NCD079044426_20040623_General Electric Co. Shepherd Farm_FRBCERCLA FYR_Five-Year Review-OCR

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NCDENR
•
North Carolina Department of Environment and Natural Resources
Dexter R Matthews, Director
Dr. Gary Hill
250 Old TyTy Road
Tifton, GA 31794-6607
Division of Waste Management
June 23, 2004
RE: Superfund Five-Year Review Report
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County, NC
Dear Dr. Hill:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has completed the Superfund Five-Year Review Report for the General
Electric/Shepherd Farm National Priorities List (NPL) Site. The Superfund Section offers the
attached document for your files.
If you have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachment
Sincerely,
·yJ_ J3tff;tb; €~11,'1
David B. Mattison, CHMM
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh. North Carolina 27699-1646
Phone [phone] \ FAX [phone] \ Internet http://wastenotnc.org
• An Equal Oppor1unity I Affirrna1ive _<l..ction :'.:11ployrH ~ Printed 011 Dual Purpose RecyclerJ Pc1per
• .=&;;~;:;_i .. ih •
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director
Mr. Bany Hallock
EHS Manager
GE Lighting Systems, Inc,
30 IO Spartanburg Highway
East Flat Rock, NC 28793
Division of Waste Management June 23, 2004
RE: Superfund Five-Year Review Report
General Electric/Shepherd Farm NPL Site
East Flat Rock, Henderson County, NC
Dear Mr. Hallock:
Michael F, Easley, Governor
William G, Ross Jr,, Secretary
.The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has completed the Superfund Five-Year Review Report for the General
Electric/Shepherd Farm National Priorities List (NPL) Site. The Superfund Section offers the
attached document for your files.
If you have any questions or comments, please feel free to contact me at [phone],
extension 349.
Attachment
Sincerely, ·y J"b t( ,;tta; ec .i ~,..
David B. Mattison, CHMM
"'"environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] \ FAX [phone] \ Internet http://wastenotnc.org
•\n Equal Opportunity I ,11.ffirmative .,'lction Emoloy~r -Printed on Dual Purpose Recycled Paper
ROD info
I of I
• • Subject: ROD info
Date: Tue, 27 Apr 2004 21 :36:06 -0400
From: "Stephanie Grubbs" <[e-mail]>
To: "'David & Mindy Mattison"' <[e-mail]>, <[e-mail]>
If you want to forward this to Michael please do.
As for the IC issue, I checked the ROD and it states:
1 . "Usage restrictions on capped areas" so we can change "propose" to "implement IC as per the ROD for capped
areas11
•
2. But I'm not to sure about groundwater ... it states, (pages 108 and 109 of the ROD) that '1he GW remedy, will
include GW extraction for 15 years and then the performance will be monitored on a regular basis and adjusted if
warranted" (etc, etc.) then it states '1o ensure clean-up continues to be maintained, the aquifer will be monitored at
those wells where pumping has ceased on an occurrence of at least every 2 years following discontinuation of GW
extraction" ... (etc. etc) then "if it is determined, on the basis of the preceding criteria and the system performance
data, that certain portions of the aquifer cannot be restored" .... then it suggests "IC may be provided/maintained to
restrict access to those portions of the aquifer which remain above remediation goals." Not sure if GW IC's can be
implemented until at least 15 years of GW extraction? Or until pumping is discontinued?
As for the GW remediation goals:
The ROD did have a summary table and it stated that the basis for goal of vinyl chloride was the "CRQL (NC MCL
0.015 ug/1)" and for PCE was "CRQL (NC MCL 0.7 ug/1)".
That's what I found out from the ROD, I'll talk with you about it tomorrow and decide what to change.
See you bright and early!
stephanie
12120/2004 5:07 PM
FW: GE/shcpard farm • •
I of I
Subject: FW: GE/shepard farm
Date: Tue, 27 Apr 2004 11 :37:59 -0400
From: [e-mail]
To: "Stephanie Grubbs" <[e-mail]>,
"Stephanie Grubbs" <[e-mail]>
Stephanie,
Here are Michael's comments. We played voice tag yesterday but he"s it and
has yet to contact me today.
Dave
>--Original Message --
>Date: Mon, 26 Apr 2004 13:48:11 -0400
>From: [e-mail]
>Subject: GE/shepard farm
>To: [e-mail]
>
>
>
>
>
>
>my comments are attached. I left a few comments in italics, that are
>more questions than comments
>
>
>
>
>
>(See attached tile: ge-my5yrcmts.wpd)
>
>Attachment: ge-my5yrcmts.wpd
>
David Mattison, CHMM
Environmental Engineer
NC DENR Superfund Section
Federal Remediation Branch
[phone] ext 349
~ ge-my5yrcmts. wpd
Name: ge-my5yrcmts.wpd
Type: WordPerfect 7 Document
(application/x-unknown-content-type-WP7Doc)
Encoding: base64
12/20/2004 5: 12 PM
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Specific Comments
vi, l.
Pg. vi, 3.
Pg. vi,4.
Pg. vii, Sum. Table
Pg. viii, 4.
Pg. I, 6th para. 2nd sen.
Pg. I, 6th para. 3"' sen.
Pg. 2, Table I, item 6.
Pg. 2, Table 1, item 7.
Pg. 2. Table 1, item 8
Pg. 2. Table 1, item 13
Pg. 3. Table 1, item 4
Pg. 3. Table I, item 8.
• •
GE/ Shepard Farm
Five Year Review Comments
If institutional controls are going to be a recommendation, the
recommendation should be specific to which controls should be put
in place and stated as a action. ( note. we should probably discuss
this recommendation to determine if we can actually accomplish
the goal)
Historically I don't think we have been changing the remediation
goals post ROD. I need to verify what is the policy for this.
I assume GE is discharging their production water to the POTW
currently. Are we concerned that there is a problem with the water
the POTW is accepting or we just needing verification that there is
not a problems.
Need new date for triggering action
It appears we are recommending evaluation of the situation, and
offering conclusions at the same time.
It appears that we are using the document we are currently
preparing as a justification reference for the trigger date selected.
"according to the five year ......... (PCOR)" should be deleted.
"The" should be replace with This.
Reference to landfi II B else where in the document suggest that
hazardous constituents were disposed of in landfill B.
Was the surface water discharge, the ponds or something else.
What was the treatment for the creek sediments.
What is a "listing" site inspection.
Was the Seldon Clark property found not to be contaminated.
Briefly state what the change was in the ESD.
• •
Pg. 3. Table I, item 15. Briefly state what the change was in the ESD.
Pg. 4., para 2. Can not discern on figure, the railroad tracks, creek, or the
highway. (Not sure this can be corrected)
Pg. 4., para 5. Could the 26 acres of landspread plots be contributing
contamination to the creek.
Pg. 7, para 1. Has the recreational area been certified safe to be used as such.
Pg. 10, para I. Is their a regulatory reference that can be included here as
confirmation that the USTs have been removed.
Pg. 14, para 2 Was the landfill areas backfilled after verification.
Pg. 14, para 3. Rephrase last sentence to reflect actually what happened. Or
simple state that excavation continued until the conformational
sampling verified the achievement of the remediation goal.
Pg. 15, para I. 3"' sent. "bio" should be inserted after in-situ.
Re: GE/Shepherd Fann NPL Site -5 Year Review. •
I of2
Subject: Re: GE/Shepherd Farm NPL Site -5 Year Review
Date: Thu, 22 Apr 2004 14:00:07 -0400
From: [e-mail]
To: [e-mail]
CC: Michael Townsend <[e-mail]>,
Samantha Urquhart-Foster <[e-mail]>,
Stephanie Grubbs <[e-mail]>, Stephanie Grubbs <[e-mail]>
Dave, Stephanie and Michael, attached are my comments on the 5-yr
review. As with anything, they are only suggestions.
Enjoy, Giezelle
(See attached file: Syrreviewcomments.wpd)
DAVID.MATTISON@nc
mail.net
Townsend/R4/USEPA/US@EPA
To: Michael
cc: David Lown
<[e-mail]>, Giezelle
04/15/2004 10:39
AM
Bennett/R4/USEPA/US@EPA, Samantha
Urquhart-Foster/R4/USEPA/US@EPA,
Stephanie Grubbs
Stephanie Grubbs
Please respond to
david.mattison
<[e-mail]>,
<[e-mail]>
Subject: GE/Shepherd Farm NPL Site -
5 Year Review
Michael,
Please find attached the text portion of the Five-Year Review Report for
the GE/Shepherd Farm NPL Site. A complete hard copy was sent via
overnight
carrier yesterday afternoon. I realize that this is on a very short
turnaround,
but if we could get comments from you by phone or email by Wednesday
(4/2l)morning,
I believe that the document can be safely revised and returned for
signature
by the April 26 deadline.
Two items of note:
1. Photo documentation will be included in final copy.
2. I still need a firm trigger date and justification for its use. I
thought
that we had it nailed but Giezelle indicated that maybe we don't.
Please feel free to contact me if you have any comments or questions.
Thanks for your help,
12/20/2004 5:05 PM
Re: GE/Shepherd Farm NPL Site - 5 Year Review. • (
2 of2
Dave
David Mattison, CHMM
Environmental Engineer
NC DENR Superfund Section
Federal Remediation Branch
I 919 I 733-2801 ext 349
(See attached file: Syr GE rnsword.doc)
~ Syrreviewcomments. wpd
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1 5 GE ·d d Type: Winword File (application/msword) yr msw01 . oc E d" b 64 •nco mg: ase
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12/20/2004 5:05 PM
'
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
• •
GE 5-yr Review Comments
It is stated in the Executive Summary and elsewhere in the document that since
the quantitation limits for PCE and vinyl chloride have changed that the
remediation goal should also change. Please check with the attorney on this. In
the past, we have not lowered remediation goals, especially on PRP-lead sites
where we have a signed CD, because the PRP could argue that we are asking
them to meet a moving target.
Site Chronology -Generally this table only includes EPA actions or actions that
are in CERCLIS -it starts with site discovery, and includes things like the PA, SI,
NPL listing, etc. This table seems too detailed and a lot of it is based on
assumptions.
In Section 3.2, need to include the word "residential". Does "rural" imply
residential?
In Section 4.2 under Landfill A, last paragraph, first sentence -Please change to
"A total of 11,698 cubic yards of material were excavated from Landfill A."
In Section 4.2 under OSI, need to include Shepherd Farm soils in the first
sentence.
In Section 4.2, the second paragraph under Groundwater -The remedial action
was not initiated with the construction of the AGRS. GE constructed it on their
own prior to the RI/FS. It was merely modified for the remedial action.
In Section 4.2, the second paragraph under Groundwater, last sentence -The
effluent air is not sampled to ensure POTW requirements are met.
In Section 4.2, the last paragraph under Groundwater, first sentence -The
groundwater pump and treat system was only considered the AGRS until the
ROD was signed. After that date, it was the GRS -groundwater remediation
system.
In Section 4.3, 4th bullet, Add the following to the end of the second sentence -
"and to ensure that residents are not drinking contaminated water in their private
well."
In Section 5.1, add the word "Review" between "Year'' and "Report" in the last
line.
In Section 5.5, under Soil -Pre-remedial data usually refers to PA or SI data, not
data before the remedial action, i.e., RI data.
• •
' 12. Under Final Remedial Action Report for Soil, need to add that confirmation
sampling was also performed to determine if the top foot of soil was PCB-free at
Shepherd Farm.
13. Under site inspection, need to include the names of the NC DENR personnel.
14. In the Site Inspection section, metals that are above NC standards are
mentioned. These metals need to be specified; their concentration, the NC gw
standard, the remediation goal, and the POTW standard.
15. In Section 8 -How is GE the party responsible for institutional controls at the
Shepherd Farm Site?
16. Note -In previous 5-yr reviews, the O&M costs for the last 5 years are specified.
Since the tables and figures are not included in this draft, there is no way to
determine if this information is included.
17. Note -There are a number of typos that need correcting.
Five Year Review Comments • •
I of I
Subject: Five Year Review Comments
Date: Wed, 21 Apr 2004 17:43: 10 -0400
From: "Todd Hagemeyer" <[e-mail]>
To: <l)[e-mail]>
CC: "David Buchalter" <[e-mail]>,
"Patricia Hermann" <[e-mail]>, <[e-mail]>
Dave,
On behalf of GE, attached please find comments on the Draft Five Year Review Report. If you have any
questions, please contact Barry Hallock (828-693-2148), Trish Hermann or me.
Thanks,
Todd
Todd Hagemeyer, P.O.
GeoTrans, Inc.
1080 Holcomb Bridge Road
Building 100, Suite 190
Roswell, GA 30076
770-642-1000, x-102 office
770-642-8808 fax
404-219-7531 cell
Name: Comments on the Draft Five Year
Review.doc
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12/20/2004 5:05 PM
• •
Comments on the Draft Five Year Review
General Electric/Shepherd Farm Superfund Site
General Comments:
1. The former Sheldon Clark Subsite was deleted by EPA and is therefore not relevant to the
remedial action and five year review. All references to the Sheldon Clark Subsite should be
deleted from the report.
2. The site description in Section 3 is outdated and incorrectly describes historic features and
operations as present day features and operations. This section needs to be modified to
reflect current conditions. Please refer to Section 1.1.1 of the Final Groundwater Remedial
Design Report (GeoTrans, 2000) for a more current description of the site conditions.
3. One of the recommendations in the Five Year Review is for GE to implement institutional
controls. Note that GE can assist in the implementation of the institutional control, but does
not have the mechanism to implement controls on property of other landowners, such as the
Spring Haven community. This recommendation should be deleted or modified to reflect this
comment.
4. One of the recommendations in the Five Year Review is for GE to abandon the residential
well at the former Womack residence. Similar to General Comment 3, GE can assist in the
implementation of such action, but GE is not the property owner and is not responsible for the
residential well. This recommendation should be deleted or modified to reflect this comment.
5. Figures were not available for review.
Specific Comments:
1. Page 4, Section 3.1, Paragraph 3. The report states that a guard is on duty at all times. The
current security schedule is as follows: A security guard is on duty from 4 PM - 8 AM on all
business days and 24 hours on non-business days. From 8 AM - 4 PM on business days a
receptionist is on duty who oversees the security system.
2. Page 4, Section 3.1, Paragraph 4. The report states that the plant includes a chlorine building.
Chlorine is no longer used at the facility and the chlorine building has been converted into an
oil storage building.
3. Page 4, Section 3.1, Paragraph 5. Landfill A should be referred to as former Landfill A.
Landfill A has been excavated.
4. Page 4, Section 3.1, Paragraph 5. The report states that there is a landspreading area. GE has
not used the back lot for landspreading in many years and the area should not be referred to
as such as the practice no longer occurs. The area referenced is an open grassy field that was
formerly used for landspreading.
5. Page 4, Section 3.1, Paragraph 5. The report states that there is an inactive sludge pond. The
inactive sludge impoundment is now the landfill and should not be referred to as a sludge
impoundment.
C:\TEMP\Comments on the Draft Five Year Review.doc
12/20/2004
• •
6. Page 4, Section 3.1, Paragraph 5. The report states that southeast of the warehouse is an
active wastewater treatment pond. This is not a true statement. The pond is not an active
wastewater treatment pond. It was used as such in the past but is currently used for
stormwater.
7. Page 4, Section 3.1, Paragraph 5. The report states that there is an underground drain line
used for transport of wastewater. This is not a true statement. The underground drain line
was formerly used to transport wastewater, but now conveys stormwater.
8. Page 4, Section 3.1, Paragraph 5. The report states that there is an active landfill for
construction debris. This feature is no longer present.
9. Page 7, Section 3.1, Paragraph I. The report refers to a I-acre wastewater pond. This is not
a true statement. The small pond conveys stormwater.
10. Page 7, Section 3.1, Paragraph I. Landfill B should be referred to as former Landfill B.
Landfill B has been excavated.
11. Page 7, Section 3.1, Paragraphs 3-5. The Seldon Clark Subsite is not part of the
GE/Shepherd Farm Site and does not need to be described in this report.
12. Page 7, Section 3.1, Paragraphs 4-5 and Page 9, Section 3.1, Paragraph I. These paragraphs
include a general description of site location, topography, geology, and hydrogeology and
should be inserted after the first paragraph of Section 3.1, or provided as a separate
subsection.
13. Page 9, Section 3.1, Paragraph I. There is no information about wetlands in the surface water
section. Since the remedy design accounted for impacts to wetlands, it would be appropriate
to add a description of the wetland and bunched arrowhead in this section.
14. Page 9, Section 3.3, Paragraph 2. There is no mention of the excavation and removal of PCB
material from Landfills A and B nor backfill with clean material before any paving occurred.
These should be referred to as former landfills for clarification. A reference to these landfills
being excavated would be appropriate in this section.
15. Page 10, Paragraph 2. The paragraph describes the history of the Shepherd Farm property.
Please add the fact that Mr. Shepherd operated a disposal company at the property.
16. Page 13, Section 4.2, Paragraph I. Please change the word consists to consisted in the first
sentence.
17. Page 14, Section 4.2, Paragraph 2. Please change yard to yards and was to from in the first
sentence.
18. Page 14, Section 4.2. Paragraph 3. Please revise the last sentence to state that the cleanup
criteria of 10 ppm total PCBs was achieved using confirmation sampling.
19. Page 14, Section 4.2, Paragraph 5. Please revise the paragraph to make it clear that all soils
from the Shepherd Farm Site were added to the OSI.
C:\TEMP\Comments on the Draft Five Year Review.doc
12120/2004
2
' J
• •
20. Page 15, Section 4.2, Paragraph 3. No water goes through GAC and it does not effect the
treatment of the water in anyway. The release of carbon and accumulation of water in the
VGAC may have reduced the removal efficiency of the VGAC for the air effluent from the
air stripper. Please revise accordingly.
21. Page 16, Section 4.2, Paragraph 2. The report describes the AGRS, which was installed and
operated prior to the GRS. Operation of the GRS should be added.
22. Page 16, Section 4.2, Bullet 5. There are 6 surface water stations.
23. Page 21, Section 5.5, Paragraph l. Please revise the paragraph to make it clear that all of the
data discussed and included in the tables and figures is RI data and therefore historic data.
24. Page 21, Section 5.5, Paragraph 2. Groundwater sampling is now done on a semi-annual
basis (March and September). Treatment system sampling continues to be performed
quarterly (December, March, June and September). Revise accordingly.
25. Page 34, Section 5.5, Paragraph 5. Please remove the information regarding the Seldon Clark
Subsite as it is not part of the Site.
26. Page 46, Section 5.5, Paragraph 2. Please include a completion date for the Final Remedial
Action for Soil. The Remedial Action of Shepherd Farm Soil Revised Final Report was
approved by the EPA on January 8, 1999. The Final Remedial Action for Soil at the GE
Subsite was approved by the EPA on October 4, 2000.
27. Page 55, Section 5.6, Bullet 2. Please revise first sentence to state "the low water level
alarms."
28. Page 55, section 5.6, Bullet 2. Please change lend to lends.
29. Page 55, Section 5.6, Paragraph l. This paragraph should be revised as follows. "Three
additional items were noted during the interview process. The first was regarding the
treatment of metals. Extracted groundwater is treated for VOCs, used in the GE facility,
treated for metals with other process water, and discharged to the POTW. Of the five metal
RTCs, only manganese concentrations exceed the North Carolina groundwater standards in
the extracted groundwater and none of the metal concentrations exceed the POTW limit.
Therefore, treatment of the groundwater for metals is unnecessary and GE intends to seek
approval from the POTW to discontinue metals treatment of the extracted groundwater."
This verbage should be reflected in the Executive Summary (page viii).
30. Page 56, Section 6.1, Paragraph 2. Please note that the carbon unit in no way affects the
removal of VOCs and SVOCs from the groundwater. All effluent water concentrations have
been non-detect. The carbon unit only affects the removal of RTCs from air effluent from the
airstripper.
C:\TEMP\Comments on the Draft Five Year Review.doc
12120/2004
3
R~: GE/Shepherd Farm NPL Site - 5 Year Review. • '
I of 3
Subject: Re: GE/Shepherd Farm NPL Site - 5 Year Review
Date: Mon, 19 Apr 2004 13:20:31 -0400
From: [e-mail]
To: [e-mail]
CC: Michael Townsend <[e-mail]>,
Stephanie Grubbs <[e-mail]>, Stephanie Grubbs <[e-mail]>
Michael, Dave & Stephanie. I have reviewed the GE/Shepherd Farm draft
Five Year Review Report that you submitted via e-mail on 4/15/04 (no
figures, attachments and few tables). I am providing comments based on
clarity and consistency regarding the Five Year Review process guidance.
My review did not evaluate any technical aspects of the report. See
below for my 10 comments ...
1. The document needs to include a signature page.
2. Five Year Review Summary Form -The form indicates that there are
multiple OUs. However, only one OU is identified in WasteLAN and the
ROD. Therefore, please change the answer to multiple OU question from
yes, to No.
3. Five Year Review Summary Form -Include a date for Construction
Completion or insert "N/A"
4. Introduction, last paragraph on page -Because what's stated in the
PCOR isn't correct, change the second sentence to, "The triggering
action for this statutory review is the date construction activities
first began at the Site in relation to the Remedial Action.11
5. Site Chronology -Is the date for "Final Remedial Action for soil
contamination at the GE Subsite" the completion date or start date?
Please clarify and add a line item for the start date (if this is the
completion date), since there seems to be confusion regarding the
accurate trigger date.
6. Executive Summary, Five Year Review Summary Form, and Section 7.0 -
The Issues sections talk about clean-up levels for PCE and vinyl
chloride. The values listed in those sections, 0.7 ug/L PCE and 0.5
ug/L vinylchloride do not match the concentrations found in Table 2, ROD
cleanup goals. However, I later read in section 5.4 that these values
are the ones that would be consistent with current ARARs/detection
limits, not ROD clean-up values. Please clarify these sections to
reflect ROD established clean-up values versus current ARARs. For
example, instead of saying "3. It is now technically possible to obtain
lower quantitation limits in water samples for two site specific
compounds, tetrachloroethene (PCE) and vinyl chloride. Therefore,
clean-up goals of 0.7 ug/1 for PCE and 0.5 ug/1 for vinyl chloride
should be changed to reflect these new values." A clearer wording would
be, "3. It is now technically possible to obtain lower quantitation
limits in water samples for two site specific compounds,
tetrachloroethene (PCEI and vinyl chloride. Therefore, the clean-up
goals for PCE and vinyl chloride should be changed to reflect current
ARARs to the extent that detection limits allow. This would change the
ROD established clean-up goal of PCE from 1 ug/L to 0.7 ug/1 (state
ARARI and the ROD established cleanup goal of vinyl chloride from 1 ug/L
to 0.5 ug/1 (current detection limit, which is higher than state ARAR of
0 .15 ug/L)."
7. Section 5.2 -
through newspaper
to a few people?
state so here.
Was the community notified about the 5YR process
ad, fact sheets, etc or just through telephone calls
If a fact sheet or other media ad was used, please
8. Section 5.6 -Include any state or federal representatives in the
bullet list of participants in the Site inspection.
9. Sections 5.6 and 6.1 -You discuss O&M of the groundwater system,
12/20/2004 5:05 PM
R~: GE/Shepherd Farm NPL Site -5 Year Review. •
2 of 3
but what about the DSI cap? Are there any O&M activities associated
with it? Does it appear to be in good shape?
10. Section 10.0 -Because of uncertainties regarding when this report
will actually be signed and because you listed it due in 4 years, unless
you intend to do a review sooner than required, replace this section wit
h, "The next Five-Year Review for the GE/Shepherd Farm site is required
to be completed within five years from the EPA Region 4 Waste Management
Division Director's (or his designee) signature/approval date of this
document."
Thanks for the opportunity to review!
Samantha
DAVID.MATTISON@nc
mail.net
Townsend/R4/USEPA/US@EPA
To:
cc:
Michael
David Lown
<[e-mail]>, Giezelle
04/15/2004 10:39
AM
Bennett/R4/USEPA/US@EPA, Samantha
Urquhart-Foster/R4/USEPA/US@EPA,
Stephanie Grubbs
Stephanie Grubbs
Please respond to
david.rnattison
<[e-mail]>,
<[e-mail]>
Subject: GE/Shepherd Farm NPL Site -
5 Year Review
Michael,
Please find attached the text portion of the Five-Year Review Report for
the GE/Shepherd Farm NPL Site. A complete hard copy was sent via
overnight
carrier yesterday afternoon. I realize that this is on a very short
turnaround,
but if we could get comments from you by phone or email by Wednesday
(4/21)morning,
I believe that the document can be safely revised and returned for
signature
by the April 26 deadline.
Two items of note:
1. Photo documentation will be included in final copy.
2. I still need a firm trigger date and justification for its use. I
thought
that we had it nailed but Giezelle indicated that maybe we don't.
Please feel free to contact me if you have any comments or questions.
Thanks for your help,
Dave
David Mattison, CHMM
Environmental Engineer
NC DENR Superfund Section
Federal Remediation Branch
( 919) 733-2801 ext 349
12/20/2004 5:05 PM
Re: GE/Shepherd Farm NPL Site - 5 Year Review.
'
◄ (See attached file: 5yr GE msword.doc)
Name: 5yr GE msword.doc
•
rs.5 . GE ·d d Type: Winword File (application/msword) 8!:I y, mswo1 . oc E d" b 64 ·-nco mg: ase
Download Status: Not downloaded with message
3 of3 12/20/2004 5:05 PM
Re: Trigger Date for GE/Shepherd Fann NPL Site -ar Review • Subject: Re: Trigger Date for GE/Shepherd Farm NPL Site 5-Year Review
1 Date: Wed, 14 Apr 2004 10:26:02 -0400
I of3
From: [e-mail]
To: [e-mail]
CC: [e-mail], Michael Townsend <[e-mail]>,
Stephanie Grubbs <[e-mail]>, Stephanie Grubbs <[e-mail]>
I thought I remembered seeing that memo a year or so ago, but couldn't
find it in my files and couldn"t remember what it said. So if someone
happens to find the memo in the file ...
Giezelle Bennett
Urquhart-Foster/R4/USEPA/US@EPA
04/13/2004 02:34
Michael
PM
Grubbs
GE/Shepherd Farm NPL Site
Urquhart-Foster)
To: Samantha
cc: [e-mail],
Townsend/R4/USEPA/US@EPA, Stephanie
<[e-mail]>, Stephanie Grubbs
<[e-mail]>
Subject: Re: Trigger Date for
5-Year Review(Docurnent link: Samantha
I remember writing a memo to the file and to HQ detailing the reason why
the 5-yr review was not due in 2002 as stated in the PCOR, but I cannot
find it on my computer. It is in the file somewhere. But the 4/26/99
date is the only one in CERCLIS. There are two RAs in CERCLIS; the GE
landfill and the pump-and-treat system. So, if you go back and use the
1997 date, the file will really be arbitrary.
Anyway, that's my 2 cents worth.
Giezelle
Samantha
Urquhart-Foster
<[e-mail]>, Giezelle
04/09/2004 11:20
Townsend/R4/USEPA/US@EPA,
AM
Stephanie Grubbs
GE/Shepherd Farm NPL Site
Bennett)
To: [e-mail]
cc: David Lown
Bennett/R4/USEPA/US@EPA, Michael
Stephanie Grubbs <[e-mail]>,
<[e-mail]>
Subject: Re: Trigger Date for
5-Year Review(Docurnent link: Giezelle
12/20/2004 5:06 PM
Re: Trigger Date for GE/Shepherd Fann NPL Site .ar Review •
2 of 3
Hi Dave. The 4/26/04 date came from the earliest RA start date entered
in WasteLAN/CERCLIS (4/26/99). CERCLIS was HQs and EPA management's
primary source for tracking tool on when reports are due. I've come to
realize that that may not be the most accurate source. The 1997 dates
that you mentioned aren't in CERCLIS. The National Contingency Plan
(NCP) (40 CFR §300.430(f) (41 (iii I states: "If a remedial action is
selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited
use and unrestricted exposure, the lead agency shall review such action
no less often than every five years after the initiation of the selected
remedial action.' EPA HQ recommends using the date of on-site
construction (i.e. mobilization date), which is typically later than the
contract award date. So it looks like October 14, 1997 would be the
trigger date if this is a statutory review, as seemed to be indicated by
the PCOR language that you mentioned. So, unless Giezelle or Michael
have more site-specific insight, I would recommend using October 14,
1997 as the trigger date if that is the date of the "initiation of the
selected remedy11 •
Samantha
DAVID.MATTISON@nc
mail .net
Townsend/R4/USEPA/US@EPA, Samantha
04/08/2004 10:14
<[e-mail]>, Giezelle
To: Michael
Urquhart-Foster/R4/USEPA/US@EPA
cc: David Lown
AM Bennett/R4/USEPA/US@EPA, Stephanie
Grubbs
Stephanie Grubbs
Please respond to
david.mattison
<[e-mail]>,
<[e-mail]>
Subject: Trigger Date for GE/Shepherd
Farm NPL Site 5-Year
Review
Michael/Samantha,
I hate to bring this topic up again but I feel that EPA needs to make
the
call regarding the official trigger date for the GE/Shepherd Farm NPL
Site.
The Preliminary Close-Out Report (Sep 2000) states that the trigger date
was "five years after the award of the first RA contract and was to be
completed
prior to November 2002." I have contacted GeoTrans, GE's consultant, to
determine the actual award date for the contract for soil remediation
activities
at Shepherd Farm. This date is likely between August and October 1997.
Additionally, October 14, 1997 is the date on which remedial action
began
with soil excavation activities at the Shepherd Farm Subsite.
12/20/2004 5:06 PM
Re: Trigger Date for Gr/Shepherd Farm NPL Site .ar Review •
3 of3
Regardless of which of the above trigger dates is used, the 5-Year
Review
is considerably late. Do we have a source for the April 26, 2004
submittal
date or was that data arbitrarily picked by Phil V? What date would EPA
prefer that NC DENR include in the 5-Year Review Report?
Thank you for your assistance,
Dave
David Mattison, CHMM
Environmental Engineer
NC DENR Superfund Section
Federal Remediation Branch
[phone] ext 349
12/2012004 5:06 PM
RE: Trigger Date • •
I of I
Subject: RE: Trigger Date
Date: Wed, 7 Apr 2004 22:10: 18 -0400
From: "Stephanie Grubbs" <[e-mail]>
To: <[e-mail]>
Hey Dave,
The trigger date stated in the PCOR was "five years after the award of the
first RA contract and was to be completed prior to Nov. 2002". I couldn't
get in touch with Giezelle and could not find the date of the award of the
contract for the RA or what she thought the trigger date was. Next week I
can call the contractor and find out from them what the award date was. The
date in Table 1, Oct. 14, 1997, is the actual start of the RA at the
Shepherd Farm site, it was the beginning of the residential relocation and
excavation began on that date too (stated in the RA of Shepherd Farm Soil
Report, Sept 1998).
Glad the day went well--I'm so sorry that you had such a long day (lots of
comp time I guess). Thanks for getting me all the info so quick! I got
Diane"s fax and she said there were no concerns. But she thought that
instead of just attaching the info that it should be summarized in the text
of the report and interview pages added in an Attachment. Also she added
that once the review if final, Dr. Gary Hill wants a copy sent to him(?).
He sounds really mad in her interview (spoke of legal action against EPA
when 10 year waiver has ended).
Thanks and I'll talk with you soon--probably Monday and I think I might come
in on Tues to get your comments on the last draft and the new stuff and let
you read over things (hopefully) one last time before we send the draft out.
Stephanie
-----Original Message-----
From: [e-mail] [mailto:[e-mail]]
Sent: Wednesday, April 07, 2004 11:51 AM
To: Stephanie Grubbs; Stephanie Grubbs
Subject: Trigger Date
Stephanie,
What was the actual trigger date given in the PCOR? And it was the date
of the award of the contract to the RA contractor, right? Now, what is the
source of the Oct 14, 1997 given in Table l? Is it the actual date that
the soil RA began at Shepherd Farm (i.e., mobilization, set up, first
shovel-full ... )?
The trip went well.
around 9. Ouch. It
written but I should
Thanks,
Dave
Long
will
have
David Mattison, CHMM
Environmental Engineer
NC DENR Superfund Section
Federal Remediation Branch
( 919 I 733-2801 ext 349
day though. Left the house at 5 am and got back
take me a little while to get the summary reports
it done by tomorrow COB.
12/20/2004 5:06 PM
• •
OSWER No. 9355. 7-03B-P
Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term
Response Actions are in progress, O&M activities may be referred to as "system operations" since
these sites are not considered to be in the O&M phase while being remediated under the Superfund
program.
Five-Year Review Site Inspection Checklist (Template)
(Working document for site inspection. Information may be completed by hand and attached to the
Five-Year Review report as supporting documentation of site status. "NI A" refers to "not applicable.")
I. SITE INFORMATION
Site name: t:... r: /5,.,.,0>1E.~ Cp,11,.,. Date of inspection: A/,_ /oL;-
. . lf.A':,-Y-Fi.A-r fl-~r..,.__ ,J,C.. , ' Location and Region: ,,.;,. l.~io , A ' EPA ID:
Agency, office, or company leading the five-year Weather/temperature:
review: •le_ .-n -. •" s..,,_. .,, ~ <""o·~~ ,t,,_~ ... ,: ---10·~!""! ,
Remedy /Lludes: (Check all that apply)
Landfill cover/containment Monitored natural attenuation
/Access controls Groundwater containment
v'fnstitutional controls Vertical barrier walls
/Groundwater pump and treatment
Surface water collection and treatment
Other
Attachments: Inspection team roster attached Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M site manager
Name Title Date
Interviewed at site at office by phone Phone no.
Problems, suggestions; Report attached
2. O&M staff
Name Title Date
Interviewed at site at office by phone Phone no.
Problems, suggestioris; Report attached
D-7
• •
OSWER No. 9355. 7-03B-P
3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices, etc.) Fill in all that apply.
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
4. Other interviews ( optional) Report attached.
D-8
• •
OSWER No. 9355.7-03B-P
1.
lll. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
O&M Documents
O&M manual
As-built drawings
Maintenance logs
Readily available~
Readily available~
Readily available
Up to date/
Up to date /
Up to date ✓
NIA
NIA
NIA
Remarks ________________________________ _
2. Site-Specific Health and Safety Plan Readily available7 Up to date ✓ N/A
mg ency plan/emergency response plan Readily available ,,· Up to date.:/" NI A
s G..C l\o\O. 1 .... ~, .u '> f, '-:%,-~ ~on_ (., tc:.._ '7"t:L\t a:vt,16 L-
i/ O&M and OSHA Training Records Readily available ..,,,,,,. Up to date / NIA l __ Remarks, ________________________________ _ ,,
4. Permits and Service Agreements
Air discharge permit Readily available
Effluent discharge Readily available
Waste disposal, POTW Readily available ./_,,
Other permits R,yv >'Ee,._ , rs. Readily available _,,,
Up to date NIA/
Up to date NIA /
Up to date / _,Ni A
Up to date __,., N/A
Remarks ,S.,N D [,,,.,,., o u ,J 'l) ,..., , -b ~ c,J -Ii) N tQ__
5. Gas Generation Records Readily available Up to date NIA/
Remarks
6. Settlement Monument Records Readily availableilf(./' Up to date NIA/
Remarks
7. Groundwater Monitoring Records Readily available ✓ Up to date / NIA
Remarks
/
8. Leachate Extraction Records Readily available Up to date NIA./
Remarks
9. Discharge Compliance Records
~NIA Air Readily available ~ Up to date
Water (effluent) Readily available Up to date NIA
Remarks
IO. Daily Access/Security Logs Readily available . ./ Up to date ./ NIA
Remarks
D-9
.
• •
OSWER No. 9355. 7-03B-P
IV, O&M COSTS
I. O&I\.1 Organization •
State in-house Contractor for State/,
PRP in-house Contractor for PRP G ,r <:!/£A,,v ~
Federal Facility in-house Contractor for Federal Facility
Other
2. O&M Cost Records
Readily available Up to date
Funding mechanisrrv'agreement in place
Origi~al O&M cost estimate Breakdown attached
Total annual cost by year for review period if available VA Ovu Is.
From To Breakdown attached
Date Date Total cost
From To Breakdown attached
Date Date Total cost
From To Breakdown attached
Date Date Total cost
From To Breakdown attached
Date Date Total cost
From To --Breakdown attached
Date Date Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons:
V, ACCESS AND INSTITUTIONAL CONTROLS /4pplicable NIA
A. Fencing
I. --1'encing damaged Location shown on site map Gates secured / NIA
Remarks NE.-> $(C'1 V f(. t "f't_ MCP-SV1t.,~> -:::t::)l~cJ V ~t.-to,rf' 7<A,.J--,
B, Other ,;ccess Restrictions
I. !s'igns and other security measures Location shown on site map NIA
Remarks
D-10
• •
OSWER No. 9355. 7-03B-P
C. Institutional Controls (!Cs)
I. Implementation and enforcement ✓
Site conditions imply ICs not properly implemented Yes No/ NIA
Site conditions imply !Cs not being fully enforced Yes No/ NIA
Type of monitoring (e.g., self-reporting, drive by) ·ne \,/£_ -..✓
Frequency -..., ·-J i. ............... '~l."'-'-'1'u.r----J ..-!.A-,.J t~ •• • •(,
Responsible party/agency C,,1=. (p £..o ~ ~' Tn...l~~
Contact 'l:>~!l•O ~Dl;;~o:!J
I
Name Title Date Phone no.
Reporting is up-to-date Yes/ No NIA
Reports are verified by the lead agency Yes/ No NIA
Specific requirements in deed or decision documents have been met Yes No1NIA
Violations have been reported Yes No NIA
Other problems or suggestions: Report attached
"):E.C..t:!! ~C.'i.-;-t?..., t-0-0,....Si clQ"! ,~e.'--E:~:J:c!:r:l~
• "-~ c...o g.Q ~ ~,J
2. Adequacy I Cs are adequate ICs are inadequate / NIA
Remarks C--~ .d'I
D. General
I. Vandalism~spassing Location shown on site map No vandalism evident /
Remarks v .-l C..
2. Land use c~rnges on site NIA
Remarks ... <J
3. Land use c,'.ianges off site NIA
Remarks .o
VI. GENERAL SITE CONDITIONS ,
A. Roads vJ½,plicable NIA
I. Roads damaged Location shown on site map Roads adequate / NIA
Remarks
D-11
• •
OSWER No 9355 7-0JB-P
B. Other Site Conditions .
Remark-r'\ v -" • · • ,,_ .. G. c -o ,. , ·Pe... ~-G r.o 1> LL_ ,,5~1,,!£ ,;..o,,.; l...,,
'
VII. LANDFILL COVERS .. /4plicable NIA
A. Landfill Surface
I. Settlement (Low spots) Location shown on site map Settlement not evident ./·
Areal extent. _____ _ Depth, ____ _
Remarks, ______________________________ _
2. Cracks Location shown on site map Cracking not evident /
Lengths, ____ _ Widths, ____ _ Depths, ____ _
Remarks, ______________________________ _
3. Erosion Location shown on site map Erosion not evident ✓
Areal extent,______ Depth,_~---
Remarks Su t..,,., r -Mo,.,1,,-,1,, ( "5,:,Hc:,
4. Holes Location shown on site map Holes not evident /
Areal extent, _____ _ Depth, ____ _
Remarks, ________________________________ _
5. Vegetative Cover Grass / Cover properly established / No signs of stress
Trees/Shrubs (indicate size and locations on a diagram)~ ) .J .Pe:;,.)
Remarks TI-'Yald'<L Mow Id b, ('2,.X -..,__..---r OVUSZ:£..o ,,JC:..
~UA 1..-L-A..o"t) ~ ... l '--'
6. Alternative Cover (armored rock, concrete, etc.) NIA_/
Remarks, ________________________________ _
7. Bulges Location shown on site map Bulges not evident _.,....,-·
Areal extent, _____ _ Height, ____ _
Remarks, ________________________________ _
D-12
• •
OSWER No. 9355. 7-03B-P
8. Wet Areas/\Vater Damage Wet areas/water damage not evident /
Wet areas Location shown on site map Areal extent
Ponding Location shown on site map Areal extent
Seeps Location shown on site map Areal extent
Soft subgrade Location shown on site map Areal extent
Remarks
9. Slope Instability Slides Location shown on site map No evidence of slope instability"" v
Areal extent
Remarks
B. Benches Applicable/ NIA
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
I. Flows Bypass Bench Location shown on site map NIA or okay/
Remarks
2. Bench Breached Location shown on site map ~orokay
Remarks
3. Bench Overtopped Location shown on site map @rokay
Remarks
..
C. Letdown Channels Applicabl,/Ajf/ NI A ✓
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep
side slope of the cover and will allow the runoff water collected by the benches to move off of the
landfill cover without creating erosion gullies.)
I. Settlement Location shown on site map No evidence of settlement./
Areal extent Depth
Remarks
2. Material Degradation Location shown on site map No evidence of degradation ./
Material type Areal extent
Remarks
3. Erosion Location shown on site map No evidence of erosion ~·
Areal extent Depth
Remarks
D-13
• •
OSWER No. 9355.7-03B-P
4. Undercutting Location shown on site map No evidence of undercutting /
Areal extent Depth
Remarks
5. Obstructions Type No obstructions ./
Location shown on site map Areal extent
Size
Remarks
6. Excessive Vegetative Growth ·Type
No evidence of excessive growth
Vegetation in channels does not obstruct flow
Location shown on site map Areal extent
Remarks
I
D. Cover Penetrations Applicable ../ NIA /
I. ~Vents Active /Passive 7
Good condition / roperly secured/locked Functioning Routinely sampled
Evidence of leakage at penetration Needs Maintenance
NIA
Remarks
2. Gas Monitoring Probes
Properly secured/locked Functioning Routinely sampled Good conditio/
Evidence of leakage at penet.ration Needs Maintenance NI A
Remarks
3. Monitoring Wells (within ~ace area ofland~ll) ~ /
Properly secured/locked Functioning /Routinely sampled Good condition
Evidence of leakage at penetration Needs Maintenance NIA
Rematl<s ,J E.v..,.... cc.,.--r u u,,,-A• -°SA~L.C,__~ RA, ... ,,.,1, n,n---:;:i::: ,-.,cr, ... rl,d c r .... , n.,,. I.a.., Vl,""'4' <I J/ cH , 0 '1 I Ir t ~
~
4. Leachate Extraction Wells
Properly secured/locked Functioning Routinely sampled Good conditio:,....-----
Evidence of leakage at penetration Needs Maintenance NIA
Remarks
5. Settlement Monuments Located Routinely surveyed NIA/'
Remarks
D-14
• •
,,.... OSWER No. 9355. 7-038-P
E. Gas Collection and Treatment Applicable NIA
I. Gas Treatment Facilities
Flaring Thennal destruction Collection for reuse
Good condition Needs Maintenance
Remarks
2. Gas Collection Wells, Manifolds and Piping
Good condition Needs Maintenance
Remarks
3. Gas Monitoring Facilities (e.g., gas monitoring of adja~ent homes or buildings)
Good condition Needs Maintenance NIA
Remarks
F. Cover Drainage Layer Applicable/ NIA~
I. Outlet Pipes Inspected Functioning NI✓
Remarks
2. Outlet Rock Inspected Functioning ../ NIA
Remarks
,
G. Detention/Sedimentation Ponds Applicable ._,/' NIA
I. Siltation Areal extent Depth NIA
Siltation not evident .7'
Remarks
2. Erosion Areal extent Depth
Erosion not evident ./
Remarks
3. Outlet Works Functioning/ NIA
Remarks
,
4. Dam Functioning/ NIA
Remarks
D-15
• •
OSWER No. 9355. 7-03B-P ,'
H. Retaining \Valls Applicable NIA
1. Deformations Location shown on site map Deformation not evident
Horizontal displacement Vertical displacement
Rotational displacement
Remarks
2. Degradation Location shown on site map Degradation not evident
Remarks
I. Perimeter Ditches/Off-Site Discharge Applicable_,-NIA
1. Siltation Location shown on site map Siltation not evident
Areal extent Depth
Remarks
2. Vegetative Growth Locatio~ on site map NIA
Vegetation does not impede flow
Areal extent Type
Remarks
3. Erosion Location shown on site map Erosion not evident ._,/"
Areal extent Depth
Remarks
4. Discharge Structure Functioning--••··t:u A
Remarks
VIII. VERTICAL BARRIER WALLS Applicable NIA _./
I. Settlement Location shown on site map Settlement not evident
Areal extent Depth
Remarks
2. Performance MonitoringType ofmonitorincr
Performance not monitored
Frequency Evidence of breaching
Head differential
Remarks
D-16
• •
OSWER No. 9355.7-0JB-P -
IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable NIA/
A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable ✓ NIA
I. Pumps, Wellhead ~fog, and Electrical L
Good condition All required wells properly operating Needs Maintenance NIA
Remarks
2. Extraction System y«Des, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs Maintenance
Remarks
3. Spare Parts and E~
~ires upgrade Readily available Good condition. Needs to be provided
Remarks
.
B. Surface \Vater Collection Structures, Pumps, and Pipelines Applicable NIA./
I. Collection Structures, Pumps, and Electrical
Good conqition Needs Maintenance
Remarks
2. Surface \Vater Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs Maintenance
Remarks
3. Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks
D-17
• •
/ - -OSWER No 9355 7 038 P
C. Treatment System Applicable._,/ NIA
I. Treatment Train (Check components that apply)
Metals removal Oil/water separation Bioremediation
./ Air striplgng . ...-1::arbon adsorbers
.,1-i!ters _ p.-<c,
Additive (e.g., chelation agent, flocculent)
Others "' Good condition ✓ Needs Maintenance
Sampling ports properly marked and functional .,,--
Sampling/maintenance log displayed and up to date/
Equipment properly identified
Quantity of groundwater treated annually 5"'o O OD j'.fJ...
Quantity of surface water treated annually
Remarks
2 Electrical Enclosures and Panels (p/erly rated and functional)
NIA ' Good condition· Needs Maintenance
Remarks
3. Tanks, Vaults, Storage Vessels /
Proper secondary containment ~eeds Maintenance NIA Good condition
Remarks ~ ~ I< M.f: !, ~ I J U! 4 IL'-:i;,,. ...--o
A' IL <;.IIL1~,-~
4. Discharge Structure and Appurten~
NIA . Good condition Needs Maininance
Remarks 't> \'j(;.wO.~ ~ :!I! U:.t:tl.i::: o,::;ci::-\d<c.l<,E.o c.-.,..-
5. Treatment Building(s) / NIA Good condition (esp. roo/ doorways) Needs repair
Chemicals and equipment properly stored
Remarks
6. Monitoring Wells (pump and treatment remedy) _ / Properly secured/locked/7tioning/ Routinely sampled .,.,.----Good condition
All required wells located Needs Maintenance N/ A
Remarks
D. Monitoring Data
I. Monitoring Data / ls of acceptable quality/ Is routinely submitted on time
2. Monitoring data suggests: /4 / Groundwater plume is effectively contained Contaminant concentrations are declining
D-18
j
• •
OSWER No. 9355. 7-03B-P
D. Monitored Natural Attenuation
I. Monitoring \Vells (natural attenuation remedy)
Properly secured/locked Functioning Routinely sampled Good cond\ti~
All required wells located Needs Maintenance NIA
Remarks
X. OTHER REMEDIES -
If there are remedies applied at the site which are not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.
XI. OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as
designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant
plume, minimize infiltration and gas emission, etc.).
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope ofO&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
D-19
• •
OSWER No. 9355.7-03B-P
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be
compromised in the future.
D. Opportunities for Optimization
.
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
D-20
' • •
OSWER No. 9355. 7-038-P
INTERVIEW DOCUMENTATION FORM
The following is a list of individual interviewed for this five-year review. See the attached
contact record(s) for a detailed summary of the interviews.
·g~ Ir::~ ::I ~ ~ U.-0('..l<. E.t-15 ,i,1 ~,,h!ef!l E: ft. {--;z;£6f€.«AL t;::; ~~IC... 1.luL01.
Name Title/Position Organization 'na1e
1f2t,.~ 1 ll :K!.!~~~ 'J'v-1 ,oa.. J::"1.c-:i!.. b!;:o u~~~ ~4/-~~ Name Title/Position Organization ate
'8r-n.1c.,11 J/4µ,A,,1,./ PIZn.rcc:c s c.,wr,J r G~ :z;,,J<, 1-/1..o I o4 I 6ate Name Title/Position Organization
DA.-.£> /JAIQ.~t.J.o,./ ?iAt:J. '-ai-Pr~-J:".JV /2c:.t,£.L:-....£'1.,c:., , ......... 4' ij..ot:. Name Title/Position Organization nlte
Name Title/Position Organization Date
Name Title/Position Organization Date .
C-8
[phone]. T-194 P.001 HOO
FAX TRANSMISSION FROM:
Diane Barrett, Community Involvement Coordinator
U. S. Environmental Protection Agency, Region 4
Economic Redevelopment & Community Involvement Branch
61 Forsyth Street, SW, 10th Floor
Atlanta, GA 30303
Phone: [phone]
{404) 562-8489
, . · . , ·. ½ _FAX# {404) 562-8566
TO: ;,,dttcr::s-b //;-rl~ DATE: ,i//~/;i..oej
/J;tJJ~
Apr-06-04 02:ZOpm From-RCRA .ance Section [phone]. T-194 P.002/008 F-300
5-Year Review Questionnaire
Site
City/State
~ q,e1tv /~ ~
Date: 1/.rJo ,j
Name of Citizen
Address
Do you live near the Site? If yes, how long? p &1d7 S-! Q wlA,,:2./
Are you familiar with EPA activities over the past years? ~,i...1,,,/=-----. --------
What isyo_ ur overall impression of the P_ roject?.. . ~ tu-iz C ¼H9-:: ~ ~ . '/2 ~~ a_cb..'.,._; -
Overall, h~leased or displeased with deanup actions at this Site?
What effects, if any, have site operations had on the surrounding community? fa~~
. fo.d/1?4-~ ~<.cld _f/__ ~ '.I~ c~ ~ -4~~ . -nrdiyll· ~'s ?w):;,;..; f,:;.;;: ¼/ctA M-M/et;;: 4J 2l
Do you still have any concerns regarding EPA clean up activities of~ ,,,,; &et w~f (j;;f ;;;Jt:J:tr;;;;t ff!vjl~ tt/J~~'/4../'
Are you aware of any events, incidents, or activities at .the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details. s .4 ~ · G € .,,,_,__, .;. .
~ -1,, -t,_,
Is meone else that you would like to r
/)
Do · hat EPA can i · ve communication with t ublic?
'
Apr-06-04 02:20pm From-RCRA C.ance Section [phone]. T-194 P.003/008 F-300
S~Year Review Questionnaire
Address
/ Al
Do you live near the Site? If yes, how long? 'Jv,..J ~ JL~~ ·
Are you familiar with EPA activities over the past yearsf izq,!f u,-zv,v' ~--£?-I'..,,_) ,h,tJ ~ ., r
What is your overall impression of the project? C1;.C' .u%/t.£ . · 5 . . l
~ ;-Vo_ .2[131
Overall, havzou been pleased or displeased with cleanup actions at this Site?
j) 4a-ec/.-.c· ,.,
Do you still have any concerns regarding EPA clean up activities of the Site?
Do you thi~ou have been kept _adequately informed about clean up activities at the Site?
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emerg~ responses from local authorities? If so, please give details. __________ _
:I\!
Is the·re.:;i9(!1,eone else that you would like to recommend we contact for more information?
ve any suggestions that EPA can implement to improve communication with the public?
. . 'c"· • n () ~-·
lnterviewconductedby: ,/1~ A~
Date conducted : 41£1:i.oG Y-, I
Apr-06-04 02:21pm From-RCRA C.nce Section [phone]. T-194 P.004/008 F-300
5-Vear Review Questionnaire
How long have you lived near the. Site? , ¼4J.. 1 (62d) I 0 q Y
Are you familiar with EPA activities over the past years? __ L.,..J""~~--· ______ _
.JJ
Do you still have any concerns regarding EPA clean up activities of the Site?
ave you been pleased or displeased with EPA actions at ,his Site? .. ./,' -
Do you i~:,u have been adequately informed about clean up .activitles at the Site?
Is there any information about the Site that you would like to share with us that would assist in
our 5-ye1:1r review of site activities?
Is there someone else that you would lik'e to recommend we contact for more information?
Do you hav1;,any suggi:istions that EPA can impl~e_nt to improve communication with h1;1
public? U. · . "" c.u -\ =
/, .
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at-------------~-------------
Interview conducted by: '-"-<9.H+:t:-:':::'.". ~,.-~-
Date conducted: ¥/ya,'C .
Apr-06-04 02:Zlpm Fram-RCRA C.nce Section [phone]. T-194 P.005/008 F-300
5-Vear Review Questionnaire
Site '2~ ftJl.eZEu..u l/'4:tAJ ~,J
City/State t'~ 06.±-ib-4. It'« ·
Date: __ 1~/s-;~J,'--0-+f---Phone No. (52J) .75-(p a 7/
m:, ✓-~ iz:f ~lf.Ld . Name of Citizen
Address
How long have you lived near the. Site? 6~~ ;,.,_,) ~ Y-IU ~ < A,._, __ ,JJ_ If
Are you familiar with. EPA activities over the past years? gffa/
Do you still have any concerr,is ,~egarding EPA clean up activities of the Site?·
1-IL I '7f,,.,,_ . a,u, I .a/40
Overall, IJqve you been pleased or displeased with EPA _actions at this Site?
~Dµ-If' 14: dLd. , #----;y«:rl-. ~
Do you think you have been adequately informed about clean up _activities at the Site? -~
Is there any Information about the Site that you would like to share with us that would assist in
our Sfideview of site activities?
Is ther · eone else that you would like to recommend we contact for more information?
Do you have any suggestions that EPA can implement to improve communication with the
pub~lic"'i?~-----------------------------
c)
[A copy of the 5-year review will be placed in the Sits Information Repository file localed in the Site
Information Repository.at ______________ ,--_,. _________ _
Apr-06-04 02:21pm From-RCRA C.n,e Section [phone].
Date:
Address
How long have you lived near the, Site?
Are you familiar with EPA activities over the past years?
Do you stil e any concerns regarding EPA clean up activities of the Site?
,9
Overall, h~ou been pleased or ~ispleased with EPA actions at this Site?
I ·~ .,. ':::4:-<-{:;,L ~r:0<---& ✓
T-194 P.006/008 F-300
Is there any information about the Site that you would like to share with us that would assist in
our 5-y:ZZeview of site activities?
{,'
Is there ~one else that you would like to recommend we contact for more information? ,, .
Do you hav/4 suggestions that EPA can implement to improve communication with the
public? 1
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Sita Information Repository at _______________________ _
Interview conducted by: '~ 6 ~l ./ 4._,f-0::(.w-:--
Date conducted: 11/fWoo ,L
(
Apr-06-04 02:ZZpm From-RCRA C.nce Section [phone]. T-194 P.007/008 F-300
5-Vear Review Questionnaire
Address
Are you familiar with EPA activities over the
Do you sti ave any concerns regarding EPA clean ·up activities of e Site?
en kept adequately inform about clean up activities at the Site? ___ _
Are you aware of any events, inc· , or ivities at the site such as vandalism, trespassing, or
emergency responses from local auth · · s? If so, please give details. __________ _
Is there someone else th you would like to recommend we ntact for more information?
uggestions that EPA can implement to improve commu ·
Interview· conducted by-'1/ .,J,, ; f O 1 ~-
Date conducted : -~....,,...6~(P.c-,/'--o"'-~-"--------
Apr-06-04 02:22pm From-RCRA C,.,, Section [phone]. T-194 P.008/008 F-300
5-Year Review Questionnaire for Govt. Officials
Site ~ frJ,£,,cf!'lyfl,i_-;;!,,..._,
City/State M 9-ld: ,fd1 ~ __.,_ C -
Date:
Name
!flu/41 Phone No. (t~!r) t,f'l-</toe; ., , -~K>tJG
Address
What is your overall impression of the project?
Have there been routine communications or activities conducted by your office regarding the Site?
(Site visits, inspections, reporting activities, etc.) If so, please give purpose and results.
Have there been any complaints, violations or other incidents related to the Site requiring a response
by your office? If so, please give details of the events and results.
Do you feel well informed about the Site's activities and progress? ___________ _
Do you think olean up activities at the Site have had a positive or negative impact on the communfy?
In what ways? ------------------------------
Do you have any comments; suggestions, or recommendations regarding the Site's management or
operation? .
Interview conoucted by_-"'.~"-'-=-• c:· :..:·=-.J.._,.&-=r,:,<.=--1-.,:;-<..-".=,-«=="""-----------------
Date conducted -------------
Re: 5-Y car Review Site Visit • • { Subject: Re: 5-Year Review Site Visit
I of2
Date: Mon, 29 Mar 2004 10:35:30 -0500
From: David Mattison <[e-mail]>
To: "Hallock, Barry -HEN (GE Consumer & Industrial)" <[e-mail]>
CC: 'Patricia Hermann' <[e-mail]>,
Todd Hagemeyer <[e-mail]>,
Michael Townsend <[e-mail]>,
Stephanie Grubbs <[e-mail]>
Barry/Trish,
What about next Tues (4/6) or Wed 14/7)?
Thanks for the help on this (especially considering the short notice)
Dave
"Hallock, Barry -HEN (GE Consumer & Industrial)" wrote:
> Our plant is in a shutdown this week. Is there any way to schedule this for
> another week? Also, I am out Tuesday and Wednesday of this week taking a
> group of safety reps to visit a plant in LaFayette Georgia. In addition I
> would like to have David Anderson present during this visit as David
> operates the groundwater recovery system and is probably the one to answer
> your questions. Please let me know if this visit can be delayed to next
> week or the week after. Thanks.
>
> Barry J. Hallock
> EHS Manager
> GE Lighting Systems, Inc.
> /828) 693-2148
>
> -----Original Message-----
> From: Patricia Hermann [mailto:[e-mail]]
> Sent: Monday, March 29, 2004 10:15 AM
> To: [e-mail]
> Cc: Todd Hagemeyer; Hallock, Barry -HEN /GE Consumer & Industrial)
> Subject: Re: 5-Year Review Site Visit
>
> David-
>
> I am available anyday this week for a site visit. The new GE EHS
> Manager is Barry Hallock and his email address is
> [e-mail]
>
> Trish
>
> Trish Hermann
> Project Scientist
> GeoTrans
> 1080 Holcomb Bridge Road
> Building 100, Suite 190
> Roswell, GA 30076
> /770) 642-1000
> /770) 642-8808 FAX
>
>>>>David Mattison <[e-mail]> 03/29/04 10:05AM >>>
> Trish,
>
> I need to schedule a site visit to the GE/Shepherd Farm site this week
12/20/2004 5:06 PM
Re: 5-Year Review Site Visit • • (
2 of2
> (preferably Tues or Wed) for an inspection of the site and the GRS for
> the 5-year review that the NC DENR Superfund Section is conducting for
> the EPA. What is your schedule for this week? Also, I do not have an
> email address for the current GE representative? Would you please
> send
> it to me so that I can notify him as well? I will need to question
> both
> yourself and the GE representative regarding the operation and
> maintenance of the landfill and the GRS. Don't worry, the questions
> aren't that tough.
>
> Thanks,
> Dave
12/20/2004 5:06 PM
Re_ NCDENR performance of Five Year Reviews. •
I of 4
Subject: Re: NCDENR performance of Five Year Reviews
Date: Thu, 25 Mar 2004 15:58:38 -0500
From: David Mattison <l)[e-mail]>
To: [e-mail]
CC: [e-mail], [e-mail], [e-mail],
JACK BUTLER <[e-mail]>,
James Bateson <[e-mail]>,
Michael Townsend <[e-mail]>
Samantha,
Your guess is as good as mine as to the source of the dates used in the Agreement.
Regardless, we will use
the dates listed in CERCLIS for our trigger dates and subsequent reviews. In regards
to the trigger date for
the GE/Shepherd Farm Site, I instructed Stephanie to use the April 30 (now April 26)
deadline in order to
agree with the information in the CERCLIS database. We will also use the May 15,
2005 deadline for the Davis
Park Road TCE Site. As far as the lack of a fourth site, the NC DENR Superfund
Section will perform those
5-year reviews as directed by Region 4. If Region 4 does not have a fourth site for
this Agreement, we will
wait for FY2006, hope for a renewal of the Agreement, and perform those 5-year
reviews as needed by Region 4.
Dave
[e-mail] wrote:
> Hi Dave. I don't know where those dates in the Agreement came from
> unless they are just end of the month/fiscal year dates. Five Year
> Reviews are required to be signed by the EPA Waste Division Director no
> later than 5 years, to the day, of the triggering action. Trigger dates
> are: /1) Previous 5YR signature date. /2) If no prior 5YR, tor /a)
> Statutory review: Date of on-site construction start. (b) Policy
> review: Date of PCOR signature.
>
> The official due dates by EPA HQ guidance were the ones I stated in my
> previous e-mail. There was a question about whether the GE/Shepherd
> Farm was statutory or policy review and what the date of actual on-site
> construction start was. Since Michael couldn't clarify, we chose the
> conservative date of 4/26/1999 as the trigger (the date listed in
> CERCLIS tor RA Start general heading tor the earliest RA listed.) In
> doing the SYR, I'm hoping you or Stephanie can clarify this. Davis Park
> Road is a policy review and therefore is due 5/15/2005, 5 years after
> the PCOR signature (5115/2000).
>
> I have an extensive database of all Sites requiring Five Year Reviews in
> Region 4 and my search of that database is the source tor the into I
> provided. Unless there is one that somehow slipped through mine and HQs
> research, what I stated in my prior e-mail is all that exists for
> FY-2004 and FY-2005 in NC. Based on needs and official due dates, I
> would recommend moving Davis Park Road to FY-2005. Not sure what needs
> to be done about the shortfall tor FY-2004 ...
>
>
> David Mattison
12/20/2004 5:05 PM
Re: NCDENR perfonnance of Five Year Reviews. •
2 of 4
> <David.Mattison@n To: Samantha
Urquhart-Foster/R4/USEPA/US@EPA
> email.net> cc: [e-mail],
Harold
>
Hill/R4/USEPA/US@EPA,
> 03/25/2004 02:59
Taylor/R4/USEPAIUS@EPA, Franklin
DAVID LOWN <[e-mail]>,
James Bateson
> PM <[e-mail]>, JACK
BUTLER
>
Townsend/R4/USEPA/US@EPA
>
<[e-mail]>, Michael
Subject: Re: NCDENR performance of
Five Year Reviews
>
>
> Samantha,
>
> Under the Support Agency Cooperative Agreement for 5-Year Reviews of
> Remedial Action at NPL Sites in North Carolina /I can supply you with a
> copy
> if you would like), NC DENR is tasked to perform two /2) 5-year reviews
> in
> FY2004 and two /2) 5-year reviews in FY2005.
>
> I am currently managing the 5-year review for the GE/Shepherd Farm NPL
> Site
> although Stephanie Grubbs is doing the bulk of the work. Diane Barrett
> has
> already placed an ad notifying the affected public regarding the 5-year
> review and was to conduct the facility and interested public interviews
> this
> week. I will arrange for a site visit either next week or the
> following.
> We hope to issue the draft document to Michael Townsend on or about
> April
> 12. Assuming that the draft can be reviewed and revised in a two week
> timeframe (which it should be), we will have the final copy for EPA's
> signature prior to the deadline. The trigger date is still in question
> as
> seen in the fact that the Support Agency Agreement cites an April 30,
> 2004
> deadline and your email cites an April 26, 2004 deadline. Do you have
> any
> additional clarification on this issue?
>
> In regards to the 5-year review for the Davis Park Road TCE Site, the
> Support Agency Agreement cites a deadline of September 30, 2004.
> However,
> if Jennifer requires more time to obtain data, we can postpone this
> activity
> until FY2005. Will this require an amendment to the Support Agency
> Agreement? Unless another site requiring a 5-year review suddenly
> appears,
> it looks like we will run short either in FY2004 or FY2005, depending on
> when we start the 5-year review for Davis Park Road TCE Site. If this
> is
> indeed the case, I do not see the need to initiate the 5-year review for
> the
> Davis Park Road TCE Site until Jennifer gets the data that she needs for
> the
> site (unless we want to have strict compliance with the trigger dates
> for
12120/2004 5:05 PM
Re: NCDENR performance of Five Year Reviews. •
3 of 4
> use by HQ). Regardless, we will still plan on conducting the 5-year
> review
> tor the Davis Park Road TCE Site in either FY2004 or FY2005 as well as
> the
> 5-year review for the Charles Macon Lagoon and Drum Storage Site
> (September
> 30, 2005 deadline).
>
> I, too, have cc'ed this message to my management to likewise get their
> opinion.
>
> Keep me posted,
> Dave
>
> [e-mail] wrote:
>
>>Hi Dave. When we were at the Holtrachem Site earlier this month, we
>>briefly discussed Five Year Reviews. I believe that NCDENR is
> supposed
>>to do two a year tor us under the Cooperative Agreement (I think
> that 1 s
>>what it's called?). I don't have a copy of that document. Is it for
>>the Fiscal Year (FY) or calendar year?
> >
>>For FY-2004, there is only 1 Five Year Review (5YR) report due for
> Sites
>>in North Carolina. The General Electric Co/Shepherd Farm Site has a
> 5YR
>>due 4/26/2004. I believe Michael Townsend has already contacted
> someone
> > within your group about preparation of th.is report.
> >
>>For FY-2005, there are only 2 Sites with 5YRs due that could be
>>performed by NCDENR. Davis Park Road TCE Site is the first one that
> is
>>due, 5/15/2005. Jennifer Wendel has stated that she would like more
>>groundwater data to be obtained before the report is prepared.
> However,
>>she stated
> absolutely
> > necessary,
> > (FY-2005).
> > 9/26/2005.
> a
that work could begin on the 5YR during FY-2004 it
but not be completed until after future data is received
The 5YR tor Charles Macon Lagoon and Drum Storage is due
There are two others due in the state tor FY-2005; one is
>>Federal Facility which is required to do their own, and the other is
> JFD
>>Electronics/Channel Master which will be prepared by the PRP.
> >
>>I'm not sure what the time spand is for the agreement with NC.
> However,
>>there is only 1 Site that will be ready tor a 5YR tor this FY, and two
>>tor FY-2005. I'm not sure what implications this has. I'm not even
>>sure who's involved with these types of things so I'm copying my
>>management on this hoping that one of them will know. I know that
> Phil
> > Vorsatz was involved in the past, but he's no longer Section chief in
>>our branch. I tried to call him, but he's out of the office and I
> want
>>to go ahead and get this out.
> >
>>Samantha Urquhart-Foster
>>RPM I Region 4 Five Year Review Coordinator
> > [phone]
12120/2004 5:05 PM
•
TO:
T-105 P.001/002 F-057
FAX TRANSMISSION FROM:
Diane Barrett, Community Involvement Coordinator
U. S. Environmental Protection Agency, Region 4
Economic Redevelopment & Community Involvement Branch
61 Forsyth Street, SW, 10th Floor
Atlanta, GA 30303
Phone: [phone]
[phone]
~ . _ ~ -. ~AX# [phone]
dJa-,,-(_k ~ !;>ATE: 0/ 9/4 i
1/C. 1 f I)µ
FAX# &1 '1) '7-I:3 -.YI/ NO. PAGES J__
SUBJECT: dy1,it 5-=-r, J\p ~_,__, a.1 -!f.,,J (fE__, .
COMMENTS: . :Ji* . 0-R. 'Lcd j r1LJ w;,T C!-4,;✓,,-
~ ILA2 · ~,<.~
Mar-09-04 10:56am Frcm-RCRA .anco Section [phone]. T-105 P.002/002 F-057
ii• .... ♦.,.'--~: 41!:
A Five-Year Review is being conducted of the clean u activities taken at the £~..,+ f'I~+ ~. General Electric/Shepherd Fann Site in~a · , North Carolina. A
copy of the report will be placed in the Administrative Record & Information
Repository files located in the BP A Record Center, 11th Floor, 61 Forsyth
Street, SW, Atlanta, GA 30303, and the Henderson County Public Library,
310 N. Washington Street, Hendersonville, NC.
The remedies implemented at the Site included: groundwater extraction/
treatment/discharge/monitoring; excavation of contaminated soil from
specific residential areas and landfills on GE property: excavated soil placed
in the dry s~udge impoundment on the GE property and capped; deed
restrictions .on future use of impoundment area.
The Five Year Review process will evaluate the remedies implemented at the
Site and determine if they are still protective of human health and the
environment.
EPA will also conduct a number of telephone interviews with nearby
residents, local officials, state officials, and others to obtain their opinion on ' the clean up process. If you would like' to speak with us about this Site,
please call J?iane Barrett, EPA Community Involvement Coordinator, at 1-
800-435-9233 or 404-562-8489.
If you have 'any technical questions, please contact Michael Townsend, EPA
Site Project Manager at 404-562-8813.