Cenco_ FILE DOCKET E 93-97-OCR

Glen Simpson
December 16, 1997
Page 2 of3
Pursuant to 40 CFR 270.14(c)(8)(iii), codified at ISA NCAC 13A .0113, if hazardous
waste constituents have been measured in the groundwater which exceed the concentration limits
established under 40 CFR 264.94 Table 1, or if groundwater monitoring conducted at the time of
permit application under 40 CFR 265.90 through 265.94 at the waste boundary indicates the
presence of hazardous constituents from the facility in ground water over background
concentrations, the owner or operator must submit sufficient information, supporting data, and
analyses to establish a corrective action program which meets the requirements of 40 CFR
264.100.
CTI is currently in violation of 40 CFR 270.14(c)(8)(iii), codified at 15A NCAC 13A
.0113, in that CTI has failed to submit sufficient information, supporting data, and analyses to
establish a corrective action program which meets the requirements of 40 CFR 264.100.
Specifically, as stated in items 41 and 43 of the March 26, 1997 NOD, CTI has not:
A. Provided an estimate of time and horizontal distance for the complete breakdown
ofTCE (and its associated daughter products) and all other hazardous constituents
detected at this site which would be required for approval of natural attenuation as
a possible corrective action mechanism. This estimate should be based on site-
specific hydrogeologic conditions; and
B. Determined whether other hazardous constituents have migrated onto adjacent
property. Based on the results of its off-site investigation, CTI may design a
groundwater monitoring system that will demonstrate the adequacy of the
proposed corrective action system.
COMPLIANCE SCHEDULE
By January 21, 1998, CTI must comply with 40 CFR 270.14(c)(8)(iii), codified at ! 5A
NCAC !3A .0113 by:
A. Providing an estimate of time and horizontal distance for the complete breakdown
of TCE (and its associated daughter products) and all other hazardous constituents
detected at this site which would be required for approval of natural attenuation as
a possible corrective action mechanism. This estimate shall be based on site-
specific hydrogeologic conditions; and
B. Determining whether other hazardous constituents have migrated onto adjacent
property. Based on the results of its off-site investigation, CTI shall design a
groundwater monitoring system that will demonstrate the adequacy of the
proposed corrective action system.