NCD003202603_19890326_Ward Transformer_FRBCERCLA ROD_Amendment to the Enforcement Record of Decision - Remedial Alternative Selection-OCR

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AMENDMENT 'TC> THE
ENFORCEMENT
RECORn OF n~--:.~:I.SLON
REMEDIAL ALTERNATIVE SELECTION"~=~-=-===-=-"'
SCANNED
FEB 2 3 2017
N.C. Superfund Section
CHEMTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME and LOCATION
Chemtronic11
sw~ri::-:a~oa, ~!Jncombe co·.lnty, North carcli:-.c1
STATEMENT OF PURPOSE
This document represents the selected remedial action for this Site developed
in accordance with CERCLA as amended by SARA, and to the extent practicable,
the National contingency Plan.
The State of North Carolina has concurred on the selected Remedy.
STATEMENT OF BASIS
The dec.iaion ie baaed upon the administrative record for the Chemtronica Site.
The attached index identifies the items which comprise the administrative
record upon which the selection of a remedial action is baaed.
DESCRIPTION OF THE SELECTED REMEDY
MIGRATION CONTROL (Remediating Contaminated Groundwater)
Installation of a groundwater interception and extraction system downgradient
of the disposal areas in both the Front~valley and Gregg Valley. The level
and degree of treatment of the extracted groundwater will depend on l) the
ultimate discharge point of this water and 2) the level of contaminants in
the extracted groundwater. The three water discharge alternatives for the
treated water are 1) the local sewer system, 2) a surface stream and
3) on-site irrigation. The range of treatment for the extracted groundwater
includes air stripping, filtration through activated carbon filter and metal
removal. The point of discharge and the degree of treatment will be
determined in the Remedial Design stage. The water discharged will meet all
ARAR~s.
A monitoring•program, employing bioassays, will be established for surface
water/sediment. Monitoring locations will be located on the Unnamed Stream,
Gregg Branch and Bee Tree creek. The purpose of this monitoring program is
l) to insure no adverse impact on these streams during implementation of the
remedial action and 2) to establish a data base to use to measure the success
of the remedial action implemented. The initiation of this monitoring
program will be concurrent with the remedial design activities.
Review the existing groundwater monitoring system and install additional
wells, if necessary, to insure proper monitoring of groundwater downgradient
of each disposal area. Thia includes disposal areas t6, 17/8, #9, #10/11,
#23, and the acid pit area.
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In addition to the monitoring of the groundwater downgradient of each
disposal area identified above, action levels for the contaminants present in
the disposal· areas will be set eo that after remediation levels for
groundwat8.t'~·have been obtained and verified through monitoring, if this level
is reached.in any subsequent sampling episode, a remedial action to
permanently:. eliminate that source on contamination will be initiated.
SOURCE CONTROL (Remediating Contaminated Soils)
Cap Disposal Area. t6, Disposal Area t7/8, Disposal Area t9, Disposal Area
tl0/11, Disposal Area t23, and the Acid Pit Area with a Multi-Layer cap which
includes a synthetic liner. Security fencing, vegetative covers and, where
deemed necessary, a gas collection/ventilation system will be installed. The
multi-layer cap will meet as a mini.mum, the standards specified under 40 CFR
Subsection 264, Subparts K-N.
Sample On-Site Pond on Unnamed Stream
During the Remedial Design stage, sample the water and sediment in the
pond. If the analysis indicates contaminants in either the water column or
sediment, then the pond will b~ drained, with the water being treated
through the treatment system developed .for addressing the extracted
groundwater and the sediments will be transported to another disposal area
and capped along with that disposal area.
DECLARATION
The selected remedy is protective of human health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is coat-effective. This remedy satisfies the preference for treatment that
reduces toxicity, mobility, or volume ae d principal element. Finally, it is
determined that this remedy utilizes permanent solution and alternative
treatment technologies to the maximum extent practicable.
APR 2 6 1989
Date fY{Pl/z;;f4 (G~C Tidweli
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CHEMTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA· GEORGIA
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TABLE OF CONTENTS
Page No.
1.0 Introduction .................... :./ .............................. 1
J .• ,1. S.i.(t! Lor.at.tor, ~nd ·D~·e.t:;:r.iI?tL .. Jn~,,.;-..,, ~·", .. ~ .. ~, .. , , .. ·.·,. · ....... 1·
1.2 SiteHistory •..••.••••••..•... : •.•••..••••.•..•...••••••.•.• l
2. 0 Enforcement Analysis ............................................. 6
3. 0 Current Site Statue; ............................................. 6
3. 1 Hydrogeologic Setting •••••••••••••••••.••.•.•.••••.••.•••••• 6
3.2 Site Contamination .......................................... 7
3.3 Air Contamination ........................................... 8
3.4 Soil Contamination .......................................... 9
3.5 Groundwater Contamination ....•.............................. 9
3.6 Surface Water and Sediment Data ••••••••.••..•••.••••••••••. 16
3. 7 Receptors ••.•••••••••.•••••••••••••••••.••.•••.•••••••••••• 16
4. 0 Cleanup Criteria .••••••••••••••••. • ••••••••.••••.••.•••.•••••••••• 17
s.o
4. 1 Groundwater Remediation .................................... 1 7
4.2 Soil Remediation .••••••••••••• · ••••••••••••••••••••••••••••• 18
4.3 Surface Water/Sediment Remediation ••••.••.•.•••••••••.••••• 18
Alternatives Evaluated •.•••••••••••••••••••.••.•.•..•••••••••••. 18
5.1 Modification of April 5, 1988 Chemtronics Record
of Decision Remedial Alternative for Disposal
Area 2 3 •.•..••••••••••••••••• : ••••••••.•..••••••••••••••• 18
5.2 Nine Point Evaluation Criteria for Evaluating
Remedial Action Alternatives •••••••••••••.••••••.•••••••• 23
6. 0 Recommended Alternatives ••..•.••••••••••••••.•••.••••••••••••••• 2 6
6.1 Description of Recommended Remedy ..•...............•....... 26
6.2 Operations and Maintenance ................................. 26
6.3 Cost of Recommended Alternative ••••••••••••••••••.••••••••. 27
6.4 Schedule •••.•••••••••••.••••••••••••••••.••.••••••.•••••••• 27
6. 5 Future Actions ••••••••••••••••••••••••••.•••••••••••••••.•• 27
6.6 Consistency With other Environmental Laws ••.••••••••••••••. 27
7. 0 Community Relations •.•.••...••••••••••••••••.•.•.••••••••••••••• 2 7
8.0 State Involvement ••••••••••••.•••••••••••••••••.•••••••.•••••••• 28
Appendices
Appendix A -Table 8 from the Chemtronics Superfund Site Record of
Decision Signed April 5, 1988 Contaminants Found in the
Groundwater in the Vicinity of Disposal Area 23
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TABLE OF CONTENTS
(continued)
Appendix 8\\; .. Letter (with enclosures) from Chemtronica, Inc. dated
September 19, 1988
Appendix c· "· ~::.:tober 7, 1983 MemoL"a:~d:i:.t f=::;;-.i·.wade· Y..r~iyht, chief of· Q-..;.•.:...:.::::y
Assurance and Laboratory Evaluation Section, Environemntal
Services Division
Appendix D -Explanation of Significant Difference Fact Sheet/Proposed
Plan Fact Sheet (February 10, 1989)
Appendix E -Legal Notice Published in the Asheville Times/citizen
Newspaper (March 1989)
Appendix F Responsiveness Summary
Appendix G -Analytical Results of Sampling Monitor Well·SW-4 On January
4, 1989
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Figure 1.
Figure 2.
Figure 3.
Figure 5.
Figure 6.
LIST OF FIGURES
PAGE NO.
Kap Showing Site Location ••••••••••••••.••••••••.••••••••.• 2
Kap Highlighting Site Boundary •••••••••..••.••••••••••••••• 3
Map Showing Locations of Individual Disposal Area
On-Site in Front Valley and Gregg Valley •••••••.••••••••• S
Meli;, Locatii:q Surf.:ic:.3/~u)..1ct:.::face Sc.!.:. Samples in
Disposal Area 23 •••••••••••.••.••••..•..•...••••••.•••.. 10
Map Showing Locations of Monitor Wells and
Concentrations of Volatiles Found in the
Groundwater Associated with Disposal Area 23 ............ 13
Map Showing Locations of Monitor Wells and
Concentrations of other Contaminants Found
in the Groundwater Associated with Disposal Area 23 ..... 15
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Table
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Table
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l.
2.
3.
4.
LIST OF TABLES
PAGE NO . . :;iSf
contaminants Found in Soil Samples Associated with
Disposal Area 23 ......... , ••••............•..........•••• 11
contaminants Found in the Gto~ndwater in the Vicinity of
Disposal Area 23 .•••.•••••....••.••.......•.•.••..•.... 14
Gt:1..~-11nrhJ::tt.c.•: N~m.t:.1d..!..::::!.l:ion L~veis ~.n.d Cii:.ed Reierence9. ~ .. · ... ;2u··
Soil Remediation Levels for Contaminants Lacking
Promulgated Criteria or Standards ....................... 21
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1.0 INTRO~UCTION
AMENDMENT TO THE
ENFORCEMENT RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CHEHTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY, NORTH CAROLINA
The Chemtronice Site was included on the first official National Priorities
List (NPL) published by EPA in December 1982. The Chemtronica Site haa been
the subject of a Remedial Investigation (RI) and a Feasibility Study (FS)
performed by two of the pctentially reapcnaible parties (PRPa), Chemtronica,
Inc., and Northrop Corporation, under an Administrative Order of consent dated
OCtober 1985. The third viable PRP, Hoechst Celanese Corpcration, declined to
participate in the RI/FS. The RI report, which examined air, groundwater,
soil, and surface water and sediment contamination at the Site and the routes
of exposure of these contaminants to the public and environment was accepted by
the Agency in May 1987. The FS, which develops, examines and evaluates
alternatives for remediation of the contamination found on site, was issued in
draft form to the public in February 1988.
This Record of Decision (ROD) has been prepared to summarize the remedial·
alternative selection process and to present the selected remedial alternative.
1.1 SITE LOCATION AND DESCRIPTION
The Chemtronics Site encompasses approximately 1,027 acres and is located at
180 Old Bee Tree Road in a rural area of Swannanoa, Buncombe County,
approximately 8 miles east of Asheville, North Carolina. The approximate
center of the site lies at latitude 35 degrees 38' 18" north and
longitude 82 degrees 26' 8" west. The Site ia bounded on the east by Bee Tree
Road and Bee Tree Creek. The area to the north and west of the Site is
comprised of sparsely inhabited woodlands. Immediately to the south of the
site, there are several industrial facilities which lie on land that waa once
part of the original (Oerlikon) property. The general location of the Site ia
shown in Figure 1. Figure 2 ahowa the approximate boundaries of the Site in
relationship to ita immediate surroundings.
The topcgraphy of the Site ia steep, ranging from 2,200 to 3,400 feet above
mean aea level (amel). The Site lies on the southeast aide of Bartlett
Mountair and;i:s moderate to heavily vegetated. Surrounding mountains reach
elevations ·of. approximately 3,800 feet amal. All surface water from the Site
drains into small.tributaries of Bee Tree Creek or directly into Bee Tree
Creek. Thie creek flows into the Swannanoa River which ultimately, empties
into the French Broad River.
1.2 SITE HISTORY
The property comprising the Chemtronics Site was first developed as an
industrial facility in 1952. The Site haa been owned/operated by Oerlikon Tool
and Arma Corporation of America (1952-1959), Celanese Corporation of America
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GENERAL LOCATION MAP
CHEMTRONICS, INC.
SWANNANOA, NORTH CAROLINA
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1· 13 MILES
FIGURE NO.
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SITE LOCATI SCALE 1 '2',000
CHEMTRONlgN MAP F.GUSE NO. 2
SWANNANO S, INC.
A. NORTH C AROUIA
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(Hoechst Celanese corporation) (1959-1965), Northrop Carolina, Inc. (Northrop
Corporation) '"(1965-1971), Chemtronics, Inc., as apart of Airtronics, Inc.,
(1971-1978i-6and Chemtronics, Inc. (1978 -present). The Site operated under
the name of··Aincel Propulsion, Inc. (1959-1965) under both Oerlikon and
Celanese. The Site is currently owned by Chemtronice Incorporated, a
subsidiary of the Halliburton Company:
· Wast~ ~i.sposa:1 occurrr:J civer. a Rmatl r-~•r.t.i.oD {.:1;;,pro,-~im.atel~ .. tha!!-' ·".:en acres}
of the Site. Twenty-three individual on-site disposal areas were identified
and described by reviewing existing records and through interviews with
former and current Site employees. These 23 individual disposal areas (DAB)
are grouped into 6 discrete disposal areas: DA-6, DA-7/8, DA-9, DA-10/11,
DA-23, and the Acid Pit Area. The Site can also be divided into two
geographical subsections; they will be referred to as the Front Valley and
Gregg Valley. The locations of the 23 disposal areas and the two valleys are
shown in Figure 3.
Disposal practices prior to 1971 are not well defined. From 1952 to 1971,
solid waste materials and possibly solvents were incinerated in pits dug in
the burning ground. Chemical wastes were disposed of in trenches beside this
burning ground. Waste materials generated in the production of the
incapacitating, surety agent, 3-quinuclidinyl benzilate (BZ) and the tear gas
agent, o-chlorobenzylidene malononitri_le (CS), were placed in 55 gallon,
rim-lid drums, reportedly covered with decontamination "kill" solution and
then buried on-site in trench-type landfills. These kill solutions
neutralized the BZ and CS compounds. These drums were disposed of in
disposal areas DA-6, DA-7/8, DA-9, and·DA-10/11.
From 1971-1975, moat of the liquid wastes generated on-site went to the
Buncombe County Sewer System following some form of neutralization and
equalization. Small volumee were disposed of in on-site pita/trenches.
solid wastes, rocket motors, explosive waStee, etc., were all burned in the
burning ground. From 1975-1979, Chemtronics, Inc. conetructed pits/trenches,
as needed, for the disposal of spent acid and various organic wastes. These
pita/trenches were constructed in the area that wae once the burning ground,
now referred to as the Acid Pit Area.
In 1980, the State ordered Chemtronics to discontinue all discharges to these
disposal pits/trenches. The pits have subsequently been back-filled.
consequently, in 1979, Chemtronics installed a 500,000 gallon lined lagoon
for biotreatment of waetewaters on top of an abandoned leach field for the
main production/processing building (Buildihg 113). After the lagoon was
filled, the lagoon lost its contents due to the incompatibility of the liner
with the brominated waste initially introduced into the lagoon.
Reconstruction of the biolagoon, with a different liner, was completed in
August 1980 and was in use up to 1984 at which time the biolagoon was
deactivated. Thie entire area, including the abandoned leach field and the
biolagoon, has been designated as DA-23.
The Site has been the subject of two previous Region IV, Environmental
Protection Agency {EPA) planned investigations, an investigation by the u.s.
Army and an emergency response action by Region IV, EPA. In June 1980,
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LOCATIONS OF KNOWN/SUSPEGlED DISPOSAL AREAS
GHEMTRONIGS, NC.
l!IWAP,NANOA, NORTlt CAll:JlliA
FD.IE HO.
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groundwater, surface water, sediment, and waste samples were collected for
analysis. In April 1984, private water supply wells in the vicinity of the
Site were sampled. In September 1984, the U.S. Anny Toxic and Hazardous
Materials Agency (USATHAMA) collected samples from two drums exposed at the
surface in DA-10/11. These two drums.were suspected of containing wastes
from the production of the chemical warfare agent BZ. Although no BZ was
found, in Ja~aary 1985, an immediate removal of the same two exposed drums
•.•U!2 initiat~,6 O'l ~?1'. d::.:.c to hC?ig!"~t.ar.ed i-ilblic awa.J..'l:l'ut:uu:Ji luvulve.ment with· the
Site. The drums were sampled and then transported to GSX, Pinewood facility,
south Carolina.
2.0 ENFORCEMENT ANALYSIS
The Chemtronics Site was included on the first NPL in December 1982, and EPA
assumed lead responsibility for the Site at that time. The Site has been
operated as an industrial facility since 1952. An EPA contractor completed a
PRP search in November 1983. Notice Letters were sent to the six identified
PRPs. Three of the PRPs were found to be viable and EPA initiated
negotiations with these three PRPs. Negotiations began in June 1984 and were
concluded in october 1985 with two of the PRPs, Chemtronics, Inc. and
Northrop Corporation, signing an Administrative order of Consent to perform.
an RI/FS. The third PRP, Hoechst Celanese corporation.declined to
participate in the RI/FS process.
Negotiation on a Remedial Design/Remedial Action (RD/RA) were initiated in
June 1988. Due to the inability of the three viable PRPs (Chemtronics, Inc.,
Hoechst-Celanese Corporation, and llor1:hrop Corporation), the Agency issued
the three PRPs an Unilateral Administrative Order. The effective date of the
Administrative Order was March 22, 1989.
3,0 CURRENT SITE STATUS
The Site is an active facility with the majority of manufacturing activities
occurring in the Front Valley. The property is presently being leased from
Chemtronics, Inc. by Jet Research, Inc., another subsidiary of the
Halliburton Company.
3.1 HYDROGEOLOGIC SETTING
The Chemtroni'ds Site lies within the Blue Ridge geologic province. The Blue
Ridge provinc:'e·ill predominantly composed of ancient igneous and' metamorphic
rocks. These rocks have been complexly folded and faulted in a northeasterly
direction, parallel to the regional trend of the mountains. These structural
and metamorphic imprints are reflected in the topographic and drainage
patterns within the region.
There are no known geologic faults or shear zones within two miles of the
Site, and the Brevard Fault Zone lies about seven miles south of the Site.
The Site property is underlain almost entirely by biotite gneiss.
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In the Front Valley, the bedrock topography is reflected in the surface
topography and hae a shape similar to an elongated bowl or trough. The
center of tha,-bedrock trough coincides roughly with the center of the . ' topographic v_alley and this ie where the overburden ie thickest (65 to
90 feet). Bedrock elevations increase with the surface topography and the
overburden decreases as slopes steeperl. The thickening of the overburden in
the valley is-most likely due to natural weathering processes.
In Gregg Valley, the bedrock topography is more complex and is not always
reflected by the surface topography. For example, a steep bedrock elope wae
identified in the northeastern corner of the acid pit area but is not
reflected by the surface topography. There ie alee a bedrock trough near the
middle of the acid pit area which has no surface expression. Reshaping of
the topography by man in this area ie meet likely responsible for masking
these bedrock features. Elsewhere in Gregg Valley, the bedrock topography ie
reflected by the surface topography. AB in the Front Valley, overburden in
Gregg Valley thickens in ite central and lower portions.
Groundwater recharge in this area is derived primarily from local
precipitation. Generally, .the depth of the water table depends on the
topography and rock weathering. The water table varies from the ground
surface in the valleys (streams) to more than 40 feet below the ground
surface.in sharply rising slopes.
The aquifer underlying the Site can be subdivided into" a surficial zone and a·
bedrock zone. The surficial zone refers· to the overlying saprolite and the
bedrock zone includes the weathered and· fractured region of the bedrock.
These two zones are considered one aquifer as it was demonstrated in the RI
that these zones are interconnected.
The groundwater underlying the Site has been classified as Class IIB, using
EPA Groundwater Classifications Guidelines of December 1986, since there is
potential future use for this aquifer as a source of drinking water.
Therefore, the groundwater needs to be remediated to levels protective of
public health and where appropriate, to levels protective of the environment.
3.2 SITE CONTAMINATION
The field work associated with the RI for the Chemtronice Site centered on
numerous known disposal areas on-site, eight other possible areas of
contamination on-site and three off-site areas that reportedly received waste
material from.the Site. Soil, groundwater, surface water and sediment
samples were ·collected in and around these areas and initially analyzed for
the compounds on the Hazardous Substance List (HSL) ae well ae other selected
compounds. After reviewing the analytical data from the HSL scans, indicator
parameters were.then selected to be run on subsequent samples and sampling
episodes.
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The indicator compounds selected were,
* Volatile Organic Priority Pollutants
-Ben~ene
-l,2~Dichloroethane
-Methylene chloride . ,
-Tetrachloroethene
-Tol1.:uane
-Tzichlcr~ath~na/Tric~loru~~hylaiB.
-Trihalomethanea
Bromoform
-Chloroform
* Explosives
-Picric Acid
-RDX
-TNT
* Chemical Agents
-BZ
-cs.
-and their degradative compounds
• Metals
-Chromium
-Nickel
The Agency approved the RI report in May 1987 which documented the presence
as well as the level and extent of contaminants on-site. Contamination wae
found in the following media: surface and subsurface soils, surface water and
sediment, and groundwater. In OCtober 19~7, the PlU?s reeampled 12 monitor
wells in an attempt to verify and confirm the levels and extent of
contamination in the groundwater. The analytical data indicates that, to
date, no contamination has migrated pass the Site's boundaries although
plumes of contamination in the groundwater have been found emanating from
several of the disposal areas.
3.3 AIR CONTAMINATION
The most common source of air contamination at hazardous waste sites are the
volatili:tatio.n of toxic organic chemicals and the spread of airborne
contaminated'~uat particles. During the recent RI, Site personnel used an
HNu photoionization analyzer and cyanide sensitive colorimetric indicator
tubes to monitor the air while performing the designated RI tasks. l\n action
level of 5 ppn was established in the Chemtronica Project Operations Plan
(POP) and Health & Safety Plan. This level was only attained during the
excavation of the teat pita in the d.ispoaal areas. The 5 ppm action level
was surpassed on several occasions when the HNu was placed in the teat pit or
near exposed waste material unearthed during the excavation of the teat
pita. No cyanide was detected by the colorimetric tube.
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3.4 SOIL CONTAMINATION
The study of ~he soil, surface and subsurface, occurred in two parts. The
first task encompaeeed the excavation of teat pita in the majority of the
known diepoaa_l areae and the second task ce1_1tered on the collection of
surface and subsurface soil samples f~oru borings drilled in and around the
disposal area~. These. activities not only allowed the determination of the
rl.opth:,o.f---th.e,-d.ia-p9aed 1.;aP.tes b".It alee ryrovided data to --4?.t~rmine the .flxt~nt,
vertically and horizontally, 'that the ~on'taio.inants have migrated in 'the·
soil. The three disposal areas where test pits were not excavated were in
DA-9, DA-23 and the Acid Pit Area.
3.4.1 SOIL CONTAMINATION IN THE FRONT VALLEY
The Front Valley contains two disposal areas, DA-10/11 and DA-23, where
surface and subsurface soil .samples were collected and analyzed. Below
briefly describes the contaminants present in each disposal area.
DA-10/11
Refer to the Chemtronice ROD dated April 5,. 1988.
DA-23
The analytee detected in and around DA-23 included volatile organic priority
po~lutants, explosives, cs, BZ, and their degradative products, total organic
halides, and total cyanide. The sampling locations are shown in Fi_gure 4.
'£he analytee found are listed in Table 1 along with the maximum
concentrations. Table 1 also identifies where the contaminants were found as
well as the frequency of their occurrence among both on-site and off-site
s~ples.
3.4.2 SOIL CONTAMINATION IN GREGG VALLEY
Refer to the Chemtronice ROD dated April 5, 1988.
3.5 GROUNDWATER CONTAMINATION
All monitor wells were sampled in June 198& ae part of the RI. Twelve (12)
of these wells were reeampled in October 1987 in an attempt to verify
concentrations-.
3.5.1 GROUNDWATER CONTAMINATION IN THE FRONT VALLEY
Groundwater contamination in the surficial zone of the Front Valley exists
primarily in the area downgradient of DA-23, the old leach field for Building
113 and the biolagoon. other portions of the aquifer in this valley also
appear to have been adversely affected but the source of contamination in
these areas cannot be clearly defined. In each of these locations, volatile
organic priority pollutants are present.
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I ,_.
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---.. ______ _
FIGURE NO. '-l LCCATIONS OF SlJRFACE/SUA.SllRFACE SOIL
SAMPLES IN AND ARC(JN[) 11ISEDSAL AREA 23
-------------------
I ..... .....
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TABLE NO. 1 C(fflAMINANTS ro.JND IN SOIL SAMPLES ASSCx:::IAT8D WITII DISPOSAL AA£A 23
Haxium Incation
retected of Haxium
C(JTij)Ollnd
retected
Concentration tx,tected
(m;i/Kg) Concentration
Volatile Organic Priority 1':>llutants(ll
Tolua~e · }~i?}!::J~:
Methylene chloride
1,2-Dichloroethane
Chloroform
Ethyl Ben.:ene,
tetrachloroethene
Explosivesf2)
mr
0.014
0.140
2.70
0.011
<0.01
0.6
0.5
fll\ 23-2
fll\ 23-4
DI\ 23-2
C\11 23-2
fll\ 23-2
DA'23-2
C\11 23-2
CS, BZ & Degradation Products Total Oicqanic Halides(2)
Benzylic Acid/
Benzophenone
Total Organic Halides( 2)
Total cyanide (2)
DA = Dis[)Osal Area
N/A = Not Analyzed
9.0
3.6
1.9
11.0
0.18
0.58
(1) Number of locations sarrpled
Number of samples collected
Number of samples analyzed
(2) NUJnber·of locations sampled
NUJnber of samples collected
Number of samples analyzed
[II\ 23-2
QA 23-2
C\11 23-2
C\11 23-2
fll\ 23-4
JJ/\..23-4
On-site
4
Off-site
3
4
4
On-site
1
4
4
30
17
Off-site
3
30
17
Boring
Interval
Sample
cepth (ft)
12 ( 10-12)
12 ( 45-85) u (25-27)
12 (10-12)
12 (10-12)
U (5-9)'
12 (10-12)
11 ( 5-9)
12 (10-12)
12 (10-12)
13 (15-19)
(20-22)
11 (0-2)
12 (4.5-8.5)
% of Samples Analyzed
in Which Ccrnpound
was retected
Q-i-site Off-sib3
25 0
100 100
100 29
25 0
25 0
50 N/A
75 6
25 N/A
25 24
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The highest c.9ncentratione of volatile organics in the groundwater were
detected in monitor wells downgradient of DA-23 as shown in Figure 5 and
tabulated in '·Table 2. Concentrations of 1, 2-dichloroethane range from
0.15 to 7.4 mg/L. In this area, higher concentrations of volatiles were also
detected in the deeper portion of the _aquifer, indicating downward as well as
lateral· migration of the contaminants. 1,2-Dichloroethane was also detected
.in .stream sample RW-7 (Fl.gure.5) indicating th~t thi~ compound is di~charging
with grounciw~ter ·in this vicihity int·o· the northe~n tributary-' of the· ~~~anieci ·
branch.
Lower concentrations of two other volatile organic compounds were also
detected in this area, specifically, 0.11 mg/L of chloroform in monitor well
(MW) SW-4 and 0.013 mg/L of trans-1,2-dichloroethene in MW M85L-4.
Benzylic acid, a degradative compound of BZ, was detected in MW SW-4 at
470 mg/L (Figure 6). This implies that BZ derivatives have migrated
downgradient with the groundwater from the Building 113 leach field. RDX and
picric acid were also detected in the groundwater downgradient of DA-23. A
concentration of 0.046 mg/L of RDX in MW SW-6, which is located upgradient to
DA-23, may indicate that this well is located near the abandoned tile
drainage line leading from Building 113 to the leach field or within the
upper boundary of the leach field itself. A low concentration of
bis (2-ethylhexyl) phthalate was also detected in MW SW-6 (Figure 6).
Groundwater in the vicinity of MW SW-5, _on the southwestern side of the
unnamed branch, has also been adversely affected (Figures 5 and 6).
Contaminants in this area include trichloroethane, RDX and trans
1,2-dichloroethane. According to groundwater flow patterns in the area, it
is unlikely that these contaminants are coming from DA-23 or DA-10/11. It is
feasible that these contaminants have migrated from the leach field of
B_uilding 107 (Figure 3) or are a result of. otheI'.' past activities or incidents
within the upgradient area.
Lastly, 0.17 mg/L of trichloroethene was the only contaminant detected in the
furthest downgradient MW M85L-ll (Figure 5). It is unlikely that this
contaminant originated from DA-10/11 since this contaminant was not found in
either monitor wells, SW-2 or SW-3, both of which are immediately
downgradient of DA-10/11. This is further supported by the fact that no
trichloroethene contamination was detected in any of the soil borings samples
collected from this area. The absence of trichloroethene in groundwater
downgradient of DA-23 indicates that the s9urce of trichloroethane in
MW M85L-ll is not DA-23 and is therefore, most likely due to some other past
activity or incident.
In summary, the extent of the groundwater contamination in the surficial zone
in the Front Valley ie greatest downgradient of DA-23. The majority of
contaminants from this area are migrating with the groundwater and
discharging locally into a northern .tributary of the unnamed branch.
Groundwater contamination in other areas within the valley are most likely
due to the presence of other old leach fields (such as that of Building 107)
or other past activities. Finally, given that no contaminants were detected
in groundwater samples collected from wells downgradient of DA-10/11 during
the RI and only methylene chloride at 0.007 mg/Lin the October 1987 sampling
episode, it appears that contaminants have not moved from this area.
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0
•
LEGEND
Existing Monitor Well
Newly Installed Surficial Well
Newly Installed Bedrock Well
RI -Samples Collected Between January+ September 1986
10/87 -Additional Samples Collected in October 1987
SCALE IN FEET
F.IGURE NJ. 5 LOCATIONS AND CONCENTRATIONS Of VOU\TILE CONTAMINANTS ASSOCIATED WITH DISPJSAL AREA 23 FDUND IN THE GROUNDWATER IN THE FRONT VALLEY
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- - - ----- -- ------ - -
Yolatl h, Exp1oJ1VtS CSl6l Produgta
1k I 1 Type
Upgr1dlent
SW 6 Sh> I I ow <0.01 . 0.012 o.oq6 -. + • NA. • 6.12
BW 3 Dedroclc <0.01 • HA· 6.Jo
11Qungradlcnt
SW • ~ho II ow 2. 1 0.11 <0,01 0.059 -1.5 0,01 00 6 .• 5
IU I lnteraedlat~ 0.5• <0,01 NA 6.0I
BU • Rt:droc\l.
"w 5 Btdrock
0.53 , (0.01 -0.01 ' o.o-;• ♦ o. qoo 6.60
0. 15 <0.01 + 1.0 8.o~
IIW 6 8r-drock <0.01 <0.01 -<0.01 -<0.01 0.01 • NA 6.53
BW I] B~-drock (0.01 (0,01 <O,O'IO 1.15
H85Lq £id,tln11
H85L Io £•1,tlng
HB5LI I h I tl Int
o. 15 <0,01 -<0,01 -• NA • 6.H
1.• <0.2 <0.2 <0.2 0,023 • 1.2 • 6 ,16
O. ITO -• NA 6 •• ,
-• not tfot•ot.ed • • qu.allfle-d data
HA ; not analyted
( I) llulober or wilt In thl• Area: 11
{2) PhUwlate oonce-ntrat1ons are a:uueed to be the re.sult or contact bet~e-n groundwater and phthalate•cont.atnh:ig nattrhlt during .;,.,.JlJ tn,tallatlooa or
h.lH)dltua and an.aly.sl!t In the laboratory.
(3) Contaminant Levels Measured in mg/L (parts per million)
TABLE NO. l (X)NT/\MINANTS FOUND TN Tilf:: GROUNJNI/\TER TN Tfm VICINI'rY OF
D[SPOSAL AREA 23
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FIGURE NO-6
0
•
LEGEND
Existing Monitor Well
Newly Installed Surficial Well
Newly Installed Bedrock Well
RI -Samples Collected Between
January+ September 1986
-Additional Samples Collected
in October 1987
SCALE IN FEET
u:x:ATICNS AND CONCENTRATIONS OF NON-VOu\TILE CONTAMINANTS
ASSOCIATED WITil DISFOSAL AREA 23 FOUND IN TilE GROUNDvlATER
IN THE FRONT VALLEY
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The bedrock zone of the aquifer in the Front Valley contains three
contaminants., ... _ 1, 2-dichloroethane, bis ( 2-ethylhexyl) phthalate, and
chloroform •. :i;'The extent of this contamination ia in the vicinity of two
wells, BW-4 and BW-5 (Figure 5 and 6). The contaminant detected in MW BW-5
was 1,2-dichiOroethane at a concentraticn of 0.15 mg/L. The source of thie
contaminant c9uld be DA-23 in that this well ia hydraulically downgradient
• fro;n: this disp-:,sf.J. ~oa. An aear.:1tiall~ ',1c"':'i.;:.011t-:j,l frac-t:.!u·e in the bed.c:>c1:
waa detected in MW BW-4 that could provide a pathway for this compound. Thia
would explain the appearance of this contaminant in of MW BW-5 but not in
MW SW-5, which was completed in the surficial zone.
Three contaminants were detected in MW BW-4: 1,2-dichloroethane,
bia ( 2-ethylhexyl) phthalate, and chloroform. While the low concentration o'f
bia (2-ethylhexyl) phthalate is likely the result of sample contamination,
the presence of 1,2-dichloroethane and chloroform can be directly related to
waste disposal in DA-23.
In summary, the only area of the bedrock zone affected by disposal activities
in the Front Valley appears to be primarily in the vicinity of wells BW-4 and
BW-5. Thia leads to the conclusion that the contamination of the bedrock
zone of the aquifer in this valley is of limited extent and haa migrated leas
than 800 feet from areas of waste disposal as evident by the absence of
contaminants in wells BW-6 and intermediate monitor well tl (IW-1).
3.5.2 GROUNDWATER CONTAMINATION IN GREGG VALLEY
Refer to the Chemtronica ROD dated April 5, 1988.
3.6 SURFACE WATER AND SEDIMENT CONTAMINA~ION
Refer to the Chemtronica ROD dated Aprils, 1988.
3 . 7 RECEPTORS
There haa been no change in the identified receptors between now and the
April 5, 1988 Chemtronica ROD.
The routes of exposure examined in the Risk Assessment were:
1) ingee:t·ton of contaminated groundwater, surface water and wild life;
2) direc~:i:.:Contact with the contaminants in th0 soil, surface waters or
groundwater; and
3) inhalation of vapors or contaminated particles.
The aquifer under the Chemtronica Site ia classified aa Claaa IIB, a
potential source of drinking water, .using the USEPA Groundwater
Claaaificatl.ona Guidelines of December 1986. Although the site aquifer is
not currently used for drinking water purpoeee, potential (future) uee was
incorporated in the baseline risk assessment. consideration of potential
groundwater use ia consistent with 40 CFR Section 300.68(e)(2)(v).
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Groundwater, as noted, is contaminated on-site~ The general flow of
groundwater ie to the east and west to the unnamed stream and Gregg Branch
and east to .. Bee Tree Creek, discharging to these surface water features.
Groundwater contamination was particularly noted downgradient of the Acid Pit
Area and DA-23·. No drinking water wells exist between the site and the
groundwater discharge points, thus a pathway via domestic well usage does not
exist ..
currently, fugitive dust particle generation is considered an unlikely
event. The majority of the disposal areas are capped by dirt and are
vegetated. One area, although vegetated, has numerous empty drums exposed at
ground level. Thia area, DA-9, was identified in the RI to have the greatest
degree of risk to exposure to the contaminants present. The chance of
exposure is greatly reduced to the remoteness of this disposal area.
contaminated soils will continue to leach to surrounding soils and
groundwater.
Surface runoff from surface sails may contaminate additional soils and
surface waters and sediments, although concentrations would not be expected
to be high.
4.0 CIJ'lANUP CRITERIA
There has been no change in the cleanup goals between now and the
April 5, 1988 Chemtronics ROD.
The extent of contamination was defined in Section 3.0, Current Site Statue.
This section examines the "applicable and relevant or appropriate
regulations" (ARARs) associated with the contaminants found on site and the
e_nvironmental medium contaminated. In thu cases where no specific AR.AR can
be identified, a defendable minimum goal of remedial action will be
presented.
4.1 GROUNDWATER REMEDIATION
In determining the degree of groundwater clean-up, Section 12l(d) of the
Superfund Amendment and Reauthorization Act of 1986 (SARA) requires that the
selected remedial action(s) establish a level or standard of control which
complies with all ARARs.
This remedy i1,1,.a cost-effective remedy which will achieve a level protective
of human heal~h as will as remove the threats this Site poses to the
environment. The remedy will meet appropriate requirements, and is
coat-effective.· Finally, the remedy utilizes permanent treatment
technologies to the maximum extent practicable.
The presence of several contaminated found on Site presented some special
problems with respect to the establishment of target cleanup levels. Since
these chemicals either lack or have only limited human health standards and
supporting physiochemical and toxicological data, it was necessary to develop
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preliminary pollutant limit values (PPLVs) for critical exposure
pathways, using estimates of acceptable daily doses (OT) and
partition coefficients, The calculations and supporting references
for these PPLVs are presented in Appendix A of the Feasibility Study.
For those contaminants found in the gxoundwater on-site Table 3
presents the levels the migration control remedial alternative will
ach.:.evJ at a,•minimw.::.
4.2 SOIL REMEDIATION
The Public Health ~nd Environmental Assessment in the RI (Chapter 4),
determined that risks to human as a result of exposure to on-site
contaminants via inhalation, ingestion and dermal contact are very
low under present Site conditions. For potential future use
scenarios, the risk is slightly higher. Therefore, remediation and
institutional controls will be necessary to assure that an increased
risk to human health is not posed in the future.
Table 4 presents remediation levels the source control remedial
alternative will achieve. This includes PPLVs for these contaminants
lacking promulgated criteria or standards.
4.3 SURFACE WATER/SEDIMENT REMEDIATION
The contaminant levels in the surface waters (the unnamed stream and
Gregg Branch) are expected to decline with the implementation of
groundwater and soil remediation. Thus, it was concluded that the
remediation of surface water is not necessary~ A biomonitoring
program will be implemented to document that the.remediation
activities do not have an adverse affect On the surface waters. The
RI did not identify any contaminants entering Bee Tree Creek from the
Site.
5.0 ALTERNATIVES EVALUATED
Refer to the Chemtronics ROD dated April 5, 1988.
5.1 MODIFICATION OF APRIL 5, 1988 RECORD OF DECISION REMEDIAL
ALTERNATIVE FOR DISPOSAL AREA 23
Based on a correction of analytical data with regard to the chemical
quality of the groundwater downgradient of DA-23 in the Front Valley,
it has been deerited necessary to change the source control remedy
selected for DA-23. The mandate to addrese poet-ROD changes is
provided by cornpreheneive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) Sll7(c), which states:
"After adoption of a final remedial action plan
(1) if any remedial.action is taken {under
sectione 104 or 120), {2) if any enforcement
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action under section 106 is taken, or (3) if any
settlement or consent decree under section 106 or
section 122 is entered into, and if such action,
settlement or decree differs in any significant
respects from the final plan, the lead agency
· shall publish an explan~tion of the significant
differences and the reasons such changes were
.-made.~
5.1.1 CHANGE IN THE RECORD OF DECISION
The remedial action selected in the Chemtronics April 5, 1988 ROD for the
contaminants and contaminated soils associated with DA-23 was a soil
fixation/stabilization/solidification (f/a/a) process followed by capping the
entire disposal area. The f/s/s alternative was selected due to the
concentration level of the non-yolatile organic contaminant benzylic acid and
benzophenone found in the groundwater downgradient of DA-23. The Remedial
Investigation Report, dated April 1987, stated that the concentration for
benzylic acid/benzophenone in the groundwater downgradient of DA-23 in
monitor well (MW) SW-4 as 470 milligram/liter (mg/1). Thia concentration is
equivalent to 470 parts per million (ppm). MW SW-4 is a shallow monitor well
and 470 mg/1 is a relatively high concentration for a contaminant in
groundwater.
In October 1987, approximately one year .after the original sampling episode,
nine ( 9) monitor wells were re sampled.·. MW SW-4 was one of these wells. The
analytical results for benzylic acid/benzophenone for SW-4 was 1.2 mg/1,
which is considerably leas than the 470 mg/1 level recorded in the initial
sampling episode. The concentration level of 1.2 mg/1 is more in line with
the levels found in other wells downgradient of DA-23 as can be seen in
Appendix A.
It was the Agency's rationale, baaed on the level of 470 mg/1, that the
concentration of benzylic acid/benzophenone in the soils of DA-23, the source
of this contaminant, must also be relatively high, therefore requiring a more
rigorous source control remedial action. Thia thought process led the Agency
to select a soil f/a/a process as the source control remediation for DA-23.
The f/s/s alternative was selected over soil venting or capping due to the
fact that the contaminant of concern, benzylic acid/benzophenone, is not
readily volatilized. Although soil venting would help remove the volatile
organics from the soil, it would not remove the non-volatile organics.
Usually, it is the non-volatile organics that determine the length of time
necessary to pump and treat the groundwater as non-volatile organics do not
readily move with groundwater through the soil as do volatile organics. Soil
venting ~ould help reduce the levels of volatile organics, but it does not
address the non-volatile fraction of contaminants and therefore, soil venting
was not selected ao the new source.control remedial action for DA-23.
Due to the lower level of benzylic acid/benzophenone than first identified as
being present in the groundwater downgradient of DA-23, and the fact that a
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TABLE NO. 3 GROUNI:WATER REMEDIATION LEVELS AND CITED REFERENCES
1, 2-Dichlo:roe:t:hane
Trichloroethylene
Methylene atloride
Tran.5-1,2-Dichloroethylene
Benzene
atlorofo:cn
Ethyll:.enzene
Tet:rachloroethylene
Brt::m:lf orm
carbon Tetrachloride
Toluene
Piede J\cid
ROX
'lNI'
Total cyanides
Lead
Olranium
Nic::lcel
O::>pper
Zinc
Eenzilic J\cid
Eenzq:henone
Reined i atian I.evel ___ '!lB/1 ___ _
0.005
0.005
0.06
0.07
0.005
0.1
0.68
0.007
0.1
0.005
2.0
. 14.0
0.035
0.044
0.200
0.05
0.05
o.5
1
5
0.021
0.152
MCL -Maximum .Contaminant lsvel.
&m.--ce
MCL
MCL
RSD
.J:M:I.G
MCL
MCL(TlllM)
J:M:I.G
RSD
MCL(TlllM)
MCL
B1CLG
PPLV
~
PPLV
RfD
MCL
MCL
RfD
MCL
w;::,:::
PPLV
PPLV
Mc:L{TrnM) -'!he MCL for Total Trihalarethanes (sum of all a:incen-
PPLV
RfD
RSD
Fran TIN
t:rations) is 0.1 =.IL TIHM's include chlorofom,
bro:t0fo:an, brcm::clichlo~, ard chlorodibrc:m:)-
:rrethane.
-l?rq;:osed MaXimJm Contaminant Iellel Goal 50 FR 46936-47022
(November 13, 1985) •
-~:iminary E<:,llutant Limit Value (see~ A).
-Rsference D:lse 52 FR 29992-29997 (August 12, 1987).
-Risk Specific D:,se, 51 FR 21648-21693.
-US Arey Water Q.lality Criteria. 'lhe given values have
been a.:proved by the Arey Su:cgeon General.
-Clean Water Act, Water Quality Criteria for Hutran Health
-Adjusted for Drinking Water Only, [Gold B::ck}.
-Calq11ated from a 'Ihre:shold Limit Value, based on a' 70 Kg;
person who drinks 2 liters of water per day. A safety
factor of 100 has also been a,:plied.
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TABLE NO. ·· 4 SOIL REMEDIATICN LEVELS FOR COITTAMINANTS LACKING
PRCMULGATED CRITERIA OR STANDARDS
Contaminant Group
FCBs
3--Quinuclidinol
Benzilic Acid
Benzophenone
CS ( 2--C,lorobenzal-
malononi tri le)
Malononitrile
0-Chlorobenzaldehyde
TNT
RDX
,
Soil Standard (ng/Kg)
10
25.7
9.3
9.3
43.3
N/A+
0.31
305
95
Source
TSCA
. PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
Picrate/Picric Acid PPLV 38,000
+ -Malononitrile would not persist in soil based upon Ka partition
coefficient
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aoil venting alternative would not decrease the time needed to remediate
DA-23, the Agency selected as the preferred source control remedial
alternative~f9r DA-23 to place a multi-layer cap, which includes a synthetic
liner, over-this disposal area instead of implementing a f/s/s process to
remediate the,contaminated soils of DA-23. The multi-layer cap will meet as
a minimum, the requirements specified'under 40 CFR Subsection 264, Subparts
K-N. A gas collection system will also be incorporated into the cap if
G~e.med ns~d~aary~
5.1.3 DOCUMENTATION OF A TRANSCRIPTION ERROR
In a letter dated September 19, 1988 (Appendix B), the PRPs informed the
Agency of a possible transcription error made by the laboratory contracted by
the PRPs to perform their analytical analyses. Instead of reporting the
detected concentration as 470 micrograms/liter (ug/1) or 470 parts per
billion (ppb) as they should had done, the laboratory reported the
concentration as 470 mg/1 or 470 ppm. Misplacing the decimal point by three
(3) places resulted in a change of concentration by a magnitude of three (3).
This information and the documentation to support the reported transcription
error was transmitted to EPA, Region IV Chief of the Quality Assurance and
Laboratory Evaluation Section (QALES) of the Environmental Services
Division; After reviewing the documentation, QALES concurs that a
transcription error had occurred (Appendix C).
5.1.4 CONFIRMATION OF GROUNDWATER QUALITY
Prior to making a final decision on whether to change the selected source
control remedy for DA-23, the Agency resampled MW SW-4 the first week of
January 1989. The analytical results for-·the January 1989 sample are 48 ug/1
for benzylic acid and 3400 ug/1 for benzophenone. These results confirm the
lower concentration range of 0.0 to 470 ug/1 and not concentrations in the
hundreds of parts per million. Therefore, the Agency elected to change the
source control remedial alternative for DA-23 from soil f/s/s to capping.
The cleanup goal, as specified in Table 3, for benzylic acid and benzophenone
are the same as stated in the April 5, 1988 ROD. The goals for benzylic acid
and benzophenone are 21 ug/l and 152 ug/1, respectively.
Capping DA-23 will be as protective as would have been a soil f/s/s process
of human health and the environment. This ls based of the findings that the
exposure pathways for the contaminants found at DA-23 are consumption of
contaminatad:,gtoundwater and discharge of contaminated groundwater to surface
streams. These findings are documented in the Public Health and
Environmental Assessment section of the Remedial Investigation report and the
Endangerment Assessment incorporated into the Feasibility Study document.
Both of these pathways are mitigated by the groundwater extraction/treatment
system required for the Front Valley· under the Migration control section of
the ROD. Therefore, in terms of protecting the public health and the
environment, capping DA-23 and pumping and treating the groundwater in the
Front Valley of the Chemtronics site achieves the same degree of protection
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as the soil f/e/e process. Aa documented in the Feasibility study, capping
is the more coat effective remedial action. The North Carolina Department of
Human Resources has been apprised and is in complete agreement with the
Agency's proposal.
In addition to meeting the requirement df Superfund, being coat effective and
protecting public health and the environment, capping DA-23 will also satisfy
the post: '-.:loBUre· require.ne:nt.E. imposed upon t:he ow:.-;.£,.,:/u~r.1;~,;r of t;,-n facility
by the Resource, Conservation & Recovery Act (RCRA) programs of the Agency
and North Carolina Department of Human Resources. The RCRA programs are
involved with DA-23 because the biolagoon was operated poat-1980.
Under RCRA, when a business or individual stops operating a solid waste
management unit (SMU), the SMU needs to be closed out according RCRA
regulations. Capping DA-23 and pumping and treating the groundwater will
meet RCRA'e requirements.
5.2 NINE POINT EVALUATION CRITERIA FOR EVALUATING REMEDIAL ACTION
ALTERNATIVES
Each alternative was evaluated using a number of evaluation factors. The
regulatory basis for these factors cornea from the National Contingency Plan::
(NCP) and Section 121 of SARA. Section 12l(b)(l) states that, "Remedial
actions in which treatment which permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances, pollutants and·
contaminants as a principal element, are to be preferred over remedial
acti.ona involving such treatment. The offsite transport and disposal of
hazardous substances or contaminated materials without such treatment should
be the least favored alternative remedial action where practicable treatment
technologies are available."
Section 121 of SARA also requires that the selected remedy be protective of
human health and the environment, cost-effective and use permanent solutions
and alternative treatment technologies or resource recovery techn9logies to
the maximum extent practicable.
Baaed on the statutory language and current U.S. EPA guidance, the nine
criteria used to evaluate the remedial alternatives listed above were:
1. overall Protection of Human Health and the Environment addresses
whether or not the remedy providee·adequate protection and describes
how rieka are eliminated, reduced or controlled through treatment,
engi·n~,iering controls, or institutional controls.
2. Compliance with ARARa addressee whether or not the remedy will meet
all of the applicable or relevant and appropriate requirements of
other environmental statues and/or provide grounds for invoking a
wavier.
3. Long Term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
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4. Reduction of toxicity, mobility, or volume is the anticipated
performance of the treatment technologies a remedy may employ.
5. Short~term effectiveness involves the period of time needed to
achieve protection and any adverse impacts on human health and the
environment that may be posed•dUring the construction and
implementation periods until cleanup goals are achieved.
6. Implementability is the technical and administrative feasibility of a
remedy inc.luding the availability of goods and services needed to
implement the chosen solution.
Cost includes capital and operation and maintenance costs.
8. Support Agency Acceptance indicates whether, based on its review of
the RI/FS and Proposed Plan, the support agency (IDEM) concurs,
opposes, or has no comment on the preferred alternative.
9. Community Acceptance indicates the public support of a given remedy.
This criteria is discussed in the Responsiveness Summary.
5.2.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The change in the selected remedial action for DA-23 will be as protective as
a f/a/a process. The primary route of exposure identified for DA-23 was
exposure to contaminated soils and ingestion of contaminated groundwater
emanating from the disposal area. The multi-layer cap will.prevent
percolation of rain through the contaminated soils and recharging the
underlying groundwater with the resulting leachate. Coupled with the
migration control remedial action, pump and treat groundwater, these two
remedial actions will adequately protect fiuman health and the environment.
5.2.2 COMPLIANCE WITH ARARS
Thia modification to the April 5, 1988 ROD does not trigger any new Federal
and State applicable or relevant and appropriate requirements.
5.2.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
Thia modification to the source control remedial action for DA-23 does not
greatly impact the long-term effectiveness and permanence of the
remediation. The multi-cap will decrease the contaminant's mobility as well
as the risk of direct contact.
5.2.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
The multi-layer cap will reduce the mobility of the contaminants and the
volume of contaminated groundwater but does not address the toxicity of the
contaminants.
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5.2.5 SHORT-TERM EFFECTIVENESS
During the construction of the multi-layer cap, dust release may occur.
5.2.6 IMPLEMENTABILITY
There .ohould.--be ?l".> difficulty with. .the ~.ei=ri~n an~ conBtr1~--t~.on of· a .suit;,ib!.o
multi-layer cap.
5.2.7 COST
Capital cost for groundwater remediation is estimated to be $239,000 with
system O&M coat at $139,500 for 30 years, which includes sampling and
analysis. The total present worth cost of the groundwater remediation is
$378,500.
Capping disposal areas DA-6, DA-7/8, DA-9, DA-10/11, DA-23, and the Acid Pit
Area with a multi-layered cap ia estimated to be $1,350,000. The O&M coats
for all caps is $362,400. The above costs include engineering, overhead,
profit~ contingency, and administrative fees. The total oresent worth coat
ia $1,870,400.
The present worth cost of this remedy, including both source and migration
control remediation is approximately $2 ,.248, 900.
5.2.8 STATE ACCEPTANCE
The North Carolina Department of Human Resources has been apprised and is in
c_omplete agreement with the Agency's proposal and since it is expected that
the RD/RA will be undertaken by the PRPa, there has been no request made
under CERCLA, Section 104(c) for the State to contribute ten percent of all
costs for the remedial action.
5.2.9 COMMUNITY ACCEPTANCE
Explanation of Significant Difference Fact Sheets were sent to all those on
the Chemtronica mailing list including the four information repositories. A
legal public. notice announcing the propcaed amendment to the April 5, 1988
ROD was alao,;published in the Asheville Timers/Citizen Newspaper. These were
the two mech,ajlisms employed to notified interested parties, residents, media,
and local andistate officials of the Agency's intention to amend the. April 5,
1988 ROD. In these announcements, the Agency also made it known that the
Agency would conduct public meeting in there was interest in the local
community.
The Explanation of Significant Difference/Propcaed Plan Fact Sheet described,
in detail, the justification for amending the ROD. The legal notice briefly
described the Agency's justification. Both announced that there was a three
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week public colillllent period associated with the proposed amendment to the ROD
and encouraged the public to submit written comments to the Agency. The
comment period ended March 21. Only one comment was received during this
time frame. 'This letter dealt with several other issues surrounding the
Chemtronics site and not the proposed amendment to the Aprils, 1988 ROD.
S.O RECOMM~MDEO ALTE~~AT!V!::S
6.1 DESCRIPTION OF RECOMMENDED REMEDY
The recommended alternative for remediation of groundwater and soil
contamination at the Chemtronica Site includes extraction, treatment and
discharge of groundwater and capping contaminated soils. The capped areas
will be fenced with a chain-linked fence and marked accordingly.
The water and sediment in the pond on the unnamed stream will be sampled. If
evidence of contamination is present, the pond will be drained with the water
being sent through the treatment system set up for treating groundwater and
the sediment will be transported to another disposal area and capped along
with that disposal area.
A monitoring program, employing bioass·ays, will be established for the
surface water. Monitoring locations will be located on the unnamed stream,
Gregg Branch and Bee Tree creek. The purpose of this monitoring program is
l) to insure no adverse impact on these streams during implementation of the
remedial action and 2) to establish a data base to use to measure the success
of the remedial action implemented.
Soila in disposal areas DA-6, DA-7/B, DA-9, DA-10/11, DA-23, and the Acid Pit
l\rea will be capped with a multi-layered cap which will include an inert
synthetic liner. Where determined necessary, a venting system will also be
installed.
A groundwater extraction system will be installed in both the Front Valley
and in Gregg Valley. The extracted groundwater will either be treated in
each valley or combined and treated through a single system. The treated
groundwater will be discharged meeting all ARARs.
These recommended alternatives meet the requirements of the NCP, 40 CFR
Section 300,68(j) and SARA. Thia recommended remedy permanently and
significantl:f reduces the volume of hazardous substances in the groundwater,
reduces' the•-t.o~icity and/or mobility of contaminants in the soils.
6.2 OPERATIONS AND MAINTENANCE
When the remedy is completed, long-term operation and maintenance (O&M) will
be required for the caps along with long-term monitoring of the groundwater,
Thia will assure the effectiveness and permanence of the source control
remediation and groundwater remedies. Long-term O&M will also be required
for monitoring the groundwater extraction systems and the groundwater
treatment ayatem(s).
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6.3 COST OF RECOMMENDED ALTERNATIVE
Capital coet,. !,or groundwater remediation ie estimated to be $239,000 with
system o&M·coet at $139,500 for 30 years, which includes sampling and
analysis. The total present worth coat of the groundwater remediation is
$378,500.
Cappias-: :.iL:-.:..pCisal areaa I:P.-6, D.:'..-·7/":-, DJl..c .'), DA;-_lC/11, DA-23, and tl·~..::. :.cid Pit
Area with a multi-layered cap is estimated to be $1,350,000. The O&M coate
for all caps is $362,400. The above costs include engineering, overhead,
profit, contingency, and ·administrative fees. The total oreaent worth cost
la $1,870,400.
The present worth cost of this remedy, including both source and migration
control remediation is approximately $2,248,900.
6.4 SCHEDULE
The planned schedule for remedial activities at the Chemtronics Site is
expected to be governed by a Consent Decree to be signed by the PRPa, but
tentatively is as follows:
6.5
April 1988 -Approve Record of Decision
April 1989 -Amend April 5, 1988 ROD
May 1989 -Begin Remedial Design
OCtober 1989 -Complete Remedial Design and Mobilize
FUTURE ACTIONS
Following completion of remedial activiti·es, long-term groundwater monitoring
will be required to assure effectiveness of the groundwater cleanup and
source control remediation. Maintenance of the caps on disposal areas DA-6,
DA-7/8, DA-9, DA-10/11, DA-23, and the Acid Pit Area. Action levels for
contaminants in the groundwater will be set with the State of North
Carolina's concurrence. If these levels are reached during any sampling
episode after the remedial activities achieve goal, this will trigger an
immediate permanent remediation of the disposal area responsible for this
level of contamination is reached downgradient of that disposal area. The
action levels expected to be implemented are MCLa and PPLVa.
6.6 CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Refer to the Chemtronics ROD dated April 5, 1988.
7.0 COMMUNITY RELATIONS
Refer to the Chemtronica ROD dated April 5, 1988 for summarization of
previous community relations activities.
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Explanation of Significant Difference Fact Sheets (Appendix D) were sent to
all those on .. the Chemtronics mailing list including the four information
repositorieea:,C A legal public notice (Appendix E) announcing the proposed
amendment to'\the April 5, 1988 ROD was also published in the Asheville
Timers/Citizii,ii Newspaper. These were the two mechanisms employed to notified
interested parties, residents, media,~ a1id local and state officials of the
Agency's intention to amend the April 5, 1988 ROD. In· these announcements,
t~u A';jency a-rec ,ma'J.e it l::ncw.: tha-= -=he Aqc:::::y would conduct ·t,1-..i!:.i.ic meeting-Li
there was interest in the local community.
The Explanation of Significant Difference/Proposed Plan Fact Sheet described,
in detail, the justification for amending the ROD. The legal notice briefly
described the Agency's justification. Both announced that there was a three
week public comment period associated with the ·proposed amendment to the ROD
and encouraged the public to submit written comments to the Agency. The
comment period ended March 21. Only one comment was received during this
time frame. This comment· and the Agency's response can be found in
Appendix F.
The four information repositories are located at:
Buncombe County Emergency Services
P.O. Box 7601
Asheville, NC 28807
Contact: Mr. Jerry VeHaun
Chemtronics Site Information Bureau
70 Woodfin Place
Asheville, NC 28814
University of North Carolina at Asheville
One University Heights
Asheville, NC 28804-3299
Contact: Dr. Gary Miller
Warren Wilson College Library
Warren Wilson College
701 Warren Wilson College Road
Swannanoa, NC 28778
Contact: Ms. Laura Temple-Haney
The Administrative Record is located at Warren Wilson College's library.
8.0 STATE INVOLVEMENT
The North Carolina Department of Human Resources has been apprised and is in
complete agreement with the Agency's proposal and since it is expected that
the RD/RA will be undertaken by the PRPs, there has been no request made
under CERCLA, Section 104(c) for the State to contribute ten percent of all
coats for the remedial action.
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APPENDIX A
source --Table 8 from the Chemtronics Superfund site
Record ·of Decision Signed April 5, 1988
Contaminants Found in the Groundwater
in the Vicinity of Disposal Area 23
---- ---------- --.. -
. :1
Yolatlles E,iploslvn Metals CSIBZ Produgta
.. l I ? s ., d' l' .. l,r l
Upgradlent
s~ 6
BW 3
SW,
]~ 1
BW ,
HW 5 aw 6
BW l3
H85Lq
H65Ll0
· K85Ll I
Type
Sho II ow
lle,:lrock
3ho ]low
lnttraedLate
Bedrock
Bedrock
Bed roe I<
Bedrock
Eid st lng
hl>t!ng
Ewt!Ung
-• not det•oUld
• • qu.allfled dat1
KA i not analyzed
... ..: ti ...... ,;;
2. 1
0.5J o. 15
<0.01
o. 15 1.,
( t) "11iber or 1,1111la In tl\h Area: 11
&-~ ~ .:-
<0.01
,0.01
<0.01
,0.2
0.170
,<; .. ~ i: e fj S-!' ~ ;, '1 ti (S .,.
<0.01 •
0.11
0.03
. ,0.01 .
<0.01 <0,01 -<0.01 .
<0.2 <0.2 .
,. ... • :.: .5
0.012
<O.Ol
<0.01
o.o-;,
< o. 01
<0.01
•
,o. Olio
. ·t ··1;. I' ~· ....
" be I ,._u
-.,b ;;, .. ~ .: ,f ,:, " Q ,I' • ..,# o< g, ""' " ~ .. (,;; \ "'(., l .... ~ ...
9' {; :,-. :, i"~ ~ t "' ..... (S ~~ ,._o ~~.:, o..c,
0.016 • • • n • 6.12 • t.1A 6.30
0.059 • 1.5 0.01 1/iO 6.,5
0.5, ,0.01 . ►.:;1 6.01
• o,qoo 6.60
• 1.0 6.o•
0.01 I )IA 6 .53
7_q5
I t!A I 6.•2
0.023 • i .2 • 6.16
I 114 6.,1
(2} Phthulate ooocentratlons are a:,ataed to be the result or contact between groundwater and phthalate-cont.alnlng uterl1h durln1; well ln.stallatlcn1 or
hand) lflll and ■n.alysls 1n the laboratory.
(3) Contaminant Levels Measured in mg/L (parts per million)
TABLE NO, 8 CONTAMINAITTS FOUND IN TilE GROUNfl-lATER IN THE VICINITY OF
DISPOSAL AREA 23
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APPENDIX B
source --Letter (with enclosures) from
Chemtronica, Inc. dated September 19, 1988
,,,,~ .~-a:-1 ~::.
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CHEMTRONICS, INC.
J.~ _Old See Tree Road • SwannMoa, NC 28778 • [phone]
Mr. Jon K. Bornholm
Superfund Project Manager
u.s. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
Reference: Chemtronics Superfund Site RI Report of April 1987
Dear Jon:·
ERRS
£PA -l!EGIOH IV
ATLANTA, GA.
It has come to the attention of the PRP's at the Chemtronics Superfund Site
that there exists a data error in the RI report that was accepted by EPA in Apdl
of 1987.
The data ;;,:,int of concern related to the water analysis on $W-4 in regards
to the arrount of Benzylic Acid and Benzephenone found in that saaple. The
certificate of analysis presented during the RI and used in generating data
tables reported a quantity of 470 ITT;1/liter or parts per million. In reality the
actual .result was 470 fig/liter or parts per billion. '
According to IT Corporation, the analytical service used during the RI, the
error was due to the failure to convert to,. g/liter prior to transcription to the
raw data work.sheet. Attached for your information are tWQ letters received frcm
IT along with their file data on the analysis plus a corrected Certificate of
Analysis.
We
reflect
the methodology for correction of the record to
during the RI.versus those reported in error.
r/2~
John F. Schultheis
PRP Coordinator
JFS:wr
CC: Or. Gary Serio -Northrop
Tony Young -Piper & Marbury
Charles Case -Moore & Van Allen
C)>. Halliburton Company
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t]] INTERNATIONAL
TECHNOLOGY
CORPORATION
September l~;-1988
; : .
Mr. John Schultheis
Chemt ron i cs, Inc.
180 Old Bee Tree Road
Swannanoa, NC 28778
Oear Mr. Schultheis,
. ,,
As .per a request from Jim Cloonan of Sirrine Environmental, the benzylic acid
result for sample SW-4, original]y reported. to Metcalf & Eddy on July 18, 1986,
was re-checked. It was discovered that the result was actually 470 µg/L (ppb)
rather than the 470 mg/L (ppm) as originally reported. As such, a corrected
Certificate of Analysis has been issued to Chemtronics (see enclosure).
Please feel free to ·contact me with any questions or problems.
'
R ,,!1-Vr
Op ations Manager
RW:sm
Enclosure
Reg1onol Olllce
5815 Middlebrook Pil<e. Knoxv,lle. Tennessee 37921 • 615-588-640I
.. .,:ia -... , :1
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rn INTUHATIONAL TECHNOLOGY CORPORATION·
ANALYTICAL
SERVICES
.. 5815 Middlebrook Pike• Knoxville, Tennessee 37921 • 615·588-6401
CERTIFICATE OF ANALYSIS ' ,
re,: Che::-r.trc11ics:;~· Inr:,. LlATE REPORTED: September 14, 1988 ..
ATTN: John Schultheis
180 Old Bee Tree Road
Swannanoa, NC 28778
PROJECT CODE MEOW 22466-Corrected Cert ifi c
ORDER NUMBER: S-58D8
PAGE l 4 OF ~1,..4,.__
Sample Description: SW-4 (X8598) (Water}
CS, BZ, AND DEGRADATION PRODUCTS ANALYSIS
Concentration(l),
Compound
cs
o-Chlorobenzaldehyde
BZ
Benzylic Acid/Benzophenone(2)
(mg/liter)
NO
NO
NO
0.47
Remarks: 0.010 = Quant1tat1on Limit(3)
ND= Not detected
( l)
(2)
( 3}
The concentration fs based on peak heights with a response factor of 1.00 relative to
the nearest non~fnterfered internal standar-0 •
. ·:.;Zi'.·
Benzilic Act~jllgrades to Benzophenone. Quantitation 1s based on both compounds.
,--::~'.-*
The quantitatfon limit is 101 of inte,rnal standard i;oncentration 1n extract as
analyzed. The l1m1t given ls with respect to the sample.
Date of Extraction: 6/9/86
Date of Analysis: 6/25/86
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rn INTERNATIONAL
TECHNOLOGY
CORPORATION
September 1§, 1988
Mr. John Schultheis
Chemtroni cs, -foe.
180 _01 d Bee~·Tree Road
Swannanoa, NC 28i,8
Dear Mr. Schultheis:
' .
Enclosed please find the raw data for sample SW-4 (ITAS sample no. X8598). CS,
BZ, and their breakdown products were searched for manually using known reten-
tion time windows from standard analyses. Confirmation was based on mass
spectral match with standard and referenced (NBS and Battelle) spectra.
Estimated concentrations were calculated using the internal standard method;
calculations were based on peak h_eight assumin·g a response factor of 1 using the
nearest internal standard {IS):
{ / 1 ) 1 I peak he i t t Concentration in extract µgm = 40 µg/m S x peak heig t IS
Concentration in sample (µg/L) = ~g/ml in extract x l.O ml l.O l
Using the values SW-4,
extract.
x dilution
factor
40 µg/ml IS
obtained for benzylic acid in sample
14 IIIR ~benzylic acid) 7 89 / 1 x . 1 rrrn ( IS} • = • ll9 m benzylic acid
7.89 pg/ml benzylic acid x f:~ ~l x (2x30) ~ 473 pg/l benzylic acid
As benzylic acid, the hydrolysis product from BZ, further decomposed to benzo-
phenone, it was this latter compound that was actuany measured.
Please note that the error was due to failure to convert to mg/liter prior to
transcriptf.,_to the raw data worksheet; no problems in analytical approach were
:~" seen. • ,:c;;.:-:•
-~~r,::7-7.-• ',;_.:.;-:;,:-;
Si~, 11; ·Rx.1.~. ~
Operations Manager
RW: sm
Enclosure Regional O!lice
5615 Middlebrook Pike • Knoxville. Tennessee 3792 l • 615-588-640!
IT Analytical Services
CS, BZ, 'l.nd Degradation Products A· lysis I
?reject Code: M eD w , ':2'/t. t.,
ILab Sample If: X'i?SCtf 12[:.
.Sample Matrix: . Wa.}t!. .,-.,
Analyst/Inst: 1)j)5 /,;4,L-/ 0 <-v 4 ,{_
l*"'"'************'"**.*~11',,;***"'··*·*·*****"'****·"'****""**"'**'l':****"'"'•,,r1,***"'***"'·":;;::.*~~*"'**,.,"'
Sample Description: S (.,J -4' G
I Compound Cone. (""g:/4-) ( 1)
t-Chlorobenzaldehyde
Malononitrile
lz
113-Quinuclidinol
l\enzylic Acid/ Benzophenone (2)
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· Remarks: I .
I
.010 = Quantitation Limit (3)
NO= Not detected
(l)"The concentration is based on peak heights with a response
factor·of 1.00 relative to the nearest non-interfered internal
i,rtand,_,., ·
11
I
(2} Benzr:lifAcid degrades to Benzophenone. Quantitation is based on
both co'iiipyunds ..
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(3) The quantitation limit is 10% of Internal Standard concentration
in extract as analyzed. The limit given is with respect to the
sample.
HE003Rl
I · .. ,-. T. ANALYTICAL SERVICES
I · DATA· FILE: X8598R2 ·
CALIBRATION FILE: CAL05062
SEARCH OF LIBRARYCE
LIBRARY SEARCH REPORT
EXTRACTAB~E ORGANIC ANALYSIS
I
SCAN
I 493
662
895
11099
I 443
1623
•IS• I, 4-DICHl:OROBENZE:NE_-D4
•IS• NAPHTHALENE-DB
•IS• ACENAPHTHENE-DIO
•!S• PH~N~NTHRENE-D10.
•IS• CHRYSENE-Dl2
•IS• PERYLENE-Dl2
iJ> ,,,a: I: c.. ~ •
ML
DELTA
0
0
0
C
0
-1
PUR-FIT
904-960
878-949
876-973
s:;9-947
863-873
874-893
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X * UG/ML •
{, 0
/. 0
(-;/.~ (DILUTION) * \:"---=--77 (FACTOR) = ~o.o
L / ' -...__j.. -I FLAGS: SAT -NUMBER OF MASS PEAKS SA[TURATED
'!°''~_ .,_.,.,
ti
AMT FLAGS
(UG/ML:> SAT LIB
40 0 -1
40 0 0
40 0 0
10 C ~ V
40 0 -2
40 0 -2
'f?o-1,/,...
* X UGI L / _,4
I LIB -NUMBER CF PEAKS OUT OF CLP SPECS IN ENHANCED SPECTRUM
I
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I
RIC' DATA: X8598R2 Ill SCAHS 150 TO 2000 (16/27/86 21: 24: 013 CALI: CAL05062 15 SAMPLE: X 8598 <MEDI, 22466) BII/AE: 0. 3ML EA + 6. 0UL JS, I. 5UL Cotl05.: OWA4: DIR ltlJ OIi 313 M DB-5: 45-325 DEG C AT 12 D/M RANGE: G 1,2000 LABEL: H 0, 4.0 QUAHr A 0, 1.0 J 0 BASE: U 20, 3 100.0 895 ·
,1'.J3
l 1089
' I'
662
'.:,(JI} 11300
8,20 16:40 -----------
1444
1:367-
1500
25:00 -

-
1623
-

-
-
2828.
2000 SCAII
3,,:20 ~ -
I QUANTITATION REPORT
DATA: xe,98R2. TI
I FILE· xa,98R2, !
06/27/86 21:24:00
I SAMPLE: X 8598 <MEOW 22466) BN/AE: 0, 3ML EA+ 6.0UL IS, 1. 5UL
CONDS.: OWA4: DIR INJ ON 30 M DB-5: ~5-325 DEG CAT 12 DIM
FORMULA: WATER c INSTRUMENT: OWA4 WEIGHT:
I SUBMITTED BY: MEDW:jf[',; ANALYST: !)OS/SAL ACCT. NO.
M10UNT=AREA • REF. Al'INT/(REF. AREA!* RESP. FACT); DET. LIM.= 0. 00
RESP. FAC. FROM LIBRARY ENTRY. I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
NO
3
4
5
6
7
8
9
10
11
12
13
14
1 5
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
NAME
* l S•
*IS•
•IS*
•IS*
l,4-DiCHLOR □BENZENE-D4
NAPHTHALENE-DB
ACENAPHTHENE-010
PHENANTHRENE-D10
*IS* CHRYSENE-012
*IS+ PERYLENE-Dl2
•SS• 2-FLUOROPHENDL
*SS* PHENOL-05
*SS• NITROBENZENE-05
•SS• 2-FLUOROBIPHENYL
•S5* TRIBROMOPHENOL
•SS• TERPHENYL-014
N-NITROSODIMETHYLAMINE
PHENOL
BIS<2-CHLOROETHYL>ETHER
2-CHLOROPHENOL
1,3-DICHLOROBENZENE
1,4-DICHLOROBENZENE
BENZYL ALCOHOL
1,2-DICHLOROBENZENE
2-METHYLPHENOL
BI5(2-CHLOROISOPROPYLlETHER
4-METHYLPHENOL
N-NITROSO-DI-N-PROPYLAMINE
HEXACHLOROETHANE
NITROBENZENE
ISOPHORONE
2-NITROPHENOL
2,4-DIMETHYLPHENOL
BENZOIC ACID
BISC2-CHLOROETH□XYlMETHANE
2,4-DICHLDR □PHENOL
1,2,4-TRICHLOROBENZENE
NAPHTHALENE .. .:~ ....
4-CHLOROANJLI~-
HEXACHLOROBUT~
4-CHLORO-J-Mcliff't.pHENOL
2-METHYLNAPHTHALENE
HEXACHLOROCYCLOPENTAOIENE
2,4,6-TRICHLOROPHEN□L
2,4,5-TRICHLOROPHENOL
2-CHLORONAPHTHALENE
2-NITROANALINE
DIMETHYL PHTHALATE
ACENAPTHYLENE
3-NITROANILINE
I
I
0. 000
22466
I NO
47
48
I 49
50
51
I 52
53
54
55
I 56
57
58
I 59
60
61
62 I 63
64
65
I 66
67
68
I 69
70
71 .,. ..,
I . ~
73
74
75
I 76
77
78
I 79
80
81
I 82
83
84
I NO
1
2
I 3
4
5
I 6
7
8
9
I 10
I 1
12
I 13
14
15
I 16
I
NAME
ACENAPHTHENE
2,4-DINITROPHENOL
4-NITROPHENOL
DIBENZOFURAN
2,6-DINITROTOLUENE
2,4-DINITROTO~UENE
DIETHYLPHTHALATE
4-CHLOROPHENYl:i\PHENYLETHER
FLUORENE
4-NITROANILINF_-
1t s-.-t"'iT"ll<''l·or\_•,_-,.:·,-uv1 ot.1c;.1r-i1 • , .... ... ..... "' ' ...... ,_ ', __ '' '' -· ; '""'1 "'-''-
N-NITROSODIPHENYLAMINE
1,2-DIPHENYLHYDRAZINE
4-BROMOPHENYL-PHENYLETHER
HEXACHLOROBENZENE
PENTACHLOROPHENOL
PHENANTHRENE
ANTHRACENE
DI-N-BUTYLPHTHALATE
FLUORANTHENE
BENZIDINE
PYRENE
BUTYLBENZYLPHTHALATE
3,3'-DICHLOROBENZIDINE
BENZO(AlANTHRACENE
BIS(2-ETHYLHEXYL>PHTHALATE
CHRYSENE
DI-N-OCTYLPHTHALATE
BENZO(B)FLUORANTHENE
BENZOCKlFLUORANTHENE
BENZO<AlPYRENE
INDENOCl,2,3-C,DlPYRENE
DIBENZO(A,HlANTHRACENE
BENZOJG,H, !lPERYLENE
MALONONITR!LE
0-CHLOROBENZALDEHYDE
BENZILIC ACID .
0-CHLOROBENZYLIDENEMALONONITR!LE(CS)
M/E
152
136
164
188
240
264
l l 2
99
82
172
330
244
74
94
93
128
SCAN
493
662
895
1089
1443
1623
TIME
8: 13
11: 02
14: :,:,
REF
1
2
:3
18: ()9. 4
24: 03··.· :,
27:03; 6
. :::•"'"· 1
1
2
3
4
5
1
1
1
1
RRT
L 000
L 000
L 000
1. 000
1. 000
1. 000
I METH
A s'e
A a;v
A BB
A a;e
A BB
• A BB
AREACHQHT) AMOUNT ¾TOT
663. 40.000 UQ/ML 16.67
2159. 40.000 UC:/11L 16.67
1959. 40.000 UQ/11L 16.67
·3743. 40.000 UC:/11L 16.67
2337. 40.000 UQ/11L 16.67
2909. 40.000 UC:/11L 16.67
I ~-•-;,,' I NO M/E SCAN TIME REF RRT METH AREA(HGHT) · ,MOUNT 7.TOT ' I ,, 17 146 1 ~
18 · 146 1
1.9 79 1 I 20 146 1
21 108 1
22 121 1 ...
I 23 108 -,, . 1
24 130 1
25 11 7 1
I 26 77 2 ...,.., 82 2 C. '
28 139 2
29 122 2 I 30 105 2
I 31 93 2
32 162 2 ' I 33 180 2 , I 34 128 2
35 127 2 I
I 36 225 2 I 37 107 2
38 141 2
' 39 237 3 'I 40 196 3
41 196 3
42 162 3
I 43 138 3
44 163 3
45 152 3
ii 46 138 3
47 154 3
48 184 3
49 65 3 I 50 168 3
51 165 3
52 165 3
I 53 149 3
54 204 3
55 166 3
I 56 138 3
57 198 3
58 169 4
59 77 3 I 60 248 4
61 284 4
62 266 :.;., ... 4 .. _,;:-.. _._
I 63 178 4
64 178 4
65 149 4
I 66 202 4
67 184 5
68 202 5
69 149 5 I 70 252 5
71 228 5
72 149 5
I
I
I i"~~ I ·a,, I NO M/E . SCAN TIME REF RRT METH AREA!HGHT) MOUNT . %TOT I -73 228 ,
Jj
' 74 ·149 6
I 75 252 6
76 25;! 6
77 252 6 78 276 6 I 79 278 6 BO 276 6 81 66 l ; ,
I 82 139 2
83 105 4 94· 153 3
I I NO RET<Ll .RATIO RRTiL) RATIO
4~r~b
AMNT(L) R.FAC R.FAC(L) RATIO 1 8:41 0. 95 I. 000 1. 00 40. 00 l. 000 1. 000 l. 00 ., 11:29 0. 96 1. 000 1. 00 40. 00 1. 000 1. 000 1 00
~ 40,00 I 3 15:21 0.97 l. 000 1. 00 40.100 40.00 1. 000 1. 000 1. 00 4 18:36 0.98 1.000 1. 00 40. 00 40. 00 l. 000 1. 000 1. 00 5 24:29 0. 98 1. 000 1. 00 40. 00 40.00 1. 000 1. 000 1. 00 I 6 27:29 0.98 1. 000 1. 00 40. 00 40.00 1. 000 1. 000 1. 00 7 5:59 0. 692 J00.00 0. 7!:ll 8 8:08 0. 940 100.00 1. 098
I 9 9:56 0.868 100.00 0. 232 10 13: 55 0.907 100. 00 0. 749 11 17:06 0. 921 100.00 0. 182 12 22: 11 0. 906 100.00 0. 703 I 13 2:37 0.303 so. 00 0. 721 14 8: 10 0. 944 50.00 1. 444 15 8: 13 0.950 50.00 1. 362 :I 16 8: 18 0. 960 50.00 1. 342 17 8:34 0.990 50. 00 1. 632 18 8:41 1. 004 50.00 1. 845
I 19 9:27 1. 092 50.00 0.982 20 9: 06. 1. 052 so. 00 1. 616 21 9:27 1. 092 50.00 1. 242 22 9:26 1. 091 50.00 0.353 I 23 9: 47 1. 131 50. 00 L 184 24 9:44 1. 12:5 50.00 0. 150 25 9: 46 1. 129 j 50.00 0. 878 · I 26 9:58 0. 870 50.00 0. 509 27 10:32 0. 920 I 50.00 0.841 28 10:42 0.934. I 50.00 0. 188
I 29 10:54 0. 952 i 50.00 0.287 30 11: 20 0.9'90
I 50.00 0. 202 31 11:04 0,~67 50.00 0. 420 32 11: 1 7 0,,'985 50.00 0.326 I _ .. , ..
I 33 11: 23 0'.;994 50.00 0.499 34 11: 30 1. 004 50.00 1. 078 35 11: 45 1. 026 50.00 0. 121 I 36 11: 58 1. 045 50.00 0.365 37 12:54 1. 127 50.00 0.357 38 13:02 1. 138 50.00 o. 676 I 39 13:34 0.884 50.00 0. 403 40 13:46 0.897 50.00 0. 4:58 41 13: 54 0.906 50.00 0. 526
I 42 14:05 0. 917 50.00 1.220
I "
~ " .,.~,-·.~ -:-~:; ::;i I j ' NO RET<Ll RATIO RRT<Ll RA ,0 A!"NT AMNT(Ll R. , .,C R. FACCLl R!\Tro 43 14: 28 0.942 50 00 0. 246 ' · 44 14: 56 0. 973 50.00 1. :524 I 4!5 l !l: 00 0.977 50. 00 1. 614 46 1 !l: 31 l. 011 50.00 0, 010 47 15: 25 1.·004 50.00 1. 182
I 48 15:37 1:;.017 · 50.00 o. 094 49 16:03 l' .. 046 50, 00 0. 056 50 15:47 1. 028 ·, , 50, 00 1.685 5 1 15:02 0.979 50. 00 0.279 I <;.., l 5: 55 , 1,-0:37 50.00 0. 423 _.,
53 l t,; '. ,JQ !", 075 SC. CO J ~ ~-J., QI V 54 16:35 I. 080 50.00 0. 789
I 55 16: 32 1. 077 50, 00 1. 400 56 16: 32 I. 077 50, 00 0.017 57 1 b: 48 L 094 50.00 0.2b7 58 16: 5 l 0. 906 50. 00 0, 357 I 59 16: 55 1. 102 50. 00 2. 071 60 17:36 0. 950 50, 00 0.260 61 17:55 0.965 :'JO. 00 0. 365 I '.., 18:21 o. 988 50. 00 0. 169 .:,.,
63 18:37 1.003 :'JO. 00 1. 167 64 18:44 l. 009 50.00 1. 164
I 65 20:06 1. 083 50.00 1. 343 66 21: 16 1. 145 50. 00 l. 482 67 21:48 0.890 80. 00 0.028 68 21: 45 0.888 50.00 2.055 I b9 23:24 0. 956 50.00 0.719 70 24:31 L 001 50, 00 0. 159 71 24;27 0.999 50. 00. l. 617 I 72 24: 47 1.012 50.00 1. 141 73 24:32 1. 002 50.00 1. 752 74 26:07 0. 950 50.00 l. 597
I 75 26:45 0. 973 50.00 l. 823 76 26:48 0.975 • 50. 00 2. 017 77 27:23 0.996 50.00 1. 328 78 29:57 l. 089 50.00 1. 422 I 79 29: 59 l.090 50.00 1,069 80 30:37 l. 113 50.00 1. 081 81 5:26 0. 649 100.00 2.451 I 82 11: 01 0. 9:H 100. 00 · 1. 000 83 17:27 0,936 50,00· l. 000 84 16:09 1. 066 · 100.00 1. 000
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IT ANALYTICAL SERVICES
GA/GC REPORT
F'!LE: X8598R2
INTERNAL STANDARD AREA CHECK
o OUT OF 6 ARE WITHIN 507. TO 2007. OF DAILY STANDARD AREAS .
• <Ht INTERNAL STANDARB--AREAS ARE WITHIN GC LIMITS ••
*IS* l,4-D!CHLDROBENZENE-D4 60 ,.
•IS* NAPHTHALENE-DB 51 7.
*IS* ACENAPHTHENE-DlO 68 7.
•IS* PHENANTHRENE-DlO 63 7.
+IS• CHRYSENE-D12 . :;4 7.
*IS• PERYLENE-D12 66 7.
INTERNAL STANDARD RETENTION TIME CHECK I ======================================
I 6 OUT OF 6 ARE WITHIN+/-30 SECONDS OF DAILY STANDARD RETENTION TIME
** INTERNAL STANDARD RETENTION TIMES ARE.WITHIN OC LIMITS**
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11
I
11
I
I 6/27186 21:26:29
ACQUISITION STARTED
I ACQUIRE
06/27/86 21:24:00 +. 2:04
SAMPLE: X 8598 CMEDW 22466)
I CONDS. : OWA4: DIR fiif-i ON 30
f'"ORMULA: WATER
SUBMITTED BY: MED~-
1 c.OW MASS:
HiGH MASS: :rno
I :ENT SIP: 10 ACTUAL: 10
FRAG SIP: 10 ACTUAL; 10
I MIN PEAK WIDTH: 2
AID THRESHOLD: 2
I MODE: CENTROID POSITIVE ION
INTERFACE NUMBER
SUB-INTERFACE NUMBER
I # OF ACQU BUFFERS
INSTRUMENT TYPE
FULL SCALE MASS
•• ZERO SCALE MASS
INTENSITY/ION
PEAK WIDTH
OFFSET AT LOW MASS
OFFSET AT HIQH MASS
SCAN 121 OF 2000
RUN O:X8598R2 ACQUIRING
FREE SECTORS: l 63:56
BN/AE: 0. 3ML EA+ 6.0UL
M DB-5: 45-325 DEG CAT
INSTRUMENT: OWA4
SCAN: 124 OF 2000
rs. L SUL
12 0/M
ANAL. YST: D!iS/SAL
WEIGHT: 0.000
ACCT. NO. 22466
!JP: 0. C17 L+
DOWN: 0.00 L
TOP: C. CO
BOTTOM: 0.03
SAMP INT IMSI: 0.200
SAMP INT CMS): 0. 200
PEAK WIDTH: 1000.
INTEN/ION: 2
MIN FRAG WIDTH¼: BO
BASELINE: 0
MIN AREA:
M.S. TUNE PARAMETERS:
2
0 MULTIPLIER VOLTS: -2000.00
0 LOW RESOLUTION: 126.00
16 HIGH RESOLUTION: 127.00
Q ION ENERGY: 3. 53
BOO AMU ION PROGRAM: 8. b3
1 AMU LENS VOL TAQE: -75. 29
2 EXTRACTOR: 2.00
1000. MMU ELECTROHETER RANGE: 7.00
0 MMU ELECTROMETER ZERO: -1. 11
0 MHU I VOLTAGE SETTLING TlME<MS) 4
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I
6/27/86 21: 57:52
ACQUISITION COMPLETED
SCANS 1 TO 2000 CENTROID
MODE I CENTROID
SCANS·
2000
SECS
1.'
OUT OF
2000 .. 0
I
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I
I
I
0. 1
PEAKS PER SCAN PER SEC
13828. 7. 7.
·T'ca,-' . .. .
. "i
'1
IOB.0
105
RIC
-
RIC + MASS CH;;·ot1ATOGRAM DATA: X8598R2 1110,17 SCAHS 928 TO 1167
06/27 /86 21: 2.1: 00 CALI: CAL8:5062 115
SAMPLE: X 859B (MED14 22466) Bt~/AE: 0. 3ML EA + 6,0UL IS, 1. SUL
COHOS.: Ol4A4: DIR !HJ Otl 30 M 08-5: 45-325 DEG C AT 12 0/M
BEHZILIC ACHl
RAHGE: G 1,2000 LABEL: H 0, 4.0 QLIAH: A 0, 1.0 J 0 BASE: U 20, 3
r
I
950 1(100
15::{t lio: 40 - ---- -- -
11)50
17:30 -
I I I
1089
' ,
r-
--
~-1119 1145 j . I • _,......, -,-_..,_...>y ==-t'" -r~ f Orr T ,o, •
I W0 1150
18:'.)3 19: 10 - - - - -
100.
105.031
t 0.500
2068.
SCAII
TIME - -
F ,·~···· . -' ,,
t
1000
'lE
LIBRARY SEARCH DATA: X8598R2 I 995
06✓27✓86 21:24:00 + 16:35 CALI: CAL05062 I 5
SAMPLE: X 8'.i98 (MEOW 22466> 8H✓AE1 0,3t1l £A .t-6.0Ul IS, I.SUL
COHOS.: OWA4: DIR !HJ 00 30 M DB-5: 45-325 DEG CAT 12 O✓M
ENHANCED <S 158 1H 0T)
BASE M✓E: 77
RIC: 284.
u...~---~-,,c.,,,.....i.1.__,_._..,.,---1,.._,.._,--,--~--,,....--..........--.-~---....---,,..L.,,.--,--... ,--.--.--T.-......--...---r.----.--'
,H10.O METHAHOHE,DIPHEHYL-Cf!S t 119-61-9
r1?8! I I 77
I I l 10579
B!S j_· --,--......,-~--,..............--.---,...~......--.w.-...---.---.----.-.--.--~...----.--.-.....--.--.-J
1,2,4-TRIDXOLAHE,3,3,5-TRIPHEHYL-CAS l 23246-12-0
50 100 150 250
-------------------
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APPENDIX C
October 7,. 1988 Memorandum from Wade lCnight,
Chief of Quality Assurance and Laboratory Evaluation
Section, Environmental ServiCea Division
·,q~
"'f ,
.;_•.·
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS. GEORGIA 30613
--.--
MEMJRANDUM
DATE: October 7, 1988
SUBJECT: Data Error -ChB11tronics RI Report
FROM: ll I,, L J.L :fl Wade Knight, Chief ·v•-· ·'.l
Laboratory Evaluation & Quality Assurance Sec ti on
TO: Jon K. · Bornholm
Project Manager
Superfund Branch
Waste ManagB11ent Division
We have reviewed the infonnation supplied by Chemtronics concerning a report-
ing error for Sample SW-4 analyzed June 6, 1986. According to ChB11tronics,
the value for benzyl ic acid was reported .. as 470 mg/L when it should have been
reported as 470 ug/L. From our review of the raw data, we agree that the
val_ue should have been reported as 470 ug/L.
·~
"
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APPENDIX D
Explanation of Significant Difference
in A Component of the Remedy to be
Implemented at the Chemtronice Superfund Site
Fact Sheet Dated February 10, 1989
,.,,..,,. ··:.,, -~ · ..
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UNITED STATES E:NVIRONMENTAL PROTECTION AGENCY
REGION IV
:US COURTLAND STREET
ATL.ANTA., GE:ORGIA. 31ll45
Explanation of Significant Difference in A
component of the Remedy to be Implemented at
the Chemtronics Superfund Site
February 10, 1989
The mandate to address post-ROD changes is provided by CERCLA S117(c), which
states:
"After adoption of a final remedial action plan
(l) if any remedial action "is taken (under
sections 104 or 120), (2) if any enforcement
action under section 106 is taken, or (3) if any
settlement or consent decree under section 106 or
section 122 is entered into, and if such action,
settlement or decree differs in any significant
respects from the final plan, the lead agency
shall publish an explanation of the significant
differences and the reasons such changes were
made."
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INTRODUCTION
Based on a correction of analytical data with regard to the chemical quality of
the groundwater downgradient of Disposal Area 23 (DA-23) at the Chemtronics
Superfund site·, the u.s. Environmental Protection Agency is proposing to change
the source control remedy selected fat: i1A-23 in the Record of Decision (ROD).
Thia do.cument. is an explanation of the difference between the source control
. rere~f.iy. aa. ori{Jinall't,· :::::pe::;ified i:n the ~ROD and '...:hi: rerr.6:•ly RPA •;10w··prnpclRA.:c · r.,, !1':--
implemented. The rationale and data supporting the proposed change is
specified below.
BACKGROUND
Site Description
The Chemtronics Site encompasses approximately l,027 acres and is located at
180 Old Bee Tree Road in a rural area of Swannanoa, Buncombe County,
approximately 8 miles east of Asheville, North Carolina, The approximate
center of the site lies at latitude 35 • 38' 18" north and longitude 82' 26 '· 8"
west. The Site is bounded on the east by Bee Tree Road and Bee Tree Creek.
The area to the north and west of the Site is comprised of sparsely inhabited
woodlands. Immediately to the south of the Site, there are several industrial
facilities which lie on land that was once part of the original (Oerlikon)
property.
site History
The property comprLBLng the Chemtronics Site was first developed as an
industrial facility in 1952. The Site has been owned/operated by oerlikon Tool
and Arms Corporation of America (1952-1959), Celanese Corporation of America
(Hoechst-Celanese corporation) (1959-1965), Northrop Carolina, Inc. (Northrop
Corporation) (1965-1971), Chemtronics, Inc., as apart of Airtronics, Inc.,
(1971-1978), and Chemtronics, Inc. (1978 -present). The site operated under
the name of Amcel Propulsion, Inc. (1959-1965) under both oerlikon and
Celanese. The Site is currently occupied by an active facility owned and
operated by Chemtronics Incorporated, a subsidiary of the Halliburton company.
Waste disposal occurred over a small portion (approximately than ten acres) of
the Site. Twenty-three individual on-site disposal areas were identified and
described by reviewing existing records and through interviews with former and
current site employees. These 23 individua1 disposal areas are grouped into 6
discrete dia~aal areas, DA-6, DA-7/8, DA-9, DA-10/11, DA-23, and the Acid Pit
Area. The si~e can also be divided into two geographical subsections; they
will be referred to as the Front Valley and Gregg valley.
Disposal Area 23 is located in the Front Valley. DA-23 consists of a lined
40,000 gallon neutralization basin and a lined 500,000 gallon biolagoon built
on top of an abandoned tile leach field. The tile field was built in
association with Building 113, the main production building. The tile field
was abandoned in the 1960's. The neutralization basin and the biolagoon were
partially built on top of the abandoned leach field. Soils contaminated due to
the tile field were probably used in the construction of the berms to support
the basin and biolagoon.
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-2-
When the biolagoon was originally constructed in 1979, the initial synthetic
liner failed when the owner/operator introduced the contents of a 55 gallon
drum of BCL 462 (a brorninated compoun.l.)·'into the biolagoon to acclimate the
bacteria present in the lagoon. The brominated compound-disintegrated the
.lir!-:::!." .. releae·ing .. tt.e ::•:>!:'..:entH of the :,5 • gall•.:,:: --::l!:'w.1 c:.::d apprc:::l.r..atel y 300, 000· ·
gal~ons of water. A second liner was installed in 1980 and was used until 1984
when the owner/ope_rator decommissioned the biolagoon. Appendix A provides a
list of the wastes and the approximate quantity treated through the biolagoon.
An accurate inventory of wastes disposed of through the leach field is not
possible as no records of disposal were maintained.
RECORD OF DECISION
In April 1988, EPA prepared the ROD baaed on the findings of the Remedial
Investigation (April 1987), supplemental groundwater data collected in October
1987, the Feasibility Study (March 1988), and the public comments .received
during the five week comment period following the Feasibility study public
meeting held February 23, 1988. The ROD (available at the four information
repositories) specified the following remedial action for DA-23 and groundwater
contamination found in the Front ValleY:
Installation of a groundwater interception and extracti~n system
downgradient of the diapoaal areas·in both the Front Valley and Gregg
Valley. The level and degree of treatment of the extracted groundwater
will depend on l) the ultimate discharge .point of thia water and 2) the
level of contaminants in the extracted groundwater. The three water
discharge alternatives for the treated water are 1) the local sewer system,
2) a surface stream and 3) on-site irrigation.· The range of trei'atment for
the extracted groundwater includes air atri~ping, filtration through
activated carbon filter and metal removal. The point of discharge and the
degree of treatment will be determined in the Remedial Design stage. The
water discharged will meet all ARAR's.
Review the existing groundwater monitoring system and ins~all additional
wells, if necessary, to insure proper monitoring of groundwater
downgradient of Bach disposal area.
In addition to the monitoring of the groundwater downgradient of each
disposal-area identified above, action levels for the contaminants present
in the dispoeal·areas will be set so that after remediation levels for
groundwater have been obtained and verified through monitoring, if thia
level is reached in any subsequent sampling episode, a remedial action to
permanently· eliminate that source of contamination will be initiated.
For the contaminants and contaminated soils associated with DA-23,
determine the moat appropriate soil fixation/stabilization/solidification
process and the mixing ratios for the components involved. Following the
soil fixation/stabilization/solidification for DA-23, the entire surface of
the disposal area will be capped.
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CHANGE IN Tlll:I/ .. RBCORD OF DECISION
The original source control remediation·'action selected for DA-23 is stated
above. The fj..xation/stabilization/solidification alternative was selected due
t-:J .tho. ,concantrc'.t5 "."):'1. !evel 0f tho .... on-vol a+: il'! 0)r.,:;:..nic: cor:~M::inan:t; .. ben;ylic
acid and benzophenone found in the groundwater downgradient of DA-23. The
Remedial Investigation Report, dated April 1987, stated that the concentration
for benzylic acid/benzophenone in the groundwater downgradient of DA-23 in
monitor well (MW) SW-4 as 470 milligram/liter (mg/1). This concentration is
equivalent to 470 parts per million (ppm). MW SW-4 is a shallow monitor well
and 470 mg/1 is a relatively high concentration for a contaminant in
groundwater.
In OCtober 1987, approximately one year after the original sampling episode,
nine (9) monitor wells were resampled. MW SW-4 was one of these wells. The
analytical results for benzylic acid/benzophenone for SW-4 was 1.2 mg/l, which
is considerably less than the 470 mg/1 level recorded in the initial sampling
episode. The concentration level of 1.2 mg/1 is more in line with the levels
found in other wells downgradient of DA-23 as can be seen in Appendix B.
It was the Agency's rationale, based on the level of 470 mg/1, that the
concentration of benzylic acid/benzophenone in the soils of DA-23, the source
of this contaminant, must also be relatively high, therefore requiring a more
rigorous source control remedial action. Thie thought process led the Agency
to select a soil fixation/etah_ilization/solidification process as the source
control remediation· for DA-23.
The fixation/stabilization/solidification alternative was selected over soil
venti_ng or capping due to the fact that tne contaminant of concern, benzylic
acid/benzophenone, is not readily volatilized. Although soil venting would
help remove the volatile organics from the soil, it would not remove the
non-volatile organics. Usually, it is the non-volatile organics that determine
the length of time necessary to pump and treat the groundwater as non-volatile
organics do not readily move with groundwater through the soil as do volatile
organics. Soil venting would help reduce the levels of volatile organics, but
it does not address the non-volatile fraction of contaminants and therefore,
soil venting was not selected aa the new source control remedial action for
DA-23.
Due to the lower level of benzylic acid/benzophenone than first identified as
being presanti:.J,n the groundwater downgradient of DA-23, and the fact that soil
venting alternative would not accelerate the time needed to ramediate DA-23,
the Agency now proposes that DA-23 be capped with a multi-layer cap, which
includes a synthetic liner. The multi-layer cap will meat as ·a minimum the
specified under 40 CVR Subsection 264, Subparts K-N. A gas collection system
will also be incorporated into the cap if deemed necessary.
DOCUMENTATION OF A TRANSCRIPTION ERROR
In a letter dated September 19, 1988 (Appendix C), the potentially responsible
parties (PRPs) informed the Agency of a possible transcription error made by
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the laboratory contracted by the PRPs to perform their analytical analyses.
Instead of reporting the detected concentration as 470 micrograms/liter (ug/11
or 470 parts per billion (ppb) as they should had done, the laboratory reported
the concentr~tion as 470 mg/1 or 470 ppm. Misplacing the decimal point by
This information and the documentation to support this reported transcription
error was transmitted to EPA, Region IV Chief of the Quality Assurance and
Laboratory Evaluation Section (QALES) of the Environmental Service Division.
After reviewing the documentation, QALES concurs that a transcription error
had occurred (Appendix D).
CONFIRMATION OF GROUNDWATER QUALITY
Prior to making a final decision on whether to change the selected source
control remedy for DA-23, the Agency reaampled MW SW-4 the first week of
January 1989. The analytical results for the January 1989 sample are 48 ug/l
for benzylic acid and 3400 ug/l for benzophenone. These results confirm the
lower concentration range of 0.0 to 470 ug/1 and not concentrations in the _
parts per million. Therefore, the Agency proposes to change the source control
remedial alternative for DA-23 from soil fixation/stabilization/solidification
to capping. The cleanup goal, as specified in Table 13 of the ROD, for
benzylic acid and benzophenone has r,ot changed and remaine at 21 ug/1 and 152
ug/l, respectively (Appendix E).
Capping will be aa protective of human he~lth and the environment aa the soil
fixation/stabilization/solidification process. This is baaed of the findings
that the exposure pathways for the contaminants found at DA-23 are consumption
of contaminated groundwater and discharge of contaminated groundwater to
surface streams. These findings are documented in the Public Health and
Environmental Assessment section of the Remedial Investigation report and the
Endangerment Assessment incorporated into the Feasibility Study document. Both
of these pathways are mitigated by the groundwater extraction/treatment system
required for the Front Valley under the Migration Control section of the ROD.
Therefore, in terms of protecting the public health and the environment, caping
DA-23 and pumping and treating the groundwater in the Front Valley of the
Chemtronics .site achieves the same degree o·f protection as the soil
fixation/stabilization/solidification process. As documented in the
Feasibility Study, capping is the more cost effective remedial action. The
North Carolina Department of Human Resources has been apprised and is in
complete agreement with the Agency's proposal.
In addition to meeting the requirement of Superfund, being co~t effective and
protecting public health and the env.ironment, capping DA-23 will also satisfy
the post closure requirements impose upon the owner/operator of the facility by
the Resource, Conservation & Recovery Act (RCRA) programs of the Agency and
North Carolina Department of Human Resources. The RCRA programs are involved
with DA-23 because the biolagoon was operated post-1980.
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Under RCRA,. when a business or individual stops operating a solid waste
management wiit (SHU), the SMU needs to be closed out according RC!U\
regulations. ··Capping DA-23 and pumping•and treating the groundwater will meet
RC!U\'s reguir.,..nents.
COMMENTS FROM THE PUBLIC
The public is encouraged to submit written comments on the above change. The
public comment period will end three (3) weeks after the date on the title page
of this document. Comments will be summarized and responses provided in the
Responsiveness Summary that will be placed in the Information
Repositories/Administrative Record. The Agency is also willing to meet with
local residents to address their concerns~ Written comments or requests for
further information should be sent to:
Jon Bornholm
US EPA
345 Courtland street, NE
Atlanta, GA 30365
404/347-7791
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:.:_.~:-
APPENDIX E
Legal Notice Published in the
Asheville Times/Citizen Newspaper
March 1989
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION !V
l<l5 COUATt.ANC STREET
ATI..ANTA, Gl:ORGIA 303165
LEGAL NOTICE
Amendment to the Record of Decision
for the Chemtronics Superfund Site
March 8, 1989
The mandate to address post-ROD changes is provided by CERCLA
Sll7(c), which states:
"After adoption of a final remedial action plan
( 1) if any remedial action is taken ( under
sectione 104 or 120), (2) if any enforcement
action under section 106. is taken, or (3) if any
settlement or consent decree under section 106 or
aection 122 ia entered into, and if such action,
settlement or decree differs in any significant
reepecta from the final plan, the lead agency
ahall publish an explanation of the significant
differences and the reasons such changes were
made."
RECORD OF DECISION
In April 1988, EPA prepared the ROD baaed on the findings of the Remedial
.Inveecigation (April 1987), supplemental groundwater data collected in october
1987, the Feasibility study (March 1988), and the public comments received
during the five week comment period following the Feasibility study public
meeting held February 23, 1988. The ROD (available at the four information
repositories) specified the following remedial action for DA-23 and groundwater
contamination found in the Front Valley:
Installation of a groundwater interception and extraction eystem downgrad'ient
of the diepoeal areas in both the Front Valley and Gregg Valley. The level and
· degree of treatment of the_ extracted groundwater will depend on l) the ultimate
discharge point of this water and 2) the level of contaminants in the extracted
groundwater. The three water discharge alternatives for the treated water are
1) the local sewer system, 2) a surface stream and 3) on-eite irrigation. The
range of treatment for the extracted groundwater includes air stripping,
filtration through activated carbon filter and metal removal. The point of
diacharge and the degree of treatment will be determined in the Remedial Design
atage.' The water discharged will meet all ARAR's.
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Review the existing groundwater monitoring system and install additional wells,
if necessary, to insure proper monitoring of groundwater downgradient of each
disposal area.
In addition to the monitoring of the groundwater downgradient of each disposal
area_ ident:i (1 "'11'1 ~~0<.•>:; · e,/::ti,;.;,n ·.L":!'~!~le · f·Qr the c~:'1t~i!1.:int~ p::c:..:~~'!:. in th.ii
disposal areas will be set ea that after remediation levels for groundwater
have been obtained and verified through monitoring, if this level is reached in
any subsequent sampling episode, a remedial action to permanently eliminate
that source of contamination will be initiated.
For the contaminants and contaminated soils associated with DA-23, determine
the moat appropriate soil fixation/stabilization/solidification process and the
mixing ratios for the components involved. Following the• soil
fixation/stabilization/solidification for OA-23, the entire surface of the
disposal area will be capped.
INTRODUCTION
Baaed on a correction of analytical data with regard to the chemical quality of
the groundwater downgradient of Disposal Area 23 (DA-23) at the. Chemtronics' . . Superfund Site, the U.S. Environmental Protection Agency is proposing to change
the source control remedy selected for.OA-23 in the Record of Decision (ROD).
Thia document is an explanation of the'Qifference between the source control
r@medy ae origir,.alJ.y apecified in the ROD and the remedy EPA now propos,as to be
implemented, The rationale and data supporting the proposed change is
specified below.
CHANGE IN THE RECORD OF DECISION
The original source control remediation action selected for DA-23 is stated
above. The fixation/stabilization/solidification alternative was selected due
to the concentration level of the non-volatile organic contaminant benzylic
acid and benzophenone found in the groundwater downgradient of DA-23. The
Remedial Investigation Report, dated April 1987, stated that the concentration
for benzylic acid/benzophenone in the groundwater downgradient of DA-23 in
monitor well (MW) SW-4 as 470 milligram/liter {mg/1). Thia concentration is
equivalent to, 470 parts per million (ppm). MW SW-4 is a shallow monitor well
and 470 mg/J::ila a relatively high con.;entration for a contaminant in
groundwater~!}?--·~
In OCtober 1987, approximately one year after the original sampling episode,
nine (9) monitor wells were resampled. MW sw-4 was one of these wells. The
analytical results for ben.zylic acid/benzophenone for sW-4 was 1.2 mg/1, which
ie considerably less than the 470 mg/1 level recorded in the initial sampling
episode. The concentration level of 1.2 mg/1 is more in line with the levels
found in other wells downgradient of DA-23 ae can be eeen in Appendix B,
It was the Agency's rationale, based on the level of 470 mg/1, that the
concentration of benzylic acid/benzophenone in the soils of DA-23, the source
of this contaminant, must also be relatively high, therefore requiring a more
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rigorous source control remedial action. Thia thought process led the Agency
to select a·~,·e'a11 fixation/stabilization/solidification process as the source
control remediation for DA-23.
The fixation/stabilization/solidification alternative was selected over soil
vent.in~ or. ca:;;r,L.r:; du.e ':.:.o the =:.t.ct that the co::1t~r.i::.ant of concern. :>en~·.y:ii:..
aci~/benzophenone, is not readily volatilized. Although soil venting would
help remove the vo_latile organics from the soil, it would not remove the
non-volatile organics. Usually, it is the non-volatile organics that determine
the length of t~e necessary to pump and treat the groundwater as non-volatile
organics do not readily move with groundwater through the soil as do volatile
organics. Soil venting would help reduce the levels of volatile organics, but
it does not address the non-volatile fraction of contaminants and therefore/
soil venting was not selected as the new source control remedial action for
DA-23.
Due to the lower level of benzylic acid/benzophenone than first identified as
being present in the groundwater downgradient of DA-23, and the fact that soil
venting alternative would not accelerate the time needed to remediate DA-23,
the Agency now proposes that DA-23 be capped with a·multi-layer cap, which
includes a synthetic liner. The multi-layer cap will meet as a minimum the:
specified under 40 CFR Subsection 264,· Subparts K-N. A gas collection system
will also be incorporated into the cap if deemed necessary.
COMMENTS FROM THE PUBLIC
The public is encouraged to submit written comments on the above change to:
Jon Bornholm
US EPA
345 Courtland Street, NE
Atlanta, GA 30365
404/347-7791
Written comments should be postmarked no later than Tuesday, March 21, 1989.
Comments will be summarized and responses provided in the Responsiveness
Summary that will be placed in the Information Repositories/Administrative
Record. Materials relating to the above change and other information regarding
the Che~troniCs site are, also, available for citizen review the information
repositories.-,.·:.~ The four information repositories for the Chemtronics superfund
site are loc&ted at:
Dr. Gary Miller
Environmental Studies
University of North Carolina
@ Asheville
One University Heights
Asheville, NC 28804-3299
Mr. Jerry VeHaun
Buncombe County Emergency Services
P.O. Box 7601
Asheville, NC 28807
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Chemtronics Site Information Bureau
P.O. Box 18177:
70 Woodfin Place
Asheville, NC' 28814
Warren Wilson College Library
Warren Wilson College
701 Warren Wilson college Road
Swannanoa, NC 28778
The U.S. Environmental Protection Agency, Region IV, upon citiz~~ request, will
meet with local residents to address their concerns.
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: -~..:'-.
APPENDIX F
Responsiveness Summary
Comments Received by the Agency
and the Agency's Responses
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,.7on C,-,,.:.nhr, ·r ,1,
Region IV, US EPA
345 Courtland Street, NE
Atlanta, GA 30365
Re: Explanation of Significant Difference .
Superfun_d Site
Dear M~-Eor11holm:
. Chemtronics
Contrary to statements in both the Record of Decision (ROD)
and the Feb. 28, 1989, Explanation of Significant Difference
(ESD), stated remediation levels for contaminated
groundwater do not meet applicable or relevant and
appropriate requirements. Groundwater remediation levels as
set in Table 13 of the ROD have not been approved by North
Carolina's Department of Environmental Management, a
violation of CERLCA and SARA Section 12l(d) (2) (a) (ii), and
are not set at the most stringent chemical-specific levels.
Until EPA has completed the process, including public
hearing, required for seeking a variance from North
Carolina's existing groundwater quality standards, neither
the ROD or the ESD can set definitive groundwater
remediation goals.
The groundwater remediation goal for this site should be
recovery to naturally-occurring state. Therefore,
remediation levels should be set at detection levels for all
synthetic, man-made substances. EPA's current suggested
levels do not begin to attempt this goal. At the least,
remediation levels should be set at maximum contaminant
level goals (MCLGs) (see Sara Section 121 (d) (2) (a) where
they are more stringent than MCLs. However, using drinking
water standards for remediation tevels, particularly in
North Carolina, means that remediation levels are not as
''clean" as background levels; in essence, this standard
allows a continuing level of degradation, which is
unacceptable. If site capping and groundwater interception
and extraction options chosen for remedial action cannot
assure contaminant levels in groundwater no greater than
detection levels, then corresponding action levels for
groundwater may not protect the public health and th~
environment, as required by law.
Contrary to the ROD and the ESD, capping and groundwater
extraction/treatment/monitoring do not constitute a
permanently effective treatment technology which, according
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to SARA, is preferable. According to the Office of
Te.chnology Assessment Special Report OTA-ITE-362 (June
1988), ·:containment, an impermanent technology, will likely
require-future cleanups for the wastes left in the ground,
and is an impermanent technoiogy chosen too frequently by
EPA for remedial action. All manmade attempts to control
surface_and subsurface are susceptible to failure over time.
Tna -ramedi~l ac~icn chcsen for ·the Chemtroni8s site pro1uises
a ''band-aid'' cleanup. The chosen remedial action virtually
assures that the PRPs, the community, and EPA will have to
deal with this site once again in the future.
The ROD and the ESD fail to address off-site hazardous waste
dumps used by the PRPs. Specifically, neither document
addresses the dumps in Buckeye Cove (Mary Crain's land), the
Tropigas site on highway 70, or the site south of
Chemtronics property (Asheville Dyeing and Finishing).
Though the RI/FS acknowledges PRP dumping of hazardous·
wastes at these sites, EPA fails to hold the PRPs
responsible for these sites. This represents gross
negligence on the part of the PRPs and EPA. Questions of
ethics and accountability aside, the public health and the
environment continue to be endangered by the failure to
address the off-site dumps.
cc: Senator Terry Sanford
Congressman James McClure Clarke
William L. Meyer
Perry Nelson
Citizens' Watch for a Clean Environment
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4Wll-SFB
Ma. Jennie !ff' Rominger
Clean Water l"Und of.North Carolina
138 East chestnut Street
Asheville, NC 28801
Re, Response to Comments Received During Public comment Period on
Explanation of Significant Difference for Chemtronics Superfund Site
Dear Ms. Rominger:
This correspondence is in response to your March 20, 1989 letter on the
Agency's Explanation of Significant Difference (Amendment to the Record of
Decision) for the Chemtronics Superfund Site. The public comment period for
this document ended March 21, 1989.
The cleanup goals the Agency selected for contaminated groundwater and soil
were based on the information, calculations and conclusions presented fn the
Public Health and Environmental Assessment and the Endangerment Assessment.
The Public Health and Environmental Assessment can be found in the Remedial·
Investigation report and the Environmental Assessment is located in the
Feasibility Study (FS) document. Also presented in the FS are the
calculations for deriving Preliminary I'.ollutant Limit Values (PPLVs). PPLVs
are cleanup goals for specific contaminants found at the Chemtronica site
that have no established cleanup goals or standards. Since the calculated
PPLVa are based on limited toxicological data, a conservative, protective
approach was utilized to arrive at these cleanup levels. Baaed on existing
toxicological data, the Agency is confide~t in stating that the remediation
levels set forth in Table 13 of the Record of Decision (ROD) will be
protective of human health and the environment.
Provisions in Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 {CERCLA) as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) allow the Agency to waive
"applicable or relevant and appropriate requirements• (AR.ARB) under six
situations. One of these situations, compliance is technically
impracticable, applies to the Chemtronics site. The Agency's position is set
forth in the Agency's letter to the State of North Carolina requesting a
variance to.North Carolina Administrative Code, Title 15, Subchapter 2L,
Paragraph .0202; (15 NCAC 2L) dated March 1, 1985. I have enclosed a copy of
this request?·:,· ·Presently, the Agency is waiting for a response from the North
Carolina Division of Environmental Management on the Agency's request.
'~. ~-·:,
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The Agency acknowledges the fact that capping the disposal areas is not
considered a--permanent remedial action. As stated in the FS public meeting
conducted.on February 23, 1988, the Agericy•s preferred remedial alternative
for addressing the contaminated soils was on-site incineration with a fall
back i:,caL":.~.r.:i of capping the die:,x,.=Jc.~ an=:.:>.9 •. SiE~3 capping is not .:...,·
pe~anent remedial action, the Agency is required under Section _121 of SARA
to revisit the sit~ every five (5) years. This review is to assure that
human health and the environment are being protected and to consider the
remedy in light of new treatment technology developed during the interim.
This review process may result in the potentially responsible paities (PRPs)
conducting additional remedial action efforts at a later date.
The off-site areas of Buckeye Cove landfill and the landfill off of Highway
Route 70 are not part of the Chemtronics site. Ae you know, the Agency
compelled the PRPs to conduct limited investigative field work in these
landfills to determine if an imminent and substantial hazard existed.
Minimal contamination was found. Trace levels of cs were found at Buckeye
Cove landfill and large molecular organics, typically found in municipal
landfills, were found in the landfill off of Rt. 70. The level of CS in the
Buckeye Cove landfill was below the action level, the PPLV, set for this
contaminant in the ROD, Table 13. The· Agency for Toxic Substances and·
Disease Registry_reviewed the analytical data generated from this field work
and advised the Agency that neither the public nor the environment are at
risk due to the levels of contaminants --found in these landfills.
The third off-site. landfill, designated as Disposal Area 24 (DA-24) in the
Chemtronics RI and FS reports was also investigated as part of the
Chemtronics RI field work. Based on the analytical data generated from the
environmental samples collected from DA-2~, the Agency determined that DA-24
did not require remediation. The environmental samples included both surface
and subsurface soil samples.
If I can of be of further help, please do not hesitate to contact me at
[phone].
SincerelY y6urs,
Jon K. Bornholm
Superfund Project Manager
Enclosure
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APPENDIX G
Analytical Reaulta of Sampling Monitor
Well SW-4 On January 4, 1989
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U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV, ATHENS, GEORGIA
MEMORANDUM
DATE: FEB 06 1989
SUBJECT: Results of Sampling at Chem4ronics, Inc., Swannanoa, North
Carolina. ESD Project No. 89-194.
l't /j t,, I J • , J r.,,·,n, ... .1:~>..vn .• " ,.., .... , ', ,,. ' Jd..ln,a::S '-'• Vl:,;1,y /'It,.,,•-
TO:
Hazardous Waste'.-""Section
Environmental Compliance Branch
Environmental Services Division
Jon Bornholm
Superfund Branch
Waste Management Division
. I
THRU: M. D. Lair, Chief · l' t,~.
Hazardous Waste Section
Environmental Compliance Branc .
Environmental Services Division
As per your request of December 5, 1988, well SW-4 at the Chemtronics site in
Swannanoa,. North Carolina was sampled. Sampling was conducted on January 4, ·
1989. Present at the sampling was Beverly Ashbrook of Chemtronics to whom
split samples were given. The following data were collected during the ·
sampling and subsequent analysis.
• Well Sounding and Purging. Sounding of the well gave a depth to the
water of 9.20' below the top of the well casing. The total deprh of
the well was determined to be 53.23'~ leaving a water column of
44.03'. For a 2" diameter well this volume of water calculated out to
be 7.18 gallons, After 25 gallons of water had been purged from the
well, the sample was collected.
•pH.Conductivity and Temperature. At the time of the sample, the pH of
the groundwater was determined to be 5.85, the conductivity was 210
micromhos per square centimeter, and the temperature was 15 degrees
centigrade.
• Analytical Results. Final analysis of the sample gave a concentration
for benzylic acid of 48 micrograms per liter, and for benzophenone of
3400 micrograms per liter.
A copy of the analytical report is attached to this memo. Should you have
any questions regarding these results or should you require additional
information, please call me at FTS: 250-3589.
cc: Finger/Patton
Lair/Mundrick
Knight