel coordinator at the facility. 6.3 DOCUMENT REVIEW This Five-Year Review involved a review of relevant documents including RDs, O&M Monthly Reports, monitoring data, etc. A list of documents reviewed in preparing this Five-Year Review Report can be found in Appendix B. 6.4 ARAR REVIEW One purpose of the Five-Year Review is to review federal and state regulations promulgated or modified since the issuance of a ROD to determine if any of these changes alter the established ARARs. As part of this review, the existing federal and state ARARs identified in the four RODs were compared to more recently promulgated ARARs. The following federal regulations were reviewed to determine the OU #I ARARs: • Clean Air Act (CAA); • Clean Water Act (CWA); • • Endangered Species Act (ESA); and • Safe Drinking Water Act (SDWA). 26 Five-Year Review Rcpon National S. Chemical Company Superfund Site September 2002 As documented in the OU #I ROD, no State groundwater standards were incorporated into the OU #I ROD. The OU #2 ROD was a no action ROD and therefore did not incorporate any performance standards. The OU #3 ROD considered the following federal and state regulations to be ARARs: • Federal Regulations: • Clean Air Act (CAA); • Clean Water Act (CW A): and • Safe Drinking Water Act (SDWA). • State Regulations: -North Carolina Air Quality Permit Procedures (NCAC Tl5A:2Q, August I, 1995); -North Carolina Air Pollution Control Requirements (NCAC Tl5A:2D, April I, 1995); -North Carolina Groundwater Classifications and Standards (NCAC Tl5A:2L, November 23, 1993); and -Classifications and Water Quality Standards Applicable to Surface Waters and Wetlands of North Carolina (NCAC Tl5A:2B, March 3, 1993), respectively. For OU #4 (as well as for OU #2), there were no federal or state ARARs that govern the remediation of the impacted soils present at the Site. The OU #4 soil performance standard for 1,2-DCA was based on protecting groundwater from 1,2-DCA leaching from the soils into the groundwater. Based on the computer modeling efforts conducted during OU #4, the concentration of 1,2-DCA that could be left in the soil without adversely impacting the underlying aquifer above the groundwater performance standard for 1,2-DCA was calculated to be I 69 µg/kg. The OU #I ROD identified 25 chemicals of concern (COC). The OU #I ARARs were based upon SDW A Maximum Contaminant Levels (MCLs), laboratory detection limits, Reference Doses (RrDs), and Acceptable Chronic Intake (AC!) concentrations. If a MCL was not available, the RrD or AC! concentration was specified as the performance standard. The OU #3 ROD identified 18 COC. When comparing between the MCL or the State groundwater standard, the most stringent standard was incorporated in the OU #3 ROD for each COC. All of the identified COC for each OU are listed in Table 3. Included in Table 3 for each COC is the performance standard (clean-up goal) and the basis for the performance standard. Newly promulgated or modified federal and state requirements evaluated included: • SDWA Maximum Contaminant Level (40 CFR 141); • North Carolina Air Quality Permit Requirements (NCAC Tl5A:2Q, August I, 1995): • North Carolina Air Quality Standards (NCAC Tl5A:2D, April I, 1995); • 27 Five-Year Review Report Nalional S. Chemical Company Superfund Site SepLCmber 2002 • North Carolina Groundwater Quality Standards and Classifications (NCAC T15A:02L.0200, November 23, 1993); and • North Carolina Water Quality Standards (NCAC Tl5A:2B, March 3, 1993); The newly promulgated or modified performance standards are listed in the second to last column in Table 3. The last column in Table 3 identifies t_he basis for each performance standard. As can be seen, a number of the newly promulgated ARARs are more stringent than the current ARARs. However, since CERCLA related work at this Site is anticipated to last for a minimum of another 20 years (e.g., the OU #4 ROD estimated that it would take 130 years to achieve the groundwater performance standard for 1,2-DCA), it would be more efficient use of time and effort to update the ARARs at a later date. This is a feasible approach as the exposure assumptions used in the Baseline Risk Assessment have not changed nor are they anticipated to change anytime in the near future. 6.5 DATAREVIEW The following section is based on the Agency's interpretation of its review of the historical analytical data for groundwater and surface water/sediment monitoring. The groundwater samples were collected from the extrnction wells and a select number of monitoring wells associated with OU #I and OU #3 as well as groundwater samples collected from the OU #3 Collection Trench. The surface water/sediment samples were collected from both the Unnamed and Northeast Tributaries. Groundwater monitoring has been conducted at the NSCC site since 1976. However, for the purpose of preparing this report only groundwater data collected as pan of the RA effort were reviewed. The following wells associated with OU# I (refer to Figure 4) were monitored on a quarterly basis from 1993 through I 998 and annually since I 999: • Plume Periphery Extraction Wells: EX-01, EX-02, EX-03, and EX-04; • Plume Periphery Monitoring Wells: NS-29, NS-30, NS-31, and NS-32; • Trench Area Extraction Wells: EX-05, EX-06, EX-07, EX-08, EX-09, and EX-JO; and • Tench Area Monitoring Wells: NS-9, NS-10, NS-I 1, and NS-15. The following wells associated with the OU #3 RA (refer to Figure 5) were monitored bi- annually between I 998 and 2000 and have been sampled annually since 2001: • Wells Assumed To Be Inside Zone of Hydraulic Control • Extraction Wells: NS-49 and NS-5 I • Monitoring Wells: NS-13, NS-14, NS-39, NS-40, NS-41, NS-42, NS-45, NS-46, NS-47, NS-48, NS-50, NS-52, NS-53, and NS-54 • Collection Trench (CT-I) • Wells Assumed To Be Outside Zone of Hydraulic Control • Monitoring Wells: NS-24, NS-35, NS-36, NS-37, NS-38, NS-43, and NS-44. • 28 Fi vc-Year Review Rcpon National S~ Chemical Company Superfund Site "9' September 2002 Tables 4 through 7 and Tables 8 through 11 present a compilation of historical analytical groundwater data for monitoring wells associated with the OU #I PPES and Trench Area system, respectively. Tables 12 and 13 provide historical analytical groundwater data for a number of wells and the Collection Trench which are associated with OU #3. As can be seen from the data in these tables, there is no clear, persistent downward trend in concentrations of organic contaminants in the groundwater in either OU. Contaminant levels in extraction wells EX-02 and EX-03 have shown some decrease in contaminant levels since the pumps in these wells have been turned off. However, this observation makes sense since these wells are no longer pulling contaminated groundwater towards themselves. Figures 7 and 8 show the groundwater elevation contours in the transition zone and bedrock zones for the OU# l area, respectively. These figures were for data collected in the fourth quarter of 1999 since the PPES wells were shut down in the first quarter of 2000. As can be seen, insufficient information is provided to confirm that the extraction systems are capturing the plume. Figures 9 and IO show the groundwater elevation contours in the saprolite/transition zone and. bedrock zones for the OU #3 area, respectively. These figures were for data collected in the third quarter of 2000. As with the previous figures, insufficient information is provided to confirm that the extraction system is capturing the entire plume, both laterally and vertically. Tables 14 and 15 present a compilation of historical analytical data for surface water/sediment samples in the Unnamed Tributary and the Northeast Tributary, respectively. Figures 11, 12, and 13 show the locations of all the surface water/sediment sampling locations on the Unnamed tributary. Figures 11, 12, 14, and 15 show the locations of all the surface water/sediment sampling locations on the Northeast Tributary. An ecological risk assessment of the Northeast Tributary was performed as part of the OU #3 baseline risk assessment. The potential impact to aquatic and benthic (bottom-dwelling) organisms in the Northeast Tributary was evaluated. 1,2-DCA is the primary ecological contaminant of concern in this tributary. To determine if there were any effects of 1,2-DCA on the benthic communities inhabiting the Northeast Tributary, a Rapid Bioassessment Protocol was conducted. The results indicated that segments of the tributary with historically elevated 1,2- DCA levels (portions of the stream adjacent to the plant operations area) were devoid of sensitive macrobenthic species and exhibited generally lower taxa richness and abundance than the reference station (i.e., upgradient of where 1,2-DCA enters into the stream). However, the benthic organisms in the referenced station were not dominated by species known to be tolerant of chemical stress. The ecological risk assessment concluded that due to the naturally-limiting factors associated with a headwater stream of this type, the ecological impacts resulting from the presence of 1,2-DCA in the Northeast Tributary could not be determined. Following the Rapid Bioassessment , chronic toxicity tests were performed on surface water and sediment samples to further examine the ecological impairments noted during the field assessment. Surface water tests were conducted using fathead minnows and water fleas, while amphipods and water fleas were used for sediment tests. The measurement endpoints (survival, growth, or reproduction) did not differ significantly between Site samples (containing elevated levels of 1,2-DCA) and reference or laboratory samples (containing little or no 1,2-DCA). These • 29 Five-Year Review Report National S~ Chemical Company Superfund Site 'W' September 2002 test results initially suggested that ecological impainnents observed in the Northeast Tributary resulted from natural stresses rather than the presence of 1,2-DCA or other chemical contaminants. However, chemical analysis of surface water samples collected at the same time and locations as those for the toxicity tests indicated that the level of 1,2-DCA in the sample collected adjacent to the Site (200 µgll, estimated value) had decreased below historic levels for that area (800-3200 µg/1) and was below the screening level (2000 µg/1) thought to be potentially toxic to aquatic organisms. Presently, no substantive link has been made between the presence of 1,2-DCA in the Northeast Tributary and the limited biodiversity in this stream as the area of the stream impacted by the Site is approximately 1,500 feet from the head-water of this stream. However, the RI report did conclude that the source of 1,2-DCA in the Northeast Tributary is the contaminated groundwater in the saprolite zone of the aquifer discharging into this stream. Since very high concentrations of 1,2-DCA (660,000 µg/1) have been found in the groundwater, the potential for discharge of groundwater contaminants above levels of ecological concern is possible. Hence it is necessary to institute long-tenn monitoring of the Northeast Tributary. 6.6 SITE INSPECTION The pre-final/final inspection of OU #3 RA was conducted on March 22, 2000 by EPA and NCDENR. During this visit to the Site the other OUs at the Site were also reviewed. The combined water treatment is successfully treating the extracted groundwater as well as the plant's effluent prior to being discharged to the City of Salisbury POTW. 7.0 TECHNICAL ASSESSMENT One of the primary purposes of the Five-Year Review is to determine the effectiveness and protectiveness of the remedies. Perthe Agency's Five-Year Review Guidance (June 2001), the review needs to address the following three questions: (A) ls(Are) the Remedy(ies) Functioning as Intended by the Decision Documents? (B) Are the Exposure Assumptions, Toxiciry Data, Cleanup Levels, and RAOs Used at the Time of Remedy Selection Still Valid? (C) Has Any Other Information Come to Light That Could Call Into Question the Protectiveness of the Remedy(iesj? For the NSCC Site, the assessment of the remedies and answers to these questions is accomplished by comparing Site data and operations to the original RAOs. As noted in Section 4.1, the groundwater RAOs can be generalized as: • 30 Five-Year Review Repon National S. Chemical Company Supcrfund Site September 2002 • To prevent further migration of the plumes (i.e., capture the plume through the extraction of groundwater), • To treat the extracted groundwater, and • To restore contaminated groundwater to levels protective of human health and the environment. This evaluation will assess the following: • the trends for the in situ groundwater monitoring well data (untreated) by comparing sampling data to the cleanup levels in the RODs • the effectiveness of the remedies in capturing the plume and restoring groundwater • the protectiveness of the current performance standards for groundwater and potential updates to ARARs and criteria since the issuance of the RODs. 7.1 QUESTION A: IS THE REMEDY FuNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? Based on Site visits and the review of documents, all remedies have been constructed in accordance to the appropriate ROD and RD. With the exception of the PPES, the Trench Area extraction system (OU#!), the two bedrock extraction wells (OU #3), and the Collection Trench (OU #3) are operating. Phase I of the Natural Degradation Treatability Study is complete and Phase Il is underway (OU #4). However, insufficient data is available to verify that the groundwater extraction systems for both OU #I and OU #3 have or will create a sufficient hydraulic capture zone to encompass the plumes emanating from the sources. The monitoring well networks for both OU #I and OU #3 are currently insufficient to make an accurate determination as to whether the extraction systems are effectively capturing or containing Site groundwater. No information is available to determine if the plume size is stable, is being reduced as a result of pumping and treating the groundwater, or is growing. Based on an analysis of the drawdown (groundwater contour Figures 7-10), it appears that there is some capture of the plume but not complete capture. This determination is critical to determine whether the remedies are functioning as intended by the RODs. Another RAO and measure of success is whether concentrations of Site contaminants in groundwater are decreasing to levels that are protective of human health and the environment, (i.e., are meeting the groundwater performance levels specified in the RODs). In general, although some contaminant levels in some wells have indicated a decrease, most groundwater concentrations in situ (prior to treatment) are still not meeting the groundwater performance standards set forth in the RODs. Furthermore, a number of the current groundwater ARARs are lower than the existing ROD levels. Thus, onsite groundwater would not currently be considered to be "restored" or protective of human health or the environment. 31 Fi\'e-Year Review RcpPl1 N:uional Starch & Chemical Company Superfund Sitt' Sep1ember 2002 TABLE 3 --PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS PERroRMANCE CONTAMINANTS STANDARD BASIS OF (BASED ON STANDARD OU #I ROD) PERFORMANCE STANDARD (BASED ON OU#3 ROD) BASIS OF STANDARD PERFORMANCE STANDARD (BASED ON OU#4ROD) BASIS OF STANDARD CURRENT ARAR BASIS OF STANDARD GROUNDWATER -VOLATILE ORGANIC COMPOUNDS Acetone 3,500 700 NCAC 15-2L zene 5 b NCAC 15-2L lt--B_ro_mod __ ic_h_lo_r_o_me_th_a_n_e_-+ ___ 5 __ ___,i---~--~--=0.:.:.5=----j---'C'-'R=L=-----1 (b) Chloroform 5 1.2-Dichloroethane 5 MCL 1,1-Dichloroethene 7 cis/trans-1,2-Dichloroethene cis-1,2-Dichloroethene trans-1,2-Dichloroethene 1,2-Dichloropropane 6 3,500 Tetrachloroethene Toluene I. 1.2-Trichloroethane 5 Trichloroethene 5 MCL 2.8 Vinyl Chloride 2 MCL CRQUState 0. I 9 NCAC 15-2L (b) CRQUState MCUState 0.38 70 70 0.56 29 5 0.7 1,000 5 2.8 0.015 NCAC 15-2L MCUNCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L MCUNCAC 15-2L MCL NCAC 15-2L NCAC 15-2L 32 Five-Year Review Rep<.nl Na1i1,11al Starch & Chemical Company Superfund Silt' September 2002 TABLE 3 --PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS CONTAMINANTS Xylene PElffORMANCE STANDARD (BASED ON OU #I ROD) 7,350 BASIS OF STANDARD CRQL PERFORMANCE STANDARD (BASED ON OU#3ROD) GROUNDWATER -SEMI-VOLATILE ORGANIC COMPOUNDS (2-Chloroethyl)ether Bis(2-ethylhexyl)phlhalate 4-Nitro henol GROUNDWATER· IN0RGANICS Antimon Arsenic IO Barium 1,000 Cadmium 10 Chromium 50 7,700 350 Selenium Thallium 2 Zinc 7,350 2,100 BASIS OF STANDARD MCL Stale PERFORMANCE STANDARD (BASED ON OU#4ROD) BASIS OF STANDARD CURRENT ARAR 530 0.31 3 5 6 IO 2,000 5 50 50 100 50 2 2.100 BASIS OF STANDARD NCAC 15-2L NCAC 15-2L NCAC 15-2L CR L MCL MCL NCAC 15-2L MCLINCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L MCLINCAC 15-2L MCL NCAC 15-2L Five-Year Review Rep(lrt Na1i11n:i.l Slan.'h & Chemical Company Superfund Sile September 2002 33 TABLE 3 --PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS PERFORMANCE CONTAMINANTS STANDARD BASIS OF (BASED ON STANDARD OU#I ROD) PERFORMANCE STANDARD (BASED ON OU#3ROD) SURFACE WATER· VOLATILE ORGANIC COMPOUNDS I ,2-Dichloroethane 2,000 SOIL VOLATILE ORGANIC COMPOUNDS BASIS OF STANDARD EPA, Region IV Chronic Screening Value PERFORMANCE STANDARD (BASED ON OU#4ROD) BASIS OF STANDARD Anticipated concentration 1ha1 will prmect underlying aquifer CURRENT ARAR I .2-Dichloroethane 169 µg/kg from being adversely .350 µg/kg impac1ed above the groundwater remediation goal All concentrations are in micrograms per liter (µg/1) or parts per billion (ppb) MCL --Maximum Concentration Limit as Specified in the Safe Drinking Water Act \'M --The risk levels are based on a 2 liter daily consumption rate by a 70 kilogram individual. CRQUState --Where the Maximum Allowable Concentration Of A Substance Is Less Than The Limit Of Detectability (NCAC 15-2L.0202(b)(I)) and where CRQL is the Contract Required Quantitation Limit CRQL --Contract Required Quantitation Limit State --State Groundwater Quality Standards (NCAC 15-2L.0202) Inactive Hazardous Sites Response Act of 1987 -(North Carolina General Statute J30A-3!0 et. seq.) BASIS OF STANDARD Inactive Hazardous Sites Response Act of1987 • Five-Year Review RL·pnr! N:11i\1nal Starch & Chcmil':tl ( 'nnlp:my Superfund Sitr Scplt·mher 2002 Ti\ f3 LI: 4 --HISTORICAL ANALYTICAL GROUNDWATER Di\ Ti\ FOR 1,2-DICHLOROETHi\NE FOR WELLS ASSOCIATED WITH TI-IE PLUME PERIPHERY SYSTEM OF OU #I. ROD PERl'ORMANCE STANDARD FOR 1,2-DICHLOROETHANE IS 5 micrograms/liter (,1g/l) SAMPLING SAMPLING LOCATION TIME EX-01 EX-02 EX-03 EX-04 NS-29 NS-30 NS-JI NS-32 IQ93 20 NS 2J 4J 110 79 J 100 5U 2Q93 5U 460 DJ 65 3 J 22 8 71 SU .1QIJ.1 10 U 511) DJ 611 SJ .1 J 56 49 10 ll 4Q93 10 lJ 3300 U 55 .I 10 U 3 J IOU 20 10 U I ()94 I[) u 2500 U 250 U 10 U lOU IO lJ 9J 10 U 2()94 5 \1 1700 U 120 U 5U 17 4 J 5 5U 3()94 5U 1200 U 50 U 5 3J .) u 4 J SU 4Q94 '.ill 550 J 93 U 3 J 4J SU 4J 5U IQ95 5U IOOO U .13 u 7 ·3 SU 250 U SU 2Q95 5 u 750 59 5 J7 5U 41 5U " 3Q95 3 J 570 10 J 17 U 69,0 5U 120 SU ·' •H)<J5 5 2500 U 61 62 U 3100 U SU 500 U 5U • 1()96 5U 1200 150 .I 4J 860 5U 250 U SU .. 2()% 4 J 590 42 25 U 300 SU IOOU 5U 3Q96 10 U 610 J 250 U 10 U 500 U JOU IOOOU IOU 4Q% 5 J 1.40 J 60 .I .1 J 1200 IOU 170 J 10 U I ()97 7.1 520 220 .I 5 J 760 3J 150 J IOU 2Q97 3.5 J 290 240 .I 6J 680 10 U 1000 U IOU 3Q97 10 U 690 200 .I 5 J 1900 JOU IOOOU IOU 4Q97 10 U 920 230.J 10 U 1700 IOU 1000 U 10 U .1()98 IOU 230 200 JOU 2300 IOU 260 IOU 2Q98 10 U 410 190 IOU 4200 SJ 2500 U IOU 3Q98 10 U 600 200 U SJ 2400J 42 J 1000 lJ IOU 4Q98 10 U 1000 200 U !OU 3600 58 l00 U 10 U 4Q99 Ill 880 9.1 Ill 3500 84 62 IU 4QOO I U 100 U 50 U I U IOOOU 50 U llOE I U IQ02 JU JU 0.96 J 0.7 J 100 U 2.8 100 I U ' NOTES: -All conccnlralions rcporied in micrograms/lilcr (µg/1) or pans per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit '•,:·,:· Five• Year Review Rcpnfl N:11it,11al Starl'h & Chcrnical Cnrnpany Supcrfund Silt' Scplcmher :WO.'. TABLE 5 --HISTORICAL ANALYTICAL GROUNDWATER DA TA FOR 1.2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ROD PERf'ORMANCE STANDARD FOR 1,2-DICHLOROPROPANE rs 6 micrograms/liter (pg/I) SAMPLING SAMPLING LOCATION TIME EX-01 EX-02 EX-03 EX-04 NS-29 NS-30 NS-31 NS-32 IQ93 JS NS 120 SU 350 D 190 170 SU 2Q93 41 820 DJ 180 SU 46.5 23 200 SU JQ93 10 U IOOODJ 150 IOU 51 97 SJ I J 4Q93 IOU 3300 U 170 U IOU IOU IOU 31 IOU IQ94 IOU 2500 U 250 U IOU IOU IOU IOU IOU 2()94 (, u 1600 .I 70 .I 6U 6U 6U 3 J 6U 3Q94 (, u 1200 J 44 J 6U 6U 6U 6U 6U 4()94 (, u 1200 SJ .I 6U 6U (, u (, u (, u IQ95 (,l) 670.l 40 U 6U 6U 6U JOO U 6 u 2Q95 6U 1300 160 6U 12 .I 6U so 6U 3()95 (,lJ 890 24 ' 26 1000 6U 260 (, u 4Q95 (, u 3000 U !JO 75 U 2200J 6U 340 .I 6U IQ96 SU 830 140 .I 5 u 1600 SU 250 LI 5 u 2Q96 SU 650 3J 25 LI 710 SU 94 J SU 3Q96 IOU 640J 87 J 2 J 1900 10 U 1000 U IOU 4Q96 I J lOOJ 71 J I J 1800 10 U 160 J IOU IQ97 7J 400 ISO J 7J 1200 ! 10 U 1000 U 10 U 2Q97 3 J 190 .J 240 J 17 980 IOU IOOOU 10 U .1Q97 2.1 460 2JOJ 7.1 2500 IOU 1000 U IOU 4Q97 10 U 730 310 21 2700 10 U 1000 U IOU IQ98 IOU 130 200 3 J 2700 IOU 170 J 10 U 2Q98 10 U 170 .I 235 IOU 3700 I 5 J 2500 U IOU 3Q98 IOU 360 1001 IOU 2100 68 1000 U IOU 4Q98 IOU 490 200 U IOU 2700 54 100 U tOU 4Q99 IU 810 30 IU 3l00 20 160 IU 4QOO IU IOOU 50 U IU 1000 U .50 U 180 E IU IQ02 IU !U IU IU IOOU IU 200 IU NOTES: i\11 concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) llold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit five-Year Review Reprnt N;it'1Pn:1I St:irch & Chemical Comr:iny Supcrfund Sitt' .Scplemhcr 2002 T/\13LE6 --HISTORIC/\L /\N/\L YTIC/\L GROUNDW /\TER D/\T/\ FOR METHYLENE CHLORIDE FOR WELLS /\SSOCI/\TED WITH THE PLUME PERIPHERY SYSTEM OF OU#! ROD PEIU'ORMANCESTANDARD FOR METHYLENE CHLORIDE IS 5 micrograms/liter (µg/1) SAMPLING SAMPLING LOCATION TIME EX-0 I EX-02 EX-03 EX-04 NS-29 NS-30 NS-31 NS-32 IQ93 2 BJ NS 2 BJ SU 3 BJ 48 BJ 3 BJ 2 IJJ 2Q93 I J 4J 2J 2 J 2J SU SU I J 3Q93 2 BJ JOU IOU 5 BJ 2 BJ 2 BJ 2 BJ I J 4Q93 NR NR NR NR NR NR NR NR IQ94 NR NR NR NR NR NR NR NR 2Q94 SU 1700 U 120U SU SU SU SU SU 3Q94 911 2900 II 11011 7 II 813 8 B 9 II 9 ll 4Q94 5U 1200 II 150 II 6 ll 78 SU . 6 II 9 B IQ95 5U 1300 II 37 II 3 IJJ 3 BJ SU 200 BJ 4 !JJ 2Q9S 3U 44 II 41 BJ 7 B 13 B IO B 16 B II lJ 3Q95 SU 250 U 17 U 17 U 250 U SU 32 U SU 4Q95 SU 2500 U 72 B 62 U 3100 U 5U 480 !JJ SU IQ% 2 BJ 150 BJ 160 BJ 2 BJ 150 BJ 2 BJ 71 BJ 2 !JJ 2Q96 I IJJ IJJ 25 U 5 !JJ 50 U SU 21 J 5U 3Q96 IOU 620 J 140 J 41 2200 IOU 3IOJ IOU 4Q96 0.(, J 74J 16 J I J 37 .I 0.6 J 110 J 0.7 J IQ97 IOU 250 U 250 U IOU 500 U IOU 1600 B 3 J 2Q97 IOU 250 U 250 U IOU 500 U IOU IOOOU IOU 3Q97 IOU 250 U 250 U IOU 500 U IOU IOOOU IOU 4Q97 IOU 40J 40 .I 10 U 89 J IOU 160 J 10 U .IQ98 IOU 50 U !DOU IOU 500 U IOU 250 U IOU 2Q98 IOU 250 U JOO U IOU 500 U IOU 2500 U IOU 3Q98 IOU 100 U 110 J IOU IIOO J I 2 J IOOOU IOU 4Q98 IOU 9J 200 U IOU 250 U IOU JOO U IOU 4Q99 JU 7.5 L JU JU 14 L I IU IU JU 4QOO JU 300 BD 160 !JI) JU 2000 !JD 38 JBD JU IU IQ02 2U 2U 2U 2U 200U 2U ·100 U 2U NOTES: All concentrations reported in micrograms/liter (pg/I) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard I NS -Not Sampled NR -Not Reported U -Nol detected at indicated concentration L -Common laboratory conlaminant D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit IJ -Compound detected in associated method blank Fivt:-Yl'ar Hcvicw lfrpon Na!irn1:1I Stard1 & Chemkal ( ·umpany Su pet fund ~ill' Seplc-mht·r 200! TAl3LE 7 --HISTORICAL ANALYTICAL GROUNDWATER DATA f'OR BIS(2-CI-!LOROETHYL)ETHER FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ROD PERf-ORMANCE STANDARD f-OR B1s(2-CIILOROETHYL)ETHER IS 5 micrograms/liter (pg/I) SAMPLING SAMPLING LOCATION TIME EX-01 EX-02 EX-03 EX-04 NS-29 (NS-30 NS-31 NS-32 IQ93 38 NS 8Z 12 190 44 71 IOU 2Q93 4 J 380 D 100 5 J 52 ' 32 95 10 U 3Q93 II U 540 D IOU II ZS 10 U 38 IOU 4Q93 II U 440 74 53 U 18 10 .J 25 II U IQ94 10 U 510 150 D 22 J 8 I 41 24 II U 2Q94 II U 770 120 17 .I 12 29 20 IOU 3Q94 6U 680 56 13J 12 17 21 5U 4Q94 5U 570 110 21 J 17 21 14 SU IQ95 YU 540 130 14 .I 13 17.5 II 5U 2Q95 3 J 650 180 lJ 55 32 16 78 5U 3Q95 14 570 120 64 450 12 130 6U 4Q95 11 570 140 41 1100 10 320 370 1()% 9,J 400 IJO 10 590 D 5 J 72 IOU 2Q% 7,J 500 E 93 71 250 7J 160 10 U 3Q96 10 U 430 170 48 1400 D 7J 380 10 U 4Q% 17 320 D !JO 49 740 4 J 200 D 10 U IQ97 31 490 D 180 68 D 810 IO .I 540 D IOU 2Q97 21 . 250 D 180 74 I) 410 7 .I 390 D IOU 3Q97 24 310 I) 210 D 68 D 1400 D 8.1 21 lJ 650 D 4Q97 17 43 260 D 47 D 1400 D 10 lJ 19 560 D IQ98 46 180 ll 350 I) 94 ll 2400 D 9J 1500 ll 10 lJ 2Q98 14 140 D 195 D 28 3100 D 21 2700 D 10 lJ 3Q98 23 :noo 230 I) 26.5 100 U 23 2400 n IOU 4Q98 34 850 D 10 lJ 58 D 3600 D 37 2200 D IOU 4Q99 20 1300 310 SI 3800 57 160 10 lJ 4QOO 2U l700E 1100 IJ I 7100 D IOOO D 2U 52 lJ IQ02 IOU 730 600 2.6 J 9900 150 81 10 U NOTES: All concentrations reported in micrograms/liter (/,g/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit Fi vc-Year Review Rep(1rl Natil,11:il Slan:h & Clwmi~·al Company SupcrfumJ .Si!r Seplcnihrr 2002 TAU LE 8 --HISTORICAL ANALYTICAL GROUNDWATER DATE FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #I ROD PERl'ORMANCE STANDARD FOR 1,2-Drcrn,OROETHANE IS 5 micrograms/liter (µgll) SAMPLING SAMPLING LOCATION TIME EX-05 EX-06 EX-07 EX-08 EX-09 EX-10 NS-09 NS-10 NS-I I NS-15 IQ93 NS NS NS NS NS NS NS NS NS NS 2Q93 NS NS NS NS NS NS 10000 D 16000 D 5ll NR 3Q93 NS NS NS NS NS NS 14000 D 8000 IJ JOO 440 D 4Q93 NS NS NS NS NS NS 4700 2800 25 ll SJO 1()94 NS NS NS NS NS NS 170 8800 500 U 480 2Q9,t NS NS NS NS NS NS 3100 U 9700 8 400 3Q94 NS NS NS NS NS NS 8300 l/ 7100 5l/ 380 4Q94 NS NS NS NS NS NS 10000 ~ 420 5 l/ 380 E IQ'J5 NS NS NS NS NS NS J 9100 SU 370 2Q')5 NS NS NS NS NS NS 500 U 9800 5 l/ 330 D 3()95 NS NS NS NS NS NS II 7600 6 250 D 4Q95 NS NS NS NS NS NS 1700 8100 5 260 IQ96 NS NS NS NS NS NS l" 6100 9 250 2()96 350000 IJ 920 83000 D 330000 D 710001) 28000 D 40 4 I 00 E SU 210 E JQ% 5000 U 10 U 3300 ll 5000 l/ 3300 U 1700 U 2100 D 2200 n II 67 4Q9G 430000 IJ 240 D 50000 D 350000 D 190000 D 35000 7100 D 4500 D 34 ISO IQ97 5 I 0000 D SJ 34000 D 390000 IJ !80000 D 31000 10000 D 2000 n 400 D 190 2Q97 470000 I) SJO D 35000 D 290000 D 130000 D 30000 4400 D 870 31 120 JQ97 340000 D 550 D 36000 D 310000 Il 160000 D 53000 4900 D 1800 170 D 160 D 4Q97 380000 IJ 140 27000 D 270000 D 130000 D 59000 5900 D 1600 260 D 160 .Q98 340000 D 80 19000 220000 D 110000 D 44000 D 10000 Il 9201) 24 JOO Q98 340000 D 550 100 U 220000 Il 85000 D 290001) 25000 1900 D 41 130 JQ98 230000 I) 120 140000 D 210000 D 79000 D 39000 25000 D 12001) 15 20 4()98 300000 I) 12 130000 D 180000 D 71000 D 36000 D 17000 D 460 D 15 98 4Q99 400000 IU 500 U 180000 IOOOOO 25000 21000 330 IU 69 4QOO 530000 D IU 180 D 190000 D 160000 D 40000 D 550 D 13 2 ll 76 D IQ02 390000 IU 270 190000 91000 14000 1400' 13 JU 27 NOTES: i\11 concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit TABLE 9 -- SAMPLING TIME IQ93 2Q9) 3()93 4()9) I ()94 2Q94 )()94 4()94 IQ95 2Q95 )Q95 4Q95 IQ% 2Q96 3Q96 4Q96 IQ97 2Q97 3Q97 4Q97 IQ98 2Q98 3Q98 4Q98 4Q99 4()00 1()02 NOTES: Fiv1,.•-Yea, Rc,·il'W Report National S1arch & Chemic:it Company Supe1fund Sile September 2002 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OFOU #I ROD PERf-ORMANCE STANDARD f-OR I ,2-D!CHLOROPROPANE IS 5 micrograms/liter (µg/1) SAMPLING LOCATION EX-05 EX-06 EX-07 EX-08 EX-09 EX-IO NS-09 NS-IO NS-I I NS-IS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS SU 2 J 5 U NS NS NS NS NS NS NS 10 U I J 10 U 2 J NS NS NS NS NS NS 250 U 330 U 25 U 67 U NS NS NS NS NS NS 10 U 500 U 500 U 50 U NS NS NS NS NS NS 3800 U 380 U 6 U 15 U NS NS NS NS NS NS 10000 U 400 U 6 U JOU NS NS NS NS NS NS 12000 U 20 LI 6 lJ 6U NS NS NS NS NS NS 6U 380 LI 6U 15 U NS NS NS NS NS NS 600 U !IOU 6U 6U NS NS NS NS NS NS 6 LI 100 U 6 U 6U NS NS NS NS NS NS 68 U 400 U 6 U IOU NS NS NS NS NS NS 10 U 250 U SU IOU 350 25 U l20U 530 9400 D 82000 D 50 U 50 U SU SU 5000 lJ 10 lJ 3300 U 5000 U 12000 81000 D 50 U 10 U IOU IOU 250 .I IOU 250 U 5000 U 11000 78000 I00U 100 U IOU 10 U 2000 U 10 U 250 U 5000 U 12000 68000 100 U 100 U IOU IOU 2000 U 10 lJ 250 U 5000 U 9100 56000 100 U I00U IOU IOU 2U00U 10 U 250 U 5000 U 11000 60000 100 U 100 U IOU IOU 2000 U 10 U 250 U 1000 .I 12000 75000 100 U 100 U 10 U IOU 5000 U 10 U 1000 U 1200 .I 12000 41000 D 100 U 10 U IOU 10 U 5000 U IOU I00U 2800 13000 44000 D I00U 20 U IOU 10 U 5000 U IOU 88 J 3100 14000 54000 500 U IOU 10 U IOU 2500 U IOU 1000 U 3600 15000 42000 D 100 U 10 U 10 U 10 U 500 U IU 500 U 2700 13000 22000 2 IU IU 1.5 5000 U Ill SU 1500 JD 16000 D 31000 D IOU I 2U 10 U 3000 U Ill IOU 23001 6400 11000 0.53 J Ill IU I ll All concentrations reported in micrograms/liler (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected al indicated concenlralion D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the repo11ing limit Fi 1·t•-Yt·;u R1'1·ic:w Rl'plltl N:itinn:il St:irch & Chcrnic:11 Cump;111y Supc:1fun<l Sifl' Seplemher .:!001 TAIJLE IO --IIISTORICAL ANALYTICAL GROUNDWATER DATA roR TOLUENE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU 111 ROD PERFORMANCE STANDARD FOR TOLUENE IS 2,000 micrograms/liter (µg/1) SAMPLING SAMPLING LOCATION TIME EX-05 EX-06 EX-07 EX-08 EX-09 EX-10 NS-09 NS-10 NS-I I NS-15 IQ93 NS NS NS NS NS NS NS NS NS NS 2Q93 NS NS NS NS NS NS 400 D 21 61 NR 3Q9) NS NS NS NS NS NS 1100 D 17 59 23 4Q9) NS NS NS NS NS NS 330 330 U 120 18 J IQ94 NS NS NS NS NS NS 100 500 U 500 U 50 U 2()94 NS NS NS NS NS NS 6200 U 620 U 7J 13 J 3()94 NS NS NS NS NS NS 17000 U 670 U 13 171 4Q94 NS NS NS NS NS NS 20000 U 33U 61 10 IQ95 NS NS NS NS NS NS 47 620 U 23 10 J 2()95 NS NS NS NS NS NS 340 J 180 U II BJ 3Q95 NS NS NS NS NS NS 130 170 U 15 51 4Q95 NS NS NS NS NS NS 410 670 U 61 91 IQ% NS NS NS NS NS NS 180 250 U 6 II 2Q96 I 6111111 I> 74 3200 68000 D 38000 D 14000 D 170 50 U 11 15 3Q96 19000 67 2200 J 28000 29000 15000 69 41 12 2 l 4Q96 20000 65 1700 25000 28000 15000 200 91 19 61 IQ97 24000 42 1600 30000 28000 16000 100 U 100 U 28 5 J 2Q97 23000 37 1200 24000 20000 12000 80 J 100 U 5 1 41 )Q97 22000 82 1100 25000 23000 12000 150 100 U 7 1 10 .Q97 21000 43 I 100 26000 22000 14000 110 100 U 29 8 J IQ98 210110 40 820 J 24000 21000 D 9000 30 J 10 U 91 3 1 2Q98 14000 75 56 J 20000 15000 7600 76 J 5 1 61 71 3Q98 13000 48 6800 22000 D 18000 l0000 500 U 5 1 10 IOU 4Q98 14000 31 6600 20000 18000 9000 29 J 10 28 2 l 4Q99 24000 D IU 500 U 34000 31000 5000 54 E JU 3.3 2.6 4QOO 510001) IU 120D 26000 D 65000 D 9500 D 110D I 61) 13 D IQ02 26000 IU 48 171100 30000 2900 150 I lJ 1.4 0.771 NOTES: All concentrations rerorted in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Pe1formancc Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a sccondarv dilution range E -Estimated concentration exceeds the calibration limit J -cslirnatcd concentration is less than the reporting li111i1 TABLE 11 -- SAMPLING TIME IQ93 2Q93 3Q93 4Q93 IQ94 2Q94 3Q94 4Q9•1 IQ95 2(.)95 3Q95 4Q95 IQ% 2Q% 3Q% 4Q96 IQ97 2(.)97 3Q97 4Q97 IQ98 2Q98 3Q98 4Q98 4Q99 4Q00 1(.)02 NOTES: Five-Year Rc\'iew l{t'potl Na!it111al Starch & Chcmic:il Company Superfund Site September 2001 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR BIS(2-CHLOROETI-IYL)ETHER FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU# I ROD PERf-ORMANCE STANDARD r:OR B1s(2-CHLOROETHYL)ETHER IS 5 micrograms/liter (µg/1) SAMPLING LOCATION EX-05 EX-06 EX-07 EX-08 EX-09 EX-10 NS-09 NS-10 NS-I I NS-15 NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS IOU II U II U II U NS NS NS NS NS NS 66 u 10 U 10 U 10 U NS NS NS NS NS NS 5 0 U 50 U to u 42 U NS NS NS NS NS NS BJ 220 U 10 U IOU NS NS NS NS NS NS 20U 1100 U II U 22 U NS NS NS NS NS NS 6U t 10 U SU 2t U NS NS NS NS NS NS ti u 22 U SU IOU NS NS NS NS NS NS I 53 U 520 U SU II U NS NS NS NS NS NS 27 U 250 U SU 6U NS NS NS NS NS NS 28 U 310ll 6U SU NS NS NS NS NS NS 50 U 260 U 5U 5U NS NS NS NS NS · NS IOU 500 U IOU !OU 2500 U 100 l/ 200 U 320 .I 10000 35000 50 U 200 U 50 l/ 50 U 5000 U 4 1 I00U 5000 U NR 47000 50 U 200 LI IOU 20 U 170 .I 16 100 U 2500 U 6600 29000 20 U 100 LI 10 U !OU 530 U 10 U 100 U 210 7200 29000 10 U 10 U IOU 10 U 110 U 10 U 100 U 390 3800 D 14000 20 U 100 U 10 U 10 U 500 l/ 10 U 110 U 620 7500 30000 20 U IOU IOU 10 U 55 .I IOU 18 .I 810 7400 D 16000 21 11 U II U 10 U 53 U IOU 14 J 1100 10000 D 68000 II U 10 U 10 U II U 110 U II U II U 1900 7100 D 23000 3 l 10 U II U IOU 110 U 10 U 990 D 1400 6200 D 15000 21 IOU IOU IOU 120 J IOU I00U 2900 18000 D 14000 21 IOU 2 1 II U 200 U IO U 10 U 200 U 500 U 11000 1.0 U IOU IOU 10 U 2(,0 U 51 U 51 U 51 U 2600 U 510 ED 51 U NA 51 U 52 U 600 U 10 U IOU 1800 2900 4800 10 U IOU IOU !OU . All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit TABLE 12 -- SAMPUN(i TIME 2Q98 3Q98 3Q99 .QOO ()00 IQ0I JQ02 NOTES: r-i\'e-Year Review Report National Starch & Chemical Company Superfund Sile September 2002 1 IISTORICAL ANALYTICAL GROUNDWATER DATA POR l ,2-D!CHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 ROD l'ElffORMANCE STANJJAl<ll fOR 1,2-DICIILOROETIIANE IS 5 micrograms/liter (µg/1) SAMPLING LOCATION NS-13 NS-14 NS-24 NS-35 NS-36 NS-37 NS-38 NS-39 NS-40 NS-41 NS-42 NS-41 JO00U IOU NS 2500 U 500U JOU JOU 250 U 2000 U 5000 U 2500 U IOU NS NS NS 100 U JOU NS IOU IOU 50 U NS 500 U 10 U 76 5U 5U 40000 52000 5U 5U 270 92000 84 92000 SU NS NS JU 41000D 60000 IU I lJ NS NS NS NS JU I 011110 I) 51 D 5U 170001) 63000 I) SU 5 lJ 19 84000 D DO 32000 D SU NS NS 21 5000 D 1.10000 D I lJ 5 lJ NS NS NS NS JU 0.5.1 J NS I U 6700 39000 JU JU 46 73000 .16 I I() JU All concentrations reported in micrograms/liter (11g/l) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estim,ited concentration is less than the reporting limit TABLE I J --HISTORICAL ANALYTICAL GROUNDWATER DATA POR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 ROD l'EHfORMANCE STANDARD roR 1,2-DtCIILOROETIIANE IS 5 micrograms/liter (pg/I) ,11'I.INO SAMPLING LOCATION IMI' NS-44 NS-45 NS-46 NS-47 NS-48 NS-49 NS-50 NS-51 NS-52 NS-SJ NS-54 CT-I 2Q98 10 U JOO U IOU 10000 lJ 250 lJ 2500 U 2500 U 1000 lJ 2500 U 2500 lJ 500 U NS 3Q98 NS 20 U NS NS NS NS NS NS NS NS NS NS 3Q99 SU 3100 18 310000 67 15000 29000 290000 13000 IJOOO 31000 SU JQ00 JU NS NS NS NS 34000 NS 410000 NS NS NS 8.1 JQ00 5 lJ 190 3000 D 260000 D 18 32000 D 4500 92000 D 2000 D 2000 D 72000 2 J IQ0I JU NS NS NS NS 22000 D 160000 D NS NS NS 78000 D 25 IQ02 I lJ 3.3 12 180000 3.2 ·7500 390 38000 82 82 69000 2 NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Ncit detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J ~ estimated concentration is less than the reporting limit Five• Year Review Rcprnt Naliuu;il Starch & Chemical Company Supcrfuml .Silt' Septemhcr 2002 ~BLE 14 --1-IISTORICAL ANALYTICAL SURFACE WATER/SEDIMENT DATA FOR THE UNNAMED TR113UTARY ltll' DATE OF SAMPLING EVENT MARCIi 1987 CONTAMINANTS Acetone 13 i s(2-el h yl hex yl )phtha I ale 13 utylbenzylphthalale NOTES: LOCATION OF SAMPLE SURl'ACE WATER SW-3 SW-4 ND ND ND ND ND SW-6 SE-3 ND ND ND 3200 ND 1800 SEDIMENT SE-4 SE-6 42 50 3400 2700 1500 1000 SW/UT --Surface Water Sample/Concentrations reprn1ed in micrograms per liter (µg/1) or parts per billion (ppb) SE --Sediment Sample/Concentrations reported in micrograms per kilogram (µg/kg) or parts per billion (ppb) ND --Nut Detected JUNE 2000 SURPACE WATER UT-2 UT-4 UT-5 Ill U IOU 10 U 10 U 10 U 10 U IOU 10 U five-Year Review Rcrtin Na1iP11:il S1arch & (.'ht·rnii:al C1m1p:i.ny Supc1fu11d Silt' Sep1emht·r 2m)2 Ti\BLE 15 --l-IISTOR!Ci\L i\Ni\LYT!Ci\L DAT!\ fOR 1,2-DICHLOROETHANE IN SURFACE WATER/SEDIMENT SAMPLING OF THE NORTHEAST TRIBUTARY SAMl'I.E NUMIIEI<" MARCIi 1987 JllNE 1987 0c-r.,Nov. JULY 1990 JUNE 1991 MAY 1992 JUNE!992 JANU,\RY 1993 !999Q3 2000Q3 1969 SW-I/SE-I 1,400/ I 8" ... ··-------... ·--... ... ---SW-2/SE-2 ND/ND -·----··----------------... SW-5/SE-5 ND/ND ... ---... ---··----... . .. ---NS-WI/SI ... ND/ND ·------·----... ... ... . .. NS-W2/S2 ---ND/ND ... ---... ---··----. .. ... NS-W3/S3 ... ND/ND ---··--·· --------· --· ··-NS-W4/S4 ... 4,400 J/3 ,400 J ... ... ---. .. ··-. .. ---... SIV/SE-09 ... ---350nG IG0/980 77/23 150 J/9 J ... . .. s un.7 u 19n u SIV/SE-10 ... -·· 1.200/14 !,GOO/ND 8I0/310 1,300 J/GIO D --· ... s un.4 u IGOn U SIV/SE-11 ... . .. ND/ND ND/ND ND/ND ND/ND ---... 5 U/23 U 5 U/12 U SIV-12/\ ... ... ··-------... ND ... --· . .. (Backeroun<l) SIV/SE-12 ... --· ---NS/ND NS/ND 2 J/ND --· ND/ND ... ---(llackground) .IV/SE-13 ... ------880/3,400 1,80017,400 3,200 D/290 ---200 J/1,200 D 10n.4 u 3 JIG U S\V/SE-14 ... ... ---i,700/1,200 I ,200/4,200 590 D/l ,000 D ----SW/SE-I 5 ... ------ND/ND ND/ND ... ---... S\V/SE-1(, ---... ---··----1,300 DJ/61 ---··- NOTES: Concentration for surface winer s.imples are in micrograms per liter (pg/I) or parts per billion (ppb) Concentration for sediment samples are in rnicrngr:nns per kilogram (11g!kg) or pans per billion (ppb) " S\V/SE-surface water/sediment; NS~\V/S -surface wa1er/scdirncnt " Firs! value represents conccnlration of l .2-DCA in surface water/Second value represents concentration org .2-DCt\ in sedir11c111 IJ -Concentration reported from secondary dilution J -Conccntr:ition i.s estim:ited NI -Analyzed for 11111 not detected NS . Not sampled (no water available) lJ Undetected at the indic.ited quantitation limil LEGEND • MONITORINC WELL LOCA TlON ♦ 0:TRACTION 'lll(LL LOCATION ~ STREAM CAUC( LOCA TlON ( 7 4 9. 4 8) GROUND-We 1ER El[" TION ----------GROUND-WATER ELEVATION CONTOUR (DASHED '#HERE INFERRED) -- SCAl.( IN FUT • • ,_, / Five-Year ReYiew f<epon • ional Starch & Chemical Company Superfund Site September 2002 \ \ " \ \ GROlJ1,rDWATER ELEVATION CONTOUR MAP FOR OU #1/OU #2 TRANSITION ZONE WELLS FOURTH QUARTER 1999 FIGURE 7 ~ • MONITORING Yltll LOCATION ♦ EXTRACTION WELL LOCATION S STR[AM CAUC( LOCATION ( 7 I 4. 2 0) CROIJNO-WA TER El.EVA TION .---, GROUND-WATER ELEVATION CONTOUR (0-'SHEO 'M-lERE INFERRED) • ·-• SCAU IN FUT - \ • / • · Fivc-Yc.ir Review Report tional S1arch & Chemical Company Superfund Site September 2002 GROUNDWATER ELEVA TJON COJ\.'TOUR MAP FOR OU# I/OU #2 BEDROCK WELLS FOURTH_ QUARTER 1999 FIGURE 8 I I I I I / • Five. Year Review Rcpon • ional S1arch & Chemical Company Superfund Site September 2002 LEGEND • MONITORING W[LL LOCATION ♦ EXTRACTION WELL LOCATION A SURfACE WATER/SEDIMENT SAMPLE LOCAT10N CROUNOWA TER ELEVATION GROUNOWA TER ELEVATION CONTOUR (DASHED 'M-IER[ INFERRED) -0 -..,, SCAl.£ IN fEET GROUNDWATER ELEVATION COJ,ffOUR MAP FOR OU #3 SAPROLITEITRANSITION ZONE WELLS -THIRD QUARTER 2000 FIGURE 9 I I I I I I y I )1 I I / / • / • F1\tc• Year Review Repon tional Starch & Chemical Company Superfund Sile September 2002 LEGEND • MONITORING 'lttll LOO, TION ♦ EXTRACTION WELL LOCATION & suRrACE WAITR/S(DIMENT SAMPLE LOCATION ""' 0 ""' SCAL.£ IN f'IET GROl.J1'1)W ATER ELEVATION COl\'TOUR MAP FOR OU #3 BEDROCK WELLS - THIRD QUARTER 2000 FIGURE JO • F1ve• YcJr krvu: ... ~epon • ional Starch & Chemical Company Superfund Site September 2002 -----··-::::--~---- I .....__. --,,,..,-/ i..:..... '· I SURFACE WATER SAMPLING LOCATIONS FOR MARCH 1987 FIGURE 11 • Five-Ye.ir Rcvicv. Report • tiona! S1arch & Chemical Company Supcrfund Sire September 2002 --··· ::::-------. SURFACE WATER SAMPLING LOCATIONS FOR MARCH 1987 · FIGURE 11 '.> ~-.----. . . ; ... ·:. --,.. \. / I. • ct:lor.J.d• 6.5 uq/Kg SEDIMENT SAMPLING LOCATIONS FOR MARCH 1987 Five-Year Review Rcpon • tion:il Starch & Chemical Company Superfund Site Seplembcr 2002 --.::: FIGURE 12 i ' / Five-Year kevic.,., P.cpor: • tional Starch & ChcITUcal Company Supcrfund Site September :!002 LEGEND • MONITORING WEU. LOCA TlOO ♦ EXTRACTION WEU. LOCATION 4 APPROXIUAT[ LOCATION or SURfAC[ WA TER/S[DIMENT SAMPLING LOCA, TlON 6-APPROXIMATE LOCATION OF STREAM GI.JAG( LOCA TIO,., 0 llffi[ ACRES TRAILER PARK DOMESTIC WEU. LOO, TION Jl.J:,.,c 2000 SURFACE WATER/SEDIMENT SAMPLL"JG LOCATIONS ON UNNAMED TRIBUTARY 0 SCALC IN rtET FIGURE 13 N ---- I NATIONAL STARCH PROPERTY UNE • ------------ Five• Yc:ar Review Report • :uional Starch & Chcmic:il Company Supcrfund 5·11c: September 2002 AIRPORT ROAD \ o· , 000' 2000· Sc:AU: APPROXlUA TE Ji'ff 19S7 SURFACE WATER/SEDIMENT SAJ\1PLING LOCATIONS ON NORTHEAST TRIBUTARY FIGURE 14 N 150 - N 550 - N250 ,- 1 l -050 • ABANDONED RAILROAD SPUR ' ' '' '' P~ LOT ---..: AREA2 ·-· .... -----. [] LAGOON OGDON 1 2 ~ E -l50 CHAIN LINK FENCE-----...._~ I E 250 Five-Ye:.ir Rc:vicv. Report • 1ional St.iri:h & Chemical Company Superfund Site September 2001 SW/SE-10 I I i SW/SE-16 I • I SW/SE-13 -----.. I """"OIOW.TE SCALE ill) ' 100 :ao0 JOO C10 100 :::URREl\'T SURFACE W ATER/SEDLT\1ENT SAMPLING LOCATIONS ON NORTHEAST ,TRIBUTARY FJGURE 15 • ~· .~ Five-Year Review Rcpon ~ National S. Chemical Company Superfund Site g September 2002 ] .,.. The institutional controls that are in place include deed recordation to inform any potential > f}l,lure guY,er of th;property rf th.Ci-yO\jtain_i1]at~op..r.r~f.ent,afithe Site. Howev.er, Jhe. deed :;;;r~l!lrMM?8A ~~&/\t~ltffsD/i1.§f rilE!tot1ie~'llh-~ilPl1!q1Iife\Hbnntslio~eral Statute UUA-3 lU et. seq.), "' as amended, or the associated Guidelines for Assessment and Cleanup (NCDENR, Inactive Hazardous Sites Program, 2001 ). This deed recordation was included on the description of the property on June 12, 1997. The fence around the plant operations area which limits access to the contaminated areas has been maintain. All cracks, seams, and other points of infiltration through paved and built-up areas has been maintained. In summary, the answer to question (A) ls(Are) the Remedy(ies) Functioning as Intended by the Decision Documents? is No. 7.2 QUESTIONS B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES USED AT THE TIME OF THE REMEDY STILL VALID? Overall, the exposure assumptions, toxicity data, cleanup levels, and RAOs included in the RODs are still valid. The plant remains an active facility and there is no indication that this status will change anytime in the near future (i.e, within the next five years). Access to the active part of the facility is controlled via a six-foot chain linked security fence. The exposure assumptions used in all four RODs to develop the Human Health Risk Assessment were basically the same. They included current and future exposure of workers on- site under a industrial scenario and secondly, the property being transformed into a residential area in the future. Although there has been no change in the potential future use exposure scenarios, the assumptions and processes used to develop the Human Health Risk Assessment have changed over time. Some of the toxicity factors for the chemicals of concern have changed as new data becomes available. The toxicities for some of the chemicals have either increased or decreased but the over all impact to the Baseline Risk Assessments is negligible. This is especially true due to the conservative methodology of the risk assessment process. As stated earlier, some of the ARARs have changed since the issuance of the RODs but there is no need at this time to initiate modifications to the RODs to integrate these new ARARs as remediation efforts at this Site will continue for at least 20 years. The RAOs remain acceptable for the Site at this time. In summary, the answer to question (B) A.re rhe Exposure Assumptions, Toxicity Dara, Cleanup Levels, and RAOs Used ar rhe Time of Remedy Selecrion Sri// Valid? is No. • Five• Year Review Report National .& Chemical Company Superfund Site Septcmbc, 2002 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? As discuss in Section 6.5, no ecological impacts were identified during the 1993 baseline risk assessment and no new ecological impacts were identified during the Five-Year Review process. Tables 14 and 15 present analytical data for samples collected from the Unnamed Tributary and Northeast Tributary, respectively. As can be seen, the levels of 1,2-DCA have decreased in both streams with time. Periodic surface water and sediment samples will continue to be collected from the Unnamed Tributary and the Northeast Tributary to insure that these environmental media are not being adversely impacted. This is especially true for the Unnamed Tributary until the assessment of the PPES is completed. No weather-related events have affected the protectiveness of the remedies. There is no other information that calls into question the protectiveness of the remedies. In summary, the answer to question (C) is Has Any Other Information Come to Light That Could Call Imo Question the Protectiveness of the Remedy(ies)? is No. 8.0 ISSUES Identified issues have been listed in Table 16. TABLE 16 --LIST OF SIGNIFICANT ISSUES AFFECTS PROTECTIVENESS (YIN) ISSUE CURRENT Fl.mJRE Complete OU #4 Biodegradation Treatability Study N y Complete assessment of PPES N y Complete assessment of OU #2 N y Continued high detection levels for groundwater analyses y y The decision documents for the Site do not reflect current ARARs or subsequent recordation requirements and N y cleanup standards for both soil and groundwater Before this Site can be considered for deletion, the issue of how clean is clean for the soils in the Trench Area N y needs to be addressed • Five-Year Review Rcpon National .& Chemical Company Superfund Site September 2002 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS Recommendations offered in this Five-Year Review are summarized in Table 17. 10.0 PROTECTIVENESS STATEMENT The portion of the Site remedy dealing with potential soil exposures appears to be protective of human health and the environment as the Trench Area, Area 2, and the lagoon area remain covered and the deed restrictions are in place. At the conclusion of Phase 2 of the Natural Degradation Treatability Study in 2007, a definitive answer should be made and the contingency in the October 1994 OU #4 ROD will either be implemented or deleted from the OU #4 ROD. There are no current onsite groundwater receptors and the nearest private, potable wells is located approximately 2,700 feet north of Area #2. Since there is currently no indication of contaminated groundwater or surface water exiting the property, the remedy is considered protective in the short-term. Groundwater at the NSCC Site is not protective of human health and the environment in the long-term due to the following reasons: the current groundwater monitoring system is insufficieni to determine if the plumes are being captured, groundwater is likely migrating to a degree and discharging to adjacent surface water, groundwater performance standards are not being met throughout the plume, and groundwater is not currently "restored", as some of ARARs are lower than the ROD standards. I 1.0 NEXT REVIEW The next Five Year Review should be scheduled five years from the date of this Review in September 2007. TABLE 17 -SUMMARY OF RECOMMENDATIONS AND FOLLOW-UP ACTIONS ISSUE RECOMMENDATIONS AND PARTY FOLLOW-UP ACTIONS RESPONSIBLE How clean is clean for the soils in the Initiate discussions between EPNNCDENR regulatory agencies, NSCC, and · nch Area public to discuss this issue INSCC Complete OU #4 Biodegradation Maintain communication with NSCC Treatability Study NSCC Complete assessment of PPES Maintain communication with NSCC NSCC Conduct soil sampling in Complete assessment of OU #2 conjunction with OU #4 NSCC Biodegradation Treatability Study Effectiveness of Collection Trench in Evaluate if Collection Trench is NSCC capturing plume capturing plume .ectiveness of other groundwater Detennine if efficiency of extraction systems existing groundwater extraction NSCC systems can be enhanced Are groundwater monitoring systems Detennine if additional EPNNCDENR adequate? monitoring wells are needed INSCC Arc contaminants leaving the Site via Locate and sample new sampling the Northeast Tributary point downstream of Sampling NSCC Location SW/SE -09 OVERSIGHT AGENCY EPA EPA EPA EPA EPA EPA EPA EPA Five-Year Review Report National Starch & Chemical Company Superfund Si1e September ~002 AFFECTS PROTECTIVENESS? (YIN) MILESTON CURRENT FuTuRE E September N y 2007 February N y 2007 April 20m y y July 2003 N y December y y 2003 September 2007 N y December y y 2004 December 2003 y y • • The decision documents for the Site do not reflect current ARARs or Amend decision documents and EPA/NCDENR subsequent recordation requirements NSCC deed recordation to reflect EPA Septem and cleanup standards current ARARs /NSCC 2012 APPENDIX A FIVE-YEAR REVIEW QUESTIONNAIRES slar Review Questionnaire• Site !t~1!ti:. ~~ City/State~ ~( · . Name of Citizen Address How long have you lived near the Site? -- Are you familiar with EPA activities over the past years? V41 ~-f?r4-.:,._ ~ DNDu still have any concerns regarding EPA clean up activit~f the Site? tions tthi~ D~: think you have been adequately informed about clean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in out 5-year rev:er ~ site ac~vities? A r, · 1, ./..1 rl1. fl. . ..,t./_ I\)~ -~r ~((Id'-, -Y?kX {~ ~ //4.v --=y !faiqy Is !here someone else that you would like to recommend we contact for more information? 0 Do you h public? [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at __________________________ _ Interview conducted by: Date conducted : 5,ear Review Questionnaire• Site ~~~we City/State ~ = 11ka1C~~, Date: Name of Citizen Address How long have you lived near the Site? Are you familiar with EPA activities over the past years? Do you still have any concerns regarding EPA clean up activities of the Site? Overall, have you been pleased or displeased with EPA actions at this Site? Do you think you have been adequately informed about clean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in our 5-year review of site activities? Is there someone else that you would like to recommend we contact for more information? Do you have any suggestions that EPA can implement to imp'rove communication with the public? ------------------------------- [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at--------------------------- Interview conducted by: Date conducted : ----------- Site City/State Name of Citizen Address sfllar Review Questionnaire. Phone No. How long have you lived near the Site? Are you familiar with EPA activities over the past years? still tiave any concerns regarding EPA clean up activities of the Site? 0 sed or Qi§p,le -/2; hink you have been adequately informed about clean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in 07l1!fiilfflii;:V!b;;t;;u1 &J't ~ 4 Ly? d e contact for more information? nication with the [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at ___________________________ _ lmeolew cood"Cied by J,orf ,_,,;/ ... ~ Date conducted : /9 e,{) I Site City/State Name of Citizen Address A R. . Q t· .• ~ear ev1ew ues 1onna1re How long have you lived near the Site? Are you familiar with EPA activities over the past years? Do ii have any concerns regarding EPA clean up activities of the Site? u think you have been adequately informed about clean up activities at the Site? Is here any information about the Site that you would like to share with us that would assist in our ~rear rev~te activi~e;;? j f ~· &o -~,tt&~ -w _Z &3~ ik to recommend we contact for more information? [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at __________________________ _ lm,~iew '°"'""" bY'➔-0£J';.~ Date conducted: --~/~f~@=~~-~'+-----~ •• • 5-'Vear Review Questionnaire Site 71~-irc~ City/State , 7:::. · PhoneNr'DPF ft Address !J!!!!:¾11!!! Ho long = you rve near the Site? Are you familiar with EPA activities over the past years? je4 ~f5:itl4t/'«e-<-t;t;,.,~ Overall, have you been pleased or displeased with EPA actions at this Site? Is there any information about the Site that you would like to share with us that would assist in our / ye~r review of site ctivilie ? _ M aJJ;:t:cfc, o recommend we contact for more information? [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at _________________________ _ Interview conducted by: Date conducted : -ear Review Questionnaire• Site ~~ City/State ___ _ Name of Citizen Address How long have you_ lived near the Site? _,._/..,;J"-",-"</'l'(.,.,.,.,44'"""---------~-'--'---- Are you familiar with EPA activities over the past years? ,&'-"-"'v,._f..,,t~J....,~ .. ...,_1 ______ _ Do you still have any concerns regarding EPA clean up activities of the Site? ve b~en adequately informed about c ean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in -ourfJYJar review of site activities? Is there someone else that you would like to recommend we contact for more information? D Do you hav any suggestions that EPA can implement to imp·rove communication with the public? -+"--'O'------------------------------ [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at __________________________ _ • • LIST OF DOCUMENTS REVIEWED Remedial Investigation Report { Prepared by NSCC} (January 1988) Record of Decision for OU #1 {Prepared by EPA} (September 30, 1988) Five-YearReviewReportforOU#l {Prepared by EPA} (June 18, 1996) Five-Year Review Repon for OU #2 {Prepared by NSCC} (August 1998) Explanation of Significant Differences #2 for OU# 1 { Prepared by EPA} (September 28, I 990) Record of Decision for OU #2 { Prepared by EPA} (September 28, 1990) Record of Decision for OU #3 { Prepared by EPA } (October 7, 1 993) Record of Decision for OU #4 { Prepared by EPA} (October 6, 1994) Explanation of Significant Differences #1 for OU #1 {Prepared by EPA} (June 10, 1997) Phase I Natural Degradation Treatability Study Work Plan { Prepared by NSCC} (March 26, 1998) Final Design Report for OU #3 { Prepared by NSCC} (March 1999) Phase II Natural Degradation Treatability Study Work Plan {Prepared by NSCC} (January 2000) Combined OU #1 & #3 Pretreatment System Operation & Maintenance Manual {Prepared by NSCC} (April 2000) Final Construction Report Combined OU #1 + OU #3 Pretreatment System {Prepared by NSCC} (August 2000) Remedy Evaluation Report for OU #1 {Prepared by NSCC} (November 2000) Draft Five-Year Review Report for All Operable Units {Prepared by NSCC} (August 2001) Five-Year Review Report for All Operable Units { Prepared by NSCC} (March 2002) 2001 Site Monitoring Report {Prepared by NSCC} (August 2002) All Appropriate Monthly Progress Reports { Prepared by NSCC} Appropriate Quarterly Reports {Prepared by NSCC} NORTH CAROLI/\A DEPARTMENT OF ENVIR.ENT AND NATURAL RESOURCES DIVISION OF WASTE MANAGEMENT MICHAEL F. EASLEY, GOVERNOR WILLIAM G. Ross, JR., SECRETARY DEXTER R. MATfllEWS, DIRECTOR Mr. Jon K. Bomholm Remedial Project Manager Superfund Branch Waste Management Division US EPA Region IV 61 Forsyth Street, 11 th Floor Atlanta, Georgia 30303 RE: Five-Year Review Report September 18, 2002 National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC Dear Mr. Bornholm: • The Superfund Section and the Hazardous Waste Section of the North Carolina Department of Environment and Natural Resources (NC DENR) have reviewed the First Five-Year Review -Report for the Entire National Starch and Chemical Company Superfund Site. The NC DENR offers the following attached comments. We appreciate the opportunity to comment on this document. If you have any questions or comments, please feel free to call me at (919) 733-2801 extension 349. Sincerely, D:i»z,d 13 . m.o.Ill s If>../ I c1.1c... David B. Mattison, CHMM Environmental Engineer Superfund Section cc: Ms. Daphne Olszewski, NC Hazardous Waste Section 1646 MAIL SER\"ICE CEl\TER, R,LEIGH, NORTH CAROLII\A 27699-1646 401 OBERLl!'i ROAD, SUITE 150, RALEIGH, NC 27605 PHONE: 919-733-4996 I FAX: 919-715-3605 Al'\ EQUAL OPPORTlll'olTI°IAFFIRMATI\'£ ACTI0!\' EMPLOYER-~(1% REC\'CLEO/10% POST-CONSUMER PAPER Mr. Jon Bomholm September 18, 2002 Page I · • • First Five-Year Review Report for the Entire National Starch and Chemical Company Superfund Site Table of Contents 1. Please correct the Table of Contents to indicate that Section 4.3 -System Operations/Operation and Maintenance is located on page 21. 2. Please correct the Table of Contents to indicate that Section 7.3 -Question C: Has Any Other Information Come To Light That Could Call Into Question The Protectiveness Of The Remedy is located on page 53. 3. Please correct the List of Figures in the Table of Contents to indicate that Figure 7 is titled "Groundwater Elevation Contour Map for OU #I/OU #2 Transition Zone Wells - Fourth Quarter 1999." List of Acronyms 4. Please correct the List of Acronyms to indicate the following relationships: ARARs CAA GC/MS 15A NCAC2B 15ANCAC 2L RAOs SDWA Executive Summary Applicable or Relevant and Appropriate Requirements Clean Air Act Gas Chromatograph/Mass Spectrograph North Carolina Administrative Code Title ISA Subchapter 2B (NCAC 1SA-2B), Classification and Water Quality Standards Applicable to the Surface Waters and Wetlands of North Carolina North Carolina Administrative Code Title ISA Subchapter 2L (NCAC 1SA-2L), Groundwater Classifications and Standards Remedial Action Objectives Safe Dri~ng Water Act 5. Please delete the duplicate period at the conclusion of the third sentence of the Executive Summary. Section 1.0 Introduction 6. Please correct the third sentence of the first paragraph of Section 1.0 to state, "In addition, Five-Year Review Reports identify issues found during the review, if any, and identify recommendations to address them." Mr. Jon Bomholm September 18, 2002 Page 2 • Section 3.1 Physical Characteristics • 7. Please revise the last sentence of the fifth paragraph of Section 3.1 to state, "Based on the above information, the horizontal flow of groundwater in the saprolite was estimated to have a velocity of 80 feet/year (ft/yr) in the lagoon area and 27 ft/yr in Area 2." Table 1 Chronology of Site Events 8. Please correct the second item on page 5 to state "ROD for OU #2 signed, divided Site into three OUs, created OU #3" 9. Please correct the twenty-first item on page 5 to state, "Initiated OU #4 Natural Degradation Treatability Study-Phaser•. I 0. Please correct the sixth item on page 6 to state '!Initiated OU #4 Natural Degradation Treatability Study-Phase IT'. 11. Please correct the eighth item on page 6 to state, "Complete OU #4 Natural Degradation Treatability Study-Phase IT'. Section 3.4 Initial Response 12. Please correct the last sentence of the third paragraph of Section 3.4 to state, "However, the usefulness of the data generated from these efforts was very limited since these samples were only analyzed for chemical oxygen demand (COD) and pH." Section 4.1 Remedy Selection 13. Please revise the third sentence of the second paragraph to state, "However, negotiations on the CD were not successful. The Agency issued NSCC an Unilateral Administrative Order (UAO) directing NSCC to design and implement the Remedial Action (RA) Specified in the OU #I ROD." Section 4.2 Remedy Implementation 14. Please correct the fourth sentence of Section 4.2 to state, "The first phase of construction focused on the plume periphery extraction wells and associated piping and electrical connections, the second phase focused on the pretreatment system for the extracted groundwater, and the third phase centered on the installation of the Trench Area extraction wells and associated piping and electrical connections." Mr. Jon Bornholm September 18, 2002 Page 3 • Section 6.4 ARAR Review • 15. Please correct the first bullet item in the first paragraph of Section 6.4 to state, "Clean Air Act (CAA)". 16. Please correct the first bullet item under Federal Regulations in the second paragraph of Section 6.4 to state, "Clean Air Act (CAA)". 17. Please correct the first, second, third and fourth bullet items under State Regulations in the second paragraph of Section 6.4 to state, "North Carolina Air Quality Permit Procedures (NCAC TISA:2Q, August I, 1995); North Carolina Air Pollution Control Requirements (NCAC Tl5A:2D, April I, 1995); North Carolina Groundwater Classifications and Standards (NCAC TISA:2L, November 23, 1993); and, Classification and Water Quality Standards Applicable to the Surface Waters and Wetlands of North Carolina (NCAC Tl5A:2B, March 3, 1993).", respectively. 18. Please revise the third paragraph of Section 6.4 to include provisions for compliance with the Inactive Hazardous Sites Response Act of 1987 (North Carolina General Statute 130A-310 et. seq.), the associated Guidelines for Assessment and Cleanup (North Carolina Department of Environment and Natural Resources (NC DENR, Inactive Hazardous Sites Program, 2001) and the soil/sediment remediation requirements detailed in Section 4 of the Guidelines. I 9. Please correct the second, third, fourth and fifth bullet items in the fifth paragraph of Section 6.4 to state, "North Carolina Air Quality Permit Procedures (NCAC TISA:2Q, August I, 1995); North Carolina Air Pollution Control Requirements (NCAC Tl 5A:2D, April I, 1995); North Carolina Groundwater Classifications and Standards (NCAC TISA:2L, November 23, 1993); and, Classification and Water Quality Standards Applicable to the Surface Waters and Wetlands of North Carolina (NCAC T15A:2B, March 3, 1993).", respectively. 20. Please correct the first sentence in the last paragraph of Section 6.4 to state," "The newly promulgated or modified performance standards are listed in the second to last column in Table 3." Section 6.5 Data Review 21. Please correct the first sentence of Section 6.5 to state, "The following section is based on the Agency's interpretation of its review of the historical analytical data for groundwater and surface water/sediment monitoring." Mr. Jon Bornholrn September 18, 2002 Page 4 • • Table 3 Performance Standards According to the OU #1, OU #3, and OU #4 Record of Decisions 22. Please correct Table 3 to indicate that the Basis of Standard for the Current ARAR for cis-1, 2-dichloroethene in groundwater is "MCUNCAC l S-2L". 23. Please correct Table 3 to indicate that the Current ARAR for trans-I, 2-dichloroethene in groundwater is 70 micrograms per liter (µg/L) and that the Basis of Standard is NCAC 15-2L. 24. Please correct Table 3 to indicate that the Current ARAR for xylene in groundwater is 530 µg/L and that the Basis of Standard is NCAC l 5-2L. 25. Please correct Table 3 to indicate that the Current ARAR for bis (2-chloroethyl) ether in groundwater is 0.031 µg/L and that the Basis of Standard is NCAC l 5-2L. 26. Please correct Table 3 to indicate that the Current ARAR for bis (2-ethylhexyl) phthalate in groundwater is 3 µg/L and that the Basis of Standard is NCAC l 5-2L. 27. Please correct Table 3 to indicate that the Current ARAR for barium in groundwater is 2,000 µg/L. 28. Please correct Table 3 to indicate that the Current ARAR for I, 2-dichloroethane in soil is 0.35 ppm or milligrams per kilogram (mg/kg) and that the Basis of Standard is the Inactive Hazardous Sites Response Act of 1987 (North Carolina General Statute 130A- 3 IO et. seq.), the associated Guidelines for Assessment and Cleanup (NC DENR, Inactive Hazardous Sites Program, 2001) and the soil/sediment remediation requirements detailed in Section 4 of the Guidelines. Section 7.1 Question A: Is The Remedy Functioning As Intended By The Decision Documents? 29. Please insert the following sentence following the second sentence of the last paragraph of Section 7.1 "However, the deed recordation likely does not meet the current requirements of Hazardous Sites Response Act of 1987 (North Carolina General Statute !30A-3 IO et. seq.), as amended, or the associated Guidelines for Assessment and Cleanup (NC DENR, Inactive Hazardous Sites Program, 2001 )." Mr. Jon Bombolm September 18, 2002 Page 5 • • Section 7.2 Question B: Are The Exposure Assumptions, Toxicity Data, Cleanup Levels, And Remedial Action Objectives Used At The Time Of The Remedy Still Valid? 30. Please revise the last sentence of the second paragraph of Section 7 .2 to state, "Although there has been no change in the potential future exposure scenarios, the assumptions and processes used to develop the Human Health Risk Assessments have changed over time." Section 7.3 Question C: Has Any Other Information Come To Light That Could Call Into Question The Protectiveness Of The Remedy? 31. Please revise the second sentence of Section 7.3 to state, "Periodic surface water and sediment samples will continue to be collected from the Unnamed Tributary and the Northeast Tributary to insure that these environmental media are not being adversely impacted." Table 16 List of Significant Issues 32. Please revise Table 16 to include the following: Issue Affects Protectiveness (YIN) Current Future The decision documents for the Site do not reflect current ARARs or subsequent N y recordation requirements and cleanup standards for both soil and ITTOundwater Mr. Jon Bomholm September 18, 2002 Page 6 • • Table 17 Summary of Recommendations and Follow-Up Actions 33. Please revise the last two issues/recommendations in Table 17 to include the following: Affects Protectiveness? (YIN) Issue Recommendation Party Oversight Milestone Current Future sand Follow-Up Responsible Agency Actions ls Determine if EPA/ EPA December y y Groundwater additional NCDENR/ 2004 Monitoring monitoring wells NSCC System are needed Adequate? Are Locate and NSCC EPA December y y contaminants sample at new 2003 leaving the sampling point Site via the downstream of Northeast Sampling Tributary? Location SW/SE-09 The decision Amend decision EPA/ EPA September N y documents documents and NCDENR/ 2007 for the Site NSCC deed NSCC do not reflect recordation t'o current reflect current ARARsor ARARs subsequent recordation requirements and cleanup standards for both soil and !"round water • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 4WD-NSMB Mr. David Mattison REGION 4 ATLANTA FEDERAL CENTER 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3104 September 5, 2002 North Carolina Department of Environment & Natural Resources/Superfund Section Suite 150 401 Oberlin Road Raleigh, NC 27605 9 2002 SUBJ: Request to Review the Five-Year Review Report on All Operable Units for the National Starch & Chemical Company Superfund Site Dear Mr. Mattison: Enclosed for the State's review is a copy of the above referenced document, dated September 2002. This report was prepared by the Agency using the following guidance, Comprehensive Five-Year Review, June 200 I. This guidance document can be accessed at the following web address: http://www.epa.gov/superfund/resources/5year/index.htm The Agency would appreciate receiving the St;te's comments/concerns and/or approval . by Monday, September 16, 2002. A.shol1 time-frame is needed as the Agency would like to have this document in an approvable format by the end of September. If the State fines this document acceptable in its current condition, please sign the second page and facsimile this page to my attention. If you have any questions, I can be reached at 404-562-8820. Enclosures ' Sincerely, Arriit. 6ovJ~ fonu K. Bomholm Remedial Project Manager l. September 2002 Five-Year Review Report for the National Starch & Chemical Company Superfund Site \ I North Carolina • Department of Environment dnd Natural Resources Michael F. Easley, Governor William G. Ro_ss Jr., Secretary Dexter R. Matthews, Director Mr. Jon K. Bomholm Remedial Project Manager Superfund Branch Waste Management Division US EPA Region IV 61 Forsyth Street, 11 th Floor Atlanta, Georgia 30303 RE: Final Five-Year Review May 1, 2002 National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC Dear Mr. Bomholm: ....... ~ ~·--_Ill,: m ,;;1( ___ _ MCDENR FILE COPY The Superfund Section and the Hazardous Waste Section of the North Carolina Department of Environment and Natural Resources (NC DENR) have reviewed the Final Five-Year Review. The NC DENR offers the following comments. Final Five Year Review -National Starch and Chemical Corporation General Items The NC DENR Superfund Section recommends that the United States Environmental Protection Agency (US EPA) use the guidance manual, "Comprehensive Five-Year Review Guidance" (EPA 540-R-01-007, US EPA, June 2001) when drafting its version of the Five-Year Review Report for the National Starch and Chemical Corporation (NSCC). Although the document reviewed was prepared with this intent in mind, many of the items required for the current format were noticeably absent. Additionally, the process of evaluating the site as specified in Chapter 4 of the current guidance was not implemented. However, the US EPA in drafting its version of the Five-Year Review Report may use much of the supporting documentation from this document.. The NC DENR Superfund Section believes that once the guidance and its protocols for evaluation are implemented, the Final Five Year Review drafted by the US EPA will not only be consistent but may also reach different conclusions. recommendations and protectiveness statements than those drafted by NSCC. 1646 Mail Service Center, Raleigh, North Carolina 27699-1646 Phone: 919-733-4996 \ FAX: 919-715-3605 \ Internet: ½'vvw.enr.state.nc.us AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER • • Mr. Jon Bomholm May!, 2002 Page 2 Specific items I. There was little information regarding the groundwater extraction and treatment system for Operable Units One and Three contained in the Final Five-Year Review Report prepared by NSCC. · The appropriate sections of the Five-Year Review Report should be revised to include a detailed description of the !,'TOundwater extraction and treatment system as well as a detailed evaluation of the effectiveness of the groundwater extraction and treatment system. Items to be addressed include the text and tables necessary to describe basic information describing the extraction and treatment system including the aquifer(s) that the extraction wells are pumping from, the design and actual removal rates for the individual extraction wells, a delineation of the areas of hydraulic control for the various aquifers, the amount of groundwater extracted and treated, the design and actual efficiencies of the groundwater treatment system, the quantity of contaminants removed, monitoring requirements, instances of noncompliance with monitoring or permitting requirements, problems associated with operation of the extraction and treatment system, etc. Also, an evaluation of the performance of the extraction wells and the treatment system should be performed. This evaluation should consider maintenance and performance issues associated with these systems, including problems associated with biofouling, excess cycling of the extraction wells or the treatment system, etc. 2. The issue of applicable, relevant and appropriate requirements (ARARs) was addressed in the Five-Year Review Report submitted by NSCC. However, the NC DENR Superfund Section wishes to emphasize the objective of the groundwater remedial actions at the site: groundwater restoration. The NC DENR Superfund Section believes that the Five-Year Review Report drafted by the US EPA should include provisions for the evaluation of the North Carolina groundwater standards for the groundwater remedy at the site. Additionally, the NC DEl\1R Superfund Section has identified additional ARARs for the site: the Inactive Hazardous Sites Response Act of 1987 (North Carolina General Statute 130A-3 IO et.seq.), the associated Guidelines for Assessment and Cleanup (North Carolina Department of Environment and Natural Resources (NC DENR), Inactive Hazardous Sites Program, 200 I) and the soil remediation requirements detailed in Section 4 of the Guidelines. The NC DENR Superfund Section believes that the requirements specified in this statute and associated guidance are particularly relevant in the evaluation of Operable Units Two and Four. 3. The NC DENR Superfund Section believes that the Five-Year Review Report to be drafted by the US EPA should include much greater detail regarding the evaluation of Operable Units Two and Four. Information such as the extent of contamination, attempts to determine current soil contaminant concentrations, attempts to determine the rates of contaminant degradation, impacts on the performance of the groundwater extraction and treatment system. and a true evaluation of the remedy and its effectiveness should be described in the Final Five-Year Review. Mr. Jon Bomholm May I, 2002 Page 3 • • We appreciate the opportunity to comment on this document. If you have any questions or comments, please feel free to call me at (919) 733-2801 extension 349. Sincerely, /Ju.lid b . (rlcJ2/_.5 C')·J I dL David B. Mattison, CHMM Environmental Engineer Superfund Section cc: Ms. Daphne Olszewski, NC Hazardous Waste Section • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER • October 2, 2001 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3104 fo) fE(C;fE~WrEW u'u_ OCT 9 2001 I 4WD-NSMB Ms. Angela J. Dahl National Starch & Chemical Company 10 Findeme A venue Bridgewater, New Jersey 08807 Mr. Michael P. Fleischner Blasland, Bouck & Lee, Inc. 8 South River Road Cranbury, New Jersey 08512-9502 SUPERFUND SECTION SUBJ: Comments on the August 2001 Draft Five-Year Review Report on All Operable Units · at the National Starch & Chemical Company Superfund Site Dear Ms. Dahl & Mr. Fleischner: In a correspondence dated May 17, 2001, the Agency inquired whether or not National· Starch & Chemical Company (NSCC) would be interested in preparing the Five-Year Review Report that would cover all Operable Units. NSCC and its consultant, Blasland, Bouck & Lee, Inc. (BBL), replied they would. The draft report was received on September 4, 2001. Copies of this report were subsequently sent to the State of North Carolina Department of Environment and Natural Resources (NCDENR) for its review and comments. Below are the Agency's comments and enclosed are comments from NCDENR . .Ji. Page 1-2, Section 1.2, list of guidance: EPA recently issued a new five-year review guidance, entitled Comprehensive Five-Year Review, June 200 I. This guidance document can be accessed at the following web address: http://www.cpa.gov/su perf und/resources/5 year/i nclex .htm ✓2. Page 5-1, Section 5.1, first paragraph, second sentence: The Agency_ thought that a catalytic oxidizer_was being used to control emissions from the air stripper. /3_ Page 5~ 1, Section 5. (, ·second paragraph, first sentence: Has the presence of a DNAPL been verified or is the presence of a DNAPL still speculative? • 2 /4. Page 5-3, Section 5.5: The Agency realizes minimal analytical data exists for OU #3. However, has sufficient groundwater level data been collected to evaluate whether or not the groundwater extraction system, as installed and operated, is·achieving hydraulic control? If not, when will sufficient data be collected to evaluate either or both the hydraulic control aspect and the quality of the groundwater? /s. Page 7-1, Section 7.0: Have any issues been raised by the community? If so, these need to be listed along with how NSCC responded to each issue. At what frequency have these meetings with the public been held? What is the attendance like? /4. Page 8-1, Section 8.1 J2-f!,r_sl,.Pe,!]gr%?h,,!ast ~le~, .U.,is sentence needs to be reword as follows," ... , and ~6g~h§x:,{h1Jf\ill'~iii:19~c.!.:i~.li!'.!:{iiiAte"'d the following parameters will be cli111i11atcd from groundwater..·.'. / J7. Page 8-2, Section 8.1.3: Additional surface water/sediment samples from the Unnamed Tributary need to be collected/analyzed to support the statement that the OU #I remedial action is being protective of the environment. /4. Figures: A figure should be developed for each set of groundwater level measurements collected that shows the groundwater capture zones around each of the extraction systems. ✓9. There appears to be no discussion of surface water/sediment samples collected recently. What conclusions can be drawn from this data? The Unnamed Tributary receiving groundwater discharge from the western portion of the Site (OU #I and OU #2) needs to be sampled on a periodical basis (i.e., annually). Without this data, it is hard to support the statement made in the first sentence on page 2 of the Executive Summary, 'The OU! remedial action is protective of humari health and the environment." All of the above and enclosed comments need to be addressed within 21 calendar days. If you have any questi_ons and would like to discuss these comments via a conference call, or would like to meet with EPA, please allow several days for the necessary individuals to arrange their schedules. cc: David Mattison, NCDENR Sincerely, ,tK6JVJv Jon K. Bomholm Remedial Project Manager Mr. Jon K. Bornholm Remedial Project Manager Superfund Branch • Waste Management Division US EPA Region IV 61 Forsyth Street, 11 th·Floor Atlanta, Georgia 30303 RE: Draft Final Five Year Review • September 26, 200 I National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC Dear Mr. Bornholm: The Superfund Section and the Hazardous Waste Section of the North Carolina Department of Environment and Natural Resources (NC DENR) have reviewed the Draft Final Five Year Review. The NC DENR offers the following attached comments. We appreciate the opportunity to comment on this document. If you have any questions or comments, please feel free to call me at (919) 733-280 I extension 349. Sincerely, David B. Mattison, CHMM Environmental Engineer Superfund Section cc: Ms. Daphne Olszewski, NC Hazardous Waste Section Attachment Mr. Jon Bornholm September 26, 2001 Page I • DRAFT FINAL FIVE YEAR REVIEW General • I, Revise the Draft Final Five Year Review to include potentiometric surface maps and isoconcentration maps (both plan and cross-sectional views). These maps should completely describe all contamination, including volatile organic compounds (VOCs), semi volatile organic compounds (SYOCs) and metals. These maps should be presented for both present and past conditions. At a minimum, historical maps should be submitted for each significant project milestone, such as the completion of the Plume Periphery Extraction System (PPES), Trench Area Extraction System (T AES), and Combined Operable Unit I (OUl)/Operable Unit 3 (OU3) Pretreatment System, in order to illustrate the. impacts of the remedial actions. 2. The information presented in the Draft Final Five Year Review must be sufficient to support all claims regarding the effectiveness of the remedial actions being conducted at the National Starch and Chemical Company (NSCC) facility. As it stands now, the document makes many claims that·are likely true, however, the claims are unsubstantiated and the document is. unapprovable. Revise the Draft Final Five Year Review to include all of the elements presented in the document, Comprehensive Five Year Review (United States Environmental Protection Agency (US EPA), June 2001). Additionally, all of the information used to support the claims asserted in this document should be presented in a logical fashion. The document should contain a very thorough discussion and presentation for the technical evaluation of the remedial action as discussed in Chapter 3 and Chapter 4 of the aforementioned document. All of these elements must be presented in the revised document. Table of Contents · -3. Correct the Table of Contents to indicate that the title of Table 6 is "Historical Analytical Results -OU3 Extraction and Monitoring Wells." Section 3.3 ARARs Review /4. This section indicates that although the North Carolina groundwater standards were not incorporated into the Record of Decision (ROD), the scope of the remedial actions would not have been altered if the more stringent groundwater standards were embodied in the ROD Performance Standards. In order to include the North Carolina groundwater standards (as well as the North Carolina surface water standards, air quality standards and air permitting requirements), it is likely that an Explanation of Significant Difference (ESD) will be required. Detail whether this task is to be implemented and the steps required to complete this. task. NSCC should note that in the event that these standards Mr. Jon Bornholm September 26, 200 I Page 2 • • are not implemented during these remedial actions conducted under the auspices of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), the site must be forwarded to the appropriate divisions of the North Carolina Department of Environment and Natural Resources (NC DENR) for continued remedial actions until the North Carolina standards have been achieved. Section 3.5 System Effectiveness /s. Insert a page break prior to the beginning of Section 3.5. Additionally, revise the Table of Contents accordingly. -6. Revise Section 3.5 to include a detailed description of the groundwater extraction and treatment system as _well as a detailed evaluation of the effectiveness of the groundwater extraction and treatment system. lnclu_de the text and tables necessary to describe basic information describing the extraction and treatment system including the aquifer(s) that the extraction wells are pumping from, the design. and actual removal rates for the individual extraction wells, a delineation of the areas of hydraulic control for the various aquifers, the amount of groundwater extracted and treated, the design and actual efficiencies of the groundwater treatment system, the quantity of contaminants removed, monitoring requirements, instances of noncompliance with monitoring or permitting requirements, problems associated with operation of the extraction and treatment system, . etc. Also, include an evaluation of the performance of the extraction wells and the treatment system. This evaluation should consider maintenance and performance issues associated with these systems, including problems associated with biofouling, excess cycling of the extraction wells or the treatment system, etc. 7 7. The last sentence of Section 3.5 states, "Analytical results form the fourth quarter 2000 monitoring event demonstrate that the shut down of the plume periphery extraction wells has not adversely impacted local groundwater quality." Provide the supporting evidence and explanation for this conclusion. 7 8. Section 3.5 discusses the suspension of groundwater extraction activities in plume periphery of OU I. However, no mention of sediment or surface water sampling of the . Unnamed Tributary is made. Revise Section 3.5 to include provisions for sediment and surface waler sampling of the Unnamed Tributary or include a valid, technical justification for not conducting these activities. Mr. Jon Bornholm September 26, 2001 Page 3 • • Section 4 OU2 Remedy Evaluation -9. Revise Section 4 to include much greater detail regarding the extent of contamination, any attempts to determine current soil contaminant concentrations, any attempts to determine the rates of contaminant degradation, the impacts cin the performance of the groundwater extraction and treatment system, and a true evaluation of the remedy and its effectiveness. Section 5.5 Remedy Effectiveness -IO. Although there is limited data to evaluate the effectiveness of the Operable Unit 3 remedy, revise Section 5.5 to include a detailed description of the groundwater extraction and treatment system as well as a detailed evaluation of the effectiveness of the groundwater extraction and treatment system given the information available at this time. Include the text and tables necessary to describe basic information describing the extraction and treatment system including the aquifer(s) that the extraction wells are pumping from, the design and actual removal rates for the individual extraction wells, a delineation of the areas of hydraulic control for the various aquifers, the amount of groundwater extracted and treated, the design and actual efficiencies of the groundwater treatment system, the quantity of contaminants removed, monitoring requirements, instances of noncompliance with monitoring or permitting requirements, problems associated with operation of the extraction and treatment system, etc. Also, include an evaluation of the performance of the extraction wells and the treatment system. This evaluation should consider maintenance and performance issues.associated with these systems, including problems associated with biofouling, excess cycling of the extraction wells or the treatment system, etc. The third sentence of Section 5.5 states, "These initial data indicate that the extraction system is effective in containing groundwater in the area of impacts and wells outside the zone of hydraulic control have not exhibited an increase in concentration." Provide the . necessary supporting evidence and explanations required to defend these claims. Section 7 Summary of Community Involvement -,.12. Revise Section 7 to include all elements of the Community Involvement as described in the document, Comprehensive Five Year Review (US EPA, June 2001). Mr. Jon Bornholm September 26, 200 I Page 4 • • Section 8 Recommendations 13. Revise Section 8 to include a paragraph describing Operable Unit 2 and any applicable recommendations. Section 8.1.1 Evaluation of Potential Fractures -14. Revise Section 8.1.1 to include provisions for sediment and surface water sampling of the Unnamed Tributary or include a valid, technical justification for not conducting these activities. Section 8.1.2 Elimination of Selected Monitoring Parameters /is. ✓17. Section 8.1.2 includes a request to delete the contaminant xylene from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. This request is denied because xylene was detected at groundwater monitoring well NS-29 at 1,200 micrograms per liter (µg/L) in the Fourth Quarter of 2000 and the performance standard for xylene is 350 µg/L. Revise Section 8.1.2 accordingly. Section 8.1.2 includes a request to delete the contaminant 4-nitrophenol from the list of ·monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. However 4-nitrophenol was not analyzed at the proper delection limits at groundwater monitoring well NS-29 in the Fourth Quarter of 2000 in order to ascertain the presence or . absence of the contaminant in excess of the performance standard. Therefore this request is denied. Revise Section 8.1.2 accordingly. Section 8.1.2 includes a request to delete the contaminant arseriic from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. This request is denied because arsenic was detected at groundwater monitoring well NS-30 at 37 .2 µg/L in the Fourth Quarter of 2000 and the performance standard for arsenic is 10 µ g/L. Revise Section 8.1.2 accordingly. Section 8.1.2 includes a request to delete the contaminant chromium from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. However, chromium has been detected.at groundwater monitoring well NS-29 in increasing concentrations for the last two years. Therefore, this request is denied. Revise Section 8.1.2 accordingly. Mr. Jon Bornholm September 26, 2001 . P~ge 5 • /19. Section 8.1.2 includes a request to delete the contaminants beryllium, cadmium, and zinc . · from the li:St of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells: This request is approved because these constituents have not been detected in excess of the performance standards since the Fourth Quarter of 1997 or before. However, revise Section 8.1.2 to include the NC DENR Division of Water Quality (DWQ) provisions for site closure as they apply to the revision of monitoring requirements. Specifically_ the NC DENR DWQ provisions state that: I) the facility must demonstrate four (4) consecutive quarterly sampling events in which all constituents of concern are below North Carolina and federal groundwater standards prior to discontinuing operation of the groundwater extraction and treatment system; 2) the · facility must submit to the US EPA and the NC DENR a written request to discontinue operation of the groundwater extraction and treatment system and must receive written authorization from the US EPA and the NC DENR prior to suspending extraction and treatment activities; and, 3) the facility mustdemonstrate that all constituents of concern continue to remain below applicable North Carolina and federal groundwater standards for four (4) consecutive quarterly sampling events following suspension of groundwater extraction and treatment activities. Section 8.1.3 Statement of Protectiveness 20. The first sentence of Section 8.1.3 indicates that the OU I remedial action is protective of human health and the environment. However, the first sentence of Section 8.1.1 states, "Groundwater data collected from OU I during the monitoring program indicates that the PPES is not an effective remedy for controlling groundwater impacts and preventing impacted groundwater from migrating toward the area of the Northeast Tributary." Revise Section 8.1 to resolve these inconsistencies. Section 8.2 OU3 21. The third sentence of Section 8.2 states, "While a statistical data analysis cannot be performed to validate the level of protectiveness of the remedy, the OU3 remedial action appears to attain the desired level of protectiveness for human health and the environment by preventing further migration of the plume bases on the initial data collected following ·•the startup of the OU3 extraction system." Provide an explanation and the supporting evidence for this statement .. Mr. Jon Bornholm September 26, 200 I Page 6 Section 8.3 OU4 • • 22. The first sentence of the last paragraph of Section 8.3 states, 'The OU4 remedy appears to be protective of human health and the environment because the OU3 remedial action appears to be effective and there is limited opportunity for exposure to impacted soil in the Plant Area." Pr9vide the supporting documentation for these claims. Note that the remedy for OU4 is not a no further action remedy and therefore Section 8.3 should be revised to discuss the effectiveness of the remedy for OU4 and not reliance upon the effectiveness of the remedy of OU3. NORTH CAROLINA DEPARTMENT OF ENVIR!afENT AND NATURAL RESOURCES DIVISION OF WASTE MAN-~1ENT f i l E CO p y MICHAEL F. EASLEY, GOVERNOR WILLIAM G. Ross, JR., SECRETARY DEXTER R. MA TillEWS, INTERIM DIRECTOR Mr. Jon K. Bornholm Remedial Project Manager Superfund Branch Waste Management Division US EPA Region IV 61 Forsyth Street, 11th Floor Atlanta, Georgia 30303 RE: Draft Final Five Year Review September 26, 2001 National Starch and Chemical Company NPL Site Salisbury, Rowan County, NC Dear Mr. Bornholm: • The Superfund Section and the Hazardous Waste Section of the North Carolina Department of Environment and Natural Resources (NC DENR) have reviewed the Draft Final Five Year Review. The NC DENR offers the following attached comments. We appreciate the opportunity to comment on this document. If you have any questions or comments, please feel free to call me at (919) 733-2801 extension 349. Sincerely, Dcwid. 6. f(/_a.fti.J;(frJ / dJ<., David B. Mattison, CHMM Environmental Engineer Superfund Section cc: Ms. Daphne Olszewski, NC Hazardous Waste Section Attachment 1646 MAIL SERVICE CE1'TER, RALEIGH, NORTH CAROLINA 27699-1646 401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605 PHONE: 919-733-4996 \ FAX: 919-715-3605 AN EQUAL OPPORTIJNJTY/AFFIRMA TIVE ACTION EMPLOYER· 50% RECYCLED/JO% POST-CONSUMER PAPER Mr. Jon Bornholm September 26, 2001 Page I • DRAFT FINAL FIVE YEAR REVIEW General • I. Revise the Draft Final Five Year Review to include potentiometric surface maps and isoconcentration maps (both plan and cross-sectional views). These maps should completely describe all contamination, including volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs) and metals. These maps should be presented for both present and past conditions. At a minimum, historical maps should be submitted for each significant project milestone, such as the completion of the Plume Periphery Extraction System (PPES), Trench Area Extraction System (T AES), and Combined Operable Unit 1 (OUl)/Operable Unit 3 (OU3) Pretreatment System, in order to illustrate the impacts of the remedial actions. 2. The information presented in tbe Draft Final Five Year Review must be sufficient to support all claims regarding the effectiveness of the remedial actions being conducted at tbe National Starch and Chemical Company (NSCC) facility. As it stands now, the document makes many claims that are likely true, however, the claims are unsubstantiated and the document is unapprovable. Revise the Draft Final Five Year Review to include all of the elements presented in the document, Comprehensive Five Year Review (United States Environmental Protection Agency (US EPA), June 2001 ). Additionally, all of the information used to support the claims asserted in this document should be presented in a logical fashion. The document should contain a very thorough discussion and presentation for the technical evaluation of the remedial action as discussed in Chapter 3 and Chapter 4 of the aforementioned document. All of these elements must be presented in the revised document. Table of Contents 3. Correct the Table of Contents to indicate that the title of Table 6 is "Historical Analytical Results -OU3 Extraction and Monitoring Wells." Section 3.3 ARARs Review 4. This section indicates that although the North Carolina groundwater standards were not incorporated into the Record of Decision (ROD), the scope of the remedial actions would not have been altered if the more stringent groundwater standards were embodied in the ROD Performance Standards. In order to include the North Carolina groundwater standards (as well as the North Carolina surface water standards, air quality standards and air permitting requirements), it is likely that an Explanation of Significant Difference (ESD) will be required. Detail whether this task is to be implemented and the steps required to complete this task. NSCC should note that in the event that these standards I p Mr. Jon Bomholm September 26, 200 I Page 2 • • are not implemented during these remedial actions conducted under the auspices of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), the site must be forwarded to the appropriate divisions of the North Carolina Department of Environment and Natural Resources (NC DENR) for continued remedial actions until the North Carolina standards have been achieved. Section 3.5 System Effectiveness 5. Insert a page break prior to the beginning of Section 3.5. Additionally, revise the Table of Contents accordingly. 6. Revise Section 3.5 to include a detailed description of the groundwater extraction and treatment system as well as a detailed evaluation of the effectiveness of the groundwater extraction and treatment system. Include the text and tables necessary to describe basic . information describing the extraction and treatment system including the aquifer( s) that the extraction wells are pumping from, the design and actual removal rates for the individual extraction wells, a delineation of the areas of hydraulic coritrol for the various aquifers, the amount of groundwater extracted and treated, the design and actual efficiencies of the groundwater treatment system, the quantity of contaminants removed, monitoring requirements, instances of noncompliance with monitoring or permitting requirements, problems associated with operation of the extraction and treatment system, etc. Also, include an evaluation of the performance of the extraction wells and the treatment system. This evaluation should consider maintenance and performance issues associated with these systems, including problems associated with biofouling, excess cycling of the extraction wells or the treatment system, etc.· 7. The last sentence of Section 3.5 states, "Analytical results form the fourth quarter 2000 monitoring event demonstrate that the shut down of the plume periphery extraction .wells has not adversely impacted local groundwater quality." Provide the supporting evidence and explanation for this conclusion. 8. Section 3.5 discusses the suspension of groundwater extraction activities in plume periphery of OU!. However, no mention of sediment or surface water sampling of the Unnamed Tributary is made. Revise Section 3.5 to include provisions for sediment and surface water sampling of the Unnamed Tributary or include a valid, technical justification for not conducting these activities. Mr. Jon Bornholm September 26, 200 I Page 3 • Section 4 OU2 Remedy Evaluation • 9. Revise Section 4 to include much greater detail regarding the extent of contamination, any attempts to determine current soil contaminant concentrations, any attempts to determine the rates of contaminant degradation, the impacts on the performance of the groundwater extraction and treatment system, and a true evaluation of the remedy and its . effectiveness. Section 5.5 Remedy Effectiveness I 0. Although there is limited data to evaluate the effectiveness of the Operable Unit 3 remedy, revise Section 5.5 to include a detailed description of the groundwater extraction and treatment system as well as a detailed evaluation of the effectiveness of the groundwater extraction and treatment system given the information available at this time. Include the text and tables necessary to describe basic information describing the extraction and treatment system including the aquifer(s) that the extraction wells are pumping from, the design and actual removal rates for the individual extraction wells, a delineation of the areas of hydraulic control for the various aquifers, the amount of groundwater extracted and treated, the design and actual efficiencies of the groundwater treatment system, the quantity of contaminants removed, monitoring requirements, instances of noncompliance with monitoring or permitting requirements, problems associated with operation of the extraction and treatment system, etc. Also, include an evaluation of the performance of the extraction wells and the treatment system. This evaluation should consider maintenance and performance issues associated with these systems, including problems associated with biofouling, excess cycling of the extraction wells or the treatment system, etc. 11. The third sentence of Section 5.5 states, 'These initial data indicate that the extraction system is effective in containing groundwater in the area of impacts and wells outside the zone of hydraulic control have not exhibited an increase in concentration." Provide the necessary supporting evidence and explanations required to defend these claims. Section 7 Summary of Community Involvement 12. Revise Section 7 to include all elements of the Community Involvement as described in the document, Comprehensive Five Year Review (US EPA, June 2001). Mr. Jon Bornholm September 26, 200 I Page4 • Section 8 Recommendations • 13. Revise Section 8 to include a paragraph describing Operable Unit 2 and any applicable recommendations. Section 8.1 .1 Evaluation of Potential Fractures 14. Revise Section 8.1.1 to include provisions for sediment and surface water sampling of the Unnamed Tributary or include a valid, technical justification for not conducting these activities. Section 8.1.2 Elimination of Selected Monitoring Parameters 15. Section 8.1.2 includes a request to delete the contaminant xylene from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. This request is denied because xylene was detected at groundwater monitoring well NS-29 at 1,200 micrograms per liter (µg/L) in the Fourth Quarter of 2000 and the performance standard for xylene is 350 µg/L. Revise Section 8.1.2 accordingly. 16. Section 8.1.2 includes a request to delete the contaminant 4-nitrophenol from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. However 4-nitrophenol was not analyzed at the proper detection limits at groundwater monitoring well NS-29 in the Fourth Quarter of 2000 in order to ascertain the presence or absence of the contaminant in excess of the performance standard. Therefore this request is denied. Revise Section 8.1.2 accordingly. 17. Section 8.1.2 includes a request to delete the contaminant arsenic from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. This request is denied because arsenic was detected at groundwater monitoring well NS-30 at 3 7 .2 µg/L in the Fourth Quarter of 2000 and the performance standard for arsenic is 10 µg/L. Revise Section 8.1.2 accorclingly. I 8. Section 8.1.2 includes a request to delete the contaminant chromium from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. However, chromium has been detected at groundwater monitoring well NS-29 in increasing concentrations for the last two years. Therefore, this request is denied. Revise Section 8.1.2 accordingly. I .. Mr. Jon Bornholm September 26, 200 I Page 5 • • 19. Section 8.1.2 includes a request to delete the contaminants beryllium, cadmium, and zinc from the list of monitoring parameters for the Plume Periphery Extraction and Monitoring Wells. This request is approved because these constituents have not been detected in excess of the performance standards since the Fourth Quarter of 1997 or before. However, revise Section 8.1.2 to include the NC DENR Division of Water Quality (DWQ) provisions for site closure as they apply to the revision of monitoring requirements. Specifically the NC DENR DWQ provisions state that: 1) the faciJjty must demonstrate four (4) consecutive quarterly sampling events in which all constituents of concern are below North Carolina and federal groundwater standards prior to discontinuing operation of the groundwater extraction and treatment system; 2) the facility must submit to the US EPA and the NC DENR a written request to discontinue operation of the groundwater extraction and treatment system and must receive written authorization from the US EPA and the NC DENR prior to suspending extraction and treatment activities; and, 3) the facility must demonstrate that all constituents of concern continue to remain below applicable North Carolina and federal groundwater standards for four (4) consecutive quarterly sampling events following suspension of groundwater extraction and treatment activities. Section 8.1.3 Statement of Protectiveness 20. The first sentence of Section 8.1.3 indicates that the OU! remedial action is protective of human health and the environment. However, the first sentence of Section 8.1.1 states, "Groundwater data collected from OU I during the monitoring program indicates that the PPES is not an effective remedy for controlling groundwater impacts and preventing impacted groundwater from migrating toward the area of the Northeast Tributary." Revise Section 8.1 to resolve these inconsistencies. Section 8.2 OU3 21. The third sentence of Section 8.2 states, "While a statistical data analysis cannot be performed to validate the level of protectiveness of the remedy, the OU3 remedial action appears to attain the desired level of protectiveness for human health and the environment by preventing further migration of the plume bases on the initial data collected following the startup of the OU3 extraction system." Provide an explanation and the supporting evidence for this statement. Mr. Jon Bornholm September 26, 200 I Page 6 Section 8.3 OU4 • • 22. The first sentence of the last paragraph of Section 8.3 states, "The OU4 remedy appears to be protective of human health and the environment because the OU3 remedial action appears to be effective and there is limited opportunity for exposure to impacted soil in the Plant Area." Provide the supporting documentation for these claims. Note that the remedy for OU4 is not a no further action remedy and therefore Section 8.3 should be revised to discuss the effectiveness of the remedy for OU4 and not reliance upon the effectiveness of the remedy of OU3. • September 21, 200 I To: Dave Mattison, Superfund Section From: Daphne Olszewski, Hazardous Waste Section ~ Re: Comments on the Draft Final Five Year Review Report National Starch Chemical Company (NSCC) Salisbury, NC NCO 000 623 116 • I realize that I am used to the RCRA program where the type of information I refer to below is normally submitted in semi-annual monitoring and effectiveness reports. Use these comments for what you think they are worth, indeed if you wish to use any of them at all. Sometime when you have a chance, I would like to talk to you about what you expect in a five- year review. I printed out the guidance, and the main thing seems to be to determine if the remedy is functioning as intended. I don't know how to get that information out _of this report without either checking other reports to see if what I look for in an effectiveness evaluation report is located elsewhere, or contouring and drawing maps and cross-sections of the data myself. I didn't have time to review this report in depth, but here are some of my "big picture" concerns. I+ When I evaluate effectiveness reports for my facilities, I am used to having something other than tabular data to review. The only detailed map of the facility is Figure 2, a site map with well locations. Where are the potentiometric surface maps, the isoconcentration maps (both plan and cross-sectional views), etc? Historical map(s) for comparison would be very useful -where was the plume 5 years ago, and what were the concentrations found? Has the area of the plume decreased in size and concentration as a result of the pumping? /♦ Analyses of the extraction well system is something that wasn't really addressed in this report. How many gallons were pumped and what are the removal rates for the individual extraction wells? Is there any evaluation to determine if certain extraction wells are declining in efficiency through time? Are there any problems with the wells so that they do not operate continuously ( e.g. biofouling that requires periodic pump maintenance, or drawndown below the set point so that the extraction well cycles on and off)? What levels of the aquifer are the extraction wells pumping from (saprolite/PWR/bedrock) and are there different configurations of hydraulic control for the different levels? There is just not much information in this report other than the tabular geochemical data. ♦ The 1998 report attachment (Ground-Water Data Evaluation for Plume Periphery and Trench Area Extraction Wells) states that "detection limits for VOCs are greater than the ROD Perforn1ance Standards used during some of the monitoring events even for samples analyzed at a dilution factor equal to one. [ ... ) Therefore the analytical method for VOCs - I - • • Comments on National Starch's Draft Final Five Year Review Report September 21, 200 I should be changed to a USEPA-Approved method (e.g., SW-846) that can achieve detection limits equal to or less than the ROD Performance Standards." Has the analytical method been changed to a more appropriate one? Are VOCs the only problem as far as detection limits? A request to review the lab's detection limits, or at least a strong statement in the correspondence back to NSCC that says the DL must be less than the ROD performance standard is fairly critical. ♦ OU-I: The attachment, Ground-Water Data Evaluation for Plume Periphery and Trench Area Extraction Wells, does address why NSCC believes the remedy is not effective (although the main report does not). Since they have observed an increasing trend from Mann-Kendall (statistical?) Tests, they decided to turn off the plume perimeter extraction wells, and plan to re-evaluate their remedial options here. I am not a statistician, but the total number of tests is only thirty, with 16 for VOCs, 8 for SVOCs, and 6 for metals. Someone who is a statistician (at EPA?), and who is familiar with this test should see if this number of samples is statistically valid. Also, when they say there were 4 VOCs, I SVOC, and 2 metals considered for these tests, does that mean that for VOCs there were 4 VOC constituents with 4 tests run per constituent (versus 16 tests on each of the 4 constituents?). The information given here is ambiguous. Another thought is that NSCC did not have to remediate the soil, which acts as a continuing source to the groundwater. It is possible that a decrease in the groundwater samples might not be expected until the soil has been flushed more? The main concern is that they didn't wait for approval to turn off these extraction wells, they just did it (this would be a Class 3 -- the most involved type of permit modification for RCRA). ♦ OU-3: The report mentions monitoring wells located outside the zone of hydraulic control, and lists them. What is the relationship of where there is hydraulic control and where the most contaminated part of the plume is? This is where map(s) would definitely help. The report also states that OU-3 cannot be comprehensively evaluated at this time due to the limited data currently available. Then they state that "the initial data indicate that the extraction system is effective in containing groundwater in the areas of impacts and wells outside the zone of hydraulic control have not exhibited an increase in concentration." NSCC should document how the initial data indicate that the extraction system is effective in containing groundwater in areas of impact. The fact that the wells outside the hydraulic control zone have not exhibited an increase in concentration could be attributable to this being an area of the dissolved plume. If the source (DNAPL) portion of the plume is hydraulically controlled, this part of the plume effectively becomes a slug which, without further sourcing, will begin to attenuate. What are the levels in this part of the plume, and are those levels such that they will be below risk-based levels - 2 - • • Comments on National Starch's Draft Final Five Year Review Report September 21, 200 I upon reaching receptors? Another question that I had is that the report refers to the DNAPL sourcing. Do they have a handle on where the DNAPLs are? If so, this is important information to pass on. ♦ OU-2: Not having a background with this facility, I am not sure why OU-2, unlike OU-4, doesn't have any type of sampling required to show that degradation of constituents in the soil is occurring, and at what rates. I am assuming that the levels in OU-2 are either much lower than the levels in the soil at OU-4, or are not a threat to a receptor. It is, however, puzzling. ♦ Section 8-5 makes it sound like NSCC plans to go ahead and delete the parameters listed without waiting for approval. In RCRA, the dropping of parameters always has to requested and then approved in writing for non-permitted facilities, and is a Class 3 permit modification for a permitted facility. I went ahead and checked these constituents, and my findings based on the tabulated data are that it's okay to drop xylene, but since they have to sample for VOCs anyway, what is the point? This is also true for 4-nitrophenol; they will still have to extract and analyze samples for bis(2-chlorethyl)ether, so why drop this parameter? Indeed, 4-nitrophenol is found in two wells (EX-08 and EX-09) where they plan to keep sampling for this constituent. My advice would be to just keep reporting it; the lab will have to analyze for it anyway. Arsenic was found in 4th Quarter 2000 in NS-30 of the Plume Periphery Extraction and Monitoring Wells at 37.2 ug/1 (ROD performance standard is IO ug/1). Also, for the Trench Area, arsenic has been found in two wells above the ROD performance standard as recently as 4th Quarter 1998. This particular compound is one that has come under intense scrutiny lately, and the proposed 2L standard is 0.20 ug/1. I disagree that arsenic should be dropped from the sampled constituents. Other parameters that NSCC would like to drop are Be, Cd and Cr with no hits above ROD Performance standards since 1998, but I can't make the call there. RCRA requires a minimum of 3 years below applicable standards before a constituent can be dropped from monitoring. Is there a specific time frame for that in CERCLA? Zn can, in my opinion, be dropped. Whatever the evidence, NSCC Starch should not be allowed to drop parameters without pre-approval. cc: Central Files re: Kathy Lawson Linda Culpepper NS_ SF5yrrcportrevicwmemo. wpd - 3 - • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER . 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3104 Spetember 5, 2001 4WD-NSMB SUPERFUN_Q_SECTION Mr. David Mattison North Carolina Department of Environment & Natural Resourccs/Superfund Section Suite 150 401 Oberlin Road Raleigh, NC 27605 SUBJ: Request to Review the Draft Five-Year Review Repott on All Operable Units for the National Starch & Chemical Company SLiperfund Site Dear Mr. Mattison: Enclosed for the State's review and Site file are two copies of the above referenced document, dated August 200 I. This report was prepared on National Starch & Chemical Company's behalf, by their contractor Blasland, Bouck, & Lee, Inc. Please review this document. EPA recently published the following document, Comprehensive Five-Year Review, June 2001. This guidance document can be accessed at the following web address: http://www.epa.gov/superfund/resources/5 year/index .ht m The Agency would appreciate receiving the State's comments/concerns and/or approval by Wednesday, September 26, 2001. If the State is unable to provide comments/approval by this date, please inform the Agency as to when a response can be expected. If you have any questions, I can be reached at 404-562~8820. Sincerely, jK6~V Jon K. Bomholm - Remedial Project Manager Enclosures 1. Draft Five-Year Review Report for the National Starch & Chemical Company Superfund Site • • · FIVE-YEAR REVIEW REPORT FIRST FIVE-YEAR REVIEW REPORT FOR THE ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE SEPTEMBER 2002 Prepared by: U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 4 Atlanta, Georgia • • USEPA Five Year review Signature Page SITE NAME: National Starch & Chemical Company EPA ID: NCD003 I 88828 SPILL ID 0402 REGION: 04 I STATE: NC CrrYiCOUNTY: Salisbury/Rowan County LTRA (highlighted): y ,w ~ CONSTRUCTION COMPLETION DATES: OPERABLE UNIT #1: March 1996 PRP LR OPERABLE UNIT #2: No Action OPERABLE UNIT #3: February 2000 OPERABLE UNIT #4: April 2007 (target) FUND/PRP LEAD: PRP NPLSTATUS: Listed on NPL LEAD AGENCY: EPA, Region 4 WHO CONDUCTED THE REVIEW (EPA REGION, STATE, FEDERAL AGENCIES OR CONTRACTOR? EP.A, Region 4 DATES REVIEW CONDUCTED: July 200 I -September 2002 DATE(S) OF SITE VISIT: March 22, 2000 WHETHER FIRST OR SUCCESSIVE REVIEW: Successive Review TYPE OF REVIEW (highlighted): DUE DATE: September 2002 Statutory Politr, TRIGGER FOR Tms REVIEW (Name and Date): Operable Unit #2 Five-Year Review Report (August 1998) RECYCLING, REUSE, REDEVELOPMENT SITE (highlight): Yes Nil Issmis: A list of issues were identified. See attached report, Section 8.0 -ISSUES. RECOMMENDATIONS: Recommendations arc listed in the attached report, Section 9.0 -RECOMMENDATIONS AND FOLLOW0 UP ACTION. PROTECTIVENESS STATEMENT(S): The portion of the Site remedi dealing with potential soil exposures is protective of human health and the environment in the short-term. The Trench Area, Area 2, and the lagoon area remain covered and the deed restrictions are in place. At the conclusion of Phase 2 of the Natural Degradation Treatability Study in 2007, a definitive answer should be made regarding long-term protectiveness and the contingency in the October 1994 OU #4 ROD will either be implemented or deleted from the OU #4 ROD. There are no current onsite groundwater receptors and the nearest private, potable wells is located approximately 2,700 feet north of Area #2. Since there is currently no indication of contaminated groundwater or surface water exiting the property, the remedy is considered protective in the short-term. Groundwater at the Site is not protective of human health and the environment in the long-tenn due to the fol19wing reasons: the current groundwater monitoring system is insufficient to determine if the plumes are being captured, groundwater is likely migrating to a degree and discharging to adjacent surface · water, groundwater performance standards are not being met throughout the plume, and groundwater is not currently "restored", as some of ARARs are lower than the ROD standards. The next Five Year review should be scheduled five years from the date of this Review, in September 2007. APPROVAL OF US EPA DIVISION DIRECTOR: Ri ard D. Green n(r ctor Waste Managemen Division Date • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE TABLE OF CONTENTS SECTION PAGE No. EXECUTIVE SUMMARY ................................................. v111 1.0 INTRODUCTION ................................................... I 2.0 SITE CHRONOLOGY ............................................... 2 3.0 BACKGROUND .................................................... 2 3.1 PHYSICAL CHARACTERISTICS ..................................... 2 3.2 LAND AND RESOURCES USE ...................................... 3 3.3 HISTORY OF CONTAMINATION ................................... 10 3 .4 INITIAL RESPONSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 3.5 BASIS FORT AKING ACTION ..................................... 11 4.0 REMEDIAL ACTION ................................................ 12 4.1 REMEDY SELECTION ........................................... 12 4.1.1 OPERABLE UNIT #I REMEDIAL ACTION OBJECTIVES ............ 13 4.1. i. i OPERABLE UNIT# I REMEDIAL ACTION COMPONENTS . . . 13 4.1.2 OPERABLE UNIT #2 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . 15 4.1.2. i OPERABLE UNIT .#2 REMEDIAL ACTION COMPONENTS . . . 15 4.1.3 OPERABLE UNIT #3 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . I 5 4.1.3. J OPERABLE UNIT #3 REMEDIAL ACTION COMPONENTS ... 16 4.1.4 OPERABLE UNIT #4 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . 16 4.1.4.1 OPERABLE UNIT #4 REMEDIAL ACTION COMPONENTS . . . 17 4.2 REMEDY IMPLEMENTATION ...................................... 18 4.3 SYSTEM OPERATIONS/OPERAT!ON AND MAINTENANCE ............... 21 5.0 PROGRESS SINCE. THE LAST FIVE-YEAR REVIEW .................... 21 6.0 FIVE-YEAR REVIEW PROCESS ..................................... 25 6.1 ADMINISTRATIVE COMPONENTS ................................. 25 6.2 .COMMUNITY INVOLVEMENT/COMMUNITY INTERVIEWS ............... 25 6.3 DOCUMENT REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 6.4 ARAR REVIEW ............................................... 25 6.5 DATA REVIEW ............................................... 27 6.6 SITE INSPECTION .. : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 II • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE TABLE OF CONTENTS SECTION PAGE No. 7.0 TECHNICAL ASSESSMENT ........................................ 29 7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENT? ................................. · . 30 7.2 QUESTIONS B: ARE THE EXPOSURE ASSUMPTIONS,TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES_ USED AT THE TIME OF THE REMEDY STILL VALID? ................... 55 7 .3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? . . . 55 8.0 ISSUES .......................................................... 55 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ................... 56 10.0 PROTECTIVENESS STATEMENT .................................... 56 11.0 NEXT REVIEW ....................................... : . . . . . . . . . . . 56 APPENDICES APPENDIX A --FIVE-YEAR REVIEW QUESTIONNAIRES APPENDIX B --LIST OF DOCUMENTS REVIEWED APPENDIX C --SEPTEMBER 25, 2002 CONCURRENCE LE'ITER FROM NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE TABLES TABLE PAGE No. TABLE I CHRONOLOGY OF SITE EVENTS ......................................... 4 TABLE2 MAJORITYOFCONTAMINANTSDETECTEDATTHESITE ..................... 14 TABLE 3 PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS ..................................... 31 TABLE 4 HISTORICAL 7\NAL YTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ....... 34 TABLE 5 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOR:OPROPANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY.SYSTEM OF OU# I ....... 35 TABLE 6 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR METHYLENE CHLORIDE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ....... 36 TABLE 7 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR BIS(2-CHLOROETHYL)ETHER FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEMOFOU#l ................................ 37 TABLE 8 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU# l ................. 38 TABLE 9 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #1 ................. 39 TABLE 10 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR TOLUENE FOR WELLS ASSOCIATED.WIHI HIE TRENCH AREA OF OU #1 .................... 40 TABLE 11 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR BIS(2-CHLOROETHYL)EHIER FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #1 ......................................... 41 TABLE 12 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 .................................. 42 TABLE 13 HISTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 ................ 42 TABLE 14 HISTORICAL ANALYTICAL SURFACE WATER/SEDIMENT DATA FOR THE UNNAMED TRIBUTARY ....................................... 43 TABLE 15 HISTORICAL ANALYTICAL DATA FOR 1,2-DICHLOROETHANE IN SURFACE WATER/SEDIMENT FOR THE NORTHEASTTRJBUTARY ............... 44 TABLE 16 LIST OF SIGNIFICANT ISSUES .......................................... 55 TABLE 17 SUMMARY OF RECOMMENDATIONS AND FOLLOW-UP ACTIONS ............... 57 IV • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE FIGURES FIGURE PAGE No. FIGURE l SITE LOCATION .................................................... 7 FIGURE 2 FEATURES AROUND THE NATIONAL STARCH & CHEMICAL COMPANY FACILITY . . 8 FIGURE 3 LAYOUT OF NATIONAL ST ARCH & CHEMICAL COMPANY FACILITY ............. 9 FIGURE4 COMPONENTS OF OU #1 GROUNDWATER REMEDIATION SYSTEMS ............. 22 FIGURE 5 COMPONENTS OF OU #3 GROUNDWATER REMEDIATION SYSTEMS ............. 23 FIGURE 6 NATURAL DEGRADATION TREAT ABILITY STUDY PHASE 2 SAMPLING LOCATIONS . 24 FIGURE 7 GROUNDWATER ELEVATION CONTOUR MAP FOR OU# 1/OU #2 TRANSITION ZONE WELLS FOURTH QUARTER 1999 .................................. 45 FIGURE 8 GROUNDWATER ELEV A TION CONTOUR MAP FOR OU# 1/OU #2 BEDROCK WELLS -FOURTH QUARTER 1999 ...................................... 46 FIGURE 9 GROUNDWATER ELEVATION CONTOUR MAP FOR OU #3 SAPROLITE/ TRANSITION ZONE WELLS -THIRD QUARTER 2000 .............. : .......... 47 FIGURE 10 GROUNDWATER ELEV A TION CONTOUR MAP FOR OU #3 BEDROCK WELLS -THIRD QUARTER 2000 ....................................... 48 FIGURE 11 SURFACE WASTE SAMPLING LOCATIONS FOR MARCH 1987 ................. 49 FIGURE 12 SEDIMENT SAMPLING LOCATIONS FOR MARCH 1987 ...................... 50 FIGURE 13 JUNE 2000 SURFACE WATER/SEDIMENT SAMPLING LOCATIONS ON UNNAMED TRIBUTARY .............................................. 51 FIGURE 14 JUNE 1987 SURFACE WATER/SEDIMENT SAMPLING LOCATIONS ON NORTHEAST TRIBUTARY ............................................ 52 I;JGURE 15 CURRENT SURFACE WATER/SEDIMENT SAMPLING LOCATIONS ON NORTHEAST TRIBUTARY ............................................. 53 V • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE AC! AOC ARARs CAA CD CERCLA CFR coc COD CT CWA DNAPL 1,2-DCA EPA ESA ESD FS ft/day ft/yr GC/MS gpm HRS MCL 15A NCAC 2B 15A NCAC 2L NCDEM NCDENR NCP NPL NSCC O&M OU LIST OF ACRONYMS Acceptable Chronic Intake concentrations Administrative Order on Consent Applicable or Relevant and Appropriate Requirements Clean Air Act Consent Decre€- Comprehensive Environmental Response, Compensation, and Liability Act of 1980 , Code of Federal Regulations Chemical of Concern Chemical Oxygen Demand Collection Trench Clean Water Act Dense Non-Aqueous Phase Liquid 1,2-Dichloroethane U.S. Environmental Protection Agency Endangered Species Act Explanation of Significant Difference Feasibility Study feet per day feet per year Gas Chromatograph/Mass Spectrograph gallons per minute Hazardous Ranking System Maximum Contaminant Level North Carolina Administrative Code Title 15A Subchapter 2B (NCAC ISA-2B), Classification and Water Quality Standards Applicable to the Surface Waters and Wetlands of North Carolina North Carolina Administrative Code Title 15A Subchapter 2L (NCAC l5A-2L), Groundwater Classification and Standards North Carolina Department of Environmental Management North Carolina Department of Environment and Natural Resources National Contingency Plan National Priority List National Starch & Chemical Company Operation and Maintenance Operable Unit VI • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE ppb, PPES ppm POTW PRP ·pvc RA RAOs RD RD/RA RP RI Rl/FS ROD RPM SDWA SARA OU SVOCs TCLP UAO µg/kg µgll voes LIST OF ACRONYMS parts per billion Plume Periphery Extraction System Parts per Million Publically Owned Treatment Works (local sewer system) Potentially Responsible Party Polyvinyl Chloride Remedial Action Remedial Action Objectives Remedial Design Remedial Design/Remedial Action Reference Doses Remedial Investigation Remedial Investigation/Feasibility Study Record of Decision Remedial Project Manager Safe Drinking Water Act Superfund Amendments and Reauthorization Act of 1986 Operable Unit Semi-Volatile Organic Compounds Toxicity Characteristic Leaching Procedure Unilateral Administrative Order microgram per kilogram microgram per liter Volatile Organic Compounds Vil • • FIRST FIVE-YEAR REVIEW REPORT for the ENTIRE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE EXECUTIVE SUMMARY The remedies for Operable Unit #1 and Operable Unit #3 at the National Starch & Chemical Company Superfund site in Salisbury, North Carolina include groundwater extraction and on-site treatment of contaminated groundwater. The treated groundwater is discharged to the City of Salisbury sewer system. The Record of Decision for Operable Unit #2 specified "No Action" for the contaminated soils in the Trench Area since the contaminants that migrate into the aquifer via natural flushing by precipitation percolating through the contaminated soils are anticipated to be· captured by the Operable Unit# 1 groundwater extraction system. A natural degradation treatability study is currently being conducted for the contaminated soil associated with Operable Unit #4. The Operable Unit #4 Record of Decision is a contingent Record of Decision. If National Starch & Chemical Company cannot demonstrate that natural degradation of contaminants in the soil is occurring, then-a soil-vapor extraction system is to be installed. The first Five-Year Review Report for Operable Unit #1 was issued on June 18, 1996 and the . first Five-Year Review Report for OU #2 was issued in August 1998. This Five-Year Review Report covers all four Operable Units. The trigger for conducting this five-year review was the start date for the construction of the plume periphery extraction system for Operable Unit #1 on August 14, l 990. The assessment of this Five-Year Review found that the remedies for Operable Unit #1 and Operable Unit #3 were constructed in accordance with the requirements of the September 30, 1988 Record of Decision for Operable Unit #1 and the October 7, 1993 Record of Decision for Operable Unit #3. The Record of Decision for Operable Unit #2, dated September 28, 1990, was a no action Record of Decision and therefore, no remedial action was implemented with regard to Operable Unit #2. National Starch & Chemical Company is currently conducting a natural degradation treatability study in accordance with the October 6, 1994 Record of Decision for Operable Unit #4. Two Explanation of Significant Differences, dated June 10, 1997 and September 28, 1990, were prepared for Operable Unit #3. The first Explanation of Significant Difference was issued to specify the type of treatment to be used on the contaminated soils generated during the installation of the components of the Operable Unit #3 remedial action. The second Explanation of Significant Difference substituted an interception trench for a number of extraction wells. Part of the Operable Unit #1 remedy (the Trench Area extraction wells) and the entire Operable Unit #3 remedies are functioning as designed. National Starch & Chemical Company is currently evaluating the effectiveness of the plume periphery extraction wells of the Operable Unit #1 remedy which requires these wells to be temporarily shut-down. The immediate threats associated with the four Operable Units have been addressed and these remedies are expected to be protective until groundwater cleanup goals are achieved through groundwater extraction and monitored natural attenuation. The clean-up of the Site is expected to require more than 120 years. Vlll • · First Five-Year Review Report for the Entire • National Starch & Chemical Company Superfund Site Salisbury, North Carolina 1.0 INTRODUCTION The purpose of a five-year review is to determine whether the remedy(ies) at a Superfund Site is(are) protective of human health and the environment. The methods, findings, and conclusions of this review are documented in a Five-Year Review Report In addition, Five-Year Review Reports identify issues found during the review, if any, and identify recommendations.lo address them . . The Agency has prepared this Five-Year Review Report for the entire National Starch & Chemical Company (NSCC) Superfund Site pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund) and the National Contingency Plan (NCP). CERCLA § 121 states: If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less· often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgement of the President action is appropriate at such site in accordance with section I 04, the President shall take or require such action. The President shall report to the Congress.a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews. The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states: If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted. exposure, the lead agency shall review such action no less often then every five years after the initiation of the selected remedial action. The United States Environmental Protection Agency (EPA or Agency), Region 4, conducted the five-year review of the remedies implemented at the NSCC Superfund Site in Salisbury, North Carolina. This review was conducted by the Remedial Project Manager (RPM) in conjunction with North Carolina Department of Environment and Natural Resources (NCDENR) with the assistance of NSCC for the entire Site from July 2001 through August 2002. This report documents the results of the review. • 2 A Fi vc-Year Review Report National St~ Chemical Company Superfund Site September 2002 The first Five-Year Review Report, dated June 18, 1996, covered Operable Unit #1 (OU #1) and the second Five-Year Review Report, dated August 1998, covered OU #2. This five-year review is for the entire NSCC Site (i.e., all four OUs). The triggering action for the June 18, 1996 Five-Year Report was the initiation of the OU #1 remedial action on August 14, 1990. The June 1996 Five-Year Review Report specified it was a statutory review as hazardous substances, pollutants, or contaminants remain on Site that would not allow unlimited use of the Site. 2.0 SITE CHRONOLOGY Table 1 lists the major milestones for CERCLA related work at-the Site. 3.0 BACKGROUND 3.1 PHYSICAL CHARACTERISTICS The NSCC site is located on Cedar Springs Road, approximately 5 mile:; south of the City of Salisbury, in Rowan County, North Carolina. Figure 1 shows the location of the Site with respect to the City of Salisbury and Figure 2 identifies the features around the NSCC facility. As can be seen, commercial, industrial, and residential developments surround the Site. Grants Creek forms the western boundary. Two separate tributaries of Grants Creek, the Unnamed Tributary (Southwest Tributary) and the Northeast Tributary, are located in the southwest and northeast portions of the Site, respectively. Figure 3 highlights the locations of the structures/facilities on the NSCC property and the general locations of the four OUs. OU #1 focuses on contaminated groundwater in the western portion of the NSCC property and the surface water/sediment in the Unnamed Tributary (refer to Figure 3); OU #2 concentrates on the Trench Area soils in the western portion of the NSCC property (refer to Figure 3); OU #3 deals with the contaminated groundwater· under Area 2, the parking lot, and the wastewater treatment lagoons and the surface water/sediments in the Northeast Tributary (refer to Figure 3); and OU #4 centers on the contamin_ated soils in and around Area 2 and the wastewater treatment lagoons (refer to Figure 3). Area 2 includes the following features: Area 2 reactor room, the tank room, raw material bulk storage, the warehouse, and an abandoned underground terra-cotta pipe line that ran from the Area 2 reactor room to the wastewater treatment lagoons. The lagoon area includes three lagoons which were originally constructed as unlined lagoons between 1969-1970. Underlying the ground surface at the Site is saprolite; a clay-rich, unconsolidated material derived from in-situ weathering of the underlying bedrock. A transition zone between the saprolite and competent bedrock consists of saprolite, partially weathered rock, and competent rock fragments to boulders. The transition zone represents a zone of greater weathering than the competent bedrock, but lesser weathering than the saprolite. The transition zone averages between five and 122 feet in thickness and appears to underlie the entire facility. The depth of bedrock ranges from JO to 125 feet below ground surface. • • Five-Year Review Report National St & Chemical Company Superfund Site September 2002 3 The saprolite and transition zones collectively act as the storage zone for groundwater. The bedrock generally has low primary porosity and therefore does not act as an important storage zone. More groundwater flow occurs in the transition zone than in the saprolite, this is mainly due to differences in conductivity and effective porosity. Groundwater flow in the fractured bedrock is through secondary porosity, which is primarily in the form of vertical or high angle fractures. These three lithological units are hydraulically interconnected with little impedance between them. . Water level measurements from the water table/saprolite zone of. the aquifer indicate that hydraulic heads decrease from both the east and west toward either the Unnamed Tributary or the Northeast Tributary. This indicates that these tributaries act as groundwater divides for the underlying aquifer. The hydraulic conductivity of the saprolite materials and the bedrock ranges from 0.72 to 3.35 feet per day (ft/day) and 0.0 I to 1.13 ft/day, respectively. Based on the above information, the horizontal flow of groundwater in the saprolite was estimated to have a velocity of 80 feet/year (ft/yr) in the lagoon area and 27 ft/yr in Area 2. 3.2 LAND AND RESOURCES USE The groundwater beneath the NSCC property is designated as Class GA in accordance with North Carolina's water classification system and Class !IA under USEPA Groundwater Classification Guidelines (December 1986). The Class GA classifications means that the groundwater is an existing or potential source of drinking water supply for humans as specified under North Carolina Administrative Code, Title 15, Subchapter 2L (NCAC 15-2L.02). EPA classifies the groundwater as Class !IA since the aquifer is currently being used as a source of drinking water in the vicinity of the NSCC facility. . . Neither the Unnamed Tributary nor the Northeast Tributary are specifically classified due to the low flow conditions within these streams. However, these streams are considered Class "C" under North Carolina Administrative Code, Title !SA, Subchapter 2B (NCAC ISA-2B.02) because the receiving stream, Grants Creek, is classified as a Class C stream. A Class C stream is defined as being suitable for secondary recreation and the "propagation of natural trout and maintenance of trout." Land use of the areas immediately adjacent to the NSCC property is a mixture of residential and industrial developments (refer to Figure 2). An industrial park is-located on the east and south sides of the NSCC facility. Another industrial park is located along the southern property line. A mobile home park adjoins the extreme southwestern comer of the property. Two. housing developments lay to the north, one of which is adjacent to the facility property. The location of the nearest private, potable wells is approximately 2,700 feet north of Area #2. • 4 TABLE 1 --CHRONOLOGY OF SITE EVENTS EVENT Proctor Chemical Company purchased the 465-acre tract Construction of facility Proctor Chemical Company dissolved and merged with NSCC Site proposed for National Priorities List Special notice letter to conduct Remedial Investigation/Feasibility Study • Five-Year Review Report nal Starch & Chemical Company Superfund Site September 2002 DATE September 1968- 1970 January I, 1983 April 1985 May 30, 1986 Administrative Order on Consent signed -De_c;_ember I, 1986 Remedial Investigation/Feasibility Study (RI/FS) Work Plan December 1986 Amended RI/FS Work Plan July 1987 Site re-proposed for National Priorities List June 1988 First Remedial Investigation (RI) Report [for Operable Unit (OU) #I] June 21, 1988 First Feasibility Study (FS) Document (OU #1) September 8, 1988 Proposed Plan Fact Sheet September 1988 Proposed Plan Public Meeting (OU #I) September 14, 1988 Proposed Plan public comment period (OU #1) September 3 -24, 1988 OU# I Record of Decision (ROD) Signed, divided Site into two OUs, September 30, 1988 created OU #2 Issued Special Notice Letter to Conduct Remedial Design/Remedial March 27, I 989 Action for OU #I Unilateral Administrative Order issued to perform OU #I Remedial July 27, 1989 Design/Remedial Action (RD/RA) Site finalized on National Priorities List October 1989 Supplemental Remedial Investigation Report for OU #2 May 1990 Initiation of OU# I construction -building access roads to bedrock plume August 14, 1990 periphery extraction well locations Installation of four bedrock plume periphery extraction wells August 30-November 14, 1990 Proposed Plan for OU #2 July 1990 Proposed Plan public comment period July 30 -August 29, 1990 • 5 TABLE 1 --CHRONOLOGY OF SITE EVENTS EVENT Supplemental Feasibility Study Document for OU #2 ROD for OU #2 signed, divided Site into three OUs, created OU #3 Consent Decree for OU #2 OU #3 Remedial Investigation Report -OU #3 Feasibility Study Document - Proposed Plan Fact Sheet for OU #3 Co'nstruction of trench area extraction wells+ pretreatment system OU #3 Proposed Plan Public Meeting Proposed Plan public comment period Record of Decision for OU #3 signed, divided Site into 4 OUs, created OU#4 OU #4 RI Report (used June 1993 OU #3 Remedial Investigation) OU #4 Feasibility Study Document Proposed Plan Fact Sheet for OU #4 OU #4 Proposed Plan public comment period OU #4 Proposed Plan Public Meeting Record of Decision for OU #4 Unilateral Administrative Order for OU #3 and OU #4 RD/RA Initiated OU #3 and OU #4 Remedial Design Construction Completion for OU# I Remedial Action First Five-Year Review Report (for OU #I) Initiated OU #4 Natural Degradation Treatability Study -Phase I First Explanation of Significant Difference Completed OU #4 Natural Degradation Treatability Study -Phase I OU #3 Remedial Design Completed • Five-Year Review Report nal Starch & Chemical Company Supcrfund Sile September 2002 DATE September 1990 September 28, 1990 CD signed August 1991, entered in Federal Court on July 20, 1992 June 2, 1993 June 21, 1993 July 15, 1993 July 1993 -February 1996 August 3, 1993 July 19-August 17, 1993 October 7, 1993 June 1993 June 20, 1994 July 8, 1994 July 12 -August 11, 1994 July 26, 1994 October 6, 1994 September 29, 1995 October 1995 March 1996 June 18, 1996 December 1996 June 10, 1997 March 26, 1998 June 1998 • 6 TABLE 1 --CHRONOLOGY OF SITE EVENi'S EVENT Second Explanation of Significant Difference Initiation of OU #3 Remedial Action Initiation of OU# l + OU #3 Combined Pretreatment System Completion of OU #l + OU #3 Combined Pretreatment System Construction Completion for OU #3 Initiated OU #4 Natural Degradation Treatability Study -Phase Jl First Site-Wide Five-Year Review Report Complete OU #4 Natural Degradation Treatability Study -Phase II Accept Findings of Soil Degradation Treatability Study or Implement Contingent Remedy Complete OU #1 Plume Periphery Evaluation Implement Recommendations of OU# 1 Plume Periphery Evaluation Second Site-Wide Five-Year Review Report Third Site-Wide Five-Year Review Report • Five-Year Review Report nal Starch & Chemical Company Supcrfund Site September 2002 DATE November 4, 1998 June 15, 1999 September 23, 1999 February 18, 2000 February 18, 2000 November 5, 2001 July 2002 Anticipated December 2002 February 2003 July 2003 September 2003 September 2007 September 2012 • • Five-Year Review Report National Sta Chemical Company Superfund Site 70 7 DAVIDSON COUNTY - ROWAN ------KAHHAPLOIS CASAARUS COUNTY SCALE: ---- 0 8 SITE LOCATION COUNTY 7 I September 2002 N \ 16 MIU:S FIGURE I SOURCES: ROWAN MILLS, CHINA GROVE, NORTH CAROLINA 7.5 MINUTE QUADRANGLE CONTOUR INTERVAL= 10 FEET QUADRANGLE LOCATION • 8 UTW GRID ANO 1987 MAGNETIC HORTH 0£CLINAf10N AT CENTER Of SHEET • Five-Year Review Report tional Starch & Chemical Company Superfund Site September 2002 2000' 0 2000' Approximate Scale: 1" ::: 2000' FEATURES AROUND THE NSCC FACILITY FIGURE 2 '11 0 C :,0 [Tl (;.) ... • - • 3.3 HISTORY OF CONTAMINATION A. Five-Year Review Report National St~ Chemical Company Superfund Site September 2002 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 I, 1983, Proctor Chemical Company was dissolved and its operations merged with NSCC. The primary products of this facility are 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 liquid waste stream from the manufacturing processes include reactor and feed line wash and rinse solutions. This wastewater may include a combination of the following chemicals: acrylimide, 1,2-dichloroethane (1,2-DCA), methyl isobutyl ketone, methanol, styrene, maleic anhydride, vinyl toluene, sulphonated polystyrene, epichlorohydrin, octyl alcohol, ethyl alcohol, ally! alcohol, ally! chloride, sodium hydroxide, and sulfuric acid. In general, the greatest concentrations of organic contaminants in the soil were found in four areas: in and.around the Trench Area, underneath Area 2, in and around the.terra-cotta pipeline, and north-northeast of the lagoon area. Based on a 1984 CERCLA 103(c) notification report filed by NSCC, from 1971 to 1978, NSCC disposed of approximately 350,000" gallons of DO02 waste (corrosive waste with pH,; 2.0) reaction vessel wash·waters in trenches constructed in a 5-acre tract of land (Trench Arca). Liquid effluent from the plant production area flowed into Lagoon I, which was unlined, and then was pumped to the Trench Area. Each trench was used until liquid no longer readily percolated into the ground. Afterwards the_ trench was backfilled and seeded, and a new trench was excavated. Since 1978, production plant process waters were directed to NSCC's pretreatment system and then discharged to the City of Salisbury publicly owned treatment works (POTW) (sewer system). In Area 2; two sources of contamination were identified: an underground terra-cotta pipeline and a solvent recovery system (distillation unit). The underground terra-cotta pipeline transported wastewater from the production area to the wastewater treatment lagoons. Terra-cotta piping was also used to control and direct surface water run-off from the plant area to the embankments of the Northeast Tributary. In February 1994, NSCC sealed the ends of the terra-cotta pipelines and replaced them with overhead pipelines. The solvent recovery system now sits on a concrete platform surrounded by a concrete berm so that any spills associated with the operation of this system are controlled and not released into the environment. In the lagoon area, the source of contamination was eliminated in I 984 when NSCC lined the lagoons with concrete. The contamination currently being detected in the soils and groundwater in these areas is the result of past practices and the residual contamination in the soil. 3.4 INITIAL RESPONSE The first environmental investigative work occurred in 1976 which included drilling 14 soil borings and the installation of eight polyvinyl chloride (PVC) monitoring wells within and around the Trench Area.· Surface water/sediment samples were also coBected during this time- • • Five-Year Review Report National St Chemical Company Superfund Site September 2002 11 frame but the locations of the sampling points were not recorded consequently, this data has little value. NSCC first sampled these wells in January 1977 and again in November 1977. North Carolina Department of Environmental Management (NCDEM) sampled three of these wells in June 1977 and resampled two of the same wells and a different well in January 1983. All of the samples discussed above were analyzed for only metals and general water chemistry parameters. As part of the 1977 assessment effort, NCDEM also sampled Grant Creek. In 1978, NCDEM augured 31 soil borings around the Site as well as collected groundwater samples. In June I 984, NC DEM resampled the same wells sampled in Janu·ary 1983. These samples were analyzed using a gas chromatograph/mass spec'trograph (GC/MS), but contaminant specific data was not generated. As a result of this sampling effort, NCDEM directed NSCC to run full sweeps on these wells. Consequently, NSCC collected groundwater samples from these wells in September and October [984. The results showed the presence of toluene, xylene, 1,2-DCA, I ,2-dichloropropane, and several other organics. NCDEM also sampled the Southwest Tributary as part of this effort. In 1984 and !985, North Carolina Department of Health Services, NSCC, and Rowan County Health Department sampled and resampled a number of nearby residential potable wells. None of the analyzes showed any detection of organic contaminants. NSCC also sample Grant Creek and the Unnamed Tributary in 1985. NSCC also sampled surface water conditions during three (3) different weather conditions: (I) after a 5-week dry period, (2) after a rainstorm, and (3) after a heavy rainstorm. However, the usefulness of the data generated from these efforts was very limited since these samples were only analyzed for chemical oxygen demand (COD) and pH. The NSCC Site was proposed for inclusion on the National Priorities List (NPL) in April I 985, re-proposed in June 1988, and finalized on the list in October 1989 with a Hazardous Ranking System (HRS) score of 46.51. The HRS score was 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. 3.5 BASIS FOR TAKING ACTION A number of contaminants have been detected in the soils, groundwater, and surface water/sedime[lt at the NSCC Superfund site. Table 2 lists the majority of contaminants that have been detected in these environmental media. Under EPA's risk management criteria, exposure to Site soil, groundwater, or surface water/sediment could result in unacceptable human health risks. The carcinogenic risks were highest for exposures to groundwater and soil due to the high concentrations of carcinogenic chlorinated volatile organic compounds (VOCs). Non-carcinogenic risks were highest for exposures to groundwater due to the elevated concentrations of metals in the groundwater. Potential risks associated with exposure to groundwater are attributed to the presence ofa variety of VOCs that exist at concentrations that exceed State and Federal applicable or relevant and appropriate requirements (ARARs). • 4.0 REMEDIAL ACTION 4.1 REMEDY SELECTION 12 ~ Fi vc-Year Review Report National St~ Chemical Company Superfund Site September 2002 Since there has only been one owner/operator of this property after being developed into an industrial complex, no "Responsible Party Search" was performed. NSCC has been and remains the sole owner/operator of the facility and therefore the only Potentially Responsible Party (PRP). A special notice letter was sent on May 30, 1986 to provide NSCC an opportunity to conduct the Remedial Investigation/Feasibility Study (RUFS). A good faith offer was submitted and negotiations were concluded with NSCC signing an Administrative Order on Consent (AOC) on December I, 1986. The first RUFS wa~completed on June 21, 1988 and September 8, 1988, respectively. Following the signing of OU #1 Record of Decision (ROD) on September 30, 1988, the Agency sent a special notice letter to NSCC to initiate negotiations on a Consent Decree (CD) for implementing the OU #I Remedial Design/Remedial Action (RD/RA). However, negotiations on the CD were not successful. The Agency issued NSCC an Unilateral Administrative Order (UAO) directing NSCC to design and implement the Remedial Action (RA) specified in the OU #I ROD. The effective date of the UAO was July 27, 1989. To date, NSCC is in compliance with the requirements of the July 1989 UAO. The OU #I ROD split the Site into two operable units. Working under the December 1986 AOC, NSCC generated a Supplemental Remedial Investigation (RI) Report and Feasibility Study (FS) document for OU #2. These reports were completed in May 1990 and September 1990, respectively. The Supplemental RI reported continued detections of contaminants in the Northeast Tributary but did not identify the source of this contamination. The OU #2 ROD, signed on September 28, 1990, was a no action alternative with regard to the soils in the Trench Area, however, this ROD did divide the Site into a third operable unit. Following the signing of the OU #2 ROD, the Agency sent NSCC another special notice letter in March 1991 to initiate negotiations on a CD. This CD governed the implementation of the OU #2 RA. The CD was signed in August 199 I and was entered by the Federal Court on July 20, 1992. To date, NSCC is in compliance with the requirements of the July 1992 CD. On December 4, 1991, EPA issued written notification to NSCC to conduct a third RI/FS to determine the source, nature, and extent of contamination entering the Northeast Tributary as required by the OU #2 ROD. As with the previous RI/FS efforts, the OU #3 RUFS was conducted in accordance to the December 1986 AOC. The OU #3 RI and FS reports were completed on June 2, 1993 and June 21, 1993, respectively. Due to an inadequate evaluation of source control remediation alternatives in the OU #3 FS document, the Agency decided to split the groundwater and source control efforts into OU #3 and OU #4, respectively. The OU #3 ROD was signed on October 7, 1993 and required a fourth operable unit. On October 12, 1993, EPA requested NSCC to initiate OU #4 in accordance to the December 1986 AOC. Since only the evaluation of the source control remediation alternatives was in question, the June 1993 OU #3 RI sufficed as the OU #4 RI report. The June 20, 1994 OU #4 FS was conditionally approved. by the Agency on July 8, 1994 and EPA issued the OU #4 ROD on October 6, 1994. In an effort • 13 A. Five-Year Review Report National St~ Chemical Company Supcrfund Site September 2002 to conserve resources, the Agency decided to negotiate the OU #3 and OU #4 RD/RAs together. Negotiations on a CD were unsuccessful. Consequently, EPA issued a second UAO to NSCC to implement the OU #3 and OU #4 remedies. The effective date of the UAO is September 29, 1995. To date, NSCC is in compliance with the requirements of the September 1995 UAO. Below are the remedial action objectives (RAOs) and the major components of each operable unit: 4.1.1 OU #1 RAOs • Extract contaminated groundwater from the transition and bedrock zones throughout the plume; • Pump extracted groundwater to treatment system for treatment; • Monitor the groundwater extraction and treatment systems; • Reduce mobility, toxicity, and volume of the contaminants in the aquifer; • Prevent further migration of groundwater contamination beyond its current extent; • Restore aquifer to Federal and State ARARs, including drinking water standards, and a level that is protective of human health and the environment within a reasonable period of time; and • Eliminate/minimize the threat posed to human health and the environment by preventing exposure to groundwater contaminants. 4.1.1.1 OU #1 RA Components • Install groundwater extraction system to capture the leading edge of the plume, plume periphery extraction system (PPES), and the heart of the plume (i.e., immediately downgradient of the Trench Area). • Treat the extracted groundwater through a train of treatment technologies that may include: air stripping, activated carbon filtration, and metal removal to achieve a quality of water that can be discharged to the City of Salisbury POTW. • Establish a monitoring program for groundwater and surface water/sediment; and • Conduct a supplemental RI (OU #2) to determine the source of contamination continually being detected in the surface waters. The ROD for OU #I did not specify a duration for the RA. 14 • · Five-Year Review Report al Starch & Chemical Company Superfund Site September 2002 TABLE 2 -MAJORITY OF CONTAMINANTS DETECTED AT THE SITE SOIL VOLATILE ORGANIC COMPOUNDS Acetone Bromodichloromethanc 2-Butanone Chloroform Dibromochloromethanc 1,2-Dichloroethane Tetrachloroethene Toluene Trichlorocthene Total Xylenes Vinyl Chloride PESTICIDE Delta-Hexachlorocyclohexane INORGANICS Antimony Arsenic Barium Beryllium Cadmium Chromium Manganese Nickel Selenium Thallium Zinc GROUNDWATER VOLATILE ORGANIC COMPOUNDS Acetone Bi s(2-chloroethyl)ether Benzene Bromodichloromethane Carbon Disulfide Chloroethane Chloroform 1,2-Dichloroethane 1, 1-Dichloroethene 1,2-Dichloroethene (cis/trans) 1,2-Dichloropropane Ethyl benzene Methylene Chloride Tetrachloroethene Toluene I, 1,2-Trichloroethane Trichloroethene Total Xylenes Vinyl Chloride SEMI-VOLATILE ORGANIC COMPOUNDS B is(2-ethylhex yl )phthalate Di-n-butyl Phthalate Di-n-octyl Phthalate 4-Nitrophenol INORGANICS Antimony Arsenic Barium Beryllium Cadmium Chromium Manganese Nickel Selenium Thallium Zinc SURFACE WATER/SEDIMENT VOLATILE ORGANIC COMPOUNDS 1,2-Dichloroethanc • • Five-Year Review Report National St Chemical Company Superfund Site September 2002 15 4.1.2 OU #2 RAOs • Capture contaminants leaching from the soils in the Trench Area as precipitation naturally infiltrates and flushes the contaminants from the soils into the groundwater (accomplished by OU #1); • Minimize the migration of contaminants into surface water; and • Reduce mobility, toxicity, and volume of the contaminants in the soils in Trench Area.to a point where the contaminants will no longer adversely impact the quality of the underlying aquifer. · _ 4.1.2.1 OU #2 RA COMPONENTS • No action remedy; • Monitored natural attenuation; • Monitor soils in the Trench Area on a quarterly basis; • Deed restriction to I) identify the area(s) of contamination, 2) prevent transfer of property to an uninformed purchaser, and 3) limit future utilization of the property; and • Conduct an RI (OU #3) to determine the source of contamination continually being detected in the surface waters in the Northeast Tributary. The ROD for OU #2 estimated 20 -30 years for the levels of contaminants in the soils to be reduced to a concentration where the contaminants will not adversely impact the quality of the underlying aquifer above the specified ARARs. 4.1.3 OU #3 RAOs • Operate groundwater extraction in the impacted areas; • Pump groundwater to the treatment system for treatment; . • Treat the groundwater in the combined OU #I and OU #3 pretreatment facility through equalization, hydrolysis, and air stripping; • Monitor groundwater and surface water/sediment in the Northeast Tributary; • Reduce mobility, toxicity, and volume of contaminants in the aquifer; • Prevent further migration of groundwater contamination (including a potential dense non- aqueous phase liquid (DNAPL)) beyond its current extent; • Five-Year Review Report National St Chemical Company Superfund Site September 2002 16 • Restore contaminated groundwater to Federal and State ARARs, including drinking water standards, and a level that is protective of human health and the environment within a reasonable period of time; and • Eliminate/minimize the threat posed to human health and t_he environment by preventing exposure to groundwater contaminants; 4.1.3.1 OU #3 RA COMPONENTS • Install a groundwater extraction system in Area 2 (interception trench) and the lagoon area (extraction wells); • Treat the extracted groundwater using air stripping and/or activated carbon filtration (metal removal is not warranted at this time due to their low concentrations) to achieve a quality of water that it can be discharged to the City of Salisbury POTW; • · Vapor emissions from the air stripping unit are to be controlled through catalytic oxidizing and scrubbing; • Establish a monitoring program for groundwater and surface water/sediment; and • Conduct FS (OU #4) to re-examine remediation options for the soils in this area of the NSCC facility. Two Explanation of Significant Differences (ESDs), dated June 10, 1997 and November 4, 1998, were prepared for OU #3. The first ESD was issued to specify that the contaminated soils generated during the installation of the OU #3 extraction wells were to be treated thermally to remove the VOCs from the soil. The vapor was treated prior to being released to the atmosphere. The second ESD substituted an interception trench for a number of extraction wells. All costs in the OU #3 ROD are based on running the groundwater extraction system for 30-years. ' 4.1.4 OU #4 RAOs • Implement a biodegradati ve study to substantiate the occurrence of natural degradation of contaminants in the soils at the Site and determine where and at what rate degradation is occurrmg; • Develop a long-term monitoring program to ensure natural degradat\on continues to be effective until the ROD soil Performance Standard for 1,2-DCA is achieved and maintained; • Reduce mobility, toxicity; and volume of the contaminants; • • -Fivt-Ycar Review Report National St. Chemical Company Superfund Site September 2002 17 • Eliminate or minimize the threat posed to human health and the environment by preventing exposure to groundwater contaminants; • For human health, prevent release of contaminants from soil that could result in contaminant levels in excess of groundwater cleanup objectives specified in the OU #3 ROD; and • For environmental protection, continue containment of contamination. 4.1.4. l OU #4 RA COMPONENTS OU #4 ROD contains a contingency. The components of the primary alternative (monitored natural attenuation) include: • Perform a "Biodegradative Study" to (I) substantiate that natural degradation of contaminants of concern in the soil is occurring in the OU #4 area, (2) identify where in the subsurface soils degradation is occurring, and (3) determine the rate of degradation; • Develop and implement a for long term monitoring plan to monitor the biodegradative process until the performance standards are achieved; • Implement institutional controls. Institutional controls include deed restrictions and maintenance of both the existing fence around the plant operations area and the paved areas around Area 2; • Develop a plan to protect workers in the event that the contaminated soils are to be excavated prior to the levels of 1,2-DCA reaching the appropriate direct contact health based risk concentration; • Conduct a five-year review in accordance with CERCLA Section 12l(c); In the event that the "Biodegradative Study" cannot substantiate the occurrence of significant natural degradation of l ,2-DCA and other contaminants of concern in the soil, or the study shows that degradation products increase the Site risks, the contingent remedy will be implemented. "Significant biodegradation" is defined as a statistically significant decrease in levels of contaminants of concern (particularly 1,2-DCA) that is coupled with multiple indicators of biological activity, which includes the appearance of degradation products such as, but not limited to, chloroethanc, ethane, vinyl chloride, cthene, carbon dioxide, hydrogen sulfide, methane, and soluble iron(II)) and the depletion of electron acceptors (including oxygen, nitrate, iron, sulfates, or others). The components of the contingent remedy include: • Install a soil-vapor extraction system above the water table to remove the volatile organic contaminants from the unsaturated zone and • • Five-Year Review Report National St Chemical Company Supcrfund Site September 2002 • Treat the extracted contaminated air from Area 2 using fume incineration to des"troy the volatile organics prior to the air stream being released into the atmosphere. After concentrations of contaminants decrease in the extracted air, this contaminated vapor may be treated via vapor-phase activated carbon adsorption filters. The extracted contaminated air from the lagoon area will be treated using vapor-phase activated carbon adsorption filters to remove _the volatile organics prior to the air stream being released into the atmosphere. The OU #4 ROD estimates it will take up to approximately 35-years to obtain the performance standard of 169 microgram per kilogram (µg/kg) or parts per billion (ppb) forl,2- DCA in soil through monitored natural attenuation. At this concentration, 1,2-DCA should not adversely impact the groundwater in the underlying aquifer above the ARAR for 1,2-DCA which is 1 microgram per liter (µg/1) or ppb. The OU #4 ROD also estimated the time-frame to achieve the ARAR for 1,2-DCA in groundwater to .be 130 years. 4.2 REMEDY IMPLEMENTATION The OU #1 RD/RA was implemented under the July 27, 1989 UAO. The OU #1 Remedial Design (RD) was approved by the Agency in 1990 and RA construction activities began on August 14, 1990. OU #I RA took place in three phases. The first phase of construction focused on the plume periphery extraction wells and associated piping and electrical connections, the second phase focused on the pretreatment system for the extracted groundwater, and the third phase centered on the installation of the Trench Area extraction wells and associated piping and electrical connections. Construction of OU# I was completed in March· 1996. Figure 4 shows the location of the OU #I RA components. Originally, the four PPES extraction wells were pumping at a combined average of 86 . gallons per minute (gpm). In the second quarter of 1998, the average combined flow was reduced to 31 gpm. _The average combined pumping rate of the six Trench Area extraction wells is approximately 12 gpm. In January/February 2000, the PPES was shutdown to allow NSCC to conduct a hydrogeologic evaluation of this area. Currently, the PPES remains offline as the hydrogeologic evaluation continues. This evaluation is scheduled to be completed by April 2003. OU #2 was a no action ROD. The Agency sent NSCC a special notice letter in March 1991 to initiate negotiations on a CD. This CD governed the implementation of the OU #2 RA. The CD was signed in August 1991 and was entered by the Federal Court on July 20, 1992. OU #2 ROD required the monitoring of the Trench Area, placement of a deed restriction, and initiation of OU #3. OU #3 and OU #4 RA are being conducted under the same UAO, dated September 29, 1995. The OU #3 RA commenced on June 15, 1999 and was conducted in numerous phases. The first phase involved converting two existing deep bedrock monitoring wells (NS-49 and NS- 51) into extraction wells and installing the necessary piping and electrical connections. The • • Five-Year Review Report National S & Chemical Company Superfund Site September 2002 19 second phase involved the construction of a groundwater interception trench on the top of bedrock and the installation of the necessary piping and electrical connections. This trench is referred to as the "Collection Trench". The next phase, although not required by the ROD, involved the construction of a berm around Area 2 and re-grading some areas in order that all surface water runoff following a storm event can be collected. The collected runoff is now being piped to the facility's wastewater pretreatment system instead of being discharged into the Northeast Tributary. All of these discharge lines were strung above ground. NSCC then capped and grouted the terracotta discharge line running from Area 2 to wastewater pretreatment system. The last phase involved modifying the groundwater pretreatment system. Construction of OU #3 RA was completed on February 18, 2000. On average, the combined flow from the two bedrock extraction wells is 20 gpm and the extraction rate for the Collection Trench is 6 gpm. Figure 5 shows the location of the OU #3 components. OU #4 ROD includes a contingency. The preferred alternative involves conducting a "Biodegradative Study" to (I) substantiate that natural degradation of contaminants of concern in the soil is occurring in the OU #4 area, (2) identify where in the subsurface soils degradation is occurring, (3) determine the rate of degradation, and (4) develop and implement a long-term monitoring plan to monitor the biodegradative process until the performance standards have been achieved. In the event that the "Biodegradative Study" cannot substantiate the occurrence of significant natural degradation of 1,2-DCA and other contaminants of concern, or the study shows that degradation products increase the Site risk, the contingent remedy shall be implemented. The contingency remedy involves the construction and operation of a soil-vapor extraction system installed in the unsaturated zone. The extracted contaminated air from Area 2 will initially be treated using fume incineration to destroy the volatile organics prior to the air stream being released into the atmosphere. After concentrations of contaminants in the extracted air decreases, this contaminated vapor can be treated via vapor-phase activated carbon adsorption filters. The extracted contaminated air from the lagoon area will be treated using vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air stream being released into the atmosphere. The contaminants captured by the vapor-phase carbon filters will be destroyed through the thermal regeneration of the used activated carbon at an off-site, commercial regeneration facility. Also included in OU #4 ROD is the implementation of two · institutional controls: the placement of deed restrictions on this portion of the NSCC facility and maintenance of both the existing fence around the plant operations area and the paved areas around Area 2. Phase I of the OU #4 Natural Degradation Treatability Study was initiated in December 1996 and was completed in March 1998. The objectives of Phase I were to: • determine if natural degradation of Site contaminants was occurring in the saprolite; • determine if natural degradation can be enhanced through the addition of nutrients to the soils, and; • determine where in the subsurface degradation is occurring. • 20 a. Five-Year Review Report National St~ Chemical Company Superfund Sile September 2002 The following were conclusions highlighted in the Phase I Natural Degradation Treatability Study for OU #4 Report, dated March 26, 1998: • Results of the laboratory biotreatability study indicated: • relatively high numbers of viable indigenous microorganisms exist in Site soil samples where there are sufficient nutrients (nitrogen and phosphorous); • these indigenous soil microorganisms are able to degrade 1,2-DCA under both aerobic and anaerobic conditions with the addition of nitrate to the soil; and • little or no loss of 1,2-DCA occurred under either aerobic and anaerobic conditions in the absence of microorganisms. • Results of the field biotreatability study provided three observations and three lines of evidence of natural degradation of 1,2-DCA in unsaturated soils: • Observations: • Concentrations 1,2-DCA in soil varied over a large range both spatially and with depth; • Moisture content in the soil samples ranged from 20 to 30 percent; • pH of soil samples generally ranged between 5.79 to 8.73 and is suitable for microbial activity. • Evidence: • Mass reduction of 1,2-DCA occurred in the soils during this time-frame; • Presence of 1,2-DCA biodegradation daughter products; and • Favorable geochemical environmental conditions. Phase II was started in November 200 I and is anticipated to be completed in February 2007. This work is being conducted in accordance to the January 2000 Phase II Natural ' Degradation Treatability Study Work Plan. The primary objective of Phase [I is substantiate biodegradation, collect sufficient data to establish a defensible degradation rate, and"develop a long-term monitoring program. Figure 6 shows the distribution of the sampling points of the natural degradation treatability study. In response to the institutional control (i.e., deed restrictions) requirements included in both the OU #2 and OU #4 RODs, a plot map was prepared and the restrictions were filed with the Rowan County Register of Deeds Office on June· 12, 1997. The description can be found in Book 9989, page 179. • • Five-Year Review Report National St Chemical Company Supcrfund Site September 2002 21 4.3 SYSTEM OPERA TIONS/OPERATION AND MAINTENANCE NSCC and its consultant is conducting long-term monitoring and operation and maintenance (O&M) activities according to the current O&M manual, the "Combined OU #I & #3 Pretreatment System Operation & Maintenance Manual", dated April 2000. The primary activities associated with O&M include the following: • Inspection of the condition of groundwater monitoring wells; • Periodic environmental monitoring which includes the following activities: collecting samples from selected monitoring wells, extraction wells, the Collection Trench, the pretreatment system influent, the pretreatment system effluent, surface water/sediment from the Unnamed and Nou_heast Tributaries, soils, and measuring and recording groundwater levels and flow rates. The focus of the RAs implemented at the NSCC Superfund Site is to remediate groundwater and use a combination of natural flushing to wash the contaminants out of the soils and monitored natural attenuation to address the contamination ih the soils. Those contaminants that migrate from the soil into the groundwater will be removed from the environment through the groundwater extractions systems. The yearly O&M cost for all four OUs is approximately $320,000. Currently, NSCC is re-evaluating the hydraulic control of the OU #I plume periphery extraction system. This was in response to detecting contaminants in a monitoring well, NS:31, on the opposite of the Unnamed Tributary. According to the conceptual groundwater model for the Site, this stream should be acting as a hydraulic barrier. This evaluation should be completed by April 2003. . 5.0 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW This is the first Five-Year Review Report for the entire Site. A Five-Year Report for OU #I, prepared by the Agency, was completed on June 18, 1996. A Five-Year Review Report for OU #2, prepared by NSCC, was completed in August 1998. The 1996 Five-Year Review Report for OU #I concluded that insufficient data had been collected with regard to the OU #1 RA to make a determination on the protectiveness of the remedy due to the recent completion of the construction activities. However, the report assumed that the installed remediation systems would be protective of human health and the environment. This report recommended that the Site not be deleted from the NPL. The 1998 Five-Year Review Report for OU #2 made the following recommendations: reduce groundwater monitoring from quarterly to an annual basis, eliminate selected monitoring parameters for designated wells, and change the analytical method for VOCs. The Agency concurred with these recommendations. This report concluded that the OU #2 RA was protective of human health and the environment. LEGEND • MONITORING v.£LL LOCATION ♦ · EXlRACllON WELL LOCATION • A SURF ACE WATER/SEDIMENT SAMPLE LOCATION / I "l". • P-2 • -SCALE IN FEIT r -I I I \ \ I I I \ \ 22 COMPONENTS OF OPERABLE UNIT #I • Five-Year Review Report tional Starch & Chemical Company Superfund Site September 2002 ,.-- J I ( I \ I '-- FIGURE4 I en NS-2 l' I r-- 1 I • 23 COMPONENTS OF OPERABLE UNIT #3 • Five-Yt:ar Review Report atiooal Starch & Chemical Compdny Superfund Site September 2002 LEGEND • MONITORING WELL LOCATION ♦ EXTRACTION WELL LOCATION .6 SURFACE WATER/SEDIMENT SAMPL£ LOCATION zqo' ....---j 0 -=I -I SCALE IN FEET .... I FIGURES \ I I I I I I I ) ) J / / I I I I / / / / / / J I I I I • 24 / , I \ I j) I ,,, I / I / I I I I ~ • Fi\e-Ycar Review Repon National Starch & Chi:mical Company Superfund Site September 2002 LEGEND .l RI SOIL BORING LOCATION (APP~OXIMATE) • MONITORING WELL LOCATION 4 EXTRACTION WELL LOCATION • SURFACE WATER/SEDIMENT SAMPLE LOCATION • SOIL BORING (LOCATION TO BE SAMPLED IN 2002) • SOlL BORING EUM!NATED FROM MONITORING PROGRAM · ---·--ABANDONED TERRA-COTTA PROCESS SEWER LINES (UNDERGROUND) ----ABANDONED TERRA-COTTA STORM SEWER LINE RANDOMLY SELECTED GRID BLOCKS TO BE SAMPLED IN 2002 NATURAL DEGRADATION TREAT ABILITY STUDY PHASE 2 SAMPLING LOCATIONS FIGURE 6 • 6.0 FIVE-YEAR REVIEW PROCESS 6.1 ADMINISTRATIVE COMPONENTS A Five-Year Review Report National St,~ Chemical Company Superfund Site September 2002 NSCC was notified of the initiation of the five-year review on May 17, 2001. The basis of this Five-Year Report was provided by NSCC in a document.entitled, "Draft Final Five Year Review", dated August 2001 and the revised version dated March 2002. NCDENR assisted in the review of both of these NSCC documents as well as this document. Since NSCC's revised report did not fulfill the requirements of EPA OSWER's Directive 9355.7-03B-P entitled, Comprehensive Five-Year Review Guidance, June 200 I, the Agency elected to finalize this Five- Year Review Report. 6.2 COMMUNITY INVOLVEMENT/COMMUNITY INTERVIEWS During the week of December 17, 2001, EPA contacted a number of citizens who live around the Site. Copies of the review questionnaires (with the names of the interviewees redacted) are induded in Appendix A. All of the residents contacted have lived near the Site for at least 12 years. In general, none of the individuals contacted identified any problems/concerns with regard to the Superfund cleanup. A few of the residents voiced that they attributed an occasional odor from the NSCC facility. NSCC holds Community Advisory Panel group meetings on a bimonthly basis. Attendees at these meetings have included NSCC personnel, City of Salisbury Firemen, City of Salisbury Utilities, Rowan County Emergency Response members, residents of adjoining or nearby neighborhoods, Rescue Squad members, and others. Plant activities, including those undertaken to advance the remedial activities at the Site, are discussed during these meetings and questions or concerns that attendees raise at the meetings are addressed by the Community Advisory Panel coordinator at the facility. 6.3 DOCUMENT REVIEW This Five-Year Review involved a review of relevant documents including RDs, O&M Monthly Reports, monitoring data, etc. A list of documents reviewed in preparing this Five-Year Review Report can be found in Appendix B. 6.4 ARAR REVIEW One purpose of the Five-Year Review is to review federal and state regulations promulgated or modified since the issuance of a ROD to determine if any of these changes alter the established ARARs. As part of this review, the existing federal and state ARARs identified in the four RODs were compared to more recently promulgated ARARs. The following federal regulations were reviewed to determine the OU# 1 ARARs: • Clean Air Act (CAA); • Clean Water Act (CW A); • • . .Five-Year Review Report National St Chemical Company Superfund Site September 2002 26 • Endangered Species Act (ESA); and • Safe Drinking Water Act (SOWA). As documented in the OU #I ROD, no State groundwater standards were incorporated into the OU #I ROD. The OU #2 ROD was a no action ROD and therefore did not incorporate any performance standards. The OU #3 ROD considered the following federal and state regulations to be ARARs: • Federal Regulations: • Clean Air Act (CAA); • Clean Water Act (CW A); and • Safe Drinking Water Act (SOW A). • State Regulations: • North Carolina Air Quality Permit Procedures (NCAC TI 5A:2Q, August I, 1995); • North Carolina Air Pollution Control Requirements (NCAC Tl5A:2D, April I, 1995); • North Carolina Groundwater Classifications and Standards (NCAC Tl5A:2L, November 23, I 993); and • Classifications and Water Quality Standards Applicable to Surface Waters and Wetlands of North Carolina (NCAC Tl5A:2B, March 3, 1993), respectively. For OU #4 (as well as for OU #2), there were no federal or state ARARs that govern the remediation of the impacted soils present at the Site. The OU #4 soil performance standard for 1,2-DCA was based on protecting groundwater from 1,2-DCA leaching from the soils into the groundwater. Based on the computer modeling efforts conducted during OU #4, the concentration of 1,2-DCA that could be left in the soil without adversely impacting the underlying aquifer above the groundwater performance standard for 1,2-DCA was calculated to be 169 µg/kg. However, when ARARs are re-evaluated prior to this Site being c,onsidered for dclisting from the NPL, the requirements specified in the Inactive Hazardous Sites Response Act of 1987 (North Carolina General Statute 130A-3 IO et. seq.), the associated Guidelines for Assessment and Cleanup (North Carolina Department of Environment and Natural Resources (NCDENR, Inactive Hazardous Sites Program, 2001) and the soil/sediment remediation requirements detailed in Section 4 ·of the Guide will need to be included in this evaluation. The OU #I ROD identified 25 chemicals of concern (COC). The OU #I ARARs were based upon SOW A Maximum Contaminant Levels (MCLs), laboratory detection limits, Reference Doses (R,Ds), and Acceptable Chronic Intake (ACI) concentrations. If a MCL was not available, the R,D or AC! concentration was specified as the performance standard. The OU #3 ROD identified 1_8 COC. When comparing between the MCL or the State groundwater standard, the most stringent standard was incorporated in the OU #3 ROD for each COC. All of the identified COC for each OU are.listed in Table 3. Included in Table 3 for each COC is the performance standard (clean-up goal) and the basis for the performance standard. · • Five-Year Review Report National St· Chemical Company Superfund Site · September 2002 27 Newly promulgated or modified federal and state requirements evaluated included: • SDWA Maximum Contaminant Level (40 CFR 141); • North Carolina Air Quality Permit Procedures (NCAC Tl5A:2Q, August I, 1995); • North Carolina Air Pollution Control Requirements (NCAC Tl5A:2D, April I, 1995); • North Carolina Groundwater Classifications and Standards (NCAC TI 5A:2L, November 23, 1993); and • Classifications and Water Quality Standards Applicable to Surface Waters and Wetlands of North Carolina (NCAC Tl5A:2B, March 3, 1993), respectively. The newly promulgated or modified performance standards are listed in the second to last column in Table 3. The last column in Table 3 identifies the basis for each performance standard. As can be seen, a number of thenewly prom\![gated ARA Rs are more stringent than the current ARARs. However, since CERCLA related work at this Site is·anticipated to last for a minimum of another 20 years (e.g., the OU #4 ROD estimated that it would take 130 years to achieve the groundwater performance standard for 1,2-DCA), it w·ould be more efficient use of. time and effort to update the ARARs at a later date. This is a feasible approach as the exposure assumptions used in the Baseline Risk .Assessment have not changed nor are they anticipated to change anytime in the near future. 6.5 DATA REVIEW The following section is based on the Agency's interpretation of its review of the historical analyt_ical data for groundwater and surface water/sediment monitoring. The groundwater samples were collected from the extraction wells and a select number of monitoring wells associated with OU #1 and OU #3 as well as groundwater samples collected from the OU #3 Collection Trench. The surface water/sediment samples were collected from both the Unnamed and Northeast Tributaries. Groundwater monitoring has been conducted at the NSCC site since 1976. However, for the purpose of preparing this report only groundwater data collected as part of the RA effort were reviewed. The following wells associated with OU #1 (refer to Figure 4) were monitored on a quarterly basis from 1993 through 1998 and annually since 1999: · • Plume Periphery Extraction Wells: EX-01, EX-02, EX-03, and EX-04; • Plume Periphery Monitoring Wells: NS-29, NS-30, NS-31, and NS-32; • Trench Area Extraction Wells: EX-05, EX-06, EX-07, EX-08, EX-09, and EX-10; and • Tench Area Monitoring Wells: NS,9, NS-10, NS-11, and NS-15. The following wells associated with_ the OU #3 RA (refer to Figure 5) were monitored bi- annually between 1998 and 2000 and have been sampled annually since 2001: • Wells Assumed To Be Inside Zone of Hydraulic Control • Extraction Wells: NS-49 and NS-51 • • · Five-Year Review Report National St< Chemical Company Superfund Site September 2002 28 • Monitoring Wells: NS-13, NS-14, NS-39, NS-40, NS-41, NS-42, NS-45, NS-46, NS-47, NS-48, NS-50, NS-52, NS-53, and NS-54 • Collection Trench (CT-I) • Wells Assumed To Be Outside Zone of Hy~raulic Control • Monitoring Wells: NS-24, NS-35, NS-36, NS-37, NS-38, NS-43, and NS-44. Tables 4 through 7 and Tables 8 through 11 present a compilation of historical analytical · groundwater data for monitoring wells associated with the OU #1 PPES and Trench Area system, respectively. Tables 12 and 13 provide historical analytical groundwater data for a number of wells and the Collection Trenc'1 which are associated with OU #3. As can be seen from the data in these tables, there is no clear, persistent downward trend in concentrations of organic contaminants in the groundwater in either OU. Contaminant levels in extraction wells EX-02 and EX-03 have shown some decrease in contaminant levels since the pumps in these wells have been turned off. However, this observation makes sense since these wells are no longer pulling contaminated groundwater towards themselves. Figures 7 and 8 _show the groundwater elevation contours in the transition zone and bedrock zones for the OU #I area, respectively. These figures were for data collected in the fourth quarter of 1999 since the PPES wells were shut down in the first quarter of 2000. As can be seen, insufficient information is provided to confirm that the extraction systems are capturing the plume. Figures 9 and 10 show the groundwater elevation contours in the saprolite/transition zone and bedrock zones for the OU #3 area, respectively. These figures were for data collected in the third quarter of 2000. As with the previous figures, insufficient information is provided to confirm that the extraction system is capturing the entire plume, both laterally and vertically. Tables 14 and 15 present a compilation of historical analytical data for surface water/sediment samples in the Unnamed Tributary and the Northeast Tributary, respectively. Figures 11, 12, and 13·show the locations of all the surface water/sediment sampling locations on the Unnamed tributary. Figures 11, 12, 14, and 15 show the locations of all the surface water/sediment sampling locations on the Northeast Tributary. An ecological risk assessment of the Northeast Tributary was performed as pa_rt of the OU #3 baseline risk assessment. The potential impact to aquatic and benthic (bottom-dwelling) organisms in the Northeast Tributary was evaluated. 1,2-DCA is the primary ecological contaminant of concern in this tributary. To determine if there were any effects of 1,2-DCA on the benthic communities inhabiting the Northeast Tributary, a Rapid Bioassessment Protocol was conducted. The results indicated that segments of the tributary with historically elevated 1,2- DCA levels (portions of the stream adjacent to the plant operations area) were devoid of sensitive macro benthic species and exhibited generally lower taxa richness and abundance than the reference station (Le., upgradient of where 1,2-DCA enters into the stream). However, the benthic organisms in the referenced station were not dominated by species known to be tolerant of chemical stress. The ecological risk assessment concluded that due to the naturally-limiting factors associated with a headwater stream of this type, the ecological impacts resulting from the presence of 1,2-DCA in the Northeast Tributary could not be determined. • • Five-Year Review Report National St Chemical Company Supcrfund Site September 2002 29 Following the Rapid Bioassessment , chronic toxicity tests were performed on surface water and sediment samples to further examine the ecological impairments noted during the field assessment. Surface water tests were conducted using fathead minnows and water fleas, while amphipods and water fleas were used for sediment tests. The measurement endpoints (survival, growth, or reproduction) did not differ significantly between Site samples (containing elevated levels of 1,2-DCA) and reference or laboratory samples (containing little or no 1,2-DCA). These test results initially suggested that ecological impairments observed in the Northeast Tributary resulted from natural stresses rather than the presence of 1,2-DCA or other chemical contaminants. However, chemical analysis of surface water samples collected at the same time and locations as those for the toxicity tests indicated that the level of 1,2-DCA in the sample collected adjacent to the Site (200 µgll, estimated value) had decreased below historic levels for that area (800-3200 µgll) and was below the screening level (2000 µg/1) thought to be potentially toxic to aquatic organisms. Presently, no substantive link has been made between the presence of 1,2-DCA in the Northeast Tributary and the limited biodiversity in this stream as the area of the stream impacted by the Site is approximately 1,500 feet from the head-w<!ter of this stream. However, the RI report did conclude that the source of 1,2-DCA in the Northeast Tributary is the_contaminated groundwater in the saprolite zone of the aquifer discharging into this stream. Since very high concentrations of 1,2-DCA (660,000 µgll) have been found in the groundwater, the potential for discharge of groundwater contaminants above levels of ecological concern is possible. Hence it is necessary to institute long-term monitoring of the Northeast Tributary. 6.6 SITE INSPECTION The pre-final/final inspection of OU #3 RA was conducted on March 22, 2000 by EPA and NCDENR. During this visit to the Site the other OUs at the Site were also reviewed. The combined water treatment is successfully treating the extracted groundwater as well as the plant's effluent prior to being discharged to the City of Salisbury POTW. 7.0 TECHNICAL ASSESSMENT One of the primary purposes of the Five-Year Review is to determine the effectiveness and protectiveness of the remedies. Per the Agency's Five-Year Review Guidance (June 2001), the review needs to address the following three questions: (A) ls(Are) the Remedy(ies) Functioning as Intended by the Decision Documents? (B) Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and RAOs Used at the Time of Remedy Selection Still Valid? (C) Has Any Other Information Come to Light That Could Call Into Question the Protectiveness of the Remedy( ies)? • • Five-Y car Review Report National St;. Chemical Company Superfund Site . September 2002 30 For the NSCC Site, the assessment of the remedies and answers to these questions is accomplished by comparing Site data and operations to the original RAOs. As noted in Section 4.1, the groundwater RAOs can be generalized as: • To prevent further migration of the plumes (i.e., capture the plume through the extraction of groundwater), • To treat the extracted groundwater, and • To restore contaminated groundwater to levels protective of human health and the environment. This evaluationwill assess tb_e following: • the trends for the in situ groundwater monitoring well data (untreated) by comparing sampling data to th_e cleanup levels in the RODs • the effectiveness of the remedies in capturing the plume and restoring groundwater • the protectiveness of the current performance standards for groundwater and potential updates to ARARs and criteria since the issuance of the RODs. 7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? Based on Site visits and the review of documents, all remedies have been constructed in ' accordance to the appropriate ROD-and RD. With the exception of the PPES, the Trench Area extraction system (OU #1), the two bedrock extraction wells (OU #3), and the Collection Trench (OU #3) are operating. Phase I of the Natural Degradation Treatability Study is complete and Phase II is underway (OU #4). However, insufficient data is available to verify that the groundwater extraction systems for both OU# 1 and OU #3 have or will create a sufficient hydraulic capture zone to encompass the plumes emanating from the sources. The monitoring well networks for both OU #1 and OU #3 are currently insufficient to make an accurate determination as to whether the extraction systems are effectively capturing or containing Site groundwater. No information is available to determine if the plume size is stable, is being reduced as a result of pumping and treating the groundwater, or is growing. Based on an analysis of the drawdown (groundwater contour Figures 7-10), it appears that there is some capture of the plume but not complete capture. This determination is critical to determine whether the remedies are functioning as intended by the RODs. Another RAO and measure of success is whether concentrations of Site contaminants in groundwater are decreasing to levels that are protective of human health and the environment, (i.e., are meeting the groundwater performance levels specified in the RODs). In general, 31 Fi\'c-Year Review Report N:llional Starch & Chemical Company Superfund Site September 2002 TABLE 3 --PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS CONTAMINANTS Acetone Benzene Chloroform 1,2-Dichloroethane 1, 1-Dichloroethene cis/trans-l ,2-Dichloroethene cis-1.2-Dichloroethenc trans-1.2-Dichloroethene 1,2-Dichloropropane Eth •I benzene Meth •Jene Chloride Tetrachloroethene Toluene I, 1,2-Trichloroethane Trichloroethene Vinyl Chloride Xylene PERFORMANCE STANDARD (BASED ON OU#l ROD) 3,500 5 b 5 5 6 3,500 5 2 7,350 BASIS OF STANDARD CRQL MCL MCL MCL CRQL PERFORMANCE STANDARD (BASED ON OU#3 ROD) 7 5 2.8 BASIS OF STANDARD CRQUS1ate (b) CRQUS1ate (b) MCUState State (b) CRQUState PERFORMANCE STANDARD (BASED ON OU#4 ROD) BASIS OF STANDARD CURRENT ARAR 700 0.19 0.38 70 70 0.56 29 5 0.7 1,000 5 2.8 0.015 530 BASIS OF STANDARD NCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L MCUNCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L NCAC 15-2L MCUNCAC 15-2L MCL NCAC 15-2L NCAC 15-2L NCAC 15-2L 32 Five•Year Review Report National Starch & Chemical Company Superfund Site September 2002 TABLE 3 --PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS CONTAMINANTS Bis(2-Chloroethyl)ether Bis(2-ethylhexyl)phthalate 4-Nitro henol ·. .. ('. G.ROUNDW~T,Eif0,i Antimony Arsenic Barium Cadmium Chromium Man°anese Nickel Selenium Thallium Zinc PERFORMANCE STANDARD (BASED ON OU#l ROD) 10 l.000 10 50 7,700 350 7,350 BASIS OF STANDARD PERFORMANCE STANDARD (BASED ON OU#3 ROD) 2 2,100 BASIS OF STANDARD MCL State PERFORMANCE STANDARD (BASED ON OU#4 ROD) BASIS OF STANDARD CURRENT ARAR 0.3 l 3 5 6 10 2.000 5 50 50 lOO 50 2 2,100 BASIS OF STANDARD NCAC l5-2L NCAC 15-2L CRQL l\'ICL MCL NCAC l5-2L MCUNCAC 15-2L NCAC 15-2L NCAC l5-2L NCAC l5-2L MCUNCAC 15- MCL NCAC l5-2L Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 33 TABLE 3 --PERFORMANCE STANDARDS ACCORDING TO THE OU #1, OU #3, AND OU #4 RECORD OF DECISIONS CONTAMINANTS 1,2-Dichloroelhane PERFORMANCE STANDARD (BASED ON OU#! ROD) BASIS OF STANDARD PERFORMANCE STANDARD (BASED ON OU#3 ROD) 2,000 BASIS OF STANDARD EPA, Region IV Chronic Screening Value ~ ----~ ' -. . . . . -' . -. ' PERFORMANCE STANDARD (BASED ON OU#4ROD) BASIS OF STANDARD Anlicipated concentra(ion thal will protect underlying aquifer CURRENT ARAR I ,2-Dichloroethane ' -. . .. : ,_ ----: _-~ -. ' I 69 µgJkg from being adversely impacted 350 µg/kg • -: -• --• i" ·"'" • • , , above the groundwater remediation goal All concentrations are in micrograms per liter (µg/1) oi-parts per billion (ppb) MCL Maximum Concentration Limit as Specified in the Safe Drinking Water Act \'/Ji --The risk levels are based on a 2 liter daily consumption rate by a 70 kilogram individual. CRQUState --Where the Maximum Allowable Concentration Of A Substance Is Less Than The Limit Of Detectability (NCAC 15-2L.0202(b)(I)) and where CRQL is the Contract Required Quantitation Limit CRQL --Contract Required Quantitation Limit State --State Groundwater Quality Standards (NCAC 15-2L.0202) Inactive Hazardous Sites Response Act of 1987 -(North Carolina General Statute 130A-310 et. seq.) BASIS OF STANDARD Inactive _Hazardous Sites Response Act of 1987 34 Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 TABLE 4 --IDSTORICAL AN AL YTICAL GROUNDWATER DAT A FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ROD PERFORMANCE STANDARD FOR 1,2-DICHLOROETHANE IS 5 micrograms/liter (µg/1) SAMPLING SAMPLING LoCATICN TIME EX-01 EX-02 EX-03 EX-04 NS-29 NS-30 NS-31 NS-32 1Q93 20 NS 23 41 no 79J 100 SU 2Q93 SU 460 DJ 65 3 1 22 8 71 5 3Q93 !OU 510 DJ 60 51 31 56 49 1 4Q93 !OU 3300 U 55J IOU 31 IOU 20 10 1Q94 !OU 2500 U 250 U !OU IOU IOU 9J 10 U 2Q94 SU 1700 U 120 U SU 17 41 5 SU 3Q94 SU 1200U 50 U 5 3 1 SU 41 SU 4Q94 SU 550J 93 U 3 1 43 SU 41 SU IQ95 SU 1000 U 33 U 7 8 SU 250 U SU 2Q95 SU 750 59 5 37 SU 41 SU 3Q95 31 570 101 17 U 690 SU 120 SU 4Q95 5 2500 U 61 62 U 3100 U SU 500 U SU IQ96 SU 1200 150 J 41 860 SU 250 U SU 2Q96 41 590 42 25 U 300 SU 100 U SU -3Q96 !OU 610J 250 U 10 U 500 U 10 U IOOOU 10 U 4Q96 51 140 J 60J 31 1200 IOU 170 J IOU 1Q97 7J 520 220J 51 760 3 l 150 J IOU 2Q97 3.51 290 240J 6J 680 10 U IOOOU 10 U 3Q97 10 U 690 200J 51 1900 10 U lOOOU 10 4Q97 IOU 920 230J IOU -1700 10 U IOOOU I IQ98 IOU 230 200 !OU 2300 IOU 260 10 2Q98 !OU 410 190 IOU 4200 51 2500 U IOU 3Q98 !OU 600 200 U 5 J 2400 J 42 J IOOOU 10 U 4Q98 10 U 1000 200 U IOU 3600 58 100 U 10 U 4Q99 IU 880 9.1 lU 3500 84 62 1 U 4QOO lU 100 U 50 U I U 1000 U sou llOE lU 1Q02 lU lU 0.961 0.7 l 100 U 2.8 100 I U NOTES:. All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit 35 Five-Year Review Report National Starch & Chemical Company Superfund Site Sep1embcr 2002 TABLE 5 --HIS)'ORICAL ANALYTICAL GROUNDWATER DAT A FOR 1,2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #1 ROD PERFORMANCE STANDARD FOR 1,2-DICHLOROPROPANE lS 6 micrograms/liter (µg/1) SAMPLING SAMPLING LoCATION TIME EX-01 EX-02 EX-03 EX-04 NS-29 NS-30 NS-31 NS-32 1Q93 35 NS 120 SU 350 D 190 170 SU 2Q93 41 820DJ 180 SU 46.5 23 200 3Q93 IOU 1000 DJ 150 10 U SJ 97 83 4Q93 IOU 3300U 170 U 10 U !OU IOU 31 IOU IQ94 IOU 2500 U 250 U IOU !OU !OU 10 U 10 U 2Q94 6U 1600J 70J 6U 6U 6U 31 6U 3Q94 6U. 1200J 44J 6U 6U 6U 6U 6U 4Q94 6U 1200 53J 6U 6U 6U 6U 6U IQ9S 6U 670J 40U 6U 6U 6U 300 U 6U 2Q9S 6U 1300 160 6U 12 J 6U 50 6U 3Q9S 6U 890 24 26 1000 6U 260 6U 4Q95 · 6U 3000 U 130 75 U 2200J 6U 340J 6U IQ96 SU 830 140 J SU 1600 SU 250 U SU 2Q96 SU 650 33 25 U 710 SU 94J SU 3Q96 IOU 640J 87 J 21 1900 !OU 1000 U IOU 4Q96 I J lOOJ 71 J I J 1800 !OU 160 J IOU IQ97 7J 400 150 J 7J 1200 !OU 1000 U IOU 2Q97 3 J 190 J 240J 17 980 IOU 1000 U 10 U 3Q97 2J 460 230J 7J 2500 !OU 1000 U 1 4Q97 10 U 730 310 21 2700 10 U 1000 U I IQ98 10 U 130 200 31 2700 10 U 170J 10 U 2Q98 !OU 170 J 235 10 U 3700 SJ 2500 U IOU 3Q98 10 U 360 100 J !OU 2100 68 IOOOU IOU 4Q98 IOU 490 200 U !OU 2700 54 100 U !OU · 4Q99 IU 810 30 !U 3100 20 160 JU 4QOO IU 100 U 50 U JU 1000 U I 50 U 180 E !U 1Q02 IU lU 1 U I U lOOU IU 200 IU NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard I NS -Not Sampled· U -Not detected at indicated concentration . D c Concentration from a secondary dilution range .. E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit 36 Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 TABLE 6 --HISTORICAL ANALYTICAL GROUNDWATER DATA FOR METHYLENE CHLORIDE FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ROD PERFORMANCE STANDARD FOR METHYLENE CHLORIDE IS 5 micrograms/liter (µg/1) SAMPLING SAMPLING LOCATION TIME EX-01 EX-02 EX-03 EX-04 NS-29 NS-30 NS-31 NS-32 IQ93 2 BJ NS 2 BJ 5U 3 BJ 48 BJ 3 BJ 2 BJ 2Q93 I J 41 21 21 21 5U 5U I 3Q93 2 BJ IOU IOU 5 BJ 2 BJ 2 BJ 2 BJ 4Q93 NR NR NR NR NR NR NR IQ94 NR NR NR, NR NR NR NR NR 2Q94 5U 1700 U 120 U 5U 5U 5U 5U 5U 3Q94 9B 2900 B 110B 7B SB SB 9B 9B 4Q94 5U 1200B 150 B 6B 7B I 5U 6B 9B IQ95 5U 1300B 37 B 3 BJ 3 BJ 5U 200 BJ 4 BJ 2Q95 3U -44 B 41 BJ 7B 13B JOB 16 B II B 3Q95 5U 250 U 17U 17 U 250 U 5U 32 U 5U 4Q95 5U 2500 U 72B 62 U 3100 U 5U 480 BJ SU IQ96 2 BJ 150 BJ 160 BJ 2 BJ 150 BJ 2 BJ 71 BJ 2 BJ 2Q96 I BJ 13J 25 U 5 BJ 50U I 5U 21 J 5U 3Q96 IOU 620J 140 J 41 2200 10 U 310J 10 U , 4Q96 0,6 J 74J 16 J I J 37 J 0,6 J 110 J 0,71 !Q97 IOU 250 U 250 U IOU 500U ·IOU 1600 B 31 2Q97 · IOU 250 U 250 U 10 U 500 U JO u !OOOU 10 U 3Q97 10 U 250 U 250 U 10 U 500 U IOU !OOOU IO 4Q97 IOU 40J 401 10 U 89J 10 U 160 J I IQ98 IOU 50 U IOOU IOU 500U IOU 250 U 10 U 2Q98 IOU 250 U IOOU 10 U 500 U 10 U 2500 U 10 U 3Q98 IOU 100 U llOJ IOU l lOO J 12 J 1000 U 10 U 4Q98 IOU 9J 200 U IOU 250 U IOU IOOU IOU 4Q99 IU 7.5 L IU IU 14 L IU IU I U 4QOO I U 300BD 160 BD IU 2000BD 38JBD JU I U IQ02 2U 2U 2U 2U 200U 2U JOO U 2U NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled NR -Not Reported U -Not detected at indicated concentration L -Common laboratory contaminant D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit B -Compound detected in associated method blank Five-Year Review Report Na1ional SLarch & Chemical Company Superfund Site September 2002 37 ' TABLE 7 --HISTORICAL ANALYTICAL GROUNDWATER DATA FOR BIS(2-CHLOROETHYL)ETHER FOR WELLS ASSOCIATED WITH THE PLUME PERIPHERY SYSTEM OF OU #I ROD PERFORMANCE STANDARD FOR B1s(2-CHLOROETHYL)ETHER IS 5 micrograms/liter (µg/1) SAMPLING LOCATION I SAMPLING TIME EX-01 EX-02 EX-03 EX-04 NS-29 NS-30 NS-31 NS-32 1Q93 38 NS 82 12 190 44 71 IOU 2Q93 4 J 380 D 100 51 52 32 95 I ' 3Q93 II U 540 D 10 U 11 25 IOU 38 I 4Q93 II U 440 74 53 U 18 lOJ 25 II U 1Q94 IOU 510 150 D 22 J 8 41 24 11 U 2Q94 11 U 770 120 17 J 12 29 20 IOU 3Q94 6U 680 56 13J 12 17 21 SU 4Q94 SU 570 110 21 J 17 21 -14 SU IQ95 SU 540 130 14 J 13 17.5 11 SU 2Q95 3 J 650 180 D 55 32 16 78 5U 3Q95 14 570 120 64 450 12 130 6U -4Q95 11 570 140 41 1100 10 320 370 IQ96 9J 400 130 10 590 D SJ 72 10 U 2Q96 7J 500 E 93 71 250 7J 160 IOU 3Q96 IOU 430 170 48 1400 D 7J 380 10 U 4Q96 17 320D 130 49 740 4J 200 D IOU 1Q97 31 490D 180 68D 810 . lOJ 540 D 10 U 2Q97 21 250D 180 74D 410 7J 390 D IOU 3Q97 24 310D 210D 68 D 1400 D SJ 21 U 65 4Q97 17 43 2600 47 D 1400 D 10 U 19 56 · IQ98 46 180D 350 D 94D 2400 D 9J 1500 D IOU 2Q98 14 140 D 195 D 28 3100 D 21 2700 D IOU 3Q98 23 310 D 230D 26.5 100 U 23 2400 D IOU ' 4Q98 34 850 D IOU 58 D 3600 D 37 2200 D 10 U 4Q99 20 1300 310 51 3800 57 160 IOU 4QOO 2U 1700 E 1100D 1 7100 D 1000D 2U 52 U IQ02 IOU 730 600 2.6 J 9900 150 81 IOU NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 38 TABLE 8 --HISTORICAL ANALYTICAL GROUNDWATER DATE FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #I ROD PERFORMANCE STANDARD FOR 1,2-DICHLOROETHANE IS 5 micrograms/liter (µg/1) SAMPLING . SAMPLING LOCATION TIME EX-05 EX-06 EX-07 EX-08 EX-09 EX-10 NS-09 NS-10 NS-I I NS-15 IQ93 NS NS NS NS NS NS NS NS NS NS 2Q93 NS NS NS NS NS NS 10000 D 16000 D 5U 3Q93 NS NS NS NS NS NS 14000 D 8000 D 100 44 4Q93 NS NS NS NS NS NS 4700 2800 25 U 5 IQ94 NS NS NS NS NS N'' ., 170 8800 500 U 480 2Q94 NS NS NS NS NS N'' ., 3100 U 9700 8 400 3Q94 NS NS NS NS NS NS 8300 U 7100 5U 380 4Q94 NS NS NS NS NS NS 10000 U 420 5U 380 E IQ95 NS NS NS NS NS NS 30 9100 5U 370 2Q95 NS NS NS NS NS NS 500 U 9800 5U 330D 3Q95 NS NS NS NS NS NS 11 7600 6 250 D 4Q95 NS NS NS NS NS NS 1700 8100 5 260 IQ96 NS NS NS NS NS NS 9J 6100 9 250 2Q96 350000 D 920 83000 D 330000 D 71000 D 28000 l> 840 4100 E 5U 210 E 3Q96 5000U IOU 3300 U 5000 U 3300 U 1700 lJ 210~D 2200 D 11 67 4Q96 430000 D 240D 50000 D 350000 D 190000 D 35000 7100 D 4500 D 34· 150 IQ97 510000 D 53 34000 D 390000 D 180000 D 31000 10000D 2000D 400 D , 190 2Q97 470000 D 530D 35000 D 290000 D 130000 D 30000 4400 D 870 3 J 120 3Q97 340000 D 550D 36000 D 310000 D 160000 D 53000 4900 D 1800 170 D 160 4Q97 380000 D 140 27000 D 270000 D 130000 D 59000 5900 D 1600 260D ' IQ98 340000 D 80 19000 220000 D 110000 D 44000·0 10000 D 920 D 24 100 2Q98 340000 D 550 I00U 220000 D 85000 D 29000 D 25000 1900 D 41 130 3Q98 230000 D 120 140000 D 210000 D 79000 D 39000 25000 D 1200D 15 20 4Q98 300000 D 12 130000 D 180000 D 71000 D 36000 D 17000 D 460D 15 98 4Q99 400000 JU 500 lJ 180000 100000 25000 21000 330 I lJ 69 4Q00 530000 D JU 180 D 190000 D 160000 D 40000 D 550D 13 2U 76D IQ02 390000 IU 270 190000 91000 14000 1400 13 I lJ 27 NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit 39 Five-Year Review Report National Starch & Chemical Company Superfund Si(e September 2002 TABLE 9 --HlSTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROPROPANE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #I ROD PERFORMANCE STANDARD FOR 1,2-D!CHLOROPROPANE IS 5 micrograms/liter (µg/1) SAMPLING SAMPLING LOCATION I TIME EX-05 EX-06 EX-07 EX-08 EX-09 EX-10 NS-09 NS-IO NS-I I NS-15 !Q93 NS NS NS NS NS NS NS NS NS NS 2Q93 NS NS NS NS NS NS SU 2J SU 3Q93 NS NS NS NS NS NS I IOU I J IOU 4Q93 NS NS NS NS NS NS 250U 330 U 25 U 67 U !Q94 NS NS NS NS NS NS IOU 500U 500 U 50 U 2Q94 NS NS NS NS NS NS 3800 U 380 U 6U 15 U 3Q94 NS NS NS NS NS NS 10000 U 400U 6U 30 U 4Q94 NS NS NS NS NS NS 12000 U 20U 6U 6U !Q95 NS NS NS NS NS NS 6U 380 U 6U 15 U 2Q95 NS NS NS NS NS :,s 600 U l!OU 6U 6U 3Q95 NS NS NS NS NS :,s 6U 100 U 6U 6U 4Q95 NS NS NS NS NS NS 68 U 400U 6U IOU IQ96 NS NS NS NS NS NS IOU 250 U SU IOU 2Q96 350 25 U 120 U 530 9400 D 82000 D sou 50 U SU SU 3Q96 5000U IOU 3300 U 5000U 12000 81000 D sou IOU IOU IOU 4Q96 250J .IOU 250 U 5000 U 11000 78000 100 U !OOU IOU IOU IQ97 2000U IOU 250 U 5000 U · 12000 68000 IOOU 100 U IOU IOU 2Q97 2000U IOU 250 U 5000 U 9100 56000 100 U 100 U IOU IOU 3Q97 2000U IOU 250U 5000 U 11000 60000 100 U 100 U 10 U I ' 4Q97 2000U IOU 250 U 1000 J 12000 75000 100 U 100 U 10 U I !Q98 5000 U JOU IOOOU 1200J 12000 41000 D IOOU IOU IOU JOU 2Q98 5000 U IOU IOOU 2800 13000 44000 D !OOU 20U JOU IOU 3Q98 5000 U JOU 88J 3100 14000 54000 500 U IOU IOU IOU 4Q98 2500 U IOU 1000 U 3600 15000 42000 D !OOU IOU IOU IOU 4Q99 500U IU 500U 2700 13000 22000 2 JU JU 1.5 4QOO 5000U JU 5U 1500 JD 16000 D 31000 D IOU I 2U IOU IQ02 3000 U IU IOU 2300) 6400 11000 0.53 J IU IU IU NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -e,timated concentration is less than the reporting limit 40 Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 TABLE 10 --HISTORICAL ANALYTICAL GROUNDWATER DATA FOR TOLUENE FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #I L ROD PERFORMANCE STANDARD FOR TOLUENE IS 2,000 micrograms/liter (µg/1) , SAMPLING SAMPLING LOCATION TIME EX-05 EX-06 EX-07 EX-08 EX-09 EX-10 NS-09 NS-10 NS-I I NS-15 IQ93 NS NS NS NS NS NS NS NS NS NS 2Q93 NS NS NS NS NS NS 400D 2) 61 3Q93 NS NS NS NS NS NS ll00D 17 59 4Q93 NS NS NS NS NS l'/S 330 330 U 120 18 J IQ94 NS NS NS NS NS NS 100 500 U 500 U sou 2Q94 NS NS NS NS NS NS 6200U 620 U 7) 13 J 3Q94 NS NS NS NS NS NS 17000 U 670U 13 17J 4Q94 NS NS NS NS NS NS 20000U 33 U 6) 10 IQ95 NS NS NS NS NS NS . 47 620 U 23 10 J 2Q95 NS NS NS NS NS NS 3401 !SOU II 8) 3Q95 NS NS NS NS NS NS 130 170 U 15 5 J 4Q95 NS NS NS NS NS NS 410 670 U 6) 9) IQ96 NS NS NS NS NS NS 180 250 U 6 II 2Q96 16000 D 74 3200 68000 D 38000 D 14000 D 170 sou II 15 3Q96 19000 67 22001 28000 29000 15000 69 41 12 2) 4Q96 20000 65 1700 25000 28000 15000 200 9) 19 61 1Q97 24000 42 1600 30000 28000 16000 I00U 100 U 28 5 J 2Q97 23000 37 1200 24000 20000 12000 80 J 100 U 5) 4) 3Q97 22000 82 I 100 25000 23000 12000 150 100 U 7J 4Q97 21000 43 1100 26000 22000 14000 I IO 100 U 29 1Q98 21000 40 820 J 24000 21000 D 9000 30 J 10 U 91 3 1 2Q98 14000 75 56 1 20000 15000 7600 761 51 61 7J 3Q98 13000 48 6800 22000 D 18000 10000 500U 51 10 10 U 4Q98 14000 31 6600 20000 18000 9000 291 10 28 21 4Q99 24000 D JU 500 U 34000 31000 5000 54 E JU 3.3 2.6 4Q00 51000 D JU 120 D 26000 D 65000 D 9500 D 110 D I 6D 13 D 1Q02 26000 lU 48 17000 30000 2900 150 IU 1.4 0.771 NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected. concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit 41 Five-Year Review Repon National Starch & Chemical Company Superfund Site September 2002 TABLE 11 --HISTORICAL ANALYTICAL GROUNDWATER DATA FOR BIS(2-CHLOROETHYL)ETHER FOR WELLS ASSOCIATED WITH THE TRENCH AREA OF OU #I ROD PERFORMANCE STANDARD FOR BIS(2-CHLOROETHYL)ETHER IS 5 micrograms/liter (µg/1) SAMPLING SAMPLING LOCATION TIME EX-05 EX-06 EX-07 EX-08 EX-09 EX-W NS-09 NS-10 NS-I I NS-15 IQ93 NS NS NS NS NS NS NS NS NS NS 2Q93 NS NS NS NS NS NS IOU 11 U 11 U I 3Q93 NS NS NS NS NS NS 56U IOU 10 U I 4Q93 NS NS NS NS NS NS 530U sou 10 U 42 U !Q94 NS NS NS NS NS NS SJ . 220 U IOU 10 U 2Q94 NS NS NS NS NS NS 20U 1100 U II U 22 U 3Q94 NS NS NS NS NS NS 6U 110 U SU 21 U 4Q94 NS NS NS NS NS NS 11 U 22 U SU 10 U 1Q95 NS NS NS NS NS. NS 53 U 520 U SU 11 U 2Q95 NS NS NS NS NS NS 27U 250 U SU 6U 3Q95 NS NS NS NS NS NS 28 U 310 U 6U SU 4Q95 NS NS NS NS NS NS sou 260 U 5U SU 1Q96 NS NS .NS NS NS NS 10 U 500 U 10 U 10 U 2Q96 2500 U 100 U 200U 320J 10000 35000 sou 200 U sou sou 3Q96 5000 U 41 lOOU 5000 U NR 47000 sou 200U 10 U 20U 4Q96 170 J 16 100 U 2500 U 6600 29000 20U 100 U 10 U 10 U 1Q97 530 U !OU 100 U 210 7200 29000 IOU IOU 10 U 10 U 2Q97 llOU 10 U 100 U 390 3800 D 14000 20U 100 U 10 U IOU 3Q97 500 U IOU llOU 620 7500 30000 20U 10 U 10 U l 4Q97 55J 10 U 18 J 810 7400 D 16000 21 11 U 11 U I IQ98 · 53 U 10 U 14 J ll00 10000 D 68000 11 U IOU 10 U 11 U 2Q98 !IOU 11 U 11 U 1900 7100 D 23000 3 1 IOU 11 U 10 U 3Q98 110 U 10 U 990 D 1400 6200 D 15000 21 IOU 10 U 10 U 4Q98 120 J IOU 100 U 2900 18000 D 14000 21 10 U 21 11 U 4Q99 200U 10 U IOU 200U 500 U ll000 IOU 10 U 10 U 10 U 4QOO 260 U 51 U 51 U 51 U 2600 U 510ED 51 U NA 51 U 52 U IQ02 600U 10 U 10 U 1800 2900 4800 10 U IOU IOU IOU NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit 42 Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 TABLE 12 --IDSTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 ROD PERFORMANCE STANDARD FOR 1,2-DICHLOROETHANE IS 5 microgramsniter (µg/1) SAMPLING SAMPLING LOCATION TIME NS-13 NS-14 NS-24 NS-35 NS-36 NS-37 NS-38 NS-39 NS-40 NS-41 NS-42 NS-41 2Q98 lOOOU IOU NS 2500 U 500U 10 U 10 U 250 U 2000U 5000 U 2500 U 10 U 3Q98 NS NS NS lOOU 10 U NS IOU 10 U sou NS 500 U 10 U 3Q99 76 SU SU 40000 52000 SU SU 270 92000 84 92000 SU lQOO NS NS lU 41000 D 60000 l U lU NS NS NS NS 3QOO 10000 D 51 D. SU 17000 D 63000 D SU SU 19 84000 D 130 32000 D lQOI NS NS 21 5000 D 130000 D lU SU NS NS NS NS l U 1Q02 0.53 J NS lU 6700 39000 l U lU 46 73000 36 110 lU NOTES: All concentrat_ions reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D: Concentration from a secondary dilution ra','ge E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit . TABLE 13 --IDSTORICAL ANALYTICAL GROUNDWATER DATA FOR 1,2-DICHLOROETHANE FOR WELLS ASSOCIATED WITH OU #3 ROD PERFORMANCE STANDARD FOR 1,2-DICHLOROETHANE IS 5 microgramsniter (µg/1) · SAMPLING · SAMPLING LOCATION TIME NS-44 NS-45 NS-46 NS-47 NS-48 NS-49 NS-50 NS-51 / NS-52 NS-53 NS-54 CT-• . ' 2Q98 !OU lOOU IOU 10000 U 250 U 2500 U 2500 U 1000 U 2500 U 2500 U 500 U NS 3Q98 NS 20U NS NS NS NS NS NS NS NS-NS NS 3Q99 SU 3100 18 310000 67 15000 29000 290000 13000 13000 31000 5U lQOO lU NS NS NS NS 34000 NS 410000 NS NS NS 8.1 3QOO SU 190 3000 D 260000 D 18 32000 D 4500 92000 D 2000D 2000D 7200D 2] lQOl lU NS NS NS NS 22000D 160000 D NS NS NS 78000 D 25 IQ02 l U 3.3 12 180000 3.2' 7500 390 38000 82 82 69000 2 NOTES: All concentrations reported in micrograms/liter (µg/1) or parts per billion (ppb) Bold font indicates detected concentration greater than ROD Performance Standard NS -Not Sampled U -Not detected at indicated concentration D -Concentration from a secondary dilution range E -Estimated concentration exceeds the calibration limit J -estimated concentration is less than the reporting limit 43 Five-Year Review Report National S1arch & Chemical Company Superfund Site September 2002 TABLE 14 --HISTORICAL ANALYTICAL SURFACE WATER/SEDIMENT DATA FOR THE UNNAMED TRIBUTARY DATE OF SAMPLING EVENT MARCH 1987 JUNE2000 ~1~tf~t~~f-;:.,Ji~:i~!i·!j)~]~;~:t,~·~?!Y!_~;ii~fli t~7,~i~ SURFACE WATER SEDIMENT SURFACE WATER CONTAMINANTS LOCATION OF SW-3 SW-4 SW-6 SE-3 SE-4 SE-6 UT-2 UT-4 UT-5 SAMPLE ,TT.'' ·~,:;-¼;,,,_ :~.""?,}\~>. 'f;•·: ;i, }.',':: .~.-;:-; Acetone ~.)~;,,;Jt~~::i~~;,f'-. ~l:~ ~:& ND ND ND ND :: --<l:..'i..'-• _7_,,, c~,• .,, ~ ._, ,-_ _,,,.; 42 50 10 u 10 U 10 U B is(2-eth yl hex yl)phthalate :"1' -. , , _,.,, ._, "~~~·r · •f:1 ::i~?-\~'~cr~~~~b; ,.,. ~4;1~~ t:-.;:>i ~} ~:-' ,,':._ .... :v__<-:;,, '.'· ,t-~~'.¢'.i.r~·;:•; ND ND ND 3200 3400 2700 10 U 10 U 10 U Butylbenzylphthalate :.1'.;;o "' ''·'ir:'"!f';¥rt1(~i ~if~~ii~ ND ND ND 1800 1500 1000 10 U 10 U 10 U NOTES: , SW/UT --Surface Water Sample/Concentrations reported in micrograms per liter (µg/1) or parts per billion (ppb) SE --Sediment Sample/Concentrations reported in micrograms per kilogram (µglkg) or parts per billion (ppb) ND --Not Detected TABLE IS -- 44 Five-Year Review Report National Starch & Chemical Company Superfund Site September 2002 HISTORICAL ANALYTICAL DATA FOR 1,2-DICHLOROETHANE IN SURFACE WATER/SEDIMENT SAMPLING OF THE NORTHEAST TRIBUTARY . SAMPLE NUMBER" MARCH 1987 JUNE 1987 Ocr .. Nov. . JULY 1990 JUNE1991 MAY 1992 JUNE1992 JANUARY 1993 1999Q3 2000Q3 1989 SW-1/SE-l 1,400/18b. --------------------------- SW-2/SE-2 ND/ND --------------------------- SW-5/SE-5 ND/ND ------------' --------------- NS-Wl/Sl ---ND/ND ------------------------ NS-W2/S2 ---ND/ND ------------------------ NS-W3/S3 ---ND/ND ------------------------ NS-W4/S4 ---4,400 J/3,400 J ---------··-------------- SW/SE-09 ------350/76 160/980 77/23 150 J/9 J ------5 U/7.7 U 19/7 U SW/SE-10 ------1,200/14 1,600/ND 810/310 1.300 J/610 D ------5 U/7.4 U 160/7 U SW/SE-11 ------ND/ND ND/ND ND/ND ND/ND ------5 U/23 U 5 U/12 U SW-12A ------------------ND --------- (Background) SW/SE-12 ---------NS/ND NS/ND 2 J/ND ---ND/ND ------ (Background) SW/SE-13 ---------880/3,400 l,800/7,400 3,200 D/290 ---200 J/1,200 D 10/7.4 U 3 J/6 U SW/SE-14 ---------l ,700/1,200 l ,200/4,200 590 D/l ,000 D ---- SW/SE-15 ---------ND/ND ND/ND --------- SW/SE-16 ---------------1,300 DJ/61 I ------ NOTES: Concentration for surface water samples are in micrograms per liter (µg/1) or parts per billion (ppb) Concentration for sediment samples are in micrograms per kilogram (µg/kg) or parts per billion (ppb) " SW/SE -surface water/sediment; NS-WIS -surface water/sediment h First value represents concentration of 1,2-DCA in surface water/Second value represents concentration of 1,2-DCA in sediment D -Concentration reported from secondary dilution J -Concentration is estimated · 1 ND -.Analyzed for but not detected NS -Not sampled (no water available) U -Undetected at the indicated quantitation limit LEGEND • MONITORING WELL LOCATION ♦ EXTRACTlc»,t WELL LOCATION "' STREAM CAUC( LOCATION (749.48) GROUND-WATER ELEVATION CROUND-WAT[R ELEVATION CONTOUR (DASHED WtiERE INFERRED) SCAl£ IN FEET - • • P-2 45 A Five-Year Review Report Wl,Jational St.irch & Chemic;il Company Superfund Site September 2002 GROUNDWATER ELEVATION CONTOUR MAP FOR OU #I/OU #2 TRANSITION ZONE WELLS FOURTH QUARTER 1999 FIGURE 7 LEGEND • lr.lONITORINC WELL LOCATION ♦ EXTRACTION WELL LOCATION S STREAM GAUGE LOCATION (714.20) CROUND-WATtR ELEVATION ,,,......_____, GROUND-WATER EL(\IATION CONlOUR {DASHED 'M-IERE INFERRED) ... SCAI.L IN F£ET \ 46 \ \ \ / I I I I I I I I I 'u; I l \ I I I I I I I \ I I I r I • Five-Year Review Report ational Starch & Chemical Company Superfund Site Sep1ember 2002 GROUNDWATER ELEVATION CONTOUR MAP FOR OU #I/OU #2 BEDROCK WELLS FOURTH QUARTER 1999 FIGURE 8 I I I I I / 0 47 • Five-Year Review Report ational Starch & Chemical Company Superfund Site September 2002 LEGEND • MONI TORJNG 'ltt:LL LOCATION ♦ EXTRACTION 'NELL LOCATION A SURfACE WATER/SEDIMENT SAMPLE LOC:ATION GROUNDWATER ELEVATION GROUNDWATER EL£\IATION CONTOUR (DASHED M-IERE INFERRED) -• SCAI..£ IN FEET / I(;\\ I (Jj I I . I \ , 10 ~\\__,, I ' b-- ! I j I / 'b I I I / \, '/, \ 11r---__ --.____ \ 1, ---------------~ ... \ ' \ GROUNDWATER ELEVATION CONTOUR MAP FOR OU #3 SAPROLITEffRANSITION ZONE WELLS -THIRD QUARTER 2000 FIGURE 9 I I I I I • 48 A Five-Year Review Report WJ-lational Starch & Chemical Company Superfund Site September 2002 LEGEND • MONITORING WELL LOCATION ♦ EXlRACTlON WELL LOCATION A SURFACE WATER/SED1t.4ENT SAMPLE LOCATION GROUNDWATER ELEVATION --GROONDWATER EL.£VAT10N CONTOUR (DASHED WHERE INFERRED) SCAL( IN FEET -,- GROUNDWATER ELEVATION CONTOUR MAP FOR OU #3 BEDROCK WELLS - THIRD QUARTER 2000 FIGURE 10 0 49 • Fivc-Yc:ir Review Report ational Starch lJ:-Chemical Company Superfund Site September 2002 SURFACE WATER SAMPLING LOCATIONS FOR MARCH 1987 FIGURE II / I. H•tbylene chloride Ac■ton■ 19 ug/Kg Di-n-butylphth•l•t■ 8 uql !Cg USI u9/tc.9 • . f-1.ve•Ycar Review Report tional Starch & Chemical Company Supcrfund Site September 2002 50 AG■ton■ ,o ug/Kg Butyl.beazylphth•l•t■ lOOO BJ•(2-etbylbaiyl)phtb•l•t• Ac■too• •2 ug/Kg uq/Kg 2700 ug/Kg Butyl.benzylphth•l•t■ 1500 ug/Kg Bi•f2-■tbylbazyl)pbth•l•t■ 3400 uq/Kg Butylbenzylpbth•l•t■ 1800 ug/Kg B!a(2-■thylb&xyl)phth•l•t■ 1200 ug/Kg / \ .. SEDIMENT SAMPLING LOCATIONS FOR MARCH 1987 FIGURE 12 0 51 • Five-Year Review Report tional Starch & Chemical Company Superfund Site September 2002 LEGEND • MONITORING WEU. LOO, TION ♦ EXTRACTION WELL LOCATION • APPROXIMATE LOCATION Of SURfACE WA TER/S[DIMENT SAMPLING LOCA, TION $ APPROXIMATE LOCATION Of STREAM GUAG( LOCATION 0 UffiE ACRES TRAILER PARK DOMESTIC WEU. LOCATION 'f SCAL[ IN fE[T JUNE 2000 SURFACE WATER/SEDIMENT SAMPLING LOCATIONS ON UNNAMED TRIBUTARY FIGURE 13 N ------ I NATIONAL STARCH PROPERTY LJNE • --------- 52 \ NS-\ NS-S1 . \ • Five-Year Review Report tional Starch & Chemical Company Superfund Sire September 2002 AIRPORT ROAD CJ ucooNs o· 1000' 2000· SCA!.£ Al'PROXIMA TE JUNE 1987 SURFACE WATER/SEDIMENT SAMPUNG LOCATIONS ON NORTHEAST TRIBUTARY FIGURE 14 j i I ' Nl50 - NS50 - ABANDONED RAILROAD SPUR ... -.. -... -. -.... -.. -..... -.. ·, 53 '··-······-····-· AREA2 ........ -. - '. -. -. ' ' : ...... --...... : Iii~:;..~:::::~.~-.-... -... -........ -...... -.. -·. ~-::::::, · .. -........ _, .... - [] '• El LAGOON 1 . 2 .... . I E -350 E 250 SW/SE-12 CHAIN UNK FENCE-----...___ Five-Year Review Reporl •1ational Starch & Chemical Company Superfund Site September 2002 SW/SE-10 l SW/SE-16 l I SW/SE-13 I AP!'ROlOMATE SCA.£ Ill! 1 00 200 ICJII .:io 100 CURRENT SURFACE WATER/SEDIMENT SAMPLING LOCATIONS ON NORTHEAST TRIBUTARY FIGURE 15 • · Five-Year Review Report National St Chemical Company Superfund Site September 2002 54 although some contaminant levels in some wells have indicated a decrease, most groundwater concentrations in situ (prior to treatment) are still not meeting the groundwater performance standards set forth in• the RODs. Furthermore, a number of the current groundwater ARARs are lower than the existing ROD levels. Thus, onsite groundwater would not currently be considered to be "restored" or protective of human health or the environment. The institutional controls that are in place include deed recordation to inform any potential future buyer of the property of the contamination present at the Site. However, the deed recordation likely does not meet the current requirements of Inactive Hazardous Sites Response Act of 1987 (North Carolina General Statute 130A-3IO et. seq.), as amended, or the associated Guidelines for Assessment and Cleanup (NCDENR, Inactive Hazardous Sites Program, 2001). This deed recordation was included on the description of the property on June 12, 1997. The fence around the plant operations area which limits access to the contaminated areas has been maintain. All cracks, seams, and other points of infiltration through paved and built-up areas has been maintained. Ir. summary, the answer to question (A) Js(Are) the Remedy(ies) Functioning as Intended by the Decision Documents? is No. 7.2 QUESTIONS 8: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES USED AT THE TIME OF THE REMEDY STILL VALID? Overall, the exposure assumptions, toxicity data, cleanup levels, and RAOs included in the RODs are still valid. The plant remains an active facility and there is no indication that this status will.change anytime in the near future (i.e, within the next five years). Access to the active part of the facility is controlled via a six-foot chain linked security fence. The exposure as.sumptions used in all four RODs to develop the Human Health Risk Assessment were basically the same. They included current and future exposure of workers on-· site under a industrial scenario and secondly, the propetty being transformed into a residential area in the future. Although there has been no change in the potential future use exposure scenarios, the ass_umptions and processes used to develop the Human Health Risk Assessment have changed over time. Some of the toxicity factors for the chemicals of concern have changed as new data becomes available. The toxicities for some of the chemicals have either increased or decreased but the over all impact to the Baseline Risk Assessments is negligible. This is especially true due to the conservative methodology of the risk assessment process. As stated earlier, some of the ARARs have changed since the issuance of the RODs but there is no need at this time to initiate modifications to the RODs to integrate these new ARARs as remediation efforts at this Site will continue for at least 20 years. The RAOs remain acceptable for the Site at this time. · 55 A Five-Year Review Report National St~ Chemical Company Supcrfund Site Scp1ember 2002 In summary, the answer to question (B) Are the Exposure Assumptiolls, Toxicity Data, Cleanup Levels, and RAOs Used at the Time of Remedy Selection Still Valid? is No. 7.3 QUESTION C: HAS ANY OTHER INFORMATION COi\-lE TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? As discuss in Section 6.5, no ecological impacts were identified during the 1993 baseline risk assessment and no new ecological impacts were identified during the Five-Year Review process. Tables 14 and 15 present analytical data for samples collected from the Unnamed Tributary and Northeast Tributary, respectively. As can be seen, the levels of 1,2-DCA have decreased in both streams with time. Periodic surface water and sediment samples will continue to be collected from the Unnamed Tributary and the Northeast Tributary to insure that these env1ronmental media are not being adversely impacted. This is especially true for the Unnamed Tributary until the assessment of the PPES is completed. No weather-related events have affected the protectiveness of the remedies. There is no other information that calls into question the protectiveness of the remedies. In summary, the answer to question (C) is Has Any Other Information Come to Light That Could Call Into Question the Protectiveness of the Remedy( ies)? is No. 1 8.0 ISSUES Identified issues have been listed in Table 16. TABLE 16 --LIST OF SIGNIFICANT ISSUES ISSUE AFFECTS PROTECTIVENESS (Y /N) CURRENT FUTURE Complete OU #4 Biodegradation Treatability Study N y Complete assessment of PPES N y Complete assessment of OU #2 N y Continued high detection levels for groundwater analyses y y The decision documents for the Site do not reflect current ARARs or subsequent recordation requirements and N y cleanup standards for both soil and groundwater Before this Site can be considered for deletion, the issue of how clean is clean for the soils in the Trench Area N y needs to be addressed 56 & Five-Year Review Report National St~ Chemical Company Superfund Site September 2002 · As seen in Table 16, one of the issues listed is the continued high detection levels for groundwater samples. This issue has been highlighted in a number of correspondence sent to NSCC. In response, NSCC is working with the analytical laboratory they send their groundwater samples in an effort to resolve this issue. 9,0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS I Recommendations offered in this Five-Year Review are summarized in Table 17. 10.0 PROTECTIVENESS ST A TEMENT The portion of the Site remedy dealing with potential soil exposures is protective of human health and the environment in the short-term. The Trench Area, Area 2, and the lagoon area remain covered and the deed restrictions are in place. At the conclusion of Phase 2 of the Natural Degradation Treatability Study in 2007, a definitive answer should be made regarding long-term protectiveness and the contingency in the October 1994 OU #4 ROD will either be imple'mented or deleted from the OU #4 ROD. There are no current onsi te groundwater receptors and the nearest private, potable wells is located approximately 2,700 feet north of Area #2. Since there is currently no indication of contaminated groundwater or surface water exiting the property, the remedy is considered protective in the short-term. Groundwater at the NSCC Site is not protective of human health and the environment in the long-term due to the followi_ng reasons: the current groundwater monitoring system is insufficient to determine if the plumes are being captured, groundwater is likely migrating to a degree and discharging to adjacent surface water, groundwater performance standards are not being met throughout the plume, and groundwater is not currently "restored", as some of ARARs are lower than the ROD standards. 11.0 NEXT REVIEW The next Five Year Review should be scheduled five years from the date of this Review in September 2007. 57 TABLE 17 --SUMMARY OF RECOMMENDATIONS AND FOLLO\V-UP ACTIONS ISSUE RECOMMENDATIONS AND PARTY FOLLOW-UP ACTIONS RESPONSIBLE . How clean is clean for the soils in the Initiate discussions between EPA/NCDENR regulatory agencies, NSCC, and Trench Area public to discuss this issue /NSCC Complete OU #4 Biodegradation Maintain communication with NSCC Treatability Study NSCC Complete assessment of PPES Maintain communicationwith NSCC NSCC . Conduct soil sampling in Complete assessment of OU #2 conjunction with OU #4 NSCC Biodegradation Treatability Study Effectiveness of Collection Trench in Evaluate if Collection Trench is NSCC capturing plume capturing plume Effectiveness of other groundwater Detennine if efficiency of extraction systems existing groundwater extraction NSCC systems can be enhanced Are groundwater monitoring systems Detennine if additional EPA/NCDENR adequate? monitoring wells are needed /NSCC Are contaminants leaving the Site via Locate and sample new sampling the Northeast Tributary point downstream of Sampling NSCC Location SW/SE -09 The decision documents for the Site Amend decision documents' and do not refle_ct current ARARs or EPA/NCDENR NSCC deed recordation to reflect subsequen·t recordation requirements /NSCC and cleanup standards current ARARs OVERSIGHT AGENCY EPA EPA EPA EPA EPA EPA EPA EPA' EPA I Fivc-.'r'ear Review Report National Starch & Chcmkal Company Supcrfund Site September 2002 AFFECTS PROTECTIVENESS? (Y/N) MILESTONE CURRENT FUTURE September N y 2007 February N y 2007 April 2003 N y July 2003 N y December N y 2003 September 2007 N y December N y 2004 December 2003 N y September N y 2012 . • • 5-Year Review Questionnaire Site ±~-i!ti:::.rf!o~ City/State~;=(· . Name of Citizen Address How lon_g have you lived near the Site? o(.5 f"' -.. Are you familiar with EPA activities over the past years? ¼t !lJf.; .:..t4'r4-.:_.. ~ . DNbu still have any concerns regarding EPA clean up activit{ts4of the Site? ' D~: think you have been adequately informed about clean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in ouJ 5-year re~ of site advities? h:J · J.& , Ji. . ~ ~ " tf'l\.-.l--~ ,,....,.__ ( /.,0 L{_,• 7 Is here someone else that you would like to recommend we contact for more information? 0 Do you h ove communicati ith the public? LL.f:j_~i.e____,:&f:C:!."-J&c.p/,~~_JcU:::_L,L-&,&:i&.~~.!J:'.i~'-'4..4---- [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at __________________________ _ Interview conducted by: Date conducted : • • 5-Year Review Questionnaire Site ~~ City/State~~~- Date:__________ Phone No. ::::s: C-it-iz_e_n_~'-------------- How long have y?u· lived near the Site? / ;J, 1(t'M _ Are you familiar with EPA activities over the past years? ,&<..!<.><Y1-f,11-~.u.~..u~41 ______ _ Do you still liave any concerns regarding EPA clean up activities of the Site? ve b~en adequately informed about c ean up activities at the Site? t:l,,u_ Is there any information about the Site that you would like to share with us that would assist in our/J~ear review of site activities? Is there someone else that you would like to recommend we contact for more information? /JD . ' Do you hav any suggestions that EPA can implement to imp"rove communication with the public? -+-"---"O'------------------------------ [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at--------------~------------ lote~iewWodocted by, j;,k~tJ-~ Date conducted : / 9 e, • • 5-Year Review Questionnaire Date: Site City/State Name of Citizen Address How long have you lived near the Site? Phone No. Are you familiar with EPA activities over the past years? Do y still tiave any concerns regarding EPA clean up activities of the Site? () . been pleased or Qi.§Rlea -/o hink you have been adequately informEsd about clean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in 01,1!fiilffE/!eP.@;:t;;u) IJJ't ~~Lr? e contact for more information? nication with the· [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at-------------------------- • • 5-Year Review Questionnaire Site City/State Name of Citizen Address How long have you lived near the Site? Are you familiar with EPA activities over the past years? Do ii have any concerns regarding EPA clean up activities of the Site? u think you have been adequately informed about clean up activities at the Site? Is here any information about the Site that you would like to share with us that would assist in ouj}~ar ~ev~t~i;z;_ _ £, 4 f Z t[L 3 wa,/4 uld like to recommend we contact for more information? ' [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at--------------------------- lc<eMew co,dcc<ed bY'4d'.:ai::/ Date conducted : __ __,/_,fc;~=~""-'-J.L, -~L____ ~ • • 5-Year Review Questionnaire Site ~,~ City/Stat; , ~ Address Are you familiar with EPA activities over the past years? F ~JJ:jtt &-j1«'-"t;t;!,.;~ Overall, have you been pleased or displeased with EPA actions at this Site? Is there any information about the Site that you would like to share with us that would assist in o~ review?c~? · H-+-1 ~ · r Q., -/U;~a..e, recommend we contact for more information? [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at __________________________ _ Interview conducted by: Date conducted : • • 5-Year Review Questionnaire Site ~1:il:t!;,~a£ City/State ~ = ;r/4 ('.} I (-d~i] , Phone No. _ Date: Name of Citizen Address How long have you lived near the Site? Are you familiar with EPA activities over the past years? Do you still tiave any concerns regarding EPA clean up activities of the Site? Overall, have you been pleased or displeased with EPA actions at this Site? Do you think you have been adequately informed about clean up activities at the Site? Is there any information about the Site that you would like to share with us that would assist in our 5-year review of site activities? Is there someone else that you would like to recommend we contact for more information? Do you have any suggestions that EPA can implement to-imp'rove communication with the public? --------------------------------- [A copy of the 5-year review will be placed in the Site Information Repository file located in the Site Information Repository at __________________________ _ Interview conducted by: Date conducted : __________ _ • LIST OF DOCUMENTS REVIEWED Remedial Investigation Report (Prepared by NSCC} (January 1988) Record of Decision for OU# I ( Prepared by EPA} (September 30, 1988) Five-Year Review Report for OU #I (Prepared by EPA} (June 18, 1996) Five-Year Review Report for OU #2 ( Prepared by NSCC} (August 1998) Explanation of Significant Differences #2 for OU #I {Prepared by EPA} (September 28, 1990) Record of Decision for OU #2 { Prepared by EPA} (September 28, 1990) Record of Decision for OU #3 {Prepared by EPA} (October 7, 1993) Record of Decision for OU #4 ( Prepared by EPA} (October 6, 1994) Explanation of Significant Differences #1 for OU #1 {Prepared by EPA} (June 10, 1997) Phase I Natural Degradation Treatability Study Work Plan ( Prepared by NSCC} (March 26, 1998) Final Design Report for OU #3 ( Prepared by NSCC} (March 1999) · Phase II Natural Degradation Treatability Study Work Plan (Prepared by NSCC} (January 2000) Combined OU #1 & #3 Pretreatment System Operation & Maintenance Manual ( Prepared by NSCC} (April 2000) Final Construction Report Combined OU #1 + OU #3 Pretreatment System {Prepared by NSCC} (August 2000) Remedy Evaluation Report for OU #1 {Prepared by NSCC} (November 2000) Draft Five-Year Review Report for All Operable Units {Prepared by NSCC} (August 2001) Five-Year Review Report for All Operable Units {Prepared by NSCC} (March 2002) 200 I Site Monitoring Report ( Prepared by NSCC} (August 2002) All Appropriate Monthly Progress Reports { Prepared by NSCC} Appropriate Quarterly Reports { Prepared by NSCC} • APPENDIX C SEPTEMBER 25, 2002 CONCURRENCE LETTER FROM NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES SEP.-25'02(WED) 16:16 ~ORTII L,\l(()Lll'IA NCDENR .TE MGMNT DEPARTMENT Of ENVIRONMENT AND NATIIJtAL RESOURCES DIVISION OF WASTE MANAGEMENT MICIIAEL f. EAsLEY, GOVERNOR Wn.l.lJ\M G. Ross, ,IR-, SECR!,.1ARY PCXTER R. MATTIIEWS, DIRECTCIK Mr . .Ton K. Bornholm Remedinl Project Mnnag~r Superfund Branch Waste Management Division US EPA Region JV 61 Forsyth Street. l I'h Floor Atlanta, Georgia 30303 RE: Five-Year Review Report September 25, 2002 National Starch and Chemical Company NPL Site Salisbury, Rowan County,_NC Dear Mr. Bomholm: The State ofNonh Carolina has reviewed the attnched First Five-Year Review Report for the Entin: National Starch & Chemical Company National Priority List (NPL) Site ("Site"). The State of North Carolina concurs with the First Five-Year Review Report for the Entire National Starch & Chemical Company (NSCC) NPL Site, subject io the following conditions. 1 . Siate concurrence on the First Five-Year Review Report and the selected remedy for the Site is based solely on the information contained in the subject First Five- Year Review Report. Should the State receive new or additional information that signlfic!llltly_ affects the conciusions or remedy selection contained in the First Five-Year Review Report, it may modify or withdraw this concUITence with wrinen notice to the United States Environmental Pro,ection Agency (US EPA) Region JV.- 2. State concurrence on this firSl Five-Year Review Report in no way binds the · State to conc\lf in future decisions or commits the State to participate, financially or otherwise. in the clean up of the Site. The State reserves the right to review, overview, comment. and make independent assessment of all furure work relating to this Site. 3. If, after remediation is complete, the total residual risk level exceeds lo·•, the State may require deed recordation/resuiction tdocwnent the presence ofresidual comarninaiion and possibly limii furure use of the property as specified in NCGS l 30A-3 l 0.8. . 1646 M.\IL SER\'lCE CE~TE:11., R.AL£1GII. No11n1 CAROLl"A 17699-1646 401 Oer.1u .. 1s R.OAP, StllTE 150, R.Al.f.lCII, NC :?7605 PIIOSE: 919-733-4996 If A-X: 919-71 S-3605 • • · .. -• •·· •----·--:t:1>01 a .. -.... • ..-,.11na.:. Pnc:i• .. rn..,~11•1F.R PA.rtR SEP.-25'02(WED) 16:17 Mr. Joo K. Uomholm September 25, 2002 . Pase 2 NCDENRiSTE MGMNT TEL:. 733 4811 The State of North Carolina appreciates the opportunity to comment on the First Five- y car Review Report for the Entire NSCC Site and we look forward to workins with the US EPA on the final remedy. If you have any questions or comments, please feel free to contact me at (919) 733-2801, extension 278. · Attachment David .1. Lown, LG, PE Acting Head Federal Remediation Branch Superfund Section cc: Phil Vorsatz, NC Remedial Section Chief Jack Butler, Chief NC Superfund Section P. 003