NCD003188844_19860512_Carolina Transformer_FRBCERCLA C_Pre-NPL Departmental correspondence 1978 - 1986-OCR

I
DIVISION OF KNVIB.ONMKNTAL MANAGKMENT
May 12, 1986
Mr, Bob Jourdan, Chief
Investigation Unit
ERRB
US EPA
345 Courtland St., M.E.
Atlanta, Georgia 30308
Dear Mr. Jourdan:
SUBJECT: Groundwater Monitoring
Carolina Transformer Sita
Fayetteville, Cumberland County
North Carolina
The Environmental Protection Agency COlllJ)lated a clean-up action at
the subject site during Auguat, 1984 (see attached OSC Summary). There
were at least two wells contomL,ated with cblorobeue carriers which made
it necessary for area resident& to abandon their wells and connect to city
water.
Our office continues to receive calls from time to time from citizens
in the area as to whether or not the groundwater is contaminated end if so
bow much and large en area. We are not able to provide complete informa-
tion on the status of the groundwater in the area end feel that additional
action on the matter is merited by EPA. The action envisioned would be in
the form of a groundwater IIIOtlitoring program to determine the horizontal
and vertical extant of the contamination. It ia felt that eucb action is
crucial since the Caroline Transformer site is on the fringe of a heavily
populated area and it is possible that contaminated groundwater could be
unknoviDgly used in the area.
Baaed on the information gathered during the groundwater monitoring
program, the Groundwater Section, Division of Environmental Manag-nt,
North Caroline Department of Natural Resources & Community Development
could reclassify the area accordingly to try end prevent inappropriate
use if restoration is not economically feasible,
. ". ''
Yoa;'auiataace ill Cb.ta •teer -u N gnatly lffl'IIOiaced. If JOU . '.:-baft aD)'}flllNtiou or aeed addit1-1 Wonat1-.'pleilM'c:0ntaet • at ---. -. [phone],
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ORIGINAL SIGNED BY MARION J. NOLAND
. CC I I.ea Laymon
M, J, Moland
Beg1oneJ supervisor
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
¼'illiam W. Cobey, Jr .. Secretaiy
George T. Everett, Ph.D.
August 28, 1990
MEMORANDUM
TO: Lee Crosby, Chief
Superfund Section
Division of Soli
FROM: George Everett
SUBJECT: Draft Remedial Investi tion Report
Caroli na_Trans f.ormeL-S.ite.,
NCD003188844
Cumberlcmd_ County
Director
As requested in your July 9, 1990 memorandum to Mr. Perry
Nelson, Chief, Groundwater Section, the Division has reviewed the
subject remedial investigation report.
This Division concurs with the findings of the report. It
is our understanding that additional sampling will be conducted
to further define soil and surface water contamination. The
Division wishes to review this information once it is available.
If there is any need
clarification, please advise.
cc: Mick Noland
Perry Nelson
Lee Daniel
Steve Tedder
Bill Reid
for
PoUudon ~ntlon P"ys
additional comments or
RECEIVED
AUG 3 O l))u
PDLLunorv CONTROL BRANCH
P.O. Box Z 7687, Raleigh, North Carolina Z 761 I-7687 Telephone [phone]
MEMO
• ; !
TO lit' II Z1J
DATE, --------l,l2--L..L;t/----'--9---'=---~ __
SUBJECT, ____ _
C-E)'t!CL/J /7.A~~ /
t;.,,,... ~/-.£
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North Carolina Department of Environment
Health, and Natural Resources '
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary 9 July 1990 William L. Meyer
Director
MEMORANIXJM
'IO: Perry Nelson, Chief
Groundwater Section
Division of Erwironmental Managenent
FRCM: Lee Crosby, Olief ~ •• I
SUperfund section /R-'
RE: Draft Remedial Investigation Report
carolina Transfonner Site, NCD003188844
Fayetteville, Cl.Imber land County, North carolina
EPA is in the process of conpleting a Remedial Investigation
for the carolina Transfonner SUperfund Site, a National Priority
List Site.
Attached are three copies of the Draft Remedial
Investigation Report for the subject site. 'Ihis report was
prepared by Dan 'Iharnan of the EPA Erwironmental Senrices
Division. It is requested that these documents be forwarded to
the appropriate sections of DEM and connnents be submitted to the
NC SUperfund Section. 'Ille NC Superfund section will be reviewing
this document and submitting connnents to EPA Region N in the
near future. It is our desire to include the views and
permitting requirements of the Air Quality, Groundwater, and
Water Quality sections of DEM.
If you or your staff have any questions, please call Jack
Butler or me at [phone].
IC/ds
Attachment
~(r.Jin"'7W~n . . . "n\ u .,
i;:-JUL 13 1990
GROU NOWATER SECTION
RALEIGH, NC
RECEIVED
l)\IG 1 5 \))\)
POLLUTION CONTROL BRANCH
I
/
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 1, 1990
M E M O R A N D U M
~:s~--
"'"'''. ::f <~ ~~.-.•., .. •.,;IP' '
TO:
FROM:
SUBJECT:
('~~"' -<§.) <;::,~
Perry Nelson, Chief ,?:_%3 ""'7 <$
Groundwater Section ~~~')., ~ s'-0 ~
~-I.. \l ~(D ,;;t ~
M. J. Noland, Regional Supervis;,r ~~ ~ ~"'i;-<::,~'
Fayetteville Regional Office ~'ci ;J} ~~ ~~
Draft Remedial Investigation Report ~
Carolina Transformer Site NCD003188844
Fayetteville, Cumberland County
As requested, the subject document has been reviewed by all sections in
the Fayetteville Regional Office. It is our understanding that additional
sampling is to be done the week of August 6, 1990, to further define soil and
surface water contamination. This office recommends favorable comment on the
remedial investigation report.
If there is any need for additional information or clarification, please
advise.
MJN/tf
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 7, 1990
M E M O R A N D U M
~' ~~i/ '
~\'{:,, ~ ~ .~~
TO:
FROM:
SUBJECT:
./;;J :\' Sammy Amerson <};,
Air Quality Section ~ ~ S ~
Jack Floyd/I.,,(_ ~ ;f>{tj ~~~"!
GroundwatK/ection ~ ~ ;y
I ~~ Draft Remedial Investigation Report ~
Carolina Transformer Site NCD003188844
Fayetteville, North Carolina
Cumberland County
Attached are the referenced documents and comments from the
regional office. Your assistance in reviewing these documents
and returning them with your comments by end-of-work, August 14,
1990, will be appreciated.
Attachments
..
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 9, 1990
M E M O R A N D U M
TO: Mills
FROM:
r Qual~Section
Flo~/_--<._
Groun wateJ Section
SUBJECT: emedial Investigation Report
Caroli a Transformer Site NCD003188844
Fayett ville, North Carolina
Cumber and County
Attached are the referenced documents and comments from the
regional office. Your assistance in reviewing these documents
and returning th m with your comments by end-of-work August 16,
1990, will be app eciated.
Attachments
SECTION 1
, DSC SUMMARY
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C5C Report
Carolina Transformer o:mpany, Fayetteville, North Carolina EXiward L. Hatcher, OSC
Dennis Manganiello, Project Officer
Background
After the roadside dunping of PCB oil in July of 1978, the Fayetteville Regional Office began receiving oornplaints frc:m a resident that lived near the Carolina · Transformer 'Corpany (Cl'C) site on River Road. The residents were concerned about the possibility of ground water contamination fran the transfoaner site since they were on wells. The analysis fran the well samples did not she,,,, any 'PCB contamination, ho,,ever, several contaminants were found in two private wells in the inrnediate area. one of the wells, located with 250 feet of the site, sho,,ed significant concentrations of chlorobenzene, a PCB carrier fluid, and the second well which is located 1000 feet fran the site sho,,ied trace anounts of the chlorobenzene carriers. A short time later the City of Fayetteville ex-tended water lines into this area. At the present time residents and businesses in this inrnediate area are on city water. A total of twelve (12) welis were sampled by EPA in November 19_78 and March 1979 in the vicinity of the Carolina Transformer Canpany site. (.~ of those sampled were contaminated as was previously mentioned in tHis-"'paragraph. A recent check was made with the City of Fayetteville's Public w:>rks Depart:Jnent and it was determined fran talking with the attorney for Carolina Transformer Conpany, Mr. DJane Gilliam, that Carolina Transformer o:mpany paid for the connection of the residence of Mrs. Bessie Edge, onto city water. The remaining connections were not paid for by Carolina Transformer o:mpany.
Following this investigation, the Fayetteville Regional Office and EPA oollected a series of soil surface water samples fran the Carolina Transformer Q:rnpany site. This sanpling verified the presence of PCB both in the soil and surface water on this site. DJring this period of time Carolina Transfoaner o:mpany had re-tained Rose and Purcell, Inc., consulting engineers to work on a proposal to clean the area or to treat the surface water runoff. In a letter dated August 22, 1979, EPA advised Carolina Transformer o:mpany that reiroval would not be mandated since ere indicated that the material had been spilled prior to April 18, 1978, ·..men the Toxic substances Control Act ('IOSCA) became effective. HOWever, EPA also indicated that storm water runoff fran the site would have to be controlled. under present TOSCA criteria, a concentration of PCB in the soil of SO mg/kg or greater would be considered to be PCB contaminated. soil sampling done by Natural Resources and COrmunity Developnent and EPA in 1979 (Exhibit A) approxinately 1 to 1 1/:?. acres of the site appear to be contaminated in excess of SO mg/kg.
Fron late 1979 until the present, oontact was maintained with ere about the .need to oorrect the problem, but. no progress was made. The consulting engineers are no longer retained by ere.
On March 3, 1982, Mr. Kerr T. Stevens, Environmental Engineer, Fayetteville Regional Office visited the ere River. Road site and oollected a surface water sanple in the headwaters of an unnamed tributary to the Cape Fear River which receives runoff .fran the ere side.
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The analysis of the March 3, 1982 sample showed a PCB concentration of 15 parts per billion. A second visit made to the site on April 27, 1982 and another surface water sample was cxillected at the sarre location. The analysis of this sanq,le sho..ed a PCB concentration of 40 parts per billion. The matter of clean-up of the River Road site was discussed with Mr. Strother, but he did not seen to have any particular plan in mind for the site.
The sampling which was cxiriducted in March and April 1982 did establish a violation of the.water quality standard for PCB which is 0.001 parts per billion. In a letter to ere dated May 10, 1982 the ccmpany was advised of the surface water violations and it was requested that they contact to arrange a meeting to discuss the cleanup of the site. Mr. Strother stated that they did not kl'lC:M .. _ 'What to do and he did not think that their ccmpany could afford to clean ·up the site. Mr. Strother did however, agree to look into the matter. ·
No proposal was ever sul:::mitted and a second letter was sent to ere requesting that the a:xnpany show cause on septerrber 3, 1982 as to why enforcement action should not be taken. The September 3rd meeting was held and the matter was discussed with Mr. Dewey K. Strother and Mr. Kenneth Strother of Carolina Transformer Conpany. It was agreed that the cx:ropany 'wOUld contact several consulting engineers or contractors about the site cleanup and would then sutrnit a proposal. on November 8, 1982, Mr. Kenneth Strother was contacted about the agreed upon proposal and he stated that they just could not find anyone that could advise them on cleaning up the site. He again indicated that a cleanup would be cxist prohibitative. At this point it appeared that an enforcement action was the only option •
EPA Enforcement J\Ction
The site consists of contaminated soil located on and adjacent to the Conpany's old transformer· storage area. A large portion of the site is situated on property Owned by the heirs of the Honbarier estate. Known potentially respon-sible parties include the facility owner/operators Dewey Strother and his son Kenneth Strother, and the adjacent property owners Roxie Honbarrier, Frances Honbarrier Davis, B.G. Honbarrier and Carolyn Horibarrier White.
EPA attempted to address the problem through TOSCA and the CWA, however, neither act gave EPA the authority to require rercoval of the cxintaminated soil or proper closure of the site. In 1984, EPA issued a CERCLA 106 Order to the facility requiring the renoval and proper disposal of cxintaminated soil. After the canpany refused to undertake the work, EPA determined that imnediate rerroval · action was necessary and appropriate. on August 1984, EPA began clean-up activities at the Carolina Transformer Site in Fayetteville, North Carolina.
Although the landowners of the property adjacent to the site are potentially responsible parties, ,enforcement efforts have been aimed at the ccmpany because they appear to be financially viable and because problems at the site appear to be caused solely by the acts or anissions of the owner/operators. In addition, the landowners probably have a strong 107(b)(3) defense in that they inherited the property after the contamination had occured and there is no evidence of a cxintractual relationship, existing between the present and past owners and the facility. If enforcenent or cxist recovery efforts against the ccmpany are unsuccessful, EPA may reconsider the efficacy of pursuing the .landowners.
Site tescription
This site is situated at the headwate·rs of. the unnamed tributary. The general
area is lc:7,i lying, semi swampy with a oonsiderable amount of standing water
observed on the ere site. The surface water drainage fran the ere site flows
through an 18 inch culvert under a dirt road at the southwest side of the
site. Fran this point the water flows through a natural stream channel
approximately 18 to 24 inches wide through another swampy area then into a
tributary approxinately 4 feet in width. The flow fran this site travels
approxinately l 1/2 miles to the cape Fear River just about the City of
Fayetteville's wastewater discharge, about 1/4 mile upstream of U.S. 301 bridge.
'rtlis tributary is bordered on one side by ccmnercial developnent and on the other
side by fann land. PUblic access is sanewhat limited to the tributary due to
little residential developnent in this area. (Note map on foll™ing page).
Hazardous SUbstances Involved
'rtle results of the soil sample analysis done in June 1984, indicated that the
soil was contaminated with PCB's (Aroclor 1242 and 1260) and related carrier
cx:mpounds -trichlorobenzene, dichlorobenzene, and pentachlorobenzene. 'rtle oon-
centration of PCB found at the surface ranged fran 106 rrg/kg to 20,000 rrg/kg
continuing to a depth of 8 inches.
'rtle effects on human health of the contaminats detected are:
a. Aroclor 1242 and 1260 aninal carcinogens.
b. Pentachlorobenzene is a teratogan & carcinogen.
c. Dichlorobenzene has been k= to cause liver and kidney damage.
Trichlorobenzene is a mild irritant to skin, eyes and mucous
membranes. In surnnary, acute chronic human exposure to the
identified chlorinated benzenes can result in skin, lung & mucuos
membrane irritation, liver, kidney damage and QIS effects.
Additionally, thes1:: caupounds, especially dichlorobenzene, are
toxic to non-human mamnals, birds & aquatic organisms, They are
also import an offensive taste and odor to water.
Site-Cleanup
Cleanup operations began August 13, 1984 and were ccrnpleted August 22, 1984.
'rtle project included several actions; dewatering the contaminated swampy area,
solidifying the renaining PCB/oil sludge, excavating and disposing contaminated
soil, arranging disposal and transportation for solidified wastes, backfilling
the area and grading the excavated area.
A total of sixty-four loads (approximately 975 tons) of PCB contaminat.,-·
was renoved fran the site and transported to the Chemical Waste Mar·
disposal facility in Emelle, AL. The excavated·areas were bacl<~·
tons of locally·procured fill dirt.
Project Cbst
'rtle scope of work was estinated to cost $340,000. A ,
for S200,000. Remaining funds ($140,000) were a::mnitt,
nounting transportation cost. A breakdown of project
cost is tabulated bel™:
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TOtal Extranural Cost:
Personnel
Equipnent
Material
Analytical
Transportation
Disposal
TOtal
Cbnclusions/r..essons I.earned
$ 14,845
10,084
3,200
600
118,600
121,418
$ 268,747
1. samples taken after the excavation showed PCB oontamination up to 140 ppn.
These samples were taken at depths where previous samples had indicated very
lcrw oontaminations. It appears fran these results that the rerroval activities
(heavy equipnent operation) tended to push the contamination further dcrwn into
the soil. This problem was the result of the soft swampy area where the 1113jor
contamination was located. The ocs, after oonsulting the state osc, concluded
further excavation would not be oost effective because of these problems. The
cleanup operations resulted in a 99% reduction (20,000 ppn to 140 ppn) of the
on site oontamination •
. 2. Incident Obligation LOg serves no useful purpose where the rrajority of
changes are "await bill" and should be discarded £ran the project file for
future jobs.
. '
. '.
STATE LABORATORY OF PUBLIC HEALTH
DIVISION OF HEALTH SERVICES
IJ@mDWltW
APR 2 1985 N.C. DEPARTMENT OF HUMAN RESOURCES
SEP 12 \984 P.O. BOX 28047 -306 N. WILMINGTON ST., RALEIGH 27611 . [., . .
CH · Q i g · ~RO!JttDM~[~ECllCil WATER SUPPLY 18¼~ANIC CHEMICAL ANALYSES -r&k: wrJ cz rf~Hr-f,-r,. · .
-REGION Ill · · / 1 -
• Complete All. I terns Above Heavy Line r Ct n S -r-o _rvrJ-€' r
Procp.;;_s, "'..::J Plnnr (See Instructions on Reverse Side) O,' / .s
Source of Water:
(Xl Ground ) Both
( ) Surface ) Purchased
Source of Sample:
( ) Distribution Tap· ( ) House Tap
()() Well Tap
. Type of Sample:
O(l Raw Treated
T,v_?e of Treatment:
(,IC,) None
--~ .,,,,.,-{ ;_c_-'.i!,-:-, ;~---v - ' ~ --;~ ~J:~:=~
Collected By::...· -'-J.L!....L!.Lf,-'----~.<.<.:+'g'""'-'U:!..!.!.h..c:;JS::=...:· __ _;_· ---1 ( ) Filtered
( Lima
( ) Soda Ash .. )-Po~phosphate . ( ' .
( ' I · Water Softener
Time: / .2; ( ) Aluni I ) Other
Locetion of Sampling Point: ..,a=-'.~.!..!d_·_4__,_"_,,'"'--"-"--"e-'-l.!..I ____ ~
(Adc!ress where sample was collected) SW 5 ,de · of .b/1)
Type of Sample:
(; ) Regular
f ) Check
( ) Private
( )() Special
Re .. m. a ks· · .. · A,, . -WATER SYSTEM 1.0. NUMBER (COPY FROM MAILING LABEL)
r · ~,1-,,"'fu/i-·• e /)/so t"<.>,r.,..f--lo f'p,I~.,,/ Lo ,,-hr (£,,,,,/o,4,,r/,c r/ [a]~-[2][61-[41[i]~
State Drinking Water Parameters (Required)
Results
(CHLORINATED HYO CARBONS:) En ·n mg/I 5 ..... :.·
mg/I 4
mg/I 3
ICHLOROPHENOXY
mg/I 4
mg/I 3
mg/l 4
Date Extracted
Comments:
..
STATE LABORATORY OF PUBLIC HEALTH
DIVISION OF HEALTH SERVICES
N.C. DEPARTMENT OF HUMAN RESOURCES
ER SUPP LY BRANCH P.O. BOX 28047 -306 N. WILMINGTON ST., RALEIGH 27611 . WAT . ~ i i; ~· ¥ k ., . . REGION llbRGANIC CHEMICAL-ANALYSES -'pusuc A ER SYSTEM
Complete All Items Above Heavy Line ks+ -fu r' (See Instructions on Reverse Side) -;--( .
Name of
System:
· Address: -...Lu.J~,.,/.....LJ~L..t.!"'Z!.!..; .::::-"'./1J~d.!..!!!!>e:::!.l.Lt..CI.:..I.:l.l
,lie. IP
ZIP
t rfi nS -to II rn f' r
Source of Water:
()() Ground
( ) Surface
Source of Sample: (X ) Distribution Tap
Type of Sample:
(X) Raw
Type of Treatment:
O , I::,
Both
·. Purchased ..
House Tap
Well Tap
Treated
:.~•phone Number:_..__--:).,'--..,-.. -.. ---:.,.'""...-.. -_-.,-=-:,,-__ =.--:;.,._-____ -__ ;:+.-. ef-.. _i;.~--."'!.-.,~4'-_,.,.J)(-~-~~;:~~!f-1-· _:_: ~~---;· ~'~ -~f ~p:phate
Collected By: ··..LJ1!..J.Ll-,::lt:....!...L!:!.::~~!.L!:=------~ ( ) Filtered ( ) Water Softener
Date Collected:· Time: :so· ·.. . . Spjcf-,,
Location of Sampling Point: -~-=---....Ll-"-':..::C>:----~ (Address where sample was colfected)
Remarks:
State Drinking Water Parameters (Required)
Results
(CHLORINATED H
(CHLOROPHENO
Comments:
·-· 1'
mg/l 5
mg/I 4
mg/I 3
mg/I 4
mg/I 3
mg/I 4
( ) Alum ( ) Other
Type of Sample:
( ) Regular
( ) Check
Private
Special
WATER SYSTEM 1.D. NUMBER (COPY FROM MAILING LABEL
. [Q][3]-5][b]-[4J[i]~
Optional Parameters (List as needed) . • · · · · · f. T-sf-+or /rons-{,,,_rmer-,o,· 5 .. Results 5,.._ ,-,ff4,1,"'1 ,::."t
p= fl Of 75";)._
.. jlt --'.1. , ...........
County:
ZIP , .. ,.
Telephone Number: • ,i t
w #---'.<--··. ·•· \ . w
Collected By( .. _ L-'-'-'--'Ll+'--''-"'"-#':...;<' c::O:..:· ':::.-'.:..n:.,:"5=' :__;___....::.......;,.--1-..
Date Collected:·c; =-f"-J+.-=.:::.L~,!_..JTC!limc!.!ee,:_;:_· L:.J....!'..:.• 55=~-_;P:...:M::...
State Drinking Water Parameters (Required)
mg/I
(CHLOROPHENOX
mg/I 3
mg/I 4
Source of Water: (x, Ground l Both . ~
( ) Surface ) Purchased·'
Source of Sample:
()<) B Distribution Tap ( House Tap
. ')'&-HJ J/"r/)rr -1-,.,, I::: ( Well Tap
Type of Sample:
( )() Raw Treated
Type of Treatment:
<Xi None ( ) Lime ,
( l Chlo)"inated ( . l Soda Ash,
uor e ·· 1ypho,ifh'ate
Filtered Water Softener
Alum Other
Type of Sample:
( l Regular ( l Private l.
( l Check !Xl Special
WATER SYSTEM I.D. NUMBER (COPY FROM MAILING LABEL
[a~-Q][k]-~ ~
. ----
Date Received __ _,q-f/_7.y.8.l.1_'1,___,f/c.:..:..• j)_.,-= Date Re~!· q -7 -f i
r I -·
Report~ {?. Jlf ~ 4 4951· Date Extracted 9-1-91/&JJ Date Analyzed CJ-7-N 8JO Laborn ry Number _______ _
Comments:
;"{", .';~ .
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, .
DIVISION 'OF ENV_IRONMENTAL MANAGEMZllT
. May 12, 198~ _
SUBJECT: ··Groundwater Monitoring
,. .•.':: .Carolina Trnnsformer. Site
Fayetteville, Cumberland Couilty
North Carolina
.· .... · : · . The'.Environmental Protection Agency completed a· clean-up. llCtion at ., \'•. the '._i11ubjl!ct' aite during August_, 1984 (see attac!icd OSC Summary). There · · ·. . ;::cwre-at least . two wells contami,1ated ·With chlorobenze carriers which made :-: :· · -· · :: > ... ' it .neceesary,,,fbr area ·residunts .to abandon their wells and connect to city· "':'_:I. •• /.. ~ ::, t_ ... -·.: •• : • :. -~ •• , '\.j.. • • -water. · ',.,,,\. • · · ... 1'i_;i ;.:·--,-·: .. : ... t:-~~:~::.\\,-~:····_,, .' '?'.i;~·••, . ' . . . . . , ' '< Our.,,e_ffice. continues to receive calls from tioc to time from citizens .·,: :,;.¥1-the:arcia,as_to who_ther or not ··the groundwater is contnminatad nnd if oo /'.· .,:i_how much,and large _o'n ·area, We are riot able to provide complete informa-. ···,,:;,ition ·on the status.of 'the groundwater in the area and feel that additional ' . 1 -' . t • . ; , . • . . --~•\;. . ,'-'.';. ac~ioi:1 .. on the '.matter .is. merited by EPA, Tbe.,action envisioned would be in J. ;.'tlie ''.forju-of-a · groundwater monitoring. program to determine the-hor.i~pntal · '. , .. /;~,: ·c «;/l1:1d vertical, extent of the contamination.. It is felt that such action is .. :· • 1 '·'·,'-'s'Jcruc~:a1nce·the Caroline Transformer site is on_ the'fringe of:a heavi~y · -''·"·populated area··and it is possible that contaminated groundwater could be _.,.. _".,,{·.I'._~:;,.:' -·:uwar~,~y.~uaed in _the area; ' .
. _:-._;,. -~ .. Baaed-on thl! information gathered during the groundwater monitoring -,:· _:, '.p.rogram,. the·Groundwater Section, Division of Environmental Management,
''• . . . ,\ ~ ... ;.-_ North.' Car°olina Department of Natural ·Resources & Community Development . \'.couid;:reclassify the area accordingly to try and prevent -inappropriate ·.·.:·uilc if·restoration .is not economically feasible, ,... . . . '
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Mr; Bob Jourdan.c
Page 2 •.•
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Your assistance in this ~tter would. be greatly apprediated/·· If you
:have any questions or need additional information.:pieasl!_C!>!',tact·me at
(919)4!16-1541.
MJN/gcc
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Sincet_ely •
'.ORIGINAL SiGNE[>:BY
MARION J. N.OLAND ' ..
·.· M, J. Noland
· , Regional Supervisor
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OOC Report
carolina Transformer Ccmpany, Fayetteville, N<ilrth Carolina E)jward L, Hatcher, a;c Dennis Manganiello, Project Officer
Background
After the roadside dUTipil"¥J of FCB oil in July of 1978, the Fayetteville Regional Office began receiving oooplaints fran a resident that lived near the Carolina Transformer catpany (ere) site on River Road. The residents were concerned about the possibility of ground water contamination fran the transformer site since they were on wells, The analysis fran the well sanples did not show any FCB contamination, however, several contaminants were found in two private wells in the inrnediate area, one of the wells, located with 250 feet of the site, showed significant concentrations of chlorobenzene, a pCB carrier fluid, aoo the second well which is located 1000 feet fron the site showed trace azrounts of the chlorobenzene carriers. A short time later the City of Fayetteville ex-tended water lines into this. area. At the present time residents and businesses in this inrnediate area are on city water, A total of twelve (12) wells were sanpled by EPA in NOVember 1978 and March 1979 in the vicinity of the Carolina Transfonner Q:n1pany site. Two of those sampled were contaminated as was previously mentioned in this paragraph. A recent check was made with the City of Fayetteville's PUblic W::>rks Department and it was determined fran talking • with the attorney for Carolina Transformer Ccmpany, Mr. [).lane Gilliam, that Carolina Transfor:mer Canpany paid for the connection of the residence of Mrs. Bessie Edge, onto city water. The remaining connections were not paid for by Carolina Transfor:mer Canpany.
Following this investigation, the Fayetteville Regional Office and EPA collected a series of soil surface water samples fran the Carolina Transformer Ccmpany site. This sarrpling verified the presence of pCB ooth in the soil and surface water on this site. During this period of time Carolina Transformer O:nipany had re-tained ROSe and purcell, Inc,, consulting engineers to work on a proposal to clean the area or to treat the surface water runoff, In a letter dated August 22, 1979, EPA advised Carolina Transformer Ccmpany that rem::>val would not be mandated since ere indicated that the material had been spilled prior to April 18, 1978, when the TOxic Substances Control Act ('IOSCA) became effective. However, EPA also indicated that storm water runoff fran the site would have to be controlled, under present TOSCA criteria, a concentration of PCB in the soil of SO m;i/kg or greater would be considered to be PCB contaminated. soil sampling done by Natural Resources and camrunity oevelopnent and EPA in 1979 (Exhibit A) approxbro.tely 1 to 1 1/2 acres of the site appear to be contaminated in excess of SO 119/l<g.
Fran late 1979 until the present, contact was maintained with ere about the need to correct the problem, but no progress was made. The consulting engineers are no longer retained by ere.
on March 3, 1982, Mr. Kerr T, Stevens, Environmental Engineer, Fayetteville Regional Office visited the ere River Road site and oollected a surface water sarttile in the headwaters of an unnamed tributary to the Cape Fear River which receives runoff fron the CTC side.
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The analysis of the March 3, 1982 sample showed a PCB ooncentration of 15 parts per billion. A second visit made to the site on April 27, 1982 and another surface water sairple was collected at the same location. The analysis of this sample sho.led a PCB a:incentration of 40 parts per billion. The matter of clean-up of the River Road site was discussed with Mr. Strother, but he did not seen to have any particular plan in mind for the site.
The sampling which was conducted in March and April 1982 did establish a violation of the water quality standard for PCB which is 0.001 parts per billion. In a letter to ere dated May 10, 1982 the canpany was advised ot' the surface water violations and it was requested that they contact to arrange a meeting to discuss the cleanup of the site. Mr. Strother stated that they did not know what to do and he did not think that their canpany oould afford to clean up the site. Mr. Strother did however, agree to look into the matter.
No proposal was ever subnitted and a seooncl letter was sent to ere requesting that the ccmpany show cause on Septerrber 3, 1982 as to why enforcement action should not be taken, The September 3rd meeting was held and the matter was discussed with Mr. Dewey K. Strother and Mr. Kenneth Strother of carolina Transformer Q:rnpany. It was agreed that the canpany would contact several oonsulting engineers or contractors about the site cleanup and would then sutrnit a proposal. On November 8, 1982, Mr. Kenneth Strother was contacted about the agreed upon proposal and he stated that they just oould not find anyone that could advise them on cleaning up the site. He again indicated that a cleanup would be cost prohibitative. At this point it appeared that an enforcement action was the only option.
EPA Enforcement Action
The site consists of contaminated soil located on and adjacent to the Ccrnpany's old transformer storage area. A large po.tion -0f the site is situated on property owned by the heirs of the Honbarier estate. Known potentially respon-sible parties include the facility owner/operators De',ley Strother and his son Kenneth Strother, and the adjacent property owners Roxie Honbarrier, Frances Honbarrier Davis, B.G. Honbarrier and carolyn Honbarrier White.
EPA attempted to address the problem through TOSCA and the CWA, however, neither act gave EPA the authority to require reiroval of the contaminated soil or proper closure of the site. In 1984, EPA issued a CERCLA 106 Qrder to the facility requiring the renoval and proper disposal of contaminated soil. After the canpany refused to undertake the work, EPA determined that imnediate removal action was necessary and appropriate. on August 1984, EPA began clean-up activities at the Carolina Transformer Site in Fayetteville, North carolina.
Although the landowners of the property adjacent to the site are potentially responsible parties, enforcement efforts have been aimed at the canpany because they appear· to be financially viable and because problems at the site appear to be caused solely by the acts or anissions of the owner/operators·. In addition, the landowners probably have a strorg 107(b) (3) defense in that they inherited the property after the contamination had occured and there is no evidence of a contractual relationship, existing between the present and past owners and the facility. If enforcement or cost recovery efforts against the canpany are unsuccessful, EPA may reconsider the efficacy of pursuing the landowners.
Site rescription
This site is situated at the headwaters of the unnamed tributary. The general area is low lying, semi swampy with a oonsiderable amount of standing water observed on the ere site. The surface water drainage fran the ere site flows through an 18 inch culvert under a dirt road at the southwest side of the site. Fran this point the water flows through a natural stream channel approximately 18 to 24 inches wide through another swampy area then into a tributary approxinately 4 feet in width. The flow fran this site travels approxi.nately 1 1/2 miles to the Cape Fear River just about the City of Fayetteville's wastewater discharge, about 1/4 mile upstream of U.S. 301 bridge. This tributary is bordered on one side by cx:mnercial developnent and on the other side by farm land. Public access is sanewhat limited to the tributary due to little residential developnent in this area. (NOte map on following page).
Hazardous Substances Involved
The results of the soil sample analysis done in' June 1984, indicated that the soil was contaminated with PCB's (Aroclor 1242 and 1260) and related carrier a::rnpounds -trichlorobenzene, dichlorobenzene, and pentachlorobenzene. The oon-centration of PCB found at the surface ranged fran 106 mg/kg to 20,000 mg/kg continuing to a depth of 8 inches.
The effects on human health of the oontaminats detected are: a. Aroclor 1242 and 1260 animal carcinogens.
b. Pentachlorobenzene is a teratogan & carcinogen.
c. Dichlorobenzene has been known to cause liver and kidney damage. Trichlorobenzene is a.mild irritant to skin, eyes and muoous membranes. In sunrnary, acute chronic human exposure to the identified chlorinated benzenes can result in skin, lung & mucuos
membrane irritation, liver, kidney damage and CNS effects.
Additionally, these canpounds, especiallydichlorobenzene, are toxic to non-human mamnals, birds & aquatic organisms. They are also import an offensive taste and odor to water.
Site-Cleanup
Cleanup operations began August 13, 1984 and were canpleted August 22, 1984. The project included several actions; dewatering the oontaminated swampy area, solidifying the remaining PCB/oil sludge, excavating and disposing contaminated soil, arranging disposal and transportation for solidified wastes, backfilling the area and grading the excavated area.
A total of sixty-four loads (approximately 975 tons) of PCB contaminatP·-was rerroved fran the site and transported to the Chemical Waste Mar-disposal facility in 0nelle, AL. The excavated areas were back". tons of locally procured fill dirt.
Project Cbst
The soope of work was estinated to oost $340,000. A, for $200,000. Remaining funds ($140,000) were ccmnitt,
rrounting transportation cost. A breakdown of project
· cost is tabulated below:
Total Extranural Cost:
Personnel $ 14,845 Equipnent 10,084 Material 3,200 Analytical 600 Transportation 118,600 Disposal 121,418
TOtal $ 268,747
O,nclusions/Lessons Learned
1. samples taken after the excavation showed PCB contamination up to 140 ppn. These samples were taken at depths where previous samples had indicated very low contaminations. It appears fran these results that the rerroval activities (heavy equipnent operation) tended to push the contamination further down into the soil. This problem was the result of the soft swampy area where the najor contamination was located. The ocs, after consulting the state osc, concluded further excavation would not be cost effective because of these problems. The cleanup operations resulted in a 99% reduction (20,000 ppn to 140 ppn) of the on site contamination.
2. Incident Obligation I.cg serves no useful purpose where the rejority of changes are "await bill" and should be discarded fran the project file for future jobs.
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DIVISION OF ENVIRONMENTAL MANAGEMENT
Mr. Bob Jourdan, Chief
Investigation Unit
ERRB
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Jourdan:
January 13, 1987
SUBJECT: Site Cleanup/Groundwater Status
1. Cape Fear Wood Preserving
Fayetteville, Cumberland Co., N.C.
2. Carolina Transformer
Fayetteville,Cumberland Co., N.C.
3. Macon Site
Rockingham, Richmond Co., N.C.
4. Aberdeen Pesticide Dumps
Aberdeen, Moore Co., N.C.
The four subject sites underwent emergency cleanup activities in the
last few years. Cleanup was stopped at the Macon site and some material
temporarily secured in an onsite lagoon. Tanks remain at the Cape Fear
Wood Preserving site which contain hazardous liquids with a potential for
spills due to vandalism, tank deterioration, or overflow due to rainfall.
The Carolina Transformer site cleanup is considered complete as far as EPA
is concerned. The Aberdeen pesticide dump cleanup is on-going with
evaluations being made concerning the feasibility of incineration as a
disposal option.
There continues to be concern about the status of the groundwater in
the vicinity of these cleanup sites as well as when cleanup is anticipated
to be completed. The concerns at each site are as follows:
1. Cape Fear Wood Preserving -When is site cleanup to be completed
and when are recommendations to be made for groundwater remedial
action based on the groundwater investigation completed during
1985.
2. Carolina Transformer -When is a groundwater investigation to be
scheduled for this site (see attached letter).
Mr. Bob Jourdan
Page 2
January 13, 1987
3. Macon Site -When is cleanup to be completed at this site and a
groundwater investigation conducted.
4. Aberdeen Pesticide Dumps -An area-wide groundwater investigation
needs to be completed to determine the connection, if any, between
scattered pesticide dumps and Lindane contaminated municipal
wells.
Any information that you have as to when these concerns are to be
addressed would be appreciated. If you need assistance in gathering
additional data or information, we will help to the extent that we can. I
can be reached at [phone] if necessary.
MJN/lcr
Attachment
Sincerely,
OR\G\i'!N. sv:+'tD [l'{
Mfa-.KiCi•! J. i'--;0LAl'1D
M. J. Noland
Regional Supervisor
IMR.Incidents.2
Lat.(Deg:MinlSec):
Reason for Incident:
Source Permitted:
Source on ERRIS List:
Permit Type: Ownership: Actions Taken Summary:
Incident Occurred: II I II I ,, Incident Reported: iry: I PIRF Submitted: II 111 II Incident Report Submitted:
One Page Action Plan: U:t~l-tl Monitoring Pgrm. Implemented:
RS Designation: Remedial Action Implemented:
Close-out Report: ao,•. a/ r; Reclassification Report:
Long.(DeglMinlSec):
Source in Use:
Permit No.:
ERRIS No.:.l>"0.3lBli'8~f
Operation Type:
Incident Phase: ~ ~
Target Date:
IMR.Incidents.l
In~ident No.: "3_~8'_,~--.~ ,.._. cJ.r ,-,.,,.n1~.L-'r.,, Type of Action: Incident Name: ~--.,..,.....V-
Contaminated Well:
Incident Address:&Rt7lij. . A J _ City/Town: q--.-.. ,'rh;_,,;,Jl.Q_p. County: CJ.vYTW< Region: Fo/ Incident.Summary: ~----
Pollutants Involved:
Amount Stored:
Amount Lost:
Amount Recovered:
Reported By (code): :J... PC!.. 13 • ~ c..c¼, Br-,JV-'-J-ir-1
Lab Samples: 1
Vertical Migration: Horizontal Migration: Areal Extent: Probability of Violations: Remedial Action Priority: Potential Hazard of Substance: Threat to Drinking Water: Seriousness of Threat: Overall Regional Concern: Rank Score: Source of Pollution: II Multiple Source: J Pollution Confirmed: Type of Pollutant: I\ Location: I Setting:_
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G R O U N D W A T E R P O L L U T I O N S O U R C E E V A L U A T I O N
RANKING CRITEP.IA
THREAT TO GROUNDWATER THREAT TO PEOPLE OR ECONOMY THREAT OF POLLUTANTS ------
Probabi 1 ity of Groundwater Violations How Hazardous to Health/Economy How Toxic are Pollutants (use Sax)
{J Vi.olations documented or highly probable O' People or business advised of contamination 0) High value
2 Default 2 Default 2 ft1od value
1 Violations unlikely 1 No expected impacts on people or b~siness 1 Low or None value
Extent of Groundwater Contamination Number of People at Risk nuantity of Pollutants in Ground
3 Mappable, 'migrating plume 0 4 or more family units, or $10,000 loss 3 Reportable quantity of hazardous material
(CERCLA def.) or quantity of real concern
(3' Default 2 Default Q Default
1 Insignificant contamination expected 1 No people or other interests at risk 1 Not of concern to regional office
Seriousness of Groundwater Threat Seriousness of People Threat Seriousness of Pollutant T!':reat
~ One of most serious in DEM region Qi Strong DEM concern over threat to peep 1 e 3 One of most serious in OEM region
6, 2 Default 2 Oefaul t Def au 1t
1 Not considered a serious problem 1 No threat to people or economy 1 Not a serious threat
FEASIBILITY FOR TAKING ACTION FEASIBILITY OF RECLASSIFYING GROUNDWATER RANK SCORE:
Feasibility for Remedial Action Need to Reclassify Frou ndwa ter
a" ~ ·.~ I 3 Remedial action both feasible and desirable 3 Groundwater should be relassified RS or GC Source Name: . .
@ G 11-
Default Default
o2 38'~ 1 No remedial action recoITTTiended 1 No reclass. nor remedial action recorrmended Control Number:
Desirability of Remedial Action Desirability of Reclassification
~-G) One of top regional office priorities 3 One of top reclassification priori ties County: r,)~6
2 Default 0 Default Ranker: 6&-•
1 Not a priority incident 1 Not a priority incident Date:
!3s~berl County Number GROUNDWATER POLLUTION SOURCE INVENTORY Oc?-(,,
Source Name cA~IJl/1 7J!/I II 5 Ft)ie/1162--u,,1(/ OWNERSHIP
@,Private Source Addr°'J?./f)fii'Jl '.Kc>J9..l) ( SI. /7 /<I) 2 Municipal
3 County City
P/9-Y€7T€/// //G' I c°'c!AmBcR,L/1-N/) r Re~• 4 State
5 Federal
Owner/Operator 6 Military
/j Quad Name I Mun 1ple Source($ '.:)1te county :,ource N s YES
POTENTIAL SOURCE OF GROUNDWATER POLLUTION
LOCATION OPERATION TYPE TYPE OF WASTE DISPOSAL FACILITY OTHER SOURCE
{) Facility 1 Municipal 1 Gasoline/diesel 1 Lagoon, etc. 1 Agricultural Activity
2 Highway (Ji Industrial 2 Other oil 2 Landfill-contra. 2 Salt water intrusion
3 Rail road 3 Agricultural 3 Solvents (D Landfil 1-uncont. 3 Chemical stock pile
4 Waterway 4 Oil and gas 4 Corrosives 4 Land application 4 River infiltration
5 Pipeline 5 Mining @other chemical 5 Abandoned site 5 Mine drainage
6 Dumpsite 6 Other Source 6 Sewage/septage 6 Sewer system 6 Intentional dump
7 Other 7 Sludge 7 Septic tank 7 Spill
8 Leachate 8 Injection well 8 Leak--above ground
9 Other solids 9 Disposal well 9 Leak--underground
(i;> In use 10 Gas WASTE: STATUS OF SOURCE: 2 Inactive 11 Pest/herbicides
3 Other 12 Fertilizers ?CB
POLLUTION STATUS AND CROSS-REFERENCES
GROUNDWATER POLLUTION FACILITY PERMITTED: Yes No
~ Confirmed CY Rank 1 NPDES 6 Mining
Potential 2 Tabulate No: No:
MONITORING WELLS 2 DEM Nondischarge 7 Hazardous Waste (RCRA)
0 No: No: No monitoring
2 State has data 3 Well Construction 8 Solid Waste (Landfill)
3 Data at facility No: No:
4 Status unknown
4 Capacity Use 9 Oil Terminal Registration
DATABASE CROSS-REFERENCE No: No:
l ERRIS (CERCLA) list 5 UIC ~ Air Quality
ID: (VC/J (),()"~ I 'l' f7',zgq No: No:
2 Surface lmpoundment (SIA) Conments G'f ,1 1fiVc/ve/ ID: IS /,'/ c.leM-"17
3 GW Pollution Source Inv.
Date:
4 Other DEM investigation
Date: Compiler: Date: