18060_Cooper Bussmann_Supplemental Phase II Assessment CB_20150224

February 24, 2015 133-84340.01
North Carolina Department of Environment and Natural Resources
Department of Waste Management 1646 Mail Service Center
Raleigh, NC 27699-1646 Attn: Ms. Sue Murphy, Engineer
RE: SAMPLING IN RESPONSE TO THE NCDENR RESPONSE LETTER (NOVEMBER 6, 2014) COOPER BUSSMAN GOLDSBORO 210 DIXIE TRAIL, GOLDSBORO, NC

Dear Ms. Murphy:
Eaton Corporation (Eaton) retained Golder Associates NC, Inc. (Golder), to perform a supplemental Phase II groundwater sampling event at the Eaton/Cooper Bussmann facility located at 210 Dixie Trail, in
Goldsboro, Wayne County, North Carolina (Site - see Figure 1). This additional groundwater sampling event was performed in response to the North Carolina Department of Environment and Natural
Resources (NCDENR’s) November 6, 2014 letter regarding to Cooper Bussman Goldsboro (NONCD0002598) facility (attachment 1).
1.0 BACKGROUND
Golder performed supplemental assessment activities to assess potential soil and groundwater impacts
identified during limited Phase II activities conducted in September 2013. Golder submitted the results of the September 2013 limited Phase II investigations to the North Carolina Department of Environment and
Natural Resources (NCDENR) Inactive Hazardous Sites Branch (IHSB) with a completed Site Conditions Questionnaire, dated July 3, 2014. NCDENR sent a letter dated August 12, 2014 to Eaton indicating that
the Site can be cleaned up through the IHSB Registered Environmental Consultant (REC) Program with oversight by a Registered Site Manager (RSM).
The response letter indicates that the next step is for Eaton is to enter into an REC-Administrative
Agreement (AA) with NCDENR to complete voluntary cleanup and required Eaton to reply to NCDENR’s request for a REC-AA within 60 days (i.e., by Saturday, October 11, 2014). Concurrent with NCDENR’s
review of the Site Conditions Questionnaire, Golder completed supplemental Phase II activities at the Site in July 2014. The results of the supplemental Phase II activities were submitted to NCDENR in a letter
report Response to Notice of Eligibility/Results of Supplemental Phase II Activities dated October 9, 2014. Based on the results of the July 2014 supplemental Phase II activities, it did not appear that a release has
occurred at the Site and Eaton requested NCDENR reevaluate whether the Site needs to enter the REC Program.
Eaton received a response letter from the NCDENR Inactive Hazardous Sites Branch (IHSB) on
November 6, 2014 regarding the previously submitted (Golder) Supplemental Limited Phase II Report dated September 10, 2014. The NCDENR response letter requested the following:
 Provide information on the storage and disposal of trichloroethylene and trichloroethylene-containing rags for spot cleaning as described in the October 2014 letter
report (Page 1 Bullet Item 3)

Golder Associates NC, Inc.
5B Oak Branch Drive Greensboro, NC 27407 USA Tel: [phone] Fax: [phone] www.golder.com Engineering Lic. No. C-2862/Geology Lic. No. C-399 Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation
Ms. Sue Murphy February 24, 2015 NCDENR 2 133-84340.0004

 Perform on additional groundwater sampling event for the same range of contaminants
as those taken during the prior sampling events in September 2013 and July 2014.
The requested information is presented below.
2.0 STORAGE AND DISPOSAL ACTIVITIES
Mr. Mike Graham (Eaton) contacted Mr. Jerry Bridgers, the former Eaton environmental coordinator for
Cooper from mid-1980s to mid-2000s. Mr. Bridgers indicated that the use of trichloroethylene (TCE) at the Eaton Goldsboro site was used and managed as follows:
 TCE was not stored in tanks or used for degreasing operations (no tanks or parts
washers were used onsite). The virgin TCE was stored in five-gallon buckets in a flammable storage cabinet.
 TCE was used to clean 0.5-inch diameter by 0.5-inch tall metal caps used to cover connections for electrical fuses. The soldering process included the use of a resin-based flux, which needed to be cleaned before the caps could be placed on the fuses. The process included pouring approximately one pint of TCE and grounded corn cob or
walnut shells (tumbling media) into a small cement mixer. The TCE/tumbling action would remove the resin.
 TCE evaporated during the mixing process and the caps were cleaned in batches.
 TCLP testing on the used tumbling media was below EPA hazardous levels which was then transported to and disposed of in accordance with local, state and federal regulations.
 TCE was also reportedly used sporadically to remove bottle fuse labels.
 TCE was used from approximately 1990 to the mid-1990s. The facility converted to a citrus-based cleaner when the fuse line moved to Juarez, Mexico in 2009.
3.0 SUPPLEMENTAL PHASE II INVESTIGATION METHODOLOGY
The following sections describe the field methodology followed during the additional groundwater sampling event completed in November 2014. The field work described herein was supervised and
performed by Golder’s staff.
3.1 Monitoring Well Sampling
Golder measured depth-to-water levels relative to the top-of-casing in each of the monitoring wells.
Golder calculated the groundwater elevation measured at each monitoring well by subtracting the measured depth to groundwater from the elevation of the top-of-casing in each respective well. The water
table elevation measurements are provided in Table 1.
Golder personnel collected groundwater samples from the five monitoring wells. Golder used a peristaltic
pump and dedicated teflon and silicon tubing to purge and collect groundwater samples from the wells using EPA low-flow sampling techniques. Golder monitored water quality parameters during well purging
activities including temperature, specific conductivity, pH, turbidity, ORP, and dissolved oxygen. Groundwater samples were collected following the stabilization of field water quality parameters (to within
10 percent of the previous two readings). The groundwater collection forms are provided in Attachment 2.
Golder submitted the groundwater samples on ice, under chain-of-custody procedures, to ALS for
analysis of one or more of the following parameters: VOCs using EPA Method 8260C, SVOCs using EPA Method 8270 D, total metals using EPA Methods 6010C/7471B (mercury), and TPH using EPA Method
8015D GRO/DRO. Groundwater samples collected from monitoring wells MW-12 and MW-13 (nearest the “pit”) were also analyzed for glycols (ethylene and propylene) using EPA Method 8015C. Golder also
collected one duplicate groundwater sample for quality assurance purposes from MW-12. The laboratory analytical reports are presented in Attachment 3.

Ms. Sue Murphy February 24, 2015 NCDENR 3 133-84340.0004
3.2 Quality Assurance and Quality Control
Golder performed the assessment activities in general accordance with industry standard practices. To confirm the accuracy and reproducibility of the laboratory analytical results, the analytical laboratory
implemented a Quality Assurance and Quality Control (QA/QC) program, including laboratory replicate samples, method blanks and control standards. The laboratory QA/QC data generated during the sample
analysis are included in the laboratory analytical reports (Attachment (2)) provided to Golder. Golder also submitted one field duplicate sample and a trip blank sample for chemical analysis (using EPA Method
8260 for VOCs) for quality control purposes.
4.0 SUBSURFACE GROUNDWATER CONDITIONS
Based on groundwater elevations monitored on November 25, 2014, shallow groundwater flows to the
southeast. The conceptual groundwater contour map is presented on Figure 2. Water levels in the shallow monitoring wells ranged from 4.32 to 4.90 ft. bgs. These shallow wells are screened in a sand unit
that produces a significant amount of water during groundwater purging and sampling without significant drawdown. The groundwater flow direction, toward the east-southeast, is similar to that reported for the
July 2014 sampling event and also similar to the October 1981 groundwater flow direction presented in the Investigation of Groundwater Conditions at the Sycor Building, Goldsboro, NC Report, prepared by
Geraghty & Miller, Inc., dated October 1981.
Based on review of the historical topographic map, an un-named pond is located approximately 1,600 feet
to the southeast of the Site. The Neuse River is located approximately 4,600 feet west of the Site and meanders to the southeast of the Site (7,000 feet). The surface water flow on the Site is via sheet flow,
which infiltrates into the surrounding soil or flows to drainage ditches around the property.
5.0 RESULTS
Golder personnel compared the groundwater results to the North Carolina 2L Groundwater Standards
(NC 2L) and Interim Maximum Allowable Concentrations (IMAC). Copies of the laboratory analytical reports are included in Attachment 3. The analytical laboratory results (detections only) for groundwater samples are summarized on Tables 2.
5.1 Groundwater Quality Summary
A summary of the detected constituents in groundwater are summarized in Table 2. Many of the reported detections were laboratory estimated concentrations. ALS reported all analyzed VOC, SVOC, metal, TPH,
or glycol compounds at concentrations below the NC 2L Groundwater Standard.
6.0 SUMMARY OF FINDINGS AND CONCLUSIONS
Golder conducted additional groundwater sampling activities at the Cooper Bussmann facility located at
201 Dixie Trail in Goldsboro, Wayne County, NC on November 25, 2014. Based on the field observations and laboratory analytical results obtained during the supplemental Phase II activities, the following
summary is provided:
 Groundwater flow in the surficial aquifer is towards the east-southeast based on
groundwater level monitoring performed in July and November 2014. This calculated groundwater flow is consistent with historically reported direction of local groundwater
flow.
 Based on the additional groundwater sampling activities, there are no groundwater
exceedances on Site. The results of the groundwater quality analyses indicate that no VOCs, SVOCs, metals, TPH, or glycols were detected at concentrations above the NC
2L Groundwater Standards.
Using this newly provided data in conjunction with the initial Site Cleanup/Questionnaire submission,
Eaton believes they have demonstrated that there are no soil or groundwater impacts above the

Ms. Sue Murphy February 24, 2015 NCDENR 4 133-84340.0004

applicable NCDENR soil and groundwater standards that would result in the need for the to be listed
as a state contaminated site.
7.0 CLOSURE
Based on the results of the November 2014 sampling effort (report in this submission) and the September
2014 supplemental Phase II activities there is no evidence of a release to the environment from Site operations. Groundwater concentrations at the Site are below the NC2L standards.
Based on this information, Eaton believes it is unnecessary to enter into an REC-AA and additional investigation and remediation of the Site is not warranted.
Please contact Brian Eichlin at [phone] if you have questions regarding this subject.

Sincerely
GOLDER ASSOCIATES NC, INC.

Richard P. Lovett, P.G. Brian J. Eichlin, P.E.
Senior Project Geologist Principal and Senior Consultant

Frederick M. Booth, P.G. Principal and Practice Leader

Attachments: Table 1 – Monitoring Well Construction and Groundwater Elevation Information Table 2 – Summary of Groundwater Analytical Detections
Figure 1 – Site Location Map Figure 2 – November 2014 Conceptual Groundwater Contour Map
Attachment 1 – NCDENR Response letter (November 6, 2014) Attachment 2 – Groundwater Sample Collection Forms
Attachment 3 – Laboratory Analytical Reports
RPL/BJE/FMB

TABLES

February 2015 Table 1
Monitoring Well Construction and Groundwater Elevation Information
Cooper-Bussmann
Goldsboro, NC
133-84340.01
G:\Projects\Eaton - Goldsboro\Phase II Investigation\Report\Copy of Tables 1 through 2 November 2014 - Goldsboro (final).xlsx
Page 1 of 1
Well ID Northing Easting
Ground Surface
Elevation (ft
msl)
Top of
Casing
Elevation (ft
msl)
Top of
Screen (ft
bgs)
Bottom of
screen (ft
bgs)
Depth to water
(ft BTOC)
WL Elevation (ft
msl)
MW-09 586534.18 2296979.21 70.771 69.881 4 14 4.90 64.98
MW-10 586361.62 2297120.45 70.358 69.758 4 14 4.80 64.96
MW-11 586120.68 2297103.76 69.649 69.398 4 14 4.65 64.75
MW-12 586158.51 2296974.69 69.753 69.336 4 14 4.34 65.00
MW-13 586234.6 2296902.17 70.096 69.369 4 14 4.32 65.05
Notes:
ft BTOC = feet below top of casing
WL = Water Level
Elevations in NAD 88 Prepared by: RPL 2/24/2015
ft msl = feet above mean seal level Reviewed by:BJE 2/24/2015
ft bgs = feet below ground surface
Depth to water measured on November 25, 2014.
February 2015 Table 2
Summary of Groundwater Analytical Detections
Cooper Bussmann
Goldsboro, North Carolina
133-84340.01
G:\Projects\Eaton - Goldsboro\Phase II Investigation\Report\Copy of Tables 1 through 2 November 2014 - Goldsboro (final).xlsx Page 2 of 2UnitsNC 2L Groundwater Standard----
----
Volatile Organic Compounds (VOCs)
Methyl tert-butyl ether µg/L 20 ND ND ND ND ND ND 1.2 ND NA ND 0.62 J ND NA ND ND ND ND ND NA 0.35 JTolueneµg/L 600 1.9 2.6 17 1.7 1.4 5.0 5.1 3.8 NA ND ND ND NA ND ND ND ND ND NA ND
Semi Volatile Organic Compounds (SVOCs)
3&4-Methylphenol µg/L 40 (14)ND ND ND ND ND 0.097 J ND ND ND ND ND ND ND ND ND ND ND ND ND ND
Bis(2-ethylhexyl)phthalate µg/L 3 0.75 1.8 0.23 0.63 0.37 1.2 1.0 0.31 1.6 0.097 J 2 0.100 J 0.78 0.19 J 0.46 0.72 0.43 0.071 J 2.6 0.087 JButyl benzyl phthalate µg/L 1,000 0.027 J ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NDCaprolactamµg/L 4,000 ND ND ND ND 0.26 ND ND 0.14 J 0.077 J ND 0.079 J ND 0.062 J 0.088 J 0.2 J ND 0.13 J ND 0.1 J NDDiethyl phthalate µg/L 6,000 0.11 J 0.059 J 0.071 J 0.050 J 0.050 J ND 0.065 J ND ND ND ND ND ND ND ND ND ND ND ND NDDi-n-butyl phthalate µg/L 700 0.35 0.082 J 0.20 0.094 J ND 0.079 J 0.13 J 0.055 J 0.069 J ND 0.078 J ND ND 0.05 J ND 0.053 J ND ND 0.088 J NDDi-n-octyl phthalate µg/L 100 0.044 J 0.055 J ND 0.046 J ND ND 0.13 J ND ND ND ND ND ND ND ND ND ND ND ND ND
Pentachlorophenol µg/L 0.3 ND 0.37 ND ND 0.056 J 0.30 ND ND ND ND ND ND ND ND ND ND ND ND ND NDPhenolµg/L 30 ND 0.064 J 0.10 J ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
Total Metals
Arsenic mg/L 0.01 ND ND ND 0.00291 J ND 0.00111 J ND 0.00195 J NA ND ND ND NA 0.00426 J 0.0016 0.00181 J 0.0022 0.00152 J NA 0.00225 J
Barium mg/L 0.7 0.0362 0.0710 0.0365 0.0536 0.0136 0.0494 0.0567 0.0578 NA 0.0176 0.0880 0.075 NA 0.047 J 0.0343 0.032 0.034 0.0313 NA 0.0496
Chromium mg/L 0.01 0.000884 J ND 0.000736 J 0.000815 J 0.000978 J 0.00101 J 0.00202 J 0.00118 J NA 0.00109 J 0.0008 J 0.000608 J NA ND 0.0006 J ND 0.0006 J ND NA ND
Lead mg/L 0.015 ND ND ND 0.000418 J ND ND 0.000712 J 0.000444 J NA 0.0011 J 0.0003 J 0.000422 J NA ND 0.00019 J ND 0.00019 J ND NA NDMercurymg/L 0.001 NA NA NA NA NA NA NA NA NA 0.00007 J NA 0.000065 J NA 0.00007 J NA 0.000068 J NA 0.000065 J NA 0.000065 J
TPH - GRO/ORO
GRO mg/L (9)ND ND 0.0388 J ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
ORO mg/L (9)ND ND ND ND ND ND ND 0.059 J ND ND ND ND ND ND ND ND ND ND ND ND
Glycols
Ethylene glycol mg/L 10 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA ND ND ND ND ND
Propylene glycol mg/L 140 (15)NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA 1.4 ND ND ND ND
Notes:Prepared by: RPL 2/24/20151) ND - Not Detected Reviewed by:BJE 2/24/2015
2) µg/L - micrograms per Liter
3) mg/L - milligrams per Liter4) Bold - Indicates a detection5) Highlighted - Indicates detection above NC 2L Groundwater Standard
6) J - Estimated Value
7)
8) ft. bgs - feet below ground surface9) The reported TPH results are less than the lowest published standards for petroleum hydrocarbon fractions.
10) N = Normal Environmental Sample, Dup = Field Duplicate Sample.11) NA = Not analyzed.
12) Monitoring wells B-1 through B-8 were temporary direct push wells. Monitoring wells MW-9 through MW-13 are permanent two-inch diameter wells.
13) Monitoring wells installed in the same location are designated by color - B-2 and MW-9 and B-6 and MW-13.14) The NC 2L standard listed is for 4-methylphenol.
15) Currently a NC 2L standard does not exist for propylene glycol, the interim maximum allowable concentration published by NCDENR is shown.
4 to 14 ft. bgs
N N N Dup N N
4 to 14 ft. bgs 4 to 14 ft. bgs 4 to 14 ft. bgs 4 to 14 ft. bgs 4 to 14 ft. bgs
MW-12 MW-13 (13)
11/25/14 11/25/14 11/25/14 11/25/14 11/25/14 11/25/1407/15/14 07/15/14
MW-9 (13)MW-10 MW-11 MW-12
Sample Depth (screened interval or grab depth)
B-1
2 to 12
ft. bgs
B-7
2 to 12
ft. bgs
Sample Date
B-8
09/06/13 09/06/13 09/06/13 09/06/13 09/06/13 09/06/13 09/06/13 09/06/13
B-2 (13)B-3 B-4 B-5 B-6 (13)
TPH = Total Petroleum Hydrocarbons, GRO = Gasoline Range Organics, ORO = Oil Range Organics
2 to 12
ft. bgs
2 to 12
ft. bgs
2 to 12
ft. bgs
2 to 12
ft. bgs
2 to 12
ft. bgs
ANALYTE
N N N N N N N N
2 to 12
ft. bgs
Sample Type
07/15/14 07/15/14 07/15/14 07/15/14
SITE
CLIENTEATON CORPORATION
SUPPLEMENTAL PHASE II ESA
LEGEND
Approximate Property Boundary
REFERENCE
SERVICE LAYER CREDITS: SOURCES: ESRI, DELORME, NAVTEQ,USGS, INTERMAP, IPC, NRCAN, ESRI JAPAN, METI, ESRI CHINA
(HONG KONG), ESRI (THAILAND), TOMTOM, 2013
PROJECTEATON - COOPER/BUSSMANN
210 DIXIE TRAILGOLDSBORO, NORTH CAROLINA
TITLE
SITE LOCATION MAP
133-8434001 1 0 1
2014-06-19
CDS
NCS
JSP
THR 1 in0Path: W:\Projects\Confidential\Eaton\210 Dixie Trail\1338434\1338434A004_Figure 1.mxd KEY MAP
IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET HAS BEEN MODIFIED FROM: ANSI ACONSULTANT
PROJECT No.CONTROL Rev.FIGURE
YYYY-MM-DD
PREPARED
DESIGN
REVIEW
APPROVED
SITE
1,000 0 1,000500
Feet
GOLDER ASSOCIATES NC, INC,58 OAK BRANCH DR. | GREENSBORO, NC 27407ENGINEERING LIC NO. C-2862GEOLOGY LIC. NO. C-399
MW-964.98
MW-1064.96
MW-1164.75
MW-1265.00
MW-1365.05
<
<
<
<
<65.0064.8064.9065.0064.9064.80CLIENT EATON CORPORATION
SUPPLEMENTAL PHASE II ESA
LEGEND
<Monitoring Well Location
Approximate Property Boundary
Phreatic Surface Contours
NOTES
REFERENCE
1. TEMPORARY MONITORING WELLS INSTALLED ONSEPTEMBER 5-6, 2013, REMOVED AFTER SAMPLING ON
SEPTEMBER 6, 2013.
2. THIS MAP IS BASED ON GROUNDWATER MEASUREMENTS
TAKEN ON NOVEMBER 25, 2014.
SERVICE LAYER CREDITS: COPYRIGHT:© 2013 ESRI, DELORME,NAVTEQ, TOMTOM
SOURCE: ESRI, DIGITALGLOBE, GEOEYE, I-CUBED, USDA,
USGS, AEX, GETMAPPING, AEROGRID, IGN, IGP, SWISSTOPO,AND THE GIS USER COMMUNITY
PROJECTEATON - COOPER/BUSSMANN
210 DIXIE TRAILGOLDSBORO, NORTH CAROLINA
TITLENOVEMBER 2014 CONCEPTUAL GROUNDWATERCONTOUR MAP
133-8434001 1 0 2
2015-01-12
BSD
RPL
RPL
BJE 1 in0Path: W:\Projects\Confidential\Eaton\210 Dixie Trail\1338434\Report\1338434A001_Figure-2_Groundwater_Map.mxd IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET HAS BEEN MODIFIED FROM: ANSI BCONSULTANT
PROJECT No.CONTROL Rev.FIGURE
YYYY-MM-DD
PREPARED
DESIGN
REVIEW
APPROVED
0 100 20050
Feet
GOLDER ASSOCIATES NC, INC,58 OAK BRANCH DR. | GREENSBORO, NC 27407ENGINEERING LIC NO. C-2862GEOLOGY LIC. NO. C-399
SITE
North Carolina
FIGURE NARRATIVE
THIS FIGURE DEPICTS THE GROUNDWATER ELEVATION AS
MEASURED IN SHALLOW GROUNDWATER MONITORING WELLS
AND IS INTENDED TO REPRESENT THE APPROXIMATEELEVATION OF THE GROUNDWATER TABLE (PHREATIC)SURFACE. THE POSTED DATA WERE CALCULATED FROM
DEPTH TO WATER MEASUREMENTS MADE BY GOLDER ONNOVEMBER 25, 2014 FROM WELLS SCREENED ACROSS ORNEAR THE WATER TABLE. ONLY DATA CONSIDERED TO
REPRESENT STATIC WATER LEVEL CONDITIONS WERE USEDIN THE CONSTRUCTION OF THIS PHREATIC SURFACE MAP.THE DIRECTION OF HORIZONTAL GROUNDWATER FLOW AT
AND NEAR THE PHREATIC SURFACE CAN BE GENERALLYINTERPRETED AS BEING PERPENDICULAR TO THE
GROUNDWATER ELEVATION CONTOURS. GOLDER INFERRED
THE ELEVATION CONTOURS BASED ON THE DATAILLUSTRATED. THE ACTUAL ELEVATION OF THE PHREATIC
SURFACE IS LIKELY MORE HETEROGENEOUS THAN SHOWN
AND ACTUAL CONDITIONS WILL VARY. OTHERINTERPRETATIONS ARE POSSIBLE. THE DEPTH TO
GROUNDWATER IS KNOWN TO VARY WITH TIME.